CODEX Standard for Fish Oil
The Codex standard for Fish Oil was finally adopted at the 40th Session of the Codex Alimentarius Committee (CAC40) held in Geneva 17 – 21 July 2017. The CODEX Alimentarius Commission approved the development of a Codex Standard for Fish Oils as new work as proposed by the 22nd session of the Codex Committee for Fats and Oils (CCFO) in 2011. It was a long process involving many discussions on the finer details which was important to clarify as the purpose of this Standard is to protect consumer health and promote fair practices in the trade of fish oil.
The guidelines, standards and recommendations produced by Codex are not legally binding; however they do provide a template for laws and are used by the World Trade Organization (WTO) as an agreed benchmark in global trade disputes.
The Codex Standard for Fish Oil can be found here as well as in the list below and covers the following areas:
- Scope: Aim and purpose
- Description: Products to be covered
- Essential Composition and Quality Factors: Fatty acid composition range for named fish oils and limits for quality parameters such as Peroxide Value and Free Fatty Acids.
- Food Additives: Such as including tocopherols and rosemary extract as additive in fish oils
- Contaminants: Maximum levels for e.g. arsenic and lead
- Hygiene: General and Microbiological
- Labelling: Requirements and information needed on labels e.g. possible labelling for farmed salmon
- Methods of Analysis and Sampling: Prescribed methods of analysis for the quality parameters and contaminants
The next CODEX Committee on Fats and Oils meeting will be held in Malaysia in February 2019.
Updates on the proposed fish oil standard:
Monitoring of Codex Standard for Fish Oil intended for Direct Human Consumption.
IFFO previously notified members that the Codex Standard for Fish Oil has been adopted at the Codex Alimentarius Committee meeting held in Geneva in July. At the previous Codex Committee on Fats and Oils (CCFO) meeting it was agreed that the application of the standard will be monitored with a view to address the difficulties associated with using only the fatty acid ranges of Table 1 as a measure to determine compliance of a fish oil with Section 2.1 of the Standard on Fish Oil. Specifically, the positive verification of the fish species used as raw material may be ambiguous considering the wide ranges of some of the fatty acids.
The Codex Circular Letter, which can be found here, is a request to monitor the application of the standard with respect to the conformity of named fish oils with the requirements (especially the fatty acid profile), and its effect on trade. Based on that data, the Committee will evaluate whether a revision of the fatty acid profiles for named fish oils is necessary and whether other aspects such as additional complementary criteria for example supplementary information from traceability and certification systems, are needed.
It is important to ensure that the Standard for Fish Oil is relevant and applies to currently traded named fish oils. Codex relies on the industry to inform them of any problems with and non-conformances found that is relevant to the standard. We would therefore appreciate it if members could collect data throughout the year and complete the Excel table attached below (copied from the Codex Circular letter) and submit it to us at firstname.lastname@example.org by 15 August 2018. We will collate the data and submit it to the CCFO.
The adoption of the Codex Standard for Fish Oils was on the Agenda at the 40th Session of the Codex Alimentarius Committee (CAC40) held in Geneva 17 – 21 July. The Standard for Fish Oil was adopted at Step 8 (final step) with reservation by Chile regarding the authenticity and traceability of fish oils, based on the use of fatty acid profiles, which was noted.
The Committee had agreed to monitor the application of the standard with a view to addressing some of the technical difficulties. A Circular Letter (CL) will be issued to monitor the application of the Standard for Fish Oils with respect to the conformity of named fish oils with its requirements (especially the fatty acid profile) and to its effects on trade, with data to be compiled by Chile and Switzerland. IFFO will circulate the CL to all members once available and will collate the input from members for submission to the co-chairs.
IFFO, represented by our Technical Manager Dr Gretel Bescoby, attended the 25th Codex Committee on Fats and Oils (CCFO) meeting held in Kuala Lumpur, Malaysia 27 February – 3 March. As an expert on Fish Oil biochemistry, Dr Bescoby was able to contribute to the discussion on behalf of IFFO members and request a realistic approach to the standard. The Committee agreed at the meeting to forward the Fish Oil Standard to the Codex Alimentarius Commission (CAC) for adoption at its meeting in July. This is the final step that will result, subject to approval, on the implementation of the standard.
However, the Fish Oil Standard once again generated a lot of interest and discussions. Concerns were raised on the use of the fatty acid profile table in the Fish Oil Standard as means of identification of named fish oils. The CCFO came to the following agreement:
- The CCFO will refer the concern of ensuring the authenticity of all oils (including fish oil) to the Codex Committee on Food Import and Export Inspection and Certification Systems (CCFICS) to address the issue.
- The application of the Fish Oil Standard will be monitored by evaluating samples to determine whether the fatty acids profiles is in agreement with the ranges provided by the Fish Oil Std. A Circular Letter will be sent to Codex members asking for data and information on named fish oils to be used in the monitoring of the Fish Oil Std. The work will be led by Chile and supported by Switzerland.
Dr Gretel Bescoby represented IFFO as an official Observer at the recent (Feb 2015) Codex Committee meeting on Fats and Oils where the Draft Standard for Fish Oil was discussed in detail. Despite initial misgivings, the Codex Committee is pleased with the progress that has been made. Agreement has been reached on a number of contentious issues and the most important results are listed below:
- The category for “Concentrated fish oils” will remain in the proposed standard.
- The categories for “Extra low oxidised fish oils” as well as “Fish liver oil devitaminised” has been removed.
- In addition to the three initial named fish oils (anchovy, cod liver and tuna oil) menhaden oil, krill oil as well as salmon oil has been added. The fatty acid profiles of the salmon oil will differentiate between “Wild” and “Farmed” salmon and it will also be specified on the label whether the source of the raw material is from wild or farmed salmon.
- Tocopherols have been approved as an additive with addition levels up to 6,000 mg/kg.
The Codex Draft Standard for Fish Oil has now progressed to Step 5 (of 8). Additional data will be obtained in the run up to the next Codex Fats and Oils meeting in 2017 particularly with regards to the fatty acid profiles of anchovy (as requested by Chile) and krill oil and specific labelling issues. A physical working group will once again convene prior to the 2017 meeting to discuss the received information and comments and if there is agreement on the Draft Standard it will progress further and will be submitted to the Executive Committee for critical review and to the Commission with a view to its adoption as a standard.
The report of the Codex Committee on Fats and Oils meeting held in February 2015 can be found here. The discussions on the proposed draft Standard for Fish Oil can be found in paragraphs 18 - 43 and the Proposed Draft Codex Standard for Fish Oils in Appendix III on page 34.
IFFO would like to thank all members who have provided us with valuable information during this process which enabled us to contribute towards the Draft Codex Standard for Fish Oil.