Indonesian Seafood EU Labeling: 2025 Compliance Guide

A practical, field-tested guide to declaring sulphites on EU shrimp labels in 2025. Exact wording, thresholds, allergen emphasis, and an SO2 testing plan you can adopt today.

If you process shrimp with sodium metabisulphite for black-spot control, the EU label can feel like a minefield. The rules aren’t new, but enforcement has sharpened. We’ve seen more importer audits and border checks flagging either missing allergen emphasis or confusing additive wording. Here’s a focused, no-fluff playbook for 2025 that we use on our own lines in Indonesia.

We’ll only cover sulphites and allergen emphasis on retail packs. Not FAO area, gear type, nutrition panels, sustainability marks or catch docs.

What the EU expects in 2025 (shrimp + sulphites in one page)

Maximum residue: 150 mg/kg SO2 in crustaceans. That’s your legal ceiling.
Allergen threshold: 10 mg/kg SO2. At or above this, “sulphur dioxide and sulphites” is an allergen and must be emphasised in the ingredients list.
Additive declaration format: functional class + specific name or E-number. Example: “Antioxidant: sodium metabisulphite (E223).”
If sulphites are present in the finished product, you need an ingredients list. A single-ingredient product becomes “multi-ingredient” the moment an additive remains.
If no ingredients list appears on pack, a “Contains sulphites” statement is required. But in reality, shrimp with residual sulphites should have an ingredients list, so the “Contains” line becomes optional and mostly redundant.

Why this matters now. RASFF alerts in late 2024 highlighted lots of crustaceans with either high SO2 or unclear labels. Importers are asking for COAs and label proofs before PFI. In our experience, a clean SO2 testing plan plus crisp wording is the fastest way to breeze through approval.

Action-first checklist: get the label and lab work right

Confirm if you must declare sulphites

Did you use metabisulphite and do any sulphites remain in the finished product? If yes, it’s an additive and needs declaring.
Is the residual SO2 <10 mg/kg and does it serve no technological function in the final product? Then it’s not an allergen and may be considered carry-over. But only skip emphasis if a lab result supports it and you can justify “no function” in QA docs. When in doubt, declare.

Build the ingredient line correctly

Use the functional class first. For sulphites in shrimp, that’s “Antioxidant”.
Follow with either the name or the E-number or both. We often use both to satisfy different buyer preferences.
Good: “Ingredients: Shrimp (Crustaceans) 98%, Antioxidant: sodium metabisulphite (E223).”
Also good: “Ingredients: Shrimp (Crustaceans) 98%, Antioxidant: E223 (sodium metabisulphite).”

Emphasise allergens in the ingredients list

Emphasise “Crustaceans” and “sulphites”. We bold them on-pack. Example: “Shrimp (CRUSTACEANS)” and “sodium metabisulphite (contains SULPHITES).”
Practical tip we’ve found works with reviewers: either bold the whole additive or at least the word “sulphites” within the additive. Just make sure it’s obviously emphasised.

Decide if you also add a “Contains sulphites” statement

If you already emphasise sulphites in the ingredients list, a separate “Contains sulphites” line is optional. It can help clarity on multi-language packs, but it isn’t required.

Choose spelling and languages wisely

EU English uses “sulphites”, not “sulfites”. Keep it consistent on pan-EU labels. Match the local language(s) for your target market when you produce country-specific packs.

Takeaway: Build your label around the 10 mg/kg allergen threshold and 150 mg/kg legal maximum. Declare as an antioxidant, emphasise allergens, and keep lab evidence on file.

The questions we get every week (and straight answers)

Do I have to declare sulphites if shrimp were dipped then rinsed before packing?

Usually yes. If any sulphites remain in the finished shrimp, they’re an additive. If you can prove by lab that residual SO2 is below 10 mg/kg and the additive no longer has a technological function, you may treat it as carry-over and skip both declaration and emphasis. We rarely rely on that because buyers and auditors expect transparency. Our rule of thumb: test, document, and declare if you’re not clearly below 10 mg/kg with a sound processing-aid justification.

What exact wording should I use for E223?

Use the functional class plus the specific name or E-number. We recommend both:

“Antioxidant: sodium metabisulphite (E223).” If you use potassium metabisulphite, swap the name and E-number accordingly:
“Antioxidant: potassium metabisulphite (E224).”

At what level do sulphites become an allergen that must be emphasised?

At or above 10 mg/kg (or 10 mg/L), expressed as SO2 in the finished product. Below 10 mg/kg, allergen emphasis is not required. But the additive may still need declaring if present and functional.

If my product is only shrimp plus sulphites, do I still need a full ingredients list?

Yes. The moment an additive remains, you have more than one ingredient. Use an ingredients list and emphasise allergens inside it.

Should I add a separate “Contains sulphites” statement or is bolding in the ingredients enough?

Bolding in the ingredients is enough and is the primary requirement. A separate “Contains sulphites” line is optional and mainly useful when space and multilingual design allow. We add it on some private labels when buyers want extra clarity.

Acceptable wording: “sulphites” vs “sulfites” on EU labels?

Use “sulphites”. That’s the EU spelling. Some importers are relaxed, but consistency helps during label checks.

Two ingredient line examples you can copy

Residual <10 mg/kg SO2, declaration by choice, no allergen emphasis required

“Ingredients: Shrimp (CRUSTACEANS) 100%.” Only use this if you have lab proof <10 mg/kg and a carry-over rationale. Otherwise declare the additive.

Residual ≥10 mg/kg SO2 (typical treated pack)

“Ingredients: Shrimp (CRUSTACEANS) 98%, Antioxidant: sodium metabisulphite (E223) [contains SULPHITES].”

We also keep a variant without the bracketed note, by bolding the entire additive: “Antioxidant: SODIUM METABISULPHITE (E223)”. Both approaches have passed importer reviews.

Residual SO2 testing plan that actually passes label review

I’ve found that most problems happen before the label is printed. A solid SO2 plan makes everything else easy.

Method. Use a recognised method suitable for crustaceans. Monier–Williams distillation with titration is a staple for total SO2. HPLC or ion chromatography methods offer better specificity when you’re close to 10 mg/kg. Set your LOQ at ≤5 mg/kg if you want confidence below the allergen threshold.
Sampling. For each production lot, composite at least 10 primary units taken across the batch (start, mid, end of pack-out, different basket layers). Test the composite plus two individual units. If any result is >130 mg/kg, test 5 more single units to confirm uniformity and legal compliance.
Internal specs. Legal max is 150 mg/kg. We set our release spec at ≤120 mg/kg to stay clear of drift and variability. For allergen emphasis, treat anything ≥10 mg/kg as “emphasise”. For labels claiming “no sulphites”, we require <5 mg/kg with confirmatory method.
Frequency. Every lot at the start of a program. Once your process is stable for 10 consecutive lots, you can risk-based downshift to 1 in 5 lots plus any lot with process deviation. Keep trending data.
COAs and retention. Keep COAs, method details, and raw chromatograms or titration sheets for 24 months minimum. Importers increasingly ask for proof before shipment.

Common mistakes we see (and how to avoid them)

Relying on dip concentration rather than finished product testing. The only value that counts for labels is residual SO2 on the final product.
Forgetting that glaze water dilutes, but can also hide hotspots. Sample deglazed product consistently before testing.
Using test strips. They’re fine for in-process checks. They’re not acceptable as your release COA.
Not re-checking near end of shelf life. SO2 usually declines, but we validate at MHD minus 1 month to confirm label claims still hold.

Need help tailoring a sampling plan to your line speed and pack sizes? If you want a quick review of your current COAs and label wording, you can Contact us on whatsapp.

Applying this to Indonesian frozen shrimp

We process and export both farmed and sea-caught shrimp from Indonesia with IQF and block options. For buyers needing pre-compliant packs, we deliver treated or non-treated programs and match ingredient lines to your market. If you need a starting point for specs, our standard for treated shrimp uses a 70–120 mg/kg SO2 target and the wording you saw above. You can view our shrimp range here: Frozen Shrimp (Black Tiger, Vannamei & Wild Caught).

If you also carry a mixed seafood range and want consistent additive wording across SKUs, our team can align labels for species like grouper or snapper that don’t use sulphites but share the same retail style. That keeps your brand uniform and avoids the “one pack looks different” audit flag. You can View our products for context on formats and pack types.

Quick recap you can hand to your label designer

Declare sulphites as an antioxidant and list name and/or E-number. Example: “Antioxidant: sodium metabisulphite (E223).”
Emphasise CRUSTACEANS and SULPHITES in the ingredients list when SO2 is ≥10 mg/kg.
Keep finished product SO2 well below the 150 mg/kg legal maximum. We like ≤120 mg/kg as an internal cap.
Back your decision with lab results using a recognised method. File the COA with your label artwork.

The reality is, EU label reviews go fast when your wording matches the regulation’s structure and your data is tidy. Do that, and the rest of the conversation becomes product quality and price. Which is where we all want to spend our time.