Product of Canada, eh?
Fish
In Canada, imported fish are subject to the labeling requirements of the Fish Inspection Regulations maintained by the Canadian Food Inspection Agency. Country of origin must be declared on all imported fish product, but only on the container in which it is imported, not necessarily on the retail package. Fish that undergoes transformation (e.g. canning, smoking, salting) in Canada in a federally registered establishment can be labeled "Product of Canada."
Here are some highlights from the fish inspection regulations:
- "No person shall package any fish or mark or label any container of fish in a manner that is false, misleading or deceptive."
- "No person shall import into Canada or attempt to import into Canada any fish unless ... each container has a label on which the name of the country of origin is clearly identified."
The "country of origin" mark is based on the last substantial transformation the product has undergone.
What is "Substantial Transformation"? Any major processing step that changes the original nature of the fish or fish product such that the original product loses its identity and becomes a new product having a new name, character, and use. For example, cod fillets transformed to cod in batter or fresh salmon processed into canned salmon.
So, if a raw salmon were imported from the U.S. and canned in a federally registered facility in Canada, the canned salmon would be "Product of Canada." This regulation is based on the the idea that regardless of a country of origin, the raw fish intended for further processing in Canada must meet Canadian safety and quality standards.
Imported fish that has been only re-packaged or de-boned in Canada cannot be labeled "Product of Canada" because those processes are not considered substantial transformations.
The fish program does not apply the 51 percent rule that applies to such packaged goods as cheese and ready-to-use garlic.
Here are some quick facts about fish and seafood inspection in this country:
- Regular shipments are tested at a rate of 5 percent. The idea that if fish are farmed together in the same water and given the same feed, a small sample will likely reflect any contamination across the entire batch.
- When the CFIA encounters a company or product it hasn't seen before, the entire shipment is held and tested. If it's clean it goes on the "good" list (with 5-percent sampling). If not, it goes on the "bad" list, and all shipments after that are held and tested until four shipments in a row meet Canadian requirements. Then it's over to the "good" list (with 5-percent sampling).
The current 100-percent hold-and-test list includes:
- Farmed finfish from China (hold and test for Malachite Green and Leucomalachite Green)
- Farmed fish from Vietnam (hold and test for Chloramphenicol, Nitrofurans, Malachite Green and Leucomalachite Green) (without certificate; with a certificate the test frequency goes down to 5 percent)
- Farmed eels and eel products from Taiwan (hold and test for Malachite Green and Leucomalachite Green)
- Farmed shrimp from China (hold and test for Nitrofurans)
- The U.S. Food and Drug Administration has a 100 percent hold-and-test on farmed fish from China, and its tests check for gentian violet. (The Canadian agency does not currently perform this test)
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