E500 in Fishery Products


Suffolk Coastal Port Health Authority

Issue Number 01 | August 2013 |


Port Health Update - Imports of Products of Animal Origin

E500 (Sodium carbonates including bicarbonate) in Fishery Products

Commission Regulation 1333/2008 establishes the EU list of approved food additives. Annex II of this regulation was amended by Commission Regulation 1129/2011 on 1st June 2013. Annex II provides the details of which additives are approved and their E numbers, in what quantities, in different categories of food under specific conditions.

E500 is listed as an approved food additive, however there are restrictions on its use.

Processed Fish

E500 is permitted in processed fish and fishery products including molluscs and crustaceans, up to the maximum levels specified in part C of Regulation 1129/2011. This represents no change from the previous requirements. Imports of consignments of processed fishery products that contain E500 should have it declared as an ingredient. 

Unprocessed Fish

E500 is not permitted in unprocessed fish. However if the unprocessed fishery product is sold with another ingredient, such as a glaze or sauce, that ingredient may contain additives in its own right. Sauces and glazes (which fall within food category 12.6 (sauces) in Annex II of Regulation 1333/2008) are permitted to contain E500 which would have to be labelled as an ingredient in order to comply with import conditions. 

Definition of Unprocessed

Article 3 of Regulation 1333/2008 defines 'unprocessed food' as a food which has not undergone any treatment resulting in a substantial change in the original state of the food. The following in particular are not regarded as resulting in substantial change: dividing, parting, severing, boning, mincing, skinning, paring, peeling, grinding, cutting, cleaning, trimming, deep-freezing, freezing, chilling, milling, husking, packing or unpacking.

Therefore, as an example, frozen skinless raw tilapia fillets are regarded as unprocessed fish for the purpose of this additives regulation. As such E500 would not be permitted in this product. 


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