Which country has the best e-CDS that can be used as a model? / by Francisco Blaha

I get very often variations of this question… which I tend to respond to the enquirer that is not a question that has no real answer, and then direct them to read some CDS publications that explain why. Yet since I got the question again and i’m jet-lagged, I decided to compile an answer for a colleague, in a simple language as I can try!

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Below is my attempt to an answer:

The 1st thing to understand is that a CDS is a “traceability” system that uses certificates and other documents to determine whether marine products in a supply chain originate from legal catches. The objective is to deter IUU fishing by denying its products entry to national and international supply chains and markets. And while CDS may be unilateral or multilateral, to talk about a “national CDS” as something that one country can do by itself over the whole value chain, is misleading.

The key word is traceability which in this context is “tracking fishery products through entire supply chains from catch and landing through division and processing to final sale and consumption”. It is achieved by means of identification and record-keeping along the value chain in systems such as a CDS.

Each country has “a part” on CDS that relates to making sure that they fish they are receiving (either by landing or importation) or transhipment that they are hosting is legal and then accounted for. What happens inside that country is their internal traceability (which then need to be connected with the next country in the value chain for a “full CDS”).

Hence if you want to call it that way, we have a “domestic CDS” (the traceability based system inside the country) and the “full CDS” which is the system in between the countries that part of it.

All present “full CDS” are run by RFMOs, not by countries… The first multilateral CDS were introduced in the form of trade documentation schemes (TDS) or trade information schemes by tuna RFMOs to monitor trade in the fish species they governed. The TDS is the precursor of the multilateral CDS, and TDS are in place in four out of five tuna RFMOs, and are the only multilateral trade documentation mechanism in IOTC, and IATTC; ICCAT developed a CDS in 2008 and CCSBT in 2010. The WCPFC still the only one that has none of these systems in place.

The two existing tuna CDS together cover substantially less than 1 percent of global tuna harvests by volume – all commercial species combined; the three RFMO CDS cover less than 0.1 percent of global wild fishery catch by volume. There is hence vast scope for expansion of the systems. 

Of all CDS systems only 2 are electronically native, the ICCAT e-CDS was operational by the end of 2016; the upgraded CCAMLR e-CDS was operational in the first quarter of 2017. 

There are also two unilateral attempts to a CDS in existence, the 1st has been implemented by the EU since 2010, is different from the general advised CDS, as it operated unilaterally by a single market state and does not apply to any specific species or fisheries. Instead it covers most wild-caught marine finfish traded into the EU market, and requires products to be covered by catch certificates validated under the scheme by flag state authorities.

The layout and functionalities of the EU scheme reflect those of multilateral schemes (less port of landing which is inexplicably absent), but it has few verifiable traceability mechanisms and for most flag states it certifies products exported but not the one caught. The scheme lacks a central registry to issue and record certificates. The system is hence vulnerable to fraud because the foundation for traceability in a CDS is missing, and individual traceability mechanisms applied by individual countries along their supply chains have limited scope with regard to eliminating fraud. The scheme is hence weakened because there is no effective supply chain traceability system that transcends individual country systems.

The US SIMP system suffers from a different set of limitations as a end market measure, one of the key ones is that does not requite validation at all by any CA of any producing country. A comparison in between the data requirements of both is here.

Below I represent the “full and domestic” CDS and their interactions in graphs, so perhaps is easier to understand:

The “full CDS” illustrated in Figure 1 (original by Gilles Hosch) and show the connections in between countries that are the key issue

Figure 1: Each country is a black box that process its own internal traceability system, country A has the responsibility of determine legality at landing/transhipment and initial volumes determination, everyone else needs to avoid fish laundering by checking the volumes per species it receives versus the ones sent from the last country, all the way to the volumes and species legally unloaded from the vessel.

Figure 1: Each country is a black box that process its own internal traceability system, country A has the responsibility of determine legality at landing/transhipment and initial volumes determination, everyone else needs to avoid fish laundering by checking the volumes per species it receives versus the ones sent from the last country, all the way to the volumes and species legally unloaded from the vessel.

Then each country has what some call their “domestic CDS” (the traceability based system inside the country) where knowing the movements of the fish in between operators and and the mass balance in between in and out is the key element, as we see in Figure 2 for a generic Country A.

Fig 2: Each “black box country” will have different needs according type of state roles (flag, port, coastal, processing) of the country.A generic country could have sequence above if it does most functions.

Fig 2: Each “black box country” will have different needs according type of state roles (flag, port, coastal, processing) of the country.A generic country could have sequence above if it does most functions.

Operationally a complex country like PNG for example has an internal traceability systems able to do what you see in Figure 3 by a combination of PSM to define legality at unloading and a catch accountancy system (that is world class!) along the “in country” processing chain. Once it leaves the country, the next country needs to have a system to receive that data and manage its own process.

Fig 3: The schematic system being worked inside PNG. While is called CDS, is in reality their “inside CDS”, ( it becomes a “full CDS” when it reaches the full value chain with other countires )

Fig 3: The schematic system being worked inside PNG. While is called CDS, is in reality their “inside CDS”, (it becomes a “full CDS” when it reaches the full value chain with other countires)

For Marshall islands for example the system is different as you see in Figure 4,  we have moved a step closer to a CDS since we are linking to our main “next country” Thailand, but still only a partial one, since it does not incorporate most flag states and no market state.

Fig 4: RMI operational “inside CDS”, as you see our inside system is very small so we are working to link it with the one in Thailand

Fig 4: RMI operational “inside CDS”, as you see our inside system is very small so we are working to link it with the one in Thailand

The minimal MCS tools needed to capture the necessary data that need to be captured each country for a CDS to work will depend of the combination of the type of states that are in their fisheries reality. For example PNG is a flag, coastal, port, processing and market state (since it imports tuna sometimes). Solomons is flag, coastal, port and processing. Tuvalu is flag, coastal and port. Tokelau only coastal. 

This FAO document I co-wrote with my friend Gilles Hosch, has the a description of the ideal configuration needed at each type of state in order to get the minimal data for a CDS (and you’ll recognise some of the words here too).

For a FFA lead eCDS, that then could be push into the WCPFC, we will not only need to have all member countries in but also on one side all DWFN (TW, China, Korea, Japan, US, Philippines, Spain) this could be achieved via pushing the participation as part the “harmonised minimum terms and conditions” or “HMTCs” that all vessels fishing in FFA waters need to comply (as they recently did with labour issues), yet this leaves out those fishing only in the high seas… and that is something that only the WCPFC and the flag states have jurisdiction.

On the other end, we also need Thailand, Vietnam, Philippines, and China (as key processing countries to play a part).

Thailand’s involvement is almost guaranteed since they have become leaders on the area, Vietnam is under the microscope because the EU yellow card (the most successful outcome of the EU IUU regulation), Phillipines’ canning industry depends totally of the fish they catch in PNG waters, so they could be coerced into it.

With China, who knows… not that they're really care about anything or anyone and not that the EU or the US are going to put any trade related measure with them…

And then is the engagement with the EU, Japan and US as final market states.

The EU has the capacity to accept RFMO’s CDS as equivalent of their Catch Certificate, it would be a long negotiation but can be done. Japan has been talking about a CDS for a while, they have been very supportive of FFA so if they are seated on the table they could be part of it.

The US system does not involve anyone else other than themselves (there is a pattern there?), the exporter inputs the dat and the importer receives it, that is it, no involvement of any fisheries authority from any state. Yet their system (SIMP) is electronic, so if we have a system where nothing leaves the country unless authorised and accounted, if that fish goes to the US the exporter (under national legislation) would have to log into SIMP via a nationally run portal, that feed into the SIMP platform.

once we get to all that… we quite sorted