NGO threatens UK government with legal action over salmon farming’s environmental impact

Published on
January 26, 2023
Feedback Executive Director Carina Millstone.

The U.K. environmental campaign group Feedback, a non-governmental organization with the mission of seeking to address historic and current injustices in the food system, is threatening the U.K. government with a lawsuit over its alleged failure to properly regulate Scotland’s salmon-farming industry.

In a letter written to the U.K. government in advance of launching legal proceedings, Feedback said the U.K. government is required to ensure the nation’s farmed-salmon sector does not have a negative impact on the climate and marine ecosystems, and that its failure to properly regulate salmon farming violates that requirement.

Feedback expressed disappointment that no “meaningful policies” to regulate use of wild-caught fish for aquaculture were proposed in a recent Joint Fisheries Statement (JFS) issued by the U.K. government, despite legislation requiring it to devise policies to ensure that aquaculture does not have a net negative impact on the environment.

Feedback Executive Director Carina Millstone said the government needed to address environmental issues related to salmon feed, sea lice, fish welfare and disease, waste created by overfeeding and excrement, and salmon farming’s impact on wild salmon populations.

“The government needs to step up to the plate and regulate the Scottish farmed salmon industry,” Millstone said in a statement. “If it is serious about delivering world-class sustainable fisheries and aquaculture management, it can no longer allow this industry to go unchecked as it gobbles up vast quantities of precious wild fish.”

Citing research on sustainable protein production led by University of Cambridge Research Fellow David Willer, Feedback said the volume of farmed salmon produced in the U.K. annually is “equal to the amount of fish consumed by the U.K. population every year.”

Production of 179,000 metric tons of Scottish Atlantic salmon in 2014 required fish oil derived from 460,000 metric tons of wild-caught fish, 76 percent of which were species edible by humans,” it said.

Feedback called on the salmon-farming industry to reduce the amount of wild-caught fish in the aquafeed they use, thereby reducing pressure on marine capture fisheries.

“[It is] an inefficient use of nutritious wild fish that has disastrous impacts on food insecure countries, which supply most of the fish used by the global feed industry,” it said, calling for “a greater reduction of marine feeds in salmon production to enable them to be used for human consumption.”

The U.K.’s salmon-farming sector is the third largest in the world after Norway’s and Chile’s, and was worth GBP 760 million (USD 942 million, EUR 860 million) to the Scottish economy in 2022. Farmed salmon represents the U.K.’s largest food export by value, worth GBP 614 million (USD 761 million, EUR 695 million) in 2021.

In response to Feedback’s accusations, Salmon Scotland called Feedback a group of “extreme activists” and the U.K.’s industry is already the most-regulated salmon-farming sector in the world.

“Feedback openly campaigns to ban Scottish salmon farming and wants to make 12,500 workers the length and breadth of Scotland unemployed,” Salmon Scotland Chief Executive Tavish Scott told SeafoodSource. “They also fail to understand that it is the Scottish, not the U.K. government and its agencies, that regulate the Scottish salmon sector. The rest of their claims are similarly misinformed.”

Scott said U.K. consumers seek out Scottish salmon because it is nutritious, and said they trust the buying decisions of their fishmonger or local supermarket, which has accreditation and traceability built into purchasing decisions.

“Domestic sales and exports continue to rise and, as far as I am aware, we have never seen a drop in sales resulting from scaremongering,” he said. “Social media is an echo chamber, which repeats exaggeration and misrepresentation and where perpetual conspiracy theories become like white noise.”

Scott challenged an accusation made by Feedback that Scottish farmed salmon eat three times their body weight in wild fish, saying Scotland’s farmed-salmon industry has an average fish-in, fish-out ratio requiring 1.2 kilograms of fish feed to produce one kilogram of farm-raised salmon. 

Scott said the marine ingredients used in the feed for Scottish salmon farms are sourced from producers with sustainability certifications and caught from responsibly managed fisheries. The wild fish used to produce the fishmeal and fish oil used in Scotland come from species for which there is little or no market for human consumption, Scott said, and one third of the marine ingredients used are trimmings from fish processing. Moreover, every year, more novel feed ingredients are increasingly being incorporated into salmon feed used in Scotland, Scott said.

“Scottish salmon farming actually converts fish that people do not want to eat into the U.K.’s most-popular fish,” Scott said.

The November 2022 Joint Fisheries Statement, drafted by the U.K.’s four devolved fisheries authorities in England, Northern Ireland, Wales, and Scotland, sets out an ambition to deliver world-class, sustainable management of fisheries, in line with eight objectives detailed in the Fisheries Act of 2020, according to the document.

But Feedback Solicitor Rowan Smith said the organization will be pushing forward with its campaign.

‘There is no evidence in the Joint Fisheries Statement that the authorities have discharged their legal obligation. Our client hopes that a full explanation will be given, otherwise legal action may follow,” Smith said.

Photo courtesy of Feedback

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