A comparative study of KDEs in import control schemes aimed at tackling IUU in the EU, US & JP. / by Francisco Blaha

Is nice to read a study that goes along the line of things one has been saying and writing for a while, and even more so when the authors are 5 big NGOs (EJF, Oceana, TNC, PEW and WWF) that form part of the IUU coalition.

One for the EU, japans does not need one yet, the US SIMP don’t care about state authorities but they have that stupid NOAA 370 form, then the ICAAT BE document, then the MSC CoC (why?) gotta love the present paper CDS world.

One for the EU, japans does not need one yet, the US SIMP don’t care about state authorities but they have that stupid NOAA 370 form, then the ICAAT BE document, then the MSC CoC (why?) gotta love the present paper CDS world.

In fact, I echo the words of my friend Gilles Hosch as mine when he wrote to me yesterday when I sent him the report: “it is the first time I read something in which I was not involved, covering my area of expertise, that repeats all of my thoughts and conclusions one by one, as published in previous work… that is nice because it tells me that some of our work is getting read, and some of our messages are going through, and are starting to fall on open ears”…

This shouldn't surprise us, as the study quotes our FAO book plus Gilles’ work and my blog on the topic quite substantially. In fact, they contacted me a few months ago to ask me for permission to quote my blog and review the draft, which I happily did, and I’m pleased that most of the 32 recommendations/comments were incorporated.

Obviously I’ll recommend you read it! Is good and clear stuff… I like the ”who’, ‘what’, ‘when’, ‘where’ and ‘how’ approach of a seafood product as it moves through the different stages, yet I thought aligning them to the type of states would have been very useful

The objective of the study is to identify areas of convergence, as well as gaps that should be addressed by increased data consistency at a technical level, in order to facilitate trade and improve information exchange and cooperation between key market States. In this context, the study focuses on existing unilateral import control schemes and requirements already in place for the top three seafood market States – the EU, the US and Japan. After providing a brief introduction of existing import control schemes in these markets, the EU IUU Coalition presents a set of best practices based on the FAO guidelines (we were involved in that), existing sources, including peer-reviewed literature, technical documents, and research papers. A comparative analysis of data requirements in existing import control schemes is then provided followed by conclusions and recommendations.

I also like that they acknowledge that: “There is a real risk of a proliferation of non-harmonised unilateral trade instruments to combat IUU fishing. A lack of standardisation and harmonisation among systems can lead to a situation where CDS requirements in multiple systems may be poorly understood and design flaws may pass undetected and be repeated in new systems. For fishers and supply chain actors that currently or may in the future seek to sell or process catch for multiple markets, the costs of complying with different systems could be considerable.”

And that is my biggest frustration with CDS, the market states that impose them don't want to concede to a better global system and part of the reason why I so disappointed with the present status of the CDS discussion worldwide… I’m working with at least 3 organizations on the topic and unfortunately, even in groups of countries with same overall interests (trough regional organizations or RFMOs) no one seems to want to concede anything… and producers nations do not have the power to change markets. 

The simple fact that after 9 years the EU set up an e-system that is only voluntary and for its members only while requiring everyone else to still work on falsifiable paper and the US SIMP bypasses ALL of the authorities of states (flag, coastal, port and processing) responsibility are just telling examples of this malady.

Honestly, other than pointing to this, I don't even know if producing countries, NGOs and small players like me… can’t change anything… CDS is just a set of nice words that everyone seems to say we are doing… but NOTHING has changed in years now… so that is the reason I’m focussing on PSM (vital for CDS in any case) and Labour issues. since it deal with reality and not with bureaucrats that are more worried about their perception, have never worked on a fishing boat or processing plant or yield to political pressure.