Country of origin labelling for seafood in hospitality settings: regulation impact statement

Country of origin labelling for seafood in hospitality settings

WAFIC submission to Consultation Regulation Impact Statement

The Western Australian Fishing Industry Council (WAFIC) is Western Australia’s peak industry body representing the State’s commercial fishing sector, including wild catch, aquaculture and post-harvest businesses. WAFIC is also active in its community consultation and engagement and works alongside food service operators and retail traders.

WAFIC has long been advocating for compulsory Country of origin labelling (CoOL) across the food-service sector and applaud the Federal Government commitment to work through how such as system may be implemented in Australia including the release of the discussion paper (the paper) and the follow up consultation regulatory impact statement (consultation RIS). As such, we respectfully reject the status quo option.

The AIM framework proposed in the consultation RIS clearly articulates an absolute minimum standard for implementation of CoOL labeling in Australia. There is no doubt the system outlined would greatly improve reporting across the food service sector with only a minimal impost to hospitality providers. However, the scope does not go far enough to deliver on the expectations of the Australian seafood industry. There is potential for Australia to be world leading and we should not miss this opportunity.

Australian consumers want to buy Australian, so differentiation between Australian and imported is the first step, but we would argue there is scope to report at the state level – giving consumers the opportunity to prioritise local produce when they want.

Care should also be taken in the labeling requirements. While allowing origin to be represented with a simple “A” ,“I” or “M” might simplify the printing of cafe menus, we should not lose sight of what is trying to be achieved and a consideration of a clear “Australian” or “Imported” may be more appropriate than abbreviations.

While Australian consumers have a right to easily identify local seafood versus imports, this interest in providence extends beyond simply “Imported”. The seafood imported into Australia can have varying levels of transparency and performance relating to sustainability, legality and human rights. For example, “Imported” could cover New Zealand sourced Hoki which is third party certified by the Marine Stewardship Council (MSC), or something much more dubious.

Merely reporting on if seafood is “Imported” or not does not provide the consumer with enough providence information to make the informed decisions that they wish to make. This is particularly relevant in the absence of a mechanism for consumers to quantify the “food miles” their dinner may have travelled. The actual country should be explicitly reported.

It is already mandatory for all fish sold at the retail level, such as in supermarkets, to be labelled with its country of origin. Provision of this level of providence information is valued by retail consumers (for seafood and other food lines). It should not be overly onerous to provide the same information to the hospitality consumer, particularly when the county of origin information already accompanies the seafood all the way into the restaurant kitchen.

Country of Origin labelling for the food service sector is a priority for commercial fishing as it supports existing fisheries management and sustainability initiatives, including traceability and Marine Stewardship Council certification, to which WAFIC is heavily committed.

The Federal Government currently has a significant opportunity to markedly improve the reporting and traceability of seafood consumed in Australia which should not be wasted. If done well, the result could have a permanent benefit in improved transparency for seafood consumers.

Truth in labelling allows consumers to make informed purchasing decisions free of confusion and in-line with consumer detail preferences. An effective CoOL program also contributes to a level playing field for Australian fishing and aquaculture industries, shifting the onus of decision making from price alone.

It is expected that the new mandatory labelling will stimulate a greater commitment from the hospitality and food service sector to purchase locally-sourced seafoods over imported species, as customers gain a greater understanding of where their seafood comes from.

Greater transparency throughout the supply chain can further level the playing field by encouraging sourcing decisions to consider the standards, regulation and management frameworks associated with imported products. The Federal Government can do more here to strengthen import controls to ensure imported seafood is held to a similar level of regulatory standards as Australian seafood, such as those associated with Approval of a Wildlife Trade Operation (WTO) under the EPBC Act.

A more level playing field is particularly important as the cumulative impact of ever-increasing pressures on the level of fishing access to productive Australian waters begins to place growing pressure on Australian seafood production. For example, in WA we see thousands of square kms of lost access due to exclusions from Commonwealth and State marine parks; damage to valuable nursery areas from coastal industrial developments such as expansive solar salt evaporation projects; planned desalination plants for urban water and hydrogen energy hubs; and a number of the world’s largest offshore renewable windfarm proposals.

Australians should have the confidence of the same rules being applied for all seafood. All seafood must have to meet sustainability and ethical standards, even if it is imported. Australia should establish appropriate seafood import controls and invest in improving traceability and labeling to ensure we have confidence that we know what products are and where they come from. Everyone deserves to know exactly what they are buying.

Any further cost-benefit modeling undertaken around implementation of CoOL should not just consider the short-term costs to hospitality businesses. Government also needs to appreciate the longer-term social and economic benefits for seafood consumers, local seafood producers and associated supply chains, the viability of regional communities, improved seafood sustainability at global scales and the importance safeguarding Australia’s food security with continuing access to local seafood resources.