News Reports About “Meat Glue” Being Used to Bind Cheap Meat Scraps Together As “Filets”
There have been recent news reports, including this ABC affiliate’s report, about “meat glue”– a product apparently being used by some meat suppliers and restaurants to “glue” together pieces of inexpensive meat (e.g. stew scraps) and make them appear to be a single piece of high-quality meat (e.g. pieced into one cut resembling filet mignon).
The meat-glue substance itself is a powder mix, sold under the brand names Activa or Fibrimex. The Activa product, made by the company Ajinomoto, is made with the enzyme transglutaminase, also called TG or TGase. The Fibrimex product is made with the enzyme fibrin. The use of the meat glue products and their enzymes is not illegal, in and of itself.
The Food Safety and Inspection Service (FSIS), which is part of the U.S. Department of Agriculture, has permitted the use of the TG enzyme under certain circumstances. Under FSIS regulations, a meat supplier which meat-glues a given product, and thus uses the TG enzyme in that product, must comply with several important requirements, including these: (1) the product must declare the presence of TG enzyme in the list of ingredients on the product’s label; and (2) the product name must be labeled to bear the term “formed” or “reformed” in conjunction with product name.
Potential Health Safety Issue, Due to Bacteria
According to some media accounts (e.g. here and here), use of meat glue could present a public-health risk, because scraps of meat have a significant amount of bacteria on their surfaces, and when they are pieced together into one piece, they have more bacteria distributed throughout the meat than does a natural single cut of meat (which does not have significant bacteria at its center). If a meat-glued meat piece is served rare or not cooked properly, it could present more risk to the consumer than a natural cut of meat.
It must be noted the media articles discuss potential risks, and there has not been any specific instance reported in the media accounts I saw where any meat-glued product had caused health concerns for any specific consumer. But independent of any safety concern, there is a growing concern that consumers may not be informed and aware of certain instances when they are eating meat-glued meat.
Particular Meat Suppliers Not Labeling Meat-Glued Products As “Formed,” “Reformed” Etc. As Required?
News articles I have seen have shown examples of how meat glue is used, but the examples are typically conducted by food-industry people who (while knowing how meat glue works and is used) do not use meat glue in their own business. Of note, the articles have not identified any specific meat supplier who have violated labeling requirements by not labeling TG-altered products as “reformed” or “formed”, or by not including transglutaminase (TG or TGase) in that product’s ingredients. It is certainly possible, however, that this is a systemic practice being conducted by particular meat suppliers.
Restaurants Failing to Disclose Meat-Glued Products, e.g. Buying “Reformed” Meat and Selling to Customers As “Filets”?
The news articles I’ve seen have not identified any specific restaurants who use meat-glued products, or how such restaurants are labeling those products in menus and otherwise.
From my review of FSIS regulations, it is not certain whether restaurants using TG- altered meat products are required to label the product for the consumer/menu (e.g. the FSIS requirement to label as “reformed” or “formed” as referenced above) or to otherwise disclose that their product is something other than the consumer understands it to be. In my view, some– but not all– restaurant operations are exempted from the FSIS labeling requirement, so there is legal gray area there.
Aside from the FSIS disclosure requirement, there could be violations of false advertising-related laws if a restaurant or supplier knowingly labels items of meat to be something they are not (e.g. calling meat-glued scraps a “filet”), or knowingly conceals important information from the consumer.
I have not heard of any specific restaurants, suppliers or situations where meat-glue altered meat is not labeled properly; whether there are actual violations of law and/or safety standards depends on the circumstances.
Are you aware of restaurants or suppliers using meat-glued and re-formed meat (whether if it was meat-glued by suppliers or meat-glued by the practices of the restaurant itself), and not labeling the meat in a way customers would understand that’s the case? If so and you are interested in discussing this privately, please call me (Attorney Michael Brown) at 920-858-2265 or please email me at firstname.lastname@example.org.