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What we heard report: Government of Canada consultation on boat-to-plate traceability for fish and seafood products

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Introduction

The 2019 Minister of Health's mandate letter introduced a commitment to develop a boat-to-plate traceability program to help Canadian fishers to better market their high-quality products. This was to be done in collaboration with the Minister of Fisheries and Oceans Canada and the Canadian Coast Guard, and the Minister of Agriculture and Agri-Food. Since that time, the Government of Canada has engaged various stakeholders, other levels of government, and Indigenous rights holders in the fish and seafood sector to better understand their perspectives on this commitment. This was accompanied by a broad public consultation seeking feedback on a Discussion paper: Boat-to-plate traceability mandate commitment, from August 13, 2021, to December 11, 2021.

The discussion paper sought feedback on the following 3 key themes, which were identified as being key drivers behind the mandate commitment:

Since traceability is a potential tool that relates to each of the 3 themes, the topic of traceability was embedded within these themes.

This report summarizes the feedback received during the consultation. As such, it reflects the views expressed by participants, and not those of the Government of Canada.

Who we heard from

The Canadian Food Inspection Agency (CFIA), Department of Fisheries and Oceans (DFO) and Agriculture and Agri-Food Canada (AAFC) carried out the boat-to-plate traceability consultation jointly. The 3 departments issued a questionnaire (online or in print) that included an optional demographic sub-questionnaire. In response, the following was received:

Of the 171 unique responses (64 optional online questionnaire demographics and 100 unique emailed responses), the breakdown is as follows:

What we heard

Overall, respondents welcomed the opportunity to provide feedback on the boat-to-plate traceability initiative. They also expressed support for the federal government's efforts to seek feedback to inform approaches to fulfill the mandate commitment.

CFIA, DFO and AAFC were pleased to receive responses from a broad range of partners and stakeholders, including individuals and organizations. This diversity of responses provided insight from a number of perspectives, from consumers living in coastal communities who purchase fresh fish from local fishers, to consumers from central Canada who trust their retailer or restauranteur for their purchases; and from individual fishers and seafood businesses to large industry associations and non-government organizations (NGO) representing many members. We also heard from partners in provincial and territorial levels of government in Canada.

Because this report reflects questionnaire responses, letters and emails from individuals, as well as organizations representing many members, it was not possible to quantify the results in a representative way. Instead, general, qualitative descriptions of the nature of the input are provided. For example, "some", "many" and "most" are used to describe the volume of respondents who provided the feedback.

Highlights

Most respondents indicated that they appreciate the value of traceability in the fish and seafood sector. They had varying preferences for a suitable approach to this, from a comprehensive regulatory system to an industry-driven voluntary one.

Many comments relating to traceability did not make a distinction between the intended purposes of these systems. Distinct objectives of traceability systems noted by respondents relate to food safety traceability and to the legality or sustainability of products. Legality was explained as whether or not fish and seafood is harvested according to sound fisheries management requirements, whether domestically or abroad. Sustainability relates to whether fish or seafood is grown or harvested in a way that maintains the health of existing stocks and ecosystems over time.

There was general recognition by participants that CFIA's existing food safety traceability measures enable processing facilities in the fish and seafood sector to effectively trace and retrieve affected fish and seafood lots in the case of a recall.

Some respondents indicated that there are opportunities to increase consumer confidence by enhancing existing labelling tools, such as the CFIA Fish List, and by improving clarity and availability of information for consumers to better identify domestically harvested seafood.

Responses from the majority of participants show strong interest in sustainably harvested fish and seafood. While respondents were generally aware of DFO's efforts to sustainably manage Canadian fish and seafood, some questionnaire respondents noted specific concerns with respect to fisheries management, compliance and enforcement in Canada.

However, since most of the seafood consumed in Canada is imported, many respondents expressed concern that current traceability requirements are not adequate to verify that imported products are produced following equivalent standards to those for domestic fisheries management and sustainability. Responses linked increased traceability of tracking elements (such as harvest area and catch method) to potential benefits, such as sustainability, detecting IUU fishing and aligning with export requirements.

Some respondents expressed concern that increased costs related to traceability could disproportionately burden domestic industry. Additionally, many respondents indicated that it is important to consider how any measures would affect costs to the consumer, with one suggesting any increased costs to the consumer could have a detrimental effect on sales of fish and seafood products. Additionally, some participants expressed concern about the time it is taking to determine appropriate approaches to boat-to-plate traceability in the Canadian context.

Theme 1: Consumer protection and food safety

Seafood misrepresentation and mislabelling

Misrepresentation and mislabelling occur when advertising or labelling of a food does not align with what the food actually is or contains, leading to various negative impacts. CFIA is responsible for enforcing subsection 5 (1) of the Food and Drugs Act (as it relates to food) and subsection 6 (1) of the Safe Food for Canadians Act, which prohibit, in part, the false, misleading or deceptive representation of food.

The discussion paper summarized activities CFIA does to address fish and seafood misrepresentation and mislabelling, and asked respondents a series of questions to better understand:

What we heard

Overall, respondents recognize that complete and accurate food labelling and representation is essential to making informed purchases in the Canadian marketplace.

A large majority of respondents indicated that they are aware of the potential for fish species being misrepresented on the label and some respondents indicated that they can recall an instance where the fish they purchased appeared to be misrepresented. Respondents mentioned a number of signs of potential misrepresentation, including:

Another comment about mislabelling was that when it occurs, it is not necessarily all fraudulent or intentional. For example, in some cases, it may be the result of nomenclature issues (for example, mistakenly using a common name that is used in another country but is not on the CFIA Fish List), or data integrity deficiencies in the supply chain.

In addition to fish species substitution, respondents expressed concern about potential misrepresentation with respect to:

Respondents indicated that fish and seafood species are harder to identify as they are further transformed or move through the supply chain, due to changes such as filleting, removal of skin, freezing, and addition of spices, breading or sauces. Respondents also indicated that there may be particular challenges within the restaurant, foodservice, and retail industry that can make it difficult to consistently authenticate fish received from suppliers. This can be due to factors such as high turnover, training gaps and availability of product information from the supplier.

In addition to existing activities implemented by the CFIA and industry to address misrepresentation and mislabelling, respondents recommended that the following additional measures would be effective:

Some respondents offered to play an active role in educational campaigns aimed at raising awareness about misrepresentation, supporting prevention and compliance, and increasing consumer confidence in Canada.

Food labelling

The discussion paper summarized relevant labelling requirements related to the naming of fish and the identification of origin. A further overview was provided on the requirements if voluntarily providing optional information, as well as on labelling of catch method or farming, which is mandatory in some countries. The paper outlined that there is no limitation to voluntarily provide information related to things like catch method, farming, or harvest location in addition to mandatory country of origin, provided such information is not false, misleading, deceptive, or likely to create an erroneous impression.

Respondents were then asked a series of questions about using and understanding labelling information, accessing information about fish and seafood products directly from a company and ranking of important factors when purchasing fish and seafood. There was also an industry specific question on labelling of items such as scientific species name, harvest location and catch method.

What we heard

We heard from some respondents that they want the scientific name of the fish or seafood species to be required on the label, alongside the common name, while other respondents suggested that this may confuse consumers. Most indicated that they have not experienced a situation where they were unable to make an informed purchasing choice about the type of fish because the scientific species name was not on the label. About half of the respondents to the questionnaire indicated that the common name sufficiently identifies fish or seafood.

Respondents who indicated that the common name did not sufficiently identify the fish or seafood product indicated that common names can sometimes be generic, with the example of "shrimp" given as a common name for 41 different species.

On average, respondents to the questionnaire ranked "country of origin" as the second most important factor when purchasing fish and seafood. Several respondents flagged that current country of origin labelling can be misunderstood by consumers. Only about half of consumer respondents were aware that the country of origin for the purpose of labelling is the country where the food undergoes the last substantial transformation.

Many respondents indicated that, in addition to the country of last substantial transformation, the location of harvest or production (aquaculture) is also important and would help consumers with their purchasing decisions. It was suggested that CFIA explore labelling options for seafood that would allow geographic location of harvest as an alternative to country of origin (last substantial transformation). We also heard concerns that mandating the declaration of harvest location could be challenging for some fisheries.

Respondents were asked to rank the factors most important to them when purchasing fish and seafood. From 1 to 12, respondents ranked the following factors from most important to least important:

  1. freshness/quality
  2. country of origin
  3. sustainably sourced/certified on label
  4. wild caught
  5. best-before date marked on the label
  6. price
  7. traceability information on label
  8. catch methods and their effect on fish stocks and ecosystems
  9. brand
  10. organic
  11. farmed fish
  12. information about fishing gear on the label

Although price was at the mid-point in the list, the importance of this factor was highlighted by some respondents. For example, a participant noted an independent study that referenced cost as the largest barrier to increased fish and seafood consumption. Additionally, the possibility of increased regulatory burden meaning higher costs to consumers was raised as possibly being counter-productive to the objectives of the mandate commitment of supporting the marketing of fish and seafood, as well as to healthy eating objectives that include fish and seafood as part of our diet.

While some commented that they would like to see labels include information on fishing gear, this ranked as lowest in importance to those who responded to the questionnaire.

Many industry respondents were supportive of non-regulatory approaches that provide information to consumers about their purchases and reduce consumer confusion. They emphasized that education and adopting new technologies (for example, QR codes) would allow more product information to be shared quickly and more accurately.

Most respondents indicated that they have never contacted a food business to get information that was not provided on the label, stating that it is inconvenient, time consuming, and that they are not confident they would get an answer. Many consumers stated that they simply don't purchase a product if they have insufficient information.

About half of respondents who indicated that they have contacted a food business to get information that was not on the label said that the information was made available to them. Some respondents indicated that they purchase seafood from local suppliers they trust or that they have enough knowledge of the fish and seafood in general to make informed purchasing decisions.

"Accurate labelling is the key. There is a difference between country of origin and country of production. Most people do not know that some prawns or fish travelled the world just to get onto the plate of a consumer. Consumers nowadays are very environmentally aware and would oppose the amount of energy inputted."

Discussion paper respondent

The CFIA Fish List

The discussion paper described the CFIA Fish List, which is a tool that provides guidance on common names for fish and seafood. Respondents were asked several questions regarding their awareness and use of the CFIA Fish List, its value and utility, and whether they used other tools to determine acceptable common names. Questions were also posed on alternative approaches to maintaining the CFIA Fish List.

What we heard

The majority of consumer respondents indicated that they were unaware of the CFIA Fish List before reading the boat-to plate discussion paper. Industry and NGO stakeholders, however, indicated that it is an important resource to help determine the common name, with some recommendations for improvement. Respondents generally pointed out that existing online resources, including the CFIA Fish List, are industry focused and not well understood or used by consumers. This is not surprising because these tools are primarily intended to promote industry compliance with regulatory requirements.

Respondents with an awareness of the CFIA Fish List identified the following issues:

CFIA has received many recommendations on improvements to the CFIA Fish List from various partners and stakeholders over the years. The discussion paper provided the opportunity to suggest alternative approaches to maintaining the list, potentially with stakeholder involvement. While there were no alternative approaches suggested, respondents recommended that CFIA consult regularly with other government departments, NGOs, academia and industry on its contents, and suggested improvements such as increased alignment between the CFIA Fish List and parallel lists of Canada's trading partners such as The Seafood List in the United States.

Food safety traceability

The discussion paper described the food traceability requirements under the Safe Food For Canadians Regulations (SFCR), which require most food businesses to track food "one step forward and one step back." These rules allow food to be traced from one point in the supply chain to the next, and they contribute to food safety objectives such as aiding the quick removal of unsafe food from the marketplace when necessary. Traceability rules in place for the purposes of food safety include requirements for both documentation and labelling.

Respondents were asked a series of questions about traceability for the purposes of food safety, including whether there are gaps, using technology or electronic means to maintain traceability records, and considerations around expanding the scope of existing requirements.

What we heard

Respondents indicated that processing facilities in the fish and seafood sector are able to effectively trace and retrieve affected lots in the case of a recall under existing traceability requirements. Despite this, approximately one-third of respondents indicated that they see gaps in the supply chain where they believe the food safety traceability requirements of the SFCR do not apply. The main areas where participants noted potential gaps were:

There were also comments about gaps at the retail level, as well as products containing multiple ingredients, but these appear to be based on the perception of those who participated in the consultation rather than on the actual scope of SFCR requirements.

Some respondents expressed concerns that there are no linkages between traceability information along the supply chain with a "one up, one down system." Information is passed from a regulated party to another without having to provide documentation of previous origin or being able to fully trace a product through the supply chain.

Additionally, many respondents indicated that current food safety traceability systems are not aligned across the supply chain because companies keep individual records using proprietary systems. These systems vary; for example, some companies may use paper-based systems while others use electronic ones, and the electronic software used to store the data varies between companies.

"What is universally beneficial, however, is to focus less on the platform and more on the data structuring techniques to ensure interoperability, or the ability to exchange and make use of information, between the various systems in use across the industry."

Discussion paper respondent

Theme 2: Sustainability and fisheries management related to traceability and combatting illegal, unreported and unregulated fishing

IUU fishing is recognized as a major contributor to the decline of fish stocks and marine habitat destruction worldwide. Fish and seafood traceability programs can help combat these activities by making it possible to trace fish and seafood back to the point of origin. Several jurisdictions, including the European Union and the United States, have introduced traceability requirements for fish and seafood imports to address these concerns. In addition to government-mandated traceability in some countries, many fish and seafood businesses have adopted in-house or third-party certification approaches that verify a product's origin or promote sustainable sourcing.

The discussion paper described a number of activities that DFO currently undertakes to improve sustainable fisheries management, combat global IUU fishing, and provide consumers with information about the origin and sustainability of fish and seafood. It asked respondents a series of questions to better understand:

What we heard

All respondents acknowledged the importance of traceability measures to improving the sustainability of fisheries and combatting IUU fishing, whether industry led or government backed. Detailed responses are broken down according to the themes below.

Sustainability and IUU fishing

To maintain sustainable fisheries, respondents acknowledged the need to preserve fish stocks, protect ocean biodiversity and prevent IUU fishing. Respondents recognized that IUU fishing is a significant threat to the global sustainability of fisheries, posing risks to the health of ocean ecosystems, fisheries management efforts and industry actors. Some respondents stated that governments should take stronger measures to prevent these activities.

Generally, we heard that existing management and enforcement measures in Canada are viewed as largely effective in preventing significant non-compliance with Canadian legislation (The Fisheries Act). However, many respondents had concerns that fish imported into or re-exported from Canada may not have been harvested in a sustainable manner, including overfishing of endangered species and unsustainable fish farming practices. They were also concerned about the potential presence of toxins, chemicals, and additives in seafood products. Without an effective traceability system in place to clearly identify the geographical location of harvest, respondents noted that it was difficult to discern whether the seafood they buy is sustainably harvested or not.

Respondents noted the importance of existing domestic fisheries management efforts to regulate volumes, control the type of species caught and prevent overfishing. It was also stated that more oversight of aquaculture and fish farming operations and their impacts on native fish populations and the environment would be beneficial to ensure sustainability.

Other concerns that were noted include:

"Canada has a strong domestic system currently in place to ensure traceability with regards to health and safety concerns and to eliminate illegal, unregulated, and unreported (IUU) fishing within Canada's borders from both domestic and international supplies."

Discussion paper respondent

Information to consumers

The discussion paper asked respondents to provide views on whether current information available to consumers meets information needs relating to the sustainability and legality of fish and seafood.

What we heard

Some respondents felt that current approaches are meeting consumer needs and that consumer demand for information can be met through existing traceability initiatives led by industry or third-parties, such as the Marine Stewardship Council.

In contrast, others stated that there is increasing demand from consumers for information on harvesting or aquaculture practices and the product supply chain, and that current approaches such as food labelling requirements are not meeting these demands. These respondents indicated that additional information would be welcome and could help boost consumer confidence that seafood products are sustainably farmed or harvested, and are not contributing to illegal or harmful environmental and human rights practices.

Several respondents also stated that increasing consumer demand for transparency is a global trend that is shifting practices within the seafood industry. In their view, Canadians' expectations for transparency are likely to be shaped by the way the traceability initiatives are implemented elsewhere.

Existing traceability measures

The discussion paper provided an overview of existing food traceability measures in Canada and asked respondents to provide views on whether these measures provide enough information to determine whether fish and seafood sold in Canada is sustainably or legally sourced. Respondents had differing views on whether current traceability requirements administered by CFIA are sufficient to determine this.

What we heard

We heard that the lack of information on the origin, legality and sustainability status of imported seafood products is seen as a significant gap with respect to existing traceability mechanisms in Canada and that it is not always possible to confirm whether fish and seafood entering Canada has been legally or sustainably sourced. There was a perception that the Canadian food supply chain is vulnerable to fish and seafood that is the product of IUU fishing outside Canada.

While some respondents felt that voluntary or industry driven traceability measures were "somewhat effective" at documenting details on the source and harvesting of fish and seafood, over half of respondents stated that such traceability measures were either "not very effective" or "not at all effective." Some concerns were also raised that non-compliance with mandatory traceability requirements may be present in certain fisheries in Canada.

Some respondents supported the use of certification programs or schemes that verify sustainable fishing practices. However, it was noted that participation in these schemes is voluntary, which results in incomplete market coverage compared to legally mandated traceability requirements.

We also heard that, while many Canadian fishers already comply voluntarily with higher traceability standards to meet requirements in target export markets, the same standards are not applied to products from less regulated parts of the world that are sold in Canada. In the respondents' view, this has created an uneven playing field for Canadian industry because it must shoulder a heavier burden of compliance than some imported products sold in the domestic market.

Some respondents called for a mandatory boat-to-plate traceability system for all seafood caught, farmed or sold in Canada. They think this is necessary to effectively protect Canada's seafood supply chains, safeguard the oceans and restore consumer confidence. Some also expressed support for implementing additional traceability requirements. Others preferred to maintain the current approach to traceability in Canada.

"We found that the lack of government-required labelling and tracking for exported and imported seafood makes assessing the sustainability of many seafood products impossible."

Discussion paper respondent

Design of a traceability program

The discussion paper asked respondents to provide views on specific design elements that should be included in a traceability program to address questions related to sustainability and IUU fishing. These could include the program's objectives, using new technologies and what information should be mandatory to track.

What we heard

Objectives

Some respondents noted the importance of having clear objectives for a traceability program, given the potential costs of implementation to industry. They also suggested that it should emphasize improvements in fisheries management, or deterring IUU fishing over promoting increased consumer confidence, which may be more difficult to achieve.

Other respondents suggested that a traceability program should be both consumer oriented and internationally oriented, to address sustainability and IUU-related concerns that may be reflected in import requirements of trading partners. It was suggested this would allow meeting the requirements of key trading partners and growing Canada's fish and seafood exports, while also supporting consumers to make informed purchasing decisions.

Some concern was expressed over the absence of a consistent international approach for fish and seafood traceability. Some respondents highlighted the need for Canada and other countries to take strong measures toward catch documentation and traceability across regions and fisheries. However, it was also noted that global supply chain standards for fish, seafood and aquaculture product traceability already exist and are in use in parts of the industry, as well as in other countries. We heard that where possible, Canada should aim to leverage these existing standards to provide efficiencies and be interoperable with emerging and evolving global systems.

We were also cautioned against a "one size fits all" approach to designing a traceability program, noting that each fishery requires specific management techniques and will require unique traceability tools.

The vast majority of respondents indicated their preference for a traceability program that meets the needs of both domestic and international markets, and that also considers imported fish and seafood coming into Canada. Some thought that implementing a domestically oriented program as a first step may be more feasible and should be prioritized. Some respondents also recommended that Canada's boat-to-plate traceability program should align with traceability programs of other countries. Additionally, respondents suggested that any new approaches considered should include both wild capture and aquaculture.

Use of new technologies

Many respondents believe a traceability program should explore the potential of new technologies to store and trace information throughout the product supply chain, leveraging practices and standards already in use in other countries. Examples included blockchain, quick response (QR) codes and data standards for traceability developed by industry and other countries. It was noted, however, that current practices vary and include some paper-based systems.

Information elements for traceability

Some respondents flagged existing international standards and approaches to traceability and said that Canada should adopt or build on such standards, including the type of traceability data elements being captured to harmonize with international practices.

Respondents indicated that traceability programs should capture information such as:

Respondents said this information should be made available throughout the supply chain. Feedback also included a suggestion that there are opportunities for the sector to identify areas of consensus with respect to key data elements, to prepare for any future traceability approaches and to maximize any potential benefits to trade.

Theme 3: Market access, trade, and marketing of Canadian fish and seafood

Market access, trade and marketing of Canadian fish and seafood

The discussion paper outlined various enhanced traceability and import requirements for fish and seafood in other countries and jurisdictions and asked partners and stakeholders about effects of these on business and trade.

It also summarized information on voluntary "Product of Canada" labelling and other Canadian branding. Questions were also asked about consuming and promoting Canadian fish and seafood.

What we heard

When asked if current Canadian traceability requirements resulted in any limitations on their ability to trade, some respondents indicated that export destinations such as the United States, the European Union and Japan have implemented traceability requirements that must be met to import Canadian fish and seafood products into those jurisdictions. In response to differing foreign traceability requirements, respondents indicated that industry is adapting by implementing individual traceability systems that exceed Canadian requirements. These systems may differ between businesses and fisheries, including which technology is used or which third-party certification is being followed.

Nearly all respondents indicated that they consume fish and seafood as part of their diet. Most respondents indicated that they consume fish and seafood a few times every week, while some consume seafood once a month. When purchasing fish and seafood, most respondents indicated that they actively seek out Canadian products and that they do so by reviewing food labels, asking retail employees for proof of origin, looking for "Product of Canada" claims on a label, looking for Canadian brands, or based on their own knowledge of fish products.

Some respondents expressed concern that current guidelines for "Product of Canada" claims may be misunderstood by consumers and that the labels do not fully support the marketing of Canadian products. Some said that the discussion paper provided an opportunity for AAFC and CFIA to finalize previously consulted on "Product of Canada" guidelines that would enable expanded use of the claim, which could lead to more products identified as having Canadian content in the marketplace.

Some industry respondents indicated that they promote their products as Canadian due to our internationally recognized marine environment as well as sustainably managed fisheries. Additionally, certain participants believe that there are new opportunities to fulfill consumer interests in sustainable fishing by linking certain fish and seafood products to having been harvested under DFO oversight, and by better communicating successful mitigation measures, such as those implemented to protect North Atlantic right whales.

Additionally, some respondents mentioned that there are certain sources of existing funding aimed at supporting the marketing of fish and seafood products, both domestically and abroad. Some suggested that further funding would be beneficial to better promote Canadian seafood products and their attributes related to sustainability and protection of marine mammals. Some noted that it is important to consider costs to industry of implementing any potential new system, and whether any costs that end up being borne by consumers may have the effect of reducing fish and seafood demand and consumption.

"Canada should prepare for other foreign governments to demand traceability data for Canadian exports, including species with highly complex supply chains such as Canadian lobster."

Discussion paper respondent

Other considerations

Out–of-scope issues

While out of scope, some respondents commented on the labelling of genetically engineered (GE) fish, particularly farm raised GE Atlantic Salmon. Comments were primarily about interest in seeing labelling of GE fish and about the risks that escaped GE salmon could pose to wild salmon populations. It is important to note that, while not required to do so, companies can voluntarily provide GE information on food labels, provided it is truthful and not misleading.

A few respondents suggested that substances known as processing aids should be required to be listed in food ingredient lists. Processing aids are used for a technical effect during food processing or manufacture, for example to reduce bacterial load, but do not affect the intrinsic characteristics of the food and result in no or negligible residues of the substance or its by-products in or on the finished food. Although out of scope, comments related to processing aids will be forwarded to Health Canada for consideration.

There were also comments about linkages between IUU fishing and human rights or law enforcement issues, such as forced labour and human or drug trafficking. While these are important issues, they were outside the scope of this consultation.

Next steps

CFIA, DFO and AAFC will consider all input received in order to determine appropriate measures to further the objectives of the themes set out in the discussion paper. Because traceability may serve multiple objectives, distinguishing these objectives is important when considering federal roles and responsibilities in this space. Given the range of feedback received, it will also be important to balance the interests of consumers, industry and other stakeholders, as well as partners in other levels of government.

CFIA, DFO and AAFC thank everyone who participated in the consultation process.

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