World Wildlife Fund (WWF) Japan released a report in September examining the likelihood that illegal, unreported and unregulated (IUU) seafood products will enter the Japanese market, and presenting recommendations to keep these products out.
The report, “IUU Fishing Risk in and around Japan,” recommended that Japan develop a catch certificate system similar to the European Union catch certificate or the U.S. Seafood Import Monitoring Program, to include supply chain identification for all fish and fish products entering the market, with identification of the vessel, date, and location of fishing activity, as well as identification of the species entering the country.
In the report, 50 species of seafood were scored on six criteria, and from these, 10 species were selected for detailed risk assessments, based on the potential for IUU catch to enter the supply chain. Of these species, eels, flatfish and Pacific salmon were found to be higher-risk species. King crabs and tanner crabs were found to be medium-high risk, while herring, mackerel and octopus were found to be low-medium risk.
“In order to keep IUU seafood products out of Japan, a transparent supply chain, from source to consumer for all fish and fish product imports, is needed,” Maya Takimoto of WWF Japan said in a press release accompanying the report.
For the higher risk species – eels, flatfish and Pacific salmon – clear identification of species and location of fishing activity is recommended. For the former two, this is because there are many species traded that when processed, are not easily distinguishable. For example, because of low stocks of Japanese eel, importers may substitute other types of eel, and the pressure on these stocks may not be noticed through import data. Flatfish, such as flounder, are also of many species which may be substituted without being noticed. Currently, eel and flatfish statistics are categorized broadly as “eels nei” (not elsewhere included), and “flatfish nei,” without species information.
Though there are fewer species of Pacific salmon, and these are not so easily substituted for one another, information on the location of fishing activity is important, as fish from threatened or overfished runs may be misrepresented as coming from other areas.
Though the report recommends the development of a tracking system mirroring those of the U.S. and E.U., it does not paint Japan as particularly bad in terms of IUU.
“Generally there is a low incidence of IUU fish in the market and supply chains,” the report said, noting that the level of audits and other checks in place in the supply chain is similar to that in many other developed countries.
The E.U. and the United States have been implementing systems in recent years to reduce entry of IUU product to the market. Catch certificates and the validation of catch certificates by cooperating states are the main elements of the systems.
In both programs, the documentation of Regional Fisheries Management Organizations (RFMO’s) may be substituted for the paperwork required. (The report notes that data from RFMO’s is also already used in Japan for some species, including mackerel and bluefin tuna.)
The programs vary somewhat. The E.U.’s covers all species, while the species covered under the U.S. program are Atlantic cod, blue crab (Atlantic), dolphinfish (mahi), grouper, king crab (red), Pacific cod, red snapper, sea cucumber, sharks, swordfish, and tuna (albacore, bigeye, skipjack, bluefin, and yellowfin). Abalone and shrimp are to be added later.
Both the E.U. and U.S. programs are aimed at imports, but exclude domestically caught seafood for domestic consumption. The US program does not apply to US exports, though it does apply when US-caught seafood of the above species is processed in other countries and re-imported.
China has objected at the World Trade Organization (WTO) to the U.S. Seafood Import Monitoring Program on the grounds of unequal treatment and that it requires burdensome paperwork and tracking even where the tracking has not been scientifically shown to reduce risk.
The Chinese representative brought up the U.S.’s proposed rules at a meeting of the WTO's Committee on Sanitary and Phytosanitary Measures (SPM), arguing that the monitoring program would go against a procedural obligation to give the WTO formal notification in advance of the proposal and allow members to comment. The U.S. has responded that the proposal is part of an effort to combat illegal fishing, and thus falls outside of the scope of the committee, which is mainly concerned with health and safety measures.
