Fish as Food or Feed?
IFFO Position Paper
The use of small species of fish as farmed animal (including fish) feed is important for global food security and is entirely appropriate if the source fishery is well managed and does not deprive local communities of good quality food for which there is a demand.
Recent reports in the media and from some lobby groups have misrepresented the value of small fish and ignored the good management practices now in place in many fisheries and improvement projects driven by market demand. Claims that it is wrong to feed fish to (farmed) fish ignore the decreasing amounts of fishmeal used in feed, the increasing amounts of fishmeal recovered from the by-products of fish processing that would otherwise be waste, the lack of markets for direct human consumption of small, bony fish that are otherwise well managed and abundant and remove incentive for improvement in fishery management.
It is also important to remember that the natural diet of many farmed fish species is predominantly other fish which provides them with the optimal nutrition. The use of alternative non marine sources of protein and oil can carry anti-nutritional factors which compromise growth and fish health. To date, only marine ingredients provide the long chain Omega 3 oils in farmed fish that are important for good human nutrition.
However, the increasing knowledge of the inter-relationships within ecosystems should be taken into account when setting future fishery management guidelines for the benefit of the fishmeal and fish oil industry and the environment on which it relies.
The use of small, bony fish for reduction to a dried protein (fishmeal) and oil fractions is a well-established industry and was historically based on stocks of fish for which there was little or no direct human consumption market. Populations of these species can be huge, the largest fishery in the world of approximately 5 million tonnes catch per year is the Peruvian Anchoveta, and, as they are near the beginning of the food chain, they can be grouped under a heading of Low Trophic Level Species (LTLS). The protein and oil they contain, however, can be used in a number of applications, the most important of which are now as ingredients for farmed animal (including fish) feed and, in the case of oil, for health food supplements.
Recently, concern has been expressed over this industry for several reasons, summarised as:
a) The use of the species for animal feed deprives local communities of a nutritious food source.
b) Fishing deprives marine mammals and other predators of a food source on which their populations may rely. Fishing deprives more valuable commercial species of fish that are caught for direct human consumption of a food source, creating an economic incentive to leave the small fish in the water rather than catch them.
c) Fisheries are badly managed and environmentally unsustainable.
d) Farmed fish consume more wild fish than they convert to growth.
This document represents the views of the members of IFFO, the international trade association for the fishmeal, fish oil and wider marine ingredients industry. IFFO members represent over 50% of the global production of fishmeal and fish oil and approx. 75% of the traded value.
The Biological Argument
In 2012, the Lenfest Report “Little Fish Big Impact” highlighted the views of a wide panel of fishery scientists on the vulnerability of forage fish i.e. the small species that form the prey for larger fish and marine mammals. The report called for more precautionary approaches to stock management to recognise the dependence of the wider ecosystem on a stock, rather than managing the stock to maintain a reproductive and viable population of the target species. While the need for an ecosystem approach is becoming more recognised, many of the Lenfest reports’ conclusions were based on economic arguments which are questionable (see below).
The 2014 FAO SOFIA report highlighted the problem of so-called “trash fish”, low value species caught in South East Asia tropical trawl fisheries by fine mesh nets and used in fishmeal. This is a different situation to fishmeal from well managed stocks and is clearly an unsustainable practice. IFFO members are working with government and NGO partners to introduce better practices in this region.
Fishery science is an evolving area and, as with any field, scientific opinion varies. However, there is widespread acceptance by IFFO members that all stocks must be managed in a responsible manner to ensure the long term survival of the industry and the fish stocks on which it relies. The main stock used for reduction, Peruvian Anchoveta, was recognised in a 2008 study by the University of British Columbia as well managed and permitted catch is regulated each year to protect recruitment of juveniles and in response to environmental changes.
Approximately 42% of the global fishmeal and fish oil production comes from factories that are certified to the IFFO Responsible Supply standard (IFFO RS), an independent third party scheme that is accredited under ISO65 guide and includes a requirement to observe the UN FAO Code of Conduct for Responsible Fisheries (1995).
The level of precaution applied to the stock management is a matter for regulators who should balance the need for a healthy ecosystem with the need for viable industry, taking decisions based on best and most current scientific advice. IFFO members support responsible management of fisheries and do not support the use of fish from unsustainable resources.
The demand from markets for responsibly managed raw materials is driving improvements in fishery management. IFFO members believe calls to remove fishmeal from animal feeds ignore the availability of responsibly sourced raw material and remove incentive for improvement.
The Social Argument
Many countries, particularly in the developing world, have poor nutrition and the protein contained in LTLS fish caught locally is a possible option. However, local communities have preferences over their diet and will not generally consume products they find to be unpalatable. Despite years of marketing and promotion by government and independent activists, the consumption of Anchoveta in Peru for human consumption is still extremely low at around 2% of the catch, leaving a significant surplus.
There is an argument for local wild fish caught in nutrition-poor regions to be directed for human consumption rather than conversion to feed for high value farmed species for export to other markets. However, this assumes the local consumers want to eat the wild species landed and denies the community of earning income from farming which can be used for discretionary purchases of food or other goods and services.
Many of the companies who are licenced to produce fishmeal also make products for human consumption, meaning there is little preventing the human consumption market developing should demand exist. This is evidenced by the trend in recent years for less whole fish to be used in fishmeal production. Species that previously were reduced e.g. Herring, Mackerel and Blue Whiting now have direct human consumption markets offering better returns for fishers and processors. This reduction has been offset by an increasing amount of by-products and trimmings from fish processing entering fishmeal production, latest FAO estimates quoting 35% of all raw material now (2012) comes from recovered by-products and is likely to increase.
A 2009 report for FAO concluded that feeding fishmeal and fish oil to farmed fish and crustaceans did not deprive communities of food but that it "increases the effective supply of fish for human consumption by 7-8 million tonnes per year" and “Halting industrial fishing would lead to an immediate loss of fish for food.” In summary, “the practice of using fish as feed is viable, that is, is capable of surviving as a practice within the coming decades."
There is little evidence that reduction fisheries are depriving local populations of fresh fish for direct human consumption. IFFO members support the harvesting of fish from responsibly managed stocks that is surplus to demand for direct human consumption.
Reducing world hunger is a priority for governments and fish farming is recognised as a major potential source of protein for the growing population. To date, fishmeal and fish oil are the best performing ingredients in fish feeds but are already at much lower inclusion rates than before. Fishmeal production has been steady at around 4.5 million tonnes for the last few years yet feed volumes have increased with the growth of aquaculture, necessitating a reduction in the percentage of fishmeal used. Much of the protein content has already been substituted with soya and other land based proteins to the level where further reductions would incur a fish growth or health penalty. Typical inclusion rates for farmed Salmon diets are now at around 10% fishmeal compared to 40% or more in the past.
Small species of oily fish of the kind used in fishmeal and fish oil can be rich in the important long chain Omega 3 fatty acids. If there is no direct human consumption of these species, inclusion in the diet of farmed fish can translate these nutrients into products e.g. farmed salmon that are in demand and can be made available to consumers. IFFO members support the inclusion of essential nutrients such as long chain Omega 3’s in national diets.
The Economic Argument
Although, in principle, it would be wrong to deprive local populations of fish for direct human consumption, there is also the consideration of the rights of fishers to market their catch for their best return. If they receive a greater economic return by selling their catch for reduction than direct human consumption, regulators would be interfering with market mechanisms and the livelihoods of fishers if policies seek to influence the sale of the catch.
One of the main references arguing against the use of small species of fish for the production of fishmeal is the previously mentioned Lenfest report “Little Fish, Big Impact”. This report quotes that the value of forage fisheries globally is US$5.6 billion compared to the value of the larger fish that eat them being worth US$11.3 billion i.e. it is better to leave these fish in the water as food for larger, more valuable fish. Unfortunately, this argument is flawed for several reasons:
a) The price of forage fish in the report is taken from a database published by Sumaila et al (2007). This database itself was compiled from prices collected in the period 1950 – 2002. For much of this period, forage fish had little or no value and fish oil was routinely burned for fuel. Now, with the opening of markets for health supplements and animal feed since the 1990’s, the last decade of the database period, the value of fish oil has increased by 4-5 times and the value of fish protein has tripled with a corresponding increase in the value of the catch.
b) The report compares the landed price of e.g. Anchoveta with Tuna. This compares two different stages of the food chain and undervalues the LTLS fish which, as stated, have little value as whole fish. Their value is realised when they are reduced to their constituent protein and oil for further applications and a more relevant comparison would be the price of products as consumed by humans e.g. farmed salmon, partly fed on fishmeal from Anchoveta, versus Tuna.
c) In hunting prey, predators like Tuna expend a significant amount of energy that is therefore not available for growth. Farmed fish, partly fed on fishmeal, is fed without the need to hunt and converts far more of the energy consumed to growth. There are many claims that farmed fish consume 5 or more times their body weight in wild fish through their diet. This is now completely out of date as fishmeal levels in diets have reduced in favour of soya and other non-marine protein sources. Taken across all species of farmed fish that are given feed, there is now 1kg of fish grown for each 0.3kg of whole fish used in the diet i.e. farmed fish are net producers of fish protein.
Although some farmed fish species are vegetarian e.g. carps, they are not widely preferred. The higher value species that are most in demand by markets perform best when their diet includes a small percentage of fishmeal. Removing fishmeal from these diets requires the use of alternative protein sources, usually vegetable, that incur a growth penalty and may compromise the health of the fish, both incurring a cost to the farmer.
Regulators are responsible for balancing the economic needs of society and maintaining a healthy marine environment. IFFO members believe economic decisions should be based on accurate and current statistics, taking into account market demand, innovation and trends within industry.
IFFO members have demonstrated their commitment to responsible fishery management and will continue to engage with other stakeholders to apply good management practices. Improver programs and liaison with the scientific and NGO community are key parts of the effort to raise standards for the future.
In conjunction with this, IFFO will communicate with regulators and policy makers to help them make informed decisions based on accurate, current data and good science.
 Little Fish Big Impact, 2012, Pikitch et al, Lenfest Ocean Program.
 Fisheries Centre, University of British Columbia, Canada. Research Reports , 2008 Volume 16 Number 7
A comparative assessment of biodiversity, fisheries and aquaculture in 53 countries’ exclusive economic zones
 SOFIA report 2014
 Wijkström, U. N. 2012. Is Feeding Fish with Fish a Viable Practice, in R. P. Subasinghe, J.R. Arthur, D. M. Hartley, S.. S. Da Silva. M. Halwart, N. Hishamuna, C. V. Mohan & P Sorgeloos, eds'. Farming in Waters for People and Food. Proceedings of the Global Conference on Aquaculture 2010, Phuket, Thailand. 22-25 September 2010. pp33-55. FAO Rome and NACA, Bangkok.