The structural tension in UNCLOS when it comes to fisheries access agreements

I’m starting some work on the nature and structure of fisheries access agreements, and while my angle is from an operational perspective, as a born-again UNCLOS nerd, there is so much more to it than rich country A with lots of boats and no fish paying poor country B (generally with surplus fish and fewer boats) to fish in their waters.

So I guess over the next few months, I’ll be using the excess research I’m doing for that job to blog about a few of the many issues these agreements entail… starting with the legal tensions arising between the regulatory frameworks of the flag state and the coastal state.

In the past, I wrote about the geopolitics in fisheries, and access agreements are the most basic manifestation of that… and perhaps the most influential (albeit short-lived) and forgotten agreement was the Kiribati - Soviet Union one in 1985 that brought the USA Purse Seiners to accept and respect the Pacific Island Countries’ EEZ. I wrote about it here

But let's get back to the “tension,” of course. I don’t develop much new thinking myself that hasn't been studied and published before by real experts, and some of them are acquaintances, which I'm extremely proud to know: Camille Goodman and Valentin J. Schatz are the first ones to come to mind… so this blog has a lot of bibliography at the end!

Flag and/or Coastal?

The foundational issue is that the EEZ is legally neither territorial sea nor high seas — it is a sui generis zone where two sets of jurisdiction apply simultaneously to the same space. Under UNCLOS, the coastal State has sovereign rights for the purposes of conserving and managing the living resources within its EEZ (Article 56(1)(a)) and is authorised to board, inspect, and arrest vessels engaged in IUU fishing in violation of its laws (Article 73(1)). At the same time, as a general rule, ships on the high seas are subject to the exclusive jurisdiction and authority of the state whose flag they lawfully fly — a principle of exclusivity firmly rooted in the order of freedom of the high seas. When a foreign fishing vessel enters an EEZ under an access agreement, both jurisdictions claim it simultaneously, and UNCLOS does not fully resolve how they interact[1].

The "due regard" asymmetry

The critical mediating concept is Article 58(3), which requires flag states and their vessels to have "due regard" to the rights of the coastal state when operating in its EEZ. The existing discourse on due regard obligations has primarily focused on the conflicting rights or interests between coastal States and flag States in areas within national jurisdiction. Most commentators read this as an asymmetric, subordinating obligation — it falls on the flag state operating in someone else's EEZ, not on the coastal state in its own zone. This gives the coastal state structural legal prevalence, even if the practical picture is messier.[2]

The ITLOS 2015 Advisory Opinion

The most significant recent clarification came from the ITLOS advisory opinion of the Sub-Regional Fisheries Commission. The Tribunal's starting point was the role of the coastal state, which, "in light of its special rights and responsibilities in the EEZ, has the primary responsibility, and even an obligation, to take the necessary measures to prevent, deter and eliminate IUU fishing." With respect to fisheries in the EEZ, Articles 56, 61, 62 and 73 establish the coastal state's primary responsibility, which includes extensive regulatory and enforcement jurisdiction. However, the opinion did not make the coastal-state and flag-state jurisdictions mutually exclusive. Rather, the flag state retains parallel or concurrent jurisdiction over its fishing vessels in the EEZ. [3]

Recognising the sovereign rights of coastal States to manage and conserve fisheries resources in their EEZs, the Tribunal concluded that coastal States have "the primary responsibility for taking the necessary measures to prevent, deter and eliminate IUU fishing." Nonetheless, the Tribunal emphasised that flag States were not relieved of their obligations. The Tribunal acknowledged the obligation under UNCLOS Article 58(3) to give "due regard" to the laws of the coastal State, and under Article 62(4) for nationals of other States to comply with the laws of the coastal State. As such, flag States have the obligation to effectively exercise jurisdiction and control over the vessels they flag when those vessels are in the EEZs of other States..[4]

The practical implication was that, as coastal State regulation and enforcement have, in many cases, proven insufficient, the focus has shifted towards a parallel, complementary responsibility of flag States.[5]

How the literature assesses prevalence

The scholarly consensus is that coastal state rights are legally primary within the EEZ, but that primacy is qualified in three important respects:

First, 40 years after the adoption of the Convention, there remains considerable uncertainty about the nature and extent of these sovereign rights — particularly how far coastal States can go in imposing conditions on access and in exercising enforcement. Goodman's influential work (OUP, 2021) argues that coastal State jurisdiction over living resources in the EEZ is flexible but functional — consisting of broad discretion, exercisable within functional limits determined by reasonableness and by reference to the balance of rights and interests in the EEZ. Crucially, she also identifies a clear trend: coastal States adopt approaches that "thicken" their jurisdiction within the EEZ, "project" their jurisdiction beyond the EEZ, expand the effect of their jurisdiction through cooperation, and enhance the application of their jurisdiction through technology. [6]

Second, international courts and tribunals are likely to adopt a more generous approach to assessing the reasonableness of the coastal State's prescriptive exercises of jurisdiction, and a narrower, more textual approach to assessing the reasonableness of enforcement jurisdiction. Thus, coastal States have wide latitude to legislate access conditions, but less latitude to enforce them extraterritorially.[7]

Third, there is a live political dispute — most visible at WCPFC — over how this legal primacy translates into allocation. Coastal states have advocated that "all historical catches taken within an area under the national jurisdiction of a CPC shall be attributed solely to the CPC with jurisdiction over that area, regardless of the flag of the vessels that took such catches." In contrast, the EU and some distant-water fishing nations have proposed that historical catch from an EEZ should be attributed to the vessel's flag, even if a foreign vessel within an EEZ took it. This is a direct collision between the legal logic of coastal state sovereign rights and the political-economic interests of distant-water fishing nations, and it remains unresolved. [8]

A note on the critics

Not everyone views the current settlement as satisfactory for coastal states. Generally, the ITLOS advisory opinion places emphasis on the responsibilities of flag States and eludes the question of the primary responsibility of coastal States for the management and conservation of resources. This criticism from the Coalition for Fair Fisheries Arrangements reflects a broader concern among developing coastal states that the "primary responsibility" language cuts both ways — conferring rights but also imposing obligations on states with limited enforcement capacity, while distant-water fishing nations retain practical leverage through access negotiations and economic dependence. [9]

In short, the legal literature broadly concludes that coastal state rights are structurally and judicially prior within the EEZ, but that this primacy is (a) constrained by a reasonableness standard on enforcement, (b) supplemented rather than replaced by flag state concurrent obligations, and (c) contested in practice through the political economy of access negotiations where distant water fishing nations retain significant leverage regardless of the formal legal position.

Bibliography

[1] Deirdre M. Warner-Kramer & Krista Canty, Stateless Fishing Vessels: The Current International Regime And A New Approach, 5 Ocean & COASTAL L.J. (2000). Available at: https://digitalcommons.mainelaw.maine.edu/oclj/vol5/iss2/3

[2] Kim, So & Moh, Youngdawng. (2025). Due Regard Obligations in Areas beyond National Jurisdiction. International and Comparative Law Quarterly. 74. 235-254.

[3] Valentin Schatz (2016) Fishing for Interpretation: The ITLOS Advisory Opinion on Flag State Responsibility for Illegal Fishing in the EEZ, Ocean Development & International Law, 47:4, 327-345, DOI: 10.1080/00908320.2016.1229939

[4] Ford, J. H., Wold, C., Currie, D. & Wilcox, C. (2022). Incentivising change to beneficial ownership and open registers—Holding flag states responsible for their fleets and costs of illegal fishing. Fish and Fisheries, 23, 1240–1248. https://doi.org/10.1111/faf.12677

[5] Valentin J. Schatz (2017), The contribution of fisheries access agreements to flag State responsibility, Marine Policy, Volume 84, , Pages 313-319, ISSN 0308-597X, https://doi.org/10.1016/j.marpol.2017.06.022

[6] Camille Goodman (2021). Coastal State Jurisdiction over Living Resources in the Exclusive Economic Zone (Oxford, Oxford University Press) 2021, ISBN: 97801928g6841,

[7] Goodman, C. (2018). Rights, Obligations, Prohibitions: A Practical Guide to Understanding Judicial Decisions on Coastal State Jurisdiction over Living Resources in the Exclusive Economic Zone. The International Journal of Marine and Coastal Law, 33(3), 558-584. https://doi.org/10.1163/15718085-12323082

[8] Andriamahefazafy, M., Haas, B., Campling, L. et al. (2024). Advancing tuna catch allocation negotiations: an analysis of sovereign rights and fisheries access arrangements. npj Ocean Sustain 3, 16. https://doi.org/10.1038/s44183-024-00055-9

[9] Anaïd Panossian, 2015 Rights and responsibilities of flag states and coastal states in West Africa - CFFA comments on ITLOS Advisory opinion about SRFC request. https://www.cffacape.org/publications-blog/2015/06/09/2015-6-9-rights-and-responsibilities-of-flag-states-and-coastal-states-in-west-africa-cffa-comments-on-itlos-advisory-opinion-about-srfc-request

The Long Arm of the Port: Extraterritorial PSMs and the High Seas Transhipment Problem

A PhD thesis from 2019 rarely makes it to the top of my ever-growing everyday work reading pile, but it does when pretending to be an academic researcher on UNCLOS (after my conversion at the Rhodes Academy), one of my pet topics: transhipments in the High Seas by Longliners in the WCPFC.

That is why Arron Honniball's PhD thesis on extraterritorial port-state measures deserves not only my attention, but that of anyone who thinks seriously about how we govern fishing on the high seas.

What he maps out — methodically, legally, sometimes painfully — is the architecture of something practitioners like me navigate daily: the uncomfortable gap between what a port state wants to do and what international law allows it to do.

Yet it is not a straight line, as Arron's thesis doesn't focus specifically on high-seas transhipment. I therefore used the extraterritorial PS Jurisdiction framework he builds as the lens through which to examine why transhipment is so legally awkward: carrier vessels arriving at port with catch that changed hands in international waters, outside the reach of any port-state inspection that occurred at source.

The distinction he draws between enforcement jurisdiction (what happens at the port, which is territorial) and prescriptive jurisdiction (the rule being applied, which may target extraterritorial conduct) is the heart of it.

That's what makes denying landing to a reefer carrying transhipped fish legally defensible in some cases but exposed in others.

Let me explain why his work matters overall, but for my interest…. especially for high-seas transhipment.

The basic idea of port state measures (PSMs) is elegant in its simplicity: a vessel has to come to port eventually, and when it does, you have leverage. Deny it entry, deny it landing rights, deny it fuel and ice and the ability to offload its catch — and suddenly the economics of IUU fishing become far less attractive. The Port State Measures Agreement (PSMA), which entered into force in 2016, formalised this leverage into binding international law. So far, so good.

But here is where it gets complicated, and where Arron’s analysis cuts to the bone.

The moment a port state tries to go further than reacting to what happened in its own waters — the moment it tries to use port access as a lever to regulate what a vessel did on the high seas, or in another state's EEZ, or in a fishery it has no direct relationship with — it steps into deeply contested jurisdictional territory. This is what Arron calls "extraterritorial" port state jurisdiction (PSJ): the use of port access conditions to influence conduct that happened elsewhere.

And this is precisely the terrain on which high seas transhipment lives.

The transfer of catch from a fishing vessel to a carrier or reefer vessel on the high seas is one of the original sins of fisheries monitoring. It is the moment when the chain of custody breaks, when IUU catch can launder itself in the legitimate supply chain, when the accountability that port state inspections are supposed to provide simply... evaporates.

A tuna longliner offloads to a carrier in a High Seas Pocket. That carrier then steams to a port — maybe in one state, maybe another — and presents documentation for fish that no inspector or intelligence analysis has laid eyes on since it was caught. The fishing vessel itself may never enter a port where a PSM-capable authority is waiting for it.

The transhipment problem is not new… anyone working in Pacific tuna knows it. The WCPFC has wrestled with it for years around the “impracticability exemption” but what Arron's work forces us to confront is the legal fragility of the tools we're using — or trying to use — to fix it.

When a port state refuses to allow port use to a carrier vessel (maybe change crew or to land fish that were transhipped at sea from a vessel suspected of IUU activity), it is doing something legally remarkable: it is effectively regulating conduct that took place outside its territory, by a vessel it may have no flag or nationality connection to, in waters governed by flag state exclusivity under UNCLOS. The freedom of fishing on the high seas is not a platitude — it is a foundational norm, and states that breach it face real legal exposure.

Arron walks through this carefully. The basis for extraterritorial PSMs lies in a mix of treaty obligations (UNFSA's Article 23, PSMA provisions, RFMO CMMs) and the more contested terrain of customary international law. The key insight is that a port state denying landing or transhipment is exercising enforcement jurisdiction within its own territory—at the wharf side or in the lagoon—even if the prescriptive basis for that denial (the rule being enforced) targets extraterritorial conduct. The distinction matters legally, even if it looks academic from the operational perspective.

What this means in practice is that the legal ground under PSMs applied to high seas transhipment is real but limited. A port state can deny the landing of fish that were transhipped from a vessel suspected of IUU fishing or a vessel on the vessel of interest list (VoI). It can refuse port services to a carrier whose documentation doesn't meet the CMMs of the relevant RFMO. It can require prior notification and inspection.

What it cannot do — or at least cannot do without legal risk — is unilaterally legislate behaviour on the high seas and enforce that legislation through port access conditions that go beyond what existing treaty frameworks authorise, hence the importance of having information and compliance-sharing agreements, but also reaching out to port states to be part of RFMOs, even if as cooperation non-members.

The Chilean – EU (2000-10) swordfish dispute is the canonical cautionary tale here. Chile sought to use port access conditions to enforce its national licensing requirements for high-seas swordfish fishing. The EU pushed back hard, arguing that this violated the freedom of fishing and constituted an extraterritorial overreach. The case was eventually settled, but the legal ambiguity it exposed never really went away. Port states with strong domestic fisheries interests, good inspection infrastructure, and political will to act — and there are not many of them — have to calibrate carefully.

So, where does this leave the transhipment problem?

Honestly? In a difficult place. The PSMA's provisions around transhipment — requiring parties to inspect vessels seeking to use designated ports for transhipment — are a real step forward. Several RFMOs have moved toward requiring transhipment in port or at designated anchorages rather than on the high seas. These are the right moves. But enforcement remains patchy, the carrier vessel fleet is heavily concentrated under flags of convenience (or open registries to use the polite terminology), and the high seas remain — as they always have — a jurisdiction of last resort where the flag state's exclusive authority is both foundational and yet frequently useless as a compliance tool.

What Arron's work does, at its best, is provide practitioners and policymakers with a map of what can legally be demanded of vessels entering port and where those boundaries lie.

For those of us working on transhipment reform — trying to make the data systems work, trying to get independent observer coverage on carriers, trying to conduct intelligence analysis prior to notification requirements, and actually inspect what comes off carrier vessels — this is not abstract jurisprudence. It is the scaffolding on which operational tools are built.

The future of PSMs as applied to high seas transhipment almost certainly runs through two things: greater multilateralism (so that unilateral measures reflect shared treaty obligations rather than individual state preferences) and better information systems (so that port state inspectors can actually interrogate the catch history of fishing vessels that pass their fish to a carrier vessel before it offloads).

The legal framework, as Aron demonstrates, can accommodate robust action. Whether the political will and the technical capacity exist to use it — that remains the harder question, and one that no PhD thesis can answer for us.

This blog draws on Arron N. Honniball, Extraterritorial Port State Measures: The Basis and Limits of Unilateral Port State Jurisdiction to Combat Illegal, Unreported and Unregulated Fishing (Utrecht University, 2019).

In tuna fisheries... fuel prices underlie it all.

A bit over a month ago, I wrote about the potential impacts of the then-looming fuel crisis on the tuna industry. Unfortunately, things have not got better.

Source: https://shipandbunker.com/prices/apac/sea/sg-sin-singapore

When analysts discuss threats to global tuna supply chains, the usual suspects appear: overfishing, IUU fishing, climate change, labour standards, traceability gaps, and so on. These are real concerns. But the single biggest disruptor on the desk of every Pacific tuna vessel operator is none of them. It is a fuel invoice.

What began as military strikes between Israel, the US, and Iran has escalated into a full maritime crisis — Gulf shipping attacks, Strait of Hormuz restrictions, and the Houthis re-emerging as a force capable of paralysing Red Sea commerce. Most people read war headlines. Pacific tuna businesses are reading them as cost projections.

Here is the number that matters: Singapore bunker fuel — the benchmark for Pacific fishing fleet operations — was trading at USD 709 per tonne at the end of February. By 10 April, it had reached USD 1,630. Fuel prices doubled in six weeks.

This is not a minor fluctuation in input costs. Fuel accounts for 40 to 65 per cent of vessel operating costs in tuna fisheries. No other single variable comes close. When the Persian Gulf destabilises, Singapore’s crude supply tightens almost immediately — and the Pacific, which depends on Singapore for bunker fuel, feels the impact within days. The distance between a military strike in the Strait of Hormuz and a vessel operator in Majuro delaying departure is shorter than most people in this industry appreciate.

Fish prices have risen in response — skipjack has moved from around USD 1,600 to USD 2,000 per tonne — but nowhere near enough to offset the cost shock. Operators are caught in a margin squeeze with no quick way out.

What does a fleet do when fuel economics break down? It does not stop immediately. The changes are operational and incremental: dry-docking brought forward, port stays extended, departures delayed while waiting for price signals. By the third week of April, contractions were visible. Philippine fleets slowed. Taiwanese vessels lingered in port. South Korean ships returned early, nominally for maintenance. In fisheries economics, these are leading indicators. The supply chain notices them weeks later, often after the damage has already compounded.

The industry that worries me most in this scenario is not the large distant-water fleets backed by conglomerates or state subsidies. Those operations have balance sheets capable of absorbing a prolonged shock, and some have government support mechanisms that effectively socialise the risk. The operations that cannot wait out a six-month fuel crisis are the marginal domestic operators in Pacific Island countries — smaller fleets, thinner capitalisation, higher exposure to local financing costs, and far less resilience to external shocks they cannot influence.

When domestic Pacific fleets stop fishing, the consequences quickly move ashore. Processing plants in the Solomon Islands and Papua New Guinea depend on local tuna throughput. Reduced throughput generally means reduced employment, reduced export earnings, and direct pressure on foreign exchange reserves in economies where fisheries revenues are not marginal — they are foundational. A conflict in the Persian Gulf becomes, within months, a budget problem in Noro, in the Solomon Islands.

For me, this is the structural lesson that Pacific tuna fisheries policy (and surely others, too) struggles to grasp: global seafood systems are energy systems first. We spend enormous effort debating reference points, the use of dFADs, paying for Ecolabels, EM and observer coverage, catch documentation, labour standards, market access, and so on— all of it important, all of it necessary — yet fuel prices underlie everything.

Without affordable fuel, vessels don't move, carriers don’t transport fish, containers don’t get loaded, refrigeration chains become economically unviable, air freight costs escalate, and the access fee negotiations that underpin Pacific Island government revenues look completely different at the table, where distant-water operators factor fuel costs into every offer.

That last point deserves serious attention from Pacific governments. Prepaid vessel-day arrangements currently offer some insulation. But if high fuel prices persist through the next negotiating cycle, operators will build that uncertainty into their pricing. Nobody wants to pay yesterday's access fees against tomorrow's fuel bill.

There is a deeper paradox here. The foreign distant-water fleets that Pacific Island nations have, entirely reasonably, sought to regulate and extract greater value from are, structurally, better placed to survive this kind of shock than the domestic industries those same nations are trying to build. External shocks rarely first weaken the most powerful actors. They weaken the most exposed.

The tuna is still in the water. The vessels can still catch it. The market still wants it. But between the tuna and the plate lies a global logistics and energy system that is becoming increasingly volatile and more expensive to operate. Pandemics, conflicts, sanctions, climate disruption, freight crises — these are no longer exceptional events for Pacific fisheries managers to plan around. They are becoming the baseline operating environment.

The sector is no longer just managing tuna stocks; it is managing volatility. That requires a different kind of thinking from the one most fisheries institutions we work with were built for.

The Fisheries Bill Debate We Should Actually Be Having

I don't get involved in NZ fisheries much anymore, yet up to the late 90s I was part of the industry, then advised regulators and also was an MPI (MoF on those days) research provider working on pelagics and recreational fisheries assessments, and survival rates of returned fish

that is me going fishing here at home in Waiheke island… speaffishing and non motorised troll

Various reasons for me not being involved… firstly, NZ has a lot of good people working on fisheries, then while many people believed that I being a “foreigner” was good as I had no agenda… others had a more “who the fu*k are you?” attitude and they were quite vocal about it. Finally, there was better pay for working overseas.

This is not to say that I don't keep a keen interest in it or that I have no intention of returning to it. In fact, I have used NZ experiences and models in my work overseas and have good friends deeply involved in NZ fisheries at every level. 

In any case, I always get dubitative when I’m asked to comment on NZ fisheries, since you're immediately cornered into a sector or user… doesn't matter what you take is… You are with us or against us… and I hate that shit.  I get accused of being with industry (even if I haven’t worked for industry for over 20 years) or, as I work with government, it means that I’m paid by industry, or as a scientist, I don’t know shit, or as a former UN fisheries officer, I’m part of a conspiracy… and so on

Yet there has been a remarkable amount of noise about the proposed New Zealand Fisheries Amendment Bill. Depending on who you listen to, it is either a long-overdue modernisation of fisheries management, a dangerous weakening of environmental protections, or a total sell-out to industry interests. The problem is that voices are either from a recreational lobby group with the support of massive multinationals with interest in selling trucks, boats and fishing equipment, people involved in making money out of selling spearfishing gear (which I buy) or have a TV fishing program on one side and the minister of fisheries on the other, and that is it

As usual, the reality is more complicated and somewhere in between those poles. So it was great to read a few of my friend Shelton Harley's posts on LinkedIn. Shelton is an avid recreational fisherman originally from Whakatane, but is also a fisheries scientist with over 30 years' experience studying fisheries in New Zealand, Alaska, the western and central Pacific, the Indian and Atlantic Oceans. He obtained his PhD in Canada, where he studied in the years immediately after the infamous cod collapse (and in my opinion, he is part of a group of scientists responsible for the fact that tropical tunas have not collapsed)

I tend to be generally fair with my praise, but he really knows his shit… I would only trust 3 people in terms of NZ fisheries advice, and he is one of them (Adam Langley and Andy McKay are the other 2)

So, based on his writings and my own ideas, here is my take… yet first, I state that I dive into this from a fisheries science and management point of view, not from privacy rights and compliance, so I stay away from the non-science aspects of the bill: i.e., the fines for releasing EM footage

I start where much of the public discussion has focused on headlines—“legalising discards,” “allowing undersized fish to be landed,” “weakening protections.” But also, for me, a key aspect that has not been touched and is buried beneath the politics is some genuinely important questions about how fisheries management actually works in practice, and how it might work better in the future.

The three aspects of the Bill that are particularly interesting to me are: the introduction of multi-year catch decisions and Management Procedures, the proposed changes to discarding rules, and the reform of Minimum Legal Sizes (MLSs). On the surface, these may appear to be separate technical issues. In reality, they are deeply connected by a common theme: incentives.

And in my experience, fisheries management is, in the end, largely about incentives.

New Zealand manages more than 400 individual fish stocks under the Quota Management System. That alone explains part of the challenge. We often talk about “the fishery” as if it were a single entity, but it is really hundreds of small management systems operating simultaneously across species, regions, and fishing methods.

A useful comparison that Shelton does is monetary policy. The Reserve Bank reviews the Official Cash Rate regularly using economic indicators and adjusts it accordingly. Fisheries management operates in a broadly similar way, except that, instead of one OCR, fisheries managers effectively run hundreds of them at once.

The difficulty is scale… only around 20 to 35 catch limits are reviewed each year. At that rate, many fish stocks may go a decade or more without formal reassessment. And it is worth remembering something important: not reviewing a catch limit is still a decision. It is a decision to leave things as they are.

This is where the Bill’s proposals on multi-year decisions and Management Procedures become interesting. At present, catch limits are generally reviewed annually. If the science suggests that a stock needs a significant adjustment but decision-makers prefer a cautious, staged approach, the current system often requires repeating the entire consultation and decision-making process each year. This consumes time, resources, and management attention.

The Bill proposes allowing multi-year pathways to be agreed upon up front. In practical terms, this means a gradual adjustment over several years could be consulted on once, rather than repeatedly.

That may sound bureaucratic, but it matters. Because the real issue here is not simply efficiency, it is management coverage. If structured processes allow managers to deal with more stock more often, that can potentially improve responsiveness across the system.

Management Procedures go a step further. These are essentially pre-agreed rules that determine how catch limits change based on data. In plain language: if the stock looks like this, then management responds like that.

This is not a radical idea. Variants of Management Procedures and Harvest Strategies are widely used internationally, including in some of the world’s best-managed fisheries. We have been dealing with this in the WCPFC for a while now… in fact, and I couldn't give a shit about Ecolables like MSC (I find private certifications neocolonial), but having a Harvest Strategy is one of the conditions.

Environmental organisations and industry groups alike often support them because they reduce ad hoc decision-making and create more predictable, science-based responses; also, and fundamentally, in my opinion, they reduce the space for lobbying and political improvisation.

Of course, no system is entirely automatic. Exceptional circumstances still require judgment. But the principle is important, fisheries management works best when rules are clear before the pressure arrives, not negotiated afterwards in the middle of conflict.

What strikes me about this part of the Bill is that it has attracted relatively little public attention compared with some of the more emotive debates. Yet these procedural changes may ultimately prove more significant in the long term than many of the headline issues.

Because they are really about changing how decisions are made, not simply what those decisions are.

The debate around discards and Minimum Legal Sizes is different. Here, the politics become more visible because the images are more tangible. Undersized fish thrown back dead into the sea tend to provoke strong reactions, understandably so.

The phrase “legalising discards” has circulated widely in criticism of the Bill…but that framing is, at best, incomplete.

Discarding already exists in New Zealand fisheries. Commercial fishers currently return undersized fish that do not count against quota, and Recreational fishers must also release undersized fish, with generally no obligation to retain them.

The important point is that, under the current system, there are situations in which fish are discarded without direct consequences, even when survival rates are low, and this is what we studied already back in 2005.

That matters because incentives matter. If undersized fish do not count against quota when discarded, what incentive exists to avoid catching them in the first place? Particularly in fisheries where post-release survival is low.

This is where the previous government’s policy shift becomes important, and much of the current debate seems to overlook this context. The previous government introduced a principle that fish should only be returned if they are likely to survive. If survival is unlikely, requiring release may simply institutionalise waste, which is actually a fairly logical position.

The current Bill largely operationalises that earlier policy direction by proposing the removal of many commercial MLS requirements, particularly in trawl fisheries where survival rates of returned fish are often poor.

Under the proposed changes, those fish would instead need to be landed and counted against quota.

On the face of it, there is a coherent logic here. If fishers must retain and account for undersized fish, then catching them becomes costly. And if catching them becomes costly, there is a stronger incentive to avoid them.

That is a meaningful change in behavioural incentives.

Yet this is also where concerns raised by recreational groups and environmental NGOs deserve serious attention… Because incentives can cut both ways.

If undersized fish can legally be landed, could markets eventually emerge for smaller fish? Could that alter targeting behaviour over time? I understand why people worry about that possibility.

At the same time, the issue is not quite as straightforward as some of the public rhetoric suggests. Commercial fisheries remain constrained by quota limits. Fishers generally maximise value, not volume alone, and smaller fish often represent lower economic returns.

Besides that small fish are hard to commercialise (and eat!) as commercial fishermen you need to make the biggest return possible for every kilo you catch, and fishing, thanks to mostly the cost of fuel, has never been as expensive as it is now… and if you don’t sell your fish for more money that it costed you to catch it, you’ll be out of business in no time.

So the whole idea that industry will turn to catch undersized fish to send to fishmeal and byproducts where the price is set by the waste of processing bigger fish, would be ruinous to whoever idiotic fishing company try that strategy… so it will not last long.

And while I agree that it is not one at the front of most critics' minds and does not eliminate the risk entirely. But neither does it make the feared outcome inevitable.

And here Shelton’s insight is gold: we are really debating a trade-off between two imperfect systems.

Maintaining existing MLS rules may continue to generate significant waste where released fish do not survive. Removing them may improve accountability and reduce waste, but it also creates concerns about unintended incentives. Neither position is entirely comfortable.

And perhaps that discomfort is healthy.

Too often, fisheries debates collapse into simplistic binaries: conservation versus industry, protection versus exploitation. The reality is usually messier. Fisheries management is full of situations where every option carries risks, costs, and unintended consequences.

What matters is whether the incentives embedded in the system broadly push behaviour in the right direction.

That, ultimately, may be the common thread linking these different aspects of the Bill.

Multi-year decisions and Management Procedures aim to create more structured, predictable management incentives at the governance level. Discard reforms and MLS changes aim to reshape incentives at the operational level.

In both cases, the Bill is attempting to move away from reactive, ad hoc approaches toward systems where behaviours are influenced more directly through pre-agreed rules and accountability mechanisms.

Whether it succeeds is another question.

But the debate would probably benefit from spending less time arguing about slogans and more time examining the incentive structures these changes actually create.

Because fisheries policy is rarely just about fish. It is about the systems we build around people.

And here's the main beef for me: when we get to fisheries policy in NZ… It is a circle of people who are pointing fingers at each other and expecting the other to change, while not offering much in return

Recreational and commercial fishing lobbyists, public servants responsible for fisheries management, politicians, fisheries scientists, and other experts (indeed, whether they are or not) who provide advice we all need to understand the nature and dimensions of fisheries politics in which we operate. 

When you say someone is "playing politics," you're generally trying to criticise or even insult them.

But politics is how people talk about and work out their differences. Politics can't happen without people disagreeing. Politics is how disagreements are discussed and resolved, whether in the family, at work, in government, or in a campaign to parliament

Fisheries politics happen at many different levels. It determines which tools are available to control fisheries and how they affect the environment. It clarifies the connection between extraction and protection. It determines how the catch will be split among groups with different needs.

International rules govern the protection and sharing of migratory and straddling stocks between countries. These relationships are based on political rules and norms. Those who want to have the most impact on how fisheries are handled and used can learn these rules and practise them, not just toxically point fingers

People fish for a job, people fish for fun, and people fish because it is part of their culture, but we're in the same game. We are lucky we can debate in NZ, but I believe each sector's sense of entitlement has taken the debate to toxic levels. We are all using the same resources.

In NZ, we are fortunate to be able to fish for fun and recreation without paying a licence, have access to a commercial QMS, and practise legislated customary fishing. We have so much in our favour, yet we are wasting our time pointing fingers at each other.

This has never been so evident to me than in this debate

Seeing a lot but owning very little

It’s hard not to be compelled by the promises of electronic monitoring (EM) paired with machine learning (ML), artificial intelligence (AI), and edge computing. Cameras and algorithms that never stop, providing near-real-time insights into what is being caught, where, and how.

This article, "Monitoring Fishing Activity on the Edge," which deals with EM and edge AI for longline fisheries, makes its case well. It is forward-looking, technically grounded, and persuasive in its central proposition: that combining onboard processing with machine learning can dramatically improve transparency, reduce review costs, and bring fisheries monitoring closer to real time.

Source: https://www.fisheries.noaa.gov/new-england-mid-atlantic/commercial-fishing/electronic-monitoring-northeast

For those of us involved in MCS and fisheries management, which suffer from delayed, incomplete, and often unreliable data, the idea of near-real-time catch verification is not just attractive—it is overdue. The longline sector, in particular, has long operated in a space where visibility is limited, observer coverage is sparse, and verification is often retrospective at best.

So yes, the technology is promising. But as I read the piece, what struck me was not what it said, but what it did not.

Because the discussion of cameras, models, and deployment strategies is all about data management and processing… but not a lot about who owns it, who controls it, and who ultimately benefits from it.

The article speaks confidently about systems that convert raw video into annotated datasets and about using those datasets to train models capable of identifying species and verifying catch. It gestures towards openness by mentioning publicly available tools and baseline datasets. It highlights efficiency gains and scalability.

The model is compelling:  Raw footage becomes labelled imagery >> Labelled imagery becomes training data >> Training data becomes model weights (the core process of ML- essentially converting massive datasets into actionable knowledge and numerical patterns), and then >> Model weights become products.

At each step, value is created… And at each step, the question grows sharper: where does that value go?

This is not a theoretical concern. It is a structural feature of how ML systems develop; the more data they ingest, the better they perform. The better they perform, the more valuable they become. Over time, the models themselves—refined through exposure to vast quantities of real-world data—become proprietary assets.

In the context of fisheries, that data does not come from nowhere.

It comes from vessels operating in sovereign waters, from fish caught under national jurisdictions, and from fisheries that coastal states here in the Pacific are responsible for managing.

And yet, if the architecture of these systems is not carefully designed, the long-term value generated from that data can easily accumulate elsewhere.

EM deployments, especially when combined with edge AI, are more than monitoring and compliance tools. They are also a data-harvesting system that generates continuous streams of information for monitoring and training increasingly sophisticated models.

If those models—and the datasets that underpin them—are controlled by vendors, then over time, a form of dependency will emerge.

While countries receive improved monitoring in the short term, developers/vendors accumulate data and refine models in the long term… And the balance of value shifts accordingly.

As I wrote in the past, I still struggle to read much about some basics:

• Who owns the footage captured on board?

• Who has rights to the annotated datasets derived from it?

• Who controls the trained models built using that data?

• Can those models be transferred, replicated, or independently audited?

These are not peripheral questions. They go to the heart of what this technological transition means.

Without clear answers, there is a real possibility that image libraries derived from sovereign fisheries become proprietary training sets. That model weights—refined over years of deployment in specific regions—become locked within commercial platforms, and then the countries that contributed the raw material find themselves purchasing back the analytical capability built from their own data.

It seems that along the way, the terms governing data ownership and intellectual property are either left vague or treated as secondary to immediate operational benefits. By the time the system is mature, the structure is already set, and at that point, renegotiating ownership or access becomes considerably harder.

Don’t get me wrong… this is not an argument against EM and the use of edge computing; all the opposite, these tools have the potential to address long-standing weaknesses in fisheries governance. They can improve compliance, support science, and reduce the opacity that has long characterised parts of the industry.

But technology does not arrive in a vacuum.

It arrives embedded in business models, contractual arrangements, and institutional contexts that shape how benefits and costs are distributed. And in the case of EM and AI, those distributions are not always obvious at the outset.

The WCPO provides a particularly relevant context for this discussion, as it is here that some of these systems are being piloted or considered. It is here that the stakes are high—not only in terms of fisheries management, but in terms of economic value, data sovereignty, and long-term control over marine resources.

The narrative, however, remains heavily weighted toward the technological promise these systems are bringing, which is real.

But the parallel narrative—about data sovereignty, intellectual property, and value capture—seems underdeveloped… and this imbalance matters:  If the first wave of deployment proceeds without clear data governance frameworks, the second wave will inherit those assumptions. By then, the leverage to reshape them may be reduced.

This is not unfamiliar territory… data generated in one place, processed in another, monetised elsewhere. Value chains that begin with raw inputs and end with high-value outputs are often concentrated in the hands of those who control the intermediate steps.

The difference is that this time, the resource is not just the fish. It is also the data about the fish. And data, unlike fish, accumulates and compounds. It becomes more valuable the more of it you have.

Without them, transparency, compliance, and even sustainability may improve, but the underlying distribution of value becomes more skewed.

As said, this is a really good article that makes a strong case for what these technologies can achieve.

I would like to see more articles on what they may be doing unintentionally. In the end, with EM “seeing” everything, only part of the story is told; the other part is deciding who gets to own what is seen—and what is built from it.

HS Transhipment mechanism in the WCPFC compared with other tRFMOs

There is a quiet pride in reading a report that lists your name in the acknowledgements. You recognise the arguments, the framing, even some of the technical suggestions. Yet when you read the final published report, what emerges is less a story of progress than one of persistence—of problems that have been known for years and worked on, described in a much better, more sophisticated language than my own, yet still largely unresolved in the WCPO.

ilustrative image only

This ISSF report I’m talking about is the result of the excellent work of Kerrie Robertson & Holly Koehler, and benchmarks the different tuna Regional Fisheries Management Organisations (RFMOs) against the FAO’s 2022 Voluntary Guidelines on transhipment , in which I worked a few years ago.

It is a thorough piece of work; it compares five RFMOs, assesses their performance against dozens of criteria, and reaches a conclusion that is both unsurprising and troubling: none of their regulatory frameworks around high seas transhipments is fully aligned with the guidelines. 

That, in itself, is not the most concerning aspect. Voluntary guidelines are, after all, voluntary. They are also relatively “new”, and the RFMO CMM making and review process is notoriously slow.

The more telling story for me lies in how the gaps are distributed—and nowhere are they deeper or more consequential than in the Western and Central Pacific Fisheries Commission, wich is worth remebering does in pronciple prohibits teanshipmenbts at sea!

As someone who has been working on High-Seas (HS) transhipment reform efforts within the WCPFC. Through research, analysis, extensions and writing quite a lot about the problems we have (in particular the abuse of the impracticability exception), I knew we didn’t align…. But had a limited idea of how bad we were in comparison with the other tRFMOs

The WCPFC manages the world’s largest tuna fishery. It sits at the centre of global tuna supply chains, where volumes are high, distances vast, and oversight inherently difficult. If there is one place where HS transhipment controls need to be robust, coherent, and enforceable, this is it. And yet, what the report reveals is a system that is structurally incomplete.

On the surface, the WCPFC system based on CMM 2009-06 appears functional. It has authorisation frameworks, reporting requirements, vessel lists, and, increasingly, access to data. In fact, the report identifies transparency and data sharing as one of its strongest areas. 

But transparency is not the same as control. It never has been.

The system is better at documenting what has already occurred than at preventing what should not occur in the first place. HS transhipment events are largely validated after the fact, through declarations and reports that arrive days or even weeks later. Observer reports may take months. By the time the information reaches those who might act on it, the fish has already moved through the supply chain, blended into the system, and lost its traceability.

And those of us working on the reform know it is not a technical limitation, but rather an incomplete design choice by those fishing nations that do not want changes to occur, albeit agreeing to stronger measures in the other tRFMOs

The FAO Guidelines place considerable emphasis on risk-based approaches, pre-event verification, and real-time monitoring… which are not abstract concepts but rather elements in the basic architecture of any HS transhipment control system that aims to manage risk rather than simply record it. Yet this is precisely where the WCPFC system shows its greatest weakness.

Verification and risk management remain underdeveloped. There is no systematic process for assessing risk before HS transhipment. There is no consistent mechanism to cross-check what is declared at sea with what is eventually landed. In effect, there is no reliable way to ensure that what is reported corresponds to reality. Instead, the system relies on a combination of declarations, partial observer coverage, and delayed reporting. It functions, but it does not provide control.

Perhaps the most striking gap is the lack of an independent regional observer programme (RoP) for transhipment. Among all tuna RFMOs, WCPFC is the only one without a specifically designed ROP to cover HS transhipments, which is cost-recovered from participants…I wrote extensively about it here.

Observers are present, but the lack of flag-state independence raises questions about consistency, credibility, and, ultimately, the potential for enforcement. In a context where the observer is often the only direct witness to a covered HS transhipment, this matters more than the programme's formal presence. Independence is not a procedural detail; it is the difference between observation and potential verification.

Without independence, data is fragile… and fragile data, even when abundant, fails to support effective monitoring.

The report notes that the data collected—through declarations, observer reports, and logbooks—often lacks the quality and structure needed for meaningful analysis. Key fields are missing, formats are inconsistent, and reporting timelines do not align with operational realities. Information is available, but not necessarily usable.

There is a tendency in fisheries governance to equate more data with better management. I like that this report’s comparative findings could suggest otherwise: data, without timeliness, standardisation, or verification, is not a solution… at best, it offers only a partial description of the problem.

HS transhipment, by its nature, sits at the weakest point of the fisheries MCS world. It occurs far from shore, across jurisdictions, and often involves vessels that can operate in more than one RFMO area and that receive fish from a handful of DWFN-flagged vessels. And if weaknesses in one RFMO are not contained, they propagate across the system, as the same carriers can operate under different regulatory regimes, each with its own gaps and inconsistencies. In this context, the absence of harmonised standards, shared data systems, and coordinated enforcement creates opportunities—not for compliance, but for avoidance.

Reading through the report’s recommendations, one is struck by their familiarity. Improve pre-event notifications. Standardise data fields. Shorten reporting timelines. Introduce independent observer programmes. Strengthen cross-referencing of data. These are not new ideas. They have been discussed, proposed, and, in some cases, partially implemented for many years.

That brings me to the uncomfortable part of the analysis.

The gaps identified are not primarily technical. They are not the result of insufficient knowledge or a lack of available tools. They persist because of the way decisions are made, priorities are set, and trade-offs are accepted.

In that sense, the system is not failing in the conventional sense. It is functioning within the limits that have been collectively agreed—or at least collectively tolerated.

My modest contributions to the report sit within that reality… they do not, in themselves, change the underlying condition.

I’m absolutely guilty of believing that better analysis leads to better outcomes… Sometimes it does… but more often, it simply leads to better descriptions of the same outcomes.

This report is a excellent piece of work. It is careful, balanced, and evidence-based. It acknowledges progress where it exists and identifies gaps where they remain. It does very well what it sets out to do.

What it also does, for me, is to highlight the distance between knowing and doing.

My personal take is that the WCPFC HS transhipment system does not lack information, frameworks, or recommendations… what it lacks is the collective willingness to create a system that consistently prioritises control over convenience, and prevention over description.

As usual, on one side are Pacific islands and a few DWFN allies, and on the other, the DWFN that benefit from the status quo

Until that balance shifts, HS transhipment in the WCPC will remain as it has long been: a space where the system works just well enough to function, but not well enough to fully control what matters most.

The Comfort of Voluntary Initiatives

I always get a reassuring feeling about initiatives like the Ethical Tuna Collaboration (ETC). They signal intent and create a sense of responsibility.

They bring companies, NGOs, and well-meaning actors, many of whom I have known for years and respect, together through the Conservation Alliance for Seafood Solutions, an organisation I served on its board, into a shared space where problems are acknowledged, and solutions are discussed.

My years as a migrant fisherman, albeit a couple of decades ago, my work in fisheries compliance today, and my present research on the labour rights of fishers make me painfully aware that abuses in fisheries are real, persistent, and, thankfully, increasingly visible.

And yet, surely because I come from a compliance angle. I always feel a bit anguished about these initiatives. Not because they are wrong—but because I feel they are incomplete in ways that, in my (surely wrong) opinion, are fundamental.

In response to pressure from consumers and retailers, the private sector and the NGO Ecosystem have stepped in, developing voluntary frameworks, standards, private certifications, and collaborations to improve working conditions at sea. These initiatives foster progress through transparency, dialogue, and incremental improvement.

But they also share a defining characteristic: they largely operate outside the structures of state authority. Governments are the very entities responsible for regulating vessels, enforcing labour standards, and ensuring compliance, yet they are absent or peripheral in these initiatives, surely because they are coming from a different angle, one that is built on goodwill, market incentives, and reputational risk, and not from hard enforcement.

To me,  the issues these initiatives aim to address are not aspirational. They are not “nice-to-have” conditions that distinguish responsible operators from less responsible ones. They are, in fact, basic legal obligations.

For example, timely payment of wages in accordance with contract terms is not an ethical aspiration—it is a minimum standard, and anyone employed by an organisation could take their employer to court for failing to meet it.

The prohibition on fisher-paid recruitment fees is not a corporate commitment—it is a well-established safeguard against debt bondage… which is illegal under international labour law (ILO Convention) since 1930, recognised as a form of slavery since 1956, and reinforced repeatedly since then (last time in the 2014 Protocol to the Forced Labour Convention), which has already 62 signatories (albeit none of the Asian DWFN).

Access to contracts and documentation, freedom of movement, are not innovations—they are embedded in international instruments and most national legislations when you bring foreign workers to work in a country.

If these basics are not met, the question is not whether a company should participate in a voluntary initiative, but for me is far more fundamental:

How is that vessel allowed to go fishing and to sell the catch in the first place?

This is where the distinction between outcomes and causes becomes critical for me.

If I were contracted by a company in Vanuatu to work anywhere in the country, I’d be required, in addition to completing a lot of paperwork, to pay $1,670 USD to obtain the right to work legally there and to receive protections equivalent to those of a Vanuatuan citizen in the workplace. 

Similarly, for China, your cost will be around $800, with all costs accounted for, and again, have protections like those for nationals working with you.

So it angers me that we take it for granted that people in fishing boats should not have those rights, and that this should not be challenged as the basis for buying fish!

For example, the only reason I’m in NZ is that Sanford, the fishing company I was working for, provided me with a work visa, which is required to work on a NZ-flagged vessel, whether in the EEZ or the high seas.  This then allowed me to apply based on my qualifications, work experience and employment to gain residency and citizenship.

So it is possible and can be done… yes, it is expensive, but the cost of not doing it is paid in abuses and forced labour for those less fortunate

Voluntary initiatives may improve outcomes at the margins. They can raise awareness, harmonise expectations, and create incentives for companies to improve. However, for me, they do not address the root causes of labour abuse in fisheries, which stem from structural governance failures.

As the literature increasingly points out, the proliferation of voluntary social responsibility tools in the seafood industry reflects not just innovation but also displacement. Rather than strengthening state regulation, responsibility is diffused across a growing ecosystem of standards, certifications, and collaborations.

The result is what some have described as a “hydra” of initiatives—each well-intentioned and addressing part of the problem, yet collectively failing to transform the conditions that enable abuse in the first place.

At the heart of this problem is a simple asymmetry. Fishing vessels operate under flag states. These states have clear obligations: to regulate working conditions, to enforce labour standards, and to ensure compliance before and during fishing operations. When these obligations are weakly implemented—or not implemented at all—space opens for exploitation.

Voluntary initiatives, as well-intended as they are, do not close that space… they operate within it.

They rely on audits, reporting, and certification processes that, across sectors, have repeatedly proved effective at detecting or preventing labour abuses for a few committed players, but not for the sector as a whole, where the rest lack meaningful worker participation, robust grievance mechanisms, or enforceable remedies.

And crucially, they do not alter the underlying incentives.

A flag state that allows a vessel to reduce costs by underpaying crew, charging recruitment fees, or extending working hours beyond legal limits can still compete—sometimes more effectively—than one that fully complies with labour standards. In such a context, voluntary compliance becomes a competitive disadvantage unless universally enforced.

This is why framing basic labour rights as elements of “ethical” trade is problematic for me. It subtly reframes obligations as choices.

It suggests to me that paying wages on time or eliminating recruitment fees are markers of leadership rather than mere legal requirements. It shifts the conversation from enforcement to excellence by a few…

If the baseline is not clearly defined and enforced by states, then the best outcome—no matter how well articulated by voluntary initiatives—remains “optional”

Close your market, don’t buy fish from vessels flagged to countries that treat foreign workers on fishing boats differently from workers on their territory in terms of immigration and labour rights, and things would change. Require states to accede to the basic ILO conventions as a condition of doing business, and so on….

Yes, this will have implications and costs, yes, it would alter standards, business practices, and so on… but we’ve been here before… no one today would argue not to have official health certification for traded seafood products, the EU has a list of authorised countries and approved vessels and establishments in each country/flag state that is allowed to export. Both the USA and the EU require different forms of non-IUU catch certification (albeit fundamentally different and arguably incomplete). I was working with industry and regulators when these obligations came, and they were argued as “impossible”, and here we still are.

Now, let me be clear: all this rant is not to dismiss the value of collaborations, not at all. There is space for industry-and NGO-led initiatives to complement regulation, pilot new approaches, and accelerate improvements where governments are slow to act.

The experience from other sectors is instructive. Decades of voluntary social governance tools in industries such as garments and agriculture have shown that, while they can improve transparency and mitigate reputational risk, they rarely deliver sustained improvements in working conditions without strong public regulation and worker-driven mechanisms.

Fisheries are unlikely to differ, and in fact, they may be more challenging. The remoteness of operations, the transnational nature of supply chains, and the vulnerability of migrant crews all amplify the risks and complicate oversight.

In such a context, reliance on voluntary mechanisms alone is not just insufficient—it may be counterproductive if it diverts attention from the need for binding enforcement.

I have no issues with voluntary commitments, as long as an equal level of effort is put on governance, compliance, enforcement and government-driven initiatives, such as market access

This should be enforced by flag states before vessels depart; if not, by market states through import controls and due diligence requirements

Which brings me back to first principles. Labour rights at sea are not a matter of corporate ethics. They are a matter of equal human rights, including those of the citizens of the flag state and of immigrants working in their territory and on their vessels, regardless of where they fish.

If a vessel is operating with unpaid wages, debt-bonded crew, or confiscated documents, the failure is not primarily a matter of corporate responsibility. It is a failure of governance.

Voluntary initiatives help illuminate that failure. They can even, at times, mitigate its consequences. But they cannot resolve it.

To ensure that fishermen are treated fairly, it is necessary to fill in the many legal loopholes, ensure that flag nations comply with regulations, strengthen international collaboration, and close markets to those that don’t provide official guarantees.

The protection of fishers' rights and the improvement of working conditions are both dependent on networked multilateralism. Approaches that stem from the bottom up, such as those that involve unions and fishermen, are also fundamental.

The fishers I have worked with for over 40 years are some of the most resourceful, resilient, generous, and positive people I've met… chances are that they wouldn’t be alive otherwise. We owe them the same right we enjoy at land.

Ports as an economic anchor that ties DWFN to concrete places

I read with interest a recent Ocena report, Behind the Fleet: Mapping the Global Network of Service Providers Keeping Distant-Water Fishing Afloat, based on the interesting take they had… For years, the focus has been squarely on vessels—their flags, movements, and compliance or lack thereof.

Yet his reports on the network of service providers that support them are a web of ports, insurers, crewing agencies, fuel suppliers, and ports… and, as someone who works a lot in ports here in the Pacific, I thought it might miss a bit of context, so I will try to provide it in this blog.

Of course, I’m no one compared with the academic credentials of the authors… so my take may not be worth the few minutes it will take to read it, but yeah, here it is in any case.

The report is detailed and technically sound. It clearly maps the infrastructure that sustains distant-water fishing (DWF). Yet as one reads through its pages, a pattern emerges: the system is described primarily through its vulnerabilities.

Service providers are framed as leverage points because they are points of failure—places where oversight can break down, where illicit activity can hide, where governance struggles to keep pace with mobility and scale.

What is largely absent from the narrative, particularly when it comes to ports, is the idea that this system persists not simply because of gaps, but because of relationships that work.

There is, in practice, a form of mutualism between DWFN and the ports and services of developing coastal states—a relationship that is neither accidental nor entirely exploitative, but structurally embedded in the region’s fisheries economy.

The report tells us that ports are “gateways for global catch,” essential for resupply, repairs, crew changes, and landings. It correctly explains that without access to ports, most distant-water fleets could not remain at sea for extended periods.

But if you look at this from the port perspective, a different picture is also valid.

Many port states (which are also coastal states) - particularly in the WCPO - are not just gateways for fish, they are engines of the local economies, places where global fisheries intersect with national development in very tangible ways.

Jobs are created not in reports but in supermarkets, vessel services, and workshops; revenue flows not only through licensing agreements but also through MCS activities, provisioning, maintenance, and logistics. Many “port economies” are key to the countries through vessel arrivals and departures.

This is where the report's narrative feels incomplete to me. It recognises that DWF depend on ports, but it does not fully explore the reciprocal truth: that many ports, particularly in developing countries, have a symbiotic relationship with those DWF fleets.

That dependence is not necessarily a weakness. It is, in most cases, a deliberate positioning; most port states I work with have positioned themselves precisely to attract DWFN they have long-standing relationships with, recognising that geography, proximity to productive fishing grounds, and a safe anchorage can translate into economic opportunity.

Others have leveraged foreign investment, sometimes controversially, to modernise facilities and increase capacity. But this is often framed through the lens of risk rather than strategy.

Yet from the perspective of those states, the calculation is often pragmatic. DWFN bring activity, and activity brings revenue. The challenge is not whether to engage, but how.

This is where the idea of mutualism becomes important, as DWFN require access to places to transship, land and maintain vessels close to the fishing grounds; ports provide that access and, in return, capture a share of the economic value generated by those operations.

Yes, it is not always a fair exchange and is certainly not problem-free, but it is a relationship of interdependence rather than a simple one-sided exploitation.

Seen in this light, ports are not merely control points within a governance system. They are interfaces—places where economic and regulatory logics converge.

They offer services, but they also offer something less tangible yet more powerful: jurisdiction. They are among the few places where DWFN can be physically inspected, documents can be checked, and rules can be enforced with immediacy.

The report acknowledges this by highlighting the shift towards port-based control. But it stops short of fully embracing the implication: that oversight itself becomes part of the services ports provide to the regions they serve.

In practice, this is already happening. All ports in the FFA membership use the FFA PSM Frameworks, while many are also implementing the FAO PSMA, effectively using access as leverage to improve compliance.

This is not a story of passive vulnerability. It is a story of evolving agency.

Emphasising uneven implementation, weak coordination, and governance gaps risks flattening that complexity. It is perhaps easier to see developing-state ports as potential weak links in a global chain than as active participants shaping it; oversight does not fail; it adapts and sometimes strengthens under real-world constraints.

None of this is to dismiss the risks the report identifies. They are real, and in many cases, serious. IUU fishing likes to operate in ambiguity; labour abuses persist where oversight is fragmented; transhipment and bunkering can obscure accountability. The service provider lens helps illuminate these issues in ways that vessel-centric approaches often cannot.

But governance built solely on identifying risk will always be partial. To be effective, it must also engage with the incentives that sustain the system.

Distant-water fishing continues not because it escapes governance, but because it is economically rational within the current structure of global fisheries. Service providers—ports above all—are embedded in that rationality. They do not simply enable fishing; they derive value from enabling it. Any attempt to strengthen oversight must therefore work with that reality, not against it.

This is where the report’s insights could go further. If service providers are indeed leverage points, then the question is not only how to restrict services to non-compliant actors, but how to align the provision of services with compliance itself. How to make it economically advantageous for ports to demand transparency. How to ensure that offering oversight is not a burden, but a competitive strength.

There is, however, another layer that sits beneath both the economics and the governance—and it is one that the report touches only indirectly: geopolitics.

Distant-water fishing nations are not present on the high seas and in coastal regions solely because of fish. They are present because presence itself carries weight. In international practice, and often in unspoken doctrine, “if you have presence, you have rights”—whether formal, informal, or anticipatory.

Distant-water fleets are also instruments of statecraft. Port calls, infrastructure investments, long-term access agreements, and even routine vessel visibility all contribute to placing a nation within a generally uneven geopolitical space… where else can small island countries flex influence over giant world powers?

Tuna fisheries, in this sense, are not only about extraction; they are about positioning and diplomacy (as I wrote here)

This has an important implication. If service providers are leverage points, then constraining or tightening those services will certainly affect how DWF fleets operate. But it is naive to assume that doing so will make those fleets simply disappear.

When strategic, economic, or geopolitical interests are at stake, DWF's efforts do not vanish—they adapt.

The DWF system is not only resilient because of market incentives; it is resilient because it is underpinned by state interests. Removing or tightening enablers may raise costs or change behaviours, but it will not, on its own, unwind the deeper drivers of distant-water fishing presence.

Recognising this does not weaken the case for engaging service providers. It strengthens it. Because it suggests that governance must operate not only at the level of compliance tools, but at the level of strategic alignment—acknowledging that coastal states, port authorities, and DWFNs are all operating within a shared, and sometimes competing, geopolitical space.

In that sense, the most powerful idea in the report is also the least fully developed: that many of these service providers are geographically fixed, operating under national jurisdictions that differ from the flag states of the vessels at sea. Ports are not just a governance opportunity; they are an economic anchor that ties DWFN to concrete places—places with their own priorities, constraints, and ambitions. Ports are the places where DWFN become visible, tangible, regulated and economically meaningful.

Are you a Fisheries Economist with an interest in Transhipment?

Here is a consulting opportunity for you!

My friend Bubba, for whom I have tons of respect, is involved with Sharks Pacific, a well-established NGO that is seeking to engage a qualified fisheries economist and research team to conduct a comprehensive analysis of decision-making dynamics within the WCPFC.

The detailed request for proposals is here, but in summary, this is who you need to be and the team you should assemble. Of course, you can also have me support you as a Pacific Islands specialist with regional expertise and networks.

The primary objectives of the project include the following:

1. Quantifying Historical Economic Losses: Assess the economic losses PICTs have experienced from high-seas transhipment practices over the past 20 years (2005-2025).

2. Calculating Current Opportunity Costs: Compare the economic benefits under current transhipment regimes with counterfactual scenarios requiring in-port delivery.

3. Projecting Future Impacts: Analyse potential economic impacts under various policy scenarios through 2040, including considerations for climate change.

4. Disaggregating Regional Impacts: Evaluate the economic effects at regional, sub-regional, and individual PICT levels.

5. Identifying Policy Pathways: Develop actionable recommendations for PICTs to capture greater economic value through reformed transhipment governance.

The research will address critical questions across revenue dimensions, economic multipliers, infrastructure development, distributional impacts, comparative policy analysis, and climate change interactions. The findings will inform PICT governments, regional organisations, and international fisheries forums, supporting policy reforms to maximise economic benefits and enhance sovereignty over marine resources.

Technical Qualifications of the Desired Team:

The ideal team should comprise highly qualified professionals with expertise in fisheries economics, economic modelling, and regional knowledge of the Pacific Islands.

Key qualifications include the following:

1. Lead Researcher/Team Lead Requirements:

• A PhD in economics, resource economics, agricultural economics, or a closely related field.

• At least 10 years of professional experience in fisheries or natural resource economics.

• A proven track record of published research on fisheries economics, particularly in the Pacific context.

• Advanced quantitative modelling skills, including econometric analysis, input-output modelling, and spatial economic analysis.

• Proficiency in statistical software such as Stata, R, or Python.

• Strong communication skills to present complex economic analyses to non-technical audiences and policymakers.

2. Team Composition (if applicable):

• A senior fisheries economist to lead the project.

• A Pacific Islands specialist with regional knowledge and networks.

• A data analyst or quantitative modeller for handling large datasets and conducting economic modelling.

• A research associate to manage stakeholder engagement.

• Optionally, a climate economist or fisheries scientist can integrate climate scenario development.

3. Institutional Requirements:

• Affiliation with a recognised research organisation, university, or consulting firm.

• Proof of liability insurance and capacity to manage the proposed budget and timeline.

• Experience working with Pacific Island governments or regional organisations is highly desirable.

The team must demonstrate the ability to employ rigorous economic impact assessment methods, conduct comparative and spatial economic analyses, and engage effectively with stakeholders to ensure the research is policy-relevant and actionable.

Are you a Game Theorist Mathematician /Economist with an interest in fisheries?

Here is a consulting opportunity for you!

My friend Bubba, for whom I have a ton of respect, is involved with Sharks Pacific, a well-established NGO seeking to engage a qualified game theorist and research team to conduct a comprehensive analysis of decision-making dynamics within the WCPFC.

Image source: https://mpost.io/glossary/game-theory/

The main aim is to understand how the current institutional design, which prioritises consensus-based decision-making, influences strategic behaviour, coalition formation, and governance results. 

The research will examine the implications of consensus versus voting mechanisms, especially in the context of Pacific Islands Countries and Territories (PICTs) and their sovereignty over valuable tuna resources.

The study will offer practical insights to guide PICT delegations on strategic issues, coalition-building, and potential institutional reforms to enhance decision-making efficiency, conservation results, and fair distribution.

The detailed request for proposals is here, but in summary, this is who you need to be and the team you should assemble. Of course, you can also have me support you in two roles to facilitate your work: an international relations/institutions expert with knowledge of RFMO governance and a Pacific Islands specialist with regional expertise and networks.

Technical Qualifications: The desired team should possess the following qualifications:

1. Lead Researcher/Team Lead Requirements:

• Academic Credentials: A PhD in Economics, Political Science, Game Theory, or a closely related field with expertise in strategic interaction and institutional analysis, along with a minimum of 8 years of professional experience in game-theoretic analysis or institutional economics.

• Relevant Expertise: Proven track record of published research applying game theory to international cooperation, environmental agreements, or natural resource management. Experience with coalition-formation models, voting-power analysis, and knowledge of fisheries economics or RFMO governance is highly desirable.

• Technical Capabilities: Advanced proficiency in game-theoretic modelling, coalition game analysis, voting power indices, and mechanism design. Ability to develop and validate formal models and translate complex concepts into accessible insights for non-technical audiences.

• Communication Skills: Demonstrated ability to explain technical concepts to policymakers and stakeholders, with a history of policy-relevant research and engagement with government officials, negotiators, or international organisation delegates.

2. Team Composition :

• A lead game theorist with expertise in coalition games and voting analysis.

• An international relations/institutions specialist with knowledge of RFMO governance. I can help in this role

• A Pacific Islands specialist with regional knowledge and networks. And this one

• A research associate for stakeholder engagement and interview analysis.

3. Institutional Requirements:

• Affiliation with a recognised research organisation, university, or consulting firm.

• Proof of liability insurance and capacity to manage the proposed budget and timeline.

• Experience working with Pacific Island governments, FFA, or other regional organisations is highly desirable.

The team must demonstrate the ability to employ rigorous game-theoretic modelling, institutional analysis, and empirical methods while ensuring that the research findings are accessible and actionable for PICT delegations and other stakeholders.

Fuel is not just another input in tuna fisheries. It is 'the' input.

Back in my days when I was fishing, the key input cost was crew, 30 to 40%, and I like to think that at that time, we considered it an investment (as opposite of a cost), as we relied substantially less on technology to find and catch tuna; you needed people that knew their jobs… and they expected to be paid for the money they were making for the vessels owner.

not really fuel bunkering in this case… but you get the idea.

For today’s DWF fleets, fuel accounts for up to half of operational costs until a few weeks ago… it would be more now. Change bunker fuel prices, and you do not merely influence fishing vessels' profitability—you alter dynamics and behaviour.

Vessels will need to fish differently, travel differently, and sometimes not fish at all. In effect, fuel prices become an unacknowledged, market-driven control mechanism, one that operates entirely outside the carefully negotiated commercial frameworks between buyers, traders, and canners and even more so, outside the regional fisheries management measures.

Source: https://shipandbunker.com/prices/apac/sea/sg-sin-singapore

And it is bad... In early 2026, very low sulphur fuel oil (VLSFO) prices in Singapore—arguably the benchmark for the WCPO—rose above $500/mt, with some grades increasing even further, reflecting tightening supply and geopolitical disruptions. More dramatically, spot prices in Asia have reportedly surged to over $1,000/mt during recent market shocks, effectively doubling in some cases in a matter of weeks. This level of volatility is not just noise: it fundamentally alters the economics of fishing operations, especially for fuel-intensive fleets like longliners.

The VDS is the central column of the PS activity in the WCPO and is built on the premise that fishing effort can be quantified, allocated, and traded. But it also relies—quietly—on the expectation that there will be consistent demand for those fishing days. When fuel prices rise sharply, demand generally softens, as consumer price elasticity for canned tuna (a commodity) is very limited. As such, fleets become more selective about how many days they purchase and more aggressive in negotiating their prices.

It also involves distribution. Not all waters are equally productive at different times of the year, and as fuel costs rise, vessels will increasingly concentrate on areas with higher catch rates. Some countries may see their waters fished more intensively, while others—less fortunate in oceanographic terms—find it harder to sell their own allocated days. The scheme remains in place but strained.

At the WCPFC level, the effects are no less complex. Higher fuel costs incentivise efficiency, but not necessarily the kind of efficiency that aligns with ecological objectives. FADs will become even more attractive because they reduce search time and, therefore, fuel consumption. Fishing patterns compress spatially, concentrating effort in predictable, fuel-efficient zones. What emerges is not less fishing, but different fishing—driven by economics rather than management intent.

Free school fish (FAD-free) is, in principle, more sustainable and allegedly commands a higher premium price, yet the gap between that premium and the cost of fishing driven by oil prices diminishes, and people may drop the practice altogether. It would be interesting if the war continues and oil prices get even higher; if we are going to see any PS out during FAD closure.

There is, of course, a more optimistic reading. If fuel costs rise sufficiently, overall fishing effort may decline, at least temporarily. But to rely on fuel prices as a management tool would be a unique abdication of responsibility. The benefits, if they materialise, are likely to be incidental and short-lived.

More concerning, perhaps, is what happens at the margins. As profitability tightens, the incentive to cut corners grows. Compliance becomes more burdensome, not less, and the risk of illegal and unreported fishing increases correspondingly. At the same time, distant water fleets—facing higher costs—may push harder in negotiations, seeking lower access fees or more flexible conditions, and usually cut costs on crew conditions, welfare and vessel maintenance.

And yet, within this disruption lies an opportunity—if one is willing to see it. The energy crisis exposes something that has long been implicit: that fisheries management does not exist in isolation from broader economic systems. Fuel prices, like fuel subsidies or market demand, shape behaviour just as surely as catch limits or effort controls. The difference is that, unlike those other variables, fuel has remained largely invisible in policy design.

Bringing this into view would not be straightforward. It would, at the very least, require recognising that economic indicators—fuel costs and profitability thresholds—belong alongside biological reference points in management discussions. It might even involve confronting the uncomfortable question of fuel subsidies, which continue to distort the true cost of fishing.

Under climate change scenarios, fuel price are no longer a background condition. It is a defining variable. And until it is treated as such, the risk is that the carefully constructed systems of tuna governance—so effective under one set of assumptions—become increasingly brittle under another.

For shore activities: reduced PS fishing impacts, transhipment, port services, and processing sectors.

Now, the LL sector in the WCPO is likely to feel the energy shock more acutely than the PS fleet… LL depends on distance, dispersion, and time. The gear uses far more fuel per kg of fish on board than any other gear, and while it targets higher-value species for higher-value markets, it often operates with thinner operational margins.

When fuel prices rise, this model faces immediate pressure because you must also account for the cost of keeping fish frozen. For temperatures from -30 to -60°C for the sashimi market, it also includes the cost of shipping the fish to those markets and the fact that sashimi fish is almost a luxury item, with fine dinning among the first to be affected during any economic crisis. 

At the same time, compliance costs become more burdensome, increasing the constant risk of IUU fishing encroaching at the margins. In a sector already affected by declining catch rates and market fluctuations, the energy crisis not only raises costs but also threatens the viability of the longline model as it currently exists in the WCPO.

And, of course, the most affected are Pacific Island-based industries; for LL, they mainly target the fresh fish market, which is accessed by airfreight, usually with spare cargo capacity on commercial airlines that primarily serve the tourism sector. Their operating costs are directly linked to jet fuel prices, and during crises or when ticket prices rise, demand diminishes as people avoid flying for holidays… a death spiral follows.

Shore processing is very expensive in the Pacific Islands due to economies of scale; electricity costs are high, reflecting that they power production to the levels needed by industry (you aren't going to run cookers, retorts and cool stores off solar panels for now) is based on fuel, and if they want enough to affect their competitiveness, you have the massive increases in the cost of transport… as container ships also run on fuel.

So yeah… if over the next month we don’t return to “normal”, I fear that we will exceed the price elasticity limit, and things will start to shut down… And then they take much longer to start running again.

And if tuna income does not flow into the islands, which are already at the back end of value chains and, because of their economies of scale, they have no capacity to outbid better bidders if fuels become scarce… I really worry about what will happen.

Hope peace prevails again, and the people in charge get their shit together and do the right thing for everyone, not just them.

Galvanic shark deterrent to reduce catch of elasmobranchs in longline fisheries

The idea of electrifying a hook is almost poetic. Not in a dramatic or cinema-like way, but in a quiet, almost bureaucratic manner. A small piece of zinc, pressed against graphite and clipped just above the bait, generated a weak electric field in the water. Not visible. Not outrageous or costly. And yet, it could change some things.

This paper, "Efficacy of a novel galvanic shark deterrent to reduce catch of elasmobranchs in longline fisheries," looks like a technical addition to the growing list of tools that help reduce bycatch. Another study, another gadget, and another percentage drop.

But if you read it carefully, it turns into something else… a story about incentives, selectivity, and maybe even how we keep looking for technological fixes for problems that are really structural at their core.

Let's start with what works, and there is a lot that does.

The concept is quite straightforward: sharks can detect electricity, which most bony fish cannot. The ampullae of Lorenzini help them locate tiny electric fields, so instead of altering the bait, hooks, or depth, which might affect the target species, the idea is to leverage a biological difference.

Create an electrical field and let the sharks get annoyed… and hopefully the annoyance is stronger than the willingness to prey.

The concept of electropositive deterrents isn't new; they have been tested previously. The innovation here is the material — graphite and zinc. Cheap, easy to source, and already recognised by fishers as sacrificial anodes. No rare metals, no magnets that get stuck in gear, no complicated electronics. Just chemistry doing its thing in salt water.

And the results, at least in part, are very interesting. It works very well… when it does.

The figures from the Florida demersal trials are hard to overlook; compared to controls, shark catch rates decreased by 62% to nearly 70%.

That is not insignificant. That is not a gradual process. If such a reduction were implemented widely, it would significantly alter a fishery's bycatch profile.

Most importantly, the deterrent did not reduce the target catch, which is almost provocative. In a few tests conducted in the open ocean, treated hooks caught more target teleosts, such as tuna and swordfish.

That's the holy grail of bycatch reduction: get rid of the unwanted without affecting the wanted.

For once, the trade-off seems to get easier, but nothing in fisheries is ever that easy.

And this is where the paper gets more interesting. In Massachusetts, the deterrent did not deter spiny dogfish, no matter what. Why?

The authors put forward a few ideas:

• Sensitivity that is specific to a species (some sharks have fewer electroreceptors)

• Behaviour when there is competition (when food is scarce, punishment is less important)

• Effects of density (too many sharks, not enough time to choose)

Which is very logical and sensible, but together they point to something more important: there is never a one-size-fits-all answer; always, one answer depends on something else. So yeah, it works, but only in certain ecological contexts, with specific species, and under particular behavioural conditions.

This is, of course, how fisheries work.

Then there is the question that always comes up with promising trials: Is it possible to use this?

It appears that the deterrent effect only functions at close range; the electric field diminishes rapidly—possibly within half a metre—and is not very strong with sharks, which are not generally patient predators. I smell/taste first, then decide whether to bite… they generally go for it.

Hence, the deterrent needs to be in each hook, not one for a basket or a set… One for each hook…. And that in today’s pelagic longlining practices… is a LOT of hooks… let’s say above 3000 per set!

And each of them will need checking, replacing the zinc if needed, and time to do it… all by hand, and considering that we are inferring these days that most longliners are working above 18 hrs… either they put more crew on, or they ask the crew to work more hours… And we know they'll choose the 2nd option!

And this is where many good and promising ideas quietly fail. It's not that they don't work; it's that they don't fit well into the way fishing works.

And then the key question is: what is the big problem we are trying to solve?

Of course, it is presented as a conservation tool, on the one hand, because it reduces shark bycatch, supports sustainability, and addresses declining populations.

On the other hand, it is clearly stated that it will help reduce fishing costs: less gear damage (assuming metal tracers are not used), less time spent handling… But it is not that the crew get paid by the work effort they do… They are on board and work as commanded… not by the hour.

Today's longline is a numbers game. I have written about it in the past, in 1993/4 when I was fishing these waters, it was the heyday of LL in the WCPO, peaking at 5000 vessels. Today, as you can see here, only 1/3 of that fleet (1600) remains, yet they are soaking almost twice as many hooks. How can that be possible? Deck and gear setting technology is almost the same… response: overworking the crew, duplicating the workload, and obviously having as many hooks in the water as humanly possible (literally).

The more hooks are available for the species you want to catch, the more you will catch… thanks to the mess that the squid fishery in the SE Atlantic is…. Squid (the main bait is cheap chips)

This is where things get interesting: generally, conservation won't be the main reason people adopt bycatch minimisation strategies (e.g., for sharks or seabirds).

It will be efficient, which is at once the issue and the answer… efficiency is what caused the bycatch problem in the first place.

Longline fisheries are already highly efficient. They have been refined over decades to maximise fish catch, minimise costs, and operate on a large scale across vast ocean areas... and have been pushing the economic limit for some time now... personally, I believe subsidies and geopolitics are what are keeping the current figures in place.

If we develop technology that promises to make longline more selective, that's really good, but it is not neutral.

Because efficiency doesn't happen on its own. It works with effort, incentives, and market demand. If you catch fewer sharks per hook, one of two things happens:

1. The same amount of work has fewer negative effects (the best-case scenario)

2. Or effort and catch increase as the fishery becomes more efficient, as crew costs are fix (the less discussed scenario)

The paper, as one would expect, does not go there.

In any case, this study doesn't just give you a tool; it also shows you where to go.

It says that:

• A better understanding of biology can help with selectivity.

• Simple, cheap solutions might work better than complicated ones.

• Behavioural ecology can be used in real-life fisheries.

And maybe most importantly:

Regulation doesn't need to be the only solution to address bycatch issues. Some solutions can arise from incentives that work together. If vessels can catch more tuna and fewer sharks at lower cost, adoption makes sense and isn't burdensome.

As in other aspects of fisheries, the problem is not with technology; it's with the system.

Every year, unless they are specifically targeted, sharks are accidentally caught… a shark caught on a hook means one less tuna on board, and if we didn’t have a grey zone due to regional demand and the fact that crew is now a commodity on board for almost 24 hours, the solution would lie in the benefits of selectivity… but we are not there yet… no matter how smart a piece of zinc and graphite is, that doesn't change.

Yet it can reduce harm at the edges, and sometimes that's all it takes to make a difference... In my experience, apart from a few exceptions, that's how fisheries change: not through big moves, but by making small, beneficial adjustments that accumulate over time and transform the system from the inside out.

dFADs as Abandoned, Lost or Otherwise Ddiscarded Fishing Gear (ALDFG),

As you may know, I have a strong interest in dFADs and have written ad nauseam about them.

In a recent post—“We need to start seeing dFADs as a waste crisis in the WCPO”— I describe the unsettling feeling of watching a “slow-motion train crash” unfold in a fishery that, on paper, is otherwise a global success story. The stocks are stable. IUU is controlled. Labour issues are—slowly—being addressed.

And yet, between 40,000 and 60,000 move silently across the WCPO—many of them untracked, unaccounted for, and largely unmanaged at the end of their life.

That number alone should force us to reframe the conversation.

While it would have helped me a lot to read this FAO/IMO report on abandoned, lost or otherwise discarded fishing gear (ALDFG), it helps, perhaps unintentionally, to sharpen this reframing.

The anatomy of a problem we pretend not to see

Let's get the basics right: dropping or retrieving a dFADs fits inside the definition of fishing and is considered as such; therefore, dFADs are fishing gear, and as such, they can be seen as part of the ALDFG ecosystem

Section 2 of this report does something deceptively simple: it dissects the term ALDFG. It pulls apart the acronym—abandoned, lost, otherwise discarded—and in doing so exposes the uncomfortable ambiguity that has allowed the issue to persist in regulatory limbo.

Fishing gear, we are reminded, is not trivial. It is capital.

Similar to FADs, these are expensive tools that often represent a significant investment. So why are they left behind? The answer is not singular, and that is precisely the problem.

Some FADs are abandoned—left deliberately, often under duress…. But basically, a calculation that recovery is not worth the risk. Some FADs are lost—a casualty of currents, conflict with other gear, or simple bad luck. And some is discarded—quietly, rationally, economically—because disposal at sea is cheaper than doing it properly.

Each category carries a different moral weight, but the impacts do not care about our semantics. A FAD that is “lost” is just as impactful as one that is "discarded". The distinction matters legally; it does not matter ecologically.

And here lies the first uncomfortable insight: ALDFG is not a single problem. It is a spectrum of behaviours, incentives, and failures.

The report is refreshingly honest about this. It acknowledges that some forms—particularly accidental loss—are inherently resistant to regulation. You cannot legislate away storms or untimely damage or technical failures. But others—especially deliberate discarding—are entirely within human control.

Which raises the obvious question: why do we deal with them so slowly?

Because dFADs do not fit neatly into those categories.

• They are deployed with the expectation of partial loss.

• They are tracked—until they are not.

• ·They are used efficiently—until they drift beyond economic reach.

At some point, every dFAD transitions from asset to liability. And at that exact moment, the system quietly lets go.

Was it abandoned? Lost? Discarded? Legally, it matters. Operationally, it does not.

And unlike many other gear types discussed in the report, dFADs are not marginal. They are central to the modern purse seine fishery. Their scale is industrial. Their lifecycle is, by design, incomplete.

Which leads to an uncomfortable conclusion: dFADs are not just fishing gear that ends up as waste. They are, structurally, a waste-generating system.

The efficiency paradox

The FAO/ILO questions: why would fishers abandon valuable gear? With dFADs, the answer is brutally clear: because efficiency demands it.

FADs have transformed tuna fisheries by dramatically increasing catch efficiency. They reduce search time, stabilise operations, and generate substantial economic returns. As I have noted elsewhere, the return on investment of a single buoy can be extraordinary.

As I put it, “this is the bill for the massive increase in efficiency that FADs brought to the PS fishery.” and is one that is:

• Not paid by the vessel.

• Not paid by the flag State.

• Not even fully paid by the market.

It is paid downstream—by ecosystems, by coastal communities, and by small island developing States that find these objects washing ashore, entangling reefs, or simply accumulating as marine debris.

back in the days

A regulatory toolbox that wasn’t built for this

Section 4 of the FAO/IMO report opens the “regulatory toolbox.” It is comprehensive, logical, and—on paper—reassuring, yet is where the tone shifts from diagnosis to possibility. And here, the irony becomes almost painful: the legal tools already exist.

Command-and-control rules? Available.
Liability regimes? Conceptually straightforward.
Impact assessments? Routine.
Voluntary measures? Abundant.

But here is the problem: most of these tools assume discrete events. dFADs are different.

They are not exceptional events; they are systemic flows. Thousands are deployed, drift, fragment, beach, or disappear every year as part of normal operations.

This is why enforcement struggles. MARPOL Annex V, for instance, clearly prohibits the discharge of plastics, including fishing gear. But as the report notes, enforcement at sea is inherently weak, especially across a dispersed fleet.

And in the WCPO context, we already know this story: rules exist, compliance is partial, and the gap between intention and reality remains stubbornly wide.

Because most of these tools share a common flaw: You cannot meaningfully regulate reality with rules designed for accidents.

These tools regulate behaviour without fundamentally changing incentives. They tell fishers what they should not do, but rarely make it economically irrational to do it.

This is where Section 4.4—market-based mechanisms—quietly emerges as the most promising, and perhaps the most underutilised, pathway, which reassures me on my bod idea in the FAD workshop blog I wrote before.

Seeing dFADs for what they are

In that blog post, I make a conceptual leap: dFADs should be treated as a waste problem rather than just a fisheries management issue.

If dFADs are waste, they should be treated as waste. Which brings us to deposit-refund schemes.

Imagine this: every dFAD deployed carries a deposit—attached to the buoy, the structure, or both. That deposit is only recovered when the dFAD is either retrieved, accounted for, or demonstrably transferred into an approved recovery or recycling pathway.

Suddenly, the economics change.

A drifting FAD is no longer just a lost opportunity—it is stranded capital. A beached FAD is not just debris—it is recoverable value.

A community that retrieves a FAD is not cleaning up someone else’s mess—it is participating in a reverse logistics system.

This is the essence of the polluter pays principle—not as an abstract legal doctrine, but as an operational reality.

And crucially, it does something that traditional regulation cannot: it works even when no one is watching.

From invisible losses to traceable assets

We do not even know exactly how many dFADs are in the water. That uncertainty is not incidental—it is foundational to the problem.

Deposit-refund systems, by necessity, require traceability. They force the creation of registries, tracking systems, and accountability chains. In doing so, they generate precisely the data that is currently missing.

They transform a diffuse, invisible flow into a measurable system. And once something is measurable, it becomes governable.

The economic discomfort of obvious solutions

The FAO/IMO report ends with a quiet truth: the choice of tools is not legal, but economic and political.

Applying deposit-refund systems to dFADs would not be technically difficult. The technology already exists—satellite buoys, tracking databases, and fleet reporting systems.

What is required is a shift in perspective:

From seeing dFADs as tools of production to seeing them as products with a lifecycle.

From treating loss as inevitable to treating it as a cost to be internalised.

From regulating behaviour to redesigning incentives. But dFADs are not a natural disaster. They are a designed system, operating exactly as its incentives dictate.

Which means they can be redesigned, and the FAO/IMO report sets out the legal framework.

Because once we accept that dFADs are not just fishing gear but industrial-scale drifting waste, the policy response becomes not only clearer but also unavoidable.

The Pacific has always been a place of movement—currents, migrations, trade winds, history, colonialism, and boom-and-bust cycles.

Now it carries something else: the externalities of fisheries efficiency.

The question is no longer whether we understand the problem. It is whether we are prepared to make waste visible—and make the responsible pay for it, but not as punishment, but as rent for fishing here.

The Roughest Form of Ballet: Masculinity and Risks on Tuna Fishing boats

At the end of 2024, Victoria M. Syddall, the author of the paper I’m sharing here and with whom I had previously collaborated on her work on gender and fisheries, approached me for an interview for a scientific paper she was writing.

Her pitch immediately attracted my interest, as her research took a bold step beyond her prior work on power and gender imbalance in tuna fisheries, which has driven important reforms, especially in small-scale fisheries

I know… safety gear wasn't a thing at the time…. You can be more, but not less than your fellow crew… particularly for me as the only part-white guy on board

The paper she co-wrote with Karen Fisher, “Exposing multiple masculinities across hierarchies and performance and experience of risk-taking on-board tuna longlining vessels in the WCPO”, investigated something we have long known but rarely articulated in industrial tuna fisheries generally, and in fishing boats specifically: men are not a uniform block of power.

I just read the paper and was pleasantly surprised to see that many aspects of our conversations, many of my direct quotes (under “participant, online” and anyone who knows me will recognise them), and even some blog entries are included in it.

The key issue she brings up, and that I fully endorse, is that masculinity at sea is divided, racialised, contractualised, and deeply shaped by hierarchy. Some men command. Some endure. Some just don’t handle it and leave the fishery, or in a few extreme cases, don’t make it back.

Drawing on empirical research in Fiji’s longline fishery and conversations with people like me, the authors explore how multiple masculinities are performed, negotiated, and policed on board vessels.

They reject the familiar image of the “hard-bodied, risk-taking fisherman” as the universal male archetype. Instead, they reveal a layered world where nationality, rank, contract type, vessel flag, race, and class intersect to determine which men are visible, which are expendable, and which are protected.

At sea, hierarchy is spatial. Your rank determines the amount of space you have, which bunk you sleep in, the workload you have, your exposure to risk, and, of course, your pay.

The captain and engineer — often aligned with the vessel’s ownership nationality or flag state — hold authority. Beneath them sit officers, mates, bosuns, and deckhands, with the lower ranks frequently recruited from Southeast Asian or Pacific Island communities under markedly different contracts. Two men may stand side by side hauling the same line, yet one is paid more, housed better, and treated as belonging, while the other is perhaps more disposable

Masculinity, in this context, is more than just an identity.

The paper frames this through intersectionality—not as an academic flourish but as an analytical necessity. Risk at sea is not evenly shared. Some men are expected to display physical strength and endurance; others are stereotyped as compliant and low-skilled; still others are burdened by racialised assumptions that influence discipline and surveillance. Masculinity becomes both performance and constraint. It can elevate a man within a hierarchy—or trap him in it.

The authors’ risk framework is especially persuasive. They utilise disaster risk scholarship to conceptualise vulnerability not as weakness but as exposure influenced by thresholds, stressors, pre-existing conditions, and outcomes.

On a tuna longliner, these stressors are constant: long voyages, isolation, hazardous machinery, sleep deprivation, unpredictable weather, market pressure, and hierarchical discipline. However, vulnerability is heightened when these physical risks intersect with unstable contracts, language barriers, withheld wages, or the inability to seek redress.

This is where the paper challenges the dominant gender narrative. The authors argue that much of what has been described as “labour abuse” or “human rights violations” also amounts to gender-based violence of men against men.

Debt bondage, forced labour, physical assault, psychological intimidation, wage withholding, racial humiliation — these are not gender-neutral issues simply because the victims are male. They occur within masculinised spaces, reinforcing norms of dominance, toughness, and a “just deal with it” attitude.

And “just deal with it” is key.

The dominant narrative of masculinity — stoicism, endurance, resilience — conceals vulnerability. A man injured at sea may lose not only his job but also his standing in his village. A crew member who reports abuse risks ostracism or losing his employment. Some deaths are recorded as “fell overboard.” Others remain ambiguously documented. The paper highlights how migrant and low-ranking crew can be highly visible as potential troublemakers, yet invisible when it comes to welfare and protection.

The policy analysis is sobering, and as I have mentioned in my work many times, despite the widespread discourse on human rights within fisheries governance, gender issues remain largely absent from the strong framework of tuna regulation. UNCLOS, the Fish Stocks Agreement, and the FAO Code of Conduct — none of these explicitly address gendered labour dynamics at sea. Even where labour standards exist regionally, they have been slow to become legally binding and even slower to explicitly incorporate gender or Gender-Based Violence considerations.

While the FFA HMTCs and WCPFC Labour CMM have made steady progress on crew labour standards, the gap between resolutions and enforceable measures reveals a structural delay. Meanwhile, masculinised vessel cultures persist within fragmented oversight regimes.

The authors are not suggesting that attention to the “traditional take on gender” should decrease. Instead, they argue that gender equality policy must become relational. If we overlook how masculinities are constructed, rewarded, and punished in fisheries, we end up reproducing the very hierarchies we aim to dismantle.

One of the most notable contributions of the paper is its typology that links hierarchy, risk, resilience, and amplifiers. Crew hierarchy intersects with labour sourcing patterns and vessel flags. Distant-water fleets with long voyages and few port calls are associated with higher forced labour risk indicators. Contract opacity increases economic vulnerability. Cultural narratives about “strong Pacific men” or “cheap Southeast Asian labour” reinforce both exploitation and silence.

Masculinity at sea is therefore neither inherently powerful nor inherently oppressed. It is contingent. A captain’s authority is not the same as a deckhand’s endurance. A racially aligned senior officer may be protected by ownership ties; a migrant crew member may be subjected to both economic and physical coercion.

Importantly, the paper also places these dynamics within social-ecological systems. Tuna fisheries are not just extraction industries; they are embedded in coastal communities where remittances, status, and social expectations circulate. A man’s ability to provide sustains household resilience. When injury, unpaid wages, or disappearance disrupt that flow, vulnerability spreads outward.

There is an uncomfortable clarity here. Tuna fisheries are often discussed in terms of stock assessments, CPUE, and compliance regimes. Yet beneath those metrics are embodied hierarchies. The choreography on deck during fishing —described by my quote

“You need to have your game on; if you fuck up, someone else pays the price. This is because everything is connected and moving. Fishing is the roughest form of ballet you can imagine; choreography has to be impeccable on board because the consequences of mistakes are bad, life-threatening if anyone is slacking, and the others will let them know real fast”

Fishing depends on disciplined, ranked performances. When one body falters, another absorbs the risk.

And adapting to that structure is not easy for everyone. Here again, my words come up:

I think that of the guys I fished with, including myself, are what you call today “on the spectrum” (Autism Spectrum Disorder - ASD), and in my case, also dyslexic, which was seen as dumb, suggesting that, as a big man, I should pursue a career in fishing. And while fisheries have been described quite rightly as a microcosm of society, vessels are a bit different: they are small, unique societies comprising socially excluded individuals. In this sense, you can argue that tuna fishing boats are socially inclusive, as they employ men who struggled to find work elsewhere.

The authors conclude that meaningful gender-transformative policy must engage with multiple masculinities. That means recognising migrant men as rights-bearing workers, not just labour inputs. It means integrating gender explicitly into crew welfare measures. It means collecting disaggregated data that goes beyond binary categories and token inclusion. It also means confronting the fact that industrial tuna governance has privileged economic efficiency over social equity.

And in that aspect, I really appreciate that Victoria and Karen’s paper neither romanticises nor demonises fishers. It explores our complexities.

And perhaps its most crucial contribution is that, in tuna fishing across the WCPO, men are neither simple heroes nor uniform oppressors.

They are positioned actors within complex systems of power, race, contract, and hierarchy. If fisheries policy continues to treat them as a single, invulnerable group, it will continue to fail to recognise the structural conditions that influence both their exploitation and resilience at sea.

In a sector increasingly scrutinised for human rights abuses, this analysis emphasises that gender is not an afterthought. It is essential to the organisation of labour, risk, and value in the global seafood economy.

And until governance frameworks recognise that… the “choreography” I was quoted with will continue — precise, disciplined, and too often unforgiving.

my take on the IMO Cape Town Agreement Impact on IUU fishing

I walked away from most social media a few years ago (I only maintain Bluesky and LinkedIn), yet I have had a few non-fishing acquaintances telling me I just read that “a new agreement is going to help finish IUU fishing”… so I thought that I could unpack what the IMO Cape Town Agreement really can (and cannot) do, at least from my operational perspective,

So as usual, hype overruns reality… The Cape Town Agreement  (CTA) is not a fisheries instrument — and it was never meant to be.

But dismissing it is not fair, and leads to missing its deeper structural potential.

Let’s start with the premise that signing an agreement (which, after all, is a piece of paper) does mean that the problem it addresses is over… it only means that, as a signatory, you now have responsibilities and standards to meet.

Generally, international bodies adopt the language of an agreement over the years, and once agreed, they set a minimum threshold for accession by IMO member countries before it enters into force, meaning that those that have ratified it need to comply with it.

The CTA (adopted in 2012 under the International Maritime Organisation) updates and modernises the 1977 Torremolinos International Convention for the Safety of Fishing Vessels and the 1993 Torremolinos Protocol.

The CTA was to enter into force 12 months after at least 22 States, collectively representing 3,600 qualifying fishing vessels - typically ocean-going ships operating on the high seas - consent to being bound by the treaty. With the recent accession of Argentina, the total number of Member States has reached 28, and, crucially, the sum of 3,754 vessels of 24 metres or more in length.

The CTA core purpose is to set minimum requirements for Safety standards for fishing vessels ≥24m, in relation to construction, stability, life-saving appliances, radio communications and fire protection, among others as well as setting up mandatory certification and inspection, as well as stronger flag State obligations (yet with the caviat that is applies only to the 28 that are contracting states of the agreement, so far Argentina, Belgium, Belize, Congo, Cook Islands, Croatia, Denmark, Finland, France, Germany, Ghana, Iceland, Japan, Kenya, Namibia, Kingdom of the Netherlands, New Zealand, Nicaragua, Norway, Peru, Portugal, Republic of Korea, Saint Kitts and Nevis, Sao Tome and Principe, Solomon Islands, South Africa, Spain and Vanuatu)

CTA is about the safety standards for fishing vessels above 24m for flag states that are contracting states to the agreement… is not about fishing… but

It raises the cost of being flagged to some open registries

Some open registries (flags of convenience) are associated with states that typically exhibit high levels of IUU events. They are attractive because of their minimal or non-existent requirements for fisheries compliance monitoring. Additionally, they accept substandard vessels in terms of safety (as good, safe vessels are expensive), and often have poorly documented ownership structures behind numerous shell companies, making it difficult to identify responsible parties if problems occur. Regulatory fragmentation also exists, as aspects such as MARPOL compliance and minimal manning standards—such as qualifications and international equivalents required to be a captain or second mate—are convoluted. The key selling point of open registries is their weak flag control, and in many cases, they also function as fiscal paradises, as detailed here.

The CTA imposes more stringent requirements regarding identification and documentation, proper vessel certification, surveys, and inspection routines, which implies recognised flag State oversight. In other words, it obliges vessels to operate within a system of greater transparency than at present, which, in turn, can assist fisheries prosecutions.

Yet again… it would only apply to the countries that are parties to the agreement… and I'm encouraged to see that open registries with low levels of fisheries compliance, such as Belize and Vanuatu, are part of it…. Yet this is a small % of flag states

Does it strengthen port and coastal leverage?

A lot is being said that the CTA complements instruments like the FAO Port State Measures Agreement (PSMA) and the ILO’s Work in Fishing Convention. Yet let’s digest this a bit from the operational side.

Now, as explained before… those agreements are also only compulsory for states that have become parties to it (25 for C188 and 108 for PSMA)

From the PSMA side, the port states that the parties have the right to require vessels arriving to provide information 72 hours in advance, and then conduct intelligence and, as a result, use tools such as deny entry, deny port use, inspect, detain, etc.

However, as a fisheries authority, we cannot take direct action if a vessel lacks a valid safety certification, fails to meet compliance standards, or is structurally non-compliant. The best approach is to collaborate with the official body in the port states responsible for maritime safety, and hope their legal structure and resources can do something about it… Yet again, this displaces the burden to many developing countries’ ports instead of putting the onus of compliance assessment where it legally belongs: the flag state! How come a vessel that is structurally non-compliant, or lacks safety certifications, is allowed to travel to my port by its ultimate responsible, the flag state? Why do I have to make it my problem as a port state?

With C188, the link becomes even more fragile… a vessel can be constructed and designed to meet CTA requirements, and have crew on board whose contracts and living conditions do not satisfy ILO C188, and vice versa. Therefore, unless the flag state is a party to both, the two remain independent.

Yeah, but port states can inspect both and do seething… sure… but again… why do we expect many developing countries’ port states to bear the burden of compliance with flag state obligations? How come an unsafe vessel with crew on board whose labour rights are substandard is allowed to leave the waters of the flag state?

So to summarise, the CTA does not include, among others:

• Criminalise IUU fishing

• Mandate AIS/VMS transparency

• Address beneficial ownership

• Create global vessel identifiers

• Harmonise RFMO enforcement

• Automatically link to any of the present catch documentation schemes

And without a strong flag State political will, it is just paperwork. If key distant-water fleets ratify but under-enforce, little changes, and if major fishing States (like China, Panama, USA, Taiwan, Nauru, FSM, Ecuador, just to name a few in the Pacific) stay outside, the main holes remain.

Where it could be transformative

If — and this is the big IF — it becomes integrated (i.e. a requirement) for:

• RFMO positive vessel lists to operate in the high seas

• Part of the licensing condition to operate in coastal states

• Part of the conditions for IMO ship identification numbers

• Part of the condition for crew labour rights compliance regimes

But for me, at least, the key measure would be to make it a condition for insurance and classification societies… no CTA adherence, no insurance.

But yeah… until such day… It’s great that CTA has entered into force, no doubt… but will I see a difference in my work in the fisheries administrations and wharves in the short and medium term… not really.

One Hundred Years of tuna, adaptability and systems

The two times I wrote about work by John DeBeer (here and here), I mentioned that I grew up in a culture where you always listened to and respected your elders. This was later emphasised by my time in the Navy and then in fishing, as well as by the Pacific cultures that have hosted me in my new home since 1991.

You may not always need to agree with them, but you listen, because they have two things that only time can give context and perspective.

I completely devoured the latest book by John (and a bunch of other well-known tuna experts), A Personalised History of the U.S. West Coast Tuna Industry, as soon as the copy he kindly sent me arrived home.

He and some of the other authors are the elders in the tuna world I’m part of, and he has always been very kind with his time to my questions and views. So if you want to understand the tuna industry from the perspective of where it started and in 1rst person experience, I recommend you get a hard copy or the Kindle one

The tuna industry is shaped by people on deck and in the engine room, by salt, steam, diesel, deck machinery, net materials, refrigeration technology, and political negotiations, and carries the smell of used brine and geopolitics equally.

A Personalised History of the U.S. West Coast Tuna Industry is not merely a chronology of boats and brands. It is a study in access. Access to fish. Access to markets. Access to ports. Access to regulation. And, increasingly, access to survival in a world where fisheries biology, economics, and policy collide with ruthless indifference to each other.

The authors start where all fisheries must: with the raw material. No access, no fish. No fish, no cannery. No cannery, no brand. No brand, no industry. It is an elegantly simple equation — until the world intervenes.

Here are my lessons learned… but please read the original.

From Ice to Brine: Extending the Horizon

In the early 20th century, the tuna fishery off California was modest, almost intimate. Albacore were taken by small pole-and-line vessels operating within reach of shore. Ice was the limiting factor — both literally and economically. Fish could only be kept so long before decomposition turned profit into loss.

Then came brine freezing in the 1930s. Ammonia-cooled wells replaced ice. Trip length lengthened. Fishing grounds expanded southward. What appears to be a technical adjustment was, in fact, a structural transformation: technology dissolved geography.

This is the recurring theme of the book — every technological innovation changes not only efficiency but also power.

The fishery became less coastal and more industrial. And once the range extended, the next question was inevitable: how far can we go?

The Purse Seine Revolution

The Puretic power block and nylon nets in the 1950s transformed tuna fishing from artisanal harvest to industrial extraction. Cotton nets gave way to mechanised retrieval. Capacity exploded.

The IATTC data reproduced in the book show a surge in carrying capacity from the 1960s through the 1980s. Steel hulls replaced wooden ones. Shipyards in San Diego and Tacoma produced purse seiners like factories manufacture machinery.

And machinery was exactly that. Catch rates increased. Efficiency rose sharply. The fleet turned into a harvesting machine — until the shore-based infrastructure could no longer keep pace.

Cannery processing capacity is not infinitely elastic.

The Cannery: The Other Constraint

One of the most insightful parts of the book is not about fishing, but about processing. Canneries operate for 48–50 weeks each year. They are built for consistent throughput. Retorts, seamers, precookers, and thawing capacity — all fixed.

When purse seiners flooded the docks with frozen tuna in the 1980s, inventory management — not fish availability — became the bottleneck. Boats were ordered to tie up for 60 days after unloading.

That is a crucial insight. Overcapacity in fisheries is often discussed in biological terms, but here it is industrial logistics that regulates the fleet. Canned inventory value surpassed capital assets. Too much fish became a liability.

It was the market, not the ocean, that set the limit.

Law Shapes Geography: Jones and Nicholson

If technology broadens the range, then law redraws it.

The Jones Act (1920) limited coastwise shipping to vessels built and registered in the U.S. The Nicholson Act (1950) restricted foreign-built fishing vessels from docking directly at U.S. canneries — except in certain territories.

These laws subtly reshaped the geography of tuna processing.

Puerto Rico prospered under tax incentives (Section 936), but only U.S.-flag vessels were permitted to unload directly. American Samoa received a special exemption that allowed foreign vessels to land fish there and to ship canned products duty-free to the mainland.

Thus, the policy created an industrial shift. Canneries relocated overseas. By 2025, Puerto Rico’s tuna factories had all closed. Only one major cannery remained in American Samoa. Mainland operations transitioned to frozen loins imported from global precooking plants.

What started as a West Coast round-fish industry developed into a global loin-processing system.

Transhipment: The Invisible Artery

Few outside the industry appreciate the logistical ballet described in the chapter on Marine Chartering Company’s reefer fleet.

In the 1950s, tuna caught off Peru had to travel 4,000 miles to California. Grace Lines' cargo vessels were inefficient for frozen fish. MCC introduced small dedicated reefers. Ultimately, a global neutral freight network transported millions of tons of frozen tuna across oceans — from Peru to Puerto Rico, West Africa to Spain, Western Pacific to Pago Pago.

Transhipment is not glamorous, but it is crucial. It allowed fleets to stay on the grounds. It separated catching from processing. It facilitated the global reorganisation of tuna flows.

And when the neutral freight model was replaced by trader-controlled vessels, control of logistics shifted to control of sourcing and pricing.

Again: power shifts with infrastructure.

The 200-Mile Revolution

If the 1950s were a technological revolution, the 1970s/80s were a jurisdictional revolution.

The spread of 200-mile Exclusive Economic Zones fragmented the high seas into national jurisdictions.

Highly migratory tuna do not respect borders. But vessels must.

Suddenly, access required diplomacy. The American Tunaboat Association negotiated with foreign governments. Seizures occurred. Access agreements became essential. (Read here if keen to know more about this.)

And so RFMOs emerged — notably the IATTC in the Eastern Pacific.

But closures — such as the Yellowfin Regulatory Area — prompted fishermen to innovate spatially. The renowned “Outside the Line” grounds west of the Commission area became viable alternatives.

The fleet was adaptable. If fish were not available within regulated areas, they searched outside them.

This is another enduring lesson: regulation rarely ends fishing; it redistributes it.

Moving West

Veterans of WWII had observed skipjack schooling in the Western Pacific. In 1970, U.S. ships advanced into the Western Tropical Pacific near Palau.

The move was initially unsuccessful. Nets designed for dolphin-associated yellowfin in the Eastern Pacific were too shallow for deeper thermocline conditions. Japanese vessels, with deeper nets and advanced electronics, outperformed them.

The Pacific Fisheries Development Foundation (PFDF) was established to investigate hidden fisheries. Survey trips were conducted, and lessons were learned.

By the 1980s, Western Pacific fishing and American Samoa processing had become key components of the U.S. tuna industry.

Again: technology meets fisheries biology meets policy.

Food Safety: Invisible Discipline

Parallel to the evolution of fishing, there was also regulatory evolution on land.

From the California Cannery Inspection Act (1925) to the 12D botulism standard, from HACCP to histamine controls, the processing chapters of the book remind us that tuna is not merely a commodity — it is a food safety risk if mishandled.

Salt penetration, honeycomb formation, mercury levels, sodium reduction, and low-acid canned food regulations—each issue demanded a technical solution.

Fishing and processing are inherently linked. If fish heat during transhipment, histamine levels increase. If brine seeps unevenly into the muscle, the texture deteriorates. If concerns about mercury rise, consumer confidence declines.

The fishery persisted because the industry invested in resolving these issues.

Human Machinery

Perhaps the most compelling elements of the book are the vignettes — stories of boiler explosions in Samoa, of surly retort leadmen, of captains taking risks to fish in Peru, and of engineers tracing the foot of a 300-pound retort operator.

These stories are not merely decorative. They serve as reminders that fisheries are human systems. Decisions are made by people — sometimes impulsively. Machines explode. Nets tear. Governments change policy mid-season.

Behind every ton of tuna lies a web of human improvisation.

Rise and Decline of West Coast Canning

At its peak, dozens of canneries operated along the U.S. West Coast. By 2005, the last whole-fish cannery in San Pedro had closed. Production shifted to loins that were precooked overseas and imported for final packing.

The causes were well known: labour costs, foreign competition, transportation expenses, and trade regimes.

But beneath the economics lies a deeper structural shift: vertical disintegration. The old model — vessel to dock to cannery to brand — fractured. Catching, processing, and branding became geographically separated.

The U.S. tuna industry didn’t vanish. It reshaped itself.

Lessons in Systems

What does this century-long story teach me?

1. Access is political. Fishing grounds are negotiated spaces.

2. Technology outpaces governance. Every efficiency gain produces a regulatory response.

3. Processing capacity disciplines fleets. Biology is not the only constraint.

4. Logistics determines power. Who controls the transhipment controls value?

5. Industries globalise when cost structures demand it.

6. Human resilience underpins adaptation.

The tuna industry survived wars, EEZ revolutions, dolphin controversies, mercury scares, overcapacity crises, and globalisation. It did so not because it was static, but because it was adaptable.

And Now?

By 2025, the U.S. tuna processing footprint will be a shadow of its mid-century scale. But the system persists — reoriented around global loin supply chains, remaining territorial canneries, and distant-water fleets operating under RFMO regimes.

The book does not romanticise the past. It documents it — candidly, technically, occasionally humorously.

And it leaves us with a subtle but powerful realisation: fisheries are not just about fish. They are about alignment — between fisheries biology, engineering, regulation, logistics, labour, and markets.

When they align, the system hums. When they diverge, vessels tie up and factories close.

Tuna, the most migratory of fish, has borne witness to a century of industrial and political change. The story of the U.S. West Coast tuna industry is therefore not confined to local matters — it reflects a broader picture of global fisheries development.

Steel hulls. Nylon nets. Steam retorts. 200-mile lines. Reefer vessels. Tax codes. Scout planes. Observer programmes.

All in pursuit of a straightforward goal stated early in the book: to provide a wholesome, nutritious protein to people.

The journey from ocean to supermarket shelf is anything but simple. And that is precisely why this history matters.

We need to start seeying dFADs as a waste crisis in the WCPO

As I mentioned last week, I have been in Tahiti at the International Workshop on Mitigation of FAD Loss and Abandonment in the Pacific Ocean. It has been a great and impactful experience. Since participating in the climate change in fisheries workshops in 2024, I haven’t been challenged by facts as I was in this workshop.

While I’m pleased to see our fishery remains stable and sustainable in terms of stocks, our challenges with IUU fishing being well controlled and among the lowest globally, and with labour issues being addressed progressively, I once again have the feeling of observing a slow-motion train crash.

This is a programme that affects all of us here and many more who are not here. They say there is no free lunch… and it is true… this is the bill for the massive increase in efficiency that FADs brought to the PS fishery.

Beyond their obvious role in modern tuna fisheries, dFADs have a range of unintended environmental and socio-economic consequences that extend well beyond the moment of deployment.

In the WCPO, we estimate there are between 40,000 and 60,000 of these objects drifting east to west along the equator — and yes, we don’t really know the exact number, which is the first part of the problem — and while most are concentrated within 10 degrees of it, we find them all the way down to 25 to 30 degrees south and north. 

The enormous year-to-year fluctuations in dFAD numbers mean that even relatively low loss rates result in a significant buildup of floating gear that drifts out of fishing zones and eventually washes up on shores or coral reefs.

When a dFAD makes landfall or tumbles onto a reef, it does more than simply litter the landscape: it can transform into a source of chronic habitat degradation. Still, most of the tails are built with synthetic netting and salt bags designed to extend deep into the water column; when they strand in shallow coastal waters or reef flats, that netting continues to destroy coral and entangle marine life long after the fisheries vessel that deployed the device has left the area.

These additional impacts on nearshore habitats are already compounded by multiple stressors from climate change and local resource use.

Coastal communities in the Pacific bear the brunt of these impacts in tangible ways. Stranded dFADs wash up on beaches, in lagoons, and among coral bommies, where they must be physically removed to protect subsistence fishing grounds, tourism assets, and aesthetic values.

We were presented with numerous examples of their destructive potential: images of dFAD long tails along the reef, with the raft and buoy washed up on the beach, broken buoys with batteries leaking, and so on.

Local authorities and voluntary groups in the islands have limited resources to collect and dispose of these objects; on some islands, ongoing citizen science and reporting initiatives are the only means of documenting and addressing the issue.

The examples we discussed highlight that the “externalities” of industrial tuna fishing extend beyond the offshore environment and also affect the ways of life and economies of island nations.

A dFAD deployed months earlier to improve fishing efficiency often becomes marine debris with ecological consequences. And while we have made advances in design (e.g., biodegradable materials) and in regional cooperation in reporting, retrieval, and accountability… We are still far from meaningfully tackling this problem.

The root cause is that dFADS are now ubiquitous, and intense competition among the three main manufacturers of sonar buoys (Marine Instruments, Zunibal, and Satlink) has made them inexpensive and very effective.

A rough calculation suggests that, if you make the dFAD body from biodegradable materials (best-case scenario) and add a latest-generation sonar buoy, set it up, let it drift, and after a couple of weeks, you catch 3 to 4 tonnes of skipjack (which is a VERY small set), you’ll pay for the whole dFAD. Anything above it is earnings… so the incentive of recovering it, if it drifts beyond a certain distance from the vessel, is gone. Since the cost of fuel and the loss of fishing time are much higher than the cost of the dFAD (particularly once it has been fished, it is not cost-effective to recover it and is easy to let it sink or abandon.

To complicate things, as dropping and recovering FADs is defined as fishing, if they drift into an area where you have no licences (or vessel days), then you are acting “illegally” even if you are trying to do the right thing… thankfully, this could be the easiest issue to fix.

However, once you delve into the legal language, dFADs are difficult to define and may be regarded as MARPOL violations, hazards to navigation, or fishing gear. One of the interesting exercises we undertook was to define 'lost', 'abandoned', and 'discarded' because intentionality is a key issue that is difficult to establish.

But for me, beyond the definitions and legal arguments, the reality is that the life cycle of dFADs is not a “new problem”; it is a waste issue. 

My personal view is that we are treating it as a “waste management” issue, centred on disposal and limited recycling, which happens at the end of the problem and shifts the burden onto those who did not cause it… and this is simply not right.

So we need to see it from the perspective of “reverse logistics” that differs from traditional waste management in that it adds a “value” to recovering and repurposing products and routes while respecting the internationally recognised UNCLOS principle that the country to which a fishing vessel belongs is responsible for all the actions of the vessel, including the waste produced by that vessel.

I think we should consider a targeted “waste-bond” system that combines a deposit on new dFAD with a recoverable payment for verified retrievals, creating a market signal that turns abandoned gear into an asset rather than waste.

There are already international experiences in developing a waste bond system payable at the time of permitting activities. In the case of fisheries, this includes licensing, registering FADs, and related activities.

This ‘dFAD bond’ should involve fishing vessels for dFAD bodies and sonar buoy producers for their units, as they are directly involved in the issue.

Sure, it would be great to have the canners and traders involved… yet there is very little leverage to get them in… and in principle, cost can be added to the price sold to them as one option, or they can choose to buy dFAD-free (non-associated) fish in the same way that vessels can choose to do that as well.

Of course, this will increase fish prices, as a premium would need to be involved, yet I know premiums are volatile… Currently, most canned tuna buyers prefer MSC-certified tuna over FAD-free tuna. However, some traders encounter specific customers who request FAD-free options. In such cases, a premium is usually paid to the fishing vessel for implementing onboard catch separation. The FAD-free premium typically ranges from USD 50-100 per tonne. 

However, as I will discuss later … MSC may also have a role, their Principle 2 – Ecosystems considerations, which dFADs are very much part of it, they could have the requirement to be part of the dFAD waste bond fund (after all, until a decade ago, dFAD fish wasn’t certifiable) is not something they couldn’t do again if they want to

Yet these days, MSC premiums are negligible because they have lobbied distributors and retailers in rich countries to make it a standard market requirement, and almost all purse seiners in the WCPO are covered under an MSC certification. If an MSC premium is being offered, it would be around USD 20-50.

(My views on the neocolonial nature of private certification are more than well documented… rich countries’ consumers should not trust the sustainability claims of Pacific Islands governments or their bodies, so certification bodies from rich countries need to provide that certification)

But as I said before, the price for dFADs is now borne by the environment and the communities in the Pacific islands… which are the ones that are less involved in PS fishing.

While I’m aware this is a theoretical exercise for now, and we need to test legal, logistical, and financial mechanisms for

1. incentivising responsible design and deployment,

2. enabling community-based collection and reimbursement, and

3. establishing an accountable chain of custody for reused or recycled materials…

I’m old enough to remember when PNA’s VDS was also an “idea”… and look at it now

Based on the vessels' operational and size characteristics, a reasonable estimate of loss expectancy can be used to calculate the required dFAD bond. Many factors must be considered when setting the bond amount, including practical, economic, and political considerations.

The FAD bond would be held in escrow, possibly using a standard commercial mechanism, and renewed annually for each licence period or as needed. Vessels that repeatedly fail to manage their FAD may lose their bond, and that money could be allocated to a different FAD recovery programme.

The initial numbers in SPC’s analysis talked of around 1000 to 2000 USD per recovery, with the variability based on the different types of systems and scenarios

So, we could imagine a system where we have a deposit + recovery payment (waste-bond)

• Deposit: Per-dFAD fee applied at point of registration (collected in equal parts from buoy/fleet owners, vessel operators and manufacturers) and the bond is held in a managed pilot fund.

• Recovery payment: Verified retrievals (stranded or drifting but recovered) are eligible for a payment drawn from the fund. Payment should exceed local collection costs to ensure participation (e.g., cover transport + a margin). The payment scale could be tiered: higher payments for reef/nearshore retrievals (harder and greater ecological benefit), lower payments for open-water recovery.

• Bond mechanics: If an owner demonstrates recovery (proof of retrieval), part or all of their deposit is returned; if the dFAD is not recovered within a defined period, or if the dFAD is abandoned, the deposit funds are allocated to support local recovery/processing and community incentives.

Then a Verification and chain of custody

• ID & registration: All participating dFAD buoys must carry unique, tamper-resistant IDs and be registered in a central registry.

• Proof of retrieval: EM or Photographic evidence (geotagged), GPS buoy transfer logs, observer records, handing in to authorised collection points, or verified collection by trained community teams.

• Processing points: Designated collection hubs receive material, separate buoy electronics (for reuse), and route netting/components to designated recycling or repurposing partners.

So the reverse-logistics flow could be:

1. Deployment → buoy registered → deposit paid.

2. If lost/stranded, the community or the retrieval team collects it and transports it to the collection hub.

3. Hub verifies, logs, and issues a recovery payment to the collector, and, if appropriate, returns a deposit (or a partial refund) to the registered owner.

4. Reusable components repurposed or sent to a recycler; non-reusable waste to be transported back to the flag state to be disposed of per environmental standards.

And fundamentally, we need to agree on Governance, roles and responsibilities, so here are some ideas

• Regional coordination: WCPFC/SPC or a regional body to provide a regulatory framework, technical guidance, harmonise reporting, and provide legal templates.

• National governments: Host pilots, manage local permits, approve collection hubs, administer funds or appoint fund manager.

• Industry partners (fishing companies, buoy manufacturers): Participate in deposit payment, register buoys, and engage in co-funding and design improvements.

• Local communities/NGOs: Collection teams, verification, awareness campaigns, and hub operations.

• Ecolabels: having as part of their standards (for example, in MSC Principle 2 – Ecosystems considerations) the requirement to be part of the dFAD fund. (after all, until a decade ago, dFAD fish wasn’t certifiable) so is not something new they could do.

• Third-party administrator/trustee: Financial management of deposits, payments, and audit functions (could be a regional organisation, financial advisor or trust).

• Donors/development partners: Seed funding for deposits, capacity building, and initial hub setup.

As if all the above were not complicated enough. This all has to fit under a Legal & policy framework that incorporates

• Compatibility with national laws: Ensure deposit collection and fund use align with customs, tax and fisheries regulations.

• Ownership & liability: Clarify ownership of recovered gear and liabilities.

• Incentives versus perverse outcomes: Avoid incentives that encourage deliberate recoveries to claim payments (strong verification is required).

• Data/privacy: Buoy registration and tracking data protocols must maintain the present confidentiality and proprietary tracking arrangements.

Yet, given that the key buoy manufacturers are all Spain-based, they may need to comply with the EU’s Waste from Electrical and Electronic Equipment (WEEE) regulations and other Extended Producer Responsibility (EPR) laws that hold producers financially or physically responsible for the entire lifecycle of their products, particularly those that require separate collection and recycling targets, and mobilising reverse logistics across entire product categories.

Compliance with these principles could also be required, as market conditions are today, in the same way that catch and health certificates are today (see my publication for FFA on this). Particularly, the Directive (EU) 2024/1760 of the European Parliament and of the Council of 13 June 2024 on corporate sustainability due diligence (CSDDD) is worth mentioning here, as this legislation will be implemented gradually over the next few years, imposing mandatory human rights and environmental due diligence requirements on large EU and non-EU corporations operating in the EU.

These companies must take steps to manage actual and potential adverse impacts of their activities on human rights and environmental matters arising from :

1. their own operations,

2. the operations of their subsidiaries, and

3. the operations of their business partners in their chain of activities.

The "chain of activities" does not encompass the disposal of products or the activities of a company's downstream business partners related to the company's services. However, it does cover:

1. The activities of the company's upstream business partners related to the production of goods or the provision of services by the company (including the design, extraction, sourcing, manufacture, transport, storage, and supply of raw materials, products, or product components, and the development of products or services).

2. The activities of a company's downstream business partners related to the distribution, transport, and storage of the product, in which the partners perform those activities for the company or on its behalf.

The primary due diligence obligations under the CSDDD are "obligations of means", not "obligations of result".

Companies are not expected to guarantee that adverse impacts will not occur, nor will they always be prevented. However, they are expected to take "appropriate measures": measures capable of achieving due diligence objectives.

Finally, I’m the 1st one that is VERY aware that this is all easier said than done and will require coordination, time, effort and money, but we have precedents in solid waste (MARPOL) and the Basel Convention on the Transboundary Movement of Hazardous Wastes, so we don’t need to reinvent the wheel. Yet we need to find a solution for these problems, if we wish to maintain any legitimacy as a responsible industry

Additionally, we could also consider this from an insurance perspective and the obligations under UNCLOS…. But I’ll leave these for another day.

From Fishing Grounds to Shorelines: Rethinking dFAD Loss and Recovery in the Pacific

I have been fascinated by the impact that drifting Fish Aggregating Devices (dFADs with sonar buoys) have had on the purse seine fishery since I was fishing in the 90s. It has significantly changed the fishery, and I've written extensively about it in the past.

The usual end of lifecycle of a dFAD (picture by @SPC)

While I have worked on assessing plastic waste generation from fishing vessels in the WCPO, I have not written extensively about one of the most persistent and complex challenges facing tropical tuna fisheries: the “other impact” of FADs, namely the loss and abandonment of drifting FADs

This week, I'm in Papeete, Tahiti, for an ambitious and timely international workshop on the subject, organised by SPC and ISSF.

They are getting people from the fishing industry, regional fisheries bodies, scientists, technology providers, NGOs, governments, and coastal communities to work together. The goal of the workshop is to go beyond diagnosis and develop practical, scalable approaches to reduce dFAD loss and increase recovery rates across the Pacific.

The workshop will go for four days and is meant to connect fishing grounds and shorelines. It recognises that losing dFADs is not just a problem for vessels and regulations at sea; it also has real effects on the environment, society, and economy of coastal ecosystems and island communities.

The first day will set the stage for analysis by looking into why dFADs are lost or left behind. Sessions look at how dFAD design and materials have changed over time, keep an eye on new technologies and fishing methods, and show new evidence of loss corridors and buoy trajectories in both the Eastern and Western Central Pacific.

We will examine both the legal frameworks and certification requirements, as well as industry perspectives. This hopefully brings up both regulators' expectations and the realities of running a business. Significantly, stakeholder perspectives—obtained via regional surveys and collaborative exercises—ground the technical discussions in empirical experience.

On day two, the focus will change from offshore dynamics to coastal effects. Participants will look at how stranded dFADs affect reefs, shorelines, and people's lives in the Pacific, Indian, Atlantic, and Caribbean regions. They will also look at how in situ data collection and monitoring programs are being created and put into action.

Peer-to-peer exchanges will help us share what we've learned about recovery operations, getting people involved in the community, and the problems that come with long-term monitoring on remote islands. At the end of the day, there will be talks about how to improve monitoring of stranding events and their effects on the environment, especially in delicate habitats like coral reefs.

The third day will be all about solutions. There will be a wide range of recovery programs on display and under critical review, from community-based FAD watch programs to industry-funded recovery schemes and pilot trials. These experiences add to bigger talks about how to make dFAD retrieval programs work, including how to make them cost-effective, how to set up incentives, and how to measure success. We look into new ways to do things, like deposit-refund systems, repurposing buoys, recycling pathways, and dedicated recovery funds. We're especially interested in making sure that small island developing states don't have to bear too much of the burden.

The workshop will conclude with a visit to the fishing port of Papeete (where I began my Pacific fishing career in 1991). This will connect the discussion to the real world. This last day drives home a key point of the meeting: that long-term solutions to dFAD loss must be technically sound, economically viable, and based in the communities that are most affected.

In general, I think this Tahiti workshop is more about practical alignment than theoretical commitments. We want to create a path to a more responsible and truly sustainable dFAD fishery in the Pacific by bringing together all the people who are involved in the dFAD lifecycle, from design and deployment to loss, stranding, and recovery.

And needless to say, I am truly grateful to Lauriane Escalle from SPC and Gala Moreno from ISSF for inviting me to participate in this event, which is supported by The World Bank, Problue, Direction des Ressources Marines (DRM), ISSF, IATTC, The Nature Conservancy, The Palmyra FAD Watch Program, American Tunaboat Association, Bolton Food, Tri Marine, Satlink, Zunibal, Marine Instruments, and Tunacons. Special thanks go to DRM and Thibaut Tellier for their local assistance and organisation.

Tuna Industry and Trade Dynamics in the Western and Central Pacific Ocean

Here is another update to this seminal FFA publication… I remember the 1st version commissioned by my good departed friend, Hugh Walton, in 2011 and written by Amanda Hamilton and the now departed Anthony Lewis, plus Mike McCoy, Liam Campling and Elizabeth Havice being the last 3 ones continuing authors of the present opne

The publication offers a detailed analysis of the tuna industry and trade patterns in the WCPO. It explores key players in the international tuna market, emerging environmental, social, and governance (ESG) trends, trade policy developments, and their implications for Pacific Island Countries (PICs).

I just get some of the basics I like, and the ones I don't… Yet, as noted, it is a critical publication that one should read in its entirety to have any credibility when discussing tuna fisheries in the region.

Key Players in the Tuna Industry

The global tuna industry is led by a few major players, known as the "Big Four," which include Bolton Food & Tri Marine, Thai Union & Chicken of the Sea, FCF & Bumble Bee, and Dongwon Industries & StarKist. These companies are highly competitive, vertically integrated, and have diverse portfolios in seafood and other sectors. They depend on efficient access to raw materials and competitive prices to stay profitable.

1. Bolton Food & Tri Marine: Bolton Food is a family-owned company with a strong presence in Europe, Latin America, and the US. It owns several premium tuna brands, including Rio Mare, Saupiquet, and Wild Planet. Tri Marine, acquired by Bolton in 2019, is a global tuna trading company with operations in the Solomon Islands. Together, Bolton Food & Tri Marine have established a vertically integrated supply chain, ensuring sustainable fishing practices and delivering substantial economic benefits for the Solomon Islands.

2. Thai Union & Chicken of the Sea: Thai Union is the world’s largest ambient tuna processor, with factories in several countries, including Thailand, Indonesia, Vietnam, and the US. It owns brands such as Chicken of the Sea, John West, Petit Navire, and Mareblu. Thai Union is recognised for its sustainability efforts, including its SeaChange 2030 strategy, which emphasises environmental and social responsibility. Despite its global presence, Thai Union faces challenges stemming from declining consumer spending in the US and the effects of new tariffs.

3. FCF & Bumble Bee: FCF is a major marine products trading company with strong links to the Taiwanese fleet. It owns Bumble Bee, a leading North American seafood brand, and has made significant investments in processing facilities across the Pacific, including plants in Papua New Guinea (PNG) and Fiji. FCF has faced scrutiny over labour and environmental practices but has introduced programmes to address these concerns, including social responsibility initiatives and sustainability certifications.

4. Dongwon Industries & StarKist: Dongwon Industries is South Korea’s largest deep-sea fishery company, owning vessels and processing plants worldwide. It acquired StarKist in 2008, which is the leading shelf-stable tuna brand in the US. StarKist operates a large processing plant in American Samoa, benefiting from duty-free access to the US market. Dongwon has also invested in processing facilities in Ecuador and Senegal, expanding its global presence.

In addition to the Big Four, Chinese companies are increasingly important in the tuna industry. Companies such as Shanghai Kaichuang Marine International, Zhejiang Ocean Family, and Liancheng Overseas Fishery (Shenzhen) Group have expanded their presence in the WCPO, leveraging government support and joint ventures with Pacific Island nations. These companies are vertically integrated, with investments in fishing fleets, processing plants, and trading operations.

The Philippines also plays a vital role in the tuna industry, with companies like RD Corporation and Frabelle Group operating as vertically integrated businesses. ​RD Corporation has led onshore tuna processing in PNG, while Frabelle Group has set up fishing and processing operations in the WCPO and PNG.​

Emerging companies like Dayang Seafood Ltd., a Taiwanese firm, are also establishing their presence in the industry. Dayang operates purse seine vessels in the WCPO and has invested in a processing facility on Kosrae.

Environmental, Social, and Governance (ESG) Trends

The publication emphasises the increasing significance of ESG trends in the tuna industry. Environmental sustainability and social accountability have become essential parts of the business, driven by pressure from major markets, buyers, and NGOs. Companies are progressively implementing dedicated ESG programmes, public sourcing commitments, and traceability systems.

These advances appear to be achieved only through private certifications; here, as may be expected, I disagree not with the authors but with the principles that the present systems imply.

They discuss the impact that the Marine Stewardship Council (MSC) has on the fishery... As someone who works with fisheries officers, I see things from the other side — the effect the fishery has on MSC.

A fishery can be certified becasue is sustainable; it is not sustainable because it is certified.

The framing of this discourse suggests that private certifications enhance environmental sustainability and social accountability, but they do not. It is primarily the Pacific Islands and their organisations, such as SPC, PNA, and FFA, that undertake the real work… while private certification. ro the rubberstamping

The whole existence of private certification based in rich Western countries is based on the colonial and racist principle that you cannot trust poor brown people, so organisations based in rich white countries have to come and certify this… otherwise it is not true. Furthermore, it is the producers who must pay for this, not the wealthy people who want the fish because they overfished their own.

For example, the bulk of the work for MSC Principles 1 and 2 (focusing on maintaining sustainable, productive fish stocks and minimising environmental impacts) is done by the Oceanic Fisheries Programme (OFP) of SPC, while Principle 3 focus on effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks… wich is what all the pacific fisheries admintrations do, even if the evaluators only used the data provided by the clients.

The real work is mostly performed by the same people who cannot be trusted, and then certified by certification bodies that are paid by the industry; MSC receives a share of all sales that bear its logo.

FIPs are even worse, as they morph the obligations into a situation where companies and flag states are seen as having voluntary commitments, and they are allowed to improve over time… instead of clearly stating: this is an obligation, and if you cannot prove that you are complying with it in its entirety, you cannot fish here. 

I have written to oblivion on this and the even worse menace of private certifications for labour standards…. Independently, we are the only region in the world that tied fishing access to minimum labour standards through the FFA HMTC for licensing and the forthcoming WCPFC Labour Standards CMM.

Earlier this year, I attended a presentation by Marcelo Hidalgo on the numerous private certifications and initiatives to which the PNG Fishing Industry Association adheres (likely at high cost to its members). I'm unsure whether any fishery in Europe could fulfil all those requirements… And why. Is it because of PNG? More importantly, I have not found any study suggesting that they earn more than other countries because they adhere to those standards.

For me, the whole private certification world is a racketeering scheme based on deep-seated colonialism. I see my friends and colleagues in the Pacific working REALLY hard… doing a great job… yet the whole setup is that their efforts are not to be believed unless “certified” by an organisation from a rich colonial country.

On more positive topics

It’s encouraging to see that climate change is on the agenda: companies are developing decarbonisation strategies to mitigate its impacts.  Thai Union, Bolton Group, and Dongwon Industries have set ambitious targets to reduce greenhouse gas emissions and achieve net-zero emissions by 2050.

It would be useful to review their strategies regarding MARPOL, as we investigated their plastic dumping in 2021, and the figures are staggering.

With respect to traceability and transparency, private and third-party traceability systems are increasingly prevalent in tuna value chains. Traceability is part of the remit of both fisheries and seafood authorities in every Pacific Island country. Yet again has to be approved by someone from the other side of the world for it to be true and demonstrable

Trade Policy Developments

The publication also examines the influence of trade policies on the tuna industry, emphasising tariff arrangements, rules of origin, and changing trade policies.

Tariff Structures: The EU and US are the largest markets for canned tuna, with tariff peaks of 24% and 35% respectively, to protect local producers. Preferential trade arrangements, such as the EU’s Economic Partnership Agreements (EPAs) and the US Compact of Free Association Act, provide duty-free access to specific markets, influencing the distribution of tuna production.

Rules of Origin: Rules of origin (RoO) determine whether products qualify for preferential access to trade. The EU’s "global sourcing" RoO, negotiated in the 2007 Interim Economic Partnership Agreement (IEPA), allows Pacific Island countries to source fish from any vessel, provided it is processed locally. This flexibility has benefited PNG, Solomon Islands, and Fiji, enabling them to access the EU market for canned tuna and loins.

Evolving Trade Policies: Labour and environmental standards are increasingly integrated into trade agreements. The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) is a forthcoming trade requirement intended to improve sustainability and labour conditions in global supply chains. However, these measures also create compliance burdens for Pacific Island countries.

Finally, it irks me a bit that market access and market success are conflated; market access is the minimum requirement to enter a particular market with your products. For example, for the EU, you must first be an authorised country from a sanitary perspective; then, every consignment entering the EU requires a health certificate and a catch certificate issued by the competent authorities of the country of origin… no private certifications from MSC to ISO are needed… only those of the state…. For the US, being in SIMP is what is required, and so on (written about this here)

Now, MSC, BRC, FoS, CREW... and you could include 20 more... are all private certifications that a buyer in Europe might request. Since you want to sell them, you pay for these certifications, which can help you achieve market success. However, they are NOT part of the official market access requirements.

Around 80-90% or more of the tuna consumed in Europe and the USA is caught outside their waters and supplied via imports... and from that I will say that 60-70% is from the WCPO. What do you think will happen if all of the producers stop paying for private certifications… Will people stop eating tuna? Will canneries stop canning? Will vessels stop fishing?

Of course not… everything will continue as it is… and all private certifications will disappear…

Overall, the publication emphasises the unique position of PICs in the global tuna value chain.  As resource owners, PICs possess significant leverage but encounter challenges in capturing more value from the industry.

It’s not just about fishing, is also geopolitics.

I have insisted for the last couple of decades that the biggest shift I’ve seen in my 40 years of fishing is that it used to be about catching fish to be eaten by people… while now a whole parallel dynamic is at play: geopolitics.

The main issue I have with Distant Water Fishing Nations (and their subsidies) is that they blur the boundary between commercial activity and geopolitics…. and generally the consequences are paid by others.

The principle that “presence equals rights” is fundamental to how nations establish, maintain, and defend their interests in disputed areas. It embodies the idea that ongoing activity in a specific region grants a state or other actor "rights" in that territory or activity, often overriding legal claims or international standards.

Therefore, fishing is no longer solely about catching fish.

Here is an example from FFA’s excellent “Trade and Industry News,” which is worth subscribing to, and, in addition, it relates to a country very close to my work (and heart), the Marshall Islands.

In late October 2025, the USA suddenly reclassified tuna caught in the Marshall Islands EEZ and exported to the US as Chinese origin. The practical effect is severe: a sudden 45–55% import tariff on tuna, which had long been considered a Marshallese product.

What makes this move especially upsetting is that it directly undermines established fisheries governance, since, for over a decade, the WCPFC has been clear in terms of the reporting of those catches:

In the Conservation and Management Measure for Bigeye, Yellowfin, and Skipjack Tuna (CMM 2023-01, para. 8), it is stated that, ‘...attribution of catch and effort shall be to the flag state, except that catches and effort of vessels notified as chartered under CMM 2021-04 or its replacement shall be attributed to the chartering member….’, 

The new US position simply disregards that consensus—at least for trade purposes—raising uncomfortable questions about how fisheries management, trade policy, and geopolitics are now conflicting.

The government of the Marshall Islands has strongly pushed back. Its Foreign Minister formally lodged an objection to US Customs, reportedly without response, while MIMRA publicly recognised the serious economic risks to jobs, revenue, and domestic industry. The impact is real. 

The issue directly affects Marshall Islands Fishing Venture (MIFV), a long-established Majuro-based operation that anchors a regional longline supply chain exporting high-value bigeye and yellowfin to the US and Japan.

At the time of writing, the issue remains unresolved. However, what is clear is that this involves far more than tariffs. It reveals how fragile small island economies can be when dominant trading partners unilaterally alter the rules—and how swiftly decades of carefully negotiated fisheries governance can be sidelined by trade politics.

For the Marshall Islands, the stakes are existential: market access, livelihoods, and the credibility of the rules-based system they have adhered to for years.

Now…MIFV is a wholly-owned subsidiary of Luen Thai International Group in China. MIFV has been in continuous operation in RMI for 25 years and currently operates a processing facility adjacent to MIMRA that processes longline-caught fish in the RMI EEZ, with a fleet of approximately 30 vessels, mostly flagged in China, with a few flagged in FSM. The vessels are owned by Liancheng Overseas Fishery Group (Shenzen) Co. Ltd. or one of its subsidiaries, all of which are part of the parent company, Luen Thai.

The fleet based in Majuro targets yellowfin and bigeye tuna in RMI’s EEZ for export to the US, Japan, and other markets. In 2024, RMI’s longline tuna catch was 4,049 mt, consisting of 51% bigeye, 42% yellowfin and 7% albacore.6 Exported products include whole tuna and fresh/frozen loins, including loins treated with carbon monoxide. The Majuro operation forms an integral part of the company’s supply chain that links RMI with other unloading and supply bases in Samoa, Pohnpei and occasionally Kosrae in FSM

Crucial here is that Shenzhen-based Liancheng Overseas Fishery (Shenzhen) Group (LCFG) a massive fisheries conglomerate, is the umbrella company under which its three subsidiaries, Liancheng Overseas Fishery (Shenzen) Co. Ltd, Liancheng Overseas Fishery (FSM) Co. Ltd (FMLC) and China Southern Fishery Shenzhen Co. Ltd operate tuna longline vessels in the WCPO.

Luen Thai’s Asia Pacific Airlines (APA), owner of MIFV, plays a vital role in LCFG’s fresh fish operations in the western Pacific through its air cargo services. Operating up to four 757 air freighters, APA facilitates the transportation of LCFG’s fish across Micronesia to markets in Japan, Hawaii, the US mainland, and beyond.

Reflagging those vessels to the Marshall Islands would resolve the issue, as the “customs” origin would then be fully RMI; however, geopolitical considerations enter.

RMi is a strong ally of Taiwan, and its foreign policy aligns with the compact agreement (a kind of US commonwealth) with the USA. Although RMI and China have no official relations, up to 30 Chinese-flagged vessels operate in the RMI EEZ, which is a sore point for TW and a strong card for China (remember, if you have presence, you have rights). 

Furthermore, having those vessels flagged to RMI will entail upgrading many of their safety requirements and classification certificates, thus imposing costs on the operators.

Yet fundamentally, they will lose the generous fuel subsidies they currently receive, which are disguised as tax exemptions at headquarters in China.

Trade rules are quite fickle, as many variables from both the receiving and the originating countries influence trade agreements and development status. Yet, as a gross generalisation, a product is considered to originate in a country (like RMI) if it has been wholly obtained or sufficiently worked or processed with wholly or partly imported materials.

So here the details can be argued, not only through the chartering of vessels by an RMI company – MIFV (independent of the ownership), yet fishing only in the RMI EEZ (wholly obtained), but also to what extent fresh loins by plane to the USA constitute sufficiently worked or processed.

And while the fish have been passing through the USA for decades without issues, providing jobs for locals and Filipino immigrants alike, the current hostility between the US government and China directly affects a Pacific Island nation that does not cause the problems and merely seeks to benefit from the only gifts nature has bestowed — a well-managed ocean and a good port.

So again… It’s not just about fishing, it's also geopolitics.