Codex 192 and the South African FCD Act describe compoundfoods in a similar way in terms of disclosure of the true composition of theproduct in the words:
“… in a package bearing a label which complies with the provisions of the regulations (if any) and which indicates clearly that the foodstuff sold is such a mixture, compound or blend and specifies the names or, as the case may be, the kinds or grades of the ingredients and the proportions or amounts in which they are present …” (FCD Act, 1972).
After the serious 2018 Listeria poisoning case in South Africa, the policing became fragmented between the Departments of Health, Agriculture, the SABS and the NRCS. Deviating from Codex, the form or shape of meat and meat-containing compound foods, such as ground meat products formed into sausages, burger patties, meat balls dictated the nature of the composition of such products. The fact remains that any blend of ingredients can be formed into round flat discs, balls or elongated rolls, irrespective of composition. Codex 192 make the distinction clearly on whether the products are fresh or processed, in large pieces or small particles, and subjected to various degrees of heat treatment, including sub-zero temperatures. The actual temperatures are not specified or prescribed.
Codex has surprisingly few standards for meat products and is limited to Canned Corned Beef, Luncheon Meat, Cured Pork Shoulder, Cooked Cured Ham, Cooked Cured Chopped Meat. There are no further compositional standards for meat or meat containing products. The words “sausages”, “patties”, “steaks”, “meat balls” and other terminology are used without any further qualification. These terms are not related to composition. Fresh, processed, salting, curing, drying, pickling, fermentation, heat treatment, freezing are also not related to composition, but all of the above terms determines the Codex Class and subsequently the recommended additives.
Noteworthy is the fact that meat-containing burger patties fall in various Codex classes, depending on the degree of cooking, and whether these are sold in the fresh, cooked and/or frozen state. This aspect will be a bit of a mind shift for the South African regulators and assignees of the enforcement bodies. The bottom line is that shape does not dictate composition, but that processing technique may dictate different ingredient requirements.
There are also numerous differences in the compositional standards for various cooked products under the Agricultural Products Standards Act, based on product names, that are hard to understand. Names do not dictate composition either. The choice of a header “Ready to Eat Meat Products” in some government publications is unfortunate, since it implies that other are not ready to eat.
What we are left with is numerous names that do not reflect compliance to the prerequisite opening paragraph of this note. Instead, these random names serve as a tool to disguise the presence of certain ingredients. To rephrase, it becomes a tool to legally misrepresent the true nature of a product.
