IFFO Members' Meeting: New rules simplify fishmeal transport

At the IFFO 2025 Members’ Meeting in Madrid, IFFO’s technical director Brett Glencross provided a comprehensive overview of current fishmeal shipping regulations and their implications for the marine ingredients sector.

Fishmeal, a natural product rich in omega-3 fatty acids, is prone to oxidation – a process that, if left uncontrolled, can lead to spontaneous combustion. Because of this risk, fishmeal has long been classified as a dangerous good, listed by the International Cargo Handling Coordination Association (ICHCA) as a cargo of concern for supply chain safety.

To mitigate this risk, the industry has traditionally used antioxidants, such as ethoxyquin, which help stabilize the product and preserve its nutritional value. Two regulatory frameworks govern the use of antioxidants in fishmeal: one concerning transport and shipping safety, and the other concerning feed and food safety.

Oversight of shipping safety falls under the International Maritime Organization (IMO), a United Nations agency responsible for preventing marine and atmospheric pollution from ships. IMO guidelines are enforced through international shipping codes developed by its Maritime Safety Committee (MSC)—the organization’s highest technical body.

Two specific codes impact fishmeal shipping:

The International Maritime Dangerous Goods (IMDG) Code: covers packaged or containerized goods.
The International Maritime Solid Bulk Cargoes (IMSBC) Code: governs bulk cargoes.

The IMSBC Code classifies materials into:

Group A: goods that may liquify,
Group B: goods with chemical hazards (e.g., self-ignition),
Group C: non-hazardous materials.

Shift away from ethoxyquin

In 2017, the European Food Safety Authority (EFSA) raised concerns over the toxicity of ethoxyquin, leading to its eventual ban in 2022. Since then, the marine ingredients industry has been actively developing and testing alternative antioxidants, such as BHT and tocopherols, and working toward their approval under IMO regulations. After nearly a decade, this process is nearing completion.

In the past year, significant progress has been achieved. The IMO agreed to adopt recommendations from a Peruvian submission to amend the Group B code for bulk shipping to align it with the containerized shipping code, resolving previous irregularities.

“We demonstrated that we can stabilize fishmeal using BHT and tocopherols effectively, both in small container loads and large bulk shipments. This means that the industry now only needs to comply with one harmonized set of regulations, simplifying operations significantly,” Glencross explained.

As part of this process, IMO required testing under worst-case conditions, which involved Peruvian anchovy, known for its high omega-3 content and volatility. Stabilizing this fishmeal demands antioxidant levels up to ten times higher than those needed for species like Icelandic capelin. This raised concerns among Norwegian producers about excessive tocopherol use.

Previously, regulations required a minimum residual level of antioxidants (ethoxyquin, BHT, or tocopherols) at the time of shipment to confirm proper stabilization. There was a clause, Special Provision 928, that allowed bypassing some requirements if safety could be demonstrated through heat tests.

Inspired by the example of soybean and sunflower meal, which are volatile but classified under Group C (non-dangerous), stakeholders proposed a similar approach for fishmeal, using heat stability tests. After careful consideration, the IMO agreed this was feasible.

Consequently, a new shipping schedule was drafted, detailing the procedures and testing standards required to qualify fishmeal as a Group C (non-dangerous) product. Under the new classification, if test results, verified by accredited labs like SGS or Eurofins, prove the product is safe, it can be shipped under Group C. This designation removes limitations on antioxidant type or concentration and eliminates the need for future antioxidant testing to undergo a decade-long registration process. The IMO ratified the Norwegian proposal in September 2024, agreeing to this new approach.

“This classification change is significant,” said Glencross. “It increases shipping availability, lowers shipping and insurance costs, and treats fishmeal the same as clothing or other non-hazardous cargo.”

The revised testing approach also streamlines product validation. Traditionally, testing a new antioxidant involved two years of work and could take up to five years to complete. The new focus is on testing outcomes, such as heat stability, rather than the antioxidant itself. While a heat stability test costs around $1,000 (compared to $200 for antioxidant tests), it needs to be conducted only once a year.

All proposed changes are currently undergoing the required six-month review period among global shipping organizations, which began in December 2024. The final Maritime Safety Committee (MSC) meeting to approve these amendments is scheduled for June 2025 in London.

If ratified, the new schedule and Group C classification will be voluntarily available from January 1, 2026, and will become mandatory by 2027. “This marks a significant regulatory shift for the marine ingredients sector, streamlining shipping procedures and reinforcing safety through practical, science-based methods,” Glencross said.

Addressing new contaminants

The European Food Safety Authority (EFSA) and Codex Alimentarius are introducing new regulations targeting contaminants like mineral oil hydrocarbons (MOH) in food, with implications that are likely to extend to animal feed as well.

MOHs are a diverse group of chemical compounds derived primarily from the distillation and refining of petroleum. They are broadly categorized into: MOSH (Mineral Oil Saturated Hydrocarbons), and MOAH (Mineral Oil Aromatic Hydrocarbons).

The health risks associated with MOHs vary significantly. MOAH are of particular concern, as they are suspected genotoxic carcinogens, meaning they can damage DNA and potentially cause cancer. MOSH, while less acutely toxic, are known to accumulate in the liver and lymphoid tissues. For MOAH, EFSA has stated that no safe exposure level can be established.

Originally, MOAH testing methods were developed for plant-based oils such as olive or rapeseed oil. However, Glencross reported that when these same methods were applied to marine oils, they yielded inconsistent and unreliable results, even across laboratories using identical protocols. “The problem lies in the unique composition of marine oils, which are rich in carotenoids and long-chain omega-3 fatty acids like EPA and DHA. During chemical pre-treatment for MOAH analysis, these compounds can convert into structures that mimic MOAH, producing false positives and distorted data,” Glencross reported.

“The industry raised this issue with EFSA, fully supporting the goal of eliminating MOH contamination, but stressed the importance of using reliable and specific measurement techniques. Since current methods are not fit for purpose, the industry requested time to develop improved analytical tools,” said Glencross.

In response, IFFO has launched a contamination surveillance initiative, collecting marine oil samples from regions such as South America and the North Atlantic. The organization is now collaborating with Eurofins to develop a new, tailored method for accurately detecting MOAH in marine oils, addressing the specific chemical characteristics that differentiate them from plant-based oils.

This proactive approach highlights the industry's commitment to consumer safety and regulatory compliance, while also ensuring that marine-based ingredients are assessed fairly and accurately.