36.Globally a third of fish stocks are overfished. Professor Boyd, Chief Scientific Adviser for the Department for Environment, Food and Rural Affairs, told us that although it is not getting worse, overfishing is still probably the number one threat to the health of the oceans. Unsustainable fishing, in the UK and elsewhere, causes a decline of populations of non-target species which are caught accidentally. For example, it has been estimated that between 160,000 and 320,000 seabirds are killed annually in longline fisheries across the world. One of the biggest threats to corals and other seafloor habitats is from fishing practices such as bottom trawling, which can damage or destroy corals and habitats. Sustainable fishing practices could help reduce wider biodiversity loss and the risk of damage to deep sea habitats and ecosystem function. Market-based mechanisms can be used to recognise, reward and incentivise sustainable fishing as a compliment to robust fisheries policy and legislation. Our inquiry has looked specifically at the effectiveness of the Marine Stewardship Council certification scheme’s contribution to sustainable fisheries.
37.The Marine Stewardship Council (MSC) was founded in 1997 by WWF and Unilever (then owner of major seafood brands Birdseye and Iglo) and has been independent since 1999. It is one of the world’s most recognised certification schemes for wild capture fisheries with its ‘blue tick’ label denoting a fishery has scored highly against the MSC’s sustainability criteria (see box). Over four hundred fisheries, landing 10 million tonnes of seafood per year are engaged in the programme, certified or under full assessment, including small-scale fisheries in Asia, Africa and Latin America; over 50 per cent of UK landings are MSC certified.
Marine Stewardship Council certification
Fisheries are assessed by independent third-party accreditors (Conformity Assessment Bodies - CABs) against the MSC’s standard for environmentally responsible and sustainable fishing, which is based on the United Nations Food and Agricultural Organisation’s Code of Conduct for Responsible Fishing. They receive a score out of a hundred for each of 28 sustainability indicators. If a fishery scores below 60 it fails to be certified, if it scores between 60–79 for any indicator it must improve its performance within a specified time frame to gain or retain certification. Certified fisheries must score an average of at least 80 for indicators within each of the three principles of the MSC Standard: Sustainable fish stocks, minimising environmental impact and effective management. Assessments can take 8–24 months, depending upon the complexity of the fishery.
38.The MSC has met Global Sustainable Seafood Initiative (GSSI) certification, one of five certification schemes in the seafood sector, and we heard that the alternative labelling and certification systems (FairTrade, ASMI, Friend of the Sea, Marine Ecolabel Japan) are not nearly as rigorous or stringent. The MSC is the only wild-capture fisheries certification and ecolabelling programme that meets best practice requirements set by both the United Nations Food and Agricultural Organisation (UNFAO) and ISEAL Alliance. We received many submissions supporting the MSC and providing evidence of where it has led to improvements in sustainable fishing practices, and a number calling for the MSC to review and improve its processes and standard. One witness described it as a force for good that had lost its way, while another said that the bar is becoming too high even for world leading fisheries.
39.The NGO collective Make Stewardship Count suggested that an increasing number of controversial fisheries “that have long-lasting negative impacts on vulnerable species and sensitive habitat” have received MSC certification or have been recertified. Another coalition On the Hook, has called for the MSC to “urgently review its Standard” with regard to the fishing of tuna in the Parties to the Nauru Agreement (PNA) fishery. The use of nets to catch free swimming tuna in the region was certified by the MSC in 2011, but it has been reported that the same vessels can also use other more damaging techniques that generate more by-catch on the same fishing trip, including the capture of protected species (see box). This is called a compartmentalised fishery. The MSC allows fisheries to define their target stock, management area, fishing gear and vessels, their Unit of Assessment. On the Hook consider that fisheries entering the MSC programme should be assessed holistically looking at all the activities that take place within it. It also has concerns that shark finning is taking place within the PNA Fishery which is banned by the MSC standard and the PNA nations.
Fishing gear types in tuna fisheries
Purse seine fishing involves a net being put into the water to encircle a school of tuna. The bottom of the net is then drawn together, trapping them. The net may be placed over a school of tuna swimming in the open ocean. The levels of bycatch are lower because it is less likely that other marine mammals or fish will be trapped. Tuna can be difficult to locate in the open ocean, so fishers can rely on Fish Aggregating Devices (FADs), originally natural objects around which small fish congregate, attracting larger fish such as tuna, but latterly manmade devices. Due to the development of communities around these devices, setting a purse seine net on a FAD involves much more by catch of non-target species and juvenile tuna.
40.We asked Rupert Howes, Chief Executive of the MSC, why it allowed compartmentalised fisheries to be certified. He told us that the MSC, like all market-based programmes, allow the Unit of Assessment to be defined by the client, to “try to give advantage to those units that are operating sustainably”. He pointed out that the MSC cannot differentiate between gear types because it follows the UNFAO guidelines for certification. Only the sustainable catch is certified, and the independent certifiers have onboard observers who ensure the catch is completely segregated.
41.In January 2018, the MSC Board considered the issue of compartmentalised fisheries and “determined its preferred solution”, but further stakeholder engagement identified that the “proposed solution could not readily be operationalised”, and consultation was therefore re-opened for further input in August 2018. The MSC told us that since then it has been in the process of reviewing its Standard and it will incorporate the submissions from On the Hook and Make Stewardship Count and other stakeholders. It said the proposal by its critics to complete the review by the year end, “suggests they do not appreciate the scale of the task of reviewing a 700-page Standard alongside new developments in science and fisheries management”. The MSC also explained its view that Governments and international fisheries management agencies are responsible for ensuring fisheries are sustainable:
We want to see global fisheries fish sustainably. It does not mean they have to be MSC certified. Yes, we do have concerns on policy, but we are not a policy organisation or an advocacy or a campaigning organisation. It sounds a bit boring, but we are a crusty old standard setter trying to use certification, labelling and science to influence behaviour. That is our contribution to shifting the entire sector.
42.We asked WWF, one of the founders of the MSC, what it made of the criticism. Dr Louise Heaps, Head of Blue Economy at WWF told us that the MSC has been “a game changer globally over the last 20 years”. Yet she considered the external environment had changed a great deal and consumers are now expecting a lot more in terms of governance for the whole ecosystem and not just on the target species. Dr Heaps also explained that WWF had concerns on the independence of the certifying bodies:
Many fisheries out there are certified well and are acting well and we are happy with them, but we have experienced cases where we have felt that there was not full independence with regard to the certifier. […] We are suggesting that the system should be tightened to make sure that the certifier is not the only body finalising and making decisions and that the best scientific evidence that is out there is leading the decisions and making them robust.
43.The MSC told us it is subject to regular independent review and evaluation; it undertakes a comprehensive and systematic review of its own Standard every five years. The Conformity Assessment Bodies that undertake the certification process are accredited by an independent accreditation body, Accreditation Services International (ASI). ASI told us that in the past five years, it has placed four CABs under suspension from the MSC Fisheries programme. Dr Heaps suggested that a third arbiter could be brought in if there was no agreement between a peer reviewer, a stakeholder and the certifying body.
44.Charles Redfern, from Fish4ever, expressed serious concerns that the MSC is “not viable” for the small-scale fishing industry:
By their definition they favour large-scale industrial boats, and if you look at it from a global statistics point of view, small-scale fishing is far better in terms of bycatch, discard and environmental impact … I think it is very important that the small-scale fishing industry, which is also disadvantaged by economic factors and competitive factors, is not disadvantaged by a sustainability certification.
He added that small scale fishing can be hampered by others overfishing in the same area. Sönke Fischer from ASI said that most standard systems are harder for small scale producers to access and a review of barriers to entry may be helpful. Rupert Howes explained that the MSC has helped to engage small scale fisheries, for example through the UK Project Inshore, an eight-year project with Defra. Dr McQuatters Gollop from the University of Plymouth noted that, as large fisheries generate more CO₂ than smaller fisheries due to their ships travelling over longer distances, carbon should be factored into the MSC standard.
45.Under its 25 Year Plan for the Environment, the Government has committed to implement science-based plans as part of its approach to managing fisheries sustainably and to recovering fish stocks to sustainable levels in the shortest time feasible. Defra told us that fisheries companies using certification standards such as those provided by the MSC and retailers stocking products with fisheries ecolabels, are playing key roles in tackling the challenge of unsustainable fishing. Lord Ahmad said that the Foreign and Commonwealth Office believed certification to be one of the solutions to tackling the challenge of unsustainable fishing and pointed to the successful recovery of cod stocks in the North Sea. Specifically on the MSC, Claire Perry noted that the Government do not have a view as to whether it is the right scheme or whether there might be another scheme that is better.
46.The Marine Stewardship Council standard is the market leader and the most rigorous certification in the seafood sector. We heard evidence that it is driving incremental change towards sustainable fish stocks through improvements in fishing practices, but there were concerns with the holistic assessment of fisheries and the inclusion of small scale fisheries. To ensure continued consumer confidence in the Marine Stewardship Council certification, we recommend the MSC addresses specific criticisms raised by WWF, Prof Callum Roberts and others into its five-year review and strengthens its standard accordingly. These criticisms include its unit of assessment, the need to factor in carbon from ships into its standard, concerns about shark finning (where we look forward to the publication of data verifying the reduction of this practice in 2019) and barriers to entry for small scale fisheries. The review should be transparent and ideally independently evaluated. Ultimately voluntary, market-based schemes will never be applicable or relevant to every fishery. The responsibility for managing and overseeing fisheries and ensuring their sustainability lies with policymakers both at the national and international level, whether it be individual governments or regional bodies such as the European Union.
47.Aquaculture—or fish farming—now provides half of all fish for human consumption globally and by 2030 it may be as much as 63 per cent. The University of Exeter’s Centre for Sustainable Aquaculture Futures (SAF) argues that aquaculture is the only foreseeable way to sustainably intensify seafood production to meet the projected growth in human population. The UK is one of Europe’s leading aquaculture producers. It is dominated by Atlantic salmon and blue mussels with 99 per cent of UK finfish production based in Scotland and 47 per cent of UK shellfish produced in England and Wales. Agriculture, fisheries and environment policies are devolved to Scotland.
48.In 2018 the Scottish Parliament Environment, Climate Change and Land Reform Committee (ECCLR) conducted in depth inquiry on the environmental impacts of salmon farming. It found that of the 227 salmon farms in the sea, 22% are within Marine Protected Areas. The report identified further issues within the industry (for example, sea lice, disease and discharge of medicines, the sustainability of feedstock, waste and the impacts on wild fish), and was deeply concerned that growth of the sector is taking place without a full understanding of the environmental impacts. It recommended an independent assessment of the environmental sustainability of the predicted growth of the sector.
49.Aquaculture is more space efficient than agriculture and salmon production has lower CO₂ emissions compared to pork or beef. Fish are also more efficient producers of protein than cows or chicken. In the wild, salmon eat other fish and marine animals. On farms, most species are fed a carnivorous diet comprising fishmeal and fish oil derived from wild caught species of small non-native pelagic fish (fish that live in the open seas) such as anchovies, herring and sardines. Professor Boyd, Chief Scientific Adviser for the Department for Environment, Food and Rural Affairs, raised concern over the sustainability of fish feed and its impacts on the food chains in the Southern Ocean:
Essentially we feed fish to fish, so we catch fish in various parts of the world, process them into salmon food, and then feed them to salmon. That is highly inefficient. The environmental impacts of that are felt in places like Antarctica, because Antarctic krill are fished partly for that purpose.
Dr McQuatters Gollop from the University of Plymouth also stressed that the diverse Southern Ocean food web is largely dependent on availability of krill (small crustaceans). The ECCLR Committee concluded that the current source of fish meal and fish oil are at “maximum sustainable yield” and there is not enough sustainable fish produced to expand Scottish aquaculture. We put this to Ben Hadfield from the Scottish Salmon Producers’ Organisation, he told us:
We buy a lot worldwide. Basically, everything that we have is certified […] by the International Fishmeal and Fish Oil Organisation. That standard says that the total allowable catch is sustainable relative to the biomass. It is not as advanced as MSC […] Fisheries is moving towards MSC certification for feed-grade fisheries in fishmeal and fish oil.
Fishmeal can be replaced with specific plant and vegetable alternatives, however a differentiator for consumers is that Scottish salmon has high marine oil content in its diet which provides health benefits (Omega 3 essential fatty acids). SAF told us that replacing fishmeal and fish oil has now reached its limit without affecting fish health and the quality of the product. Research and development is ongoing into alternative sources of feedstock including algal fermentation and genetically modified (GM) oil seed plants so that the industry is able to grow without utilising more fish. Mr Hadfield told us that “GM crops will not be acceptable within Europe” and he hoped algal fermentation would become cost effective and scalable in time.
50.Guy Linley-Adams, representing Salmon and Trout Conservation Scotland (S&TCS) told us its main concern on aquaculture is the impact of open-cage salmon on wild salmon and sea trout, particularly regarding sea lice. Sea lice reproduce in numbers many orders of magnitude higher than any natural background on Scottish salmon farms which wild salmon have to pass as they emigrate from rivers. Sea lice are naturally occurring marine crustacea that attach to the skin of salmon and harm the fish by feeding on skin and blood. They can be treated with pesticides although there is a concern that these treatments are costly (currently £70 million per year), not fully effective and sea lice may be becoming resistant to treatment. S&TCS are concerned that if the industry expands, the problem of sea lice will increase with it.
51.The majority of finfish farming takes place in floating net cages in freshwater lochs or coastal waters. Discharges of feed and waste along with dissolved residues of medicines used to treat disease or parasitic infection may pose a risk to the environment. We heard that these discharges have been known to cause biotoxin contamination of shellfish and other marine biota. Ben Hadfield told us that the environment around the farms assimilates the waste without causing eutrophication and this is the reason the industry has such a low CO₂ profile and the reason why salmon farming is so efficient. Dr Hughes, from the Scottish Association for Marine Science (SAMS) confirmed that waste is assimilated within the environment and he felt the process was “well regulated”. He added that there is a recognition by the aquaculture industry that it is dependent on good environmental status of the waters its farms are in and, therefore, has an interest in developing innovative technology. We also heard that the stocking densities in Irish farms were lower than in Scotland.
52.Salmon and Trout Conservation Scotland recommend that over the medium to long term the industry should move into closed containment technology, whether that is floating at sea or on land, so there is a biological separation between farmed fish and wild fish. We asked Ben Hadfield how much recirculating aquaculture systems would cost, he said another company was “spending close to £50 million” to produce 1000 tonnes of fish at any one time. He added that to create capital infrastructure on land to replace that which is already in the sea in Scotland would cost around £2 billion. He added that the positive CO₂ benefits would be lost by building “huge concrete structures, which are hugely hungry in power”. We asked Dr Hughes for his view on whether there should be a moratorium on open cage salmon farming and he thought more research was needed:
I do not think that there is enough evidence to say that there should be a moratorium. There needs to be more scientific research to establish what the major impacts are, and we lack a major risk assessment for the industry.
The ECCLR Committee also noted concerns about the energy consumption, visual impact and availability of suitable sites for closed containment systems. It called for independent research to be commissioned including a full cost-benefit analysis of recirculating aquaculture systems, with a comparative analysis with the sector as it currently operates in Scotland.
53.Lord Ahmad wrote to us to confirm that the all feed in the Scottish salmon farming industry uses 100 per cent International Fishmeal and Fish Oil Organisation or MSC certification. He said the Scottish Government is supportive of the exploration of alternative feed sources and has provided £11.1 million to establish the Scottish Aquaculture Innovation Centre (match funded by industry) which is exploring alternative protein sources for fish feed. He also added that “while the Scottish Government has said it will ban the cultivation of GM crops in the open environment, it is up to the industry to decide whether or not to use EU approved GM feed”. Lord Ahmad noted that the annual krill catch is around 0.3 per cent of the unexploited krill population in the Southern Ocean. He said the issue had not been directly raised with the Foreign and Commonwealth Office in the context of the development of the International Ocean Strategy, but he could see its relevance:
One of the aims of the strategy is to ensure that the Government looks holistically at these interconnected economic and environmental issues such as how we can promote sustainable aquaculture that helps wild fish stocks recover from overfishing, but without causing other environmental impacts.
The management of protected areas in the Southern Ocean is discussed in Chapter 6: International Leadership.
54.Since our inquiry the Scottish Environmental Protection Agency (SEPA) has published a study which found that medicines from Scottish salmon farms is significantly harming local marine environments. It has announced “evidence-based proposals for a revised regime that will strengthen the regulation of the sector”, including a new tighter standard for the organic waste deposited by fish farms, a new approach to sustainable siting of farms and an enhanced environmental monitoring and enforcement unit.
55.By 2030 as much as 63 per cent of fish for human consumption could come from aquaculture. Salmon is a net producer of protein and can be a sustainable source of food provided that its feed is sustainably sourced, and its environmental impacts are mitigated. We welcome and support the precautionary approach of the Scottish Parliament’s Environment, Climate Change and Land Reform Committee suggesting that independent assessments are needed on the environmental sustainability of the predicted growth of the sector and a full cost-benefit analysis of closed containment systems. We also welcome the Scottish Environmental Protection Agency’s proposals for a revised regulatory regime, including the sustainable siting of fish farms and tighter standards for the release of organic waste. The Government has recognised that aquaculture and marine conservation are interconnected economic and environmental issues and we look forward to this being reflected in its International Oceans Strategy to help ensure that wild fish stocks recover from overfishing.
111 Currently 33.1 per cent are fished beyond biological sustainability. UNFAO. 2018.
113 Anderson ORJ, Small CJ, Croxall JP, Dunn EK, Sullivan BJ, Yates O, Black A. 2011. . Endangered Species Research 14:91–106
114 RSPB (); Marine Stewardship Council (); Pew Trusts ()
115 Marine Stewardship Council ()
116 The Global Sustainable Seafood Initiative (); California Environmental Associates ()
117 Marine Stewardship Council (); ISEAL Alliance () The ISEAL Alliance is the global membership association for sustainability standards.
118 E.g. Zoological Society of London (); Marine Biological Association (); Professor Michel Kaiser (); Dr Simon Jennings (); RSPB (); Wageningen Marine Research (); Scomber consultancy (); BirdLife South Africa (); Sustain: The Alliance for Better Food and Farming (); Southern Inshore Fisheries and Conservation Authority (); Aquaculture Initiative EEIG (); Fair Seas Limited (); Thuenen Institute of Baltic Sea Fisheries (); Deepwater Group (); see also California Environmental Associates ()
119 E.g. Make Stewardship Count (); Earth Island Institute (); On The Hook (); Fish4Ever (); Richard Page (); Austral Fisheries Pty Ltd (); Professor Callum Roberts ();
120 Professor Callum Roberts ()
121 Norwegian Fishermen’s Association (NFA) ()
122 Make Stewardship Count () Make Stewardship Count is a collective of marine conservation organisations, academics and researchers, animal protection organizations, and individuals. In January 2018, the group sent an open letter to the Marine Stewardship Council outlining concerns and a series of specific recommendations.
123 Signatories to On the Hook () (Oct 2018) include Lewis Pugh, Hugh Fearnley-Whittingstall, World Wise Foods, Bloom, American Tuna, Blue Marine Foundation, Woolworths South Africa, David Suzuki Foundation, Ocean Harvester Operative, Ecology Action Centre, Island Conservation Society, SharkProject, Environmental Justice Foundation, Fish4Ever, Forest & Bird, Fair Fish, Turtle Island, Richard Benyon MP, James Heappey MP, Simon Clarke MP, Paul Scully MP, Professor Callum Roberts, Professor Jennifer Jacquet, Professor Megan Bailey, Dr Thomas Appleby, Dr Phillippe Cury.
124 PNA Members are Federated States of Micronesia, Kiribati, Marshall Islands, Nauru, Palau, Papua New Guinea, Solomon Islands and Tuvalu.
125 , The Guardian, 31 Aug 2018
126 On The Hook (); On the Hook (); Dr Simon Jennings ()
127 On the Hook ()
128 On the Hook ()
129 On The Hook ()
133 Marine Stewardship Council ()
135 E.g. Sharkproject International e.V ()
136 , 9 Oct 2018
140 Marine Stewardship Council ()
141 Accreditation Services International (); Marine Stewardship Council (); Dr Simon Jennings ()
144 Charles Redfern ()
146 ; see also Southern Inshore Fisheries and Conservation Authority ()
148 HM Government. 2018.
149 Department for Environment Food and Rural Affairs ()
150 11 November 2018
152 UN Food and Agricultural Organisation. 2016.
153 Centre for Sustainable Aquaculture Futures ()
154 33% in Northern Ireland; 20% in Scotland for 2008. MCCIP. 2011. impacts report card and Centre for Sustainable Aquaculture Futures ()
155 Environment, Climate Change and Land Reform Committee, , 5 March 2018
156 Centre for Sustainable Aquaculture Futures (); ; It takes around 700 grams of wild fish to produce over 1 kilo of farmed salmon,
157 Arup ()
159 ; see also Friends of the Sound of Jura ()
160 Environment, Climate Change and Land Reform Committee, , 5 March 2018
162 Scottish Salmon Producers’ Organisation ()
163 Centre for Sustainable Aquaculture Futures ()
167 Salmon and Trout Conservation Scotland ()
169 Scottish Environmental Protection Agency. [Accessed 25/09/2018]
170 Mr Allan Berry ()
171 ; Scottish Salmon Producers’ Organisation ()
177 Environment, Climate Change and Land Reform Committee, , 5 March 2018. p55
178 11 November 2018
179 11 November 2018
180 , SEPA, 7 Nov 2018
181 , SEPA, 7 Nov 2018
Published: 17 January 2019