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A Comparative Legal Analysis of Labelling Requirements in the EU and US for Restructured and Mechanically Tenderised Beef

Nathan Meijer, Yannick Weesepoel, Rob de Jonge, Bernd van der Meulen, Leo van Raamsdonk, Saskia van Ruth

Meat is processed to various degrees before it reaches the consumer. The surface of a piece of meat may be contaminated with pathogenic bacteria during processing. Sufficiently heating the product is therefore often required to ensure safe consumption. The focus of this article is on the food safety risk of two types of invasively processed beef products: (i) mechanically tenderised meat and (ii) restructured meat products. If such a product is undercooked because the consumer believes it to be an un-processed whole piece of meat, then these types of products may be unsafe to eat because any potential pathogenic contamination in the product core will not be eliminated. Risk factors of mechanically tenderised and restructured beef have been examined, and the sufficiency of the corresponding legal protection of consumers in the European Union (EU) compared to those in the United States (US) was evaluated. We conclude that deep tissue contamination of invasively processed beef may occur more often and at higher concentrations than estimated, and that consumers are not adequately made aware of this. Although certain microbiological criteria are in place to mitigate the risk from the producer’s side, outbreaks in the US have shown that these measures are insufficient. We therefore recommend that labelling requirements in the EU be changed for this type of meat.

Nathan Meijer, MSc is a junior scientist at Wageningen Food Safety Research (WFSR), Wageningen University & Research. For correspondence: <>. Yannick Weesepoel is a scientist at WFSR Wageningen University & Research. Dr. Rob de Jonge is a senior scientist at the Dutch National Institute for Public Health and the Environment, Centre for Zoonoses and Environmental Microbiology. Bernd van der Meulen is Director of the European Institute for Food Law and Professor of Comparative Food Law at Renmin School of Law, Beijing under the Program of Top-level Foreign Experts of the State Administration of Foreign Experts Affairs People’s Republic of China. Dr. Leo van Raamsdonk is a scientist at WFSR Wageningen University & Research. Saskia van Ruth is Professor at Wageningen University & Research; Food Quality and Design Group, and Senior Scientist at WFSR Wageningen University & Research. The authors wish to thank Esther van Asselt for proofreading the manuscript. This research did not receive any specific grant from funding agencies in the public, commercial, or not-for-profit sectors.


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