BONUS GOHERR – Integrated governance of Baltic herring & salmon
Fishy business in the Baltic Sea
The sale of Baltic herring has been significantly restricted in the EU Member States since 2002. This is due to the detected concentration levels of dioxins, which often exceed the maximum set by the European Commission for food and feed. However, Finland and Sweden have been granted an exemption to sell Baltic herring in their territories or to each other regardless of the dioxin content, providing that the consumers are fully informed about the potential health risks. Despite of the sale restriction, all of the Baltic Sea countries catch Baltic herring annually and during the past few years the catches have been increasing. Finland has the biggest herring fishery in the Baltic Sea (40%) followed by Sweden (16%), Poland (10%) and Estonia (10%).
This is the bit that puzzles me: if Baltic herring is likely to exceed the maximum level of dioxin, but only Finland and Sweden are allowed to sell them, where does all the fish go to? And more to the point, how do the national authorities ensure that non-compliant fish does not end up on the plates of consumers?
Baltic herring is by far the most important commercial catch in Finland, but despite of the exemption, only a fraction of the total catch goes to human consumption. Instead, majority of it goes to industrial use, namely to fur farms. This feed, unlike the feed used in food production (e.g. fish meal and oil), is not limited by the dioxin regulation.
Majority of the Swedish and Danish herring catches also goes to industrial use, mainly to fish meal and oil production. The production facilities are required to test the end products for dioxin before placing them to the market. If the product contains high levels of dioxin, the product goes through a purification process during which the dioxin is extracted. Such purification processes are used at least in Denmark and Germany, and a new facility is currently being built in the Finnish Archipelago Sea. If purification processes are not available, other measures should be undertaken to ensure that non-compliant products do not enter in the EU market, but according to the audit reports of the EU authorities, such measures are often missing or inadequate.
In the other Baltic Sea countries the majority of the herring catches goes to human consumption. It is up to the national monitoring programmes, measures and official controls to ensure that the products ending up on consumer plates comply with the regulation. In practice, these measures include for example centralizing the fishery for certain low dioxin areas (in south western Baltic) as is the case with Germany and Denmark, or targeting smaller (<17cm) herring that contains less dioxin as the Estonian fishery does.
Owing to the dioxin regulation, majority of the non-compliant Baltic herring intended for food is sold outside the EU, which at least in my opinion raises some moral questions. If it’s not safe for us to eat, why would it be safe for anyone else to eat? Currently, this decision is handed over to the countries outside the EU (i.e. the potential buyers), whose awareness and perceptions of the potential health risks may vary significantly. However, it’s not just the third countries we should be worried about. According to the European authorities, none of the Baltic Sea countries have been fully able to ensure that non-compliant Baltic fish is not placed on the EU market as well. This applies to both food and feed.
For example, approximately 5-10% of the Estonian herring catch exceeds the maximum level. Yet, there are no sufficient measures in place to remove the non-compliant fish. But it gets even fishier than that! Back in 2013, it was reported that one of the largest fish processing establishments in Sweden had sold 50% of its Baltic herring to other EU countries for human consumption, even though the consignment included non-compliant herring. And this might be only the tip of the iceberg if you consider the amount of actors involved throughout the production and distribution chain as well as in monitoring. Not to mention that in order to ensure compliance with the regulation, all of these actors have to be aware of it, competent to act accordingly and willing to comply despite of extra work, potential financial loses and technical difficulties. But does it matter in the end? And more to the point, how concerned should we be about dioxins on our plate? To find out more, please read Suvi’s blog post on how different Baltic Sea countries deal with the uncertainty related to the dioxin content of Baltic fish and its implications to public health.