Summary of provisions relating to caviar of sturgeons and paddlefish (Acipenseriformes spp.), according to Regulation (EC) No 865/2006 (as amended)
In April 1998, the decisions to list all species of sturgeon and paddlefish (Acipenseriformes spp.) in the CITES Appendices entered into effect, covering all live specimens, as well as any parts and products derived from these species (such as caviar, meat, leather, fertilised eggs, cartilage, etc.). These specimens may only be traded in accordance with the provisions of CITES and the EU Wildlife Trade Regulations.
Imports and exports from shared stocks
Member States are obliged to reject applications for import and export permits for caviar and meat of sturgeon and paddlefish species (Acipenseriformes spp.) from shared stocks1 unless export quotas have been established for the species in question in accordance with the procedure laid down by the Conference of the Parties. Details of current quotas may be found on the Secretariat’s website (http://www.cites.org/eng/resources/quotas/index.php).
Time validity of import and export permits
In the case of caviar of sturgeon and paddlefish species (Acipenseriformes spp.) that originated form shared stocks that are subject to export quotas:
Import permits cease to be valid on the last day of the year to which the quota applies (i.e. the year, starting on 1 March and ending on the last day of February, in which the caviar was harvested and processed) – if this is earlier than the normal maximum 12-month period of validity applicable to import permits, and
Export permits cease to be valid on the last day of the year to which the quota applies (i.e. the year in which the caviar was harvested and processed) – if this is earlier than the normal maximum six-month period of validity applicable to export permits.
Labelling requirements
In April 2000, CITES Parties agreed on a universal labelling system for the identification of caviar that came into effect in the EU on 1 January 2002. The labelling system was revised in November 2002 (CITES CoP 12), October 2004 (CITES CoP 13), June 2007 (CITES CoP 14) and in March 2013 (CITES CoP 16) in order to improve the traceability of the product (see Resolution Conf. 12.7 (Rev. CoP17) – Conservation of and trade in sturgeons and paddlefish, which may be viewed at https://cites.org/sites/default/files/document/E-Res-12-07-R17.pdf). In the EU, the labelling requirements for the identification of caviar are detailed in Article 66(6) of Regulation (EC) No 865/2006 as amended by Article 18 of Regulation (EC) No 100/2008. All primary containers (tin, box, jar, or other container into which caviar is directly packed), irrespective of size and including containers of repackaged caviar, must be affixed with a non-reusable label that includes a unique code. The label must either seal the container or the caviar must be packaged in such a way that it becomes evident if the container has been opened. The uniform labelling system applies to all caviar produced for commercial and non-commercial purposes, from the wild or farmed, and includes re-packaged caviar and all caviar sold on domestic markets.
It is noted that the mixing of caviar from different Acipenseriformes species into a primary container is not permitted, except in the case of pressed caviar (i.e. caviar composed of unfertilised eggs (roe) of one or more sturgeon or paddlefish species, remaining after the processing and preparation of higher quality caviar)2.
For the purposes of facilitating the marking requirements for caviar, the Management Authority must license facilities (or plants) that process, package or repackage caviar (including caviar producing aquaculture operations) and must attribute a unique registration number to these facilities3. The facilities must also maintain adequate records of the quantities of caviar imported, exported, re-exported, produced in-situ or stored that must be available for inspection by the Management Authority in the relevant Member State. The list of facilities licensed in this way must be notified to the CITES Secretariat and to the European Commission and is available at http://cites.org/eng/taxonomy/term/152.
Caviar packaged in countries of origin
All containers of caviar produced by the countries of origin, must have a non-reusable label. It must seal the container unless there is some other means of packaging whereby tampering/opening becomes evident. This condition applies regardless of the size of the container or its intended destination, whether domestic on international. The non-reusable label affixed by the processing or packaging plant in the country of origin (first country of export) must include the information as shown in the example below using the codes agreed in Annexes 1 and 2 of the CITES Resolution Conf. 12.7 (Rev. CoP17) (see https://cites.org/sites/default/files/document/E-Res-12-07-R17.pdf). Import and export permits and re-export certificates may only be issued when the Management Authority is satisfied that the caviar container is marked in accordance with these conditions4.
Description of label to be affixed in the country of origin on all primary caviar containers
HUS: Standard species code, here “Huso huso”
W: Source code of the caviar, here “wild”
RU: ISO code of the country of origin, here “Russian Federation”
2000: Year of harvest, here 2000
xxxx: Number for the processing plant
yyyy: Lot identification number
Example: HUS/W/RU/2000/xxxx/yyyy
Re-packaged caviar
All containers in which caviar is repackaged must also be affixed with a new non-reusable label that seals the container (if the packaging is not already done in such a way as to reveal tampering) regardless of its size and destination, whether it is destined for re-export or the domestic market. As required for the label affixed in the country of origin, the new label should allow authorities to trace the origin of the caviar. It must therefore contain the information shown below using the codes agreed in Annexes 1 and 2 of CITES Resolution Conf. 12.7 (Rev. CoP17) (see https://cites.org/sites/default/files/document/E-Res-12-07-R17.pdf).
Description of label to be affixed in the country of re-packing on all secondary containers
PER: Standard species code, here “Acipenser persicus”
W: Source code of the caviar, here “wild”
IR: ISO code of the country of origin, here “Islamic Republic of Iran”
2001: Year of repackaging, here 2001
IT-wwww: The official registration code of the repackaging plant, which incorporates the two-letter ISO code of the country of repackaging if different from the country of origin
zzzz: Lot identification number, or CITES export permit number, or re-export certificate number
Example: PER/W/IR/2001/IT-wwww/zzzz