Carbon Monoxide Tuna: Indonesia Export Legality 2025 Guide

A practical, step-by-step playbook Indonesian exporters can use to secure an EU-ready CO “not detected” certificate for tuna in 2025. Covers legality, acceptable test methods, sampling size, certificate wording, and how to avoid RASFF alerts.

We went from border holds to a 100% pass rate in under 90 days by standardizing our EU CO-free tuna certificate workflow. If you sell tuna into Europe in 2025, you can do the same. Here’s the system we actually use in our Indonesian plants and with our buyers.

The three pillars of passing EU checks for CO-treated tuna

1. Know the rule and the risk. Carbon monoxide–treated tuna is not authorized in the EU. Authorities consider CO treatment misleading because it fixes the cherry-red color even when the fish ages. In practice, that means your lot can be detained, tested, and rejected if officials suspect CO treatment. RASFF alerts for CO-treated tuna surged again through 2024, and border checks remain tight in 2025.

2. Test the right way. EU border control labs rely on headspace gas chromatography for carbon monoxide in fish muscle. Some also use a carboxymyoglobin spectrophotometric ratio. Natural background CO in tuna is typically at or below the method’s limit of detection. Treated product shows much higher values. We recommend aiming for “CO not detected” on a lab certificate with an LOD of ≤0.2 mg/kg, or a carboxymyoglobin saturation result within natural background, often ≤5%.

3. Send documents that travel with the lot. A clean lab result is only half the story. If the certificate doesn’t identify the lot, method, LOD/LOQ, and the sampling plan, officials can still question it. Tie every page back to your invoice, packing list, and CHED-P entry so there’s no ambiguity.

Week 1–2: Map risks and design your sampling plan

Here’s the thing. Most rejections happen before the fish leaves your plant. It starts with sampling.

• Define the lot. One species, one production date range, one process line, one frozen format. Mixing multiple formats without separate composites is a common mistake.

• Set sampling sizes. For loins, saku, and steaks we use 5–10 sub-samples per lot depending on lot size. Under 5 tons, collect at least 5 sub-samples. Over 5 tons or high-risk SKUs for sashimi, go to 10.

• Composite correctly. Take 20–40 g from each selected piece. Include both surface and core muscle. Pool to a 200–300 g composite. Prepare one primary and one retained duplicate.

• Choose the method. Prioritize headspace GC for carbon monoxide in fish muscle. Accept carboxymyoglobin spectrophotometry if your buyer agrees and the lab is accredited for the method.

• Pick your lab. Use ISO/IEC 17025–accredited labs with CO in fish on their scope. In Indonesia, international networks and state-owned labs operate HS-GC for CO. We verify scope and LOD in writing with providers such as SGS, Intertek, and SUCOFINDO. Always confirm that “CO in fish muscle by HS-GC” appears on the accreditation scope and note the reported LOD.

Practical takeaway. Build a one-page sampling SOP with photos and labels. If your composite is traceable and the method is clear, you’ve already removed 70% of the risk.

Week 3–6: Test, document, and rehearse border questions

Run two or three pilot lots end-to-end.

• Lab turnaround and cost. In our experience, HS-GC CO testing in Indonesia runs 2–5 working days. Expedited analysis can be faster. Costs range roughly IDR 1.5–4 million per sample depending on lab and SLA.
• Certificate fields that EU officers expect to see.
  • Exporter, processor address, and EU-approved establishment number if applicable.
  • Species and scientific name. Product form (loin, saku, steak), HS code, lot/production codes, net weight.
  • Sampling plan. Number of sub-samples, composite weight, date, and who sampled.
  • Method and LOD/LOQ. “Headspace gas chromatography for carbon monoxide in fish muscle. LOD ≤0.2 mg/kg.” Or “Carboxymyoglobin spectrophotometric ratio. LOQ as validated.”
  • Result. “Not detected” with the LOD shown. Or a numeric value with units mg/kg or % CO-myoglobin.
  • Conformity statement. “No evidence of carbon monoxide treatment. CO not detected at LOD 0.2 mg/kg.”
  • Lab accreditation details. ISO/IEC 17025 number, signature, and date.
• Non-CO declaration from the processor. Put this on your letterhead and tie it to the lot. Example wording: “We declare the product in Lot XXX was not treated with carbon monoxide or tasteless smoke. Modified atmosphere packaging, where used, contained only CO2/N2/O2 and no CO.”
• Document flow. Attach the lab certificate and your non-CO declaration to the commercial invoice and packing list. Reference the lot code and match it with the CHED-P submission.

If you want a clean template for a CO “not detected” certificate and a non-CO treatment declaration, we’re happy to share the versions we use with EU buyers. Need a copy tailored to your plant? You can Contact us on whatsapp.

Week 7–12: Scale and keep your pass rate at 100%

• Supplier onboarding. Require your raw tuna suppliers to sign a non-CO treatment pledge. Audit MAP gases and ice sources. Unknown “smoke” powders and color-stable ice packs are red flags.
• Train QC on color expectations. Extremely bright, uniform cherry red across old pack dates invites questions. Teach teams to spot unnatural color persistence.
• Retain evidence. Keep duplicate composites frozen for 30 days. Archive photos of labeled sampling, lab chain-of-custody, and MAP gas specs.
• Pre-advise buyers. Send the lab report before loading. Experienced importers pre-notify border vets, which can prevent holds.
• Continuous monitoring. If any test returns a quantifiable CO value, pause and investigate. Run duplicate analysis. Check packaging gases, brines, and smoke flavorings.

We apply this workflow to our EU-bound tuna lines like Yellowfin Saku (Sushi Grade), Yellowfin Steak, and Bigeye Loin. The process is the same regardless of cut. Only the sampling points change.

Five mistakes that trigger RASFF alerts on CO-treated tuna

1. Relying on color alone. If it looks “fresh,” it must be fine, right. Not in Europe. Authorities test. You need a lab result that says “CO not detected.”

2. Vague certificates. A page that says “Pass” without LOD, method, lot, and sampling plan will not help if a BCP lab finds CO.

3. Mixing formats in one composite. Loins and saku packed on different lines should be tested separately. Component cross-over can create false positives.

4. Tasteless smoke confusion. Using smoke flavorings that incidentally generate carboxymyoglobin can still be flagged as CO-treated tuna in Europe. If color is stabilized, it is non-compliant.

5. Not aligning documents. The lot code on your certificate must match the invoice, packing list, and CHED-P. We’ve seen clean products detained because paperwork didn’t match.

Quick answers to what importers ask

Is carbon monoxide–treated tuna illegal in the EU in 2025?

Yes. CO treatment to stabilize color in fish is not authorized. EU officials treat it as misleading. Expect detentions if suspected.

What CO level counts as treated versus natural background?

There is no single EU-wide numeric cutoff. In practice, untreated tuna sits at or below the analytical LOD. Treated tuna shows markedly higher levels. We target “not detected” with LOD ≤0.2 mg/kg by HS-GC, or a carboxymyoglobin ratio consistent with natural background, often ≤5%.

Which lab test does the EU accept to detect CO treatment?

Headspace gas chromatography for carbon monoxide in fish muscle is the most common. Some official labs use a carboxymyoglobin spectrophotometric ratio. Use ISO/IEC 17025–accredited labs and ensure the chosen method and LOD are stated.

How many samples per lot should I submit?

For lots under 5 tons, at least 5 sub-samples composited to 200–300 g. For larger or high-risk sashimi formats, 10 sub-samples. Retain a frozen duplicate.

What should a CO “not detected” certificate include?

Lot identity, product and species, sampling plan, HS-GC method plus LOD/LOQ, numeric result with units, a clear “CO not detected” statement, and ISO 17025 accreditation details with signature.

Do I need to print “no CO” on the label?

No. There is no requirement to label “CO-free.” Keep the lab certificate and non-CO declaration with your shipping docs. Some buyers ask for the declaration on company letterhead.

How do EU border controls test for CO in tuna?

They inspect color and labeling, then sample muscle and analyze CO by HS-GC or check carboxymyoglobin. If they detect CO above background, they can detain or reject and issue a RASFF alert.

Resources and next steps

If you’re setting up your EU CO-free tuna certificate process from scratch, start with a simple toolkit. One sampling SOP with photos. One lab method confirmation with LOD. One clean certificate template. Run two pilot lots and adjust. We can share the exact templates and certificate wording we use for Indonesia-to-EU shipments. If you want a quick review of your plan, Contact us on whatsapp. If you’re benchmarking specs across SKUs, you can also View our products to see how we standardize cuts and documentation.

Final takeaway. The EU isn’t trying to make life hard. They just don’t want color-masked fish. When your sampling, method, and paperwork line up, you’ll move through BCPs cleanly and avoid the RASFF board altogether.