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Sec. 540.700 Processed and/or Blended Seafood Products (CPG 7108.16)
BACKGROUND:
In recent years, a number of processed seafood products have been produced. Some of these products made to resemble and promoted as substitutes for crabmeat, shrimp, lobster, scallops, and other natural seafoods, have been developed and sold in the United States. The National Marine Fisheries Service and several trade associations are cooperating with FDA by providing information regarding the manufacture and promotion of these products that are composed, all or in part, of surimi.
Surimi is an intermediate processed seafood product used in the formulation/fabrication of a variety of finished seafood products. It is normally traded in 10 kg. frozen blocks which are individually wrapped in waxed cardboard boxes. Surimi is minced fish meat (usually pollock) which has been washed to remove fat and undesirable matters (such as blood, pigments, and odorous substances), and mixed with cryoprotectants (such as sugar and/or sorbitol for a good frozen shelf life). In formulating finished seafood products, surimi is thawed and blended with other ingredients and additives such as natural shellfish meat, and/or shellfish flavoring, salt, water, and starch and/or egg white; and processed by heat for making fibrous, flake, chunk, and composite-molded consumer products. The finished products are marketed frozen or unfrozen and may be breaded.
The following guidance is in response to inquiries FDA has received regarding the proper labeling for surimi-based seafood products.
POLICY:
1. If the surimi-based product purports to be or is represented as any specific type of natural seafood, including shape or form representations, but is nutritionally inferior to that seafood, it must be labeled as imitation in accordance with 21 CFR 101.3. To date FDA has not encountered any surimi-based product in which nutritional equivalency has been achieved.
2. An additional statement of product identity must appear on the principal display panel such as "A Blend of Fish with ______." The blank is to be filled in with the common or usual name of the ingredient or component, such as "snow crab". Because the fish used in the surimi-base has been decharacterized, the word "fish" is adequate for the statement of product identity. If an artificial flavor or color is added, the label must comply with 21 CFR 101.22.
3. The specific names of all seafoods used in the product shall appear in the
ingredient statement in descending order of predominance ("pollock" must be used
as opposed to "white fish;" "snow crab" rather than "crab").
All other ingredients present must also be declared in descending order of predominance.
The intermediate surimi product usually contains sugar and/or sorbitol and phosphate compounds as cryoprotectants. These should be listed in the ingredient statement unless removed during the manufacturing process.
4. Products that are not purported or represented to be a specific type of seafood or
seafood body part, need not be labeled imitation, but may be marketed if the label
properly reflects their composition.
5. Labeling of surimi-based products may suggest use in recipes in place of natural seafood products by a generalized statement such as "use like crabmeat, lobster, or shrimp in all seafood recipes," or a similar statement.
Issued: 6/3/85
Reissued: 10/30/89