Market names aren't optional
FDA maintains The Seafood List — its guide to acceptable market names for individual species. A label can't use an invented, regional, or aspirational species name in place of the accepted market name; doing so is treated as misbranding, regardless of whether the name is common in trade usage elsewhere. This is one of the more overlooked labeling risks for importers bringing in species that go by different common names in different countries.
Allergen declarations
Fish and crustacean shellfish are both major food allergens under US labeling law. That declaration requirement doesn't stop at whole fish or shell-on shrimp — it follows the ingredient into any processed product it's used in, from surimi-based items to sauces and coatings that include fish- or shellfish-derived ingredients.
Fresh, frozen & processed — what changes
| Requirement | Fresh | Frozen | Processed |
|---|---|---|---|
| Market name | Must match Seafood List name | Same requirement | Name must reflect actual contents (e.g. "imitation crab" for surimi) |
| "Previously frozen" disclosure | Required if thawed before sale | Not applicable | Required if a frozen component was thawed during processing |
| Net weight basis | As-packed, drained if in liquid | Frozen weight, glaze excluded | Finished product weight including coating/sauce |
| Nutrition Facts | Required unless a specific exemption applies | Required | Required, reflecting finished as-sold product |
Glaze weight is a common error
Frozen seafood is often sold with a protective ice glaze. The declared net weight has to exclude the glaze — declaring glazed weight as net weight is a frequent, avoidable labeling violation that inflates the stated weight of the actual product.
Frequently asked
Can I use any common name for a fish species on the label?
No — FDA's Seafood List sets the acceptable market names. An unlisted or invented name can be treated as misbranding.
Do fish and shellfish need allergen labeling?
Yes. Both are major food allergens and must be declared, including when used as an ingredient in a processed product.