Species substitution — labeling lower-value Illex argentinus (shortfin squid) as the more prized Loligo species — is a documented issue in the frozen squid trade. FDA's seafood import surveillance includes species verification testing. Importers can mitigate risk by requiring species-level documentation from suppliers, conducting third-party DNA testing on incoming lots, and maintaining robust supplier verification programs under their HACCP plans.

Flours, meals, and pellets of cuttlefish, squid, and octopus are included in this heading only when fit for human consumption. The processing method (grinding, drying, pelleting) and the intended end use must be documented on the commercial invoice. Feed-grade cephalopod meal would be classified under a different heading, so the human-consumption designation is a critical classification determinant.