Labelling Requirements for Fish and Fish Products
Storage Instructions and Handling Labelling
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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].
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