The EU is currently proposing changes to the common fisheries policy that include provisions for a ban on discarding of small and large pelagic species (from 2014), and species under quota (from 2015). Such a ban would mean that fishermen would be required to land all fish they catch. The main objective of the ban will be to avoid the capture of any unwanted catch. However, there is always likely to be some fish caught that cannot be sold on the human consumption market due to a weak or absent demand for these species, or catches of fish under the minimum landing size that cannot legally be sold. We explore whether the discards not destined for human consumption could be utilised. This information is needed in order to be better prepared to deal with the discards ban when implemented.
Fish and shellfish automatically become an animal by-product when the decision is made that they are not intended for human consumption. Fish discards that do not enter the human food chain will be classified as Category 3 animal by-products provided they do not show signs of disease communicable to humans or animals in which case they would be category 2 animal by -products. As such, the main regulatory framework for utilising discards is the EC Regulation 1069/2009 (EU control Regulation) and its corresponding implementing EU Regulation 142/2011 (EU Implementing Regulation). The key Articles related to this legislation are reviewed.
The views of the main commercial outlets towards their suitability and interest in utilising unwanted catch that would not be destined for human consumption were sought through interviews with company managers. Results indicate that the opportunities for utilising discards not fit for human consumption include reduction to fishmeal and fish oil, ensiling, composting, anaerobic digestion with energy recovery, and freezing (prior to use as bait). Nine main outlets in UK expressed interest in utilising discards as raw materials to process into animal, pet and aqua feed; compost and organic fertilizer; frozen bait; and other products such as renewable energy generation. Most outlets stated that they accept raw material in all formats including as whole fish, trimmings, ensiled or fresh.
Estimates of discard quantities from English fleets, based on data from scientific observers, showed that most of the commercial outlets are not located close to the main landing ports where the discards would likely come ashore. Most outlets however, have extensive transport links that they would use which would enable them to cover even the remote ports. Others would consider setting up processing facilities at the major ports where most material would be landed.
Preliminary analysis on cost of discarding shows that a discard ban on all species will lead to increases in annual operating costs for fishermen ranging from £4,708 to £90,959. If the ban is imposed on quota species alone, as has been suggested by the Commission, then the annual increase in operating costs for each vessel will range from £1,709 to £33,005. Given that the discards may end up for fishmeal processing where the fishermen will fetch around £125 per tonne, then majority of the fishermen will make losses in their fishing operations.
Although the commercial outlets interviewed could not provide estimates for the revenue they would generate by processing discards, managers insisted that they would be able to make profit by utilising unwanted catches that were not destined for human consumption. With the exception of two outlets who would consider building new infrastructure to accommodate fish discards, all other outlets indicated that they already have sufficient processing capacity.
Two outlets expressed some concerns regarding the quantities that will be available to them whereas the majority did not see any issues towards utilising bulk discards. When asked whether utilising fish discards makes commercial sense, the respondents stated that utilising as many of the discards as possible to help feed humans was key. Most felt that directing the remaining discards to usable products such as fishmeal, fish oil, animal feed, pet feed and organic fertiliser, would be a disincentive for fishermen to catch discards. This is due to the low prices paid by the fish by- product processing companies in comparison to the potential revenue from supplying for human consumption. All commercial outlets stated that dealing with by-products was their main business and the utilisation of discards is a real opportunity to expand their business. They were keen to develop business models and pilot schemes to accommodate fish discards.
This feasibility study reveals that there is enough interest in UK registered commercial bulk outlets dealing with Category 3 animal by-products to utilise fish discards not destined for human consumption. Most see this as an opportunity to expand their current business while others see it as an opportunity to develop further solutions. As a result, commercial outlets could utilise all of the non-human consumption discards that would be landed with the implementation of a discard ban. However, the financial returns to the catching sector would be low (less than £150 per tonne) compared to the human food chain.
This work has shown that any discards that are landed should ideally be utilised in human consumption. Where this is not practicable then utilisation of discards in bulk uses such as fishmeal or animal feed is the next preferred option. Bulk outlets that may be considered ‘waste’ operations such as composting and anaerobic digestion are least desirable.
Further ReadingYou can view the full report by clicking here.