Labelling Requirements for Fish and Fish Products
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Table of Contents
- Common Name - Fish and Fish Products
- Additional Terms
- Net Quantity - Fish and Fish Products
- Storage Instructions and Handling Labelling
- Nutrition Labelling - Fish and Fish Products
- Legibility and Location - Fish and Fish Products
- Country of Origin - Fish and Fish Products
- Grade, Size Class, Count and Moisture Content
- Code Markings
- Shipping Containers and Institutional Packages
- Molluscan Shellfish Labelling Requirements
- Voluntary Claims and Statements
- Label Example
- Additional Information
For the purposes of this webpage, "fish" means any marine animal, including fish, shellfish, crustaceans and also other marine animals such as marine mammals.
The labelling requirements of the Fish Inspection Regulations (FIR) that are summarized in this section apply to all of those animals and any parts, products or by-products thereof processed in federally registered establishments, as well as to imported products. When sold in Canada, fish and fish products are also subject to the labelling requirements under the Food and Drugs Act (FDA) and the Consumer Packaging and Labelling Act (CPLA).
Fish and fish products destined for intraprovincial trade are subject to the labelling requirements under the Food and Drugs Act and the Consumer Packaging and Labelling Act. These are summarized in the core labelling, claims and statements, and food-specific labelling requirement pages of the Industry Labelling Tool. Provincial regulations may also apply to products sold within that province.
The requirements detailed in the following sections are specific to fish and fish products. They are in addition to the core labelling and other requirements that apply to all prepackaged foods.
Common Name - Fish and Fish Products
Every fish, can of fish or the wrapper or label thereon shall be correctly and legibly marked with the common name of the fish. Refer to Legibility and Location – Fish and Fish Products for more information. [25(1)(a) and (2), 26(1)(a) and (2), FIR].
The common name of a fish product is [B.01.001, B.01.006(1), Food and Drug Regulations]:
- the name prescribed by the Fish Inspection Regulations (or other applicable Canadian legislation) [38-40, 51, 52, 72, FIR] or
- the name identified by boldface type in the Food and Drug Regulations; or
- if the name is not prescribed in legislation, the name by which the food is generally known;
CFIA Fish List
The CFIA Fish List provides regulatory guidance regarding the common names for fish. The names on the CFIA Fish List are considered acceptable common names and the use of these names is recommended. The use of common names that are not on the CFIA Fish List can be assessed against the requirement that no person shall package or label fish in a manner that is false, misleading or deceptive [27, FIR; 5(1), FDA; 7(1), CPLA].
The CFIA Fish List also provides a Taxonomic Serial Number (TSN) for each species, along with any associated hazards. Scientific names for fish species are verified with the Integrated Taxonomic Information System (ITIS).
Anyone seeking an amendment (deletion or addition) to the CFIA Fish List may submit a request through the Ask CFIA website. Applications can be made in accordance with Section 5 of the Guidance on Determining the Common Names for Fish Sold or Processed in Canada.
Generic Common Names
Unless outlined in the Fish Inspection Regulations, the use of generic names such as "fish fillets" or "fish portions" is not permitted. A name of the species should be incorporated into the common name, for example "haddock fillets", "cod portions".
Labelling of Pacific Salmon in Canada
The name "Pacific Salmon" is not included as an acceptable common name in the CFIA Fish List due to the different market values of species of Pacific salmon. As described above, the common name must always include the name of the species, for example "chum salmon fillets" or "sockeye salmon portions". The statement "Pacific salmon" is permitted on the label only as additional information, but may not replace the common name.
Indication of Geographic Origin
The geographic location where the fish has been harvested may be added to the common name, however this is optional.
Canned Fish Products
The common name on canned fish must:
- be shown in letters of equal height and prominence, and
- indicate whether the product has been prepared
- by mincing, flaking or other special process;
- from selected parts of fish;
- for dietetic use [25(1)b, FIR].
Fish products that are made from surimi (a paste made from highly refined minced fish) must use the name by which the food is generally known, as there is no prescribed common name in the Fish Inspection Regulations nor identified in boldface type in the Food and Drug Regulations. Therefore, such products may use the term "surimi" in the common name, and should include additional descriptors as appropriate (e.g. surimi roll, surimi cakes).
In some instances, surimi-based products closely resemble more expensive seafood products, such as crab legs, shrimps, or scallops through flavouring and shaping. Surimi-based products that resemble these foods should be labelled and/or advertised to clearly show that they are imitations.
- The common name identifies the term "artificial" or "simulated" or "imitation", (such as, "artificial crab legs" and "imitation lobster meat"), or
- The common name identifies the name of the species used in the product, (such as, "crab flavoured Alaskan Pollock" and "Lobster flavoured seafood made from whiting"), or
- If various species were used, the common name refers to a generic name (such as, "crab flavoured seafood" and "lobster flavoured kamaboko")
From a single species
If the oil has been extracted from a single species of fish or marine animal, the common name of the product should be the common name of the species, e.g. "halibut oil" or "seal oil".
From various species
If the oil is a mixture of oils extracted from various species, the name of the product must include all the common names of the species, e.g., "salmon, sardine and seal oil" and the common names of the species must be repeated in the list of ingredients. The common names must be declared in the ingredients list in descending order by their content in the product.
If the oil has been extracted from multiple marine animal species, and not from fish species, a generic common name "Marine oil" can be used. The common names of the marine species must be included in the list of ingredients in descending order by their content in the product.
If the oil has been extracted from multiple fish species, but not from other marine animals such as seals, a generic common name "Fish oil" can be used, and common names of the fish species must be included in the list of ingredients in descending order by their content in the product.
Descriptive terms are required on some prepacked fish products:
- In the case of canned fish, descriptive terms must be printed in the letters not less than one-half of the letters used for the common name [25(3), FIR].
- In the case of fish, other than canned fish, descriptive terms are required if their absence would make the label false, misleading or deceptive [27, FIR].
For instance, uniform rectangular portions of breaded minced fish require "made from minced fish"/ "fait de poisson haché" in close proximity to the common name, and in letters not less than one-half of the letters used for the common name [51(4), FIR].
The labels of all cans of tuna must indicate the colour of the fish flesh [49, FIR]:
- "white meat tuna" or "white tuna" (only tuna of the species Thunnus alalunga or Thunnus germo),
- "light meat tuna" or "light tuna";
- "dark meat tuna" or "dark tuna".
Each container of whitefish (Coregonus clupeaformis) must be marked in English or French with the name of the lake of origin of the whitefish, including the name of the province, and the words "dressed whitefish" or "round whitefish" or "whitefish fillets", as the case may be.
Use of Filtered Smoke
For fish processed using filtered smoke, absence of a descriptor indicating the presence of filtered smoke in close proximity to the common name may be considered misleading. Acceptable statements include:
- "(Colour – optional) preserved with filtered wood smoke" or "(Colour – optional) preserved with purified smoke" or other similar statements identifying clearly that the colour of the fish is not natural but was altered; or,
- "Processed with filtered wood smoke as a preservative (for color retention - optional)"; or,
- "Produced using filtered wood smoke"
Net Quantity - Fish and Fish Products
The net quantity declaration on prepackaged fish is mandatory unless the container or label states that the contents are to be weighed at the time of retail sale (catch weight) [25(1)(b), 26(1)(b), FIR].
|Oysters in the Shell||Weight or bushels or pecks or by count|
|Oyster and clam meats – not frozen||Weight or fluid measures or count|
|Canned shellfish and crustaceans||Drained Weight|
|Canned fish packed with added water||Drained weight|
|Fish frozen with glaze||Excluding weight of the glaze|
|Fish packed in brine or vinegar solution||Drained weight|
The words "net weight" or "drained weight" can be used only on fish products that contain only edible parts. If the product also contains inedible parts such as shells, the word "weight" alone must be used.
Weight declarations such as "made from X lb" (e.g. for peeled shrimp) or "net weight when packed" (e.g. live mussels) are unacceptable.
See Legibility and Location – Fish and Fish Products for information on these requirements.
Storage Instructions and Handling Labelling
Smoked or Liquid Smoked Fish
Fish which is packed to exclude air and which has been smoked or to which liquid smoke or liquid smoke flavour concentrate has been added and which:
- contains less than nine per cent of salt; and
- has not been heat processed after sealing at a temperature and for a time sufficient to destroy all spores of the species Clostridium botulinum; and
- is not customarily cooked prior to use
requires the statement "Keep frozen prior to use"/ "Garder congelé jusqu'à utilisation" on the principal display panel in letter size equal to the letters used in the common name [B.21.025, FDR].
Note: Smoked fish packed with oxygen permeable screensFootnote 1 needs no freezing and can be stored under refrigeration conditions. The statement "keep frozen prior to use" is not required, however the statement "Keep refrigerated" must be present, and the shelf life indicated on the label cannot exceed 14 days. The information on oxygen permeability of the packaging material must be available to an inspector up to retail level.
Heat Treated Non-RTE Fish Products
Fish products that have received some heat treatment but are not ready-to eat products (e.g., frozen blanched crab legs, frozen "flash fried" breaded fish portions), and which may be perceived as such by consumers, must be labelled as follows:
- Information indicating that the product is raw and must be properly cooked prior to use must be clearly visible and present in both official languages on the principal display panel (PDP).
- Statements such as "ready-to-eat," "heat and serve", "grilled fillets", "fried fish" or other statements giving any impression that the product can be consumed without further cooking are not permitted.
- Cooking instructions are optional. However, if present, they must be adequate to ensure safety of the product.
- If a vignette is present which creates an impression that the product is ready-to-eat, the statement "Serving suggestion" (or similar) in both official languages must be on, or adjacent to, the vignette.
- Storage conditions to ensure safety of the product must be present on the label in both official languages (e.g., "keep frozen" statement on frozen products; "keep refrigerated" and "best before" date on products sold under refrigeration).
Previously Frozen Fish and Fish Products
Any fish [B.21.003, FDR] or the meat of any marine or fresh water animal [B.21.004, FDR] that has been frozen and thawed prior to sale must declare the words "previously frozen" on their principal display panel or on a sign displayed close to the food in letters that are legible and discernible. This includes both prepackaged and non-prepackaged products. When declared on the principal display panel, these words must either be close to the common name of the food in letters that are the same size as those used for the common name or anywhere on the principal display panel in letters that are at least ¼ of an inch (6.4 mm) in height [B.01.080, FDR].
If part of one of these foods has been frozen and thawed prior to sale, the words "Made from fresh and frozen portions" or "Made from fresh and frozen (naming the food)" must be declared [B.01.080, FDR].
As per the FDR, "frozen" means preserved by freezing temperatures and does not include any surface freezing that may occur during holding and transportation [B.01.080, FDR].
Nutrition Labelling - Fish and Fish Products
Raw, single ingredient marine or freshwater animal products (in fresh or frozen form) are usually exempt from carrying a Nutrition Facts table. This includes fish, crustaceans and combinations of raw, single ingredient marine or fresh water animal products (e.g. a mixture of raw single ingredient shrimp and scallops) [B.01.401(2)(b)(iv), FDR].
Smoked fish is not a single-ingredient food since smoke must be declared and salt is added; therefore, it is not exempt from carrying a NFT.
If a registered processor custom-processes sport-caught fish, charges a fee for the service of processing the fish for personal consumption by the fisher, and the fish is returned in a package, then no sale is involved and an NFT is not required [B.01.004(2), FDR].
Legibility and Location - Fish and Fish Products
The common name, net quantity declaration and grade, size, class count or moisture content declarations on consumer packages (canned, and other than canned containing 900 g or less of fish) must appear in letters not less than 3.2 mm in height [26(2), FIR].
Note: Where the area of the principal display panel is greater than 258 square centimetres, the minimum type height of numerals in the net quantity must comply with the height prescribed in Section 14 of CPLR. Refer to the Net Quantity Legibility and Location requirements for more information.
Country of Origin - Fish and Fish Products
For fish or fish products imported into Canada, the name of the country of origin must be clearly identified on the label. The wording "Product of /Produit de" must be used to clearly identify the name of the country of origin [6(2)(c), FIR].
For imported fish products, the country of origin is the country where the last substantial transformation occurred.
For domestic products, a country of origin declaration is not required but may be provided voluntarily.
Grade, Size Class, Count and Moisture Content
|Fish Product||Required Information|
|Pickled Fish||Grade, Class and Size|
|Bloaters||Grade and Count|
|Frozen Atlantic Smelts||Size|
|Atlantic Oysters in the shell||Shape Designations|
Code markings are required on cartons and cases in which containers of domestically processed or imported fish are packed, as well as every container of pickled, spiced or marinated fish [6(2)(a), 6(3), 31, 32, FIR]. These markings must identify:
- the name of the establishment and
- indicate the day, month and year of processing and
- for some products, identify the product (using the table Code Marking Letters for Product Identification below).
Every hermetically sealed container of fish that has been sterilized must be embossed or otherwise permanently marked to identify [33, FIR]:
- the name of the establishment and
- the day, month and year of processing and
- for some products, identify the product (using the table Code Marking Letters for Product Identification below).
The meaning of code markings must be available to an inspector.
Code Marking Letters for Product Identification
|Product||First letters of code marking|
|Mixed species of minced salmon||M|
|Tomalley or lobster paste||LT|
Shipping Containers and Institutional Packages
Shipping Containers for Fish and Fish Products
Labels of shipping containers (master cartons) for fish and fish products containing labelled retail packages, require [6(2)(a), 26(1)(f), 31(1), FIR]:
- the common name of the fish;
- the identity of the establishment
- day, month and year of processing; and
- the harvest location for bivalve molluscs in the shell.
All mandatory information normally applied on consumer packages is required on shipping containers with bulk fish, or containing fish packages with no labels (for institutional use).
The master carton label information can be in either English or French, and net quantity expressed in either metric or imperial units.
Protective wrappings are normally associated with bulk packaging, or with products that cannot be transported without adversely affecting its quality e.g. blocks of shrimp. Where fish are held within a protective wrapping, inside a properly labelled shipping container, then these protective wrappings are not considered to be inner packages and do not require labelling.
For more information on the shipping container requirements of the Food and Drug Regulations, please refer to Shipping Containers.
Institutional Packages for Fish and Fish Products
The net weight on institutional packages can be expressed either in metric or Imperial units.
Declaration of an approximate portion size on institutional packages is considered non-mandatory information, and e.g. the statement "about 60 g/portion" is acceptable.
Imports into Canada
All imported products must meet Canadian labelling requirements, including code markings.
It is the importer's responsibility to ensure that code marking information is securely, legibly and clearly stated on one end of the master carton prior to export to Canada. The CFIA will not allow importers to add this information to containers after they arrive in Canada.
Exports from Canada
In the case of fish products exported outside Canada, the label must meet Canadian labelling requirements unless an exemption from the regulation(s) is applied for and granted by the Fish, Seafood and Production Division. The exemption may be granted if the exporter supplies the Division with appropriate documentation from the regulatory authorities of the importing country that the label is acceptable in their country. In cases where the Division is already aware of the requirements, the exporter need not acquire the noted documentation.
Master cartons containing containers of fish products with exempted labels must bear the statement "For export to (a name of the country)".
Molluscan Shellfish Labelling Requirements
Live Molluscan Shellfish
In addition to the mandatory information that must be present on all food labels, the FIR requires that the label for bivalve molluscs in the shell must be correctly and legibly marked to show the date of processing and the location from which the bivalve molluscs were harvested [26(1)(f), FIR].
The label must also indicate either a "best before" date, or the date the molluscs were harvested. This date must be expressed on the label in the manner required in B.01.007(4)(d) and (5) of the FDR, (e.g. 97 JA 15 for January 15th 1997). The full year can be written out for clarity, e.g. 2003 JA 05. The statement "keep refrigerated" and the certification number of the registered establishment where the shellfish were processed must be also present on the label.
When live molluscs were wet-stored or relayed for more than 14 days, the harvesting date is the date when the molluscs were removed from the wet storage or relay site. When live molluscs were depurated, it must be indicated on the label.
Raw Shucked Molluscan Shellfish
In addition to the mandatory information that must be present on all food labels, the label on shucked molluscan shellfish sold fresh must indicate the registered establishment's certification number, the processing dateFootnote 2, the "best before" date and the statement "Keep refrigerated".
The label on shucked molluscan shellfish sold frozen must indicate the registered establishment's certification number, the processing dateFootnote 2, and the word "frozen" which must be immediately adjacent to the common name of the shellfish, and it must be in the letter type of equal prominence to the common name.
The "best before" date must be expressed on the label in the manner required in B.01.007(4)(d) and (5), FDR (e.g. 97 JA 15 for January 15th 1997). The full year can be written out for clarity, e.g. 2003 JA 05.
Where shucked meats were processed from depurated molluscan shellfish, it should be indicated on the label.
Voluntary Claims and Statements
The term "light salted" with respect to fish is specifically permitted in the Food and Drug Regulations (FDR) [B.01.502(2)(k), FDR]. Using this term does not trigger the Nutrition Facts table on exempted foods. Please refer to Composition and Quality Claims for more information on "light" claims that are specifically permitted under B.01.502(2) of the FDR.
Refer to Nutrient Content Claims for more information.
A quality designation can be used only when a standard for that quality has been prescribed in the FIR, and the product meets that standard, e.g. "Fancy Shape" designation on Atlantic oysters is permitted when the oysters meet the requirements indicated in Section 65(a) of FIR [29, FIR].
Quality claims, where it is clear that the processor or importer or distributor is declaring responsibility for the quality, are permitted, e.g. "All Company X products meet our highest standards. If you have any questions or comments please write to us at: Company X, 123 Main St., Town, Province, Postal Code" would be an acceptable statement.
General statements such as "Quality products from XX", "Satisfaction guaranteed", "Guaranteed quality", etc. are also acceptable.
Method of Production Claims (e.g. sustainable, dolphin safe, etc.)
It is the responsibility of the company to ensure that all information contained on labels is truthful and not misleading. Companies who wish to place such statements on the labels must develop their own procedure to ensure that the product meets the claim. Upon request, documentation providing proof of these methods must be available to an Inspector of the CFIA.
Use of the "Canada Inspected" Logo
All fish establishments registered under the FIR are entitled to use the "Canada Inspected" logo on fish products processed as part of the establishment's Quality Management Program (QMP). Only fish products that are considered "Product of Canada" can bear the logo [28, FIR]. Refer to "Product of Canada" and "Made in Canada" Labelling for more information on the use of this statement.
There are no restrictions as to the size or the colour of the logo; however, the logo must be separate and distinct, and must not interfere with any mandatory labelling requirements. Permitted examples of "Canada Inspected" logos are shown in Bulletin 41 of the Fish Products Inspection Manual. The registration number of the establishment may be included in the logo.
Label for Fish Products
Any fish that is sealed in a can and is sterilized [2, FIR].
A prepackaged product that, because of its nature, cannot normally be proportioned to a predetermined quantity and is, as a result, usually sold in varying quantities [38, CPLR].
The weight of the edible contents of the container exclusive of free water, brine, pickling solution or glaze [2, FIR].
Any fish, including shellfish and crustaceans, and marine animals, and any parts, products or by-products thereof [2, FIA].
Fish or prepared fish [B.01.001, FDR].
With respect to unfrozen or frozen lobster meat, means the weight of the edible contents of a container after the liquid has been drained from the container by a method approved by the President of the Agency and, with respect to any other fish, means the total weight of the edible contents of a container [2, FIR].
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