Freezing requirements for fishery products intended to be eaten raw or lightly cooked

Guidance for businesses that produce or sell fishery products that are intended to be eaten raw or lightly cooked.

About this guidance

Applies in England, Wales and Northern Ireland

This guidance provides an overview of the legal requirements and will be of interest to food businesses, including restaurants, that place raw or lightly cooked fishery products on the market.

Under European food hygiene legislation, certain fishery products destined to be eaten raw in dishes (such as sushi or cold smoked) need to be frozen before use. This is to protect consumers against parasites, unless certain risk-based freezing exemptions can be applied.

Parasites and freezing requirements

Fish parasites such as Anisakis are a problem in certain species of wild fish. If eaten by a human, they can cause illness. This means all fish and fishery products must be inspected and any visible parasites removed before the fish or fishery product is sold. Cooking kills parasites, but freezing is an additional way to protect the health of consumers. This is because the freezing process kills any parasites that may remain undetected.

Food Standards Agency research showed there is a negligible risk of parasites from farmed salmon. The European Food Safety Authority (EFSA) then reviewed the available evidence on the presence of parasites in wild and farmed fish. After that review, the European Commission and member states agreed updated hygiene legislation requirements, which allow a risk-based approach to be taken when applying the freezing requirements for fish and fishery products.

The updated requirements are set out in Commission Regulation (EU) No 1276/2011, which amends the relevant provisions in Regulation (EC) No 853/2004, and came into force on 29 December 2011. These were implemented in all UK nations on 30 July 2012.

European Union (EU) fish freezing requirements

Who do the requirements apply to?

All food businesses that place on the market, fishery products that are subject to a freezing treatment. Food businesses include restaurants and other retailers. See question ‘Who has responsibility for carry out any required freezing treatment’ below for further guidance on who has responsibility for carrying out any required freezing treatment.

Which fishery products do the freezing requirements apply to?

All fishery products from finfish or cephalopod molluscs that are intended to be consumed raw or lightly cooked must be frozen before consumption. This includes fish intended to be eaten raw such as sushi and sashimi, as well as cold smoked fish where the smoking process does not achieve a core temperature of 60°C for at least one minute. Marinated and salted fishery products, and any other treated products where the processing treatment used is insufficient to kill the viable parasites, must also be frozen before consumption. This could include products such as gravlax, carpaccio and pickled herring, depending on the marinating or curing treatment used.

What are the specific requirements for fishery products that require freezing for killing parasites?

Fishery products that are subject to a freezing treatment must be frozen at -20°C for not less than 24 hours, or -35°C for not less than 15 hours. The freezing must reach all parts of the product.

Are there any exemptions from the freezing requirements?

Yes. Food businesses do not need to apply a freezing treatment to fishery products, if they meet at least one of these conditions:

  • Fishery products have been, or before consumption, are due to be heat treated at a level that is sufficient to kill viable parasites. This is 60°C for at least one minute for parasites other than trematodes.
  • Fish have been preserved as frozen fishery products for a sufficiently long period to kill the viable parasites. This includes fishery products that have been commercially frozen at -18°C for at least 4 days for storage, transport and distribution purposes.
  • Wild catches have been authorised by the FSA, the central competent authority, to be exempt from freezing on the basis of evidence showing that the fishing grounds of origin do not present a health hazard with regard to parasites. There are currently no freezing exemptions for wild fish authorised in the UK.
  • Farmed fish, when cultured from embryos and fed on a diet that cannot contain viable parasites, and:
    • Have been exclusively reared in an environment that is free from viable parasites (this would include most onshore tank based production systems); or
    • Where the food business can verify that the fishery products do not present any health hazards in relation to parasites, through procedures approved by the competent authority. (See the question ‘Are they any approved exemptions in the UK for farmed fish?’ for further details on the types of production systems that are likely to fall within this category.)

Are there any documentation requirements?

Yes. When fishery products that are subject to a freezing treatment are placed on the market they must be accompanied by a document, issued by the food business carrying out the treatment, stating the type of freezing process the products have undergone.

Food businesses placing affected fishery products on the market which have not been subject to a freezing treatment, and which are not intended to undergo such treatment before consumption, must ensure that they are sourced from fishing grounds or fish farms that meet the exemption conditions. This information can be provided in the commercial documentation or any other information accompanying the fishery products.

Does documentation need to be supplied to the final consumer?

No. The documentation requirements do not apply to fishery products supplied to the final consumer.

UK authorised freezing exemptions

Are there any authorised exemptions in the UK for wild fish?

No. Parasites such as anisakis nematode worms are known to commonly affect a number of fish species caught in UK waters, particularly cod, mackerel, herring and monkfish. There is no evidence showing that UK fishing grounds do not present a health hazard with regard to parasites.

Are there any approved exemptions in the UK for farmed fish?

Yes. The UK has authorised a general freezing exemption for farmed Atlantic salmon following the EFSA risk assessment that concluded the parasite risks associated with this type of production system are negligible.

At the time that EFSA published its scientific opinion, it concluded that, unlike the salmon sector, there was insufficient monitoring data available to provide a robust assessment of the risk from viable parasites in other species of farmed fish. However, EFSA did establish that where fish are reared using the same production methods as farmed salmon – ie reared in raised sea pens and fed on a controlled artificial diet that cannot be infected with larval parasites – farmed fishery products from other species may also be considered as presenting a negligible risk with regard to parasites. This means a freezing exemption may also be approved for other species of farmed fish where it can be demonstrated that they have been reared using the same production methods as farmed salmon, including equivalent freshwater systems.

For fish reared using onshore tank-based systems, including freshwater ponds, tanks and raceways, it is sufficient for food businesses to document compliance with good practice for such farming systems, including appropriate filtration where necessary, to enable a freezing exemption to be applied.

The Food Standards Agency published the final report of further research in this area: 'A survey of parasitic nematodes in maricultured finfish in Scotland'.

This study was carried out by the University of Stirling to assess the risk from parasites in other mariculture species in Scotland, namely Atlantic halibut and rainbow trout. The research found that the risk of parasite infection in these species when farmed using existing practices is extremely low. Based on this new evidence, the UK has authorised a general freezing exemption for these two species as well as for farmed salmon.

FSA will consider any further freezing exemptions for farmed fish reared using any other production methods on a case by case basis.

Duties of food business operators

Who has responsibility for carrying out any required freezing treatment?

Food business operators placing fishery products on the market that are subject to the EU freezing requirements are legally responsible for applying a freezing treatment. This could be either the fish supplier or a restaurant serving the fish for example, depending on the circumstances and the point at which fishery products are marketed for raw consumption.

In some cases, it may not be known at the initial point of supply if fresh fish are intended to be consumed raw or cooked before consumption, particularly if products are exported or placed on the market via a distributor or wholesaler. This means the need to apply a freezing treatment may not be established until further down the food supply chain.

Buyers of fishery products, who intend to market a product which requires a freezing treatment, should specify the need for this to the supplier. Alternatively, the purchaser may wish to carry out the treatment themselves. It is considered that this would be in line with food safety management obligations for food businesses under Regulation (EC) 852/2004.

The provisions are intended to be flexible enough to allow the freezing process to be applied at the most appropriate point in the food chain and, notwithstanding the legal obligations outlined above; commercial agreements may be reached between suppliers and customers as to who takes responsibility for the freezing obligation. It is advised that this is done transparently with a high regard for consumer safety, and is auditable by the relevant enforcement authority.

How can it be demonstrated that a freezing treatment has been applied?

The food business applying a freezing treatment must ensure that the fishery products are accompanied by a document indicating the type of freezing process the products have undergone. Without this documentation it may not be obvious to any receiving businesses whether or not they had an obligation to apply a freezing treatment to fish they intended to market for raw consumption.

Products which are received without a document indicating the type of freezing process the products have undergone should be considered not to have been frozen until the evidence of freezing has been provided.

Will food businesses need to carry out any sampling or monitoring?

In the case of farmed salmon, Atlantic halibut and rainbow trout, no additional sampling by food businesses will be required assuming there are no changes to farming practices, and it will be sufficient for businesses to refer to the EFSA risk assessment and the FSA-funded research.

Similarly, food businesses rearing other species of farmed fish will not be expected to carry out sampling when fish are produced in accordance with the production methods set out in the answer to the question ‘Are they any approved exemptions in the UK for farmed fish?’ above.

The FSA will carry out further research where necessary to monitor parasite prevalence levels in wild and farmed fish as part of an ongoing national programme of work to ensure that verification procedures applied by food businesses remain risk-based and proportionate.

Requirements for import and export

Do the freezing exemptions apply to fishery products sourced from non-EU countries which are placed on the UK market?

If a UK food business wants to place fishery products – from a non-EU country on the market – for consumption as a raw product without applying a freezing treatment, then it is the responsibility of the business to ensure that the products are sourced from fishing grounds or fish farms that can demonstrate ‘equivalence’ with the EU exemption criteria. This should be verified by documentation and other information accompanying the fishery product from the non-EU country.

This may require the UK business notifying the FSA (as the UK central competent authority) so that, the FSA liaises with the competent authority in the country where the fish has been sourced to ensure that the UK food business satisfies verification procedures.

What if a UK food business exports fishery products to other countries where it is subject to further cooking?

Fishery products intended to be cooked before consumption are not subject to freezing controls. As outlined above it may not always be known at the point of export if fresh fish are intended to be consumed raw or cooked before consumption, and it is the responsibility of purchasers in receiving countries to apply a freezing treatment should it be established further down the food supply chain that such a treatment is required.

Further guidance

How can I find further information or advice on the requirements?

If you want to discuss any issues in this guidance, please email the relevant contact below.

More background information can be found in the European Commission’s guidance on Regulation 1276/2011. This can be accessed via the 'External sites' link on this page.

Where can I find related consumer advice?

FSA has published advice to consumers on the risk associated with wild caught fish. This can be found via the NHS Choices link on this page. It is important to ensure that the products caught for personal consumption are safe to eat. Some wild caught fish are known to be at risk of being infected with the nematode parasite anisakis.