Opinions

Use of the preservatives sorbic acid and benzoic acid and their salts in cold-smoked fish / fish products

The question of whether the use of sorbic acid and benzoic acid or their salts in the production of cold-smoked fish (e.g. mackerel and herring) is permissible has been discussed controversially in the past. The Working Group Fish and Fish Products of the Food Chemical Society, Division in the German Chemical Society, has now reassessed this issue against the background of the current law on additives. In the opinion of the AG, the use of these preservatives is not permitted for cold-smoked fish / fish products. The preservatives are approved according to Regulation (EC) 1333/2008 Annex II Part E Category 09.2 (processed fishery products) for "partially preserved" fish and fishery products. Smoked fish are not listed here. A definition for the category ?partially preserved? fish and fishery products is not contained in Regulation (EC) 1333/2008. The ?Guidance document describing the food categories in Part E of Annex II Regulation (EC) No 1333/2008 on Food Additives? can be used as an aid to interpretation. It must also be taken into account that the system of food categories in Regulation (EC) 1333/2008 is based on the system of food categories of the General Standard for Food Additives of the Codex Alimentarius CODEX STAN 192-1995 (see recital 4 of Regulation (EU) 1129 / 2011). The description of the category "Fish and fishery products, partially preserved" ("Semi-preserved fish and fish products") in the Guidance document corresponds to the description of the category "Semi-preserved fish and fish products" in CODEX STAN 192-1995. From this it can be concluded that the category ?fish and fishery products, partially preserved? includes the products that the Codex category ?semi-preserved fish and fish products? also describes. In CODEX STAN 192-1995, however, smoked fish products do not belong to the ?Semi-preserved fish and fish products? category, but form a separate category. According to this, smoked fish products are not (at the same time) classified as "partially preserved" fishery products. Viewing smoked fish and fish products as a separate category with regard to the use of preservatives is also in line with CODEX STAN 311-2013 (Standard for smoked fish, smoke-flavored fish and smoke-dried fish). According to this, the mentioned preservatives are not used for smoked fish, except for products packaged in a reduced oxygen atmosphere.

Position and basic papers

 

• Glazed fishery products - indication of the glaze water in the list of ingredients as of June 2022 ( PDF )
• Labeling of fish bought ready for slaughter in directly selling aquaculture farms as of May 2019 ( PDF )

Current topics

 

• CO treatment of tuna and tilapia
• Labeling issues
• Composition tropical shrimp species
• Sanitary parameters of squid
• Addition of water to fishery products