Microbiological requirements for lightly salted fish in the EAEU

On June 10, 2021, on the website of the Eurasian Economic Commission, in the section "Current issues concerning technical regulations", explanations regarding the requirements for microbiological safety indicators for lightly salted fish were published.

Clarification of the provisions of the technical regulations TR EAEU 040/2016

The starting point for the publication of explanations was the ambiguity of the requirements contained in Annex 1 to the technical regulation TR EAEU 040/2016 "On the safety of fish and fish products". Annex No. 1 "Microbiological Safety Standards" contains 5 tables with microbiological safety indicators for fish products, canned fish products, as well as fish products for infants and fish used in the production of the indicated fish products.

What is a lightly salted fish?

"Lightly salted fish" is a category of fish products that is very popular in the countries of the Eurasian Economic Union. It is difficult to find an unambiguous term "lightly salted fish", as it has not been defined in point 4 of the regulations. At the same time, lightly salted fish was included in such product categories as:

  • lightly salted smoked fish, sea fish fillets
  • spicy, pickled fish, including frozen, sliced ​​and not sliced, lightly salted and salted fish, seasoned and stuffed fish fillets
  • vacuum-packed fish, including vacuum-packed fish with no preservatives

Lightly salted fish therefore belongs to the type of product of salted fish products (i.e. made and preserved with a large amount of salt). According to point 4 of the technical regulations, salted fish products are ready-to-eat fish products that are processed with sea or table salt, with or without the addition of sugar, spices, spice extracts, and food additives. This type of product also includes lightly salted fish and an intermediate category between salted and lightly salted fish - the so-called "medium salted fish".

Microbiological indicators for lightly salted fish

The three types of salt preserved fish mentioned above must meet the microbiological indicators set out for the product categories to which they are included in the technical regulations (marinated, spicy, frozen, with added additives, etc.).

It is worth recalling that the technical regulations TR 040/2016 have been in force for almost four years - from September 1, 2017 to be exact. Confirmation of the compliance of fish products, in accordance with point 87 of the document, takes the form of a declaration.