1. EU IUU Catch Certification Scheme
Francisco Blaha
www.franciscoblaha.com

2. But mostly, I’m just an overqualified fisherman
Who am I?
l Ridiculous mixture of Austrian, Argentinean and New Zealander.
l Involved in commercial fishing since I'm 17. As a fisherman, 2nd
mate, fisheries observer, researcher, QC, R&D Manager, Fishery
Industry Officer at FAO Rome and a Consultant.
l I work with industry in the Pacific since 93 (since 95 based in
New Zealand), and as a advisor for DEVFish, ADB, AUSAid, EU,
FAO, WTO, SIPPO, etc.
l I have a MSc in Fisheries Biology (1991), a MSc in Food Science
(2000) and I'm doing a PhD in Governance & Public Policy.
l When I’m not doing this I do family, surfing, swimming, music
and still go fishing (and spearfishing) as much as I can.

3. The EU Market Access
The European Union (EU) is the
biggest single market for fish and
fishery products worldwide.
Over 60% of the seafood
consumed there originates in 3rd
Countries. (For Tuna the
estimated figure is 80-90%)
The EU bases its seafood import
on government-to-government
assurances (official certificates),
without the intervention of any
private type certification or
ecolabel scheme.

4. The certifications
I will keep my presentation focused on 2 types of certifications
The “usual” deals with “fish a safe food”, and provides official
guarantees from the exporting government to the EU that the
fish has been submitted to processing conditions as required
by the EU legislation. It relates to the “health of the
consumers”.
The “new one” who deals with “fish as a legally caught
resource”, and provides official guarantees from the vessel’s
flag state to the EU, that the fish was harvested in
accordance with applicable flag state laws and international
conservation and management measures.

5. What comes first?
Both go in parallel.
To access the EU a country must
be sanitary approved, then all its
vessels intending to provide the
EU market need to be too.
Around 100 countries are
presently approved.
While both regimes are as
different as the work scope of a
Seafood Safety Inspector and a
Fisheries Officer, there should be
synergies in between both
certifications.
Both certificates cannot contain
discordant information.

6. Health certification
Your country CA EU
registration approval listing DG Sanco BIP Market
list that goes to the EU
FBOs allowed to FBOs allowed to FBOs allowed to
produce food and export directly to process and update the list
supply to FBOs and pass it to all the BIPs
feed the EU (EU #)
exporting to the
EU
all FBOs vessels freezer vessels
under your reefers factory vessels
legislation cool stores reefers
ice factories cool stores
transporters processing est.
landing sites
Health
Health
This list stays in the country Certificate
Certificate

7. Catch Certification
Provides official guarantees
from the vessel’s flag state to
the EU:
that the fish was harvested in
accordance with their own
applicable laws
and international conservation and
management measures
The catch certificate is specified
in a expressed format, and shall
be validated by the CA of the
flag state of the catching vessel.
The catch certificate may be
established, validated or
submitted by electronic means.

8. What it means?
The fish was caught...
By who? Where? In what When? How?
quantity?
Primarily concerned with vessel ID
: & fishing ground
la ted Primarily concerned with catch quantity,
re gu : perhaps closure period and gear type
l/ un rted
ga re po All data types are relevant
Ille Un e:
a nc
pli Primarily concerned with area, quantity, season
Co
m e:
ie nc
Sc

9. What it means?
Flag State needs to prove
compliance with:
Fisheries law
MCS activities
NPOA - IUU
International agreements
Bilateral agreements
Coastal State controls
Port State controls
Flag State controls
Market State controls
Management measures of
RFMOs

10. Scenarios
National industrial fishing vessel –
domestic or overseas landings
Importation of raw fish. products.
accompanied by validated catch
certificates – domestic processing or
for direct export.
Mixing of imported and landed fish.
products – domestic processing.
Transshipments – National industrial
vessels transshipping for re-export
Transit with no processing.
Similar scenarios for artisanal
fisheries...

11. Paper is easy
Most countries do the certificates and
most products enters the EU.
Signing the paper is easy enough,
but how meaningful that certificate is,
varies intensely in different countries.
And fisheries at each country is a
unique universe.
As with the sanitary certifications,
there should be a system that can be
audited in order to provide a
background on legality to all
statements.
If you sign and official document, but
can’t prove the truth behind it,
problems will follow.

12. Coastal State controls
Laws are not up to date with the
present situation of the sector,
nor the international and RFMO
agreements.
NPOA–IUU are not totally
complied with, do not incorporate
the best international practices,
nor facilitate focussing of MCS
activities in higher risk areas.
Most lack of a Fisheries
Information System to integrate
all MCS data and the capacity to
evaluate effectiveness over time.
Under-reporting is hard to
quantify.

13. Coastal State controls
Sanctions system is not normally
even-handed and dissuasive –
providing proportionate penalties for
both artisanal and industrial fishers.
The sanctioning regime does not
eliminate incentives for appealing
and taking matters to long court
battles, while the vessel continue
operating.
VMS application does not
completely regulate the operational
and legal aspects of it, in order to
establish non-conformances as
solid legal electronic evidence. This,
however is changing rapidly.

14. Coastal State controls
Tuna vessels landing in 3rd
countries are not consistently
reporting catches to its flag state
fisheries authorities as per their
permit conditions.
Log book reporting is patchy.
Observers programmes are
partially implemented and reporting
has variable time lags until
analysis is performed.
Licensing systems is not
transparent.
Political and economical
interference, etc.

15. Port State controls
Difficulties in coordination in between
maritime, port, and fisheries
authorities.
Difficult interaction in between
Fisheries CA of of the vessels Flag
State and the Fisheries CA of the
Port State.
Limited capacity to inspects landings.
Limited capacity for denial of port
access and prohibition of the imports
of fishery products from IUU vessels.
Political and economical interference,
lack of transparency, etc.

16. Port State controls
Pew’s Port State Performance project consolidates six years of movement data on IUU-listed
vessels, tracking their port visits globally to evaluate port State performance in combating illegal,
unregulated and unreported (IUU). The final data and findings were uploaded on May 25th, 2010.

17. Flag State controls
Difficulties in coordination in
between maritime and fisheries
authorities.
Difficulties in coordination in
between registry and fisheries
authorities.
Fisheries CA have no full control on
vessels operating internationally.
Limited capacity to interact with
fisheries authorities of landing
countries.
Political and economical
interference, lack of transparency,
etc.

18. Market State controls
Difficulties in coordination in
between “health cert.” and “catch
cert.” authorities.
Sanitary control and approval of
vessels that don’t operate in
national waters is difficult.
Sanitary eligibility of products is
complex, as requires separation of
fish from arrival to factory.
While is not forbidden to give a CC
for a vessel that does not hold the
sanitary approval, issuing it does
jeopardise the official guarantees
provided by CA in the health
certificate.

19. Catch Certification Process
Is not really a catch certificate, but
rather another export certificate.
Not many countries have a
information verification procedure,
as they lack of a FIS to integrate all
data required.
They not have an efficient landing
account systems (fish from a same
landings that goes in different
exports, or different landings from a
same boat in one lot).
Disparity in the forms and what
goes in which area, not a complete
understanding of the scenarios.
Not many rejections, but many
expensive delays.

20. The data first, certifications follow
Fish as Fish Fish as Food
Vessels Ports Factories Regional Organizations Authorthies EU
SPC/FFA WCP
PNA, etc
Compliance, Science,
trade statistics
e-cert or paper
ü
20

21. The data first, certifications follow
The origin of the raw materials and the way it arrives define the
eligibility in terms of “fish as food”
Philippines
MoU
PNG
PNG
PNG
Vanuatu / RMI
FSM / Kiribati
Taiwan
EU listed factory
Ecuador
Vanuatu

22. The data first, certifications follow
The validation of the catch certificate defines the eligibility in
Flag state CA terms of IUU fish
PNG
PNG
China
EU listed factory
Vanuatu
Ecuador
Ecuador Kiribati
EU listed factory
Transshipment or
Non processing statement
22

23. Non-cooperating third countries
A third country may be identified as
a non-cooperating if it fails to
discharge the duties incumbent
upon it under international law as
flag, port, coastal or market state,
to take action to prevent, deter and
eliminate IUU fishing.
The EC is discussing the cases of
Panama (429 vessel in IATTC reg)
Belize (34)
Colombia
Honduras
Togo

24. Situation in the Pacific
In the approved and notification list:
Fiji
French Polynesia
New Caledonia/Wallis and Futuna
PNG
Solomon Islands
Not in the notification list
FSM (initially in but taken out in
october 2010)
Kiribati
Marshall Islands
Vanuatu and Cook islands
In 2011, a 30 country wide EU
funded evaluation programme
visited PNG and found only one
major issue with the validation of
foreign Certs.

25. Situation in the Pacific
The 2nd part of the that evaluation
programme has just started, will
visit 15 countries over the next
months
The reports of these missions are
only of advisory nature, not audits
In the Pacific will visit
Fiji
Solomon Islands
Kiribati
Marshall Islands
FSM
In parallel, DG Mare visited Vanuatu
in January 2012, and literally
suggested it, as a “flag of
convenience”

26. Difficulties with the CCS
The EU now has 2 mandatory export
certificates instead of one.
Categorical Flag State rule (Charters
not contemplated)
Liability of the captain to operate
legally is transferred onto the
factories.
Immediate incentive for third
countries to monitor national
landings is cancelled...
Detection of IUU fishing occurrences
becomes less likely (fish does not
turn IUU inside a processing plant)
National CC models not available on
EU web

27. Difficulties with the CCS
System is erected on circulation of
photocopies
Place of landing is not recorded
Most 3rd countries do not
simultaneously monitor in- & outflow
of Certificates & related products
3rd country to 3rd country sales of
partial lots complete with whole CCs
3rd country purchases of raw
products through fish brokerage
firms
Certified weights on CCs double
every single time a partial
consignment is sold.
Laundromat for IUU fish

28. Fish laundering

29. Difficulties with the CCS
CCs are not issued and/or recorded
centrally at the EU
CC “migration” and related weights
go unmonitored
The amount of fish entering the EU
under specific certificates is
unknown
3rd countries and MS cannot query
individual certificates to assert
legality
3rd country “e-solutions” can only be
incomplete and imply a multiplication
of wasteful partial non-solutions
Zero “control” at EU level, beyond
customs adding up & rubber
stamping off (often) fake numbers

30. Conclusions for PI countries
Very annoying, but not impossible...
It offers an opportunity to
strengthen MCS system.
It does not offer an opportunity to
transit and transshipments
countries.
Countries with fleets need to get
sanitary authorization first.
Compliance cost increases for
industry and CA
Fish accountancy
Fisheries volumes forensic analysis
It highlights the need for a
comprehensive regional Fisheries
Information Management System.

31. Conclusions for the EU
Enforce Batch Integrity (Ensuring that
the fish certified by the flag State is the
same fish imported by the EU after
processing)
The lack of a central database fuels
the multiplication of fake certificates,
de facto legalizing imports of IUU fish
The CCS will not curb the importation
of IUU fish in any meaningful manner
unless a central electronic
certification system with global
logons for authorities and operators
is implemented.
The idea behind the regulation is
commendable – but so it should
be its tools of implementation...

32. Thank you and good fishing