G/SPS/GEN/1585  
25 October  2017 
(17-5802) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original:  French  
 
  
REVISION OF THE PRELIMINARY DRAFT GUIDELINES ON  
HISTAMINE CONTROL IN THE CODE OF PRACTICE FOR  
FISH AND FISHERY PRODUCTS (CAC/RCP 52 -2003)  
COMMUNICATION FROM MOROCCO  
This communication, dated 24 October  2017, is being circulated at the request of the delegation of 
Morocco . 
 
_______________  
 
 
1  INTRODUCTION  
1.1.  The Government of Morocco has the honour of drawing the attention of WTO Members to the 
fact that the fishery sector  is a resource that provides  structure to the  Moroccan economy, and is 
one of the pillars of the domestic economy . It has contributed  an average of 2.3% to GDP during 
the last ten years . In 2015, the fishery sector recorded an export turnover of US$1.85  billion , 
represent ing 6.8% of total exports and 58 % of exports of agr i-food products (Trade, 2016).  
1.2.  The fishery sector  creates over 26,000 direct jobs and 100,000 indirect jobs . The level of 
employment could be higher if units had the possibility to funct ion at maximum capacity, instead 
of at 50%, which is currently the case.  
1.3.  Since  2011, within  the Codex Alimentarius, the delegation of Japan has been proposing that 
the issues relating to histamine be examined from a broader perspective, that the public hea lth 
risks linked to the presence of histamine in fish and fish ery products be studied, and that the 
existing sampling plans and different levels of protection applied on a national scale be taken into 
account . It has emphasized that this work should be car ried out in conjunction with the study on 
microbiological criteria currently being conducted by the Codex Committee on Food Hygiene . An 
electronic working group, co -chaired by Japan and the United States, has since been mandated to 
examine the issue of histamine from different angles, with a view to lowering  the current 
histamine limit in fishery products.  
1.4.  Given that a potential reduction of the histamine level for  fishery products would be 
problematic for its export s, Morocco, which is aware of the socio -economic challenges that come 
with this issue , has stressed the need to prepare  the missions organized by the Codex Alimentarius 
over the last six years , and members of the Moroccan delegation have participated in the work of 
the different electronic working groups set up by the Codex Alimentarius secretariat.  
1.5.  The observations made by the members of the electronic working groups, of which  Morocco is 
an active member, have address ed a large number of topics relating to  histamine, in particular:  
 maintaining the current histamine limit  for health and safety within the standard s or 
revising the current limit  downward  on the basis of dose -response data, taking into 
account  uncertainty  and other risk management  factors ; 
 creating a new histamine sampling plan;  
 considering different histamine limits for products based on consumption levels, or other 
product  characteristics ; and 
 re-evaluating the histamine limit for decomposition to include it within the standard s. G/SPS/GEN/1585  
- 2 - 
  2  CONSEQUENCES OF LOWERING THE HISTAMINE LIMIT  
2.1.  If a reduction of the histamine safety limit were approved within  the Codex Alimentarius, it 
would be very difficult  for products from Morocco and other developing countries to meet th is 
requirement, and as a re sult: 
 Moroccan exports of fishery products would be impeded (particularly for pelagic fish such 
as: sardine s, ancho vies, mackerel, tuna , etc.). 
 Lower exports would have a proportional effect on employment along the entire value 
chain . Between  16,000 and 17,000 direct jobs would be lost if exports decreased by 60%, 
and between  5,000 and 6,000 direct jobs if exports fell by  20%, with simultaneous 
negative  repercussions for indirect jobs . 
 The price of sought -after raw materials w ould rise and the supply of products w ould 
decrease, which would lead to an increase in the price of finished products, especially as 
demand is growing , particularly for exports to Africa . Such demand represents  between 
40% and 45 % of exports , particularly  to countries with limited r evenue . This category of 
the population would be heavily affected , as it would have to pay higher prices or reduce 
consumption.  
 
3  CONCLUSIONS  
3.1.  Given the fact that : 
 the threshold toxic dose for histamine  in fish is not clearly or precisely defined 
(Taylor,  1986) . In most cases, histamine levels in illness -causing fish have been above 
200 mg/kg, and often above  500 mg/kg (FDA, 2011) ; 
 the potential lowering of the limit could have a damaging socio -economic impact on the 
sector;  
 
Morocco calls on members of Codex Alimentarius to take into account the exports of developing 
countries in the definition of a new lower limit of histamine in fishery products and the new 
guidelines for histamine control, while preventing a negative impact on  the economies of such 
count ries. 
 
3.2.  It is paramount that the socio -economic repercussions of this action  be taken into account . 
The Codex Procedural Manual clearly stipulates (page 121) that the chairperson  of a Codex 
committee must ensure  that matters are not progressed from step to step until all relevant 
concerns are taken into account and adequate compromises worked out . 
3.3.  Morocco proposes that Codex Alimentarius establish a group of experts to examine the 
preliminary draft guidelines on histamine control in the Code of Practice for Fish and Fishery 
Products (CAC/RCP 52 -2003) , particularly the application of the HACCP system to artisanal fishing 
boats, which is very difficult  to implement . 
__________