A Rant: A fat lot of use

© Nichola Fletcher 2004  Published by Guild of Food Writers 2004

This year new regulations for labelling meat products came into force.  The idea behind them is to make it easier for consumers to make an informed choice based on the information provided on the labels. So far, so good.   The previous regulations worked on the basis of listing all ingredients in descending order of weight, and requiring products to comply with 'minimum meat content' declarations.  In that context, the word 'meat' included not just muscles tissue but anything that was of animal origin: offal, skin, MRM, and other parts of an animal that many would rather not know about but which have been used widely in 'budget' products and in the catering trade who don't have to list their ingredients. Oh, and fat was counted as 'meat' too.

The new regulations require separate listing of offal, MRM and any added fat.  Labels must now also list the percentage of actual 'meat' and also the percentage of any other ingredient listed in the title, such as apples, leeks, etc. "Hooray!" we cry. 'Meat' on labels at last means lean muscle tissue (visible lean or VL as it is known in the trade).  But hold on, I'm afraid it doesn't. Someone – I wonder who? - has 'got at' the new regulations. 

Now our venison has very little fat (anywhere from 1-5%) so we have to add some to lubricate the sausages (currently we use 10 - 12% rare breed pork fat). But sometimes there is a little, especially in the late summer in which case we adjust the fat accordingly. Traditionally, the accepted norm was about 30% fat for sausages but nowadays many prefer lower fat contents.   So when my helpful EHO came round to show me how to calculate the new labels, I asked him how I should calculate the amount of fat in the meat trimmings if it varies from time to time.  To my astonishment, he said, "Oh, you're lucky, you won't need to worry about that. Your meat is very lean isn't it – 3 or 4% maybe, and you are allowed to have 25% fat included in the 'meat' before you have to declare it on the label so long as the fat is from the same species." Let me repeat that: 25% fat is allowed in 'red meat' (30% in the case of pork) before it has to be declared as fat on the label.  Lucky? I almost fell off my chair.  

For us and anyone else making products out of very lean meats, the new regulations mean that, because we have to add fat that isn't venison fat, we have to list it on our labels. We always did, so that's not the problem.  The problem is that, unlike sausages made from fatty meat, our added pork fat cannot be included in the percentage of venison 'meat'. Let's make a theoretical a sausage that contains, say, 68% venison. If we say the fat content of this 68% is 3%, that means 1% of the total ingredients is fat & 67% is lean meat. Then suppose we add our 12% rare breed pork fat, the total fat content is 13%.  Our label must now read 'venison (68%), pork fat, oatmeal, spices'.  However, had that pork fat been venison fat, the 'meat' content would increase to 80% and no fat would need to appear in our ingredients. 

Thus someone making sausages from traditionally fatty meats like pork, or domesticated wild boar, can sell a sausage in which the 'meat' contains 30% fat but yet the label could legally declare "pork (80%), rusk, spices, no added fat." It therefore appears to have a higher 'meat' content and no fat at all, when in fact the reverse is true: 30% fat and 50% meat. Indeed with any sausage that actually declares added fat from the same species, it will be much worse. e.g. a label reading 'pork (80%), fat (10%), rusk, spices' will really contain 40% fat. But the consumer will have no way of telling that. Great, isn't it?  I think it is about time I retired from this artisan food malarky and became a full time food writer….