Gold Standard for Sustainable · See John C. Dernbach, Synthesis, in Stumbling Toward Sustainability 1, 5–6 (2002); Michelle Allsopp et al., Challenging the Aquaculture Industry

Gold Standard for SustainableAquaculture Ecolabel Design:Summary Report

Environmental Law InstituteThe Ocean FoundationMay 2008

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ii Environmental Law Institute

This publication is a project of the Environmental Law Institute (ELI) and The Ocean Foundation (TOF). Funding was provided bygrants from the Munson Foundation, the Keith Campbell Foundation for the Environment, and an anonymous donor. The

authors of this report include Read D. Porter, Kathryn Mengerink, and John Pendergrass of ELI and Mark J. Spalding of TOF. JesseDaniel Oppenheimer and intern Anne Davis contributed research support. The Environmental Law Institute is responsible for theviews and research contained in this report, including any omissions or inaccuracies that may appear. The information in thisreport was obtained through interviews and independent research conducted from March 2007 to February 2008. Comments orcorrections are welcome and should be directed to the authors.

We thank Rebecca Goldburg, Environmental Defense Fund, Dr. Cathy A. Roheim, University of Rhode Island, Stacey Marz, Esq.,TOF, and Monika Thiele, TOF, for reviewing and commenting on the report. In addition, we gratefully acknowledge the manyinterviewees who gave generously of their time and experience.

Acknowledgements

ABOUT ELI PUBLICATIONS

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Gold Standard for Sustainable Aquaculture Ecolabel Design: Summary Report

Copyright © 2008 The Environmental Law Institute® and The Ocean Foundation. Cover photos courtesy of Salmon Farm Protest Group/Marine Photobank (salmon netpen); Kathryn Townsend/Marine Photobank (geoduck farm). All rights reserved. Mangrove photo created by Jesse Allen, NASA Earth Observatory, using data obtainedcourtesy of the University of Maryland's Global Land Cover Facility.

ISBN No. 978-1-58576-146-3, ELI Project No. 070102

An electronic retrievable copy (PDF file) of this report may be obtained for no cost from the Environmental Law Institute Website, athttp://www.eli.org/Program_Areas/ocean_pubs.cfm. [Note: ELI Terms of Use will apply and are available on site.]

(Environmental Law Institute®, The Environmental Forum®, and ELR®—The Environmental Law Reporter® are registered trademarks of the Environmental Law Institute.)

The aquaculture industry is on the rise: since 1950, aquacul-ture production has grown 8.8 percent per year and shows

no signs of slowing. In 2004, global production stood at 59.4million tons, with a market value of $70.3 billion.1 Proponentsclaim that this “blue revolution” reduces pressure on depletedwild fish stocks, provides a source of sustainable income gen-eration for developing economies, and serves as an importantfood source to address protein deficits in developing regions.Unfortunately, these claims are undermined by serious envi-ronmental and social impacts caused by current aquacultureproduction practices. These impacts range from dependenceon wild feedstocks to trade imbalances, and each must beaddressed before aquaculture development can be consideredsustainable over the long term.

The Marine Aquaculture Task Force has noted that “eco-labeling, and certification have the potential to significantlyimprove the sustainability of aquaculture production prac-tices.”2 Ecolabels are intended to leverage consumer demandfor sustainable products to provide incentives for adoption ofimproved environmental practices by producers. Certified pro-ducers can market their products with the ecolabel, indicatingto consumers that the products meet certain production stan-dards. Producers benefit from increased access to markets andprice premiums for labeled products. This simple idea hasbeen implemented through ecolabels in a wide array ofindustries ranging from forestry to capture fisheries. Whilethe theory behind ecolabeling is the same from industry toindustry, each label’s institutional design differs, as does itssuccess on the ground. Design differences affect the label’s

credibility and pragmatic benefits: labels must be properlydesigned to ensure that they produce their intended benefits.

A number of ecolabels have already been developed inresponse to increasing demand for an aquaculture label, andmore are forthcoming in coming months and years. However,existing and planned labels all focus on incremental improve-ments to production processes rather than on sustainability.In these labels, sustainability is more a buzzword than aguideline for implementation. Moreover, an independentreview has revealed that all existing ecolabels lack credibilitydue in part to a lack of institutional controls and inadequateconsideration of key impacts of production and processing. Inaddition, it is not clear that these efforts have resulted inimprovements in environmental or social practices on theground.

The Environmental Law Institute (ELI) and The OceanFoundation (TOF) seek to introduce a new paradigm for ecola-beling in which sustainability—not feasibility—is the basisfor certification. Sustainability is a high bar—it seeks eco-nomic development that does not degrade natural systems orundermine basic human needs for either this generation orfuture generations.3 Creation of an ecolabel that meets thesedisparate economic, environmental, and social goals requirescareful and flexible institutional design to enable the evolu-tionary development of certification standards.

This Gold Standard describes a comprehensive framework forthe design of an aquaculture certification that is based explic-

EXECUTIVE SUMMARY

Gold Standard for Sustainable Aquaculture Label Design: Summary Report 1

1. FAO, State of World Aquaculture 2006 6 (2006).2. Marine Aquaculture Task Force, Sustainable Marine Aquaculture: Fulfilling the Promise; Managing the Risks 110 (2007) [hereinafter Sustainable Marine Aquaculture]. TheMarine Aquaculture Task Force is a diverse panel of experts with scientific, regulatory, business and policy-making backgrounds. It was convened by the Woods HoleOceanographic Institution, with support from the Pew Charitable Trusts, to develop a suite of protective, science-based standards to assure that aquaculture developmentposes minimal threats to the ocean environment.3. See John C. Dernbach, Synthesis, in Stumbling Toward Sustainability 1, 5–6 (2002); Michelle Allsopp et al., Challenging the Aquaculture Industry on Sustainability 19 (2008).

Executive Summary

itly on environmental and social sustainability. The GoldStandard has been designed as efficiently as possible toensure that it is both credible and practical. As a result, sys-tems that follow the Gold Standard will comply with all estab-lished international design standards, will certify only sus-tainable operations and will provide economic benefits toproducers over the long term. Through comprehensive consid-eration of effects on the environment, society, human health,and animal welfare, scientific standard-setting, careful con-trols on certification decisions, transparent review and report-ing on performance, and robust objections procedures, con-sumers can be assured that Gold Standard-compliant ecola-bels will successfully translate their rigorous standards intosustainable practices. Existing labels can also use the GoldStandard to evaluate their institutional design. These labelsmay improve the credibility of their systems by adopting ele-ments of the Gold Standard.

The Gold Standard is based on the four elements of ecolabeldesign: (i) scope; (ii) governance structure; (iii) standards; and(iv) implementation methodology. Every ecolabel—basedon sustainability or not—must consider each of these ele-ments in order to design processes and substantive standardsthat are credible and offer incentives for producers to partici-pate. The recommendations included for each of these ele-ments in the Gold Standard are designed for optimal opera-tion of a working sustainable aquaculture ecolabel giventhese requirements. The Gold Standard is a workable, compre-hensive design framework for those who propose to create anecolabel for aquaculture products. It uses sustainability as theminimum requirement for certification because only withsubstantively sustainable standards will aquaculture live upto its promise without causing undue harm.

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The creation of a working ecolabel requires a precise delin-eation of the scope and goals the label will attempt to achieve.This scoping determination permits the development of thethree fundamental elements of ecolabel structure, includinggovernance bodies, standard-setting procedures and resultantstandards (including principles, criteria, and indicators), andimplementation systems. In this Gold Standard, “standards”include principles, criteria, and indicators; specific terms areused where appropriate. This Gold Standard provides the opti-mal design recommendations for each of these design criteria.

A. Scope

Clear delineation of the scope of the ecolabel is necessary atthe outset of a labeling program to ensure that stakeholdersand designers understand the goals for which the label is cre-ated. Ecolabel scoping requires identification of relevantimpacts and stakeholders and establishment of benchmarksfor stringency of standards.

1. Develop a Written Scoping DocumentThe first task of a potential label should be to develop anexplicit statement of principles. This statement should haveseveral components, including:

• Identification of the impacts the ecolabel will address. • Stakeholder groups that are affected by those impacts• Stringency of standards to be adopted• Key principles for ecolabel operation, including partici-

pation, transparency, and accountability• Definitions of sustainability and other key terms.

If desired, the principles may also identify global require-ments for certified entities, such as the use of managementsystems and legal compliance.

2. Address all significant effects of aquaculture production and processingThe general principles should address all significant types ofsocial and environmental impacts (including harms to humanhealth) caused by aquaculture production, including but notlimited to:

• Siting conflicts, including interference with other usesof land and waters, including ecosystem services

• Workers’ and indigenous persons’ rights• Feedstocks• Chemicals and antibiotics• Wastes• Disease• Escapes• Animal welfare• Human health• Greenhouse gas releases

Failure to address significant impacts is likely to negativelyaffect the credibility of both standards and the ecolabel as awhole. Decisions to exclude impacts may be acceptable if theyare adequately addressed through other mechanisms, such asinternational conventions. Ecolabels should provide justifica-tions for excluding known categories of impacts.

3. Incorporate social, environmental, and economic stakeholdersThe creation of an ecolabel to address a broad range ofimpacts requires inclusion of a similarly broad array of stake-holder groups from the label’s creation. These stakeholdersshould be consulted in the identification of impacts and struc-tural elements of the label. Key stakeholder groups include:

• Producers—Large-scale (e.g. Marine Harvest)

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—Small-scale (e.g. family-farming operators)• Supply Chain

—Retail—Processing

• Environmental NGOs• Community/Social NGOs• Consumer groups• Wild-capture fishery representatives (due to significant

interaction)• Independent Bodies (independent experts)

—Academics—Multilateral organizations

Ecolabels are non-state, market driven structures that aredesigned to operate independently from government regula-tion to produce environmental and social benefits by volun-tary, market-driven means rather than by prescription. As aresult, the inclusion of government representatives as a pro-tected interest group may distort the intentions and credibili-ty of the ecolabel system as a whole. Multilateral organiza-tions, including but not limited to FAO and the World Bank, donot raise the same issues and may therefore be valuable con-tributors or supporters due to their interest in developing pro-grams for aquaculture.

4. Incorporate stakeholders from both developed and developing countriesA credible sustainable aquaculture certification organizationrequires engagement by producers and NGOs in developingcountries, as many common species—notably shrimp andpangasius—are primarily produced in small scale operationsin developing countries and the inclusion of these parties isvital for the credibility of the system.

5. Adopt sustainability as the baseline for stringency In addition to identifying the important impacts of aquacul-ture production, scoping requires explicit delineation of theintended stringency of standards; if significant impacts areexcluded, the reasons for the exclusion should be explicitlyidentified. Clarity of goals at the time of creation will reducecontention later in the labeling process. The scoping document

for a comprehensive ecolabel should require that certificationbe based on environmental, social, and economic sustainabili-ty rather than on feasibility or current industry practice.Determination of sustainability should be based on the bestavailable science, as determined by the Technical AdvisoryBoard and implemented through appropriate criteria and indi-cators. Where current production practices are already sustain-able, anti-backsliding provisions are required. Where scientificinformation is incomplete, the Gold Standard adopts a precau-tionary approach, calling for the TAB to determine standardsthat err on the side of caution and allowing indicators to evolveas more complete information becomes available.

B. Governance

Ecolabel governance must be credible, incorporating all stake-holder groups in a balanced manner. Where not dictated byobjective evidence, decisions must be based on consensus (asdefined by the ISO), made within a prescribed time period,and made by accountable entities. Where consensus cannotbe achieved within prescribed time limitations, the ecolabel’sfounding documents may allow decisions based on majorityrule. The recommended governance structures meet theserequirements and comply with all relevant international stan-dards. While other institutional designs may also be credible,these recommendations are based on a comparative study ofthe strengths and weaknesses of past ecolabel design initia-tives and are designed to be effective in the aquaculture con-text. In particular, this design is intended to achieve twogoals: development of standards based on the best availablescience and consistent certification that produces the desiredresults in production facilities.

GENERAL ASSEMBLY

1. Engage stakeholders through a membership structureThe participation of members in ecolabel governance increas-es the label’s credibility while also providing an ongoing

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forum that can be used to leverage the expertise of commit-ted and diverse stakeholder groups during standard-setting.Limited membership fees, tiered based on ability to pay, canbe used to offset the costs of operating the membership struc-ture but should not be used to support the label’s other oper-ations. Tiered membership fees, however, should not result inlimited opportunity to participate in ecolabel governance.

2. Create a general assembly with limited governance responsibilitiesA general assembly with annual meetings provides a consis-tent forum to promote stakeholder communication and seekfeedback on ecolabel activities. The general assembly shouldhave explicit powers to:

• Elect the ecolabel’s board of directors• Make substantive recommendations to the board,

independently or at the board’s request, which theboard must consider.

Delegation of additional powers to the assembly—notably,the sole power to alter the ecolabel’s principles—is not rec-ommended, as the debate required to achieve consensus mayresult in costly mechanisms. All board activities should rely onconsensus (not unanimity), as defined by ISO and the ISEALAlliance, and should be constrained by time limitations.

3. Require balanced membership and powers in the assemblyThe assembly should include members from each of thestakeholder groups. Voting power for board elections shouldbe normalized to take account of differences in the represen-tation by each stakeholder group. The use of membershipchambers is recommended to simplify this operation. The FSCsystem offers a model for establishing chambers and normal-izing voting power by chamber. Membership chambersshould include producers, supply chain interests, environ-mental interests, and social interests. Other interest groups,such as consumer groups and academics, should apply formembership in the most appropriate chamber. Each chambershould elect its own representatives for the board independ-

ently. In addition, the assembly as a whole should elect theindependent board members, as nominated by the board.

BOARD OF DIRECTORS

1. Require balanced representation in the board of directorsThe board should consist of one member from each assemblychamber and the CEO of the label. Independent members,from both developed and developing countries, should alsobe appointed to the board by the Assembly based on consen-sus. Membership of uninterested parties is vital to the board’stransparency, and the inclusion of all stakeholder groups intheir appointment ensures credibility. The board shouldinclude at least four independent members.

2. Limit size of board and term length of its membersThe board of directors should include between nine andtwelve members, each of whom should serve a two year term.Re-election of incumbents should be permitted for up tothree terms to provide continuity between boards. If a stag-gered election process is used, half of the board should beelected each year.

3. Provide board with broad responsibilitiesThe board should be permitted to establish subcommittees asneeded to carry out its responsibilities, but approval of theiractions by the whole board is important to ensure accounta-bility. The board of directors should have broad responsibili-ties, including:

• Final decisions on standards• Financial decisions• Strategic decisions• Oversight of the secretariat• Approval of technical advisory board and objections

panel members

4. Require the board to consider technical and stakeholder input

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As part of its mandate, the board and its subcommitteesshould be required to consider the technical advice and stake-holder input provided by the technical advisory board andassembly, respectively. This consideration should be “on therecord” to provide transparency. Procedures for considerationand response to comments from the assembly and technicaladvisory board should be created as part of the board’sbylaws.

5. Create a board subcommittee for standard-settingA board subcommittee for standard-setting carries out thedevelopment of principles, criteria, and indicators in mostecolabels. In the Gold Standard, the substantive content ofindicators is determined by the technical advisory board. Theboard’s standards subcommittee is responsible for translatingthat substantive input into implementable indicators, as wellas phrasing principles and criteria to carry out the label’s pur-pose, as stated in its scoping document. The standards sub-committee should be balanced by interest group and shouldrely on the secretariat’s standards unit for procedural support.

SECRETARIAT

1. Develop a secretariat to manage the ecolabel on aday-to-day basisThe secretariat houses the ecolabel’s permanent executivestaff. It should be an independent organization led by a chiefexecutive, who is also a member of its board of directors. Thesecretariat is responsible for overseeing development andimplementation of the ecolabel’s standards, consulting withfacilities considering certification, evaluating performance bycertified entities, and developing markets for labeled prod-ucts. The secretariat should carry out these diverse tasksthrough a separate standards unit, producer unit, and busi-ness unit. Other units may be developed as needed.

2. Establish secretariat as a global presence with consumers and producersAs part of its producer unit, the secretariat should establishoffices in each of the major aquaculture-producing regions to

aid in compliance and adoption of indicators on a local level.Offices in Asia and Central/South America are of particular rel-evance. The majority of production occurs in China, with sub-stantial additional production in Southeast Asia and theIndian subcontinent. Other species are produced in largequantities in the Americas (e.g. salmon, mollusks), so anoffice in the Americas is similarly important, depending onthe species certified.

Offices in Europe, North America, and Asia (primarily Japan)are also important from a business perspective. The secretari-at’s business unit must focus on these markets to developretailer support for market access and consumer recognitionof the label.

3. Evaluate and report on the environmental and social performance of indicatorsExisting ecolabels face a major challenge in determiningwhether standards based on sustainability are being translatedinto sustainable performance on the ground. The Gold Standardrecommends the use of the secretariat to determine whethercertification decisions based on existing indicators are produc-ing environmental and social benefits. The standards unit, withdata from the producer unit and certification body, can effec-tively evaluate how indicators translate into performance due totheir experience in consultation and standard-setting, respec-tively. The secretariat should use this data to creat a rigorousannual report on ecolabel success, both providing metrics forevaluation of success and identifying areas where the effective-ness of indicators could be improved through revision of theindicator or certification body guidelines.

4. Centralize management to minimize cost and ensure consistency across operationsThe use of independent national initiatives may be costly andmay result in inconsistent application of criteria and indica-tors. While national standards and labels have been devel-oped, none of these efforts are credible enough to serve as apreexisting national initiative for a Gold Standard-compliantlabeling system. exists for aquaculture, so the development ofnational initiatives is not advisable. Instead, the ecolabel’s

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management should be centralized to minimize costs andshould provide central oversight over global operations toensure consistency.

TECHNICAL ADVISORY BOARD

1. Create a standing, independent technical advisory board The secretariat should establish and recruit members for astanding, independent technical advisory board composed ofindependent experts specializing in environmental sciences,sociology, and economics. These experts may be drawn fromacademia, government, or multilateral organizations, butshould be free of conflicts of interest, including financial inter-est in the content of ecolabel standards. Sources of funding formembers’ research should be disclosed to the board prior toappointment to the technical advisory board. The inclusion ofexperts who may have some conflicts is acceptable ifapproved by the board.

2. Authorize the technical advisory board to provideobjective measures of sustainabilityThe Technical Advisory Board’s expertise, independence, andobjectivity should be uniquely suited to the determination ofthe substantive requirements for sustainability. The board’sresponsibilities should therefore include:

• Provision of objective, peer-reviewed informationregarding the requirements for sustainable standards(criteria or indicators, as appropriate)

• Advice to the board on initiation of standard-setting orreview of existing standards.

The board’s decision-making process should be transparentand objective. Where members do not agree on the contentsrequired for sustainability, the board should apply a precau-tionary approach to determine requirements for certification.The board’s decisions should govern standards developmentby the secretariat and board subcommittees unless the boardof directors votes to reject a technical board finding.

3. Authorize the technical advisory board to create sub-panelsThe production of each species in aquaculture has uniqueimplications for sustainability. As a result, the technical advi-sory board should be authorized to create sub-panels com-posed of scientific experts on particular species and theirimpacts. These sub-panels should be authorized to determinethe scientific measures of sustainability, but responsibility forthe approval of these measures remains with the technicaladvisory board as a whole, as in the ISO system.

OBJECTIONS PANEL

1. Create an independent objections panelEffective review of grievances is an important element ofcredible governance structures. The creation of a standing,independent objections panel is the most transparent systemto ensure the credible review of grievances and is likely to berequired by FAO guidelines. The panel’s membership shouldbe independent from all operations of the ecolabel butapproved by the board to ensure accountability. Panel mem-bers should serve three year terms, but be eligible for reap-pointment. Decisions of the independent objections panelmust be final.

2. Allow secretariat to review and address grievances prior to appeal to panelThe secretariat should be the locus for initially reviewing andaddressing grievances. The secretariat is subject to stakehold-er control through the board of directors and therefore isaccountable and offers fewer conflict of interest concerns thancertification bodies. In addition, the secretariat is not directlycomposed of stakeholders and makes no final decisions onapproval or content of standards. Therefore, it is more suitablethan a board subcommittee for reviewing substantive dis-agreements.

The initial secretariat review is intended to promote efficientdispute resolution, permitting some flexibility with respect toformat and rules of decision. Where initial review does not

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resolve a difference, however, all complainants must be per-mitted to appeal to the formal objections panel to ensure thecredibility of the dispute resolution process.

3. Allow stakeholders to challenge procedure and sub-stance of standard-setting and certification decisionsAccountability fundamentally requires that stakeholders bepermitted to challenge both substantive determinations andthe procedures used to reach those determinations. Ecolabelsshould create a process for challenges based on both avenuesfor both determination of standards and certification deci-sions.

4. Allow external organizations to object even if theyare not membersMembership is not a credible way to limit access to the dis-pute resolution process. Instead, any interested individual,organization, or multilateral entity should be permitted tolodge a complaint. Some limits on access are needed to avoidfrivolous complaints, however. Limits should be tied to activeparticipation in the decision-making process through arequirement for complainants to have submitted commentsduring the public comment phase of standard-setting or cer-tification, as appropriate. Exceptions to the participationrequirement should be allowed on a case by case basis wheregood cause is shown.

C. Standard-Setting

With a credible, efficient governance system in place, ecola-bels can develop and implement credible standard-settingsystems. All standard-setting should be based on written pro-cedures. Ecolabels should develop three layers of standards,including overarching principles, criteria determining howeach principle applies to particular impacts, and indicatorsthat provide objective measures of compliance with each cri-terion that can be directly applied during certification. In thisreport, “standard” is used in a general sense to refer to allthree of these levels. The specifics of standard-setting will dif-fer depending on the type of standard under development or

review. As a result, where more specificity is desired, a morespecific term is used.

1. Comply with the ISEAL Alliance Code of PracticeThe ISEAL Alliance has set forth a Code of Practice for StandardSetting that specifies minimum practices for the creation ofcredible standards. Gold Standard ecolabels should complywith the requirements of the Code, which is based on bal-anced and consensual decision-making and incorporates min-imum standards for participation, transparency, and account-ability.

2. Use explicit standard-setting processesAll standard-setting (including creation of criteria and indica-tors, as appropriate) should be based on explicit, public proce-dures for standard-setting. The use of this document is vital tothe transparency and accountability of the standard-settingprocess. The processes should be used to develop both theecolabel’s guiding principles and standards and the criteriaand/or indicators used to apply them. The processes must bedeveloped and published prior to the initiation of standard-setting.

3. Use the Technical Advisory Board to determine stringency of criteria and indicatorsWhere sustainability can be measured by the technical advi-sory board (TAB), the board’s standards committee must relyon the TAB determination when determining standards.Where the TAB cannot directly measure sustainability, howev-er, it should provide baseline stringency determinations thatreflect the TAB’s estimate of minimum standards given thestate of scientific knowledge. In such cases, the standardscommittee must rely on those baselines, which provide mini-mum stringency measures. It can, however, increase the strin-gency of such standards beyond the minimum level estab-lished by the TAB.

4. Base standards on both process and performance Credible standards for assessment of the impacts of aquacul-ture production require consideration of both processes andactual performance. Process standards require the adoption

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of record-keeping and other necessary elements of effectiveand reviewable management systems. Performance stan-dards are objective, verifiable measurements of the resultsobtained during the operation of facilities. The principlesadopted should explicitly recognize that performance stan-dards are required in addition to considering existing processstandards in relevant areas, including environmental per-formance, quality, food safety, and occupational health andsafety. Where possible, standards should avoid mandating theadoption of specific mechanisms for achieving sustainablelevels of performance, in order to encourage innovation andallow facilities to reduce the costs of compliance: the use ofcertain techniques should not serve as a proxy for perform-ance levels absent compelling justification.

5. Develop indicators on a species or species-group basisEcolabel must create indicators that elaborate on its globalprinciples and criteria to enable certification bodies to evalu-ate producers. Indicators should be created for each species orgroup of related species (e.g. shrimp, tilapia), rather than on acountry-by-country or regional basis. Production processesand impacts vary widely by species, and sustainable practicesare unlikely to change based on geography. Ecolabels, howev-er, must require compliance with national laws to complywith international standards. While such compliance mayrequire producers to undertake more rigorous actions than arerequired by the ecolabel, this outcome is unlikely because theaquaculture industry is generally under-regulated.

6. Centralize development of principles, criteria, and indicators The use of centralized standard-setting processes is the bestway to create indicators for use during conformity assess-ment. Reliance on decentralized systems risks the develop-ment of inconsistent standards and indicators and increasescosts. Centralized development can and should require inputfrom stakeholders in specific regions. This requirement can befulfilled through species-by-species indicator development,particularly as the production of many species is and shouldbe localized based on the native ranges of species in produc-tion.

7. Allow secretariat to develop guidanceEven though the standard-setting procedure should be over-seen by the ecolabel’s central bodies, it will be a lengthyprocess requiring multiple rounds of consultation, drafting,public comment, and revision. As a result, a less formalmethod for development of guidance is needed. The secretari-at’s standard-setting unit should therefore be empowered tocreate guidance documents to enable quick responses to newdevelopments in the aquaculture industry, such as the intro-duction of novel vegetable-based feeds.

D. Implementation

The third element of ecolabeling systems is the implementa-tion methodology, which applies indicators at the productionfacility or processor level. Ecolabels use certification bodies toapply their indicators via set processes for facility evaluation.

UNITS OF CERTIFICATION

1. Establish individual facilities as the unit of certificationThe appropriate unit of certification for aquaculture produc-tion is the single facility. Much like farm certification for agri-culture labeling, aquaculture facilities are generally self-contained and many of their impacts can be measured effec-tively at each facility. This does not mean that impacts withcumulative effects—such as habitat modification—shouldnot be considered; to the contrary, these factors can andshould be explicitly considered on the individual level. Partialcertification of facilities should not be allowed.

2. Provide for small-scale producer and group certification Many aquaculture facilities, particularly in the developingworld, are small, family-run operations. These facilities lack theinstitutional capabilities that are available to their large-scalepeers. The cumulative impacts of these small producers arenonetheless extensive and they should be encouraged to

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undergo conformity assessment. The aquaculture ecolabelshould therefore develop group certification methodologies topermit certification of numerous producers on a collectivebasis and should consider providing monetary or in-kind assis-tance (through the secretariat’s producer unit) to groups seek-ing certification. This procedure should be modeled on thatused by the FSC, which has proven effective. The Fairtrade sys-tem also provides a model for creation of democratic systemsto share costs and benefits of group certification.

3. Provide for provisional certification prior to construction of new facilitiesSustainability is a high bar for certification that will requirethe use of cutting-edge producer technologies. The potentialexpense of such systems may not be worthwhile for someproducers unless they can determine prior to constructionwhether their facility is likely to be eligible for certification orwhether certification may increase profit margins. Pre-certification would therefore be useful to evaluate siting andother variables. In such cases, full certification would still berequired following construction.

4. Develop chain-of-custody certification In addition to producer certification, the Gold Standard labelmust include traceability provisions. To that end, a chain-of-custody certification should be introduced to trace culturedfish from producer to table. While primarily intended toensure that labeled products at retail originated with certifiedproducers, traceability standards also offer opportunities forcertification of food safety standards and greenhouse gasemissions associated with transportation. These elementsrepresent opportunities to add substantive value to chain-of-custody certification, but the label should be careful to limitits liability for labeled products that prove unsafe. Use ofexisting ISO food quality management system standards mayprove useful in this context.

CERTIFICATION BODY

1. Create a pilot-scale independent certification body

At least at a pilot scale, conformity assessment should prefer-entially be carried out by a single, specialized certificationbody that is independent from but may be purposefully creat-ed to carry out certification for the ecolabel. While subject tosome credibility challenge, a system modeled on the FairtradeLabelling Organization’s certification body would conform tointernational standards. Other labels use similar systems,including the Global Aquaculture Alliance and RainforestAlliance. Benefits from such a system would include consis-tent certification decisions, elimination of pressures for thecertification body to reduce the rigor of certification, cost lim-itation, and simplification of the certification process throughelimination of the accreditation requirement. These benefitsoutweigh the potential credibility shortfalls of such a systemin the short term. In addition, this system can be used to growthe ecolabel slowly, allowing an evolution of practices andrequirements as the label and its certifier gain experience foreach species and facility type.

As the label expands, demand for certification services mayrequire the use of a free-market certification system similar tothat used by the Forest Stewardship Council and MarineStewardship Council. A free-market model may therefore beused either at the outset or due to expansion in the number ofspecies and facilities eligible for certification. This modelrequires accreditation of all certification bodies to ensurecompliance with international standards. Accreditationshould be carefully monitored due to recent recognition thatexisting accreditation system processes may not be credible.The preexisting single-party certification body may evolve tohandle accreditation when the ecolabel shifts to a free-market system. Use of an existing accreditation body wouldalso be acceptable, but would require care to ensure thataccreditation is sufficient to ensure consistency across geo-graphic regions and facility types.

2. Establish protections for certification body independence and consistencyCredibility losses in a single-certification-body system can beminimized by establishing firewalls to protect the independ-ence of the certification body and its employees from the sec-

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retariat. The certification body should be legally and financial-ly independent from the ecolabel, although the entities mayshare a parent organization. In addition, certification person-nel should be barred from producer consultation, standard-setting, or grievance determinations, instead leaving theseduties to the secretariat’s producer unit. The certification bodyshould also review its employees periodically for conflicts ofinterest.

ASSESSMENT PROCESS

1. Create credible, explicit procedures for certification The certification process, like the standard-setting process,should follow set procedures that have been developed incompliance with the ecolabel’s standard-setting proceduresand the ISEAL Alliance Code of Practice.

2. Use preassessment, assessment, and review for certificationAn efficient certification process proceeds through three phas-es, including preassessment, assessment, and review. Thisthree-step process encourages producers to participate whilealso providing credibility.

3. Carry out confidential, streamlined preassessment Preassessment is not intended to be onerous, but rather toencourage producers to participate by providing them with abasic understanding of their standing vis-à-vis the standardfor a low cost. Preassessment should therefore be confidentialand inexpensive. It should occur after an initial consultationwith the secretariat’s producer unit, which can provide assis-tance with achieving the standard but which must remainindependent from the certification process.

4. Develop credible assessment processes that require on-site consultation In comparison with preassessment, the assessment processmust be transparent and should include stakeholder input.The importance of developing-world producers in the aqua-culture context demands on-site meetings with local commu-

nities, which are unlikely to have access to internet-basedcomment outlets. Public comment periods should antedateissuance of initial audit reports, and audit reports shouldexplicitly address all stakeholder comments. The initial auditreport should be opened for public comment, and the finalreport should be publicly available and subject to reviewshould an objection be lodged. Effective systems requireobjections to be filed within set time periods and provide timelimits on the completion of review by the objections panel.The MSC objections process is a good model for aquaculturecertification.

5. Allow limited conditional certificationIn the best case, producers will comply fully prior to certifica-tion audits as the result of assistance from the secretariat’sproducer unit. This is unlikely in all cases, however—particu-larly in developing countries. Where major violations of crite-ria are discovered during the audit, certification should bedenied. However, minor violations that can be redressedquickly need not foreclose certification. Conditional certifica-tion may therefore be permitted, with compliance to beassessed during the following year’s audit. If conditions arenot met at that time, certification should be revoked.

6. Audit producers and processors annuallyInspections are important for ensuring that certified facilitiesremain in compliance. These audits should occur at leastannually, either as part of a full recertification process or inde-pendently, and ideally would be unscheduled or be per-formed on short notice. Audits should include solicitation ofcomments for the facility. Audits should be used to determinecompliance with conditions on certification, and additionalminor violations discovered during audits must be remediat-ed before the next year’s audit. Discovery of major violationsmay result in revocation of the facility’s certificate.

Full recertification may occur annually or after up to five years.Within these limits, the timing of recertification should varyby species in accordance with predicted developments intechnological sophistication. Thus, for species that are devel-oping quickly, recertification should be required on a shorter

THE GOLD STANDARD


term than for species for which production practices are rela-tively stable.

7. Collect performance data and report to secretariatThe certification body plays an important role in ensuring thatthe ecolabel’s indicators translate into effective on-the-

ground performance. The certification body’s inspections dur-ing the certification and audit processes allow for data collec-tion across all of the ecolabel’s indicators. All performancemetrics should be collected and reported to the secretariat’sstandards unit for use in that body’s annual report on per-formance.

THE GOLD STANDARD


Documents

Gold Standard for Sustainable · See John C. Dernbach, Synthesis, in Stumbling Toward Sustainability 1, 5–6 (2002); Michelle Allsopp et al., Challenging the Aquaculture Industry