DEAS 830: 2021  
ICS 67.120.30  
© EA C 2021                                                                                                                               First Edition 2021 
 
DRAFT EAST AFRICAN STANDARD  
Frozen fish sticks (fish fingers), fish portions and fish fillets — Breaded 
or in batter — Specification  
EAST AFRICAN COMMUNITY  DEAS 830: 2021  
ii © EAC  2021  – All rights reserved  
 Copyright notice  
This EAC document is copyright -protected by EAC. While the reproduction of this do cument by 
participants in the EAC standards development process is permitted without prior permission from EAC, 
neither this document nor any extract from it may be reproduced, stored or transmitted in any form for 
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© East African Community  2021 — All rights reserved  
East Africa n Community   
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Reproduction for sales purposes may be subject to royalty payments or a licensing agreement.  
Violators may be persecuted  DEAS 830: 2021  
© EAC 2021  – All rights reserved  iii 
 Foreword  
Development of the East African Standards has been necessitated by the need for harmonizing requirements 
governing quality of products and services in the East African Community. It is envisaged that through 
harmonized standardization, trade barriers that are encountered when goods and services are exchanged 
within the Community will be removed.  
In order to achieve this objective, the Community established an East African Standards Committee mandated 
to develop and issue East African St andards.   
The Committee is composed of representatives of the National Standards Bodies in Partner States, together 
with the representatives from the private sectors and consumer organizations. Draft East African Standards 
are circulated to stakeholders th rough the National Standards Bodies in the Partner States. The comments 
received are discussed and incorporated before finalization of standards, in accordance with the procedures 
of the Community.  
East African Standards are subject to review, to keep pace  with technological advances. Users of the East 
African Standards are therefore expected to ensure that they always have the latest versions of the standards 
they are implementing .  
FDEAS 830 was prepared by the Technical Committee EASC/TC 003, Fish and fi shery products . 
 
 DRAFT EAST AFRICAN STANDARD  DEAS 830:2021  
 
© EAC 2021  – All rights reserved  1 
 Frozen fish sticks (fish fingers), fish portions and fish fillets — 
Breaded or in batter — Specification  
1 Scope  
This Draft East Africa n Standard specifies requirements and methods of sampling and test for frozen fish 
sticks (fish finger s), fish portions and fish fillets – breaded or in batter, intended for human consumption  
2 Normative references  
The following referenced documents are indispensable for the application of this document. For dated 
references, only the edition cited applies . For undated references, the latest edition of the referenced 
document (including any amendments) applies.  
AOAC 952.13,  Arsenic in food — Silver diethyldibocarbamate method  
AOAC 972.23 , Lead in fish —– Atomic absorption spectrophotometric method  
AOAC 973. 34, Cadmium in food — Atomic absorption spectrophotometric method  
AOAC 977.13 , Histamine in sea food — Fluorometric method  
AOAC 983.20 , Mercury (methyl) in fish and shellfish — Gas chromatographic method  
AOAC 2015.01, Heavy metals in food  
CAC/GL 50 -2004  General guideline on sampling  
CAC/RCP 52 -2003 , Code of practice for fish and fishery products  
CODEX STAN 192 -1995 , General standard for food additives  
EAS 12, Drinking (potable water) — Specification  
EAS 38 , Labelling of pre -packaged foods — Requirements  
FDEAS 827:2015 , Fresh and frozen whole fin fish – Specification  
FDEAS 831:2015, Frozen fish fillets — specification  
ISO 4833 -1, Microbiology of food chain — Horizontal method for the enumeration of microorganisms — Part 
1: Colony -count at 30 degrees C by the pour plate technique  
ISO 6579 , Microbiology of food and animal feeding stuffs — Horizontal method for the detection of Salmonella 
spp. 
ISO 6888 (all parts) , Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration 
of coagulase -positive staphylococci (Staphylococcus aureus and other species)  DEAS 830: 2021  
2 © EAC  2021  – All rights reserved  
 ISO 7251 , Microbiology of food and animal feeding stuffs — Horizontal method for the detection and 
enumeration of presumptive Escherichia coli — Most probable number technique  
ISO 11290 (all  parts) , Microbiology of food and animal feeding stuffs — Horizontal method for the detection 
and enumeration of Listeria monocytogenes  
ISO 16050 , Foodstuffs — Determination of aflatoxin B1, and the total contents of the aflatoxins B1, B2, G1 
and G2 in ce reals, nuts and derived products — High performance liquid chromatographic method  
ISO 21527 -1, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration of 
yeasts and moulds — Part 1: Colony count technique in products with wat er activity greater than 0,95  
ISO/TS 21872 (all parts) , Microbiology of food and animal feeding stuffs — Horizontal method for the 
detection of potentially enteropathogenic Vibrio spp.  
3 Terms and definitions  
For the purposes of this standard, the followin g terms and definitions shall apply.  
3.1 
fish stick (fish finger)  
product including the coating shaped so that the length is not less than three times the greatest width  
3.2  
fish portion  
product including the coating and may be of any shape, weight or s ize 
3.3  
fillets  
slices of fish of irregular size and shape which are removed from the carcass by cuts made parallel to the 
backbone and pieces of such fillets, with or without the skin  
3.4 
batter  
paste prepared  from ground cereals, spices, salt, sugar an d other ingredients and/or additives for coating. 
Typical batter types are non -leavened batter and leavened batter.  
3.5  
breading  
application of dry breadcrumbs or other dry preparations mainly from cereals with colourants and other 
ingredients used for t he final coating of fish and fishery products. Breading types /forms  are free flowing 
breading, coarse breading and flour type breading.  
3.6 
foreign matter  
presence of  soil, sand, skins, scales,  bones, dirt  or any  material other than flesh  
3.7 
food grade m aterial  
packaging material, made of substances which are safe and suitable for their intended use and which will not 
impart any toxic substance or undesirable odour, c olour or flavour to the product  
3.8  
coating  
covering the surface of a fishery product w ith batter and/or breading  DEAS 830: 2021  
© EAC 2021  – All rights reserved  3 
 4 Requirements  
4.1 General requirements  
4.1.1  Raw material  
4.1.1.1  Frozen fish sticks (fish fingers), fish portions and fis h fillets, breaded or in batter  shall be prepared 
from frozen fish fillets and/or fresh and frozen whole f in fis h that conform to FDEAS 831 and FDEAS 827 
respectively or minced fish flesh, or mixtures thereof, of edible species which are of a quality such as to be 
sold fresh for human consumption . 
4.1.1.2  The coating and all ingredients used therein shall be o f food grade quality and conform to relevant 
Codex or East Africa n standards.  
4.1.1.3  Fat or oil used in cooking operation shall be suitable for human consumption and conform to 
relevant East Africa n or Codex standard.  
4.1.1.4  Water used for washing the fi sh shall be potable and comply ing with EAS 12.  
4.1.2  Finished product  
Frozen fish sticks (fish fingers), fish portions and fish fill ets, breaded or in batter shall:  
a) be free from foreign matter ; and  
b) not have objectionable odour,  colour and flavour.  
4.2 Spec ific requirements  
4.2.1  When tested in accordance with AOAC 977.13 , the level of histamine in fish such as scro mboids 
species  shall not exceed 10 ppm.  
4.2.2  The frozen fish sticks (fish fingers), fish portions and fish fillets,  breaded or in batter , shall be 
maintained at  a temperature of -18 ºC or below . 
5 Food additives  
Food additives may be used in the preparation and processing of frozen fish sticks (fish fingers), fish portions 
and fish fillets, breaded or in batter  in accordance with CODEX STAN 192.  
6 Hygiene  
The product covered by the provisions of this standard shall be prepared and handled in accordance with EAS 
39 and CAC/RCP 52 and shall comply with microbiological limits given in Table 1 . 
Table 1 — Microbiological limits for frozen fish sticks ( fish fingers), fish portions and fish fillets, 
breaded or in batter  
S/No  Micro -organisms  Maximum  limits  Test method  
i) Salmonella  spp, per 25 g  Absent  ISO 6579  
ii) Escherichia coli , MPN/g  10 ISO 7251  
iii) Listeria monocytogenes , per 25  Absent  ISO 11290  DEAS 830: 2021  
4 © EAC  2021  – All rights reserved  
 iv) Staphylococcus aureus , CFU/g   103 ISO 6888  
v) Vibrio Spp . Per 25  g Absent  ISO/TS 21872  
vi) Total viable count , CFU/g  105 ISO 4833 -1 
vii) Yeast and mould s, CFU/g  103 ISO 21527 -1 
6 Contaminants  
6.1 Heavy metals  
Frozen fish sticks (fish fingers), f ish portions and fish fillets, breaded or in batter , shall comply with the heavy 
metal  limits given in Table 2.  
Table 2  — Heavy metal  limits for frozen fish sticks (fish fingers), fish portions and fish fillets,  breaded 
or in batter  
S/No  Heavy metal  Maximu m limit , 
mg/kg  Test method  
i) Lead  0.3 AOAC 972.23  
ii) Cadmium  0.3 AOAC 973.34  
iii) Mercury  0.5 AOAC 2015.01  
 
6.2 Aflatoxins   
When tested in accordance with ISO 16050 , the level for  aflatoxin  B1 in the product shall not exceed 5 µg/kg  
and total aflatox in shall no t exceed 10 µg/kg . 
6.3 Veterinary drug residues  
The product shall comply with those maximum veterinary drug residue limits established by the Codex 
Alimentarius Commission.  
6.4 Pesticide residues  
The product shall comply with those maximum pest icides residue limits established by the Codex Alimentarius 
Commission.  
7 Packaging  
Frozen fish sticks (fish fingers), fi sh portions and fish fillets - breaded or in batter , shall be packaged in food 
grade material  which will safeguard the hygienic, nutri tional, and organoleptic qualities of the product.  
 
 
 DEAS 830: 2021  
© EAC 2021  – All rights reserved  5 
 8 Labelling  
8.1 General  
In addition to the requirements in EAS 38, the following specific labelling requirements shall apply and shall be 
legibly and indelibly marked:  
a) name of the product as “Frozen fish sticks ” (fish fingers), “fish portions ” or “fish fillets ”, breaded or in 
batter ; 
b) common n ame /species name;  
c) storage and transportation conditions declaring the temperature to be -18 ˚C or lower ; 
d) name and physical address of processor or packer ; 
e) net weight in grams or kilograms ; 
f) date of production ; 
g) batch number ; 
h) expiry date ; 
i) instruction for use ;  
j) list of ingredients used in descending order of proportion;  and 
k) country of origin . 
8.2 Labelling of non -retail containers  
8.2.1 Information on the above provisions shall be given either on the container or in accompanying 
documents, except that the name of the product, lot identification, and the name and address of the processor 
or packer as w ell as storage instructions, shall appear on the container.  
8.2.2 However, lot identification, and the name and address of the processor or packer may be replaced by 
an identification mark provided that such a mark is clearly identifiable with the accompan ying documents.  
9 Sampling  
Sampling shall be done in accordance with CAC/GL 50.  DEAS 830: 2021  
© EAC 2021  – All rights reserved