Association of Genuine Alaska Pollock Producers
GAPP
The mission of the Association of Genuine Alaska Pollock Producers is to drive awareness and demand for Wild Alaska Pollock harvested in US waters.
ID: 618620194833-04
Lobbying Activity
Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market
28 Aug 2025
The Association of Genuine Alaska Pollock Producers (GAPP) welcomes the opportunity to respond to the European Commissions call for evidence regarding the Consumer Agenda 2025-2030. GAPP members are committed to sustainable production methods and responsible management of its flagship species, Alaska pollock. While Alaska is the cradle of the species, production of this fish is not limited to U.S. waters off Alaska. In fact, the majority of Alaska pollock consumed in Europe today comes from Russian territorial waters, either directly in the form of once-frozen fillets, or more commonly, via China where it is reprocessed into twice-frozen fillets that are not linked to Alaska in any way. There is therefore an urgent need to amend the EU regulatory framework to enable consumers to make a clear distinction between fish genuinely originating in the Alaska Region of the United States and those harvested in other regions. At present, fishery and aquaculture products are subject to the Fisheries Regulation (Regulation (EU) No 1379/2013), which requires the FAO fishing zone of the fish was harvested in to be indicated on the labelling (article 35). This indication must be included in particular for fishery products caught at sea, in terms that are intelligible to the consumer, either by the written name of the FAO fishing zone, or by a map or pictogram indicating this zone (article 36). Although the Fisheries Regulation requires this indication, in principle it is insufficient to provide consumers with clear information on the origin of the product for two main reasons: Combining the geographical reference to Alaska with the indication of a different fishing zone makes the information more complex for the consumer, who will not necessarily be able to determine which of these two indications of origin should be taken into account. Moreover, the consumer does not have access to intelligible information, especially in cases where the FAO number of the fishing zone is referred to rather than its name written out in full, or where multiple fishing zones are referenced; The boundaries of the fishing zones established by the United National Food and Agricultural Organisation (FAO) do not necessarily correspond to maritime borders. Indeed, the straight line separating zones 61 and 67 does not reflect the delimitation of the maritime border between Russia and the United States. For example, part of Alaska's territorial waters is classified in zone 61 (Pacific, north-west), while part of Russia's territorial waters is in zone 67 (Pacific, north-east). The average consumer, normally informed and reasonably attentive and enlightened, would presume that Alaska pollock comes from Alaskan territorial waters of the United States, and not from Russian territorial waters. Consumers cannot be expected to know, in the absence of any other information, that such a product comes from territorial waters other than those of Alaska. In addition, it is not reasonable to expect consumers to have any knowledge of the FAO codes for particular fishing zones. The mere mention of the fishing zone on the label is therefore not sufficient to guarantee intelligible and correct information for consumers, or to enable them to take environmental or geopolitical concerns into account in their purchase decisions. EU consumers are therefore being systematically misled, the demand for real Alaska pollock is undercut, and Alaskas global reputation is being appropriated to benefit competitors from non-market economies. GAPP therefore strongly recommends an amendment to the EU regulatory framework to mandate meaningful information as to the true origin of the fish, such as the inclusion of the flag state as the relevant harvest data element on the product label. Such an amendment would empower consumers to make informed and sustainable choices when purchasing fish products.
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