Scope
The department has implemented new import conditions for breaded, battered and crumbed (BBC) prawns. Further information is available in Biosecurity Advice Notice 2018-15 and Import Industry Advice Notice 80/2018.
All BBC prawns imported from 28 September 2018 must be certified by the competent authority as having undergone a par-cooking step after the prawns have been coated to solidify and adhere the coating to the prawn. Only product that is deemed sufficiently par-cooked can be imported without testing for white spot syndrome virus (WSSV) and yellow head virus – genotype 1 (YHV1).
- This process is intended to minimise the opportunity for removal of the BBC product coating post border for on-sale as peeled and head-off raw prawns.
- The coating of par-cooked product should appear at least slightly browned and solid, with the coating naturally adhering to the prawn.
- The coating and appearance of the prawn meat during inspection should appear the same as submitted in the original permit assessment documentation.
- Prawn tails (where present) should have a pinkish appearance resulting from the heat applied during the par-cooking process.
- Par-cooking of raw prawn meat and then application of the coating without any further processing will not be accepted.
Product that is deemed not to be sufficiently par-cooked during the import permit application process may only be imported if it meets the import conditions for uncooked peeled prawns outlined within Biosecurity Advice 2017-12. For more information, please refer to our uncooked prawns webpage.
Par-cooking – Import Permit Application Assessment
Information required to support import permit applications for BBC prawns
The ‘prawns for human consumption questionnaire’ contains all information required to support an import permit application for par-cooked BBC prawns. While the questionnaire is not mandatory, it enables a quick and efficient assessment of import permit applications. The questionnaire is also available through Australia’s Biosecurity Import Conditions database (BICON), and should be submitted with your import permit application.
Applications to import uncooked breaded, battered or crumbed prawn products must include the name and address of the importer, manufacturer and exporter, and the following information about the BBC prawn product to be imported:
- The commercial product name (including brand name) as it appears on the product packaging.
- Full list of ingredients including percentage of each ingredient to add up to 100% of the final product weight.
- Detailed description of the production-scale manufacturing process of your proposed BBC prawn product. This can be provided with a processing flow chart or a detailed description of the manufacturing steps of this product. The department has provided guidance material to clarify acceptable par-cooking requirements for breaded, battered or crumbed prawns.
- Three colour photographs of each product - one of the product when frozen, one of the product when thawed, and one of the thawed product with coating separated from the prawn. Photos should be of sufficient size and resolution to clearly represent your product.
- Colour photographs of the packaging in which the finished product will be imported. Photographs should include both the front and back including the details relating to the food preparation instructions. A pdf version of the proposed marketing label will also be accepted.
The application will be assessed on the above information as well as any other criteria deemed relevant by the Delegate of the Director of Biosecurity.
Par-cooking BBC prawns
The department will undertake a detailed assessment of each par-cooked BBC product during the import permit application assessment process. The information must allow the department to establish the following:
- That the manufacturing process is capable of consistently delivering a product that has undergone a par-cooking step (such as pre-frying or baking);
- The par-cooking step is conducted after the prawns have undergone the breaded, battered, or crumbing manufacturing step; and
- The heating time and temperature applied during the par-cooking process.
The department will consider a suitable range of par-cooking methods, including pre-frying and baking. The table below can be used as guidance for specific par-cooking methods. Applicants must be aware that these are examples only and the department will conduct individual assessments on a product by product basis.
Important: These time and temperature combinations are examples only and each BBC product will undergo a thorough assessment by the department as part of the import permit application process to determine if a product is sufficiently par-cooked.
| Prawn size | Pre-fry oil temperature (oC) | Pre-frying time (seconds) |
|---|---|---|
10/15 | 170 – 175 | 65 ± 2 |
16/20 | 170 – 175 | 60 ± 2 |
21/25 | 170 – 175 | 55 ± 2 |
26/30 | 170 – 175 | 52 ± 2 |
31/40 | 170 – 175 | 50 ± 2 |
41/50 | 170 – 175 | 40 ± 2 |
51/60 | 170 – 175 | 30 ± 2 |
Questions and Answers
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What if I do not want to include a par-cooking step for my BBC prawns, or the department finds my product does not meet the BBC import conditions?
If your product does not undergo an acceptable par-cooking process, or if you request to intentionally import your BBC product that is not par-cooked, the department will apply the uncooked prawn conditions to your import permit. Uncooked prawn conditions are outlined within Biosecurity Advice 2017-12.
How will par-cooking be assessed during the import permit application assessment process?
The outcome the department is seeking is that the par-cooking process solidifies and adheres the coating to the prawn. This process is intended to prevent the easy removal of the coating post-border, and therefore minimise the likelihood that BBC prawns could be on-sold as raw uncooked prawns. Par-cooking of raw prawn meat or subsequent application of a coating that has not been par-cooked will not be accepted.
The department will seek photos of the product packaging and prawns in their frozen and thawed state, and of finished product with the coating peeled off. The coating of par-cooked product should appear at least slightly browned, the prawn meat and tails (where present) should have a pinkish appearance resulting from the heat applied during the par-cooking process and raw prawn meat (suitable for sale as a raw product) should not be recoverable after the coating has been removed.
Note that the information provided above on par-cooking times and temperatures to solidify coatings is for guidance only, as import permit applications are assessed on a case-by-case basis.
How will the department undertake border inspections?
The department will continue to subject 100% of uncooked and BBC prawn consignments to secure seals intact inspections. Containers must remain unopened and seals intact. Biosecurity Officers must remove the seals and verify the details of the consignment and the product as part of the inspection process.
Inspectors will use the same criteria as outlined above for import permit assessments to assess consignments at the border.
The department’s inspection procedures may also involve attempts to wash off the coating of thawed product and visual comparisons of the product at the border to the photos and information supplied at the import permit application step to ensure consistency.
My prawns are not par-cooked but they take much longer to ‘wash off’ the coating than other non-legitimate product.
The department has considered these issues and a number of other potential measures carefully. It was deemed that mandating a par-cooking step was the only way to apply consistent requirements for this class of product.
What about fully cooked prawns that are also BBC coated?
The import conditions for cooked product will apply. All protein in the prawn meat must be coagulated and the consignment must be accompanied by a valid health certificate. Coagulation of prawn meat means that it has changed to a solid or semi-solid state with a colour change from translucency to white. Note that cooked prawns are now subject to ongoing randomly selected seals intact inspections, as outlined within the 69-2018 Industry Advice Notice.