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."
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