sippo eu market access and eco laberlling

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


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


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


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.


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?


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?


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


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.


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


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.


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


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


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


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


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


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.


• 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


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


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.


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.


Prawn trawler in Belize


3.7.1 Key regulations for fish and fishery products


3.7.2 Key regulations for bivalve molluscs


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.”


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.


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.


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.


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


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.



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.



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.


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”.


• 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.


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


• 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


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;


• 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


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)?


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




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


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


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


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




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

®


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


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


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


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


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.

pdf

• 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


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


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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