EFFOP comments to Marin Trust V3 proposed clauses for by-products
Marin Trust is in the process of developing a version 3 of their Standard and on Thursday 20th January 2022 held a Workshop to present and discuss the proposed clauses for by-products.
EFFOP participated in the workshop and coordinated the views of EFFOP members towards the proposed changes to the Marin Trust certification for by-products.
The EFFOP feedback to Marin Trust was along these lines:
- It is vital that MarinTrust Version 3 remains relevant, robust, and fit for purpose.
- The MarinTrust system must be effective and create as little workload as possible for all involved in the certification process.
- By-products are considered a sustainable raw material that should be better utilized and too many rules and requirements for traceability will result in reduced use of by-products because it becomes too complex and costly to manage small batches.
- European producers support Marin Trust and recognize the need for full transparency, traceability and responsibility in fisheries and production of fishmeal and fish oil. However, a further development of the Marin Trust standard must consider the regional diversity in fisheries and production. A one-size-fits-all is not a viable way forward as there are vast geographical differences in the regulatory environment of the fisheries and production facilities worldwide.
- It should be reflected, that for by-products the fishmeal factory is not the firsthand – but the secondhand – buyer. The firsthand buyer – and supplier of the by-products – is responsible for all registration and information about species or mix of species as well as their traceability.
- In Europe, firsthand buyers and suppliers of the by-products follow EU and national laws and regulations for traceability of buying and selling fish. The factories can document and trace the by-products one step back – to the information received in the sales document from the supplier. The supplier is responsible for traceability and has information about origin of the fish by-product.
- By law we do not have any IUU-fishery in any European countries.
- The European fishmeal industry supports the circular economy. The use of trimmings for fish meal are considered to be sustainable. All customers, including the salmon business, backs this approach. This is also supported by the ASC-standard.