The agency’s first front panel for a 400 g plant-based mince lands on the technical manager’s desk. Across the top it reads “Meat Free Beef-Style Mince 400 g”, with a cow outline beside the name and two flashes, “Source of protein” and “Vegan”. The same week, the laboratory reports the factory trial batch at exactly 9.0 percent protein. The site is Thuthuka Fresh Meals, the training scenario in ASC’s Intermediate NPD course, and every figure from it here is illustrative. Neither document gets the pack onto a shelf yet.
In short
- “Mince” is a prescribed name under R.6436 of 2025 and needs a descriptor in front, as in “plant-based mince” or “soy mince”.
- Species names stay out of the name. “Beef-style” wording and animal pictures stay off the pack, and “meat free” stands alone, away from the name and no bigger than it.
- A mince analogue needs at least 9 percent protein as analysed, and “meat alternative” or similar on the main panel.
- A formula gives a design estimate. Build it at the worst case of the specification, and let analysed batches with a margin release the name.
- Clearing 9 percent does not earn “source of protein”. That claim has its own R.146 tests, and “claim held” is a sound decision.
What does R.6436 of 2025 require on a plant-based mince pack?
R.6436 of 2025, in operation since about 18 July 2026, allows “mince” on a meat analogue only with a descriptor before it, such as “plant-based mince”. No animal species or cut names go in the name, and no “beef-style” wording or animal images go on the pack. The main panel carries a statement such as “meat alternative”, and the product needs at least 9 percent protein as analysed.
The regulations were made under the Agricultural Product Standards Act and published as GN R.6436 in Government Gazette 53020 on 18 July 2025. Regulation 16 put them into operation 12 months from publication, with no calendar date given. Regulation 3(1) applies to anyone selling a meat analogue in South Africa, so imports are covered too.
Running a plant-based project on a certified site?
Intermediate Food Product Development (NPD) takes this mince through the R.6436 name, the worst-case protein estimate and the gate where an open must-meet keeps it on Hold. 16 hours online for R3 950. See what the course covers
Which names does R.6436 prescribe?
Annexure A lists burger, patty, sausage, banger, griller, loaf, polony, mince, roast and schnitzel, plus six shape names from frikkadel to sizzler. Mince is item 8. Its examples include “plant-based mince”, “vegan mince” and “veggie mince”, and regulation 7(1)(b) offers “soy mince”.
Names that are not prescribed are left alone. Regulation 3(3) gives “hot dog”, “steak”, “bites” and “tenders” as examples. Bobotie is not prescribed either, so a plant-based bobotie carries a dish name R.6436 does not restrict.
Two cautions apply. If the bobotie label calls a component mince, that word is prescribed and needs its descriptor. And the rules against misleading descriptions in R.146 and section 41 of the Consumer Protection Act apply to every pack.
Where does the descriptor go, and which words and pictures are out?
Before the name, under regulation 7(1)(a) and the note to Annexure A. The pack says “plant-based mince”, never “mince, plant-based”, and regulation 6(2)(a) wants the name prominent on a main panel, at least 2 mm high for lower case vowels.
Regulation 7(1)(c) keeps species and cut names out of the product name. Regulation 7(1)(d) keeps “chicken-style”, “beef-style”, “chick’n”, “b*con” and similar wording off the container and outer container, back panel and shipping case included. Regulation 7(1)(e) bars pictures of animal species on either.
Regulation 12(5) lets “meat free” appear on its own, but not as part of the name, not in close proximity to it and not in bigger letters. Where the 9 percent test applies, regulation 7(1)(f) asks for “meat replacer”, “meat substitute”, “meat alternative”, “plant-based protein”, “plant protein” or similar wording on the main panel.
| On the agency draft (illustrative) | Rule | Fix |
|---|---|---|
| “Beef” in the name | R.6436 reg 7(1)(c) | Remove |
| “-Style” | R.6436 reg 7(1)(d) | Remove from every panel |
| Cow outline | R.6436 reg 7(1)(e) | Remove |
| “Meat Free” opening the name | R.6436 reg 12(5) | Move it away from the name in smaller letters, or drop it |
| “Mince” with no descriptor | R.6436 reg 7(1)(a), Annexure A | “Plant-based mince” |
| No meat replacer statement | R.6436 reg 7(1)(f) | Add “Meat alternative” to the main panel |
| “Source of protein” | R.146 reg 52, Table 1 | Off until the analysis exists |
| “Vegan” | R.146 reg 48, R.6436 reg 12(4) | Hold until every additive and carrier has written plant origin and cross-contact is settled |
The corrected panel reads “Plant-based mince 400 g” with “Meat alternative” beside it and no animal anywhere. The name still waits for the laboratory.
How is the 9 percent measured?
Regulation 4(1)(c) asks for “a protein content of at least 9% as analysed” where the product replaces meat in burgers, patties, sausages, bangers, polony or mince. Regulation 14(1)(a) names the Kjeldahl method AOAC 955.04D with a factor of 6.25, or any other internationally recognised method.
“As analysed” ends a common argument. A spreadsheet gives a design estimate, which tells you whether the formula has a chance. The laboratory result on product from the line decides whether the name is printed.
Worked example
Design estimate = (TSP mass x TSP protein as supplied + protein from other ingredients) / batch mass
Batch mass = TSP mass x (1 + hydration) + other ingredients
In the training scenario (illustrative), a batch takes 15 500 g of textured soy protein (TSP), and the other ingredients weigh 28 200 g and bring 738.0 g of protein. With TSP at 50.0 percent protein and 2.6 g of water per g of TSP, the batch holds 8 488 g of protein in 84 000 g, or 10.10 percent.
Ask the laboratory to state the method, the basis and the expanded uncertainty on every report. Without the uncertainty, a result near 9.0 cannot be read.
Why design to the worst case of the specification?
At 10.10 percent the target looks comfortable. But TSP arrives at any protein the specification allows, and the line adds any water the specification allows. Build the estimate where both go against you.
| Case (illustrative) | TSP protein as supplied | Hydration, g water per g TSP | Design estimate |
|---|---|---|---|
| Worst case | 48.0% (minimum) | 2.8 (maximum) | 9.39% |
| Target | 50.0% (typical) | 2.6 (target) | 10.10% |
| Best case | 50.0% (typical) | 2.4 (minimum) | 10.49% |
The scenario’s worst case, 9.39 percent (illustrative), clears the legal 9.0 but misses the site’s 9.5 percent design floor, an illustrative internal margin for laboratory uncertainty and batch variation. At minimum protein the estimate reaches that floor at a hydration of 2.73 and the legal minimum at 3.04. The specification allows 2.8, so the specification, not the recipe, is what needs fixing.
Two fixes work on paper in the scenario. Tighten the hydration maximum to 2.7, which lifts the worst case to 9.56 percent, and calibrate the water meter so the line can hold it. Or ask the supplier for a 48.7 percent protein minimum, which reaches 9.5 percent at 2.8. Both still need analysed batches.
Check the basis too. In the scenario (illustrative) the specification gives protein as supplied, while the certificates of analysis report dry basis. As supplied = dry basis x (100 minus moisture) / 100. Supplier B’s lot, 52.0 percent dry at 6.9 percent moisture, is 48.41 percent as supplied, barely above the 48.0 minimum.
Work the worst case on your own case variant
Lesson 2.5 of Intermediate Food Product Development (NPD) builds this estimate step by step. The assessed practical then gives you your own case variant, so no two delegates share an answer. 16 hours online, R3 950. Enrol in Intermediate NPD
Is a result of exactly 9.0 percent a pass?
Not one you can print a name on. Here are the scenario’s three batches, Kjeldahl x 6.25 at an accredited laboratory (illustrative results).
| Batch (illustrative) | TSP lot, protein as supplied | Hydration g/g | Estimate | Analysed, with uncertainty of 0.3 |
|---|---|---|---|---|
| 1, bench | Lot A, 50.22% | 2.600 | 10.15% | 10.0% (9.7 to 10.3) |
| 2, pilot | Lot A, 50.22% | 2.700 | 9.96% | 9.7% (9.4 to 10.0) |
| 3, factory trial | Lot B, 48.41% | 2.948 | 9.22% | 9.0% (8.7 to 9.3) |
Batch 3 sits on the limit, and its interval dips to 8.7, so its true protein could be under 9. It also carried three changes. It was the first factory use of supplier B’s TSP, an uncalibrated water meter dosed 45 700 g against 40 300 g planned (illustrative), and it was the first batch on the factory line. One result cannot say which change cost the protein.
Every analysed result in the scenario sits 0.15 to 0.26 points below its estimate, while analysed moisture came in lower than estimated each time. Drier product should read higher, so moisture does not explain the gap. The laboratory must explain it before any estimate is trusted.
Before the name is released, further batches need hydration held by a calibrated meter and a tighter specification, TSP from an approved supplier, and analysed results from the factory line that clear 9.0 with a margin. Supplier B, with unknown GM status and no hydration specification, is not approved.
R.6436 says nothing about measurement uncertainty, so the decision rule is the site’s to write. A rule that keeps the bottom of the interval above 9.0 is one you can defend at audit.
In the course, the gate review after the factory trial rescores the project to 62.0 percent and sends it to Recycle (illustrative), as our post on gate reviews explains. The repeat trial and analysis add at least four weeks to a 20-week plan with no float on either step (illustrative).
Does passing the 9 percent test make it a source of protein?
No. The name and the claim are separate tests. Regulation 12(4) of R.6436 allows nutrient content claims on a meat analogue’s main panel only as the Foodstuffs, Cosmetics and Disinfectants Act regulations prescribe, which for labels means R.146.
For a solid food, “source of protein” under Table 1 Part B of R.146 needs at least 5 g protein per 100 g and at least 2.5 g per 418 kJ, and regulation 52(8) says both must be met. Regulation 52(11) adds that the analysed amino acids must reach 100 percent of each amino acid in the Annexure 5 reference pattern, with the protein sources named in the ingredient list. Regulation 50(12) wants claimed values from a reputable laboratory’s analysis of a composite sample, and the claim makes a nutrition table compulsory.
On the scenario’s calculated figures (illustrative), the mince carries 10.10 g protein per 100 g, so the quantity condition looks met. The per 418 kJ condition cannot be screened until energy is calculated, and regulation 50(3)(b) says that uses the factors in Annexure 2 of R.146 itself. Codex and EU factors are not R.146 factors. There is no amino acid result either, and a plant protein short of one amino acid can fail Annexure 5 with plenty of protein on paper.
The scenario’s bobotie shows the other edge, at a calculated 5.54 g per 100 g (illustrative), only 0.54 g above the line. On both packs the claim is held. “Claim held” is a decision, filed with the evidence that would release it.
What about labels designed before July 2026?
R.6436 has no transitional clause for printed stock or approved artwork. Treat plant-based artwork approved before July 2026 as a draft and check it again.
- An Annexure A name with its descriptor in front and no species name, at least 2 mm high for lower case vowels.
- No “-style” words or animal pictures on any panel, the outer case included.
- “Meat alternative” or similar on the main panel, and “meat free” only on its own.
- An analysed protein result for product made to the current specification on the current line.
- R.146 evidence behind every claim, and no comparison with meat, which regulation 12(6) bars.
Regulation 6(5) lets stickers cover incorrect particulars found at an inspection. That is a remedy after the fault is found, not a licence to keep printing wrong artwork.
Claims and artwork control in depth sit in Labelling Claims and Regulatory Framework, Advanced Food and Beverage Labelling and Allergen Labelling and Artwork Control. If you are not on a factory site, start with Introduction to Food Product Development (NPD), 8 hours online for R1 950.
Frequently asked questions
Can I call a soy product “mince” in South Africa?
Yes, if it meets R.6436 of 2025. The name needs a descriptor before it, as in “plant-based mince” or “soy mince”. The product needs at least 9 percent protein as analysed and a statement such as “meat alternative” on the main panel. Species names stay out of the name, and “beef-style” wording and animal images stay off the pack.
Are names like “steak”, “bites” or “bobotie” covered by R.6436?
Not by its naming rules. Regulation 3(3) leaves names that are not prescribed unrestricted, and “steak” and “bites” are among its examples. Bobotie is not prescribed either. The misleading description rules in R.146 and section 41 of the Consumer Protection Act still apply, and a component the label calls mince still needs its descriptor.
Where may “meat free” appear on a plant-based pack?
On its own, away from the product name. Regulation 12(5) of R.6436 says it may not form part of the name, sit in close proximity to the name or be printed in bigger letters than the name. “Meat Free Beef-Style Mince” fails the first of those and the species and “-style” rules as well.
Does R.6436 apply to imported meat alternatives?
Yes. Regulation 3(1) applies to anyone who sells a meat analogue in South Africa, so an imported product needs a prescribed name with its descriptor and no species name, 9 percent protein where that rule applies and no animal images.
Is a calculated protein figure enough to use the name?
No. R.6436 asks for 9 percent protein as analysed, by the Kjeldahl method with a factor of 6.25 or another internationally recognised method. A calculated figure is a design estimate. Build it at the worst case of your specification, then release the name only on analysed batches that clear 9 percent with a margin.
Take one plant-based range from brief to launch call
Intermediate Food Product Development (NPD) runs Thuthuka Fresh Meals, a training scenario, from the retailer’s private label brief to a gate 4 decision, with the R.6436 name and the claims screen on the way. 16 hours online for R3 950, with an ASC certificate when you pass. Start the Intermediate NPD course
Sources. GN R.6436 of 18 July 2025, Government Gazette 53020 (gov.za). R.146 of 2010, regulations 50 and 52 (Acts Online). Consumer Protection Act 68 of 2008, section 41 (Acts Online). General guidance, not legal advice.
Written by Mthokozisi Nkosi, Lead Auditor, Trainer and Consultant at ASC Food Safety Consultants.
