Names and descriptions of foods and ingredients have been much debated over the years.
In many cases, it ought to be accepted that ingredient lists and Quantitative Ingredient Declarations (QUID), already legally required for consumers, are more practical than new legislation or guidance which risks raising further questions of interpretation. One of the main purposes of QUID, when first proposed by consumer lobby groups, was to avoid the need for further regulations.
When is a ham sandwich not a ham sandwich is just one question under discussion following Local Authority Coordinators of Regulatory Services (LACORS) guidance notes on sandwich labelling. According to LACORS, cured pork shoulder can't be called 'ham'. Reformed ham has to be described as such in the name. And ham containing water, hydrolysed proteins and starch has to be called, say, 'processed ham'. This implies that straight 'ham' is by definition of a higher quality. But it's conceivable that sandwiches using cured pork shoulder could taste better than those with straight ham, depending on the quality of the cured meat and the nature and combination of the other ingredients. Moreover, once the meat has been cut up for use in the sandwich the difference in eating quality could be negligible.
In contrast, there are other occasions when it is essential to have clear definitions. In the late 1980s, when the European Directive on Milk Hygiene was near completion, the UK pointed out that its scope had not been defined. Was a cheesecake, say, counted as a dairy product for the purposes of that Directive? At one stage Commission officials suggested that the question should be decided according to the amount of dairy ingredient in the foods. This idea was soon dropped upon realisation that some cheesecakes, say, with lower dairy content would not be covered by any hygiene legislation, but others would.
In another example, food names are defined by compositional standards in the Food Labelling Regulations 1996 and the Meat Products Regulations 2003. In the UK, these still exist for some British traditional cheeses, sausages, corned beef and burgers. Some believe that without such standards there would be new arguments over whether a cheese, say, could be called Wensleydale.
The debates continue.
Clare Cheney
Director General
Provision Trade Federation
clare.cheney@provtrade.co.uk