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Prosjektnummer: 901638
Status: Pågår
Startdato: 16.04.2020
Sluttdato: 30.11.2020

Studies on moisture levels in clipfish (cod and saithe) and methodologies applied by customs authorities (CLIPTURE) / Dokumentasjon av vanninnhold i klippfisk og saltfisk for eksport til Brasil (CLIPTURE)

​Brazil is one of the most important markets for the Norwegian clipfish industry. The Brazilian government made effective the new technical regulation for salted fish and clipfish by publishing the Instruçao Normativa nº1, do 15 de janeiro de 2019. Among others, this regulation listed denominations for different salted fish cuttings, unacceptable defects, and sampling and microbiological criteria to be applied by custom authorities. It also laid down the differentiation between dried-salted fish (peixe salgado seco), which can contain up to 52.9% moisture content, and salted fish (peixe salgado) which may vary between 53% and 58%. The categorization of goods in one or other category leads a different tariff duty.

The FHF project ‘Updating of analytical data for the nutritional labelling of traditional (klipfish, saltfish, stockfish) fish / Revisjon av analysedata om næringsinnhold i konvensjonelle produkter (klippfisk, saltfisk og tørrfisk)’ (FHF-901307) updated the analytical data of four species of dried salted fish exported by Norwegian companies. Among other results the average moisture contents of dried-salted fish was measured. The moisture method used and the sample preparation was based on the cross-sectional method of the Portuguese Decreto Lei 25/2005 (Decreto Lei nº 25/2005 de 28 de janeiro do Ministério da Agricultura, Pescas e Florestas. Diário da República – I Série-A. Nº20), but with some modifications.

Some companies informed of certain discrepancy on the analytical methodologies to measure moisture content put into force by different Brazilian customs offices, and this similar criterion may have been causing uncertainty and customs issues to the Norwegian industry.

The Brazilian Agriculture Ministry (Agricultura, Pecuária e Abastecimento) includes in its Manual de Métodos Oficiais para Análise de Alimentos de Origem Animal (Official method manual for the analysis of food products from animals) detail of the procedure that should be implemented by official Brazilian laboratories (LFDAs and accredited). This document acknowledges either ISO1442:1997 or AOAC 2008.06 as valid general methods to determine the moisture content in general food samples; but, considers the AOAC 950.46B (Moisture in meat) method as the one to be applied to salted and dried salted fish products. Nonetheless, a reference method for the determination of moisture content in food products from an animal origin (MET POA/SLAV/27/03/01) is available at the archive of methods from the Brazilian Ministry website here, but it is obsolete at present. This reference determines different sample weigh and drying conditions for each type of food sample, that are similar, but do not match, the AOAC 950.46 criteria; and it does not address the sample preparation for analysis.

The previously cited Brazilian manual for the analysis of food products from animals (MET POA/SLAV/27/03/01) represents the only reference available for the sample preparation of salted and dried-salted fish in Brazil (section 5.1.3). Even though it lays down that the cross-section method described in the CODEX-STAN 167-1989 can be implemented, but it also includes some additional methodological aspects that are somehow contradictory to this reference and can eventually lead to misunderstanding by laboratory operators.

Despite the moisture content method is probably one of the simplest physical-chemical methods to be applied on food, there are some discrepancies between methods, especially in the laboratory sample preparation.

To widen knowledge about clipfish materials for better labelling and trade is within the priorities of the ‘clipfish and saltfih’ sector in 2020. As a tool to potential trade issues and promote fairness, effectivity and homogeneity in the inspection of imported clipfish by custom authorities in third countries, the objectives of this proposal become necessary.  

Based on the arguments stated above, the Norwegian clipfish and saltfish industry considered it necessary to extend the studies carried out in the former FHF project FHF-901307, mentioned above, for cod and saithe moisture levels and its variation among producers. A comparison between different methodologies seems also necessary in order to unveil potential methodological variance in the evaluation of the imported lots by the Brazilian authorities. Finally, since cross-section methods are commonly applied to salted and dried salted fish, it has been also considered of interest to define the degree of variation in the fish length.

The project will fully be executed at the Advanced Center of Research Technologies for Marine and Food Industry (CYTMA) belonging to ANFACO-CECOPESCA.

ANFACO-CECOPESCA's testing laboratories are accredited in accordance to Standard UNE EN ISO 17025 by the ENAC (Spanish National Accreditation Body), with accreditation numbers 96/LE230 (SCOPE OF THE 96/LE230 ACCREDITATION)-Agrifood analysis). The ENAC being a signer of the EA (European Cooperation for Accreditation) Multilateral Agreement on the mutual reliability with regard to testing, as well as the technical examination it involves, this accreditation means that the accredited tests coming from ANFACO-CECOPESCA are valid to any of the signing countries in this agreement. ANFACO-CECOPESCA´s laboratories have a large list of certifications and acknowledgements by national and international Authorities to perform official controls in foodstuff, technical assistance, R&D and training activities.
1. To provide, with a scientific approach, the difference between moisture methodologies and consequent deviation acceptance used as a basis for correct labeling of clipfish or saltfish exported to Brazil.
2. To document nonconformities/variation in test results due to size and species.
3. To compare differences in moisture evaluation derived from the application of the Annex B of CODEX STAN 167-1989 versus current Brazilian methodology.
4. To calculate the variation degree in moisture content in a split clipfish piece.
5. To define a new sampling procedure that could be easier, avoids misunderstandings and show same results as the cross-sectional method from CODEX STAN 167-1989–Annex B.
6. To write a scientific publication to be used by the industry when meeting food authorities in Norway and in Brazil.
The extension of the studies on the moisture levels in the final products will bring more confidence to data reducing uncertainty of Norwegian clipfish exporters at border inspection.

Detailed information on the methods performance will also help discussion about their suitability to clipfish inspection and understand the differences on the results when different methodologies are applied. The information gathered can also help to update, simplify and homogenize criteria on the application of moisture content methods to clipfish and saltfish, not only to the industry but also to the authorities in Brazil and Norway.
​The project consists of four tasks:

Task 1: Sampling 
Sampling will be carried out by Norwegian producers and co-ordinated by FHF with the assistance of ANFACO-CECOPESCA. Dried salted samples will be supplied by Norwegian companies and shipped to Vigo (Spain) under the common co-ordination of FHF and ANFACO-CECOPESCA.

The number of fish has been defined for each one of the objectives. Studies are focused only in cod (Gadus morhua) and saithe (Pollachius virens). Several Norwegian companies will participate in the studies. Sampling will also include size categories; 3 size categories for cod (7/9, 8/10, and 10/12) and 3 size categories for saithe (7/9, 10/12, and 16/20). Each of the categories will include up to 20 total samples for each category in order to get statistically significant results.

Upon reception all samples will be categorized and labelled according to analytical planning. Materials will be maintained at the cool chamber (2ºC) appropriately packed to prevent moisture loss until analysis.

​Task 2: Determination of average moisture contents in clipfish its variation.
Four samples in each of the size categories will be analyzed. The method to be applied is the cross–sectional method included in Annex B of Codex Stan 167-1999, specially to what concerns to the laboratory sample preparation. This reference considerably varies from the accredited method at ANFACO-CECOPESCA and special plates will be used to process a higher amount of sample.

Since the 8/10 size category in cod sampling will also be part of Task 3, two replicates of each sample will be carried out and the averaged results will be considered.  

Task 3: Method performance comparison and moisture variance in fish length
This task will compare the performance of two method references; the Codex method and the moisture content method applied by the Brazilian Authorities. Only cod samples from one defined size category (8/10) from the 5 different suppliers will be analyzed in duplicates. Reciprocally to what was mentioned above, the results of the CODEX method will also be utilized in Task 1.

From the same fish utilized for the method comparison, three additional sections of 25 mm will be prepared. The anterior cross-section will be selected at the pectoral fin (just after), the medium at half the distance between the line at the ear bones and the cleft of the tail, and the posterior at the annus (just after). After excluding bone and skin, each of three sections will be mechanically grinded and analyzed following the MET POA/SLAV/27/03/01. After being weighed for drying the three samples will be homogenized making up the sample that would represent the entire fish in the method comparison. This aggregate sample will be analyzed in the same way, and simultaneously as the other three samples, but in this case for duplicate.

Task 4: Project co-ordination, data analysis and reporting
This task includes all aspects related to project task monitoring, contact and discussion, project plan changes and communication to FHF including the submission of documents related to project management. This task also addresses the data analysis, the development of the deliverables, factsheets or presentations that could be necessary for the appropriate dissemination of the project. ​
​Dissemination of the project will be carried through the FHF channels and the relevant industry meetings and info-sheets. The deliverables are also intended as reference documents to be included in discussions between Norwegian authorities and other third countries´ bodies.