Neil Auchterlonie's full response to the Changing Markets Foundation Report
April 18th 2019
IFFO is aware of the recent publication of the report “Until the seas run dry: How industrial aquaculture is plundering the ocean” by the Changing Markets Foundation. The Changing Markets Foundation is a body that according to its website “partners with NGOs on market focused campaigns”, and it is clear from this unbalanced and inaccurate document that they have sided with some of the most uninformed players in the NGO community.
As IFFO, The Marine Ingredients Organisation, is referred to specifically in the text, we as a body thought it important to respond and set out some of the facts. Much of this information is already in the public domain on our website at www.iffo.net and can be accessed by anyone who has an interest in the subject.
Firstly, there is a serious allegation of a Conflict of Interest levelled at IFFO regarding the Global Standard for Responsible Supply (IFFO RS). This needs to be straightened out. The authors have neither taken the time nor cared to get their facts correct whilst writing about the standard, that is one of the foremost across all feed ingredients encompassing now over 50% of global annual production. IFFO RS Ltd., is a separate entity to IFFO, and whilst being the standard holder for the IFFO RS standard (now on its second version, and developed through a multi-stakeholder forum that includes NGOs), ensures independent certification of the scheme via third party inspection and accreditation to internationally recognized standards such as ISO 17065. There is no Conflict of Interest in the way the standard has been developed, nor how it is operated and managed, and many highly knowledgeable people both inside and outside the industry have contributed a great deal since 2007 in making this standard into an environmental success story for the marine ingredients industry. This is further endorsed through IFFO RS’s Membership of ISEAL the global membership association for credible sustainability standards. This information is presented on the IFFO RS website. A key aspect of IFFO RS is traceability of the product, which I mention here because accusations of opaqueness and lack of transparency abound in the text.
The report separates into three main sections: the use of wild-caught fish as a raw material for fishmeal and fish oil; the major areas of fishmeal production around the globe; and, the role of major companies in aquafeed with the implication being that the marine resources are being used to make quick profits. Responding to these points in turn is straightforward:
IFFO is very clear on its position regarding the use of fish as food or feed. IFFO members support responsible management of fisheries and do not support the use of fish from unsustainable resources. IFFO members believe calls to remove fishmeal from animal feeds ignore the availability of responsibly sourced raw material as an essential resource in support of global protein production. The criticism of the use of fish as raw material for fishmeal and fish oil production exhibits a lack of basic understanding of the seafood market, where fish destined for food markets achieve considerably higher prices than those for fishmeal production.
An additional point to make is that there are a series of nutrients available in fishmeal and fish oil that are just not available in the same quantities, consistently, in other feed ingredients. That is why they are such effective ingredients in aquafeeds. Recognising their importance, the FAO (in 2016 and 2018), stated that “Fishmeal and fish oil are still considered the most nutritious and digestible ingredients for farmed fish feeds”. Global aquaculture converts this resource into edible protein that shows a very marked multiplier effect, where approximately 5 million tonnes of fishmeal every year contributes to approximately 23 million tonnes of aquaculture, as well as several million tonnes of pork and poultry, not to mention all the pets and human beings that also benefit from the consumption of other products including omega-3 oils.
In an attempt to appear knowledgeable, the report contains an extensive reference list but when this is accessed it is noteworthy for being a good example of “cherry-picking”. A clear and obvious illustration of this is the reference to the Sustainable Fisheries Partnership (SFP) report on Reduction Fisheries published in 2018. As an independent NGO that works in the marine fisheries domain, the SFP is regarded as an organisation carrying much expertise and standing on the subject of marine fisheries management. Strange, then, that the authors of the report chose to ignore one of the headlines in that 2018 report by the SFP that showed 91% of the major stocks under analysis in the report were “reasonably-well managed, or better”. To neglect to mention one of the important headlines in that report which actually shows the industry’s performance in a good light questions the integrity of the whole text.
In relation to the report’s focus on major regions of the world producing fishmeal and fish oil, the text displays emotive language such as “rampant overfishing” and “vagaries of El Niño” in relation to the fisheries of Peru, a country which presents an excellent example of the industry working alongside government and regulators for the common goal of responsible fisheries management. Environmental impacts are mentioned, and again very serious allegations of the industry damaging local communities and the marine environment are stated by the authors with Chimbote, a city to the north of Lima referred to specifically. Had the authors researched this article in any depth, they would have been aware of the industry’s collective actions in improving the local environment in the city and the good work performed there, but that does not fit the narrative that the writers are working to.
As an organisation IFFO is aware that there are some regions of the world where there may still be challenges in the responsible sourcing of material for fishmeal and fish oil production, although as a reflection of the total volume of supply these are minor volumes. IFFO has a recent history of funding projects (along with the Global Aquaculture Alliance, GAA) to look at the situation on the ground and see where positive change may be made. In order to appreciate the full picture, it is important that the reader understand that one way the industry can support those positive changes is actually via the IFFO RS scheme, which, through its Improver Programme, presents a realistic and accessible system that permits local producers to work together to improve effective management of fish stocks. Ironically, given the criticism in the report, the IFFO RS IP provides an opportunity for positive change in fish stock management, itself being a key contributor to improvements in marine ecosystem health.
The report has also sought to criticise the structure of the aquafeed industry, without any understanding of the history behind the industry’s development alongside the aquaculture sector’s growth globally. Had there been any understanding of the reasons why the structure looks the way it does in 2019, there would not be the thinly-veiled accusations of corporate greed. In fact, as the feed companies have managed - out of necessity - to make the supply of fishmeal and fish oil go further as more aquafeed is required, they are surely to be applauded in their efforts which have occurred at considerable cost to their own businesses. In this manner a more optimal and effective utilisation of key nutritional products has supported increasing farmed fish growth over time. The reality is quite contrary to the story being portrayed in the report.
Finally, a few words on the recommendations from the report:
The first recommendation mentioned is for the aquafeed industry to stop using wild-caught fish. We must ask ourselves the question: why should the aquafeed industry stop using wild-caught fish when the majority of this material is responsibly-sourced? Neglecting what is an important, renewable, natural resource for food production will have major implications for global food production and security. It is both illogical and irresponsible to assume that removing this material from global supply chains would have anything other than serious and dramatic effects on societies across the world, as there would be an immediate and significant lack of the farmed protein that this important material supports.
For the second recommendation, it is requested that the aquaculture industry focus on species that do not require feed, or species that may utilise a vegetarian diet. This bold statement ignores the realities of the economics of aquaculture whereby the industry is only effective when it produces a product for which there is an actual market for the fish that people want to eat. In addition, those farmed fish species which are vegetarian are generally fed diets containing fishmeal and fish oil in hatcheries to provide nutritional benefits that are realised in improved growth and survival. Biologically speaking this is not an uncommon situation in the wild, where even apparently vegetarian species such as grass carp are also known to consume animal protein such as insects and other invertebrates in their diet. Even if changing over to vegetarian aquafeeds were possible, it is also important to recognize that the certification of such materials from agriculture lags well behind that of marine ingredients, for example soy as one of the major vegetable feed ingredients has only 2-3% of total annual production certified to independent standards. Such a switch would therefore change the impacts from a known environment (marine) where they are quantified and managed, into an unknown system where those impacts are known to have much higher environmental impacts in areas such as deforestation, water use, land use, and chemicals use. That is a rash strategy during a time when society is struggling to agree how to respond to climate change and reflects a true lack of understanding of the food production systems that operate globally.
The next set of recommendations for certification schemes ignore the fact that ecologically speaking improvements in the management of the small pelagic species used for fishmeal production benefit the broader marine ecosystem. Certification schemes in themselves may be viewed at a level about regulatory frameworks, generally achieving more than is required by fisheries management rules and regulations. The idea that certification for non-food fishes could be removed from schemes could have a major deleterious effect on supply, where certifications such as MSC and IFFO RS actually protect those stocks.
There is at least one point we may be able to agree on. IFFO fully endorses the first recommendation for policy-makers, that governance frameworks should be strengthened to eliminate IUU and slave labour, prevent over-fishing, and enhance transparency and reporting in global fisheries’ supply chains. The second recommendation for policy-makers is, however, like that for the aquaculture industry, naïve, and irrational.
For the recommendations for retailers, IFFO can agree that transparency is important and this also works to secure the true value of fishmeal and fish oil in aquaculture production, however eliminating fishmeal and fish oil in seafood cultivation is nonsensical for reasons outlined above, as well as the use of trimmings and byproduct which account for at least 33% (and some regions even more) of total world fishmeal production. That is an effective use of a resource that would otherwise predominantly go to landfill.
Another baseless recommendation is that for consumers to “reduce fish consumption”, ignoring the strength of the market for farmed seafood production and its great success, a success that is thoroughly endorsed by the FAO. Consumers want the product because it is healthy and nutritious. To advise consumers to reduce fish consumption is, again, an incredibly irresponsible statement in a public document and one which if followed could have a very serious impact on healthcare services around the world when there is a strong body of evidence showing the nutritional benefits of seafood to human beings. There is really no excuse for such a statement when many countries around the world are struggling with aging populations, many of which will actually benefit from greater seafood consumption, not less.
As an organisation, Changing Markets Foundation appear to be well resourced, producing a glossy document and running a campaign via social media. Given the weakness of their arguments, they perhaps should have spent more of that resource on determining the facts and realities of the fishmeal and fish oil sector, rather than developing their own biased narrative.