Memorandum by Sainsbury's plc
INTRODUCTION
— We are pleased to be able to respond
to the Committee's inquiry into the Common Fisheries Policy. We
are one of the biggest fish retailers in the UK, selling over
£400 million worth of fish in our stores last year. We have
over 300 fish counters in our stores across the UK, and are the
UK's largest retailer of MSC-certified fish, both in terms of
range and turnover. We are committed to doubling this figure by
the end of this year.
— We thought it would be helpful to
the Committee if we put in context our approach to sourcing fish
sustainably. We have also answered some of the questions posed
by the Committee on the CFP.
OUR WORK
ON SOURCING
FISH SUSTAINABLY
— Our sustainability rating system:
In 2006 we conducted a major review of our fish sourcing policies.
We worked closely with the Marine Conservation Society and a number
of other key stakeholders, including suppliers, boat skippers,
aquaculture experts, government representatives and specialist
campaigning organisations. This led to the development of our
own sustainability rating system. Working on a traffic light basis,
the system gives a sustainability rating for all the fish we sell:
Green means the fish has been scientifically
verified as in plentiful supply and is fully sustainable.
Amber means there are some concerns about sustainability,
but action is being taken to resolve them.
Red means there are major concerns about sustainability,
so we will not sell it.
— As a result of this system, we no
longer sell any red-rated fish and are working with suppliers
to move any amber-rated fish to green status. We have already
removed skate and huss from our shelves, and now take squid from
a more sustainable source as a result of this assessment process.
— 80% of the fish we sell comes from
five species—cod, haddock, salmon, tuna and prawns. This
places huge pressure on the stocks of these species. Through the
development of our rating system we hope to move all these species
to "green" by 2010.
— Sustainable fishing practices: Alongside
our rating system, we also work to develop higher standards of
sustainability in fishing practices. Examples include:
(i) Wild: Line-caught wild fish: Line-caught
is a less destructive, more sustainable alternative to trawling.
It also ensures that fish suffer minimal stress and damage during
capture. 100% of our fresh cod and haddock is now line-caught,
accounting for nearly 10,000 tonnes a year. This makes us the
largest retailer of line-caught cod and haddock in the UK. Furthermore,
fresh line catching vessels fish for shorter periods—from
one to three days maximum. Robust environmental assessments: We
carry out environmental impact assessments using independent scientific
data. Where data is lacking, we have commissioned further studies.
Where we are aware of particular risks relating to fishing methods
or species, we have commissioned independent scientists to verify
the sustainability rating that we have given to the species that
we sell.
(ii) Farmed: Sustainable feed: The origin
of feed for our farmed fish is an important issue. We therefore
apply our sustainability rating system to species used for fish
feed, ensuring our processes are sustainable right the way through
from egg to plate. Reducing pollutants: We avoid substances that
may pollute the marine environment. For us, sustainable fisheries
and protection of the marine environment go hand in hand: it is
impossible to address one concern whilst neglecting the other.
For example, we are working closely with our suppliers to eliminate
the use of anti-foulants for cleaning fishing nets. We are encouraging
our suppliers to return to traditional manual methods of cleaning
their nets.
— We also stock the widest range of
MSC-certified products, currently offering over 20 MSC-certified
fresh and processed products. Furthermore, in January 2008, we
became the first retailer to introduce MSC-certified canned tuna—Albacore
tuna.
— Promoting sustainable alternatives:
Offering more sustainable alternatives to our customers is an
important part of our approach. We have recently reintroduced
more sustainable alternatives to cod, such as pollock and hoki.
We now buy more local pollock than any other UK retailer.
— We promote these alternatives to
our customers through use of recipe "Try" Tip Cards,
our "New In Season" promotions and the Sainsbury's Magazine.
Our trained fish counter staff also offer advice on cooking and
preparation.
STAKEHOLDER ENGAGEMENT
— We engaged with stakeholders throughout
the development of our rating system, as well as on specific issues,
and we continue to share best practice through the fishing industry.
For example, our discussions with Greenpeace on beam-trawling
contributed to our decision to move our cod and haddock to line
caught methods.
— Seafood Retailer of the Year: In
September 2007, in recognition of our positive contribution to
the fishing industry, we were awarded the Seafish "Seafood
Retailer of the Year" Award.
THE ISSUES
CONSERVATION/MANAGEMENT
1. Chapter II of Regulation 2371/2002 on the
conservation and sustainable exploitation of fisheries resources
under the Common Fisheries Policy introduced new methods of ensuring
conservation and sustainability, including recovery plans, management
plans and emergency measures. To what extent have these been effective?
These are welcome additions to the CFP and we
have seen some positive effects already, such as a recovery in
some fish stocks. This is a result of the increased management
of fisheries and the enforcement of quotas.
We support and appreciate this range of measures
within the CFP on the basis that they are supported by adequate
scientific evidence in order for the International Council for
the Exploration of the Seas (ICES) to accurately model the impact
of such measures on fish stocks.
2. A wide range of management tools are available
to fisheries managers. What are your views on the following tools:
a. Total Allowable Catches
b. Effort limitation, including "days
at sea", marine conservation areas and real-time closures
c. Rights-Based Management tools
d. Technical Conservation Measures
Total Allowable Catches: All of these are welcome
components of the CFP. TACs play a major role in most fishery
management processes and, if implemented and enforced effectively,
are important ways of reducing levels of discard.
We are, however, concerned that TACs are difficult
to enforce in fisheries where discarding takes place at a significant
level. A quota system, which allows fish that are either over-quota
or under-sized to be discarded, is severely flawed. The CFP must
take a fresh look at eliminating discarding through enhancements
to the TAC rules.
Days at sea: These are also an effective means
of effort limitation but the interaction between TACs and days
at sea is a complex one and needs further consideration.
There is a clear and overwhelming body of evidence
which suggests that fishery closures and Marine Protected Areas
(marine reserves) play an important role in fishery productivity
and the North East Atlantic fisheries need to review how these
can be implemented on a wider scale to both protect sensitive
marine environments and enhance fish stock recruitment.
Rights based management tools: Tools such as
individual transferable quotas (ITQs) have had proven benefits
in well managed fisheries outside of the CFP such as in Iceland
and should be considered very seriously as a potential major reform
to future CFP amendments.
Technical Conservation Measures: Some TCMs such
as mesh size are made compulsory across EU fisheries yet others
such as separator grid escape panels are often not. TCMs such
as nets with technical adaptations, eg sorting grids and escape
panels, are fundamental in reducing by-catch. The mixed fisheries
for haddock, whiting and certain nephrops fisheries are of particular
concern due to the high level of cod by-catch for example, and
fleets in these fisheries should be required to introduce more
selective gear. There is need for a review of how TCMs are implemented
within the catching sector and wherever possible this should not
be left on a voluntary basis with the catching sector (although
assisted funding for vessels may need to be made available in
order to implement this if there is a significant change to gear
configuration).
3. To what extent have current management
tools increased the levels of discards and by-catch? What is your
view on how these problems can best be tackled?
This is an issue of paramount importance with
a range of possible solutions—the current Minimum Landing
Size must be removed and replaced with a plan that would establish
a "trigger point" for capture of juveniles, which is
constantly monitored and once exceeded leads to a fishery zone
closure to enable depleted stocks to replenish.
4. Do you consider that fisheries management
policies may need to adapt to climate change? If so, how might
this be achieved?
In our view, ocean acidification is the biggest
challenge facing fisheries and the marine environment. The increased
pH levels of the world's oceans will have a significant effect
on the productivity of marine eco-systems. This could lead to
a worldwide decline in areas favourable to coral reef growth,
as well as major changes in marine ecosystems affecting the marine
food chain, and a reduced ability for oceans to absorb carbon
dioxide. This must be recognised by government and the EU as a
major issue.
CONTROL AND
ENFORCEMENT
5. Chapter V of Regulation 2371/2002 lays
down the responsibilities of the Member States and the Commission
as regards the control and enforcement of the rules of the Common
Fisheries Policy. The recent Court of Auditors Report on the control,
inspection and sanctions systems relating to the rules on conservation
of Community fisheries resources was very sceptical of the systems
currently in place. What is your view of the efficacy of the systems
in place? To what extent has the Community Fisheries Control Agency
already assisted in improving matters?
We have seen some encouraging signs from the
CFCA which has sought to harmonise fishing practices across the
EC, but it is too early to comment yet on the efficacy of their
systems. We naturally welcome the initiative to harmonise implementation
and enforcement measures across the Community.
6. The European Commission has regularly highlighted
how serious infringements of the CFP are penalised differently
across the Community. This was a matter that was also raised by
the Court of Auditors and sanctions were included in the recent
Commission Proposal in IUU fishing. What is your view on the issue?
Punishments against fishermen who engage in
Illegal, Unregulated and Undeclared (IUU) fishing should be draconian
and sufficient to discourage the practice—although the economic
motivations of IUU needs to be addressed by Member States.
One very important area that could affect supplies
into the UK for all retailers and have a negative impact on developing
countries, are the EU-proposed IUU regulations. The regulations
are currently in draft form, but potentially look like a major
barrier to trade for such countries if they go through in their
current form.
The EU proposals to help combat IUU fishing
are distinctly disadvantageous to developing countries. The introduction
of a paperwork system to accompany each fish from catch to processing
is concerning on two counts: (i) the chopping up of fish into
separate cuts, each of which will need a certificate, will increase
the level of paperwork and cost to all involved along the supply
chain; (ii) this overly complex system requires heavy investment,
a good level of literacy and a high level of technology on the
part of all states. Developing countries lack the financial resource
for many of these activities, so while EU Member States will be
able to continue to fish and work in accordance with the new regulations,
the UK could potentially lose out on supply from important fisheries
in developing parts of the world. The working party run by the
Food and Drink Federation, in which we take part, has been working
on a proposal in response to the EU's draft proposals, in which
this concern will be made clear. It is important to note that
while we would welcome any move to eliminate IUU, an overly simplistic,
"one-size fits all nations" approach may not work.
GOVERNANCE
10. As a result of Regulation 2371/2002, Regional
Advisory Councils (RACs) were established to advise the Commission
on matters of fisheries management in respect of certain sea areas
or fishing zones. What is your assessment of the success thus
far of the RACs? What is your view on their future evolution?
RACs bring a local feel to fisheries management
and in our view would be the ideal way to govern EU fisheries.
These councils will help the Commission draft legislative proposals
for the CFP, but, bearing in mind that the first RAC in the Baltic
Sea is only just beginning to function, we are as yet unclear
how effective such organisations will be in helping to formulate
fisheries policy across the EU.
February 2008
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