A new EU study has suggested that labelling rules for seafood alternatives should be stricter to make a clear distinction between conventional and plant-based products.
The research analyses the seafood alternatives market, identifying 102 companies supplying 228 different products. These companies are based in 26 different countries, including 12 EU Member States. The analysis notes that plant-based seafood products were originally sold mostly in specialised shops and online, but in recent years have been supplied by major retailers in both North America and the EU. Additionally, large agrofood companies and conventional seafood producers are beginning to enter the market.
78% of the 228 products studied imitate tuna, whitefish (for fish finger-like products), salmon, shrimp, and crab, with the latter mostly sold in the North American market. These findings are reportedly in line with conventional seafood consumption, suggesting that plant-based seafood is a direct competitor.
Soy, pea, and wheat were found to be the most common protein ingredients used in seafood alternatives, with starch-based ingredients such as konjac often used for shellfish alternatives. The study claims that products may use additives that “are in general not in line with the characteristics of authentic seafood products”. It also criticises the use of allergens and imported ingredients in some seafood alternatives, and claims that production requires “several industrial steps” that could make the products less natural.

Labelling rules
Conventional seafood products must abide by the Common Market Organisation (CMO) Regulation 1379/2013 and the Food Information to Consumers (FIC) Regulation 1169/2011. However, plant-based alternatives only have to comply with the FIC Regulation, unless they are made with seaweed or algae.
The study notes that Article 7 on fair information practices in the FIC Regulation says that “Food information should not be misleading”. It claims that some seafood alternatives could be non-compliant with this article, since 45% of products analysed use names suggesting a relation with seafood. Additionally, 57% make a direct reference to the term “fish” or the name of a fish species.
The authors argue that the use of the commercial designation of aquatic species for a product that does not contain seafood should be forbidden, while products using invented names should be required to provide additional information. They also suggest that seafood alternatives should be labelled with the name of the main ingredient used, claiming that this provides better information than terms such as ‘plant-based’ or ‘vegan’.
Furthermore, the study argues that the level of processing of a product should be indicated on the packaging. If a plant-based seafood alternative contains omega-3, the authors say it should be labelled “enriched with omega-3” to clarify that the nutrient does not occur naturally in the product.

Preventing consumer confusion?
In recent years, there have been several attempts to restrict the labelling of plant-based alternatives, ostensibly to avoid consumer confusion. However, studies consistently show that consumers are not confused by terms such as “vegan burger” or “oat milk”.
In many cases, labelling restrictions are proposed by lobby groups for the meat, dairy, or seafood industries. In some instances, these groups have openly admitted that their actions are at least partially motivated by fear of losing market share. Notably, the new study was requested by the European Parliament Committee on Fisheries, which is likely to have an interest in promoting the conventional seafood industry.
It could be argued that in reality, imposing labelling restrictions may cause more consumer confusion rather than less; for example, if a product can’t be labelled as “plant-based tuna”, it will be difficult for manufacturers to communicate its intended use. This was illustrated by two failed amendments voted on by the European Parliament in 2020, which would have prevented plant-based meat products from being labelled as “burgers” or “sausages”; instead, it was suggested that the terms “discs” and “tubes” should be used, even though this would likely create more confusion.
“These regulations are counter-productive and based on misunderstandings,” said Jasmijn de Boo of ProVeg International in 2022. “Plant-based foods are a vital key to solving the climate crisis as well as ensuring economic growth. Many meat and dairy companies themselves know this, which is why they are investing in both plant-based and animal-based foods, and in some cases switching to plant-based foods entirely.”