3. (I) New EC definition and new 2003 Regulations LACORS welcomes new EC meat definition Provides improved consumer information Pragmatic, flexible enforcement approach

4. (II) Industry needs time to make appropriate recipe and labelling changes. FSA Guidance Notes welcomed but ongoing task to guide smaller producers Important role to be played by local producer seminars etc LACORS will continue to address ongoing issues and produce appropriate guidance

5. (III) Logistical issues: Large Supermarkets: many individual product, many suppliers Recipes changes and packaging/labelling changes take time Long lead-in times and limited capacity to supply new labelling etc Early dialogue with Home Authority is highly desirable

6. (IV) EC definition and 2003 Regulations “out of synch” LACORS pressed for implementation at the same time; also FSA intention Lengthy consultation exercise desirable but has created problems EC definition date of 1 st July unalterable

7. (V) LACORS recommending informal transitional period; FSA emphasis in relation to non prepacked products Look at each case on its own merits; not a blanket derogation Rolling compliance programme; consumer information not consumer safety Prefer EC definition for all declarations but may need to be flexible

8. (VI) Need to refer to other legislation Mechanically Recovered Meat (MRM) Protein Ingredient definitions Poultry meat definitions; water content controls

9. (VII) 2003 England Regulations Scottish, Welsh and Northern Irish legislation Products traded across territorial borders in the UK New EC definition applies across the UK

10. (VIII) Fat/excess Fat declarations Connective Tissue declarations Support use of specific names Added water indications in name but not declarations for and so potential for exploitation.

11. (IX) Declaration of “foreign” proteins Schedule 3 exemption “added for a technological purpose” Position of poultry under Schedule 1

12. (X) FSA butchers and bakery guidance notes Two commercial meat content calculators are available Visible lean estimation concept Potential problems for smaller producers

13. XI Average/Typical QUID valves No specified tolerances; EC work in progress Meat contents should not be overestimated Fat/connective tissue contents should be underestimated

14. (XII) Specific names of cuts as ingredients Names should be those understood by consumer/be aware of regional variations Potential innovative general meat description listing Cooked/Raw Equivalence Issues

15. (XIII) What is MRM? What isn’t MRM? Consider carefully mechanically deboned meat EC definition different from UK working definition of MRM Combination of factors need to be considered e.g. equipment

16. (XIV) Imported products from the EU EC wide approach in terms of names of products with added ingredients Application of UK “reserved descriptions” Possible Free Movement of Goods Principle implications

17. (XV) Enforcement more effective at point of production rather than retail level Stress importance of liasing with Public Analyst Difficulties in relation to imported products Resource issues also need to be considered

18. (XVI) QUID does not apply to catering establishments Problems with defining “catering establishments” Possible Scope for Debasement Ingredients/Dehydrated Rind etc

19. (XVII) Revoked former reserved descriptions Potential compositional debasement “Pork savoury – I Can’t Believe Its Not A Pork Pie” Meat products which are now not meat products e.g. Hot Dogs

20. (XVIII) Needs to be explain to consumers/media Want to avoid unnecessary trade/consumer concerns in terms of workloads Frequently asked questions and answers Consumer Education Programme