reLAKSation 127.

Safeguarding what?: Back in 1995, a representative from Callander McDowell was asked to speak at a conference in Brussels entitled ‘Increasing Demand, Diminishing Supplies’. The basic premise of the conference was that whilst demand for fish was continuing to increase, supplies of wild caught fish were in decline through over-fishing. Those attending the meeting were split into two distinct camps; they came from either from a fisheries or an aquaculture background and as the conference progressed, the divide appeared to grow, not come together. The farmers put their case for farming, whilst those from fisheries argued the need for help to improve wild catch fisheries. Not one speaker appeared willing to address the fundamental problem as to how to meet an increasing need for fish from a diminishing supply of marine fish. There was little attempt to connect the decline in wild catch fisheries with a rise in aquaculture, even though this was clearly intended to be the underlying message of the conference.  The simple fact is that whilst many of the measures adopted by the authorities are intended to minimise the effect of declining stocks, such as decommissioning etc, there has been little attempt to address the problem   of supply. The European Community has to rely on third party fishing agreements and increased imports to meet consumer demand. Yet, increased supply from outside European waters only increases the fishing pressure on these stocks, compounding the global problem.  Yet, little consideration has been given to the possibility of replacing lost fish stocks with supplies from aquaculture. This is because the great divide between fisheries and aquaculture, which was evident at the Brussels conference, still exists. Clearly, if supplies of fish can be met from aquaculture, the fishing pressure on wild fisheries stocks can be reduced, allowing much needed time for recovery.

However, whilst the authorities have difficulty in reconciling the idea of using aquaculture as a management tool for wild fisheries, the consumer has taken the concept on board, albeit rather unknowningly. The reduced and unpredictable availability of more expensive supplies of popular marine species such as cod and haddock has meant that consumers have favoured alternative, more available and cheaper species. The one single fish to benefit from increased demand has been salmon. This is because it is widely available, low cost and represents value for  money. As a result, salmon has become the most popular fish in the UK and consumption is likely to continue increasing as it becomes even more widely available.  Processors have recognised that salmon offers enormous potential for adding value, to transform it into a whole range of products which consumers want to buy.

It is therefore unexplainable why, against this background, the British government has applied to the European Commission for safeguards to protect the Scottish and Irish industries  in the face of Norwegian over-production. How can any fish farming industry be over-producing when supplies of wild catch fisheries are so rapidly diminishing?

We, at Callander McDowell certainly believe that this application for safeguards is misguided. The EU may be importing more salmon from other countries, but it is clearly because consumers, who are unable to afford more expensive marine species, have created a growing demand that neither the Scottish or Irish industries can meet, either individually or together.

According to IntraFish, the British application argues that salmon imports to the EU rose during the first nine months of 2003 compared to the previous year. Yet, the EU should welcome this rise because it means that consumers are able to buy value for money fish and at the same time, pressure on fish stocks is being reduced as demand is being met from farming.  Even Scottish producers have recognised the need for increased supplies as Scottish production rose despite the awareness that the Norwegians were supposedly over-producing.  Why continue to expand production if there wasn't confidence that the fish could be sold?

The British government also argue that safeguards should be introduced because of 'unforeseen developments'. It is difficult to comprehend why international salmon producers should be penalised because of 'unforeseen developments'. Common sense would suggest that businesses should try to consider all possible eventualities, after all, nothing is certain, and then plan accordingly. These unforeseen developments include Norwegian over-production, yet as we have already discussed, how can any farming industry be over-producing when supplies of wild caught fish are under threat. Equally, claims of over-production are now starting to wear a bit thin.   The Norwegians were first accused of over-production over a decade ago when Scottish production was only about 28,000 tonnes. These accusations have continued over the ensuing years whilst Scottish production has continued to expand, although this expansion has not been fast enough to meet demand.

The issue is not about over-production, but rather it should be about under-marketing; about the ability to produce what the consumer wants. In this case it is low cost, value for money fish.

The other unforeseen developments include a strong euro, but global business has always had to contend with variable exchange rates and this is not sufficient reason to penalise other producers.

The final unforeseen development was the removal of the European salmon agreement. We would argue that this was both foreseen and expected.  The EU salmon agreement should never have been imposed since it was just a compromise solution to bring yet another dumping case to an end. The dumping  case in question was yet another attempt aimed at excluding Norwegian salmon from the European market.

This application for safeguards  and its suggestion that if they are not imposed, many Scottish and Irish farms will fail, is really about helping European farms avoid having to address the real issues of the marketplace.  We repeat that the fundamental problem is that many Scottish producers aim to produce a high quality product for which they expect to receive a premium price.  Consumers, however, are more interested in value for money salmon, which they can eat as an everyday meal choice. These two expectations do not match up.  The question is should the EU accede to British Governments demand for safeguards and let Scottish farmers produce what they want or should they recognise what the consumer wants and continue to allow a free flow of imports. We, at Callander McDowell  certainly believe that imports should remain unimpeded and farmers, from where-ever they come should adapt their production accordingly. This should not mean that the Scottish industry should automatically be expected to compete in the market for low cost raw salmon flesh. Instead, they should exploit the opportunities to develop high value extra processed product, which should bring a better return and should be less competitive.  The government is clearly concerned about the industry's ability to survive, but rather than opt for this sticking plaster solution, it may find the long term viablity of the industry can be better secured by looking at ways to help producers adapt to an evolving consumer demand.

Finally, IntraFish have highlighted four specific examples of what they call 'price-undercutting'.

We have highlighted previously that the declared industry strategy is to produce a high quality product for which they can command a premium price.  This clearly implies that if they receive a premium price, others must receive a non-premium price, hence a lower price.  Thus by it's very nature, imported salmon must be sold cheaper that Scottish salmon so any claims of price under-cutting are nonsensical.

In addition, one of the four examples cited is for Chilean salmon, which is usually imported as frozen. Representatives from the Scottish industry have previously said that imported frozen salmon is not competitive with fresh Scottish salmon and therefore this example is meaningless.  The other examples are all of Norwegian salmon, but there is no mention of whether the fish are Norwegian superior or ordinary, which have different price structures, but then they would always be cheaper than Scottish product.

However, the aspect of these examples which we find of most interest is that the British governments application document suggests that these examples of price-undercutting have meant that EU producers have had no choice but to lower their prices as well.  Surely, as Scottish fish are being targeted at a specific market for premium priced fish, they are not in direct competition with the fish from  these examples which are being bought by processors and are not necessarily destined for the fresh fish counter or high value restaurant trade. Why would EU producers have to lower their prices to compete for this different market need? Does the Scottish industry not have sufficient confidence in its premium product that they cannot hold out to meet their expectations? Perhaps, this is just another indication of the mismatch between what producers want to produce and what consumer want to buy!

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