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CIRCULAR WITH REGARDS TO FROZEN PRAWNS (SHRIMPS)

Numerous recurring problems have been identified during our routine sampling and inspection of imported frozen prawns with regard to:

  1. The use of preservatives/antioxidants and acidifying agents;
  2. Labeling requirements;
  3. Inadequate packaging of the product;
  4. The use of colourants; and
  5. The absence of the required documentation and lack of factory codes.

The requirements of section 17(1) of the Standards Act of 1982 stipulates that no person shall sell any commodity for which or for the manufacture of which a compulsory specification is in force, unless such commodity complies with the relevant specification. Since the sale and production of prawns are governed by the requirements of the Compulsory specification for Frozen Shrimps (Prawns), Langoustines and Crabs as published by Government Notice No. 326 of 20 March 1987, all prawns imported into the Republic of South Africa must comply with the requirements of this specification.

The onus rests with the importer to inform the SABS of all consignments imported into South Africa. The importer must ensure that the product complies with all the requirements of the above-mentioned compulsory specification. The problems as listed above are dealt with here below.

  1. PRESERVATIVES/ANTIOXIDANTS AND ACIDIFYING AGENTS

    In terms of the requirements of the relevant compulsory specification and the regulations under the Foodstuffs, Cosmetics and Disinfectants Act of 1972, the following must be complied with.

    1.1 The following antioxidants are permitted for use with frozen prawns:

    1. L-Ascorbic acid - the quantities to be used must be in accordance with “good manufacturing practice” (GMP) limited to such a maximum level that the product will not be deleteriously affected, or its compliance with legal requirements disturbed.
    2. Sodium metabisulphite - the quantities must not exceed 30 mg/kg in the final product, expressed as SO2, singly or in combination with other sulphites.
    3. Sodium bisulphite - maximum limit the same as for (b).

    The presence of an antioxidant which also has preservative effect, must be shown in the ingredients listing, e.g “Antioxidant: metabisulphite” or “metabisulphite (antioxidant)”.

    1.2 Where citric acid is used it must be declared on the label.

  2. LABELING REQUIREMENTS

    The following information shall appear legibly and indelibly on each package in accordance with the above-mentioned compulsory specification and the Foodstuffs, Cosmetics and Disinfectants Act as well as the regulations under the Trade Metrology Act of 1973.

    2.1 The name and full business (street) address of the manufacturer, seller, producer, proprietor or controlling company, or in the case of containers packed on behalf of any other person or organization, the name and full business (street) address of that person or organization. The size of the lettering shall not be less than 1 mm in height.

    2.2 The name of the product shall be a true description thereof including its method of preparation, presentation and shall not be misleading. Where applicable, the description shall be in accordance with the presentation and described as follows:

    1. Whole: Cephalothorax (head), shell and tail fans intact.
    2. Headless: Cephalothorax removed, shell and tail fans intact.
    3. Headless and deveined: Cephalothorax removed, the back cut open and the vein removed, shell and tail fans intact.
    4. Peeled and deveined (tail fans removed): Cephalothorax and vein removed and shell removed down to the last segment, i.e the shell on the last segment and tail fans shall be present (fantail shrimps).
    5. Peeled and deveined (tail fans removed): As in d) above, but with all shell and tail fans also removed.
    6. Breaded or battered shrimps: Either as in d) or e) above.
    7. Other acceptable descriptions (presentations).

    The name must appear on the main panel/s in bold print in letters not less than 4 mm in height.

    2.3 The words which qualify the foodstuffs or are an essential part of the description thereof, shall be in the immediate proximity to the name and in prominent letters at least 3 mm in height.

    2.4 Where applicable, a list of the ingredients in descending order of content by mass. The size of the lettering shall not be less than 1 mm in height.

    2.5 The pictorial representations which reflect products not contained in the packet, must have the words “serving suggestion” superimposed on or in the immediate proximity of such pictorial representation in bold print not less than 3 mm in height.

    2.6 The net mass of the contents shall be expressed in the relevant units of the metric system, viz kilograms (kg) or grams (g). The required statement of quantity shall be in bold characters and figures each kind of a uniform print throughout, be of a height not less than 25 per cent of the average height of the largest and smallest characters used for the brand-name or for the descriptive name, where only the one or the other appears, or where both appear, the name for which the larger characters are used shall serve as the basis for determining the minimum height of such statement: Provided that no statement of quantity shall be less than 1,5 mm in height or need exceed 15 mm in height.

    2.7 The date of manufacture and the identity of the factory in which the product was packed must be indelibly marked or stamped on each immediate container. The use of a code is permissible provided that the key is disclosed to the SABS.

    2.8 A statement that the product is cooked or uncooked as applicable together with the necessary storage instruction, shall appear on the main panel in letters not less than 3 mm in height.

    Uncooked/Raw - Keep frozen
    Partly cooked - Keep frozen
    Cooked - Keep frozen

    2.9 Grading: The product shall be graded by mass and shall fall into such categories as may be acceptable and in accordance with trade requirements. Where applicable, the counts shall be in accordance with the declaration on the container. On visual examination, the units shall be acceptably uniform in size.

    2.10 The country or origin must be given. The size of the lettering shall not be less than 1 mm in height.

    2.11 The directions of use - where relevant. The size of the lettering shall not be less than 1 mm in height.

    2.12 Substandard - when applicable shall be printed prominently and indelibly on all main panels in print size at least half the size of the product or trade name, whichever is the greater.

    Information appearing on the label must be in either or both of the official languages.

    The above-mentioned labeling requirements shall be printed on the package, or on a label of acceptable material attached to the package. Labels on the packages shall be clean and neatly and securely attached. They shall not be superimposed on other labels or on matter directly printed on the packages. Labels or sealing adhesive that are liable to deteriorate under conditions of storage of the packaged products shall not be used. When new or amended labels are to be printed, we suggest that you submit to us drafts of these labels for approval prior to printing.

  3. PACKAGING

    Unless the product is glazed, it shall be packaged in material of low permeability to moisture and oxygen. Packaging material shall be new, clean, non-toxic and inert. Where cartons with drainage holes are used, the product should be wrapped in suitable material, e.g polyethylene, to prevent contamination. The use of inverted cartons, that is cartons with the printing on the inside of the carton, are not permitted.

  4. COLOURANTS

    Where colourants are used their use must be in accordance with conditions and limits permitted under the regulations of the Foodstuffs, Cosmetics and Disinfectants Act of 1972. The use of colourants must be declared on the label on the main panel in their comon chemical name or names as well as the color index number(s).

  5. DOCUMENTATION

    The following documentation is required before or on sampling:

    5.1 The Bill of Entry or any other relevant documentation.

    5.2 A code list indicating the various codes as well as different grades and quantities of each in the consignment.

    As specified in Paragraph 2.7 all immediate packages must be factory coded, as any consignment discovered after release without a code will be considered as a new/separate consignment and subject to sampling and inspection as such.

    We trust that this information will be of value to you. Should you have any queries, please do not hesitate to contact us.

J VAN HEERDEN
SABS: FOODS AND ASSOCIATED INDUSTRIES

 

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