Consumers Union appreciates the opportunity to make comment to the National Organic Standards Board’s recommendations for aquaculture. This comment specifically addresses the proposed organic aquaculture standards for fish feed, net pens and related management issues.

We are disappointed with the final recommendations currently being considered by the National Organic Standards Board (NOSB) and urge the NOSB to reject these recommendations that fall significantly short of consumers expectations in many respects. Two independent, nationally representative, telephone surveys conducted by the Consumers Reports National Research Center reveal several findings about consumer expectations for “organic” fish:

June 2007 poll results include:

• 90% of Americans agree that “organic” fish should be produced without environmental pollution and be free-of or low-in contaminants like mercury and polychlorinated biphenyls (PCBs).

November 2008 poll results include:

• 93% of Americans agree that organic fish should be produced with 100% organic feed like all other animals

• 91% of Americans agree agreed that organic fish farms should be required to recover waste and not pollute the environment. In addition to this expectation, 57% registered additional concern about ocean pollution caused by ”organic” fish farms

(these surveys can be accessed in their entirety in the Food section at Consumer Reports’ www.greenerchoices.org )

For complete comments, click here (PDF format).