Trout is sold as salmon. Plain green tea is sold as matcha. Both are examples of the same underlying practice: misrepresenting what a product actually is. Food misrepresentation is a serious problem that can mislead consumers. When one product is sold as another, the issue is not just a harmless substitution but a misleading practice that can affect trust, safety, and fair competition.
According to, Article 12 of Cambodia's Law on Consumer Protection prohibits businesses from making misleading representations regarding the type, classification, quality, or composition of goods. Selling one product under the name, and at the price of another falls within this prohibition. The law does not require proof of intent to deceive, only that the representation made to the consumer was false. This is why the common defense, that the substitute is "basically the same," so the issue is minor, does not hold. Article 12 makes no exception for substitutes considered similar to the genuine product; a false representation of composition or classification falls under the law regardless of how close the substitute is to the original.
What makes this more than a labeling technicality is that consumers cannot always protect themselves from it. In cases such as plain tea sold as matcha, a more informed buyer may be able to spot inconsistencies through ingredient information and taste. But in cases such as farmed trout sold as salmon, the substitution generally cannot be identified without laboratory testing, no matter how careful or informed the buyer is. This is precisely why consumer awareness alone cannot resolve this category of misrepresentation, and why inspection and enforcement are necessary.
The enforcement role belongs to the Consumer Protection, Competition and Fraud Repression Directorate-General (CCF), under the Ministry of Commerce, which maintains complaint offices in every province. The agency already has the authority and capacity to act. According to The Phnom Penh Post, CCF reports seizing more than 1,000 tones of counterfeit consumer goods each year, including food and beverage products, and its director-general has stated that the public can report suspected cases directly to the agency.
However, CCF’s public communication on consumer complaints appears limited, particularly on social media, even when complaints are supported by visible evidence. This year’s durian controversy, in which imported durians were allegedly marketed as locally grown products, raised fresh concerns about CCF’s effectiveness in protecting consumer rights and responding transparently to public complaints. Following public criticism and comments from Senate President Hun Sen, a senior CCF official in Battambang was removed from his position, reinforcing public perceptions that enforcement actions may at times be driven more by political pressure than by the agency’s legal mandate and responsibilities.
The latest salmon case raises a similar concern. It began with an investigation into unsafe frozen and imported meat products from Thailand, but public attention shifted after an officer accidentally posted a photo showing a trout box inside a shop that had long promoted the product as salmon. Choronai has since admitted that trout was indeed involved, yet CCF has remained silent and has not provided any public update regarding to its decision. This silence matters because the issue is no longer only about one shop or one product. Beside Chroronai, there are still more seller promoting salmon with trout box.
Now, it is about whether consumers can trust that the agency responsible for
protecting them will respond clearly, consistently, and publicly when business misconduct is exposed.