Federation of European Aquaculture Producers
FEAP
The Federation of European Aquaculture Producers represents the European fish farming profession.
Lobbying Activity
Meeting with Costas Kadis (Commissioner) and
3 Dec 2025 · Exchange of views around Oceans Pact, Vision for the Future of Fisheries and Aquaculture in Europe by 2040 and evaluation and possible revision of the Common Fisheries Policy (CFP)
Meeting with Costas Kadis (Commissioner) and
1 Dec 2025 · Presentation of the proposal for a “Blue Foods” project and action plan
Response to Modification of rules on organic trade and simplification
18 Nov 2025
FEAP welcomes the initiative to introduce targeted amendments to Regulation 2018/848. Despite a supposedly supportive regulatory framework, the fish farming organic sector continues to face significant barriers. As a result, many fish farmers who have bet on organic production have struggled to maintain or expand their organic lines, leading to stagnation or even a noticeable decline in overall output. FEAP recently carried out an internal evidence-gathering exercise with fish farmers and feed suppliers across several Member States to identify the main bottlenecks affecting organic finfish production. The following points summarise the most recurrent findings. 1. Feed availability, cost and formulation rules are the main limiting factors. Organic feed costs for finfish remain significantly higher than for conventional feed, mainly due to the restricted list of permitted ingredients and processing techniques. Producers report limited access to suitable certified protein sources, particularly for carnivorous species and early life stages. Scarcity and high prices of certified marine ingredients, limited authorised additives, and the prohibition of certain processing methods and synthetic amino acids reduce formulation flexibility and competitiveness. Updating Annex II (Part III, 3.1.3) to broaden permitted protein and lipid sources, and allowing a wider range of functional additives and processing techniques, would substantially improve performance and lower production costs. 2. The shortage of certified organic juveniles is a critical bottleneck for finfish producers. Several species, notably seabass, seabream and meagre, face severe constraints due to the very limited number of certified hatcheries in Europe. Some hatcheries have recently discontinued organic production, creating supply instability and, in some cases, interruptions of organic output. Divergent national interpretations of the separation requirements for mixed organic and non-organic hatcheries create uncertainty and hinder investment. Clear, harmonised guidance and a regularly updated overview of available certified juvenile suppliers would significantly improve planning and continuity. 3. Market limitations undermine the economic viability of organic finfish farming. Price premiums often do not compensate for higher input costs. Consumer awareness of organic fish remains low in many markets and competition from other labels, or even with wild caught fish, is strong. Some organic finfish is routinely sold as conventional due to insufficient demand. Strengthened consumer information, coherent control of imports under equivalence schemes, and EU-level promotion of organic aquatic food would support more stable demand. 4. Divergent interpretations of requirements increase administrative burden. Producers report differences between Member States and certification bodies, particularly on hatchery setups, parallel production, and certain operational requirements. Greater clarity and harmonisation would reduce administrative burden, ensure legal certainty, and facilitate investment. In some countries, spatial planning and licensing conditions further limit the expansion of organic finfish capacity. 5. Health management rules are generally workable, but gaps remain. While most producers can operate within the current limits on allopathic treatments, the absence of authorised organic medicated feed and the expected increase in disease pressure under climate change raise concerns for fish welfare and resilience. Priority areas for targeted amendments: Broaden permitted feed materials and processing aids; Clarify and harmonise separation rules for mixed hatcheries; Support an updated EU-level overview of certified juvenile supply; Ensure consistent certification and control practices; Promote organic aquatic food to strengthen consumer awareness; Enhance transparency and controls for imported organic products.
Read full responseMeeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto), Kyriacos Kyriacou (Cabinet of Executive Vice-President Raffaele Fitto) and
20 Oct 2025 · Presentation of call for an EU Action Plan on Blue Foods
Meeting with Aurel Ciobanu-Dordea (Director Environment)
17 Oct 2025 · Reuse targets for the fish sector in the Packaging and Packaging Waste Regulation (PPWR)
European aquaculture producers demand recognition in nature credit system
16 Sept 2025
Message — FEAP requests including traditional freshwater pond and marine lagoon aquaculture in the nature credit scheme. They urge the Commission to develop certification methods tailored to aquaculture-related biodiversity services.12
European aquaculture producers demand binding targets and less bureaucracy
10 Feb 2025
Message — FEAP calls for compulsory production targets and the inclusion of freshwater fish farming. They advocate for administrative simplification and a level-playing-field to compete with high import volumes.123
Why — Specific production targets and reduced regulatory burdens would help reverse two decades of stagnation.45
Impact — Environmental groups may lose influence as regulations are rebalanced to prioritize industrial food production.6
Meeting with Costas Kadis (Commissioner)
24 Jan 2025 · Fish Farming in the EU, Common Fisheries Policy and promotion of aquatic food consumption
Meeting with Delilah Al Khudhairy (Director Maritime Affairs and Fisheries) and
23 Jan 2025 · Upcoming meeting with the MARE Commissioner. Key concerns of FEAP
Meeting with Ton Diepeveen (Member of the European Parliament)
5 Nov 2024 · Kennismakingsgesprek
Meeting with Isabella Lövin (Member of the European Parliament, Rapporteur for opinion)
5 Nov 2024 · Stakeholder discussion on protection of animals during transport
Response to Evaluation of the Common Fisheries Policy
4 Sept 2024
The Federation of European Aquaculture Producers (FEAP) welcomes the opportunity to provide its views on the performance of the instruments and measures of the Common Fisheries Policy (CFP) Regulation over the last decade (2014-2024). The 2013 reform of the CFP included the "Promotion of sustainable aquaculture" to contribute to food security and supply, growth and employment. It established non-binding strategic guidelines from the European Commission, Multiannual National Strategic Plans of the Member States on aquaculture and the exchange of best practices. It is a fact that EU aquaculture production has stagnated in volume since 2000, and the EU self-sufficiency rate in aquatic products reached its lowest level in 2021, at 38%. FEAP, therefore, concludes that the CFP has not even come close to achieving the goal of promoting sustainable aquaculture to contribute to food security and supply, growth and employment. Furthermore, FEAP considers that the low priority given to aquaculture in the Member States leads to failures in implementing these policies. In this regard, FEAP points out the following: 1. The non-binding strategic guidelines on aquaculture have had a very limited impact on the legislation and governance of the Member States in this field. 2. The Multiannual National Strategic Plans of the Member States on aquaculture have shown deficiencies in content and application. 3. No effective and timely follow-up measures have been established either at the European Union level or in the majority of Member States. 4. No progress is perceptible towards achieving the CFP objective of promoting sustainable aquaculture development in the Union. In light of all this, this federation recommends adopting political measures to ensure that aquaculture is given a higher position in the European Union's common policies.
Read full responseEuropean Fish Farmers Urge Tailored Rules for Aquatic Transport
8 Apr 2024
Message — FEAP requests the regulation explicitly exclude fish embryos and eggs from its scope. They propose doubling the allowed transport radius for farmers to one hundred kilometers. They also advocate replacing mandatory veterinary supervision with experienced farm operators.123
Why — This would lower compliance costs and remove technical requirements that are not practically feasible.45
Impact — Animal welfare groups lose higher protection standards as veterinary oversight is replaced by informal experience.6
10 Jan 2024
The Federation of European Aquaculture Producers welcomes this important initiative that introduces rules also for fish farmers and aquaculture veterinarians for the oral administration of veterinary medicines mixed in feed, well understanding, as reported in the recitals 11 and 12, the peculiarities and differences of fish farming. The following are FEAPs remarks and notes referring in particular to Article 6 of the proposal: (1) Art.6 Point 1. There are clinical situations in aquatic animal health (as certainly also in terrestrial animals) demonstrating the involvement at the same time of more than one pathogen, or disease complexes, that justify treatment simultaneously with two active substances. To reduce the onset of antimicrobial resistance two active substances may not be used against one pathogen, however, they might be very well used simultaneously against different pathogens and pathological syndromes. FEAP considers that this should be addressed in the draft. (2) Art.6 Point 3. FEAP welcomes the intention for a derogation of oral medication in aquaculture. In many EU countries, under certain circumstances, it is impossible to obtain medicated feed for aquaculture. For this reason, oral medication will be the only alternative to ensure a timely and effective therapy when needed, through responsible and controlled use of VMPs. (3) Art.6 Point 4. Although national rules can better satisfy specific national needs and local situations, any restrictions that lead to inequalities between different Member States, or the adoption of procedures that determine unnecessary and sectoral limits to the possibility of adopting effective therapies, can unequivocally favour unequal conditions of competition that go against the EU Single Markets level-playing-field. FEAP invites the Commission to develop and issue specific guidelines and a strong drive to ensure a uniform and harmonized application of the proposal.
Read full responseMeeting with Clara Aguilera (Member of the European Parliament)
21 Mar 2023 · Bluefin tuna
Response to Energy transition of EU fisheries and aquaculture sector
28 Nov 2022
FEAP supports the efforts to accelerate the energy transition in EUs aquaculture sector. The energy transition in fish farming focuses on moving away from the use of fossil fuels and unsustainable electricity sources. The use of non-carbon electricity should be dealt with through the selection of an adequate supplier. This contribution focuses on the decarbonisation of aquaculture vessels. Currently, the fuel mix in the maritime sector, including aquaculture, relies entirely on fossil fuels. This can be explained by the characteristics of the vessels in use, insufficient incentives for operators to cut emissions, and the lack of mature, affordable, and globally utilisable technological alternatives to fossil fuels in the sector. The lack of information on future regulatory requirements and the long lifespan of vessels further complicate this situation. Aquaculture vessels are used for day-to-day farming operations, but these are characterised by journeys that are short in distance, regular in intensity, and involve daily returns to a home port. This makes its energy transition a more achievable objective in the short term than for capture fisheries or maritime transportation vessels. In this sense, aquaculture can lead the way for other sectors. Initial technical proposals suggest that, in the short run, addressing emissions from aquaculture vessels will arrive through increased electrification and, in the mid-term, the application of hydrogen for their propulsion, besides the use of solar power for auxiliary power uses. It should be stated that achieving significant reductions in carbon emissions in aquaculture vessels requires the construction of carbon-neutral vessels and the use of cleaner types of energy, such as renewable and low-carbon fuels, but also less energy by increasing energy efficiency. FEAP proposes the following actions: a) The European Commission and Member States fund research and technological development to deal with the specific requirements of the energy transition of aquaculture vessels. Such requirements should be understood as different from those of capture fisheries vessels. This matter would require close coordination between DG MARE, DG RTD, and the European Climate, Infrastructure and Environment Executive Agency (CINEA). b) DG MARE makes use of the Aquaculture Assistance Mechanism to spot and share current experiences in renewable and low-carbon fuel in aquaculture vessels on which common European development could be built. This outlooking exercise could be extended to other countries, such as Norway, where examples of full-electric aquaculture vessels are in development. c) Member States find ways to make use of the creativity and proactivity of aquaculture farmers to accelerate the energy transition in aquaculture vessels. This could be promoted through Fisheries Local Action Groups (FLAGs) or Producer Organisations (POs). d) Member States provide maximum financial support through the European Maritime, Fisheries and Aquaculture Fund (EMFAF) to aquaculture farmers engaging in the decarbonisation of energy in aquaculture vessels, including for both the purchasing of vessels built with a carbon neutral balance and for decarbonised propulsion systems e) Any policy making for the decarbonisation of energy in aquaculture vessels should be coherent with the reality of this primary production sector, mainly comprised of micro and small undertakings. Changes in the legal framework should offer predictability to operators and investors. f) The transition should mean the acquisition of new carbon neutral built aquaculture vessels, the acquisition of low-carbon powered aquaculture vessels and the adaptation of existing vessels by the replacement of combustion engines and the installation of low-carbon auxiliary power sources. g) The decarbonisation of energy in aquaculture vessels would also benefit from efforts to increase their energy efficiency.
Read full responseAquaculture Federation Urges Explicit Fish Exclusion from Rules
27 Nov 2022
Message — The federation requests that the Commission clearly state the proposal does not apply to aquatic vertebrate animals. They want to ensure legal security and avoid risks when transportation lorries are pulled over.123
Why — This clarification avoids potential troubles for undertakings when rules are not accurately written.4
Response to Communication on the functioning of the Common Fisheries Policy
23 Sept 2022
On how to improve reaching the CFP objectives under current legal framework:
- Reaching the objectives of the CFP requires the correct interpretation of the regulation by the MS and regional authorities. Throughout the regulation, there are clear inconsistencies in the meaning of the term ‘fisheries’ on matters related to aquaculture. There is a need to clarify in the regulation the scope of the term ‘fishery’ as sometimes it seems to comprise aquaculture and sometimes it seems not to include it and refers only to ‘capture fishing’.
- There is widespread use of the term ‘sustainable aquaculture’ but no definition for it. Disposing of sustainability indicators for environmental, economic, and social aquaculture sustainability is needed.
- The CFP is expected to contribute to a fair standard of living for small-scale fisheries. Small-scale aquaculture farmers are supposed to be included in this objective of the CFP but, from a practical perspective, they are not. This limitation should be corrected.
- The management of aquaculture should also be carried out under ecosystem-based approaches.
- MS should consider aquaculture vessels as fishing vessels, and they don’t always do it that way.
On the interaction between aquaculture management tools, EU env. legislation and the objectives of the Green Deal:
- The GD, and previous EU policies, have spined-off numerous legal initiatives to protect and restore the natural environment. The EC's recent proposal for a Regulation on nature restoration is the latest example. The FEAP supports and emphasizes their relevance because fish farmers are environmentally conscious denizens because of carrying out their daily work within nature. Furthermore, aquaculture requires clean and good-quality waters to be viable. However, the FEAP stresses that too few initiatives have been set in place at the EU level to back the livelihoods of people that farm directly in coastal or riverine public areas. This call for support should not be understood exclusively in the form of financial aid but through the establishment of a friendlier business environment. The CFP has been unable to counterbalance the impact of those environmental policies on the aquaculture sector.
On the emerging trends and challenges faced by aquaculture:
- Most environmental, social, and economic challenges that the aquaculture sector has to face today are shared throughout the MS. Facing those challenges in an effective way would require a transnational approach. Although the CFP (and the CMO) allow for certain transnationality there are no specific tools for it set in place, neither by the EC nor the MS. The FEAP requests a more imaginative approach to this transnationality issue. (Beyond the proposals on transnational PO's already informed by the EC.)
On how the CFP can drive a sustainable future:
- During the Covid-19 and the Ukraine war crisis, the relevance of food production in the EU and the importance of strengthening food security have been heightened. Aquaculture production in the EU has been recognised as having a potential leading role in both. Moreover, the environmental sustainability of aquaculture, the low carbon footprint of this production, its contribution to a circular economy, even its provision in some cases of ecosystem services, and the role of aquaculture in the Blue Economy, have been widely recognised. However food production in the EU continues to be a second-level political target, well behind environmental protection. The FEAP strongly calls on the European Commission to find ways to link environmental objectives to social and economic targets.
Read full responseResponse to Application of EU health and environmental standards to imported agricultural and agri-food products
16 Mar 2022
The Federation of European Aquaculture Producers (FEAP) is an organisation that represents the European fish farming profession and is based in Brussels. FEAP is composed of 24 national fish farming associations from 23 countries, both EU and non-EU. The combined yearly production of FEAP members surpasses 2,5 million tonnes of nutritious, safe, delicious and environmentally sustainable fish.
The FEAP emphasises the utmost importance of assuring that imports to the EU of agricultural and food products fulfils not only food safety rules but also the same environmental and social sustainability standards as EU-produced food. This level-playing field is essential to reach the social and economic sustainability objectives of the Farm to Fork Strategy, for achieving the sustainable food system framework initiative objectives, and for attaining the UN Sustainable Development Goals in the European Union.
The EU is the main international trade market for aquatic food products and 65% of all aquatic food consumed in the EU is currently imported from Third countries. This globalisation makes the sustainability of aquatic food production and consumption in Europe especially dependent on making sure that imported aquatic food complies with standards assuring that externalisation of unsustainable practices does not occur.
Aquaculture in the EU currently applies the most stringent environmental, social, and fish welfare standards in the entire world. The EU should take advantage of this situation to shape global rules for more sustainable and fairer aquaculture and capture fisheries in other parts of the world. This can be achieved through the currently reviewed EU Trade Policy for an open, sustainable, and assertive Trade Policy. In other ways, the EU aquaculture sector will continue suffering the unbearable weight of unfair competition from imported aquatic food products.
The FEAP favours opening a wide, transparent, and informed debate on the application to imports of certain sustainability production standards, including environmental, social, and fish welfare standards. This will encourage the production in Third countries of agri-food products that comply with sufficiently high social and environmental sustainability practices.
Environmental, social, and fish welfare sustainability standards have already been developed for aquaculture in different fora. The FEAP proposes making use of the experience of the European aquaculture sector to develop the necessary set of sustainability standards and offers direct collaboration on this matter.
Within this context the FEAP:
1. Calls the European Commission to revise decades-old bilateral agricultural trade agreements to incorporate sustainability standards to comply with the objectives of the Green Deal and the Farm to Fork Strategy.
2. Requests the EC to develop a legally binding control system intended to ensure, and where necessary to enforce, that all fishery and aquaculture products imported to the EU comply with the relevant EU requirements. It is essential to ensure the ability of the competent authority of the third country to deliver the required sustainability standards.
Read full responseResponse to Recommendation for strengthened actions against antimicrobial resistance
14 Mar 2022
The Federation of European Aquaculture Producers (FEAP) published in January 2022 its Position paper on Antimicrobial Resistance. Please read the full document attached.
Read full responseMeeting with Virginijus Sinkevičius (Commissioner) and
14 Mar 2022 · To discuss the impact of increasing fuel and raw material prices on the fishing sector
Response to Sustainable food system – setting up an EU framework
25 Oct 2021
The FEAP supports the European Commission’s objective to build more sustainable food systems and welcomes the Commission’s initial consultation on a related framework initiative. This federation appreciates the possibility to provide its views in relation to the works for making the European Union food system sustainable.
The FEAP represents European primary producers, in particular fish farmers. This federation fully shares the main objective of the Farm to Fork Strategy to ensure that all foods placed on the EU market become sustainable. However, as part of the European Green Deal, the Farm to Fork Strategy should tackle climate and environmental-related challenges under the perspective of healthy economic growth and fair social development.
This federation has accumulated over the last decades extensive experience showing that when European level legislation, mainly environmental, is implemented at Member State level its potential impact on the competitiveness of the undertakings and on the income of farmers is severely overlooked. For this reason, the competitiveness of EU fish farmers, when compared to the development of aquaculture in Third countries, has decreased year after year. The European Commission should keep this in mind at the inception of any new legislation and not expect that this situation can be compensated from the fish farmers' side through innovation or management excellence. These help but are not enough.
The core message of this contribution from FEAP to this inception impact assessment is that the FEAP fully supports the work of the European Commission for pursuing a sustainable food production system and that all foods placed on the EU market should become increasingly sustainable. This federation stresses that any sustainability requirements stemming from the food systems framework initiative should be clear, realistic, consistent, proportionate and shared between all players of the food chain, including economic operators, public authorities and consumers. However, FEAP also highlights that there is a considerable risk that this initiative will inadvertently contribute to further reduce the competitiveness of EU fish farmers.
The European Commission’s Strategic guidelines for a more sustainable and competitive EU aquaculture recommend streamlining and harmonising legislation and administrative guidance on aquaculture to unlock the extraordinary potential of this industry to support the Green Deal and the Farm to Fork Strategy. But it is important that any new framework legislation does not become another layer of administrative burden for aquaculture producers, and is coherent with the current obligations of fish farmers on environmental protection, veterinary issues, food safety, workers safety, customer rights, animal welfare, taxes, water access and other relevant areas. In this sense, the ‘one in-one out’ principle should be considered to ensure that new burdens resulting from the introduction of new legal requirements are offset by equivalently reducing burdens in the same policy area.
The European fish farming industry is already placed on an environmental and social sustainability baseline that is well above Third countries aquaculture and, furthermore, beyond other European economic industries. This meritorious socle has been achieved thanks to the implementation of the Common Fisheries Policy and the environmental requirements pegged to the use of public domain waters.
Furthermore, the farming of fish is the most resource-efficient animal production when compared to terrestrial vertebrate production, and with the lowest carbon footprint.
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(The complete FEAP contribution is included as an attached file).
Read full responseResponse to Amendment to the delegated act on the functioning of the Advisory Councils under the Common Fisheries Policy
8 Sept 2021
The Federation of European Aquaculture Producers (FEAP) welcomes the initiative of the European Commission to improve the detailed rules for the functioning of the Advisory Councils. This federation currently participates in two Advisory Councils (AAC and MAC) and believes they are effective tools for improving the governance of aquaculture (production and markets) in the European Union and beyond.
The FEAP welcomes most of the provisions included in the Commission’s delegated act proposal. Indeed, they tackled concerns expressed by this federation in the past on the functioning of the Advisory Councils. However, we bring here forward the following comments:
- This delegated act (as in previous regulations) insists on taking special care of the participation and representation of small-scale capture fleets; but there is no reference to encouraging the participation of aquaculture microenterprise representative organisations (on seaweed production, for example). This should be added.
- On the new definition of ‘sector organisations’ the proposal refers to ‘health’ organisations when describing the types of member organisations, but without clarifying if it refers to human or animal. Although ‘animal welfare’ sometimes comprises ‘animal health’ it is not always the case and regulations must avoid ambiguities that can lead to misinterpretations. For example, the EC in its communication on the Strategic guidelines for a more sustainable and competitive EU aquaculture for the period 2021 to 2030 separates animal ‘health’ from animal ‘welfare’ and discusses them separately.
- Also on the new description of ‘sector organisations’ this federation proposes the following amendment in addition: (e) provided that one of the criteria listed in point 1(a) to 1(d) is met, the organisation is active in the field of environment, consumers and human rights, public health, promotion of equality, animal health or animal welfare.
- Moreover, organisations that are independent from economic interests linked to the sectors of commercial fishing, aquaculture, processing, marketing, distribution or retail of seafood that are dedicated to research, to training and to education should be eligible to access any Advisory Council as ‘Other interest group’.
- On the new definition of ‘other interest groups’ the FEAP proposes the following amendment in addition: (a) the organisation is primarily active in the field of environment, consumers and human rights, public health, promotion of equality, animal health, animal welfare, research, training, education, or recreational or sport fishing; …
Read full responseResponse to Animal welfare labelling for food
23 Aug 2021
The Federation of European Aquaculture Producers is strongly committed to maintain a high level of farmed fish welfare in Europe and to continuously improve it. This is carried out by fostering the production of sound scientific knowledge, through best practices at farm level and through the promotion of a coherent legal framework.
The FEAP welcomes this consultation initiative aiming to update EU animal welfare rules to increase the role of recent science-based analysis, broaden their scope and make them easier to enforce.
However, we note with some concern that this inception impact assessment comes at a time when the outcomes of the fitness check of the current rules are not yet known. The roadmap for the inception impact assessment confirms that the fitness check for the animal welfare legislation is still ongoing and only due for completion in 2022, but it highlights that available information already points to weaknesses in the design, implementation, compliance and enforcement of the EU legislation.
The FEAP has published two position papers on fish welfare that we share here (see 2 annexed documents):
- FEAP position on Fish Welfare (May 2019)
- FEAP position on Transport of live fish (May 2021)
This federation highlights the following issues for this EC roadmap consultation:
(1) Fish are farmed throughout Europe in many very different conditions, systems, environmental conditions, climatic zones, salinities, and employing a great variety of technologies. This means that the establishment of legally binding hard rules on the welfare of farmed fish can be counterproductive (and play against the wellbeing of the fish) unless sound science knowledge is available for each species under all those different conditions. And the possible welfare rules must be clear in setting conditions for all those conditions.
(2) The FEAP stresses that fish welfare rules must be based on good quality science, that this science is sufficiently detailed to address the specificities of each fish farming condition, that the rules take a practical approach, and acknowledging where the sector currently is in terms of best practice. Moreover, when consulting with interested parties on technical issues for policy making, public authorities are expected to make a distinction between knowledgeable organisations and uninformed bodies that claim to be experts but that have an unscientific or outdated approach to fish welfare.
(3) Whenever EU animal general welfare legislation is produced for vertebrate animals, special care must be taken to consider the differences between terrestrial animals and aquatic animals, and what applies to one, to the other and to both.
(4) The EU Single market imports from Third countries almost 65% of the aquatic food that it consumes. The achieving of a level playing field for aquatic food placed on the Single market is an objective of the Farm to fork strategy and it is essential for the competitiveness of EU fish farmers. Any development in EU animal welfare legislation (including labelling) should take this situation into consideration and offer solutions.
(5) The ongoing revision of the EU animal welfare legislation does not cover wild animals. The EU market for aquatic food consists of 75% of wild fish and 25% of farmed fish. When consumers buy aquatic food they do not chose based on if the fish were caught or farmed but on other factors. The setting of stricter rules on aquatic animal welfare only for 25% of the sentient fish placed on the market does not face the expectations of citizens and consumers and perpetuates an unfair situation.
The FEAP is an organisation that represents the European fish farming profession and is based in Brussels. FEAP is composed of 24 national fish farming associations from 23 countries, both EU and non-EU. The combined yearly production of FEAP members surpasses 2,5 million tonnes of nutritious, safe, delicious and environmentally sustainable fish.
Read full responseResponse to Protecting the environment in the EU’s seas and oceans
5 May 2021
The Federation of European Aquaculture Producers (FEAP) represents the fish farming sector in Europe. It is composed of 24 national aquaculture associations drawn from 23 countries across the continent.
The Marine Strategy Framework Directive (MSFD) aims to achieve good environmental status for productive and healthy seas. The FEAP recognises that the marine environment is subject to multiple pressures and impacts from human activities at sea and on land. It acknowledges that maintaining healthy, productive and resilient marine ecosystems is central to the future of Europe but also, in particular, for the sustainable development of European aquaculture, one of the pillars of the European Blue Economy and of the Farm to fork Strategy.
The FEAP wishes to highlight in this roadmap consultation that fish farming can only be performed in clean waters because aquaculture is about food production. For this reason, the FEAP has always been interested in promoting the development of responsible aquaculture in Europe that makes a sustainable use of natural resources and minimises its environmental footprint in the waters. However, at the same time the FEAP insists that other human activities are controlled with similar level of zeal so as not to disturb the environmental quality of those same waters that are essential for aquaculture.
The FEAP also stresses the importance of streamlining the environmental legislation so that it is fit for purpose and it keeps a balance between the protection of marine resources and the development of sustainable economic activities. This should apply both at European level and for national and subnational legislative frameworks. Most fish farming undertakings are micro and small enterprises for which excessive red tape becomes an unsurmountable burden.
Read full responseResponse to Setting of nutrient profiles
27 Jan 2021
The Federation of European Aquaculture Producers (FEAP) represents 22 national associations from 21 countries across Europe. Our organisation works for the sustainability of the European fish farming profession. We represent both marine and freshwater finfish production, with a consolidated sectorial annual production of 2,574,000 t.The fair, healthy and environmentally friendly food system that the Green Deal and the Farm to Fork Strategy aim to achieve for the European Union are fully supported by the FEAP. These initiatives are expected to set out regulatory and non-regulatory measures to deliver more sustainable food and help achieve the European Union’s ambitions towards climate-neutrality.
The FEAP shares with the European Commission the view that a sustainable food system should not only deliver affordable foods but also improve the incomes and competitiveness of European primary producers, including fish farmers.
However, the FEAP stresses that to reach the objectives of the Farm to Fork Strategy there is a need to consider this policy in a holistic way. This means that cherry-picking for environmental targets should be avoided and all the aims should be pursued synchronically.
The FEAP agrees with the Farm to Fork strategy on the acknowledgement that European primary producers lag in terms of income and that the implementation of the strategy should aim to ensure the possibility of a sustainable livelihood for them.
This federation also highlights that the strategy should also focus its assessment on the rest of the value chain (processing, transportation and retailing) and their contributions to value chain fairness and impact on the environment, and not focus only on the farmers.
Moreover, the FEAP strongly stress the need to further empower consumers (last link of the value chain) through clear, precise and comprehensive food labelling information for responsible purchasing as a key element for the sustainability of primary producers (first link of the value chain).
On information to consumers on fisheries and aquaculture products:
Although there is a growing interest from consumers to know more about the food they purchase the European Commission should be aware that the current compulsory labelling rules leave wide loopholes that the implementation of the Farm to Fork strategy should now close.
The European Parliament has pointed out in several occasions that fish products are, after olive oil, the second product most at risk of food fraud in the European Union.
Voluntary information on labels is valuable for some secondary characteristics of fish products but cannot be expected to cover the gaps left open by compulsory labelling information legislation.
Fish is one of the food categories that must follow specific labelling rules. But these were originally set up to control and protect wild fish stocks and not for other objectives. The placing on the market of aquaculture products has inherited the obligations of capture fisheries even though they are products with different characteristics.
The majority of European aquaculture products are placed on the market and offered to consumers through the retail channel and as non-prepacked. This means that the information to consumers that they must comply with is the one established in Regulation 1379/2013 on the common organisation of the markets in fishery and aquaculture products. However, prepacked aquaculture and fisheries products must comply with Regulation 1169/2011 on the provision of food information to consumers.
The FEAP highlights that the consumption of fish in hotels, restaurants and catering (Horeca channel) can be estimated around 25% of all aquatic products consumption in the European Union. The consumers of this fish in Horeca rarely have the opportunity to know with truthiness the basic characteristics of this fish: e. g. country of origin, species name, or having been defrosted. This situation must be faced and solved.
The FEAP also points out...
Read full responseResponse to Contingency plan for ensuring food supply and food security
12 Jan 2021
The FEAP welcomes the establishing of a Contingency Plan to ensure food supply and food security in the event of crises.
Contributions to the Contingency Plan (see attached document for details):
1. Food security in emergency times needs to be built during normal times.
During the last 50 years the EU and European citizens have taken food supply for granted. Either through domestic production or by means of imports from third countries the food needs of Europe have been addressed without major tensions. However, the recent favourable evolution of the economic and social conditions in many developing countries, with China as the main example, has drastically changed the global scenario and the balance of food supply and demand. But the Covid-19 crisis has clearly exposed the new limits on food supply in a sort of preview of a situation that was already ongoing. Europe is self-sufficient for most agricultural products. However, the EU continues to bear a huge trade deficit on aquatic products (meaning both aquaculture and capture fishery products). The extra-EU trade balance deficit on seafood in 2019 was worth EUR 21 billion . Aquatic food products are a key element for maintaining a healthy diet. Aquatic products are an essential part of any official Healthy Eating Pyramid recommendations in Europe and around the world. This means that fish supply is an essential component of food security and cannot be compensated by any other foodstuff. The current strong imbalance in aquatic food external trade in the European Union is incompatible with any long-term food security European policy. And this becomes more critical when planning for facing emergency situations in which transportation and trade will be severely disrupted, like the ones to be faced by the Contingency Plan.
The FEAP considers that an essential element to provide sufficient food security to the European Union is by greatly increasing fish production in the Union. And as capture fishery production is capped by the maximum sustainable yields of the wild fish stocks the only way to rebalance this situation is through the substantial increase of aquaculture production in the EU. FEAP recommends the European Commission to find immediate real solutions to unlock the potential of aquaculture in the Union.
2. There are weaknesses in the EU’s food supply chain, and they have showed-up in the Covid-19 crisis.
The European Commission’s statement that during the recent Covid-19 crisis the EU’s food supply chain responded well and that it proved to be resilient to large-scale disruption misses an important point. Being true that quantity wise the functioning of the EU’s food supply chain held tight during the emergency, from a price point of view the situation was very different. In the case of aquaculture products, a significant drop in average prices has been felt in almost all the species. This decrease has been strong enough to jeopardise the viability of numerous undertakings. The reasons for this price drop can be traced to lower internal demand but mainly to massive imports at very low prices from third countries where the crisis also stroke and where fishers and fish farmers need to keep their revenues afloat. The Contingency Plan must include a special vigilance of the prices of food imports to detect sudden price drops and mechanisms to immediately correct them. In normal situations the Union has mechanisms in place to detect and countervail these type of market failures through official complaint procedures, but during emergency situations the established time-frames for these complaint procedures simply do not exist.
Other contributions:
3. Primary producer’s undertakings are also affected directly by insufficient coordination between Member States.
4. Need to define the essential components of the economy for emergency time.
5. Aquaculture stakeholders are to be included in the coordination mechanism forum.
Read full responseResponse to Protecting biodiversity: nature restoration targets
2 Dec 2020
The Federation of European Aquaculture Producers (FEAP) warmly welcomes the new EU Biodiversity Strategy. The Federation sees this Strategy as an opportunity for the aquaculture sector to place sustainability in the centre of food legislation. The FEAP has proven over the years our commitment to move towards more sustainable aquaculture systems and contribute to preserve biodiversity, as stated in our Code of Conduct.
FEAP also welcomes the Nature Restoration Targets under EU Biodiversity Strategy recognizing the importance of restoration of ecosystems as well as improving the natural resources- Good ecological status is a key element for sustainable aquaculture production.
Together with acknowledging the efforts necessary to restore natural habitats, FEAP highlights the complex environmental benefits of traditional extensive and semi intensive aquaculture technologies to maintain wetland habitats in both inland and coastal areas throughout the EU. FEAP also wishes to draw attention to the importance of social acceptance and the support that these aquaculture production systems deliver to create and maintain natural values.
The extensive and semi intensive aquaculture systems, typically meaning freshwater pond aquaculture (most of which are artificial structures) and brackish/marine lagoon aquaculture in Europe, operate as open ecological systems, where the natural and technological processes are in synergy and cannot be separated. As a result of these this farming systems specific nature-like ecosystems are created. Although being artificial systems they are very similar to the natural wetland ecosystems in complexity. It is important to emphasize that aquaculture processes are essential in creating and maintaining the natural values of fishponds and lagoons. These technologies are based on renewing natural resources, so they are also good examples of circular economy.
Besides contributing to the sustainability of aquatic and wetland habitats, fish ponds and lagoons ensure the maintenance of numerous natural values with European importance. Their most significant impact is the support of waterfowls connected to wetland habitats; providing nesting, resting and feeding habitats for many bird species.
In addition to the water-related habitats and species they preserve, fishponds and lagoons also have other, less known, but also significant natural values, including different ecological processes and functions that, for example, could play a significant role in optimizing environmental conditions and reducing the negative effects of extreme climatic events (e.g. drought, rapid temperature fluctuations, etc.). The different benefits of these processes can be identified as “Regulating and maintaining ecosystem services”. The main forms of these: (1) CO2 absorption/Global climate regulation; (2) Microclimate regulation; (3) Air quality regulation; (4) Water quality regulation; (5) Water storage; (6) Water retention; (7) Groundwater recharge.
Finally FEAP also stresses that as active components of fishpond ecosystems, the wildlife of ponds and lagoons have high economic negative impacts for fish farmers. They influence the income of production that – besides the lack of acknowledging the role aquaculture has in maintaining natural values – these impacts are neglected by the authorities and are under-compensated to the farmers. However, insufficient social acceptance of these traditional aquaculture technologies threatens their economic sustainability and, at the same time, their potential to maintain that complex natural values sketched above.
Read full responseResponse to Production rules concerning feed and veterinary parasite treatments in aquaculture and sprouted seeds
17 Nov 2020
The FEAP is the united voice of the European fish farming profession. It promotes the sustainable development of European aquaculture and represents both marine and freshwater finfish farming. This federation is composed of 22 national fish farming associations from 21 countries. All members are European but not all are from the European Union. The members of FEAP placed on the market 2.5 million tons of fish in 2019.
The detailed document attached expresses FEAP's opinion on the Commission Delegated Regulation (EU) draft amending Annex II to Regulation (EU) 2018/848 of the European Parliament and of the Council as regards organic production rules on sprouted seeds and chicory heads, on feed for certain aquaculture animals and on aquaculture parasite treatments on organic aquaculture.
FEAP POSITION
• FEAP cannot support the proposed new text.
• FEAP's members have asked for less restrictive legislation, but in fact the new wording in most situations are more restrictive.
• FEAP notices that the main focus is still on salmon lice treatment, not recognizing parasite infections in many other fish species, and not recognizing parasite infections in different life stages, which for some species includes both freshwater, brackish and saltwater.
• FEAP underlines that taking into consideration the whole lifecycle of the fish, limiting the number of parasite treatments will lead to restrictions to the organic market, since fingerlings in most cases are reared by other companies than the ongrowing ones. Organic fingerlings submitted to two treatments will be hard to sell, comparing to organic fingerlings with no treatments. Hatcheries will not be encouraged to produce organic fingerlings leading to a decline of the organic markets.
• FEAP cannot understand why the treatment of parasite infections in organic is unlike parasite infections in all other organic animals, where no limitation exists.
• From a welfare point of view anti parasitic treatments are important.
Currently the limitation of treatment of parasites in fish is one of the most severe obstacles for making the aquaculture organic business growing for many fish species.
Since the entry into force of 848/2018 will be postponed to January 2022, FEAP suggests not to adopt the text now.
FEAP recommend instead a new round of consultation including also more relevant stakeholders and associations e.g. FEAP and FVE representing the organic fish farmers and fish veterinarians.
Read full responseResponse to Green Recovery for the Blue Economy (tentative)
10 Nov 2020
To meet the European Green Deal objectives at sea the European Commission is setting a vision for a transformation of the Blue Economy under the Green Deal’s axes of decarbonisation, zero pollution, circularity and biodiversity. The European Commission’s Communication proposal aims to reach its objectives by encouraging sustainable solutions, innovative products and services and emerging sectors with high employment potential and low environmental impact. The FEAP shares the European Commission’s view that the Blue Economy forms an integral part of the European Green Deal and that a new approach is needed to develop such economy in a sustainable way through coordinated management. The FEAP acknowledges the prominent role of aquaculture in the Blue Economy alongside other economic activities. However, FEAP emphasises that the Blue Economy, besides marine aquaculture, also encompasses economic activities that take place in freshwater, such as fresh and brackish water aquaculture.
FEAP’s claim
Aquaculture (marine, brackish and freshwater) is part of the solution to meet the objectives in the Green Deal (greenhouse gas emissions, circular economy, biodiversity, and sustainable and resilient food systems).
Arguments
1. The EU self-sufficiency ratio on aquatic products has remained at around 43 % for the last decade and EU’s trade deficit on seafood has increased since 2013 and reached a negative peak of more than 20 billion EUR in 2018. Aquaculture can help close the gap.
2. Aquaculture production demonstrates a high ecological efficiency and low environmental impact.
3. Pressure on land use and freshwater resources are key drivers of biodiversity loss. Aquaculture requires little land and hardly any freshwater consumption.
4. Aquaculture generates a very low carbon footprint.
5. Aquaculture systems convert feed into body mass very efficiently.
6. Aquatic products have health benefits and can play an important role in addressing malnutrition and obesity.
7. Aquaculture provides jobs to women and young people in rural, coastal and in the outermost regions.
8. Aquaculture has clear synergies with other new activities like renewal energies.
9. Aquaculture is compatible with other activities like fishing, nature conservation and tourism.
Initiatives
1. Develop regulatory frameworks and revise existing regulations to address barriers to growth of aquaculture.
2. Create a best practice platform to foster knowledge transfer and closer collaboration among Member states.
3. Strengthen social acceptance and address false perceptions about aquaculture.
4. Establish a competitive level playing field for aquatic products in Europe.
5. Investigate the possibilities to increase the share of circular economy in aquaculture.
6. Allocate physical and environmental space to aquaculture via maritime spatial planning.
7. Facilitate compensatory measures integrating farming of low-trophic species with fish farming.
8. Improve consumer information at sale points to ensure responsible purchasing decisions.
9. Promote holistic innovation and research to implement new aquaculture technologies and to optimize conventional aquaculture systems.
10. Disseminate the natural values and ecosystem services of aquaculture sites (freshwater, brackish and marine) and their role in the maintenance of wetland habitats.
Read full responseResponse to Action plan for the development of EU organic production
23 Oct 2020
The FEAP welcomes the consultation on organic fish farming as the potential of this production paradigm has still to fully develop in the European Union. However, we believe that the objective to increase the organic production by 25% is over ambitious. For many EU countries, a 10 to 15% increase of the organic aquaculture production could be realistic if, and only if, the certification rules are thoroughly revised.
Indeed there are clear conflicts between national legislation on environmental production aspects and EU organic regulation.
Moreover, the sites fulfilling the environmental criteria’s of the Water Framework Directive (WFD) and Habitat Directive are not considered as organic while by the fact of being ‘natural by themselves’ they should benefit from this qualification of ‘organic aquaculture’.
On the other hand, the difficulty for aquaculture farmers of access to sites (licensing) combined with the small size of the market for organic farmed fish means that it is economically unsustainable for the farmers to devote entire sites to organic production, except in Ireland where the whole country has made the choice of producing organic fish.
Additionally, the costs of organic feed are higher because of the difficulty to find the raw materials allowed in the organic method. Furthermore, there is insufficient control on food ‘labelled as organic’ coming from third countries with very little traceability and which is often placed on the market at lower prices than that farmed in the EU. Lastly, the cost of organic certification is constantly increasing.
For these reasons, the FEAP thinks that the following should be reconsidered in the action plan for the development of EU organic production :
- The restrictions that make the organic certification virtually impossible for fish farms in "natural" sites (lagoons, estuaries).
- The organic production conversion method for farms that cannot be completely emptied.
- The regulations concerning simultaneous production of organic and non-organic fish (Article 25c).
- The level playing field for non-EU organic products.
Read full responseMeeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries)
17 Sept 2020 · Exchange of views on the strategic guidelines for the sustainable development of European aquaculture
Response to Fitness Check of the EU legislation on animal welfare
29 Jul 2020
FEAP position on Fish Welfare
The FEAP is the united voice of the European aquaculture producers, representing 22 members out of 21 countries. FEAP represents a wide range of farmed species that include Atlantic salmon, rainbow trout, seabass, seabream, carp, catfish, turbot, cod, sturgeon and meagre.
The FEAP strives to assure the welfare of fish farmed in Europe. Fish farmers are the owners of their fish stocks and are responsible for them.
FEAP’s position :
1) Fish are not a single species but many and with considerable biological differences between them, including welfare needs. Furthermore, fish farming in Europe is a very diverse activity taking place both in marine and fresh waters and using different production systems such as tanks, ponds and sea pens.
2) FEAP promotes a holistic approach to fish welfare in which specific welfare issues must be considered alongside the limitations of the physical farming environment, workers safety, environmental protection, product quality and economic viability.
3) European fish farmers follow rules and regulations on health and animal welfare that apply to fish.
4) FEAP understands that Good Practice at farm level is key to ensuring the adequate welfare of fish and, for this reason, promotes their uptake within the industry.
5) The farming of fish is a young activity when compared to other livestock production. For this reason, even today important gaps exist in scientific knowledge on this matter. FEAP recommends the promotion of further scientific research on fish welfare, in particular welfare indicators. Furthermore, EU Fish Welfare Reference Centres should be created to be tasked with:
a) Consolidating knowledge base and identifying best practices;
b) Identifying and prioritising knowledge gaps possibly activating dedicated research lines;
c) Validating efficacy of best management practices.
6) FEAP considers that when addressing fish welfare, the whole life cycle of the fish has to be addressed.
7) FEAP recognises the importance of adequate training for fish farm workers on this issue.
8) FEAP wishes to highlight that fish welfare should not contribute towards the un-level playing field with respect to other fish products, both imported into Europe or caught by fishing fleets.
9) FEAP understands the relevance of communication to make society aware of how European farmed fish are treated. FEAP is concerned with the misleading communication actions on fish welfare which regularly appear in the media.
Read full responseResponse to EU rules on industrial emissions - revision
21 Apr 2020
The Federation of European Aquaculture Producers (FEAP) fully supports the objectives and means of the European Green Deal. Specifically by taking on and fostering the new growth strategies built in both the Farm to Fork Strategy and the Circular Economy Action Plan that aim to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use.
As the united voice of the fish farming industry, the FEAP wishes to highlight that aquaculture is currently exhaustively regulated and monitored by European Union, national and regional regulations, amongst others from an environmental perspective already covering the great majority of the aspects of the Industrial emissions directive (IED).
Being the aim of the European Green Deal to achieve its objectives in the most effective and least burdensome way, the FEAP thinks that it is not appropriate to include aquaculture into the scope of the Industrial emissions Directive. Aquaculture is not an industrial activity causing significant pollution, and the monitoring and control of effluents and impact from aquaculture on the environment are already taken care of by the existing regulations and directives. The current aquaculture legal framework takes already care of these issues through obligations within the scope of the Water Framework Directive (2000/60/EC), the Marine Strategy Framework Directive (2008/56/EC), the Habitats Directive (92/43/EEC), the Birds Directive (2009/147/EC) and the Environmental Impact Assessment Directive (85/337/EEC), followed by supplementary national and regional rules.
The IED is based on several pillars, in particular on an integrated approach, the use of best available techniques (BAT), flexibility, inspections and public participation (https://ec.europa.eu/environment/industry/stationary/ied/legislation.htm).
The development of additional BAT for aquaculture at EU-level is strongly advised against due to the great diversity of aquaculture (different species, different water use, different techniques, etc.) and completely different potential environment footprint impacts in the different water bodies. Furthermore, BAT and Codes of conduct are already part of aquaculture regulations in most countries.
If aquaculture is included in the revised IED scope its governance will become more complicated with additional unnecessary burdens which is in itself a contradiction to the EU current strategy.
Regardless of the adoption by the European Commission of successive Strategies for the Sustainable Development of European aquaculture, reality is that aquaculture in the European Union continues to be in stagnation since the turn of the century, in strong contrast with sustained growth of aquaculture production at global level (FAO State of World Fisheries and Aquaculture http://www.fao.org/fishery/sofia/en). The main reason for this is the extremely complicated legal framework in which it must develop. The European Commission has recommended to “reduce the administrative burden on aquaculture”, and “to simplify administrative procedures and reduce licensing time for aquaculture farms” (https://www.europarl.europa.eu/factsheets/en/sheet/120/european-aquaculture). The FEAP strongly recommends that the revised Industrial emissions Directive does not play against this objective.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
FEAP embraces the Farm to Fork strategy. This initiative flags several issues that are crucial for a truly sustainable food chain, essential to achieve the goals of the European Green Deal and, furthermore, the UN Sustainable Development Goals in Europe.
The existence of a competitive primary production is a necessary condition if Europe wishes to become less dependent upon food and feed from import, and specifically on aquatic products. Aquaculture is today important in many regions of the European Union, but it has the potential to become a highly relevant source of nutritious, healthy and competitive food for European citizens while providing quality employment in remote areas. However, the current administrative hurdles, the unpredictable licensing system and an unlevelled playing field with respect to imports from developing Third countries are a severe bottleneck for sustainable growth. Therefore, FEAP encourages the European Union to adopt a more efficient approach to governance that will unlock the potential of aquaculture. Aquaculture should be seen a solution to many of the food security, food safety and environmental challenges faced by the European Union.
The demand for aquatic food products among consumers is increasing in Europe. Wild fish catches are at their maximum and overfishing of some stocks limits the fisheries sector to cover this demand. But this growing demand, plus the present market gap, are covered exclusively by imports. Therefore, Europe should look at its aquaculture for the delivery of increasing amounts of healthy and nutritious seafood. The “Food from the oceans”, produced in 2017 by the Scientific Advice Mechanism of the European Commission, concluded that “the greatest and most feasible potential identified for expansion globally of seafood production lies in aquaculture”.
A diet shift to more seafood may contribute to several goals in the Green Deal. As one of the few sectors in the Bioeconomy, aquaculture has the potential to be a global contributor to climate change mitigation, as seafood has a far smaller carbon footprint compared to other animal proteins. It may also relieve the pressure on land areas and on the need of fresh water. Of course, on a local level, it is important to have correct regulations taking into account the carrying capacity of the surrounding ecosystems. In many cases, aquaculture should even be recognised as an ecosystem service provider.
Animal health and welfare are key elements in sustainable aquaculture, important for a positive public perception and for consumers’ confidence in fish products. Therefore, the Farm to Fork strategy should provide means to achieve higher animal health and welfare standards. An improved understanding of factors affecting aquatic species health and welfare is critical. Through anticipatory measures such as vaccines and sanitary measures, adverse health conditions can be prevented, thus limiting the use of chemicals and antimicrobials.
If successful, the aquaculture can become a substantial contributor to the Circular economy, and at the same time less dependent upon resources that could be used as human food.
The adoption of an efficient and competitive food production system approach in the European Union is strongly encouraged. As this evolution is highly challenging, an open and inclusive dialogue between industry, scientists and policy makers is required. Aquaculture is to be recognized as a key player in the Farm to Fork Strategy and a solution to transform the European Union into a fair and prosperous society, with a modern, resource-efficient and competitive economy.
Read full responseResponse to Approval of aquaculture establishments and traceability of aquatic animals
25 Nov 2019
FEAP is the united voice of the European aquaculture producers, representing 22 members from 21 countries. FEAP represents a wide range of farmed species including Atlantic salmon, rainbow trout, seabass, seabream, carp, catfish, turbot, cod, sturgeon and meagre.
FEAP stresses the importance of simplifying all the authorization, registration and documentary procedures provided for by the delegated act, with respect to the many situations encountered in fish farms and not overlapping.This with specific reference to the articles: 7, 23 and 35.
Article 3 stated that aquaculture establishments where aquaculture animals are kept solely for release into the wild shall be required for the approval of their aquaculture establishments. Within the FEAP Fish Health and Welfare Commission, there was a wide discussion and examination noting that several examples of stripping and farming of fish leads to findings and outbreaks of both listed and newly emerging diseases.
Our opinion is that these kinds of fish farms should also be authorized and thereby controlled by the authorities also taking into account the analysis of the risk of spreading diseases.
Read full response