Andre Leu
Chair PO Box 800 Mossman, Qld 4873 61 (0) 7 40987610 leu@austarnet.com.au
17-11-05
Cover Letter to The National Organic Mark Discussion Document Consumers are finding the plethora of different logos and labels very confusing. There are seven logos for genuine certified organic products and numerous logos and labels for free range, eco, natural, low GI, heart ticks, etc, etc. To end this confusion industry stakeholders held a series of meetings under the auspices of the Australian Quarantine Inspection Service (AQIS) and agreed to adopt one national regulatory mark for certified organic products in May 2004. This national regulatory mark is voluntary and can be used in conjunction with the certifiers’ logos. Several of the certifiers have begun the process of encouraging their producers to use this mark on their certified products. Consumers are starting to see it appear in retail outlets. There has been discussion in the organic sector that the wording and design of the mark should be changed. The OFA, as the peak body, has started a consultation process with all sector stakeholders on the possibility of a new design. The following document gives a list of options for consideration. Until the organic sector clearly states that there is a need for a new mark the OFA will continue to support the current status quo. That is the AQIS regulatory mark and the logos of the seven AQIS accredited certifiers.
Yours Sincerely,
Andre Leu Chair Organic Federation of Australia
Andre Leu, Chair Organic Federation of Australia November 05
Organic Federation of Australia
National Organic Mark Discussion Document
For Public Comment 20-10- 05. Comments to be received by Feb 16 2006 Chairs meeting. Paper to: Paper from: Nov 2005 Re: The Issue of the National Logo Purpose of the Paper: This paper’s purpose is both to stimulate discussion, and to seek broad ranging feedback, from the Advisory Boards, as to how the OFA Board should proceed in respect to the issue of a National Logo (on behalf of the organic industry). Manner and Method of Consultation: Given that this is the first time that the newly constituted OFA Board has consulted with the Advisory Boards, it is appropriate that some ground rules be established, although these may be amended when the intended paper on OFA governance and protocols is released for consultation. Consultation will always occur on major matters of policy, and therefore those policy issues must be considered very carefully by the Advisory Boards. It is expected that the Advisory Boards will canvas wide ranging views from their respective constituencies, to the extent that is practicable and possible. The OFA Board would be pleased to ask that, in responding to this issue, the Advisory Boards do so in writing, and also advise the extent of consultation that has occurred. The style of the OFA papers on major policy matters will be to set out a number of options for consideration by the Advisory Boards. The paper will also indicate where OFA’s preference lies and why, but that preference will not put it as a formal recommendation at this stage, prior to consultation. The final decision will rest with OFA Board, but it will take well considered and well thought out propositions from the Advisory Boards seriously, and it is very possible, on major policy matters, that there will be more than one round of consultation to ensure we reach a well considered industry view, that has broad currency within all sections of industry. However, it is not expected that there will always be full agreement on every issue, and eventually a decision will have to be made by the Board on behalf of industry; the key issue is that all sections of industry will have had a voice in the formulation of major policy matters. It is expected that Advisory Board members, who are also OFA Board members, will participate in the consultation process, but will allow other members of the Advisory Boards to lead the discussion. This is to ensure that the widest possible views are canvassed, rather than the consultation process being viewed as a lobbying exercise for a particular outcome by OFA Board members. The Issue of the National Logo: Overall Summary The case has been put by a number of parties within the industry that, due to the number of domestic certifying logos that currently exist in Australia, there is considerable confusion in consumers’ minds as to what they can purchase with confidence as genuinely organic products. This situation is exacerbated by; The existence of different certifying marks on imported products. The fact that consumers cannot clearly tell, in all cases, whether a product is an Australian certified organic product or an imported certified organic product (and this is becoming much more important in the context of country-of-origin labelling). The international reciprocity between Australian certifiers and a number of their counterparts, which brings additional certification marks into Australia. Clinton Starr, Deputy Chair, Organic Federation of Australia Nov 05 2 The Chairpersons of the Advisory Boards to the OFA The OFA Board: Author Clinton Starr
Organic Federation of Australia
National Organic Mark Discussion Document
The absence of domestic legislation which allows the generic use of the word organic without any requirement for a certification mark.
To date the Government has been disinclined to legislate in respect to the use of the word organic and what that word imports for consumers. Because of this situation, and the growing importance of the organic market, the case has been put that the industry should unite behind a national logo, which would reduce consumer confusion, increase consumer confidence, and potentially increase the sales of organic products in Australia. A current proposal exists to adopt the “orange ball” style AQIS logo which, to date, has been applied to export products only. This is a recent proposal. Countered against the proposition for a national logo are a number of important considerations for the industry to consider. In summary they are; A certifiers’ logo/mark currently has added financial value to its user, and provides some rationale to consumers to pay a premium for certified product; ie there is an important dimension of financial gain/loss in its use. The Australian certified organic industry has grown up under a number of logos/marks, and the members of those organisations have expended considerable sums to develop and protect those marks. It is an intrinsic part of their intellectual property, even if not explicitly included in their balance sheet assets. The use of the certifiers’ logos/marks is a function of an ongoing auditing process and a legally enforceable licence agreement; there are specific penalties for misuse of the certifiers’ marks, and a specific process which controls their adoption/removal. A national mark or logo must have widespread support, some marketing spend behind it, and some regulatory “teeth”, if it is perceived to have value by consumers and the industry. This begs the question of who effectively owns the mark, who is going to spend money on it, and how is its use to be regulated? There is also the issue of yet another mark in the market, which has the potential to further confuse consumers, the opposite of what is intended. It is almost inevitable that, without legislation, the mark would have to be voluntary, because there would be no legal mechanism to enforce its usage, or cause it to be withdrawn if misused or misapplied. The Success Criteria for a National Logo It would therefore appear that there are a number of success criteria if there is going to be a national organic logo (and, for the moment, this leaves aside the issue of possible domestic legislation). The solution has to have widespread support within industry. It must avoid further consumer confusion, as far as is possible. To the contrary, it should help consumers in their shopping choices. It should not increase costs to industry unreasonably. It should have clear ownership, and be capable of being promoted. It should have design integrity, and be considered an attractive memorable design by consumers. There has to be some form of regulation over it use, even if not under the fiat of legislation, which extends at least to misuse and misapplication. It should not detract from the value of Australian certifiers’ existing marks and their investment in those marks. To the extent possible it should reinforce the existing marks and their position in the Australian market. It should clearly identify any product as an Australian certified organic product, rather than imported. OFA Board Discussion and Current View The new OFA Board considered the issue of the national logo at its inaugural Board meeting on 18 th August. Beyond deciding that the issue of the national logo was of such importance that it should be open to wide consultation, the Board also considered a proposal to deal with the issue of the logo.
Clinton Starr, Deputy Chair, Organic Federation of Australia Nov 05
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Organic Federation of Australia
National Organic Mark Discussion Document
The Board decided that this proposal, as broadly outlined below, was its preferred option, subject to further consultation with the Advisory Boards, and the possibility of other options arising that had not been canvassed to date. The OFA Board’s position is that this issue has to be debated thoroughly to give the resultant decision legitimacy, and to allow for the possibility of other solutions to emerge. The OFA Board’s Current Position in respect to the National Logo Issue
The OFA board supported the AQIS regulatory mark because it was agreed to by the OIECC meeting in May 2004 and as such it is the only mark that is accepted by certifiers. Two certifiers have indicated that they will introduce it. However since that board agreement it has emerged that the AQIS regulatory mark solution is not currently preferred by many in industry because:
The design has not been well received by retailers, wholesalers, consumers and some certifiers. It introduces another logo/mark, and thus has the potential to increase confusion, it is not “owned” by the industry, and it compromises the existing certifiers’ logos/marks and their investment to date. The OFA board is currently considering the following as a preferred option: A “blended mark”; ie a unique design that can appear together with all certifiers’ logos/marks, in the form of a watermark, that identifies the product and the certifier as being under the auspices of the Organic Federation of Australia. The watermark would be designed specifically to complement all the existing certifier’s marks/logos. Features of the blended mark/watermark would broadly be; o It would only appear with a members’ certifying mark; never on its own. o It could only be used by certifiers who are members of the OFA. o It could also be used with a certifiers’ general mark (eg BFA, NASAA), as distinct from the specific certification mark, if they are different companies, and provided the organisation is a member of the OFA, (and all Australian certifiers would be encouraged to join the OFA, as has always been the intent). o OFA would make a modest charge for the use of the watermark to be used to explain to consumers the significance and meaning of the mark for all Australian certified products. o The other theme of the campaign would be to explain to consumers that the presence of the watermark, with the certifiers, mark/logo, is their best guarantee of buying a quality Australian certified product, and they should always look for the combination as their best protection. o The use of the mark would be voluntary, but the Board of the OFA and the Certifier’s Advisory Board would strongly encourage support for the blended mark, with the further support of the other Advisory Boards. Advantages of the Blended Mark Solution Enhances, and does not detract from, existing certifiers’ marks/logos. Helps domestic certifiers distinguish themselves from their overseas counterparts in the minds of consumers. Unifies the Australian industry in a non adversarial manner, without devaluing the work done to date, and the value imbued in existing marks/logos. Is a low cost solution in adoption and administration. By always appearing with a certifiers’ logo/mark, automatically deals with the regulatory regime. Through the modest charge for its use, encourages that use by being modest, but also provides some funds to explain to consumers what they should be looking for, particularly in the context of country-of-origin labelling. Is an appropriate solution under a minimal legislation model. Provides an opportunity to be very innovative in design terms, given that the watermark must enhance the existing certifiers’ logos/marks. Options for Consideration This is not meant to be an exhaustive list; it is here it act as a stimulus to discussion and debate; Leave the position as it is but, rather than adopting a national logo, spend more marketing dollars on promoting the existing certifiers’ logos/marks to Australian consumers, possibly using the OFA as the promoting vehicle on behalf of all its members. Clinton Starr, Deputy Chair, Organic Federation of Australia Nov 05 4
Organic Federation of Australia
National Organic Mark Discussion Document
Agree that the industry needs to deal with this issue at some stage, but it is not as important as the issue of the domestic standard and possible legislation, and that consideration of a national logo should be postponed until those issues are resolved (also given that the issue of a national logo might be affected by legislation). Adopt the existing AQIS Orange Ball logo to be positioned alongside the certifiers’ marks/logos. Adopt a completely new logo that stands on its own, and is not a blended mark, perhaps with ownership or some other form of control by the existing certifiers or the OFA, or both.
There are clearly advantages and disadvantages to all of the above options; and it is not intended to include those in this paper, for reasons of length. The OFA Board now asks that Advisory Boards to give this important matter their attention, and provide the Board with well considered feedback. OFA Board August 2005
Clinton Starr, Deputy Chair, Organic Federation of Australia Nov 05
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