Memorandum submitted by the Winemakers'
Federation of Australia
The Winemakers' Federation of Australia (WFA)
is the national peak industry body representing winemaker interests.
The UK is Australia's largest wine export market, accounting for
some 37% of exports. As the market leader in the UK for trade,
Australian wine has a high profile and is obviously not a local
product. As such, Australian wine is a target of "food miles"
and related campaigns, leading to industry interest in contributing
to the UK Parliament Environmental Audit Committee inquiry.
SUMMARY
— The Winemakers' Federation of Australia
supports labelling requirements that contribute to desired consumer
information and safety outcomes.
— Environmental labelling could contribute
to increased consumer awareness, however it must:
— Be based on internationally recognised
performance standards.
— Follow the principle of rationalisation
of labelling requirements rather than the proliferation of various
schemes.
— Take into account the existing ISO
14020 series that address environmental labelling.
— Given that an internationally recognised
environmental standard does not exist (ISO 14001 is considered
to be a process standard rather than an environmental performance
standard), harmonisation of standards and environmental programs
must be the first priority ahead of investigating a labelling
program.
Wine is not subjected to compulsory environmental
labelling. Some wine producers choose to voluntarily label their
product as "organic" against existing international
standards, whilst others use logos of environmental causes that
they support on their labels as a means of marketing. The labelling
of wine is regulated by the EU and compulsory environmental label
requirements would need to be integrated into these regulations.
An environmental label is essentially a claim
of environmental performance of some type. The value of environmental
labels is determined by market forces, and regulatory intervention
needs to be carefully considered.
Discussion about the use of international environmental
labels is premature, given that an environmental label is merely
an indication of a standard or program. Without agreement on an
international "environmental" standard, discussion of
an international environmental label is moot. Lines of inquiry
are better focused along the potential for harmonisation of standards
and environmental assurance programs, with the review of an environmental
label a concluding, and potentially minor, issue to be dealt with
in the process.
The proliferation of environmental labels is
a symptom of the plethora of environmental-type standards and
programs operating in the international market. In other parts
of the market, environmental sustainability is being encouraged
as a pre-competitive issue, much the same as food safety. Some
programs have made a conscious decision not to make use of a unique
environmental label because they would prefer environmental sustainability
to be a basic assumption of the product rather than a point of
difference. An example of this is the South African wine industry's
Integrated Production of Wine scheme.
Any discussion or investigation on environmental
labelling must take into account the existing ISO 14020 series
that address environmental labelling and, in theory, represent
the international consensus on this matter. These standards appear
to address many of the issues raised in the inquiry brief.
The use of "carbon footprint" labels
based on a life cycle assessment is preferable, and a more accurate
representation of a product's impact, than the simplistic notion
of "food miles" and even "air freight" labels.
Whilst the latter serve the "buy local" campaign, they
should not be presented as environmental labels.
The wine industry supports the case for rationalising
the use of environmental labels because, if for no other reason,
there is limited space on wine labels. Wine labels are already
required to include information about Geographic Indication/appellation,
allergens, alcohol content and health warnings. Specialised labelling
requirements create an additional cost to producers because they
shorten the label run sizes, add to inventory and waste, create
unnecessary complexity, limit market flexibility and, as a result,
increase production costs. Rationalisation and moves towards environmental
labels based on internationally-accepted standards would also
save suppliers from compliance and other costs associated with
different retailer environmental assurance programs.
There is little harmonisation of environmental
standards or program requirements, a scenario mirrored in quality
and food safety assurance. Because each standard/program owner
believes theirs to be the best, it warrants its own label to highlight
the point of difference and the result is the proliferation that
we see today. This is exacerbated by retailers also instigating
their own assurance schemes and requiring prospective suppliers
to adhere to that as a condition of supply. Suppliers servicing
a number of retailers are required to seek certification under
the different schemes operated by each retailer, which is a costly
exercise for suppliers, and a cost ultimately borne by the consumer.
Anecdotal evidence provided at a recent primary production conference
indicated that some suppliers of fresh produce were choosing to
abandon the UK market because of the increasing complexity and
duplicated costs in complying with multiple supplier guidelines
as issued by UK retailers.
The proliferation of environmental labels has
also given rise to increased scrutiny, accusations of "greenwashing"
and recognition of potential damage to brand image. Threats of
exposure for "greenwashing" combined with the absence
of any universally recognised environmental assurance standards
can act as a disincentive for companies to make any claims with
respect to their environmental management activities, which can,
in turn, act as a disincentive to undertake environmental management
activities.
Environmental labels should be an indicator
that a product has satisfied the requirements of a particular
standard or program. Labels should not list additional detail
about the requirements that have been satisfied. This gives rise
to the issue of consumer overload of information and label clutter.
Numerous studies already available point to customer confusion
and varying levels of support for existing "environmental"
labels. Further, studies have also shown that consumers "saying"
that they would preferentially purchase a product labelled as
"environmentally friendly" does not always equate to
the consumer "buying" the labelled product.
The issue of labelling without consideration
of the underlying standard, calculation method or program can
give rise to misinformation that is then picked up by media and
given a profile amongst consumers. The wholesale adoption of the
food miles concept as an indicator of a product's environmental
impact, in the absence of any data, is evidence of how an over-simplified
notion can become popularised. When that popularity is retained
in the public domain, even when authorities acknowledge that the
concept does not reflect the environmental impact of a product
across its life cycle, another environmental myth is created.
This only adds to consumer confusion and mistrust of environmental
claims in the long term.
If adopted, environmental labels should be validated
and regulated in the same manner as health claims, for example
"light" and "fat-free". A model must exist
somewhere in this field that could potentially be extrapolated
to environmental claims.
If environmental labels are to become a mainstay
in the marketplace, the issue of label clutter and consumer overload
remains. The observed trend amongst assurance standards is towards
integration. The scope of individual standards and programs are
increasingly addressing quality management, food safety, occupational
health and safety and environmental management. Efforts to rationalise
environmental labels should look more broadly at rationalising
the labels associated with quality management, food safety and
environmental management into a single product guarantee. This
would also address concerns that moves to establish formal environmental
labels will be a precursor to labelling of broader corporate social
responsibility and risk management activities, increasing the
threat of label clutter and related production cost issues. However,
this approach still requires the harmonisation of standards at
a minimum, and the replacement of the various standards with a
universal standard.
October 2007
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