European Commission's services comments on the V0 draft of the HLPE report on "the role of
sustainable fisheries and aquaculture for food security and nutrition"
The European Commission's services welcome the V0 draft of the HLPE report on "the role of
sustainable fisheries and aquaculture for food security and nutrition".
The European Commission's services share the observation that fisheries and aquaculture are absent
from most global reports and discussions on food security and consider that this report offer a good
opportunity to highlight the possible role of sustainable fisheries and aquaculture for food security.
We would like to thank the HLPE for this extensive draft report that provides a good understanding
of the issues at stake and the complexity of fisheries management.
The European Commission's services agree that "food security and nutrition in relation to fish cannot
be achieved without the combined sustainability of the two sectors (fisheries and aquaculture)". The
crucial role of healthy marine ecosystems, sustainable fisheries and sustainable aquaculture in
achieving food security was recognized at the third UN Conference on Sustainable Development,
Rio+201. In this context, States committed to meet the 2015 target as agreed in the Johannesburg
Plan of Implementation to maintain or restore stocks to levels that can produce maximum
sustainable yield on an urgent basis thought the development and implementation of science-based
management plans including by adapting fishing catch and effort with the status of the stock and
managing by-catch and discards. These objectives have guided the recent reform of the European
Union Common Fisheries Policy. This being said, the European Commission's services recognize that
further action would be needed to reinforce the contribution of sustainable fisheries and aquaculture
to food security and welcome the initiative of the HLPE to propose some specific recommendations.
Through its development cooperation, the European Union (EU) has played a leading role in tackling
hunger and malnutrition for many years and food security remains at the top of the EU development
agenda. The EU is the world's largest donor in supporting global food security and sustainable
agricultural development with an annual budget of some 1 billion euros.
The principles of the European Union (EU) development policy in the field of fisheries have been
outlined in a Communication adopted in 20002. For the period 2007-2013, the EU development
policy funds have financed several projects in the field of fisheries and aquaculture for a total of
around 150M euros. Regional programmes in Africa, in the Indian Ocean and in the Pacific Ocean
have focused on strategic governance issues including control, surveillance and the fight against IUU
fishing. As a complement, national programmes have supported the formulation and implementation
of national sectoral policies developed by partner countries as well as initiatives led by local
communities. Fisheries have also benefited from EU development programmes on health
surveillance, sanitary issues and market-access.
1
2
Paragraph 113, "the Future we want", A/RES/66/288
Communication from the Commission to the Council and the European Parliament, Fisheries and Poverty
Reduction, COM(2000)724 final, of 8.11.2000
The Commission's services note that HLPE recommendations in the VO draft report are not final
recommendations and need to be further screened against evidence. At this stage of the process, we
would like to make the following comments for HLPE's consideration:
Starting from a general point of view we think the draft report could more carefully delineate who
are currently the food insecure (producers, consumers, owners, labourers, fishers, aquaculture,
coastal, urban, subsistence, export, etc.) and whose food security could be improved by sustainable
fisheries and aquaculture – and what impact policy choices (trade, fish consumption, fisheries
partnership agreements, certification, labelling, aid, FDI, etc.) have on food security in third
countries.
Furthermore the answer to the major question in the problem statement (p. 10: "recognizing the
well-established importance of fish to food security and nutrition… frequently in a gendered way?")
could be developed and made clearer in the final report.
Looking at specific sections of the draft paper the Commission's services have the following remarks:

With regards to trade, the draft paper argues that export markets maybe benefitting groups
of population in the exporting countries, but that the pressure of exports forces food out of
the country and potentially damages small scale operations. Hence, on balance the benefits
are not clear. Many trade related aspects of the draft report will be discussed at the FAO subcommittee on trade by the end of February 2014. It may be advisable to consider the results
and conclusions from that meeting in the final report.

Regarding fisheries management, looking at balanced harvesting as study object is
commendable and the protection of undersized fish should be the main driver for
sustainability and stock reproduction. In this context the report could perhaps explain in
more (technical) detail how it defines "sustainable fisheries and aquaculture".

There appears to be a strong bias in the draft paper in favour of small scale fisheries (SFF)
and domestic markets and against industrial fisheries and international trade. The same goes
for aquaculture. We believe this is a simplistic point of view. Looking at the small-scale
fisheries sector as essentially a subsistence fisheries is an overstatement. The reality seems
more complicated than this. As regard recommendation 4, we consider that positive
discrimination of SSF should not mean that SSF is excluded from the general principles of
conservation and management policies.

The chapter on governance in aquaculture could be better developed; it would be interesting
to analyse how and what kind of governance (at national and international level) can
contribute to food nutrition aspects.

The draft report makes a link between small scale fisheries, the IUU fishing and the impact on
food security (page 74 under section Fisheries governance at international level) which is
important. However, the draft report ought to take a more holistic view on the full fish
supply chain and cover also the processing industry. In that respect it is not only the small
scale fisheries or the large scale industrial fleets that should be mentioned but also in land
where raw materials are processed.
The existence of effective port and market State measures and traceability of operations in
transformation industry is of paramount importance to address in any strategy for
sustainable fisheries and food security. This is particularly important in areas of the world like
West Africa to avoid creation of 'ports of convenience' or 'back box processing factories' that
would legalize IUU stemming products.

Regarding the impact of measures against IUU fishing and their impact on SSF, we would like
to stress that most of these measures focus on illegal activities on the high-seas or illegal
activities by third country vessels in the EEZ of a coastal State which by nature in general
concerns larger vessels. This in effect means that small-scale vessels rarely are directly
targeted by international measures adopted by RFMO's, nor by the EU. All flag States should
however elaborate national plan of actions against IUU and thereby target the illegalities in
their own EEZ by all national fleet segments.
The EU IUU regulation (1005/2008) which focuses on trade in fisheries products does take
small scale vessels into account by allowing (in its implementing regulation) vessel owners of
vessels smaller than a certain size to be represented by their exporters. The vessels must be
registered though which in effect means that the EU IUU Regulation has led to registration of
many small scale vessels - in particular in West Africa, which is an essential condition for
proper fisheries management.
We consider that the comment: "The IUU term does not make a clear distinction between
what is illegal and what is unreported and unregulated" is not correct. There is a clear
definition in the IUU regulation (1005/2008) of respectively illegal, unreported and
unregulated fishing – just as in the FAO IPOA on IUU. We would recommend the HLPE to
have a look at this definition – and to clarify their recommendations on this issue.

It should be discussed whether it is fully justified to say in the "Summary of key governance
points" (p.76, point 5.4) that there is no adequate international governance for adequate
inclusion of both FSN and aquaculture. There are international instruments, binding and nonbinding which regulate the relationship between fisheries and food security, particularly in
relation to small-scale fisheries and aquaculture. It should be examined whether there is not
a problem of implementation of these international instruments by coastal States and how
this can be better remedied.
On the more specific we would like to draw the intention of the HLPE to the EUs Sustainable Fisheries
Partnership Agreements which could be a useful example for "Fisheries governance at international
level" (page 77):
Bilateral fisheries agreements between the EU and third countries constitute a highly regulated and
transparent framework for fishing activities of the EU fleet in third-country waters. Current
Sustainable Fisheries Partnership Agreements (SFPAs) aim to create a partnership to promote
sustainable fisheries, based on the best available scientific advice and information on the cumulative
fishing effort in the waters concerned and have the objective to allow EU vessels to fish only surplus
resources in the exclusive economic zones of a number of third countries, in line with the relevant
provisions of UNCLOS. They constitute a transparent legal framework which aims to ensure that
fishing activities of EU fleets are respectful of stock status, of the environment and ecosystems and
do not compete with local fishermen communities. Through these FPAs, while obtaining access to
the surplus resources of third countries, the EU provides financial and technical support for the
sustainable development of the fisheries sector of partner countries. Thus, they can contribute to
enhancing food security, both directly (by increasing the local supply of fish) and indirectly (through
generated income due to employment creation, harbour activities, processing factories…).