Response to IMO: re Chocolate Labeling Practices

Florentine Meinshausen
Institut für Marktökologie, IMO
IMO Group office
Weststrasse 51
CH-8570 Weinfelden – Switzerland

Dear Florentine,

Thank you for your formal response on November 22nd to our labeling concerns. We have posted your response on our website

While we appreciate you taking this seriously and your thorough response and commitment to correct, we do have a few remaining concerns.

1. In reviewing the previous Fair for Life Standards from 2008, it states in section that the use of the green (full) seal was even at that time available only for registered, authorized processors or traders. Neither Trader Joe’s nor Whole Foods is listed as registered on the IMO website. Can you please direct us to the sections of the standards which would have allowed private label products to carry the full seal without registering or signing a contract or clarify where we can find information about the terms of authorization for Traders Joe’s and Whole Foods?

2. In the 2008 labeling guidelines, we understand your point that the 95% rule applies only to typically certified ingredients, however, our reading of the rest of the policy stating “at the very least 50% of the agricultural ingredients (in weight) must be certified” to mean that even if an exemption for sugar were granted in terms of the 95% rule, the label should not have appeared on the front panel as 50% of agricultural ingredients, including sugar and milk, were not fair trade.

3. We have asked a few brands about their experience obtaining fair trade sugar for composite products and it has been indicated to us that it is possible. Can you please tell us more about decision-making process that led to this exemption and whether you are still allowing sugar that is not fair trade in products carrying the full label?

4. We are not clear on why, if the new standards were released in February 2011, there were still products in the market that are not in full compliance more than 18 months later, and that had not in fact even been audited until 18 months after the release of the standards. On transition period, the 2011 Preamble states, “Operations that are already certified will have a transition period of 1 year to implement the new minimum requirements” which we understand to mean they should have been in full compliance by February 2012.

We understand that you are trying to correct this situation. We will post any additional responses from you to clarify the above points on our website. We would also request that you post on your own website an explanation of these inconsistencies and the steps that you are taking to correct them so that there is clear and transparent information available to consumers.

Because these labeling issues are significant and represent an inability for Fair for Life to uphold its own standards, we hope that they are quickly corrected. If they are not corrected in full by February 28, 2013, we will need to reconsider our support of Fair for Life.


Dana Geffner



Dana Geffner

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