USFDA IMPORT BULLETIN 16B-95, May 1999

"TASTELESS SMOKE AND/OR CARBON MONOXIDE"

This bulletin responds to numerous complaints that FDA has received on the importation and distribution of frozen tuna that has been processed with "tasteless smoke" (TS) or carbon monoxide (CO). This treatment may be applied to tuna processed in Indonesia, the Philippines and Taiwan.

TS or CO is used to preserve (fix) the natural red flesh color of tuna during frozen storage. These agents may also be abused to enhance the

color, making the product look of better grade or quality than it is. The complaints are from manufacturers, distributors, and federal and state agencies. Imported tuna treated with TS or CO should be:

* labeled as processed foods that have been treated with CO or TS,

* and not misrepresented as fresh frozen seafood by their label,and

* near normal in flesh color.

For example, at a minimum, the ingredients statement should include "tasteless smoke (preservative to promote color retention)," consistent with the labeling requirements of 21 CFR 101.22 (j). Such treated products are misbranded when labeled as "Smoked Tuna," "Lightly Smoked Tuna," and "Cold Smoked Tuna" because these are the common or usual names for traditionally processed smoked-flavored fish.

Tuna treated with either TS or CO that is not labeled to indicate it contains a preservative purports to be unprocessed, fresh or fresh frozen tuna and is, therefore, misbranded. These processed seafood required label declarations under 21 CFR part 101, including nutrition information.

Treatment with TS or CO causes the flesh color to persist upon thawing and holding near room temperature. This color-fixing attribute provides a means of testing suspect tuna that may have been treated, but not labeled as outlined above. The length of time the color persists will vary with the agent and extent of exposure to TS or CO. In the most obvious case of misbranding, the product will appear to have an enhanced or unnatural red coloration, and its labeling will not indicate that it has been treated. In addition to being misbranded, color enhanced products may be deemed to be economically adulterated under Section 402 (b)(4) of the Federal Food, Drug, and Cosmetic Act.

FDA believes that the application of these preservatives might be abused.

The flesh of treated products may display an artificial, unnaturally bright red coloration, but the degree of color enhancement may vary. Tuna that has an artificial, enhanced red color may have been exposed to TS or CO but not labeled. This product should be analyzed for decomposition and histamine, since there is no official method to test for TS or CO.

Tuna treated with TS and/or CO must bear appropriate label declarations, or the product is misbranded.

Any inquiries regarding this Import Bulletin should be referred to Frank Sikorsky at (202) 205-4606.

PRODUCT CODE: 16A--45; 16D--45; 16-B95; 16A

Products are also misbranded if their labeling fails to include other to make lower or inferior grades look better, and to mask decomposition.

EXPIRATION: 90 Days from date of issuance.

KEY WORDS: Tuna, Smoked, Carbon Monoxide, Tasteless Smoke

FOI: No purging is required.