Issues under discussion at Codex

Below are a list of issues currently under discussion at Codex that are relevant to the Australian Seafood Industry. SafeFish welcomes any technical advice, comments or input around these issues. A comprehensive report that contains more detailed information on these issues is compiled by SafeFish every quarter, to access the most recent report please click here.

Methylmercury – Proposal under consideration to significantly reduce maximum level in fish

The CCCF have been discussing methylmercury limits since 1992. In 2013 CCCF agreed that consumer advice should not be developed at the international level and that such guidance was more appropriate at the national level.  There is a growing consensus from the international community to convert these Guideline Levels into a Maximum Limits. In 2016 CCCF agreed to establish a ML for tuna, but work needed to be undertaken to determine whether it was possible to establish a single ML for tuna or whether different MLs should be set for different species of tuna, and whether it was possible and appropriate to set MLs for canned tuna. There is also some interest in establishing MLs for other fish species which contain high mercury content.

At the beginning of January 2018 Codex Australia was given a very short timeframe to comment on a report that was prepared in the lead up to the next CCCF meeting (to be held in The Netherlands from 12-16 March 2018). The report proposed MLs for methylmercury in certain fish (see below) and sampling plans. The proposed MLs were derived based on the ALARA principle with a 5% rejection rate using data published in a global food database.


Fish species

Proposed ML for methylmercury (mg/kg)













SafeFish provided a submission to Codex Australia for consideration after consultation with the industry around the potential impact of implementing the levels above, and this was fed into the international EWG. It is understood that there will be further opportunity to provide comment and feedback prior to the March 2018 meeting. The global database currently contains little information from Australian fish stocks. Industries that may be impacted by the proposed MLs should consider obtaining information on methylmercury levels in their product for submission to this database. Please advise SafeFish if you have any data on mercury in your product, or would be prepared to obtain this in the near future.

Histamine – New histamine control guidance and consideration of reduced maximum level

Scombrotoxin fish poisoning (SFP) is a common cause of fish poisoning that occurs in humans. Histamine formation can be effectively controlled by using good manufacturing practices to maintain hygienic quality of fish, and by using HACCP systems to control fish time and temperature exposure. CCFH have prepared a draft revision of the Code of Practice for Fish and Fishery Products to include a new section to help prevent SFP. This will identify what actions should be undertaken, and includes the need to measure temperature and maintain the history of temperature and time records throughout the supply chain. These draft revisions will be applicable to marine finfish and their products that have the potential to develop hazardous levels of histamine and includes tuna, mackerel, anchovies, sardines, kingfish, Australian salmon, Mahi Mahi and Escolar. The current Codex health-based safety limit for histamine in fish from Clupeidae, Scombridae, Scombresocidae, Pomatomidae and Coryphaenedae families is 200 mg/kg. Discussion are also occurring on potentially reducing this level and revision of sampling plans.

Ciguatoxins – New standard under consideration

The Codex Committee for Contaminants in Food has requested the FAO/WHO direct JECFA (Joint expert committee on Food Additives) to assess risk of Ciguatoxin.  The FAO/WHO will be releasing a call for data and experts later this year (date not confirmed, subject to availability of funds). Given that ciguatera poisoning causes the greatest number of illnesses related to seafood in Australia each year, SafeFish will be involved in these discussions and would be interested in running a process to determine what type of data is available in Australia, what would be involved in collating this into a form suitable for submission, and would consider sponsoring an expert to attend the meeting if that was not funded through the JECFA process. If you would be interested in joining an Australian working group to assist in this process, please contact the SafeFish secretariat.

Alignment of Food Additives – Notification of changes to a variety of seafood products

Food additives in 10 frozen seafood commodity standards and for canned shrimp and prawns are to be aligned to the General Standard for Food Additives (CODEX STAN 192-1995). The list of approved food additives and maximum permitted level within the individual commodity standards (above) will be replaced with reference to permissions listed within the General Standard for Food Additives (CODEX STAN 192-1995). The alignment will mean that any additive that is not permitted in the GSFA will also not be allowed to be used in the relevant commodity standards.

Non Dioxin-like PCBs – Revision to cover non dioxin-like PCBs in food and feed

In 2015 the Joint FAO/WHO Expert Committee on Food Additives (JECFA) assessed the toxicity of non dioxin-like PCBs and concluded that based on the available data non dioxin-like PCBs are unlikely to be a health concern for adults and children, but for breastfed infants the safety margin would be expected to be lower. It remains important that efforts are undertaken to reduce or prevent human exposure to non dioxin-like-PCBs. In 2015 CCCF agreed to review the Code of Practice for the Prevention and Reduction of Dioxin and Dioxin-like PCB Contamination in Food and Feeds (CAC/RCP 62-2006) to evaluate if non dioxin-like PCBs could be included. CCCF have recommended that non dioxin-like PBCs be include in the Code of Practice. The practices to reduce the presence of dioxin-like PCBs are also applicable to non dioxin-like PCBs, i.e. there should be no significant change to the current Code.

Fish Oils – New standard for fish oil, maximum level for arsenic and lead under consideration

CCFO have developed a draft Standard for Fish Oils and in March 2017 agreed to forward the draft Standard for Fish Oils to CAC40 for adoption at Step 8. The draft Standard will apply to fish oils that are presented in a state for human consumption. Aspects of the standard will apply to crude fish oils. CCFO have requested CCCF to consider to develop maximum levels for arsenic and lead in fish oils for inclusion into the General Standard for Contaminants and Toxins in Food and Feed (CODEX STAN 193-1995).

Review of maximum level (ML) for lead in fish

The Joint FAO/WHO Expert Committee on Food Additives (JECFA) has identified that there is no safe level of lead and consequently there is a need to maintain the levels of lead in food at the lowest achievable levels, in particular to protect vulnerable populations groups. The 10th session of CCCF (April 2016) agreed to establish an eWG to review the ML for lead in fish in the General Standard for Contaminants and Toxins in Food and Feed (CODEX STAN 193-1995). The eWG extracted data from the GEMS/Food database for samples collected and/or analysed between 1995 and 2016. The eWG recommended that the current ML for lead in fish of 0.3 mg/kg be maintained. This compares to the current domestic level in the FSANZ Food Standards Code of 0.5 mg/kg.


WTO Sanitary & Phytosanitary (SPS) Notifications

Korean SPS Notification (February 2017)

In February 2017 Korea issued a SPS notification that a new Korean MRL for isoeugenol (active component within Aqui-S or clove oil) is being established at 0.01 mg/kg. No timeframe was provided on when the new MRL would come into effect. The current MRL in Australia for isoeugenol is 100 mg/kg for fish (excluding molluscs or crustaceans). For the SPS notification, please click here. In addition to this the United States Food & Drug Administration (FDA) released a GAIN report in October 2017 which provides an overview of the Korean Seafood Market. For this report, please click here.

Hong Kong SPS Notification (June 2017)

In June 2017 Hong Kong issued a SPS notification that is proposing to establish/modify MLs for metallic contamination in different food/food groups. This will impact fish, crustaceans, molluscs and other aquatic animals. The proposed amendments plan to adopt Codex MLs unless otherwise justified. Some of the proposed amendments will be stricter than Australian domestic (FSANZ) and Codex MLs. To view the SPS notification, please click here.

Indian SPS Notification (August 2017)

India has issued an SPS notification informing parties that they are proposing to change the Maximum Residue Limits (MRLs) and the use of a large number of antibiotics and other pharmacologically active substances. For the SPS notification, please click here.