I asked my shaykh, 
 Shaykh ‘Abd al-‘Azeez ibn Baaz (may Allaah have mercy on him) about 
 this, and he answered:
 No, this (i.e., fish) is not merchandise. It is like the case if he were to go fishing every day and eat what he caught. But if he puts it in the freezer and then sells it, in this case, if a whole year passes, then he has to pay zakaah. And Allaah knows best.

On What is Zakah Due

Islam Q&A - Sheikh Muhammed Salih Al-Munajjid

Zakaat on fresh fish

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