EUfishmeal

EUfishmeal is a European non-governmental organisation representing European fishmeal and fish oil producers The objectives of EUfishmeal are: To represent and promote the European fishmeal and fish oil industry in the EU To assure a pro-active position for the sector in front of the EU Commission, the EU Council and the European Parliament To provide accurate information to decision makers To organize and coordinate activities within the areas of interest of the European fish meal and fish oil producers To distribute relevant national and international legislation to its members To cooperate with other associations within its field Full members of EUfishmeal are national associations in European countries focusing on the production of fishmeal and fish oil. Associated members of EUfishmeal are companies and organisations within Europe, who are invited to join EUfishmeal.

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Transparency Register Profile

ID: 242927422969-47

Lobbying Activity

Response to Revising the rules for free allocation in the EU Emissions Trading System

8 Jul 2019

With the revision of the Emissions Trading System for phase 4 starting in 2020, new criteria will be introduced for sectors permitted to present data to document their energy and trade intensity and being at risk of carbon leakage. The random criteria established have tremendous and unreasonable consequences for the European producers of fishmeal and fish oil and can potentially impose costs which are so large that production in EU/OECD will no longer be possible. Europe is one of the world’s largest producers of fishmeal and fish oil. On a global level, Europe is producing 16% of the world´s fishmeal and 23% of the world´s fish oil and the total value of production is approximately 1 billion €/year. Energy intensive production − a highly competitive industry: The production is energy intensive, and the European factories are very exposed to international competition and they are for these reasons today on the list of sectors receiving free quotas under the quota system. The political agreement on the revision of the Emissions Trading System and the changed criteria for carbon leakage indicators led to an outcome where an entire industry is impacted and “sacrificed” despite an unchanged intensity of energy use and trading. Producers of fishmeal and fish oil fall completely out of the CL-list and additionally - are not able to apply to remain on the list despite an unchanged intensity of energy and trading. Requests on a qualitative assessment of the energy and trading intensity has been rejected by the European Commission with reference to the fact that the industry does not meet the criteria to submit data. This is solely due to the position of the industry placed in the European statistical classification under processing of fishery products where there is no specific subcode for fishmeal and where the industry is classified under NACE code 1020 along with the rest of the fish processing, which is not as energy intensive. If the industry had been statistically classified under the production of fish oil on NACE 1041 (eg. food graded oil) or along with the production of other types of feed which are high in protein, such as milk powder, our industry would have remained on the carbon leakage list. Consequences for the fishmeal industry: Calculations based on the quota allocations from 2020 shows that the consequences of European fishmeal industry’s removal from the CL-list alone cost the factories a minimum of 27 million euros during 2021-2030 (CO2 quota price of 25 €/quota). It is an unjust and differential treatment of this industry caused solely be a random statistical classification. The industry has an unchanged energy intensity and a qualitative estimation of the fishmeal industry will without a doubt document a continued justification of free quotas. Internationally, the industry is highly competitive, and a future European production of fishmeal and fish oil will depend on acknowledgement from the European Commission and establishments of compensating measures for the industry.

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