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Forthcoming changes in European labelling of fishery products

The European regulation (EC) No 1379/2013 of the European Parliament and of the Council refers to the common organization of the markets in fishery and aquaculture products. Relevant are mandatory information concerning the labelling of fishery products in the market of European Union.

For this regulation mandatory information for the consumer are: a) the commercial designation of the species and its scientific name;(b) the production method, in particular by the following words"… caught …" or "… caught in freshwater …" or "…farmed …";(c) the area where the product was caught or farmed, and the category of fishing gear used in capture of fisheries, (d) whether the product has been defrosted;(e) the date of minimum durability, where appropriate.

This regulation thus introduced important elements that improved and facilitated the traceability of fishery products. It is also necessary to bear in mind that each different species of fish and fishery product has a different shelf life according to the different countries concerned, as the method of capture and the way it is processed has an influence on the duration of the shelf life. For this reason the new regulation includes the necessity to specify the type or category of fishing gear or equipment used. This will also help improve traceability and limit illegal fishing. Knowing the catch zone and catching method will enable data searches to check if the catching method was registered as being used in that zone. Regarding the indication of the catch of production area, different sub areas are mentioned. This process was further strengthened by means ofthe Regulation (EC) No 178/2002 of the European Parliament and of the Council which lays down the general principles and requirements of food law, and in Article 18 deals with traceability. Another milestone of EU regulation with regard to labelling and traceability was the Council Regulation (EC) No. 1005/2008 of 29 September 2008 establishing a Community system to prevent, determine and eliminate illegal, unreported and unregulated fishing, including catch certification schemes and indicating that no IUU fish product can enter the EU market.

Regulation (EC) No 1169/2011 introduced some important new norms regarding the labelling of fishery products and food products in general. These changes consist of features regarding nutritional labelling and the indication of origin, style and format of labelling, allergens, date of minimum durability/expiry, the percentage of water content, the specification of defrosting if this has occurred, the specification of combined foodstuffs, animal or vegetable origin of oils used, the person or body with legal responsibility for any infractions and legislative indications for sale at a distance.

The articles contained in these  last  legislations  will become valid and enforceable on the 13th of December 2014 as regards mandatory information to the consumer(including fishing gear used and the sell-by/expiry dates of foodstuffs), while the articles regarding nutritional labelling will become valid and enforceable on the 13th of December 2016. At present there is no obligation to specify the sell-by/expiry dates of imported fishery products into the EU, but as the date of December 2014 is imminent those countries that export fishery products to the European Union should already now already start to consider how to bring their products into conformity with the new regulations. For this reason they must know the shelf life of the various categories of fishery products by conducting internationally certified and valid laboratory tests in order to label the goods properly and avoid any alerts, rejections or blocks regarding the quality of their products. This is extremely important, especially forthose countries that export fresh fishery products. Any non-compliance with the labelling regulations will lead to rejection which in turn will affect professional activities and local economies in developing and exporting countries.

As regards the date of minimum durability, "use by" date and date of freezing the addendum “Annex X” of Regulation (EC) No 1169/2011 specifies as follows:

The date of minimum durability shall be indicated as follows:

(a) the date shall be preceded by the words:

- "Best before …" when the date includes an indication of the day,- "Best before end …" in other cases,

(b) the words referred to in point (a) shall be accompanied by:

- either the date itself, or,
- a reference to where the date is given on the labelling,

If need be, these particulars shall be followed by a description of the storage conditions which must be observed if the product is to keep for the specified period;

(c) the date shall consist of the day, the month and possibly, the year, in that order and in encoded form.

However, in the case of foods:

- which will not keep for more than 3 months, an indication of the day and the month shall be sufficient,
- which will keep for more than 3 months but not more than 18 months, an indication of the month and year shall be sufficient,
- which will keep for more than 18 months, an indication of the year shall be sufficient,

This new legislation introduces the obligation for the producers and exporters of fishery productsto have a greater responsibility and greater awareness regarding the nature and quality of their exports to another external market.

In order to avoid any blocking of their products following the first shipments (due to deterioration of the food before the time limits and "use by" datesspecified on the goods) the operators in the sector would be advised to keep well within the limits on sale and consumption established by laboratory tests and recommendations.

This is especially important for fresh fish products where the shelf life can vary according to the species of fish. In general fish with high fat content have a shorter durability than low fat fish. Taking this factor into consideration it is still possible to give a general indication of shelf life for three categories of fresh marine fish products.

- fresh whole fish: 5-7 max days from capture
- fresh fish fillets: 7-9 days
- fresh fish fillets (vacuum packed): 10-12 days.

For vacuum packed products labels must be attached to each package and also to the box containing the packages.

For farmed fish the shelf life is usually 2-3 days longer than the above because of their diet and less traumatic method of capture.

The regulations on nutritional value which will come into force on 13th of December 2016 mean that exporters must not only include a full list of contents and ingredients but also their weight  expressed as a percentage of total weight. This is very complex and will require much preparation by exporters.

The European Commission has produced a new guide for the seafood industry, describing new labeling laws that will take effect this week. Along with describing the new rules, the 11-page "pocket guide" also shows examples of proper labels, both for canned, prepacked and unprocessed products. The guide includes contacts for questions from the industry. The Pocket Guide is available at http://ec.europa.eu/fisheries/documentation/publications/eu-new-fish-and-aquaculture-consumer-labels-pocket-guide_en.pdf

By Ruggero Urbani, 
FAO Consultant, Fish Inspector, Quality Assurance Expert

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