Cephalopods / 0303 / 0304

The FAO (1998) published guidance on the major commercial cephalopods in the Western Central Pacific Ocean(Thailand, Malaysia, Cambodia, Indonesia, Vietnam and the Philippines) which included nautilus, cuttlefish, squid and octopus (ftp://ftp.fao.org/docrep/fao/009/w7192e/w7192e02.pdf).


Fresh cephalopods are extremely perishable and should be handled in such away as to prevent contamination and reduce the growth of micro-organisms.
The table below shows the average export values of cephalopods at the HS 6 digit level to the EU market between 2007 and 2011.

COMMODITY DESCRIPTION HS CODE Average annual value of Indonesian exports to the EU (US$)2007-2011
Octopus, Frozen, Dried, Salted or in Brine 030759 18,061,589
Cuttle Fish and Squid, Frozen, Dried, Salted or in Brine 030749 11,133,169
A description of fish processing, including hygiene and food safety requirements, can be found in the Codex Alimentarius Code of Practice for Fish and Fishery Products (CAC/RCP 52-2003). This includes a consideration of processing cephalopods (Section 15).  The Code also stresses the application ofappropriate elements of the prerequisite programme (Section 3) and HACCP principles (Section 5) in order to provide the processor with reasonable assurance that the essential quality, composition andlabelling provisions will be maintained and food safety issues controlled.
There is a Codex Standard for Quick Frozen Raw Squid (CODEX STAN 191 – 1995) which includes compositional and quality factors.

Diagram showing cephalopod processing (from Codex CAC/RCP 52-2003)

EU requirements are described in Regulation (EC) 853/2004 laying down Specific Hygiene Rules for Food of Animal Origin; section VIII is applicable to fishery products including vessels, landing sites, processing facilities, wrapping, packing and storage.  EU Regulation (EC) 2406/96(amended 2005) provides for marketing standards for some fishery products including freshness and weight criteria for cuttlefish.
Value Chain
The EU Food Law and related technical regulations applies throughout the value chain for primary production, distribution, handling, processing and placing on the market.The approach is also commonly called “Farm to Fork”.It is a risk assessment oriented approach in which the principle is that only control of potential hazards in every single step in the value chain will provide sufficient guarantees that the end product is safe for consumption.
A value chain is a string of companies or players working together to satisfy market demands for a particular product.For food the value chain starts with the companies/players providing input to the farmers and it ends with the sale to the final consumer.The EU Food Law applies to all such companies/players and the related technical regulations stipulate specific criteria for conditions of operation for all operators and to the extent relevant for their specific input.
A study in Morocco (major exporter) produced this value chain for octopus (Infosamak 2011):


According to the FAO (World Review of Fisheries and Aquaculture, 2012) the share of cephalopods (squid, cuttlefish and octopus) in the world fish trade was 4 per cent in 2010. Spain, Italy and Japan were the largest consumers and importers of these species. Thailand followed by Spain, China and Argentina were the largest exporters of squid and cuttlefish, while Morocco and Mauritania were the principal octopus exporters.
Main product attributes

Standards for some fishery products including cephalopods (cuttlefish) were set down by Regulation (EC) 2406/96 “laying down common marketing standards for certain fishery products” which included freshness criteria and sizes.

  Freshness category
  Extra A B
Skin Bright pigmentation,
skin sticks to flesh
Dull pigmentation;
skin sticks to flesh
Discoloured; easily
detached from flesh
Flesh Very firm; pearlywhite
Firm; chalky white Slightly soft; pinkywhite or slightlyyellowing
Tentacles Resistant to removal Resistant to removal More easily removed
Smell Fresh; seaweed Slightly or no smell Ink smell
Thailand is a major exporter of cephalopods; as described in the Thai standard for cephalopods (TAS 7005-2005 at http://www.acfs.go.th/standard/download/eng/CEPHALOPODS.pdf) fresh cephalopods consist of four species including Loligospp. (squid), Sepistenthislessoniana(soft cuttlefish), Sepia spp. (cuttlefish) and Octopus spp.
This standard further describes the butchery of cephalopods to produce eight product types which are widely traded:
(1) Whole round cephalopods: intact cephalopods with their organs complete
(2) Whole cleaned cephalopods: whole cephalopods without skin, eyes, beak and internalorgans
(3) Tube cephalopods: cephalopods without skin, gut, head and shell or chitin; with orwithout wing removal
(4) Fillet cephalopods: cephalopods as described in (3) with or without wing removal; witha cut along the body
(5) Head of cephalopods; head section with tentacles without eyes, beak and ink sac; forcephalopods in the family of Loliginidaeand Sepiidae(squid, cuttlefish and soft cuttlefish)this may be called tentacles
(6) Cephalopod’s wing; outer organs on both sides of cephalopod’s body
(7) Octopus ink off; octopus without ink sac
(8) Octopus gutted; octopus without internal organs; with or without removed eyes and beak.
These types and styles of fresh cephalopods should have the followingcharacteristics:
(1) Fresh appearance withtypical characteristics of its species and styles
(2) Natural colour
(3) No obvious defects
(4) Slightly fishy smell but no foul or objectionable odour
(5) Free from foreign matter caused by improper hygiene practices
For the purposes of trade, size and weight can be specified according to weight ranges or number per kilogram for individually frozen product (IQF) or weight per block for block-frozen product.EU Regulation (EC) 2406/96 gives some weight ranges for cuttlefish; 3 sizes are given with weight above 0.5 kg, between 0.3 and 0.5 kg and below 0.3 kg per fish.Commercial descriptions can include product shape e.g. “flower-shape”.
Typical physical and chemical characteristics of cephalopods
Quality descriptions, chemical and microbiological characteristics are defined in several specifications.  These include colour, flavour and texture and can include microbiological (TVC, coliforms, E.coli, Salmonella, Listeria, Staph aureus and C. perfringens) and chemical (histamine, mercury, cadmium, lead and arsenic) parameters.
Specifications for cephalopods
In addition to Codex standards and the EU hygiene requirements, some of the major exporting countries have published specifications for cephalopods which apply to international trade. For examplethe Thai standard for cephalopods TAS 7005-2005 and standards from the East African Community (which consists of Kenya, Uganda, Tanzania, Burundi and Rwanda). The EAC has published standards for frozen octopus (http://www.eac-quality.net/fileadmin/eac_quality/user_documents/3_pdf/CD-K-515-2010__Frozen_octopus_-_Specification.pdf), squid (http://www.eac-quality.net/fileadmin/eac_quality/user_documents/3_pdf/CD-K-539-2010__Quick_frozen_raw_squid_-_Specification.pdf) and for cuttlefish and squid (http://www.eac-quality.net/fileadmin/eac_quality/user_documents/3_pdf/CD-K-566-2010__Frozen_cuttle_fish_and_squid_-_Specification.pdf).These employ photographic standards and give the following microbiological limits:
Test Maximum limit
Total plate count 107/g
Coliforms 100/g
E. Coli 10/g
Salmonella Nil/g
Staphylococcus aureus 50/g
Faecal coliforms Nil/g
Vibroparahaemolyticus Nil
Vibrocholerae Nil/g
And for chemical contaminants:
Test Maximum limit
Histamine 50 ppm
Mercury 1 ppm
Total volatile base 25 mg/100g
Lead 0.5 ppm
Cadmium 0.1 ppm
Sensory and physical examination should be assessed by persons trained in such examination and in accordance with the procedures in the Standard and in the Guidelines forthe Sensory Evaluation of Fish and Shellfish in Laboratories (CAC/GL 31 - 1999).
Packs for retail sale in the EU should be labelled according to Directive 2000/13 on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs (which is replaced by Regulation 1169/2011 with effect from 2014) or theCodex General Standard for the Labelling of Prepackaged Foods (CODEX STAN 1-1985), as appropriate.
Analytical methods

Histamine HPLC
J. AOAC Internat. 1996, 79, 43-49. (EU Regulation (EC) 2073/2005)
AOAC 977.13
Nitrogen Extraction & distillation ISO 937:1978
Moisture Gravimetric ISO 1442:1997
Fat content Gravimetric ISO 1443:1973
Mercury Flameless atomic absorption
AOAC 977.15
Lead Atomic absorption spectrophotometry
(direct graphite furnace)
AOAC 994.02
IUPAC 2.623
ISO 12193:1994
(Codex general method)
Cadmium Graphite furnace atomic absorption spectrophotometry (GFAAS) ISO 15774:2001
Tin Atomic absorption spectrophotometry AOAC 985.16 (Codex general method)
Dioxins GC-MS
Immunoassay kits
EU Regulation (EC) 1883/2006 and 252/2012
PAH Reverse phase HPLC-Fluorescence detection
GC-MS in development
ISO 15302:2007
ISO 22959:2009
(ISO 24054)

(*) Several methods listed in FAPAS inter-laboratory comparison for nitrofuran derivatives in honey (http://www.anvisa.gov.br/reblas/cooperacao/resultados/fapas_nitrofurano_mel.pdf).
Recommended methods of analysis and sampling (CODEX STAN 234-1999) at http://www.codexalimentarius.org/download/standards/388/CXS_234e.pdf.
See Guidelines on the use of mass spectrometry (MS) for identification,confirmation and quantitative determination of residues (CAC/GL 56-2005) at http://www.codexalimentarius.org/download/standards/10185/cxg_056e.pdf,
and guidelines on estimation of uncertainty of results (CAC/GL 59-2006) at http://www.codexalimentarius.org/download/standards/10692/cxg_059e.pdf.
Microbiological methods
There are various sources of standard methods to examine the microbiological status of foods; for example see the USDA Bacteriological Analytical Manual (BAM) at http://www.fda.gov/Food/ScienceResearch/LaboratoryMethods/BacteriologicalAnalyticalManualBAM/ucm071363.htm.
Also Bergey's Manual of Determinative Bacteriology at http://www.bergeys.org/index.html
Test Method
Total plate count ISO 4833
Coliforms ISO 4832
E. Coli ISO 7251
Salmonella ISO 6579
Staphylococcus aureus ISO 6888
Faecal coliforms ISO 4832
Vibroparahaemolyticus ISO/TS 21872-1
Vibrocholerae ISO/TS 21872-1
Chemical Safety (Residues & Contaminants)
Residues of Veterinary Medicines
Directive 96/23 is concerned with measures to monitor certain substances and their residues in live animals and animal products.In order to carry out this monitoring the Directive establishes that Member States should draft a national residue monitoring plan for the groups of substances detailed in Annex I. These plans must comply with the sampling rules in Annex IV to the Directive.Directive 96/23/EC establishes the frequencies and level of sampling and the groups of substances to be controlled for each food commodity.  However, this Directive refers only to aquaculture products and not wild-caught cephalopods.
Commission Regulation (EC)1259/2011 (amending Regulation (EC) 1881/2006) sets maximum levels for muscle meat of fish and fishery products.The levels are:

-     3.5pg/g wet weight for the sum of dioxins
-     6.5pg/g wet weight for the sum of dioxins and dioxin-like PCBs and
-     75 ng/g wet weight for the sum of PCB28, PCB52, PCB101, PCB138, PCB153 and PCB180

These limits have been in force since 1 January 2012.
Commission Regulation (EC) 1883/2006 lays down methods of sampling and analysis for the official control of levels of dioxins and dioxin-like PCBs in certain foodstuffs.This was amended by Regulation (EC) 252/2012 (see http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:084:0001:0022:EN:PDF).
Contamination of food and feed with dioxin and dioxin-like compounds has caused a number of incidents in the past.The US FDA has carried out various surveys of food to check for the presence of DLCs (see http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/ChemicalContaminants/DioxinsPCBs/ucm077444.htm ).Methods generally use GC with MS detection.
There is a European Union Reference Laboratory for Dioxins and PCBs in Feed and Food based in Freiburg; a proficiency test using animal fats was organised between February and April 2012.See http://www.crl-freiburg.eu/dioxin/EURL_PT_Pork_and_Lard_2012-Announcement.pdf.
The Codex Alimentarius has issued a Code of Practice for the reduction of dioxin contamination of food (see www.codexalimentarius.net/input/download/.../CXP_062e.pdf).
The European Food Safety Authority has published a review of non dioxin-like PCBs in food and feed which has some useful discussion about the general area and some references (http://www.efsa.europa.eu/en/efsajournal/doc/1701.pdf).
Polycyclic Aromatic Hydrocarbons
Processing of food (such as drying and smoking) and cooking of foods at high temperatures (grilling, roasting, frying) are major sources generating PAH.Levels as high as 200 μgram/kg food have been found for individual PAH in smoked and barbecued fish and meat.Contamination of vegetable oils (including olive residue oils) with PAH usually occurs during technological processes such as direct fire drying, where combustion products may come into direct contact the oil seeds or oil.
Regulation (EC) 420/2011(http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:111:0003:0006:EN:PDF ) amending EU Regulation (EC) 1881/2006 gives a maximum value for PAH of 5.0 μgram/kg for cephalopods.
Sampling and analysis should be carried out according toRegulation (EC) 836/2011 (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:215:0009:0016:EN:PDF).
EFSA carried out a more recent review of the scientific evidence (http://www.efsa.europa.eu/en/efsajournal/doc/724.pdf).
For methods, see the review by Wenzl et al. (2006) http://www.pfigueiredo.org/met_8.pdf.
A more recent appraisal can be found at www.fsai.ie/WorkArea/DownloadAsset.aspx?id=8416.
Heavy Metals
Regulation (EC) 1881/2006 sets the limit for lead in cephalopods (without viscera) as 1.0 mg/kg wet weight.
For cadmium the limit is 1.0 mg/kg wet weight for cephalopods (without viscera).
For mercury the limit set was 0.5 mg/kg wet weight for fishery products and muscle meat of fish and crustaceans.
The maximum level for inorganic tin in canned products (other than beverages) was set at 200 mg/kg.
The consolidated text of Regulation (EC) 1881/2006 is athttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2006R1881:20100701:EN:PDF.
Graphite furnace atomic absorption spectrophotometry appears to be able to detect a number of heavy metals (e.g. arsenic, lead, cadmium, chromium and selenium) in edible oils (see application note http://www.perkinelmer.com.cn/CMSResources/Images/46-12977544-129775APP_PinAAcleToxicMetalsEdibleOils.pdf).
A summary of official methods for the determination of heavy metals in feed and food was published by the EU Reference Laboratory for Heavy Metals in Feed and Food (http://irmm.jrc.ec.europa.eu/EURLs/EURL_heavy_metals/legislation/Documents/Official%20
Maximum levels for histamine were set in EU Regulation (EC) 2073/2005 (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2005R2073:20071227:EN:PDF) andsampling requirements were given.This criterion applies in the case of fishery products from fish species associated with a high amount of histidine (i.e. tuna).  This group does not include cephalopods although it appears that specifications for international trade may include maximum histamine levels as an indicator of quality (freshness).
Product Standards
Compositional Standards
Compositional standards apply to fishery products with respect to proximate analysis (e.g. protein and fat content) and label declarations with regard to meat content.
Microbiological criteria
Regulation (EC) 2073/2005 sets no specific microbiological limits for cephalopods.  However, limits for histamine andmicrobiological criteria can be applied for trade.  Note that there have been numerous border rejections of cephalopods from Indonesia at EU border posts due to presence of Salmonella spp.  The criterion for Listeria monocytogenes in ready-to-eat food would apply to cephalopods to be eaten raw (hiraki).
Traceability and labelling
General requirements for traceability were set out in Food Law (EU Regulation (EC) 178/2002) and were defined recently for food of animal origin (Regulation (EC) 931/2011).
EU Regulation (EC) 104/2000 gives the requirements for the marketing of fishery and aquaculture products and includes cephalopods in CN code 0307 (aquatic invertebrates other than crustaceans and molluscs, live, fresh, chilled, frozen, dried, salted or in brine).Regulation (EC) 2065/2001 (consolidated 2007)(http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:278:0006:0006:EN:PDF) lays down detailed rules for the application of Regulation (EC)104/2000 as regardsinforming consumers about fishery and aquaculture products describes the requirements for traceability.In particular, Article 8 states that information is required concerning the commercial designation, the production method and the catch area and that this shall be available at each stage of marketing of the species concerned.Thisinformation together with the scientific name of the speciesconcerned shall be provided by means of the labelling orpackaging of the product, or by means of a commercial document accompanying the goods, including the invoice.
A list of EU-approved establishments in Third Countries with their registration numbers is available at http://ec.europa.eu/food/food/biosafety/establishments/third_country/index_en.htm.
Labelling of foods in the EU is defined by Directive 2000/13 on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs.This is replaced by Regulation (EC) 1169/2011 with effect from 2014.
This Directive includes Quantitative Ingredient Declarations (QUID) which apply to ingredients that form part of the name of the food (e.g. tuna).

EU Regulation (EC) 2406/96 states that products imported from third countries may be marketed only if they are presented in packages on which the following information is clearly and legibly marked:
- country of origin, printed in Roman letters at least 20 mm high,
- scientific name of product and its trade name,
- presentation,
- freshness and size categories,
- net weight in kilograms of products in the package,
- date of grading and date of dispatch,
- name and address of consignor.
There is a Codex Standard for the Labelling of Pre-packaged Food (CODEX STAN 1-1985 last amended 2010) (http://www.codexalimentarius.org/download/standards/32/CXS_001e.pdf.
Sustainable/organic production
There appears to be little threat to the cephalopod population and therefore sustainability is not an issue.
Organic production and certification
Legislation concerning organic production and certification came into effect on 1 January 2009 and concerns the production, preparation, storage and importation from a non-EU country and the inspection bodies which control these activities.The standards are set out in Regulation (EC) 834/2007 on organic production and labelling of organic products and Regulation (EC) 889/2008 on the implementation of the rules on organic production, labelling and control.
Further to this legislation, on December 6th, 2011 the European Commission published the first list of control bodies recognised as implementing equivalent organic standards and control measures in third countries. The list is published as implementing Regulation (EU) 1267/2011 which amends previous Regulation (EC) 1235/2008 and includes aquaculture products but not fish and fishery products.
See also Codex Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods (GL 32-1999; amended 2010) at: http://www.codexalimentarius.org/download/standards/360/cxg_032e.pdf.
Areas of concern with regard to food safety in relation to the composition of food imported into the EU can be found in the activities of the Rapid Alert System for Food and Feed (RASFF); in particular, annual reports highlight recent problems.The website for the RASFF is at http://ec.europa.eu/food/food/rapidalert/index_en.htm.
There were a number (13) of border rejections of frozen cephalopods in 2012, mainly octopus, from Indonesia at EU Border Inspection Posts due to the presence of Salmonella spp.
Date Code Product Action taken Country Origin Problem found
16/11/2012 2012.1595  food information for attention ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen octopus (Octopus vulgaris) from Indonesia
09/01/2012 2012.AAW  food border rejection GREECE from INDONESIA Salmonella spp. (presence /25g) in frozen octopus (Octopus vulgaris) from Indonesia
27/02/2012 2012.ANF  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen squids (Loligospp) from Indonesia
27/02/2012 2012.ANG  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen octopus (Octopus spp) from Indonesia
08/03/2012 2012.AOY  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen cuttlefish (Sepiolaspp) from Indonesia
09/03/2012 2012.APD  food border rejection ITALY from INDONESIA Salmonella (presence /25g) in frozen octopus from Indonesia
12/03/2012 2012.APK  food border rejection ITALY from INDONESIA Salmonella paratyphi b (presence /25g) in frozen whole cleaned cuttlefish from Indonesia
13/03/2012 2012.APP  food border rejection ITALY from INDONESIA Salmonella Apeyeme (presence /25g) in frozen squids (Loligospp) from Indonesia
13/03/2012 2012.APU  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen baby octopus (Octopus aegina) from Indonesia
27/03/2012 2012.ASN  food border rejection ITALY from INDONESIA Salmonella (presence /25g) in frozen whole cleaned cuttlefish from Indonesia
29/03/2012 2012.ATJ  food border rejection ITALY from INDONESIA Salmonella (presence /25g) in frozen sepia from Indonesia
03/04/2012 2012.AUB  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen whole cleaned cuttlefish (Sepiellaintermis) from Indonesia
05/04/2012 2012.AUK  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen octopus (octopus spp) from Indonesia
12/04/2012 2012.AVH  food border rejection ITALY from INDONESIA Salmonella spp. (presence /25g) in frozen octopus (Octopus spp) from Indonesia
Up to 18 March 2013, there have been no further border rejections of cephalopods from Indonesia.

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