This is a guide to the Australia New Zealand Food Standards Code (the Code) labelling and compositional standards for fish and fish products sold in, or imported into, Australia and New Zealand. Generally, all foods sold by retail must be labelled in full. Information on the full labelling requirements is available in the Queensland Health Label Buster guide.
Chapter 1 of the Code contains the labelling provisions and information that must be provided for foods, and the requirements for how this information must be presented. Standard 2.2.3 imposes additional labelling and information requirements specific to fish and fish products. A reference number with square brackets e.g. [1.3.1] in this guide is a reference to the relevant Standard in the Code.
Definitions
Assisted service display cabinet - an enclosed or semi-enclosed display cabinet which requires a person to serve the food as requested by the purchaser e.g. deli cabinet.
Fish - any of the cold-blooded aquatic vertebrates and aquatic invertebrates including shellfish, but does not include amphibians and reptiles.
Fish products - are not specifically defined in the Code, but in this guide they include whole and processed fish products, as well as mixed food products that contain fish with other foods, such as fish patties.
GMP (Good Manufacturing Practice) - using the lowest level possible of an additive to achieve a technological function (e.g. preservation) which will leave the least residue in the final food.
Name of fish - the name sufficient to describe the true nature of the fish. The Australian Fish Names List prescribes standard fish names for use in Australia and specifies when these fish names should be used. This list can be accessed at
Package - any container or wrapper in or by which food intended for sale is wholly or partly encased, covered, enclosed, contained or packaged.
Labelling - food for retail sale
Generally, all foods sold by retail must be labelled in full. Information on the full labelling requirements is available in the Label Buster guide.
However, exemptions apply to some food, including food that is:
unpackaged
in an inner package not designed for individual sale (excluding individual portion packs with a wrapper that has a surface area of 30cm2 or more, which must contain allergen declarations)
made and packaged on the premises from which it is sold
packaged in the presence of the purchaser (including sale from an assisted service display cabinet) delivered packaged and ready for consumption at the express order of the purchaser
sold at a fundraising event e.g. a seafood raffle.
All food for retail sale that fit into any of the specified exemption categories must still provide certain information on or in connection with the display of the food, or provided upon request by the purchaser, (refer to the Label Buster guide). [1.2.1]
Examples of some of the information requirements for fish and fish products are provided in table 1.
Table 1Additional labelling requirements for fish and fish products
Requirement / ExampleAllergens – a specifically worded advisory statement, warning statement or declaration is required. [1.2.3] / Presence of peanuts, cereals, unpasteurised egg products, added sulphites in concentrations of 10mg/kg or more.
A nutrition claim - nutrition information panel. [1.2.8] / Claims such as ‘gluten free’ or ‘low fat’.
Irradiated food - a statement to the effect that the irradiated food has been treated with ionising radiation. [1.5.3] / Herbs that have been irradiated which are added as an ingredient to a fish product.
Value-added fish products- percentage of fish in the product. / Crumbed fish and fish cakes
Raw fish has been formed or joined to look like a cut or fillet of fish using a binding system without the application of heat, whether coated or not–
a declaration that the fish is either formed or joined, and
cooking instructions on the label on the package which indicate how the microbiological safety of the product can be achieved.
Thorough cooking to 60° C or above is recommended. [2.2.3] / Seafood stick
Unpackaged fish and fish products– country of origin (see section below). / Fish fillets displayed in an assisted service display cabinet.
Unpackaged fish and fish products
Country/ countries of origin
Country of origin labelling is required for all unpackaged fish for retail sale and includes fish that has been mixed or coated with one or more other foods and it applies to fish that has been:
(a)cut, filleted, sliced, minced or diced; or
(b)pickled, cured, dried, smoked, frozen or preserved by other means; or
(c)marinated; or
(d)cooked.
The information that must be provided for unpackaged fish and fish products is different than for packaged food. Unpackaged fish and fish products must be labelled with a statement on or in connection with the display of the food which:
(a)identifies the country or countries of origin of the food; or
(b)indicates that the food is a mix of local and imported foods; or
(c)indicates that the food is a mix of imported foods.
Print sizes
Where country of origin labelling for unpackaged fish or fish products is on a label in connection with the display of the food, the height of the writing on the label must be at least 9mm in height, unless the food is in a refrigerated assisted service display cabinet, in which case it must be at least 5mm in height.
Labelling - fish for wholesale
Wholesale fish and fish products must bear a label or have associated documentation which provides a name indicating the true nature of the fish or a description of the food, lot identification, name and address in Australia or New Zealand of the supplier and country/countries of origin.
You will also need to supply, on demand by the retailer or regulatory authority, sufficient information about your product to enable them to comply with labelling and composition requirements for their product, including the country/countries of origin and information about ingredients, additives, use of genetically modified ingredients and potential allergens, e.g. sodium metabisulphite (META).
Example:
A wholesaler sells crumbed fish to a retailer who then packs and labels the product for sale to a consumer. If the retailer asks the wholesaler to provide all the information they will need to adequately label the crumbed fish for retail sale, the wholesaler is legally required to provide this information. This may include a request for information about any potential allergens such as wheat, date marking, nutrition information, percentage labelling and ingredients.
Composition of fish and fish products
The Code includes provisions for what foods and additives may be present in different fish and fish products, and any associated labelling declarations in relation to these foods.
Food additives [1.3.1]
Food additives must not be added to food, unless expressly permitted in Standard 1.3.1 of the Code.
The additives and maximum permitted level of additives in different fish and fish products are identified in tables 2 and 3 below. References to schedules refer to the relevant schedules for Standard 1.3.1 of the Code.
Unprocessed fish and fish fillets
Additives in unprocessed fish and fish fillets (including frozen and thawed) are not permitted unless specified in Schedule 1 of Standard 1.3.1. Permitted additives for specified foods are listed in table 2.
Table 2Permitted additives and maximum permitted levels (MPLs) for unprocessed fish and fish products
Food type/ generic food category / Additive Name / AdditiveINS no. / MPL (mg/kg)
Uncooked crustacea / Sulphur dioxide and sodium and potassium sulphites / 220-225, 228 / 100
Ascorbic acid and sodium, calcium and potassium ascorbates / 300-303 / GMP
Erythorbic acid and sodium erythorbate / 315-316 / GMP
Citric acid and sodium, potassium, calcium and ammonium citrates / 330-333, 380 / GMP
Sodium carbonates / 500 / GMP
Magnesium carbonates / 504 / GMP
4-hexylresorcinol / 586 / GMP
Frozen fish (including peeled prawns) / Ascorbic acid and sodium, calcium and potassium ascorbates / 300-303 / 400
Erythorbic acid and sodium erythorbate / 315-316 / 400
Sodium, potassium and calcium phosphates / 339-341 / GMP
Pyrophosphates, Triphosphates, Polyphosphates / 450-452 / GMP
Processed and preserved fish and fish products
Additives from schedules 2, 3 and 4 are permitted in:
processed fish and fish products
semi preserved fish and fish products
fully preserved fish including canned fish products.
Other additives permitted for specified foods are expressly stated in Schedule 1 of Standard 1.3.1. Permitted additives for specified foods are listed in table 3.
Table 3Permitted additives and MPLs for processed and preserved fish and fish products
Food type/ generic food category / Additive Name / AdditiveINS no. / MPL (mg/kg)
Processed fish and fish products
Cooked crustacea / Sulphur dioxide and sodium and potassium sulphites / 220-225, 228 / 30
Roe / Amaranth / 123 / 300
Semi-preserved fish and fish products
Annatto extracts / 160b / 10
Sorbic acid and sodium, potassium and calcium sorbates / 200-203 / 2,500
Benzoic acid and sodium and calcium benzoates / 210-213 / 2,500
Fully-preserved fish including canned fish products
Sulphur dioxide and sodium and potassium sulphites / 220-225, 228 / 30
Calcium disodium EDTA / 385 / 250
Canned abalone (paua) / Sulphur dioxide and sodium and potassium sulphites / 220-225, 228 / 1,000
Roe / Amaranth / 123 / 300
Maximum Residue Limits and maximum levels of contaminants and natural toxicants
Maximum limits for chemicals and toxicants are safe legal limits of natural and man-made contaminants that are tolerated in specified foods.
Natural toxicants [1.4.1]
Chemical and natural toxin uptake occurs during the normal life cycle of fish. Maximum limits for chemicals and toxicants such as arsenic, mercury and lead are the safe legal limits of natural and man-made contaminants tolerated in fish and fish products. These limits are determined based on where the fish was harvested and its feeding habits.
Maximum level of histamine permitted in fish or fish products [2.2.3]
Histamine is a naturally produced toxin, which can cause food poisoning. It is an indicator of decomposition and increased levels of histamine may be linked to inappropriate standards of hygiene and handling.
The level of histamine in fish or fish products must not exceed the following levels for the species of the families Clupeidae, Scrombridae, Scrombresocidae Coryphaenidae, and Pomatomidae:
(a)decomposition - 10mg/100g of histamine.
(b)hygiene and handling - 20mg/100g.
Further information on histamine poisoning, other types of shellfish poisoning and ciguatera poisoning can be found in the fact sheet Naturally occurring seafood toxins located at
Maximum Residue Limits [1.4.2]
Maximum Residue Limits (MRLs) are the highest legal limits for agricultural and veterinary chemical residues in particular foods (including fish and fish products) [1.4.2]. They are set to protect the health and safety of consumers. If there is no maximum level specified in the Code for an agricultural or veterinary chemical in a food, the chemical is not permitted to be present in the food.
Legal microbiological limits [1.6.1]
Legal microbiological limits are set to ensure that all fish and fish products are safe to eat. Correct handling of fish and fish products is essential to ensure microbiological safety. The Code sets legal limits that apply for micro-organisms such as Listeria monocytogenes, Salmonella, Coagulase-positive staphylococci and Escherichia coli (E Coli).
Carry-over of additives
If an ingredient contains an additive, the additive could be present in a final product. For example, if cooked crustacea that is intended for use in the manufacture of a seafood broth contains 25mg/kg of sulphur dioxide, it is likely all or most of this will be present in the final product. Therefore, the manufacturer must consider this before adding additional preservatives, to ensure the maximum permitted level of sulphur dioxide (30mg/kg) is not exceeded (refer to table 3).
When using an additive in food, GMP must be used, which means using the lowest level possible of an additive to achieve its function (e.g. preservation) which will leave the least residue in the final food.
For further information
This document is a brief guide to help you understand the requirements of the Code. You will find more detailed information in the Code and the user guides and fact sheets from the Food Standards Australia New Zealand website at
Queensland Health have a variety of fact sheets with detailed information on food safety. These fact sheets can be accessed at
If you have any further questions relating to labelling and composition of fish and fish products, contact the Public Health Unit for the area where you are located. Contact details for Public Health Units can be found at
Fish and fish products – August 2015 / - 1 -