“To purchase or not to purchase?”

It is a question every customer confronts when reading a label of a product they want to consume. 

Seafood is an essential part of every diet worldwide. It is rich in proteins and contains Omega-3 fatty acids with various health benefits. When making decisions about buying seafood, consumers need clear and accurate information from seafood labels to suit their dietary needs.

Seafood labels are tied to a string of regulations, requiring manufacturers to provide information such as potential allergens and harvest methods.

This blog post talks about the key aspects of seafood labeling requirements across the globe, highlighting common labeling elements, regional differences, and how to stay compliant.

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Disclaimer: This blog post derives information from the websites of the U.S. Food and Drug Administration (FDA) and other regulatory heads and is updated as of October 4, 2024. Do refer to the respective website for final and updated information regarding regulations. Artwork Flow is a software designed to streamline compliance for brands, not a service providing legal or regulatory advice.

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Importance of seafood labeling

A well-structured and transparent seafood label can help consumers comprehend the label, protect them from the risk of potential allergens and expired products, and inform them of the nutritional information needed to make healthy diet choices. 

Proper seafood labeling can help consumers and also the environment in several ways:

Consumer protection

• Make informed choices: Why do you think pregnant and breastfeeding women avoid fish with high levels of mercury including shark, tuna, and swordfish? Accurate labeling lets consumers learn everything about their potential diet including its harvest method, allergens, the difference between fish and shellfish species, and so on. 
• Prevent allergy: Some may be allergic to shellfish and labeling helps them distinguish various seafood species easily.
• Avoid mislabeling: Proper labeling helps prevent mislabeling, where seafood is falsely represented as a different species or higher quality that can pose a risk to the consumers. For e.g., Expensive swordfish is often substituted by a less expensive mako shark. 
• Ensure food safety: By following all the safety protocols and providing information about potential hazards, you can help prevent the spread of food borne illnesses. 
• Analyze nutrition information: Labeling provides consumers with essential nutritional information, allowing them to make healthy dietary choices. For e.g., Consumers can go for salmon that has less fat.

Sustainability

• Traceability: Labeling can help to trace seafood back to its source, allowing consumers to support sustainable fishing practices.
• Conservation efforts: According to the United States Department of Agriculture (USDA), U.S. consumers are willing to pay more for the eco-labeled canned tuna. By choosing seafood from sustainable sources, consumers can contribute to the conservation of marine ecosystems and protect endangered species. 

Seafood labeling requirements by the FDA

The FDA has established specific seafood labeling requirements to ensure consumers have accurate information about the products they purchase. These requirements cover various aspects of the seafood, including:

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1. Method of production

This shows whether the seafood is "wild-caught" or "farm-raised." This information is crucial for consumers who may have preferences for one method over the other.

2. Name of seafood

The label must clearly state the common and scientific names of the seafood species. This helps consumers identify the exact type of seafood they are purchasing and avoid confusion.The FDA states that seafood products sold in interstate commerce may be labeled with acceptable market names and common names that are not prohibited by law, rule, or regulation.In the case of incorrect use of an acceptable market name, it can lead to mislabeling, which can result in the product being misbranded by the FDA.

3. Inspection label

Your label should have an inspection label issued by a recognized authority, such as the FDA or a state or foreign government inspection agency. This label signifies that the seafood has been inspected for safety and quality.Checking logos or FDA approved labels is easier now with ComplyAI! Using its image rule, you can add your brand or required elements to the rulebook which you can customize and see if the logo matches your requirements.‍

4. Brand

The brand name of the seafood product should be prominently displayed on the label. This helps consumers recognize and identify specific brands or products.

5. Cooking and safe handling instructions

Provide clear and easy-to-follow instructions on cooking and safely handling the seafood in your labels. It includes average cooking time and temperature, refrigeration instructions, and more. This information is essential to prevent food borne illnesses.

6. Nutrition facts and list of ingredients

The label must include a nutrition facts panel that lists the serving size, calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrates, dietary fiber, sugars, protein, vitamin A, vitamin C, calcium, and iron per serving. According to the FDA's labeling laws and regulations, any food product, including seafood products, that contains two or more ingredients must have an ingredient statement that lists each added ingredient by its common or usual name. The ingredients should be listed in descending order of predominance by weight.

7. Location of manufacturer or distributor

Display the location of the manufacturer or distributor on the label. This information is important for consumers who may have questions about the product and could easily trace back to the manufacturer.

Additional requirements

1. Bilingual labels

If there is a presence of any language other than English on the label, then every labeling statement must be presented in both English and the other language. 

2. Counts/size of the product on the package

When labeling shrimp sizes, it is important to indicate a range of the count per pound (e.g., 30-40 shrimp per pound) and specify "count per pound." If a label only shows the count as a range without specifying "count per pound," state regulators may interpret it as a statement of quantity. Using a range instead of a single number for any statement of quantity may be seen as a violation of state labeling laws. If the manufacturer includes a range (such as "21 to 30 shrimp per bag"), the consumer will believe the product contains the exact amount.

Regional variations in seafood labeling

Now that we covered the FDA’s labeling requirements for seafood labeling, let’s dive deep into the seafood labeling regulations elsewhere in the world. 

Remember, while there are some commonalities such as the method of production, country of origin, nutritional facts, and address of the manufacturer in seafood labeling regulations worldwide, there are also notable differences.  

Seafood labeling regulations in Europe

Labeling regulations by the European Commission are way stricter if you want to distribute your fish products among European countries. Again, there are common labeling elements between processed and unprocessed prepacked and non-prepacked seafood products while the former needs additional information. 

The following requirements apply to all unprocessed and some processed products (e.g. salted, smoked products, and cooked shrimps in their shells). These products are prepacked and non-prepacked. 

Required labeling elements	Non-prepacked fish and seafood products	Prepacked fish and seafood products
Commercial designation and scientific names
Method of production
Country and body of water/country of production
Fishing gear
Defrosted
‘Best before’ / ‘Use by’ date
List of ingredients
Quantity of ingredients
Allergens
Net weight
European Union Seller
European approval and lot number
Conditions for storage and use
Nutrition declaration
Name and address of the food business operator
Packaged in a protective atmosphere
Identification mark
Added proteins of different animal origin
Date of first freezing
Added water

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1. Catch area/Country and body of water/country of production: The area where fish are caught at sea is called the FAO area, sub-area, or division. Fish caught in the Northeast Atlantic, Mediterranean, and Black Sea must show the name of the sub-area or division, along with a consumer-friendly name, map, or pictogram. For other areas around the world, only the name of the sea area needs to be displayed.

‍2. Fishing gear: The label must display the fishing gear category used to catch any species here. E.g., seines, gill nets and similar nets, hooks and lines, etc. 

‍3. Defrosted: The consumer should understand from the label whether the product has been defrosted. This information should come with the commercial name in pre-packed products. 

‍4. ‘Best before’/‘Use by’ date: Perishable seafood products should have a ‘use by’ date while non-perishable ones must have a ‘best before’ date on their labels.

5. List of ingredients: The European Union has allotted ‘E numbers’ to the substances added to the food. Remember to include them. 

‍6. Quantity of ingredients: It should be expressed as the percentage of the total net weight.

‍7. Allergens: Allergens must be distinct from the rest of the ingredients. Present it in a typeset such as a font style or background color. When the food name is related to any allergen(s), you don't necessarily have to include it.

‍Want to check your product before things can actually get puffy? Artwork Flow lets you create rules for checking all mandatory warnings and statements at once. The ‘Words or phrases’ rule can be used to add potential allergens that may be present in your seafood product. 

8. Net weight: Net quantity must be displayed in grams or kilograms. If the solid food is in a liquid or frozen form, then you must show the drained net weight as well. 

‍9. European Union Seller: If the business name and address of the manufacturer or seller are established in the European Union, you must include it in the label.

‍10. European approval and lot number: The package must contain the aforementioned E number and lot number, a number assigned to the products belonging to the same batch of an exporter.

‍11. Conditions for storage and use: Include conditions for product use and special storage, if any, on your label. 

‍12. Nutrition declaration: Show the nutrition facts panel and the serving sizes of each nutrient of your seafood products.

‍13. Name and address of the food business operator: Display the name and address of the person responsible for the food information and under whose name the food is marketed.

‍14. Packaged in a protective atmosphere: Add this information to your label if the product was packaged in certain gasses.

‍15. Identification mark: When the product is produced in the European Union (EU), the country name, approval number, and European Community (EC) number, or its translation in other EU languages, must be displayed.

If the products are imported, you only have to show the name of the country and the approval number of the establishment.

16. Added proteins of different animal origins: The name of the seafood must inform the presence of added proteins and their animal origin.

‍17. Date of first freezing: This labeling requirement only applies to unprocessed seafood products. The date format followed for this one is DD/MM/YYYY.

‍18. Added water: You have to display added water among the list of ingredients. If the water is added above 5% in processed fish, include added water in the name of the seafood. E.g., Tuna with added water.

Seafood labeling regulations in Canada

Even though Canada’s fish labeling regulations aren’t as comprehensive as the European Union’s, it has strong regulations to promote sustainable fishing practices, and seafood labels may include sustainability certifications. Fish and fish products are controlled under agencies like:

1. Safe Food for Canadians Act (SFCA)
2. Safe Food for Canadians Regulations (SFCR)
3. Food and Drugs Act (FDA)
4. Food and Drug Regulations (FDR)

For prepackaged foods sold in Canada, the FDA and FDR labeling requirements apply, as do specific requirements under the SFCA and SFCR.If you are distributing seafood in Canada, here are the items you need to include on your label:

• Common name
• Net quantity
• Date marking, storage and handling instructions
• Nutritional labeling
• Name and place of business
• Country of origin
• Grade name, class name, and size designation
• Lot number
• Voluntary claims and statements

Grade name, class name, and size designationAccording to the SFCA, grade name is a prescribed name or designation of a food commodity. The grade name of prepackaged fish must be shown in characters that are at least 3.2 mm in height if the net quantity is 900 g or less.Prepackaged fish that is imported, exported, or sent between provinces must be labeled with any applicable class or size designation. The class name and size designation must be shown in characters that are at least 3.2 mm in height and close to the grade name.

Voluntary claims and statements

1. Light salted: In Canada, light salted fish is seafood that is labeled as such when it contains between 25% and 33% salt by dry weight. 
2. Boneless: Seafood labeling that indicates "boneless" means that the seafood has had its bones removed before being processed. 
3. Method of production claims: Labels can claim the method of production of fish and fish products provided they meet the criteria. Claims include natural claims, feed claims, “raised without the use of added hormones” claims, etc. 

           Reading information on gear used, or processing and handling standards also helps the consumers make an informed decision and also encourages them to go            the sustainable way.

4. Inspection legend: The inspection legend is a label used on fish, meat, and processed egg products in Canada that shows that the product has been prepared and produced under the requirements of the law and is safe to eat. Only an inspector or someone authorized by an inspector can apply the inspection legend at the meat plant where the product was processed or packaged.

Traceability requirements

Traceability requirements for food should support the sustainability of Canada's seafood supply chains and help combat fraud and illegal fishing and consumer abuses. Traceability documents are useful when there is a food safety inspection or a food recall case which could protect consumers’ health and avoid huge company losses.

Seafood labeling regulations in India

In India, the Food Safety and Standards Authority of India (FSSAI) regulates the entire labeling process to safeguard every food and seafood product. India's food labeling standards are generally in line with international standards, but there are some differences in the level of detail required.

The FSSAI mandates the following structure for all food and seafood product labels in India:

1. The name of the food

2. List of ingredients

3. Net contents and drained weight

4. Name and address

5. Country of origin

6. Lot identification

7. Date marking and storage instructions

8. Instructions for use

9. FSSAI license number

10. Allergen declaration

Non-vegetarian logo

The brown non-vegetarian logo is a common symbol used in India to indicate that a food product contains meat or seafood. It's a simple, easily recognizable icon that helps consumers quickly identify non-vegetarian items.

Specific labeling for imported seafood

When a food product is imported into India, the following are necessary:

• Country of origin: The specific country where the seafood was harvested or processed.
• Name and complete address of the importer in India.
• The FSSAI logo and license number issued by the Indian government.

Seafood labeling regulations in Japan

According to Japan's Food Labeling Act, retail packages of imported processed food must include the following information in Japanese:

• Name of the product.

• Country of origin of the finished product.

• Name and address of the importer.

• Ingredients, other than additives, in descending order of weight percentage.

• Food additives in descending order of weight on a separate line from other ingredients.

• The net weight (in metric units only).

• Best-before date.

• Storage instructions.

• Labeling of certain genetically engineered (GE) ingredients as “GE” or “GE non-segregated.”

• Allergen labeling (Food involving shrimp, crab, egg, dairy products, peanut, etc).

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Common seafood labeling errors and ComplyAI's solution

Seafood labeling can be complex and even established companies can make the smallest of mistakes. Such mistakes could lead to legal consequences, hefty fines, and most importantly, customer dissatisfaction. Here are some overlooked seafood labeling errors you should avoid:

1. Mislabeling

Mislabeling is very common in a seafood product where a cheaper fish species is labeled as more expensive or desirable than it actually is. For example, labeling pollock as cod.

2. Missing allergen

Seafood products often contain allergens like shellfish or squid. Failing to list these allergens on the label can pose a serious health risk to consumers with allergies or sensitivities.

3. Spelling and unit errors

Even minor spelling errors can create confusion and affect the credibility of your product. This is especially true for species names, which can be complex and unfamiliar to many consumers.

Also, Errors in calculating nutrient values may occur, leading to inaccurate information on the label.

4. Wrong logo

Using the wrong logo or branding elements can mislead consumers and damage your company's reputation and might get you disbarred from distributing that particular seafood product. It can also lead to legal issues if the incorrect logo is associated with a competitor.

5. Inaccurate nutrient claims

Exaggerated or false claims about nutritional content can deceive consumers and lead to legal issues. For example, claiming that a seafood product is low in fat or high in protein when it doesn't meet those criteria.

7. Harvest method errors

Misrepresenting the harvest method, such as labeling farmed seafood as "wild-caught," can mislead consumers about the product's quality and sustainability.

So, it's essential for seafood producers and retailers to carefully review their labels and ensure they are accurate and compliant with all relevant rules and regulations. Here’s where an AI-powered label compliance software like ComplyAI helps you save your product from costly recalls:

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Also read: Product Recall: How to Save Yourself from the Mess

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1. Smart proofing: Something fishy about your labels? With ComplyAI’s proofing tool, catch typos, incorrect logos, or missing allergen information or domestic address. This saves you a heap of time in reviewing every seafood label.

2. Automated compliance for label regulations: Run label compliance checks using AI with the latest guidelines from the FDA, EU, and other regulators to stay on top of regulatory affairs.

3. Flexible rulebooks: We have read variations among seafood labeling regulations of each region above and we understand how overwhelming it can be with all the rules lying around. With ComplyAI, you can customize your own rulebook and set your grammar, font size, nutritional value preferences, etc and let the tool screen your labels to find any discrepancies.

4. Table rule: If you don’t want to mess with the wrong nutritional value, table rule is your partner. You can create rules here to specifically check the Nutrition Facts table (currently for FDA Guidelines) in a label. Verify the amounts of nutrients, vitamins, and minerals (both in units and percentages) in your label along with their font size and style and ensure they match the intended values.

All in all, ComplyAI is a powerful tool for seafood producers and retailers looking to distribute compliant labels in the market. Apart from ComplyAI, Artwork Flow’s artwork management software streamlines label workflows, automates brand and legal compliance, identifies the latest version of your creative, fast-track product launches, and more. Schedule a demo with us to avoid any shipwrecks!

FAQs

1. What are the regulatory requirements for labeling?

Every product label must have the following:

(i) An identity statement: It is the concise description of the product and reflects the contents of the package.

(ii) A net weight statement: It indicates the total weight of the product, excluding any packaging. A net weight is expressed in both metric and imperial units. 

(iii) A list of ingredients: This lists all the ingredients used in the product, in descending order of weight. It also helps consumers understand the composition of the product and identify potential allergens.

(iv) Company name and address: Company information provides contact details for the manufacturer or distributor.  It helps consumers report issues or seek further information.

2. What is the seafood traceability standard?

The Global Dialogue on Seafood Traceability (GDST) is a project focused on developing universal seafood traceability standards. These standards provide a unique global system for identifying and tracking trade items, assets, logistics, parties, and locations.

‍3. What does "formed fish" mean?

Formed fish in the name of the food applies when the fishery products appear to be made from one piece of fish but are not. E.g., Fish filet.

4. What are the Canada Country of Origin labeling requirements?

If a food product is made entirely outside of Canada, its label must clearly show that it's imported. This can be done by listing,

(i) The Canadian company and the product's country of origin,

(ii) Foreign manufacturer's details, 

(iii) Or simply stating "imported for" or "imported by" followed by the Canadian company's information.

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