Fisheries, RFMOs and the BBNJ Agreement

A lot has been made in the non-specialised media and in online forums about the adoption of the Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas Beyond National Jurisdiction (BBNJ Agreement).

The agreement does mark a historic milestone in global ocean governance as a landmark treaty to address critical gaps in the conservation and sustainable utilisation of marine biodiversity in areas beyond national jurisdiction (ABNJ), more commonly known as the High Seas or International Waters.

In fact, I was recently asked to work on a paper examining the potential of MCS (Monitoring, Control, and Surveillance) mechanism over Marine Protected Areas in the High Seas, which is one of the tools the agreement provides for.

Yet I see many images associated with the news (fish, fishing boats, whales, etc.), suggesting that the agreement would be a solution to the woes of fisheries and that there are no tools or organisations at present dealing with any of it…. Which, of course, is not the case.

So I thought I would have a go at a blog that tries to summarise what it can do and what it does not do… and I emphasise the “can do” because having an agreement adopted is surely great, but implementation is the challenge… The United Nations Convention on the Law of the Sea (UNCLOS) is over 40 years old now… and we are still struggling to get flag states to implement and comply with what they agreed to do.

If you want a deep dive into the topic, check out this excellent publication by FAO Fisheries and the BBNJ Agreement – A guide. They do publish GOOD stuff, so it should be your first stop for most issues you want to understand. (One of the proudest days of my life was when my 1st FAO-commissioned book was published, and there have been a couple more since then, here and here.)

So for me, the 1st thing to get clear is that the BBNJ Agreement does not specify fisheries management measures, yet it introduces new processes and obligations that intersect with the mandates and operations of Regional Fisheries Management Organisations (RFMOs). And these interactions present both challenges and opportunities for RFMOs to contribute to and benefit from the evolving framework of ocean governance.

RFMOs are intergovernmental organisations established to manage fish stocks and promote sustainable fishing practices within specific regions of the high seas. They possess decades of expertise in science-based decision-making, stock assessments, spatial management, and compliance measures. It is crucial to emphasise once again that RFMOs are the entities responsible for managing fisheries in the high seas and are particularly well-equipped to support the objectives of the BBNJ Agreement, not the other way around.

This blog will explore the interactions between RFMOs and the BBNJ Agreement, emphasising how RFMOs can (and will) play a vital role in shaping and benefiting from the evolving framework of ocean governance.

But first:

Understanding the BBNJ Agreement and Its Objectives

The BBNJ Agreement was adopted in 2023 after nearly twenty years of negotiations. It establishes a global framework to conserve and sustainably manage marine biodiversity in ABNJ, which accounts for almost two-thirds of the world’s oceans. The Agreement highlights four main focus areas.

1. Area-Based Management Tools (ABMTs), including marine protected areas (MPAs).

2. Environmental Impact Assessments (EIAs) for activities that may cause significant environmental harm.

3. Capacity Building and Transfer of Marine Technology (CBTMT) to support equitable participation in biodiversity governance.

4. Marine Genetic Resources (MGR) and benefit-sharing mechanisms.

These focus areas aim to promote collaboration across sectors and integrated management, providing RFMOs with opportunities to further align their fisheries governance with biodiversity conservation objectives and vice versa.

The Role of RFMOs in ABNJ Governance

RFMOs are “the” essential entities in governing fisheries in ABNJ.

They are intergovernmental organisations established by international agreements to manage fish stocks and promote sustainable fishing practices in specific high-seas regions and the EEZs of member coastal countries.

They are found in nearly every ocean basin worldwide… other than the Southwest Atlantic. (which, in my opinion, goes a long way in explaining why that area is the fishing mess that it is)

The BBNJ Agreement explicitly recognises the importance of collaboration with relevant legal instruments, frameworks, and bodies, including RFMOs, which are classified as "relevant instruments, frameworks, and bodies" (IFBs). This recognition ensures that RFMO mandates are upheld and not compromised by the new biodiversity governance framework.

However, the Agreement also introduces new processes, such as area-based management tools (ABMTs), environmental impact assessments (EIAs), capacity building and transfer of marine technology (CBTMT), and marine genetic resource (MGR) benefit-sharing, which will require active involvement from RFMOs to promote coherence and mutual supportiveness between fisheries governance and biodiversity conservation.

Institutional and Implementation Framework ​

The BBNJ Agreement establishes several institutional bodies and tools to support its implementation, including the Conference of the Parties (COP), the Scientific and Technical Body (STB), the Implementation and Compliance Committee (ICC), and the Clearing-House Mechanism (CHM).

RFMOs will need to engage with these bodies to ensure that fisheries science, data, and governance experience inform biodiversity decisions and processes, and this is not a small issue… This means that they will need more resources and staff with the right experience and qualifications.

The STB, as a central advisory body, will offer expert guidance on science and technology, including EIAs, ABMTs, and MGRs. RFMOs can provide data, conduct peer reviews, and facilitate knowledge exchange to ensure that fisheries science and traditional knowledge are integrated into broader biodiversity governance.

The ICC will encourage adherence to BBNJ Agreement obligations through dialogue, transparency, and support. RFMOs can share their experiences with compliance tools and challenges to help shape fair, practically feasible compliance mechanisms. And here is a study I contributed to on how to MCS the MPA in the ABNJ, if it is of interest.

The CHM will act as a central platform for information sharing, promoting transparency, coordination, and data accessibility. RFMOs can participate in developing the CHM to ensure fisheries data is shared securely and fairly, with clear guidelines and mutual trust.

Interactions Between RFMOs and the BBNJ Agreement

Supporting Area-Based Management Tools (ABMTs)

ABMTs are spatially explicit regulatory or management measures designed to oversee human activities within defined marine areas to support biodiversity conservation, sustainable resource use, and conflict mitigation.

The BBNJ Agreement sets out a process for identifying, designating, and managing ABMTs, including marine protected areas (MPAs) and other effective area-based conservation measures (OECMs). While ABMTs under the BBNJ Agreement are not specifically intended for fisheries management, they may impact fisheries, particularly in regions where no RFMO or other fisheries organisation exists. (Yet, in my opinion, this absence of RFMOS presents a catch-22 situation… under which forum are you going to agree to HS MPA if there is no RFMO or IRBs)

RFMOs have historically applied spatial management tools, such as:

• Fisheries closures to protect spawning grounds and nursery areas. ​

• Protections for vulnerable marine ecosystems (VMEs) to safeguard habitats from destructive fishing practices.

• Seasonal or gear restrictions to minimise environmental impacts. ​

These measures align with the ecosystem approach to fisheries and promote biodiversity conservation.

As such, RFMOs can share their expertise in spatial planning and enforcement to support the design and implementation of ABMTs under the BBNJ Agreement. They can also provide data on ecologically or biologically significant marine areas (EBSAs) and other spatial management tools that reinforce biodiversity conservation objectives.

By leading the development of ABMT provisions, RFMOs can ensure these tools are evidence-based, practical, and complementary to existing fisheries management frameworks.

Contributing to Environmental Impact Assessments (EIAs)

EIAs are essential for evaluating and managing the environmental impacts of large-scale activities in ABNJ. The BBNJ Agreement requires EIAs for activities that could cause significant adverse effects, in accordance with the precautionary principle and UNCLOS commitments. While EIA responsibilities do not extend to activities overseen by RFMOs, the Agreement recognises comparable procedures under other relevant frameworks.

Many RFMOs already conduct risk-based impact assessments for new or expanding fisheries, which adhere to EIA principles. These assessments evaluate cumulative and transboundary impacts and rely on the best available science.

RFMOs can bring that expertise when developing BBNJ EIA standards and procedures, ensuring consistency with existing fisheries frameworks and emphasising the importance of their monitoring and risk assessment systems.

By participating in EIA processes, RFMOs can influence cross-sectoral coordination and ensure that the effects of non-fisheries activities, such as shipping, dumping, etc., on marine ecosystems supporting fisheries are properly assessed. This collaboration can safeguard fisheries' interests while also supporting wider biodiversity conservation.

Promoting Capacity Building and Technology Transfer

The BBNJ Agreement emphasises the significance of capacity building and technology transfer in promoting fair participation in marine biodiversity governance, particularly for developing countries, small island developing states (SIDS), and least developed countries (LDCs).

RFMOs generally have a dual role in capacity development and technology transfer.

• As providers, they can offer training, tools, and expertise in fisheries management, ecosystem-based monitoring, and risk assessment.

• As beneficiaries, they can access support for institutional development, data systems, and scientific research.

By engaging in capacity-building initiatives, RFMOs can help strengthen states' ability to participate in BBNJ processes while also enhancing their own capacity to adapt to emerging biodiversity governance frameworks.

Advancing Marine Genetic Resource (MGR) Governance

Marine genetic resources, including genetic or biological material of marine origin found in ABNJ, are subject to benefit-sharing obligations under the BBNJ Agreement. While fishing and fishing-related activities are excluded from these provisions, RFMOs can still contribute by:

• Being involved in developing access protocols for genetic material collected during fisheries research.

• Ensuring traceability and transparency in the use of marine genetic resources.

• Promoting policy coherence between fisheries governance and MGR frameworks.

RFMOs can also assist in integrating fisheries-related genetic data into global biodiversity governance, ensuring their practices align with the principles of the Convention on Biological Diversity (CBD) and the Nagoya Protocol.

Enhancing Cross-Sectoral Cooperation ​

The BBNJ Agreement emphasises collaboration among relevant legal instruments, frameworks, and bodies.

RFMOs work through collaboration; any of the chairs and leads in RFMO meetings can make sure that parties:

• Collaborate with other sectors, such as shipping, mining, and conservation organisations, to align actions and avoid duplication.  

• Participate in joint workshops, shared working groups, and liaison roles to foster effective cross-sectoral collaboration.  

• Promote mutual recognition of equivalent measures to ensure coherence between fisheries governance and biodiversity conservation.

So yeah... I believe that RFMOs, overall, can greatly support the functioning of the BBNJ Agreement, as they possess extensive experience in this area, having negotiated agreements across a wide range of issues over a long period. Personally, I think that while some non-specialist groups may perceive the BBNJ agreement as a way to influence fisheries and RFMOs, the opposite is more likely.

"Desk Experts" and the limits of remote monitoring of fishing vessels

As I wrote a few weeks ago, I don’t really have much of a work portfolio in Spanish, even if it was literally my mother’s language and the one in which I had my basic and university education.

I have worked more in Portuguese (which I learnt from living on the border with Brazil) than in Spanish itself. And as they say, no one is a prophet in their own culture. I have never worked again in Argentina since I left my last position at the National Institute of Fisheries and Development (INIDEP) in the early 90s

Yet in recent years, despite my strong views that the mess at the fishery in mile 201 stems from Argentina’s absolute (and shortsighted, in my opinion) refusal to even consider establishing an RFMO based on this, I have seen this as an implicit recognition of the Malvinas/Falklands Islands Government as a coastal state, thereby relinquishing sovereignty claims. 

As someone who was involved in that war, I can see the basis of that reticence, yet I think it is totally misguided… You can manage the migratory resources without relinquishing sovereignty… There are a few examples in other RFMOs that prove that case.

In any case, I have been collaborating on the basis of two people with simmilar interest nd a comon past basis with Captain Sergio Almada, the Coordinator of Argentina’s Interdisciplinary Working Group for the Control of Maritime Areas and their Resources that depends on the country’s “Prefectura – PNA” (Coast Guard), from which he retired as a senior officer of patrol and surveillance vessels.

I have never met him personally, but as most former fishermen and skippers, you tend to develop a good sense for assessing people’s character, and Sergio seems to be a very good and solid seaman and professional… and I have no problems working with people like him.

We mostly discuss the technical analysis of vessel manoeuvring and the ground truthing of perceived vessel activities.

He also confronts a similar problem that many of us working on remote assessments via Maritime Domain Awareness (MDA) systems… the “desk experts”… which generally are very well-intended individuals that get hold of a Global Fishing Watch (or equivalent) account and start analysing fishing vessels’ tracks (generally without any fishing experience themselves) and propose their findings/theories in social media and something in the non-specialised press that is always up for “a one-line punch” to the work of specialists and institutions, casting doubt on their capacity and integrity…

And as “doom sells but does not help”, then the real specialists have to spend a second time debunking those opinions, instead of doing the work they are supposed to do.

Yet Sergio wrote a great article in Spanish, explaining some of the issues with “Desk Experts” and their work, and he was really kind to quote me and refer to my work a few times, for which I’m very grateful…. And I hope one day get to meet him personally

The original is here, in Argentina’s Revista Puerto and a semiautomatic translation follows below

When AIS deceives: the limits of remote monitoring against illegal fishing

Technology based on Automatic Identification System (AIS) data is a vital tool for monitoring and managing fishing activity at sea. When used correctly, it enhances surveillance, but not everything displayed or interpreted by these platforms or "desk experts" is accurate. Recognising its limitations and inaccuracies is crucial.

Starting with a false premise or inaccurate causes when addressing a problem reduces the chances of finding an effective solution. This principle is especially relevant to criminal activities at sea and is vital for researchers working at a desk behind a computer, analysing information from monitoring platforms.

Understanding how to interpret what these platforms show us, analysing and evaluating the quality and relevance of the information, and seeking to compare it with real-world evidence requires skill and the ability to validate and contextualise. This is often lacking, undervalued, or considered of little importance, especially when what is presented responds more to interests than to the pursuit of truth with the necessary scientific rigour in an investigation.

To paraphrase Francisco Blaha, a specialist in fisheries issues and an expert in validating hypotheses and providing operational filters for these remote desktop analyses, ‘focusing the solution to problems surrounding fishing activity at sea on a single tool, such as AIS, carries the risk of raising expectations about what this technology can offer excessively.’

Blaha states that if the hypotheses and indicators used by these platforms are adjusted and the methodology employed is better verified in the field, the results will be more reliable and the tool will be more effective to use, providing more realistic figures on the problems.

It is worth exploring Francisco Blaha's blog, which has been around for over a decade, where you can find his contributions to the conservation and sustainable management of fisheries, monitoring and control, decent work on board fishing vessels, and a practical, operational view of the activity. This makes his perspective unique, and for me in particular, more appealing and engaging.

Fishing activity monitoring platforms not only display current and historical information about vessel identification and dynamics, but also report on their presumed activities (events), such as fishing, transhipments, encounters, navigation, anchoring, entry or exit from ports, AIS shutdown, and fishing effort, among others.

To achieve this, they employ a methodology, indicators, training data, and algorithms that enable them to define these activities, often with the assistance of artificial intelligence. In other words, their role in control and investigation is very significant, but it is not decisive for fully understanding what truly occurs around the activities, nor for addressing forms of maritime crime such as illegal fishing without room for error.

It is not conclusive because the information they present must not only be verified in the field but also contextualised at the local level, which requires genuine knowledge of the activity and consultation with its main actors. It is in this context that the figure of what some call ‘desk experts’ emerges and, together with them, the platform-expert binomial, which can be very effective but also potentially disastrous.

The outcome of the platform-expert collaboration will largely depend on the latter's ability to interpret and contextualise the information gathered from the platform, their knowledge of the sources and algorithms employed by the platform, their familiarity and experience with the activity under investigation, and the opportunity to engage with key actors who can validate the interpretation based on primary sources.

Common errors identified in these ‘desktop’ analyses

Few researchers verify their assumptions with the hydrometeorological data relevant to the event they are examining. Blaha highlights that anyone who has spent time on a ship knows that ‘weather is king at sea’ and that a ship's capabilities depend on sea conditions.

Not every time a ship maintains almost the same position for a couple of days is it engaging in illegal activity, as it is quite possible that when the AIS data is superimposed on the hydrometeorological data, it will be verified that it is actually weathering 50-knot winds and huge waves, where rather than illegal activity, it is simply trying to survive or ensure the safety of the ship and its crew.

Associating the entry into port of a fishing vessel or a refrigerated fishing support vessel directly with the arrival to unload catches, without considering that it may also be for other services and without consulting the port authorities to confirm or discard this assumption. For example, fleets such as the Chinese fleet operating in Mile 201 tranship their products on the high seas and rarely unload in port.

Considering the encounter of a fishing vessel with another fishing vessel or with a cargo vessel as a transhipment of catches, when there are many other operational reasons for encounters at sea, such as the provision of supplies, bait, fuel, spare parts, fishing gear, crew changes, and anything else we can think of. Analysing the duration of the encounter can be very helpful in identifying the reason.

It is a serious mistake to take for granted the boundaries that monitoring platforms present for the maritime spaces of coastal states without verifying that they correspond to the official ones.

Comparative experience across several Exclusive Economic Zones (EEZs) in South America indicates that the boundaries used by some of these platforms differ from the official ones, which often makes activities outside jurisdictional waters appear to be illegal fishing.

This issue has persisted for years regarding the Marine Regions boundaries used by Global Fishing Watch (GFW) for Argentina's EEZ, extending into the “Agujero Azul” / Blue Hole area to 4.4 nautical miles on the high seas. A similar discrepancy remains in the boundary between Uruguay's EEZ and Brazil's, with no corrections made so far.

Unequivocally linking illegal fishing to a vessel entering an area where it is not authorised to operate, without considering whether its movement patterns and dynamics are compatible with fishing activities for that type of vessel, thus failing to acknowledge the international right of free navigation that supports them.

Another issue identified in studies that track port arrivals using AIS is that poorly trained algorithms may mistake movements between anchorage areas, from these to port and vice versa, as new arrivals, significantly overestimating their numbers. This issue has been observed in studies on the arrival of fish cargo ships at the port of Montevideo.

It also leads to errors to analyse apparent fishing manoeuvres based on AIS positions without considering the type of vessel. This is because, depending on the fishing gear used by a vessel, the speed, fishing pattern, depth, and characteristics of the area of operation, and in some cases, even the time of day when the activity occurs, will vary, making it possible to associate it with an activity compatible with fishing for that type of vessel.

Associating the switching off of AIS directly with illegal activity without recognising that not all fishing vessels are required to carry this device or keep it switched on by their flag states, to whom international regulations delegate this responsibility, or that there are commercial competition reasons for doing so.

Added to this is the failure to consider that many coastal States, such as Argentina through its Coast Guard System, and various platforms for controlling fishing activity have the capacity to detect them using satellite imagery, regardless of their AIS transmission.

Finally, some machine learning algorithms on these platforms mistakenly classify activities as fishing that, to an expert, do not correspond to that type of manoeuvre for a given fishing gear. Such errors help to exaggerate fishing effort.

In conclusion, analysing the information from fishing activity monitoring platforms should not be done without taking the context into account.

Some trends identified by analysts, such as changes in service ports for distant-water fishing fleets due to stricter or, conversely, more relaxed controls, may simply reflect annual variations in fishery resources or commercial and logistical reasons when considered in context. For example, the collapse of the Tsakos Dock in Montevideo in December 2022 forced fishing vessels operating in Mile 201 to initially seek alternative ports in southern Brazil for repairs.

With proper use, interpretation, and contextualisation of the information, combining data from these platforms with the work of experts and researchers to monitor and control fishing activities is highly beneficial. However, if this combination fails, it can distort the reality of what is actually happening, potentially hindering efforts to find solutions, especially when such information is utilised by decision-makers.

This article is not intended to criticise monitoring platforms or the work of experts or researchers; on the contrary, the contribution of information and effort is highly valued. It simply aims to highlight the risks of using this technology out of context and without the necessary expertise.

A 45-Year Retrospective on the EU’s Fishing Access Agreements

In my view, in fisheries, there are way more “opinionholders” than “stakeholders”, which, interestingly, at least from what I can see, is the opposite of land-based primary production like agriculture, dairy, and forestry, for example. You read tons of news analysing fisheries issues, and very few on land-based, which, as I discussed before, is substantially more impactful.

In a similar vein, I see way more analysis in the news and academic papers on the EU Fisheries Access Agreements with other countries than on those from all the other Distant Water Fishing Nations (DWFN), even though all of them have access agreements.

Map of the network of fishing access agreements developed by the EU around Africa (A) and in the Pacific Ocean (B). Chances are you could not find the text and details of all these agreements for any other DWFN.

I think this “more attention” to the EU ones comes from the fact that the EU upholds higher standards than the rest of the DWFN, but also from its transparency….For a copy with all the details for each EU agreement, you just need to go to a webpage and download them. Yet for the ones for. CN, TW, and KR, for example, chances are you need to know people in really high places, and even so… you may not see all the details.

And as much as I have criticised many of the technical issues around EU Market Access, I have always been very upfront in recognising that it's all above board, you have open access to all documents… and, fundamentally, they have always funded capacity building activities not only for the countries they have agreements with but also for many others that theyu don’t… and that sepatates as well form other resource users + donors as the DWFN are.

Chances are that a paper like this one could not be written about the fisheries agreements of any of the other DWFN, simply because the information would not be available… simply as that. So whatever your opinion is about the EU fisheries agreements, you have to recognise that they are there for you to read and analyse… and that alone separates them from the rest of the DWFN.

With that said, I read with interest this paper, not just because of the agreements they have with two of the Pacific Islands I work with (Cooks and Kiribati), but also because of the work I have done inside the frameworks of agreements in African countries in the past (Guinea-Bissau, Mozambique, Senegal and Angola), and adding to that I know personally and have a lot of respect two of the authors.

Below is a summary, but as always, read the original!

Since the late 1970s, the European Union (EU) has negotiated fishing access agreements with developing coastal states, formalising the presence of its distant-water fishing (DWF) fleets in foreign waters. These agreements, which started with Senegal in 1979, have developed significantly over the past 45 years, reflecting shifts in geopolitical dynamics, economic interests, and sustainability concerns. This blog post offers a comprehensive overview of the findings from a recent study that examined the scope, scale, and impact of these agreements.

The Origins of EU Fishing Access Agreements ​

The foundation for modern fishing access agreements was established in 1982 with the United Nations Convention on the Law of the Sea (UNCLOS). ​This treaty introduced the concept of Exclusive Economic Zones (EEZs), granting coastal states sovereign rights over marine resources within 200 nautical miles of their shores. ​Article 62 of UNCLOS specified that coastal states should promote the optimal use of living resources and permit other states access to surplus resources through agreements.

For the EU, these agreements offered a chance to tackle overfishing in its domestic waters by reallocating surplus fishing capacity to the resource-rich waters of developing countries. This expansion was also motivated by the need to satisfy the EU population's increasing demand for seafood. Over time, the EU established a wide network of fishing access agreements, mainly with African and Oceanian countries, many of which were former colonies.

Evolution of EU Fishing Access Agreements ​

The study highlights three distinct phases in the development of EU fishing access agreements:

1980s Expansion, where the EU began with a single agreement with Senegal in 1979, growing to 12 agreements by the end of the decade. These agreements targeted a broad range of species, including coastal and demersal fish.

Peak Period (1990s–2000s) saw the highest number of agreements, averaging 14 at any given time, with geographical expansion into new EEZs in Africa and Oceania. The agreement with Angola was condemned in 2004, indicating the beginning of a decline. Recent

Decline (2010–2025) reflects a reduction to nine active agreements as of January 2025, driven by shifting geopolitical and economic interests and by increasing concerns about sustainability and fairness.

Key Trends in EU Fishing Access Agreements ​

The study highlights several significant trends in the composition, distribution, and economic scale of EU fishing access agreements:

1. Shift in Target Species: Early agreements targeted a diverse range of species, including coastal and demersal fish. Over time, the focus shifted primarily to large pelagic species, such as tuna, which now dominate the EU’s fishing efforts.

2. Reduction in Fleet Size: The number of EU vessels engaged in DWF operations has markedly decreased, from a peak of 1,812 vessels in 1999 to a median of 676 vessels since 2020. This decline is primarily due to the decrease in bottom trawlers and dredgers, especially from Spain.

3. Subsidy Allocation: Public subsidies have played a vital role in supporting EU fishing access agreements. Interestingly, small pelagic fisheries, which account for only 4% of vessels and 7.6% of tonnage, received 63.9% of the total €4.8 billion in subsidies allocated over 45 years. In contrast, large pelagic fisheries, which account for most of the fishing effort, received just 10.2% of the subsidies.

4. Geopolitical and Geoeconomic Dynamics: The study highlights how power imbalances shape access relationships. Coastal states often lack the industrial and financial capacity to develop competitive domestic fishing fleets, making them dependent on income from access agreements. However, these agreements can deepen inequalities, limit local access to seafood, and underestimate the value of resources extracted from their waters. (Yet in my opinion, this can be said about ALL fisheries agreements, at least the EU ones have funds earmarked for development and capacity building, something that others don’t.)

Case Studies: Morocco and Senegal ​

The study provides detailed case studies of Morocco and Senegal to illustrate the complexities of access relations:

• Morocco: The EU’s agreement with Morocco has undergone significant changes over time. At its peak in the mid-1990s, the agreement offered considerable fishing opportunities for small pelagics, demersal species, and large pelagics. However, by 2023, the scope of the agreement had been greatly reduced, with limited opportunities for demersal species and large pelagics. The future of this agreement remains uncertain, as the Court of Justice of the EU recently ruled that including disputed waters in Western Sahara is illegal.

• Senegal: The EU’s agreement with Senegal, the oldest in its network, has faced multiple challenges. It was terminated in 2006 under President Abdoulaye Wade, who prioritised local artisanal fishers and sought to protect overexploited fish stocks. Although the agreement was reinstated in 2014 under President Macky Sall, it faced strong opposition from local fishers and environmental groups. In late 2024, the EU and Senegal failed to renew their agreement, leaving its future uncertain.

Challenges and Implications ​

The study identifies several challenges associated with EU fishing access agreements:

1. Sustainability Concerns: Overfishing by industrial fleets, both legal and illegal, has depleted fish stocks in many coastal states. This has serious consequences for local fishers, forcing them into economic hardship and increasing irregular migration.

2. Transparency Issues: Although the EU’s agreements are regarded as the most transparent among DWF nations, there remains a lack of comprehensive data on the scope and characteristics of EU fleets operating in foreign waters.

3. Geopolitical Tensions: Agreements are influenced by complex geopolitical and geoeconomic factors, including colonial histories, trade treaties, and spheres of military influence. These elements often cause tensions between the EU and coastal states.

4. Equity and Fair Benefit-Sharing: The study emphasises the disproportionate distribution of subsidies to a small portion of the EU fleet, raising concerns about fairness within the EU and between the EU and coastal states.

The Future of EU Fishing Access Agreements

The future of EU fishing access agreements remains uncertain. The network of agreements has continuously evolved, and this trend is likely to persist. The EU faces a dilemma: it can either continue supporting its industrial fleets in foreign waters, which may cause local and regional resentment, or pursue more cooperative arrangements that emphasise fair benefit-sharing, local development, and sustainability.

Coastal states, on the other hand, will continue to examine different arrangements to optimise the use of their fishing grounds. ​ This may involve partnerships with non-EU fleets or alternative approaches such as joint ventures. ​ The study highlights the need for future research to compare the relative advantages of various access arrangements and to better understand the implications for sustainability governance.

Conclusion

EU fishing access agreements with coastal states of the Global South exemplify broader struggles over sovereignty, equity, and sustainability. While these agreements have secured the EU’s DWF fleets relatively stable access conditions, they have also revealed multiple tensions between economic interests, resource sustainability, and other factors.

Biodiversity Consequences of Replacing Animal Protein From Capture Fisheries With Animal Protein From Agriculture

This is not a new concept… some of the authors in this paper have been beating that drum for some years now ( I have written about it here and here )

I have long thought that fisheries seem to be subject to public scrutiny at different levels than agriculture… a typical example in NZ, around 1.1-2% of the EEZ, is actually bottom-trawled each year, primarily on established fishing grounds, while around 50-51% of NZ's total land area is used for agriculture and horticulture. Yet we mostly hear about the trawl impact.

The paper "Biodiversity Consequences of Replacing Animal Protein From Capture Fisheries With Animal Protein From Agriculture" examines the environmental and biodiversity impacts of substituting animal protein from marine capture fisheries with sources from agriculture. The authors argue that such a shift could exacerbate global biodiversity loss because agriculture has a more significant effect on ecosystems than the less invasive methods.

Below is a summary, but as always, read the original!

Introduction: The Sustainability Debate in Food Production

The paper begins by examining the growing global debate on sustainable food systems, particularly regarding animal protein consumption. Documentaries like Seaspiracy and Oceans have raised concerns about the sustainability of seafood, leading to calls to reduce reliance on marine capture fisheries. Although cutting down on meat and fish is often seen as environmentally beneficial, the authors challenge the notion that agriculture is inherently less impactful than fisheries, particularly when biodiversity is used as the benchmark.

Agriculture and Fisheries: Effects on Biodiversity

The authors emphasise the vital role of food production in causing biodiversity loss. Agriculture uses about half of the Earth’s habitable land, with 77% of this dedicated primarily to animal farming, mainly cattle rearing. This land conversion significantly drives biodiversity decline, especially in tropical forests, which are among the most biologically diverse habitats worldwide. The paper observes that agriculture often replaces complex ecosystems with simplified, human-managed systems, leading to irreversible impacts on biodiversity.

In contrast, fisheries primarily impact higher trophic levels in aquatic ecosystems, leaving the lower levels of the food chain relatively unaffected. Although fishing can lead to localised ecosystem changes and species depletion, well-managed fisheries aim to operate within the natural structures and functions of ecosystems, thereby reducing long-term damage.

Land Use Implications of Replacing Marine Protein with Agricultural Protein. The paper provides detailed calculations to estimate the land area needed to replace the protein currently obtained from marine capture fisheries with agricultural alternatives. If marine protein were replaced by the current proportional mix of livestock (beef, lamb, chicken, and pork), an additional 4.99 million square kilometres of land would be required—an area larger than the intact rainforest in Brazil. Replacing fish protein with grains or soy would require considerably less land, but the biodiversity impacts of such a shift remain significant.

The authors also examine the implications of replacing fishmeal in aquaculture with soy-based alternatives. They estimate that this transition could require up to 47,453 square kilometres of new agricultural land, further exacerbating biodiversity loss. While alternative feeds for aquaculture are being developed, the dominant option remains crops like soy, which carry their own environmental trade-offs.

Extinction Risks and Threats to Biodiversity

Using data from the International Union for Conservation of Nature (IUCN) Red List, the authors compare the extinction risks posed by agriculture and fisheries. Agriculture is identified as a significantly greater threat to biodiversity, with approximately 22,728 species listed as Critically Endangered, Endangered, or Vulnerable due to agricultural activities, compared to 2,143 species threatened by fishing. This disparity is attributed to the transformative nature of agriculture, which replaces native ecosystems with monocultures or non-native species, whereas fisheries generally do not involve habitat removal.

The paper also emphasises that agriculture poses considerable risks to aquatic species, including those in freshwater and estuarine systems. For example, agricultural activities such as dam construction and water extraction can disrupt aquatic ecosystems, amplifying the impacts of fishing. Even in marine environments, agriculture indirectly threatens species through coastal habitat degradation caused by agricultural runoff and pollution.

Trophic Level Impacts: Agriculture versus Fisheries

The authors explore differences in impacts across trophic levels between agriculture and fisheries. Agriculture primarily targets the bottom of the food chain (plants and primary producers), leading to the replacement of native species with crops and livestock preferred by humans. This transformation often triggers cascading effects on higher trophic levels, reducing biodiversity and altering ecosystem functions.

In contrast, fisheries primarily target higher trophic levels, such as predatory fish, leaving lower trophic levels relatively unaffected. Although specific fishing methods, such as bottom trawling, can affect benthic ecosystems, these effects are usually localised and less extensive than the widespread habitat loss caused by agriculture.

Trade-offs and Policy Implications

The paper emphasises the importance for policymakers to consider the broader effects of dietary changes and food production methods on biodiversity. While reducing livestock consumption and advocating for plant-based diets could decrease land use and biodiversity impacts, the authors warn against oversimplified solutions that call for the complete elimination of marine fisheries or the use of fish in aquaculture. Such approaches could lead to unintended consequences, including increased pressure on terrestrial ecosystems.

The authors argue that well-managed fisheries can be a sustainable source of animal protein while minimising impacts on biodiversity. Effective fisheries management practices, such as regulating harvests and rebuilding stocks, have already proven successful in improving fish stock status and reducing ecosystem disruption. Transitioning to protein from well-managed fisheries could help lessen biodiversity loss associated with rising agricultural production.

The Importance of Comprehensive Tools and Comparisons

The paper advocates for developing tools to compare the biodiversity impacts of different food production methods objectively. While Life Cycle Analysis (LCA) remains a valuable method for assessing environmental impacts, it often does not sufficiently account for biodiversity effects, especially in the context of seafood production. Incorporating ecosystem models and input-output analyses into LCA could provide more detailed insights into the trade-offs between land- and water-based food production systems.

The Role of Fisheries Management in Reducing Biodiversity Loss.

The authors emphasise the undervalued importance of effective fisheries management in reducing biodiversity impacts. By adopting sustainable practices, fisheries can minimise ecosystem changes and prevent the loss of iconic species. Better management could also lead to significant increases in fish catches, reducing dependence on land-based protein production and its associated biodiversity impacts.

Future Challenges and Ethical Considerations

The paper concludes by examining the complexities of future food production choices. The rise of fish-free "seafood" products and lab-grown animal proteins presents new challenges in assessing environmental and nutritional impacts. The authors highlight the importance of transparency in sourcing and manufacturing these alternatives, as well as the necessity for independent verification of sustainability claims.

Ultimately, the paper indicates that the increasing global population and wealth, particularly in developed nations, are driving unsustainable food production methods. Policymakers must carefully assess the impacts of dietary changes and agricultural methods to prevent further biodiversity decline and other environmental issues.

Key Takeaways

• Agriculture poses a greater threat to biodiversity loss than fisheries, due to its disruptive effects on ecosystems. 

• Land Use: Replacing marine protein with agricultural protein would necessitate significant land conversion, further threatening biodiversity.

• Extinction risks: Agriculture poses a greater threat to species extinction than fisheries, particularly for terrestrial and freshwater species. 

• Trophic Level Impacts: Agriculture affects lower trophic levels, leading to ecosystem changes, while fisheries primarily impact higher trophic levels. 

• Policy Implications: Policymakers should consider the broader biodiversity impacts of dietary changes and food production strategies, emphasising the importance of well-managed fisheries.

• Future Challenges: The rise of fish-free and lab-grown animal proteins requires a thorough assessment of their environmental impact and greenhouse gas emissions.

An Expanded Evaluation of Global Fisheries Management Organizations on the High Seas

As you all may know, I spend a lot of my work time and personal time working on transhipment issues in the WCPO…  I was involved in transshipments as a fisherman, as a compliance officer, as an observer training standards developer, as an algorithm developer with Starboard.nz, as a researcher (IUU quantification and Impracticability assessment), and as a policy operator both with the FAO Transhipment Guidelines and with the now-defunct WCPFC Transhipment Interseasonal Working Group, and so on… I think I know my stuff on this fishing reality.

Yet it is always interesting to read about it from a different perspective, so I was interested to read a recent paper, "An Expanded Evaluation of Global Fisheries Management Organisations on the High Seas," authored by Gabrielle Carmine et al., which provides a comprehensive review of how Regional Fisheries Management Organisations (RFMOs) perform in managing high seas fisheries. And also talks about a topic I also worked on recently, MPAs in ABNJ

While not its primary objective, the paper focuses on transhipment at sea, which has been linked to higher risks of IUU fishing and other illegal activities. Interestingly, the WCPFC scores well on overall sustainable management of the fishery, yet we still have the loosest HS Transhipment scheme among tRFMOs.

So yeah… below is a summary, but as always, read the original!

The high seas, which constitute nearly half of the Earth's surface, are crucial for global biodiversity and fisheries. Yet, industrial fishing activities have led to significant biodiversity loss, overfishing, and bycatch, posing challenges to the sustainability of marine ecosystems. RFMOs carry a dual mandate under the United Nations Fish Stocks Agreement (UNFSA) of 1995: to ensure the long-term conservation of fish stocks and their ecosystems, and to manage the sustainable use of high seas fisheries.

The study evaluates 16 active RFMOs using 100 performance questions across ten categories, including access and equity, bycatch reduction, illegal, unreported, and unregulated (IUU) fishing prevention, integration of scientific knowledge, spatial management, and stakeholder participation. The authors assign scores (0, 0.5, or 1) based on publicly available information such as meeting documents, conservation and management measures (CMMs), and convention texts.

The average score across all RFMOs was 45.5 out of 100, with the highest being 61.5 for the Western and Central Pacific Fisheries Commission (WCPFC) and the lowest at 29.5 for the North Atlantic Salmon Conservation Organisation (NASCO). Notably, no RFMO achieved a perfect score in any category, highlighting significant performance gaps.

The study found that only one RFMO, the South-East Atlantic Fisheries Organisation (SEAFO), has implemented a complete ban on transhipment at sea. Five other RFMOs—GFCM, IATTC, ICCAT, IOTC, and WCPFC—maintain partial prohibitions, which were rated at 0.5 points in the evaluation. The remaining RFMOs have no restrictions on transhipment at sea, leaving this practice largely unregulated in many high-seas areas. The authors argue that a complete moratorium on transhipment at sea could bring substantial ecological and social benefits, including reducing IUU fishing, safeguarding high seas biodiversity, and addressing human rights issues.

The paper also stresses the importance of RFMOs adopting more rigorous measures to tackle the challenges of transhipment. These include enhancing monitoring and enforcement mechanisms, increasing transparency in transhipment activities, and applying policies that follow the precautionary principle. The authors recommend that RFMOs work together with the United Nations Biodiversity Beyond National Jurisdiction (BBNJ) treaty, which will come into force in 2026, to establish marine protected areas (MPAs) and improve governance frameworks.

The study's findings suggest that RFMOs are not meeting their mandates to manage high-seas fisheries sustainably and to conserve marine biodiversity. Despite having policies and best practices in place, there is little correlation between RFMO management performance and positive outcomes, such as reduced overexploitation of target stocks or lower fishing intensity. Reactionary policymaking, external environmental factors, and ineffective enforcement of RFMO measures may cause this disconnect.

The authors recommend several measures to enhance RFMO effectiveness, including the establishment of permanent no-take MPAs covering at least 1% of RFMO convention areas, immediate reductions in allowable catches to combat overfishing, and a complete ban on transhipment at sea. They contend that no-take MPAs are more successful than multi-use protected areas in achieving conservation objectives, as they support considerably higher fish biodiversity and can provide spillover benefits to nearby exclusive economic zones (EEZs). Furthermore, banning transhipment at sea would mitigate the risks of IUU fishing and improve transparency and accountability in high seas fisheries.

The paper also highlights the importance of good governance in RFMOs to prevent regulatory capture and ensure fair decision-making. The authors note that some RFMOs have allowed industry representatives to participate in decision-making processes, raising concerns about conflicts of interest and the risk of regulatory capture. They advise RFMOs to adopt robust governance measures, such as those used by the International Pacific Halibut Commission (IPHC), including comprehensive rules to manage conflicts of interest.

In conclusion, the paper highlights the urgent need for RFMOs to improve their performance in managing high-seas fisheries and conserving marine biodiversity. The authors advocate for stronger collaboration between RFMOs and the BBNJ treaty to address existing governance gaps and implement effective conservation measures. By prioritising long-term conservation and adopting a precautionary approach, RFMOs can better fulfil their mandates and support the sustainable use of high seas resources.

How many of you and where do you read this from!

At this time of the year, for every app we have, we have been given a complete set of statistics on how the year was. So I thought I'd do the same, in case any of you care.

And when I say you... I very rarely know who you are... As a self-employed consultant, I hardly get the chance to attend conferences and events like that, so when I do get invited, it's always great when someone comes up and says, "Hi, I read your blog and like this or that, or it's good to read what you think about this and that`’

Yet I remind myself constantly that writing a blog does not make one meaningful!

In any case, for 2025, there have been 24,000 visits, with 21,000 unique visitors who read 31,000 pages. Most of you (11500) come directly to the page, use Windows (12923), and browse with Chrome.

 Currently, 25% of you are based in the USA, 10% in China, 6.28% in Australia, and 4.73% in the UK... which, interestingly, are all countries I haven’t worked in.

Now… I also realised recently that I started this blog in January 2014 just because it was offered for free with the template I chose from Squarespace – the hosting platform for this website – and not because I had any inkling of being a blogger.

And as such, I can tell you that in the last decade, this blog has been viewed 387,000 times by 245,000 unique visitors across 298,000 visits. (It peaked in 2022 during the COVID pandemic at 38000 visits, but also then I quit most social media, so a lot of traffic subsided too)

Needless to say, these figures are truly astonishing for me, since I see myself as a fisheries operational consultant who writes a blog in my free time and not a “science communicator'‘, and I don’t have any form of sponsorship or pay for promoting this blog

Thank you all for your time and interest. I wish you all a beautiful time off with your loved ones.

A New Seafood Import Policy for Nations to Combat Illegal Fishing

As you may know from my work, if by some obscure reason you have been reading my blogs for the last 12 years, Catch Documentation Schemes has been one of my main professional frustrations.

I started working on them back in 2009, while employed by FAO, following their mention in the PSMA, and continued through the frustrations of the EU CCS (2010) and the long, disappointing story of the never-to-be-advanced WCPFC CDS (2013). I was also the author of the initial draft and a later part of the secretariat for the FAO CDS technical consultation (2015) and the 2017 voluntary guidelines. Additionally, I co-wrote a seminal book on the subject with my friend Gillies, linking traceability to fisheries compliance, and peer-reviewed two other books he authored. Further frustrations arose with FFA CDS. Recently, I documented all the CTEs and KDEs for end-to-end traceability in both fisheries and aquaculture for FAO, which, to date, has not been used by any RFMO.

the way everything starts

The frustrations come primarily out of the unilateralism of those imposed by end markets (being quite critical of them for many technical reasons) and the lack of political will to set up fisheries forward ones out of RFMOs (especially the WCPFC)

This does not mean I don’t keep track of what is happening and being written, particularly when the authors are people I know, like the first 3 in this paper: Leslie Roberson, Gilles Hosch, and Chris Wilcox.

Their paper, A New Seafood Import Policy for Nations to Combat Illegal Fishing, while not explicitly written for the timid noises Australia has been making about setting up a unilateral one… I feel it was meant for Australia, and hence you can argue it's “new”

I like this paper because it summarises the shortcomings of unilateral CDS over the past 15 years. I can now send questions about the EU CCS, US SIMP, the Japanese one, and other unilateral initiatives to this document instead of coming over my blogs and books!

It is a good and informative paper. Below is a summary, but as always, I recommend you read the original!

The complexity and opacity of global supply chains make it difficult to trace the origins of seafood products. Compared to other agricultural commodities, seafood import controls are severely inadequate, leaving consumer countries vulnerable to the entry of illegal products into their markets.

Currently, only three major market regions—the European Union (EU), the United States, and Japan—have enacted legislation targeting IUU seafood imports. These systems, while important, are riddled with loopholes and do not fully guarantee the legality and traceability of seafood products. For example, the EU’s catch documentation scheme, introduced in 2010, is paper-based, which makes it vulnerable to fraud. Although updates are scheduled for 2026, the digitisation will only take place at the final point of trade, leaving earlier stages of the supply chain exposed. Similarly, the United States’ Seafood Import Monitoring Program depends on importers to gather and maintain supply chain documentation, but it lacks a centralised tracking system. Japan’s catch documentation scheme, implemented in 2022, covers only four species groups, limiting its scope.

The paper stresses the importance of wider adoption of import controls by more countries to strengthen global efforts against IUU fishing. Countries like Australia, which imports two-thirds of its seafood, have the chance to create leading systems that promote multilateral cooperation. Australia has been a regional leader in fighting IUU fishing through initiatives such as the Regional Plan of Action on IUU fishing. However, it currently lacks specific import controls to stop IUU seafood from entering its borders. The Australian government is working on a seafood import regulation policy aimed at IUU products, building on existing examples from RFMOs and other market states.  

The authors identify two main types of trade measures used to track the origins and verify the legality of internationally traded seafood: catch documentation schemes and import monitoring programmes. Catch documentation schemes, as defined by the Food and Agriculture Organization (FAO), begin at the fishing vessel with the issuance of a catch certificate that links to subsequent trade documents throughout the supply chain. These schemes are either multilateral, carried out by RFMOs, or unilateral, implemented by market states. Import monitoring programmes, on the other hand, require trade documentation at the point of import but lack a traceability mechanism covering the entire supply chain.  

The paper highlights key flaws in current systems, including limited control over complex supply chains and arbitrary enforcement mechanisms. Multilateral trade measures are preferred over unilateral systems, as they can prevent IUU fishing across entire species or stocks. However, the three existing RFMO catch documentation schemes only cover a few species, reducing their effectiveness. Diplomatic efforts to encourage more countries to adopt these measures are essential. Furthermore, enforcement triggers in current systems are often inconsistent and lack transparency, which diminishes their effectiveness.

To overcome these limitations, the authors suggest eight essential design standards for improved seafood import control systems.

1. Fully Electronic Catch Documentation System: A digital system for issuing and storing catch and trade certificates is crucial for effective traceability and preventing fraud.  

2. Linked Certificates Along the Supply Chain: Certificates should be sequentially connected to ensure traceability from the fishing vessel to the final market.  

3. Centralised Certificate Registry: A centralised electronic registry accessible to authorised parties can reduce fraud and encourage multilateral participation.  

4. Automated mass balance monitoring: Automated systems should identify discrepancies in the supply chain, preventing unauthorised products from re-entering certified supply chains.  

5. Official Validation Process: Public authorities should supervise the validation and certification procedures to ensure authenticity and compliance with regulations.  

6. Integration With Trade System Infrastructure: The system should seamlessly integrate with existing trade and customs processes to streamline operations.  

7. Minimum Key Data Elements and Unique IDs: A standardised set of essential data elements and unique identifiers can facilitate interoperability and effective tracking.

8. Broad Scope of Species Coverage: Trade measures should encompass a wide variety of species to prevent mislabelling and ensure thorough traceability.

The authors highlight the importance of designing systems that are flexible, automated, and self-enforcing. Countries like Australia can take the lead by adopting systems that complement and build upon existing frameworks in the EU, US, and Japan. A centralised and collaborative certification system would reduce compliance burdens and simplify the current patchwork of regulatory arrangements. Digital traceability systems, such as blockchain technology, can improve trust and transparency in seafood supply chains, making it easier for small-scale actors to participate.  

In conclusion, the paper urges market states to take a leadership role in fighting IUU fishing by implementing effective import control measures. By adopting well-designed systems and supporting multilateral cooperation, consumer countries can play a crucial role in enhancing the sustainability of global fisheries and reducing the ecological and social harms related to IUU fishing.  

EU updates regulations on brine-frozen tuna for direct human consumption

Most of my current work is on the MCS. PSM and labour side – it wasn’t always like that… For over a decade, the central focus of my job was EU market access from both the sanitary and IUU perspectives. I was heavily involved in helping many countries access or maintain sanitary authorisation and remove yellow cards.

On the sanitary side, my area of specialisation was vessels and landing sites. In that domain, I carried out extensive work for the EU through its Better Training for Safer Food (BTSF) programme. Subsequently, I focused on drafting EU market access guides that explain the complex double authorisation system countries must navigate to export to the EU. The latest version I wrote for FFA is here.

While it is a long story, one of the tenets that the EU had was that when tuna was frozen in brine (as in purse seine), it could be ONLY used for canned tuna, and such could be maintained along the cold chain at -9°C while in brine, which had to be kept at -18°C if held in “dry” (as opposed to “wet” while in brine) stores.

This is because 30 years ago, if you had brine (seawater and salt in a highly concentrated solution often maintained at around 21% to 23.3% salt by weight), the density increased the cooler you made it… to a point that beyond -15°C it became challenging to circulate with the standard pumps and pressures we had at the time; furthermore, the fuel consumption increased significantly the cooler the brine became.

If you are interested in the process and physics of freezing, you can download and read this chapter of a book I co-wrote years ago about cold chains in fishing.

In summary, fish are mainly water, typically 60–90 per cent depending on the species, and freezing converts most of this water into ice. Freezing involves removing heat, and fish from which heat is extracted decrease in temperature, as illustrated below. During the initial cooling phase, the temperature rapidly drops just below 0°C, the water's freezing point. As more heat needs to be removed in the second phase to turn most of the water into ice, the temperature changes only minimally; this is known as the period of "thermal arrest". When approximately 55% of the water has frozen, the temperature begins to fall sharply again, and during this third phase, most of the remaining water freezes. This final stage requires removing only a small amount of heat. 

Temperature-time graph for fish during freezing

Fish quality mainly depends on the speed of freezing, especially the time it takes to reach -5°c. At this point, ice formation begins through nucleation, where supercooled water molecules organise into a stable, ordered ice crystal structure. This initial "nucleus" then expands rapidly, releasing latent heat and causing the surrounding liquid to freeze; the faster this process happens, the smaller the ice crystals within the cells, resulting in less cellular damage and better quality when the fish is thawed.

Purse seine brine freezing is intended to quickly freeze large quantities of fish, which works well but compromises quality and salt penetration in the surface tissues beneath the skin. For many decades, this was not an issue because all PS fish was destined for canning, where tuna is peeled and overcooked twice (once before canning and then again in the can).

In the old days, no one sensible would take a skipjack or a yellowfin that had been three weeks in messy brine and cut it up for steaks... That is what you do with longline fish, which are killed individually and quickly frozen in blast freezers.

However, all of this changed in the last decade… in two ways;

FAD fishing: Before the nearly exclusive FAD fishery we have today, most tuna was caught in free schools… and these were very consistent in species composition… Usually, almost all skipjack and sometimes yellowfin. You might have encountered yellowtail Seriola lalandi (also known as yellowtail kingfish, hiramasa, or great amberjack), but not much beyond that. With the advent of FAD fishing, catches became very mixed, including yellowfin and bigeye (though mostly juveniles), which, of course, fetch a much higher price than skipjack in the direct-to-consumer market. This creates an incentive for fishermen to sell these as such, even if they were frozen in brine and intended only for canning. If not for canning, they could only be stored at temperatures below -18°C.

Certainly, this caused many issues for the CA of the flag states regarding control, as well as for consumers experiencing histamine problems. When tracing back through the chain, the catching vessel is a PS, so that fish should not have entered the direct human consumption value chain.

Better and newer vessels; a lot of newer vessels started setting some of dry lockers at the stern as blast freezers, so the fish is brailed on board, and the crew take the bigger yellowfin and freezes them there and creates a 2nd stream of freezing on board, which then is aimed at the ready-for-human-consumption value chain of frozen tuna. Yet on newer vessels, more efficient refrigeration systems allow freezing in brine at -19 to -20°C by tweaking and fine-tuning brine density between 19.8° and 22° in the Baumé scale. It is also essential to work with the lowest possible suction temperatures in the cooling system available

So, with all these changes, the EU has faced the need to update its regulations to reflect reality. One of my friends in DG SANTE approached me about this in 2021, so it has been in progress for some time. 

Audits and official controls have shown that some tuna suppliers have falsely sold canned-grade tuna frozen in brine at -9°C as suitable for direct ‘fresh’ human consumption within the EU market. This practice endangers consumers by exposing them to scombroid food poisoning caused by potentially high histamine levels. The issue has been confirmed by an increasing number of notifications issued via the EU’s Rapid Alert System for Food and Feed (RASFF) concerning histamine levels exceeding permissible limits in vacuum-packed, thawed tuna loins treated with additives to imitate freshness, leading to confirmed cases of food poisoning.

Finally, on 29 October 2025, the European Commission (EC) officially adopted Delegated Regulation (EU) 2025/1449, amending Annexe III of Regulation (EC) 853/2004 to establish new standards for frozen tuna in brine. Under the new rules, only vessels proven capable of maintaining a continuous freezing process that reduces core tuna temperatures to –18°C may use brine freezing for tuna destined for direct human consumption.

The regulation requires that temperature reduction be continuous. For direct brine freezing, whole round tuna must reach –18°C within 96 hours of first entering the brine and must drop below 0°C within 24 hours. If first cooled in clean seawater, the water must be cooled to 3°C within 6 hours and to 0°C within 16 hours. Once in brine, the tuna must reach –18°C at its centre within 72 hours. 

Interestingly, adding to the EM world, to ensure process integrity, freezer vessels must be equipped with real-time electronic brine-temperature monitoring systems that transmit data onshore, allowing food business operators and authorities to access them.

Furthermore, operators must develop a validation plan that demonstrates their vessel’s freezing capacity, including kinetic studies linking brine temperature with core tuna temperature, and certification confirming that temperature sensors meet international measurement standards.

Authorised third-country Competent Authorities (CA) are responsible for reviewing this plan during their vessel’s approval or listing process. The amended regulation is set to come into force from 27 January 2026.

This would introduce significant complexity to the systems of the four countries (PNG, Fiji, Solomon Islands, and Kiribati) in the WCPO (hopefully five soon, now that RMI is being evaluated).

The issue is that most of the PS are only flagged to the country, but their home ports are in TW, CN, and KR, where they used to be flagged. While EU rules are meant to be applied equally across all EU-authorised countries, most of these vessels appear to breach these regulatory requirements only when they fly a Pacific Island country’s flag. They complain that the regulations are too demanding and that KR or TW CA never asked for anything like an HACCP plan. 

I have boarded hundreds of DWFN-flagged PS ships over the past 20 years. Most of them should not have been approved, as they do not meet even the basic requirements... and since they haven't been in the home port for over two years, they haven't been inspected at all... so the EU DG SANTE expects a lot from countries like RMI to prove they have CAs that are equivalent to those in Germany or France. Yet, the CAs of KR, TW, and CN seem to have no control over their vessels outside their waters.

While I endorse the changes that DG SANTE has implemented, and if I were in a position where my opinion mattered, I would advise that DG SANTE, either directly, through MoUs with national CAs, or with support from the EU delegations (where they already have DG MARE staff), station officers in the main Pacific ports. These officers should conduct independent boarding operations to ensure a level playing field for the Pacific Islands and the DWFN.

In my professional opinion (I used to train EU seafood inspectors), such DWFN vessels/fish should not be approved for EU exports, and their CAs should have their authorisations suspended. 

Fshers and seafarers in international law – Really so different?”

One of the issues I find most challenging to explain to people working in other seafaring industries (cargo, research, exploration, transport, etc.) is that fishers are not considered seafarers… There are fishing boats that are larger than many other working vessels, like tugs and local ferries. Yet, the crew on these vessels have more regulatory protections under international agreements than fishers.

And while I know from experience, the extent to which this difference is entrenched became very clear to me while writing the fisheries chapter for the forthcoming Oxford Handbook of Human Rights at Sea.

The global fishing industry employs around 39 million people worldwide, yet despite its significance, fishers face systemic marginalisation under international law compared to seafarers, who benefit from stronger protections and greater global recognition.

So, I have been searching for someone who has conducted a comprehensive academic analysis of the justifications for this disparity, which undoubtedly stems from historical, structural, cultural and institutional differences. 

And found it!  All this is discussed in Daphne Guelker’s comprehensive paper: “Fishers and seafarers in international law – Really so different?” published in Marine Policy in 2023.

So here is a summary, but as usual, I recommend reading the original

The Legal Divide: MLC vs. C188

Two key international conventions govern the rights and protections of workers at sea: the Maritime Labour Convention, 2006 (MLC), and the Work in Fishing Convention, 2007 (C188). While the MLC is widely ratified and regarded as a success, C188 has struggled to garner support, with only 20 ratifications so far. The MLC explicitly excludes fishers from its definition of "seafarers," leaving them subject to the weaker protections under C188. This exclusion has resulted in significant consequences for fishers, including limited access to shore-based facilities, greater risk of abandonment, and fewer enforcement mechanisms compared to seafarers.  

COVID-19 and the Crew Change Crisis  

The COVID-19 pandemic revealed significant disparities in the treatment of seafarers and fishers. The "crew change crisis" left around 400,000 seafarers stranded on vessels, unable to return home or receive wages. This crisis attracted extensive media coverage and prompted initiatives like the Neptune Declaration, which aimed to support seafarers' well-being and secure their access to vaccines, health protocols, and repatriation. However, fishers, who encountered similar difficulties during the pandemic, were largely excluded from these efforts. Many fishing crews were stranded in foreign ports without access to communication, health services, or the protections granted to seafarers.  

Four Key Reasons for the Disparity  

Guelker outlines four main reasons for distinguishing between fishers and seafarers under international law.

Diverse Fisher Populations: The fishing industry covers a broad spectrum of activities, from small-scale artisanal fishing to large-scale commercial operations. The absence of a universally agreed-upon definition of small-scale fisheries (SSF) complicates efforts to establish global standards. While C188 aims to address these issues, its flexibility allows countries to exclude specific categories of fishers, leading to inconsistent protections.  

Employment Structures: Unlike seafarers, who usually work under formal employment agreements, many fishers operate under "share of catch" arrangements. This system often classifies fishers as self-employed, excluding them from labour law protections. Even employed fishers face exploitative conditions, such as long working hours, poor living conditions, and limited access to collective representation.  

Historic and Modern Maritime Zones: Traditionally, fishing was seen as a domestic issue, with vessels operating within their own territorial waters or on the high seas. However, the modern law of the sea has extended maritime zones, bringing fishing activities under foreign jurisdictions. Despite this change, fishing has not been recognised as a globalised industry that requires coordinated international responses, unlike seafaring. 

Institutional Representation: The International Maritime Organisation (IMO) has played a vital role in establishing robust protections for seafarers, including the MLC. In contrast, the fishing industry is governed by a fragmented system involving the IMO, the International Labour Organisation (ILO), and the Food and Agriculture Organisation (FAO). This piecemeal approach has led to overlapping and inconsistent initiatives, further marginalising fishers.  

Consequences of Marginalisation ​

The weaker protections for fishers have resulted in serious consequences. Fishing remains one of the most dangerous occupations worldwide, with mortality rates considerably higher than those in other industries. The FAO estimates that between 24,000 and 32,000 fishers die each year, primarily involved in small-scale fisheries. Accidents, injuries, and deaths are common due to hazardous working conditions, lack of safety gear, and extreme fatigue. Fishers frequently work long hours, suffer from poor nutrition, and get insufficient rest, which heightens the dangers of their occupation. 

Cases of "sea slavery" and forced labour in the fishing industry have attracted media attention. Still, these extreme cases obscure the broader issues of labour exploitation and unsafe working conditions faced by most fishers. Initiatives aimed at tackling illegal, unreported, and unregulated (IUU) fishing have concentrated on fighting forced labour and human trafficking, but do not address the full range of fishers' rights. 

Proposed Solutions

To tackle the disparity between fishers and seafarers, Guelker proposes several solutions.

Promote C188 Ratification: A collective effort is required to encourage states to ratify and implement C188. This would help harmonise protections for fishers across countries and ensure broader coverage.

Extend MLC Protections to Fishers: Including large-scale commercial fishers under the MLC could provide consistent protections for a significant portion of the fisher population. However, this would necessitate extensive renegotiations and political commitment.

Strengthen Collaboration Among International Organisations: The FAO, ILO, and IMO should work together to develop a clear strategy for promoting fishers' rights. This includes actively advocating for the ratification of relevant conventions and monitoring the implementation of non-binding instruments.

Engage Regional Fisheries Bodies (RFBs): RFBs should be encouraged to align their initiatives with international standards and promote the ratification of relevant conventions among their members. This would help reduce the fragmented nature of protections for fishers. This is happening, as we have seen in the case of the WCPFC.

Address Structural Barriers: The unique employment structures in the fishing industry, such as share fishing, should not be used as an excuse to deny fishers basic protections. C188 has demonstrated that these arrangements can be addressed through Fisher's work agreements.

 Conclusion

The differentiation between fishers and seafarers under international law is unjustified and has led to significant disparities in protection. Fishers face hazardous working conditions, exploitation, and marginalisation, despite their critical role in global food security. While extending MLC protections to fishers may be challenging, promoting C188 ratification and fostering collaboration among international organisations and RFBs are more immediate and feasible solutions. A unified and harmonised framework is essential to ensure safety and decent work for all fishers, regardless of their classification or the scale of their operations.

Una entrevista in Spanish

While Spanish is literally my mother’s language (my mum spoke Spanish to me, my dad -Austrian- spoke German, and my village language was Guarani), I barely work in Spanish… In fact, I work more in Portuguese than in Spanish… even if my schooling and 1st university degree were in Spanish.

I suppose that, as I left Argentina two weeks after submitting my thesis, with most of my experience being in fishing and as a science technician aboard research vessels, I never had the chance to “grow” professionally in Spanish. Consequently, I’m not recognised in that world... but also, and as the Bible states (Luke 4:24), “no one is a prophet in his own land.”

While I was working for FAO in Rome, I liaised with the Spanish industry and the Spanish Association for Standardisation and Certification (AENOR), and I enjoyed it. But that was a long time ago.

I was pleasantly surprised and somewhat intrigued when the editor of Industrias Pesqueras (IP), a leading Spanish maritime and fishing industry magazine published since 1927 and regarded as the primary reference for fishing and marine activities in Spain and Portugal, asked me for an interview.

The result (in Spanish) is below… it covers my views on fishing, its sustainability, the business (and hypocrisy)  of ecolabels, geopolitics, and how we degraded the labour side by commoditising crew as a cost rather than an investment. And similarly, we expect excellence from scientists and regulators, yet we pay for mediocrity at best.

I also discuss the double standards that seem to apply to fisheries compared to land-based activities, and how we would rightly make a fuss if there were a discussion panel on gender issues with four men in their 60s. However, I have rarely seen panels on fisheries and labour rights where any of the panellists have ever worked as fishers.

So yes, apologies to my only English readers; this blog is for those (like me) who grew up speaking Spanish, the second most spoken colonial language (English is the most spoken colonial language overall – including native and non-native speakers – mainly because of its role as a global lingua franca).

I am very thankful to Nieves García Figueira, IP deputy director of the magazine and interviewer for such a candid and frank interview and to the IP magazine for the opportunity.

The End of the Age of NGOs?

I have had a complex relationship with NGOs over the decades. I do share some of the aims… but generally not the methods they use

In 1992, a Tongan friend shared a cultural lesson that I have not forgotten… Being young and still a fisherman, I was pretty harsh and confrontational in my manner of speaking. So he asked me: Francisco, if I told you that ‘you are ugly’, how does that make you feel? I replied: I know you are right, but I wouldn't like it. … What if I had said: ‘It's a pity that your inner beauty as a person is not reflected in your external appearance,' how do you feel now? He still told me I’m ugly. But I felt like hugging him for understanding me instead of getting angry.

looking undeeath the fish is always a good idea.

And that approach I had then is generally what I struggle with them now… I’ve been part of many fisheries meetings, and when some NGO people fail to influence change, it’s usually because they complain without attempting to understand. They give speeches berating participants, fail to consider trade-offs, and assume that everything is simpler than it is, imagining that the only reason anyone would disagree with them is that they’re corrupt and/or stupid. They accuse the bodies of not listening, but they don’t even attempt to hear. When they’re done, the meeting chair says, “Thanks for your input,” and moves on because they haven’t contributed anything that might sway anyone’s position.

Of course, this is not a universal rule that applies to everyone. I do some work for certain NGOs, but honestly, it's because I like the people I work for. I usually do not compromise my views... A few years ago, I left a very well-paid advisory position with PEW because I felt they were taking a “white saviour” stance on a technical issue and opposing the collective decisions about the Pacific Island countries. So, although I really like my manager, I decided to end the contract.

I think sometimes that is mainly caused by a limited view of what “reality” looks like for others and a bit of ignorance about the VERY recent past of colonisation in many Pacific island countries… I always remind people that, at 60, I’m older than all the countries I work with… and it was the same when I was 30!

Yet I’m very aware of people in NGOs who do an excellent job, have built trust with many partners, and are genuinely committed to being part of the solutions rather than just pointing out problems. My friend Bubba Cook is the first person who comes to mind in this category (even if we disagree on the “positive” role of ecolabels)

So, when I read this article “The End of the Age of NGOs? How Civil Society Lost Its Post–Cold War Power” in the Foreign Affairs magazine, I was genuinely eager to explore it, even if it has a Cold War and political perspective, more than an enviremantal one… yet does not escape my views on cold war roots of tuna diplomacy and the colonial nature of the work I do.

Below is a summary; however, as always, I recommend reading the original for the full context.

—

The 1990s marked a golden era for nongovernmental organisations (NGOs), as their numbers surged and their influence expanded globally. ​ Renowned organisations like Amnesty International, Greenpeace, and Oxfam thrived during this period, championing liberal causes such as LGBTQ rights, environmental protection, and human rights.

Between 1990 and 2000, the number of international NGOs increased by 42%, and thousands of new organisations were founded. NGOs became key players in shaping state policies, delivering humanitarian aid, and influencing global governance. ​ Their efforts led to significant achievements, such as the adoption of the Anti-Personnel Mine Ban Convention in 1997 and the UN Convention Against Corruption in 2003. ​

The post-Cold War era was characterised by optimism about the role of civil society in creating a better world. ​ NGOs were seen as principled actors, distinct from governments and private companies, and were praised for representing marginalised voices and providing essential services. ​ They gained legitimacy by influencing international negotiations and delivering foreign aid, often in partnership with national governments. ​ The rise of NGOs was heralded as a "power shift" from states to global civil society, with many believing that NGOs could drive progressive policy changes and improve service delivery worldwide. ​

However, the landscape has shifted dramatically in recent years. ​ Between 2010 and 2020, the growth of international NGOs stagnated, with their numbers increasing by less than 5%. ​ Public scepticism about NGOs has deepened, governments have developed strategies to undermine their activities, and funding sources have begun to dry up. ​ The result is a significant decline in NGOs' political power and capacity, with states reclaiming much of the influence they had lost. ​

Mounting Criticism of NGOs ​

Over the past two decades, criticism of NGOs has intensified. ​ Sceptics from across the political spectrum have questioned their effectiveness, accountability, and political influence. ​ While NGOs have made efforts to address these concerns—such as implementing transparency initiatives and localisation strategies—public trust in the sector has eroded. ​ High-profile scandals, such as the sexual exploitation cases involving Oxfam Great Britain in Haiti and the Democratic Republic of the Congo, have further damaged the reputation of NGOs. ​ These incidents have led to accusations of corruption, fraud, and unethical behaviour, undermining the public's perception of NGOs as principled organisations. ​

The Edelman Trust Barometer, which measures public trust across 28 countries, revealed a significant shift in 2021: for the first time in 25 years, businesses were trusted more than NGOs. ​ By 2025, businesses were perceived as nearly as ethical as NGOs and far more competent. ​ This growing scepticism has made it increasingly difficult for NGOs to maintain their legitimacy and secure funding. ​

Government Crackdowns on NGOs ​

The decline in NGO power has coincided with a global erosion of democratic norms. ​ In the 1990s, the liberal international order supported the growth of NGOs, even in nondemocratic countries like China and Zimbabwe, where governments allowed NGOs to deliver essential public goods. ​ However, as democracy has waned in recent years, governments have become more hostile toward NGOs, particularly those advocating for human rights, environmental protection, and democracy. ​

Authoritarian regimes have implemented strict regulations to suppress NGOs, fearing that their activities could lead to democratisation or regime change. ​ Russia, for example, passed laws in 2006 and 2012 that imposed severe restrictions on NGOs, including labelling foreign-funded organisations as "foreign agents" and subjecting them to burdensome reporting requirements. ​ These laws have served as a model for similar legislation in countries like Georgia, Hungary, and Kyrgyzstan. ​ In India, Prime Minister Narendra Modi's government has revoked the registrations of thousands of foreign-funded NGOs, including Greenpeace India, citing alleged violations of the country's Foreign Contributions Regulation Act. ​

Governments have also created "zombie" NGOs—organisations that mimic legitimate civil society groups but serve state interests. ​ These government-organised NGOs undermine genuine advocacy efforts and erode public trust in the sector. ​ For example, low-quality election monitors in countries like Azerbaijan and Zimbabwe have been used to legitimise flawed elections. At the same time, government-organised NGOs have submitted reports to the UN praising repressive regimes. ​

The growing influence of nondemocratic powers like China and Russia has further emboldened governments to suppress NGOs. ​ Research shows that countries with closer economic ties to China are more likely to repress NGOs, as Beijing does not use trade sanctions to promote human rights. ​ Russia has also worked to discredit Western election observers and democracy promotion efforts, encouraging other countries to adopt similar strategies. ​

Financial Struggles and Shrinking Resources ​

The financial challenges facing NGOs have been exacerbated by declining government support for foreign aid. ​ Budget constraints, competing priorities, and populist opposition have led to significant cuts in development assistance from major donor countries. ​ In 2024, overseas development assistance from top donor countries in the Organisation for Economic Cooperation and Development fell by over 7%. ​ The United States, under President Donald Trump, has drastically reduced foreign aid programs, and European countries like Germany, the United Kingdom, and France have also made steep cuts to their development budgets. ​

The closure of the U.S. Agency for International Development (USAID) in 2025 marked a significant blow to the NGO sector, as it was a primary source of funding for many organisations. While some private donors and foundations have stepped in to fill the gap, their resources are limited compared to those of governments. ​ As a result, many NGOs have been forced to downsize, curtail their activities, or shut down entirely. ​ This has had a devastating impact on humanitarian relief efforts, vaccine administration, and other critical programs. ​

The Shift in Power ​

The decline of NGOs has led to a shift in power back to states, particularly nondemocratic governments. ​ By suppressing NGOs, these governments can control information, stifle dissent, and avoid accountability for failing to meet international standards. ​ This shift has contributed to the global decline of liberal norms and values, as states become more insulated from external pressure. ​

The weakening of the NGO sector also represents a loss for democratic governments, which have historically benefited from the advocacy and service delivery provided by these organisations. ​ Former U.S. Secretary of State Colin Powell once described NGOs as a "force multiplier" for achieving U.S. foreign policy goals, including democracy promotion and human rights protection. ​ By reducing foreign aid budgets and undermining NGOs, Western governments are relinquishing a key source of influence in global politics. ​

The Path Forward for NGOs

To reverse these trends, NGOs must take proactive steps to restore their legitimacy and adapt to the changing political and financial landscape. ​ Transparency and accountability are crucial, as organisations must demonstrate their commitment to ethical practices and effective service delivery. ​ Collaboration among NGOs can also help resist government repression, as seen in successful campaigns in Kenya and Nigeria to prevent the passage of restrictive laws. ​

In the face of shrinking government funding, NGOs will need to explore alternative sources of support, such as private donors and socially conscious businesses. ​ However, private capital is unlikely to replace the resources provided by states fully. ​ As a result, many NGOs may need to refocus their programming or scale back their operations. ​

The decline of NGOs highlights the fragility of the post–Cold War power shift that once empowered global civil society. ​ While the optimism of the 1990s envisioned a world transformed by active and well-resourced NGOs, ​

——-

The authors of the piece have a new open-access book, Crowded Out (Cambridge University Press), for anyone who wishes to learn more. It examines how today's aid system—rules for compliance, contracting chains, risk offloading, and "foreign agent" regimes—can unintentionally leave out the very civic actors it aims to help, using data from multiple countries and fieldwork to identify what went wrong and what needs to change.

The Disproportionate Socioeconomic burden in conservation borne by an unrecognised SIDS still under colonial rule

I have written about colonialism and neo-colonialism in fisheries, and my work, either directly by the influences of former colonial countries or via the imposition of standards, either regulatory (unilateral market access requirements) or commercial (like private 3rd party certifications and ecolabels)

https://southpacificislands.travel/new-travel-guide-for-american-samoa-marks-major-leap-for-tourism/

I explored the role of the US during the “Tuna Wars” in my “Tuna Diplomacy” blogs, and, before that, the “Guano Islands Act” as a striking example of neo-imperialism. Add to that a long-term interest in the Spanish Oceania and how the USA either took over them or pushed Spain into selling them to Germany, all compounded by this fascinating history book I recently read, “How to Hide an Empire’

So when along my feeds a paper named “Amerika Samoa Vs. The World. The Disproportionate Socioeconomic Burden in Conservation Borne By American Samoa as an Unrecognised Small Island Developing State under Colonial Rule” I had to have a look (not only because of the long name that acts as an abstract!), and then to my surprise (or not) it was written by someone I know well, Tim Costelloe, who may be the fisheries official that has worked for more administrations I know!)

As a New Zealander, proud of his Irish and Maori roots… His disdain for colonialism runs deep, and we have discussed it for nearly two decades.

Anyway, here is my summary of the paper; I still suggest you read the original.

—

His paper examines the socioeconomic challenges faced by American Samoa, a U.S. unincorporated territory, stemming from federal marine conservation policies and its lack of recognition as a Small Island Developing State (SIDS). The main issue concerns the Biden administration's 2023 Presidential Proclamation 14008, which proposed expanding National Marine Monuments (NMMS) in the Central Pacific Ocean as part of the global 30x30 conservation initiative.

This policy would have closed significant fishing areas within American Samoa’s Exclusive Economic Zone (EEZ), forcing its tuna fishing fleet to operate in the High Seas, which would increase costs and competition, and threaten the survival of the territory’s only remaining tuna cannery in Pago Pago. The cannery is vital to the local economy, which relies heavily on the tuna fishing industry. The potential closure of the cannery would have devastating effects on the territory’s economy, further deepening its dependence on U.S. federal welfare.  

The paper highlights American Samoa’s unique status as a U.S. territory that is not fully integrated into the federal system. Its residents are recognised as U.S. Nationals rather than citizens, and the territory lacks voting representation in Congress. This dual disenfranchisement makes American Samoa vulnerable to federal policies that often neglect its economic and social realities. 

Furthermore, the territory’s lack of recognition as an SIDS worsens its difficulties, as it is excluded from the international benefits and protections granted to other Pacific Island nations under agreements such as the United Nations Convention on the Law of the Sea (UNCLOS) and the United Nations Fish Stocks Agreement(UNFSA). This is because its colonial master is not a signatory of UNCLOS, although it has signed UNFSA (albeit the latter being an implementing agreement of the former).

The study criticises the U.S. for using American Samoa as a "sacrificial zone" to meet global conservation targets while avoiding environmental reforms on the mainland. It argues that such policies exemplify a broader pattern of environmental imperialism, where powerful nations impose conservation burdens on marginalised communities.

The rescission of Proclamation 14008 by President Trump in 2025 offered temporary relief but did not address systemic inequalities in the U.S.-American Samoa relationship. 

The paper promotes a justice-centred approach to marine conservation that prioritises the voices and agency of American Samoa. It suggests granting the territory autonomy over its EEZ, officially recognising it as an SIDS, and establishing legally binding consultation processes for federal policies that affect its economy. Additionally, transitional measures should be implemented to support economic diversification and reduce dependence on federal welfare.

The document also underscores the lack of support from other Pacific Island nations for American Samoa’s SIDS recognition, partly due to its colonial ties to the U.S. This has resulted in further marginalisation in regional and international forums, such as the Western and Central Pacific Fisheries Commission (WCPFC).

In conclusion, the document highlights the need for a fundamental reassessment of the asymmetric relationship between American Samoa and the U.S. It advocates for policies that respect the territory’s internal sovereignty, promote sustainable economic growth, and address the uneven conservation burden it faces.

And for me, the killer paragraph is:

The situation of American Samoa is, therefore, a microcosm of a global injustice, exposing the tendency of wealthy, powerful nations to outsource the burdens of environmental conservation to marginalised communities and foreign fishing zones, played out as a textbook case of the asymmetric imposition of the will of the privileged centre to use less privileged peripheral territories as sacrificial zones for virtue-signalling policies.

—-

My take: This issue has been raised before at the WCPFC, yet, unfortunately for American Samoa, the USA has not gained many friends over the years, and people in the region do not forget the tuna wars or the threats of cutting all assistance as a consequence of the PICs' renegotiation of the tuna treaty. So, you have to feel for American Samoa, caught in a halfway sandwich between the USA, which would never let them go. The SIDS that will not accept them as one of their own as long as they remain part of the most powerful country in the West... This would be similar if Wallis and Futuna asked for the same while being part of France. Yet it would be for the brilliant people and the lawyers to decide whether this violates the WCPFC Convention.

So yeah… credit to Tim for highlighting this issue academically and pinpointing the colonial-era outposts of the old and new empires that still exist, where it needs to be addressed.

Climate change implications for fisheries and aquaculture in the Pacific Islands region

Last year, I blogged about my sobering week at the excellent Fisheries Climate Awareness Workshop (CLAW), which was designed to enhance knowledge and awareness of SPC member countries and territories on climate issues and projected impacts on the industrial fisheries of the western and central Pacific.

The work by SPC is continuous in this area, as aquatic ecosystems in the Pacific Islands region are crucial for food security, livelihoods, and economic development. They face various pressures, including environmental degradation from urbanisation and agriculture, which threaten freshwater and coastal ecosystems.

Climate change is expected to exacerbate existing pressures, affecting marine resources and productivity that communities rely on for food, income and livelihoods. Climate change threats, such as rising ocean temperature and acidification, profoundly affect marine ecosystems and fisheries.

This document, the 2025 assessment, includes coastal, oceanic, and freshwater fisheries; consideration of supporting habitats; and aquaculture, with implications for livelihoods, economies, and blue foods.

The update also includes summaries of the assessment findings for each of the 22 PICTs, along with targeted adaptations for each, highlighting challenges posed by population growth, urbanisation, and environmental degradation.

It's a significant document, but a fundamental read in the general sense, and it also has specific assessments for each PIC. And on top of that, it publishes 7 of my photographs… which is always very honouring.

The generalities of Chapter 1 are below, yet I, as usual, recommend reading the original.

Challenges in Fisheries Management

The Pacific Islands face significant challenges in managing fisheries due to illegal fishing practices and inadequate regulations. ​

• Most catch from coastal and freshwater fisheries is unreported, complicating management efforts. ​

• Standard destructive fishing methods include spearguns with torches and small-mesh gill nets. ​

• Illegal fishing persists despite efforts to strengthen monitoring and control systems (MCS). ​

• Overharvesting has led to declines in coastal fish stocks, particularly high-value species such as sea cucumbers. ​

• Limited data and resources hinder effective management of coastal fisheries. ​

Population Growth and Urbanisation Impacts

Rapid population growth and urbanisation in the Pacific Islands are driving environmental challenges and resource degradation. ​

• The region's population grew from 9.9 million in 2010 to 13.2 million in 2024, a 33% increase. ​

• Urbanisation is projected to rise from 24% in 2020 to 32% by 2050. ​

• High population density in coastal areas increases pressure on marine resources. ​

• Environmental challenges include soil loss, habitat degradation, and pollution from urban lifestyles. ​

• Governments struggle to balance food, water, and housing needs with ecosystem sustainability. ​

Climate Change Effects on Marine Resources

Climate change is significantly impacting marine biological resources in the Pacific Islands, affecting fisheries and aquaculture. ​

• The tropical Pacific marine climate has warmed by approximately 1°C since pre-industrial times. ​

• Changes include increased sea surface temperatures, altered rainfall patterns, and rising sea levels. ​

• Climate change threatens the productivity of fisheries and aquaculture, impacting food security and livelihoods. ​

• The Pacific Ocean absorbs 10% of global carbon emissions and plays a crucial role in regulating the climate. ​

Demographic Changes Since 2011

Demographic shifts in the Pacific Islands have intensified social and economic changes, affecting traditional resource management. ​

• The population has increased by 33% since 2010, with Melanesia experiencing the highest growth. ​

• Urban migration disrupts traditional governance and social networks, weakening local resource management. ​

• Subsistence economies are transitioning to monetised systems, increasing reliance on market-based food sources. ​

• Traditional diets are being replaced by processed foods, leading to health issues like obesity and non-communicable diseases. ​

Growing Demand for Sustainable Seafood

The demand for blue foods is rising due to population growth and urbanisation, necessitating sustainable management of marine resources. ​

• Coastal communities depend heavily on marine resources for subsistence, and reduced local catches can impact nutrition. ​

• Increased demand for blue foods is putting pressure on vulnerable marine resources, particularly high-value exports such as sea cucumbers. ​

• Policies are needed to improve coastal resource management and support local communities' access to nutritious foods. ​

Trade Dynamics in Fisheries

Global trade and demand for fisheries products are influencing market prices and the economic landscape of Pacific Island fisheries. ​

• Export values from FFA member countries increased by 45% from 2015 to 2021, reaching USD 915 million. ​

• Fresh exports, such as deepwater snapper, declined significantly due to supply chain disruptions during the pandemic. ​

• Processed products, particularly canned tuna, saw substantial growth, quadrupling in exports. ​

Strategic Plans for Fisheries and Aquaculture

Efforts are underway to secure sustainable fisheries and aquaculture in the Pacific Islands through strategic planning and collaboration. ​

• The 2015 Regional Roadmap for Sustainable Pacific Fisheries outlines goals and strategies for tuna and coastal fisheries. ​

• The "New Song for Coastal Fisheries" initiative aims to improve community well-being and ecosystem health. ​

• A regional aquaculture assessment in 2022 identified key challenges and opportunities for sustainable aquaculture development. ​

Advances in Climate Change Modelling

Recent advancements in climate and ecosystem modelling are enhancing the understanding of fisheries vulnerability to climate change. ​

• New data sources and technological innovations have improved the accuracy of ecosystem and fisheries models. ​

• The IPCC Sixth Assessment Report provides updated climate projections with higher confidence and reduced uncertainty. ​

• Vulnerability assessments help identify climate change impacts on fisheries and inform adaptive management strategies. ​

Assessing Vulnerability to Climate Change

Vulnerability assessments are crucial for understanding the impacts of climate change on fisheries and aquaculture in the Pacific Islands. ​

• Vulnerability is defined as the degree to which systems are able to cope with the effects of climate change. ​

• Assessments aim to inform decision-makers on how to strengthen adaptive capacity and reduce risks. ​

• The framework integrates exposure to climate hazards, sensitivity, and adaptive capacity to evaluate overall vulnerability.

Regional Context and Climate Change Projections

This section establishes the foundational climate change projections and regional context for vulnerability assessments in Pacific Island Countries and Territories (PICTs). ​

• Provides essential climate change projections relevant to the 22 PICTs.

• Sets the stage for vulnerability assessments that follow in the publication.

• Highlights the importance of understanding regional climate impacts for effective adaptation strategies.

Summary of Results for PICTs

This section summarises the findings for each of the 22 PICTs, aiding in national-level adaptations and policy formulation. ​

• Presents a comprehensive summary of results for all 22 PICTs. ​

• Aims to inform national-level adaptations and policy decisions.

• Results are crucial for understanding local vulnerabilities and adaptation needs.

Implications of Climate Change on Marine Habitats

This section discusses the effects of climate change on coastal, oceanic, and freshwater habitats, including fisheries and aquaculture.

• Examines the impact of climate change on coastal and freshwater ecosystems.

• Discusses implications for fisheries and aquaculture sectors. ​

• Highlights the importance of these habitats for local food security and economies. ​

Cascade of Effects on Blue Foods

This section assesses the broader implications of climate change on the benefits provided by blue foods, including food security and livelihoods.

• Evaluates the cascading effects of climate change on blue foods.

• Emphasises the role of blue foods in food and nutrition security.

• Discusses the economic implications for local communities and government revenues.

Importance of Local Context in Adaptation Strategies

This section emphasises the need for context-specific adaptation strategies due to varying political and social systems across PICTs. ​

• Recognises the diversity of tenure and political systems in PICTs. ​

• Stresses the importance of local environmental, social, and cultural contexts in adaptation planning. ​

• Highlights the value of traditional knowledge in enhancing adaptive capacity. ​

Recommendations for Policy and Legislation

This section outlines the necessary policies and legislation to support the implementation of adaptation strategies in fisheries sectors. ​

• Recommends tailored policies for each of the 22 PICTs to support adaptations. ​

• Emphasises the need for legislation to facilitate effective implementation.

• Aims to maintain the role of fisheries and aquaculture in local economies.

Building Resilience in Pacific Communities

This section discusses strategies for enhancing the resilience of Pacific communities through sustainable resource management. ​

• Advocates for a range of adaptations to reduce dependence on specific marine resources. ​

• Suggests diversifying food and livelihood sources to enhance resilience. ​

• Highlights the importance of maintaining government revenue from tuna fisheries.

Addressing Climate Change Uncertainty

This section introduces the concept of uncertainty in climate change assessments and how it is communicated in the publication.

• Defines uncertainty as a state of incomplete knowledge in climate assessments. ​

• Discusses various sources of uncertainty, including data gaps and human behaviour. ​

• Outlines the approach for communicating uncertainty using confidence and likelihood metrics.

Confidence and Likelihood in Findings

This section explains how confidence and likelihood are assessed and communicated in the context of climate change findings.

• Confidence is evaluated based on the quality and consistency of evidence. ​

• Likelihood is expressed probabilistically, indicating the chance of specific outcomes. ​

• Provides a framework for interpreting findings with varying levels of confidence and likelihood. ​

While climate change needs to be addressed through concerted international efforts, local and regional measures can minimise the scale of impacts on marine ecosystems and support adaptation while global socio-climate systems respond. Addressing the implications of climate change for Pacific Island peoples requires adequate resourcing for national governments and communities, along with financial commitments for effective, coordinated implementation.

Inadequate resourcing has been a persistent issue, hindering PICTs' capacity to implement climate change adaptation measures to support resilient aquatic ecosystems and communities. In many cases, this will require the development and implementation of basic but robust management systems, significant education and awareness-raising, and enforcement at all levels – from government through to communities.

Ultimately, actions that support the sustainability of marine ecosystems and their productivity will contribute to the functioning of the Pacific Ocean within the global climate system and benefit all people.

Emergent geopolitical risks from fishing activities and past conflicts in the Pacific Ocean

I’m a sucker for papers that blend tuna fishing and geopolitics… and it might be clear from my writings on tuna diplomacy and the alliances and misalliances that TW, CN, KR, JP, and the USA have within the WCPFC, especially regarding longline fishing (as I’ve discussed before, it’s a mess). 

When I by chance came across a paper titled “Emergent geopolitical risks from fishing activities and past conflicts in the Pacific Ocean”, I definitely had to read it (even if it is from 2024, “emergent” is an elastic concept)

The study investigates the rising geopolitical risks caused by international fishing activities and historical disputes in the Pacific Ocean, with particular attention to drifting longline fisheries. 

This spatial competition increases the risk of fisheries conflicts, which can occur as disputes over shared resources, gear interactions, and territorial claims. Such conflicts not only affect the livelihoods of fishers but also have broader implications for international relations and the sustainability of marine ecosystems. Using geospatial and network analyses, the researchers identified countries, country pairs, and regions in the Pacific Ocean at higher risk of fisheries conflicts due to overlapping fishing areas and historical rivalries. 

Indeed, Taiwan and China emerged as dominant players, with the largest fishing areas and efforts, followed by Japan, South Korea, and the USA. The tropical Pacific was found to have the highest international fishing diversity and conflict risk, especially in areas outside national waters, such as the high seas adjacent to EEZs. These regions are hotspots for spatial competition, particularly in fisheries targeting tuna and tuna-like species, which are often the focus of disputes.

The study offers little new information for those familiar with and working in the region. Still, it provides a valuable academic reference for discussing these issues by emphasising the role of long-standing rivalries in influencing conflict risk. Countries with a history of recurring conflicts, such as Japan, China, Taiwan, and South Korea, are more likely to become involved in future disputes, especially in areas where their fishing activities overlap.

Higher-risk dyads, such as Japan-Taiwan and Japan-China, were identified based on shared fishing areas and the intensity of past conflicts. The research emphasises that these risks are not limited to geographically proximate countries, as distant-water fishing fleets from regions like Europe also contribute to spatial competition in the Pacific.

Governance mechanisms are essential in reducing conflict risks and encouraging cooperation. Regional organisations like the WCPFC and agreements such as the PNA oversee fishing activities and advocate for sustainable practices, even if the PNA's influence on LL remains relatively limited compared to PS. 

These frameworks have helped reduce the intensity of conflicts, as seen in the historical Tuna Wars between Pacific Island nations and the USA, which led to the establishment of cooperative arrangements.

The study advocates for proactive measures to mitigate conflict risks, including science-based management of fishing efforts, catch limits, and incentives for sustainable practices. It also highlights the importance of considering broader social, political, and ecological factors, such as climate change, industry subsidies, and power imbalances, which can increase the likelihood of conflict.

The paper argues that understanding the complex dynamics of fisheries conflicts, including the role of private actors and global networks, is crucial for developing effective strategies to manage shared ocean spaces and promote the sustainability of marine resources. By integrating historical data, spatial analyses, and governance insights, the study offers a comprehensive framework for assessing and reducing fisheries conflict risks in the Pacific Ocean. 

Training on the upcoming requirements of the EU Catch Certification Scheme

As I wrote before, in 2023, Council Regulation (EC) No 1005/2008 was amended by Regulation (EU) 2023/2842 of the European Parliament and of the Council of 22 November 2025, introducing a series of updates, including the use of the CATCH EU-wide real-time IT system for managing all procedures linked to the EU catch certification scheme.

The new system introduces modifications to the catch certificate template content and processes, such as punctual changes to enhance traceability along supply chains and ensure the proper functioning of the IT environment.

Specifically, it introduces changes to Chapter III: the IUU CCS, including CATCH: Article 12, general functionalities, access to CATCH, and the timeframe for the current EU CCS paper-based system, which will be valid until 26 January 2026.

However, beyond 10 January 2026, EU importers will be required to use the CATCH system when submitting catch certificates and related documents to the authorities of EU Member States. 

Exporters and authorities in non-EU countries may choose to use the CATCH system voluntarily. However, all authorised exporters must adopt the new template and, importantly, the updated role of the processing statement from 10 January 2026.

There has been a complete shift in the use of the processing statement required by Annexe IV of the IUU Regulation. It was previously only necessary for fish processed in a third country with a foreign catch licence. Now, it will be mandatory even if the processing and flag state are the same.

Processing statements must now accompany ALL processed fish products entering the EU, regardless of where processing occurs (in the flag state or another non-EU country).

This means that processing statements should also be approved when the flag state of the fishing vessel that caught the fish matches that of the processing operation.

 Additionally, the processing statement will require you to use a unique number issued by the officials who endorse the statement. If you use CATCH directly, the system can generate this number for you.

Specifically, the processing statement should mention the catch certificates that show the volume of fish per species used as raw material for the processed goods sent to the EU.

From a practical and managerial perspective, the CA of the processing state that verifies this document must keep a record of signed processing statements that include details about the species, volumes, and their destinations.

Considering the significant upcoming changes to the current EU CCS, FFA members with access to the EU market have sought capacity-building and strategic guidance to prepare for these forthcoming changes. 

So, my FFA friends and colleagues asked me to prepare and deliver a capacity-building mission grounded in practicality and my experience with the first iteration of the CCS back in 2010, and again in much more depth when the yellow cards were introduced to the region between 2012 and 2015.

The activities included

i)      The development of training materials describing all the changes

ii)     A training schedule

iii)   The development of a new CC template

iv)   And an agreed timetable for changeover

The first 4-day event was held at the Lae International Hotel in PNG for industry and NFA staff; the second took place at the Peninsula Hotel in Suva for industry staff and officers from Fiji, the Solomon Islands, and Kiribati.

The following training materials were provided to all participants

• PowerPoint presentation 

• FFA’s EU Market Access Guide for Fish and Fishery Products

• TRACES NT- CATCH Explanatory Website

• Regulation (EU) 2023/2842 of the European Parliament and of the Council of 22 November 2023 amending Council Regulation (EC) No 1224/2009 and amending Council Regulations (EC) No 1967/2006 and (EC) No 1005/2008 and Regulations (EU) 2016/1139, (EU) 2017/2403 and (EU) 2019/473 of the European Parliament and of the Council as regards fisheries control

• Council Regulation (EC) No 1005/2008 of 29 September 2008 establishing a Community system to prevent, deter and eliminate illegal, unreported and unregulated fishing, 

• EU CCS Changes timelines for each country

• Processing statement draft

• Non-processing statement draft

• Notification from the European Union – Article 20: Flag State Notifications and Cooperation with Third Countries

Seafood exports to the EU are a crucial economic lifeline for FFA members with market access. These exports underpin national revenue, employment, foreign exchange earnings, and the overall financial stability of their fishing and processing industries. 

Non-compliance carries significant financial risks: a country may face export bans, yellow or red cards, loss of preferential access, and costly corrective measures. Even a temporary withdrawal of EU approval can result in millions in lost revenue, factory closures, job losses, and long-term damage to reputation and investor confidence.

The training team motivated participants and supplied resources to assume leadership on this issue before deadlines.

Undoubtedly, the first weeks after the 10 January 2026 deadline set by the EU for importers in EU member states to adopt the CATCH system will be challenging, as they will need to enter the catch certificates received from non-EU countries manually. This will test their systems, and some changes in interpretation may occur, similar to what happened in early 2010 when the first version of the CCS came into force.

As such, the advice was to wait for a few months and consult with trading partners before moving into CATCH.

This activity was only made possible through the support, trust, and dedication of my FFA colleagues Yaniba Alfred and Jope Tamani.

The training introduced new ideas and approaches; the management of the fisheries authorities and industry consistently encouraged staff to participate willingly despite their busy schedules.

I am genuinely grateful to FFA and participants for the opportunity to lead these training sessions.

Biofilms in water hoses on board fishing vessels?

In the past, I worked a lot on the seafood safety side of fisheries. When a fish is on deck, it is no longer just a fish; it has turned into food, and as such, there is a whole universe of rules, compliance, and operations that go along with it. And as usual, not many people with practical experience in fisheries are involved.

Working on a trawler in Guinea Bissau in 2024

I took that whole side of fisheries quite seriously particularly when I migrated to NZ, at some stage I was responsible for most of the HACCP plans in the country and went all the way to do a Masters in Food Science in 2000 (on top of my one in Fisheries Science from 1991)… and while I enjoy that part of the work particularly in the area of EU market access conditions for vessels and landing sites (areas I still work with a bit), I moved back to fisheries that is where my hearth really is.

I keep an eye on papers on cold chain issues, histamine, and hygiene. And one of our tenants on boats, where seawater is free, is to hose down everything to death; seawater is an excellent cleaner… and we assume that with some sanitation and a good hose-down with seawater, everything should be alright.

So when I read this paper “Biofilms in water hoses from the food processing environment harbour diverse microbial communities”, which deals with the presence and composition of biofilms inside the hoses, my heart sank a bit… as if seafood safety is not complicated in itself already… sure it is in fresh water… but chances are that there would be similar biofilms with more halophilic bacteria that hopefully have low link to known pathogens like Pseudomonsa. In any case, an interesting paper and a future headache for my colleagues still working in the seafood processing arena

The study examines the presence and composition of biofilms in water hoses used in a meat processing environment. Biofilms, which are communities of microorganisms embedded in a matrix, can harbour bacteria and fungi, including opportunistic pathogens, thereby posing health risks and contamination threats in food processing facilities. The research focused on eight-month-old water hoses, sampled three times at six different locations within the facility. 

Using optical coherence tomography (OCT), researchers visually examined the inner surfaces of the hoses and detected visible biofilms in 2 of them. However, biochemical analyses revealed biofilms in 14 of 15 tested hoses, indicating that OCT is less sensitive for biofilm detection than biochemical methods. The study defined biofilms as the presence of bacteria and/or fungi, confirmed by qPCR, along with at least two extracellular matrix components (carbohydrates, proteins, and extracellular DNA).

Bacteria were detected in all samples, with bacterial loads ranging from 0.93 to 5.93 log10 BCE/cm². Fungi were detected in all but one sample, with fungal loads ranging from 0.05 to 4.32 log10 FCE/cm².

The concentration of biofilm matrix components varied significantly across the hoses, suggesting heterogeneity in biofilm composition despite similar environmental conditions. The bacterial community analysis revealed that Mycobacterium was the most abundant genus across all samples, followed by unclassified Comamonadaceae, Rhodobacteraceae, Rhodococcus, and Ketobacter.  

Opportunistic pathogens, such as Legionella and Pseudomonas, were detected at low levels, with Legionella present in all hoses except one. Meat spoilage bacteria, including Pseudomonas and Stenotrophomonas, were also identified in low abundances.  

The fungal community showed low diversity, with Trichoderma being the most prevalent genus, followed by Sistotrema, Polyschema, and Asterostroma. Trichoderma, known for its potential health risks to immunocompromised individuals, was detected in all hoses except one.

The study found significant differences in the beta diversity of bacterial communities between hoses from different sampling locations, suggesting that factors such as water pressure and frequency of use may influence biofilm composition.  

For instance, hoses used weekly showed no significant differences in bacterial load or biofilm matrix components compared to those used daily.  The study also noted that fibres within the hoses' inner surfaces might contribute to biofilm growth.

The findings highlight the potential risks posed by biofilms in water hoses, including contamination of food processing environments through water flow and aerosols.  Despite using the same hose material, the same water source, and similar environmental conditions, biofilms were highly heterogeneous.  

The study emphasises the need for further research to understand the factors influencing biofilm formation and microbial community diversity in water hoses.  This knowledge is crucial for improving hygiene standards and ensuring food safety in processing facilities.

In conclusion, water hoses in food processing environments are prone to biofilm formation, which can harbour diverse microbial communities, including opportunistic pathogens and spoilage bacteria.  The study underscores the importance of addressing biofilm formation to mitigate contamination risks and enhance food safety.

Includding pacific Islands traditions in the potential management of the high seas pockets as MPAs

The high seas, which make up about two-thirds of the world’s oceans and are broadly defined as areas beyond national jurisdiction (ABNJ), remain among the least governed and most contested spaces in our oceans.

This year, we began operationalising the High Seas Treaty, a landmark international agreement to protect marine biodiversity in the ABNJ. The treaty seeks to address longstanding gaps in global ocean governance by establishing a legal framework for the conservation and sustainable use of marine resources outside national boundaries. Its focus is on the following Key Objectives and Provisions.

1. Marine Protected Areas (MPAs):
   Establishes a process for creating and managing MPAs on the high seas to conserve biodiversity and ecosystems.

2. Environmental Impact Assessments (EIAs):
   Requires countries to assess the potential impacts of human activities (like fishing, shipping, or deep-sea mining) on marine biodiversity before they occur.

3. Marine Genetic Resources (MGRs):
   Sets rules for sharing benefits from the use of genetic material from marine organisms (e.g., for pharmaceuticals or biotechnology), ensuring equity between developed and developing nations.

4. Capacity Building and Technology Transfer:
   Supports developing countries with access to marine science, technology, and training for fair participation in ocean conservation and research.

5. Institutional and Governance Mechanisms:
   Creates a Conference of the Parties (COP) to oversee implementation, compliance, and decision-making, similar to frameworks in other global treaties like the Paris Agreement

The United Nations Convention on the Law of the Sea (UNCLOS) and related international organisations have traditionally served as the basis for “governing” the oceans. However, environmental damage, climate change, species loss, and marine pollution remain significant problems.

While the High Seas agreement is a good thing (and I recently participated in a deep study to foresee the potential of MCS activities in Marine Protected Areas), it remains under the coverage of Einstein’s quote, “We cannot solve our problems with the same thinking we used when we created them” 

I understand that we are not going to alter the “ocean world order” established by UNCLOS. Still, it feels to me that we are attempting to address this problem by creating and refining legal instruments that originate from the same legal instrument (and mindset!) that created it.

Perhaps because of my recent reflections on my experiences in Japan in terms of “conservation”, my suggestion of the high seas pockets as MPAs and because I have spent over half my life in Pacific Islander societies—spanning what anthropologists describe as Polynesia, Micronesia, and Melanesia (labels that my friends in the region themselves rarely identify with)—I have been fortunate to learn a little about my hosts’ worldviews and their traditions of navigation, stewardship, customary marine tenure, and relational ocean ethics. 

So, while I wait five hours to check in for my next flight, I took some time to explore how these traditions could serve as a rich conceptual and practical resource for reimagining high seas governance; by reframing the ocean as relational and communal, integrating customary governance systems into large-scale ocean management, and combining traditional knowledge with global institutions. 

While I acknowledge it is idealistic and utopian, could a shift from the “freedom of the high seas” -as a key tenet of the UNCLOS regime- to one based on responsibility, reciprocity, and guardianship be possible?

Here are some of the key issues under which the traditional ways could be used or adapted:

Customary marine tenure and seasonal closures

One key aspect of Pacific Island tradition is the practice of customary marine tenure: local communities hold rights and responsibilities over specific marine areas, regulate access, and implement rotational closures or bans to allow resource regeneration. For example, the “ra’ui” system in the Cook Islands manages access to fishing grounds through temporary restrictions, reflecting local ecological knowledge and traditional governance. In fact, and not surprisingly, we also have it in New Zealand as "rāhui," a temporary prohibition or restriction on accessing a specific area or resource, rooted in Māori custom (tikanga). It is placed to protect the area's ‘mauri’ (life essence) or ‘tapu’ (sacredness), and is used for conservation, resource recovery, or to mark a place of death. Rāhui can be voluntary, imposed by a local iwi (tribe), or—very relevantly—formally gazetted under legislation such as the Fisheries Act, which is what we have in Waiheke Island, where I have been living for the last 20 years.

Similarly, in Palau, a customary “bul” has been used to close entire zones to fishing when resources become scarce, effectively combining local observation with enforcement. These local governance forms highlight stewardship, flexibility, and community accountability rather than centralised regulation.

Traditional navigational and ocean-wayfinding knowledge
In many Pacific societies, knowing about the ocean is more than just fishing and harvesting. It also includes advanced skills in finding your way by using the stars, swell patterns, birds, and other seasonal signs, passing on marine knowledge orally, and understanding the sea's relational cosmology. These ways of doing things stress the importance of knowledge networks linking islands, adaptable observation of ocean and weather changes, and a movement and connection ethic.

Indigenous and ecological epistemologies of the sea
In Pacific Islands traditions, the ocean is not just a resource to be used, but also a living thing that people interact with in a two-way relationship. People know about iconic species, traditional harvest times, and stories told by elders about extreme past events. These things connect culture, ecology, and governance.   This way of thinking about knowledge offers ways to run things that are based on respect, remembering the past, and being accountable to others.

Why might these traditions be necessary for running the high seas?

Changing the way we think: from exploiting to managing

Freedom of navigation, resource extraction, quota allocation (for fish or minerals, for example), and state-based sovereignty are the main principles governing the high seas today. Pacific Island customs, on the other hand, focus on relationships (between people, the ocean, other species, and future generations) and duties (such as guardianship and caring for each other) rather than just rights. This change could help move high seas policy towards a model of care: the question is no longer "who gets to fish or mine?" but "who is responsible for keeping the ocean healthy for future generations?"

Community-based and distributed governance

In the Pacific, marine traditional systems are not always one big thing. Instead, they are often local and flexible. The high seas are vast, but the model of nested governance, which includes smaller or local governments within larger systems, can be used to plan governance across multiple levels. These types of forms can enhance ecological authority, legitimacy, and adaptability.

Integrating knowledge and making climate and ecosystems more resilient

Traditional knowledge about the ocean offers memories of long-term ecological events, seasonal currents, wind changes, species movements, temperature changes, and storms. It also lets us see, in fine detail, how the marine environment is changing across each season. In the high seas, where data isn't always consistent and rules aren't always followed, this kind of information can fill in the blanks, send early warning signals, and make governance more flexible and quicker to act.

Truth, fairness, and legitimacy

Involving Pacific islands’ cultural traditions also addresses issues of justice. Small island states often have to deal with the effects of climate change, rising sea levels, and the high seas more than they should, yet they have little say in how areas beyond their jurisdictions are governed. Recognising traditional traditions in high seas governance frameworks can help address the imbalance, give local views greater weight, and ensure decisions remain fair.

The problems of bringing these concepts into the management of ABNJ

 Scale and a lack of authority

Pacific customary systems primarily operate at the local or national level. Trying to apply them to the high seas, which are generally controlled by the most powerful countries and are often shaped by global geopolitics and dynamics, is almost impossible, given how these frameworks are built. RFMOs may not be able to work efficiently with community-based or customary systems when regulating the high seas.

Integration of knowledge and institutions

When traditional knowledge is used in global governance systems, it raises issues of translation, validation, rights, intellectual property, and epistemic respect. Reforming institutions, building people's skills, and changing how information is organised are all needed to make integration meaningful.

 Power relations and the effects of colonisation

There have been colonial, post-colonial, and neocolonial forms of government in many Pacific countries. These pasts have an impact on customary governance systems, passing down information from one generation to the next, and legal recognition. Some traditional practices may no longer be as prevalent or may have changed. Reforms to governance must take these memories into account and ensure that local agency is at the centre, not just a token.

Enforcement, monitoring and resources

One practical problem with high seas management is that monitoring vast areas of the ocean is both complicated and expensive. Customary marine tenure works in part because of the social tracking and enforcement systems in place in the area. To make this work on the high seas, new enforcement networks, surveillance, community-based remote sensing, and partnerships would be needed.

Ideas on How to Use Pacific Traditional Knowledge in High Seas Governance

Set up area government systems that are based on community involvement

Create "ocean stewardship" zones in the Pacific Ocean that are outside of national jurisdiction and are governed by Pacific Island states and their people. These zones should be based on traditional marine tenure systems. I personally think that the High Seas pockets in the FFA membership would be a good test for this.

Adaptive governance and ecological‑temporal systems

Borrowing from Pacific traditions of cyclical closures, rotational harvests, ecological observation and adaptive protocols, global governance can move toward adaptive zoning, dynamic closures, and monitoring‑triggered responses rather than static protected areas.

 Relational design and ethical ocean control

Incorporate an ocean guardianship ethic into organisations and treaties. Instead of seeing the high seas as a resource frontier, see it as a heritage for future generations and a place to steward relationships.

—-

Anyway… this is just a theoretical exercise. I’m very aware that it is my interpretation of Pacific island practices, which, as I’m not a Pacific islander, could easily be wrong, and my apologies if that is the case…

Here are the references I read for this rambling

Proulx, M., Ross, L., Macdonald, C., & Fitzsimmons, S. (2021). Indigenous Traditional Ecological Knowledge and Ocean Observing: A Review of Successful Partnerships. Frontiers in Marine Science, 8.

UNESCO. Indigenous knowledge in the Pacific Islands and the UN Ocean Decade.

Pacific Community Centre for Ocean Science (PCCOS). Traditional ocean knowledge and practices.

Living Oceans Foundation. Celebrating Traditional Marine Management Practices Across the Pacific Islands. (2022).

Le Meur, P.-Y., & Muni Toke, V. (2025). Competing Knowledges and Sovereignties in the French Pacific Oceanscapes. Ocean and Society, 2.

Sustainable Seas National Science Challenge. Why Indigenous knowledge should be an essential part of how we govern the world’s oceans.

Australian Department of Climate Change, Energy, the Environment and Water. Enhancing Pacific Ocean Governance. (2024).

Conceptualising Responsible Exits in Conservation Philanthropy

As I dive deeper into EM (Electronic Monitoring), an area that I have been working with for a while now, I’m not surprised anymore about the dozens of EM trials over the last decades that have taken place in the Pacific and Asia, funded by NGOs that have provided good information but totally collapsed after the funding ended.

You always know when they “start” because they are announced with self-congratulatory fanfare, yet they tend to “exit” without a strategy; they just fade away into nothingness.  

So, when this paper, titled "Conceptualising Responsible Exits in Conservation Philanthropy", came to my attention, it was good reading, as it examines the critical yet neglected issue of exits in conservation philanthropy, especially in ocean conservation.

As donations to environmental causes rapidly increase, the frequency of exits—defined as the termination of funding relationships—has also risen, often due to the rise of time-limited grants in strategic philanthropy. Exits can have a significant impact on grantees, conservation objectives, and local communities, making responsible exit planning an ethical obligation.

Authored by Elodie Le Cornu and colleagues, it is the first empirical research on exit processes in ocean conservation philanthropy. It draws on interviews with 47 individuals from 36 foundations and a knowledge co-production workshop with 41 participants. The study develops a conceptual framework to define and categorise exits into three types: embedded (planned and determined early in the grant-making process), organic (arising from internal or external drivers), and forced (unexpected and abrupt). Exits are further analysed along three dimensions: what is ending or shifting (e.g., geography, issue, funding relationship), scale (temporal, geographic, financial), and degree (full or partial).

The paper also highlights 52 best practices for responsible exits, organised into three categories: principles, administration and management, and sustainability. Key principles include respecting local contexts, promoting inclusivity, encouraging reflectivity, maintaining transparency, and allowing for flexibility.

Administrative best practices emphasise planning for exits from the outset, conducting thorough evaluations, fostering long-term relationships, and offering both financial and non-financial support.

Sustainability practices centre on capacity-building, fostering autonomy, and establishing strong funder networks to ensure the long-term viability of conservation initiatives.

It also highlights several challenges related to executing exit strategies in conservation philanthropy:

1. Internal Constraints: Foundations often face limitations such as a lack of resources, knowledge, or experience to execute exits effectively. Staff turnover and hierarchical decision-making within foundations can also hinder the process, as programme officers may lack control over when and why exits occur, with decisions often made at the board level.

2. Managing Relationships with Grantees: Tensions can arise between grantees' expectations for continued funding and the funders' decision to exit. Grantees may struggle to accept the reality of an exit and fail to plan for it proactively. This can lead to challenges in navigating relationships and ensuring a smooth transition. ​

3. Coordination with Other Funders: Exits can shift the funding burden to other funders working in the same space, potentially creating disagreements and tensions. Poor coordination among funders can lead to significant funding gaps for grantees.

4. Power Dynamics: Exits often reinforce power imbalances, as funders typically make unilateral decisions about ending funding relationships, leaving grantees with limited input or control over the process.

5. Timing and Context: Exits may occur at unfavourable times or in challenging contexts, which can exacerbate their negative impacts on grantees and conservation initiatives.  Some participants even questioned the necessity of exits altogether, advocating for long-term investments instead.

6. Lack of Planning: Exits are often regarded as an afterthought, with inadequate time and effort allocated to planning and managing the tensions and issues that emerge during the process.

These challenges highlight the need for more systematic research, better planning, and inclusive practices to ensure responsible exits that minimise harm and support the sustainability of conservation efforts.

The authors highlight challenges in adopting these practices, such as internal limitations within foundations, hierarchical decision-making processes, and conflicts in grantee relationships. They advocate for further research to incorporate grantee and community perspectives, understand long-term impacts, and refine best practices tailored to specific exit types.

Ultimately, the paper emphasises that responsible exits are a crucial part of ethical and effective conservation philanthropy. By providing a shared language and practical guidance, the study aims to assist funders, grantees, and conservation practitioners in managing exits in a way that minimises risks and maximises positive outcomes for people, organisations, and conservation goals.

Putting Regional Fisheries Management Organisations' Climate Change House in Order

My experience in writing collaborative papers is somewhat limited, typically involving 4-5 co-authors at a time, and that requires time and coordination. I have no idea what it would take to get 22 people involved, but I guess I’m lucky to know half of them, so I would ask one day.

This interesting Ghothi paper*, Putting Regional Fisheries Management Organisations' Climate Change House in Order, examines the urgent need for Regional Fisheries Management Organisations (RFMOs) to adapt their scientific processes to address the impacts of climate change on transboundary fish stocks.

Using South Pacific albacore tuna (SPA) as a case study, the authors demonstrate how climate change is affecting the biology, abundance, and distribution of fish stocks, creating challenges for sustainable fisheries management.

Projected effects of climate change on the distribution of South Pacific albacore tuna (SPA). Average biomass distribution (kg.km−2) of SPA in the Southern Pacific Ocean basin for 2015 (2011–2020) (top), and mean anomalies (kg.km−2) from the average 2015 biomass distribution projected to occur by 2050 (2044–2053) under the RCP 8.5 emissions scenario (bottom)

The paper identifies four key research areas to assist RFMOs in enhancing their scientific frameworks and maintaining the resilience of fisheries in the face of climate change.

Enhancing Understanding of Biological Changes: Climate change affects key biological factors, including growth, fecundity, and migration patterns, of fish stocks. Current stock assessment models often assume that these factors remain constant over time, which is unlikely under changing environmental conditions. The paper emphasises the importance of including climate-induced changes within research frameworks. For SPA, studies have indicated variations in life history across its range, highlighting the need for further analysis of its spatial stock structure. Techniques like Close-Kin Mark-Recapture (CKMR) are recommended for estimating population variables, such as connectivity, abundance, and fecundity, which are vital for effective management.

Enhancing Data Collection. Robust data collection is crucial for detecting shifts in biological and environmental factors. The paper advocates for long-term data collection programmes that combine fishery-dependent and fishery-independent data.  Collaborating with fishing fleets and leveraging advanced technologies, such as temperature sensors on longline gear, can improve data quality and reduce costs. Initiatives like these have already demonstrated success, as evidenced by a 40% improvement in thermocline depth estimates in New Zealand. The authors also emphasise the importance of coordinated biological sampling networks in supporting advanced modelling techniques.

Improving CPUE Modelling: Catch-per-unit-effort (CPUE) data is a key indicator of fish stock abundance, but it must be refined to account for climate-induced changes in fish distribution and fleet dynamics. The paper recommends adopting advanced modelling techniques, such as generalised additive models (GAMs), machine learning methods, and spatiotemporal approaches, to improve the reliability of CPUE indices. For SPA, incorporating habitat suitability variables and three-dimensional ecosystem data (e.g., depth distribution) into CPUE models is crucial for better reflecting the impacts of climate change on stock assessments.

Ensuring Adaptive and Robust Scientific Advice: Fisheries management must adapt to the uncertainties brought by climate change. The paper differentiates between adaptive strategies, which involve flexible management measures, and robust strategies, designed to perform well under high levels of uncertainty. Management strategy evaluation (MSE) is recommended to test harvest strategies against different climate scenarios. For SPA, strategies that consider spatial biomass redistribution caused by ocean warming are emphasised as essential. The authors also highlight the importance of dynamic depletion-based benchmarks, which may be more resilient to climate-driven changes in recruitment dynamics.

The paper concludes that RFMOs must invest in these four research areas to ensure the sustainable management of transboundary fish stocks in the face of climate change. Collaborative efforts between RFMOs, member countries, and fishing fleets are essential to improve data collection, modelling, and management strategies. By adopting robust and adaptable scientific advice, RFMOs can better tackle the challenges posed by ocean warming and secure the long-term sustainability of fisheries. The SPA case study serves as a model for other RFMOs managing stocks affected by climate change.

 * Ghoti papers: Ghoti aims to serve as a forum for stimulating and pertinent ideas. Ghoti publishes succinct commentary and opinion that addresses important areas in fish and fisheries science. Ghoti contributions will be innovative and have a perspective that may lead to fresh and productive insight of concepts, issues and research agendas. All Ghoti contributions will be selected by the editors and peer reviewed.
Etymology of Ghoti: George Bernard Shaw (1856–1950), polymath, playwright, Nobel prize winner, and the most prolific letter writer in history, was an advocate of English spelling reform. He was reportedly fond of pointing out its absurdities by proving that ‘fish’ could be spelt ‘ghoti’. That is: ‘gh’ as in ‘rough’, ‘o’ as in ‘women’ and ‘ti’ as in palatial.

The 9th Pacific Tuna Forum

This week in Denarau, Fiji, the 9th edition of the Pacific Tuna Forum was organised by my friends from INFOFISH, with the support of Fiji’s Ministry of Fisheries and PNG’s National Fisheries Authority.

As usual…. trying to convince people I know what I’m talking about

Almost 60% of the world's tuna is caught in the Western and Central Pacific Ocean (WCPO). This makes the Pacific and the "Blue Pacific Continent" the centre of the global tuna business.

The theme of the 9th Pacific Tuna Forum (PTF 2025) is "Pacific Tuna 2050: Resilience, Innovation, Equity and Sustainable Trade for a Prosperous Future." This emphasises not only a regional focus and priority on retaining more value, fostering industry growth, creating sustainable supply chains, expanding markets, and boosting trade to ensure the tuna industry’s longevity.

It also highlights generating substantial revenue to support national development priorities, creating jobs, transferring technology and knowledge, promoting more equitable wealth distribution, addressing the impacts of climate change across the region, and strengthening the resilience of the Blue Pacific Continent. 

The long-term health and success of the tuna industry are essential not only for the region but also for its lasting global influence. It plays a crucial role in ensuring food security, reducing poverty, improving health and education, maintaining stable supply chains, markets, and trade, enhancing fisheries management, combating illegal, unreported, and unregulated fishing, and supporting the UN's Sustainable Development Goals for a safer, better, and more prosperous future in the Pacific region and beyond.

This is the 9th time I’ve been invited to be a presenter—something I don’t take lightly or for granted.

My presentation examined the implementation of the Port State Measures (PSM) in the region, particularly in the RMI, which has proven to be a vital tool in Monitoring, Control, and Surveillance (MCS) efforts to combat illegal, unreported, and unregulated (IUU) fishing.

However, it remains a last resort measure, addressing the lack of flag state responsibility by Distant Water Fishing Nations (DWN) over their vessels.

DWFN carrier vessels on the high seas source fish from more longliners flagged to various states than many Pacific ports, often with no checks on the legality of the catches they receive. Meanwhile, effective PSM implementation remains a logistically complex and resource-intensive task for most Pacific Island fisheries administrations.

Additionally, I highlighted examples of longliners that travel considerably greater distances to reach the high seas rendezvous point with carriers than they would if heading to a port. This demonstrates, as with many other cases, the disproportionate burden of MCS placed on Pacific nations. At the same time, DWFN entities mostly evade similar oversight.

I hope that my presentation contributes to the growing calls for reform of high-seas transhipment within the Western and Central Pacific Fisheries Commission (WCPFC).

Furthermore, this year I have been asked to moderate the final session, “Future-Proofing the Tuna Industry and Its Sustainable Development in the Blue Pacific Continent. This session looks ahead—exploring how we can strengthen resilience, increase participation, and ensure shared benefits across the Pacific tuna value chain in a fairer, more transparent, and more sustainable manner.

The presenters will examine key aspects of a sustainable future for tuna—including climate financing, ecolabelling certification, private certification of fishers’ labour standards, and social accountability in industry standards. 

It's interesting and ironic too that they asked me to moderate a session that includes ecolabels and private labour certifications, two topics that have been highly criticised for years.

So yeah…. I’ll try to be a consummate professional about it.