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Labeling of added proteins in meat products as per (EU) No 1169/2011

labelingRegulation 1169 added protein labeling

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#1 YanislavValev

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Posted 24 August 2018 - 11:41 AM

Dear all,

 

Working as a quality assurance specialist in Bulgaria, my job also includes labeling verification of all products that our company manufactures.
Currently I am facing a challenge regarding labeling of meat products with added dairy protein as an ingredient.
 
Here's the thing: we produce many different types of meat products which contain added dairy proteins as ingredients and until now they were all labeled  According to Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, Annex VI Name of the food and specific accompanying particulars, Part A —   Mandatory particulars accompanying the name of the food, 5. In the case of meat products, meat preparations and fishery products containing added proteins as such, including hydrolysed proteins, of a different animal origin, the name of the food shall bear an indication of the presence of those proteins and of their origin. For example 'Air-dried Salami, with added dairy protein'.
 
However it turns out that none of our competitors does the same. Our Marketing department did a research with more than 70 different product, including products from Italy and Spain, and none of them was labeled 'with added dairy protein'.  Now we are being pressed to edit the labels and to remove the 'with added dairy protein' text from the name of the products so they look more 'natural', like our competitors' ones.
 
I'd like to ask if any of you have experienced anything like that? If you produce meat product and you use a dairy protein as an ingredient in it, do you add 'with added dairy product' to the name of the product? If not, how do you interpret this legislative requirement in order not to do? I mean specifically dairy proteins.
 
Thank you,
Yani
 
 


#2 Scampi

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Posted 24 August 2018 - 02:20 PM

are you 100% sure that your competitor ARE using protein from another animal source?  

 

There is zero room for interpretation.....the law is the law and it specifically (and clearly) states that you must label it accordingly (whey protein, hydrolyzed soy protein etc)

 

Did the marketing folks send samples out for analysis or just read labels????????????   Don't ask sales people for scientific facts.......just because it's not on the label does not mean it's in the product


Because we always have is never an appropriate response!


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#3 FurFarmandFork

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Posted 25 August 2018 - 03:33 PM

Agree with Scampi. Marketing people LOVE to show you how competitors aren't doing what you say they have to.

 

1. Unless they can prove that the labeling is incorrect, they have no way of knowing.

2. Just because the government sucks at enforcing labeling regs, doesn't mean they don't. And big companies get in trouble for labeling stuff all the time, to say nothing of the class actions.

3. When it's a labeling issue, first determine whether it's a matter of food safety (e.g. allergen or ingredient declaration). If it is, then foot down and don't continue to work somewhere that will make those decisions.

4. If it doesn't pose a food safety risk, then present your case for company liability and what the implications would be. Your job is to keep the company out of trouble, marketing's job is to sell the product. Write everything down and make the marketing folks (or whomever has the final call) put it in writing if they think it's the right decision. All you can do is your job and explain the risks involved. If they want to open themselves up to enforcement or other liability, then make sure that in writing you have informed them of the risk.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

#4 YanislavValev

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Posted 26 August 2018 - 09:30 AM

Thank you guys for your comments.

Scampi, all of the samples of other products that we’ve checked do contain dairy proteins and this is clearly stated in the ingredient lists. Thus we haven’t sent out samples to lab. We don’t question other manufacturers whether there’re dairy proteins in their products if their labels state they do, right? :)


FurFarmandFork, I believe it’s not a matter of food safety because the presence of dairy protein (also marked as an allergen) in the products is clearly declared on the labels. I have already done everything you mentioned in pt 4. Despite all the risks I explained the management still wants to proceed to change our labels. And now this is something beyond me.

My question is more about how others skip to add this information (‘with added dairy protein’) to the name of the product according to the requirement of Regulation1169/2011 that I quoted in my first post.



#5 Scampi

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Posted 27 August 2018 - 01:26 PM

Perhaps it's sheer ignorance.....I mean they are not aware of the law (even though they should be)


Because we always have is never an appropriate response!


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