25
Where’s the Catch? The Reputational Risk of IUU from Discards Seafish Discard Action Group 18 th July 2017
Where’s the Catch?
The Reputational Risk of IUU from Discards Seafish Discard Action Group
18th July 2017
Contents
1. Background – a new era of risk management 2. The Issue – IUU discarding, a new risk 3. The Role of the Market – advocacy for brand
protection
Background
A new era of risk management
2013 – a paradigm shift for food brands
• During the early part of 2013, confidence in the food manufacturing industry across Europe was rocked by the discovery of widespread substitution of beef with horse meat
• Major retailers and food brands across a number of different countries became implicated
• The consequences for food brands were profound - not just in the red meat industry but for all foodstuffs including seafood
Food Fraud – now a major brand focus
• Once lost, consumer confidence is not easily regained – Findus Beef Lasagna has never returned to the
UK supermarket shelves! • Brands have increased their efforts to
identify and eliminate the risk of deliberate criminal acts in upstream food supply chains
• IUU is now widely considered in the UK to be a form of ’Food Fraud’
Seafish Guide – Provenance & Authenticity 1. Species substitution 2. Fishery substitution 3. IUU substitution 4. Species adulteration 5. Chain of custody abuse 6. Catch method fraud 7. Undeclared product extension (dilution) 8. Fresh v frozen 9. Official documentation fraud in third countries 10.Quality Enhancement Treatments 11.Durability indication alteration
Horizon scanning and risk mitigation
• Since the horsemeat scandal, the food industry has been working to increase its resilience to risk
• New horizon scanning tools have been developed to identify risks before they become reputational issues – including seafood specific tools created by Seafish
• The UK seafood industry has been pro-active in recognising the reputational risk of IUU discarding
The Issue
IUU Discarding – a new risk
IUU discarding
• After a decade of hard work in legitimising fishing effort, it seemed that the dark legacy of wanton overfishing and black market fish landings had become a thing of the past.
• But, because of implementation challenges of the LO in some sectors, there is a tacit understanding that some vessels are continuing to discard despite the introduction of the discard ban.
• There is already evidence that this is the case in some trawl fisheries!
• Continued unaccounted mortality from discarding against quotas (which have actually been increased to account for the LO) will lead to overfishing.
Recent reports on IUU discard risk
During the latter half of 2016, TWO independent reports indicated the risk of IUU discarding in EU fisheries: 1. ‘Assessing the Implications of the Landing
Obligation on MSC Certified Fisheries in Europe’ by Rob Blyth-Skyrme and Lisa Borges
2. ‘Scheveningen Control Expert Group Report on the Control and Monitoring of the Demersal Landings Obligation’
Report conclusions
• The Blyth-Skyrme/Borges report: concluded that in the event of weak LO implementation, EU demersal trawl fisheries appear to be at particular risk of failing MSC assessment.
• The Scheveningen Control Expert Group: of the 12 North Sea trawl fisheries assessed, 4 were considered to represent a ‘High or Very High’ risk of illegal discarding
Other indicators of risk
• European Fisheries Control Agency • ICES estimates of unaccounted mortality • Landings into the fishmeal channel
What is the European Fisheries Control Agency? • The European Fisheries Control Agency’s objective
is to organise operational coordination of fisheries control and inspection activities by the Member States and to assist them to cooperate so as to comply with the rules of the CFP
• The European Fisheries Control Agency has a key role in coordinating the implementation of the discard ban
European Fisheries Control Agency
• At the SFP Landings Obligation workshop in Vigo (May 2017), Miguel Nuevo of EFCA reported that; based on the agency’s last haul inspections in the Baltic Sea, “there appeared to be a problem in reporting discards”
• Out of 5 demersal fishing gear groups assessed by EFCA in different areas of the Baltic Sea, 2 were considered to be “high risk” of illegal discarding and one “medium risk” (2 were “low risk”)
• Miguel Nuevo also stated that in his opinion, the North Sea would represent greater challenges to LO implementation than in the Baltic
EFCA Report on Baltic Cod
• “Landings of fish below the minimum conservation reference size (MCRS, 35 cm) are very low and discarding still takes place despite the fact that the landing obligation has been in place since 2015.“
• “The discard rate in 2016, with the present MCRS, was estimated at approximately 10% based on observer data; however, there have been problems gaining observer access in some countries and the 10% figure is considered to be an underestimate.”
• It is increasingly likely that Baltic cod will be downgraded in fishery sustainability rating systems because of the incidence of illegal discarding.
2017 ICES Advice Eastern Baltic Cod
Cod (Gadus morhua) in subdivisions 24–32, eastern Baltic stock (eastern Baltic Sea), 8th June 2017
Fishmeal • Fish landed below the MCRS must only be used in
industries outside of direct human consumption markets, such as fishmeal, fish oil, pet food, food additives, pharmaceuticals and cosmetics
• Since the introduction of the LO, there has been minimal volume sold into the fishmeal sector in Aberdeen (serviced by Fraserburgh and Peterhead) and zero volume into Grimsby (serviced by all English ports)
• The low uptake of product into fishmeal production in both Aberdeen and Grimsby fishmeal plants cannot be viewed as absolute evidence that discarding is continuing, but taken as a proxy, it may be considered a robust indicator
The Role of the Market
Advocacy for brand protection
The dilemma
• An effective and properly executed CFP is essential to ensure the biological and economic sustainability of European fisheries
• Fully documenting fisheries is an essential tool for successful fisheries management and necessary for the attainment of Bmsy
• Ignoring illegality because it is inconvenient and problematic is wrong, and...
• Failing to properly document extractions from the resource should not be sacrificed because there are implementation challenges in some fleet sectors
The market consequences
• For the first time in many years, the market faces the very real prospect that some EU fishery products in their supply chains are likely to be sourced from vessels that are fishing illegally
• Illegal discarding within certified sustainable fisheries threatens the viability and reputation of consumer facing sustainability schemes
The market response to risk
• Seafood brands and retailers will inevitably face NGO and media questions about alleged illegality (IUU) in their upstream supply chains due to the risk of illegal discarding
• Do their current policies and risk analysis tools adequately protect them from this risk?
• How can the influence of the buyers be brought to bear on the Member States to protect fishermen from this dilemma, and protect their own brand integrity?
Recent market measures in the UK • In October 2016 - on seeing the Scheveningen Control
Expert Group report, seafood brands and retailers wrote a private letter to the DEFRA Minister responsible for fisheries, urging action on transparent actions to prevent IUU discarding in UK fisheries
• In May 2017 – a wider coalition of retailers and processors aligned on the issue of IUU discarding through the trade federations BRC (retail) and PTF/FDF Seafood Industry Alliance (processing). A joint positioning has been agreed
• Retailers and brand owners have been contacting their upstream fishery supply chains to seek assurances of no IUU discarding
The BRC/SIA Joint Position Statement (extract)
• Effective implementation of current legislation… is essential to ensure the continued biological and economic sustainability of European fisheries including those MSC certified fisheries
• Fully documenting fisheries is an essential tool for successful fisheries management and the attainment of healthy fish stocks
• Failing to properly document and account for catches should not be sacrificed because there are implementation challenges in some fleet sectors
The BRC/SIA joint position supports 5 initiatives
“In order to address this we are willing to support initiatives that will be necessary to support this outcome.” These include:
1. Increased selectivity in fishing activities both in terms of fishing practice and gear development
2. Comprehensive and cost-effective monitoring and enforcement of measures
3. Innovation in access to quota – including the creation of new, more flexible quota trading platforms.
4. Incentivising innovation in fishing practices to address potential choke situations.
Legal Sourcing - no compromise
• The market requires that there is no illegal practice in up-stream supply chains - we will continue with our efforts to ensure that all seafood is sourced from fully documented, legal sources
• The market recognises the urgent need for practical actions to be taken in order to prevent the loss of buyer access to EU catches on the basis of a failure of legal compliance
