Processed meats: What are the labelling requirements?
After a number of changes to the regulations governing processed meats in the recent couple of years, the industry has since had to grapple with five different regulations, specifications and standards to ensure that they are labelling their products correctly – not an easy task.
The regulations, specifications and standards:
The complexities surrounding the labelling of products in this category start with the large number of regulations that must be considered:
- The Regulations Relating to the Labelling and Advertising of Foodstuffs (R. 146/2010)
- Labelling requirements for pre-packaged products (pre-packages) and general requirements for the sale of goods subject to legal metrology control, South African National Standard, SABS Standards Division (SANS 289:2016)
- Compulsory Specification for Processed Meat Products (VC 9100)
- South African National Standard for Processed Meat Products (SANS 885:2011 Ed.3)
- The Regulations Regarding the Classification, Packing and Marking of Processed Meat Products (R. 1283/2019)
PLEASE NOTE: Products such as minced meat, burger patties and sausages are covered by the Regulations Regarding the Classification, Packing and Marking of Certain Raw Processed Meat Products (R. 2410/2022). These products must only comply to regulations 1 and 2 listed above in addition to R. 2410.
What does each regulation or standard cover?
Firstly, it’s important to note that this discussion relates to the labelling of prepacked processed meats only. It does not include un-prepacked meat products, canned meats, or raw processed meat products (minced meat, burger patties and sausages).
The Regulations relating to the Labelling and Advertising of Foodstuffs should be consulted for the minimum information that is required to appear on all food labels: product name, ingredient list, storage instructions, instructions for use, net content (which refers to SANS 298), date marking, batch numbering, country of origin and the applicable address. As a quick reference, download our infographic showing the minimum requirements for all food labels.
The Compulsory Specification for Processed Meat Products (VC 9100) and the South African National Standard for Processed Meat Products (SANS 885) should be read together. As SANS 885 is mentioned in VC 9100, it changes from a voluntary standard to a compulsory standard. All aspects included in SANS 885 must be adhered to, except for the compositional requirements. Topics addressed include: requirements for the factory; requirements for ingredients and the finished products; microbiological requirements; chemical requirements; and packing, marking and some labelling requirements. Labelling considerations from SANS 885 cover storage conditions, date of manufacture, and manufacturer details.
For compositional requirements, please refer to the Regulations Regarding the Classification, Packing and Marking of Processed Meat Products (R.1283). These also include some labelling requirements, including: product name; address and telephone number; date and batch marking; and country of origin.
You will note that for certain requirements (including letter sizes) there is an overlap between the various regulations and standards. For example, date marking is addressed in SANS 885, R. 1283, and R. 146. You can try to adhere to all of them equally, but as a general rule the more specific regulation trumps the rest.
Enforcement:
Ensuring that the requirements of the various regulations are met is not enforced single-handedly, as these regulations all fall under different regulatory authorities. Apart from the general labelling requirements, enforced by the Department of Health, the Department of Trade, Industry and Competition (DTIC) and the Department of Agriculture, Land Reform and Rural Development (DALRRD) are also involved; specifically, through the National Regulator for Compulsory Specifications (NRCS) and the Food Safety Agency (the appointed assignee) respectively.
The large number of regulations that must be considered makes ensuring your processed meat products are correctly labelled a particularly tricky challenge.
FACTS has a regulatory team made up of dieticians and food scientists who can assist in ensuring your labels are compliant with all of the relevant regulations, across all the government departments. Contact us for more information.
Other articles you may be interested in:
Gelatine in comminuted processed meat products
Meat regulations: The Meat Safety Act (Act 40 of 2000)
Meat fraud: Testing to detect species substitution
Testing Catalogue
Regulatory and Nutrition