EU Farm to Fork Strategy – Our Fish submission


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The European Commission is developing a Farm to Fork Strategy, to help achieve the goals of the EU’s Green Deal.

Below is Our Fish’s official submission, which can also be found as official feedback to the Farm to Fork strategy on the European Commission website

Our Fish Submission to EU Farm to Fork Strategy, March 17, 2020:

There will be no “sustainable” EU seafood until the EU ends overfishing. This is a no-brainer for the provision of healthy food and the only way to deliver for dependent communities.

“The EU has committed to the 2030 Sustainable Development Agenda and to being a frontrunner in its implementation”. Goal 14.4 states, “By 2020, effectively regulate harvesting and end overfishing, illegal, unreported and unregulated fishing and destructive fishing practices and implement science-based management plans, in order to restore fish stocks in the shortest time feasible, at least to levels that can produce maximum sustainable yield as determined by their biological characteristics.” The EU has failed to do this; this is not being a frontrunner, this is being a laggard. Not only is it a failure to reach this SDG goal, it is also a failure to reach its own self-imposed target within the Common Fisheries Policy. This has denied consumers and fisheries dependent communities of healthier fish populations, and is undermining ocean health.

Reversing the EU’s thirty year addiction to overfishing does not require new solutions, it requires old-fashioned discipline. Changing the approach to fisheries management from one of maximising resource extraction, to maximising ecosystem health and functioning would provide a more reliable and abundant source of protein. The Farm to Fork Strategy is an opportunity to recommit to the implementation of existing targets and proven strategies in order to make seafood production ecologically sustainable and deliver benefits for consumers and communities. Specifically:

  1. Implement in full of the Common Fisheries Policy (CFP):

– All harvested fish populations in the EU are fished below maximum sustainable yield (FMSY), in order to protect and restore wild fish populations to healthy levels;

– Increase monitoring and enforcement of the Landing Obligation, to reduce unwanted catches and eliminate waste of fish and marine life;

– End destructive, carbon-intensive fishing activities through implementation of Article 17, allocating more quota to fleet segments that have minimum environmental impact and maximum social and economic benefits;

  1. Prioritisation of an up-to-date Fisheries Control Regulation that includes strong focus on increasing resources to monitoring and enforcement of CFP rules, specifically:

– Require full documentation of all catches of fish and bycatch of threatened and protected species through remote electronic monitoring and CCTV on all vessels > 12m, and for vessels < 12m that are high-risk of non-compliance with the CFP;

– Improve transparency so that all Member States’ reports on implementation of the fisheries control system are publicly available;

– Improve and digitize traceability of seafood products to make them traceable from point-of-catch to point-of-sale, in order to combat IUU fishing and achieve healthy fisheries;

– Standardize enforcement measures and sanctions for fisheries infringements.

  1. Protect marine biodiversity, ocean ecosystem services in order to improve ocean resilience in the face of extreme climate change:

– Require an environmental impact assessment as a condition of any request for fishing in all EU basins, only granting access to those who commit to  fishing in a way which improves the environmental status of the ecosystem and fish populations.

4.End fisheries subsidies which increase capacity, public funds must support public goods:

– Increase data collection, monitoring, control and enforcement of fishing activities, and the conservation and management of marine ecosystems;

– Apply legal and fiscal repercussions on Member States who fail to  implement EU laws for ecologically sustainable food systems.

It is clearly reckless to continue sanctioning overfishing while purporting to be rolling out a Green Deal. There is no deal unless it embraces the importance and value of a healthy marine environment. #GreenDealBlue