Can we rely on the MSC label for sustainable fish?

The perils of accepting a “sustainable” food label without the bigger picture

by Sally Campbell

BioMar, a Danish Company, is one of the leading suppliers of “high performance” fish feed to the aquaculture industry worldwide. BioMar operates 13 feed factories including one at Grangemouth, Scotland. According to its own figures, roughly one out of five farmed fish produced in Europe, South and Central America is fed on BioMar fish feed. Worldwide, the BioMar Group supplies feed to around 60 countries and to more than 45 different fish species. A recent fire at the Grangemouth plant had SEPA responding to complaints of “fishy smells”. So, what was causing the smell? On investigation of BioMar’s website, and specifically their 2017 Sustainability Report these are the fish used in fishmeal and fish oil feed:

Fish meal and Fish oil used in BioMar in 2017 (MT=metric tonnes)

SpeciesVolume (MT)ShareSpeciesVolume (MT)Share
Blue whiting65,20430.8%Trimmings35,31433.8%
Anchoveta20,4829.7%Lesser sand-eel7,2587.0%
Lesser sand-eel19,4939.2%Sprat6,7146.4%
Capelin6,2192.9%Blue whiting5,5095.3%
Norway pout1,8660.9%Hake1,2531.2%
Other1,1970.6%Norway pout1,1321.15%
TOTAL211,752100 %Herring9770.9%

It is hard not to notice how many of these species are currently under well-publicised threat from overfishing. The costs of over-fishing around the world are well known with the loss of livelihoods for inshore communities and the removal of effective food availability for the folk in these communities and also for all classes of sea birds and marine species, causing a profound knock-on effect for regional biodiversity.

It is widely recognised that sand eels and krill are overfished. The Aquaculture Stewardship Council (ASC) is now up and running, “certifying environmentally and socially responsible seafood”. It is the opinion of many environmental NGO’s that salmon aquaculture in open sea pens should never qualify under this label as no marine salmon farm in Scotland is environmentally responsible, emptying its faecal waste, neurotoxins and antibiotics untreated into our sea lochs and coastal waters.

Whilst BioMar, in common with many fish meal producers, heralds “sustainability” labels for the fish they utilise, it is clear that these labels are marketing ploys, sometimes even known by environmental groups as “greenwash”, rather than being markers of a production judged against vigorous ecosystem sustainability criteria. By choosing seafood with the “Blue” MSC label for example we are told: “you are helping to protect oceans, livelihoods and fish for the future.” However, certification does not consider the wider ecosystem services. A sad example of the complexities of this, and that we ignore at our peril, is the research that has been conducted on the adverse effects of krill fishing on penguin chicks in the Antarctic. Krill makes up a large proportion of reconstituted fish meal and the more krill fished from these cold southerly waters means less krill for the local wildlife.

The main supplier of krill from Antarctica to BioMar is AkerBiomarine which boasts a “Blue label”. In July 2018 representatives from the seafood industry (including BioMar) and environmental NGOs led by Greenpeace, have collectively stated support for the creation of marine protected areas, including large no-fishing zones in the Antarctic. This will affect krill fishing in that region and is an acknowledged response to research which showed the effects of depleting waters of their krill populations. Krill is a rich ingredient for aquaculture feeds not only for its fish health and nutrition properties being a more “natural” food for the farmed fish but also because it is a natural source of carotenoids which give salmon and shrimp their pink colour.

This major announcement from a group of the largest krill fishing companies will see nearly all krill companies operating in the Antarctic voluntarily stop fishing in extensive areas around the Antarctic Peninsula, including ‘buffer zones’ around breeding colonies of penguins, to protect Antarctic wildlife, and represent 85% of the krill fishing industry in the Antarctic. This is an enlightened outcome as a result of groups of conflicting interests in a complex picture coming together to try to reach a collective agreement. However, it means that the fish meal, if production of farmed fish is to remain at the levels it currently is at, will have to be compounded from a modified mix of ingredients.

Other Ingredients of fish meal:
So, in 2017 BioMar’s breakdown in the total feed:
48% dry plant material
18% marine dry matter
15% plant oils
9% marine oils
5% land animal ingredients
5% micro-ingredients

In 2017 116,068 tonnes of feed from BioMar went to Atlantic salmon farms, 65% of their feed production in that year. These vegetable products shown above reduce the Fish In-Fish Out (FIFO) ratio, which they herald as contributing to increasing sustainability of fish stocks. Once again this is a clear example of ignoring a complex system that does not just involve one activity. To feed farmed salmon, more soya and palms are required, which can disrupt an ecosystem in another part of the world. This to some extent moves the largely unsustainable farming from the sea to the land. The wild salmon is a carnivorous fish, whilst for farmed salmon the main ingredient of feed in BioMar’s products is vegetable matter such as soya bean and palm products. BioMar is further researching different plant products for their feed and are now in the process of identifying with partners Panghea, a by-product from guar-gum that could be a source of protein for aquaculture. The project was born out of the need to further reduce the dependence on marine based fishmeal and fish oil and the original concept focused on fish feed solutions for salmon. Guar is an arid region plant with tolerance to drought and high temperatures, making it a good crop option in desert regions. The climate in Northwest India and Southeast Pakistan has periods of monsoon and drought cycles, to which the guar plant has become adapted over millennia.

It has long since been possible to replace fishmeal with other protein sources, but BioMar in order to push the sustainability agenda and the innovation frontier looks to produce fish feed with zero inclusion of marine ingredients where the fish oil is replaced with micro-algae and other novel ingredients. Insect protein has been raised elsewhere as a possibility.

So much of the compounded feed is now vegetarian, which is why wild salmon tastes so different to farmed salmon. Most fish farmers also have to add pigmenting compounds to the salmon food, so that the fish develop the same deep pink colour of flesh that wild salmon obtain naturally from the crustaceans and other food in their environment. These pigments are carotenoids, mostly astaxanthin and producers choose the colour their customers desire from colour charts, just like choosing the paint colour for your walls!

Fish farming is increasing throughout the world, so more feed factories are being built. This is a huge multinational industry, with great economic power, which we see daily in the west coast lochs of Scotland. Marine Harvest is building a large feed facility on the east coast of Skye at Kyleakin. The new plant costing £93 million will be completed in 2018. This plant capacity is around 180,000 tonnes per year and the plant will produce fish feed to supply Marine Harvest’s salmon farms across the western Highlands and islands of Scotland, as well as Ireland, Norway and the Faroe Islands. There is concern amongst communities and environmental NGOs in Scotland and the UK about fish health, escapes and Scotland’s inshore environment for wild salmon and creeling.

In Chile the country’s entire salmon farming sector is now under the spotlight following the escape of 690,000 fish, caused by a massive storm, from a Marine Harvest farm on July 5. The storm damaged the confinement structures. To date only 38,000 – just 5.5% of the 900,000 in the cages have been retrieved. With climate change, with increased severe storms forecast and tidal surges, the whole of Scotland’s aquaculture industry must be at risk. Their reputational risk is also rising due to sealice infections, neurotoxin and antibiotic usage.

In the latest development trends, the industry is looking at using research to genetically modify land-based crops to produce substances for fish feed that will act like fish oils. There is EU reluctance to permit the growing and trading of genetically modified food. In other parts of the world these GM crops are already being formulated in products. The latest plans for increasing omega-3 in farmed salmon which has dropped in recent years (less krill in feed) is to utilise recent research. The commercial cultivation of a Genetically Modified (GM) variety of Camelina sativa, known as false flax, is one of Europe’s oldest oil seed crops; the results from this GM crop trial have seeds containing omega-3 fatty acids normally only present in oily fish such as salmon, mackerel and herring. Fish oil grown on the farm has come a step closer. Omega-3 oils are important to fish farming because fish need them to stay healthy but do not naturally produce the substances themselves. They are manufactured by marine algae which are eaten by small fish and passed up the food chain. Farmed fish consume huge quantities of fish oils either directly or in fish meal as was shown in the tables earlier in this reporting. In 2011 around 80% of all the fish oil produced in the world went to fish farms. Experts believe the sector is growing so fast, conventional sources of fish oil will in future not be sufficient to meet the demand. We must ask ourselves if this is what we, the customer wants?

It is very difficult with the present polarised political environment to ask folk to look at a more complex picture when many of these issues are raised. Why would fish with a “sustainable” label in the Co-op be unsustainable? Obviously, it is for consumers to make their own choices and that is made even harder when there are arguments on both sides for job opportunities. But it is always worth asking a few more questions and wondering what you feel “sustainable” should really mean.

According to the World Council for Economic Development (WCED), sustainable
development means development that “meets the needs of the present without
compromising the ability of future generations to meet their own needs”. I wonder whether we are stepping into a future that will feed fish aquaculture, but further damage other ecosystems, be they on land or in the marine environment.

BioMar whose Sustainablity 2017 report I have relied upon here to some extent to provide perspective are to be commended for their considerable publically available reporting of how they define sustainability. Their output of course promotes debate in the wider community. Should you wish to explore their claims further the report is to be found at

Sally Campbell
August 2018