Finfish which has been processed and is ready-to-eat

​Ready to eat processed finfish

Back to Tests applied to risk food

Reference FSH 10/2016

All imported food must comply with Australia’s biosecurity import conditions.

Check the Biosecurity Import Conditions system (BICON) to determine if the food you intend to import requires an import permit or a treatment or if it must meet any other conditions. All biosecurity requirements must be met before Imported Food Inspection Scheme requirements apply.

Imported Food Inspection Scheme risk food

Processed ready-to-eat finfish (RTE finfish) for human consumption is classified as a risk food for Listeria monocytogenes. The RTE finfish may be whole or in portions. Processed includes:

  • cooked
  • smoked
  • smoke flavoured
  • vacuum packed.

Food excluded from inspection and analysis as a risk food

Examples of food that would not be considered a risk classified food for this hazard include:

  • dried fish
  • pickled fish
  • salted fish
  • fermented fish
  • raw fish for sashimi or sushi
  • fish roe
  • caviar
  • shark fin
  • food containing ready to eat processed finfish as an ingredient such as seafood extender and surimi
  • retorted— the final product is in a hermetically sealed (airtight) container and has been heat treated (retorted) within this container so that the final product is shelf stable (not requiring refrigeration).

Applicable standards

There are two standards that apply to RTE finfish that is classified as risk food (see the Clearance section below). 

From 2 November 2016, brokers will be asked two new lodgement questions to enable the department to determine which Listeria monocytogenes standard to apply to RTE finfish.

Lodgement question 1:

‘ARE THE GOODS READY TO EAT WITHOUT FURTHER PROCESSING (EG COOKING) AND NOT CANNED, BOTTLED, FERMENTED, PICKLED OR RETORTED; AND A FOOD IN WHICH GROWTH OF LISTERIA MONOCYTOGENES CAN OCCUR ACCORDING TO THE DEPARTMENT’S CRITERIA? GO TO WWW.AGRICULTURE.GOV.AU/IMPORT/GOODS/FOOD/INSPECTION-COMPLIANCE/RISK-FOOD/RTEFINFISH’

Lodgement question 2:​

‘ARE THE GOODS READY TO EAT WITHOUT FURTHER PROCESSING (EG COOKING) AND NOT CANNED, BOTTLED, FERMENTED, PICKLED OR RETORTED; AND A FOOD IN WHICH GROWTH OF LISTERIA MONOCYTOGENES WILL NOT OCCUR ACCORDING TO THE DEPARTMENT’S CRITERIA? GO TO WWW.AGRICULTURE.GOV.AU/IMPORT/GOODS/FOOD/INSPECTION-COMPLIANCE/RISK-FOOD/RTEFINFISH’

Answering ‘No’ to both these questions will mean that the finfish will not be referred as a risk food.

Answering ‘No’ to the first question and ‘Yes’ to the second question will mean that the RTE finfish will be referred as risk food and the L. monocytogenes standard of 100 cfu/g in five samples will apply. (See the ‘Clearance’ section below).

Answering ‘Yes’ to the first question and ‘No’ to the second question will mean that the RTE finfish will be referred as a risk food and a standard of no detectable L. monocytogenes in five 25 g samples will apply (See the ‘Clearance’ section below).

Food in which growth of Listeria monocytogenes will not occur

To assist brokers in answering the lodgement questions, the department’s criteria are that RTE finfish in which growth of L. monocytogenes will not occur is food that has one or more of the following parameters:

  • the food has a pH less than 4.4 regardless of water activity, or
  • the food has a water activity less than 0.92 regardless of pH, or
  • the food has a pH less than 5.0 in combination with a water activity of less than 0.94, or
  • the food is frozen and will be either consumed frozen or consumed within five days of being thawed, or
  • the food is not frozen and has a refrigerated shelf life not greater than 5 days (from date of manufacture to the use-by date on the label of the fish).

In addition, the department’s criteria include that RTE finfish is food in which growth of L. monocytogenes will not occur if:

  • it can be validated that the level of L. monocytogenes will not increase by greater than 0.5 log cfu/g over the food’s stated shelf life, or
  • it can be validated that the level of L. monocytogenes will not exceed 100 cfu/g within the food’s stated shelf life. This option only applies to finfish that has not received a listericidal* process during manufacture eg. cold smoked salmon.

*A listericidal process is a process that reduces L. monocytogenes microorganisms in the food to a safe level.

The department expects that importers/brokers maintain records of the information used to justify answers to lodgment questions. Consignment specific information may not be necessary if the importer has documentation that the manufacturing process produces food that always meets one or more of the above criteria. The department may require that importers present this information upon request for compliance or verification activities.

Clearance

RTE finfish that meets the department’s criteria for a food in which the growth of L. monocytogenes will NOT occur, will be cleared where:

Listeria monocytogenes
n = 5, c = 0, m = 100 cfu/g

where:
n = the minimum number of sample units which must be examined from a lot of food,
c = the maximum allowable number of defective sample units,
m = the acceptable microbiological level in a sample unit.

RTE finfish that meets the department’s criteria for a food in which the growth of L. monocytogenes can occur, or where no information is available, will be cleared where:

Listeria monocytogenes
n = 5, c = 0, m = not detected* in 25g,

* the department allows appointed analysts to composite the five RTE finfish samples when the ‘not detected’ standard applies. This may result in reduced testing costs for importers. Importers may request a review of a decision within the legislated timeframe for such reviews. If such a review requires re-sampling and re-analysis of samples (for example, for assessment against the other of the two standards) then this will occur at the importer’s expense. A non-compliant result, on its own, is not justification for a review or re-analysis.

Imports from New Zealand

Imports of this food from New Zealand will not be inspected or analysed under the Imported Food Inspection Scheme. This is because Australia and New Zealand have agreed to mutual recognition for the food safety controls for this food.

Additional information

Background information relating to the department’s requirements is available from the following sources:

Standard 1.6.1 and the ready to eat foods requirements in Schedule 27—4 of the Australia New Zealand Food Standards Code,

  • legislation.gov.au/Series/F2015L00411
  • legislation.gov.au/Series/F2015L00453

Version history

Date

Amendment details

12/10/2016

FSH 10/2016

Updated requirements following risk advice provided to the department by FSANZ

1/5/2014

FSH 05/2014

Replaces Imported Food Notice 09/12 Tests applied to risk category foods

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