DEFINITION
In accordance with the Codex Alimentarius Code of Practice for Fish and Fishery Products (CXC 52-2003), Fish is defined as any of the cold-blooded (ectothermic) aquatic vertebrates. This definition explicitly excludes amphibians and aquatic reptiles [1]. Depending on the regulatory context, the European Union provides different definitions:
- Food of animal origin hygiene: Under Regulation (EC) No 853/2004, Annex I, Point 3.1, “Fishery products” encompasses all seawater or freshwater animals, whether wild or farmed, including all edible forms, parts, and products. This definition specifically excludes live bivalve molluscs, live echinoderms, live tunicates, live marine gastropods, and all mammals, reptiles, and frogs. [2]
- Animal Health: Regulation (EU) 2016/429 groups fish within the taxonomic group the superclass Agnatha and the classes Chondrichthyes, Sarcopterygii, and Actinopterygii. [3]
The category of Fish and Fish Products comprises all aquatic organisms (from wild capture or aquaculture) intended for human consumption, including bony and cartilaginous fish, crustaceans, molluscs (gastropods, bivalves and cephalopods) and other aquatic invertebrates. Fishery product means any human food product in which fish is a characteristic ingredient. [1] Aquatic food safety hazards are classified into biological, chemical, or physical agents likely to cause illness or injury:
- Biological hazards include bacterial pathogens (e.g., Salmonella, Vibrio [4]), viral agents like Norovirus, and parasites such as Anisakis [8].
- Physical hazards comprise hard or sharp foreign objects, including natural bone fragments and man-made contaminants like glass, metal, or microplastics [7].
- Chemical hazards encompass environmental contaminants like methylmercury in large pelagic fish, “forever chemicals” (PFAS), and Histamine (a toxin that forms if fish aren’t well iced [5], [6]. Additionally, processing can introduce carcinogenic Polycyclic Aromatic Hydrocarbons (PAH), while aquaculture carries risks from misused veterinary residues and antimicrobial resistance.
Food fraud in this sector represents a deliberate, deceptive practice. It is defined in a food fraud report by FAO as a practice intended to deceive others regarding the prescribed specifications or expected characteristics of food to gain an unfair economic advantage [9]. Within the European Union legislation (Article 9(2) of Regulation (EU) 2017/625), these “fraudulent or deceptive practices” are identified as violations of EU food law.
The sector’s extreme vulnerability stems from a high species diversity, with over 12,000 individual species traded, and complex supply chains, resulting in a fraud probability of 20,6 %, significantly higher than that of meat (13,4 %) or fruits and vegetables (10,4 %) (10). Below are some of the most common fraud categories:
- Species substitution (e.g., selling tilapia as red snapper);
- Adulteration (adding dyes to fish to make them look fresher);
- Simulation (utilizing surimi to simulate crab);
- Mislabeling/Misdescription (e.g., falsifying the origin, method of production, or organic claims).
The economic gain from fraud is a major driver. As an example, substituting Atlantic salmon for Pacific salmon yields an average profit of 9 € per kilogram. Beyond financial loss, fraud creates severe food safety risks, including exposure to undeclared allergens in surimi simulations or tetrodotoxins in substituted puffer fish. Furthermore, misrepresenting frozen-thawed fish as “fresh” compromises structural integrity and promotes hazardous bacterial growth if consumers unknowingly refreeze the product [9].
