China rules rainbow trout can be sold as salmon

Posted by Nicola Aporti on 29th August 2018

BLOG: ON August 6, 2018, CAPPMA (China Aquatic Products Processing and Marketing Alliance) issued a rather controversial draft standard about “Salmon for raw consumption”.

The draft is aimed at regulating “definition, requirements, inspection methods, inspection principles, label, indications, packaging, transportation and storage for raw salmon”.

CAPPMA is a non-profit industry association gathering Chinese aquaculture industries. This standard shall be applicable to raw salmon products that are processed directly from fresh and frozen salmon.

The controversial part of this standard is its article 3.1, whereby it defines “三文鱼 – salmon” as “a general denomination for the varieties of salmonidae, which includes Atlantic Salmon (Salmo Salar)、rainbow trout, silver salmon, chinhook salmon, sockeye salmon, chum salmon, humpback salmon etc.”.

Find the intruder. Got it, the rainbow trout!

How can the rainbow trout be labelled and sold as salmon? This has indeed astonished readers worldwide, following a very well-read article by the Guardian as well as several other websites and newspapers.


It all happened just few weeks after media reported the interesting news whereby most of Norwegian Salmon sold in China is actually domestically-produced rainbow-trout.

In this scenario, on social media and food-expert websites, the main comment was: is China actually legalising some kind of food-fraud?

We analysed the standard (still at draft level, so not effective yet) as well the official statement published by the CAPPMA on its website (please find herein our unofficial translation).

CAPPMA briefly explains that the Chinese term 三文鱼 (pronounciation: “Sanwenyu”) “is not a scientific name … but rather a commercial common name for some kinds of fish”.

In origin, it comes from a translation of the English term “salmon” in HK and Macao. In origin, “sanwenyu” was used only for farmed Atlantic salmon [Salmo Salar].

Also in Australian Food News

Later on, the domestic trout farming began to develop. Some restaurants in the vicinity of the trout farms sold the trout under the name of the sanwenyu since several decades.

Because sanwenyu is a common name and has no scientific definition, it has been used until now.

The reason why people are controversial about the term “sanwenyu” is that some people still believe that “sanwenyu” is only Atlantic salmon (Salmo Salar). Others believe that “sanwenyu” is a common name for several salmons and trouts, and debate arise.

Briefly, if we read carefully CAPPMA statement, we understand that CAPPMA aims at regulating what it deems a language issue, which has created vagueness amongst consumers.

In the amazing richness of Chinese language, we in fact can see that:

• “Salmon” is officially/scientifically translated as 鲑(pron: Gui);
• “trout” is officially/scientifically translated as 鳟 (pron: Zun);
• “Salmonidae” (the family to which both salmon and trout belong to) is officially/scientifically translated as 鲑科 (pron: Gui ke);
• “Salmoninae” (the subfamily to which both salmon and trout belong to) is officially/scientifically translated as 鲑亚科 (pron: Gui ya ke)

From this perspective, it shall be agreed that the term “sanwenyu” although widely used is in fact not a scientific term.

In practice, however, in real daily life, “sanwenyu” is the most used term by Chiense consumers to refer to salmon, and as a Mandarin-speaking foreigner in China since more than a decade I have to admit that I only knew “sanwenyu” as translation for “salmon”.

Yet, some linguistic researches eventually made me realise that “sanwenyu” is indeed also used in practice to refer also to trouts (if you want to test your Chinese capabilities, please refer to this link, amongst others). On some – even major – Chinese dictionary, the term “sanwenyu” does not feature.


First of all, it remains to be seen whether the current draft standard will enter into effect or whether modifications will be input.

Secondly, we shall notice that the current standard requires quite clear (article 7.1) labeling requirements, whereby beside the generic product name as “sanwenyu”, it shall be specified the actual fish species (whether rainbow trout, or Salmo Salar, etc…).

If we assume that “sanwenyu” is actually in practice a vague term, at least this draft standard is aiming at regulating its use – even by acknowledging/including the existing vagueness.

Freshwater rainbow trout should not be eaten raw. But it has been passed off as seawater salmon in China for a while…

Posted by on Thursday, 23 August 2018


CAPPMA is intervening on a non-regulated term – yet widely used amongst consumers: “sanwenyu”. Briefly, it is acknowledging the vagueness of the term and – in a way – is making this vagueness becoming official – redefining in an extensive ways its meaning.

Most negative comments coming from non-Chinese sources stressed the fact that CAPPMA standard had been adopted on the main reasons that CAPPMA considers trout very similar to salmon from biological/taxonomy perspective.

The message was: “China allows trouts to be called salmon because trouts are considered similar to salmon”.

Technically, by analysing the draft standard and the supporting explanation by CAPPMA, this does not seem to be the main point, in our opinion.

What is true is that China is now (if the draft standard will enter into force as such) allowing trouts to be called “sanwenyu”, which is a term usually referring to salmon, but not only (at least according to some/several persons in China).

If we carefully read CAPPMA explanation, the species similarity from taxonomic perspective is only a part of their grounds, while the fundamental part remains the claim – by CAPPMA – that “sanwenyu” is not the scientific translation of salmon and actually has become a vaguely-comprehensive term. So CAPPMA seems mainly to address a linguistic issue – which has of course business implications.

Of course, the use of English term “salmon” within the text of the draft standard as suggested translation of “sanwenyu” is incorrect and contributes to the chaos and disputes.

Questionable as it is – and I do believe that many Chinese consumer consider that the term “sanwenyu” is not vague and clearly defines only “salmon”) – in any way it seems that what is being done by CAPPMA is definitely not legalization of some food fraud – at least as long as the labeling requirement under article 7.1 will be strictly implemented and enforced.

The name of food on the label shall (according to article of GB 7718) “shall clearly indicate the true nature of the food”.

For now, we can ask ourselves whether this was just an attempt to give legality to existing practices in the industry and to protect Chinese local aquaculture industry?

Will the labeling requirements set by article 7.1 of the draft standard be enough not to mislead Chinese consumers? What will their reaction be – from both market behavior and claims against food operators? Will trout sales (and prices) soar?

Let’s sit by the river and wait for fish to come….


ABOUT THE AUTHOR: Mr Nicola Aporti is Head of Corporate and Food Regulatory at law firm HFG Law and Intellectual Property, Shanghai. His blog is republished here with his kind permission.