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Traceability Certification PNA Global Tuna Market
- 1. Traceability and certification in the PNA and global tuna markets Coral Triangle Fishers Forum II, Lami, Fiji 18 June 2012
- 2. PNA – 8 island nations in an area 40% bigger than the EU ,
- 3. Market import requirements Really 2 areas :- Import Catch Documentation Scheme [CDS] • USA • EU • ICCAT Consumer demanded / NGO driven perception of sustainability :- • Dolphin safe AIDCP, EII, FOS • MSC • Pacifical
- 4. US Government • EPO Yellowfin must meet requirements of USG dolphin safe standards for EPO, and drift net prohibition globally. No issue for Skipjack. • US Department of Commerce, also has own “Dolphin Safe” Outside EPO , US imports only require NOAA 370 form declaring origin. NO DOLPHIN SAFE REQUIREMENT OTHERWISE
- 5. EC Regulations - Ms Damanaki answer on behalf of the Commission • “The Agreement on the International Dolphin Conservation Program (AIDCP) has established a Dolphin Safe Tuna certificate and label. Its use is voluntary. Therefore, market operators are free to decide whether to use it or not and, in either case, they can sell their products in the EU market.” • Council Regulation (EC) No 882/2003(1) transposed the AIDCP Dolphin Safe Tuna into Union law without, however, either making it compulsory or imposing it as the sole scheme available. This decision is due to the fact that other similar labels with similar objectives might exist (and in fact do exist). Furthermore, tuna fished outside the Eastern Pacific Ocean could not receive an AIDCP dolphin safe label, on a simple geographical origin principle, even in the event where the fishing activities are carried out in accordance with the criterion of the AIDCP.
- 7. Dolphin safe
- 8. Dolphin safe PNA DOLPHIN SAFE ???
- 11. AIDCP • Successful IATTC observer backed scheme, based on mitigation of dolphin mortality. • Dolphin safe scheme traces from net to retail with full traceability and verification. • Only applies to EPO yellowfin • Recognized by governments internationally. • Recognised by FAO and leading NGOs • Opposed by EII
- 13. EII - Dolphin safe [single species] • Claimed certification means •no targeting dolphins, •no IUU, [since 2009] •no shark finning, •no drift net, •by-catch reduction, and •no fishing in Marine Protected Areas , Reality: • Nil observer coverage at sea. • Self declaration by companies with no verification. • Industry pressured in media /trade to join or face embargos . • Widely documented as a worthless scheme
- 14. EII Membership requirement • Members sign declarations of EII, “International - dolphin safe policy”. • Pay “voluntary” fees, and expenses for EII visits. • Undertake not to buy from, process or sell to non EII members. • Provide regular reports of trade to EII. • Open books to inspection by EII to verify suppliers, processors, traders and markets, who are then targeted • This is then a EII “Dolphin Safe” • company, and captains can self certify catch compliance, with no verification or validity as documented globally • In Eu use of registered “dolphin safe” logo means paying royalties to EII as well
- 15. Dolphin conservation or extortion? Recent Examples of EII as an action group: • Solomon islands: Government and investors held to ransom over customary harvest and limited live trade in dolphin. • Maldives: government, resort developers, tuna processors and artisanal tuna industry held to ransom over proposed dolphin show investment. • Challenge EPO yellowfin Trade under IATTC scheme, • PNA / Pacifical MSC – global industry blackmailed not to support unless we subscribe to EII and allow them to dictate with whom we trade. • Attacking retailers using alternative certification
- 16. Invisible to EII
- 17. 5 Traceability test: Audits must include a test at the beginning and at the end of one or more batches of the finished product, contemplating suitable mass budgets, bills, invoices and all relevant documents to prove origin of the product and his conformity to the standard. [Required to be an EII member]
- 19. FOS free school certification • Proposed new scheme with FOS working with large industry players, to offer alternative to MSC. • PNA FAD closure can not be validly certified Free school catch despite claims. • Scheme has no observers or validation at sea set by set or by period. • Euro 5,000 [$6,300] per month [$75,600 per year] monitoring fee to get free school certificates. • Projected return $2.00/case [about $ 120.00 / mt]
- 20. MSC premiums offer an economic incentive to target mature free school skipjack and avoid bye catch issues of FADs and juveniles
- 21. Overview of the PNA MSC COC Responsibility of PNA - PNAO and Authorities
- 22. MSC Batch Approval De-briefing Specific training in MSC Verification Strengthen Observer of Observer Observer Sea-based training Records Workbook Recording Port sampling Observe transhipment process and onboard carrier Special ‘club’ MSC Material Agreement Traceability, Identification and Inspection by Authority Segregation Company Captain’s Audit & Approval Record Logbook Company training of of company vessel crew and review Double Video Observers Monitoring PNA Office Approval of Batch as Automatic database ‘MSC Eligible’ On-site sample auditing of member checks and issuance companies, observers, authority, of approval number vessels and handling of materials 22
- 23. Greenpeace campaigner Sari Tolvanen says: “The overarching standards imposed by MSC on the [PNA] products are more far reaching than EII certification which has a focus on the cetacean issue alone. If consumers demand a dolphin safe logo on these products on top of the MSC certification, the PNA dolphin safe provides this assurance.”
Hinweis der Redaktion
- Your excellencies, ladies and gentlemen. All of us have common interests, our nation’s food security, our economic independence and the sustainable future of our peoples. For most it is our marine resources, for us in our region it is our tuna.
- The Parties to the Nauru Agreement [PNA] is 30 years old, set up to sustain and see economic benefit from our tuna resources, 8 Island nations : Palau, FSM, Marshall Islands, Kiribati, Tuvalu, Nauru, Solomon Islands and Papua New Guinea The combined EEZs are spread over an ocean area of 14.8million Km 2, 40% larger than EU land area. A vast area, huge distances 48 hours and 8 flights to get here today, not also limited logistics. 2 PNA nations as small as about 10,000 each, [second only to Vatican] GDP as low as $600/year and fish consumption as high as 180Kg / man woman and child For many sustainable tuna is their only resource and future, 50% of world skipjack catch comes from PNA waters, a band 10N to 10S, 70% of WCPFC catch. 25 of global tunas - but traditional benefit was just 5% for access to PNA waters and catch worth $2.5 billion that feeds offshore industries and a $5 billion trade in our fish. 2 years ago PNA office was established to actively look at vertical integration and enhance benefit from net to table, and more meaningful participation for our future.[today under VDS, and limited output parties return up to 8%], and $ returns doubled at today’s $2200/mt and a profitable sector. No longer enough to have our resources exploited for a few % and told “we cant do it”, by those exploiting our resources, as we watch them from the beach.
- Today I will cover 2 areas, briefly touch on import requirements of Eu and USA and the reality of eco certification schemes and consumer expectations of sustainability.
- USA Require NOAH form 370, a self declaration by captain of fishery / region in which the catch was harvested. Note it only requires dolphin safe compliance for EPO yellowfin. Not for other species or other regions. [Besides drift net embargo on Italy]. The US “dolphin safe” definition has been successfully challenged by Mexico through WTO as a invalid non tariff trade barrier applied in EPO
- EU. Require more detailed CDS declarations, endorsed by flag state. For many SIDs, they lack the staff structures, infrastructure and budgets to establish EU Competent Authorities and the onerous growing Eu-IUU and phyto sanitary regulations, these serve as impediments to SIDs fleets complying with EU terms of market access. Only PNG and Solomon Islands are recognized currently in PNA as compliant. For many the cost of compliance would exceed their GDP, and staff wise would be the biggest employer, eg Tuvalu. So need a regional CA to help domestic industry So application of EU CDS and Non tariff barriers favours industrialized fleets exploiting us and discriminates against SIDs domestic vessels and aspirations. Eu recognizes IATTC -AIDCP “dolphin safe” standard for EPO yellowfin, but accepts that others “dolphin safe” labels exist but are not required. ICCAT scheme traces blue fin and frozen bigeye currently from Madrid, If expanded to other species it may pose another non tariff barrier to SIDS. “ Dolphin safe” is NOT a import requirement .
- Dolphins were a serious issue in the 80s and unique to the Yellowfin fishery in EPO. On the back of the successful NGO actions, this has not been a significant issue since mid 90s in EPO. it has never been an issue in other regions, nor with skipjack .
- What is the Dolphin safe??? There are many “Dolphin safe” logos. But dolphins do not run with skipjack globally. Earth Island Institute [EII] “dolphin Safe program “, has lead the globalization of a “non issue”, driven through a mix of miss information and “fanatical action” against producers and retailers. Ironically many consumers now look for “dolphin safe” as a sign of eco friendliness. But from numerous independent reviews, all Dolphin safe labels [except for AIDCP] are near valueless,without at sea verification, and a clear mis-representation to the public. – a eco fraud !!.
- Should PNA also have a “Dolphin safe “ logo,???? PNA could actually offer 100% assurance and validity for the fishery with 100% VMS and independent observer coverage, something no other scheme can offer. It could feed into any existing scheme private brands or NGO based to give them validity , credibility and assurance. But the failing of all existing Dolphin safe schemes outside EPO, is that besides no validation at sea is that they are applied in fisheries where there are no significant dolphin issues, they are based on a single species [dolphin], and not ecosystem based. In effect worthless as a eco label.
- Recent USA based survey sees 59% of consumers believe dolphin safe means no dolphin were killed or injured. 22% that there was no dolphin meat in the cans [perhaps logical as schemes primarily inspect processors.]. Only 10% that it meant no encirclement as in US policy specific to EPO yellowfin. there is the perception that “dolphin safe” infers eco system sustainability. It does not. !!!!
- An independent study has ranked various eco certification schemes against 6 criteria, Clearly MSC [blue] exceeded all, on every criteria being eco system based and widely recognized as the highest standard in the trade. Backed by FAO, WWF, Green Peace and Pew foundation amongst others. “ fishery improvement plans” [FIP] where MSC is the typical goal, this is a great initiative, but it is a concern if this link serves to undermine MSC standards with “ MSC Lite ”, being offered as a certification standard in the market place. FAO has provided guidelines on eco labeling. Only MSC really meets those standards as a valid ecosystem based scheme. AIDCP is RFMO scheme recognized by FAO, WWF, Green Peace etc as a single species and region specific certification. EII / FOS schemes are based on action groups which drives or forces companies into joining their own certification schemes. Today I will cover AIDCP, EII, FOS and MSC, Also Pacifical.
- IATTC covers the EPO waters and yellow fin only. The AIDCP scheme has observer verification , only certifies EPO Dolphin safe yellowfin products to markets requiring it
- Earth Island Institute [EII] - Dolphin Safe EII is a radical eco action group and certification scheme in one. Non FAO compliant. A recipe for serious conflict and perceived extortion implications with the combined functions.
- EII actually claims more than dolphin safe, although primarily dolphins. But no claims of this certification scheme are verified at sea, just self certified and it is widely documented that the claims are just not valid and even fraudulent.
- The action side of EII “forces” membership or black listing, extorts voluntary contributions, covering costs of visits and restricts free trade dictating who you can sell to or buy from. EII objectives no targeting dolphins, no IUU, [since 2009] no shark finning, no drift net, by-catch reduction, and no fishing in Marine Protected Areas , No history of declared non compliance by EII members, who self certify “compliance”, once a member. Clearly not true. !!! Some in industry like the self certification schemes, especially where operations clearly are borderline or in breach eg IUU .
- Examples of fanatical action by EII. One wonders what drives these?, is it conservation?, or the commercial interests of EII or their sponsors? or as a warning to broader industry not to challenge them ?. Clearly all small economies and domestic industry are vulnerable to such extortion, an concern globally not just PNA nations and Maldives as we are all small vulnerable economies.
- Unlike Solomon Island and Maldives, - Apparently invisible to EII scheme includes:- Artisanal harvest and trade of dolphin , whales, and other non target species in SE Asia. Whale and dolphin meat traded in Japan and Korea USA dolphin harvests for sea parks licensed by NMFS, Dolphin shows and free global trade of live USA dolphins, and with high mortality. sharks finned at sea [up to 65% in WCPFC] Accidental cetacean mortality in industrial fisheries IUU activity especially SE Asia No mitigation of by-catch with FADs Apparently all non issues once a member of EII, or based in an industrialized nation. Note at least 1 photo was this year, and non related to our PNA island tuna industry. .
- Friends of the Sea is billed as a more broad Eco certification scheme. FOS broadens the net beyond EII dolphin and tuna, and potentially all seafood, something of a re-launch of the EII certification. FOS is not “voluntary”, with fees to join, and for tuna - EII membership is still compulsory as would be “voluntary” contributions. Validity of certification basically no different to EII “dolphin safe”, self declaration and no validation at sea.
- Although Dolphin safe is known in USA and UK , FOS market penetration in Europe is mainly limited in Germany and Italy, almost unknown otherwise. MSC is well known globally, especially Europe.
- This is an interesting recent development part of EII/FOS being launched as a option to MSC, apparently relying on exploiting the PNA 4 month FAD ban to protect juvenile bigeye, ironically a conservation measure when industrialized nations who target this resource contribute nil to conservation. A scheme with no validation of free school on mixed trips, or during fad closure. No observers , no Coc or other aspects to give credibility and validity to scheme, but a Free School premium of about $120/mt projected for reported $75,600 per year in monitoring fees .
- Confident of our high standards of governance, PNA went for MSC certification of the free school skipjack fishery in February 2010 . Globally recognized as the highest standard for credible ecosystem management and sustainability. A PNA MSC process was opposed by EU and USA associations and commercial interests, [ISSF], right to the end. MSC Certification was issued to PNA at xmas 2011, a world first for a purse seine tuna fishery, after almost 2 years intense scrutiny, over 100 consultations, 20 hearings and finally defended in a 2 day adjudication hearing in London. The biggest assessment in MSC history. Today we are enforcing our ongoing governance of our stocks, introducing reference points [RP] and harvest control rules [HCR] for the perpetual sustainability of our resource. Over capacity remains a global issue, but it is not homegrown by island states !, PNA manages by VDS, a rigid effort control, which put control in our hands, not industrialized fleets who have invested in over capacity to exploit us. But to utilize MSC certification we need develop a certified MSc coc scheme from the net to the factory, whereby there is 101% independent assurance of no mixing of non MSC fish, this again a world first.
- MSC Chain of custody is complex, a fishery where we want economic incentives for free school tuna which must be kept separate from associated schools eg FADs on the same boat. An unprecedented complexity to MSC COC.
- The robust PNA / MSC COC scheme builds on PNA MTCs , 100% observer coverage VMS, tuna catch retention, in port transshipment, whale shark measures, etc and ship and company data, log sheets, catch sampling, and mass balances to ensure absolute surety of MSC free school skipjack is free school and in fact truly “Dolphin Safe”. Set by set, well by well, data is maintained in FIMS data base together with VMS records to ensure traceability from net to cold store.
- In unprecedented actions, WWF, Green Peace and PEW have individually and all 3 jointly put declarations supporting PNA MSC as a credible certification and opposing EII actions to block PNA MSC COC implementation and MSC trade.
- Pacifical , is a PNA marketing initiative , aimed to see the benefit of MSC certification as a premium back to our industry and PNA nations. We have today >100,000 mt of commitments to PNA MSC tuna products globally. Each subject to PNA co branding and guaranteed 20% premium to PNA Parties and industry. Yet we are being opposed and even our industry still facing extortion by single species schemes, without verification or credibility, who are threatening branding our partners as “non Dolphin Safe” enterprises, and blacklisted globally. Under PACIFICAL we link the FIMS coc data base with regular onshore coc schemes and commercial documentation. It offers a truly valid certified traceability from the net to retail. What PACIFICAL has done for the market is link the 2 and reverse it. So the consumer may log onto the internet and trace the can in the hand back to the net, based on can production codes on every can lid and offer full traceability. note words and footage are data base generated subject to the can code Tenkyu tru, komol tata, Vinaka, Thank you in conclusion I will show a brief video See Video