The year on a caviar tin can mark a change of container, not the harvest. A recent repacking date tells you when the roe entered its latest tin. It does not make the caviar newly harvested.
An original tin is the container in which caviar was first packed; repacked caviar has been transferred into another container. Quality depends on more than that distinction. Ask who handled the roe, when it was harvested and packed, and how the seller traces your tin to its original batch.
What repacking means for your purchase
A large trade tin becomes several smaller retail tins: this is a common reason for repacking. The process means taking caviar out of its original container and placing it in a new one. It is a legal trade practice when the operation meets the applicable registration, labelling and food hygiene requirements.
That transfer adds handling and potential exposure to air. Operators must control both to protect the eggs and limit oxidation. Ask about the full interval since harvest, rather than just the time the caviar has spent in its current tin.
The distinction lies in the container's history, not its size or the name on its lid.
Original tin or repacked: read the code
The label tells a different part of the story after repacking. An original processing label records the harvest year and processing plant. A repacked label records the repackaging year and repackaging plant instead, keeping the country of origin separate from the repacker's location.
The country named prominently on a tin may be where the caviar was repacked or where the brand operates, rather than where the roe originated.
CITES, the international wildlife trade convention, sets out its caviar labelling guidelines in Resolution Conf. 12.7 (Rev. CoP17), Annex 1. A primary container is the tin or jar touching the caviar, not an outer gift box.
Teaching example, not a real label. Every value below is a deliberately invalid placeholder. Neither line identifies a species, country, year or registered operation.
| Field | Original tin | Repacked tin |
|---|---|---|
| Code | XXX/?/ZZ/0000/0000/000 |
XXX/?/ZZ/0000/YY-0000/000 |
| Species | XXX | XXX |
| Source | ? | ? |
| Origin country | ZZ | ZZ |
| Year | Harvest: 0000 | Repackaging: 0000 |
| Plant | Processing: 0000 | Repackaging: YY-0000 |
| Final field | Lot: 000 | Lot: 000 |
On a real repacked label, the plant code incorporates the repacking country's two-letter ISO code when that country differs from the origin country. The final field can be a lot identifier or a CITES document reference, depending on the jurisdiction's rules. See the CITES caviar code for the remaining fields.
Repacking within the country of origin may leave no second country code. One country code therefore cannot settle whether a tin is original: ask the seller to identify the plant.

Six questions to ask the seller
Ask about the batch you will actually receive. A readable photograph of its label is a useful starting point. The seller can supply these answers separately; they need not all appear on the retail tin.
- Who farmed the fish and who processed the roe? Request both names, not just the brand or distributor.
- When was it harvested and first packed? Ask for dates where available, rather than only the harvest year encoded on the label.
- Has it been repacked, and when? The repacking year alone gives neither the day nor the month of transfer.
- Are the original CITES details available? Ask the seller to connect the retail batch to the original processing label and supporting records.
- What is the repackaging plant code? Request the registered operator's legal name and location so you can check the code independently.
- How was it stored between those dates? Ask about temperature control during storage, repacking and delivery. Follow the product's storage instructions.
Contradictory dates need an explanation. An unidentified repacker needs a name. If the seller cannot resolve either, pause the purchase. The wider guide to how to buy caviar places these checks alongside the other questions worth asking.
Check the plant, not just the brand
Match the plant code to an operator's name and address. Use the CITES register's country pages, such as its United States register, and check the country attached to the repackaging plant, rather than automatically looking under the country of origin.
The register lists operations, not every retail brand. A shop name may therefore be absent without anything being wrong. If you cannot match a code, ask the seller and the relevant national CITES authority to resolve it. See checking a producer on the register.
Which labelling rules apply?
Domestic legislation determines how the international CITES labelling system applies in law. This matters particularly when comparing domestic US sales with international shipments.
| Jurisdiction | Buyer-relevant rule | Legal source | Checked |
|---|---|---|---|
| EU | Each primary container needs a non-reusable label; plants packing for export, re-export or intra-EU trade must be licensed. | Regulation (EC) No 865/2006, Article 66(6) and (7) | November 2026 |
| Great Britain | Check the assimilated regulation and APHA plant registration requirements. | Assimilated Regulation (EC) No 865/2006, Article 66 | November 2026 |
| Northern Ireland | EU wildlife trade provisions apply. | Regulation (EC) No 865/2006, Article 66 | November 2026 |
| United States | This provision governs CITES container labelling for imports, exports and re-exports. | 50 CFR 23.71(b) | November 2026 |
| Switzerland | Containers need non-reusable traceability labels; commercial producers and repackers must register with BLV. | CITES Control Ordinance, Article 5 | November 2026 |

Do not read origin from the front
The country named prominently on a tin may be where the caviar was repacked or where the brand operates, rather than where the roe originated. Read the qualifying words and the complete label. The guide to country of origin versus country of repacking explains the distinction.
- EU: Regulation (EU) No 1169/2011 prohibits misleading origin information and requires origin disclosure where its absence would mislead.
- UK: Great Britain applies its assimilated food information rules; Northern Ireland generally follows EU rules. Both require origin claims to avoid misleading the buyer.
- US: Imported food is subject to customs origin marking requirements. Repacking alone does not justify replacing foreign origin with a US claim.
A CITES label gives you a route through the records; it cannot establish a particular tin's contents, quality or safety. Apply the same buying standard to original and repacked tins: a clear history, an identifiable operator and answers that agree with the records.
Sources
- CITES, Conservation of and trade in sturgeons and paddlefish, Resolution Conf. 12.7 (Rev. CoP17), 2016, particularly paragraph 2 and Annex 1. Resolution text retrieved from the US federal regulatory docket: resolution PDF. The post-CoP20 resolutions index was located through live search, but its complete entry could not be opened.
- CITES Secretariat, United States of America: Register of caviar exporters, live register, retrieved November 2026: country register.
- European Commission, Commission Regulation (EC) No 865/2006, consolidated edition dated 18 February 2025, Article 66: EUR-Lex consolidated PDF. The indexed consolidation was retrieved; full-text access requires an editorial recheck. Czech public administration portal, Licences for caviar processors and packers, undated live guidance, independently confirms the Article 66(7) licensing requirement: official guidance.
- US Fish and Wildlife Service, How can I trade internationally in sturgeon caviar?, 50 CFR 23.71, live eCFR text retrieved November 2026: regulation.
- US Fish and Wildlife Service, Notice to Wildlife Import/Export Community: CITES labeling requirements for sturgeon caviar, bulletin dated 13 March 2008: official bulletin.
- Codex Alimentarius Commission, FAO and WHO, Code of Practice for Fish and Fishery Products, CXC 52-2003, 2020 publication, sections 20.17 to 20.23; retrieved institutional copy: code PDF.
- Swiss Federal Department of Home Affairs, Verordnung über die Kontrolle des Verkehrs mit Tieren und Pflanzen geschützter Arten, SR 453.1, Article 5, including the amendment effective 1 March 2022; official legislative text reproduced in the LexFind archive: ordinance PDF.
- UK Government, Packaging and labelling, undated live guidance, retrieved November 2026, sections on the Food Information to Consumers Regulation and country of origin: official guidance.
- US Food and Drug Administration, CPG Sec. 560.200: Country of Origin Labeling, live guidance retrieved November 2026; revision date not stated in the retrieved document: FDA guidance.
- Defra, The commercial use of caviar, 2007 leaflet, retrieved from a WWF-hosted copy; historical support only, not confirmation of current UK law: leaflet PDF.
This piece was researched against CITES documents.
Last checked: November 2026

