Assessment of voluntary claims on fishery and aquaculture products (FAPS).
Date: 2019-05-20
Institutions: Directorate-General for Maritime Affairs and Fisheries
Subjects: advertising malpractice, aquaculture, consumer behaviour, consumer information, fish product, food industry, labelling, marketing, nutritional needs, packaging

ASSESSMENT OF VOLUNTARY 
CLAIMS ON FISHERY AND 
AQUACULTURE PRODUCTS 
(FAPS) 

DG Maritime Affairs and Fisheries 
Framework Contract EAHC/2013/CP/04 Market Studies 

(Written by GfK Belgium and Wageningen UR)  

Maritime Affairs 
and Fisheries 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Maritime Affairs and Fisheries 
Directorate A — Maritime Policy and Blue Economy 
Unit A4 — Economic Analysis, Markets and Impact Assessment 
mare-A4@ec.europa.eu  
European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

ASSESSMENT OF VOLUNTARY 
CLAIMS ON FISHERY AND 
AQUACULTURE PRODUCTS 
(FAPS) 

DG Maritime Affairs and Fisheries  
Framework Contract EAHC/2013/CP/04 Market Studies 

2019 

Directorate-General for Maritime Affairs and Fisheries  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Assessment of voluntary claims on fishery and aquaculture products (FAPS) 

Europe Direct is a service to help you find answers  
to your questions about the European Union. 

Freephone number (*): 

00 800 6 7 8 9 10 11 

(*) 

The information given is free, as are most calls (though some operators, phone 

boxes or hotels may charge you). 

LEGAL NOTICE 

This document has been prepared for the European Commission however it reflects the views only of the 
authors, and the Commission cannot be held responsible for any use which may be made of the information 
contained therein. 

More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2019 

ISBN 978-92-76-04615-8 
doi: 10.2771/732718 
KL-02-19-363-EN-N 

© European Union, 2019 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Assessment of voluntary claims on fishery and aquaculture products (FAPS) 

Table of Contents 

1 

INTRODUCTION .............................................................................. 1 

1.1  Background ..................................................................................... 1 
1.2  Objectives and research questions ...................................................... 2 
1.3  Scope and approach ......................................................................... 2 

1.3.1  What is a voluntary claim? ..................................................... 2 
1.3.2  What are Fishery and Aquaculture Products (FAPs)? .................. 3 
1.3.3  Geographical coverage .......................................................... 3 
1.3.4 
Policy areas .......................................................................... 5 
1.3.5  Methodological Approach ....................................................... 7 

2  AN OVERVIEW AND THE EVOLUTION OF VOLUNTARY CLAIMS ON FAPS 10 

2.1  Presence of all types of voluntary claims on FAPs ................................ 10 
2.2  Presence of schemes (third-party or self-declared) on FAPs .................. 12 
2.3  FAPs increasingly carry voluntary claims ............................................. 15 
2.4  Prevalence of claims according to policy areas ..................................... 16 

3 

THE MARKET OF VOLUNTARY CLAIMS ON FAPS ................................. 22 

3.1  Reasons/benefits and barriers/costs to place claims on FAPs for those in 

the supply chain .............................................................................. 22 
3.2  Market visibility ............................................................................... 24 

Issue-based claims .............................................................. 26 
3.2.1 
3.2.2  Healthy and natural .............................................................. 28 
3.2.3  Source of the FAP: Where does my FAP come from? ................. 30 
3.2.4  Composition claims .............................................................. 32 
3.2.5 
Taste/Product Quality ........................................................... 32 
3.2.6  Organic production methods .................................................. 33 
3.2.7 
Production methods ............................................................. 34 
3.2.8  Smaller policy areas ............................................................. 34 
3.2.9  Unclassified ......................................................................... 34 

4  CONSUMER BEHAVIOUR AND PURCHASING DECISIONS .................... 36 

4.1  Do voluntary claims influence consumer behaviour? ............................. 36 

4.1.1 

4.1.2 
4.1.3 

The  effect  of  type  of  claim  and  policy  area  on  consumer 
behaviour ........................................................................... 36 
The role of claim credibility ................................................... 38 
The role of concurrent claims ................................................ 39 

4.2  Factors consumers consider when buying FAPs .................................... 40 

5  CONSUMER UNDERSTANDING, CONFUSION AND TRUST .................... 44 

5.1  Consumer understanding of different ‘types’ of voluntary claims ............ 44 
5.2  Consumer knowledge about food labels .............................................. 46 
5.3  Consumer  perceptions  of  FAPs  with  voluntary  claims  –  Are  consumers 

confused about the message voluntary claims carry? ........................... 46 

5.3.1  Consumer perception of the message of voluntary claims ......... 47 
5.3.2  Reasons for consumer confusion ............................................ 49 
5.3.2.1  Claim ambiguity ................................................................... 49 
5.3.2.2  Lack of consumer knowledge regarding policy areas ................. 50 

6  REQUIREMENTS  FOR  FAPS  AND  A  CONSUMER  PERSPECTIVE  ON  THE 
EXTENT  TO  WHICH  THEY  ARE  CLEAR,  UNAMBIGUOUS,  VERIFIABLE, 
NOT MISLEADING AND HAVE ADDED VALUE..................................... 52 

6.1  Assessment of voluntary claims on FAPs ............................................. 53 

 
 
 Assessment of voluntary claims on fishery and aquaculture products (FAPS) 

6.1.1 

Protocol for the assessment .................................................. 54 

6.2  Results ........................................................................................... 62 

6.2.1  Analysis by policy area ......................................................... 62 
6.2.1.1  Allergen 62 
6.2.1.2  Food safety ........................................................................ 62 
6.2.1.3  Health and Nutrition ............................................................ 63 
6.2.1.4  Traceability ........................................................................ 64 
6.2.1.5  Free from additives ............................................................. 65 
6.2.1.6  Generic 

Environmental 

responsibility/ 

responsibility/ 

Sustainability ..................................................................... 65 
6.2.1.7  Social responsibility claims ................................................... 66 
6.2.1.8  Animal welfare and animal health claims ................................ 66 
6.2.1.9  Religious dietary laws .......................................................... 67 
6.2.1.10 Organic production methods ................................................. 68 
6.2.1.11 Origin ................................................................................ 68 
6.2.1.12 Production methods ............................................................ 69 
6.2.1.13 Taste/Product Quality .......................................................... 70 
6.2.1.14 More detailed information on fishing gear............................... 71 
6.2.1.15 Composition ....................................................................... 72 
6.2.1.16 Unclassified claims .............................................................. 72 
6.2.2 Assessment of claims across policy areas ................................... 73 
6.2.3 Comparison of policy areas ....................................................... 74 

7  CONCLUSIONS .............................................................................. 75 

7.1  Focus on the consumer .................................................................... 78 
7.2  Focus on the supply chain ................................................................. 78 

ANNEX 1: STAKEHOLDER CONSULTATION AND SURVEYS ........................ 79 

1. 

Stakeholder consultation .................................................................. 79 

1.1 
1.2 
1.3 
1.4 

Stakeholder groups .............................................................. 79 
Semi-structured interviews ................................................... 80 
Questionnaire design ............................................................ 81 
Sample design ..................................................................... 81 

2. Stakeholder Surveys ............................................................................ 84 

2.1 Consumer Protection Authorities .................................................. 84 
Consumer Watchdogs ........................................................... 93 
2.2 
Certification Bodies ............................................................ 102 
2.3 
Fishery and Aquaculture Producers ....................................... 109 
2.4 
Import Associations ............................................................ 117 
2.5 
Processing and Packaging Companies ................................... 124 
2.6 
Retailers ........................................................................... 135 
2.7 
Scheme Owners ................................................................. 144 
2.8 

ANNEX 2: INNOVA DATABASE............................................................. 154 

1 

Analysis of Innova database............................................................ 154 

1.1 

Weighting ......................................................................... 157 

ANNEX 3: BEHAVIOURAL EXPERIMENT AND QUESTIONNAIRE ................. 158 

1 

Behavioural experiment .................................................................. 158 

1.1 
1.2 
1.3 
1.4 
1.5 
1.6 

Design of Experiment 1 ...................................................... 158 
Outcome measures ............................................................ 163 
Post-experiment questionnaire ............................................ 164 
Design of Experiment 2 ...................................................... 165 
Outcome measures ............................................................ 167 
Post-experiment questionnaire ............................................ 167 

 
 
 Assessment of voluntary claims on fishery and aquaculture products (FAPS) 

1.7  Questionnaire ............................................................................... 168 

ANNEX 4: MYSTERY SHOPPING AND WEB SWEEP .................................. 178 

1. 
2. 

Building the inventory .................................................................... 178 
Collecting claims ........................................................................... 178 

2.1.  Web sweep ....................................................................... 178 
Online research of most important brands with FAPs .............. 179 
2.2. 
Mystery shopping of supermarket and specialty stores ........... 179 
2.3. 

3. 
4. 

Processing claims .......................................................................... 179 
Coding claims ............................................................................... 181 

4.1. 
4.2. 
4.3. 
4.4. 
4.5. 
4.6. 

Type of claims ................................................................... 181 
Type of FAP ....................................................................... 183 
Coverage .......................................................................... 184 
Production stage ................................................................ 184 
Information about schemes ................................................. 184 
Policy areas ....................................................................... 185 

 
 
 
 
 
 
 
 
1  Introduction 

1.1  Background 

In the European Union, a large assortment of Fishery and Aquaculture Products (FAPs) are 
available on the market. They all carry consumer information. Food labelling policies have 
a dual purpose1: protecting consumers on the one hand and ensuring fair marketing on 
the  other.  We  can  make  a  distinction  between  mandatory  consumer  information  and 
voluntary consumer information, also known as voluntary claims2. Mandatory information 
is that which is legally required to be specified on FAPs. On top of horizontal mandatory 
information on all food products, there is fish-specific information that must be provided 
to  the  consumer.  This  includes  information  about:  the  commercial  designation  and 
scientific  name  of  the  FAP,  whether  the  product  is  fished  or  farmed,  the  origin  of  the 
product,  the  fishing  gear  used  where  applicable,  if  the  product  is  defrosted,  the  best 
before/use  by  date,  and  any  allergens  that  may  be  in  the  FAP.  These  fish-specific 
requirements  are  in  addition  to  the  information  that  is  mandatory  for  all  food  products, 
such as those related to ingredients, instructions for storage and use, etc. Voluntary claims 
go beyond legal obligations and may refer to different kinds of product characteristics or 
attributes  including  the  product’s  composition  or  content,  product  quality  or  form, 
nutritional  value,  as  well  as  environmental  or  social  aspects  of  the  product’s  production 
process or method. They are presented through logos or labels, but also include statements 
on the packaging. Voluntary claims are a tool for producers and food business operators 
to better market their products and to improve the image of their brand and products in 
front of consumers.  

This information should however be clear, unambiguous, verifiable and not misleading.  

Voluntary claims established themselves in the market of FAPs during the last decade and 
are  part  of  a  wider  market  trend  in  which  consumers  receive  an  increasing  amount  of 
information through various channels. They have proliferated as a means for products to 
differentiate  themselves  from  others.  Yet,  they  risk  being  a  source  of  confusion  for 
consumers.  Research  shows  that  the  amount  of  information  provided,  and  the  way  it  is 
communicated, may make it difficult for consumers to understand what exactly is meant 
by this information in the form of claims3.  

Several  provisions  in  EU  law  require  ensuring  a  high  level  of  consumer  and  health 
protection. EU consumer policy hence aims at enhancing consumers’ welfare in terms of 
price, choice, quality, food security, health and safety, transparency and sustainability of 
products.  

In order to achieve such a high level of required health and consumer protection in the EU, 
information-regulation  has  been  an  important  strategy.  Voluntary  claims  on  FAPs  are 
governed by EU rules concerning consumer information on food in general and on fishery 
and  aquaculture  products  in  particular.  The  applicability  of  this  framework  has  recently 

1   Albert, Janice (2010) Introduction to innovations in food labelling in Innovations in food labelling. The Food 
Limited. 

the  United  Nations  and  Woodhead  Publishing 

and  Agriculture  Organisation  of 
http://www.fao.org/docrep/018/i0576e/i0576e.pdf   

2   Consumer Market Study on the functioning of voluntary food labelling schemes for consumers in the European 

Union EAHC/FWC/2012 86 04 (2013) 

3   Simeone, M., D. Scarpato and G. Rotondo (2015).  "Consumer attitudes to food labelling: Opportunities for 
firms  and  implications  for  policy-makers."  Quality  -  Access  to  Success  16:  312-319;  Client  Earth  (2011). 
Environmental claims on supermarket seafood. Improving product labelling & consumer protection; Parkes, 
G. et al. (2010). Behind the Signs – A Global Review of Fish sustainability Information Schemes, Reviews in 
Fisheries Science, 18(4), 344-356. 

1 

 
                                                 
broadened  as  the  European  Court  of  Justice  has  paved  the  way  to  provide  for  a  wider 
understanding of labelling to include pictorial4 claims5.  

Further, EU Consumer law serves as a framework for voluntary claims. Generally, unfair 
commercial practices targeted at consumers are prohibited, including the provision of false 
or deceiving product information. These consumer rights are amplified for the food sector 
through the general food information to consumers and sectorial consumer information.  

Voluntary information may come in different forms. Voluntary certification schemes have 
been the subject of best practice guidelines6.  

1.2  Objectives and research questions  

EU Regulations clearly establish that food information provided on a voluntary basis shall 
not mislead the consumer, shall not be ambiguous or confusing for the consumer and shall, 
where appropriate, be based on the relevant scientific data in order to be verified. The goal 
is  thus  to  give  consumers  transparent,  clear,  sound,  reliable  and  verifiable  information. 
Although voluntary claims are a tool that can add value to products, they can be a source 
of  confusion.  Consumers  may  be  confused  because  of  a  mismatch  between  what 
consumers believe the claims state and the message they actually carry. Consumers may 
not always be sure what the exact content of the claim is; credibility and clarity are then 
missing.  

Previous research has mostly looked into voluntary claims on food in general, often with 
reference to information channelled by third-party schemes. 

This  study  focuses  on  FAPs  and  looks  at  all  types  of  voluntary  information  across  the 
various themes (referred to as 'policy areas') that are relevant to FAPs.  

Specifically, the following are the main objectives of this study: 

1.  to  provide  an  overview  of  the  existing  voluntary  claims7  on  FAPs  and  their 

functioning 

2.  to explore to whether such claims presented on FAPs are compliant with relevant 

requirements  

3.  to explore consumers’ understanding and behaviour towards voluntary claims 

1.3  Scope and approach 

1.3.1  What is a voluntary claim? 

There  is  a  variety  of  information  that  can  be  found  on  the  packages  of  fishery  and 
aquaculture products. Certain pieces of information that can be included on the labels of 
the products are not required by law, i.e. they offer ‘voluntary’ information. The focus of 
this study is on voluntary claims that consumers can find on FAPs at retail level. Voluntary 
claims  on  FAPs  highlight  some  specific  ‘quality’  or  ‘characteristic’  of  the  product.  These 

4   Including images or graphics 

5    Bundesverband Der Verbraucherzentralen  Und Verbraucherverbände  -  Verbraucherzentrale  Bundesverband 
e.V. v Teekanne GmbH & Co. KG (C-195/14) ECLI:EU:C:2015:361, see also Schebesta and Purnhagen, 'The 
Behaviour of the Average Consumer: A Little Less Normativity and a Little More Reality in the Court’s Case 
Law? Reflections on Teekanne', European Law Review (2016) 595 

6   Commission Communication — EU best practice guidelines for voluntary certification schemes for agricultural 

products and foodstuffs (2010/C 341/04) 

7   Including all type of voluntary claims 

2 

 
                                                 
claims  can  be  in  the  format  of  logos/labels/images  or  as  statements  on  the  packaging. 
These  claims  can  relate  to  many  different  topics,  such  as  health  and  nutrition, 
sustainability, the welfare of the fish, how it was caught, how it tastes, etc.  

There is a difference between voluntary claims that are supported by schemes (i.e. that 
indicate they are in compliance with a formal scheme) and those that are ‘simple’ textual 
or pictorial claims that are not supported by a scheme8.  

1.3.2  What are Fishery and Aquaculture Products (FAPs)? 

There  are  two  broad  categories  of  fishery  and  aquaculture  products  (FAPs)  that  can  be 
considered for the purposes of this study:  

Fish- live, fresh, chilled, frozen fish; fish fillets and other fish meat; dried, salted 
or in brine, smoked, prepared or preserved fish (e.g. canned fish, breaded fillets, 
fillets with sauce, herbs) 

Crustaceans,  molluscs  and  other  aquatic  invertebrates-  live,  fresh,  chilled, 
frozen,  dried,  salted  or  in  brine,  smoked,  cooked,  prepared  or  preserved  (e.g. 
shrimps with garlic, herbs, sauces, mussels in cans)  

1.3.3  Geographical coverage 

The  inventory  of  voluntary  claims  covers  FAPs  across  all  28  Member  States.  The 
behavioural  experiments  and  stakeholder  survey  were  carried  out  in  eight  EU  Member 
States (except where stakeholders were pan-European). The eight countries are Czechia, 
Germany, France, Italy, Poland, Spain, Sweden and the United Kingdom.  This this study 
distinguishes three types of voluntary claims that appear on FAPs. 

Third-party certified claims 

Third-party certified claims are those that represent a third-party scheme.  

As  stated  in  the  Commission  guidelines  2010,  the  main  defining  feature  of  certification 
schemes  is  that  they  rely  on  a  third-party  attestation  procedure.    Certification  schemes 
provide  assurance  through  a  certification  mechanism  that  certain  characteristics  or 
attributes of the product or its production method or system, laid down in specifications, 
have been observed and confirmed through a third-party attestation. 

Attestation  is  defined  in  the  guidelines  as  the  issue  of  a  statement  based  on  a  decision 
following review that fulfilment of specified requirements has been demonstrated.   

For  the  purposes  of  this  definition,  a  third-party  is  a  certification  body  that  issues  the 
certificate  or  statement  on  the  fulfilment  of  the  scheme’s  specified  requirements.  The 
certification body does  not, however, need to  be an independent body that conforms to 
harmonised accreditation requirements, as such requirements do not exist in some policy 
areas, such as the domain of taste/product quality (of which the third-party claim “Mark of 
Quality - Slovak Gold Certificate N14/2009” is an example). Although award schemes are 
technically third-party schemes because they are issued by an independent arbiter, they 
generally  have  more  subjective  criteria  than  certification  schemes,  and  as  such,  claims 
related to awards are qualitatively different from claims related to certification bodies.  A 
third  party  cannot  be  the  producer  or  retailer.  However,  the  scheme  operator  can  be 
accredited to certify a scheme. Therefore, the scheme operator can certify that members 
of the scheme have fulfilled the specific requirements of the scheme. 

Third  party  certification  schemes  can  involve  an  external  body  that:  a)  certifies  certain 
aspects  of  the  FAP  (e.g.,  that  the  product  is  organic,  or  that  it  has  a  certain  origin),  b) 
bestows an award on the product (e.g., “ best Estonian fish product award”), or approves 

8   It should be noted that due to the subtle nature of some picture claims, for example where the packaging 
utilises imagery as part of the design but could be also considered to be a voluntary claim, some versions of 
picture claims were not recorded, although the most obvious ones were included. 

3 

 
                                                 
the FAP for a specific purpose (e.g., heart symbol products from Sydänmerkki). Third-party 
claims are generally indicated by a logo of the third-party scheme or body.  

Self-declared claims 

Self-declared claims can be of two types: 

  Those that are supported by adherence to a self-declared scheme: Self-declaration 
schemes are those schemes that do not have third party attestation.  Adherence to 
these  schemes  is  done  by  either  a)  the  scheme  operator  (in  the  case  where  the 
operator is not a certification body), or b) declaration by the producer or retailer. 
Therefore, these claims are supported by a self-declared scheme that has not been 
certified by a third-party; 

  Self-declared  claims  that  are  in  reference  to  a  third-party  certification  scheme: 
voluntary claims that are placed on the packaging which accompany claims of third-
party  certification  schemes.  These  claims,  for  example  ‘sustainable  fish’  can  be 
placed as a self-declared statement on the packaging to accompany the logo of a 
third-party scheme related to sustainable practices. This is a marketing tool used 
to highlight the attributes of the FAP towards consumers. It states the message of 
what the third-party scheme means (for example, for consumers who may not be 
familiar with the logo of a given scheme). Therefore, they are self-declared claims 
that are supported by third-party certified schemes. 

Other voluntary claims  

Other voluntary claims include voluntary claims that are defined as logos, statements and 
images  on  the  product  packaging,  which  constitute  a  claim  as  to  the  attributes  of  the 
product  or  its  production  process  that  are  not  part  of  a  third-party  certified  or  self-
declaration scheme. Claims that have no specific criteria attached to them are considered 
as ‘other’, as well as claims that are verifiable, but without specific criteria, such as skinless 
and boneless, no artificial colours, etc. 

The following figure (Figure 1) illustrates the differences between the types of voluntary 
claims that may appear on the packaging of FAPs within the scope of this study. 

4 

 
 
 
Figure 1 
example 

Third-party, self-declared and other voluntary claims on FAPs  – an 

Third party claim: 

Marine  Stewardship  Council 
MSC  

Self-declared claim (in reference to a 
third party scheme):  

Responsibly sourced 

Self-declared  claim  (supported  by  a 
self-declared scheme): 

Tesco:  Freshness  and  Quality

Other claim: ‘boneless’ 

1.3.4 

Policy areas 

The voluntary claims found on all FAPs carry specific messages. The main message of a 
voluntary claim belongs to what can be considered to be the main theme, which is referred 
to as 'policy area' in this study. As such, voluntary claims identified during this study (in 
building an inventory of voluntary claims) were all grouped into 15 different policy areas  
in  addition  to  ‘unclassified’  claims  or  those  that  were  ‘ambiguous’  as  they  could  not  be 
assigned to a specific policy area. In some cases voluntary claims were identified as not 
having a single ‘main’ message – i.e., the claim referred to several policy areas. In such 
cases the main policy area was coded as ‘Multiple’.  There were also claims that, despite 
referring to several policy areas, did also have a main policy area. In such cases the main 
policy  and  the  secondary  policy  area  The  main  policy  areas  and  a  brief  description  with 
examples of such claims are presented in the table below: 

5 

 
 
 
 
 
 
 
 
 
Policy area 

Examples of claims 

Allergen (free)  

Examples of claims that fall under this category are “wheat free”, 
“gluten free”. 

Food safety 

Health and nutrition  

Traceability  

Free from additives 

Only claims that refer to the fish/mollusc/crustacean component of 
the product  considered  here.  That is,  the claim  does not  refer  to 
the breading, coating, sauce, etc. of the FAP. 

Food safety is defined here as the conditions of handling, storing 
and  preparing  food  to  prevent  infection  with  foodborne  illnesses. 
An example of claims that fall under this category is: “Controlled 
for quality”. 

This category includes claims that claim benefits related to health 
or  claim  information  on  the  nutritional  content  of  the  product. 
Examples of claims that fall under this policy area are: “Omega 3”; 
“Low in fat”; “Good for you”. 

Traceability  claims  are  considered  as  any  text  referencing  the 
ability  to  trace  the  product’s  origin  or  whereabouts  during  the 
distribution  process.  Examples  of  such  claims  are  “traceable”, 
“Trace your fish”.  

Claims  indicating  that  preservatives,  colourings,  flavouring  etc. 
have not been added to the product. Examples of claims under this 
category are “free from artificial colours and flavours”, “no added 
preservatives”. 

Generic 
responsibility/Environmental 
responsibility/sustainability 

The claims selected for this policy area refer to sustainability of/and 
responsibility of the marine environment or nature in general (for 
example MSC, ASC, Friends of the Sea). They can also refer to non-
specific ‘generic’ responsibility.  

Social responsibility  

Claims  that  purpose  to  have  a  positive  impact  on  social  aspects 
(such  as  the  local  economy).  Examples  of  claims  under  this 
category are: “Fair Trade Certified”, “Good for employment”. 

Animal welfare and animal 
health  

Claims that relate to animal welfare and animal health. Examples 
of  claims  under  this  category  are  “Dolphin  safe”  and  “Dolphin 
friendly.  

Organic production method 

Claims that the FAP has been produced organically.  Claims under 
this  category  are,  for  example  “100%  organic”  or  “certified 
organic”. 

Religious dietary laws 

Claims that the product adheres to religious dietary laws. Examples 
of claims under this category are “Kosher”. 

Origin  

Claims that refer to a geographical area. Examples of claims under 
this  category  are  “Fish  from  [country]”;  “Product  from/Produced 
in/Made in [country]/ Maps”. 

More detailed information 
on fishing gear 

Claims  that  provide  information  about  the  fishing  gear  that  has 
been  used:  Examples  of  claims  under  this  category  are  “Pole  & 
Line” and “Individually caught”. 

Production process 

These  types  of  claims  give  information  about  how  the  product  is 
processed  or  prepared.  Examples  of  claims  under  this  category 
include  claims  related  to  the  use  of  traditional  preservation 
methods (drying; salting; etc.); “Processed by hand”; “Artisanal”; 
“Family/house tradition or recipe”; “Recipe from (country/region)”; 
“Original (recipe)”; Different forms of smoking (e.g., hot smoked).  

Taste/Product quality 

Claims that refer to the quality of the product. Examples of claims 
under this category are: “Great taste”, “Premium quality”.  

Composition  

Composition  claims  refer  to  the  composition  of  the  product, 
Examples of claims under this category are: 
and 
boneless”, “100% made with (fish)”. 

“Skinless 

6 

 
Unclassified/ambiguous 

Unclassified claims are those indicated on products but that cannot 
be categorised in the policy areas mentioned above. Examples of 
claims  under  this  category  are:  “No  drain”,  “Wild”.  Ambiguous 
claims  are  those  for  which  it  is  unclear  what  the  claim  refers  to 
(e.g., “From the fishmonger”) 

Multiple 

When  the  claim  did  not  have  one  ‘main’  message,  but  several 
messages, it was coded as ‘Multiple’.  

The criteria used to assign a claim to a policy area were: 

  The claim was considered at face value and clearly refers to a topic of a policy area 
and was coded as such. For example ‘Good for your health’  refers to ‘Health and 
nutrition’, ‘Sustainably fished’ to ‘Generic responsibility’, etc. 

  The  claim  does  not  refer  to  a  policy  area  directly,  but  to  a  topic  that  is  directly 
related to the policy area. For example although the claim ‘High in Omega 3’ does 
not mention health or nutrition directly, it refers to the presence of nutrients that 
provide a health benefit and so it belongs to the policy area 'Health and nutrition'. 
Similarly, ‘Gluten free’ does not directly refer to ‘allergens’, but because it refers to 
the  absence  of  an  ingredient  that  is  known  to  be  an  allergen,  it  belongs  to  the 
Allergen (free) policy area.  

  When a claim did not belong to any of the main policy areas identified it was coded 
as ‘Unclassified'. When it was unclear what the claim is  referring to (for example 
‘Vital; natural; original; APPROVED (seal)’) the policy area of the claim was coded 
as Ambiguous, otherwise the policy area was coded as ‘Unclassified’.  

  When a claim was not backed up by more detailed information on the package or 
online, the claim was coded at ‘face value’ (for example a generic ‘Pole & Line’ claim 
= information on fishing gear) or as ambiguous.  

  When a claim was ambiguous by its look or its name BUT was backed up by more 
detailed information on the package  or  online, the claim was coded following the 
available information which identified the main policy area of the claim. 

1.3.5  Methodological Approach 

Data  collection  in  order  to  answer  the  research  questions  was  done  through  multiple 
means: 

  Desk  research  and  literature  review  in  order  to  understand  the  functioning  of 
voluntary  food  labelling  schemes  in  addition  to  literature  on  food  and  consumer 
behaviour  to  design  the  consumer  behavioural  experiment  and  stakeholder 
consultation.  This  included:  a)  reviewing  a  previous  study  on  voluntary  claims, 
namely  the  Consumer  Market  Study  on  the  functioning  of  voluntary  food  labelling 
schemes for consumers in the EU (2013), b) examining the literature on academic 
literature  on  food  and  consumer  behaviour,  and  c)  using  online  consumer  tools  to 
better 
and 
keurmerken.milieucentraal.nl).  Desk  research  also  allowed  claims  to  be  examined 
more closely, so that it could be determined whether the claim was supported by a 
scheme or not (so that the type of claim could be coded), whether the claim was part 
of  an  umbrella  scheme,  and  who  the  owner  of  the  claim  was.  The  legislative 
framework  (i.e.  a  review  of  legal,  non-binding  and  best  practices  in  EU 
law/international policy documents) that was applied in the assessment of claims and 
the legal assessment was also based on desk research. 

www.label-online.de 

understand 

schemes 

(e.g., 

  Consultation with stakeholders (annex 1) to collect stakeholders’ opinions about 
voluntary claims on FAPs.  Towards this aim, 30-minute semi-structured interviews 
with seven different stakeholders in the chain from Belgium and the Netherlands were 
conducted, in order to strengthen the knowledge base and get an idea of stakeholder 

7 

 
 
understanding  (see  Annex  1).  The  stakeholders  represented:  1)  an  NGO,  2)  a 
producer and producer organisation, 3) a processor/packager, 4) an importer, 5) a 
board  member  of  a  scheme,  6)  a  retailer,  and  7)  academics  and  subject  matter 
experts. The questions  asked  covered topics such as:  understanding the concepts, 
the procedures associated with the use and control of schemes, the overall trends, 
the  role  of  consumers,  and  the  advantages  and  disadvantages  for  different 
stakeholders.  Following  this,  a  stakeholder  survey  was  carried  out,  with  46 
stakeholders from 8 EU countries (Czechia, France, Germany, Italy, Poland, Spain, 
Sweden,  and  the  UK)  participating.  They  represented:  1)  retailers  and  retailer 
organisations,  2)  scheme  owners  (across  the  EU28  countries)  ,  3)  processing  and 
packaging  companies  and  associations,  4)  certification  bodies,  5)  consumer 
watchdogs, 6) consumer protection authorities, 7) fishery and aquaculture producers 
and associations, and 8) import companies and associations. 

A  separate  questionnaire  was  designed  for  each  stakeholder  group,  consisting  of 
mainly  closed  questions  and  some  open  questions  (see  Annex  1).  The  questions 
pertained to:  

1)  The  presence  of  voluntary  claims  according  to  the  types  of  FAPs  (frozen, 
fresh/chilled, dried, salted, in brine, smoked, or otherwise processed) and the 
policy 
generic/environmental 
responsibility/sustainability, etc.)  

taste/product 

quality, 

(origin, 

area 

2)  Reasons or benefits of placing voluntary claims on FAPs 

3)  Barriers to including voluntary claims on FAPs 

4)  Perceptions of the transparency of voluntary claims and whether they complied 

with existing regulations 

  Consultation  of  six  experts  in  the  domains  of  market,  certification,  voluntary 
schemes  and  claims,  and  consumer  behaviour.  They  provided  feedback  on  the 
methodological  approach,  findings  and  conclusions  of  the:  1)  desk  research  and 
literature review, 2) stakeholder surveys, and 3) behavioural experiment and survey. 

 

 

Two behavioural experiments (annex 3) with an accompanying consumer survey 
were  conducted  online  in  eight  EU  countries  (Czechia,  France,  Germany,  Italy, 
Poland, Spain, Sweden, and the UK). The aim of these studies was to collect views, 
behaviours  and  perceptions  regarding  voluntary  claims  on  FAPs.  Experiment  1 
examined the extent to which different types of claims (i.e., 3rd party, self-declared, 
other)  in  different  policy  areas  (i.e.,  sustainability,  quality,  origin)  influence 
consumers’ a) purchase intentions, b) willingness to pay for an FAP, and c) product 
perceptions, compared to a FAP with no claim. Experiment 2 investigated the extent 
to which 3rd party and other claims on FAP influenced the same outcomes (as those 
in  Experiment  1),  when  a  single  claim  compared  to  a  claim  accompanied  by  three 
concurrent  claims  was  presented.  In  addition,  Experiment  2  also  investigated 
whether the type and number of claims affected the ease of understanding the claim 
information.  

The survey that was administered after the two experiments identified which factors 
respondents  take  into  account  when  buying  fish,  their  knowledge  of  food  labelling 
requirements,  familiarity  with  claims  used  the  experiments,  and  the  respondents’ 
financial situation (in order to  check whether the results were dependent on these 
factors). 

A web sweep and mystery shopping exercise (annex 4) in shops within the 28 
EU member states to identify and analyse voluntary claims on FAPs’. These claims 
were  examined  for  regularities  and  patterns  that  could  be  coded  into  relevant 
categories.  The emergent categories were: 1) claim type in terms of whether and 
how they were supported by a 3rd party scheme (3rd party, self-declared, other), 2) 
policy area the claim pertained to, 3) the country/countries where the FAP retailed, 
4) the type of FAP (fish/crustacean/mollusc), and 5) further information about any 
applicable scheme. The results of this exercise were used to build an inventory of  713 

8 

 
claims  and  associated  images  of  the  claims  and  examples  of  at  least  one  product 
carrying the claim. Similar claims were groups together. 

 

An assessment of the inventory of claims (built from the web sweep and mystery 
shopping exercises). Each claim was analysed according to whether it:  

- 

- 

- 

- 

is  clear  (from  a  consumer’s  perspective):  the  claim  can  be  understood  at 
first glance  

is unambiguous (from a consumer’s perspective): the claim does not have 
multiple meanings  

can be verified: the claim can be checked as to whether it is accurate or not  

is not misleading in the sense of being untruthful; 

-  adds  value  (from  a  legal  perspective):  the  claim  allows  the  consumer  to 
distinguish the product from other similar products – i.e., it provides useful 
information. 

 

An extract of the Innova database (Annex 2), one of the largest databases of food 
products, including FAPs to identify the presence and evolution of voluntary claims 
on FAPs. This database covers the period January 2009 – July 2016, in which 13,746 
FAPs in the 25 EU Member States9 covered by the database were encoded. The claims 
found on all the FAPs were grouped into 15 different policy domains,. The analysis of 
the Innova database was utilised in order to capture the presence of voluntary claims 
on the market and in particular to observe the trends in voluntary  claims on FAPs 
since 2009.  

 

Appendices to this report provide the detailed information regarding the methodology 
implemented in this study.  

9   Cyprus, Luxembourg and Malta were not covered by the Innova database 

9 

 
 
 
                                                 
2  An  overview  and  the  evolution  of  voluntary  claims  on 

FAPs 

2.1 

Presence of all types of voluntary claims on FAPs 

The first objective of the study was to identify the current situation of voluntary claims on 
FAPs.  One  source  that  was  utilised  to  answer  this  research  question  was  the  Innova 
database, which is one of the largest databases of food products. This database was utilised 
in  order  to  start  painting  a  picture  of  the  degree  to  which  FAPs  carry  voluntary  claims. 
Innova does not contain all products that can be found on the market, so it is not possible 
to definitively say how many products carry a voluntary claim. Nonetheless, it is one of the 
most extensive sources of product information and therefore was utilised to paint a picture 
of the market and trends since 2009.  

During the period between January 2009 and July 2016 13,746 fish and seafood products 
were  entered  into  the  Innova  database  in  the  25  EU  Member  States  covered  by  the 
database. The following graph highlights the percentage of all FAPs in the Innova database 
that carry (all types of) voluntary claims on them. On average, just under 60% of products 
carry  voluntary  claims  during  this  period.  It  highlights  that  the  prevalence  of  claims  on 
products is highest in Sweden, Germany, the UK and Ireland where over 70% of products 
in the database carry a voluntary claim. This is in contrast to countries such as Slovakia, 
Czechia, Estonia and Latvia where less than 40% of products carry claims. Therefore, the 
visibility of voluntary claims towards consumers varies considerable within the EU.  

Figure 2 Percentage of FAPs carrying Voluntary Claims, per country, 2009-2016 
(2016 until July) (n=13,746), weighted 

Source: Calculations Wageningen Economic Research based on the Innova Database 

Whilst in some countries the majority of FAPs carry a voluntary claim and in other countries 
this is not the case, the analysis also considers what types of FAPs carry voluntary claims. 
Voluntary claims are carried on all different types of FAPs (frozen, salted, in brine, 
smoked, other preservation such as canned) according to stakeholders consulted for this 

10 

 
 
study10. The sole exception is fresh fish that is sold unpackaged, as there is a self-evident 
barrier to provide this type of fish with a claim when being sold to customers. This means 
that  the  presence  of  claims  on  FAPs  varies  according  to  markets  where  consumers  buy 
more fresh unpackaged FAPs or more packaged FAPs (which can be fresh, frozen, canned, 
etc.). For example, data from a recent Eurobarometer11 on EU consumer habits regarding 
fishery and aquaculture products shows that 62% of Europeans buy pre-packed products 
often or from time to time in comparison to 68% who buy loose products (often or from 
time to time). Significant differences exist across Member States. More than three-quarters 
of  consumers  in  Sweden  (84%),  the  Netherlands  (79%),  Austria  (77%)  and  Slovakia 
(76%) buy pre-packed products often or from time to time. Instead, in Hungary, Slovakia, 
and Czechia the majority rarely or never buy pre-packed FAPs.  

Figure 3 Presence of voluntary claims per type of FAP per stakeholder type (supply chain 
stakeholders  and  certification  bodies)  below  illustrates  the  fact  that  voluntary  claims 
appear on all types of FAPs according to the stakeholders consulted. Retailers are likely to 
sell all types of FAPs. According to their responses, all types of FAPs carry voluntary claims. 
Scheme  owners  and  certification  bodies  also  agree  that  voluntary  claims  appear  on  all 
types  of  FAPs.  Half  of  processing  and  packaging  companies  only  process  frozen  fish  – 
therefore their responses (and the appearance that voluntary claims are predominantly on 
frozen fish) have to be interpreted in relation to their processing activities.  

Figure  3  Presence  of  voluntary  claims  per  type  of  FAP  per  stakeholder  type 
(supply chain stakeholders and certification bodies) 

The inventory of claims collected across the EU28 for the purpose of this study finds both 
fish  and  seafood  products  carry  voluntary  claims,  irrespective  of  the  product  type 
(fresh/chilled,  frozen,  dried,  smoke,  canned/prepared  or  in  brine).  The  inventory  of 

10   Type of fish was asked to the different stakeholders as follows: On which type of fish products is your scheme 
featured? (scheme owners) Which type of Fishery and  Aquaculture Products (hereafter fish products) does 
your company process or sell? If you sell fish products carrying any type of scheme, on which type of fish 
products  are  these  schemes  used  (fishery  and  aquaculture  producers)  Which  type  of  fish  products  with 
voluntary claims do the companies your association represents import the most? (importers) What type of 
fishery and aquaculture products (hereafter called fish products) does your company sell? (retailers) On which 
type of fish products does your company place other voluntary claims? (processing and packaging companies) 
What types of fish products does your certification body issue certificates for? (certification bodies). Answer 
categories were always: 1. Live, fresh/chilled fish products, 2. Frozen fish products, 3. Dried, salted, in brine, 
smoked fish products, 4. Otherwise preserved (i.e. canned or jarred) fish products, 5. I don’t know 

11   Special  Eurobarometer  450-  June  2016  “EU  consumer  habits  regarding  fishery  and  aquaculture  products” 

http://ec.europa.eu/COMMFrontOffice/publicopinion/index.cfm/Survey/getSurveyDetail/instruments/SPECIA
L/surveyKy/2106 

11 

 
 
                                                 
voluntary claims was built on the basis of identifying claims rather than products (products 
without claims are not considered). Therefore, it is not possible to say whether voluntary 
claims are more prevalent on fish or  seafood  or  on certain types  of FAPs (as this would 
require the analysis to consider the percentage of products that carry a claim  within the 
sum  of  all  products  of  that  type  that  carry  and  do  not  carry  claims).  Nevertheless,  as 
evidenced in the inventory, all types of FAPs (in terms of fish and  seafood and different 
preservation  methods  such  as  frozen,  smoked,  canned)  carry  voluntary  claims. 
Furthermore, some specific claims are found on multiple types of FAPs (i.e. the same claim 
is found on different types of FAPs). As discussed later in this chapter, this is due to the 
fact that certain claims appear to be recurring – they appear on multiple types of FAPs and 
multiple  brands  –  and  therefore  could  be  considered  as  the  most  ‘visible’  towards 
consumers.  

Whilst  the  indications  from  the  stakeholder  survey  and  the  building  of  an  inventory  of 
voluntary  claims  suggests  that  all  types  of  FAPs  carry  voluntary  claims,  the  Innova 
database  can  also  help  to  shed  light  on  whether  certain  types  of  FAPs  are  more  or  less 
likely  to  carry  voluntary  claims.  As  mentioned  above,  the  analysis  has  to  consider  the 
percentage  of  products  within  a  given  type  to  determine  the  prevalence  of  claims.  For 
example,  if  the  analysis  only  considers  the  prevalence  of  all  voluntary  claims  and  then 
presents  what  type  of  FAP  it  appears  on  it,  the  results  will  be  skewed  towards  those 
products that are just more prevalent in the market (i.e. it may be that most claims appear 
on canned goods, but this may be due to the presence of more canned goods on the market 
in general).  

Whilst the Innova database does not identify the specific ‘type’ of FAP, it does indicate the 
shelving of the product (i.e. where in the store the product is found). As such it identifies 
frozen, fridge and ambient. Whilst not an exact match, these are roughly equated to frozen 
FAPs, chilled FAPS (fridge) and canned/jarred/preserved (ambient) FAPs. In Figure 4, the 
analysis highlights that within each of these categories the prevalence of voluntary claims 
is  almost  exactly  equal.  Therefore,  the  evidence  from  all  sources  (i.e.  stakeholder 
interviews, the inventory of voluntary claims and the Innova database of FAPs) indicates 
that voluntary claims are found on all types of FAPs.  

Figure 4 Percentage of products carrying claims, per type of product, 2009-2016 
(2016 until July) weighted 

2.2 

Presence of schemes (third-party or self-declared) on FAPs 

The above sub-section indicates the presence of all types of voluntary claims on FAPs. This 
section now considers the extent to which voluntary claims that are supported by schemes 
(third-party or self-declared) are present on the market. 

12 

 
 
 
Two prior inventories of voluntary schemes that are available for a range of food products, 
including FAPs, were compiled. In 2010, the Commission identified 441 labelling schemes 
for agricultural products and foodstuffs marketed in the EU12. In 2013, an inventory of 901 
schemes were identified as a result of the analysis of voluntary food labelling13.  

An  important  aspect  of  the  methodology  of  these  inventories  is  that  they  are  primarily 
based  on  desk  research  on  what  food  labelling  schemes  are  available  in  each  Member 
State.  A  web  shopping  exercise  was  also  utilised  in  the  2013  study  in  the  context  of 
checking  that  no  schemes  were  missing.  However,  the  web  shopping  did  not  assess  to 
what degree any of the schemes identified during the web sweep were actually available 
on the market.  

Whilst these two inventories did not look at FAPs in particular, FAPs were included in the 
scope of the data collected. In 2010, 101 schemes that were applicable to fish products 
were identified. The inventory identifies the number of schemes in the product group of 
fish  in  the  fourteen  policy  areas  covered  by  the  study.  The  most  commonly  occurring 
schemes were within the policy areas of traceability, organic farming and origin. Schemes 
in that study could cover multiple policy areas (e.g. a scheme could be coded as involving 
both origin and organic farming).  

The  database  from  the  Consumer  Market  Study  of  2013  contains  information  on  901 
schemes  in  all  EU27  countries  (Croatia  only  became  an  EU  country  in  2013  and  was 
therefore not within the scope of this study) and includes more than 10 different types of 
products, including fish products.  

Of these 901 schemes, 265 related to FAPs (either in combination with other products, or 
FAPs exclusively) in comparison to the 101 schemes found in 2010. 214 of those identified 
in  the  category  of  fish  products  were  part  of  certification  schemes  and  49  were  self-
declaration (with two schemes not classified). Again, schemes could cover more than one 
policy  area  when  they  included  topics/criteria  relating  to  different  aspects  (such  as  a 
scheme that covers both quality and health). The results from that study demonstrate that 
the number of schemes identified primarily related to origin claims (over half), with around 
a quarter of schemes in the areas of organic farming, traceability and traditional production 
methods.  

The current study combines both a web shopping and mystery shopping exercise to identify 
which schemes and claims actually appear on FAPs found in retailers in the EU28. As such, 
this  study  utilises  a  bottom-up  approach  to  identify  which  schemes  appear  in  the  EU 
market.  

The  inventory  of  voluntary  claims  compiled  for  this  study  identifies  third-party,  self-
declared and ‘other’ voluntary claims on FAPs on the market during the period of the web 
shopping and mystery shopping exercises. In comparison to the 2013 study, a total of 84 
claims supported by third-party schemes were identified. A further 134 claims deemed to 
be self-declared were identified - though many of these are claims that are accompanied 
by third-party certification scheme logos. In total, 218 claims supported by third-party or 
self-declared schemes14 were identified. A further 486 ‘other’ claims (where no evidence of 
being supported by a scheme or identifiable criteria was found) were identified. Two ‘combi’ 
claims  were  also  identified,  both  consisting  of  a  combined  self-declared  organic  claim 
combined with a sustainability claim – e.g., “Sustainable organic-aquaculture”.  

This study aimed to be more precise about the policy area of a claim. Therefore, the ‘main’ 
specific  policy  area  of  these  claims  is  identified  –  the  majority  of  claims  supported  by 
schemes  are  not  related  to  multiple  policy  areas  as  was  the  case  for  the  previous 
‘environmental 
inventories.  For  example,  MSC 

is  considered  to  be  related  to 

12   Inventory of certification schemes for agricultural products and foodstuffs marketed in the EU Member States 

https://ec.europa.eu/agriculture/sites/agriculture/files/quality/certification/inventory/inventory-data-
aggregations_en.pdf 

13   http://ec.europa.eu/consumers/consumer_evidence/market_studies/food_labelling/index_en.htm     

14   Including those claims in reference to third party schemes 

13 

 
                                                 
responsibility/sustainability’ in this study, whereas in the previous study it was related to 
both environmental and traceability policy areas. 

Therefore, whilst the previous studies identify origin, organic farming and traceability to 
be the most prevalent scheme types in the EU, this is reflective of the methodology used. 
It highlights that schemes in these areas are most prevalent in terms of availability.  The 
inventory that was built for this assignment is based on what schemes were found on FAPs 
in the market. As a result it identifies schemes in the policy areas of origin, taste/quality, 
generic/environmental sustainability (primarily due to the number of ‘self-declared’ claims 
that refer to MSC/ASC and similar third party schemes), and health/nutrition as being the 
most common (in addition to claims that carry ‘multiple’ policy area messages).  

Number of claims per policy area – current inventory of voluntary claims 

Policy Areas 
Allergen (free) 
Animal welfare & health 
Composition 
Food Safety 
Free from additives 
Generic responsibility/Environmental 
responsibility/Sustainability  
Health and nutrition 
More detailed information on fishing gear 
Organic production methods 
Origin 
Production methods 
Religious dietary laws 
Social responsibility 
Taste/product quality 
Traceability 
Unclassified 
Multiple 
Total 

Third-party 
1 
2 

5 
1 

7 
3 

7 
9 

1 
1 
40 

14 
84 

Self-
declared 

1 

3 

51 
2 
6 
13 
3 
1 

4 
10 

40 
134 

Other 
3 
9 
29 
2 
31 

14 
63 
6 

121 
37 
1 

76 
13 
30 
51 
486 

Combi 

2 
2 

Total 
4 
12 
29 
10  
32 

72 
68 
12 
20 
133 
38 
2 
5 
126  
13 
30 
107 
713 

A distinction was made between whether the claim was associated with a public body. If a 
government/public  body  is  involved  in  a  scheme  (such  as  managing,  or  funding  the 
scheme), it is considered a public scheme – otherwise it is a private scheme. Of the claims 
supported by schemes (third-party or self-declared) that were identified during the creation 
of  the  current  inventory,  the  majority  are  private  schemes  (199)  with  a  minority  being 
public schemes (26) and 1 scheme as a private/public partnership. Many of the schemes 
identified are umbrella schemes (79), meaning that a) they also appears on other products 
in addition to FAPs (for example on dairy products, oil, etc.) or b) the claim has various 
appearances depending on the different regions/countries where it is found.  

The analysis also considered whether voluntary claims related to schemes (third-party or 
self-declared) were more or less likely to appear on fish compared to crustaceans/molluscs 
and  found  that  31%  of  claims  found  on  fish  were  third-party/Self-declared  and  38%  of 
claims on crustaceans/molluscs were third-party/self-declared. This suggests that schemes 
do not appear to be more or less prevalent on fish as opposed to seafood. The presence of 
voluntary claims supported by schemes is also almost equal across all types of FAPs (fresh, 
frozen,  smoked,  canned,  etc.).  The  exception  are  dried  FAPs,  on  which  very  few  claims 
were found (only seven voluntary claims in total were found on dried FAPs – one of which 
is a third-party scheme).  

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Types of FAPs 
Fresh/Chilled 
Frozen 
Smoked 
Canned 
Dried 

Percentage of voluntary claims on 
that type of FAP that are third-
party/self-declared schemes.  

33% 
36% 
36% 
28% 
14% 

As mentioned, the results between the various studies are not directly comparable given 
the differing methodologies, differences in defining policy areas and the fact that this study 
identifies  the  main  policy  area  of  a  claim.  However,  what  this  exercise  does  highlight is 
that  the  inventory  built  for  the  purpose  of  this  study  identifies  far  fewer  third-party 
accredited schemes that appear on FAPs in the market.  

This is an important finding – and whilst this study cannot definitively answer why there 
are more schemes available than found on the market, this may be due to: 

-  Costs associated with being compliant with a scheme (for all of those in the supply 

chain – see the section on benefits/costs to placing claims on FAPs); 

-  Existence of local schemes that are not widely found on the market (for example in 
the 2013 inventory of schemes there are 19 schemes from Czechia that refer to a 
region in Czechia, which is not likely to be carried widely and therefore may not be 
picked up by the data collection exercise carried out during this study); 

-  The market demands something other than these schemes (for example, only some 
schemes may be seen as beneficial by those in the supply chain, and operators may 
prefer to place claims not supported by schemes on FAPs). 

2.3 

FAPs increasingly carry voluntary claims 

Most  stakeholders  (28  out  of  49)  within  the  supply  chain  agree  that  there  has  been  an 
increase in the number of FAPs carrying voluntary claims within recent years15. In the view 
of certification bodies, there appears to be a trend towards an increase in both the number 
of self-declared and ‘other’ voluntary claims, but the rise in self-declared claims is not more 
pronounced than other types of claims (i.e. third-party or other claims)16.  

It is also possible to look at the evolution of claims during the period between 2009 and 
2016 year on year by utilising the Innova database to test the hypothesis that there is an 
increase in the number of FAPs carrying voluntary claims. The analysis highlights that in 
2009  there  was  an  almost  50/50  split  in  terms  of  the  number  of  products  that  carried 
voluntary  claims  vs  products  that  had  no  claim.  Since  2009,  this  has  steadily  evolved 
towards a higher number of products that carry claims in comparison to products that do 
not. The situation as of July 2016 indicates that 65% of FAPS in the Innova database carry 
voluntary claims. Thus, today consumers are more likely than a decade ago to be presented 
with an FAP that carries a voluntary claim. 

15   Increase was measured via statement questions. Stakeholders were asked To what extent do you agree with 
the  following  statements  on  voluntary  claims  on  fish  products?  «  Over  the  last  10  years,  the  number  of 
voluntary claims on fish products has increased steadily. »  (certification bodies, scheme owners) Over the 
last 10 years, the number of fish products with voluntary claims has increased steadily. (import associations, 
processing and packaging companies, retailers, scheme owners) « Over the last 10 years, the number of fish 
products that carry schemes has increased steadily. » (fishery and aquaculture producers) 

16   Certification  bodies  answered  more  in  specific  the  statement  question  Do  you  agree  with  the  following 
statements  on  self-declared  claims  (defined  as  claims  that  have  not  been  certified  by  an  accredited 
certification  body)  on  fish  products?«  Over  the  last  10  years,  the  number  of  self-declared  claims  on  fish 
products has increased steadily. » 

15 

 
 
 
                                                 
Figure 5 Percentage of FAPs carrying Voluntary Claims, per year, 2009-2016 
(2016 until July) (n=13,746) 

Source: Calculations Wageningen Economic Research on the basis of Innova Database 

2.4 

Prevalence of claims according to policy areas 

Whilst section 2.2 primarily highlights the presence of voluntary claims that are supported 
by schemes that were found on FAPs in the market, this section considers the prevalence 
of all types of voluntary claims. As that section concluded, it is possible that the market 
demands something other than schemes in order to present and market FAPs. Therefore, 
the analysis considers the prevalence of all types of voluntary claims and the ‘messages’ 
that they carry.  

Stakeholders have different relations with voluntary claims on FAPs. They can choose to 
place it on their product, or receive a product with a certain claim on it. They can certify 
for  a  certain  claim,  or  can  receive  complaints  against  some  of  them  via  consumers  or 
consumer  organisations.  For  all  types  of  stakeholders,  voluntary  claims  have  a  certain 
‘message’ that relates to a given policy area or areas. There is a tendency among those in 
the  supply  chain  to  consider  that  information  (i.e.  voluntary  claims)  on  origin, 
sustainability, traceability and animal welfare/health are most commonly placed on FAPs 17. 
This seems to be reinforced by the fact that all three certification bodies interviewed within 
this study issued certification for all these categories of voluntary claims (all certified claims 
related  to  origin,  traceability  and  animal  welfare/health,  but  also  claims  related  to  food 
safety  and  environmental  responsibility).  Some  scheme  owners  combine  multiple  policy 
areas  within  their  scheme,  as  observed  from  their  responses  to  the  question  “which 
information their scheme featured on fish products conveyed” as well as the inventory of 
voluntary claims, which found that in some cases schemes covered more than one policy 
area. 

17   The  question  posed  to  stakeholders  varied  by  type  of  stakeholder,  but  covered  what  were  the  topics  or 
information that the voluntary claims on fish products convey. Scheme owners: Which information does this 
scheme featured on fish products convey? Producers: If you sell fish products, what is the information these 
schemes  convey?  Retailers:  What  are  the  most  common  topics  covered  by  the  voluntary  claims  on  fish 
products  in  your  stores?  Processing  and  packaging  companies:  A  combination  of  questions  on  what 
information  the  voluntary  claims  on  fish  products  that  come  from  their  suppliers  and  which  they  place 
themselves.  

16 

 
 
 
                                                 
It  could  be  assumed  that  the  below  policy  areas,  which  then  can  be  translated  into 
voluntary claims that are carried on FAPs, are those which the supply chain believes are of 
most interest to consumers.  

Figure  6  Presence  of  voluntary  claims  per  policy  area  per  stakeholder  type 
(supply chain stakeholders and certification bodies) 

Whilst the above opinion of the stakeholders highlights that voluntary claims may be more 
or  less  related  to  different  policy  areas,  the  inventory  built  for  this  study  illustrates  the 
variety  of claims that are found within the different policy areas as  shown in Table 2 in 
section  2.2.  The  majority  of  claims  were  found  in  four  policy  areas,  namely  origin, 
taste/quality, generic/environmental sustainability and health/nutrition. The limitation of 
this inventory are that it illustrates the variety of the number of claims within a policy area 
but does not shed light on the number of products that carry such claims.   

The Innova database of FAPs provides evidence on the percentage of products within the 
database that carry claims in sixteen different policy areas.  

Taking all the FAPs that were entered in the Innova database during the period between 
2009 and July 2016, it is clear that claims appearing on such products tend to be related 
to  a  number  of  key  policy  areas.  Almost  a  fifth  (19%)  of  the  products  identified  in  the 
database carry claims relating to health and nutrition. 16% of the products carry taste and 
product quality claims, such as ‘delicious taste’ or ‘exclusive’. Similarly, 16% of products 
have claims relating to sustainability. 10% of the products carry claims that are related to 
being ‘free of preservatives’.  

17 

 
 
 
 
 
Figure  7 Percentage  of FAPs entered  in the Innova  database carrying claims in 
various policy domains, 2009-2016 (2016 until July) (n=13,746), weighted  

Most common policy domains for claims on FAPs

20%
18%
16%
14%
12%
10%
8%
6%
4%
2%
0%

Source: Calculations Wageningen Economic Research based on the Innova Database 

This is interesting to compare to the factors that consumers consider when buying FAPs as 
indicated in the behavioural experiments. Consumers in eight Member States were asked 
which  factors  they  consider  important  when  buying  fish  products.  The  factors  that  are 
deemed most important are taste and quality, that the FAP was prepared under controlled 
(hygienic)  conditions,  how  good  the  product  is  for  your  health  and  that  it  is  free  from 
additives. With the exception of the importance that the FAP was prepared under controlled 
(hygienic)  conditions,  all  the  other  factors  that  consumers  consider  to  be  important  are 
also amongst the most common claims in terms of the number of products that carry them. 
While 
FAPs, 
claims 
environmental/sustainability  considerations  appeared  much  further  down  the  list  of 
priorities for consumers in the behavioural experiment. 

environmental/sustainability 

prevalent 

very 

are 

on 

18 

 
 
 
 
Figure 8 

The importance of factors when buying fish products  

How the product tastes

The quality of the product

That the product was prepared under controlled (hygienic)
conditions

How good the product is for your health

That the product is free from additives (e.g., preservatives,
colourings, flavourings)

How affordable the product is (i.e., the price)

The appearance of the product

That the product was caught in an animal-friendly manner

The environmental impact of the product

Your familiarity with the product

Which country/region the product comes from (i.e.,
geographic origin)

Whether or not the product is organically produced

6,07

6,05

5,84

5,78

5,73

5,62

5,54

5,43

5,30

5,25

5,25

4,99

0

2

4

6

8

A further advantage of the Innova database is the possibility to explore trends over time. 

Some  policy  areas  have  seen  a  marked  trend  as  the  percentage  of  products  that  carry 
claims within that policy area has doubled during the  2009-16 period. Nevertheless, the 
percentage of products that carry claims in these policy areas was so low in 2009 that – 
even  though  it  may  have  doubled  –  the  visibility  of  these  types  of  claims  towards 
consumers remains low. For example, the category "more detailed information on fishing 
gear" has gone from 0.5% of products in 2009 to 2.5% of products in 2016.   

The  following  graph  considers  the  trends  in  the  top  ten  policy  areas  over  the  period. 
Products are most likely to carry health and nutrition claims over the time period and this 
was relatively stable (with a spike in 2014). What is interesting is that the biggest increases 
can be seen for environmental/sustainability claims and animal welfare claims. Both policy 
areas have doubled in the period. As a result, environmental/sustainability claims were on 
par  with  the  top  ranking  policy  area  of  health/nutrition  claims  in  2016  in  terms  of 
prevalence.    The  number  of  products  carrying  animal  welfare  claims  also  jumped 
considerably from less than 5% of products in 2009 to over 11% in 2016. This means that 
what had ranked as the seventh most common policy area (in terms of products carrying 
claims in this area) in 2009 ranked fifth in 2016. This primarily relates to the higher number 
of products with dolphin friendly/safe claims.  

Furthermore, taste/quality claims were found on almost 13% of products in 2009 and this 
increased to be on par with the number of products carrying health and nutrition claims 
already  in  2012.  As  a  result,  by  2016  similar  percentages  of  products  were  carrying 
health/nutrition and taste/quality claims. 

Another policy area that has seen considerable growth is the number of products carrying 
allergen claims. This has doubled in the period and by 2016 accounted for 8% of products 
carrying such claims. It is not possible to definitively say what may be driving this increase 

19 

 
 
– it may be due an increase of those following a gluten free lifestyle amongst those that 
do so for reasons other than having a gluten allergy18.  

Figure 9 Evolution of the top 10 policy areas used on FAPs (n=13,746 products) 

25,00%

20,00%

e
l
t
i
T
s
i
x
A

15,00%

10,00%

5,00%

0,00%

Health & nutrition claims

Taste, product quality claim

Environmental sustainability claim

Other/unclassified claims

Free of preservatives, colourings,
flavourings, etc. claim

Animal welfare and animal health
claim

(Traditional) production methods

Allergen (free) claims, other than
mandatory allergen information

Composition claims (e.g.
boneless)

Origin claims and other
geographical claims

2009

2010

2011

2012

2013

2014

2015

2016

Is it possible to link this increased presence of FAPs with claims to actions by specific actors 
such as NGOs? This is a complex question. Over half of scheme owners (7 of 11), almost 
all producers (5 of 6) and all retailers (5 of 5) agreed with the statement that “there have 
been actions by NGOs that can be linked to an increase in the use of fish products with 
voluntary  claims”.  Processing  and  packaging  companies  (8  of  16)  also  often  agree  that 
actions of NGOs can be linked to an increase in the use of voluntary claims. Retailers also 
acknowledge that they receive pressure from NGOs to sell FAPs with voluntary claims. 
Nevertheless, none of the retailers indicated that this pressure from NGOs is a reason in 
their decision to sell FAPs with voluntary claims. Processing and packaging companies do 
not agree with this (only 1 agreed, 4 disagreed and another 4 took an in-between position 
whether NGOs pressure processing and packaging companies to place voluntary claims on 
FAPs).   

18   Whilst there is no clear data on this in Europe – evidence from the United States supports the hypothesis that 
increasing, 
the 
https://www.theguardian.com/society/2016/sep/06/gluten-free-eating-celiac-disease-marketing-trend-diet  

following 

numbers 

people 

gluten 

diets 

free 

of 

is 

20 

 
 
  
 
                                                 
 
Summary of key findings: 

Voluntary claims appear on all different types of packaged FAPs (frozen, chilled, 
smoked/salted/in  brine,  canned/prepared)  and  there  is  no  strong  evidence  that 
voluntary claims are found more commonly on a particular type of FAP.  

In  2013,  an  inventory  of  901  schemes  which  were  applicable  to  food  products  was 
compiled19.  Of  these,  265  were  related  to  FAPs  (either  in  combination  with  other 
products, or FAPs exclusively). That inventory took a top-down approach to identifying 
certification schemes that can be placed on FAPs. This study takes a bottom-up approach 
to identify which voluntary claims (including schemes) are found on FAPs on the market 
(rather  than  being  available  for  the  market).  In  comparing  the  results  from  the  two 
approaches, the inventory of voluntary claims built for the purposes of this study finds 
significantly fewer voluntary claims supported by a third-party scheme on FAPs 
in the market.  

In  terms  of  the  messages  (i.e.  policy  areas)  that  voluntary  claims  communicate,  the 
highest percentage of products in the Innova database carry claims relating to 
health/nutrition, taste/quality and environment/sustainability. This mirrors the 
findings  from  the  current  inventory  of  voluntary  claims  built  for  this  study,  with  the 
exception of origin claims which were commonly found in the inventory but not  in the 
Innova database. This may be due to the often visual nature of these claims (e.g. flag), 
which may not be captured by the database. Results from the consumer survey suggest 
that consumers also consider taste and quality as well as how good the product 
is  for  your  health  as  being  amongst  the most  important  factors  when  buying 
FAPs.  Another  important  factor  was  that  the  products  are  prepared  under  controlled 
(hygienic) conditions, whereas the prevalence of food safety claims is not widespread on 
products. Furthermore, whilst a high percentage of products carry claims relating 
to  environmental/sustainability  issues,  the  environmental  impact  of  the 
product featured lower on the list of factors consumers consider when buying 
FAPs.  

The share of FAPs that carry (at least one) voluntary claim is increasing. Whilst 
products most commonly carry a health/nutrition claim, this has remained fairly stable 
during the time period between 2009 and 2016. This is in stark contrast to other policy 
areas that have seen significantly higher number of products carrying claims with these 
messages.  The  number  of  products  carrying  an  environmental/sustainability 
claim increased from being ranked fifth of all policy areas to being on par with 
health and nutrition claims at the top. Furthermore, the number of products carrying 
animal welfare claims (most commonly found in the format of a dolphin welfare claim) 
doubled  in  the  period  (from  5%  to  11%  of  products  that  entered  the  market). 
Taste/quality  claims  were  also  more  prevalent  on  FAPs  at  the  end  of  the 
analysis period than in the beginning.  

Stakeholders commonly agreed that “there have been actions by NGOs that can be linked 
to an increase in the use of FAPs with voluntary claims” and retailers acknowledge that 
they receive pressure from NGOs to sell FAPs with voluntary claims. However, none of 
the retailers indicated that this pressure from NGOs is a reason in their decision to sell 
FAPs with voluntary claims.  

19   http://ec.europa.eu/consumers/consumer_evidence/market_studies/food_labelling/index_en.htm     

21 

 
 
 
 
                                                 
3   The market of voluntary claims on FAPs 

3.1  Reasons/benefits and barriers/costs to place claims on FAPs for those in the 
supply chain 

The  previous  chapter  highlights  that  the  placement  of  voluntary  claims  on  FAPs  has 
increased during the period since 2009, in line with the opinion expressed by stakeholders 
consulted  in  the  course  of  this  study  that  FAPs  are  increasingly  carrying  claims. 
Furthermore, certain ‘messages’ (i.e. policy areas) have significantly increased during the 
period; environmental/sustainability claims and animal welfare claims (which are primarily 
in reference to dolphin safe/friendly claims) in particular. This section considers the reasons 
behind why voluntary claims are placed on FAPs as well as the barriers to doing so based 
on insights gained from the stakeholder consultation.  

Reasons (which can be considered to be the benefits to producers, processor, retailers or 
other operators) to place voluntary claims on FAPs are different for different stakeholders 20. 
Overall,  for  stakeholders  who  are  in  direct  contact  with  consumers  (retailers,  retail 
associations,  producers  who  are  in  charge  of  packaging  and  other  operators),  voluntary 
claims have a dual purpose: a marketing purpose to increase sales (either to the consumer 
in  the  case  of  retailers,  or  access  to  the  market  in  the  case  of  producers)  by  adding  a 
voluntary claim to the FAP, and a brand image purpose, as voluntary claims can prove a 
certain reputation and can underline the values of the company or association. 

20   Reasons were questioned via closed questions to the following stakeholders: What are the main reasons that 
led your  company  to  differentiate  your fish  products  with  a  scheme?  (Fishery  and  Aquaculture  Producers), 
What are the main reasons the companies you represent import fish products with voluntary claims? (Import 
associations), What are the main reasons your company sources fish products with voluntary claims? & What 
are the main reasons your company places additional voluntary claims on their fish products? (Processing and 
Packaging companies) What are the reasons/benefits for your company to sells fish products with voluntary 
claims? (Retailers) 

22 

 
 
 
                                                 
Figure 10 Reasons or benefits of placing voluntary claims on FAPs per stakeholder 
type 

Benefits – open quotes from stakeholders: 

  Marketing strategy to differentiate this product from others that are similar (packaging 

and processing company) 

  Give more information and trustworthiness towards the consumers (packaging and 

processing company) 

  Maintain market access (producer) 
Fulfil clients requirements (producer) 
 
  Highlight the sustainability (producer) 
  Better image of industry and better economic returns (producer) 
 

They build confidence within supply chains and serve as an assurance against possible 
negative issues (producer) 
Increasing profit margin for company (producer) 
Increasing market access (producer) 

 
 
  Cater to the needs of their customers who request them (importer) 

Specific to third-party certified claims: 

  Clear and trustworthy message to consumer (certification body) 
 

Independent, conflict of interest free statement of compliance to a defined set of 
standards (certification body) 

  Credibility, independency of evaluation, qualification of auditors and harmonized 

 

network (certification body) 
The scheme owner cannot be accused to increase volume of sales with his “logo” 
(certification body) 

Certification bodies consider that there are several benefits for consumers (and retailers) 
from the presence on FAPs of claims relating to third party certified schemes. First, these 
claims risk no conflict of interest between the certification body, the scheme owner or the 

23 

 
 
 
 
other players in the supply chain. This is an important benefit, as opposed to self-declared 
voluntary schemes, where the scheme owners certify their own products. 

Secondly, when there are schemes on the FAP, it appears that everyone in the supply chain 
upholds  a  certain  standard.  Independently,  it  gives  a  certain  regulating  ground  for 
consumers to assume the product has met these standards.  

Barriers  to  including  voluntary  claims  on  FAPs  are  complex  according  to  stakeholders. 
There are costs to multiple players in the supply chain to uphold the requirements of some 
specific  third-party  certified  schemes,  which  can  be  a  barrier  to  including  them. 
Administrative  burdens  were  also  cited  as  an  obstacle  for  third  party  certification. 
Furthermore, as mentioned during the semi-structured interviews, in certain instances the 
demand for a certain type of FAP exceeds the availability of supply that carries a certified 
scheme and when faced with this the retailer would rather all products carry no claim than 
to  have  some  products  with  the  claim  and  other  products  without  it.  Responses  also 
indicate concern in relation to some third-party schemes being dominant in the market, 
thus making it difficult to sell products without this certification. From the perspective of 
scheme owners themselves, few or no barriers were mentioned.  

Barriers and motivators for the supply chain actors often relate to what can be gained from 
an economic point of view versus the costs (and return) of the investment.  

Barriers – open quotes from stakeholders: 

  External and internal costs, especially when participants are required to comply and be 

certified to multiple standards (certification body) 

  Can be a high degree of overlap between the similar standards versus lack of 

mechanisms to recognize equivalence between similar standards (certification body) 

  Administrative barriers (producer) 
  Costs of the scheme bureaucracy (producer) 
  Costs (using some logos is unprofitable, rights to use them are expensive) (producers, 

importer) 

  Difficult for small independent fishmongers to gain chain of custody and it is cost 

prohibitive (retailer) 
Problems with the quantities of products with particular guarantees (retailer) 

 
  Not all fish types are available under some third party schemes (retailer) 
 

Little real & tangible benefit (importer) 

This brings us to hypothesise the  reasons to place  self-declared or ‘other’  voluntary 
claims on FAPs. Costs are avoided by adding information that may imply the same as a 
third party certified scheme.  In this case, the  final point of sale (retailer) can choose to 
include this information as a self-declared scheme. However, as a result, there is a chance 
that  there  is  an  overlap  of  some  third  party  certification  schemes  with  self-declared 
schemes,  making  it  more  difficult  for  consumers  to  choose  between  what  appear  to  be 
similar  standards.  Consumers  may  indeed  be  unaware  of  the  difference  in  certification 
standards between third-party and self-declared claims – as discussed in Chapter 5.  

Costs of placing a scheme or logo were also avoided by stakeholders by including voluntary 
information that does not require certification and is still seen as bringing benefits to the 
retailer in terms of sales according to some stakeholders.  

3.2  Market visibility 

The evidence highlights that voluntary claims are increasingly present on FAPs and there 
are benefits and costs to placing different types of voluntary claims on FAPs. This section 
describes what voluntary claims can be found on the market and looks at which claims are 
most  visible  towards  consumers  in  the  EU28.  An  assessment  of  the  voluntary  claims  is 
discussed in a later chapter.  

One way of looking at the visibility of voluntary claims in the FAP market is using market 
share information. Data is collected and published in relation to consumption of FAPs and 

24 

 
 
 
expenditure  (see  EUMOFA21),  however,  retrieving  market  share  data  for  individual 
voluntary claims is problematic.  

Market shares can be obtained for a brand – but a brand often does not only market FAPs 
(for example, a brand may market a range of frozen or canned foods). Data sources that 
identify  the  market  share  of  a  brand  within  a  specific  category,  for  example,  within  the 
frozen fish category, do exist. But many voluntary claims are carried on FAPs in several 
categories, for  example,  on frozen  fish, chilled and  canned  fish. Another complication is 
that within a certain category not all products of a given brand necessarily carry the same 
voluntary claims. Therefore, it is not possible to create a reliable market share indicator 
for individual voluntary claims or for FAPs that carry a particular voluntary claim.  

Another  approach  to  assess  the  visibility  of  voluntary  claims  in  the  market  is  using  the 
percentage of FAPs that carry a particular voluntary claim on the total of all FAPs in the 
market: the more products a voluntary claim appears on, the more visible it is and vice 
versa. But this may lead to the wrong conclusion being drawn. Indeed, a voluntary claim 
can appear on a limited number  of FAPs but at the same time be  very visible when the 
FAP(s)  it  appears  on,  is  from  a  brand(s)  that is  very  present  in  the market  (i.e.  sold  at 
many retailers in several countries).  

As the above approaches, using quantitative data, are not meaningful for the assessment 
of  the  market  visibility  of  voluntary  claims  in  this  study,  a  more  qualitative  assessment 
exercise has been conducted. The starting point taken is what voluntary claims consumers 
are exposed to when deciding between FAPs: what messages on the package of FAPs are 
presented to them and which of those are most frequent and widespread, across FAPs and 
across countries? 

Market visibility, in terms of this analysis, is what consumers of FAPs are most likely to see 
when  buying  these  products  in  stores  in  the  EU.  This  is  based  on  an  analysis  of  the 
inventory built for the purpose of this study looking at: 

a) claims that are carried on 10 brands or more,  

b) claims that are carried on multiple ‘types’ of FAPs  

c)  claims that are multi-country and  

d) claims that may not meet the other criteria but are highly visible due to the variety 
of similar claims (e.g. there is no ‘common’ quality claim that appears on multiple 
brands, or multiple types or across countries, but the presence of such claims is 
high by the fact that the analysis considers the many different variations together) 

Furthermore,  the  inventory  can  also  be  described  in  general  terms.  For  example,  if  the 
analysis  considers  how  voluntary  claims  are  positioned  towards  consumers  there  is  an 
almost equal split between those that can be considered to be a picture (363 of the  713 
claims  inventoried)  (which  may  include  text)  compared  to  those  that  are  purely  textual 
claims (350 of the 713 claims). However, there are differences depending on the type of 
claim. While third-party claims are most likely to be visual pictures (73 of the 91) – self-
declared claims are almost evenly split (likely as many are textual claims that appear on 
the package in addition to a third-party scheme logo). ‘Other’ claims are more likely to be 
textual claims (268 of the 486), yet a significant share present themselves visually as a 
picture (218). 

As  mentioned  in  the  prior  chapter,  voluntary  claims  do  not  appear  to  be  more  or  less 
associated with certain types of FAPs (though there is more variety in the number of claims 
on  fish  in  comparison  to  crustaceans/molluscs)  or  the  type  of  preservation  of  the  FAP 
(fresh/chilled, frozen, smoked, canned/prepared/in brine, dried) with the exception of dried 
fish where very few claims were found.  

21   http://www.eumofa.eu/the-eu-fish-market  

25 

 
                                                 
Whilst there are 15 policy areas identified and voluntary claims are classified according to 
these policy areas in terms of the message they convey, it is possible to group these policy 
areas into nine main domains, according to their main policy area: 

•  Group 1: Issue based claims (encompassing animal welfare, sustainability, social 

responsibility) 

•  Group 2: Healthy and natural (encompassing the policy areas of health/nutrition, free 

from additives and allergen claims) 

•  Group 3: Source of the FAP (origin and traceability claims) 
•  Group 4: Taste/quality claims  
•  Group 5: Composition claims  
•  Group 6: Organic production methods  
•  Group 7: Production methods 
•  Group 8: Less visible claims (religious dietary laws, more details on fishing gear and 

food safety) 

•  Group 9: Unclassified claims 

Overall, we could observe four main groups of voluntary claims on FAP packages, namely 
group 1: Issue based claims, group 2: healthy and natural claims, group 3: claims on the 
source of the FAP and group 4: taste/quality claims22. These main groups are outlined below 
with the other groups also described in brief.  

3.2.1 

Issue-based claims  

There  are  three  main  ‘issue’  based  types  of  claims  which  are  those  relating  to 
generic/environmental sustainability, animal welfare and lastly social responsibility. These 
are all policy areas that can be considered to be issues or topics that may be of concern to 
consumers who wish to make more ‘responsible’ consumer decisions.  

A very common policy area is that of generic/environmental sustainability claims and 
certain schemes in particular. These claims tended to refer to certification of sustainable 
fishing/aquaculture, responsible sourcing/farming, or environmental programmes (such as 
mangrove  preservation).  All  such  claims  found  in  the  inventory  belonged  to  private 
organisations and canned/processed FAPs have the greatest variety of sustainability claims 
(e.g. ‘sustainably farmed’, ‘from an ASC certified fish farm’), followed by frozen FAPs, with 
relatively  few  variations  on  smoked  and  fresh/chilled  products.  A  greater  variety  of 
sustainability claims were found in Germany, followed by the UK and France. A handful of 
claims  were  part  of  umbrella  schemes,  such  as  Tesco  responsible  sourcing,  WWF,  Pro 
Planet,  and  DESPAR  -  Program  for  the  environment.  About  half  the  claims  included  a 
picture, usually of fish. 

A FAP consumer in the EU is highly likely to encounter a product that carries a MSC, or an 
ASC certification label (the inclusion of MSC or ASC depending upon the type of product). 
A wide variety of FAPs in terms preservation types and brands  carry either of these two 
schemes.    

Friend of the Sea was  also observed to be  widespread  across  countries, but in terms of 
what  consumers  are  most  likely  to  see  on  FAPs,  MSC  is  clearly  the  more  dominant 
sustainability claims in the seafood market, as evidenced by the 2012 study by Ponte23. 
The most recent MSC annual report (2016/17)  confirms this in showing that there were 
24,768  MSC  labelled  products  available  in  101  countries.  Of  all  the  different  types  of 

22   Whilst  the  Innova  database  does  not  recognise  a  large  percentage  of  products  carrying  voluntary  claims 
related to origin, this is likely to do with the fact that Innova picks up mostly on textual claims and origin 
claims are commonly presented in a visual format.  

23   Ponte, S. (2012), “The Marine Stewardship Council (MSC) and the Making of a Market for ‘Sustainable Fish’”, 

Journal of Agrarian Change, Vol. 12, No. 2-3, pp. 300-315. DOI: 10.1111/j.1471-0366.2011.00345  

26 

 
                                                 
sustainability claims, those referencing one of the main three certification schemes (MSC, 
ASC, or Friends of the Sea), appeared on the most number of brands. 

In general, it is observed that the packaging of products carrying generic/environmental 
sustainability  claims  very  often  provides  the  criteria  for  the  certification  by  adding  a 
reference to the claim message in a more explicit form, some as a text message, other in 
a more visual design. 

This may be a result of expectations that consumers are not sufficiently informed on what 
the scheme stands for. The MSC annual report 2016/17 indeed shows that only a third of 
consumers recognise the blue logo.  

Self-declared claims displayed the greatest range of different claims. Such claims can be 
set up by producers and brands to combine several topics into their own claim, although 
they  are  predominately  related  to  sustainability  and  responsibility  for  the  environment. 
Widespread brands have their ‘own’ claim on the packages based on criteria certified by 
3rd party  certifications among  others, but elaborated with other  criteria referring to the 
same policy area but also extending to other areas like quality. 

Whilst generic/environmentally friendly claims are found to be very widespread in terms 
of  being  present  in  all  countries,  found  on  all  types  of  FAPs  and  being  carried  by  many 
brands, animal welfare claims are also very visible for those who purchase certain types of 
FAP.  

Animal welfare claims do not generally refer to the fish/seafood element of the product, 
but the welfare of other species when the fish is caught. The vast majority of these claims 
are in reference to the safety of dolphins, with the Earth Island ‘Dolphin Safe’ logo having 
the greatest market visibility in terms of number of brands and countries where this claim 
was found. Nevertheless, there are multiple brands in multiple countries that are carrying 
a dolphin safe  claim where the picture is not the official logo of the third-party certified 
scheme. Another common claim is the ‘Dolphin friendly’ claim that is not associated with 
any scheme but is found on 11 different brands across 6 different countries. Furthermore, 
it  was  not  possible  through  desk  research  to  verify  whether  these  dolphin  friendly/safe 

27 

 
 
 
claims  are  part  of  a  self-declared  scheme  or  what  is  behind  these  claims.  The  claims 
relating to dolphin safe/friendly fishing practices are nearly always found on tinned (tuna) 
products – and frozen tuna fillets were also found to be carrying the claim.  

The presence of the dolphin safe/friendly claims are the most visible in the animal welfare 
policy area. What is interesting is that there are a small number of claims that refer to the 
welfare of the fish itself – for example RSPCA in the UK referring to the welfare of salmon 
and trout. These types of claims are not commonly found on multiple brands or in multiple 
markets.  Only  the  RSPCA  claim  was  a  third-party  certified  claim  with  the  other  animal 
welfare claims that were unrelated to dolphin welfare such as ‘100% animal welfare’, ‘Safe 
[picture of a turtle]’ or ‘Salmon welfare’ being without clear reference to a scheme. Claims 
in this policy area were more often found in Italy and the UK than in other countries in the 
EU. All claims were owned by private organisations, and the only claim associated with an 
umbrella scheme, and therefore also found on non-FAP products, was the RSPCA claim. All 
but one claim was in a picture format. 

Whilst  generic/environmental  sustainability  and  animal  welfare  claims  are  commonly 
observed on FAPs, the policy area of ‘social responsibility’ which could also be considered 
to be an issue-based set of claims is not very visible on the market. There were relatively 
few  claims  in  this  policy  area  and  were  often  coupled  with  another  policy  area  (most 
commonly origin and sustainability) rather than being the ‘main’ policy area of the claim. 
Therefore,  social  responsibility  claims  appear  to  be  an  element  of  a  third-party  or  self-
declared  scheme  (which  was  more  commonly  the  case)  rather  than  the  focal  point  and 
none of these claims were ‘other’. Only five claims could be said to be mainly in reference 
to the issue of social responsibility and these claims were all self-declared claims made by 
the individual brand. Therefore, these claims are not frequently obvious to the consumer 
as they are either only part of a broader scheme or are a self-declared claim carried by 
only  some  brands  in  certain  countries,  namely  Followfish  (Belgium,  Germany, 
Luxembourg),  Fish  Tales  (Belgium  and  the  Netherlands)  Butler’s  Choice  (Denmark)  and 
Ovive  (France).  Only  two  of  the  claims  belonged  to  umbrella  schemes  –  ‘Fair  Trade 
Certified’,  and  ‘Butler’s  Choice’.  Animal  welfare  claims  were  generally  found  on 
canned/processed and frozen FAPs (although the very small sample size makes it difficult 
to draw general conclusions). 

3.2.2  Healthy and natural 

Regardless  of  what  FAP  the  consumer  wants  to  buy,  eating  fish  and/or  seafood  is  often 
promoted as a healthy choice – this encompasses the policy areas of health/nutrition, free 
from additives and could also include allergen claims as they relate to gluten free claims 
which some people choose for dietary reasons rather than allergies. Fish and seafood are 
natural sources for Omega 3- Fatty acids and those marketing FAPs appear to utilise this 
fact to market their products as healthy for the consumer.  

Capitalising on the potential health benefits of Omega 3 is popular as almost all types of 
FAPs and many brands carry a claim that brings the consumers attention to the fact the 
fish contains (high levels) of Omega 3. This claim has many variations, which can take the 
form of more elaborate explanations “Salmon is a natural source of omega-3 (fatty acids)” 
to  a  very  simple  “Omega  3”  without  defining  the  level  of  the  nutrient  (for  a  further 
discussion on this see Chapter 6 on the assessment of claims).  

28 

 
In addition to the very apparent Omega claims (which come in a variety of formats), many 
packages of FAPs will display other health/nutrition claims, for instance referring to FAPs 
as being a natural source of protein. There were fewer varieties of claims (that were still 
found over multiple brands) communicating that the FAP had reduced salt, reduced fat, is 
a source of vitamins, and minerals, and those suggesting that that the product is associated 
with a health organisation (e.g., national heart foundations). Most claims were found on 
canned/processed products. There were very few umbrella schemes, specifically ‘Eat well’ 
(associated with a retail chain), ‘Tick in a green circle’ (owned by producers), and the public 
Green Keyhole of Sweden. The claims were more often found in the UK, Malta, and Czechia 
than  in  other  countries.  There  were  slightly  more  text  than  picture  claims,  which  most 
pictures illustrating an element associated with omega 3, such as a fish, a heart, a drop, 
or an omega symbol. Almost all claims were ‘other’ claims (i.e., not associated with a third 
party  or  scheme).  Claims  in  this  policy  areas  were  generally  associated  with  private 
organisations.  

The addition of artificial colouring, flavouring and preservatives is a  common practice in 
the food industry. Next to the healthy benefits of the seafood, many packages of FAPs will 
also display that during  the processing ‘no additives’ were added. Furthermore,  claims 
purporting  that  the  product  is  ‘natural’  are  commonly  carried  across  various  types  of 
products and many different brands, but only in the case of canned tuna and bonito the 
use of the term 'natural' is regulated by law.  

29 

 
 
 
 
Another  very  popular  claim  were  those  declaring  the  absence  of  preservatives  (often  in 
combination  with  the  absence  of  artificial  colours  and  flavours).  It  is  interesting  to  note 
that  the  claims  stating  an  absence  of  additives  were  often  found  on  canned/processed 
products, and very few were found on fresh/chilled products.  

featured 

leaves  (e.g.,  Without  colorants;  without 
Picture  claims  predominately 
taste  enhancers”,  “Without 
preservatives;  “Without/no  preservatives”,  “Without 
stabilizer”), even though none of the claims were related to plants. It could be construed 
that such a motif is used to convey an image of the product being more natural through 
its lack of additives. This impression is reinforced by the results of a survey of 2,046 Danish 
households24,  in  which  the  most  common  reason  given  for  avoiding  additives  (given  by 
40% of respondents) is that additives are unnatural, unhealthy, and unnecessary.  

All claims were associated with private organisations, and only one belonged to an umbrella 
scheme (i.e., ‘A-Quality - Ä-märket’). Czechia and Poland featured more of the different 
claim types than the other EU countries. 

There are very few allergen claims and all relate to the FAP being free from gluten. Whilst 
the  ‘gluten  free’  claim  itself  is  commonly  found  across  countries  –  this  is  primarily  in 
reference to FAPs that include other ingredients such as a breading or mayonnaise. Finding 
a gluten free  claim on an FAP that is solely in relation to the fish/seafood  component is 
rare, but is found on a very small number of FAPs (in terms of type and brands). These 
claims do not typically belong to a  scheme (either third-party or self-declared) with the 
exception  of  claim  linked  to  a  coeliac  society  in  Portugal,  making  the  claim  part  of  an 
umbrella scheme. The claims were most commonly represented by the image of an ear of 
wheat that is crossed out. 

The gluten free claims referring to the fish/seafood itself were not exclusive to a particular 
type of FAP, although many were on canned products and none were found on fresh/chilled 
products in the inventory. Finding these claims on FAPs that are not prepared  can have 
valid reasons to include this type of claim – for example because of the fact the product 
can  be  guaranteed  not  to  carry  the  risk  of  gluten  cross-contamination  during 
manufacturing. However, it may also be linked to marketing of goods as ‘gluten free’ due 
to the trend towards this as a diet/lifestyle choice as described in section 2.4.  It is also 
worth  noting  that  gluten-related  claims  are  regulated  by  Reg  828/2014  on  the 
requirements  for  the  provision  of  information  to  consumers  on  the  absence  or  reduced 
presence of gluten in food. 

3.2.3  Source of the FAP: Where does my FAP come from? 

When a consumer wants to buy a FAP, s/he will most likely find a claim on the package 
that gives some information about where the FAP was sourced. These types of claims are 
origin claims and also traceability claims.  

24   Christensen, T., Mørkbak, M. R., Evald, S. S. T., & Jensen, J. D. (2011). Danish consumers’ perceptions of 
(2011/4). 

Commissioned 

other 
food 
https://curis.ku.dk/ws/files/44757230/FOI_udredning_2011_4.pdf  

technologies. 

additives 

work, 

and 

FOI 

30 

 
 
                                                 
The way the source claim is formulated depends upon the type of product. For example, 
smoked  salmon  is  often  accompanied  by  information  on  origin  relating  to  the  main 
production areas: Norway, Scotland and Alaska. For canned tuna, the package will most 
likely have a claim referring to the ocean where it is caught, which is voluntary information 
on  canned  products,  but  mandatory  information  for  non-processed  or  lightly  processed 
products.  

Since  smoked  and  canned  FAPs  are  in  a  very  competitive  market  with  several  similar 
products (mostly from the same regions) the origin claims on these products are enhanced 
by  visual  effects  like  the  colours  of  the  flag  or  some  identifiable  seascape/landscape  In 
terms  of  the  different  types  of  origin  claims  found  in  the  inventory,  there  was  a  similar 
proportion  of  text  and  picture  claims.  Nearly  all  claims  were  associated  with  private 
organisations,  and  the  only  umbrella  schemes  were  Italcheck  (for  Italian  products), 
Certificate of Polish product, Artesania; region of Murcia, and Croatian Creation. 

Origin  claims  are  more  apparent  in  some  countries  than  in  others.  FAP  products  in,  for 
example, France, Italy, Spain, Poland are more likely to carry an origin claim than other 
countries  like  Bulgaria,  Austria  or  Germany.  It  is  interesting  to  note  that  origin  claims 
related to France or Spain more frequently referred to regional areas (e.g., ‘Prepared in 
Brittany’ ‘Produced in Galicia’), compared to claims related to other countries (e.g., ‘Made 
in Iceland’). 

Information  about  the  origin  of  the  product  is  not  only 
displayed in the form of country or region claims, but is also 
made available off the package and can be accessed via a URL 
or  QR-code  displayed  on-pack.  In  addition  to  information 
about the origin of the FAP, many traceability claims provide 
information about other details of the supply chain,  such as 
what happens to the FAP between the process of being caught 
and distribution of the product (e.g., “100% Traceable - Trace 
your can”, and “From fjord to table – [methods described]”. 
These types of ‘traceability’ claims are nearly always found 
on  canned  tuna  products  and  are  specific  to  the  brand  of 
product  –  with  many  brands  carrying  some  variation  of  this 
claim. Of the different types of traceability claims available, more were found in Germany 
than in other countries. The different types of claims were similarly divided between picture 

31 

 
 
and text formats. Most  of the picture  claims featured an image of  a fish. All traceability 
claims  were  associated  with  private  organisations,  and  none  belonged  to  an  umbrella 
scheme.  

3.2.4  Composition claims 

It is possible for FAPs to have some characteristics that may turn consumers off. Therefore, 
it is unsurprising that voluntary claims were found on the market that explain to consumers 
the absence of undesirable characteristics in their products. Claims stating that the product 
is ‘without skin and bones’ (or some variation of this) are very prevalent on the packages 
of  most  types  of  fish.  Again,  they  come  in  a  wide  variety  of  text  or  pictures,  but  the 
message they display is univocal.  

Composition claims were most often found on frozen and canned/processed FAP, perhaps 
because, unlike fresh or smoked FAP which normally have transparent packaging, frozen 
and  processed  FAPs  are  often  presented  in  (mostly)  opaque  packaging,  which  does  not 
allow the consumer to visually assess the composition of the food. No claims in this policy 
area were associated with schemes, and all originated from private organisations. As can 
be  expected  with  claims  relating  to  the  structural  characteristics  of  FAP,  no  claim  was 
associated  with  an  umbrella  scheme.  Whilst  claims  relating  to  being  skinless  and/or 
boneless were most common – composition claims in relation the percentage of FAP in the 
product, such as 100% cod, were also very present. The greatest number of the different 
types of composition claims were found in Belgium, followed by France and the UK. 

3.2.5 

Taste/Product Quality 

EU consumers will not find a single ‘common’ quality claim on FAP packages. When looking 
for  a  quality  product  the  consumer  will  rather  be  exposed  to  an  immense  diversity  and 
variety of claims telling them something about the product’s quality. The more frequent 
claims were those that referred to the product as being ‘Quality’ or ‘Premium’, and those 
that  referred  to  the  positive  taste  of  the  FAP  (e.g.,  ‘Tasty’,  ‘Delicious’).  References  to 
awards were also commonly featured on claims in this policy area. Inventorised claims in 
this policy area were most commonly found in the UK and Belgium. Canned and processed 
products carried the greatest variety of the different types of claims. 

Third  party  certified  quality  and  taste  schemes  are  very  rare  –  with  the  exception  of 
‘awards’  for  taste/quality,  which  also  tended  to  be  associated  with  umbrella  schemes, 
whereas  other  taste/quality  claims  were  not.  Most  claims  were  associated  with  private 
organisations.  The  most  notable  claim  associated  with  a  public  organisation  are  the  EU 
quality claims (i.e., ‘Protected Designation of Origin’, ‘Protected Geographical Designation’, 
and ‘Traditional Speciality Guarantee’), which are also umbrella schemes.   

It is not uncommon for retailers who carry their own products to set out criteria for their 
top  quality  products  on  their  websites.  The  claims  from  these  superstores  provide  the 
consumer a very clear choice to buy a perceived superior product or not if the choice  is 
made between their own brands (i.e. for consumers who choose between a ‘budget’ own-
brand or a more ‘superior’ own-brand of the retailer). 

When the consumer has to choose between different brands, it is however impossible to 
compare and make a rational choice. What frozen salmon would be better quality? The one 

32 

 
 
that carries the claim ‘superior’  or the  one that claims that is from a  ‘special selection’? 
There are no objective criteria to decide. 

Within this variety of ‘quality’ claims, some producers highlight the claim by adding design 
elements, making the claim look like a seal. Adding these design elements does not provide 
the consumer more information on the criteria for the quality claim, but they could have 
the effect of giving the impression that the claim has some kind of criteria to which it has 
to adhere. A little over half of the different types of taste/quality claims were in a picture 
format. 

3.2.6  Organic production methods 

Organic  FAPs  are  farmed  according  to  regulated  stocking  densities,  are  not  spawned  by 
artificial hormones, and should be fed on organic feeds that can be supplemented by fish 
feeds  from  sustainably  managed  fisheries.  However,  this  definition  differs  from  the 
common public perception of organic FAPs (as will be discussed in the assessment of claims 
in Chapter 6). In the EU, all products with organic claims need to be supported by a public 
scheme. About half the claims belonged to umbrella schemes. Of all the FAP types, smoked 
FAPs had the greatest number of the different types of organic claims, probably because 
smoked FAPs tend to consist of salmon, which tends to be subject to organic production 
methods more so than other species.  

Nearly  all  claims  were  associated  with  private  organisations,  with  the  exception  of  the 
certification bodies EU Organic and Bio Siegel (nach EG-Öko-verordunung). These private 
organisations can be found at all levels of the supply chain, including producers (e.g. Circeo 
Pesca’s ‘Live naturally’), processing business (e.g. Labeyrie’s ‘From organic aquaculture’), 
and retailers (e.g. ‘TESCO Organic – working with nature’), as well as 3rd parties such as 
non-profit organisations (e.g. ‘Naturland’), and certification bodies (e.g., ‘Organic Farmers 
and Growers’ –).The claims generally referred to organic umbrella schemes that also apply 
to foods other than FAPs.  

Claims  that  were  supported  by  the  organic  schemes  EU  Organic  and/or  Agriculture 
Biologique (ie., the EU Organic and/Agriculture Biologique logos were found elsewhere on 
the packaging) were found on the most number of brands, with the EU Organic label having 
the widest cross-country coverage. Organic claims were more commonly found in Germany 

33 

 
 
 
and  France  than  in  other  countries.  The  different  types  of  organic  claims  were  similarly 
divided between picture and text formats.   

3.2.7 

Production methods 

The  claims  in  this  policy  area  referred  to  smoking  methods,  salting  methods,  regional 
styles,  traditional  methods,  hand  processing  methods,  freezing  methods,  and  special 
cooking methods (e.g. ‘flame roasted’). They tended to be designed to highlight tradition, 
taste and the careful preparation of the product, rather than to inform the consumer about 
manufacturing  processes.  Of  the  EU  countries,  France,  Poland  and  the  UK  featured  the 
greatest variety of claims relating to production methods.  All claims were associated with 
private organisations, and none were related to umbrella schemes. The claims in this policy 
area were similarly divided between picture and text formats. The claims that appeared in 
most countries were those that referred to smoking methods and hand processing. Of the 
claims related to smoking methods, most referred to the type of wood that was used (e.g., 
beech, oak), or indicated that the fish was traditionally smoked. Claims related to the type 
of wood used for smoking may be referring to the product having a distinct taste. Claims 
related  to  traditional  smoking  methods  refer  to  the  method  of  smoking  as  being  more 
natural (rather than using a chemical smoke flavour). In general, claims about production 
methods  seemed  designed  to  bestow  a  more  artisanal  image  on  the  FAP  in  order  to 
differentiate  it  from  other  smoked  products.  Perhaps  unsurprisingly,  smoked  and 
canned/processed products had the greatest diversity of claim types in terms of production 
methods. 

3.2.8  Smaller policy areas 

FAPs rarely carry messages that fall into the policy areas of food safety or religious dietary 
laws.  The  claims  about  food  safety  are  nearly  all  in  reference  to  HACCP,  and  religious 
dietary  law  claims  are  only  in  relation  to  being  kosher.  Another  smaller  policy  area  are 
claims about fishing gears. These claims are only really found on canned tuna in reference 
to the pole and line method of fishing and are self-declared (except for one claim referring 
to Rope  Grown  Mussels). Therefore, there is no third-party scheme that is found in this 
policy domain across brands but rather brands themselves have their own self-declared or 
‘other’  claim  about  the  fishing  methods  used.  The  greatest  variety  of  claims  related  to 
fishing methods was found in the UK.  

All claims in these smaller policy areas are associated with private organisations, and only 
those  associated  with  HACCP  food  safety  and  Kosher  certification  belong  to  umbrella 
schemes. 

3.2.9  Unclassified 

Some claims did not belong to any of the main policy areas, they are known as ‘unclassified 
claims’.  There  were  three  main  categories  of  such  claims,  the  most  visible  (in  terms  of 
exposure across brands and countries) being those referring to the ‘wild’ nature of the FAP, 
followed by those referring to the ‘fresh’ quality of the FAP, and those referring to the lack 
of  GMO  associated  with  the  FAP.  All  unclassified  claims  were  related  to  private 
organisations, and only one was part of an umbrella scheme.  

Claims about the wild nature of the FAP were found across all FAP types and in most EU 
countries. Claims about freshness and being free of GMOs were found only on fish, and not 
on  crustaceans  nor  molluscs.  As  can  be  expected,  claims  about  freshness  were  mainly 
found on fresh/chilled products, but they were also found on canned products. 

34 

 
 
 
Summary of key findings: 

In  terms  of  explaining  why  voluntary  claims  are  carried  on  FAPs,  the  stakeholder 
consultation  suggests  two  primary  motivations  for  those  in  the  supply  chain  – 
marketing and improving brand image. Marketing is not only to be understood as 
differentiating  the  product  from  other  (similar)  products,  but  also  in  terms  of  gaining 
access  to  a  market  amongst  producers  (rather  than  gain  a  price  premium  for  their 
products).  

The benefits of placing claims supported by participation in certification schemes on FAPs 
are  outlined  by  certification  bodies.  There  is  no  conflict  of  interest  between  the 
certification body, scheme owner or other players in the supply chain. Consumers can 
assume  the  product  has  met  the  standards.  However,  for  some,  the  costs  and 
administrative  burden  of  participating  in  such  schemes  is  a  barrier  to  being 
included  in  them.  This  could  lead  to  the  market  seeking  alternatives,  such  as  self-
declared schemes or placing ‘other’ types of voluntary claims on their products to market 
them.  

Whilst it is not possible to determine the market shares of certain claims, the evidence 
from the inventory of voluntary claims built for the purpose of this study highlights which 
claims are most ‘visible’ towards consumers. That is, which voluntary claims are most 
likely to be encountered by consumers when the pick up a package of fish/seafood.  

Certain  schemes  (namely  MSC,  ASC)  within  sustainability  claims  are  very 
dominant as claims supported by these schemes are found on (almost) all types of FAPs 
and across the entire EU. Beyond the MSC, ASC supported claims, the most common 
claims  are  communicating  to  the  consumer  that  the  FAP  is  a  healthy  choice 
through the use of a variety of Omega 3 claims or other nutritional claims. Furthermore, 
claims  often  relate  to  the  fact  the  product  is  ‘natural’  and  has  no  additives 
(preservatives or colourings) reinforcing the ‘healthy’ image of the product. Consumers 
are also faced with a large variety of quality claims on FAPs, with no tendency 
towards a certain standard description of quality. Furthermore, claims commonly refer 
to where the FAP comes from  either through the use of visuals (such as flags and 
maps) or tracking codes (allowing to trace the fish through its production chain).   

35 

 
 
 
 
 
4  Consumer behaviour and purchasing decisions 

4.1  Do voluntary claims influence consumer behaviour? 

4.1.1 

The effect of type of claim and policy area on consumer behaviour 

The first research question in relation to consumer behaviour was what impact voluntary 
claims have on consumers’ behaviour and purchasing decisions, including their willingness 
to pay a bonus price for products that belong to a scheme.  

The  results  from  the  behavioural  experiments  suggest  that  the  presence  of  a  single 
voluntary claim in comparison to products without a voluntary claim may have little effect 
on  consumers’  decisions.25  Experiment  1  shows  that  consumers  were  not  more  likely  to 
purchase  products  with  a  claim  than  without  a  claim.  The  results  of  both  experiments 
showed that consumers’ purchase intentions were also relatively unaffected by the type 
of voluntary claim (third-party/self-declared versus other voluntary claims26). 

Figure 11 

The estimated effect of the type of claim on purchase intention 

7

6

5

4

3

2

1

4,65

4,58

4,51

4,48

3,38

3,26

Other claim

3rd party/self-
declared claim

Control 
(no claim)

Salmon

Cod

Experiment 1

Mussels

Experiment 2

Similarly,  consumers  are  not  very  ready  to  pay  a  premium  price  for  packages  with 
voluntary claims (Figure 12). The findings of both experiments show that willingness to 
pay (WTP) is relatively unaffected by the type of voluntary claim on a FAP. Compared to 
packages with no claims, WTP is only higher for frozen cod with a 3rd party/self-declared 
claim (M3rd/sd claim=3.33 vs. Mno claim=3.08; p=.036). No other differences between packages 
with  and  without  claims  and  between  packages  with  different  claims  were  found  in  the 
experiments. 

25   Including the respondents’ financial situation as a covariate to control for its effect on the purchase intention 

did not affect the results. 

26   “Other voluntary claims” include voluntary claims that are defined as logos, statements and images on the 
product packaging, which constitute a claim as to the attributes of the product or its production process that 
are not part of a third party certified or self-declaration scheme. Claims that have no specific criteria attached 
to them are considered as ‘other’ – or where claims are verifiable (but without specific criteria) such as skinless 
and boneless, no artificial colours, etc. 

36 

 
 
 
 
                                                 
Figure 12 

The estimated effect of the type of claim on willingness to pay 

5 €

4 €

3 €

2 €

1 €

0 €

3,93 €

3,90 €

3,18 €

3,33 €

3,20 €

3,11 €

Other claim

Control 
(no claim)

Salmon

Cod

Experiment 1

Mussels

Experiment 2

However, consumers may not know the difference between different ‘types’ of voluntary 
claims  (discussed  further  in  section  7.1).  Therefore,  a  measure  of  what  the  consumers 
believed the claims to be in Experiment 1 can also be used to estimate the effect of the 
(perceived) claim type on consumers’ behaviour27.  

The resulting regression models show that purchase intention was relatively unaffected 
by the perceived type of claim. Consumers were only somewhat more likely to purchase a 
FAP when they thought that the claim on the package was verified by a third party claim 
(M  =  4.82)  than  when  they  thought  the  claim  was  self-declared  (M  =  4.68;  p  =  .076), 
while other comparisons were not significant. Similarly, no significant effects were found 
for the willingness to pay.  

The  presence  of  a  claim  may  not  have  a  large  impact  on  consumers  increasing  their 
likelihood to purchase a product, as it is not the presence of the claim per se or even the 
type  of  claim  (or  perceived  type  of  claim),  but  rather  the  message  that  it  conveys  that 
influences consumers to make a purchase. However, the results from Experiment 1 do not 
support this hypothesis: consumers were not more likely to purchase products with a claim 
in certain policy areas in comparison to claims covering other policy areas or compared to 
products  without  voluntary  claims.  Similarly,  consumers’  willingness  to  pay  was  also 
unaffected by the policy area covered by the claim. 

Finally, the analysis considered both the type of claim and the message of the claim (i.e. 
policy  area)  together  and  whether  there  may  be  a  combined  effect.  The  findings  of  the 
regression analysis ( 

27   Concretely, a model was estimated that predicts respondents’ behaviour and perceptions when they believe 

the claim was certified by a third-party versus self-declared versus other claims.  

37 

 
 
 
                                                 
Figure  13),  illustrates  no  significant  interactions  between  the  two  factors28.  The  type  of 
claim and policy area it conveys do not influence each other’s effect on purchase intentions 
or willingness to pay.  

28   Despite the absence of interactions between the types of claim and policy areas, consumers are willing to pay 
more  for  a  FAP  with  a  3rd  party/self-declared  quality  claim  than  for  a  FAP  without  claim  (p  =  .042).  The 
differences between all other claims and the control condition are not significant (all p > .05). 

38 

 
 
 
                                                 
7

6

5

4

3

2

1

Figure 13 
willingness to pay, conditional on the type of claim 

The estimated effect of policy area on (a) purchase intention and (b) 

a) 

Purchase intention 

4,61

4,67

4,67

4,48

4,47

4,43

Other claim

3rd party/self-
declared claim

Control 
(no claim)

Other claim

3rd party/self-
declared claim

Control 
(no claim)

Sustainability

Quality

Origin

b)     Willingness to pay 

3,52 €

3,49 €

3,56 €

3,70 €

3,51 €

3,70 €

5 €

4 €

3 €

2 €

1 €

0 €

Sustainability

Quality

Origin

4.1.2 

The role of claim credibility 

Voluntary  claims  may  be  able  to  affect  consumers’  decisions  regarding  FAPs  via  the 
credibility  they  evoke.  The  findings  of  Experiment  1  show  that  perceived  credibility29  of 
voluntary  claims  is  positively  related  to  purchase  intention  (β  =  .93;  p  <  .001)  and 
willingness  to  pay  (β  =  .55;  p  <  .001).  Furthermore,  the  current  findings  suggest  that 
perceived credibility may be one of the most important drivers of the impact of claims on 
consumer  behaviour.    A  multiple  regression  model  estimated  the  effect  of  perceived 
credibility, while also including the perceived type of the claim (3rd party certified vs. self-
declared vs. other) and the policy area covered by the claim (sustainability vs. quality vs. 
origin)  on  purchase  intention  and  willingness  to  pay.  The  findings  show  that  even  after 
including the other factors, perceived credibility remains a strong predictor of  consumer 
behaviour (p < .001).  

Despite  the  importance  of  perceived  credibility,  the  findings  in  Figure  14  show  that 
consumers are often unaware of actual differences in credibility between different types of 
claims. Based on the assumption that consumers are knowledgeable about the difference 
in different types of claims, perceived credibility should be higher for 3rd party and self-
declared claims than for other claims. However, only a very small (marginally significant) 
difference in favour of 3rd party certified and self-declared claims was found (M3rd part/self-
declared = 4.34 vs. Mother = 4.25; p = .069).  

29   Perceived  credibility  of  claims  was  measured  using  the  scale  by  Moussa,  S.,  &  Touzani,  M.  (2008).  The 
perceived credibility of quality labels: a scale validation with refinement. International Journal of Consumer 
Studies, 32(5), 526-533. 

39 

 
 
 
 
 
                                                 
Figure 14 
perceived credibility of the claim  

The  estimated  effect  of  type  of  claim  and  policy  area  on  the 

7

6

5

4

3

2

1

0

4,30

4,41

4,21

4,35

4,23

4,28

Other claim

3rd party/self-
declared claim

Sustainability

Quality

Origin

The  fact  that  this  difference  in  perceived  credibility  does  not,  however,  translate  into  a 
higher purchase intention or willingness to pay for FAPs with 3rd party and self-declared 
claims,  hints  toward  the  impact  of  other  factors.  One  such  factor  may  be  consumer 
confusion, as indicated by mixed results regarding the correct interpretation of claims (see 
section 7.3). This includes potential risks. Consumers may use claims based on their own 
subjective interpretations, while the claims may be missing objective criteria. 

4.1.3 

The role of concurrent claims 

Whilst consumers were not more or less likely to buy FAPs with a single voluntary claim 
(regardless  of  type  or  policy  area),  Experiment  2  considers  the  presence  of  concurrent 
claims on FAPs on the behaviour of consumers. 

Figure 15 

Concurrent claims in Experiment 2 

Concurrent claims 

Focal 
voluntary 
(Other quality claim) 

claim 

The results of Experiment 2 demonstrate that, while purchase intentions do not appear to 
be strongly influenced by the presence of one or more concurrent claims, consumers may 
be willing to pay a premium for FAPs when concurrent claims are present on FAPs 
that carry a third party claim.30  

30   When no concurrent claims are present, the willingness to pay was statistically the same between FAPs with 
a 3rd party claims (M = 3.11) and packages with an other claim (M = 3.20; p = .89). When concurrent claims 
were  added,  consumers’  willingness  to  pay  increased  (Mconcurrent  claim    =  3.38;  SD  =  2.20  vs.  Mno 
concurrent claim = 3.16; SD = 2.16; p = .004). This effect was particularly driven by FAPs with a 3rd party 
claim (p = .044), while no significant difference was found for FAPs with an other claim (p = .15). 

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 16 

The effect of concurrent claims on willingness to pay for FAPs 

€ 3,42

€ 3,11

€ 3,20

€ 3,34

No concurrent claims

Concurrent claims

5 €

4 €

3 €

2 €

1 €

0 €

3rd party claim

Other claim

The results suggest that adding concurrent claims increase the value of the product in the 
eyes of the consumer. Hence, adding more (even relatively unrelated) claims to packages 
of FAPs might result in a bonus price being paid as such products are considered to warrant 
a higher value. 

4.2 

Factors consumers consider when buying FAPs 

The  post-experiment  questionnaire  measured  the  perceived  importance  of  12  different 
aspects that respondents declare they take into account when buying fish and aquaculture 
products on a 7-point scale (Not important at all – very important)31.  

31   Question 12: “To what extent are the following aspects important to you when you buy fish and aquaculture 

products?”  

41 

 
 
 
                                                 
Figure  17  shows  all  12  aspects  and  the  average  perceived  importance  across  all 
experimental  conditions.  Consumers  find  the  taste  of  the  product  (M  =  6.07)  and  the 
quality of the product (M = 6.05) most important. In contrast, consumers find it the least 
important if a FAP is produced organically (M = 4.99). 

42 

 
 
 
Figure 17 

The (self-declared) importance of factors when buying fish products  

How the product tastes

The quality of the product

That the product was prepared under controlled (hygienic)
conditions

How good the product is for your health

That the product is free from additives (e.g., preservatives,
colourings, flavourings)

How affordable the product is (i.e., the price)

The appearance of the product

That the product was caught in an animal-friendly manner

The environmental impact of the product

Your familiarity with the product

Which country/region the product comes from (i.e.,
geographic origin)

Whether or not the product is organically produced

6,07

6,05

5,84

5,78

5,73

5,62

5,54

5,43

5,30

5,25

5,25

4,99

0

2

4

6

8

The factors consumers find important when purchasing FAPs might have an impact on the 
way they use package information, including voluntary claims. Concretely, consumers may 
pay more attention to a claim of a certain policy area (e.g. sustainability, quality, origin), 
when this policy area corresponds with aspects they find important when buying fish. For 
example, a consumer who attaches great importance to fish sustainability may be more 
inclined to purchase a fish with a sustainability claim than a consumer with little regard for 
sustainability. 

While the findings of Experiment 1 show that consumers with a relatively high regard for 
sustainability (i.e. “the environmental impact of the product”), quality or origin of the FAP 
are  generally  willing  to  pay  a  premium  price  for  FAPs,  the  findings  do  not  suggest  a 
consistent increase of consumers’ use of the respective claims. For example, while a higher 
perceived importance of sustainability caused a significantly higher willingness to pay for 
3rd  party/self-declared  sustainability  claims  (3.98  vs.  3.05),  it  also  increased  the 
willingness  to  pay  for  packages  with  no  claims.  In  addition,  willingness  to  pay  was  not 
affected  for  other  sustainability  claims  (3.63  vs.  3.42).  The  absence  of  a  significant 
interaction further suggests that, while consumers who find sustainability important might 
be willing to pay more for FAPs in general, they are not more likely to rely on sustainability 
claims  on  FAP  packages.  The  table  below  (Figure  18)  shows  that  while  consumers’ 
willingness to pay is significantly higher for respondents who find sustainability important 
(except for packages with the other sustainability claim), consumers are not more likely to 
rely on sustainability on FAP packages. After all, sustainability importance also increases 
the willingness to pay for packages with quality claims, origin claims and even packages 
without any claim. 

43 

 
 
 
 
 
 
Figure 18 
for an FAP as a function of the type of claim featured  

The effect of the importance of sustainability on willingness to pay 

3,63 €

3,42 €

3,98 €

3,85 €

3,95 €

3,99 €

3,05 €

3,22 €

3,46 €

3,70 €

3,33 €

3,38 €

3,65 €

3,23 €

Low importance of
sustainability

High importance of
sustainability

4,5

4

3,5

3

2,5

2

1,5

1

0,5

0

Other claim 3rd/ sd
claim

Other claim 3rd/ sd
claim

Other claim 3rd/ sd
claim

Sustainability claim

Quality claim

Origin claim

No claim

Similarly,  while  higher  quality  concerns  increase  the  willingness  to  pay  for  FAPs  with  a 
quality claim, it also increased the willingness to pay for products with other claims, such 
as origin claims. Finally, higher importance of origin increases the willingness to pay for 
products  with  origin  claims,  but  also  for  packages  with  quality  claims,  3rd  party/self-
declared sustainability claims and even packages without claims. 

The lack of effects on consumers’ behaviour suggest that consumers may either not fully 
grasp the meaning of voluntary claims or do not trust the information sufficiently to find it 
relevant for the factors they find important. 

44 

 
 
 
 
 
 
Summary of key findings: 

Results  from  two  online  experiments  conducted  with  consumers  in  eight  EU  countries 
suggest that the presence of a voluntary claim on an FAP may have little effect 
on  consumers’  decisions.  Both  purchase  intention  and  willingness  to  pay  were 
relatively unaffected by the presence of a single voluntary claim regardless of the type 
of  claim  or  the  message  of  the  claim.  The  exception  was  frozen  cod  products.  The 
presence (relative to the absence) of a third party or self-declared claim on frozen cod 
products caused a higher willingness to pay. 

The perceived type of voluntary claim (i.e. do consumers think a claim is a third party 
or self-declared or other claims) may also affect consumer behaviour. After all, consumer 
may not always be able to distinguish between the different types of claims (see section 
7.1).  However,  the  results  find  that  purchase  intention is  only  marginally  significantly 
higher  when  consumers  believed  a  claim  to  be  a  third-party  claim  than  when  they 
thought  the  claim  was  self-declared  and  other  comparisons  were  not  significant.  Nor 
were there any significant differences in the willingness to pay.  

It could also be argued that it is not the type of claim that drives consumer behaviour, 
but rather the ‘message’ of the claim, i.e. the specific policy area a claim covers (e.g. 
sustainability, quality or origin), that influences consumers. However, the evidence from 
the behavioural experiments does not support this conclusion and consumers’ purchase 
intention and willingness to pay was unaffected by the policy area represented by the 
claim.  

Furthermore, the presence of concurrent claims appears to act as cues of quality 
towards  consumers.  The  results  from  the  behavioural  experiment  2  illustrate  that 
consumers are willing to pay a bonus price for products that carry a third-party certified 
claim in conjunction with other voluntary claims.  

The evidence points more towards the perceived credibility of voluntary claims 
as  driving  purchasing  and  willingness  to  pay  decisions  amongst  consumers 
rather than the ‘type’ of claim it is or even the message it conveys. Despite the impact 
of  perceived  credibility,  consumers  often  seem  unaware  of  the  actual  credibility  of 
different types of claims. 

Consumers also indicated the factors that they find important when purchasing FAPs. It 
might be expected that those who find certain issues to be important would be driven to 
purchase products or pay a bonus price for products carrying messages that attribute to 
the  FAP  those  characteristics  that  consumers  find  important.  However,  the  current 
results  do  not  support  this  hypothesis.  For  example,  respondents  who  attach  more 
importance to sustainability were not more likely to purchase a FAP with a sustainability 
label. 

45 

 
 
 
 
5  Consumer understanding, confusion and trust 

As  highlighted  in  the  previous  chapter,  the  results  from  the  behavioural  experiment 
illustrate that consumers are not more or less likely to purchase or pay a premium price 
for FAPs with a certain ‘type’ of voluntary claim. This chapter aims to provide insights into 
why  voluntary  claims  may  not  have  the  expected  effect  on  consumers.  Concretely,  this 
chapter focuses on the following questions:  

  Can consumers distinguish between different types of voluntary claims? 

  What is consumer knowledge about food labelling? 

  What is the impact of voluntary claims on consumers’ perception of a product? Do 

claims therefore correspond to consumers’ expectation? 

5.1  Consumer understanding of different ‘types’ of voluntary claims 

Consumers’ perception about the type of claim (3rd party, self-declared or other) on a fish 
package  may  affect  the  impact  of  this  claim  on  their  behaviour.  As  such,  the  current 
findings  show  that  when  consumers  thought  that  a  claim  was  certified  by  a  third  party, 
they perceived this claim as slightly more credible (M=4.59) than when they thought the 
claim was self-declared (M=4.56; p=.006) or  when they thought it was an ‘other’ claim 
(M=4.21; p < .001). Similarly, perceived credibility was also significantly higher when the 
claim was seen as self-declared than when it was seen as an ‘other’ claim (p < .001). Since 
perceived  credibility  of  a  claim  is  expected  to  have  a  profound  effect  on  consumer 
behaviour (section 6.1.2; the  role  of claim credibility), correct knowledge  of the type of 
voluntary claims seems important. 

Despite its potential effect on consumer behaviour, the findings of Experiment 1 suggest 
that  consumers  have  little  knowledge  of  the  type  of  claims.  Figure  19  shows  that  a 
significant  share  of  respondents  does  not  know  or  are  unsure  about  the  type  of  claim 
(between 31% and 50%) or have a wrong idea about the type of claim (between 31% and 
58%). In contrast, only a relatively small percentage of respondents were able to correctly 
classify the type of claim (between 11% and 32%). 

The  analysis  further  shows  that  consumers  were  more  likely  to  correctly  categorise  3rd 
party/self-declared claims than other claims and (28.5% vs. 16.2%; p < .001). Claim type 
knowledge  is  also  affected  by  the  policy  area  covered  by  the  claims.  Respondents  were 
significantly more successful in correctly categorising 3rd party/self-declared sustainability 
and  quality  claims  (compared  to  all  other  claims).  Knowledge  was  particularly  low  for 
‘other’ sustainability (11%) and quality claims (15%). 

Figure 19 

Correct knowledge of the type of claim  

other sustainability claim

31%

58%

11%

other quality claim

50%

36%

15%

other origin claim

3rd party/self-declared sustainability claim

3rd party/self-declared quality claim

3rd party/self-declared origin claim

41%

38%

34%

38%

36%

23%

31%

34%

32%

32%

42%

21%

Don't know /
not sure
Incorrect

Correct

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

46 

 
 
 
 
These findings are hardly surprising. Consumers’ familiarity with the claims32 used in the 
current  experiment  ranged  only  between  10%  and  36%.  Survey  results  from  different 
countries show that more than a third of shoppers recognise the blue MSC label (though 
awareness in countries like Germany is higher)33. Given that the MSC label is probably one 
of the most visible voluntary claims used in the EU, these results hint towards a rather low 
consumer awareness of different claims.  

The current findings reveal quite some uncertainty and confusion about the true nature of 
voluntary claims. The confusion might be related to different types of certification. Drawing 
on  the  inventory,  potential  sources  for  consumer  confusion  become  clear.  Figure  20 
presents  the  various  different  ‘Dolphin  safe’  claims  from  the  inventory  with  the  claim 
supported by the third-party Earth Island scheme on the left.  

Figure 20 

Examples of ‘Dolphin safe’ 

The sheer quantity of different claims that can cover the same policy area, which can also 
be visually very similar, may make it difficult for consumers to categorise them into the 
correct claim types. It could mean that consumers need to rely on design differences to 
assess a  claim’s credibility. This becomes  even more complicated when considering that 
the term ‘dolphin safe’ is not the only claim in relation to the welfare of dolphins. Dolphin 
welfare claims are also found in the form of claims like ‘Dolphin friendly’, ‘Dolphin friendly 
caught’  or  claims  with  a  more  personal  message,  like  ‘On  the  side  of  the  dolphins’  and 
‘Friends of the dolphins’. 

Figure 21 

Examples of Dolphin welfare claims 

32   Respondents were asked to indicate for each of the claims they have seen during the experimental session 

whether they had seen the claim earlier in real life (‘yes’, ‘no’, ‘not sure’) 

33   https://www.msc.org/documents/msc-brochures/annual-report-archive/annual-report-2016-17-english 

47 

 
 
 
 
                                                 
5.2  Consumer knowledge about food labels 

The findings of the current experiment show a significant correlation between the perceived 
type  of  claim  and  the  perceived  credibility  of  the  claim  (see  section  7.1):  perceived 
credibility is higher when a claim is thought to be certified by a 3rd party,  compared to 
self-declared claims or other claims. In addition, perceived credibility of voluntary claims 
is an important driver of consumer behaviour. The question then is why the perceived type 
of claim has no effect on consumer behaviour (section 6.1.1).  

The  findings  on  consumers’  knowledge  regarding  food  labels  provide  a  possible 
explanation.  Assessed  by  six  quiz  questions,  the  behavioural  experiment  shows  that 
consumers’  knowledge  about  claims  and  food  labels  is  rather  low.  Table  4  shows  that 
consumers knew only the correct answers for about one third of the questions (36.5%). 
For  example,  29.5%  of  consumers  falsely  believes  that  labels  are  always  certified  by 
independent  (3rd  party)  organisations.  This  indicates  that  consumers  lack  in-depth 
knowledge about how claims are issued and about what it takes for a product to be labelled 
this  way.  Given  that  consumers  cannot  clearly  distinguish  between  types  of  claims  (see 
section 6.1) and lack knowledge about food labels and claims, they are most likely to rely 
on the face value of claims. 

 Table 4 
questions 

Respondents’  evaluation  of  the  ‘knowledge  about  food  labels’  quiz 

Labels are always certified by independent (3rd party) 
organisations. 
Food producers and/or retailers can create their own 
labels, based on their own criteria. 
Producers of fish or seafood need to meet all the 
requirements of a label to get certified. 
In order to be labelled as ‘organic’, the production of 
food has to comply with specific legal requirements. 
A food product can only have a label from an 
independent (3rd party) organisation if all companies 
involved in producing, processing and transporting 
the food are certified. 
A label can cover several issues (for example, one 
label indicating both animal welfare and 
environmental sustainability). 

True 

False 

Don't know 

29.5% 

29.1% 

41.4% 

40.4% 

23.0% 

36.6% 

61.1% 

9.4% 

29.5% 

72.1% 

8.4% 

19.5% 

43.5% 

14.5% 

42.0% 

53.3% 

9.4% 

37.3% 

Total 

Correct 
answers 
36.5% 

False 
answers 
29.2% 

Don’t know 

34.4% 

Note: numbers in bold correspond with the correct answer to the respective quiz question 

5.3  Consumer  perceptions  of  FAPs  with  voluntary  claims  –  Are  consumers 
confused about the message voluntary claims carry?  

The inventory highlights that some voluntary  claims carry multiple messages that cover 
more  than  one  policy  area  without  a  single  predominant  specific  policy  area.  This  is 
primarily an issue for third-party or self-declared claims that cover multiple policy areas 
without a clear ‘main’ policy area that is identifiable. An example, as described in the in-
depth  legal  analysis,  is  the  ‘Pacifical  wild  tuna’  scheme,  which  is  related  to  both 
sustainability and origin. Therefore, some  voluntary  claims, particularly those supported 
by third-party and self-declared claims carry multiple messages towards consumers, which 
could lead to consumer confusion.  

The inventory also highlights the risk that consumers may not have a clear understanding 
of what the message of the claim is. This manifests itself in two ways. As mentioned in the 
section presenting the overview of voluntary claims (section 2.2), the vast majority of self-
declared claims are those that are in reference to a third-party scheme logo that appears 

48 

 
 
 
 
 
 
 
 
on the packaging. Experiment 2 illustrates that concurrent claims have a positive effect on 
consumers purchasing decisions (in terms of a higher willingness to pay when claims are 
concurrent  with  the  third-party  scheme),  which  could  be  an  explanation  as  to  why  this 
practice  exists.  Whilst it  was  not  in  the  scope  of  this  study  to  identify  why  this  practice 
occurs, it may be that concurrent claims serve as a cue of overall quality in the mind of 
the  consumer  (including  also  other  aspects,  such  as  nutrition  and  sustainability),  which 
may have an additive effect in influencing their choice.  

However, while the current findings show that concurrent claims slightly increased quality 
perceptions,  which  was  the  main  message  of  the  focal  claim,  other  perceptions  such  as 
sustainability perceptions, were still higher. This further suggests that consumers may not 
fully grasp the message.  

While  further  research  is  needed  to  really  understand  the  working  of  multiple  related 
claims, the results of Experiment 2 suggest that consumers found the information on FAP 
packages with concurrent claims easier to understand.  

Drawing  on  both  the  results  of  the  behavioural  experiments  and  the  assessment  of 
voluntary  claims,  this  chapter  takes  a  closer  look  at  consumers’  confusion  about  the 
message that voluntary claims carry.  

5.3.1  Consumer perception of the message of voluntary claims 

The behavioural experiments tested whether claims evoke product perception that expands 
beyond the characteristics covered by the claim. The results of Experiments 1 and 2 show 
that  claims  often  fail  to  communicate  their  meaning  or  even  cause  confusion  among 
consumers.  

The analysis of Experiment 1 shows that, compared to FAPS without claims, sustainability 
claims  significantly  increased  respondents’  sustainability  perceptions  of  the  product 
(M=4.70 vs. M=4.27; p<.001). However, sustainability did not only increase sustainability 
perceptions, but also perceptions unrelated to the claims (Figure 22). As such, FAPs with 
sustainability  claims  also  evoked  stronger  perceptions  of  socially  responsible  production 
(p=.001), traceability (p=.008) and high quality (p=.036). 

Figure 22 

The effect of sustainability claims on product perceptions 

Healthy

Prepared under controlled (hygienic) conditions

Free from additives

Sustainably sourced / environmentally friendly

Produced in a socially responsible way (fair trade)

Traceable (from the water to the shop)

High in nutrient

Tasty

Of high quality

1 €

2 €

3 €

4 €

No claim (control)

Sustainability claim

5,01
5,11

4,58

4,72

4,42

4,60

4,27

4,20

4,70

*

4,52

*

4,20

4,46

*
4,88

5,01

4,89

5,00

4,64

4,83

*

5 €

6 €

7 €

While  sustainability  claims  increase  different  and  even  unrelated  product  perceptions, 
quality claims had no effect on the quality perceptions of the FAPs, as compared to the no 
claim condition or on any other, unrelated, product perception. Origin claims did increase 

49 

 
 
 
 
consumers’ traceability perceptions (M=4.44 vs. M=4.20; p<.001), hinting also towards 
consumers’ confusion between different, albeit somewhat related constructs.  

An interesting moderator for the current results is perceived claim credibility. It is likely 
that  consumers  understand  the  voluntary  claims,  but  do  not  adjust  their  product 
perceptions, because they do not think the claim is credible. The findings of Experiment 1 
show, however, that perceived claim credibility increases all measured product perceptions 
(e.g. healthy, tasty, traceable, etc.), irrespective of the claim presented on the FAP.  

Consumer  confusion  is  further  illustrated  by  the  finding  that  when  credibility  is  low, 
sustainability  claims  increase  sustainability  perceptions  (compared  to  quality  and  origin 
claims),  while  the  difference  between  the  policy  areas  disappears  when  claims  are 
perceived as credible. 

What about when multiple concurrent claims also appear on the packaging? The second 
experiment shows the  effect of  quality claims in the presence  of concurrent claims (see 
section 6.1.3 for an overview of the concurrent claims). The findings reveal a small positive 
effect of concurrent claims on the quality perception of the FAP. This suggests that even 
claims not directly related to quality can contribute to the consumers’ quality perceptions. 
The findings also showed small positive effects on nutrition perceptions (which is likely in 
relation  to  the  ‘omega  3’  concurrent  claim)  and  the  sustainability  perceptions  of  the 
product. 

The  result  that  there  was  no  positive  association  in  quality  perceptions  in  experiment  1 
when consumers were presented with a quality claim, but that when the quality claim in 
experiment  2  was  accompanied  by  concurrent  claims  there  was  a  small  positive  effect, 
could  be  due  to  a  number  of  factors.  For  example,  it  could  be  due  to  differences  in  the 
design/presentation  of  the  quality  claims  between  the  two  experiments.  It  could  also 
suggest  that  quality  claims  alone  may  not  increase  consumers’  quality  perceptions  of  a 
product, but when a quality claim is accompanied by other claims this raises overall quality 
perceptions  amongst  consumers.  Further  experimental  research  that  holds  constant  the 
type of claim in comparison to both a no-claim condition and a concurrent claim condition 
would shed further light into this issue.  

Looking at the role of the importance that consumers attach to product factors on 
the effect of voluntary claims on product perceptions may provide further insights into the 
degree  of  consumer  confusion.  The  findings  show  that  the  perceived  importance  of 
sustainability as a factor when buying FAPs has a positive effect on the perception of FAPs 
as  sustainable.  More  importantly,  this  effect  was  stronger  for  FAPs  with  sustainability 
claims than FAPs with no claim. This effect was, however, not found for all claims. Perceived 
importance  of  quality  increased  the  quality  perceptions  for  FAPs,  irrespective  of  the 
presence  of  a  quality  claim.  The  results  suggest  that  purchase  factor  importance  can 
increase  consumers’  understanding  of  a  voluntary  claim.  However,  this  may  be  claim-
dependent. 

50 

 
 
 
 
Figure 23 

The effect of purchase factors on the effect of product perceptions 

7

6

5

4

3

2

1

5,11

5,16

4,56

4,04

4,05

4,98

5,06

4,95

4,53

4,54

4,42

4,32

Low importance of
sustainability/quality

High importance of
sustainability/quality

Other claim 3rd/sd claim No claim Other claim 3rd/ sd claim No claim

Sustainability perceptions

Quality perceptions

Given that the experiments suggest that consumers can have perceptions that the claim is 
carrying  messages  beyond  what  the  claim  states,  this  is  of  concern.  Whilst  these 
perceptions did not affect consumers purchasing decisions or willingness to pay for a FAP 
in the current experiment, they can lead to consumers believing that when they buy FAPs 
with certain claims, this means that the product has attributes it does not possess. In fact, 
if consumers were aware of what the claims are actually stating and not stating, they may 
make other decisions.  

Further experimental research could investigate how consumers purchasing decisions and 
willingness to pay are affected when presented products with claims with no accompanying 
explanation  in  comparison  to  presenting  claims  with  further  details  about  the  actual 
message  of  the  claim. This  could  provide  further  evidence  on  whether  consumers  make 
different purchase decisions if they understood what messages claims are actually carrying 
and the boundaries of those claims in terms of what they say.  

5.3.2  Reasons for consumer confusion 

A  better  understanding  of  consumer  confusion  regarding  claims  is  important.  Confusion 
can hinder the effect of important claims on consumer behaviour or cause misinterpretation 
of the claim.  

Consumers’  confusion  regarding  the  meaning  of  a  claim  can  come  from  two  different 
sources. First, consumers may find the meaning of claims ambiguous. Second, consumers 
may lack knowledge about the constructs covered by claims. 

5.3.2.1  Claim ambiguity 

A  likely  cause  for  the  effect  of  specific  claims  on  different,  sometimes  even  unrelated, 
product perceptions may be explained by the ambiguity of claims. As such, claims may not 
always succeed in communicating a clear message, leaving it to the consumer to (falsely) 
interpret the meaning of a claim based on its design and their own association.  

The current study also included an assessment of voluntary claims in terms of clarity 
and ambiguity. The findings for over 700 claims showed that, while the majority of claims 
seems to be rather clear and unambiguous, there is still a noticeable share of claims with 
problems.  Many  claims,  mostly  self-declared  and  ‘other’,  were  evaluated  as  ambiguous 
(before being checked whether they could verified through information available on-line). 
While consumers can find information regarding the real meaning of these claims on the 
brand, product or claim websites in the case of self-declared claims, this poses a problem. 
Consumers  often  use  the  claims  at  the  point-of-purchase,  without  the  ability  and/or 
willingness to look up claim information (if available at all). 

51 

 
 
 
Furthermore, there was no evidence found via desk research in relation to the availability 
of any comparison tools for consumers to be able to look up what a specific claim means, 
especially in relation/comparison to other similar claims.  

One source of claim ambiguity in the consumer assessment were claims relating to multiple 
standards and/or multiple criteria (e.g. food safety, food quality). In such cases, consumers 
would benefit from having the relevant principle criteria listed on the claim. For example, 
schemes  related  to  one  policy  area  –  such  as  social  responsibility  -  were  often  hidden 
behind claims that appear to represent another policy area. This is illustrated by the Rio 
Mare’s Pole and Line claim, which at face value was perceived to be related to fishing gear 
only,  and  Fish  Tales’  heroes  range,  which  was  interpreted  to  be  related  to  origin 
information. This represents a lost opportunity for such products to advertise their added 
value  over  other  products,  and  to  increase  consumer  awareness  of  social  responsibility 
issues. Given that the behavioural experiments demonstrate that multiple claims increased 
the perceived quality of a product, companies may also increase the perceived quality of 
their  product  by  being  more  explicit  about  the  multiple  policy  areas  that  their  claim 
represents (where this is verifiable).  

5.3.2.2  Lack of consumer knowledge regarding policy areas 

Multiple  studies  suggest  that  consumers  may  lack  sufficient  knowledge  regarding  the 
constructs and policy areas covered by claims.  

A study by Norge amongst French consumers about the French and seafood34 found that 
when consumers gave their opinion on farmed, wild and organic fish, organic fish was seen 
as the most environmentally friendly, healthier, more animal friendly and safer to eat than 
both wild and farmed fish. Farmed fish only outweighed wild and organic fish in relation to 
being better value for money and being more risky in terms of extensive use of antibiotics 
and hormones in production than wild and organic fish. Another study by OrAqua35 found 
that 19-27% of consumers confuse organic fish with wild fish.  

The importance of this lack of knowledge between these related concepts becomes even 
more apparent when looking at a recent Eurobarometer on EU Consumer habits regarding 
fishery  and  aquaculture  products36.  The  findings  of  this  study  show  that  a  majority  of 
consumers  prefer  wild  products  (34%)  in  comparison  to  farmed  products  (8%;  a  large 
proportion (31%) have  no preference) and almost three-quarters  of  respondents (73%) 
think the distinction between a wild or a farmed product is important on labels of fresh, 
frozen, smoked and dried products and 55% in the case of tinned or prepared products. 
Even though only 14% said they do not know if the FAPs they buy or eat are wild or farmed, 
the  findings  of  the  previous  study  suggest  that  in  reality  this  percentage  may  be  much 
higher if consumers are unaware of what constitutes farmed fish.  

In other cases, consumers may associate that claim with not only being how the tuna was 
caught but believe this is a sustainable practice, which may not be the case. For example, 
discussions around the boundaries of dolphin safe claims have also been in the discourse 
given that some consumers may also associate these types  of  claims with sustainability 
when they are limited to the specific issue of dolphin safe fishing practices.  

34   SEAFOOD 

AND 
https://seafood.no/contentassets/6b8fa7b9742b4b0d9b2cc4a8d87af7a5/french-seafood-study.pdf  

INSIGHTS 

OUTLOOK 

FRENCH 

STUDY 

2016 

THE 

& 

: 

SEAFOOD 

35   https://www.oraqua.eu/content/download/110528/1547961/file/Perception+understanding.pdf?version=1 

36   Special  Eurobarometer  450-  June  2016  “EU  consumer  habits  regarding  fishery  and  aquaculture  products” 

http://ec.europa.eu/COMMFrontOffice/publicopinion/index.cfm/Survey/getSurveyDetail/instruments/SPECIA
L/surveyKy/2106 

52 

 
 
 
 
                                                 
Summary of key findings: 

One  potential  source  of  confusion  for  consumers  is  the  difficulty  in  distinguishing 
between different types of voluntary claims. The findings of the experiments show that 
when consumers thought that a claim was certified by a third party, they also perceived 
this claim as more credible. This is relevant, given the potential effects of credibility on 
consumer behaviour (see section 6.1.2). However, despite the effect of 3rd party claims 
on  perceived  credibility,  experiment  1  shows  that  consumers  have  only  very  little 
knowledge of the correct type of claim. Most consumers do not know, are unsure or even 
have the wrong idea about whether a voluntary claim is certified by a third party, self-
declared or a simple allegation. 

Consumers’ lack of understanding about voluntary claims on FAPs is further illustrated 
by the experiments’ findings regarding consumers’ knowledge about how food labels are 
certified and about what is necessary for a product to obtain a certain label. Respondents 
only answered about one third of food label-related questions correctly. 

Another potential source of confusion for consumers is the perception of what message 
is actually associated with voluntary claims. Drawing on insights from the inventory, the 
behavioural experiments and an assessment of the  clarity and ambiguity of voluntary 
claims indicates at least some confusion for consumers. 

The inventory shows that voluntary claims often carry multiple messages, with the ‘main’ 
policy  area  difficult  to  identify.  This  makes  it  hard  for  consumers  to  understand  what 
message  the  claim  tries  to  communicate.  The  inventory  also  shows  that  self-declared 
claims are often used in reference to a third-party scheme logo on the packaging. It is 
possible  that  producers  include  additional  claims  or  logos  on  packages  because  the 
meaning of claims is often confusing for consumers. 

The findings of the behavioural experiment also suggest that the meaning of claims is 
not always clear for consumers. As such, the findings show that sustainability claims also 
increase  other,  somewhat  unrelated,  product  perceptions,  including  perceptions  of 
socially responsible production, traceability and high quality. In contrast, quality claims 
failed to increase the quality perceptions of the FAPs at all. In addition, consumers may 
also  be  confused  between  related,  yet  different  constructs,  such  as  origin  and 
traceability. The findings of the  experiment also show that perceived claim credibility, 
the  presence  of  concurrent  claims  and  the  product  factors  consumers  find  important 
when buying FAPs have only mixed effects on the consumers’ correct understanding of 
the claim message. 

Consumers’  confusion  with  a  claim’s  meaning  can  be  caused  by  two  factors.  First,  an 
assessment of the clarity and ambiguity of voluntary claims highlighted that a noticeable 
share of claims, most of them self-declared and other voluntary claims, were evaluated 
as ambiguous, before they could be verified through information on the claim’s website 
(when available). This is particularly relevant, given that consumers are unlikely to look 
up claim information at the point-of-purchase and, therefore, need to rely on the design 
aspects of the claim. 

Second,  drawing  on  existing  literature  shows  that  consumers  often  lack  detailed 
knowledge about what the different constructs and policy areas covered by claims mean. 

53 

 
 
 
 
6  Requirements for FAPs and a consumer perspective on 
the  extent  to  which  they  are  clear,  unambiguous, 
verifiable, not misleading and have added value  

What are the requirements that voluntary claims have to comply with and who is in control? 
Claims  on  FAPs  are  subject  to  a  number  of  regulations.  First,  there  are  very  general 
prohibitions  on  deceiving  the  consumer  and  providing  inadequate  information  to  the 
consumers in the UCPD. Next to this, the prohibition on misleading the consumer and on 
ensuring adequate information is repeated in the food legislation (General Food Law, Food 
Information  to  Consumers  Regulation)  that  creates  specific  duties  on  food  business 
operators. FAPs information provision is additionally regulated in the CMO Regulation. Next 
to  these,  the  Commission  has  drawn  up  recommended  criteria  that  address  formal 
voluntary food schemes. Taken together, these regulations point to the need for claims to 
be  clear,  unambiguous,  not  misleading  (i.e.,  not  false),  and  verifiable.  At  international 
level,  on  the  other  hand,  eco-labelling  in  FAPs  has  received  the  widest  attention  and  a 
number of best practices have been developed in this vein.   

Compliance is understood as two different concepts by the stakeholders37 consulted for the 
purposes of this study. On the one hand, stakeholders interpret  compliance as the rules 
and regulations of the EU regarding labelling or the national laws that relate to FAPs. On 
the  other  hand,  stakeholders  often  also  interpret  compliance  as  the  adhering  to  the 
requirements of a certain certified voluntary scheme in order to place their logo on a FAP. 

Compliance  control  is  the  activity  of  assessing  whether  standard  users  fulfil  standard 
requirements.  Within  private  standard  setting,  it  is  important  to  distinguish  standard-
setting, certification, and accreditation activities.38 Certification guarantees compliance with 
standards; third-party certification guarantees independence. Certifiers are private parties, 
while accreditation bodies are very often public or quasi-public.39 

Voluntary claims that are supported by a certification scheme are commonly ‘controlled’ 
by the mechanisms of the scheme. The goal of certification is to signal to both business-
to-business and to consumers compliance with an agreed set of standards. Governments 
can  be  involved  in  ensuring  a  credible  system  by  accrediting  (and  thus  ‘controlling’) 
certifiers. However, certification bodies do not have to be accredited.  

Whilst certification and accreditation mechanisms could be viewed as ‘controlling’ voluntary 
claims that are certified, neither certification nor accreditation is compulsory 40 for voluntary 
claims on FAPs (or food products in general). Other than the voluntary EU food schemes 
of organic and PDO/PGI/TSG Quality Schemes, voluntary claims on FAPs  are not legally 
‘controlled’, resulting in diversity in how voluntary claims are controlled depending on the 
rigour of the scheme and certification processes as well as leading to claims that do not 
include such scheme controls (i.e. ‘other’ voluntary claims).  

Therefore,  in  labelling  of  FAPs,  important  differences  exist  with  respect  to  control  and 
verifiability.  

37   Stakeholders were posed an open question if they were aware of any regulations and requirements as regards 
the clarity, verifiability, non-ambiguity and truthfulness of voluntary claims on fish product. Answers varied 
considerably. 

38   H. Schebesta, 'Control in the Label - Self-Declared, Certified, Accredited? On-Pack Consumer Communication 
about Compliance Control in Voluntary Food Schemes from a Legal Perspective' in P. Rott (ed.) Certification 
–  Trust,  Accountability,  Liability?  (Springer,  2018,  Forthcoming)  Wageningen  Working  Papers  in  Law  and 
Governance 
at 
SSRN: https://ssrn.com/abstract=2988761. 

GOVERNANCE 

2017/04. 

Available 

GROUP 

LAW 

AND 

39   Loconto and Busch (Loconto, A., & Busch, L. (2010). Standards, techno-economic networks, and playing 

fields: Performing the global market economy. Review of International Political Economy, 17(3), 507-536. ) 
p.510 note that 75% of their data set qualified as public or quasi-public. 

40   Although the EU Organic Scheme and PDO/PGI Quality Schemes do have specific control requirements 

54 

 
                                                 
In  terms  of  environmental  claims,  arguably,  ISO  has  developed  the  most  relevant 
classification  of  (environmental)  ecolabels  in  the  literature.  There  are  three  types  of 
ecolabels:  Type  I  ecolabels  are  based  on  voluntary  multi-criteria  product  life-cycle 
assessment  of  environmental  effects  with  verification  through  a  third  party.  (While  ISO 
classification call for product life-cycle assessments, in fisheries there are examples of so-
called  single  issue  labels  such  as  “dolphin-safe’).  Type  II  ecolabels  are  based  on  self-
declared  environmental  claims  by  producers,  importers  and  retailers  on  products  and 
services.  Type  III  ecolabels  provide  quantified  product  information  according  to  pre-set 
indices, similar to general consumer information on product packages. 

In  terms  of  whether  claims  are  clear  and  unambiguous  (as  provided  for  by  the  legal 
framework) stakeholders (producers and retailers) are often of the opinion that third-party 
schemes  are  clear  in  their  message  (i.e.  the  actual  claims  are  clear  for  consumers). 41 
Nevertheless, there is an indication from some stakeholders that detailed information about 
the  schemes  is  not  always  available  to  consumers.  Commonly  information  is  available 
online, but not in all cases, and in some cases consumers have to request it. Given that 
this is the case for third-party certification schemes, it is even more problematic for ‘self-
declared’ and ‘other’ claims, as also found during the building of the inventory of claims.  

Comprehensive  evidence  of  control  related  to  voluntary  claims  in  terms  of  consumer 
protection was not identified during the course of this study. Nevertheless, one consumer 
watchdog who participated in the stakeholder consultation received complaints regarding 
confusing,  unclear,  misleading  or  unverifiable  information.  The  consumer  protection 
authority who participated in this study mentioned it had received complaints regarding 
voluntary  claims  on  FAPs  that  were  linked  to  ambiguous  or  unclear  claims,  and  even 
untruthful claims.  

Transparency – open quotes: 

  Differentiation between the standards can be confusing and unclear to the consumer 

(consumer protection authority) 

  Voluntary information could be hardly comprehensive for some consumers, who are 

not always familiar with fish products and marine fish production (consumer 
watchdog) 

As part of this study, an assessment of the  voluntary claims that appear on FAPs in the 
EU28 (based on the inventory of voluntary claims built for the purpose of this study) was 
carried  out  from  the  consumer’s  perspective.  Each  claim  was  assessed  according  to 
whether  it  was  clear,  unambiguous,  verifiable,  not  misleading,  and  whether  it  provided 
added value. Here we present the results of this consumer assessment of voluntary claims 
to paint the broad picture of the extent to which claims may be problematic.  

6.1  Assessment of voluntary claims on FAPs 

 An assessment of all claims from the inventory was carried out in order to examine the 
extent to which the claims were clear, unambiguous, verifiable, had added value and were 
true (i.e. not misleading). This addresses the research questions of:  

a)  To  what  extent  to  the  inventoried  claims  comply  with  these  legal  and  non-binding 
requirements,  

b)  What  is  the  higher  value  provided  to  consumers  by  the  specific  features  or 
characteristics presented in the claims, 

41   Producers, importers and retailers were posed the question to what extent they agreed with the statement 
that  “The  information  that  the  schemes  provide  to  the  consumer  is  clear  and  unambiguous.”  3  out  of  6 
producers and 3 out of 5 retailers agreed with this statement (others did not have a strong opinion, but did 
not disagree with the statement). Only the importer did not agree with this statement. 

55 

 
 
 
                                                 
c)  Are there differences in compliance/performance between the different policy areas?  

d) Do voluntary claims serve as best practices and why?  

6.1.1 

Protocol for the assessment 

Each claim was assessed according to whether it was clear, unambiguous, verifiable, and 
whether it provided added value (see below for further details). The characteristics of the 
operational context were: 

  The average consumer  is native to the country that corresponds to the language 

used on the product. 

  We assume that the product displays mandatory information). 

  The  claim  will  be  assessed  in  the  context  of  other  information  –  including  other 

claims – featured on the product. 

  The average consumer is able to look for off-package information on the product. 

  For claims specific to dietary restrictions (e.g. gluten free/kosher), we assumed the 
perspective  of  the  average  target  consumer  (e.g.,  those  who  are  intolerant  to 
gluten/follow a kosher diet).  

Only one product representing each claim was selected, as this was done by selecting the 
claim  that  appeared  to  have  the  greatest  market  visibility  from  the  consumer’s  point  of 
view  (i.e.,  what  was  considered  to  be  the  most  ‘popular’  brand  that  most  people  would 
buy). It should be noted that while all claims assessed in the inventory apply to voluntary 
information,  in  some  cases  the  same  claim  would  be  considered  to  be  mandatory 
information if found on another type of FAP. For example, information about the type of 
fishing  gear  used  is  mandatory  for  unprocessed  and  lightly  processed  products  (e.g., 
frozen,  salted,  dried  or  smoked  FAPs,  shrimps  cooked  in  their  shells),  but  voluntary  for 
canned and processed FAPs (e.g., composite products, breaded products, etc.). 

The  criteria  of  the  claims  were  assessed  independently  of  each  other,  rather  than  as  a 
cumulative process. The assessment was conducted based on information available on the 
product (or off-package information in the case of verifiability).  The criteria of ‘clear’ and 
‘unambiguous’ were assessed from the perspective of the average consumer.  The criteria 
of ‘verifiability’ and ‘added value’ were assessed from a legal perspective. The criteria of 
misleading was assessed by considering whether the  claim was true  or not. The criteria 
were assessed in the following order: 

1) Clear (Is the message of the claim easy to understand?)  

In other words, is it possible for an average consumer to understand the message of the 
claim without great effort/difficulty. In concrete terms, this means that the text and/or the 
picture are understandable and do not contain unknown words/terms or designs.  

“At first glance I understand the claim.”  

A claim is considered to be unclear if it fulfils any of the following conditions:   

a)  it refers to the name of a scheme, organisation, etc., without descriptive information 
that  would  clarify  the  meaning  of  the  claim  –e  g.  HACCP  Certification,  Charte 
D’Excellence; 

b)  it  refers  to  very  domain  specific  information  about  a  product  that  is  beyond  the 
knowledge of the average consumer  – e.g. From Almadraba, Farmed in basins in 
Marennes Oléron, Quick Frozen; 

c)  it attributes inappropriate characteristics to an aspect of the product. This includes 
quantifying  a  non-quantifiable  aspect  of  the  product  (e.g.,  100%  flavour),  or 
claiming a relationship between unrelated characteristics (e.g., tasteful, that’s how 
organic tastes).  

56 

 
 
 
2) Unambiguous (Is the message unambiguous?) 

Will each consumer interpret the claim from the same perspective or is it open to multiple 
interpretations that mean conceptually different things? Is the content or the message of 
the  claim  consistent  for  all  (average)  consumers?  When  a  claim  is  associated  with  a 
scheme, related online information can be used on disambiguate the claim.  

“I understand what the claim is telling me".   

A claim is considered to be ambiguous if it fulfils any of the following conditions: 

d)  it has multiple meanings from the consumers point of view– e.g., “Eat well” could 
mean that the product allows the consumer to eat well, or that consumers should 
eat well. Also, the meaning of “eat well” is not entirely clear, as it could refer to 
health, environmental, and/or social considerations. 

e)  it is too vague for consumers to know what aspect of the product the claim refers 

to – e.g., “Controlled quality” could refer to food safety, animal welfare, or 
product quality. 
it makes a claim involving a comparison without specifying the reference of 
comparison  - e.g., 25% less salt  

f) 

In  some  cases  a  claim  may  be  considered  to  be  ambiguous  at  face  value,  but  can  be 
disambiguated with information from the target product/scheme website. In such cases, 
the claim is no longer considered to be ambiguous. 

3) Verifiable (Is the content verifiable?)  

This  pertains  to  whether  the  claim  is  theoretically  verifiable  or  not  –  i.e.,  would  it  be 
possible for a control authority to check the claim? Some avenues of verification include: 

a)  If a claim is associated with a 3rd party (e.g., certification body, health 

organisation), then the relevant 3rd party may be contacted to verify the claim 
b)  The FAP can be physically inspected to assess whether it conforms to the claim 

(e.g., the claim of ‚skinless and boneless‘) 

Further information about the verifiability assessment according to policy area can be found 
in Table 28. 

Claims  that  cannot  be  verified  often  pertain  to  the  subjective  qualities  of  the  product  – 
e.g., “100% taste”, “Best quality”. 

 “I can check if what the claim says is true or not”  

4) Added value (Does the claim provide added value to the product?) 

A claim is considered to have added value if:  

a)  It provides information beyond that which is provided by mandatory information 
on the packaging (e.g., allergen free claims do not have added value because 
they provide information that is consistent with mandatory listing of allergens), 
and 

b)  The information provided helps the consumer to differentiate the product from 

other FAPs.   

Further  information  about  the  added  value  assessment  according  to  policy  area  can  be 
found in Table 28. 

“This information is not redundant and I can use it to distinguish this product from other 
FAPs" 

57 

 
 
 
 
 
 
 
5) Misleading (Is the claim truthful?) 

Whether information communicated on a claim misleading or not is an open norm that is 
judged  on  a  case-by-case  basis  in  case-law.  Thus,  in  the  current  context  we  take  a 
conservative definition in assessing claims as misleading only if they are false – e.g., the 
claim  ‚suitable  for  vegetarians’.  This  definition  is  covered  by  Article  6(1)  of  the  UCPD, 
stating  that  "A  commercial  practice  shall  be  regarded  as  misleading  if  it    contains  false 
information and is therefore untruthful...“ Misleading claims do not have added value. 

58 

 
Table 28. Regulations related to the assessment of verifiability and added value, according to policy area 
Policy  area  related  to  the 
claim 
Allergen  (free)  claims  (other 
than  mandatory 
allergen 
information) 

Operationalisation of relevant criteria related to the 
legislation 
-  All  allergen  (free)  claims  are  considered  to  be 
verifiable,  as  they  can  be  checked  by  cross 
referencing with the list of ingredients on the product, 
which is provided as mandatory information.  

Policy specific legislation 

-  Mandatory information under the FIC that 
requires specific allergens to be declared 
-  Reg  828/2014  on  the  requirements  for 
the provision of information to consumers 
on  the  absence  or  reduced  presence  of 
gluten  in  food.  The  information  should 
“not  be  provided  on  a  divergent  basis 
which  could  mislead  or  confuse  the 
consumers.” 

Food safety  

Mandatory  information  in  the  General  Food 
Law (Reg 178/2002): 
- laying down Hygiene for Products of Animal 
Origin, SECTION II: OBJECTIVES OF HACCP-
BASED PROCEDURES, Annex III, Section VIII 
fishery products  
-  on  the  hygiene  of 

foodstuffs,  which 
specified that the food has to be processed 
and  controlled  according 
to  HACCP 
principles 

Health & Nutrition  

Reg 1924/2006; FIC regulation 

-  Such claims do not add value because the same info 
can be obtained from mandatory list of ingredients. 

-  Claims specifying food safety controls will be assessed 

in terms of their compliance with HACCP principles. 42 

-  Such claims are considered to be verifiable insofar as 
they must comply with Article 5 on providing evidence 
and  documentation  of  compliance  with  HACCP 
principles.  

-  Given  that  all  FAPs  must  comply  with  HACCP 
regulations,  claims  that  follow  HACCP  principles  are 
not considered to add value.  

-  Claims not related to HACCP principles will be assessed 
according to the general principles of verifiability and 
added value outlined above. 

- 

In  assessing  the  verifiability  of  nutritional  claims, 
Article 8 of Reg 1924/2006 will be taken into account 
– namely, if the claim is on the list of approved claims 

42   The HACCP principles consist of the following: (a) identifying any hazards that must be prevented, eliminated or reduced to acceptable levels; (b) identifying the critical control 
points at the step or steps at which control is essential to prevent or eliminate a hazard or to reduce it to acceptable levels; (c) establishing critical limits at critical control points 
which  separate  acceptability  from  unacceptability  for  the  prevention,  elimination  or  reduction  of  identified  hazards;  (d)  establishing  and  implementing  effective  monitoring 
procedures at critical control points; (e) establishing corrective actions when monitoring indicates that a critical control  point is not under control; (f) establishing procedures, 
which  shall  be  carried  out  regularly,  to  verify  that  the  measures  outlined  in  subparagraphs  (a)  to  (e)  are  working  effectively;  and  (g)  establishing  documents  and  records 
commensurate with the nature and size of the food business to demonstrate the effective application of the measures outlined in subparagraphs (a) to (f).  

59 

 
 
                                                 
in  the  Annex  of  the  regulation.  If  it  is  an  approved 
claim,  it  will  be  considered  to  be  verifiable  and  to 
add  value,  otherwise  the  general  principles  of 
verifiability and added value outlined above apply.  
-  Approved  nutrition  claims  are  considered  to  be 
verifiable  as  such  claims  must  be  supported  by 
mandatory  nutrition  information  available  on  the 
product, pursuant to the FIC regulation. 

-  Health  claims  are  considered  to  be  verifiable 
according to the guideline 17 of Reg 1924/2006 and 
Article  36(2)(c)  of  the  FIC  regulation,  which  state 
that all health claims must be supported by scientific 
evidence (e.g., that Omega 3 is good for the heart, 
for claims that make an association between Omega 
3 and the heart). If such claims have no supporting 
scientific  evidence  (e.g.,  “Break  speed  records  with 
this natural snack”), they are considered to have no 
added value. 

-  According to Article 11 of R 1924/2006 claims 

related to national associations of medical, nutrition 
or dietetic professionals and health-related charities 
are governed by relevant national rules rather than 
EU regulations. 

-  Such claims are not verifiable according to EU level 

regulations, but the consumer may verify the claim 
by contacting the implicated health organisation. 

-  Such claims related to a health organisation are 

considered to have added value. 

-  Claims  related  to  traceability  generally  provide 
consumers  with  a  way 
traceability 
information  related  to  the  FAP  (e.g.,  by  entering  a 
product code on a website.  Such information will be 
considered to be  verifiable.  This information is also 
considered to have added value.  

to  access 

-  Such  claims  are  verifiable  through  cross  reference 

with the ingredients list.  

60 

Traceability claims 

N/A 

Free from additives 

N/A 

 
Generic 
responsibility/Environmental 
responsibility/Sustainability 

Social responsibility claims 

N/A 

Animal  welfare  and  animal 
health claims 

N/A 

Religious dietary laws claims 

N/A 

Organic  production  methods 
claims 

-  Council  Regulation  (EC)  No  834/2007  of 
28 June 2007 on organic production and 
labelling  of  organic  products  and 
repealing  Regulation  (EEC)  No  2092/91 
(Organic Products Regulation). 

- 
The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 
- 
The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 
. 
The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 
These claims are all related to Kosher food products. The 
general criteria of verifiability and added value apply. 
-  Organic  claims  are  considered  to  be  verifiable 
according  to  guideline  31  of  Reg  834/2007,  which 
states  that  organic  claims  are  required  to  be 
submitted to a control system. 

-  Such claims are also considered to add value. 

- 

- 

rules 

detailed 

  Commission  Regulation 
(EC)  No 
710/2009  of  5  August  2009  amending 
Regulation  (EC)  No  889/2008  laying 
down 
the 
implementation  of  Council  Regulation 
(EC)  No  834/2007,  as  regards  laying 
organic 
down 
aquaculture 
seaweed 
production  (Commission  Regulation  on 
Organic 
and 
Seaweed Production). 

Aquaculture 

detailed 

Animal 

animal 

rules 

and 

for 

on 

  Commission  Regulation 
(EC)  No 
889/2008  of  5  September  2008  laying 
the 
down 
implementation  of  Council  Regulation 
(EC) No 834/2007 on organic production 
and  labelling  of  organic  products  with 

detailed 

rules 

for 

61 

 
 
 
 
regard  to  organic  production,  labelling 
and  control  (Commission  Regulation  on 
Organic 
and 
Control).  (‘Commission  Regulation  on 
Organic 
and 
Control’) 

Production, 

Production, 

Labelling 

Labelling 

Origin claims 

FIC (33): The Union’s non-preferential rules of 
origin  are  laid  down  in  Council  Regulation 
(EEC)  No  2913/92  of  12  October  1992 
establishing the Community Customs Code 
(OJ  L  302,  19.10.1992,  p.  1.  )  and  its 
implementing  provisions 
in  Commission 
Regulation (EEC) No 2454/93 of 2 July 1993 
laying down provisions for the implementation 
of  Council  Regulation  (EEC)  No  2913/92 
establishing the Community Customs Code 
(OJ L 253, 11.10.1993, p. 1.). Determination 
of the country of origin of foods will be based 
on those rules, which are well known to food 
business  operators  and  administrations  and 
should ease their implementation 

Production methods 

More  detailed  information  on 
fishing gear  

N/A 

Taste/product quality claims 

EU legislation on quality schemes - Regulates 
use of the PDO/PGI/TSG logo 

Composition 
boneless) 

claims 

(e.g. 

N/A 

The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 
- 

The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 

The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 

The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 
The  general  criteria  of  verifiability  and  added  value 
apply – i.e., the claims will be assessed on a case-by-case 
basis. 

62 

 
 
 
 
 
GMO-free  (Unclassified  policy 
area) 

(EC)  1830/2003 
Commission  Regulation 
concerning  the  traceability  and  labelling  of 
genetically  modified  organisms  and 
the 
traceability  of 
feed  products 
food  and 
produced from genetically modified organisms 

Given  that  the  relevant  regulation  requires  all  food 
products to label if they are associated with GMOs, claims 
related to GMO-free FAPs are considered not to add value 
because they  cannot be distinguished from FAPs that do 
not carry such claims. 

63 

 
6.2  Results 

6.2.1  Analysis by policy area 

6.2.1.1  Allergen 

There were very few allergen claims found on FAPs and they were all gluten-free claims. 
Such claims are typically related to FAPs containing other ingredients, such as breading or 
sauce, or which are otherwise ‘prepared’. Because the inventory only considers the claims 
relating to the FAP component of the product, it is unlikely that there will be many allergen 
claims related to this component. The claims that were found were on FAPS that would not 
be expected to contain gluten (e.g. smoked salmon or canned fish in olive oil). Although it 
may seem strange for such products to contain gluten-free claims, this may still have an 
added value for the consumer. This is also accepted in Recital 10 of Reg 828/2014, which 
considers that “It should also be possible for a food containing ingredients naturally free of 
gluten to bear terms indicating  the absence of gluten.”  

The  allergen  claims  were  all  clear,  unambiguous,  verifiable,  and  not  manifestly  false. 
Gluten-free claims may provide further reassurance to consumers that the risk of gluten 
cross-contamination is minimal for the FAP, so it could be seen as still being useful for the 
consumer.  

Good/bad practices for gluten-free claims 

According to the Reg 828/2014, a product may be referred to as being ‘gluten-free’ if it 
contains no more than 20 mg/kg of gluten, which has been established as a safe threshold 
of gluten for those with celiac disease.43 However, when a product still contains one of the 
cereals  mentioned  in  Annex  II  of  the  FIC,  this  ingredient  still  must  be  indicated    and  
emphasised  in    the    list    of  ingredients  in  accordance  with  Articles  9  and  21  of  the 
Regulation. One product from the inventory shows a ‘Gluten free’ crossed grain symbol, 
but  nevertheless  includes  ‘gluten’  in  bold  in  the  list  of  ingredients.  This  apparent 
inconsistency may be confusing for consumers who are unfamiliar with the conditions of 
Reg 828/2014. As such, it is recommended that in cases where a product that contains 
levels  of  gluten  that  are  under  the  regulatory  threshold,  further  information  is  provided 
next to the allergen claim or list of ingredients indicating that the product contains minimal 
levels of gluten. 

6.2.1.2  Food safety 

Most  claims in this policy area related to  HACCP food safety principles (e.g., ‘System of 
quality  and  food  security  -  ISO  9001).    Such  claims  were  often  supported  by  3rd-party 
certification (e.g., ‘IQ Net quality systems’), or had self-declared criteria on a website (e.g., 
‘HACCP  Certificate’).  Although  it  is  mandatory  for  all  food  operators  to  follow  HACCP 
guidelines, certification of such standards is not required. As such claims that refer only to 
HACCP guidelines do not have added value, whereas those that refer to the certification of 
a system that follows such guidelines do (e.g., ‘Q-food safe’, ‘Controlled for quality’). 

43   Catassi,  C.,  Fabiani,  E.,  Iacono,  G.,  D'agate,  C.,  Francavilla,  R.,  Biagi,  F.,  ...  &  Pianelli,  G.  (2007).  A 
prospective, double-blind, placebo-controlled trial to establish a safe gluten threshold for patients with celiac 
disease–. The American journal of clinical nutrition, 85(1), 160-166;  Gibert, A., Espadaler, M., Canela, M. A., 
Sanchez,  A.,  Vaque, C.,  & Rafecas,  M.  (2006).  Consumption  of gluten-free  products:  should  the  threshold 
value  for  trace  amounts  of  gluten  be  at  20,  100  or  200  ppm?.  European  journal  of  gastroenterology  & 
hepatology, 18(11), 1187-1195. 

64 

 
                                                 
From a consumer’s perspective, many of the claims relating to food safety systems were 
not clear, but they were often disambiguated with website information. 

Claims that provided added value were those that referred to a more specific part of food 
safety, such as ‘Hermetic packaging - guarantee of safety and hygiene of the product’, and 
‘Pasteurized’. 

All claims in this policy area are verifiable either through certification, documentation, or 
inspection of the packaging. None of the claims were manifestly false. 

Good/bad practices for food safety claims 

It  is  recommended  that  food  safety  claims  only  highlight  characteristics  that  are 
independent of HACCP guidelines – such as certification of a HACCP-conforming system - 
and that such characteristics are explicitly indicated on the claim. 

6.2.1.3  Health and Nutrition 

Claims in this policy area can be classified according to the following categories: 

  Low/reduced salt 
  Low/reduced fat 
  Sugar free 
  Low glycemic index – association with reducing diabetes 
  Healthy eating 
  Dieting 
  Omega 3/6/9 fatty acids (including simply ‘Omega 3’, ‘Source of Omega 3’, ‘Good 

source of Omega 3’, ‘High in Omega 3’, ‘Rich in Omega 3’) 

  Protein  (including  ‘Source  of  protein’,  ‘Good  source  of  protein’,  ‘High  protein 

content’, ‘Rich in protein’) 

  Vitamins/minerals 
  Heart health 
  National cardiologist associations 

Health  and  nutrition  claims  were  generally  clear,  unambiguous,  verifiable  via  package 
information (and scientific evidence in the case of health claims), and had added value for 
the consumer. Some claims could be ambiguous from a consumer’s point of view, although 
they are clearly framed under relevant EU regulations. However, the consumer may not be 
aware  of  the  regulations,  and  therefore  may  not  interpret  the  claims  accordingly.  This 
applies to: 

a)  Claims that referred to a reduction in salt/fat (e.g., ‘reduced salt’, ‘50% less fat’, ‘-
25%  salt’).  The  point  of  comparison  for  such  claims  were  not  made  clear  to  the 
consumer  –  for  example  whether  the  reduction  was  in  relation  to  a  previous 
formulation, or to similar FAPs.  

b)  Claims that described products as being a ‘source of [nutrient]’ or ‘high in [nutrient]. 
Although  the  level  of  nutrient  that  has  to  be  associated  with  such  claims  are 
indicated in Reg 1924/2006, most consumers are not aware of these criteria, and 
therefore may not make a distinction between these two types of claims.  

One way to avoid the ambiguity associated with such nutritional would be to indicate the 
exact level of a nutrient on the claim, such as claims that specified ‘only 2.6% fat’, ‘60% 
protein’, ‘Collagen 30%’.  

65 

 
A subset of claims were associated with health campaigns or associations (such as “Stop 
diabetes glycemic index <50”, “Spanish Foundation for the Heart”, and “Recommended by 
the foundation of cardiac surgery”). Such claims are allowed under EU rules, and their use 
can  be  regulated  at  national  level.  These  claims  indicate  that  the  FAP  is  approved  by  a 
campaign/association,  which  the  consumer  can  verify  by  contacting  the  relevant 
organisation. Only one association (Sydanmarkki, represented by the heart symbol claim) 
had information about approved products listed on their website, and the criteria used to 
select the products, which serves to exemplify the best practice for such types of claims.  

Another  best  practice  is  to  indicate  the  benefit  of  a  particular  nutrient  on  a  claim, 
particularly  for  lesser  known  nutrients  (e.g.  selenium,  vitamins  D3,  B12).  Some  omega 
claims do this by showing a heart on their claim, and one claim explicitly indicated “with 
Omega-3,  EPA  and  DHA  to  help  your  heart”.  Claims  that  refer  to  EPA  and  DHA  having 
benefits for the heart fall under Reg 432/2012. 

Reg 1924/2006 requires that health claims are supported by scientific evidence. One claim 
that  appears  to  contravene  this  regulation  was  ‘Break  speed  records  with  this  natural 
snack’. This claim is manifestly unverifiable and untrue. As such, its added value is also 
questionable. 

6.2.1.4  Traceability 

There were generally two types of claims in this policy area:  

a)  Claims that allow the consumer to input a code specific to their product online in 
order to find information about where, when and with which vessel their FAP was 
caught.  The  traceability  claims  were  generally  clear,  although  some  claims  could 
only be disambiguated with accompanying website information, such as ‘Check your 
product’.  

b)  Claims that refer to traceability as only part of the description or a requirement of 
another  claim  on  the  package  –  e.g.,  ‘Domstein  Miljogaranti  -  Environmental 
guarantee’,  ‘Premium  Scottish  Smoked  Salmon  -  Guaranteed  traceability’.    Often 
these  claims  referred  to  environmental  schemes,  for  which  there  was  further 
disambiguating website information. 

Some of the traceability claims provide voluntary information for processed products that 
for  other  products  would  be  mandatory  consumer  information.  For  example,  the  claim 
‘Where does my fish come from?’ offers origin information for a canned product, which is 
required to be specified on a fresh or lightly processed product.  

Claims in this policy area were all theoretically verifiable, because the information provided 
can be checked by a control authority. As traceability claims make information about the 
origins of the FAP more accessible to the consumer, their added value lies in allowing the 
consumer to more readily evaluate the FAP based on this information, compared to other 
FAPs that do not carry such claims. Although none of the claims in this policy area were 
manifestly false, a subset of claims did not make sense, as they suggested that the product 
was  100%  traceable  (e.g.,  ’100%  Traceable  -  Trace  your  can’,  ‘Guaranteed  100% 
traceability’, despite traceability being an unquantifiable characteristic.  

66 

 
 
 
6.2.1.5  Free from additives 

Claims  in  this  policy  area  generally  referred  either  to  the  FAP  being  natural44,  or  to  the 
absence of additives, preservatives, (artificial) colours/flavours, E-substances, glutamate, 
stabilisers,  or  sweeteners.  These  claims  were  generally  clear  and  those  referring  to  the 
absence of additives were unambiguous. However, the term ‘natural’ may have different 
meanings for different consumers. The use of this term is not regulated under EU law for 
food products, except with reference to flavourings and canned tuna and bonito products. 

Claims  referring  to  the  absence  of  certain  ingredients  were  verifiable  through  cross 
reference  with  the  ingredients  list,  eliminating  their  potential  to  be  manifestly  false. 
Because the information related to the claim can be found elsewhere on the product, such 
claims do not have added value. Verification of other meanings of the term ‘natural’ may 
also  be  possible  –  for  example,  through  documentation  of  the  sourcing  or  processing 
methods of the FAP. 

Very  few  of  these  claims  were  associated  with  schemes  –  these  were  generally  one  of 
multiple policy areas  covered, not always with a mention of this criterion on-pack (e.g., 
Labeyrie Quality Engagement).  

As with ‘Allergen free’ claims, consumers may find such claims helpful if they are trying to 
avoid certain additives.  

Good/bad practices for free from additives claims 

According  to  the  FAOs  Codex  General  Guidelines  on  Claims  (5.1,  vi.,  b),  “Claims  which 
highlight  the  absence  or  non-addition  of  particular  substances  to  food  may  be  used 
provided  that  they  are  not  misleading  and  provided  that  the  substance…is  one  which 
consumers would normally expect to find in the food.” A similar criterion is outlined in the 
FIC  regulation  (Art.7(c)),  indicating  that  “Food  information  shall  not  be  misleading, 
particularly by   suggesting   that   the   food   possesses   special   characteristics when  
in  fact  all  similar  foods  possess  such  characteristics,  in  particular    by    specifically    
emphasising    the    presence    or    absence  of  certain  ingredients  and/or  nutrients. 
Given  this  principle,  it  is  debatable  whether  canned  FAPs  should  be  able  to  claim  the 
absence of preservatives (as was found for several products in the inventory), as canning 
renders  the  addition  of  preservatives  to  be  unnecessary.  Such  claims  may  give  the 
impression that canned FAPs normally contain preservatives unless otherwise stated.  

In  2008,  the  UK  Food  Standards  Agency  revised  their  best  practice  guidelines  on  the 
‘Criteria  for  the  use  of  the  terms  fresh,  pure,  natural,  etc.  in  food  labelling’  (2008).45 
According to this document, claims should not be made that give undue emphasis to the 
fact that a product is “free from certain non-natural additives or categories of additives”, 
when the product contains other non-natural additives.  

6.2.1.6  Generic responsibility/ Environmental responsibility/ Sustainability 

Most  claims  in  this  policy  area  were  related  to  sustainable  fishing  (e.g.,  ‘Sustainable 
fishing’) and farming (e.g., ‘Responsibly farmed’).  A large number of variations of claims 
in this policy area were found in combination with the large number of brands that carry 
these claims and the fact that every country had FAPs on the market carrying sustainability 
claims.  Many  claims  also  related  to  multiple  policy  areas,  most  notably  origin  (e.g., 

44   Claims referring to ‘natural’ did not refer to canned tuna and bonito products in this context, as the use of 

‘natural’ for such products falls under different regulations (Council Regulation (EEC) No 1536/92. 

45   https://www.food.gov.uk/sites/default/files/multimedia/pdfs/markcritguidance.pdf  

67 

 
                                                 
‘Sustainable  fishery  from  the  Barents  Sea’),  and  organic  production  methods  (e.g., 
‘Sustainable organic-aquaculture’).  

From  a  consumer  point  of  view,  the  claims  were  generally  clear.  However,  the  issue  of 
sustainability and responsibility and how they are assessed is so multidimensional that the 
claims under this policy area are unlikely to be unambiguous to most consumers.   

Claims that were associated with certification or other schemes (e.g. self-declared) were 
generally  verifiable,  and  had  added  value.  Those  that  were  not  associated  with  specific 
criteria – e.g. ‘Responsibly farmed’ may be more difficult to verify, but this may be done 
through documentation once the scope of the claim has been specified. As such, although 
the claims have added value, exactly how the associated product can be distinguished from 
other products is dependent on how the consumer interprets the claim. 

Although  no  claims  were  manifestly  false,  a  few  claims  were  problematic  because  they 
referred  to  their  product  being  ‘100%’  sustainable  or  ‘Responsible’.  These  misrepresent 
the concept of sustainability and responsibility, which cannot be quantified and are never 
absolute.  However,  it  could  be  argued  that  the  framework  of  sustainability  certification, 
which results in a categorical judgement of ‘yes’ an FAP is sustainable, or ‘no’ it is not, also 
gives the impression that sustainability can be absolute, instead of being a complex, multi-
faceted, ever fluctuating status. Moreover, such claims give the impression that the FAP is 
superior  to  other  products  in  terms  of  sustainability,  and  that  there  are  no  negative 
environmental consequences associated with the FAP. 

6.2.1.7  Social responsibility claims 

This policy area had relatively few claims, and the claims generally referred to the use of 
local fishers (e.g. ‘Maldives-Ali’), and/or fair working conditions for the fishers employed 
(e.g., ‘Choice Foundation’, ‘Fair Trade certified’).  There is currently no Fair Trade-specific 
legislation at the EU level, and France is the only country to regulate this term.  

All claims were associated with schemes that had further website information explaining 
their  criteria,  allowing  consumers  to  clarify  and  disambiguate  the  claims,  which  were 
sometimes  quite  vague  (e.g.  ‘Choice  Foundation’).  Most  of  the  schemes  associated  with 
social  responsibility  were  self-declared,  and  many  covered  multiple  policy  areas, 
particularly  that  of  Generic  responsibility/  Environmental  responsibility/  Sustainability. 
Nearly all social responsibility claims were found on canned fish products.  

Social responsibility claims were considered to be verifiable through third party certification 
and/or documentation and as having added value, with no claims being manifestly false. 

Good/bad practices for social responsibility claims 

Because the implications of many social responsibility claims found in the inventory were 
not clear at face value, good practice should involve claims spelling out to consumers how 
the associated scheme relates to social responsibility.  

6.2.1.8  Animal welfare and animal health claims 

Claims  that  had  animal  welfare  and  animal  health  as  their  main  policy  area  generally 
pertained  to  either  the  FAP  species  in  the  package  (e.g.,  RSPCA  Assured),  or  to  the 
protection of dolphin bycatch (e.g., ‘Dolphin safe’). Those in which animal welfare/health 
was a secondary policy area tended to refer to fishing methods-e.g. ‘Long Lines (stop sign 
), although some claims related to both the FAP in the package as well as by-catch (e.g. 
‘KRAV’). The bycatch-related claims were primarily about dolphin welfare, with the Earth 
Island ‘Dolphin Safe’ logo having the greatest market visibility in terms of number of brands 

68 

 
and  countries,  followed  by  a  ‘Dolphin  friendly’  claim  that  was  not  associated  with  any 
scheme. Such claims also often belonged to multiple policy areas, such as more detailed 
information on fishing gear. Nearly all claims were found on canned fish, and most were 
not supported by a scheme.  

Animal  welfare/health  claims  are  generally  verifiable  based  on  certification  or 
documentation of the farming conditions or fishing methods, and they provide added value. 
No claim was manifestly false, however, the claim of 100% animal welfare was dubious in 
the sense that: a) it quantifies an unquantifiable concept, and b) that any product resulting 
from animal death could not be considered to uphold animal welfare to the maximum level.  

Good/bad practices for animal welfare/health claims 

It is interesting to note that a substantial proportion of the different types of inventorised 
claims relating to dolphin welfare were not associated with any schemes, which contrasts 
with the regulation of dolphin-safe characteristic in the US under the  Dolphin Protection 
Consumer  Information  Act  passed  in  1990.  This  was  done  “to  prevent  fraud,”  because 
people were concerned that unless the dolphin-safe label was regulated, “firms that used 
technology that was harmful to dolphins might be labelling [their tuna] erroneously.46” This 
type of regulation has not been mirrored in the EU. 

Given  that  very  few  different  types  of  animal  welfare  claims  in  the  inventory  were 
associated with schemes (e.g. ‘Salmon welfare’, ‘Dolphin friendly’ are not associated with 
schemes), a first step towards improving animal welfare/health labelling would be to make 
the  criteria  of  the  claim  easily  accessible  to  consumers,  either  via  on  the  package 
information, or via the product/brand website. This is particularly important given that an 
animal welfare labelling feasibility study47 commissioned by the EC found that the lack of 
animal welfare information on food products is an important issue for consumers, but that 
they  are  unable  to  understand  and  differentiate  the  welfare  standards  of  the  labelling 
schemes.  

6.2.1.9  Religious dietary laws  

There  were  only  two  claims  related  to  religious  dietary  laws,  and  they  both  related  to 
kosher  food,  with  one  being  supported  by  a  scheme  (KLBD  Kosher  Certification,.  These 
claims  were  found  on  fresh,  frozen,  and  preserved  fish.  Although  Kosher  prescriptions 
mean that knowing the FAP species allows one to judge whether a food is Kosher or not, 
an independent check  can be  carried out by a  Kosher authority to verify the species, in 
case  it is  mislabeled.  Claims in  this  policy  area  were  clear,  unambiguous,  and  verifiable 
through documentation and/or physical inspection (i.e., if the fish has scales intact). They 
also provided added value, and none were manifestly false.  

Good/bad practices for kosher claims 

Kosher claims are not subject to EU regulations, and thus the most authoritative way for 
consumers to check whether a food follows kashrut is through certification through a Rabbi 
or  Rabbinical  organisation.  However,  because  widespread  kosher  certification  is  not 
feasible, in many European countries the principal method of rabbinical approval is via a 
kosher  list  (albeit  with a  lower  kosher  standard)  published  annually  by  local  or  national 

46   Vogel, D. (1995). Trading Up. Cambridge, MA: Harvard University Press. 

47   Feasibility  study  on  animal  welfare  labelling  and  establishing  a  Community  Reference  Centre  for  Animal 
Welfare. 

Protection 
https://ec.europa.eu/food/sites/food/files/animals/docs/aw_other_aspects_labelling_feasibility_study_repor
t_part1.pdf 

and 

69 

 
                                                 
Jewish  authorities  (such  as  the  Chief  Rabbinate).  This  suggests  that  where  widespread 
certification is not possible, other means of communicating approval from an authority may 
serve the same purpose as authorised food claims. 

6.2.1.10  Organic production methods 

Claims in the policy area related only to farmed FAPs. Nearly all claims referred to a 3rd-
party  scheme,  with  EU  Organic  being  the  dominant  scheme  (associated  with  over  10 
brands),  followed  by  Bio  Siegel  (nach  EG-Öko-verordunung),  AB  Organic  Agriculture 
(Agriculture Biologique), and Krav covering six brands each.  Most FAPs with such claims 
were found on smoked products (perhaps due to the widespread farming of salmon), and 
many were also found on canned/processed products.  

Organic  claims  were  generally  clear,  verifiable  primarily  through  certification,  but  also 
through  documentation,  and  had  added  value.  However,  it  could  be  argued  that  many 
claims stating that the FAP was organic were ambiguous in the sense that consumers often 
interpret  the  meaning  of  the  claim  differently  to  the  conditions  set  out  in  the  relevant 
regulations.  For  example,  results  from  the  OrAqua  project  on  consumer  perceptions  of 
organic fish48 found that 19-27% of consumers confused organic fish with wild fish, and 
50%  considered  that  fish  raised  in  organic  conditions  were  not  exposed  to  medicines, 
despite regulations that do allow for some medicines to be used for animal welfare reasons.  

Good/bad practices for organic production methods 

The  use  of  the  EU  organic  farming  logo  and  correct  labelling  is  obligatory  for  all  pre-
packaged food produced within the European Union that is sold as 'organic'.  

Fish feed is one of the most important factors in aquaculture production. The OrAqua study 
found that one of the highest priorities of consumers regarding organic aquaculture is the 
use of organic feed without synthetic additives (> 45%). However, this is not a mandatory 
requirement  of  organic  aquaculture,  which  prioritises  either  organic  and/or  sustainable 
sources of feed. As such, operators should consider communicating to consumers the feed 
source of the organic FAP – either on the packaging or on the product websites. 

6.2.1.11  Origin 

Claims related to the origin of an FAP generally belonged to one of the following types: 

  Claims that related to where the FAP was fished/farmed (e.g., ‘Fished in the North 

Atlantic’) 

  Claims that related to where the FAP was processed (e.g., ‘Prepared in France’) 
  Claims  that  associate  the  origin  of  the  product  with  taste/quality  (‘Quality  Food 

Slovakia’) 

These  claims  were  generally  clear,  unambiguous,  provided  added  value,  and  were  not 
manifestly  false.  Those  that  were  ambiguous  tended  to  relate  the  origin  of  the  product 
together with a claim about the quality of the FAP without specifying how the product was 
a  quality  product.  For  example,  it  was  unclear  whether  the  claims  ‘Danish  Quality’  or 
‘Alaska USA quality’ related simply to the products having the quality of originating from 
their particular region, or whether the products were of good quality because of their origin.  

In the case of wild caught fish, the concept of origin is further complicated by the fact that 
a fish has no origin until it is caught. Thus, an origin claim could refer to the waters where 

48   https://www.oraqua.eu/content/download/110528/1547961/file/Perception+understanding.pdf?version=1  

70 

 
                                                 
products  are  caught  or  to  the  flag  state  of  the  vessel  that  caught  the  product,  and  the 
consumer would not know precisely what origin is conveyed unless this is disambiguated 
by the operator.  

According to Article 13(1) of the FIC, voluntary information should not be presented in a 
way that detracts from mandatory information. However, some claims related to a product 
being “Packed in Ireland”, could be argued to violate this criteria, as they were presented 
in a much more salient way than that of the mandatory information about where the FAP 
was sourced. The “Packed in Ireland” claims were presented with a picture (often an Irish 
flag or a fishing vessel) near the centre of the packaging, while the origin information was 
presented either further down the packaging, or at the back of the packaging. The pictures 
create a strong association of the product with Ireland, or with Irish fishing, which may 
lead  consumers  to  presume  that  the  FAP  comes  from  Ireland,  instead  of  simply  being 
packed there. 

Origin claims were considered to be verifiable based on documentary checks. This pertains 
to  claims  that  indicate  simply  the  origin  of  the  FAP,  or  that  the  FAP  is  ‘produced’  in  a 
particular country, or that it is a ‘product’ of that country. Claims that related to a product 
being processed in a particular place are also verifiable through documentation. Those that 
related the quality of the product to its origin could be verified if the claim was related to 
a scheme (e.g., ‘Approved Estonian Taste’), but otherwise the taste/quality aspect of the 
claim could not be verified, although the origin part could  – e.g., ‘Irish flavour’. In such 
cases, only the verifiable origin component of the claim added value. 

Good/bad practices for origin claims  

The Food Standards Agency outlines good practices for origin labelling in their Country of 
Origin Labelling Guidance.49 It points out that many consumers perceive claims of “Product 
of…” to imply that the place of processing and the origin of ingredients are the same. The 
guidance recommends that in cases where these two factors differ, claims should specify 
this difference, such as “Made in France from imported fish”.  

The guidance also suggests that if a claim refers to a product having been “Packed in X”, 
it should be accompanied by the statement “Produced in Y” if the country of packaging and 
the  country  of  origin  differ.  This  may  apply  to  products  carrying  the  claims  “Packed  in 
Ireland” and “Packed in Slovakia”. 

6.2.1.12  Production methods 

There were a large number of claims in this policy area, with smoking methods being the 
most widely represented (e.g., ‘smoked over birch’), followed by methods involving hand-
processing (e.g., ‘hand sliced’), and then those referring to production methods that were 
traditional (e.g. ‘traditional recipe’) or artisanal (e.g., ‘Artisanal preparation’). As can be 
expected,  most  claims  about  production  methods  were 
found  on  smoked  or 
canned/processed FAPs. Many claims also included messages that fell under multiple policy 
areas, with some relating the method of production to taste (e.g., ‘Traditionally cured and 
kiln-smoked for a sweet smoky taste’ ), to composition (e.g., ‘Naturally cut; full fillet’), to 
origin (e.g., ‘Cured in Galicia’), or to product quality (e.g., ‘Hand prepared by professional 
chefs’). Very few claims in this policy area were supported by a scheme. 

49 

http://webarchive.nationalarchives.gov.uk/20101209115147/http://food.gov.uk/multimedia/pdfs/originlabel
lingguid0909.pdf 

71 

 
                                                 
Claims  concerning  production  methods  were  generally  clear,  unambiguous,  verifiable 
through documentation of methods, and had added value.   

Good/bad practices for claims about production methods 

There are no EU regulations relating to the types of production methods found in this policy 
area, which tend to be designed more for marketing purposes to highlight tradition, taste 
and  the  preparation  of  the  product,  rather  than  to  inform  the  consumer  about 
manufacturing processes.  

6.2.1.13  Taste/Product Quality 

Claims in this policy area generally belonged to one of the following types of claims: 

  Claims related to the taste/texture of the FAP (e.g., “With firm flakes and a subtle, 

mellow flavour”) 

  Claims related to awards/certificates (e.g., “Award winning”) 
  Claims  about  the  product  being  approved  by  consumers  (e.g.,  “Customer  choice 

2015 - The best news”) 

  Claims about the product being selected (e.g., “Carefully selected”) 
  Claims related to a special method/process applied to the FAP (e.g., “Gourmettrim 

- Precision worked and cut”) 

  Claims about the general quality of the FAP (e.g, “Our best ever”, “Top quality”) 
  Claims  about  the  traditional  quality  of  a  product  (e.g.  Traditional  Speciality 

Guaranteed) 

  Claims  associating  the  quality  of  a  product  with  a  region  (e.g.,  “Protected 
Designation of Origin”; “Protected Designation of Origin Mojama tuna from Cristina 
island”) 

Taste/product quality claims were generally clear. Claims that were unclear included those 
that were unspecified/very vague – e.g., “Cluny Red Label”, A – 4 stars, or that attempted 
to quantify unquantifiable aspects of the FAP (e.g., 100% flavour, 23.5% smoky taste).  

Although most claims were unambiguous, there were many claims that were ambiguous 
when  compared  to  other  policy  areas.  Claims  that  were  ambiguous  were  vague  –  e.g., 
“Saupiquet Quality”, “Gourmet Collection”, “Best Choice”, “Carefully selected”. Such claims 
communicate something about the quality of the product, but it is ambiguous as to what 
these  qualities  are.  As  was  the  case  for  unclear  claims,  such  ambiguous  claims  are 
considered  not  to  have  any  added  value  as  they  provide  too  little  information  to  allow 
consumers to distinguish the FAP that carries this claim from other FAPs.  

Claims  that  were  not  ambiguous  could  add  value  even  if  they  were  subjective,  such  as 
those relating to a specific aspect of the taste/texture of the FAP (e.g., Mild and delicate).  

The  subjective  nature  of  many  claims  in  the  policy  area  renders  them  unverifiable, 
particularly  given  that  many  are  not  related  to  schemes.  Given  the  subjective 
nature/criteria of the claims in this policy area, it was also not possible to judge the claims 
as being manifestly false. 

Most  claims  related  to  schemes  tended  to  refer  to  3rd  parties  that  assigned 
awards/certificates,  which  allows  such  claims  to  be  verified  by  contacting  the  awarding 
party. In most cases, the criteria of the awards are clearly specified (even if they remain 
subjective), making it clear how the product attained the award. Those claims that were 
related to non-award schemes also had criteria that could be found online, which serves to 
disambiguate what would otherwise be an ambiguous claim (e.g., “Quality guaranteed”, 

72 

 
“Friedrichs quality”). These criteria allow such scheme-related claims to be verifiable and 
add value for the consumer. 

Good/bad practices for taste/product quality claims 

In their ‘Criteria for the use of the terms fresh, pure, natural, etc. in food labelling’50, the 
UK  Food  Standards  Agency  stated  that  “It  is  misleading  to  use  the  term  “traditional”, 
without qualification, simply to distinguish an “original” recipe from subsequent variants.  
Manufacturers  and  retailers  should  pay  particular  attention  to  the  use  of  ingredients, 
particularly  additives,  and  to  the  use  of  processes  that  have  not  been  used  in  food 
manufacture  for  the  significant  period  of  time  indicated  above  [25  years].    They  must 
ensure that the term does not imply a composition or production method that would not 
be  regarded  as  “traditional”  by  the  average  consumer  and  should  consider  whether  the 
term  “original  recipe”  or  similar  expression  may  be  more  appropriate.    There  should  be 
evidence to substantiate the use of the word for the particular product.” According to this 
guideline,  one  of  the  claims  found  in  the  inventory  may  be  argued  to  use  the  term 
‘traditional’  in  a  potentially  misleading  way,  because  they  contain  additives  such  as 
dextrose,  the  acidity  regulator  gluconodelta-lactone,  monosodium  glutamate,  the 
preservatives sodium benzoate and potassium sorbate. 

Furthermore, research in 2005-200651 commissioned by the Agency found that the terms 
“traditional style” and “selected” were not easy to understand and it is suggested that their 
use  should  be  avoided.  As  such,  the  guidelines  recommended  that  the  element  of  the 
product that has been ‘selected’ or the process of selection should be specified in order to 
prevent confusion. 

The research also showed that terms such as “Premium”, “Finest”, “Quality”, and “Best” 
are  viewed  by  consumers  as  ways  in  which  manufacturers  differentiate  their  ranges  of 
products to indicate the one that is ‘top of the range’.  As such, the guidelines suggest that 
manufacturers and retailers could help consumers to understand why a claim of high level 
of overall quality is justified and why the particular term is used.  

6.2.1.14  More detailed information on fishing gear 

No claims in this policy area were 3rd-party claims, and most were self-declared. The most 
popular claim was the Pole & Line claim, of which there were 11 variations. Other claims 
related  to  other  fishing  methods,  such  as  ‘FAD  free  fishing’,  ‘Rope  Grown  Mussels’,  and 
‘Sustainable  fishing  with  cage’  The  Pole  &  Line  claim  was  often  self-declared  (Rio  Mare, 
Pandomar,  John  West  -,  Santa  Catarina/Fish  Tales,  Fish4Ever)although  it  was  also 
frequently used without requirements. Claims relating to fishing gear were predominately 
found on canned fish, particularly tuna, suggesting that fishing methods are of a particular 
concern for this type of fish. In addition, corporate commitments to sustainable sourcing 
may also favour the pole and line fishing method. 

Because the type of fishing gear used has implications for sustainability and animal welfare 
in terms of reduced bycatch, claims in the former category were often associated with the 
latter two policy areas – e.g., ‘Sustainable fishing with cage’ and the self-declared claim 
‘Line caught’. The latter claim and the associated website provided information about how 
the fishing method does not harm dolphins or turtles.  

50   https://www.food.gov.uk/sites/default/files/multimedia/pdfs/markcritguidance.pdf  

51 

http://webarchive.nationalarchives.gov.uk/20100929131633/http://www.food.gov.uk/multimedia/pdfs/mar
ktermfinalrep0106.pdf 

73 

 
                                                 
From  a  consumer  point  of  view,  such  claims  are  clear  and  unambiguous  at  face  value, 
although in many cases further information is required to understand the implications of 
the claims, which is why many claims in this policy area have related website information 
(on  the  brand  or  scheme  website).  These  claims  are  also  verifiable  with  reference  to 
documentation about fishing methods, and have added value for the consumer. 

6.2.1.15  Composition 

Most claims in this policy area related to the quantity of FAP in the product (e.g., ‘100% 
cod’ ), or whether the fish contained skin and/or bones (e.g., ‘Skinless and boneless’). No 
claims  in  this  policy  area  were  associated  with  schemes.  Composition  claims  were  most 
often found on frozen and processed FAP, perhaps because, unlike fresh or smoked FAP 
which  normally  have  transparent  packaging,  frozen  and  processed  FAPs  are  often 
presented in (mostly) opaque packaging, which does not allow the consumer to  visually 
assess the composition of the food.  

Composition  claims  were  generally  clear,  verifiable  through  physical  examination  of  the 
FAP, or examination of the ingredients list for claims related to a pure composition of an 
FAP, and had added value. Two claims were found to be ambiguous: 1) ‘100% Squid’ , as 
the packaging of the FAP depicts a breaded product but the claim may refer to the FAP 
content,  and  2)  ‘Pure  salmon*’,  as  the  ingredients  listed  indicate  that  the  product  only 
contained  80%  salmon,  but  again  the  "*"  suggests  that  the  claim  may  refer  to  the  FAP 
content. 

6.2.1.16  Unclassified claims 

Claims in this category generally referred to: a) the freshness of an FAP (e.g. ‘Packed from 
fresh’, b) a particular freezing method (e.g., ‘Frozen at sea’), c) the GMO-free nature of 
the FAP (e.g. ‘No GMO/GMO free’), or d) the ‘wild’ nature of the fish – e.g. (‘Wild’). Although 
the claims were generally clear from a literal point of view, their implication was sometimes 
ambiguous,  as  it  is  not  clear  whether  a  product  that  is  ‘Frozen  at  sea’,  for  example,  is 
preserved  straight  after  catch,  or  for  a  considerable  duration  after  catch.  Nor  is  it  clear 
what it means for a canned product to be ‘Ocean fresh’.  In a similar vein, at face value, 
‘Tuna fished in free-roaming schools’ may seem to suggest that the Tuna are wild-caught. 
However the term ‘free-roaming schools’ actually refers to FAD-free fishing, which supports 
the welfare  of bycatch, as FADs are  known to attract many untargeted  species that are 
taken on board in tuna purse seine nets. The unclassified claims were found predominantly 
on canned/processed FAPs, and none were supported by a scheme. 

In relation to GMO foods, Reg. 1830/2003 requires that all food products associated with 
GMOs  must  label  their  products  as  such.  Thus,  claims  related  to  GMO-free  FAPs  are 
considered not to add value because they cannot be distinguished from FAPs that do not 
carry such claims. Furthermore, such claims are problematic because, from the consumer’s 
perspective, they imply that foods that do not carry such claims do have GMO origins.  

Claims that refer to the wild nature of the FAP are essentially indicating that the product is 
not  farmed,  which  is  mandatory  information  on  FAPs  that  are  fresh  or  lightly  processed 
(e.g.,  ‘Wild  and natural’,  on  frozen  salmon),  but  not  on  canned  and  processed  products 
(e.g., ‘Wild Canadian’, on canned salmon). In this sense, ‘wild’ claims could be considered 
to have no added value for the former category of FAPs. However, the choice of ‘wild’ might 
convey a more direct meaning to the consumer than the functionally equivalent ‘caught’, 
and thus may serve to draw attention to this quality of the product. In cases where ‘wild’ 
is  found  on  species  that  are  always  or  nearly  always  fished  (e.g.,  tuna,  langoustines, 
Alaskan Pollock, herring, sardines), this claim may be considered to imply that the FAP has 
a  special  quality  that  other  products  of  the  same  species  do  not  possess,  which  is 
potentially misleading. 

74 

 
In general unclassified claims can theoretically be verified though documentation, although 
those that refer to the freshness of a product will have to be more clearly specified before 
verification is possible. Except for claims related to the GMO-free or to the wild nature of 
the FAP, unclassified claims generally have added value, although in many cases further 
clarification of the meaning/implications of the claim would make this added value more 
concrete. One claim that was patently false was ‘Suitable for vegetarians‘, which was found 
on a salmon product. 

Good/bad practices for unclassified claims 

The best practice guidelines of the Food Standards Agency states that the terms “fresh” or 
“freshly”  should  only  be  used  where  they  have  a  clear  meaning,  whether  used  alone  or 
qualified by other terms. 

6.2.2 Assessment of claims across policy areas 

Overall, voluntary claims on FAP fulfilled the criteria of:  

a)  Being clear – the few claims that were not clear at face value (e.g. those that were 
associated with schemes that had vague names  –  e.g., ‘IQ  Net quality systems’) 
were generally associated with websites that clarified the claim.  

b)  Being unambiguous – ambiguous claims could often be disambiguated with further 
information found on the website of the product or scheme. However, some claims 
are  related  to  concepts  are  so  subjective  and  complex  (e.g.  sustainability),  or  to 
concepts  for  which  the  common  public  perception  differs  from  the  regulatory 
guidelines  (e.g.,  organic),  that  it  would  be  difficult  for  the  exact  meaning  of  the 
claim to be unambiguous to consumers. 

c)  Being verifiable – the  only claims that were not verifiable were those that were 
about the subjective quality of the FAP, such as those found in the taste/product 
quality  policy  area,  and  those  with  exaggerated  claims  about  the  effect  of  the 
product (i.e. ‘Break speed records with this natural snack’). 

d)  Adding value – only a small minority of claims did not add value, which could be 

represented in one of two ways:  

a.  Referring  to  information  that  can  be  found  elsewhere  on  the  packaging 
because  the  reporting  of  such  information  is  mandatory.  Although  such 
claims provide redundant information, they may nonetheless be helpful to 
the  consumer  because  they  highlight  information  in  a  way  that  makes  it 
more accessible to the consumer.  

b.  Claiming that the product has a quality that is in fact applicable to FAPs that 
do  not  have  such  a  claim  (e.g.,  GMO  free).  These  claims  are  more 
problematic  than  the  above  condition  of  simply  providing  redundant 
information,  because  they  give  a  false  impression  about  FAP  products  in 
general,  thereby  putting  the  target  FAP  at  an  unfair  advantage.  However, 
such claims would be rendered less problematic if we follow the guidelines 
of the Canadian Food Inspection Agency to only allow such claims if they are 
qualified to indicate that other FAPs also share the same characteristic. 

e)  Not being clearly false – there were very few claims that were obviously false (e.g., 
‘Suitable for vegetarians’, ‘Break speed records with this natural snack’). The truth 
of  such  claims  are  relatively  easy  to  assess,  but  they  may  still  mislead  many 
consumers, such as those who take the truth of claims for granted. 

75 

 
6.2.3 Comparison of policy areas 

Although  the  inventorised  claims  generally  fulfilled  the  five  criteria  to  a  large  extent  as 
highlighted  above,  it is  worth  noting  that  there  were  variations  between  different  policy 
areas that made some types of claims more problematic than others. Taste/product quality 
claims were often subjective, making them difficult to verify. As such, these types of claims 
had little added value. Another group of claims that had questionable added value were 
unclassified claims, particularly those whose policy area was ambiguous. Such claims would 
benefit  from  being  more  specific  and/or  clear  about  the  benefit  of  their  product.  Many 
unclassified claims also had little added value, but for another reason. In this case, such 
claims (e.g., ‘Wild’ on unprocessed and lightly processed FAPs, claims of ‘GMO-free’) often 
related to mandatory information, and thus did not serve to distinguish their product from 
similar FAPs that did not carry such a claim. Furthermore, in the case of foods advertised 
as  being  GMO  free,  these  claims  also  were  problematic  in  suggesting  that  their  product 
was different to other products that did not carry the same claim. 

Other claims that posed some problems were those that used the term ‘natural’ (under the 
‘Free  from additives’ policy area). This term may be considered to be ambiguous to the 
consumer, and the fact that its use is not regulated (except for canned tuna  and bonito) 
does  not  help  to  disambiguate  the  claim.  When  the  claim  refers  to  the  ingredient 
composition of the production, it has no added value beyond the list of ingredients. 

Claims  related  to  Organic  production  methods  or  Generic  responsibility/Environmental 
responsibility/Sustainability were ambiguous from a consumer point of view because they 
referred to very complex, multidimensional concepts. Furthermore, it can be argued that 
some claims from the latter policy area misrepresent their key concepts by presenting their 
products as being ‘100%’ sustainable/responsible. 

Claims that were less problematic tended to be those from the following policy areas – but 
this is possibly due to the low variety of claims within these policy areas compared to the 
variety of claims found in others:  

  Allergens: although these claims may provide information that is redundant from a 

legal point of view, such claims can nevertheless be useful for consumers 

  Traceability, Origin, Production methods, Fishing gear, Composition: claims in these 
policy areas were generally unambiguous at face value and could be easily verified 
  Social  responsibility,  Animal  welfare:  claims  in  these  policy  areas  that  were 
ambiguous  at  face  value  were  often  associated  with  schemes  that  had 
disambiguating online information 

  Religious  dietary  laws:  such  claims  were  clear  to  the  target  consumer,  and  they 

were either certified, or could be otherwise verified 

76 

 
 
 
7  Conclusions 

Voluntary claims are prevalent on FAPs in the EU and are carried on all different types of 
FAPs.  Furthermore,  the  prevalence  of  voluntary  claims  on  FAPs  is  increasing.  Certain 
messages about the characteristics of the FAP are dominant. These tend to be in relation 
to describing the product as healthy, of good quality and sustainable. Whilst many schemes 
were identified as being applicable to FAPs in previous studies, this study about what is 
found on the market identifies far fewer. Furthermore, in terms of market visibility, there 
are few schemes that are commonly visible towards consumers. This means, that typically, 
for a consumer in the EU who picks up a FAP they are most likely to see claims that are: 

- 

- 

supported by a small pool of third-party schemes (MSC/ASC),  

some variation on an Omega 3 claim positioning the product as ‘healthy’,  

-  a claim purporting the FAP is ‘natural’, free from additives, etc.; 

-  an indication that it is ‘easy to eat’ – skinless and boneless; 

-  one of the many variations of ‘quality’ claims declaring the product to be superior, 

selected, etc. 

-  And where the FAP has come from (either origin or traceability).  

These claims are broadly in line with what the consumers in the experiment considered to 
be important factors when purchasing FAPs.  

On the basis of the stakeholder consultation, voluntary claims are placed on FAPs in order 
to market the product (either to gain access to the market in the case of some voluntary 
claims supported by schemes or to increase sales). Which claims are placed depends on 
what can be gained weighted against costs (financial or administrative), with claims that 
are  subject  to  scheme  certification  (or  legal  regulation)  being  more  costly  in  some 
instances.  

What are the main problem for consumers?  

The main problems consumers face with voluntary FAP claims are: 

a)  They cannot distinguish between different claim types 

b)  They find it difficult to understand the meaning of the claim in terms of what policy 

area it relates to 

c)  Certain popular terms used in claims are ambiguous to consumers 

The following sections describe the nature and scope of these problems, outlines the effects 
of these problems and discusses the possible reasons why these problems arise.  

Consumers  cannot  distinguish  between  the  claims  types  of  3rd-party  certified, 
self-declared, and other claims.  

What is the scope of this problem?  

The findings of the experiments show that consumers are not able to distinguish different 
types  of  claims.  In  addition,  consumers  are  not  knowledgeable  about  the  control 
mechanisms claims are subject to. For example, 29.5%  of  respondents in Experiment 1 
think that labels are always certified by 3rd party organisations, and 59.66% did not realise 
that food producers/retailers can create their own labels, based on their own criteria.  

What are the effects of this problem?  

The  inability  for  consumers  to  distinguish  between  different  types  of  claims  makes  it 
difficult for consumers to  choose between what appear to be similar standards between 
different types of claims. Experiment 1 showed that consumers’ purchase intentions and 

77 

 
 
willingness  to  pay  were  relatively  unaffected  by  whether  the  claim  was  supported  by  a 
scheme (3rd-party/self-declared claim) or not (other claim). Therefore, it is not the type of 
voluntary  claim  that  drives  consumer  behaviour.  This  could  account  for  why,  although 
perceived claim credibility is important for driving consumer behaviours, consumers in the 
behaviours experiments were unable adapt their credibility perception to objective criteria 
(e.g. whether or not the claim is certified by a third party), Thus, although the consumer’s 
purchases decisions in the experiments were based on how credible they believed the claim 
to be, this credibility seems, however, based on the face value of the claim. 

What are the possible reasons for this problem? 

Other  than  lack  of  familiarity  with  food  labels  and  their  requirements,  consumers  have 
difficulty  distinguishing  between  different  types  of  claim  types  (e.g.,  in  terms  of 
generalising certification conditions to all types of claims).  

Consumers are confused about the meaning of the claim in terms of what policy 
areas it covers  

What is the scope of this problem?  

While  claims  often  represent  specific  policy  areas  (e.g.  sustainability,  quality,  etc.),  the 
findings  of  the  experiments  showed  that  consumers  find  it  difficult  to  interpret  claim 
information, which is reflected in wrong product perceptions.   For example, results from 
the  OrAqua  project  on  consumer  perceptions  of  organic  fish52  found  that  19-27%  of 
consumers  confused  organic  fish  with  wild  fish.  In  our  behavioural  experiments, 
sustainability  claims  also  increased  other,  somewhat  unrelated,  product  perceptions, 
including  perceptions  of  socially  responsible  production,  traceability  and  high  product 
quality.  

What are the effects of this problem? 

The difficulty that consumers have in understanding the meaning of a claim could explain 
why  in  Experiment  1  consumers’  willingness  to  pay  for  an  FAP  was  not  affected  by  the 
policy area a claim  belonged to (even when the policy area was important to them), in 
comparison  to  claims  covering  other  policy  areas  or  compared  to  products  without 
voluntary  claims.  Furthermore,  perceived  claim  credibility  increases  perceptions  of  all 
product dimensions (e.g., healthy, tasty, traceable, etc.), regardless of the claim presented 
on  the  FAP.  Although  this  effect  could  be  a  result  of  consumer  confusion  regarding  the 
meaning of a claim, it may also be a general heuristic that consumers use when processing 
claims that renders them unable to distinguish between different policy areas. 

The  confusion  that  consumers  experience  over  claims  may  drive  them  to  base  their 
purchase  decisions  by  wrong  credibility  perceptions  and  misinterpretation  of  the  claims. 
Although they may be able to access off-the-package information that could help inform 
their decisions, it is unlikely all consumers will look for additional information at the point-
of-purchase. 

What are the possible reasons for this problem? 

The  consumer  assessment  of  claims  shows  that  while  the  majority  of  claims  can  be 
considered as being clear and unambiguous in their message, many claims could only be 
disambiguated  with  online  information.  However,  even  the  online  information  was 
sometimes  insufficient.  Furthermore,  the  source  of  the  off-the-package  information  was 
generally  not  indicated  on  the  inventorised  claims,  making  it  even  more  difficult  for 
consumers to access this information. Some respondents in the stakeholder consultation 

52   https://www.oraqua.eu/content/download/110528/1547961/file/Perception+understanding.pdf?version=1  

78 

 
                                                 
corroborated this view and pointed out that in some cases consumers even have to request 
the information related to the claim, because it is not always available online.  Indeed, one 
consumer watchdog had received complaints regarding confusing, unclear, misleading, or 
unverifiable claim information.  

When faced with an FAP carrying voluntary claims, consumers are confronted with making 
choices based on the information they have to hand.  

Another  reason  why  consumers  may  have  difficulty  in  understanding  what  a  claim 
represents is because there is a lack of harmonised EU standards about issues such as fair-
trade, animal welfare and sustainability. As such, consumers may generalise the criteria of 
particular  claim  to  other  claims  they  perceive  to  be  similar,  which  may  be  particularly 
problematic  for  claims  that  cover  multiple  policy  areas.  This  in  turn  may  lead  to  the 
perception  that  sustainability  claims  also  relate  to  socially  responsible  production, 
traceability and high product quality (as was found in our experiments).  

Consumers appear confused about the  use of certain terms in  claims  and what 
they imply 

What is the scope of this problem? 

Certain  popular  terms  featured  on  claims,  and/or  the  ways  in  which  these  terms  are 
presented are ambiguous to consumers. This applies to terms related to quality claims  – 
e.g., ‘Premium’, ‘Finest’, ‘Quality’, and ‘Best’, and those related to origin claims. Because 
products can have multiple origins, not all the origins are equally represented, meaning 
that  consumers  do  not  always  have  the  complete  picture  of  the  origin  of  their  product. 
Also, sometimes voluntary origin information (such as where a product was processed or 
packed) may detract from mandatory information about the origin of the FAP. 

What are the effects of confusing quality claims? 

The behavioural experiments show that the quality claims used (e.g., ‘Premium’, ‘Quality 
Guarantee’, ‘Superior’) had no effect on the quality perceptions of the FAPs, in comparison 
to either no claim, or a claim that was unrelated to quality. However, having multiple claims 
on a product (i.e., ‘Natural Taste’, ‘Wild’, ‘Source of Omega 3’) in additional to a ‘Premium’ 
claim on a product increased the perceived quality of a product compared to a ‘Premium’ 
claim alone. This suggests that consumers infer the quality of a product from more concrete 
aspects of the FAP, rather than from vague claims of quality. 

What are the possible reasons for this problem? 

According to the UK Standards Food Agency, consumers find quality claims confusing. They 
recommend that such claims explain why the product is of good quality.  

What are the effects of confusing origin claims? 

When not all origin information about an FAP is equally represented, consumers can receive 
the impression that a product has only one origin, when it in fact has multiple origins. This 
is particularly problematic given that the origin of a product is one of the factors consumers 
consider to be most important in deciding what FAP to purchase.  

79 

 
 
 
 
What are the possible reasons for this problem? 

Such problems occur because current EU regulations do not require all origin information 
to  be  equally  represented  (except  where  voluntary  information  cannot  detract  from 
mandatory information).  

7.1 

Focus on the consumer 

Consumers  are  faced  with  a  range  of  product  choices  carrying  (in  some  cases  multiple) 
voluntary  claims  in  addition  to  mandatory  information,  which  can  be  informative  for 
consumers, but could also be ambiguous or misleading. Ambiguous, misleading and non-
verifiable  voluntary  claims  also  undermine  the  possibility  for  consumers  to  make 
purchasing choices that could contribute to a range of specific outcomes, such as better 
health/nutrition  choices,  support  sustainable  fishing  practices,  support  local  fishing 
economies, etc.  

The issues around consumer comprehension of what voluntary claims mean, as highlighted 
by the evidence in this study, indicates the need for further transparency about voluntary 
claims on FAPs. Information is not, in all cases, easy to find or to understand for consumers 
who are willing to seek further information about what a specific voluntary claim means. 
Furthermore,  some  voluntary  claims  are  ambiguous  or  confusing  for  consumers  as 
highlighted by the consumer assessment  

However,  evidence  from  a  recent  Eurobarometer53  highlights  relatively  high  levels  of 
consumer trust in the information provided by the brand or seller (71%). Therefore, it is 
not necessarily about building trust amongst consumers, but whether that trust is justified.  

7.2 

Focus on the supply chain 

The evidence from this study suggests that voluntary claims are a tool used to market and 
gain market access, for producers and food operators. The evidence related to consumer 
demand for such claims is weak. Coupled with the fact that there appears to be quite some 
consumer confusion about labelling (even when the labels can be considered to be clear, 
unambiguous and verifiable by off-pack information sources), in answer to who is receiving 
a benefit from adding voluntary claims to the products, the evidence points to those in the 
supply chain. It is difficult to say with certainty what this benefit is, given the small pool of 
stakeholders  who  participated  in  the  consultation.  However,  amongst  those  who  did 
participate  this  benefit  was  more  related  to  marketing  and  market  access.  The  issue  of 
competition and access to markets being dependent upon obtaining (certain) certification 
was beyond the scope of this assignment, but was mentioned by those who participated in 
the stakeholder consultation and could be considered as a topic for further research.  

There is no clear strong effect of voluntary claims (of different types or in different policy 
areas) on consumer behaviour (measured by purchase intentions and willingness to pay), 
but that voluntary claims do influence consumers understanding of the characteristics of a 
product.  Furthermore,  it  is  the  trust  that  consumers  have  in  claims  (i.e.  the  perceived 
credibility  of  the  claim)  that  can  influence  their  behaviour  rather  than  the  (perceived) 
certification of the claim.  

53   Special  Eurobarometer  450-  June  2016  “EU  consumer  habits  regarding  fishery  and  aquaculture  products” 

http://ec.europa.eu/COMMFrontOffice/publicopinion/index.cfm/Survey/getSurveyDetail/instruments/SPECIA
L/surveyKy/2106 

80 

 
 
 
 
                                                 
Annex 1: Stakeholder consultation and surveys 

1.  Stakeholder consultation 

Stakeholders are involved in the supply chain for FAPs, or are concerned about the topic 
of  voluntary  claims  on  FAPs.  In  the  context  of  this  study,  they  were  consulted  to  attain 
insight into  

  The benefits obtained and costs incurred by producers, processors, retailers or other 

operators in the supply chain; 

  To what extent voluntary claims comply with specific requirements; 

  Whether it is possible to link the increased present of FAPs with claims in the market 

to actions by specific actors (e.g. NGOs).  

The stakeholder consultation considers the insights gained from 46 stakeholder surveys, 
together with the insights obtained from semi-structured interviews performed with seven 
stakeholders and experts on the topic of voluntary claims on FAPs. 

A mixed method approach was chosen including both a quantitative survey and qualitative 
interviews. The resulting analysis of this consultation is combined to build the picture of 
stakeholder opinion in this area.  

1.1 

Stakeholder groups 

The  target  population  of  the  stakeholder  consultation  was  quite  diverse,  as  a  variety  of 
actors  are  involved  in the  decision  of  placing  voluntary  claims  on  FAPs  or  in  the  control 
thereof. This covers: 

1.  Retailers & retailer organisations 

Retailers and retailer organisations can be described as businesses that sell goods 
to consumers, and include catering services, restaurants, supermarkets, etc. They 
sell goods that carry all types of voluntary claims, and can be scheme owners as 
well. 

2.  Scheme owners 

Scheme  owners  are  organisations  that  are  responsible  for  developing  and 
maintaining  a  scheme,  and  determining  its  specification.  They  can  be  NGOs, 
government bodies, producer associations, etc. 

3.  Processing & packaging companies and associations 

Processing  and  packaging  companies  prepare  products  for  the  market.  They  can 
process FAPs with voluntary claims, carry their own voluntary claims, or be part of 
claims that cover multiple sections of the supply chain. The associations represent 
the interests of their member companies and provide resources. 

81 

 
 
 
 
4.  Certification bodies 

Certification bodies provide auditing and certification services, determining whether 
certain  products  or  businesses  fit  the  specifications  and  requirements  needed  to 
carry certain voluntary schemes. 

5.  Consumer watchdogs 

Consumer  watchdogs  are  organisations  that  advocate  for  consumer  rights  and 
interests.  They  for  instance  may  focus  on  the  benefits  and  barriers  of  voluntary 
claims for consumers. 

6.  Consumer protection authorities 

Consumer  protection  authorities  are  official  government  authorities  and  have  a 
formal role to protect consumers. These authorities are involved in control of and 
adherence to regulations and requirements to the guidelines of voluntary claims. 

7.  Fishery and aquaculture producers and association 

Fishery  and  aquaculture  producers  are  businesses  that  produce  fishery  and 
aquaculture  products  for  sale  and  are  the  first  link  in  the  supply  chain.  Their 
products  can  carry  voluntary  claims.  The  associations  represent  the  interests  of 
their member companies and provide resources. 

8.  Import companies and associations 

Import organisations bring merchandise from foreign countries for processing, use 
or sale. Import associations represent the interests of their member companies and 
provide resources. 

1.2 

Semi-structured interviews 

Before  carrying  out  the  survey  amongst  stakeholders,  seven  semi-structured  interviews 
were conducted with stakeholders and experts.  

The  semi-structured  interviews  were  conducted  with  different  stakeholders  in  the 
Netherlands and Belgium to better understand the different roles of these stakeholders in 
the area of voluntary claims, and how they themselves understood them and the effects 
on consumers. The interview profiles were the following: 

  an NGO 

  a producer and a producer organisation 

  a processor/packager 

  an importer 

  a board member of a scheme 

  a retailer  

  academics and subject matter experts.  

82 

 
No  consumer  watchdog  or  consumer  organisation  was  willing  to  participate  in  a  semi-
structured interview. 

1.3 

Questionnaire design 

For each target or stakeholder group, a questionnaire was designed in close collaboration 
with the external experts consulted during this study, stakeholders themselves (through 
in-depth interviews) and DG MARE. Feedback  was integrated and the questionnaires for 
stakeholders were finalised to consider the various research questions. The questionnaires 
included mainly closed questions and some open questions. All questionnaires can be found 
in section 3 at the end of this annex. 

1.4 

Sample design 

The focus  was placed  on stakeholders in eight EU countries: Czechia, France, Germany, 
Italy, Poland, Spain, Sweden, and the UK. These eight countries are consistent with those 
chosen for the behavioural experiment. An exception was made for the group of scheme 
owners as all EU28 countries were considered to be part of the sample and some of them 
could  be  considered  ‘international’  instead  of  country  based.  Schemes  are  often  pan-
European and could provide insight for the inventory of claims which is why for this group 
of stakeholders all EU28 countries were included.  

In  the  following  figure,  one  can  note  that  the  consumption  of  fish  and  seafood  differs 
considerably between the eight focus countries.  

Figure 1 
in 2016 (Live weight equivalent - kg capita/year) 

Per capita consumption of fish and seafood in the eight EU countries 

Source: EUMOFA based on elaboration of EUROSTAT, national sources, FEAP and FAO data: 
https://www.eumofa.eu/documents/20178/132648/EN_The+EU+fish+market+2018.pdf   

83 

 
 
 
 
Figure 2 
least once a month within the eight EU countries in 2016 

Proportion of consumers buying fishery and aquaculture products at 

% Buy fish monthly

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

Spain

France

Sweden

Italy

UK

Germany

Poland

Czechia

Source: Eurobarometer 2017 : EU Consumer habits regarding fishery and aquaculture products  

The  stakeholders  were  sampled  using  different  sources,  such  as  internal  resources  and 
experience in the field, contacts of subject matter experts, previous studies on voluntary 
claims,  desk  and  web  research  and  input  from  DG  MARE.  The  number  of  stakeholders 
changed during the fieldwork period, as stakeholders were added based on the answers of 
other  stakeholders  or  deleted  when  they  were  not  the  correct  stakeholder  type  or  no 
contact information was found. Furthermore, where scheme owners were identified during 
the building of the inventory, these were also contacted to participate in the stakeholder 
survey.  

The final sample considered 495 stakeholders. Of those, 49 or 10% of them participated 
in the study. 46 of them could be considered valid and analysed. The surveys can be split 
per group of stakeholder and country where they are based. 

84 

 
 
 
 
Table 1 

Stakeholders per category 

Stakeholder group 

Target 
sample 

# received 
surveys 

# valid 
stakeholders
54 

Country of 
origin 

Retailers  & 
organisations 

retailer 

47 

5 

5 

BE, FR, ES, UK 

Scheme owners 

191 

14 

12 

BE, CZ, DE, 
NL, (NO55), PT, 
(RO56), ES, UK, 
international 

Processing  &  packaging 
companies 
and 
associations 

Certification bodies 

Consumer watchdogs 

Consumer 
authorities 

protection 

Fishery and aquaculture 
producers 
and 
association 

Import  companies  and 
associations 

72 

21 

35 

8 

41 

80 

16 

16 

FR, PL, ES 

4 

2 

1 

6 

1 

3 

2 

1 

6 

1 

(CZ57), FR, SE, 
UK 

CZ, IT 

PL 

DE, PL, SE, UK 

BE 

54   Respondents were screened out from the analysis if they did not relate themselves to voluntary claims on 
FAPs  when  being  asked  in  the  beginning  of  the  questionnaire  and  thus  did  not  answer  the  questions  on 
voluntary claims on FAPs. 

55   Stakeholder interview was not valid 

56 Stakeholder interview was not valid 

57 Stakeholder interview was not valid 

85 

 
 
 
 
                                                 
2. Stakeholder Surveys 

2.1 Consumer Protection Authorities 

Survey on Consumer Protection in Relation to Voluntary Claims on Fishery 
and Aquaculture Products 

This survey is about the protection by the relevant EU Member State authority of consumers 
facing voluntary claims on fishery and aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform the 
consumer about the product (for example: sustainability claim, traceability claim, or health 
claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the Consumer Protection Authority that you represent:  

86 

 
 
 
 
 
 
           
 
 
           
 
 
 
 
3.  Please  indicate  the  competences  by  law  of  the  Consumer  Protection  Authority that  you 
represent. 

4. Is the Consumer Protection Authority that  you represent an independent administrative 
authority or not? 

1. 
2. 

 Yes 
 No, please specify which ministry/national authority you depend from: 

3. 

 I don’t know 

Control & Enforcement 
5. Has the Consumer Protection Authority that you represent adopted a program aimed at 
controlling and evaluating voluntary claims on fishery and aquaculture products  to protect 
consumers? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

6. Which regulations that relate to the clarity, verifiability, non-ambiguity and truthfulness of 
voluntary claims on fishery and aquaculture products does your organization actively control 
compliance with? 

7. Which actors do you control for compliance with the regulations on voluntary claims on 
fishery and aquaculture products? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 

 Scheme owners with schemes certified by 3rd party certification bodies 
 Scheme owners with self-declared schemes 
 Certification bodies 
 Producers of fishery and aquaculture products 
 Traders of fishery and aquaculture products 
 Retailers of fishery and aquaculture products 
 Processing and packaging companies of fishery and aquaculture products 
 Others, please specify: 

87 

 
 
 
 
 
 
 
 
 
 
 
 
9. 

 I don’t know 

8. How does the Consumer Protection Authority you represent monitor or oversee the market 
regarding voluntary claims on fishery and aquaculture products.  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 

 Detection team looking for the key problems in the market 
 Risk analysis 
 Market scans 
 Stakeholder dialogs 
 Consumer complaints 
 Other, please specify: 

7. 

 I don’t know 

9.  Based on your answer to 8, please explain briefly the process carried out by the Consumer 
Protection Authority you represent. 

10. After the control actions described in question 9 have revealed possible non-compliance 
cases, what is the next step taken by  the Consumer Protection Authority you represent? 

1. 
2. 

 Launch a formal investigation 
 Report problems to other authorities, please specify  

3. 

 Others, please specify: 

4. 

 I don’t know 

88 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
11.  In  case  the formal  investigation  confirms  the  violation,  what types of  sanctions do  you 
impose?  

Please rate all that apply, starting from number 1 as the most frequent 

1. 
2. 
3. 

4. 
5. 
6. 

 Warning 
 Fine 
 Mandatory publication by the violator of your resolution and/or of its statement 

of rectification of non-compliance 
 Compensation to consumer 
 Removal of products 
 Other, please specify: 

7. 

 I don’t know 

12. Do you undertake any additional steps after an observed violation? 

1. 
2. 
3. 
4. 

 Assess the root causes 
 Assess if violation is a symptom of a larger problem in the market 
 Launch awareness campaigns 
 Other, please specify: 

5. 

 I don’t know 

13. Is there a procedure of appeal by the party who has been sanctioned for non-compliance 
issues related to voluntary claims on fishery and aquaculture products? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

14. If yes, which is the authority in charge of the appeal procedure? 

1. 
2. 
3. 
4. 

 The Consumer Protection Authority that  you represent  
 Another administrative authority, please specify 
 Judicial authority, please specify 
 I don’t know 

15. What is the time limit for you to complete each of the following steps: 

1.  Preliminary investigation 

89 

 
 
 
 
 
 
 
 
2. 

Investigation 

3. 

Imposition of sanctions 

4.  Reporting to other competent sectoral authority 

Non-compliance and violations  

16.  What  are  the  most  common  non-compliance  issues  of  voluntary  claims  on  fishery  and 
aquaculture products? 

Please rate  starting from the most frequent  

1. 
2. 
3. 
4. 

 Ambiguous or unclear voluntary claims 
 Not verifiable voluntary claims 
 Untruthful voluntary claims 
 Other, please specify: 

5. 

 I don’t know 

17. The voluntary claims on fishery and aquaculture products that face non-compliance issues 
are most often concerning which topics? 

Please rate all that apply, starting from number 1 as the most frequent 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 

90 

 
 
 
 
 
 
 
 
 
13. 

 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

18. What is the estimated percentage of controls that lead to sanctions due to non-compliance 
with the regulations relating to voluntary claims on fishery and aquaculture products. 

19. To what extent do you agree with the following statements, based on what controls have 
shown? 

e
e
r
g
a
y
l
l

a
t
o
t

I

t
o
n

o
d

I

t
o
n

o
d

,
e
e
r
g
a

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

3rd-party  certified  schemes  are,  overall,  more 
compliant to the regulations and requirements 
that  relate  to  the  clarity,  verifiability,  non-
ambiguity and truthfulness of voluntary claims 
than self-declared schemes. 

Public schemes are, overall, more compliant to 
the  regulations  and  requirements  that  relate 
to the clarity, verifiability, non-ambiguity and 
truthfulness  of  voluntary  claims  than  private 
schemes. 

to 

Non-compliance 
and 
requirements  that  relate  to  the  clarity, 
verifiability, non-ambiguity and truthfulness of 
voluntary claims is increasingly problematic. 

regulations 

Complaints 

20. With regard to complaints that you receive regarding voluntary claims on fish products, 
what has been the trend over the past 10 years? 

91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. 
2. 
3. 
4. 

 An increase 
 A decrease 
 It remained stable 
 I don’t know 

21. Who do you mostly receive these complaints from? 

Please rate starting from most frequent 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 

 Fishery or aquaculture organizations 
 Fish producers and packagers 
 Traders 
 Retailers  
 Consumers 
 Consumer organizations 
 NGOs 
 Other, please specify  
 I don’t know 

22. What kind of complaints do you receive with regards to voluntary claims on fishery and 
aquaculture products? 

Please rate starting from most frequent 

1. 
2. 
3. 
4. 

 Ambiguous or unclear voluntary claims 
 Not verifiable voluntary claims 
 Untruthful voluntary claims 
 Other, please specify: 

5. 

 I don’t know  

23.  What  is  the  estimate  percentage  of  complaints  that  lead  to  sanctions  due  to  non-
compliance  with  the  regulations  relating  to  voluntary  claims  on  fishery  and  aquaculture 
products. 

92 

 
 
 
 
 
 
 
 
 
 
Cooperation With Other Authorities 

24. Do you cooperate with other authorities to control the compliance with the regulations 
relating to voluntary claims on fishery and aquaculture products? 

1. 

 Yes, please specify which authority: 

2. 
3. 

 No 
 I don’t know 

25. What type of cooperation do you carry out with other authorities? 

1. 
2. 
3. 
4. 
5. 

 Preliminary investigation 
 Investigation 
 Imposition of sanctions 
 Reporting 
 Other, please specify: 

6. 

 I don’t know  

Overall evaluation of enforcement situation and suggestions  

26. What are the problems that you face in conducting your actions regarding compliance with 
voluntary claims on fishery and aquaculture products?  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 

 Collaboration with legislators 
 Control of actors 
 Preliminary investigation 
 Investigation 
 Enforcement 
 Cooperation with other authorities 
 Other, please specify: 

8. 

 I don’t know 

27.  In  what  way  could  the  compliance  to  regulations  on  voluntary  claims  on  fishery  and 
aquaculture products be improved?  

Please indicate all that apply 

93 

 
 
 
 
 
 
 
1. 

2. 

3. 
4. 
5. 
6. 

 More/better defined powers and competences of the Consumer Protection 

Authority that  you represent 

 Adoption/improvement of a Performance Plan or Program by the Consumer 

protection authority that you represent 

 Legislative process 
 Enforcement process 
 Cooperation with other authorities 
 Other, please specify: 

7. 

 I don’t know 

Feedback and comments 

28.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

29. Do you have contact details of other consumer protection authorities that we should invite 
for this survey? 

30. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

94 

 
 
 
           
 
 
 
           
 
 
 
           
 
 
 
 
2.2  Consumer Watchdogs 

Survey on Consumer Protection in Relation to Voluntary Claims on Fishery 
and Aquaculture Products 

This survey is about the protection by the relevant EU Member State authority of consumers 
facing voluntary claims on fishery and aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform the 
consumer about the product (for example: sustainability claim, traceability claim, or health 
claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the consumer organisation you represent:  

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Voluntary Claims of Fish Products 

3.  Has  your  organisation  commissioned  any  studies  related  to  voluntary  claims  on  fish 
products? 

1. 

 Yes, namely: 

2. 
3. 

 No 
 I don’t know 

4. What are in your opinion the main benefits of voluntary claims for consumers who buy fish 
products with such claims?  

5. What are in your opinion the main risks of voluntary claims for consumers who buy fish 
products with such claims?  

6.  Has  your  organisation  ever  received  complaints  regarding  claims  that  appear  on  fish 
products? 

1. 
2. 
3. 

 Yes  
 No (Please continue with question 14) 
 I don’t know 

96 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7. Within the past year, how many complaints (estimate) did you receive regarding voluntary 
claims on fish products?  

8. Considering the past 10 years, have you seen a trend in the number of complaints regarding 
voluntary claims on fish products? 

1. 
2. 
3. 
4. 
5. 

 An increase 
 A decrease 
 It remained stable 
 No trend 
 I don’t know 

9. Compared to other food groups, do fish products receive more or less complaints about 
voluntary claims? 

1. 
2. 
3. 
4. 

 More complaints about fish products 
 Less complaints about fish products 
 Similar 
 I don’t know 

10. What kind of complaints regarding voluntary claims on fish products did you receive? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

 Confusing, unclear information 
 Misleading information 
 Not verifiable 
 Lacking information 
 Other, namely:  

6. 

 I don’t know 

97 

 
 
 
 
 
 
 
 
 
 
 
11. Overall, complaints about voluntary schemes on fish products were often related to which 
topic? 

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

12. Overall, complaints were most often related to which classification of fish products? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 

 Live, fresh/chilled fish products 
 Frozen fish products 
 Dried, salted, in brine, smoked fish products 
 Otherwise preserved or prepared (i.e. canned or jarred) fish products 
 There is no trend 
 I do not know 

98 

 
 
 
 
 
13. What kinds of action were undertaken by your organisation to handle the complaints? 

Regulations & Requirements 

14. Do you know of any regulations and requirements that relate to the clarity, verifiability, 
non-ambiguity and truthfulness of voluntary claims on fish products? 

1. 

 Yes, I am aware of the following regulations and requirements: 

2. 
3. 

 No (Please continue with question 21) 
 I don’t know 

15. In your opinion, are these regulations and requirements effectively implemented (i.e. are 
they followed)? 

1. 
2. 

 Yes 
 No. Please explain how regulations and requirements could be improved:  

3. 

 I don’t know 

16.  Does  your  organisation  test  compliance  to  regulations  and  requirements  of  voluntary 
claims on fish products? 

1. 
2. 
3. 

 Yes  
 No 
 I don’t know 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
17.  Does  your  organisation  interact  with  consumer  protection  authorities  when  suspected 
cases of non-compliances are found? 

1. 
2. 

 Yes 
 No, because: 

3. 

 I don’t know 

18. Does your organisation disseminate information on existing regulations and requirements 
of fish products to different operators in the supply chain? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

19. Does your organisation inform consumers about their rights in terms of regulations and 
requirements on voluntary claims on fish products? 

1. 

 Yes, namely by: 

2. 

 No, because: 

3. 

 I don’t know 

100 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
20. Does your organisation provide comparison tools for voluntary claims on fish products? 

1. 

 Yes, namely: 

2. 

 No, because: 

3. 

 I don’t know 

Trends 

21.  To  what  extent  do  you  agree  with  the  following  statements  regarding  claims  on  fish 
products? 

e
e
r
g
a
y
l
l

a
t
o
t

I

e
e
r
g
a
I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d
y
l
l

a
t
o
t

I

w
o
n
k

t
’
n
o
d

I

« Over the last 10 years, the number of fish 
products with voluntary claims has increased 
steadily. » 

« There have been actions by NGOs that can 
be  linked  to  an  increase  in  the  use  of  fish 
products with voluntary claims. » 

«  The  fish  supply-chain  receives  pressure 
from consumers to use voluntary claims. » 

«  Voluntary  claims  on  fish  products  are  a 
good development for consumers. » 

101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
« There is a trend of self-declared claims in 
fish  products  moving  towards  third-party 
certification. » 

«  Over  the  past  10  years,  the  number  of 
fish  products  with 
problems  regarding 
voluntary claims has increased. » 

23. What are in your opinion good or best practices when it comes to voluntary claims on fish 
products, and why? 

Feedback & Comments 

24.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

25. Do you have contact details of other consumer watchdogs that we should invite for this 
stakeholder survey? 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
26. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

103 

 
 
 
 
 
 
 
 
2.3  Certification Bodies 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumer facing (business to consumer) voluntary claims on fishery and 
aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform the 
consumer about the product (for example: sustainability claim, traceability claim, or health 
claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the certification body you represent:  

3. This certification body is:  

1. 
2. 

3. 
4. 

 accredited by a national accreditation body 
 accredited by an accreditation body which is a signatory to the multilateral 

recognition agreement (MLA) for product certification of the International 
Accreditation Forum (IAF) 

 not accredited 
 other: 

104 

 
 
 
 
 
 
 
 
 
 
 
4. Is there a subsidiary organisation to your organisation that is a scheme owner? 

1. 

 Yes, of the following schemes: 

2. 
3. 

 No  
 I don’t know 

Certification of Schemes 

5. How many schemes related to fishery and aquaculture products (hereafter referred to as 
fish products) is your certification body issuing certificates for? 

Please indicate all that apply 

1. 

2. 

3. 
4. 

 An estimated 

fish products. 

 An estimated  

fish products. 

 privately managed schemes relating to 

 publicly managed schemes relating to 

 We do not issue schemes related to fish products (end of survey) 
 I don’t know 

6. To which category/categories of voluntary claims do the majority of these schemes belong? 

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 

105 

 
 
 
 
 
 
 
 
 
 
 
 
13. 

 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

7. What types of fish products does your certification body issue certificates for? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

 Live, fresh/chilled fish products 
 Frozen fish products 
 Dried, salted, in brine, smoked fish products 
 Otherwise preserved (i.e. canned or jarred) fish products 
 I don’t know 

Certifications 

8. How many certifications under a given scheme on fish products do you grant every year? 

Number  of 
granted 
(estimated) 

certifications 
last  year 

in  the 

Schemes on fish products your certify 

1 

2 

3 

4 

5 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
9.  On  average,  how  often  do  you  audit  compliance  of  certified  fish  products  with  the 
scheme(s)? 

1. 
2. 
3. 
4. 
5. 
6. 

 At least once every 12 months 
 Every 1 – 2 years 
 Once every 2 years 
 Less than once every two years 
 Conformity is audited only once 
 I don’t know 

10. In the last year, how many audits of fish products highlighted non-compliance issues with 
the specifications of the scheme(s) they carry?  

                                                             (Please fill in in percentages)  

11. Which are the most common reasons for non-compliance with the specifications of the 
scheme(s)? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

 Complexity of the certification procedure 
 Complexity of the requirements / specifications of a scheme 
 Costs of certification 
 Other, namely: 

5. 

 I don’t know 

12.  What  is  your  standard  procedure  for  dealing  with  cases  of  non-compliance  with 
specifications of the scheme(s) on fish products?  

Trends 

13. To what extent do you agree with the following statements on voluntary claims on fish 
products? 

107 

 
 
 
 
 
 
 
 
 
 
 
,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
I

e
e
r
g
a
s
i
d
y
l
l

a
t
o
t

I

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
y
l
l

a
t
o
t

I

«  Over  the  last  10  years,  the  number  of 
voluntary  claims  on  fish  products  has 
increased steadily. » 

«  Over  the  last  10  years,  the  number  of 
certification  applications  for  schemes  on 
fish has increased steadily. »  

«  Over  the  past  10  years,  the  number  of 
problems  regarding  fish  products  with 
voluntary claims has increased. »  

Self-declared claims 

14. Do you agree with the following statements on self-declared claims (defined as claims that 
have not been certified by an accredited certification body) on fish products? 

e
e
r
g
a
y
l
l

a
t
o
t

I

e
e
r
g
a
I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d
y
l
l

a
t
o
t

I

w
o
n
k

t
’
n
o
d

I

«  Over  the  last  10  years,  the  number  of 
self-declared  claims on  fish  products has 
increased steadily. » 

«  Self-declared  claims  are  a  positive 
development 
and 
aquaculture industry. » 

fishery 

the 

in 

«  More  claims  on  fish  products  are  self-
declared certified now than 10 years ago. 
» 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
15.  What  are,  in  your  opinion,  the  main  benefits  of  third-party  certification  for  scheme 
owners? 

16. What are, in your opinion, the main disadvantages of third-party certification for scheme 
owners? 

Feedback & Comments 

17.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
18.  Do  you  have  contact  details  of  other  certification  bodies  that  we  should  invite  for  this 
stakeholder survey? 

19. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
2.4 

Fishery and Aquaculture Producers 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumer facing (business to consumer) voluntary claims on fishery and 
aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform 
the  consumer  about  the  product  (for  example:  sustainability  claim,  traceability  claim,  or 
health claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the fishery and aquaculture producer you represent:  

Use of Schemes 

3. Do you sell any fish products carrying consumer facing voluntary claims? 

1. 
2. 
3. 

 Yes 
 No (Please continue with question 12) 
 I don’t know 

111 

 
 
 
 
 
 
 
 
 
 
 
 
4. Do you sell fish products carrying consumer facing schemes certified by an independent 
accredited certification body? 

1. 

 Yes, namely the following schemes:  

2. 
3. 

 No 
 I don’t know 

5. Do you sell fish products carrying any other self-declared consumer facing schemes that are 
not certified by an independent accredited certification body? 

1. 

 Yes, namely the following schemes: 

2. 
3. 

 No 
 I don’t know 

6. If you sell fish products carrying any type of scheme, on which type of fish products are 
these schemes used?  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

  Live, fresh/chilled fish products 
  Frozen fish products 
  Dried, salted, in brine, smoked fish products 
  Otherwise preserved (i.e. canned or jarred) 
 I don’t know 

112 

 
 
 
 
 
 
 
 
 
 
 
 
7. If you sell fish products, what is the information these schemes convey?  

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

8. What are the main reasons that led your company to differentiate your fish products with 
a scheme? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 

 The voluntary claims underline the values of the company 
 Quality assurance (e.g. regulated quality standards) our company upholds  
 It is a vital part of our marketing strategy 
 Increasing profit margin for our company 
 Increasing market access 
 Improving reputation and trustworthiness towards our customers  
 Demand of our clients 
 Demand of NGOs and other interest groups 
 Other reasons, namely:  

10. 

 I don’t know 

113 

 
 
 
9. How does your company learn about new potential schemes for your products? 

1. 
2. 
3. 
4. 

5. 

6. 
7. 

 We are approached by scheme owners 
 We are approached by NGOs 
 We are approached by government organisations 
 We are approached by consumers or consumer organisations 
 We are approached by our clients 
 We actively seek out potential claims for our products 
 Other, namely: 

8. 

 I don’t know 

10.  In  your  opinion,  what  are  the  main  benefits  for  you  company that  derive  from  adding 
voluntary claims in the form of schemes to your products? 

11. In your opinion, what are the main barriers your company faces to add voluntary claims in 
the form of schemes to your products?  

12. If you don’t add any schemes to your fish products, what are the reasons for this? 

114 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Scheme Requirements 

13. If you product carries a 3rd-party certification scheme, how often is your company audited 
for conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

14.  If  a  product  carries  a  self-declared  scheme,  how  often  is  your  company  reviewed  for 
conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

15.  To  what  extent  do  you  agree  with  the  following  statements  regarding  messages, 
specifications and requirements of schemes on the fish products your company produces? 

e
e
r
g
a
y
l
l

a
t
o
t

I

e
e
r
g
a
I

o
d

,
e
e
r
g
a
t
o
n
o
d

I

e
e
r
g
a
s
i
d
t
o
n

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d
y
l
l

a
t
o
t

I

w
o
n
k

t
’
n
o
d

I

« The information that the schemes provide to 
the consumer is clear and unambiguous. » 

« The information that the schemes provide to 
the consumer is verifiable. » 

«  The  specifications  of  the  scheme  are 
available, clear, detailed. » 

115 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
« The procedures of certification for 3rd party 
certified  schemes  are  available,  clear  and 
detailed. » 

Trends 

16.  To  what  extent  do  you  agree  with the  following  statements  regarding  schemes  on fish 
products? 

e
e
r
g
a
y
l
l

a
t
o
t

I

,
e
e
r
g
a

t
o
n

o
d

I

t
o
n

o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

«  Over  the  last  10  years,  the  number  of  fish 
products  that  carry  schemes  has  increased 
steadily. » 

« There have been actions by NGOs that can be 
linked to an increase in the use of fish products 
that carry schemes. » 

«  Fishery  and  aquaculture  producers  receive 
pressure from NGOs to carry schemes on fish 
products. » 

«  Fishery  and  aquaculture  producers  receive 
pressure from their clients to sell fish products 
that carry schemes. » 

«  Fishery  and  aquaculture  producers  receive 
pressure 
from  consumers  or  consumer 
organisations  to  sell  fish  products  that  carry 
schemes. » 

116 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regulations & Requirements 

17. Are you aware of any regulations and requirements that relate to the clarity, verifiability, 
non-ambiguity and truthfulness of voluntary claims on fish products? 

1. 

 Yes, namely: 

2. 

3. 

 No 
 I don’t know 

Feedback & Comments 

18.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

19. Do you have contact details of other fishery and aquaculture producers that we should 
invite for this stakeholder survey? 

117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
20. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

118 

 
 
 
 
 
 
 
 
2.5 

Import Associations 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumers facing voluntary claims on fishery and aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform the 
consumer about the product (for example: sustainability claim, traceability claim, or health 
claim). 

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the import association you represent:  

3. How many companies does your association represent? 

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4. What is the estimated total volume of fish products that imported by the companies your 
association represents? 

Voluntary Claims 

5.  What  is  the  total  estimated  share  of  fish  products  that  carry  consumer  facing  voluntary 
claims that the companies your association represents import? 

1. 
2. 
3. 
4. 
5. 

 Over 50% 
 Around 50% 
 Under 50% 
 None (please continue with question 15) 
 I don’t know 

6. What is the estimate share of fish products that carry consumer facing  3rd party certified 
claims imported by the companies represented by your association? 

7.  What  percentage  of  fish  products  with  voluntary  claims  that  your  companies  import 
continue to carry these voluntary claims when sold to their clients? 

8.  Which  type  of  fish  products  with  voluntary  claims  do  the  companies  your  association 
represents import the most?  

Please indicate all that apply 

1. 
2. 
3. 
4. 

  Live, fresh/chilled fish products 
  Frozen fish products 
  Dried, salted, in brine, smoked fish products 
  Otherwise preserved (i.e. canned or jarred) 

120 

 
 
 
 
 
 
 
 
 
 
 
 
 
9.  Which  information  does  these  voluntary  claims  on  fish  products  the  companies  your 
association represents convey?  

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

10.  What  are  the  main  reasons  the  companies  you  represent  import  fish  products  with 
voluntary claims? 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

 The voluntary claims underline the values of our company 
 Quality assurance (e.g. regulated quality standards) our company upholds  
 Part of our marketing strategy 
 Increasing profit margin for our company 
 Increasing market access  
 Improving reputation and trustworthiness towards our customers  
 Pressure from our customers 
 Pressure from NGOs and other interest groups 
 This is made available by the supplier 
 Other reasons, namely:  

11. 

 I don’t know 

121 

 
 
 
11. In your opinion, what are the main benefits for the companies you represent to import 
fish products with voluntary claims?  

12. In your opinion, what are the main barriers for the companies you represent to import 
fish products with voluntary claims?  

13. If the companies you represent do not import fish products with voluntary claims, what 
are the main reasons for this? 

122 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Scheme Requirements 

14.  To  what  extent  do  you  agree  with  the  following  statements  regarding  messages, 
specifications  and  requirements  of  voluntary  claims  on  the  fish  products  your  members 
import? 

e
e
r
g
a
y
l
l

a
t
o
t

I

,
e
e
r
g
a
t
o
n
o
d

I

t
o
n

o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

The  information  that  the  schemes  provide  to 
the consumer is clear and unambiguous. 

The  information  that  the  schemes  provide  to 
the consumer is verifiable. 

The specifications of the scheme are available, 
clear, detailed. 

The  procedures  of  certification  for  3rd  party 
certified  schemes  are  available,  clear  and 
detailed. 

Trends 

15. To what extent do you agree with the following statements regarding voluntary claims on 
fish products? 

e
e
r
g
a
y
l
l

a
t
o
t

I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

Over  the  last  10  years,  the  number  of  fish 
products  with  voluntary  claims  has  increased 
steadily. 

There have been actions by NGOs that can be 
linked to an increase in the use of fish products 
with voluntary claims. 

Import  organizations  receive  pressure  from 
NGOs to use voluntary claims. 

Import  organizations  receive  pressure  from 
their customers to use voluntary claims. 

123 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Import  organizations  receive  pressure  from 
their consumers to use voluntary claims. 

Regulations & Requirements 

16. Do you know of any regulations and requirements that relate to the clarity, verifiability, 
non-ambiguity and truthfulness of voluntary claims on fish products? 

1. 

 Yes, I am aware of the following regulations and requirements:  

2. 
3. 

 No, I am not aware of any regulations and requirements (continue to question 18) 
 I don’t know 

17. In your opinion, are these regulations and requirements effectively implemented (i.e. are 
they followed)? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

Feedback & Comments 

19.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

124 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
20.  Do  you  have  contact  details  of  other  import associations  that  we  should  invite for this 
stakeholder survey? 

18. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

125 

 
 
 
 
 
 
 
 
 
 
 
 
 
2.6 

Processing and Packaging Companies 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumers facing (business to consumer) voluntary claims on fishery and 
aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform 
the  consumer  about  the  product  (for  example:  sustainability  claim,  traceability  claim,  or 
health claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the processing / packaging company you represent:  

3.  Which  type  of  Fishery  and  Aquaculture  Products  (hereafter  fish  products)  does  your 
company process or sell? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

  Live, fresh / chilled fish products 
  Frozen fish products 
  Dried, salted, in brine, smoked fish products 
  Otherwise preserved (i.e. canned or jarred) 

126 

 
 
 
 
 
 
 
 
 
 
 
Voluntary Claims Coming From Supplier 

4. Does your company process or package fish products that already carry consumer facing 
voluntary claims when coming from your supplier?  

1. 

 Yes, namely the following voluntary claims: 

2. 
3. 

 No (Please continue to question 10) 
 I don’t know 

5. What percentage of these fish products that carry voluntary claims from the supplier still 
carry these claims after processing / packaging? 

1. 
2. 
3. 
4. 
5. 

 More than 75% 
 Between 50% – 75% 
 Around 50% 
 Between 25% – 50% 
 Less than 25% 

6. On which classification of fish products does your company carry voluntary claims that came 
from the supplier?  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

  Live, fresh / chilled fish products 
  Frozen fish products 
  Dried, salted, in brine, smoked fish products 
  Otherwise preserved (i.e. canned or jarred) 
 I don’t know 

127 

 
 
 
 
 
 
 
 
 
 
 
7. What information do the voluntary claims on fish products that come from your supplier 
convey? 

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

8. What type of schemes do the fish products you buy carry when coming from your supplier? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

 Certified by a 3rd-party certification body 
 Not certified but self-declared 
 I don’t know 
 Not applicable 

9. What are the main reasons your company sources fish products with voluntary claims? 

Please indicate all that apply 

1. 
2. 
3. 

 The voluntary claims underline the values of the company 
 Quality assurance (e.g. regulated quality standards) our company upholds  
 Part of our marketing strategy 

128 

 
 
 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 

 Increasing profit margin for our company 
 Increasing market access  
 Improving reputation and trustworthiness towards our customers  
 Pressure of wholesalers and retailers 
 Pressure of the Civil Society (being NGOs and other interest groups) 
 Pressure from consumers 
 This is offered by our suppliers 
 Other reasons, namely:  

12. 

 I don’t know 

Use of Other Voluntary Claims 

10. Does your company place any other consumer facing voluntary claims on the fish products 
it produces? 

1. 

 Yes, namely: 

2. 
3. 

 No (Please continue with question 18) 
 I don’t know 

11. On which type of fish products does your company place other voluntary claims?  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

  Live, fresh/chilled fish products 
  Frozen fish products 
  Dried, salted, in brine, smoked fish products 
  Otherwise preserved (i.e. canned or jarred) 
I don’t know 

129 

 
 
 
 
 
 
 
 
 
 
12. What are the topics covered by these voluntary claims that your company places on fish 
products? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 
14. 
15. 
16. 
17. 
18. 

 Allergen (free), other than mandatory allergen information (e.g. gluten free) 
 Food safety  
 Health and nutrition  
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information 
 Organic production methods 
 Origin claims, other geographical indication 
 More detailed information on fishing gear 
 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims / unclassified  
 I don’t know 

13. If the voluntary claim you place on the product is a scheme, how are the schemes on the 
fish products you process or package certified? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

 Certified by a 3rd-party certification body 
 Self-declared 
 I don’t know 
 Not applicable 

14. What are the main reasons your company places additional voluntary claims on their fish 
products? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

 The voluntary claims underline the values of the company 
 Quality assurance (e.g. regulated quality standards) our company upholds  
 Part of our marketing strategy 
 Increasing profit margin for our company 

130 

 
 
 
5. 
6. 
7. 
8. 
9. 
10. 

 Increasing market access  
 Improving reputation and trustworthiness towards our customers  
 Pressure from wholesalers and retailers 
 Pressure from NGOs and other interest groups 
 Pressure from consumers 
 Other reasons, namely:  

11. 

 I don’t know 

15.  In  your  opinion,  what  are  the  main  benefits  for  processing/packaging  companies  to 
produce fish products with voluntary claims?  

16. In general, what are the main barriers for processing / packaging companies / associations 
to produce fish products with voluntary claims?  

Scheme Requirements 

17. Has your company ever been audited for conformity with the requirements of schemes 
placed on products by your supplier? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

131 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
18. If your product carries a 3rd-party certification scheme on your product, how often is your 
company audited for conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

19.  If  your product  carries  a  self-declared  scheme,  how  often  is  your  company audited for 
conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

20. Do you provide the following information about the voluntary claims or schemes on your 
products? 

Information provided via: 

Information 
not provided 

Our 
website 

packaging 

on request 

Logo of the voluntary claim 

Link to the website of the voluntary 
claim 

Scheme contents 

Scheme requirements 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
21.  To  what  extent  do  you  agree  with  the  following  statements  regarding  messages, 
specifications and requirements about voluntary claims on the fish products your company 
produces? 

e
e
r
g
a
y
l
l

a
t
o
t

I

e
e
r
g
a
I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
s
i
d

I

« The information that the schemes provide to 
the consumer is clear and unambiguous. » 

« The information that the schemes provide to 
the consumer is verifiable. » 

«  The  specifications  of  the  scheme  are 
available, clear, detailed. » 

« The procedures of certification for 3rd party 
certified  schemes  are  available,  clear  and 
detailed. » 

No Addition of Voluntary Claims 

22. What are, in your opinion, the main reasons your company does not add voluntary claims 
to your products? 

23. What are, in your opinion, the main barriers for your company to add voluntary claims to 
your products?  

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Trends 

24. To what extent do you agree with the following statements? 

e
e
r
g
a
y
l
l

a
t
o
t

I

,
e
e
r
g
a

t
o
n
o
d

I

t
o
n

e
e
r
g
a
s
i
d

o
d

e
e
r
g
a
s
i
d

I

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

« Over the last ten years, the number of 
fish  products  with  voluntary  claims  has 
increased steadily. » 

« There have been actions by NGOs that 
can be linked to an increase in the use of 
fish products with voluntary claims. » 

«  Processing  and  packaging  companies 
receive  pressure  from  NGOs  to  use 
voluntary claims. » 

«  Processing  and  packaging  companies 
receive pressure from their customers to 
use voluntary claims. » 

«  Processing  and  packaging  companies 
receive  pressure  from  consumers  to  use 
voluntary claims. » 

Regulations & Requirements 

25. Are you aware of any regulations and requirements as regards the clarity, verifiability, non-
ambiguity and truthfulness of voluntary claims on fish products? 

1. 

 Yes, namely: 

2. 
3. 

 No 
 I don’t know 

134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
26.  Does  your  company  take  any  measure  to  warrant  that  the  fish  products  you  sell  with 
voluntary claims comply with these requirements? 

1. 

 Yes, namely by: 

2. 

 No, because: 

3. 

 I don’t know 

27. In your opinion, are these regulations and requirements effectively implemented (i.e. are 
they followed)? 

1. 
2. 
3. 

 Yes 
 No 
 I don’t know 

Feedback & Comments 

28.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

29. Do you have contact details of other processing/packaging companies/associations that 
we should invite for this stakeholder survey? 

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
30. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

136 

 
 
 
 
 
 
 
 
 
2.7  Retailers 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumers facing voluntary claims on fishery and aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform 
the  consumer  about  the  product  (for  example:  sustainability  claim,  traceability  claim,  or 
health claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please fill in the name of the retailer you represent:  

3. What type of fishery and aquaculture products (hereafter called fish products) does your 
sell?  
company 
Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 

 Live, fresh/chilled fish products 
 Frozen fish products 
 Dried, salted, in brine, smoked fish products 
 Otherwise preserved (i.e. canned or jarred) fish products 
 We don’t sell any fish products (End of survey) 
 I do not know  

137 

 
 
 
 
 
 
 
 
 
 
Voluntary Claims on Products  

4. Does your company sell fish products with any voluntary claims? 

Please indicate all that apply 

1. 
2. 
3. 
4. 

5. 

 Yes, we sell live, fresh/chilled fish products with voluntary claims 
 Yes, we sell frozen fish products with voluntary claims 
 Yes, we sell dried, salted, in brine, smoked fish products with voluntary claims 
 Yes, we sell otherwise preserved (i.e. canned or jarred) fish products with 

voluntary claims 

 No, our fish products do not carry any voluntary claims, because: 

(Please continue with question 21) 

6. 

 I do not know 

5. Are voluntary claims more present in one or the other type of products? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 

 Yes, more present on live, fresh/chilled fish products 
 Yes, more present on of frozen fish products 
 Yes, more present on dried, salted, in brine, smoked fish products 
 Yes, more present on otherwise preserved (i.e. canned or jarred) fish products 
 No  
 I do not know 

6. What are the most common topics covered by the voluntary claims on fish products sold in 
your stores? 

Please indicate all that apply 

1. 

2. 
3. 
4. 
5. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 

138 

 
 
 
 
 
 
 
 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

7.  What  are the  most  common  voluntary  claims  on fish products  your company sells  in  its 
stores and their estimated share of sales out of all fish products your company sells?  

Name of voluntary claim 

Share of sales  

1 

2 

3 

4 

8.  What  are  the  reasons/benefits  for  your  company  to  sells  fish  products  with  voluntary 
claims? 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

 The voluntary claims underline the values of our company 
 Quality assurance (e.g. regulated quality standards) our company upholds  
 Part of our marketing strategy 
 Increasing profit margin for our company 
 Increasing sales  
 Improving reputation and trustworthiness towards our customers  
 Pressure from our customers 
 Pressure from NGOs or other interest groups 
 This is made available by the supplier 
 Other reasons, namely: 

139 

 
 
 
 
 
 
 
 
 
 
 
 
11. 

 I don’t know 

9. What barriers are there for your organisation to sell fish products with voluntary claims?  

Voluntary Claims on Products Actively Sought 

10. Which of the statements applies better to your company? 

1. 
2. 

3. 

 Our company has an active policy of buying fish products with voluntary claims 
 Our company considers voluntary claims important for some specific fish 

products 

 Our company considers voluntary claims as a feature on fish products that does 

not influence our purchase decisions. 

11. If your company does not actively seek fish products with voluntary claims, what are the 
reasons for this? 

Please continue with question 14 

12. If your company actively seeks voluntary claims, what type of voluntary claims does are 
these? 

Please indicate all that apply 

1. 

 3rd party certified schemes, namely: 

140 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. 
3. 

 Self-declared schemes 
 I don’t know 

13. Does your organisation have influence on the voluntary claims that your suppliers include 
on the packaging of the fish products you buy? 

1. 
2. 
3. 
4. 

 Yes 
 To some extent 
 No 
 I don’t know 

14. What percentage of fish products you buy from the supplier that carry voluntary claims 
still carry these claims when you sell them to your costumers? 

1. 
2. 
3. 
4. 
5. 
6. 

 More than 75% 
 Between 50% – 75% 
 Around 50% 
 Between 25% – 50% 
 Less than 25% 
 I don’t know 

Additional Voluntary Claims on Products  

15. Does your organisation place additional voluntary claims on fish products after they have 
come from your supplier? 

1. 
2. 

 Yes, we place additional self-declared voluntary claims on fish products 
 Yes, we place additional 3rd party certified schemes on fish products, namely: 

3. 

 No, because: 

4. 

 I don’t know 

141 

 
 
 
 
 
 
 
 
 
 
Transparency of Voluntary Claims and Schemes 

16. If your product carries a 3rd-party certification scheme, how often is your company audited 
for conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

17. If your product carries a self-declared scheme, how often is your company reviewed for 
conformity with the specifications of the scheme? 

1. 
2. 
3. 
4. 
5. 
6. 

 Only once 
 At least once a year 
 Every one to two years 
 Less than every two years 
 I don’t know 
 Not applicable 

18.  To  what  extent  do  you  agree  with  the  following  statements  regarding  messages, 
specifications and requirements of voluntary claims on the fish products your company sells? 

e
e
r
g
a
y
l
l

a
t
o
t

I

t
o
n

o
d

I

t
o
n

o
d

,
e
e
r
g
a

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

The  information that  the  schemes provide  to 
the consumer is clear and unambiguous. 

The  information that  the  schemes provide  to 
the consumer is verifiable. 

The specifications of the scheme are available, 
clear, detailed. 

The  procedures  of  certification  for  3rd  party 
certified  schemes  are  available,  clear  and 
detailed. 

142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
19. If any of your fish products carry  schemes, how is the following information about the 
schemes provided? 

Information provided via: 

website  packaging 

in our 
stores 

folder 

on 
request 

Information 
not 
provided 

Contact 
information 

Scheme contents  

Scheme 
requirements 

Scientific 
documentation 

Certification 
procedure 

Details 
certification body 

of 

the 

Costs 
membership 
certification 
procedure 

of 
& 

20.  Is  your  organisation  in  partnership  with  an  NGO  who  is  involved  with  the  policy 
development of your organisation regarding the purchase of fish products? 

1. 

 Yes, namely: 

2. 
3. 

 No 
 I don’t know 

Regulations & Requirements 

21. Are you aware of any regulations and requirements as regards the clarity, verifiability, non-
ambiguity and truthfulness of voluntary claims on fish products? 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. 

 Yes, namely: 

2. 
3. 

 No 
 I don’t know 

22.  Does  your  company  take  any  measure  to  warrant  that  the  fish  products  you  sell  with 
voluntary claims comply with these requirements? 

4. 

 Yes, namely by: 

5. 

 No, because: 

6. 

 I don’t know 

Trends 

23. To what extent do you agree with the following statements. 

e
e
r
g
a
y
l
l

a
t
o
t

I

e
e
r
g
a
I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

e
e
r
g
a
s
i
d
y
l
l

a
t
o
t

I

w
o
n
k

t
’
n
o
d

I

Over the last 10 years, the number of fish products 
with voluntary claims has increased steadily 

There  have  been  actions  by  NGOs  that  can  be 
linked  to  an  increase  in  the  use  of  fish  products 
with voluntary claims 

Retailers  receive  pressure  from  NGOs  to  sell  fish 
products with voluntary claims 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Retailers receive pressure from consumers to sell 
fish products with voluntary claims 

Feedback & Comments 

24.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

25. Do you have contact details of other retailers or retailer organizations that we should invite 
for this stakeholder survey? 

26. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

145 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.8  Scheme Owners 

Survey on Voluntary Claims on Fishery and Aquaculture Products 

This survey is about consumers facing voluntary claims on fishery and aquaculture products.  

A voluntary claim is any type of non-mandatory information placed on a product to inform 
the  consumer  about  the  product  (for  example:  sustainability  claim,  traceability  claim,  or 
health claim).  

Different types of voluntary claims can be found on products.  

  They can be used in the form of a label or logo on a product, sometimes referred to as 
a scheme, and can be either certified by a 3rd-party certification body or self-declared. 
  Other types of voluntary claims can be found on the packaging of a product simply in 

the form of a statement or an image. 

General Information 

1. Please fill in your function or job title:  

2. Please indicate what type of organisation you are: 

Please indicate all that apply 

1. 

2. 
3. 
4. 

 Fishery / aquaculture 

Producer 

 Processing business 
 Distributor 
 Control Authority 

5. 
6. 
7. 
8. 

 Retailer 
 Trade organization 
 NGO 
 Public body 

9. 

 Certification 

body 

10. 
11. 

 Other 
 I don’t know 

3. Do you own a scheme that is currently featured on fish products? 

1. 
2. 
3. 
4. 
5. 

 Yes 
 No, but our scheme has featured on fish products in the past 
 No, but or scheme can feature on fish products  
 No, our scheme does not feature on fish products at all (End of survey) 
 I don’t know 

146 

 
 
 
 
 
 
 
 
Scheme Information 

3. How many schemes currently featured on fish products do you own?  

If you own more than 1 scheme, please focus the following questions on the scheme with the 
largest market share  

4. Does this scheme only feature on fish products? 

1. 
2. 
3. 

 Yes, only on fish products 
 On fish products and other food products 
 I don’t know 

5. Please fill in the name of the scheme you own: 

6. In which year was this scheme launched? 

7. In which EU countries does your scheme operate?  

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 

 EU 28 
 Austria 
 Belgium 
 Bulgaria 
 Croatia 
 Cyprus 
 Czechia 
 Denmark 
 Estonia 
 Finland 

11. 
12. 
13. 
14. 
15. 
16. 
17. 
18. 
19. 
20. 

 France 
 Germany 
 Greece 
 Hungary 
 Ireland 
 Italy 
 Latvia 
 Lithuania 
 Luxembourg 
 Malta 

21. 
22. 
23. 
24. 
25. 
26. 
27. 
28. 
29. 
30. 

 Poland 
 Portugal 
 Romania 
 Slovakia 
 Slovenia 
 Spain 
 Sweden 
 The Netherlands 
 United Kingdom 
 Other 

147 

 
 
  
 
 
 
 
 
 
 
 
8. In which three (if applicable) EU countries is your scheme most present on fish products? 
And how large would you estimate the market share of fish products carrying your scheme (in 
percentages)? 

Country (or EU) 

Market Share % 

1 

2 

3 

9. If your scheme operates in multiple countries, do you change the scheme or some of its 
features depending on the country?  

1. 
2. 
3. 

 Yes 
 No  (Please continue to question 11) 
 I don’t know 

10. To what extent do you change the scheme depending on the country in which your scheme 
operates (e.g. design of the logo, content of the message)? 

148 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
11. Which information does this scheme featured on fish products convey?   

Please indicate all that apply 

1. 

 Allergen (free), other than mandatory allergen information (e.g. gluten 

free/crossed grain) 

2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 
10. 
11. 
12. 
13. 

 Food safety (e.g. prepared under controlled conditions) 
 Health and nutrition (e.g. high in healthy omega 3) 
 Traceability (e.g. trace or tracking code) 
 Free of preservatives, colourings, flavourings, etc. (e.g. free of additives) 
 General/unspecified sustainability (e.g. sustainably produced) 
 Environmental responsibility (e.g. protection fish stocks) 
 Social responsibility (e.g. conditions of fishing vessels) 
 Animal welfare and animal health (e.g. no by-catch) 
 Religious dietary information (e.g. kosher, halal) 
 Organic production methods  
 Origin claims, other geographical indication (e.g. catch location) 
 More detailed information on fishing gear (e.g. individually caught by pole and 

line) 

14. 
15. 
16. 
17. 
18. 

 (Traditional) production methods (e.g. smoked over open fire) 
 Taste, product quality  
 Composition claims (e.g. boneless) 
 Other claims/unclassified 
 I don’t know 

12. On which type of fish products is your scheme featured? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

 Live, fresh / chilled fish products 
 Frozen fish products 
 Dried, salted, in brine, smoked fish products 
 Otherwise preserved (i.e. canned or jarred) fish products 
 I don’t know 

149 

 
 
 
 
 
 
13. Which is the main target group of your scheme in the supply chain? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 

 Producers 
 Processors 
 Retailers 
 Consumers 
 Others, namely: 

14. From whom do you receive royalties for using the scheme?  

Please indicate all that apply 

1. 
2. 

3. 

4. 

5. 

 Producers  
 Processors 
 Retailers 
 We do not receive any royalties 
 Others, namely:  

6. 

 I don’t know 

15. Who carries out the audit of compliance with the scheme provisions? 

1. 
2. 
3. 
4. 

 An independent accredited certification body 
 A non-accredited independent certification body 
 Our own organization (self-assessment) 
 The compliance is not controlled 

16. How often is conformity to the scheme provisions and the right to use the scheme logos 
and labels audited? 

1. 
2. 
3. 
4. 
5. 

 At least once every 12 months 
 Every 1 – 2 years 
 Less than once every two years 
 Conformity is audited only once 
 Conformity is not audited 

150 

 
 
 
 
 
 
 
 
6. 

 I don’t know 

17. Do you carry out combined audits or harmonized auditing protocols with other schemes?  

1. 
2. 
3. 
4. 

 Yes, we combine audits 
 Yes, we harmonized auditing protocols 
 None of the above 
 I don’t know 

Transparency 

18.  What  are  obstacles or  barriers  for those  organisations  who  wish  to obtain  certification 
under your scheme? 

19. How is the following information about your scheme provided? 

Information provided via: 

Information 
not provided 

website 

packaging 

on request 

Contact information 

Scheme contents  

Scheme requirements 

Scientific documentation 

Certification procedure 

Details  of  the  certification 
body 

Costs  of  membership  and 
certification procedure 

151 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
20. Are your scheme objectives and requirements reviewed or is feedback considered? 

1. 
2. 
3. 
4. 

 Yes, at least once a year 
 Yes, less than once a year 
 No 
 I don’t know 

21.  Are  other  actors  involved  in  the  development  of  your  scheme  objectives  and 
requirements? 

1. 
2. 
3. 
4. 
5. 

 Yes, consumers or consumer bodies 
 Yes, yes producers or retailer 
 Yes, experts or scientific bodies 
 No, no other stakeholders are involved 
 I don’t know 

Regulations and Requirements 

22. Do you know of any regulations and requirements that relate to the clarity, verifiability, 
non-ambiguity and truthfulness of voluntary claims on fish products? 

1. 

 Yes, I am aware of the following regulations and requirements:  

2. 
3. 

 No (Please continue with question 29) 
 I don’t know 

23. Does your scheme include a mechanism of checking for conformity with regulations and 
requirements that relate to your scheme? 

1. 

 Yes, namely: 

2. 

 No, because:  

3. 

 I don’t know 

152 

 
 
 
 
 
 
 
 
 
 
24. Has your organisation ever been tested for compliance to regulations and requirements 
of voluntary claims on fish products? 

1. 

 Yes, by: 

2. 
3. 

 No 
 I don’t know 

25. Did you encounter any difficulties in complying with these regulations and requirements?  

1. 
2. 
3. 

 Yes  
 No (Please continue with question 27) 
 I don’t know 

26. In which areas of these regulations and requirements did you encounter difficulties? 

Please indicate all that apply 

1. 
2. 
3. 
4. 
5. 
6. 
7. 

8. 
9. 

 Content of the scheme 
 Conformity assessment, certification and accreditation 
 Scheme participation and development 
 Clarity and transparency of scheme requirements  
 Evidence base of scheme claims and requirements 
 Truthfulness or verifiability of the scheme 
 Certification and inspections (e.g. impartiality and independence of certification, 

inspections, costs, qualification of auditors / inspectors, provisions for small-scale 
producers) 

 Mutual recognition and benchmarking / overlap with other schemes 
 Other area, namely: 

10. 

 I don’t know 

27. Do the existing regulations and requirements need improvement? 

1. 
2. 
3. 

 Yes 
 No (Please continue with question 29) 
 I don’t know  

153 

 
 
 
 
 
 
 
 
 
28. What are the areas that could be improved and how could this be achieved? 

Trends 

29. To what extent do you agree with the following statements regarding voluntary claims on 
fish products? 

e
e
r
g
a
y
l
l

a
t
o
t

I

,
e
e
r
g
a

t
o
n

o
d

I

e
e
r
g
a
s
i
d
t
o
n
o
d

e
e
r
g
a
s
i
d

I

y
l
l

a
t
o
t

I

e
e
r
g
a
s
i
d

w
o
n
k

t
’
n
o
d

I

e
e
r
g
a
I

«  Over  the  last  decade,  the  number  of  fish 
products  with  voluntary  claims  has  increased 
steadily. » 

« There have been actions by NGOs that can be 
linked to an increase in the use of fish products 
with voluntary claims. » 

«  In  general,  food  labelling  schemes  on  fish 
products  use  and  fully  comply  with  the 
regulations and requirements. » 

Feedback and Comments 

31.  Do  you  have  any  additional  information  or  literature  you  consider  relevant  to  address 
when considering voluntary claims on fish products? 

32.  Do  you  have  contact  details  of  other  scheme  owners  that  we  should  invite  for  this 
stakeholder survey? 

154 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
33. Do you have any comments or feedback that you would like to share regarding this survey 
on voluntary claims on fish products? 

Thank you for your participation 

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 2: Innova database 

1  Analysis of Innova database 

The  Innova database is a worldwide database  with information about a large amount of 
new food products that are launched in the retail market. For each new product entered in 
the database information on the packaging is collected and recorded according to a fixed 
template.  

The database has a  claims feature field that captures claims translated from the source 
language to English. New product entries do not solely refer to entirely new products in 
the retail market, but also products that are defined as new because their appearance or 
other characteristics have changed (as a results of a renewed logo, claim, new packaging 
etc). With the exception of Cyprus, Malta and Luxemburg, all EU countries are represented 
in the database. 

There  is  not  one  comprehensive  definition  of  ‘claims’  that  Innova  uses.  Generally,  all 
statements about the product that are not specifically captured in another field such as the 
ingredients or price field and scheme logos are considered claims.  

In the period January 2009 – July 2016, 13,746 fish and seafood products were entered in 
Innova  in  the  25  EU  Member  States  covered  by  the  tool.  These  products  were  divided 
between countries and years as depicted in the following figure. Spain, France, the United 
Kingdom, Germany and Italy are the countries with most products listed in the database. 
Some countries, especially Estonia, Bulgaria, Croatia, Slovenia and Slovakia are less well 
represented  in  the  database.  For  these  countries,  there  were  less  than  200  FAPs  per 
country over the period.  

156 

 
 
 
Figure 1    Number  of  fish  and  seafood  products  entered  in  the  Innova 
database, per year, 2009-2016 (2016 until July) (n=13,746), unweighted 

In the Innova database there are 13,746 fish and seafood products (during the period of 
interest) of which 3,248 do not contain any claims. The remaining 10,498 products carry 
a total of 25,763 claims (defined as strings of text separated by a period, exclamation mark 
or other end of sentence marker, that each can contain multiple claims e.g. “This product 
is new and improved and now contains more Omega-3 than before which is good for your 
health”). These 25,763 claims were reduced to 7,996 unique claim sentences, (of which 
1,694 were considered not to be voluntary claims (e.g. ‘microwave for 4 minutes’). Very 
near duplicates like ‘dolphin safe’, and ‘dolphin safe!’ were combined. After cleaning the 
database a total of 6,038 unique claims sentences are included in the database of voluntary 
claims. Many of these claims may still be different formulations of the same or nearly the 
same thing (e.g. ‘low fat’, ‘almost no fat’, ‘less fat’).  

The claims found on all FAPs in the Innova database during the period were all grouped 
into 16 different policy domains (Table 1). The categorisation of the claims sentences in 
one or several policy domains was made manually and involves a lot of expert judgement. 
Both fishery experts,  experts  on  retailing and experts  on various  sustainability schemes 
were involved. 

Table 1  

Policy domains 

157 

 
 
 
 
 
Policy area 

Examples of claims 

Allergen (free) claims 

Examples  of  claims  that  fall  under  this  category  are  “wheat  free”, 
“gluten free”, “dairy free”, “egg free” or “soy free”. 

Food safety 

Health and nutritional 
claims 

Traceability claims 

Free of preservatives, 
colourings, flavourings 

Only  claims  that  refer  to  the  product  not  containing  allergens  are 
considered here. 

Food safety is defined here as the conditions of handling, storing and 
preparing  food  to  prevent  infection  with  foodborne  illnesses.  An 
examples  of  claims  that  fall  under  this  category  are:  “guaranteed 
safety and hygienic product”. 

This category includes claims that claim benefits related to health or 
claim  information  on  the  nutritional  content  of  the  product.  Only 
permitted/listed or authorized health claims (Functional Health Claims 
and  Disease  Reduction  Health  claims)  under  Regulation  1924/2006 
may be used. Nutritional claims contain information on the nutritional 
content  of  the  product  (Art.  39(h)  CMO).  Only  permitted  nutrition 
claims  listed  in  the  Annex  of  and  in  compliance  with  Regulation 
1924/2006 may be used. Examples of claims that fall under this policy 
area are: “ “(…) helps maintain heart health”, “Contains phosphorus, 
vitamin B2, and vitamin B12”. 

Traceability claims are considered any text referencing the ability the 
trace  the  products  origin  or  whereabouts  during  the  distribution 
process.  The  coding  searched  for  words  like  ‘traceable’,  ‘trackable’, 
‘can be traced back’, etcetera.  

Claims indicating that preservatives, colourings, flavouring etc. have 
not been added to the product. Examples of claims under this category 
are  “free 
flavours”,  “  no  added 
preservatives”. 

from  artificial  colours  and 

Generic/Environmental 
sustainability 

The claims selected for this policy area refer to sustainability of/and 
responsibility  of  the  marine  environment  or  nature  in  general  (for 
example MSC, ASC, Friends of the Sea, …) 

Social responsibility 
claims 

Claims that purpose to have a positive impact on social aspects (such 
as the local  economy).  Examples of claims under  this category are: 
“Work with the cultivators for certification which meets requirements 
for  quality,  food  safety,  environmental  and  social  aspects”,  “(…) 
packed  locally  in  Maldives,  thus  supporting  the  resident  economy”, 
“Fish4Ever  only  work  with  local  boats  and  campaign  actively  for 
sustainable seas, better management and against illegal fishing” 

Animal welfare and 
animal health claims 

Claims that relate to animal welfare and animal health. Examples of 
claims under this category are Dolphin safe and Dolphin friendly.  

Organic production 
methods 

Claims  under  this  category  are,  for  example  “100%  organic”  or 
“certified organic”. 

Religious dietary laws 

Examples of claims under this category are “Kosher approved by the 
Manchester Beth Din.” “(Certified) Halal”, “Certified Kosher” 

Origin claims 

Claims  that  refer  to  a  geographical  area.  Examples  of  claims  under 
this  category  are  “Directly  from  their  sea  farms  from  Norway”  and 
“Made from halibut caught in Greenland, Denmark”. It includes also 
some claims about e.g. local recipes, but the vast majority of claims 
in this category are relating to the origin of the fish. 

Information on fishing 
gear 

Claims that provide information about the fishing gear that has been 
used: Examples of claims under this category are “Line caught” and 
“Individually caught by Pole & Line” 

Production techniques 

This type of claims give information about production or processing of 
the product. Examples of claims under this category are “Three factors 

158 

 
determine  the  taste  and  quality  of  traditional  smoked  salmon:  The 
origin of the crop, the production process and the quality of cutting.” 

Claims  that  refer  to  the  quality  of  the  product.  Examples  of  claims 
under this category are: “For a unique taste experience for all those 
who love variety”, “Great taste”, “Premium quality”  

Composition claims refer to the composition of the product, generally 
claiming a feature of the  fish texture, or bonelessness. Examples of 
,  “Firm 
claims under this category are: “Skinless  and  boneless” 
structure with a natural flavour” and “Juicy fillet” 

Claims  indicated  on  products  but  that  cannot  be  categorised  in  the 
groups  of  claims  mentioned  above.  Examples  of  claims  under  this 
 “Original  claims”,  “Proactive  about  packaging”  and 
category are: 
“Old style recipe”, or claims that are ambiguous 

Taste/Quality 

Composition claims 

Other 

1.1  Weighting 

In order to aggregate the results from the different countries to the EU 25 the results have 
to be weighted per country. Every observation (i.e. a product) gets a weight based on the 
country share of EU fish consumption in 2014. This is done for two reasons. First, some 
countries may be overrepresented in the database as the number of ‘new’ products is much 
larger than the relative position in terms of fish consumption in the EU. These countries 
would  have  a  more  than  proportionate  impact  on  the  aggregated  results.  Second,  the 
coverage of the various countries in the Innova database increases significantly for some 
countries  in  some  years.  This  may  be  due  to  expansion  of  the  data  collection  effort  of 
Innova  or  e.g.,  a  substantial  renewal  of  products  by  one  or  several  retailers.  Again,  to 
avoid disproportionate effects of such changes, weighting is applied.  

This weighting is done on the basis of fish and seafood consumption provided by EUMOFA 
on the basis of Eurostat data for 2014. The year 2014 was chosen as the reference year, 
although  fish  consumption  and  the  share  of  different  countries  may  change  somewhat 
between  years.  However,  given  the  consumption  figures  and  the  development  of  the 
number of inhabitants per country, the assumption is that fish consumption and the share 
of different countries is fairly stable for almost all countries.  

159 

 
 
 
 
Annex 3: Behavioural experiment and questionnaire 

1  Behavioural experiment 

The  research  goals  were  tested  with  two  experiments.  The  two  experiments  were 
conducted  online,  bundled  in  one  experimental  session.  Respondents  always  completed 
Experiment  2  first,  before  proceeding  to  Experiment  1  to  avoid  that  the  claim-related 
questions in Experiment 1 reveal the purpose of the experiment and thereby influence the 
respondents’  responses  to  Experiment  2.  Both  experiments  were  completed  by  3,244 
respondents  from  the  GfK  consumer  panel  across  eight  countries:  Czechia,  France, 
Germany,  Italy, Poland, Spain, Sweden and the United Kingdom. The  experiments were 
conducted amongst respondents that indicated that they buy fish products at least several 
times per year. 

1.1  Design of Experiment 1 

Experiment 1 was constructed as a fully randomised 2 (type of FAP) x 2 (type of claim) x 
3 (policy area) mixed design, plus a control condition with no claim, as show in Figure 1 
below. 

Figure 1  

Design of Experiment 1 

3200 consumers in 8 countries; 400 consumers per country 

Fish product  
A 

(Salmon) 

C1 

C2 

C3 

Self-declared/ 
3rd party claim 
Policy area A 

Self-declared/ 
3rd party claim 
Policy area B 

Self-declared/ 
3rd party claim 
Policy area C 

C4 
Other  
claim 
Policy area A 

C5 
Other 
 claim 
Policy area B 

C6 
Other 
 claim 
Policy area C 

C7 
No claim 

Fish product B 

C1 

C2 

C3 

(Cod) 

Self-declared/ 
3rd party claim 
Policy area C 
* Condition C1 to C6 are fully randomised allowing for all possible combinations. The arrows from C1 show all possible combinations for this 
cell. Similar combinations can be made between all other conditions. 

Self-declared/ 
3rd party claim 
Policy area A 

Self-declared/ 
3rd party claim 
Policy area B 

C4 
Other 
claim 
Policy area A 

C5 
Other  
claim 
Policy area B 

C6 
Other  
claim 
Policy area C 

C7 
No claim 

First,  each  respondent  was  presented  with  two  types  of  FAP  on  which  the  claim  was 
presented.  Respondents  were  asked  to  complete  the  experiment  for  fictional  brands  of 
smoked  and frozen cod. Smoked salmon and frozen cod were selected as products because 
they are widely known and commonly consumed in the EU. Furthermore, these products 
often carry claims on their packaging. The order of the FAP was randomized: half of the 
respondents first saw the smoked salmon, while half of the respondents first saw the frozen 
cod. 

Since  the  product  factor  is  not  a  factor  of  interest  from  a  theoretical  perspective  (it  is 
assumed  that  the  effects  hold  generally  for  all  products),  the  data  for  the  two  different 
products can be combined in the analysis, which yields 2 x 57 = 114 responses per claim, 
strongly enhancing statistical power. This assumption is checked throughout the analyses, 

160 

 
 
by testing the moderating effect of the fish type on the effect of claim certifying body and 
claim policy area on the different measures.  

Depending on the condition the respondent was in, the fish product packaging included a 
different  claim.  A  distinction  was  made  between  the  type  of  the  claim,  either  third-
party/self-declared  or  other,  and  between  different  policy  areas,  namely  sustainability 
(policy area A), quality/taste (policy area B) and origin (policy area C). Table 1 shows the 
different types of claims used in Experiment 1. 

In this study, existing claims currently featured on fish products were used. Therefore, the 
selection of claims by different types covering different policy areas was guided by what is 
featured on fish products in the focus countries. 

The advantage of using real claims is that respondents are presented with information they 
could normally encounter when shopping, which increases the realism of the study and the 
possibility to draw real life conclusions. In addition, respondents may already know58 and 
trust  existing  claims,  which  may  increase  the  possibility  to  find  an  effect  of  claims  on 
respondents’ behaviour and perceptions. A potential disadvantage of using existing claims 
is that they often differ regarding their design and content. Conclusions may only be drawn 
with regard to the specific existing claims that are used in the study. In addition, not all 
claims are used across all countries and, hence, different claims are used for each country. 
The degree to which claims are known by consumers, instead of the mere characteristics 
of the claims, may affect the results. 

For each product, the package contains one out of six claims: 

1.  Third-party/Self-declared claim in the policy area of sustainability 

2.  Other claim in the policy area of sustainability 

3.  Third-party/Self-declared claim in the policy area of quality/taste 

4.  Other claim in the policy area of quality/taste 

5.  Third-party/Self-declared claim in the policy area of origin 

6.  Other claim in the policy area of origin 

58  Respondents’ pre-existing familiarity with the claims used in the experiment is measured and 

reported in sections 2.2.6.4 and 3.2.5.4 

161 

 
 
                                                 
Table 1 

Claims used in Experiment 1 (salmon and cod) 

Country 

Sustainability 

Quality/Taste 

3rd-party/Self-
declared 

Other  

3rd-party/Self-
declared 

Other 

Origin 
Other 

3rd-
party/Self-
declared 

CZ 

DE 

FR 

IT 

PO 

ES 

Aus Nachhaltiger  
Fischerei  

Sustainably sourced 

Quality Guaranteed 

Seafood from  
Norway (10021) 

Controlled Quality 

From certified responsible 
fisheries 

Quality Engagement  

Sustainable fishing 

Marine Stewardship  
Council  

Explore Good Food 

Pescanova  sustainable 
fishing  

162 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country 

Sustainability 

Quality/Taste 

3rd-party/Self-
declared 

Other  

3rd-party/Self-
declared 

Origin 

Other  

3rd-
party/Self-
declared 

SE 

UK 

A-Quality 

163 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Each respondent was randomly allocated to two of these claims, randomly presented the 
order of either the salmon package or the cod package first. Figure 2 below shows examples 
of the product packaging used in the experiment.  

Figure 2 
policy area of quality/taste) 

Example of product packages used in Experiment 1 (Other claim in the 

Respondents were presented with a scenario in which they were instructed that they should 
imagine themselves as looking to buy fish. The experiment focused on the effects of claim 
certifying body and policy area information. To be able to examine which effects are due 
to each of the two factors (certifying body of the claim and the policy area of the claim), 
they were manipulated separately.  In this way, both the individual effects  of presenting 
claims from a different  certifying body and from a different policy area, as well as their 
combined effect could be investigated. 

Finally,  a  seventh  ‘no  claim’  control  condition  was  added.  Respondents  in  the  control 
condition  were  given  the  two  products  of  cod  and  smoked  salmon  (in  a  random  order) 
without  any  claims  on  the  product  packaging.  The  results  for  this  control  condition  will 
serve as the baseline, against which the effect of claims will be measured.  

Table 2 provides an overview of responses per condition. Since each respondent saw two 
fish products (smoked salmon; frozen cod), the total number of responses equals 6,488. 

164 

 
 
 
 
 
Table 2 

Number of responses in each condition 

l
a
t
o
T

e
c
n
a
r
F

y
n
a
m
r
e
G

d
n
a
l

o
P

n
i
a
p
S

y
l
a
t
I

n
e
d
e
w
S

a
i
h
c
e
z
C

K
U

Salmon  Other claim & policy 

445 

61 

60 

45 

53 

62 

61 

51 

52 

Cod 

area A 
Other claim & policy 
area B 
Other claim & policy 
area C 
3rd party/sd claim & 
policy area A 
3rd party/sd claim & 
policy area B 
3rd party/sd claim & 
policy area C 

No claim 

Other claim & policy 
area A 
Other claim & policy 
area B 
Other claim & policy 
area C 
3rd party/sd claim & 
policy area A 
3rd party/sd claim & 
policy area B 
3rd party/sd claim & 
policy area C 

No claim 

512 

62 

59 

72 

62 

62 

58 

74 

63 

464 

63 

59 

50 

57 

69 

56 

52 

58 

446 

58 

56 

46 

56 

64 

57 

50 

59 

464 

50 

62 

63 

66 

55 

54 

52 

62 

479 

61 

59 

63 

52 

56 

62 

70 

56 

434 

59 

54 

61 

55 

46 

53 

51 

55 

487 

57 

62 

73 

52 

61 

58 

65 

59 

423 

55 

55 

45 

52 

56 

58 

51 

51 

469 

58 

59 

57 

59 

65 

59 

55 

57 

473 

62 

55 

64 

54 

63 

58 

53 

64 

481 

66 

65 

54 

53 

64 

60 

64 

55 

477 

57 

59 

46 

76 

59 

55 

61 

64 

434 

59 

54 

61 

55 

46 

53 

51 

55 

Total 

6,488  828  818  800  802  828  802  800  810 

1.2  Outcome measures 

The experiment assessed multiple key outcome measures59: 

  Purchase intention 

  Willingness to pay 

  Product perceptions 

Respondents were presented with a product and had to indicate their purchase intention 
and  willingness  to  pay.  The  purchase  intention  (Q6)  was  measured  by  asking 
respondents  to  which  degree  they  agree  with  the  statement:  “I  would  buy  this  type  of 
product in the next month, if it were available in my supermarket” on a 7-point scale (1 
‘completely disagree’ to 7 ‘completely agree’). Willingness to pay (Q7) was assessed by 

59   See section 3 for the full questionnaire. 

165 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
asking how much respondents would be willing to pay for the product on a scale from 0 to 
10 euro. 

In addition, consumers were instructed to indicate the qualities (related to different policy 
areas)  they  associate  with  the  product  (Q8).  This  makes  it  possible  to  test  if  claims 
correctly influence  consumers’ product perceptions. Respondents were asked to indicate 
the extent to which the product has 12 different characteristics on a 7-point scale (1 ‘not 
at all to 7 ‘very much’).  

Note  that  both  the  certifying  body  of  the  claims  and  the  covered  policy  areas  were 
manipulated, so that the outcome measures could be linked to the specific claims. 

In addition, measures were included to test for respondents’ perceived credibility of the 
claims, using a 6-item scale from Moussa and Touzani (2008)60. This scale tests to which 
degree respondents trusted the information in the claims (Q9). This was done by having 
respondents  evaluate the six statement  on a  7-point scale (1 ‘completely disagree’ to 7 
‘completely agree’). 

Another  measure  assessed  respondents’  correct  association  of  the  claim  as  a  ‘third 
party/self-declared claim’ or an ‘other claim’ (Q10a). This measure provides both insights 
into the knowledge of the respondents and will help ascertain if a certain association (e.g., 
a claim is from a third party) is related to the outcome measures (e.g., a higher willingness 
to pay). Respondents were given definitions of the different certifying bodies of claims and 
were asked to indicate the one that corresponds with the claim they saw on the package. 

Respondents  in  the  no  claim  (control)  conditions  did  not  see  the  claim-related  question 
(i.e. correct association of the claims) and the question regarding the perceived credibility 
of the claims. To keep the cognitive load relatively equal with respect to respondents in 
the  claim  conditions,  they  were  given  a  filler  question  about  the  design  of  the  product 
package. 

1.3 

Post-experiment questionnaire 

A  post  experiment  questionnaire  measured  relevant  variables  and  respondent 
characteristics.  The  questionnaire  identifies  which  factors  respondents  take  into 
account when buying fish (Q12). The more important a certain factor is for consumers’ 
decisions, the more a claim related to this factor may influence their purchase intention, 
willingness to pay and product perceptions. For example, it is possible that a quality claim 
has a stronger effect for respondents that generally pay more attention to the quality of 
the  product.  This  was  measured  by  asking  respondents  to  indicate  their  perceived 
importance of 12 different aspects when buying fish and aquaculture products on a 7-point 
scale (1 ‘not important at all’ to 7 ‘very important’) 

In  addition,  respondents’  knowledge  about  food  labels  (Q13)  was  measured. 
Respondents  were  asked  to  answer  a  quiz  question,  where  they  had  to  indicate  if  6 
statements about food labels were true  or false (or that they don’t know). Respondents 
with a high knowledge of food labels might be more likely to use voluntary claims for their 
purchase decisions.  

60   Moussa,  S.,  &  Touzani,  M.  (2008).  The  perceived  credibility  of  quality  labels:  a  scale  validation  with 

refinement. International Journal of Consumer Studies, 32(5), 526-533. 

166 

 
                                                 
Similarly,  respondents’  familiarity  with  the  claim  (Q14)  they  have  seen  is  tested,  by 
asking them if they had seen the claims from the experimental product packages before in 
real life. 

Respondents’ familiarity with the product was measured as (1) the regularity with which 
the fish product was bought and (2) the availability of the fish product in respondents’ life 
on a 7-point scale. The two answers were combined into one product familiarity score. 

Finally, respondents’ financial situation was measured by asking respondents to indicate 
the difficulty of making ends meet (1 ‘very difficult’ to 5 ‘don’t know’). Socio-demographic 
measures, such as gender, age, level of education and work status were also measured.  

1.4  Design of Experiment 2 

The experimental design is a 2 (certifying body) x 2 (concurrent claims) between-subjects 
design,  with  100  respondents  per  condition  in  each  country.  Respondents  are  randomly 
assigned to one of the following four conditions. 

1. 

2. 

3. 

4. 

Third-party claim, no concurrent claims 

Other claim, no concurrent claims 

Third-party claim, three concurrent claims 

Other claim, three concurrent claims 

In each condition, the claim(s) are presented on a packaging for frozen mussels. Figure 3 
below presents an overview of the experimental set-up.  

Figure 3  

Design of Experiment 2 

3200 consumers in 8 countries screened ; 400 consumers per country 

Condition 1  
(N = 100) 

Condition 2  
(N = 100) 

Condition 3  
(N = 100) 

Condition 4  
(N = 100) 

 Third-party 
claim 

Other claim 

No Concurrent 
claims 

No Concurrent 
claims 

Third-party 
claim 

Concurrent 
claims 

Other claim 

Concurrent 
claims 

Respondents  were  presented  with  situations  in  which  they  were  looking  to  buy  frozen 
mussels. The product was chosen because it realistically allowed a European-wide third-
party claim to be featured on the packaging. Furthermore, frozen mussels are consumed 
in all countries of the experiment. 

The  concurrent  claims  factor  was  manipulated  by  adding  three  additional  claims  to  the 
package. The focal claim was a quality claim that was either a 3rd party claim or another 
(i.e. ‘other’) quality claim. The third-party claim selected was the EU PGI quality claim; the 
other claim was a gold medal stating “premium”. The three concurrent claims were “Natural 
Taste”, “Source of Omega 3” and “Wild”. See Figure 4 for an example of condition 4. These 
were selected based on what can be found featured on this type of product in store in the 

167 

 
 
 
 
 
 
 
 
 
EU.  Figure  4  presents  examples  of  the  stimuli.  The  claims  used  in  Experiment  2  are 
presented in Table 3. 

Figure 4 
concurrent claims) 

Example  of  the  stimuli  (other  claim;  without  and  with 

No concurrent claims 

Concurrent claims 

Table 3 

Claims used in Experiment 2 for mussels (for all countries) 

3rd-party/Self-
declared 

Other 

It is important to note, that the third-party claim used in the experiment is a real voluntary 
claim. This claim was selected to increase the realism of the study and to draw conclusions 
for  real  claims  used.  The  other  claim  and  the  concurrent  claims  used  in  the  experiment 
were all based on what is found on products in the EU but designed for this experiment by 
a graphic designer. Claims differed slightly across countries in terms of size and text due 
to  language  differences,  introducing  some  noise  to  the  results.  To  investigate  potential 
country differences, findings will also be presented for each investigated country. Table 4 
provides an overview of responses per condition.  

168 

 
 
 
 
 
 
 
 
 
 
Table 4 

Number of responses in each condition 

l
a
t
o
T

e
c
n
a
r
F

y
n
a
m
r
e
G

y
l
a
t
I

d
n
a
l

o
P

n
i
a
p
S

n
e
d
e
w
S

K
U

a
i
h
c
e
z
C

807 

101 

97 

100 

100  106  101  100  102 

814 

111 

102 

98 

101  102  100  100  100 

812 

103 

103 

100 

100  106  100  101  99 

811 

99 

107 

102 

100  100  100  99 

104 

3rd party / self-
declared claim 

Other claim 

No 
concurrent 
claims 

Concurrent 
claims 

No 
concurrent 
claims 

Concurrent 
claims 

Total 

3,244  414 

409 

400  401  414  401  400  405 

1.5  Outcome measures 

The key outcome measures61 are: 

  Purchase intention 

  Willingness to pay  

  Product perceptions 

  Ease of understanding information 

Similar to Experiment 1, respondents were presented with a product and had to indicate 
their purchase intention (Q1) and willingness to pay (Q2). In addition, it was tested which 
qualities (related to different policy areas) respondents associate the product with (Q3). 
This makes it possible to test if claims correctly influence consumers’ product perceptions. 
Concretely, it is expected that a quality claim increases quality perceptions for a product. 

In  addition,  measures  were  included  to  test  for  respondents’  perceived  ease  of 
understanding the information (Q3), using a 3-item bipolar scale. This scale tests to 
which degree respondents found the information on the package easy to understand (vs. 
difficult to understand), clear (vs. confusing) and helpful (vs. unhelpful) on a 7-point scale. 
The average score is recoded so that a higher score indicates a better understanding of 
the package information. 

1.6 

Post-experiment questionnaire 

The same post experiment questionnaire used for Experiment 1 was used for Experiment 
2.  The  questionnaire  identifies  which  factors  respondents  take  into  account  when 
buying fish. The more important a certain factor is for consumers’ decisions, the more a 

61   See Section 5 for the full questionnaire. 

169 

 
  
  
 
 
 
 
 
 
 
 
 
  
  
  
 
                                                 
claim related to this factor may influence their purchase intention, willingness to pay and 
product  perceptions.  Most  interesting  for  the  current  experiment  is  the  importance 
respondents attach to the quality of a fish when making a purchase.  

In  addition,  respondents’  knowledge  about  food  labels  was  measured.  Respondents 
with a high knowledge of food labels might be more likely to use voluntary claims for their 
purchase decisions. Similarly, respondents’ familiarity with the claim they have seen 
is tested. 

Respondents’ familiarity with the product was measured as (1) the regularity with which 
frozen mussels were bought and (2) the availability of frozen mussels in respondents’ life. 

Finally, respondents’ financial situation was measured by asking respondents to indicate 
the  difficulty  of  making  ends  meet.  Socio-demographic  measures,  such  as  gender,  age, 
level of education and work status were also measured.  

1.7  Questionnaire 

Length of interview: 20 min 

End fieldwork:  

III. INTRODUCTION 

Dear Sir/Madam, 

Questionnaire Template 

DG MARE 

Start fieldwork:  

Methodology:  CAWI  

GfK Belgium is carrying out an international survey to gain more insights into the consumer perception of fish 
products.  

It would be very valuable if you could fill out the questionnaire for us. 

Please  note  that  there  are  no  right  or  wrong  answers  and  your  responses  will  be  kept  anonymous  and 
confidential. 

It will take about 15 minutes to complete the questionnaire. 

Thank you for participating! 

IV. SCREENER QUESTIONS 

Base: all respondents 

S1. 

How old are you? 

Base: all respondents 

S2. 

Are you a…?  

1. Woman   

2. Man 

3. Don’t wish to answer 

170 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Base: all respondents 

S3.  

How often do you buy fish products? 

1.  Never  

2.  Several times per year, but less than once a month  

3.  At least once a month, but less than once a week 

4.  At least once a week  

IF S3=1 - SCREENOUT 

V. EXPERIMENT 2 

In this part of the study you will be shown a fish product, similar to the ones you may find in your supermarket. We will ask you a 
number of questions regarding this product. 

Purchase decision/willingness to pay 

Purchase Intention 
Base: all respondents  

Q1.  

Look at the following product: 

INSERT IMAGE PRODUCT FOR EXPERIMENT 1  

To what extent do you agree with the following statement? 

Columns (scales): 

1.  1 (scripter insert break) Completely disagree 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Completely agree 

Rows (items) 

I would buy this type of product in the next month, if it were available in my supermarket. 

to 

pay 

Willingness 
Base: all respondents  

Q2.  

INSERT IMAGE PRODUCT FOR EXPERIMENT 1  

How much are you willing to pay for this product? 

€ 0    --------------------------------- € 10 

171 

 
 
 
 
 
 
 
Product perceptions 
Base: all respondents  

Q3.  

INSERT IMAGE PRODUCT FOR EXPERIMENT 1 

To what extent do you think this product has the following characteristics? 

The product is … 

Columns (scales) 

1.  1 (scripter insert break) Not at all 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Very much 

Row (items) (randomise) 

1.  Healthy 
2.  Prepared under controlled (hygienic) conditions 
3.  Free from additives (e.g. preservatives, colourings, flavourings) 
4.  Sustainably sourced / environmentally friendly 
5.  Produced in a socially responsible way (fair trade) 
6.  Traceable (from the water to the shop) 
7.  High in nutrients 
8.  Tasty 
9.  Of high quality 

Confusion of information / information overload 

Base: all respondents  

Q4.  

Looking at the product, how would you evaluate the information presented on the product packaging? To which 
degree do you agree with the following statements? 

INSERT IMAGE PRODUCT FOR EXPERIMENT 1 

The information presented on the product packaging is … 

Columns (scales) 

1.  1 (scripter insert break) Not at all 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 

172 

 
 
 
 
 
7.  7 (scripter insert break) Very much 

Row (items) (randomise) Left and right grid text 

Difficult to understand – Easy to understand 

Confusing - Clear 

Unhelpful - Helpful 

VI. EXPERIMENT 1  

In this part of this study you will be shown two fish products similar to the ones you may find in your supermarket. 
For each of the two products, we will ask you a number of questions.   

All questions of Experiment 2 will be presented to each respondent twice (Q6 – Q7). 

Purchase decision/willingness to pay 

The block about the purchase decision/willingness to pay (Q6-Q8) will be repeated twice, once for each of the 
two conditions a respondent will see. The product (salmon and cod) will be varied ad random during these two 
presentations. 

Purchase Intention 
Base: all respondents  

Q6.  

Look at the following product: 

INSERT IMAGE PRODUCT FOR EXPERIMENT 2 

To what extent do you agree with the following statement? 

Columns (scales): 

1.  1 (scripter insert break) Completely disagree 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Completely agree 

Rows (items) 

173 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.  I would buy this type of product in the next month, if it were available in my 

supermarket. 

Willingness to pay 
Base: all respondents  

Q7.  

How much are you willing to pay for this product? 

INSERT IMAGE PRODUCT FOR EXPERIMENT 2 

€ 0    --------------------------------- € 10 

Product perceptions 
Base: all respondents  

Q8. 

To what extent do you think this product has the following characteristics? 

INSERT IMAGE PRODUCT FOR EXPERIMENT 2 

The product is … 

Columns (scales): 

1.  1 (scripter insert break) Not at all 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break)  Very much 

Rows (items) (randomise) 

1.  Healthy 
2.  Prepared under controlled (hygienic) conditions 
3.  Free from additives (e.g. preservatives, colourings, flavourings) 
4.  Sustainably sourced / environmentally friendly 
5.  Produced in a socially responsible way (fair trade) 
6.  Traceable (from the water to the shop) 
7.  High in nutrients 
8.  Tasty 
9.  Of high quality 

Questions Claims (and products) 

Base: only respondents in claim conditions Hidden_X2=1-30 OR 32-61 (not respondents in the control conditions) 

174 

 
 
 
 
 
 
 
 
This block of questions (Q9-Q10b) will be asked for all claims used in this experiment. Respondents will therefore 
see this block twice. There is a separate question for respondents in the control conditions. 

Perception of information 
Base: only respondents in claim conditions Hidden_X2=1-30 OR 32-61 

Q9.  

Looking at the product, how would you evaluate the information presented on the product packaging? 

INSERT IMAGE PRODUCT FOR EXPERIMENT 2 

To which degree do you agree with the following statements? 

Columns (scales): 

1.  1 (scripter insert break) Completely disagree 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Completely agree 

Rows (items) (randomise) 

1.  I can trust what the information on the package says. 
2.  The information on the package comes from recognised experts. 
3.  The information on the package is honest. 
4.  The organisation that provides the information on the package has good intentions. 
5.  The organisation has passed serious tests before issuing the information on the package. 
6.  The information on the package gives me confidence. 

Type of claim 
Base: only respondents in claim conditions Hidden_X2=1-30 OR 32-61 

Q10a  

You have seen the following label on one of the product packages you have seen earlier: 

INSERT CLAIM PRODUCT FOR EXPERIMENT 2 

To which category do you believe the label belongs?  

1.  The label is certified by a third party 

2.  This means that next to the organization that issues the label, an independent third-party organisation has 

verified that the product carrying the label complies with the requirements of the label. 

3.  The label is self-declared 

The issuer of the label (which can also be the producer or retailer themselves) decided that the product 
carrying the label meets the requirements for the label. No independent organisation was involved in 
verifying if the requirements were met. 

175 

 
 
 
 
 
 
 
 
4.  Other label 

These are images and/or statements about product characteristics that are put on the product packaging 
by the producers themselves. In contrast to the other claims, there are no requirements that have to be 
met. 

5. 

I don’t know / not sure 

Third-party vs. self-declared claims 
Base: only respondents in the control conditions Hidden_X2=31 OR 62 

Q10b  

You have seen the following product package earlier. 

Please evaluate the attractiveness of the following items: 

Columns (scales): 

1.  1 (scripter insert break) Not at all attractive 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Very attractive 

Rows (items) (randomise) 

1.  The design of the product package  

2.  The colour scheme used on the product package 

3.  The brand name 

4.  The font of the brand name 

5.  The layout of the different items on the package 

VII. Food Choice Motivations & Knowledge Question 

 This post-survey will always be presented after the two experiments have been completed by the respondents 

Factors when buying fish 
Base: all respondents  

Q12 

To what extent are the following aspects important to you when you buy fish and aquaculture products? 

Columns (scales): 

1.  1 (scripter insert break) Not important at all 
2.  2 
3.  3 
4.  4 
5.  5 

176 

 
 
 
 
 
 
6.  6 
7.  7 (scripter insert break) Very important 

Rows (items) (randomise) 

1.  How good the product is for your health 
2.  That the product was caught in an animal-friendly manner 
3.  That the product was prepared under controlled (hygienic) conditions 
4.  That the product is free from additives (e.g., preservatives, colourings, flavourings) 
5.  How affordable the product is (i.e., the price) 
6.  How the product tastes 
7.  The appearance of the product 
8.  Your familiarity with the product 
9.  The environmental impact of the product 
10. Which country/region the product comes from (i.e., geographic origin) 
11. The quality of the product 
12. Whether or not the product is organically produced 

Knowledge about food labels 
Base: all respondents  

Q13 

Please indicate whether you think each of the following statements is true or false. Please select one answer for 
each statement. 

Columns (scales): 

1.  True 
2.  False 
3.  Don’t know 

Rows (items) (randomise) 

1.  Labels are always certified by independent (third-party) organisations. 
2.  Food producers and/or retailers can create their own labels, based on their own criteria. 
3.  Producers of fish or seafood need to meet all the requirements of a label to get certified. 
4.  In order to be labelled as ‘organic’, the production of food has to comply with specific 

legal requirements. 

5.  A food product can only have a label from an independent (third-party) organisation if all 
companies involved in producing, processing and transporting the food are certified. 
6.  A label can cover several issues (for example, one label indicating both animal welfare 

and environmental sustainability). 

Familiarity with claim 

Base: only respondents in claim conditions Hidden_X2=1-30 OR 32-61 

Q14  

The following labels appeared on the product packages you have seen earlier. Please tell us whether or not you 
have seen these labels before in real life: 

The three claims the respondent has seen during the experiment are presented. 

177 

 
 
 
1.  Yes 
2.  No 
3.  Not sure 

Familiarity with the product 
Base: all respondents  

Q15 

Please answer the following questions regarding the products in this study. 

I regularly buy this type of product: 

Columns (scales): 

1.  1 (scripter insert break) Completely disagree 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Completely agree 

Rows (items) (randomise) 

1.  Smoked Salmon 
2.  Frozen Cod 
3.  Frozen Mussels 

This type of product is easily available for me: 

Columns (scales): 

1.  1 (scripter insert break) Completely disagree 
2.  2 
3.  3 
4.  4 
5.  5 
6.  6 
7.  7 (scripter insert break) Completely agree 

Rows (items) (randomise) 

1.  Smoked Salmon 
2.  Frozen Cod 
3.  Frozen Mussels 

VIII. Socio-demographic characteristics 

Finally, we are interested in some background information. 

178 

 
 
 
 
 
 
 
Base: all respondents  

Z1  

What  is  the  highest  level  of  education  you  have  successfully  completed  (usually  by  obtaining  a  certificate  or 
diploma)? 

1.  No qualification 
2.  Primary education 
3.  Lower secondary education 
4.  General National Vocational Qualification (GNVQ, GSVQ) / GCSE/ SCE standard / 

Apprenticeship or A Level 

5.  Higher Education Access Course, or equivalent qualification 
6.  Higher National Certificate (HNC) / Higher National Diploma (HND), Higher Education 

Diploma 

7.  Bachelor's Degree (BA, BSc or equivalent qualification) 
8.  Master's Degree or Post-Graduate Degree (MA, MBA, MSc, Mphil or equivalent 

qualification) 

9.  Doctorate: PhD or Dphil 

Base: all respondents  

Z2  

What is your current occupation? 

1. Self-employed   

2. Manager 

3. Other white collar 

4. Blue collar 

5. Student 

6. House-person and other not in employment 

7. Seeking a job 

8. Retired 

Base: all respondents  

Z3 

Thinking about your household’s financial situation, would you say that making ends meet every month is …? 

1. Very difficult 

2. Fairly difficult 

3. Fairly easy 

4. Very easy 

5. Don’t know 

Base: all respondents  

Thank you for your participation in this study. To finish this survey, please click on the ‘forward’ button. 

End 

179 

 
 
 
 
 
Annex 4: Mystery shopping and web sweep 

1. Building the inventory  

To compile the inventory a bottom-up approach was utilised – starting with what appears 
on FAPs on the market in order to build a picture of which schemes and other voluntary 
claims  are  placed  on  packaging  of  FAPs  in  the  EU28.  This  inductive  approach  was  open 
ended in the beginning and allowed us to start exploratory and to anticipate adaptations 
during the coding process needed to build a final inventory. The methodology used is based 
on four questions and simultaneously four stages in the process of building the inventory: 

1.  Which claims are on FAPs in retail in 28 EU Member States? 

  Collecting  as  many  examples  of  fish  and  seafood  products  as  possible  available 

across the EU  

2.  How can these claims be categorised? 

  Looking for regularities and detect patterns in the claims 

3.  Which claims are in the scope of the inventory? 

  Formulating tentative inventories 

4.  How do the claims need to be coded? 

  Building the inventory 

2. Collecting claims 

For the collection of claims appearing on Fishery and Aquaculture Products in all EU Member 
States three methods were used: 

  Web sweep of online catalogues of (online) retail and specialty stores,  
  Online research of most important brands with FAPs 
  Mystery shopping of supermarket and specialty stores 

2.1.  Web sweep 

A web sweep of the EU member states was conducted in order to identify the claims FAP. 
This was done by first identifying the existing super- and hypermarkets in each country, 
and then selecting those stores that had online catalogues. Participants began by searching 
for the keyword ‘fish’ from the catalogue search engine of a given store. They assessed 
every product resulting from this search if: a) the product was in the scope of the study, 
and b) if the package displayed any claim(s). They completed an excel sheet for each claim 
they  found,  and  took  pictures  of  each  claim.  The  same  procedure  was  applied  to  the 
keywords ‘seafood’, and ‘shellfish’. In cases where these search terms did not identify all 
FAP, participants also noted other search terms they used to identify such products. We 
first coded the claims from a subset of 8 countries where we would later run the behavioural 
experiments.  

180 

 
 
2.2.  Online research of most important brands with FAPs 

The claims collected from the web sweep results were supplemented by an online search 
of claims from the most important FAP brands (in terms of market visibility), including Rio 
Mare,  John  West,  Iglo,  Imperial,  Birds  Eye.  This  was  done  by  searching  for  the  product 
range of these brands on their company website, and adding claims and products that had 
not yet been identified through the web sweep. 

2.3.  Mystery shopping of supermarket and specialty stores 

Claims on FAPs were also collected from physical supermarkets and specialty stores in the 
EU28  member  states  by  mystery  shoppers.  These  shoppers  visited  stores  and  took 
photographs of the front of FAP packaging. All claims from these products were added to 
the inventory – either as new claims, or additional instances of pre-existing claims (for new 
products or new countries/supermarkets/brands that had not been previously associated 
with the claim). That is, when claim that was already in the inventory was found on a new 
product,  or  on  the  same  product  from  a  different  supermarket  or  country,  the  new 
information associated with the claim was updated in the inventory. 

3. Processing claims 

The inventory of claims was built from three sources of information: a) a web sweep, b) 
desk research, and c) a mystery shopping task. These three methods used to collect claims 
resulted in over 20.000 examples of claims on almost 1.000 brands sold in 180 different 
supermarkets, online supermarkets; specialty stores over the 28 EU member States.  

181 

 
 
 
The characteristics of claims that were to be coded (as set out in the Terms of Reference) 
were:  

  whether they are third-party certified, self-declared or other, 

  which policy areas they cover and if there are different types of objectives in the 
same policy area that are leading to different types of claims (specific topics), 

 

in which countries they are present and if there are cross-country claims, 

  which  type  of  FAP  (fresh,  frozen,  smoked,  salted,  dried,  in  brine  or  prepared)  or 

process (production, processing, etc.) they cover, 

 

the type of body/actor that develops, manages and owns claims, 

  whether they are publicly supported or not; 

 

for schemes: if there are umbrella schemes. 

Nevertheless, the criteria of how to compile and code the claims were not specified from 
the outset. The coding of ‘schemes’ would have been narrower in scope and a methodology 
could be based on previous studies, but as this inventory included ‘other’ voluntary claims 
in  the  form  of  logo/statements  on  the  packaging  this  required  the  most  suitable 

182 

   
 
methodological approach to be identified over time. As a result, the development of the 
methodology for both compiling and coding was an iterative process, with insights gained 
from each stage feeding back into the methodology, so that previous outputs from coding 
were updated as new developments were made. 

Next to the online investigation of FAP brands, desk research was a crucial methodology 
in  assessing  the  claims.  Most  importantly,  desk  research  in  this  stage  of  the  research 
provided information on the type of claim and the scheme owner (third party certified, 
self-declared or other) (see section 1.4.1). 

At each stage, the Commission and contractor/researchers discussed the output resulting 
from the data used and the applied coding methodology. 

4. Coding claims 

4.1.  Type of claims 

The criteria that were developed to distinguish between 3rd party, self-declared and other 
claims was based on information that the consumer might consider at ‘face value’, unless 
there was further information available via desk research. This meant that the information 
search consisted of typing in the claim on a web search, typing in the brand of the product 
and  checking  information  available  on  the  brand  website62,  and/or  conducting  a  Google 
reverse image search of any images associated with the claim. The criteria were as follows: 

1.  3rd  party  claims:  claims  were  considered  to  belong  to  3rd  party  schemes  if  an 
internet  search  yielded  information  revealing  that  the  claim:  a)  represented  a 
certification body (e.g. Iceland Responsible Fisheries), or b) indicated that a product 
was certified (e.g. Agriculture Biologique, MSC).  

2.  Self-declared claims: such claims reference external criteria for the claim that is 
either:  a)  a  3rd  party  certification  mechanism  (e.g.,  if  the  claim  of  ‘Sustainable 
product’ is accompanied by the MSC logo), or b) information found on the website 
of the product company (e.g. information that describes the sustainability criteria 
that the product meets).  In  cases where a 3rd party certification mechanism was 
referenced, this reference was indicated in the ‘Remarks’ column of the inventory. 
In  cases  where  a  claim  was  supported  by  information  found  on  the  product 
company’s website, the website was indicated in the ‘Website’ column. 

3.  Other claims: claims were coded as ‘other’ if an internet search did not yield any 
information  supporting the  claim  as  being  a  3rd  party  of  self-declared  claim  (e.g. 
high in omega 3, with no information on the product website about omega 3) or if 
there was no supporting information referencing a scheme on the packaging. 

4.  Combi claims:  such claims involve a combination of two of the above three types 
of claims. An example of such a claim is “100% sustainable organic aquaculture” 
that  is  accompanied  by  an  EU  organic  logo.  The  “organic”  part  of  the  claim  that 
refers  to  the  EU  organic  logo  constitutes  a  self-declared  claim,  while  “100% 
sustainable” constitutes an other claim. Such claims were only identified after the 
building  of  the  inventory  had  begun,  when  it  became  apparent  that  some  claims 
could only be partially supported by external sources of information. If one of the 

62   Or the retailer in the case of ‘own’ brands 

183 

 
                                                 
claims  was  a  self-declared  claim,  it  followed  the  criteria  for  self-declared  claims 
outlined above. 

Another distinction was made between claims in the form of a picture or text. When claims 
were initially collected from the web shopping, we initially distinguished between  claims 
that  consisted  solely  of  text,  those  that  consisted  solely  of  a  picture,  and  those  that 
combined both a picture and a text.  However, we later considered those that combined 
text with a picture to fall into the “picture” category. 

To examine whether there were differences in the message of the claim depending on its 
format, all variations of a claim containing a picture were initially coded as separate claims. 
For instance, the claim ‘Omega 3’ in a blue bubble was coded separately to ‘Omega 3’ in a 
green bubble. However, this process resulted in a database of over 6,000 claims from the 
web shopping alone, which led to a revision of our coding system so that only images that 
represented an object/concept related to the claim (e.g. a fish, a heart, or an oil drop in 
relation  to  Omega  3,  but  not  a  bubble)  were  considered  to  represent  picture  claims. 
Furthermore, picture claims were considered to be unique only if their image represented 
a  conceptually  (not  perceptually)  different  object/concept  to  that  which  had  previously 
coded. For instance, all variations of Omega 3 fish pictures were coded as instances of the 
same claim, but a claim consisting of “Omega 3’ within a heart picture was considered to 
be  different  to  ‘Omega  3’  within  a  fish.  This  distinction  was  made  because  conceptually 
different pictures may highlight different associations related to a particular claim. In the 
foregoing example of ‘Omega 3’, a heart highlights the health benefits of omega 3 more 
specifically than a fish does. 

Initially textual claims such as ‘low in fat’ were considered to be picture claims if they were 
presented in any kind of ‘logo/label’. This also resulted in many claims that were considered 
‘unique’  because  they  were  visually  different  (see  the  example  below).  This  was  later 
changed so that that these kinds of  claims are actually considered to  be textual claims. 
Furthermore,  they  are  unique  claims  if  the  statements  are  distinctly  worded  differently 
(e.g. Omega 3, Rich in Omega 3, High in Omega 3 are all unique claims but the colour or 
placement of the text in blue box compared to a green box are not considered unique).  

The following images highlight this issue where  ‘100% natural’ was initially considered a 
‘picture’ in the product image on the left and a ‘textual’ statement on the product image 
on the right and therefore considered separate claims. In the final coding  – these claims 
are both considered to be textual statements and are coded as being the same claim. 

184 

 
 
 
Separation of claims: It is possible for some text claims to be separated into multiple claims 
that are coded separately, depending on whether it consists of easily divisible units. For 
example, ‘Fish filet processed in a quality-preserving way’ cannot be easily separated, and 
is  thus  one  claim.  However,  “Salt  cured,  oak  smoked,  Scottish  salmon  strips”  can  be 
separated into two claims of ‘Salt cured’ and ‘Oak smoked’ because the concepts can be 
differentiated. 

Merging  of  claims:  Claims  that  are  essentially  the  same  claim  are  considered  to  be 
instances of the same claim. For example, ‘Skinless’ = ‘Without skin’ = ‘no skin’. Similarly, 
‘Free from artificial colours, flavours, and preservatives’ = ‘No artificial flavours, colours, 
and preservations’. However, the ‘merging’ of claims is only done where this is very clearly 
the case in order to ensure that relevant variations (such as those for Omega 3 claims) are 
captured.  

4.2.  Type of FAP  

In coding types of FAP, a distinction was made between Fish and Crustaceans & Molluscs. 
The product was coded according to the type of preservation that was primarily used to 
preserve the product. 

  Fresh/Chilled: involves no other preservation than that presented by the store in 

the ‘fresh department’ or is cooled in the refrigerator 

  Frozen: the product is frozen (in whole, slices, pieces, etc.) 

  Dried: the product is dried 

  Smoked: the product is smoked 

  Canned,  prepared,  or  in  brine:  when  the  product  is  canned,  cooked,  pickled, 
salted, in brine, breaded, prepared for eating as is, etc.  and not dried or smoked  

In case where a product undergoes multiple preservation processes – e.g. fish fingers that 
are both prepared and  frozen,  or  smoked salmon that is both  smoked and chilled  – the 
product was coded according to the preservation process that is unrelated to cold storage. 

185 

 
 
 
4.3.  Coverage 

The distribution of products was coded according to the following criteria:  

  Country: Every EU-Member State where consumers could purchase a product with 
the claim, either from an online catalogue of a store or in an offline store located in 
that Member State. 

  Cross-country:  When  the  claim  was  available  in  stores  of  multiple  EU-Member 
States  (purchased  either  through  purchase  via  an  online  catalogue  or  an  offline 
store within a Member State). 

  Shop: Store(s) where the product that carries the claim was sold.  

  Brand: Brands that carry the claim on the package of their products. 

  # Brands: the minimum number of brands that carry the claim on the package of 

their FAP. 

4.4.  Production stage 

Claims were coded as pertaining to either the production and/or post-production stage. 

  Production: refers to 1) means of catching/breeding the product, including fishing 
gear/method; 2) location where the product is produced; 3) inherent characteristics 
of the product (e.g. ‘Omega 3’); 

  Post-Production: refers to any  stage after production, including 1) the way the 
product is processed or preserved, 2) the way the FAP is packaged (‘Packed at sea’, 
‘Packed by hand’), 3) claims that are used to promote the product that is not related 
to  the  production,  processing,  or  packaging  stages  (e.g.,  best  quality),  and  any 
awards associated with the product. 

4.5. 

Information about schemes 

Public vs private: A distinction was made between whether the claim was associated with 
a public body. If a government/public body is involved in a scheme (such as managing, or 
funding the scheme) it is considered a public scheme – otherwise it is a private scheme. 
For example, the scheme “Traditional Speciality Guaranteed”, is a public scheme, because 
it is managed by the EU. 

Body that owns the claim: This information was only coded for claims that were either 
‘self-declared’  or  ‘3rd  party’.  This  refers  to  the  name  of  the  body  from  which  the  claim 
comes from (e.g. MSC owns the MSC logo, claim ‘sustainably fished’ may come from an 
FAP brand or a supermarket). 

Scheme  owner:  Whether  the  body  that  owns  the  self-declared  or  3rd  party  claim  is  a 
non-profit organisation, a government organisation, a certification body etc. 

Umbrella scheme: A  claim is associated with an umbrella scheme when: a) it appears 
also on other product categories in addition to FAPs (e.g., the organic claim ‘Agriculture 
Biologique’  also  appears  on  plant-based  products),  and/or  b)  the  claim  can  appear 
differently  in  different  regions/countries.  For  example,  the  ‘Protected  Designation  of 
Origin’/ ‘Denominazione d’Origine Protetta’ claim covers all types of food, including FAPs, 
dairy products, oil, etc. This only applies to self-declared and 3rd party claims. 

186 

 
4.6.  Policy areas 

The policy area refers to the main topic of the claim. The fifteen policy areas considered 
are presented below, accompanied by some examples of associated claims. As discussed 
in the section on processing claims these policy areas were identified in an iterative process 
– with ‘broad’ guidelines on what fell into each policy area set out initially and then refined 
based on the iterative process as claims were identified and coded:   

Allergen (free): Gluten/wheat free. Generally associated with the production stage. 

Food safety: Assured food standards; Sterilised. Associated with the production and post-
production stage. 

Health  and  nutrition:  Omega  3;  Low  in  fat;  Low  salt;  High  in  Protein;  Vitamins  and 
minerals; Healthy; Good for you. Generally associated with the production stage. 

Traceability: traceable; origin controlled. Generally associated with the post-production 
stage. 

from 

Free 
flavour 
enhancers/aromas/flavourings; No E numbers;  Natural; All natural. Generally associated 
with the post-production stage. 

preservatives,  No 

additives:  No 

artificial 

added 

Generic  responsibility/Environmental  responsibility/sustainability:  Claims  that 
refer  to  sustainability  of/and  responsibility  of  the  marine  environment  (e.g.,  MSC,  ASC, 
Friends of the Sea, etc.). Generally associated with the production stage. 

Social  responsibility:  Fairtrade;  Supporting  local  small  business.  Associated  with  the 
production and post-production stage. 

Animal welfare and health: Dolphin safe/friendly; RSPCA; Some ‘Pole and Line’ claims 
Generally associated with the production stage. 

Religious dietary laws: Kosher Generally associated with the production stage. 

Organic  production  method:  Bio;  Organic;  Ecological  (if  the  organic  definition  is 
supported  by  desk  research).  Such  claims  are  always  either  3rd  party  or  self-declared. 
Generally associated with the production stage. 

Origin:  Fish 
in  [country/ocean/etc.];  Product 
from/Produced in/Made in [country]/ Maps. Generally associated with the production stage. 

from  [country];  Caught/Farmed 

Production  process:  Use  of  traditional  preservation  methods  (drying;  salting;  etc.); 
Processed  by  hand;  Artisanal;  Family/house  tradition  or  recipe;  Recipe 
from 
(country/region); Original (recipe); Different forms of smoking (e.g., hot smoked); Quick 
frozen. Generally associated with the post-production stage. 

Taste/product  quality: 
(taste/quality);  Quality 
seal/claim; Nr1 in [country]; any award related to taste/quality. Generally associated with 
the post-production stage. 

Premium/Best/Great/Supreme 

More detail on fishing gear: Pole and Line; No use of FAD; Individually caught; Rope 
grown. Generally associated with the production stage. 

Composition: [X]% fillet; Skinless; Boneless; 100% made with (fish); Headless; No tail. 
Generally associated with the production stage. 

187 

 
In addition to coding the relevant policy area/s, the main policy area was also specified. 
When  the  claim  refers  to  more  than  one  main policy  areas  without  a clear  ‘main’  policy 
area, the main policy area was coded as ‘Multiple’.  

The criteria used to decide the policy area of a claim were: 

  The claim is considered face value and clearly refers to a topic of a policy area and 
is coded as such. For example ‘Good for your health’ refers to ‘Health and nutrition’, 
‘Sustainably fished’ to ‘Generic responsibility’, etc. 

  The  claim  does  not  refer  to  a  policy  area  directly,  but  to  a  topic  that  is  directly 
related  to  the  policy  area.  For  example  ‘Omega  3’  refers  to  an  ingredient  of  the 
product that is supposed to be a health claim.  

  When  a  claim  did  not  belong  to  a  policy  area  its  main  policy  area  was  coded  as 
‘Unclassified'. When it was unclear what the claim referred to (for example ‘From 
the  fishmonger’)  the  subpolicy  area  of  the  claim  was  coded  as  ‘Ambiguous’. 
Otherwise the subpolicy area was coded as ‘Unclassified’ 

  When  a  claim  is  not  backed  up  by  more  detailed  information  on  the  package  or 
online, the claim was coded ‘face value’ (for example a generic ‘Pole & Line’ claim 
= information on fishing gear) or as ambiguous.  

  When  a  claim  is  ambiguous  by  its  look  or  its  name  BUT  is  backed  up  by  more 
detailed information on the package  or  online, the claim was coded following the 
available information (for example Friends of the Sea or Fish for Life or the Pole and 
Line Claim of RioMare). 

188 

 
 
 
 
HOW TO OBTAIN EU PUBLICATIONS 

Free publications: 

•  one copy: 

via EU Bookshop (http://bookshop.europa.eu); 

•  more than one copy or posters/maps: 

from the European Union’s representations (http://ec.europa.eu/represent_en.htm);  
from the delegations in non-EU countries 
(http://eeas.europa.eu/delegations/index_en.htm);  
by contacting the Europe Direct service (http://europa.eu/europedirect/index_en.htm) 
or calling 00 800 6 7 8 9 10 11 (free phone number from anywhere in the EU) (*). 

(*)  The information given is free, as are most calls (though some operators, phone boxes or hotels may 
charge you). 

Priced publications: 

•  via EU Bookshop (http://bookshop.europa.eu). 

Priced subscriptions: 

•  via one of the sales agents of the Publications Office of the European Union 

(http://publications.europa.eu/others/agents/index_en.htm). 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
K
L
-
0
2
-
1
9
-
3
6
3
-
E
N
-
N

ISBN:  978-92-76-04615-8 
doi: 10.2771/732718