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To the EU commission and the EU member states ministers respsonsable for fishery

The association fair-fish recommends like the EU Commission to set the priority on option 3 as it seems to be the best way to convert the biggest possible proportion of worlwide fisheries to sustainability. We support all 5 minimal requirements named by the Commission, but we would like to draw your attention to the following suggestions:

Minimal requirement 1: Concrete ones!
We support the Commission's demand for concrete criteria for sustainability. Such criteria can and must be named today already, as for instance:

  • No applying of destroying fishing gear like bottom trawlers, drift nets, longlines a.s.o.
  • No fishing on species that are known to be overfished or endangered in the concerned region.
  • Fixed maximum for by-catch of species that are not to be processed.
  • Ships that land certified fish are to be always accompanied by an on board observer who are placed by an international board, changing in turn from one fishery to the other. Excempt are only certification systems which garantee by other means and controllably that only sustainable fishing methods have been applied.

Minimal requirement 2: free access / competition
To our opinion, free of discrimination access to a certain label is less impor-tant than
free access of different labels (fulfilling the minimal requirements, of course) to the market. The task of the EU is to garantee free competitiion of several labels. To concentrate all efforts on one label only would be dangereous, for different reasons:

  • For the time being, MSC sure is the leading fishery label from the point of view quantity. But only 1 to 5 percent of all fisheries worldwide are MSC certified, and further growing of MSC seems to become more and more difficult because of its very complicated and costy certification scheme. MSC is a possible way to the goal of eco-certifying the majority of the fish market, but this goal most probably won't be reached with MSC alone. As some fish market players, too, put it, there is a need for alternatives, that is: for several eco-labels.
  • Only competition among several labels can assure an adequate relationship between costs of certification and added value of labelling. Initiatives like Friend of the Sea and fair-fish show lower costs and even higher added values are possible.
  • From an eco-label on fisheries, consumers do not only expect sustainability (protection of resources and species). Implicitely they expect as well that fishermen get fairly paid (fair trade) and that the fish did not have to suffer for a long time (animal welfare, ethics). Labels like fair-fish which meet these two expectations, too, must have the same access to the market as those labels which garantee sustainability «only». This is the more true as between the three goals, there exists a positive, mutually enforcing correllation: The one who is getting a better price for his fish can afford the expenditure of careful fishing. And the one who is organizing his fishing in a way that the fish has not to stay for a long time in the fishing gear and that it can be stunned and killed quickly when heaved will therefore not be able to fish with destroying methods.

Example for the meaning of competion among several labels
The requirements of the Bio Suisse label regarding animal welfare are the leading ones in ecological agriculture worldwide. This is not at all evident, as the eco-farming movement has been bothering astonishly few about animal welfare since itsw beginning. Until the early 1990s Bio Suisse did not demand the extent of animal welfare instinctively presumed by eco-consumers. Only the decades long enduring pressure by the label kagfreiland, a pioneer in farm animal welfareand free range husbandry, forced Bio Suisse to improve its respective regulations – and this has been the kick off for improvements within the eco-farming international IFOAM. It's hard to imagine how these improvements could have been settled without such label competition.

Minimal requirements 3: Transparency
There is a broad call for one only label - an astonishing «etatistic» call in a free market society in which consumers prove to be absolutely in shape to choose between a hige variety of brands (cars, home electronics, cloths, ready soups, a.s.o.).
Simularly as a technical control board assuring for technical products that consumers are buying a safe and functioning product whatever brand they choose, minimal requirements for eco-labellling of fisheries must garantee that certified fish - independent of the chosen label - derives from sustainable fishery. This is the only way how concerned traders and consumers are enabled to decide rapidly and safely what to choose. For those traders and consumers who want to know it more precisely and who want to go ahead one step farther, more demanding labels must have non discriminated access to the market as these traders and consumers are the ones who will deepen and advance the development of sustainable fishery.
The crucial point in transparency is not how many labels exist but whether there is a strong definition of the minimal requirements they have to meet. Thus, the deciding criteria is not free access to a certain label but free competition among all labels in conformity with these requirements. It is the competition which will take best care of that anybody meeting these requirements will have access to a corresponding label.
It's only on the run of free competition that best solutions will show up step by step. In the end, even convergency on one single label is possible – but this can only be a result of competing efforts and not the starting point.


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