Seafood traceability: exemptions risk fuelling illegal fishing

Posted on January, 14 2021

1 in every 6 fish imported into the EU at risk of being untraceable
The EU is the largest seafood market in the world, importing more than 60% of its consumed seafood. In the effort to improve the transparency of the EU seafood market, the European Commission has proposed to overhaul the seafood traceability system in the revision of the EU fisheries Control Regulation. This will deliver benefits not only for ascertaining the legality and sustainability of a given product, but equally for food safety and quality control, forming the basis for bringing clear information to consumers.

However, it has been suggested by certain Member States and Members of the European Parliament that seafood traceability should remain paper-based and that a specific group of seafood products should be made exempt from this traceability system. Specifically, this would apply to products falling under codes 1604 and 1605 of the Combined Nomenclature (CN).1 CN code 1604 covers prepared or preserved fish, as well as caviar and caviar substitutes prepared from fish eggs, while CN 1605 covers crustaceans, molluscs and other aquatic invertebrates, both prepared and preserved. In practice, these classifications include many popularly consumed products like canned tuna, fish fingers or caviar.

The suggestion to remove these specific seafood products from the EU seafood traceability system is of great concern, as this would allow for a lesser standard for a host of products that can be at risk of being sourced from IUU-fisheries or other unsustainable or unethical fisheries. In addition, paper-based systems for the complex global seafood value chain are at high risk of inadvertent errors or fraud, and so cannot deliver true accountability for these products.

Making seafood products traceable from the fishing vessel to the final consumer is necessary to combat IUU fishing and achieve healthy fisheries and aquaculture, both in the EU and beyond. Given the size of European demand for seafood, an EU-mandated traceability system will encourage transparency and accountability not only in the EU, but also far beyond the EU’s own seafood supply. The revision of the EU’s fisheries control system is a unique opportunity to secure this. 

WWF recommends that the European Parliament and Member States mandate a digital seafood traceability system which ensures that all the data elements necessary to establish a transparent supply chain are recorded and transmitted at each step of a seafood product’s journey. This system must cover all seafood products available on the EU market, not least those that are imported into the EU, as well as preserved or processed products.
The top 10 imports of CN code 1604 and 1605 seafood products by the EU-27 (2017-2019 averages)
© WWF European Policy Office