In a stainless steel bowl placed over a saucepan of simmering water, whisk together the eggs, sugar, and lemon juice until blended. Cook, stirring constantly until the mixture becomes thick, similar to sour cream or a hollandaise sauce. This will take approximately 10 minutes. Remove from heat and immediately pour through a fine strainer to remove any lumps. Add the butter and whisk into the mixture until the butter has melted. Add the lemon zest and let cool. The lemon curd will continue to thicken as it cools. Cover immediately (so a skin doesn't form) and refrigerate. Once cooled and thick, pipe or spoon the curd into the tart shells. Refrigerate until time of service.
Fresh berries make a nice garnish for these petite tarts.
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