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Does we need a "contains statement" for fresh/frozen fish?

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qualityfishgirl11

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Posted 25 September 2018 - 02:09 PM

Hi

 

I have a label question. If we are processing fish- for example- smelt- and want to sell to the US- do we have to label the box with "contains fish". The labels we make always declare the common name of the fish, and the scientific name of the fish. Does there need to be a "contains statement"?

 

Further more- does it need to be a CCP?  

 

thanks

 



Scampi

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Posted 25 September 2018 - 02:27 PM

This should help fishgirl

 

 

https://www.fda.gov/...d/ucm419606.htm

It would appear that this relates mostly to labeling one species as another...

 

Labeling would presumably not be a CCP UNLESS you've had repeated mislabeling occurrences at your facility


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012117

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Posted 26 September 2018 - 01:13 AM

not CCP but perhaps oPRP. If you go with the decision tree, the allergen as hazard are always significant hazard, and when you identify control such as acceptance check and go with decision tree, it may be as oPRP rather than CCP.



Charles.C

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Posted 26 September 2018 - 10:46 AM

Hi

 

I have a label question. If we are processing fish- for example- smelt- and want to sell to the US- do we have to label the box with "contains fish". The labels we make always declare the common name of the fish, and the scientific name of the fish. Does there need to be a "contains statement"?

 

Further more- does it need to be a CCP?  

 

thanks

 

Hi qfg,

 

Re - "contains" - IMEX the customer's advice is usually compelling. Often from bitter experience. Some well-known species variations are of commercial significance as illustrated in Scampi's nice video. (the video omitted to mention that technology is now of considerable value regarding some species distinctions).

 

Re - CCP - Assuming the relevant hazard-to-be-prevented is "allergen" it will presumably depend on whether FDA allow "allergen control" to be handled as a PRP. I anticipate that they will but have not confirmed.

 

If the hazard is "food fraud" afaik seafood/FDA are not (yet) subject to FSMA's meandering requirements so maybe is outside "safety-quality" scope.


Kind Regards,

 

Charles.C


kfromNE

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Posted 26 September 2018 - 02:11 PM

Hi

 

I have a label question. If we are processing fish- for example- smelt- and want to sell to the US- do we have to label the box with "contains fish". The labels we make always declare the common name of the fish, and the scientific name of the fish. Does there need to be a "contains statement"?

 

Further more- does it need to be a CCP?  

 

thanks

 

 

You don't have to have the contains statement however you would need to put in parenthesis (fish) after name the fish.

 

https://www.fda.gov/...n/UCM265446.pdf - pg. 23 and 24



Charles.C

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Posted 26 September 2018 - 02:28 PM

You don't have to have the contains statement however you would need to put in parenthesis (fish) after name the fish.

 

https://www.fda.gov/...n/UCM265446.pdf - pg. 23 and 24

 

Hi Kfromla,

 

Thanks for the above "contains"  link although it would tax Sherlock Holmes to work through the relevant clauses.

 

I guess F8 / F9 also have some interest.


Kind Regards,

 

Charles.C


Fishlady

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Posted 30 September 2018 - 11:10 PM

Yes, a label check for proper allergen declaration (to ensure that the proper species is declared) must be a CCP, according to FDA's Seafood HACCP regulation. 

 

You do not need a "contains" statement, and you do not need to mention "(fish)."  FALCPA (food allergen labeling regulation) says that you must declare the proper species of fish, and that you may optionally declare "(fish)" if the consumer may not realize that the ingredient is a type of fish.

That being said, your customer may require you to put it on the label anyway.





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