Submission to the Review of Food Labelling Law and Policy

The Wilderness Society WA, Inc May 14th, 2010

The Wilderness Society, WA makes the following recommendation to the Review of Food Labelling Law and Policy

·  All imported seafood products must be required to meet the same standards of sustainability as domestic seafood production.

·  Australia’s regulations must be brought in line with other international countries that regulate the import of seafood that has been sourced from Illegal, Unregulated or Unreported (IUU) fisheries eg the European Community and the USA

·  There must be greater transparency of imported seafood products than just country of origin.

Food Standard Code should be changed to

·  mandate compliance with the Australian Fish Names Standard by changing the Food Standards Code 1.2.4 and 2.2.3 to require that all point-of-sale and package labelling of seafood and seafood products to be labelled in accordance with the Australian Fish Names Standard.

The Wilderness Society, WA wants all seafood products to have a fully verifiable chain of custody. Any processed and/or unprocessed seafood product (as in products made of marine animals) sold by fishmongers, wholesalers or retailers to end customers must have clear and easily understandable and readable labelling of the following information:

-  specific common names and scientific name (Latin species name) of each seafood species contained in the product

-  the country of origin for each seafood species contained in the product

-  the production method (‘wild caught’, ‘farmed’ or ‘ranched’) for each seafood species contained in the product

-  if ‘wild caught’ the catch area, as defined by the Food and Agriculture Organisation (FAO) spelled out in words and the name of the stock where each species contained in the product came from (e.g. Georges Bank stock)

-  if ‘wild caught’ the gear type (e.g. trawl) and exact fishing method (e.g. bottom otter trawl or mid-water trawl; purse seining or purse seine with fish aggregation device) used for each seafood species contained in the product

-  if ‘farmed’ or ‘ranched’ whether the species is ‘naturally occurring’ or is a ‘domesticated breed’ or is an ‘introduced species’ in the area where it has been farmed

On request and/ or on the retailer’s website the following information should be made available to consumers:

-  if ‘wild caught’

o  the status of the stock (depleted, lightly exploited, fully exploited, over-exploited), according to scientific body advising the management organisation in charge (e.g. ICES for the stocks managed by the European Union); in case a stock assessment has not been undertaken this should be indicated

o  the identification number (ID) and the flag state of the vessel that caught each seafood species contained in the product

o  the port and country of landing as well as the country of processing for each seafood species contained in the product.

-  If ‘farmed’ or ‘ranched’

o  name or identification number (ID) of farm/ ranch

o  information about the farming/ ranching method:

§  Extensive, semi-intensive, intensive

§  closed/ open system

§  source of broodstock

§  chemical products (pharmaceutics, fertilizers, fungicides etc.) that have been used in the production process

§  composition of feed (species and agricultural sources) and % of fish meal and oil

§  whether feed contained genetically modified organisms (if yes, list which).