Product standards guideline - fish exports

Product testing assesses the performance of an export registered establishment’s food management system (Approved Arrangement) in producing compliant fish and fish products. A regular program of product testing provides the Australian Government with a level of assurance, which allows them to issue export health certification. See the departments website for more information on registration, Approved Arrangements and government export health certification.

Where the importing country has a different food standard to Australia, establishments must demonstrate compliance with this standard for all fish intended for export to that market.

This guideline mandates minimum testing requirements for some fish and fish products. Additional product testing may be required to verify that controls documented in your Approved Arrangement (AA) are effective in producing compliant fish and fish products. Accurate product descriptions and thorough hazard analysis of all product lines for the potential presence of contaminants, natural toxicants (for example, ciguatoxin) and residues will assist in determining where additional product testing is required to verify the adequacy of your AA.

Additional testing may also be required:

• when food additives that may have regulated limits are used (for example, sulphur dioxide in crustacea)
• to verify that product complies with the relevant regulatory levels as detailed in the Australian New Zealand Food Standards Code (FSC) or as set by importing country authorities
• to verify that action taken to address non-compliance has been effective
• to verify that a specific shipment meets importing country requirements
• as a result of sanctions.

Minimum testing requirements for export to the EU are provided at Appendix A. Known requirements of other importing countries can be found in the Manual of Importing Country Requirements (Micor).

Under Australia’s export legislation a registered establishment must notify the department when product has been found to be or is suspected of being unsafe and an export permit has been issued. Procedures for this must be covered in the export registered establishment’s Approved Arrangement.

The minimum testing required for export is outlined in Tables 1 to 4. Table 1 outlines specific testing for contamination that may occur before harvest (sourcing requirements). Tables 2 to 4 outline specific testing for contamination that may occur post-harvest and during manufacture (Hazard Analysis Critical Control Point (HACCP) verification).

The testing requirements can be integrated into other testing that the establishment undertakes for domestic or commercial arrangements.

Who conducts testing?

If required by an importing country or if declarations relating to test results are required on certification, all testing must be carried out in a National Association of Testing Authorities (NATA) or International Accreditation New Zealand (IANZ) accredited laboratory. If not required for these purposes, testing can be conducted in-house or at non-NATA-accredited laboratories.

What testing methods can be used?

Alternate test methods are permitted for sourcing and HACCP verification in Tables 1, 3 and 4 only where the laboratory has determined equivalence to the test methods prescribed by the FSC (if one is prescribed), but may not be allowable for confirming specific declarations on certification.

Chemical and micro testing notes

The FSC (Standard 1.1.1) requires that foods comply with the prescribed microbiological limits at any stage of their manufacture or sale. Consideration should be given to sampling product at intervals that can verify shelf life and where ‘use by’ labelling is applied to packaging.

Testing may be minimised for certain environmental or sourcing hazards where valid technical data can be provided that supports the likelihood that fish taken from particular areas will contain levels of environmental contaminants within acceptable limits. For example, data from the departments Fisheries Branch or National Residue Survey can be used to reduce the minimum testing tabled in this document on a case-by-case basis after consultation with the Dairy, Egg and Fish Export Program.

Where the test is a presence/absence test for a specific food pathogen, the testing laboratory may composite the sub-samples and conduct one test. You should discuss your product testing needs with the laboratory before sending samples for analysis.

Antibiotic testing

Documented evidence of nil use of antibiotics, including in feed, may be used to justify minimum testing of one sample per year per supplier for antibiotic testing of product. National test results for antibiotics can be substituted for this test (if they are within 12 months) or where the supplier provides laboratory test results.

Tables 1 to 4 detail fish products that require testing, according to risk, and provides corresponding minimum testing frequencies.

Table 1 Testing requirements to verify the source of fish and fish products

^a A ‘lot’ is declared as a quantity of processed food of the same type, processed or packed under essentially the same conditions, during a particular period of time (not generally exceeding 24 hours) and usually from a particular processing or packing line. For shellfish, a ‘lot’ means a single species of shellfish harvested from a particular harvest area and designated by a single harvest record number.

The frequency for testing of fish products will depend on whether the establishment prepares the product types detailed and the intended use of these products.

Table 2 Frequency of testing for product types specified in Tables 3 and 4

Table 3 Minimum testing regime of fish and fish products to verify HACCP—microbiological

^c The maximum allowable number of defective sample units. m The acceptable microbiological level in a sample unit. M The level that when exceeded in one or more samples would cause the lot to be rejected.

Table 4 Minimum testing regime of fish and fish products to verify HACCP—other standards

Table 5 Biotoxin and contaminants testing for the European Union

Table 6 Microbiological criteria for the European Union

^c The maximum allowable number of defective sample units. m The acceptable microbiological level in a sample unit. M The level that when exceeded in one or more samples would cause the lot to be rejected.

Table 7 Process hygiene criteria for the European Union

^c The maximum allowable number of defective sample units. m The acceptable microbiological level in a sample unit. M The level that when exceeded in one or more samples would cause the lot to be rejected.

The information in this appendix is from Commission Regulation No. 853/2004 laying down the specific hygiene rules for food of animal origin; Commission Directive No 22/2001 laying down the sampling methods and the methods of analysis for the official control of the levels of lead, cadmium, mercury and 3-MCPD in foodstuffs; and Commission Regulation No 2073/2005 on microbiological criteria for foodstuff. Commission Regulation No. 2074/2005, 1664/2006 and 15/2011 are also referenced. Commission Regulations and directives are available from the European Union’s official website.

Information on EU requirements for additives and flavourings is available from the EU Foods system application.

• Approved Arrangements and registration
• EU Commission Regulations
• EU Foods system application
• Export Documentation system (EXDOC)
• Department of Agriculture, Water and the Environment Charging guidelines
• Export legislation
• Manual of Importing Country Requirements (Micor)

The department’s website has further information on:

• Approved Arrangements
• becoming export registered
• department audit regime
• government issued export permits and certificates.