From the Rav’s Desk: Does fresh or frozen fish need a Hashgacha for Pesach?

1. Question: [Tuesday, 6^th Nissan, 5783]

I have in my freezer a sizable amount of unopened packages of unprocessed frozen fish which I purchased during the year. It however does not state that it is kosher for pesach. May I still use them for Pesach?

 

Answer:

Fresh unprocessed fish: Unprocessed fresh fish is intrinsically kosher for Pesach and there is nothing that needs to be done to it to make it certified kosher for Pesach. Thus, it may be used for Pesach even if it does not contain a kosher for Pesach symbol. 

Frozen fish: Frozen fish should have a Kosher for Pesach certification even if it is not processed, as often those who market them place starch and other products on the fish in order to preserve it. For definite verification, I would suggest calling the Hashgacha, or Rav Hamachshir about your specific product.

Processed fish: All processed fish must contain a Kosher for Pesach certification.

Explanation: Several factors need to be considered in the question of whether fish require a kosher for Pesach certification. These are: 1) Did the fish go through any processing in which additives and preservatives were entered into them? 2) Was the knife used to cut them clean of Chametz residue? 3) Is there any issue if the fish were fed Chametz fodder during its growth?

The final conclusion of all these questions is as follows: Unprocessed fresh fish are intrinsically kosher for Pesach and there is nothing that needs to be done to it to make it certified kosher for Pesach. Thus, it may be used for Pesach even if it does not contain a kosher for Pesach symbol.  The reason that none of the above issues make non-processed fresh fish require a kosher for Pesach certification is because: 1) The knives that are used to cut them are not usually used for any Chametz foods, and even it they were a simple rinse suffices. 2) Even if the fish was fed Chametz fodder during its growth, this is not considered an issue at all. According to Halacha, this issue only begins to apply regarding fish that were fed Chametz on Pesach itself and not to those fed Chametz before Pesach. Even during Pesach itself, majority of Poskim rule leniently. [Nonetheless, some Mehadrin Hashgachas are careful several days or weeks before Pesach to only feed the fish non-Chametz fodder in order so there is no Chametz inside the organs and it may then get cooked on Pesach. However, is a mere chumra, and even the Eida Hachareidis under Rav Bransdofer were not careful in this until recently.]

However, processed fish, must be kosher for Pesach as various spices and additives are used in the processing, and these spices may contain Chametz.

Likewise, frozen fish requires a kosher for Pesach certification. The reason for this is because some frozen fish from China contains starch, depending on the specific manufacturer and product, either as an ingredient or as a coating to help preserve the quality of the fish during freezing and transportation. Now, China is one of the largest producers and exporters of seafood in the world, and many types of fish and seafood are imported from China to the USA, Israel, and other countries. Thus, this is a real concern everywhere.

Sources: See regarding the need for a Kosher for Pesach certification on fish: Madrich of Eida Hachareidis; https://oukosher.org/passover/guidelines/food-items/fish/; Star K Pesach list “All frozen raw fish products should have reliable certifying agency Passover approval. If Passover-approved frozen fish is not available, or the frozen fish was already purchased without Passover approval, then it should be washed, ideally before Pesach. This should not be done over a Pesach sink. Fresh KOSHER fish with skin may be bought anywhere and rinsed.” See regarding Kashrus of salt: Admur 462:19; See regarding salted fish and herring: Otzer Minhagei Chabad Nissan p. 61; See Admur 447:36 and gloss of Maharil See regarding if animal ate Chametz: Admur 450:18 in parentheses based on Michaber Y.D. 60:1; 142:11 and Shach 142: 1; P”M 448 A”A 10 regarding animal of gentile; Shaareiy Teshuvah 448:7 in name of his uncle; Beis Ephraim 35; Kitzur SHU”A 117:13; Yeshuos Yaakov 448:9; Nishmas Adam 19; Toras Chesed 21; Teshuvah M’Ahava Y.D. 3:60; Arugas Habosem 138; Maharshag 2:85; Ashel Avraham Butchach 448; M”B 448:33; Igros Moshe 1:258;Nitei Gavriel 57 footnote 24; Piskeiy Teshuvos 448:33