MAPPING SHRIMP

FEED SUPPLY CHAIN

IN SONGKHLA PROVINCE
TO FACILITATE FEED
DIALOGUE
FULL REPORT
SUBMITTED TO OXFAM THAILAND
Lead Researcher: Sarinee Achavanuntakul
Research Team: Srisakul Piromwarakorn
James True
Pattraporn Yamla-Or
Sasiwimon Khlongakkhara
Koranis Tanangsnakool
March, 2014
1. Research Background 13
1.1 Objective of this project 14
1.2 Objective of this report 14
1.3 Methodology and Limitations of Research 15
2. Overview of Fishmeal Industry 16
2.1 Thailands Fisheries from the Past 16
2.2 Why trawlers and push nets are banned 20
2.3 Characteristics of Fishmeal 22
2.4 Overview of Fishmeal Industry 26
2.4.1 Global 26
2.4.2 Thailand Fishmeal Production 28
2.4.3 Thailand Fishmeal Consumption 31
2.4.4 Thailand Fishmeal Exports 31
2.4.5 Thailand Fishmeal Imports 33
2.4.6 Songkhla Fishmeal 34
2.5 Fishmeal Price 35
2.6 Classification 37
2.7 Government policies and regulations 38
3. Literature review: impact of trash fish industry on ecosystems 39
4. Literature review: Changes and Impact on Local Artisanal Fishing Community 48
4.1 Definitions of Artisanal Fisheries 48
4.2 Thailands Artisanal Fishing Communities 49
4.3 Conflicts between Commercial Fishermen and Artisanal Fishermen 49
4.4 Impact of Commercial Fisheries in the 3,000-Meter Prohibited Areas on Artisanal Fishermen 50
5. Existing regulations and standards relating to trash fishing and Thailand implementation 54
5.1 FAO Code of Conduct for Responsible Fisheries and the EU regulation on IUU fishing 54
5.1.1 The development of IPOA-IUU 54
5.1.2 The definition of illegal, unreported and unregistered fishing activities 56
5.1.3 The European Union regulation to combat IUU fishing 57
TABLE OF
CONTENTS
TABLE OF
CONTENTS
5.2 Standards on trash fishing at an international level 57
5.2.1 Marine Stewardship Council 57
5.2.2 Aquaculture Stewardship Council 58
5.2.3 The certification standard for the Responsible Supply of Fishmeal and Fish Oil 58
5.2.4 Best Aquaculture Practices 59
5.2.5 Global Good Agricultural Practice (Global G.A.P) 60
5.2.6 Friend of the Sea 60
5.2.7 ASC, GAA, and Global G.A.P. agreement on responsible sourcing of fishmeal and fish oil 60
5.3 National regulations and standards 67
5.3.1 Thai fisheries law 67
5.3.2 Control of IUU fishing 70
5.3.3 Compliance to the EU Requirements: Thailand catch certificate scheme 74
5.3.4 Fishmeal certificate scheme in Thailand 76
5.3.5 A Roadmap for Sustainable Development of Thailands Fisheries 80
6. Estimates of biomass diverted to fishmeal supply chain 81
6.1 Preamble 81
6.2 Data collection summary 85
6.3 Biomass analysis conclusion 95
7. Supply Chain of Fishmeal Industry in Songkhla and Its Activities 97
7.1 Supply Chain and Stakeholders activities 97
7.2 Responsible sourcing of fishmeal raw material 112
7.2.1 Animal feed mills 112
7.2.2 Fishmeal producers 114
7.2.3 Suppliers of raw materials 115
7.3 Supplementary information: field research at Ta Sa-aan Port 116
8. Case Study: Sustainable Fishing in Peru 120
8.1 Overview of Perus anchoveta industry 120
8.2 History of the Peruvian anchoveta fishery 121
8.3 Toward fishery sustainability 124
8.4 Lessons from Peruvian sustainability 129
9. Impact of Supply Chain Activities, Gap Analysis, and Recommendations 132
9.1 Direct Impacts on Thai marine ecosystem 132
9.2 Indirect Impacts on Thai marine ecosystem 132
9.3 Gap analysis and recommendations 135
Appendix 149
Figure 1: Marine Production in Thailand from 1950 - 2011 17
Figure 2: Catch Per Unit Effort from 1961 2010 (kilograms per hour) 18
Figure 3: Thailands EEZ map 19
Figure 4: Number of fishing boats by type, 2011 21
Figure 5: Volume of wild-caught marine production by type of fishing gears, 2010 (tons, % of total) 21
Figure 6: Main species and share of global output and export 22
Figure 7: Species of fish usually found in trash fish 23
Figure 8: Production process of fishmeal and fish oil 25
Figure 9: Composition of 1st, 2nd, and 3rd grade fishmeal 26
Figure 10: Worlds fishmeal production, 1988 - 2009 27
Figure 11: Top six fishmeal producing countries (thousand tons) 27
Figure 12: Top six fishmeal consuming countries (thousand tons) 27
Figure 13: Top six fishmeal exporting countries (thousand tons) 28
Figure 14: Top six fishmeal importing countries (thousand tons) 28
Figure 15: Thailands fishmeal production by year, 2006-2011 29
Figure 16: Thailands fishmeal production and producers, 1987 - 2011 29
Figure 17: Thailands top five fishmeal producing provinces in 2011 30
Figure 18: Raw materials of fishmeal, 1987 - 2011 30
Figure 19: Thailands fishmeal export by year, 2008-2013* 32
Figure 20: Thailands fishmeal export by category, 2007 2013* 33
Figure 21: Thailands fishmeal export by category, 2008 2013* 33
Figure 22: Raw materials of fishmeal in Songkhla, 1999 2011, divided into trash fish,
trimmings (by-product) and other fish 34
Figure 23: Average prices of fishmeal by province in 2011 (Baht per kilogram) 35
Figure 24: Peruvian fishmeal price from 1980 2013 (US$ per ton) 36
Figure 25: Prices of trash fish, 1st and 2nd grade fishmeal, and Peruvian fishmeal, 2007-2011 (Baht per kilogram) 36
Figure 26: Estimated quantity of livestock and feed ingredients required for sufficient animal feed
in Thailand, 2003-2012 (tons)* 37
Figure 27: Reported finfish landing in the Gulf of Thailand 43
Figure 28: MSY model 44
Figure 29: Simplified coastal food webs 46
Figure 30: Average daily income per boat of artisanal fishermen in Songkhla during 1993-1999 51
Figure 31: Average daily cost per boat of artisanal fishermen in Songkhla during 1993-1999 52
Figure 32: Average daily profit/loss per boat of artisanal fishermen in Songkhla during 1993-1999 53
Figure 33: Requirement for Sourcing of fishmeal and fish oil of BAP, ASC, G.A.P. 61
Figure 34: Summary of international standards and certified Thai companies 62
Figure 35: Figure 35: Key features of Fisheries Act 1947, compared to draft of the new fisheries act 69
Figure 36: Vessels registration process 71
Figure 37: Number of registered Thai fishing vessels, 2010-2013 71
TABLE OF
FIGURES
TABLE OF
FIGURES
Figure 38: Process of acquiring fishing license and fishing permit in Thai waters 72
Figure 39: Process of acquiring fishing license and fishing permit in overseas waters 73
Figure 40: Number of fishing vessels receiving and returning fishing logbook from 2010-2013 74
Figure 41: Catch Certificate Scheme 75
Figure 42: Amount of certified marine products exported to the EU and number of catch certificate issued
from 2010-2013 76
Figure 43: Fishmeal certificate scheme 78
Figure 44: Number of fishmeal certificate (submitted for verification), amount of materials, and amount of fishmeal
by source of materials from 10 June 31 December 2013 78
Figure 45: Summary of various schemes 79
Figure 46: Pla pet condition in Songkhla 82
Figure 47: Reported finfish landings in the Gulf of Thailand 83
Figure 48: Volume of marine fish landed at Songkhla (Ta sa-aan) 84
Figure 49: The fisheries pier at Songkhla just before dawn (Image S. Arunrugstichai) 86
Figure 50: Results composition of landed product at Songkhla 87
Figure 51: Summary of catch statistics for the vessels interviewed for this study 88
Figure 52: Selections of pla pet found at port 89
Figure 53: Department of Fisheries Catch per Unit Effort (CPUE) figures for 2010/11. 90
Figure 54: Composition of pla pet from a vessel offloading at Songkhla in August 90
Figure 55: Example composition of pla pet from a vessel offloading at Songkhla in September 91
Figure 56: Summary of the diversity of biota landed as pla pet in Songkhla in August and September 91
Figure 57: Average species composition of the food fish component of catches landed at Songkhla 92
Figure 58: A multispecies basket of fish landed in Songkhla 93
Figure 59: crustaceans, squids and fish mashed together into unrecognizability 94
Figure 60: Ta Sa-aan Afterwards 95
Figure 61: Peruvian fishmeal and fish oil supply chain 97
Figure 62: Map of fishmeal supply chain in central and eastern regions of Thailand 98
Figure 63: Map of fishmeal supply chain on Andaman Sea side 99
Figure 64: Map of fishmeal supply chain on Gulf of Thailand side 99
Figure 65: Map of fishmeal supply chain in Songkhla 100
Figure 66: Fishmeal producers in Songkhla, ranked from largest to the smallest 102
Figure 67: Raw materials of fishmeal in Songkhla, 1999 2013, divided into trash fish, by-products and other fish 102
Figure 68: Relationships between top five fishmeal producers in Songkhla and fish-processing manufacturers 103
Figure 69: Fishmeal prices at Bangkok market announced by CPF on February 8, 2014 104
Figure 70: Fishmeal operation flow chart 105
Figure 71: Summary of trash fish usage (highlighted in red) and map of supply chain of fishmeal industry
in Songkhla 108
Figure 72: Activity map of fishmeal supply chain and practices under Thailands fishmeal certificate 111
Figure 73: Animal feed mills based on fishmeal traceability, ranked from highest % to lowest % 114
Figure 74: Fishmeal produced from whole fish and fishmeal produced from non-traceable whole fish by purchasers
(percentage) 116
Figure 75: Ta Sa-aan Port 117
Figure 76: Ta Sa-aan Port Landing Area 118
Figure 77: Peruvian anchoveta 121
Figure 78: Historical Peruvian anchoveta landing, major El Nio and fishery phases 122
Figure 79: Fleet size and number of fishmeal factories: 19502006 124
Figure 80: Peruvian rapid decision flow on fishing closure (IFFO 2009) 127
Figure 81: Stakeholders activities and their impacts on Thai marine ecosystem 134
Figure 82: Gulf of Thailand at night, as seen from space 136
ABBREVIATIONS
APFIC The Asia-Pacifc Fishery Commission
ASC The Aquaculture Stewardship Council
BAP Best Aquaculture Practices
CC Catch Certifcate
CD Customs Department, Ministry of Finance
CPF Charoen Pokphand Foods
CPUE Catch Per Unit Effort
DFT Department of Foreign Trade, Ministry of Commerce
DOF Department of Fisheries
EEZ Exclusive Economic Zone
EU European Union
FAO Food and Agriculture Organization
FAO-COFI Food and Agriculture Organization Committee on Fisheries
FIP Fishery Improvement Project
FMFO Fishmeal and Fish Oil
FSARG Fishery Statistics Analysis and Research Group
FOS Friend of the sea
GAA Global Aquaculture Alliance
Global G.A.P. Global Good Agricultural Practices
GoT Gulf of Thailand
IDH Sustainable Trade Initiative (Initiatief Duurzame Handel)
IFFO International Fishmeal and Fish Oil Organization
IFFO RS Responsible Supply of Fishmeal and Fish Oil
IMARPE The Instituto del March del Peru
IPOA The international plans of action
IUCN The International Union for Conservation of Nature
IUU Illegal, Unreported, and Unregulated Fishing
IVQ Individual Vessel Quota
MCPD Marine Catch Purchasing Document
MCPD-FM Marine Catch Purchasing Document Fishmeal
MCTD Marine Catch Trans-shipping Document
MOAC Ministry of Agriculture and Cooperatives
MSC Marine Stewardship Council
NPOA-IUU National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported
and Unregulated Fishing
RFMO Regional Fisheries Management Organizations
RPOA-IUU Regional Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported
and Unregulated Fishing
SFP Sustainable Fisheries Partnership
SNP Sociedad Nacional de Pesqueria (Perus National Fisheries Society)
TAC Total Allowable Catch
TFMA Thai Feed Mill Association
TFM Thaiunion Feedmill
TFPA Thai Fishmeal Producers Association
TUF Thaiunion Frozen Products
UNGA United Nations General Assembly
WWF World Wildlife Fund
TABLE OF
ABBREVIATIONS
TABLE OF
ABBREVIATIONS
FOREWORD
FOREWORD
This research contributes to the Economic Justice Programme of
Oxfam Thailand. Oxfam is an international development agency that
works in more than 90 countries worldwide. We have the mission to work with
partners to end poverty and inequality. In Thailand, the Economic Justice
Programme empowers peoples organizations with knowledge and
information, and partners with key stakeholders in the country and regions
to achieve equal economic opportunities. Two main target groups are the
fsherfolk and the small scale farmers. With close consultations with Oxfams
partners, we are working to achieve the community right to joint natural
resources management, climate change adaptation and gendered enterprise
and market.
This research is aimed to inform the Association of Thai Fisherfolk
Federations, civil society, relevant public and private sectors and hope it will
springboard discussions towards more sustainable marine management
which also takes fsherfolks right into account.
Oxfam Thailand would also like to thank Thai Sea Watch Association
(TSWA), our partner, whose support for feld coordination and information
was crucial to the success of this research.
8
EXECUTIVE
SUMMARY
EXECUTIVE
SUMMARY
product which is completely unsaleable in any
other market (especially used in reference to
badly damaged or putrescent products). In Thai
fsheries parlance, such trash fsh is known as
pla pet and does not refer to low-value, but
otherwise edible fsh.
Thi s research fnds t hat Thai l and s
demersal fshery has been severely depleted
by overfshing. Excess fshing capacity over the
past four decades has meant that Catch Per
Uni t Eff ort (CPUE) has been decl i ni ng
continuously since 1961 from almost 300
kilogrammes per hour to 17.8 kilogrammes in
2010. The rapid depletion, contrasts with
published production fgures, suggesting that
Thailand has been depending on resources
from other countries for a long time.
It is now widely recognized that unselective
fshing aimed at maximizing the total catch, such
as bottom trawling which yields the kind of trash
fsh used in Thailands fshmeal production,
tends to dramatically change marine ecosystem.
Small fsh and invertebrates such as squids that
feed mainly on plankton will become over-
represented in the ocean, and will quickly
domi nat e t he syst em. Over fshi ng i s
increasingly understood to result in changes
in the structure and functions of marine habitat,
especially organisms relative positions in the
food chain (technically called trophic level of
an ecosystem). Since populations of many small
fsh species depend on adding new members
(recruitment in scientifc term), overfshing has
This research project is predicated on the
premise that in order to constructively engage
shrimp industry in Thailand to implement more
sustainable supply chain practices, one of the
most important frst steps is to pinpoint the
impact of fshmeal (shrimp feed) industry on the
livelihood of coastal communities in Thailand,
as well as map their supply chain in order to get
a clearer picture of business conducts of key
stakeholders for use in evaluating potentially
fruitful engagement strategies.
Fishmeal is a main protein ingredient for
animal feed, especially for fsh and shrimp feed.
During this research, we encountered many
different accounts of ratio between whole fsh,
trimmings, and trash fsh used in fshmeal
production. While the global norm for fshmeal
is that 75% of raw materials comprise whole fsh
(including trash fsh in international defnition,
i.e. undesirable or unpalatable fsh), and 25%
trimmings, Thai Feed Mill Association claims
that raw materials of fshmeal in Thailand are:
35% trimmings from canned fsh manufacturers,
18% trash fsh, 15% sardinellas and other fsh,
20% trimmings from Surimi producers, 2% trash
fsh from overseas waters and the remaining
10% are trimmings from other fsh processing
manufacturers.
In part, this variance can be explained by
the imprecision of the phrase trash fsh.
Whereas in Western countries, trash fsh means
undesirable or unpalatable fsh, in modern
Thailand, it means exclusively that fraction of
9
SUMMARY
SUMMARY
been suggested as the main reason for the
declining fsh stock that is available to artisanal
fshermen. This of course has tremendous
consequence to the l i vel i hood and food
security of artisanal fshermen who rely on
natural replenishment of coastal fsh stock. It
also affects industrial fshermen who target adult
fsh population.
From the statistics of small-scale fshing
households, we found that the majority of the
artisanal fshermen in Thailand use small
outboard powered boats. In Songkhla, the
percentage of artisanal fshermen who used
such boats was 63.64% or 3,930 households in
2000, and about 27.5% or 1,683 households
di d not use any fshi ng vessel . Severe
overcapacity in the industrial fshing industry
resulting in the depletion of near-shore marine
resources, has left local artisanal fshermen with
very limited choices as 1) their boats, if any,
were relatively small, so they could not go to
fsh very far from shore 2) many of them had no
skill other than fshing. When the previously
abundant coastal sea became barren, local
artisanal fshermen faced a lot of problems, both
fnancial and social. Financial problems include
decreasing incomes and increasing costs of
fsheries eventually leading to informal debts.
One research in fve villages in Songkhla during
1993-1999 showed that local fshermens
income in 1999 fell 3-40 times from the 1993
level.
Our fel d r esear ch f or t hi s pr oj ect
discovered that, with the exception of a single
vessel interviewed in August, the vessels
interviewed in September 2013 were landing
around 4 tons of commercial fsh per trip on
Songkhla fshing port, after spending anywhere
between one and two weeks at sea. This catch
was supplemented by roughly 6.5 tons of
pla pet. All of the skippers interviewed stated
that their fshing was conducted in the vicinity
of Mu Koh Kra (an offshore group of islands in
Nakhorn Sri Thammarat province). The vessels
were all standard medium otter-board trawlers
(24-40m in length, crew of 5-6, powered by
275-315 horsepower diesel engines, and
deploying trawl nets with 10 metre gape), and
represent a reasonable sample of the types of
medium-sized commercial fshing vessels
returning product to Songkhla at that time of
year.
The fgures presented here represent an
average total return on fshing effort (CPUE) of
approximately 49(17) kilogramme/hour for the
vessels landing catch in August and September.
The high catch rates of juvenile and trash fsh
i n demersal trawl s can be expl ai ned by
inappropriately fne mesh used in the cod-ends
of nets. The Thai Department of Fisheries
Master Plan suggests that 40 millimetres is an
appropriate mesh size for demersal trawl
fsheries in the Gulf of Thailand. None of the
vessels surveyed used mesh larger than 25
millimetres, and most used 20 millimetres or
less. Push-net fshermen use even fner
meshed nets (as little as 10 millimetres) and
frequently target areas utilised as nurseries by
many speci es of fsh and crust aceans.
Juveniles of commercially valuable species and
those important in food security for local people
are killed in large numbers, wasting their
potential.
The wastefulness of overly-fne mesh sizes
is compounded by the use of long trawl duration,
often 6 hours or more, meaning that any product
captured during the frst few hours of the tow
even if it is of commercially valuable species will
become ruined and unsalable and will become
pla pet. Tossapornpitakkul et al. (2008)
reported that the average pla pet composition
of catches in Nakhon Sri Thammarat and
Songkhla averaged 42.08% of the annual
capture for small otter board trawlers such as
those we interviewed. These authors also
suggested that the catch composition changes
throughout the year (with pla pet being 40% of
the catch in the Northeast monsoon, 47%
between the monsoons, and 40% during the
Southwest monsoon). However, we found an
10
average of 62% pla pet in catches landed in
September, at the end of the Southwest monsoon.
This suggests that the situation has worsened.
Likewise, the volume of pla pet per vessel
landing (averaging slightly more than 6 tons)
coincides with Songkhla fsheries records
(roughly 4000 vessel landings, for a total of
25,000 tons of pla pet.) Theoretically, 100% of
pla pet landed at Songkhla could be sold to
fshmeal producers, as could any other wasted
or degraded product. However, most of the pla
pet was too decomposed to be used as
feedstock for the high grade fshmeal preferred
for shrimp food production, so they are sold to
factories that produce lower-grade fshmeal at
lesser value.
In-depth interviews with fshmeal factories
based in Songkhla found that, of the 25,000 tons
total estimated pla pet amount landed every
year, approximately 5,760 tons or 23% are sent
to fshmeal producers based in Songkhla; the
remaining 77% probably went to fshmeal
producers in other provinces.
The main raw materials used in fshmeal
production in Songkhla are trimmings from
fsh-processing manufacturers e.g. surimi, tuna
canning; fsh ball producers as well as anchovy
producers and fsh retailers at the markets which
accounted about 80% of the estimated total raw
materials of 100,215 tons, or 79,964 tons in
2013. Fi shmeal producers al so buy raw
materials directly from commercial fshing boats,
as well as brokers who collect trash fsh from
local fshing boats from Songkhla and other
provinces. This accounted for 20% of raw
materials or 20,250 tons. Of this amount, 62%
or about 12,609 tons were fsh landed in
Songkhla (which includes 5,760 tons of trash
fsh or pla pet); the remaining 38% or 7,641 tons
were fsh from other provinces such as Satun
and Pattani, as well as imported fsh.
Animal feed mills activities that cause
indirect impacts are similar to those of fshmeal
factories, as animal feed mills are major users
of fshmeal produced from trash fsh or fsh
caught unsustainably. In effect, they are the
ones that create demands for trash fsh. It starts
when they set buying criteria. Many feed mills
set buying criteria and prices based on the
qualities of the fshmeal alone, not by how fsh
raw materials of fshmeal were caught. Thus,
fshmeal produced from trash fsh caught by
trawlers and push nets that destroy marine
ecosystem can be sold to animal feed mills. This
encourages fshing boat owners to continue
their unsustainable fshing practices.
The good news is that currently several
feed mills in Thailand already implement various
sustainable procurement practices, to varying
degrees of success, partly owing to pressures
from the ultimate buyers of frozen food exports,
particularly the European Union. For example,
as of March 2014 both Charoen Pokphand
Foods (CPF) and Thaiunion Frozen Products
(TUF), two major feed mills, are certifed Best
Aquaculture Practices (BAP) 4-star or top level
status. CPF is also certifed under Global Good
Agricultural Practice (Global G.A.P). CPF is far
and away the l argest buyer of fshmeal
produced in Songkhla, with 45% market share
of fshmeal sold to animal feed mills, followed
by Betagro (17%), Thaiunion Feedmill (11%),
Lee Pattana (9%), and Krungthai Feedmill (3%).
Top three pl ayers CPF, Betagro, and
Thaiunion have 73% share of the market
combined.
Our analysis of biomass catch as well as
fshmeal supply chain in Songkhla show that
there is signifcant room for improvement in
sustainable sourcing. Only fshmeal used by
Betagro and Krungthai Feedmill is currently
100% traceable, since they both buy 100%
fshmeal from one single fshmeal producer that
is 100% traceable. Among major feed mill
players, CPF, Lee Pattana, and Thaiunion
Feedmill have the highest share of fshmeal
produced from non-traceable sources 74%
combined.
11
Our analysis of biomass catch as well as
fshmeal supply chain in Songkhla show that
there is signifcant room for improvement in
sustainable sourcing. Only fshmeal used by
Betagro and Krungthai Feedmill is currently
100% traceable, since they both buy 100%
fshmeal from one single fshmeal producer that
is 100% traceable. Among major feed mill
players, CPF, Lee Pattana, and Thaiunion
Feedmill have the highest share of fshmeal
produced from non-traceable sources 74%
combined.
Complicating the picture is the fact that,
since trash fshing is not yet considered
categorically illegal in Thailand, it is possible
even for traceable fshmeal (i.e. complying with
the standards) to i ncl ude trash fsh raw
material. In other words, currently there is no
sustainability standard or fshmeal certifcate
scheme in Thailand that can ensure that no
trash fsh was used in fshmeal production.
For example, there were 575 tons of fshmeal
produced from trash fsh sold to CPF, about half
of this amount was traceable and got the
fshmeal certifcation under private sectors
fshmeal certifcation scheme.
We observe three key limitations of current
sustainability standards and certifcate schemes
as currently practiced in Thailand:
1. There i s currentl y no sustai nabl e
sourcing scheme or standard that all major feed
mills subscribe to. Unless any scheme/standard
incorporates all large feed mills, there would
still be a market for fshmeal produced from
irresponsibly-sourced raw materials such as
trash fsh, and therefore this practice will con-
tinue.
2. Most schemes rely on a self-report
mechanism. Nothing can assure full traceability
or guarantee that the fshermen themselves
fll out the necessary documentation. More
specifcally, the source of fshmeal raw materials
cannot be verifed due to the lack of location-
specifc audit mechanisms, e.g. satellite-
positioning tools to ascertain that the fshing
boat is really fshing at the stated location.
Therefore, it is currently only possible to check
whether the documents are flled out correctly,
not the correctness of the document contents.
3. Currently every sustainable sourcing
scheme and st andard i s based on t he
internationally accepted defnition of IUU
Fi shi ng the catch must not be Il l egal ,
Unreported, and Unregulated (IUU) to ft
under this defnition. But due to Thailands
out dat ed fsher y l aw, what i s wi del y
considered damaging fshing conduct e.g.
small mesh size of trawls, is not illegal in
Thailand. In addition, every illegal conduct
under fsheries law is considered illegal only
when the fsherman is caught in the act.
Therefore, damaging fshing in Thailand is not
considered IUU Fishing, and therefore no
st andard based on I UU can eff ect i vel y
di scourage t rash fsh t rawl i ng. Thi s i s
Company
% Share of Fishmeal
from Songkhla Sold
to Animal Feed Mills
% of Traceability
Traceable
Fishmeal Amount
(tons)
CPF 45% 81% 6,839
Betagro 17% 100% 3,270
Thaiunion Feedmill 11% 47% 972
Lee Pattana 9% 36% 600
Krungthai 3% 100% 600
12
exacerbated by i nsuffci ent control and
monitoring systems due to limited resources.
Consequently, illegally-caught marine products
can be landed legally.
Lessons that Thailand can learn from the
case study of Perus sustainable fshing industry
also show gaps in the current attempts toward
sustainable practices as follows:
1. Si nce overfshi ng and destructi ve
fshing are tragedy of the commons problem
in economics parlance, where efforts of a few
unscrupulous players i.e. free riders can ruin
the resources for everyone, it is necessary to
implement solutions and standards across the
board, i.e. encompassing every stakeholder.
Peru successfully utilizes a combination of laws
(e.g. Individual Vessel Quota (IVQs), mesh size,
by-catch regulation, seasonal closure, fshing
rights) and industry involvement and self-
regul ati on (parti ci pati on of SNP (Perus
National Fisheries Society) in setting quota and
resolving conficts) across the board, while
Thai l and sti l l has seri ous gaps from the
legal defnition (e.g. trash fshing still not
categorically illegal, practices considered
only illegal when caught in the act), weak
enforcement, to piecemeal participation of
standards and voluntary schemes (e.g. only one
feed mill is offering monetary incentives under
fshmeal certifcate scheme).
2. Science-based data and technology
are both vital to ensure fsheries sustainability
and effective enforcement. IMARPE, major
government marine research agency in Peru,
i s recogni zed gl obal l y as a worl d cl ass
authority, continually reporting maximum
sustainable yield, ecosystem conservation, and
resource sustainability considerations to the
government on which to base decisions such
as quota setting. On the technology front, all
commercial fshing vessels in Peru are required
to install satellite tracking devices to ensure
enf orcement of seasonal cl osures and
individual quotas, since the government can
track the movement and location of vessels
in real-time. In Thailand, there is yet no
sustainability standard or scheme which
includes satellite tracking of fshing boats to
ensure that traceability documentation is
correct, and maximum sustainable yield is not
yet a part of systematic decision-making at
policy level.
3. The clearer the business case for
sustainability, the more incentives players have
to comply with sustainability laws/standards/
schemes. In Peru, IVQs helped encourage feet
operators to maximize their effciency through
carefully fshing trip scheduling, accounting for
abundance, and proximity to shore to achieve
shorter and more successful fshing trips.
Consequentl y, the feet recei ves fresher
landings, providing higher-quality fshmeal
production and ultimately higher profts with
lower costs due to less fuel consumption. In
contrast, there is as yet no clear business case
for sustainability in Thailands fshmeal industry
in Songkhla; most fshmeal producers that
participate in the fshmeal certifcate scheme do
so only because they are paid a price premium
by the buyer (currently only CPF), or they must
do it as part of the buyers requirement.
There is only one fshmeal producer that
cites competitiveness as the reason they
participate in the scheme; since they cannot
compete on quality, they offer full traceability
to build credibility and trustworthiness.
Given the above major gaps between
current practices and best practice in Peru,
we believe it is imperative that all current efforts
to move the fshmeal industry in Thailand
towards a more sustainable pathway from new
fsheries law to the industrys latest Fisheries
Improvement Project are synchronized and
truly encompass all stakeholders, designed to
close the above gaps as much as possible with
a view toward long-term sustainability of marine
ecosystems in Thailand.
13
Aquaculture is one of the fastest growing
food production systems with the total economic
value around 150 billion USD worldwide. This
industry is controversial for its extensive impact
on society and ecosystems. Yet it also presents
signifcant food production and economic
opportunities for developing countries as
dominant aquaculture producers, including the
rural areas in which that production takes place.
Thailand is the worlds largest exporter of
shrimp, and therefore has one of the largest
shrimp feed industries in the world. However,
the feed industry in Thailand is still little
concerned wi th qual i ty i ssues and l ess
incentivized to try and comply with existing
sustainability standard setting mechanisms (or
eco-labels) such as RSPO, RTRS, SAN, MSC,
FT and/or organic voluntary standards. In
addition, the use of genetically-modifed
organisms (GMO) in these commodities is less
transparent. Moreover, from a sustainability
perspective, there is a blatant ecological
ineffciency in the system: it has been estimated
that 2 kilograms of feed is required to produce
1 kilograms of aqua-cultured fsh.
The problem is that increasing demand for
lesser quality fsh, grains, and soy for aquaculture
feeds drives growing unsustainable negative
impact on global food production systems as
well as livelihoods of poor people in fsheries
and agriculture. This takes place particularly in
developing countries; affecting agriculture
potential in rural areas, access to land for rural
poor; and/or ecosystem services for those
depending food production systems such as
capture fsheries and forestry. Protein is the
major component for shrimp feeds and animal
proteins have long been considered essential,
since they are nutritionally appropriate and
readily digestible. Fishmeal has been the
traditional choice amongst all animal proteins in
aquaculture feeds for its protein quality,
palatability and as a source of essential amino
acids. It has been estimated that almost 50% of
by-catch and (legally) under-sized catch in
fsheries goes into aquaculture feed. What this
means for the coastal artisanal fshers of
Thailand is largely unknown.
Oxfam in Thailand has been working with
civil society on community rights to coastal
resource management and access to agricultural
land rights. Globally, Oxfam has been engaged
i n t he devel opment of t he Aquacul t ure
St ewardshi p Counci l (ASC; see: www.
ascworldwide.org) and several standards this
certifcation system houses, in particular with
regards to shrimp. One of the main drawbacks
of the ASC system as a tool towards responsible
or sustainable aquaculture was and is that the
feed that goes into the aquaculture ponds is still
insuffciently captured by the ASC standards.
Thus, despite the ASC being a tool to drive
aquaculture practices towards sustainability,
there is still a huge door open to negative impact
(indirectly) caused by aquaculture; namely
through the supply of aquaculture feed and feed
ingredients.
The ASC has recently announced the start
of Feed Di al ogues and i nvi ted i nterest
stakehol ders to parti ci pate. In order to
constructively engage major shrimp feed
compani es i n Thai l and, one of the most
important frst steps is to pinpoint, as accurately
as possible, the impact of shrimp feed industry
on the livelihood of coastal communities in
Thailand, as well as map their supply chain in
order to get a clearer picture of shrimp feed
industry business conduct for use in evaluating
potentially fruitful engagement strategies.
RESEARCH
BACKGROUND 1.
14
1.1 Objective of this project
1) To establish and quantify, as much as
possible, the impact of shrimp feed industry
on the livelihood of local fshing communities
in Songkhla;
2) To map the supply chain of shrimp feed
industry in Songkhla, including market
shares and key activities of major stake-
holders in the supply chain; and
3) To spur more awareness and support for the
issue from the general public via an effective
communication plan that will be executed in
conjunction with research.
1.2 Objective of this report
1) Review background documents related to
depletion of coastal resources and livelihood
of local fshing communities in Songkhla as
well as other relevant research papers and
literature;
2) Discuss with Oxfam teams and local NGOs
i nvol ved i n Oxfams ongoi ng program
in Songkhla, as well as others which have
carried out similar works to gain further
understanding of local condition and trend;
3) Establish and quantify, as much as possible,
the impact of shrimp feed industry on the
livelihood of local fishing communities in
Songkhla;
4) Submit a full analysis on the linkage between
shrimp feed industry and livelihood of local
fshermen in Songkhla;
5) Identify key companies involved in both
upstream and downstream of shrimp feed
business in Songkhla, review their business
practices, and identify potentials for more
socially and environmentally responsible
business conducts; and
6) Revi ew envi ronment al l y sust ai nabl e
busi ness practi ces carri ed out i n the
similar context and formulate practical
recommendations for further discussions
with business stakeholders
15
1.3 Methodology and Limitations
of Research
For this research, the research team conducted
feld research on the following issues:
1) Supply chain structure and practices of
fshmeal industry in Songkhla; and
2) Estimate and analysis of catch landed at
Songkhla Ta Sa-aan Port
In addition, the team conducted desk research
and interviews on the following issues:
1) Literature review on the impact of trash
fshing on marine ecosystem in Songkhla;
2) Literature review on the impact of trash
fshing on livelihood of local artisanal fshing
communities in Songkhla;
3) Overview of the fshmeal industry in Thailand
and Songkhla;
4) Existing regulations and standards and
proposed revisions; and
5) Literature review on sustainable fshing in
Peru
The research team found that existing
research on the impact of trash fshing on the
livelihood of local artisanal fshing communities
in Songkhla is very limited. There appears to be
no research on this specifc topic; the closest
we were able to uncover were a few reports on
the impact of push net fsheries in Pattani, and
impact of anchovy fshing using luring light in
Songkhla. The latter includes quantitative data
of incomes of local fshermen during 1993
1999; this data was used to support the sugges-
tion that destructive fshing like anchovy fshing
using luring light had impact on local fshermen.
The use of quantitative data in this research is
rare; most reports simply contain descriptions
of the causes, impact, and adaptations of local
fshermen.
We still cite the aforementioned research
in this report because we believe that, the
aforementioned reservations notwithstanding,
research data shows that local fshermen in
Songkhla were affected from the reduction of
marine resources caused by destructive fshing.
When one consi ders decl i ni ng mari ne
resources, it is diffcult to distinguish the effects
of trawlers and push nets from the effects of
anchovy fshing using luring light. Even if it were
doable, no such data was collected or available
at this point.
Apart f rom l i mi t ed i nf ormat i on and/
or literature available, much of the information
i s al so out dat ed. Bot h pi eces of t he
aforementioned research reports we reviewed
for this report were written in 2000, over 13
years ago. Not only are research reports
outdated, but key data e.g. Marine Fishery
Census, which records income of small-scale
fshing households, is also outdated. For
example, Marine Fishery Census, which was
conducted every 10 years, was discontinued
after the 2000 Intercensal Survey of Marine
Fishery (B.E. 2543). Similarly, the Income of
Small-Scale Fishing Households Survey was
also last conducted in 2000 or B.E. 2543.
16
2.1 Thailands Fisheries from the Past
Commercial fsheries in Thailand can be
traced back to before World War II. Fishing
gears used in the early days were simple, e.g.
hooks, pots, stow nets, set nets, or beach
seines, and most of the fshing boats were
non-powered boats such as sailboats, rowboats
or paddle boats. In 1945, there were only 65
powered boats and 2,513 non-powered boats.
Between 1953 1960, trawlers were introduced
to Thailand, but they were not particularly
successful because fshermen did not know the
characteristics of the sea bottom where they
trawled, and the prices of the demersal
1
fsh
were very low because Thai people at that
time did not know demersal fsh; they preferred
pel agi c
2
fsh l i ke I ndo-Paci fc anchovy
(Department of Fisheries, n.d.).
However, in 1960, the German government
sent experts to train Thai fshermen to use
trawlers; they were very successful. They found
that marine resources in the Gulf of Thailand
were very rich, and that the most effcient gear
to catch demersal fauna was the Otter Board
Trawl (OBT). Almost instantly, trawlers became
very popular. At that time, the Thai Department
of Fisheries (DoF) itself also supported the
use of pair trawlers (PT). They modifed and
converted Chinese purse seiners to function as
trawlers, and trained fshermen in trawl fshing.
The trawl fshery was booming, spurring the
acquisition of more and bigger trawlers. In 1960,
there were only 99 trawlers, but in 1966 the
number had skyrocketed to 2,695, equivalent to
a 2,600% growth rate wi thi n si x years.
Meanwhile, marine production increased by
over 600%, from 63,711 tons in 1960 to 448,554
tons in 1966 (Boonwanich & Boonpakdee,
2009.).
From 1967, Thai trawlers began fshing in
the marine zones of Cambodia, Myanmar,
Vietnam, and Malaysia, increasing Thai
marine production to 1,548,157 tons in 1972;
Thailand became a top ten marine product-
producing country (DoF, n.d.). In 1987, the
marine production topped 2 million tons, of
which 68% was demersal fauna, composed of
41% of demersal fsh, 39% of trash fsh
3
, 9%,
of squids and other miscellaneous organisms,
including shrimps (Kongprom et al., 2007).
It stayed at levels of 2.4 2.8 million tons during
1990 2006, reaching its peak of 2,827,400
tons in 1995. Since then it has gradually
declined (Fishery Information Technology
Center [FITC], 2012).
OVERVIEW OF
FISHMEAL INDUSTRY 2.
1
Demersal fsh are fsh living at/near the seafoor e.g. sea bass, shark, red snapper, ray, grouper, fatfsh, sea catfsh, bream.
2
Pelagic fsh are ocean fsh which live in schools in the upper sea levels e.g. anchovy, mackerel, tuna, sardine, mullet, pomfret.
3
Trash fsh are a term fshermen call small-sized, non-commercial fsh and/or spoiled fsh that cannot be sold for human
consumption. In Songkhla, trash fsh or Pla Kai is a specifc term for assorted small-sized, non-commercial fsh sold to fshmeal
producers. If the same fsh is sold to fsh farms, it will be called bait fsh or Pla Yue. Fish and other marine fauna that have
badly handled, smashed by the trawl net or are putrescent are termed Pla Pet.
17
4
Catch Per Unit Effort (CPUE) is a reference number used to indirectly measure the abundance of the marine resources. It is the
total catch divided by the total amount of effort spent on the catch. Reported CPUE is calculated as weighted number of
CPUEs reported by 85 stations of Marine Fisheries Research and Development Bureau in Gulf of Thailand (64) and Andaman
Sea (21); CPUE is calculated using standard vessels which will trawl for one hour using Otter Board Trawls with 2.5 cm mesh
size during January to June every year (Marine Fisheries Research and Development Bureau, 2012).
5
From interview conducted with Marine Fisheries Research and Development Bureau, 2013.
Figure 1: Marine Production in Thailand from 1950 - 2011
Source: Oceans in the Balance, Thailand in Focus, 2013
3000000
2500000
2000000
1500000
1000000
500000
0
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
t
o
n
s
1
9
5
0
1
9
5
2
1
9
5
4
1
9
5
6
1
9
5
8
1
9
6
0
1
9
6
2
1
9
6
4
1
9
6
6
1
9
6
8
1
9
7
0
1
9
7
2
1
9
7
4
1
9
7
6
1
9
7
8
1
9
8
0
1
9
8
2
1
9
8
4
1
9
8
6
1
9
8
8
1
9
9
0
1
9
9
2
1
9
9
4
1
9
9
6
1
9
9
8
2
0
0
0
2
0
0
2
2
0
0
4
2
0
0
6
2
0
0
8
2
0
1
0
years
Although Thailands marine production
kept growing during the period 1960 1995,
the Catch Per Unit Effort (CPUE)
4
has been
decl i ni ng conti nuousl y si nce 1961 from
almost 300 kgs per hour to 17.8 kgs in 2010
(Boonwanich & Boonpakdee, 2009). This
suggests that marine resources of Thailand
have been declining, and that Thailands fshery
production has been depending on resources
from other countries for a long time. When
Malaysia and Indonesia began imposing new
regulations that disallow foreign boats to fsh in
their maritime zones, Thai fshing boats in those
waters had to be registered as Malaysian and
Indonesian boats. When landing the catches
from these boats, the catches were considered
imported fsh. Thailands marine production,
therefore, sharply dropped to 1,644,800 tons in
2008 (DoF, 2013) while the CPUE did not
change much. Even so, the offcial Fisheries
Statistics of Thailand does not accurately refect
the amount of fsh caught in Thai waters,
because the offcial fgures include fsh caught
in the un-policed EEZs of Cambodia (in the Gulf
of Thailand fgures) and Myanmar and on the
high seas (in Andaman Sea catch fgures)
5
.
18
Figure 2: Catch Per Unit Effort from 1961 2010 (kilograms per hour)
Source: Boonwanich & Boonpakdee, 2009.
Therefore, in order to maintain or increase
the volume of marine production of the country,
Thailand has to search for more abundant
fshi ng grounds, exert more eff ort , use
undiscriminating fshing gears that can catch
almost everything, and/or build more boats.
Fishing Grounds
Thailand covers an area of 514,000 km
2
,
and has two coastl i nes 2,600 km l ong.
The coastline on the Gulf of Thailand (GoT)
side is 1,840 km in length, and that of the
Andaman Sea is 865 km. According to Fishery
and Aquaculture Country Profles of the King-
dom of Thailand (FAO, n.d.), the main fshing
ground for Thai fshing boats is GoT which ac-
counts for 41% of total wild-caught fsh and
seafood. (19% in the Andaman Sea and 40% in
the waters outside Thailands EEZ (Exclusive
Economic Zone) According to the United
Nations Convention on the Law of the Sea
(UNCLOS), EEZ is defned as the area within
200 nautical miles (nm) from baseline. Each
country has the sovereign right to explore,
exploit, conserve, and manage the marine
resources both living and non-living in the
waters superjacent to the sea-bed, sea-bed, and
subsoil within the EEZ. Thailands EEZ covers
an area of 323,488.32
6
km
2
(120,812.12 km2
of the Andaman Sea and 202,676.20 km
2
of
GoT) (Hydrographic Department, Royal Thai
Navy, 2012 cited in Department of Marine and
Coastal Resources, n.d.).
350
300
250
200
150
100
50
0
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
C
P
U
E

(
k
g
.
/
h
r
.
)
2
5
0
4
2
5
1
3
2
5
3
5
2
5
2
2
2
5
4
4
2
5
0
7
2
5
1
6
2
5
3
8
2
5
2
5
2
5
4
8
2
5
1
0
2
5
3
1
2
5
1
9
2
5
4
1
2
5
2
8
2
5
5
1
297.8 kg./hr.
17.8 kg./hr.
6
There are many numbers of Thailands EEZ e.g. 316,000 km2 (FAO), 316,118.3 km2 (Greenpeace Southeast Asia), 420,280
km2 (Khemakorn, 2009), 306,365 (See Around Us Project), but we use the one from Department of Marine and Coastal Re-
sources which cited from Hydrographic Department, Royal Thai Navy.
19
Figure 3: Thailands EEZ map
Source: Hydrographic Department, Royal Thai Navy, 2012 cited in Department of Marine and Coastal Resources, n.d.
:::sa::
Internal Water
-:.aaa.c:
Territorial Sea
.c::a.:a
Contiguous Zone
.c:.-+a...:
Exclusive Economic
Zone
:-e:..
i-a-..a.ra
Malaysia - Thailand
Joint Development Area
Explanation of Map Symbols
ca.a::--:.a.a:ca:
Basic Marine and Coastal Information
aa.c:--:.aca::.--i-a
Maritime Zone of Thailand
:.:..e
Province Location
a:: Road
Waterway
aa.c:..e
Province Boundary
20
Apart from EEZ, UNCLOS also defned
shelf area
7
that each country can claim its
rights. In 1971, Vietnam imposed law on its shelf
area, and so did Cambodia in 1972. To protect
its rights, Thailand claimed its shelf area in
1973. The claims over shelf areas of the three
countries created the overlapping areas that
cause disputes between the three nations. The
overlapping areas are as follows:
1. Thailand Cambodia 8,733 nm
2
2. Thailand Vietnam 3,903 nm
2
3. Cambodia Vietnam 18,311 nm
2
After both Vietnam and Cambodia laid
claims over shelf areas, they claimed on EEZ
which directly affected Thai fshery industry as
it lost around 300,000 nm
2
of high seas that Thai
fshing boats used to fsh, making fshing boats
smaller than 22 meters to return to Thai waters
and compete with the same size or smaller
fshing boats fshing there trying to catch as
much as possible. Middle-sized boats, on the
other hand, bought concessions to fsh at the
same areas or operate illegally while large boats
went even further to fsh in the high seas that
were not claimed.
Those small fshing boats including trawlers
that returned to fsh in Thai waters worsened
the overcapacity problems in GoT, and had
conficts with other small fshing boats that
already were fshing in these areas. Thus, later
on, Ministry of Agriculture and Cooperatives
(MOAC) enacted regul ati ons concerni ng
trawlers, trawl fshing, push nets, and push net
fshi ng, e.g. Mi ni stry of Agri cul ture and
Cooperatives decree on forbidden zones to use
trawlers and push nets B.E. 2515 (1972),
regulation on the practice of reducing trawlers
and push nets B.E. 2523 (1980), and regulation
on the control of trawlers and push nets B.E.
2539 (1996).
2.2 Why trawlers and push nets are
banned
The Mi ni st r y of Agr i cul t ur e and
Cooperatives (MOAC) latest regulation on
trawlers and push nets, issued in B.E. 2539
(1996), stipulates that the Thai government
will no longer grant licenses to new trawlers;
only those who already own the licenses can
apply for license renewal. As a result, the
number of registered trawlers and push nets
has been declining. For example, in 1989,
there were 13,113 trawlers, but in 2011,
t he number was 3, 466 (Boonwani ch &
Boonpakdee, 2009; FITC, 2013). The reasons
MOAC enact ed t hese regul at i ons were
because they realized that marine resources
were exploited faster than the reproductive
ability of nature, which could lead to depletion
of the resources which would eventually affect
the economy. Also, there were too many fshing
boats, particularly trawlers and push nets, and
trawlers and push nets are destructive fshing
gears that catch everything indiscriminately
(Boonwanich & Boonpakdee, 2009).
Trawlers and push nets catch fsh and
other marine fauna living at or near the seafoor.
They sweep everything including juveniles of
commercial fsh into the cod-end as well as
destroy coral reefs, spawn grounds and habitats
of fsh when they drag pass, making the sea-bed
smooth, plain, muddy seafoor (Plathong, 2012).
There are three types of trawls: 1) otter board
trawl (most popular), 2) pair trawl, and 3) beam
trawl. In 2011, of 17,203 registered fshing
boats, 20.1% or 3,466 were trawlers. Of the
total number of the trawlers, 65.1% (2,256) were
registered as otter board trawlers, 31.5%
(1,092) were pair trawlers, and 3.4% (118) were
beam trawlers. Although trawlers account for
only 20.1% of the total number of fshing boats,
capture by trawlers comprised 773,317 tons, or
48% of the wild-caught marine production total
of 1,610,418.
7
Shelf area is the area of the seafoor that naturally extends from the land until it merges with the continental margin or within
200 nm from the baseline.
21
Figure 4: Number of fshing boats by type, 2011
Figure 5: Volume of wild-caught marine production by type of fshing gears, 2010 (tons, % of total)
Source: Fishery Information Technology Center, 2013
Source: Fishery Information Technology Center, 2012
trawlers
purse seine
gill nets and entangling nets
falling nets
lift nets
push nets
other nets
hook & lines
miscellaneouse
3,719,22%
3,466, 20%
32, 0%
32, 0%
1,498, 9%
7,825, 45%
274, 2%
375, 2%
11, 0%
trawlers
purse seine
gill nets and entangling nets
falling nets
lift nets
push nets
other nets
hook & lines
miscellaneouse
773,317, 48%
533,016, 33%
77, 849, 5%
22,682, 1%
60,384, 4%
3,352, 0%
16,596, 1% 123,222, 8%
The composition of fsh caught by trawlers reveals why they are considered destructive fshing
gears. Kongprom et al. (2007) reported that of the total fsh and seafood caught by trawlers small
otter board trawls, medium otter board trawls and pair trawls, 36.08% - 71.94% were trash fsh,
of which between 15.18% - 54.57% were juveniles of commercial fsh. If these juveniles had not
been caught and allowed to grow, they would have much higher economic values both as larger
fsh and as a source of replenishment of the exploitable stock when they recruited to the spawning
population.
22
2.3 Characteristics of Fishmeal
Fishmeal is brown powder made from
cooking, drying, and squeezing trash fsh
8
and/
or trimmings of fsh (Nordahl, 2011). Raw
materials used to produce fshmeal include
whole fsh and trimmings (i.e. trimmings) from
fsh production such as fsh heads, bones, etc.
According to C.J. Shepherd and A.J. Jackson
(2012) from International Fishmeal and Fish Oil
Organisation (IFFO), the global norm for
fshmeal is that 75% of raw materials comprise
whole fsh (including trash fsh in international
parlance, i.e. undesirable or unpalatable fsh),
and t he remai ni ng 25% are t ri mmi ngs.
However, according to the Thai Fishmeal
Producers Associ ati on (TFPA), fshmeal
produced in Thailand is made from 65%
tri mmi ngs and 35% trash fsh (Personal
communication, August 13, 2013).
Yet another set of fgures is cited by the
animal feed industry. According to Thai Feed
Mill Association, raw materials of fshmeal
come from 35% trimmings from canned fsh
manufacturers, 18% trash fsh, 15% sardinellas
and other fsh, 20% trimmings from Surimi
producers, 2% trash fsh from overseas waters,
and the remaining 10% are trimmings from
other fsh processing manufacturers (Fishmeal,
2011).
The species of whole fsh used in fshmeal
production vary from region to region. For
example, in South America, the main species
are anchovy and Northern Europe blue whiting
while in Thailand, various species are used to
produce fshmeal.
Based on Bureau of Agricultural Economics Research, species of fsh caught depend on the
fshing gears fshermen used. If the fshermen use gillnets or purse seines, fsh caught will be
pelagic fsh only such as Sardinellas. But if they use trawlers otter board trawl, pair trawl or bottom
trawl or push nets, most of the fsh caught will be demersal fsh which consist of various kinds of
species usually referred to as Pla Benchapan (literally means fve kinds of fsh) or trash fsh. Figure
7 show the species of fsh usually found in trash fsh.
8
Trash fsh is an all-encompassing term used to describe low economic-value fsh, usually small species that are not preferred
by consumers. They are bycatch from non-selective fsheries; in some countries, trash fsh will be discarded while in many
countries they are used for 1) making fshmeal for animal feed, 2) direct animal feed, and 3) human consumption. In Thailand,
trash fsh or Pla Ped/Pla Kai is usually referred to small size fsh (both true trash fsh which is still small when maturing e.g.
sardinella and juveniles of high economic value fsh) and damaged fsh, which are used to produce fshmeal.
Figure 6: Main species and share of global output and export
Country/Region
of production
Main species used in production
Global production
share 2007
Global export
share 2007
Peru Anchove 25% 41%
Chile Jack Mackerel, Anchovy, Sardines 13% 16%
China Various 19% 0%
Thailand Various 8% 3%
USA Menhaden, Alaske pollock 5% 3%
Iceland Blue-whiting, Herring, trimmings 2% 4%
Norway Blue-whiting, Capelin, trimmings 3% 1%
Denmark Sandeel, Sprat, Blue-whiting, Herring 3% 5%
Japan Sadine, Pilchard 4% 0%
Total 81% 73%
Source: FAO Fishstat 2009 cited in Nordahl, 2011
23

Figure 7: Species of fsh usually found in trash fsh

24
Source: Thai Fishmeal Producers Association, 2013
Figure 7 (continued)
25
Production Seasons
Peru the worlds major fshmeal producer
and exporter has two fshing seasons. The
frst Peruvian fshing season starts from May
to July, and the second season runs from
November until January (IFFO, 2009). The
fshing seasons in each region of Thailand are
as follows:
1. Southeast region (Andaman Sea):
November April
2. Southwest region (Gulf of Thailand):
May October
3. East region (Gulf of Thailand):
September April (Bureau of
Agricultural Economics Research, 2012)
In Thailand, fshmeal production season
is principally in the non-Monsoon period from
April July; the fshmeal producers receive a
lot of raw materials during this period. The
composition of product that is diverted to
fshmeal production changes during the year,
with a larger proportion of juveniles and true
trash fsh after the recruitment pulses that
coincide with monsoon seasons.
Figure 8: Production process of fshmeal and fsh oil
Pelagic fsh
(globally 75% of input)
Trimmings
(globally 25% of input)
Step 1
Cooked at 95
o
C
Step 2
Squeezed
Crude fshoil
Fishoil yield
2.5 - 4.5%
Step 3
Flame Dried
(low quality fshmeal)
Steam Dried
(high quality fshmeal)
Fishoil yield
22 - 24%
Fishmeal Production Process
Fishmeal production process in Peru is
different from the process practiced in Thailand.
In Thailand, the producers do not separate fsh
oil from fshmeal, so the fshmeal contains a lot
of fat resulting in a short shelf life. The fshmeal
and fsh oil production process in Peru as shown
in fgure 8 is divided into three steps: 1) cook 2)
squeeze, and 3) dry. The frst step is to check,
clean, and cook the fsh at around 95 degree
Celcius. The second step is to squeeze the
liquid out of the cooked fsh, and the third step
is to dry the fsh (Nordahl, 2011). The oil is
extracted between stages 2 and 3.
In Thailand, there are two types of fshmeal
production process: 1) squeezing and 2) drying.
The squeezing system is the traditional process
that causes water pollution. This system can be
described in four steps: 1) cook 2) squeeze 3)
dry and 4) grind. Fishmeal produced by the
system has low protein and fat because some
of protein and fat are lost during the squeezing
step. The drying system consists of four steps:
1) chop 2) cook 3) dry and 4) grind. Fishmeal
produced by this system will contain 58-65%
protein, but it has a short shelf life (Bureau of
Agricultural Economics Research, 2012).
Source: Nordahl, 2011
26
From IFFO estimates, outputs from the Peruvian production process include 4.79% fsh oil,
22.5% fshmeal, and 72.8% water steam (Shepherd and Jackson, 2012). According to IFFO
9
,
composition of fshmeal includes 60-72% of protein, 10-20% of ash, 5-12% of fat as well as the
fatty acids EPA and DHA or omega-3. This breakdown is similar to the Study of Economic
production and Market of Fishmeal under the Quality Assurance System that states that fshmeal
contains protein, ash, salt, humidity, and remains (Kak). According to Ministry of Agriculture and
Cooperatives of Thailand, fshmeal is graded by its composition as shown in Figure 9.
Figure 9: Composition of 1
st
, 2
nd
, and 3
rd
grade fshmeal
Fishmeal 1
st
Grade 2
nd
Grade 3
rd
Grade
Protein (not less than) 60% 55% 50%
Ash (not more than) 26% 28% 30%
Salt (not more than) 3% 3% 3%
Humidity (not more than) 10% 10% 10%
Remaining (not less than) 2% 2% 2%
Source: Bureau of Agricultural Economics Research, Ministry of Agriculture and Cooperatives of Thailand, 2012
9
cited in Is the Aquaculture Industry Caught in a Fishmeal Trap? by Per Gunnar Nor (2011)
2.4 Overview of Fishmeal Industry
2.4.1 Global
Fishmeal is a main protein ingredient for
animal feed, especially for fsh and shrimp feed.
The global production of fshmeal in 2012 was
4.73 mi l l i on tons (Bureau of Agri cul tural
Economics Research, 2012); however, the trend
is declining because of the El Nio that causes
the reduction of fsh stock which is the raw
material of fshmeal. Also, Peru a major
fshmeal producer and exporter introduced a
fshing quota. It produced 1.34 million tons of
high quality fshmeal with 65%+ protein in 2009
while Chile the second largest producer
produced 0.65 million tons in the same year.
The two countries accounted for 41.63% of the
total fshmeal producti on, so when they
introduced fshing quotas, it affected the global
supply of fshmeal and resulted in increasing
prices. Other major fshmeal producers include
Thailand, USA, Japan and Denmark.
Even though globally there is high demand
for aqua-cultured animals, the trend of fshmeal
consumption is declining because of the
growing prices of fshmeal (Fishmeal, 2013).
The major consumers are China who in 2004
used 1.528 million ton, Japan 0.703, Chile
0.467, Thailand 0.409, and Norway 0.309.
China is also the biggest importer of fshmeal.
In 2009, China alone imported about 1.31 million
tons while Peru exported about 1.583 million
tons of fshmeal (Seafsh, 2011).
27
Figure 10: Worlds fshmeal production, 1988 - 2009
Worlds Fishmeal Production 1988 - 2009
1
9
8
8
1
9
8
9
1
9
9
0
1
9
9
1

1
9
9
2
1
9
9
3

1
9
9
4
1
9
9
5
1
9
9
6
1
9
9
7
1
9
9
8
1
9
9
9
2
0
0
0
2
0
0
1
2
0
0
2
2
0
0
3
2
0
0
4
2
0
0
5
2
0
0
6
2
0
0
7
2
0
0
8
2
0
0
9
8000000
7000000
6000000
5000000
4000000
3000000
2000000
1000000
0
t
o
n
s
years
Worlds Fishmeal Production /
Source: IFFO, 2010 cited in Seafsh, 2011
Figure 11: Top six fshmeal producing countries (thousand tons)
Country 2001 2002 2003 2004 2005 2006 2007 2008 2009
Total 5,997.4 6,201.7 5,401.6 6,274.5 6,022.7 5,230 5,052.8 5,006.8 4,775.2
Peru 1,844 1,941 1,251 1,982.7 2,019.9 1,378 1,407 1,430.3 1,346.9
Chile 699 839 664 933.1 870.4 854.7 781.9 729.7 641
Thailand 381 387 397 403 473.4 461.2 428 468 381.2
USA 342 337 318 353 268.8 232 251 216.2 249
Japan 227 225 230 295 221.9 219.6 210 202.9 192
Denmark 299 311 246 259.2 213.1 209.4 166 161.3 180.9
Source: IFFO, 2010 cited in Seafsh, 2011. No revision has been made to the fgures.
Figure 12: Top six fshmeal consuming countries (thousand tons)
Country 1996 1997 1998 1999 2000 2001 2002 2003 2004
China 1,240 1,516 1,113 1,366 2,030 1,682 1,406 1,183 1,528
Japan 802 792 699 744 710 691 687 596 703
Chile 293 261 149 351 270 222 351 36 467
Thailand 566 466 418 481 504 484 408 405 409
Norway 232 320 247 223 361 276 246 289 309
Taiwan 308 315 303 254 253 250
Source: IFFO, 2005 cited in Seafsh, 2011. No revision has been made. Figure of Chile in 2003 is believed to be a typo.
28
Figure 13: Top six fshmeal exporting countries (thousand tons)
Country 2001 2002 2003 2004 2005 2006 2007 2008 2009
Peru 1,937 1,520 1,372 1,751 2,000 1,338 1,219 1,561 1,583
Chile 491 497 576 494 709 470 474 478 609
Denmark 307 305 203 247 254 253 161 210 240
Iceland 190 125 126 158 104
Mexico 19 9 12 51 39 83 94
Morocco 27 20 35 34 55 48 33 70 92
Source: IFFO, 2010 cited in Seafsh, 2011. No revision has been made.
Figure 14: Top six fshmeal importing countries (thousand tons)
Country 2001 2002 2003 2004 2005 2006 2007 2008 2009
China &
Hong Kong
984 976 797 1,147 1,598 980 986 1,352 1,310
Norway 143 127 150 162 202 211 220 242 328
Japan 478 480 388 402 376 412 350 309 281
Taiwan 295 242 239 238 234 213 152 150 180
Vietnam 29 20 60 61 96 83 104 114 115
UK 233 192 184 143 138 143 91 92 114
Source: IFFO, 2010 cited in Seafsh, 2011. No revision has been made.
2.4.2 Thailand Fishmeal Production
Thai l and s fshmeal product i on was
estimated to be around 0.43 0.50 million tons
during 2008 2013. These numbers are
esti mated numbers from Thai Fi shmeal
Producers Association (TFPA) since Thailand
does not have any report or record of actual
fshmeal production. These statistics are also
different from those from Fishery Statistics
Analysis and Research Group (FSARG) at
Department of Fisheries (DoF), which are quite
low compared to TFPAs fgures: FSRAG
estimated annual fshmeal production at 0.33
0.35 million tons between 2007 2011.
According to interviews with both organizations,
we found that they use different methods to
estimate annual production, and these different
methods lead to different fgures. TFPA has local
committees in each province estimate their
monthly fshmeal productions, while FSARG has
fshmeal producers in each province report their
productions to DoFs provincial offce.
29
Figure 15: Thailands fshmeal production by year, 2006-2011
Thailands Fishmeal Productions 2006 - 2011
600000
500000
400000
300000
200000
100000
0
2006 2007 2008 2009 2010 2011
P
r
o
d
u
c
t
i
o
n

(
t
o
n
s
)
TFPA
DoF
Source: Thai Fishmeal Producers Association (TFPA), 2013; Fishery Statistics Analysis and Research Group (DoF), 2013
From Figure 15, the production of fshmeal in recent years is quite stable. Despite the
increasing demands for animal feed, declining fsh stock in Thai waters meant that production fell
behind demand, even compensated by trimmings from fsh processing manufacturers (Fishmeal,
2010a) Apart from declining supplies of raw materials, decreasing production capacity the number
of fshmeal producers, also affects the total fshmeal production, as shown in Figure 16.
Figure 16: Thailands fshmeal production and producers, 1987 - 2011
Thailands fshmeal productions and producers
1
9
8
7
1
9
8
8
1
9
8
9
1
9
9
0
1
9
9
1

1
9
9
2
1
9
9
3

1
9
9
4
1
9
9
5
1
9
9
6
1
9
9
7
1
9
9
8
1
9
9
9
2
0
0
0
2
0
0
1
2
0
0
2
2
0
0
3
2
0
0
4
2
0
0
5
2
0
0
6
2
0
0
7
2
0
0
8
2
0
0
9
2
0
1
0
2
0
1
1
500,000
450,000
400,000
350,000
300,000
250,000
200,000
150,000
130
120
110
100
90
80
70
60
N
u
m
b
e
r

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
r
s
Number of fshmeal producers Fishmeal productions (tons)
F
i
s
h
m
e
a
l

p
r
o
d
u
c
t
i
o
n
s

(
t
o
n
s
)
Years
Source: Fishery Statistics Analysis and Research Group (FSARG), DoF, 2013
According to the Thai Fishmeal Producers Association (TFPA), there are 64 fshmeal producers
registered as members of the association. The total production of these producers combined
accounts for approximately 80% of national production (Personal communication
10
, August 13,
2013). Fishmeal industry consists of many medium and small players who try to work together to
negotiate fshmeal prices. The industry landscape is unlike animal feed industry in that there is no
dominant producer; most members of the association are similar in size, and no company is as large
or as powerful as any of the major animal feed mills. Because of this, and because animal feed mills
10
Interview with Khun Sanguansak Akaravarinechai, President and Khun Nichkamol Kumaree, Manager on August 7, 2013;
email from TFPA on August 13, 2013.
30
are the main purchaser of fshmeal and mandate quality, animal feed mills therefore have vast
bargaining power to set fshmeal prices (Bureau of Agricultural Economics Research, 2009).
In Thailand, the largest fshmeal producing province is Samutsakorn; in 2011, it produced 138,420
tons or 27.51% of total production according to TFPA, and 115,668 tons or 35.3% according
to Department of Fisheries (DoF). Production in other provinces differs according to the various
estimates used by TFPA and DoF (Figure 17).
Figure 17: Thailands top fve fshmeal producing provinces in 2011
Rank TFPA DoF
1 Samutsakorn, 138,420 tons or 27.51% Samutsakorn, 115,668 tons or 35.3%
2 Nakorn Sithammarat, 66,490 tons or 13.21% Songkhla, 39,402 tons or 12.03%
3 Songkhla, 56,960 tons or 11.32% Ranong, 31,640 tons or 9.66%
4 Pattani, 42,459 tons or 8.41% Phuket, 25,127 tons or 7.67%
5 Trang, 37,840 tons or 7.52% Pattani, 24,243 tons or 7.4%
Source: Thai Fishmeal Producers Association, 2013; Fishery Statistics Analysis and Research Group (DoF), 2013
Figure 18: Raw materials of fshmeal, 1987 - 2011
Raw materials of fshmeal
1
9
8
7
1
9
8
8
1
9
8
9
1
9
9
0
1
9
9
1

1
9
9
2
1
9
9
3

1
9
9
4
1
9
9
5
1
9
9
6
1
9
9
7
1
9
9
8
1
9
9
9
2
0
0
0
2
0
0
1
2
0
0
2
2
0
0
3
2
0
0
4
2
0
0
5
2
0
0
6
2
0
0
7
2
0
0
8
2
0
0
9
2
0
1
0
2
0
1
1
2,000,000.00
1,500,000.00
1,000,000.00
500,000.00
-
Years
other fsh trash fsh trimmings
T
o
n
s
Source: Fishery Statistics Analysis and Research Group (DoF), 2013
As mentioned in an earlier section, raw
materials of fshmeal produced in Thailand
consist of whole fsh and trimmings. According
to TFPA, in 2012, fshmeal raw materials
comprised 30% trimmings from fshing canning
manufacturers, 25% trimmings from Surimi
producers, 10% trimmings from fsh processing
manufacturers 10%, and the remaining 35% are
whole fsh (interview with TFPA, August 13,
2013). This is similar to data reported by FSARG
indicating that in 2011, fshmeal raw materials
consisted of 39% whole fsh (comprising 28%
trash fsh labeled in the report as pla pet, and
11% t rue t rash fsh meani ng not -yet -
decomposed fsh that are used as fshmeal
raw materials, i.e. in line with international
standards and juveniles) and 61% trimmings.
From the past until 1996, raw materials of
fshmeal were whole fsh (trash fsh, true trash
fsh, and juveniles). But beginning in 1997,
trimmings have played a more important role as
main raw material for fshmeal, while the
percentage and amount of whole fsh have been
declining continuously as shown in Figure 18.
31
2.4.3 Thailand Fishmeal Consumption
Si nce i t i s not requi red for fshmeal
producers in Thailand to report the amount of
fshmeal they produce, we obtained estimated
fgures of fshmeal production with some details
on provincial data from TFPA and DoF. Fishmeal
consumption fgures are far more obscure and
inconsistent than production fgures.
Accordi ng t o Bureau of Agri cul t ural
Economic Research (2012), Thailand in 2012
consumed around 0.45 0.48 million tons of
fshmeal, mainly for aquaculture especially for
Whiteleg shrimps. This is similar to fgures in
Animal Feed Business magazine volume 135,
November December 2010 that showed that
fshmeal consumptions during 2006 2010
were around 0.42 0.52 million tons (Fishmeal,
2010a). Nevertheless, they were conficted
with fgures shown in Animal Feed Business
magazine volume 134, September October
2010 that said the increasing livestock
populations increase the demand for fshmeal
as follow ... in 2009 total demands are 0.556
million tons, and in 2010 total demands are
0.578 million tons (Fishmeal, 2010b, p. 27).
These numbers were derived from tables of
livestock populations, amount of animal feed,
and amount of raw material in 2009 and 2010
published on Thai Feed Mill Association website
(www.thaifeed mill.com).
Once agai n, t he above fgures are
estimated, and we found that the fgures do
not refect the actual demands for fshmeal.
For example, based on an interview with TFPA
and an offcial of DoF, fshmeal is no longer used
to produce animal feed for chicken, and it is
used very little in feed for pigs only for pig
breeding stock. However, in the TFPA-published
table of livestock populations, the amount of
animal feed, and amount of raw material in
2013, demands of fshmeal for all types of
chicken still account for a high proportion
almost 50% of the total estimated demands.
This is because fgures for such published table
are still calculated theoretically from the amount
of livestock, as opposed to using actual fgures.
Si mi l ar t o fshmeal product i on and
consumption fgures, there is no public data on
the amount or percentage of fshmeal used by
major animal feed producers; nonetheless,
based on an interview with Thai Fishmeal
Pr oducer s Associ at i on ( TFPA) , TFPA
represent at i ve est i mat ed t hat Charoen
Phokphand Foods (CPF) is the largest fshmeal
buyer in Thailand; the company is thought to
purchase approximately 40-50% of fshmeal
produced domestically every year. Major
fshmeal buyers i ncl ude CPF, Krungthai
Feedmill, Thaiunion Feedmill, and Lee Pattana.
Based on their reported fnancials in 2012, CPF
was ranked the frst with 56,471 million Baht
revenues, followed by Krungthai Feedmill at
5,294 million Baht, Thaiunion Feedmill 4,951
million Baht, and Lee Pattana 4,071 million
Baht. In 2010, CPF was the worlds largest
animal feed producer, with annual production of
approximately 23.2 million metric tons.
2.4.4 Thailand Fishmeal Exports
Unl i ke producti on and consumpti on,
imports and exports of fshmeal are subject to
customs process, so we then have offcial
records of imported and exported fshmeal, but
again we found the conficts between numbers
published by the Offce of Commodity Standards
(OCS), Department of Foreign Trade (DFT),
Ministry of Commerce (MOC) and the Customs
Department (CD), Ministry of Finance.
OCS publishes data of exported fshmeal
dividing it into three grades: 1st grade, 2nd
grade, and 3rd grade; while CD categorizes data
according to Harmonized System Codes (HS
Code), and fshmeal i s di vi ded i nto four
categories: fshmeal with >60% protein content,
fshmeal with <60% protein content, meals of
crustaceans, molluscs, and other aquatic
invertebrates; and others.
32
Looking at Figure 19, we see although the
numbers are different, particularly in 2010 and
2011, the trends are very similar; actually in
2012 and 2013 their fgures are very close
54,534,47 (CD), 58,365.61 (OCS) in 2012, and
110,848.54 (CD), 109,213.09 (OCS) in 2013.
Compared to the fgures in 2012, fshmeal
export doubled in 2013. This is probably
because in 2013 Thailands shrimp industry
faced Early Mortality Syndrome (EMS) problem,
causing shrimp production to reduce by half to
0.25 million tons (Shrimp Export Shrinks, 2013).
This led to the decline of shrimp feed demands
followed by the reduction of the domestic
demands for fshmeal; therefore, fshmeal
producers had to sell their stocks to export
markets. Accordingly, if Thailands shrimp
industry faces the same problem in 2014,
fshmeal producers will probably have to rely on
export again.
Thai l ands maj or export markets for
fshmeal include Vietnam, China, Taiwan, and
Indonesia. According to OCS and CD, in 2013,
Thailand exported around 42,000 tons of
fshmeal to Vietnam and around 24,000 tons to
Figure 19: Thailands fshmeal export by year, 2008-2013*
Fishmeal Export, 2008 -2013
120,000.00
100,000.00
80,000.00
60,000.00
40,000.00
20,000.00
-
2008 2009 2010 2011 2012 2013
T
o
n
s
Customs Department Offce of Commodity Standards
Years
Source: Offce of Commodity Standards, Department of Foreign Trade, 2013; the Customs Department, 2013
Note:* Number in 2013 of OCS is from Jan. Oct. while that of CD is from Jan. Nov. For OCS, we use data of all
three grades of fshmeal, and for CD, we use two categories of fshmeal: fshmeal with >60% protein content (HS
CODE 2301.20.20), and fshmeal with <60% protein content (HS CODE 2301.20.10)
China accounting about 38% and 22% of total
exported fshmeal. Vietnam has a growing feed
industry with annual growth rate of 15-17%.
This high growth is due to the fact that local
ingredients were not enough to supply local
feed production demand, so they had to import
about 60-70% of the ingredients. 90-95% of
dried soybean cakes and fshmeal are imported
(Hoang Anh, 2012). As for China, in 2011, it beat
the USA and became the worlds largest feed
producer with 175 million metric tons of feed
production, and kept increasing in 2012 to 191
million metric tons. Despite the growing feed
production, Chinas local supply of fshmeal is
still low, making it necessary for China to import
fshmeal to fll the fshmeal demand-supply gap.
In 2012, it was estimated that China imported
about 1.2 million ton of fshmeal (USDA, 2012).
Consi deri ng the qual i ty of exported
fshmeal, based on export data from both OCS
and CD, Thailand mainly exports 1st grade
fshmeal, defned as fshmeal with >60% protein
content, as shown in Figure 20 and 21.
33
Figure 20: Thailands fshmeal export by category, 2007 2013*
Fishmeal with <60% protein content Fishmeal with >60% protein content
Fishmeal Export, 2007 -2013*
Years
120,000.00
100,000.00
80,000.00
60,000.00
40,000.00
20,000.00
-
2007 2008 2009 2010 2011 2012 2013
T
o
n
s
Source: The Customs Department, 2013
* From Jan. Nov. 2013
Figure 21: Thailands fshmeal export by category, 2008 2013*
Years
3rd grade Fishmeal 2nd grade Fishmeal 1st grade Fishmeal
Fishmeal Export, 2008 -2013*
120,000.00
100,000.00
80,000.00
60,000.00
40,000.00
20,000.00
-
2008 2009 2010 2011 2012 2013
T
o
n
s
Source: Offce of Commodity Standards, DFT, MOC, 2013
* From Jan. Oct. 2013
2.4.5 Thailand Fishmeal Imports
Since Thailand can produce only 25% of high protein (60%+) fshmeal, it has to import high-
protein fshmeal from other countries (Animal Feed Business, 2011) According to CD records, in
2013 Thailand imported around 6,092 tons of fshmeal mainly from Myanmar (45.87%) and Vietnam
(36.68%). However and again, we found the conficts of fshmeal import fgures even from the same
source. For example, in Animal Feed Business magazine volume 134, September October 2010,
it says that in 2008 Thailand imported 12,968 tons of fshmeal, in 2009 the number increased to
16,755 tons, and in the frst half of 2010, Thailand imported about 7,220 tons of fshmeal (Fishmeal,
34
2010b). However, these fgures confict with
those in the next issue volume 135, November
December 2010 that says in 2010 Thailand
imported only around 1,000 tons of fshmeal
reducing from 2,000 tons in 2009 (Fishmeal,
2010a). The fgures i n the vol ume 135,
however, match the fgures we get from the
Customs Department.
2.4.6 Songkhla Fishmeal
Currently fshmeal industry in Songkhla
consists of 9 fshmeal producers, according to
The Thai Fishmeal Producers Association,
declining from 18 producers listed on the
website of Department of Internal Trade (www.
dit.go.th) as of 2010. Based on their revenues
in 2012, the top fve fshmeal producers in
Songkhla were 1) Jana Fish Industries with
28.6% share of total revenues 2) Paesae
Songkhla 16.1% 3) Pacifc Fishmeal Industrial
14.7% 4) Samila Fishmeal 11.8%, and 5) Thai
Charoen feed mill 10.4%.
According to TFPA, in 2013, Songkhla
produced around 41,000 tons of fshmeal,
equivalent to about 8.2% of total production of
the country. This makes Songkhla the second
largest fshmeal producer in the Southern region
and fourth largest nationally, after Samutsakorn,
Samutprakarn and Nakhon Si Thammarat.
Based on dat a f rom DoF, most raw
mat eri al s used t o produce fshmeal i n
Songkhla are trimmings (by-product) as shown
in Figure 22. In 2011, 94.95% of total raw
materials or 134,986 tons were trimmings while
only 5.05% or 7,178 tons were whole fsh (of
which 5,428 tons were trash fsh). However,
please note that of the fgure for trash fsh here
was of those going to fshmeal producers at
Songkhla, not trash fsh landed at Songkhla.
Based on interviews with DoF offcials, TFPA
representatives, and fshmeal producers peo-
ple, we found that fshmeal producers source
their raw materials across provinces.
Figure 22: Raw materials of fshmeal in Songkhla, 1999 2011, divided into trash fsh,
trimmings (by-product) and other fsh
Raw materials of fshmeal in Songkhla, 1999 - 2011
180,000
160,000
140,000
120,000
100,000
80,000
60,000
40,000
20,000
0
Years
Other fsh Trash fsh Byproduct
T
o
n
s
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
Source: Fishery Statistics Analysis and Research Group (FSARG), DoF, 2013
For the prices in 2011, the average 1st grade fshmeal with 60%+ protein at Songkhla was
30.43 Baht per kilogram (Offce of Internal Trade Songkhla, 2013) or 0.30 and 6.21 Baht lower when
compared with 30.73 Baht of the national average price, and 36.64 Baht of Peruvian F.O.B. price.
35
In 2011, the average trash fsh price at Songkhla was 4.33 Baht per kilogram, 4.27 Baht lower
than the national average price of 8.60 Baht (Offce of Agricultural Economics, 2012). When we look
at the average prices of fshmeal by province in 2011, the price of fshmeal at Songkhla was among
the cheapest prices, ranking number 3 from the bottom. This refects the relatively poor quality of
fshmeal produced in Songkhla, which depends largely on the quality of raw materials.
Figure 23: Average prices of fshmeal by province in 2011 (Baht per kilogram)
P
u
k
e
t
Province
n Average price of fshmeal sold at the province
R
a
y
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S
a
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h
a
b
u
r
i
S
a
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t

P
r
a
k
a
n
C
h
o
n

B
u
r
i
S
a
m
u
t

S
o
n
g
k
h
r
a
m
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r
a
c
h
u
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b

K
h
i
r
i

K
h
a
n
T
r
a
t
T
r
a
n
g
S
a
t
u
n
N
a
k
h
o
n

S
i

T
h
a
m
m
a
r
a
t
45.00
40.00
35.00
30.00
25.00
20.00
15.00
10.00
5.00
0.00
B
a
h
t
Average price of fshmeal by province, 2011
Source: Fishery Statistics Analysis and Research Group (FSARG), DoF, 2013.
(Note: Fishmeal prices of all grades are the same throughout the country, but differences in the average prices here
refect different grades of fshmeal sold at the provinces.)
For details of estimated market shares in
Songkhla of animal feed mills, and estimates of
quantities of fshmeal produced in Songkhla,
see Chapter 7 of this report.
2.5 Fishmeal Price
Fishmeal price has been trending upwards
due to high demand of fshmeal for aquaculture
feed, especially from China, and low supply for
the major fshmeal producers due to disruptions
caused by El Nio phenomenon and decreasing
marine resources (Globefsh, 2009-2013;
Mavromichalis, 2013). As shown in Figure 19,
the price started climbing since 2009 as
fshmeal production decreased in conjunction
with high demand for fshmeal and expected
El Nio. Subsequently, one of major fshmeal
pr oducer s Chi l e was damaged by
earthquake in 2010, coupled with low stock in
China, so the price climbed back up. However,
when the price became very high, buyers were
hesitant to buy and turned to substitute products
that also have high protein content, such as
soybean i nstead. Furthermore, fshmeal
production decreased in the second half of
2011, and this resulted in price drop. In 2012,
demand for animal feed from aquaculture and
livestock industries were positive again, while
low catches and low fshmeal production were
reported, so the price went up and remained
high during the frst two months of 2013.
(Globefsh, 2009-2013)
36
Figure 24: Peruvian fshmeal price from 1980 2013 (US$ per ton)
2,500
2,000
1,500
1,000
500
0
1
/
1
/
1
9
8
0
1
/
7
/
1
9
8
1
1
/
1
/
1
9
8
3
1
/
7
/
1
9
8
4
1
/
1
/
1
9
8
6
1
/
7
/
1
9
8
7
1
/
1
/
1
9
8
9
1
/
7
/
1
9
9
0
1
/
1
/
1
9
9
2
1
/
7
/
1
9
9
3

1
/
1
/
1
9
9
5
1
/
7
/
1
9
9
6
1
/
1
/
1
9
9
8
1
/
7
/
1
9
9
9
1
/
1
/
2
0
0
1
1
/
7
/
2
0
0
2
1
/
1
/
2
0
0
4
1
/
7
/
2
0
0
5
1
/
1
/
2
0
0
7
1
/
7
/
2
0
0
8
1
/
1
/
2
0
1
0
1
/
7
/
2
0
1
1
1
/
1
/
2
0
1
3
Source: International Monetary Fund (IMF), 2013
Figure 25: Prices of trash fsh, 1
st
and 2
nd
grade fshmeal, and Peruvian fshmeal,
2007-2011 (Baht per kilogram)
50
45
40
35
30
25
20
15
10
5
0
Price of assorted trash fsh
Second grade fshmeal with
<60% protein
First grade fshmeal with
>60% protein
FOB price of Peruvian fsh-
meal
Source: Bureau of Agricultural Economic, 2012; Fishmeal, 2010
Figure 25 showed that fshmeal prices in
Thailand increased signifcantly in 2008, then
has held steady thereafter. In practice, prices in
Thailand are set and announced by CPF, a
major feed mill company, and these prices will
determine the prices of trash fsh used to
produce fshmeal. Typically, trash fsh is used
to produce fshmeal in the ratio of 4:1, i.e. 4 units
of trash fsh are required to produce 1 unit of
fshmeal. (Bureau of Agricultural Economics
Research, 2009).
Factors that affect the prices of fshmeal
include 1) demand for animal feed, 2) supply of
fshmeal, 3) reference prices of Peruvian and
Chilean fshmeal, and 4) prices of protein
subst i t ut es such as soybean (Of fce of
Agricultural Economics, 2012).
1) Demand for fshmeal
Since fshmeal is a main protein ingredient
used in animal feed production, especially
aqua-cultured animals, which use higher
percentage of fshmeal in their feeds, the
demand for animal feed therefore drives the
demand for fshmeal. The demand for animal
feed has been rising due to an increasing
37
Figure 26: Estimated quantity of livestock and feed ingredients required for suffcient
animal feed in Thailand, 2003-2012 (tons)*
18,000,000
16,000,000
14,000,000
12,000,000
10,000,000
8,000,000
6,000,000
4,000,000
2,000,000
0 | | | | | | | | | | |
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Fishmeal
Soybean meal
Maize
Broken rice
Livestock
Source: Thai Feed Mill Association, 2003-2012
(Note: *As mentioned earlier, these fgures are still calculated theoretically from the amount of livestock, as opposed
to using actual fgures.)
number of farmed animals, which in turn has
been increasing to meet the demand for food
from a growing global population.
In addition, prices of substitutes such as
soybean meal and meat bone meal (MBM)
affect the demand for fshmeal. Both soybean
meal and MBM give lower percentages of
protein than fshmeal, but when the prices of
fshmeal are high, animal feed mills will use
them instead of more expensive fshmeal.
2) Supply of fshmeal
The supply of fshmeal has been on a
slight decline since 2008. According to Oceans
in the Balance, Thailand in Focus report by
Greenpeace Southeast Asia (2013), Thailands
fsheries are declining due to deteriorating
resources caused by overfshing and the use of
destructive fshing gears such as bottom trawl
and push nets. Fi sh caught by trawl ers
comprises 40% of target species, 40.8% trash
fsh, and 19.8% of juvenile target species.
Statistics from the Department of Fishery cited
in this publication shows that catch per unit effort
has declined from 300 kg per hour in 1961 to
25 kg per hour in 2011.
3) Reference prices of Peruvian
fshmeal
Peru i s the worl ds l argest fshmeal
producer and exporter. Its FOB prices are used
as reference prices. These prices are affected
by the Peruvian fshmeal production and Chinas
fshmeal imports, which in turn mostly depend
on fshmeal stocks and demands from Chinas
aquaculture.
2.6 Classifcation
Fishmeal is divided into grades depending
on quality defned by the following criteria 1)
percentage of protein 2) odor 3) TVBN (Total
Volatile Basic Nitrogen a commonly used
indicator of freshness) and 4) percentage of
humidity. Fishmeal is also classifed by quality
into 6 grades: 1) shrimp grade 2) frst grade
fshmeal 3) second grade fshmeal 4) third grade
fshmeal 5) fsh head grade, and 5) leftover
grade (Bureau of Agricultural Economics
Research, 2012). The quality of fshmeal
depends largely on the quality of raw materials.
Fish caught by gillnet are the best-quality raw
materials that can be used to produce shrimp
38
grade fshmeal. This is because fsh caught by
gillnet belong to the pelagic school of fsh; they
are not mixed in with other marine creatures or
mud. In contrast, fsh caught by trawler,
especially bottom trawlers, have lower quality
than those caught by gillnet. Pair trawls use less
time to catch fsh than bottom trawlers do, so
the fsh caught by this gear are fresher than
those by bottom trawlers.
Tr i mmi ngs f r om f s h pr oc es s i ng
manufacturers such as fsh heads, bones, tails
or guts can be used to produce fshmeal, but
the resulting fshmeal is low protein fshmeal; it
will be either third or fsh head grade fshmeal.
A useful rule of thumb in estimating trash
fsh usage in fshmeal production is the fact that
trash fsh or pla pet as currently defned (badly
damaged or putrescent; completely unsalable
otherwise) can only be used to produce third
grade (#3 grade) fshmeal and below. Second
grade (#2 grade) fshmeal and above cannot
utilize trash fsh. However, since there is not
much discrepancy of protein between different
grades, some fshmeal producers will mix high-
protein fshmeal with lower-protein fshmeal in
order to upgrade fshmeal to sell for better
prices. This creates demands for low protein
fshmeal as fshmeal producers know that it can
be mixed to increase the percentage of protein
later on.
More details of fshmeal classifcation and
processes are found in Chapter 7 of this report.
2.7 Government policies and regulations
Import export policies
Import policies depend on government
policies during each period and existing trade
agreements. For example, import tariff of
ASEAN-China for fshmeal with 60%+ protein
in 2006-2007 was 15%, and then was dropped
to 8% in 2008-2009, and further reduced to 0%
in 2010. Import policies related to fshmeal since
2010 are as follows:
1. Import tariff for fshmeal with 60%+
protein imported under normal condition is 15%.
But it can be imported without quota at any time.
2. For fshmeal with protein lower than
60%, importers have to obtain import permission
from the Department of Foreign Trade. The
tariff levied for this type of fshmeal under normal
condition is 6%.
3. All grades of fshmeal are levied 0%
tariff if imported under:
1) ASEAN Free Trade Agreement
(AFTA)
2) Thailand-New Zealand Free Trade
Agreement (FTA)
3) Thailand-Australia Free Trade Agree-
ment (FTA)
4) ASEAN-China Free Trade Agreement
4. All grades of fshmeal are levied 5%
tariff if imported during January March and
3.33% during April December under Japan
Thailand Economics Partners Agreement
(JTEPA)
5. All grades of fshmeal are levied 10%
tariff if imported under ASEAN Korea Free
Trade Agreement (AKFTA).
For exports, exporters can export freely;
there is no export tariff.
39
3.
LITERATURE REVIEW: IMPACT
OF TRASH FISH INDUSTRY ON ECOSYSTEMS
Fisheries in Thailand are a large component
of the export industry, both in terms of wild-caught
and farmed products. Department of Fisheries
claims about 4.2 million tons of fsh and seafood
are produced per year, 90 percent of which is
destined for the export market, earning around
US$ 7.3 billion in 2011 (Department of Fisheries
(DoF), 2013). An increasing proportion of
undersized fsh and decreasing volume of
commerci al l y i mport ant speci es i n t he
composition of the wild fsh catch in recent years
suggest symptoms of biological overfshing and
loss of coastal habitat, declining stocks, with
concomitant falling profts of individual vessels
indicate that economically overfshed fsh stocks
threaten the viability of wild fsheries in the Gulf
(Ahmed et al. 2007, Nasuchon & Charles 2010).
The term trash fsh is misleading because
it suggests this part of the catch has no
ecological or commercial value. Clearly this is
not the case. The AFPIC Regional Workshop
on The production and use of low value/trash
fsh from marine fsheries in the Asia-Pacifc
region (Funge-Smith et al 2005) suggests that
uses of trash fsh are diverse and include:
1) local consumption (e.g. fresh, dried)
11
,
2) direct feed (e.g. livestock, high value
species aquaculture),
3) fshmeal production (e.g. for poultry,
aquaculture) and
4) value-added products (e.g. fsh sauce,
surimi, protein concentrates).
In the context of this study, however, we will
concentrate on that fraction of the fsheries
capture that is diverted towards fshmeal
processing. This fraction includes not only the
trash fsh component of the landed catch, but
al so offcuts from economi c fsh that are
pre- processed at the landing for canning or
surimi production (Fishmeal 6_2556).
In most economically developed polities,
such as Europe or Australia, much of the
non-targeted trawl catch and juveniles caught
are discarded in the sea (whether during the
sorting phase of the harvest or by the use of
specialised Bycatch Reduction Devices ftted to
the nets). In countries where there is a strong
market for trash fsh such as Thailand, on the
other hand, non-target catch and under-sized
fsh are also landed and may comprise a
substantial portion of fshermen incomes
( Supongpan & Boonchuwong 2010,
Boopendranath et al. 2013). A report prepared
for FAO (Kungsawan 1996) asserted that very
little discarding now takes place at sea in the
Thai fshing industry; this gels with feld observa-
tions made at fsh landings in southern Thailand.
The problems have been exacerbated by
inappropriate or uncoordinated policies within
and between government agenci es, for
example, the protection of the fshmeal industry
has a direct impact on fsheries, since it has
encouraged capture of smal l trash fsh,
often leading to high catches of juveniles of
important species (Lebel et al. 2002, Pauly &
Chuenpagdee 2003, Boonchuwongse &
Dechboon 2003, Stobutzki et al. 2006, Saikliang
11
Note that this is quite rare in Songkhla, and coastal Thailand generally; almost universally, the landed product that is regarded
as trash fsh has been damaged beyond suitability for human consumption, or is composed of species that are never eaten
by locals; the trawler fshermen are able to sell not only genuine trash fsh, but also the damaged remains of fsh and inver-
tebrates that accumulates in the cod end of the net during long trawls (often degraded to the point of putrescence).
40
2007). The enormously over-capacity trawl
fshery of the Gulf has in many ways become
the fshmeal producer that has enabled the
aquaculture industry to develop into a huge
export industry with relatively low feed costs.
However, the quality of the meal produced
from the Thai fsheries these day is not suffcient
by itself for aquaculture due to the poor quality
of the landings (predominantly damaged, or
degraded product) and consequently the
aquaculture meal industry supplements Thai
fshmeal with imported meal (World Bank 1991).
Thailand once exported the bulk of their
fshmeal (60% in 1980), but thereafter steadily
decreasing the export quantities to less than 1%
by 1992 and thereafter. Thailand became a net
importer of meal in 1992 (Deutsch et al 2007).
An APFIC workshop on the exploitation of
trash fsh and other low-value capture fsheries
(APFIC, 2005) found great diffculties in defning
the expression trash fsh in a meaningful
context either ecologically or economically;
they now prefer the expression low value fsh.
The problem arises partly because of the
widely variant interpretations of what constitutes
trash fsh in any given fshery; in specialist
fsheries, any low value non-target species is
regarded as trash fsh, whereas in heavily-
exploited multi-species fsheries such as
Songkhla the defnition of trash fsh is much
more nebulous.
Most fshermen rely on harvesting different
species for their livelihood and seldom target
one particular species (although they may
prefer certain species for their economic value).
Moreover, as the fshery in the Gulf of Thailand
has changed under exploitation and the most
desirable species have become rarer, species
that were previously discarded or sent directly
to fshmeal processors are now classifed as
economic fsh (Tossapornpitakkul et al., 2008).
Supongpan & Boonchuwong (2010) reported
that trash fsh were the most numerous
component of research vessel cat ches
everywhere in the Gulf of Thailand. Khemakorn
et al. (2005) reported also that fshermen would
sort damaged specimens of economic fsh and
those that had spoiled in transit into the trash
fsh bins for sale at landings. Comparisons of
recent with historical estimates of trash fsh
versus economic species in fsheries production
thus are at best tenuous. Consequently, the
fshermen and fsheries offcials usually fnd it
diffcult to clearly defne and understand the
by-catch issue, and even between agencies, the
defnition of trash fsh fuctuates.
Some theoretical fsheries context is of
assi stance i n ai d of understandi ng thi s
terminological problem. Firstly, it is widely
recognised that unselective fshing aimed at
maximising the total catch (the so-called
biomass trash fsh production industry model)
will tend to reduce average trophic level in a
systems food web (Pauly & Chuenpagdee
2003). Small fsh and invertebrates such as
squids and crustaceans that feed mainly on
plankton will become over-represented in the
marine community and will quickly dominate the
system in terms of biomass. A large proportion
of the catch from any vessel operating these
days in the Gulf of Thailand will be cephalopods,
indicating severe depletion of fnfsh stocks (in
early years, fnfsh comprised the bulk of
catches: Pauly 1985).
Increasingly in the Gulf of Thailand, the
total catch has a higher proportion of trash fsh
(consisting of undesirable or unpalatable
by-catch), much of which goes to fshmeal.
A survey by Patthananurak & Phoonsawat
(2003) concurs with Department of Fisheries
summaries that indicate around 1/3 of the
product landed by trawlers in the Gulf of
Thailand is classifed as trash fsh; however, the
proporti ons of j uveni l es and undersi zed
individuals of target species are typically not
included in the Fisheries fgures.
Tossapornpitakkul et al (2008) described
the catch of trawlers in Songkhla as (on
average) composed of 53% economic fsh and
47% trash fsh, of which 38.5% were juveniles
of economic species. These numbers varied
considerably throughout the year, with juveniles
being over-represented in catches during the
monsoon period coinciding with reproduction.
41
12
It might be worth noting that the assumptions made in many of the theoretical discussions of fsheries in the literature make
this same assumption: that the goal of the fshermen and management authorities is to balance long-term viability with short-
term proftability. This is usually wrong in Asia, since historical laxity and lack of knowledge about how to apply inappropriate
(mostly temperate, single-species) fsheries models to a disparate, multi-species tropical fshery have hampered understand-
ing of both the industry and the resource (Ruddle & Hickey 2008, Ye et al. 2011).
An earlier study (Sahat 1994 in Tossapornpitak-
kul et al., 2008) produced roughly similar
numbers (economic: trash fsh 55:45, juvenile:
trash 47:53), al though the previ ousl y
mentioned reclassifcation of species suggests
that the proportion of juveniles of economically
useful species are declining as a proportion of
the total catch (i.e. there has been a large
reduction in the amount of juveniles available to
catch in recent years, even with an expanded
list of species). Supongpan and Boonchuwong
(2010) place the fraction of juveniles in the trash
fsh component as 35%.
Reasons for bycatch
The size of the mesh at the cod-end of a
trawl net can make a very large difference in the
amount of juveniles caught as bycatch (In
Thailand, cod-end mesh size may be as small
as 15mm (5/8) and very few animals escape
(Eayrs 2007, Davies et al. 2009). Pauly (1985)
suggested that the minimum appropriate net
cod-end mesh si ze for the i nner Gul f of
Thailand, where the bulk of the catch was made
at that time, should be 4555mm; Pauly
apparently assumed, like Broadhurst et al.
(2000) that the goal of the fshery was long term
proftability rather than simply volume extraction,
and that the 60% reduction in bycatch offered
by the >45mm mesh was thus desirable
12
.
Larger mesh sizes greatly increase the chances
of juvenile fsh and prawns escaping the trawl
(Boonchuwong & Dechboon (2008) report that
seasonal prohibitions of mesh sizes smaller
than 47mm apply to certain areas of the Gulf,
for this reason). The Thai Department of
Fisheries Masterplan (DoF 2008) suggests that
this gear restriction is a primary source of
non-compliance and illegal fshing in the Gulf of
Thailand. Tossapornpitakkul et al. (2008)
reported that mesh sizes used by fshermen in
the Gulf of Thailand range from 19.05-25 mm
(3/4 -1), with most fshermen using a mesh of
22mm (7/8).
Di fferent types of bycatch reducti on
technologies have been developed in the fshing
industry around the world with a view to reduce
the bycatch and di scards from trawl i ng,
however, with the exception of TEDs (Turtle
Exclusion Devices), uptake of the technology in
tropical countries such as Thailand has been
miniscule (Ekmaharaj 2006, Boopendranath et
al. 2013). For some fshermen, trash fsh may
generate over one-third of their income from
the catch (Funge-Smith et al 2005). Bycatch
reduction devices can reduce the volume of
juveniles and non-target species captured by as
much as 40% (Eayrs 2007, Boopendranath et
al. 2013).
Fishing strategy contributes to the large
bycatch fgures published by the Department of
Fisheries; it can be seen that gear selection can
strongly infuence the capture composition.
For instance, large otter trawls return most of
the catch as trash fsh (comprising 45.4 - 62.5%
of the total catch), whereas edi bl e fsh
comprises only 14.4 - 29.1% of the total catch
(Boonchuwongse & Dechboon 2003); the
trade-off for the operators is that CPUE is much
greater for the larger vessels, since they are
towing much larger nets. The decline in mesh
sizes as overall CPUE diminishes means that
the increase in the trash fsh fraction subsidizes
the lower catch rate of the target species
(Dayton et al 1995, Khemakorn et al. 2005).
Undersized juveniles of various demersal and
some pelagic species are trapped by the
fne mesh sizes of trawls indiscriminately
harvesting marine products in prolonged
trawling operations. In social and economic
terms the total commercial biomass extracted
i n the GoT may be more i mportant than
sust ai nabi l i t y, i . e. t he unst at ed fshery
management objective is to maximize the catch,
irrespective of the species composition (in fact
the DoF website, English version {http://www.
fsheries.go.th/english/introduction.html} states
that its goals are achieving catch targets for the
42
fshery rather preserving the resource for future
generations). The ratio of undersized fsh to the
total catch is huge in a multi-species fshery that
is concerned only with maximising the volume
of product landed.
Overfshing in GoT
This is not new information; a stream of
documentation dating back several decades
has consi stentl y warned of the massi ve
overcapacity in the GoT fshery since the 1980s
(e.g. Hongsul 1980); in fact, Payaotou &
Jetanavanich (1987, p44) stated: by 1973
the inshore catch reached 803,000 tonnes
which is indicative of overfshing not only when
compared to the MSY but also when the
declining catches in subsequent years are
considered. Pauly (1985) went further
fortunes were made, but the bottom line is
blight the Gulf of Thailand became barren....
The overfshi ng probl em was repeatedl y
highlighted in subsequent years, in a variety of
reports (e.g. Boonwanich 1992, Janetkitkosol
et al., 2003, Kongprom et al. 2003, Pauly &
Chuenpagdee 2003, Boonchuwongse &
Dechboon 2003, Stobutzki et al. 2006).
The Gulf of Thailand is one of the most-
documented examples of resource depletion in
fsheries literature; by 1995 the total biomass
estimates had declined to less than 8% of the
1965 esti mates (Stobutzki et al . 2006).
Moreover, the impact of unregulated ecosystem
overfshing in the GoT has been highlighted in
several key national documents prepared for
regional and global fsheries organisations
(Payaotou & Jetanavanich 1987, Kongprom et
al. 2003, Lymer et al 2008). When the trawl
fshery began in the 1950s, inappropriate gears
and inexperience ensured that fshing pressure
was minimal; a substantial technical upgrade in
the 1960s saw rapid increase in capacity,
helped by CPUE in the order of around three
hundred kilograms per hour.
The standing biomass and CPUE rapidly
declined as the easily harvested portion of the
stock was exploited by a rapidly expanding
fshing feet (Pauly & Chuenpagdee 2003)
trawlable biomass in the GoT declined from 680
000t in 1961to 560 000t in 1995, attributed
mainly to overcapacity in the fshing industry
(Funge-Smith et al. 2012). Subsequent declines
in Thailands marine fsheries resources can be
attributed to a number of additional factors,
including the use of destructive fshing gear (e.g.
trawl, push nets) and methods (e.g. large scale
trawling in near shore areas, use of push nets
near coral reefs). Industrial fshing in Thailand
is characterised by an almost ubiquitous culture
of violation of both fsheries regulations (e.g.
fshing in fsh spawning grounds during periods
of temporary fshing bans) and coastal zone
exploitation bans, and a Malthusian extraction
of marine resources, resulting in destruction of
fsh habitats, such as mangroves, seagrass
meadows, and coral reefs.
It is actually quite diffcult to establish the
real intensity of fshing pressure in the Gulf of
Thailand, because the information released by
the Department of Fisheries is inconsistent,
at times obfuscatory and apparently self-
contradicting. For instance, the capture levels
reported in the documents available from the
DoF website confict with those reported to FAO
and other organisations, partly because fgures
included product landed at Thai ports but
sourced elsewhere (usually Indonesia, where
several hundred nominally Thai boats fy
Indonesian fags: Morgan et al. 2007). More-
over, there is no clear estimate of the amount
of fsh illegally harvested by commercial opera-
tors within the 3km coastal limit that is supposed
to be reserved for local fshermen (Barbier
2002). The research vessels used to calculate
the Fishery Departments MSY and CPUE fg-
ures use a 40mm cod-end mesh (Payaotou &
Jetanavanich 1987, Kongchai et al. 2003, Kong-
prom et al. 2003); since small nets retain
disproportionately more juveniles and trash fsh,
this has the effect of making the Department
of Fi sheri es capt ure and eff ort fgures
underestimates of the true catch (in all size
classes).
43
Figure 27: Reported fnfsh landing in the Gulf of Thailand
1985 1990 1995 2000 2005 2010
Year
L
a
n
d
i
n
g
s

(
t
o
n
s
)
1,500
1,000
500
0
total fsh
food fsh
trash fsh
Reported fnfsh landings in the gulf of Thailand
Figure 27. Landings of fnfsh abstracted from DoF reports, 1986-2011. The sharp rise in the early 1990s refects
the growing importance of the pelagic tuna fshery (only a fraction of which is actually captured in the GoT). The
circled area indicates a reclassifcation of several species from trash fsh to food fsh. The crash evident in the
landings in the period after 2005 probably refects a tipping point in the ecosystem towards a lower productivity
system with a higher proportion of low trophic level species caused by chronic overexploitation of demersal species.
Part of this change may be explained by some Thai fshing boats changing registration to Malaysia and Indonesia
domicile, in order to comply with more stringent Malaysian and Indonesian regulations.
An adequate management system based
on single-species and single- feet reference
points is probably infeasible in the context of the
Gulf of Thailand. A substantial proportion of the
landings at Songkhla port are sourced from
vessels operating in international waters (or
from the EEZs of neighbouring countries), yet
are included in production statistics (FAO 2009),
somet hi ng whi ch t ends t o val i dat e t he
expectation of unreliability of offcial fsheries
esti mates for the southern GoT fshery.
Likewise the Department of Fisheries frst
included Tunas as a separate entry in the Indian
Ocean catch statistics in 2005 (and switched
Barracuda from demersal to pelagic); these
are likely to be mostly products of offshore
fshing vessels operating outside Thailands
EEZ (Lymer et al 2008). It can be said without
hesi tati on, however, that most demersal
resources and almost all groups of pelagic fsh
are over-exploited. Furthermore, the catch rates
recorded by government research vessels have
shown persistently decreasing trends since
1966 (FAO 2009).
44
Within the Gulf of Thailand, fshing effort has
increased as catches have declined.
Payaot ou & Jet anavani ch ( 1987)
highlighted the rapidity of the decline in CPUE
(Catch per Unit Effort) of GoT fsheries, as well
as the change in trash fsh composition of the
catch, and related it to overcapacity. Kongprom
et.al. (2003) suggested that the 1995 level of
fshi ng effort was about twi ce the effort
necessary to harvest Maximum Sustainable
Yield (MSY), which indicated that the demersal
and other fshery resources were already
severely over-fshed. Supongpan and Boonchu-
wong, (2010) assessed demersal fsh caught by
trawl fsheries in the Gulf of Thailand and
reported a calculated MSY of 277,027 metric
tons (approximately one third of that estimated
by Payaotou & Jetanavanich (1987) a decade
earlier) at an optimum fshing effort (fMSY) of
31.4 million trawling hours. Demersal catches
in 2005 reported by the Department of Fisheries
amounted to 315,418 tons captured during 49.3
million hours of fshing effort. The reported effort
expended in capturing demersal fsh exceeded
optimum by 60% and the safely extractable
resource of demersal fsh was overexploited by
more than 50%. It can be seen easily here that
the economic beneft of the extra effort followed
the classic law of diminishing returns, and that
the demersal shrimp industry in particular was
unproftabl e at i ts current l evel of effort
(Boonchuwongse & Dechboon 2003).
A calculation of optimal fshing effort by
Ahmed et al (2007) indicates the overcapacity
problem clearly (Figure 21 below). Not exploiting
fsheries resources at MSY or MEY leads to the
loss of production and rents from the fsheries;
this is a 2-tailed relationship in that under-
exploitation means the resource is not providing
as much as it might, whereas overexploitation
means that the resource is being degraded
(Guillen et al. 2012). Over the decades since
industrial fshing was introduced, fsheries
development in the Gulf of Thailand has
concentrated on increasing fshing effort to
maintain or increase the production volume.
Figure 28: MSY model
Figure 28. In this model, the MSY fgure represents the apex of the cost-beneft curve; excessive effort, such as
that reported by the Department of Fisheries, is greatly sub-optimal, and approximately twice the effort that would
produce MEY (Maximum Economic Yield). From Ahmed et al. 2007.
45
Evidence for massive changes in species
composi ti on i n the Gul f of Thai l and was
obtained from analysis of trawl survey data
between 1963 and 1972 (Pauly, 1985). It has
been shown that fshing can affect, directly or
i ndi rectl y, the structure of demersal fsh
assemblages (Suvavepun, 1991 Kongprom et
al ., 2003). Neverthel ess, thi s conti nued
expansion of the GoT fshery was economically
driven, despite local and overseas experiences
and the recommendations of experts within
Thailand (Boonchuwongse & Dechboon 2003),
apparently under the impression that the stock
was inexhaustible. The extreme overcapacity
which was apparent in the 1990s has seen
successive collapses in fsheries production, to
the extent that reported CPUE was reduced to
around from around 300kg/hour in the 1960s
to 17kg/hour in 2010 (Pauly & Chuenpagdee
2003, Boonchuwongse & Dechboon 2003,
[Fisheries Director] (unpubl 2010)).
Other research has placed actual CPUE in
the GoT much lower: a trawl survey conducted
by SEAFDEC in 2004-5 indicated that the
highest average catch rate in the GoT was
11.9kg/hour, with an average CPUE of 10.3kg/
hours (Rugpan & Bunleudaj, 2012). The much
reduced CPUE has, in turn, led the fshermen
to employ increasingly long trawl times (up to 6
hours) between net retrievals. The extraordinary
length of tow times highlights the increasingly
patchy resource distribution in the trawl areas;
chroni c fshi ng di sturbance l eads to the
removal of high-biomass species and declines
in total community biomass, biomass of larger
macrofauna, and a total production decline
(Duplisea et al. 2001, 2003, Jennings et al 2002,
Queiros et al 2006). It also leads to greater
amounts of patchinesss in the resource, as the
areas disturbed by trawling take time to recover
(Thrush & Dayton 1991).
Tossapornpitakkul et al., (2008) reported
that three major strategies exist for commercial
fshing operators: diurnal, daylight or nocturnal.
The diurnal fshermen (around 32% of vessels)
conduct operations of 1-13 days duration
(average 6+3.5 days), during which they
customarily trawl twice during the day and 2-3
times per night, with each tow being 4-5 hours
duration. They use the same capture equipment
for both daytime and night time operations.
Daytime-only operators (around 7% of vessels)
conduct trips of 1-10 days duration, although
they tend to prefer short trips (2.3+3 days).
They conduct 2-3 trawls per day, each lasting
4-6 hours. The nocturnal fshermen (around
61% of vessels) likewise preferred short (2
days) trips and also trawled 2-3 times per night,
with tows being 3-6 hours long. These very long
trawl times increase the proportion of damaged
product and bycatch in the trawls, as the early
catch is smashed against the back of the net
and forms a solid lining over the net mesh
through which nothing escapes.
The great weakness of surplus production
models such as the one presented here is that
they make certain assumptions about the
generation times of the fshery stock; the most
egregious of these is to assume that the
high-turnover species which dominate the catch
of the highest ecological and economic value.
This is seldom true in a complex multispecies
fshery such as the Gul f of Thai l and. In
multi-species and multi-feet fsheries, single
species assessments, and consequently MSY
and MEY reference points, are often not valid,
and so catch targets are often gross over-
estimations (Guillen et al 2013). Unfortunately,
it is impossible to adequately model the
complexity of the demersal assemblage in the
GoT in any meaningful way. The consequences
of adopting a simplifed model are profound,
however: the remai ni ng stocks become
increasingly reliant on recruitment to maintain
population, and thus undergo larger variations
i n bi omass as r ecr ui t ment fuct uat es
stochastically between years. Fisheries returns
thus become increasingly diffcult to predict,
particularly for artisanal fshermen who have
limited scope for migration to different localities
if fsh become scarce.
The effects of juvenile overfshing
Overfshing is increasingly understood to
result in indirect alterations of habitat structure
and function, particularly in regards to trophic
46
levels (Valentine & Heck, 2005). The roles that
small fsh species may play as prey, competitors,
predators and herbivores make them potential
key members of communi t i es and key
determinants of the fate of other populations
(Forster & Vincent 2010). It is trivial to predict
that the integrity of juvenile populations is crucial
if ecosystems are to function effectively.
Truncation of age structure by fshing has been
suggested as the main reason for the increased
higher variability in recruitment of exploited
species (Hsieh et al., 2006), and hugely
reducing the number of individuals available for
capture by artisanal fshing techniques (Gislason
2001, Naj mudeen & Sathi asdhas 2008).
This, of course has tremendous consequence
for the livelihood and food security of artisanal
fshermen who rely on coastal replenishment,
and also for the industrial fshermen who target
the adult population (Figure 29). The reduction
in habitat heterogeneity is a major deterrent in
the survival and recruitment of a multitude of
marine organisms, including many species that
are commercially important (Kumar & Deepthi
2006). Substantial increases in proftability of
fshing would be achieved, at lower harvest
rates, if juvenile fshing were reduced (Vibun-
pant et al. 2003).
Figure 29: Simplifed coastal food webs
BEFORE FISHING AFTER FISHING
Figure 29. Simplifed coastal food webs showing changes in some of the important top-down interactions due
to overfshing; before (left side) and after (right side) fshing. Bold font represents abundant; normal font represents
rare; crossed-out represents extinct. Thick arrows represent strong interactions; thin arrows represent weak
interactions. Severe overfshing drives species to ecological extinction because overfshed populations no longer
interact signifcantly with other species in the community (From Jackson et al. 2001)
47
Even in a system that is targeting only the
largest individuals, as the level of fshing
mortality increases, the population dynamics
are increasingly dominated by recruitment, and
at the limit the population variability is equal to
the variability of recruitment (Hsieh et al., 2006,
Froese et al., 2008). Fisheries biologists tend to
partition overfshing into several overlapping
components, dependi ng on the i ndustry
practi ces. Recrui tment (or reproducti ve)
overfshing can be defned as depleting the
reproductive part of the stock by so much that
recruitment is impaired. Growth overfshing can
be defned as where i nef fci ent l y smal l
specimens are targeted, depleting the young
part of the stock before it has reached its full
biological and economic potential (Diekert
et al. 2010). The common perception is that
growth-overfshing is the more wide-spread
form of overfshing, whereas recruitment-
overfshing has more disastrous consequences
since it directly impedes the future viability of
fsh st ocks. Avoi dance of recrui t ment
overfshing is the stated main theoretical basis
for fsheries stock management in the Gulf of
Thai l and; t he Depart ment of Fi sheri es
(noti onal l y) seeks to avoi d reduci ng the
spawning stock to a level that the catchable
stock diminishes over time because of a lack of
recruits. In truth, the processes overlap
considerably, but the removal of juveniles from
the potential spawning population has a more
insidious effect.
Severe overfshing drives species to
ecological extinction because overfshed
populations no longer interact signifcantly with
other species in the community (Jackson et al.
2001). The use of single-species reference
points is questionable when species interactions
are important (Stergiou 2002). Rapid declines
in mean trophic level of captured fsh (i.e.
fshing down the food web) refects profound
modifcations in the ecosystem, and leads to a
cascade of undesirable consequences (Pauly
& Chuenpagdee 2003, Srinivasan et al 2010,
Rochet & Benoit, 2011). In a multi-gear
multi-species fshery such as the Gulf of
Thailand, where undersized and otherwise
undesirable components of the catch are a key
part of fshermen income, the proliferating
impact of juvenile fshing is much more intense
(cf Najmudeen & Sathiahas 2008).
Disproportionately large-scale removal and
destruction of young and juveniles of fsh and
crustaceans are especially detrimental to the
fshery because when juvenile mortality is
increased the future catches and subsequent
recruitment will be affected. The estimates
made (by fsheries biologists) of growth,
mortality and recruitment are thus invalidated,
because the progression of juveniles into the
spawning population is compromised.
Changes to the community composition are
an obvious and pernicious effect of overfshing
and trophic decline. The creation of ponds for
marine shrimp aquaculture under the impetus
of this push has led to the destruction of
thousands of hectares of mangroves and
coastal wetlands. This is important to local
artisanal fshermen because they provide
nursery grounds for various young aquatic
animals including commercially important fsh,
and their destruction can lead to substantial
economic losses for commercial fsheries
(Stobutzki et al 2006, Allsopp et al 2008) and
livelihood risks for local people heavily reliant
on fshing as both income and food security
(Fleishman 2006, Pomeroy et al. 2007).
It is important to note at some stage that
trawl bycatch is not the only source of juvenile
mortality in the system. The cage culture of food
fsh widely-promoted as an alternative income
stream for local fshermen uses predominantly
wild-caught juveniles as stock (Tanyaros et al
2008, Songrak et al 2008, Sheriff et al 2008),
and also uses whole or sectioned trash fsh
(including many juveniles) as stock feed
(Bunlipatanon et al 2012). Since the mangrove
creeks where cage culture is practiced are also
key nursery areas for many economically
important species, this represents a signifcant
potential threat to recruitment and trophic
integrity of the system, over and above the
threat posed by industrial fshing (FAO 2008,
Allsopp et al. 2013).
48
LITERATURE REVIEW: CHANGES AND IMPACT
ON LOCAL ARTISANAL FISHING COMMUNITY
4.
Whenever marine resources are depleted,
every fsherman is affected, both artisanal and
commercial alike. However, artisanal fshermen
seem to be more gravely affected, as their
fshing capacity is a lot lower than the commercial
fshermen in term of fshing gears and vessels.
They seem to be victims of overfshing by
commercial fshermen, particularly those using
trawlers and push nets which are the main trash
fsh suppliers to fshmeal producers.
In the context of this study, although the
research team focuses on analysing the impact
of trash fshing on the local artisanal fshing
communities in Songkhla, it is diffcult to
separate the impact of trash fshing by trawlers
and push nets from anchovy fshing using luring
light, so in this section of literature review, we
will include impact from both push nets fshing
and anchovy fshing with luring light as both of
them are destructive fsheries that highly affect
the marine ecosystem and eventually have
impact on the artisanal fshermen. It will show
how the artisanal fshermen were impacted and
what the results were.
4.1 Defnitions of Artisanal Fisheries
Before we talk about changes and impact
of trash fshing on local artisanal fshing
communities, we should frstly defne the term
artisanal fshery ( ) so that we
have a clear picture and scope of what it is in
this research. The term artisanal fshery is
sometimes used interchangeably with the terms
coastal fshery (a::.ca:) and small-scale
fshery (a::.c:e.aa) (Artisanal Fisheries,
2012; DoF, 2005; FAO, n.d.; Kijthavorn et al.,
2000; Panjarat, 2008; Sirichai, 2003). This is
because art i sanal fsheri es are usual l y
small-scale, and the fshing grounds are inshore
or operate within three km. off the coastline.
However, the word artisanal also connotes
low-level technology, and the use of small
amount of capital and labor (FAO, n.d.).
We can summarize key characteristics of
artisanal fsheries as follows:
1) Not using any fshing vessels or using
small size fshing vessels with or without
power not more than 10 meters long e.g.
sailboats, Kolae boats, Hua-Tong boats
2) Using low-tech fshing gears specifcally
for target species e.g. nets, hooks, lines,
traps, crab gill nets, shrimp gill nets
3) Operating not far from the shoreline
usually within three km. from the coast
4) Using labors within households from 1-3
persons
In some countries, artisanal fsheries are
defned by type and size of boats. For example,
in Brunei, artisanal fshermen are those who use
non-powered or powered boats not longer than
60 ft.; in Hong Kong, not longer than 40 ft.; in
Malaysia, not over 10 G.T. (gross ton); the
Philippines, not over 3 G.T) (Distinguishing and
Types, n.d.). A similar criteria was used by
National Statistical Offce (NSO) and DoF
(2001) when they conducted a survey on the
income of small-scale fshing households in
2001. They defned smal l -scal e fshi ng
household by type of boats including no-fshing
vessel, non-powered boats, outboard powered
boats, inboard powered boats less than 5 G.T.,
and inboard powered boats between 5-9 G.T.
49
In some countries, artisanal fsheries are
defned by type and size of boats. For example,
in Brunei, artisanal fshermen are those who use
non-powered or powered boats not longer than
60 ft.; in Hong Kong, not longer than 40 ft.; in
Malaysia, not over 10 G.T. (gross ton); the
Philippines, not over 3 G.T) (Distinguishing and
Types, n.d.). A similar criteria was used by
National Statistical Offce (NSO) and DoF
(2001) when they conducted a survey on the
income of small-scale fshing households in
2001. They defned smal l -scal e fshi ng
household by type of boats including no-fshing
vessel, non-powered boats, outboard powered
boats, inboard powered boats less than 5 G.T.,
and inboard powered boats between 5-9 G.T.
4.2 Thailands Artisanal Fishing
Communities
Much research has focused that Thailands
context, artisanal fshery concept goes beyond
key characteristics mentioned earlier; it also
includes traditional, handed-down wisdom from
previous generations, and the responsibilities
to protecting and preserving the sea which is
unlike commercial fsheries that focus on getting
the most out of the sea. The wisdom teaches
them not only when, where and how to fsh (e.g.
they learn that shrimps and fsh are abundant
during Monsoon season; they use gears
specifcally for target species with large mesh
size, so mostly, they catch mature fsh and/or
other fauna; for example, they will use crab gill
nets with 7 cm mesh size to catch crabs), but
also how to maintain the abundance of fsh in
the sea. (They learn not to overfsh and make
artifcial corals or Sung for the fsh to live in.)
This is because in many cases, fshing is just
for subsistence, and it is the only thing they
know how to do, so their lives and their family
members depend on the sea (Sirichai, 2003).
Accordi ng to the Report of the 2000
Income of Small-Scale Marine Capture Fishery
Household Survey by NSO and DoF (2001),
t her e wer e 53, 343 smal l - scal e fshi ng
households country wide
13
. 86.1% or 41,225
were fshing households with outboard powered
boats (long-tailed boats, .a:e). Songkhla
had the highest number of small-scale fshing
households, i.e. 6,175 households which were
86.71% of the total marine fshery households
in Songkhla (7,121 households). Of the total
number of small-scale fshing households,
63.64% or 3,930 households operated with
outboard powered boats, and 27.5% or 1,683
did not use fshing vessels. During peak season,
there were 16,340 fshermen working, of which
61.2% or 10,001 worked in small-scale fsheries.
4.3 Conficts between Commercial
Fishermen and Artisanal Fishermen
In modern day, artisanal fshermen do not
capture fsh only for their own consumption but
as main income of the households. They
preserve and protect the sea by capturing
mature fsh to give them a chance to reproduce
and creating artifcial corals for fsh. Problems
occurred when commercial fshing, particularly
push nets and trawlers, came to fsh within
fshing grounds of artisanal fshermen, or within
3,000 meters off the shore whi ch i s fsh
spawning grounds. These push nets and
trawlers 1) depleted marine resources by
sweeping almost everything unselectively into
their cod-ends, 2) broke fshing gears of local
artisanal fshermen stationed in the sea, and 3)
destroyed the sea grass and coral reefs as well
as artifcial corals made by local fshermen,
which were habitats and spawning grounds of
the fsh (Boonwanich & Boonpakdee, 2009).
In The Roles of Fisherfolk Community in
Natural Resources Management and Law
Enforcement in the Area of Pattani Bay: Case
Study at Tanyongpao Village
14
, Moo 4, Tagamsa
13
In this report, the small-scale fshing households include those who do not using fshing boats, use non-powered boats, use
outboard powered boats, and inboard powered boats not over 9 G.T.
14
Tanyongpao village is a fshermens village in Tambon Tagamsam, Amphoe Nongchik, Pattani. The village has around 236
households with the population of 1,154 people, of which 99% were Muslim and 80% were artisanal fshermen.
50
Subdistrict, Ampoe Nongchik, Pattani, Piya
Kijthavorn et al. (2000) also found that the
intrusion of push net fshing boats, which were
fuelled by fshmeal business since 1970,
destroyed fshing gears of local fshermen as
well as the traditional artifcial corals or Sung,
and depleted coastal resources, reducing the
amount of marine animals that local fshermen
could catch. These fndings are similar to those
of Chalita Bandhuwong (2000) (cited in Suwi-
mon Piriyathanalai et al., 2011) in the paper
titled Huatong Development, Characteristics,
and Adaptations of Andaman Fisherfolk. She
states that there are two problems caused by
trawl and push net fshing; one is that the fshing
gears of the local fshermen were destroyed,
and the other is the reduction of marine animals.
In case of anchovy purse seines with luring
light, even though they did not destroy the
fshing gears of the local artisanal fshermen,
the way they catch fsh using light to lure them
at night is very destructive to the marine
ecosystem, because the light lured not only
anchovy that was target species, but also other
juveniles of economic fsh. Of the total fsh
caught by this method, 69-78% was anchovy,
and the rest was juveniles; in some areas e.g.
Prachuab Kirikhan, the percentage of anchovy
went down to 55%. These juveniles would then
be sold cheaply to fshmeal producers as trash
fsh. In the contrary, if they were let to live, they
would have much higher economic values
(Dachapimon, 2000).
Conficts between commercial fshermen
and artisanal fshermen can be dated back
to 1964 when push nets and trawlers were
booming. Ministry of Agriculture had to enact
regulations prohibiting powered boats with push
nets and trawlers to operate within 1,000 meters
off the coast, as they destroyed the fshing gears
of the local fshermen causing the conficts
between them. The situation did not improve; in
fact it worsened after many countries claimed
their EEZ and shelf areas, causing Thai fshing
boats to lose their about 300,000 km2 fshing
grounds when high seas they used to fsh were
turned into shelf areas of other countries. Thus,
some of them came back to fsh in Thai waters
encroachi ng upon t he preserved areas
(Boonwanich & Boonpakdee, 2009; Sirichai,
2003). Suwimon Piriyathanalai et al. (2011)
studied fshing communities in Pattani and wrote
a paper titled the Project of Adaptation of
Fisherfolk in Pattani. It states that fshermen
communities in Pattani have faced destructive
fshing problem caused by push net fshing for
more than 30 years, and the problem became
more severe during the past 15 years.
Main reasons that the commercial fshing
boats violated the laws that prohibited the
commercial fsheries within 3,000 meters off the
coast are 1) marine resources outside the
preserved areas have been used up 2) the laws
are not clear, e.g. when one province enacted
regulations that prohibited push nets from
operating in that province, it is not clear where
the line is in the sea because there was no map
attached, and 3) the penalties are low compared
to the returns they would get from violating
the laws (Sirichai, 2003; Offce of Natural
Resources and Environmental Policy and
Planning).
4.4 Impact of Commercial Fisheries
in the 3,000-Meter Prohibited Areas
on Artisanal Fishermen
From the statistics of small-scale fshing
households, we found that the majority of the
artisanal fshermen in Thailand use small
outboard powered boats. In Songkhla, the
percentage of artisanal fshermen who use such
boats went down to 63.64% in 2000, but about
27.5% did not use any fshing vessel. Thus,
when commercial fshing boats violated laws
and caught fsh within 3,000-meter area,
resulting in the depletion of marine resources,
this left local artisanal fshermen with very
limited choices as 1) their boats, if any, were
relatively small, so they could not go to fsh
somewhere else very far from the shore 2) many
of them have no other skills but fshing (Sirichai,
2003). Similarly, Sutira Chairuksa (2001)
reported in her research The Way of Life of the
Local Fishing Households: Comparative Studies
51
15
Ban Bor-It village is a local fshing community along the coast of GoT in Tambon Koh-Taew, Amphoe Mueang, Songkhla. There
are about 300 households with the population about 1,500 people. The majority are artisanal fshermen operating in GoT.
16
Ban Ta-Sao village is a local fshing community by Songkhla Lake in Tambon Satingmor, Amphoe Singhanakorn, Songkhla.
There are about 270 households with the population about 2,850 people. The majority are artisanal fshermen operating in
Songkhla Lake.
Two Areas, That Are Between the Gulf of
Thai l and Area and Songkhl a Lake Area,
Songkhla that 82.9% of heads of the local
fshing households of the sample group (92
househol ds) at Ban Bor-It vi l l age
15
sai d
they had not done anything else before they
became fshermen while the percentage went
up to 94.2% from the sample group of 120
households at Ban Ta-Sao village
16
.
Trin Suknuan (cited in Suwimon Piri-
yathanalai et al., 2011) wrote in his research
entitled Adaptation of Fisherfolk Communities
at Pak Phanang River Basin After Pak Phanang
River Basin Development Project that the
abilities of local fshermen to adapt themselves
depended on many conditions most importantly
resource condition, economic condition, and
social and cultural condition. Those who only
worked on fshery and had no land would have
low chances and abilities to adapt themselves.
Those who could not adapt had to relocate.
When the sea was not abundant any
longer, local artisanal fshermen then faced a lot
of problems, both fnancial and social. Financial
problems include decreasing incomes and
increasing costs of fsheries eventually leading
to informal debts (Dachapimon, 2000). Figure
30 shows average daily incomes per boat of
artisanal fshermen in Songkhla in fve villages
during 1993 1999 (Piya Kijthavorn, cited in
Dachapimon, 2000), which was a downward
trend. Interestingly, in 1993, their incomes
varied widely, e.g. fshermen in Ban Le could
earn as much as 2,000 Baht per day while
fshermen in Ban Pang Chang Tie only earned
around 600 Baht per day. However, in 1999,
their income fell to around 200-400 Baht per
day, except in Ban Le that the income collapsed
to 50 Baht per day, 40 times or 4,000% lower
than their income in 1993.
Figure 30: Average daily income per boat of artisanal fshermen in Songkhla during 1993-1999
Ban Hua Wa ra,
Ranode
Ban Pang Chang Tie,
Sathingpra
Ban Muang Ngam,
Singhanakorn
Ban Le, Singhana-
korn
Ban Taling Chan,
Chana
| | | | | | | |
1993 1994 1995 1996 1997 1998 1999
2500
2000
1500
1000
500
0
Source: Piya Kijthavorn cited in Dachapimon, 2000.
52
When we look at local fshermens costs,
we will see that they are quite stable throughout
the 7-year period. There are signifcant changes
in costs at two villages: Ban Pang Chang Tie
and Ban Muang Ngam, during 1996-1997.
From 1993-1996, the average cost of artisanal
fshermen at Ban Pang Chang Tie was 300 Baht
per day, and that of Ban Muang Ngam was 460
Baht, but in 1997, the costs dropped to 150 Baht
and 120 Baht. This is probably not because the
costs themselves decreased, but because the
fshermen reduced their fshing efforts time
spent on fsheries and distance offshore as
they could not bear the costs any longer. This
will become clearer when we look at the Figure
30 which shows average profts/losses of the
artisanal fshermen at fve villages. In 1996 the
fshermen in Ban Pang Chang Tie broke even,
while those at Ban Muang Ngam made losses.
Probably because of the clear downward trend
of their income, the fshermen decided to reduce
the efforts so that they can save costs and have
some money left.
In Figure 31, the graph looks similar to the
one in Figure 22 in that it is also a downward
slope. Since average incomes varied widely in
1993 while the costs were not much different,
the profts fshermen made also varied widely
along with incomes. However, in 1999 after their
income had been consistently decreasing for
many years, the profts they made were around
50 150 Baht except for Ban Le. Out of the
fve villages, the fshermen from Ban Le village
made the highest incomes of 2,000 Baht in
1993-1994, but after that their average income
sharply dropped to 1,000 Baht (50% decrease).
It continued to decline until it was 150 Baht per
day in 1998 which was below cost, resulting
in 50-Baht loss. Then, in 1999, their cost went
up 50% from 200 Baht per day to 300 Baht
(probably because they put more efforts for the
hope that they might be able to catch more fsh
and earn more money), but it turned out that
they could make only around 50 Baht, or 66%
less than they earned in the previous year.
Figure 31: Average daily cost per boat of artisanal fshermen in Songkhla during 1993-1999
Ban Hua Wa ra,
Ranode
Ban Pang Chang Tie,
Sathingpra
Ban Muang Ngam,
Singhanakorn
Ban Le, Singhana-
korn
Ban Taling Chan,
Chana
| | | | | | | |
1993 1994 1995 1996 1997 1998 1999
2500
2000
1500
1000
500
0
Source: Piya Kijthavorn cited in Dachapimon, 2000.
53
Figure 32: Average daily proft/loss per boat of artisanal fshermen in Songkhla during 1993-1999
Ban Hua Wa ra,
Ranode
Ban Pang Chang Tie,
Sathingpra
Ban Muang Ngam,
Singhanakorn
Ban Le, Singhana-
korn
Ban Taling Chan,
Chana
| | | | | | | |
1993 1994 1995 1996 1997 1998 1999
2200
1700
1200
700
200
-300
Source: Piya Kijthavorn cited in Dachapimon, 2000.
When the returns were not worth the efforts,
many fshermen stopped fshing, sold their
boats, and found other jobs e.g. they became
workers in commercial fshing boats, factories,
or at the construction sites; a considerable
number became unempl oyed. For those
who still carried on fshing to maintain their
household cash fows as well as invest in their
boats, fshing gears, and fuels as they put in
more effort and went further offshore, they had
to turn to middlemen for loans. This is because
most artisanal fshermen were not qualifed
to borrow money from the bank e.g. they
coul d off er no col l at eral and had l i t t l e
savings (Dachapimon, 2000; Sirichai 2003).
As household debts increased and incomes
declined, men spent more time away at sea,
while women had to leave their homes to work.
Some could not afford to send their kids to
school, and these kids were then illiterate
(Kijthavorn et al., 2000).
For those who decided to fnd other jobs to
solve fnancial problems, many faced social
problems instead. When fshermen went to
work on big commercial boats, in the cities
or overseas, they were exposed to new
environments, new cultures, as well as drugs.
Some of these people brought back drugs to the
communities (Kijthavorn et al., 2000). Moreover,
people who work on commercial fshing boats
or at the port tend to commit a crime because
they are addicted to drugs. When adults move
to the city or another country and leave their
children behind, the children are not well-
educated and tend to have problems; some of
them became drug addicts (Piriyathanalai et al,
2011). However, if the parents took their children
with them, the children will not be educated.
Kijthavorn et al. (2000) reported that some
fshermen went to work illegally in Malaysia and
brought their children with them. Their children
were then not educated, while some had
children while they worked as illegal aliens,
making the children born in Malaysia illegal
children.
54
EXISTING REGULATIONS AND STANDARDS RELATING
TO TRASH FISHING AND THAILAND IMPLEMENTATION
5.
5.1 FAO Code of Conduct for
Responsible Fisheries and
the EU regulation on IUU fshing
Concerns of depletion of marine resources,
damages to the marine ecosystems, and
soci oeconomi c i mpact s t hat t hr eat en
sustai nabi l i ty i n the l ong-run have been
expressed at various international stages.
The Code of Conduct for Responsible Fisheries
had been devel oped accor di ng t o t he
recommendation from the Nineteenth Session
of the FAO Committee on Fisheries (COFI) held
in 1991 and was eventually adopted by the
Twenty-Eighth Session of the FAO Conference
on 31 October 1995 (FAO1, 2014). The code
provides principles, guidance, and instruments
for all involved in fsheries to achieve the
ultimate goal of sustainability (FAO, 1995).
The international plans of action (IPOAs)
are voluntary instruments elaborated within
the framework of the Code of Conduct for
Responsible Fisheries. In practice, they function
as international agreements to manage issues
relating to responsible fshing practices. Four
IPOAs include (FAO2, 2014):
1) International Plan of Action for Reducing
Incidental Catch of Seabirds in Longline
Fisheries
2) International Plan of Action for Conser-
vation and Management of Sharks
3) International Plan of Action for the
Management of Fishing Capacity
4) International Plan of Action to Prevent,
Deter, and Eliminate Illegal, Unreported
and Unregulated Fishing (IPOA-IUU)
this is the pertinent standard for trash
fshing and will be elaborated in the
subsequent sections of this report.
5.1.1 The development of IPOA-IUU
Il l egal , unreported and unregul ated
fshing, (IUU) is a concept which has gained
widespread use in recent years (FAO, 2001).
Overfshing and irresponsible fshing activities
have led to marine resources depletion as
well as damaged aquatic biodiversity and
environment. In addition, IUU fshing also entails
socio-economic impact. Overexploited fshing
causes a decline in fsh stock which in turn
affects the size and quality of marine catches,
leading to lower proftability and job losses.
Moreover, IUU fshing brings about an unfair
competition between those players following the
rules and those who do not.
International laws and regulations on IUU
fshing have been widely discussed for decades.
Initially, the term IUU had not been clearly
defned; onl y i deas and measures were
discussed. These have been developed into
guidelines and enhanced into more concrete
regulations many decades later (Chanrachkij et
al., n.d.).
Food and Agriculture Organization of the
United Nations (FAO) has played a leading role
in promoting international efforts to address
and combat IUU fshing and was the frst
organization to defne IUU fshing (Chanrachkij
et al., n.d.). An international effort to prevent,
deter and eliminate IUU fshing stemmed
from the Rome Declaration (1999) on the
Implementation of the Code of Conduct for
Responsible Fisheries, which states that all
countries would develop a global action plan to
fght IUU fshing. This provided the framework
f or FAO t o devel op and expound t he
International Plan of Action to Prevent, Deter
and El i mi nat e I l l egal , Unreport ed and
Unregulated Fishing (IPOA-IUU) (Chanrachkij
et al., n.d.; Kongrawd, 2006).
55
IPOA-IUU was adopted in 2001 to address
many problems that emerged from IUU fshing.
It encourages countries to develop regional plan
and national plan of action to combat IUU fshing
in order to establish sustainable fsheries.
However, IPOA-IUU is a voluntary non-legal
binding instrument; it acts as a toolbox for all
countries to adapt and design their measures
to meet their situations (Chanrachkij et al., n.d.;
Kongrawd, 2006). Problems regarding IUU
fshing are complex and multi-faceted due to the
differences in marine biodiversity, environment,
and socio-economic situations in any particular
country. Therefore, it is impossible to design
one-size-fts-all IUU Fishing guidelines that can
work everywhere; the instrument must be
adjusted to respond to specifc circumstances
(Chanrachkij et al., n.d).
Fi shi ng i n st at es wat ers has been
monitored and controlled by each coastal states
laws and regulations, and the state can fully
enforce its laws on IUU fshing. However, there
are many economic species in the high seas
where state-level law is inapplicable. For this
reason, IPOA-IUU suggests that regional
organization play a leading role in designing and
executing measures for sustainably managing
marine resources and combating against IUU
fshing (Chanrachkij et al., n.d). Regional
Fisheries Management Organizations (RFMO)
was mentioned for the frst time in the United
Nations Convention on the Law of the Sea 1982
about the collaboration between 2 coastal
states in managing marine resources. Thailand
is a member of The Asia-Pacifc Fishery
Commi ssi on
17
(APFIC), the RFMO that
monitors fshing areas where the largest share
of world marine products comes from. APFIC
as a regi onal organi zati on pl ays rol e to
st r engt hen fsher i es management and
conservati on i n the regi on by provi di ng
technical support and development guidelines.
It acts as an advisory body for RPOA-IUU,
which was endorsed in the Meeting of Ministers
responsible for fsheries from 11 participating
countries, including Thailand (DoF, n.d.). RPOA-
IUU covers the area of Southeast Asian region
including the South China Sea, Sulu-Sulawesi
Seas (Celebes Sea) and the Arafura-Timor Seas
(APFIC, 2007).
According to APFIC Strategic Plan 2012-
2018 (2012), the overall objective of APFIC is
to promote regional arrangements and regional
processes in order to improve responsible
fsheries and aquaculture in the region. It works
through the regional consultative forum where
member countries, regional fsheries and
aquaculture organizations gather to identify
emerging issues in fsheries sector. During the
period 2005-2012 APFIC has addressed key
issues for every 2 years which covers:
1) Co-management in fsheries; Low value/
trash fsh (2005-2006)
2) Certifcation in aquaculture & fsheries;
Capacity management and reduction of
IUU fshing (2007-2008)
3) Livelihoods & ecosystem approach
(2009-2010)
4) Use of assessments for i mproved
management & addr essi ng t he
implications of climate change in the
APFIC region (2011-2012).
In addition, there are numbers of regional
technical projects APFIC coordinates with FAO
which have resulted in capacity building
acti vi ti es i n the vari ous areas; namel y,
strengthen management of fsheries, raise
awareness on cl i mat e change i mpact s
adaptation and mitigation related to fsheries
and aquaculture, contribute to combating IUU
fshing, promote reduction of fshing over-
capacity, etc (APFIC, 2012).
At a national level, APFIC assists its
members to develop National Plan of Action to
Prevent, Deter and Eliminate Illegal, Unreported
and Unregulated Fishing (NPOA-IUU). This is
in accordance with FAO guideline that encour-
17
Current members of APFIC are Australia, Bangladesh, Cambodia, China, France, India, Indonesia, Japan, Malaysia, Myanmar,
Nepal, New Zealand, Pakistan, the Philippines, Republic of Korea, Sri Lanka, Timor Leste, Thailand, United Kingdom, United
States of America, and Vietnam (APFIC, 2014).
56
ages all states to establish NPOA-IUU. FAO
suggested procedures for nations to effectively
develop NPOA; for examples, a nation should
review their fsheries policy and agreement,
improve cooperation between states agencies,
evaluate marine resources and IUU fshing.
Currently, Thailands NPOA-IUU is under
drafting process and expected to be complete
in 2014
18
. This does not mean that IUU issues
have been neglected; measures to combat IUU
concerns were included in countrys fsheries
roadmap called Marine Master Plan, which
covers the period of 10 years from 2009 to 2018.
That IUU fshing might threaten export of marine
products to the EU was the underlying reason
that IUU issue was incorporated into the Plan
(Cabinet Resolution, 2009). This has led to the
development of catch certifcate scheme, and
subsequently the implementation of logbook
report and measures to promote vessel and
fshing gear registration (see 5.3.2). Moreover,
the Marine Master Plan has recommended that
outdated Fisheries Act B.E.2490 be revised so
as to be in line with current fshing activities (see
5.3.1) (Ministry of Agriculture and Cooperatives,
2010).
5.1.2 The defnition of illegal, unreported
and unregistered fshing activities
Accordi ng t o Kongrawd (2006), t he
defnition of IUU fshing has developed through
many discussions at an international level; for
example, United Nations General Assembly
(UNGA), Food and Agriculture Organization
Committee on Fisheries (FAO-COFI), and UN
Commission on Sustainable Development.
The defnition of IUU fshing adopted by the
International Plan of Action to Prevent, Deter
and Eliminate IUU Fishing (IPOA-IUU) is as
follows (FAO, 2001):
Illegal Fishing refers to activities:
- conducted by national or foreign vessels
in waters under the jurisdiction of a State,
without the permission of that State, or in
contravention of its laws and regulations;
- conducted by vessels fying the fag of
States that are parties to a relevant regional
fsheries management organization but operate
in contravention of the conservation and
management measures adopted by that
organization and by which the States are bound,
or rel evant provi si ons of the appl i cabl e
international law; or
- i n vi ol at i on of nat i onal l aws or
international obligations, including those
undertaken by cooperating States to a relevant
regional fsheries management organization.
Unreport ed fshi ng ref ers t o fshi ng
activities:
- which have not been reported, or have
been misreported, to the relevant national
authority, in contravention of national laws and
regulations; or
- undertaken in the area of competence of
a relevant regional fsheries management
organization which have not been reported or
have been misreported, in contravention of the
reporting procedures of that organization.
Unregulated fshing refers to fshing activi-
ties:
- in the area of application of a relevant
regional fsheries management organization that
are conducted by vessels without nationality, or
by those fying the fag of a State not party to
that organization, or by a fshing entity, in a
manner t hat i s not consi st ent wi t h or
contravenes the conservation and management
measures of that organization; or
- in areas or for fsh stocks in relation to
which there are no applicable conservation or
management measures and where such fshing
activities are conducted in a manner inconsistent
with State responsibilities for the conservation of
living marine resources under international law.
18
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (4 December 2013).
57
Overall, IUU fshing refers to the acts of
fshi ng t hat obst r uct , vi ol at e, or har m
conservation management measures. This
included an act of noncompliance and false or
falsifed report. IUU fshing can be conducted
not only by large commercial vessels but also
small coastal vessels and in any waters both
high seas and states water. Therefore, in an
attempt to combat IUU activities, action plan and
measures need to be adjusted to various
circumstances at different levels; namely
international level, regional level, and national
level (Chanrachkij et al., n.d.).
5.1.3 The European Union regulation
to combat IUU fshing
The EC IUU Regulation is the outcome of
the European Commission efforts to combat
IUU fshing. The European Commission has
applied the Council Regulation (EC) No.
1005/2008 on September 29, 2008 in order to
establish an EU system to prevent, deter and
eliminate IUU fshing. This regulation is directly
driven by the FAO IPOA-IUU adopted in 2001
and likewise contains the objective to fght
against IUU fshing to ensure sustainable
harvesting of marine resources. The IUU
Regulation applies to catches made from
January 1, 2010.
According to the Handbook on the practical
application of Council Regulation (EC) No.
1005/2008 (2009), the IUU Regulation aims to
prevent, deter and eliminate IUU fshing
activities in any maritime waters relating to the
European Community through trade fows,
or the fag of fshing vessels, or the nationality
of operators. After the EUs IUU regulation
was adopted (hereinafter referred as IUU
Regulation), information of this new instrument
and advises of future implementation were
given to all third countries through various
seminars and meetings. The regulation is
transparent and non-discriminatory between
European communi t y and t hi rd-count ry
fsheries. The instrument is applied to all fshing
vessels, under any fag, in all marine waters,
t hat pr oduct s ar e t r aded wi t h t he EU
community or communitys vessels involved in
IUU fshing.
The I UU Regul at i on i s a vol unt ary
instrument providing general requirements in
which countries can adapt to suit their particular
challenges. It relies on the responsibility and
commitment of third countries. A catch certifcate
scheme was adopted to ensure full traceability
of all aquatic fshery products traded with the
EU community. This is a core part viewed as a
tool to assist in the control and compliance of
the regulation. To affrm that none of products
in the EU Community market is sourced from
IUU fshing, catch certifcate is required for
marine products exported to the Community. On
the other hand, the catch certifcate scheme
may also apply to products exported from the
EU, if certifcate is required by the country of
destination.
5.2 Standards on trash fshing at an
international level
There are 6 most popular international
standards in the area of marine feed ingredients
including the Marine Stewardship Council
(MSC), the Aquaculture Stewardship Council
(ASC), the IFFO Global Standard Responsible
Supply of Fishmeal and Fish Oil (IFFO RS), the
Global Aquaculture Alliance Best Aquaculture
Practice (BAP), the Global G.A.P. standard, and
the Friend of the Sea (FOS) (IFFO, 2012). All of
these six standards are applied on a voluntary
basis, but the certifcation process is audited,
i.e. not self-report by producers.
5.2.1 Marine Stewardship Council
The MSC is the most widely recognized
and the worlds largest standard to certify
sustainability in wild-caught fsheries (Seafsh1,
2012). On a voluntary basis, the MSC uses it
certifcation process and blue eco-label to
infuence consumers choices. The certifed
label will assure that fsh products come from
sustainable and well-managed sources (MSC,
2010).
58
The MSC environmental standard for
sustainable fshing and MSC chain of custody
standard for seafood traceability are at the core
of the program. The sustainable fshing standard
is only applied for wild-captured fsheries not to
farmed fsh. Fishery will be assessed against
three principles including sustainable fsh
stocks, minimizing environmental impact, and
effective management. Once a fshery has been
certifed, companies who wish to sell product
from certifed fsheries must have MSC Chain
of Custody certifcation and apply for eco-label
bef ore usi ng. To get Chai n of Cust ody
certifcation, businesses must be examined that
they have effective traceability, storage and
record-keeping systems. This helps to prevent
illegally-caught fsh from entering the seafood
supply chain and ensure that fsh sold with
the MSC eco-label comes from a certifed
sustainable fshery (MSC1, 2014). Currently,
there is neither certifed fshery nor fshery in
assessment under MSC system in Thailand
(MSC2 and MSC3, 2014).
5.2.2 Aquaculture Stewardship Council
The Aquaculture Stewardship Council
(ASC) was found in 2010 by World Wildlife
Fund (WWF) in cooperation with the Dutch
Sustainable Trade Initiative (IDH). The main
objective is to enhance responsible aquaculture
through a global set of standards and to promote
the best environmental and social practices in
farmed seafood. The standard covers fsh farm
and crustacean, for which each different species
has its own standard (IFFO, 2012). Similar to
MSC, ASC develop its label to infuence
consumers choices and assure they are buying
responsibly farmed fsh, crustaceans and
shellfsh. Once a fshery has been certifed, ASC
chain of custody helps ensure that products
delivered in the supply chain originate from
ASC-certifed farms. So far, there is neither
certifed farm nor farm in assessment under
ASC in Thailand; therefore, there is no certifed
supplier in the chain of custody standard (ASC1
and ASC2, 2014).
ASC is currently developing a feed standard
to promote Envi ronmental l y Sound and
Socially Responsible Feed in the Global
Aquaculture Industry (ASC3, 2014). This has
begun in the second quarter of 2013 and the
approval is projected by the end of 2015. The
output will be a single ASC Feed Standard
that is applicable globally to all types of
aquaculture feed production facilities and usable
by all certifcation programs. The following
outcomes are expected (ASC4, 2014):
1) A more environmentally sound and
socially responsibly produced feed for
aquaculture
2) Stronger market-based incentives for
more envi ronment al l y sound and
socially responsible feed production
3) An i mproved sourci ng of the feed
components, using ingredients from
credible certifed sources.
5.2.3 The certifcation standard for the
Responsible Supply of Fishmeal and Fish
Oil
The cer t i fcat i on st andar d f or t he
Responsible Supply of Fishmeal and Fish Oil
(IFFO RS) is designed to certify responsible
practice in raw material sourcing, and fshmeal
and fsh oil manufacturing both for direct human
consumption and for animal feed usage (IFFO,
2012). The standard contains three essential
component s of r esponsi bl e sour ci ng,
responsible manufacturing, and responsible
traceability, which are key eligibility criteria to
become certifed (IFFO1, 2014).
To be certifed, a fshmeal and fsh oil
factory must be able to demonstrate that it
responsibly sources its raw materials showing
where all its raw materials come from. Fish
products must be sourced from well managed
fsheries
19
. The factory then must be able to
prove that it has full and effective traceability
system. For responsible manufacturing, the
factory must implement systems demonstrating
19
Sustainable fsheries are fsheries managed according to the FAO Code of Conduct for Responsible Fisheries. One way to
demonstrate this is to use a fshery that has been certifed by the MSC.
59
20
Shrimp products can bear a mark with up to 4 stars (for feed mills, hatcheries, farms, and processing plants), while marks on
packaging for other species including salmon, mussels, other fnfsh and crustacean have up to 3 stars (since BAP standards
for hatchery facilities have not yet been developed) (GAA3, 2014) .
good manufacturing practices, such as FEMAS
and GMP+ (IFFO, 2012).
The IFFO Assured certifcation mark has
been developed to represent compliance to the
IFFO Standard. At present, IFFO members
include producers, traders, feed companies,
edible oil refners, retailers, fnancial institutions,
gover nment al and non- gover nment al
organizations in more than 30 countries. Its
members account for over 50% of world
production and 75% of the fshmeal and fsh
oil traded worldwide (IFFO2, 2014). There are
currently 103 factories in 9 different countries
that have been successfully certifed to the RS
standard including Peruvian Anchovy and
Alaskan Pollock, two of the largest sustainably
managed fsheries (IFFO3, 2014). Currently,
there is neither approved IFFO RS factory
(IFFO4, 2014) nor a certifed chain of custody
unit in Thailand (IFFO5, 2014). However,
Charoen Pokphand Foods and T.C. Union
Agrotech are members of IFFO (IFFO6, 2014).
5.2.4 Best Aquaculture Practices
Best Aquaculture Practices (BAP) is an
audited certifcation standard for hatcheries,
farms, processing facilities and feed mills
developed by the Global Aquaculture Alliance
(GAA) to promote the use of responsible
aquaculture practices. The BAP standards
address environmental and social responsibility,
animal welfare, food safety and traceability in a
voluntary certifcation program for aquaculture
facilities. The BAP program outlines standards
for each type of facility as follows (GAA1, 2014):
1) BAP Seafood Processing/Repacking
Plant Standard
2) BAP Seafood Processing Plant Standard
3) BAP Finfsh and Crustacean Farm
Standard
4) BAP Salmon Farm Standard
5) BAP Mussel Farm Standard
6) BAP Shrimp Hatchery Standar
7) BAP feed mill Standard
BAP standards are also illustrated on retail
packaging ranging from 2-star to 4-star
20
.
Four-star status refects top level in the BAP
program, signifying that the marine product is
produced from BAP-certifed at all four facilities;
that is from BAP-certifed hatcheries through
BAP-certifed farms, processed at a BAP
certifed processing plants, and aquaculture
feed used is produced from a BAP-certifed feed
mills (GAA, 2011).
According to the BAP feed mill Standard
(GAA, 2010), certifed feed mill must fulfll
requirements regarding fshmeal and fsh oil
conservation in order to be certifed. It requires
a feed mill to indicate feed fsh ingredients on
products labels, packaging, shipping documents
or invoices for all feeds produced under the BAP
program. The feed mill must also obtain
declarations of species and fshery origins from
suppliers, keep full traceability record of feed,
and must implement effective procedures to
separate feed produced under BAP from other,
non-BAP feed.
For future standard, it requires that:
1) (Future critical standard.) After June 1,
2015, at least 50% of the fshmeal and fsh oil
derived from reduction fsheries shall come from
approved certifed sources.
2) (Future critical standard.) After June 1,
2015, at least 50% of the fshmeal or fsh oil
derived from fshery by-products such as
trimmings and offal shall come from approved
certifed sources.
Currently in Thailand, there are 29 BAP-
certifed processing plants, 34 certifed farms, 8
BAP-certifed hatcheries, and 6 BAP-certifed
feed mills (BAP4, 2014). Charoen Pokphand
Foods (CPF) and Thai Union Frozen Products
(TUF) are the onl y two compani es that
60
announced they have achieved BAP 4-star
status (BAP1, 2014). There are 7 Thai
companies certifed BAP 3-star (BAP2, 2014),
and 6 companies certifed BAP 2-star (BAP3,
2014).
5.2.5 Global Good Agricultural Practice
(Global G.A.P)
Global G.A.P standards are intended to
assure consumers that food is sustainably
produced by mi ni mi zi ng envi ronment al
impacts, reducing chemicals use, and ensuring
a responsible practice to animal welfare and to
worker health and safety. The standards certify
Good Agricultural Practice in agricultural and
aquaculture products. There are currently six
different standards within Global G.A.P which
are (seafsh2, 2012):
1) Integrated Farm Assurance (IFA) -
including a module for aquaculture
2) Compound Feed Manufacturing (CFM)
- covering feeds for both livestock and
aquaculture
3) Livestock Transport (LT)
4) Plant Propogation Material (PPM)
5) Risk Assessment in Social Practice
(GRASP)
6) Chain of Custody
According to the List of Certifed Compound
Feed Manufacturi ng Compani es as of 8
February, 2013 (GlobalGAP1, 2013), three
animal feed companies in Thailand, namely
Thaiunion Feedmill, Charoen Pokphand Food,
and Krungthai Feedmill, have certifed CFM
standard. However, as of February 2014,
only Charoen Pokphand Food is certifed
(Gl obal GAP, 2014) under thi s standard;
Thaiunion Feedmill and Krungthai Feedmill
certifcates have expired since June 2013 and
August 2013 respectively (GlobalGAP1, 2013).
5.2.6 Friend of the Sea
Friend of the Sea was founded to promote
the conservati on of the mari ne habi tat.
The organizations most well-known project is
the Dolphin-safe Project which has been able
to save millions of dolphins from dying in tuna
nets. This program is considered by some
observers to be the starting point of sustainable
seafood movement. Friend of the Sea label was
created to assure that the products were
produced and sourced sustainably; therefore,
consumers can make their choices. Certifed
products comprise products originating from
fsheries and aquaculture, covering food fsh
and widely traded species, fshmeal, fshfeed,
and Omega-3 fsh oil. However, requirement
regarding fshmeal used in aquaculture has not
been addressed (Friend of the Sea1, 2014). The
frst and only Thai seafood product approved for
Friend of the Sea label is wild-caught Meretrix,
under Panapesca brand by Thai Spring Fish
(Friend of the Sea2, 2014).
5.2.7 ASC, GAA, and Global G.A.P.
agreement on responsible sourcing of
fshmeal and fsh oil
Aquaculture Stewardship Council (ASC),
Gl obal Aquacul ture Al l i ance (GAA) and
GLOBAL G.A.P. have announced and signed
a joint Memorandum of Understanding on
common requirements for sourcing of fshmeal
and fsh oil (FMFO). This will harmonize
requirements between certifcation schemes
and can be considered as the frst step towards
their mutual goal to improve aquaculture
pr act i ce. The t hr ee par t i es i dent i fed
crosscutting elements covered in all three stand-
ards. Thi s hel ps feed compani es when
consider to get engaged in one or more of
these standards. Sourcing requirements
of FMFO under the three standards are
summarized in the following picture. The
identifed common criteria are (GlobalGAP,
2013; SeafoodSource, 2013):
21
Thai Spring Fish is a subsidiary company of the PanaPesca Group (http://www.friendofthesea.org/public/catalogo/Check-
list%20FoS%20Wild%20Catch%20Fisheries%20-%20Thai%20Spring%20Fish%202010%2006%2029.docx)
61
Figure 33: Requirement for Sourcing of fshmeal and fsh oil of BAP, ASC, G.A.P.
l
50% MSC or IFFO RS certifed
by 2015 for both fsheries and
industrial by-products;
l
Use material from Fisheries
Improvements Projects
when available.
l
100% MSC (or ISEAL) certifed
by 2017;
l
IFFO RS fshmeal up to 2017
(Pangasius only_;
l
Fishsource score 6 with no
individual < 6.0 or N/A in stock
assessment category
l
No CITES
l
Traceability to speces and country
of origin;
l
No endangered species (IUCN red
list) used for fshmeal/-oil;
l
Preference for feed manufacturers
with evidence of responsible
sourching;
l
Avoicance of IUU
l
Report % FAO CCRF compliant (e.g. MSC or IFFO RS
certifed) for fsheries origin;
l
3
rd
party accredited certifed origin for industrial by-
products.
l
Clear written plan for
responsible sourcing;
l
Free of undesirable substances
(food safety related).
Requirements for sourcing of fshmeal and fsh oil (from whole fsh and fshery by-products)
NOTE: AN ASC requirements included at form level standards, most BAP and GLOBALG.A.P. requirements
included as feed mill standards.
BAP ASC
GLOBALG.A.P.
Source: http://www.thefshsite.com/uploads/fles/news/gaa%20-%20Copy.gif
1) Traceability to the species and to the
country of origin.
2) No use of raw material sourced from
endangered species based on the
International Union for Conservation of
Natures (IUCN) red list for fshmeal
and fsh oil.
3) Avoidance of fsh sourced from illegal,
unreported and unregulated fshing
(IUU).
4) Preference for feed manufacturers with
evidence of responsible sourcing.
62
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67
5.3 National regulations and standards
5.3.1 Thai fsheries law
The Fisheries Act, B.E.2490 (1947) is the
principal legislation on fshery industry in
Thailand. The Act has been amended twice in
1953 and 1985. It not only established baseline
regulation for the registration and licensing
of fshing equipment, but also empowers
competent authority to regulate types of fshing
techniques. In addition, the Act requires permit
for those engaging in fshing operation. The Act
comprises six chapters, covering the areas of
fsheries management and conservation,
aquaculture, registration and application for
permission, collection and fxation of fsheries
tax, fsheries statistics, and penalties.
1) Management measures under the
Fisheries Act
In order to handle depleted fsheries
resources, management measures have been
designed and implemented under Thai Fisheries
Act. According to the national fshery sector
overview conducted by FAO (2009), key fshery
management measures are as follows:
l
Area and seasonal closures
Initially, area and seasonal closures are
imposed to recover important economic marine
species; such as the Indo-Pacifc anchovy.
Various regulations have been implemented
since 1984; for example, from 1 February to 31
March and from 1 April to 15 May, trawlers and
purse seiners using gear with mesh size
smaller than 4.7 cm have been prohibited from
fshing in the upper southern area of the Gulf of
Thailand.
l
Gear Restrictions
To preserve coastal resources, trawlers and
push net are prohibited within 3,000 m. from
shore since these gears are very destructive
especially operated inshore. This is because
they catch trash fsh, a large portion of which
are juveniles of economically valuable species.
In additions, repeated dragging of trawlers
may damage benthic habitats and demersal
resources.
l
Limited Entry
In an attempt to control numbers of trawl
and push nets, in 1980 Department of Fisheries
announced a protocol requiring trawl and push
net to be registered and form then no more
licensed would be issued. Therefore, only those
trawlers and push netters with licenses could
annually extend their fshing licenses. The
licenses are transferable only to fshermens heir
and are not applicable if gears have been
changed.
2) Shortcomings of Thai fshery law
Thai fshery is facing a severe overfshing
crisis. Aquatic animals have been harvested at
a faster rate than their replenishment, resulting
in a continuously decline in capture fsheries
(Apaipakdee, n.d.). Competition for marine
resources has been more severe since coastal
neighboring countries proclaimed Exclusive
Economic Zone (EEZ)
22
, which resulted in
Thailands loss of 300,000 sq. mile access to
fshing area (Apaipakdee, n.d.; Panjarat, 2008).
Moreover, Thailand has lost its direct access to
high seas from the Gulf of Thailand; some
medium and large Thai vessels, without a
l i cense, i l l egal l y passi ng nei ghbor i ng
countri es EEZ were frequentl y arrested
(Apaipakdee, n.d.; Panjarat, 2008; FAO, 2009).
Not only competition among commercial
fshermen became more severe, but also
confi cts between commerci al and l ocal
fshermen arose (Apaipakdee, n.d.).
Intense competition is exacerbated by
ineffective and improper fsheries law and
regulations. The Fisheries Act was drawn up
before the development of marine fsheries.
22
Myanmar and Vietnam in 1977, Cambodia and the Philippines in 1978, Indonesia and Malaysia in 1980
68
There have been signifcant changes in fshing
activities during the past 66 years, such as an
increase in the number of vessels and fshing
gears capacity. Therefore, the Fisheries Act
B.E.2490 is considered inappropriate in the
following aspects:
l
Outdated regulations and problems of
enforcement
It is necessary to make change in regulations
in response to those changes in fshing activities
so that the government authorities are armed
with proper instruments for effectively handling
and regulating fsheries (Karnjanakesorn and
Yen-Eng, n.d.). According to Panjarat (2008),
the Fisheries Act does not effectively respond
to present situation of marine capture regarding
the development of fshing gears and methods.
An increasing catch capacity of vessels and
gears, a declining in fsh stock, and an ineffcient
control over destructive fshing gears and
equipment, especially mesh size of trawls
(Apaipakdee, n.d.), have led to a capture of
increasing proportion of trash fsh including
juvenile economic valuable species. As of March
2014, Department of Fisheries is conducting a
research on impact from increasing minimum
trawl mesh size from 2.5 cm. to 4 cm.
23

Moreover, because legal fshing ground in
each province is not clearly demarcated and
well-known, fshermen are likely to misuse
licensed destructive gears (Madadam, 2012).
The most recognized consequence is the
damages trawlers made on sea foors and local
fsheries in the coastal area
24
.
The outcome of such outdated regulations
is that damaging fshing practices such as
bottom-trawling for trash fsh is not yet illegal in
Thailand. In addition, penalties including fne
and imprisonment are not suffciently stringent
(Apaipakdee, n.d.; Madadam, 2012). Perhaps
most importantly, every violation of fsheries law
is only considered a violation if the wrongdoer
is caught in the act.
25
For these reasons, there
have always been instances of legal violations
and illegal fshing.
l
Barriers to participation
The present Fisheries Act empowers
Minister of Agriculture and Cooperative and
Provincial Governor to regulate and enforce
fshery related activities (Karnjanakesorn and
Yen-Eng, n.d.; Artisanal Fishermen Association
of Thailand, 2011). It does not allow local
fshermen as key stakeholders to participate in
the fsheries resources management and
establishment of fsheries law (Panjarat, 2008).
This has led to a limited acceptance by fshermen,
contributing to violation of regulations and
conficts among stakeholders. Decentralization
by empowering local organizations in fsheries
administration, management and development
will help improve marine resource management
by monitoring and controlling of illegal acts
(Association of Thai Fisherfolk Federations, 2011).
3) Draft of the New Fisheries Act
Having been the main regulatory apparatus
for decades, the existing Fisheries Act is con-
sidered outdated and inadequate for some of
the reasons outlined above (Madadam, 2012)
and is agreed among stakeholders that it should
be revised (IOM, 2011). There have been many
efforts to draft and adopt new fsheri es
legislation. The latest attempt as of February
2014 has resulted in a draft of the new fsheries
act whi ch modi fes i nappropri ate and/or
outdated content as summarized in Figure 35.
Of all the proposed changes, clearer
demarcation of legal fshing grounds, as well as
defned authority to mandate type, number, size,
and components of allowed fshing gear and
fshing methods in each area, should fnally help
make damaging practices such as trash fshing
by bottom-trawling illegal in Thailand.
23
Problems and Future Management of Local Fishing Communities Conference at Department of Fisheries, 21 February 2014.
24
Notifcation of Ministry of Agriculture and Cooperatives, Subject: Prohibited area of motorized fshing vessels using trawl nets
and push nets usage (1964).
25
More specifcally, Clause 57 in the Fisheries Act stipulates that the authorities must fnd all three of the following components
at once at the time of arrest: fshing boat, fshing gear, and catch. In other words, violators must be caught in the act.
69
Figure 35: Key features of Fisheries Act 1947, compared to draft of the new fsheries act
The Fisheries Act, B.E.2490 (1947) Draft of the new fsheries act
1. Fishing Ground and Fishing Methods
Fishing area is not clearly identifed, leading
to the confict between commercial fsheries
and coastal (artisanal) fsheries.
l
Fishing ground is divided into 3 areas:
coastal fsheries area, offshore fsheries
area, and inland fsheries area.
l
Minister or provincial governor has the
authority to mandate type, number, size,
and components of allowed fshing gear,
fshing methods, and no-fshing seasons in
each area.
2. Promoting and Controlling of Aquaculture
There have been problems relating to aqua-
culture; high chemical usage and mangrove
forest intrusion. However, promoting and
controlling of aquaculture has not been stated
on the Act.
Principles relating to aquaculture promotion
and control are established.
3. Hygienic Control
Contaminated export aquaculture and its
related products have been detected,
resulting from an absence of clear standard.
Impose catch and post-catch standards for
aquaculture.
4. Public Participation
Lack of cooperation among stakeholders in
fsheries management.
Department of Fisheries shall play a leading
role in promoting cooperation among
stakeholders as well as supporting
community-based fsheries management.
5. National Fisheries Policy Commission
-not mention- National Fisheries Policy Commission,
which comprises Minister of Agriculture and
Cooperation, as a chairman, and committees
from related parties from both private and
public sectors, works as policymaker
managing and controlling fsheries.
6. Penalties
Fine and imprisonment are imposed to those
violating the Act.
- Fine from 50 Baht to 20,000 Baht.
- Imprisonment from 1 month to 6 years.
Increase the severity of penalties to
- Fine from 5,000 Baht to 600,000 Baht.
- Imprisonment from 1 month to 6 years.
Source: Department of Fisheries, cited in Madadam (2012)
70
Pri or to parl i ament di ssol uti on on 9
December, 2013, draft of the new fsheries act
has passed two readings at the commission
level; it is only pending the third and fnal
reading, which is the vote in the senate. Since
the parliament has been dissolved, Council of
State will compile pending draft laws and will
propose to the new government and parliament,
whenever Thailand has a new parliament, to
consider. As of March 2014, the Department of
Fisheries has notifed the Council of State of its
intention to submit this draft law to the senate.
26
5.3.2 Control of IUU fshing
Thailand has developed National Plan of
Action to Prevent, Deter and Eliminate IUU
Fishing (NPOA-IUU) in accordance with IPOA-
I UU t o preserve mari ne resources and
subsequently achieve sustainable fsheries.
However, Thailands NPOA is still in drafting
process and expected to be complete in 2014
27
.
At present, there are three state unit involving
in fshery management in Thailand; namely, 1)
Department of Fisheries, Ministry of Agriculture
and Cooperation, 2) Department of Marine and
Coastal Resources, Mi ni stry of Natural
Resources and Environment, and 3)Marine
Depart ment , Mi ni st ry of Transport and
Communication. These units collaboratively
monitor and control illegal, unreported and
unregulated fshing in the country (Jantrarotai,
2013).
1) Control of illegal fshing
Currently the Thai authorities combat illegal
fshing via three methods: enforcement of laws
and regulations, vessel registration, and fshing
permit and licensing.
l
Fishing under Thai laws and regulations
All vessels fshing and cultivating marine
animals in Thai waters must comply with the
law, rules, regulations, and conditions approved
and i mposed by the state. The pri nci pal
legislative mechanism for fsheries activities is
the Fisheries Act, B.E.2490 (1947). The Act is
governed by the Ministry of Agriculture and
Cooperation and executed by Department of
Fisheries, which is the main government
agency responsible for managing fshery.
According to Jithlang (n.d.), other fsheries law
and regulation related to combating against IUU
fshing include Navigation in Thai Waters Act,
B.E.2456 (1913), and Thai Vessel s Act,
B.E.2481 (1938). Other regulations include
Notifcation of Ministry of Agriculture and
Cooperatives, Notifcation of Department of
Fisheries, and RFMO
28
regulation.
l
Vessel registration and vessel license
Vessel registration and vessel licensing are
issued by Marine Department. According to Thai
Vessel Law
29
, all motorized vessels and above
6 GT non-motorized vessels require vessel
registration (Department of Fisheries, 2009).
Vessel registration certifcate is a lifetime
certifcate indicating registration number, state
fag, vessel ownership, and the vessels physical
characteristics. Vessel license identifes vessel
type and usage, name of certifed vessel crew,
as well as the locations of permitted sailing
water. The license must be renewed annually.
Department of Fi sheri es of Thai l and
collaborate with Marine Department to establish
persuasive measures to encourage vessel
registration, namely registration fee reduction
for small vessels (less than 14 meters or less
than 20 GT), which mostly are local artisanal
vessels. In addition, registered vessels are
entitled for natural disaster compensation
30
.
26
From a conference Problems and Future Management of Local Fishing Communities at Department of Fisheries (21 Febru-
ary 2014)
27
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (4 December 2013).
28
Regional Fisheries Management Organizations are international organizations working towards sustainable fsheries manage-
ment in a particular region (European Commission, 2013).
29
Thai Vessels Act, B.E.2481 (1938) section 8
30
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (4 Dec 2013).
71
Figure 36: Vessels registration process
Vessel owner
receives Certifcate of Vessel
Registration
Vessel owner
File an application with document
support
Vessel owner
Fill application form (Kor 5, Bor57)
Marine Department/
Vessel Standard Bureau
Vessel inspection
Vessel Standard Registration
Certifcate of Vessel
Registration/ Vessel license
Source: Department of Fisheries (2009) and Jithlang (n.d.)
The Department of Fisheries has set a vessel registration target to register 40,000 fshing
vessels within four years (2010-2013). This target accounts around 70% of total fshing vessels in
Thai water
31
; however, the number of registered vessels has not reached the target as shown in
Figure 37.
Figure 37: Number of registered Thai fshing vessels, 2010-2013
Fiscal year
Number of registered vessels
Goal Result %
2010 7,000 4,356 62.23
2011 11,000 7,350 66.82
2012 11,000 6,631 60.28
2013 11,000 1,521 13.83
Total 40,000 19,858 49.65
Source: Marine Fisheries Research and Development Bureau, Department of Fisheries
31
A survey by Marine Fisheries Research and Development Bureau in 2011 indicated a total of 57,141 fshing vessels operating
in Thai water both the Gulf of Thailand and Andaman Sea.
Despite failing to meet the goal, Department
of Fisheries has decided to continue setting
annual target of 11,000 vessels for 2014. It is
worth noting that the problem of inconsistent
data has arisen from the lack of cooperation
between government agenci es, namel y
Depar t ment of Fi sher i es and Mar i ne
Department. The number of fshing vessels
operating in Thai water individually collected by
each unit is unmatched which led confusion to
72
the EU inspecting offcials. For this reason, MOU
on information sharing, particularly on vessel
registration, was signed by both units in 2013
32
.
l
Fishing permit and fshing license
To legally engage in fshing operation,
fshing permit and fshing license are required.
These are issued by a competent offcial
Department of Fisheries. According to the
Fisheries Act 1947, permit refers to license
issued to a person to fsh and to cultivate
aquatic animals in the reserved fsheries and
license refers to license issued to a licensee to
use fshing implement . A person is permitted to
use fshing license only when the license in
his name has been issued and the fshery tax
has been paid. Each fsherman is allowed to
use a specifc type of fshing gear, out of 12
categories, that is indicated in a fshing license.
Fishing information and the validity of a license
commence annually from April 1 to March 31 of
the following year (Fisheries Act, 1947).
There are 3 types of fshing gears that are
restricted; their renewal will only be issued to
those fshermen enti tl ed i n the previ ous
harvesting season. These include trawl nets,
push nets, and anchovy lift nets which are
recognized as highly destructive gears.
32
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (4 Dec 2013).
33
Reserved fsheries are fsheries in which a person has been permitted to fsh or to cultivate aquatic animals, and include
trapping pond (the Fisheries Act 1947).
34
Fishing Implement includes machinery, instrument, accessories, component parts, arms, stakes, or vessels used in fshing (the
Fisheries Act 1947).
Figure 38: Process of acquiring fshing license and fshing permit in Thai waters
Vessel owner
Existing fshing license (if any)
- Thai nationality, ID card
- Thai Domicile
- Power of Attorney
- Copy of vessel registration certifcate
- Copy of vessel license
- Names of crews who are allowed to
use the fshing gear
Fisheries District Ofce
Document check
Submit to the District Chief
Record and collect fee
Fishing License (Aor 1) and Fishing Permit (Aor 6)
Source: Jithlang (n.d.)
73
Apart from compl yi ng wi th l aws and
regulations, fshing activities are not legal under
Thai law unless both fshing vessel and fshing
gear are legalized, by registering vessel and
acquiring fshing license (Aor 1) as mentioned
above. For less than 14-meter fshing vessels,
mostly local artisanal vessels, vessel registration
and fshing license are not necessary in case
fshing permit (Aor6) has already been acquired.
2) Control of unreported fshing
In an attempt to control unreported fshing,
Thai authority has adopted a fshing logbook
scheme as part of fsheries regulations. It is
used to facilitate and encourage report of fshing
conduct; in other words, to eliminate unreported
fshing. A fshing logbook is used to record
information relating to vessels and catch. It
needs to be endorsed by a vessel master then
submitted to the authorities
35
of the vessels fag
state. In addition, a fshing logbook is necessary
for an exporter since it is required to obtain a
catch certifcate in the frst place. Data collected
in a fshing logbook are as follows (Department
of Fisheries, 2009 and Prompoj, 2011);
a. Fishing Vessel Registration (indicating
vessels name, registration number, and
size of vessel)
b. Fishing License Number
c. Type of Fishing Gear
d. Fishing Ground/Area
e. Fishing Duration
f. Port of Departure/Arrival (indicating date
for departure and arrival)
g. Species/quantity of catches
h. Certifed by Vessel Master
There are 6 types of fshing logbook
classifed by types of fshing gear; 1) Fishing
logbook for trawler and push net, 2) Fishing
logbook for purse seine, 3) Fishing logbook for
gill net, 4) Fishing logbook for lift net, 5) Fishing
logbook for trap, and 6) Fishing logbook for
other gears (Prompoj, 2011). Statistics of fshing
l ogbook Mari ne Fi sheri es Research and
Development Bureau has distributed to and
received from registered fshing vessels are
shown in Figure 40.
35
Fishing logbook shall be submitted to one of twenty-two Department of Fisheries Coastal Provincial Offces or Fisheries
Inspection Offces at ports (Bangkok, Ladkrabang, Songkhla, Samutsakorn, and Ranong).Fisheries Act 1947).
Figure 39: Process of acquiring fshing license and fshing permit in overseas waters
Vessel owner
Fill application form
Existing fshing license (if any)
- Thai nationality, ID card
- Thai Domicile
- Power of Attorney
- Copy of vessel registration certifcate
- Copy of vessel license
- Agreement of contract for fshing in
the oversea water
- Fishing License for vessels which
authorized by other countries
Fisheries District Ofce
Document check
Submit to the District Chief
Record and collect fee
Fishing License (Aor 1) and Fishing Permit (Aor 6)
Source: Jithlang (n.d.)
74
Figure 40: Number of fshing vessels receiving and returning fshing logbook from 2010-2013
Fiscal year
Number of fshing vessels
receiving fshing logbook
Number of fshing vessels
returning fshing logbook
2010 3,589 2,082
2011 2,061 1,549
2012 1,462 1,573
36
2013 291 355
Total 7,283 5,559
Source: Marine Fisheries Research and Development Bureau
36
Number of fshing vessels returning logbook can exceed those of receiving since the logbook paper is not an annual basis.
37
A person violating fsheries law is only to be caught in the act of committing an offence
38
From an in-depth interview with Chief of Songkhla marine fsheries suppression and prevention center
39
This is mainly applied to food fsh which is an important product exported to the EU. However, it is a crucial starting point that
later expanded into a fshmeal certifcate scheme.
40
Some marine products are excluded from the scope of the EC IUU Regulation (Handbook of the EC IUU Regulation, 2009).
3) Control of unregulated fshing
Unregulated fshing essentially involves
wi t h fshi ng i nconsi st ent wi t h l aws and
regulations or that conducts in any area where
no measures, l aws, and regul ati ons are
applicable. This can be controlled by effective
moni tori ng and survei l l ance system; for
exampl e, offshore patrol s and l i censi ng
schemes (Kongrawd, 2006). In doing so,
Department of Fi sheri es establ i shed 12
fsher i es suppr essi on and pr event i on
centers, including 7 centers for freshwater
fsheries and 5 centers for marine fsheries
(Department of Fisheries, 2014). Songkhla
marine fsheries suppression and prevention
center is responsible for monitoring and
regulating fsheries in lower-southern GoT
of 136.6 kilometers. Main obstacles to control
of i l l egal conduct s compr i se r esour ce
insuffciency, including human resource and
fnancial resource, and limitation of fsheries
law
37
(as stated in 5.3.1)
38
.
5.3.3 Compliance to the EU Require-
ments: Thailand catch certifcate scheme
The EC IUU Regulation applies 1) to all
marine fshery products, both processed and
not, that originates from third country fshing
vessel and exported to the EU Community; and
2) to products originating from EU Community
fshing vessels exported to third countries
(European Commission, 2009). Thus, Thailand,
as an exporter, needs to comply with the IUU
Regulation
39
. Suppliers need to provide
certifcate of marine product
41
demonstrating
that the raw material is sourced in compliance
with EU regulation on IUU fshing (European
Parliament, 2013). The EU requires each fag
state to establish Competent Authority to control
fshery and aquaculture products and their
production chain. This was designated to the
Department of Fisheries of the Ministry of
Agriculture and Cooperatives. Its powers and
responsibilities include access to premises
and al l documentati on rel ated to fshery
pr oduct i on, t he suspensi on of expor t
certifcation, the removal from the list of
establishments approved to export to the EU
and t he possi bi l i t y of sei zi ng product s
(European Parliament, 2013).
Since catch certifcate scheme is a key
instrument to exclude IUU products from the
markets and to promote responsible fshing, an
essential part of this scheme is traceability of
product supply chain. Accordingly, Thailand
75
41
Food and Veterinary Offce carried out an audit on fshery products (including live bivalve molluscs) and monitoring of residues
and contaminants in live animals and animal products.
Catch Certifcation scheme has been in practice
since January 1, 2010. Three procedures have
been exercised to ensure full traceability of
aquatic fshery products and three documents
from each procedure are required when apply
for a catch certifcate (Department of Fisheries,
2009). Fish Inspection and Quality Control
Division is the offcial controller of this scheme
(Prompoj, 2011).
Required documents under catch certifcate
scheme include:
a. Fishing Logbook to record information
relating to vessels and catches (as
mentioned earlier).
b. Marine Catch Transshipping Document
(MCTD) i ndi cat es t rans-shi ppi ng
information, signed by fshing vessels
and carrier vessels.
c. Marine Catch Purchasing Document
(MCPD) demonstrates purchasi ng
information including vessels, catches,
and sellers/buyers along the supply
chai n from fshi ng vessel s to the
processors.
According to European Parliament (2013),
Thai fshery products were audited by Food and
Veterinary Offce in 2011 and 2012. It was
observed that existing measures are insuffcient
in assuring that fsh products exported to the EU
are obtained, managed and processed in
authorized establishments. To address this
problem, Department of Fisheries as the
competent authority has informed the Thai
Frozen Food Association and Thai Food
Processors Association that only raw materials
obtained from EU-approved sources, caught
by EU approved freezer vessels that comply
with relevant EU legislation, can be exported
to the EU.
There is a number of other offcial standards
Figure 41: Catch Certifcate Scheme
Source: Prompoj, 2011
- Sign MCPD
when catch sold
Logbook
Daily upload
Issue a catch
certifcate
Apply for
a catch
certifcate
C
r
o
s
s
-c
h
e
c
k
w
ith
d
a
ta
b
a
s
e
n
e
tw
o
r
k
(3)
(3)
(4)
MCPD
EU
(4)
MCPD
Fishing
Vessel
Fish Collector
MCPD 1
- Authorized offcers validate
MCPD
- Receive a copy of recorded
fshing logbook and MCTD (if any)
(2) Sign and submit
recorded logbook and
MCTD (if any) when fsh
landed
Remarks : CC = Catch Certifcate
Logbook = Fishing logbook
MCPD = Marine Catch Purchasing Document
MCTD = Marine Catch Transship Document
(1) Provide
logbook to
fshermen
Fish Collector
MCPD 2
Factory A
-Database Network
Fishing Port
Fishery Provincial Offces
or Fisheries Inspection Offces
Fish Inspection
and Quality
Control Division
(CA Offce)
- validate information
in MCPD(s) and fshing
record from database
then issue Catch
Certifcate for the
processors/exporters
- record catch data from receiving recorded logbook
into DOF fshing record system database
76
compatible with EU legislation, including Notifcation of the Ministry of Public Health on Food
Labelling, Notifcation of the Ministry of Public Health on standard for some chemical contaminations
in foods, Notifcation of the Ministry of Public Health on veterinary drugs residues in foods, and
Notifcation of the Ministry of Industry on the list of hazardous substances. These standards are not
imposed specifcally on fshery and aquaculture products but rather on commodities and food in
general; however, they represent conformity and compliance of Thai legislation to EU requirements
(European Parliament, 2013).
There are 314 fsh processing establishments that comply with the above procedures and
approved by Department of Fisheries (as of November 13, 2013).
42
Currently 254 licensed fsh
processing plants, including freezing vessels, are authorized to export to the EU (August 28, 2013)
43
.
As of 2013, 126 Thai companies have been issued catch certifcate
44
. The number of catch certifcate
issued and quantity of marine products exported to the EU from 2010 to 2013 are as follows:
Figure 42: Amount of certifed marine products exported to the EU and number of catch
certifcate issued from 2010-2013
Fiscal year Certifed marine products
exported to the EU (ton)
Number of catch certifcate
issued
2010 23,317.35 3,254
2011 68,258.01 8,854
2012 57,245.78 8,510
2013 58,353.48 7,523
Total 207,174.61 28,141
Source: Marine Fisheries Research and Development Bureau
5.3.4 Fishmeal certifcate scheme in
Thailand
In 2013, the Department of Fisheries
established a separate certifcate scheme for
fshmeal production. This is mainly to assure
that the process of obtaining raw materials for
fshmeal producti on i s unharmful to the
environment
45
. The scheme involves players at
all stages along the fshmeal supply chain from
fshing vessels to feed mills. The scheme, frst
implemented on 1 July 2013, is a collaboration
of 5 organizations: Department of Fisheries,
Thai Fishmeal Producers Association, Thai
Feed Mill Association, Department of Livestock
Development, and the National Fisheries
Association of Thailand. The Department of
Fisheries plays lead role in facilitating the
system and validating all documents.
Similar to the catch certifcate scheme,
fshing vessels and fshing gears that seek
fshmeal certifcate need to be legal. This can
be done by registering vessels and acquiring
fshing license as mentioned earlier. Fishing
logbook is employed as a reporting measure
indicating origin of fsh, type of gear, type of fsh,
etc. Fi shmeal producers need to col l ect
documents demonstrating origins of raw
materials used in their fshmeal production.
42
http://www.fsheries.go.th/quality/DOF%12820list.pdf
43
https://webgate.ec.europa.eu/sanco/traces/output/TH/FFP_TH_en.pdf
44
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (26 November 2013).
45
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (26 November 2013).
77
There are 5 types of documents that
fshmeal producers need to collect. These
include Marine Catch Purchasing Document
Fi shmeal ( MCPD- FM) , Mar i ne Cat ch
Pur chasi ng Document ( MCPD) , Cat ch
Certifcate, Form A, and Form B. Whichever
documents fshmeal producers must collect
depends on the types of raw materials and
suppliers as follows:
1) Whole fsh (whether from vessels,
brokers, or piers) Fishmeal producers need to
request Marine Catch Purchasing Document
-Fishmeal (MCPD-FM) which demonstrates
fshing activities including types and amount of
fsh as well as fshing area.
2) By-product s (suri mi ) Fi shmeal
producers need to col l ect Mari ne Catch
Purchasing Document (MCPD) and document
form A, which indicates suppliers, types and
amount of fsh.
3) By- pr oduct s ( t una) Fi shmeal
producers need to collect a catch certifcate or
captains statement of imported tuna. And
document form B that illustrates processing
plants, types and amount of fsh, fshing area,
vessels and fshing gears used.
After that, Thai Fi shmeal Producers
Association will certify batch of fshmeal
produced from traceable raw materials and
i ssue a fshmeal cer t i fcat e. However,
practically, fshmeal producers will issue a
fshmeal certifcate by themselves on behalf of
the Association since the scheme is self-
reported. Then, fshmeal producers will submit
all documents to feed mills when delivering
products. Subsequently, feed mills will pass
those documents to Department of Fisheries for
validation. The process of fshmeal certifcate
scheme is demonstrated in Figure 43.
It is worth noting that the fshmeal certifcate
scheme i s a purel y vol untary measure.
Department of Fisheries is not an authorized
agent managing or governing the scheme, but
acts as facilitator by validating information with
its database. Feed mills must offer incentives
for players in their supply chain, from vessels to
fshmeal factories, to join the scheme. As of
March 2014, offering a price premium for
traceable products is the only incentive for
stakeholders to join the scheme
46
.
Between 10 June and 31 December 2013,
there was only one feed mill, namely market
leader Charoen Pokphand Foods (CPF) that
submitted documents and request Department
of Fisheries to help examine. There were 1,752
fshmeal certifcates from 26 fshmeal producers
submitted for verifcation which accounted for
the total of 29,724, 841 kilograms of fshmeal
(Figure 44).
46
From an interview with Marine Fisheries Research and Development Bureau, Department of Fisheries (26 Nov 2013).
78
Figure 43: Fishmeal certifcate scheme
Fish pier owner
(issue MCPD-FM)
Fishing vessel
Processors
(provide proofs of raw
materials sources)
Fishmeal producers
(issue MCPD-FM if purchase
directly from fshing vessels)
DOF
validate all documents by
checking with IUU database
(Information acquired from
fshing logbook)
Feed Mills
(Submit all document to
DOF for validation)
import
Catch certifcate/
captain statement
Document form A
+ copy of MCPD
Fishmeal certifcate
and MCPD-FM/
MCPD + form A/
Catch cec. + form B
MCPD-FM
+ form A,B
Submit
MCPD-FM
Document form B
+ copy of catch
certifcate of
captain statement
DOF: Department of Fisheries
MCPD - FM: for Marine Catch Purchasing Document - Fishmeal
Form A records amount of raw materials from trimmings (surimi)
Form B records amount of raw materials from trimmings (tuna), and foreign vessel information
Source: Department of Fisheries
Figure 44: Number of fshmeal certifcate (submitted for verifcation), amount of materials,
and amount of fshmeal by source of materials from 10 June 31 December 2013
Source of materials Fishmeal certifcate
Amount of materials
(kg.)
Amount of fshmeal
(kg.)
Wild-Caught 1,119 75,183,563 19,302,989
Offcuts from domestic
Surimi production
167 9,664,123 2,860,026
Imported offcuts from
tuna production
292 17,005,650 4,974,515
Other offcuts 171 9,289,366 2,542,671
Unidentifed 3 - 44,640
Total 1,752 111,142,702 29,724,841
Source: Marine Fisheries Research and Development Bureau, Department of Fisheries
79
Figure 45: Summary of various schemes
Objectives/Core ideas Responsible Unit Relation to IUU
P
l
a
n

o
f

A
c
t
i
o
n
IPOA-IUU To prevent, deter and eliminate
IUU fshing by Providing a
guidelines for all countries to
adapt and design their measures
to meet their situations
FAO, All states IUU terms as defned
by FAO 2001
RPOA-IUU To prevent, deter and eliminate
IUU fshing. Emphasize the
cooperation among member
states in monitoring and
managing marine resources
in the high seas
Member states IUU terms as defned
by FAO 2001
NPOA-IUU To prevent, deter and eliminate
IUU fshing by selecting suitable
instrument form IPOA-IUU and
adapt to specifc conditions.
Particular state IUU terms as defned
by FAO 2001
The EC
regulation
To prevent, deter and eliminate
IUU fshing. To exclude products
from IUU fshing from EU market
using catch certifcate scheme as
the main instrument.
EU community and
third countries traded
with the EU
IUU terms as defned
by FAO 2001
C
e
r
t
i
f
c
a
t
e

S
c
h
e
m
e
Catch
Certifcate
Scheme
Adopted by the EU community
to ensure full traceability of all
aquatic fshery products.
To affrm that none of products
appear in the EU market is
derived from IUU fshing.
EU community and
the third countries
traded with the EU.
Third countries
authorized agent
(Department of
Fisheries, Thailand)
IUU terms as defned
by FAO 2001
Fishmeal
Certifcate
Scheme
To ensure full traceability of
raw materials for Fishmeal
production. To assure
responsible sourcing of raw
materials.
Department of
Fisheries, Thai
Fishmeal Producers
Association, Thai
Feed Mill
Association,
Department of
Livestock, and the
National Fisheries
Association of
Thailand
IUU terms as defned
by FAO 2001. The
scheme is expanded
from a catch
certifcate scheme.
T
h
a
i

p
r
i
n
c
i
p
a
l

l
a
w
Thai
Fisheries
Act 1947
To regulate all fshing activities
in Thailand as the principal
legislation on fshery industry.
Ministry of Agriculture
and Cooperatives
Consistent with
IPOA-IUU guidelines
to review a countrys
fshery law and
regulations.
Draft of
the new
fsheries act
To update the Fisheries Act
Source: Marine Fisheries Research and Development Bureau, Department of Fisheries
80
5.3.5 A Roadmap for Sustainable
Development of Thailands Fisheries
Gi ven short comi ngs of t he exi st i ng
standards and regulations outlined above, Thai
Feed Mill Association is currently drafting a
roadmap for sustainable development of
Thailands fsheries. This is to further ensure
that supply chain and food production are
sustainable, i.e. fshmeal is made from legal and
responsible sources, not from trash fshing that
harm marine resources.
The drafting process is assisted by World
Wildlife Fund (WWF) and Sustainable Fisheries
Partnership (SFP). They proposed Fishery
Improvement Project (FIP) be initiated as a
guideline for the development of this roadmap.
Preliminary studies of the FIP are expected to
be compl eted i n February 2014 and be
discussed with all stakeholders. It will then be
developed into the roadmap which is projected
to be complete in July 2014 and subsequently
implemented in August of the same year.
The framework, guideline, and stakeholders
activities will be clarifed in the roadmap. This is
expected to lead Thai fsheries sector toward
sustainability within the next 5 years.
Al l st akehol ders are encouraged t o
participate in the FIP, especially eight major
seafood and food producer associations which
are major consumers of Thailands fshmeal
production. Other organizations that are
participating in this project include the National
Fisheries Association of Thailand, the Thai
Overseas Fisheries Association, the Thai
Fishmeal Producers Association, the Thai
Frozen Foods Association, the Thai Feed Mill
Association, the Thai Shrimp Association, the
Thai Tuna Industry Association and the Thai
Food Processors Associ ati on. These 8
organizations have signed the Memorandum of
Understandi ng (MoU) to j oi ntl y devel op
Thailands seafood manufacturing system
in November 2013 (Bangkok Post, 2014;
Manager, 2014).
81
ESTIMATES OF BIOMASS
DIVERTED TO FISHMEAL SUPPLY CHAIN
6.
6.1 Preamble
The term trash fsh travels poorly. In the understanding of FAO and fsheries biologists outside
of Asia, trash fsh are not synonymous with bycatch, low-value products or discards from a
fshery. For instance, in western countries the term refers to bycatch fsh that are either discarded
at sea or used primarily for livestock/fsh food, while in other countries (particularly in developing
countries) it covers low value fsheries products used for both livestock/fsh food and human food.
Thailand uses the term trash fsh (pla pet: :a.:e) only for marine products that are utilized for
animal feed. Fisheries offcers in Thailand may occasionally use the term low value fsh for those
fsh destined for processing prior to human use, or may class everything unusable as trash fsh
and fsh with any market value at all as food fsh or economic fsh. These low value fsh include
many species that are elsewhere designated as trash fsh. Bycatch itself means little in the modern
Thai fshery, since trawl fshermen do not target specifc stocks (e.g. shrimps) and everything can
be sold; nothing at all is discarded.
Fisheries researchers quite often refer to several categories of product being sold by commercial
boats that traditionally have been grouped collectively as trash fsh. Note that only the frst one is
prevalent overseas:
l
Bycatch fsh that are frequently unsaleable even in good condition (they are
regarded as unpalatable or not worth the effort) this is the category reported in the
FAO literature as low value or trash fsh;
l
fsh (including crustaceans) of commercial species that are unsaleable because they
are damaged or degraded by poor post-capture handling; and
l
the mashed-up detritus of fsh, crustaceans and other marine biota that coats the
back of the cod-end of the net after a prolonged trawl.
pla pet

Our researchers found only the last two

categories of fsh and other biota that are too
damaged or degraded for either fresh markets
or for sale to food processors collectively
known as pla pet in Thailand are universally
synonymised with trash fsh in Thai fsheries
literature and general vernacular.
That i s t o say, nei t her Thai l and s
Department of Fisheries offcers nor local
peopl e i n Thai l and recogni sed the frst
category (undesirable or unpalatable species)
by the term trash fsh. Any catch statistics
reported by the Department of Fisheries in
the past decade or so refer to the lower two
categories of degraded product (particularly the
last). This has not always been the case.
Tossapornpitakkul et al. (2008) suggested
that around 61.5% of what was termed trash
fsh could be construed as true trash fsh (:a
.:e.- ), while the remainder was composed of
juveniles of economic fsh, but this distinction
was not particularly evident in the current study.
82
The fshermen can reliably sell virtually any
landed marine species of any size/maturity in
good condition to the fshball processing
factories either locally or in the major distribution
markets (e.g. Mahachai in Samut Songkram),
so referring to a product as food fsh or
economic fsh, is nowadays the same as
saying it is not pla pet.
The variance in usage may have resulted
from a mistranslation of the sense of the slang
word trash into Thai or more likely it may
have mutated over the years (as the fshery has
become more Mal thusi an) to mean onl y
degraded and damaged product. The usage
i s a cruci al vari ance f rom i nt ernat i onal
understanding of what constitutes trash fsh
sensu strictu, however, and fundamentally
changes the interpretation of Thai fsheries
statistics. To reduce confusion, we will use the
Thai term pla pet in its native sense henceforth
to refer to the entire proportion of catch that is
unsuitable for human consumption, without
regard to species or stage of maturity.
Figure 46: Pla pet condition in Songkhla
Figure 46. Fish that have degraded into noticeable putrescence by poor storage or handling during transpor-
tation are highly valued by the fshmeal factors because of the high protein content, but are a relatively minor
component of the pla pet market. However, it is an unpredictable resource and does not appear on fsheries
statistics as pla pet. (Image S Piromvaragorn)
In presenting the following results, it is worth noting that the published results of Department
of Fisheries surveys and research literature indicate that the composition of fshing boat landings
at Songkhla varies throughout the year, with the effects of the monsoon on both community
composition of the fshed populations and the locations fshed by the fshermen. This is consistent
with expectations of a trophically-degraded system where catchable stocks are heavily dependent
on stochastic fuctuations in recruitment. An increasing proportion of undersized fsh and
83
decreasing volume of commercially important
species in the composition of the wild fsh catch
in recent years suggest symptoms of biological
overfshing and loss of coastal habitat, declining
stocks, with concomitant falling profts of
individual vessels indicate that economically
overfshed fsh stocks threaten the viability of
wild fsheries in the Gulf (Ahmed et al. 2007,
Nasuchon & Charles 2010).
Figure 47: Reported fnfsh landings in the Gulf of Thailand
1985 1990 1995 2000 2005 2010
Year
L
a
n
d
i
n
g
s

(
t
o
n
s
)
1,500
1,000
500
0
total fsh
food fsh
trash fsh
Reported fnfsh landings in the gulf of Thailand
Figure 47. Landings of fnfsh abstracted from DoF reports, 1986-2011. The sharp rise in the early 1990s coin-
cides with the growing importance of the pelagic tuna fshery (only a fraction of which is actually captured in the
GoT). The circled area indicates the endpoint of a progressive reclassifcation of several species from trash fsh
to food fsh as the term trash fsh came to mean exclusively pla pet. This type of reclassifcation has occurred
several times over the past decades, and refects the process of fshing down the food chain as more desirable
species have become rare. The crash evident in the landings in the period after 2005 probably refects a tipping
point in the ecosystem towards a lower productivity system with a higher proportion of low trophic level species
caused by chronic overexploitation of demersal species. Part of this change may be explained by some Thai fshing
boats changing registration to Malaysia and Indonesia domicile, in order to comply with more stringent Malaysian
and Indonesian regulations. Note that these landings contain a variable (but impossible to separate) component of
fsh caught outside Thailands EEZ, but landed in ports such as Songkhla by courier boats.
There is a paucity of published data about the way the catch changes over the year, and the
fshermen range over a substantial portion of the Gulf of Thailand, meaning that the effects on the
local fsheries resource are quite hard to predict. Seasonal changes in population structure (the
proportion of juvenile fsh in the population) of the fshed resources is likely to change the proportion
of product landed by the fshermen that is unsalable in the fresh market, and is therefore likely to
have an effect on the proportion allocated to the surimi/fshball and trash fsh portions sold by the
fshermen. This is an important caveat to the generality of the results presented here, also; because
of the time constraints of the project, the data presented are merely a snapshot of the landings at
Songkhla.
84
It is likely, however, given the geographically
wi de hunti ng range of the fshermen we
interviewed, that any direct effects on resources
targeted by artisanal fshermen will be diffuse,
and will probably refect the overall decline in
fsheries resources of the Gulf of Thailand
evident in data published from recent years
by the Department of Fisheries. Payaotou &
Jetanavanich (1987, p44) stated: by 1973
the inshore catch reached 803,000 t which is
i ndi cat i ve of overfshi ng not onl y when
compared to the MSY but also when the
declining catches in subsequent years are
considered. Thailands fsheries have been
operati ng greatl y over thei r sustai nabl e
capacity for several decades, and the overall
t rophi c l evel of t he cat ch has decl i ned
substantially. This means the intense fshing
pressure has depauperised a previously
abundant resource; in recent years, despite an
increase in effort, the total catch has declined.
The effects of the commercial fshing are
noticed by artisanal fshermen for two main
reasons: the general decline in resource
abundance means that spawning stocks have
been depleted, so that the large pulses of
recruitment previously observed are no longer
occurring (this means, in turn, that the local
fshermen perceive the decline); secondly,
it means that the composition of the catch has
changed over time the high value food fsh are
no longer a dominant portion of the catch.
The pla pet itself is usually divided into
several categories, depending on its state of
degradation (or putrescence). Since the sale
price of fshmeal depends on both its protein
content, and its aroma, the lowest value pla pet
is purchased by the buyers only reluctantly,
since its putrescence will pervade any fshmeal
of which it is a component; generally, the buyers
prefer to purchase their production quota of the
Figure 48: Volume of marine fsh landed at Songkhla (Ta sa-aan)
Year
Figure 48. Fisheries data for Songkhla (Songkhla Department of Fisheries report, 2013). Note the precipitous
decline in fsh landings in the early part of the last decade (mirroring the decline seen in the previous fgure for
the entire Gulf of Thailand fshery), and the commensurate drop in effort (vessel trips) as returns diminished. The
crossover of food fsh and trash fsh landings in 2008 refects an overall decline in the quantities of fsh available
for capture and the enormously protracted trawl times common in the fshery.
85
better classes of pla pet, and offcuts. The
fshmeal producers purchase all available
categories of low value and pla pet, as well as
the offal and offcuts of commercial species that
are processed for sale or canning at the docks.
This last category (production waste) has
become an increasingly valuable proportion of
feedstock for fshmeal, but its availability is
severely limited.
Noteworthy however, are throwaway
comments by fshmeal production buyers about
the decline in both supply and quality of trash
fsh and pla pet in recent years once upon a
time the buyers would arrange to have several
trucks lined up to receive feedstock, and could
nominate the quality ahead of time; nowadays,
they complained, they were lucky to get enough
to start the processors on a given day, and had
to carefully adulterate the product with low
value (putrescent) pla pet to make up production
quotas. Some producers suggested that it was
no longer possible to consistently produce the
highest quality of fshmeal because the supply
of high quality trash fsh had diminished so
much. In recent years as the suppl y of
high quality feedstock has declined, and the
proportion of pla pet in the fshmeal supply has
become dominant.
The vessels observed unloading product at
the fshery pier of Songkhla were of two main
types: otter-board trawlers and courier boats.
The otter-board trawlers were operated by local
fshermen, but tended to operate far from the
home port seeking trawl grounds with the
highest returns within the southern Gulf of
Thailand. The courier boats were not engaged
in fshing (although they were built on the same
lines), but were mostly engaged in ferrying
product from large vessels operating offshore,
or outside Thailands EEZ. They landed
substantial amounts of trash fsh and pla pet,
but were not available for interview. The
workers at the landings described most of the
high value food fsh landed by such vessels as
ori gi nati ng i n Indonesi a (al though thi s
description was vague enough to simply mean
elsewhere than Thailand). There were
signifcantly more of these vessels unloading
at the port during the days our researchers were
present than local boats; this may refect a
change in the importance of the Gulf of Thailand
as a pri mary source of fsh l andi ngs for
Songkhla, but there is very little data available
one way or another.
The latest Department of Fisheries statistics
available (for 2011: http://www.fsheries.go.th/
i t - st at / year book/ dat a_2554/ Year book/
Yearbook2011-4.1.pdf) indicate that a total of
82,913 tons of marine fsh were landed at
Songkhla in that year (out of total marine
landings of 90,363 tons), 70% of which (57,783
tons) was classed as food fsh. This fgure
includes the product landed by the offshore
boats, however, and is not a refection of the
situation faced by fshermen in coastal waters.
Moreover, the breakdown of landings supplied
by the Songkhla Department of Fisheries offce
gave a slightly different story: they report that
total landings at Ta Sa-aan fshing port were
88,341 tons, comprised of 56,074tons of food
fsh, 7,082 tons of other economic biota and
25,185 tons of trash fsh (slightly more trash fsh
than reported by the Department of Fisheries
Yearbook data).
FD statistics indicate also that in 2011,
all the trashfsh landed, plus around one sixth
of food fsh were converted into fshmeal.
As previously mentioned, these statistics do
not distinguish between Gulf and Andaman
fsheries, nor do they distinguish between food
fsh caught specifcally to feed the fshmeal
industry (un-knowable) or surplus production
that was otherwi se unsal abl e at market
(essentially zero in all cases, since buyers from
other provinces bought whatever was available).
6.2 Data collection summary
PSU researchers interviewed the captains
of local Thai fshing boats unloading at the
fshing pier at Songkhla on three occasions (in
August and September 2013), completing nine
key-informant interviews regarding fshing
practices and gear. The boat captains were
86
i nformal l y engaged i n conversati on and
questioned about their vessel and gears
employed, (roughly) where and how they fshed,
and where they sold their product. The data
obtained in these interviews was checked
against published fsheries data to develop a
point estimate of the total effort and production
landed at Songkhla fshing port. The estimate
can only be applied to the period during which
interviews occurred, because (as noted) the
fshery varies during the year, according to
seasonal changes in conditions and stocks.
That being said, however, we believe it is valid
to make some broad assumptions based on the
material developed in this study.
The researchers also undertook detailed
analysis of the catch composition of the
products unloaded by 9 vessels (both the
August and September landings), concentrating
on t he composi t i on of t he component
designated trash fsh. Within the pla pet
samples, fnfsh were tabulated at family level,
where possible since many were juveniles and
hence diffcult to identify at a lower taxonomic
level. Fishes that were suffciently damaged
that they were not identifable to family level
were grouped as others. Other landed
products were i denti fed to broad bi oti c
category (e.g. crustaceans), or grouped into a
miscellaneous category (mostly composed of
various molluscs and echinoderms). Note that
the same caveat about seasonal variations in
catch composition already mentioned will also
apply to these data.
While at the landing site, the researchers
also informally interviewed the buyers who were
waiting to receive various products from the
fshing boats. They were asked about the
supply of pla pet, and invited to share insights
about the industry from their perspective.
Figure 49: The fsheries pier at Songkhla just before dawn (Image S. Arunrugstichai)
87
With the exception of a single vessel
interviewed in August, the vessels landing
product at Songkhla fshing port were landing
around 4 tons of commercial fsh per trip, after
spending anywhere between one and two
weeks at sea. This catch was supplemented
by roughly 6.5 tons of pla pet. All of the skippers
i ntervi ewed stated that thei r fshi ng was
conducted i n the vi ci ni ty of Mu Koh Kra
(an offshore group of islands in Nakhorn Sri
Thammarat province). The vessels were all
standard small otter-board trawlers (24-40m
in length, crew of 5-6, powered by 275-315HP
diesel engines, and deploying trawl nets with
10m gape), and represent a reasonable sample
of the types of medium-sized commercial fshing
vessels returning product to Songkhla at that
time of year.
The fshermen worked in pulses; for the
week before and after the full moon, nets were
deployed and trawled 24 hours per day, for 5-6
hours per tow. For the remainder of the month,
the trawlermen deployed their nets only during
daylight hours (again, generally in 6 hour tows),
because of changes in the diurnal behaviour
(and therefore catchability) of their target
species. The use of sonar technology was
pervasive: the fshermen would search for
bottom structure such as boulders or reefs, and
plan their tow-path to pass as close as possible
to the potential fsh attracting structure.
The fgures presented here represent an
average return on fshing effort (CPUE) of
approximately 49(17)kg/hour for the vessels
landing product in August and September. This
is almost three times the published Department
of Fisheries average CPUE for the far southern
region for 2011 (Figure 68). The disparity has
several interpretations: the region where all the
fshermen declared they were fshing (near Koh
Kra) is more than 50 kilometres from the
mainland, and is quite likely to be a different
ecological system from that sampled by the
Department of Fisheries. It may be that there is
a strong seasonal component to the catch and
capture rates for i nstance, the vessel
interviewed in August (Figure 65) had a much
higher proportion of economic fsh than trash
Figure 50: Results composition of landed product at Songkhla
Day fshing Commercial Fish Pla pet
14
12
10
8
6
4
2
0
14000
12000
10000
8000
6000
4000
2000
0
= August (single vessel interviewed)
= September (8 vessels interviewed)
Product landed at Songkla - Aug-Sept 2013
D
a
y
s

(
+
S
D
)
K
g

l
a
n
d
e
d

(
+
S
D
)
Figure 50. (LHS) average number of days spent actively fshing by vesels that offoaded product at Songkhla.
(RHS) average landings by category; note that while catch composition of the landings varied widely, on average
trash fsh composed 2/3 of the landed product, substantially more than is reported in Department of Fisheries sta-
tistics. Of the commercial fsh category perhaps 10% was composed of various species of squid and prawns, the
remainder being fnfsh.
88
fsh, in strong contrast to the September
landings. Because the Department of Fisheries
does not publish fgures refecting monthly
samples, it is diffcult not to believe that the
published Department of Fisheries fgures are
an amalgamation of many months sampling and
thus strongly average both catch rates and
composition. It is more likely, however, that the
fshermen surveyed in this study were fshing a
completely different ecosystem from the inshore
grounds routinely surveyed by Department of
Fisheries vessels, and that published capture
rates should be viewed with skepticism.
August was a month of very little activity
from the fshermen of Songkhla, many of whom
(being Muslim) greatly reduced their fshing
activity during Ramadan. It is possible that
this reduction in effort allowed the vessel
interviewed in this study to fsh with little
competi ti on, i ncreasi ng thei r CPUE and
proportional catch of food fsh, but it seems
unl i kel y. The phase of t he moon al so
infuences fshermens activity, such that many
choose not to fsh during the less productive
times, when they can only proftably fsh during
the daytime. The vessel we interviewed was
the only vessel to land product at the small pier
during that week, although the courier boats
unloaded at a rate of 4-8 per day. The rates of
capture and the effort described in the National
Department of Fisheries reports do not seem to
closely refect what this study observed at
Songkhla (although the Songkhla-originating
reports tally well, suggesting that the National
reports average and therefore mask substantial
regional variation).
Figure 51: Summary of catch statistics for the vessels interviewed for this study

Vessel Month Length Total Catch CPUE % Economic % Remarks
number of trip (kg) (kg/hour) fsh Trash fsh

1 August 14 18,720 56 67.9 32.1
2 September 7 10,160 60 21.3 78.7
3 September 7 12,000 71 50.0 50.0
4 September 9 14,400 67 30.6 69.4
Left their
5 September 14 14,800 44 32.4 67.6 product
with boat # 4
6 September 12 7,300 25 38.4 61.6

7 September 7 7,360 44 45.7 54.3 Left their
8 September 9 5,800 27 48.3 51.7 product with
9 September 7 5 Had engine trouble boat # 6
800

Source: vessels interviews
Figure 51. Summary of catch statistics for the vessels interviewed for this study. It is evident that groups of
fshermen operate cooperatively and that the resource is extremely patchy. Notwithstanding this, the Catch per Unit
Effort (CPUE) for all of these fshermen is between 2 and 3 times the catch rate stated by the Department of Fisheries
researchers using the same gear. Moreover, the relatively low proportion of trash fsh quoted by the Department of
Fisheries is realised only in one vessel (that fshed in August), suggesting a) strong seasonal variation in trash fsh
abundance relative to economic fsh, and b) the catch statistics used to represent Songkhla region are unlikely to
be accurate, since all of these operators were fshing around Koh Kra, offshore of Nakhon Sri Thammarat province.
89
Figure 52: Selections of pla pet found at port
Figure 52. a, b, d selections of pla pet identifed in the laboratory (after cleaning and fxation to prevent further
degradation); c Thai Department of Fisheries offcers from Songkhla regional offce identifying samples of pla
pet at the pie; e a typical basket of quite high quality pla pet unloaded from a trawler; f fsh heads that are
discarded by on-pier processors are eagerly sought by the fshmeal producers. (Images: a-d: W. Klagnurak, e: S.
Arunrugstichai, f: S. Piromvaragorn)
a b
c d
e f
90
Figure 53: Department of Fisheries Catch per Unit Effort (CPUE) fgures for 2010/11.
CPUE fgures by fshing ground in the Gulf of Thailand (Unit:kg/hr)
fshing ground 2010 2011 +/- %
1 24.800 19.814 (-4.986) (-20.10%)
2 19.282 16.950 (-2.333) (-12.10%)
3 13.372 9.480 (-3.892) (-29.11%)
4 11.469 13.090 1.621 14.13%
5 27.957 52.897 24.940 89.21%
6 29.292 48.650 19.358 66.09%
7 10.170 8.990 (-1.179) (-11.60%)
8 13.287 12.335 (-0.952) (-7.16%)
9 15.485 16.069 3.77%
Gulf of Thailand 18.559 25.015 6.456 34.78%
Figure 53. Highlighted area refects the putative fshing grounds of vessels landing product at Songkhla. Note
that published CPUE varies widely between years, suggesting that the resource is unstable. Note also the degree
of variation in capture rates between regions only the central regions (5 and 6) approach the CPUEs reported by
the Songkhla fshermen.
The composition of the pla pet varies widely, probably refecting the fshing practices of the vessels.
Figure 54: Composition of pla pet from a vessel offoading at Songkhla in August
OtherComposition of pla pet landed from vessel #1 at Songkhla (27/8/2013)
Figure 54. Composition of fsh categorised as pla pet from a vessel offoading at Songkhla in August. The other
category includes fsh that are damaged to unrecognisability and also some non-teleost biota.
91
Figure 55: Example composition of pla pet from a vessel offoading at Songkhla in September
Composition of pla pet from vessel # 4 (23-9-13)
Figure 56: Summary of the diversity of biota landed as pla pet in Songkhla in August and September
Average composition of pla pet in landings at Songkhla
92
57: Average species composition of the food fsh component of catches landed at Songkhla
Figure 57. Average species composition of the food fish component of catches landed at Songkhla.
The mix categories contain some duplicate names because the baskets often comprised a varied collection of
miscellaneous fsh cotaining a high proportion of juveniles, which were diffcult to identify in the time available (the
fshermen were understandably keen to shift the catch as rapidly as possible). Note, however, that the proportions
of some trash fsh families (see above) are signifcant in the total catch, and that many juveniles of economic species
also fnd their way into the pla pet bins.
93
Figure 58: A multispecies basket of fsh landed in Songkhla
Figure 58. A multispecies basket of fsh landed in Songkhla, bought by middlemen for sale to a seafood factory
via Mahachai market in Samut Songkram. Note that several of the species (and most of the size classes) would see
this basket classifed as trash fsh in countries such as Australia. (Image: W.Klangnurak)
Forecasting the amount of pla pet landed
at Songkhl a r equi r es some degr ee of
assumption about harvesting rates, fshermens
activity levels and seasonal variations in both
capture rates and catch composition. As is
demonstrated by the Department of Fisheries
statistics, such assumptions are inherently
fawed, and should only be used as a rough
guide to the behaviour of the system. From the
very limited data available, it would seem that
the volume of trash fsh caught by each vessel
is roughly similar both between vessels and
between months. However, the composition
of the catch, and the proportion of trash fsh in
landings varies quite strongly, both between
vessels and between months. The rate of
transfer of trash fsh to local fshmeal factories
appears to be highly variable, also, and very
diffcult to predict.
94
Figure 59: crustaceans, squids and fsh mashed together into unrecognizability
Figure 59. Crustaceans, squids and fsh mashed together into unrecognizability - up to 70% of the product of
Thailands trawl-capture fshery looks like this at landing. (Image S. Arunrugstichai)
Even so, it appears that the results obtained
in this rapid survey concur with previous studies
to a reasonable degree: the proportion of trash
fsh in the total catch is broadly similar to that
reported by Tossapornpitakkul et al. (2008) for
the same time of year. Likewise, the volume of
pla pet per vessel (averaging slightly more than
6 tons) coincides with Songkhla fsheries
records (roughly 4000 vessel-landings, for a
total of 25,000 tons of pla pet in 2012). The
elevated catch rates reported here may refect
the trend towards reduced fshing effort as
fshermen decide the returns from landing
mostly pla pet are insuffcient to pay for the fuel
and maintenance required to fsh constantly.
They are therefore pulse-fshing by targeting
higher-effciency strategies (such as 24hour
fshing days around the full moon, rest phases
when the moon is unsuitable).
Likewise, if these data are indicative of the
scale of variation in catches of economic fsh
(which seems plausible given the wide variation
in published Department of Fisheries fgures),
then it is reasonable to model the pla pet
component of the catch as mostly static, while
the economic fsh proportion supplies most of
the variation in landing volumes. Moreover, it
suggests that the proportion of food fsh in the
l andi ngs reported by the Department of
Fisheries is likely to be strongly buffered by the
offshore fshing industry which lands product
at Songkhla and by the extremely variable
supply of economic fsh during the remainder of
the year.
95
Figure 60: Ta Sa-aan Afterwards
Afterwards. Image: S. Piromvaragorn
6.3 Biomass analysis conclusion
Fi shmeal producti on for shri mp food
is probably not the primary driver of the decline
in artisanal fsheries in southern Thailand,
but it is certainly contributory. The trawler
fshermen do not distinguish between trash fsh
species and ruined fsh in their catch any
fsh catch in good condition is sorted out into
saleable categories and the ruined catch is
agglomerated as pla pet, and is kept only
because there is always a market for it.
Much of the reason for the high catch rates
of juvenile fsh in demersal trawls can be
explained by inappropriately fne mesh used in
the cod-ends of nets. The Thai Department of
Fisheries Master Plan suggests that 40mm is
an appropriate mesh size for demersal trawl
fsheries in the Gulf of Thailand. None of the
vessels surveyed here used mesh larger than
25mm, and most used 20mm or less. Push-net
fshermen use even fner meshed nets (as little
as 10mm) and frequently target areas utilised
as nurseries by many species of fsh and
crustaceans. Juveni l es of commerci al l y
valuable species and those important in food
security for local people are killed in large
numbers, wasting their potential.
The wastefulness of overly-fne mesh sizes
i s compounded by the use of l ong trawl
durations. Trawl times reported by the fshermen
here are extraordinarily long. The extreme
duration of tows (often 6 hours or more) means
that any product captured during the early part
of the tow (say, the frst few hours) is guaranteed
to be damaged or unsalable (i.e. ruined) and will
become pla pet, even if it is of commercially
valuable species. The pla pet coating the
cod-end of the net forms an inescapable
barrier to juvenile fsh. The very fne mesh used
by all vessels and the prolonged tow duration
means that very little escapes from the nets
96
during normal fshing, and also that a signifcant
component of what is caught will be smashed
into uselessness. That the fshermen reported
CPUEs far exceeding (up to three fold) those
reported by the Department of Fisheries
suggest s t hat l ong t rawl durat i ons are
compl etel y unnecessary, and l ower the
economic return by degrading the value of the
catch. While the time spent deploying and
retrieving the trawl net seems to be counted as
lost effort by many fshermen, the added value
of product that has not been pulverised and
rendered unsaleable by hours of being dragged
along the seafoor is likely to far outweigh any
lost productivity.
Bycatch reduction devices can reduce the
volume of juveniles and non-target species
captured by as much as 40% (Eayrs 2007,
Boopendranath et al. 2013). This is not seen as
a beneft by fshermen. However counter-
intuitive it seems to degrade the bulk of their
catch for minor increases in volume, the
existence of a ready market for pla pet means
that the fshermen have no inclination to install
bycatch reduction devices on their nets or in
any way reduce the waste component of their
catch.
Tossapornpitakkul et al. (2008) reported
that the average pla pet composition of catches
in Nakhon Sri Thammarat and Songkhla
averaged 42.08% of the annual capture for
small otter board trawlers such as those we
interviewed. These authors also suggested that
the catch composition changes throughout the
year (with pla pet being 40% of the catch in the
NE monsoon, 47% between the monsoons, and
40% during the SW monsoon). However, we
found an average of 62% pla pet in catches
landed in September, at the end of the SW
monsoon, with the possible exception of the
August boat discussed above. That is, more
than 2/3 of the fsh landed by local commercial
trawl fshermen in Songkhla during September
were smashed and degraded beyond the
possibility of being used for human food. This
represents a tremendous wastage of biomass
and ecosystem potential.
100% of pla pet landed at Songkhla could
be sold to fshmeal producers, as could any
other wasted or degraded product. This is a
potential supply of around 25,000 tons per year
of pla pet plus several hundred tons of offcuts
and spoiled products from seafood factory
production. However, most of the pla pet was
too decomposed to be used as feedstock for the
high grade fshmeal preferred for shrimp food
production, and very little low value product was
available for sale to the fshmeal factories. With
the steady decline in pla pet volume and
quality over the past decades as it moves ever
further from the international defnition of trash
fsh (and closer to the word garbage), it is
diffcult to imagine that the current shrimp food
production industry relies as strongly on local
production as it used to.
97
SUPPLY CHAIN OF FISHMEAL INDUSTRY
IN SONGKHLA AND ITS ACTIVITIES
7.
7.1 Supply Chain and
Stakeholders activities
So far, there are two studies on economics
of fshmeal production and market which
includes the supply chain of fshmeal industry
in Thailand: one by Bureau of Agricultural
Economics Research in 2012, and the other by
8 Regional Offce of Agricultural Economics in
2007. But, the latter is more specifc on fshmeal
industry in the upper southern region. However,
before going through the studies of fshmeal
supply chain in Thailand, this section will start
with the Peruvian fshmeal supply chain.
Figure 61 illustrates the Peruvian fshmeal
and fsh oil supply chain of Copeinca
47
. The
chain starts with the supply of raw materials
anchovy received from anchovy fshing. Then,
the fsh are sent to the fshmeal production
plants to be inspected, cleaned and cooked.
The outputs from this process are 22% of
fshmeal and 3.5% of fsh oil. After that they are
distributed through agents, representatives,
brokers, and direct sales. And fnally they are
sold to the markets for animal consumption
which can be divided into 58% aquaculture and
42% animal feed (IFFO, 2011 cited in Nordahl,
2011).
The supply chain of fshmeal in Thailand is
slightly different from that of Peru on three
aspects. First, Peru uses whole fsh as raw
materials for fshmeal while Thailand uses both
whole fsh and trimmings from fsh processing
manufacturers. Second, in Peru, fsh are
supplied directly to the fshmeal production
plant whereas in Thailand, unless it is the
fshmeal producers fshing boats, fshmeal
producers buy trash fsh from piers who act as
middlemen between the fshing boats and the
fshmeal producers. Lastly, outputs of Peruvian
production are fshmeal and fsh oil while in
Thailand, the output is only fshmeal with crab
shell meal as trimmings.
Figure 61: Peruvian fshmeal and fsh oil supply chain
Source: Copeinca, 2010 cited in Nordahl, 2011
47
Copeinca is a Norway-based company operating in fshing industry, producing fshmeal and fsh oil.
98
Figure 62 show the supply chain of fshmeal
industry in the central and eastern regions of
Thailand as studied by Bureau of Agricultural
Economics Research (2012). It shows that raw
materials for the fshmeal production come from
55.31% of whole fsh (trash fsh) and 44.69%
of trimmings, and that trash fsh is used to
produce not only the fshmeal but also fsh
sauce, fertilizers, and as baits in fsh farms.
After the fshmeal was produced, it is then sold
mostly to animal feed mills (94.85%), to farmers
(0.47%), to brokers (3.03%) who later sells it to
animal feed mills and exports it. Only 1.65% is
exported. This piece of research is the only one
that mentions export in the supply chain.
8
t h
Regi onal Of fce of Agr i cul t ur al
Economics conducted a similar research on
the economics of fshmeal production and
market of fshmeal industry in the upper
southern region in 2007. Fishmeal supply
chain studied in this research is separated into
two supply chains between Andaman Sea side
and Gulf of Thailand side. Both of them are
slightly different from the fshmeal supply chain
in the central and eastern regions as they do
not mention export in the supply chains, and
they do not show the distribution of trash fsh.
However, the big differences between them are
the percentages of trimmings used in the
fshmeal production. In the central and eastern
regions, trimmings are 44.69% of raw materials
while in the southern region, trimmings from fsh
processing manufacturers are used only as
1-3% of raw materials for fshmeal.
When comparing the supply chain of
fshmeal industry on Andaman Sea side with
that of Gulf of Thailand side, they are not very
different only slight changes in percentages,
and that fshmeal producers on Gulf of Thailand
side also buy trash fsh from brokers who collect
trash fsh from l ocal coastal fshermen.
The different percentages are the percentage
of trash fsh from fshmeal producers fshing
boats and the percentage of fshmeal sold to
brokers. On the Andaman Sea side, trash fsh
from the fshmeal producers boats account for
20.97% of raw material while it is only 3.34%
on the Gulf of Thailand side. This means that
fshmeal producers on the Andaman Sea side
own more fshing boats than those on the Gulf
of Thailand side. This is probably because there
are enough fsh worth operating their own
fshing boats.
Figure 62: Map of fshmeal supply chain in central and eastern regions of Thailand
Trash Fish 100%
Fish sauce 3%
Farmers 0.47%
Fishmeal
producers fshing
boats
Fishmeal
producers 92%
Brokers 3.03%
Animal feed
mills 94.86%
Fish processing
manufacturers
Export 1.65%
Piers 95% Fertilizers 1% Fish farms 4%
55.1%
44.69% 0.21%
Source: Bureau of Agricultural Economics Research, 2012
99
Figure 63: Map of fshmeal supply chain on Andaman Sea side
Fishing boats of
fshmeal producers
Fish procerssing
manufacturers
Fishmeal
producers
Crab shell meal
processing
factory
Crab shell
meal
t
r
i
m
m
i
n
g
s
Farmers
Others
Animal feed
Piers
20.97%
Trash fsh
77.69%
Trash fsh
1.34%
4.51%
0.01%
95.48%
Commercial
fshing boats
Local fshing
boats
Brokers
Source: 8 Regional Offce of Agricultural Economics, 2007
Figure 64: Map of fshmeal supply chain on Gulf of Thailand side
Fishing boats of
fshmeal producers
Fish procerssing
manufacturers
Fishmeal
producers
Crab shell meal
processing
factory
Crab shell
meal
t
r
i
m
m
i
n
g
s
T
r
a
s
h

f
s
h
Farmers
Others
Animal feed
Piers
Coastal
fshermen
3.34%
Trash fsh
92.11%
Trash fsh
3.4%
21.21%
1.15%
0.72%
78.07%
Commercial
fshing boats
Local fshing
boats
Brokers
Brokers
Source: 8 Regional Offce of Agricultural Economics, 2007
Supply Chain of Fishmeal Industry in Songkhla
Our understanding of the structure, activities, and market shares of fshmeal supply chain in
Songkhla is formed from the information received from both secondary research and personal
in-depth interviews with representatives of major animal feed mills, managers of fshmeal producers
in Songkhla, trash fsh brokers, and a pier owner. For the fshmeal producers, we interviewed 8 out
100
of 9 existing fshmeal producers that are
based in Songkhla. The supply chain is more
complicated and involves more players than
those written in A Study of Economics of
Fishmeal Production and Market under the
Quality Assurance System by Bureau of
Agr i cul t ur al Economi cs Resear ch and
Economi cs of Fi shmeal Producti on and
Market in Upper South Region in 2007 by 8
Regional Offce of Agricultural Economics,
Bureau of Agricultural Economics Research
which we have reviewed earlier in this chapter.
In short, the fshmeal supply chain in
Songkhla is formed from six links starting from
the fshery business who supply the raw
materials, to the middlemen at the pier (Pae
Pla), to the core of the chain fshmeal
producers, to the most infuential player in the
chain animal feed mills, to the users farmer,
and fnally to markets, both exports and
domestic. However, the main focus of this
research is the frst four links fshery business
to animal feed mills, so there will be no details
on activities of ffth and sixth link.
First link of the supply chain of fshmeal
industry in Songkhla is the fshery business
which supplies raw materials to the fshmeal
producers. There are two types of boats overall:
1) fshing boats and 2) transporting boats (tour
boats). Function of fshing boats is to capture
fsh while that of transporting boats is to provide
necessities e.g. foods, water, salt to the fshing
boats so that they can continue fshing without
returning to the port for the foods or water.
Meanwhile, the tour boats will transport catch
Figure 65: Map of fshmeal supply chain in Songkhla
Source: Interviews and analysis
101
back to the port to ensure that they are still fresh.
There are two types of fshing boats: 1)
local fshing boats and 2) commercial fshing
boats. The local fshing boats are smaller than
the commercial fshing boats, and usually run
by family members. They fsh within Thailands
maritime zone. All the catches land at the port,
and for trash fsh, they will sell them to brokers
who collect trash fsh from many boats to sell to
fshmeal producers. For the commercial fshing
boat s, some bel ong t o fsh processi ng
manufacturers or fshmeal producers, so they
suppl y al l t he cat ches t o t hei r owners
companies. For those that do not belong to
fshmeal producers, they will usually sell to
their regular customers. We estimate that
approximately 5,760 tons
48
of trash fsh that
were landed at Songkhlas port in 2013 went to
fshmeal producers in Songkhla (see Figure 35
for details).
Activities of fshery businesses
Their activities can be grouped into three
stages: 1) preparing 2) fshing, and 3) landing.
During preparing stage, fshing boat owners will
borrow money to fund their fshing trips and then
buy supplies for the trip including food, water,
ice, salt and gas. The next stage is fshing, in
which fsh is caught by various types of fshing
gears depending on target fsh. However, some
gears i.e. trawlers or push nets, catch everything
in their waves. In the sea, caught fsh will be
sorted by species, stored, and fermented. After
that, in landing stage, they will be transported
back and landed at the port.
Second link is Pae Pla or fsh piers and
brokers that buy fsh from the fshing boats.
Piers or Pae Pla here do not refer to a physical
structure of port, but rather refer to a type of
business that auctions fsh from the fshing boats
to re-sell; they act like a broker; however, they
also provide other services such as sorting and
cutting off the heads and separating the offal.
Activities of fsh pier (Pae Pla) and brokers
After the boats arrive at the port, economic
fsh catches will land at the port frst, and Pae
Pla will auction for the fsh they want. Then they
will sort the fsh by size, and in some case they
will cut the heads off for the customers. After
that they will sell the fsh to exporters, foreign
clients, anchovy producers, and seafood whole-
salers. Both anchovy producers and seafood
retailers will sell the trimmings such as fsh
head, fsh bones and gut s t o fshmeal
producers. After the auctions of economic fsh
is over, then Pla Rong-ngan or factory fsh
(whole fnish that is unpalatable) will be sold to
fsh processing manufacturers such as canned
fsh producers, or Surimi producers. For those
boats belonging to fshmeal producers, the fsh
will be sent directly to the mills.
Then, the fsh whose sizes do not meet the
standards of fsh processing manufacturers
but are still fresh are sold to fshball producers.
After that process, the fsh are sold to fsh
farmers. After all the factory fsh are landed,
trash fsh are fnally landed; they are the last to
land among all catch types, and are typically
segregat ed i n separat e l andi ng areas.
Remainders from factory fsh and trash fsh are
then sold together to fshmeal producers.
Brokers will collect undersized fsh, trash fsh
and offcuts, and sell them to fshmeal producers.
Third l i nk i s fshmeal producers. In
Songkhla, there are currently nine fshmeal
producers still in operation. In 2013, the top fve
players Thai Charoen Animal Feed, Pacifc
Fishmeal Industrial, Paesae Songkhla, Samila
Fishmeal, and Jana Fish Industries together
produce approximately 81% of Songkhlas total
fshmeal production of 29,300 tons
49
. Figure 66
shows the relative sizes of fshmeal producers
in Songkhla based on their productions from the
largest to smallest.
48
Interviews with fshmeal producers in Songkhla.
49
Interviews with fshmeal producers and their 2012 income statements.
102
The main raw materials used in fshmeal
production in Songkhla are trimmings from
fsh-processing manufacturers e.g. surimi, tuna
canning; fsh ball producers as well as anchovy
producers and fsh retailers at the markets which
accounted about 80% of the estimated total raw
materials of 100,215 tons, or 79,964 tons
in2013. Apart from this, fshmeal producers also
buy raw materials directly from commercial
fshing boats, as well as brokers who collect
trash fsh from local fshing boats from both
Songkhla and other provinces. This accounted
for 20% of raw materials or 20,250 tons. Of this
amount, 62% or about 12,609 tons were fsh
landed in Songkhla; the remaining 38% or 7,641
tons were fsh from other provinces such as
Satun and Pattani, as well as imported fsh.
Figure 66: Fishmeal producers in Songkhla, ranked from largest to the smallest
Fishmeal Producer
1. Thai Charoen Animal Feed Co. Ltd.
2. Pacifc Fishmeal Industrial Co. Ltd. 3. Paesae Songkhla Co. Ltd.
4. Samila Fishmeal Co. Ltd. 5. Jana Fish Industries Co. Ltd.
6. Songkhla Marine Products Co., Ltd. 7. Southern Fish Powder Factory 1969 Co., Ltd.
8. Sangcharoen Wattana Fisheries Co., Ltd.
50
9. Songkhla Fishery Trading Limited Partnership
Source: In-depth interviews
50
Since we could not interview Sangcharoen Wattana Fisheries, we estimated its relative size from the 2012 income statement
compared with other fshmeal producers.
Figure 67: Raw materials of fshmeal in Songkhla, 1999 2013, divided into trash fsh,
by-products and other fsh
Raw materials of fshmeal in Songkhla, 1999 - 2011
180,000
160,000
140,000
120,000
100,000
80,000
60,000
40,000
20,000
0
Years
Other fsh Trash fsh Byproduct
T
o
n
s
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
Source: Fishery Statistics Analysis and Research Group (FSARG), DoF, 2013
103
Among 12,609 tons of whole fsh landed in
Songkhla and went to fshmeal producers in the
province, 5,760 tons or 46% were trash fsh.
Thus, this means that of 25,000 tons of trash
fsh whi ch we esti mated to be l anded i n
Songkhlas port, only 23% went to fshmeal
producers in Songkhla; the remaining 77%
or 19,240 tons probably went to fshmeal
producers in other provinces. Accordingly, when
we incorporate data of raw materials used in
2013 with data from DoF, we get a raw material
chart of Songkhlas fshmeal producers as
shown in Figure 67.
Since raw materials are crucial to the
fshmeal producers, and wild-caught fsh
are rarer, off cut s f rom fsh-processi ng
manufacturers have played an important role.
Fishmeal producers that have fsh-processing
manufacturers as parent companies will be
supplied with trimmings regularly, so their
operations are more stable and predictable;
therefore, they can produce more fshmeal
than those that do not have fsh-processing
companies in the group. We also found that all
of the top fve players have fsh-processing
manufacturers as their parent companies or own
by the same major shareholders as shown in
Figure 68.
Of the total fshmeal produced in Songkhla
in 2013, 36.8% were #2B grade (surimi), 22.9%
were fsh head grade, 23.2% were #2 grade,
and 17.1% were #3 grade. This corresponds
with relative quality of fshmeal raw materials in
Songkhla as we mentioned earlier, in that the
main raw materials are by-products from
fsh-processing manufacturers.
However, if we look the grade of fshmeal
produced from Songkhla from the past, we fnd
that Songkhla fshmeal is #3 grade on average.
Due to the low quality of trash fsh, fshmeal
produced with trash fsh as main raw material
Figure 68: Relationships between top fve fshmeal producers in Songkhla and
fsh-processing manufacturers
Fishmeal producers
Fish-processing manu-
facturers
Relationships
Thai Charoen Animal Feed
Co. Ltd.
Chotiwat Manufacturing
Co. Ltd.
Four major shareholders of Chotiwat
Manufacturing hold 55% shares of Thai
Charoen Animal Feed.
Pacifc Fishmeal Industrial
Co. Ltd.
Pacifc Fish Processing
Co. Ltd.
All shareholders of Pacifc Fishmeal
Industrial are major shareholders of
Pacifc Fish Processing.
Paesae Songkhla Co. Ltd. Man A Frozen Foods Co.
Ltd.
Four major shareholders of Man A
Frozen Foods hold 96.92% of shares of
Paesae Songkhla.
Samila Fishmeal Co. Ltd. Siam International Food
Co. Ltd.
Samila Fishmeal holds 11% of shares
of Siam International Food, and fve
major shareholders of Siam
International Food hold 69.92%
of shares of Samila Fishemal.
Jana Fish Indutries Co. Ltd Songkhla Canning Co.
Ltd
One major shareholder of Songkhla
Canning holds 30% of shares of Jana
Fish Industries.
Source: Fishery Statistics Analysis and Research Group (FSARG), DoF, 2013
51
Sold grade fshmeal is the lowest grade of fshmeal usually produced from very bad condition trash fsh. The smell is very bad
and the percentage of protein is the lowest of all fshmeal. In Thai, it is called pla kai ().
104
is always #3 grade or lower (sold grade
51
).
If we look at historical trends of fshmeal raw
material usage both Songkhla and Thailand,
we observe that the percentages of by-products
have increased continuously, while whole fsh
usage including trash fsh has been declining
steadily. This confrms the trend shown in Figure
67 that from 2004 onwards, fshmeal producers
in Songkhla have shifted from trash fsh toward
by-products as the main raw material in fshmeal
production.
Among the top fve fshmeal producers, two
receive by-products from surimi producers, and
three from tuna canning manufacturers. The
differences between #2B and fsh head grade
are 1) freshness 2) percentage of protein 3) odor
and 4) percentage of fat. #2B fshmeal is very
fresh as it was produced from offcuts of fsh
used to produce surimi which is for human
consumption, so they are fresh and clean.
The trimmings from surimi producers usually
have fsh fesh with them, so they yield high
percentage of protein and low fat. Because they
are very fresh and clean, fshmeal produced
from them smells good. For offcuts from tuna
canning manufacturers, they are heads, guts,
and bones that were cut off the fsh and barely
had any fsh fesh left, so the percentage of
protein is lower than that of #2B while the
percentage of fat is higher because fsh heads
are full of fat. When compared with trimmings
from surimi producers, by-products from tuna
canning are less fresh, so the smell of fsh head
grade fshmeal is then not as good as #2B
grade.
Grading of fshmeal in animal feed industry
is more complicated than offcial fgures cited
earlier in Chapter 2 which divides fshmeal into
three grades. Figure 69 shows an example
of prices of fshmeal announced by CPF on
February 8, 2014. Please note that offcially CPF
is not the one who quotes the prices of fshmeal,
but because CPF is the largest fshmeal buyer
in Thailand, its prices are commonly used as
reference prices in both fshmeal industry and
animal feed industry.
Figure 69: Fishmeal prices at Bangkok market announced by CPF on February 8, 2014
Fishmeal
Former prices (Baht) Changes New prices (Baht)
January 28, 2014 (+/-) February 8, 2014
Shrimp grade protein 65% - 99.99% 31.80 + 1.50 33.30
#1 protein 60% - 99.99% 30.90 + 1.50 32.40
#1 protein 57% - 59.99% 30.70 + 1.50 32.20
#2 protein 60% - 99.99% 30.20 + 1.50 31.70
#2 protein 54% - 59.99% 29.20 0.00 29.20
#2B (Surimi) protein 58% - 99% 31.60 0.00 31.60
#2B (Surimi) protein 52% - 57% 29.30 0.00 29.30
#3 protein 60% - 99.99% 26.00 + 1.50 27.50
#3 protein 52% - 59.99% 24.80 + 1.50 26.30
Sold grade 15.30 0.00 15.30
Fish head grade protein 45% - 54.99% 28.10 + 1.50 29.60
Source: Thai Fishmeal Producers Association, 2014
105
A major difference between rough three
grades of fshmeal cited in Chapter 2 and 11
grades in Figure 69 above is that those three
grades are further subdivided into: shrimp
grade, #2B grade (surimi), sold grade, fsh head
grade, and #1-3 grades divided into upper and
lower. Percentages of protein require for #1-3
upper grade are all between 60%-99.99%. What
sets them apart is clearly not the percentage of
protein; it is the smell. The smell is the most
signifcant criteria in grading fshmeal, and it
usually correlates with TVBN (measure of
freshness), i.e. smelly fshmeal usually has high
TVBN. Smell of fshmeal will attract fsh, shrimp,
and livestock to eat the feed while percentage
of protein will affect growth rate, so the key
grading criteria are smell, protein, and TVBN.
Activities of fshmeal producers
Their activities can be divided into three
stages: 1) pre-processing 2) processing, and 3)
post-processing. In pre-processing, their
activities include buying criteria setting, supplier
screening, buying, raw materials receiving,
raw materi al s checki ng, and documents
checking
52
. Fishmeal producers will set buying
criteria based on grades of fshmeal they
produce, and after that they will screen suppliers
so that they get raw materials that meet their
criteria. Then, when they agree to buy, fshmeal
producers will send a truck to pick up raw
materials, but in some cases, suppliers will
deliver them at the fshmeal producers factories.
After that, they will check the quality of the raw
materials if they are as agreed or if they are
acceptable. Then, the documents will be
checked (for those who require documents).
In processing stage, the activities vary
depending on their operations whether they
produce fshmeal only or they also produce fsh
oil. This depends on their raw materials. If they
use a lot of offcuts, especially fsh heads that
are full of fat, they usually produce fsh oil. If
they produce fsh oil cooking and squeezing
process will be added. Trash fsh usage has no
effect on the operation even it is mixed up with
mud. But if the trash fsh is very mashed up
until it becomes liquid, solid raw materials must
be added so that they can be moved by a screw
conveyor to a cooker.
There are two types of fshmeal operation
system in Songkhla: steaming system and hot
oil system. The only difference between the two
is one uses steam in the drying process, and
the other uses hot oil. The rest of the operations
52
Only fshmeal producers that require documents e.g. MCPD
Figure 70: Fishmeal operation fow chart
Source: In-depth interviews and factory visits
Raw material receiving
Raw material checking
CookingSqueezing
Drying
Sieving
1st temperature reducing
Additive adding
Grinding
2nd temperature reducing
Quality checking
Mixing
Packing
106
ar e t he same. However, i n Songkhl a
steaming system is more popular; only a few
use hot oil system, and it is believed that
fshmeal produced by hot oil system can be
contaminated from substances in the oil.
Their operations start after raw material
received and checked for the quality of raw
materials i.e. freshness, and contaminants such
as rubber gloves. Then, they are moved by a
screw conveyor to a cooker (in case that they
will produce fsh oil) after that the cooked offcuts
are squeezed the liquid out. The liquid will be
piped to fsh oil operation, and fshmeal will be
transported to a dryer. If they do not produce
fsh oil, raw materials are transported to dryers
after they were received. When they are dried,
either by steam or hot oil, they will be sieved to
separate big bones, and then cooled. After that
additives are added, and fshmeal is ground and
reduced temperature again.
In post-processing stage, fshmeal will be
checked for its quality e.g. color, humidity, odor,
and mixed with other lots of fshmeal so that it
matches with a specifcation of each buyer. After
that it is packed and delivered to the buyers.
The fshmeal operation fow chart is shown in
the Figure 70.
Fourth link is animal feed mills. After the
fshmeal producers produce fshmeal, mostly
they will sell it to animal feed mills, and sell some
to farms that mix their own feed. Some will be
sold to brokers who add values by mixing
different grades of fshmeal and then sell it to
animal feed mills or farms. Animal feed mills
inspect the quality of the fshmeal and grade
them. If the fshmeal producers do not agree
with their inspection and are not satisfed with
the prices they offer, they have to bring the
fshmeal back and bare the transportation cost.
From our study of Songkhlas fshmeal
industry supply chain, we found that in 2013,
66% of fshmeal produced in Songkhla went to
animal feed mills, 24% were bought by brokers,
and the remaining 10% were sold to farms. And
the largest and most important buyer of fshmeal
in Songkhla is CPF because of 66% of fshmeal
sold to animal feed mills, CPF bought about
8,463 tons or 45%, and six out of eight fshmeal
producers said they sold their fshmeal to CPF.
The next largest buyer is Betagro buying 3,270
tons or 17% followed by Thaiunion Feedmill
(TFM, 51% owned by Thaiunion Frozen Foods)
and Lee Pattana at 2,052 tons (11%) and 1,680
tons (9%) respectively. Krungthai Feedmill only
bought 600 tons of fshmeal or 3%, while the
remaining 15% went to other small and medium
size animal feed mills.
5,760 tons of trash fsh could produce 1,527
tons of #3 grade fshmeal, of which 37.6% or
575 tons were sold to CPF, 42.7% or 652 tons
to brokers, and 19.7% or 300 tons to farms.
Nevertheless, CPF bought various grades of
fshmeal - #2, #2B, #3, and fsh head grade
from six fshmeal producers while other animal
feed mills bought only one or two grades from
a single or a couple of fshmeal producers which
are their regular suppliers. Summary of trash
fsh usage and map of Songkhlas fshmeal
industry supply chain with details is shown in
Figure 71.
Activities of animal feed mills
Activities in the pre-processing stage
include criteria setting, quality checking, and
document checking. First, each animal feed mill
will set the buying criteria such as the grades of
fshmeal , percentage of protei n, TVBN,
temperature, and contamination. They specify
the grades and the pri ces they wi l l buy
according to types of animal feeds they produce
as different types of animal feeds use different
types of fshmeal; for example, feeds for duck
may contain fshier fshmeal than other types,
whi l e pi gl et f eeds cannot use fshmeal
containing crab shell meals as it will hurt
stomachs of piglets. While livestock and poultry
feeds can use low protein fshmeal, aquaculture
feeds need high protein fshmeal, especially
shrimp feeds and feeds for fsh that eats meats.
Some animal feed mills may buy more fshmeal
produced from by-products as they want to
shift from bycatches to by-products that are
perceived to have less environmental impacts.
TFM, for example, has products which are zero
107
bycatch. These products, accounting for 33.5%
of the total, use fshmeal produced from
by-products only.
The second step is a quality checking
process. After fshmeal producers whose
fshmeal meet the criteria of the animal feed mill
and agree with the offered prices, fshmeal will
be delivered to the animal feed mill. On the
arrival, a fshmeal truck will be queuing for the
frst sampling. Sample will be taken from every
bag possible from the top and the back row
using a bag probe. A sample taker will look if
there are insects mixed in the fshmeal, if there
are, they will be rejected. And then he will look
at the color of fshmeal. If the color is different
from a previous bag, it will be kept in a separate
bag. Then the sample taker will touch sample
of fshmeal to sense the temperature. If it is quite
hot, they will use a digital temperature checker
to re-check if it is acceptable. After touching, a
sample taker will smell the fshmeal to see if
they smell the same or different. If they smell
different, it will be kept in a separate bag. Then,
all the samples will be mixed and tested in the
lab. After the frst sampling, bags of fshmeal will
be loaded. Then, sample will be taken from
every bag. The samples will be mixed, tested in
the lab, and kept for three months just in case
that there is a problem and the sample is
needed to be re-tested. Then, documents of the
fshmeal will be checked if animal feed mills
require the documents.
During the processing stage, raw materials
will be cooked so that they can be ground
easily, and then they will be sieved and ground
in order to be mixed easily. After that they will
be cooled, mixed and sent to a pellet mill. Then,
feed pellets will be dried and cooled one
more time before they are fltered. For post-
processing stage, feeds will be packed and
delivered to customers (Pollution Control
Department, Ministry of Natural Resources
and Environment, 2005).
Fifth link is farms both livestock and
aqua-cultured farms. They buy animal feeds
produced by the animal feed mills of the fourth
link which use fshmeal as a main protein
ingredient. However, some farms will buy all
the ingredients and mix them themselves.
Of the total fshmeal produced in Songkhla in
2013, 10% or 2,850 tons were sold to farms.
Aqua-cultured animals fsh and shrimps
need to be fed by high protein feeds. Therefore,
when shrimp farms were hit by Early Mortality
Syndrome (EMS), the demands for shrimp
feeds dramatically declined, and it affected the
domestic demands for fshmeal as well.
Si xt h l i nk i s expor t and domest i c
consumption. Since January 1, 2010, EC
requires catch certifcates from the exporters
who will export marine products. This affects the
supply chain of fshmeal industry because
shrimp exporters will need catch certifcates
from the animal feed mills who produce shrimp
feeds to show that the exported shrimps were
not fed by shrimp feeds produced from IUU-
fshing trash fsh. This effectively forces animal
feed mill exporters to require catch certifcates
from the fshmeal producers who need to ask
for the fshing logbooks from the fshing boats.
Overall, fshmeal supply chain in Songkhla
and market shares of major players in the chain
is summarized in Figure 71.
108
F
i
g
u
r
e

7
1
:

S
u
m
m
a
r
y

o
f

t
r
a
s
h

f
s
h

u
s
a
g
e

(
h
i
g
h
l
i
g
h
t
e
d

i
n

r
e
d
)

a
n
d

m
a
p

o
f

s
u
p
p
l
y

c
h
a
i
n

o
f

f
s
h
m
e
a
l

i
n
d
u
s
t
r
y

i
n

S
o
n
g
k
h
l
a
C
P
F

=

C
h
a
r
o
e
n

P
o
k
p
h
a
n
d

F
o
o
d
s
,

T
F
M

=

T
h
a
i
u
n
i
o
n

F
e
e
d
m
i
l
l

(
s
u
b
s
i
d
i
a
r
y

o
f

T
h
a
i
u
n
i
o
n

F
r
o
z
e
n

P
r
o
d
u
c
t
s
)
,

L
e
e

P
a
t
t
a
n
a

=

L
e
e

P
a
t
t
a
n
a

f
e
e
d

m
i
l
l
,

K
r
u
n
g

T
h
a
i

=

K
r
u
n
g

T
h
a
i

f
e
e
d

m
i
l
l
;

r
e
d

i
t
e
m
s

=

t
r
a
s
h

f
s
h

u
s
a
g
e
S
o
u
r
c
e
:

I
n
-
d
e
p
t
h

i
n
t
e
r
v
i
e
w
s

a
n
d

t
e
l
e
p
h
o
n
e

i
n
t
e
r
v
i
e
w
s

w
i
t
h

8

o
u
t

o
f

9

f
s
h
m
e
a
l

p
r
o
d
u
c
e
r
s

i
n

S
o
n
g
k
h
l
a
3
0
0

t
o
n
s

(
5
0
%
)
(
m
a
d
e

f
r
o
m

t
r
a
s
h

f
s
h
)
6
0
0

t
o
n
s
#
3

g
r
a
d
e

(
2
1
%
)
2
,
2
5
0

t
o
n
s
#
2
B

g
r
a
d
e

(
7
9
%
)
C
P
F

(
4
5
%
)
8
,
4
6
4

t
o
n
s
6
,
8
3
9

t
o
n
s

(
8
1
%
)
t
r
a
c
e
a
b
i
l
i
t
y
9
7
2

t
o
n
s

(
4
7
%
)
t
r
a
c
e
a
b
i
l
i
t
y
1
,
0
8
0

t
o
n
s

(
6
4
%
)
#
2

g
r
a
d
e
n
o
n
-
t
r
a
c
e
a
b
i
l
i
t
y
6
0
0

t
o
n
s

(
3
6
%
)
#
2
B

g
r
a
d
e
t
r
a
c
e
a
b
i
l
i
t
y
S
u
m
m
a
r
y

o
f

t
r
a
s
h

f
s
h

u
s
a
g
e

i
n

s
u
p
p
l
y

c
h
a
i
n

o
f

f
s
h
m
e
a
l

i
n
d
u
s
t
r
y

i
n

S
o
n
g
k
h
l
a
-

5
,
7
6
0

t
o
n
s

o
r

5
.
7
%

o
f

1
0
0
,
2
1
5

t
o
n
s

o
f

r
a
w

m
a
t
e
r
i
a
l
s

w
e
r
e

t
r
a
s
h

f
s
h
.
-

2
,
4
0
0

t
o
n
s

o
r

4
2
%

o
f

5
,
7
6
0

t
o
n
s

o
f

t
r
a
s
h

f
s
h

h
a
d

M
C
P
D
-
F
M
.
-

3
,
3
6
0

t
o
n
s

o
r

5
8
%

o
f

5
,
7
6
0

t
o
n
s

o
f

t
r
a
s
h

f
s
h

d
o

n
o
t

h
a
v
e

M
C
P
D
-
F
M
.
-

1
,
5
2
7

t
o
n
s

o
r

5
.
3
%

o
f

2
8
,
5
0
9

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h
.
-

6
5
2

t
o
n
s

o
r

4
2
.
7
%

o
f

1
,
5
2
7

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

w
e
r
e

s
o
l
d

t
o

b
r
o
k
e
r
s
.
-

5
7
5

t
o
n
s

o
r

3
7
.
6
%

o
f

1
,
5
2
7

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

w
e
r
e

s
o
l
d

t
o

C
P
F
.
-

3
0
0

t
o
n
s

o
r

1
9
.
7
%

o
f

1
,
5
2
7

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

w
e
r
e

s
o
l
d

t
o

f
a
r
m
.
-

1
0
0
%

o
f

6
5
2

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

t
h
a
t

w
e
r
e

s
o
l
d

t
o

b
r
o
k
e
r
s

c
o
u
l
d

n
o
t

b
e

t
r
a
c
e
a
b
l
e
.
-

3
0
0

t
o
n
s

o
r

5
2
.
2
%

o
f

5
7
5

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

t
h
a
t

w
e
r
e

s
o
l
d

t
o

C
P
F

c
o
u
l
d

b
e

t
r
a
c
e
a
b
l
e
-

1
0
0
%

o
f

3
0
0

t
o
n
s

o
f

f
s
h
m
e
a
l

p
r
o
d
u
c
e
d

f
r
o
m

t
r
a
s
h

f
s
h

t
h
a
t

w
e
r
e

s
o
l
d

t
o

f
r
a
m

c
o
u
l
d

n
o
t

b
e

t
r
a
c
e
a
b
l
e
.
3
0
0

t
o
n
s

(
4
1
%
)
(
m
a
d
e

f
r
o
m

t
r
a
s
h

f
s
h
)
1
,
6
2
5

t
o
n
s

(
1
9
%
)
n
o
n
-
t
r
a
c
e
a
b
i
l
i
t
y
1
,
3
5
0

t
o
n
s

(
8
3
%
)
#
2
B

g
r
a
d
e
3
,
9
0
0

t
o
n
s

(
5
7
%
)
#
2
B

g
r
a
d
e
2
4
0

t
o
n
s

(
3
%
)
#
2

g
r
a
d
e
7
3
7

t
o
n
s

(
1
1
%
)
#
3

g
r
a
d
e
1
,
9
6
2

t
o
n
s

(
2
9
%
)
f
s
h

h
e
a
d
g
r
a
d
e
2
7
5

t
o
n
s

(
1
7
%
)
#
3

g
r
a
d
e

(
m
a
d
e

f
r
o
m

t
r
a
s
h

f
s
h
)
1
,
0
8
0

t
o
n
s

(
5
3
%
)
n
o
n
-
t
r
a
c
e
a
b
i
l
i
t
y
L
e
e
p
a
t
t
a
n
a
1
,
6
8
0

t
o
n
s

(
9
%
)
B
e
t
a
g
r
o
3
,
2
7
0

t
o
n
s

(
1
7
%
)
f
s
h

h
e
a
d

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
K
r
u
n
g
t
h
a
i
6
0
0

t
o
n
s

(
3
%
)
#
2
B

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
O
t
h
e
r
2
,
7
4
8

t
o
n
s

(
1
5
%
)
#
2

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
T
F
M
2
,
0
5
2

t
o
n
s

(
1
1
%
)
#
2

g
r
a
d
e
I
m
p
o
r
t
s

6
2
3

t
o
n
s
w
i
t
h

M
C
P
D

(
8
%
)
S
a
t
u
n

5
,
9
1
0

t
o
n
s
w
i
t
h
o
u
t

M
C
P
D
-
F
M

(
7
7
%
)
P
a
t
t
a
n
i

1
,
1
0
8

t
o
n
s
w
i
t
h
o
u
t

M
C
P
D
-
F
M

(
1
5
%
)
W
i
t
h

M
C
P
D
7
0
,
3
2
4

t
o
n
s

(
8
8
%
)
W
i
t
h
o
u
t

M
C
P
D
9
,
6
4
1

t
o
n
s

(
1
2
%
)
8

F
i
s
h
m
e
a
l

p
r
o
d
u
c
e
r
s
1
0
0
,
2
1
5

t
o
n
s

o
f

r
a
w

m
a
t
e
r
i
a
l
s
2
8
,
5
0
9

t
o
n
s

o
f

f
s
h
m
e
a
l
F
a
r
m
s

(
1
0
%
)
2
,
8
5
0

t
o
n
s
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
A
n
i
m
a
l

f
e
e
d

m
i
l
l
s
1
8
,
8
1
4

t
o
n
s

(
6
6
%
)
4
8
0

t
o
n
s

(
7
%
)
#
2

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
1
,
3
0
8

t
o
n
s

(
1
9
%
)
F
i
s
h

h
e
a
d

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
3
,
2
5
7

t
o
n
s

(
4
8
%
)
#
3

g
r
a
d
e
2
,
6
0
5

t
o
n
s

(
8
0
%
)
t
r
a
c
e
a
b
i
l
i
t
y
1
,
8
0
0

t
o
n
s

(
2
6
%
)
#
2
B

g
r
a
d
e
1
0
0
%

t
r
a
c
e
a
b
i
l
i
t
y
6
2
5

t
o
n
s

(
2
0
%
)
n
o
n
-
t
r
a
c
e
a
b
i
l
i
t
y
(
m
a
d
e

f
r
o
m

t
r
a
s
h

f
s
h
)
B
r
o
k
e
r
s
6
,
8
4
5

t
o
n
s

(
2
4
%
)
T
r
a
s
h

f
s
h
5
,
7
6
0

t
o
n
s

(
4
6
%
)
S
o
n
g
k
l
a
1
2
,
6
0
9

t
o
n
s

(
6
2
%
)
O
t
h
e
r

w
h
o
l
e

f
s
h
6
,
8
4
9

t
o
n
s

(
5
4
%
)
O
t
h
e
r
s

7
,
6
4
1

t
o
n
s

(
3
8
%
)
W
h
o
l
e

f
s
h
2
0
,
2
5
0

t
o
n
s

(
2
0
%
)
T
r
i
m
m
i
n
g
s
7
9
,
9
6
5

t
o
n
s

(
8
0
%
)
W
i
t
h

M
C
P
D
-
F
M
2
,
4
0
0

t
o
n
s

(
4
2
%
)
W
i
t
h

M
C
P
D
-
F
M
4
,
5
0
0

t
o
n
s

(
6
6
%
)
W
i
t
h
o
u
t

M
C
P
D
-
F
M
3
,
3
6
0

t
o
n
s

(
5
8
%
)
W
i
t
h
o
u
t

M
C
P
D
-
F
M
2
,
3
4
9

t
o
n
s

(
3
4
%
)
T
r
a
s
h

f
s
h

l
a
n
d
e
d

i
n

S
o
n
g
k
l
a
2
5
,
0
0
0

t
o
n
s
S
o
n
g
k
l
a
5
,
7
6
0

t
o
n
s

(
2
3
%
)
O
t
h
e
r

p
r
o
v
i
n
c
e
s
1
9
,
2
4
0

t
o
n
s

(
7
7
%
)
109
Data source and calculation methodology
In i n-depth i ntervi ews wi th fshmeal
producers, we asked them to average the
amount of raw materials they used monthly,
percentage of their raw materials with MCPD
or MCPD-FM, their production ratios, grade
of fshmeal they produce, and percentage of
each major customer (animal feed mill) who
purchase their products.
1) Raw materials
l
Trimmings
We found that eight fshmeal producers
used about 100,215 tons of raw materials to
produce around 28,509 tons of fshmeal. Of
100,215 tons of raw materials, 80% or 79,965
t ons were off cut s f rom fsh-processi ng
manufacturers e.g. surimi producers, fsh ball
producers, or fsh canning manufacturers;
and 20% or 20,250 tons were whole fsh.
Since trimmings were from fsh-processing
manufacturers for human consumption, 88% of
the total offcuts or about 70,324 tons were
by-products that had MCPD which tells where
the fsh came from or where they were caught
by which vessels. Only 12% or 9,641 tons did
not have MCPD. Some of these by-products
actually had MCPD, but the fsh-processing
manufacturer did not release the MCPD, saying
it was trade secret.
l
Whole fsh
Of 20,250 tons of whole fsh, 62% or 12,609
tons were fsh landed in Songkhla, and 38% or
7,641 tons were from other provinces including
imports. Fish landed in Songkhla can divided
into two groups: trash fsh and other whole fsh
(true trash fsh and undersized fsh left over at
the pier). For the trash fsh, in case that they did
not tell us directly, we evaluated from the grade
of fshmeal they produce and the source of the
fsh. From our calculation, around 5,760 tons of
trash fsh landed in Songkhla were used to
produce fshmeal; this was 46% of the whole
fsh from Songkhla. The other whole fsh were
6,849 tons or 54% of the whole fsh from
Songkhla. 66% of these or about 4,500 tons
had MCPD-FM, and the rest 34% or 2,349 tons
did not have.
For the fsh from other places, 5,910 tons
or 77% of 7,641 tons were from Satun, and
1,108 tons or 15% were from Pattani. Fish from
both provinces were without MCPD-FM. Please
note that these fsh were bought by one fshmeal
producer who did not require the documents.
The rest 8% or 623 tons were i mported
with MCPD. The fshmeal producer did not
import the fsh by itself, but these fsh were
undersized imported fsh sold from a fsh
canning manufacturer.
2) Fishmeal
After we knew each fshmeal producers
average monthly amount of raw materials used,
their production ratios, and grade of fshmeal
they produce, we then calculated the amount
of each grade of fshmeal produced by each
fshmeal producer. Of 28,509 tons of fshmeal
produced in Songkhla in 2013, 36.8% or 10,500
tons were #2B grade, 23.2% or 6,600 tons were
#2 grade, 22.9% or 6,540 tons were fsh head
grade, and 17.1% or 4,869 tons were #3 grade.
And among 4,869 tons of #3 grade fshmeal,
1,527 tons or 31.4% were fshmeal produced
from trash fsh.
3) Fishmeal Buyers
After we calculated each grade of fshmeal
each fshmeal producer produce, we then asked
them whom they sold it to at what percentage,
and after that we calculated the amount of each
grade of fshmeal each fshmeal buyer bought.
Fishmeal buyers can be divided into three
groups: 1) animal feed mills 2) brokers and 3)
farms. Animal feed mills are the largest group,
buying 18,814 tons or 66% of 28,509 tons in
2013, while brokers bought around 6,845 tons
or 24%, and farms bought 2,850 tons or 10%.
Major animal feed mill buyers consist of fve
major animal feed mills and unidentifed small
and medium animal feed mills which we labeled
110
as others. The fve major animal feed mills
include Charoen Pokphand Foods (CPF),
Betagro, Thaiunion Feedmill (TFM), Lee
Pattana, and Krungthai. CPF bought 8,464 tons
or 45% of 18,814 tons, Betagro 3,270 tons or
17%, TFM 2,052 tons or 11%, Lee Pattana
1,680 tons or 9%, Krungthai 600 tons or 3%,
and others 2,748 tons or 15%.
l
CPF
Of 8,464 tons of fshmeal CPF bought, 81%
or 6,839 tons were fshmeal produced from raw
materials with documents for traceability, and in
case of CPF, they were fshmeal certifcates.
The others 19% or 1,625 tons were fshmeal
without fshmeal certifcate. Among 6,839 tons
of fshmeal with fshmeal certifcates, 3,900 tons
or 57% were #2B fshmeal, 1,962 tons or 29%
were fsh head grade, 737 tons or 11% were #3
grade, and 240 tons or 3% were #2 grade. Of
737 tons of #3 fshmeal, 300 tons or 41% were
fshmeal produced from trash fsh. As for 1,625
tons of fshmeal without fshmeal certifcates,
1,350 tons or 83% were #2B grade, and 275
tons or 17% were #3 grade fshmeal produced
from trash fsh. In total, CPF bought about 575
tons of fshmeal produced from trash fsh or
6.8% of fshmeal CPF bought from Songkhla.
l
Betagro
Betagro bought 3,270 tons of fsh head
grade fshmeal all, of which had fshmeal
certifcates. This is because Betagro bought the
fshmeal from a single fshmeal producer that
can provide fshmeal certifcates to all of the
fshmeal it produces as its raw materials are by-
products from the mother company which already
has MCPD of fsh it bought, so the mother
company then provided MCPD documents for
traceability to the fshmeal producer.
l
TFM
TFM bought 2,052 tons of #2 fshmeal 47%
of which or 972 tons were produced from raw
materials with documents for traceability. And
the other 53% or 1,080 tons had no documents.
l
Lee Pattana
Lee Pattana bought 1,680 tons of fshmeal
64% of which or 1,080 tons were #2 fshmeal
with no documents for traceability. And the
other 36% or 600 tons were #2B fshmeal
produced from raw materials with documents
for traceability.
l
Krungthai
Krungthai bought 600 tons of #2B fshmeal,
all of which were produced from raw materials
with documents for traceability. Like Betagro,
Krungthai bought the fshmeal from a single
source that can have documents for traceability
of all of fshmeal it produces.
l
Others
Unidentifed small and medium animal feed
mills altogether bought 2,748 tons of #2 fshmeal
produced from raw materials with documents
for traceability.
l
Brokers
Brokers bought 6,845 tons of four different
grades of fshmeal including 3,257 tons of #3
or 48% of the total fshmeal they bought,
1,800 tons of #2B produced from raw materials
wi th documents for traceabi l i ty or 26%,
1,308 tons of fsh head grade with document
for traceability or 19%, and 480 tons of #2
produced from raw materials with documents
for traceability or 7%.
Of 3,257 tons of #3 fshmeal, 2,605 tons or
80% were produced from raw materials with
documents for traceability, and the other 20%
or 652 tons were produced from trash fsh
without documents for traceability.
l
Farms
Farms bought 2,850 tons of two grades of
fshmeal produced from raw materials with
documents for traceability. Of 2,850 tons, 79%
or 2,250 tons were #2B, and the other 21% or
600 tons were #3 50% of which or 300 tons were
produced from trash fsh.
111
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112
7.2 Responsible sourcing of fshmeal
raw material
As stated in chapter 5, standards on fshery
are designed to promote responsible fshing
practices to achieve the goal of long-term
sustainability. Standards in the area of fshmeal,
namely IFFO RS, ASC, Global G.A.P., and BAP,
all require responsible practices from sourcing
material to end products. Animal feed mills
aiming to get certifed are inevitable but to fulfl
the qualifcations. CPF and Thai union are
examples of Thai feed mills that actively respond
to the requirements, although there remain
si gni fcant gaps due to shortcomi ngs of
Thailands current fsheries law and lack of
location-based tracking. Standards that both
frms engage in
53
set the criteria for fshmeal
sourcing to be traced back to where and how raw
materials originate. Fishmeal must be produced
from traceable, non-IUU fshing, and uses
no endangered species as raw materials.
Consequently, feed mills attempt to incorporate
suppliers practices into their practices and invent
measures to better manage their supply chain.
As stated earlier, the fshmeal supply chain
in Songkhla comprises six links from fshery to
animal feed market. The focus of this research
is, however, on the frst four links which involves
three groups of players, namely suppliers of raw
materials
54
, fshmeal producers, and animal
feed mills. Their activities regarding responsible
sourcing of fshmeal are summarized by key
players below.
7.2.1 Animal feed mills
A call for responsible sourcing from an
international market, particularly the European
Union, is the key factor driving animal feed mills
to respond by inventing program to enhance
their supply chain management and to display
their intention toward sustainability. As the most
infuential payers in the chain, feed mills are the
most capable of motivating changes in their
suppliers practices.
1) Thaiunion Feedmill
Thaiunion Feedmill (TFM), a subsidiary of
Thaiunion Frozen Products (TUF), is currently
developing the program to promote responsible
sourcing as a part of sustainability project of its
mother company, TUF. Monetary incentive is to
be adopted in order to increase players
participation which is the essence of the
program. Pilot projects will be launched this
year (2014) in Phang-Nga and Chumphon
province, where large share of supply come
from
55
. Presently, the company is committed to
BAP standard; accordingly, it needs to obtain
declarations from suppliers on the species and
fshery origins of each batch of fshmeal, and
keep record of one up, one down.
According to feld interviews, 2,052 tons of
fshmeal produced in Songkhla was sold to the
company last year; none is originated from
Songkhla trash fshing
56
. Forty-seven percents
of this amount come from affliated surimi frm,
therefore, it is traceable. Fishmeal producer is
requested to flls the form provided by the
company. This form identifes species and
amount of raw materials as well as fshing area.
However, it is a self-reported form and the
company does not require other proofs of raw
material sourcing from the suppliers suppliers
since the company only complies with one down
traceability.
Despite being certifed under BAP standard,
53% of fshmeal the company bought from
Songkhla in 2013 is without declarations of
species and origins of raw materials. Around
70% of untraceable fshmeal is sourced from
53
Suppliers of raw materials include fshing vessels, brokers, Pae Pla, and processing plants.
54
From an interview.
55
Evaluate from grade of fshmeal. Fishmeal grade 3 and below are made from trash fsh. Thaiunion Feedmilldid not buy grade
3, or below, fshmeal last year.
56
Evaluation by grade of fshmeal. Fishmeal grade 3 and below are made from trash fsh. Thaiunion Feedmill did not buy grade
3 or below fshmeal in 2013.
7.2 Responsible sourcing of fshmeal raw material
7.2.1 Animal feed mills
1) Thaiunion Feedmill
2) CPF

3) Other feed mills
113
57
Interview with CPF, 13 February 2014.
58
No information about reasons behind their decisions or information about their future plan toward sustainable sourcing of fsh-
meal as they all reject an interview
59
Mostly from Pattani and Satun
wild fshery, though, not from trash fshing,
nothing can assure responsible fshing practices.
2) CPF
That Thai l and fsher y i ndust r y i s
internationally known for unsustainable and
irresponsible fshing would harm CPF credibility
and competitiveness in a global market. In
response to the market pressure, the company
has entered IFFO last year and is currently in
preparation stage for applying the IFFO RS. For
this reason CPF very active in co-inventing and
promoting the fshmeal certifcate and is so far
the only feed mill engaging in the scheme. The
objective of the scheme is to ensure responsible
fshing practice and fshmeal is produced from
raw materi al s that excl ude IUU fshi ng.
Documents, as mentioned earlier in chapter 5,
were designed to fulfl the scheme requirements.
Participation of all players in the chain is
necessary for enabling a full traceability. For this
reason, CPF offers a price premium of 3 baht
per kilogram to fshmeal producers for batches
of fshmeal, of which its sourcing can be traced
back, whether produced from by-product or
whol e fsh and regardl ess the grade of
fshmeal
57
. The company expects fshmeal
producers to requests proof of document from
their suppliers and also expects the suppliers to
request document from the previous ones. This
way a full traceability is assured. According to
CPF, before the scheme implementation all
fshmeal is considered non-traceable and
cannot be claimed to be responsibly sourced.
In earlier 2014, around 50% of fshmeal sold to
CPF is traceable and certifed. The number is
different for fshmeal supplied from Songkhla
around 80% of fshmeal is certifed while only
20% is not. This represents that a monetary
i ncent i ve i s consi der ed per suasi ve t o
incorporate players into the scheme. However,
it is a challenge for CPF to reduce fshmeal
produced from untraceable sources so as to
meet IFFO RS standard. That CPF does not
have the mechanism to monitor or manage the
allocation of a price premium may exclude some
players out of the scheme and obstruct the
company to reach a goal of full-certifed
fshmeal. In addition, that IFFO RS requires
certifed product to be segregated to those
uncertifed would necessitate CPF to develop a
monitoring system in the future.
Lastly, it is worth noting that there were 575
ton of fshmeal produced from trash fsh sold to
CPF, about half was traceable and got a
fshmeal certifcation. This indicates that the
scheme is not capable of excluding trash fshing
from fshmeal production.
3) Other feed mills
Other feed mills refer to Betagro, Lee
Pattana, and Krungthai Feedmill. All of them
have engaged in neither a fshmeal certifcate
scheme nor any international standards
58
.
Betagro and Krungthai Feedmill purchased
3,270 and 600 ton of fshmeal from Songkhla
fshmeal producers last year respectively.
All fshmeal sourcing is traceable. Betagro were
supplied from fshmeal producer whose raw
materials were sourced from its tuna processing
mother Company. Likewise, Krungthai Feedmill
got supplied mostly from by-product fshmeal
producer. Therefore, the product was 100%
traceable and the fshmeal producers are able
to prepare documentary proof, though, not
requested by both feed mills.
As for Lee Pattana, 36% of fshmeal bought
from Songkhla fshmeal producers last year was
traceable. Fifty-eight percents of total fshmeal
were produced from non-traceable whole fsh
59
.
This indicates a market for irresponsible
sourcing fshmeal that allows unsustainable
fshing practice to continue.
114
Figure 73 ranks fve major animal feed
mills based on the percentages of fshmeal
traceability from the highest to the lowest.
Please note that traceability here does not
excl usi vel y mean a fshmeal certi fcate.
Traceability here includes fshmeal produced
f rom raw mat eri al s wi t h document s f or
traceability such as MCPD and MCPD-FM, but
it will not have a fshmeal certifcate with it if the
fshmeal producer did not issue the fshmeal
certifcate. Some fshmeal producers issue
fshmeal certifcates for the fshmeal produced
from raw materials with MCPD or MCPD-FM;
these fshmeal producers usually are those
who sell to CPF since CPF gives monetary
incentives of three baht per kilogram for
fshmeal wi th val i d fshmeal certi fcates.
However, some fshmeal producers see this as
an extra process which they will not do unless
the buyer will request and/or pay for it.
7.2.2 Fishmeal producers
None of fshmeal producer in Songkhla gets
their plant certifed under any international
standards. The only scheme they currently join
is Thailands fshmeal certifcate scheme. In
order to identify their activities and incentives
regarding responsible sourcing of fshmeal
under this scheme, fshmeal producers in
Songkhla can be divided into 3 groups as
follows: 1) fshmeal producers with no incentive,
2) fshmeal producers infuenced by monetary
incentive, and 3) fshmeal producers infuenced
by other factors.
1) Fishmeal producers with no incentive
There are two out of eight interviewed
fshmeal producers that do not trade with
CPF ; therefore, they are excluded from the
scheme. One of them stated that it had no
incentive to trace its raw materials or prepare
document in order to be certifed. There was no
beneft of doing so since its trading partners did
not request any certifcation. Ninety percent of
its total raw materials are whole fsh, of which
sourcing practice; including IUU fshing, cannot
be traced. However, it only produces grade-2
fshmeal, which implies that probably no trash
fsh is used as raw material.
The other fshmeal producer is a subsidiary
of Thaiunion Group, and this is likely to be the
reason for not selling to CPF. It was requested
by Thaiunion Feedmill to fll the form declaring
species and amount of raw materials as well as
fshi ng area; however, fshmeal sol d to
Thaiunion Feedmill accounted for 30% of total
fshmeal, leaving another 70% without any
documentary verifcation. Nevertheless, the
factory manager stated that raw materials
mostly come from its mother companys surimi
Figure 73: Animal feed mills based on fshmeal traceability, ranked from highest % to lowest %
Company % of Traceability Amount (tons) Note
Betagro 100% 3,270
Buys 100% from a single fshmeal
producer that is 100% traceable
Krungthai 100% 600
Buys 100% from a single fshmeal
producer that is 100% traceable
CPF 81% 6,839
TFM 47% 972
Lee Pattana 36% 600
Source: Field interviews by research team, 2014.
60
The reasons for not trading with CPF one of them is a subsidiary of Thaiunion Group, the other is due to product qualifcation.
115
processing plant, while a small portion comes
from whole fsh. The fshmeal producer claims
that all raw material used are traceable.
2) Fishmeal producers infuenced by
monetary incentive
There are fve fshmeal producers in this
category. From interviews, they all agreed that
to fulfl the scheme requirement and prepare all
documents increased their administrative cost,
training employees and instructing suppliers in
particular. They would not participate in the
scheme unless a price premium is given. Three
of fve producers are supplied with raw materials
from their mother processing company so it is
easier for them to request documents compare
to those purchasing from vessels, Pae Pla, or
brokers. Shares of price premium allocated to
suppliers of raw materials vary from 0.2-1 baht
per kilogram of raw materials. However, none
of these fshmeal producers shares the received
price premium with its mother processing
company. They stated that whether or not they
requested, their mother company need to
prepare those documents for export anyway.
Fishmeal producers in this group only
prepare traceability document for fshmeal
batches that are sold to CPF, but not all fshmeal
sold to CPF is traceable. Last year, 6,501 ton
of fshmeal from producers in this group were
sold to CPF, 75% are of traceable while the rest
of 25% are non-traceable. The proportion is
compatible when considering fshmeal sold to
others, 80% is traceable and 20% is non-
traceable. When considering types of raw
materials, fshmeal sold to CPF is around 81%
of by-products and 19% of whole fsh; fshmeal
sold to other is 80% by-products and 20% whole
fsh. It can be concluded from these fgures and
interviews that a fshmeal certifcation scheme
does not affect how raw materials are selected.
3) Fishmeal producer infuenced by other
factors
There is only fshmeal producer in this
group. Unlike others, it is not infuenced by a
price premium offered by CPF. It is supplied by
tuna processing plant which is its mother
company; hence, its fshmeal is totally traceable.
Documentary proof of product sourcing is 100%
prepared, declared to the purchasers regardless
of their requests. According to an interview with
the factory offcer, this is because fshmeal
produced here contains low protein compare to
others. It cannot compete in quality when protein
is an essential component, therefore, documen-
tary proof demonstrating full traceability of raw
materials origin is offered to build credibility and
trustworthiness. This indicates that the key
factor infuencing this fshmeal producer is
competitiveness rather than monetary incentive.
7.2.3 Suppliers of raw materials
Suppliers of raw materials can be classifed
into 2 groups which are 1) processing plants,
and 2) fshing vessels, Pae Pla, and brokers.
1) Processing plants
As stated in the previous chapter, 5 of 8
fshmeal producers are supplied by their
processing plants, which are their mother
company. Processing plants practices to show
their conformity to a fshmeal certifcate scheme
is to provide traceability document when required.
Documents for surimi processing plant and tuna
processing plant are slightly different as
mentioned in chapter 5. According to interviews,
the processing plants never get a share of a price
premium but they still provide all documents
requested in order to facilitate their subsidiary.
2) Fishing vessels, Pae Pla, and brokers
Unlike processing plants, players in this
group are requested to prepare MCPD-FM as
a proof of responsible sourcing. For fshing
vessels, it is necessary to legalize their vessel
and gear as well as submit their logbook to the
authority when land. These players will receive
share of a price premium range from 0.2-1 baht
per kilogram of raw material if batch of fshmeal
produced from their supply is certifed. Figure
74 presents proportions of fshmeal produced
from total whole fsh and non-traceable whole
fsh by purchasers.
116
Figure 74: Fishmeal produced from whole fsh and fshmeal produced from non-traceable
whole fsh by purchasers (percentage)
Share of fshmeal produced
from whole fsh (%)
Share of fshmeal produced
from non-traceable whole
fsh (%)
CPF 24 16
Lee Pattana 19 29
Thaiunion Feedmill 19 29
Krungthai 1 0
Betagro 0 0
Other feed mills 7 0
brokers 19 18
farms 11 8
Total 100 100
Source: calculated from interviews with 8 fshmeal producers in Songkhla
Figure 74 shows that CPF accounts for 24% of fshmeal that produced from whole fsh. This number declines when
considering only fshmeal produced from non-traceable whole fsh. This indicates the effect of a fshmeal certifcate
scheme on CPF purchasing of fshmeal from Songkhla. The impact on wild fsh sourcing may not be signifcant since
there is still a big market for non-traceable whole fsh.
7.3 Supplementary information:
feld research at Ta Sa-aan Port
Songkhla (Ta Sa-aan) Fishing Port is
the biggest fshery port in Songkhla operated
by the Fish Marketing Organization (State
Enterprises), under the ministry of Agricultural
and Cooperatives. The fsh are caught from both
domestic waters as well as from Malaysian
and Indonesian territorial waters. It could be
considered as a small regional fshery market
where all types and all qualities of marine
animals are sorted, auctioned, and distributed
to domestic and international seafood markets
worldwide.
117
Landing and Logistics of the Port
Ta Sa-aan () Port can be divided into three main areas: markets worldwide.
Figure 75: Ta Sa-aan Port
1) Local fshing boat landing area. (North)
2) Economic fsh landing area (Middle)
3) Trash fsh landing area (South)
118
Firstly, commercial fshing boats land at
economic fsh landing area (2), where the most
valuable sea products are immediately sorted
by the workers and auctioned by the middlemen
or Pae-Pla (.:a) who usually have ties with
exporters and international buyers, as well as
major domestic markets. From feld observation,
we found that signifcant amount of fsh from
commercial fshery boats are juvenile marine
animals which should not be caught at these
sizes and ages. Most marine animals landed
here will be exported to international brokers.
61
After all valuable sea products have been
moved from boats to the pier and sorted, these
commercial fshery boats will later move to the
trash fsh landing area (3). The trash fsh that
are normally stored at the bottommost area of
the boats wi l l be moved to the pi er and
transported directly to the fshmeal factories.
Local fshermen usually land at the local
fshing boat landing area (1), where their marine
animals, namely squid and small fsh, are
sorted then sold to small middlemen. The
products landed here are normally sold to local
and domestic markets.
Fishmeal Supply Chain at Ta Sa-aan Pier
Commercial Fishery Boats
Fishmeal processors usually deal with
boats directly to secure their supply chain. It is
unlikely that the trash fsh will be auctioned at
the pier like other types of marine products.
Each boat owner has his own relationship with
a certain fshmeal processor and usually
contacts his buyer directly prior to landing. Since
one of the major threats in this industry is the
sharp decline in fsh stocks and marine animal
suppl i es, i n some cases, t he fshmeal
processors provide fnancial assistance in form
of credit called Giaw (.a a.). The credit is
normally given to the boat owner in advance to
help with their petrol, labor and other costs,
under the condition that the later would only
deliver fsh to the creditor.
62
Some of the middlemen at the port are
representatives of the fshmeal processing
companies. For example, the owner of Wallop
(.aas) Pae-pla also owns a fshmeal factory
called Sang Charoen. Moreover, Wallop Pae-
Pla also owns 11 boats. Together with other
61
Interview with Mr.Rai (Maliwan Pae-pla)
62
Interview with Mr.Rai (Maliwan Pae-pla) and representative of Wallop Pae-Pla
Figure 76: Ta Sa-aan Port Landing Area
119
63
Sang Charoen factorys capacity is 100 ton/day (if operates 24 hrs.)
64
Interview with Khun Jane or Mr.Theerawat Puttharo (082-036-1898)
boats in its networks, this middleman alone
delivers trash fsh directly to its mill 10-20 tons
a day.
63
Local Fishery Boats
Although with less amount, these smaller
players also have trash fsh products to sale.
Unlike the commercial fshery boats which
contact factories directly, the local fshermen
sale their trash fsh to the broker which will
collect and then later deliver trash fsh to
fshmeal factories.
Major Brokers at Ta Sa-aan
According to the interviews, there are two
major brokers who buy and collect the trash fsh
and fsh parts from the port for sending to
fshmeal factories, namely Jane-Jub and
Choke Sai Thong
Normally the Jane-Jub Pae-Pla buys
trash fsh from smaller brokers or the smaller
middlemen who doesnt have direct tie with
factories
64
. Another source of their supplies
comes from fsh parts and fsh heads which are
primarily separated at the port. The left over
parts will be sold to Jane-Jub. Like the big boats,
Jane-Jub also has a long-term relationship with
couple of factories which it regularly sends the
trash fsh to, for example, Pacifc (PFP) and
Sripitak. At the moment, Jane-Jub delivers
approximately 6-7 tons of trash fsh to factories
daily. While 10 years ago, they delivered about
20-30 tons/day.
Other Information
l
It is very diffcult to fnd offcial data that
would represent the real number of trash fsh
amount landed and delivered from this port.
Although there are records kept at the Fish
Marketing Organization, these numbers could
not portray the real amount which could be
many ti mes more than what have been
recorded.
l
The economic fsh products from this port
are considered very fresh compared to fsh
landed at Mahachai Area. However, the trash
fsh here has very low quality because the
fshermen dont really pay attention at keeping
the quality high by sorting out the non-protein
substances and using ice to keep them fresh.
This is because the ice cost as much as the
value of trash fsh. The high-quality trash fsh
usually comes from Andaman Sea.
l
Annually, the trash fsh supplies increase
during the month of January to May. Therefore
it is hard to calculate the yearly trash fsh
amount from a month or two months records
because amount of seafood supply differs
during and between the years.
l
The price of trash fsh are not really
fxed to the price set by the Thai Fishmeal
Association. It differs depending on the quality,
t he br oker s, fnanci al condi t i ons, and
relationship between seller and buyer. For
example Jane-Jub sale fsh heads at 3.50 Baht/
kg and 4.3-5 Baht/kg for other types of trash fsh
(with more protein content).
120
CASE STUDY:
SUSTAINABLE FISHING IN PERU
8.
At present, global fsheries are facing consequences from unsustainable
use of natural resources. Nearly one in four fsheries collapsed during the
period 1950-2000 (Mullon et al. 2005), where collapsed is defned as 90%
reduction of a wild fsh stock. There has been a continuous decline in global
catches since late 1980s (Pauly et al. 2003). Peruvian fshery has been a famous
case study on sustainable fshing for many years. Proven sustainability of
fshery in Peru was not achieved in a short period of time, but gradually
developed through 50 years of trial and error and continuous improvement.
Peru faced various issues stemming from the lack of proper institutions,
including regulations, measures and enforcement. Such defciencies resulted in
over-exploitation and collapse of fsheries in 1970, before recovery that have
been continuing for two decades.
The Fisheries Center at the University of British Columbia ranked Perus
fsheries and marine ecosystem as the most sustainable in the world out of 53
marine countries (IFFO 2009).Meanwhile, Chavez et al. (2008) also described
Peru as the most intense and successful fshery worldwide.
Perus experience is of particular interest for Thailand because Peru is the
largest fshmeal exporter in the world.
8.1 Overview of Perus anchoveta industry
The Peruvian anchovy Engraulis ringens fshery has been described as the
largest mono-specifc fshery that has ever existed on Earth (Bakun and Weeks
2008, Aranda 2009b). This large-scale enterprise accounts almost 10% of the
worlds marine fshery landings (FAO 2010), covers the catching area of 14,000
km2 with a potential biomass of 15-20 million tons annually (Pauly 1992; Niquen
et all. 2000). The Peruvian anchoveta feet has the capacity to land in three days
when fshing feets from other countries such as Colombia, Germany, Australia,
Panama, Poland and Sweden usually land in one year. (Arias Schreiber 2013)
Since 1950, rapid industry growth and increase in harvest led Peru to become
one of the worlds largest exporters of fshmeal and fsh oil (FAO 2008).
Peruvian fshing industry produces 30-40% of the global production of fshmeal
and fsh oil, and is the second largest industry of the country after mining (Tacon
2003, PRODUCE 2005, 2008 a). The fshing industry employs tens of thousands
of jobs along its complex supply chains. In 2010, exported fshmeal and fsh oil
reached 1 million tons, valued at US$1.9 billion (SNP 2010). Approximate 1,300
purse seiners are in the industry and target only the Peruvian anchovy.
121
Peruvian anchoveta is a marine, pelagic,
coast al speci es whi ch can be f ound at
approximately 80-150 km off the coast of Peru.
Anchovies breed throughout the year with a
major spawning in winter/spring (August to
September) with lesser spawning in summer
(February and March). They typically grow to
8-9 cm in length in 5-6 months, 10 cm in 12
months and 12 cm in 18 months with longevity
about three years, reaching a maximum of 20
cm. (IFFO 2009).
The productivity of anchoveta catch is
highly variable based on fuctuations in climate,
oceanographic, ecosystem conditions, and
seasons. One vital factor that affects the amount
of landings is the El Nio Southern-Oscillation
phenomenon. (iquen 2004) The El Nio results
in limiting nutrient fux (Barber and Chavez 1983),
creating changes in plankton assemblage
composition that leads to the disruption of the
anchoveta food web (Chavez 2005). In addition,
warmer waters during El Nio cause reduction
of habitat, leading to extensive anchovy
biomass losses (Bertrand et al. 2004).
Since 1973, two anchovy populations have
been recognized in Peru: the north central stock
from 0430 to 15 S, and the southern stock
from 15 S to the southern limit of the Peruvian
maritime domain. (Checkley et al. 2009) The
north central stock is wholly in Perus territory,
i.e. country has the full authority in the area. On
the other hand, the southern stock waters are
shared with Chile. Sustainability practices and
enforcements such as closed fshing seasons
to reserve the stock are not responded by
Chilean authorities.
98% of anchovy catches are converted to
fshmeal and fsh oil in Peru to be exported to
international markets for aquaculture and animal
feed; the remaining 2% is canned or frozen for
l ocal human consumpt i on. FAO (2013)
estimated that the majority of Peruvian fshmeal
was sold to China (52%), followed by Germany
(15%) and Japan (9%). The anchovy processing
industry offers a variety of fshmeal products
with different grades to the international market.
Processi ng pl ant s produce mai nl y t he
traditional fair average quality of FAQ fshmeal,
amounting to 57% of the total, although with
current investments made in new processing
machinery and equipment, there is a growing
trend towards the production of high quality
fshmeal (Snchez and Gallo 2009). Another
main export is fsh oil. The strongest export
markets for Peruvian fsh oil continue to be
Belgium, Chile and Denmark. (FAO 2013) Fish
oil is sold principally for the aquaculture feed
market. With its richness in long chain omega-3
fatty acids, it is also produced as a product for
direct human consumption.
8.2 History of the Peruvian anchoveta
fshery
The sustainability of the Peruvian anchovy
has evolved over fve decades. Categorized by
amount of fshery landings, Arias Schrieber
Photos Credit: www.sfgate.com and www.worldfshingnet.com
Figure 77: Peruvian anchoveta
122
Figure 78: Historical Peruvian anchoveta landing, major El Nio and fshery phases
Source: Arias Schreiber, M., and A. Halliday. 2013
(2012) identifed four distinct phases of the
anchovy fshery in Peru.
1) Mid 1950s to 1972 the frst growth
and unsustainable phase
Fisheries in Peru were established in
mid-1950s. In order to increase exports, the
government mandated the construction of
fshmeal plants since early 1940s. (Laws 1997,
Olazo 2000) Growth was spurred by capital
investment, foreign technology transfer, state
support, deregulations, and expansions into
international markets. (Glantz 1979, Aguilar
Ibarra et al. 2000) During this anchoveta boom
period, Peruvian fshery was conducted in an
open-access resource without barriers to entry,
characterized by explosive and uncontrolled
growth.
During 1960-1970s, three organizations
which became key stakeholders of the industry
were founded. First, The Instituto del March
del Peru (IMARPE) is a scientifc institution
set up to provide information and expertise
i n oceanographi c condi ti ons and mari ne
resources to the government. Even though
IMARPE has no legislative power in managing
the anchovy stock (Hammergren 1981), they
play a signifcant role of assessing sustainable
yields, monitoring and determining the habitat
and distribution of this resource (Marcacin
...1970a) and recommends fshing quota or
suspensi on of quota to the authori ti es.
The founding of IMARPE was considered the
beginning of science-based decision making in
Peruvian fshery.
Second, in the business sector, Sociedad
Nacional de Pesqueria (SNP- the National
Fisheries Society) was established. Currently
SNP membership comprises approximately
70% of fshing companies. In 1970s, the
government empowered SNP to act as the
agent in assigning export licenses in conformity
with world market quotas (Per ratifca ...
123
1961). SNP has engaged in intensive lobbying
on taxation and credit policy (Hammergren
1981) and facilitated conficts between resource
users. In 1970, the Ministry of Fisheries was
created to dedicate to fshery management and
oversee IMARPE.
At the end of 1960s, the sharp growth with
unsustainable practices had continued. In 1971,
landing peaked at 12.3 million tons, the highest
level ever experienced for a single-species
fshery in the world. The collapse occurred in
1972, likely due to a combination of overfshing,
an unfavorable, decadal-scale ecosystem
regime shift; and a strong El Nio event that
year (Bakun and Broad 2003; Bertrand et al.
2004; iquen and Bouchon 2004).
2) 1972 1984 the collapsed phase
After the collapse, the anchoveta population
was severely depressed. Anchoveta biomass
and landings remained low at the average of
under 2.5 million tons per year before reaching
the lowest point during the second El Nio in
19821983, with the harvest of only 0.024
million tons. (Olazo 2000)
During the military governments state
control, the whole industry was nationalized in
1973 through the expropriation of both fshing
feet and fshmeal-processing facilities. As a
public corporation, PESCAPERU (Empresa
Pblica de Produccin de Harinay Aceite de
Pescado) was formed under state ownership
with fexibility to consolidate holdings and r
estructure efforts, with the focus on proft
maximization, not sustainability. (Deligiannis
2000)
3) 1985 1993 the second growth
phase
In this phase, anchovy catches grew
dramatically without the effect from the warm
climatic change and reached the landings of
approximately 10 million tons in 1994. The
recovery of anchovy catches during this period
was a direct result of a slew of new laws and
regulations.
A number of legislative measures were
enacted. In 1988, the new General Fisheries
Law replaced the original 1971 law, and
the catch quota violation sanctions were
established. Later on, permits are required for
anchoveta fshing, followed by closing of fshery
access. No new industrial license was issued
during this period, while the anchoveta vessel
size was capped by law. In 1991, juvenile
catches were regulated. The General Fisheries
Law was renewed again in 1992 with new
regulations to promote the sustainability
development and ensure its continuity as an
important source of food, employment and
i ncome (Ari as Schrei ber 2013); f urt her
amendments in 1994 added licensing required
for artisanal feets and environmental mandates.
4) 1993-present the sustainable period
Annual landings in Peru have been stable
at around 5-9 mi l l i on tons i n years wi th
propitious oceanographic conditions and have
recovered quickly from perturbations caused
climate change, including the extreme El Nino
in 1997-1998. (Arias Schreiber 2012)
In order to promote fshery sustainability,
various new government directives have
continuously been enacted and enforced. The
General Fisheries Law was revised again in 2001
with emphasis on sustainability, conservation,
and soci o-economi c devel opment , e. g.
promoting direct human consumption market.
In 2002, decision-making and all management
regulations authority were transferred to the
Vice-Ministry of Fisheries, a subdivision of the
Ministry of Production (PRODUCE) based on
scientifc reports from IMARPE, after the
abolishment of the Ministry of Fisheries.
In 2008, installation and use of satellite
positioning systems and database integration
to prevent illegal and over-quota catches
became mandatory. At the same time, the new
quotas for individual fshing vessels (Individual
Vessel Quota: IVQ) was i ntroduced and
substantially altered some key, long-standing,
institutional features of Peruvian fshery.
(Aranda 2009a, Arias Schreiber 2012)
124
8.3 Toward fshery sustainability
Overcapacity Problem
Aranda (2009) pointed out that throughout
history of Peruvian fshery, the continuous
enlargement of fshing capacity has been
detrimental to its sustainability. During the frst
unsustainable growth period, access to fshery
resources was wide open. The rapid growth
numbers of fshing vessels and fshmeal
processing factories had broadly followed
changes in the amount of anchovies. In addition,
the availability of funding and the incentives
from a global quota system poured into Peru.
Both resulted in the overcapitalization of the
industry (Ibarra et al. 2000, Thorpe et al. 2000,
Fron et al. 2008, Aranda 2009a), in the form of
excess feet and processing plant capacity.
(Lemay 1998; Grboval and Munro 1999)
Even though the fshing licenses system
was introduced to limit the access to resources
as early as 1956, it only increased corruption
before the system was abandoned in 1962
(Thorp and Bertran 1978). The amount of
r egi st er ed fshi ng vessel s i ncr eased
signifcantly from 52 in 1953 to 1,309 in 1972,
despite declining from the peak of 1,744 vessels
in 1964 (Aranda 2009b). After the collapse
in 1972, with the forming of PESCAPERU
under the government, the fshing feet was
nationalized and large numbers of vessels and
processing facilities were decommissioned by
applying a moratorium on vessel licensing and
construction (Laws 1997). The number of
vessels and processing facilities dramatically
declined. Later on, with unaffordability in
subsi di zi ng, the government deci ded to
denationalize the fshing feet. (Glants 1979)
Many of idle purse seiners were exported to
other countries in Latin-America (Suerico 1996)
to decrease the number of feets.
Figure 79: Fleet size and number of fshmeal factories: 19502006
Source: Adapted from Freon et al. 2008.
125
In addition to accelerated depletion of
natural resource, overcapacity decimated the
economics of the fshing industry and caused
soci al tensi ons. Thi s probl em i ncreased
the political pressure to achieve higher and
increasing quotas (Deligiannis 2000). During
seasons of the previous collapse or scarcity
period like El Nio, excess capacity became
damaging as debt accumulated and costs
increased, leading to widespread bankruptcies.
(Clark 1976; Hammergren 1981).
In 1990s, the recovery of the anchoveta
stocks incentivized the industry to once again
expand feet and processi ng f act ori es.
The government revised the General Law of
Fisheries to prevent capacity building, such as
requiring the new vessel entries to be balanced
by decommissioning older feet (close of entry).
Many companies were authorized to build
vessels only for human-consumption fshery;
some tried later on to adjust the vessel to
ft anchoveta fshing (Thrope et al. 2000).
None of these measures prevent overcapacity.
Furthermore, the effort of the government to
support economics need of the artisanal feet
sector by issuing the law to permit the Viking
feet (the wooden feet of artisanal boats larger
than 30m3 capacity) to catch anchovy for the
fshmeal industry created substantially more
fshing boats. (Aranda 2009)
In 2007, maximum annual sustainable
yield for the entire Peru was estimated at 8
million tons in an average season; the level of
overcapacity was 70% for the entire Peruvian
feet and 89% for the processing factories.
Estimated overcapacity actually fuctuates with
annual quota assignments (Paredes and
Gutierrez 2008). In fact, the quota measure was
applied since the frst phase of fshery to control
overcapacity. IMARPE recommended the
government to use Total Allowable Catch (TAC)
since 1960s, but the enforcement was not
suffciently strong to ensure compliance. TAC
unintentionally gave the incentive for feets to
take a bigger piece of the quota and race for
fsh. When fshers invested in larger vessels
wi t h more modern cat chi ng equi pment
(Grevobal and Munro, 1999), i mproved
effciency drastically resulted in shortening
fshing seasons because quotas were being
reached even faster e.g. as short as 54 days in
2006 (PRODUCE 2006) and unavoidably often
shortened seasons of crew employment to
under 100 days/year. (Fren et al. 2008)
In addition to the governments attempt in
relieving overcapacity problem, overcapacity
has been a major concern of stakeholders too.
SNP, the most infuential association of fshing
companies, also proposed a decommissioning
program in 1998. SNP proposed that any
company that wishes to stay in the industry must
buy out 25,000 m3 feet from those who wishes
to exit. The association additionally proposed a
fund contributed by fshmeal producers with a
fee of $10 per ton of fshmeal exported (Anon
1998). Later i n 2007, the associ ati on of
small-scale feet operators requested the
government to buy back feets for them to be
able to leave the industry, and suggested a fund
contributed by boat owners with a fee of $2 per
ton of anchoveta landing. (PRODUCE 2007)
Since 2006, levels of capacity largely
depends on the concentration by largest
operators, for instance, the seven biggest
companies own 50% of fsh-hold capacity
(Arroyo 2007). There has been an ongoing
consolidation in the industry. Large fshing frms
purchased fshing capacity to grow (Anon 2007)
As of earl y 2009, the Peruvi an i ndustry
consisted of 140 fshmeal processing plants with
feet of 608 steel industrial and 592 wooden
vessels. (Aranda 2009)
Individual Vessel Quotas (IVQs)
Despi t e numerous eff ort s f rom t he
government and SNP, overcapacity challenges
remai ned. In 2008, Peru adopted a new
approach called Individual Vessel Quotas
(IVQs) to control capacity and eliminate the
race for fsh. Industry consolidation, driven by
expectation of IVQ legislation, helped alleviate
overcapacity problem, and the measure itself is
widely considered a regulatory innovation.
(Orlic 2011)
126
An IVQ system assigns rights to the
resource by allocating a share of the years
total allowable catch (TAC) to each fshing unit
i.e., each vessel in the anchoveta fshing feet.
(Grboval and Munro 1999; Perman et al.
2003).The large-scale and the small-scale feets
can apply for initial allocation of TAC with
distinctive criteria for each group. Rights
allocation is based on the best years of landing
in 2004 applied to 60% of industrial vessels. The
remaining 40% is determined by fsh-hold
capacity licensing. Specifc season quotas are
determined by multiplying these coeffcients by
that years TAC which is set by IMARPE. Every
fshing vessel must install satellite tracking
devices to ensure enforcement of seasonal
closures, and to ensure that harvesting will stop
after reaching individual quotas.
The IVQ allocation is carried out on a
temporary basis with the validity of 10 years.
Rights are attached with the vessel itself and the
fshing license. If a vessel is decommissioned,
its remaining quota shall be assigned to other
boats under the same owner. Additionally, if a
boat does not utilize its quota within a given
season, the quota cannot be carried over to the
next season. The model does not allow full right
transferability, a characteristic which may lead
to concentrati on of weal th among a few
operators, nor allow any new entries.
Orlic (2011) suggests that IVQ ends the
competition for increasingly larger shares of the
TAC and allows effort to be distributed over
l onger fshi ng seasons. Fl eet operators
maximize their effciency through careful
planning of fshing trip schedules, accounting
for abundance and proximity to shore to achieve
shorter and more successful fshing trips.
Consequently, the feet overall delivers fresher
landings, allowing for higher-quality fshmeal
production and ultimately higher profts with
lower costs due to less fuel consumption.
Since the IVQ legislation was issued in
2008 and implemented in 2009, it is still too
early to identify the impact. However, the frst
season showed promising results towards
achieving sustainability. (Orlic 2011) First, the
competition to increase larger portion of the TAC
quota no longer existed. Second, the average
daily catch has declined by more than 100,000
million tons per day to approx. 35,000 million
tons per day, which extended the catching
season to be longer than 100 days, from the
previous average of less than 55 days. Third,
unused vessels were scrapped, sold or shifted
the focus to other pelagic species; which
directly contributed to reduction of overcapacity.
In addition, the whole fshery gained
economics saving. Petrol consumption of the
feet was only 60% from the previous season.
Costs of fshmeal production plunged around
30%. Most savi ngs wer e f r om vessel
decommission and shortened journey. Fishmeal
processi ng faci l i ti es al so benefted from
higher-quality grade, generating 10% price
premium in the export market.
Despite the early proven success of the
IVQ scheme, a diverse set of challenges have
been identifed. On the one hand, the IVQ
system improves effciency of companies that
remain proftable. On the other hand, in an
overcapitalized fshery, many companies cannot
be assigned a suffcient quota to cover their
investment and operating costs. As a result, such
risks can lead to bankruptcy and unemployment.
However, in Peru, alternative employment for
fshermen has long been adopted from regular
shortened seasons from overcapitalized fshery.
For instance, The Fishers Compensation Fund
(Fondo de Cooperacin para el Desarollo
Social, FONCOPES) was founded to relieve
fshermens burden; this organization is funded
by feet owners on a mandatory basis. The fund
supports early and voluntary retirement of their
staff with upgraded pension and severance
packages. The fund also includes re-education
funds for worker relocation into others industries.
Overfshing and El Nio events
El Nio and severe overfshing were major
challenges that cause sharp plunge of the
Peruvian anchoveta industry, to the point of
collapse in the 1970s. To achieve sustainability in
later phases, the Peruvian authorities have made
decisions since 1964 based on continuously
collected science-based data from IMARPE.
127
IMARPE is a government marine research
agency recognized as a world class authority
by UN FAO, UNESCO, ICES and CIAT (IFFO
2009). They produce reports to the authorities
on maximum sustainable yield, ecosystem
conservation, and resource sustainability
considerations. IMARPE conducts acoustic
surveys to assess fsh populations three times
a year, together with plankton surveys to
estimate fsh abundance based on egg and
larvae density in situ. Further analysis is
conducted on data from the satellite or in
situ monitoring, including information on the
spatial distribution, size structure and school
depth of fsh and water temperature, and daily
real time verifcation of landings from all ports.
These are essential pieces of information
that the Vice-Ministry of Fisheries uses to
regulate fshing. Prior to setting of TAC or the
recent-launched TVQ quota of each season,
IMARPE plays a key role in making quota
r ecommendat i on t o ensur e r esour ce
sustainability. Since 1994, any management
measure has had to be backed up by a written
recommendation from IMARPE. Scientists and
politicians agree that dynamic changes in
anchoveta stock call for an equally dynamic
response e.g. fshing suspension can be
implemented in 36 hours (IFFO 2009). Several
ministerial solutions enforced to regulate the
industry tend to increase during the El Nio
events when the resource is vulnerable and
depressed.
Ari as Schrei ber and Hal i day (2013)
described that congruence between rules and
local environment conditions of the resource has
always been an important feature of the
Peruvian anchoveta fsherys sustainability.
The frst closed season was announced in 1965
for a month long (Agosto. 1965) in the
peak spawning period of anchovy population
(Checklet et al. 2009). Measures were taken to
ban catching if 50% or more of the catch
consisted of fsh that are 12 cm long or less (The
average size is 14 cm and the maximum size is
20 cm (Froese et. al 2012) and a weekend
landing prohibition was applied.
Figure 80: Peruvian rapid decision fow
on fshing closure (IFFO 2009)
I n gener al , MayJul y and August
September are two closed annual seasons to
allow spawning. During periods of instant
oceanographic or climate changes, short-term
closures are recommended on an ad hoc basis.
In the past 40 years, catch quota limits were
enacted with annual limits between 8-9 million
tons, in line with IMARPEs sustainable yield
assessment. (Clark 1976, Chavez et al. 2008)
As a rule of thumb, the level of exploitation or the
amount of fsh which can be taken must ensure
that at least around 5 million tons of spawning
biomass remains at sea (Arias Schreiber 2013).
128
At present, annual expenses of IMARPE
are around $15 million (De La Puente et al.
2011), 60% of which is used for anchovy
population monitoring. These expenses repre-
sent less than 1% of annual export values of the
Peruvian anchoveta fshery.
Another key challenge of the Peruvian
fshery is El Nio event. Despite decades of
monitoring the key resource data to ensure
sustai nabi l i ty, the degree of control that
multi-decadal climate variability exerts on
anchoveta stocks still remains uncertain, with
catch data and biomass estimates only available
for a few decades (only about two Pacifc
Decadal Oscillation (PDO) cycles). Uncertainty
about the impact of climate change compounds
these challenges, as discrepancies between
model predictions exist (Bakun 1990; Bakun and
Weeks 2008), making it more diffcult to enact
effective long-term fsheries policy. The idea of
setting up a fund to stabilize the industry has
been suggested to mitigate the economic risks
during extended closed seasons on future El
Nio events; such initiative has not yet been
rolled out.
Illegal fshing
The monitoring to ensure compliance with
rules has become more extensive, intensive and
effective during the sustainable phase in Peru,
compared to the previous unsustainable phase
when IMARPEs personnel undertook catches
monitoring but did not have an authority to
enforce compliance. With limited of resources,
monitoring a large amount of fshing vessels
during the long fshing season, for example, 223
days per year, while controlling overall fshing
activities was very problematic. In the past when
location tracking device was not available,
IMARPEs landing assessment was usually
underestimated by 20% between 1952 and
1982 (Castillo and Mendo 1987)
In the sustainable phase, although the
number of vessels decreased, the monitoring
one of the worlds largest fsheries continues to
be challenging. Since 1999, by legislation, each
fshing feet has been obliged to pay fshing
rights (drechos de pesca) equivalent to $3 per
ton of anchoveta landing. The collected funds
are used to fnance the operations of related
government units including IMARPE. Non-
payment will cause the sanction in the form of
fshing license withdraw.
In 2000, the law required all fshing vessels
to be equipped with Vessel Monitoring System
with satellite tracking system. (Gobeirno
del Peru, Ministerio de Pesqueria, 2000) All
commercial vessels which must operate outside
5 nautical-mile-limit reserved for artisanal boats
(by law) are ftted with the monitoring system.
Therefore, the government can track the
vessels real-time movement and location to
ensure enforcement of seasonal closures,
non-catching activities after reaching individual
quotas, and catching territory regulations. For
instance, spatial restrictions allow only artisanal
boats to operate within fve miles of the coast;
commercial vessels that possess fshing license
are permitted to fsh within the 200-mile limit.
The vessel monitoring system is on 24-hour
independent recording and reporting of landings
at 134 unloading points, to ensure that the entire
feet is complying with the rules in each territory.
The cost of this monitoring system is
absorbed by feet owners. The tracking system
allows IMARPE and inspectors from the Fishing
and Landing Monitoring and Surveillance
program to monitor landings at all ports before
transferring the surveillance of regulations
compliance to an independent international
company that is fnancially supported by fshing
frms. Annual cost of this monitoring system was
budgeted at $7 million from the fund raised by
a levy of $1.4 per ton of landing.
Fi shi ng operator must keep track of
announcements published in Perus state-
owned newspaper and online through the
Ministrys website, for information on when the
fsheries are open and closed. There will be
temporal restrictions and ports closures when
landings report more than 10% of juvenile
by-catch.
129
Pollution and Environmental Degrada-
tion
Di rect i mpact of fshery expl oi tati on
includes ecosystem impacts from by-catch
of nontarget species and trophic linkage
degradation. These have been shown to impact
ecosystem productivity, stability, and resilience
(Brunner et al. 2009). To lessen environmental
impact, Peruvian government released a
maximum 10% by-catch regulation; the mesh
size is at the minimum of inch (13 mm) and
begun outlining marine protected areas for
future implementation.
In addition to the catching activities, the
fshmeal processing industry has created both
air and water pollution. In 2008, Peru passed a
law to regulate both fshmeal plant water
discharge in pH value, solid and lipid content;
(PRODUCE 2008b), and introduced Maximum
Permissible Limits (MPLs) on emissions in 2009
with the policy to introduce clean technologies.
In 2004, a scheme, at the center city of fshmeal
processing, Apropisco, was introduced at the
port of Pisco which comprises the treatment of
effuent at each of the seven fshmeal plants
(which is the case for every plant) and then the
treated effuent is pumped to a central station
from where it is pumped far out to sea. The
scheme continued in 2007, when a decree was
introduced to implement a similar scheme at
Chimbote for all sea product factories - that is
treated waste from fshmeal, and freezing and
canning. (IFFO 2009)
There are also other requirements from the
government to control the processing industry.
Today, the Perus total fshmeal plant capacity
has been capped, and licenses are only issued
to move, merge, or replace previously existing
plants. Fishmeal plants must possess a working
permit conferred by the Ministry of Production
and a heal th certi fcati on from Peruvi an
Technological Institute (Instituto Tecnolgico
Pesquero or ITP) to ensure compliance with
safety regulations and controlling capacity
gr owt h and di s t r i but i on t o manage
environmental impact (FIN 2006; PRODUCE
2006). Every day, the Ministry of Production will
publish on its website (www.produce.gob.pe)
the name of the vessels authorized to go out
fshing, as well as names of the vessels that are
prohibited from doing so; processing plants are
not permitted to receive fsh coming from
vessels without a valid license or not listed on
the Ministries website. Furthermore, in case of
any failure in the processing equipment, the
processing plant must stop receiving fsh if there
is as well as in their equipment to protect the
environment. Processing plants are also not
allowed to operate outside the fshing season.
Orl i c (2011) found from the fshmeal
processing facility survey that some leading
fshmeal companies mitigated their environmental
impact through applying new technology to both
recover waste from fshmeal plant water
discharge, and reduce air emissions by replacing
conventional meal dryers with steam dryers,
wi th the added beneft of hi gher qual i ty
production and increased operational margins.
8.4 Lessons from Peruvian sustainability
In general, fshery sustainability cannot be
achieved by relying on one or more institutional
changes or any one players initiatives alone.
The sustainability of the Peruvian fshery is the
result of a multi-faceted and continuing process
of historical transformation and adaptations
(Arias Schreiber 2013). Constant attempts have
not been focused on a particular set of issues
or any one stakeholder group. A broader set of
solutions covering numerous stakeholders have
been implemented in order to manage this
complex and large industry.
Key factors of success in achieving fshery
sustainability in Peru include the following:
1) Continuation of fexible, adaptive and
rapid management strategies
Throughout decades, t he Peruvi an
government has applied the best available
long-record and latest science data to base
management decision in managing the fshery.
130
Political expediency allows Peru to rapidly drive
regulative actions, for example, announcement
of statutory and temporal restrictions and ports
closures when fnding more than 10% of juvenile
by-catch which could be achieved within
36 hours. The authori ti es al so careful l y
consider climate cycles with an effort to improve
predicting the variability and frequency of
relevant climate variables which can cause
anchovy population vulnerability.
2) Strong collaboration among various
group of stakeholders
Stock quotas in the form of both TAC
and IVQ schemes are effective and necessary
tools to accomplish sustainability in Peru.
The catch quota in each season is established
via consensus among the working group of
scientists and politicians. For fshing companies,
trade association SNP acts as an institution
responsible for the resolution of conficts
between resource users and actively lobbies
for tax and policy benefts for its members.
In addition, the government and diverse
stakeholders in the sector founded Sectorial
Working Commission to discuss and provide
advice to the authorities when confict arises or
when the country enters a resource-crisis
period. The commission is comprised of offcials
from the Ministry of Production, Treasury, and
industry representatives from SNP.
3) Congruence with local environment
conditions and costs and benefts
Periodic closure of fshing seasons has
been one of the key tools to accomplish
sustainability. As mentioned, Peruvian general
management measures such as quot a
recommendation or temporal restrictions are
made on ad hoc basis based on scientifc
information from IMARPE. During El Nio
events, numbers of ministerial resolutions tend
to increase to relieve stress and instability of
the affected resource. Congruence between
costs and benefts has always been high since
taxes, fshing licenses; and funds to cover
management , moni t ori ng and sci ent i fc
research have been calculated based on
amount of landings or fshmeal processed.
The pract i ces are st rai ght f orward and
enable the fshery industry to maintain the
equivalence between cost and beneft in a way
that resources users perceive fairness (Arias
Schreiber and Halliday 2013).
4) Clearly established boundaries with
regular adjustments of rules and regulations
The main General Fisheries Law provided
the basis for sustainable management by
clearly setting boundaries i.e. determining who
is permitted to participate in the fshery, what is
their level of access, what are different rights
and boundaries between commercial and
artisanal feets, etc. Through fve decades,
Perus fshery law has been amended several
times to add the context of sustainability,
envi ronmental conservati on, and soci o-
economic development. Extended groups
of stakeholders have been integrated into
the law e.g. artisanal fshers. When previous
measures led to weak results, such as the total
allowable catch (TAC) which resulted in the
race for fsh crisis, the authorities learn from
the outcome and successfully improved it into
the present successful Individual Vessel Quota
(IVQ) scheme.
5) Centralized top-down management
In the past few decades, Peru was ruled
by t he mi l i t ary whi ch t hen t ransi t ed t o
democrati c governments, but the l i ne of
legislative control has not been changed from
the centralized top down management. A top
down regime may not hinder sustainability in
the anchoveta fshery. Being a commercial
large-scale industry comprised of numerous
fshing companies in complex tiers of chains;
all possibly seeking to maximize profts on
scarce common resources, the governments
top-down management approach may be the
most appropriate institution. For instance, in
solving the decade-long overcapacity problems,
enforcement from centralized authorities was
quite effcient in interconnecting and controlling
numerous feet owners in both the commercial
and artisanal scales, processing companies as
131
well as others who felt impact from the changes.
6) Applying technology in monitoring and
enforcement
Because the Peruvians fshery measures
and policies have been launched, planned and
improved based on scientifc oceanographic and
landing data, precision of information is vital.
Mandatorily funded by fshing companies, the
government has invested in a robust monitoring
system under the operation of IMARPE e.g.
using acoustic techniques to estimate fsh
bi omass. The recent l aunch of Vessel
Monitoring System with satellite tracking
system enforced in every vessel allows the
government to track the feets on real-time
movement to ensure their regulation and quota
compliance.
Despite being one of the worlds large-
scale fsheries working with a vast network of
stakeholders and complex tiers of supply
chains, Peru has successfully proven that
fshery sustainability is a possible in practice.
Even though the country, as the worlds leading
exporter of fsh oil and fshmeal with strong
incentive to increase production to respond to
rising demand in world market, the Peruvian
authorities have seriously managed anchoveta
resources to achieve long-term sustainability,
such as closing fshing grounds when there is
a resource crisis or natural disasters. The
Peruvian fshery, the countrys second largest
industry, is clearly in pursuit of long-term
envi ronmental and soci al i mpact rather
than short-term fnancial gains. Lessons
learned from suffering for over a decade
from the landing collapse, as well as ongoing
climate changes, have driven Perus fshery
to move to a path of sustainable development,
t o ensure t hat Peru can mai nt ai n t hei r
competitiveness and grow a robust sector
without depleting key marine resources.
132
IMPACT OF SUPPLY CHAIN ACTIVITIES,
GAP ANALYSIS, AND RECOMMENDATIONS
9.
9.1 Direct Impacts on Thai marine
ecosystem
A main activity that creates direct impacts
on Thai marine system is fshing, particularly by
otter board trawlers and push nets which are
considered destructive fshing gears. Fishmeal
and animal feed industries are usually said to
be one of the causes of problems because
fshmeal producers buy trash fsh caught by
trawlers and push nets that destroy marine
ecosystem and usually overfsh, while animal
feed mills buy fshmeal produced from these
trash fsh.
Trawlers and push nets create negative
impacts on Thai marine ecosystem in three
ways: 1) they sweep the bottom of the sea and
destroy coral reef which is habitats of fsh and
other marine fauna causing the change of
marine ecosystem structure 2) they usually use
small size mesh which will catch juvenile fsh,
and 3) they usually overfsh.
9.2 Indirect Impacts on Thai marine
ecosystem
Some activities of players in the supply
chain may not cause direct impacts to the
marine ecosystem; however, they support
continued existence of problems. The two
stakeholders whose activities cause the most
indirect impacts on Thai sea ecosystem are
fshmeal producers and animal feed mills.
Fishmeal producers activities create
economic incentives for fshery businesses to
continue their unsustainable practices in four
ways:
First, without buying criteria and supplier
screeni ng, t rawl ers and push net s are
economically incentivized to continue their
practices as whatever they captured, no matter
how bad its condition is, can be sold to fshmeal
producers as it still yields high enough protein.
In Songkhla, most fshmeal producers set their
buying criteria and screen their suppliers; they
usually buy from their regular suppliers, and
they do not buy very bad conditioned trash fsh
caught by trawlers usually for two reasons: 1)
their factories are in the communities, and using
t hese t r ash fsh i s t oo smel l y f or t he
communities, and 2) their factories produce
good grade fshmeal e.g. 2nd grade, so they
cannot buy these trash fsh that will yield lower
grade fshmeal.
However, there is one fshmeal producer in
Songkhla that does not have buying criteria for
trash fsh sold to its factory, because the fshing
boats owners are relatives of the factory owners;
Therefore, this fshmeal producer will buy
whatever is sold to it no matter how bad the
133
condition, and the condition is usually bad; trash
fsh is mashed up, spoiled and very smelly. In
this case, fshing boat owners are encouraged
to continue their unsustainable practices as they
know that they can always sell to at least this
one fshmeal producer.
Second, buying trash fsh creates demands
for them. Thus, when the fshing boat owners
know that trash fsh can always be sold, they
will continue their practices as mentioned
earlier that income from trash fsh is one third
of some trawlers which is better than nothing. If
they know that there is a market for it, why would
they throw away their extra income, and a
fshing trip itself costs a lot of money wages,
gas, foods, water etc.
Thi rd, mi xi ng fshmeal can upgrade
fshmeal to be sold for a better price. Different
qualities of raw materials yield different grades
of fshmeal, and different grades of fshmeal can
be sold at different prices. However, since there
is not much discrepancy of protein between
different grades, some fshmeal producers will
mix high-protein fshmeal with lower-protein
fshmeal in order to upgrade fshmeal to sell for
better prices. This creates demands for low
protein fshmeal as fshmeal producers know
that it can be mixed to increase the percentage
of protein later on. Therefore, demands for
low-quality trash fsh continue unabated,
and therefore unsustainable trash fshing
continues.
Animal feed mills activities that cause
indirect impacts are similar to those of fshmeal
producers, since animal feed mills are the main
consumers of fshmeal produced from trash fsh
or fsh caught unsustainably; therefore they are
the ones who actually create demands for trash
fsh. It starts when they set buying criteria.
Animal feed mills set buying criteria and prices
based on qualities of the fshmeal alone, not by
how fsh raw materials of fshmeal were
caught. Thus, fshmeal produced from trash fsh
caught by trawlers and push nets that destroy
marine ecosystem can be sold to animal feed
mills. This encourages fshing boat owners to
continue their unsustainable fshing practices.
We observe three key limitations of current
sustainability standards and certifcate schemes
as currently practiced in Thailand:
1. There i s currentl y no sustai nabl e
sourcing scheme or standard that all major feed
mills subscribe to. Unless any scheme/standard
incorporates all large feed mills, there would
still be a market for fshmeal produced from
irresponsibly-sourced raw materials such as
trash fsh, and therefore this practice will
continue.
2. Most schemes rely on a self-report
mechanism. Nothing can assure full traceability
or guarantee that the fshermen themselves
fll out the necessary documentation. More
specifcally, the source of fshmeal raw materials
cannot be verifed due to the lack of location-
specifc audit mechanisms, e.g. satellite-
positioning tools to ascertain that the fshing
boat is really fshing at the stated location.
Therefore, it is currently only possible to check
whether the documents are flled out correctly,
not the correctness of the document contents.
3. Currently every sustainable sourcing
scheme and st andard i s based on t he
internationally accepted defnition of IUU
Fi shi ng the catch must not be Il l egal ,
Unreported, and Unregulated to ft under this
defnition. But due to Thailands outdated
fshery l aw, what i s wi del y consi dered
destructive fshing conduct e.g. small mesh
si ze of trawl s, i s not i l l egal i n Thai l and.
In addi ti on, every i l l egal conduct under
fsheries law is considered illegal only when
the fsherman is caught in the act. Therefore,
dest r uct i ve fshi ng i n Thai l and i s not
considered IUU Fishing, and therefore no
st andard based on I UU can eff ect i vel y
di scourage t rash fsh t rawl i ng. Thi s i s
exacerbated by i nsuffci ent control and
moni t or i ng s y s t ems due t o l i mi t ed
resources. Consequently, illegally-caught
marine products can be landed legally.
Key stakeholders activities and impacts on
Thai marine ecosystem are summarized in
Figure 81.
134
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135
9.3 Gap analysis and recommendations
Lessons that Thailand can learn from the
case study of Perus sustainable fshing industry
also show gaps in the current attempts toward
sustainable practices as follows:
1. Since overfshing and destructive fshing
are tragedy of the commons problem in
economics parlance, where efforts of a few
unscrupulous players i.e.
free riders can ruin the resources for
everyone, i t i s necessary to i mpl ement
solutions and standards across the board, i.e.
encompassi ng every st akehol der. Peru
successfully utilizes a combination of laws
(e.g. IVQs, mesh size, by-catch regulation,
seasonal closure, fshing rights) and industry
i nvol vement and sel f-regul ati on (SNPs
participation in setting quota and resolving
conficts) across the board, while Thailand still
has serious gaps from the legal defnition (e.g.
trash fshing still not categorically illegal,
practices considered only illegal when caught
in the act), weak enforcement, to piecemeal
parti ci pati on of standards and vol untary
schemes (e.g. only one feed mill is offering
monetary incentives under fshmeal certifcate
scheme).
2. Science-based data and technology
are both vital to ensure fsheries sustainability
and effective enforcement. IMARPE, major
government marine research agency in Peru, is
recognized globally as a world class authority,
continually reporting maximum sustainable
yield, ecosystem conservation, and resource
sustainability considerations to the government
on which to base decisions such as quota
setting. On the technology front, all commercial
fshing vessels in Peru are required to install
satellite tracking devices to ensure enforcement
of seasonal closures and individual quotas,
since the government can track the movement
and location of vessels in real-time. In Thailand,
there is yet no sustainability standard or scheme
which includes satellite tracking of fshing boats
to ensure that traceability documentation is
correct, and maximum sustainable yield is not
yet a part of systematic decision-making at
policy level.
3. The clearer the business case for
sustainability, the more incentives players have
to comply with sustainability laws/standards/
schemes. In Peru, IVQs helped encourage feet
operators to maximize their effciency through
carefully fshing trip scheduling, accounting for
abundance, and proximity to shore to achieve
shorter and more successful fshing trips.
Consequentl y, the feet recei ves fresher
landings, providing higher-quality fshmeal
production and ultimately higher profts with
lower costs due to less fuel consumption.
In contrast, there is as yet no clear business
case for sustainability in Thailands fshmeal
industry in Songkhla; most fshmeal producers
that participate in the fshmeal certifcate
scheme do so only because they are paid
a price premium by the buyer (currently only
CPF), or they must do it as part of the buyers
requi rement. There i s onl y one fshmeal
producer that cites competitiveness as the
reason they parti ci pate i n the scheme;
since they cannot compete on quality, they
offer full traceability to build credibility and
trustworthiness.
136
Figure 82: Gulf of Thailand at night, as seen from space
Figure 82. Thousands of fshing boats doing lit fshing show up as green lights clustered the Gulf of Thailand
are seen in this still from a night video of East Asia taken by astronauts aboard the International Space Station,
released by NASA in February, 2014.
65
65
Sara Schonhardt, Whats the One Thing in Thailand Visible From Space?, Wall Street Journal, February 28, 2014. http://
blogs.wsj.com/searealtime/2014/02/28/whats-the-one-thing-in-thailand-visible-from-space/
Given the above major gaps between
current practices and best practice in Peru, we
believe it is imperative that all current efforts to
move the fshmeal industry in Thailand towards
a more sustainable pathway from new
fsheries law to the industrys latest Fisheries
Improvement Project are synchronized and
truly encompass all stakeholders, designed to
close the above gaps as much as possible with
a view toward long-term sustainability of marine
ecosystems in Thailand.
137
Chapter 2
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of Trawl Fisheries in Thailand (Translated from
Thai). Bangkok: Marine Fisheries Research and
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Bureau of Agricultural Economics Research (BAER),
Ministry of Agriculture and Cooperatives of
Thailand (MOAC). (2012). A Study of Econom-
ics of Fishmeal Production and Market under
the Quality Assurance System (Translated from
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Bangkok: Bureau of Agricultural Economics
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Department of Fisheries, Ministry of Agriculture and Co-
operatives of Thailand (MOAC). (August, 2013).
Marine Production (translated from Thai). Docu-
ment presented at seminar Thailands Fisheries
in the Future, Bangkok .
Department of Fisheries, Ministry of Agriculture and
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tion of Thai Fishing Gears (Translated from Thai).
Retrieved October 30, 2013, from http://www.
fsheries.go.th/DOF_THAI/Division/Web_gear/
HP_ main.html.
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Thai). Retrieved October 30, 2013, from http://
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Trash fsh composition
A report prepared for FAO (Kungsawan 1996, http://www.fao.org/docrep/w6602e/
w6602e09.htm) asserted that very little discarding now takes place at sea in the
Thai fshing industry; this gels with observations made at fsh landings in southern
Thailand.
The trash fsh component of the catch which is called true trash and made into
fshmeal is made up a number of species the predominance of which depends on
the fshing methods and areas. The most common families/groups are given in Table
1 below.
Table 1 below. Table 1. Main species in the true trash component
Species group Rough proportions in trash
Leiognathidae High
Trash crab High
Apoginidae Medium
Gobiidae Medium
Balistidae Medium
Biohidae Medium
Tetraodontidae Small to medium
Callionymidae Small to medium
Pentapodidae Small
Daya spp Small
Periophthalmidae Small
Platycephalidae Small
Scorpaenidae Small
Bragmaceros spp Small
Synancedae Very small
Pentaprion longimanus Very small
Siganus spp Very small
APPENDIX
150
Small species of fsh such as threadfn breams, monocle breams and croaker, are especially
sorted from the rest for production of surimi type products and fsh balls. Local traditional products
such as salted dried fsh, fsh sauce, fermented fsh, shrimp paste and dried cephalopods are also
made from bycatch. Note that many species from several of these groups have now been
reclassifed as food fsh, both in practice and in fsheries statistics.
Table 2. Main commercial fsh species caught as juveniles in the Thai shrimp bycatch
Common Name Scientifc Name
Indian anchovy Rastrelliger kanagurta
Lizard fsh Saurida isarankurai
Lizard fsh S. undosquamis
Lizard fsh S. elongata
Threadfn bream Nemipterus hexodon
Threadfn bream N. mesoprion
Purple spot bigeye Priacanthus tayenus
One-fnlet scad Atule mate
Yellowstripe scad Selaroides leptolepis
Monocle bream Scolopsis teaeniopterus
Tonguesole Cynoglossus spp
Flathead fsh Platycephalus spp
Deep bodied trevally Atule kalla
Source: Kungsawan A (1996) Regulations, practices and statistics with regard
to by-catch in the shrimp industries in Thailand. Paper prepared for FAO - mimeo 1996
151
List of Interviews
Date Organization Participants/Interviewees
21/7/2013 Thai Sea Watch Association Banjong Nasae, Chairman
23/7/2013 Paesae Songkhla Sunee Apinuntanapong, Factory Manager
Aquatic Science, Faculty of Natural
Resource, Prince Songkhla University
Jarunee Chiayvareesajja, Dr., Researcher
24/7/2013 Southern Fish Powder Factory 1969 Pisit Suksriwan, Factory Manager
Songkhla Fishery Department Sayan Eamrod, Director Sahas, Offcial
Pacifc Fishmeal Industrial Sak Lertwanangkul, Factory Manager
7/8/2013 Thai Fishmeal Association Sanguansak Akaravarinechai, President
Nichkamol Kumaree, Manager
22/11/2013 Marine Fisheries Research and
Development Bureau, Department of
Fisheries
Suchada Boonpukdee, Fisheries Senior
Technical Specialist
26/11/ 2013 Marine Fisheries Research and
Development Bureau, Department of
Fisheries
Nawaporn Lert-umnuaychok,
Fisheries Biologist Waraporn Norsit,
Fisheries Biologist
4/12/2013 Marine Fisheries Research and
Development Bureau, Department of
Fisheries
Manoch Roongratri, Director Marine
Fisheries Research and Development
Bureau Komonpan Awaiwanont,
Dr., Fisheries Senior Technical Specialist
21/1/2013 Thaiunion Feedmill Supis Thongrod, Dr., Director of Product
Research & Development
27/1/2014 Songkhla Marine Fisheries
Suppression and Prevention Center
Seri Petchrit, Chief
Paesae Songkhla Sunee Apinuntanapong, Factory Manager
Songkhla Fish Inspection and
Research Center
Suntorn Kumsuk, Director
28/1/2014 Southern Fish Powder Factory 1969 Pisit Suksriwan, Factory Manager
Thai Charoen Animal Feed Sukanya Pankerd
Pacifc Fishmeal Industrial Sak Lertwanangkul, Factory Manager
29/1/2014 Songkhla Marine Products Suvit Tanratanakorn, Owner
Jana Fish Industries Pichart Piwbangkul, Deputy Factory
Manager
Marine Fisheries Research and
Development Bureau, Department of
Fisheries
Suchada Boonpukdee, Fisheries Senior
Technical Specialist
152
Date Organization Participants/Interviewees
30/1/2014 Marine Fisheries Research and
Development Bureau, Department of
Fisheries
Suchada Boonpukdee, Fisheries Senior
Technical Specialist
10/2/2014 Thai Feed Mill Association Pornsilp Patcharintanakul
13/2/2014 Charoen Pokphand Foods Lucksamee Paiboon, Senior Vice
President Aquaculture Feed Technology
Offce
Pitipong Dejjarukul, Assistance Vice
President, Feed Raw Material Offce
AQUA FEED BU
Companies in Songkhla fshmeal supply chain that declined to be interviewed
Company Stated Reason
Betagro, Animal feed mill The company uses very little fshmeal.
Krungthai, Animal feed mill The company has no policy to be interviewed and disclose
the information.
Lee Pattana, Animal feed mill The company has not offcially rejected, but it has not
responded to our several requests.
Songkhla Fishery Trading,
Fishmeal producer
The company is a very small company currently operating
once a week. However, the company gave partial information.
Sangcharoen Wattana Fishery,
Fishmeal producer
Could not be reached.
Sinakorn, Fishmeal producer Out of business.