Finfish which has been processed and is ready-to-eat (from 8 August 2018)

​​Refer to Imported Food Notice 05-18 for details on recent updates to this web page.

Reference FSH 07/2018

Biosecurity requirements

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

Ready-to-eat processed 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).

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Community Protection (CP) question

From 8 August 2018, the department will replace the existing CP questions for RTE finfish with the following question:

  • ‘IFIS: Are the goods cooked, cured or smoked finfish that require refrigeration (frozen or chilled) and do not require further cooking before consumption? If yes, you have the option to lodge an ‘Imported Food Inspection Scheme–importer declaration for processed ready-to-eat finfish that does not support the growth of Listeria monocytogenes’. Search ‘IFIS Importer declarations’ at agriculture.gov.au for more information.’

The department will monitor the answers to the CP questions. Consistent with the department’s minimum document requirements policy, the department expects that importers and brokers will maintain records of the information used to substantiate answers to CP questions. The department may require brokers and importers to present this information upon request for compliance or verification activities. Giving false or misleading information is a serious offence.

Imported Food Inspection Scheme (IFIS) Importer declaration

From 8 August 2018, the department will introduce an IFIS Importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes. The ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’ is a voluntary declaration that will enable importers to provide information on why the RTE finfish does not support the growth of Listeria monocytogenes.

RTE finfish lodged with this declaration will be analysed against the standard of no more than 100 colony forming units of Listeria monocytogenes per gram.

The ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’ is available from the ‘Lodging declarations and documentation for imported food’ webpage.

The importer declaration is valid for a year from the date it is signed by the importer. Giving false or misleading information in an importer declaration is a serious offence.

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 listericidal1 process during manufacture eg. cold smoked salmon.

1A 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

The table below provides the tests applied and permitted results for RTE finfish based on the combination of the answer provided to the CP question and whether the goods are accompanied by an ‘Imported Food Inspection Scheme – importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’.

CP question
IFIS: Are the goods cooked, cured or smoked finfish that require refrigeration (frozen or chilled) and do not require further cooking before consumption?
IFIS Importer declaration
Are the goods accompanied by an ‘Imported Food Inspection Scheme–importer declaration for ready-to-eat processed finfish that does not support the growth of Listeria monocytogenes’?
Test appliedPermitted result
YesYes Listeria monocytogenesn = 5, c = 0, m = 100 cfu/g
YesNo Listeria monocytogenesn = 5, c = 0, m = not detected1 in 25g
NoN/AThe food will be referred as a ‘surveillance food’ and surveillance tests apply, unless the broker has answered ‘Yes’ to another imported food CP question.

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.
1 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,

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Version history

Date Amendment details
10/07/2018FSH 07/2018Updated to reflect introduction of a voluntary importer declaration
12/10/2016FSH 10/2016Updated requirements following risk advice provided to the department by FSANZ
1/5/2014FSH 05/2014Replaces Imported Food Notice 09/12 Tests applied to risk category foods
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