On a
regular basis, the FSAI ( The Food Safety Authority of Ireland) publishes new
guidelines for food businesses to comply with. While in the past couple of
years it feels like we have to concentrate more on educating people (allergen
lists, calories on menus, warnings regarding some colourings for example) than
the actual safety regarding the food we produce, artisans like us do comply
with the rules and just get on with it….
The last
guideline published came out yesterday… and it has my blood boil …
The food
industry is being given definitions for the following words:
§
Artisan/Artisanal
§
Farmhouse
§
Traditional
§
Natural
The goal is
to make sure the consumers are not being misslead by those words when used
in the marketing and publicity of food products. Presumably the aim is to stop
big factories from using words that don’t apply to their product, and by doing
so, protecting the businesses whose product is defined by one or more of those
words.
So far so
good… couldn’t agree more …
I have,
however, a massive problem with the definition of artisan that is being given …
here is the official definition:
5.1 Artisan/Artisanal
The terms ‘artisan’ or ‘artisanal’
or similar descriptions using these terms should only be used on foods or in
advertising of foods that can legitimately claim to meet all of the following
criteria:
1. The food is made in limited
quantities(5) by skilled craftspeople(6)
2. The processing method is not
fully mechanised and follows a traditional(7) method 3. The food is made in a
micro-enterprise(8) at a single location
4. The characteristic
ingredient(s)(9) used in the food are grown or produced locally(10), where
seasonally available and practical
(5) Limited quantities means total
production by the food business operator of less than 1,000 kg or litres of
food per week on average over a year (this limit is aligned with the higher
limit in other national rules covering an activity which is considered
‘marginal, localised and restricted’ see S.I. No. 168 of 2012 and S.I. No. 340
of 2010).
(6) A skilled craftsperson is
someone who has special expertise in making food in a traditional manner (see
footnote 7).
(7) Traditional has the meaning
defined in Council Regulation 1151/2012 on quality schemes for agricultural
products and foodstuffs: “....proven usage on the domestic market for a period
that allows transmission between generations; this period is to be at least 30
years;”.
(8) A micro-enterprise is defined
as an enterprise which employs fewer than ten persons (or whole time
equivalents) and whose annual turnover and/or annual balance sheet total does
not exceed EUR 2 million. (Commission Recommendation 2003/361/EC).
(9) Examples of characteristic
ingredients are milk in cheese, pork meat in ham, strawberries in strawberry
jam, oats in porridge. This is not intended to be a definitive list of
characteristic ingredients. As a rule of thumb, the characteristic
ingredient(s) are those that would normally require a quantitative ingredient
declaration (QUID) under the food information regulations.
(10) Within a 100 km of the
manufacturing/food service establishment (this limit is aligned with the sale
and supply limit set in other national rules covering an activity which is
‘marginal, localised and restricted’, see S.I. No. 168 of 2012 and S.I. No. 340
of 2010)
Will it stop big non artisan factories from using that word?
Probably … But it will also limit and restrict the real artisans like us, and
that’s where the real danger lies in my opinion….Let me explain by taking back
the 4 points of the definition:
1 – food made in limited quantities (1000kg or
ltr per week max): why limit the quantity of what an artisan can
produce???? Surely there’s no limit, the artisan just trains more people as
demand grows!
– a
skilled craftsperson: artisan or not, everybody is skilled in the position
they work at I would have guessed …
–
traditional
manner: here they are telling us that you can’t create a new product or it
won’t be “artisan”
2 – traditional
method: same as previously, this limits the creation of new products …
3 – micro enterprise:
they don’t want the artisan to develop too big. By restricting quantities and
turnover, there’s a clear risk of prices going up for the consumer as an
artisan won’t want to go over the threshold to remain in the artisan category.
The only way then to keep on increasing the turnover is to increase prices,
very unhealthy way of doing business in my opinion…
- single location: I don’t see how the
location affects an artisanal product. That’s just more restrictive nonsense…
When we had our shop in Dalkey, we had a lovely young Lady working in the shop
who we regularly asked to do trays of sugar flowers. I would then bring those
back to Kilcullen. That didn’t make our cakes any less artisanal …
4 – ingredients used
grown or produced locally: this is going to be the most controversial bit
here … they are touching on a complete different subject!!! One simple and
straight forward example: you will never have an artisan mince pie in Ireland if you
follow their logic: we don’t grow raisins, sultanas, oranges, lemons … The core
ingredient of our macarons is ground almonds: Ireland doesn’t produce almonds …. See
the problem ?!??
One final thought:
The fact that
artisans make products by hand is completely left out of the definition, and
the “art” bit of artisan is completely ignored …
Signed: a very angry
artisan
Armelle
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