Reviewed and Approved by Tim Lombardo, Senior Director, Food Consulting Services, EAS Consulting Group; and Mark Moen, Sr. Regulatory Consultant, EAS Consulting Group
Recent controversies surrounding the quality of imported tuna have spotlighted a troubling issue known as "vitamin tuna" – a practice where lower-grade tuna is treated with additives like beet juice, paprika, ascorbic acid, and saline to give it a premium appearance.
This tactic has led to widespread concerns about transparency and potential food fraud in the seafood industry. According to industry reports, up to 60% of yellowfin tuna from Vietnam is injected with saline and additives, making the product look fresher and boosting its value by 15-20%.
This practice is deceiving both retailers and consumers, resulting in possible regulatory and health concerns, particularly for those with dietary restrictions or allergies to the additives.
Before talking about undeclared coloring additives being used in some tuna and seafood, we should say a few words about the common practice in the seafood industry of treating tuna or other products with carbon monoxide (CO).
Often called “filtered smoke”, “wood smoke”, or “tasteless smoke”, carbon monoxide helps retain a bright red color, giving tuna loins a fresh look. While this method does not affect the taste or texture of the fish, it can make it difficult for consumers to gauge freshness based on color alone.
Globally, the use of carbon monoxide in seafood is regulated differently. It is banned in the European Union due to concerns about misleading consumers regarding the freshness of the product. However, in the United States, the FDA permits the use of CO if it is properly declared on the label.
While carbon monoxide is allowed in the U.S., the use of undeclared color additives is not, and herein lies the current problem:
Some suppliers are using substances such as beet juice, paprika, ascorbic acid, and saline to artificially improve the color and appearance of tuna and other seafood.
This allows them to pass off low-quality tuna and other seafood as premium grade, increasing the price.
For importers and distributors, it’s vital to know that importing seafood with undeclared additives violates the Federal Food, Drug, and Cosmetic Act (FD&C Act) and could result in the rejection of shipments, costly recalls, and damage to your reputation.
In response to the growing concerns surrounding undeclared additives in “vitamin tuna” and other seafood, the FDA has intensified its regulatory measures.
The FDA published Import Alert 45-02 on Sept. 27, 2024: Detention Without Physical Examination and Guidance of Foods Containing Illegal and/or Undeclared Colors.
The alert covers a wide range of undeclared food color additives and several food products, including tuna and other seafood. The Alert gives FDA field personnel the power to detain any product that is shown as containing an undeclared color additive.
Given the complexities of importing, the last thing you need is to receive notice that your seafood shipment is detained due to Detention Without Physical Examination (DWPE).
To help avoid that scenario, proactively verify your supply chain and test your products to ensure compliance.
As always when working with suppliers, it starts with building strong relationships and auditing their processes and practices. While third-party certifications are always a good sign, don’t rely solely on them – conduct your own audits and verify that suppliers are following local and U.S. regulations.
EAS Consulting Group, a Certified Group company, is an excellent resource for help with auditing your suppliers if you don’t know where to start.
Secondly, verify product quality and the absence of undeclared coloring additives with laboratory testing. Your supplier may provide a Certificate of Analysis or other record that indicates product quality, but conduct your own testing to verify.
Common additives used to enhance the appearance of tuna and other seafood include…
Below are a few types of tests that can help ensure your tuna or other seafood is free from undeclared additives:
Whether you’re concerned about “vitamin tuna” or other forms of adulteration, choosing the correct food testing for your products depends on a few factors, such as…
EAS Consulting Group can help to conduct a Food Fraud Vulnerability Assessment for your products to determine preventive and mitigation strategies, to include testing.
And, when you’re ready to test, Certified Laboratories and Food Safety Net Services (FSNS), both part of Certified Group, offer testing in ISO 17025-accredited labs using validated methods. This provides you with an accurate picture of your product quality so you can protect your customers and your brand.
The use of undeclared coloring additives in seafood, such as “vitamin tuna”, may pose significant risks for your company.
To protect your brand and maintain compliance with U.S. regulations, proactive seafood testing for undeclared color additives and preservatives is essential.