Posted on March, 22 2018

WWF’s Dr Geoffrey Muldoon zooms in on two main points in the recently launched, sobering report on the Live Reef Food Fish Trade: the importance of correct data, and the value of cooperation in a regional supply chain.

There's a “perfect storm” brewing in the Southeast Asian Live Reef Food Fish Trade (LRFFT), and if concerns are not addressed, the future could indeed be bleak for this billion-dollar industry.

This is the sobering message of “Going, Going, Gone: The Trade in Live Reef Food Fish,” a report released last February and published by the Swire Institute of Marine Sciences at the University of Hong Kong, ADM Capital Foundation, and the WWF Coral Triangle Programme. The report says that it “aims to reflect upon why so little progress has been made to date, towards achieving a sustainable LRFFT, by examining the trade’s many components and characteristics,” in a historical context spanning almost three decades.

According to the report, the trade consists of 15-20 main species of reef fish, coming from both wild populations and farms, from Indonesia, the Philippines, Thailand, Malaysia, and Australia as source countries. The destination: millions of consumers in Hong Kong and, largely via this free port city, in mainland China.

Hong Kong is the global hub for the trade, where much of the negotiations and movements go largely unreported and unregulated, spelling trouble for species, food security, and livelihoods in the region, the report says.

“Hong Kong remains the major trade hub because of its tariff-free status and long-established regional trade networks,” says Dr Geoffrey Muldoon, Senior Manager with the WWF Coral Triangle Programme and co-author of the report. “For this reason, LRFF does not appear to be going elsewhere. Unlike other illegally traded commodities desired in many countries, such as ivory, China and Hong Kong are by far the major destinations of live fishes.”

The report raises many points, ranging from the high value and regional importance of the LRFFT, to the fact that it is a field marked by “unrelenting overexploitation, vulnerability of species to overfishing, perverse fishing incentives due to their luxury good status, concentration of market power downstream in the supply chain, and limits to mariculture as a solution.” Dr Muldoon zooms in on two particular areas covered by the report: data issues and regional cooperation.
 

Limited data analyses

There are major concerns over data collection used to monitor the trade. Generally, limited data has been available from the countries where LRFF are sourced. As such, data collected by Hong Kong authorities has usually been relied on to analyse trade between nations, particularly for LRFF products transported by air.

“Historically, the issue of under or misreporting is not new,” notes Dr Muldoon, certainly not by fishery agencies and LRFF traders in source countries, though to a lesser extent in Hong Kong. “It has long been held that most underreporting occurs for LRFF transhipped by sea. This has to do with exemptions on certain types of registered vessels, and poor monitoring of sea imports by authorities.” Recent analysis has challenged that assumption.

Comparing trade data for live grouper exports from Australia to Hong Kong—mainly of Leopard Coralgrouper, caught on Queensland’s Great Barrier Reef—revealed sizeable and persistent discrepancies between the two countries’ records. Data shows that Hong Kong’s Census and Statistics Department (C&SD) recorded imports from Australia for this species were on average 50 percent lower than the comparative and highly reliable Australian export data over the period of 2006 to 2016. 





















With this revelation, “a whole new light has been cast on underreporting,” Dr Muldoon emphasises. “If the discrepancy is so large for Australia, where good export records are available to counter whatever Hong Kong records are telling us, what does that mean for other countries known for having poor data, and for the trade as a whole? And this is the critical point. While superficially there are mechanisms in place to ensure data accuracy and quality, in practice, it would appear they are not working. While we cannot point to where the system is breaking down, we now have reason to question the veracity of Hong Kong’s data, and grounds for believing underreporting could be much, much larger than originally thought.”

This finding naturally trains all eyes on Hong Kong. “Hong Kong’s role in the LRFFT and the trade’s poor record in sustainability and transparency must not be underestimated,” the report says. “Traders, transport, and logistics carriers are allowed to exploit a vacuum created by inadequate and outdated regulation, loopholes in the law and lax enforcement of live seafood trade into, within, and through Hong Kong.”

“As the epicentre of the LRFFT, it is critical Hong Kong takes steps to regulate before it is too late,” stated Dr Yvonne Sadovy, professor of biological sciences at the University of Hong Kong and lead author of the report, in an earlier interview.
 

‘Pressure must be applied’

Hong Kong recently released its Biodiversity Strategic Action Plan as part of its commitment to the Convention on Biological Diversity, reports Dr Muldoon, which mentions the need for stricter control in the illegal wildlife trade to reduce the city’s negative impact on global biodiversity. “The existence of this plan provides a platform through which pressure must be applied. For example, Hong Kong’s local and international commitments in relation to safeguarding biodiversity means it should be ensuring that imports and sales of Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)-listed Humphead Wrasses are all legal.”

Dr Muldoon is also looking beyond the borders of Hong Kong towards China’s official Eco-Civilization vision, its blueprint of reforms for addressing environmental issues, again emphasising the need to advocate with relevant Chinese agencies “to secure stronger commitments to a more responsible seafood trade—particularly, around transparency in meeting international environmental obligations and illegal, unreported, and unregulated (IUU) fishing issues surrounding imports of live fish.”

The report acknowledges the LRFF trade chain as being “supplied by many and controlled by a few,” meaning traders in Hong Kong are wielding considerable power. “These traders are virtually uncontrolled, and it has been recognised that illegal activities, often abetted by them seriously compromise the long-term future of this trade,” Dr Muldoon says. “Their power sustains and exacerbates inequities in the trade in terms of value distribution and social dislocation of fishing communities in source countries.” Traders keep the upper hand by offering almost irresistible economic incentives for fishers to target LRFF, a product prized by China’s conspicuous consumers. “While this has provided a short-term windfall for some, the long-term livelihood impacts have been disastrous in many communities,” he notes.

Some problems—such as mismanagement of LRFF resources—are not limited to Hong Kong, though, Dr Muldoon qualifies. “Porous borders and ineffective regulation by responsible agencies facilitate extensive IUU trade within and between source and destination countries, including cross-border trade, such as out of Indonesia, from the Philippines to Malaysia, as well as from Hong Kong to mainland China.”

Remedial efforts, particularly the trans-boundary “whole-of-supply-chain approach” that espouses regional cooperation, specifically through the Coral Triangle Initiative for Coral Reefs, Fisheries and Food Security (CTI-CFF), initiated in 2007, must be ongoing.
 

Multilateral partnership

Noting the CTI-CFF as “a multilateral partnership of six countries to address the urgent threats facing the coastal and marine resources in one of the most biologically diverse and ecologically rich regions on earth,” the report steps through a series of regionally focused events designed to leverage this partnership for reform. Beginning with coordination among the CT countries from 2008, and a workshop to develop an LRFFT sustainability roadmap, held in Hong Kong the following year, this cooperative approach culminated in an Association of South East Asian Nations (ASEAN) Intergovernmental Forum in 2013. The ASEAN forum sought, among other objectives, to reach regional agreement on sustainable LRFFT resolutions within the CTI-CFF; to see common national and regional policies drafted; to establish a Regional LRFFT Forum; and to have coordination and support from the CTI-CFF regional secretariat.

“The steps after the forum were intended to take this demonstrable regional momentum and seek to engage more meaningfully with the Hong Kong government,” says Dr Muldoon. The results were disappointing, in that Hong Kong “preferred to put the onus back on source countries, as they had every right to do, but resisted pressure to take responsibility for the role it could play on several levels from reforming inadequate regulations, placing greater emphasis on biodiversity conservation, and improving transparency through better monitoring and control.”

Other obstacles to the success of achieving such cooperation exist, at the source country and on a regional level. Although its destructive impacts are widely felt, the LRFFT, as a high value fishery, deals with relatively small volumes. Yet, as Dr Muldoon explains, despite accounting for less than 2 per cent of the volume of the Western and Central Pacific tuna fisheries, the LRFFT’s value is roughly one-third of that fishery. “ Notwithstanding, the catching sector is dominated by small scale fishers, and governments traditionally have not allocated a lot of time and effort to supporting this sector. Despite the LRFFT clearly being ‘big business,’ this means that remedial efforts are not being implemented by national governments on the scale they should be to redress the major issues, such as overexploitation and destructive and IUU fishing.”

Still, Dr Muldoon is betting on such an approach for the future, especially in the light of the still-growing demand for LRFF. “Regional and whole-of supply chain approaches are critical to success. But they cannot be done in isolation, and the report includes a number of clear recommendations aimed at four key constituencies: source countries, traders and retailers including the transport sector, destination countries including consumers, and non- and intergovernmental organisations.”

As Dr Sadovy stated in a previous interview, “We are not talking about not eating fish at all…We need to know where seafood comes from—that it’s legally sourced, safe to eat, and that it is responsibly sourced and preferably sustainable.”

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