Japan prepares its own CDS (and I’m on my way there!) / by Francisco Blaha

Fish is soul food for the Japanese citizens, and it is an integral part of the Japanese culture as it  comprises more than 40% of animal protein consumed each year. Japan is the 2nd largest seafood importer after the EU, but the biggest in terms of a single country. The main suppliers to the Japanese market are China, the United States of America, Chile and Thailand, while the top imported products are shrimp, tuna, salmon and trout. Japan’s fish exports are marginal in comparison, with the total value of Japanese imports 8 times greater than that of its exports.

Hopefully it says what I meant… (love my infographics tho)

Hopefully it says what I meant… (love my infographics tho)

Japan is also the world's largest market for high value species, importing 470,000 tons of tuna every year, and of course, this high import rate makes it vulnerable to the inadvertent import of IUU fish (as any major Market). Yet interestingly, Japan does not have operational market access requirements for it seafood, not for IUU fishing nor for seafood safety.

Yet in terms of the IUU side, things are to change as the Fisheries agency and the parliament (DIET) have been discussing the need to have some form of unilateral Catch Documentation Scheme as the EU CCS and one could argue the US SIMP supposed to be (see here for details).

They have been quite interested in due diligence and learn from the shortcoming of both systems and trying to not make the same operational mistakes, which is awesome.

Hence my trip there, I been invited to give a seminar at the DIET and to have some talks to people of the Fisheries Agency.

I have to find my way the 2nd member’s office building and (horror!) wear a suit and tie!

I have to find my way the 2nd member’s office building and (horror!) wear a suit and tie!

There is quite few people involved in these process, so I don't really know a lot of the way they are going, but I’m very interested to help.

So far the signs are positive, the idea is to:

  • Base it on FAO's guideline on the catch documentation scheme (even if it is unilateral)

  • Use the EU model principle of involvement of the government (yet may not only be flag state, but hopefully coastal and port state have a role)

  • Be electronic

  • Initially targeting species selected based on a risk-based approach (not all species will be included at once as target), with the aim of increasing the target gradually

  • Target species selection and criteria designing for the species selection will be conducted by a newly establishing task-force under the Fishery Policy Council.

  • The idea is not to violate the WTO’s rule of non-discrimination among domestic and import products, as the new fisheries law, established the end of last year, says most of the major domestic fisheries need to report their catch information anyway.

 Apparently some concerns  around “what if the amount of seafood that processing companies deal decreases due to this CDS how do you (gov't) compensate?" was raised, in a very polite and calm manner. Which is in principle very interesting, yet this has not happen (meaning not changes in volumes imported) in the EU with almost 10 years of implementation or the US so far… without noticeable changes in the traded volumes entering the EU, either the present EU system is not working or there is no IUU fishing… I think the answer is obvious… (references below) 

In any case, I’m very exited to go there… with Japanese efficiency all presentations were sent ahead of time and translated (as you can see on the translated part of one slide of my presentation)

Anyway, form the industry side, is again another requirement to comply with… like if the EU and the US ones weren’t enough! So hopefully Japan (with or without my help), does something practical and effective on their CDS… as that would be a novelty!

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One of the basis of setting the EU CCS up was that figure that 20% of the fish traded is IUU, hence if the CCS scheme would be effective we would have seen a lowering on imports. A 2014 DG MARE commissioned report[1] on finding 56 recognises that: “The analysis was specifically designed to report trends in the volume of several species codes identified in the CN. With the information used (analysis of trade statistics, Member States analysis and discussions with EU traders), the results showed that no impact on trade in relation with the IUU Regulation can be detected”

Furtherer, an later OCEANA report found that because Spain’s better systems trade increased in Portugal and other countries with less stronger systems.

On the other side, then have been some rejection and some issues with certificates, yet they relates mostly with problems with the certificate (the piece of paper) and represent very little of the full volumes entering. 

A EU parliament commissioned report (2) concluded: “Furthermore, the monitoring and supervision of the EU IUU Regulation by the EC to date has been opaque, patchy and incomplete. Until this is improved, accountability will be limited, and the required checks and balances will not be in place. There are existing provisions in the EU IUU Regulation that are not being instituted at all (e.g. alerts), and those that are being instituted are not being recorded (e.g. SLOs, audits, biennial reports) nor being standardised (e.g. training, procedures). This applies to actions with respect to EU MS (section 4.3.3), actions with respect to third countries and transparency and the availability of data generally (section 4.3.4). No information is available on the reasons and number of rejected or blocked consignments since the entry into force of the EU IUU Regulation. This makes it impossible to evaluate the actual impact of this Regulation on the imports of IUU FAP into the EU”

[1] https://ec.europa.eu/fisheries/sites/fisheries/files/iuu_regulation_final-report_en.pdf (STUDY ON THE STATE OF PLAY REGARDING APPLICATION AND IMPLEMENTATION OF COUNCIL REGULATION (EC) NO 1005/2008 OF 29 SEPTEMBER 2008, ESTABLISHING A COMMUNITY SYSTEM TO PREVENT, DETER AND ELIMINATE ILLEGAL, UNREPORTED AND UNREGULATED FISHING (IUU REGULATION) SPECIFIC CONTRACT NO)

2.http://www.europarl.europa.eu/RegData/etudes/etudes/join/2013/513968/IPOL-PECH_ET(2013)513968_EN.pdf. COMPLIANCE OF IMPORTS OF FISHERY AND AQUACULTURE PRODUCTS WITH EU LEGISLATION