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Guide to Additives Permitted in Fish and Fish Products

Introduction

The purpose of this document is to serve as a guide for CFIA field personnel and to assist in answering inquiries from the fish-processing industry and fish importers concerning the use of additives in fish and fish products. The guide prescribes additives, and maximum levels permitted, in the various categories of fish and fish products sold in Canada. These categories of fish and fish products were developed to relate to the technological processes that are applied to fish/shellfish products.

Note: This document applies only to fish and fish products sold in Canada.

The guide is based on the following Divisions of the Food and Drug Regulations (FDR):

Division 1 Foods, General
Division 16 Food additives
Division 21 Marine and fresh water animal products

Note: The Fish Inspection Regulations include shellfish in the term fish, whereas in general, the Food and Drug Regulations refer to shellfish as "meat".

This material constitutes a guide only. The information summarized in this document was carefully selected and prepared but revisions to the FDR may have occurred after the production of this document. To obtain more information regarding the use of additives, contact:

Mr. John Salminen
Chief, Chemical Health Hazard Assessment
Food Directorate
Health Products and Food Branch
Health Canada

Address: Frederick G. Banting Building, Floor 1
Tunney's Pasture
Ottawa, ON
K1A 0L2

Fax #: (613) 990-1543
Phone #: (613) 957-1700

The additives for use in fish and fish products in Canada must be chosen in accordance with Division 16 of the FDR. The additives are listed in the fifteen tables of Division 16. Each table contains additives used in foods for the same or similar purpose(s).

There are two categories of fish and fish products, namely: standardized fish products (identified in Division 21 by [S], e.g. canned fish, smoked fish), and unstandardized fish products (e.g., seafood salad, fish burgers, salmon spread). Aside from fish, unstandardized fish products may contain various amounts of different ingredients. The additives contained in all ingredients of these products must be listed. If the additive is permitted in at least one ingredient then it can be present in the final product as a carry-over additive.

Example: Sorbic Acid is not permitted to be added to unstandardized fish products such as smoked salmon spread but is permitted in unstandardized salad dressings. Since smoked salmon spread contains both these ingredients, the presence of Sorbic Acid is permitted in the product but only if this additive originated from the dressing and the amount is proportional to the amount of dressing in the spread.

Approval of Non-listed Additives

This document applies only to fish and fish products sold in Canada.

The fact that certain additives are not listed as permitted in some products does not necessarily mean that permission for their use cannot be obtained from Health Canada. An applicant should provide the Bureau of Chemical Safety/ Health Protection Branch with information on the specific function of the requested additive for the particular product. All requests for permission to use new additives, or any changes in the use of additives, should be made in accordance with Division 16, Section B.16.002 of the Food and Drug Regulations.

Product for Export Only

If a product processed in Canada is intended only for export and contains additives not permitted in Canada but permitted in the importing country, the product must comply with Section 37 of the Food and Drugs Act. This section states that the product is in compliance "if the package is marked in distinct overprinting with the word "Export" and a certificate that the package and its contents do not contravene any known requirement of the law of the country to which it is or is about to be consigned has been issued in respect thereof in prescribed form and manner."

• List of Permitted Additives in Fish and Fish Products