Which regulatory requirements must a cannery meet before it can export?
Morocco's first: a sanitary approval before any production. Then the importing country's, which differ sharply between the European Union, the United Kingdom and the United States.
In Morocco: the sanitary approval
Decree No. 2-10-473 lists every establishment that produces, processes, packs or preserves fishery products among the activities that need a sanitary approval (agrément). Approval requires self-monitoring that complies with Moroccan standard NM 08.0.002 (HACCP) or an equivalent system. For maritime fishery products, the decree gives the licensing role to the authority in charge of maritime fisheries, with ONSSA giving its opinion during the site visit. Have the provincial ONSSA office confirm the licensing route before filing; listing for export, for its part, goes through Morocco’s competent authority, which proposes establishments to importing countries. The file and deadlines are covered in our roadmap from ONSSA approval to GFSI certification.
The same decree contains a rule written for canners: the water used to cool hermetically sealed containers after heat treatment must not become a source of contamination.
Into the European Union: the list of authorised non-EU establishments
The EU only imports fishery products from establishments on its list of authorised non-EU establishments, fishery products section. The European Commission explains that the exporting country's competent authority proposes the establishments, the Commission examines the proposals, and the lists are kept in the TRACES system. Listed plants must apply hygiene rules equivalent to Regulation (EC) No 853/2004, and products must meet the criteria of Regulation (EC) No 2073/2005, including the histamine criteria. Each consignment travels with an official health certificate.
For an EU importer, this is the first check before any commercial discussion: a cannery that is not on the list cannot ship, whatever certificates it holds.
Into the United Kingdom
Since leaving the EU, the UK applies its own import conditions. It keeps its own list of non-EU establishments approved to export animal products to Great Britain. The UK and the EU do not share data on these establishments: being on the EU list is not enough. The exporting country’s competent authority asks the Department for Environment, Food and Rural Affairs (Defra) to add or update an establishment, using an official form.
Into the United States: seafood HACCP and low-acid canned foods
The FDA applies two cumulative regimes to a fish cannery:
- Seafood HACCP (21 CFR Part 123). It applies to foreign and US processors alike, and the importer must verify that its supplier complies. The FDA states that the FSVP rule does not apply to seafood imported from a supplier that is subject to, and in compliance with, seafood HACCP; the importer then follows the importer requirements of 21 CFR 123.12.
- Low-acid canned foods (21 CFR 108 and 113). According to the FDA, every foreign processor exporting low-acid canned foods to the US must register its plant (FCE number) and file each scheduled thermal process (SID). This is separate from, and in addition to, the general food facility registration. At entry, the FDA checks the FCE and SID; shipments from non-compliant plants can be detained.
Into Africa and the Middle East
Requirements vary by importing country: health certificates, product registration, Halal certification.
Which GFSI standard for which export market?
The one your buyer requires. Regulation opens the border; a GFSI certificate opens the listing with a retailer or manufacturer.
The GFSI recognises 12 certification programme owners. Four come up in canning: BRCGS Food Safety (Issue 9 in force, Issue 10 in preparation with no announced date), IFS Food (Version 8, mandatory since January 2024), FSSC 22000 (Version 7, published May 2026) and, for North America, SQF (Edition 9 audited; Edition 10 published March 2026, audits expected from January 2027).
Market | Main regulatory requirements | Standard often requested | Watch points |
|---|---|---|---|
European Union | Plant on the EU list (fishery products); Regulations 853/2004 and 2073/2005; official certificate per consignment | IFS Food v8 (Germany, France, Italy) or BRCGS | Histamine criteria, allergen labelling |
United Kingdom | Establishment on the UK list, separate from the EU list | BRCGS Food Safety Issue 9 | Possible unannounced audits; grade visible to customers |
United States and Canada | Seafood HACCP (21 CFR 123); FCE and SID for canned products (21 CFR 108 and 113) | SQF, BRCGS or FSSC 22000 depending on the buyer | Filed processes, sterilisation records |
Multinational manufacturers | Depends on destination | FSSC 22000 v7 | Prerequisites per ISO 22002-100:2025 |
Africa, Gulf | Per importing country | Buyer-specific; Halal frequent | Halal certificates recognised by the importing country |
Supplying both a UK and a German retailer often leads to dual BRCGS and IFS certification. The two share a HACCP core and very similar prerequisite programmes: one well-built system serves both. Our comparison of BRCGS, IFS and FSSC 22000 by export market covers grading and audit frequency.
Which hazards must a cannery control first?
Four hazards structure a cannery's HACCP plan and the auditor's visit: histamine, sterilisation, double seams and foreign bodies. Allergens follow closely.
Hazard | Where it arises | Typical control | Evidence expected at audit |
|---|---|---|---|
Histamine | Cold-chain breaks between catch and processing (sardine, mackerel, tuna) | Chilling at landing and receipt, temperature limits, lot testing | Temperature records, test results, rejected lots |
Survival or growth of Clostridium botulinum | Inadequate or badly applied thermal process | Process validated by a thermal processing specialist, qualified retorts, every cycle recorded | Heat penetration studies, retort records, deviation reviews |
Post-process contamination | Defective seams, contaminated cooling water | Visual and teardown seam checks at a defined frequency, cooling water treatment and monitoring | Seam inspection sheets, chlorination results, actions on deviations |
Foreign bodies | Raw materials, equipment, packaging | Inspection, detection, maintenance, glass and metal control | Detector verification, incident logs |
Allergens | The fish itself, sauces and toppings | Allergen matrix, scheduling, validated cleaning, label control | Matrix, cleaning validation, label checks |
Seam check frequencies and sterilisation parameters do not transfer from one plant to another: they come from the validated process for each line, can size and retort. An auditor will ask for the validation first, then for the records proving the validated process is applied cycle after cycle.
Allergens deserve particular care for exports. Fish is itself one of the allergens that must be declared in the EU under Regulation (EU) No 1169/2011, and sauces, flavoured oils and toppings can add others, such as mustard, celery or soy, depending on the recipe. Label errors are a frequent cause of recalls: a foreign-language label prepared for one customer must be checked against the recipe actually produced.
Two mistakes come up often. The first: treating histamine as a laboratory topic when control actually happens upstream, at landing and in storage, with qualified fish suppliers. The second: a "historical" thermal process with no validation study and no review after a change of can format or retort. The full hazard analysis for a sardine line is in our HACCP plan guide with a worked cannery example.
Which additional certifications do buyers ask for?
They depend on the customer, never on the regulation: add them when a contract requires them. In canning, the most frequent ones cover sustainability, religious requirements and social compliance.
- Fishery sustainability (MSC, Friend of the Sea). Some European retailers require them for certain ranges or brands. They cover the fishery and the chain of custody of supply, not plant hygiene.
- Halal. Required for Muslim-majority markets. In Morocco, IMANOR issues a Halal label.
- Kosher. Requested by some North American and European importers; it is issued by religious bodies, not under a public standard.
- Social audit (for example SMETA). Requested by retailers that assess working conditions at their suppliers. It does not replace a food safety certificate.
These schemes sit on top of an existing system. A cannery whose traceability already meets BRCGS or IFS has most of what a sustainability chain-of-custody audit will check.
How can an international buyer verify a Moroccan cannery before listing it?
Check the documents that the authorities and scheme owners publish, then see the plant. Most of the regulatory evidence can be verified before the first visit.
For an importer or a retailer's quality team, five checks come first:
- Sanitary approval. Ask for the approval number and check that it appears on packaging and commercial documents, as the Moroccan decree requires.
- Export eligibility. For the EU, check that the plant appears in the fishery products section of the list of authorised non-EU establishments. For the US, ask for the FCE number and the SIDs of the processes that cover the formats you will buy.
- GFSI certificate. Check the certificate, its scope (products, processes, site) and its expiry date in the scheme owner's public directory, not on a PDF sent by email. A certificate that does not cover the canning lines you buy from does not protect you.
- Thermal process evidence. Ask who validated the sterilisation processes and when they were last reviewed, and request a sample of retort records and seam inspection sheets for a recent production week.
- Histamine control. Ask how fish is chilled from landing to processing, which lots were rejected in the last season and how histamine results are trended.
Documents tell you what the plant says it does; a site visit tells you whether it does it. A second-party audit by an auditor who knows both the GFSI standards and Moroccan regulation is the usual way to close that gap, especially before a first contract or after a change of supplier site. Some buyers also use this visit to check social compliance and production capacity.
What roadmap should an export-focused cannery follow?
Start from the target market and work backwards: establishment lists and country rules, the buyer's GFSI standard, then extras. This sequence avoids certifying to a standard no customer asks for.
- Map markets and buyers. Countries, retailers, required standards and certifications, tender calendar.
- Check the regulatory base. Sanitary approval, export listing and, for the US, FCE registration and filed processes.
- Run a gap analysis against the chosen GFSI standard, starting with the fundamental requirements: management commitment, HACCP plan, traceability, corrective action.
- Secure the four major hazards: histamine, sterilisation, seams and foreign bodies, with evidence over a real production season.
- Train the HACCP team, retort operators, seam inspectors and supervisors.
- Hold a mock audit a few weeks before the certification audit; see our article on the GFSI mock audit.
- Add the extra certifications your contracts require (Halal, MSC, social audit).
The sardine season weighs on this calendar: evidence must cover real production weeks. Canneries in Agadir, Safi, Laâyoune or Dakhla should run the diagnosis before the peak of the season. Buyers, for their part, often audit before listing: our guide to supplier audits in Morocco and Africa explains what they check.
Checklist before answering a new export buyer: