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 – 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 labeled 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-experts websites, the main comment was: is China actually legalizing some kind of food-fraud?

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 Chinese consumers to refer to salmon.

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 realize that “sanwenyu” is indeed also used in practice to refer also to trout (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.


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 trout to be called salmon because trout is considered similar to salmon”.

Technically, by analyzing the draft standard and the supporting explanation by CAPPMA, this does not seem to be the main point, in our opinion. What is true China is now (if the draft standard will enter into force as such) allowing trout 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….