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Labelling requirements for fish and fish products

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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:

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 additional core labelling and voluntary claims and statements requirements that apply to all prepackaged foods.

Common name

The common name must appear on the principal display panel of prepackaged fish and fish products [B.01.006(1), FDR; 218(1)(a), SFCR].

The common name of a fish product is:

For more information, refer to Common name and Legibility and location pages of the Industry Labelling Tool.

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 permitted when the product contains a single fish species. The name of the species must be incorporated into the common name, for example "haddock fillets", "cod portions".

If the product contains more than 1 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, that is to say 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" include, but are not limited to, clams, oysters, mussels, scallops, whelks, shrimp, sea urchins, lobster and crab.

A seafood mix which also contains other marine products (for example, fish, squid, octopus, cuttlefish) could be labelled 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".

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 or identified in boldface type, but not in italics, in the FDR. Therefore, such products may use the term "surimi" in the common name, and should include additional descriptors as appropriate (for example, surimi roll, surimi cakes) [B.01.001(1), FDR; 1, SFCR].

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:

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, such as "salmon 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, such as "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 of their proportion by weight in the product.

or

If the oil has been extracted from multiple marine animal species, and not from fish species, a 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 of their proportion by weight in the product.

or

If the oil has been extracted from multiple fish species, but not from other marine animals such as seals, a 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 of their proportion by weight 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.

Hermetically sealed tuna

The labels on all packages of hermetically sealed tuna must indicate the colour of the fish flesh [262(1)(b), SFCR]. The descriptors intended for use, and conditions that must be met, are listed in Table 3 of the document Descriptive Words, Expressions and Identification Names for Specific Foods:

Salted fish

In the case of prepackaged salted fish, if the label bears one of the expressions to describe the salt and moisture content of the fish in Table 4 of the document entitled Descriptive Words, Expressions and Identification Names for Specific Foods, the condition indicated for that expression must be met [262(2), SFCR]:

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)(a), 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:

Nearshore wet storage:

Onshore wet storage:

Wet storage after relay:

Land based aquaculture:

For policies and criteria that apply to the harvesting of bivalve molluscs, refer to the Canadian shellfish sanitation program manual.

Descriptive words about the true nature of fish products

Additional descriptive words that tell about the true nature of prepackaged fish and fish products must be shown on the principal display panel when their omission will likely result in the food being mistaken for another food. This includes, but is not limited to, description of the various forms or styles of the food (such as split, fillet, minced, flaked), its packaging medium (such as packed in water, brine or oil, or dry pack) or its condition (such as salted, dried, smoked) [B.01.006.1, FDR].

For example, breaded fish portions may be made from slices of fish or from minced fish. Descriptive terms to indicate when such a product is made from minced fish must be shown on the principal display panel of the label.

Similarly prepackaged shellfish, such as mussels, may be sold with or without the shell. When the shell is included with the product and is not visible to consumers at the point of sale, the information concerning the presence of shells must be indicated on the principal display panel.

When fish is processed using filtered smoke, a statement that indicates the presence or use of the filtered smoke for colour retention purposes must be shown on the principal display panel to avoid misleading the consumer or purchaser about the true nature of the food.

Fish products that have received some heat treatment but are not ready-to-eat (RTE) products (such as frozen blanched crab legs, frozen "flash fried" breaded fish portions) may be perceived as being RTE. To prevent such a product being mistaken for a RTE product, words indicating that the product is raw and must be properly cooked prior to use must be shown on the principal display panel.

For more information on this requirement, refer to True nature.

Net quantity

For most consumer prepackaged 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, which must generally be expressed in metric units and be shown on any part of the label except solely on the bottom of the container [243, 244.1(c), 244.2, 245, SFCR]. Refer to Fish in hermetically sealed containers for exception.

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(a), 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 (for example, a package of cooked mussels in the shell), the word "weight" alone must be used.

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

Refer to the Net quantity page for more information, including minimum type size requirements.

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 [item 52, Table 1, Units of Measurement for the Net Quantity Declaration of Certain Foods].

Oysters in shell

Consumer prepackaged oysters that are sold in the shell, other than those in hermetically sealed packages, must declare their net quantity by bushels or pecks, if the net quantity is shown in Canadian units by volume [237(1) and (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, in addition to the declaration of net quantity, if the drained weight corresponds to less than 80% of the net quantity [item 53, Table 1, Units of Measurement for the Net Quantity Declaration of Certain Foods].

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 (for example, canned fish) [244.4(b), SFCR].

Date marking, storage and handling instructions

Many fish and fish products have a durable life of 90 days or less. The same requirements for date markings and storage instructions that apply to other prepackaged foods also apply to fish and fish products. For more information, including manner of declaring, see the Date markings and storage instructions page.

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:

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 screens Footnote 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.

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 easily legible (meaning, readily discernible) and conspicuous (meaning, clear and prominent) to a prospective buyer. 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 at least as legible and conspicuous 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 instead and in the manner described above [B.01.080(3), 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(1), FDR].

Nutrition labelling

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 (for example, 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

The label of prepackaged fish or fish products must include the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled. 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, refer to the Name and principal place of business page.

Country of origin

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

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 have been harvested may be indicated on the label, including as part of the common name.

Note: in the SFCR, country of origin is referred to as foreign state of origin.

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 and grade requirements for fish 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 1 official language [205(1), 206(3), SFCR].

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

Table 1: type height for grade name on consumer prepackaged fish (when net quantity > 900 g)
Item Area of principal display surface Minimum character height
1 ≤ 32 cm2 (5 inches2) 1.6 mm (1/16 inch)
2 > 32 cm2 (5 inches2) but ≤ 258 cm2 (40 inches2) 3.2 mm (1/8 inch)
3 > 258 cm2 (40 inches2) but ≤ 645 cm2 (100 inches2) 6.4 mm (1/4 inch)
4 > 645 cm2 (100 inches2) but ≤ 2 580 cm2 (400 inches2) 9.5 mm (3/8 inch)
5 > 2 580 cm2 (400 inches2) 12.7 mm (1/2 inch)

For prepackaged other than consumer prepackaged fish, the grade name must be clearly and prominently shown and readily discernible 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 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:

Table 2: Required grade, class and size information for prepackaged fish
Fish product Required information
Pickled split herring Grade name, class name and size designation
Pickled fish other than pickled split herring Grade name and size designation
Bloaters Grade name
Bloater fillets Grade name
Frozen Atlantic smelts Grade name
Atlantic oysters in the shell Grade name
Dried squid Grade name
Pacific salmon Grade name
Whitefish Grade name

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 on the Date markings and storage instructions page.

As well, refer to Legibility requirements for other specific labelling topics for information on the legibility requirements that are applicable to lot codes.

Voluntary claims and statements

Light salted

The term "light salted" with respect to fish is specifically permitted in the 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 (sustainable, dolphin safe and others)

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 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.

Please note that until December 13, 2022, inspection legends that comply with section 28 of the repealed Fish Inspection Regulations will be deemed acceptable for use on fish product labels. As of December 14, 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.

Refer to Legibility requirements for the inspection legend for an image of Figures 1 and 2 of Schedule 2 of the SFCR and for information on minimum type size and other legibility requirements.

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(1), FDR].

Foreign state

Foreign state includes a World Trade Organization (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, and includes consumer prepackaged [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 for a definition of principal display surface, as it applies to consumer prepackaged food [1, SFCR].

Salted fish

Fish of the Gadidae family that has been preserved by salt and that has a salt content of 12% or more by wet weight and a moisture content of not more than 65% [261, SFCR].

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