Hampshire Trading Standards

Fish Labelling & Traceability

This advice is designed to provide basic guidance to traders. It is not a complete or authoritative statement of the law. A large print version is available.

EC Regulations which came into force on 01 January 2002 introduced two new requirements:

  • The provision of specific consumer information at the point of retail sale to the final consumer, whether sold loose or prepacked. (This should be on a label, ticket or notice directly in association with the product).

  • The maintenance of a traceability trail of required information throughout all stages of the distribution and wholesale chain. (This information may be on a label on the packaging or on associated trade documentation).

Are there any situations where the Regulations do not apply?

Fish and fish products sold by catering establishments are not caught by the new labelling requirements. This will include restaurants, canteens, takeaways, etc. where the product is ready for consumption without further preparation.

Also the Regulations do not apply to sales of small quantities of fish sold directly to the final consumer by either fisherman (e.g. from the quayside) or aquaculture producers (e.g. from lakes, ponds, etc.) For the purposes of this Regulation, the term "small quantity" is taken to mean sales not exceeding 20 € (generally £14 -£15)

What products are caught by the Regulations?

  • live fish;

  • fresh, chilled and frozen fish;

  • fish fillets and other fish meat (whether minced or not);

  • dried, salted or brined fish;

  • smoked fish (whether hot or cold smoked fish (but not if dyed));

  • crustaceans (except crustaceans which are both cooked and peeled ; and,

  • molluscs (except cooked molluscs).

The Regulations apply to all uncooked fish to which no other ingredients have been added even if it has been subject to physical processes such as slicing, cutting, flaking, etc. Examples include: frozen fish or shellfish blocks not treated in any way; fish steaks (e.g. tuna steak, salmon steak); fish steaks from re-formed fish; minced fish meat; slices of fish (e.g. smoked salmon slices); fish that has been flaked, cubed/diced (e.g. salmon flakes sold as such to the final consumer to add to recipe dishes, sandwiches, etc.).

They do not apply to fish to which other ingredients have been added such that the fish becomes an intrinsic part of the end-product (i.e. coated/battered/breaded fish products, recipe dishes/fish ready meals) or to fish that has been further processed, preserved, treated or cooked.

What labelling information has to be provided for the consumer?

Three pieces of information are required.

  • The Commercial Designation

  • The Production Method

  • The Catch Area

 

What is the Commercial Designation?

These are the names prescribed by law (as stated in Regulations 6(1) of the Food Labelling Regulations), which means that they are also the commercial names of fish in compound fish products. The English Language list of agreed commercial designations for use in the UK is contained in the Schedule to the 2003 Regulations. The list comprises the scientific (Latin) species name and the designated common name. The latter is the name which must be used at retail sale and may only be used for the designated species.

The designated common name may be qualified with supplementary information provided this is accurate and does not mislead as to the species concerned. e.g. deepwater prawn (Pandalus borealis); red snapper (Lutjanus campechanus). The scientific name is an optional addition at retail sale.

Are there any circumstances where the specified commercial designations would not have to be used?

Yes. In the case of smoked fish, with the exception of salmon, the fish may be called by a customary name that is not necessarily the assigned commercial designation. e.g. a 'kipper'.

 

What is the production method?

The production method relates to the manner in which the fish is 'harvested', that is whether it is caught at sea or in freshwater, or produced by aquaculture.

How should the production method be indicated?

The production method should be given in one of the following ways:

a) for products caught at sea or in freshwater: the terms "caught" or "caught in freshwater"

b) for products of aquaculture: the terms "farmed" or "cultivated" must be used to indicate that the fishery and aquaculture products have been farmed.

It is recommended that the term 'farmed' is used for fish (e.g. farmed cod) which are fed, whilst the term 'cultivated' is used for shellfish production (e.g. cultivated oysters) where beds are seeded but not fed.

Are there any circumstances where the production method need not be indicated?

Yes. For fish caught at sea, the terms "caught" or "caught in" do not have to be used if it is obvious from the commercial designation or the catch area that species have been caught at sea. However, if there is any doubt about the production method, then omitting the terms "caught" or "caught in" is not permitted.

 

What information is required for the catch area?

The catch area must be indicated as follows:

(a) for products caught at sea,
the origin must be indicated by reference to one (or more, if appropriate) of 12 catch areas based on FAO statistical classifications.
For example, the catch area, "North-East Atlantic", would need to be indicated on the label for any fish/shellfish caught in the UK (e.g. North Sea, Irish Sea), Norway, Iceland, Denmark (West Coast) but fish caught on the East Coast of Denmark or around the Danish Islands would be the "Baltic Sea". Fish caught in New Zealand waters would need to make reference to the "Pacific Ocean". Similarly, salmon caught in Alaska, would need to make reference somewhere on the label to the catch area, "Pacific Ocean" or "Pacific".

(b) for products caught in freshwater,
the origin must give a reference to the Member State (i.e. EC Country) or third country of origin.
For example, trout caught in freshwaters of Spain or Norway, reference would need to be made to Spain or Norway respectively. Product labelling may, for example, state "Norwegian trout" or "trout caught in the freshwaters of Norway", etc.

(c) for farmed and cultivated products,
the origin must indicate the Member State or third country in which the product underwent final development.
For example, if a fish started its life farmed in France and Denmark but was "finally farmed" in Iceland, the labelling is required to state "Farmed Icelandic fish". However, consistency with separate advice on country of origin labelling would suggest that all countries be indicated on the labelling to give consumers accurate and meaningful information on the true place(s) of origin of the fish. So in the above example, it is recommended that the product be labelled as "Farmed Icelandic fish reared in France and Denmark".

Can a more precise catch area be given?

A more precise geographic origin in terms of the catch or production area may be given but only in addition to the mandatory requirements above.

 

How do the new rules apply to products containing a mixture of fish either by species and/or source locations and/or methods of production?

Essentially all the information relating to the mixture must be included. For example, "a mix of farmed Scottish cod and cod caught in the N.E. Atlantic", in the order in which origin predominates".

Are there any special rules about the presentation of retail labelling information?

There are no specific requirements however it is recommended that the information is presented in a way that is easy to understand, clearly legible, indelible and given in a conspicuous place so as to be easily visible in accordance with general requirements of the Food Labelling Regulations 1996. It is not necessary for the information to be together provided it all is easily and clearly related to the products concerned.

What are the traceability requirements?

Information on the commercial designation, production method, and catch area, including the scientific name of the species, must be available at each stage of marketing of the species. Retailers should receive this information in writing from their supplier either on a label on the packaging or on the accompanying commercial documentation. This information must be passed on in writing to any catering or manufacturing customers.

Where can I get more information?

Detailed Guidance notes including maps of the sea areas and extracts from the EC Regulations are available from the Food standards Agency and can be viewed in their website at

A full list of Legal names, and an excel spreadsheet for searching fish names, can be found on the Food Standards Agency website at:

 

 

Download

Fish Labelling & Traceability leaflet PDF 47kb

Reviewed November 2010

B/Foo/149/003 August 2010