Beyond the Paper Tigers of Sustainable Sourcing:

There is a striking disconnect in the food industry today: companies invest heavily in sophisticated food safety and quality assurance (FSQA) systems while often treating sustainable and ethical sourcing as little more than paperwork exercises. This disparity persists even as sustainable sourcing occupies increasingly larger portions of customer specification sheets and has evolved from nice-to-have commitments to regulatory requirements.

As someone who has spent years on processing plant floors and in boardrooms discussing both quality standards and sustainability initiatives, I've observed this inconsistency firsthand.

Why don't we apply the same verification rigor to sustainable sourcing that we insist upon for food safety?

The modern food safety landscape wasn't built overnight. Decades of hard-learned lessons—many following significant public health crises, product recalls and ensuing laws and regulations—have established today's robust preventative control plans and verification systems. Companies now understand that food safety isn't just about having policies; it's about continuous verification, validation, and risk management. These systems represent significant investments, but they're universally considered essential business costs. Why? Because the consequences of failure—regulatory action, consumer illness, brand damage, and litigation—are too severe to risk.

Now contrast FSQA compliance policies with how many companies approach supply chain integrity compliance policies: A policy is crafted, published on the website, communicated to suppliers, and written into spec sheets. Perhaps an annual self-assessment questionnaire goes out. Maybe third-party NGOs conduct occasional spot-checks. But real-time verification? Continuous monitoring? Data validation? The rigorous verification tools common in FSQA are rarely part of the picture.

Why This Matters Now More Than Ever

The stakes for supply chain integrity — sustainable & ethical sourcing verification have never been higher:

Regulatory Evolution

While food safety regulations have long been established, sustainability and ethical sourcing are rapidly becoming codified in law: The US Seafood Import Monitoring Program (SIMP), US Forced labor import restrictions (UFLPA), US Russian Import Ban, UK IUU Fishing Requirements, EU's CATCH Certificate Scheme are well known examples industry deals with every day. Non-compliance is no longer just a PR issue—it now carries legal consequences.

Consumer Expectations Reputational Risk

Today's consumers expect action, not just promises. Millennial and Gen Z consumers are increasingly sophisticated about greenwashing and demand verification. Exposés like those from The Outlaw Ocean Project and others have pulled back the curtain on supply chain abuses. Social media can amplify failures globally in hours, not days — potentially resulting in brand damage, boycotts and lobbying for more onerous regulations on industry. 

Competitive Differentiation

As sustainability commitments become ubiquitous, the differentiator is shifting from having policies to proving they're being followed. Leading brands are beginning to recognize that verification isn't just risk management — it's a competitive advantage.

Too Little, Too Late: Traceability and Annual Reviews

Food safety policy verification is continuous, objective, and designed to help reduce risk, reduce harm and ensure compliance with the law in as “real-time” as practical. Sourcing policy verification deserves the same approach. Up until now, two common approaches have emerged, both falling short:

Too Late: The Annual Manual Review

Would any reasonable company leave the verification of their food safety controls—critical assurance that their products are safe and compliant with customer and legal requirements—to a once-per-year retrospective analysis by an advocacy organization? Of course not. Yet, this is precisely how many companies approach sustainable sourcing verification.

Here's how it works: NGOs-for-hire and consultants manually review annual data dumps from companies and perform ex-post analysis of sourcing data and provide an assessment of "risk" and application of their sourcing policies, plus gain some public recognition. This outdated practice is more sparkle than substance, as it misses the opportunity to flag compliance issues or course correct sourcing in real time to meet company and customer goals.

Too Little: Traceability Without Validation

Imagine a food safety system that dutifully recorded temperatures but never alerted anyone when they fell into the danger zone. That's effectively how many traceability systems operate regarding sustainability and compliance claims.

Standard traceability software suffers from an inability to validate sourcing data, widespread failures in interoperability and a lack of investment in real-time alerts or in-depth analytics. Many companies have invested in traceability systems believing that simply collecting data was sufficient. Others devote additional time and effort to verifying data collected by a traceability provider. Traceability puts all the hard work of validation and due diligence—and all the compliance risk—on the seafood company paying the traceability provider. It makes one wonder ...what am I paying for?

I witnessed this exact type of disconnect during a supplier plant visit once—back when I worked as FSQA & Sustainability Manager for a seafood wholesaler. I remember observing quality control staff diligently sampling and recording individual product weights as instructed—but they continued writing down out of spec measurements without stopping to interpret the data and investigate if and why the grade was not meeting the spec. There was no understanding of why they were collecting this data or what actions should result from different data results; most importantly what to do if results indicated non-compliance to the customer spec. The inspection had become a mindless exercise in data collection and passing data forms along the supply chain rather than a meaningful quality control mechanism intended for actionable insights during production to prevent non-compliant product reaching the customer.

This anecdote from my experience working in FSQA perfectly illustrates the current state of most supply chain integrity policies — data is collected but rarely validated, analyzed, or acted upon in real-time. Traceability providers can’t provide this level of service, and manual validation is inefficient, costly and impractical for most companies within the supply chain to handle at scale. NGOs are paid to produce yearly retrospectives — a year too late to be operationally useful. 

Opportunity Awaits

Good intentions are there. Good people and lots of hard work and investment goes into researching and crafting sustainable and ethical sourcing policies. The policies exist, but they're what are known as "paper tigers" — impressive on the surface but lacking teeth and substance.

What is the answer?

Part 2 of this blog post will outline The Better Way Forward — how to bring FSQA rigor to sustainable and ethical sourcing polices. Coming Thursday.