Ornamental Fish International
OFI
Ornamental Fish International (OFI) is the peak international trade association representing the ornamental fish industry since its inception in 1980.
ID: 36098352545-58
Lobbying Activity
Response to Evaluation of the Animal Health Law
2 Apr 2024
The European Pet Organization (EPO) representing the voice of the pet sector in Europe, and Ornamental Fish International (OFI) the international trade association representing the ornamental fish industry - would like to thank the European Commission for affording stakeholders the opportunity to provide feedback on the evaluation of the EU Animal Health Law, i.e. Regulation (EU) 2016/429 on transmissible animal diseases. As a sector, it is very important to acknowledge the importance of such a regulation aiming to tackle transmissible animal disease at EU level and beyond. Several arguments can well illustrate this with, among others: - providing one sole text regrouping the former 40 legislatives acts covering animal health, while tackling both terrestrial and aquatic diseases, aiming to facilitate the handling of transmissible animal diseases for all stakeholders. - introducing a risk-based approach with a disease listing and categorization/ prioritization for EU intervention, replacing the former EU approach whose focus was on eradication rather than on preventive measures. - emphasizing the responsibility of all stakeholders and more precisely for our sector by setting up the registration requirements (if not approval) for all industry operators; introducing a self-declaration document for the movements of aquatics within the EU (under specific conditions); and rules for kept Psittacidae among other species related to identification and traceability....
Read full responseResponse to Protection of animals during transport
21 Mar 2024
Ornamental Fish International (OFI) would like to thank the European Commission for affording stakeholders the opportunity to provide feedback on the updated rules for live animal transport as presented this past December. Ornamental Fish International (OFI) is the peak international trade association representing the ornamental fish industry since its inception in 1980. OFI represents members from more than 30 countries around the world including major import and exporting countries. OFI members represent the full chain of custody of the aquatic ornamental sector from source to destination country including NGOs and other trade associations. OFI members include collectors / fishermen communities, breeders, wholesalers, retailers, importers, exporters, consultants, manufacturers, publishers, plant specialists, freight forwarders, airlines, exhibition companies and even a University department. As the voice of the ornamental fish industry, OFI would like to thank the EU authorities for presenting an exemption of these updated rules for ornamental fish- as per Chapter I on subject matter, scope, definitions and general provisions, article 3. In this regard, as a sector we truly appreciate this exemption that not only acknowledges the high biosecurity measures but also the high standards on husbandry, handling and transport taken by the aquatic ornamental operators to ensure the optimum conditions to transport aquatic ornamental species. Nevertheless, we are surprised to read that this exemption is only granted to ornamental fish if we refer to Chapter I article 3 with the following definitions: 1. animals means animals means live vertebrate animals, cephalopods and decapods; 2. aquatic animals means fish, cephalopods and decapods; Considering the high biosecurity measures and high standards taken by our sector to transport not only ornamental fish but also both ornamental cephalopods and decapods, we kindly invite the EU authorities to consider adjusting the suggested exemption of the updated rules as presented for ornamental fish by either referring to ornamental aquatic species rather than ornamental fish or by inserting a definition of ornamental species that should include ornamental fish, ornamental cephalopods and ornamental decapods. This approach should thus enable to continue acknowledging the specific transport conditions adopted by our sector. Furthermore, by referring to definition, we are concerned to read that there is no clear definition provided for the term economic activity. This lack of clear definition could easily provide an open door for various interpretations and implementation at Member States level but also from concerned stakeholders. As a sector we also welcome the EU proposal that will consider special provisions for aquatic species. In this regard, OFI and its members will surely be glad to assist the EU authorities with this task by sharing its sectors best practices, expertise and experience, and more generally contribute, as relevant, to the development of the respective delegated acts and implemented acts to be developed in the future.
Read full responseResponse to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU
13 Dec 2021
The European Pet Organization (EPO) – representing the voice of the pet sector in Europe- and Ornamental Fish International (OFI) – representing the global aquatic ornamental sector- would like first to thank the European Commission for providing the opportunity to share their respective feedback on the 3rd update of the EU List of Concern as per Regulation (EU) 1143/2014 on Invasive Alien Species (the IAS Regulation).
More particularly, both EPO and OFI would like to raise again throughout this exerice their respective concern and position against the listing of the following species of interest:
• Northern Snakeheads, Channa argus (Cantor, 1842),
• Gambusia affinis (Baird & Girard, 1853), Gambusia holbrooki Girard, 1859, Hakea sericea Schrad. & J.C.Wendl., Koenigia polystachya (Wall. ex Meisn.) T.M.Schust. & Reveal,
• Common Kingsnake, Lampropeltis getula, (Linnaeus, 1766),
• Water Lettuce, Pistia stratiotes L.
For the reasons that we outline in our enclosed response, we consider that a Union wide trade ban on these species is a disproportionate response and does not fully meet the criteria as set under Article 4 (3) of the Regulation (sections d and e).
Read full responseResponse to Implementing rules for registration of aquaculture establishments and record keeping by operators
12 Jul 2021
This statement is submitted on behalf of Ornamental Fish International (OFI) - the peak international trade association representing the ornamental fish industry since its inception in 1980. This statement is being endorsed by the European Pet Organization (EPO), the European umbrella organization for national pet trade associations.
Read full response12 Feb 2020
Ornamental Fish International (OFI) - representing the ornamental fish industry - would like to comment on this draft delegated regulation and more particularly about the current absence of sectors’ reference when referring to the various risks level.
This absence of sectors’ reference does indeed challenge the current provision the ornamental sector has had up to know throughout Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on Member State’s exemption for approval.
Read full responseResponse to Rules on plant passports
9 Jan 2020
The Ornamental Aquatic Trade Association (OATA, UK), Ornamental Fish International (the Netherlands) and the European Pet Organization (the Netherlands) thank the European Commission for affording stakeholders an opportunity to provide feedback. Our organizations represent members of the ornamental aquatic plant sector (which encompasses both pond and aquarium plants).
In principle, we support the aims and objectives of plant passports in maintaining high levels of biosecurity within the European Union to protect plant health. Further, completion of Part B i.e. the Operator’s registration number and Member State country code and the requirement for record keeping for three years, permits an ‘audit trail’ to trace the movement of a consignment within the supply chain, both within the EU and within an individual Member State.
However, we are extremely concerned about the poor timing of this consultation and Draft Implementing Regulation, given that it is likely to cause considerable confusion to an industry and Member States, who are presently adjusting to the new plant passporting regime. Particularly as the timing is less than one month after the new requirements came into force. In our opinion, it also demonstrates a lack of understanding of how the industry operates and the logistics involved, given that most, if not all, operators have to prepare many months in advance. This also has a ripple effect which affects subsidiary companies in the supply chain e.g. packaging, logistics etc.
We would urge the Commission to undertake consultation with industry, before proposing any amendment to the Plant Health Regulation, as the new plant passporting regime is already having considerable impacts on our industry in terms of administrative and financial burdens. Our organizations, together with our colleagues in related sectors, are on the front line of desseminating guidance on plant passports to our members. This is taking considerable resource not only on our part but on the part of Competent Authorities that we are consulting as clear and succinct guidance on the plant passporting regime has not been forthcoming from the Commission. The timing of this consultation, barely a month after the introduction of the new regime, will not inspire confidence either for plant passporting requirements or the regulation which underpins it. We have received numerous concerns and complaints from our members who are being given conflicting information and this apparent “shifting of the goalposts” is hindering our efforts considerably, even though the aims and objectives of plant passports are ones which we broadly support, particularly as they encompass distance sellers, particularly those trading via online third party faciltating platforms such as eBay, Amazon and Facebook.
We therefore urge the Commission to facilitate a workshop with industry in order to gauge a better understanding of how the various sectors within this industry operate, the advance timing required and logistics involved before any changes to the regulation are sought. What all stakeholders require at this time is consistency and clarity, together with sound and definitive guidance from the Commission to avoid the present perceived chaos that this new regime is causing, which would have been preventable if full consultation with all actors in the industry had been sought.
Read full responseResponse to Approval of aquaculture establishments and traceability of aquatic animals
21 Nov 2019
The European Pet Organization (EPO) – representing the European pet industry- and Ornamental Fish International (OFI)- representing the global ornamental fish industry- thank the European Commission for enabling stakeholders the opportunity to provide feedback as per the draft Delegated Act (DA) consultation.
As currently interpreted, this DA would have highly significant impacts on the ornamental aquatic sector, which would result in a considerable administrative burden to such businesses. We therefore ask for clarification from the European Commission on the DA in the following areas:
• We seek an assurance from the European Commission that the derogation for certain low risk businesses e.g. retailers, as provided under Directive 2006/88/EC, will be carried forward. The provisions for such a derogation are as afforded via an Implementing Act given Regulation 2016/429 provides the Commission with such implementing powers.
• We seek clarity on what the extra requirements are for both businesses already registered/authorized as Aquaculture Production Businesses (APB) and for transporters already working under the record keeping requirements as per the relevant welfare legislation.
• We seek clarification in relation to the updated definition of a “closed facility” as to whether, in the main, water discharged to tertiary treatment i.e. the foul sewer, would meet this requirement.
• In relation to a “significant disease risk”, in order to prevent variance in interpretation between Member States (MS) as to what this constitutes, we seek assurance whether this would relate to the movement of species susceptible to Member State/EU listed diseases and where the volume of trade may cause a rapid spread of new and emerging diseases.
• Following an Implementing Act to continue the current derogation for certain low risk businesses. We recommend that for businesses which would fall under scope of the DA and subsequently need to register/be authorized as APBs, that in order to minimize both disruptions to trade and administrative burdens to both Competent Authorities and such businesses, that a twelve (12) month transition period is afforded...
Read full responseResponse to Animal disease notification, reporting, surveillance, eradication and disease-free status
1 Jul 2019
OFI- representing the ornamental fish industry - would like to comment on this draft delegated regulation and more particularly to the section dedicated to "aquatic animals, with the Annex IV- specific requirements as regards diseases of aquatic animals" - with the Annex IV- “specific requirements as regards diseases of aquatic animals".
Read full response29 May 2018
Ornamental Fish International (OFI) - represents the international ornamental aquatic trade industry - with approximately 150 members (including several country based trade organisations that represent many more members) spanning 30 countries. It represents all sectors of the ornamental fish industry including producers, exporters, importers and retailers across various forums including EU institutions, CITES, as well as member interests within their countries. The goal for OFI is to ensure the ornamental fish industry continues to develop in a sustainable manner to ensure the long-term viability of industry and the environment.
The European Pet Organization (EPO) is the European umbrella organization of national pet trade associations in Europe. It today represents ten (10) trade associations in ten (10) countries representing thousands of enterprises many of which are SME’s or micro businesses. Its members are working together with both animal protection and scientific organizations. Its member organizations include for each country: Austria (WKO), France (PRODAF), Germany (ZZF), Italy (VIMAX / AIPA), Norway (NZB), Spain (AEDPAC), Sweden (ZOORF), Switzerland (VZFS), the Netherlands (DIBEVO), the United Kingdom (OATA).
The Ornamental Aquatic Trade Association (OATA) – represents the ornamental aquatic industry within the UK and has approximately 850 members, who span the entire supply chain e.g. importers, wholesalers, retailers, dry goods manufacturers etc. OATA’s aim is to enhance the reputation of our industry by promoting the benefits derived from it, setting high standards, providing good education and training, and encouraging responsible ownership and enjoyment among fish keepers.
OFI, EPO and OATA are in part supportive of the Commission Delegated Regulation (EU) amending the list of diseases set out in Annex II to Regulation (EU) 2016/429 of the European Parliament and of the Council on transmissible animal diseases and amending and repealing certain acts in the area of animal health (‛Animal Health Law’).
However, we also have some concerns over the proposed changes, which are further detailed in the attached supporting documentation.
We welcome further dialogue on this very important topic.
Read full responseResponse to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species
20 Dec 2017
To whom it may concern,
Please find enclosed the joint response from Ornamental Fish International (OFI), in the Netherlands, and the Ornamental Aquatic Trade Association (OATA), in the UK in response to Ref: Ares (2017) 5777844 – Draft Delegated Regulation – Supplementary Regulation (EU) No. 1143/2014 of the European Parliament and of the Council with regard to risk assessments in relation to invasive alien species.
Best regards,
Nathalie Gamain, OFI EU Affairs Officer.
Read full response