Roadmap To E.U. Farmed Fish Policy Reform

The European Commission is planning to revise and expand the scope of E.U. animal protection policies. This is part of a 10-year plan to make the food chain more sustainable (called the Farm-to-Fork Strategy). In July 2021, the Commission announced it is considering species-specific rules on killing certain fish species, including Atlantic salmon, common carp, rainbow trout, European sea bass, and Gilthead sea bream. It may adopt further rules on farmed fish welfare based on scientific evidence as it progressively becomes available. 

Animal advocates have called for a huge range of policy reforms to improve farmed fish welfare in the European Union. The aquatic animal advocacy movement is not resourced to push for all of them, and neither is it realistic to assume all “asks” have the same potential impact or probability of success. The movement must choose according to which policies positively affect the largest number of animal lives, by the largest amount, within the limited scope of what policies decision-makers will actually consider.

Together with my colleagues from Rethink Priorities, we’ve built a strategy based on the strengths, weaknesses, opportunities, and threats of the animal advocacy movement in the E.U. farmed fish policy space. In this blog, I explore some of the key insights from our full report.

Which Fish Are The Most Promising Targets For E.U. Policy Reform?

The majority of fish consumed (in tonnes) in the E.U. are either wild-caught fish or farmed fish imported from non-E.U. Norway, Scotland, and Turkey. However, these are unlikely to be the most promising targets for policy reform in the short term. There is little evidence that the E.U. will regulate fish imports this decade. In fact, a leaked draft impact assessment from the European Commission suggests that seafood will not be included in the list of imported animal products that may be regulated after a 10-year transition period. 

To reduce the suffering of wild fish (especially those caught for fish feed), some experts have suggested that we farm herbivorous species or make fish feed more plant-based. However, these interventions have uncertain effects on wild fish populations. For example, it’s uncertain that fish welfare in the wild would be better if they weren’t caught. It’s also unclear if decreases in demand for wild-caught fish actually change the amount fished. Finally, some evidence suggests that carnivorous fish are heavier at slaughter time than herbivorous ones — in other words, switching to herbivorous fish may require more farming time, thus causing more net animal suffering.

However, ~45% of global farmed sea bass and sea bream alive at any one time are in the E.U., so this is an area where an E.U. focus can have a significant impact on the global problem. Sea bass and sea bream are among the most numerous in terms of individuals farmed in the E.U. (444 million sea bream and 381 million sea bass juveniles produced per year). 

A large number of farmed trout in the E.U. achieve slaughter weight at a small size, increasing the number of animals affected. “Portion trout” is generally a whole trout, below 500g (or even below 450g), “medium-sized trout” is between 500g and 1.2kg, while “large-sized trout” is above 1.2kg. About 64% of the E.U. production is portion and medium-sized trout. The total time spent per year on farms by all the portion trout farmed in the E.U. is likely comparable to sea bream. Additionally, most E.U. consumption of trout, sea bream, and sea bass comes from E.U. production. Therefore, we narrowed the scope of the report to the species farmed in the largest numbers of individuals and life-years in the E.U. — sea bass, sea bream, and small rainbow trout.

Which E.U. Farmed Fish Policy Reforms Seem The Most Promising?

The report argues that the most promising E.U. fish policy “ask” is a fast transition to better slaughter conditions for all three species. We recommend this for a few reasons: It’s an option that E.U. policymakers already suggested as part of their larger animal legislation reform package, animal advocacy organizations support it, and it has real world implementation. Furthermore, less than 5% of sea bass and sea bream are already stunned, and while the Commission claims that 20%-50% of trout are stunned, it’s possible that the majority of trout individuals are not stunned even if the majority of tonnage comes from stunned fish. There are also clear actions to improve the request, namely by showing the European Commission that companies don’t need the full 10 years to transition to more humane slaughter methods.

The E.U.’s scientific agency, EFSA, has opinions on farmed fish welfare due 2024-2029.  These will offer an entry point for fish farming reforms that affect the whole life of an individual (e.g., water quality standards, stocking density maximums, enrichment especially for juveniles). As such, fish advocates may be able to push for these reforms in the future. However, the aquatic animal advocacy movement needs to start creating economic and political precedents years in advance to make the most of EFSA opinions on farmed fish welfare — the report discusses what sort of evidence is required.

How Might Political Changes Affect Policy Priorities?

One crucial concern is that after the European Commission presents its reform proposal (if this happens as planned in September/October 2023 including a cage-free hen policy), little progress will be made before the June 2024 European Parliament elections put more conservative co-legislators in place, and a new European Commission five-year term starts in November 2024. If reform negotiations drag on and the movement doesn’t pivot to pushing for reforms to how fish are reared, advocates may not make the most of the EFSA opinions, and they could be left playing catch-up in a few years.

The report argues that advocates should make an effort before June 2024 to push for a fast slaughter transition and ensure this ask makes it into the final law — especially if things are progressing quickly. However, given limited resources, if advocates spend excessive resources advocating for slaughter reform, they risk taking away from efforts to reform the fish-rearing process later this decade. Rearing reforms are expected to have a positive impact on farmed fish, so advocates can’t afford to neglect them.

Why Might Someone Disagree With Our Conclusions?

Even if the E.U. reform looks to be slowing, some advocates may argue that the movement should focus 100% of their fish policy efforts on slaughter to set a precedent for farmed fish advocacy at the E.U. level. In turn, they might argue that this slaughter provision forms an entry point for reforming the rearing process later. This may be a compelling argument if you doubt that there will be opportunities to utilize EFSA’s opinions to create reform, especially in the absence of a fish slaughter precedent. 

However, the report argues that slaughter reform is not necessary to make further progress for several reasons. Firstly, the European Commission’s leaked draft impact assessment already signaled a willingness to explore fish reforms after the EFSA opinions are released. Secondly, the Commission will need to grant itself power to update rearing regulations in light of the EFSA opinions, and this is unlikely to be affected by a fish slaughter requirement being included now or not. Finally, if the E.U. reform on the whole is going poorly, we believe the movement may not want to pursue fish advocacy if it comes at the expense of reforms to egg-laying hens and broiler chickens that are also on the table. 

Other advocates might think the movement should push for more than slaughter reforms right now, with the goal of putting at least one more welfare improvement onto the E.U. policy agenda. In our view, however, there is not much evidence of political appetite for fish rearing reforms yet. Currently, we also don’t have enough high-quality evidence to persuade policymakers to take these requests seriously now. As researchers continue to explore fish welfare and what they need to thrive, this may change in the future. 

Next Steps & Acknowledgments

Below you’ll find a visual roadmap to the advice we make throughout the report. Animal advocates in the E.U. can use this as a guide to inform their research and campaigns, with the goal of improving the lives of farmed fish over the coming decade.

ROADMAP TO E.U. FARMED FISH POLICY REFORM

The report is a project of Rethink Priorities — a think tank dedicated to informing decisions made by high-impact organizations and funders across various cause areas. If you are interested in RP’s work, please visit our research database and subscribe to our newsletter.