EFFOP contributes to Joint-AC Advice on valorisation of fisheries and aquaculture byproducts

The Joint-AC Advice on valorisation of fisheries and aquaculture by-products has just been sent to the European Commission and Member States.

You can read the report here

As the global demand for sustainable practices continues to rise, EFFOP, as part of its work with within the developments at EU level has contributed to the recently released Joint-AC Advice on Valorisation of Fisheries and Aquaculture By-products. The document aims to provide critical insights on overcoming regulatory challenges and unlocking the potential of by-products from the fisheries and aquaculture sectors.

A Circular Economy for Fisheries and Aquaculture

The Joint-AC Advice was initiated following the BlueBio event hosted at the European Parliament in January 2024, aiming to identify new ways of transforming the fisheries and aquaculture sectors into sustainable and circular industries. The report highlights several case studies and projects that explore valorising waste from these industries and presents recommendations for policymakers on how to streamline regulations to facilitate this transition.

For EFFOP, valorisation is essential to achieving circularity in the blue economy. Today, around 40% of the raw materials used in fishmeal and fish oil production come from recycled trimmings. This not only reduces waste but also contributes to creating high-value products from what was previously considered a waste stream.

Facilitating the circularity of aquafeed: the case for fish sludge

Fish sludge, consisting of faeces and undigested feed from farmed fish, is a nutrient-rich by-product collected from on-land aquaculture systems. In some countries, like Norway, it is successfully used as fertiliser. However, within the European Union, its use faces significant regulatory hurdles.

Under the EU Fertilising Products Regulation (EU No. 2019/1009), fish sludge is not listed as a permissible material, preventing its use as fertiliser. Additionally, the Animal By-product Regulation (EU No. 1069/2009) does not classify fish excreta as manure, further complicating its recycling for agricultural use. These regulations create barriers for fish producers, who must navigate between national rules, the EU framework, or opt for mutual recognition under Regulation (EU) No. 2019/515.

The key challenges in recycling fish sludge include concerns over food-chain and environmental safety, particularly with regard to controlling heavy metals and organic pollutants. Proper hygiene standards and processing methods are also critical to prevent the spread of infectious agents.

To be viable as fertiliser, fish sludge must have suitable physical properties such as good storage, low odour, and balanced nutrient content to meet agricultural needs. Another potential use is as feed for insect farming, but this route is currently excluded due to concerns over pathogen transmission, as EU regulations classify insects as farmed animals, and feeding them fish sludge is prohibited.

To ensure the safe use of fish sludge as fertiliser or feed, regulations must be updated to reflect new scientific knowledge, risk assessments by EFSA, and political support for legislative change.

Circularity of fisheries side streams and waste

Fishmeal and fish oil production is a vital part of the circular economy, especially with the growing use of trimmings from fish processing. However, when it comes to human consumption, significant regulatory challenges arise. To produce fish oil for human consumption, the industry must adhere to stringent food safety regulations. This requires processing food-grade raw materials in food-grade facilities, which presents difficulties for European factories as they processed animal by-products.

The problem lies in the fact that a production line approved for food production is prohibited from processing raw materials that are not eligible for human consumption, even with an appropriate cleaning of the equipment, according to EU regulations. In addition, certain fish trimmings and cut-offs, which are safe to consume, are downgraded to by-products. Once a product is deemed an animal by-product, it cannot be upgraded for human consumption. This limits the industry’s ability to make full use of valuable resources.

Despite the importance of maintaining strict hygiene standards, there is a clear need for regulatory flexibility. Especially as the fish oil production process includes a number of steps that considerably reduce sanitary risks ( boiling, heating to very high temperatures and even refining). With appropriate measures in place, the industry could safely process more fish oil and other products for human consumption, ensuring that valuable marine resources are used to their fullest potential while contributing to a more sustainable food system.

Recommendations for the Future

The Aquaculture Advisory Council (AAC), Market Advisory Council (MAC), North Sea Advisory Council (NSAC), and CCRUP, provides several recommendations to the European Commission, including:

• • Foresight and Anticipation: The European Commission should adopt a forward-looking approach to ensure EU policy and regulation remain adaptable to societal and technological developments, while maintaining high safety and consumer confidence standards.
  • Scientific Support for Legislative Changes: Sound scientific advice, especially from bodies like EFSA, is crucial for revising current regulations to reflect new knowledge and practices.
  • Clarity on Organic Fertiliser Standards: The Commission should establish clear guidelines for acceptable additives and processing methods in organic farming, supporting the growth of organic aquaculture as part of the Farm to Fork Strategy.
  • Maximizing Aquatic Resources: Developing operational frameworks for EU producers to optimize the use of aquatic resources for food and feed, while revisiting the 2009 Animal By-Product Regulation to classify fish excreta as manure, would align with circular economy goals without compromising safety.
  • Collaboration for Innovation: Stronger collaboration between policymakers, researchers, and industry stakeholders is essential for developing effective strategies to support the transition to a sustainable blue economy.
  • Flexible Approaches to Regulatory Obstacles: In some cases, solutions may be found outside of legislative changes. The Commission should explore alternative options to address regulatory challenges on a case-by-case basis.
  • Harmonised Feed Regulations: Harmonising feed regulations across EU member states is essential to streamline market entry and foster competitiveness within the aquaculture and fisheries sectors

A Sustainable Path Forward

The Joint-AC Advice signals a crucial step towards establishing a fully circular blue economy, where waste is no longer a challenge but a resource. As an important  participant in this transformation, EFFOP will continue to have a role in demonstrating how fisheries and aquaculture can adopt more sustainable, circular practices and we remain committed to working closely with the European Commission and other stakeholders to refine the regulatory landscape and enable the valorisation of fisheries and aquaculture by-products.

Read about EFFOP’s participation in the European Parliament here.