A newly released scientific paper, “Food-grade phosphates in the Seafood Industry: technological functions, quality, safety, and integrity implications,” Gonçalves & Fernandes (2025) arrives at a pivotal moment for Brazil’s fishing and aquaculture sector — and for seafood consumers more broadly. While the subject of phosphates may sound technical, its implications go directly to issues consumers care deeply about: product quality, honest labeling, food safety, and trust in the seafood supply chain.

From a Seafood Consumers Association (SCA) perspective, this paper is important because it does not frame phosphates as either “good” or “bad,” but rather as powerful technological tools that must be used transparently, proportionately, and under effective regulatory oversight.

Why phosphates are used — and why that matters

Phosphates perform several legitimate and well-established technological functions in seafood processing. As outlined in the paper, they can improve water-holding capacity, stabilise muscle proteins, enhance texture, reduce oxidation, and improve product performance during freezing, thawing, and cooking. These functions are particularly relevant for frozen fillets, molluscs, and crustaceans — products increasingly relied upon for affordable protein and food security.

When used correctly, phosphates can reduce waste, improve eating quality, and support efficient processing, benefiting both producers and consumers. From a consumer standpoint, better texture, less drip loss, and consistent cooking performance are tangible quality outcomes.

However, technological benefit alone is not sufficient justification. Consumers are not simply buying performance — they are buying what they believe the product to be.

Where consumer risk emerges

The paper clearly identifies the central risk: misuse or fraudulent application of phosphates. Excessive or undeclared use can artificially increase product weight, mask poor raw material quality, or disguise inadequate processing practices. In these cases, consumers may unknowingly pay for added water rather than seafood or receive products that do not match their expectations or labeling claims.

This is not a theoretical concern. Globally, phosphate misuse has been linked to economic fraud, misleading labeling, and erosion of trust in frozen seafood categories. For consumers, this undermines confidence not only in individual products, but in entire supply chains — including those that operate responsibly.

From the SCA perspective, integrity failures by a minority damage the credibility of the majority.

The significance of Brazil’s updated regulation

The paper rightly highlights the importance of Anvisa’s Normative Instruction No. 380/2025, which modernises Brazil’s regulatory framework by clearly authorising phosphates for specific seafood categories while establishing technological limits. This is a critical development.

Clear rules matter to consumers because ambiguity creates enforcement gaps. By defining what is permitted — and within what limits — regulators enable better compliance, more consistent inspection, and stronger accountability. Importantly, such frameworks also protect responsible processors from unfair competition by those who cut corners.

For consumers, modern regulation aligned with science is not about permissiveness; it is about clarity, fairness, and enforceability.

The role of inspection and science

The paper emphasises the essential role of Federal Agricultural Auditors (AFFA) in Brazil, whose technical expertise underpins risk-based inspection and fraud prevention. From a consumer viewpoint, this role cannot be overstated.

Effective consumer protection depends on inspectors having access to:

              •            Up-to-date scientific knowledge

              •            Robust analytical tools to distinguish natural from added phosphates

              •            Clear regulatory benchmarks

              •            Strong institutional support

Without these, even the best rules remain theoretical. The SCA strongly supports inspection systems that are science-led, independent, and adequately resourced, as they are the frontline defence against mislabeling and economic fraud.

In Australia, the use of phosphates in seafood is strictly governed by Food Standards Australia New Zealand (FSANZ) under the Australia New Zealand Food Standards Code (Standard 1.3.1 - Food Additives). While phosphates are legally permitted to improve moisture retention and texture, the Australian regulatory landscape focuses heavily on preventing "economic fraud"—the practice of using excessive water-binding agents to artificially inflate the weight of a product.

Regulatory Situation in Australia

  • Permitted Use: Phosphates (such as sodium tripolyphosphate) are authorized for use in "unprocessed" and "processed" fish and fish products, but only at levels necessary to achieve a technological function, such as preventing drip loss during thawing.
  • Labelling Mandates: Any phosphate added to seafood in Australia must be clearly declared in the ingredient list by its functional class (e.g., "Humectant" or "Thickener") followed by its specific name or international code number (e.g., "Sodium tripolyphosphate" or "451").
  • Import Surveillance: The Department of Agriculture, Fisheries and Forestry (DAFF) regularly monitors imported seafood—particularly prawns and white fish fillets—to ensure they do not exceed the prescribed limits or contain undeclared additives that might mislead the consumer regarding the product's quality.

Specific Issues in Australia

The debate in Australia mirrors the global struggle between "quality enhancement" and "economic integrity":

  1. "Weight Laundering" vs. Quality: A major issue is the use of "soaking" treatments where seafood is left in phosphate baths longer than necessary to increase yield. This is often viewed as economic fraud by the SCA, as the consumer ends up paying for "expensive water". 
  2. The "Natural" vs. "Added" Conflict: There is ongoing debate regarding how to distinguish between naturally occurring phosphorus (found in all muscle tissue) and added food-grade phosphates during testing. This makes it challenging for regulators to enforce strict limits without more robust analytical methods.
  3. Consumer Perception & "Clean Label" Trends: Similar to the Brazilian concept, Australian consumers are increasingly moving toward "clean label" products. This has led to the rise of "Phosphate-Free" seafood in premium retail markets, marketed to consumers who perceive additives as a compromise to the "clean and green" reputation of Australian seafood.
  4. Health Considerations: While not a widespread public health crisis, excessive phosphate intake is a growing concern for individuals with chronic kidney disease. The SCA advocates for clearer "added phosphorus" disclosures to help these vulnerable populations manage their dietary intake.

In summary, while the Australian system may appear to be robust in its safety testing, the SCA believes the real frontier for reform is in transparency—ensuring that the use of humectants is a choice made by the consumer at the counter, not a hidden cost baked into the weight of the fillet.

 

Transparency is the consumer bottom line

Consumers are not opposed to food technology. What they oppose is being misled. The strategic, declared, and compliant use of phosphates — clearly reflected in ingredient lists and aligned with regulatory limits — allows consumers to make informed choices.

This is particularly important for vulnerable populations, including people managing kidney disease or other health conditions who may need to monitor phosphate intake. Transparency is therefore not just an economic issue, but a public health responsibility.

Looking forward: building trust, not just yield

The future perspectives outlined in the paper — improved analytical methods, stronger traceability, tighter benchmarks, and closer integration between science and inspection — align closely with SCA principles.

Sustainable seafood is not defined solely by environmental performance. It also requires honesty, accountability, and respect for consumers. Technological tools like phosphates can support sustainability and food security — but only when embedded within systems that prioritise integrity over short-term gain.

A shared responsibility

This paper is a timely reminder that consumer trust is fragile and hard-won. Regulators, inspectors, processors, scientists, and retailers all share responsibility for ensuring that technological advances serve the public interest.

From the Seafood Consumers Association perspective, the message is clear:

phosphates are not the problem — opacity, misuse, and weak enforcement are.

With strong science, clear rules, and transparent practice, Brazil’s seafood sector can demonstrate that innovation and consumer trust are not competing goals, but complementary ones.

We encourage all stakeholders — including consumers — to engage with this important paper and the conversations it supports.

If you are at a fresh seafood counter, you can often identify phosphate-treated products by their appearance: "wet" scallops or fillets will often appear unnaturally white or translucent and may sit in a milky liquid. Untreated "dry" seafood tends to have a more cream-colored, opaque appearance and will not leak excessively when cooked. There are no signs to suggest phosphate free – if in doubt as your Fishmonger.

 

NOTE: Dr. Alex Augusto Gonçalves is a SCA Advisory Council Member

 

References

https://medcraveonline.com/MOJFPT/MOJFPT-13-00331.pdf