IFN 12-18 – Border controls for carbon monoxide treatment of tuna and barramundi (amended)

​27 September 2018


The purpose of this notice is to advise importers and brokers about border controls for the inspection and analysis of carbon monoxide (CO) treatment of fresh, chilled or frozen tuna and barramundi fillets, portions and cutlets. The new controls commence on 1 November 2018.

This notice supersedes the previous notice 08/18, issued on 20 July 2018. The notice has been amended to include barramundi.

What has changed?

From the commencement date, the Department of Agriculture and Water Resources will refer imported fresh, chilled or frozen tuna and barramundi fillets, portions and cutlets for inspection and analysis under the Imported Food Inspection Scheme (IFIS) at the surveillance rate of five per cent to assess compliance as per the table below.

Table 1 Documentation and labelling provided, test applied and permitted results
Documentation and labelling providedTest appliedPermitted result
No documentation or labelling indicating the product has been treated directly or indirectly (via a smoking process) with COCarbon monoxide< 200 µg/kg (< 0.2 mg/kg)
If above the permitted result, the product will be failed.
Labelled as having being smokedN/AThe product description must be clearly identified as having being ‘smoked’. If not, the product will be failed.
Labelled as having being treated with CO directly (e.g. by gas flushing)N/AThe product will be failed.


Since 2006, the department has received a number of complaints from industry expressing concern about imports of tuna that have been subjected to carbon monoxide (CO) treatment to fix the colour of the flesh, potentially misleading consumers by masking the age and condition of fish.

In October 2013, Food Standards Australia New Zealand (FSANZ) published a report Proposal P1019 – Carbon Monoxide as a Processing Aid for Fish. Subsequent to the report FSANZ made a variation to Standard 1.3.3 – Processing Aids in the Food Standards Code. The variation clarifies that carbon monoxide must not be used in the processing of fish where its use results in a change to or fixes the colour of the flesh of the fish. The variation also clarifies that this prohibition does not extend to carbon monoxide that is naturally occurring or naturally present in smoke being used to process fish as a food. The report is available on the FSANZ website.

In November 2016, the department published an Imported Food notice, IFN 19-16 – Carbon monoxide treatment of fish, to advise importers of restrictions on the use of carbon monoxide in the processing of fish, and the steps they should take to ensure they only import fish that complies with the Food Standards Code.

To ascertain if there is any evidence that imports of tuna are being treated with CO, the department undertook a small targeted pilot survey. The survey report, ‘Carbon Monoxide in Fish Pilot Survey’, March 2018 is available on the Imported food surveys and reviews webpage. The survey found evidence that tuna available for sale in Australia has been treated with CO, some of which may be imported.

The department has also recently received evidence that imports of barramundi are being treated with carbon monoxide.

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Last reviewed: 4 November 2019
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