Malaysia Seafood Labelling: Fish Products, Frozen Prawns and Glaze Net Weight

Seafood and aquatic products sold in Malaysia are labelled under the administration of the Food Safety and Quality Division (FSQD) of the Ministry of Health, per the Food Act 1983 and the Food Regulations 1985. Whether it is fresh fish, frozen fish and prawns, fish balls, surimi, fish sauce, shrimp paste (petis/heko) or canned seafood, as long as it is manufactured or imported for retail in Malaysia, the label must comply with the prescribed standards for "fish and fish products" in Part VIII of the Food Regulations and the general labelling requirements. Imported aquatic products must additionally pass border inspection and sampling by the Malaysian Quarantine and Inspection Services (MAQIS), which has the power to re-export, detain or destroy non-compliant containers.

How seafood is classified

The Food Regulations divide aquatic products into several categories, each with its applicable standard and naming rule:

The product name must use a prescribed/common name that reflects the substance, e.g. stating the fish species (such as "tilapia" or "mackerel"), must not pass off a low-priced fish as a high-priced species, and must not use a misleading name or graphic.

Glaze and net weight

The most dispute-prone issue for frozen aquatic products is the glaze weight. The internationally accepted principle, consistent with Codex, is: glaze serves a protective purpose and should not be counted in the net quantity of the food. Therefore the net weight declared for frozen fish and prawns should be the actual product weight after de-glazing (the so-called drained / net weight), and pumping the ice weight into the net weight is short measure and economic adulteration. Practical advice:

• Declare the net quantity as the "actual aquatic-product net weight", and where necessary additionally state the total weight including glaze for reference.
• If the glaze proportion is high, distinguish it more clearly to avoid consumers and inspectors deeming it padded.
• Water-retaining agents added in processing (such as polyphosphates) must be disclosed in the ingredient list and comply with the Food Regulations' permitted level for that additive.

Borax and prohibited substances

Malaysia expressly prohibits adding borax (boric acid) in food processing, commonly used by unscrupulous operators to increase the crunchiness and appearance of fish balls and prawns. Borax is harmful to health; once detected it is unlawful, regardless of labelling — no matter how nicely the label is written, it cannot save the product. In addition, additives such as preservatives and colourings must all fall within the Food Regulations' permitted list and levels, and be truthfully declared on the label.

Mandatory general label particulars

Products containing beef, pork or alcohol must carry a conspicuous declaration; where halal certification is obtained, the halal mark must comply with JAKIM rules.

Imported aquatic products: the MAQIS gate

Beyond label compliance, imported aquatic products must have the exporting country's health certificate ready, declare as required, and undergo MAQIS sampling. Common sticking points include: labels missing Malay/English mandatory particulars, net weight padded with ice, microbiological or heavy-metal exceedances, and documents not matching the actual goods. It is advisable to prepare labels and documents in one go before shipment, to avoid detention on arrival.

Common mistakes

• Frozen prawns counting the glaze weight into the net weight.
• Fish-species labelling not matching the actual product (passing off a cheap fish as an expensive one).
• Water-retaining agents or preservatives added but not disclosed in the ingredient list.
• Imported goods carrying over the overseas label, omitting Malay/English, country of origin or the local importer.

Frequently asked questions (FAQ)

Q: Should the net weight of frozen fish and prawns include the glaze? No. Glaze is regarded as a protective layer; the net quantity should state the actual product weight after de-glazing; pumping ice weight into the net weight is short measure.

Q: Can fish balls have borax added for crunchiness? Absolutely not. Borax is a prohibited substance in Malaysia; once detected it is unlawful, regardless of whether it is labelled.

Q: What else does imported frozen seafood need beyond labelling? It must pass MAQIS border inspection, have the exporting country's health certificate ready, and declare as required; non-compliance may result in re-export, detention or destruction.

Q: Can a common/colloquial name be used for the fish species? A common/colloquial name may be used, but it must truthfully reflect the actual species, and must not pass off another species or mislead consumers.

Q: Is adding water-retaining agent (polyphosphate) lawful? It may be used within the permitted scope and level, but must be truthfully disclosed in the ingredient list and comply with the Food Regulations for that additive.

Self-check list

• [ ] The product name reflects the substance, with the correct fish species/product category
• [ ] Frozen product net weight is the actual net weight after de-glazing
• [ ] Additives are within the permitted list and levels and disclosed
• [ ] No prohibited substances such as borax added
• [ ] Net quantity, manufacturer/importer, country of origin, date and storage are complete
• [ ] Imported goods have MAQIS inspection documents and the exporting country's health certificate ready

In summary

Seafood compliance has three high-risk points: glaze net weight, fish-species authenticity, and prohibited substances. Getting the label right is only the basics — glaze must not be pumped into the net weight, the fish species must be genuine, and borax must never be touched; imports add one more layer of MAQIS border inspection. Take care of these three points and both shelving and clearance go much more smoothly.

Further reading: Malaysia food labelling overview, Net quantity labelling rules, MAQIS border inspection in depth.

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This article is compiled from official sources for reference only; actual compliance is governed by the latest official text and review by the competent authority.