Efficiency (fisheries) | Food Policy for Canada

Additional steps towards co-management, co-monitoring and ecosystem knowledge (including revisions to advisory boards)

Design and execution of stock recovery plans

Owner-operator and fleet separation requirements

Support for fishing co-ops and fish harvester organizations

Sustainable fishery certification

Restricting tourism recreational fishery and angler competitions to catch and release or put, grow, take

Revisions to recreational licensing

Improving local and direct markets

Intro to solutions

Making changes to this complex situation definitely requires some concerted transition planning. Such planning has been undertaken before by DFO (e.g., Preserving the Independence of the Inshore Fleet in Canada’s Atlantic Fisheries (PIIFCAF), see below) so it is a familiar process. The transition is informed by the following objectives and principles (adapted from Ecotrust and Suzuki, 2018):

Optimizing the economic and social viability of fish harvesters, and resilience of fishing communities
Facilitating the entry of new fishers (and especially youth) to be next generation of fishers
Ensuring that the full and true value of seafood is realized
Conserving healthy fish stocks for current and future generations
Reconciliation with Indigenous peoples, which means Nation to Nation discussions and prioritizing the Indigenous fishery relative to non-aboriginal fisheries, especially those related to sport and recreation.

Principles for transition planning, such as:

Making transition as easy and cost effective as possible for all parties
Minimizing difficulties for those fishers negatively affected by changes to rules and programming
Facilitating transitions for processors, but only to the extent that fish processing for domestic markets is remains viable, the presumption being that those with sufficient resources to participate in international markets will adapt progressively to the new realities
Maximizing buy-in and community/industry cohesion

Additional steps towards co-management, co-monitoring and ecosystem knowledge (including revisions to advisory boards) (adapted from Ahmed, 2019)

Co-management arrangements are highly varied, from top-down hierarchies to industry self-management (for many different co-management models that are more effective than those used in Canada, see Ecotrust and Suzuki, 2018). Co-management is used by DFO currently to describe its management relationship with the fishing sector, despite DFO retaining most of the decision-making power in the relationship. It is also used within a narrative that furthers the privatization of the fishery for the benefit of limited corporate interests. These configurations of co-management are not consistent with the purposes and transition principles articulated here. Nor does current departmental practice seem consistent with the language of section 2.5 of the Fisheries Act (unless the department considers the language of "the minister may" to provide them an out compared with "the minister shall"). Under section 4.1, however, the Minister is authorized to enter into agreements with co-management bodies. The 2019 mandate letter to the Minister of Fisheries and Oceans (re-iterated in the 2021 letter) tasks the Minister with continuing implementation of the amended Fisheries Act.

Small-scale fishermen and the communities they were once embedded within are quickly losing access and independence within the fishery. If the aim of co-management is to empower those whose livelihoods are most directly affected by management decisions (Berkes 2009), simply undertaking co-management with any group that has the time, resources and incentive to participate in a government-prescribed process is not enough. Co-management as it currently exists hinders the development of a fishery management system that is effective and just.

In the literature, there are many concrete examples of co-management in the fisheries being effective (for a summary, see De Schutter et al., 2019:383). The benefits of co-management in increasing effectiveness are predicated on an open and accessible incorporation of all participants into critical decision-making conversations (Pinkerton 1994; Quimby and Levine 2018). Canadian co-management institutions, with some notable exceptions, are only open to a select few participants, do not provide an effective forum for discussion and genuine power-sharing, and exist on a single, geographically large scale that is not accessible for most small-scale participants. The DFO-created advisory process engages in consultation more than any kind of power-sharing, and therefore can only be classified as co-management in a vague sense (Berkes 2009; Castro and Nielson 2001). To call it co-management, DFO must engage in open dialogue and collaboration on what exactly co-management should look like; who is engaged in this conversation is of critical importance.

"Getting to co-management involves institution building, the development of trust and social capital," (Berkes, 2009, 1694), so the first stage of transition is altering the institutions and processes of knowledge generation and decision making. Simply devolving power and responsibility, however, without attention to who benefits can lead to 'capture' of power by neoliberal rhetoric, which also benefits from devolution (Mansfield, 2004a). Pinkerton et al. (2018) and Berkes (2009) argue that local leadership or 'bridging organizations' between the co-management partners are necessary for successful collaboration: currently, there are few such organizations with the capacity or mandate to fulfill this role.

A critical necessity for functional co-management is open and transparent information sharing (Pinkerton 1994). Knowledge about the resource must be freely shared and collaboratively produced for it to have lasting legitimacy (Berkes 2009). Reciprocally, co-production of knowledge is a dynamic process that can only work in a context of open, transparent dialogue and the development of trust and respect of alternate knowledge systems (Berkes 2009). It also serves as a mechanism to improve ecosystem health outcomes (Berkes 2009; Eamer 2004). The processes and protocols for integrating western science and indigenous knowledge are increasingly developed and practised (cf. Alexander et al., 2021; Buxton et al., 2021; Henri et al., 2021).

At the efficiency stage, advisory committees/boards must be reconfigured and repurposed. There are many of them, but only a limited number serve as examples of co-management on which to build, the agreement with the Haida on Haida Gwaii being one positive example. And as part of this, bridging organizations must be built or strengthened (see also Support for Co-operatives and Fish Harvester Organizations). Many West Coast Advisory Boards have been criticized for structural problems that result in focusing more on license-holders than active fishers, for DFO participation with less senior staff, and for a failure to reflect Advisory Board advice in decision making, particularly related to stock assessments.

There appear to be more viable co-management foundations on the East Coast. For example, Lobster Fishing Area 22, Magdalen Islands is managed by a committee that "relies on fishing input controls, fishing season closures, size limits, trap limits and restrictions, and other gear limits. No quotas are in place, but rather a homogenous effort quota is represented by a maximum of the number of traps per fisher, and a limited number of fishing hours." (Ecotrust and Suzuki, 2018:63). The management committee is primarily fishers with a partnership with the Quebec Ministry of Agriculture, Fisheries and Food (MAPAQ). This integrated fishery management approach has been in place since 2010 and has resulted in MSC-certification, and increased landings and sale prices. However, the processors are opposed to this model and it is, as a result, under constant pressure.

Although flexibility is required for each region and fishery, this kind of actively engaged management committee is required in all regions/fisheries. For many First Nations, collaborative management already exists through Indigenous governing bodies and the Minister can issue communal licenses under the Fisheries Act and Regulations. At a minimum at this stage of transition to co-management (adapted from Lowitt et al., 2019), governments and First Nations should have fishing agreements addressing key aspects of co-management including full recognition of Aboriginal and Treaty rights, territorial boundaries for commercial fishing, monitoring and compliance, information of fish stocks to be exchanged, and total allowable catch for commercial harvests. From a settler government's perspective, this establishes a cooperative framework to help ensure that a First Nations' commercial fishery and non-aboriginal fishing can co-exist coexist, while maintaining a sustainable fishery. From a First Nations' viewpoint, although incomplete (see other proposals at the Substitution and Redesign stage), some feel these agreements represent a step towards reducing blockages to self-determination and ensuring the exercise of rights and and culture without discrimination from settler governments or settler society. So, the legal framework is in place for such approaches, but DFO budgets and processes must be adjusted to implement them.

Once constituted, a key early task of these advisory boards and First Nations governance processes is helping FOC/DFO complete Integrated Fisheries Management Plans (IFMP). Both a working document and a process, IFMPs provide information on a given fishery including “scientific aspects [and] management objectives for the fishery, management measures used to achieve those objectives, and criteria by which attainment of objectives will be measured” for “fisheries managers, other DFO sectors…, legislated co-management partners, fishery participants, other stakeholders and the general public” (Government of Canada, 2013). IFMPs are meant to address three main factors:

“(1) The requirement to incorporate the Sustainable Fisheries Framework, in particular the precautionary and ecosystem approaches to fisheries management; (2) The demands of Canadians seeking more stability, fairness and transparency from fisheries management systems; and (3) The need to put in place a rules-based approach to decision-making, which is transparent, rigorous and systematic” (Government of Canada, 2013).

According to Oceana (2018), 25% of marine Canadian fish stocks do not have an IFMP so completing those within an emerging co-management framework is a priority. Similarly, inland fisheries IFMPs must be completed and it is unclear how many have nothing in place. Nunavut has numerous elements of knowledge sharing that other jurisdictions might replicate to devise integrated plans. One aspect of their strategy is the Nunavut Coastal Resource Inventory (NCRI), operated by their Fisheries and Sealing Division, which assists communities, co-management partners, the territorial government and others to identify opportunities for inshore fisheries development by mapping and documenting Inuit knowledge. This knowledge informs resource development, management plans, land use and conservation (Nunavut Fishing Strategy).

Design and execution of stock recovery plans

Under section 6.2 of the Fisheries Act, the Minister is authorized to rebuild fish stocks for those depleted. As discussed under Current State of the Fishery, 26 fish populations are considered critically depleted and only 3 have recovery plans in place (all in the Pacific Fishery). As assessed by Oceana (2018), these 3 are all significantly limited in scope. Eleven other plans are in development with completion dates targeted originally between now and 2021 (some are listed as delayed), and little work as been accomplished on 12 (one of which had a plan that expired in May 2018). Stock recovery plans can typically including season/fishing hour limits, area restrictions, input and gear restrictions, size and trap restrictions, license restrictions, and ultimately bans. As an example of the relationship between gear, markets and recovery plans, in Newfoundland, a number of communities are using single hook handline gear in the cod fishery as part of a strategy to limit harvest and contribute to stock recovery, and because of the quality of the fish, generating higher prices / lb selling into premium markets (Verma, 2021). Interesting work on ropeless gear also holds promise for reducing negative impacts on non-fishing species and thereby contributing to confidence in the viability of some fisheries (MacDonald, 2022). This is a voluntary undertaking but such ideas need greater consideration in stock recovery plans.

Three areas of work are required at this stage (adapted from Oceana, 2018):

Upgrade the three existing plans based on more recent abundance assessments and fuller evaluation of the effectiveness of measures in the plans. Each plan needs to assess the merits of a full range of measures, including bans and season/fishing hour limits, area restrictions, input and gear restrictions, size and trap restrictions, license restrictions,
Develop and publish rebuilding plans for five priority stocks within the 11 for which work has commenced:
- Atlantic cod – Scotian Shelf and Bay of Fundy
- Atlantic cod – Georges Bank
- Atlantic cod – northern cod
- Yellowtail flounder – Georges Bank
- Northern shrimp – shrimp fishing area 6
For the remaining stocks, complete more of the preliminary work that will then allow for development of a full recovery plan. Some stocks do have preliminary plans developed by other organizations, from which a full Canadian plan can be built.

For freshwater fish species, subspecies, and DUs, 36 are endangered, 35 are threatened, and 32 are of special concern (in the COSEWIC categorization).

Importantly, IFMPs were found to offer more protection to species listed under the Species at Risk Act (SARA, see also Goal 5 Wildlife Protection and Species at Risk) than species that were not (McDevitt-Irwin et al., 2015). Listed species in IFMPs had significantly more conservation methods than their non-listed counterparts, and there was also a notable difference in the type of conservation measures the species received based on their listing. Most SAR were covered by four basic measures in IFMPs; efforts include control of their harvest, mitigating their bycatch, spatial or time-based closures of important areas, and some reference to the Sensitive Benthic Areas policy. Conservation measures limited to mostly listed SAR included actual policy on their bycatch, Sensitive Benthic Area-related protections, as well as habitat protections. Precautionary reference points, which conservatively estimate the sustainable removal rate of fish, were all but absent for a single species (McDevitt-Irwin et al., 2015). IMFPs, however, are not legally binding, and inclusion of conservation measures in these documents does not necessarily mean their implementation is enforced or monitored for efficacy. These trends indicate that SAR who are not-listed, and are therefore not protected under SARA, may also not be receiving sufficient protections under the Fisheries Act (McDevitt et al., 2015).

Obviously more resources are required to keep DFO up to date with its own work plans. There is evidence that budget cuts to the Department have reduced its capacity to fulfill its obligations. See Financing the Transition for more discussion about how our siloed approach to budgeting and the failure to invest in prevention strategies results in significantly increase public expenditures. See also Goal 5, Wildlife Protection and Species at Risk.

Owner-operator and fleet separation requirements

The Fisheries Act and General Regulations support the owner-operator principle for licensing, but unfortunately regional agreements that supercede the Act and General Regulations weaken these provisions. The result is that regional policies and directives produce very different realities for the West and East Coast fisheries.

Perhaps most importantly, average income for fishers in the Atlantic has substantially increased between 2000 and 2015 relative to the Pacific Coast and not because of the value of landings (Ecotrust and Suzuki, 2018). The problem is who captures value and that is intimately linked to the question of transferability of quota and license, and the associated costs of leasing quota.

In the Atlantic region, 4 regional instruments are applied that, despite historical loopholes that may now be further closed by recent changes to the Fisheries Act, have helped protect small to medium scale fishers.

In contrast, on the Pacific Coast, 12 of the 20 main commercial fisheries have ITQs and there is strong evidence of shifts in control from small to large economic actors and from more remote coastal communities to urban centres, from owner-operators to processors and investors . Many examples of lease price manipulation and limited access to fish have been documented associated with these high degree of corporate consolidation in the ITQs (Ecotrust and Suzuki, 2018).

At this stage, the measures that have been successful in the Atlantic fishery should be adopted in the Pacific fishery. There is some resistance to this idea even among those who would presumably benefit from the shift. Some of the opposition presumes that economic power and price setting ability remains with processors, so proposals elsewhere address that constraint. Equally important, many are worried about workload and safety in an owner-operator environment and this is why collaborative arrangements are important, which is discussed further under other subsections.

Support for fishing co-ops and fish harvester organizations

As discussed under co-management, and highlighted by Ecotrust and Suzuki (2018), the construction or revitalization of fish harvester organizations that aggregate fishers is an important piece of building co-management and shifting power dynamics in the industry. Harvester organizations can take multiple forms, ranging from First Nations structures, to unions, to a trade association model, to an NGO structure, to a co-operative. What's critical to all them is aggregating activity and functions to create more collective power for small fishers because in the current environment of Individual Quotas, corporate consolidation and power asymmetries, small fishers are price takers, having limited to no influence over prices they pay for inputs and prices they receive for their fish.

Many organizations are formed by its participants without external assistance, but frequently the challenges of working together, especially in economically challenging circumstances, result in failed attempts to organize. Most government grant programs assume that organizations are already functioning. Economic development and Innovation grants often focus on hard infrastructure or product development rather than human and social capital. Others focus on community network development, which is often significant, but the challenges here represent a precursor to network formation. Requirements can often be very modest, since most struggling to form groups need outside facilitation and advice on organizational design. Some provinces have offered support to co-operative formation, but not necessarily a full range of organizational forms. At this stage of transition, provincial and territorial governments must adapt at least one existing program to provide such supports to fisher organization formation. The federal government can support the creation of a fish harvester - led entity that would take over some, if not all, the functions of the Freshwater Fish Marketing Corporation (Anderson, 2020).

Sustainable fishery certification

As with other areas of the food system, the combination of government and market failure and consumer interest in sustainability has generated a sustainable certification process led primarily by NGOs and private foundations (for some history, see Winson et al., 2021). The main independent sustainable fishery certifier is the Marine Stewardship Council (MSC), in operations since 1997. A smaller certifier is Friend of the Sea. Other labels that appear in Canadian supermarkets include Dolphin Safe, Ocean Wise, SeaChoice and Responsible Fishing Scheme. Some are essentially Sustainable Seafood Guides, many based on the Monterey Bay Aquarium’s Seafood Watch Program, but this is a weaker approach. Marine Stewardship Council's certification scheme remains the most highly-regarded program though FOTS' scheme also meets high standards and is growing quickly. However, both these schemes suffer from significant shortcomings and, in FOTS' case, suffer from a lack of widespread availability in Canada.

As with Sustainable agriculture certification (see Goal 5, sustainable food production), these programs have a number of weaknesses (adapted from Sundar, 2017):

Usually a response to state and market failure, but by existing may let the state off the hook for addressing its failures
Limited resources relative to the state; who pays is a significant issue since many smaller operators have limited resources to address monitoring, inspection and fee requirements
Limited application, voluntary, market – driven
Standards and certification can be weak; limited public scrutiny of standards construction and execution
Don’t necessarily address power relations; often reinforce them by focusing on large actors with resources to participate and passing liability to least powerful actors in the supply chain
Individual species certification can not fully account for ecosystem dimensions of problems
Consumer confusion over the number of labels (cf. Winson et al., 2021), the schemes don’t necessarily address information asymmetries (see Goal 1, Consumer Information Systems).

However, they also present certain important opportunities at the early stages of transition:

Create new market relations and new markets, in fact some markets such as many in the EU require it
Create new norms of behaviour
Bring profile to hidden problems
Ultimately have a positive impact on power relations, viability and performance of participating actors
Improve sustainability
May ultimately force governments to improve their approach

The MSC program is based on 3 principles :

Sustainable Fish Stocks
Minimizing environmental impact
Effective Management

It utilizes a points-based system in the standards with a minimum 80 average score per principle; a minimum 60 for each individual criteria (Conditions apply to criteria scoring between 60 and 80).

It has visibility in Canada, with support from the federal and BC governments in particular, and products in major Canadian supermarkets (Sundar, 2017). As of 2016, about 2/3 of the wild marine and freshwater domestic fishery was certified by MSC, but progress is slower on imports, particularly fish meal and fish fats (Govender et al., 2016; Winson et al., 2021). MSC claims significant impact globally as well. Friend of the Sea impacts can be found here. However, while Canadian consumer knowledge of the need to protect fisheries is quite high, understanding of ecolabels is generally weak which limits the effectiveness of these programs (Winson et al. 2021). In their survey, the presence of a sustainable ecolabel ranked 6th in importance when making purchasing decisions, and fewer than 20% claimed they purchased ecolabelled seafood most of the time. They also found that "the main source of information for respondents about ecolabeled or sustainable seafood was online resources and/or mobile applications (44.8%), followed by detailed product labels (43.4%), television documentaries, lifestyle television or celebrity chefs (36.6%), word of mouth (29%), newspaper and magazine articles (27.3%), in-store help/consulting (19.2%), and others (16.3%)."

Criticisms:

Mostly in terms of principles and criteria; nothing substantial related to transparency, governance, etc.
Some controversial fisheries certified (BS Sockeye Salmon and Long-line Swordfish) through conditional certification
Major retailers have refused MSC-certified fisheries using bottom-trawling methods
Tends to certify large-capital intensive fisheries as opposed to small less impactful fisheries (e.g., Nunavut fisheries harder to certify because of expense for smaller actors, lack of infrastructure and data, see Nunavut Fishing Strategy)

On balance, certification is positive in the early stages of transitions under conditions that simultaneously address power imbalances in the structure of the fishery. In combination with many of the other transition proposals outlined at this stage, it may advance sustainability and income of participating fishers. Governments should support voluntary certification in the same way they have with Forest Stewardship Council certification. Through the Canadian Council of Forest Ministers, 3 third party systems are recognized because they:

"involve independent third-party audits that assess a forest operation’s planning, procedures, systems and performance against predetermined standards
require annual surveillance audits and public disclosure of findings through audit reports
require involvement with affected Aboriginal peoples to make sure that their rights, knowledge and values are respected
offer chain-of-custody assurance
reinforce the basics of sustainable forest management by requiring that all applicable laws be obeyed and by demonstrating that no unauthorized logging has taken place
go beyond simple timber harvesting by ensuring the conservation of biodiversity." (NRCAN)

Similarly, rigorous third party certification should be promoted through the Canadian Council of Fisheries and Aquaculture Ministers. Equally important, though, is the need to advance understanding by consumers of sustainable seafood consumption (see Goal 1, Consumer Information Systems and Goal 2 Demand-supply Coordination, Substitution). In particular, the state has a role to play in improving retailer commitments to sustainable seafood (Winson et al., 2021), somewhat akin to current efforts (using threat of regulatory enforcement) to encourage a food retail industry code of conduct on supply chain ethical relations.

Restricting tourism recreational fishery and angler competitions to catch and release or put, grow, take

The sport fishing sector is contributing to species decline in certain regions. As discussed under Core issues, although catch and release and put and take sport fishing is now common, not all firms / organizations restrict fishers in these ways. But 13 fresh water species, including rainbow trout, walleye and northern pike, are threatened so more significant conservation efforts are required. Also problematic is the introduction of exotic species for sport fishing. There is some evidence that such species are having a negative impact on native species and spread of disease (Lowitt et al., 2019 Cooke and Murchie, 2013).

Catch and release is not without controversy. Many indigenous communities consider it profoundly disrespectful of other life forms. Animal rights organizations believe it to be cruel. There is evidence that at least a modest percentage of fish do not long survive after catch and release, due to poor handling by anglers, or a loss of fitness, or being more attractive to predators. However, to maintain sport fishing at current levels, catch and release must be maintained, otherwise stocks will surely be decimated (Hume, 2021).

Provincial governments should use fish licensing regulations to restrict harvest of specified species for conservation purposes. The species covered will of course vary by region. In Ontario, for example, under the Fish Licensing Regulations of the Fish and Wildlife Conservation Act, the authority to impose conservation restrictions already exists (section 9). Given lack of accurate data for the inland fishery, a precautionary approach to restrictions on the sport fishery should be imposed, with catch and release rules implemented for all threatened species / region combinations.

Ministries of Natural Resources should no longer permit stocking of non-native species unless in closed pond systems with minimal risk of release to larger ecosystems and no reproductive potential. Any habitat modifications undertaken should focus on native species.

Given, however, the economic importance of the sport fishery, often in more remote regions, the new rules should be imposed over a three year period to permit for gradual adjustment by fishing lodges and competitions.

Revisions to recreational licensing

See Goal 1, Self-provisioning.

Improving local and direct markets

As with many other areas of the food system, local market infrastructure has deteroriated in the post WWII period, although some aspects of it have been re-established more recently in some areas of the country. In some cases, there isn't any local infrastructure that is compliant with "modern" harvest, processing and distribution. That loss, combined with the economic relations of the fishing sector, price points, the IQs and the licensing processes, and the relatively small size of many coastal communities makes selling into local markets a significant challenge. It is also an issue in the interior freshwater fishery where local buyers in some remote regions, because of economic concentration in the buying sector, are forced to sell to a distant market and then have their local retailers or restaurants buy it back from these distant markets at a higher price than would result from more direct exchange. The absence of local processing can mean significant back and forth movement for local fish.

Direct marketing, generally thought of as a subset of localization, may not focus on the local market but sell across the country with no middlemen. In most provinces, direct sales are significantly restricted with specified exemptions (for example for self-consumption without resale), with Manitoba and Alberta somewhat more permissive than other jurisdictions. The direct sales of fish-by-fish harvesters were prohibited in Newfoundland and Labrador until late 2015, justified on the grounds of maintaining the viability of the fish-processing industry and to ensure food safety (DesRivieres et al., 2017) Some provinces permit sales to restaurants from fish harvesters who typically also have to have a vendor license. As with many issues around food safety, the challenge is to maintain safety while not penalizing smaller operators in local markets that don't involve cross border trade. For more on this, see Goal 4, Food Safety.

There is a nascent Community Supported Fisheries (CSF) sector where eaters buy shares in the catch in advance of the fishing season. The harvesters process and package the fish and distribute to specific locations for pickup. Skipper Otto’s in Vancouver, British Columbia is one of the oldest examples of this approach, with direct sales across the country.

Rules also make it more challenging to sell into local markets unless processor also focuses on local sales. In some communities, (re)building the local infrastructure is critical. For example, the Nunavut Fisheries Strategy focuses on off-loading facilities for fishing boats, community storage and freezers. Smaller-scale processing infrastructure is needed to cut and wrap fish and meat for country food markets. Nunavut has small funding program (Fisheries Development and Diversification Program), and is seeking foreign investment in processing (see also Wilson et al. 2019). The federal government funds the Canadian Northern Economic Development Agency. Associated with the lack of infrastructure is people with the skills to work the boats, ports and processing plants. The Nunavut Fisheries Strategy has a significant training objective for local people. Other aboriginal communities in regions where land claims agreements have not been settled have benefited from the federal Aboriginal Fisheries Strategy and the Allocation Transfer Program, though First Nations groups have not found the program as beneficial as it could be (National Indigenous Fisheries Institute).

It is not clear that the newly created Local Food Infrastructure Fund, announced as part of the new National Food Policy, will address the fishery. And the money allocated is so small, even if remote communities were eligible, it is unlike the Fund would have much of an impact at this stage.

Reducing seafood fraud

The federal government announced with its unveiling of the national food policy expenditures of $24.4 million over 5 years to fight food fraud. This presumably is in addition to current expenditures on fraud prevention and prosecution, large by the CFIA. But what specifically the funds will be used for is not yet clear. The 2019 mandate letter to the Minister of Fisheries and Oceans reinforces the need to develop a boat to plate traceability program.

According to the CFIA, fish is one of the top 5 foods for which frauds of varying kinds are reported (the others being honey, olive and specialty oils, dry spices and organic foods). Oceana (2018) reported that 44% of fish sold in sampled food retail and restaurants in 5 Canadian cities (almost 400 samples) was mislabelled. Common cases of mislabelling (deliberate or accidental) included: cheaper haddock and pollock substituted for cod; farmed salmon served as wild salmon; escolar as butterfish or white tuna; and red snapper as some other species.

The problem exists because of the complexity of global supply chains, the economic pressures on many actors, food price inflation, and the lack of transparency in the movement and ownership of fish.

In addition to the obvious economic and food safety problem this creates, there is also an ecosystem one. Fraud can happen anywhere along the supply chain, from the fishing boat, to the wharf, to the processing plant, to the retailer or restaurant. The CFIA found that 15% of fish were mislabelled before the processing stage (Shehata, 2018). Monitoring of catch and by-catch becomes more difficult. In the Oceana study, 30% of substitute samples were endangered, threatened or vulnerable species, and a further 38% have unclear status. The red snapper story can make eaters think the stock is fine, even though its status is vulnerable. Fraud may also give illegally caught fish a new identity, significant given that 20% of all harvest may actually be illegal caught or unreported. All this is contributing to overfishing.

Traceability regulations in the EU are having a positive impact on fraud, from 23% down to 7% since 2011 according to Oceana. The US has recently moved toward boat-to-border traceability for imported at-risk species. Canada has some voluntary programs, but rules in the Safe Food for Canadians Act are not strong enough to reduce this problem. The SFCA regulations appear to presume no fraud prior to final packaging and therefore display a narrow and inaccurate interpretation of the problem. The weaknesses are particularly stark in comparison to EU fish labeling requirements.

A difficulty of imposing better tracking and labelling rules is the cost to fishers and processors. Large operations are usually better able to bear the costs and pass them along the supply chain. For small operators who don't have the resources to research, monitor, inspect and change packaging, the costs can be burdensome. The new technologies being developed, such as blockchain and GPS tracking will only exacerbate these problems (see Mooney, 2018), and there are still significant questions about their utility.

To make transparency affordable, three things need to happen at this stage of the transition. First, a significant amount of the $24.4 million announced funding should go to building transparency infrastructure for fish and seafood, and it should be done in a way that does not exacerbate the scale problems described above. We can adapt the systems that have been put in place in the US and EU to the Canadian context, systems that identify where, when and how a fish was caught, and its chain of custody through processing, distribution, retail and restaurant, if applicable. Second, such measures become more manageable for small operators when part of an aggregating efforts (see Support for co-operatives and fish harvester organizations), so these measures should be implemented in concert with such efforts. Third, transparency works as part of value chain coordination, so some of the funding allocated to build these new mechanisms should incentivize equitable sharing of value along the supply chain. Important here is ensuring that the most powerful actors in the supply chain to not control the information flow essential to the transparency process.