Our Nutritional labelling concerns

When a butcher makes a product like a pork sausage they utilise different parts of the carcase depending what is available. One day it may be shoulder or belly pork trim, other days it could be pork leg – it depends what has and has not sold. The pork ingredients will be made up to a set visual lean (VL) right for making the product to that recipe.

However the different cuts have different nutritional values, this will affect what should go on the pack (should it be stated as a typical nutritional value). Butcher shops have always been a good example of business making sure waste is at an absolute minimum and they work in a very different way to large scale manufacturers who buy specific meat cuts to a set VL level. As with the Meat Product regulations there is a guesstimate of the meat cut value based on how the product is made that day as demonstrated above.

It is possible that the suppliers of seasonings and rusks may give nutritional values with part of their technical sheets along with a product declaration and allergen information for their standard recipes. Scobie & Junor are already doing this however it is only based on using the one cut type per recipe.

This if extended to other suppliers would limit the impact on business to pay for the calculations. Scottish Craft Butchers could engage a competent person to calculate the standard recipes e.g. Abertay University including negotiated fee for non standard recipes. This is still going to be an expensive exercise.

If a food business carries out an analytical calculation of a recipe will the Environmental Officer accept this as being a true representation of the product? Will there be a sampling schedule in every local authority area?

This is a very important point, if sampling was carried out by EHO's and the results differ to the paper result, how will this be interpreted by them? Enforcement action or a measured approach where the EHO will take into account a business has made a genuine attempt to comply? What is in the consumers' interest here?

If you are a micro business under the 10 employees and 2m euros then there is no cost effective way to get the nutritional calculation done either by being sent for analysis (approx. £100 per product) or paper calculations possible £40 per product). It would be desirable if Environmental Health and FSS would assist the smaller businesses. It's not that they do not want to inform consumers but costs associated with calculation or testing have a greater impact on them than on larger scale manufacturers.

It would appear to me that the guestimates required (as outlined in opening paragraph above) to start working out the nutritional values remove any potential for physically tested nutritional values resembling those computed from data. Values will vary from batch to batch and the accuracy of the information is extremely unlikely.

The legislation sounds like a good idea but in practice a nonsense.

This is the only online source of assistance

FSANZ's Nutrition Panel Calculator (NPC) helps food manufacturers calculate the average nutrient content of their food products and prepare a nutrition information panel.

Standard 1.2.8 – Nutrition Info”‹rmation Requirements”‹, of the Australia New Zealand Food Standards Code sets out the legal requirements about providing nutrition information panels and other nutrition information for food that is required to be labelled under the Code.

Although FSANZ is responsible for making food standards, enforcement of the standards is the responsibility of state and territory government agencies, the New Zealand Ministry for Primary Industries, and the Department of Agriculture. There are important provisions in state and territory Food Acts, the New Zealand Food Act 1981, and the Imported Food Control Act 1992 which provide various defences for failure to comply with food standards.

The NPC database 2011 files””provided in Microsoftâ„¢ Excel format – are for people who wish to import the food and nutrient information directly into their own software, rather than use the calculator.

They will ask you to provide some basic details when accessing the NPC database files so that they can let you know about future updates and tailor future releases to best meet your needs, and to maintain some basic statistics about how food composition products are being used.