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 sets out requirements for how this information must be presented.

Standard 2.2.3 includes additional labelling 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 - a cold-blooded aquatic vertebrates or aquatic invertebrates including shellfish, but not including amphibians or 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, it is exempt from certain labelling requirements where the food is:

• not in a package
• made and packaged on the premises from where it is sold
• packaged in the presence of the purchaser
• delivered packaged and ready for consumption at the express order of the purchaser (e.g. take away fish and chips), except when the food is sold from a vending machine
• displayed in an assisted service display cabinet.

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:

• for a product that consists of raw fish that has been formed or joined in the semblance of a cut or fillet of fish using a binding system without the application of heat, whether coated or not (e.g. seafood sticks), the following information is required:
  • a declaration that the food is either formed or joined
  • in conjunction with that declaration, cooking instructions that would result in microbiological safety of the food being achieved.
• allergen declarations (required for fish, crustacea and mollusc)
• percentage labelling of characterising ingredients (e.g. percentage of fish in crumbed fish and fish cakes)
• nutrition information panel where a nutrition content claim is made (e.g. ‘low fat’ or ‘gluten free’)

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.

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

Compositional requirements

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 forms of fish and fish products:

• Unprocessed fish and fish fillets (including frozen and thawed)
  • uncooked crustacea
  • frozen fish
• Processed fish and fish products
  • Cooked crustacea
  • Roe
• Semi preserved fish and fish products
  • Roe
• Fully preserved fish including canned fish products
• Canned abalone (paua)
• Roe.

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 for uncooked crustacea) is not exceeded.

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.

Contaminants and 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 their feeding habits, Standard 1.4.1. - Contaminants and natural toxicants.

Schedule 19 sets out maximum levels of:

• metal contaminants
• non-metal contaminants
• natural toxicants
• average and maximum levels of mercury in fish.

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 - Fish and fish products.

The level of histamine in fish or fish products must not exceed 200mg/kg.

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.d - Agvet chemicals.

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 under Schedule 20, the chemical is not permitted to be present in the food.

Legal microbiological limits

Legal microbiological limits are set to ensure that food is safe to eat. Correct handling of fish and fish products is essential to ensure microbiological safety. The Food Standards Code sets legal limits under Schedule 27 that apply to molluscs and cooked and uncooked crustacea for micro-organisms such as Listeria monocytogenes, Salmonella, Coagulase-positive staphylococci, Standard Plate Count (SPC) and Escherichia coli (E Coli) Standard 1.6.1 - Microbiological limits in food.

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.

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.