Fisheries Committee on May 15th, 2019

[The Chair, Liberal, Ken McDonald]

Good afternoon, everyone. We'll get started with our first set of witnesses.

Pursuant to Standing Order 108(2), we are holding a briefing session on seafood mislabelling. In our first half hour we have, from Oceana Canada, Kimberly Elmslie, campaign director, and Lesley Wilmot, communications director. As well, as an individual, we have a former employee of Oceana Canada, Julia Levin. Welcome.

I don't know who has opening remarks. You're going to share the time? Okay.

When you're ready, Lesley, you have seven minutes or less.

[Lesley Wilmot, Communications Director, Oceana Canada]

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.

[Kimberly Elmslie, Campaign Director, Oceana Canada]

Great. Thanks.

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.

[The Chair, Liberal, Ken McDonald]

Thank you for that.

Julia, I don't know if you had a presentation to deliver.

[Julia Levin, Former employee, Oceana Canada, As an Individual]

I'm here in a support role.

[The Chair, Liberal, Ken McDonald]

Okay. I know you were listed as an individual, so I wanted to give you that opportunity.

[Julia Levin]

Thank you.

[The Chair, Liberal, Ken McDonald]

At first I didn't know how much time we were going to have, but it looks like we could probably do a seven-seven-seven minute round before we reach five o'clock.

Mr. Morrissey, you have seven minutes or less, please.

[Bobby Morrissey, Liberal, Egmont, PE]

Thank you for your presentations. Obviously, they're in-depth and you put a lot of thought and research into your statistics.

When you reference the 44% of samples in restaurants that are mislabelled—I forget the other commercial outlets you were looking at—could you give us an example of the type of mislabelling you uncovered there?

[Julia Levin]

Yes.

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.

[Kimberly Elmslie]

It's known as the laxative of the sea.

[An hon. member]

They don't put that on the menu!

[Bobby Morrissey, Liberal, Egmont, PE]

I'll go back to your reference of the snapper. A fish is a fish. There are all these varieties. Obviously, it tastes good to me or I wouldn't continue eating it. From that side, why should the consumer be concerned?

[Julia Levin]

There are multiple reasons. Let's start with health. Of the hundreds of mislabelled samples that we found, 60% had health issues.

[Bobby Morrissey, Liberal, Egmont, PE]

They had health issues?

[Julia Levin]

They had potential health impacts. For example, the type of species substituted had higher risk of certain environmental contaminants. We came to the number by cross-referencing the CFIA's fish list, which lists all of the potential health impacts of certain species.

We cross-referenced the substituted species that CFIA flagged as having associated health risks with what was on the label. In that 60% of cases, they were fish with flagged health concerns that weren't reflected in the species on the label.

[Bobby Morrissey, Liberal, Egmont, PE]

That would concern me.

[Julia Levin]

Exactly.

Also, seafood is a high allergen risk category. You don't want to be served a fish that you're allergic to. That's obviously a huge issue.

Then there's the impact on our oceans, because 30% of the mislabelled samples are vulnerable or threatened species, and as my colleague mentioned, illegal fishing is also a big issue related to seafood fraud. It often ends up happening, and one of the primary motives for seafood fraud, other than economic incentive, is to launder illegally caught fish into supply chains.

As we presented before—

[Bobby Morrissey, Liberal, Egmont, PE]

Could you elaborate on that a bit more? They're laundering....

[Julia Levin]

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.

[Kimberly Elmslie]

I'll give you some examples from a report that we had put together with all of our sampling, which I can certainly supply to committee members. I'll just read from it, because I'm not good at remembering numbers.

Some of the things we found were that, on the menu, sea bass, which costs $113 per kilogram, was replaced by catfish, which costs $11 per kilogram; and rock lobster at $95 a pound was replaced by crayfish at $20 a pound. This is the thing we're seeing. You've paid for one thing, but you're getting a much cheaper substitute than what you think you're getting.

[Bobby Morrissey, Liberal, Egmont, PE]

How do you define mislabelling? There's an obvious side to it, but it takes many different forms.

[Julia Levin]

Yes, it does.

Seafood fraud is actually an umbrella term that can also refer to things like overglazing, underweighting and different issues of that sort, where you're pretending there's more fish matter than there is in what you're selling.

Oceana's focus on species substitution is due to the ocean impacts of that form of seafood fraud.

Is that enough of an answer to your question?

[Bobby Morrissey, Liberal, Egmont, PE]

Well, I would interpret or define it as simply telling me I'm getting a particular species when I'm not, but you're getting into the mislabelling of volumes. I know that in some fish processing operations, you can increase the weight volume by doing things with it.

Does that...?

[Lesley Wilmot]

I'll just clarify that our study does not look at things like volumes. It's really about species mislabelling—species substitution.