Traceability and labelling of fresh fish:what the buyer should demand

01

Which mentions are mandatory?

For a mixture of lots of the same species, the method of each lot must be given, and at least the area of the lot that is largest in quantity, stating that the product also comes from other areas (Art. 35, paragraph 3).

Article 39 lists the voluntary information, allowed if it is verifiable: date of catch or landing, port of landing, detailed gear, flag of the vessel, environmental information. A "landed at Le Guilvinec on 12 October" is not mandatory, but it can be checked.

02

What must the traceability document contain?

Each lot must remain traceable at all stages, from catch to retail. A lot may only be merged or split after first sale if it is still possible to trace it back to the boat (Regulation (EC) No 1224/2009, Art. 58).

Since 10 January 2026, the revision of the control regulation (Regulation (EU) 2023/2842) requires downstream operators (fish merchants, wholesalers, distributors) to pass on this information electronically. In the absence of a common format, the French Ministry for the Sea accepts an email from one operator to the next, with the information in the body of the message or in an attached PDF. The minimum information per lot:

1. the lot identification number;
2. the identifier of the fishing trip or fishing day (or, for farming, the producer), or for an imported product the vessel identifier and the catch certificate number;
3. the three-letter FAO code of the species and its scientific name;
4. the catch or production area;
5. the fishing gear category;
6. the date of catch or harvest;
7. the quantity in net kilos, or the number of pieces;
8. where applicable, the quantities below the minimum size, separately;
9. the information required by marketing standards (freshness category, size grade).

The product also carries the health identification mark of the plant that prepared or dispatched it: an oval with "FR", the establishment's approval number and "CE" (Regulation (EC) No 853/2004, Annex II). It is this mark that makes it possible to trace back to the fish merchant in the event of an alert.

03

What must the fishmonger display?

The five mentions of Article 35 must be brought to the consumer's attention. For non-prepacked fish, they can appear on a sign, a slate or a poster at the counter (Art. 35, paragraph 2), next to the price per kilo. The area can be given by its common name or by a map.

04

And the restaurant owner?

A restaurant is one of the "mass caterers" within the meaning of European law: its supplier must therefore pass on the Article 35 mentions to it. The obligation to display origin in the dining room, introduced in food service by Decree No 2002-1465 and extended by Decree No 2022-65 of 26 January 2022, does not cover fish. Three obligations do apply, however:

• Allergens. Fish, crustaceans and molluscs are among the fourteen allergens to be declared (Regulation (EU) No 1169/2011, Annex II). In France, the information must be given in writing, displayed or directly available to the customer (Consumer Code, Art. R412-14).
• An honest menu. What is written must be true: a "bar de ligne" (line-caught sea bass) on the menu must be a sea bass caught on a line, and a "Saint-Pierre" (John Dory) cannot be another species. Keep the documents that prove it.
• Raw or lightly cooked fish. Tartare, ceviche, sushi: except for the exceptions provided by the text, wild fish must be frozen to the core for at least 24 hours at -20 °C, or 15 hours at -35 °C, to kill parasites (Regulation (EC) No 853/2004, Annex III, Section VIII). Fish treated in this way does not have to carry the mention "defrosted".

05

The receiving checklist to print

To tick parcel by parcel, before signing the delivery note. It is a benchmark: complete it with the documents your suppliers send you.

Documents

• Delivery note or invoice: supplier, date, species, net weights
• Lot number on each line, identical to the parcel label
• Traceability information received (email, PDF or attached document)

Label on each parcel

• Commercial designation and scientific name
• "Caught", "caught in freshwater" or "farmed"
• FAO area with subarea or division for areas 27 and 37 (country of farming for aquaculture)
• Fishing gear category
• Mention "defrosted" if the product has been frozen
• Date of minimum durability for prepacked products
• Oval health identification mark (FR, approval number, CE)
• Net weight

Consistency

• The species delivered matches the scientific name (a pollack is not a saithe)
• The area is plausible for the species and the season
• Size grade and presentation as ordered

Live shellfish and crustaceans

• Health label present, with packing date
• Label kept for 60 days after splitting

Archiving

• Delivery notes, labels and traceability emails filed by date, retrievable in the event of an alert

06

The FAO areas useful to buyers of French seafood

Official names: European database of commercial designations and fishing areas. Boundaries: Regulation (EC) No 218/2009, Annex III, and the subareas of the General Fisheries Commission for the Mediterranean; editorial summary, as a benchmark.

Outside areas 27 and 37, the name of the main FAO area is enough on the label (Art. 38): for example Northwest Atlantic (21) for a lobster caught in Canada, Indian Ocean (51 and 57) or Western Central Pacific (71) for imported prawns or tuna.