Labelling Requirements for Fish and Fish Products

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Table of Contents

Overview

For the purposes of this webpage, "fish" means any marine animal, including fish, shellfish, crustaceans and also other marine animals such as marine mammals.

The labelling requirements of the Fish Inspection Regulations (FIR) that are summarized in this section apply to all of those animals and any parts, products or by-products thereof processed in federally registered establishments, as well as to imported products. When sold in Canada, fish and fish products are also subject to the labelling requirements under the Food and Drugs Act (FDA) and the Consumer Packaging and Labelling Act (CPLA).

Fish and fish products destined for intraprovincial trade are subject to the labelling requirements under the Food and Drugs Act and the Consumer Packaging and Labelling Act. These are summarized in the core labelling, claims and statements, and food-specific labelling requirement pages of the Industry Labelling Tool. Provincial regulations may also apply to products sold within that province.

The requirements detailed in the following sections are specific to fish and fish products. They are in addition to the core labelling and other requirements that apply to all prepackaged foods.

Common Name - Fish and Fish Products

Every fish, can of fish or the wrapper or label thereon shall be correctly and legibly marked with the common name of the fish. Refer to Legibility and Location – Fish and Fish Products for more information. [25(1)(a) and (2), 26(1)(a) and (2), FIR].

The common name of a fish product is [B.01.001, B.01.006(1), Food and Drug Regulations]:

  • the name prescribed by the Fish Inspection Regulations (or other applicable Canadian legislation) [38-40, 51, 52, 72, FIR] or
  • the name identified by boldface type in the Food and Drug Regulations; or
  • if the name is not prescribed in legislation, the name by which the food is generally known;

CFIA Fish List

The CFIA Fish List provides regulatory guidance regarding the common names for fish. The names on the CFIA Fish List are considered acceptable common names and the use of these names is recommended. The use of common names that are not on the CFIA Fish List can be assessed against the requirement that no person shall package or label fish in a manner that is false, misleading or deceptive [27, FIR; 5(1), FDA; 7(1), CPLA].

The CFIA Fish List also provides a Taxonomic Serial Number (TSN) for each species, along with any associated hazards. Scientific names for fish species are verified with the Integrated Taxonomic Information System (ITIS).

Anyone seeking an amendment (deletion or addition) to the CFIA Fish List may submit a request through the Ask CFIA website. Applications can be made in accordance with Section 5 of the Guidance on Determining the Common Names for Fish Sold or Processed in Canada.

Generic Common Names

Unless outlined in the Fish Inspection Regulations, the use of generic names such as "fish fillets" or "fish portions" is not permitted. A name of the species should be incorporated into the common name, for example "haddock fillets", "cod portions".

Labelling of Pacific Salmon in Canada

The name "Pacific Salmon" is not included as an acceptable common name in the CFIA Fish List due to the different market values of species of Pacific salmon. As described above, the common name must always include the name of the species, for example "chum salmon fillets" or "sockeye salmon portions". The statement "Pacific salmon" is permitted on the label only as additional information, but may not replace the common name.

Indication of Geographic Origin

The geographic location where the fish has been harvested may be added to the common name, however this is optional.

Canned Fish Products

The common name on canned fish must:

  • be shown in letters of equal height and prominence, and
  • indicate whether the product has been prepared
    • by mincing, flaking or other special process;
    • from selected parts of fish;
    • for dietetic use [25(1)b, FIR].

Surimi

Fish products that are made from surimi (a paste made from highly refined minced fish) must use the name by which the food is generally known, as there is no prescribed common name in the Fish Inspection Regulations nor identified in boldface type in the Food and Drug Regulations. Therefore, such products may use the term "surimi" in the common name, and should include additional descriptors as appropriate (e.g. surimi roll, surimi cakes).

In some instances, surimi-based products closely resemble more expensive seafood products, such as crab legs, shrimps, or scallops through flavouring and shaping. Surimi-based products that resemble these foods should be labelled and/or advertised to clearly show that they are imitations.

For example:

  • The common name identifies the term "artificial" or "simulated" or "imitation", (such as, "artificial crab legs" and "imitation lobster meat"), or
  • The common name identifies the name of the species used in the product, (such as, "crab flavoured Alaskan Pollock" and "Lobster flavoured seafood made from whiting"), or
  • If various species were used, the common name refers to a generic name (such as, "crab flavoured seafood" and "lobster flavoured kamaboko")

Fish Oils

From a single species

If the oil has been extracted from a single species of fish or marine animal, the common name of the product should be the common name of the species, e.g. "halibut oil" or "seal oil".

From various species

If the oil is a mixture of oils extracted from various species, the name of the product must include all the common names of the species, e.g., "salmon, sardine and seal oil" and the common names of the species must be repeated in the list of ingredients. The common names must be declared in the ingredients list in descending order by their content in the product.

Or

If the oil has been extracted from multiple marine animal species, and not from fish species, a generic common name "Marine oil" can be used. The common names of the marine species must be included in the list of ingredients in descending order by their content in the product.

Or

If the oil has been extracted from multiple fish species, but not from other marine animals such as seals, a generic common name "Fish oil" can be used, and common names of the fish species must be included in the list of ingredients in descending order by their content in the product.

Additional Terms

Descriptive terms are required on some prepacked fish products:

  • In the case of canned fish, descriptive terms must be printed in the letters not less than one-half of the letters used for the common name [25(3), FIR].
  • In the case of fish, other than canned fish, descriptive terms are required if their absence would make the label false, misleading or deceptive [27, FIR].

For instance, uniform rectangular portions of breaded minced fish require "made from minced fish"/ "fait de poisson haché" in close proximity to the common name, and in letters not less than one-half of the letters used for the common name [51(4), FIR].

Canned Tuna

The labels of all cans of tuna must indicate the colour of the fish flesh [49, FIR]:

  • "white meat tuna" or "white tuna" (only tuna of the species Thunnus alalunga or Thunnus germo),
  • "light meat tuna" or "light tuna";
  • "dark meat tuna" or "dark tuna".

Whitefish

Each container of whitefish (Coregonus clupeaformis) must be marked in English or French with the name of the lake of origin of the whitefish, including the name of the province, and the words "dressed whitefish" or "round whitefish" or "whitefish fillets", as the case may be.

Use of Filtered Smoke

For fish processed using filtered smoke, absence of a descriptor indicating the presence of filtered smoke in close proximity to the common name may be considered misleading. Acceptable statements include:

  • "(Colour – optional) preserved with filtered wood smoke" or "(Colour – optional) preserved with purified smoke" or other similar statements identifying clearly that the colour of the fish is not natural but was altered; or,
  • "Processed with filtered wood smoke as a preservative (for color retention - optional)"; or,
  • "Produced using filtered wood smoke"

Net Quantity - Fish and Fish Products

The net quantity declaration on prepackaged fish is mandatory unless the container or label states that the contents are to be weighed at the time of retail sale (catch weight) [25(1)(b), 26(1)(b), FIR].

Declarations

The following specified fish products must indicate the net content as follows:
Fish Product Declaration
Oysters in the Shell Weight or bushels or pecks or by count
Oyster and clam meats – not frozen Weight or fluid measures or count
Canned shellfish and crustaceans Drained Weight
Canned fish packed with added water Drained weight
Fish frozen with glaze Excluding weight of the glaze
Fish packed in brine or vinegar solution Drained weight

The words "net weight" or "drained weight" can be used only on fish products that contain only edible parts. If the product also contains inedible parts such as shells, the word "weight" alone must be used.

Weight declarations such as "made from X lb" (e.g. for peeled shrimp) or "net weight when packed" (e.g. live mussels) are unacceptable.

See Legibility and Location – Fish and Fish Products for information on these requirements.

Storage Instructions and Handling Labelling

Smoked or Liquid Smoked Fish

Fish which is packed to exclude air and which has been smoked or to which liquid smoke or liquid smoke flavour concentrate has been added and which:

  • contains less than nine per cent of salt; and
  • has not been heat processed after sealing at a temperature and for a time sufficient to destroy all spores of the species Clostridium botulinum; and
  • is not customarily cooked prior to use

requires the statement "Keep frozen prior to use"/ "Garder congelé jusqu'à utilisation" on the principal display panel in letter size equal to the letters used in the common name [B.21.025, FDR].

Note: Smoked fish packed with oxygen permeable screensFootnote 1 needs no freezing and can be stored under refrigeration conditions. The statement "keep frozen prior to use" is not required, however the statement "Keep refrigerated" must be present, and the shelf life indicated on the label cannot exceed 14 days. The information on oxygen permeability of the packaging material must be available to an inspector up to retail level.

Heat Treated Non-RTE Fish Products

Fish products that have received some heat treatment but are not ready-to eat products (e.g., frozen blanched crab legs, frozen "flash fried" breaded fish portions), and which may be perceived as such by consumers, must be labelled as follows:

  • Information indicating that the product is raw and must be properly cooked prior to use must be clearly visible and present in both official languages on the principal display panel (PDP).
  • Statements such as "ready-to-eat," "heat and serve", "grilled fillets", "fried fish" or other statements giving any impression that the product can be consumed without further cooking are not permitted.
  • Cooking instructions are optional. However, if present, they must be adequate to ensure safety of the product.
  • If a vignette is present which creates an impression that the product is ready-to-eat, the statement "Serving suggestion" (or similar) in both official languages must be on, or adjacent to, the vignette.
  • Storage conditions to ensure safety of the product must be present on the label in both official languages (e.g., "keep frozen" statement on frozen products; "keep refrigerated" and "best before" date on products sold under refrigeration).

Previously Frozen Fish and Fish Products

Any fish [B.21.003, FDR] or the meat of any marine or fresh water animal [B.21.004, FDR] that has been frozen and thawed prior to sale must declare the words "previously frozen" on their principal display panel or on a sign displayed close to the food in letters that are legible and discernible. This includes both prepackaged and non-prepackaged products. When declared on the principal display panel, these words must either be close to the common name of the food in letters that are the same size as those used for the common name or anywhere on the principal display panel in letters that are at least ¼ of an inch (6.4 mm) in height [B.01.080, FDR].

If part of one of these foods has been frozen and thawed prior to sale, the words "Made from fresh and frozen portions" or "Made from fresh and frozen (naming the food)" must be declared [B.01.080, FDR].

As per the FDR, "frozen" means preserved by freezing temperatures and does not include any surface freezing that may occur during holding and transportation [B.01.080, FDR].

Nutrition Labelling - Fish and Fish Products

Raw, single ingredient marine or freshwater animal products (in fresh or frozen form) are usually exempt from carrying a Nutrition Facts table. This includes fish, crustaceans and combinations of raw, single ingredient marine or fresh water animal products (e.g. a mixture of raw single ingredient shrimp and scallops) [B.01.401(2)(b)(iv), FDR].

Smoked fish is not a single-ingredient food since smoke must be declared and salt is added; therefore, it is not exempt from carrying a NFT.

Sport Fish

If a registered processor custom-processes sport-caught fish, charges a fee for the service of processing the fish for personal consumption by the fisher, and the fish is returned in a package, then no sale is involved and an NFT is not required [B.01.004(2), FDR].

Legibility and Location - Fish and Fish Products

The common name, net quantity declaration and grade, size, class count or moisture content declarations on consumer packages (canned, and other than canned containing 900 g or less of fish) must appear in letters not less than 3.2 mm in height [26(2), FIR].

Note: Where the area of the principal display panel is greater than 258 square centimetres, the minimum type height of numerals in the net quantity must comply with the height prescribed in Section 14 of CPLR. Refer to the Net Quantity Legibility and Location requirements for more information.

Country of Origin - Fish and Fish Products

For fish or fish products imported into Canada, the name of the country of origin must be clearly identified on the label. The wording "Product of /Produit de" must be used to clearly identify the name of the country of origin [6(2)(c), FIR].

For imported fish products, the country of origin is the country where the last substantial transformation occurred.

For domestic products, a country of origin declaration is not required but may be provided voluntarily.

Grade, Size Class, Count and Moisture Content

The Fish Inspection Regulations require that grade, size, class, count or moisture content must be shown on the principal display panel for certain fish products as follows [26(1)(c), FIR]:
Fish Product Required Information
Pickled Fish Grade, Class and Size
Bloaters Grade and Count
Bloater Fillets Grade
Frozen Atlantic Smelts Size
Atlantic Oysters in the shell Shape Designations
Dried Squid Grade

Code Markings

Code markings are required on cartons and cases in which containers of domestically processed or imported fish are packed, as well as every container of pickled, spiced or marinated fish [6(2)(a), 6(3), 31, 32, FIR]. These markings must identify:

  • the name of the establishment and
  • indicate the day, month and year of processing and
  • for some products, identify the product (using the table Code Marking Letters for Product Identification below).

Every hermetically sealed container of fish that has been sterilized must be embossed or otherwise permanently marked to identify [33, FIR]:

  • the name of the establishment and
  • the day, month and year of processing and
  • for some products, identify the product (using the table Code Marking Letters for Product Identification below).

The meaning of code markings must be available to an inspector.

Code Marking Letters for Product Identification

Product First letters of code marking
Blueback salmon B
Chum salmon K
Coho salmon C
Pink salmon P
Sockeye salmon S
Spring salmon T
Steelhead salmon H
Mixed species of minced salmon M
Lobster L
Tomalley or lobster paste LT
Lobster cocktail LC

Shipping Containers and Institutional Packages

Shipping Containers for Fish and Fish Products

Labels of shipping containers (master cartons) for fish and fish products containing labelled retail packages, require [6(2)(a), 26(1)(f), 31(1), FIR]:

  • the common name of the fish;
  • the identity of the establishment
  • day, month and year of processing; and
  • the harvest location for bivalve molluscs in the shell.

All mandatory information normally applied on consumer packages is required on shipping containers with bulk fish, or containing fish packages with no labels (for institutional use).

The master carton label information can be in either English or French, and net quantity expressed in either metric or imperial units.

Protective wrappings are normally associated with bulk packaging, or with products that cannot be transported without adversely affecting its quality e.g. blocks of shrimp. Where fish are held within a protective wrapping, inside a properly labelled shipping container, then these protective wrappings are not considered to be inner packages and do not require labelling.

For more information on the shipping container requirements of the Food and Drug Regulations, please refer to Shipping Containers.

Institutional Packages for Fish and Fish Products

The net weight on institutional packages can be expressed either in metric or Imperial units.

Declaration of an approximate portion size on institutional packages is considered non-mandatory information, and e.g. the statement "about 60 g/portion" is acceptable.

Imports into Canada

All imported products must meet Canadian labelling requirements, including code markings.

It is the importer's responsibility to ensure that code marking information is securely, legibly and clearly stated on one end of the master carton prior to export to Canada. The CFIA will not allow importers to add this information to containers after they arrive in Canada.

Exports from Canada

In the case of fish products exported outside Canada, the label must meet Canadian labelling requirements unless an exemption from the regulation(s) is applied for and granted by the Fish, Seafood and Production Division. The exemption may be granted if the exporter supplies the Division with appropriate documentation from the regulatory authorities of the importing country that the label is acceptable in their country. In cases where the Division is already aware of the requirements, the exporter need not acquire the noted documentation.

Master cartons containing containers of fish products with exempted labels must bear the statement "For export to (a name of the country)".

Molluscan Shellfish Labelling Requirements

Live Molluscan Shellfish

In addition to the mandatory information that must be present on all food labels, the FIR requires that the label for bivalve molluscs in the shell must be correctly and legibly marked to show the date of processing and the location from which the bivalve molluscs were harvested [26(1)(f), FIR].

The label must also indicate either a "best before" date, or the date the molluscs were harvested. This date must be expressed on the label in the manner required in B.01.007(4)(d) and (5) of the FDR, (e.g. 97 JA 15 for January 15th 1997). The full year can be written out for clarity, e.g. 2003 JA 05. The statement "keep refrigerated" and the certification number of the registered establishment where the shellfish were processed must be also present on the label.

When live molluscs were wet-stored or relayed for more than 14 days, the harvesting date is the date when the molluscs were removed from the wet storage or relay site. When live molluscs were depurated, it must be indicated on the label.

Raw Shucked Molluscan Shellfish

In addition to the mandatory information that must be present on all food labels, the label on shucked molluscan shellfish sold fresh must indicate the registered establishment's certification number, the processing dateFootnote 2, the "best before" date and the statement "Keep refrigerated".

The label on shucked molluscan shellfish sold frozen must indicate the registered establishment's certification number, the processing dateFootnote 2, and the word "frozen" which must be immediately adjacent to the common name of the shellfish, and it must be in the letter type of equal prominence to the common name.

The "best before" date must be expressed on the label in the manner required in B.01.007(4)(d) and (5), FDR (e.g. 97 JA 15 for January 15th 1997). The full year can be written out for clarity, e.g. 2003 JA 05.

Where shucked meats were processed from depurated molluscan shellfish, it should be indicated on the label.

Voluntary Claims and Statements

Light Salted

The term "light salted" with respect to fish is specifically permitted in the Food and Drug Regulations (FDR) [B.01.502(2)(k), FDR]. Using this term does not trigger the Nutrition Facts table on exempted foods. Please refer to Composition and Quality Claims for more information on "light" claims that are specifically permitted under B.01.502(2) of the FDR.

Refer to Nutrient Content Claims for more information.

Quality Designations

A quality designation can be used only when a standard for that quality has been prescribed in the FIR, and the product meets that standard, e.g. "Fancy Shape" designation on Atlantic oysters is permitted when the oysters meet the requirements indicated in Section 65(a) of FIR [29, FIR].

Quality claims, where it is clear that the processor or importer or distributor is declaring responsibility for the quality, are permitted, e.g. "All Company X products meet our highest standards. If you have any questions or comments please write to us at: Company X, 123 Main St., Town, Province, Postal Code" would be an acceptable statement.

General statements such as "Quality products from XX", "Satisfaction guaranteed", "Guaranteed quality", etc. are also acceptable.

Method of Production Claims (e.g. sustainable, dolphin safe, etc.)

It is the responsibility of the company to ensure that all information contained on labels is truthful and not misleading. Companies who wish to place such statements on the labels must develop their own procedure to ensure that the product meets the claim. Upon request, documentation providing proof of these methods must be available to an Inspector of the CFIA.

Use of the "Canada Inspected" Logo

All fish establishments registered under the FIR are entitled to use the "Canada Inspected" logo on fish products processed as part of the establishment's Quality Management Program (QMP). Only fish products that are considered "Product of Canada" can bear the logo [28, FIR]. Refer to "Product of Canada" and "Made in Canada" Labelling for more information on the use of this statement.

There are no restrictions as to the size or the colour of the logo; however, the logo must be separate and distinct, and must not interfere with any mandatory labelling requirements. Permitted examples of "Canada Inspected" logos are shown in Bulletin 41 of the Fish Products Inspection Manual. The registration number of the establishment may be included in the logo.

Label Example

Label for Fish Products

Label for Fish Products. Description follows.
Description for Label for Fish Products

A - Brand name

A brand name is not required but frequently used by a manufacturer to identify its products distinctively from others of the same type. Brand names are subject to all labelling requirements, including compliance with provisions regarding claims.

B - Nutrient Content Claim

A nutrient content claim is a voluntary statement or an expression which describes, directly or indirectly, the level of a nutrient or energy in a food or a group of foods. Only those listed in the Food and Drug Regulations are permitted on food labels when the foods meet the stated criteria. When made, nutrient content claims must be in both English and French and the amount of the nutrient must be declared in the Nutrition Facts table.

C – Storage Instructions

The storage instructions are required on products with a durable life of 90 days or less that have storage conditions that differ from normal room temperature. Storage instructions must be declared in both French and English on any panel except the bottom of the container. Additional information indicating that the product is raw and must be properly cooked prior to use are required on the label when fish products may be perceived as ready-to-eat by some consumers.

D – Country of Origin

The country of origin provides information about the originating country of the product. The country of origin of imported fish or fish products must be clearly identified on the label, preceded by the words "Product of / Produit de". The country of origin declaration may be displayed on any surface except the bottom of the package, in either English or French. Domestic products may declare "Product of Canada" by meeting specific guidelines outlined in the Product of Canada Policy.

E – Composition Claim

The composition claim is a voluntary claim used by companies to highlight or emphasize an ingredient or flavour in a food product. When made, composition claims must be in both English and French.

F - Net Quantity

The net quantity is the amount of food in the package. It must be present on the principal display panel in a minimum type height. Specific requirements for declaration of net quantity may exist for specific fish products.

G – Canada Inspected Logo

Fish products processed under an acceptable Quality Management Program in federally registered establishments can bear the Canada Inspected logo. These products must have undergone substantial transformation in Canada.

H – Common Name

The common name is the name of the food printed in boldface type in the Food and Drug Regulations, the name prescribed by the Fish Inspection Regulations, or if not otherwise prescribed by the name in which the food is generally known. It must be present on the principal display panel in both English and French. The CFIA Fish List serves as a collection of French and English common names recognized by legislation and/or by which the fish is generally known. Descriptive terms may be required on certain fish products.

I – Nutrition Facts Table

The Nutrition Facts table (NFT) provides information about the nutrient content of a food (including energy (Calories) and 13 core nutrients) in a standardized format, allowing for comparison among foods at the point of purchase. The NFT must be displayed on the package in both English and French.

J – Contains Statement

Food allergens, gluten sources and sulphites are required to be labelled in the list of ingredients or in a "Contains" statement. An allergen, gluten or sulphite source must be written using the prescribed source name at least once in the list of ingredients or in a "Contains" statement. For example, if casein is present in a prepackaged product, it would be identified by the word "milk" in the ingredient list or Contains statement. A "Contains" statement if used must be complete for all allergens present in the product and appear on the label following the list of ingredients in both English and French.

K - List of Ingredients

The list of ingredients must be listed in descending order of proportion by weight, as determined before the ingredients are combined to make the food. The list of ingredients is required on most prepackaged foods. The ingredient list may be shown anywhere on the package, except the bottom and must be shown in both English and French.

L - Identity and Principal Place of Business

The identity and principal place of business identifies the responsible party and provides the location where a company can be contacted. It must be declared on any part of the food container except the bottom, in either French or English.

Additional Information

Decisions

Definitions

Canned Fish

Any fish that is sealed in a can and is sterilized [2, FIR].

Catch-Weight Product

A prepackaged product that, because of its nature, cannot normally be proportioned to a predetermined quantity and is, as a result, usually sold in varying quantities [38, CPLR].

Drained Weight

The weight of the edible contents of the container exclusive of free water, brine, pickling solution or glaze [2, FIR].

Fish

Any fish, including shellfish and crustaceans, and marine animals, and any parts, products or by-products thereof [2, FIA].

Fish Product

Fish or prepared fish [B.01.001, FDR].

Net Weight

With respect to unfrozen or frozen lobster meat, means the weight of the edible contents of a container after the liquid has been drained from the container by a method approved by the President of the Agency and, with respect to any other fish, means the total weight of the edible contents of a container [2, FIR].

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