Fancy a reformed chicken sandwich? Or one containing ham made from 5% water? They don't sound too enticing, do they? Yet, these are exactly the sort of descriptions that could soon become the norm on the front of sandwich packs if proposals made by Lacors last month are implemented.
The local authority regulator wants manufacturers to use more detailed descriptions of sandwich contents to aid consumer choice and allow fair competition.
Predictably, the proposals have not gone down well with sandwich makers, but not because they object to Lacors' call for greater transparency. No. They claim that they weren't consulted and as a result many of the proposed labels don't actually make sense.
Under the proposals, meats flash-branded with char marks would not be allowed to be described as 'chargrilled' and those given a smokey flavour by being treated with artificial flavourings would not be allowed to be called 'smoked' without clarification. In a seemingly perverse move, Lacors has also proposed the more precise term of "use by the end of" be replaced by "use by".
While the guidelines are not legally binding, they form the basis of environmental health and trading standards inspections by local authorities, so many companies will feel compelled to comply.
That would be disastrous, warns Jim Winship, director of the British Sandwich Association (BSA). Some of the definitions producers are being asked to used would be misleading and confusing for consumers, he believes.
Under the guidelines, a whole roast chicken that has been de-boned, rolled and chopped, would have to be described as 'reformed', for example. Critics argue that this definition would suggest to most shoppers that the meat has been derived from the reconstituted flesh of several birds.
Furthermore, if meat were cooked according to the definition of "roast" - for 30 minutes at 200°C - it would end up burnt, according to several manufacturers contacted by The Grocer. "We would have to make our sandwiches so dry they would be almost inedible in order to use the word roast," said one.
The BSA is angry its members are being asked to give more precise information than a meat producer has to give.
"If they want to change the definitions of different type of meat that is a discussion they should be having with the meat industry," Winship says.
But the BSA's main bone of contention is that after a meeting between the BSA, the FSA and Lacors last July failed to end in agreement, Lacors had decided to "go ahead and publish and be damned", says Winship. "They have published these guidelines without agreement from the Food Standards Agency, the British Retail Consortium or anyone," he says. "They haven't dealt with any of the potential issues."
Lacors, however, insists it spent several years consulting on the guidelines and reached agreement on nearly all aspects, except the labelling of meats that contain high levels of non-meat ingredients.
The new guidelines were a response to consumer concerns about chicken and ham with large amounts of water and pea starch, says Les Bailey, policy officer for food at Lacors.
"We felt that labelling of these meats was a key part of the guidelines and we couldn't remove that. As we couldn't agree with the trade associations we said we would send out our guidelines, making clear the guidance was not shared by them," he adds.
Bailey believes the latest Lacors guidelines simply clarify the law as it stands: "If a consumer is looking at a range of ham salad sandwiches and yet the ham within them ranges from ham with 95% pork to one with 60% pork, then there is no way for the consumer to distinguish between them," he says. "Food law states that a product should have a name that enables consumers to distinguish between foods that look identical but are different."
According to Bailey, up to 5% water can be included in any food before it has to be declared and so most sandwich makers will not be forced to change the name or the recipes of their products. "The name of the food should reflect the nature of the product," he says. "Each case will be judged on its own merits and we are more than happy to amend advice after input from stakeholders."
Sandwich makers are due to put their case to Lacors and the Food Standards Agency at the end of the month. They'll find out then whether Lacors is as open to negotiation over the proposed labelling changes as Bailey suggests. n