FIR webinar
Alasdair Tucker
Premier Foods’ head of regulatory affairs Alasdair Tucker explained that the manufacturing giant was adopting a project management approach to comply with the FIR.
He also complained of delays surrounding the introduction and clarification of the new rules.
Here, he tackles a few of your questions.
Various listeners asked: “Can food be sold after the date mark?”
Tucker: “In essence, the EU FIC does not change the current situation – food on sale after the ‘use by date’ is ‘deemed’ to be unsafe. As such, it would be an offence under the General Food Regulations 2004 to sell food after the use by date.
“The Article in the EU FIC worth referring to is Article 24.
“Whilst ‘use by dates’ relate to food safety, ‘Best before’ dates relate to food quality, including taste, texture and aroma. A food which is past its ‘best before’ date is likely to be safe to eat, but may not be at its best quality after this date. Selling products after the ‘best before’ date is permitted provided the product is of the nature, substance or quality demanded by the purchaser, and the food which meets food safety requirements and complies with the General Food Law Regulation (EC) 178/2002.”
“We produce frozen ready meals, so we put the best before on pack. Will we need to now also put on date of freezing?” David Taylor, technical manager, Kershaws Frozen Foods
Tucker: “The date of first freezing for frozen meat, frozen meat preparations and unprocessed fishery products is required under Article 24 of the EU FIC. These categories of products have specific definitions which help determine that the requirement to apply the date of first freezing does not apply to frozen ready meals.
“‘Meat preparations’ are defined in Annex I Part 1 point 1.15 of Regulation 853-2004: Fresh meat, including meat that has been reduced to fragments, which has had foodstuffs, seasonings or additives added to it or which has undergone processes insufficient to modify the internal muscle fibre structure of the meat and thus to eliminate the characteristics of fresh meat.
“Unprocessed fishery products take into account definitions of ‘fishery products’ and ‘unprocessed’ products: Unprocessed products (from the definition in article 2 point 1 (n) of Regulation 852-2004) have not undergone processing, and includes products that have been divided, parted, severed, sliced, boned, minced, skinned, ground, cut, cleaned, trimmed, husked, milled, chilled, frozen, deep-frozen or thawed;
“Fishery products are defined in Annex I part 3 point 3.1 of Regulation 853-2004:
Fishery products means all seawater or freshwater animals (except for live bivalve molluscs, live echinoderms, live tunicates and live marine gastropods, and all mammals, reptiles and frogs) whether wild or farmed and including all edible forms, parts and products of such animals.”
“What is the speaker’s viewpoint on the use of the term reformed? ”Jamie Weall, food law advisor, Exova
Tucker: “The term described within EU FIC is ‘formed’ rather than reformed.
The requirement to indicate ‘formed meat’ or ‘formed fish’ in the name of the food applies to meat products, meat preparations and fishery products which appear to be made from one piece of meat or fish but are not. This applies to products that appear to be a whole piece of meat (e.g a chicken breast fillet) or whole fish fillet but also covers items such as sliced products, such as slices that appear to be taken from a whole single piece meat ie. sliced ham shoulder.”