EU Export Requirements Library Update: Fish and Seafood

The European Union (EU) food export requirements library webpage for fish and seafood has been updated in response to the findings of the EU’s shellfish audit on Canada’s food safety system as it relates to the production of bivalve molluscs intended for export to the EU.

The main updates include:

Product Specifications section:

  • Microbiological requirements: identifies differences in Canadian and EU sampling and testing requirements, new information on the EU’s Commission Regulation (EU) 2024/2895 of 20 November 2024 amending Regulation (EC) No 2073/2005 as regards Listeria monocytogenes, applicable from July 1 2026
  • Marine biotoxins requirements: identifies requirements to implement marine biotoxin monitoring programs if exporting molluscan shellfish harvested from offshore areas, and specify that echinoderms (sea urchins, sea cucumbers), gastropods (whelks, periwinkles), and tunicates that are processed for export to the EU must not be harvested from areas subject to biotoxin closures for bivalve shellfish
  • Export control plan (ECP) requirements: outlines information that are required in a written ECP for exporters who are exporting fish and seafood to the EU

Additional requirements section:

  • New information has been provided on the specific hygiene requirements for tuna frozen in brine on freezer vessels

Requesting an export certificate section:

Exporters are strongly encouraged to use the revised application form when applying for certification services to avoid administrative delays. For more information on the European Union’s current requirements, please refer to European Union (EU) – Export requirements for fish and seafood.

In addition, exporters are reminded of the following:

As per the Food Export Control Policy, exporters are responsible to ensure that exported food meet the requirements prescribed in the Safe Food for Canadians Act and Regulations, and any additional conditions agreed upon by the CFIA and the foreign competent authority of the importing country. Where EU requirements differ from Canadian requirements, exporters must prepare and implement effective written controls that demonstrate compliance with these additional conditions. These are outlined as a special condition included under the public health requirements for fish and fishery products for human consumption in Section A of Annex 5-E to Comprehensive Economic and Trade Agreement (CETA), or on the EU food export requirements library webpage.

Please note that EU’s sampling and testing procedures of microorganisms in fish and fishery products may be different from Canadian requirements. For example, the microbiological criteria limits given in the annexes of Commission Regulation (EC) no 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs refer to each sample unit tested individually, and not as a pooled/composite sample for most microorganisms. Please refer to the most up-to-date/consolidated version of the regulation.

At any time, CFIA inspectors may conduct inspection activities to verify that exporters have prepared and implemented effective written controls that demonstrate how SFCA and SFCR, and any applicable additional conditions are met. When an exporter is unable to demonstrate that effective export controls are implemented for additional export conditions outlined in the policy, a non-regulatory non-compliance can be issued by the CFIA. If actions are not taken by the exporter to correct the non-compliance, response actions can be initiated by the CFIA.

If you have any questions, please contact your local CFIA office.