Dr Mellette and FACTS (Food and Allergy Consulting and Testing Services) are correct in that there is currently no legislation that regulates the composition of minced meat.
As FACTS points out, the Department of Agriculture, Land Reform and Rural Development has recently made available to the industry its Draft Regulations Regarding The Classification, Packing and Marking of Certain Raw Processed Meat Products Intended For Sale In The Republic of South Africa for comment. These Draft Regulations set out the compositional standards for both raw minced meat and raw flavoured ground meat or raw flavoured minced mix and once passed into law will regulate such compositional standards.
Until such time as these Draft Regulations are passed into law, any minced meat product, whether it is consists of just minced meat or a combination of minced meat and other foodstuffs, must comply with the Foodstuffs, Cosmetics and Disinfectants Act and more particularly to the Regulations Relating to the Labelling and Advertising of Foodstuffs promulgated under such Act, as well as with the provisions of the Consumer Protection Act relating to the right to disclosure and information and the right to fair and responsible marketing.
We, along with other retailers, namely Pick n Pay, Shoprite Checkers, Spar, Massmart and numerous independent retailers, have been selling Ground beef, a mixture of minced beef and soya, for a number of years. Our intention behind selling this particular product is not to mislead our customers as to the true nature of the product, but to rather make available to our customers an affordable form of protein during tough economic times. We have gone to great lengths to ensure that our customers are fully informed as to the true nature of our ground beef, including a full ingredient declaration on the front of the pack, as well as a prominent sticker on the front of the pack declaring that the product contains 14% soya. Please see attached a photo of a pack of our ground beef bearing the aforementioned sticker.
In addition to this, we ran an in-store educational campaign earlier this year for a period of 6 months, which consisted of information boards explaining the composition of ground beef being placed in the butchery departments alongside the product in all our store. Please see attached an example of such an information board. Since running this campaign we have not seen a drop in the sale volumes of this product, which indicates to us that our customers, now fully informed as to the composition of ground beef, have elected to purchase this product over minced beef, which retails at a higher price.
Further to these measures, we have recently completed a process of revising our Ground Beef recipe, as well as our Ground Beef label to ensure that such label is fully complaint with the requirements of the R146 Labelling Regulations and that there are no inconsistencies across our stores with regard to the declaration of ingoing ingredients. Please see attached a copy of the revised label, which features an image of both a cow and a plant and prominently declares that the product contains 5% soya, in addition to the ingredient declaration. We have also rectified the error on our current label by disclosing the ingoing percentage of water. This label has already been sent to print and will feature on our Ground Beef product within the next two weeks. We will once again be placing our educational posters in our butchery departments for a period of time to inform our customers of the composition of our revised recipe. Please see attached the revised poster. We will gladly send you a picture of one of these posters once they go up in store again.
We therefore do not believe that we are misleading our customers by selling our ground beef product. If there was any intention on our part to deceive or mislead our customers as to the composition of ground beef, we would most certainly not have gone to the lengths that we have to educate and inform our customers as to the true composition of our ground beef product and there can be no doubt that our customers are fully informed as to the composition of this product.
We do believe that ground beef plays a very valuable nutritional role in South Africa as it allows South Africans who would ordinarily not be able to afford minced beef to access a more affordable form of protein. By way of illustration our average selling price of ground beef over the past year has been R59,99 per kg with the average selling price of lean beef mince being R89.99 per kg and extra lean beef mince being R99.99 per kg, which makes this product very affordable to our customers. We also believe that the taste and quality of our ground beef product is comparable to that of our minced beef and the volume of sales that we are seeing in respect of this product is testament to that.
We hope that this information has been able to assist you with your query. Please do contact us on firstname.lastname@example.org should you require any further information relating to this product.