Fish Products

How does OMRI assess the preferential use of acids for the stabilization of liquid fish?

By Colleen Al-Samarrie

Fish products include fish meal, fish powder, fish farm wastes and hydrolysate, emulsions, and solubles. All that fishy goodness is prone to decay, so manufacturers generally stabilize these materials with an acid. The Canadian Organic Standards at CAN/CGSB-32.311 Table 4.2 states, “Chemical treatment is prohibited, with the exception of the following substances which are in preferential order: a) vinegar; b) citric acid; c) phosphoric acid; or d) sulphuric acid.” This language may lead the curious mind to ask how this preferential order is enforced. Who is responsible for this verification? Whose preference determines a product’s compliance?

OMRI had similar questions. In 2022, we asked the Standards Interpretation Committee (SIC) a few questions about the fish products entry. These questions included:

1. Should this annotation be viewed as a restriction for growers to source fish products formulated with vinegar first, and then subsequently acids other than vinegar? Or should this annotation be viewed as aspirational—a guidance that is not meant to actually add compliance criteria for growers/restrict product usage? Or is this annotation meant for someone else, such as product manufacturers?
2. Is verification of the preference of a given fish product, stabilized with an acid other than vinegar, up to individual certifiers working with specific producers? Or should material review organizations be evaluating reasoning given by product manufacturers?
3. If material review organizations need to evaluate the reasoning given by product manufacturers, what explanations as to why one acid is used over another are acceptable under the standards? If not, what explanations should certifiers be accepting from growers?

The SIC responded, “Material reviewers need to determine if the fish product and acid used is permitted. The preferential order of the list is guidance only.” Their response also indicated that they did not consider further interpretation to be necessary, and they did not publish a formal answer to the question on their website.

The SIC interprets the standards to mean that the preferential order cited in the annotation is, in practice, aspirational. With this in mind, OMRI collects and reviews the manufacturing process for liquid fish products to verify the acid used is allowed. In the past, we asked applicants to provide documentation explaining their acid preference if it was anything other than vinegar to evaluate compliance with the preferential order.  For example, if a manufacturer stabilized their liquid fish product with phosphoric acid, OMRI required documentation explaining whether or not vinegar or citric acid had been evaluated as preferred stabilizers. We no longer consider the applicant preference of allowed acids as part of our product review.

We continue to collect pH labs on acid-stabilized fish products and liquid fish ingredients in multi-ingredient fish products (see OMRI Standards for Lab Analyses for Canada-OMRI.org/suppliers/manuals). For products with a pH less than 3.5, we ask applicants to demonstrate that they use the minimum amount of acid needed to stabilize the product. Products with a pH below 3.5 may be forfeited for failure to demonstrate compliance. This is how we verify that products do not contain allowed acids in excess of the level required for stabilization.

This article was originally published in the spring 2024 edition of the OMRI Materials Review newsletter, and was revised in June 2025 by Standards Manager Jarod Rhoades. 

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