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.