冷凍水產品包冰之適法性與安全性暨消費者認知之探討

「包冰」是在冷凍水產品表面再附著上一層冰衣，用以減少產品表面接觸的空氣及冰晶昇華，達到減少品質劣變的效果。常有不肖業者以包冰不當增加產品重量之案例，但目前官方對於產品過度包冰的現象，並無明確罰則。本研究探討冷凍水產品包冰之適法性與安全性，以及就消費者角度，如何看待產品包冰之相關議題。研究鎖定四大議題-各國對於產品包冰的相關規範及標示規定，是否存在法規限定之最高包冰量，包冰對於水產品是否有增加危害風險，以及最後消費者對於包冰產品的接受度及觀感。研究以文獻回顧的方式蒐集期刊論文、各國食品法規、國家度量衡及檢驗標準，以及新聞案例等相關報導文獻，並運用文獻分析法，進行比較性的分析研究，另將資料以表格進行統整對照。首先將包冰相關的法規、案例、標準進行統整分析，以提供業者提升製程與品質能力、降低管銷費用，以及滿足相應出口國法規要求之參考；再來回顧包冰操作是否增加水產品潛在安全危害；最後則是一般大眾對包冰產品的消費經驗以及觀感認知體驗。研究結果如下：現行未有合理包冰率之規範，然如超過30 %以上，則易衍生難以辨識原產品與欺騙消費者之嫌疑；歐美都有明確且強制性之核實標示包冰含量或不含包冰淨重之規範，違反時得以詐欺罪起訴，但中國大陸及我國對包冰率，僅訂定行業標準或是以市場淘汰機制為主。對市售產品及消費者的相關調查結果顯示，約80 %的消費者回應其購買經驗上包冰量介於12-19 %，然而也有近10 %的費者有購買到介於30-35 %之冷凍水產品；另外幾乎所有消費者皆認為曾有購買到包冰過度的產品，對政府監管單位以「包冰無涉食品安全」之態度覺得不滿。對市面上流通水產品的調查，也發現高達10-14 %的產品淨重與標示不符。結論是由於監管單位缺乏恰當的監管手段與力度，致使冷凍水產品仍存在包冰過度以及淨重不實等現象。研究結果可供我國政府及相關權責單位對稽查市面上產品之依據，以及對生產、製造、進口業者之規範參考及引用。

關鍵字

包冰；淨重

並列摘要

"Ice glazing" refers to the process of forming a layer of ice on the surface of frozen aquatic products to reduce the contact between the product surface and air, as well as the sublimation of ice crystals, in order to minimize quality deterioration. There have been cases where unscrupulous operators improperly increase the weight of products through excessive ice glazing. However, currently, there are no clear penalties from official authorities for excessive ice glazing of products. This study explores the legality and safety of ice glazing on frozen aquatic products, as well as how consumers perceive the related issues of product ice glazing. The research focuses on four main issues: the relevant regulations and labeling requirements for product ice glazing in different countries, whether there are maximum ice glazing limits defined by regulations, whether ice glazing increases the risk of hazard to aquatic products, and finally, the acceptance and perception of ice-glazed products by consumers. The study collects journal papers, food regulations from various countries, national metrology and inspection standards, and relevant news articles through a literature review approach. The data is then analyzed using literature analysis methods, and the information is integrated and compared through tables for comparative analysis. Firstly, the study conducts a comprehensive analysis of the regulations, cases, and standards related to ice glazing to provide references for industry operators to improve processes and quality capabilities, reduce management and distribution costs, and meet the regulatory requirements of export countries. Secondly, it reviews whether ice glazing operations increase potential safety hazards for aquatic products. Finally, it examines the consumption experience and perception of frost-glazed products by the general public. The research findings are as follows: Currently, there are no regulations on reasonable ice glazing rates. However, if the ice glazing exceeds 30% or more, it can raise suspicions of difficulty in identifying the original product and deceiving consumers. In Europe and America, there are clear and mandatory regulations for verifying the ice glazing content or net weight without ice glazing, and violations can lead to charges of fraud. However, in mainland China and our country, the ice glazing rate is only specified by industry standards or relies on market elimination mechanisms. The results of surveys on products available in the market and consumers indicate that approximately 80% of consumers reported ice glazing levels ranging from 12-19% in their purchasing experience. However, nearly 10% of consumers have purchased frozen aquatic products with ice glazing levels between 30-35%. Additionally, almost all consumers believe that they have purchased products with excessive ice glazing and are dissatisfied with the government regulatory authorities' attitude of considering ice glazing unrelated to food safety. An investigation of aquatic products circulating in the market also found that up to 10-14% of products had net weights that did not match the labeling. In conclusion, due to the lack of appropriate regulatory measures and enforcement by regulatory authorities, excessive ice glazing and inaccurate net weights still exist in frozen aquatic products. The research findings can serve as a basis for the government and relevant authorities to inspect products in the market, as well as provide reference and citation for regulations concerning production, manufacturing, and import companies.