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

NSW Seafood Industry Council (NSWSIC) submission to the Department of Industry, Science and
Resources Country of origin labelling for seafood in hospitality settings regulation impact statement

3rd August 2023
Submitted via email: to mailto:OriginLabelling@industry.gov.au on Thursday, August 3, 2023.

NSW Seafood Industry Council
NSWSIC welcomes the opportunity to make a submission to the Department of Industry, Science and
Resources Country of origin labelling for seafood in hospitality settings regulation impact statement.

By way of introduction, the NSW Seafood Industry Council (NSWSIC) is the State peak body for the NSW
Seafood Industry, representing the interests of its members:

• Master Fish Merchants Association of Australia www.mfma.com.au
• NSW Fishermen’s Co-operative Association Ltd
• NSW Fishing Industry Training Committee www.maritimesafetytraining.com.au
• OceanWatch Australia www.oceanwatch.org.au
• Professional Fisher’s Association of NSW www.pfa.com.au
• Sydney Fish Market www.sydneyfishmarket.com.au

NSWSIC, through its member organisations, represents the NSW Seafood Industry across the supply
chain plus environment and training sectors and is committed to working constructively with
governments at all levels and the regulators, to ensure that we deliver on the industry purpose:

“We exist so that consumers and related industries have access to their local, sustainable seafood and
aquatic products.”

1
This submission covers the following areas
1. Overview
2. Consultation regulation impact statement question replies
3. Conclusion

Overview
NSWSIC strongly believes in the rights of consumers to make informed choices about the food they purchase and consume. Thanks to a strong food safety reputation in Australia, and a trusted agricultural supply chain, Australian consumers have developed an expectation of food safety, authenticity and trust in their purchases.

Since 1986, food retailers have affixed information on where the ingredients have originated from. As such, the decision to mandate a consistent labelling scheme in Australia has been welcomed by consumers and industry alike. The legislation brought about by the Country of Origin Food Labelling Information
Standard 2016 (“The Standard”), made under section 134 of the Australian Consumer Law, was welcomed by consumers and the Australia seafood industry alike for its ability to provide clearer, consistent, more informative and easier to find country of origin labels for food.

The purpose of this information standard is to provide Country of Origin Labelling (CoOL) requirements for food sold for human consumption in Australia. The reforms aimed to help consumers make more informed choices about the food they buy, in line with their personal preferences and purchase motivations.

Under this information standard, most food for retail sale in Australia, must be labelled with a country of origin, however food sold to the public for immediate consumption by the “food service sector” otherwise known as the hospitality sector (Country of Origin Food Labelling Information Standard 2016, Part 2,
Division 1, 14, 2, a-e) was exempt from enforcing this legislation with the requirements for standard marks and the placement of origin statements voluntary, rather than mandatory.

NSWSIC strongly believes in the rights of consumers to make choices, informed by any number of motivators, regarding the origin of foods they to eat, and the importance of the transparency provided by country of origin labelling statements in increasing consumer confidence in both the Australian seafood industry, Australian food supplies, primary producers and the agricultural supply chain on a whole.

NSWSIC agrees with the principal objective of the Discussion Paper which would see mandatory CoOL introduced for seafood sold in hospitality settings.

It is important to note, this is not a process to vilify imported or international seafood, we recognise the important role international seafood plays in the market and in consumer diets, but overwhelmingly we’ve heard consumers struggle to support industry when they dine out, because they simply can’t tell which seafood is Australian. Australia imports 66% of seafood consumed (ABARES, 2021), so having this sort of information clearly available to consumers in hospitality is critical to allow them to supply chain transparency, and choice.

2
The current exemption provided to the hospitality sector to label and identify Australian seafood impedes the rights of Australian consumers to the information and transparency provided by origin statements to which they are entitled. The exemption reduces the level of accountability and professionalism in the hospitality sector, which also provides them with undue advantage over the retail sector.

Right now, for food safety purposes, the supply chain of seafood is known in foodservice all the way to the kitchen door, however, the information is often not passed on.

NSWSIC believes the exemption to hospitality debases the entire CoOL reform by applying a double standard to the rights of consumers. Whilst the impact on businesses should not be untenable, neither should businesses avoid its duty to inform entirely.

Adopting CoOL legislation would lead to increased consumer awareness of the origin of the seafood they are purchasing and consuming, and subsequently support the Australian seafood industry, Australian jobs and have positive economic impacts. A cost-benefit analysis of the scheme, conducted on behalf of the
Australian Government, found that every $1 of costs incurred generated $3.30 in benefits.

NSWSIC endorses the Regulation Impact Statement and the introduction of mandatory Country of Origin
Labelling for seafood sold in hospitality settings. We support the proposition to make it a penalized offence for hospitality outlets who fail to comply with Country of Original Labelling requirements.

We believe the absence of a mandatory penalty for non-compliance would be akin to the voluntary information approach currently in practice.

NSWSIC believes that any penalty enforceable would need to act as a sufficient deterrent to adhere to or adopt CoOL.

3
Regulation impact statement key questions and replies
1. Are there any alternative ways to address the problem?
No. While there are alternatives to government action, NSWSIC does not believe these would be viable or sufficient to address issue. Industry capacity to lead action on this issue may also be limited given the current economic climate, especially as many businesses and industries across Australia are still gradually recovering from COVID-19 and other disruptions such as natural disasters, labour recruitment problems, and global crises. Therefore, the market is unlikely to resolve the issue on its own.

Additionally, NSWSIC does not believe it would be practical or sensible to display seafood origin information using the current retail CoOL bar charts and graphs. Whilst the kangaroo and bar chart can be accommodated in a retail environment and on packaging, it would be a detractor on food service menus in any form. NSWSIC supports this conclusion as drawn in the 2021, ‘Evaluation of Country of Origin
Labelling reforms’, Cost Benefit Analysis prepared for the Department of Industry, Science, Energy and
Resources by Deloitte Access Economics.

The 2021 evaluation of country of origin labelling for food (CoOL evaluation) attempted to estimate how many Australian food service businesses currently provide seafood origin information. Using the best available information, the evaluation conservatively estimated that only around 1% of businesses that offer seafood were providing origin information (Deloitte 2021a).

Consumer access to origin information for seafood in hospitality settings currently relies on businesses’ willingness to voluntarily provide this information, either through signage or in response to customer queries.

Currently this information is shared on a voluntary basis and the 1% uptake shows there is little to no appetite for businesses to voluntarily share this information, unless it is listed.

As such, we reject both the:
• a voluntary or industry-led standard
• an education and awareness campaign as viable alternatives to the development of an Australian Consumer Law information standard.

A voluntary or industry-led standard would require action from the hospitality industry or cooperation between the hospitality industry, Australian seafood producers and seafood importers. The hospitality industry is unlikely to act on this issue on its own, as it would be responsible for implementation costs and other business impacts. However, most of the benefits from increased origin information would be gained by consumers and seafood producers. The hospitality industry, Australian seafood producers and seafood producers have also historically had conflicting views on origin labelling and have different interests and priorities. It is unlikely that they would reach a consensus on an approach without intervention.

4
Voluntary and industry-led standards are not likely to be able to offer the same level of consistency and benefit to consumers as mandatory labelling. As businesses could choose whether or not they adopt the standard, origin information would still only be available at some venues and could be displayed or defined differently. As a result, consumers may not know to expect it or think to look for it. This is consistent with the CoOL evaluation’s findings that while voluntary labelling would not impose as much cost or regulatory burden, it also would not provide as much benefit overall because less information would be available to consumers compared to mandatory labelling across the industry (Deloitte 2021b).

Businesses could choose to label seafood based on their own definitions and interpretations of ‘origin’.
For example, one business may label based on the country where fish was caught, whereas another may label based on where it was processed or packaged. Even with a well-defined industry standard, it would be difficult for consumers to know if businesses are adopting the standard or their own definitions, which could result in greater uncertainty and confusion.

Actions such as promoting voluntary uptake of labelling, educating consumers about seafood origin, and encouraging them to ask about seafood origin would likely face similar issues, as the information being provided could be inconsistent or not available at all.

WHY A VOLUNTARY SYSTEM DOES NOT WORK

The Australian seafood industry has been assured a voluntary labelling system is available as a reasonable alternative to mandatory legislation. Similar to the failures in the retail sector prior to CoOL legislation originally being introduced in 2006, the voluntary approach to food service labelling has not worked.

The retail sector has evolved and strengthened over time as a result of the improvements in consumer confidence. This increasing consumer confidence is as a direct result of the increased transparency and accountability the retail sector achieves through origin information labelling. The beginnings of which can be found in this legislative approach.

Similarly, a mandatory system is required to begin the cultural shift towards accountability and trust in the food service sector. Consumers are increasingly ambivalent about what they are being served when eating out as the disparity in regulation and access to information widens.

The Australian seafood industry could not quantify the level of investment that would be required to create a similarly massive shift in transparency in food service as the way the removal of the CoOL exemption in food service would create. The benefits to consumers of CoOL in food service far outweigh the cost burden to food service businesses affected.

There has been little to no adoption of seafood CoOL outside of niche businesses and fine-dining establishments. Many of these businesses who promote provenance and country of origin do so where there is a positive story, such as the Australian origin of their produce. However, we are also aware that the vast majority will not seek to voluntarily advise their customers of the country of origin of all foods,

5
and particularly where there is a not a marketable interest in doing so. However, the absence of CoOL is to the detriment of the consumer with more than 50% of those surveyed (Seafood CRC, Lawley, 2015) assuming the seafood is of Australian in origin if there is no stated country of origin.

NSWSIC is aware of two recent examples where members if Seafood Industry Australia, the national peak- body representing the Australian Seafood Industry, have attempted a voluntary seafood labelling system in their food service establishments in Hobart, Tasmania and Western Sydney, New South Wales. In both instances the businesses suffered a loss of sales and reputation, and were forced to revert back to non- labelling as they were discriminated against by consumers who believed their competitors used all
Australian seafood due to their lack of CoOL.

Similarly, the Australian Seafood industry has been advised that consumers do not require mandatory labelling in food service as they can simply “ask the waiter”. However, asking food service staff for information on origin has been proven to be ineffective. The culture of awareness of seafood origin is not prevalent in the food service sector.

To test the veracity of this assumption Seafood Industry Australia commissioned independent research in
2017 into the reliability of asking the waiter for origin information. On average, 67% of staff were unable to provide credible information regarding the origin of the seafood being sold. The worst results were found in clubs with more than 90% of staff being unable to answer the question. This clearly demonstrates that a self- regulatory system for providing origin transparency for seafood does not deliver to the purposes of the Information Standard.

6
We believe market failure currently exists and mandatory, legislated CoOL is the necessary solution.

2. What is the impact of this lack of consumer information on seafood origin information in
hospitality settings?
This lack of easily accessible and consistently displayed information means consumers may be unable to make educated or informed purchasing decisions for seafood in hospitality settings in line with their personal preference.
It is important to note, this is not a process to vilify imported or international seafood, we recognise the important role international seafood plays in the market and in consumer diets, but overwhelmingly we’ve heard consumers struggle to support industry when they dine out, because they simply can’t tell which seafood is Australian. Australia imports 66% of seafood consumed
(ABARES, 2021), so having this sort of information clearly available to consumers in hospitality is critical to allow them to supply chain transparency, and choice.

7
If hospitality providers are not passing on origin information to consumers, and this information is desired by consumers to inform their purchasing decisions, then a situation of information asymmetry arises. This lack of information affecting purchasing decisions and power could lead to market distortion.

3. How important is price point when you make decisions about buying seafood in hospitality
settings?
Answered below with question 4.

4. Will seafood origin information in hospitality settings change your purchasing behaviour
with buying seafood?

Yes. There is strong consumer demand for country-of-origin labelling information to be provided for seafood sold in the food service sector. The political debate around the Country of Origin Bill 2016 repeatedly reinforced this point. Support for the right for consumers to have access to country-of-origin information was bipartisan and undisputed.

Research conducted by the Federal Department of Industry, Innovation and Science in 2015 found being able to identify country of origin was either “important” or “very important” to 74 per cent of consumers surveyed. Research has shown a minimum of 50% of consumers assume the seafood they are buying in food service is of Australian origin, even when the Country of Origin was not identified on the menu
(Seafood CRC, 2015). However, with almost 70% of seafood consumed in Australia imported, we know this is not the case.

Federally there have been numerous inquiries supporting a labelling solution, including:
• Labelling Logic: Review of Food Labelling Law and Policy, an independent review of national
food labelling law and policy, conducted by Dr Neil Blewett in 2011 (Blewett Review)
• Senate Rural and Regional Affairs and Transport References Committee “Inquiry into the
Current Requirements for Labelling of Seafood and Seafood Products” (2014);
• House of Representatives Standing Committee on Agriculture and inquiry into CoOL for food
in 2014
• Joint Select Committee on Northern Australia “Scaling Up: Inquiry into Opportunities for
Expanding Aquaculture in Northern Australia” (2016);
• Senate Rural and Regional Affairs and Transport Legislation Committee inquiry into private
Senator’s bill, in 2015 Senator Xenophon’s (and other co-sponsors) Food Standards
Amendment (Fish Labelling) Bill 2015 recognised consumer desire to know the origin of their
food
• The Standing Committee on Agriculture and Industry’s “A Clearer message for consumers”
report stated: “The Committee acknowledges that many consumers want to support
Australian businesses by purchasing Australian made products – consumers express a strong
preference to support local industries including food processing and manufacturing”

8
• Joint Select Committee on Northern Australia inquiry into opportunities for expanding
aquaculture in Northern Australia in 2016
• Productivity Commission inquiry into Regulation of Australian Marine Fisheries and
Aquaculture Sectors in 2016
• Seafood Origin Working Group (Industry-led), chaired by the Hon Craig Laundy MP, former
Assistant Minister for Industry, Innovation and Science, in 2017
• The “Food demand in Australia: trends and issues 2018” report found demand for Australian
grown produce domestically was on the rise, with Australians wanting to support our farmers
and choosing to buy Australian produce. The report showed consumers’ want clear food
labelling and to be informed, and food producers should be listening to that message.
• The Australia and New Zealand Ministerial Forum on Food Regulation and the former
Legislative and Governance Forum on Consumer Affairs consideration of extending origin
labelling to seafood in food service in 2018
• Department of Industry, Science and Resources ‘Evaluation of Country of Origin Labelling for
Food 2020–2021’
• Queensland Parliament ‘Food (Labelling of Seafood) Amendment Bill 2021’
• The House of Representatives Standing Committee on Agriculture and Water Resources
inquiry into Australian aquaculture sector 2022

Further, the Blewett Review, “Labelling Logic” identifies the need to monitor for market failure in the provision of consumer values information such as origin of seafood, with the prospect of a legislative intervention. The absence of CoOL is to the detriment of the consumer with more than 50 per cent of those surveyed assuming the seafood they purchase is of Australian in origin if there is no stated country of origin (Lawley 2015).

Just as recent changes to country of origin labelling in retail were driven by “public confusion” and
“overwhelming calls from the public for improved country of origin labelling” (Agricultural
Competitiveness White Paper, 2015), so too is there a need to address choice and confusion in the food service sector.

There is community and political support for the extension of origin labelling to seafood sold in the food services sector. In 2008, Country of Origin Labelling for seafood sold in food service was introduced in the
Northern Territory with minimal disruption. The seafood industry and food service sector have both reported positives from the introduction of the legislation.

Significant volumes of seafood are sold into the food service sector whether through takeaway, casual dining, high- end restaurants, or the corner fish and chip shop. With close to 62 per cent of seafood consumed in Australia imported (ABARES, 2022), and the majority of seafood consumed in the food service sector, many consumers assume their iconic seafood meals are made using iconic Australia seafood, however we know this is often not the case.

While nearly all domestic consumption of other major food service proteins such as beef, lamb and chicken are of Australian origin. Australian seafood consumers are often not aware of the nation’s high

9
seafood import rates, resulting in an elevated risk of inappropriate pricing, import substitution and reputational damage to Australian seafood suppliers and/or producers. The current exemption to CoOL legislation has led to the economic and social detriment of the Australian seafood industry, and had impacts on local jobs, and to the overall Australian (and Queensland) consumer experience and purchasing confidence.

Consumers want to eat Australian seafood and support Australian seafood producers, the Food demand in Australia: trends and issues 2018 report found demand for Australian grown produce domestically was on the rise, however consumers cannot buy Australian seafood if they cannot tell where it’s from.

As noted in the Australian Barramundi Farmers’ Association submission to the Country of Origin Labelling
Evaluation 2022, in the case of Barramundi, they estimate imported product fetches a whole fish price that is 40% of the price of Australian product (e.g., $10/kg whole for Australian fish and $4/kg equivalent for imported). However, there is no legislation to enforce that the origin of this iconic Australian fish must be provided to customers. Research conducted by the Seafood CRC in 2015 showed a minimum of 50% of consumers assumed when a seafood’s origin is not listed in food service the seafood is Australian. We suggest that for Barramundi this assumption is much higher.

Australian seafood producers strive to differentiate their product on provenance values, quality, safety, and sustainability - yet one of our biggest challenges to achieving growth in profitably is the difficulty in differentiating product from cheaper imports at the point of sale. To be clear, we are not vilifying imported seafood. We understand, appreciate and support their position in the market; however we believe country of origin should be clearly available for seafood sold in food service as it is in retail.

The Blewitt Review recognised there are mutual benefits to buyer and seller when the country of origin information is positive to include, but that government intervention is required when the benefits are non-reciprocal. That is, when the country of origin has negative connotations, and it is in the seller’s interest to withhold the information the Blewitt Review recommended intervention. Margins are greater where imported product can be sold with the origin withheld, and coupled with the public’s assumption that product is Australian.

Interestingly many food service venues have wine lists showing specific origin e.g. Champagne from
Champagne, or Shiraz from the Adelaide Hills, this extends to specify a range of other location indicators on menus for a variety of foods when it is considered a positive e.g. local flathead, Alaskan king crab etc.

Consumers both assume and expect, especially when dining out in a venue in an Australian coastal location, the seafood is local, or at least Australian. We support the Bill amendment as it raises quality to meet market expectations.

10
*Food demand in Australia 2018 (DAFF, 2018).

Repeatedly, the Australian seafood industry has been assured that by conducting its own marketing and promotional activities it can support the consumption of Australian seafood domestically. However, the absence of CoOL information in the food service sector, and the inability of the majority of vendors to reliably provide origin information, means consumers cannot willingly seek out and consume Australian seafood.

An increasing portion of Australian seafood is consumed in food service, as opposed to in-home consumption, which means with the exemption standing consumer ability to identify Australian seafood is rapidly diminishing.

1
Evaluation of Country of Origin Labelling reforms Final Report, July 2021.
2
As above.
3
As above.

5. How much will it cost business to implement the AIM model? If possible, please provide
estimates for immediate, short-term and long-term costs.

11
Seafood producers, both wild catch and aquaculture, Australian and imported, provide their customers with an awareness of the name and origin of the product, at all points in the supply chain. For food safety requirements including enacting any recall orders, this information is readily available all the way through the supply chain and into the food service kitchen. As such, there will be no additional costs along the supply chain for the origin of a seafood product, either Australian or imported, to be known.

At each transaction point through the supply chain there is a legal requirement for the seller to identify the product, any relevant product identifiers and country of origin on a tax invoice. For example, a fisher will provide a wholesaler an invoice for 100kg of Whole Australian Tiger Flathead caught that morning.
The wholesaler will on-sell this product to a restaurant as Whole Australian Tiger Flathead (current market price $14p.kg) or process the fish into fillets and sell the product as Australian Tiger Flathead
Fillets (current market price $45p.kg). The restaurant has the species, the form (whole or fillet) and the country of origin.

If the Flathead was imported from Argentina, it would be already processed into fillets to take advantage of the competitive cost of labour outside of Australia. The flathead would be marked on the frozen box outer as Product of Argentina and current market price would be closer to $14p.kg for fillets. Moreover, importing and biosecurity regulations will ensure that the importer is provided with all required product and origin information.

We are in no doubt whatsoever that every food service business in Australia that is transacting seafood through legal channels will have access to all the information they require, including country of origin information.

To help indicate the potential implementation expenses for businesses, the costs to implement seafood labelling requirements in the Northern Territory (NT) were relatively modest (Calogeras et al
2011).
On average, NT venues advised they spent $630 implementing requirements. With inflation applied, the costs may average around $1,000 in 2023. Costs to venues were higher initially, as large expenditure items such as menu and display boards were updated. These costs subsequently decreased over time. However, it should be noted that the NT is a small food sector market and may not be reflective of nationwide costs to hospitality businesses.
However, if hospitality businesses are provided with a 12-24 month implementation window, most of these costs will be negated as the implementation could be coupled with standard menu updates; noting there will be minor additional administration time needed to complete this.
Expected Costs
• Hospitality businesses will incur costs updating menus, displays etc. as well as ongoing
administration costs.
• Government will incur education and awareness campaign costs, as well as ongoing
compliance and enforcement costs.

12
6. How will hospitality businesses benefit from the AIM model in the short and long term?
Australian seafood producers strive to differentiate their product on provenance values, quality, safety, and sustainability - yet one of our biggest challenges to achieving growth in profitably is the difficulty in differentiating product from cheaper imports at the point of sale.
Hospitality businesses will be able to better identify their value proposition once CoOL labelling is implemented. The use of Australian produce will be an indicator of quality, freshness, sustainability, and care taken by the food service operator.
Expected Benefits
• A cost-benefit analysis of the scheme, conducted on behalf of the Australian Government,
found that every $1 of costs incurred generated $3.30 in benefits (DISER, 2022).
• Consumers have access to consistent origin information across all venues on which to base
their purchasing decisions.
• Consumers are better educated about seafood origin and the information businesses must
provide.
• Hospitality businesses will benefit from greater consumer confidence in business.
• Simple labelling model has a lower cost on business.
• The problem of asymmetry would no longer exist.

7. How much will it cost business to implement the country model? If possible, please
provide estimates for immediate, short-term and long-term costs.
NSWSIC does not support the ACL information standard – country model.

8. How will hospitality businesses benefit from the country model in the short and long
term?
NSWSIC does not support the ACL information standard – country model.

9. Which of the 3 policy options do you prefer and why?
NSWSIC supports the ACL information standard – Australian (A)/Imported (I)/Mixed (M) (AIM) model, as set out in the department’s discussion paper (DISER, 2022). This option would require businesses to label on menus, display boards or anywhere fish for sale is advertised, whether seafood is either:
• Australian (A)
• Imported (I)
• Mixed origin (M) (if a dish contains both Australian and imported seafood).

13
NSWSIC supports that the model be implemented through a new information standard under the ACL.
In addition, we agree that the government should run an education and awareness campaign to introduce any regulatory change.
NSWSIC does not support maintaining the status quo.
NSWSIC does not support the ACL information standard – country model. Sources of seafood can change for a variety of reasons, including seasonal availability and supply chain disruptions or shortages. Due to the price-point of seafood of Australian origin, we know it is typically not a competitor to seafood of imported origin. When pricing their menu items businesses will make a decision between seafood of Australian origin or imported seafood. However, due to the reasons we know and understand that the availability of seafood of international origin can vary depending on availability requiring businesses to switch between seafood originating in two or more international countries, or use a mix of more than one country. As such, NSWSIC believes that requiring businesses to differentiate between the international origins of the seafood they are serving would be onerous, would result in a more frequent need to change or alter menus if supply is unavailable or of mixed origins, and ultimately lower compliance with the ACL information standard.
Importantly, NSWSIC believes that businesses should retain the right to list the international country of origin alongside the Imported (I) at their discretion. We know the origin of a seafood species is an important consideration point for consumers, and the same applies to international seafood species and hero products.

10. Do you agree with the costs and benefits set out for each option? If not, please identify
which costs or benefits you disagree with and why.
The AIM model would result in increased regulatory requirements for impacted hospitality businesses and increased compliance and enforcement responsibilities for government.
Consumers would benefit from increased information to inform their purchasing decisions, both through labelling and the accompanying education and awareness campaign run by government to introduce the regulatory changes.
Sources of seafood can change for a variety of reasons, including seasonal availability and supply chain disruptions or shortages. Requiring businesses to differentiate between Australian seafood, imported seafood, or dishes that contain a mix of both (rather than more specific country or region information) should reduce the frequency of menu and information updates.

11. Do you think there is any relevant information missing from the options? Please specify.
NSWSIC suggests further clarification should be provided around the labelling of seaweed, and whether this is a seafood that requires labelling. We believe seaweed should be covered in the labelling.
Seaweed is a growing industry, AgriFutures Australia (Australian Seaweed: A $1.5 billion blue economy

14
opportunity) has identified a $100 million plus opportunity for seaweed over the next five years, with potential to scale to $1.5 billion over the next 20 years.
Further clarification should also be provided relating to cooking demonstrations in supermarket aisles and retail stores. Usually, the demonstrators use a small sign or board to indicate what is being cooked.
We suggest this could hold the CoOL information.
We also believe advice should be provided to cover seafood giveaways in places likes RSLs, pubs, and clubs.
We believe the seafood origin information needs to be clearly displayed on all menus including printed, digital, blackboard and food delivery services alongside the menu item and meal description.
Similar to the placement of diet-sensitive information relating to a particular menu item e.g. vegan, gluten free. Importantly, we do not wish to vilify imported seafood products, and understand there is a place for a variety of seafood products at a variety of different price points. Imported seafood can be similarly identified if so desired.
NSWSIC advocates that the food service sector should be provided with a minimum of 12 months to implement the new labelling legislation. We also recommend a maximum of 24 months for compliance.
Mandatory CoOL in the hospitality sector provides transparency for consumers who demand it, removes the potential cost burden of menu printing from the lower end of the food service pyramid
(hospitals, prisons, aged care) as the prevalence of Australian seafood is minimal, and provides a manageable environment for enforcement of regulation. However, we believe the types of hospitality establishments listed for potential exemption from the legislation, should instead be given the option to include CoOL, if they believe the consumers in those institutions have a right to know. We recommend strong definitions are supplied for the exempt businesses in order to close any potential classification loopholes.

15
Thank you

In conclusion, NSWSIC urges Department of Industry, Science and Resources to implement Country of origin labelling for seafood in hospitality, thereby providing transparency for the Australian consumer and the ability for consumers to make informed purchasing decision.

This legislation would create a level playing field for Australian seafood sold across retail and food service, and provide consumers with the same level of information regardless of where they chose to dine. Truth in labelling allows consumers to make informed purchasing decisions free of confusion and in-line with consumer detail preferences.

NSWSIC would like to thank you for taking the time to review our submission and the commitment from the Albanese Government to implement this legislation. In addition, we extend our thanks to Senator the
Hon Tim Ayres Assistant Minister for Trade and Assistant Minister for Manufacturing for his time and dedication to seeing through this meaningful commitment.

I welcome the opportunity to discuss any of our requests with you further and can provide more details if needed.

I would like to thank you in advance for your support of the future of Australia’s seafood industry, and your commitment to truth and transparency for Australia’s seafood consumers.

Yours sincerely,

Email:
Phone:

NSW Seafood Industry Council
C/o Master Fish Merchants Association, Locked Bag 247, Pyrmont NSW 2009

16