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Particular controversy has developed with respect to nomenclature of red snapper (Lutjanus campechanus) owing to the sale of Pacific coast rockfish under the name of red snapper (Otwell, 1985). In response, FDA developed Compliance Policy Guide No. 7108.04, which states:

BACKGROUND—The name "red snapper" has been preempted by many years of consistent consumer usage as meaning only the fish Lutjanus campechanus. Because of the high esteem in which this fob is held by consumers, and the relatively limited catch, there have been numerous attempts to substitute other, less expensive fishes for this species. Substitutes of less desirable species have included members of the family Lutjanidae, groupers, a number of West Coast rockfishes of the genus Sebastes, and other species. The West Coast rockfishes have, until relatively recently, been distributed mostly locally, and thus have been beyond the reach of the Federal Food, Drug, and Cosmetic Act. Some of the states an the West Coast have officially sanctioned "red snapper" as an alternative name for such members of the Sebastes genus, although these fishes am quite different in appearance, flavor, and texture, and are generally regarded by consumers familiar with Lutjanus campechanus as inferior.

POLICY—The labeling or sale of any fish other than Lutjanus campechanus as "red snapper" constitutes a misbranding in violation of the Federal Food, Drug, and Cosmetic Act.

Notwithstanding the formal FDA guideline, California still allows the sale of rockfish species under the name of "red snapper" in intrastate commerce.

Several matters of seafood nomenclature have also been addressed by States, which have developed (1) common or usual name regulations for halibut that are identical to the Federal regulations (Alaska Stat. §17.20.045; Mass. Gen. Stat. Ann. §194B; Or. Rev. Stat. §616.217; Wash. Rev. Code §69.04-315); and (2) labeling requirements with respect to the source of catfish (i.e., "farm-raised catfish," "river or lake catfish," "imported catfish," or ''ocean catfish") (Ark. Stat. Ann. §20-61-202 and §20-61-206; Miss. Code Ann. §69-7-605 to 69-7-609). FDA's list of acceptable market names further distinguishes between marine species identified as either "ocean catfish'' or "sea catfish" (FDA, 1988; NFERF, 1991b). It should be noted that regulatory and promotional aspects of aquaculture per se are under USDA jurisdiction, whereas regulation of harvested catfish and derived food products (including labeling aspects) is handled by FDA.

Surimi-based Imitation Crab and Other Fish Substitutes Various substitute seafood products pose a labeling problem because of the need to accurately identify products for possible public health reasons (e.g., allergy) and prevent economic deception. With respect to imitation crab products (i.e., products that are defined as not 100 percent crabmeat and often contain surimi manufactured from the processed flesh of pollock or similar fish), such products must be labeled "imitation crabmeat" and bear an



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