reLAKSation 84.
Consuming words (Labelling special): Although its been nearly 15 months since the European Union introduced new labelling regulations for fishery products, the UK Government has finally issued the Statutory Instruments to make such labelling mandatory. According to Intrafish, the legislation came into force at the end of March, after which, anyone failing to meet the regulations can be subjected to prosecution.
The labelling legislation requires that fish products be clearly labelled to show whether the fish are wild caught or farmed, where they are produced or if wild caught, which sea area it was caught. Finally, the label must state the scientific name of the species in addition to the common name.
The introduction of the Statutory Instruments will however make little difference since most supermarkets have already responded to the new legislation and changed the way in which they label their fish. Intrafish spoke to representatives from some of the major supermarkets who all confirm that the changes were introduced sometime ago.
Certainly, regular observations undertaken by Callander McDowell would indicate that virtually all of the leading supermarkets now comply with the legislation, or at least with most of it. The one main area of weakness is the incorporation of the scientific name of the fish on either the pre-pack or counter labels. This is likely to cause major problems for the retail sector, simply because this is extremely specialist knowledge for counter staff to assimilate. It is hard enough for us who work in the industry to correctly state the appropriate scientific name of the fish so it is bound to be difficult for many supermarket staff to be able to get it right. In addition, most consumers will probably look totally blank if asked anything to do with scientific names.
Yet, it is understandable that the European Commission might want to include such information on labels as the names of fish can vary not only from member state to member state but also within individual member states. Many regions have local names for fish which differ significantly from the usual common name. Yet, it is unlikely that even with the widespread use of local names, that many consumers will be misled and thus this new labelling may be a step too far.
Despite these good intentions, our observations suggest that the reality is that most consumers do not bother to study what’s written on labels, however detailed the information provided. We can deduce this from two observations. In those stores that sell salmon from more than one origin mixed on the same shelf, most consumers tend to select the first pack to hand rather than make any conscious decision to buy one pack or another. Secondly, when errors in labelling have occurred, repeated observations suggest that the error is allow to continue, because no-one has drawn attention to it due to the fact that they have not actually read the information provided. It is important to point out that any errors that we at Callander McDowell have observed are most likely due to human error rather than any specific intention to deceive.
There has been a past belief that some supermarkets have deliberately set out to deceive their customers in the way they label their fish products. For example, the then marketing manager of the now defunct Scottish Salmon Growers Association accused many supermarkets of misleading their customers by using the term ‘Produced in the UK’. This was thought to imply that the product was actually of UK origin, when the term could actually mean that the fish were imported and then processed in the UK. Scottish producers believed that consumers were being tricked into buying what they thought was Scottish salmon when they were actually buying imported fish. Given the choice, market research had indicated that consumers preferred to buy Scottish rather than imported salmon and it was felt that the use of ambiguous terminology was denying them the opportunity to do so.
However, now that supermarkets are clearly labelling their salmon with the country of origin, it would seem that the mainstream consumer is not concerned about where the salmon comes from, but rather that it looks good, tastes good and most importantly, represents value for money.
Unfortunately, the new labelling legislation appears to have failed to address industry concerns about misleading consumers. In those cases where a supermarket buys in salmon from more than one country it can choose one of two ways to identify the origin of the fish. It can use a standard label, which it then overprints with the country of origin. Thus, customers can be faced with packs on the same supermarket shelf with salmon marked as being from different origins. Alternatively, the supermarket can choose to highlight that it buys salmon from different origins, but leave their customers unsure of exactly which of the origins the fish is from. In the first example, the label will state ‘Farmed in Scotland’, ‘Farmed in Norway’, Farmed in Ireland’ or ‘Farmed in Chile’.
Farmed in Norway
Farmed in Scotland
Farmed in Chile
In the second example, the label might say ‘Farmed in Scotland or Norway’.
Farmed in Scotland or Norway
Critics of the new legislation have suggested that consumers faced with the second example could be misled into buying Norwegian salmon when they actually wanted to buy Scottish. Our view is that any consumer who would really wanted to be sure that they were buying Scottish would buy from a source where they could be 100% sure that the fish come from Scotland. Clearly, consumers who buy from stores which state more than one origin on the same label are unconcerned about where their salmon comes from.
Some critics of the new labels are also concerned about whether farmed fish are actually labelled as farmed. All the major supermarkets, except one, clearly labels all fish produced by aquaculture as farmed. The sole exception is also the only supermarket to sell Scottish salmon exclusively. They do not import salmon from Norway or Chile or anywhere else. They also promote their salmon under the Tartan Quality Mark, which would confirm that the salmon is farmed. It will be interesting to see if and how they respond to enforcement of new legislation.
All the other supermarkets do clearly state that their salmon is farmed, as well as other farmed species which now appear regularly on the supermarket shelves. According to Intrafish, supermarket buyers have reported little comment about the appearance of the word farmed on labels. Presumably, consumers are so familiar with farmed produce from terrestrial sources, that they now expect fish to be farmed as well.
Not surprisingly, it is the anti-farming lobby who are making most noise about supermarket labels. The Scottish based Salmon Farm Protest Group has called on it’s supporters to check supermarkets over the Easter period to note how salmon products are labelled. They have said that those supermarkets that fail to differentiate between farmed and wild salmon and do not identify the country of origin will be breaking the law. The SFPG plan to take action against any supermarket who do not label their fish properly. As regular observers of the supermarket shelves, we, at Callander McDowell think that they will be hard pressed to find any deliberate breaches of the law. It is interesting that the one example of improper labelling concerned fish, then sent for smoking, allegedly caught from the River Tweed, when it was actually caught in the North Sea off the River Tweed. This is digging really deep.
As we have already stated, we do not believe that there are any deliberate attempts to deceive consumers about whether salmon is farmed and from where it originates. There have been isolated examples of conflicting information appearing on some packs, but we are sure that these are rare and simply due to human error. Such problems are not exclusive to the fish industry.
At the recent Sea Change conference, MSP Maureen Macmillan said that she had tried to buy some salmon in her local supermarket and the only pack available failed to identify any country of origin. She also said that the salmon looked to be of poor quality. When asked to clarify which supermarket, we assured her that in our experience this particular supermarket was one of the first to clearly label all its fish and that a single pack was more indicative of a problem within the individual store rather than a policy decision by the supermarket company. If someone was to look hard enough, it will be always possible to find single examples which fail to meet up to expectation. It would be wrong of anyone to use such examples as illustrations of the failure of the new legislation, which is clearly working well.