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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,
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