5522 Fish Finger A2 poster PRINT.qxp

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Food law – ‘fish fingers’ deficient in fish
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Added water not taken into account in the fish block ingredient
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S. Elahi, M. Walker, K. Thurlow, P. Colwell
Government Chemist Programme
LGC, Queens Road, Teddington, Middlesex, TW11 0LY, United Kingdom
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law requires a pre-packed food such as this
to be labelled with a declaration of the
amount of fish present. The product as sold
was labelled with the declaration “65%
Minced White Fish”. Analysis of a portion of
the sample by the Public Analyst had shown
that the amount of fish present was lower
than declared fish content. The Government
Chemist was asked to carry out a definitive
analysis of the fish content of the sample.
Method
There is no direct method for the
determination of the fish content of a finished
product. The Stubbs and More method for the
determination of the meat content of a product
is widely accepted. It is based on the amount
of nitrogen in a sample, corrected for non-fish
nitrogen, compared to the mean nitrogen
content of the species. The nitrogen factor is
the mean value for the percentage nitrogen
content of the species of fish used and varies
naturally, even within the same species,
because of factors such as different fishing
grounds, size, sex or spawning cycles.
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The study
Fish fingers are normally made from “white
fish”. Originally the fish of choice was cod,
but depleted stocks have led to the use of
other fish of high quality, for example
haddock. Many products are now labelled as
containing “fish” or “white fish”, which allows
the manufacturers to use fish from a variety
of sources. Food law in the EU (Directive
2000/13/EC) requires a quantitative ingredient
declaration (QUID) of the amount of fish for
a pre-packed product named ‘fish fingers’.
The quantity should be calculated on the
basis of fish expressed as a percentage of
the total weight of all the ingoing ingredients
(except for the weight of added water or
volatile ingredients lost in processing).
Buckinghamshire Trading Standards carried
out a nutritional survey of fish fingers in 2005
and discovered that some samples appeared
to have less fish than claimed on the label.
Further, formal samples were taken, and the
Public Analyst reported that the fish content
in one particular sample was 57 %, which
was significantly lower than the 65%
declared. The labelling of the product listed
the ingredients as:-
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Is there more to
A sample of fish fingers was submitted under
the
provisions
of the Food
Safety Act 1990 (a
this
than
meets
“referee sample”) for determination of the
amount
ofeye?
fish present. In order for
the
consumers to make informed choices, food
Background
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The case
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[email protected]
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Minced White Fish (65 %), Wheat Flour,
Water, Wheat Starch, Iodised Salt,
Skimmed Milk Powder, Spices, Yeast,
Flavourings.
Figure
2 - Single salt crystal at
high magnification
% Fish content =
Total Corrected Nitrogen x 100
Nitrogen factor
To avoid over estimating the fish content,
nitrogen that does not originate from fish
must be excluded from the calculation.
Wheat flour, skimmed milk powder and yeast,
although principally carbohydrates all contain
nitrogen. There is no single method suitable
for the determination of carbohydrate in a
food. The Stubbs and More method typically
determines total ‘carbohydrate’ by difference
[100 – (Protein + Water + Fat + Ash)], where
Protein = N x 6.25, and applies a correction
based on the ‘carbohydrate’ nitrogen content.
Results and outcome
The sample was divided into two equal
portions of 125 g. The breadcrumbs and
coating were removed from the flesh in one
half of the sample, then the flesh was blended
and analysed for proximates, i.e. moisture,
nitrogen, fat and ash using methods which
were originally recommended by the AMC and
have been subsequently been adopted as
British Standards. With the other half of the
sample, the entire product was blended and
proximates determined. Treating the sample in
this manner allowed corrections to be made for
sources of non-fish nitrogen.
The mean results obtained on analysis of
homogenised whole product were as follows:-
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Analysis
Nitrogen factor
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Fish content
(g/100 g)
Measurement
uncertainty
(g/100 g)
Analyte
Result
(g/100 g)
Moisture
Fat
Nitrogen
Ash
61.1
8.9
1.62
1.56
The Trading Standards led the
joint prosecution, resulting in
the trader pleading guilty to two
offences of falsely describing
the fish content of fish fingers contrary to Section 15(1) (a) of The Food Safety Act 1990. Fines of
£2500 for each offence were imposed and costs of £995 awarded to Buckinghamshire Trading
Standards. The maximum penalties available to magistrates in such a case are £5000 fine or
imprisonment for up to six months. It is clear therefore that the magistrates regarded this as a
serious breach of food law.
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Hoki (2.464)
White fish (2.65)
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For more information and references please see www.governmentchemist.org.uk/Function.aspx?elementId=537
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