Thank you very much for asking us to appear before you today to talk about seafood mislabelling, how it impacts Canada and the world, and what we can do to address it.
Oceana Canada, for anyone who doesn't know, is an independent charity. We're part of the largest international advocacy group focused solely on ocean conservation. We have offices across the Americas, in the EU and in Asia. We believe that Canada has a national and a global obligation to rebuild depleted fisheries and ensure a sustainable source of protein for the world's growing population.
As for the issue today, we've been investigating the prevalence of seafood fraud and species substitutions since 2017 in Canada, and internationally since 2011. We have dedicated campaigns on this issue in the U.S., the EU, Mexico and Brazil. Seafood fraud or mislabelling is really any activity that misrepresents the product being sold, including swapping a cheaper, less desirable or more readily available species for one that is more expensive, and substituting farmed products for wild-caught ones, or black market fish for legally caught varieties. It undermines food safety; it cheats consumers and the Canadian fishing industry; and it weakens the sustainability of fish populations. It can even mask global human rights abuses by creating a market for illegally caught fish.
When one fish is substituted for another, consumers risk exposure to allergens, parasites, environmental chemicals, aquaculture drugs or natural toxins found in some species of fish. Cheap or more readily available species are mislabelled so that they can be sold as expensive, desirable or supply limited ones. Not only do consumers get cheated out of what they paid for, but responsible, honest businesses also face unfair market competition. It harms our oceans by disguising threatened and endangered species and allowing illegally caught fish into the market. This undermines efforts to stop overfishing and to manage our fisheries sustainably.
Unfortunately, it's very common here in Canada and around the world. A 2016 review by Oceana of more than 200 published studies, from 55 countries, found that one in five of more than 25,000 samples was mislabelled. More recently in Canada, in 2017 and 2018, we collected seafood samples from restaurants and retailers in five Canadian cities and found that an alarming 44% of samples were mislabelled. This is consistent with other studies that have taken place in Canada. For example, the University of Guelph, with Dr. Bob Hanner, found that up to 41% of samples were mislabelled, and again, in 2018, the University of British Columbia found that 25% were mislabelled.
The Canadian Food Inspection Agency's own research found that 15% of mislabelling happened before seafood products even reached the processing stage. Canada produces high quality seafood, however we export roughly 85% of this, and about 80% of what we eat here in Canada is imported from overseas. Seafood is traded globally, more than any other food. The supply chains are long, complex and quite obscure, and they often cross many national borders, sometimes going back and forth across the same border, which allows for many opportunities for mislabelling and illegal activity to be introduced along the way.
The best way to combat this is with full chain traceability, requiring that key information be paired with the fish product along the entire supply chain, from the point of capture or harvest to the point of sale. This approach has been implemented in the EU, which is the largest importer of seafood in the world, and the rate of mislabelling has dropped. The U.S. also recently implemented boat-to-border traceability for species that are at the highest risk of fraud.
That's the context in Canada. My colleague, Kim, is going to share recommendations for how we can address this more specifically in Canada.
I wish I could present you guys with a silver bullet that's an easy fix to this issue, but unfortunately, as Lesley has alluded, it is a very complex issue. What further complicates things is that Canada is lagging behind comparable jurisdictions. There are fewer regulatory requirements governing traceability here in Canada, for now. No single agency is wholly in charge of combatting seafood fraud. It's regulated through multiple government departments at federal and provincial levels, with a patchwork of legislation and regulatory provisions. Then to further complicate things, provinces and municipalities may play a role.
However, there are other jurisdictions around the world that are doing something to tackle seafood fraud. For instance, in the European Union they're really leading the way on combatting seafood fraud and they have robust proof-of-legality and traceability requirements to deter fraud and to prevent the entry of illegally caught seafood into their markets. Right now, if you're in the EU and you buy a seafood product, as a buyer you're going to know from the label on the product the commercial and scientific name, the production method, the geographical area where the fish was caught or farmed, the fishing gear that was used, whether the product is fresh, frozen or previously frozen, the best-before date and any information on potential allergens.
We found that these regulations in the EU are working. Before they were in place, we were finding fraud levels of 23% in the EU. Then in 2015, after the regulations were put into place, we found levels of about 7%, so it is effective.
A few years ago, the United States created a task force to combat fraud and illegal, unreported and unregulated fishing, or IUU. This was the seafood import monitoring program, or SIMP. This has looked at the species that are at greatest risk for fraud. It required traceability from boat or farm to the U.S. border. This is something that is going to be rolled out to other species within the United States. They just started with the most high-risk ones.
Some of our recommendations for what could be done to combat this issue are, first, to create a multi-department task force in Canada to ensure that all the relevant departments work together to strategize on how to detect and prevent seafood fraud. This would be supported by full-chain traceability requirements.
Second is to require and share catch documentation to identify the origin and legality of seafood for all domestic and imported seafood, in line with what is currently required by the EU, and recommended by the Food and Agriculture Organization of the United Nations. Canada agreed to this at the G7 summit.
Our next recommendation is to strengthen the existing safe food for Canadians regulations, so that they require full-chain traceability. Currently, they require one step forward and one step back. When the time comes for review, we would like to see that be more fulsome and go throughout the full system, and also require that the regulatory bodies report this information electronically.
Fourth is to improve seafood labelling standards. We heard what the EU can find out about their food. We'd like to be able to find that out here as well. We've seen that work; it can work again, so that essential information about the fish is travelling with the fish.
Finally, we'd recommend the use of DNA testing for imported and domestic species authentification in CFIA's inspection program, and more investment in that department, so they can do this.
All that to say, we're really looking forward to your questions. We are looking forward to hearing Lyzette's presentation, and to working with CFIA, and to working with other departments because we do want to find a solution to this problem.
Of the nearly 400 samples collected from restaurants and grocery stores, and a small number from markets, 44% were mislabelled.
A common one was snapper, or “red snapper” on the label, but it was actually tilapia. We collected 44 samples of snapper, with 12 of red snapper, and none of those were in the snapper family. It's worth keeping in mind that “snapper” is actually a generic name that can apply to over 200 species, and none of these 44 samples that we collected were any of those 200 species. That was one of the common mislabelling incidents we came across.
There are also examples of Pacific salmon, and any of those five main species of Pacific salmon were actually Atlantic salmon, which is a big issue. When we were out in Atlantic Canada, we found “Atlantic cod” on the label, and it was actually Pacific cod. All of these really iconic species in the different areas around the country were mislabelled.
One slightly unpleasant example that we've talked about in the past is where white tuna was almost always escolar, which is indigestible. I'll leave it at that.
They're laundering illegally caught fish.
A minimum of 20% of the global fishing catch is associated with illegal, unreported and unregulated fishing. Imagine how many thousands and thousands of tonnes of fish that is. All of that needs to be laundered into supply chains, and it happens through mislabelling fish along the way.
Tied to illegal fishing is slavery in seafood supply chains. We'd be happy to present a submission that we put forward to your colleagues a year and a half ago, who were studying supply chains and responsible enterprises. Slavery within the seafood supply chain is very well documented, so that's another reason you wouldn't want to eat a mislabelled fish.
As well, the last 75% of the mislabelled samples that we collected were for more expensive fish. Most of the time, you're just being ripped off. From a financial standpoint, if you're paying for coho salmon, which is quite a bit more expensive than Atlantic salmon, you want to make sure you get that. If you're paying for Chilean sea bass, you don't want that to be a cheap whitefish.
As mentioned, my name is Lyzette Lamondin.
I want to thank the committee for giving me the opportunity to speak about seafood labelling.
More specifically, I appreciate being able to explain how labelling fits into the mandate of the Canadian Food Inspection Agency, the CFIA, and into our ongoing work in this area.
The CFIA is a risk-based scientific agency. As part of the health portfolio, the CFIA strives to maintain a strong and reliable food safety system.
Food products, whether domestic or imported, must comply with Canada's food safety and labelling laws. This includes a requirement that food be labelled in a way that is truthful and not misleading. It applies to all food, including seafood and fish.
The CFIA is well aware of the growing attention to the fish and seafood labelling issue and the associated risk of food fraud.
We also recognize that this is a global issue and not just a national issue.
Today I would like to discuss three points regarding the issue—how CFIA works to protect Canadians when it comes to fish and seafood, how our new safe food for Canadians regulations support CFIA in this area and how we continue to work to maintain public trust.
First, fish and seafood represent one of several commodities that can be false or misleading. The CFIA monitors for fish mislabelling and substitution as part of regular inspection programs and does conduct laboratory analysis when necessary to detect fish species substitution.
In addition to our own inspection activities, there are a number of third party studies, such as the reports by Oceana Canada, that have examined the issue and contribute to our knowledge base on these issues. I appreciated the presentation by Oceana today to share their perspective, and I appreciated their offer to brief me earlier this week.
Third-party studies are a useful source of information for the CFIA.
Still, it is without question the responsibility of businesses, our regulated parties, to make sure that the labels on their food products are truthful and not misleading, and that all labelling requirements are met.
The CFIA plays a key oversight role, verifying that food labels and advertising materials comply with regulations. The CFIA works to protect Canadians from intentional adulteration, substitution or product misrepresentation in a number of ways. For example, the CFIA has been routinely using DNA bar coding technology for fish species since 2013, so we can check that the fish and seafood product is what it says it is. The CFIA provides tools such as online labelling tools to promote compliance and help businesses themselves verify that their labels meet all the regulatory requirement.
Another key tool is the CFIA fish list, which links the scientific name of a fish or seafood to the common name that the consumer would look for—in other words, what the fish is known as in Canada.
There are many potential causes of food misrepresentation, as well. Without question, there are situations when there is a clear intent to commit a fraudulent act for an economic benefit. This is a criminal act, the enforcement of which involves not just the CFIA but law enforcement agencies.
Misrepresentation can also occur, however, without intent. For example, in some cases we are learning that the mislabelling may occur when our trading partners call a species by one name and we call it by another. This may be compounded by the fact that names must appear in both official languages in Canada. There may also be situations where companies substitute species out of convenience, not recognizing the seriousness of the action they're taking.
I want to make it clear that we take appropriate action in all cases of non-compliance.
Finally as noted in the Oceana Canada report, the international seafood supply chain is highly complex. Once a fish is caught, it can cross many national borders.
Thanks to the safe food for Canadians regulations, which came into force on January 15, 2019, we do have new tools at our disposal, which brings me to the next point.
The safe food for Canadians regulations now require all businesses, including importers, to be licensed, to have traceability and records in place, and to have a preventive control plan. The preventive control plan requirement enables our CFIA inspectors to verify control measures are in place—for example, how the business is ensuring that its labels are truthful and not misleading, and how it monitors and responds to complaints There is also clear accountability for importers to ensure that their product meets Canadian requirements. In essence, they need to know their suppliers and the food they are bringing into the country.
The safe food for Canadians regulations also allow for significant new fines up to $15,000 and prosecution, providing an additional incentive for businesses to comply. Morever, businesses could lose their licence or have it suspended.
These regulations include traceability requirements for all foods, and these requirements are based on the international standards set by Codex Alimentarius. The regulations require businesses to keep records one step forward and one step backward throughout the food chain so that a food can be traced through the supply chain when required.
Traceability requirements are driven by food safety. The primary purpose of the traceability is to be able to rapidly remove a product from the marketplace when that's required. However, they will also facilitate trace-back during investigation of food fraud. This brings me to my last point.
Public confidence in the products that food companies produce and market to Canadians is key to market access and consumer acceptance. Canadian consumers want safe and quality products that are properly labelled.
Budget 2019 provides $24.4 million over five years to the CFIA, starting in 2019-20, and $5.2 million per year ongoing to enhance our capacity to address food fraud.
This funding helps us to better understand and better focus our inspection activities.
These funds will allow us to better understand and target our enforcement activities to areas of food fraud.
We will continue to collaborate with industry, governments and international partners, and to engage Canadians to address this important issue.