William Emerson Euro Med TDS

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					                                        William Emerson

                            Fishery Industry Officer, DG Fisheries

                              Food and Agriculture Organization




ECO-LABELLING


Beginning with the FAO Committee on Fisheries meeting in February 1997, the issue of eco-labelling
of fish and fishery products from marine capture fisheries has been discussed on several occasions in
FAO forums. The debate in FAO as well as in other international gatherings was at times
controversial and focussed on four areas of concern, as follows:


      First, the concern that eco-labelling schemes are used or may be used as new forms of barriers
       to trade;
      Second, the scientific basis of certification standards and criteria;
      Third, the potential difficulties for developing countries to participate in such schemes,
       especially the small-scale producers in these countries;
      Fourth and finally, the potential confusion among traders and consumers which may derive
       from the utilization of a number of various and diverse product labels, themselves relating to
       different criteria and standards.

These concerns were also at the forefront of the discussions at the first Technical Consultation on Eco-
labelling of Fish and Fishery Products from Marine Capture Fisheries hosted by the FAO in October
1998. That Consultation was convened by FAO to investigate the feasibility and practicability of
developing non-discriminatory and globally applicable technical guidelines for the eco-labelling of
fish and fishery products. The Consultation developed some valuable guiding principles for eco-
labelling schemes but there was no agreement on what should be FAO’s involvement in the
development of international technical guidelines in this matter.


In parallel to the debate in FAO, several developments have been taking place, all of which aim at
influencing the purchasing behaviour of fish consumers in the context of increasing media attention
towards sustainability issues in marine fisheries. These developments include the appearance of
various schemes of fish purchasing guides on the Internet as well as in other media. At the corporate
level, some large processing, trading and retailing companies have also included sustainability criteria
in their product procurement policies encompassing, inter alia, fish and fishery products.


One of the most noteworthy aspects of these developments is maybe the recent expansion of fishery
production covered by the scheme of certification and eco-labelling under the Marine Stewardship
Council (MSC). This expansion is the result of three major fisheries having become certified by the
MSC, namely Alaska salmon in September 2000, New Zealand hoki in March 2001 and South
African Hake Trawl Fishery in April 2004. Notable are also the MSC certification of small volume
but high value fisheries, namely the Western Australian Rock Lobster fishery and the Red Rock
Lobster fishery of Baja California, Mexico. The latter is the first small-scale developing country
fishery certified by MSC.


We may observe thus an increasing responsiveness of consumers and intermediaries – processors,
traders and retailers – in the major fish importing countries to sustainability and environmental issues.
This has prompted many FAO members to request FAO to advance the process of the development of
international guidelines on eco-labelling through the holding of an expert consultation. The draft
Technical Guidelines prepared by the Expert Consultation were submitted to the COFI Sub-
Committee on Fish Trade which met earlier this year in Bremen.


The Sub-Committee was satisfied by the work that had been accomplished. It noted the benefits which
fisheries managers, producers, consumers and other stakeholders may derive from internationally
agreed and widely accepted and applied guidelines that ensure the credibility and trustworthiness of
voluntary eco-labelling schemes for fish and fishery products. The Sub-Committee stressed that such
eco-labelling schemes needed to be transparent, market-driven and non-discriminatory, based on best
available scientific evidence, not create obstacles to international trade, allow for fair competition and
respect the sovereign rights of States.
Finally the Sub-Committee recommended that FAO to further elaborate the work of the
Expertorganize a Technical Consultation Consultation and finalize the draft guidelines for their
consideration by the Twenty-sixth Session of COFI in February 2005.


The Technical Consultation was held in Rome in October of this year. The Consultation recognized the
benefits of internationally agreed guidelines aimed at avoiding the misuse of eco-labelling schemes
through, inter alia, preventing them becoming barriers to trade.

The Technical Consultation achieved much progress during the meeting and completed one of the two
parts of the draft guidelines. This part contains the procedural and institutional aspects of eco-labelling
schemes. The Consultation nevertheless acknowledged that more work was still necessary on the part of
the Technical Guidelines dealing with the provisions on terms and definitions and the minimum
substantive requirements and criteria.

It was also understood, for the purpose of reaching consensus on the document, that the draft
guidelines should be considered as a whole since the two parts are closely linked. For that reason, the
Consultation recommended that a two days meeting should be convened immediately before the next
session of COFI, notwithstanding the possibility of further negotiations during COFI itself. I will now say
some words about traceability.



TRACEABILITY

In the fish industry, traceability can relate to:

          the origin of raw materials and ingredients
          the handling and processing history
          the distribution and location of the product after delivery.
Traceability was recently defined by the Codex Alimentarius as “the ability to follow the movement of a
food through specified stages of production, processing and distribution ” (Codex Alimentarius 2004).

Interest in traceability in food processing has been increasing in recent years, primarily because of the
different crisis in the food sector such as the mad cow disease (BSE) in 1996 in the UK and the dioxin
contamination in Belgium in 1999. Authorities have focused on traceability to assure consumer safety,
to be able to re-call defective/hazardous products and to identify the source of the problem.

As the food chain has lengthened from local production, processing and consumption to more global
commercial opportunities, the need to transfer information related to production and public health and
the complexity of these transfer vehicles have expanded. For example, over 1000 fish species are
marketed in the EU and over 800 in the USA. With the increase in complexity, the consumer wishes to
be fully informed about fish species, place, condition of rearing or catch, handling, transformations and
the distribution of the food products they consume. Likewise, many foods are labelled to provide
nutritional and dietary information to the consumers. This type of nutritional labelling is presently
mandatory in many countries.

Of particular relevance to the Mediterranean region are the EU’s 2002 Regulatory Traceability
requirements (Art 18 of Regulation (EC) No 178/2002). I will now briefly go over some of the key
features of the EU regulations to give you a feeling for their requirements:

“2. Food and feed business operators shall be able to identify any person from whom they have been
supplied with a food, a feed, a food-producing animal, or any substance to be, or expected top be,
incorporated in a food or feed”;

“3. Food and feed business operators shall have in place systems and procedures to identify the other
business to which their products have been supplied. This information shall be made available to the
competent authorities on demand”;

“4. Food or feed which is placed on the market or is likely to be placed on the market in the Community
shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or
information in accordance with the relevant requirements

The Regulations also include responsibilities for business operators, in particular:

“1. If a food business operator considers … that a food … is not in compliance with the food safety
requirements, it shall immediately initiate procedures to withdraw the food in question from the market
… and inform the competent authorities thereof. …”; and

“1. (cont) … the operator shall effectively and accurately inform the consumers of the reason of its
withdrawal, and if necessary, recall from consumers products already supplied to them…”

These requirements will carry different obligations depending on which sector of the fishing industry we
are considering. In the case of aquaculture, for example, the origin of the feed products is of critical
importance. In the case of live bivalves it will be important to identify the area where they were
harvested and the quality of the water in that area. For wild caught fisheries it will be important to
monitor its trail from point of harvest to the final consumer.

From a company perspective, traceability may be advantageous. It allows different raw materials to be
directed to production of different categories of product. It subsequently allows the company to
determine if yield, quality, or safety of a particular category was related to a particular raw material or a
particular ingredient. In fact, a form of traceability is required for a HACCP system to be implemented.

With traceability, the whole chain from vessel to retailer can be managed in a more effective way, when
the traceable information is used actively to enhance mutual trust and cooperation between
stakeholders of the various steps in the overall food chain. Significantly less time (and resources) can be
spent on quality checks and storage, and when recalls are to be carried out, traceability is an assurance
that the company limits the loss, and protect its image on the market.



CONCLUSION
Certification and labelling requirements are increasingly important competitive parameters to consider
when accessing international fish markets. Not only must processors and exporters adhere to the
regulatory requirements of importing countries, but additional labels or certificates may also be
required by the importer for commercial and marketing reasons. In the same way, the producer or
exporter may also choose to apply particular labels or undergo voluntary certification programmes in
order to target specific segments of consumers, thereby gaining a competitive advantage.
Overall, it is expected that labels testifying to specific qualities and attributes regarding product content,
production process, geographic indication or other environmental considerations will increase their
importance in the marketplace, especially in response to consumers' concerns about food safety,
species           sustainability          and          other           environmental           considerations.

				
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