CCFO- Draft Standard for Fish Oils- Discussion of results in response to CL2013/7-FO
1.
At the 23rd session of the CCFO the Proposed Draft Standard for Fish Oil was discussed. In view of the comments made and the need for further data and information, the committee agreed to return the
Proposed Draft Standard to Step 2 for re-drafting. It was decided that for this purpose an eWG should be established chaired by Switzerland. The committee agreed that items already agreed at the 23rd session should not be re-opened for debate by the eWG. However, further comments may be discussed at the next session of the committee. In preparation for the eWG, the Codex Secretariat sent out a Circular
Letter, requesting information on volume and patterns of trade for different fish oils as well as information on quality and composition, including fatty acid profile for named fish oils. This data should help to justify establishing requirements for specific named fish oils in the Proposed Draft Standard.
2.
CL 2013/7 FO requesting information on volumes and patterns of trade for different fish oils as well as information on their quality and composition was distributed in March 2013 to all members and observers of the Codex Alimentarius Commission. The Deadline for sending comments was September
30, 2013.
Comments from the following members and observers were received:
Canada, Chile, Iceland, Ireland, Japan, Norway, Seychelles, Switzerland, Thailand, USA, IADSA, IFFO.
3.
In February 2014, the Codex Secretariat distributed an invitation to participate in the eWG to prepare the
Proposed Draft Standard for Fish Oil. The following members and observers announced their interest:
Argentina, Australia, Brazil, Canada, Chile, Denmark, Egypt, European Union, France, Ghana, Iran,
Japan, Netherlands, Norway, Poland, Republic of Korea, Russian Federation, Seychelles, Switzerland,
Thailand, USA, IADSA, IFFO.
Discussion of data received in response to the CL 2013/7-FO
4.
As a result of the data we received in response to CL 2013/7-FO, we suggest to limit the Proposed Draft
Standard for Fish Oil to unspecified fish oils and fats and furthermore to a few named fish oils for which sufficient data was submitted. The Standard could be extended to other types of named fish oils at a later stage, when sufficient data is available.
5.
The survey’s objective was to identify the types of fish oil which are significant items in trade (volume and value) and whether for those the fatty acid composition of several batches would allow the definition of a distinct fatty acid profile. The original data received were transferred in two spreadsheets
(attachments trade_data.xls
and analytic_data.xls
). Table I of this document summarizes the information submitted by members of the eWG as trade and as analytical data. Unfortunately there were only little data submitted, especially the analytical data were partially unclear.
6.
Remarks on trade data: production and trade volumes and their value (in USD) were submitted by producers & exporters, importers, and organizations representing producers and users. In general, data are inconsistent and difficult to reconcile. For anchovies e.g. several parties report large production and trade volumes of anchovy oil from Latin American countries which suggest that these oils are derived from one species or a major species ( E. ringens ); one major producer, however, states that anchovies form shoals with other fish species and that these differ between areas which would suggest that the country does not export anchovy oil as such but a fish oil consisting of oils obtained from different fish species. Similar inconsistencies are also obvious for other types of fish oil. Since the objective was not to produce robust trade data but to assess the importance of single fish oils in trade, production, (internal) consumption, export, and import figures were added up without major corrections for double reporting.
Values were categorized as high (> 10'000 t/a), medium (1'000 - 10'000 t/a), and low (< 1'000 t/a). page 1 of 6

7.
Remarks on analytical data: each analytical report, reported fatty acids ranges, or existing standard (e.g.
European Pharmacopoeia) was considered to constitute one dataset. The number of such datasets and members making submissions for each fish oil was used as prime evidence for existing documentation.
Due to the limited number of analytical data received we decided to rate as high more than 10 datasets, medium for 5 to 10 datasets, and low for not more than 5 datasets per type of fish oil. A considerable number of fish oils were not documented at all with respect to their fatty acid composition.
8.
Variability of fatty acid composition: several comments confirmed that regional and seasonal variations occur; differences may depend on ocean temperatures and catch depth, the fatty acid reflects the diet of the fish population and changes in the feed may therefore result in fluctuations of fatty acid. Due to these factors variations within a type of fish oil are expected. One eWG member emphasized that the compositional data may vary due to the analytical methods being applied (this was not investigated further since it would only be important after the eWG has decided how to proceed).
9.
Crude vs refined oil: neither the trade nor the analytical data provide sufficient information on the significance of crude vs refined oil. In the submitted information it was not specified whether the trade data of crude fish oils were for human consumption only. Therefore this information could also include fish oils used in feed or other non-food uses (pharmaceutical, cosmetic, technical).
10.
Codex standard shall be applicable to food commodities that are important for international trade. The data provided by eWG members may be ranked easily according to traded quantities. In respect of the traded quantities three types of fish oil are standing out as they are being traded at amounts well beyond
10’000 tons per year: anchovy oil (mainly E. ringens), unspecified fish oils and fats, and cod liver oil
(from G. morhua). Other oils with trade between 1000 to 10000 tons per year are tuna oil, salmon/trout oil, sardine oil, anchovy oil (from E. encrasicolus), boarfish oil (crude oil from Capros aper), sprat oil
(crude oil from Spratus spratuss), herring oil, blue whiting (crude oil from Micromesistius poutassou).
Trade volumes from all other types of fish oil proposed by the submitting countries are below 1000 tons per year. We were not in a position to rank the fish oils according to their value, as there was insufficient data concerning the value of the fish oils. Nevertheless, the few data on the value received seem to support the proposed ranking according to trade volumes.
11.
With respect to setting standards for certain types of fish oils using their fatty acid composition, a representative number of datasets will be needed to understand regional and seasonal variation and to define ranges for typical or for all fatty acids. Members and observers submitted analytical data for single batches, aggregated ranges of fatty acids (no explanation how the ranges had been derived were usually offered), and ranges of fatty acids from valid regulatory standards (notably European
Pharmacopoeia). More than ten datasets were submitted for anchovy oil (mainly E. ringens) and tuna oil
(several species). Between 5 and 10 datasets (including an official standard) were submitted for cod liver oil (from G. morhua), Pacific saury oil (Cololabis saira), boarfish oil (C. aper), mackerel oil (S. japonicus). For all other types less than 5 datasets are available.
12.
The available data allow identifying three categories of fish oils that are very significant due to their trade volume: anchovy oil (mainly E. ringens), cod liver oil, and fish oils and fats (unspecified). Of those oils for which reported trade data indicate medium importance tuna oil stands out because of the quantity of analytical data that have been submitted which indicate a possibly significant trade not yet fully reported. Considering the data on importance in trade and the robustness of analytical data, a future fish oil standard could include in a first step the following types of fish oil: page 2 of 6

Fish oil
Anchovy oil (mainly E. ringens)
Fish oils and fats (unspecified)
Cod liver oil (from G. morhua)
Tuna oil
Fish oils and fats (further specified by their source)
Comments
Available fatty acid composition confirms proposal of first draft; refinement to be discussed.
Generic standard not based on species-specific fatty acid description; it would be possible to state e.g. content range/minimum content for specific fatty acids (e.g. DHA/EPA, singly or in combination)
Available fatty acid composition confirms proposal of first draft; refinement to be discussed; available standard from Eur. Pharm. could be used as reference
At least five species mentioned as commercially important; for analytical data the breakdown by species is not sufficiently well documented to conclude that ranges of fatty acid would apply to oils from all species traded as tuna oil; commercial importance of tuna oil is not yet fully evident from available trade data.
If included into the standard, this could not be based on fatty acid composition due to limited or lack of analytical data. Other means of documentation/ verification of the source would be required.
Questions to the eWG
13.
The eWG is invited to consider the following issues for developing the Draft Codex Standard on Fish
Oils further: a.
Do you agree with the conclusions that according to the submitted trade data the major specific fish oils of relevance are Anchovy and Cod liver? b.
A considerable set of analytical data for Tuna oil were submitted by several members and observers. Although trade data are limited it seems that Tuna Oil is nevertheless traded in important quantities. Members of the eWG are asked to submit data in regard of Production,
Import and Export of Tuna Oil. c.
Based on trade importance and available analytical data it is proposed to include in the first round only a small number of specific fish oils (anchovis oil from E. engraulens, cod liver oil, tuna oil). Do you agree that other specific fish oils can be included at a later stage provided sufficient data demonstrating their relevance in international trade and describing well their fatty acid composition? d.
Should the ranges of fatty acid remain the only and decisive reference to define the source and species of a fish oil to be included in the standard? e.
If not, what other qualitative / quantitative criteria should be used to define fish oils/fats to be covered by the Draft Standard on Fish Oils? f.
If a generic fish oil standard would be more suitable, what would be the essential qualitative and quantitative characteristics for such a standard? page 3 of 6

Table 1: Trade and analytical data submitted by eWG members and their relative importance and quality
The specific fish oils are listed according to their reported trade importance
Designation Fish species Trade data
(submissions)
Anchovis oil Engraulis ringens
6
Cod liver oil
Fish fats & oils
Tuna oil
Mackerel oil
Gadus morhua
Not specified / mixtures
Various species
(min. 5)
Scomber scombrus
Boarfish oil Capros aper
Salmon
(Trout) oil
Sardine oil
Herring oil
Salmon salar
Oncorhync hus mykiss
Sardine
(main species)
Clupae harengus
4
5
3
1
1
2
1
2
Production (t)
Consumption (t)
Export (t)
Import (t)
159'704
5'603
157'053
25'020
9'850
1'105
12'434
10'564
-
-
74'810
84’753
700
25
1375
1705
150
-
6'000
-
-
-
8'000
-
3'762
260
3'002
-
-
-
-
1'700
-
-
4'418
-
Value for column to the left
(1000 USD)
341'847
14'587
463'321
-
23'725
615
39'262
18'918
-
-
79'015
50'156
-
-
-
-
-
-
-
-
315
-
-
-
6'275
-
5'400
-
-
-
-
-
-
-
> 666
-
Crude oil
Refined oil
X
X
Trade importance
(high / medium
/ low)
High
(> 10'000 t/a)
X
X
X
X
X
X
X
-
X
-
X
X
-
-
X
X
High
(> 10'000 t/a)
High
(> 10'000 t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Analytical data:
Single datasets
(submissions)
41
(6)
7
(4)
-
27
(9)
7
(3)
6
(1)
1
(1)
3
(2)
4
(1)
Species covered
(datasets)
E. japonicas (4)
E. sp. (1)
E. ringens (8)
Gadus morhua (5)
-
Thunnus spp. (5)
Thunnus obesus (1)
K. pelamis (1)
S. japonicas (3)
S. scombrus (43)
Capros aper
S. salar (farmed) (1)
Not given
Clupae harengus
Quality of analytical data
(high / medium / low)
High
> 10 datasets
Medium
5 – 10 datasets
Not available
High
> 10 datasets
Medium
5 – 10 datasets
Medium
5 – 10 datasets
Low
< 5 datasets
Low
< 5 datasets
Low
< 5 datasets page 4 of 6

Designation Fish species Trade data
(submissions)
1 Blue whiting Micromesistius poutassou
Anchovis oil
Pollock liver oil
Engraulis encrasicolus plus others
-
1
1
Krill oil
Menhaden oil
Sprat oil
Squid oil
Fish liver oil
Capelin oil
Calanus oil
Euphasia superba
Menhaden
(main species)
Spratus spratuss
Illex argentinus, Dosidicus gigas,
Todarodes pacificus
-
Mallotus villosus
Calanus s.I.
(mainly)
1
1
1
1
2
1
1
Production (t)
Consumption (t)
Export (t)
Import (t)
-
-
2'000
-
-
-
8'422
-
100
-
100
-
1'000
-
925
-
-
-
-
200
-
-
500
-
> 400
-
-
-
-
-
52
924
100
-
100
-
-
-
-
-
Value for column to the left
(1000 USD)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24'657
-
-
-
-
-
-
-
-
> 2'000
> 500
> 2'000
-
-
-
1'341
9'420
-
-
-
-
> 4'000
> 500
> 3'500
-
Crude oil
Refined oil
X
-
X
-
X
-
Trade importance
(high / medium
/ low)
Medium
(1'000 - 10'000 t/a)t/a)
Medium
(1'000 - 10'000 t/a)t/a)
Low
(< 1'000 t/a)
-
X
-
-
X
-
-
X
X
X
X
-
-
X
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Low
(< 1'000 t/a)
Analytical data:
Single datasets
(submissions)
2
(1)
-
1
(1)
2
(1)
1
(1)
2
(1)
-
-
-
-
Species covered
(datasets)
Micromesistius poutassou
-
Theragra chalcogramma
(Pollock oil or
Pollock liver oil)
Not given
Not given
Spratus spratuss
-
-
-
-
Quality of analytical data
(high / medium / low)
Low
< 5 datasets
Not available
Low
< 5 datasets
Low
< 5 datasets
Low
< 5 datasets
Low
< 5 datasets
Not available
Not available
Not available
Not available page 5 of 6

Designation Fish species Trade data
(submissions)
Pacific saury oil
Cololabis saira
-
Production (t)
Consumption (t)
Export (t)
Import (t)
-
Value for column to the left
(1000 USD)
-
Crude oil
Refined oil
-
Trade importance
(high / medium
/ low)
No data provided
Analytical data:
Single datasets
(submissions)
5
(1)
Species covered
(datasets)
Cololabis saira (5)
Quality of analytical data
(high / medium / low)
Medium
5 – 10 datasets page 6 of 6