Deceptive Dishes: Seafood Swaps Found Worldwide - Oceana USA

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Deceptive Dishes:Seafood Swaps Found Worldwide

Table of ContentsAuthorsDr. Kimberly Warner, PatrickMustain, Beth Lowell, Sarah Gerenand Spencer Talmage1Executive Summary3Introduction4Global Review of Seafood FraudAcknowledgements6Highlights10The European Union:The authors would like to thank thefollowing individuals for their contributionsduring the development and review of thisreport as well as the map and analyses:Dr. Andrea Armani, Eric Bilsky, ChristopherCarolin, Alicia Cate, Dustin Cranor, CarlosDisla, Nicolas Fournier, Rachel GoldenKroner, Dr. Kathryn Matthews, Dr. DanaMiller, Jacqueline Savitz and Amelia Vorpahl.A Promising Case Study12Conclusion andRecommendations13Building the Global Map14Endnotes16Global Review and MapBibliographyOceana is grateful for the investmentof Oceans 5, the Paul M. Angell FamilyFoundation, the Robertson Foundation, theDavid and Lucile Packard Foundation andthe Pacific Life Foundation in our efforts toreduce seafood fraud and end illegal fishingthrough improved traceability.Steve De Neef

Highlights of thisreview include:Executive SummarySeafood fraud is a serious global problemthat undermines honest businesses andfishermen that play by the rules. It alsothreatens consumer health and puts ouroceans at risk. As global fishing becomesmore expansive and further industrialized,seafood fraud and its related impacts couldget even worse. This update of Oceana’s2014 review of seafood fraud studiesdemonstrates the global scope of theproblem, but also reveals some promisingtrends due to recent regulations in theEuropean Union (EU) that are increasingtransparency and traceability as wellas addressing illegal, unregulated andunreported (IUU) fishing. An interactivemap of global seafood fraud cases andstudies compiled by Oceana can be found fraud comes in different forms,including species substitution—often alow-value or less desirable seafood itemswapped for a more expensive or desirablechoice—improper labeling, including hidingthe true origin of seafood products, oradding extra breading, water or glazing toseafood products to increase their apparentweight. The focus of this review is seafoodmislabeling and species substitution.The majority of assessed fisheries aroundthe world are already being fished at orover their sustainable limits. And the riskSeafood fraud is aserious global problemthat undermineshonest businesses andfishermen that play bythe rules, threatensconsumer health, andputs our oceans at risk.Creditof overexploitation only increases whenconsidering the complexity and opacityof the global seafood supply chain, whichis rife with illegal fishing, human rightsabuses, inadequate management, and withthe exception of a few model countries,little to no traceability. However, theseproblems can and should be addressed.Oceana maintains that with propermanagement, the oceans’ wild fisheriescould provide a responsibly caught,nutritious seafood meal to 1 billion peopleevery day.1 But proper managementrequires transparency and accountability.In 2014, Oceana documented the globalreach of seafood fraud in its review ofthe literature, identifying reports offraud in 29 countries. At the time of itsrelease, Oceana’s report was the mostcomprehensive review of seafood fraudpublications ever, citing 103 sources,including investigations by journalists,peer-reviewed literature, and governmentand non-governmental organization(NGO) documents. A similar analysis of 51peer-reviewed studies published since 2005found a 30 percent average rate of fraudglobally, a rate consistent with Oceana’sown additional investigations into seafoodfraud in the United States, which foundmislabeling rates for fish, shrimp and crabbetween 30 and 38 percent.2This update to Oceana’s 2014 global fraudreport reviewed more than double thenumber of studies and cases as previousreviews, looking at seafood fraud globallyand examining more than 200 peer-reviewedjournal articles, popular media sources,and public documents from governmentsand NGOs.A presidential task force has released aproposed rule to address IUU fishingand seafood fraud, two problems that arelinked due to a global, complex and opaqueseafood supply chain and that share acommon solution: full-chain traceabilityfor all seafood. The proposed rule includestraceability requirements that would onlyapply to 13 “at-risk” types of seafood, and One in five of the more than25,000 samples of seafood testedworldwide was mislabeled, onaverage. The studies reviewedfound seafood mislabeling atevery sector of the seafoodsupply chain: retail, wholesale,distribution, import/export,packaging/processing and landing. Seafood fraud was investigated in55 countries and found on everycontinent except for Antarctica. Every study found seafood fraud,except for one. Asian catfish, hake and escolarwere the three types of fish mostcommonly substituted. Specifically,farmed Asian catfish was sold as 18different types of higher-value fish. More than half (58 percent) ofthe samples substituted for otherseafood posed a species-specifichealth risk to consumers, meaningthat consumers could be eating fishthat could make them sick. Eighty-two percent of the 200grouper, perch and swordfishsamples tested in Italy weremislabeled, and almost half of thesubstituted fish that were soldwere species that are consideredthreatened with extinction by theInternational Union for Conservationof Nature (IUCN). In Brazil, 55 percent of “shark”samples tested were actuallylargetooth sawfish, a speciesconsidered by the IUCN to becritically endangered and for whichtrade is prohibited in Brazil. Ninety-eight percent of the 69bluefin tuna dishes tested in Brusselsrestaurants were mislabeled.oceana.org1

Executive Summarythose requirements would be in effect onlyfrom the boat or farm to the U.S. border.While a valuable first step, the rule asproposed would be inadequate.Extension of traceability requirementsinside the U.S. border could help preventmislabeling and fraud that occurs withinthe U.S. supply chain, instances of whichhave been documented and compiled in arecent Oceana report. Of the 60 differentmisidentified types of seafood in that report,only 26 percent would be covered by therule. Seventy-seven percent of the legal casesreviewed (since 2001), in which seafoodwas found or suspected to be mislabeled,involved fraud that occurred within theU.S. In other words, the rule as proposedends traceability at the border and would donothing to prevent those particular cases ofseafood fraud within the United States.The EU offers a lesson on whether moretransparency, traceability and seafoodlabeling requirements can help reducefraud. At the turn of this century, the EUbegan developing legal provisions aimedat tracing seafood and providing moreconsistent information to consumers.Following these early legal provisions,academic and government-sponsoredseafood mislabeling investigationsrevealed weaknesses in the rules and theirimplementation and enforcement. Thesestudies, which gained attention in themedia, likely helped sway the public andpolicymakers to strengthen rules governingthe EU seafood market. In 2008, the EUestablished measures for combating illegalfishing that included, among others,catch documentation requirements forall imported seafood in the EU market.These measures went into effect in January2010. Additional provisions that wentinto effect in 2012 and 2014 require evenmore stringent traceability and labelingrequirements to ensure that fisheriesproducts can be traced back and checkedthroughout the supply chain.While many factors influence seafood fraudrates, studies of seafood fraud that weredone both before and after the stronger EUfisheries control, traceability and seafoodOCEANA Jenn Huetinglabeling rules were implemented haveindicated that, for the most part, whereregulations have been in effect and enforced,rates of fraud have decreased.This in-depth examination into globalseafood fraud shows that it is still a seriousproblem, hurting consumers’ health andwallets, and threatening marine wildlifeand ecosystems. However, traceability andaccountability, where in place and enforced,appear to reduce rates of fraud in the EU.If the United States adopts comprehensive,full-chain traceability, it will be moredifficult for bad actors to mislead consumersand exploit our oceans. It could also serve asa model elsewhere.The Presidential Task Force on CombatingIUU Fishing and Seafood Fraud is ata critical crossroads. As the proposedSeafood Import Monitoring Program ruleis being finalized and beyond, there are keyopportunities to ensure that all seafoodsold in the U.S. is safe, legally caught andhonestly labeled.2 OCEANA Deceptive Dishes: Seafood Swaps Found WorldwideThe President’s TaskForce should: Require key information to followseafood through the full supplychain, from the boat or farm tothe dinner plate. That informationshould include species-specificnames, where and how a productwas caught, or whether it wasfarmed. Expand traceability requirementsto all seafood in the final rule or,at a minimum, commit to a timelineto do so. Extend traceability requirementsthrough the entire seafood supplychain. Provide consumers with moreinformation about the seafoodthey purchase and eat.

IntroductionThe Food and Agriculture Organizationof the United Nations (FAO) reportedthis year that global seafood trade andconsumption are at all-time highs.3 TheFAO 2016 State of World Fisheriesand Aquaculture report described the“tremendous potential” of our oceans andinland waters to provide nutritious mealsfor a global population expected to reach9.7 billion by 2050. But with the majority ofassessed fisheries around the world alreadyeither fully fished or overexploited, wildcaught seafood may not be able to reachthat potential by 2050.Seafood fraud, specifically speciessubstitution or mislabeling, is an old andgrowing problem. It threatens consumerhealth and safety, cheats consumers whenthey pay higher prices for a mislabeledlower-value fish, and hides harmfulpractices like illegal fishing, poorly-regulatedaquaculture and human rights abuses.Following the release of Oceana’s seafoodfraud reports4 and growing public attentionto the issue, President Obama establishedthe Task Force on Combating IUU Fishingand Seafood Fraud,5 which released itsfinal recommendations in March 2015.6While IUU fishing and seafood fraud arerelated but different problems, they sharea similar solution: traceability. In 2016, theTask Force issued a proposed rule, creatingthe Seafood Import Monitoring Programthat will implement some of its traceabilityrecommendations.7 The rule wouldrequire information to follow the productfrom the boat or farm to the U.S. border,including how and where a fish is caughtor harvested, along with a species-specificname. These traceability requirements,however, would only apply to 13 types ofseafood deemed “at-risk” of illegal fishingand seafood fraud.The limited scope of the proposed ruleleaves the door open for continuedfraud and may even incentivize fraudand mislabeling of the species coveredby the rule. In order to avoid additionalscrutiny and documentation requirements,unscrupulous actors may decide to mislabelseafood products that are covered bythe rule as seafood products that are notcovered. Oceana, other NGOs, somefishermen and seafood industry members,chefs and concerned citizens have calledfor the traceability requirements in theproposed rule to extend to all seafoodspecies, and also for the additional productinformation (such as a species-specificname, and how and where the seafoodproduct was caught or farmed) to beavailable through the entire seafood supplychain—all the way to the end consumer.Aquaculture has been playing a growingrole in seafood fraud. Seafood consumersacross the world may be eating severalincreasingly popular farmed fish withouteven realizing it. Asian catfish, orpangasius, a variety of catfish farmedlargely in Southeast Asia, farmed Atlanticsalmon and farmed tilapia are makingtheir way onto dinner plates, but arefrequently disguised as wild-caught,higher-value fish. Not only do these swapscheat consumers, but many aquaculturefacilities damage surrounding ecosystems,and use chemicals and antibiotics that canharm consumer health.8The following pages contain an update toOceana’s 2014 global review of seafoodfraud, nearly doubling the number ofcountries where fraud was investigatedby including data from more than 100additional studies.9 To help capture thescope of seafood fraud, Oceana createdan interactive map that illustrates thewidespread and global nature of theproblem.With a supply chain that remains largelyopaque and unaccountable, the seafoodindustry will continue to be susceptible toIUU fishing and fraud. However, the EUcase study described in detail later in thisreport suggests that these problems canbe addressed through the enforcement ofcomprehensive requirements for increasedtransparency and traceability.OCEANA A. Ellisoceana.org3

Global Review of Seafood FraudTo identify the scope of seafood fraud,specifically mislabeling and speciessubstitution, Oceana reviewed morethan 200 published studies, includingEnglish language peer-reviewed journalarticles, popular media sources, and publicgovernment and NGO documents (seeBibliography and Appendix for moredetail). These data were analyzed to identifygeneral trends in seafood fraud, includingrelationships to the presence or lack ofregulation. Oceana also developed aninteractive map to illustrate the global scaleof seafood fraud.This updated review covers 55 countrieson every continent except Antarctica.The United States and Europe account forthree-quarters of the studies and cases inthis review, but seafood fraud has beeninvestigated in a growing number ofcountries, including Egypt, India and China.While documented seafood fraud stretchesback to 1915, the bulk of the studies havebeen conducted since 2005. One hundredand forty-one of those studies includedquantitative data, totaling 25,700 samples ofseafood analyzed for mislabeling.The total number of samples analyzed ineach study reviewed ranged from threeto 4,652, but most of the studies analyzedfewer than 100 samples. While the averageThese issues areespecially problematicwhen the ambiguityor mislabeling isintentional and lawsare deliberately broken.And indeed, laws arebeing broken on aglobal scale.mislabeling rate worldwide is 34 percent,the rate normalized to sample size is 19percent. This means that the average wasweighted by sample size, so studies witha greater number of samples were givena higher weight. Nearly one in every fivesamples tested worldwide, on average, wasfound to be mislabeled. In the U.S., studiesreleased since 2014 found an averageweighted fraud rate of 28 percent.Fraud was found at every level of theseafood supply chain, though the majorityof the studies (80 percent) were conductedat the retail level, such as restaurants orgrocery stores. The remainder of the studiesincluded samples from the wholesale anddistributor level, the import level, or at anumber of points in the supply chain. Lessthan 3 percent involved cases or studies atthe point of landing and/or packaging andprocessing, and just three studies focusedon online seafood markets, an emergingsector of the seafood supply chain wherelabeling rules are still vague.The most frequent types of seafoodinvestigated for mislabeling varies acrossthe globe. Snapper, grouper and salmonwere the most studied in the United States;cod, hake and sole in Europe; and cod,shellfish and snapper were the most studiedelsewhere (Appendix Tables 1-3). The mostcommon seafood substitutes identifiedacross multiple studies globally areAsian catfish, hake and escolar, or oilfish(Appendix Table 4).Seafood fraud was identified in all 200 plusstudies reviewed except one. The exception,one small study in Tasmania, found noexplicit fraud but did highlight unclearseafood labeling practices.10 For instance,hake was sold as “smoked cod,” whichalthough misleading, is permissible underAustralia’s seafood labeling rules.The Tasmania study resembles others incountries where lax labeling rules may not4 OCEANA Deceptive Dishes: Seafood Swaps Found Worldwidelead to fraud per se, but probably resultin consumers thinking they are gettingone seafood product when it is actuallyanother. Cases like these were notincluded in Oceana’s map or analysis, butevidence indicates that seafood consumersare often misled even if it does not violatelocal or regional seafood labeling rules.For example, a study in western Indiafound restaurants selling “crab,” whichwas actually cheaper varieties mixed inwith more expensive ones.11 At the sametime, the EU allows each member state(or country) to adopt its own commercialmarket names for seafood.12 In France,“colin” is the single market name forsix different species, including hake(Merluccius spp), saithe (Pollachius virens),European pollock (Pollachius pollachius),marbled rockcod (Notothenia rossii),Alaska pollock (Theragra chalcogramma)and even Patagonian toothfish(Dissostichus eleginoides).13Other studies identified vague marketnames that include a number of species,some of which may have different prices,conservation statuses or health risks. Astudy in Greece found that hake, cod,haddock and whiting were all labeled“bakaliaros,” despite some species posinghigher allergy risks than others.14 Sixtysix different species are allowed to be soldas “grouper” in the U.S., making it nearlyimpossible for consumers to know whichactual fish they are buying and underminingtheir ability to make seafood choicesbased on sustainability or other reasons.15Though laws were not broken in thesecases, vague labeling rules potentially cheatconsumers, harm their health, or makethem unwitting accessories to fishing oraquaculture practices that are illegal orharm the environment.16 These issues areespecially problematic when the ambiguityor mislabeling is intentional and laws aredeliberately broken. And indeed, laws arebeing broken on a global scale.

Global Review of Seafood FraudSeafood fraud was investigated in 55 countries onevery continent except for Antarctica.A student project at auniversity in Chicagoidentified 16 mislabeledsamples out of 52—mostly cheaper fishmisrepresented as moreexpensive ones.A Santa Monica restaurantand two sushi chefs werecharged for selling whalemeat, including meat fromthe endangered sei whale.The restaurant, which hassince closed, had labeledthe whale as fatty tunato hide its true identitywhen it was shipped to therestaurant in order to sellwhale sushi.In the United Kingdom, aconsumer watchdog groupdiscovered a number ofcases in which haddockwere being sold as moreexpensive cod, and whitingwere being sold as moreexpensive haddock.In Brazil, 55 percent of“shark” samples tested wereactually largetooth sawfish,a species considered bythe IUCN to be criticallyendangered and for whichtrade is prohibited in Brazil.Ninety-eight percentof the 69 bluefin tunadishes tested in Brusselsrestaurants were actuallyanother fish.In a 2014 study, lower-valueSouth African hake wasrevealed to have been sold ashigher-value European hakein Spain.Researchers in Italy foundthat 82 percent of the 200grouper, perch and swordfishsamples they tested weremislabeled, and almost half ofthose mislabeled species areconsidered threatened withextinction by the IUCN.A 2015 German studyfound about half of thesamples sold as “sole”to be lower-value fishupon testing.Due to its high price and thedifficulty in identifying itssource, caviar is especiallysusceptible to fraud. Of 27caviar samples tested from avariety of vendors around theBlack Sea and the Danube River,10 were identified as somethingother than what the labelclaimed. Three of the “caviar”samples tested contained noanimal DNA at all. It is unknownwhat exactly these counterfeitcaviar samples were made of.Interactive map:

OCEANA Jenn HuetingHighlightsThis review not only demonstrates theglobal scope of seafood fraud, but alsobrings up a number of serious concerns thatillustrate the need for prompt and decisiveaction to combat these illegal activities.The examples below represent just asampling of many ongoing practices thatthreaten consumer health, hurt consumers’wallets, cheat honest fishermen and seafoodbusinesses, and contribute to the depletionof ocean resources.HealthMore than half (58 percent) of the samplesidentified as substitute species in thisanalysis carried a species-specific health riskto consumers, meaning these risks couldnot be adequately screened or mitigateddue to the mislabeling.17 These health risksinclude parasites, environmental chemicalsand aquaculture drugs, and other naturaltoxins, including those described below:18 Histamine or scombrotoxinpoisoning, produced in thedecomposition of certain tuna-relatedspecies, which can cause tingling orburning of the mouth or throat, rashor hives, low blood pressure, itching,headache, dizziness, nausea, vomiting,diarrhea, fluttery heartbeat and troublebreathing; Ciguatera, a natural toxin in certainreef fish from affected waters, whichcan cause long-term debilitatingneurological symptoms, includingtemperature reversal (not being able todistinguish between hot and cold) andpainful tingling; Tetrodotoxin, a toxin found incertain pufferfish species, which6 OCEANA Deceptive Dishes: Seafood Swaps Found Worldwidecan cause symptoms ranging fromnumbness and tingling to paralysis anddeath; and Gempylotoxin, a natural toxin foundin escolar and oilfish, which can causeoily bowel discharge, nausea, vomitingand stomach cramps.One commonly mislabeled fish with aspecies-specific health risk is escolar.Escolar and its close cousin oilfish arespecies that contain naturally occurringgempylotoxin and have been associatedwith outbreaks of severe gastrointestinalproblems. Oceana’s seafood fraudinvestigations revealed more than 50 casesof escolar being sold as “white tuna” in sushirestaurants in the U.S., while a study inSouth Africa found oilfish being substitutedfor swordfish and steenbras.19 A numberof outbreaks of gastrointestinal symptomswere reported in two Australian states

Highlightsafter customers ate what they thought was“rudderfish,” but what was likely actuallyescolar.20 Escolar sold as “butterfish” also ledto outbreaks in Spain and Australia, as didoilfish sold as cod or seabass in Hong Kongand Canada.21Pufferfish have been found substitutedfor squid in Italy, cod in China, filefish inTaiwan, and monkfish in Chicago.22 Manyspecies of pufferfish can harbor the naturaltoxins tetrodotoxin and saxitoxin, whichcan be deadly at the right dose. TheChicago case sickened the couple whopurchased the mislabeled fish and sent thewoman to the hospital with numbness,tingling and chest pain. She required weeksof rehabilitative care.23Case Study: Asian CatfishImposter Syndrome: What You Thought You BoughtWhen You Were Served PangasiusPerchRock CodGrouperHakeSolePollockPlaiceSnakehead (channa)HalibutPangaCatfishRawasCodRed SnapperFlounderGurnardBasaAnglerfishFigure 1. In 141 instances, pangasius was swapped for 18 differenttypes of fish around the world, but mostly for perch, grouper and sole(See Appendix Table A4 for citations).Asian Catfish Counterfeits Expanding Around the Globe8765South he global seafood trade is substantial.Millions of tons of seafood are caught orharvested, processed, packaged, shippedand sold every year, valuing 148 billionin 2014.24 It is uncertain what the cost ofseafood fraud is to this global value, butit is no doubt substantial. The estimatedvalue of annual losses due to illegalfishing worldwide is between 10 billionand 23.5 billion.25 Regardless of theexact annual value of seafood fraud andIUU fishing, there are plenty of economicincentives and opportunities for deceptionin the opaque global seafood market.This hurts consumers as well as honestfishermen and businesses.Across the world, our review revealsthat seafood mislabeling appears to bemotivated primarily by economic gainthrough intentionally misleading buyersat every level of the seafood supplychain. About 65 percent of the studiesreviewed include clear evidence ofeconomically motivated adulteration ofseafood products. In case after case,cheaper or less desirable fish weremislabeled as more expensive varieties.Pangasius, the most commonly substitutedfish worldwide, is frequently disguised aswild, higher-value fish. In total, pangasiushas stood in for 18 types of fish worldwide(Figure 1). Investigative journalistsfirst publically uncovered pangasius as asubstitute for wild-caught fish in the 2006,26 but fraud involving pangasiussubstitutes appeared as early as 2002 inthe U.S.27 Since then, the substitutionof pangasius for more valuable productshas increased. The next earliest cases ofpangasius substitution were in Canadaand Europe in 2008,28 followed by Egypt29and South Africa in 2013-2014,30 Brazil in2015,31 and India in a 2016 study32 (Figure2). Although Europe now accounts for mostof the cases of pangasius substitutions in ourglobal analysis, the most recent large, panEuropean study found pangasius replacingonly 3 percent of the 3,900 samples.332002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015Figure 2. Timelines of pangasius substitution around the world using thenumber of studies, cases or reports finding pangasius fraud. Fraud involvingpangasius substitutes appeared as early as 2002 in the U.S. Since then, thesubstitution of pangasius for more valuable products has increased.oceana.org7

HighlightsOCEANA Keith EllenbogenMislabeling is by no means restricted topangasius. Consumers across the worldare being cheated in cases involving a widevariety of seafood, as illustrated in theexamples below: A 2015 German study found abouthalf of the samples sold as “sole” to belower-value fish upon testing.34 In the United Kingdom, a consumerwatchdog group discovered a numberof cases in which haddock werebeing sold as more expensive cod,and whiting were being sold as moreexpensive haddock.35 Lower-value South African hake wasrevealed to have been sold as highervalue European hake in Spain in a 2014study.36 In 2015, European researchers foundthat 14 percent of the products theytested labeled as European anchovieswere replaced with lower-value fish.37 A student project at a university inChicago identified 16 mislabeledsamples out of 52, mostly cheaper fishmisrepresented as more expensive ones.38 Due to its high price and the difficulty inidentifying its source, caviar is especiallysusceptible to fraud. Of 27 caviarsamples tested from a variety of vendorsaround the Black Sea and the DanubeRiver, 10 were identified as somethingother than what the label claimed.Three of the “caviar” samples testedcontained no animal DNA at all. It isunknown what exactly these counterfeitcaviar samples were made of.39Fraud occurs throughout the seafoodsupply chain, not just at restaurants andsupermarkets. One case reported inOceana’s 2013 “Seafood Sticker Shock”report described the prosecution of a U.S.seafood processor for the mislabeling of160,000 pounds of coho salmon as the moreexpensive Chinook, a value of 1.3 million.40An investigation underway in New Englandalleges that the owner of multiple fishingvessels and seafood processing facilities wasable to hide roughly 154 million in illegallycaught and mislabeled seafood in a decadeslong scheme.41ConservationThe oceans are in trouble. Overfishing,destruction of essential habitat (due todamaging bottom trawls), and bycatch(the killing of non-target species) have allled to severely depleted fish stocks, andmore and more marine animals are endingup on a growing list of species threatenedwith extinction.8 OCEANA Deceptive Dishes: Seafood Swaps Found WorldwideTo help certain species recover and toprevent their local or total extinction,some governments have put protections inplace that limit the amount of those speciesfishers can catch or prohibit the killing ofespecially vulnerable species.42 But someunscrupulous poachers flout these rulesand then mislabel their catch to hide theirillegal practices.The studies compiled here bear troublingstatistics. Sixteen percent of the speciesidentified as substitutes are considered tohave some level of elevated conservationrisk (either threatened or close tobecoming threatened with extinction inthe near future) by the IUCN.43 Most ofthose (nearly 12 percent of all the speciessubstituted) are considered criticallyendangered, endangered or vulnerable.More than half of the species identified assubstitutes were species that are categorizedas “data deficient” or “not evaluated”by the IUCN, meaning it is not knownwhether or not these species have healthypopulations.44It is very important to have accurateseafood labels. Seafood buyers already havedifficulty differentiating the responsiblycaught snapper since species-specificnames are often not offered, and evenmore concerning is the threat to at-risk

Highlightsspecies when they are caught and thensold as a more abundant variety. Oceana’spast investigations found that 87 percentof snapper sampled nationwide weremislabeled.45 In fact, 33 different speciesof fish were found to be substituted forthe snapper sold. The majority of speciessold under the name of “snapper” in theU.S.46 have not had the population statusof their stocks evaluated, so it is unclearwhether most snapper species are actuallysustainably fished or in jeopardy. Of theminority of the snapper species that havebeen assessed, 20 percent face a high risk ofextinction in the wild.47The FDA also allows 66 different speciesof fish to be sold under the acceptablemarket name “grouper.”48 In contrast tothe snappers, most of the species marketedunder the name grouper in the U.S. havebeen evaluated by t

common solution: full-chain traceability for all seafood. The proposed rule includes traceability requirements that would only apply to 13 "at-risk" types of seafood, and Seafood fraud is a serious global problem that undermines honest businesses and fishermen that play by the rules, threatens consumer health, and puts our oceans at risk.

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