Enabling Agricultural Traceability through Data Interoperability

June 13, 2024

Department of Agriculture, Fisheries and Forestry
Australian Government

Submitted via email, 1 July

Comment on Data interoperability framework for agricultural traceability and product data: consultation paper

The Marine Stewardship Council (MSC), established in 1997, plays a pivotal role in the global sustainable seafood movement. As a leading international non-profit organization, the MSC sets rigorous environmental standards to ensure the health and sustainability of the world's oceans.
Today, 674 fisheries worldwide are engaged in the MSC program, demonstrating their commitment to sustainable practices. The impact of the MSC's work is evident, with more than 20k MSC-labelled products available in 66 countries and over 47k sites holding MSC Chain of Custody certificates, forming a robust and traceable sustainable seafood supply chain. (MSC annual report 22-23)

The MSC relies heavily on its Chain of Custody (CoC)and traceability systems to uphold and assure the MSC claim of sustainability. The Chain of Custody certification ensures that every step in the seafood supply chain is monitored and verified. This rigorous certification process ensures that
MSC-labelled products are sourced from certified sustainable fisheries. Through its CoC standard’s traceability requirements, the MSC assures that the seafood consumers purchase with the MSC label is sourced from a fishery certified as sustainable against the MSC fisheries standard, maintaining the integrity and credibility of the MSC claim. This robust system is fundamental to the
MSC's mission, assuring consumers and stakeholders that their seafood choices contribute to the health and sustainability of the world's oceans.

The MSC's Traceability Enhancement Program (TEP) aims create a Traceability Standard that is evolved from the MSC Chain of Custody (CoC) Standard. This new Standard will incorporate key aspects of the CoC standard, like the need to segregate and identify certified products, and will
bolster traceability requirements through the reporting of specific, standardized, digital data for key activities like landing, processing, and the shipping and receiving of products. The TEP leverages the progress made in digital traceability and will reinforce the integrity of the MSC ecolabel by further strengthening our traceability requirements and digitizing data collection and auditing. Our approach relies heavily on standardization and interoperability and promotes a decentralized data sharing approach.

The MSC welcomes the National Agricultural Traceability Strategy 2023 to 2033, which identifies data interoperability as key to reducing agricultural traceability costs, increasing product value add, and responding to food safety and biosecurity risks. This initiative aligns with the MSC's commitment to robust, traceable, and sustainable supply chains, further supporting our mission to ensure the health and sustainability of the world's oceans.

We work with the Institute of Food Technologists (IFT) & the Global Food Traceability Center (GFTC) to support our Traceability Pilot and have aligned our submissions with their insights and recommendations. We would like to express our gratitude to the IFT and GFTC for their invaluable work and support, which have significantly contributed to our efforts.

Responses to Consultation Questions
Consultation question 2: Refer to section 2.3.1. Do you agree with the criteria for selecting existing interoperability resources to leverage in the framework?

We concur with the proposed criteria for selecting existing interoperability resources for the framework, which include adoption, credibility, longevity, support and governance, cooperation, and alignment with Australian Standards. These criteria ensure that the selected resources are robust, reputable, and capable of supporting the framework's objectives.

However, we advise against entirely excluding newer or less widely adopted standards and resources. The food industry has historically been slow to embrace new technologies and practices, but this should not prevent the consideration of valuable resources. Embracing newer innovations can drive necessary change and improvement in the industry. Therefore, maintaining a balance between established and emerging resources is essential to ensure inclusivity and adaptability.

Consultation question 3: Refer to section 2.3.1. Are there any other criteria for selecting existing resources that should be included?
An additional criterion that may be considered is the existence of multilingual support for resources and standards. While Australia may not require extensive multilingual support domestically, considering the global nature of food and agriculture supply chains, it is prudent to plan for potential international applications of the framework. Multilingual capabilities can facilitate broader adoption and interoperability on a global scale, supporting widespread use of the framework.
Consultation question 5: Refer to section 2.3.2.2. Please indicate your preference from the following:

We strongly prefer option (a) – utilizing the Critical Tracking Events (CTEs) and Key Data Elements
(KDEs) developed by the United States-based Institute of Food Technologists (IFT) as the foundational traceability data terms. Leveraging the CTE/KDE framework, which is already widely recognized and implemented, will ensure consistency and interoperability across global supply chains, benefiting both Australian stakeholders and international trade partners.

GS1’s suite of standards that support supply chain traceability, several of which are referenced in this consultation paper, reflect the foundational framework of CTEs and KDEs. At the Marine
Stewardship Council, we have chosen to work with the Institute of Food Technology and apply the
CTE/KDE framework to digitize traceability requirements for any entity handling MSC Certified products. We are proposing to introduce a CTE/KDE matrix in the next iteration of our Chain of
Custody standard, for which MSC will also seek alignment with the Aquaculture Stewardship
Council. Here, we have opted to follow the Global Dialogue on Seafood Traceability-developed
CTE/KDE framework at the commodity level, establishing data requirements that enable legal and traceable seafood.

Adopting this established framework will facilitate international harmonization and provide a solid foundation for the Australian traceability system, supported by existing resources.

Consultation question 6: Refer to section 2.3.3. Would an agricultural traceability and product data ontology be a valuable resource to support interoperability?

We affirm that developing an agricultural traceability and product data ontology would be a valuable resource to support interoperability. An ontology will aid in the semantic understanding of traceability data and the relationships between data elements. This is crucial as many traceability use cases, such as sustainability or food safety initiatives, require an in-depth understanding of data.

A robust ontology that describes the properties of events, including their meaning, structure, and components, will further aid in consistent technical implementation across the diverse software platforms used throughout the industry. This consistency is vital for ensuring that different systems can effectively communicate and share data, enhancing the overall interoperability of the traceability framework. Prioritizing the development of an ontology alongside other framework components will enhance the framework's overall efficacy.

Consultation question 10: 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?
While W3C Verifiable Credentials (VCs) and Decentralised Identifiers (DIDs) offer promising approaches for secure and verifiable data exchange, they are relatively new and lack established implementation protocols and best practices. This nascent stage of development poses risks related to reliability, security, and standardization. Until these technologies mature and gain broader acceptance, it may be prudent to exercise caution in their adoption within the framework.
Consultation question 11: 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?

We believe that the framework should initially be voluntary to allow for adjustment and revision during implementation. However, there is merit in considering a strategy that includes mandatory elements to kickstart adoption. A phased approach, targeted toward specific commodities and outcomes, would be particularly beneficial.

For instance, mandating the collection and reporting of a specific set of Critical Tracking Events
(CTEs) and Key Data Elements (KDEs) related to product identification and movement data applicable to all agricultural commodities could serve as an effective starting point. These requirements could first be mandated to achieve priority outcomes in specific supply chains. For example, mandating traceability data in seafood supply chains could be used to monitor and reduce the incidence of IUU seafood entering Australian markets.

A well coordinated strategy with voluntary sustainability standards could leverage the phased approach. As sustainability standards we could support the industry with staying ahead of upcoming mandatory traceability requirements.

By targeting high-priority outcomes like IUU reduction and/or high-risk commodities, such as seafood, in the early phases of implementation, the framework can leverage existing data collection and sharing practices. These areas already acknowledge the need for improved traceability and have some level of infrastructure in place. Focusing on these sectors will not only demonstrate the value of the framework but also help achieve critical industry buy-in, as the drivers for data collection and sharing are already largely recognized.

This approach, which initially focuses on mandatory CTEs/KDEs, may also provide a valuable foundation for the development of interoperable software systems. It would prompt a large number of industry actors to start collecting data in a standardized manner, allowing for more informed and robust opportunities to pilot the technical nature of the framework and interoperability measures.

Over time, as the benefits of the framework become evident and adoption increases, the scope of mandatory elements can be expanded. A well-planned phased mandate can significantly enhance the framework's effectiveness. It ensures that the framework is tested by a diverse range of actors in agricultural supply chains, not only by industry leaders.
Consultation question 12: Refer to section 2.4.2. Is the proposed governance structure adequate to support the development and maintenance of the framework?
The proposed governance structure appears inclusive of necessary stakeholders, which is commendable. However, additional clarification is needed regarding the power and representation of each group within the structure. Ensuring that all stakeholders have appropriate authority and representation will be crucial for balanced decision-making and effective governance of the framework.
Consultation question 14: Refer to section 3.1. How might these barriers be addressed?
To address the barrier related to the cost of purchasing recommended standards and associated services, we recommend the use of Digital Link URIs as identifiers. An application of this solution may be observed in the Marine Stewardship Council’s traceability pilot, where we apply the GDST
Standard that supports the use of Digital Link URIs, referred to as GDST identifiers, as a solution for supply chain actors for whom registry-based identifiers (e.g. GS1 GLNs) are not accessible.

However, it is important to acknowledge that using another form of identifier may exacerbate issues related to multiple location identifiers. A comprehensive evaluation of identifier systems should be conducted to balance cost considerations with interoperability needs.
Consultation question 15: Refer to section 3.1. Are there any other barriers to adoption of the framework that you can think of?
A notable barrier that needs to be addressed is the continuity of traceability regulations and initiatives, through the provision of adequate resources for the development and maintenance of the framework. Ensuring that sufficient funding, technical support, and infrastructure are available will be critical for the successful adoption and sustainability of the framework.

We also acknowledge that a key challenge is to educate the industry around the different applications of traceability and the potential of decentralized data management. Specifically concerns around data privacy and security would need to be addressed.
Consultation question 16: Refer to section 3.3. Do you agree with the roles and responsibilities listed? If not, please provide your reasons and alternative suggestions.
We generally agree with the listed roles and responsibilities. However, we suggest that supply chain stakeholders be actively involved in the development process. Their practical insights and experience will be invaluable in shaping a framework that is both feasible and effective. Engaging supply chain participants early and throughout the development process will enhance the relevance and adoption of the framework across the industry.