IUU fishing EJF

Editor’s note: The following is a commentary submitted to SeafoodSource by Ned Daly, special project advisor for SeaWeb.

NOAA’s recent announcement that it will be working with ten countries to address their failures to control illegal, unreported and unregulated (IUU) fishing activities under their flagged vessels follows similar action by the European Union last year to list countries that had failed to meet EU IUU regulations. This all comes at a time when other governments, the conservation community and many in industry are working together to develop responses to IUU fishing.

Along with significant social and environmental impacts, IUU fishing is estimated at a USD 10 billion to USD 23 billion loss for the global fishing industry. The seafood industry will benefit significantly from this new set of tools and actions, but it is the coordination and integration of these tools with each other and with industry traceability efforts that will be most valuable to the seafood industry. These collaborative endeavors not only allow global actions to be more efficient and effective in protecting marine and seafood resources, but they also provide industry with a great opportunity to easily engage and contribute to the fight against IUU fishing.

What is IUU fishing? According to Chatham House — which has developed a great online resource about IUU fishing — at its broadest, illegal fishing takes place where vessels operate in violation of the laws of a fishery. This can apply to fisheries that are under the jurisdiction of a coastal state or to high seas fisheries regulated by regional fisheries management organizations (RFMOs). Unreported fishing is fishing that has been unreported or misreported to the relevant national authority or regional organization, in contravention of applicable laws and regulations. Unregulated fishing generally refers to fishing by vessels without nationality, or vessels flying the flag of a country that is not party to the regional organization governing that fishing area or species and fishing other areas not covered by management arrangements without specific authorization.

One way a seafood company can help address IUU fishing is through traceability of its supply chain. A great resource for all seafood companies, but particularly for companies just starting to think about traceability, is a comprehensive overview of international traceability efforts produced by Mariah Boyle, at FishWise “Without a Trace II: An Updated Summary of Traceability Efforts in the Seafood Industry.”

However traceability alone cannot address IUU fishing. It is a complex problem occurring at different scales and in different forms all across the globe. Tony Long, Director of the Global Campaign to End Illegal Fishing with the Pew Charitable Trusts explained, “To deter IUU fishing activity requires a shift from business as usual, in which illegal fishing is a low-risk, high-reward activity, to one in which the threat of sanctions is real and the opportunity to exploit the system is not worth the cost. This is why the industry is vital to making a difference; they must close the market to illegal catch by uniting to demand greater transparency from the moment the fish is caught to when the consumer buys it.” Long has an acute understanding of how to tackle such a difficult issue, after 27 years in the Royal Navy tracking vessels that don’t want to be found.

“There is no silver bullet that will adequately address the problem of IUU fishing but if processors and retailers mandated that IMO numbers be part of all traceability arrangements and that FAO Port State Measures are adopted then much greater transparency in fishing operations will be achieved,” Long added.

Identifying vessels that are fishing illegally, developing the process for information sharing across national borders, better national rulemaking, the need for globally coordinated measures that combat illegal fishing — these are the basic building blocks to combat illegal fishing and the foundation of Pew’s global strategy. Steve Trent, the executive director of the Environmental Justice Foundation (EJF), sees the value of better-coordinated IUU efforts at the local level. “Improving information sharing between coastal countries and importing countries is crucial to effectively addressing IUU fishing.” EJF runs a community surveillance project in West Africa that allows fishing communities to document and report illegal fishing by trawlers that supply the global seafood market. EJF's work with fishing communities has resulted in a number of high-profile arrests of illegal trawlers, seizures of IUU fish, and a dramatic reduction in inshore illegal fishing in Sierra Leone. Trent added, “we now need to significantly increase transparency in the global fishing sector by establishing a Global Record of fishing vessels and ending the use of Flags of Convenience. Industry has a central role to play in achieving this.”

Beyond the obvious value to the industry of better-coordinated government and international efforts to protect seafood resources from IUU fishing, there is a more compelling reason for seafood companies to engage in and support IUU efforts beyond their own traceability. The impacts of illegal fishing on the seafood industry go beyond liability issues in the supply chain. IUU fishing can threaten long-term assured supply of an entire fishery or threaten the market reputation of species or geographies.

There are a number of parallels between the issue of illegal logging and IUU fishing and some lessons to be learned from the terrestrial world. Like fishing, forestry often focuses on a few species that are commercially viable in the marketplace. So while there may seem to be plenty of fish in the sea and plenty of trees in the forest, illegal extraction can wreak havoc on, and often targets, the most commercially valuable species. In the criminal context, illegal, unregulated, and underreported does not mean unorganized.

Phil Guillery, the systems integrity director at the Forest Stewardship Council International, demonstrated this point when he said “companies like big box DIY stores in Europe and the U.S. see illegal and unsustainable logging generally as a threat to long-term assured supply. Addressing illegal logging is not only a sustainability strategy—it’s a procurement strategy.”

Tom Kraft with Norpac Fisheries Export sees a similar trend developing in seafood.

“There is no question that the larger retailers and club stores are seeing seafood sustainability as a procurement issue to be addressed now, in order to avoid supply disruptions in the future. IUU products in the supply chain are seen as counterfeit product that diminishes the product integrity and the retailer’s brand,” said Kraft. “We are finding broad support for electronic product traceability that enables transparency around capture data, processing, and species identification.”

The work Pew, FishWise, EJF, WWF, and others are doing to develop a strategy around the variety of enforcement, legislative and inter-governmental efforts underway will support industry traceability efforts and provide industry a platform for addressing some of these longer term threats IUU poses to the seafood industry. “Our strategy at Pew is to promote identifying vessels that are fishing illegally, developing the process for information sharing across national borders, better national rulemaking and globally coordinated measures that combat illegal fishing — these are the basic building blocks to combat illegal fishing and protect these resources,” said Long.

Boyle at FishWise is working with NGO partners, companies, and governments to develop specific opportunities for the seafood industry to support these key international efforts. “Our hope is to continue to work with industry and give them a voice in IUU discussions and strategy development and to educate companies on what is happening legislatively, through NOAA, NGO, and inter-governmental efforts,” Boyle said. Below are some of the key opportunities FishWise and colleagues are working to engage seafood businesses and others to support efforts to stop IUU fishing:

1. Support the ratification of the UN FAO Port State Measures Agreement ( by engaging foreign offices, suppliers, and partners to encourage more nations to ratify the agreement because more rigorous port inspections will limit the scope for illegal product to enter the market.

2. Governments and seafood businesses should require the use of an IMO number that uniquely identifies a fishing vessel throughout its life and therefore improves transparency of vessel operations and ownership and is unaffected by name, flag or changes of owner.

3. Include in your supplier code-of-conduct (yes, you should have one) a prohibition on the use of flags of convenience that fail to meet their international obligations.

4. Improve your supply chains’ traceability by reviewing its data and information systems, protocols, and conducting risk assessments.

5. Support Congressional efforts to address IUU fishing and traceability in the supply chain.

6. Support NOAA’s efforts to address IUU fishing and work with other countries to strengthen fisheries legislation and enforcement.

If you are a seafood business and would like to learn more about these issues or get involved in any of these efforts, SeaWeb can connect you with organizations, projects, and opportunities to protect seafood resources from IUU fishing. Contact Ned Daly at or go to our website,


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