A big part of my job for many years was to help countries with issues around EU Market Access, and in what regards vessels and landing site, since that still is part of my “specialities” and I get always asked questions :-)
There is an interesting scenario developing in the purse seine tuna industry started by the French a few years ago. Traditionally, purse seiners freeze in brine and mostly kept the fish there. Lately, they installed dry lockers (on board coolstores/freezers where they put the fish after being frozen in brine) and moved the frozen fish from the wells (in brine) to the "dry lockers". Usually, they could bring this down to -15C or so... but as they were destined to canning, hence they can be stored at –9C, that wasn't an issue
Now that MSC fish has a higher value, more and more Purse Seiners are replacing some of their dry lockers with blast freezers to -35C for the big yellowfin they catch, than then is sold as -35C fish to be process frozen (loins, steaks, etc), and destined to the sashimi market, while the rest goes to canning
Generally, once the fish comes to deck from brailing into the chute table, the big yellowfin are separated and sent to the blast freezers... But many go through into the brine, get frozen and then (a few days later) when they move the fish to the dry-lockers they are separated and stored in -35C
Now this fish was initially frozen in brine, and the way I read the regs it can be kept at -9C if is going to canning, but what is the situation now for that fish when it goes into -35C?... it can go to frozen processing for loins and then exported to the EU?...
One way you can read the regs... is that is the temperature the one that decides the "destiny", and not the way it was frozen... from the food safety perspective the fish is safe, histamine is low... is nothing wrong with that fish... it just it took it a bit longer to get to -35C :-)
This has been so far the case so far since no one questioned the EU about it… But DG SANTE has their eyes on the tuna industry, and as in the case of the double use (fish and fuel), I wrote before… they don't like it.
In May they put out a “letter” making their position clear:
“certain operators use tuna frozen in brine on freezer vessels at -9C for purposes other than canning, such as the production of tuna loins placed on the market as fresh”
“It is clear that the freezing of fishery products in brine at a temperature of not more than - 9C is only allowed if those products are intended for the manufacture of canned food.
Those fishery products which are not intended for canning must be rapidly frozen to reach a core temperature of not more than -18C. Therefore, the practice of using tuna frozen in brine on freezer vessels at -9C for purposes other than canning, such as the production of tuna loins placed on the market as fresh, is contrary to the provisions of the Regulation”
And they also go into the monoxide issue… but that has been clear for years now.
I don't think that is clear… but in any case, it put the CA in the world into another problem… How could the CA ever prove (without being on board) that that practice that I describe (1st brine then -35) did not happen?