Today FDA released the 4^th edition of the Fish and Fishery Products Hazards and Controls Guidance document (Hazards Guide). Newly added to the guidance is confirmation that misidentification of species (i.e., species substitution) could result in a potential food safety hazard. Chapter Three of the Hazards Guide lists the potential species-related and process-related hazards in table format and includes the following information on species substitution.

Species substitution

Illicit substitution of one species for another may constitute economic fraud and/or misbranding violations of the Federal Food, Drug, and Cosmetic Act. Furthermore, species substitution may cause potential food safety hazards to be overlooked or misidentified by processors or end users, as shown in Table 3-1, The Effect of Misbranding Through Species Substitution on the Identification of Potential Species-Related Hazards. These examples are based on actual incidents of species substitution or misbranding.

Table 3-1

THE EFFECT OF MISBRANDING THROUGH SPECIES SUBSTITUTION ON THE IDENTIFICATION OF POTENTIAL SPECIES-RELATED HAZARDS