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 scheme.
Thank you for your time and immediate attention to this critically important matter.
Sincerely yours,
Dana Geffner
Executive Director