Memorandum submitted by the National Federation of Fishermen's Organisations (SFS 48)




The NFFO is the representative body for fishermen in England, Wales and Northern Ireland. Our member vessels range from 40 metre stern trawlers operating at North Norway and Greenland to small, under 10 metre vessels, beach launched and with limited range. The Federation holds seats on the EC Advisory Committee for Fisheries and Aquaculture, and the North Sea, North West Waters, Pelagic and Long Distance regional advisory councils. The NFFO is also a member of Europeche, the European trade federation for the fishing industry.






The NFFO is concerned with the capture of wild fish and shellfish, and its responses reflect this fact and do not comment on matters that affect other areas of the food system.






Robust is taken to mean the ability to respond and adapt to changing circumstances. The commercial fishing industry exhibits many indications of strength, but there are areas of weakness.


It must be remembered that the UK fishing industry is governed by the Common Fisheries Policy, CFP which has the achievement of Maximum Sustainable Yield, MSY, as a key objective. The CFP applies in UK waters not only to UK vessels but also to other European fleets. For key species, the CFP currently sets how much may be caught, how many days may be spent at sea, what gear may be used, and how the catch may be marketed. Although there is currently a move towards Long Term Management Plans for these species (which are aimed at increasing stocks), and progress has been made, a degree of inflexibility remains. The institutional process means that responses are slow and, currently, bureaucratic.


Nonetheless, it must also be understood that the fishing industry is in a permanent state of change. Fish have never stayed in the same place waiting to be caught and as a result the industry has always had to adapt. It adapts temporarily through changing the time when species are targeted: it adapts spatially by changing the area that is fished; and it adapts by changing the species that is targeted.


Furthermore, the marine environment is not static but constantly changing. The hydrological patterns change and there are Cycladic shifts in currents. Temperatures constantly vary over the year and among years. Salinity alters. The fishing industry is inevitably forced to respond and adapt.


Whilst individual vessels may be flexible in their responses, the industry as a whole is capital intensive and therefore not very flexible. Large amounts of capital are tied up in vessels which inhibit exit from and entry into the industry. In addition, if there is no excess capacity it will take time for the industry to respond to an increase in demand with a new vessel taking well over a year to commission and more likely two.


For these reasons, the fishing industry exhibits both strengths and weaknesses. The weaknesses are institutional and structural. The strengths are in the adaptive ability of those who work in the industry.





The UK runs a deficit on trade in fish products. Currently c.60% of global fish production is traded. In 2007 the UK imported 782,000 tonnes (1,847 million) and exported 438,000 tonnes (923 million). It should be noted that the value will alter substantially according to the strength or weakness of sterling. Cod, haddock, tuna and shrimp and prawns are the chief imports, whilst herring, mackerel and shellfish are the main exports. In general terms, exports cannot be substituted for imports, and vice versa.


In addition, it should be stressed that the supply of fresh fish (as opposed to frozen) is always subject to seasonality and fluctuations in market supply. This characteristic acts as a negative attribute in a world where consumers (and by extension processors) expect a constant supply of fish species throughout the year.


Estimates of consumption vary, with the FAO estimating over 1 million tonnes a year, whilst UK statistics imply 666,000 tonnes in 2006. On the basis of the UK statistics, the population eats roughly one portion of fish a week, which means that in order to reach the suggested two portions of fish would require a doubling of supply. This effectively means that there needs to be a major increase in the availability of white fish either from imports or increased domestic supply. If this proves difficult to attain then eating habits will have to be changed and demand re-orientated to other species and shellfish.


The ability of the global market to respond to these challenges is by no means guaranteed. The Pacific, which provided much of the increased catch in the past, is starting to be over-exploited and aquaculture is unlikely to be able to continue the rapid expansion of past years. In addition, domestic requirements in emerging economies are likely to reduce the type, and amount, of fish reaching the international market.


Concerns about sustainability and the drive towards stock recovery in the seas around the UK have meant restrictions on catching within the EU' Common Fisheries Policy, CFP. Although, in the longer term it is expected that fish stocks will recover there is no certainty that they will reach previous levels due to changes in the marine environment and climate change. Furthermore, the reduction in capacity after de-commissioning schemes means that there exists the possibility of a lack of skilled, trained, personnel.


As a result, the UK industry is not presently in a strong position to immediately increase landings to meet projected increased demand or to make good shortfalls in international availability. Looking towards the future, however, the increased prevalence of Long Term Management Plans should lead to sustainable, higher, stock levels permitting the industry to respond more rapidly to increases in demand.





Whilst it is in the interests of all to pursue the goal of sustainability of fish resources, it should be borne in mind that the blanket closure of large areas of our seas to create Marine Protected Areas, MPAs, has the potential to further reduce the responsiveness of the UK fishing fleet if these areas become No Take Zones, NTZs, by excluding all fishing activities from some of the most productive sea areas.


Otherwise, because the impact of climate change is relatively gradual, the fishing industry is already responding and adapting to different conditions. Fishing is constantly changing its fishing patterns and diversifying into other species. The need is to encourage the consumption of fish and shellfish which, at the present time, consumers are unwilling to try.




A key role for DEFRA lies in ensuring that the CFP functions more effectively than it has done in the past. Reducing the level of micro-management by the Commission and increasing support for the regional approach evidenced by the Regional Advisory Councils, RACs, is highly desirable. Improving the transparency (and legitimacy) of the CFP is important for achieving the goals of sustainable, economically viable fisheries for the food supply system.


At another level, it is not helpful to have various Government Departments and NGPDs seeking to expand their remit from consumption into the production side of the food supply chain. Although attention has recently been given to the question of food there is at the present time no national food strategy. Clear lines of responsibility for food supply should lead back to DEFRA.





Extensive monitoring already exists for the catching fisheries through MFA in order to meet CFP requirements on landings, capacity and profitability.


In addition, details as to the per capita consumption in the UK of fisheries' products and the rate at which it is increasing, or decreasing, should be improved.


Perhaps additional attention should be given to establishing by species an index of the desired percentage to come from imports and observing its progression.


Whilst sustainability is an important objective, care should be taken to ensure that the definition is clearly defined and understood. In a mixed fishery such as the North Sea, for example, MSY is a desirable objective, but it should be borne in mind that it is impossible for all species to be at MSY levels at the same time given the inter-relationships and the predator/prey factors involved.





The contribution of fish to the security of food supplies depends upon the ability of the domestic industry to provide a substantial portion of the products consumed. At the present time the industry does not produce sufficient products that the consumers want and the shortfall is made good from imports. Since the UK exports certain species of fish and shellfish, the gap could be reduced if consumers' tastes altered.


The current state of key stocks, and the CFP, means that, although the fishing industry has the potential to do so, it is not in a position to respond quickly to increases in demand. Although the signs are that stocks are recovering, the institutional rigidities engendered by the CFP mean that response time is slow.


Thus, fisheries will make a contribution to meeting the increase in demand forecast for 2030, but it is unlikely to be on the same scale as the projected increase.


National Federation of Fishermen's Organisations


January 2009