October 19, 2011


Paul Rice, President and CEO

Fair Trade USA

1500 Broadway, Suite 400

Oakland, CA 94612


Dear Paul:


I am writing on
behalf of the Fair World Project (“FWP”), a project of the Organic Consumers
Association which, as you know, is the nation’s largest network of green and
ethical consumers.  FWP is extremely
disturbed about those elements of Fair Trade USA’s new labeling standards
announced as part of its “Fair Trade for All” initiative.


Under the new
labeling standards, in order for a product to bear the “Fair Trade Certified”
mark—clearly implying that the product in
and of itself
is “Fair Trade Certified”—only 25% of the product will be
required to consist of fair trade certified ingredients.  In order for a product to bear the “Fair
Trade Certified –Ingredients” mark, only 10% of the contents of the product
will be required to consist of Fair Trade Certified ingredients. FTUSA would
require only 10% of the contents of products bearing the “Fair Trade Certified-Ingredients”
seal to consist  of fair trade certified
ingredients—even though that seal looks identical to the “Fair Trade Certified”
whole-product seal.


The egregious effects of these new standards is
greatly magnified by FTUSA’s second significant change in its policy:  that, as you announced in a recent webinar
explaining the new initiative, FTUSA will will not require that an ingredient
used in a product bearing the FTUSA “Fair Trade Certified” seal be fair trade
certified if it is commercially available in fair trade certified form, so long
as the FT content threshold of 10% or 25% is reached.  The result of this new policy is that, for
example, 75% of the contents of a chocolate bar bearing the “Fair Trade Certified”
label could consist of non-fair trade
cocoa if the remainder was 25% fair trade sugar—indeed, could in fact consist
of cocoa produced using child labor or other practices that the Fair Trade
movement is designed to prohibit in the production of commodities labeled “Fair
Trade,” despite the fact that fair trade cocoa is commercially available in
fair trade form.


The combined result of these practices is that the
“Fair Trade Certified” label would 
provide consumers desiring to support Fair Trade producers, no
meaningful or reliable indication whatsoever that in purchasing the product
bearing that label, the consumer would in any way be supporting or contributing
to fair trade producers with the integrity that they expect when they see a
fair trade seal on a product. 


OCA/FWP’s position is that a fair trade seal should
appear on the front of a  product only
if, one, a minimum/majority of 50% fair trade content by dry weight is present
(not 25% and certainly not 10%), and two and most importantly, that the
non-fair trade ingredient content is permitted in non-fair trade form only
until fair trade forms become commercially available in the market, at which
point that product must transition to the fair trade form of the ingredient
within a reasonable transition time, not to exceed 18 months at the most.   For products with any less FT content than
50% and that do not commit to sourcing fair trade forms of non-FT ingredients
in the product as they become commercially available, no fair trade seal should
appear on the front of packaging; rather, there should only be a “Made with
Fair Trade [specified ingredient(s)]” call-out on the front with the seal in
the back if present at all.  Fair trade
seals should fly on the front of products that truly support fair trade
producers with the integrity that fair trade consumers expect.  Front use of FT seals is not for fairwashing
products and brands that seek to use only a minority of fair trade content in
products in order to appear as if they support fair trade producers like
dedicated FT brands and products do.


For these reasons, FWP demands that FTUSA immediately
change its labeling standards and practices, and publicly announce that
decision.  As of January 1, 2012, FWP
will no longer recognize  FTUSA as a
reputable fair trade certifying organization, unless FTUSA conforms at a
minimum with FLO’s existing FT content and commercial availability requirements
for FT products. FWP believes FLO’s content thresholds already leave much to be
desired.  FWP cannot accept FTUSA making
them even lower while also abandoning the requirement to source commercially
available FT ingredients.  


Please advise me of FTUSA’s decision no later than
close of business December 15, 2012.  If
we do not hear from you by that time, FWP will assume that FTUSA intends to
proceed with its changes in labeling standards and practice as previously
announced and therefore we will withdraw our support of the FTUSA certification

Thank you for your time and immediate attention to
this critically important matter.


Sincerely yours,

Dana Geffner

Executive Director 

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