GoldFish: the EU's coordinated action on illegal water addition and other types of fraud

Published by SIPA

Announced in January 2024, the EU’s GoldFish coordinated action aims to combat seven fraud categories:

  • undeclared or mis-declared glazing
  • undeclared or mis-declared water addition
  • undeclared or mis-declared authorised use of additives
  • undeclared or mis-declared unauthorised use of additives
  • undeclared or mis-declared addition of proteins and hydrolysed proteins
  • carboxymethyl cellulose injected into shrimps
  • mis-declared breading

A European Commission representative shared the aims of GoldFish during a Market Advisory Council (MAC) meeting on 30th January 2024. Very little new information has been released since that date. This is what we know:

Market Advisory Council minutes

This information is available from the minutes of a meeting of the MAC held on 30th January 2024. During that meeting, Mr Paul Roquiny of DG SANTE explained that shortweighting occurs when a processor misrepresents the weight of a fishery or aquaculture product by including weight gained through practices such as overglazing, soaking, and breading in addition to the net weight of the product. Mr Roquiny identified crustaceans and fish as the wild catch and aquaculture products that provide the highest number of cases of suspected fraud.

In the time since these remarks were made at the MAC meeting, there has been no new information on GoldFish. The topic appeared as an item on a MAC meeting draft agenda scheduled for 1-2 December 2025, but the item was removed from the final agenda. According to FRUCOM:

‘As a justification, the Commission informed MAC that they were “unable to provide detailed information on the sampling plan, species selection, methods, sample presentation, and the specific conclusions of the action, as this data is considered internal at the moment.” The Commission assured that they will report to MAC “whenever necessary and whenever possible (in course of year 2026)” and proposed holding further discussions once Goldfish had been concluded.’

Notifications in the monthly reports on EU Agri-Food Fraud suspicions

Over the past months, Germany and Romania in particular have been very active in carrying out checks for “water addition” and related types of fraud. The results do not appear as RASFF notifications, but they show up in the “Monthly reports on EU Agri-Food Fraud suspicions”. It is not clear whether this activity is related to GoldFish, but the reported issues cover at least one of the seven fraud categories that are meant to be targeted.

I have looked at the monthly reports from January 2025 to March 2026 and extracted all the “water addition” and “lower protein” findings. You can see them in the attached spreadsheet.

Note that the number of water addition/lower protein fraud suspicions has been increasing: 8 in the first half of 2025, 20 in the second half of 2025 and 28 in January to March 2026.

I prepared a second table on the same spreadsheet listing all the fraud suspicions of incorrect net weight or undeclared glaze. There are 11 of these, none in the first half of 2025. Ten of them were notified by Germany or Czechia.

A peer-reviewed study published in Deutsche Lebensmittel-Rundschau concluded that the degree of processing significantly affects the water/protein ratio of shrimp. You can read more on this here:
Study on water-to-protein reference values in warm water shrimp: a summary.

EU Fraud Suspicions (water addition)
2026-05-10WaterAdditionEUFraudSuspicionsJan25-Mar26-1.xlsx
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