Export Market Requirements

EU

Establishments that export fishery products to EU shall comply with general hygiene requirements in Regulation (EC) 852/2004 and specific hygiene requirements in Regulation (EC) 853/2004.  Annex II section IV on of Regulation (EC) 853/2004 have specific requirements on labeling of frozen fishery products and Annex III section VIII provide specific hygiene criteria for production of on fishery products, including specific hygiene requirements to primary production, i.e. fishing vessels and landing sites and processing of fishery products.

In addition to the general and specific hygiene criteria that apply to the business operators, the following EU legislation have most important requirements to for fishery products intended for export to EU:

  • Microbial criteria in Regulation (EC) 2073/2005: Download – July 2018
  • Maximum Levels of environmental contaminants in Regulation (EC) 1881/2006: Download July 2018
  • Use of food additives in Regulation (EC) 1333/2008 (Link to Database )
  • Labeling of products to final consumer in Regulation (EC) 1169/2011

Guidelines and clarifications to all the legal requirements can be found on the DG Sante web-site DG SANTE Website  and the latest versions of all the legal documents can be found on EUR-Lex (Simple Guide to identify the EU Legislation).

A general guide on export to EU is available on the EU Trade Helpdesk  EU Trade Helpdesk


Japan

  • Residues and contaminants in fishery products:Regulation for residues of Agricultural Chemicals in Foods, including pesticides and pharmacological active substances of veterinary medicines – The allowed substances and related MRLs can be seen on the Database of Japanese Chemical Research Foundation
    • Environmental Contaminants: See Guidance.
    • Residues of pesticides: Japan accept residues of a number of pesticides in different products of aquatic origin. Information about substances and their MRLs for different groups of products can be found on Database
    • Residues pharmacological active substances from of veterinary medicines: Japan prohibits the residues of certain pharmacological substances in any food including all fishery products Japan Prohibits. Japanese regulation summarized in the context of the Myanmar regulation: See Guidance.
  • Microbiological criteria for fishery products intended for export to Japan:  The standards are issued by the Ministry of Health and Welfare Notification No. 370, 1959 (latest revision: MHLW Notification No.336, 2010) under the title of “Specifications and Standards for Food and Food Additives etc”.  See Guidance
  • Food Additives The Japanese Ministry of Health and Welfare have established regulations regarding the approval and use of additives. Link The information on additives in products intended for export to Japan is published on Japanese Chemical Research Foundation.
  • Guidance on additives allowed in fishery products intended for export to Japan: Guidance
  • Japan External Trade Organization (JETRO) have a general guidance  on export of food to Japan.

US

The establishments that intend to export fishery products to US market shall demonstrate to the importer that they comply with requirements to Good Manufacturing Practices in the US Code of Federal Regulations Title 21 Part 110 (link 21CRF110) and with the specific requirements to HACCP  in the Seafood HACCP Regulation (link: 21CFR123).

The use of additives are in US listed as GRAS (Generally Recognised as Safe) in the US regulation (link: 21CFR182). As such they may be used in accordance with the general principles of §182.1 of 21CFR182. Additives with limited use in specified products are listed in 21CFR171 and additives allowed in rinsing and washing of certain foods are in 21CFR173.

Most valuable guidance to implement the requirements of the US market for fishery products are provided in the document “Fish and Fishery Products Hazards and Controls Guidance” (Link). Annex 5 of this document also provides guidance on microbial and chemical criteria that will be applied by the US authorities at import. See also short Summary of Microbiological and  Chemical criteria.

Fish of the Siluriforms which cover all catfish including among others species of the families Ictalurus, Clariida and Pangasius can currently not be exported from Myanmar to US. This will require specific approval of the Myanmar Authorities and establishments by US Department of Agriculture Food Safety and Inspection Services. Please find further information in Regulation (link) and guidance (link).