Published name
Name of the organisation your response is on behalf of (if applicable)
Which of the following best describes your situation?
Which sector do you represent?
You may wish to upload your submission here:
World Animal Protection
120 Christie St
St Leonards NSW 2065
Mtamulevich@worldanimalprotection.org.au
03 March 2025
Australian Agricultural Traceability Assuring Sustainability Claims Working Group
Department of Agriculture, Fisheries and Forestry
GPO Box 858 Canberra ACT 2601
By email: credentials.innovation@aff.gov.au
World Animal Protection Submission: Sustainability claims for International Markets
Dear ASCWG Members,
World Animal Protection welcomes the opportunity to comment on the Assuring Agricultural
Sustainability Claims Discussion Paper.
On behalf of our more than 86,000 supporters across New South Wales, we acknowledge and support the intent behind the discussion paper and its analysis of the various sustainability claims that must be considered for international trade. We want to emphasize the importance of translating community expectations regarding animal welfare and the scientific reality of animal sentience into rules, regulations and law.
As the discussion paper also notes, many of Australia’s international trading partners are placing increasing emphasis on sustainability, and animal welfare is a critical topic with respect to demonstrating sustainability claims.
There are clear reputational issues arising from Australia’s ongoing failure to effectively ensure transparently assured animal welfare standards. Farming and wildlife care practices, in particular, are increasingly scrutinised by other stakeholders, both nationally and internationally. Unfortunately,
Australia currently holds a D ranking on the World Animal Protection Animal Protection Index, owing to the failure of our national frameworks for animal welfare, related regulations and their enforcement to keep pace with international best practice1.
The discussion paper identifies this critical importance but proposes isolating consideration of animal welfare claims only to animal-based sectors. We encourage the ASCWG to more broadly apply animal welfare considerations across sectors to avoid unintended consequences that may result from siloing animal welfare concerns solely into animal-based sectors. For example, We note that climate mitigation strategies in many sectors may have unique animal welfare implications and risks.
1
https://api.worldanimalprotection.org/country/australia
Additionally, due to the varied interpretations of the term “animal welfare” across industries, we recommend that the glossary include a definition of “animal welfare” that serves as a common reference between stakeholder groups. This definition should incorporate the principles of the Five
Domains, a science-based model widely utilised across industries. We suggest using the following definition, informed by the World Organisation of Animal Health:
Animal welfare refers to the physical and psychological wellbeing of an animal. The welfare of an animal can be described as good or high if the individual is fit, healthy, free to express natural behaviour, free from suffering and in a positive state of wellbeing.
We also suggest that the paper review the glossary definition of the term “greenwashing” and either amend it to explicitly incorporate animal welfare concerns or add the term “humanewashing” to the glossary as well.
While greenwashing is commonly associated with the environmental and climate implications of a product or practice, humanewashing is an increasingly utilised term that explicitly acknowledges attempts to mislead consumers about the treatment of animals. This term allows for more specificity when describing sustainability claims that have a deleterious impact on animal welfare.
Finally, we want to express our disappointment that the process to date has seemingly neglected critical insights from animal welfare professionals. The various sustainability frameworks that are used as references within the paper -ABSF, AASF and ADSF- draw heavily from industry stakeholder consultation. This, coupled with the fact that animal welfare organisations were not notified about the consultation when it was announced in December, has meant that the discussion paper is lacking in its consideration of animal welfare and our sector has had insufficient time and capacity to respond.
Given the critical importance of animal welfare to sustainability claims, we request that the ASCWG engages substantively with Australian and international animal welfare experts who can provide unique perspectives and insights into animal-based sectors, as well as on native wildlife, climate, and farm animal welfare.
We appreciate the opportunity to contribute to this consultation and look forward to participating in any subsequent discussions involving animal welfare and sustainability claims for international markets.
Sincerely,
Ben Pearson
Country Director
World Animal Protection
Australia and New Zealand