Country of origin labelling for seafood in hospitality settings: information standard and explanatory statement

Consultation submission on
Country of origin labelling for seafood in hospitality: Information Standard and
Explanatory Statement

Australian Marine Conservation Society and TRAFFIC
8 April 2025

Contact:
1. Introduction
The Australian Marine Conservation Society (AMCS) is Australia’s peak marine conservation organisation, representing around 300,000 people from all around the country.
For 60 years, we have used scientific research, policy advocacy, community engagement, and education to protect and restore Australia’s oceans.

TRAFFIC is a leading non-governmental organisation working globally on trade in wild animals and plants in the context of both biodiversity conservation and sustainable development. TRAFFIC generates evidence, analysis, and solutions to strengthen global and national policy frameworks, and build responsible and fair supply chains. Its team of over 180 staff around the world works in and connects across some of the world’s most critical wildlife trade hotspots. TRAFFIC has worked on fisheries issues within Australia for
32 years.

AMCS and TRAFFIC are key members of a group of conservation and human rights organisations and local seafood industry members who are campaigning for stronger seafood import controls, traceability and labelling.

Thank you for the opportunity to respond to the Country of Origin Labelling for Seafood in
Hospitality: Consultation on Information Standard and Explanatory Statement. We congratulate the department on producing the draft standard with the aim of implementing it by 1 July 2025, as communicated to AMCS and other relevant stakeholders. Here we include responses to the questions posed by the department, and reiterate our position on the need to expand CoOL beyond the AIM model, as raised in our previous submission on this topic.1

Questions from the exposure draft information standard and draft explanatory statement:

1. Do they help you understand the proposed future labelling requirements for hospitality
businesses?
2. Is any of the language confusing?
3. What additional examples or scenarios should we include in future guidance material to
help improve understanding of the labelling requirements?

2. Understanding the proposed future labelling requirements
As the proposed labelling requirement is relatively minimal (i.e. the AIM model), the implementation instructions contained in the explanatory statement are correspondingly brief and easy to understand. However, there are some omissions and inconsistencies that need to be addressed before this standard can be clearly understood and applied throughout the hospitality industry.

A. Exemption for certain food service sectors

1
AMCS (2023). Consultation submission on Country of origin labelling for seafood in hospitality. 15
March 2023. Australian Marine Conservation Society (AMCS), Brisbane, Australia.
https://consult.industry.gov.au/cool-for-seafood-in-hospitality/survey/view/223

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Consumers get most of their seafood (57% by volume) from food service venues –
takeaway outlets, cafes and restaurants, catering at special events, and institutions
such as hospitals, prisons, schools and child care facilities.2 However, suppliers are
exempt from the proposed labelling requirements if the seafood is served at a
“school, prison, hospital, or medical institution, and…a fundraising event operated by
an endorsed charity, gift deductable [sic] entity or government school.”

Specifically, we believe the exemption for fundraising events to be problematic.
Caterers, food trucks and other hospitality businesses supplying seafood to
fundraising events are very likely to be supplying seafood in other public venues, and
under conditions that require display of the products’ origins under the proposed
regulations. It makes no sense for these suppliers to be required to display seafood
sourcing information in some contexts but not others. We recommend that hospitality
businesses be required to display country of origin information regardless of the
setting.

B. Exemptions for certain seafood products

The proposed exemption for “shelf stable food that consists of or contains chopped,
diced, minced, pureed or shaved seafood” is problematic. Products such as surimi3
(otherwise known as ‘seafood highlighter’) and prawn crackers are made almost
entirely from pureed whitefish and prawns, respectively. Surimi is widely used as
imitation crab, and as such is present in sushi rolls, seafood salads and other dishes
commonly served in hospitality venues. These items and other similar products
containing seafood as a major ingredient should therefore be included in the
requirements for country of origin labelling for seafood in hospitality.

The proposed exemption for “pre-packaged items for sale at food service outlets”
should be clarified to specify that such products must be produced commercially by a
third party AND fully compliant with the existing CoOL information standard. In the
explanatory statement, an example of this exemption is given as a cafe selling
pre-packaged tuna and salad sandwiches. However, in many cafes, bakeries and
similar hospitality venues, pre-made sandwiches are often made in house, wrapped
in plastic and labelled minimally, if at all. In order to avoid creating a loophole that
would allow venues to omit AIM labelling for “pre-packaged” or ready-to-eat items,
this requirement must be clarified and more detail provided on which items are
included under the proposed CoOL in hospitality standard.

2
Spencer S, Kneebone M (2012). FOODmap: An analysis of the Australian food supply chain.
Updated July 2012. CC BY 3.0. Department of Agricultre Forestry and Fisheries (DAFF), Australian
Govenment.
https://www.agriculture.gov.au/sites/default/files/sitecollectiondocuments/ag-food/food/national-food-pl an/submissions-received/foodmap-an-analysis-of-the-australian-food-supply-chain-30-july.pdf
3
What is surimi? GoodFish Sustainable Seafood Guide.
https://goodfish.org.au/resource/what-is-surimi/

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2. Instances of confusing or unclear language
We applaud the inclusion of language detailing the location of harvest, as this information is a vital requirement for traceability and for evaluating the sustainability of the product.
However, knowing the harvest location requires robust traceability, as seafood products may pass through multiple countries on their journey through the supply chain. As detailed in
AMCS and TRAFFIC’s previous submissions on this topic, many imported seafood supply chains are opaque, with low traceability. There is a risk that seafood suppliers will not provide the true harvest location, but rather the product’s ‘last stop’ in the supply chain, e.g.
the location of processing. This creates a risk that Australian-sourced seafood sent overseas for processing (e.g. prawns) could be re-imported and labelled as ‘Imported’. Robust traceability and verification is required to avoid situations such as these.

We also recommend that Section 6 of the explanatory statement is re-written to specify that seafood sellers and wholesalers supplying product to hospitality must provide seafood sourcing information in writing. This information is supplied in the draft standard, but is only present in the explanatory statement within the example scenarios (see Section 6, example
6).

3. Recommendations for future guidance material
We recommend the following guidance material be provided to industry (fishing and hospitality) in order to facilitate consistent and effective implementation of the new regulation:

1. Detailed guidance around implementation
a. Including details around auditing and compliance procedures to allow both
industries to adapt to the new requirements
2. Detailed guidance around the criteria for using the ‘Mixed’ designation
a. This would specify what proportion (by volume) of imported seafood in a dish
or product is required to trigger the use of the M label. We recommend that
hospitality venues specify the origin for each ingredient, as Part 2, Section 5,
Example 3, last two bullet points. This would allow consumers to understand
the proportion of Australian-sourced seafood versus imported seafood in their
dish, as well as the origin of specific ingredients.
3. Information on projected costs and funding opportunities to support industry during
the transition

4. Expansion of CoOL beyond the A,I,M model
AMCS and TRAFFIC commend the government for seeking to address a significant gap in seafood labelling requirements. We are glad to see the introduction of an option to improve labelling for hospitality venues beyond simply indicating if it is from Australia, or Imported or from Mixed Sources. Unfortunately, the proposed changes outlined in the draft standard will still not allow consumers to understand whether their seafood options are ethical or sustainable. Strengthening seafood labelling is one element in improving supply chain transparency and traceability, and should be developed alongside current work to develop a

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framework that addresses the importation of seafood from fisheries that involve illegal, unreported, and unregulated (IUU) fishing practices.

We cannot simply avoid these problems by buying from Australian sources, as the two proposed changes to CoOL might suggest. We rely on imported seafood to meet the demand of Australian appetites – our own fisheries and fish farms simply cannot produce enough. We need equitable access to all relevant sourcing information to be able to choose seafood from reputable international sources as well.

As we outlined in our first submission, the proposed ‘AIM’ labelling requirement to simply show whether seafood is either Australian, imported or international, or of mixed origin is oversimplified, flawed, and is not true Country of Origin labelling. It will only allow consumers in hospitality settings to potentially choose an Australian product over an imported one.
However, this won’t help buyers choose a particular seafood species, express a preference for wild or farmed seafood, or support more sustainable fisheries or farming practices. As we rely on imported seafood to meet Australian appetites, we need equitable access to all relevant sourcing information to be able to choose seafood from reputable international sources, as well as Australian ones.

We note that retailers are increasingly providing both species and provenance information voluntarily for terrestrial and seafoods, because it has market advantages and meets consumer demand i.e. presenting this information is not considered an additional cost, rather it adds value. Seafood provenance labelling has likely fallen behind terrestrial labelling in this regard because of the peculiarities of Australia's seafood wholesaler practices and the reluctance of some in the industry to lose their competitive advantage by revealing provenance information.4

4. Our recommendations
Seafood transparency and traceability are a major issue internationally, and consumers will increasingly be asking for accurate information on the source of their seafood. Australia can draw from the experience of progressive retailers and chefs that are already providing transparency in seafood sourcing for their customers. We can also learn from key trade partners and major seafood importers, the EU, USA and Japan, which have all developed
IUU import laws and policy.

While seafood import controls along with better traceability and labelling will not be a ‘silver bullet’ to all the problems in seafood supply chains, these will drive a shift towards more sustainable and ethical practices in the countries we import seafood from, provide a more level playing field for our domestic industry, and reward those at home and abroad who are doing the right thing.

The government must put in place laws and policies that ensure:

1. Consistent national end-product labelling requirements, at all points of sale for all wild
and farmed fish products and seafood (fresh, frozen, dried, canned, value-added,
4
Thompson BS, Rust S (2023). Blocking blockchain: Examining the social, cultural, and institutional factors causing innovation resistance to digital technology in seafood supply chains. Technology in
Society; 73: 102235 https://doi.org/10.1016/j.techsoc.2023.102235

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main ingredients, as well as where marine products are the main ingredients in
pharmaceuticals, health supplements, and pet food), that includes:

a. species name including common name (following a mandatory Australian
Fish Names Standard) and scientific name
b. fishing method, point of capture (to allow identification of stock and
management body), and who caught it (vessel flag nationality and beneficial
owner nationality if different from flag) OR farming method, and farm location
(region, and country)
c. exporting country.

2. All seafood in Australia is fully traceable and properly labelled throughout the supply
chain, in line with the Global Fisheries Transparency Coalition’s Global Charter for
Transparency.5 This should include a Seafood Documentation Scheme that includes
the Key Data Elements recognised as fundamental for establishing baseline
traceability of seafood products.6 Ensuring seafood is fully traceable will prevent
market access by a significant proportion of IUU fisheries.

3. Australia has minimum standards to close the market to illegal and unethical
imported seafood products, and works with key seafood exporting countries to
ensure we all meet our international commitments focused on protecting marine life
and those who work in the seafood industry.

Finally, we recommend that a review of CoOL in hospitality be undertaken 12 months after the commencement of implementation in order to identify and correct any issues early in the process.

For more details on points 2 and 3, please refer to: Dorey C, Sant G (2023). Consultation submission to the Department of Agriculture, Fisheries and Forests on Measures to prevent the importation of illegal, unreported and unregulated seafood: discussion paper. Australian
Marine Conservation Society and TRAFFIC, 30 June 2023.

5
Coalition for Fisheries Transparency (2023). Global Charter for Fisheries Transparency. April 2023.
https://fisheriestransparency.net/wp-content/uploads/2023/04/ONEPAGERA54-18.pdf
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A set of KDEs for wild and farmed fish have been recognised by the Global Dialogue on Seafood
Traceability (GDST) https://traceability-dialogue.org/gdst-standards-and-materials/ and 17 KDEs for fisheries in a recent collaborative report: EU IUU Fishing Coalition (2020). A comparative study of key data elements in import control schemes aimed at tackling illegal, unreported and unregulated fishing in the top three seafood markets: the European Union, the United States and Japan. The
Environmental Justice Foundation, Oceana, The Nature Conservancy, The Pew Charitable Trusts and
WWF. https://www.iuuwatch.eu/wp-content/uploads/2020/11/CDS-2020-report-EN-WEB-Nov-2020.pdf

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