Choice editing and the role of regulators

When I started my business as a frozen seafood importer, I was driven by the idea of creating a company in line with my values: we would supply products we are proud of, adhering to our ethical beliefs. However, I quickly realized that the challenge was much greater than I thought. The reality was that my colleagues and I are informed consumers, aware of what quality seafood is. On the contrary, most of our end consumers are making decision based merely on price.

Now, the world of frozen seafood is a very tricky one: producers and importers are never lacking creativity in finding ways to lower down the price of their products or at least giving the illusion of it. Would you believe me if I told you that the main ingredient imported in frozen seafood is not fish… but water? One of the most common practices in the industry is to add a layer of ice around the product. Initially, a thin layer of ice, counting for barely 3% of the product’s weight, was added to protect the fish from the effect of “freezer burn” which affects the taste and texture of the product. Nowadays, in order to compensate for the constantly increasing costs of raw material, the wide majority of frozen shrimps sold in the UK through small independent retailers contain 30% to 50% of water. While net weights are clearly stated on the packaging, UK consumers still go for the cheapest product regardless of the water content.

Shrimp on ice blockThis results in even more unsustainable supply practices pushing consumption, lowering down quality standards, and increasing energy use and GHG emissions. In order to add that much water to a shrimp, a factory has to freeze it two to three times in a row, adding a new layer of water each time resulting in as much additional energy consumption. Also, considering that farmed shrimps are mostly, if not exclusively, produced in tropical climates, transport-related carbon emissions for those products are 40% higher than they should be.

As a company, we have consistently refused to go down that path and promoted products free of unnecessary ice.  While fishmongers, who sell shrimps defrosted and therefore are technically sensitive, responded well to our approach, we did not sell one bag of frozen shrimp to Cash and Carry stores or independent grocery shops! They would not buy a product without enough water added to reach their target price. Choice editing might be an option for large retailers or well-established companies with relatively captive customers, but it is very challenging for smallholders who can only have a marginal effect on market trends, especially in a very scattered market made of small independent retailers.

In this specific context, one can wonder why regulators aren’t taking necessary measures to protect consumers and limit unsustainable production, which is also referred to as “citizen choice editing”. The general opinion to rely on businesses to bring more sustainable products to the consumers is valid to a certain extent but for some markets, the main driver of change is the policy makers who have the power to guide stakeholders to more sensible practices.



  1. Fascinating subject, ND438. As someone involved in the growing, packing, importation and distribution of fresh fruits and vegetables, I see some interesting parallels between our experiences. Much of my focus and interest has been on loss or waste of fruits and vegetables, and I’ve found it helpful to think of the water content of the item itself in exploring potential alternatives. It seems that efforts can be made to reduce, maintain or increase the water content of items. Each of these efforts seem to describe a specific category. For instance, those involved in reducing the water content of fresh items may be involved in ‘dehydration’; those involved in maintaining the water content may be involved in ‘fresh’; and those involved in increasing water content may be involved in ‘frozen’.

    There are dehydrated, fresh and frozen categories in both sea food and fresh produce industries. The situation you have described involves the increase of water content through adding water and freezing, and the abuse of that practice by adding more water and re-freezing, thereby increasing the weight of the item. Though, at the same time, adding water and freezing it seems to be part of the nature of the frozen sector. Within the fresh sector, we work to avoid product ‘shrink’, though, I suppose there would be reason for concern if the weight of our product were to be artificially increased as well. An increase in weight would be ‘untrue’ to the category. Similarly, those involved in the dehydrated category may cheat the system by not dehydrating their product sufficiently. Though, a juicier dehydrated mango, for instance, might be more marketable than one resembling leather in consistency.

    It seems that so long as the product is to be sold, the desire is to have a product with more weight while being true to the category. The situation of abuse that you describe within the frozen category seems to suggest an alternative, ‘super frozen’ category. Could there similarly be a ‘super dehydrated’ category following water content levels?

    Super dehydrated — Dehydrated — Fresh — Frozen — Super frozen

    Both sea food and produce are highly perishable products. Dehydration and freezing may each prolong shelf-life of the product, but when a product fails to be sold, most would probably prefer to have a items with less weight, reducing disposal fees. If it’s any consolation, perhaps those ‘super freezers’ that cheat the system pay more to dispose of their product.

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  2. It is a good read, showing all the difficulties in the frozen food industry in sustainability challenge not only about catching fish but also about more about preserving fish. There are no clear technology or method clearly can reduce use of water and energy. Nevertheless, have the industry every looking at other cooling method to preserve fishes? Such some of the air condition unit now are now using seawater cooling and in some application in medical sector are now using reusable chemical cooling.



  3. Insightful article – I had no idea about the additional ice used in seafood industry. As a consumer, it would be so useful to see comparison of water content of products! I’d rather purchase 1kg prawn meat than 700g of actual meat for the same price. I wonder if say a supermarket would be willing to display this kind of information so a consumer could decide.

    To your point about the regulatory intervention (rather than relying on businesses to influence change) – what do you think the hurdles are? What is preventing governments (in general) from acting?



  4. This is a fascinating subject and one that is important to bring to the fore so thank you. The general focus on the seafood industry has largely been on sustainable catch methods and rightly so – we’ve been overfishing for decades and the oceans and wider environment in turn have been suffering as a result. In more recent years, as we’ve started to improve the catching methods we use, focus has started to shift from sustainable sources to the social issues and poor labour standards involved in the fishing industry – fishmeal catch from Thailand attracting particular attention, and again, rightly so.

    However, this has all meant that the rest of the value chain has been left relatively unscrutinised. You can, for example, purchase a ‘sustianable’ fillet of fish meal over a UK counter which has been certified by an independent third party which many consumers recognise as a sign of ‘quality’ and ‘goodness’. However, that same fish may easily have travelled across the globe twice to be processed in a country far away from where it was sustainably caught, and similarly far away from where it will, ultimately, be sold and served. You also rightly point out that during the processing of seafood, there are elements added to it, which themeselves require energy to apply (and then take off again!) but also add to the weight of the product, hence increasing any impact of their air miles exponentially.

    As Naureen aludes to, this is not something that consumers are too aware of. Particularly when products are already labelled as ‘sustainable’ because its been caught in a sustainable way, this is oftern enough for a consumer to take in. Over labelling our products can be confusing and it can be off-putting. My own view is that consumers will buy from the brands they know and trust – and that this trust can be built in a number of ways. I’m not of the view that labelling the products with all the details of the value chain is the right way to go.

    However, should we, as consumers be generally more informed? As the old saying goes, we are what we eat and we eat for a good proportion of our waking days – its not an insignificant part of our lives and yet we arguably, know very little about what it is we’re putting in our bellies or feeding our families. I agree that there is a role for the regulators but is there also a role for the education system? Would educating our young generation on where their food comes from and under what circumstances (and how the people who handle it are treated) not mean they are more informed to make their own decisions on what is right and wrong? It could mean that the more holistically ‘sustainable’ products automatically become the preference, it could mean that intesively farmed meat is left on the shelf while the free range options are taken home – it could mean that more people understand what free range really means… or it could even lead to us eating more seasonally, more locally and more sustainably.



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