[Kim Taemin's Food and Medicine Story] Delivery Food and HMR Era... Keeping Our Table Safe

HMR Outer Packaging Established as Household Substitute Meals Exempt from Food Labeling
Food Hygiene Management Blind Spots in Processing of Vegetables and Livestock Products
Manufacturing and Processed Food Stores Should Be Regulated Differently Based on Scale

Spending the second Chuseok holiday amid COVID-19, I felt that the day is not far off when Home Meal Replacements (HMR), which have been substituting the dining-out market, will also take their place on the ancestral ritual tables. When HMR first appeared on the market several years ago, they merely imitated famous menus from some popular restaurants. However, they have now established themselves as true home substitutes that satisfy all aspects including taste, price, and quality. Due to the spread of one- to two-person households and busy social lives, preparing ingredients and cooking at home is no longer advantageous in terms of cost or time, and ultimately, the taste difference has made even following famous chefs' recipes meaningless.

Food Labeling Required on Outer Packaging of Easy Cooking Sets

The Ministry of Food and Drug Safety (MFDS) reflected the popularization trend of HMR by newly establishing a food category called ‘Easy Cooking Sets’ under the Standards and Specifications for Foods according to the Food Sanitation Act in October last year. Before the revision, HMR occupied a very ambiguous position and was in a blind spot in terms of management. Looking at the product composition, it was simply packaging vegetables that had undergone cutting and washing processes, appropriately sized livestock products, and processed foods such as kimchi, tofu, and sauces, raising questions about whether the product itself was truly a processed food. Moreover, when livestock products were included, management under the Livestock Products Sanitary Control Act was required, causing considerable confusion among local governments, the supervisory agencies, due to differing relevant laws depending on product composition. Considering the confusion faced by frontline administrative agencies, it was very welcome that the MFDS promptly resolved the issue by newly establishing a food category and setting standards and specifications.

However, food labeling is still not consumer-friendly. Some easy cooking sets sold online are products where, unlike general foods, consumers cannot check the components, expiration dates, or ingredients until the outer packaging is opened. Even if easy cooking sets are sold in containers without special processing, at minimum, the packaging containers holding the components of the set should include labeling for all ingredients. In 2019, the MFDS allowed exemption from food labeling on outer packaging of set-packaged foods sold online under the ‘New Industry Field Regulatory Innovation Plan,’ causing confusion only for consumers.

For cut vegetables frequently used in HMR, unless the manufacturer directly purchases, washes, and cuts the vegetables, regulations need to be strengthened to require purchasing from Food Safety Management Certification (HACCP) certified companies. Using products packaged by simple agricultural product processors inevitably causes practical problems in thorough safety management. Since the final manufacturer of home meal replacement sets does not have actual processing steps, this principle is essential unlike other processed foods.

Strengthening Hygiene Management for Restaurant Delivery and Side Dish Stores

Considering hygiene, the practice of selling cooked food via delivery services from general restaurants should also be more strictly regulated. Currently, administrative agencies such as the MFDS do not take significant issue with restaurants delivering ordered food to distant customers via parcel services, separate from customers visiting the restaurant to take out food or ordering semi-cooked food by phone. However, frequent large-scale food poisoning incidents at general restaurants this summer have brought the previously lax hygiene management of general restaurants into focus. General restaurants are assumed to have relatively few customers consuming cooked food in a short time, so their facility management standards are lower than those for food manufacturing and processing businesses, and relaxed hygiene standards are applied. However, risks have been raised regarding time and temperature management, the most critical factors in food hygiene, in the delivery of cooked food.

Finally, management of instant sales manufacturing and processing businesses such as side dish stores must also be strengthened. Instant sales manufacturing and processing businesses literally sell foods manufactured and processed on-site at the business location. They must sell products cooked on-site and only to the final consumer. Like general restaurants, instant sales manufacturing and processing businesses are subject to lower legal standards for hygiene and facility management than food manufacturing and processing businesses, as they sell food only to final consumers visiting the store. However, instant sales manufacturing and processing businesses such as side dish stores have grown in scale, with some generating tens of billions of won in sales, raising the need to differentiate regulations according to scale.

Nowadays, it has become common to seek hygienically and deliciously prepared food rather than feeling a mother’s sweat and devotion at the dining table. Therefore, the most important factor must be food safety. From home meal replacements to cooked foods from famous restaurants and side dishes, everyone must not forget that safety is the top priority.

/ Lawyer, Food Sanitation Law Research Institute