Scottish Government ignores scientific evidence in its efforts to undermine EU Discard Ban


Edinburgh, 28 May 2019:- In March 2019, Our Fish reported that no undersize cod have been landed on Scotland’s quaysides since the discard ban came into force, suggesting that vessels are continuing to discard this fish at sea, because it cannot be sold but counts against fisheries quota [1].

In response, the Scottish Government, which manages Scottish fish stocks and fisheries, has largely left the concerns raised by Our Fish unaddressed, and appears to be taking no action to mitigate and eliminate non-compliance, such as establishment of electronic monitoring on vessels.

In a letter dated April 25, the Director of Marine Scotland, Graham Black responded to these reports of suspected non-compliance by arguing that the year’s cod stock is poor and therefore few undersize fish are actually being caught. Such a view is not supported by the scientific advice, which states “landings of [juvenile] cod reported to ICES are currently much lower than the estimates of catches… by observer programmes” and contradicts reports given by Scottish Government staff, who recently stated that, without electronic monitoring, vessels were landing only a “token gesture” of the non-saleable species they catch [3,4].

Our Fish argue this is highly concerning, particularly when Scottish Ministers negotiated for 2019 cod quota in the North Sea to be set 25% over the scientific advice, and for 1,735 tonnes on the West of Scotland, when the scientific advice recommends zero catch [4].

Our Fish Programme Director Rebecca Hubbard says “We need strong leadership from governments if the discard ban is to be a success. It is alarming to see Scotland ignoring the problem, and failing to deliver meaningful monitoring which will allow fisheries to operate on a fair, transparent and sustainable footing.”

“Marine Scotland appear to be contradicting themselves by saying one thing – that the lack of landings of undersize cod is down to their not being caught because of low stocks – to one audience, and another thing to others – that discarding continues because of poor control, and they need electronic monitoring to deliver compliance. Furthermore, not only does Marine Scotland appear to be enabling and excusing discards at sea, it is also pushing for quotas far above scientifically advised sustainable levels – a situation which results in double overfishing”.

“Scotland and the UK may soon become an independent coastal state. As the the EU is required to ban imports of fish from outside the EU which is caught in an illegal manner, it is crucial for the future of Scotland’s fisheries that vessels begin complying with the discard ban.”



Dave Walsh, Communications Advisor, Our Fish,, +34691826764



[1] Fish Overboard: Did the UK Throw Away 7,500 tonnes of North Sea Cod?

[2] Letter from Marine Scotland’s Graham Black to Our Fish, 25 April 2019

[3] ICES Advice on fishing opportunities, catch, and effort, Greater North Sea Ecoregion, Published 29 June 2018, cod.27.47d20

[4] Electronic Monitoring (EM), Evidence of Compliance, presentation by Marine Scotland’s EM coordinator, Norman Fletcher – page 6

See also:

18 March 2019 European Commission responds to Our Fish, promising to “further investigate the issues raised” by Our Fish.

Accusations of fishy business in UK cod catches as small fish vanish from statistics

UK vessels illegally threw away 7,500 tons of cod in North Sea, campaigners say


About Our Fish

Our Fish works to ensure European member states implement the Common Fisheries Policy and achieve sustainable fish stocks in European waters.

Our Fish works with organisations and individuals across Europe to deliver a powerful and unwavering message: overfishing must be stopped, and solutions put in place that ensure Europe’s waters are fished sustainably. Our Fish demands that the Common Fisheries Policy be properly enforced, and Europe’s fisheries effectively governed.

Our Fish calls on all EU Member States to set annual fishing limits at sustainable limits based on scientific advice, and to ensure that their fishing fleets prove that they are fishing sustainably, through monitoring and full documentation of their catch.


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