Codex Standard for Fish Oils All Hands on Deck!

by Harry B. Rice

The 23rd Session of the Codex Committee on Fats and Oils (CCFO) has come and gone. For a day and a half in Langkawi, Malaysia, member nations and observer organizations debated the specifics related to the Proposed Draft Standard for Fish Oils. This standard will define what fish oils are for international tradebut in many developing countries, Codex Standards are also adopted as regulatory requirements. This makes the issue a very important one for the omega-3 and broader nutraceutical industries.

While it was obvious to anyone attending the CCFO meeting that significantly more work needs to be done before adopting a standard, the good news is that the industrys concerns were considered. Without getting too deep into the specifics of the Codex procedures, it is an eight-step process. The Proposed Draft Standard was discussed at Step 3, but its now going back to Step 2 for further consideration and redrafting by the electronic Working Group (eWG), which Switzerland will continue to chair. When the 24th Session of the CCFO meets Feb. 9-13,  2015, the Proposed Draft Standard will once again be discussed at Step 3. So, even considering a best-case scenario, it will be at least another four years before a fish oil standard is adopted. For those seeking a more in-depth discussion on the procedure for elaborating a Codex Standard, see the Codex Alimentarius Commission Procedural Manual (20th ed.).

For many, the last four years, since the Delegation of Switzerland introduced its proposal for new work on a standard for fish oils at the 21st Session (Feb. 16-20, 2009) of the CCFO, have been arduous. Assuming it takes only another four years, it will have taken eight years to adopt a standard for fish oil. While eight years may seem like a long time, consider that the issue of elaborating a standard for marine oils was first introduced more than 40 years ago during the Sixth Session in 1969. Discussions continued at the Seventh (1974), Eighth (1975) and Ninth Sessions (1977), where the effort was finally abandonedat least temporarily.

While the CCFO reached agreement on the scope and description of the Draft Proposed Standard, for all intents and purposes, the remainder was deferred to the eWG for further discussion, including:   

Sections 2.1 2.6.3 which cover the different named fish oils and types

Section 3 Essential Composition and Quality Factors

Sections 6 Hygiene

Section 7 Labeling

Section 8 Methods of Analysis and Sampling

Two new sections were proposed, including raw materials and permitted ingredients and were subsequently referred to the eWG. 

The most contentious issue going into the meeting was the use of fatty acid profiles to identify named fish oils such as salmon, anchovy and others tied to specific species. Much of the feedback received by the CCFO about this issue was that the fatty acid profiles should be scientifically based, a prerequisite for any Codex Standard. In addition, it was generally agreed that standards for named fish oils should be established only for the most highly-traded oils, but it was left to the eWG to establish such criteria.   

In the very near future, the Codex Secretariat will send out a Circular Letter with a call for data associated with named oils. The requested data will include trade volumes and fatty acid levels. GOED plans to reach out to the chair of the eWG to provide input on the scope of that activity since prior data (both trade volume and fatty acid levels) were collected by GOED. There are issues such as methods, seasonality and long-term trends that the scientifically-based process should consider.

All Hands On Deck

Adopting a Fish Oil Standard that is manageable for everyone is going to require a global effort from the industry. Global Organization for EPA and DHA Omega-3s (GOED) encourages industry professionals to become involved via trade association affiliation(s) and/or by reaching out to the respective Codex Delegate to the CCFO. For more information about who to contact, visit the Codex Contact Point. Any adopted standard needs to allow for free trade.

As mentioned above, there was agreement by delegates to the CCFO on the language associated with the scope and description. That language follows.

1. Scope

This standard applies to the fish oils described in Section 2 that are presented in a state for human consumption. For the purpose of this Codex Standard, the term 'fish oils' refers to oils derived from fish and shellfish as defined in Section 2 of the Code of Practice for Fish and Fishery Products (CAC/RCP 52-2003). This standard only applies to fish oils used in food and in food supplements where those are regulated as foods.

2. Description

'Fish oils' means oils intended for human consumption derived from raw materials as defined in Section 2 of the Code of Practice for Fish and Fishery Products (CAC/RCP 52-2003). Processes to obtain fish oil for human consumption may involve, but are not limited to, crude oil extraction from raw material and refining of that crude oil. Crude fish oils are intended for human consumption only after they have undergone further processing, refining and purification as applicable. Crude oils require further processing before they are placed on the market for the consumer. Fish oils and concentrated fish oils are primarily composed of glycerides of fatty acids, whereas concentrated fish oils ethyl esters are [primarily] composed of [contain] fatty acids ethyl esters. Fish oils may contain other lipids and unsaponifiable constituents naturally present. 

While the aforementioned represents my recollection of the discussions from the CCFO meeting, I was not present for the review of the draft report on the final day of the meeting. The CCFOs final report should be available within a month of the meetings conclusion. To find the report once it is made available, click this link and search for CCFO23. 

Harry B. Rice is the vice president of regulatory and scientific affairs for the Global Organization for EPA and DHA Omega-3s (GOED). He has worked in the ingredient, dietary supplement, functional food and consumer packaged goods industries for more than a decade. Among his responsibilities for GOED are monitoring and reporting on regulatory issues, spearheading efforts on complex issues, and providing scientific analysis of the growing body of scientific literature. In addition, Rice manages the scientific and regulatory committees. Prior to joining GOED and UNPA, he spent more than six years at Cargill Inc., involved in the development and execution of global regulatory and scientific strategies for a wide range of functional ingredients. Rice earned a master's and doctorate in nutrition from Pennsylvania State University and a bachelor's degree in dietetics from Miami University (Ohio).