Risk Management Proposal  
 
Aquatic Animal Products   
AQUAPROD.GEN  
 
 
 
 
[Document Date]  Risk Management Proposal:  Aquatic Animal Products  [Document Date ] 
Ministry for Primary Industries   Page 1  
 
 
Disclaimer  
This risk management proposal does not constitute, and should not be regarded as, legal advice. While every 
effort has been made to ensure the information in this document is accurate, the Ministry for Primary Industries 
does not accept any responsibility or liability whatsoever for any error of fact, omission, interpretation or opinion 
that may be p resent, however it may have occurred.  
© Crown Copyright - Ministry for Primary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for further information : 
Ministry for Primary Industries (MPI)  
Biosecurity New Zealand  
Animal Imports  
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz  
Telephone:  04 890 0134  
  Risk Management Proposal:  Aquatic Animal Products  [Document Date ] 
Ministry for Primary Industries   Page 2  
Contents  
1 Purpose  3 
2 Background  3 
3 Objective  5 
4 Commodity scope  5 
5 Options assessment  6 
5.1 Risk organisms in fish  6 
5.2 Risk organisms in crustaceans  7 
5.3 Risk organisms in molluscs  7 
6 Recommendations for ide ntified risk organisms  8 
6.1 Fish products  8 
6.2 Crustacean products  12 
6.3 Mollusc products  15 
6.4 Echinoderm products  16 
6.5 Tunicate products  16 
6.6 Cnidarian products  16 
6.7 Aquatic animal meal and aquatic animal oil  16 
Appendix  1 – Document History  17 
 Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 3 1 Purpose  
(1) The purpose of this risk management proposal (RMP)  is to:  
a) Show how options for the management of risk o rganisms have been assessed.  
b) Provide recommendations for import requirements.  
2 Background  
(1) Aquatic animal products are considered risk commodities, with the potential of harbour ing exotic viral, 
bacterial,  fungal, protozoal , microsporidian  and metazoan pathogens.  These biosecurity risks require 
managing before aquatic animal products can be imported into New Zealand.  
(2) This document discusses the options for managing biosecurity risks in aquatic animal produc ts imported 
into New Zealand for uses other than as bait or feed for aquatic animals . 
(3) For reasons stated below, risk management measures for the following categories of aquatic animal 
products are not discussed in this RMP.  
a) Bait and products for feeding aquatic animals. This category of products will be covered under a 
separate import health standard (IHS).  
b) Retorted aquatic animal products intended for animal consumption . This category of products can be 
imported under the  Import Health Standard for the Importation into New Zealand of Processed 
Petfood Containing Category 3 Material Only from the European Community , FODPPPIC.EE C and 
the Import Health Standard for Shelf -stable Petfoods Containing Animal Products , PETFODIC.ALL . 
(4) The following ten IHSs currently exist for aquatic animal products for human consumption:  
a) Import Health Standard for the Importatio n into New Zealand of Caviar for Human Consumption from 
All Countries , FISCAVIC.ALL , 19 May 2008.  
b) Import Health Standard for the Importation into New Zealand of Commercial Consignments of 
Fresh/Frozen/Processed Salmonids for Human Consumption from the European Community , 
FISSALIC.EEC , 24 September 2004.  
c) Import Health Standard for the Importation into New Zealand of Cooked Fish from all Countries , 
FISCOOIC.ALL , 11 May 2004.  
d) Import Health Standard for the Importation into New Zealand of Fish Eggs/Roe for Human 
Consumption from the European C ommunity , FISROEIC.EEC , 24 September 2004.  
e) Import Health Standard for the Importation into New Zealand of Frozen Nile Perch (Lat es niloticus) 
Skinless, Boneless Fillets for Human Consumption from Kenya, Tanzania or Uganda (Lake Victoria) , 
FISNPEIC.AL L, 28 June 2000.  
f) Import Health Standard for the Importation of Marine Fisheries Products for Human Consumption 
from All Countries , FISMARIC.ALL , 6 October 2008.  
g) Import Health Standard for the Importation into New Zealand of Marine Fisheries Products for 
Human Consumption from the European Community , FISMARIC.EEC , 24 September 2004.  
h) Import Health Standard for Processed Tilapia and Catfish for Human Consumption , FISFILIC.SPE , 
04 February 2011.  
i) Import Health Standard for the Importation into New Zealand of Salmonids for Human Consumption 
from Australia , FISSALIC.AUS , 16 August 2000.  
j) Import Health Standard for the Importation into New Zealand of Salmonids for Human Consumption 
from Specified Countries , FISSALIC.SPE , 28 June 2004.  
(5) While the IHSs for salmon ids, tilapia, catfish, fishmeal, and fish oil products were based on published 
import risk analyses (IRAs), the IHSs for the other aquatic animal products were not. MPI has always 
intended to review the IHSs for the other aquatic animal products once updated IRAs for these 
commodities have been developed.  
 
 Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 4 (6) The Ministry for Primary Industries (MPI) has now completed the following risk analyses:  
a) Import Risk Analysis: E viscerated or Trunked Fish for Human Consumption  (Version 3.2) ; 
dated June 2019 (the Fish IRA).  
b) Import Risk Analysis: Crustaceans for Human Consumption ; dated 23 July 2018 ( the Crustacean 
IRA).  
c) Supplementary Import Risk Analysis: Frozen Fish and Cephalopod Molluscs for Fish Bait ; 
dated 19 November 2020 (Fi sh Bait SRA).  
(7) Risk management advice for mollusc products is in progress.  
(8) The following existing MPI risk analyses have also been used in this RMP:  
a) The Risk of Introducing Exotic Diseases of Fish int o New Zealand through the Importation of Ocean -
Caught Pacific Salmon from Canada ; dated September 1994.  
b) Import Health Risk Analysis: Salmonids for Human Consumption ; dated September 1997.  
c) Supplementary Import Risk Analysis: Head -on, Gill -in Australian Salmonids for Human Consumption  
d) Import Risk Analysis: Frozen, Skinless and Boneless Fillet Meat of Oreochromis spp. from China 
and Brazil for Human Consumption ;  dated September 1999.  
e) Import Risk Analysis: Frozen, Skinless and Boneless Fillet Meat of Pangasius spp. Fish f rom 
Vietnam for Human Consumption ; dated September 2008.  
f) Import Risk Analysis: Fish Food ; dated April 2008.  
g) Supplementary Risk Analysis: Extension of Countries Eligible to Export Frozen, Skinless, Boneless 
Fillet Meat of Pangasius spp. under the Import Health Standard FISFILIC.SPE ; dated April 2010.  
(9) Using the above IRAs, additional science and technical advice received from MPI’s Animal Risk 
Assessment Team (the Risk Team), and information in the World Organ isation for Animal Health (OIE) 
Aquatic Animal Health Code  (the Aquatic Code ), the Animal Imports Team commenced development of 
the generic Import Hea lth Standard: Aquatic Animal Products , AQUAPROD.GEN . The generic IHS will 
replace the above listed 10 IHSs for aquatic animal products intended for human consumption and those 
10 IHSs will be revoked.  
(10) The Import Health Standard for the Importation into New Zealand of Marine Fish for Petfood from All 
Countries , PETFISIC.ALL , 12 November 1999 , is applicable for importation into New Zealand of fresh, 
frozen or uncooked marine fish from all countries for use as cat or dog food. It was assessed that the 
advice in the Fish IRA and the Crustacean IRA was suitable for animal consumption as well.  Henc e, 
IHS: AQUAPROD.GEN  sets out import requirements for aquatic animal products for further processing 
into animal food  other than for use as feed for aquatic animals , and IHS: PETFISIC.ALL  will be revoked . 
(11) Clause 7.2.3 of the Import Health Standard for Fish Food and Fish Bait from All Countries , 
FISFOOIC.ALL , 2 December 2011 , sets out the import requirements for fishmeal and fish oil. These 
requirements are based on risk management recommendations included in the Import Risk Analysis: Fish 
Food  (Chapter 4). IHS: AQUAPROD.GEN  will include requirements for these two commodities  for uses 
other than as bait or feed fo r aquatic animals , which will result in an alteration to Clause 7.2.3 of  
IHS: FISFOOIC.ALL . 
(12) Aquatic animal products are also imported into New Zealand for use as bait, and the Supplementary 
Import Risk Analysis: Frozen Fish and Cephalopod Molluscs for Fish Bait  (Fish Bait SRA) was developed 
to inform this import pathway. Aquatic animal products imported for use as ba it is excluded from this RMP, 
and an updated IHS for this commodity will be consulted later. The risk information in the Fish Bait SRA 
has also been used for IHS: AQUAPROD.GEN . 
(13) In accordance with MPI processes, the IHS: AQUAPROD.GEN  contains generic import requirements. 
These requirements manage the biosecurity risk s of importing aquatic animal products for uses specified 
in Section 2(2) of this document.  
(14) Where required by the IHS, MPI will negotiate  country -specific health  certifica tes with the exporting 
country’s Competent Authority once MPI is satisfied with the exporting country’s export systems. 
Negotiations will consider the verifiable health status of the exporting country, the national systems, 
legislation and import regulatio ns in the exporting country for regulatory oversight of the aquatic animal Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 5 product  industry, and the capabilities and preferences of the exporting country’s Competent Authority. The 
assessments will be based on Section 3  (Quality of Aquatic Animal Health S ervices ) of the Aquatic Code . 
(15) Along with this RMP , a guidance document is being  issued by MPI and this will provide commodity specific 
guidance information , including model health certificates,  for trade in aquatic animal products . Specimens 
of country -specific, bilaterally negotiated  health certificat es, when they become available, will be included 
in the guidance document. These specimen certificates will also be available in the dropdown area where 
IHS: AQUAPROD .GEN  is listed on the web.  
3 Objective  
(1) The objective is to effectively manage biosecurity risks associated with the import of aquatic animal 
products for uses other than as bait or feed for aquatic animals  consistent with New Zealand’s domestic 
legislation and international obligati ons. 
4 Commodity scope  
(1) For the purposes of IHS: AQUAPROD.GEN , aquatic animal products are those derived from the following 
categories of aquatic animals:  
a) Superclass Osteichthyes , including, but not limited to, bony fish like salmon, perches, cods, herrings, 
and eels . 
b) Class Chondrichthyes , including, but not limited to, cartilaginous fish like sharks and stingrays . 
c) Phylum  Mollusca,  including, but not limited to, clams, mussels, oysters, scallops, octopus, squids, 
and snails but not land snails  like escargot.  
d) Subphylum  Crustacea , including, but not limited to, crabs, lobsters, shrimp, prawns , and crawfish. 
Excludes terrestrial crusta cean species.  
e) Phylum  Echinodermata , including, but not limited to, sea cucumbers, sea stars, and sea urchins.  
f) Phylum  Cnidaria , such as jellyfish.  
g) Subphylum  Tunicata , including, but not limited to, sea squirts, sea tulips, sea peaches ( Halocynthia 
aurantium ) sea pineapples/hoyas ( Halocynthia roretzi ), Pyura spp., and Microcosmus  spp. 
(2) The aquatic animal products are categorised into the following risk goods, for which specific risk 
management options are discussed in Section 6  of this document.  
a) Fish products : 
i) Salmon id products  
ii) Marine fish products from Australia  
iii) Non-salmon id fish produc ts from recognised countries  
iv) Low-risk non -salmon id fish products from any country  
v) Non-salmon id fish products from any country for further processing in New Zealand  
vi) Specified non -salmon id fish products : 
1) Non-salmon id fish skin-off fish fillets  
2) Dried non-salmon id fish products  
3) Non-salmon id fish products in retail packaging  
  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 6 b) Crustacean products  
i) Crustacean products from recognised countries  
ii) Specified crustacean products  
1) Heat -treated crustacean products  
2) Frozen crustacean products  
3) Crustacean products in r etail packaging  
c) Mollusc products  
d) Echinoderm products  
e) Tunicate products  
f) Cnidarian products  
g) Aquatic animal meal and aquatic animal oil 
5 Options assessment  
(1) The World Trade Organi zation ’s (WTO) Agreement on the Application of Sanitary and Phytosanitary 
Measures  (the SPS Agreement), Article 3.3, requires that risk management measures that provide a level 
of protection greater th an provided by international standards are only imposed when they can be 
scientifically justified on the basis of a risk assessment.  
(2) For a detailed analysis of the hazards and their risks please refer to the IRAs listed in Sections 2(6)  and 
2(8) of this  document. The IRAs contain the relevant risk assessment and an analysis of management 
options for each risk organism.  
(3) Of the hazards, the IRAs concluded that risk management measures were justified for the followi ng risk 
organisms in imported aquatic animal products.  
5.1 Risk organisms in fish  
(1) Viruses:  
a) Epizootic haematopoietic necrosis virus  (EHNV) / European catfish virus  (ECV) / European sheatfish 
virus (ESV)  
b) European eel virus  (EVE)  
c) European eel herpesvirus  (EEHV)  
d) Grass carp haemorrhagic virus  (GCHV)  
e) Grouper iridovirus  (GIV)  
f) Hirame rhabdovirus (HIRRV)  
g) Infectious haematopoietic necrosis virus  (IHNV)  
h) Infectious pancreatic necrosis virus  (IPNV)  / Halibut birnavirus  / Viral deformity of yellowtail virus  
i) Infectious salmon anaemia virus  (ISAV)  
j) Koi herpesvir us (KHV)  
k) New Japan virus (NJV)  
l) Nodaviruses, including viral nervous necrosis virus  (NNV)  
m) Oncorhynchus masou  virus  (OMV)  
n) Piscine aquareovirus  (PRV) / Salmon aquareovirus  / Tasmanian salmon reovirus  / grass carp 
reovirus  / turbot reovirus  (TRV) / Heart and skeletal muscle inflammation syndrome virus  
o) Red sea bream iridovirus  (RSIV) / Infectious spleen and kidney necrosis virus  (ISKNV) / Gourami 
iridovirus  
p) Salmon alphavirus  (SAV) / Salmon pancreatic disease virus  
q) Salmon gill poxvirus  (SGPV) / Carp oedema virus  / Koi sleepy disease virus  
r) Spring viraemia of carp virus  (SVCV) / Pike fry rhabdovirus  
s) Viral haemorrhagic septicaemia virus  (VHSV)  
  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 7 (2) Bacteria:  
a) Aeromonas hydrophila  (exotic strains)  
b) Aeromonas salmonicida  var. salmonicida  (atypical strains)  
c) Aeromonas salmonicida  var. salmonicida  (typical strains)  
d) Edwardsiella  spp.  
e) Flavobacterium columnare  (exotic strains)  
f) Francisella  spp. 
g) Moritella  viscosa   
h) Piscirickettsia salmonis  and related Rickettsia -like organisms  
i) Pseudomonas anguill iseptica  
j) Renibacterium salmoninarum  
k) Streptococcus agalactiae  (serotype III: 283)  
l) Streptococcus iniae  
m) Yersinia ruckeri  (Hagerman and other exotic strains)  
(3) Fungi and Microsporidia : 
a) Aphanomyces invadans  
b) Ichthyophonus hoferi  
c) Microsporidian pathogens   
d) Sphaerothecum destruens  
(4) Metazoa : 
a) Anguillicola crassus  
b) Myxozoa ( including  Enteromyxum, Henneguya, Kudoa, Myxobolus, Sphaerospora , and Unicapsula ) 
c) Cestode larvae  
d) Digenean larvae  
e) Monogenean parasites, including Gyrodactylus salaris . 
5.2 Risk organisms  in crusta ceans 
(1) Fung us: 
a) Aphanomyces astaci  
(2) Protozoa : 
a) Hematodinium  and Hematodinium -like spp.  
(3) Metazoa : 
a) Angiostrongylus cantonensis  
b) Paragonimus  spp. 
5.3 Risk organisms  in molluscs  
(1) The risk organisms in mollusc products will be listed when the risk advice for this commodity is completed. 
Until that time the risk management options for mollusc products, as set out in the  current  Import Health 
Standard for the Importation of Marine Fisheries Products for Human Consumption from All Countrie s, 
FISMARIC.ALL , 6 October 2008, are proposed in the new IHS but with the following amendments.  
a) A requirement for a health certificate will be added.  
b) A provision for importing mollusc meat put back on cleaned shells will be added.  
  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 8 6 Recommendations for ide ntified risk organisms  
(1) Risk management measures included in IHS: AQUAPROD.GEN  are based on the following approaches.  
a) Inactivation of specified risk organisms through treatment (heating or freezing).  
b) Absence of specified risk organisms in the commodity in t he exporting country. The specified risk 
organisms are those that are identified in the relevant IRA and listed in Section s 5.1 and 5.2  of this 
document.  
c) Packaging and end use of the commodity.  
6.1 Fish products  
6.1.1 Salmon id fish products  
(1) Salmon id fish products can currently be imported only from Australia, Canada, Norway, the USA, and the 
European Union.  The applicable IHSs are:  
a) From Australia: Import Health Standard for the Importation into New Zealand of Salmonids for 
Human Consumption from Australia , FISSALIC.AUS  
b) From Canada, Norway, and the USA: Import Health Standard for the Importation into New Zealand 
of Salmonids for  Human Consumption from Specified Countries , FISSALIC.SPE  
c) From European Union countries: Import Health Standard for the Importation into New Zealand of 
Com mercial Consignments of Fresh/Frozen/Processed Salmonids for Human Consumption from the 
European Community , FISSALIC.EEC . 
(2) The above IHSs are based on the  following risk analyses:  
a) The Risk of Introduc ing Exotic Diseases of Fish into New Zealand through the Importation of Ocean -
Caught Pacific Salmon from Canada  (1994)  
b) Import Health Risk Analysis: Salmonids for Human Consumption  (1997)  
c) Supplementary Import Risk Analysis: Head - on, Gill - in Australian Salmonids for Human 
Consumption  (1999)  
(3) The current IHSs for salmon id fish products include assessment of country systems.  
(4) Updated aquatic animal disease information has been published and is summarised in the Fish IRA and  
considered in IHS: AQUAPROD.GEN  for salmon id fish products from the currently recognised  countries.  
Salmon id fish products  from Australia  
(5) Under the current Import Health Standard for the Importation into New Zealand of Salmonids for Human 
Consumption from Aust ralia, FISSALIC.AUS , salmon id fish products  can be imported from Australia in 
eviscerated form.  Removal of the head and gills is not a requirement under the IHS.  
(6) As indicated in the Fish IRA, t he OIE -listed diseases Aphanomyces invadans  and epizootic 
haematopoietic necrosis virus (EHNV) have been reported from salmon ids in Australia . Given that New 
Zealand is free from these two risk organisms, risk management measures  will be applied  to salmon id 
products from Australia . MPI is proposing  that salmon id fish products  from Australia needs to be, at the 
minimum, in headed, gilled, and gutted form, and subject to the risk management options discussed in  
Section 6.1.1(8)(b)  of this document.  
Salmon id fish products  from Canada, the EU, Norway, a nd the USA  
(7) The IHSs – IHS: FISSALIC.SPE and IHS: FISSALIC.EEC  -- for salmon id fish products  from Canada, the 
EU, Norway, and the USA allow importation of headed, gilled , and gutted salmon ids from these countries . 
The systems of these countries were assesse d, and the commodity was determined as meeting N ew 
Zealand ’s requirements.  
(8) The IHS: FISSALIC.SPE , which is applicable for salmon id fish products from Canada, Norway, and the 
USA, includes the following definitions:  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 9 Bulk form : product which is intended to be further processed and/or packaged in New Zealand 
prior to retail sale or use in the institutional trade. e.g. containers of more than  one fish. (Note: 
bulk product must be directed to a transitional facility).  
 
Commercially packaged for direct retail sale : means product not requiring further packaging 
and/or processing prior to retail sale or use in the institutional trade in New Zealan d. e.g. retort 
pouch packaged single fish, hermetically sealed packages of fish portions.  
a) The intent of the above definitions was to mitigate risks posed by waste generated from salmon id 
fish products  imported in bulk form, meaning salmon ids imported in he aded, gilled, and gutted form . 
The Import Health Risk Analysis: Salmonids for Human Consumption  and the Supplement ary Import 
Risk Analysis: Head -on, Gill -in Australian Salmonids for Human Consumption  recommended such 
products be consigned to a transitional facility where they must be processed into products that are 
commercially packaged for direct retail sale. The technical requirements for the transitional facility 
include, among other things, approved methods of waste disposal and discharge of wastewater into 
an urban sewage treatment system.  
b) However, the definitions in the IHS for salmon ids in bulk form did not c learly convey the intent of the 
above salmon id IRAs. For clarity, MPI is proposing  that the new IHS will not include the term ‘bulk 
form’, but will instead appl y the risk mitigation measures , which are commodity -based, as follows:  
i) Salmon id fish products wh ere very little waste is produced . This applies to salmon id fillets and 
steaks , and all products derived from further processing of fillets and steaks.  
ii) Salmon id products with potential for waste generation . This applies to headed, gilled, and 
gutted  salmon ids. This product will be directed to a transitional facility  where it is processed to 
the level described in “ i” above to be eligible for biosecurity clearance. The transitional facility 
(TF) will need to have approval under  MPI’s  Facility Standard: Transitional Facilities for Animal 
Products , MPI-STD-ANIPRODS . An import permit will be required for importing headed, gilled, 
and gutted salmon ids so that consignments are directed to the transitional facility named on 
the permit.  
iii) Schedule 9  of IHS: AQUAPROD.GEN  outlines  the transitional facility requirements.  
(9) The RMP further proposes that the salmon id fish commod ity requirements will apply to all members of the 
family Salmonidae , instead of being limited , as they currently are,  to fish within the genera Oncorhynchus , 
Salmo , and Salvelinus . This proposal is in line with the assumption made in the Fish IRA  that i f an 
identified risk agent  is reported from a species then the other species in the family may be susceptible to 
that disease  (page 15 of the Fish IRA).  
(10) The following requirements from the existing salmon id IHSs will also be retained:  
a) The product for export is derived from fish that were harvested from a population for which a 
documented health surveillance programme exists , which is administered by a competent 
government -authorised agency.  
b) The product for export is derived from fish that were not slaughtered as an official disease control 
measure as a result of an outbreak of disease.  
(11) To allow salmon id fish products to be im ported from a recognised country that is not the source country, 
the model health certificate in the guidance document includes a clause relating to third -country processed 
products.  
Salmon id fish products  from other countries  
(12) Any country not currently rec ognised for exporting salmon id products to New Zealand will need to undergo 
the country recognition process described in Section 1.5 of  IHS: AQUAPROD.GEN . 
  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 10 6.1.2 Marine fish products from Australia  
(1) In addition to being  a geographical neighbour , Australia has a close trading relationship with New Zealand , 
and whole marine fish from Australia have been imported for human consumption for many years . It is 
therefore proposed that whole fish of marine1 origin from Australia and products derived from the fish will 
not require any sanitary attestation other than identifying the product as belonging to a marine fish species 
and sourced from within Australia’s exclusive economic zone and adjacent waters.  
(2) Australia’s Competent Authority, the Department of Agriculture, Wat er and the Environment , had advised 
MPI that sea mullet ( Mugil cephalus ) in that country does not have an obligate freshwater lifecycle. MPI 
categorises sea mullet from Australia as marine fish species.  
6.1.3 Non-salmon id fish products from recognised countries  
(1) The Fish IRA recommended acceptance of country /zone freedom for risk organisms applicable to a fish 
family as a  risk management option . This recommendation is included in IHS: AQUAPROD.GEN , meaning 
whole, non -salmon id fish may be imported if the exporting country can demonstrate freedom for the risk 
organisms identified for the family the fish species belongs to.  This recommendation will also apply to 
products derived from such fish that are unable to be imported under  any of the other product categories 
presented in the IHS.  
(2) The IHS will also enable the importation of treated fish products from recognised countries where MPI has 
approved that the treatment, as per the Fish IRA, inactivates the risk organisms associated  with the 
species of fish.  
(3) The fish families that can be imported under this category are those that have been identified in the Fish 
IRA and listed in Schedule 3  of the IHS.  
(4) Before trade can commence for the commodities above, the exporting country will r equire MPI recognition 
as per Clause 1.5 of the IHS and a negotiated health certificate.  
6.1.4 Low-risk non -salmon id fish products from any country  
(1) The Fish IRA identified some fish families that have not been reported in scientific literature as being 
associate d with risk organisms of concern to New Zealand. The RMP proposes allowing importation of 
these low -risk non-salmonid fish families in whole form. These families are presented in Schedule 4  of the 
IHS. 
(2) Some fish species  popular as bait  are also imported fo r other end uses. Hence, recommendations for the 
importation of whole fish made in the Supplementary Import Risk Analysis: Frozen Fish and Cephalopod 
Molluscs for Fish Bait  (Fish Bait SRA) are included in this RMP.  
a) Fish species associated with risk organisms that are mitigated by freezing at -18°C for a period of no 
less than 168 hours are listed in Schedule 5  of the  IHS. 
b) Fish species associated with risk organisms that are mitigated by freezing at -18°C for a period of no 
less than four months  are listed in Schedule 6  of the IHS . 
Note : The Fish Bait SRA recommended freezing temperatures of between -18°C and -20°C , but for 
simplicity the single temperature of -18°C has been proposed . 
(3) In the Fish Bait SRA, the risk management options recommended for bait do not extend to all members of 
a fish family but are limited to the specific fish species. Because of this , Schedules 5  and 6 of the IHS  list 
fish by species instead of by families.  
 
1 Marine fish means a species that spends all of its lifecycle in saltwater. An example of a marine fish species is Thunnus thynnus , the Atlantic bluefin tuna . 
A fish (such as the salmon) that spends part of its lifecycle in freshwater environment is not a marine fish even if harveste d from saltwater. MPI uses 
FishBase ( www.fishbase.org ), the global biodiversity informati on system on fish, for determining the marine status of fish. If any one of the terms 
“freshwater”, “anadromous”, “catadromous”, “amphidromous”, “diadromous”, or “potamodromous” is mentioned in FishBase’s “Envir onment” section for the 
species, then it does  not qualify as a marine fish species . Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 11 6.1.5 Non-salmon id fish products from any country for further processing in New Zealand  
(1) MPI is propos ing allowing importation of whole fish of any non -salmon id species from any country 
provided further  processing occurs at a transitional facility  in New Zealand . The exporting country can use 
the model health certificate included in the guidance document.  
(2) An import permit will be required for importing the fish so that the consignment may b e directed to the 
transitional facility  named on the permit.  
Schedule 9  of the IHS outlines  the transitional facility requirements . 
(3) To be eligible for clearance, the fish must be processed at the transitional facility  to one of the product 
categories described in Section 6.1.6 (Specified non -salmon id fish products) of this document.  
6.1.6 Specified non -salmon id fish products  
(1) The Fish IRA rec ognises treatments (such as heating and freezing) and processing (such as filleting) as 
options for mitigating biosecurity risks in aquatic animal products . The Fish IRA’s recommendation s are in 
line with the advice provided in Article 5.4.1 of the Aquatic  Code , which considers criteria to assess the 
safety of aquatic animal products regardless of the disease status of the exporting country.  
Non-salmon id fish skin-off fish f illets  
(2) The Fish IRA  determined that processing fish to skin -off fillets  manages the risk for 38 of the total 40 risk 
organisms identified in the document . The remaining two risk organisms —cestode larvae and the Asian 
eel swimbladder worm ( Anguillicola crassus) —are present in the musculature of some fish families , and so 
removing the skin does not eliminate them.  Freezing to -20°C or below for a minimum of 168 hours is a 
recommended measure for eliminating cestodes, while the recommended temperature for inactivating 
A. crassus  is -20°C for 60 hours. Since many fish families susceptible to A. crassus  infestation are also 
susceptible to cestode  larvae infestation , MPI is propos ing the former time –temperature parameter ( -20°C 
for 168 hours) as the import requirement for skin -off fillets derived from non-salmon id fish families  
susceptible to either or both of these two risk orga nisms.  
(3) Non-salmon id fish families that have not been reported in scientific literature as being affected by c estode 
larvae and A. crassus  can be imported as non -frozen skin -off fillets. They are listed in Schedule 7  of the 
IHS. 
Dried non -salmon id fish prod ucts 
(4) The Fish IRA , in line with the advice provided in Article 5.4.1 of the Aquatic Code , recommend ed that dried 
non-salmon id fish products can be imported  regardless of the disease status of the exporting country  
provided the fish is eviscerated and mechanically dried by heating to a minimum core temperature of 
100°C for a period of no less than 30 minutes.  
(5) Dried products may be derived from any fish specie s and are not restricted to the families listed in 
Schedule 3  of the IHS.  
Non-salmon id fish products in retail packaging  
(6) The Risk Team found that the small amount of waste that may be generated from imported aquatic animal 
products at the end  users’ point is likely to be directed to landfills, domestic sewerage, and official rubbish 
disposal systems. Consequently, the likelihood of the waste material entering the aquatic environment 
would be minimal. In the event of any waste material entering the aquatic e nvironment, the likelihood of a 
susceptible fish receiving an infectious dose of an exotic pathogen because of exposure to the waste 
material was deemed to be negligible.  
(7) Aligned with the Risk Team’s conclusion, Article 5.4.2 of the Aquatic Code  considers criteria to assess the 
safety of aquatic animal products that are imported for retail trade regardless of the disease status of the 
exporting country. The criteria for considering products safe to trade include the type of product  and the 
volume of waste g enerated.  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 12 (8) This RMP proposes inclusion in the IHS of non -salmon id fish products in retail packaging with a limit of 
1 kg or 1  litre net content (combined aquatic animal ingredients and non -aquatic animal ingredients) in the 
retail packaging. The content lim it is to minimise generation of aquatic animal waste.  
(9) Retail packaging is defined in the IHS as the original imported primary packaging, designed for direct sale 
of the aquatic animal product to households and businesses in the food service sector in New Zealand.  
(10) Fish products in retail packaging must be frozen and  may be derived from any non-salmonid fish species 
and are not restricted to the families listed in Schedule 3  of the IHS.  
6.2 Crustacean products  
(1) The Crustacean IRA assessed the risks associated with the importation of crustacean products and 
identified four organisms, namely Aphanomyces astaci , Hematodinium  spp., Angiostrongylus cantonensis,  
and Paragonimus  spp., that require consideration for  risk mitigation measure s. 
Aphanomyces  astaci   
(2) The Crustacean IRA assessed Aphanomyces astaci  (crayfish plague) as a risk in crabs and lobsters  and 
recommended the following risk mitigation options.  
a) Option 1 : 
i) Freshwater crustaceans  could be imported only from countries, zones or compartments that 
have been recognised by MPI as  free from A. astaci .  
b) Option 2 : 
i) Freshwater crustacean products could be imported in the following forms:  
1) Heat -sterilised hermetically sealed freshwater crustacean products (i.e. a heat 
treatment at 121°C for at least 3.6 minutes or any time/temperature equivalent that has 
been demonstrated to inactivate A. astaci ). 
2) Freshwater crustacean products that have been subjected to heat treatment at 100°C 
for at least one mi nute (or any time/temperature equivalent that has been demonstrated 
to inactivate A. astaci ). 
3) Freshwater crustacean products that have been subjected to heat treatment at 90°C for 
at least 10 minutes (or any time/temperature equivalent that has been demons trated to 
inactivate A. astaci ). 
4) Frozen Freshwater crustacean products that have been subjected to -20°C or lower 
temperatures for at least 72 hours . 
c) Option 3: 
i) Freshwater crustacean products could be imported from areas where A. astaci  is present, 
provided  it is prepared and packaged for retail trade for human consumption (Article 9.2.11 of 
the Aquatic Code ) and the associated packaging is clearly marked with the words “ For human 
consumption only . Not to be used as bait or feed for aquatic animals .” 
(3) Crayfish plague,  an OIE listed disease, is considered the most serious disease of freshwater crayfish.  
(4) The main pathways for introduction of A. astaci  to naïve crayfish populations is through the movement of 
infected individuals by humans, movement of spor es with contaminated water or equipment, and through 
the natural secondary spread of invasive resistant host species. However, f or part of its life -cycle A. astaci  
exists as a free -swimming biflagellate zoospore that is chemotactically attracted to crayfis h cuticle and can 
survive for prolonged periods outside a host.  The entry of infected crayfish used as bait, or disposed of in 
municipal landfill, into freshwater environments or contaminated wastewater  may facilitate the release of 
free-swimming biflagell ate zoospores  and subsequent infection of susceptible individuals . 
(5) Recommendations in this RMP are to adopt the risk mitigation options from the Crustacean I RA with some 
changes (see sections 6.2.1 and 6.2.2  of this document ). Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 13 Hematodinium  spp.  
(6) The Crustacean IRA assessed Hematodinium  spp. as a risk in crabs and lobsters, and recommended the 
following risk mitigation options:  
a) Option 1 : 
i) Crab and lobster  product s could be imported from countries, zones or compartments that have 
been recognised by MPI as free from Hematodinium  spp. 
b) Option 2:  
i) Crab and lobster products that have been frozen to a minimum core temperature  of -18°C.  
c) Option 3:  
i) Crab and lobster products that have been cooked unt il all the protein in the crustacean meat is 
coagulated. Precautions must be taken to avoid any post -processing contamination (e.g. 
contact with raw crustaceans).  
d) Option 4:  
i) Crab and lobster products that have been prepared and packaged for retail trade for  human 
consumption and the associated packaging is marked with the words “ For human 
consumption only . Not to be used as bait or feed for aquatic animals .” 
(7) Hematodinium  spp. are parasitic dinoflagellates that have recently been identified as important patho gens 
of decapod crustaceans. They are not OIE listed.  
(8) If the organism was present in imported product and this was used as bait, an individual or a small number 
of individual  crabs or lobsters could become infected and transmission could occur , as free -living 
Hematodinium  spp. can remain viable in seawater for 5 days . The Crustacean I RA does consider this an 
unlikely event. Transmission in wild pop ulations  of temperate and cold-water  crustaceans has been 
demonstrated.  
(9) Recommendations in this RMP  are to adopt the risk mitigation options from the Crustacean I RA with some 
changes (see sections 6.2.1 and 6.2.2  of this document ). 
Angiostrongylus cantonensis  
(10) The Crustacean IRA assessed Angiostrongylus cantonensis  as a risk in freshwater crustaceans an d 
recommended the following risk mitigation options : 
a) Option 1:  
i) Freshwater crustacean products could be imported from countries, zones or compartments 
that have been recognised by MPI as free from A. cantonensis . 
b) Option 2:  
i) Freshwater crustacean products could be frozen to a minimum core temperature of -18°C for 
a period of not less than 12 hours.  
c) Option 3:  
i) Freshwater crustacean products that have been cooked until all the protein in the crustacean 
meat has coagulated.  
(11) A. cantonensis , which is also known as the rat lungworm, is a nematode and can cause  zoonotic disease  
(eosinophilic meningitis)  in humans . Rats are the definitive host and several species of land snails are 
intermediate host s. Important paratenic hosts are freshwater  shrimp and fish.  Modes of transmission  as a 
zoonosis  include ingestion by humans  of raw fish, snails and fresh leafy vegetables contaminated by snail 
slime trails containing A. cantonensis  larvae.   
(12) A small proportion of chilled freshwater crustaceans could be disposed of uncooked (spoiled) at a landfill. 
For establishment, infected crustacean tissue would need to be scavenged by a suitable definitive host Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 14 (i.e. rats). A suitable intermediate snail host would then need to consume infected rat faeces and then 
itself be consumed by a rat.  
(13) Despite literature supporting fish being a paratenic host for A. cantonensis , this parasite was not 
considered a hazard  in fish in the Fish IRA. When considering the unlikely pathwa y for establishment 
through discarding of chilled infected crustacean product s in a landfill , A. cantonensis  is considered a 
negligible risk and will not be considered further.  
Paragonimus spp  
(14) The Crustacean IRA assessed Paragonimus  spp. as a risk in fresh water crustaceans and recommended 
the following risk mitigation measures:  
a) Option 1:  
i) Freshwater crustacean products could be imported from countries, zones or compartments 
that have been recognised by MPI as free from Paragonimus  spp. 
b) Option 2:  
i) Freshwater crustacean products could be frozen to a minimum core temperature  of -18°C.  
c) Option 3:  
i) Freshwater crustacean products that have been cooked until all the protein in the crustacean 
meat is coagulated.  
(15) Paragonimus  spp. belong to the  trematode  family , and commonly referred to as lung flukes.  Paragonimus 
spp. are not OIE listed  but are classified as exotic unwanted organisms  under the Biosecurity Act. 
(16) Paragonimiasis is a zoonotic infection caused by a parasite with a complex lifecycle which includes two 
intermediate hosts (molluscs and crustaceans) and a definitive host (terrest rial mammals, including 
humans).  
(17) For establishment, spoilt chilled crustaceans would need to be left at a landfill, and scavenged by a 
definitive (e.g. cats) or paratenic host (e.g. rodents). The paratenic host may then be eaten by a definitive 
host, which  would then need to defecate in, or near, an aquatic habitat. This would enable the expelled 
parasitic eggs to infect a suitable molluscan host. The parasite would then be required to infect a suitable 
second intermediate host (crustacean) which finally mu st be consumed by an appropriate mammalian host 
to fulfil the parasite ’s life-cycle.  
(18) When considering the unlikely pathway for establishment through discarding of chilled infected crustacean 
product in a landfill , it is considered a negligible risk and wil l not be considered further.  
6.2.1 Crustacean products from recognised countries  
(1) The Crustacean IRA recommended acceptance of country/zone freedom for risk organisms applicable to a 
crustacean species as a risk management option. This recommendation is included in 
IHS: AQUAPROD.GEN : 
a) Crustacean products from species susceptible to Aphanomyces astaci  could be imported from areas 
free from this risk organism . 
b) Crab and lobster  products could be imported from areas free from Hematodinium  spp. 
(2) Note that o ther o ptions are offered for frozen, heat treated , and consumer -ready packaged crustacean 
products (see the product categories in section 6.2.2  of this document ). Before trade can commence f or 
chilled crustacean  products that are not in retail  ready packaging,  the exporting country will require MPI 
recognition as per Clause 1.5 of IHS: AQUAPROD.GEN  and a negotiated health certificate.  
6.2.2 Specified crustacean products  
(1) Considering the Crustacean IRA’s risk management recommendations for Aphanomyces astaci  and 
Hematodi nium  spp., the RMP proposes importation of the following categories of specified crustacean 
products.  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 15 Heat -treated crustacean products  
(2) For Aphanomyces astaci , the Crustacean IRA and the Aquatic Code  recommend the following heat 
treatment options for products derived from crustacean species susceptible to A. astaci : 
a) Heated to a minimum core temperature of 100°C for a period of not less than one minute; or  
b) Heated to a minimum core temperature of 90°C f or a period of not less than 10 minutes.  
Schedule 8  of IHS: AQUAPROD.GEN  presents the list of crustacean species susceptible to A. astaci.  
(3) For Hematodinium  spp., the Crustacean IRA does  not give any specific time –temperature heat treatment 
parameters. Crustacean products , other than those derived from species susceptible to A. astaci , will be 
eligible for import provided they have been cooked until all the protein in the crustacean meat is 
coagulated . 
Frozen crustacean products  
(4) The Crustacean IRA recommends the following minimum freezing time –temperature parameters for the 
two risk organisms of concern to New Zealand.  
 
 
(5) The risk mitigation measure for products from crustacean species susceptible to A. astaci  will be  freezing 
to a minimum core temperature of -20°C for a period of not less than 72 hours.  
Schedule 8  of IHS: AQUAPROD.GEN  presents the list of crustacean species susceptible to A. astaci.  
(6) For mitigating the risk from Hematodinium spp., MPI proposes p roducts derived from crustacean species 
other than those listed in Schedule 8 of IHS: AQUAPROD. GEN be frozen to a minimum core temperature 
of -18°C with no specific requirement  for time.  
Crustacean products in retail packaging  
(7) The Crustacean IRA recommended that crustacean products can be imported regardless of the disease 
status of the exporting country  provided they are prepared and packaged for retail trade for human 
consumption  and the associated packaging is clearly marked with the words “For human consumption 
only, Not to be used as bait or feed for aquatic animals .” 
(8) Given that crustacean products can also be used for purposes other than human consumption (but not as 
bait or feed for aquatic animals ), this RMP proposes the label to exclud e the words “ For human 
consumption only .” 
(9) MPI is also proposing a limit of 1 kg or 1 litre net content (combined aquatic animal ingredients and non -
aquatic animal ingredients) in the retail packaging. The content limit is to minimise the generation of 
aqua tic animal waste . 
(10) Section 6.1.6( 10) of this document describes retail packaging. at non -freezing temperature  
6.3 Mollusc products  
(1) With the exception of what have been proposed in section 6.3( 2) of this document, MPI is proposing 
retaining the measures for moll uscs as stated in the current Import Health Standard For The Importation 
Of Marine Fisheries Products For Hum an Consumption From All Countries , FISMARIC.ALL . These 
measures are based on previous risk assessment s. The measures are recognised by the CTO as being 
conservative, and when additional risk advice becomes available in the future it is expected that a wide r 
range of mollusc products will be able to be imported.  
(2) The following m inor changes to the current import requirements are proposed:  Risk organism  Freezing parameters  
Aphanomyces astaci  -20°C for at least 72 hours  
Hematodinium  spp -18°C (the Crustacean IRA does not specify duration)  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 16 a) There will be the new requirement to include a health certificate , attesting the current requirements 
that the molluscs have been shelled and either cooked, dried,  or frozen.  
b) A commonly requested commodity is mollusc meat that has been removed from the shell and then 
placed on a clean sh ell for presentation purposes. Importation o f this commodity will be allowed, 
provided MPI is satisfied with the manufacturing process for cleaning of the shell. This will 
necessitate an import permit.  
6.4 Echinoderm  products  
(1) MPI is proposing retaining the measures for echinoderm products as stated in t he current Import Health 
Standard For The Importation Of Marine Fisheries Products For Human Consumption From  All Countries , 
FISMARIC.ALL . These measures are based on previous risk assessments, the outcomes of which are 
documented in the form of the IHS. Commercially prepared and packaged echinoderm (such as sea 
urchins and sea cucumbers) products can be imported  from any country.  
6.5 Tunicate products  
(1) Tunicates have previously been assessed as posing negligible risk when imported as commercially 
prepared and packaged products. The current import risk mitigation measures as stated in the Import 
Health Standard for the Importation of Marine Fisheries Products for Human Consumption from All 
Countries , FISMARIC.ALL  will remain  in place for these products. Tunicate (such as sea squirts) products 
can be imported from any country.  
6.6 Cnidaria n products  
(1) Cnidaria have previously been assessed as posing negligible risk when imported as commercially 
prepared and packaged products.  The c urrent import risk mitigation measures as stated in the Import 
Health Standard for the Importation of Marine Fisheries Products for Human Consumption from All 
Countries , FISMARIC.ALL  will remain in place for these products. Cnidarian (such as jellyfish) products 
can be imported from any country.  
6.7 Aquatic animal meal  and aquatic animal oil 
(1) Fishmeal and fish oil not intended for manufacture into fish food is currently imported under the Import 
Health Standard for Fish Foo d and Fish Bait from All Countries , FISFOOIC.ALL , provided the commodities 
are manufactured by heat ing to a minimum core temperature of 80°C for a period of no less than 20 
minutes. Measures in IHS:FISFOOIC.ALL  are based on the recommendations made in the Import Risk 
Analysis: Fish Food . 
(2) Though the  Import Risk Analysis: Fish Food  looked at risks only in fish products, a review of the all the risk 
advice provided in the Fish IRA  and the Crustacean IRA, and taking into consideration the generic 
description of the rendering process applied for manufacturing aquatic animal meal and aquatic animal oil, 
MPI proposes applying the above heat treatment parameters (80°C for 20 minutes) to meals and oils 
derived from all aquatic animals.  
(3) MPI further propo ses health certification requirement for aquatic animal meal and aquatic animal oil 
instead of a manufacturer’s declaration, which is the current requirement in IHS: FISFOOIC . 
  Risk Management Proposal: Aquatic Animal Products  
Ministry for Primary Industries   Page 17 Appendix 1 – Document History  
Date First Issued  Title Shortcode  
2 August 2021  
(Internal Consultation)  Risk Management Proposal: Aquatic Animal 
Products  RMP AQUAPROD.GEN  
11 October 2021  
(External Consultation)  Risk Management Proposal: Aquatic Animal 
Products  RMP AQUAPROD.GEN  
Date of Issued A mendments  Title