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Allergen labelling of wild caught seafood products?

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Posted 09 January 2020 - 01:14 PM

Hi Everyone


Does anyone have any experience of allergen labelling of wild caught seafood products? From experience businesses would not place a statement on pack (or with the mandatory labelling particulars) that a wild caught fish may contain traces crustaceans or molluscs (based on EU legislation) yet in reality of the risk or bycatch is never fully eliminated with most catch methods. And although there are inspections carried out on the vessel/trawlers, at landing and during processing there is always a risk that a small piece (e.g. baby crab in clams catch) will make it through to the finished product packaging.


Therefore my question is - is alibi / may contain warnings necessary on wild caught seafood products and if so, why is it not actively done at present? Perhaps this is a topic that the industry is conveniently not addressing..


Any thoughts would be welcomed!


Note - the above is based on my knowledge and experience of the seafood industry in the UK and wider EU markets. I'm not sure if other countries and/or jurisdictions manage this differently or have this a requirement entirely.





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Posted 09 January 2020 - 02:38 PM

I'm not sufficiently familiar with that part of the food industry to comment with any authority, but it's an interesting question!
I did note that Seafish, the UK promotion/industry body, state that "only allergenic ingredients added deliberately need to be declared" and "potential contaminants do not need to be declared" in this guidance: https://www.seafish....rvice140603.pdf

To an extent I agree with their position in the specific sense it's intended in terms of compliance with 1169/2011, but there is the potential broader issue of Article 14 of Regulation 178/2002 - particularly in terms of 3(a) and 3(b) with regard to "normal conditions", "other information generally available to the consumer" etc.


Are you part of an industry association in this area? It's the sort of thing on which I could imagine there being private guidance for members rather than shared publicly on the website.

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Posted 19 January 2020 - 11:31 PM

I am in the US but have worked for several companies that export fish to the EU. We have always declared “fish” and the species of fish but have never been asked to address potential cross-contact with crustaceans that may have been in the net with the fish- or consumed by the fish.
During Storage after the catch has been segregated and throughput processing the fish and crustaceans are kept segregated.


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Posted 21 January 2020 - 08:28 AM

Interesting question. Some things I've come across that may be of help:


6.0 What are allergens and when should they be declared? Certain ingredients added to a food intentionally must be declared on the label. There is no legal requirement to list allergens that may have accidentally contaminated the product. However, if you choose to state that a food is ‘free from’ certain ingredients, such as nuts, you must take reasonable steps to ensure that the product and its ingredients have not been contaminated with the named ingredient. (p5) (note 2011)



The question could equally be turned around - Do crustaceans caught in the sea require a fish allergy warning? The below document on handling & storing crustaceans is substantial but I can't see anything mentioning fish contamination in terms of allergy, from a scan & search through it. A section on "undesirable contamination of live crustacea" p81/82 addresses only physical and chemical contaminants.


Also from the document:

Annexe 1, Part A II : Hygiene provisions 2. As far as possible, food business operators are to ensure that primary products are protected against contamination, having regard to any processing that primary products will subsequently undergo.

Annexe 1, Part A II (4f) as far as possible to prevent animals and pests from causing contamination;


I imagine that, because it is not possible to declare wild sea fish free from crustacean contamination due to the nature of the environment, there is no requirement regarding it. That said, personally I expect in future all wild sea fish products may need to carry a "may contain crustacean" label; if there is indeed a loophole at the moment I doubt it will be long before someone takes advantage and tries to prosecute a supplier following a "reaction", real or otherwise.

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