Fish and fish products

This page is a guide to the Australia New Zealand Food Standards Code (the Food Standards Code) labelling and compositional standards for fish and fish products sold in, or imported into, Australia and New Zealand.

Chapter 1 of the Food Standards Code contains the labelling provisions and information that must be provided for foods, and the requirements for how this information must be presented.

Standard 2.2.3 includes additional labelling and information requirements specific to fish and fish products.

Definitions

• Assisted service display cabinet - an enclosed or semi-enclosed display cabinet which requires a person to serve the food as requested by the purchaser e.g. deli cabinet.
• Fish - any of the cold-blooded aquatic vertebrates and aquatic invertebrates including shellfish, but does not include amphibians and reptiles.
• Fish products - are not specifically defined in the Code, but in this guide they include whole and processed fish products, as well as mixed food products that contain fish with other foods, such as fish patties.
• GMP (Good Manufacturing Practice) - using the lowest level possible of an additive to achieve a technological function (e.g. preservation) which will leave the least residue in the final food.
• Name of fish - the name sufficient to describe the true nature of the fish. The Australian Fish Names List prescribes standard fish names for use in Australia and specifies when these fish names should be used. This list can be accessed at www.fishnames.com.au.
• Package - any container or wrapper in or by which food intended for sale is wholly or partly encased, covered, enclosed, contained or packaged.

Labelling for retail sale

Generally, all foods sold by retail must be labelled in full. However, some exemptions apply.

Step 1:  Decide if your food needs a label

Take our do I need a label? quiz to check if your food needs a label.

Even if your food does not need a label, there is labelling information that may be required to:

• be displayed with the food (e.g. on display card)
• provided upon request by the purchaser (e.g. verbally or in writing).

Step 2:  Create a food label or a product sheet

Use Label Buster to help you to create to a food label or a product sheet for your fish and fish products.

Examples of some of the specific labelling information required for fish and fish products are:

• allergen declarations (e.g.: contains fish, crustacea)
• percentage labelling of characterising ingredients (e.g. percentage of fish in crumbed fish and fish cakes)
• mandatory warning and advisory statements
  • when producing raw fish that has been formed or joined to look like a cut or fillet of fish (e.g. seafood sticks)
• nutrition information panel where a nutritional claim is made (e.g. ‘low fat’ or ‘gluten free’)
• country of origin labelling for unpackaged fish and fish products (e.g. fish fillets displayed in an assisted service display cabinet).

Where country of origin labelling for unpackaged fish or fish products is on a label in connection with the display of the food, the height of the writing on the label must be at least 9mm in height, unless the food is in a refrigerated assisted service display cabinet, in which case it must be at least 5mm in height.

Labelling for wholesale

Wholesale fish and fish products must bear a label or have associated documentation which provides:

• a name indicating the true nature of the fish or a description of the food
• lot identification
• name and address in Australia or New Zealand of the supplier
• country/countries of origin.

You will also need to supply, on demand by the retailer or regulatory authority, sufficient information about your product to enable them to comply with labelling and composition requirements for their product, including the country/countries of origin and information about ingredients, additives, use of genetically modified ingredients and potential allergens, e.g. sodium metabisulphite (META).

Food additives

Food additives must not be added to food, unless expressly permitted in Food Standards Code under Standard 1.3.1 Food additives.

Table 9 in Schedule 15 – Substances that may be used as food additives lists the food additives and maximum permitted level of food additives allowed in different fish and fish products such as:

• Unprocessed fish and fish fillets (including frozen and thawed)
  • uncooked crustacea
  • frozen fish (including peeled prawns)
• Processed fish and fish products
• Processed fish and fish products
• Semi preserved fish and fish products
• Fully preserved fish including canned fish products.

Carry-over of additives

If an ingredient contains an additive, the additive could be present in a final product. For example, if cooked crustacea that is intended for use in the manufacture of a seafood broth contains 25mg/kg of sulphur dioxide, it is likely all or most of this will be present in the final product. Therefore, the manufacturer must consider this before adding additional preservatives, to ensure the maximum permitted level of sulphur dioxide (30mg/kg) is not exceeded (refer to table 3).

When using an additive in food, GMP must be used, which means using the lowest level possible of an additive to achieve its function (e.g. preservation) which will leave the least residue in the final food.

Natural toxicants

Chemical and natural toxin uptake occurs during the normal life cycle of fish. Maximum limits for chemicals and toxicants such as arsenic, mercury and lead are the safe legal limits of natural and man-made contaminants tolerated in fish and fish products. These limits are determined based on where the fish was harvested and its feeding habits. [Standard 1.4.1].

Maximum level of histamine

Histamine is a naturally produced toxin, which can cause food poisoning. It is an indicator of decomposition and increased levels of histamine may be linked to inappropriate standards of hygiene and handling [Standard 2.2.3].

The level of histamine in fish or fish products must not exceed the following levels for the species of the families Clupeidae, Scrombridae, Scrombresocidae Coryphaenidae, and Pomatomidae:

1. decomposition - 10mg/100g of histamine.
2. hygiene and handling - 20mg/100g.

Read about naturally occurring seafood toxins for more information on histamine poisoning, other types of shellfish poisoning and ciguatera poisoning.

Maximum Residue Limits

Maximum Residue Limits (MRLs) are the highest legal limits for agricultural and veterinary chemical residues in particular foods (including fish and fish products) [Standard 1.4.2].

They are set to protect the health and safety of consumers. If there is no maximum level specified in the Food Standards Code for an agricultural or veterinary chemical in a food, the chemical is not permitted to be present in the food.

Legal microbiological limits

Legal microbiological limits are set to ensure that all fish and fish products are safe to eat. Correct handling of fish and fish products is essential to ensure microbiological safety. The Code sets legal limits that apply for micro-organisms such as Listeria monocytogenes, Salmonella, Coagulase-positive staphylococci and Escherichia coli (E Coli). [Standard 1.6.1].

More information

Online tools

• Not sure if you need a food label?  Take the Do I need a label? quiz to find out.
• Learn how to create a label and a product sheet using the Label Buster tool.
• Country of origin labelling tool.

Read about:

• Labelling requirements in the Label Buster guide.

If you have any further questions regarding the labelling or composition of fish and fish products, contact your local Queensland Health Public Health Unit.