Labelling requirements for fish and fish products

Overview

For the purposes of this web page, "fish" means any marine animal, including shellfish and crustaceans, and any of their parts, products and by-products [1, SFCR].

This section summarizes the labelling requirements that apply to imported fish and fish products, as well as those that are manufactured, processed, treated, preserved, graded, packaged or labelled in Canada for interprovincial trade and for export. In some cases, the labelling requirements would also apply when these are intraprovincially traded.

Fish and fish products are subject to the provisions of the Safe Food for Canadians Act (SFCA) and the Safe Food for Canadians Regulations (SFCR), as well as those of the Food and Drugs Act (FDA) and the Food and Drug Regulations (FDR).

When sold intraprovincially, these products are subject to the labelling requirements under the FDA and FDR, as well as specific requirements of the SFCA and SFCR that apply to prepackaged foods sold in Canada, regardless of the level of trade. Provincial regulations may also have labelling requirements that apply when these products are sold within that province.

The labelling requirements detailed in the following section are specific to fish and fish products.  Refer to the Industry Labelling Tool for core labelling and voluntary claims and statements requirements that apply to all prepackaged foods.

Common name - fish and fish products

Prepackaged (definition) fish must be correctly and legibly labelled with the common name of the fish [218(1)(a), SFCR]. Refer to the Common Name and Legibility and Location pages of the Industry Labelling Tool for more information, including minimum type size and location requirements.

The common name of a fish product is [1, SFCR; B.01.001, B.01.006(1), FDR]:

• the name printed in boldface type, but not in italics, in the incorporated by reference document entitled Canadian Standards of Identity, Volume 3 – Fish
• the name given in the document incorporated by reference entitled Common Names for Prepackaged Fish, if the fish is in hermetically sealed package
• the name printed in boldface type, but not in italics, in the Food and Drug Regulations
• the name prescribed by other applicable Canadian legislation, 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 [5(1), FDA; 6(1), SFCA].

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 Canadian Standards of Identity, Volume 3 – Fish, the use of generic names such as "fish fillets" or "fish portions" is not recommended when the product contains a single fish species. A name of the species should be incorporated into the common name, for example "haddock fillets", "cod portions".

If the product contains more than one species of fish, in most cases a generic name "fish" can be used in the common name provided that the species are indicated in the list of ingredients.

Labelling of Pacific Salmon

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 should 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.

Labelling of Seafood Mix Products

For a seafood mix product to be labelled as "Fruits de mer" in French, 100% of the mix should be small edible marine invertebrates with a shell at the time of harvest, i.e. crustaceans, echinoderms and molluscs of the classes Bivalvia and Gastropoda. Species from the Cephalopoda class do not have a protective shell and therefore are not included in the definition of "Fruits de mer." Examples of "Fruits de mer" includes, but is not limited to, clams, oysters, mussels, scallops, whelks, shrimp, sea urchins, lobster and crab.

A seafood mix which also contains other marine products (e.g., fish, squid, octopus, cuttlefish, etc.) could be labeled as "Produits de la mer" or "Produits de la pêche" in French.

"Seafood" is an acceptable translation in English for the French terms "Fruits de mer", "Produits de la mer" and "Produits de la pêche".

Hermetically sealed fish products

The common name on hermetically sealed fish (definition) must indicate whether the product has been prepared:

• by mincing, flaking or another special process
• from selected parts of fish, or
• for dietetic use [262(1)(j), SFCR].

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 Canadian Standards of Identity, Volume 3 – Fish, the Common Names for Prepackaged Fish or identified in boldface type, but not in italics, 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

Certain descriptive terms are required on prepackaged fish products that are imported to Canada, exported from Canada or that are interprovincially traded. Unless otherwise indicated, these descriptive terms must be shown on any part of the label other than solely on the bottom of the container, and for consumer prepackaged fish products, in characters of at least 1.6 mm (1/16 inch) in height [210, 245(2) and (3), SFCR]. For more information, refer to the Legibility and Location page of the Industry Labelling Tool for requirements that apply to all foods.

Uniform rectangular portions of breaded minced fish

Uniform rectangular portions of breaded minced fish require descriptive terms, such as made from minced fish, to indicate that the product is manufactured or prepared from minced fish. Those terms must be located in close proximity to the common name and must either be printed in letters not less than one-half the height of the letters used for the common name or in characters that are at least 1.6 mm tall, whichever of the two options is greatest [262(1)(e), 262(3), SFCR].

Hermetically sealed tuna

The labels on all packages of hermetically sealed tuna must indicate the colour of the fish flesh [262(1)(g), SFCR]:

• "White Meat Tuna" / "chair de thon blanc" or "White Tuna" / "thon blanc" (only tuna of the species Thunnus alalunga)
• "Light Meat Tuna" / "chair pâle de thon" or "Light Tuna" / "thon pâle"
• "Dark Meat Tuna" / "chair foncée de thon" or "Dark Tuna" / "thon foncé"

Salmon

Transverse cuts of salmon placed in a hermetically sealed package after the skin and vertebrae have been removed must bear the words "Skinless" / "sans peau" or "Boneless" / "sans os" or "sans arête" on its label [262(1)(a), SFCR].

Salmon in a hermetically sealed package may also be sold as minced salmon, tail and nape trimmings, or small pieces. These products must bear the descriptive terms "Minced" / "haché" or "Salmon Tips" / "bouts de saumon", depending on the situation [262(1)(b), SFCR].

Lobster

Unfrozen lobster meat packaged without the addition of brine must bear the expression "Dry Pack" / "emballage à sec" [262(1)(c), SFCR]. Prepackaged (definition) frozen lobster meat must contain the expression "Frozen Lobster Meat" / "chair de homard congelée" [262(1)(d), SFCR].

Salted fish

The labels on salted fish must describe the processing of the fish using terms such as "Split Fish" / "poisson fendu", "Split Fish with Entire Backbone" / "poisson fendu avec colonne vertébrale entière", or "Fillet" / "filet" [262(1)(h), SFCR]. The labels must also describe the salt and/or moisture content of the fish using the appropriate expression [262(1)(i), SFCR]:

• "Slack Salted Fish" / "poisson faiblement salé", when salt is ≤ 25% dry weight
• "Light Salted Fish" / "poisson légèrement salé", when salt is ˃ 25% but ≤ 33% dry weight
• "Dried Heavy Salted Fish" / "poisson fortement salé séché", when salt is > 33% and moisture is ≤ 54%
• "Green Heavy Salted Fish" / "poisson fortement salé en vert", when salt is > 33% and moisture is between 54% and 65%

Bivalve molluscs

The label for bivalve molluscs in the shell and not in a hermetically sealed package must be correctly and legibly marked to show the date of processing and have an expression, code or identifier that indicates the location from which the bivalve molluscs were harvested [262(1)(f), SFCR].

The harvest location of the bivalve molluscs is the most precise identification as practical, such as the name of geographic area, lease number, harvest area identifier and/or sub-area if applicable. For any other activities listed below the location from which live bivalve molluscs were harvested is considered to be:

Relay:

• the relay site

Nearshore wet storage:

• if bivalve molluscs are wet stored for less than 14 days, the original harvest location prior to wet storage
• if bivalve molluscs are wet stored for 14 days or greater, the harvest location of the nearshore site

Onshore wet storage:

• if bivalve molluscs are wet stored in an untreated flow through system for less than 14 days, the original harvest location
• if bivalve molluscs are wet stored in an untreated flow through system for 14 days or greater, the harvest location of the source water
• if bivalve molluscs are wet stored in a system with treated water or synthetic water, the original harvest location regardless of the duration of storage

Wet storage after relay:

• nearshore or onshore criteria above applies except the original harvest location becomes the relay site

Land based aquaculture:

• if bivalve molluscs are grown in a land based aquaculture facility using treated or synthetic water, the harvest location is identified as the licence number issued by the authority permitting this activity

For policies and criteria that apply to the harvesting of bivalve molluscs, refer to the Canadian Shellfish Sanitation Program manual.

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,
• "Processed with filtered wood smoke as a preservative (for color retention - optional)", or
• "Produced using filtered wood smoke"

Net quantity - fish and fish products

For most consumer prepackaged (definition) fish products, a net quantity declaration is required on the principal display panel in metric units [221, 232, SFCR].

For prepackaged other than consumer prepackaged fish, a net quantity declaration is required and can be expressed either in metric or in Canadian units [243, 262(1)(k), SFCR].

If properly labelled prepackaged fish is placed inside a second container and the resulting product is prepackaged fish, other than consumer prepackaged fish, the second container is not required to be labelled with the declaration of net quantity [263, SFCR].

The net quantity declaration of prepackaged fish products must be shown by volume, weight or numerical count in accordance with the document incorporated by reference, Units of Measurement for the Net Quantity Declaration of Certain Foods [231, 244, SFCR].

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.

Shrimp cocktail

Shrimp cocktail must always have its net quantity declared in units of weight. The declaration must be accompanied by either a statement indicating the total weight of the shrimp inside the container or by an indication of the percentage of the weight of the shrimp in the edible contents of the container [4, Units of Measurement for the Net Quantity Declaration of Certain Foods].

Oysters

Consumer prepackaged oysters that are sold in the shell, other than those in hermetically sealed packages, may declare their net quantity by bushels or pecks, if shown by volume [237(2), SFCR].

Mackerel

When mackerel or mackerel fillets in hermetically sealed containers are prepared without adding water, brine or vinegar solution, the drained weight of the product must be specified on the label if the drained weight corresponds to less than 80% of the net quantity [262(2), SFCR].

Fish in hermetically sealed containers

The net quantity declaration must appear on the principal display panel anytime a prepackaged fish is packaged in a hermetically sealed and commercially sterile container (e.g., canned fish) [265, SFCR].

For additional details, refer to Net Quantity.

Labelling for storage instructions and handling

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].

Heat treated non-RTE fish products

Fish products that have received some heat treatment but are not ready-to-eat (RTE) 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 6.4 mm (1/4 inch) 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 temperature 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 Nutrition Facts table (NFt).

Sport fish

If a 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].

Name and principal place of business – fish and fish products

Prepackaged fish and fish products must include the name and principal place of business of the responsible party. This information must appear on any part of the label other than solely on the bottom of the container [B.01.007(1.1)(a), FDR; 218(1)(b), 218(2), SFCR].

For more information, including manner of declaring, please refer to Name and Principal Place of Business.

Country of origin - fish and fish products

For prepackaged fish (definition) imported into Canada, the name of the country of origin must be clearly identified on the label [266, SFCR]. The wording "Product of" / "produit de" is recommended to help clearly identify the name of the country of origin.

For imported prepackaged fish, 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. In contrast to other fish, Canadian prepackaged whitefish (definition) must bear the name of the lake and province from which the fish originate [267, SFCR].

The above information must be shown on any part of the label other than solely on the bottom of the container, and for consumer prepackaged fish, in characters of at least 1.6 mm (1/16 inch) in height [210, 245(2) and (3), SFCR].

The geographic location where fish (other than whitefish) have been harvested may be added to the common name, optionally.

Grade name, class name and size designation

Please note that all references to the "Compendium" in this section refer to the Canadian Grade Compendium.

The grade names (definition) and grade requirements for fish (definition) are set out in Volume 8 of the Compendium, while those for imported fish are set out in Volume 9. Unlike other commodities, import grade names for fish are identical to Canadian grade names.

All fish, except frozen gutted Pacific salmon, for which grades are prescribed by the SFCR and that are interprovincially traded, imported or exported must be graded, must meet grade requirements set out in the Compendium and must also be labelled with the applicable grade name [306(1), 306(2)(a), SFCR].

Grading is optional for frozen gutted Pacific salmon. However, when graded and labelled with the applicable grade name, the grade requirements must be adhered to [307(a), SFCR].

The grade name on prepackaged fish, including consumer prepackaged fish, is only required in one official language [205(1), 206(3), SFCR].

For consumer prepackaged fish, the grade name must be shown on the principal display panel (definition) in characters of [312, 319, Schedule 6, SFCR]:

• at least 3.2 mm in height, if the net quantity of the product is 900 g or less
• at least the minimum character height set out in the following table, which varies according to area of the principal display surface (definition), if the net quantity of the product is more than 900 g.

For prepackaged other than consumer prepackaged fish, the grade name must be clearly and prominently shown and readily discernible and legible under customary conditions of purchase and use. When the net quantity of the product is 900 g or less, the grade name must meet a minimum character height of 3.2 mm, similarly to consumer prepackaged fish [208, 319, SFCR].

When a labelled consumer prepackaged fish is placed inside a second container and results in consumer prepackaged fish, the product is not required to bear the grade name on the second container [318, SFCR].

Some prepackaged fish interprovincially traded, imported or exported must show a class name or size designation on the label in close proximity to the grade name, when required by the Volume 8 of the Compendium. Class name and size designation must be presented in a minimum type height of at least 3.2 mm [317, SFCR].

Volume 8 of the Compendium indicates that prepackaged fish outlined in the table below must provide the following information:

Lot code

For information on the requirement for a lot code or other unique identifier for traceability purposes, consult Traceability-specific labelling Requirements.

Please note that recommendations have been made regarding the use of potentially misleading lot codes. For additional information, please refer to the Lot Code section under Manner of declaring on the Date Markings and Storage Instructions page.

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 on "light" claims. For more information on Salted Fish, refer to the Additional Terms section.

Method of production claims (e.g. sustainable, dolphin safe, etc.)

Claims concerning the method of production of fish and fish products are permissible provided they meet the criteria detailed on the Method of production claims page.

Use of the inspection legend

A licence holder is permitted to voluntarily apply to prepackaged fish (definition) that is interprovincially traded or exported from Canada the inspection legend set out in Figure 1 or 2 of Schedule 2 of the SFCR, provided the conditions set out in section 182 of the SFCR are met, including the standards set out in the Canadian Standards of Identity, Volume 3 – Fish. Refer to Inspection marks for more information on inspection legends.

The inspection legends consist of a circular outline containing a maple leaf with the word Canada written across the maple leaf. When Figure 1 is used, the number identifying the licence holder’s establishment must replace the numbers 00 that appears beneath the maple leaf [183, SFCR]. Alternatively, the number identifying the establishment may be omitted from the inspection legend altogether, as per Figure 2 illustrated below.

Please note that until January 14, 2022, inspection legends that comply with section 28 of the Fish Inspection Regulations will be deemed acceptable for use on fish product labels. As of January 15, 2022, the former inspection legends may no longer be used [374(3)(c), SFCR]. When the inspection legends are used, it is the responsibility of the regulated party to accurately reproduce these.

The inspection legend must meet the legibility and location requirements set out in the SFCR for mandatory information. It must be separate, distinct, and must not interfere with any mandatory labelling requirements. With respect to type size requirements, the numerals "00" in Figure 1 (i.e., the number identifying the licence holder's establishment) must be a minimum of 1.6 mm in height [208, 210, SFCR]. For Figure 1 and Figure 2, the word "Canada" must be distinguishable within the maple leaf [208, SFCR]. These legibility requirements correspond to a minimum circle diameter of the inspection legend of about 14 mm and the use of type that has a high level of colour contrast with the background label. The size of the inspection legend may be required to increase as the size of the package increases so that the inspection legend is prominently shown on the label. All components of the inspection legend must be in the same proportions as those shown in the inspection legends above to meet the legibility requirements in section 208 of the Safe Food for Canadians Regulations (SFCR).

Additional information

Decisions

• Marine and Fresh Water Products

Definitions

Consumer prepackaged

Consumer prepackaged, in respect of a food, means packaged in a container in the manner in which the food is ordinarily sold to or used or purchased by an individual — or in which the food may reasonably be expected to be obtained by an individual — without being repackaged, to be used for non-commercial purposes [1, SFCR].

Drained weight

The weight of the edible contents of the container exclusive of free liquid or glaze content.

Fish

Any fish, including shellfish, crustaceans and other marine animals, and any of their parts, products or by-products [1, SFCR].

Fish product

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

Foreign state

Foreign state includes a WTO Member as defined in subsection 2(1) of the World Trade Organization Agreement Implementation Act [1, SFCR].

Grade name

Under the SFCA, grade name means a prescribed name, mark or designation of a food commodity [2, SFCA].

The SFCR further specify that, for the purposes of this definition, the grade names that are set out in the Compendium and in the Grades Document are prescribed in respect of foods [305, SFCR].

Hermetically sealed package

A package that, due to its design, is secure against the entry of micro-organisms, including spores [1, SFCR].

Person

Person means an individual or an organization as defined in section 2 of the Criminal Code [2, FDA; 2, SFCA].

A person may therefore be an individual or an organization, and may include a consumer, a manufacturer, a retailer, an importer, a restaurant, any other commercial or industrial enterprise, an institution such as a school or hospital, and anyone else who sells, uses, or buys a food.

Prepackaged

Prepackaged, in respect of a food, means packaged in a container in the manner in which the food is ordinarily sold to or used or purchased by a person (definition), and includes consumer prepackaged (definition) [1, SFCR].

Principal display panel

Refer to subsection B.01.001(1) of the Food and Drug Regulations and section 1 of the Safe Food for Canadians Regulations, as applicable, for a definition of principal display panel. The definitions for this term in both these regulations are closely aligned [B.01.001(1), FDR; 1, 393(1), SFCR].

Principal display surface

Refer to section 1 of the Safe Food for Canadians Regulations (SFCR) for a definition of principal display surface, as it applies to consumer prepackaged (definition) food [1, SFCR].

Whitefish

Means fish of the species Coregonus clupeaformis, Coregonus nasus or Prosopium cylindraceum [261, SFCR].