Weekly news and commentary from the Seafood Consumers Association
When labelling flexibility exposes a much bigger inconsistency
The Seafood Consumers Association has written to ACCC Deputy Chair Mick Keogh questioning the inconsistent treatment of truth in food labelling.
On 4 August, the ACCC announced that it would continue a temporary enforcement approach allowing certain egg producers affected by government avian-influenza housing orders to retain “free range” labelling for up to 90 days while hens are kept indoors. The arrangement is conditional: producers are expected to communicate the changed circumstances and prepare alternative labelling if confinement continues.
SCA recognises the seriousness of avian influenza and the need to protect animal health, food supplies and farming businesses. Nevertheless, the decision demonstrates that regulators can respond rapidly and pragmatically when an industry confronts an urgent operational problem.
That raises an important question: why has comparable regulatory energy not been applied to the longstanding problem of seafood species misdescription?
For seafood consumers, a fish name is not decorative. It helps them compare price and quality, follow health advice, evaluate provenance and sustainability, identify allergens and respond to food recalls. Once seafood has been filleted, processed or cooked, consumers generally have no practical means of confirming its species.
Australia already has a scientifically developed solution: the Australian Fish Names Standard, AS 5300. Its “one fish, one name” framework establishes accepted names linked to identified species, but its use remains voluntary across much of Australia’s domestic retail, hospitality and food-service market.
The SCA letter asks the ACCC to:
- publicly support mandatory use of AS 5300;
- issue interim compliance guidance recognising the Standard as an objective benchmark under Australian Consumer Law;
- undertake targeted seafood market surveillance and publish de-identified findings;
- convene a national roundtable to establish a regulatory and implementation pathway; and
- support consumer and workforce education through initiatives such as I-CADMUS.
The recent egg decision shows that regulators can act quickly when industry needs assistance. Seafood consumers have lived with inconsistent and potentially misleading species names for decades. They deserve an equally practical response.
Balloon kits and fish names: a question of regulatory priorities
The SCA letter also draws attention to an unusual but revealing comparison.
Australia maintains a mandatory safety standard prohibiting benzene in balloon-blowing kits. The standard dates from 1979 and remains enforceable, despite the ACCC previously reporting that it was unaware of any associated Australian deaths or injuries and identifying only one product recall.
SCA is not suggesting that protection against carcinogenic substances is unimportant. The comparison instead demonstrates that government can preserve a mandatory national standard for a small and rarely encountered product category when consumer protection requires it.
Seafood, by contrast, is purchased and eaten by millions of Australians. Species substitution and misdescription have been repeatedly documented, the financial incentive to substitute cheaper products is considerable, and a nationally accredited naming standard already exists.
The policy failure is therefore not the absence of a technical solution. It is the failure to activate that solution for Australian consumers.
This also has health implications. Consumers may receive advice concerning seafood species, allergens, mercury, pregnancy or compromised immunity. Such advice becomes considerably less useful if there is no mandatory assurance that the seafood is being sold under an accurate species name.
Food fraud moves into the national spotlight
Recent ABC Four Corners reporting has examined how food marketing, processing and health claims can create an impression that is markedly different from the product consumers actually receive.
Although the reporting extends beyond seafood, its central lesson applies directly to the seafood counter and restaurant menu: legal-looking words, attractive imagery and carefully constructed claims can influence consumers even when the complete impression is questionable.
Seafood is especially vulnerable because processing removes many of the features by which consumers might otherwise recognise a species. Fillets, battered portions, frozen packs, fish fingers and cooked restaurant dishes require consumers to rely almost entirely on information supplied by businesses.
The Food and Agriculture Organization’s report, Food Fraud in the Fisheries and Aquaculture Sector, cites research estimating the probability of fraud in the sector at 20.6 per cent—higher than comparable estimates for meat and fruit and vegetables. Species substitution and mislabelling are among the most frequently reported forms.
The issue is not simply whether individual words are technically defensible. The more important test is whether the name, label, image, menu description and marketing presentation create an accurate overall impression.
When consumers pay seafood prices for ice
Frozen seafood presents another largely invisible consumer-integrity problem: short weight and excessive glazing.
Ice glaze is legitimate when properly applied. It protects frozen seafood against dehydration, oxidation and freezer damage. The problem arises when glaze is improperly counted as seafood weight or disguises a shortage in the amount of product supplied.
In a targeted US Food and Drug Administration sampling assignment conducted between 2022 and 2024, 10 of 28 imported retail-packaged frozen-seafood samples—36 per cent—failed net-weight requirements. The non-compliant products were between 2.3 and 9.9 per cent below their declared weight.
Australia’s National Measurement Institute also conducted a targeted frozen-seafood compliance program during 2024–25. Inspectors visited 53 business premises and examined 328 packaged-product lines, identifying 18 lines as short measure. Again, this was a compliance program rather than a national estimate of deliberate fraud, but it confirms that frozen-seafood quantity warrants continued surveillance.
Protective glaze is legitimate. Selling that glaze as seafood is not.
Fisheries transparency is becoming an international movement
The UK Coalition for Fisheries Transparency has reinforced the need for governments to make reliable fisheries information accessible to regulators, businesses and the public.
Its work highlights the importance of:
- identifying the true beneficial owners of fishing vessels and businesses;
- publishing reliable vessel, license and enforcement information;
- improving catch and supply-chain traceability;
- preventing ownership structures from concealing illegal conduct; and
- enabling civil society and consumers to scrutinise the use of publicly owned resources.
These principles are directly relevant to Australia. Transparency should not end when a fish is landed. It should continue through processing, importing, wholesaling, retailing and food service until the seafood reaches the consumer.
A trusted seafood system requires visibility across four connected flows: the product, its information, the money generated by it and the trust placed in the transaction.
Can consumers see seafood enforcement in Australia?
SCA is also examining how Australian states and territories report fisheries and seafood compliance outcomes.
Victoria publishes selected enforcement outcomes through the Victorian Fisheries Authority, but information available to consumers remains fragmented. Different jurisdictions use different terminology, reporting periods and enforcement categories. Fisheries offences, food-law breaches, trade-measurement problems and misleading consumer representations may be handled by entirely separate agencies.
This makes it difficult to answer basic national questions:
- How much illegal seafood is detected?
- How many seafood businesses are inspected?
- How often are species names tested?
- How many short-weight products are identified?
- What penalties are imposed?
- Are repeat offenders being detected?
SCA believes Australia needs more consistent and publicly accessible reporting of seafood compliance activity. Transparency about enforcement helps consumers evaluate the system and demonstrates to honest businesses that competitors will not be allowed to profit from deception.
Sea of Deception and I-CADMUS update
The complete story audit of Sea of Deception is progressing well and the definitive I-CADMUS classification is being embedded throughout the book:
- I — Illegal
- C — Counterfeit
- A — Addition/Adulteration
- D — Dilution
- M — Misrepresentation/Mislabelling
- U — Unreported/Unregulated/Undisclosed
- S — Substitution
The book will be both an engaging account of seafood deception and a foundation resource for future I-CADMUS seafood-integrity training.
Help us identify seafood transparency problems
Have you encountered seafood sold under a confusing name, an unclear country-of-origin description, a questionable menu claim or a frozen product that appeared to contain excessive ice or water? Email us at seafoodsdg@outlook.com with Subject: Transparency.
SCA wants to hear from consumers and responsible seafood businesses. Examples help identify where education, investigation and regulatory reform are most urgently needed.
Twenty-six million voices. One seafood future.
Seafood Consumers Association
www.seafoodconsumers.global
Comments
Hector Hugo Gojon Baez
08 Aug 2026, 07:03 PM
This is my comment, iw very important identify where education, investigation and regulatory reform are most urgently needed.
Hector Hugo Gojon Baez
08 Aug 2026, 07:02 PM
This is my comment, is very importat identify where education, investigation and regulatory reform are most urgently needed.