Seafood Consumers Association calls on the Albanese Government to end Australia's seafood naming double standard
The Seafood Consumers Association (SCA) is calling on the Australian Government to end a glaring double standard that provides stronger fish-naming requirements for Australian seafood destined for export while leaving Australian families reliant on a largely voluntary naming system at home.
Australia has an established Australian Fish Names Standard, AS 5300, designed to provide consistent and accurate names for fish and seafood.
Yet for seafood sold to Australian consumers, adherence to AS 5300 remains largely voluntary.
SCA CEO Roy D. Palmer said Australian consumers should not receive a lower standard of seafood identification than overseas customers.
“If Australian fish names are important enough to protect our reputation in export markets, they are important enough to protect Australian families at home,” Mr. Palmer said.
“When Australians order Snapper, Barramundi or Flake, they should be able to trust that the seafood they receive is what the name says it is.”
The evidence is already there
Australian research demonstrates that seafood misidentification and mislabelling are not hypothetical problems.
A national DNA barcoding study of seafood sold through supermarkets, fishmongers and restaurants reported an aggregate direct biological mislabelling rate of 11.8 per cent.
When samples were assessed against the naming criteria of the Australian Fish Names Standard, non-compliance reached 34.9 per cent, while only 25.5 per cent of products carried a precise species-level label at the point of sale.
Separate genetic research into shark meat sold in Australia found 88 per cent of samples specifically sold as “Flake” were neither Gummy Shark nor New Zealand Rig — the two species identified for the name Flake under AS 5300.
“This isn't simply an argument about terminology,” Mr. Palmer said.
“The name of a fish can matter to consumer choice, value, sustainability and potentially health. Consumers cannot make informed decisions when they don't reliably know what species they are buying.”
Country of origin is only half the answer
SCA strongly supports the Australian Government's introduction of mandatory Country of Origin Labelling for seafood in hospitality.
But Mr Palmer said identifying whether seafood is Australian, imported or mixed does not solve the equally important question of species identity.
“Country of Origin Labelling tells Australians where their seafood came from. It doesn't necessarily tell them what fish they are eating. Consumers deserve both.”
“An imported fish can be correctly identified as imported while still being marketed under a vague, confusing or inappropriate trade name.
“Origin and identity are two different pieces of consumer information. Australia has now acted on one. It is time to complete the job.”
A public health contradiction
The issue also raises questions about the effectiveness of seafood health advice.
Food Standards Australia New Zealand provides advice to consumers, including pregnant women and young children, about limiting consumption of particular fish associated with higher mercury exposure.
Such advice necessarily depends upon consumers being able to identify the fish they purchase.
“We cannot tell vulnerable consumers to make health decisions according to fish species and simultaneously accept a marketplace where consistent species naming remains voluntary,” Mr. Palmer said.
“That is a regulatory contradiction which should be fixed.”
Four practical actions
The Seafood Consumers Association is calling on the Australian Government to:
1. Make AS 5300 mandatory for domestic seafood sales
Establish consistent Australian Fish Names Standard naming across retail, wholesale and food service, with appropriate incorporation into Australia's regulatory framework.
2. Align seafood health advice with mandatory naming
Ensure public health advice relating to particular fish species is supported by a marketplace in which consumers can reliably identify those species.
3. Strengthen action against misleading seafood names
Ensure the ACCC and state and territory consumer protection authorities have the tools and evidence needed to address seafood descriptions that are misleading or deceptive.
4. Lead by example with taxpayer-funded seafood research
Require Australian Government-funded seafood research and communications, including relevant FRDC-funded work, to consistently use Australian Fish Names Standard names.
Mr Palmer said making the standard mandatory should not be characterised as unnecessary red tape.
“This is about truth in trade.”
“Australia is still investing expertise, industry and taxpayer resources in updating and expanding AS 5300. The latest Fish Names Committee update shows hundreds of names moving through approval and consultation. Why maintain a national standard if using it to inform Australian consumers remains optional?”
One standard for everyone
The standard itself continues to evolve. The Fish Names Committee's latest September 2026 update confirms that 121 new Standard Names have recently been approved following public consultation, with a further 96 proposed additions progressing to consultation. A new AS 5300:2026 edition has also been published.
“This makes the present situation even harder to justify,” Mr Palmer said. “Australia continues to invest considerable expertise, consultation, time and money in maintaining and improving a national Fish Names Standard, yet Australian businesses are still largely free not to use it when selling seafood to Australian consumers.”
SCA says the reform would benefit responsible Australian fishers, aquaculture producers, processors, retailers and food-service businesses as well as consumers.
Businesses selling correctly identified seafood should not be commercially disadvantaged by competitors using ambiguous names or substituting lower-value species.
Mr Palmer said the principle was straightforward.
“Australian seafood producers deserve protection for the identity and reputation of what they produce. Australian businesses deserve a level playing field. And Australian consumers deserve to know what they are paying for and eating.”
“We have a national fish naming standard. It is time we started treating it like one.”
ENDS
MEDIA CONTACT
Roy D. Palmer, MBA
CEO, Seafood Consumers Association Ltd
www.seafoodconsumers.global
Email: seafoodsdg@outlook.com Phone: +61 492825012
NOTES TO EDITORS
Australian Fish Names Standard (AS 5300): Australia's established standard for consistent fish and seafood naming. It was developed through accredited standards processes and launched in 2007 and FSANZ played key role in its establishment.
National seafood study: Research involving 672 commercial seafood samples from Australian supermarkets, specialist fishmongers and restaurants reported 11.8% direct biological mislabelling. Assessment against AS 5300 criteria produced non-compliance of up to 34.9%. Flake research: Genetic research involving shark meat sold in Australia found 88% of samples specifically sold as “Flake” were neither Gummy Shark nor New Zealand Rig. All references are shown below.
Country of Origin Labelling: Mandatory seafood Country of Origin Labelling in hospitality distinguishes seafood as Australian, Imported or Mixed. SCA argues that origin information should be complemented by reliable species identification.
About the Seafood Consumers Association
Seafood Consumers Association Ltd is an independent Australian consumer-focused organisation advocating for transparent, ethical and trustworthy seafood systems. Its work focuses on consumer information, seafood integrity, food security, education and rebuilding trust throughout the seafood supply chain.
References:
Australian Fish Names Standard (AS 5300) & Seafood Mislabelling Research
This reference sheet compiles the statutory instruments, regulatory frameworks, peer-reviewed scientific studies, and enforcement precedents supporting both advocacy articles.
1. Regulatory & Standards Architecture
• Standards Australia AS 5300 (Australian Fish Names Standard):
o Status: Developed under the accredited Seafood Services Australia / FRDC standards process and launched in 2007; continually maintained via the Fish Names Committee.
o Jurisdiction: Voluntary for domestic retail, food service, and wholesale; mandatory for exports under federal biosecurity export controls.
o Reference: Fisheries Research and Development Corporation (FRDC). Australian Fish Names Standard Database (AS 5300).
• Commonwealth Export Control Framework:
o Instrument: Export Control Act 2020 and Export Control (Fish and Fish Products) Rules 2021.
o Application: Prescribes trade descriptions and official species naming requirements aligned with AS 5300 for commercial marine products exported from Australia.
• Food Standards Australia New Zealand (FSANZ):
o Instrument: Australia New Zealand Food Standards Code – Standard 1.2.2 (Food Identification Requirements) and Standard 2.2.3 (Fish and Fish Products).
o Note on Gap: Standard 2.2.3 defines what constitutes "fish" broadly for compositional and safety purposes but does not mandate species-specific standard trade names or incorporate AS 5300 by reference.
• Australian Consumer Law (ACL):
o Statute: Competition and Consumer Act 2010 (Cth), Schedule 2.
o Key Provisions:
Section 18: Prohibition against engaging in conduct that is misleading or deceptive, or likely to mislead or deceive in trade or commerce.
Section 29: False or misleading representations about goods or services (e.g., standard, quality, value, grade, composition, or origin).
2. Peer-Reviewed Academic & Empirical Studies
A. National Multi-Species Seafood Fraud & Substitution
• Minderoo Foundation National Seafood Study (2023):
o Citation: Harrison, E. P., Wilcox, C., et al. (2023). "DNA barcoding reveals widespread mislabelling and substitution across Australian seafood retail and dining sectors." Scientific Reports (Nature Portfolio).
o Dataset: 672 commercial seafood samples collected across supermarkets, specialist fishmongers, and restaurants across Australia.
o Key Findings:
11.8% aggregate direct mislabelling rate nationwide.
When tested strictly against the specific criteria of the Australian Fish Names Standard (AS 5300), non-compliance was recorded at up to 34.9%.
Only 25.5% of sampled products used a precise, species-level label.
Substitution was concentrated in sharks/rays (39.7%) and snappers (34.4%).
Endangered Species Documented: Spotback skate (Atlantoraja castelnaui, IUCN Critically Endangered) sold as generic imported stingray; Smooth hammerhead (Sphyrna zygaena, IUCN Vulnerable) sold as generic shark; School shark (Galeorhinus galeus, IUCN Critically Endangered) sold as battered fish and chips.
B. Takeaway & Retail Shark Meat ("Flake") Substitution
• Macquarie University Shark Meat Barcoding Study (2024):
o Citation: Parker Kielniacz, T., Armansin, N. C., & Stow, A. (2024). "Genetic identification of shark meat in Australian markets highlights conservation and consumer labelling concerns." Marine and Freshwater Research, CSIRO Publishing.
o Dataset: 91 shark meat samples collected from 28 retailers across six Australian states and territories.
o Key Findings:
Approximately 70% of shark meat samples failed to comply with AS 5300 or did not match the retailer's description.
88% of samples sold specifically as "flake" were neither Gummy Shark (Mustelus antarcticus) nor New Zealand Rig (Mustelus lenticulatus).
9 samples (approx. 10%) were derived from threatened species, including the critically endangered Scalloped Hammerhead (Sphyrna lewini) and School Shark (Galeorhinus galeus).
Takeaway/hospitality venues exhibited higher mislabelling and lack of species awareness than wholesale tier businesses.
• Earlier Baseline Shark Meat Studies:
o Citation: Bornatowski, H., et al. / Australian conservation genetics surveys (2019–2021) evaluating takeaway fish substitution in Victorian and New South Wales fish-and-chip outlets.
o Key Findings: Demonstrated regular substitution of elephant fish (Callorhinchus milii) and grey reef sharks in place of targeted hound sharks.
3. Legal Precedents & Regulatory Enforcement Actions
• Nature's Care vs. Australian Consumer Law / Country of Origin Rules:
o Citation: Nature's Care Manufacture Pty Ltd v Australian Made Campaign Ltd [2018] FCA 1936.
o Context: Federal Court examined the boundaries of "substantial transformation" under the ACL Safe Harbour provisions. Affirmed that importing raw marine/fish ingredients and encapsulating or repackaging them locally does not meet the threshold of an Australian product.
• ACCC Enforcement on Deceptive Processing and Provenance:
o Regulatory Target: Enforcement against major food processors (e.g., Simplot Australia, Birds Eye) regarding frozen fish products.
o Outcome: Scrutiny over the prominence of "Made in Australia" statements on crumbed/battered fish products where the fish flesh itself was sourced from imported, low-cost wild-catch or foreign aquaculture systems (e.g., Alaskan Pollock, Basa/Pangasius).
• Mandatory Country of Origin Labelling in Hospitality (CoOL):
o Commonwealth Directive (Commenced phased implementation 2025/2026): Mandates that restaurants, cafes, and pubs state whether seafood is Australian (A), Imported (I), or Mixed (M).
o Limitation: The policy regulates geography/origin only, completely excluding species identification. An imported Basa or Vietnamese Tra catfish can be lawfully compliant by marking "(I)" while continuing to be sold under trade names like "Dory" or "White Fish."
4. Institutional & Grant Accountability Sources
• Fisheries Research and Development Corporation (FRDC):
o Governance: Statutory Corporation under the Primary Industries Research and Development Act 1989 (PIRD Act).
o Portfolio Responsibility: Primary co-funder (alongside Australian taxpayers and commercial fishing levies) for the maintenance, secretariat support, and development of AS 5300.
o Audit Issue: Absence of mandatory grant compliance requiring funded academic research teams, milestone deliverables, and scientific communication outputs to exclusively employ approved AS 5300 Standard Fish Names.
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