CURRENT ISSUES RELEVANT TO THE AUSTRALIAN SEAFOOD INDUSTRY
Below are a list of issues currently under discussion at Codex and other International forums that are relevant to the Australian Seafood Industry. SafeFish welcomes any technical advice, comments or input around these issues. A comprehensive report that contains more detailed information on these issues is compiled by SafeFish every quarter, to access the most recent report please click here.
Issues under discussion at Codex
- Calanus oil - Inclusion in fish oil standard
- Dflubenzuron - Proposed Maximum Residue Limit (MRL) in Salmon
- Canned Sardines - Proposal to include Sardinella lemuru in list of approved species
- Histamine - Update on sampling plans and harmonisation of Histamine control guidance
- Methylmercury - Sampling plans and maximum levels in other species
- Ciguatoxins - Ad-Hoc FAO/WHO expert meeting on Ciguatera
- Lead - Discussions on Maximum levels of lead in seafood
- Food Fraud - Now on the Codex agenda
Issues under discussion at other International standard setting forums
- China SPS - Food Safety Standards Administration Measures
- Korean SPS - New MLs and updated MRL for Ethoxyquin in fish
- Korean SPS - Revised maximum residual limits for antimicrobials in fishery products
- Korean SPS - Reviesed limit for cadmium in squids
Inclusion of Calanus oil in fish oil standard
A proposal for Calanus oil (derived from Calanus finmarchicus) to be listed as a named fish oil in Codex Standard for Fish oil (CXS 329-2017) is under consideration by the Codex Committee on Fats and Oils. The main lipid class in Calanus oil is wax ester. The proposal to include Calanus oil as a named fish oil will reduce trade impediments and help governments in assessing the quality and the barriers and/or rejection of the product at the trade borders, and help manufacturers and traders documenting product authenticity and traceability. It is anticipated that the proposal could be adopted in 2025.
More information on the proposal is available by contacting the SafeFish Secretariat at email@example.com. Comments due by 20 August 2021
Diflubenzuron MRL in salmon
In July 2021, the Codex Committee on Residues of Veterinary Drugs in Foods (CCRVDF) agreed to forward the proposed maximum residue limit (MRL) for diflubenzuron in salmon of 10μg/kg in muscle plus skin in natural proportions for adoption by Codex Alimentarius Commission later this year. This proposed MRL follows a recent JECFA (Joint FAO/WHO Expert Committee on Food Additives) recommendation. FSANZ currently has a temporary MRL for diflubenzuron in fish muscle of 2µg/kg.
Canned Sardines – Proposal to include Sardinella lemuru in list of approved species
In March 2020 the Philippines submitted a proposal to the Codex Secretariat to amend the Standard for Canned Sardines and Sardine-Type Products (CXS 94-1981) to include Sardinella lemuru (Bali Sardinella) in the list of Sardinella species. In late 2020 Codex Alimentarius Commission approved that the Codex Committee on Fish and Fishery Products (CCFFP) be reactivated to work by correspondence to evaluate if the Standard can be amended to include S. lemuru. The Australian delegate requested to be part of the electronic working group. The eWG will decide upon the three species for comparison with the S. lemuru and the three laboratories for sensory evaluation. The EWG will oversee the sensory evaluation and inform CCFFP if the S. lemuru satisfies the requirements for inclusion in the standard. A report from the EWG is expected by 01 September 2021.
Histamine – Update on sampling plans and harmonisation of Histamine control guidance
In July 2019, the 42nd Session of the Codex Alimentarius Commission (CAC42) adopted the amendments made by the 50th Session of the Codex Commission on Food Hygiene (CCFH50) to the Code of Practice for Fish and Fishery Products (CXC 52-2003) to align with the recently established guidance for histamine control. The histamine control guidance has been published as Section 10 of the Code of Practice for Fish and Fishery Products (CXC 52-2003).
In November 2018, CCFH50 agreed to postpone the development of histamine sampling plan in the eleven commodity standards for fish and fishery products as many delegations expressed differing views. The development of sampling plans will likely be reviewed in a few years’ time when more date is available and the Codex Committee on Methods of Analysis and Sampling (CCMAS) may have revised the General Guidelines on Sampling (CXG 50-2004). The implications are that:
- The current Codex health-based safety limit for histamine of 200 mg/kg in any sample tested will remain (400 mg/kg for fish sauce).
- The current Codex histamine decomposition (quality) limit of 100 mg/kg based on the average (mean) of sample units tested will also remain
In May 2019, the Codex Committee on Contaminants in Foods (CCCF) agreed to re-establish an Electronic Working Group (EWG) to revise the discussion paper on proceeding with the establishment of maximum levels (MLs) for methyl-mercury in additional fish species and to develop sampling plans. Throughout the development of this work, SafeFish assisted in the upload of Australian methyl-mercury and total mercury data to the GEMS/Food database, and prepared formal technical submissions providing comments on the discussion papers produced by the EWG to Codex Australia in September and February 2020, and March 2021. SafeFish has also continued to advocate that prior to any MLs being established the contaminant needs to be present in amounts that are significant for total exposure and that sampling plans, if developed, should be practical and feasible whilst ensuring food safety using a risk-benefit based approach.
In May 2021, the CCCF14 committee agreed to progress establishing MLs for methyl-mercury in Orange Roughy and Pink Cusk-eel and to request that JECFA (Joint FAO/WHO Expert Committee on Food Additives) issue a call for more data specific for Patagonian Toothfish. The Committee agreed to discontinue the development of MLs for methyl-mercury in all other additional fish species. The Committee will also continue to progress sampling plans for methyl-mercury to ensure their practicality and a literature review will be undertaken to consider the possibility of developing a new guidance document for risk management of methyl-mercury in fish. The FAO/WHO will also be convening an expert meeting to update the risk/benefit of fish consumption and as part of this would consider if there is sufficient evidence to support how selenium-mercury complexes impact toxicity.
On 19-23 November 2018, the Food and Agriculture Organization of the United Nations (FAO) and World Health Organization (WHO) held an expert meeting to develop scientific advice in response to a request from the 11th Session of the Codex Committee on Contaminants in Foods (CCCF11). In particular, the requested scientific advice to FAO/WHO entailed a full evaluation of known ciguatoxins (toxicological assessment and exposure assessment), including geographic distribution and rate of illness; congeners; methods of detection; and based on this, guidance for the development of risk management options. Click here to access the report.
Lead - Maximum levels in Seafood
In 2010 JECFA (Joint FAO/WHO Expert Committee on Food Additives) identified that there is no safe level of lead and withdrew the previous provisional tolerable weekly intake (PTWI). Since then Codex Committee on Contaminants in Foods (CCCF) have been reviewing and revising the maximum levels (MLs) for lead in the General Standard for Contaminants and Toxins in Food and Feed (CXS 193-1995). In March 2018 the 12th Session of CCCF reviewed and agreed to maintain the current maximum level (ML) for lead in fish at 0.3mg/kg. The FSANZ 25th Total Diet Survey that concluded that dietary exposure to lead for most Australian consumers are likely at ALARA (as low as reasonable achievable) levels.
In 2018/19 CCCF developed a potential work program to consider establishing MLs for lead in foods not included in the General Standard for Contaminants and Toxins in Food and Feed (CXS 193-1995). This work program included seafood (crustaceans, molluscs and cephalopods) and processed fish (excluding frozen and sliced). A range of hypothetical MLs for lead were included in a Codex discussion paper. In May 2019, in view of workload, the 13th Session of CCCF agreed not to currently proceed with considering the establishment of MLs in seafood and processed fish.
Food Fraud - Now on the Codex agenda
The Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS) have established an eWG to further consider the role of CCFICS with respect to tackling the challenge of food fraud in the context of food safety and fair practices in the food trade. Alexandra McLaren (Department of Agriculture) is leading the Australian position on the Food Fraud eWG. SafeFish will maintain a watching brief and may input into the development of Australia’s position.
SPS Notification - China Notifies of Food Safety Standard Administration Measures
In May 2020, The National Health Commission of the People's Republic of China (NHC) issued the following SPS Notifications (CHN1150; CHN1151; CHN1152; and CHN1153) that proposed amendments to the following existing standards:
- GB 2762-2017 - Maximum Levels of Contaminants in Foods
- GB 29921-2013 – Pathogenic Microorganism Limits in Food
- GB 7718-2011 - General Principles for the Labelling of Pre-packaged Foods
- GB 29921-XXXX – Pathogen limits for ready-to-eat food in bulk (NEW STANDARD)
A comparison of the maximum levels of contaminants in food and microorganism limits in pre-packaged foods has been made based on a SafeFish unofficial translation of the GB Standards and can be found here. It has also been determined from the unofficial translation that the main proposed changes for fish and fishery products are as follows:
- Aligning the MLs for methyl-mercury in tuna, marlin, shark, alfonsino to Codex.
- Current maximum levels for methyl-mercury remain for all other aquatic animals and their products
- Reduction of PCBs in all aquatic products
- Removal of Staphylococcus aureus limits in pre-packaged foods -Inclusion of Listeria monocytogenes limits in raw ready-to-eat aquatic products
Comments are currently welcome from the seafood Industry on if these proposed changes will have any potential impacts. Please contact the SafeFish secretariat to highlight any concerns.
SPS Notification - New MLs and updated MRL for Ethoxyquin in fish
In July 2019, the Republic of Korea released Notice No 2019-57 to advise that it has revised its Food Code to include the scientific names of five pufferfish and has added a maximum residue limit of ethoxyquin of 1.0 mg/kg in fish and 0.2 mg/kg in crustaceans. It has also stipulated new testing methods of residue limits for aquatic products. The changes came into effect the 3rd of July 2019. In May 2019 the Republic of Korea issued a SPS notification (G/SPS/N/KOR/639) to change the Korean Standard for Food Additives, including the standards for the use of sodium metabisulfite, potassium metabisulfite, sulfur dioxide, sodium bisulfite, sodium sulfite, sodium hydrosulfite. SafeFish reviewed export data to Korea and sought to see if the Department of Agriculture and Water Resources would get it translated into English. Only very small volumes of dried or frozen abalone were exported to South Korea in 2018.
SPS Notification - Revised maximum residual limits for antimicrobials in fishery products
On 09 January 2020, the Republic of Korea issued a SPS notification (KOR673) that included their intention to review the maximum residual limit (MRL) of antimicrobials in fishery products. The notification is in Korean. An unofficial translation suggests that the limit of detection for veterinary drugs without established Korean MRLs will be reduced from 0.03 mg/kg to 0.01 mg/kg. No adoption date for these proposed changes has been announced. Current Korean MRLs for pesticides and veterinary drugs can be obtained from http://www.foodsafetykorea.go.kr/residue/main.do. If there are any concerns, or you want more information please contact the Secretariat.
SPS Notification - Revised limit for cadmium in squids
On 01 October 2019, the Republic of Korea issued a SPS notification (KOR665) that included their intention to revise the maximum level (ML) for cadmium in squid from 2.0mg/kg to 1.5mg/kg. The ML for cadmium in all other molluscs are to remain at 2.0mg/kg, excluding octopus (with viscera) that has a ML for cadmium of 3.0mg/kg. The amended provisions are expected to come into force on 1 March 2020.