Without an established USDA NOP organic standard for aquatic species, there are many questions and a general lack of
information available to consumers. We encounter these questions and requests for the facts from many customers and consumers alike and
thought we should commit some space on this page to address many of the issues surrounding certified organic seafood products.
What is or what makes a product “Organic”?
Organic standards are production standards. The term “Organic” does not refer to food safety or nutrition, but a set of production standards
that are established and approved (by a governing body) and audited by a licensed, independent certifying agency. For a fin-fish product to be
classified as organic the entire lifecycle of the fish (smolt to harvest) and all input (feed, chemicals, additives, coloring agents) and
the production process (harvesting, cleaning, processing and packing) must follow a defined set of standard regulations and inspected by an
independent, licensed certifier for compliance. The defined standard is licensed by a governmental agency (in our case DEFRA / UK Department
for Environment, Food and Rural Affairs). The concept for organic aquaculture is to produce fish in as natural an environment and method as
possible while maintaining control over the input (anything introduced to the animal or the environment within which the animal
resides) and concurrent reduction in the level of output while maintaining the water quality and surrounding pelagic and benthic environment.
Why is Farm-Raising a base requirement for Organic Seafood?
Wild fish cannot be classified as “Organic” as there is no possible way to control the fish movement, input (diet) or exposure to noxious
contaminants. Wild fish may migrate through polluted waters or over-eat a particular food source in a given area (thus damaging the
balance of the eco-system). In addition there is no possible way to monitor the health of the organism or prevent the introduction or exposure
to parasites. Essentially, “Organic” is defined by the ability to control all applied input, health and output of the organism. “Organic”
refers to the ability to control the variables that are controllable and quantify variables that are both controllable and uncontrollable while
“wild” is inherently uncontrollable.
What is the difference between Conventional Farm Raising and Organic
Organic farming is framed by a legally defined set of standards and regulations with criteria that extend beyond legal requirements imposed
upon the conventional industry. The conventional industry has to meet some legal requirements (for use of therapeutic agents etc.), yet are
not required to extend any improvements or restrictions beyond those legally required and are not necessarily audited by any independent third
party agency. A conventional farm may in fact extend practices far beyond the legal requirement, but certified organic are required to do so
and must be subjected to independent auditing of those requirements.
Some of the variables are as follows:
(a) Stocking density: Organic salmon farms are required to maintain stocking densities of less than 10 kg/m3. UK Animal Welfare Charity
Standards (such as Freedom Foods) have defined the operating density for salmon at 15 kg/m3 for animal welfare purposes. Conventional farms my
stock as high as 40 kg/m3. A benefit of lower densities is the decrease in overall environmental impact with less dry matter effluent (uneaten
feed and fecal waste). At lower densities, the fish encounter far less stress which directly translates to greater overall health and reduces
the necessity for prophylactic use of therapeutic agents in order to maintain health of the overall population.
(b) Feed: Organic farms can only use approved certified organic feed. The (UK) basis for certified organic feed is the re-cycling of fish
protein (other than salmonid species) from human food processing. The benefit is the use of what would otherwise be waste (heads, tails and
trimmings from sustainable fishery products being processed for human food). This has the direct ecological benefit in the reduction of over
fishing the pelagic species commonly used in fish meal production and the added environmental benefit of re-cycling this waste to produce a
sustainable feed regimen. Furthermore, all vegetable matter used in (UK) Organic feed must be certified Organic and be free of any GMO and
animal proteins (e.g. beef, pork, poultry or sea mammal proteins). No corn or corn derivatives are allowed in certified Organic feeds (corn is
no longer considered to possibly be GMO-free). Finally, the overall fish oil content in the fish feed cannot exceed 26%. In conventional feed
the oil content may be as high as 45% in “high-energy” feeds used to accelerate the growth rate of the fish. The benefit of limiting overall
fish oil content is realized on several levels. One is the ecological benefit of reducing the amount of pelagic fish used to create the
additional oil and another is the potential reduction of environmental contaminants. Environmental contaminants (PCBs, Dioxins) are stored in
the fat cells of all animals (including humans). Reducing the oil content in the feed reduces the possible exposure to environmental contaminants for fish consuming an organic diet. A final benefit in limiting
the fish oil content in the feed is that the fish are receiving a diet that is as close to that which they would encounter in nature and as a
result the fish are growing at a natural rate and will exhibit enhanced muscle development and a brighter, cleaner flavor. The (high-energy)
feeds used in high intensive conventional farming will produce a market sized fish in about 20% less time and the corn based/high-energy diets
generally demonstrate a distinct bitter aftertaste and a reduction in muscle tone.
(c) Therapeutic agents: The use of any therapeutic agents (antibiotics) are only allowed under strict veterinary prescription and may result in
the loss of organic status if required. Medications are only permitted for animal welfare purposes and require authorization from the
certifier prior to use and double the quarantine period post administration. The conventional industry is permitted to use therapeutic agents
as prophylactic (preventative) against possible infection, which is not allowed under (UK) Organic certification. Any use of therapeutic
agents on any sites producing under the Black Pearl trademark must be removed from distribution and sold off as conventional production.
(d) Proximity to neighboring farms: Certified organic farms are required to be segregated from all neighbors (not limited to conventional
farms). The minimum distance required is not defined in terms of miles, but within a licensed site area. Essentially an organic farm cannot
be certified if it occupies a licensed site that also accommodates a conventional farm. In real terms the farms producing salmon under the
Black Pearl Shetland Organic trademark are miles from any neighbors (the direct benefit of being located in the Shetlands where this is
possible), which is more than a sufficient buffer to reduce the likelihood of the transmission of disease and/or exposure to effluent from a
(e) Pigment: No synthetic pigments are allowed to be added the diet of Black Pearl Shetland Organic Salmon. Within the possibilities of
(natural) pigments, Krill meal is not allowed as a source of pigments. All fish packed under the Black Pearl Shetland Organic trademark do not
have any pigmenting compounds (specifically designed to impart color without nutritional benefits alone) added to the feed.
Who are the governing bodies of Organic Seafood?
Each country recognizes and licenses its own Organic certifiers. In the EU there is a legal regulation for Organic (EU regulation # 2092/91)
that requires minimum compliance in all standards for all countries (each individual organic certifications standard). Each country (i.e.
France, Germany, England) can stipulate their own additional requirements to this regulation. In the UK, the legal/governmental body
controlling organic regulations is the previously mentioned DEFRA who authorize and monitor the UK certifying bodies and their individual
Presently in the US, there is no standard established by the USDA (the Government department responsible for setting and regulating organic
standards). The NOSB (National Organic Standards Board) is currently reviewing the (Interim Final Report of the Aquaculture Working Group) a
taskforce established by the USDA to frame the standard for aquatic species.
This can be a very confusing position which has led to many arguments and some state-sponsored (California) legislation to restrict and control
the use of the word “Organic” in fish and seafood. At present we are well within our legal right to market Black Pearl Shetland Organic
product as an “EU Certified” Organic product as long as the references to Organic Food Federation/UK are made on all labeling and promotional
materials as required by our certifier (OFF).
The UK Organic certifiers are:
Organic Farmers and Growers
Scottish Farmers and Growers, Ltd.
Organic Food Federation
UK Soil Association
Bio-Dynamic Agricultural Association
Irish Organic Farmers and Growers Associtation
Organic Trust Limited
International Certification Service (GB) Ltd
Organic Certification Ltd.
Quality Welsh Food Certification Ltd.
SGS United Kingdom Ltd.
Organic certification UK Ltd.
How are these standards monitored?
The independent certifying body formally audits the organic site on an annual basis, where the actual day to day records and operations are reviewed and inspected. In addition review of outside vendors supplying feed stuffs and materials to an Organic grower are reviewed and corroborated. In between the formal audits, the accreditation body can and does conduct unannounced informal visits.
It should be noted that outside of the minimum (EU Regulation # 2092/91), there are differences between the various organic standards that should be considered significant for the marketing purposes. The single most important distinction between the Organic Food Federation (OFF) standard under which Black Pearl Shetland Organic is certified and others is the banning of the use of by-catch in the pelagic base protein used as fish meal sources. The Organic Food Federation does not permit any by-catch in the fish meal sources.
How can feed based upon wild caught pelagic fish used for fishmeal be considered Organic if there is no Organic standard for wild species?
There must be some flexibility allowed in any organic system whether it is cattle, poultry or aquatic species. A prime example is the concept of “grass-fed organic beef”. Cattle are permitted to graze on grasslands that are also certified. The certifiers have very strict rules in the certification of these producing areas to ensure for example that synthetic fertilizers and pesticide applications are not applied or have not been for a considerable specific period of time. The fact remains however that a beef steer grazing on a certified pasture is feeding upon some percentage of wild plant food that is exposed to the open environment and subjected to rain that may contain a variety of environmental pollutants or contaminants. Similarly certified organic poultry is permitted to roam freely within a limited, certified space are also able to consume wild food matter that is not certified. These points of flexibility must be a part of any system not raised in a closed vacuum, yet the standards are set to limit variables that man cannot control.
There have been recent statements in the media claiming that EU standards for Organic aquaculture are far lower than US standards…is this correct?
Currently the USDA NOP has not established any organic standard for fish or seafood products, therefore EU certification standards cannot be portrayed or comparatively described as being “lower” or correct to suggest or imply a less than adequate set of criteria. The fact is the EU is far ahead of the US and the USDA will more than likely adopt some form of or multiple components from well established EU standards as the principal framework or basis of an eventual US standard. To make claim that an EU organic standard is not credible is itself an incredible statement considering the absence of any such standard presently in the US marketplace.
The current Organic Food Federation Aquaculture standard can be downloaded off the internet at (www.orgfoodfed.com).
How do retailers handle and display Organic seafood products? How do consumers know the product is authentic?
Retailers must handle all organic seafood products separately from conventional products. This is similar to the rules in place for certified Kosher products. In addition a retailer’s must display the organic products in a separate area defined by partitions that do not permit contact with non-conventional products. All certified Organic seafood products must display signage that contains the reference to the UK certifier. In our case that would be “Organic certification UK 4” which refers to and links the product to the Organic Food Federation (as listed in the table above). This labeling information is required by the certifier and failure to properly identify the product accordingly may result in the loss of accreditation by the certifier. In our case, we label each container and affix identification tags on each fish and each fillet or portion. These identification labels should remain in place until the point of purchase at retail.
Have retailers realized any success merchandising and marketing EU certified Organic Seafood?
Many retailers are very interested in the product area and several progressive retailers have set up entire Organic seafood areas in their service counter space that has produced substantial results in a very short period of time. A recent collaborative report has been published by the New Jersey Department of Agriculture and Rutgers University titled, “United States Market for Organic Seafood”. This study clearly indicates extensive consumer interest and positive response toward the concept. The study can be obtained by visiting the following web site: www.newjerseyseafood.nj.gov.