B I M G u i d a n c e N o t e F O R R ETA I L E R S

Labelling
Requirements
for Sale of Seafood
1. RAW FISH SOLD LOOSE FROM A WET FISH DISPLAY
This applies to fish to which no other ingredient except • Baltic Sea
salt has been added and includes: live fish, fresh chilled • Central-Eastern Atlantic
and frozen fish, fish fillets and other fish meat (whether • South-East Atlantic
minced or not) dried, salted or brined fish, smoked fish • Mediterranean Sea
(whether hot or cold smoked), crustaceans (except when • Central-Western Atlantic
they are both cooked and peeled), molluscs (except • South-West Atlantic
when cooked). • Indian Ocean
• Pacific Ocean
The species name, production method, origin and
• Antarctic
price should be included on a counter label placed
• Black Sea.
in close proximity to the fish to which it relates.
n For fresh water fish, reference should be made
£ T h ec o m m e r c i a l d e s i g n at i o n to the country of origin.
of the species of fish
The commercial designation is the common
£ Price
name associated with the particular species Price per kilogram or actual selling price.
of fish e.g. the commercial designation for
Gadus morhua is Cod. £ P r e v i o u s ly f r o z e n p r o d u c t s
For products that have been frozen before sale
£ Production method
and which are sold defrosted, the name should be
n For fish produced through aquaculture (farmed accompanied by the word “defrosted”.
species) either the word “farmed” or “cultivated”
must be used. For fish caught at sea, the word £ S c i e n t i f i c name
“caught” should be used. However, if it is obvious
The scientific name of the species must be available
from the commercial designation and/or catch area
to the consumer. This information does not have
that the fish were caught at sea, then the method
to go on the counter label but can be displayed on
of production may be omitted.
a billboard or poster in close proximity to the fish
n For freshwater fish, “caught in fresh water” counter.
must be used.
E x a m p l e s o f a pp r o p r i at e
£ O r i g i n w o r d i n g t h at m ay b e u s e d
n Country of origin for farmed species must be n Salmon, Farmed in Ireland
stated. n Salmon, Cultivated in Scotland
n For fish caught at sea, the origin must be specified n Sea Bass, Farmed in Greece
by reference to one of 12 “catch areas”. These are: n Tuna, Caught in the Indian Ocean
n Cultivated Irish Mussels or Mussels,
• North-West Atlantic
Cultivated in Ireland
• North-East Atlantic (excluding the Baltic Sea)
n Cod, Caught in the North-East Atlantic or
North-East Atlantic Cod
n Irish Eel, Caught in Fresh Water
n Defrosted Smoked Coley, Caught in the
North-East Atlantic.

In addition, optional information may be included on the

label e.g. “Landed in Castletownbere” or “Farmed in
Ireland in Bantry Bay”.
2. PRE-PACKAGED RAW FISH 2 . 2 F i s h l a b e l l i n g r e g u l at i o n s
(INCLUDING SMOKED SALMON) n Commercial designation of the species of fish.

This applies to pre-packaged fish to which no other n Production Method: For fish produced through

ingredient except salt has been added and includes: live aquaculture, either the word “farmed” or

fish, fresh chilled and frozen fish, fish fillets and other fish “cultivated” must be used. For fish caught

meat (whether minced or not) dried, salted or brined fish, at sea the word “caught” should be used.

smoked fish (whether hot or cold smoked), crustaceans For freshwater fish, “caught in fresh water”

(except when they are both cooked and peeled), molluscs must be used.

(except when cooked). n Origin: country of origin for farmed species or

catch area if caught at sea.
2 . 1 G e n e r a l l a b e l l i n g See section 1 of this guidance note for further details.
requirements
n Name under which the product is sold. 2 . 3 I d e n t i f i c at i o n m a r k
Details of the physical condition of the foodstuff
This is a unique identification mark which indicates that
or processes it has undergone must accompany
the product has originated in a premises approved by
the legal name of the food e.g. smoked salmon.
the Sea Fisheries Protection Authority (SFPA) or other
n List of ingredients and declaration of allergens competent authority. It takes the form of an oval shaped
(See sections 5 and 6 for further details on mark and includes reference to the country where
allergens). produced, the factory approval number and the EU
n Quantity of certain ingredients. community mark, usually the letters EC.

n Net quantity. (Note: if the product was produced outside the EU, the
identification number may take a different format but
n Date of minimum durability (use-by date).
must still be present).
n Any special storage instructions or conditions
IE
of use.
Example: DL XXXX
n Name or business name and address of the EC
manufacturer, or packager, or of a seller within
the European Union. 2.4 Additional labelling
n Place of origin of the foodstuff if its absence
requirements
might mislead the consumer to a material n Batch or Lot Number (the durability date can
degree. double up as a lot provided it is sufficiently
precise to identify a particular batch).
n Instructions for use where necessary.
n Selling price and an equivalent price per unit
i.e. per kilogram (if the shop doesn’t have
equipment for printing shelf-edge labels or for
point-of-sale scanning, then it doesn’t have to
display the unit price, only the selling price).
3. PRE-PACKAGED PROCESSED 4. EXEMPTIONS
FISHERY PRODUCTS Fish sold loose, fish packaged at customer request and fish

Fish that has been further processed (beyond simple slicing packaged on the premises from which it is sold are exempt

or mincing), preserved, treated or cooked must comply from the labelling requirements outlined in 2.1, 2.3 and

with the labelling requirements outlined in Section 2.1, 2.4. However, when the person packaging the fish sells

2.3 and 2.4. However, they do not have to comply with it from other premises owned by him/her or to another

the specific fish labelling requirements outlined in 2.2. business the exemption no longer applies and the fish

Examples include: must be labelled in full.

n Frozen breaded fish fillets and fish fingers.

5. OTHER LABELLING
n Cooked crab claws/cooked crab meat.
REQUIREMENTS
n Fish pie/cakes/chowder (made using raw fish/
unprocessed fish).
Allergens
n Fish skewers containing raw fish and vegetables.
The presence of allergenic ingredients must be declared
If a food business is manufacturing a composite product on the label so that consumers who have allergies or
where cooked (processed) fish is bought in and used as intolerances are able to identify the ingredients they
an ingredient, an identification mark (2.3) is not necessary are sensitive to. There are some exceptions where the
on the label. These products must only comply with the nature of the food clearly indicates that it contains an
general labelling requirements outlined in 2.1 and 2.4. allergen and therefore would not need to be declared
Examples include: separately as an allergen. There are currently 14 categories
n Pizza with cooked fish topping. of ingredients (and products thereof) legally defined as
ingredients that are known to cause allergic reactions.
n Sandwiches containing cooked crab meat.
These are:
n Fish pies (made using processed fish).
n Cereals containing gluten and products thereof
If a composite product is produced in a food business (with some exceptions).
which requires approval for handling foods of animal
n Crustaceans and products thereof.
origin then the food business can voluntarily place their
identification mark on the labels. n Eggs and products thereof.

n Fish and products thereof (with exceptions for fish

gelatine).

n Peanuts and products thereof.

n Soybeans and products thereof (with exceptions).

n Milk and products thereof including lactose (with

some exceptions).

n Nuts i.e. almonds, hazelnuts, walnuts, cashews,

pecan nuts, brazil nuts, pistachio nuts, macadamia
nuts and queensland nuts, and products thereof
(with exceptions for nuts used for making distillates
and alcoholic beverages).
 n Fish can only be labelled as organic when produced
on a farm certified as organic and inspected by an
official certification body.

n Smoked salmon and smoked trout can only be

n Celery and products thereof. labelled as organic when the farm where it was
produced and the processing facility has been
n Mustard and products thereof.
certified as organic and inspected by an official
n Sesame seeds and products thereof. certification body.
n Sulphur dioxide and sulphites at concentrations of n Organic produce certified in Ireland must carry the
more than 10 mg/kg or 10 mg/litre expressed as words “certified organic” on the label along with
SO2. the code of the certifying body.
n Lupin and products thereof.
M i x e d b at c h e s
n Molluscs and products thereof.
n If a batch consists of fish of the same species from
For further details see ANNEX 111a of Council Directive
different catch areas or countries, the origin that
2000/13/EC as amended.
is most representative of the batch must be stated
along with an indication that some of the fish
Pa c k a g i n g G a s e s has come from another area. In order to give the
Fish packaged with packaging gases must be labelled customer accurate and meaningful information on
“packaged in a protective atmosphere”. the true place(s) of origin, it is recommended that
the other catch areas or countries are also named.
N u t r i t i o n a l I n f o r m at i o n n If the fish in a pack originates from only one
If a nutrition or health claim is made, nutritional country or catch area, then only this one country
information must be given. If no such claims are or catch area can be listed on the label. It is not
made, nutritional information is optional. If nutritional acceptable to list two or three countries of origin
information is given, it must follow specific formats on a label when the product only came from one
outlined in nutritional labelling legislation. of those countries.

n Example: If a food business operator sources

Organic Labelling salmon from both Ireland and Scotland but
packages and sells both products individually, a
Retailers selling loose organic fish and fish products
labelling reference “farmed in Ireland or Scotland”
(labelled as organic) must be registered with the
cannot be made as a catch all phrase on the label
Department of Agriculture Food and the Marine as an
as it does not reflect the true origin of the salmon
organic operator. The only products labelled as organic
in that particular pack and is misleading to the
that can be sold by non-licensed operators are pre-packed,
consumer.
pre-labelled organic products.

n Product may only be labelled as organic if it

contains at least 95% organic ingredients.
 n Additional requirements for provision of
information on allergens including:

• Specific ingredients which have been identified

as causing allergenic reactions to be emphasised
6. FUTURE DEVELOPMENTS IN through a typeset that clearly distinguishes them
from other ingredients.
FOOD LABELLING
• Requirements will also apply to foods sold loose.
The New Food Information Regulation will introduce some
additional labelling requirements. The new legislation n Additional requirements regarding date of
refers to food information rather than food labelling. minimum durability.
It states that food information means: “information n For frozen unprocessed fishery products the date
concerning a food and made available to the final of freezing or the date of first freezing to be
consumer by means of a label, other accompanying indicated.
material, or any other means including modern technology
n Introduction of minimum font size for all
tools or verbal communication”.
mandatory information on most labels.
It will apply to businesses at all stages of the food chain
Further requirements are detailed in the Food Safety
where their activities concern the provision of food
Authority of Ireland (FSAI) booklet “Overview of Changes
information to consumers. Among the new
to Food Labelling Introduced under the New Food
requirements are:
Information Regulation” available on the FSAI website
n Mandatory nutritional information for most www.fsai.ie
pre-packed foods.
Most of the new requirements under the Food Information
n Additional requirements regarding the Regulation will apply in December 2014 with nutritional
product name. information becoming mandatory in December 2016.

FURTHER INFORMATION
The information contained in this note is for guidance purposes only. If your company is designing new packaging or
labels we recommend that you contact the Food Safety Authority of Ireland (FSAI) www.fsai.ie in advance to
ensure that it is fully compliant with all relevant labelling regulations.

For further information on fish labelling requirements, email Eileen Soraghan: soraghan@bim.ie or Tel: 01 214 4100

Bord Iascaigh Mhara, P.O. Box No. 12, Crofton Road, Dun Laoghaire, Co. Dublin

www.bim.ie
Issue 2  November 2012