Fish Traceability Requirements

Seafood is subject to traceability laws. Here is an outline of the regulations and requirements for seafood businesses. This is for basic understanding and not a basis for implementation.

Food law

General principles and requirements of food law

Regulation 178/2002 contains general traceability rules and is in place to protect both consumers and traders. Foods must be traceable through all stages of production, processing and distribution. 

Food businesses must keep records of businesses that supply them with food and businesses they supply food to. Every item of food must have an identifiable supplier and customer. This information must be made available to enforcement officers if required.

Businesses must also keep records on the quantity of food, a reference identifying the lot or batch and description of food. 

Hygiene for products of animal origin

Regulation 854/2004 means 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.

Frozen food of animal origin 

Regulation 16/2012 means food businesses must provide the date of food production and date of freezing to the business they have supplied the food to. 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 including:

  • 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 only applies to CN03 (fresh) products. It does not apply to third country products imported under IUU, CN16 (processed products) and freshwater products.

The following must also be made available to the consumer:

  • Commercial designation
  • Species scientific name
  • Catches area
  • Production method and whether the product has been previously frozen 

Fish marketing

Regulations 2065/2001 contains rules on what information must be provided to the consumer. Businesses must provide consumers with information on commercial designation, catch area and production method throughout the supply chain for CN03 (unprocessed). These requirements currently fall within the review of the Common Fisheries Policy and are under discussion.

These are put into practice in the UK under The Fish Labelling Regulations 2010, which contain fish traceability requirements. Please note that there may be further more specific and detailed requirements that apply to your seafood business.

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