Fish traceability requirements

Seafood is subject to legislation which places traceability requirements on seafood businesses.

In the seafood sector traceability is required under different headings for different purposes, imposed under separate regulatory requirements.

The following sections provide a brief outline of the regulations under which traceability currently exists and an outline of the requirements. This is intended to provide a basic understanding only and not a basis for implementation or enforcement as there may be further more specific and detailed requirements that apply.

Food Law

Regulation 178/2002 contains general traceability requirements and is in place to protect both consumers and traders and require that foods are traceable through all stages of production, processing, and distribution. This means that food businesses are required to keep records of businesses who have supplied them with food, and businesses which they supply food to. Every item of food must have an identifiable supplier and customer, and this information must be made available to enforcement officers if required.

A recent amendment requires additional information on the quantity of food, a reference identifying the lot or batch, description of food and date of dispatch. This applied from July 2012.

Regulation 854/2004 Hygiene for Products of Animal Origin - food businesses that require approval must apply a health mark to product. This includes an approval number and country the business is located in.  There are also record keeping requirements.

Regulation 16/2012 Until food is subject to further processing or consumer labelling food business must provide food business to which product is supplied with date of production and if different the date of freezing. There is currently confusion with Commission guidance relating to which date of freezing applies.

Fisheries control

Regulation 01224/2009 provides fisheries control measures with further implementation measures under Regulation 04/2011. These require product information to be available throughout the supply chain. It includes lot number, name of fishing vessel or aquaculture unit, FAO species code, date of catch or period over which caught, quantity, date of supplier, commercial designation, scientific name, catch area and production method. It applies to CN03 (fresh) products only does not apply to third country products imported under IUU, CN16 (processed products) and freshwater products.

Commercial designation, scientific name, catch area, production method and whether the product has previously been frozen must also be made available to the consumer.

Fish marketing

Regulations 2065/2001 provide for consumer information requirements. They currently require the commercial designation, scientific name, catch area and production method to be available throughout the supply chain for CN03 (unprocessed) products and with the exception of the scientific name be provided to the consumer for these products. These requirements currently fall within the review of the Common Fisheries Policy and are still under discussion.

These are enacted in the UK under The Fish Labelling Regulations 2010, which contain fish traceability requirements.

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