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Guide to Food Labelling and Advertising > Chapter 15
Chapter 15 - Fish and Fish Products
The term "fish" means any marine animal, including fish,
shellfish, crustaceans and also other marine animals such as marine mammals.
The labelling requirements presented in this Chapter apply to all of those
animals and any parts, products or by-products thereof.
In addition to the Food and Drugs Act / Food and Drug
Regulations (FDA/FDR) and the Consumer Packaging and Labelling
Act and Regulations (CPLA/CPLR),
labelling of domestic (processed in federally registered establishments) and
imported fish and fish products is regulated by the Fish Inspection
Act (FIA) and
the Fish Inspection Regulations (FIR). Fish labelling policies
can also be found in the following reference documents:
-
Quality Management
Program Inspection Policies, Chapter 3, Facilities Inspection Manual,
at
http://www.inspection.gc.ca/english/anima/fispoi/manman/fimmii/toctdme.shtml
-
Imported Fish and Fish
Products Inspection Policies, Chapter 3, Fish Products Inspection
Manual, at
http://www.inspection.gc.ca/english/anima/fispoi/manman/fpimip/toctdme.shtml
-
Fish Products Standards
and Methods Manual, at
http://www.inspection.gc.ca/english/anima/fispoi/manman/samnem/toctdme.shtml
-
Fish Products
Inspection Manual, at
http://www.inspection.gc.ca/english/anima/fispoi/manman/fimmii/toctdme.shtml
-
Canadian Shellfish
Sanitation Program, at
http://www.inspection.gc.ca/english/anima/fispoi/manman/cssppccsm/toctdme.shtml
-
Guide to Permitted
Additives in Fish and Fish Products, at
http://www.inspection.gc.ca/english/anima/fispoi/product/additi/guidee.shtml
-
The Canadian Fish
List, at
http://www.inspection.gc.ca/english/anima/fispoi/fishlist/canadahomee.shtml
-
Questions and
Answers, at
http://www.inspection.gc.ca/english/anima/fispoi/product/questions/indexe.shtml
15.2 Common Name [25(1), 25(2)(b), 26(1), 27,
FIR]
| (i) |
Additionally names prescribed by the FDR, the name of a fish/fish
product is:
- the name prescribed by the FIR: lobster cocktail (38,
FIR), tomalley
(39, FIR),
lobster paste (40, FIR), shrimp cocktail (72,
FIR), fish
sticks (51, FIR), fish and chips (52,
FIR),
or
- the name prescribed for the species in CFIA's "The
Canadian Fish List",
or
- the name set down in the applicable product standard in the Fish
Products Standards and Methods Manual,
or
- if not otherwise prescribed, the name by which the fish product is commonly
known, e.g. fish cakes, seafood salad, caviar, solomon gundy.
When a prescribed common name is used, the product must comply with the
compositional standard established for that product by the FDR, FIR or other applicable
standards.
|
| (ii) |
All of the words in the common name of a fish/fish product must
be indicated in letters not less than 3.2 mm (1/8 inch) in height on the principal display
panel of the package. |
| (iii) |
The common name on canned fish must be shown in
letters of equal height and prominence and indicate whether the product has
been prepared
- by mincing, flaking or other special process;
- from selected parts of fish;
- for dietetic use.
|
| (iv) |
The geographic location where the fish has been harvested may be
added to the common name, however this is optional. |
| (v) |
Common (marketing) names for species new to the Canadian market
will be assigned according to the procedures outlined in Bulletin 26 in the
Fish Products Inspection Manual. |
15.3 Net Quantity [25(1)(b), and (c),
26(1)(b), FIR]
| (i) |
The net quantity declaration on prepackaged fish is mandatory
unless the container or label states that the contents are to be weighed at the
time of retail sale (catch weight). |
| (ii) |
The net quantity declaration on consumer packages (canned, and
other than canned containing 900 g or less of fish)
must appear in letters not less than 3.2 mm in height. |
| Note: Where the area of the principal display panel
is greater than 258 square centimetres, the minimum type height of numerals in
the net quantity must comply with the height prescribed in Section 14 of
CPLR. |
| (iii) |
The following specified fish products must indicate the net
content as follows:
- oysters in the shell, expressed either by weight OR in
bushels OR in pecks OR by count;
- canned fish packed in water, expressed as the drained weight;
- canned shellfish and crustaceans, expressed as the drained weight;
- oyster and clam meats that are not frozen, expressed by the weight
OR in fluid measures OR by count;
- fish frozen with glaze, excluding the weight of the glaze;
- fish packed in brine or vinegar solution (e.g. lobster meat, marinated
fish), expressed as the drained weight.
|
| (iv) |
The words "net weight" or "drained weight"
can be used only on fish products that contain only edible parts. If the
product also contains inedible parts such as shells, the word
"weight" alone must be used. |
| (v) |
Weight declarations such as "made from X lb" (e.g. for peeled shrimp) or "net weight when
packed" (e.g. live mussels) are unacceptable. |
| (vi) |
Declaration of an approximate portion size on
institutional packages is considered non-mandatory
information, and e.g. the statement "about 60 g/portion" is acceptable. |
| (vii) |
The net weight on shipping containers (master cartons) or on
institutional packages can be expressed either in metric or Imperial
units. |
| (i) |
The FIR require that grade, size,
class, count or moisture content must be shown on the principal display panel
for certain fish products as follows:
- in the case of pickled fish, with the grade, class and size of the
fish;
- in the case of boneless or semi-boneless salted fish, with the grade of the
fish;
- in the case of bloaters, with the grade and count of the fish;
- in the case of bloater fillets, with the grade of the fish;
- in the case of frozen Atlantic smelts, with the size of the fish;
- in the case of salted fish, other than boneless or semi-boneless salted
fish, with the grade and class of the fish, the size or count of the fish and
the designation for moisture content;
- in the case of Atlantic oysters in the shell, with the shape designation;
and
- in the case of dried squid, with the grade designation.
|
| (ii) |
On containers of 900 g or less, the
grade, size, class, count and moisture content, where applicable must be shown
on the principal display panel, in minimum type height of
3.2 mm. |
| (i) |
A quality designation can be used only when a standard for that
quality has been prescribed in the FIR, and the product meets
that standard, e.g. "Fancy Shape" designation on Atlantic oysters is
permitted when the oysters meet the requirements indicated in Section
65(a) of FIR. |
| (ii) |
Quality claims, where it is clear that the processor or importer
or distributor is declaring responsibility for the quality, are permitted, e.g.
"All Company X products meet our highest standards. If you have any
questions or comments please write to us at: Company X, 123 Main St., Town, Province, Postal Code" would be an acceptable
statement. |
| (iii) |
General statements such as "Quality products from XX",
"Satisfaction guaranteed", "Guaranteed quality", etc. are also acceptable. |
The name of the country of origin must be clearly identified on the label of
any fish or fish product imported into Canada. The wording "Product of
/Produit de, d', des, du " must be used to
clearly identify the name of the country of origin. For domestic products, the
declaration "Product of Canada/Produit du
Canada" is not required, however it can be shown on the label, as
appropriate.
| (i) |
All fish establishments registered under the FIR are entitled to use the
"Canada Inspected" logo on fish products processed as part of the
establishment's Quality Management Program (QMP). |
| (ii) |
Only fish products that are considered "Product of
Canada" can bear the logo. |
| (iii) |
There are no restrictions as to the size or the colour of the
logo, however the logo must be separate and distinct, and must not interfere
with any mandatory labelling requirements. Permitted examples of
""Canada Inspected" logo are shown in Bulletin 41 of the
Fish Products Inspection Manual. |
| (iv) |
The registration number of the establishment may be included in
the logo. |
15.8 Molluscan Shellfish [26(1)(f), FIR; Canadian
Shellfish Sanitation Program Manual; Bulletin 36, Fish Products
inspection Manual (provincial legislation)]
15.8.1. Label Information on Live Molluscan Shellfish
| (i) |
In addition to the mandatory information that must be present on all food
labels, the FIR requires that the label for bivalve molluscs in the
shell must be correctly and legibly marked to show the date of
processing and the location from which the bivalve molluscs were harvested.
The label must also indicate either a "best
before" date, OR the date the molluscs were harvested.
This date must be expressed on the label in the manner required in
B.01.007(4)(d) and (5), (eg. 97 JA 15 for January
15th 1997). The full year can be written out for clarity, e.g.
2003 JA 05. The statement "keep refrigerated" and the
certification number of the registered establishment where the shellfish were
processed must be also present on the label.
|
|
|
| (ii) |
When live molluscs were wet-stored or relayed for more than 14 days, the
harvesting date is the date when the molluscs were removed from the wet storage
or relay site. |
|
|
| (iii) |
When live molluscs were depurated, it must be indicated on the label. |
15.8.2 Label information on Raw Shucked Molluscan Shellfish
| (i) |
In addition to the mandatory information that must be present on all food
labels, the label on shucked molluscan shellfish sold fresh
must indicate the registered establishment’s certification number, the
processing date*, the "best before" date and the
statement "Keep refrigerated". The "best before" date must
be expressed on the label in the manner required in B.01.007(4)(d) and (5), FDR
(eg. 97 JA 15 for January 15th 1997). The full year can be
written out for clarity, e.g. 2003 JA 05. Where shucked meats were
processed from depurated molluscan shellfish, it must be indicated on the
label. |
|
|
| (ii) |
In addition to the mandatory information that must be present on all food
labels, the label on shucked molluscan shellfish sold frozen
must indicate the registered establishment’s certification number, the
processing date*, and the word "frozen" which must be immediately
adjacent to the common name of the shellfish, and it must be in the letter type
of equal prominence to the common name. Where shucked meats were processed from
depurated molluscan shellfish, it must be indicated on the label. |
* For packages with a capacity of 64 fluid ounces or more the label must
show "date shucked" instead of the processing day. "Date
shucked" must be present on the lid and also on the side wall or on the
bottom of the container.
Other mandatory labelling information as per appropriate regulations and
standards are required on fish/fish products as follows:
| (i) |
Fish packed to exclude air and which have been smoked or to
which liquid smoke or liquid smoke flavour concentrate has been added and
which:
- contains less than nine per cent of salt; or
- has not been heat processed after sealing at a temperature and for a time
sufficient to destroy all spores of the species Clostridium
botulinum; or
- is not customarily cooked prior to use
require the statement "Keep frozen prior to use"/
"Garder congelé jusqu' à
utilisation" on the principal display panel in letter size
equal to the letters used in the common name [B.21.025].
|
| Note: Smoked fish packed with oxygen permeable
screens (2,000 cc/ m2/24 h at
240C and 1 atm) needs no
freezing and can be stored under refrigeration conditions. The statement
"keep frozen prior to use" is not required, however the statement
"Keep refrigerated" must be present, and the shelf life indicated on
the label cannot exceed 14 days. The information on oxygen
permeability of the packaging material must be available to an inspector up to
retail level. |
| (ii) |
Descriptive terms are required on some prepacked fish products:
- In the case of canned fish, descriptive terms must be printed in the
letters not less than one-half of the letters used for the common name [25(3),
FIR].
- In the case of fish, other than canned fish, descriptive terms are required
if their absence would make the label false, misleading or deceptive [27,
FIR].
For instance, uniform rectangular portions of breaded minced fish require
"made from minced fish"/ "fait de poisson
haché"; in close proximity to the common name, and in letters
not less than one-half of the letters used for the common name [51(4), FIR].
|
| (iii) |
Fish products that have received some heat treatment but are
not ready-to eat products (e.g. frozen blanched crab legs,
frozen "browned" breaded fish portions), and which may be perceived
as such by consumers, must be labelled as follows [Bulletin 37, FPIM]:
- the information that the product is not ready-to eat must be indicated in
the common name or in descriptive terms, e.g. "Blanched crab
legs";
- the label must bear cooking instructions and the statement that the product
must be cooked before serving;
- if the product is frozen, the cooking instruction must indicate a proper
heat treatment from the frozen stage;
- an indication of proper storage conditions and the durable life (if
applicable) must be present on the label.
|
| (iv) |
The labels of all cans of tuna must indicate the colour of the
fish flesh (49, FIR):
- "white meat tuna" or "white tuna" (only tuna of the
species Thunnus alalunga or Thunnus germo),
- "light meat tuna" or "light tuna";
- "dark meat tuna" or "dark tuna".
|
| (v) |
Each container of whitefish must be marked in English
or French with the name of the lake of origin of the
whitefish, including the name of the province, and the words "dressed
whitefish" or "round whitefish" or "whitefish
fillets", as the case may be. |
| (i) |
Code markings are required on cartons and cases in which
containers of domestically processed or imported fish are packed. These
markings must identify the name of the establishment and indicate the day,
month and year of processing. |
| (ii) |
Code markings are required on every container of pickled, spiced
or marinated fish and must identify the name of the establishment and indicate
the day, month and year of processing. |
| (iii) |
Every hermetically sealed container of fish that has been
sterilized, must be embossed or otherwise permanently marked to identify the
name of the establishment; indicate the day, month and year of processing; and
for some products identify the product. |
| (iv) |
The meaning of code markings must be available to an
inspector. |
Amendments to the Food and Drug Regulations will make nutrition
labelling mandatory for most prepackaged products by December 12, 2005. Small
companies with revenues from the sale of food of less than $1 million in Canada
for the 12 months prior to December 12, 2002 have a five year transition
period. These regulations affect processed products. More details on the
requirements for nutrition labelling can be found in
Chapters 5 and 6 of this Guide.
Note that prepackaged raw, single ingredient marine or fresh water animal
products are exempted from showing a Nutrition Facts table on the label under
B.01.401(2)(iv). However, the exemption may be lost under certain conditions,
including when a nutrient content claim is made on the product. See 5.3 of this Guide for further
information.
Nutrient content claims and diet-related health claims can be made on some
fish products. For more information on the conditions for making these claims,
refer to Chapters 7 and 8 of
this Guide respectively.
| (i) |
Labels of shipping containers (master cartons) for fish and fish
products containing labelled retail packages, require:
- common name of the fish;
- name of the manufacturer;
- day, month and year of processing; and
- the harvest location for bivalve molluscs in the shell.
|
| (ii) |
All mandatory information normally applied on consumer packages
is required on shipping containers with bulk fish, or containing fish packages
with no labels (for institutional use). |
| (iii) |
The label information can be in either English
or French, and net quantity expressed in either metric
or Imperial units. |
| (iv) |
Protective wrappings are normally associated with bulk
packaging, or with products that cannot be transported without adversely
affecting its quality e.g. blocks of shrimp. Where fish are held within a
protective wrapping, inside a properly labelled shipping container, then these
protective wrappings are not considered to be inner packages and do not require
labelling. |
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