Pies dispatched unwrapped

This query was raised with reference to pies in particular that were being sold in a retail shop in Lanarkshire that was not part of the manufacturers business.

Labelling and wrapping of loose products are not therefore what we understand as such at retail level for pre packed items. It seems FSA are looking for traceability and this can be achieved fairly simply as detailed below. In my opinion they are not looking for anything too difficult, I suspect you already mark the trays you send out to customers for your delivery men anyway.

You just need to mark what the product is and apply a number or date so that you know when the product was delivered. If you are supplying other businesses you probably already have given them QUID declarations for your products and allergens. If you need help with QUID on products remember we provide that service FOC.

Please contact me or Bruce should you need more info.
Regards
Douglas
________________________________________
From: Angus, Jacqui [mailto:[email protected]]
Sent: 30 July 2010 09:11
To: John Sanaghan
Cc: James Dixon
Subject: Identification marks – meat products

John

Further to the discussion at Tuesday's meeting on the issue of applying ID marks to unwrapped bakery goods (meat products), please find below the FSA view on this matter.

Issue:
“This issue is in relation to an Approved Bakers premises that manufactures and supplies meat pies that are placed in bread trays and covered within grease proof paper for delivery. In effect the pies are dispatched unwrapped. Annex II of 853/2004 (see extract below) appears to imply that these foods should be “packaged”. Currently we have permitted this practice, (unwrapped) as the retail shops that are supplied are one and the same business, but insist on the ID mark and other related info being included on the delivery note. “

We draw your attention to Annex II of 853/2004, section I, C11:
“For products of animal origin that are placed in transport containers of large packages and are intended for further handling, processing, wrapping or packaging in another establishment, the mark may be applied to the external surface of the container of package”
We are of the opinion that loose products need to be identified and that the mark may simply be a label attached to the tray. We suggest a sticky label that can be removed afterwards. Permanent labelling could be a problem in trays which find their way to other establishments.

During the meeting, reference was made to the identification mark on documentation for fishery products:
C12: ” In the case of………………., and fishery products carried in bulk, an identification mark is not necessary if accompanying documentation contains the information specified in points 6 [country], 7 [approval number] and, where appropriate, 8 [community mark]”

Jim had also asked about whether there was any reference made to this in Andrew Morrison's email (20 July 2010) regarding flexibilities in small approved premises. There is none specifically mentioned however the letter asks LAs for their views on areas of potential flexibility so this might be an area worth mentioning.

Regards

Jacqui

Jacqui Angus
Senior Enforcement Advisor
Enforcement Branch, Scotland
Food Standards Agency
6th Floor, St Magnus House
25 Guild Street
Aberdeen
AB11 6NJ

Tel: 01224 285175
Mobile: 07876 131648