The prevalence of mislabeled seafood has grown to such a level that it threatens to impact the integrity of the entire market for seafood. Victims of seafood fraud not only include consumers, but also food retailers that are trusting a supply chain that is fraught with misleading labeling practices.
Explore this issueApril/May 2017
A 2015 Oceana study revealed the mislabeling of one of the America’s favorite fish—salmon. Oceana collected 82 salmon samples from restaurants and grocery stores and found that 43 percent were mislabeled. DNA testing confirmed that most of the mislabeling consisted of farmed Atlantic salmon being sold as wild-caught product. Further, in September 2016 Oceana tested 25,000 samples of seafood caught around the globe, and said an average of one out of five samples was mislabeled. The organization reviewed more than 200 published studies from 55 countries, with all but one finding seafood fraud. Fraud was found in every sector of the supply chain.
While seafood fraud is a global issue, for the U.S. it is particularly unsettling as more than 90 percent of the country’s consumed seafood is imported from other countries around the world…and from countries lacking stringent aquaculture laws.
Retailers and consumers deserve to know the facts about their seafood’s supply chain journey, including what kind of fish it is, how and where it was caught and processed (i.e. is it from legal fishing waters, a sustainable fishery, produced without any forced labor or child labor?), and most importantly, trust the information is accurate. Food retailers and restaurateurs refusing to acknowledge seafood fraud risk damage to their corporate reputation, integrity, and balance sheet. So what’s being done about it?
A lot can happen during the journey from a fisherman’s boat to the shelf to the dinner table. Many food retailers and restaurants are investing in traceability strategies to gain better insight into a seafood product’s itinerary for the following four reasons.
- Quality. Knowing the seafood’s journey and how it has been caught or handled along the way will tell food retailers a lot about its quality.
- Trust. Each species has a specific taste, recognition, and value in the market. Traceable products track who handles and treats the product at each step of the supply chain—if the seafood is traceable, food retailers can feel confident that they are getting the right species they paid for.
- Health. Traceability alleviates health concerns allowing food retailers to recall bad product and hold suppliers and processors accountable; provide accurate freshness dates; and identify whether or not acceptable chemical additives were used to preserve the product.
- Sustainability. Consumers are growing more concerned by over-fishing, bio-diversity reduction, ocean pollution, and bad social practices in the seafood industry. Traceability allows food retailers and restaurants to ensure their fish are coming from a sustainable and reputable source.
A number of supply chain traceability programs have been developed to ensure the integrity of seafood supply chains. For example, the Obama Administration announced on Dec. 8, 2016 that it had implemented a program to help prevent illegal fishing and seafood fraud. The final rule, scheduled to go into effect on Jan. 1 of 2018, directs the National Oceanic and Atmospheric Administration (NOAA) to install a Seafood Import Monitoring Program that will track about 25 percent of imported seafood from fishing boat to U.S. borders. The rule seeks to decrease the incidence of seafood fraud by requiring product reporting at the time of importation to the U.S. government and complying with a report verification process.
As cited per the Federal Register, pursuant to the Magnuson-Stevens Fishery Conservation and Management Act, the final rule establishes permitting, reporting, and recordkeeping procedures relating to the importation of certain fish and fish products identified as being at particular risk of illegal, unreported, and unregulated fishing or seafood fraud.
Collection of catch and landing documentation for certain fish and fish products will be accomplished through the government-wide International Trade Data System. The rule requires data to be reported on the harvest of fish and fish products. In addition, this rule requires retention of additional supply chain data by the importer of record and extends an existing National Marine Fisheries Service requirement to obtain an annually renewable International Fisheries Trade Permit to the fish and fish products regulated under this rule. The information to be reported and retained, as applicable, under this rule will help authorities verify that the fish or fish products were lawfully acquired by providing information to trace each import shipment back to the initial harvest event(s).
However, the rule is facing heavy challenges and adversity to its purpose as a few of the fishing industry’s biggest players including the National Fisheries Institute have sued the NOAA and Department of Commerce for placing what they say is an onerous and expensive burden on importers who already follow the rules.
In 2000, the Marine Stewardship Council (MSC) also developed a sustainable fishery standard and “Chain of Custody” traceability with certification that is applicable to the full supply chain from a MSC-certified fishery to final sale. In 2012, the Aquaculture Stewardship Council (ASC) developed a responsible aquaculture standard with the same traceability standard of MSC. Every company in the supply chain handling or selling of an MSC- or ASC-certified product must have a valid Chain of Custody certificate. This means that seafood sold with the MSC or ASC label can be traced back to the ocean or the aquaculture farm, giving buyers confidence in its origin and means of production.
Companies certified against the MSC-ASC Chain of Custody standard are audited regularly to ensure that they meet five traceability requirements: 1) seafood products can only be purchased from MSC-certified suppliers and from MSC-certified fisheries or ASC-certified farms; 2) MSC-certified seafood products must be identifiable; 3) MSC-certified seafood products must be segregated from non-MSC-certified seafood at each step of the supply chain; 4) MSC-certified seafood product volumes must be recorded; and 5) the MSC-certified organization must have a document management system. Each processor, storage, trader, and importer in the world who wants to use MSC or ASC label must be audited by accredited third-party certification body.
In addition, a new digital tracing technology called blockchain is on the rise and being tested in the seafood industry. Originally used to track the digital currency bitcoin, blockchain is a digital ledger in which transactions are recorded chronologically and publicly. New information cannot be removed or changed after it has been recorded. Blockchain aims to replace the severely outdated process of tracking seafood through tags and paper records by digitally tracking seafood across the supply chain.
The new blockchain approach allows fishermen to record their harvest (i.e. date, type of species, quantity, fishing area, fishing gear, name of vessel) and register their catch on the blockchain system. The data is then sent to the fish processor. When the fish are processed, packed, and stored, the processor records data to the blockchain system and forwards on to the next client in the chain until it reaches its final destination. The information on the origin and supply chain journey of the seafood can then be accessed and verified on smartphones used by retail buyers, restaurateurs, and consumers.
Label Verification Training
There is no universal seafood labeling system for grocery stores so buying fish products often requires a little diligence to ensure it is what it is. However, the FDA launched an online learning module to help food retailers ensure the proper labeling of seafood products offered for sale in the U.S. marketplace. Proper identification of seafood is important throughout the seafood supply chain to ensure that appropriate food safety controls are implemented and that consumers are getting the type of seafood they expect and for which they are paying.
The module provides an overview of the federal identity labeling requirements for seafood offered in interstate commerce; a list of the specific laws, regulations, guidance documents, and other materials pertinent to the proper labeling of seafood; a description of the FDA’s role in ensuring the proper labeling of seafood; and tips for identifying mislabeled seafood in the wholesale distribution chain or at the point of retail.
Third-party verification experts provide food retailers with a number of benefits. Among them is their impartiality to data allowing for trusted, ethical reporting. They can also offer counsel on the correct setup of tracing product authenticity (including MSC, ASC, and blockchain), further reducing any need for unnecessary expenditures due to fraud or labeling mistakes. Finally, they have access to state-of-the-art equipment and technology that can synthesize and analyze data to identify trends and opportunities for supply chain improvements, remedies, and corrections.
For example, in 2015 one of the world’s largest tuna trading companies in Asia employed a third-party provider to verify the traceability of its tuna supply before it was shipped to a cannery facility. The verification program focused on ensuring there was no use of fish aggregating devices (FAD), a man-made object commonly used to attract tuna, in the supply chain. The certifier examined 30 large fishing vessels in Pacific Ocean, transshipment to 20 carrier vessels, and discharge to a Bangkok port. After the assessment was complete, a FAD-free traceability standard was set into place and today the supply chain remains consistently monitored to ensure compliancy is maintained. Tuna suppliers who meet the FAD-free standard requirements receive a certificate of recognition to verify their compliance in Asia and to other international customers that require it.
In conclusion, consumer trust demands that the seafood they buy is what it says it is. Until a unified global tracking process is in place to tackle fraud, food retailers must ask the hard questions about where their seafood comes from and employ a traceable or verified system so to ensure what you “sea” is what you get.
Hoemeke is vice president of agriculture and foods at Bureau Veritas North America. Reach him at email@example.com.