What requirements should your product comply with to be allowed on European markets?
As one of the largest markets worldwide, Europe can be an interesting target market for fish and seafood. But first, you must fully understand the European Union’s legal requirements that apply to your fish and seafood products. Understanding is the first thing, after which follows the route towards compliance. Read further to improve your understanding of the legal requirements as well as the additional requirements that European buyers may ask from you.
Fishery products must come from an authorised country
If you want to export fish to the European Union, your country must be on the list of approved countries. In order to become an approved country, the national authority must submit a formal request to the Directorate-General for Health and Consumer Protection of the European Commission.
The approval is granted on the basis of your public health and control systems. This means that your country must be able to ensure that the fishery products exported meet the strict health requirements of the European Union. If your country has been approved, it also has a competent authority in place, which further approves establishments and factory vessels. Approved establishments receive a unique identification code, usually referred to as an “EU number”.
- Look at Section VIII of the list of approved countries and establishments to see whether your country is on it.
- Only the national authorities of your country can put forward your establishment for approval by the European Union. If your establishment has not been approved yet, you can contact your national authorities for further proceedings.
Fishery products must be caught by approved vessels (wild catch) or produced in registered farms (aquaculture)
To combat illegal fishing, a catch certificate must accompany fish imported or transhipped in the European Union. As an exporter, you must request the catch certificate for catches destined for the European Union. If a country fails to adhere to the European guidelines to prevent and eliminate illegal, unreported and unregulated (IUU) fishing, it risks a temporary ban from the seafood market in the European Union. In the past, this happened to Belize, Cambodia, Guinea and Sri Lanka.
A next step will probably be the development of a global catch certificate (instead of the current fragmentation, as European requirements are not the same as requirements for other main destination markets) to ensure responsible fishing throughout the world. The European Commission and the Food and Agriculture Organization of the United Nations (FAO) are looking into this matter.
- Read more about the catch certificate at the European Commission website on illegal fishing.
Fishery products must be accompanied by proper health certificates
Fishery products need health certificates which confirm that they meet the standards for export to the European Union.
- Read more about health control in the European Commission Portal.
There are many other rules and regulations in effect for exporting fishery products to the European Union.
General tips to deal with these rules and regulations are:
- Set up an administrative system that efficiently provides buyers with information about the precise sources of your products. Avoid working with intermediaries and local traders, unless you know how and from where they source the products that they sell to you.
- To identify the requirements that your specific seafood products must meet in Europe and other countries in the world, refer to the Code of Practice for Fish and Fishery products from the Codex Alimentarius Commission (CAC). In the European Union, EU Regulations show strong parallels with the Codes of Practices from the CAC.
- For a full list of requirements, including the ones mentioned below but also specific labelling requirements for fish, please consult the EU Trade Helpdesk, where you can select your specific product code under Chapter 03 or 16.
The most important rules and regulations include:
Hygiene-related regulations include the health standards of the fish, including contaminants and microbiological contamination (see below) as well as the implementation of Hazard Analysis and Critical Control Points (HACCP) principles.
In addition, they include packaging and storage (for example, controlled temperatures, also during transport). The implementation of HACCP is one of the measures that you need to take, but the general hygiene of your establishment must also be good and is of key importance to potential buyers.
- Read more about hygiene and health control in the European Commission Portal.
Traceability and labelling
Stricter traceability rules for seafood products within the European Union went into effect in December 2014 (Directive No 1379/2013). Under these rules, labels must provide precise information on the harvesting and production of the seafood. This applies to all unprocessed seafood, as well as to some processed seafood, regardless of whether it is pre-packed.
The new labelling system offers consumers the opportunity to select seafood harvested with more sustainable methods and from specific sources. One of the most significant changes concerns the requirement to specify the fishing gear used and the harvesting area.
Another recent change is that a list of allergens must be included in the label (Directive No 1169/2011). The obligation to provide nutrition information for the majority of pre-packed processed foods applies since December 2016.
- Take a look at examples of labels for fishery products, such as this label for an unprocessed and pre-packed fresh fish product.
- Read more about the labelling of allergens in the Allergy Intolerance Guide - informal guidelines regarding the requirements of Regulation (EU) No 1169/2011 on the provision of food information to consumers. Annex II of the document shows the list of allergens.
- For additional information on labelling, refer to this EU Pocket Guide to the EU’s new fish and aquaculture consumer labels.
Contaminants that may end up in the food product as a result of various stages in the process or environmental contamination are restricted by legislation. They include heavy metals such as lead, cadmium and mercury; dioxins and pentachlorophenol (PCP); as well as Polycyclic Aromatic Hydrocarbons (PAH). Fish destined for the European Union is generally tested before being shipped –sometimes in the buyer’s own lab, sometimes in recognised (independent) labs – to prevent costly border rejections.
- Learn more about contaminants in the European Commission portal; there is also a link to the EU fact sheet on Managing food contaminants: how the EU ensures that our food is safe.
Microbiological contamination is the result of bacteria unintentionally introduced into the fish and forms part of the health standard of the fish as established in Regulation (EC) No 2073/2005.
An example of microbiological contamination is a high histamine level. This can be caused by poor temperature management and can be found in tuna and sardines, for example.
Microbiological contamination can be prevented by proper hygiene measures, so make sure that you have these in place! In the case of histamine, for instance, instant cooling of the fish and proper temperature management at all stages should be introduced.
Just as contaminants, microbiological contamination is examined in the fish destined for the European Union. In many cases, processors have difficulty controlling microorganism levels in entry control. You should state minimum standards to your suppliers and perform entry tests.
- Read more about microbiological contamination and health control in the European Commission Portal.
Food safety certification as extra guarantee
The most commonly requested food safety certification schemes for seafood products are IFS (International Featured Standards) and/or BRC (British Retail Consortium). You will come across these schemes mostly in northern and western Europe.
While the standards originally focused on the food retail channel, they have also become accepted schemes in the food service channel (for example, high-end restaurants and catering providers). Certification according to one of these schemes is important for entering the European Union. Both schemes are based on HACCP and are similar in several respects.
- Obtaining BRC and/or IFS certification can improve your chances in the European Union. You should therefore start learning about these standards. You can read more about the respective schemes in the ITC Sustainability Map: BRC and IFS.
- If you are planning to invest in processing equipment, you should consider the requirements in order to avoid expensive reconstruction if you obtain certification in a later stage.
- Be aware of the time needed and the costs involved in the preparation phase. The most expensive and difficult part of the certification involves preparation for meeting the standard. The actual certification fee is usually only a fraction of the costs associated with certification.
- Consider using a certifying service provider. These providers usually offer both pre-certification and certification services.
Eco-labelling, a growing niche market
Eco-labelled seafood products have quickly gained market share on several European markets in recent years. Countries in western and northern Europe (such as the Netherlands and Germany) are the leading markets for eco-labelled seafood. On the southern and eastern markets of Europe, eco-labelling still plays a limited role.
For wild-caught fishery products, MSC (Marine Stewardship Council) is the major certification scheme. ASC (Aquaculture Stewardship Council) is the most important certification scheme for aquaculture. Other consumer eco-labels for fishery products include Friend of the Sea, Dolphin Safe, RSPCA Freedom Food and the GlobalG.A.P. Friend of the Sea Add-On Module for Aquaculture.
While the importance of eco-labelling is expected to increase in the coming years, this division between the European markets is expected to remain the same. In many western and northern European countries, supermarkets have committed to only selling eco-labelled fishery products. For example, about half the fishery products in German and Dutch supermarkets are eco-labelled. In the years to come, supermarkets are expected to drive the demand for eco-labelled fishery products.
- Although eco-labelling is often expected to offer higher margins, it should be considered primarily as a “market guarantee”, even in difficult times. This means that the demand for eco-labelled seafood is less volatile than the demand for conventional seafood.
- As many players in the northern and western parts of Europe are interested in eco-labelled products, becoming certified offers market opportunities in these countries. For more information, refer to the websites of the respective certification schemes and/or read more about these schemes in the ITC Sustainability Standards Map: MSC and ASC.
- For a full overview of certification schemes in the fisheries sector, consult the ITC Sustainability Standards Map database.
- Also look at what “organic” means according to European legislation, as explained in the EU Trade Helpdesk.
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