In October 2025, I had the opportunity to discuss in a post on this blog the latest chapter in the long-running debate over the use of meat-related names for plant-based foods. Back then, the legislative process was still ongoing and the proposed restrictions raised several questions, particularly in light of the judgment rendered by the Court of Justice of the European Union (CJEU) in Protéines France.
That judgment had made one point particularly clear: in the absence of a “legal name”, EU Member States cannot simply prohibit plant-based foods from using customary or descriptive names traditionally associated with products of animal origin. One of the questions arising from that case was therefore whether the EU or national legislators would respond by legally reserving specific meat-related terms.
The EU legislator now has.
Regulation (EU) 2026/1739, published on 29 July 2026, amended Regulation (EU) No 1308/2013 on the common organisation of the markets in agricultural products (the ‘CMO Regulation’). It did so by introducing, among other measures, EU-wide protection for various meat-related designations, although these are less numerous than those contemplated during the legislative process.
The latest CMO amendment inserts a new Part Ia into Annex VII of Regulation (EU) No 1308/2013. “Meat” is defined as the edible parts of an animal, while “meat products” are products derived from meat in which additional substances may be used, as long as they do not replace, wholly or partly, a meat constituent. In addition to the word “meat”, the Regulation (EU) 2026/1739 reserves a closed list of 31 designations. These include species-related terms such as “beef”, “veal”, “pork”, “poultry”, “chicken”, “turkey”, “lamb” and “goat”, as well as product- or cut-related terms such as “tenderloin”, “sirloin”, “ribs”, “chop”, “ribeye”, “T-bone”, “bacon”, “steak” and “liver”.
The final text is, however, notable for the terms it does not reserve for meat and meat products. “Burger”, “hamburger”, “sausage” and “escalope”, which featured prominently in earlier discussions, do not appear on the final list. A “plant-based steak” will therefore fall within the new restrictions, whereas a “veggie burger” will not. While this represents a significant narrowing of the position discussed in my previous post, the most recent CMO amendment still fails to provide definitions of such food products, which would allow them to be framed as legal names within the meaning of Regulation (EU) No 1169/2011 on the provision of food information to consumers. While it is true that the same can be said of certain names reserved for dairy products under the same CMO Regulation, it should also be taken into account that the legal protection of such names was established well before the adoption of Regulation (EU) No 1169/2011 and, most importantly, before the CJEU’s ruling in Protéines France.
Moreover, Regulation (EU) 2026/1739 contains a particularly important restriction concerning cultivated food applications, which, as discussed in my very first post in this blog, are foods produced through innovative cell- or tissue-culture techniques. Accordingly, the reserved terms may not be used for foods consisting of, isolated from or produced from cell or tissue culture derived from animals, but also from plants, microorganisms, fungi or algae (new point 4, Part Ia, Annex VII).
Such a restriction goes well beyond the plant-based naming debate, insofar as food applications resulting from cell- or culture-based technologies are already regulated under a separate and dedicated legal framework: Regulation (EU) 2015/2283 on novel foods. That regulation establishes an EU-level pre-authorisation procedure aimed at assessing the safety of products qualifying as novel foods. Where appropriate, notably where necessary to ensure that consumers are properly informed and not misled, the authorisation may also prescribe the name or designation under which a novel food is to be marketed in the EU. One could reasonably expect this to occur in the case of food applications resulting from cell- and culture-based technologies, precisely to ensure their appropriate differentiation from conventional food products. In the absence of precedents — no cultivated food application has yet been authorised as a novel food in the EU, while two cultivated meat applications are currently pending — one could argue that the solution adopted by Regulation (EU) 2026/1739 raises questions as to its legal soundness, namely because established authorisation practice suggests that the EU novel food framework may be better suited to addressing the naming of such food innovations on a product-specific basis.
Against this background, the choices ultimately made by the EU legislator in adopting Regulation (EU) 2026/1739 are legally sensitive and may expose this regulation to challenges before the CJEU. This could occur directly through an action for annulment under Article 263 of the Treaty on the Functioning of the European Union (TFEU) or, indirectly, through national litigation leading to a preliminary reference concerning the validity or interpretation of the regulation in light of the existing EU food law acquis.
One practical concern raised in my previous post has, however, been substantially addressed by the EU legislator in the final text of Regulation (EU) 2026/1739. The new naming restrictions will apply only from 19 August 2029, whereas products manufactured in or imported into the EU under the previous rules before that date may continue to be marketed until stocks are exhausted and, in any event, no later than 19 August 2032. These transitional periods will give concerned food business operators sufficient time to adapt labels, packaging and marketing strategies and avoid the costs and waste associated with immediate re-labelling.
The new naming rules also raise a broader regulatory question. EU law has long reserved dairy terms for dairy products, subject to limited exceptions. Meat-related terminology is now subject to a comparable protection regime. The question is whether similar rules may eventually be considered for fishery products. Fishery and aquaculture products have been expressly excluded from the new meat naming restrictions and, thus, remain subject to their own EU market regime. For now, there is no equivalent prohibition addressing fishery alternatives under Regulation (EU) No 1379/2013. However, as the market for such alternative products steadily expands, the same arguments concerning protection of established sectors, traditional terminology and consumer information may eventually surface.
In conclusion, Regulation (EU) 2026/1739 thus introduces more stringent rules governing the use of certain meat-related designations. While this may ensure strengthened legal protection for conventional meat products and greater transparency in commercial practices, it does not necessarily bring the naming debate to an end. If anything, the final text raises questions concerning its interaction with the existing EU food law acquis, notably the notion of a “legal name” under Regulation (EU) No 1169/2011 and the specific regime applicable to novel foods. Whether these questions will eventually require clarification from the CJEU remains to be seen.
More broadly, the progressive reservation of terminology associated with products of animal origin invites reflection on the direction in which EU food law is developing as regards the naming of food products. Dairy names have long been protected; selected meat-related designations now join them; and fishery products may provide the next testing ground. The question is therefore no longer only whether plant-based foods should be “left alone” or warrant a dedicated regulatory framework. Rather, it is about how far the EU legislator intends to go in reserving established food terminology for particular products and methods of production and, most importantly, to what extent considerations of fair business practices and consumer protection justify drawing those boundaries.