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July 10, 2012

Dear Stakeholder in Certification of Seafood,

Over the past decade, numerous seafood certification and eco-labeling schemes have been

developed to provide incentives for sustainable fisheries management and responsible

aquaculture production. During this period, the U.N. Food and Agriculture Organization (FAO)

has published useful guidelines for the creation of seafood certification and eco-labeling schemes,

as well as a Code of Conduct1

to guide fisheries and aquaculture management, supplemented by

a number of independent technical documents. However, the recent use of these FAO

documents as standards for both farmed and wild seafood certification raises serious credibility

concerns.

The undersigned conservation organizations represent diverse views in marine conservation,

with a wide array of perspectives about the degree to which seafood certification can and should

reduce the environmental footprint of fishing and seafood farming practices. Nonetheless, we

have a shared viewpoint on the core elements that any credible seafood certification scheme must

contain. These elements, many of which are captured within the FAO guidance documents,

include:

Transparency: Clear information about the structure of the standard-setting orcertification scheme, how it operates, and how stakeholders can engage with the scheme

must be easily available.

Multi-stakeholder: Standards must be developed through a process that includes asignificant input by a reasonable balance of interested parties on standards, performance

metrics and decision-making processes.

Accurate, Verifiable Claims: The certification program must identify its objectives, andthe claims made about the effectiveness of the program or social or environmental

impacts that derive from the purchase of a product or service are accurate and can be

independently verified.

1 FAO Code of Conduct for Responsible Fisheries (1995); FAO Guidelines for the Eco-labeling of Fish and

Fishery Products from Marine Capture Fisheries, Revision 1 (2009); FAO Guidelines for the Eco-labeling of

Fish and Fishery Products from Inland Capture Fisheries (2011); FAO Technical Guidelines on Aquaculture

Certification (2011).

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Relevant, Measurable, and Objective Criteria: Standards must set measurableperformance thresholds or indicators so that environmental performance can be tracked

and improved over time.

Impartiality and Independence: Verification of compliance with a standard is objectiveand free of conflict of interest. To avoid a conflict of interest, the certified entity cannotbe the standard-setter and/or standard owner, but may participate as a stakeholder.

Complaints and Appeals: Accessible, transparent, and efficient mechanisms are in placeto address complaints about both the certification process and substantive outcomes of

that process.

Learning and Continual Improvement: The effectiveness of the standards system inachieving its stated objectives is assessed with reasonable regularity and procedures are

in place to incorporate new knowledge and information into the system.

In particular, we are concerned that the recent FAO-based Certification of ResponsibleFisheries Management (CRFM) by Global Trust and its pending FAO-based certification of

aquaculture products do not meet the core elements listed above or fulfill the requirements

established within the FAO Guidelines documents themselves. Our primary concerns are:

Lack of transparency There is a substantial lack of clarity surrounding majorgovernance aspects of the Global Trust scheme, including who is the standard setter and

owner, how stakeholder feedback is incorporated and complaints addressed, and how

standards will be updated or revised over time.

Conflict of interest The FAO documents are not themselves certification standards andcannot credibly be used as the basis for certification absent an independent certification

standard created and implemented in compliance with both the substantive and

procedural elements of the FAO Guidelines. While it is unclear who the true standard

setter or scheme owner is in this case, it is clear that it is not FAO. To be considered

independent and credible, both the standard setter and the scheme owner would need both

to be unrelated to the client fishery or industry sector and to conform to the FAO

Guidelines.

Lack of measurable performance-based standards Neither the FAO Code andGuidelines nor Global Trusts use of elements of these documents as standards contain

the measurable performance indicators necessary for a credible certification. At the same

time, the FAO Guidelines are clear that these precise performance elements must be

included for a certification scheme to be credible. Without measurable performance

criteria, the standards are unlikely to produce on the water improvements.

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The attached review, released by the Environmental Law Institute (ELI) today, provides an

extensive review of the significant problems that arise when the FAO guidelines are used as

stand-alone certification standards, exemplified by Global Trusts certification scheme. Based

on our extensive collective experience and knowledge of seafood certification systems, we

believe that companies with commitments to sourcing from credible certification schemes that

meet the FAO guidelines will not be able to meet their commitments by using certification

schemes based on direct use of FAO guidelines and supplementing documents (i.e., Code of

Conduct and the Caddy checklist) as standards. Furthermore, we advise seafood buyers that

utilize FAO guidelines as means of defining their corporate responsibility commitments for

seafood to mandate that certifications address the FAO guidelines in their entirety.

Sincerely,