TR CU 040 Certification Requirements for Pickled and Smoked Fish and Seafood CUTR Certification
Certification Overview
TR CU 040/2016 is the technical regulation of the Eurasian Economic Union on the safety of fish and fish products. Pickled and smoked fish and seafood fall under the category of fish and fish products. CUTR certification, also known as EAC certification, signifies that the product meets the safety standards of the Customs Union member states (Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan) and is legally permitted for circulation and sale in these countries.

Application Entity Requirements  
The applicant must be a business entity or entrepreneur within the Customs Union (Russia, Belarus, Kazakhstan, Armenia, and Kyrgyzstan). The name of a foreign manufacturer may only be listed as product information on the certification certificate.

Certification Process and Required Documents  
Submit Application  
The applicant within the Customs Union submits a CUTR certification application for pickled and smoked fish and seafood to the certification body, specifying product-related information.

Prepare Documents
Company Documents
The applicant (a company within the Customs Union) must provide business qualification documents such as a business licence and tax registration certificate to prove the company's legal business status.
The company's contact information and address must be provided for communication and verification by the certification body.
Detailed information about the foreign manufacturer, including name, address, contact information, and production qualification documents such as a food production licence, must be provided to prove the manufacturer's ability to produce qualified products.
Product Documents  
Product formula: A detailed list of the types and quantities of raw materials, auxiliary materials, and additives used in the pickling and smoking of fish and seafood. Additives must comply with the relevant standards of the Customs Union.
Production Process Description: Describe the steps and conditions of the entire production process, from raw material procurement, pre-treatment, pickling, smoking to packaging, such as pickling time, temperature, brine concentration used, smoking method, temperature, and time, to ensure the production process complies with safety standards.
Product label sample: The label should be in Russian and include the product name, ingredients, production date, shelf life, storage conditions, manufacturer information, country of origin, etc., with font size and content that are clear and legible.
Product instructions: Include information on how to consume the product, recommended consumption amounts, precautions, etc.
Product testing report: Provide a recent testing report issued by a qualified laboratory. Testing items typically include microbial indicators (such as total bacterial count, E. coli, Salmonella, etc.), chemical contaminant indicators (such as heavy metal content, pesticide residues, veterinary drug residues, etc.), and additive usage. Testing results must comply with the requirements of TR CU 040/2016.

Product Testing
Certification bodies will test samples of pickled and smoked fish and seafood to verify compliance with regulatory requirements. Testing items typically include:
Microbial indicators: Ensure that microbial content in the product is within safe limits to prevent food safety issues caused by excessive microbial levels, such as spoilage or food poisoning.
Chemical contaminants: Testing for the content of chemical substances such as heavy metals (e.g., lead, mercury, cadmium, arsenic), pesticide residues, and veterinary drug residues. These contaminants may originate from the aquaculture environment, feed, or processing procedures, and excessive levels can pose risks to human health.
Additive usage: Verifying that the additives used are within regulatory limits and that usage quantities comply with regulations, such as preservatives, antioxidants, colourants, etc.

Factory audit (may be required)
Certification bodies may conduct on-site audits of factories producing pickled or smoked fish and seafood to assess whether the production environment, hygiene conditions, production equipment, and quality control systems comply with regulatory requirements. Audit contents include:

Production environment: The factory's location and layout should be reasonable, with clean and hygienic workshops, good ventilation, drainage, and rodent and insect prevention facilities.  
Production equipment: Equipment should be regularly maintained and cleaned, in good operational condition, and capable of meeting production process requirements.  
Quality control system: The company should establish a comprehensive quality control system, including raw material acceptance, production process monitoring, and finished product inspection, to ensure product quality is stable and reliable.
Certificate Issuance
If pickled or smoked fish and seafood products pass the testing and audit (if applicable), the certification body will issue a CUTR (EAC) certification certificate. The certificate will specify product name, model, manufacturer, and certification validity period.

Certification Validity Period and Supervision
Validity Period: Certification certificates typically have a specific validity period, generally ranging from 1 to 5 years, with the exact duration determined based on product characteristics and the regulations of the certification body (Certification Body Contact: Shanghai Jinghe Industrial Equipment Testing Co., Ltd.).
Supervision: During the certification validity period, the certification body may conduct regular or irregular supervisory inspections to ensure that the company continues to comply with regulatory requirements. The company must cooperate with the certification body's inspection work. If non-compliance is identified, the company may face rectification requirements, and in severe cases, the certification certificate may be suspended or revoked. Certification body contact: Shanghai Jinghe Industrial Equipment Testing Co., Ltd.