European Fishmeal and Fish Oil Producers
EFFOP
The objectives of European Fishmeal 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 organise and coordinate activities within the areas of interest of the European fishmeal and fish oil producers. - To distribute relevant national and international legislation to its members. - To cooperate with other associations within its field.
ID: 783980638121-41
Lobbying Activity
Response to Food and Feed Safety Simplification Omnibus
14 Oct 2025
EFFOP Marine Nutrients Europe represents European producers of marine ingredients, transforming responsibly managed marine resources into high quality proteins and nutrients, including essential omega-3 fatty acids. Our sector contributes to food security, sustainable nutrition and the EU's circular economy. We welcome the European Commission's initiative to simplify food and feed safety legislation and suggest the following key measures. Regarding Bovine Spongiform Encephalopathy (BSE), the current ban on fishmeal in ruminant feed is disproportionate given EFSA's conclusion that TSE risks are negligible and modern HACCP standards ensure safety, which supports a science-based review. With an updated EFSA opinion, lifting the ban could allow the sustainable use of 10,000-20,000 tons of blue protein per year. We strongly support the inclusion of the Animal By-Products (ABP) Regulations within the scope of this initiative. The current transport requirements for ABP materials are inconsistent across Member States, creating operational barriers in addition to the lack of transport availability in many areas. A revision of the requirements in consultation with national authorities and stakeholders, similar to the process that led to the adoption of adaptations for the transport of edible oils and fats in seagoing vessels, would facilitate logistics without compromising safety. In addition, changing the definitions of fishmeal and fish oil to include low-trophic aquatic invertebrates (tunicates, echinoderms, annelids) would unlock up to 100,000-200,000 tons of sustainable raw material per year. With regard to food hygiene rules, the current requirements for the production of fish oil for human consumption (e.g. TVBN limits, storage temperatures) are not adapted to the realities of the industry and are not scientifically sound. Revising these provisions in consultation with Member States and stakeholders would ensure harmonized EU rules and facilitate the production of safe, high-quality omega-3s for European consumers. Enclosed are the detailed proposals, and we remain at your disposal for further discussion.
Read full responseResponse to An EU strategy for fisheries external action
11 Sept 2025
EFFOP represents European producers of marine ingredients, key players in the blue food value chains. Our industry provides high quality marine proteins and nutrients such as essential omega-3 fatty acids to the aquaculture, livestock and petfood sectors. We welcome this initiative by the European Commission and would like to highlight the importance of responsible and science-based fisheries management, the need for continued access to external fishing grounds and ensuring fair competition in the blue food sector. EFFOP strongly supports long-term, science-based fisheries management. The external dimension of the Common Fisheries Policy should prioritize binding quota sharing arrangements negotiated on the basis of independent scientific advice (e.g. from ICES). This is essential to ensure stable and predictable access for the European fleet and its downstream processing sector. Recent experience has shown the risks of unilateral, uncoordinated measures: such actions threaten the sustainability of stocks and jeopardize certification and market access for certified marine ingredients. In practice, the EU must encourage that TACs and fishing opportunities in international and third country waters are set in accordance with the best available scientific advice. This will contribute to ensuring that the CFP's strategic objectives of conservation and long-term yield are met, while avoiding sudden disruptions in the supply of forage fish. In addition, continued access to productive fishing grounds is critical for the fishmeal and fish oil industry. While taking into account the coastal States prerogatives as stipulated in Part V of the UN Convention on the Law of the Sea (UNCLOS), we would like to note that unilateral closures that are not scientifically justified (such as the UK's recent decision to ban Sandeel fishing) can have inadvertent socio-economic impacts, threatening regional economies and the security of supply of sustainable raw materials. The EU's external action strategy should therefore include appropriate mechanisms to ensure a constructive approach to disagreement stemming from access restrictions that may be in contravention to international law or bilateral (or multilateral) agreement. In this regard, we welcome the recent EU-UK agreement to extend reciprocal access for a period of 12 years. Finally, EFFOP emphasizes that fair competition requires equivalent environmental and production standards for imported seafood ingredients. European producers operate under strict EU regulations (e.g. general food law, contaminants regulations) that ensure traceable, sustainable sourcing and product quality. Imports of marine ingredients, such as fish oil for human consumption, must be subject to equally stringent controls. The EU should strengthen production and border controls and traceability requirements so that all fish oil placed on the EU food market meets EU regulatory requirements. In particular, fish oil for food supplements produced in third countries and imported into the EU should meet the same production requirements and standards as EU-made products. The application of uniform standards will prevent trade distorting practices and reinforce a level playing field.
Read full responseResponse to Circular Economy Act
10 Sept 2025
EFFOP - Marine Nutrients Europe represents European producers of marine ingredients, an industry that is both economically and environmentally of strategic importance. Our members transform responsibly managed marine resources into high-quality proteins and nutrients such as essential omega-3 fatty acids, contributing to food security and healthy diets. Approximately 40% of the raw material used to produce marine ingredients in Europe are by-products of the fish processing industry, making us a cornerstone of the blue circular economy. Effective circularity begins with ensuring that raw materials are fit for high value use. However, contamination of marine resources, such as PFAS and other persistent pollutants, undermines this goal. We urge the Commission to prioritize measures that tackle pollution at source, thereby ensuring the quality of raw materials entering the circular economy and maximizing their recovery for food and feed markets. The Animal By-products (ABP) Regulation plays a crucial role in ensuring safety, but it also presents barriers that limit the optimal use of raw materials. We recommend that the European Commission address the transport and logistics constraints that currently reduce efficiency and work towards harmonized implementation across Member States to eliminate fragmentation of the internal market. In addition, current food hygiene legislation makes it almost impossible for facilities handling ABP-classified material to also produce food-grade fish oil, even if the raw material used for food production is inherently fit for human consumption. This is a particular challenge for European producers wishing to serve both the food and feed markets while meeting stringent hygiene standards. We urge a targeted review of the ABP and food hygiene frameworks to remove unnecessary barriers that prevent the food grade processing of suitable raw materials by facilitating the co-processing of ABP and food grade raw materials in the same facilities under strict segregation and hygiene protocols. Circular economy principles and the "food, feed, waste hierarchy" dictate that materials fit for human consumption should be used for food first. In practice, regulatory constraints restrict large volumes of edible fish oil to feed markets, despite European consumer demand for healthy omega-3 fatty acids. Currently, most fish oil for human consumption is imported, while valuable European raw materials remain underutilized. We believe that pragmatic solutions developed with industry stakeholders can unlock these resources while fully respecting food and feed safety. Modern industrial processes, logistics and hygiene controls already provide the means to ensure the safety and freshness of raw materials and finished products. The Circular Economy Act provides a unique opportunity to optimize the use of European marine resources, reduce import dependency and support EU competitiveness in high value food and feed markets. By enabling greater flexibility in the valorization of raw materials, the EU can increase the availability of high-quality, European-produced omega-3 products for consumers and strengthen the resilience of the blue bioeconomy. EFFOP is committed to working with the European institutions, Member States and other stakeholders to develop solutions that enable a truly circular marine ingredients sector, maximizing the value of every fish landed, ensuring food and feed safety and increasing the EU's resource independence. We encourage the Commission to integrate these considerations into the Circular Economy Act to ensure regulatory coherence and practical implementation of circular economy principles across the single market.
Read full responseResponse to Delegated Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation
12 Aug 2025
EFFOP Marine Nutrients Europe welcome the opportunity to provide feedback on the European Commission's consultation regarding the draft delegated regulation on detailed rules regarding fisheries control and enforcement. EFFOP represents the leading fishmeal and fish oil-producing nations across Europe. The European fishmeal and fish oil industry is a cornerstone of the EUs blue economy and the production of healthy food, producing around 566,000 tonnes of fishmeal and 177,000 tonnes of fish oil per year with a value of over EUR 2 billion. Our raw materials are sustainably sourced from small pelagic forage fish (60 %) and by-products from the fish processing industry (40 %). These sources include small, oily, short-lived species such as blue whiting, capelin, sandeel, Norway pout, and sprat, along with by-products from fish processing. Accurate measurement is essential for both market integrity and sustainable fisheries management. This can be achieved by ensuring impartial and consistent weighing procedures across Member States, supporting accurate reporting of catches, and contributing to reliable scientific data collection. We recommend that weighing operations are supervised either by national fisheries control authorities, by weighing operators designated and authorised by these authorities, or by independent, accredited commercial third parties. Such measures would further strengthen transparency, impartiality, and level playing field, both within the EU and in international trade contexts. We remain at the Commissions disposal for any further clarification or input, and we are happy to contribute to continued dialogue on the implementation of fair, transparent, and harmonised control measures.
Read full responseResponse to The European Oceans Pact
17 Feb 2025
The European Fishmeal and Fish Oil Producers (EFFOP) fully support the European Union's ambition to ensure cleaner oceans, sustainable fisheries and a robust blue economy and welcome the opportunity to contribute to the consultation on the European Oceans Pact. Please find enclosed our contribution to this Call for evidence.
Read full responseResponse to Setting and reviewing maximum levels for certain undesirable substances in feed
2 Feb 2024
European Fishmeal and Fish Oil Producers (EFFOP) represents European fishmeal and fish oil producers, an important processing industry key to fisheries, aquaculture, and agriculture. Our members produce high quality products with a low carbon footprint based on a sustainable supply of raw materials: fresh fish as well as by-products from the fish processing industry. The European industry excels in international competition and sets the benchmark for excellence. The factories' commitment to continuous quality control ensures fresh raw materials and traceable products that meet quality and safety standards throughout the distribution chain. As part of the food chain and as an industry committed to bringing healthy, sustainable products to the markets, we support the monitoring and, where necessary, revision of maximum levels of contaminants in feed ingredients. Some of the revisions proposed by the European Commission therefore directly affect our industry. First, we welcome the Commission's proposal to revise the maximum level of arsenic in fish, other aquatic animals, and products derived thereof. However, regarding the revision of the maximum levels and action thresholds for dioxins, we would like to draw the Commission's attention to the technical and financial feasibility for producers to comply with these new limits. Indeed, depending on the level of contamination in the raw materials, thorough cleaning will be required. For many years, European industry has invested in processes to remove dioxins during processing. In fact, the most used method for the reduction of dioxins and dioxin-like PCBs is the filtration through activated carbon. This technique is direct for fish oil, but indirect for the removal of contaminants from meals. In addition, the current state of technology does not allow the decontamination of shrimp meal because the dust content is too high. This means that not all fish meals can be effectively decontaminated using known decontamination methods (e.g. shrimp meal). Therefore, even if the best techniques are applied, there is a risk that we will not be able to process high quality raw materials due to the lack of appropriate and effective technologies for the removal of dioxins and dioxins-like PCBs and for economic reasons. EFFOP is committed to improving overall public health, but we would like the Commission to consider the need for appropriate financial investment to develop decontamination techniques and further limit dioxins and dioxins-like PCBs. We thus propose that the Commission maintains the current maximum limits and action thresholds for dioxins [sum of PCDDs and PCDFs] in crustacea meal at 1.75 and 1.25 ng WHO- PCDDFTEQ/kg (ppt) respectively. We hope that the Commission will consider our comments and raise this issue with the relevant administrations and authorities.
Read full responseResponse to Correction to the multiannual programmes for fisheries
31 Jan 2024
European Fishmeal and Fish Oil Producers has always supported fixing fishing opportunities based on the best scientific advice. It is also important for the sustainable management of stocks and the economic viability of fishing industries (primary production and processing activities) that the decision-making process for setting TACs is well-defined. The same applies to the implementation of safeguards and remedial actions for the long-term management of certain fisheries in the Baltic Sea, or other sea basin, within the regulatory framework of multiannual plans (MAPs). However, as pointed out by the Commission in its proposal, the application of the 5% rule (Article 4(6)) could, for some stock, result in a situation that would be inconsistent with the other rules of the MAPs governing the fixing of fishing opportunities. We therefore support the removal of this provision in the MAPs, which would address this inconsistency in the legal framework and clarify the guidelines for setting fishing opportunities.
Read full responseResponse to Energy transition of EU fisheries and aquaculture sector
1 Dec 2022
Please see the attached comments from European Fishmeal and Fish Oil Producers to the European Commissions call for evidence for the initiative regarding Energy transition of the EU fisheries and aquaculture sector.
Read full responseResponse to Towards a strong and sustainable EU Algae sector
18 Jan 2021
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.
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).
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