Food > Meat and Poultry Products > Manual of Procedures > Chapter 7
Chapter7 Annex K - Questions and Answers about the Use of Phosphate
Salts and/or Water in the Preparation of Meat Products - Impact of Schedule 778, an
Amendment to the Food and Drug Regulations
1. In which meat products can phosphate salts and/or water now be added?
Phosphate salts and/or water can now be added to a variety of meat products.
Specifically they can be added in the preparation of all solid cut meat products and in
other prepared meat products for which a minimum meat protein requirement has been
prescribed.
As prescribed by the Food and Drugs Regulations, the maximum level of
phosphate salts that can be added to these meat products is "0.5 % of total added
phosphate, calculated as sodium phosphate, dibasic".
2. What is a solid cut meat product?
A solid cut meat product means:
- a meat product derived from a whole cut of meat (e.g. chicken wings, a ham, a poultry
carcass, a steak, pork tails, tongues, etc. ) or
- a meat product consisting of at least 80% of pieces of boneless, skinless meat weighing
a minimum of 25 g each*.
* The 80% portion of boneless, skinless meat in pieces weighing 25 grams or more is
calculated on the basis of the weight of the raw meat, prior to the addition of any other
ingredient and further processing activities (e.g. pumping, massaging or tumbling). It is
recognized that any processing activity taking place afterwards will cause some breakdown
of small meat particles. This is a normal reaction. However this 80% portion of meat
pieces weighing more than 25 g shall not be comminuted/shredded after it has been
evaluated on a raw material basis, unless it can be demonstrated that the resulting final
product respects the proportion and size of pieces of meat as established in the raw meat
state. This should be detailed in the method of preparation (recipe).
3. When phosphate salts and/or water are added to meat products what are the
minimum meat protein content requirements?
- a solid cut meat product shall have a meat product protein content of:
- not less than 12% - cooked*
- not less than 10% - uncooked.
- standardized meat products:
- meat product protein content as prescribed in Schedule I of the Meat Inspection
Regulations, 1990.
- meat products containing a filler and having no meat product protein standard prescribed
in Schedule I of the Meat Inspection Regulations, 1990. As per section 7 of the Meat
Inspection Regulations:
- not less than 11.5% - cooked*
- not less than 9.5% - uncooked
- meat products containing no filler and having no meat product protein standard
prescribed in the Meat Inspection Regulations, 1990 :
These products are subject to the same requirements as for solid cut meat products (item
i) :
- not less than 12% - cooked*
- not less than 10% - uncooked.
and the additional labelling requirements detailed in question number 5 also applies.
* Cooked means, as per the definition in Schedule IV of the Meat Inspection
Regulations, 1990, that the product has been "subjected to heat for a time
sufficient to produce the characteristics of a cooked meat product with respect to
friability, colour, texture and flavour."
4. What is the impact of this amendment in terms of labelling?
- Standardized meat products:
There is no impact on the labelling of meat products for which a standard (i.e. a minimum
meat product protein content) is prescribed in Schedule I of the Meat Inspection
Regulations, 1990.
- Additional labelling requirements:
These additional labelling requirements (see question 5) apply only to :
- prepackaged* solid cut meat products to which phosphate salts and/or water have been
incorporated, with the exception of side bacon, Wiltshire bacon, pork jowls, salt pork and
salt beef (salt pork and salt beef are solid cut meat products preserved in salt or in a
saturated solution of salt), and to
- prepackaged* meat products to which phosphate salts and/or water have been incorporated,
that do not contain a filler and for which no meat product protein standard is prescribed
in the Meat Inspection Regulations, 1990.
Examples:
- solid cut meat products:
- hams, seasoned roast beef, seasoned chicken breast, etc.
- meat products with no filler and no meat product protein standard in the Meat Inspection
Regulations, 1990 :
- "ground seasoned roast beef", "chopped and formed seasoned chicken
breast" etc.
* Prepackaged means that the product is "packaged in a container in the manner in
which it is ordinarily sold to or used or purchased by a consumer without being
repackaged." (préemballé)
- Identity of meat products:
The identity of a meat product must appear on the label in
terms of its common name or in terms that are descriptive of the meat product. A common
name is defined as a name prescribed in the Meat Inspection Regulations, 1990 or
in the Food and Drugs Regulations or a name by which the food is generally known.
With the exception of cured or preserved products or products for which a standard
is prescribed in Schedule I of the Meat Inspection Regulations, 1990,
the identity of a meat product shall reflect the fact that phosphate salts and/or water
have been incorporated* to it.
The use of the term "seasoned" in conjunction with the product's name has
been found acceptable when phosphate salts alone or with water is incorporated into a
product. Similarly the use of the term seasoned is also acceptable when spices and/or salt
is added with water. However, if only water is added to a meat product
then an expression such as "water added" shall accompany the product's name.
For example:
- a chicken breast to which only water has been "incorporated"
would be referred to as a "Chicken Breast with water added".
N.B. This would not apply to dressed poultry carcasses and their parts picking up water
as a result of washing and chilling process as long as the tolerances specified in section
25 of the Meat Inspection Regulations are respected. Outside of the application of section
25, if water is added to a carcass or a meat cut the resulting product would be considered
a prepared meat product and would have to be sold and labelled as such.
- a chicken breast to which water and phosphate salts have been "incorporated"
would be referred to as a "Seasoned Chicken Breast".
- no modifier is required to the name "chicken burger" (to which water and/or
phosphate salts have been "incorporated"), because a minimum meat product
protein standard exists under Schedule I of the Meat Inspection Regulations, 1990.
*to "incorporate" means that phosphate salts and/or water
have been added directly to the meat ingredient(s) of the product by
means of injection, pumping, massaging, tumbling, marination or mixing.
- Second and third generation foods:
- When a meat product to which phosphate salts and/or water have been
"incorporated" is used as an ingredient in the preparation of another
food, this later is exempted from the "additional labelling requirements"
described in question number 5.
However, the meat ingredient name will be descriptive of the fact that phosphate salts
and/or water have been "incorporated" into it.
Examples:
- Product name : "Pizza with cooked ham"; the pizza contains slices of cooked
ham (with added phosphates).
List of ingredients: "Tomato sauce (water,...), ham (pork, water, salt, ... sodium
phosphate, sodium nitrite...)"
Comments: In this case the name of the meat ingredient "ham" does not have to be
modified by the addition of the term "seasoned" because the ham is a cured
product.
- Product name : "Quiche Lorraine"; the Quiche contains cooked ham (with added
phosphates).
List of ingredients: "Eggs,... ham (pork, water, salt, ... sodium phosphate, sodium
nitrite...)"
Comments: Same as in example number 1.
- Products name : "Party Pack Hors d'oeuvres" (of which component is a Quiche
Lorraine containing cooked ham), "Cooked Ham salad"; "Cooked Ham
sandwich" etc.
List of ingredients: "... ham (pork, water, salt, ... sodium phosphate, sodium
nitrite...)"
Comments: Same as in example number 1.
- Product name : "Seasoned Chicken Salad" (or "Salad with Seasoned
Chicken"); one component being chicken to which water and salt was incorporated.
List of ingredients: "Salad, chicken (water, salt) ..." or "Salad, seasoned
chicken, ..." (if chicken less than 10 %)
Comments: When phosphate salts and/or water have been "incorporated" into a meat
product this addition shall be reflected in the common name of the product, except if the
product is cured or preserved or a standard is prescribed for it in Schedule I of the Meat
Inspection Regulations, 1990.
- Product name : "Seasoned Chicken with vegetables", Ingredients
"...chicken (water, sodium phosphate), ...";
Product name :"Seasoned Chicken à la Kiev",
Ingredients: "..chicken (sodium phosphate),...";
Product name :"Seasoned Beef Fajita/Stir Fry kit"; one component being beef to
which phosphate salts were incorporated),
Ingredients: " ...beef (water, sodium phosphate),...".
Comments: Same as in example number 4.
- When phosphate salts and/or water have not been "incorporated" (added
directly) into the meat ingredient(s) but are present in the food via another
ingredient (e.g. a sauce, glaze, broth, etc.), the resulting food is also exempted from
the "additional labelling requirements":
- Examples:
- Product name : "Glazed Chicken wings" In the case of chicken wings covered
with a glaze containing phosphate salts.
List of ingredients: "Chicken wings; glaze: water, gelatin...sodium
phosphate...".
- Product name : "Pork tails in gravy" In the case of cooked pork tails in a
gravy containing phosphate salts.
List of ingredients: "pork; gravy: water,... sodium phosphate"
- Product name : "Breaded chicken breast" For a chicken breast covered by a
breading containing phosphate salts.
List of ingredients: "chicken; breading (wheat .. potassium
phosphate ...)". etc.
- Product name : "Chicken à la Kiev" phosphate salts have been added to the
sauce.
List of ingredients: "Chicken,..., Sauce : water, sodium phosphate...".
5. What are the "additional labelling requirements" for prepackaged
meat products (see item ii question 4) to which phosphate salts and/or water have been
added?
(A) The label of meat products prepackaged at the registered establishment level shall
have:
- a statement of the percentage of meat product protein as part of the common name on the
principal display panel. This declaration shall appear in a conspicuous manner (i.e. as
per section B.01.090 of the Food and Drug Regulations, in letters that are at
least ½ the size of the letters used in the common name but not less than 1.6mm in
height).
Declaration such as "minimum meat protein 12 % protéines de viande minimums",
or "meat protein 12 % protéines de viande" are acceptable. As mentioned, the
minimum percentage of meat product protein that must be declared is 10 % for uncooked
products and 12% for cooked products. However, higher protein declaration are acceptable
and encouraged. For example : "minimum meat protein 13 % protéines de viande
minimums"; and
- the "core list" nutrition information on any part of the label except the
bottom of the container. The "core list" nutrition information consists of the
energy value (in both Calories and kilojoules) and protein, fat and carbohydrates (in
grams). This statement shall appear in a single grouping in a legible manner (i.e. as per
section B.01.091 of the Food and Drug Regulations, in letters that are at least
½ the size of the letters used for showing the numerical quantity in the declaration of
net quantity as required under section 14 of the Consumer Packaging and Labelling
Regulations, but that are not less than 1.6 mm in height).
(B) The label of meat products prepackaged by the retailer for sale at a retail meat
counter shall have:
- same as above for item (A) i); and
- the list of ingredients, except in the case of cured meat products. Cured means that
salt and a minimum of 100 ppm of nitrite or nitrate salts have been added to the meat
product during its preparation.
N.B. the nutrition "core list" information is not required in this case.
For additional information on nutritional labelling consult the "Nutrition Labelling
Handbook" and the "Guide for Food Manufacturers and Advertisers" prepared
by the Food Division, AAFC (these documents were formerly produced by Consumers and
Corporate Affairs).
6. More precisely, what products are exempted from these additional labelling
requirements?
- Solid cut meat products that are not prepackaged (i.e. products that are sent bulk to
retailers, restaurants, hotel/institutions and for further processing,) are exempted.
Bulk containers (i.e. containers not intended for sale by a retailer to a consumer; this
includes a shipping container) are not required to bear the minimum protein declaration
nor the nutritional "core list".
However, since the retailer must comply with specific labelling requirements (e.g. % of
protein declaration) and that he may be asked by consumers to provide additional
information (e.g. nutrition information), it is the responsibility of the manufacturer to
provide the retailer with accurate information. Although this can be done in a number of
ways (e.g. information sheet, verbally, on shipping bills etc.), it is recommended that
the "additional labelling requirements" appear on the label of the bulk
container.
- Shipping containers of prepackaged solid cut meat products (to which the additional
labelling requirements apply) do not have to bear the minimum protein declaration nor the
nutritional "core list".
- Solid cut meat products sliced/cut at a deli outlet at the request of the consumer.
These products are not prepackaged and as such are not subject to the additional labelling
requirements (see question 5). However information (e.g. the % of protein and list of
ingredients) should be available to the consumer (e.g. by means of a sign, verbal
information, information sheet).
- Other prepared meat products (e.g. comminuted, chopped and formed meat products) handled
in the same manner as described in items i, ii and iii above.
7. Is there a difference between the minimum meat product protein declaration
that must accompany the name of the product and the protein declaration that is part of
the nutritional "core list"?
Yes.
The minimum meat product protein content declared with the name of the product is a
percentage of meat product protein calculated on the basis of the meat product as sold.
Bones and pork rind covering the product are not considered in the calculation of the meat
protein content contrary to poultry skin. In the case of solid cut meat products
only, visible fat layers surrounding every muscle shall not be included in the
calculation (this includes sub-cutaneous fat). Intramuscular fat deposit (e.g. marbling)
shall not be removed for the purpose on this calculation. Breading and other visually
distinguishable non meat ingredients are not considered in the calculation.
The protein declaration that is part of the nutrition "core list" is a
quantity of total protein, in grams, per 100 g serving. It is calculated on the basis of
the product as sold, excluding bones and covering pork rind only.
Calculation is based on the edible portion which includes fat, skin
(poultry), breading, non meat ingredients etc.
Therefore, in some instances, there will be two different protein values on the label
of the same product.
8. What is the impact with regard to the nutritional labelling policy?
The nutrition labelling "core list" (i.e. energy, protein, fat and
carbohydrate content) declared on the label of solid cut meat products to which phosphate
salts and/or water have been added must be based on a serving size of 100 g.
In addition, nutritional information can also be presented based on suggested serving
sizes as detailed in Annex F of the "Guide for Food Manufacturers and
Advertisers" and in the "Nutritional Labelling Handbook", or, in the case
of a single serving package, the serving size would be equal to the net quantity of the
food (section B.01.002A, Food and Drug Regulations). When nutritional claims are made
(e.g. "good source of protein") "the required nutrient content declaration
per serving of stated size that is triggered must appear on the label (i.e. as per
"serving size" appearing in Annex F of the "Guide for Food Manufacturers
and Advertisers" and in the "Nutritional Labelling Handbook").
9. How will these new labelling requirements be monitored?
Agriculture and Agri-Food Canada samples and evaluates meat products that are prepared
in federally inspected establishments or imported into Canada for conformity to
compositional standards. In this respect, minimum meat product protein standards have been
set under the Food and Drug Regulations for solid cut meat products to which
phosphate salts and/or water have been added (i.e. 10 % and 12 %). The same as for any
other protein standard under the Food and Drug Regulations and the Meat
Inspection Regulations, no tolerance has been established.
Nutrient quantities declared as part of the nutritional labelling "core list"
are to be representative of the food which is labelled. No official tolerances have yet
been established, but analytical variation and variations inherent in the food are taken
into consideration in evaluating the appropriateness of the data for nutritional
labelling. It is expected that compliance requirements will be reviewed as part of the
review of the Guide for Food Manufacturers and Advertisers. The U.S. compliance
requirements will be taken into consideration as part of this review. For more information
please contact: Mrs Pat Steele Food Division Food Production and Inspection Branch
Agriculture and Agri-Food Canada 59 Camelot Drive Nepean, Ontario K1A OY9 Tel : (613)
952-8000, ext. 3800 Fax : (613) 952-7387
10. What is the implementation date of the new labelling requirements?
Considering that the additional labelling requirements will add a cost to the meat
processing industry and to the retail sector, an effective date of implementation for
conformity with respect to the labelling of the products has been set for July
31, 1995.
Starting on that date all affected meat products prepared in federally registered
establishments and imported into Canada will have to be labelled appropriately.
Please note that this exemption applies only to the labelling aspect
(i.e. additional labelling requirements); all meat products to which phosphate salts
and/or water have been incorporated must otherwise be prepared in conformity with relevant
policies and regulations.
For additional information or comments please contact:
Claude Boissonneault
Chief, Regulations and Procedures
Meat and Poultry Products Division
Food Production and Inspection Branch
Agriculture and Agri-Food Canada
59 Camelot Drive
Nepean, Ontario
K1A OY9
Tel : (613) 952-8000, ext. 4676
Fax : (613) 998-0958
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