Labelling Requirements for Meat and Poultry Products
Phosphated Meats and Meat Products

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Sections B.01.090, B.01.091, B.14.021 and B.22.012 of the Food and Drug Regulations (FDR) establish labelling requirements for meat products including poultry meat, to which phosphate salts and/or water have been added. These regulations establish minimum meat protein content and labelling requirements which enable consumers to make price and quality comparisons based on % meat protein declarations. Compositional standards in both the FDR and the MIR, 1990, provide for the addition of phosphate salts and/or water to meats.

Products to which Phosphate Salts and/or Water are Incorporated

Products to which phosphate salts and/or water are incorporated can be grouped into three categories.

Type 1 – Solid cut meat (or poultry meat): A solid cut meat (or poultry meat) is a whole cut of meat or a product consisting of at least 80% of pieces of boneless, skinless meat weighing a minimum of 25 g each, as determined prior to the addition of any other ingredient and further processing activities. This category includes products such as chicken wings, poultry carcasses, steaks, pork tails, tongues, picnics, certain hams, etc. [B.14.020, B.22.011].

Type 2 – Chopped, chopped and formed meat products: This unstandardized category includes products, such as ground roast beef, ground ham and chicken breast (chopped and formed), that do not contain at least 80% of pieces of boneless, skinless meat weighing a minimum of 25 g (no further reference given).

Type 3 – Standardized prepared meat products and meat products which contain a filler: Specific minimum meat protein contents are prescribed in the MIR, 1990 or in Divisions 14 or 22 of the FDR and reproduced in the table Meat Products for which a Minimum Meat Protein Content is Prescribed.

Compositional Requirements

Phosphate Salts:

The maximum level of phosphate salts that can be added to meat products is 0.5% of total added phosphate, calculated as sodium phosphate, dibasic. The addition of phosphate salts refers to the addition directly into the meat ingredient(s) by means of injection, pumping, massaging, tumbling, marination or mixing [B.14.021, B.22.012, FDR].

Meat Protein:

Solid cut meat product (Type 1): Where phosphate salts and/or water are incorporated into a solid cut meat product, the minimum meat protein content of the product must, unless otherwise specified by regulations, be not less than 12% when cookedFootnote 1; or not less than 10% when uncooked [B.14.021, B.22.012, FDR].

Chopped and chopped and formed meat products (Type 2): These products must, unless otherwise specified by regulations, contain not less than 12% meat protein when cooked, or, not less than 10% when uncooked.

Standardized prepared meat products and meat products which contain a filler (Type 3): The minimum protein content for standardized prepared meat products is specified in the MIR (Schedule I), or in Divisions 14 or 22 of the FDR.

Prepared meat products that contain a filler and for which no standard is prescribed in Schedule I, MIR, must contain not less than:

  • 9.5% meat product protein and 11 per cent total protein in the case of an uncooked product; or
  • 11.5% meat product protein and 13 per cent total protein in the case of a cookedFootnote 1 product [7, MIR].

For more information see the table Meat Products for which a Minimum Meat Protein Content is Prescribed.

Common Name – Phosphated Meats and Meat Products

The common name of solid cut meat products must reflect the fact that they contain phosphate salts and/or water, unless the product is cured or preserved or a standard is prescribed for it in Schedule I of the MIR, 1990. The use of the term seasoned in conjunction with the product's name has been found to be acceptable when phosphate salts alone or with water are incorporated into a product. Similarly, the use of the term seasoned is also acceptable when spices are added with water. However, if water alone (i.e., water being the only non-meat ingredient) is added, then an expression such as "water added" must be part of the product's common name.

Declaration of the Minimum Meat Protein Content as Part of the Common Name

The label of prepackaged Type 1 or 2 products must have a statement of the "% meat protein" as part of the common name of the product on the principal display panel of the package with no intervening material. The type must be at least as legible and conspicuous as any other type on that display panel, and in letters that are a minimum of half the size of the letters used in the rest of the common name of the product. The type height cannot be less than 1.6 mm in height [B.01.090(2)]. Declarations such as "minimum meat protein xx%" / "au moins xx % de protéines de viande" or "meat protein xx%"/ "xx % protéines de viande" are acceptable.

Examples:

  • "Chicken Breast with water added, minimum xx% meat protein": in the case of a chicken breast to which only water has been incorporated
  • "Seasoned Chicken Breast, xx% minimum meat protein": in the case of a chicken breast to which water and phosphate salts have been incorporated

The labelling requirement of the minimum meat protein content is not required where phosphate salts and/or water have not been incorporated into the meat ingredient(s) but are present in the food via the addition of a non-meat ingredient (e.g., a sauce, glaze, broth, marinade, etc.).

Note: While suppliers (meat packers or others) are not required to label shipping containers with percent protein declarations, it is their responsibility to provide this information to retailers. Retailers should, therefore, make sure that they get this information so that they can properly label products which they package. A good way to ensure retailers get this information is for the suppliers to make sure it appears on the label of shipping containers. For more information, refer to 7.15 of the Meat Hygiene Manual of Procedures.

For information on compliance and tolerance of protein declaration, refer to the Compliance Policy for Protein Standards of Meat and Poultry Products Containing Phosphate Salts and/or Water.

Exemptions from Phosphated Meats and Meat Products

Side bacon, Wiltshire bacon, salt beef and pork jowls are exempted from the minimum protein standard and the percent (%) meat protein label declaration [B.01.092, FDR].

Water absorbed by poultry carcasses during the post-slaughter chilling process is not considered to be an ingredient providing the amount of moisture picked up does not exceed the prescribed tolerances. Refer to Retained Water Declaration for Raw Single-Ingredient Meat Products for more information. However, when water is added as an ingredient to previously chilled poultry, the resulting product is subject to the minimum protein standard and the additional labelling requirements mentioned above.

List of Ingredients – Phosphated Meats and Meat Products

Meat products to which phosphate salts and/or water have been added are not single ingredient foods. Therefore, list of ingredients requirements apply.

Type 1, 2, and 3 meat products that are packaged at the manufacturing level require an ingredient list on the label.

For products packaged at the retail level, an ingredients list is required when a Type 1 or Type 2 uncured meat product with added phosphates and/or water is packaged for retail sale by the retailer. The meat product may be cooked, sliced or cut up. Federally, Type 1 and 2 meat products that are cured do not require an ingredient list when packaged at retail. It is suggested that applicable provincial legislation also be consulted [B.01.008(3)-(6), B.01.091, FDR].

Phosphated Meat Products as Ingredients

When a meat product containing phosphate salts and/or water is used as an ingredient in the preparation of another food, the common name of this second generation meat product (the resulting product) does not have to reflect the fact that phosphate salts and/or water have been incorporated into the meat ingredient, nor does it require the declaration of percent (%) meat protein in the common name. However, the list of ingredients must accurately describe the meat ingredient(s) by their common name (e.g., seasoned chicken breast) and list the components of the ingredients, where required by B.01.009.

The following table provides examples of common names and lists of ingredients for foods that have phosphated meats as ingredients.

Examples of Products Not Requiring Minimum% Meat Protein Information
Product Name Ingredient List
Pizza with Smoked Ham Tomato sauce (tomato, water,...), ham (pork, water, salt, sodium phosphate, sodium nitrite...) etc.
Quiche Lorraine Eggs, ham (pork, water, salt, sodium phosphate, sodium nitrite)
Chicken Salad Lettuce, seasoned chicken (chicken, water, salt...)...
Chicken Sandwich ...seasoned chicken (chicken, water, sodium phosphate),...
Beef Fajita/Stir Fry Kit ...seasoned beef (beef, water, sodium phosphate),...
Glazed Chicken Wings Chicken, glaze (water, gelatin, sodium phosphate,...) ...

Nutrition Facts Table – Phosphated Meats and Meat Products

A nutrition facts table is required on meat and poultry with added phosphates and/or water whether packed at retail or packed at the manufacturer. The FDR exemption for raw single ingredient meats does not apply to meats with phosphates and/or water added. The percent (%) meat protein declaration triggers the nutrition facts table, even if other exemptions apply, such as the less than 200 cm2 available display surface or manufactured on premises. Refer to Other Permitted References to Protein and to Reasons for Losing the Exemption for more information.

Summary Tables for Labelling Requirements

The following table summarizes the labelling requirements for foods packaged for retail sale by manufacturers, importers, and by retailers.

Summary Table of Labelling Requirements for Meat Products which Contain Phosphate Salts and/or Water
(Prepackaged by the Manufacturer, Domestic & Imported)
Category of Meat Product % Meat Protein Content with the Name of the Product Common Name must include addition of phosphate and/or water List of Ingredients
[B.01.008(3)-(6), B.01.091, FDR]
Nutrition Facts table
[B.01.401(3)(e)(i), FDR]
Type 1:
Solid Cut Meat Products
(e.g., hams, roast)
Yes
[B.01.090(2), FDR]
Yes Yes Yes
Type 2:
Non-Solid Cut Meat Products
(i.e., ground, chopped and formed)
(e.g., roast beef, chopped and formed)
Yes
[B.01.090(2), FDR]
Yes Yes Yes
Type 3:
Products for which a minimum level of meat protein is prescribed in the MIR (Section 7 or Schedule I) or Division 14 or 22 of the FDR
No No Yes Yes

The following table summarizes the labelling requirements for foods packaged from bulk on retail premises, domestic & imported.

Summary Table of Labelling Requirements for Meat Products which Contain Phosphate Salts and/or Water
(Packed from Bulk on Retail Premises, Domestic & Imported)
Category of Meat Product % Meat Protein Content with the Name of the Product Common Name must include addition of phosphate and/or water List of Ingredients Nutrition Facts Table
Type 1 and 2:
Solid Cut Meat Products which are also cured, and may be cooked, sliced, or cut up
Yes
[B.01.090(2), FDR]
No
(Schedule 1, MIR)
No Yes
Type 1 and 2:
Solid Cut Meat Products which are not cured and may be cooked, sliced, or cut up
Yes
[B.01.090(2), FDR]
Yes Yes Yes
Type 3:
Products for which a minimum level of meat protein is prescribed in the MIR (Section 7 or Schedule I) or Division 14 or 22 of the FDR
No No No Yes
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