- 26/06/2026
- Posted by: Marta
- Category: Questions and answers
Dear Dario,
I'd like to ask you for some clarification on the composition and labeling criteria for minced meat.
Many thanks
Rosalba
The lawyer Dario Dongo, Ph.D. in European food law, answers
Le minced meat are defined by Regulation (EC) No. 853/2004, Annex I, point 1.13 as 'boneless meat subjected to a grinding operation into fragments and containing less than 1% salt'. Following is a brief analysis of their discipline.
Minced meat, composition criteria
Different types of minced meat are subject to harmonized composition criteria, set by:
- reg. (EC) n. 853/2004, cd Hygiene 2 Regulation, Annex III, Section V, Chapter II, as regards the Raw material requirements;
- reg. (EU) n. 1169/2011, cd Food Information Regulation, Annex VI, Part B, as regards the Specific requirements relating to the designation of 'minced meat'. These criteria, to be checked 'based on a daily average', are defined as follows (point 1):
| Typology | Fat content | Collagen/protein ratio |
|---|---|---|
| Lean ground meats | ≤ 7% | ≤ 12% |
| Pure beef minced meat | ≤ 20% | ≤ 15% |
| Minced meats containing pork | ≤ 30% | ≤ 18% |
| Minced meat of other species | ≤ 25% | ≤ 15% |
The same regulation (EU) 1169/2011, in Annex VI, Part B, also provides in point 3 that the Member states may authorise the placing on the national market of minced meat which does not comply with the criteria set out in point 1 (Composition criteria controlled on the basis of a daily average), by affixing a national mark that cannot be confused with the identification mark referred to in Regulation 853/2004, Article 5.1.
Mandatory information on the label
Le information foreseen as compulsory on the label — or in the commercial documentation accompanying or preceding delivery, in the event of the products being sold to a commercial operator — it is clear from Regulation (EU) No. 1169/11, Articles 9 and 10, from Directive 2011/91/EU (the so-called 'Batch Directive') and from Regulation (EC) No. 853/04:
- name of the food, specifying the animal species used. Particular attention must be paid to compliance with the requirements established for the legal name 'minced meat' (see previous paragraph), also taking into account the heavy sanctions introduced by law 75/2026 which modifies legislative decree 231/2017 and the penal code (Dongo, 2026a,b);
- net quantity;
- expiry date (or minimum durability date, in the case of frozen or deep-frozen products);
- special storage conditions (specifying the temperatures to be respected to guarantee the cold chain, or frost in the case of frozen or deep-frozen products), in immediate proximity to the date marking;
- company name and address of the responsible operator;
- instructions for 'use ('to be consumed after cooking'), all the better if specifying the recommendation to maintain 70°C at the core of the product for at least two minutes (so as to inactivate any thermolabile pathogens);
- nutritional declaration;
- batch traceability code;
- identification mark.
Origin labelling
As regards the mandatory indication of origin, the minced beef It must also report on the label:
- '«Prepared in [name of the Member State or third country]' according to the place where the meat was prepared and «Origin» in the event that the State or States in question are not the one in which the preparation took place' (EC Regulation No. 1760/2000, Article 14);
- 'percentage of the fat content less than …', And
- 'collagen/protein ratio of the meat inferior to …' (EU Regulation 1169/2011, Annex VI, Part B, point 2).
The origin of minced meats swine, sheep, goats and poultry species (excluding quails and game) can instead be communicated with the 'following Directions:
- ‘Origin: EU’, where the minced meat or trimmings are produced exclusively from meat obtained from animals born, raised and slaughtered in more than one Member State;
- ‘Raised and slaughtered in: EU’, where the minced meat or trimmings are produced exclusively from meat obtained from animals reared and slaughtered in more than one Member State;
- ‘Raised and slaughtered in: non-EU’, where the minced meat or trimmings are produced exclusively from meat imported into the Union;
- ‘Reared in: non-EU’ and ‘Slaughtered in: EU’ where the minced meat or trimmings are produced exclusively from meat obtained from animals imported into the Union as slaughter animals and slaughtered in one or more Member States;
- «Raised and slaughtered in: EU and non-EU» if the minced meat or trimmings are produced with:
(i) meat obtained from animals reared and slaughtered in one or more Member States and from meat imported into the Union; or
(ii) meat obtained from animals imported into the Union and slaughtered in one or more Member States'(EU reg. no. 1337/2013, article 7).
Cordially
Dario Dongo
Credit cover Jonathan borba su Unsplash
Normative References
Dongo, D. (2026, June 1). Food labeling: fines up to €100.000. GIFT (Great Italian Food Trade). https://www.greatitalianfoodtrade.it/notizie/etichettatura-alimenti-sanzioni-100mila-euro%E2%81%A0/
Dongo, D. (2026, May 18). Italy, new food crimes. GIFT (Great Italian Food Trade). https://www.greatitalianfoodtrade.it/notizie/italia-nuovi-reati-alimentari/
Law No. 75 of April 21, 2026, Sanctioning Provisions for the Protection of Italian Food Products. Official Journal No. 110 of May 14, 2026 https://www.gazzettaufficiale.it/eli/id/2026/05/14/26G00089/SG
Regulation (EC) No. 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin. Consolidated text: 27/01/2026. http://data.europa.eu/eli/reg/2004/853/2026-01-27.
Regulation (EU) No. 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers. Consolidated text: 01/04/2025. http://data.europa.eu/eli/reg/2011/1169/2025-04-01
Regulation (EC) No. 1760/2000 of the European Parliament and of the Council of 17 July 2000 establishing a system for the identification and registration of bovine animals and regarding the labelling of beef and beef products. Consolidated text: 21/04/2021. http://data.europa.eu/eli/reg/2000/1760/2021-04-21
Regulation (EU) No. 1308/2013 of the European Parliament and of the Council of 17 December 2013 establishing a common organisation of the markets in agricultural products. Consolidated text: 18/03/2026. http://data.europa.eu/eli/reg/2013/1308/2026-03-18
Commission Implementing Regulation (EU) No 1337/2013 of 13 December 2013 laying down rules for the application of Regulation (EU) No 1169/2011 of the European Parliament and of the Council as regards the indication of the country of origin or place of provenance of fresh, chilled or frozen meat of swine, sheep, goats and poultry. http://data.europa.eu/eli/reg_impl/2013/1337/oj
Commission Implementing Regulation (EU) 2018/775 of 28 May 2018 laying down rules for the application of Article 26(3) of Regulation (EU) No 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers, as regards the rules on indicating the country of origin or place of provenance of the primary ingredient of a food. Consolidated text: 09/06/2019. http://data.europa.eu/eli/reg_impl/2018/775/2019-06-09


