European Union (EU)
Fish products for human consumption
1.1 Establishment registration
The Department of Agriculture, Fisheries and Forestry (the Department) is the Australian government authority responsible for export registration, inspection and certification of Australian food and agricultural exports.
All premises involved in the production of fish and fish products for export, including fishing vessels where fish is prepared for export, must be registered with the Department. For more information or assistance with the export registration process contact the department's Dairy, Eggs and Fish program at dairyeggsfish@agriculture.gov.au.
Encapsulated fish oil for human consumption
Fish oil capsules which contain a cellulose or gelatine-based component are considered by the EU to be composite products. Please refer below for composite product requirements.
Composite Products for human consumption
Composite products are defined by the EU as products composed of both products of plant origin and processed products of animal origin such as biscuits, dips, soups and pies. EU Regulation (EC) 2017/625 provides the following categories for composite products:
- non shelf stable composite products;
- shelf stable composite products that contain meat products; and
- shelf stable composite products that contain products of animal origin other than processed meat.
Under EU regulation (EC) 2019/625, all processed composite products of animal origin (meat, dairy, eggs and fish), regardless of their percentage as an ingredient in the product, must be sourced from EU listed establishments to be eligible for import into the EU. For further information on exporting composite product containing fish please refer to EU Non-prescribed goods.
1.2 Overseas listing
| Initial listing procedure for products for human consumption | Required? |
|---|---|
*Refer to Section 6 - Documentation requirements - Accessing TRACES-NT **Under EU Regulation (EC) 853/2004, live bivalve molluscs (not including scallops (pectinidae) harvested from open ocean) intend to be exported live or prepared for export to the EU must be harvested from an EU approved harvest area. A list of approved EU harvest areas in Australia can be found at: Establishment Lists - TRACES NT (europa.eu) (Select Country: Australia, Chapter: Food, Section: Bivalve molluscs) | |
| Export registration | Yes |
| Establishment listing for EU | Yes |
| Listing in TRACES for exporters | Yes* |
| Bivalve molluscs harvest area listing for EU | Yes** |
Establishment listing for EU
Export Registered Establishments that prepare fish and fish products to the EU must be included on the list on the European Commission website: Establishment Lists - TRACES NT (europa.eu) (Select Country: Australia, Chapter: Food, Section: Fishery Products) administered by Directorate- General for Health and Food Safety (DG-SANTE) prior to commencing processing of these products if intended for export to the EU.
Cold storage establishments storing, handling and loading fish and fish products are also required to be on the applicable EU lists as part of EU supply chain requirements
Registered vessels are required to be EU listed if the fish and fish products frozen on-board are to be eligible for export to the EU (either as packaged on board the vessel or to be eligible for reprocessing at a land-based establishment for export to the EU).
Also refer to: Section 2.1 – Sourcing of fish and fish products.
If your company wants to be listed as the exporter on export documentation (in addition to being the manufacturer/processor), you must create an account to log in to TRACES NT. This will allow you to register for or find your TRACES NT identifier code (exporter ID), which is required when submitting a permit request in EXDOC (or REX in NEXDOC). See Section 6 for more details.
Listing process – land-based establishments – pre-approval
The Department is responsible for making requests for the listing of land-based establishments by entering information into the EU TRACES portal and will advise establishments of their listing status or if additional information is required.
The land-based establishment is responsible for making an application to the Department for EU listing by contacting the Dairy, Eggs and Fish Export Program at dairyeggsfish@aff.gov.au and confirming the following
- The product they intend to prepare for export to the EU
- The establishment has an approved arrangement in place that includes any additional controls where required to ensure that EU requirements are met if implemented as documented
Assessment of the application may include a site inspection to confirm implementation of any additional controls required to be in place at the establishment to ensure that importing country requirements are met.
The department will request EU approval for an establishment after confirming it meets all EU requirements, and its Approved Arrangement properly documents all relevant EU controls. The establishment can only start processing products for export to the EU once the EU grants approval.
Listing process – vessels – pre-approval
The process for requesting the listing of registered vessels is the same, with the requirement for additional documentation to be submitted to verify the ownership and flag state of the vessel.
Applications will need to be accompanied by:
- fishing licences held by the vessel
- the vessels IMO number or List of Registered Ships number as issued by AMSA
Listing process – modifications and deletions from EU list
Establishments requesting modifications to their existing EU listing (for example, establishment name) must ensure that all export documentation and labelling does not include new details until the EU list is officially amended to reflect the new information and the validity date has been reached.
Deletions are considered to be effective immediately upon submission to DG-SANTE. EU health certificates may only be issued until the last day prior to the date on which the request has been submitted to the European Commission.
Information for exporters who are non-manufacturers
Non-manufacturing exporters must wait until the details of the export registered fish establishment/s that they source product from appear on the EU TRACES-NT website prior to exporting. Product produced prior to the date of validity of the manufacturing establishment entry in this list is not eligible to be exported to the EU.
The link that exporters need to follow to check if the relevant fish establishment/s details have been added is:
1.3 Prohibited products
Australia is not currently authorised to export crocodile meat to the EU.
1.4 Access for fish products for human consumption
- Note
- Exporters are encouraged to verify import eligibility of their specific product with their importers prior to export as requirements may vary between individual EU Member States.
| Product | Access? |
|---|---|
| *Under EU Regulation (EC) 853/2004, live bivalve molluscs (not including scallops (pectinidae) harvested from open ocean) intend to be exported live or prepared for export to the EU must be harvested from an EU approved harvest area. A list of approved EU harvest areas in Australia can be found at: Establishment Lists - TRACES NT (europa.eu) (Select Country: Australia, Chapter: Food, Section: Bivalve molluscs) | |
| Finfish | Yes |
| Bivalves (for example, oysters, scallops, mussels, clams, cockles) | Yes* |
| Crustaceans (for example, crab, prawn, lobster, scampi, crayfish) | Yes |
| Echinoderms (for example, sea urchins, sea cucumber) | Yes |
| Gastropods (for example, abalone, periwinkles) | Yes |
| Cephalopods (for example, squid, cuttlefish, octopus) | Yes |
| Tunicates (for example, sea squirts) | Yes |
| Crocodile | No |
2.1 Harvest
Sourcing of fish and fish products for preparation for export
Section 5-16 of the Export Control (Fish and Fish Products) Rules 2021 (the Rules) details the requirements for the sourcing of fish and fish products for export, including when product may be sourced from a catcher boat.
Sourcing of fish and fish products for preparation for export to the EU
Fish and fish products exported to countries that adopt EU requirements must be processed by establishments (including vessels) and stored in cold storage establishments that are on the EU list of approved fishery product establishments.
The EU requires traceability of all products to the point of harvest, with additional documentation being required to confirm the origin of some species. Refer to Section 6 - Documentation requirements - Additional documentation requirements – IUU Catch Certificates.
Catcher boats and aquaculture farms
Sourcing of product from catcher boats and direct from aquaculture farms is limited to product that is live, chilled and has not been dismembered (other than killing, bleeding, and gutting) and held chilled until delivered directly to an EU listed land-based establishment.
If iced, chilled fish must be held aboard the vessel in such a way as to allow any melt water to drain.
Bi-valve Molluscs (not including scallops harvested from open ocean)
Under EU Regulation (EC) 853/2004, live bivalve molluscs (except for scallops) and their products must be harvested from an EU approved harvest area. Link to approved EU harvest areas in Australia: Establishment Lists - TRACES NT (europa.eu) (Select Country: Australia, Chapter: Food, Section: Bivalve molluscs).
Use of imported fish and fish products for preparation for export to the EU
Where fish or fish products have been imported into Australia for further processing and export to the EU, the imported products must be sourced from an establishment that is part of the EU supply chain. That is – the source establishment must be listed in the applicable third country list/s.
Refer to: Establishment Lists - TRACES NT (europa.eu)
Product Standards – EU specific requirements
Fish and fish products exported to the European Union are required to meet the physical, chemical, and microbiological requirements detailed in the applicable Commission Regulations
Where EU product or process requirements differ from the requirements of the Rules, establishments are required to identify and document any additional controls required to ensure there are monitored process controls in place. If additional product testing is required to verify process, a testing schedule must be documented to ensure product testing is undertaken as per the requirements of the Commission Regulations.
2.2 Microbial and residue sampling
Fish and fish products exported to the European Union are required to meet the microbiological requirements detailed in the annexes of Commission Regulation (EC) 2073/2005.
Establishments conducting routine product testing to verify controls in place are not required to duplicate tests to demonstrate EU requirements are being met where EU requirements are more stringent, provided tests are carried out in a NATA laboratory utilising NATA approved EU specified test methods. Note that sub-sample numbers and permissions around consolidating sub-samples may differ from Australian and other importing country requirements.
2.3 Operational requirements additional to Australia's export legislation
EU legislation requires compliance by establishments with Regulation (EC) No 853/2004 laying down specific hygiene rules for food of animal origin
In the majority of instances, operational hygiene requirements are consistent with the requirements of the Export Control (Fish and Fish Products) Rules 2021.
The following section highlights where additional controls may be required. Establishments that are EU listed (including vessels) must be aware of these additional requirements and, where applicable, incorporate controls into their approved arrangement. Inclusion and effectiveness of controls will be verified by the Department.
Chemical requirements
Includes limits for histamines, heavy metals, permitted additives and contaminates including dioxins PCBs and PAHs in fish oils, smoked fish and bivalve molluscs.
Also included in Regulations are permitted levels of histamines and shellfish toxins.
Food Additives
For permitted additives, information is as found in the Annexes of Regulation (EC) No 1333/2008 of the European Parliament and of the Council of 16 December 2008 on food additives. For more information on permitted additives please consult the DG-SANTE database on Food Additives.
Regulation (EC) N0 1333/2008 contains information on calcium disodium ethylene diamine tetra-acetate (Calcium disodium EDTA), maximum levels and restrictions/exceptions, as they apply to canned molluscs, Under Part E of Annex II.
Contaminates – Heavy metals, dioxins, PCBs, PAHs
For other contaminants, information is as found in the Annex of Commission Regulation (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs.
Residues and contaminants – therapeutants and antibiotics
The Annex of Commission Regulation (EU) No. 37/2010 of 22 December 2009 on pharmacologically active substances and their classification regarding maximum residue limits in foodstuffs of animal origin, contains the maximum permitted levels of these products in the muscle tissue of all fish and fish products intended for export to the EU.
Establishments preparing fish of aquaculture origin for export to the EU must ensure that substances used to treat fish are also approved for use in Australia and, if used, withholding periods have been determined to ensure maximum residues are not exceeded.
Farm specific NRS test results may be utilised in lieu of annual verification testing of individual suppliers by processing establishments.
Evidence that EU MRLs are being met must be verified annually for each aquaculture suppler, noting this may include a statement from the supplier that no antibiotics are used or present in fish feed.
Note: Where EU establishes lower limits than Australia
Maximum residue limits (MRLs) or import tolerances for residues of specific agricultural and veterinary chemicals approved for use in Australia may not exist in the EU or may be established at levels lower than those established in Australia. Respective limits for contaminants may also vary between the EU and Australia.
Establishments eligible to prepare fish and fish products for export to the EU should note that:
- These differences can be interrogated case-by-case by considering the EU standards (here for pesticides, veterinary drugs and contaminants) and the Australian standards (here for pesticides & veterinary drugs and here for contaminants).
- Any detection of a residue above the EU MRLs/MLs (if applicable) at the EU border would result in rejection of the consignment and trigger an information, alert and/or border rejection notification in the EU Rapid Alert System for Food and Feed (RASFF)
Parasites, biotoxins and TVB-Ns
Commission Regulations (EU) 2074/2005 provide specific requirements for parasites and biotoxin testing methodology in bi-valve molluscs and fishery products for export to the EU. This Regulation includes requirements for determine the Total Volatile Basic Nitrogen (TVB-N) as an indication of freshness for some species.
Commission Regulation (EC) 853/2004 Annex III provides details of the health standards required to be met for live bivalve molluscs and includes biotoxin limits product placed on the market live or dead.
Parasites
All fish intended for export to the EU are required to be visually inspected for the presence of parasites / nematodes.
Parts of fish which contain visible live or dead nematodes are to be removed and must not be prepared for export. Processors should make every effort to achieve this through a non-destructive examination of the fish and fish products during processing by qualified personnel.
When processing conditions do not allow for the examination of each individual fish (example: mechanical evisceration and/or filleting operations), the processor must develop a sampling plan for each batch of processed fish. The sampling plan for mechanically eviscerated fish must include a representative number of samples of not less than 10 fish per batch.
Biotoxin limits for bi-valve molluscs
Chapter 1 of Commission Regulations (EU) 2074/2005 details the methodology for the testing of biotoxins in the edible parts of molluscs.
Chapter 5 of Annex III Commission Regulation (EC) 853/2004 details the health standards and biotoxin limits for bi-valve molluscs, noting that these limits are in addition to or are lower than the limits set in the Australian New Zealand Food Standards Code.
TVB-Ns
Chapter II of Section II of Commission Regulations (EU) 2074/2005 details the levels of TVB-Ns that when exceeded in specified species of unprocessed fishery products are taken as an indication that the product is regarded as unfit for human consumption.
Where organoleptic assessment has raised doubts as to the freshness of the product to be exported, processors are required to confirm as per the test methodology described in this section.
2.4 Premises and equipment
Land based establishments that are freezing product must have freezing equipment with sufficient capacity to lower the temperature rapidly so as to achieve a core temperature of not warmer than -18°C and storage holds able to maintain this product core temperature.
- Note
- Annex I of the Regulation includes definitions of types of fishing vessels. The department has listed Australian vessels as "Factory vessels" in recognition of the level of processing that is permitted to occur under the Export Control (Fish and Fish Products) Rules 2021 (with the exception of shucking of bi-valves other than scallops).
Vessels that are freezing product must have freezing equipment with sufficient capacity to lower the temperature rapidly so as to achieve a core temperature of not warmer than -18°C and storage holds able to maintain this product core temperature.
Section VIII: Fishery Products of Commission Regulation (EC) 853/2004 details the specific requirements for all fishery products intended for export to the EU with the exception of live bivalve molluscs, echinoderms, tunicates and marine gastropods if they are alive when exported.
Requirements specific to the export of live bivalve molluscs, echinoderms, tunicates and marine gastropods are detailed in Section VII – Live Bivalve Molluscs Commission Regulation (EC) 853/2004
Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs provides the general requirements for food business operators on the hygiene of foodstuffs. Specific details for fishery products and live bi-valves (foods of animal origin) are further detailed in Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin
Exporters of fish and fish products for human consumption for export to the EU must ensure their products meet the requirements laid out in relevant EU regulations. Regulation (EU) 853/2004 sets specific hygiene requirements that must be met by food business operators at all stages of production, processing and distribution after primary production and includes requirements that must be met by EU listed establishments in a third country.
3.1 Live fish
Refer to Section 3 - Production.
3.2 Non-viable fish
Refer to Section 3 - Production.
3.3 Crocodile
Under Article 23 of Regulation (EU) 2021/405, Australia is not currently authorised to export crocodile meat to the EU.
3.4 Packaging
Regulation (EU) 853/2004 outlines the EUs requirements regarding labelling, health standards, harvest, handling, packaging, transport and storage.
3.5 Labelling
Annex II of regulation (EC) 853/2004 requires that all product in the EU supply chain has an identification mark applied when packaged product leaves the establishment at which it is packaged. This requirement is met by labelling that identifies the product as of Australian origin by including the word 'Australia' or 'AU' and the export establishment number allocated to the establishment by the department.
Shelf-life and freezing
Refer to Annex X of Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 for requirements for durability date markings and requirement to label frozen fishery products with the initial date of freezing.
Snake Mackerel, Escolar and Oilfish
Snake Mackerel (Gempylus serpens), Escolar (Lepidocybium flavobrunneum) and Oilfish (Ruvettus pretiosus) must be labelled with both the scientific and Australian Fish Names (AS 5300) of the fish and must provide information on consumer preparation and a warning about presence of substances that may have a gastrointestinal effect. Commission Regulation (EC) No 1020/2008 amending Annexes II and III to Regulation (EC) No 853/2004).
Live Bivalve molluscs: Identification Marking
The label, including the identification mark, must be waterproof. The following information must be present on the label:
- the species of bivalve mollusc (common name and scientific name); and
- the date of packaging, comprising at least the day and the month.
- the date of minimum durability may be replaced by the entry "these animals must be alive when sold".
3.6 Shelf life
The EU has no known specific requirements for shelf-life restrictions that differ from the Export Control (Fish and Fish Products) Rules 2021.
4.1 Shipping marks
The EU has no known specific requirements for shipping marks, that differ from the relevant Export Control (Fish and Fish Products) Rules 2021.
4.2 Refrigeration, transfer and loadout
Fish and Fish product prepared for export to the EU must be stored, handled and loaded at temperatures no warmer than -18°C.
Vessels
- Note
- Annex I of the Regulation includes definitions of types of fishing vessels. The Department has listed Australian vessels as "Factory vessels" in recognition of the level of processing that is permitted to occur under the Export Control (Fish and Fish Products) Rules 2021 (with the exception of shucking of bi-valves other than scallops).
Vessels that are freezing product must have freezing equipment with sufficient capacity to lower the temperature rapidly so as to achieve a core temperature of not warmer than -18°C and storage holds able to maintain this product core temperature.
5.1 Import permit
Exporters should confirm with their importer or agent if an import permit is required for their product.
5.2 Port of entry inspection and testing
eCert and TRACES NT
TRACES NT is the European Union’s digital certification and management platform for importation of goods into the European Union. The department’s export systems connect with TRACES NT to digitise our export documentation exchange. Many exporters and establishments access the TRACES NT system to:
- Ensure their business is correctly listed.
- Look up the TRACES NT “identifier code” for establishments, exporters, importers, and places of destination that goods are delivered in the EU.
- Check certificates and download PDF copies when required.
All EU member states and countries in the EU single market (Iceland, Liechtenstein, Norway and Switzerland) require electronic certification (eCert) for fish products sourced and exported from Australian establishments (including fishing vessels) that are registered by the Department and are listed with the EU.
Information included in the REX will be transmitted to TRACES NT via eCert and made available to border control posts in their official language. The EU border control post will have access to the full eCert in TRACES NT, removing the need to present a paper certificate at entry.
An extract of the data sent via eCert can be remote printed by the exporter in lieu of the paper health certificate. The extract carries only commercial information required to identify the product.
Electronic export clearance information (including endorsements) is sent from NEXDOC to TRACES NT at the same time the request for export is approved (at "COMP").
This system replaces the printed health certificates required prior to May 2022 to export fishery products to the EU.
Paper certificates in NEXDOC for the export of fish and fish products to Northern Ireland
The TRACES NT system does not apply for exports to Northern Ireland. Please contact the Department at ExportStandards@agriculture.gov.au if you intend to export to Northern Ireland direct from Australia.
Accessing TRACES-NT
To access TRACES NT, you first need to set up an account. This link will outline the process to set up an EU log in and to create an account in TRACES NT.
TRACES NT users must use multi-factor authentication to access the system. This can be done in several ways, however, for Australian residents the EU Login mobile phone app is the most reliable option. Please note that only one mobile device can be linked to one EU Login account. To do so, users should go to https://webgate.ec.europa.eu/cas, log in with the username and password they use for TRACES NT (EU Login account) and follow the instructions.
A step-by-step guide showing how to use EU login, how to set up multi-factor authentication with the EU Login Mobile app and how to sign in with an EU Login account using the EU Login Mobile App QR code is available on the European Commission website.
A user guide and frequently asked questions relating to EU Login additional instructions can be found on the EU Login Help page.
Once you have created your account in TRACES NT, you need to set up a user role or operator profile. Once this is done, please send an email to the EXDOC Help Desk (EXDOC.Helpdesk@aff.gov.au) to let us know so we can validate this for you. It is a requirement that all user roles/operator profiles are validated by the Australian competent authority (the department).
When raising your export documentation
Exporters are required to provide the following information when raising a REX:
- Place of destination - This is compulsory for all consignments, not just those in transit across the EU.
- This field will require the Name, Address, Registration/Approval Number (if applicable) and country of the place in the EU where the consignment is being delivered for final unloading (the EXDOC system will then automatically provide the ISO country code for this field).
- If the intended destination changes after the certificate has been signed, then the importer can update this information in the Common Health Entry Document (CHED). This is the responsibility of the importer and certificates should not be replaced after departure unless requested by the border control post.
- CN code - this was provided as the Harmonized System (HS) code previously but this will be entered in EU format as 4, 6 or 8 digit number as stipulated in Council Regulation EU 2021/632.
- Batch number – Batch number will be required for each line of product on a certificate. This number should match what is labelled on the cartons or commercial documents. The EXDOC system can accommodate up to 17 characters in the batch number field that can be a combination of numbers, letters and the symbols ( / ), ( : ) or ( - ). For fish which typically applies the processing date as the batch or lot number, the batch or lot number may be entered in the format of DD-MMM-YYYY (i.e. 29-MAY-2020).
- Final consumer - The certificate will require an indication of whether the products are packaged for final consumers so that the EU can check that the labelling complies with EU law.
- This should be “Yes” if the commodity is packaged for final consumers. This includes product packaged for retail sale i.e. a supermarket, or packed in individual portions for consumer use.
- This should be “No” if the products are packed in bulk and to be separated for sale to individual consumers by the retailer, i.e. such as a butcher’s shop or fish vendor.
For an eCert to be lodged successfully, valid exporter (consignor), consignee (importer), and Place of Destination TRACES NT IDs must be supplied. You should work closely with your importer to ensure you have the correct TRACES NT IDs for the Consignee and the Place of Destination.
For additional information refer to: 2022-08: European Union: Fish: Paperless trade eCert commences from 31 May 2022 - DAFF (agriculture.gov.au).
As TRACES NT is managed by the EU, if you have any further questions, the department encourage you to work with your importer to clarify any EU import requirements.
If you have any questions in relation to raising export certification please contact the EXDOC Help Desk (EXDOC.Helpdesk@aff.gov.au) or the Dairy, Eggs and Fish Export Program (dairyeggsfish@aff.gov.au).
Assessing requests for export
All Requests for Export (REXs) must be authorised by a Departmental officer.
Replacement of health certificates for fish and fish products
EU regulations allow a replacement health certificate to be issued only if:
- The original health certificate is lost or damaged.
- There is an obvious administrative error (for example, a transposed container or seal number, or a spelling mistake in addresses or product descriptions).
Replacement certificate requirements:
- There must be no changes to the identification, traceability, or health assurances of the consignment.
- The new certificate must refer to the unique code and the date of issue of the initial certificate and clearly state that it replaces the initial certificate.
- The new certificate must have a new certificate number and include date of actual issue of the replacement.
- The replacement health certificate must be issued in the same format as the original certificate, which for the EU is an eCert.
If the consignee, port of entry, date of transport, or mode of transport changes after the consignment has departed, the importer must notify the EU border official directly.
Exporters should contact the Department for advice if a replacement health certificate is required and must provide a copy of the official advice from the EU border official, where available. A replacement health certificate will be issued, as required, by the EU border official.
- Note
- It is the exporter’s responsibility to ensure that all information provided in their export permit is true, accurate and complete. Any errors may lead to the consignment being detained by EU authorities.
For any held shipments, or for further information, email dairyeggsfish@aff.gov.au.
Live and non-viable fish and fish products templates
| Commodity | eCert template name |
|---|---|
| For the export of wild origin frozen, chilled, dried and canned non-viable finfish, crustaceans and cephalopod molluscs that are packaged for retail sale e.g., Frozen yellowtail kingfish, frozen octopus, fish oil, frozen tuna | EUFXA1 |
| For the export of wild origin live crustaceans packaged and labelled for human consumption | EUFXA2 |
| For the export of aquaculture origin frozen, chilled, dried and canned non-viable finfish, crustaceans and cephalopod molluscs that are packaged for retail sale e.g., Frozen yellowtail kingfish, frozen octopus, fish oil, frozen tuna | EUFXA3 |
| For the export of aquaculture origin live crustaceans packaged and labelled for human consumption | EUFXA4 |
| For the export of live marine gastropod molluscs | EUFXB1 |
| For the export of non-viable bivalve molluscs ready for direct human consumption e.g. Frozen, chilled, canned | EUFXB2 |
| For the export of non-viable marine gastropods, echinoderms and tunicates ready for direct human consumption e.g. Frozen, chilled, canned | EUFXB3 |
| For the export of live bivalve molluscs | EUFXB4 |
| For the export of live bivalve molluscs packaged and labelled for human consumption and packaged for retail sale | EUFXB5 |
Additional documentation requirements – IUU Catch Certificates
EU traceability requirements Illegal, Unreported, and Unregulated (IUU) fishing
Council Regulation (EC) No 1005/2008 details the system established by the EU to prevent, deter and eliminate illegal, unreported and unregulated (IUU) fishing.
All fish and fish products entering the EU market, including products caught by EU-flagged vessels operating outside of the EU Economic Exclusion Zone are covered by the requirements of the IUU Regulation.
For some species exported to the EU, a government validated Catch Certificate is required to ensure fish and fish products exported originate from non-IUU (legal) fisheries. The catch certificate is required by the EC Directorate-General for Maritime Affairs and Fisheries and attests that the fish being exported was caught in compliance with the IUU regulations.
It generally includes all marine fishery products including live, fresh, chilled, frozen, prepared and preserved product forms. Fishery products which fall under Chapter 03 and Tariff Headings 1604 and 1605 of the Harmonised System Tariff Code must be accompanied by a catch certificate, with some exceptions.
All freshwater fisheries and aquaculture products are exempt from this regulation, as well as some forms of molluscs such as scallops, mussels, oysters and snails.
Annex I of the Council Regulation (EC) No 1005/2008 has the list of fishery products excluded from the scope of implementation of the catch certificate.
The exporter in Australia is required to provide a copy of the completed Catch Certificate to the EU importer prior to the product arriving in the EU. It is up to the EU importer to submit the certificate to the competent EU Member State authority. The communication of the catch certificate between the exporter and EU importer can also be done by electronic means.
Completing Catch Certificates
All catch that may be exported to the EU needs to be noted in the catch certificate i.e. even if only a portion of a catch is exported to the EU, the catch certificate must reference the whole catch from which that portion was taken for export.
All applicable product, destined for the EU, harvested by EU-approved Australian-flagged vessels, regardless of size (even small vessels), need a catch certificate for export to the EU.
- Note
- As prescribed in Annex II of EC Regulation 1005/2008 (Appendix 3 of MAA FISH 09/10), there is a requirement for one catch certificate for each vessel that contributes fish or fishery product to a consignment. Multiple species can be used on this catch certificate if they were taken by the same vessel during a single fishing trip.
As prescribed in Annex IV of EC Regulation 1010/2009, a separate, 'simplified certificate' (Appendix 2 of MAA: FISH 09/10) has been developed by the EC for catch harvested from vessels which:
- have an overall length of less than 12 metres without towed gear or
- have an overall length of less than 8 metres with towed gear or
- is without a superstructure or
- is of less than measured 20 GT.
Where a consignment is comprised of catches from vessels that meet the above criteria, the exporter can use the EC's 'simplified catch certificate' which allows for multiple catches to be referenced on the one document. It is the exporter's responsibility to ensure that all of vessel information required on the 'simplified catch certificate' can be provided.
Catch Certificates must be signed by the applicable fisheries management authority
Catch certificates, once completed are required to be verified by the State/Territory/Commonwealth authority where the fish were harvested to get their signature and stamp. Refer to contact details at the end of this section.
Contact details
Commonwealth Fisheries
State/Territory Fisheries Authorities
- South Australia Department of Primary Industries and Regions South Australia PIRSA
- Western Australia Department of Primary Industries and Regional Development
- Tasmania Department of Primary Industries, Parks, Water & Environment (Fishing Tasmania)
- Northern Territory Department of Resources – Fisheries
- Queensland Primary Industries & Fisheries
- New South Wales Fisheries Conservation and Aquaculture, Industry, and Investment NSW
- Victoria Victorian Fisheries Authority
6.1 Live fish
Refer to Section 6 - Documentation requirements.
6.2 Non-viable fish
Refer to Section 6 - Documentation requirements.
6.3 Crocodiles
There is no agreed certification for crocodiles for human consumption to the EU.
Fish products not for human consumption
1.1 Establishment registration
Fish and fish products which are for not human consumption are not regulated by the Export Control (Fish and Fish Products) Rules 2021. Establishments processing such products are not required to be export registered with the Department.
- Note
- However, if the EU requires a government certificate for the entry of the above goods, a certificate can be issued by the Department – provided that the goods have been prepared in an export registered establishment that has the required overseas listing.
1.2 Overseas listing
| Initial listing procedure for fish products not for human consumption | Required? |
|---|---|
*Refer to Section 1.4 - Access for fish products not for human consumption for more information. | |
| Establishment Registration | Yes - for animal feed* |
| Establishment listing for EU | Yes - for animal feed* |
1.3 Prohibited products
Exporters should check with their importers to determine if products not for human consumption are permitted for import to EU.
1.4 Access for fish products not for human consumption
| Product | Access? |
|---|---|
| Aquaculture feed | No agreed certification |
| Animal feed | Yes |
| Crocodile skins and hides | No agreed certification |
| Technical products and pharmaceutical material (for example, fish oil capsule) | No agreed certification |
| Rendered products | No agreed certification |
| Shells | No agreed certification |
For canned and dried petfood containing fish products or products from other aquatic animals, establishment listing is required. Establishments exporting fish based petfood must be listed on the EC website as a petfood processing establishment.
Establishments must be audited against the EU requirements for fish-based petfood and recommended for EU petfood listing by the Pet Food Industry Association of Australia (PFIAA) or another Department approved auditor. For further details, please refer to EU Meat.
- Note
- Micor meat is password protected, user registration is required prior to access.
Crocodile skins and hides are non-prescribed goods and are not regulated by the Export Control (Fish and Fish Products) Rules 2021. Market access for crocodile products may vary across EU Member States. An exporter may be required to obtain health certification and/or commercial documents for the export of raw and/or treated crocodile skins. Exporters are encouraged to verify import eligibility of their specific product with their importers prior to export as requirements may vary between individual EU Member States.
Rendered products are non-prescribed goods and are not regulated by the Export Control (Fish and Fish Products) Rules 2021.
There is no agreed certification for import of technical grade and pharmaceutical material into the EU. Exporters should work with their importers to confirm importing country requirements.
15/01/2025 - Updated information for exporters who are non-manufacturers and TRACES information (sections 1.2 and 6).
02/08/2024 - Updated information on TRACES (section 6).
20/06/2024 - Updated operational requirements for food additives (section 2.3).
16/11/2022 - Page first published on Micor.