Position Paper: Ethoxyquin and the potential impacts of its withdrawal from use in EU28 on the Fishmeal, Aquaculture and Agriculture industries. Executive Summary Ethoxyquin is a highly effective antioxidant that has been widely used by the fishmeal industry for several decades, and provides important benefits to the sector from both quality and safety perspectives. Roughly 5 million tonnes of fishmeal is produced yearly and more than 66% of that production is treated with ethoxyquin. The producers within the IFFO membership are committed to ensuring that products offered are safe and legal at all times. The potential withdrawal of the option to use ethoxyquin by the industry has serious implications for the supply of the more than 500,000 tonnes of fishmeal annually imported into European countries, impacting safety in shipping and transport, quality of the end product, and costs of production. Recognising the significant impact of any decision that has an effect on the regulation and use of the antioxidant, IFFO has been undertaking trials to evaluate the safety and efficacy of ethoxyquin at reduced levels of inclusion in fishmeal, as well as the efficacy of an alternative antioxidant. The aquaculture industry is dependent on fishmeal supply specifically for its unique nutritional properties and especially as feed for juvenile fish, salmonids and marine finfish, and crustaceans. Any withdrawal would have far reaching effects on the developing aquaculture industry at a time when the European Commission is keen to see development of the sector and decrease the vulnerability associated with a reliance on imported seafood product into EU-28. Page 1 of 31
Transcript
Position Paper: Ethoxyquin and the potential impacts of its withdrawal from use in EU28 on the Fishmeal, Aquaculture and Agriculture industries.
Executive Summary
Ethoxyquin is a highly effective antioxidant that has been widely used by the fishmeal industry for several decades, and provides important benefits to the sector from both quality and safety perspectives. Roughly 5 million tonnes of fishmeal is produced yearly and more than 66% of that production is treated with ethoxyquin. The producers within the IFFO membership are committed to ensuring that products offered are safe and legal at all times. The potential withdrawal of the option to use ethoxyquin by the industry has serious implications for the supply of the more than 500,000 tonnes of fishmeal annually imported into European countries, impacting safety in shipping and transport, quality of the end product, and costs of production. Recognising the significant impact of any decision that has an effect on the regulation and use of the antioxidant, IFFO has been undertaking trials to evaluate the safety and efficacy of ethoxyquin at reduced levels of inclusion in fishmeal, as well as the efficacy of an alternative antioxidant.
The aquaculture industry is dependent on fishmeal supply specifically for its unique nutritional properties and especially as feed for juvenile fish, salmonids and marine finfish, and crustaceans. Any withdrawal would have far reaching effects on the developing aquaculture industry at a time when the European Commission is keen to see development of the sector and decrease the vulnerability associated with a reliance on imported seafood product into EU-28.
This position paper provides details on ethoxyquin use by producers in the global fishmeal industry and summarises the impact that the loss of ethoxyquin will have in Europe. There are very few authorised alternatives to ethoxyquin that can compare in efficacy, and the impacts highlighted include possible effects on human safety in shipping of the raw material, global trade patterns for fishmeal, issues around restricted supply of fishmeal to European feed manufacture, and concerns about optimising and maintaining the quality of a sustainable but finite highly nutritious and efficacious resource.
The next step in the process is to receive the decision from the Standing Committee on Plants, Animals, Food and Feed (SCoPAFF) on the EFSA Opinion, and then review the implications of that decision.
The Issue...................................................................................................................................................... 3
Fishmeal as a Feed Ingredient...........................................................................................................................4
Antioxidants and the Quality of Fishmeal – Optimising the Utilisation of a Finite Resource............................5
Alternatives to Ethoxyquin................................................................................................................................8
Antioxidants and the Shipping of Fishmeal – an Issue of Safety........................................................................8
Assessment of the Impact of the loss of Ethoxyquin as an Antioxidant in Fishmeal......................................10
Annex I World and European Fishmeal Production and Utilisation...............................................................15
Annex II Reference levels for antioxidants in fishmeal.................................................................................18
Annex III Timeline and Process for a Proposed Change to IMO-IMDG Codes................................................19
Annex IV: Annual estimated figures in fishmeal industry with particular relevance to the EEA.....................20
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The Issue
Ethoxyquin is a highly effective antioxidant that is widely used by the global fishmeal industry, conferring both product quality and safety advantages. Ethoxyquin has been used as an effective antioxidant in animal feed for several decades, and as noted by Błaszczyk, Augustyniak, & Skolimowski (2013), there are yet to be alternative antioxidants that are as effective. Those authors also note that the compound’s presence at approved doses should not be hazardous. More recently, there has been some increased negative publicity in the EU on the use of ethoxyquin in fish feed drawing from its use in animal feed. Ethoxyquin has also been used as a fungicide to prevent the development of blight or scald on pears but its use for this purpose has not been authorised within the EU. By association, it appears that ethoxyquin’s presence in food via the animal feed chain is controversial. The reasoned opinion by EFSA on the use of ethoxyquin as a pesticide and the Maximum Residue Limits (MRL) for the compound was published in 20131, although the list of MRLs did not include fish. This document included a consumer risk assessment, which identified potential risks to consumers and acknowledged a requirement for more data on which to make a decision. A follow up opinion by EFSA in 20152 on its use in animal feed has indicated that there remain gaps in knowledge of the risk to animal, consumer and environmental safety, and the Opinion is inconclusive in relation to the substance’s use including its use as a feed additive in EU-28. Any potential loss of availability of ethoxyquin to the fishmeal industry carries significant negative socio-economic impacts, which need to be understood as direct consequences of that decision. This paper explores those impacts directly and indirectly on the fishmeal industry, potential patterns of trade for a globally traded product that supports agriculture and aquaculture and hence makes a significant contribution to European and global food security.
Fishmeal is a brown powder generally containing 8 -10 % fat and is obtained after cooking, pressing, drying and milling of fresh raw fish and/or food fish trimmings. The world fishmeal production is on average 5,000,000 tonnes per year except in years when the fishing in the South Pacific is disrupted by the warm waters of an El Niño event. Fishmeal contains typically 60% to 72% protein, 10% to 20% ash and 5% to 12% fat, which is high in the health promoting omega-3 very long chain polyunsaturated fatty acids EPA and DHA, often referred to as 'omega-3s' (producers can supply details of the type of raw material used and expected nutrient content). Fishmeal is a highly digestible ingredient of high nutritional value, and its use in livestock feeds can offer cost-effective production, optimising health or meat quality in the final product. A significant and increasing proportion (currently calculated at 30% of the total) comes from the trimmings of product caught in capture fisheries and fish silage, therefore adding value to what was previously regarded as a waste stream aligning with the European Commission’s version of a “Circular Economy”.
The predominant use for fishmeal is as a highly nutritious, high value animal feed and it is widely used as a feed ingredient for aquaculture, pigs and chickens. The world fishmeal usage is shown in Fig. 1.1 in Annex I with aquaculture markedly the main user of fishmeal. Approximately 5 MT of fishmeal is produced annually, and this supports global agriculture and aquaculture production and world food supply. The majority of fishmeal (> 68%) in 2014 was used for aquaculture followed by pig and then poultry feed. A breakdown of the aquaculture industry is shown in Fig. 1.2, Annex I where it is clear that crustacean (e.g. shrimp) and salmon farming followed by marine fish farming are the major consumers of fishmeal. Although it is a minor proportion of global production, fishmeal is also an essential component in high protein diets for juvenile fish and crustaceans, where use of the product is increasing. The juvenile production and the supply of juvenile aquatic animals for the growing aquaculture industry is of high importance to overall aquaculture production, and so fishmeal’s use in these products is essential.
Global fishmeal supply, broken down by producing country, is shown in Table 1.1 in Annex I. The total amount of fishmeal being internationally traded yearly is around 3.3 million tonnes (depending on production volumes) with the majority intended for aquaculture. Peru and Chile, as well as Scandinavia, are major producers and exporters of fishmeal who generally, due to their locations, have to ship fishmeal to customers at locations all around the world.
The EU, together with the EEA states, imports and trades in excess of 550,000 tonnes of fishmeal annually mainly for use in aquaculture. As can be seen in Table 1.1 in Annex I, four EEA countries are in the top 12 world importers of fishmeal and Norway and Germany are the 3 rd and 4th largest importers, respectively.
Within agriculture in EU-28 and EEA states approximately 250,000 tonnes of fishmeal is used annually, and mostly goes for specialist diets for both pigs and poultry. Most notably the weaning of young pigs requires special diets high in digestible protein and low in the anti-nutritional factors that are often found in plant proteins. Fishmeal is often used in these diets to provide the young pigs with the best possible start through optimal nutrition ensuring healthy fast growing pigs, and so it is a strategically important ingredient.
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Around 800,000 tonnes of fishmeal is used annually in animal feeds in Europe (including EAA countries) with aquaculture taking over 60% (see Annex I Fig. 1.3) and within aquaculture the majority of the fishmeal is used for salmon and trout production (75%) with most of the remainder used for marine fish (20%) production, largely based in the Mediterranean (see Fig. 1.4 Annex I).
Europe (including EEA states) produced 2.341 million tonnes of farmed finfish in 2014 (Source: FEAP3), of which a very high percentage (>95%) would be farmed fish fed on commercially manufactured diets containing fishmeal at some level of incorporation. European aquaculture is the 8th largest in the world (Source: DG MARE4) and production represents some 1.53% of total world aquaculture. The European Commission supports aquaculture development under Common Fisheries Policy Reform5 and the Blue Growth6 agenda, and with an increasing focus on the growth and development of aquaculture in the EU the volume is set to increase. Aquaculture is the fastest growing protein sector globally, developing at a rate of 5.8 per cent in 2013 (Source: FAO7), and so makes a key contribution to food security. Norway was the world’s 6th largest producer of fish and crustaceans in 2013 and along with the UK their share of the world’s aquaculture production of fish and crustaceans in 2013 was 2.63% which amounts to 1,413,000 mt. Much of this production is fed aquaculture, and is dependent on the supply of fishmeal for the manufacture of aquaculture diets.
Fishmeal is added to fish feed at levels generally within the range 5 –50% in contemporary commercial feeds, where the unique nutritional properties of fishmeal and fish oil result in a constant demand for these products in aquaculture. The growth of global aquaculture has meant that the fish feed industry has had to use increasing volumes of plant proteins such as soymeal in substitution for fishmeal. Overall the picture for global aquaculture feed is one of declining fishmeal inclusion rates, as predicted by Tacon, Hasan, & Metian, in 2011. For example, the fishmeal inclusion rate in salmon feed has decreased from around 65% in 1990 to 16% (and declining) in 2015, and that reduction is mirrored in the inclusion rates for fishmeal in a range of diets for other farmed fish species. This decrease has led to subsequent diminishing levels of ethoxyquin in the final feed. Taking into account that 100mg/kg of ethoxyquin should be present at time of shipping then it can be calculated that the ethoxyquin levels in the final feed has decreased from roughly 65 mg/kg in 1990 to 10 mg/kg feed in 2015, i.e. from 65g tonne -1 aquaculture feed to 10g tonne-1 aquaculture feed. It is also worth noting, however, that in addition to any ethoxyquin in the feed from the included fishmeal there is also often a contribution from the carry-over from the added vitamins.
Antioxidants and the Quality of Fishmeal – Optimising the Utilisation of a Finite Resource
Fishmeal varies slightly in composition depending on the raw material used (e.g. small pelagics like anchovy, sardine, capelin, blue whiting and menhaden or fish from by-products of the fish processing industry). Fishmeal made from anchovy, sardine and menhaden tends to be extremely reactive because of high levels of highly polyunsaturated fatty acids (PUFAs). These types of
fishmeal require a very effective antioxidant to prevent oxidation of the fatty acids. Fishmeal that is less reactive (containing lower levels of PUFAs) such as sandeel or blue whiting meal and meal made from white-fish by-products may be stabilised with a less effective antioxidant. Based on the types, production and source regions of fishmeal IFFO estimates that more than 66% is treated with ethoxyquin per year.
The PUFAs found in fishmeal are highly valuable and of great benefit to society. Because of its high omega-3 content fishmeal is a 'functional feed' providing health and welfare benefits to livestock. The health benefits of omega-3 oil consumption have been well documented (Pike, 1999; Berge, Musa-Veloso, Harwood, Hoem, & Burri, 2014; WHO, 2010) and continuing research effort provides an expanding evidence base for those benefits. Meat, fish and egg products from farmed animals fed high omega-3 fishmeal are functional foods which benefit human health. Although there are some developments in the production of omega-3 oils through mechanisms such as genetic modification of plants (Usher, Haslam, Ruiz-Lopez, Sayanova, & Napier, 2015; Betancor et al., 2015) or the farming of marine algae ( Tacon, Metian, & Hasan, 2009), annual supply of omega-3 oils at this stage is a finite resource obtained from reduction fisheries, and increasingly from trimmings. Additionally, due to changing rules on discards and the new Landing Obligations for European fisheries8, there is likely to be an increasing volume of whole fish that will be landed and may be utilised in fishmeal production. In order to extract maximum benefit to society from the annual production of these compounds it is essential that the risk of degradation (particularly oxidation) be managed, and the quality of the product maintained.
The reactive nature of fishmeal that contains PUFAs results in a material that carries the risk of self-heating, which may ultimately lead to spontaneous combustion9. This is clearly a safety issue for a product that is traded globally through major shipping routes. Mitigation of that risk since the 1950s10 has been through the addition of effective antioxidants which stabilise the product. The most effective antioxidant to protect reactive fishmeal against spontaneous combustion has proven to be ethoxyquin, and the compound has become the mainstay of the fishmeal industry for decades. Since the treatment of reactive fishmeal with ethoxyquin there have been no more incidents of spontaneous combustion during shipping of fishmeal (see section on shipping).
A recent survey by IFFO of their members worldwide11 indicated that the majority of fishmeal producers still use ethoxyquin as the safest option to protect fishmeal against oxidation. The main antioxidant in use for fishmeal is ethoxyquin with over 80% of respondents dosing with ethoxyquin (Figure 1). Many producers use mainly ethoxyquin but do treat fishmeal with alternative antioxidants on request when a combination or singular use of BHT and BHA is most often used. It appears that mainly Asian countries such as Thailand and India use BHT/BHA mixtures (or also in Europe for specialist requirements), whereas countries from South America predominantly use ethoxyquin and only a minor sector use BHT or other antioxidants as necessary. The use of the more effective ethoxyquin by South American countries is due to the highly reactive fishmeal made from anchovy (reflecting higher levels of PUFAs in that species) and the long shipping time, in contrast to countries in Thailand and India where the fishmeal is not as reactive (often made from by-products) and shipping times generally shorter. Although ethoxyquin is also used to stabilise trimmings, its
8 https://stecf.jrc.ec.europa.eu/reports/discards 9 Van den Broek, C.J.H, Spontaneous Heating of Fishmeal, Food Manufacture, Sept/Oct 1959 10 Meade, T. L., A New Development in Fishmeal Processing, Feedstuffs, May 19, 1956
11 IFFO represents the marine ingredients industry worldwide. IFFO’s members reside in more than 60 countries, account for over 50% of world production and 75% of the fishmeal and fish oil traded worldwide.
inclusion rate is often lower at c. 50-100 mg kg-1, given the lower fat (and lower PUFA) content of that material, but ethoxyquin is regarded as essential at the current time for the management of this resource.
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Figure 1: The percentage of fishmeal factories using different antioxidants (note many factories use a variety of antioxidants)
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A minority of producers use alternative antioxidants, such as a mix of tocopherols and rosemary extract or tocopherols with or without gallates. Alternatives to ethoxyquin are mainly used in fish hydrolysates as well as in products intended for the petfood market or organic aquaculture.
The dosage levels of ethoxyquin varies according to the product, reactive fishmeal with high levels of PUFAs, such as anchovy from South America, requires higher dosage levels of ethoxyquin to ensure that the meal has been stabilised, particularly for the long trade routes from that part of the globe. Fishmeal made from by-products or from fish species originating from the North Atlantic Ocean that contains lower levels of PUFAs, requires less ethoxyquin to stabilise the oil in the fishmeal.
Interrogating the RASFF12 (Rapid Alert System for Food and Feed) web portal of the European Commission for alerts caused by ethoxyquin, shows there to have been 4 incidences of the exceedance of MRLs for this compound including corn (as feed material) from France, and pears from Italy, chilli powder from the US and farmed Atlantic salmon from Chile (as food items) over the period 2005-2015, but needs to be taken in context of the level of trade of these products into the EU. The residue of ethoxyquin in the salmon sample is quoted as 0.04 mg kg -1 although fish are not listed in the current MRL values record produced by the European Commission13. Lundebye, Hove, Måge, Bohne, & Hamre, 2010, analysed the antioxidant content of fishmeal, fish oil, fish feed, and farmed salmon, trout, halibut and cod fillets, reporting respective maximum ethoxyquin values of
343 mg kg-1, 107 mg kg-1, 116 mg kg-1, 167 µg kg-1, 65 µg kg-1, 25 µg kg-1, 11.9 µg kg-1. Mean values were quoted at levels well below these (see Annex II Table 2.1).
Alternatives to Ethoxyquin
In consideration of alternatives to ethoxyquin it is important to understand that the application of other options may not be as straightforward as a “like for like” replacement. Those alternatives that do exist do not possess the same characteristics as ethoxyquin and substitution may carry some issues around use and the practicalities of treatment of fishmeal. The dosage levels of the alternative antioxidants used by the fishmeal industry are shown in Table 2. The efficacy of the alternative antioxidants is generally not as good as ethoxyquin and this is reflected in the overall higher dosage levels in the fishmeal. This has implications around operational processes, for product quality, risk associated with the end product and cost. In addition, the higher dosage levels of a synthetic antioxidant may result in higher levels being transferred to the feed, fish and ultimately the consumer, in turn potentially creating another issue of concern.
Table 2: Dosage levels of alternative antioxidants (ppm)BHA and BHT
singly or in combination(ppm)
Rosemary extract and tocopherols mixtures
(ppm)
Mixed tocopherols with or without gallates
(ppm)
100-3000 300-3500 300-1500
There are likely to be cost implications for the fishmeal sector of moving to these alternatives. Current price data indicates approximate antioxidant market prices for ethoxyquin of c.US$ 5.00, for BHT of c.US$ 43.00; for tocopherol liquid of c.US$ 145.00 all tonne -1 fishmeal treated. Taking into account average fishmeal prices in 2015 of c. US$1,700 per tonne (IFFO data), those figures represent additional costs of 2.52% and 8.53% per tonne fishmeal delivered. Price increases in the cost of production are very likely be carried over to the feed manufacturers, and then ultimately to the aquaculture and agriculture industries, increasing costs of production at a time when improved efficiencies in production is a goal of the European Commission and the FAO in the context of European and global food security.
IFFO is aware that there is an application for authorisation of another feed antioxidant, Tertiary Buthylhydroquinone (TBHQ), which dates back to 2013. The proposed use is for “all animal species” and so if successful, could potentially include use in fishmeal and aquaculture feeds.
Antioxidants and the Shipping of Fishmeal – an Issue of Safety
As noted above, fishmeal is very susceptible to oxidation due to the highly unsaturated nature of the fats and oils present in the product. When oxidation occurs, it can result in self-heating and even spontaneous combustion during long term storage or transport, reflecting a very serious safety concern for the shipping of the product which occurs across the globe. In the past, before the introduction of ethoxyquin, bulk transport of fishmeal has proven hazardous and fishmeal had to be
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allowed to fully oxidise prior to transport and even then the risk of spontaneous combustion had to be very carefully managed, but as already noted, that is not an efficient way of maintaining the nutritional quality of the product.
Fishmeal heats up to the point of fire due to aerial oxidation of reactive chemical sites on fish oil molecules. All oxidation reactions are associated with the production of heat. There have been some historical examples of the impact of not managing the risk of oxidation of fishmeal during shipping transport appropriately. In 1982 there was a series of incidents involving serious heating, sometimes to the point of fire, in fishmeal cargoes shipped from Chile on various long ocean voyages. In 1987 similar problems were encountered with fishmeal loaded at Peruvian ports. The implications of ineffective management of the risk of spontaneous combustion in fishmeal during transport at sea are serious, and could lead to loss of life.
Risk of oxidation of fishmeal is managed through the treatment of the product with an antioxidant after production. Ethoxyquin has been proven to be highly effective, more so in fact than any other synthetic antioxidant, and has been used extensively by fishmeal manufacturers to ensure safe transport of the product between destinations across many thousands of miles of sea. Because of the effectiveness of ethoxyquin lower levels than other antioxidants can be added to fishmeal, which result in lower levels in feed and ultimately less residual levels in the fish, shrimps or animal meat intended for human consumption.
Strict rules regarding safe transport of fishmeal have been put in place by the International Maritime Organisation (IMO) in the International Maritime Dangerous Goods Code (IMDG) and the International Maritime Solid Bulk Cargoes Code (IMSBC). Ensuring the safe transport of potentially hazardous cargo is essential and fishmeal (product code UN 2216) that has been treated with antioxidant is classified under Group B with a Class 9 Hazard Class Definition (Miscellaneous Hazardous Material) in the IMDG code. Requirements regarding the shipping of fishmeal under Group B are that the following concentrations of antioxidant must be added at the time of production:
between 400 and 1000 mg/kg (ppm) ethoxyquin, or between 1000 and 4000 mg/kg (ppm) butylated hydroxy toluene (BHT)
Dosage must be done within 12 months prior to shipment and the antioxidant content must be more than 100 mg/kg (ppm) at the time of shipment.
Fishmeal cannot be shipped without complying with the IMO codes. Any change to the regulation of the use of ethoxyquin therefore has marked implications for the global trade of this product. In order to change the IMO codes, the United Nations Transport for Dangerous Good (UN-TDG) committee of Experts first needs to change the UN Model Regulations for Dangerous Goods. The IMO subsequently base their IMDG and IMSBC codes on the UN Model Regulations. The timelines to change IMO codes and a flow chart summarising the process is shown in Annex III. The quickest possible change in the IMO codes would be 2020, so there is a long lead time. Any change proposed to the regulations needs to take this timescale into account, as well as the associated impacts on the risk to human life in managing the risks of oxidation of the shipped product.
IFFO realises the importance of the accessibility of ethoxyquin to the industry and also the urgency of verifying the use of alternatives to ethoxyquin should it not be re-authorised. Any proposed change to the United Nations Transport for Dangerous Goods Model Regulations and subsequently
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in the IMO codes for Dangerous Goods needs to be supported by good scientific data. IFFO is in the process of conducting fishmeal stability trials where the data could be presented to the UN TDG and IMO thereby resulting in the inclusion of the alternative antioxidant into the IMO shipping codes.
Trials will be performed with a reactive fishmeal such as anchovy meal produced at a selected factory. Samples will be treated with two different levels of ethoxyquin, the current level and a dosage level less than the current minimum dosage level of 400 mg/kg to determine if a lower concentration of ethoxyquin will effectively protect the fishmeal. In addition, fishmeal will be treated with a synthetic (BHT) and an alternative antioxidant (a blend of tocopherols and rosemary extract) to investigate the efficacy of possible alternative antioxidant options.
Assessment of the Impact of the loss of Ethoxyquin as an Antioxidant in Fishmeal
The use of impact assessment tools to evaluate likely costs and benefits and the associated risks of a proposal on the public, business or civil society organisations is becoming commonplace in national government (e.g. the UK14), and the European Commission15. Broadly, the process includes stages of appraisal, monitoring, evaluation and feedback when a change of policy is being proposed. With this issue, we are essentially at the appraisal stage when looking at the impact of the loss of ethoxyquin to the fishmeal industry, as we wait for the European Commission to pronounce on the EFSA Opinion. The following provides additional information in establishing that appraisal.
The economic importance and relevance of the role of ethoxyquin in fishmeal production is evident when it is understood that approximately 66% of world fishmeal production uses ethoxyquin as an antioxidant and approximately 50% has to use it for safe shipping. The figures are estimates drawn from IFFO data encompassing the calculation of the fishmeal treated with ethoxyquin and is based on countries that produce highly reactive fishmeal that requires an effective antioxidant such as ethoxyquin. A summary of the estimated fishmeal production and value data is provided in Table 3, along with important annual estimated figures in the fishmeal industry with particular relevance to the EEA in Annex IV. Most countries have to adhere to the IMO regulations for shipping purposes which requires that fishmeal is treated with an antioxidant to ensure safe transport of fishmeal during shipping. As we have noted above, as well as the managing the safety of transport of the product, antioxidants also maintain the quality of the product during transport and in storage.
Table 3: Estimated fishmeal production and value for 2013
Fishmeal production in 2013 (000 tonnes)
Fishmeal value in € million at current price
(€ 2,000/tonnes)Total fishmeal production 4,675.0 9,350Fishmeal production of reactive fishmeal that generally uses ethoxyquin for stabilisation1 2,425.4 4,850
Fishmeal imported/traded in EU-28 & EEA states2 560 1,1201) From the following countries Peru, Chile, USA, Denmark, Ecuador, Mexico, Iceland, Norway, Brazil, Panama, South
Africa2) Main EEA fishmeal importers: Norway, Denmark, UK, Italy, Spain, France, Germany, Netherlands
The uncertainty around the re-authorisation of alternative antioxidants such as BHT, BHA and propyl gallate leaves the industry without a viable alternative. The only other antioxidants that are currently authorised for use in feed are:
None of these alternatives will provide effective protection for reactive fishmeal during long shipping or storage periods. Without an effective antioxidant to protect reactive fishmeal the trade in fishmeal will be affected and potentially collapse.
IFFO has constructed a scenario tree summarising the potential (hypothetical) outcomes of the process, and this is represented below in Fig. 2.
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Fig.2. Scenario tree representation for outcomes within the ethoxyquin reauthorisation process
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This representation indicates several key points in the process, including a phase-out period if ethoxyquin is banned, an assessment of the efficacy of alternatives, and application to the IMO for a change to the shipping regulations. All have impacts. For all these processes the timescale is unknown, and the full impact difficult to quantify, but it is clear that there will be an impact on fishmeal producers’ businesses, and several consequential impacts through the supply chain, ultimately to the consumer and to communities involved in the seafood industry.
Those additional impact scenarios may be envisaged to include the following:
1. There could be a change in the pattern of global trade in fishmeal which is redirected towards those countries that do not maintain the same regulations on the inclusion of ethoxyquin in animal feeds or animal feed ingredients. (One possibility, for example, is that China and other countries in South East Asia may take an increased quantity of global production, and especially the high PUFA fishmeals produced in South America.) This scenario could have an effect on the supply and cost of fishmeal into the EU, with a subsequent effect on animal feed manufacture and aquaculture and agriculture production.
2. The effect of a reduction on fishmeal supply would be a likely reduction in the availability of manufactured animal feeds in Europe. When looked at from the context of aquaculture feed supply and aquaculture development, it is clear that this could be a restriction on European aquaculture production, at a time when the European Commission is seeking to grow the sector. Equally agriculture could be affected where fishmeal is used in feeds for juvenile pig and poultry.
3. A reduction in aquaculture growth, has several associated implications:a. Reduction in investment in the sector (development is constrained in the longer
term);b. Job losses (many of which are in remote areas or coastal communities), in direct
contravention of the aims of the Blue Growth agenda;c. The sustainability of businesses upstream (e.g. equipment manufacture, juvenile
supply) and downstream (e.g. processing sector, retail) of the European aquaculture industry.
d. A reduction in the availability of nutritious European seafood products, and especially those containing a high level of PUFAs.
e. An increased reliance, and hence vulnerability, on the importation of seafood products into the EU. The EU is regarded as providing some 45% of its seafood requirements16, although that figure is based on domestic production not taking into account exports of EU product. DG MARE estimates that the EU imports 64% of total seafood requirements per annum (D. Dubolino Pers. Comm.).
Summary
The proposed change to the regulations governing the use of ethoxyquin, and the implications for the additional impact on the fishmeal industry (including implications for safety and product quality) as well as the farming industry are far reaching. The production cost of fishmeal would increase
markedly if alternative antioxidants are used which would negatively affect the aquaculture industry in the EEA along with the likely re-routing of fishmeal to alternative destinations. The analysis therefore shows that prohibiting the use of ethoxyquin will have very important socio-economic impacts for EU-28 and EEA states, their economies, food security and societal health, at a time when these are of paramount importance. In addition, the safe shipping of fishmeal will be compromised by forcing the industry to use less effective alternative antioxidants for long haul shipping.
The health and safety of animals and consumers is without contention the most important consideration however a decision at this stage that takes an over-precautionary approach based on a current lack of data and scientific evidence for the risks associated with ethoxyquin has far-reaching, and possibly unanticipated (by decision-makers) effects on industry and European society.
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Usher, S., Haslam, R. P., Ruiz-Lopez, N., Sayanova, O., & Napier, J. A. (2015). Field trial evaluation of the accumulation of omega-3 long chain polyunsaturated fatty acids in transgenic Camelina sativa: Making fish oil substitutes in plants. Metabolic Engineering Communications, 2, 93–98. http://doi.org/10.1016/j.meteno.2015.04.002
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Annex I World and European Fishmeal Production and Utilisation
Figure 1.1: World Fishmeal Usage by market ('000 tonnes) (sourced: IFFO)
a Samples taken over 2005. 2006, 2007; lower concentrations observed predominantly in 2007; Samples taken according to the Norwegian Food Safety Authority’s annual sampling plan; fish were sampled from fish processing plants.
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Annex III Timeline and Process for a Proposed Change to IMO-IMDG Codes
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UN-TDG meetingDec 2015
Preparing 20th Model Regulations
UN-TDG meetingJune 2016
Preparing 20th Model Regulations
UN-TDG and ECOSOC TDG meetingsDec 2016
Finalising and adoption of 20th revision of Model Regulations
IMO meetings in 2017 to harmonise with 20th revision of UN Model Regulations, to prepare and agree amendment 39-18 of the IMDG Code
Amendment 39-18 of the IMDG Code adopted at IMO (MSC) in May/June 2018
Amendment 39-18 of the IMDG Code comes into force on voluntary basis 1st January 2019
IMO IMDG Code Mandatory 1st January 2020
Annex IV: Annual estimated figures in fishmeal industry with particular relevance to the EEA
Fishmeal yearly contribution Values
Fishmeal production worldwide 5,000,000 tons
Fishmeal traded internationally 3,300,000 tons
Fishmeal imported and traded in EU-28 & EEA >550,000 tons
Value of fishmeal imported into EEA (at €1 820/mt) € 1.05bn
EEA countries in top 12 world fishmeal importers Norway, Germany, Denmark, UK
Fishmeal used in animal feed in EEA 800,000 tons
Aquaculture
Fishmeal used in aquaculture in EAA >480,000 tons
Fishmeal used in salmon and trout farming in EEA >360,000 tons
Farmed finfish in EEA 2,341,000 tons
Farmed fish fed on commercially manufactured diets containing fishmeal >2,224,000 tons
EEA ranking in world aquaculture 8th
Growth rate aquaculture (2013) 5.8%
EEA countries with high ranking in world aquaculture production Norway 6th largest in world
Norway and UK share of world aquacultures production 2.63% ≈ 1,413,000 tons
Fishmeal addition to feed 5 – 30%
Agriculture
Fishmeal used in pig and poultry feed 250,000 tons
Antioxidant use
Fishmeal producers that use ethoxyquin (IFFO survey) >80%
Estimated amount of fishmeal treated with ethoxyquin >333,000 tons
Fishmeal shipped that has been treated with ethoxyquin >250,000 tons
Value of fishmeal shipped with ethoxyquin (F.O.B. average fishmeal prices at 1,940 US$/mt) 4,85 x 108 USD
