Fish hygiene from vessel to counter is set internationally by Codex CXC 52-2003, which asks for fresh fish to be chilled fast and held as close as possible to 0 °C. At retail it sets 4 °C or below for chilled fish, while the Dubai Municipality Food Code 2013 sets 5 °C or below for chilled high-risk food.
This guide is for fish market operators, fishmongers, supermarket seafood managers and the inspectors who check them.
What does Codex CXC 52-2003 cover, and which version is current?
CXC 52-2003 was adopted by the Codex Alimentarius Commission in 2003. It was revised several times up to 2018 and amended in 2019, and FAO and WHO published the updated text in 2020. That 2020 publication added a full section on preventing histamine formation, which Codex announced as new guidance from its food hygiene committee.
The Code follows fish from harvest to sale. The sections most relevant to a fish market chain are:
- Section 3, the prerequisite programme, including the design of fishing vessels, facilities, equipment and the hygiene control programme.
- Section 4, general handling of fresh fish, with time and temperature control at its centre.
- Section 10, fish at risk of scombrotoxin (histamine) formation.
- Section 21, transportation, and Section 22, retail.
You can read the full text in the 2020 FAO and WHO publication of the Code. Codex texts are voluntary international references. They become binding only when a national or local authority adopts them, so your local food code is what an inspector enforces.
What has to happen on the vessel before the fish reaches shore?
The Code treats the fishing vessel as part of the hygiene chain. Surfaces in handling areas should be smooth, impervious and in sound condition, so slime, blood, scales and guts do not build up. Vessels should have an adequate supply of cold potable water or clean water for washing fish and equipment.
Section 4 calls temperature the single most important factor in fish spoilage and bacterial growth. Chilling should start as soon as possible, and fish should be kept as close as possible to 0 °C with enough ice or chilled or refrigerated water. The Code also asks for fish to be stored in shallow layers and handled without trampling or puncturing.
The transport section carries the same rule ashore. Chilled fish should travel as close as possible to 0 °C, and frozen fish at −18 °C or below. Brine-frozen fish intended for canning is the one exception, at −9 °C or colder.
For a fish market, this means the temperature history of the catch matters before it arrives. Ask suppliers how the fish was iced on board and in transit, and record what you are told.
What does a retail fish market have to control?
Section 22 of the Code expects retailers to buy from known or approved sources and to use written purchase specifications. It also expects a tracking system for the origin and codes of products, so a recall can reach the right stock.
At receiving, check the vehicle's hygiene and reject products with filth, taint or signs of decomposition. Take product temperatures from several places in each shipment and record them. If the vehicle keeps a cargo-hold temperature log, examine it.
In storage, the Code sets 4 °C or below for chilled fish and 3 °C or below for fish in modified atmosphere packaging. It recommends a continuous temperature-recording chart for seafood coolers, with products stored off the floor.
The display counter is where most visible faults appear. The Code asks for:
- chilled display at 4 °C or below, with product temperatures taken at regular intervals
- self-draining displays, with ice replaced daily
- ready-to-eat items kept off ice that has held raw fish, and separated from raw products
- a separate container and serving utensils for each product
- no stock piled so deep that it cannot stay chilled, and none above the load line of self-service cases
- signs giving each fish its commonly accepted name
Which temperature limits apply in Dubai compared with Codex?
A market in Dubai is inspected against the Dubai Municipality Food Code 2013, whose definition of a food establishment includes meat and fish shops. The table sets its figures beside the Codex retail and transport figures. Always cite the limit with the authority that set it.
| Control point | Codex CXC 52-2003 | Dubai Municipality Food Code 2013 |
|---|---|---|
| Chilled fish in transport | As close as possible to 0 °C (Section 3.6) | At or below 5 °C for high-risk and perishable food (§3.6.2) |
| Chilled storage and display at retail | 4 °C or below (Section 22) | At or below 5 °C (§3.6.2) |
| Modified atmosphere packs | 3 °C or below (Section 22) | No separate figure |
| Frozen fish | −18 °C or below (Sections 3.6 and 22) | −18 °C (§3.6.2) |
| Live fish in tanks | Maintain oxygen, carbon dioxide, temperature and waste levels (Section 4) | Tank water filtered and disinfected, changed regularly (§8.4) |
The Dubai code adds two rules that matter at a fish counter. Frozen fish may be thawed in refrigeration at an air temperature of 10 °C or less, or under cold running water, provided the product stays at or below 5 °C (§3.2.7). Where fish is sold or served raw, such as for sushi, the business must have controls that eliminate parasites (§3.2.9).
If you trade in Abu Dhabi, ADAFSA's Code of Practice No. 29 of 2019 on retail food hygiene applies. We have not verified its figures, so check them with ADAFSA rather than assuming they match Dubai.
How do you control histamine in tuna, mackerel and other scombroid fish?
Histamine forms when bacteria break down fish that has been kept too warm. Cooking does not remove it. Section 10 of the Code says time and temperature control is the recommended method for preventing it in fresh, frozen and refrigerated fish.
At the counter, Section 22 asks retailers to buy scombroid species from suppliers that use HACCP or a similar system to prevent histamine. On delivery, check that the fish is surrounded by ice or another cooling medium, measure internal temperatures where appropriate, and carry out a sensory check of representative fish before you accept it. Record the result each time, because a histamine complaint will be traced back to that delivery.
The same discipline applies to ice itself. Ice touches every fish in the market, so its water source and handling need the same control as the fish. Our guide to ice as a food explains what ice producers are checked against.
What records should a fish market keep?
Inspectors judge a market by its records as much as its counter. A practical set, based on the Code's retail section and the Dubai code, is:
- an approved supplier list and written purchase specifications
- a receiving log with product temperatures, sensory checks and rejections
- cooler and display temperature records, or the continuous chart
- a daily ice replacement and display cleaning record
- a cleaning and disinfection schedule with sign-off
- lot and origin records that allow a recall
The record list is AGS's practical interpretation, not wording from either code. For businesses that run a full HACCP system, the HACCP management systems collection covers sector systems.
How AGS can help
AGS has two single documents for fish handling, each one editable Microsoft Word file:
- Hygiene & Sanitation Guidelines - Hygiene in the Retail Fish Market: one document of hygiene rules for retail fish markets.
- International Technical Guidelines Pack - Fish & Seafood Handling: one document, Fish Handling (International Edition).
Other single-document guidelines are in the technical and hygiene guidelines collection.
Frequently asked questions
Is Codex CXC 52-2003 mandatory?
Not on its own. Codex texts are international references, and they apply as law only where an authority has adopted them. In Dubai the enforceable rules are in the Dubai Municipality Food Code 2013.
Does the Dubai Food Code apply to fish shops?
Yes. Its definition of a food establishment names meat and fish shops, alongside supermarkets, groceries and restaurants.
Why do Codex and Dubai give different chilled temperatures?
They are written for different purposes. Codex gives fish-specific guidance, while the Dubai code sets one limit for all high-risk chilled food. Meet the Dubai limit as the legal minimum, and aim for the colder Codex figures to protect quality.
Does a fish counter need a HACCP plan?
The Code's retail section expects controls to be built on HACCP principles and refers to its Section 5 for preparing a plan. Whether a written plan is required for your business is set by your local authority.
AGS provides independent documentation toolkits. This guide and the referenced documents are prepared to support Codex and Dubai Municipality food hygiene requirements. They are not affiliated with, endorsed by or approved by the Codex Alimentarius Commission, FAO, WHO, Dubai Municipality, ADAFSA or any certification body, and they do not guarantee any inspection or audit outcome.
Reviewed October 2026. Facts checked against the sources current at publication.
