- The Consumer Council (the Council) is pleased to submit its views with respect to the consultation paper issued by the Agriculture, Fisheries and Conservation Department (AFCD) on the updating of Hong Kong Biodiversity Strategy and Action Plan (BSAP).
The Council’s Overall Stance
- Echoing its position in the submission[1] to the Legislative Council Panel on Environmental Affairs regarding the formulation of the first BSAP in 2016, the Council welcomes the proposed updates to the BSAP to strengthen biodiversity conservation and sustainable development in Hong Kong.
- Over the years, the Council has been consistently advocating for sustainable consumption (SC) and empowering consumers to make biodiversity-conscious choices. For instance, the Council has conducted surveys which highlight the presence of excessive levels of substances harmful to biodiversity like pesticides and genetically modified residues, raising consumer awareness to incorporate biodiversity considerations into their daily consumption decisions. Against this backdrop, the Council puts forward its suggestions regarding the possible actions in the BSAP that concern consumer interests.
Strengthening Public Awareness
- Overall speaking, the Council deems it important to raise public awareness and broaden community involvement in biodiversity conservation, and suggests that further actions to strengthen public awareness should be given due consideration in the BSAP. As reference, the Council has conducted longitudinal studies, repeating every 5 years since 2016[2] to report whether consumers’ SC behaviours have progressively improved over time. Its second in-depth SC report in 2021[3], titled Embracing Sustainable Consumption for a Happy Life, found that there was a slight decline in consumer consciousness of the relationship between SC and biodiversity in this five-year trend. Specifically, the proportion of respondents who associated SC with sustainable use of biological resources dropped from 63% to 57%, and those linked SC to the protection of endangered species fell from 62% to 58%. Despite so, slightly more consumers were concerned whether pollution from the production of the product they buy causes ecosystem damage (from 67% to 69%). Generally, the result indicated that consumer awareness on biodiversity remained limited, highlighting the need to enhance consumer awareness on biodiversity conservation at consumption level.
Promoting Biodiversity-Friendly Practices
- The Council supports the objective to promote biodiversity-friendly practices across all sectors of society (under Area 2 “Deepening Mainstreaming” of the BSAP). To achieve this goal, the Council further suggests some possible actions as below, to empower consumers to make informed and biodiversity-conscious choices.
(i) Adoption of Biodiversity Conservation Criteria in Eco-Labelling Schemes
- The Council notes that there are a variety of eco-labels currently available in the local market, where some may touch on environmental attributes such as energy efficiency, carbon emissions or waste reduction. While these eco-labels play a significant role in promoting SC, they seldom account for the biodiversity impacts of products on biological resources and ecosystems (e.g., sustainably sourced, organic, cruelty-free).
- To mitigate this gap, the Council advocates the strengthening of eco-labelling schemes, as a possible action of the BASP, by incorporating biodiversity-specific criteria, such as the impact of products on ecosystem and endangered species throughout the product lifecycle, from raw materials sourcing to production, consumption, and disposal, etc., to provide credible and transparent labelling schemes for consumers to make informed choices that support biodiversity conservation.
(ii) Measurement of Biodiversity Footprints of Consumer Products
- To align with the global targets set out in the Kunming-Montreal Global Biodiversity Framework, which call for the integration of biodiversity values into policies, regulations and consumption practices, the Council recommends that the BSAP may include measures to encourage and facilitate the measurement of biodiversity footprints associated with consumer products, to offer a practical and data-driven approach to understand and mitigate the biodiversity impacts of consumption.
- For example, the promotion of certified eco-labelling schemes that provide consumers with credible information on the biodiversity footprint of certain products, such as the Forest Stewardship Council, which promotes responsible forest management, and the Marine Stewardship Council, which certifies sustainable fisheries, thus facilitate consumers to make informed choices and contribute to their transition towards a more sustainable lifestyle.
(iii) Enhancing Consumer Access to Biodiversity-Friendly Products
- According to the United Nations Conference on Trade and Development (UNCTAD), global demand for natural-based products has surged from US$1.9 billion in 1980 to over US$141 billion in 2018[4], as consumers were increasingly demanding for more sustainable and ethically sourced products. In regard to the potential of biodiversity-friendly products, the Council opines that the BSAP should include measures to facilitate the development and promotion of biodiversity-friendly products across society, thus enhancing consumer access to biodiversity-friendly products.
- Meanwhile, the Council recommends the BSAP to incorporate biodiversity-related criteria into public procurement policies (if have not done so), urging the Government to play a proactive role in leading businesses by reducing demand for biodiversity-intensive goods and promoting more responsible supply chains. The Council also considers it essential in fostering collaboration between the Government and the business sector to develop supportive frameworks that encourage biodiversity-friendly procurement practices across the economy.
(iv) Addressing Biodiversity Impact of Imported Goods
- Besides, as a city being heavily reliant on imported consumer goods and serving as a key trading pillar in global supply chains, many of which are associated with significant biodiversity impacts, particularly agricultural, marine and hardwood products. Inappropriate extraction and production of such goods often involves deforestation, overfishing and unsustainable land use practices, which contribute to significant biodiversity loss in source countries.
- It is also noted that the biodiversity impacts of imported goods extend beyond production along the global supply chains. For instance, transportation emissions contribute to climate change, which in turn exacerbates biodiversity loss through rising temperatures and ecosystem disruption, while disposal of non-biodegradable waste, particularly plastics and electronic waste, poses a growing threat to marine and terrestrial biodiversity.
- The Council is of the view that the biodiversity impact of the consumption of imported goods must be more explicitly addressed in the BSAP, to raise consumer awareness of the biodiversity implications associated with consumption of imported goods, and foster the development of a more sustainable marketplace.
(v) Combating Greenwashing Claims
- The Council expresses concern about the increasing prevalence of greenwashing, where businesses make misleading or exaggerated environmental claims to promote their products. Such practices not only mislead consumers but also undermine genuine efforts to promote sustainability and biodiversity conservation. The Council therefore recommends the BSAP to incorporate actions to strengthen oversight of environmental and biodiversity claims. In parallel, public education should be enhanced to help consumers identify credible environmental information and certifications.
(vi) Enhancing Disclosures
- The Council is pleased to note that businesses enhance their Environmental, Social and Governance (ESG) disclosures, particularly with respect to biodiversity-related practices and impacts. While enhancing transparency is important, the Council considers making accurate and quality disclosure in these areas are also crucial in helping consumers better understand the biodiversity footprint of products and services, thereby facilitating more informed and biodiversity-conscious consumption choices.
(vii) Promoting Wildlife Gardening in Communities
- The Council supports the possible actions in the BSAP to promote wildlife gardening initiatives, such as setting up pollinator gardens and nest boxes in communities, for enhancing urban biodiversity and fostering public engagement. However, the Council notes that poor management of wildlife gardening may inadvertently disrupt local ecosystems. To ensure that wildlife gardening contributes positively to biodiversity conservation, the Council recommends the BSAP to include adoption of clear guidelines and best practices for responsible design, implementation, and maintenance of wildlife gardening projects.
Strengthening Cross-border and International Cooperation
- The Council agrees with the objective to foster cooperation internationally and within the Guangdong-Hong Kong-Macao Greater Bay Area (under Area 4 “Collaborative Partnering”). Below are some further suggestions for consideration.
(i) Addressing the Potential Difference between Regulatory Standards
- International cooperation plays a vital role in promoting biodiversity conservation and sustainable development. However, the Council recognises that differences between regulatory standards in different jurisdictions present potential challenges during cross-border collaboration. In this regard, the BSAP may need to address the potential barriers during collaboration and to explore an effective mechanism to facilitate effort and knowledge exchange for enhancing biodiversity conservation and sustainable development.
(ii) Monitoring Wildlife Trading
- Hong Kong remains a significant hub for the trade in wildlife and wildlife-derived products, some are even sourced from endangered or vulnerable species[5]. Specifically, the demand for exotic pets, traditional medicines, and luxury items has been linked to population declines in numerous species and the disruption of ecology. While much of this trade is illegal and regulated under the Protection of Endangered Species of Animals and Plants Ordinance (Cap. 586) and the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES[6]), the Council considers it essential for the BSAP to include actions to address the biodiversity impacts and risks associated with wildlife trading.
- The Council also believes that greater transparency and traceability in wildlife supply chains are necessary, while consumers should be equipped with clear, accessible information to avoid inadvertently supporting practices that contribute to biodiversity loss.
(iii) Promoting Eco-tourism
- With the Government promoting eco-tourism and the development of two eco-tourism nodes in Tsim Bei Tsui and Pak Nai, such initiatives can serve as an effective means of enhancing public awareness on biodiversity conservation. However, the Council is of view that eco-tourism activities may also have unintended biodiversity impacts consequences if not properly managed, as increased human presence in sensitive habitats can lead to disturbances in wildlife behaviour, habitat degradation, and the introduction of invasive species.
- To mitigate these risks, the Council recommends the BSAP to incorporate principles for responsible planning and management of eco-tourism. A balanced approach is also essential to ensure eco-tourism contributes positively to public education and consumer awareness without compromising the sustainability of the ecosystem.
Conclusion
- In conclusion, the Council considers the update of the BSAP an essential step in promoting biodiversity conservation and sustainable development in Hong Kong. The Council will continue its efforts in advocating SC, such as undertaking studies and conducting product testing and surveys, as well as organising seminars and educational activities, thereby empowering consumers to make informed choices that contribute to biodiversity conservation in Hong Kong.
