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Food Safety

Fish substitution (2015)

About events in 2015

In 2015, the European Commission organised a control plan coordinated at European Union level to assess the prevalence on the market of white fish mislabelled with regard to its declared species.

The plan was part of the Commission follow-up of the horse meat crisis in 2013, where systematic checks to assess the extent of possible fraudulent activity in a certain sector, was one of the actions. Fishery and aquaculture products were identified by the Commission and the EU countries' experts as a possible high risk commodity for species substitution.

The plan was agreed with the EU countries in February 2015 and the sampling took place during June and July of this year. All the sampling and analysis was performed in the EU countries using, to the extent possible, a network of local laboratories.

This is the first EU (+EFTA) wide coordinated testing programme on fish species substitution and the EU countries sampled in total 3906 samples from over 150 different white fish species from all stages of the food chain. This represents a very broad species target group in comparison to other studies of this kind.

The declared species was confirmed in 94% of the samples taken. The overall non-compliance is lower than the levels of non-compliance in white fish in many of the other more limited testing programmes in the EU countries, although for certain species the levels are still quite high.

The aggregated results can only give us an idea of the situation concerning mislabelled white fish on the EU market. Based on the information gathered in this plan it is not possible to give any estimate of how many cases of intentional violations perpetrated with the purpose of financial gain this represents, as opposed to just bad or ill-informed practices.


Available information indicates that white fish not meeting current legal requirements for identification of species may be present in the EU market. In order to better assess the prevalence of such non-compliances the European Commission organised a control plan coordinated at European Union level.


Assess the prevalence on the market of white fish mislabelled with regard to its declared species in unprocessed and processed products. In the context of this coordinated control plan "white fish" was defined as demersal species living in both marine and freshwater environments, including round fish which are benthopelagic species and flat fish which are benthic species.

Applicable legislation:

Article 53 of Regulation (EC) No 882/2004 on official controls (OCR) gives the Commission the mandate to recommend coordinated plans where considered necessary, on an ad-hoc basis, to assess the prevalence of hazards in feed, food or animals.

Regulation (EU) No 1169/2011 on Food Information to Consumers (FIC) and Regulation (EU) No 1379/2013 on the Common Market Organisation of fishery and aquaculture products (CMO) represent the detailed legislation on identification and labelling of fishery and aquaculture products.

Details of the coordinated control plan

The coordinated control plan was detailed in Recommendation C(2015) 1558 final of 12 March 2015 to the Member States. To avoid informing on all details of the controls before they were to be performed the Recommendation was not published.

Recommendation and its annexes available here.


During official controls, 27 Member States and 2 EFTA Member States collected 3906 samples of fish of predominantly white fish species. The samples were taken at different stages of the food chain and represented a broad range of products and over 150 white fish species.


Samples were collected from 1 June until 15 July 2015.

Testing protocol:

The samples were submitted to one or more of the following tests:

  • IEF (Isoelectric focusing method, e.g. AOAC Official Method 980.16 using the relevant IEF database)
  • PCR-RFLP (Polymerase chain reaction coupled with restriction fragment length polymorphism)
  • DNA-barcoding (DNA-sequencing using a validated protocol)
  • RT-PCR (Real-time polymerase chain reaction, uniplex or multiplex)

Further information