To the Department of Industry Science, Energy and Resources,
Thank you for the opportunity to contribute the perspective of Minderoo Foundation on the importance of country of origin labelling for food (CoOL), in particular seafood, in response to your “Evaluation of Country of Origin Labelling for Food: Discussion Paper”.
Minderoo Foundation is an Australian philanthropic organisation, tackling persistent issues with the potential to drive massive change. Through a collaborative, evidence-based approach we strive to solve major global challenges. Our Flourishing Oceans and Walk Free initiatives have significant expertise in research and advocacy in sustainable fisheries and modern slavery throughout supply chains.
We are sharing our position on the issue of CoOL with respect to how it applies to the sale of seafood in Australia. Current CoOL laws have been instrumental in assisting Australia consumers make informed choices when purchasing raw, uncooked seafood. However, the current exception to these laws to cooked products within the food service industry prevents this scrutiny being applied to a significant proportion of seafood for sale on Australia shores.
As the ocean is the largest ecosystem of earth, it is impossible to overstate the value of the ocean both to our planetary health but also to its role in human health. As just one example, while seafood is an invaluable source of protein for billions of people, it also plays a unique role in delivering micro-nutrients that are particularly valuable to pregnant women and children. The economics of global fisheries are staggering, accounting for an estimated 59.5 million jobs globally just in wild capture fisheries. Seafood is a truly global commodity, valued at an estimated $400 billion per year, with complex supply chains that stretch around the planet.
Australians love seafood. The average Australian now eats roughly double the amount of seafood we consumed in 1975. Today, 70 per cent of all seafood consumed in Australia is imported from overseas. While seafood caught and harvested within Australian waters is covered by strict fisheries management laws that aim to achieve sustainable fisheries, this is not the case in many parts of the world. Unfortunately, many countries do not enforce the same environmental standards as Australia when farming and fishing. With fish stocks decreasing around the world, the ability of consumers to help drive more responsible market practices by making an informed choice is critical to ensuring equity and sustainability of fisheries globally.
Over-fishing also overlaps with human rights abuses. Research suggests nearly 40 per cent of the global industrial seafood catch comes from fleets at a high risk of exploiting workers through modern slavery practices. Furthermore, Australia’s seafood imports are mainly from Asia, one of the major regions where crew on vessels are at particularly high risk of modern slavery. According to the 2018 Global Slavery Index, more than US $368 million worth of at-risk seafood was imported into Australia in 2015.
If Australians want to avoid consuming seafood caught using forced or slave labour, or caught in regions with poor fisheries governance, it is vital that consumers are able to check country of origin of seafood in food outlets. Country of origin labelling in food outlets enables consumers to make informed choices.
In Australia we lack the ability to trace our seafood origin or supply chain to ensure it was legally, sustainably, and ethically produced. The CoOL labelling has been instrumental in helping customers make an informed choice when purchasing raw seafood. Through CoOL legislation all raw seafood sold in Australia – packaged or unpackaged, imported or domestic – must be labelled with the country of origin. This legislation does not, however, apply to food service. As a result, cooked seafood is exempt from the labelling requirements.
When consumers eat any type of cooked seafood that has been prepared and cooked for immediate consumption, the food service industry is under no obligation to tell you the species of fish or where it came from. Sellers of all cooked seafood are not required to disclose details on species or how it was caught or farmed, making it impossible for consumers to make conscious choices when buying cooked seafood.
The primary distribution channel for seafood to consumers in Australia is via the food service industry, including takeaway outlets, fishmongers and restaurants. This consumption pattern results in a significant proportion of seafood currently consumed in Australia not being subject to the CoOL laws. This exemption represents a critical gap in the current scope of country of origin labelling in seafood.
We urge you to close this gap in country of origin labelling related to food service. For Australian consumers to make an informed choice about what they are eating, they must know where it came from, and how it was caught or farmed. The Australian government must facilitate transparency in the fishing industry to ensure the legality of products, rebuild flourishing oceans, safeguard the future of fishing, and stop the terrible breaches of human rights suffered by workers on fishing boats around the world.
Established by Andrew and Nicola Forrest in 2001, we are a modern philanthropic organisation seeking to break down barriers, innovate and drive positive, lasting change. Minderoo Foundation is proudly Australian, with eight key initiatives spanning from ocean research and ending slavery, to collaboration in cancer and community projects.