# Commission Implementing Regulation (EU) No 973/2013 of 10 October 2013 approving a minor amendment to the specification for a name entered in the register of protected designations of origin and protected geographical indications (Nürnberger Bratwürste/Nürnberger Rostbratwürste (PGI)), Division 2: ‘Nürnberger Bratwürste’/‘Nürnberger Rostbratwürste’ are traditionally produced with belly, belly fat, jowl, jowl fat, back or back fat according to the recipe that has been handed down. These ingredients are largely responsible for the consistency and smoothness of the sausages. Without these ingredients, the minced meat product would dry out considerably during frying and fall apart. The fatty meat is also largely responsible for the flavour, which is enhanced by the spicy nuances provided by the specific spices characteristic of ‘Nürnberger Bratwürste’/‘Nürnberger Rostbratwürste’.

Extent: E+W+S+N.I.

The purpose of the more detailed list is to clarify the ingredients. There is no common understanding of the term ‘roughly defatted pigmeat’ among experts in the field in Germany. Some consider that ‘roughly defatted pigmeat’ does not include fatty meat. This would mean that the specification of ‘Nürnberger Bratwürste’/‘Nürnberger Rostbratwürste’ had been incomplete from the outset. This is substantiated with reference to a definition in the guidelines on the German Foodstuffs Register in which the terms ‘grob entfettetes Schweinefleisch’ (roughly defatted pigmeat) and ‘Speck’ (fatty meat) are defined separately.
This point in the guidelines is incomprehensible even to the supervisory authorities. The inspection office for north Bavaria (Landesuntersuchungsanstalt Nordbayern) was also involved in the preparation of the initial specification and, with its knowledge of the ingredients, did not consider it necessary to further specify the components despite the situation outlined above. All parties involved naturally assumed that roughly defatted pigmeat could also include some fatty meat. Otherwise, the recipe would not have been able to comprise fat content of up to 35 %. This proportion can be reached only if ‘roughly defatted pigmeat’ includes some belly, belly fat, jowl, jowl fat, back or back fat.
The proportion of fatty meat in the recipe is restricted, firstly, by the 35 % limit applying to fat content. It is limited secondly as a result of the provision stipulating that meat protein free of connective tissue protein (MPFCP) must not be less than 12 %. Since the MPFCP content of fatty meat is only 8 % on average, the higher MPFCP content of at least 12 % in the end product can be achieved only in combination with particularly lean, high-quality meat with a MPFCP content well in excess of 12 %. Specifying the minimum MPFCP content in the recipe therefore limits fatty meat content. The definition of the term ‘roughly defatted pigmeat’ as used in the recipe does not therefore need to be interpreted according to the guidelines. Rather, it is evident from the recipe itself that the term is used in a different sense here than in the guidelines.
Moreover, the guidelines are not binding. It is recognised that the guidelines do not reflect the views of consumers or of specialists in the field, as their views were not sought when the guidelines were prepared. Rather, the guidelines reflect the views of certain interested parties. The guidelines in fact diverge from traditional production practices to a considerable extent. This was already evident in the preparation of the ‘Nürnberger Bratwürste PGI’/‘Nürnberger Rostbratwürste PGI’ specification, as the composition of ‘Nürnberger Bratwürste’/‘Nürnberger Rostbratwürste’ described here was considerably different to the actual recipe used locally. Consequently, the guidelines were amended after the registration process. The traditional practices applied in the production of ‘Nürnberger Bratwürste’/‘Nürnberger Rostbratwürste’ should also constitute the reference point for the definition of the ingredient ‘roughly defatted pigmeat’ as used in the recipe. Here the ingredients ‘belly, belly fat, jowl, jowl fat, back or back fat’ are traditionally used. In the interests of clarity for all parties, the ingredients ‘fatty meat, particularly pork belly, belly fat, jowl, jowl fat, back and back fat’ will now be listed explicitly in the recipe.

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Source: https://www.legislation.gov.uk/eur/2013/973/annex/I/division/2 (the official version)
Page: https://openlegislation.uk/eu-regulation-2013-973/annex-I/division-2
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.