This consultation is part of our work to improve outcomes in five key areas for organic farmed salmon – mortality, veterinary treatments, welfare, sustainable feed, and environmental impact. Some of the progress we are seeking against these priorities will come from standards-led actions, but achieving impact in the sector will require action at all levels and alongside this we are working with businesses, environmental organisations and regulators to explore opportunities.
The consultation sets the scope for standards-led approaches. This is limited to organic aquaculture operations with specific focus on farmed salmon. These proposals are restricted to the marine stage of organic aquaculture operations and are organised into five sections which introduce proposals to:
tackle mortality rates on organic farmed salmon sites,
reduce the impact of medicinal treatments on the wider marine environment,
develop welfare outcome assessments to support delivery of a good life for farmed salmon,
enhance the sustainability of organic aquaculture feed,
minimise potential environmental impacts associated with organic farmed salmon sites.
This consultation should take between 15 and 45 minutes to complete, depending on your technical expertise. There is space at the end of the consultation to provide any general comments. It will close on Sunday 15 March.
If you have any further information you would like to provide, please contact the Soil Association standards team on standards@soilassociation.org
Soil Association tests for organic farmed salmon
Although our organic standards are the strictest in the salmon industry, our research concluded that fish welfare and environmental outcomes are not always at a level the Soil Association finds acceptable. More needs to be done to address issues including fish suffering amid sea lice outbreaks, high mortality rates, and the release of veterinary medicines that can cause harm in the wider environment. These problems are more pronounced in conventional systems, but they are still unacceptable on Soil Association certified organic farms.
We have identified a possible pathway that combines changes to our standards, with a more enabling policy environment led by Scottish Government and active participation by industry, to swiftly address the concerns and drive measurable improvements.
Due to the level of concern we have over environmental and welfare outcomes, we need to deliver this work at pace. We need to see clear action and progress within one year on our areas of essential change for Soil Association’s continued involvement in the farmed salmon sector. The Soil Association has set five key ‘tests’ for organic farmed salmon with initial one-year goals as part of some longer-term ambitions. These tests are laid out below.
Organic standards are built on prevention rather than cure. We prioritise systems that ensure high welfare, good management practice and regular reporting. In doing so, organic salmon farms are required to mitigate the risk of mass mortality events occurring. Identifying what we believe to be unacceptable mortality on salmon farms will consider a number of cause factors ranging from management methods through to one-off environmental events.
We believe that the Soil Association standards can go further to ensure that sites are adequately prepared to mitigate the risks of mortality events, including those driven by the novel and unprecedented challenges that climate change is presenting or may yet present.
Within one year we will:
Analyse the causes of mortality, and update standards for preventative management, including those for monitoring and reporting to ensure that producers are taking all possible measures to prevent unacceptable levels of mortality.
Develop a definition of unacceptable levels of mortality. Use this to test if unacceptable mortality is occurring for individual operators and across the sector.
We will work with the Aquaculture Task & Finish Group to determine these definitions and the contexts in which unacceptable mortality can be identified.
The Soil Association has a long history of campaigning against harmful chemicals, and we are opposed to the use of these treatments in salmon farming. However, we have, to date, accepted that producers need access to some treatments so that they can follow veterinary advice and treat animals that are sick or suffering with parasites like sea lice. Two of the most harmful veterinary medicine treatments used by the sector, emamectin benzoate and azamethiphos are banned in Soil Association organic standards.
Deltamethrin can be used as a veterinary treatment by organic salmon farmers at marine sites, with strict withdrawal periods before fish can be harvested. The use of deltamethrin is a third of that used by the non-organic sector and many organic sites already operate without using it at all. Current standards stipulate a maximum of two allopathic treatments in a 12 month period, meaning deltamethrin could only be used twice per year, and only as a last resort. It also cannot be used preventatively. Nevertheless, we remain concerned about the environmental impacts of deltamethrin, which is a persistent chemical. As such, we do not believe that a system that relies on it as a last resort can be sustainable in the long term.
Within one year we will:
set a timescale for banning the use of deltamethrin.
We will work with an Aquaculture Task & Finish Group to identify the pace at which a full ban on use of deltamethrin can be enforced and look to do so as early as practically possible.
As part of our review, we convened an independent, international expert group, the Farmed Salmon Welfare Panel, whose remit was to identify the key components of a ‘good life’ for farmed salmon. The panel found that, of the different life stages, it is most challenging to provide a good life for farmed salmon smolts at sea (in the grower phase in sea pens). Most members of the panel* consider there’s a high risk that currently smolts at sea do not have a good life, but that with substantial system changes, a good life could be possible. Following the report outlining the deliberations of the panel, we identified key areas for standards development that we believe could deliver a good life for salmon and have mapped a pathway for developing standards and reviewing their impact. We will seek independent experts to review the impact of these standards to check that they are delivering outcomes consistent with a good life.
Within one year we will:
require organic salmon producers to carry out additional welfare outcome assessments (WoAs) according to defined welfare indicators recorded for monitoring and reporting. We will collaborate with other standard setters, such as RSPCA, to roll out these welfare outcome assessments, as part of our goal to drive improvements across the entire sector, not just organic.
develop a more detailed reporting system for Soil Association Certification to use. We will develop a system that means salmon farms are providing Soil Association Certification with clear, consistent, real-time information to allow us better awareness of when issues are occurring. It will also give us information to better inform and further develop standards to improve welfare.
* Dr Natasha Boyland from Compassion in World Farming did not agree that there is evidence to support that a good life can be achieved in a commercially viable farmed setting.
Although the Scottish farmed salmon industry tends to source marine feed ingredients from certified responsible sources, we are concerned that it could compete with food supply chains and place too large a strain on fish stocks. This is a growing concern as the industry continues to expand.
Currently, organic producers are required to prioritise ingredients from sustainable sources, with trimming and waste products used in preference to whole fish. But, they can use whole fish caught from sustainably certified fisheries to feed farmed salmon if needed.
Within one year we will:
enhance our standards to give more attention to the hierarchy of feed used in the production stage (in net pens at sea) to prioritise marine ingredients that only come from trimmings or by-products.
We will work to support producers to make this transition. We will also work with organisations certifying fisheries and fish meal and fish oil production to address questions around supply.
The impact that salmon farming is having on other habitats is not well understood. But our research has led us to conclude that we need to apply the precautionary principle more rigorously to protect marine environments.
It is the role of Scottish Government to set the legislative and regulatory framework for fish farming, and to ensure that the consenting and leasing process considers each site for suitability and its impact on the environment. We believe that neither the regulatory process nor Soil Association standards are sufficiently reducing risks to sensitive habitats, when applying the precautionary principle.
Within one year we will:
set Soil Association standards that ensure organic sites are not located in areas where they are likely to negatively impact sensitive habitats, such as wild salmon runs or the UK’s maerl habitats. We want our standards to protect all marine environments, but these specific habitats are globally important.
What we need from Scottish Government to support and enable these changes
In addition to the five points above, all of which are within our control, we will continue to engage with the Scottish Government to make progress in the following areas.
Spatial planning: Ensuring fish farms are appropriately sited, through the consenting process, as well as national and regional marine planning, and to facilitate the relocation of sites where necessary for fish welfare and environmental reasons.
Mortalities: Setting out a clear plan of action for sites found to have 'persistent high mortality' levels. This will be informed by the Scottish Government report to the Rural Affairs and Islands Committee from September 2025, which analysed data related to mortalities.
Sea lice data: Reporting of all sea lice species data, more regularly, and enhanced mechanisms to share data with other salmon farmers to inform preventative actions.
Animal welfare: Introducing additional regulations and guidance under the Animal Health and Welfare (Scotland) Act 2006 to set specific baseline standards for the welfare of farmed fish. For example, putting the Code of Good Practice for Finfish Aquaculture on a statutory footing. This should also include regulatory standards on sea lice. Action from government is essential because any farm that is experiencing high levels of sea lice presents a risk to other nearby salmon farms, and indeed the wider environment.
Next steps for Soil Association’s organic salmon standards
Most of the changes we want to see in the next year are based around developing our own standards and refining our data and reporting processes. We will work closely with the industry to build confidence and develop meaningful changes that can have the impact we are seeking to achieve.
Our standards are under review throughout 2025 with input from an expert Aquaculture Task & Finish Group appointed with representatives with expertise in the aquaculture sector, welfare and environmental NGOs, and academia. A public consultation on any changes is planned for Winter 25/26. Any changes to standards are planned to be introduced in 2026.
We will also engage closely with Scottish Government and authorities who play a vital role in setting an enabling policy environment to support the changes highlighted in the tests we have set.
The Soil Association will assess whether sufficient progress has been made against the tests outlined above in Summer 2026.
Members of the Task & Finish Group
Ben Dent - Chair, SA Standards Board / Independent
Dawn Purchase - Aquaculture lead, Marine Conservation Society
Michelle Johnson - Technical Manager, Cooke Aquaculture Scotland
Kate Stronach - Sustainability and Compliance Manager, Mowi Scotland
Richard Newton - Lecturer in Resilient Food Systems, Stirling University
Jocelyn Rose - Former Aquaculture Inspector, Independent
Phil Brooke - Research and Education Manager, Compassion in World Farming
Sean Black - Senior Scientific Officer, Aquaculture, RSPCA
Andrew Davie - Head of Aquaculture, Aquascot / SA Standards Board
Mike Read - Standards Consultant, Independent
Fiona McAuley - Quality and Assurance Manager, Salmon Scotland
More information
The full evidence pack detailing the analysis and research in our review is available on request by emailing: standards@soilassociation.org
