The Codex Standard for Sturgeon Caviar

Three to five grams of salt per 100 g of finished caviar. The female parent first in a hybrid’s name. Codex reaches from the salted roe to the fine detail of its description, but what does it settle? It is an international food reference with a distinct role in trade disputes, not worldwide permission to manufacture, label or trade caviar. Those permissions depend on the applicable legislation.

What the Codex standard can and cannot do

Codex conformity, legal compliance and a buyer’s specification are three different questions. A business needs an answer to each.

The Codex Alimentarius Commission, the joint FAO and WHO body responsible for international food standards, produces voluntary texts. Membership does not automatically make every provision domestic law. Codex provisions become enforceable through applicable legislation. Check whether the product conforms to Codex, meets the destination’s legislation and satisfies any contractual specification.

Under the WTO Agreement on Sanitary and Phytosanitary Measures, Codex is the expressly recognised international reference for food safety. The Agreement on Technical Barriers to Trade covers other technical requirements, including many composition and labelling measures, and promotes relevant international standards. These agreements concern government measures; they do not turn CXS 291-2010 into directly enforceable instructions for every processor.

The safety of the contents and the marketing description on the container may therefore require different legal analysis. Start with caviar regulation, then identify the legislation governing the proposed transaction.

Start with the right edition

The document number alone will not tell you whether a standard is current. The official PDF records adoption in 2010 and amendments in 2013, 2018 and 2024. The 2024 notice updates references for non-retail labelling, CXS 346-2021, and analysis and sampling, CXS 234-1999. The Codex register records a further modification in 2026.

Check what that modification changed before relying on an older PDF: the register’s date alone does not identify the affected clauses. Keep the downloaded standard, its amendment statement and the download date in the compliance file, alongside the applicable national rules. An unchanged document number does not make an older PDF the current edition.

What the clauses actually cover

The standard covers granular salted roe of Acipenseridae. Sections 1 and 2 exclude paddlefish and other fish families; pressed caviar is not mentioned in the scope. Mixing caviar from different species or lots is prohibited.

Ovulated eggs from farmed sturgeons are allowed under specified conditions. These include removal of the adhesive layer, shell hardening and competent authority approval of hormones where used. Section 5 addresses residues and withdrawal periods.

The finished-product salt range is 3 to 5 g per 100 g. Sections 6 and 7 reference general hygiene and prepacked-food labelling texts, while section 7.4 requires lot and species marking on non-retail containers. For hybrids, Annex A puts the female parent first.

Codex Annex A writes the female parent first; CITES and US wildlife labels put the male parent code first.

Sections 8 to 10 cover sampling, trained sensory examination, analysis, defects and acceptance. Read them together with the applicable sampling plan and analytical methods: these determine how the product is examined and assessed.

Ingredients, additives and the cold chain

Codex specifies 2 to 4°C for packaging, storage and retail, and 0 to −4°C for wholesale storage and transport. It also states that freezing is not permitted unless deterioration of quality is avoided.

Read ingredient permissions, additive provisions and handling requirements in the current standard and its referenced texts. In a professional specification, keep the distinctions clear: permission to use an ingredient is not permission to use an additive, and a storage requirement is not a serving suggestion.

A salt percentage or a satisfactory sensory examination cannot replace a validated safety system. Salt in caviar and freezing caviar explore the practical questions; use the regulatory texts themselves for the precise requirements.

Where EU and US rules meet Codex

An EU additive permission does not settle the US position. The table shows where to check naming and additive rules, not equivalence or incorporation of the whole Codex standard. Food compliance remains separate from wildlife-trade compliance.

The EU example is precise. Annex II to Regulation 1333/2008 permits boric acid, E284, and sodium tetraborate, E285, in sturgeon eggs only, subject to a limit of 4,000 mg/kg expressed as boric acid. Read the category entry and its footnotes together. An additive’s appearance in a general list does not authorise it in every food.

In the US, CPG 540.150 is FDA enforcement guidance, not a binding standard of identity. It says unqualified caviar should mean salted sturgeon roe. Other roe should name the fish, with the words substantially equal in size and prominence.

The guidance also calls for an ingredient declaration and, where permitted colour is used, a prominent declaration of artificial colour. A claim of Codex conformity does not replace that policy.

Great Britain and Northern Ireland take different routes

Great Britain uses domestic and assimilated food law; Northern Ireland generally follows the relevant EU food rules. Government labelling guidance identifies the GB and EU versions of Regulation 1169/2011 separately.

For additives, the FSA’s GB register became the official public list on 1 April 2025, with preserved conditions of use linked to earlier legislation. Check the GB authorisation rather than automatically substituting an EU additive authorisation.

Northern Ireland also has specific arrangements for qualifying retail goods moved from Great Britain under the Northern Ireland Retail Movement Scheme. Identify the product and its route first. Treating all UK movements alike misses the distinctions that determine which rules apply.

Food naming and wildlife labels tell different stories

Paddlefish illustrates the difference. Codex’s family-level food scope excludes it, while the EU wildlife implementing regulation uses Acipenseriformes for its caviar category, encompassing both sturgeons and paddlefish. That broader conservation category does not bring paddlefish roe within the food standard.

Hybrid parentage needs equal care. Record the male and female parents explicitly, rather than relying on an ambiguous trade name. Codex Annex A writes the female parent first; CITES and US wildlife labels put the male parent code first.

For a male Amur sturgeon, Acipenser schrenckii, crossed with a female kaluga, Huso dauricus, the CITES code is SCHxDAU. A CITES label provides traceability, not proof of the contents.

Other destinations have their own requirements

China’s customs guidance cites Food Safety Law Article 92: imported food must meet Chinese national food safety standards. Article 93 provides a review route where no corresponding national standard exists. An international standard can be relevant to an application, but does not itself authorise marketing.

Japan requires notification of commercial food imports under Article 27 of the Food Sanitation Act, with examination of legal compliance. Australia requires imported food for sale to meet the Australia New Zealand Food Standards Code, alongside biosecurity requirements. Neither authority’s guidance treats a Codex claim as sufficient evidence of admissibility.

For Russia, the relevant fish-products instrument is EAEU Technical Regulation 040/2016. A Russian government notice documents its implementation. Before export, check the current consolidated amendments and the provisions specific to caviar.

Build the export specification around a separate destination review. Translating the Codex sheet is not enough to establish that the product meets the importing country’s requirements.

Build a compliance record that works

Keep the formulation, process description, species identity, supplier documentation and intended destination together. Identify the source of each requirement: food law, wildlife law, a customer specification or an international reference.

For acceptance testing, settle the sampling plan, analytical method, decision rule and responsible person before interpreting a result. A contract that merely says the caviar must meet Codex leaves room for disagreement over both the edition and the evidence required. Retain a laboratory’s method and measurement basis with its result, rather than copying a pass or fail statement alone.

Finally, identify the proposed activity: domestic manufacture, domestic sale, import or re-export. Each raises its own legal questions. The complete legal guide maps those separate checks within the wider compliance system for caviar. Codex is a technical benchmark, not regulatory approval.