Having worked on sustainability concerns regarding destructive scallop and scampi fisheries for the past five years we have sadly arrived at the point where we are now unconvinced that the industry and government are able to resolve them.
We are now recommending consumers take more concerted public action to put pressure on the sourcing of some of the most environmentally damaging fisheries operating around Scotland and the UK. That is why this month we have launched the #EndSeafoodGreenwash campaign.
We’re hoping to empower people who love our seas and seafood to send a clear message to seafood companies that they have an urgent role to play in halting environmental harm in our seas caused by the products they sell.
Scottish scallop and scampi fisheries have had serious sustainability concerns for many years – the damaging impact of these fisheries on the marine environment and the importance of seabed habitats for the recovery of future fish populations is well understood. We have set these concerns out in detail.
Distribution of permanent and seasonal dredge closures in Scotland’s inshore seas. Data from Scottish Government (Marine Scotland).
Unfortunately, government regulation has been weak and for the past few years we have held out hope that good leadership within the seafood industry would help to resolve these issues – sadly this has not happened.
The lack of action on ‘responsible sourcing’
We want to explain in detail why we have run out of patience.
Back in 2017 we contacted those businesses selling scallops dredged from Scottish waters and scampi caught in Scottish bottom trawls noting that several of these fisheries were ‘red-rated’ yet sold under the guise of “responsible” or “sustainable” marketing. Many of these businesses recognised the concerns but noted that they were only following a precedent set out by the Sustainable Seafood Coalition – a coalition of food businesses who have defined a code of practice which aims to set criteria for the term “responsibly sourced” as a fishery which is either not red rated, or which is red rated but for which there is an improvement plan.
This is a relatively low bar and not what most people would consider responsible sourcing. However, it was not in fact being met by these fisheries in several locations. So, within a few months of setting out our concerns, the Marine Stewardship Council (MSC) explained their intention to establish ‘Fishery Improvement Projects’ (FIPs) for both Nephrops and Scallops fisheries.
These FIPs are a mechanism for improving the management and sustainability of fisheries to remove problems. Those fisheries promoted or led by MSC also seek to improve to the point where they are candidates to be certified by the MSC label (the MSC has therefore a tendency to lead these projects as business/income prospects as internal MSC documents have previously shown).
FIPs are a relatively new private sector initiative that have proliferated enormously in recent years. From just a handful of FIPs in the early noughties, there are now over 150 active and completed FIPs worldwide – some have driven real change.
Open Seas’ engagement with the FIP
We detail a timeline of our interaction with the FIP below:
- We first spoke with the MSC team to discuss the FIP on 20 October 2017 and met with them in Balmedie on 22 Jan 2018 during one of their trips north of the border. We spoke about the concerns, providing them with a report on sensitive areas and the need for protection, and they committed to take our input when developing the improvement plans.
- The steering group was convened and then met in June 2018. We were not invited.
- In October 2018 the FIP’s Steering Group met and discussed a scientific assessment from contractors showing the problems in the fisheries and setting out an action plan.
- In Dec 2018 the group were invited to put comments to the document – MSC initially told us this would be a public opportunity but then stopped responding and no public information was available. We set out our detailed concerns and sent them to the group in any case – you can read them here.
- Our conversation about the project with MSC continued throughout most of 2019, during which time we again pointed to evidence of destructive and illegal fishing in these fisheries. We were asked whether we would like to join the group but then were blanked for a long period after we said yes. The main problem with this was that it meant the actual plans for improvement remained secret: in the case of the scallop dredge FIP improvement plan, the document was private until 28 March 2019, in the case of the scampi dredge FIP improvement plan, until 15 July 2019.
- These reports were not great; they contained either mistakes or factual errors, but by this point they were finalised and not open to discussion. Of specific concern to us, they downplayed issues of illegal and damaging dredging in protected and sensitive areas of seabed and the damage caused to fish stocks by ongoing, illegal discarding – two issues we believe are the most important to resolve.
- In November 2019 we were finally invited to present evidence to the groups regarding our concerns but much of this was dismissed out of hand. For example, although we raised evidence of illegal discarding, the group updated their action plan to state “In the absence of real-time, at-sea data, it is very difficult to ascertain fully whether vessels are complying or not.” This seemed to be a refusal to acknowledge a problem; at the same time a Parliamentary inquiry concluded that discarding continues.
- In June 2020 the Steering Group stated they wanted to engage with Open Seas in an ad hoc way and, so we have resorted to ad hoc email contact.
- But by 5 Feb 2021, having discovered yet more evidence of illegal dredging in the fisheries supposedly being improved, we were losing patience and again contacted the MSC asking for their position on illegal fishing. We were told we had to submit a formal request to the group, so did so on 26 March 2021 – this was made more pertinent when we learnt that the head of the Scallop Committee of the Scottish Whitefish Producers Association (SWFPA) had been prosecuted for illegal scallop dredging. The SWFPA is a member of the FIP and involved in actions of the FIP relating to ‘compliance’. We received a response to our concerns on 13th May which shows no real acceptance of responsibility for this issue nor leadership in addressing it – you can read it here.
- As discussed above, throughout the four years of the above conversations, retailers and others have been selling scallops and scampi as “responsibly sourced” seafood despite them potentially coming from red-rated fisheries, simply because this FIP process exists. Tesco have also sold bottom-trawl-caught langoustine (the same animal as a scampi, just prepared differently) as “responsibly caught” which doesn’t comply with the code established by the Sustainable Seafood Coalition.
When we asked ClientEarth, who host the Sustainable Seafood Coalition, what rate of change they would expect to be achieved by the FIPs they stated the following,
“Under the guidelines, a FIP should be considered ‘inactive’ if it reports no “Improvement in Fishing Practice or Management or Improvement on the Water” within 3 years of launch. PUKFI’s first steering group meeting for the fisheries in question, when the pre-assessment report was commissioned, was in June 2018.”
It is now three years since June 2018 and we have seen no change of fishing practice or improvement on the water – damage, illegality and discarding have continued throughout the three years. We therefore consider the FIP stalled and ineffective, if not actually inactive.
Until there is change, whether via the FIPs or through some other mechanism, we are now campaigning to #EndSeafoodGreenwash and urging people to stop buying dredge-caught scallops and bottom-trawl-caught scampi.