FUR COMMISSION USA COMMENTARY, APRIL 10, 2005
Talking to the Consumer
Labeling ourselves or clear communication?
By Teresa Platt, Executive Director, FCUSA (April 1998 - May 2011)
Once upon a time, a producer was a retailer was a consumer. We bartered and traded our way through life. Over the past century, we have become specialists in production, design, manufacturing, marketing, wholesaling, distribution and, ultimately, retailing. Retail is where the entire industry is represented by a storeowner or clerk, a person who may or may not be familiar with all the components of the production of a product. However, all the way down the line, we all still depend on clear and honest communication with the consumer.
Industry constantly asks, "What does the consumer want to know, and need to know? How do we best communicate with the client?"
Product labels, third-party certification, brochures, websites, advertising campaigns, public tours of production facilities and educational campaigns are all methods of communicating to the public and the consumer. Each form has strengths and weaknesses, costs and benefits. Good communicators use components of each.
Labels, labels, what's in a label?
Fur Commission USA (FCUSA) administers a certification program establishing superior animal husbandry techniques on the mink farm. Based on the Standard Guidelines for the Operation of Mink Farms in the United States as defined by FCUSA's Animal Welfare Committee, the certification program is built upon the work of the American Veterinary Medical Association (AVMA). AVMA veterinarians act as third-party certifiers on the farms. This program also establishes a relationship between a farmer and a local veterinarian, a must for a successful farm. Certified farms receive a certificate to display plus a seal for use in promotional materials and on their pelts at auction, the wholesale level in the fur industry. Although there have been numerous discussions about keeping the "humane care" label with the pelts through the manufacturing process, all the way to the retail level, there are many obstacles to this reality. The FCUSA board has never considered voting on supporting or opposing a label at the retail level.
Product labels take copious information and standardize it for masses of retail consumers who regularly search for the same information. In talking to the consumer via a label, producers are allowed to say anything they want, as long as it is clear and truthful. In the US, the Federal Trade Commission's Bureau of Consumer Protection works with industry to satisfy consumer demands for clear and truthful labels. Tied to labels, but separate, are third-party certification programs such as eco-seals.
In its own words, the FTC "enforces a variety of federal antitrust and consumer protection laws. The Commission seeks to ensure that the nation's markets function competitively, and are vigorous, efficient, and free of undue restrictions. The Commission also works to enhance the smooth operation of the marketplace by eliminating acts or practices that are unfair or deceptive. In general, the Commission's efforts are directed toward stopping actions that threaten consumers' opportunities to exercise informed choice."
The key words here are "competitive" and "informed choice". How do we give our customers the information they need when and where they need it? And how do we allow competition to thrive, avoiding barriers to beautifully produced products supplied by hard-working people?
A closer look at the ordinary
To appreciate how detailed a label can be, take a close look at the label on the common can of tuna fish pulled from any pantry. The StarKist brand name, next to "Charlie the Tuna" with his jaunty beret, is prominently displayed across the front of the can. Establishing Charlie as a trusted symbol to the consumer required many years and lots of marketing dollars. "Sorry, Charlie. Only the best tuna can become StarKist tuna." Charlie is the only fish to gain fame from not making the grade and ending up as lunch.
The tuna can label lists contents - solid white tuna, fancy albacore (the species) - in spring water (how processed), plus weight in ounces and grams, plus "nutrition facts" - calories, fat content, percentage of "daily values" (based on a 2,000-calorie diet), fat, carbs, protein, etc. The ingredients list is complete and broken down, with nothing hidden such as monosodium glutamate (MSG) or peanut oil mixed in under "hydrolyzed protein", crucial for those following special diets, with allergies or food sensitivities.
Additionally, this can of tuna states that the can is recyclable, the tuna is "dolphin safe", and a "natural source of Omega 3", and that the American Heart Association has approved this product. As if that's not enough, larger cans include a recipe under the catchy name "Cookin' with Charlie".
Stamped into the top of the can is a tracking code. This allows the can of tuna to be traced back to the source and, from purchasing and processing paperwork, back to the fishing boat that supplied it, through the boat's logbook, back to the very set of the net that caught the fish and the exact fish well that stored the fish and carried it to shore.
Nowhere on the label does it state "made in the USA", a tough term for a global company that purchases tuna from around the world and processes it in multiple locations. What "made in the USA" means in a global economy is, in truth, an exercise in frustration, contradiction, special interest lobbying, federal guidelines and lawsuits. This is a term that is used with great care.(1)
Add a bar code for grocery store pricing and inventory tracking, contact info for the distributor, a 1-800 number and a website address for more info and special promotions. This little can of tuna leads the consumer to worlds of information.
Special interest labels
A perfect test case of special interest labels is the "dolphin-safe" logo on this can, the first and only "humane care" label hammered out in the US Congress.(2) Although tuna producers endured 20 years of consumer "boycotts" over the take of cetaceans during tuna harvesting, sales grew consistently, 20% in the five years prior to the 1990 adoption of the "dolphin safe" label.Ê
Upon the canners' adoption in 1990 of the "dolphin safe" label, the issue was hashed and rehashed to the point of confusion and overload. What appeared to be a simple labeling fix for a complicated resource management issue escalated to an international debate by people who had never seen a tuna boat and had no idea where the fishing grounds were. Animal rightists used the label as a platform to advance their agenda against fishing.
In the five years after the "dolphin safe" label was mandated by Congress, sales plummeted 20% and fishermen endured the lowest prices in 20 years. Quality suffered, and segments of the buying public thought dolphins were now in the can along with the fish. They quickly turned to chicken.
What went wrong with the industry's efforts to reach the high ground? And where, oh, where was the fabled "green consumer"?
Controversy and complications
From "recyclable" to "dolphin safe" to "sustainable" to "cruelty free" to "organic", attempts at what is called "special interest labeling" or "eco-labeling" have been fraught with controversy and complicated discussions.
However, the first question to ask remains the simplest: Is the consumer demanding a special interest label, or is industry responding to conflict generated by people who do not purchase the product?
In a rush to gain market share by embracing the "green" consumer, the industry forgot to ask if the "green" consumer truly existed and, if real, could such a consumer be wooed by a simplistic label that did not take into account the holistic nature of resource management and use, the intricacies of production and manufacturing? What would happen to that sophisticated, involved consumer when they learned that this "one size fits all" production-focused label was in conflict with the diversity of fisheries and multi-species eco-system management?(3) Was sustainable use aided by a label that focused on the charismatic mega-fauna, the dolphin, as impacted in one ocean by one gear type, while ignoring other species, other oceans and other fishing gear? What happened when the label became a trade barrier to product produced sustainably in developing countries, a buyers' club consisting of the multi-nationals of the world?
It only took a few months before the honeymoon was over and Greenpeace branded the "dolphin safe" green label "greenwash".
In retrospect, it was apparent that tuna consumers wanted a quality product at a fair price and had never asked for an assurance of dolphin safety in their product. They relied on government fisheries agencies to ensure that the product was sustainably produced, from all angles. The consumer already pays for fisheries management with their tax dollars collected in sales tax at the grocery store.
Defining eco-disasters and trade barriers
The first definition of "dolphin safe", hammered out by animal rights/conservation groups and marketing gurus on land, turned out to be an unmitigated environmental disaster at sea and a trade barrier in disguise. The Latin countries refused to abide by the dolphin safe definition as defined by canners on the Western side of the Pacific Ocean since it excluded fish harvested sustainably in the fishing grounds dominated by the Latins on the Eastern side of the Pacific Ocean. The definition excluded 25% of the world's canned tuna supply from major markets and prices plummeted to their lowest in twenty years. Fishermen suffered, bankruptcies followed. Eco-trade barrier? The Latins and their EU buyers thought so and quickly filed WTO (then GATT) complaints and won.
Although producers were promised a premium for meeting the terms of the "dolphin safe" label, blacklisting or excluding 25% of the world's canned tuna supply from major markets of the world caused a price collapse. The blacklisted product was, of course, absorbed into the world market but at distress sale prices. Closing major markets without a concomitant reduction in production drags down prices globally for all producers. Tuna prices plummeted, and bankruptcies quickly followed.
To salvage this fiasco, five years of work by the world's largest conservation groups, government and fishermen resulted in a redefinition of the "dolphin safe" label to one that would actually work for dolphins, a host of marine creatures, consumers and the 12-nation tuna fishing fleet. However, ten years, two GATT complaints by Mexico and the EU and several lawsuits later, the "dolphin safe" label is still in dispute.
An animal rights group, Earth Island Institute (EII), used the issue to push for their own certification program, one even more stringent than the one offered by the US government's "dolphin safe" label. EII charges participating canneries on a tonnage basis, threatening market closure for anyone not paying up. The canneries paid up but passed off the responsibility of meeting the EII requirement to the fishing boat captains who have to sign a certificate for EII. Lying to get the EII certification became commonplace so no cannery uses the EII-approved seal on their cans of tuna but they continue to pay EII, keeping them at bay. An unsteady, unstable truce has been reached while tuna prices continue to hover at break-even and lower.
Third-party certification programs are common. From the "Good Housekeeping Seal of Approval" to the US Department of Agriculture's seal of quality for meat, to energy efficiency seals, certification programs come at a cost. Estimated price tag for the World Wildlife Fund to monitor its proposed Marine and Forestry Stewardship Councils' "sustainability" labeling program: 1-4% of gross. That's in addition to the taxes we already pay for government to do the job ensuring that everything produced comes from sustainable and humane harvests.
Participatory democracy and shortcuts to sustainability
The fur trade should answer some basic questions as it works to address sustainability and humane issues with labels:
- What information does the consumer and the general public, policy makers want and need?
- What is the best way to present information to various audiences: labels, brochures, advertising campaigns, websites, tours, educational campaigns?
- How can the industry ensure good production practices and support responsible producers without incurring huge costs, setting up trade barriers or injuring the producers in the process?
Resource providers already have a system for ensuring that our production is humane and sustainable. It's called democracy. All citizens are represented in this process. In the democratic system, if production is to be outlawed, a process exists for redress by the participants. In a certification program, if product is excluded, for any reasons, there is no redress. A farmer can lose his market and therefore his livelihood from a process that was not elected to represent him.
Fur farmers need to ensure open trade patterns for all legally produced products. If a product is produced inhumanely or unsustainably, it should be illegal and production stopped - democratically, in an open process, with protection for property rights and respect for the rule of law.
Yes, we want to talk to our consumers. But is reducing the discussion to a tiny label really the way to go? Can't we expand the conversation, not reduce it? While in the midst of a communications revolution, where more information can be moved further and faster than ever before, why, oh, why, are we trying to reduce this incredible, complicated, wonderful, exciting discussion down to a tiny symbol on a label?
(1) See FTC: Made In The USA Comments Concerning The Made in USA Coalition - P894219, Aug. 8, 1997.
(2) See The tuna-dolphin controversy. By Michael Scott, Inter-American Tropical Tuna Commission, August 1998.
(3) See What Price Dolphin? Scientists are reckoning the true cost of sparing an endearing mammal. By Betsy Carpenter, June 1994. (PDF format)
For further information contact Fur Commission USA.
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