DRAFT EAST AFRICAN STANDARD
 DEAS 830 :2014 
ICS 67.120.30  
 
© EAC 2014 First Edition 2014  
 
 
 
 
 
 
 
DRAFT EAST AFRICAN STANDARD 
 
 
 
 Frozen fish sticks (fish fingers), fish portions and fish fillets — 
Breaded or in batter — Specification 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EAST AFRICAN COMMUNITY  DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2014 — All rights reserved ii  
 
Foreword 
 
Development of the East African Standards has been necessitated by the need for harmonizing 
requirements governing quality of products and services in East Africa. It is envisaged that through 
harmonized standardization, trade barriers which are encountered when goods and services are 
exchanged within the Community will be removed.  
 
In order to meet the above objectives, the EAC Partner States have enacted an East African 
Standardization, Quality Assurance, Metrology and Test Act, 2006 (EAC SQMT Act, 2006) to make 
provisions for ensuring standardization, quality assurance, metrology and testing of products 
produced or originating in a third country and traded in the Community in order to facilitate industrial 
development and trade as well as helping to protect the health and safety of society and the 
environment in the Community . 
 
East African Standards are formulated in accordance with the procedures established by the East 
African Standards Committee. The East African Standards Committee is established under the 
provisions of Article 4 of the EAC SQMT Act, 2006. 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 
through 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.  
 
Article 15(1) of the EAC SQMT Act, 2006 provides that “ Within six months of the declaration of an 
East African Standard, the Partner States shall adopt, without deviation from the approved text of the 
standard, the East African Standard as a national standard and withdraw any existing national 
standard with similar scope and purpose”.  
 
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.  
 
© East African Community 2010 — All rights reserved* 
East African Community  
P O Box 1096  
Arusha  
Tanzania  
Tel: 255 27 2504253/8 
Fax: 255- 27-2504481/2504255 
E-Mail: eac@eachq.org  
Web: www.each.int 
                                                           
* 2014 EAC — All rights of exploitation in any form and by any means reserved worldwide for EAC Partner Sta tes’ NSBs. 
 DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved    Frozen fish sticks (fish fingers), fish portions and fish fillets — Breaded or in 
batter — Specification  
 
 
1 Scope 
This draft East Africa draft standard specifies requirements and methods of sampling and test for 
frozen fish sticks (fish fingers), 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. 
 
 
CODEX STAN 192 , General standard for food additives  
EAS 39, Hygiene in the food and drink manufacturing industry ― Code of practice 
CAC/RCP 52[CD/K/521:2010] , Code of practice for fish and fishery products  
 
EAS 12,  Drinking (potable water) — Specification  
 
EAS 38, Labelling of pre-packaged foods — Specification 
 
EAS 103, Schedule for permitted food additives  
 
ISO 483 3, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration of 
microorganisms — Colony-count technique at 30 degrees C  
 
ISO 6579, Microbiology of food and animal feeding stuffs — Horizontal method for the detection of 
Salmonella spp.  
 
ISO 6888- 1, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration 
of coagulase-positive staphylococci (Staphylococcus aureus and other species) — Part 1: Technique 
using Baird-Parker agar medium  
 
ISO 6888- 2, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration 
of coagulase-positive staphylococci (Staphylococcus aureus and other species) — Part 2: Technique 
using rabbit plasma fibrinogen agar medium  
 
ISO 6888- 3, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration 
of coagulase-positive staphylococci (Staphylococcus aureus and other species) — Part 3: Detection 
and MPN technique for low numbers  
 
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- 2, Microbiology of food and animal feeding stuffs — Horizontal method for the detection 
and enumeration of Listeria monocytogenes — Part 2: Enumeration method 
 
ISO 7937, Microbiology of food and animal feeding stuffs — Horizontal method for the enumeration of 
Clostridium perfringens — Colony-count technique 
 
ISO 270 85, Animal feeding stuffs -- Determination of calcium, sodium, phosphorus, magnesium, 
potassium, iron, zinc, copper, manganese, cobalt, molybdenum, arsenic, lead and cadmium by I CP-
AES DRAFT EAST AFRICAN STANDARD  DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved    
ISO 16050,  Foodstuffs — Determination of aflatoxin B 1, and the total content of aflatoxin B 1, B2, G 1 
and G 2 in cereals, 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 water activity greater than 0.9 
 
AOAC 990.04 Mercury (Methyl) in seafood by liquid chromatography-atomic absorption spectroscopy 
(LC-AAS) 
 
AOAC 977.15 / 974.14,  Mercury in fish by flame atomic absorption spectroscopy (FAAS) 
 
 
3 Terms and definitions 
 
3.1 
fish stick (fish finger)  
the product including the coating weighing not less than 20 g and not more than 50 g shaped so that 
the length is not less than three times the greatest width. Each stick shall be not less than 10 mm 
thick.  
 
3.2  
fish portion 
including the coating, other than products stipulated under 3 .1, may be of any shape, weight or size.  
 
3.3  
fillets  
slices of fish of irregular size and shape which are removed from the carcass by cuts made parallel to 
the back bone and pieces of such fillets, with or without the skin.  
 
3.4 
batter 
liquid preparation from ground cereals, spices, salt, sugar and other ingredients and/or additives for 
coating. Typical batter types are non-leavened batter and leavened batter. 
 
3.5  
breading  
dry breadcrumbs or other dry preparations mainly from cereals with colourants and other ingredients 
used for the final coating of fishery products. Breading types are free flowing breading, coarse 
breading and flour type breading. 
 
3.6  
coating  
covering the surface of a fishery product with batter and/or breading 
 
4 Requirements 
 
4.1 General requirements 
 
4.1.1 Frozen breaded or battered fish sticks (fish fingers) breaded or battered fish portions and 
breaded or battered fillets shall be prepared from fish fillets that conforms to DEAS 827:2014 or 
minced fish flesh, or mixtures thereof, of edible species which are of a quality such as to be sold fresh 
for human consumption 
 
4.1.2 The coating and all ingredients used therein shall be of food grade quality and conform to 
relevant codex or east Africa standards. 
 DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved   4.1.3 Fat or oil used in cooking operation shall be suitable for human consumption and conform to 
relevant east Africa or codex standard. 
 
4.1.4 The product shall be free from foreign matter 
 
4.1.5The product shall not have objectionable odour and flavours 
  
4.1.6 Water used for washing the fish shall comply with EAS 12. 
 
 
4.2 Specific requirements 
 
4.2.1 The products shall not contain more than 10 mg/100 g of histamine based on the average of the 
sample unit tested. This shall apply only to species of Clupeidae, Scombridae, Scombresocidae, 
Pomatomidae and Coryphaenedae families. 
 
4.2.2 The frozen fish sticks (fish fingers), fish portions and fish fillets — Breaded or in batter shall have 
a temperature of -18ºC 
 
5 Hygiene 
 
The product covered by the provisions of this standard shall be prepared and handled in accordance 
with, EAS 39 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  Max. limits  Method s of test  
i Salmonella  per 25 g  Absent  ISO 6579  
ii E. coli  per gram  absent  ISO 7251  
iii Shigella  per gram  Absent  ISO 21567  
iv listeria monocytogenes  absent  ISO 11290 PART 1 &2  
v Staphylococcus aureus  cfu per gram  100 ISO 6888  
vi Clostridium perfringe ns per gram  Absent  ISO 7937  
vii Vibrio Spp  per gram  Absent  ISO  21872  
viii Total viable count per gram  105 ISO 4833  
ix Yeast and mould  102 ISO 21527 -1 
 
 
6 Contaminant  
 
Frozen fish sticks (fish fingers), fish portions and fish fillets — Breaded or in batter shall comply with 
the contaminant limits given in t able 2.  
 
 
Table 2  — Contaminant limits for frozen fish sticks (fish fingers), fish portions and fish fillets 
— Breaded or in batter  DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved    
S/No  Type of contaminant  Maximum limit  
(mg/kg)  Methods of test  
i Arsenic  0.1 ISO 27085  
ii Mercury  0.5 AOAC 
977.15/974.14  
iii Lead  0.3 ISO 27085  
iv Cadmium  0.3 ISO 27085  
v Methyl  mercury  0.5 AOAC 990.04  
 
7 Food additive  
 
Permitted  additives  may be used in the processing of frozen fish sticks (fish fingers), fish portions 
and fish fillets — Breaded or in batter in accordance with CODEX STAN 192.  
 
8 Weight and measures 
 
The weight of the product shall comply with Weight and Measures regulations of Partner States or 
equivalent legislation  
 
9 Packaging and labelling 
 
9.1 Packaging 
 
9.1.1 Frozen  fish sticks (fish fingers), fis h portions and fish fillets — Breaded or in batter  shall be 
packaged in food grade containers which will safeguard the hygienic, nutritional, and organoleptic 
qualities of the product.  
  
9.1.2  The containers, including packaging material, shall be made of substances which are safe and 
suitable for their intended use. They shall not impart any toxic substance or undesirable odour or 
flavour to the product. 
 
9.2 Labelling 
 
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 shall be "... "breaded" and/or "battered", "fish sticks" (fish fingers), "fish 
portions", or "fillets" 
b) Storage and transportation conditions declaring the temperature to be -18C or lower 
c) Name and physical address of processor or packer 
d) Net weight in grams or kilograms 
e) Date of production or packaging 
f) Batch or code number 
g) Expiry date 
h) Instruction for use 
i) Country of origin 
 
9.3 Labelling of Non-retail Containers DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved    
9.3.1 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 well as storage instructions, shall appear on the container. 
 
9.3.2 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 
accompanying documents. 
 
10 Methods of sampling and test 
 
Sampling and tests shall be done as per test methods described in respective tables.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 DRAFT EAST AFRICAN STANDARDDEAS 830:2014  
© EAC 2010 — All rights reserved