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Ingredient declaration and Reg 1169

ingredient declaration 1169 back of pack

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Dralex

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Posted 23 July 2021 - 08:24 AM

Hi all, my Company are producing fish cakes, fish pie and seafood chowder using a 'Seafood MIx' The mix always contains white fish, red (oily) fish and a smoked fish - the problem I am having is that this mix can contain up to 16 different species of fish! Our supplier makes up the mix depending on what's available/in season/cheap! As we never get the exact same mix of species twice - how do I declare the seafood mix on back of pack? Do I have to declare all 16 possible species? Or can i simply sate "Seafood Mix (White FISH, Red FISH, Smoked FISH)"? Many TIA



pHruit

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Posted 23 July 2021 - 09:09 AM

Hi, welcome to the forum :welcome:
 

I'm afraid to say that your question looks like quite a headache, but you've probably already realised that!

 

Are the white/red/smoked components always in this order in terms of largest to smallest component, i.e. whatever random species you've got for your white fish the quantity within the mix always totals more than the random species for the red fish, and in turn the total content of those is always more than the smoked fish?
If not, then you have an extra headache, as your compound ingredients should be in descending order of weight, and if this changes, your label should change...

 

I'm not a fish person but the question aroused my curiosity. Your products appears to be outside the scope of Regulation (EU) 1379/2013, and the associated requirement to provide commercial and scientific name of the species, which certainly works in your favour.

 

I don't imagine that the "and/or" labelling option in point 7 of Part A of Annex VII of Regulation (EU) 1169/2011 would be applicable for your products, so won't help here?

 

However, I do think that point 5 of Part B of that same Annex could help:

Without prejudice to Article 21, ingredients which belong to one of the categories of foods listed below and are constituents of another food may be designated by the name of that category rather than the specific name.

5. All species of fish where the fish constitutes an ingredient in another food and provided that the name and presentation of such food does not refer to a specific type of fish.

 

This gives the designation option of "fish", so it implies that that you could group them all as "fish".

 

Are you specifically using front of pack / descriptive text / pictures / advertising to draw attention to the smoked / oily / white fish mix?
If so, this definitely makes it somewhat more complex, as you're then open to the question of whether those are adequate descriptions - is a consumer going to understand what they actually mean? Guidance on this seems a bit variable, and in this case I'd honestly be inclined to pick up the phone to whoever the responsible authority is (FSAI?). It's always been my experience that trying to talk to regulators proactively only results in a positive and beneficial relationship in the long term ;)



Dralex

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Posted 26 July 2021 - 09:43 AM

Hi pHruit

 

To answer your questions:

 

1. yes, proportions of fish always stay the same 34/33/33%

2. Are you specifically using front of pack / descriptive text / pictures / advertising to draw attention to the smoked / oily / white fish mix? - no, simply "Fishcakes" or "Seafood Chowder"

 

The "point 5 of Part B - 'fish'" - is something I had noticed too, I was kinda hoping someone would agree with me that it could be the solution to my problem so thanks for that!

 

Many Thanks for your input, much appreciated!






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