Soil Association Spear House 51 Victoria Street Bristol BS1 6AD

The negative environmental impacts of the open-net salmon farming industry are completely counter to the organic principles of the Soil Association, and we believe the certification is a reputational risk for your organisation, misleading to consumers and an unacceptable greenwash of an inherently unsustainable industry. [...] The report, Responsibly farmed?, found that certification schemes for Scottish salmon require lower standards than might reasonably be expected by consumers, while breaches of the standards are rarely enforced.1 Some examples of the limitations of the Soil Association organic standard (and proposed updated standard) are outlined below: Mortalities We acknowledge that the updated standard aims to a. [...] However, as is the case with other certification schemes in the Scottish salmon farming industry, the suggested amendment relates only to reporting mortality incidents above specified thresholds (already required under the industry’s Code of Good Practice voluntary reporting regime (2015)2) and does not impose any limit on the mortalities permitted. [...] It is difficult to see the ‘added value’ of Soil Association’s organic standard in this area, even in its updated form, as the requirements do not go beyond the industry’s Code of Good Practice and requirement of Regulations. [...] As with the proposed requirements on mortalities, the focus is on reporting actions taken by the farm, and not on the outputs and potential impacts of that farm on the environment.