De-Coding Seafood Eco-Labels:

How the European Commission Can Help

Consumers Access Sustainable Seafood

eu ope
About Food & Water Europe
Food & Water Europe is the European program of Food & Water Watch, a nonprofit consumer organization based in the
United States that works to ensure the food, water and fish we consume is safe, accessible and sustainable. So we can all
enjoy and trust in what we eat and drink, we help people take charge of where their food comes from, keep clean, afford-
able, public tap water flowing freely to our homes, protect the environmental quality of oceans, force government to do
its job protecting citizens, and educate about the importance of keeping shared resources under public control.

Contact:
Food & Water Europe
europe@fwwatch.org
+32 (0) 2893 1045 eu ope

Copyright © April 2011 by Food & Water Europe. All rights reserved. This report can be viewed or downloaded at
www.foodandwatereurope.org.
De-Coding Seafood Eco-Labels:
How the European Commission Can Help
Consumers Access Sustainable Seafood

Table of Contents
Executive Summary and Findings.......................................................................................................iv

Introduction and Background: What’s an Eco-Label?...........................................................................1

What Info Does the European Commission Require for Seafood Labels?.............................................1

Third-Party Sustainability Certifications...............................................................................................2

Organic Certification..........................................................................................................................3

What Does Sustainability Mean for Seafood?.......................................................................................4

Concerns with Seafood Eco-Labels.....................................................................................................5

Comparisons of Eco-Label Programs Against FAO Standards...............................................................8

Will Enforcement of FAO Standards for Labeling Ensure Sustainable Seafood....................................10

Eco-Label Comparison and Breakdown.............................................................................................11

How Eco-Labels Have Changed the Marketplace..............................................................................13

Solutions..........................................................................................................................................15

Endnotes..........................................................................................................................................16
Executive Summary
Choosing the best fish to eat can be complicated. While you’re browsing the seafood counter or restaurant menu you may
wonder whether certain fish are safe and sustainable. In many cases, the more a person knows, the more questions arise:
Is this wild or farmed? Local or imported? Environmentally responsible and humane? High in mercury? Tainted with anti-
biotics and chemicals?

In light of these questions, there is a demand for straightforward guidance on seafood. To address the sustainability ques-
tions surrounding fish consumption, a number of certification programs have developed sets of standards and labels to
evaluate and then market “environmentally friendly” or “sustainably produced” fish.

Meanwhile, many retailers have begun sourcing their seafood predominately or exclusively from fisheries or companies
that have been certified with eco-labels in an effort to promote their environmental awareness about seafood sustain-
ability to consumers. Many of these labels claim to be in line with the United Nations Food and Agriculture Organization
(FAO) guidelines for aquaculture or fisheries certification, but are they? The European Commission has indicated it will
make an effort to enforce these guidelines.

To determine what eco-labels really mean, Food & Water Europe examined various seafood certification programs and
found that, unfortunately, labels do not always represent what consumers expect.

Our research reveals a variety of flaws and inadequacies associated with the eco-labels analyzed and suggests that private
labels may not be the most appropriate means to convey neutral, credible information about seafood. While the intent
to raise awareness about sustainability among seafood suppliers and fish farms is admirable, it is questionable whether
labels are actually increasing sustainability in the marketplace or meeting consumers’ demand for reliable information on
seafood. In fact, some labels with industry connections may actually be more successful at convincing consumers that the
products found in markets are “sustainable,” than at offering the neutral guidance consumers truly seek.

This report proposes that in order to provide consumers with much-needed, unbiased and well-regulated information, the
European Commission must develop and enforce strict criteria for interpreting the FAO guidelines on aquaculture and
fisheries certification. Until that time, consumers can use our guidelines and recommendations for safer and more sus-
tainable seafood choices at the end of this report.

Findings
• The eco-label certification programs reviewed in this report demonstrate inadequacies in regard to some or all of the
following: environmental standards, social responsibility and community relations, labor regulations, international
law, and transparency.

• Eco-labeling programs may cause increased public acceptance of products from controversial farming operations
such as coastal shrimp ponds and open-water aquaculture.

• Eco-labeling programs fail to promote local seafood options or account for the miles that imported seafood travels.

• Existing eco-labels have the potential to override the authority of governments, particularly in developing countries.

• The eco-labels examined fail to meet FAO criteria for eco-labeling and certification programs for wild fisheries and
aquaculture.

• Financial constraints have affected the ability of some otherwise eligible fisheries to attain certification.

• For some programs, there is a conflict between the intent to promote change within a certain fishery and the labeling
program, which can place a seal of approval on a product from a certified fishery before it has made conditional
improvements in ecological performance to actually meet the standards for the label.

• Eco-labels may negatively impact forage fish populations, which could damage marine food webs and harm food
security in developing countries.

iv
Introduction and Background: What’s an Eco-Label?

T he general purpose of eco-labels is to help consumers identify products that are

“greener,” more “environmentally friendly” or more “sustainable.” Eco-labels
can be found on a wide array of goods, from cleaning supplies to paper products to
seafood. In addition to providing a means of identification for consumers, labeling
can also be used as an incentive for industries to clean up their act. If they “go green,”
they earn the ability to market more easily to the growing body of consumers seeking
eco-friendly options.
In the case of fisheries and seafood, eco-labels have What Information Does the European
emerged in response to the range of controversial issues
related to the production and consumption of fish. Poor Commission Require for Seafood
fisheries management has caused the depletion of many Labels?
wild fish populations, and imported seafood from countries
You can already look for a few things on every seafood
with lower health, safety and environmental standards can
label in the European Union, even if it isn’t certified as
be tainted with dangerous chemicals and antibiotics.1 More
“eco-” or “organic.” Currently, the European Commission
than half of the world’s seafood now comes from aquacul-
(EC) requires all fish to be labeled with the name of the
ture — also known as fish farming — and many methods
fish, whether it is fished or farmed, and where it is from.
of this type of farming are associated with serious environ-
As of January 1, 2011, labels must also indicate whether
mental degradation and consumer health risks.2
the fish was previously frozen. The EC is also considering
Market research in Europe reveals that “consumers want requiring that labels include the scientific name of the fish,
more information on sustainable seafood and point of which would clear up confusion from common names,
purchase labeling.”3 In fact, 95 percent of consumers re- such as “sole” which is currently used for both Atlantic sole
sponding to one survey said they wanted more information and tropical sole. There is also a possibility that farmed fish
on how to avoid seafood that harms the environment.4 may start to be labeled by region rather than country. The
Although this desire for information must sound like good EC has stated that information on the means of produc-
news to seafood labeling schemes looking to expand their tion could also be more specific. For instance, labels could
reach, consumers should be wary of the information indi- state “small-scale fishing,” “caught by trawl” or “longline.”5
cated on these private labels, which is, in many cases, mis- If these definitions are carefully crafted, they could be
leading and insufficient. very useful for helping consumers to determine the likely
environmental impact of a fishery. Additionally, informa-

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 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood
tion on the method of production for farmed fish, such as
“open-water,” “pond” or “recirculating system,” which the
EC has not publicly considered, would be advantageous to
consumers.
• Global Aquaculture Alliance (GAA) was founded in
Third-Party Sustainability
Certifications
The method of fishing or farming and the origin of the fish
can be enough information for a fish expert to determine
whether a product meets his or her criteria for environmen-
tal or economic sustainability, but for many people, the
knowledge needed to make this analysis is not yet com-
mon, or easy to locate. To fill in these knowledge gaps,
some third-party certifications have emerged to designate
fish as “sustainable” or “responsibly produced.” The FAO
has established criteria for eco-labeling and certification
programs for wild fisheries and for aquaculture certification
programs, and the EC has stated that it “intends to ensure
that labels respect FAO guidelines.”6 However, it is not yet
clear how this will be carried out, and many existing eco-
labels can be interpreted as vastly inconsistent with the
FAO criteria.
Standards, motivations and approaches all differ between
labels. The following is a brief breakdown on those exam-
ined in this report.
• Aquaculture Stewardship Council (ASC) is not yet op-
erational, but has plans to create standards that would
certify 12 types of fish that “have the greatest impact
on the environment, highest market value and/or the
heaviest trading in the global market.” Standards have
already been developed for tilapia, pangasius, bivalves
and abalone.7 The standards for the ASC are being cre-
ated through “Aquaculture Dialogues” — roundtable
• The International Fishmeal and Fish Oil Organiza-
discussions sponsored by the World Wildlife Fund and
attended by fish farmers, other members of the aqua-
culture industry, government officials and non-govern-
mental organizations.8
• Freedom Food, operating in the United Kingdom, is
the farm assurance and food-labeling program of the
Royal Society for the Prevention of Cruelty to Animals
(RSPCA). It covers various farm animals and livestock,
including salmon. It describes itself as “the only UK
Farm assurance scheme to focus solely on improv-
ing the welfare of farm animals reared for food.”9 The
• The Marine Stewardship Council (MSC) was initially
welfare standards for salmon cover conditions during
the freshwater and marine stages of salmon farming.10
At this time, there are no Freedom Food standards for
other types of fish and seafood. Consumers should
note that this certification is focused on animal welfare
rather than environmental and social responsibility.
• Friend of the Sea (FOS) was established in 2005 in
Italy by the creator of the dolphin-safe tuna label.11 It
has gained a portion of market share in central and
2
southern Europe. FOS certifies both farmed and wild
fish and boasts a wide range of certifications, including
labels for fishmeal and oil from forage fisheries, an es-
sential part of the marine food chain.12
1997 by a wide range of companies including inter-
national aquaculture businesses, U.S. chain seafood
restaurants, wholesalers and processors, and agribusi-
nesses, like Monsanto and Cargill. It is now a power-
ful industry consortium.13 Their hundreds of corporate
members include AquaBounty,14 a biotechnology com-
pany that developed a type of genetically engineered
salmon widely opposed for its potential negative
impacts on human health and the environment;15 the
U.S. Soybean Export Council and Indiana Soybean Al-
liance, two organizations actively promoting growth in
the aquaculture industry to expand the market for soy-
based feeds;16 and Findus Group, which owns several
prominent brands of frozen food products, including
fish and other seafood, found under the label “Young’s”
in the United Kingdom.17 GAA is connected to major
aquaculture companies through membership on its
technical committees for standards-setting. For in-
stance, an executive of Marine Harvest, a large salmon
aquaculture corporation, is on the Salmon Farm Tech-
nical Committee.18 One of GAA’s primary programs
is the certification label known as Best Aquaculture
Practices (BAPs), which was introduced in 2003. GAA
uses the Aquaculture Certification Council (ACC) as its
exclusive certifying body. ACC only certifies farmed
fish and produces certification criteria by individual
species.19 The standards consider environmental and
social responsibility, community relations, and food
safety, among other things.20
tion (IFFO) certifies forage fish, or reduction fisheries,
through its own set of global standards for responsible
sourcing, with a focus on sustainability and food safe-
ty.21 Reduction fisheries supply the raw materials for
fishmeal and oil. While some fishmeal and oil is used
to make feed for land animals or nutritional supple-
ments for humans, the majority is used as feed by the
aquaculture sector.22 In 2006, aquaculture consumed
approximately 68 percent of the world’s fishmeal and
90 percent of fish oil.23
created by the World Wildlife Fund for Nature and
Unilever, once one of the world’s largest seafood buy-
ers.24 MSC became independent in 1999.25 It exclu-
sively certifies wild fisheries26 and has traditionally
seen certification as a way to form long-term working
relationships with particular fisheries.27 MSC states that
it bases standards around maintaining sustainable fish
stocks, minimizing ecological impact and effective
management.28
 Food & Water Europe

Organic Certification
Unlike the private eco-labels discussed in this report, organic standards are determined and
regulated by the European Commission.29 Public control and government oversight of labels
could help to make them more credible and transparent. Unfortunately, in the case of organic
aquaculture, the EC published regulations before developing sufficient standards. The
regulations allow non-organic materials to be used as feed, lack standards for water use and
waste disposal, allow the use of potentially harmful chemicals, and permit environmentally
destructive net pen aquaculture. While the EC works to improve the credibility of seafood
certification and keep misleading labels out of stores, it should also work to develop more
comprehensive standards for organics.

The way farmed fish are fed is an important indicator of a farm’s sustainability. Farmed fish
should not consume excessive amounts of wild fish, especially if they are sourced from
unstable fisheries. However, the regulations will allow farms to use feed that is not completely
organic or entirely sourced from sustainable fisheries until 2014, and these farms will still get
organic certification for the next several years.30

Although the regulations do ban artificial hormones and limitations on chemical use, farms are
allowed up to two courses of chemical treatment a year.31 Two chemicals that are known to be
potentially dangerous to humans, copper sulphate and potassium permanganate, are currently
allowed for cleansing and disinfection, though copper sulphate will be phased out by the end
of 2015.32 Exposure to copper sulfate can cause liver and kidney damage,33 and potassium
permanganate can cause nausea, vomiting, abdominal pain and kidney damage.34

The regulations lack standards for water use and waste disposal and, strangely, they ban
closed-containment recirculating aquaculture (farming fish in closed tanks that reuse and filter
water), insinuating that it is not as “natural” as organic fish production should be.35
Unfortunately, this poorly articulated notion of what constitutes “natural” prevents use of one
of the best possibilities for sustainable, healthy aquaculture in organic production. Worse,
operations with net pens anchored to the ocean floor that allow pollution to flow directly into
the ocean are potentially eligible.

Meanwhile, several private organizations, including the Soil Association (UK),36 Bioland
Germany,37 Naturland (Germany),38 KRAV (Sweden) and Debio (Norway)39 have developed
their own standards and certification programs for farmed fish.

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 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood

What Does Sustainability Mean for Seafood?

A certification program should be transparent and represent a clearly defined set of standards that
are publicly vetted and easily accessible to everyone. Its primary motivation should be to provide
neutral and straightforward guidance to consumers, and to do so, it should be independent from
parties with financial interests in marketing seafood. A label should not make vague claims of
being “sustainable,” “eco-friendly” or “responsible” unless it can clearly define and support those
assertions.

Although there is no single definition for sustainability or environmental responsibility for seafood,
a sustainable choice is generally considered one that is both ecologically and socially responsible.
For many people, the carbon footprint is also an important consideration, and in the case of food,
how sustainable a product is for our health (in terms of contaminants and chemicals) can be an
equally important issue.

For the purpose of this report, we consider that smart, or “sustainable,” seafood choices take the
following into account:

1. Ecological impacts:

a. For wild fish, the fish in question should have a healthy population, and the current
level of fishing should not threaten other species dependent on that fish for food.
Additionally, the fishery should not significantly threaten birds, marine mammals or
other animals, or damage the marine habitat. The type of fishing gear used and its
impacts on the seafloor and other marine wildlife are also important considerations.

b. For farmed fish, certification programs must consider water, chemical and feed use as
well as pollution discharge and impacts on wildlife and habitats.

2. Social impacts:

a. Labor standards must be fair. Working conditions should be safe, and hours reasonable.

b. Economic, health and safety impacts on surrounding communities must be considered.

A farm or fishery should not negatively impact the local economy or public health, and
must not cause safety concerns.

c. Indigenous, traditional and cultural considerations should be upheld.

3. Encouragement of a diversified seafood economy: It is important that the seafood economy

represent a variety of fish and shellfish options to benefit fishing communities, consumer health
and ecological sustainability. When a few types of fish are marketed heavily, they can
eventually become overexploited, resulting in negative ecological effects.

4. Transport and distance of the product from the market: Some of the seafood consumed in the
United Kingdom and Europe is imported from distant regions, or shipped around the world for
processing before returning to the United Kingdom or European Union. Eating local or regional
seafood helps to limit these fossil-fuel-consuming food miles.

5. Health and safety: Seafood must not be farmed with dangerous antibiotics, drugs or chemicals
and must not pose a contamination threat to consumers.

4
 Food & Water Europe

Concerns with Seafood Eco-Labels

The following are 13 prominent issues with seafood cer-
tification that the EC should ensure are addressed in its
regulation and enforcement. [Disclaimer: The following sec-
tion is designed to discuss overarching problems associated
with private seafood certification programs, not to provide
individual analysis of specific labels. Each concern is associ-
ated with at least one program, but they do not all apply to
every program.]

1. Certification of Flawed Fisheries

Some programs use their eco-label as incentive for a fishery
or farm to make improvements. For instance, MSC has tra-
ditionally viewed certification as a way to begin long-term
relationships with fisheries, and they expect further im-
provement to occur after certification takes place.40 After a
fishery has been evaluated by a third party, the fishery may
be granted certification even if it falls short of some stan-
dards.41 The fishery is given conditions for improvement,
but unfortunately, this means that a fishery with significant
flaws may still carry the MSC logo, indicating sustainability,
before it has achieved any improvements. This creates what
is known as the “free-rider” problem, in which fisheries Various logos used in fish certification programs
that are flawed, yet certified, get to ride on the reputation
products from large, industrial fish farms and boats may
of the more sustainable certified fisheries. Worse still, it
be more likely to be certified. Even Alaskan salmon, a very
risks seriously misleading consumers who may refer to the
valuable and well-managed United States fishery, has had
full standards and assume that certified products comply
difficulties financing MSC certification. It almost dropped
completely with all of them.
out of the MSC program when the Alaska Department of
Some critics have claimed that fisheries do not always Fish and Game opted not to continue sponsoring recertifi-
make improvements after MSC certification. A 2008 paper cation, which was anticipated to cost up to $1 million.46
observed that “there has been only one major ecological
Unfortunately, certification programs with lower costs can
improvement related to the MSC certification program…
come with their own problems. For instance, FOS does not
and it is unclear if it can be strictly attributed to the direct
conduct any of its own studies on the fishery or farm in
effects of the MSC program.”42 In 2010, a widely publi-
question. Instead, it relies on existing studies produced by
cized article written by prominent marine biologists openly
the FAO, regional fishing management organizations or na-
criticized the MSC explaining that “as the MSC increasing-
tional marine research authorities.47 FOS suggests that their
ly risks its credibility, the planet risks losing more wild fish
evaluation method allows for an expedited review and cer-
and healthy marine ecosystems.”43 The authors cited their
tification process, and makes the process less expensive for
concern that some fisheries seeking the eco-label are not
smaller fisheries.48 Unfortunately, this puts auditing in the
worthy of recognition for sustainability, and suggested that
hands of someone who may or may not have any expertise
the organization was in need of major reform if it wanted
in the fishery or farm, and bases the assessment on external
to fulfill its promise as “the best environmental choice.”
documents that may or may not be up-to-date.
The Aquaculture Stewardship Council (ASC) will follow a
similar model — setting environmental and social standards 3. Conflicts Resulting from Labels Used for
not at the ideal, but just above the status quo (even if the Marketing Purposes
status quo is quite far from any measure of sustainability).44
More than just a source of information for consumers, eco-
labels are often predominantly used as a marketing tool
2. Leaving Out Underfunded Fisheries and Farms for seafood companies. Some labeling programs, including
Paying for certification is expensive, and many fisheries and MSC, may be dependent, to a certain extent, on certifying
farms are not able to finance the cost. MSC certification of an increasing number of fisheries to continue building their
the small Cornish handline mackerel fishery, for instance, name and market share.49 Thus, there is an inherent con-
cost the fishery €15,000.45 Because of this cost, many small flict between an organization’s desire to maintain healthy
fisheries may not find certification financially feasible, and oceans and a need to grow its own brand name. When
these contradictory motives collide, objectionable certifica-

5
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood
tions can result. The increase in eco-label popularity may
even give incentive for groups to create new labels for the
purpose of marketing products they already have a stake in
promoting. Some companies, such as the Casino Groupe,
which owns the French supermarket chain Monoprix, have
created their own labels in order to designate some of their
products as environmentally friendly.50 Marketing goals
or connections to the industry may prevent certification
schemes from being as critical as they should be of some
fisheries and farms.
4. Inadequate Transparency and Public Input
Some certification programs lack sufficient transparency.
For instance, the criteria behind Casino Groupe’s internally
created label, “Terre et Saveur (Land and Flavour),” is un-
clear and not readily available to the public, leading one
analyst to deem it a “fantasy” label.51 In comparison, MSC,
ASC and some other programs are much more transparent.
Their standards are more readily available to the public and
they hold meetings for interested stakeholders to partici-
pate. However, some stakeholders have complained that
their comments on proposed certifications have not been
fully considered. For instance, after MSC’s controversial de-
cision to certify pollock, the Alaska Oceans Program con-
cluded that the “objections process is not legitimate.”52
5. Failure to Support a Diverse Seafood
Economy
A diverse seafood economy is necessary for supporting
both the economic and ecological sustainability of fisheries
and seafood consumption. Extractive industries (like fishing
and fish farming) that wish to operate sustainably should
allow for a broad range of participation from many differ-
ent stakeholders in a community or region. In other words,
a range of fishermen and farmers must produce sustainable
seafood to maintain diversity and economic benefits. If the
industry becomes too consolidated, communities will not
be able to participate meaningfully in the use and man-
agement of public resources, and the local economy will
suffer. Additionally, focusing the seafood market on only
a handful of species threatens those stocks’ longevity and
disrupts ecological balance to the ocean’s food web. To
prevent these problems, eco-labels would need to encour-
age the participation of a range of small-scale, community-
based individuals and companies.
6. Failure to Fully Consider Carbon Footprint
By placing a standard seal of approval on a fish, regard-
less of whether it is consumed in New York, San Francisco,
Tokyo, London, Sydney or elsewhere, most eco-labels fail
to include “food miles” in their sustainability standards. For
example, a London consumer relying on eco-labels to pick
sustainable seafood may end up with New Zealand hoki,
rather than uncertified farmed mussels produced much
closer, in the United Kingdom.
6
FOS is the only program evaluated here that addresses the
issue of carbon dioxide emissions in seafood transporta-
tion. It provides a “carbon footprint calculator” to the sea-
food industry to estimate the amount of CO2 emitted in the
process of catching (or producing) the fish and transporting
seafood to its final destination.53 They offer companies the
ability to offset their carbon emissions by investing in for-
estry, renewable energy or carbon capture technologies —
a controversial concept in its own right.
7. Pushing Farmed Fish
Certification programs that work exclusively with farmed
fish may, whether intentionally or inadvertently, promote
the consumption of farmed fish. Generally, the intention
of farmed fish certification programs is to distinguish the
more sustainable operations from ones that are associated
with a wider array of problems. But by exclusively labeling
farmed fish, they may send the misleading message that it
is better than other non-labeled wild fish, especially among
consumers who are unaware that the label applies specifi-
cally to farmed fish. A survey of European consumers has
indicated that the majority would choose to purchase wild
seafood over farmed when it is labeled as such.54 Indeed,
in many cases, wild fish from well-managed populations is
the more sustainable option.
8. Depletion of Forage Fish
Forage fish, which are near the bottom of the food chain,
are an important foundation for almost all ocean life.
Without these “prey fish” in our seas, the marine food web
could collapse.55 Additionally, many food-insecure coun-
tries rely on the same small fish as a key protein source for
residents, and fishing for them is a primary means of coast-
al employment. Overuse of these fish can harm both the
marine wildlife and the people that need these fish most.56
Forage fish are often caught and processed into fishmeal or
fish oil, which is used as an ingredient in food for carnivo-
rous farmed fish (fish that eat other fish for protein), such
as Atlantic salmon. Some programs certify forage fisheries,
which allows fishmeal and fish oil manufacturers to claim
their product is from a sustainable source. Some labeling
standards may not sufficiently consider the role of forage
fish in the ecosystem and the effect that its continual ex-
traction will have on other fish, marine animals, seabirds or
people that depend on it for food.
Additionally, some programs that certify farmed fish do
not contain adequate standards for the use of wild fish in
fish feed. One popular view of fish farming is that it can
take the pressure off of wild stocks by supplementing our
seafood supply. While this can be true for farming mussels,
oysters, tilapia or other species that do not require wild fish
in their diets, other farming systems rely heavily on extrac-
tion of “lower-value” fish to sustain their farmed stock. This
can mean that more fish are consumed by the farmed fish
 Food & Water Europe
than are ultimately produced. This is referred to as a high
feed conversion or “fish-in-fish-out” ratio. For example, to
grow just one pound of some farmed fish may require five
pounds of wild fish as feed. Some certification schemes al-
low farms with a much higher fish-in-fish-out ratio to gain
eco-certification.57
9. Allowance of Genetic Engineering, Antibiotics
and Hormones
Although some certification programs ban genetically en-
gineered (GE) fish, not all do. Further, because infections
are common on fish farms, certifications often allow some
use of antibiotics. For instance, one set of standards allows
both antibiotics and hormones to be used as long as they
are used “in accordance with instructions on product labels
and national regulations.”58 Unfortunately, some countries
may not have strict regulation or enforcement of guidelines
for antibiotic and hormone use in animals destined for hu-
man consumption.
Right now, the standards pertaining to hormones and GE
fish are most relevant to tilapia production, because the
international industry often relies on a hormone called
methyltestosterone (MT) to rear male fish to prevent uncon-
trolled reproduction and achieve speedier growth rates.59
There are serious public health and environmental concerns
surrounding the use of MT. The human risks of exposure
to this hormone may include liver dysfunction and cer-
tain cancers.60 MT has been documented to persist in the
aquatic environment and sediment below fish farms long
after being released in the form of medicated feed. This has
troubling implications for worker health and the local envi-
ronment, especially because it is common industry practice
in some countries to dredge up pond sediment to “prepare
soil” for crop production.61 MT can also cause skewed sex
ratios of untargeted organisms in the local environment.62
10. Threats to Mangrove Ecosystems
Mangroves are the densely shrubby habitats that occur
naturally at the border between water and land along many
tropical coasts, which a wide variety of marine creatures
(including fish, birds, turtles and many mammals) call
home. They help anchor soil, can provide a buffer from
storms and help filter water. Unfortunately, mangroves are
frequently destroyed or damaged for development of coast-
al shrimp farms in South America and Southeast Asia.63
The Mangrove Action Project (MAP), which works to
manage, protect and restore the rich ecology of coastal
mangroves, has been a vocal opponent of certain eco-
certifications. In one program, for instance, mangroves can
be removed for “allowable purposes” as long as the farm
replants “an area of mangroves three times the size of the
area removed.” However, mangroves can take dozens of
years to fully develop, and replanting may never result in
successful growth of a full system. MAP explains that their
“years of collective experience in working to counter the
negative effects of the shrimp aquaculture industry” has led
them to “take a strong stance against this [the Aquaculture
Stewardship Council] and other shrimp certification at-
tempts.” MAP says that current certification processes “ex-
clude those peoples most affected by the industry’s ongoing
assaults” and say that ASC’s process is “aimed in an inap-
propriate and environmentally dangerous direction.”64
11. Jeopardizing Worker Rights and Safety
With so much seafood produced in developing countries
that have less stringent or poorly enforced labor laws,
worker wellbeing is a critical issue in seafood production,
yet some certification programs may not sufficiently review
labor standards. In 2008, the Solidarity Center produced a
shocking exposé on laborers at shrimp farms and process-
ing plants in Southeast Asia. The report details egregious
human rights abuses in these facilities, including child la-
bor, the total absence of healthcare services or even basic
first-aid treatment for most workers, pitifully low wages,
and work shifts of up to 26 hours in length.65 The Center
characterizes the creation of the GAA and ACC as an at-
tempt to mitigate the negative effects of the industry on its
workers, but notes that its standards are sub-par. One of
the flaws it documents is that the standards do not men-
tion any restrictions on the number of working hours — a
major oversight in an industry where working shifts often
exceed 12 hours a day.66 The Center also observes that the
standards make “no mention of international migrant rights
standards or best practices to prevent abuses like debt
bondage, forced labor and human trafficking,” all of which
are documented abuses mentioned throughout the report.
7
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood

12. Superseding Governmental Authority
Additionally, there is a concern that by exerting a powerful
influence in the marketplace, private eco-labels may steer
fisheries management away from the control of national
governments, particularly in developing countries. As one
study finds, “MSC reregulates the coordination of the glob-
al fisheries away from public venues and into private are-
nas.”67 According to authors, the MSC “bypasses national
laws and marginalizes fisherpeople.”68
Even in developed countries, the power of private labels
can cause government laws to be pushed aside. The MSC-
certified New Zealand hoki fishery, for example, has been
found to violate that country’s fisheries act, which requires
that adverse effects on the aquatic environment (including
seabirds) be addressed and avoided.69
13. Incongruence with FAO Guidelines
The FAO standards for eco-labeling and certification pro-
grams for wild fisheries are intended to be a benchmark
for quality and reliability in a label. Many of the eco-labels
mentioned in this report have favorably compared them-
selves to the FAO guidelines, providing them with an os-
tensible measure of legitimacy.70 However, analysis of each
of the eco-label programs against the FAO’s guidelines
found them lacking. While this chart is not a complete re-
view, it does highlight some of the examples where labels
fall short.

Comparisons of Eco-Label Programs Against FAO Standards*

Description of FAO Standard70 Explanation of Violation

Criterion 29.3: Requires identification of “adverse
MSC impacts of the fishery on the ecosystem”
Principle 2.12: MSC certifies fisheries that fail to
meet certain criteria. It mandates improvements that
must be met in the future, but the label is granted in
the meantime, meaning consumers may be buying
a certified product that isn’t fully compliant yet.
This can be seen as failure to fully communicate the
label’s meaning.
Alaska pollock is being considered for re-certification despite
a crashing population and some concerns about bycatch
and impact to local communities.71 Also, MSC is currently
considering certifying several reduction fisheries,72 which
could be destabilizing to marine ecosystems that depend on
forage fish as a primary food source.
MSC certifies fisheries that fail to meet certain criteria; it
mandates improvements that must be met in the future,
but label is granted in the meantime, meaning consumers
may be buying a certified product that isn’t yet fully
compliant.73 This can be seen as a failure to communicate
full information.

Criteria 28 and 29.5: The fishery operates “in
compliance with the requirements of local, national
and international law and regulations,” and under
an “effective legal and administrative framework”
Criterion 29.6: The fishery implements the
“precautionary approach” to “protect the ‘stock
under consideration’”
Criterion 29.3: Requires identification of “adverse
Friend of impacts of the fishery on the ecosystem”
the Sea
Certified New Zealand hoki has been found to violate that
country’s fisheries act, which requires that adverse effects
on the aquatic environment (such as known bycatch of
endangered seabirds) be avoided.74
Controversial certification of British Columbia sockeye
salmon occurred even as a Canadian judicial review into
collapse of the resource was ongoing.75
FOS’s certification of reduction fisheries, and companies such
as Omega Protein that catch massive amounts of menhaden,
could be destabilizing to the ecosystem and detrimentally
affect water quality in the coastal mid-Atlantic.76

Criterion 59: “Proper records of standards and
development activity should be prepared and
maintained”
Criterion 128: The certification body “should
carry out periodic surveillance and monitoring at
sufficiently close intervals” to verify that the fishery
continues to comply with criteria
Criterion 29.3: Requires identification of “adverse
IFFO’s impacts of the fishery on the ecosystem”
GSRS
Criterion 41: Eco-label standards “should not distort
global markets”
FOS’s website does not publicly offer evaluations for many of
their certified fisheries and companies.77
FOS apparently performs an annual review — of stock status
only — in the five years between each certification.78 Many
other factors should be taken into consideration to ensure
that no other impacts on local ecology (such as the seafloor
or new and unanticipated bycatch) are taking place.
IFFO’s certification of fisheries destined for reduction could
be destabilizing to marine ecosystems that depend on forage
fish as a primary food source.79
Certification of reduction fisheries may distort global markets
and cause food insecurity in developing countries.80

* GAA / ACC, GTC, Ltd., and ASC are not included in this analysis because they only certify aquacultured seafood.

8
 Food & Water Europe

In October 2010, the FAO’s Subcommittee on Aquaculture
of the Committee on Fisheries approved the first global
guidelines for aquaculture certification. These non-binding
guidelines, which will go on to the full committee for
approval sometime this year, are intended to account for
animal welfare, environmental impacts and socioeconomic
aspects of certifications.82 Analysis of the fish farm
certification programs discussed in this report indicates that
many of these do not live up to the full intent of the FAO
guidelines.

Description of FAO Standard83 Explanation of Violation

55: “Workers should be treated responsibly and
Best in accordance with national labour rules and
Aquaculture regulations and, where appropriate, relevant ILO
Practices (of conventions.”
the Global
Aquaculture
Alliance)
76: “The standards setting body or entity
should strive to achieve balanced participation
by independent technical experts and by
representatives of interested parties in the standards
development, revision and approval process.”
46: “Evaluation and mitigation of the adverse
impacts on surrounding natural ecosystems,
including fauna, flora and habitats should be
carried out.”
40: “Environmental Integrity: Schemes should
Friend of the not be overly prescriptive, but set measurable
Sea benchmarks that encourage improvement and
innovation in environmental performance of
aquaculture.”
104: “The accreditation body or entity should
have a written policy and procedures for dealing
with any complaints in relation to any aspect of
the accreditation or de-accreditation of certifying
bodies” and 107: “Information on procedures for
handling complaints concerning accreditation
should be made publicly available.”
53: “Aquaculture should be conducted in a socially
responsible manner, within national rules and
regulations, having regard to the ILO convention
on labour rights, not jeopardizing the livelihood
of aquaculture workers, and local communities.
Aquaculture contributes to rural development,
enhances benefits and equity in local communities,
alleviates poverty and promotes food security. As a
result, socio-economic issues should be considered
at all stages of aquaculture planning, development
and operation.”
46: “Evaluation and mitigation of the adverse
Freedom impacts on surrounding natural ecosystems
Food* including fauna, flora and habitats should be
carried out.”
47: “Measures should be adopted to promote
efficient water management and use as well as
proper management of effluents to reduce impacts
on surrounding land and water resources…”
The BAP standards include no restrictions on the number
of working hours in a day and make “no mention of
international migrant rights standards or best practices to
prevent abuses like debt bondage, forced labor and human
trafficking.” Wages, benefits and child labor are evaluated
through information provided by the facility, and not by
independent evaluators.84
The BAPs have not fully engaged subsistence farming and
fishing communities affected by farming operations, or
ensured that local populations participate in development,
implementation or monitoring of farms’ environmental and
social impacts.85
Coastal shrimp farms, which can be certified by the BAPs,
can pose a substantial risk to mangrove ecosystems. The
BAPs allow mangroves to be removed for allowable purposes
if a larger area is replanted. These replanting efforts are not
necessarily effective, and their success is not enforced.86
While the FOS standards require certified farms to record
information on feed conversion (the amount of feed needed
to raise farmed fish) and “undertake to carry out a gradual
annual reduction,” no numerical requirements are put in
place.87
The FOS procedure does not appear to include peer review
of certifications or explicitly provide information on how
complaints can be lodged regarding the review process.88
FOS requires “social accountability” in its standards, but
they only require basic compliance with national and
international laws and access to medical care.
There are no standards to ensure socio-economic issues are
considered, as mentioned in the FAO standards.89 Farms
should be required to go beyond basic legal requirements in
order to achieve special certification.
Although protection of the benthic (seafloor) system is
largely viewed as a primary reason for salmon regulation,90
Freedom Food does not require monitoring of the seafloor.91
Most water quality requirements are designed in relation
to salmon health and not wider environmental health.
Water quality monitoring requirements are not sufficiently
explicit.92

* Freedom Food focuses exclusively on animal welfare standards and does not claim to represent wider environmental or socio-economic standards. In
light of this, consumers specifically concerned with animal welfare may not be concerned with the highlighted inconsistencies with FAO standards. This
comparison is intended for consumers who may assume that the presence of the label indicates a more responsibly produced product overall.

9
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood

Signs in a U.S. grocery store.

Will Enforcement of FAO Standards for Labeling Ensure Sustainable

Seafood?
Not necessarily. Even if labeling programs strictly adhere to FAO guidelines for eco-labeling
wild fisheries and aquaculture certification, the prevalence of certified fish in the marketplace
could still lead to a homogenous seafood economy and contribute to the growing carbon
footprint of the seafood industry. However, if the EC does rigorously pursue adherence to FAO
standards, the seafood industry should at least be pushed in the direction of sustainability. But
because some of the FAO guidelines are vague or open to multiple interpretations, the EC
must go beyond the guidelines to develop strict interpretations of them. For instance, the
proposed aquaculture guidelines state: “feeds… should be used responsibly to minimize their
adverse impacts on the environment and to promote economic viability.”93 To meet this
guideline, the EC could require low fish-in-fish-out ratios from producers as well as evidence
that any small amounts of wild fish used in feed come from demonstrably responsible and
healthy fisheries.

10
 Food & Water Europe

Eco-Label Comparison and Breakdown

Table 1: Concerns Associated with Standards for Certifying Wild Fish, by Label

IntERnAtIOnAl FISH
MARInE StEwARDSHIP FRIEnD OF tHE SEA
MEAl AnD FISH
COunCIl (wIlD CRItERIA)
OIl ORGAnIZAtIOn

Prohibitive costs

Ambiguous or
non-transparent criteria

Insufficient public input

negative impact on
marine animals

no carbon
footprint standards

Certifies forage fisheries

or their products

Free-rider problem

Incongruent with
FAO criteria

11
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood

Table 2: Concerns Associated with Standards for Certifying Farmed Fish, by Label
.
Best Friend of the aquaculture
Aquaculture sea (farmed stewardship freedom food terre et saveur
practices criteria) council/wwf*

Prohibitive costs TBD N/A

Does not prohibit…

GE

antibiotics Unknown

hormones Unknown

Ambiguous or
non-transparent criteria

Insufficient public input

Certify farms with

negative impact on TBD N/A Unknown
mangrove ecosystems

no carbon
footprint standards Unknown

Insufficient
FCR standards TBD Unknown

Free-rider problem Unknown

Insufficient
worker safety TBD Unknown

*Standards have only been completed for four (tilapia, pangasius, bivalves and abalone) out of the 12 categories being discussed in the Aquaculture
Dialogues.94 Because each species or category of species is being discussed separately, not all violations will necessarily apply to all standards. Con-
cerns listed here are associated with one or more of the completed sets of standards. No standards produced by the Aquaculture Dialogues yet have
made reference to carbon footprint.

12
 Food & Water Europe
How Eco-Labels Have Changed the
Marketplace
In response to consumer demand for sustainable seafood
options, retailers have developed policies for procuring
and labeling “sustainable” seafood. MSC has a particularly
wide reach in Europe and the United Kingdom and is con-
nected to many of the “responsible seafood purchasing”
programs implemented by retailers. Although retailers’
attention to seafood sustainability is a positive step, it is
problematic that so many base their seafood sustainability
programs around private third-party certification systems.
Supermarkets offering MSC-labeled products in Europe
UK supermarkets: ASDA, Waitrose, Sainsbury’s, Tesco, Young’s
Bluecrest, M&S, Morrisons and Co-op
German supermarkets: Edeka, Friedrichs, Lidl, Iglo, Tengelmann
Group, Dohle Group, Tegut, Frosta, Pickenpack, Rügen
Feinkost, Royal Greenland, Appel Feinkost, Gottfried Friedrichs
and Friesenkrone Feinkost
French supermarkets: Carrefour, Casino, Monoprix and Picard95
Case Studies:
Carrefour has launched a campaign along with the MSC. In
January 2010 it announced an awareness campaign called
“The Blue Days” to “help French consumers make posi-
tive environmental choices when buying seafood.” These
positive choices referred primarily to buying MSC-labeled
seafood. The store sells 25 MSC-labeled products under its
own brand name in the refrigerated section and fresh fish
counters. As stated by the store’s global quality director:
“The MSC is at the very heart of the Carrefour Group’s sea-
food sourcing policy.”96
The Cooperative Group (the Co-op) has also linked itself
with MSC, announcing in 2003 that it would launch its
MSC-certified fish under its own label, meaning that it
would have its own packaged products certified by prov-
ing the chain of custody from the fisheries. However, the
company stated that its work with MSC was only part of its
sustainable seafood effort and that it would also be using
its Responsible Retailing policy to evaluate fishing grounds
and methods associated with fisheries it could source
from.97 A full responsible fish sourcing policy was an-
nounced in 2008 and is intended to address “over-fishing,
illegal fishing, bycatch, fishing methods that destroy the
seabed and the effect on other fish species, marine ani-
mals and birds.”98 This initiative is important and earned
the store congratulations from European non-profit Marine
Conservation Society (MCS) in 2009. MCS noted, how-
ever, that the Co-op still needed to improve the sourcing of
farmed seafood.99
Delhaize, a prominent chain in Belgium with additional
stores in Germany, Luxembourg, Greece and other parts of
the world, is also working to develop policies for seafood
purchasing. They plan to offer MSC-certified wild-caught
seafood and, on a more independent-minded and positive
note, have also decided to favor line-caught seafood and
make sure that fish considered endangered, such as bluefin
tuna, are phased out. Regarding aquaculture, their policy
is “aquaculture where needed,” and have stated that they
prefer for farmed seafood to be GAA- or ACC-certified.100
Marks & Spencer (M&S), based out of the United Kingdom
with stores in Europe (and worldwide), is often considered
the leading retailer in terms of seafood sustainability and
has been praised by Greenpeace, Seafood Choices Alliance
and the Marine Conservation Society.101 Although the ex-
tent of M&S’s involvement in addressing questions of sea-
food sustainability is impressive, it is concerning that much
of their work is tied up in private-certification programs.
They are participating in the development of the ASC102
and source wild fish from MSC-certified fisheries. Like Car-
refour and the Co-op, M&S carries MSC products under its
own label.103
Monoprix, Franprix and Leader Price are all owned by the
French conglomerate Casino. As of 2009, Casino’s line in-
cluded 24 MSC-certified seafood products. They also label
some farmed fish with the tagline, “This Product Preserves
Our Seas.” The company says this logo is reserved for select
products meeting specific requirements, but does not list
these requirements on its website or public materials. The
company has a label called Terre et Saveur, which includes
40 seafood products.104 According to the very general lan-
guage used on the company’s website, the label requires
that modes of production “contribute to a respect of the en-
vironment and the real needs of plants and animals.”105 This
has been referred to as a “fantasy” label by critics, who are
suspicious of its internal evaluations and development.106
Sainsbury’s: Sainsbury’s, the United Kingdom’s longest-
standing major food retailer, has made it a policy to buy
MSC-certified seafood when possible. It sells over 55 MSC-
certified products. When it is not possible to obtain an
MSC certification for a product, the supermarket’s policy is
to label it using the stoplight system: Green if it is “scientif-
ically verified” to be in plentiful supply, amber if there are
concerns about sustainability but action is being taken, and
red when there are major sustainability concerns. The store
does not sell fish with red status.107 The store also claims
to sell “responsibly sourced” farmed Scottish salmon that
meets the RSPCA Freedom Food Standards.108 Unfortu-
nately, the environmental and socio-economic impacts
of Scottish and other salmon farms make this a dubious
claim.109 In November 2010, Sainsbury’s announced that it
had helped the MSC reach 7,000 products worldwide with
certification of a peeled, frozen prawn product.110
Tesco is the third-largest store group in the world and the
market leader in both fresh and frozen fish.111 It boasts
sustainability goals, claiming that it “is committed to offer-
ing customers sustainable choices… Fish is a healthy meal
13
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood
option for families; it also needs to be a healthy option for
our oceans and fishing communities.” Tesco began offer-
ing processed (chilled, smoked and frozen) MSC products
in 2001 and started offering fresh MSC-labeled fish at its
seafood counters in 2005.112 Tesco boasts of four types
of salmon in its stores. First, there’s the “standard/value”
salmon, which is typically farmed in Scotland, Chile and
Norway. Tesco claims that “farmed salmon is a sustainable
way to produce quality tasting fresh fish and the environ-
ment and health of the fish is monitored by farm assurance
schemes,” on its website. However, it does not mention the
environmental and socioeconomic ramifications for which
open-water salmon farms are notorious.113 They also offer
“Tesco Finest Specially Selected Salmon” which is grown
in Scotland and “stocked at levels recommended by the
RSPCA”; “Tesco Organic Salmon” from certified organic
farms; and “Tesco Finest Wild Salmon” from Alaska.114
Although it is a positive step for these major retailers to
14
recognize the importance of sustainability in seafood
sourcing, partnerships with sustainable seafood certifica-
tion schemes can allow eco-labels to capture large portions
of the market, keeping sustainable but uncertified fish out
of marketplace and allowing some questionably certi-
fied products to become dominant. Additionally, retailers
making independent (non-certified) claims about seafood
can be problematic and misleading. According to a study
carried about by ClientEarth, a non-profit environmental
law organization, claims such as “sustainably sourced,”
“protects the environment” and “responsibly farmed” were
misleading or unverified on almost one-third of examined
products. The organization asked that retailers includ-
ing Tesco, Asda, the Co-operative, Lidl, Marks & Spencer,
Sainsbury’s and Waitrose verify their claims or remove the
labels, and warned they would take legal action if this is
not done.115
 Food & Water Europe
Solutions
The majority of European consumers want to purchase
seafood that is sustainable, but many do not feel they have
the information necessary to do so. Market research has
revealed that consumers want the government or retailers
to bear the responsibility for making sustainable seafood
available.116 The findings of this report suggest that private
eco-labels are not reliable or neutral indicators of sustain-
able seafood choices for consumers, restaurants or retailers.
Furthermore, these labels have allowed private organiza-
tions and even companies with vested financial interests
to set the standards for sustainability without meaningful
public input. To address this problem, governments must
step up to offer consumers meaningful, well-defined and
verified information on seafood. Specifically:
1. The EC should expand information required on
seafood labels to include method of capture (han-
dline, trawl, etc.) as well as method of production
for farmed fish (pond, open water, re-circulating
land-based, etc.). This information will enable con-
sumers to make well-informed choices about all
seafood, whether it is eco-labeled or not.
2. The EC should fulfill their intention to ensure that
labels adhere to FAO guidelines by developing
specific and clear interpretations of the guidelines
and requiring any programs wishing to certify fish
sold in the EU to adhere to them. This practice
must be established as soon as possible, before
weak enforcement becomes the status quo.
In the meantime, consumers can use the following ques-
tions at supermarkets and restaurants to help assess the
quality and sustainability of seafood.
1. Was it caught or farmed locally?
Often the shorter the distance food travels to get to your
table, the less fuel is used to get it to you. Eating fish caught
or farmed close to home also gives you a better chance of
supporting local fishing communities and getting fresher
seafood.
2. Was it caught or farmed within the EU?
Seafood safety standards in the EU are stronger than in
many other parts of the world. Choosing seafood from the
EU can reduce the likelihood that your fish is contaminated
with toxic substances that the EU considers illegal.
3. Is it farmed or wild?
In general, choose wild-caught. For farmed seafood, see
tip #5 below. Wild fish often carry fewer health risks for
consumers because they are not grown in large crowded
cages with antibiotics and pesticides. Wild-caught fish
aren’t always perfect, though — some types may contain
higher levels of mercury or other pollutants, so consumers
(especially parents and women that are pregnant or may
become pregnant) should watch for warnings about which
fish to choose for themselves and their children.
4. How is it caught?
Some fishing methods have high levels of bycatch or can
cause habitat damage. Ask whether the fish has been
caught using sustainable methods.
5. How is it farmed?
Choose types of fish that need fewer inputs. Farm-raised
mussels and clams can grow more easily without chemi-
cals and antibiotics. Ask your grocery or restaurant about
the type of farm seafood products come from. Avoid open-
water factory-farm-raised finfish that require large amounts
of wild fish as feed (such as most salmon). Wild fish are
used to produce feed for many farmed fish, taking food
away from other marine wildlife and from people that rely
on smaller fish for food. Farmed fish are often grown in
large, overcrowded open-water cages where fish waste,
excess feed and any chemicals used in the operation flow
straight into open waters. This can cause environmental
harm and human health problems. Also, the large busi-
nesses that grow these fish often overtake independent fish-
ermen and put them out of business, hurting smaller-scale,
local fishing communities. Fish farmed in land-based recir-
culating systems are currently harder to find in the market,
but can be a more environmentally friendly option.
6. Is it associated with any contaminants?
Overall, try to eat a variety of fish — don’t stick to just one
type. By doing so, your exposure to possible seafood con-
taminants can be reduced. This also helps to lower pressure
on wild fish that have become over-popular seafood choices.
Always ask questions about your seafood before you buy
— you have a right to know! This will also prompt restau-
rants and markets to pay attention to what they buy once
they know their patrons care. Learn about your seafood
and share your knowledge with others.
For a handy guide that you can keep
in your wallet and pull out when
you’re at a seafood market or sitting
down to dinner at your favorite
restaurant, check out our Smart
Seafood Guide at:
http://bit.ly/seafood-guide
15
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood
Endnotes
1 Food & Water Watch. “Laboratory Error.” 2008
2 Food and Agriculture Organization of the United Nations
(FAO). “The State of the World’s Fisheries and Aquaculture
2008.” March 2009.
3 Seafood Choices Alliance. “Constant Cravings: The European
Consumer and Sustainable Seafood Choices.” 2005 at 2.
4 Ibid at 10.
5 European Commission (EC). “Traceability, labeling and certi-
fication: informing consumers.” Fisheries and Aquaculture in
Europe No. 48, August 2010 at 5.
6 Ibid at 8.
7 World Wildlife Fund. [Press Release]. “Global Abalone
Sustainability Standards Completed,” October 14, 2010.
8 World Wildlife Fund. [Press Release]. “WWF to Help Fund
Creation of Aquaculture Stewardship Council.” January 27,
2009.
9 Royal Society for the Prevention of Cruelty to Animals
(RSPCA). “Are you ready to make a difference to the lives
of farm animals?” [Brochure / Presentation]. Freedom Food,
undated at page 16.
10 RSPCA. “Welfare Standards for Salmon.” July 2010 at 3.
11 Friend of the Sea (FOS). [Press Release]. “Dolphin Safe and
Friend of the Sea guide the tuna industry toward real sustain-
ability at Infofish conference in Bangkok.” May 23, 2008.
12 Friend of the Sea. [Leaflet]. “Friend of the Sea: Sustainable
Seafood,” undated.
13 The Global Aquaculture Alliance (GAA). Database:
“Members.” Accessed February 22, 2011; available at www.
gaalliance.org
14 Ibid.
15 Food & Water Watch. “GE Salmon Will Not Feed the
World.” November 2010.
16 As evidenced by www.soyaqua.org, a website devoted to
development in aquaculture and feed technology sponsored
by the U.S. Soybean Export Council, American Soybean
Association, and United Soybean Board, as well as by
the creation of an Aquaculture Initiative and Aquaculture
Director position by the Indiana Soybean Association in
order to increase use of soybean meal in farmed fish diets,
see: Indiana Soybean Alliance. [Press Release] “Hart Joins
Indiana Soybean Alliance as Aquaculture Director,” October
24, 2007.
17 Findus Group. [Press Release]. “Foodvest becomes Findus
Group.” May 20, 2009.
18 Global Aquaculture Alliance. [Press Release]. “Salmon
Technical Committee Membership Confirmed.” June 2010.
19 Global Aquacuture Alliance. [Press Release]. “Statement on
WWF-GLOBALGAP Linkage.” June 2009.
20 As evidenced by the shrimp farm standards for Global
Aquaculture Alliance. “Aquaculture Facility Certification:
Shrimp Farms.” Last revision in September 2009.
21 International Fishmeal and Fish Oil Organization. “Global
Standard for Responsible Supply: Requirements for
Certification.” September 7, 2009 at 3.
16
22 International Fishmeal and Fish Oil Organization. “Benefits
of Fishmeal and Fish Oil Use.” Available at: www.iffo.net,
2006. Accessed February 15, 2011.
23 Tacon, Albert G.J. “Global overview on the use of fishmeal
and fish oil in industrially compounded aquafeeds: Trends
and future prospects.” Aquaculture 285, 2008.
24 Unilever sold its seafood business in August of 2001, but
before that, it was one of the world’s largest buyers of frozen
fish, with a 25% share of the European and United States
markets; it also managed several fishmeal and fish oil com-
panies. Constance, Douglas H., and Alessandro Bonanno.
“Regulating the global fisheries: The World Wildlife Fund,
Unilever and the Marine Stewardship Council.” Agriculture
and Human Values, 17. June 2000 at 125 and 129.
25 Marine Stewardship Council. “Net Benefits: The first ten
years of MSC certified sustainable fisheries.” September
2009 at 3.
26 Marine Stewardship Council. [Press Release]. “MSC not
to develop aquaculture standard – MSC Board Statement,”
November 20, 2006.
27 Marine Stewardship Council. “Fisheries Certification
Methodology,” version 6. Revised September 2006. At
Section 3.4.1.
28 Marine Stewardship Council. “MSC Principles and Criteria
for Sustainable Fishing.” Versions 1.1, May 2010.
29 European Commission. Regulation No 710/2009, Aug. 5,
2009.
30 Ibid OJ L 204, 5.8. At16 and 22.
31 Ibid at 22 and 24.
32 Ibid at 30.
33 “Copper and Compounds.” Department of the Environment
and Water Resources, Australian Government, May 2007.
34 “Material Safety Data Sheet: Potassium Permanganate.”
Libox Chem. (India) Pvt. Ltd, Undated.
35 European Commission Regulation No 710/2009, Aug. 5,
2009. OJ L 204, 5.8.2009 at 16.
36 Soil Association. “Organic Standards: Aquaculture.” July
2010.
37 Bioland Germany. “Bioland Standards.” April 23, 2007.
38 Naturland. “Naturland Standards for Organic Aquaculture.”
Gräfelfing, Germany, May 2010.
39 KRAV. “Standards for KRAV Certified Production.” Uppsala,
Sweden, January 2009, Section 5.
40 Marine Stewardship Council. “Fisheries Certification
Methodology,” version 6. Revised September 2006. At
Section 3.4.1.
41 Ibid. See Sections 2.3.2. and 3.4.2.
42 Ward, Trevor J. “Barriers to biodiversity conservation in
marine fishery certification.” Fish and Fisheries, vol. 9. June
2008 at 175.
43 Jacquet, Jennifer, et al. “Seafood stewardship in crisis.”
Nature 467: 28-29. September 2, 2010.
44 Aquaculture Stewardship Council. “ASC Strategy.” Accessed
September 6, 2010. Available at www.ascworldwide.org
 Food & Water Europe
45 European Commission. “Traceability, labeling and certifica-
tion: informing consumers.” Fisheries and Aquaculture in
Europe No. 48, August 2010 at 9.
46 Fiorillo, John, “MSC Label in Jeopardy?” Intrafish Media. July
25, 2008
47 Friend of the Sea. “Fishery Check List: Wild-Caught.” 2009
at 2.
48 Stromsta, Karl-Erik. “Friend of the Sea vs. Marine
Stewardship Council: Only one?” Intrafish Media. July 31,
2008.
49 Burton, Bob. Inside Spin: The dark underbelly of the PR
industry. Crows Nest NSW, Australia: Allen & Unwin, 2007
at 164.
50 Produits Casino. “Nos gammes éco-citoyennes.” Accessed
January 13, 2011. Available at: http://www.produits-casino.
fr/developpement-durable/dd_nos-gammes-saveur.html
51 Gruszkowski, Patrice. “Les signes de qualité concernant
l’environnement et le développement durable en France
et en Europe.” L’Encyclopédi du Développement Durable.
Accessed January 13, 2011. Available at: http://www.
encyclopedie-dd.org/les-signes-de-qualite-concernant-l
52 Marz, Stacey, consultant to Trustees for Alaska. Letter to
Rupert Howes, chief executive of Marine Stewardship
Council. Sent April 25, 2005 on behalf of the Alaska Oceans
Program, the National Environment Trust, Oceana and
Trustees for Alaska. On file with Food & Water Watch.
53 Friend of the Sea. [Press Release] “Seafood Carbon Footprint
Calculator Allows Industry and Retailers to Offset their CO2.”
May 21, 2008.
54 Seafood Choices Alliance. “Constant Cravings” at 10.
55 Marine Fish Conservation Network. [Newsletter]. “Network
News.” Vol. 13, Issue 1. May 2008 at 1.
56 Food & Water Watch. “Expansion of Factory Fish Farms
in the Ocean May Lead to Food Insecurity in Developing
Countries.” June 2010.
57 For example, Friend of the Sea requires that evidence of
a decreasing FCR (feed conversion ratio) is available, but
does not require explicit calculation or declaration of FCR.
Friend of the Sea. “Farmed Products Certification Checklist
(English).” May 13, 2009 at 6.
58 Aquaculture Certification Council. “Aquaculture Facility
Certification, Certification Application Form.” Revision 5.
Jan. 15, 2009.
59 Tetreault, Irene. “Seafood Watch Seafood Report: Farmed
Tilapia (Oreochromis sarotherodon, Tilapia).” Monterey Bay
Aquarium, May 16, 2006 at 7; And Subasinghe, Dr. Rohana
et al. Food and Agriculture Organization of the United
Nations, Fisheries and Aquaculture Department, Inland
Water Resources and Aquaculture Service. Review of the
state of world aquaculture. FAO Fisheries Circular No. 886.
Rome: FAO, 2003 at 61-62.
60 El-Neklawey, E.M. A. et al. “Detection of testosterone
residues in farm fish tissue.” Beni-Suef Veterinary Medical
Journal, vol. 19, no. 1. January 2009 at 23-26.
61 Contreras-Sánchez, Wilfrido and Martin S. Fitzpatrick. “Fate
of methyltestosterone in the pond environment: Impact of
MT-contaminated soil on tilapia sex differentiation.” Pond
Dynamics and Aquaculture, Collaborative Research Support
Program, Oregon State University. Eighteenth Annual
Technical Report. 2001 at 83-86.
62 Contreras-Sánchez, Wilfrido and Gabriel Marquez-Couturier.
“Fate of Methyltestosterone in the pond environment: Use
of MT in earthen ponds with no record of hormone usage.”
Pond Dynamics and Aquaculture, Collaborative Research
Support Program, Oregon State University. Nineteenth
Annual Technical Report. 2002 at 103-106.
63 Wells, Sue et al. United Nations Environment Programme –
World Conservation Monitoring Centre. “In the Front Line:
shoreline protection and other ecosystem services from
mangroves and coral reefs.” 2006 at 14-17; Alongi, Daniel.
“Mangrove forests: Resilience, protection from tsunamis, and
responses to global climate change.” Estuarine, Coastal and
Shelf Science vol. 76, iss. 1. January 2008 at 6-7.
64 Mangrove Action Project [Press release]. “International
NGO network opposes WWF’s decision to form Aquaculture
Stewardship Council.” February 5, 2009; Mangrove Action
Project. [Action Alert]. “Wal-Mart and Darden Restaurants
announce future sourcing of ‘certified’ farm-raised shrimp.”
January 29, 2006.
65 Solidarity Center. “The True Cost of Shrimp: How Shrimp
Industry Workers in Bangladesh and Thailand Pay the Price
for Affordable Shrimp” (Series: Degradation of Work, Part 2).
January 2008 at 27.
66 Ibid at 16.
67 Constance, Douglas H., and Alessandro Bonanno.
“Regulating the global fisheries: The World Wildlife Fund,
Unilever and the Marine Stewardship Council.” Agriculture
and Human Values, vol. 17. June 2000 at 134.
68 Ibid at 133, 135.
69 Highleyman, Scott et al. Wildhavens, Turnstone Consulting
and Ecos Corporation. “An Independent Assessment of
the Marine Stewardship Council.” Prepared for Homeland
Foundation, Oak Foundation, and The Pew Charitable Trusts.
January 2004 at 11.
70 Marine Stewardship Council. [Press Release.] “MSC wel-
comes FAO guidelines on marine eco-labeling,” March 31,
2005.; Friend of the Sea.[Press Release]. “Friend of the Sea
distances itself from WWF’s MSC ‘Everything else stinks’
campaign,” May 21, 2008; International Fishmeal and Fish
Oil Organization. “Global Standard for Responsible Supply:
Requirements for Certification.” September 7, 2009 at 8.
71 FAO. “Guidelines for the Ecolabelling of Fish and Fishery
Products from Marine Capture Fisheries.” Rome, Italy, 2005.
72 A formal objection to the certification of Bering Sea /
Aleutian Island pollock by the Yukon River Drainage
Fisheries Association (YRDFA) was submitted in September
2010 but was rejected in the final determination in
December 2010. Bering Sea / Aleutian Islands pollock
and Gulf of Alaska pollock are both now covered by the
MSC eco-label through 2015. See Rice, Jake, et al. Moody
Marine, Ltd. “MSC Assessment Report for The Gulf of
Alaska Pollock (Theragra chalcogramma) Fishery.” Public
Certification Report, Version 5, September 28, 2010.; and
Rice, Jake, et al. Moody Marine, Ltd. “MSC Assessment
Report for the Bering Sea / Aleutian Islands Pollock (Theragra
chalcogramma) Fishery.” Public Certification Report, Version
5, December 14, 2010. Available at www.msc.org
73 These fisheries being considered for certification in-
clude anchovy, sardine, herring and hake fisheries.
See: Organización Internacional Agropecuaria. [Press
Release].”Argentine Anchovy,” November 12, 2010; and
MSC. “Annual Report 2009/2010.” April 1, 2010.
17
 De-Coding Seafood Eco-Labels: How the European Commission
Can Help Consumers Access Sustainable Seafood
74 Because the MSC allows fisheries that do not meet all
standards to be certified and labeled, it allows problem-
atic fisheries to ride on the eco-friendly reputation of more
sustainable fisheries in the program – this is referred to
as the “free-rider” problem. For example, see Condition
3.4.2 in MSC Methodology: “Where the fishery achieves
a score of less than 80, but of at least 60 for any indi-
vidual Performance Indicator, the certification body shall
set one or more conditions for continuing certification.”
Marine Stewardship Council. “MSC Fisheries Certification
Methodology.” Version 6, revised September 2006. At
Condition 3.4.2 on page 21.
75 Highleyman, Scott et al. Wildhavens, Turnstone Consulting
and Ecos Corporation. “An Independent Assessment of
the Marine Stewardship Council.” Prepared for Homeland
Foundation, Oak Foundation, and The Pew Charitable Trusts.
January 2004 at 11.
76 The fact that this fishery later in 2010 sustained record runs
(occurring several weeks after the certification was deemed
effective) should not dissuade from considering this certifica-
tion a violation of the precautionary approach. At the time
of certification and prior, there was no knowledge of, or
evidence that such a drastic uptick in the population would
occur; MacLeod, Andrew. “Sockeye Eco-Certification Kicks
up Storm.” The Tyee (British Columbia, Canada). January
21, 2010.
77 FOS has certified companies that catch and sell large quanti-
ties of forage fisheries, such as Omega Protein Corporation,
which processes menhaden into fishmeal and fish oil. See:
Franklin, H. Bruce. “The Most Important Fish In the Sea.”
Island Press, 2007. See also: Omega Protein. [Press Release].
“Omega Protein Receives 2009 Friend of the Sea Award.”
April 28, 2009.
78 For example, visit Friend of the Sea. “Downloads – English
Version Documents.” Accessed February 21, 2011. Previous
versions of FOS’s website yielded downloadable PDF docu-
ments, but several of these were only available in Italian.
On file with Food & Water Watch.
79 FOS does not require audits beyond the minimum required
by FAO, and peer review of a fishery to be certified to
FOS does not appear to be incorporated into the assess-
ment process. See Friend of the Sea. [Audit and Licensing
Agreement]. “Agreement concerning the Friend of the Sea
Audit and Licensing of the Trademark Friend of the Sea.”
Undated. Available at www.friendofthesea.org
80 IFFO’s very mission, to certify forage fish stocks as sustain-
able, could result in over-extraction and adverse impacts on
the ecosystem, such as harm to marine mammals. Depleting
forage fish stocks can harm marine food webs and negatively
impact food security in developing countries. International
Fishmeal and Fish Oil Organization. “Plants Approved
Under the IFFO Global Standards for Responsible Supply
(IFFO RS).” Updated September 7, 2010.
81 Smith, Martin D. et al. “Sustainability and Global Seafood.”
Science, vol. 327, no. 5967. February 12, 2010 at 784-786.
82 FAO. [Press Release] “First global guidelines for aquaculture
certification finalized.” October 1, 2010.
83 FAO. “Technical Guidelines on Aquaculture Certification
Version adopted by the COFI Sub-Committee on
Aquaculture in its fifth session.” Phuket, Thailand, 2010.
84 Solidarity Center. “The True Cost of Shrimp” at 16.
18
85 Mangrove Action Project [Action-Alert]. “Wal-Mart and
Darden Restaurants announce future sourcing of “certified”
farm-raised shrimp.” January 29, 2006.
86 Ibid.
87 Friend of the Sea. “Certification Criteria Checklist for
Aquaculture Products: Marine Aquaculture.” Updated April
1, 2010. See Criterion 5.2 for FCR.
88 Based on a thorough review of FOS’s website, it does not
appear to be the case that
peer review is required of any audit. See Friend of the Sea.
“Frequently Asked Questions” at “The Audit Process.” Page
undated. Available at http://friendofthesea. org/faq.asp, ac-
cessed February 23, 2011; and FOS. “Stakeholders.” Page
undated. Available at http://friendofthesea.org/stakeholders.
asp , accessed February 23, 2011.
89 Friend of the Sea. “Certification Criteria Checklist for
Aquaculture Products: Marine Aquaculture.” Updated April
1, 2010.
90 Black, K.D., Hansen, P.K. and Holmer, M. “Salmon
Aquaculture Dialogue: Working Group Report on Benthic
Impacts and Farm Siting.” 2008 at 4.
91 RSPCA. “Welfare Standards for Salmon.” See “Wider
Environmental Impact.” July 2010 at 49-50.
92 RSPCA. “Welfare Standards for Salmon” at 22.
93 FAO. Technical Guidelines on Aquaculture Certification.
Version adopted by the COFI Sub-Committee on
Aquaculture in its fifth session in Phuket, Thailand. 2010 at
84.
94 World Wildlife Fund. [Press Release]. “Global Abalone
Sustainability Standards Completed,” October 14, 2010.
95 Oloruntuyi, Yemi. “Workshop on Eco-labelling and Fisheries
Sustainability in Morocco.” Marrakech, Morocco. December
1-3, 2010.
96 MSC. [Press Release] “Connétable, Findus, Labeyrie,
Carrefour and the MSC join forces to promote certified sus-
tainable seafood.” January 25, 2010.
97 Davies, Kit. “JS and Co-op make MSC pledges.” Grocer.
March 15, 2003
98 Cooperative Group. [Press Release]. “Cooperative Commits
Funding for More Sustainable UK Fisheries. August 14,
2008.
99 Marine Conservation Society. [Press Release.] “Results of
2009 Supermarket Survey.” November 26, 2009.
100 Verbeke, Katrien. “Delhaize and its sustainable fish ap-
proach.” FRDO, Brussels, January 19, 2010.
101 Seafood Choices Alliance. [Press Release]. “Seafood Choices
Alliance Names First ‘Seafood Champions’ at Awards
Breakfast During International Boston Seafood Show, March
13, 2006.”
102 Holland, Jason. “Q&A: Marks & Spencer’s sustainability
pledge.” Seafoodsource.com, May 17, 2010.
103 Davies, Kit. “JS and Co-op make MSC pledges.” Grocer.
March 15, 2003.
104 Groupe Casino. “Products that are Friendly to People and
the Environment.” Accessed on January 13, 2011. Available
at: http://www.groupe-casino.fr/en/Products-that-are-
friendly-to.html
 Food & Water Europe

105 Produits Casino. “Nos gammes éco-citoyennes.” Accessed

January 13, 2011. Available at: http://www.produits-casino.
fr/developpement-durable/dd_nos-gammes-saveur.html
106 Gruszkowski, Patrice. “Les signes de qualité concernant
l’environnement et le développement durable en France
et en Europe.” L’Encyclopédi du Développement Durable.
Accessed January 13, 2011. Available at: http://www.
encyclopedie-dd.org/les-signes-de-qualite-concernant-l
107 Stacey, Margaret. “Sainsbury’s Sells Over 55 MSC Products.”
FIS. December 9, 2009.
108 J Sainsbury’s plc. “Corporate Responsibility Report 2010.”
2010 at 35.
109 Food & Water Europe. “Fishy Formula: Why the European
Strategy Doesn’t Add Up to Sustainable Aquaculture.” June
2010.
110 J. Sainsbury’s plc. [Press Release]. “Sainsbury’s helps Marine
Stewardship Council (MSC) reach 7,000 products world-
wide.” November 22, 2010.
111 “Long road to full sustainability, says Tesco Chief.”
Fishupdate, March 25, 2008.
112 Marine Stewardship Council. [Press Release]. “Tesco Boosts
Commitment to fresh, sustainable seafood.” November 15,
2005.
113 Food & Water Europe. “Fishy Formula: Why the European
Strategy Doesn’t Add Up to Sustainable Aquaculture.” June
2010.
114 Tesco. “The Tesco Salmon Range.” Livestock Standards,
2010. Available at www.tescofarming.com
115 Client Earth. “Environmental claims on supermarket seafood:
Improving product labeling and consumer protection.”
January 2011.
116 Seafood Choices Alliance. “Constant Cravings” at 2 and 10.

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