At present, the EU imposes a number of conditions on fish products entering the EU which support sustainability and consumer information, that we fear may be under threat:
Traceability and labelling
All seafood products sold within the European Union must be labelled with the area in which the fish was caught, and the fishing gear used (or farming method, for aquaculture products) (
Directive No 1379/2013). This information is necessery for consumers wanting to check whether fish is from healthy stocks using the Marine Conservation Society’s
Good Fish Guide. Without this information, it simply isn’t possible to be sure whether a fish product is sustainable unless the packaging also bears a sustainability ecolabel. This could be very serious for some species; seabass which is wild-caught, for example, is considered ‘
fish to avoid’, whereas many sources of
farmed seabass are OK to eat.
Tackling illegal fishing
All wild-caught fish products imported into the EU must be caught by approved vessels and be
accompanied by a valid catch certificate. Countries which fail to adhere to the
EU’s guidelines to prevent and eliminate IUU fishing risk a temporary ban on importing into the European Union. (In the past this has happened to Belize, Cambodia, Guinea and Sri Lanka).
Aquaculture hygiene and chemical testing
Farmed fish products (in the UK popular farmed species are salmon, king prawns, seabass, as well as some bream, tilapia and pangasius) must undergo a ‘residue monitoring plan’ in which products are tested for contaminants including veterinary drugs (including antibiotics), pesticides and heavy metals. Results must be submitted to the European Commission annually for approval.
Sustainable Fish Cities, the campaign led by Sustain aiming to end unsustainable fishing, is concerned that EU certification requirements are perceived as limiting U.S. agricultural exports, and as part of a new trade deal, requirements for catch certificates, chemical residue testing and labelling could be removed or watered down.
Whilst the Repeal Bill was intended to transfer EU law into UK law, there are widespread concerns about how much power the Bill gives ministers to change these ‘retained’ laws in future without the normal parliamentary scrutiny (see
analysis in the Independent for example). There are also other issues to be confirmed, for example, to whom will results of residue testing in aquaculture be sent after Brexit?
Public-sector fish buying
Sustainable Fish Cities is further concerned about the UK's policies for buying sustainable fish for our public institutions. The public sector spends about £2.4bn per annum procuring food and catering services for outlets including hospitals, schools, prisons and the defence sector. Fish is served at least twice per week in hospitals and once per week in schools, so represents a lucrative potential market for imported seafood. At present, most public sector institutions must only use verifiably sustainable fish – helping to incentivise and reward sustainable fishing, but a future trade deal could look to water these down to allow more imported seafood to be served in our public institutions.
Now is the time to act
A post-Brexit trade deal with the USA is being discussed now, and there must be a condition, in any trade deal, that only food of the same or higher standards than is currently the case can be imported, otherwise we risk undermining action on tackling illegal fishing, reducing consumer power, and undercutting the UK’s fishing industry and food served in our public institutions.
The consultation closes on 26th October, and we warmly encourage you to
submit your own response using the key asks summarised by our trade expert as you see fit.
Please also
write to your MP at this crucial time, to ask them to ensure that new trade deals are fair for people and the planet.