EFFOP: “No binding targets for fishmeal reduction in aquafeed”
The following feedback was given by European Fishmeal and Fish oil Producers to the European Commission regarding the initiative “Blue bioeconomy – towards a strong and sustainable EU algae sector”. You can see the initiative and the feedback here.
European Fishmeal (EFFOP) welcomes the initiative towards a strong and sustainable EU algae sector. However, we disagree with the setting of “Binding targets for substitution of fish-based fish feed” as suggested under “Option 3: Targeted activities to support the sustainable growth of the algae sector including regulatory measures”. We disagree for several reasons:
Aquaculture production is significantly increasing and provides an increasing share of the supply of fish for human consumption. To support the growing aquaculture production of marine fish, there is a need for increasing amounts of fish feed, including marine ingredients both from algae and fish.
Fishmeal and fish oil are limited ingredients used in fish feed. The latter because of increasing demands from aquaculture, the requirements for responsible and sustainably sourced raw materials, increased prices and increasing availability of alternative competing feed ingredients. Therefore, aquaculture feeds will continue to have low inclusion levels of fishmeal and fish oil. Fishmeal and fish oil will increasingly become strategic ingredients used at critical stages in the fish life and to secure optimal or specific growth performances, e.g. as ingredients in organic fish feed, where an addition of artificial amino acids is not permitted. Fish health and human health require marine ingredients (EPA and DHA) e.g. from fish oil, either by direct human consumption or via consumption of fish.
EPA and DHA are central components in all cell membranes – particularly important for the development of the brain and vision early in life. EPA and DHA contribute to the function of the heart, blood system and immune system.
Why fishmeal and fish oil are sustainable:
- Fishmeal and fish oil are produced mainly from small, short-lived fish with little or no potential for direct human consumption as well as from recycled trimmings from fish processing for human consumption.
- The major species used to produce fishmeal and fish oil in Europe are capelin, sandeel, blue whiting, sprat, Norway pout and boarfish.
- The production is always based on a sustainable exploitation of natural resources. All fish stocks used to produce fishmeal and fish oil in European countries are subject to strict catch limitations. The total allowable catches (TACs) are based on biological advice and under strict governmental regulation.
- A growing amount of raw material comes from recycled trimmings. The fillet yield for most fish species varies between 30% and 65% of the mass of the fish, and the cut-offs constitute a valuable resource for the fishmeal and fish oil producers. Europe is leading in optimizing the exploitation of these valuable marine resources.
- All members of EFFOP support and implement the FAO code of conduct for responsible fisheries.
- Aquaculture production has a low environmental footprint compared to the production of other foods e.g. beef and pork.
- Fishmeal as a protein ingredient competes openly with other protein sources. EFFOP recognizes a need for other protein sources in agriculture and aquaculture feed to meet the global food demand. Alternatives should be equally sustainable and traceable.
Business and politicians alike have in more than a decade aimed at making sustainability a critical competitive parameter for business development and sourcing. By prioritizing one protein source over the other, EFFOP fear that the competition to achieve the most sustainable ingredient, which is a crucial driver in the green transition, will be reduced. According to Maiolo et al. (2020) , e.g. dried microalgae biomass from Tetraselmis suecica, have environmental effects on global warming of 15,371 kg CO2-e per ton of feed, the climate effect of soybean meal and soybean oil from Brazil is 6,250 and 7,940 kg CO2-e per ton of feed, respectively, much higher vis-à-vis the 1,310 kg CO2-e per ton of fishmeal found by Silva et al. (2017).
With a finite supply of fishmeal and fish oil, further growth of the aquaculture feed production will have to result in an even further reduction of the inclusion of marine resources in the diets. Trimmings from aquaculture products represent a potential new source of raw material for fishmeal and fish oil manufacture, analogous to the production of processed animal proteins from the terrestrial farming sector.
In addition, new raw materials such as algae, single cell proteins, insect meal and improved traditional raw material like soy, rape, corn will be necessary, although some of these materials are yet a long way from achieving commercial volumes of supply. Also, more specific knowledge about the exact nutritional requirement for individual species will be important, as these tend to vary across the high number of fed aquaculture species. Any other ingredient used in aquafeeds should be expected to be subjected to the same level of scrutiny applied to marine-source materials. Therefore, a phasing out of fishmeal and fish oil should not be recommended. EFFOP supports measures to reduce the dependency on critical feed materials (e.g. soya grown on deforested land) by fostering alternative feed materials issued from responsible sourcing such as insects, marine feed stocks (e.g. fish and algae) and by-products from the bio-economy (e.g. fish waste).
 Maiolo, S., Parisi, G., Biondi, N. et al. Fishmeal partial substitution within aquafeed formulations: life cycle assessment of four alternative protein sources. Int J Life Cycle Assess 25, 1455–1471 (2020). https://doi.org/10.1007/s11367-020-01759-z
 Silva, C.B., Valente, L.M.P., Matos, E. et al. Life cycle assessment of aquafeed ingredients. Int J Life Cycle Assess 23, 995–1017 (2018). https://doi.org/10.1007/s11367-017-1414-8