October 22, 2021 William D. Dar, Ph.D. Secretary of the Department of Agriculture Elliptical Road, Diliman Quezon City Re : Minimum Labeling Requirements for Imported Frozen Meat Dear Mr Secretary, I am writing you on behalf of Mr Cham of the Meat Importers and Traders Association who unfortunately contracted covid more than a month ago and is still recuperating at the hospital. In particular, I am writing you about the labeling requirements stated in AO 26 S2005, AO 24 S2010, and referred to in BAI and NMIS Joint MC No 2 S2021 and in your letter to Mr Cham dated Sept 9, 2021. Both AO 26 S2005 and AO 24 S2010 were issued when meat products ready for sale at the retail level were still under the supervision of the Dept of Agriculture. That function has since been transferred to the Food and Drug Administration. Therefore, all labeling requirements found in both AO 26 S2005 and AO 24 S2010 that pertain to retail ready goods (eg. List of ingredients, lot numbers) should be removed as they have no use for frozen meat imported as a raw material for further conversion. The net quantity does not have to be exclusively expressed in the metric system . The USA, that is a major exporter of meat to the Philippines, uses pounds. Exclusive use of the metric system may be more relevant for retail-ready meat products, but we do not see any cause for concern for meat used as raw material. Qualified meat inspectors and quality control officers know how to convert pounds to kilos. AO 24 S2010 specifies that dates appearing on the label must be uncoded and the month “shall be indicated by letters”. The US poultry industry has already indicated that this particular requirement will be problematic and there may be others because we often see only numeric date formats, irrespective of origin. It may be impossible for FME’s to comply without investing in either new software or new line printers. We understand how a strictly numerical representation of the date can be confusing because it can be read as either M/D/Y (used by North America) or D/M/Y (used by Europe). However, such conventions are common knowledge for people in the meat industry, including our NMIS and BAI inspectors. Therefore, we do not feel there is any pressing need to strictly require that the month be spelled out There is no need to strictly require a min 2.5mm font size on the labels. AO 24 S2010 stipulates that labels must be legible which also means that the information must be big enough to be read. In any case, most people now use smart phones, all of which have magnifying capabilities bundled with the camera function. Line printers vary from plant to plant. The size of the box also varies and with it the size of the label. With their limited size, many labels are packed with information, especially bilingual ones. It would be impractical to require a minimum font size. AO 26 S2005 requires “Date of manufacture and packaging” on the label. The wording seems to imply that the DA defines the manufacturing date as the slaughter date. Therefore, we believe what the Dept of Agriculture actually wants to see on the box label are the slaughter date and the pack date. Since there is also a requirement for an Expiry or Best Before date, we now have three dates that must appear on the box label. This seems superfluous (perhaps even confusing) and does not address any apparent food safety concern. To explain - The following terms are used interchangeably amongst FME’s from various countries and essentially mean the same thing: the day the meat was cut and frozen. Manufacturing date Production date Pack Date Freezing Date They do not refer to the slaughter date. Except in the poultry industry where the birds are slaughtered and packed on the same day because the process is highly automated and there are less cuts to produce, most FME’s of pork and beef chill the carcass at least overnight prior to deboning. Therefore, it is normal to have a few days difference between the slaughter date and the “production” or “pack” date (one must also account for weekends and holidays). Many FME’s are already showing a manufacturing date (or its equivalent) and the expiry (or best before) date on the box label. We do not believe there is a need to also show the slaughter date. It is more important to consider that FME’s maintain the cold chain throughout the process as part of their GMP / HACCP requirements. So a difference of a few days from slaughter to production/manufacture/pack/freezing date does not present any food safety issue and the meat is still certified as fit for human consumption by the veterinary authority of the exporting country. On the contrary, chilling the carcass overnight improves the safety and quality of the meat : it allows blood to fully drain from the vessels, inhibits the growth of pathogens, delays any enzymatic processes that break down meat protein, addresses any possible concern about FMD (with the lowering of the meat pH). In the particular case of beef, hanging the carcass and chilling overnight helps to lessen the effects of rigor mortis. Rather than getting ourselves overly burdened by semantics and having to identify which exporting countries use a particular terminology, we recommend that box labels be required to simply show : 1. Uncoded Production Date or Manufacturing Date or Packing Date or Freezing Date – used interchangeably. 2. Uncoded Expiry Date or Best Before Date, either written numerically, or expressed in terms of number of months from date of manufacture (eg. 12 / 18 / 24 months from production date or the equivalent date). The foregoing should give enough flexibility for many FME’s to be compliant while at the same time providing the essential information needed by government. Too many labeling requirements will only add to the cost of meat for consumers. There is now widespread reluctance to book any orders for January arrival because importers and FME’s are worried that shipments will just be quarantined at the cold storage due to violations of the minimum labeling requirements. With domestic pork production still short for the foreseeable future, the gains of the previous months to keep inflationary pressures in check could be lost if we were to stop imports even for a single month Finally, national elections are not far away. It has been our experience with past administrations that the status quo is normally maintained near election time and we fear no major changes will be enacted until the new administration assumes office. But more importantly, for importers to catch January 2022 arrival, the foregoing concerns must be resolved by the first week of November. With this in mind, we respectfully urge your office to please issue another Administrative Order as soon as possible to remedy the flaws of AO 26 S2005 and AO 24 S2010. Failing that, we would ask that the implementation of the labeling requirements as stated in BAI and NMIS Joint MC No 2, S2021 be held in abeyance until some common ground can be agreed upon between the Department of Agriculture, industry, and our foreign suppliers. We thank you for your service to our country, particularly your even-handed approach to maintaining food security and stability. Yours is an unenviable job where criticism is never in short supply but you can be assured of MITA’s continued cooperation and assistance. Sincerely, Sherwin Choi Vice President C.C. Usec Leocadio Sebastian, Chief of Staff and OIC, Office of the Undersecretary for Livestock Usec Fermin Adriano, Undersecretary for Policy, Planning and Research Usec William Medrano, Undersecretary-designate for Livestock Dr. Reildrin Morales, OIC-Director, BAI Dr Jocelyn Salvador, OIC, Executive Director, NMIS Sec Carlos Dominguez, DoF Sec Ramon Lopez, DTI Sec Karl Kendrick Chua, NEDA Usec Ernesto V. Perez, CPA, Deputy Director General, ARTA