How should the ingredient be described and quantified?
In most cases, a food will be labelled with a list of ingredients. The QUID
declaration should therefore relate to the ingredient in the form in which it is
described in the list of ingredients.
Where a food does not have a list of ingredients (e.g., foods sold loose and
not pre-packed) the QUID declaration will appear alongside the name of the
food (whether this appears on a ticket or notice etc, or on the food itself) in a
form such as “contains x% pork” or “x% pork”. The QUID declaration should
therefore relate to the ingredient in the form in which it is described in this
declaration. There is no need to QUID excess fat or connective tissue in this
In general therefore, where an ingredient is described as simply meat from the
named species (e.g., “beef”, “lamb”, “pork”, “chicken” etc) the QUID
declaration will be based on the new definition of meat. Therefore any excess
fat or connective tissue present in the ingredient cannot count towards the
QUID declaration. It is possible therefore that the actual amount of meat
declared is less than the weight of the meat ingredients
However, there will also be instances where the new definition will not apply –
because of the nature of the meat ingredient, or the way in which that
ingredient is described. These will fall into four areas – as described below:
It is important to note that the minimum meat content required by the reserved
descriptions will continue to apply in terms of meat according to the EU
definition, regardless of how the ingredients are described or QUIDed
(i) Animal-derived ingredients not covered by the definition of meat
Many parts of the carcase not covered by the new definition are commonly
used in traditional meat products. Some examples include kidney in pies;
liver and tongue in patés and sausages; oxtail in soups; and feet and head
meat in products such as brawn and potted head. In addition, ingredients
such as MRM, head meat and heart are often used in processed meat
products. The definition of head meat excludes masseter.
These ingredients must be declared separately in the product’s list of
ingredients. The ingredient in question must be described specifically, and
not by a generic name such as “offal”. The species source must also be
declared: e.g., “beef heart”, “pig’s kidney”, “lamb’s liver”, “Mechanically
Recovered Chicken”, “pork head meat”, etc.
(NB – none of these ingredients may count towards the meat content for the
purposes of complying with the minimum meat content requirements of the
reserved descriptions – however where a product is described as “tongue
sausage” or “liver sausage” or similar, no minimum required meat content
(ii) “Specific cuts”
Manufacturers may choose not to use generic names such as “beef”, “lamb”,
“pork” etc, but instead to describe a meat ingredient according to the specific
cut of meat used. Some examples might be “chicken breast”, “beef brisket”,
“loin of lamb”. Where ingredients are described in this way, the European
definition will not apply.
The name used to describe a “specific cut” must be specific, familiar and
understood by consumers. The FLR require that a name used to describe
an ingredient must be a name that could be used to describe that ingredient
were it being sold as a food in its own right. As a general rule therefore, the
name used to describe a “specific cut” may be considered acceptable where
that name is also used to describe that meat ingredient when sold as fresh
meat (e.g., in butchers’ shops and similar outlets).
In addition, the European Commission recommended that Member States use
CLITRAVI’s (Liaison Centre for the Meat Processing Industry in the EU)
guidance as a basis for national guidance. Therefore in line with this
recommendation, the Agency recommends that where “specific cuts” are used
to describe meat ingredients in comminuted meat products such as sausages
and burgers then the maximum limits on fat and connective tissue in the meat
Where a QUID declaration is provided in relation to a “specific cut”, the
declaration must be based only on the meat that is from that declared cut
(e.g., the declared quantity of “chicken breast” must not include any meat that
is not breast meat). In addition, the declared quantity must not include any
skin or other tissue that is not attached to the muscle meat. (See also
paragraph 13 below relating to “bone-in” cuts).
(iii) Dried or cooked meat ingredients
Where the meat ingredient is described in the list of ingredients (or declaration
where there is no list of ingredients) as having been cooked e.g., “fried
chicken”, “roast pork” etc., the limits for fat and connective tissue will not
apply. The QUID declaration will therefore be based on the weight of the
cooked ingredient at the time of its use in the recipe.
Manufacturers may if they wish base the QUID for such ingredients on the
weight of the raw equivalent, provided that the basis of the declaration is
made clear to the consumer. Where a “raw equivalent” is declared, and the
meat is described using a generic description (“pork”, “beef”, “chicken” etc)
the limits for fat and connective tissue will apply.
It is possible that a product may contain cooked and uncooked meat from the
same species. In which case, the manufacturer may choose either to QUID
the cooked and uncooked meat separately, or to provide a single QUID for the
all the meat ingredients of the same species, based on the raw equivalent.
The MPR define “cooked” as it relates to whole meat products as: ”subjected
to a process of cooking throughout the whole food so that the food is sold for
consumption without further cooking”. This definition is also useful in defining
what constitutes a “cooked” ingredient. An ingredient should only be
described as cooked (and QUIDed on that basis) if it has been thoroughly
cooked and could be consumed without further cooking. This would therefore
exclude ingredients that have been merely flash fried, lightly seared etc., from
being described as “cooked”, and QUIDed on that basis.
(iv) Compound ingredients
A compound ingredient is a food used as an ingredient, that is itself made up
of a number of ingredients. Some examples would be “sausage”, “ham” and
“bacon”. A compound ingredient will usually be an ingredient that the
consumer would recognise as a food in its own right, and which would also be
sold on its own.
A QUID for the compound ingredient will be required where it is referred to in
the name of the food (e.g., “chicken and ham pie”, “bacon sandwich”) or
where it is usually associated with that food (e.g., sausage in “toad in the
The QUID declaration should relate to the ingredient as described (either in
the ingredients list or point of sale declaration). For example, in the case of
“chicken and ham pie” and “pepperoni pizza”, the QUID declaration should be
based on the weight of the ham and pepperoni respectively, at their time of
use in the recipe. It is not necessary to quantify the meat itself, either as a
percentage of the compound ingredient, or of the total product.
There may also be instances where the meat ingredient is described
generically in the name of the food, but is declared as a compound ingredient
in the list of ingredients. A QUID based on a compound ingredient will of
course be greater than a QUID based on the meat content of the whole
product. Care must therefore be taken to ensure that providing a QUID on
this basis does not mis-represent the true composition of the food.
6. How is the QUID declaration calculated?
The QUID declaration informs the consumer of the quantity of ingredient
used, as a proportion of the final weight of the product. The QUID declaration
is therefore calculated as follows:
declarable weight of ingoing
QUID (%) =
NB – the “declarable weight” means the quantity of the ingoing ingredient that
may be counted towards the QUID declaration. This will not necessarily be
the same as the actual weight of the ingoing ingredient – because where the
QUID is provided on the basis of the new definition, any excess fat and
connective tissue may not be counted towards the QUID.
7. “weight of finished product”
In this context, the “weight of finished product” means the weight of the
product when sold. This will not necessarily be the same as the combined
weight of all the ingredients. Cooked products for example will often lose
moisture in the cooking process – resulting in the final product weighing less
than the sum of the ingredients.
8. “the ingoing ingredient”
As discussed in paragraphs 5 and 6 above, the QUID declaration must relate
to the ingredient as described in the list of ingredients, and this in turn must be
linked to the way that ingredient is named in the name of the food. The
following diagram shows how the “ingoing weight” is determined, depending
on the type of ingredient to which the QUID declaration relates – which will be
(a) an animal-derived ingredient not included in the definition – (e.g.,
“liver”, “kidney”, “tongue” – see also paragraph 5(i) above)
(b) a “specific cut” – (e.g., “chicken breast”, “pork belly”, “sirloin steak” –
see also paragraph 5(ii) above)
(c) a cooked or processed meat ingredient – (e.g., “fried chicken”, “roast
pork”, “smoked [pork]” – see also paragraph 5(iii) above)
(d) a compound ingredient – (e.g., “sausage”, “ham”, “bacon” – see also
paragraph 5(iv) above)
(e) “meat” within the meaning of the definition – (e.g., “beef”,
How is the “declarable weight” determined?
* Annex B, paragraph 1 below tells you how to find out if you have excess fat
and connective tissue.
(e) “meat” within the meaning
of the definition.
The “declared weight” is simply
the weight of the ingredient at
the time at which it was
incorporated into the food.
The QUID declaration is
weight of finished product
You do not need to use the
calculations in Annex B
Do any of the meat
ingredients contain excess
fat or connective tissue?*
The “declared weight” will be the weight of the meat ingredients minus any excess
fat and / or connective tissue. (This is because excess fat and connective tissue
cannot be counted as “meat” towards the QUID declaration). The “declared
weight” will therefore be less than the total weight of the meat ingredients
The calculations at Annex B enable you to determine how much excess fat
and connective tissue you have, and therefore how much of the meat
ingredients can be counted towards the “declared weight”.
(d) A compound ingredient
(b) A “specific cut”
(c) A processed, dried or cooked
(a) An animal-derived ingredient
not included in the definition
How should the QUID declaration be presented?
In most cases, the QUID declaration will be expressed as a percentage. The
declaration must appear on the labelling either in or next to the name of the
food, or in the list of ingredients in connection with the ingredient in question.
In the case of meat products sold non-prepacked, or prepacked for direct sale
the QUID declaration should appear either on a label attached to the food, or
on a ticket or notice that is readily discernible by an intending purchaser at the
place where he or she chooses the food. (This could include point of sale
ticketing, posters etc.)
11. What if the QUID declaration is more than 100%?
Regulation 19(4) of the FLR provides for situations where, because a food
has lost moisture as a result of treatment, the quantity of an ingoing ingredient
is greater than the weight of the finished product (i.e., where a QUID
declaration would be greater than 100%). In such cases, the QUID
declaration must indicate the weight of ingredient used to prepare 100g of
One example of such a product is the food covered by the reserved
description for corned beef, which is produced by pre-cooking beef (which
loses fat and moisture) then sterilising the product. This in effect produces a
concentrated meat product.
The reserved description requires that corned meat has a meat content of
120%. Therefore an example of a suitable QUID declaration for corned beef
would be as follows:
Corned beef: - Made with 120g of beef per 100g of finished product
12. The list of ingredients – Description of excess fat and connective
The FLR require (with certain exceptions) all foods sold pre-packed to be
labelled with a list of ingredients. The ingredients must be listed in
descending order of weight at the time of their use in the food. Where a meat
ingredient contains excess fat and connective tissue, this must be declared
separately in the product’s list of ingredients. Where the product does not
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