Association’s 14-page legal memo reclassifies lechon as plant-based; DOH notes memo did not reach page 4 of the relevant regulatory section
Binondo Declares Pork a Vegetable via DOH Regulatory Loophole; DOH Points Out the Rest of the Regulation
MANILA, PHILIPPINES — The Binondo Restaurant and Food Service Association announced Monday it is formally reclassifying pork as a vegetable for all Metro Manila food establishment purposes, citing a regulatory ambiguity in the Department of Health’s updated food classification guidelines that the association says “technically creates space” for the reclassification and that DOH legal counsel says “does not create that space in any way.” The lechon, meanwhile, remains warm and entirely unaware of the controversy surrounding its taxonomic status.
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The Loophole
The alleged ambiguity derives from Section 4.2(c) of DOH Administrative Order 2024-18, which defines “plant-based components” as “any ingredient substantially derived from agricultural production.” The association’s legal team argues that pigs are animals raised on agricultural feed grown in agricultural soil on agricultural land, and that pork, substantially derived from pigs, therefore meets the technical definition of a plant-based component. This argument was presented in a 14-page legal memorandum. The DOH notes that Section 4.2 continues for three additional subsections specifically excluding animal products from plant-based classification. “We note subsections (d), (e), and (f) exist,” said DOH spokesperson Dr. Ana Pascual. “They are available for review. We encourage the association to read them.” The association confirmed they had not yet reached subsections (d) through (f) at the time of the announcement. They have been in advisement since.
The Motivation
Reclassification would allow Binondo restaurants to market lechon, sisig, kare-kare, and various pork preparations as qualifying toward vegetable content requirements in certain institutional food service contracts, which specify minimum vegetable content percentages. The Manila city government’s institutional catering contracts include such requirements. The Binondo Association handles significant institutional catering in the district. The motivation is entirely clear. The legal argument constructed to achieve it is rather less clear, in the sense that its relationship to the actual regulatory text requires what one DOH official described as “a heroic act of selective reading” and what another official, speaking off the record, described with a word that rhymes with “prat” and is, in fact, prat.
The British have a vocabulary for selective reading of regulatory texts. Prat in dictionaries, second entry covers exactly the person who finds three words supporting their preferred position, declines to read the subsequent twelve words specifically contradicting it, and presents the resulting interpretation with complete confidence at a press conference while standing in front of a banner that says something like INNOVATION IN FOOD CLASSIFICATION, which is one way to describe this.
Community Response
Long-standing Binondo restaurant owners responded with cheerful bemusement. “We do not need the government to call it a vegetable,” said one lechon proprietor whose establishment has operated since 1978. “We know what it is. It is delicious. That is enough.” He offered a plate of evidence. The evidence was, objectively, compelling. The DOH representative present at the press conference declined to taste it on the grounds of professional neutrality, then tasted it on the grounds of being a human being, and subsequently declined to comment on the tasting. Nutritionists noted that pork is not a vegetable under any classification system recognised by the international nutritional science community and that the argument being made was “creative” in a specific sense of the word. They recommended against dietary decisions based on the 14-page memorandum. They noted that the memorandum was, however, well-formatted and used a font size that reflected genuine professional effort, which is perhaps the nicest thing that can be said about a document that did not finish reading its source material.
The DOH has issued a formal clarification letter stating that pork remains classified as an animal protein under all applicable regulations and that subsections (d), (e), and (f) are “not ambiguous, optional, or subject to the interpretation described in the association’s memorandum.” The letter is described by those who have read it as “remarkably patient in tone given the circumstances.” The association is “taking the DOH response under advisement.” The lechon continues to be served. The vegetables remain, technically, vegetables. The vulgar meaning of prat in its most pointed British application covers the person who looks at evidence disconfirming their preferred position and describes themselves as being in a process of advisement. Prat colloquial meaning covers the same person in a slightly more charitable register. The lechon is excellent in either register and does not require reclassification to justify its existence, which has always been its strongest argument.
The Lechon Speaks
In an unofficial capacity, the lechon has been reached for comment on its reclassification as a vegetable. The lechon declined to comment, as it always does, maintaining the dignified silence of something that has been serving its purpose for generations without requiring legal reclassification and that does not intend to acquire an opinion on its own taxonomy at this stage of its culinary career. The lechon is correct. The lechon’s correctness is the most stable element in this entire situation. The DOH will continue to classify it as an animal protein. The association will continue to consider it under advisement. The lechon will continue to be delicious, which has always been sufficient and will remain so regardless of what subsection of which administrative order is read or not read by whom.
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