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Aquatic Life Institute

ALI France

L'association a pour objet de faire émerger la question de la souffrance des animaux aquatiques exploités pour notre alimentation.

Lobbying Activity

Response to An EU strategy for fisheries external action

23 Jul 2025

We welcome the development of a strategic approach to the EUs external action in fisheries and appreciate the opportunity to contribute. We urge the European Commission to ensure that this initiative aligns with the EUs environmental values, legal obligations under Article 13 TFEU, and global leadership on sustainability and ocean diplomacy. In particular, we call for the inclusion of animal welfare, climate justice, and equity principles in the external fisheries framework. 1. Align External Policy with Internal Standards and Legal Obligations: The EU must not support, permit, or finance fishing practices abroad that would be unlawful within the EU, such as live finning, destructive gear, or inhumane handling and slaughter of aquatic animals. As EFSA and recent Commission strategies have affirmed the sentience of fish and cephalopods, the EU should ensure external policy reflects this recognition. Animal welfare must be addressed in Sustainable Fisheries Partnership Agreements (SFPAs), trade negotiations, and aid-funded development programs. 2. Safeguard Equity and Ocean Justice: A strategic external fisheries policy must prioritize support for small-scale fishers and coastal communities, especially in the Global South, over industrial distant-water fleets that often undermine local food security, governance, and marine ecosystems. This includes meaningful inclusion of Indigenous and artisanal fishers in policy design, consultation processes, and benefit-sharing mechanisms. Fair and just transitions must be core to the EUs external partnerships. 3. Eliminate Harmful Subsidies and Incoherent Aid: The EU should actively work to eliminate subsidies, financing, or trade incentives that lead to overfishing, bycatch, or animal suffering in third-country waters. Public funding must not exacerbate environmental degradation or support intensive fishing models at odds with sustainability or welfare objectives. This includes re-evaluating support for fleet expansion, infrastructure, and fisheries-related research when it risks undermining conservation or welfare goals. 4. Embed Aquatic Animal Welfare in Ocean Diplomacy: As the EU strengthens its ocean diplomacy, animal welfare must be integrated into broader sustainability discussions. Aquatic animals are central to ocean health, ecosystem resilience, and food systems. Recognizing their sentience and including welfare standards in fisheries negotiations enhances coherence with the Green Deal, Farm to Fork Strategy, and international commitments on biodiversity, animal health, and climate. 5. Improve Transparency and Traceability of Imports: The EUs external fisheries strategy should prioritize strong transparency and traceability mechanisms to ensure that imported seafood meets EU-equivalent environmental and welfare standards. Supply chain due diligence must cover welfare risks, bycatch levels, illegal fishing, and human rights violations. 6. Support Global Governance Reforms: The EU should actively promote reforms in global and regional fisheries governance bodies, including Regional Fisheries Management Organizations (RFMOs), to advance science-based catch limits, welfare safeguards, and non-lethal mitigation measures for incidental capture. It should also support the creation of international guidelines or minimum standards for fish welfare in wild-capture operations. In conclusion, we urge the Commission to integrate animal welfare and equity considerations into all aspects of the external fisheries strategy. Doing so will not only enhance the EUs credibility in global ocean governance but will also ensure a more ethical, sustainable, and resilient future for marine ecosystems and the communities that depend on them.
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Response to Roadmap towards Nature Credits

15 Jul 2025

Aquatic Life Institute (ALI) welcomes the European Commissions initiative to explore nature credits as part of a broader strategy to address biodiversity loss. We appreciate the recognition that marine and freshwater ecosystems are crucial to Europe's ecological and economic resilience. However, we note several important gaps and risks that must be addressed to ensure that nature credit markets are not only effective but also equitable, ethical, and ecologically sound. 1. Safeguarding Animal Welfare in Aquatic Systems: While the roadmap highlights ecosystem services and biodiversity outcomes, it fails to consider the welfare of sentient aquatic animalsboth farmed and wild. Any mechanism that incentivizes practices in marine or freshwater ecosystems must include safeguards to prevent harm to aquatic animals. Without explicit mention of animal welfare, there is a risk that practices harmful to fish, cephalopods, and other species may be certified as "nature-positive" based on narrow biodiversity or carbon criteria. We urge the Commission to ensure that certification methodologies incorporate sentience and welfare standards, particularly where restoration or farming interventions involve live animals. 2. Addressing the Complexity of Aquatic Ecosystems: Aquatic systems differ significantly from terrestrial ecosystems in their complexity, visibility, and measurability. Many marine habitats (e.g. the deep sea, coral reefs, and pelagic zones) are difficult to monitor and are already under pressure from overexploitation. The roadmap must account for these differences and develop metrics, verification tools, and crediting systems specifically suited to aquatic environments. Failure to do so could result in credit schemes that are biased toward more easily quantifiable terrestrial interventions, thereby marginalizing critical marine restoration needs. 3. Mitigating the Risk of Greenwashing in Aquaculture and Blue Economy Projects: The roadmap refers to blended finance models and the expansion of sectors such as aquaculture and seaweed farming. While these may present opportunities, they also carry well-documented risks related to pollution, invasive species, and poor animal welfare. We caution against the inclusion of intensive aquaculture systems (such as salmon farming or poorly regulated bivalve production) within nature credit schemes without rigorous evaluation. Certification standards must guard against the use of credits to justify the expansion of extractive or industrialized marine activities under a nature-positive label. 4. Inclusive and Transparent Governance: We support the proposal to establish an EU expert group on nature credits and encourage the Commission to include representatives from aquatic animal welfare organizations, not only environmental or commercial stakeholders. The inclusion of voices advocating for the protection of sentient aquatic life is critical to developing a system that reflects both ecological and ethical values. 5. Prioritizing Non-Market Mechanisms and Equity: While private finance can complement public funding, it must not lead to the commodification of nature in ways that prioritize profit over protection. The Commission should remain cautious of overrelying on market-based tools and should ensure that equity, transparency, and public interest guide all developments. This includes recognizing the rights and roles of small-scale fishers and coastal communities in stewardship efforts and ensuring they are not excluded from credit benefits due to high administrative barriers. In conclusion, we urge the Commission to integrate animal welfare considerations explicitly, tailor methodologies to aquatic systems, and ensure transparency and accountability in any emerging nature credit frameworks. Nature credit markets must complementnot undermineexisting conservation, climate, and animal protection efforts.
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Response to Modernisation of the EU legislation for on-farm animal welfare for certain animals

23 Jun 2025

Aquatic Life Institute welcomes the European Commissions initiative to modernise EU animal welfare legislation and align it with the latest scientific knowledge, societal expectations, and international standards. However, we are deeply concerned that farmed aquatic animals are not currently included in the scope of this legislative reform. We urge the Commission to ensure that the revised on-farm animal welfare rules explicitly cover aquatic animals, including fishes, cephalopods, and decapod crustaceans. Scientific consensus has confirmed that many aquatic species are sentient, capable of experiencing pain, fear, and distress. The European Food Safety Authority (EFSA) has issued multiple scientific opinions on the welfare of farmed fishes and crustaceans, and cephalopods are already recognised as sentient in Directive 2010/63/EU. Yet, aquatic animals remain almost entirely unprotected under current EU on-farm welfare law, despite representing the largest group of farmed animals in Europe by number. The omission of aquatic animals is increasingly at odds with the EUs stated values, including the recognition of animal sentience under Article 13 of the Treaty on the Functioning of the European Union (TFEU), and the EUs international commitments under the One Health and One Welfare approaches. Moreover, consumer concern about fish welfare is rising, and regulatory inconsistency undermines the credibility of the EUs food production standards. The modernisation of animal welfare legislation presents a vital opportunity to address this legal gap. We urge the Commission to: - Include clear, species-specific welfare provisions for aquatic animals, particularly regarding water quality, stocking density, handling, feeding, transport, and slaughter; - Ensure that imported aquatic products are held to equivalent animal welfare standards, in line with the Farm to Fork Strategy and WTO-compatible approaches; - Develop mandatory welfare training for aquaculture workers and producers; - Establish a transition timeline to phase out the most harmful farming practices for aquatic animals, including chronic overcrowding, high mortality systems, and inhumane slaughter methods; - Ensure adequate monitoring, enforcement, and data transparency mechanisms, including species-disaggregated welfare indicators. Failing to act now risks entrenching practices that are incompatible with EU values and scientific understanding. The lack of legal protections for aquatic animals in farming systems undermines the credibility, coherence, and fairness of the EUs animal welfare framework. We call on the Commission to ensure that this revision finally brings aquatic animals into the fold of meaningful legal protection, in line with public expectations and scientific reality.
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Response to Evaluation of the Public Procurement Directives

13 Feb 2025

Aquatic Life Institute (ALI) welcomes the opportunity to contribute to the evaluation of the Public Procurement Directives. As an organization committed to improving the welfare of aquatic animals and promoting sustainability in food systems, we recognize the significant role that public procurement plays in shaping market demand and influencing industry practices. However, the current framework does not adequately support environmentally and socially responsible procurement, as long as sustainability criteria remain voluntary while price remains a mandatory factor in decision-making. Public procurement has the potential to drive higher standards for sustainability and animal welfare in food systems, yet the current Directives fail to provide a strong regulatory foundation to achieve this. While environmental and social considerations can be included in procurement decisions, they remain optional, whereas the price criterion is compulsory. This creates an imbalance that prioritizes cost over sustainability, often leading to the procurement of goods and services that contribute to environmental degradation, poor animal welfare, and resource depletion. The evaluation of Directives 2014/23/EU, 2014/24/EU, and 2014/25/EU must address this fundamental gap by ensuring that sustainability criteria are not treated as secondary or discretionary but instead embedded as core requirements in procurement decisions. Without this shift, public funds will continue to be allocated to products and services that undermine the EUs commitments under the Green Deal, the Farm to Fork Strategy, and biodiversity protection goals. In the case of food procurement, including seafood and aquaculture products, this lack of prioritization for sustainability is particularly problematic. Without mandatory sustainability requirements, public institutions risk sourcing from production systems that contribute to habitat destruction, excessive resource use, and poor aquatic animal welfare. To address this, the Directives should require sustainability and social responsibility criteria to be weighted significantly in procurement decisions, ensuring that price alone does not dictate outcomes. Transparency and traceability are also essential to meaningful procurement reform. While existing Directives promote fair competition and non-discrimination, they do not sufficiently address supply chain opacity, particularly in seafood sourcing, where unsustainable practices and poor welfare conditions are often hidden. Strengthening transparency measures through due diligence and verification mechanisms will ensure that publicly funded purchases align with the EUs broader environmental and social objectives. ALI urges the European Commission to use this evaluation as an opportunity to shift public procurement rules away from a price-dominated model and towards a framework that actively supports sustainability. As long as environmental and social sustainability remain voluntary while price remains mandatory, public procurement will continue to fall short of its potential to drive positive change. We encourage the Commission to ensure that procurement policies align with the EUs commitments to sustainability, ethical sourcing, and long-term resilience.
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Response to European Water Resilience Strategy

13 Feb 2025

Aquatic Life Institute (ALI) welcomes the opportunity to provide input on the European Water Resilience Strategy. Ensuring Europes water resilience requires a holistic approach that not only addresses water scarcity and pollution but also integrates considerations for aquatic ecosystems and the welfare of aquatic animals. The role of aquatic food production, including aquaculture and fisheries, must be explicitly acknowledged in this strategy, as these industries have significant implications for water quality, ecosystem stability, and the broader sustainability of aquatic environments. Aquaculture, as the fastest-growing food sector globally, has a profound impact on freshwater and marine ecosystems. Many production methods contribute to nutrient runoff, habitat degradation, and excessive water use, exacerbating environmental pressures. A truly resilient water strategy must include stricter water quality regulations for aquaculture, ensuring that effluent discharge is controlled and that environmental thresholds are respected. The strategy should also establish stronger protections against water-intensive and polluting aquaculture practices that undermine ecosystem resilience and biodiversity. Prioritizing low-impact aquatic food production systems that align with ecosystem health is essential for achieving water resilience while reducing harm to aquatic animals. The welfare of aquatic animals must be explicitly considered in water management policies, as poor water quality and scarcity directly affect their health and survival. The European Water Resilience Strategy should integrate species-specific welfare indicators into regulatory frameworks, ensuring that water quality standards include parameters relevant to aquatic animal well-being, such as oxygen levels, ammonia, and nitrate concentrations. Policies should also prevent practices that degrade water conditions and contribute to stress, disease, and mortality in farmed and wild aquatic animals. Without these considerations, water resilience efforts will fail to address key drivers of ecosystem decline. Wild-capture fisheries also play a crucial role in Europes water systems, and their impact on water resilience must be reflected in the strategy. Overfishing, destructive fishing methods, and habitat degradation all contribute to water system instability. Strengthening fisheries governance, aligning quotas with ecosystem carrying capacities, and promoting the restoration of critical aquatic habitats should be prioritized. The strategy must also enhance transboundary water cooperation to ensure sustainable fisheries management and prevent further degradation of shared water resources. A circular approach to water use should extend to aquatic food systems, with policies aimed at reducing waste and improving water stewardship in aquaculture and seafood processing. Water resilience planning should also consider the increasing impact of climate change on aquatic food production, including rising temperatures, ocean acidification, and extreme weather events that contribute to water stress. Strengthening climate adaptation measures for aquatic food systems, such as early warning systems for harmful algal blooms and low-oxygen events, will be critical to ensuring water security and ecosystem stability. ALI urges the European Commission to incorporate these recommendations into the European Water Resilience Strategy to ensure a truly comprehensive and forward-thinking approach. Water resilience cannot be achieved without addressing the sustainability and welfare challenges associated with aquatic food systems, and we look forward to supporting efforts to build a more sustainable and water-secure future.
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Response to The European Oceans Pact

3 Feb 2025

On behalf of Aquatic Life Institute (ALI), I am writing to advocate for the integration of aquatic animal welfare into the European Oceans Pact. ALI is dedicated to improving the welfare of aquatic animals raised or caught for food and promoting sustainable practices in aquaculture and fisheries globally. We welcome the European Commissions initiative to create a holistic framework for ocean-related policies and advance the EUs sustainability objectives. Aquatic animals are central to the EUs blue economy, yet their welfare is frequently overlooked. The European Oceans Pact presents an opportunity to ensure that policies addressing fisheries, aquaculture, and marine biodiversity explicitly recognize aquatic animal sentience and the importance of welfare in achieving sustainability. Improved welfare standards are not only an ethical imperative but also support the Pacts goals by: - Aligning with Global Trends: Over 90% of European citizens believe that aquatic animals deserve the same level of legal protection as farmed land animals. - Enhancing Resilience and Productivity: Stress and poor welfare in aquaculture reduce growth rates, increase disease susceptibility, and result in significant economic losses. Species-specific welfare guidelines and pre-slaughter stunning practices can mitigate these impacts. - Reducing Environmental Impact: Practices that prioritize welfare, such as appropriate water quality parameters and stocking densities, align with broader goals of reducing environmental impacts of fish farms. Prohibiting seafloor contact by fishing vessels can reduce CO2 emissions. - Strengthening Public Support: Consumers are increasingly concerned about the welfare of animals in food production. Seafood certifications are already incorporating animal welfare into its standards while seafood businesses are revising their supply chain policies to maintain public trust. As a global champion for sustainability, EU should align with these progressive efforts. The fragmentation of ocean-related policies identified in the initiative highlights the need for an integrated approach. We recommend that the European Oceans Pact explicitly link aquatic animal welfare to existing frameworks, including: - The EU Common Fisheries Policy (CFP): Incorporate welfare into sustainability assessments, including by revising the CFP to include minimum welfare standards for wild-caught and farmed aquatic animals. This would align with the 2024 European Parliament Resolution calling on the Commission to undertake research on a highly overlooked area of the CFP aquatic animal welfare and to provide guidance on this in the next CFP. - The Biodiversity Strategy for 2030: Recognize aquatic animal welfare as integral to conserving marine ecosystems and addressing biodiversity loss. - International Ocean Governance: Champion welfare in global dialogues, such as implementing species-specific protections under the UN Convention on the Law of the Sea (UNCLOS) and the BBNJ Agreement. Food systems are a significant contributor to greenhouse gas emissions, and aquatic food systems present unique opportunities to reduce these impacts. The Pact should promote: - Sustainable Aquaculture Practices: Support the development of plant-based and alternative feed sources to reduce reliance on wild fish populations, mitigating overfishing and the Jevons paradox. - Methane Mitigation in Aquaculture: Prioritize research and innovation to address methane emissions in closed production systems, aligning with the EUs climate neutrality goals. The European Oceans Pact is a timely initiative to ensure sustainable, inclusive governance and we encourage the European Commission to engage stakeholders from diverse sectors, including animal welfare organizations, in shaping the Pact. By integrating aquatic animal welfare into the Pact, the EU can demonstrate global leadership in ocean sustainability, biodiversity protection, and ethical food production.
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Response to Evaluation of the Common Fisheries Policy

6 Aug 2024

1) Effectiveness in Meeting Objectives While the CFP aims for sustainable fishing and aquaculture, it lacks comprehensive animal welfare provisions for aquatic species, as outlined in Clause 16. The CFP must address this gap by enforcing welfare standards in aquaculture, including guidelines on living conditions, humane handling, and slaughter methods. Enhancing welfare can reduce stress, improve growth rates, and boost product quality, benefiting both producers and consumers. Furthermore, the CFP should support worker training and innovation in welfare practices, leading to higher productivity, reduced reliance on antibiotics, and lower environmental impacts. The integration of species-specific welfare research and innovation into the CFP is essential for maintaining the EUs leadership in sustainable aquaculture. In capture fisheries, the CFP must also prioritize welfare during capture, handling, and slaughter, affecting trillions of fish annually. Improvements could include the use of biodegradable materials, better bycatch management, and humane stunning technologies. Additionally, the CFP should shift from industrial-scale fishing to support small-scale, more sustainable practices that are less harmful to marine life. 2) Cost-Effectiveness and Proportionality The CFP has room for improvement in balancing costs and benefits. By integrating animal welfare into fisheries and aquaculture, the CFP can enhance cost-effectiveness through better fish health, reduced mortality, and higher product quality. Investing in welfare technologies can lower long-term costs, particularly by reducing bycatch and gear damage. Redirecting subsidies from industrial to small-scale fisheries will further promote economic sustainability. 3) Relevance to Current and Emerging Needs The CFP must respond to the growing demand for animal welfare in fisheries, as emphasized in the European Parliaments 2024 resolution and supported by 79% of European citizens. Current scientific recommendations from the European Food Safety Authority (EFSA) should be integrated into the CFP, particularly for farmed species like Atlantic salmon and rainbow trout. For capture fisheries, welfare improvements must consider species-specific needs, with economic and social support for fishers. Funding should prioritize gear innovation, welfare improvements, and socio-economic benefits like price premiums and better fisher livelihoods. The CFP should also strive for coherence across EU member states and with third countries, promoting fair and consistent implementation of welfare standards. 4) Coherence with Other EU Actions The CFPs internal and external coherence with EU actions can be strengthened by aligning with broader environmental goals and incorporating animal welfare standards. The newly established EU Fish Welfare Reference Center can play a critical role in this alignment by providing expertise and supporting the integration of welfare into CFP regulations. Harmonizing CFP standards with international agreements will ensure that EU policies are consistent and reinforce global welfare standards. 5) Value Added by the CFP The CFP can add significant value by adopting stronger animal welfare measures, setting a global example in sustainable fishing and aquaculture. Key actions include investing in bycatch reduction devices, biodegradable nets, and humane killing methods. These measures will not only improve product quality and worker safety but also enhance the EUs leadership in global fisheries management. Promoting certification programs and international cooperation will further ensure that EU standards are met globally, encouraging a shift toward more humane and sustainable practices.
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Response to Sustainable fishing in the EU: state of play and orientations for 2025

22 Jul 2024

As a representative of Aquatic Life Institute, an NGO dedicated to aquatic animal welfare, I am pleased to provide feedback on the implementation of the Common Fisheries Policy (CFP). The progress towards achieving sustainable fisheries within the EU is commendable, particularly the reduction in the number of overfished stocks and the movement towards Maximum Sustainable Yield (MSY). However, sustainability must go hand in hand with animal welfare. It is essential to incorporate welfare considerations into the sustainability framework to ensure that fishing practices do not result in the suffering of marine animals. The pursuit of MSY should include strategies that minimize bycatch and ensure humane handling of all aquatic animals. The state of fish stocks is a critical concern for both sustainability and animal welfare. Accurate and comprehensive scientific monitoring is crucial to assess the health of fish stocks and implement evidence-based management practices. It is also imperative to consider the impact of climate change on marine ecosystems. Changes in species distribution, ocean warming, acidification, and deoxygenation are affecting the productivity and health of fish stocks. Adaptive management strategies that account for these changes are necessary to protect aquatic animal populations. The implementation of the landing obligation is a key element of the CFP, aimed at reducing discards and promoting selective fishing. However, the effectiveness of this measure depends on robust compliance and monitoring. Traditional monitoring techniques such as inspections at sea and aerial surveillance are insufficient. We strongly support the use of remote electronic monitoring (REM) systems, including closed-circuit television cameras, to ensure compliance with the landing obligation. This technology will help verify that discards are minimized and that all catches are accurately recorded, which is essential for stock assessments and sustainable management. Balancing fleet capacity with fishing opportunities is another significant aspect of the CFP. Overcapacity leads to overfishing, which depletes fish stocks and results in higher bycatch and greater harm to non-target species. It is crucial to manage fleet capacity effectively and ensure that fishing efforts are aligned with sustainable levels. This can be achieved through targeted action plans and by supporting fishers in adopting more sustainable and animal-friendly practices. Initiatives that promote the transition to sustainable fishing methods and provide economic incentives for fishers who prioritize animal welfare are essential. Looking ahead to the fishing opportunities for 2025, it is vital to engage with a diverse range of stakeholders, including those focused on animal welfare. The setting of quotas and fishing limits should be based on the best available scientific advice and take a precautionary approach, particularly for stocks that are overfished or vulnerable. By doing so, we can ensure the recovery and long-term sustainability of fish populations. The socio-economic performance of the EU fishing fleet is closely linked to the sustainability of fish stocks. Fleets that rely on overfished stocks or use energy-intensive fishing gear face challenging conditions. Conversely, fleets that fish sustainably and improve their energy efficiency tend to perform better economically and generate higher salaries for their crews. This demonstrates the socio-economic benefits of sustainable fisheries management. The CFP must continue to evolve, integrating sustainability with animal welfare considerations to ensure the long-term health and resilience of our marine environments. Aquatic Life Institute is committed to supporting these efforts and advocating for the highest standards of aquatic animal welfare within the CFP framework.
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Response to Protection of animals during transport

25 Mar 2024

We commend the EU's initiative to enhance the welfare of animals during transport. Recognizing the proposal's comprehensive approach towards improving conditions for terrestrial animals, we urge the inclusion of specific measures tailored to the unique needs of aquatic species. The proposal's emphasis on reducing journey times, improving conditions during transport, and the push towards digitalization for better enforcement are commendable steps forward. However, the welfare of aquatic animals during transport remains an area requiring further attention and inclusion in the EU's regulatory framework. Implementing scientific evidence-based guidelines for the handling, transport, and care of aquatic species will significantly contribute to their welfare. It is crucial to emphasize the significant stress responses induced in aquatic animals from collection through to stocking as the risks associated with poor conditions, such as overcrowding and inadequate water quality, are heightened in aquatic transport due to the circulation of low-volume water, making live transport fundamentally risky. To mitigate these risks, Aquatic Life Institue recommends the following interventions: - Align all actions with WOAH standards on fish transportation, emphasizing minimal handling of fish, requiring sedation for any handling lasting over fifteen seconds, and advocating for the construction of new facilities with on-site slaughter capabilities or access to mobile slaughter facilities to minimize live transport. - Ensure water quality parameters (e.g., oxygen, carbon dioxide, ammonia levels, pH, temperature, salinity) are species-appropriate and rigorously monitored, with contingency plans like bottled oxygen ready in case of lapses. - Implement thorough documentation practices for each consignment, including detailed transport logs that are readily accessible and centrally published. - Minimize temperature changes during transport to avoid unnecessary metabolic rate adjustments in fish. Adhere to appropriate stocking densities during transport, defaulting to standard holding densities in the absence of transport-specific guidelines. Moreover, as Aquatic Life Institute advocates for global animal welfare standards, we support the proposal's intent to ensure that animals exported outside the EU receive equivalent protection. Aquatic Life Institute is eager to collaborate with the EU, offering expertise and support to enhance welfare standards for all animals, particularly those often overlooked in transport regulations.
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Response to Evaluation of Council Regulation (EC) No 734/2008 on the protection of vulnerable marine ecosystems

30 Jan 2024

We, Aquatic Life Institute, express our concern and unwavering commitment to the preservation of vulnerable marine ecosystems (VMEs) in the high seas, urging the imposition of an outright ban on bottom trawling activities. Our organization firmly believes that the current state of evidence unequivocally demonstrates the severe, irreparable damage inflicted upon deep corals and fragile benthic habitats through bottom trawling. The deleterious consequences of bottom trawling extend beyond the immediate impact on marine habitats, encompassing major threats to bycatch and contributing significantly to climate change. Disturbingly, commercial bottom trawling and pelagic trawling account for an alarming 60% of global discards, with European waters shouldering an egregious 93.2% burden. This practice not only jeopardizes the resilience of marine ecosystems but also compromises the ocean's capacity to sequester carbon. Furthermore, the ecological toll is exacerbated by the astronomical CO2 emissions associated with trawling, ranking as the highest compared to other fishing methods. With average emissions of 4.65kg CO2 per kg landed and peaks reaching up to 46.71kg of CO2, bottom trawling stands as the third-highest contributor of CO2 per kg of protein, trailing only behind beef and Norwegian-farmed salmon. While recognizing variations in the impact of different bottom trawling activities, we emphasize the imperative to uniformly protect Vulnerable Marine Ecosystems, regardless of jurisdiction. The commendable steps taken within EU waters, such as the implementation of the EU Deep Sea Access Regulation, must serve as a benchmark for stringent measures to be applied globally. In light of insufficient enforcement and limited observer coverage in the High Seas, it is imperative to fortify existing regulations, notably Council Regulation 734/2008. Despite its current application in the South West Atlantic, where a lack of established Regional Fisheries Management Organizations (RFMOs) prevails, the economic implications of a restricted number of vessels should not overshadow the urgency of protecting VMEs. We stress the need for comprehensive impact assessments not only on the seabed but also on associated marine species dependent on VME habitats. Conservation and management measures should encompass all bottom fishing activities in these vulnerable areas, with particular attention to bottom trawling. As the EU Action Plan mandates measures to reduce bycatch, we advocate for an extension of these measures to sensitive elasmobranch species beyond EU waters. Rigorous impact assessments on VMEs should consider physical alterations to the seabed and the welfare of bottom-dwelling species, guiding the prohibition of bottom gears in areas lacking adequate scientific assessments. Our plea to the European Commission is to adopt a precautionary and ecosystem-centric approach to unregulated high seas areas and VMEs. Specifically, we propose: Prohibition of bottom gears in areas lacking scientific assessment; Prohibition of bottom fishing in confirmed VME habitats. Moreover, we urge the transition of the EU's bottom fishing fleet towards environmentally-sound gear, with a focus on sustainability. Key improvements include: Limit trawl duration and catch size; Use non-injurious materials such as knotless netting to decrease body damage; Modify gear to eliminate contact with the seafloor, which will also improve fuel efficiency; Vacuum pump fish onboard; Incorporate humane stunning technology; Avoid areas of high elasmobranch bycatch. To address concerns about creating an unlevel playing field, we recommend incentivizing responsible fishing practices in non-RFMO-covered areas. This could be achieved through market access rewards, subsidies for retrofits, and fuel subsidies for vessels that avoid VMEs. We urge the European Commission to take decisive action in implementing and strengthening regulations to ban bottom trawling in the high seas.
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Response to Sustainable fishing in the EU: state of play and orientations for 2024

18 Jul 2023

The following comment is submitted on behalf of Aquatic Life Institute, a leading international not-for-profit organization, dedicated to improving the lives of aquatic animals exploited in the global food system. We commend the European Commission for its efforts to promote sustainable fishing practices and we welcome the opportunity to provide feedback on the EU consultation "Sustainable fishing in the EU: state of play and orientations for 2024. Traditionally, fisheries management has treated fish as stocks or natural resources to be maximally exploited for human benefit while ensuring their populations do not decline beyond the rate at which they can regenerate. However, the current pace of fishing activities has led to a distressing scenario: nearly 90% of the world's fish populations are either fully exploited, overexploited, or depleted. This alarming situation calls into question the effectiveness of our existing "sustainable fisheries management" practices. It is crucial to shift our perception and recognize aquatic animals as essential stakeholders in maintaining a thriving ocean, rather than viewing them solely as means to fulfill human needs. A healthy ocean plays a pivotal role in ensuring the sustainability of the entire Earth's ecosystem. By adopting a more balanced and holistic approach to fisheries management that respects the interconnectedness of all species and prioritizes the long-term health of our planet, we can forge a path forward. Capture fisheries often subject aquatic animals to various welfare issues, including exhaustion from trying to evade capture, injury through overcrowding in nets, and exposure to rapid changes in body temperature and atmospheric pressure, resulting in thermal shock and barometric trauma. Upon landing, they are further exposed to sunlight and air, and are then handled and processed with little regard for their welfare. In addition, wild-caught individuals typically suffer death by asphyxiation (suffocation in air) or freezing to death in ice water (known as 'ice slurry'). We would like to highlight that despite improvements in fisheries management systems, 90% of global fisheries are still fully exploited, overexploited, or depleted (FAO 2022). Current fishing practices, driven mostly by economic reasons, prioritize maximizing the efficiency (measured by 'catch per unit effort'; CPUE) of commercial fishing operations and minimizing the time spent at sea to fulfill the fishing vessel's catch quota. This approach needs to change as CPUE-based operations inflict significant stress, suffering, and mortality upon both target and non-target aquatic animals during the capture process. Marine animals play a crucial role in carbon sequestration in the ocean. The UNEP has introduced the term "fish carbon" to recognize their potential in mitigating climate change and preserving biodiversity. From whales providing necessary nutrients to phytoplankton, which absorb carbon, to fish and other marine animals depositing stored carbon in fecal pellets on the ocean floor, animals play a significant role in maintaining the ocean's capacity as a carbon sink. We urge the adoption of an animal welfare-based approach (WBA) to fisheries management policies and practices. A WBA considers the welfare of both target animals and other animals indirectly affected by fishing activities, such as bycatch and ghost fishing. Fisheries cannot be truly sustainable unless the welfare of aquatic animals is taken into consideration. Instead of maintaining business as usual, we should invest in resources to shift away from intensive industrial-scale fishing (and aquaculture), while mandating humane fishing practices for the companies that remain in the industry. As we approach 2024, it is imperative to continue working relentlessly towards sustainable and humane fisheries and the welfare of aquatic animals.
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Response to 2040 Climate Target Plan

22 Jun 2023

Aquatic Life Institute (ALI), an NGO focused on improving the lives of aquatic animals in aquaculture and capture fisheries worldwide, appreciates the chance to contribute to the European Commission's consultation on the 2040 climate target. We emphasize the importance of considering aquaculture and fisheries as integral components of a sustainable food systems transition to effectively address climate change. By addressing these sectors, we align with the FAO's mandate to eliminate hunger, promote sustainable agriculture, and ensure food security. Despite being overlooked in discussions on food, agriculture, and climate change, fishing and fish farming are crucial in climate change mitigation and adaptation. Therefore, we strongly advocate for their inclusion in the EU's 2040 climate targets. Aquaculture is often presented as a solution to meet future food demand and reduce pressure on wild fish populations. However, the reality is that each year, 100 billion fish and 400 billion shrimp are farmed, resulting in negative climate change emissions, environmental impacts, and public health risks. Moreover, many farmed fish species are carnivorous and rely on wild-caught fish for their diet, further depleting fish populations. Policymakers have failed to recognize the link between intensive animal farming and the impact on farmed fish. Sustainable aquaculture and fisheries, focused on improving animal welfare, can contribute to climate change adaptation by providing alternative sources of protein and income, particularly for communities vulnerable to climate change. In regions where traditional agricultural practices and fishing are no longer viable due to rising sea levels and increased water temperatures, aquaculture offers an alternative livelihood for affected communities. Industrial-scale fishing has depleted many coastal areas of fish populations that were previously relied upon by local fishers. Reducing fishing intensity allows local fish populations to recover and provides local communities with nutrition, food security, and income once again. When considering the 2040 climate target, policymakers must also address the issue of animal welfare for aquatic animals in both aquaculture and fisheries. We propose the following policy recommendations to improve aquatic animal welfare in support of the 2040 climate target: - Shift away from intensive aquaculture and industrial-scale fishing towards extensive aquaculture of low-trophic, non-carnivorous species and artisanal-scale fishing. - Promote seaweed aquaculture as a means of economic development and food security for coastal communities. - Encourage a shift towards plant-rich, healthy, and affordable food options, along with resilient agroecological practices that support smallholder farmers and local communities. - Secure locally-centered livelihoods in coastal fishing communities by redirecting subsidies away from industrial fishing and fish farming towards local artisanal fishing and/or multi-trophic aquaculture (such as seaweed combined with shellfish/bivalves that filter and oxygenate water). - Include aquatic animals and aquatic animal welfare considerations in all Sustainable Development Goals and agri-food policies. Sustainable aquaculture and fisheries play a critical role in mitigating and adapting to climate change as part of a holistic approach to food systems. The EU has a unique opportunity to drive transformation in the sustainable food systems transition. By incorporating sustainable aquaculture and fisheries into the 2040 climate target and food systems policies, we can effectively reduce carbon emissions, improve food security, and provide alternative livelihoods for vulnerable communities.
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Response to Practical arrangements for recording official controls on livestock vessels for animal welfare on an existing common dat

28 Nov 2022

We appreciate the many efforts of the EU to fulfill its mission to spur animal welfare and social progress in its regional member countries. We would be grateful for the opportunity to share with you some thoughts regarding aquatic animal welfare that we hope your institution may find relevant. The best available evidence clearly establishes that many commonly farmed aquatic animals, who have been excluded historically from the animal welfare discourse, have the capacity to suffer which is analogous to terrestrial animals. For this reason, the welfare of farmed aquatic animals should be given the same scrutiny and concern as that of other farmed animals, and their welfare in farm systems must be reassessed at the individual level, not just as a batch. Transport & Handling Where handling is absolutely necessary, it shall be carried out with minimum stress and disturbance for both the aquatic animals handled and any other aquatic animal present. Handling should occur for the shortest time possible, and anaesthetic must be applied if handling is expected to exceed a few seconds. In all new facilities, slaughter must occur on site to reduce transportation and handling. Where this is not possible, transport and handling prior to slaughter must be as limited as possible.
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Response to Setting the Course for a Sustainable Blue Planet -Update of the International Ocean Governance Agenda

14 Feb 2022

The European Commission - DG MARE and DG EEAS is seeking feedback on an initiative to set the course for a sustainable blue planet by way of updating the Commission’s international ocean governance agenda. This initiative seeks to safeguard ocean health and release the sustainable potential of the blue economy through the promotion and sharing of an integrated management approach at all levels in order to effectively address climate change, pollution, biodiversity loss, and other impacts from human activities, such as overexploitation of resources and illegal activities at sea. This initiative aims to achieve this by updating the Commission’s existing international ocean governance agenda, to confirm the EU as a driving force to strengthen ocean governance in relevant regional and multilateral fora and processes. ALI Europe, based in France, is a sister organization of the The Aquatic Life Institute. The Aquatic Life Institute is a U.S.-based internationally focused non-profit dedicated to improving fish welfare in both aquaculture and wild capture fisheries. ALI has grown a global coalition of over 100 animal rights and conservation non-profits and is deeply engaged in partnership with various certifiers including the ASC, MSC, and GLOBALG.A.P. Operating from effective altruism principles, ALI seeks to support and accelerate activities that positively impact aquatic life, focusing on the highest-impact welfare interventions for all aquatic animals on a global scale. In this feedback, we will discuss welfare-based interventions that work to solve many of the issues included in the scope of this consultation, particularly welfare issues that arise from industrial aquaculture and commercial fisheries. These solutions include ALI’s pillars of aquatic animal welfare, along with solutions that address issues these industries contribute to, including climate change, biodiversity loss, overfishing, and IUU fishing. We would like to thank the Commission for the opportunity to comment. We hope our feedback is insightful and we look forward to showing how data-driven and science-based animal welfare interventions can play an integral role in a comprehensive, all-Europe approach to ensure that the EU remains a leader in international ocean governance for decades to come. ___ All of the solutions offered below can be found in The Aquatic Life Institute’s “Report on the Benefits of Aquatic Animal Welfare for Sustainability” (https://drive.google.com/file/d/1LjmZ-JRMVTcxYW7RoeLdv4WqllyT2Z91/view ) and “Key Aquatic Animal Welfare Recommendations for Aquaculture.” Summary of our recommendations (details in our attached file): I. Key Aquatic Animal Welfare Interventions II. Recommendations for the Protection of Marine Ecosystems 1. Climate Change Mitigation Measures for Marine Ecosystems: 2. Fishing Gear Waste and Pollution 2. Fishing Gear Waste and Pollution:
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Response to Laying down certain animal health specific official controls

22 Dec 2021

We would like to thank the Commission for the opportunity to comment. We hope our feedback is insightful and we look forward to showing how data-driven and science-based animal welfare interventions can play an integral role in a comprehensive approach to ensuring aquatic animal health in the aquaculture sector across Europe. ALI Europe, based in France, is a sister organization of the The Aquatic Life Institute. The Aquatic Life Institute is a U.S.-based internationally focused non-profit dedicated to improving fish welfare in both aquaculture and wild capture fisheries. As referred to in the Draft Delegation, Article 2, sections (k,l), our primary concern and scope of feedback will pertain to ‘approved aquaculture establishments’ and ‘approved groups of aquaculture establishments’. It is our position that robust fish welfare measures can significantly improve and build-upon existing health control protocols by not only improving the health and welfare of fish, but mitigating many of the concerns around disease, biosecurity, and mass mortality events. It is our sincere belief that these measures make for a better product in the market and will ultimately be better for producers, fish, and consumers. Intervention Summary (more details are in our enclosed feedback): I. On Medical Treatment and Fish Health 1. Currently aquatic animals are treated as a ‘batch’, with most treatments being applied to every animal in the batch. From a welfare point of view, aquatic animals should be given individualized health plans , and given appropriate treatment as an individual when they are at risk of getting sick. 2. In order to maximize welfare and reduce the risk of population-level infection or infestation, treatments should be prioritized in this order: non-medical measures which prevent disease > allopathic treatments > metaphylactic treatments. 3. Due to the risk of antimicrobial resistance, prophylactic use of antimicrobials is only allowed where there is no alternative. Disease outbreaks must be properly managed through rapid diagnosis and treatment, and when necessary, humane slaughter. 4. All mass mortality events must be reported. This should include the number, weight and age of deceased animals; their cause of death; and all remedial measures taken to prevent further mortalities. II. Other Issues in Aquaculture that Compromise Fish Health and Welfare a. Parasites and Cleaner fish Methods used for removal of parasites, such as sea lice, must provide rigorous, scientific documentation and reduce any adverse effects on the welfare of the fish. We oppose the use of cleaner fish as a method of lice control in Atlantic salmon sea pens. b. Routine Mutilations We oppose the use of routine mutilations, such as fin-clipping in fish and the practice of 16 eyestalk ablation in crustaceans. III. Data-Driven Approach, Record Keeping and Reporting 1. Standards and practice, both on and off farm, must adapt to the best available evidence. 2. All monitoring and reporting data must be formatted with a relevant pro-forma, and centrally published no more than 30 days after being recorded. 3. Every effort must be made to ensure the traceability of aquaculture products. 4. Water quality records, transport logs, and mass mortality event records must all be made centrally publicly available, and linked to farm data. This will be used to give consumers an assurance of the quality of the aquatic animal products they are purchasing.
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Response to Policy Statement 2022

31 Aug 2021

The European Commission - DG MARE (the Commission) is seeking feedback on the implementation of the common fisheries policy “towards more sustainable fishing in the EU,” including progress in: -achieving sustainable fisheries -assessing the state of fish stocks -balancing fleet capacity and fishing opportunities. It also launches a public consultation on fixing fishing opportunities for 2022. ALI is an international nonprofit organization which pursues increased levels of protection for aquatic animals. ALI therefore welcomes this opportunity to give its feedback on the strategy “Blue bioeconomy – towards a strong and sustainable EU algae sector” (hereafter: “Algae Strategy.” It is ALI’s position that the EU’s fisheries policy should be more ambitious to achieve its objectives to decrease the pressure on fish stocks in the European seas, and to reduce by-catch in the European Seas.
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Response to Animal welfare labelling for food

24 Aug 2021

The European Commission - DG SANTE (the Commission) is seeking feedback on the Inception Impact Assessment of the European Commission in view of revising EU animal welfare legislation. Specifically, the Commission is looking for information regarding the economic, social, environmental impacts, as well as the impacts on the fundamental rights and simplification of a set of proposed modifications of current animal welfare laws. ALI is an international nonprofit organization which pursues increased levels of protection for aquatic animals. ALI therefore welcomes this opportunity to contribute to the inception impact assessment of the revision of EU animal welfare legislation, given its significant shortcomings in guaranteeing even minimal welfare of animals, but also fair competition between market operators, as well as environmental and socially sustainable aquatic animal production. Our position is the revision of the EU legislation on animal welfare, and specifically, standards on the welfare of aquatic animals (finfish and crustaceans), would positively impact the fishery and aquaculture sector; would respond to societal demand in support of a better treatment of animals; would ensure more sustainability in aquatic animal production; as well as it would contribute to safeguarding fundamental rights, including freedom of enterprise. All this, without imposing disproportionate administrative burden onto market operators. Cephalopod farming should be banned before it starts in the European Union.
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Response to Implementing rules for registration of aquaculture establishments and record keeping by operators

29 Jul 2021

ALI is an international nonprofit organization which pursues increased levels of protection for aquatic animals. ALI therefore welcomes this opportunity to give its feedback on the draft implementing regulation which provides exemptions to pet recording requirements of farmed fish, given its significant shortcomings in guaranteeing adequate levels of transparency in the sector through data collection. It is ALI’s position that the exemptions in the draft implementing regulation should be narrower in scope. The European Commission should increase the regulatory burden on the Member States so that they have an obligation to demand registration and record-keeping of certain establishments exempted in the draft implementing regulation. Please find attached the feedback from ALI.
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Response to Review of the EU school fruit, vegetables and milk scheme - EU aid

23 Jul 2021

L’association Aquatic Life Institute (ALI) remercie la Commission Européenne d’organiser cette consultation autour de l’alimentation à l’école. La construction des habitudes alimentaires passe notamment par l’école. Nous pensons que la découverte de mets culinaires avec une grande diversité de fruits et légumes est très importante pour répondre aux objectifs de l’Union Européenne en matière de dérèglement climatique. Notre association ALI est favorable à des aides de l’Union Européenne pour la consommation de fruits et de légumes à l’école. Nous préconisons le remplacement des produits laitiers par des alternatives végétales à la fois savoureuses, avec un faible bilan carbone et riches d’un point de vue nutritionnel. À titre d’exemple, le soja, les amandes ou les brocolis sont riches en calcium. Par ailleurs, nous tenons à souligner l’importance de la consommation d’algues à l’école. Cela permettrait de réduire la consommation de poissons afin de pallier la pêche massive et au développement de la pisciculture intensive dans le cadre de la politique européenne pour le climat. En effet, la stratégie « De la ferme à la fourchette » envisage de favoriser la production d'une nouvelle source de protéines : les algues. Les algues contiennent des micro-nutriments importants tels que la vitamine B9, le phosphore, le zinc, le fer… Par exemple, le kelp, la kombu et le wakame crus sont d’excellentes sources de calcium. Enfin, nous rappelons que les attentes citoyennes concernant la lutte contre souffrance animale, y compris les animaux aquatiques, sont très fortes. Nous encourageons la Commission Européenne a refusé les aides aux pratiques cruelles envers les animaux.
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