Don't make a decision at the 11th hour
But this 11th hour amendment, made without consultation, will mean that 98% of bacon sold in the UK will have to bear the phrase 'with added water' in the name of the food. What possible benefit could this give consumers? It is polite to use the term 'amendment'; it should really be 'botch'.
The modern method of bacon production, by wet-curing, involves injecting the brine into the meat to obtain the even curing necessary to preserve safety and shelf-life. It is not physically possible to achieve a new limit of less than 5% water, except by dry-curing.
The vast majority of bacon produced in the EU is sold in the UK, a market worth £2bn.
The 1980 report of the then Food Standards Committee under the Ministry of Agriculture, Fisheries and Food decided that water content above an agreed 10% limit (necessary for the technological process) would trigger an added water label. The 10% thus acted as a deterrent against over-watering, which had been a problem.
Before FIR, responsibility for water content moved from the Food Standards Agency (FSA) to the Department for Environment, Food and Rural Affairs. The official position was that the UK water limit was superfluous because meat content declarations were already required to provide the consumer with relevant information about the composition. This conclusion followed detailed consultations by the FSA involving all interested parties. This, and the rationale for the 10% rule, was not considered in the discussions leading to the new 5% limit.
So everyone's interests have suffered. Water levels in bacon will not fall to below 5% because only expensive dry curing will allow that. The UK's 10% ceiling, which was a deterrent to adding extra water, will be removed. And a new label will damage the image of bacon, even though the recipes will be the same. Also, it is unnecessary gold-plating of existing EU mandatory meat content labelling.
There are lessons to be learned from this mistake. Most importantly, that our UK officials should work harder to prevent EC regulations from overturning UK legislation applicable to a unique UK foodstuff, particularly when it is too late for proper consideration of the consequences. It seems that no-one even questioned why 10% had been in the UK legislation since 1984. Also, the government should review its much-maligned decision to split food labelling duties between several departments.