Updates on the proposed fish oil standard:
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.
26 November 2014
IFFO will be attending the 24th Codex Committee on Fats and Oils (CCFO) Session, held in Melaka, Malaysia from 9 - 13 February 2015. There will be a separate meeting to specifically discuss the proposed Draft Fish Oil Standard where IFFO will be submitting member’s views.
The final report and revised Draft Fish Oil Standard that has been submitted by the Swiss Chair to the Codex Secretariat can be found in the list below. Due to time constraints, supplementary information and data on volumes of additional oils such as krill and menhaden oil could not be included, but will be re-submitted at the next CCFO session in Malaysia. Please note that this Standard is for fish oil intended for human consumption.
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 following points may be of interest for our members and we welcome any feedback from you:
- The current number and concentrations of antioxidants approved for use in fish oil by the Codex Committee for Food Additives (CCFA) is very limited. The permitted level of some of the antioxidants is also significantly lower than what is used in the industry. For example, 300 ppm of tocopherols is proposed for oils, whereas in our industry tocopherols are added at up to 5000 ppm. Which antioxidants do you use and what are the levels?
- [Bracketed text] indicate areas that are still under discussion, for example in section 2.8 the “Processing” paragraph will be discussed at the next CCFO meeting.Any suggestions for improvements to the bracketed text sections will be highly appreciated.
- Minimum levels of EPA and DHA in unnamed fish oils (section 2.2) will be set in order for them to be classed as fish oil. Do you think 10%, 12% or 15% EPA + DHA content will be appropriate for unnamed fish oil to be classed as fish oil?
- For highly concentrated fish oil (section 2.5.2), the proposed EPA + DHA content must be more than [60 w/w %] of which at least 70 w/w % of fatty acids must be in the form of triacylglycerides.Do you agree with a 60% EPA + DHA and is 50 w/w % of fatty acids to be in the form of triacylglycerides for highly concentrated fish oil reasonable or should the percentage of triglycerides remain 70 w/w %?
The CCFO meeting in February will be a step closer to implementing the Codex Standard for Fish Oil. Once the Standard has been set it will be a very long and slow process to make any changes and we therefore urge members to study this document and send us any comments on the points above or edits to the attached document. Please send us your comments to firstname.lastname@example.org by Friday, 19th December.
12 September 2014
The amended draft Codex Standard for Fish Oil including the report on the consultation regarding the fish oil trade data and fatty acid composition is available to download here or dowloaded from the list below. Feedback has been requested from the electronic working group (eWG) and IFFO in turn would like to give our members the opportunity to respond.
Highlighted below are some key points from the consultation:
The report found that the highest volumes of internationally traded fish oil are from the three species listed below. In addition, the analytical data of these species’ fatty acid compositions have been proven to be sufficiently robust to be used as reference compositions.
- Anchovy oil from Engraulis spp. (Engraulidae)
- Cod liver oil from G. morhua (Gadidae)
- Tuna oil from Thunnus spp and Katsuwonus pelamis (Scombridae)
It is proposed that these three fish species’ fatty acid profiles will be the only ones included in the Standard for fish oil at this stage. However, additional named oils may be added at a later stage as trade volumes become more significant in other species and their fatty acid compositions are more robustly documented.
- Some members of the eWG had proposed to include the fatty acid profiles of salmon and krill oil, however it was decided that their profiles did not have robust enough data (e.g. for farmed versus wild salmon) or their oils are not being traded in sufficient high enough volumes to warrant their inclusion.
- It was also raised by some members that there is significant variation in the fatty acid profiles due to factors such as diet, climate, season and region, and it would therefore be advisable to include the fatty acid profiles as references but not as part of the standard. However, it was later felt that the reported fatty acid ranges already reflect the variability caused by these factors and that the proposed three named oils could stay as part of the standard.
The following issues were raised for further discussion and we welcome both the opinions and comments of our members on these topics:
- It was proposed that specific level of an minimum content in EPA/DHA would be set for unnamed/not specified fish oils, found in Section 2.2 in document. If this is included, what level do you think would be appropriate?
- Only some parts of the standard will be applicable for crude oils (Section 2.7.1) only some. These are: Sections 4.1 (GLC ranges of fatty acid composition), 7.1 (General hygiene) and 8 (Labelling). Are there any other sections that should be mentioned as mandatory requirements?
- Table 1 proposes that fatty acids ranges for anchovy oil, cod liver oil, and tuna oil based on the data submissions. Do you agree with the proposed ranges or do you have any suggestions? Requests for modifications can only be considered if supported by adequate analytical data obtained from commercial products.
- Is it appropriate to mention processes applied to devitaminize fish oils described in Section 2.4.1?
- According to paragraph 45 of the report of the 23rd session of CCFO (Section 2) it is stated that the definition for Concentrated fish oils and concentrated fish oil ethyl esters should be aligned with the description. This means that concentrated fish oils and concentrated fish oil ethyl esters are distinct categories. Therefore it is proposed to create for the ethyl esters an own subsection 2.6 at equal level to the concentrated fish oils.
- Should the category ‘Extra low oxidised fish oils’ (Section 2.7.3) be integrated in to the standard even though the submitted data on trade volume do not justify its inclusion? If it is part of the Standard should it be characterized by specific quality criteria that separate this category from other fish oils? What would you consider to be the suitable parameters?
We welcome comments on this report, including the draft standard, and answers to the questions above. Please send your feedback to us by Wednesday 25th September 2014. We encourage you to make use of this opportunity and contribute towards defining the Codex Standard for fish oil.
19 June 2014
The Proposed Draft Codex fish oil Standard has been returned for re-drafting at the last Fats and Oils Codex meeting held in February 2013 due to the need for further data and information. Switzerland has compiled the data in its request for information concerning trade and fatty acid composition of unspecified and specified fish oils. IFFO is part of the electronic Working Group (eWG) that has been established and had submitted the data that our members provided to us on our request.
Switzerland has compiled the results of the data in the attached two spreadsheets. The one spreadsheet details the trade data for the different fish species and the other spreadsheet details the fatty acid compositions by fish species.
The attached word document contains the analysis and conclusions Switzerland has drawn, based on the submitted data along with specific questions (highlighted on page 3 of the Discussion, Results and Questions Codex doc) ) that requires input from the eWG.
We would like to give our members this opportunity to submit comments on these questions to us by Friday 4th July that we will submit to Switzerland in order for them to draw up a new Draft Standard for fish oils.
For your Information, the following timetable of the eWG for preparation of the new Draft fish oil Standard is as follows:
- Deadline for comments of the eWG 18.07.14
- Analyse comments of the eWG 15.08.14
- Revision of the analyses 05.09.14
- Distribution of the analyse to eWG for ok by eWG members 30.09.14
- Distribution of the amended analyses to the Codex Secretariat 30.10.14
The following documents regarding the Draft Fish Oil standard are available for download:
- Report of the 24th session of the CODEX Committee on Fats and Oils (Feb 2015)
- Final Report and Draft Codex Standard for fish oil November 2014
- Report and Draft Codex Standard for fish oil September 2014
- Fatty acid composition data Codex June 2014
- Trade data compilation Codex June 2014
- Discussion, results and questions Codex June 2014
- Codex Circular letter requesting trade and volume information
- IFFO report of 23rd CODEX Committee for Fats and Oils held February 2013 in Malaysia
- The official CODEX report of the 23rd meeting (Extract of comments regarding the Draft Fish Oil Standard)
- The Proposed Draft Fish Oils Standard presented at the 23rd CCFO meeting in February 2013