CFIA Fish Species Sampling Activity

Objective

The fish species sampling activity was conducted to provide a snapshot of the compliance rate of fish species labelling occurring in Canada at the import, retail-packed and federally registered processors levels.

Background

The Canadian Food Inspection Agency (CFIA) is responsible for the enforcement of the Fish Inspection Act and Regulations, the Food and Drugs Act and Regulations and the Consumer Packaging and Labelling Act and Regulations. Under these Acts and Regulations, inspectors have the authority to verify that the labelling requirements on fish and fish products are being met, including a common name that is truthful and not misleading.

The CFIA has historically conducted fish species sampling activities in both the federally registered sector and the non-federally registered sector, either based on complaints, or as part of planned sampling, or to verify inspection observations and continues to do so.

Over the past years, a number of scientific reports in Canada and the US have brought attention of mislabelled fish species. Several scientific studies on seafood substitution and misrepresentation in Canada and the US have been conducted, showing non-compliance rates over 18%Footnote 1, Footnote 2,Footnote 3.

As part of its consumer protection mandate, the CFIA performs:

  • Regular inspection activities at import, processing and retail
  • Inspections in response to complaints from consumers and industry
  • Testing of products, including DNA based species identification (ID) testing

The CFIA works closely with the food industry to promote compliance and provides various tools, such as the CFIA fish list and industry labelling tool, to help companies ensure that their food labels meet all the regulatory requirements.

Sampling Activity

As part of the Canadian Food Inspection Agency's (CFIA) routine testing of various food products, the CFIA conducted a sampling and testing blitz to identify fish in the marketplace potentially misrepresented as another species on the label.

From November 2013 to March 2014, the CFIA tested 114 fish product samples from federally licensed importers and federally registered processors across Canada, as well as from retail stores in greater metropolitan areas such as Vancouver, Toronto and Halifax. Retail sampling in Quebec was conducted by the Ministère de l'Agriculture, Pêcheries et l'Alimentation du Québec (MAPAQ) as part of a separate action plan.

In the 114 fish samples, 35 different species of fish were sampled including, tuna, salmon, halibut and snapper.

Samples were tested at the CFIA laboratories using DNA analysis to compare the sample to the declared common name on the label. The CFIA Fish List was used as a reference to determine if the common name on the label was representative of the species tested.

Sampling Results

The sampling activity found that 94 per cent of fish tested used the appropriate common name.

Below is a table with the compliance rates per sector.

Compliance by Sector
Sector Number of Samples Tested Number of Non-Compliant Samples Compliance
Domestic 16 0 100%
Imported 45 2 96%
Retail 53 5 91%
Total 114 7 94%

Of 114 fish products tested, a total of 7 samples of fish products were found to be using improper common names (6%). Incorrectly identified species included: snapper (2), Pacific cod, halibut, hake, conger eel and blue shark.

Fish products with four or more samples tested:

27 of 28 Cod (Atlantic or Pacific) samples were compliant
15 of 15 Atlantic Salmon samples were compliant
12 of 12 Haddock samples were compliant
7 of 8 Halibut samples were compliant
8 of 8 Pacific Salmon (Sockeye, Chinook, Chum, or Pink) samples were compliant
7 of 7 Tuna samples were compliant
4 of 4 Black Cod/Sablefish samples were compliant
2 of 4 Snapper samples were compliant

Fish products with less than four samples tested include:

Patagonian Toothfish (3 of 3), Alaska Pollock (2 of 2), Blue Marlin (2 of 2), Canadian Plaice (2 of 2), Hake (1 of 2), Lingcod (2 of 2), Turbot (2 of 2), Amberjack (1 of 1), Arctic Char (1 of 1), Blue Shark (0 of 1), Butterfish (1 of 1), Conger Eel (0 of 1), Escolar (1 of 1), Flying Fish (1 of 1), Grouper (1 of 1), Mackerel (1 of 1), Parrot Fish (1 of 1), Sole (1 of 1), Spanish Mackerel (1 of 1) and Swordfish (1 of 1).

Enforcement Actions Taken

The CFIA followed up on all non-compliant samples and took appropriate enforcement actions, ranging from relabelling and retailer education to placing foreign packers on the mandatory inspection list.

  • These actions were taken in accordance with CFIA's regular enforcement and compliance activities and considered the harm, history and intent of the non-compliant company.
  • Additional enforcement actions for fish species substitution and misrepresentation can also include suspension/cancellation of license/registration and prosecution, as required.

Next Steps

The CFIA will continue to conduct testing for fish species substitution and misrepresentation in line with Agency priorities. Monitoring will be geared towards species and sectors most at risk. The CFIA will continue to respond to and follow up with complaints regarding fish species substitution and misrepresentation and may look to conduct another blitz in the future.

The CFIA is working closely with industry stakeholders to increase education on fish labelling requirements and promote compliance. The CFIA is engaging industry stakeholders and looking for opportunities to assist industry in developing and implementing strategies to address this issue.

Appendix A - Sampling Activity Results by Area

Atlantic
Sector Compliance Number of Non-compliant Samples
Importer 100% 0
Domestic 100% 0
Retail 95% 1
Total 97% 1
Quebec
Sector Compliance Number of Non-compliant Samples
Importer 100% 0
Domestic 100% 0
RetailTable Note 1 N/A N/A
Total 100% 0

Table Notes

Table Note 1

Retail sampling in Quebec was conducted by the Ministère de l'Agriculture, Pêcheries et l'Alimentation du Québec (MAPAQ) as part of a separate action plan.

Return to table note 1 referrer

Ontario
Sector Compliance Number of Non-compliant Samples
Importer 93% 1
Domestic 100% 0
Retail 83% 2
Total 91% 3
West (Saskatchewan, Alberta, British Columbia)
Sector Compliance Number of Non-compliant Samples
Importer 89% 1
Domestic N/A 0
Retail 89% 2
Total 89% 3

Appendix B - Sampling by Common Name

Declared Common Name Number of Samples Area Sector Compliance
Atlantic Salmon 15 Atlantic, Quebec, Ontario Domestic, Imported, Retail 100%
Haddock 12 Atlantic, Quebec, Ontario, West Domestic, Imported, Retail 100%
Atlantic Cod 11 Atlantic, Quebec, Ontario Domestic, Imported, Retail 100%
Cod 10 Atlantic, Ontario, West Domestic, Retail 100%
Halibut 8 Atlantic, Ontario, West Domestic, Retail 88%
Pacific Cod 7 Atlantic, Quebec, Ontario Imported, Retail 86%
Tuna 7 Quebec, Ontario, West Imported, Retail 100%
Sockeye Salmon 5 Quebec, West Imported, Retail 100%
Black Cod/ Sablefish 4 West Imported, Retail 100%
Patagonian Toothfish 3 Quebec, Ontario Imported 100%
Hake 2 Atlantic, Quebec Domestic, Retail 50%
Lingcod 2 West Retail 100%
Blue Marlin 2 Quebec, Ontario Imported 100%
Canadian Plaice 2 Quebec Domestic 100%
Alaska Pollock 2 Atlantic Imported 100%
Beeliner/Vermillion Snapper 2 Ontario Domestic 100%
Turbot 2 Quebec Domestic 100%
Amberjack 1 West Imported 100%
Butterfish 1 Ontario Retail 100%
Arctic Char 1 Quebec Domestic 100%
Conger Eel 1 Ontario Imported 0%
Escolar 1 West Imported 100%
Flying Fish 1 Ontario Imported 100%
Grouper 1 Ontario Retail 100%
Mackerel 1 Atlantic Retail 100%
Parrot Fish 1 Ontario Imported 100%
Red Snapper 1 West Retail 0%
Chinook Salmon 1 West Retail 100%
Chum Salmon 1 West Imported 100%
Pink Salmon 1 Ontario Imported 100%
Blue Shark 1 West Imported 0%
Snapper 1 West Retail 0%
Sole 1 West Retail 100%
Spanish Mackerel 1 Ontario Imported 100%
Swordfish 1 Ontario Imported 100%
TOTAL 114
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