Traceability of fish lots: fines of up to 32 000 euros from 31.10.2026

From 31.10.2026 the Fishery Market Organisation Act provides that a lot of fishery and aquaculture products must be traceable in accordance with Article 58 of Council Regulation (EC) No 1224/2009 (KTKS § 10¹ lg 1) [1]. Breaching the requirements is fined up to 300 fine units, a legal person up to 32 000 euros (KTKS § 76¹) [2].

What changes

• Traceability and the exception: a lot must be traceable under Article 58 of Regulation (EC) No 1224/2009; the requirements of that Article do not apply in the case set out in its paragraph 8 (KTKS § 10¹) [1]. According to the explanatory memorandum, the lot traceability requirement is directly applicable and the section implements the exception the Regulation allows: supply chain traceability requirements do not apply to sales to consumers when the quantity of fish or aquatic plants is under 10 kilograms, or up to 2 salmon [3].
• New misdemeanour: breaching the traceability requirements for lots of fishery or aquaculture products, where the misdemeanour under § 88¹ or § 88² of the Fishing Act does not apply, is fined up to 300 fine units, a legal person up to 32 000 euros (KTKS § 76¹) [2]. The extra-judicial body conducting proceedings is the Agriculture and Food Board or the Environmental Board within its competence (KTKS § 77) [4].
• Marketing standards: the misdemeanour of breaching marketing standards for fishery products or consumer information requirements now also applies only „kui puudub kalapüügiseaduse §-s 88¹ või 88² sätestatud väärteokoosseis“ (translation: “where the misdemeanour under § 88¹ or § 88² of the Fishing Act does not apply”) (KTKS § 76 lg 1) [5]; until now there was no such condition [6].
• Serious infringements: according to the explanatory memorandum, a serious infringement is punished on the basis of §§ 88¹ and 88² of the Fishing Act; the fine levels are analogous to those of the Fishing Act [7].

Who is affected

According to the explanatory memorandum, any operator holding fishery or aquaculture products: it must label the lot and keep electronic traceability records, be able to identify every operator it bought fish from, and pass the traceability data electronically to the operator it sells the lot on to [7].

What to do

• Check that lots are labelled, traceability records are kept electronically and the data is passed on to the buyer [7].
• According to the explanatory memorandum, lot traceability information must be made available to the Environmental Board on request [7].
• When selling small quantities directly to consumers, check whether the exception in Article 58(8) of Regulation (EC) No 1224/2009 applies (KTKS § 10¹ lg 2) [1] [3].