SupplierRadar

FDA refusal charge

FDA refusal charge SUBSTITUTE

Appears that a substance has been substituted wholly or in part for one or more of the article's ingredients.

SUBSTITUTE is the FDA import refusal charge for appears that a substance has been substituted wholly or in part for one or more of the article's ingredients.; it cites sections 402(b)(2) and 801(a)(3) of the FD&C Act (adulteration). FDA recorded it on 56 refused shipment lines between October 2016 and May 18, 2026, most often for sweeteners from Mexico.

Data from FDA public records, last checked .

56
refused shipment lines carry this charge
14
countries of origin
1
import alert names this charge

What SUBSTITUTE means

SupplierRadar has not written a plain-English version of SUBSTITUTE yet. FDA's own statement is quoted below.

FD&C Act section
402(b)(2)801(a)(3)
Classification
adulteration

FDA's official statement

Copied unchanged from FDA's Refusal Charges reference table.
The article is subject to refusal of admission pursuant to Section 801(a)(3) in that it appears that a substance has been substituted wholly or in part for one or more of the article's ingredients.
SUBSTITUTE · 402(b)(2), 801(a)(3); ADULTERATIONFDA reference table (CSV)

Import alerts that name SUBSTITUTE

The charge section of each alert names this code. An alert lists firms; a charge is the reason recorded on one refused line.
Import alerts naming SUBSTITUTE as a charge
AlertCoversRedGreen
99-47Foods that appear adulterated for economic gain52

Countries with the most SUBSTITUTE refusals

Shipment lines carrying SUBSTITUTE, by country of origin.
SUBSTITUTE refusal lines by country
CountryLinesShare of SUBSTITUTE
Mexico1425%
Spain713%
India611%
Italy59%
Vietnam47%
Yemen47%
Armenia35%
Dominican Republic35%
Thailand35%
Turkey24%

Product categories with the most SUBSTITUTE refusals

SUBSTITUTE refusal lines by product category
CategoryLinesShare of SUBSTITUTE
Food Sweeteners (Nutritive)3868%
Fruit and Fruit Products (berries, citrus and core fruits)916%
Spices, Flavors, and Salts59%
Milk, Butter, and Dried Milk Products12%
Fruit and Fruit Products (pit, subtropical and tropical fruits)12%
Fruit and Fruit Products (vine and other fruits)12%
Color Additives for Foods, Drugs, and Cosmetics12%

Latest SUBSTITUTE refusals

The 20 most recent refused lines, through May 18, 2026, each with its FDA source.
Latest FDA refusals carrying SUBSTITUTE
DateFirmProductCharges
AndSisian, ArmeniaHoneySUBSTITUTESource
Empacadora de Miel GdlGuadalajara, MexicoImitation syrups, molasses and honey, n.e.cSUBSTITUTESource
Empacadora de Miel GdlGuadalajara, MexicoImitation syrups, molasses and honey, n.e.cSUBSTITUTESource
Navarro'S Company Sa De CvGuadalajara, MexicoSyrups and molasses, n.e.cINCONSPICUSUBSTITUTENUTRIT LBLSource
MAG Meghvabucakan EnkerutyunArmavir, ArmeniaHoneySUBSTITUTESource
MAG Meghvabucakan EnkerutyunArmavir, ArmeniaHoneySUBSTITUTESource
AmulFed Dairy (Previously known as Mother Dairy) - A Unit of GCMMF LtdGandhi Nagar, IndiaButter oilFALSESUBSTITUTESource
Navarro'S Company Sa De CvGuadalajara, MexicoHoneySUBSTITUTESource
Navarro'S Company Sa De CvGuadalajara, MexicoHoneySUBSTITUTESource
Navarro'S Company Sa De CvGuadalajara, MexicoHoneyINCONSPICUFALSESUBSTITUTE+1Source
L. Dometita & Sons Food IndustriesQuezon City, PhilippinesSaffron, whole (spice)SUBSTITUTECOLOR LBLGYELLOW #5Source
Fang Yuan F&B International Co.,LtdTaichung City, TaiwanLemon, citrus fruit juices or concentratesSUBSTITUTESource
New King Export For Local and Agricultural ProductsSanaa, YemenHoneySUBSTITUTESource
The Harvest Of Saffron, S.L.La Solana, SpainSaffron, ground, cracked (spice)SUBSTITUTEOMITTEDSource
Empacadora de Miel GdlGuadalajara, MexicoHoneySUBSTITUTESource
Empacadora de Miel GdlGuadalajara, MexicoHoneySUBSTITUTESource
Empacadora de Miel GdlGuadalajara, MexicoHoneySUBSTITUTESource
Empacadora de Miel GdlGuadalajara, MexicoHoneySUBSTITUTESource
Kinglike Catering Trade Int'L ColtdKaohsiung, TaiwanLemon, citrus fruit juices or concentratesSUBSTITUTELACKS N/CSource
Baloglu Gida Tarim Urun. Akar. Mot. Arac.Salihli, TurkeyLemon, citrus fruit juices or concentratesSUBSTITUTESource

Questions about SUBSTITUTE

What does SUBSTITUTE mean on an FDA refusal?
SUBSTITUTE is the refusal charge “Appears that a substance has been substituted wholly or in part for one or more of the article's ingredients.”. FDA's official statement for the charge reads: “The article is subject to refusal of admission pursuant to Section 801(a)(3) in that it appears that a substance has been substituted wholly or in part for one or more of the article's ingredients.”
What law does SUBSTITUTE cite?
FDA's refusal charge table cites sections 402(b)(2) and 801(a)(3) of the FD&C Act (adulteration) for SUBSTITUTE, and classifies the charge as adulteration. The table is the Refusal Charges reference file that FDA publishes with its Data Dashboard.
Which countries have the most SUBSTITUTE refusals?
As of October 25, 2026, the countries with the most SUBSTITUTE refusal lines are Mexico (14), Spain (7) and India (6). The full list with links is in the table on this page.
Is there an FDA import alert for SUBSTITUTE?
Yes. One FDA import alert names SUBSTITUTE as a charge code, including Import Alert 99-47 (Foods that appear adulterated for economic gain). An import alert is a list of firms; a charge code is the reason recorded on one refused shipment line.

Built for the person who signs the FSVP file

Look before you order.

Check up to five suppliers against every FDA record in one paste, no account needed. Watch the ones you buy from and get the source the day a record changes.

SupplierRadar is not affiliated with the U.S. Food and Drug Administration. Data comes from public FDA records and may contain errors. This is not legal advice; importers remain responsible for their supplier evaluations.