Cautionary Support for Organic Wild Seafood

March 26, 2021

PCC provided feedback and comments to the National Organic Program (NOP) on a proposal to develop production, handling, and labeling standards for certifying wild-caught seafood as organic.

When the NOP was established under the Organic Foods Production Act (OFPA), its implementing regulations taking effect in 2002, the oversight committee known as the National Organic Standards Board (NOSB) proposed that only a discrete population of aquatic animals similar to on-land livestock herds would be suitable for organic certification. In 2003, congress amended OFPA to include the option of certifying wild-caught fish as organic if regulations were developed. Two years later, the Secretary of Agriculture established the Aquaculture Working Group (AWG) to develop recommendations and standards for certifying aquatic animals and aquaculture, including wild-caught fish, as organic.

Since that time, the National Organic Standards Board (NOSB), has periodically convened to discuss aquaculture, seaweeds, and other aquatic-derived products or materials in relation to organic certification, but wild-caught seafood dropped from the discussions and proposals submitted by the NOSB and AWG to the NOP. The last NOSB recommendation on aquaculture was completed in 2016 but was never released for public comment or added to any work agenda. In 2021, congress urged the NOP to resume evaluating wild-caught fishery systems and to assess the feasibility and appropriateness of developing organic production, handling, and labeling standards for wild-caught seafood.

In March 2021, the NOP took the first step in resuming the conversation of wild-caught seafood in organic and hosted a virtual stakeholder engagement and listening session. PCC participated and provided feedback, a record of which can be found on the USDA’s Wild-Caught Fish Virtual Town Hall Page.

PCC also submitted written comments to provide more in-depth feedback on the questions proposed during the listening session and to situate our feedback within the context of PCC’s experience and unique perspective as a certified organic retailer based in the Pacific Northwest, a region with deep cultural and economic connection to its aquatic ecosystems and resources. PCC’s written comments expressed general support for exploring how the organic label could elevate the work of existing fisheries conservation groups, such as Monterey Bay Aquarium’s Seafood Watch, but recognized the risk of missteps or abuse that could occur in aquatic ecosystems. PCC maintained our objections to the certification of any open ocean net pen operations being certified as organic and urged the NOP, if they move forward with developing standards, to do so in a manner that is protective of marine conservation efforts and public health concerns associated with seafood consumption.

Read PCC’s full written comments here.

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