IFFO responds to the Fish Free Feed (F3) Challenge

While we congratulate the finalists and winners of the HeroX F3 competition (some of whom are IFFO members), we are disappointed that the credibility of this initiative to encourage alternative sources of feed ingredients has been damaged by the organisers’ use of negative messaging, exaggeration and misinformation in relation to marine ingredients.

IFFO is on record as acknowledging the need for a wide range of responsibly sourced and high quality feed ingredients to support the continued growth of the aquaculture industry. We accept that the supply of marine ingredients cannot meet the demand and that alternative ingredients are needed. The reduction in inclusion rates has allowed feed production volumes to continue to increase unhindered, also resulting in only 0.22kg of ingoing fish being needed to grow 1kg of farmed fish, for the most recent calculation based on 2015 data[1]. In contrast to IFFO’s broader position, the F3 organisers’ intention has been to encourage the exclusion of marine ingredients from use in farmed fish feed, reducing choices for feed companies. Although, confusingly, their website states that they are not against the use of fish based raw materials, this is statement is far less prominent than the title of the competition and their statements in the media.

Unfortunately, the F3 challenge organisers have refused our offers to enter into dialogue or meet and provide up-to-date facts, instead choosing to seek publicity through a number of misleading or false statements.

Principal among these are that marine ingredients are not sustainable. The organisers claim many of the world’s wild fish stocks are in rapid decline – a claim not borne out by the UN Food and Agriculture Organisation reports that show, since 1986, that global wild capture fisheries have been steady and are not declining[2]. While catches of some small pelagic species used to produce fishmeal and fish oil are volatile, this is due to environmental fluctuation with permitted catches being varied in line with biomass abundance to protect the stocks. They also claim that the most common method for setting harvest control rules (Maximum Sustainable Yield) is an economic measure and does not take into account environmental or ecological constraints. This is clearly untrue, as the definitions from ICES[3] and the OECD[4] show.

Further evidence of sustainability in the production of marine ingredients is that over 45% of the global production of fishmeal and fish oil is now independently certified as being safe and environmentally responsible, including in its sourcing of raw materials, a figure that far exceeds any other source of feed ingredient.

Other claims include that the catch of small pelagic species impacts other marine mammals and seabirds, a claim disproven by a recent study by the University of Washington[5] who found very poor correlation between population trends of marine mammals and abundance of forage fish species, including the Californian sea lions’ predation on sardines cited by the organisers.

The most recent example of the false claims made by the organisers is a quote attributed to F3’s Dr Kevin Fitzsimmons that “In many countries, the fishmeal industry is responsible for forced labour, mistreatment of employees, and fishing from substandard fishing vessels with very high rates of injury and deaths.[6]  This exaggerates distressing but fortunately limited examples of human rights abuses reported in South East Asian fisheries, a region that only represents around 12% of the global fishmeal production. In this region, fishing activities are not well regulated but are not directed to the production of fishmeal – the catch being segregated only on landing between human consumption and fishmeal. It is therefore not possible for the fishmeal industry to be “responsible” for the abuses on board fishing vessels. Despite this, the industry is engaged in several initiatives to prevent these abuses and is working with other stakeholders and partners. Given this accusation, it is surprising that the F3 prize giving criteria make no reference to social standards in the production of alternative ingredients entering the competition.

Most farmed fish species are evolved to digest fish protein and replacement of this with terrestrial or other sources of protein can lead to fish gut inflammation and a risk of disease, potentially requiring antibiotic or other treatments, or mortality. An increasing amount (currently 35%) of fishmeal is produced from recycled by-product and waste from fish processing. Removing fish as an ingredient to feed can therefore be damaging to the health of the fish and close an environmentally friendly way of recycling waste products. When it is clear that the amount of fishmeal and fish oil is not sufficient to meet the growing demand for feed manufacture and the raw material sources for feed should be maximised, it makes little sense to exclude these valuable, responsibly sourced and highly effective ingredients.

Fish-free feeds have been available for many years for mainly vegetarian species like Tilapia and Carp. It is also well known that piscivorous species like Salmon and Trout can be raised on vegetable based diets, although their growth and health may be compromised. The F3 competition ignores fish health, mitigates against recycling of fish processing waste, promotes untruths and has not resulted in any true innovation. It is a great shame that those well-meaning contributors to the prize fund have been misled by this misguided campaign.

- Ends –

Please contact: Georgie Harris, Communications Manager

T: +44 (0) 2030 539 195

E: [email protected]


Notes for Editors:

  1. IFFO is an international trade organisation that represents and promotes the marine ingredients industry, such as fishmeal, fish oil and other related industries. Marine ingredients are nutritious products used mainly for aquafeed, land animal feed as well as for human consumption and are derived from marine organisms such as fish, krill, shellfish and algae. IFFO's members reside in more than 50 countries, account for over 50% of world production and 75% of the fishmeal and fish oil traded worldwide. IFFO is an accredited Observer to the UN Food and Agriculture Organisation (FAO). Find out more – http://www.iffo.net/
  2. Benefits of marine ingredients: Fishmeal and fish oil provide feedstuffs for farmed fish and crustaceans.  Supplementing aquaculture feed with fishmeal and fish oil effectively returns 5 million tons of sustainable non-food product back into the human food chain. The addition of fishmeal to animal diets increases feed efficiency and growth through better food palatability, enhancement of nutrient uptake and absorption. No farmed fish species or their trimmings are used to produce aquaculture grade fishmeal and fish oil for the same species - there is no intra-species recycling. Read more - http://www.iffo.net/benefits-marine-ingredients
  3. Fish in: Fish out (FIFO): The FIFO value (Fish in: Fish out ratio) for the conversion of wild feed fish to farmed salmon was 1.4:1* in 2010, not 5:1 as has been widely asserted in both publications and in the media. For all fed aquaculture in 2010, the FIFO was 0.3:1 (2010). In short more than three tonnes of farmed seafood was produced for each tonne of fish used in aquafeeds. The often quoted '5:1' ratio has created an unjustified a priori case against the use of fishmeal and fish oil in aquaculture feed. These figures have now been updated based on 2015 data, and the ratios reflect even lower figures as a result of increasing aquaculture production set against a background of similar marine ingredient supply, as well as an increasing proportion of by-product being utilised as raw material for fishmeal and fish oil production.  The calculated farmed salmon FIFO for 2015 is 0.82, and that for all fed aquaculture 0.22. Read more - http://www.iffo.net/position-paper/how-many-kilos-feed-fish-does-it-take-produce-one.     
  4. Forage fish and their predators: A team of seven respected fisheries scientists, led by Prof. Ray Hilborn, Ph.D., of the University of Washington, found that predator populations are less dependent on specific forage fish species than assumed in previous studies. This paper explores the impact of fishing low trophic level “forage” species on higher trophic level marine predators including other fish, birds and marine mammals. We show that existing analyses using trophic models have generally ignored a number of important factors including (1) the high level of natural variability of forage fish, (2) the weak relationship between forage fish spawning stock size and recruitment and the role of environmental productivity regimes, (3) the size distribution of forage fish, their predators and subsequent size selective predation (4) the changes in spatial distribution of the forage fish as it influences the reproductive success of predators. Read more - http://www.iffo.net/when-does-fishing-forage-species-affect-their
  5. Fishery Improvement Projects: IFFO & GAA: Driving change in South East Asian trawl fisheries, fishmeal supply, and aquafeed - Read more - http://www.iffo.net/fishery-improvement-projects
  6. The Global Standard for Responsible Supply (IFFO RS) is the leading independent business to business certification programme for the production of marine ingredients consisting of 3 standards; The IFFO RS Global Standard for Responsible Supply (IFFO RS), the IFFO RS Chain of Custody for Responsible Supply (IFFO RS CoC), and the IFFO RS Improvers Programme (IFFO RS IP). Since opening for IFFO RS application in October 2009 and as of 2017 130 plants in 17 different countries have gained IFFO RS certification and over 45% of the worlds combined production of Marine ingredients is IFFO RS compliant. Read more - https://www.iffors.com/
  7. Different standards, who covers what: In the area of marine feed ingredients used in aquaculture there are five commonly used standards: The Marine Stewardship Council (MSC), the IFFO Global Standard for Responsible Supply (IFFO RS), the Friend of the Sea (FOS), the Global Aquaculture Alliance Best Aquaculture Practice (BAP) and the Aquaculture Stewardship Council (ASC). There is also the Global GAP standard which covers a number of types of farming and which makes reference to marine feed ingredients. All are primarily focussed on environmental impact and do not directly address social or economic conditions. The starting point to understanding the difference between these standards is what each standard certifies, the unit of certification. The MSC standard for instance certifies a fishery, IFFO RS a fishmeal factory and ASC, BAP and Global GAP all certify fish farms, although BAP has a separate feed-mill standard. FOS certifies fisheries, fishmeal plants, feed mills and fish farms. Read more - http://www.iffo.net/position-paper/demonstrating-responsible-marine-feed-ingredient
  8. Modern slavery in the fishing sector: Read IFFO’s Position Paper - http://www.iffo.net/position-paper/modern-slavery-fishing-sector
  9. Fish as food not feed: The use of small species of fish as farmed animal (including fish) feed is important for global food security and is entirely appropriate if the source fishery is well managed and does not deprive local communities of good quality food for which there is a demand. Read IFFO’s position paper here – http://www.iffo.net/position-paper/fish-food-or-feed

See also recent case factsheet on the use of Peruvian anchovy - http://www.iffo.net/case-study-peruvian-anchovy-why-feed-not-food


[1] See Note 3 below

[2] UN FAO State of World Fisheries and Aquaculture 2016 – Table 3.

[3] https://www.ices.dk/community/Documents/Advice/Acronyms_and_terminology.pdf

[4] https://stats.oecd.org/glossary/detail.asp?ID=1644

[5] Hilborn, R., et al., When does fishing forage species affect their predators? Fish. Res. (2017), http://dx.doi.org/10.1016/j.fishres.2017.01.008

[6] INTERVIEW: Fish-Free Feed Competition Fosters New Partnerships for Feed Innovations, FeedInfo.com 13Sep2017.