The European Commission has opened a public consultation to review its policy on food promotion – including for seafood - inside and outside the EU, with a view to “enhance its contribution towards the promotion of more sustainable production and consumption, […] in line with the Farm to Fork and Biodiversity strategies.”
The European average consumer has increasingly shown interest regarding the sustainability of the food he buys. On the other hand, he remains one of the highest seafood consumers in the world, with the global consumption of fish and seafood having more than doubled in the past 50 years. In a context of overexploitation of many fish resources, the promotion of seafood consumption, whether from aquaculture or wild caught fisheries, risks placing impossible demands on the supply chain to get increasing quantities of seafood to the consumer from sustainable sources.
In our view, in order to remain coherent with all its strategies and policies, the EU should not promote more seafood consumption as it will lead to consumption levels that entail unsustainable seafood production.
1. The European consumer and food sustainability
The public consultation, launched since the end of March, openly states that the EU aims at reducing red and processed meat consumption and shift to a more plant-based diet. In September 2020, the Food Policy Coalition, underscored that the EU’s Farm to Fork strategy largely ignored seafood production and reminded that wild-caught fisheries and aquaculture are key drivers of global biodiversity loss, while at the same time they should be taken into account as essential elements for a sustainable food system.
With little mention of seafood in this public consultation, the concern is that the Commission omits yet again to take into account the sustainability issues of fish and seafood consumption. In fact, with an estimated of 24.35kg/year/per capita, Europeans are the second seafood consumers in the world after Asians. The Commission has the obligation to support a responsible consumption, and therefore should focus on providing complete and accurate information to the consumer about the seafood sold on EU markets, rather than promoting seafood consumption, in line with the objective stipulated for the common market organisation for fishery and aquaculture products, which “should enable consumers to make better informed choices and support responsible consumption.” (see §57 of the preamble of the Regulation 1380/2013).
2. Global wild-caught fisheries: increasing overfished stocks
In its latest report on the State of World Fisheries and Aquaculture (2020), FAO classified 34.2% of the world fish stocks as overfished, a percentage that keeps growing yearly. The European Union and its members states have carried out laudable efforts for the recovery of certain stocks in Community waters, though big concerns remain with stocks in the Mediterranean and the Black Sea.
Global trends in the state of the world’s marine fish stocks from 1974 to 2017. Source: SOFIA 2020, FAO.
Given the current quantities of fish consumed in Europe, the EU is forced to import large quantities of fish from third countries –including farmed fish which is fed with fishmeal and fish oil processed from wild-caught fish.
As a net importer, the EU needs to consider the sustainability of the practices of its seafood trade partners, and in parallel, seriously question the sustainability of European seafood consumption. In its paper, the Food Policy Coalition stated that the EU’s F2F strategy should go further than regulating seafood imports, and that “measures are needed to reduce the overall consumption of such products.”
3. Aquaculture products and the false narrative of sustainability
Sustainability concerns of global wild fish production have been repeatedly raised by NGOs, scientists, decision makers, journalists, and some have presented fish farming as an alternative. The narrative is that with a growing world population, fisheries will not meet the demand and farmed-fish will provide the solution. In 2014, for the first time in history humans consumed more farmed-fish than wild-caught fish. According to EUMOFA, even though the apparent consumption of seafood per capita in Europe has remained more or less stable, the consumption of salmon, 99% of which is coming from aquaculture, has increased from 1,7kg/capita to 2,25 in the last ten years.
However, turning to farmed seafood will not help address sustainability concerns. As we stated in a position on industrial aquaculture last November, a common myth is that aquaculture can help stop overfishing and replace fisheries as a seafood supply chain and this belief has taken root into the European average citizen’s mindset. Yet, what this belief omits is that farmed-fish needs to be fed, and usually, by wild-caught fish processed into fishmeal.
Several NGO reports have pointed at how global aquaculture supply chains are leading to the destruction of wild fish stocks, often putting food security at risk in developing countries. According to Changing Markets foundation, which has been leading an awareness campaign for the last few years, at least one fifth of wild-caught fish is used to produce fishmeal and oil, either for livestock or fish farming.
The 2015 European Commission campaign “Farmed in the EU” promoted for the first time aquaculture products. However, the EU should consider the impacts of aquaculture in third countries and make sure it does not promote the consumption of carnivorous species which need to be fed from wild-caught fish.
Salmon and shrimps are on the top five species consumed by Europeans, out of which 99% and 49% respectively come from aquaculture. Salmon produced in Norway and Scotland and fed with fish meal and fish oil sourced in Peru and Mauritania, is then sold in supermarkets throughout Europe. These two countries are also the main suppliers of “fishmeal and fish oil for the aquaculture feed used by the French aquaculture sector,” says Changing Markets in its most recent report. In view of this, it is counter-productive to promote fish consumption in the EU, without considering the impacts that the aquaculture and fisheries sector have in third countries.
3.1. The problem of fishmeal production in West Africa
In the last decade, the unreasonable expansion of fishmeal factories, often installed by foreign companies, particularly Chinese, has decimated stocks of small pelagics in West Africa. This expansion started first in Mauritania, and has since spread to Senegal and the Gambia, and is now reaching countries like Sierra Leone. “Artisanal fishermen are being pushed into supplying these factories, which is causing many women processors to lose their jobs”, denounced recently Gaoussou Gueye, president of the Senegalese Association for the Promotion and Empowerment of Artisanal Maritime Fishing Actors (APRAPAM), in a recent interview.
Small pelagics are the staple food of West African coastal communities and the competition with fishmeal factories to access this resource is leading to a food security crisis in the region while fishermen and women fish processors are losing their jobs and livelihoods.
The UN Special Rapporteur on the right to food pointed at the reliance on wild-caught fish for fish feed as one of the key problems of industrial aquaculture, especially of carnivorous species. “Fishmeal has shifted from use in livestock farming to use in aquaculture over the past decade. […] Recent reports highlight extensive overfishing and negative ecosystem impacts caused by the reduction industry.” He also warned that the “use of the industry to produce farmed fish for wealthy consumers may come at the expense of poorer populations who could benefit from improved availability of and accessibility to wild fish.”
In this regard, it is essential that the EU does not promote the products from aquaculture, especially carnivorous species which need to be fed from wild-caught fish. Following the consultation of last fall 2020, the Commission just recently issued new aquaculture guidelines which calls Member states to review their national plans to ensure “sustainable feed systems […] using feed ingredients that are sourced in the way that is most respectful of ecosystems and biodiversity.” This is a welcome step but it remains to be seen whether and how these non-binding guidelines are implemented at national level.
The EU can also use its leverage to improve the sustainable management of these stocks in West Africa. In a recent statement by the LDAC, EU long-distance fisheries value chain stakeholders and NGOs unanimously called the Commission to step up its game and support concrete steps that would lead to the formation of a non-tuna Regional Fisheries Management Organisation (RFMO) in West Africa.
3.2. THE PROBLEM WITH ECOLABELS
Beyond the promotion of seafood, taking into account sustainability issues, the Commission also needs to look seriously into certification schemes. Indeed, these ecolabels do not cover the social and environmental issues in the lower levels of the supply chain, particularly in developing countries. For example, these certifications are blind to the precarious working conditions faced by workers and the pollution suffered by the communities who live nearby the fishmeal plants.
For example, the French company Olvea and several other European companies involved in the fishmeal supply to European salmon farms have been financing a “Fisheries Improvement Project” (FIP) with the goal to eco-label West-Africa fishmeal and fish oil products, made from overfished small-pelagic stocks. As Andre Standing, advisor at CFFA, states, eco-labelling “ignores the fundamental point that the rights of local artisanal fishers, food processors and traders, as well as people’s right to food in the region, must take precedence over the profits of companies in developed countries.”
Instead, the EU should ensure the highest environmental and social sustainability standards apply to all products deriving from ocean exploitation. In this process, the EU should of course support developing countries to commit and achieve necessary changes for meeting these standards, through international partnerships, cooperation and trade policies.
Conclusion
The EU market is the most important and lucrative market for fish products globally. In view of the concerns regarding the sustainability of both wild-caught fisheries and industrial aquaculture, and taking into account the EU’s obligation to support a responsible consumption, it is clear that the EU should not promote seafood consumption, but rather focus on providing accurate and complete information to the consumers.
Moreover, the EU needs to seriously look into the wider environmental and social issues throughout the fisheries value chains, including for imports, to ensure all seafood deriving from ocean exploitation is sustainable. In this regard, the EU should discourage the consumption of intensive aquaculture products that depend on fishmeal and also stop the imports of seafood that has been produced abusing workers’ rights, requiring the privatisation of vast coastal areas, displacing communities or destroying vital ecosystems, such as mangroves.
There is no way that European citizens can continue consuming the same amounts of seafood, whilst ensuring it is produced in sustainable conditions. The EU should promote a general diminution of fish consumption, privileging quality over quantity, consuming wild fish coming from environmentally and socially sustainable, low-impact and preferably local fishing, while also encouraging low-impact or restorative aquaculture such as for mussels, oysters or algae.
Banner photo: Fish market in Greece, by Marko Markovic.
In a position paper, APRAPAM questions the government's proposal to support the production of fish feed and insists instead on the importance of a management plan for small pelagics and the prioritisation of human consumption.