Press release: 17 November 2022

Seafood business high risk alert as report reveals Spain's imports exposed to illegal and unreported products

Hundreds of thousands of tonnes of high-risk seafood is entering the Spanish market each year, a new report from ClientEarth and the EU IUU Fishing Coalition has found.

The report highlights that specific species, including Atlantic bluefin tuna and swordfish, present high risks of being associated with illegal, unreported and unregulated (IUU) fishing, while others like squid are harvested in major fisheries that are not being managed at all.

Authored by the EU IUU Fishing Coalition in collaboration with ClientEarth, ‘IUU fishing, working conditions and the Spanish seafood industry: The importance of due diligence in the Spanish seafood supply chain’ explains that Spain’s seafood industry can improve internal processes to ensure that the entire supply chain is free of IUU fishing products.

IUU fishing endangers fish populations, damages marine habitats, contributes to unfair competition between fishers, and threatens the food security of coastal communities. It also affects the economic viability of seafood businesses by contributing to losses of billions of Euros and is regularly connected to human rights and labour abuses. It has been referred to as the number one maritime risk and a recent EU Court of Auditors’ report shows it is not being seriously tackled at the EU level.

Huw Thomas, head of the consultancy 3 Pillars Seafood and a supply chain expert, said, “Businesses need to face the facts and accept that if they source squid from fisheries around the world, they probably have IUU fish in their supply chain.”

Spain is the largest importer of seafood in the EU – importing large quantities of seafood from high risk countries for IUU fishing like China, Ecuador and Panama. Despite substantial efforts being made by the Spanish Government to tackle this major threat, several loopholes and risk factors remain.

“Spanish seafood businesses must improve due diligence to ensure that illegal operations and human rights abuses aren’t occurring in their supply chains. Our report shows that Spain imports thousands of tonnes of seafood from high risk countries for illegal fishing and imports large quantities of high risk species including bluefin tuna, squid and swordfish - relying on national import controls alone is not enough,” said Tom Walsh, lead researcher at the Coalition.

Despite commendable national efforts aiming to ensure that the products of IUU fishing fail to enter the EU, inherent risks remain within seafood supply chains. Import controls play a crucial role in preventing IUU seafood from entering Spain, but the industry must take steps to assess the risks posed by IUU fishing within their supply chain.

NGOs and other stakeholders encourage the Spanish seafood industry to enhance due diligence including through the implementation of voluntary tools, such as the PAS 1550:2017, to ensure that all seafood provided to Spanish consumers is free from IUU fishing and human rights abuses throughout the entire supply chain.

Quentin Marchais, sustainable seafood lead at ClientEarth said, “It is in businesses’ interest to carry out thorough due diligence. It is a way to dig into your supply chain, understand its complexity, and map out the legal and reputational risks associated with it. You cannot manage what you cannot measure. Measuring the risks you are exposed to is the first step to reducing them. It is also key to improve seafood traceability and consumers’ trust.”


Notes to editors:

Spain imported EUR 4.05 billion of fisheries and aquaculture products in 2020.

In summary, this report highlights that:

  • Spain imports large quantities of seafood from countries currently yellow-carded under the EU IUU Regulation, including Ecuador (113,000 tonnes in 2019) and Panama (10,000 tonnes in 2019). A yellow card is an EU warning of potential failures in fisheries management that, if not addressed, could lead to a red card, an EU fisheries trade ban for imports from that country, among other sanctions. Spanish businesses sourcing seafood from these countries should apply increased due diligence in order to ensure that no products linked to IUU fishing are marketed in Spain;
  • Large quantities of seafood are also imported from high-risk countries for IUU fishing (according to the IUU Fishing Index). For example, over 100,000 tonnes of seafood were imported from China into Spain, in both 2018 and 2019. In both 2019 and 2021 China received the highest IUU fishing score globally on the IUU Fishing Index. Even if they are not carded, due diligence must be applied throughout the entire supply chain when importing seafood from these high-risk countries;
  • In 2020, over 10,000 tonnes of squid were imported by Spain from Argentina and China. Global squid fisheries are largely unregulated and there have been reports of illegal fishing within Chinese squid fisheries – including in the waters of Argentina. Spanish vessels have also been found to ‘go dark’ by switching off their tracking systems close to Argentina’s national waters.
  • Illegal activities have been uncovered within the Atlantic bluefin tuna trade, involving Spanish companies. Large quantities of Atlantic bluefin tuna are imported into Spain annually, from both EU Member States and non-EU countries;
  • As a valuable commodity, there have been documented cases of mislabelling within the swordfish market. For example, there have been cases in which meat marketed as swordfish, imported from Spain to Malta, was later determined to be mako shark. Spain imports large quantities of swordfish from both EU Member States and non-EU countries and businesses must be aware of the risk posed by seafood fraud.

About ClientEarth

ClientEarth is a non-profit organisation that uses the law to create systemic change that protects the Earth for – and with – its inhabitants. We are tackling climate change, protecting nature and stopping pollution, with partners and citizens around the globe. We hold industry and governments to account, and defend everyone’s right to a healthy world. From our offices in Europe, Asia and the USA we shape, implement and enforce the law, to build a future for our planet in which people and nature can thrive together.