23rd June 2021
Dear Dr Kiene and Mr Howes
On the Hook campaign renewing call for a full independent review of the Marine Stewardship Council
We are writing as members of the On The Hook campaign to renew our earlier calls for a full independent review of the Marine Stewardship Council’s standards and operations.
We believe that the intended purpose for which the MSC was established remains of fundamental importance: it is as clear today as ever that increased adoption of sustainable fishing practices requires market drivers to complement governmental and intergovernmental regulation. It is therefore in the interest of all of us who wish to see a better future for the ocean that the MSC functions effectively.
While many fisheries certified by MSC do represent genuinely sustainable options, still too many do not. Over the years, MSC has attracted growing criticism, as well as several formal objections, for its certification of destructive fisheries, including but not limited to deep-sea bottom-trawling fisheries, fisheries deliberately targeting marine mammals, and fisheries with high levels of bycatch.
That raises fundamental questions as to whether the bar for certification is set high enough for the MSC ecolabel to serve its purpose of both identifying and subsequently incentivising improved sustainability practices on the water. Our experiences suggest not in its current form.
As you are aware, On the Hook was formed in August 2017 to call for MSC reform in light of its decision at the time to recertify the Parties to the Nauru Agreement (PNA) tuna fishery. The compartmentalised nature of this fishery meant that unsustainable fishing practices continued alongside certified activity. We were also deeply concerned by the incidences of shark finning in that fishery and the lack of up-to-date finning data available at the point of certification.
It is now almost four years later. While we welcomed last year’s ban on compartmentalisation as a commendable effort by MSC to close an obvious loophole in its certification process, we are now seeing previously compartmentalised fisheries rush to include their FAD sets within their certificates. We have still heard little from MSC as to what such fisheries must do to demonstrate the sustainability of these sets which until recently were deemed inappropriate for certification. 2
On shark finning, MSC’s inclusion of this serious issue within the ongoing Fisheries Standard Review is welcomed but the apparent inclination to allow fisheries to propose alternatives to Fins Naturally Attached appears to be simply a rebranded continuation of the status quo.
Furthermore, across both of these issues, our experience has been that the opportunity for genuine stakeholder engagement and input has been too limited. And in the meantime, many more fisheries of questionable sustainability have continued to be certified.
While policy changes such as the ban on compartmentalisation do represent some progress, and it is certainly not time to give up on the MSC model entirely, quite simply the MSC’s operation is too slow to keep up with the pace of change on the ocean. Given the speed at which the climate and biodiversity crises are unfolding, MSC cannot continue to take one incremental step forward followed by several steps back. Many stakeholders devote considerable capacity towards engaging constructively with individual issues and certifications. However, as these continue to arise, it is increasingly clear that there are systematic issues underlying these which need to be addressed in order to make genuine progress.
In examining just a limited number of predetermined issues relating to the Standard (rather than procedure and/or application), with short windows for public consultation, and little visibility or transparency on the decision-making process, it is clear that the ongoing Fisheries Standard Review is not going to be the forum through which these overarching issues are resolved.
In that context, we are today relaunching our campaign to make a renewed call on MSC to undertake a full independent review of its Standard and operations, commissioned from outside the organisation, which would enable all stakeholders to raise all concerns in an open and transparent manner and for these to be systematically examined and addressed.
To reiterate, although the MSC is not currently functioning effectively to serve its intended purpose, the reason we continue to engage on this issue is that we remain entirely convinced that it has an essential role to play.
Our objective is MSC reform, not its failure, and our intention has never been to damage MSC’s public credibility. However, it is an unavoidable reality that recent events have already done that. It would therefore be in the MSC’s interest to address existing concerns proactively and openly and deliver the reset which is required. Our intention is to provide clear solutions as to how this could be achieved and we sincerely hope that this effort is received in the constructive manner that it is intended. We will keep you updated on campaign activities and would welcome any opportunity to discuss further. 3
Yours sincerely,
- Blue Marine Foundation
- David Suzuki Foundation
- Environmental Justice Foundation
- FairFish International
- Fish4Ever
- Island Conservation Society
- World Wise Foods
- Professor Callum Roberts
- Professor Jennifer Jacquet
- John McNally MP
