FSA Enforcement Letter (ENF/E/09/028), 23 June 2009
In 2007 the Food Standards Agency issued advice (reference ENF/E/07/045) to clarify the hygiene requirements for the control of parasites that may be present in fishery products intended to be eaten raw or almost raw, and in cold smoked farmed salmon.
Regulation EC 853/2004, Annex III, Section VIII, Chapter III, D, 1 (a) requires unprocessed fishery products, intended to be eaten raw or almost raw (e.g. sashimi or sushi,) to have been frozen. Freezing of such fish may take place at any point in the supply chain prior to sale to the final consumer. Food businesses may choose to freeze the fish or the final product, including when the fish forms only part of a final product.
The Agency considers that for the purposes of the relevant provisions of Regulation EC 853/2004 cold smoked farmed salmon, since it has been processed, is not to be regarded as a raw or almost raw product and therefore the legislation does not require cold smoked farmed salmon, or the farmed salmon used to produce it, to have been frozen.
The Agency has undertaken research on the prevalence of certain parasites in pellet fed salmon farmed in Scottish waters with a view to collating epidemiological evidence to support an exemption from freezing for such salmon intended to be eaten raw or almost raw as provided for in Regulation EC 853/2004, Annex III, Section VIII, Chapter III, D, 2. The Commission has requested an opinion from the European Food Safety Authority (EFSA) by the end of March 2010 as to whether the data collated from Member States would support an exemption for pellet fed farmed salmon. This data will include the Agency research findings.
The Agency intends to wait until EFSA has concluded its review before deciding whether it is appropriate to support an exemption. In the meantime, it remains the case that fishery products intended to be eaten raw or almost raw (e.g. sashimi or sushi) must have been frozen to at least -20°C for not less than 24 hours. The freezing must reach all parts of the product.