Thank you for responding to Fair World Project’s (FWP) letter and concerns regarding Fair Trade USA’s (FTUSA) labeling and commercial availability standards. I’ve read with great interest that FTUSA is reconsidering its labeling standards and is actively engaging stakeholders on this issue. FWP commends FTUSA’s work to expand the fair trade market. However, as a FLO member, FTUSA unilaterally chose to ignore the FLO commercially availability requirement for multi-ingredient products which states that ““all that can be certified fair trade must be fair trade.”
FTUSA has made it clear on several occasions, including during public webinars and in the media, that the new FTUSA’s standards will not include a fair trade commercial availability requirement. Fair World Project’s concerns with this approach to multi-ingredient fair trade products are twofold: 1) the unilateral process by which this decision was made within FTUSA and 2) the implications of not establishing an enforceable commercial availability standard for multi-ingredient fair trade products.
- While FWP is encouraged by FTUSA’s willingness to revisit its labeling standards and is consulting stakeholders, FWP wishes to underscore that this process must be transparent and documented, with FTUSA accountable to the larger fair trade movement and market. Specifically, FTUSA should create an online portal for this issue, similar to the portal for “Farm Workers Standard” (http://fairtradeusa.org/certification/standards), with a reasonable timeline for compiling and reviewing stakeholder input.
- A strong and enforced fair trade commercial availability standard, analogous to FLO 2.2 or IMO 1.1.1, is critical to assure that conventional companies with little long-term investment to fair trade establish fair trade supply chains and expand the impact for producers. Without a commercial availability requirement, manufacturers have little incentive to source fair trade ingredients beyond the bare minimum to receive the FTC mark. Claiming that you will “strongly encourage” a company out of producing a product that sources only Fair Trade Certified sugar and no Fair Trade Chocolate (or other ingredients that are widely commercially available) is not sufficient. This case was stated on a FTUSA webinar with a Hot Cocoa product. This standard must have clear and enforceable guidelines.
- As written, FTUSA’s labeling requirements technically allow for multi-ingredient products to carry the “Fair Trade Certified” mark so long as they reach a minimum dry weight of 25% fair trade ingredients. Without a fair trade commercial availability requirement, manufactures will be granted use of the FTC mark for multi-ingredient products with only 25% FTC content, even if their product could contain a higher percentage of FTC content.
- FTUSA does not have a public policy for granting exceptions or for manufacturers transitioning their supply chain to fair trade. If exceptions are granted, clear benchmarks for increasing their fair trade ingredient thresholds must be made public and within 18 months they must start to use the commercially available fair trade ingredients.
- As currently written, FTUSA labeling policies do not allow for manufacturers and consumers to easily distinguish products with high Fair Trade content and those with minimal fair trade content. Dedicated fair trade manufacturers that source 100% of Fair Trade ingredients will be at an unfair advantage when consumers must chose between similar products, one with a maximum percentage of Fair Trade ingredient, and one with only the minimum. . To assure a level playing field for consumers and manufacturers labeling requirements must include a clear identifier for the percentage of Fair Trade ingredients. Ingredients logo must be accompanied by a % of fair trade ingredients if used on the front panel.
Thank you for your time and consideration. I await your response. In the ongoing process of transparency we will post this and other correspondence on our website.
Fair World Project