Labels for commercial smoked fish have special requirements

Labeling requirements help consumers make good decisions and aid in traceability.

The Michigan Department of Agriculture and Rural Development requirements for labeling commercial smoked fish are very specific, and are helpful in two regards. First, the consumer can make better decisions regarding the freshness of the smoked fish, who made the product, and how to properly store the smoked fish. For the regulator, the label will aid in traceability and will allow for segregation of suspected of problems, and aid in the recall of product should the need arise. 

All smoked fish are required to have a label regardless of the way the smoked fish is packaged. This would include in both packaging designed to protect unfrozen smoked fish itself, and secondary packaging used to transport the unfrozen smoked fish. Smoked fish sold from a bulk display, and individually wrapped at the time of purchased must be labeled also. The labels are required to be in the English language and Arabic numerals are also required. 

Each label shall contain the name of the product. Typically this would be indicate the kind of fish, for instance “smoked salmon” would satisfy the requirements of the regulation. The name, the address of the manufacturer, distributor, packer or retailer is also required of the label. If the person whose name appears on the label has not manufactured the smoked fish, a statement regarding the connection to the manufacturer must be added.

Net weight and ingredients must be listed on the package. Typically weight is expressed in ounces and pounds. In addition to fish, the other ingredients such as salt, sugar, brown sugar and liquid smoke would be included, depending upon what is used on the process. The order would be descending from the most by weight to the least by weight. A lot code indicating the time period, which the smoked fish was processed and packaged, is also required. Smoked fish being stored must not be comingled with smoked fish that had been processed on different dates.

Two warning statements are required on the smoked fish. The first is a requirement for proper storage. “Perishable—Keep under refrigeration at 38 degrees Fahrenheit (3.3 degrees Celsius) or below.” The second warning is a shelf life statement that indicates 14 days or less from the date of smoking. The terminology is as follows: “Not to be sold or consumed after _____.” The blank space would contain the month date and year that sales or consumption should not exceed. A manufacturer may receive a variance on the shelf life if it can be demonstrated that the process used results in a safe food product if consumed after the 14-day period.

If the smoked fish is being held frozen throughout the channel, the two aforementioned warning statements regarding temperature and not required. The aforementioned warnings are replaced with a warning specific to frozen fish, which reads “Perishable: Keep frozen. Thaw in refrigerator before consumption.”

Michigan State University Extension and Innovation Counselors at the Michigan State University Product Center assist food business operators in the establishment of good practices and in producing safe food products. For further information and assistance with employee communications please contact your local Michigan State University Extension office. 

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