EFFOP statement on the safety of European fishmeal
European Fishmeal (EFFOP) is aware that an issue has been raised in relation to the content of PFAS in fishmeal. This comes after the Danish DTU Food Institute carried out a technical examination of Danish organic eggs. They believe the PFAs originate from fishmeal which is used as a feed ingredient. We take this issue very seriously and have initiated analyses to get a complete picture of all the fish species that are used to produce European fishmeal. A database will be established to map the PFA profile of European fishmeal batches that can then be used for future risk assessments in animal feeds. There is a large paucity of knowledge in our current scientific understanding of the distribution of PFAs in the whole value chain. As an industry, we urge the continuation of high-quality scientific research that can support policy decisions and any future regulation or management of this issue. We refer to the following technical information below:
- Since autumn 2022 preliminary analysis of Danish fishmeal has seen no cause for concern, the values found reflect the current values in EU regulation, that entered into force in January 2023, for whole fish on wet basis (8 μg /kg body weight: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R2388). There are no values set for feed ingredients and the fact that fishmeal is a dry powder with little moisture should not be taken for granted when performing these comparisons, since dry powders contain little water and are therefore more concentrated.
- Unfortunately, the original investigation did not contain traceable origins in relation to the fishmeal used in the feed mixes for chickens. EFFOP is coordinating with the appropriate authorities, but we refer to technical information in point 3. Indhold af PFAS i fiskemel og via indhold i økologisk foder i økologiske æg(pdf).
- A global analysis of fishmeal from ninety-two commercial fishmeals in the United states (n=9), China (n=28), Europe (n=5), South America (n=45) and southeast Asia (n=5) revealed the highly variable nature of fishmeal (Li et al., 2019). This is due to seasonality, species, site of catch and production method. Therefore, the fishmeal that is either measured or used as feed is highly context specific and should not be representative of a whole industry. EFFOP is working to map areas of risk and how fishmeal from these areas falls into current regulations.
- In 2022, the Norwegian Marine Research Institute released its technical report on contaminants in farmed Salmon, rainbow trout, cod and arctic char with values averaging 0 μg/kg (https://www.hi.no/en/hi/nettrapporter/rapport-fra-havforskningen-en-2021-40). Whereas a recent Dutch study showed that most of the farmed fish (trout, catfish, turbot, salmon, tilapia, pangasius) were among the lowest contaminated samples for PFAs in a nationwide investigation when comparing against wild caught fish and shrimp (Zafeiraki et al., 2019; averages for farmed fish ranged from 0.06 to 1.5 μg/kg). Protein and fat from fishmeal and oil contribute significantly to modern aquafeeds and can be as high as 25% for Atlantic Salmon (Aas et al., 2019) and thus there seems to be minimal transfer when compared to organic egg production.
In summary of the peer reviewed information above, PFA levels in fishmeal are very context specific and likely driven by species-specifics, production methods and spatial and temporal variations. We recommend that policymakers bear this in mind and hope that future discussions can lead to judicious, public risk assessments for all ingredients used in animal feed. We believe so far that the highlighted PFA accumulation from the technical study in Denmark may be specific to eggs. But more information is needed. Fishmeal and fish oil are one of the most important animal feed ingredients on the planet and its removal is likely to cause socio-economic challenges for the food sector as well as health and welfare problems for livestock due to sub-optimal nutrition provided from alternative sources.
Stakeholders that request ICES advice gain unique insight to ICES at MIACO 2022
European fishmeal and fish oil producers participated in the “meeting between ICES, Advisory Councils and other Observers (MIACO)” on 12th-13th January 2022 in Copenhagen.
ICES provides scientific advice and is best known for its annual advice on the maximum sustainable fishing catches, which are used by the EU and coastal states to set annual fishing quotas and TACs. EFFOP has observer status of ICES, which gives us the opportunity to have first-hand information about the advisory process and methodologies used in ICES, in tandem with our constructive feedback on that process and how it can be improved.
A summary of the discussion points presented at the MIACO meeting are outlined below:
Quality control of ICES data and the data profiling tools
The rationale and use of the data profiling tool that ICES operates was explained during the meeting. The data profiling tool, available at ( https://www.ices.dk/data/assessment-tools/Pages/default.aspx ) checks and charts the ownership, veracity, and accessibility of data use in ICES advice from outside sources which can be very beneficial expanding our current data sets on fish stocks where it becomes limited.
Stakeholder’s perspectives and engagement strategy
MIACO was invited to comment on ICES engagement strategy which gives general guidance for the ICES community on how to organize stakeholder engagement, with concrete details and guidance being developed into an implementation plan.
Renewable energy opportunities and challenges
Currently there is a large need to increase offshore installations. This development will affect the marine environment as well as other maritime activities. However, the installations do not only pose challenges, but can offer opportunities, including for protection of habitats and co-location of other activities. MIACO took part in an interactive exercise to build a conceptual model of the challenges faced by managers with the expansion of marine renewable energy facilities with the implications on commercial fishing a main consideration.
Benchmarks and reviews
The discussion panel presented the recent developments on benchmarks and gave an overview of proposed new guidelines. The benchmark process is a critical element in ICES advice to ensure a sound scientific basis as a means to peer-review and incorporate new science (new knowledge, data, analyses, and assessment methods) for use in provision of recurrent advice for fish stocks. MIACO was presented the recent guidelines on benchmarks at ICES with constructive comments made on the pros and cons of their current approach. An updated benchmark process is currently underway for two important fishmeal stocks, capelin and sand eel. MIACO asked in particular about dates for completion for the sandeel benchmark and the panel responded that the aim is to finish by 2023.
Emerging science needs
Emerging science topics were discussed in order for ICES to address possible future advisory needs from stakeholders. The aim was to identify science areas and best ways of supporting their development. MIACO formed a list of common and agreed emerging science topics for the future, including the effect of climate drivers on fish stocks, the potential of new species and the decarbonisation of fishing vessels. Their current science plan can be found here: https://www.ices.dk/Science/Pages/Science_priorities.aspx
What messaging from ICES helps deliver Stakeholder objectives?
MIACO was invited to comment on ICES communications strategy, when considering stakeholders various objectives and specifically what elements of ICES work would benefit from further communication and promotion.
The style and communication of mixed fisheries advice changed in 2022 in order to make it more understandable for end users. These changes were highlighted to MIACO. Also MIACO was asked to note a planned workshop in 2023 on mixed fisheries, which will be targeted at the needs for managers and decision makers. There are still basic knowledge gaps on how mixed fisheries considerations are used, what is needed that is not yet provided, validity of assumptions made, or how they are communicated. The planned workshop should help to bridge some of these gaps.
Providing advice in 2023
The meeting was updated with information on the work-plan for ICES advice and relevant science initiatives in 2023. The Head of ICES Advice Department explained how the advisory workplan is scheduled based on Expert Group meeting dates. More information about the events can be found here: https://www.ices.dk/events/Pages/default.aspx
In summary It was very a positive experience for EFFOP to attend a physical meeting after the covid restrictions last year. ICES has been making its advice process more and more clear to stakeholders, and in MIACO this was absolutely the case. The open dialogue will improve interaction in the future.
Photos are courtesy of Dr. Mark Dickey-Collas
New year, new employee…On 2nd January 2023, Dr James Hinchcliffe started his new position at Marine Ingredients Denmark and European Fishmeal. James is a marine biologist who has worked with aquatic animal nutrition and biology. For the last eight years his main research has focused on the sustainability of novel feeds for Swedish aquaculture. Now he gets to see the other side, “The judicious use of our ocean resources has always been a very close thing to my heart, fishmeal is an essential resource and I’m really excited to join Marine Ingredients and contribute towards the sustainability of this sector”.