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Aquacul ture Stewards hip Counci l Foundation
Daalseplein 101
3511 SX Utrecht
The Netherlands
Charity (KvK-nr.34389683)
Melbourne, June 2024
Ref: Data Interoperability Framework/DAFF/Feedback
As an organisation, the Aquaculture Stewardship council (https://asc-aqua.org/),
supports any initiative that improves traceability and transparency. We endorse the
GDST initiative and are part of their technical committee. The GDST has a strong
GS1/EPCIS element and collaborates with IFT. I would like to use the opportunity to
share our experience with the digital traceability project we’re working on. Over 2000
seafood farm sites are certified to the ASC farm standards and over 3000 companies
have CoC certification.
We can’t advocate full adoption of GS1/EPCIS in its current format as it is currently not
adapted to the needs of the seafood industry. The GS1 standard focuses on product
when it is packed (mainly retail shelve ready packaging) and largely ignores the
complexity of the supply chains prior to the product being packaged (e.g. fish in
crates, live transport etc etc). Probably a major issue is also that GTINs, which are
required, don’t come for free.
Another example is the limited use of GLNs (a lot of places, certainly at farm level,
don’t have these as a fee is charged): we would advocate the use of GeoCoordinates
of the farm gate as being much more transparent and accessible.
Despite GS1 being used in parts of the industry and widely known, if GS1/EPCIS was
easy to adopt, it would already have been widely adopted. Apart from in the
pharmaceutical industry and last mile retail, it hasn’t, and a lot of data still travels as
text via emails. In its current format, GS1/EPCIS appears to be similar to
blockchain, “written by software developers for the benefit of software developers”.
It currently only really works if a full chain has adopted and is using a single IT
platform.
It ignores the fact that the world largely works with Excel sheets when the product hasn’t
been packed in consumer ready tamper proof packaging. We are not aware of a
single full Aquaculture supply chain that has fully adopted GS1/EPCIS. Moreover, a
‘state-of-the-art’ blockchain trial we participated in, had a large part of the data
transmission done via excel sheets and emails. Certainly, in the Aquaculture
industry, and as far as we understand, in the wider seafood industry, GS1/EPCIS is
experimental when it comes to full chain implementation. While it is certainly the aim,
unlike stated on Page54 of the consultation document, GDST/EPCIS hasn’t been
widely adopted in the Seafood industry. The idea or concept is widely supported, the
implementation hasn’t followed suit.
www.asc-aqua.org
Aquacul ture Stewardshi p Council
An important issue is also that GS1 does not aim to be transparent, which should also be
part of the discussion. Another important issue is the (unnecessary?) excessive
detail and data fields often requested. Often an incomplete data set will sufficiently
demonstrate provenance and substantiate traceability. It is unfortunate that this
exercise often turns into an audit/tick box exercise where missing even a single KDE
would lead to non-compliance, which is completely unnecessary.
The use of Excel sheets is also recognised by the US Food Safety and Drug
Administration (FSDA) in their new food traceability legislation (FSMA 204). Excel
sheet submissions are permitted and accommodated; they have not expressed any
intention to remove that option (they will also allow GS1/EPCIS). We believe any
failure of 3rd party initiatives to accommodate Excel /CSV interoperability will hamper
any roll out of digital traceability.
Digital traceability and adoption of standards also comes potentially at a (very) high cost,
which never seems to be mentioned. Cost should be part of any debate and
consultation. A Swedish seafood industry organisation seems to be the only
reference, willing to publicly state the related costs of implementing a Swedish
government digital traceability initiative: it cost each of their members on average
euro180K ($290000 Aud) to adopt. Initiatives like GDST, standard setters such as
GS1, the Institute of Food Technologists, and others have never publicly clarified or
gave an indication on how much adoption of GS1/EPCIS and/or other standards
would cost. Reference: EU talk on traceability: https://eumofa.eu/eumofa-talk-
digitalisation-of-the-fisheries-sector-traceability
Cost implications for digital traceability adoption for small operators is also raised as an
issue as part of the EUDR implementation:
(https://environment.ec.europa.eu/topics/forests/deforestation/regulation-
deforestation-free-products_en)
The critical tracking events and data elements developed by organisations such as (but
not limited to) the IFT (which is heavily GS1/EPCIS based) can’t be readily adopted
in its current format, as they, as far as we are aware, don’t adequately interoperate
with Excel. The IFT nor the GDST haven’t published any instructions on how to
adopt these standards while (partly) using Excel, which is used and will be used by a
huge number of small Australian companies for quite a while.
Standard setters and initiatives should be encouraged or required to come up with
adequate solutions for interoperability, how to adopt electronic interoperability in an
Excel context first, not just leave it to industry and small businesses to try to find out
how to do so. Leaving it to small operators unnecessarily delays adoption and
makes it much more expensive. Excel interoperability makes it easier for small
operators to slot into a traceability space at minimal expense, allowing to gradually
adopt more performant systems when finances allow doing so.
Page 2 of 3
Aquacul ture Stewardshi p Council
We believe that full digital interoperability is an aim worthwhile perusing. We actively and
happily support and contribute to initiatives to achieve this. But we also believe it
should be a gradual process and should accommodate Excel/CSV submissions. No
standard should be adopted or imposed if it excludes this or makes the use of Excel
difficult. Tools to transition between both should be developed and be publicly and
available at no cost.
If you require clarification or would like to discuss any topics raised further, please feel
free to get in touch.
Kristof Bevernage
Senior Programme Assurance Manager,
Project manager of the Digital traceability project,
Department of innovation ASC.
KDE@asc-aqua.org
Page 3 of 3
Refer to section 2.3. Do you agree with the proposed high priority artefacts to be developed to support interoperability?
Refer to section 2.3.1. Do you agree with the criteria for selecting existing interoperability resources to leverage in the framework?
Please provide comments (optional)
ease of adoption is missing
Are there any other criteria for selecting existing resources that should be included? (optional)
ease of adoption, cost of adoption of existing models
Refer to section 2.3.2.1. Do you agree with the criteria for selecting the most important data terms to be included in the vocabulary?
Please provide comments (optional)
there needs to be a 'reality check' on the data fields. Your example of 'meat marble score' is a good one: it needs to be cross referenced with industry.
Refer to section 2.3.2.2. Please indicate your preference from the following:
Please provide comments (optional)
The IFT methodology discourages the use of Excel and doesn't offer any excel/CSV facilities
Refer to section 2.3.3. Would an agricultural traceability and product data ontology be a valuable resource to support interoperability?
Please provide comments (optional)
as long as it doesn't hamper Excel/CSV us.
Refer to section 2.3.6.2. How can the issue of multiple location identifiers be addressed? (optional)
GLNs should not be used, geoboundaries/polygons and/or coordinates (e.g. farm gate) should be adopted (geojson).
Are there any other gaps in data standards you would like to see addressed? (optional)
ease of use/ease of adoption
Refer to section 2.3.6.3. Are there any risks or issues you know of with the W3C Verifiable Credentials and Decentralised Identifiers (DID) standards? (optional)
Cost. But also the assumption that it would be Cryptographically secure. Origin and other data can be faked at any stage, so fake data that has been Cryptographically secured, doesn't make it real. It gives people and verifiers a false sense of security. I'm not sure if this should also be a priority: there is no or hardly any digital traceablity, there is no interoperability, therefore I would argue there are higher priorities, the risk this becoming a distraction from the real task.
Refer to section 2.4.1. Do you think any parts of the framework should be mandatory to use in the development of data systems?
Refer to section 2.4.2. Is the proposed governance structure adequate to support the development and maintenance of the framework?
Please provide comments (optional)
industry needs to include small businesses and small farmers (data interoperablity governance group)
Please list any stakeholder groups you believe to be missing from the proposed governance structure (optional)
small businesses and small farmers
Refer to section 3.1. How might these barriers be addressed? (optional)
include Excel and CSV and gradually take it from there.
Are there any other barriers to adoption of the framework that you can think of? (optional)
As seen in other projects, if the project becomes a project 'designed by software engineers for software engineers'/hijacked by 'IT companies and engineers', that would create a major barrier.
Refer to section 3.3. Do you agree with the roles and responsibilities listed?
Please provide your reasons and alternative suggestions
to be added for agriculture tech providers: provide low cost, low maintenance solutions