Scope
Resolucion No. 368 applies to fish, fish subproducts, and other products derived from fishing and aquaculture in Panama. The resolution authorizes the Departamento de Proteccion de Alimentos of the Ministerio de Salud to inspect and sample shrimp farms, fish farms, processing plants, vessels, markets, collection centers, transport, and similar operations.
HMI records the Article Sixth metals table for cadmium, lead, and mercury in fishery products. Antibiotics, dyes, steroids, pesticides, additives, histamine, dioxins, PCBs, polycyclic aromatic hydrocarbons, organoleptic checks, and parasite controls are outside the regulatory metal-limit register for this ingest.
Exact limit and units
Article Sixth states the maximum contents in mg/kg or ppm. The structured evidence register converts each value to ug/kg by multiplying by 1000. The source table does not state a wet-weight or dry-weight qualifier.
| Species | Matrix | Limit | Unit | Structured value |
|---|---|---|---|---|
| Cd | Fish meat, excluding the listed cadmium species | 0.050 | mg/kg | 50 ug/kg |
| Cd | Anchovy, bonito, mojarra, eel, mullet, luvar, sardine, tuna, and wedge sole or lenguadillo | 0.10 | mg/kg | 100 ug/kg |
| Cd | Swordfish | 0.30 | mg/kg | 300 ug/kg |
| Cd | Crustaceans, excluding dark crab meat and lobster head/thorax meat | 0.50 | mg/kg | 500 ug/kg |
| Pb | Fish meat | 0.30 | mg/kg | 300 ug/kg |
| Pb | Crustaceans, excluding dark crab meat and lobster head/thorax meat | 0.50 | mg/kg | 500 ug/kg |
| Pb | Bivalve molluscs | 1.5 | mg/kg | 1500 ug/kg |
| Pb | Cephalopods without viscera | 1.0 | mg/kg | 1000 ug/kg |
| tHg | Fishery products and fish meat, excluding the listed mercury species; applies to crustaceans excluding dark crab meat and lobster head/thorax meat | 0.50 | mg/kg | 500 ug/kg |
| tHg | Shark, tuna, sierra, swordfish, marlin, and sailfish | 1.0 | mg/kg | 1000 ug/kg |
The source says mercury rather than methylmercury, so HMI records these mercury rows as tHg.
How tested
Article First authorizes inspection and sampling by the Departamento de Proteccion de Alimentos. Article Second establishes laboratory testing to control maximum permitted residues of chemical substances, including heavy metals, in fish, fish subproducts, and other fishery or aquaculture products. Article Seventh requires fishery farms and processing establishments to conduct laboratory tests for the substances cited in the resolution in ISO 17025-accredited laboratories and under the Ministerio de Salud’s national toxic-residue monitoring plan.
The metals table does not name a metal-specific analytical method. The histamine section names HPLC for histamine, but that method statement is not generalized to the metal rows.
Enforcement posture
The resolution is mandatory for natural and legal persons engaged in production, processing, and transport of fishery products. Article Fifth authorizes sanitary and legal actions when results show prohibited substances, chemical substances, or other findings that may pose consumer-health risk. Article Eighth assigns the Departamento de Proteccion de Alimentos responsibility for strict compliance.
History of changes
Resolucion No. 368 was dated 15 May 2009 and promulgated in Gaceta Oficial Digital No. 26307 on 19 June 2009. Article Ninth repeals Resolucion No. 092 of 10 February 2005. Article Tenth states that the resolution takes effect from promulgation in the official gazette.
How it compares
This is a fishery-specific contaminant schedule, broadly comparable to seafood contaminant limits in Costa Rica, Guyana, Mexico, EU, and Codex frameworks. Comparisons should preserve the product grouping and the source’s unspeciated mercury basis.
The Panama cadmium table includes a crustacean row in addition to fish rows. The lead and mercury sections use separate product groupings and should not be inferred from the cadmium grouping.
Sources
Update history
The five most recent substantive edits to this page, classified major (evidence or structure moved), correction (a published value or statement was wrong and has been fixed), or minor (narrative rewritten without changing the underlying evidence). Each description is derived from what the edit did to this page; the linked commit is the authoritative record, routine regeneration passes are excluded, and the full version history lives in git. When DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.
| Commit | Date | Change | Description |
|---|---|---|---|
| a8052bb | 2026-08-09 | major | 1 source added; contamination-profile values revised; 7 sections added |