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EU Market Access and Eco-Labbeling for Fishery and Aquaculture Products
 

EU Market Access and Eco-Labbeling for Fishery and Aquaculture Products

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This publication provides a guideline to the regulatory requirements...

This publication provides a guideline to the regulatory requirements
for exporting of seafood products to the European Union. It describes the EU system of official assurances, the main regulations, requirements for the Competent Authorities and operators 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.

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    EU Market Access and Eco-Labbeling for Fishery and Aquaculture Products EU Market Access and Eco-Labbeling for Fishery and Aquaculture Products Document Transcript

    • EU Market Access & Eco-Labellingfor Fishery and Aquaculture Products.sippo.ch
    • Publisher.PublisherOsecStampfenbachstrasse 85, P.O. Box 2407, CH-8021 ZurichDirect phone +41 44 365 52 68 / Fax +41 44 365 52 21AuthorFrancisco BlahaLayout and designBeate RüttigerCover photoFishing Vessel Orion I - Argentina (foto de M. Capizano)© M. CapizzanoPhotos and illustrations© F. Blaha, except page 39 © Dirkje BakkerThe author is an independent fisheries specialist based in NewZealand. He has been involved with commercial fishing andresearch since the mid-1980s. He works in institutional strengthen-ing, capacity building and applied research for the private sectorand international development organisations in more than 35countries worldwide.www.franciscoblaha.comFor more information:Constantin KostyalProject Manager Food ProgrammeOsecSIPPO Swiss Import Promotion ProgrammeStampfenbachstrasse 85, P.O. Box 2407, CH-8021 ZurichDirect phone +41 44 365 52 68 / Fax +41 44 365 52 21ckostyal@osec.ch / www.osec.ch2 l EU Market Access & Eco-Labelling
    • 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-IUUcatch certification. It also includes a chapter on private eco-labelschemes and their role in the EU seafood market.This bulletin was prepared by Francisco Blaha, SIPPOConsultant, and reviewed by Constan tin Kostyal, Project ManagerFood Programme, SIPPO Swiss Import Promotion Programme.DisclaimerSIPPO, the Swiss Import Promotion Programme, is a mandateof the State Secretariat for Economic Affairs, SECO, within theframework of its economic development cooperation. It is carriedout by Osec, the official Swiss foreign trade promotion agency.The programme helps small and medium enterprises (SMEs) indeveloping and transition countries to gain access to the Swissand European markets by providing information, training coursesand other matchmaking services. SIPPO also assists importersfrom Switzerland and the European Union with finding suitablepartners and high-quality products from selected developing andtransition 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 EU Market Access & Eco-Labelling l 3
    • Foreword.The EU market is a wonderful place to be for any producer willing and development cooperation with poorer countries, trade-relatedto sell its products, with its over 500 million inhabitants, all among cooperation, including social and environmental aspects, takes onthe world‘s wealthiest. But the EU market is also a very challen- a major importance. The overall aim is to boost trade as a triggerging place to access, with thousands of enterprises competing for growth and sustainable development.for share, on the one hand, and strict quality standards set by aselective consumer base. Specifically, SECO runs programmes to promote imports to Switzerland and the rest of Europe from goods, including fish,The above is especially true with respect to fish and fishery prod- produced in developing countries. In this endeavour, SECO hasucts. On the one hand, the EU is the largest single fish market, set up the Swiss Import Promotion Programme SIPPO whichwith imports amounting to 15 billion EURO in 2009, on a quickly works directly with enterprises, providing them with counselingrising trend. On the other hand, although it offers generous tariff and market information services and directly fostering their accessconcessions to developing countries (and tariff freedom to least to markets via trade fairs.developed countries), the EU also puts high demands on prod-ucts, regarding product quality, fishing, processing, etc. Likewise, The present publication on EU Market Access for fish and fishSwitzerland provides a promising market, although on a much products is an excellent example of SIPPO’s interventions aimedsmaller footing: each of its 7 million inhabitants consumes (only) at fostering access to the European market through information10 kg of fish products every year (EU: 22 kg). By definition (Swit- dissemination. It provides the reader with tangible and lively ad-zerland is a land-locked country), fish products come from abroad, vice which should lead to market penetration in Europe. I wish youmostly the EU, making Switzerland the 1st market worldwide for a pleasant reading!EU fish products. So, entering the EU market enables accessingan even wider market, including Switzerland.It is a general rule that exports constitute an essential source ofrevenues for all countries. The State Secretariat for Economic Hans-Peter EglerAffairs SECO has recognized the key role of trade for developing Head of Trade Promotion, Economic Cooperation and Develop-countries. Among the instruments it deploys within its economic ment, State Secretariat for Economic Affairs SECO4 l EU Market Access & Eco-Labelling
    • Contents.1 About this booklet. .......................................... 6 6.6.1 Weak economic imperatives ...................................... 331.1 Guidance table ............................................................ 6 6.6.2 Certification costs ...................................................... 33 6.6.3 Weak institutional capabilities .................................... 342 Is it complicated to export to the EU? ..... 8 6.7 What about organic aquaculture? .............................. 35 6.7.1 EU regulatory framework for organic products .......... 353 Health certification. ......................................... 9 6.8 Which way to go for Eco-Labelling?........................... 363.1 The basics ................................................................... 9 6.9 Key fisheries eco-labels available in the market ........ 373.2 The health certificate ................................................... 9 6.9.1 Marine Stewardship Council ...................................... 383.2.1 The Food and Veterinary Office ................................. 10 6.9.2 Friend of the Sea (fisheries) ...................................... 383.3 Requirements for food business operators ................ 10 6.9.3 KRAV (fisheries) ........................................................ 393.3.1 Approved Establishments .......................................... 10 6.9.4 Naturland (fisheries) .................................................. 393.3.2 Conditions of operators along the production chain .. 11 6.10 Key aquaculture eco-labels........................................ 403.4 Requirements for all fishery products ........................ 12 6.10.1 Aquaculture Certification Council .............................. 403.4.1 Specific requirements for aquaculture products ........ 13 6.10.2 Global GAP ................................................................ 413.5 Official controls .......................................................... 14 6.10.3 Friend of the Sea (aquaculture) ................................. 413.5.1 Signing the certificate ................................................ 16 6.10.4 Aquaculture Stewardship Council .............................. 423.5.2 Certification and eligibility .......................................... 16 6.10.5 Naturland (aquaculture) ............................................. 423.5.3 Traceability ................................................................. 17 6.10.6 Bio Suisse .................................................................. 433.5.4 Laboratories to be used for official controls ............... 17 6.10.7 KRAV (aquaculture) ................................................... 433.6 Border Inspection Posts ............................................. 183.6.1 Rapid Alert System for Food and Feed ..................... 18 7 Bibliography. ..................................................... 443.7 What about the regulations? ...................................... 183.7.1 Key regulations for fish and fishery products ............. 20 8 Endnotes............................................................. 463.7.2 Key regulations for bivalve molluscs .......................... 21 9 Glossary. ............................................................. 474 IUU Regulation. ............................................... 224.1 The basics ................................................................. 224.1.1 What is IUU fishing? .................................................. 224.2 How does the catch certificate operate? ................... 244.2.1 Trade flows................................................................. 255 The relationship between health and IUU certification.............................................. 265.1 Comparative table ...................................................... 276 Eco-Labelling. .................................................. 306.1 The basics ................................................................. 306.2 Why are they becoming important for the EU market?... 306.3 Coverage and certification ......................................... 306.4 Producers: costs and benefits ................................... 316.4.1 Price premium ........................................................... 326.4.2 Increased market share ............................................. 326.5 Consumers‘ perspective ............................................ 326.6 Eco-labels in developing countries ............................ 32 EU Market Access & Eco-Labelling l 5
    • 1. About this booklet.Exporting seafood to the European Union (EU) is not an obli- “desirable” for your product. They do not have regulatory status,gation, and it requires an equal amount of effort by the govern- but can under certain circumstances facilitate the establishment ofment authorities and the private sector of the exporting country. market presence once access conditions have been fulfilled.Compliance and understanding of the required system of officialassurances is paramount in order to access the EU market. As this publication focuses on EU market access, only some European-operated or EU market-oriented standards and certifi-Until recently, the requirements of the EU solely focused on cation programmes with strong market presence in the EU havefood safety/health certification. However, from 2010 onwards, a been selected for identification. This is neither an exhaustive list,“new” certification is required, with a focus on the area of Illegal, nor an endorsement of the schemes identified.Unreported and Unregulated fishing (IUU). These two “necessarycertifications”, while allowing market “access”, do not guarantee It is the aim of this publication to help potential and presentmarket “success“ per se. exporters understand, on one side, the basics of the “necessary” market access certifications and, on the other, some key aspectsThe positioning of your products in the EU market depends on of the “desirable” ones. It is strongly recommended that the readermany more factors. Some are relatively obvious, such as quality, follows up with the references provided, and does research on theprice, presentation, market segmentation and reliability of supply. topics that are not covered by this publication.However, over the last years, other “certifications” are increasinglyshaping the European seafood market landscape, and these relate To facilitate the use of the booklet, the following table will helpto ethical and environmental issues associated to the sourcing, identify the appropriate sections according to the reader’s interestproduction and distribution of fish and fishery products. These and needs.private certification initiatives, known as Eco-Labelling, are1.1 Guidance table. QQ Question? Yes/No/Uncertain Section 1 Is the EU a realistic market for your product? Y: go to Q 2 N: stop here Uncertain: read section > 2 2 Are you aware of the general sanitary requirements policy for importing seafood Y: go to Q 3 and aquaculter products? N: read section > 3 3 Is the producing country authorised for the export of seafood to the EU from a Y: go to Q 4 health certification aspect? N: stop here Uncertain: read section > 3.1 4 Is the producer approved for exporting to the EU? Y: go to Q 5 N: stop here Uncertain: read section > 3.3 5 Are you interested in the basics for the regulatory products requirements? Y: read section > 3.4 N: go to Q 66 l EU Market Access & Eco-Labelling
    • 6 Are you interested in the basics of the required official controls? Y: read section > 3.5 N: go to Q 77 Are you interested in the interrelations and references of the key EU regulations Y: read section > 3.6 regarding sanitary conditions? N: go to Q 88 Are you aware of the general IUU requirements policy for seafood and aquaculture Y: go to Q 9 products imports? N: read section > 49 Do the requirements of the IUU catch certification apply to the seafood products to Y: go to Q 10 be traded? N: go to Q 13 Uncertain: read section > 4.110 Are you interested in the basics of what constitutes IUU fishing? Y: read section > 4.2 N: go to Q 1111 Are you interested in the basics of catch certifications and trade flow requirements? Y: read section > 4.3 N: go to Q 1212 Are you interested in the basics of the interrelations and differences between Y: read section > 5 health and IUU certificates? N: go to Q 1313 Are eco-labels an area of interest for you or a commercial requirement for the Y: read sections > 6, 6.1, fishery and aquaculture products concerned? N: go to Q 14 6.214 Are you interested in what eco-labels cover and in Y: read section > 6.3 the certification process of eco-labels? N: go to Q 1515 Are you interested in the costs and benefits of eco-labels for producers? Y: read section > 6.4, 6.5 N: go to Q 1616 Are you interested in the challenges facing Eco-Labelling in developing countries? Y: read section > 6.6 N: go to Q 1717 Are you interested in organic aquaculture certification? Y: read section > 6.7 N: go to Q 1818 Do you need information on how to choose an eco-label scheme? Y: read section > 6.8 N: go to Q 1919 Are you interested in the key fishery eco-labels in the EU market? Y: read section > 6.9 N: go to Q 2020 Are you interested in the key aquaculture ecolabels in the EU market? Y: read section > 6.10 N: go to Q 2121 Are you interested in a selection of references and suggested readings for all these Y: read section > 7 topics? N: stop here EU Market Access & Eco-Labelling l 7
    • 2. Is it complicated to export to the EU?The European Union (EU) is the biggest single market for fish and At present, the EU imports around 60% of its traded seafoodfishery products worldwide, as a consequence of an increased from third countries, and even though the idea of accessing manyconsumption per capita and its enlargement to 27 member states. wealthy customers is very tempting, as a producer, your decision 1While different EU member countries import different amounts, to export to the EU has to be based on the market access situa-all of them share the same market requirements for seafood tion of your country and a cost/benefit analysis for your operation.products. These requirements are also shared by Iceland, Norway,Switzerland and Liechtenstein, as they are part of the European If your potential incomes justify the expenses you may incur, inFree Trade Association (EFTA). The EU bases its seafood import terms of infrastructure upgrades, knowledge and capacity building:on government-to-government assurances, without the inter- then go ahead. There will be, however, ongoing costs involved invention of any private type certification, or standards such as ISO. maintaining the access system that should be taken into account.Therefore, the efforts of producers are conditioned to the goodperformance of whichever authority (the competent authority –CA) in the exporting country assumes the responsibility of givingthe EU the official guarantees it requires regarding complianceand 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 productdoes not originate from Illegal, Unreported and Unregulated (IUU)fishing activities.Both certifications will have a major impact on exporters, as theEU makes its legislation based on the realities of its members andnot of those of third countries.Many developing countries have found that compliance with theseobligations is complex, costly and requires a level of mobilisationof resources that is generally not available to them. Complianceand understanding of the required system of official assurances isparamount to accessing the EU market, and it requires an equalamount of effort by the government authorities and the privatesector of the exporting countries.8 l EU Market Access & Eco-Labelling
    • 3. Health certification.3.1 The basics. Once the equivalency is established and the country “authorised”, exports can then access the market as long as the lots are ac-There are currently 100 countries authorised for exporting fish companied by a health certificate emitted by the CA of the countryand fishery products to the EU, of which 15 have authorisation for of origin.live bivalve molluscs.2 The European Commission’s DirectorateGeneral for Health and Consumer Protection (DG SANCO) isresponsible for food safety in the EU. The import rules for fishery 3.2 The health certificate.products seek to guarantee that all imports fulfil the same highstandards as products from the EU Member States, with respect Seafood products exported to the EU must be accompanied by ato hygiene and consumer safety and, if relevant, also to the animal health certificate emitted by the CA of the country of origin.7 Thishealth status. certificate is the official document between the exporting country and the EU that provides the official guarantees required. As theAlthough cataloguing all what the EU requirements to accept format and content of the certificate are to be respected, its Publicseafood from a non-member country is beyond the scope of this Health Attestation is a great tool to understand the requirements.publication3, it is safe to say that the exporting country regulatorysystem should correspond (or be equal) to what is established “I, the undersigned, declare that I am aware of the relevant provi-for the EU Member Countries by Regulations (EC) No. 178/2002, sions of Regulations (EC) No. 178/2002, (EC) No. 852/2004, (EC)(EC) No. 882/2004, and (EC) No. 854/2004. The EU requires that No. 853/2004 and (EC) No. 854/2004 and certify that the fisherythe official guarantees in terms of compliance of seafood exports products described above were produced in accordance withfrom a third country4 should be given by a competent authority those requirements, in particular that they:(CA) which means the “central authority of a State competent forthe organisation of official control”5 in terms of food safety, prod- • come from (an) establishment(s) implementing a programmeuction standards and others, as specified for seafood in the relevant based on the HACCP principles in accordance with RegulationsEU legislation. It emphasises that: “The competent authorities for (EC) No. 852/2004;performing official controls should meet a number of operationalcriteria so as to ensure their impartiality and effectiveness”.6 • have been caught and handled on board vessels, landed, handled and where appropriate prepared, processed, frozenThe CA has to comply with a lengthy series of requirements, but and thawed hygienically in compliance with the requirementsroughly summarised, the CA needs to assure compliance with laid down in Section VIII, Chapters I to IV of Annex III to Regula-three types of obligations: tion (EC) No. 853/2004;• Obligations of resources: i.e. instruments of production, condi- • satisfy the health standards laid down in Section VIII, Chapter tions of handling/processing, Hazard Analysis Critical Control V of Annex III to Regulation (EC) No. 853/2004 and the criteria Point (HACCP) and prerequisite programmes, traceability, etc. laid down in Regulation (EC) No. 2073/2005 on microbiological criteria for foodstuffs;• Obligations of results: i.e. safety levels of the products (e.g. histamine, contaminants, microbiological levels), etc. • have been packaged, stored and transported in compliance with Section VIII, Chapters VI to VIII of Annex III to Regulation (EC)• Obligations of control: i.e. regulatory verification effectively imple- No. 853/2004; mented by the CA, data storage and management, administra- tive procedures, legal support, strict control of product certifica- • have been marked in accordance with Section I of Annex II to tion, etc. Regulation (EC) No. 853/2004; • the guarantees covering live animals and products thereof, if EU Market Access & Eco-Labelling l 9
    • from aquaculture origin, provided by the residue plans submitted 3.3 Requirements for food in accordance with Directive 96/23/EC, and in particular Article business operators. 29 thereof, are fulfilled; Assuming that the country is on the list of approved countries, the• have satisfactorily undergone the official controls laid down in CA is then responsible to approve food business operators (FBOs) Annex III to Regulation (EC) No. 854/2004.” 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 EUThe first part of the attestation implies the need of a certifier requirements, beyond the domestic ones. The CA’s assessment ofwhose duty relies on the body responsible for official guarantees, the FBO’s compliance with the EU standards defines the approvalwhich, as mentioned before, is the role of the CA. (or not), by assigning them a unique identification code.3.2.1 The Food and Veterinary Office 3.3.1 Approved establishmentsAs part of the market access conditions, EU experts from the All establishments in the capture or aquaculture production chainFood and Veterinary Office (FVO) assess the equivalency of an (hatcheries, farms, vessels, plants, cool stores, etc.) must beexporting country’s seafood safety regime and ascertains the approved by the CA regarding the EU requirements, in order forconditions required to be met for seafood from that country. their product to be considered “eligible” for the EU. The list of approved establishments in the progression from “raw materialThe FVO determines the status of compliance of the CA in terms to product” is maintained by the CA and represents all the FBOsof the required official guarantees with inspection missions, and in the production chain that are allowed to provide to companiesthey are the basis for establishing confidence between the EU that export directly to the EU. The establishments at the end of theCommission and the CA of the exporting country. chain (those that export directly to the EU) are to be included on a list of establishments authorised to receive a health certificate forAll inspection visit reports are publicly available and published on their products. This list can include vessels, plants or cool storesthe FVO website.8 They contain findings, references and (if neces- as long as they export directly to the EU (or to another third countrysary) recommendations to facilitate compliance. for further processing and then to the EU).Hence, seafood can be exported to the EU only from: These establishments are given a unique identification code, usually known as the “EU number”. The CA sends the EC a list• Authorised countries of authorised establishments9, with the guarantee that they have been inspected and deemed to comply with the specific hygi-• Approved vessels and establishments (e.g. processing plants, ene rules, which correspond to the type of product processed. freezer or factory) Therefore, any changes or updates in this list need to be com- municated to the EC immediately. The approval and listing is not• Vessels, cool stores – generally called Food Business Operators a “one off” event, it is based upon continuous compliance by the establishments. If the level of compliance becomes so low that the• Approved aquaculture establishments and areas 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.10 l EU Market Access & Eco-Labelling
    • Staff at a tuna cannery in the Philippines3.3.1.1 Requirements for the establishments 3.3.2 Conditions of operators along the production chainAs discussed, the CA certifies compliance to a series of require- As mentioned, all the operators in the value chain need to be inments, which are listed in the public health attestation of the compliance and under the control of the CA. These requirementscertificate. The first requirement is that: are evident in the following statement:• “(the products) come from (an) establishment(s) implementing a • “(the products) have been caught and handled on board vessels, programme based on the HACCP principles in accordance with landed, handled and where appropriate prepared, processed, Regulation (EC) No. 852/2004” frozen and thawed, hygienically in compliance with the require- ments laid down in Section VIII, Chapters I to IV of Annex III toThis booklet will not expand on HACCP any further as there is Regulation (EC) No. 853/2004”enough information on the subject worldwide. In general, at thisstage no food exporter should be processing food if they do not The statement also provides the specific set of references in thehave a fully functional HACCP plan. 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 EU Market Access & Eco-Labelling l 11
    • 3.4 Requirements for all fishery • “have been packaged, stored and transported in compliance products. with Section VIII, Chapters VI to VIII of Annex III to Regulation (EC) No. 853/2004”The particular requirements for the products are to be found in thefollowing statements: In this case, it refers to some very simple principles in terms of packaging and storage, to avoid them becoming a source of• “satisfy the health standards laid down in Section VIII, Chapter contamination, and temperature controls (e.g. melting ice for fresh V of Annex III to Regulation (EC) No. 853/2004 and the criteria products, – 18°C for frozen products and – 9°C for brine frozen laid down in Regulation (EC) No. 2073/2005 on microbiological fish to be canned), and how these same principles need to be criteria for foodstuffs” maintained during transport.This particular paragraph refers to the health standards for most • “have been marked in accordance with Section I of Annex II tofishery products such as organoleptical evaluation, histamine Regulation (EC) No. 853/2004”levels, parasites, toxins and so on. It also refers to microbiologicalstandards, which are quite minimal and only apply to ready-to-eat These identification-marking requirements are very basic andproducts. refer mostly to the type of product and establishment of origin identification.Floating tilapia cage, Betania lake in Colombia12 l EU Market Access & Eco-Labelling
    • 3.4.1 Specific requirements for aquaculture productsBesides all the requirements listed so far, the following state-ment applies specifically to products originated from aquaculture Animal health issues.11practices.• “the guarantees covering live animals and products thereof, if As of August 2008, Directive 2006/88/EC of 24 October from aquaculture origin, provided by the residue plans submitted 2006 on animal health requirements for aquaculture in accordance with Directive 96/23/EC, and in particular Article animals, and products thereof, and on the prevention and 29 thereof, are fulfilled” control of certain diseases in aquatic animals, became effective. This directive establishes the need of a recog-Countries wishing to export aquaculture products to the EU need nised CA that should perform its functions and duties ina particular approval that is given upon compliance with veterinary accordance with the general principles laid down for foodresidue monitoring requirements as outlined in Articles 29 and 30 safety, in terms of animal health of aquaculture species andof Council Directive 96/23/EC. management of infectious or contagious aquatic animal diseases in its territory, particularly the notifiable diseases,The Directive states the need of submitting a plan setting out listed by the World Organisation for Animal Health (OIE).the guarantees that it offers with regard to the monitoring of This directive requires from third countries great capacity ofthe groups of residues and substances referred to in Annex I of control, including among other obligations, zoning in termsCouncil Directive 96/23/EC. The residue-monitoring programme of diseases, registry of establishments, accreditation ofis submitted by the CA of the country of origin to the EC for initial laboratories and several requirements. The scope of theseapproval and needs to be presented annually for evaluation and requirements applies to: live fish, their eggs and gametesrenewal. It should be noted that a favourable evaluation is based intended for aquaculture in the EU, and for raw materialson the guarantees received on paper. If a subsequent inspection or products intended for further processing in the EU. How-carried out by the FVO to assess the implementation of residues ever, they do not apply to aquaculture products intendedand veterinary medicines controls demonstrates that the paper for retail. It is important to understand that the responsibilityguarantees cannot be relied upon, the status of the third country of these requirements may or may not fall under the scopeon the list could be revised. 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 EU Market Access & Eco-Labelling l 13
    • 3.5 Official controls. In terms of documentation:Official controls are required under the following statement: • General description of the company, facilities, products and processes.• “have satisfactorily undergone the official controls laid down in Annex III Regulation (EC) No. 854/2004” • The description of operations followed.However, under this last paragraph, we should first focus on the • The documented prerequisite programmes.official controls done by the CA as per EC 854/2004.12 • The HACCP plan.Some of the key requirements (but not the only ones) are thatofficial control activities are carried out: • The system to provide guarantees for the product traceability.• on a regular basis and with a frequency based on risk; • The documented and formalised withdrawal recall procedures.• without prior warning (as a general rule);• at any stage of production, processing and distribution; In terms of physical settings, operational conditions, control strate-• to include imports/exports. gies concerning the entire production process and the application of all prerequisite programmes by the operator:Official control activities on the production and placing on themarket of fishery products are aimed at assessing compliance by • The general hygiene conditions of building and surroundings.the establishments, in particular: • The water supply and water quality management system,a A regular check on the hygiene conditions of landing detailing the internal distribution net, treatment, if any, quality and first sale; monitoring plan and related records.b Inspections at regular intervals of vessels and establishments • Ice production, internal distribution and quality monitoring. on land, including fish auctions and wholesale markets, to check, in particular: • The absence of cross-contamination/air current risks (layout and infrastructure considerations). (i) where appropriate, whether the conditions for approval are still fulfilled; • Personnel health and hygiene control (including training). (ii) whether the fishery products are handled correctly; • Sanitary filtering of personnel arrangements, toilets and dressing facilities. (iii) compliance with hygiene and temperature requirements; • Facilities and equipment cleaning and sanitation plans (methods, (iv) the cleanliness of establishments, including vessels, their schedules, chemicals used and approvals). facilities, equipment and staff hygiene; and • Raw materials’ acceptance criteria and controls (freshness,c Checks on storage and transport conditions. temperature, transport, lot identification).In more practical terms, this implies that the establishments along • Specifications for other inputs as ingredients, additives orthe value chain will be “inspected” or “verified” by the CA against, packaging.for example, the requirements detailed the requirements detailedas follows.13 • Waste disposal system.14 l EU Market Access & Eco-Labelling
    • • 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 areto include at least the following regulatory elements, as describedin 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 EU Market Access & Eco-Labelling l 15
    • 3.5.1 Signing the certificate The nature of the official controls implies that all elements in theThe above-discussed issues are what the health certificate im- production chain15 need to be approved by the CA. This criti-plies. When the CA signs the health certificate, it becomes official cal issue has important ramifications, as the different stages ofevidence that the establishments, operators, raw materials and production may be under different central or regional authorities.products in the value chain comply with the requirements as listed In any case, the various “sub CAs”, and/or the Central CA need toin the public health attestations. Therefore, the health certificate act as one in terms of the offering of official guarantees to the EU.must provide an accurate description of the identity of the ap- If a country has four different authorities dealing with the fisheriesproved processor of the goods, the type of fish being shipped, the production chain, this cannot be used as an excuse for noncom-quantity of product being shipped, and the final destination of the pliance, as mechanisms should be enacted for coordinated officialgoods. controls. Good coordination is fundamental in order for certifi- cation to be meaningful, as the certification process should be3.5.2 Certification and eligibility centralised, although the fishery operators and the CA’s inspectionA very important criterion not really obvious on the certificate per activities tend to be geographically fragmented.se, is the issue of eligibility of products and raw materials as aconsequence of official controls over the production chain andtraceability.Riverside fish market, Colombia16 l EU Market Access & Eco-Labelling
    • Good IT practices are increasingly the norm in terms of proving A copy of the import certificate, or original export certificate, musttraceability, inspection results and certification of food products. In be available on request.particular, the design and maintenance of proper databasestructures enhancing the information sharing and integration be- 3.5.4 Laboratories to be used for official controlstween the CAs can be very important to provide some consistency For an analytical result to have “official” validity, it must come fromin the certification process. Whoever signs the certificate needs a laboratory accredited to ISO/IEC 17025 for those parametersto have the capacity to assure that the product certified has been to be analysed. The standard specifies the general requirementsunder officially controlled conditions in officially controlled estab- for the competence to carry out tests and/or calibrations; it coverslishments from origin to export. If the harvesting of raw materials management and technical issues, and the key objective is toor any other production stages were performed in a non-compliant assure the accuracy and quality of the results. The accreditationor non-verified16 establishment, then that raw material or prod- is what allows the CA to “trust” the impartiality and accuracy ofuct is not eligible for export to the EU, hence it cannot receive a the results, and as a result “approve” the laboratory for it results tocertificate. The fact alone that a product has been processed at be considered “official”. As a consequence the status of “appro-an establishment with an “EU number” does not guarantee its ved” can only be maintained as long as the laboratory holds theeligibility to the EU market. accreditation.3.5.3 Traceability These requirements apply equally to government and privateThe CA should verify the efficiency of a traceability system adopted laboratories, in fact, private sector laboratories are increasinglyby an operator. The principle is “one step backwards, one step for- becoming more used worldwide for regulatory purposes.wards”. The operator should be able to show from where and whomdoes 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 productsIf a company listed for the EU holds products that are not eligibleby origin (i.e. a non-approved vessel) or conditions (approved butin non-compliance), then the operator must ensure the physicalseparation of EU-eligible from ineligible seafood products for theEU. Where any assumed EU-eligible seafood products cannot bedistinguished between ineligible seafood products, then the formerare deemed to be ineligible and must be dealt with accordingly.3.5.3.2 Products with imported raw materialsBased on the principle of official controls, EU health certificatesfor seafood products exported to the EU that are derived wholly orpartly 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. EU Market Access & Eco-Labelling l 17
    • 3.6 Border Inspection Posts. 3.6.1 Rapid Alert System for Food and Feed The Rapid Alert System for Food and Feed (RASFF)18 is a toolImports of seafood from non-EU countries must enter the EU via that the EU uses to enable the quick and effective exchange ofan EC-approved Border Inspection Post (BIP) under the authority information between Member States and the Commission whenof an official veterinarian. risks to human health are detected in the food and feed chain. RASFF provides an around-the-clock-service to ensure thatAt the BIP, the the consignments are subject to three types of urgent notifications are sent, received and responded to in thechecks: shortest time possible.• A documentary check: it is done systematically; it involves The CE publishes a weekly summary of the notifications19 under checking the export certificate accompanying the seafood the RASFF system. When a notification pertains to imported consignments. 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-• An identity check: it is also done systematically; it involves sures to avoid recurrences. checking that the data on the export certificate are consistent with the product, which has been imported. 3.7 What about the regulations?• A physical check: it is done appropriately to the circumstances of the consignment; it involves examining the product, it’s pack- It is impossible to reference all legislation in one document, or all aging, the information on the label and the storage conditions. the requirements in one simple list. There is no way to escape reading regulations, and one has to be aware that they changeThe frequency and type of physical checks are determined for and get updated frequently.each category of product on the basis of the intrinsic risk andresults of checks carried out previously on the same product of The two following graphic representations resume the key regula-the same origin, and it can include taking samples for laboratory tory instruments and their interconnections and can be used as atesting on a random basis or on the basis of past records. If the base to understand the systems and to find the required references.consignment is found to be non-compliant with the EU legislationfor any reason, then the BIP notifies the non-compliance to the EUthrough the internal notification system of the EU called the RapidAlert System for Food and Feed (RASFF). If the product exceedsany regulatory levels or contains non-authorised substances, thenit is up to the exporter in the country of origin to decide to get theproduct back or let it be destroyed.18 l EU Market Access & Eco-Labelling
    • Prawn trawler in Belize EU Market Access & Eco-Labelling l 19
    • 3.7.1 Key regulations for fish and fishery products20 l EU Market Access & Eco-Labelling
    • 3.7.2 Key regulations for bivalve molluscs EU Market Access & Eco-Labelling l 21
    • 4. IUU Regulation.4.1 The basics. 4.1.1 What is IUU fishing? It is not the intention of this section to define and discuss theThe so-called “EU IUU Regulation”20 is a legal instrument applying details of IUU fishing and its impact. However, under the scope ofto all vessels engaged in the commercial exploitation of fishery the IUU Regulation, the concept covers:resources in all maritime waters, and seeks to prevent, deter andeliminate IUU fishing as much as they are linked to the EC, either • Infringements to rules on management and conservation ofthrough trade to and from its territory or the involvement of EC fisheries resources in national and international waters;nationals in IUU fishing activities conducted under any flag. • Fishing activities in high seas areas covered by a RegionalIt therefore applies to all types of trade of marine fishery products, Fisheries Managementprocessed or not, originating from third country fishing vesselsand exported to the Community by any means of transport, and to Organisation (RFMO) carried out by vessels without nationality orcatches originating from Community fishing vessels to be expor- registered under a flag state which is a non-contracting or non-ted to third countries. cooperating party to the RFMO and in a manner contravening the rules issued by this organisation;In order to ensure that no products derived from IUU fishingappear on the Community market or on markets supplied from the • Fishing activities carried out in high seas areas not covered byCommunity, the Regulation seeks to ensure full traceability of all an RFMO in a manner inconsistent with state responsibilities formarine fishery products traded by means of a catch certification the conservation of fisheries resources under international law.scheme. • Behaviours which shall be qualified as presumed IUU fishingThe IUU Regulation also comprises provisions on port state con- activities.trol for third country fishing vessels, the identification of IUU ECor third country vessels, non-cooperating third countries and EC “Under the IUU Regulation, a fishing vessel is notably pre-nationals involved in IUU fishing under any flag. sumed to be engaged in IUU fishing activities if it is shown that its operators have carried out activities in contravention with theThe provisions are complemented by a mutual assistance system conservation and management measures applicable in the areato facilitate exchange of information between the authorities in concerned, such as fishing without a valid licence, in a closedthird countries, EU Member States, the EC and a Community area, beyond a closed depth or during a closed season, or byAlert System, which is specifically designed to focus verification using prohibited gear, as well as the failure to fulfil reportingactivities towards situations at risk. obligations, falsifying its identity, or obstructing the work of inspectors.”In this respect, the IUU Regulation is based on the responsibilityand commitments of third countries, and it is funded on the appli-cable national and/or international conservation and managementmeasures; therefore, it does not introduce any new conservationor management measures.22 l EU Market Access & Eco-Labelling
    • The following figure illustrates some examples of vessels in opera- In very general terms, within a legal framework these are thetion that are involved in IUU fishing. Either they are not licensed to questions that need to be answered to establish whether fish isfish in the territorial waters of the countries A and B or the RFMO, legal or not: Who caught it? Where was it caught? How muchor they are fishing in closed areas, or with prohibited gear, or was caught? When was it caught? How was it caught? – as isalthough they have a license, do not report their catches. illustrated below. 21 The CA needs to back up these questions with a legal framework. EU Market Access & Eco-Labelling l 23
    • The answers to these questions must be verifiable in relation to The CA, in turn, has a series of “programmes” or tools within theirthe fisheries management framework of the harvesting vessel’s scheme of Monitoring, Control and Surveillance (MCS) of fishingflag state and subject to applicable laws and international conser- activities (e.g. fishing permits, fisheries observers, inspectors,vation and management measures. VMS22, landing controls, etc.) that allow them to validate the accu- racy of the information in the certificate.The “operating system” of this certification is based on the ca-pacity of the fisheries AC of the vessel’s flag state to give officialassurances about the existence and “legality” of the answers tothese questions. The fish was caught... By whom? Where? In what When? How? quantity? Primarily concerned with vessel ID & fishing ground te d: ula Primarily concerned with catch quantity, g nre : perhaps closure period and gear type l/u ed a ort Ille g rep : All data types are relevant Un ce an pli : Primarily concerned with area, quantity, season C om ce i en Sc 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 to24 l EU Market Access & Eco-Labelling
    • the importation to the EU. Regarding the implementation (and as 4.2.1.1 Indirect importation without processingforeseen in the IUU Regulation), the EC has adopted an Imple- in another third countrymenting Regulation (Commission Regulation (EC) No. 1010/2009 In order to ensure full traceability, the certification scheme alsoof 22 October 2009) laying down technical details in some of the applies to situations where the fishery products are imported fromfollowing areas: another country than the flag state. As a result, products which are transported to another third country before reaching the Commu-• Prior notification of landings, transhipments and consignments nity must also be accompanied by a validated catch certificate (Articles 1, 2); and documented evidence that the products did not undergo any operations other than unloading, reloading or any operation desig-• Landing and transhipment declarations (Article 3); nated to preserve them in a good and genuine condition.• Benchmark criteria for port inspections (Articles 4, 5); Such documented evidence may consist of:• Simplified catch certification scheme for fishery products with • a single transport document, covering the passage from the flag specific characteristics (i.e. catches obtained by small fishing state to the Community through that third country (of indirect vessels) (Article 6); importation), or;• List of recognised catch documentation schemes in Regional • a document issued by the authorities in that third country com- Fisheries Management; petent for monitoring such activities mentioning:• Deadlines for the submission of catch certificates (Article 8); - the dates of unloading/reloading; - names of the ships or other means of transport; and• Risk management criteria for verifications related to catch certifi- - the conditions in which the products remained unchanged in that cates (Articles 31, 32); third country until re-export to the Community, or;• Administrative cooperation with third countries concerning catch • where appropriate, the re-export certificate established by an certificates (Article 33). RFMO catch documentation scheme recognised in accordance with Article 13 of the IUU Regulation.4.2.1 Trade flowsThe catch certification scheme applies to all fishery products 4.2.1.2 Indirect importation with prior processing in anotherimports, exports and re-exports to and from the Community, third countryirrespective of the means of transport (fishing vessel, other vessel, Where products are processed in a country other than the flagair or land transportation). state, the importer in the Community shall submit a statement established by the processing plant in the other third country,Some products, however, are excluded from the scope of the IUU provided in Annex IV of the IUU Regulation.Regulation. These are very few and relate to freshwater species,marine species by products and some invertebrates. A complete The statement must give an exact description of the products andlist is available in the Annex 3 of Regulation (EC) No. 1010/2009.23 must indicate that the products originated from catches accompa-There is no minimum weight below which samples are exempted nied by a catch certificate. A copy of those catch certificates mustfrom the Regulation. 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. EU Market Access & Eco-Labelling l 25
    • 5. The relationship between health certification and IUU certification.Purse seiners in Southern ChileBoth regimes are as different as the work scope of a Seafood The fact that a health certificate is issued for supplies from an ap-Safety Inspector and a Compliance Fisheries Officer. proved establishment or vessel or, in addition, an origin certificate, does not infer that the fishery products concerned comply withThe existence of a health certificate is thus not relevant for the conservation and management rules.purpose of the validation of a catch certificate, which shall relyonly on compliance with conservation and management rules. However, it is important to note that the different documents (catchAdversely, the catch certificates used in accordance with the IUU certificates, health certificates, certificates of origin) cannot con-Regulation will not be substitutes for health certificates and/or tain discordant information.certificates of origin.26 l EU Market Access & Eco-Labelling
    • 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 Avoid the importation of fisheries products ob- (and aquatic fauna in the case of live fish). tained from IUU fishing. Scope Fish and fishery products traded to EU Member All fishing vessels under any flag in all maritime countries from “authorised” countries. 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 Flag state of the harvesting vessel (and/or an be in the list of “authorised” countries based on RFMO if the vessel/flag country is participant of a legal framework and the “competency” of the CA. catch certification scheme recognised as compli- ant with the applicable regulation). Applicable EU Various, most notably Regs, (EC)178/2002, The regulation Reg (EC) No. 1005/2008 estab- regulations 852/2004, 853/2004, 854/2004, 2073/2005, etc. lishing a Community system to prevent, deter Effective since 1/1/2006 (prior was a similar and eliminate IUU fishing and its Implementing system since 1993). Regulation (Commission Regulation (EC) No. 1010/2009 of 22 October 2009). Body in charge Seafood safety CA varies depending on the Generally, it is the Fisheries Authority of the flag at origin country, it can be M. Health, M. Fisheries, M. country of the vessel. It can be M. Fisheries, a Agriculture, Food Safety Authority, etc. Fisheries Institute, or Coast Guard, Marine, etc. Possibility of a split Yes, this is done by many countries. Not contemplated. Either the flag country controls system? IUU fishing activities of its vessels or it doesn’t. (One regulatory system for products to the EU, and one for the rest?) Contents of the Very specific, done by the CA, and an officer of As per the model in the regulation. The master of certificate the CA of the country of processing provides the fishing vessel at landing should raise it, and official guarantees that the consignment was dealt the official CA of the flag state shall validate it, or with as per the EU regulations. Any changes in an RFMO if applicable. the certificate form, or inaccurate information will result in detention. The language of the certificate The validation must certify that the catch was is the one of the BIP of entry in the Community. made in accordance with applicable laws, regula- tions and international conservation and manage- ment measures. Presentation of On product arrival at the Border Inspection Post. By the importer on arrival (not specified where). the certificate Either in paper by the importer or e-cert and In case of direct landings in EU ports 3 days prior under the EU TRACES system. notice. EU Market Access & Eco-Labelling l 27
    • Sanitary certification Catch certification Body in charge Initially, the Border Inspection Post of the ports of The fisheries authority at the entry port in the EU. at the EU entry at the EU under the umbrella of DG SAN- This may or may not be the BIP. No centralised CO, which holds the ultimate responsibility (autho- body as yet. rises countries, sends FVO inspections, etc.) Status of the The operator must appear in a list of authorised No list of approved vessels. Products of vessels operator establishments (EU#). The value chain from the in a list of IUU vessels (either by the EU or by vessels to him needs to be “approved” by the CA RFMOs) are not allowed access. in regards of the EU requirements. Role of the The fishing vessel is one element of the responsi- The fishing vessel is the “key” element of the certi- fishing vessel bilities of the CA, it has to be “approved” in terms fication scheme. of its hygienic conditions. Role of the None. If it has a certification scheme (CCSBT, for RFMO example), it could be the body that validates the certificates. Direct The CA of the country where the product was last The official CA of the flag state must validate the importation processed must emit the health certificate. In the certificate, or a RFMO is applicable. (imported from the production case of factory vessels landing directly, the vessel country or the flag State) needs to be “approved” by the CA of the country of origin. Indirect importation Responsibility of the processing country. Tech- The product must be accompanied by a validated (imported from another nically, the product does not “enter” the country catch certificate (by the CA of the flag state); and country than the flag state) where it is transported; if the product is in any way there should be documentary evidence that the “transformed“, this scenario does not apply. consignment remained under the surveillance of Transport only the CA and did not undergo processing. scenario (transhipment, transit or temporary warehousing) 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 Responsibility of the exporting country. The expor- a) The consignment should be accompanied by (imported from another country ter must appear in a list of authorised establish- the catch certificate validated by the flag state (or than the flag state) ments (EU#) from the exporting country. a copy in cases where only a partial catch has been used in the consignment). Processing scenario The raw materials/original product must originate b) The consignment is accompanied by a state- from an “approved” establishment of an autho- ment from the processor and endorsed by the CA rised country. (as per the specific form of the regulation) which, i) describes and quantifies the unprocessed and The health certificate must refer to the “imported processed products, and raw material” and the original health certificate ii) states that the consignment has been pro- should be kept. cessed from catches referred to on the certificate.28 l EU Market Access & Eco-Labelling
    • Sanitary certification Catch certificationIndirect importation Same as above. In both above cases (either transport or proces-(imported from another country sing in country other than flag state), an alterna-than the flag state) 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- Product detained. Rapid Alerts Systems entry, Refusal of importation. AC of MC may confiscatecompliance report from the country of origin CA, product and destroy, dispose of or sell for charity. If the returned or destroyed. 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 A Community alert system will be created to share (RASFF) is a tool used for exchange of informa- information on operators and fishing vessels tion between MS and the Commission when risks which are presumed to carry out IUU activities. to human health are detected in the food and feed chain.European Union Nothing in the legislation. Nationals of the EC shall neither support nor en-nationals 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 developing Over 15 years of technical assistance by various The EC is cooperating administratively with thirdcountries bodies inside and outside the EC. countries in the implementation of this regulation. EU Market Access & Eco-Labelling l 29
    • 6. Eco-Labelling.6.1 The basics. labelled products (i.e. 40% of the total sourced). In many Euro- pean countries, supermarkets are dominant in the retail of fish andMany governments have introduced at national, regional and seafood products. Besides requiring a stable supply chain of goodinternational levels (with different degrees of success and capac- quality and safe products, they are also requiring their suppliersity), diverse policies and mechanisms to ensure the sustainability to prove that those products have been sourced ethically. Eco-la-of fish stocks and the best environmental practices in aquaculture. belled products provide this “proof” for the retailers. Particularly inIn addition to the official measures, the private sector has also in- Central and Northern Europe, this development is very apparent;troduced market-based initiatives to support the same objectives. the population is relatively environmentally aware, and there is an active civil society. Consumption patterns are based on a limitedEco-labels are one of these initiatives; they are designed to influ- range of traditional fish products, and consumers have the habit ofence the purchasing decisions of consumers and the procurement purchasing processed/packaged fish and seafood from super-policies of retailers selling seafood products, in order to reward markets that lend themselves to the attachment of a label at theproducers involved in responsible fishing practices and aquacul- point of sale. As a consequence, the market share of eco-labelledture practices leading towards sustainable use of natural products is growing rapidly.resources.Eco-labels are seals of approval given to products that are 6.3 Coverage and certification.considered to have lesser impact on the environment than otherproducts in the same market segment.24 An eco-label is a logoor label placed on a product, therefore providing information thatlinks the product to the production process, at the moment theconsumer or retailer makes a buying decision. Organisationsdeveloping and managing an eco-label set a series of standardswhich applicants hoping to use the logo will be assessed. If foundto be in compliance, they are certified in due course.The parent organisation also promotes the significance of thelabel to consumers to ensure appreciation and demand for theirbranded products. Accreditation, in this context, is the procedureby which certifiers and auditors are accredited as being compe-tent to carry out the assessments and certification against thestandards specific to each eco-label. 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-6.2 Why are they becoming se that deal with capture fisheries and aquaculture. Some of the important for the EU market? specific requirements of each eco-label scheme will be discussed later; however, it is important to point out that they do not onlyRetailers see good potential in eco-labels as a marketing tool, as subscribe to environmental matters, but they extend to biotechno-there is growing demand for ethical products and as an assurance logy, animal welfare, social responsibility and economic develop-against disapproving pressure from environmental groups and in ment issues. In terms of their certification methodology, there isthe media. Eco-labelled products are becoming part of many also variability, however, which can be categorised as:retailers’ corporate social responsibility policies, and as conse-quence, some firms are setting procurement targets for eco- • First party labelling schemes: established by individual compa- nies, based on their own product standards, with compliance “self declared”.30 l EU Market Access & Eco-Labelling
    • • Second party labelling schemes: established by industry as- • Improved management of fisheries resources and resulting sociations for their members’ products. Compliance is verified guarantees of future production potential through internal audit procedures or by employing external certifying companies as auditors (such as Bureau Veritas, SGS, • Increased earnings through an assumed price premium for eco- etc.). labelled fish• Third party labelling schemes: usually developed by a body In contrast, costs identified included: independent of producers, distributors and sellers of the labelled products. The label is typically licensed to a producer. The “chain • Actual costs of certification, experts‘ fees, etc. of custody” is tracked to ensure that the labelled product is in fact derived from the certified product. An independent, third- • Compliance costs related to adjusted management practices, party certifier conducts the audits. data collection and record keeping, which is additional to exist- ing government administrative requirementsThe independence of certification is seen as a proxy for credibi-lity: being audited by an independent body offers a more credible • Costs related to potential adjustments in fisheries managementjudgment than a self-assessment. The proliferation and variety of (e.g. there might be a recommendation that catch limits areeco-labels has led to calls for international guidance in the area. In reduced to meet sustainability criteria)response, FAO has produced the “Guidelines for the Eco-Labellingof Fish and Fishery Products from Marine Capture Fisheries”25 The report also identified socio-economic issues in relation toin 2005, and will soon publish the “Guidelines for Aquaculture Eco-Labelling schemes, such as:Certification”.26 • Transparency and participation: standards are set by ‘outsiders’ and imposed on fishers.6.4 Producers: costs and benefits. • Legitimacy: Eco-Labelling schemes are typically developed andEven though a range of costs and benefits has been claimed for controlled by private sector operators or NGOs; some fishersproducers signing up to an Eco-Labelling scheme, there has not would prefer to participate in a public scheme which they consi-been much in-depth analysis of the economics of producers op- der has more legitimacy and some public accountability.erating in fisheries that have gained eco-certifications. As a result,there is a relative dearth of empirical evidence as to the actual • Applicability: concerns have been raised that current schemescosts and benefits. do not lend themselves to multi-species or artisanal fisheries found in developing countries, and they do not take in considera-In late 2008, a Globefish study27 analysed the cost benefits based tion their special needs.on some initial observations, experiences to date and the claimsmade by the eco-label schemes. It identified these potential • Impacts on trade: eco-labels might be used as a barrier to tradebenefits: by importing countries and become “back door” protectionism.• Access to new markets • Governance: certification and labelling depends on the effec- tive public management of marine resources. Poor institutional• Consolidation or expansion of market share in existing markets infrastructures pose a barrier to the certification of fisheries in those jurisdictions.• Greater credibility vis-à-vis retail buyers • Obligatority: fears that schemes that are initially voluntary will• Potential for more value-added products including through prod- eventually become mandatory. uct differentiation (niche markets for environmentally friendly products) EU Market Access & Eco-Labelling l 31
    • 6.4.1 Price premium 6.5 Consumers’ perspective.Whereas extracting information about prices is difficult dueto commercial sensitivities, there does not seem to be much The “explosion” of fish-related labels and certification, in particularevidence of a price premium as a result of the certification of related to farmed fish, has created what has been described asproducts. Pricing is a function of various factors, and an eco-label “eco-label noise”. Consumers may find the wealth of different mes-is arguably not the most significant. Even though most retailers sages confusing; they increasingly put their faith in trusted retai-are unwilling to divulge information about pricing, there does not lers to define the boundaries of their ethical purchasing decisions.appear to be a price premium attached to eco-labelled products ata retail level either. For example: The NZ Hoki fishery managed under an internationally peerMost returns, to both retailers and processors, appear to be more review Quota Management System (QMS) has beenindirect and related to reputation and brand value. certified by MSC since 2001, nevertheless, in 2010 Green- peace added it to its seafood red list30, as Greenpeace For example: believes “the stocks of hoki are now considered to be The New Zealand Seafood Industry Council, SeaFIC, overfished”. 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 Retailers and brand owners filter the various messages and certification noting that: “No plausible case can be made through “choice editing” decide which standards or labels to for a premium for ‘sustainable seafood’. I anything, a well include in their procurement and marketing strategies. Therefore, managed fishery should also be a cheaper fishery to the Eco-Labelling scene is dynamic; some schemes have merged, harvest as the fish should be more abundant and easier to others will do so in years to come, and some may disappear. catch!” 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.6.4.2 Increased market shareResearch in the field agrees that it is too early to tell whether Nevertheless, by their nature, the schemes are always going to beEco-Labelling will become the new norm or “minimum standard” seen as incomplete by some groups and as excessive by others.and what implications that would have for market access. Thereare some indications that fisheries operators feel compelled tobecome certified when their competitors do. 6.6 Eco-labels in developing countries.It is expected, however, that as certification becomes moreprevalent, any potential market share advantage will diminish and Although the driving force for eco-labelled products is in the devel-the usual factors such as price, presentation and brand loyalty will oped countries, the trend towards eco-labels is affecting producingdefine the point of sale choices for consumers. 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 certification32 l EU Market Access & Eco-Labelling
    • Artisanal fishermen in Papua New Guinea• Eco-Labelling schemes do not translate well into the typical con- • The concentration of Eco-Labelling in certain species that are ditions of the fisheries and aquaculture environments in devel- not the main species produced by most developing countries. oping countries (insufficient fisheries management regimes, If their competitors with similar or substitutable species are not data deficiencies, multi-species fisheries, poor environmental eco-labelled, then there is no need for them to be. management infrastructure, low levels of governance and transparency, etc) • The concentration of demand in certain markets: although there is significant demand in pockets of the European and United6.6.1 Weak economic imperatives States markets, in other significant markets such as Japan andThree factors suggest that so far developing countries need not China there is less eco-sensitivity.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). EU Market Access & Eco-Labelling l 33
    • 6.6.2 Certification costs • Certification is often based on a single species fishery charac-Even operators in developed countries complain about the high teristic of developed countries. Developing country fisheriescosts of certification. For developing countries the costs are often tend to be multi-species, with commercial and artisanal fishersprohibitive, including the up-front direct costs of the initial assess- competing for the same stocks.ment process with reliance on outside experts, as well as anysubsequent costs relating to upgrading of gear, facilities, methods • In some cases, literacy is also an issue.or management systems. Where there are multiple stakeholders,deciding who pays and how much, can also be problematic. As These problems have been recognised by the Marine Stewardshipdiscussed above, there is no guarantee of a price premium to off- Council (MSC), one of the best-known Eco-Labelling schemes.set these costs. Where there are catch limits imposed, reductions They have developed new methods to enable certifiers to assessin income and some unemployment might be other indirect costs small and data-poor fisheries against the MSC standard (MSCof certification. Risk-Based Framework), in recognition that many developing country fisheries do not have the detailed scientific data needed6.6.3 Weak institutional capabilities to demonstrate a conclusive case for their sustainability, but maySeveral commentators have raised serious concerns about the nonetheless be able to demonstrate they are operating sustain-institutional ability of many developing countries, as current Eco- ably and can make the case for certification.Labelling fisheries and aquaculture schemes require resourcesand capabilities that are not yet fully available in many developing As modern aquaculture is becoming an industrial means of foodcountry scenarios. production, it can lead to detrimental impacts on the environment and affected communities. In many developing countries thereBelow are some of the difficulties encountered: are constraints on the institutional capacity required to deal with issues, such as:• There is lack of an effective fisheries management regime, which in practice is a prerequisite for certification. Some oper- • appropriate site selection, construction and operation of small- ate under open access arrangements, with weak official controls and large-scale aquaculture operations that minimise environ- over catch limits if and when they exist. mental impacts, such as water and soil deterioration and pol- lution, disturbance and/or destruction of aquatic and terrestrial• There is a lack of accurate data information on existing stocks. habitats, introduction of alien species and disease outbreaks; Certification requires science-based stock assessments for which there is often poor infrastructure (systems and human • integration with fisheries policies as the production of high-value resources). carnivorous fish and crustaceans is often associated with a net loss of aquatic protein resources, as the species being cultivated• There is also inadequate data on catch volumes. requires considerable volumes of fishmeal and fish oil for aqua- culture feed. This increases pressure on wild fish populations;• Small-scale fishers land catch at a multitude of sites for which records are rarely kept. • resource management and allocation as excessive use can lead to conflicts amongst local stakeholders, especially where water• Eco-Labelling schemes are generally data-intensive: in devel- and land resources are scarce; 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.34 l EU Market Access & Eco-Labelling
    • • 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 inWestern Europe.31 In general, organic fish is perceived to be more be directly authorised and monitored by the EC and the Member“natural” and therefore healthier, or even tastier. In some regions States. This new procedure allows the EU Commission to super-the emphasis is on local production, in part to reduce food miles vise and better monitor the import of organic products and thebut also to support regional production. In others, the concept of control of the organic guarantees. A list of recognised thirdorganic aquaculture is focused on small, traditional farms only. For countries can be found in Annex III of the Import Regulation.33example, in France organic aquaculture certification is limited to100 tonnes per site. In other cases there is an emphasis on the Products that are produced and controlled in precisely the same“Fair Trade” concept involving human and labour rights issues. manner as in the EU will also have free access to the common market. Control bodies that intend to undertake such controls6.7.1 EU regulatory framework for organic products must apply to the EU Commission and be authorised by the Com-Until recently, there was a lack of specific organic aquaculture mission and the Member States for this purpose.regulation for third countries. However, a positive step was takenin this matter since 1 January 2009 when the new EU regulation However, since production conditions in third countries are usually(Council Regulation No. 834/2007 of 28 June 2007 on organic very different from those in Europe, it is often not possible to applyproduction and labelling of organic products)32 went into effect for exactly the same rules for production or control. Therefore, it isthe production, control and labelling of organic products. also possible to allow similar rules that conform in principle with the goals and principles of the organic legislation.The Council Regulation applies to agricultural products, includingaquaculture and yeast, either as living or unprocessed products, The EU has created an ad hoc portal for its Organic Farmingprocessed foods, animal feeds, seeds and propagating material. Policy at: ec.europa.eu/agriculture/ organic/home_enThe basis for the acceptance of EU rules on organic aquacultureis laid in article 15 of the legislation. According to the new legisla-tion, European producers of packaged organic food must use theEU organic logo as of 1 July 2010. The use of the logo on organicfoods from third countries is optional.The distribution of organic products from third countries is onlypermitted on the common market when they are produced andcontrolled under the same or equivalent conditions as the EUones. The “old” procedure for import licences is replaced by a newimport regime. Control bodies working in third countries will then EU Market Access & Eco-Labelling l 35
    • 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)?36 l EU Market Access & Eco-Labelling
    • Artisanal fishermen in Sri Lanka6.9 Key fisheries eco-labels. As this publication focuses on EU market access, only some European-operated or EU market-oriented standards and certifi-Different certification schemes certify different things, have cation programmes with strong market presence in the EU havedifferent standards, and use different assessment methodologies. been selected for identification.There is significant variation between schemes in the scope of theassessments conducted. Therefore, this is neither an exhaustive list, nor an endorsement of the schemes identified. A detailed benchmarking analysis of theIn terms of their origin, the fisheries schemes can be promoted by: schemes can be found in Assessment of On-Pack, Wild-Capture Seafood Sustainability Certification Programmes and Seafood• National and regional governments Ecolabels (WWF International 2009).38• Retailers• The fishing industry• NGO-based eco-labels and seafood guides EU Market Access & Eco-Labelling l 37
    • 6.9.1 Marine Stewardship Council 6.9.2 Friend of the Sea (fisheries)The Marine Stewardship Council (MSC) was established in 1997 Friend of the Sea is an Italian-based fisheries and aquacultureas a joint project between the then largest seafood buyer Unilever certification scheme promoted by the Earth Island Institute, anand the international conservation organisation World Wildlife international independent and not-for-profit humanitarian and envi-Fund (WWF). The MSC has operated as an independent organi- ronmental organisation. Friend of the Sea (FOS) was establishedsation since 1999. It sets the standard for the eco-label through its in 2005 and reviews the sustainability of fisheries (and aquacul-board, supported by a Technical Advisory Board. ture) production based on published data.Fishery assessments are conducted by third party certification The FOS scheme works by approving fisheries/products if: (a) tar-bodies, which are in turn accredited as competent to perform MSC get stocks are not overexploited; (b) fisheries use fishing methodsassessments by an accreditation body that is independent of both which do not impact the seabed; and (c) they generate less thanMSC and the certification bodies. For products to carry the MSC 8% discards (the global average estimated in FAO publications).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 Products/fisheries are assessed against: FAO data on stockcustody” through which the product passes from the fishery to the status in different fisheries areas; the IUCN red list of endangeredend consumer. The initial audit is valid for five years with annual species; fishing gear types felt to be harmful to the seabed; IUUsurveillance audits. and Flags of Convenience; and compliance with TACs, use of the precautionary principle, and national legislation.The chain of custody requirement is to protect against productsfrom uncertified fisheries carrying the eco-label. There is an Bureau Veritas or SGS checks the chain of custody (traceabilityindependent dispute resolution process. Currently 187 fisheries and documental evidence) and actual fishing method and compli-around the world are either certified or under assessment. These ance with legal standards.fisheries landed over 7 million tonnes of seafood annually – 12%of the global wild harvest for human consumption. The fisheries There are around 60 capture fisheries products already approvedcertified include large- and small-scale fisheries. under the scheme with certified products sold in 23 countries. Many of the certified fisheries are of small scale and in developingThe MSC has developed new methods to enable certifiers to countries.assess small and data-poor fisheries against the MSC standard(MSC Risk-Based Framework), in recognition that many devel- www.friendofthesea.orgoping country fisheries do not have the detailed scientific dataneeded to demonstrate a conclusive case for their sustainability,but may nonetheless be able to demonstrate they are operatingsustainably and make the case for certification.www.msc.org38 l EU Market Access & Eco-Labelling
    • 6.9.3 KRAV (fisheries) 6.9.4 Naturland (fisheries)KRAV is an association that promotes organic farming. It is Naturland is one of the major certifying organisations for organiccomposed of 28 members who are said to represent the interests produce and it has been one of the pioneering standard organisa-of producers, traders, processors and consumers in addition tions for organic aquaculture development.to protecting the environment and animal welfare. Although thefocus of its activities is in Sweden, KRAV supports international Naturland has developed standards for the production of a wideactivities towards organic farming through its interactions with range of commodities including fruit, vegetables, honey, livestockIFOAM and the European Union. KRAV standards cover several and for forest management. It has a well-developed process ofproduction sectors including crops, livestock, apiculture and aqua- certification and accreditation. This includes third party certifi-culture. Standards are developed and revised by KRAV some- cation bodies, accreditation bodies and objections procedures,times following several rounds of comments and are approved with frequent ISO audits to ensure the accreditation certificationby the KRAV Board of Directors. KRAV standards are applicable systems meet international requirements.to farming and all links in the supply chain including distributors,processors and restaurants. In 2006, Naturland extended its scope to include sustainable inland and marine capture fisheries with the eco-label NaturlandSustainable fishing standards are created to drive development in Wildfish.the fishing industry towards a sustainable fishing and processing.In 2004, KRAV issued standards for sustainable fishing in the The Naturland Wildfish assessment includes social and economicScandinavian jurisdiction. However, since mid 2010, KRAV will sustainability in addition to ecological sustainability. One fisheryalso accept applications for fish stocks outside Scandinavia. has been certified under this eco-label in 2009: the Lake Victoria fishery for Nile perch. It is anticipated that this first assessment willThe standards consist of five sets of rules that cover all aspects of result in further definition and refinement of the Naturland Wildfishfishing, processing, and sales: Quality assurance, Stock assess- criteria and methodology.ment, Fishing vessels, Fishing methods and Landing and proces-sing. These standards were developed for conditions in Scandina- www.naturland.de/naturlandwildfish.htmlvia and are neither tested nor intended for other areas.The KRAV standards also include: requirements concerning fuelused by fishing vessels, the type of motor, the paint used onships, 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 stockenvironment.www.krav.se EU Market Access & Eco-Labelling l 39
    • 6.10 Key aquaculture eco-labels.Different certification schemes certify different things, havedifferent standards, and use different assessment methodologies.There is significant variation between schemes in the scope of ®the assessments conducted. Most of the certification programmesavailable to the aquaculture industry focus on the following issues: 6.10.1 Aquaculture Certification Council The Aquaculture Certification Council (ACC) is a non-govern-• Food Safety: proper food health and safety measures mental body established to certify social, environmental and food safety standards at aquaculture facilities throughout the world.• Food Quality: product quality characteristics This non-profit, non-member public benefit corporation applies the Global Aquaculture Alliance (GAA).• Environment: environmentally sound production processes Best Aquaculture Practices (BAP) in the certification system com-• Social Responsibility: bines site inspections and effluent sampling with sanitary controls, social accountability within the production process therapeutic controls and traceability.• Animal Welfare: issues related to animal welfare and health The GAA has been formed by the aquaculture industry, predomi- nantly by the shrimp sector, to promote sustainable aquacultureIn terms of their origin, the aquaculture schemes can be promoted by: practices throughout the world. It has developed a Code of Good Practice for marine shrimp farming that has been used as the• Retailers basis for BAP for shrimp.• The aquaculture industry• Governments The Global Aquaculture Alliance is currently developing additional• NGOs standards for other species (fish) that may be included in the BAP-• Organic certification schemes Certification programme.• Fair trade certification schemes The Aquaculture Certification Council currently certifies GAA’sAs this publication focuses on EU market access, only some BAP programme for shrimp hatcheries, farms and processingEuropean-operated or EU market-oriented standards and certifi- plants. Independent inspectors who are trained and approved bycation programmes with strong market presence in the EU have the ACC conduct inspections and audits of farms and processingbeen selected for identification. plants.This, however, does not pretend to be an exhaustive list, nor an gaalliance.org/bap/standards.phpendorsement of the schemes identified.A detailed benchmarking analysis of the schemes can befound in Benchmarking Study: Certification Programmes forAquaculture(WWF Switzerland and Norway 2007).3940 l EU Market Access & Eco-Labelling
    • 6.10.2 Global GAP 6.10.3 Friend of the Sea (aquaculture)GLOBALGAP (GG), formerly known as EUREPGAP, is a private Friend of the Sea is an Italian-based fisheries and aquaculturesector body that sets voluntary standards for the certification of certification scheme promoted by the Earth Island Institute, anfood products around the globe. EUREPGAP started in 1997 as international independent and not-for-profit humanitarian and envi-an initiative by retailers belonging to the Euro-Retailer Produce ronmental organisation. Friend of the Sea (FOS) was establishedWorking Group (EUREP). Today GG is an equal partnership of in 2005 and reviews the sustainability of fisheries (and aquacul-producers and retailers who wish to establish certification stan- ture) production based on published data.dards and procedures for Good Agricultural/Aquaculture Practices(GAP). The aquaculture certification scheme has been developed by FOS by involving industry stakeholders as well as NGOs and scientificGG management and normative documents are hosted and bodies.owned by FoodPLUS GmbH, a non-profit industry owned andgoverned organisation. It provides standards and framework for The certification is based on compliance assessment againstthe independent, recognised third party certification of farm pro- FOS’s criteria for sustainable aquaculture (Approval Criteriaduction processes based on EN45011 or ISO/IEC Guide 65. for sustainable Aquaculture), which aim to provide a regulatory framework in accordance with the same main criteria of organicThe GG Integrated Aquaculture Assurance Standard is based on aquaculture standards.the GG Integrated Farm Assurance Standard (for agriculture) andhas a modular composition, which enables farmers to combine Criteria for Sustainable Aquaculture require, among the others,multiple products into one single audit. The aim is to ensure integ- that: an Environmental Impact Assessment or equivalent be runrity, transparency and harmonisation of global aquaculture stan- before the development of the plant; the plant is not impactingdards. The standard includes issues such as worker health, safety critical habitats, such as mangroves, wetlands, etc.; proceduresand welfare, environmental and animal welfare. GG is a pre-farm are in place to limit escapes of fish to a negligible level; no use ofgate standard that covers the whole agricultural or aquaculture GMO and growth hormones; no use of antifouling paints; waste,production process, including production of feed and juveniles/ water, feed and energy management programmes are in place;seedlings in hatcheries. and usage of FOS certified feed (currently for trout, sea bream and sea bass).GG is a business-to-business tool/certification system and istherefore not directly visible to the end consumer. FOS has currently over 12 different species and products certified, most of which are sold in European or US retail chains underwww.globalgap.org private labels. For aquaculture products, the FOS aquaculture standard requires certification by organic standards since the end of 2008. www.friendofthesea.org EU Market Access & Eco-Labelling l 41
    • 6.10.4 Aquaculture Stewardship Council 6.10.5 Naturland (aquaculture)The Aquaculture Stewardship Council (ASC) was founded in 2009 Naturland is one of the major certifying organisations for organicby WWF and IDH (Dutch Sustainable Trade Initiative) to manage produce, and it has been one of the pioneering standard orga-the global standards for responsible aquaculture, which are under nisations for organic aquaculture development. Naturland hasdevelopment by the Aquaculture Dialogues, a programme of developed standards for the production of a wide range of commo-round tables initiated and coordinated by WWF. dities including fruit, vegetables, honey, livestock and for forest management.Currently the ASC is in its business development phase. The ASCis expected to be in full operation by mid 2011. It has a well-developed process of certification and accreditation. This includes third-party certification bodies, accreditation bodiesThe ASC aims to be a global organisation working with aquacul- and objections procedures, with frequent ISO audits to ensureture producers, seafood processors, retail and food service com- the accreditation certification systems meet international require-panies, scientists, conservation groups and the public to promote ments.the best environmental and social choice in aquaculture products.The ASC will offer standards for aquaculture and for the seafood Naturland developed the first species-specific standards in 1995,chain of custody. The standards are being developed by the Aqua- starting with carp, followed by salmonids, bivalve molluscs andculture Dialogues in compliance with the guidelines for standard shrimp. Compliance to Naturland standards is assessed throughsetting established by the International Social and Environmental annual and occasional random inspections conducted by indepen-Accreditation and Labelling Alliance (ISEAL).The certification dent organisations.according to these standards will be in the hands of independent,third-party, and accredited certifiers. To improve the management of organic businesses and ease the process of inspection and certification, Naturland has entered aOnce established, the ASC will develop and launch a consumer- number of initiatives that use IT solutions. The adoption of e-toolsfacing label for responsible aquaculture. is also said to reduce the cost of inspections.www.ascworldwide.org 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.html42 l EU Market Access & Eco-Labelling
    • 6.10.6 Bio Suisse 6.10.7 KRAV (aquaculture)Bio Suisse, a private-sector organisation, is the federation of KRAV is an association that promotes organic farming. It consistsSwiss organic farmers. It is an umbrella organisation that counts of 28 members who are said to represent the interests of prod-32 organic farmers’ associations among its members, as well as ucers, traders, processors and consumers in addition to protectingthe Research Institute of Organic Agriculture (FiBL). Bio Suisse the environment and animal welfare.standards cover not only organic farming but also processing andmarketing of organic products. Although the focus of its activities is in Sweden, KRAV supports international activities towards organic farming through its interac-Conformity to Bio Suisse standards is assessed by inspection tions with IFOAM and the European Union. KRAV standards coverbodies authorised by Bio Suisse; they are selected among bodies several production sectors including crops, livestock, apiculturethat have been accredited by the Swiss accreditation authority. and aquaculture.Only businesses with a Swiss partner (e.g. importers) can applyfor Bio Suisse certification. Bio Suisse also allows for inspection Standards are developed and revised by KRAV sometimesand certification of cooperatives, projects and producer following several rounds of comments and are approved by thegroups based on criteria set by Naturland, IFOAM and FVO (Farm KRAV Board of Directors. KRAV standards are applicable toVerified Organic). farming and all links in the supply chain including distributors, processors and restaurants.In 2000, Bio Suisse adopted standards for organic aquaculture.Standards refer to the farming of organic fish (trout, salmon, carp, The assessment of conformity to KRAV standards is conducted byetc.), although approval for shrimp and mussels may also be an authorised inspection body, which is also authorised to issueobtained if a number of conditions including compliance with the certificates on behalf of KRAV, of which there are presently almostNaturland standards (or equivalent) are met. 50, located in 22 countries across the world.Bio Suisse certified aquaculture products now include salmon and The KRAV scheme offers a wide range of labels to differentiatetrout in Europe and pangasius in Vietnam. products based on the amount of organic material contained, to label production inputs, for export and for wild production.www.bio-suisse.ch 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 EU Market Access & Eco-Labelling l 43
    • 7. Bibliography.This publication has drawn views and information from the fol- IUU catch certification scheme.lowing publications under the different areas: • Handbook on the practical application of Council RegulationSanitary certification. (EC) No. 1005/2008 of 29 September 2008 establishing a Com- munity system to prevent, deter and eliminate illegal, unreported• How to export seafood to the EU. 2nd edn. Blaha, F. Feb 2009. and unregulated fishing (The IUU Regulation). Ref: Mare A4/ By ITC (WTO/UNCTAD). Geneva. http://www.intracen.org/tdc/ PS D(2009) A/12880. http:// ec.europa.eu/fisheries/cfp/illegal_ Export%20Quality%20Bulletins/EQM84eng.pdf fishing/info/handbook_original_en.pdf• Regulatory Alternatives for EU Market Access. Food and Agri- • Addendum to the first edition of the Handbook on the practical culture Organization of the United Nations. Blaha, F. 2008. FAO application of Council Regulation (EC) No. 1005/2008 of 29 Sep- Rome. ftp://ftp.fao.org/docrep/fao/012/i0884b/i0884b02c.pdf tember 2008 establishing a Community system to prevent, deter and eliminate illegal, unreported and unregulated fishing. http://• General guidance for third country authorities on procedures to ec.europa.eu/fisheries/ cfp/illegal_fishing/info/handbook_adden- be followed when importing live animals and animal products dum_en.pdf into the EU. SANCO/10063/2007 Rev.2 2009. http://ec.europa. eu/food/animal/liveanimals/guide_thirdcountries_en.pdf • Technical note – detailed description of the catch certification scheme. http://ec.europa.eu/ fisheries/cfp/illegal_fishing/info/• The Impacts of Private Food Safety Standards on the Food technical_note_en.pdf Chain and on Public Standard-Setting Processes. Henson, S. and Humphrey, J. FAO/WHO. 2009. ftp://ftp.fao.org/codex/ CAC/ • List of Member States and their competent authorities con- CAC32/al329Dbe.pdf 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.pdf44 l EU Market Access & Eco-Labelling
    • Eco-Labelling. Aquaculture • Benchmarking Study on International Aquaculture CertificationFisheries Programmes. World Wildlife Fund (WWF) Switzerland and Nor-• Product certification and Eco-Labelling for fisheries sustaina- way. Zurich and Oslo. 2007. http://assets.panda.org/downloads/ bility. Wessells, C.R. et al. FAO Fisheries Technical Paper 422. benchmarking_study_wwf_aquaculture_standards_new_.pdf Rome. 2001. ftp://ftp.fao.org/docrep/fao/005/y2789e/y2789e00. pdf • Guide for the Sustainable Development of Mediterranean Aqua- culture 3. Aquaculture Responsible Practices and Certification.• Guidelines for the Eco-Labelling of Fish and Fishery Products IUCN Gland, Switzerland and Malaga, Spain. 2009. http:// data. from Marine Capture Fisheries. FAO Rome. 2005. http://www. iucn.org/dbtw-wpd/edocs/2009-061.pdf fao.org/docrep/008/a0116t/a0116t00.htm • A qualitative assessment of standards and certification• Eco-labels and Marine Capture Fisheries: Current Practice and schemes applicable to aquaculture in the Asia-Pacific region. Emerging Issues. GLOBEFISH Research Programme. Washing- FAO Regional Office for Asia and the Pacific. Thailand. 2007. ton, S. Vol. 91. FAO Rome. 2008. http://www.nmfs.noaa.gov/ocs/ RAP PUBLICATION 2007/25. ftp://ftp.fao.org/docrep/fao/010/ mafac/meetings/2008_07/docs/GLOBEFISH_Eco-labels_mari- ai388e/ai388e00.pdf ne_capture_fisheries.pdf • Synthesis of Mediterranean marine finfish aquaculture – a mar-• Certification and Sustainable Fisheries. UNEP Division of Tech- keting and promotion strategy. Barazi-Yeroulanos, L. Studies and nology, Industry and Economics. Macfadyen, G. and Huntington, Reviews. General Fisheries Commission for the Mediterranean. T. 2009. http://www.unep.ch/etb/publications/FS%20certifica- No. 88 FAO Rome. 2010. http://www.fao.org/docrep/013/i1696e/ tion% 20study%202009/UNEP%20Certification.pdf i1696e.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 EU Market Access & Eco-Labelling l 45
    • 8. Endnotes.1A 14 good resource to understand the structure and workings of the However, fishery products from bivalve molluscs, equinoderms,EU can be found at http://europa. eu/abc/12lessons/index_en.htm tunicates, and marine gastropods can be commercialised if they2 (for a complete list see: https://webgate.ec.europa.eu/sanco/tra- have been produced in conformity with section VII of annex III,ces/output/listsPerActivity_en.htm#) and bullet 2 of chapter V of the same section of Regulation CE No.3 For a deeper view into the more technical details, see F. Blaha. 853/2004. 15 For fishery products: vessels, landing sites, transporters, coolHow to Export Seafood to the EU. 2nd edn. Feb 2009. By ITC(WTO/UNCTAD). Geneva. Available from http://www.intracen.org/ stores, processors, etc. For aquaculture products: feed producers,tdc/ Export%20Quality%20Bulletins/EQM84eng.pdf hatcheries, farms, transporters, processors, etc.4 A third country is a non-member country of the EU. 16 Against EU standards or officially equivalent ones.5 17 Regulation (EC) No. 882/2004 of the European Parliament and Regulation (CE) 882/2004 art 12 18of the Council of 29 April 2004 on official controls performed to en- For more information on RASFF: http://ec.europa.eu/food/food/sure the verification of compliance with feed and food law, animal rapidalert/index_en.htm 19health and animal welfare rules. Article 2. Definitions. For example: http://ec.europa.eu/food/food/rapidalert/reports/6Regulation (EC) No. 882/2004. 1.(6). week8-2008_en.pdf7 Regulation 20 (EC) No. 1250/2008 of 12 December 2008. http://eur- Council Regulation (EC) No.1005/2008 of 29 September 2008lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32008R1250 establishing a Community system to prevent, deter and eliminate:en:NOT illegal, unreported and unregulated fishing. An explanation hand-8 FVO homepage http://ec.europa.eu/food/fvo/ir_search_en.cfm book can be downloaded from http://ec.europa.eu/fisheries/cfp/9 For the list of establishments at each of the authorised countries external_relations/illegal_fishing/pdf/handbook_ en.pdf 21 Adapted from: Best Practice Study of Fish Catch Documenta-see https://webgate.ec.europa.eu/ sanco/traces/output/listsPerAc-tivity_en.htm# tion Schemes Phase 1 Report, 2009. MRAG Asia Pacific Pty Ltd10 See Code of Practice for Fish and Fishery Products. 2010. for the UK Department of Environment, Food and Rural Affairshttp://www.codexalimentarius.net/download/ standards/10273/ (DEFRA) 22 Fishing Vessels Monitoring Systems. Usually satellite based,CXP_052e.pdf11 Animal health for aquaculture animals exceeds the scope of this see http://www.fao.org/fishery/vms/en 23publication, but should not be ignored. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012 Official controls of production and placing on the market (Chap- 09:280:0005:0041:EN:PDF 24ter I), Official controls of fishery products (Chapter II), Decisions For a discussion of the theoretical foundations, institutional andafter controls (Chapter III). legal aspects of Eco-Labelling, see, C.R. Wessells et al., Product13 This list is an illustrative one and is far from exhaustive. certification and Eco-Labelling for fisheries sustainability. FAO Fisheries Technical Paper 422. Rome. 2001. 25 http://www.fao.org/docrep/008/a0116t/a0116t00.htm 26 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_grenadier46 l EU Market Access & Eco-Labelling
    • 9. Glossary.29 Alastair Macfarlane, General Manager, Trade and Information at BIP Border Inspection PostNew Zealand Seafood Industry Council. Pers comm. CA Competent Authority30 http://www.greenpeace.org/international/seafood/red-list-of- EC European Commissionspecies EU European Union31 For an in-depth vision of the situation of the organic aquaculture FBO Food Business Operatormarket in Europe refer to: L. Barazi- Yeroulanos. Synthesis of Med- FFP Fish and Fishery Productsiterranean marine finfish aquaculture – a marketing and promotion FVO Food and Veterinary Officestrategy. Studies and Reviews. General Fisheries Commission for GG GlobalGapthe Mediterranean. No. 88. FAO Rome. 2010. http://www.fao.org/ HACCP Hazard Analysis and Critical Control Pointsdocrep/013/i1696e/i1696e.pdf ISO International Standards Organisations32 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:20 IUU Illegal, Unreported and Unregulated fisheries07:189:0001:0023:EN:PDF MB Member Country33 Com Reg. (EC) No.1235/2008 of 8 December 2008 laying NPC National Control Plandown detailed rules for implementation of Council Regulation (EC) RASFF Rapid Alert System for Food and FeedNo. 834/2007 regarding the arrangements for imports of organic RFMO Regional Fisheries Management Organisationproducts from third countries. http://eur-lex.europa.eu/LexUriServ/ SPS Sanitary and Phytosanitary (measures)LexUriServ.do?uri=OJ:L:2008:334:0025:00 52:EN:PDF SMEs Small and Medium Enterprises34 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 andfish 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 EU Market Access & Eco-Labelling l 47
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