Labelling of Pacific Salmon Fillets/Portions (Standardized Fish Products) in Canada

December 20, 2010

To: Canadian Fish Processors and Importers

Subject: Labelling of Pacific Salmon Fillets/Portions (Standardized Fish Products) in Canada.

The purpose of this notice is to remind fish processors and importers of the requirements governing common names on standardized fish products and to inform them of acceptable labelling options for standardized Pacific salmon fillets and portions. This notice further clarifies the guidance provided in the Communiqué "Common Names for Fresh and Frozen Fish Fillets and Shucked Shellfish" issued on July 17, 2003.

Standardized fish products are the products for which a composition standard has been prescribed in Division 21 of the Food and Drug Regulations (FDR). These sections are marked with the letter [S] and are listed in the following sections of Division 21:

• B.21.003 - Fresh and frozen fin-fish
• B.21.004 - Fresh and frozen meats from marine animals other than fin-fish
• B.21.006 - Prepared fish products
• B.21.021 - Preserved fish products

Section 25.(1) (canned fish) and section 26.(1) (other than canned fish) of the Fish Inspection Regulations (FIR) require a common name on the main panel of the label of fish products. This common name must incorporate the name of the species in accordance with the CFIA Fish List.

The use of generic names such as "fish fillets", "fish portions" is not permitted. A name of the species is always required to be incorporated into the common name, for example "haddock fillets", "cod portions".

Because the species of Pacific salmon have different market values, the name "Pacific Salmon" is not included as an acceptable common name in the Fish List. Therefore, 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 not as a replacement for the common name.

Examples:

• When a package of Pacific salmon fillets contains more than one species, all the species names must be included in the common name in descending order by their weight in the package, for example "chum and pink salmon fillets".
• When a package of Pacific salmon fillets contains only one species, and this species may vary throughout the year depending on the availability, the name of the species actually contained in the package must be always included in the common name.
• When a package of Pacific salmon fillets contains more than one species or a single species depending on the availability, a name of the species (one or more) contained in the package must be included in the common name.

The Canadian Food Inspection Agency (CFIA) will not object to the use of one label for all Pacific salmon species that may be contained in the package, provided that all the species are declared on the main panel in bold letters of the minimum height of 3.2 mm, and the species actually contained in the package are properly identified.

Example:

When three species of Pacific salmon may be used but only Chum salmon and Pink salmon are contained in the package:

The common name requirements outlined above do not apply to unstandardized fish products. Unstandardized products are those for which no composition standard has been prescribed in Division 21 of the Food and Drug Regulations. For example, fish burgers made from various species of Pacific salmon can be labelled "Pacific salmon burgers" with the actual species present in the burgers declared in the list of ingredients. The use of and/or declaration of the species is permitted.

You are also reminded that the addition of any additive or ingredient to fish fillets or portions, including Pacific salmon fillets or portions, triggers the requirement for the presence of Nutrition Facts Table(s) on the label for each species present in the package.

A grace period of 6 months from the day of publication of this Industry Notice, or the next printing of labels in the establishment (whichever occurs first) will be provided to industry to bring labels to compliance with the requirements outlined above. Non compliance to the above regulatory requirements after the specified grace period may result in the application of enforcement measures by the CFIA such as product detention and possibly more stringent action such as product seizure and or prosecution.

You may contact the CFIA office in your area for further clarification and/or assistance.

Sincerely,

Terence McRae
Director
Fish, Seafood and Production Division
Canadian Food Inspection Agency