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EU Market Access & Eco-Labellingfor Fishery and Aquaculture Products.sippo.ch
l EU Market Access & Eco-Labelling2
Publisher
Osec
Stampfenbachstrasse 85, P.O. Box 2407, CH-8021 Zurich
Direct phone +41 44 365 52 68 / Fax +41 44 365 52 21
Author
Francisco Blaha
Layout and design
Beate Rüttiger
Cover photo
Fishing Vessel Orion I - Argentina (foto de M. Capizano)
© M. Capizzano
Photos and illustrations
© F. Blaha, except page 39 © Dirkje Bakker
The author is an independent fisheries specialist based in New
Zealand. He has been involved with commercial fishing and
research since the mid-1980s. He works in institutional strengthen-
ing, capacity building and applied research for the private sector
and international development organisations in more than 35
countries worldwide.
www.franciscoblaha.com
For more information:
Constantin Kostyal
Project Manager Food Programme
Osec
SIPPO Swiss Import Promotion Programme
Stampfenbachstrasse 85, P.O. Box 2407, CH-8021 Zurich
Direct phone +41 44 365 52 68 / Fax +41 44 365 52 21
[email protected] / www.osec.ch
Publisher.
EU Market Access & Eco-Labelling l 3
Introduction.
This publication provides a guideline to the regulatory require-
ments for exporting of seafood products to the European Union.
It describes the EU system of official assurances, the main regula-
tions, requirements for the Competent Authorities and opera-
tors along the value chain with regards to health and non-IUU
catch certification. It also includes a chapter on private eco-label
schemes and their role in the EU seafood market.
This bulletin was prepared by Francisco Blaha, SIPPO
Consultant, and reviewed by Constan tin Kostyal, Project Manager
Food Programme, SIPPO Swiss Import Promotion Programme.
Disclaimer
SIPPO, the Swiss Import Promotion Programme, is a mandate
of the State Secretariat for Economic Affairs, SECO, within the
framework of its economic development cooperation. It is carried
out by Osec, the official Swiss foreign trade promotion agency.
The programme helps small and medium enterprises (SMEs) in
developing and transition countries to gain access to the Swiss
and European markets by providing information, training courses
and other matchmaking services. SIPPO also assists importers
from Switzerland and the European Union with finding suitable
partners and high-quality products from selected developing and
transition countries.
The programme has five main goals:
• To inform the Swiss and European import economy about new
market sources
• To strengthen trade institutions and business sector associations
in the trade promotion process
• To increase the competitiveness of SMEs in selected partner
countries
• To develop the manufacturing and exporting skills of SMEs in
selected partner countries
• To establish qualified trade contacts between SMEs from
emerging markets and markets in transition and the Swiss and
European import economy
l EU Market Access & Eco-Labelling4
and development cooperation with poorer countries, trade-related
cooperation, including social and environmental aspects, takes on
a major importance. The overall aim is to boost trade as a trigger
for growth and sustainable development.
Specifically, SECO runs programmes to promote imports to
Switzerland and the rest of Europe from goods, including fish,
produced in developing countries. In this endeavour, SECO has
set up the Swiss Import Promotion Programme SIPPO which
works directly with enterprises, providing them with counseling
and market information services and directly fostering their access
to markets via trade fairs.
The present publication on EU Market Access for fish and fish
products is an excellent example of SIPPO’s interventions aimed
at fostering access to the European market through information
dissemination. It provides the reader with tangible and lively ad-
vice which should lead to market penetration in Europe. I wish you
a pleasant reading!
Hans-Peter Egler
Head of Trade Promotion, Economic Cooperation and Develop-
ment, State Secretariat for Economic Affairs SECO
Foreword.
The EU market is a wonderful place to be for any producer willing
to sell its products, with its over 500 million inhabitants, all among
the world‘s wealthiest. But the EU market is also a very challen-
ging place to access, with thousands of enterprises competing
for share, on the one hand, and strict quality standards set by a
selective consumer base.
The above is especially true with respect to fish and fishery prod-
ucts. On the one hand, the EU is the largest single fish market,
with imports amounting to 15 billion EURO in 2009, on a quickly
rising trend. On the other hand, although it offers generous tariff
concessions to developing countries (and tariff freedom to least
developed countries), the EU also puts high demands on prod-
ucts, regarding product quality, fishing, processing, etc. Likewise,
Switzerland provides a promising market, although on a much
smaller footing: each of its 7 million inhabitants consumes (only)
10 kg of fish products every year (EU: 22 kg). By definition (Swit-
zerland is a land-locked country), fish products come from abroad,
mostly the EU, making Switzerland the 1st market worldwide for
EU fish products. So, entering the EU market enables accessing
an even wider market, including Switzerland.
It is a general rule that exports constitute an essential source of
revenues for all countries. The State Secretariat for Economic
Affairs SECO has recognized the key role of trade for developing
countries. Among the instruments it deploys within its economic
EU Market Access & Eco-Labelling l 5
Contents.
1 About this booklet. .......................................... 6
1.1 Guidance table ............................................................ 6
2 Is it complicated to export to the EU? ..... 8
3 Health certification. ......................................... 9
3.1 The basics ................................................................... 9
3.2 The health certificate ................................................... 9
3.2.1 The Food and Veterinary Office ................................. 10
3.3 Requirements for food business operators ................ 10
3.3.1 Approved Establishments .......................................... 10
3.3.2 Conditions of operators along the production chain .. 11
3.4 Requirements for all fishery products ........................ 12
3.4.1 Specific requirements for aquaculture products ........ 13
3.5 Official controls .......................................................... 14
3.5.1 Signing the certificate ................................................ 16
3.5.2 Certification and eligibility .......................................... 16
3.5.3 Traceability ................................................................. 17
3.5.4 Laboratories to be used for official controls ............... 17
3.6 Border Inspection Posts ............................................. 18
3.6.1 Rapid Alert System for Food and Feed ..................... 18
3.7 What about the regulations? ...................................... 18
3.7.1 Key regulations for fish and fishery products ............. 20
3.7.2 Key regulations for bivalve molluscs .......................... 21
4 IUU Regulation. ............................................... 22
4.1 The basics ................................................................. 22
4.1.1 What is IUU fishing? .................................................. 22
4.2 How does the catch certificate operate? ................... 24
4.2.1 Trade flows ................................................................. 25
5 The relationship between health and IUU certification. ............................................. 26
5.1 Comparative table ...................................................... 27
6 Eco-Labelling. .................................................. 30
6.1 The basics ................................................................. 30
6.2 Why are they becoming important for the EU market? ... 30
6.3 Coverage and certification ......................................... 30
6.4 Producers: costs and benefits ................................... 31
6.4.1 Price premium ........................................................... 32
6.4.2 Increased market share ............................................. 32
6.5 Consumers‘ perspective ............................................ 32
6.6 Eco-labels in developing countries ............................ 32
6.6.1 Weak economic imperatives ...................................... 33
6.6.2 Certification costs ...................................................... 33
6.6.3 Weak institutional capabilities .................................... 34
6.7 What about organic aquaculture? .............................. 35
6.7.1 EU regulatory framework for organic products .......... 35
6.8 Which way to go for Eco-Labelling? ........................... 36
6.9 Key fisheries eco-labels available in the market ........ 37
6.9.1 Marine Stewardship Council ...................................... 38
6.9.2 Friend of the Sea (fisheries) ...................................... 38
6.9.3 KRAV (fisheries) ........................................................ 39
6.9.4 Naturland (fisheries) .................................................. 39
6.10 Key aquaculture eco-labels........................................ 40
6.10.1 Aquaculture Certification Council .............................. 40
6.10.2 Global GAP ................................................................ 41
6.10.3 Friend of the Sea (aquaculture) ................................. 41
6.10.4 Aquaculture Stewardship Council .............................. 42
6.10.5 Naturland (aquaculture) ............................................. 42
6.10.6 Bio Suisse .................................................................. 43
6.10.7 KRAV (aquaculture) ................................................... 43
7 Bibliography. ..................................................... 44
8 Endnotes. ............................................................ 46
9 Glossary. ............................................................. 47
l EU Market Access & Eco-Labelling6
Exporting seafood to the European Union (EU) is not an obli-
gation, and it requires an equal amount of effort by the govern-
ment authorities and the private sector of the exporting country.
Compliance and understanding of the required system of official
assurances is paramount in order to access the EU market.
Until recently, the requirements of the EU solely focused on
food safety/health certification. However, from 2010 onwards, a
“new” certification is required, with a focus on the area of Illegal,
Unreported and Unregulated fishing (IUU). These two “necessary
certifications”, while allowing market “access”, do not guarantee
market “success“ per se.
The positioning of your products in the EU market depends on
many more factors. Some are relatively obvious, such as quality,
price, presentation, market segmentation and reliability of supply.
However, over the last years, other “certifications” are increasingly
shaping the European seafood market landscape, and these relate
to ethical and environmental issues associated to the sourcing,
production and distribution of fish and fishery products. These
private certification initiatives, known as Eco-Labelling, are
1.1 Guidance table.
QQ Question? Yes/No/Uncertain Section
1 Is the EU a realistic market for your product? Y: go to Q 2N: stop hereUncertain: read section > 2
2 Are you aware of the general sanitary requirements policy for importing seafood and aquaculter products?
Y: go to Q 3N: read section > 3
3 Is the producing country authorised for the export of seafood to the EU from a health certification aspect?
Y: go to Q 4N: stop hereUncertain: read section > 3.1
4 Is the producer approved for exporting to the EU? Y: go to Q 5N: stop hereUncertain: read section > 3.3
5 Are you interested in the basics for the regulatory products requirements? Y: read section >N: go to Q 6
3.4
“desirable” for your product. They do not have regulatory status,
but can under certain circumstances facilitate the establishment of
market presence once access conditions have been fulfilled.
As this publication focuses on EU market access, only some
European-operated or EU market-oriented standards and certifi-
cation programmes with strong market presence in the EU have
been selected for identification. This is neither an exhaustive list,
nor an endorsement of the schemes identified.
It is the aim of this publication to help potential and present
exporters understand, on one side, the basics of the “necessary”
market access certifications and, on the other, some key aspects
of the “desirable” ones. It is strongly recommended that the reader
follows up with the references provided, and does research on the
topics that are not covered by this publication.
To facilitate the use of the booklet, the following table will help
identify the appropriate sections according to the reader’s interest
and needs.
1. About this booklet.
EU Market Access & Eco-Labelling l 7
6 Are you interested in the basics of the required official controls? Y: read section >N: go to Q 7
3.5
7 Are you interested in the interrelations and references of the key EU regulations regarding sanitary conditions?
Y: read section >N: go to Q 8
3.6
8 Are you aware of the general IUU requirements policy for seafood and aquaculture products imports?
Y: go to Q 9N: read section > 4
9 Do the requirements of the IUU catch certification apply to the seafood products to be traded?
Y: go to Q 10N: go to Q 13Uncertain: read section > 4.1
10 Are you interested in the basics of what constitutes IUU fishing? Y: read section >N: go to Q 11
4.2
11 Are you interested in the basics of catch certifications and trade flow requirements? Y: read section >N: go to Q 12
4.3
12 Are you interested in the basics of the interrelations and differences between health and IUU certificates?
Y: read section >N: go to Q 13
5
13 Are eco-labels an area of interest for you or a commercial requirement for the fishery and aquaculture products concerned?
Y: read sections >N: go to Q 14
6, 6.1,6.2
14 Are you interested in what eco-labels cover and inthe certification process of eco-labels?
Y: read section >N: go to Q 15
6.3
15 Are you interested in the costs and benefits of eco-labels for producers? Y: read section >N: go to Q 16
6.4, 6.5
16 Are you interested in the challenges facing Eco-Labelling in developing countries? Y: read section >N: go to Q 17
6.6
17 Are you interested in organic aquaculture certification? Y: read section >N: go to Q 18
6.7
18 Do you need information on how to choose an eco-label scheme? Y: read section >N: go to Q 19
6.8
19 Are you interested in the key fishery eco-labels in the EU market? Y: read section >N: go to Q 20
6.9
20 Are you interested in the key aquaculture ecolabels in the EU market? Y: read section >N: go to Q 21
6.10
21 Are you interested in a selection of references and suggested readings for all these topics?
Y: read section >N: stop here
7
l EU Market Access & Eco-Labelling8
The European Union (EU) is the biggest single market for fish and
fishery products worldwide, as a consequence of an increased
consumption per capita and its enlargement to 27 member states.
While different EU member countries1 import different amounts,
all of them share the same market requirements for seafood
products. These requirements are also shared by Iceland, Norway,
Switzerland and Liechtenstein, as they are part of the European
Free Trade Association (EFTA). The EU bases its seafood import
on government-to-government assurances, without the inter-
vention of any private type certification, or standards such as ISO.
Therefore, the efforts of producers are conditioned to the good
performance of whichever authority (the competent authority –
CA) in the exporting country assumes the responsibility of giving
the EU the official guarantees it requires regarding compliance
and conformity to all the requirements of its legislation.
Since 2010 the EU does not only require food safety/health certifi-
cation but also catch certification that guarantees that the product
does not originate from Illegal, Unreported and Unregulated (IUU)
fishing activities.
Both certifications will have a major impact on exporters, as the
EU makes its legislation based on the realities of its members and
not of those of third countries.
Many developing countries have found that compliance with these
obligations is complex, costly and requires a level of mobilisation
of resources that is generally not available to them. Compliance
and understanding of the required system of official assurances is
paramount to accessing the EU market, and it requires an equal
amount of effort by the government authorities and the private
sector of the exporting countries.
2. Is it complicated to export to the EU?
At present, the EU imports around 60% of its traded seafood
from third countries, and even though the idea of accessing many
wealthy customers is very tempting, as a producer, your decision
to export to the EU has to be based on the market access situa-
tion of your country and a cost/benefit analysis for your operation.
If your potential incomes justify the expenses you may incur, in
terms of infrastructure upgrades, knowledge and capacity building:
then go ahead. There will be, however, ongoing costs involved in
maintaining the access system that should be taken into account.
EU Market Access & Eco-Labelling l 9
3.1 The basics.
There are currently 100 countries authorised for exporting fish
and fishery products to the EU, of which 15 have authorisation for
live bivalve molluscs.2 The European Commission’s Directorate
General for Health and Consumer Protection (DG SANCO) is
responsible for food safety in the EU. The import rules for fishery
products seek to guarantee that all imports fulfil the same high
standards as products from the EU Member States, with respect
to hygiene and consumer safety and, if relevant, also to the animal
health status.
Although cataloguing all what the EU requirements to accept
seafood from a non-member country is beyond the scope of this
publication3, it is safe to say that the exporting country regulatory
system should correspond (or be equal) to what is established
for the EU Member Countries by Regulations (EC) No. 178/2002,
(EC) No. 882/2004, and (EC) No. 854/2004. The EU requires that
the official guarantees in terms of compliance of seafood exports
from a third country4 should be given by a competent authority
(CA) which means the “central authority of a State competent for
the organisation of official control”5 in terms of food safety, prod-
uction standards and others, as specified for seafood in the relevant
EU legislation. It emphasises that: “The competent authorities for
performing official controls should meet a number of operational
criteria so as to ensure their impartiality and effectiveness”.6
The CA has to comply with a lengthy series of requirements, but
roughly summarised, the CA needs to assure compliance with
three types of obligations:
• Obligations of resources: i.e. instruments of production, condi-
tions of handling/processing, Hazard Analysis Critical Control
Point (HACCP) and prerequisite programmes, traceability, etc.
• Obligations of results: i.e. safety levels of the products
(e.g. histamine, contaminants, microbiological levels), etc.
• Obligations of control: i.e. regulatory verification effectively imple-
mented by the CA, data storage and management, administra-
tive procedures, legal support, strict control of product certifica-
tion, etc.
3. Health certification.
Once the equivalency is established and the country “authorised”,
exports can then access the market as long as the lots are ac-
companied by a health certificate emitted by the CA of the country
of origin.
3.2 The health certificate.
Seafood products exported to the EU must be accompanied by a
health certificate emitted by the CA of the country of origin.7 This
certificate is the official document between the exporting country
and the EU that provides the official guarantees required. As the
format and content of the certificate are to be respected, its Public
Health Attestation is a great tool to understand the requirements.
“I, the undersigned, declare that I am aware of the relevant provi-
sions of Regulations (EC) No. 178/2002, (EC) No. 852/2004, (EC)
No. 853/2004 and (EC) No. 854/2004 and certify that the fishery
products described above were produced in accordance with
those requirements, in particular that they:
• come from (an) establishment(s) implementing a programme
based on the HACCP principles in accordance with Regulations
(EC) No. 852/2004;
• have been caught and handled on board vessels, landed,
handled and where appropriate prepared, processed, frozen
and thawed hygienically in compliance with the requirements
laid down in Section VIII, Chapters I to IV of Annex III to Regula-
tion (EC) No. 853/2004;
• satisfy the health standards laid down in Section VIII, Chapter
V of Annex III to Regulation (EC) No. 853/2004 and the criteria
laid down in Regulation (EC) No. 2073/2005 on microbiological
criteria for foodstuffs;
• have been packaged, stored and transported in compliance with
Section VIII, Chapters VI to VIII of Annex III to Regulation (EC)
No. 853/2004;
• have been marked in accordance with Section I of Annex II to
Regulation (EC) No. 853/2004;
• the guarantees covering live animals and products thereof, if
l EU Market Access & Eco-Labelling10
from aquaculture origin, provided by the residue plans submitted
in accordance with Directive 96/23/EC, and in particular Article
29 thereof, are fulfilled;
• have satisfactorily undergone the official controls laid down in
Annex III to Regulation (EC) No. 854/2004.”
The first part of the attestation implies the need of a certifier
whose duty relies on the body responsible for official guarantees,
which, as mentioned before, is the role of the CA.
3.2.1 The Food and Veterinary Office
As part of the market access conditions, EU experts from the
Food and Veterinary Office (FVO) assess the equivalency of an
exporting country’s seafood safety regime and ascertains the
conditions required to be met for seafood from that country.
The FVO determines the status of compliance of the CA in terms
of the required official guarantees with inspection missions, and
they are the basis for establishing confidence between the EU
Commission and the CA of the exporting country.
All inspection visit reports are publicly available and published on
the FVO website.8 They contain findings, references and (if neces-
sary) recommendations to facilitate compliance.
Hence, seafood can be exported to the EU only from:
• Authorised countries
• Approved vessels and establishments (e.g. processing plants,
freezer or factory)
• Vessels, cool stores – generally called Food Business Operators
• Approved aquaculture establishments and areas
3.3 Requirements for food business operators.
Assuming that the country is on the list of approved countries, the
CA is then responsible to approve food business operators (FBOs)
to export to the EU. As exporting to the EU is not compulsory, it is
the establishment’s decision to seek “approval” in terms of the EU
requirements, beyond the domestic ones. The CA’s assessment of
the FBO’s compliance with the EU standards defines the approval
(or not), by assigning them a unique identification code.
3.3.1 Approved establishments
All establishments in the capture or aquaculture production chain
(hatcheries, farms, vessels, plants, cool stores, etc.) must be
approved by the CA regarding the EU requirements, in order for
their product to be considered “eligible” for the EU. The list of
approved establishments in the progression from “raw material
to product” is maintained by the CA and represents all the FBOs
in the production chain that are allowed to provide to companies
that export directly to the EU. The establishments at the end of the
chain (those that export directly to the EU) are to be included on a
list of establishments authorised to receive a health certificate for
their products. This list can include vessels, plants or cool stores
as long as they export directly to the EU (or to another third country
for further processing and then to the EU).
These establishments are given a unique identification code,
usually known as the “EU number”. The CA sends the EC a list
of authorised establishments9, with the guarantee that they have
been inspected and deemed to comply with the specific hygi-
ene rules, which correspond to the type of product processed.
Therefore, any changes or updates in this list need to be com-
municated to the EC immediately. The approval and listing is not
a “one off” event, it is based upon continuous compliance by the
establishments. If the level of compliance becomes so low that the
CA is unable to provide the required official guarantees, then the
establishment can be suspended or removed from the list. When
this happens, the establishment loses the right to export to the
EU and/or provide raw materials and products to “listed” establish-
ments.
EU Market Access & Eco-Labelling l 11
3.3.1.1 Requirements for the establishments
As discussed, the CA certifies compliance to a series of require-
ments, which are listed in the public health attestation of the
certificate. The first requirement is that:
• “(the products) come from (an) establishment(s) implementing a
programme based on the HACCP principles in accordance with
Regulation (EC) No. 852/2004”
This booklet will not expand on HACCP any further as there is
enough information on the subject worldwide. In general, at this
stage no food exporter should be processing food if they do not
have a fully functional HACCP plan.
3.3.2 Conditions of operators along the production chain
As mentioned, all the operators in the value chain need to be in
compliance and under the control of the CA. These requirements
are evident in the following statement:
• “(the products) have been caught and handled on board vessels,
landed, handled and where appropriate prepared, processed,
frozen and thawed, hygienically in compliance with the require-
ments laid down in Section VIII, Chapters I to IV of Annex III to
Regulation (EC) No. 853/2004”
The statement also provides the specific set of references in the
legislation that apply directly to operators, namely Section VIII,
Chapters I to IV of Annex III to Regulation (EC) No. 853/2004.
These chapters define the key requirements in terms of hygiene.
They are not more difficult to comply with than any other type
of requirements such as those directly based on Codex Ali-
mentarius.10
Staff at a tuna cannery in the Philippines
l EU Market Access & Eco-Labelling12
3.4 Requirements for all fisheryproducts.
The particular requirements for the products are to be found in the
following statements:
• “satisfy the health standards laid down in Section VIII, Chapter
V of Annex III to Regulation (EC) No. 853/2004 and the criteria
laid down in Regulation (EC) No. 2073/2005 on microbiological
criteria for foodstuffs”
This particular paragraph refers to the health standards for most
fishery products such as organoleptical evaluation, histamine
levels, parasites, toxins and so on. It also refers to microbiological
standards, which are quite minimal and only apply to ready-to-eat
products.
• “have been packaged, stored and transported in compliance
with Section VIII, Chapters VI to VIII of Annex III to Regulation
(EC) No. 853/2004”
In this case, it refers to some very simple principles in terms
of packaging and storage, to avoid them becoming a source of
contamination, and temperature controls (e.g. melting ice for fresh
products, – 18°C for frozen products and – 9°C for brine frozen
fish to be canned), and how these same principles need to be
maintained during transport.
• “have been marked in accordance with Section I of Annex II to
Regulation (EC) No. 853/2004”
These identification-marking requirements are very basic and
refer mostly to the type of product and establishment of origin
identification.
Floating tilapia cage, Betania lake in Colombia
EU Market Access & Eco-Labelling l 13
3.4.1 Specific requirements for aquaculture products
Besides all the requirements listed so far, the following state-
ment applies specifically to products originated from aquaculture
practices.
• “the guarantees covering live animals and products thereof, if
from aquaculture origin, provided by the residue plans submitted
in accordance with Directive 96/23/EC, and in particular Article
29 thereof, are fulfilled”
Countries wishing to export aquaculture products to the EU need
a particular approval that is given upon compliance with veterinary
residue monitoring requirements as outlined in Articles 29 and 30
of Council Directive 96/23/EC.
The Directive states the need of submitting a plan setting out
the guarantees that it offers with regard to the monitoring of
the groups of residues and substances referred to in Annex I of
Council Directive 96/23/EC. The residue-monitoring programme
is submitted by the CA of the country of origin to the EC for initial
approval and needs to be presented annually for evaluation and
renewal. It should be noted that a favourable evaluation is based
on the guarantees received on paper. If a subsequent inspection
carried out by the FVO to assess the implementation of residues
and veterinary medicines controls demonstrates that the paper
guarantees cannot be relied upon, the status of the third country
on the list could be revised.
Animal health issues.11
As of August 2008, Directive 2006/88/EC of 24 October
2006 on animal health requirements for aquaculture
animals, and products thereof, and on the prevention and
control of certain diseases in aquatic animals, became
effective. This directive establishes the need of a recog-
nised CA that should perform its functions and duties in
accordance with the general principles laid down for food
safety, in terms of animal health of aquaculture species and
management of infectious or contagious aquatic animal
diseases in its territory, particularly the notifiable diseases,
listed by the World Organisation for Animal Health (OIE).
This directive requires from third countries great capacity of
control, including among other obligations, zoning in terms
of diseases, registry of establishments, accreditation of
laboratories and several requirements. The scope of these
requirements applies to: live fish, their eggs and gametes
intended for aquaculture in the EU, and for raw materials
or products intended for further processing in the EU. How-
ever, they do not apply to aquaculture products intended
for retail. It is important to understand that the responsibility
of these requirements may or may not fall under the scope
of the CA for official controls in terms of food safety and
traceability.
For further information: http://ec.europa.eu/food/
animal/liveanimals/aquaculture/index_en.htm
l EU Market Access & Eco-Labelling14
3.5 Official controls.
Official controls are required under the following statement:
• “have satisfactorily undergone the official controls laid down in
Annex III Regulation (EC) No. 854/2004”
However, under this last paragraph, we should first focus on the
official controls done by the CA as per EC 854/2004.12
Some of the key requirements (but not the only ones) are that
official control activities are carried out:
• on a regular basis and with a frequency based on risk;
• without prior warning (as a general rule);
• at any stage of production, processing and distribution;
• to include imports/exports.
Official control activities on the production and placing on the
market of fishery products are aimed at assessing compliance by
the establishments, in particular:
a A regular check on the hygiene conditions of landing
and first sale;
b Inspections at regular intervals of vessels and establishments
on land, including fish auctions and wholesale markets, to
check, in particular:
(i) where appropriate, whether the conditions for approval are
still fulfilled;
(ii) whether the fishery products are handled correctly;
(iii) compliance with hygiene and temperature requirements;
(iv) the cleanliness of establishments, including vessels, their
facilities, equipment and staff hygiene; and
c Checks on storage and transport conditions.
In more practical terms, this implies that the establishments along
the value chain will be “inspected” or “verified” by the CA against,
for example, the requirements detailed the requirements detailed
as follows.13
In terms of documentation:
• General description of the company, facilities, products and
processes.
• The description of operations followed.
• The documented prerequisite programmes.
• The HACCP plan.
• The system to provide guarantees for the product traceability.
• The documented and formalised withdrawal recall procedures.
In terms of physical settings, operational conditions, control strate-
gies concerning the entire production process and the application
of all prerequisite programmes by the operator:
• The general hygiene conditions of building and surroundings.
• The water supply and water quality management system,
detailing the internal distribution net, treatment, if any, quality
monitoring plan and related records.
• Ice production, internal distribution and quality monitoring.
• The absence of cross-contamination/air current risks (layout and
infrastructure considerations).
• Personnel health and hygiene control (including training).
• Sanitary filtering of personnel arrangements, toilets and dressing
facilities.
• Facilities and equipment cleaning and sanitation plans (methods,
schedules, chemicals used and approvals).
• Raw materials’ acceptance criteria and controls (freshness,
temperature, transport, lot identification).
• Specifications for other inputs as ingredients, additives or
packaging.
• Waste disposal system.
EU Market Access & Eco-Labelling l 15
• Labelling system and lot codes, providing effective traceability.
• Pest control plan. Control of insects, rodents and other undesir-
able animals.
• Equipment and facilities preventive maintenance plan.
In terms of characteristics of the products, the official controls are
to include at least the following regulatory elements, as described
in the EC Directives:
• Random organoleptic checks must be carried out at all stages of
production, processing and distribution.
• When the organoleptic examination reveals any doubt as to the
freshness of the fishery products, samples may be subjected
to laboratory tests to determine the levels of total volatile basic
nitrogen (TVB-N) and trimethylamine nitrogen (TMA-N).
• Random testing for histamine is to be carried out to verify com-
pliance with the permitted levels laid down under Community
legislation.
• Monitoring arrangements are to be set up to control the levels
of residues and contaminants in accordance with Community
legislation.
• Where necessary, microbiological checks are to be performed in
accordance with the relevant rules and criteria laid down under
Community legislation.
• Random testing is to take place to verify compliance with Com-
munity legislation on parasites.
• Checks are to take place to ensure that the following fishery
products are not placed on the market:
- poisonous fish of the following families: Tetraodontidae, Molidae,
Diodontidae and Canthigasteridae;
- fishery products containing biotoxins such as Ciguatera or other
toxins dangerous to human health.14
l EU Market Access & Eco-Labelling16
3.5.1 Signing the certificate
The above-discussed issues are what the health certificate im-
plies. When the CA signs the health certificate, it becomes official
evidence that the establishments, operators, raw materials and
products in the value chain comply with the requirements as listed
in the public health attestations. Therefore, the health certificate
must provide an accurate description of the identity of the ap-
proved processor of the goods, the type of fish being shipped, the
quantity of product being shipped, and the final destination of the
goods.
3.5.2 Certification and eligibility
A very important criterion not really obvious on the certificate per
se, is the issue of eligibility of products and raw materials as a
consequence of official controls over the production chain and
traceability.
The nature of the official controls implies that all elements in the
production chain15 need to be approved by the CA. This criti-
cal issue has important ramifications, as the different stages of
production may be under different central or regional authorities.
In any case, the various “sub CAs”, and/or the Central CA need to
act as one in terms of the offering of official guarantees to the EU.
If a country has four different authorities dealing with the fisheries
production chain, this cannot be used as an excuse for noncom-
pliance, as mechanisms should be enacted for coordinated official
controls. Good coordination is fundamental in order for certifi-
cation to be meaningful, as the certification process should be
centralised, although the fishery operators and the CA’s inspection
activities tend to be geographically fragmented.
Riverside fish market, Colombia
EU Market Access & Eco-Labelling l 17
Good IT practices are increasingly the norm in terms of proving
traceability, inspection results and certification of food products. In
particular, the design and maintenance of proper database
structures enhancing the information sharing and integration be-
tween the CAs can be very important to provide some consistency
in the certification process. Whoever signs the certificate needs
to have the capacity to assure that the product certified has been
under officially controlled conditions in officially controlled estab-
lishments from origin to export. If the harvesting of raw materials
or any other production stages were performed in a non-compliant
or non-verified16 establishment, then that raw material or prod-
uct is not eligible for export to the EU, hence it cannot receive a
certificate. The fact alone that a product has been processed at
an establishment with an “EU number” does not guarantee its
eligibility to the EU market.
3.5.3 Traceability
The CA should verify the efficiency of a traceability system adopted
by an operator. The principle is “one step backwards, one step for-
wards”. The operator should be able to show from where and whom
does it come from, what is done with it and whom is it given to.
3.5.3.1 Separation and identification of non-EU eligible
products
If a company listed for the EU holds products that are not eligible
by origin (i.e. a non-approved vessel) or conditions (approved but
in non-compliance), then the operator must ensure the physical
separation of EU-eligible from ineligible seafood products for the
EU. Where any assumed EU-eligible seafood products cannot be
distinguished between ineligible seafood products, then the former
are deemed to be ineligible and must be dealt with accordingly.
3.5.3.2 Products with imported raw materials
Based on the principle of official controls, EU health certificates
for seafood products exported to the EU that are derived wholly or
partly from raw material products must:
• have originated from a third country eligible to export the animal
product to the EU;
• have been derived from foreign premises eligible to export to the
EU, (including vessels);
• be eligible to be exported to the EU.
A copy of the import certificate, or original export certificate, must
be available on request.
3.5.4 Laboratories to be used for official controls
For an analytical result to have “official” validity, it must come from
a laboratory accredited to ISO/IEC 17025 for those parameters
to be analysed. The standard specifies the general requirements
for the competence to carry out tests and/or calibrations; it covers
management and technical issues, and the key objective is to
assure the accuracy and quality of the results. The accreditation
is what allows the CA to “trust” the impartiality and accuracy of
the results, and as a result “approve” the laboratory for it results to
be considered “official”. As a consequence the status of “appro-
ved” can only be maintained as long as the laboratory holds the
accreditation.
These requirements apply equally to government and private
laboratories, in fact, private sector laboratories are increasingly
becoming more used worldwide for regulatory purposes.
l EU Market Access & Eco-Labelling18
3.6 Border Inspection Posts.
Imports of seafood from non-EU countries must enter the EU via
an EC-approved Border Inspection Post (BIP) under the authority
of an official veterinarian.
At the BIP, the the consignments are subject to three types of
checks:
• A documentary check: it is done systematically; it involves
checking the export certificate accompanying the seafood
consignments.
• An identity check: it is also done systematically; it involves
checking that the data on the export certificate are consistent
with the product, which has been imported.
• A physical check: it is done appropriately to the circumstances of
the consignment; it involves examining the product, it’s pack-
aging, the information on the label and the storage conditions.
The frequency and type of physical checks are determined for
each category of product on the basis of the intrinsic risk and
results of checks carried out previously on the same product of
the same origin, and it can include taking samples for laboratory
testing on a random basis or on the basis of past records. If the
consignment is found to be non-compliant with the EU legislation
for any reason, then the BIP notifies the non-compliance to the EU
through the internal notification system of the EU called the Rapid
Alert System for Food and Feed (RASFF). If the product exceeds
any regulatory levels or contains non-authorised substances, then
it is up to the exporter in the country of origin to decide to get the
product back or let it be destroyed.
3.6.1 Rapid Alert System for Food and Feed
The Rapid Alert System for Food and Feed (RASFF)18 is a tool
that the EU uses to enable the quick and effective exchange of
information between Member States and the Commission when
risks to human health are detected in the food and feed chain.
RASFF provides an around-the-clock-service to ensure that
urgent notifications are sent, received and responded to in the
shortest time possible.
The CE publishes a weekly summary of the notifications19 under
the RASFF system. When a notification pertains to imported
products, then the CA of the country of origin has to make a full
investigation and report back to the EU on their results and mea-
sures to avoid recurrences.
3.7 What about the regulations?
It is impossible to reference all legislation in one document, or all
the requirements in one simple list. There is no way to escape
reading regulations, and one has to be aware that they change
and get updated frequently.
The two following graphic representations resume the key regula-
tory instruments and their interconnections and can be used as a
base to understand the systems and to find the required references.
EU Market Access & Eco-Labelling l 19
Prawn trawler in Belize
l EU Market Access & Eco-Labelling20
3.7.1 Key regulations for fish and fishery products
EU Market Access & Eco-Labelling l 21
3.7.2 Key regulations for bivalve molluscs
l EU Market Access & Eco-Labelling22
4.1 The basics.
The so-called “EU IUU Regulation”20 is a legal instrument applying
to all vessels engaged in the commercial exploitation of fishery
resources in all maritime waters, and seeks to prevent, deter and
eliminate IUU fishing as much as they are linked to the EC, either
through trade to and from its territory or the involvement of EC
nationals in IUU fishing activities conducted under any flag.
It therefore applies to all types of trade of marine fishery products,
processed or not, originating from third country fishing vessels
and exported to the Community by any means of transport, and to
catches originating from Community fishing vessels to be expor-
ted to third countries.
In order to ensure that no products derived from IUU fishing
appear on the Community market or on markets supplied from the
Community, the Regulation seeks to ensure full traceability of all
marine fishery products traded by means of a catch certification
scheme.
The IUU Regulation also comprises provisions on port state con-
trol for third country fishing vessels, the identification of IUU EC
or third country vessels, non-cooperating third countries and EC
nationals involved in IUU fishing under any flag.
The provisions are complemented by a mutual assistance system
to facilitate exchange of information between the authorities in
third countries, EU Member States, the EC and a Community
Alert System, which is specifically designed to focus verification
activities towards situations at risk.
In this respect, the IUU Regulation is based on the responsibility
and commitments of third countries, and it is funded on the appli-
cable national and/or international conservation and management
measures; therefore, it does not introduce any new conservation
or management measures.
4. IUU Regulation.
4.1.1 What is IUU fishing?
It is not the intention of this section to define and discuss the
details of IUU fishing and its impact. However, under the scope of
the IUU Regulation, the concept covers:
• Infringements to rules on management and conservation of
fisheries resources in national and international waters;
• Fishing activities in high seas areas covered by a Regional
Fisheries Management
Organisation (RFMO) carried out by vessels without nationality or
registered under a flag state which is a non-contracting or non-
cooperating party to the RFMO and in a manner contravening the
rules issued by this organisation;
• Fishing activities carried out in high seas areas not covered by
an RFMO in a manner inconsistent with state responsibilities for
the conservation of fisheries resources under international law.
• Behaviours which shall be qualified as presumed IUU fishing
activities.
“Under the IUU Regulation, a fishing vessel is notably pre-
sumed to be engaged in IUU fishing activities if it is shown that
its operators have carried out activities in contravention with the
conservation and management measures applicable in the area
concerned, such as fishing without a valid licence, in a closed
area, beyond a closed depth or during a closed season, or by
using prohibited gear, as well as the failure to fulfil reporting
obligations, falsifying its identity, or obstructing the work of
inspectors.”
EU Market Access & Eco-Labelling l 23
The following figure illustrates some examples of vessels in opera-
tion that are involved in IUU fishing. Either they are not licensed to
fish in the territorial waters of the countries A and B or the RFMO,
or they are fishing in closed areas, or with prohibited gear, or
although they have a license, do not report their catches.
In very general terms, within a legal framework these are the
questions that need to be answered to establish whether fish is
legal or not: Who caught it? Where was it caught? How much
was caught? When was it caught? How was it caught? – as is
illustrated below. 21 The CA needs to back up these questions with
a legal framework.
l EU Market Access & Eco-Labelling24
4.2 How does the catch certificate operate?Validated catch certificates must accompany all marine fishery
products traded with the EU, including processed products. The
scheme is inspired by existing systems of certification adopted by
RFMOs, which have proven to be the most effective.
It is up to the exporter to request a catch certificate for catches
that are to be traded to the EU, complete it and transmit it to the
competent flag state authority for validation. The EC importer must
ensure that the consignment to be imported is accompanied by
a validated catch certificate transmitted by the exporter prior to
By whom? Where? In whatquantity?
When? How?
The fish was caught...
Illegal/u
nregulated:
Unreported:
Compliance:
Science:
Primarily concerned with vessel ID & fishing ground
All data types are relevant
Primarily concerned with area, quantity, season
Primarily concerned with catch quantity, perhaps closure period and gear type
The answers to these questions must be verifiable in relation to
the fisheries management framework of the harvesting vessel’s
flag state and subject to applicable laws and international conser-
vation and management measures.
The “operating system” of this certification is based on the ca-
pacity of the fisheries AC of the vessel’s flag state to give official
assurances about the existence and “legality” of the answers to
these questions.
The CA, in turn, has a series of “programmes” or tools within their
scheme of Monitoring, Control and Surveillance (MCS) of fishing
activities (e.g. fishing permits, fisheries observers, inspectors,
VMS22, landing controls, etc.) that allow them to validate the accu-
racy of the information in the certificate.
EU Market Access & Eco-Labelling l 25
the importation to the EU. Regarding the implementation (and as
foreseen in the IUU Regulation), the EC has adopted an Imple-
menting Regulation (Commission Regulation (EC) No. 1010/2009
of 22 October 2009) laying down technical details in some of the
following areas:
• Prior notification of landings, transhipments and consignments
(Articles 1, 2);
• Landing and transhipment declarations (Article 3);
• Benchmark criteria for port inspections (Articles 4, 5);
• Simplified catch certification scheme for fishery products with
specific characteristics (i.e. catches obtained by small fishing
vessels) (Article 6);
• List of recognised catch documentation schemes in Regional
Fisheries Management;
• Deadlines for the submission of catch certificates (Article 8);
• Risk management criteria for verifications related to catch certifi-
cates (Articles 31, 32);
• Administrative cooperation with third countries concerning catch
certificates (Article 33).
4.2.1 Trade flows
The catch certification scheme applies to all fishery products
imports, exports and re-exports to and from the Community,
irrespective of the means of transport (fishing vessel, other vessel,
air or land transportation).
Some products, however, are excluded from the scope of the IUU
Regulation. These are very few and relate to freshwater species,
marine species by products and some invertebrates. A complete
list is available in the Annex 3 of Regulation (EC) No. 1010/2009.23
There is no minimum weight below which samples are exempted
from the Regulation.
4.2.1.1 Indirect importation without processing
in another third country
In order to ensure full traceability, the certification scheme also
applies to situations where the fishery products are imported from
another country than the flag state. As a result, products which are
transported to another third country before reaching the Commu-
nity must also be accompanied by a validated catch certificate
and documented evidence that the products did not undergo any
operations other than unloading, reloading or any operation desig-
nated to preserve them in a good and genuine condition.
Such documented evidence may consist of:
• a single transport document, covering the passage from the flag
state to the Community through that third country (of indirect
importation), or;
• a document issued by the authorities in that third country com-
petent for monitoring such activities mentioning:
- the dates of unloading/reloading;
- names of the ships or other means of transport; and
- the conditions in which the products remained unchanged in that
third country until re-export to the Community, or;
• where appropriate, the re-export certificate established by an
RFMO catch documentation scheme recognised in accordance
with Article 13 of the IUU Regulation.
4.2.1.2 Indirect importation with prior processing in another
third country
Where products are processed in a country other than the flag
state, the importer in the Community shall submit a statement
established by the processing plant in the other third country,
provided in Annex IV of the IUU Regulation.
The statement must give an exact description of the products and
must indicate that the products originated from catches accompa-
nied by a catch certificate. A copy of those catch certificates must
be attached to this statement. The competent authorities in the
processing state must endorse the statement.
N.B: Freezing is not regarded as processing, but rather preserva-
tion. However, other conservation methods, such as drying, salting
or smoking are regarded as processing, since the structure of the
product is significantly changed by such treatments.
l EU Market Access & Eco-Labelling26
Both regimes are as different as the work scope of a Seafood
Safety Inspector and a Compliance Fisheries Officer.
The existence of a health certificate is thus not relevant for the
purpose of the validation of a catch certificate, which shall rely
only on compliance with conservation and management rules.
Adversely, the catch certificates used in accordance with the IUU
Regulation will not be substitutes for health certificates and/or
certificates of origin.
5. The relationship between health certificationand IUU certification.
The fact that a health certificate is issued for supplies from an ap-
proved establishment or vessel or, in addition, an origin certificate,
does not infer that the fishery products concerned comply with
conservation and management rules.
However, it is important to note that the different documents (catch
certificates, health certificates, certificates of origin) cannot con-
tain discordant information.
Purse seiners in Southern Chile
EU Market Access & Eco-Labelling l 27
5.1 Comparative table.
The key differences between the two types of certication can be found in the following table:
Sanitary certification Catch certification
Aim Protect the health of the European Consumers (and aquatic fauna in the case of live fish).
Avoid the importation of fisheries products ob-tained from IUU fishing.
Scope Fish and fishery products traded to EU Member countries from “authorised” countries.
All fishing vessels under any flag in all maritime waters, and all processed and unprocessed ma-rine fishery products, traded to or from the EC (and EU nationals operating under any flag).
General responsible Authorised exporting country. The country must be in the list of “authorised” countries based on legal framework and the “competency” of the CA.
Flag state of the harvesting vessel (and/or an RFMO if the vessel/flag country is participant of a catch certification scheme recognised as compli-ant with the applicable regulation).
Applicable EUregulations
Various, most notably Regs, (EC)178/2002, 852/2004, 853/2004, 854/2004, 2073/2005, etc. Effective since 1/1/2006 (prior was a similar system since 1993).
The regulation Reg (EC) No. 1005/2008 estab-lishing a Community system to prevent, deter and eliminate IUU fishing and its Implementing Regulation (Commission Regulation (EC) No. 1010/2009 of 22 October 2009).
Body in chargeat origin
Seafood safety CA varies depending on the country, it can be M. Health, M. Fisheries, M. Agriculture, Food Safety Authority, etc.
Generally, it is the Fisheries Authority of the flag country of the vessel. It can be M. Fisheries, a Fisheries Institute, or Coast Guard, Marine, etc.
Possibility of a split system? (One regulatory system for products to the EU, and one for the rest?)
Yes, this is done by many countries. Not contemplated. Either the flag country controls IUU fishing activities of its vessels or it doesn’t.
Contents of thecertificate
Very specific, done by the CA, and an officer of the CA of the country of processing provides official guarantees that the consignment was dealt with as per the EU regulations. Any changes in the certificate form, or inaccurate information will result in detention. The language of the certificate is the one of the BIP of entry in the Community.
As per the model in the regulation. The master of the fishing vessel at landing should raise it, and the official CA of the flag state shall validate it, or an RFMO if applicable.
The validation must certify that the catch was made in accordance with applicable laws, regula-tions and international conservation and manage-ment measures.
Presentation ofthe certificate
On product arrival at the Border Inspection Post. Either in paper by the importer or e-cert and under the EU TRACES system.
By the importer on arrival (not specified where). In case of direct landings in EU ports 3 days prior notice.
l EU Market Access & Eco-Labelling28
Sanitary certification Catch certification
Body in chargeat the EU
Initially, the Border Inspection Post of the ports of entry at the EU under the umbrella of DG SAN-CO, which holds the ultimate responsibility (autho-rises countries, sends FVO inspections, etc.)
The fisheries authority at the entry port in the EU. This may or may not be the BIP. No centralised body as yet.
Status of theoperator
The operator must appear in a list of authorised establishments (EU#). The value chain from the vessels to him needs to be “approved” by the CA in regards of the EU requirements.
No list of approved vessels. Products of vessels in a list of IUU vessels (either by the EU or by RFMOs) are not allowed access.
Role of thefishing vessel
The fishing vessel is one element of the responsi-bilities of the CA, it has to be “approved” in terms of its hygienic conditions.
The fishing vessel is the “key” element of the certi-fication scheme.
Role of theRFMO
None. If it has a certification scheme (CCSBT, for example), it could be the body that validates the certificates.
Directimportation(imported from the production country or the flag State)
The CA of the country where the product was last processed must emit the health certificate. In the case of factory vessels landing directly, the vessel needs to be “approved” by the CA of the country of origin.
The official CA of the flag state must validate the certificate, or a RFMO is applicable.
Indirect importation (imported from anothercountry than the flag state)
Transport only scenario (transhipment, transit or temporary warehousing)
Responsibility of the processing country. Tech-nically, the product does not “enter” the country where it is transported; if the product is in any way “transformed“, this scenario does not apply.
The product must be accompanied by a validated catch certificate (by the CA of the flag state); and there should be documentary evidence that the consignment remained under the surveillance of the CA and did not undergo processing.
This evidence should be in the form of either a) a single transport document, or b) a certificate from the CA of the state of export, which describes products and indicates dates of unloading/loading and identifies the vessels/transport means.
Indirect importation(imported from another country than the flag state)
Processing scenario
Responsibility of the exporting country. The expor-ter must appear in a list of authorised establish-ments (EU#) from the exporting country.
The raw materials/original product must originate from an “approved” establishment of an autho-rised country.
The health certificate must refer to the “imported raw material” and the original health certificate should be kept.
a) The consignment should be accompanied by the catch certificate validated by the flag state (or a copy in cases where only a partial catch has been used in the consignment).b) The consignment is accompanied by a state-ment from the processor and endorsed by the CA (as per the specific form of the regulation) which, i) describes and quantifies the unprocessed and processed products, andii) states that the consignment has been pro-cessed from catches referred to on the certificate.
EU Market Access & Eco-Labelling l 29
Sanitary certification Catch certification
Indirect importation(imported from another country than the flag state)
Same as above. In both above cases (either transport or proces-sing in country other than flag state), an alterna-tive condition is that the consignment be accom-panied by a re-export certificate validated under a catch documentation scheme of an RFMO, provided that the state of export has fulfilled notification requirements for validation of re- export certificates. This only applies to the relevant species (e.g. a few tunas or toothfish, ICCAT, CCSBT).
Consequences of non-compliance
Product detained. Rapid Alerts Systems entry, report from the country of origin CA, product returned or destroyed.
Refusal of importation. AC of MC may confiscate and destroy, dispose of or sell for charity. If the flag state refuses/fails to take corrective measures against the vessel, it could be potentially listed as an IUU vessel. Flag state potentially listed as a non-cooperating country.
Alert systems The Rapid Alert System for Food and Feed (RASFF) is a tool used for exchange of informa-tion between MS and the Commission when risks to human health are detected in the food and feed chain.
A Community alert system will be created to share information on operators and fishing vessels which are presumed to carry out IUU activities.
European Unionnationals
Nothing in the legislation. Nationals of the EC shall neither support nor en-gage in IUU activities and the EC Member State concerned shall cooperate with the relevant third country in order to identify nationals supporting or engaging in IUU activities.
Support for developingcountries
Over 15 years of technical assistance by various bodies inside and outside the EC.
The EC is cooperating administratively with third countries in the implementation of this regulation.
l EU Market Access & Eco-Labelling30
6.1 The basics.
Many governments have introduced at national, regional and
international levels (with different degrees of success and capac-
ity), diverse policies and mechanisms to ensure the sustainability
of fish stocks and the best environmental practices in aquaculture.
In addition to the official measures, the private sector has also in-
troduced market-based initiatives to support the same objectives.
Eco-labels are one of these initiatives; they are designed to influ-
ence the purchasing decisions of consumers and the procurement
policies of retailers selling seafood products, in order to reward
producers involved in responsible fishing practices and aquacul-
ture practices leading towards sustainable use of natural
resources.
Eco-labels are seals of approval given to products that are
considered to have lesser impact on the environment than other
products in the same market segment.24 An eco-label is a logo
or label placed on a product, therefore providing information that
links the product to the production process, at the moment the
consumer or retailer makes a buying decision. Organisations
developing and managing an eco-label set a series of standards
which applicants hoping to use the logo will be assessed. If found
to be in compliance, they are certified in due course.
The parent organisation also promotes the significance of the
label to consumers to ensure appreciation and demand for their
branded products. Accreditation, in this context, is the procedure
by which certifiers and auditors are accredited as being compe-
tent to carry out the assessments and certification against the
standards specific to each eco-label.
6.2 Why are they becoming
important for the EU market?Retailers see good potential in eco-labels as a marketing tool, as
there is growing demand for ethical products and as an assurance
against disapproving pressure from environmental groups and in
the media. Eco-labelled products are becoming part of many
retailers’ corporate social responsibility policies, and as conse-
quence, some firms are setting procurement targets for eco-
6. Eco-Labelling.
labelled products (i.e. 40% of the total sourced). In many Euro-
pean countries, supermarkets are dominant in the retail of fish and
seafood products. Besides requiring a stable supply chain of good
quality and safe products, they are also requiring their suppliers
to prove that those products have been sourced ethically. Eco-la-
belled products provide this “proof” for the retailers. Particularly in
Central and Northern Europe, this development is very apparent;
the population is relatively environmentally aware, and there is an
active civil society. Consumption patterns are based on a limited
range of traditional fish products, and consumers have the habit of
purchasing processed/packaged fish and seafood from super-
markets that lend themselves to the attachment of a label at the
point of sale. As a consequence, the market share of eco-labelled
products is growing rapidly.
6.3 Coverage and certification.
There is a lot of variety in terms of “what” is covered by the various
Eco-Labelling schemes beyond an initial division, in between tho-
se that deal with capture fisheries and aquaculture. Some of the
specific requirements of each eco-label scheme will be discussed
later; however, it is important to point out that they do not only
subscribe to environmental matters, but they extend to biotechno-
logy, animal welfare, social responsibility and economic develop-
ment issues. In terms of their certification methodology, there is
also variability, however, which can be categorised as:
• First party labelling schemes: established by individual compa-
nies, based on their own product standards, with compliance
“self declared”.
EU Market Access & Eco-Labelling l 31
• Second party labelling schemes: established by industry as-
sociations for their members’ products. Compliance is verified
through internal audit procedures or by employing external
certifying companies as auditors (such as Bureau Veritas, SGS,
etc.).
• Third party labelling schemes: usually developed by a body
independent of producers, distributors and sellers of the labelled
products. The label is typically licensed to a producer. The “chain
of custody” is tracked to ensure that the labelled product is in
fact derived from the certified product. An independent, third-
party certifier conducts the audits.
The independence of certification is seen as a proxy for credibi-
lity: being audited by an independent body offers a more credible
judgment than a self-assessment. The proliferation and variety of
eco-labels has led to calls for international guidance in the area. In
response, FAO has produced the “Guidelines for the Eco-Labelling
of Fish and Fishery Products from Marine Capture Fisheries”25
in 2005, and will soon publish the “Guidelines for Aquaculture
Certification”.26
6.4 Producers: costs and benefits.
Even though a range of costs and benefits has been claimed for
producers signing up to an Eco-Labelling scheme, there has not
been much in-depth analysis of the economics of producers op-
erating in fisheries that have gained eco-certifications. As a result,
there is a relative dearth of empirical evidence as to the actual
costs and benefits.
In late 2008, a Globefish study27 analysed the cost benefits based
on some initial observations, experiences to date and the claims
made by the eco-label schemes. It identified these potential
benefits:
• Access to new markets
• Consolidation or expansion of market share in existing markets
• Greater credibility vis-à-vis retail buyers
• Potential for more value-added products including through prod-
uct differentiation (niche markets for environmentally friendly
products)
• Improved management of fisheries resources and resulting
guarantees of future production potential
• Increased earnings through an assumed price premium for eco-
labelled fish
In contrast, costs identified included:
• Actual costs of certification, experts‘ fees, etc.
• Compliance costs related to adjusted management practices,
data collection and record keeping, which is additional to exist-
ing government administrative requirements
• Costs related to potential adjustments in fisheries management
(e.g. there might be a recommendation that catch limits are
reduced to meet sustainability criteria)
The report also identified socio-economic issues in relation to
Eco-Labelling schemes, such as:
• Transparency and participation: standards are set by ‘outsiders’
and imposed on fishers.
• Legitimacy: Eco-Labelling schemes are typically developed and
controlled by private sector operators or NGOs; some fishers
would prefer to participate in a public scheme which they consi-
der has more legitimacy and some public accountability.
• Applicability: concerns have been raised that current schemes
do not lend themselves to multi-species or artisanal fisheries
found in developing countries, and they do not take in considera-
tion their special needs.
• Impacts on trade: eco-labels might be used as a barrier to trade
by importing countries and become “back door” protectionism.
• Governance: certification and labelling depends on the effec-
tive public management of marine resources. Poor institutional
infrastructures pose a barrier to the certification of fisheries in
those jurisdictions.
• Obligatority: fears that schemes that are initially voluntary will
eventually become mandatory.
l EU Market Access & Eco-Labelling32
6.4.1 Price premium
Whereas extracting information about prices is difficult due
to commercial sensitivities, there does not seem to be much
evidence of a price premium as a result of the certification of
products. Pricing is a function of various factors, and an eco-label
is arguably not the most significant. Even though most retailers
are unwilling to divulge information about pricing, there does not
appear to be a price premium attached to eco-labelled products at
a retail level either.
Most returns, to both retailers and processors, appear to be more
indirect and related to reputation and brand value.
For example:
The New Zealand Seafood Industry Council, SeaFIC,
concluded that, “It is difficult to identify any premium for
hoki28 arising from certification.” SeaFIC29 argues that
the industry should not even expect a price premium for
certification noting that: “No plausible case can be made
for a premium for ‘sustainable seafood’. I anything, a well
managed fishery should also be a cheaper fishery to
harvest as the fish should be more abundant and easier to
catch!”
6.4.2 Increased market share
Research in the field agrees that it is too early to tell whether
Eco-Labelling will become the new norm or “minimum standard”
and what implications that would have for market access. There
are some indications that fisheries operators feel compelled to
become certified when their competitors do.
It is expected, however, that as certification becomes more
prevalent, any potential market share advantage will diminish and
the usual factors such as price, presentation and brand loyalty will
define the point of sale choices for consumers.
6.5 Consumers’ perspective.
The “explosion” of fish-related labels and certification, in particular
related to farmed fish, has created what has been described as
“eco-label noise”. Consumers may find the wealth of different mes-
sages confusing; they increasingly put their faith in trusted retai-
lers to define the boundaries of their ethical purchasing decisions.
For example:
The NZ Hoki fishery managed under an internationally peer
review Quota Management System (QMS) has been
certified by MSC since 2001, nevertheless, in 2010 Green-
peace added it to its seafood red list30, as Greenpeace
believes “the stocks of hoki are now considered to be
overfished”.
Retailers and brand owners filter the various messages and
through “choice editing” decide which standards or labels to
include in their procurement and marketing strategies. Therefore,
the Eco-Labelling scene is dynamic; some schemes have merged,
others will do so in years to come, and some may disappear.
Mutual recognition among schemes is being tested among the
smaller players as an alternative in order to maintain market
presence, by avoiding the polarisation of labels and products.
Nevertheless, by their nature, the schemes are always going to be
seen as incomplete by some groups and as excessive by others.
6.6 Eco-labels in developing countries.Although the driving force for eco-labelled products is in the devel-
oped countries, the trend towards eco-labels is affecting producing
developing countries on various fronts.
To date, not many operations in developing countries have been
certified as part of an Eco-Labelling scheme. This is perhaps due
to three main factors:
• the lack of clear and defined economic imperatives
• the high costs of certification
EU Market Access & Eco-Labelling l 33
• Eco-Labelling schemes do not translate well into the typical con-
ditions of the fisheries and aquaculture environments in devel-
oping countries (insufficient fisheries management regimes,
data deficiencies, multi-species fisheries, poor environmental
management infrastructure, low levels of governance and
transparency, etc)
6.6.1 Weak economic imperatives
Three factors suggest that so far developing countries need not
feel that their livelihoods are threatened by the trend towards sus-
tainability certification and in Eco-Labelling schemes:
• The current small volumes of eco-labelled products on the
market suggesting limited demand to date (albeit growing).
• The concentration of Eco-Labelling in certain species that are
not the main species produced by most developing countries.
If their competitors with similar or substitutable species are not
eco-labelled, then there is no need for them to be.
• The concentration of demand in certain markets: although there
is significant demand in pockets of the European and United
States markets, in other significant markets such as Japan and
China there is less eco-sensitivity.
Artisanal fishermen in Papua New Guinea
l EU Market Access & Eco-Labelling34
6.6.2 Certification costs
Even operators in developed countries complain about the high
costs of certification. For developing countries the costs are often
prohibitive, including the up-front direct costs of the initial assess-
ment process with reliance on outside experts, as well as any
subsequent costs relating to upgrading of gear, facilities, methods
or management systems. Where there are multiple stakeholders,
deciding who pays and how much, can also be problematic. As
discussed above, there is no guarantee of a price premium to off-
set these costs. Where there are catch limits imposed, reductions
in income and some unemployment might be other indirect costs
of certification.
6.6.3 Weak institutional capabilities
Several commentators have raised serious concerns about the
institutional ability of many developing countries, as current Eco-
Labelling fisheries and aquaculture schemes require resources
and capabilities that are not yet fully available in many developing
country scenarios.
Below are some of the difficulties encountered:
• There is lack of an effective fisheries management regime,
which in practice is a prerequisite for certification. Some oper-
ate under open access arrangements, with weak official controls
over catch limits if and when they exist.
• There is a lack of accurate data information on existing stocks.
Certification requires science-based stock assessments for
which there is often poor infrastructure (systems and human
resources).
• There is also inadequate data on catch volumes.
• Small-scale fishers land catch at a multitude of sites for which
records are rarely kept.
• Eco-Labelling schemes are generally data-intensive: in devel-
oping countries there is often a lack of know-how and a weak
tradition of record keeping. This makes any chain of custody
certification problematic.
• Certification is often based on a single species fishery charac-
teristic of developed countries. Developing country fisheries
tend to be multi-species, with commercial and artisanal fishers
competing for the same stocks.
• In some cases, literacy is also an issue.
These problems have been recognised by the Marine Stewardship
Council (MSC), one of the best-known Eco-Labelling schemes.
They have developed new methods to enable certifiers to assess
small and data-poor fisheries against the MSC standard (MSC
Risk-Based Framework), in recognition that many developing
country fisheries do not have the detailed scientific data needed
to demonstrate a conclusive case for their sustainability, but may
nonetheless be able to demonstrate they are operating sustain-
ably and can make the case for certification.
As modern aquaculture is becoming an industrial means of food
production, it can lead to detrimental impacts on the environment
and affected communities. In many developing countries there
are constraints on the institutional capacity required to deal with
issues, such as:
• appropriate site selection, construction and operation of small-
and large-scale aquaculture operations that minimise environ-
mental impacts, such as water and soil deterioration and pol-
lution, disturbance and/or destruction of aquatic and terrestrial
habitats, introduction of alien species and disease outbreaks;
• integration with fisheries policies as the production of high-value
carnivorous fish and crustaceans is often associated with a net
loss of aquatic protein resources, as the species being cultivated
requires considerable volumes of fishmeal and fish oil for aqua-
culture feed. This increases pressure on wild fish populations;
• resource management and allocation as excessive use can lead
to conflicts amongst local stakeholders, especially where water
and land resources are scarce;
EU Market Access & Eco-Labelling l 35
• large-scale, industrial aquaculture activities in developing coun-
tries can be accompanied by social conflicts with local stake-
holders and communities that are negatively affected by such
operations without receiving any benefits from them;
• aquaculture facilities can employ a large number of workers on
farms and in processing plants, potentially placing labour practi-
ces and worker rights under public scrutiny.
6.7 What about organic aqua-
culture?The market share for organic products is globally on the rise.
This growth, however, is focused on the higher income strata in
Western Europe.31 In general, organic fish is perceived to be more
“natural” and therefore healthier, or even tastier. In some regions
the emphasis is on local production, in part to reduce food miles
but also to support regional production. In others, the concept of
organic aquaculture is focused on small, traditional farms only. For
example, in France organic aquaculture certification is limited to
100 tonnes per site. In other cases there is an emphasis on the
“Fair Trade” concept involving human and labour rights issues.
6.7.1 EU regulatory framework for organic products
Until recently, there was a lack of specific organic aquaculture
regulation for third countries. However, a positive step was taken
in this matter since 1 January 2009 when the new EU regulation
(Council Regulation No. 834/2007 of 28 June 2007 on organic
production and labelling of organic products)32 went into effect for
the production, control and labelling of organic products.
The Council Regulation applies to agricultural products, including
aquaculture and yeast, either as living or unprocessed products,
processed foods, animal feeds, seeds and propagating material.
The basis for the acceptance of EU rules on organic aquaculture
is laid in article 15 of the legislation. According to the new legisla-
tion, European producers of packaged organic food must use the
EU organic logo as of 1 July 2010. The use of the logo on organic
foods from third countries is optional.
The distribution of organic products from third countries is only
permitted on the common market when they are produced and
controlled under the same or equivalent conditions as the EU
ones. The “old” procedure for import licences is replaced by a new
import regime. Control bodies working in third countries will then
be directly authorised and monitored by the EC and the Member
States. This new procedure allows the EU Commission to super-
vise and better monitor the import of organic products and the
control of the organic guarantees. A list of recognised third
countries can be found in Annex III of the Import Regulation.33
Products that are produced and controlled in precisely the same
manner as in the EU will also have free access to the common
market. Control bodies that intend to undertake such controls
must apply to the EU Commission and be authorised by the Com-
mission and the Member States for this purpose.
However, since production conditions in third countries are usually
very different from those in Europe, it is often not possible to apply
exactly the same rules for production or control. Therefore, it is
also possible to allow similar rules that conform in principle with
the goals and principles of the organic legislation.
The EU has created an ad hoc portal for its Organic Farming
Policy at: ec.europa.eu/agriculture/ organic/home_en
l EU Market Access & Eco-Labelling36
6.8 Which way to go for Eco- Labelling?In April 2009 a Round Table on Eco-Labelling and Certification in
the Fisheries Sector was jointly organised by the OECD Committee
for Fisheries and the FAO Fisheries and Aquaculture Department 34.
The Round Table brought together representatives from the fishing
industry (producers, processors, buyers, retailers) NGOs, Eco-
Labelling schemes, certification bodies, academia, governments,
and relevant international organisations. The alignment of Eco-
Labelling schemes, or at least some sort of framework against
which to judge the quality and credibility of the various fisheries
certification schemes in the marketplace, became a recurring
theme throughout the Round Table.
A “wish-list” for buyers35 for fish certification schemes was pro-
posed. This list is helpful for producers to choose between Eco-
Labelling schemes if the need for certification has been
established:
• Does the eco-label operate to an internationally agreed or
harmonised reference, such as the FAO Guidelines for the Eco-
Labelling of Fish and Fishery Products from Marine Capture
Fisheries (and/or Guidelines for Aquaculture Certification)?
• Is the certification process of the eco-label compliant with rele-
vant international standards (e.g. ISO 6536, ISEAL37)?
• Is the governance and transparency of the organisation/standard
robust?
• Does the issuing organisation have credibility (related to above)?
• Is the scheme easily used by industry (e.g. easily understood
using simple language)?
• Is it affordable? Does the cost structure incite the market to
adopt the standard?
• Is a continuous business improvement process built into the
scheme?
• Do its label declarations align to international standards
(i.e. ISO 14020 – Environmental labels and declarations)?
EU Market Access & Eco-Labelling l 37
6.9 Key fisheries eco-labels.
Different certification schemes certify different things, have
different standards, and use different assessment methodologies.
There is significant variation between schemes in the scope of the
assessments conducted.
In terms of their origin, the fisheries schemes can be promoted by:
• National and regional governments
• Retailers
• The fishing industry
• NGO-based eco-labels and seafood guides
As this publication focuses on EU market access, only some
European-operated or EU market-oriented standards and certifi-
cation programmes with strong market presence in the EU have
been selected for identification.
Therefore, this is neither an exhaustive list, nor an endorsement
of the schemes identified. A detailed benchmarking analysis of the
schemes can be found in Assessment of On-Pack, Wild-Capture
Seafood Sustainability Certification Programmes and Seafood
Ecolabels (WWF International 2009).38
Artisanal fishermen in Sri Lanka
l EU Market Access & Eco-Labelling38
6.9.1 Marine Stewardship Council
The Marine Stewardship Council (MSC) was established in 1997
as a joint project between the then largest seafood buyer Unilever
and the international conservation organisation World Wildlife
Fund (WWF). The MSC has operated as an independent organi-
sation since 1999. It sets the standard for the eco-label through its
board, supported by a Technical Advisory Board.
Fishery assessments are conducted by third party certification
bodies, which are in turn accredited as competent to perform MSC
assessments by an accreditation body that is independent of both
MSC and the certification bodies. For products to carry the MSC
eco-label they must meet the MSC standards both for the sus-
tainability of the source fishery and for the integrity of the “chain of
custody” through which the product passes from the fishery to the
end consumer. The initial audit is valid for five years with annual
surveillance audits.
The chain of custody requirement is to protect against products
from uncertified fisheries carrying the eco-label. There is an
independent dispute resolution process. Currently 187 fisheries
around the world are either certified or under assessment. These
fisheries landed over 7 million tonnes of seafood annually – 12%
of the global wild harvest for human consumption. The fisheries
certified include large- and small-scale fisheries.
The MSC has developed new methods to enable certifiers to
assess small and data-poor fisheries against the MSC standard
(MSC Risk-Based Framework), in recognition that many devel-
oping country fisheries do not have the detailed scientific data
needed to demonstrate a conclusive case for their sustainability,
but may nonetheless be able to demonstrate they are operating
sustainably and make the case for certification.
www.msc.org
6.9.2 Friend of the Sea (fisheries)
Friend of the Sea is an Italian-based fisheries and aquaculture
certification scheme promoted by the Earth Island Institute, an
international independent and not-for-profit humanitarian and envi-
ronmental organisation. Friend of the Sea (FOS) was established
in 2005 and reviews the sustainability of fisheries (and aquacul-
ture) production based on published data.
The FOS scheme works by approving fisheries/products if: (a) tar-
get stocks are not overexploited; (b) fisheries use fishing methods
which do not impact the seabed; and (c) they generate less than
8% discards (the global average estimated in FAO publications).
Products/fisheries are assessed against: FAO data on stock
status in different fisheries areas; the IUCN red list of endangered
species; fishing gear types felt to be harmful to the seabed; IUU
and Flags of Convenience; and compliance with TACs, use of the
precautionary principle, and national legislation.
Bureau Veritas or SGS checks the chain of custody (traceability
and documental evidence) and actual fishing method and compli-
ance with legal standards.
There are around 60 capture fisheries products already approved
under the scheme with certified products sold in 23 countries.
Many of the certified fisheries are of small scale and in developing
countries.
www.friendofthesea.org
EU Market Access & Eco-Labelling l 39
6.9.3 KRAV (fisheries)
KRAV is an association that promotes organic farming. It is
composed of 28 members who are said to represent the interests
of producers, traders, processors and consumers in addition
to protecting the environment and animal welfare. Although the
focus of its activities is in Sweden, KRAV supports international
activities towards organic farming through its interactions with
IFOAM and the European Union. KRAV standards cover several
production sectors including crops, livestock, apiculture and aqua-
culture. Standards are developed and revised by KRAV some-
times following several rounds of comments and are approved
by the KRAV Board of Directors. KRAV standards are applicable
to farming and all links in the supply chain including distributors,
processors and restaurants.
Sustainable fishing standards are created to drive development in
the fishing industry towards a sustainable fishing and processing.
In 2004, KRAV issued standards for sustainable fishing in the
Scandinavian jurisdiction. However, since mid 2010, KRAV will
also accept applications for fish stocks outside Scandinavia.
The standards consist of five sets of rules that cover all aspects of
fishing, processing, and sales: Quality assurance, Stock assess-
ment, Fishing vessels, Fishing methods and Landing and proces-
sing. These standards were developed for conditions in Scandina-
via and are neither tested nor intended for other areas.
The KRAV standards also include: requirements concerning fuel
used by fishing vessels, the type of motor, the paint used on
ships, etc. The environmental and fisheries management dimen-
sion focuses more on the equipment and operational impacts
(fuel pollution, etc.) than on the actual habitat and marine stock
environment.
www.krav.se
6.9.4 Naturland (fisheries)
Naturland is one of the major certifying organisations for organic
produce and it has been one of the pioneering standard organisa-
tions for organic aquaculture development.
Naturland has developed standards for the production of a wide
range of commodities including fruit, vegetables, honey, livestock
and for forest management. It has a well-developed process of
certification and accreditation. This includes third party certifi-
cation bodies, accreditation bodies and objections procedures,
with frequent ISO audits to ensure the accreditation certification
systems meet international requirements.
In 2006, Naturland extended its scope to include sustainable
inland and marine capture fisheries with the eco-label Naturland
Wildfish.
The Naturland Wildfish assessment includes social and economic
sustainability in addition to ecological sustainability. One fishery
has been certified under this eco-label in 2009: the Lake Victoria
fishery for Nile perch. It is anticipated that this first assessment will
result in further definition and refinement of the Naturland Wildfish
criteria and methodology.
www.naturland.de/naturlandwildfish.html
l EU Market Access & Eco-Labelling40
6.10 Key aquaculture eco-labels.
Different certification schemes certify different things, have
different standards, and use different assessment methodologies.
There is significant variation between schemes in the scope of
the assessments conducted. Most of the certification programmes
available to the aquaculture industry focus on the following issues:
• Food Safety: proper food health and safety measures
• Food Quality: product quality characteristics
• Environment: environmentally sound production processes
• Social Responsibility:
social accountability within the production process
• Animal Welfare: issues related to animal welfare and health
In terms of their origin, the aquaculture schemes can be promoted by:
• Retailers
• The aquaculture industry
• Governments
• NGOs
• Organic certification schemes
• Fair trade certification schemes
As this publication focuses on EU market access, only some
European-operated or EU market-oriented standards and certifi-
cation programmes with strong market presence in the EU have
been selected for identification.
This, however, does not pretend to be an exhaustive list, nor an
endorsement of the schemes identified.
A detailed benchmarking analysis of the schemes can be
found in Benchmarking Study: Certification Programmes for
Aquaculture(WWF Switzerland and Norway 2007).39
6.10.1 Aquaculture Certification Council
The Aquaculture Certification Council (ACC) is a non-govern-
mental body established to certify social, environmental and food
safety standards at aquaculture facilities throughout the world.
This non-profit, non-member public benefit corporation applies the
Global Aquaculture Alliance (GAA).
Best Aquaculture Practices (BAP) in the certification system com-
bines site inspections and effluent sampling with sanitary controls,
therapeutic controls and traceability.
The GAA has been formed by the aquaculture industry, predomi-
nantly by the shrimp sector, to promote sustainable aquaculture
practices throughout the world. It has developed a Code of Good
Practice for marine shrimp farming that has been used as the
basis for BAP for shrimp.
The Global Aquaculture Alliance is currently developing additional
standards for other species (fish) that may be included in the BAP-
Certification programme.
The Aquaculture Certification Council currently certifies GAA’s
BAP programme for shrimp hatcheries, farms and processing
plants. Independent inspectors who are trained and approved by
the ACC conduct inspections and audits of farms and processing
plants.
gaalliance.org/bap/standards.php
®
EU Market Access & Eco-Labelling l 41
6.10.2 Global GAP
GLOBALGAP (GG), formerly known as EUREPGAP, is a private
sector body that sets voluntary standards for the certification of
food products around the globe. EUREPGAP started in 1997 as
an initiative by retailers belonging to the Euro-Retailer Produce
Working Group (EUREP). Today GG is an equal partnership of
producers and retailers who wish to establish certification stan-
dards and procedures for Good Agricultural/Aquaculture Practices
(GAP).
GG management and normative documents are hosted and
owned by FoodPLUS GmbH, a non-profit industry owned and
governed organisation. It provides standards and framework for
the independent, recognised third party certification of farm pro-
duction processes based on EN45011 or ISO/IEC Guide 65.
The GG Integrated Aquaculture Assurance Standard is based on
the GG Integrated Farm Assurance Standard (for agriculture) and
has a modular composition, which enables farmers to combine
multiple products into one single audit. The aim is to ensure integ-
rity, transparency and harmonisation of global aquaculture stan-
dards. The standard includes issues such as worker health, safety
and welfare, environmental and animal welfare. GG is a pre-farm
gate standard that covers the whole agricultural or aquaculture
production process, including production of feed and juveniles/
seedlings in hatcheries.
GG is a business-to-business tool/certification system and is
therefore not directly visible to the end consumer.
www.globalgap.org
6.10.3 Friend of the Sea (aquaculture)
Friend of the Sea is an Italian-based fisheries and aquaculture
certification scheme promoted by the Earth Island Institute, an
international independent and not-for-profit humanitarian and envi-
ronmental organisation. Friend of the Sea (FOS) was established
in 2005 and reviews the sustainability of fisheries (and aquacul-
ture) production based on published data.
The aquaculture certification scheme has been developed by FOS
by involving industry stakeholders as well as NGOs and scientific
bodies.
The certification is based on compliance assessment against
FOS’s criteria for sustainable aquaculture (Approval Criteria
for sustainable Aquaculture), which aim to provide a regulatory
framework in accordance with the same main criteria of organic
aquaculture standards.
Criteria for Sustainable Aquaculture require, among the others,
that: an Environmental Impact Assessment or equivalent be run
before the development of the plant; the plant is not impacting
critical habitats, such as mangroves, wetlands, etc.; procedures
are in place to limit escapes of fish to a negligible level; no use of
GMO and growth hormones; no use of antifouling paints; waste,
water, feed and energy management programmes are in place;
and usage of FOS certified feed (currently for trout, sea bream
and sea bass).
FOS has currently over 12 different species and products certified,
most of which are sold in European or US retail chains under
private labels. For aquaculture products, the FOS aquaculture
standard requires certification by organic standards since the end
of 2008.
www.friendofthesea.org
l EU Market Access & Eco-Labelling42
6.10.4 Aquaculture Stewardship Council
The Aquaculture Stewardship Council (ASC) was founded in 2009
by WWF and IDH (Dutch Sustainable Trade Initiative) to manage
the global standards for responsible aquaculture, which are under
development by the Aquaculture Dialogues, a programme of
round tables initiated and coordinated by WWF.
Currently the ASC is in its business development phase. The ASC
is expected to be in full operation by mid 2011.
The ASC aims to be a global organisation working with aquacul-
ture producers, seafood processors, retail and food service com-
panies, scientists, conservation groups and the public to promote
the best environmental and social choice in aquaculture products.
The ASC will offer standards for aquaculture and for the seafood
chain of custody. The standards are being developed by the Aqua-
culture Dialogues in compliance with the guidelines for standard
setting established by the International Social and Environmental
Accreditation and Labelling Alliance (ISEAL).The certification
according to these standards will be in the hands of independent,
third-party, and accredited certifiers.
Once established, the ASC will develop and launch a consumer-
facing label for responsible aquaculture.
www.ascworldwide.org
6.10.5 Naturland (aquaculture)
Naturland is one of the major certifying organisations for organic
produce, and it has been one of the pioneering standard orga-
nisations for organic aquaculture development. Naturland has
developed standards for the production of a wide range of commo-
dities including fruit, vegetables, honey, livestock and for forest
management.
It has a well-developed process of certification and accreditation.
This includes third-party certification bodies, accreditation bodies
and objections procedures, with frequent ISO audits to ensure
the accreditation certification systems meet international require-
ments.
Naturland developed the first species-specific standards in 1995,
starting with carp, followed by salmonids, bivalve molluscs and
shrimp. Compliance to Naturland standards is assessed through
annual and occasional random inspections conducted by indepen-
dent organisations.
To improve the management of organic businesses and ease the
process of inspection and certification, Naturland has entered a
number of initiatives that use IT solutions. The adoption of e-tools
is also said to reduce the cost of inspections.
To assist small-scale producers in complying with certification
requirements, Naturland also produces extension material on the
development of internal inspection systems.
The Naturland Standards for Organic Aquaculture now include
specific regulations for a range of aquaculture commodities and
for processing of aquaculture products. A number of projects are
also being conducted in several countries (e.g. Vietnam, Ban-
gladesh, India) aimed at assisting producers in complying with
Naturland standards and them benefiting from implementation of
organic aquaculture.
www.naturland.de/certifiedorganicaquaculture.html
EU Market Access & Eco-Labelling l 43
6.10.6 Bio Suisse
Bio Suisse, a private-sector organisation, is the federation of
Swiss organic farmers. It is an umbrella organisation that counts
32 organic farmers’ associations among its members, as well as
the Research Institute of Organic Agriculture (FiBL). Bio Suisse
standards cover not only organic farming but also processing and
marketing of organic products.
Conformity to Bio Suisse standards is assessed by inspection
bodies authorised by Bio Suisse; they are selected among bodies
that have been accredited by the Swiss accreditation authority.
Only businesses with a Swiss partner (e.g. importers) can apply
for Bio Suisse certification. Bio Suisse also allows for inspection
and certification of cooperatives, projects and producer
groups based on criteria set by Naturland, IFOAM and FVO (Farm
Verified Organic).
In 2000, Bio Suisse adopted standards for organic aquaculture.
Standards refer to the farming of organic fish (trout, salmon, carp,
etc.), although approval for shrimp and mussels may also be
obtained if a number of conditions including compliance with the
Naturland standards (or equivalent) are met.
Bio Suisse certified aquaculture products now include salmon and
trout in Europe and pangasius in Vietnam.
www.bio-suisse.ch
6.10.7 KRAV (aquaculture)
KRAV is an association that promotes organic farming. It consists
of 28 members who are said to represent the interests of prod-
ucers, traders, processors and consumers in addition to protecting
the environment and animal welfare.
Although the focus of its activities is in Sweden, KRAV supports
international activities towards organic farming through its interac-
tions with IFOAM and the European Union. KRAV standards cover
several production sectors including crops, livestock, apiculture
and aquaculture.
Standards are developed and revised by KRAV sometimes
following several rounds of comments and are approved by the
KRAV Board of Directors. KRAV standards are applicable to
farming and all links in the supply chain including distributors,
processors and restaurants.
The assessment of conformity to KRAV standards is conducted by
an authorised inspection body, which is also authorised to issue
certificates on behalf of KRAV, of which there are presently almost
50, located in 22 countries across the world.
The KRAV scheme offers a wide range of labels to differentiate
products based on the amount of organic material contained, to
label production inputs, for export and for wild production.
Although KRAV aquaculture standards contain specific parts for
salmonids, perch and blue mussels, they can be applied broadly
to production in freshwater, brackish water and marine environ-
ments and are suitable for carnivores, omnivores and herbivores
in all their life cycle stages.
www.krav.se
l EU Market Access & Eco-Labelling44
7. Bibliography.
This publication has drawn views and information from the fol-
lowing publications under the different areas:
Sanitary certification.
• How to export seafood to the EU. 2nd edn. Blaha, F. Feb 2009.
By ITC (WTO/UNCTAD). Geneva. http://www.intracen.org/tdc/
Export%20Quality%20Bulletins/EQM84eng.pdf
• Regulatory Alternatives for EU Market Access. Food and Agri-
culture Organization of the United Nations. Blaha, F. 2008. FAO
Rome. ftp://ftp.fao.org/docrep/fao/012/i0884b/i0884b02c.pdf
• General guidance for third country authorities on procedures to
be followed when importing live animals and animal products
into the EU. SANCO/10063/2007 Rev.2 2009. http://ec.europa.
eu/food/animal/liveanimals/guide_thirdcountries_en.pdf
• The Impacts of Private Food Safety Standards on the Food
Chain and on Public Standard-Setting Processes. Henson, S.
and Humphrey, J. FAO/WHO. 2009. ftp://ftp.fao.org/codex/ CAC/
CAC32/al329Dbe.pdf
IUU catch certification scheme.
• Handbook on the practical application of Council Regulation
(EC) No. 1005/2008 of 29 September 2008 establishing a Com-
munity system to prevent, deter and eliminate illegal, unreported
and unregulated fishing (The IUU Regulation). Ref: Mare A4/
PS D(2009) A/12880. http:// ec.europa.eu/fisheries/cfp/illegal_
fishing/info/handbook_original_en.pdf
• Addendum to the first edition of the Handbook on the practical
application of Council Regulation (EC) No. 1005/2008 of 29 Sep-
tember 2008 establishing a Community system to prevent, deter
and eliminate illegal, unreported and unregulated fishing. http://
ec.europa.eu/fisheries/ cfp/illegal_fishing/info/handbook_adden-
dum_en.pdf
• Technical note – detailed description of the catch certification
scheme. http://ec.europa.eu/ fisheries/cfp/illegal_fishing/info/
technical_note_en.pdf
• List of Member States and their competent authorities con-
cerning Articles 15(2), 17(8) and 21(3) of Council Regulation
(EC) No. 1005/2008. http://ec.europa.eu/fisheries/cfp/illegal_
fishing/ info/ms_authorities_en.pdf
• Addendum to and amendment of list of competent authorities in
Member States http://ec.europa.eu/fisheries/cfp/illegal_fishing/
info/addendum_authorities_en.pdf
EU Market Access & Eco-Labelling l 45
Eco-Labelling.
Fisheries
• Product certification and Eco-Labelling for fisheries sustaina-
bility. Wessells, C.R. et al. FAO Fisheries Technical Paper 422.
Rome. 2001. ftp://ftp.fao.org/docrep/fao/005/y2789e/y2789e00.
• Guidelines for the Eco-Labelling of Fish and Fishery Products
from Marine Capture Fisheries. FAO Rome. 2005. http://www.
fao.org/docrep/008/a0116t/a0116t00.htm
• Eco-labels and Marine Capture Fisheries: Current Practice and
Emerging Issues. GLOBEFISH Research Programme. Washing-
ton, S. Vol. 91. FAO Rome. 2008. http://www.nmfs.noaa.gov/ocs/
mafac/meetings/2008_07/docs/GLOBEFISH_Eco-labels_mari-
ne_capture_fisheries.pdf
• Certification and Sustainable Fisheries. UNEP Division of Tech-
nology, Industry and Economics. Macfadyen, G. and Huntington,
T. 2009. http://www.unep.ch/etb/publications/FS%20certifica-
tion% 20study%202009/UNEP%20Certification.pdf
• Proceedings of the OECD/FAO Round Table on Eco-Labelling
& Certification in Fisheries. The Hague. 22-23 April 2009. http://
www.oecd.org/dataoecd/17/43/43356890.pdf
• Review of Fish Sustainability Information Schemes – Final
Report. Fish Sustainability Information Group. MRAG. January
2010. http://www.mrag.co.uk/Documents/FSIG_Final_report.pdf
• Review of Eco-Labelling schemes for fish and fishery products
from capture fisheries. Sainsbury, K. FAO Fisheries and Aqua-
culture Technical Paper. No. 533. FAO Rome. 2010. http://www.
fao. org/docrep/013/i1433e/i1433e00.pdf
Aquaculture
• Benchmarking Study on International Aquaculture Certification
Programmes. World Wildlife Fund (WWF) Switzerland and Nor-
way. Zurich and Oslo. 2007. http://assets.panda.org/downloads/
benchmarking_study_wwf_aquaculture_standards_new_.pdf
• Guide for the Sustainable Development of Mediterranean Aqua-
culture 3. Aquaculture Responsible Practices and Certification.
IUCN Gland, Switzerland and Malaga, Spain. 2009. http:// data.
iucn.org/dbtw-wpd/edocs/2009-061.pdf
• A qualitative assessment of standards and certification
schemes applicable to aquaculture in the Asia-Pacific region.
FAO Regional Office for Asia and the Pacific. Thailand. 2007.
RAP PUBLICATION 2007/25. ftp://ftp.fao.org/docrep/fao/010/
ai388e/ai388e00.pdf
• Synthesis of Mediterranean marine finfish aquaculture – a mar-
keting and promotion strategy. Barazi-Yeroulanos, L. Studies and
Reviews. General Fisheries Commission for the Mediterranean.
No. 88 FAO Rome. 2010. http://www.fao.org/docrep/013/i1696e/
i1696e.pdf
l EU Market Access & Eco-Labelling46
8. Endnotes.1 A good resource to understand the structure and workings of the
EU can be found at http://europa. eu/abc/12lessons/index_en.htm2 (for a complete list see: https://webgate.ec.europa.eu/sanco/tra-
ces/output/listsPerActivity_en.htm#)3 For a deeper view into the more technical details, see F. Blaha.
How to Export Seafood to the EU. 2nd edn. Feb 2009. By ITC
(WTO/UNCTAD). Geneva. Available from http://www.intracen.org/
tdc/ Export%20Quality%20Bulletins/EQM84eng.pdf4 A third country is a non-member country of the EU.5 Regulation (EC) No. 882/2004 of the European Parliament and
of the Council of 29 April 2004 on official controls performed to en-
sure the verification of compliance with feed and food law, animal
health and animal welfare rules. Article 2. Definitions.6 Regulation (EC) No. 882/2004. 1.(6).7 Regulation (EC) No. 1250/2008 of 12 December 2008. http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32008R1250
:en:NOT8 FVO homepage http://ec.europa.eu/food/fvo/ir_search_en.cfm9 For the list of establishments at each of the authorised countries
see https://webgate.ec.europa.eu/ sanco/traces/output/listsPerAc-
tivity_en.htm#10 See Code of Practice for Fish and Fishery Products. 2010.
http://www.codexalimentarius.net/download/ standards/10273/
CXP_052e.pdf11 Animal health for aquaculture animals exceeds the scope of this
publication, but should not be ignored.12 Official controls of production and placing on the market (Chap-
ter I), Official controls of fishery products (Chapter II), Decisions
after controls (Chapter III).13 This list is an illustrative one and is far from exhaustive.
14 However, fishery products from bivalve molluscs, equinoderms,
tunicates, and marine gastropods can be commercialised if they
have been produced in conformity with section VII of annex III,
and bullet 2 of chapter V of the same section of Regulation CE No.
853/2004.15 For fishery products: vessels, landing sites, transporters, cool
stores, processors, etc. For aquaculture products: feed producers,
hatcheries, farms, transporters, processors, etc.16 Against EU standards or officially equivalent ones.17 Regulation (CE) 882/2004 art 1218 For more information on RASFF: http://ec.europa.eu/food/food/
rapidalert/index_en.htm19 For example: http://ec.europa.eu/food/food/rapidalert/reports/
week8-2008_en.pdf20 Council Regulation (EC) No.1005/2008 of 29 September 2008
establishing a Community system to prevent, deter and eliminate
illegal, unreported and unregulated fishing. An explanation hand-
book can be downloaded from http://ec.europa.eu/fisheries/cfp/
external_relations/illegal_fishing/pdf/handbook_ en.pdf21 Adapted from: Best Practice Study of Fish Catch Documenta-
tion Schemes Phase 1 Report, 2009. MRAG Asia Pacific Pty Ltd
for the UK Department of Environment, Food and Rural Affairs
(DEFRA)22 Fishing Vessels Monitoring Systems. Usually satellite based,
see http://www.fao.org/fishery/vms/en23 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:20
09:280:0005:0041:EN:PDF24 For a discussion of the theoretical foundations, institutional and
legal aspects of Eco-Labelling, see, C.R. Wessells et al., Product
certification and Eco-Labelling for fisheries sustainability. FAO
Fisheries Technical Paper 422. Rome. 2001.25 http://www.fao.org/docrep/008/a0116t/a0116t00.htm26 http://www.fao.org/news/story/en/item/45834/icode/27 S. Washington. Eco-labels and Marine Capture Fisheries:
Current Practice and Emerging Issues. GLOBEFISH Research
Programme, Vol. 91. FAO Rome. 2008.28 Macruronus novaezelandiae. See http://en.wikipedia.org/wiki/
Blue_grenadier
EU Market Access & Eco-Labelling l 47
29 Alastair Macfarlane, General Manager, Trade and Information at
New Zealand Seafood Industry Council. Pers comm.30 http://www.greenpeace.org/international/seafood/red-list-of-
species31 For an in-depth vision of the situation of the organic aquaculture
market in Europe refer to: L. Barazi- Yeroulanos. Synthesis of Med-
iterranean marine finfish aquaculture – a marketing and promotion
strategy. Studies and Reviews. General Fisheries Commission for
the Mediterranean. No. 88. FAO Rome. 2010. http://www.fao.org/
docrep/013/i1696e/i1696e.pdf32 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:20
07:189:0001:0023:EN:PDF33 Com Reg. (EC) No.1235/2008 of 8 December 2008 laying
down detailed rules for implementation of Council Regulation (EC)
No. 834/2007 regarding the arrangements for imports of organic
products from third countries. http://eur-lex.europa.eu/LexUriServ/
LexUriServ.do?uri=OJ:L:2008:334:0025:00 52:EN:PDF34 http://www.oecd.org/dataoecd/17/43/43356890.pdf35 Based on the presentation by Peter Hajipieris, Birds Eye Iglo,
“Recent developments in the branding and marketing of fish and
fish products.”36 Specifies general requirements for third-party operating a prod-
uct certification system.37 The ISEAL Alliance is the global association for social and envi-
ronmental standards. http://www. isealalliance.org38 http://assets.panda.org/downloads/full_report_wwf_ecolabel_
study_lowres.pdf39 http://assets.panda.org/downloads/benchmarking_study_wwf_
aquaculture_standards_new_.pdf
BIP Border Inspection Post
CA Competent Authority
EC European Commission
EU European Union
FBO Food Business Operator
FFP Fish and Fishery Products
FVO Food and Veterinary Office
GG GlobalGap
HACCP Hazard Analysis and Critical Control Points
ISO International Standards Organisations
IUU Illegal, Unreported and Unregulated fisheries
MB Member Country
NPC National Control Plan
RASFF Rapid Alert System for Food and Feed
RFMO Regional Fisheries Management Organisation
SPS Sanitary and Phytosanitary (measures)
SMEs Small and Medium Enterprises
9. Glossary.
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