NFFO Criticises Commission Proposal for New Regulations on Illegal, Unregulated and Unrecorded (IUU) Fishing
Aside from the fact that NFFO members are systematically disadvantaged through distorted competition on the markets because an estimated 10% - 15% of the EU’s fish trade is based on IUU fish, the NFFO is seriously concerned that the Commissions new proposals on IUU fishing would impose costs and regulatory burdens on law-abiding fishermen, without reducing the amount of IUU fish in Europe.
The Commission is again hurtling towards legislation that will not deliver its objectives, whilst creating disadvantages for legitimate businesses whose activities are already transparent and legal.
The Commission’s proposals, which consist of a blanket certification scheme for imports, measures against nationals involved in IUU fishing (including financial measures), measures against transhipment at sea, a black list for EU member states that fail to tackle IUU fish and alerts through an information exchange to identify IUU fish, fail in the following ways:
- The proposed blanket certification scheme for imports places the onus on the importer to demonstrate a chain of custody back to where the fish was taken from the water - but in many cases the importer may not have information about all the links in the supply chain and any batch of fish may include components from many different sources. A certification system with checks at every stage is a purely theoretical idea and a practical nightmare.
- The assumption is that because some transhipments are illegal, all transhipments should be prohibited. This ignores the practical and commercial realities which mean necessitate transhipment at times.
- Multi-processed, multi-source, large batches of fish do not lend themselves to certification at individual unit level. Even identifying a potential certifying authority, or at least ones that have the resources to make this legislation work, is not without problems.
- There is little thought given to how developing countries will be able to implement this legislation and there is an assumption that the European system would translate well in Sub-Saharan Africa, for example, where conditions are very different.
- The draft Regulation is ambiguous and gives scope for a wide range of interpretations - it is not clear whether the Commission wants a strict, or more liberal system.
The NFFO is lobbying the Commission on the following points:
- Allow adequate time for consultation during the policy design process, particularly with developing countries.
- Recognise the inherent flexibility and fluidity of fisheries.
- Base any new regulations on good governance, existing legislation and a targeted, risk based approach which uses strategic alliances between authorities and businesses which are already operating legally.
- Potentially, the best option is to focus on certification of the process which reduces IUU fishing, rather than certification of batches of caught fish.
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