My work goes through phases over various topics. Sometimes, I step away from certain areas of work due to other interests or to give space to the individuals in the region whom I have already trained, as they excel at what they do. My work on EU market access (sanitary and IUU) in the Pacific was one such case, so nine years ago, I decided to step back from it (I still update the book I wrote about that, though) to focus on CDS and PSM.
CDS is an area of genuine interest for me. I remember reading a fantastic report by Shelley Clarke in 2010. I was immediately sold on it since CDS serves as the “roof” under which many aspects of MCS and traceability come together, both fields where I have significant work experience and have invested considerable effort. I have engaged deeply in this area, from the FAO's CDS expert consultation and guidelines to our work with Gilles Hosch on several FAO publications (as a co-author or peer reviewer). Furthermore, I need to write more books on traceability and the technologies that support it.
Yet, very frustratingly, all my efforts have been theoretical, lacking practical applications so far. A few years ago, I focused on PSM, a key area for MCS and, consequently, any CDS deserving of that acronym. Yet, the basics of multilateralism and interoperability have been part of my CDS mantra since day one.
Therefore, when Gilles and Sheley published this new paper on the topic, I had to read and promote it.
I wish this was compulsory reading for any bureaucrat planning another unilateral CDS in any importing country.
Here is a summary of the article; however, I recommend reading the original.
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Catch Documentation Schemes (CDS) are systems designed to validate the legal provenance of seafood products, aiming to prevent illegal, unreported, and unregulated (IUU) fishing products from entering markets. These schemes rely on validated documents, such as catch certificates, to track seafood supply chains from fishing grounds to consumer markets. However, the proliferation of independent CDS has inadvertently created opportunities for fraud, such as "double-spend" fraud, where catch certificates are reused to import more fish than legally certified. To address these challenges, interoperability between CDS is essential for effective cooperation, data exchange, and fraud prevention.
Types of CDS and Their Objectives
CDS can be categorised into two types: multilateral (fishery-based) and unilateral (market-based). Multilateral CDS focus on protecting specific species, such as toothfish and bluefin tuna, regardless of market destination. On the other hand, Unilateral CDS aims to protect markets from IUU fishing products and cover multiple species entering specific markets. The European Union's Catch Certification Scheme (EU CCS), operational since 2010, is the largest unilateral CDS. Other major schemes include the United States' Seafood Import Monitoring Program (SIMP), which, while not a CDS, shares similar objectives by requiring importers to record legal provenance information.
Design Pillars of CDS
The effectiveness of a CDS depends on three core design pillars:
Key Data Elements (KDEs): Information such as who caught the fish, where it was caught, and its transshipment and landing details.
Architecture: The types of documentation required (e.g., catch certificates) and rules for handling them, including critical tracking events (CTEs) where KDEs are captured.
Validation Procedures: Establishing responsibilities for producing, checking, and certifying CDS information.
If any of these pillars are weak, the CDS becomes vulnerable to fraud and fails to prevent IUU fishing products from infiltrating markets.
Challenges and Opportunities for Interoperability
Interoperability between CDS is crucial to prevent IUU fishing products from diverting to markets with weaker protections. It can take several forms:
Level 1: Passive emulation of other schemes' structures and information content without established procedures for alignment or data exchange.
Level 2a: Harmonization of KDEs, document formats, and CTEs, enabling sporadic data exchange.
Level 2b: Adoption of shared rules and systematic protocols for information exchange, including automated alerts and cross-checks.
Level 3: A fully integrated "super CDS" operating as a centralised electronic platform for multiple markets, automating the reconciliation of catch certificates and traded amounts.
The EU and Japan have achieved Level 2a interoperability due to the similar architecture of their CDS, which facilitates data comparison. However, deeper interoperability at Level 2b or Level 3 requires digitisation, robust protocols, and strong working relationships between schemes.
Addressing Double-Spend Fraud
Double-spend fraud is a significant challenge for CDS, where catch certificates are reused to import more fish than are legally certified. This fraud can occur between markets operating separate unilateral CDS or within later supply chain stages. The EU's recent legislative overhaul of its CDS, set to take effect in 2026, introduces mechanisms to combat double-spend fraud. These include electronic systems for data management and a quantity management mechanism to ensure that the weight of imported fish matches the weight validated on catch certificates.
Case Studies and Global Efforts
Japan implemented a unilateral CDS in 2022, covering species like squid, mackerel, and sardine, based on the EU CCS template. Australia is considering developing a unilateral CDS, while South Korea has enacted a system that could evolve into a genuine CDS. The proliferation of unilateral CDS increases opportunities for fraud, highlighting the need for interoperability.
The US SIMP poses challenges for interoperability due to mismatches in KDEs, CTEs, and validation procedures. While achieving Level 1 interoperability is feasible, deeper integration would require significant adjustments to align the SIMP with CDS standards.
Lessons from Other Industries
The global automotive industry provides a model for interoperability, with traceability systems that track components back to their source to address safety, fraud, and efficiency. Similar principles can be applied to seafood supply chains to prevent IUU fishing products from infiltrating markets.
Moving Forward
Interoperability is not a binary concept but a matter of gradients and functionality. Electronic systems are essential for deeper interoperability, enabling systematic data exchange and fraud detection. Robust interoperability between schemes can create unified barriers to deny entry of IUU fishing products, intensifying pressure on operators to comply with legal standards.
The EU's upcoming upgrades to its CDS provide opportunities for collaboration and strengthening unilateral initiatives. Structured policy dialogues between experienced and new CDS operators are critical to addressing the challenges IUU fishing poses and ensuring these schemes' effectiveness.
In conclusion, interoperability between CDS is vital for reducing IUU fishing products in global supply chains. By harmonising design elements, adopting electronic systems, and fostering cooperation, CDS can achieve measurable outcomes in combating illegal fishing and protecting seafood markets.