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An Industry Perspective on the EU IUU Regulations 20/10/2009 AIPCE-CEP is the principle seafood processing, importing and exporting organisation in the EU, being recognised by the EC Commission and with seats on the Advisory Committee for Fisheries and Aquaculture and the Regional Advisory Councils. The EU is reliant on fishery product imports to the extent of 65% of consumption needs, a figure that has been steadily rising.
AIPCE has initiated a number of initiatives in recent years to ensure that IUU fishery products are not purchased and these were last reported at Chatham House in 2007. These control procedures were first applied to Barents Sea cod and haddock supplies, which in tandem with Governmental controls, saw a massive reduction in IUU, Similar initiatives were undertaken in the Baltic and later in Sri Lanka, although in the latter case, this was to bolster existing good practice in a small scale rather than tackle IUU. AIPCE-CEP supports the IUU Regulations concept, but believe that continued best practice will always be necessary, for example promotion of MSC certification to ensure both sustainable fisheries and whole-chain traceability.
Every effort has been taken though out the IUU Regulation consultation period to ensure that a workable solution to procedures is adopted, thereby reducing the administrative burden on the importing industry without compromising the objectives.
Whilst compromises and improvements have been achieved in terms of small- scale fisheries catch certificates, electronic data exchange and approved economic operator status, a significant administrative burden is still anticipated.
There is great concern that with less than 3 months before the legislation comes into force, that the Implementing Regulations are still in draft; that guidance notes are still awaited, many third countries are still to submit their competent authorities to DG Mare and that it is still not clear who the competent authorities will be across all EU member states.
A degree of pragmatic implementation will therefore be necessary for at least the first 6 months. There will also be a need to keep the effectiveness and working of the Regulations under review.
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