WWF POSITION STATEMENT 15th MEETING OF THE CONFERENCE OF THE PARTIES TO CITES, DOHA, QATAR, 13 25 March 2010 Proposal 15: Atlantic bluefin tuna (Thunnus thynnus) The Principality of Monaco has proposed the inclusion of Atlantic bluefin tuna (Thunnus thynnus) in CITES Appendix I. WWF position: SUPPORT Rationale: WWF urges the CITES Parties to support the inclusion of Atlantic bluefin tuna Thunnus thynnus in CITES Appendix I for the following reasons: Atlantic bluefin tuna is in urgent need of international conservation measures, having experienced a severe population decline, which has accelerated over the last few decades. The Western stock exists at a stable but extremely depleted level, having suffered an 82.4% 1 decline over just a 38-year period in the latter half of the last century. The Eastern stock is still in steep decline, and is on the verge of full stock collapse. The decline of both stocks is caused by unsustainable harvest, which is directly driven by huge market demand and high-value international commercial trade. The body responsible for managing the species the International Commission for the Conservation of Atlantic Tunas (ICCAT) has systematically failed to manage Atlantic bluefin tuna fisheries appropriately. It has almost universally set quotas far in excess of the recommendations of its own scientific body, the Standing Committee on Research and Statistics (SCRS), and also failed to ensure appropriate implementation of even its own inadequate management measures. For example, true catches of the Eastern stock have been estimated at more than twice the agreed quota in recent years 2, and even basic reporting of legal catches has been extremely weak. ICCAT s own independent performance review in 2008 deemed management of the Eastern Atlantic bluefin tuna fishery to be an international disgrace with indications that collapse could be a real possibility. The report recommended that ICCAT immediately suspend fishing until its members show they can control and report on their catch. Atlantic bluefin tuna meets the criteria for inclusion on CITES Appendix I. The SCRS determined that the overall probability that Atlantic bluefin tuna (both stocks) meets the criteria for CITES Appendix I (i.e., is at a level below 15% of the historical baseline is virtually 100%. 3 1 SCRS (2008a) Report of the 2008 Atlantic bluefin tuna stock assessment session. ICCAT stock assessment reports. 2 SCRS (2008b) The ICCAT SCRS estimated a catch of 61,000 tonnes of Eastern Atlantic bluefin tuna in 2007, against an agreed quota of 29,500 tonnes. Report of the Standing Committee on Research and Statistics. September 29 to October 3, 2008. Madrid, Spain. 3 SCRS (2009) Report of the extension of the 2009 SCRS meeting to consider the status of Atlantic bluefin tuna populations with respect to CITES biological listing criteria. ICCAT Doc. No. PA2-604/2009 page 12, Table 1.B & page 13, Table 2.A. Available at www.iccat.int/documents/meetings/docs/pa2-604 ENG.pdf Page 1 of 5
A majority of the UN Food and Agriculture Organization (FAO) ad hoc expert advisory panel, which evaluates all proposals to list commercially exploited aquatic species on the CITES Appendices, considered that the available evidence supported the proposal to include Atlantic bluefin tuna, Thunnus thynnus (Linnaeus, 1758), in CITES Appendix I, and further stated that "an Appendix I listing would be likely to reduce the bluefin catches from both component populations. This would assist to ensure that recent unsustainable catches in the east Atlantic and Mediterranean are reduced. " 4 By preventing international commercial trade, listing of Atlantic bluefin tuna on CITES Appendix I would eliminate the primary driver of overfishing. This would provide the species with an opportunity to recover and give ICCAT the time to develop the necessary management and enforcement mechanisms to ensure the return of a healthy and sustainable fishery in the future. Further notes: It should be noted that Monaco does not envisage a permanent trade ban for the species. It recognizes that some CITES Parties would have concerns about an Appendix I listing in this regard and has developed a mechanism to meet these concerns. Accordingly, the Proposal is accompanied by a draft Resolution (CoP15 Doc.52), which would mandate the Standing Committee to ask the Depositary Government (Switzerland) to submit a proposal to a future CoP for a downlisting to Appendix II should ICCAT put appropriate management measures in place and should the stocks show signs of recovery. Some countries have expressed concerns about the practicalities of enforcing a CITES Appendix I listing for Atlantic bluefin tuna (i.e., a prohibition on all international commercial trade), due to lookalike issues with other tuna species. However new gene sequencing methods, documented in the scientific literature 5,6 can accurately distinguish between tuna species and would therefore allow for effective enforcement of trade restrictions. Furthermore, this methodology makes it possible to conduct systematic or random checks on tuna products in international trade, and thus detect or discourage any large-scale mislabeling of bluefin products to evade Appendix I trade restrictions. Finally, the main importing country is Japan - which has the legal, regulatory, and technological capability to fully enforce the provisions of Appendix I. Background: Biological characteristics The Atlantic bluefin tuna is found throughout the North Atlantic Ocean and its adjacent seas, particularly the Mediterranean Sea. It is the largest tuna species, and can exceed 4 m in length. Its official maximum weight is 726 kg, but individuals of up to 900 kg have been reported. It usually occupies epipelagic waters of coastal and open-sea areas, between the surface and 200m in depth. Atlantic bluefin tuna are highly migratory, meaning that extensive international cooperation is required in order to ensure appropriate management of the species. Atlantic bluefin tuna is managed as two separate units - Eastern and Western stocks - with two separate spawning grounds on either side of the Atlantic Ocean: the Mediterranean Sea on the eastern side and the Gulf of Mexico on the Western side. However, transatlantic migrations of Atlantic bluefin tuna have been documented. 4 FAO (2009) Ad Hoc Expert Advisory Panel Preliminary Summary. Available at: www.fao.org/fileadmin/user_upload/newsroom/docs/panel_preliminary_summary.pdf 5 Lowenstein JH, Amato G, Kolokotronis S-O. 2009. The Real maccoyii: Identifying tuna sushi with DNA barcodes contrasting characteristic attributes and genetic distances. PLoS ONE 4(11): e7866. doi:10.1371/journal.pone.0007866 6 Viñas J and Tudela S (2009) A validated methodology for genetic identification of tuna species (genus Thunnus). PLoS ONE 4(10): e7606. doi:10.1371/journal.pone.0007606 Page 2 of 5
Atlantic bluefin tuna are expected to live for at least 15 years in the wild, but can live for as long as 30. Larvae have only a 1 in 40 million chance of reaching adulthood. Maturity is reached at a mean age of 4-6 years of age in the East Atlantic and Mediterranean, and at 8-12 years of age in the West Atlantic. Atlantic bluefin tuna is therefore considered a low productivity species, close to the boundary between low and medium productivity. Population status In 2009, the SCRS estimated that the historical decline of both stocks was over 85%. 7 This collapse trend is corroborated by a dramatic decline in the average size of fish caught. Role in the ecosystem Atlantic bluefin tuna is an apex predator that significantly shapes pelagic ecosystems. Juveniles and adults are opportunistic; their diet consists mainly of crustaceans, fish and cephalopods during their early years, but centres primarily on fish such as herring, anchovy, sand-lance, sardine, sprat, bluefish and mackerel as adults. The ecological extinction of this species would thus have unpredictable cascading effects in the North Atlantic, Mediterranean and Gulf of Mexico ecosystems and entail serious consequences to many other species in the food chain. Atlantic bluefin tuna fisheries In the Mediterranean Sea, Atlantic bluefin tuna were traditionally caught by traps in artisanal fisheries. This method can be very selective and sustainable. However, the advent of high-tech purse seine vessels and long lines has now all but replaced the traps. A few still exist, but have seen their catches fall by as much as 80% in recent years. Purse seine fishing involves setting a large wall of netting to encircle schools of fish. Fishermen pull the bottom of the netting closed like a drawstring purse to herd fish into the centre. Long line fishing employs a central fishing line ranging from one to 50 miles long; this line is strung with smaller lines of baited hooks, dangling at evenly spaced intervals. Prior to the 1960s fishing for north Atlantic bluefin tuna in the Western Atlantic was limited to subsistence fishing, sport tournaments, and small-scale commercial ventures. During the 1960s, fishing efforts intensified as international markets developed for canned and fresh products. By the late 1970s and early 1980s harpooners and longliners were fishing Atlantic bluefin tuna for export. Atlantic bluefin tuna ranching Tuna ranching in the Mediterranean (also known as farming ) started in 1997. Fish caught by purse seiners are transported alive to tuna farms where they are fattened during a period of 6 8 months. Fishing vessels are usually from different countries than where the tuna are later farmed, so this transfer of live fish to farms often constitutes international trade. Farming capacity abruptly increased from a few hundred tonnes in 1997 to 30,000 tonnes in 2003 and around 64,000 tonnes in 2008, representing approximately 51,000-57,000 tonnes round weight of (large) fish at the time of capture. Unsustainable international trade There is an extremely high volume of Atlantic bluefin tuna products in international trade, with the fish being one of the most appreciated species for the sushi and sashimi market in Japan and in the overall global market. International trade has been consistently unsustainable, in particular for the Eastern stock. In 2007, Japan reported to ICCAT the import of 32,356 tonnes of processed Eastern Atlantic bluefin tuna, which contrasts with the agreed total quota for that year of 29,500 tonnes. The SCRS recommended at the time that quotas should be limited to between 7 SCRS (200) Report of the extension of the 2009 SCRS meeting to consider the status of Atlantic bluefin tuna populations with respect to CITES biological listing criteria. ICCAT Doc. No. PA2-604/2009, available at www.iccat.int/documents/meetings/docs/pa2-604 ENG.pdf Page 3 of 5
8,500 tonnes and 15,000 tonnes to ensure the recovery of the species. Therefore in 2007, the level of import to one country alone was more than double the highest level recommended by ICCAT s own scientists. Illegal trade Illegal, unregulated and unreported (IUU) fishing is still rampant throughout the Eastern Atlantic bluefin tuna fishery. In 2007, the SCRS estimated that the total catch was in order of 61,000 tonnes, compared to the agreed quota of 29,500 tonnes, demonstrating that illegal catches were higher in volume than legal catches. Even after some improvements in compliance and enforcement were implemented within the EU, high levels of serious infringements have continued to be found both in 2008 and 2009. The SCRS estimated that in 2008 up to 10,252 tonnes of Eastern Atlantic bluefin tuna might have been harvested illegally and never reported. While a full SCRS assessment for 2009 is not yet available, a report by the EU concludes that in 2009, infractions were found in one third of all tug boats inspected (tug boats transport wild caught tuna to fattening cages) 8. Additionally, one of the largest bluefin tuna fleets in the Mediterranean, the Turkish fleet, was denounced by ICCAT Parties as being involved in widespread violations of ICCAT rules, and a significant amount of bluefin tuna was proven to have been caged in EU farms without the required catch documentation. This evidence, along with several other examples, raises significant concerns about the level of IUU catches in 2009 as well as ICCAT s current inability to control IUU fishing in general. Although exact figures on how much of the IUU catch enters international trade are not available, it is reasonable to assume that a significant proportion is indeed traded internationally. Current management regimes As noted above, ICCAT has repeatedly failed to manage both Atlantic bluefin tuna stocks appropriately. During the ICCAT annual meeting in 2006, the EU drove the adoption of a multiannual management plan for Eastern Atlantic bluefin tuna claiming it would recover the stock. This year SCRS revealed that even after strengthening the management plan in 2008, the plan had a less than 20% chance of recovering the stock. At its most recent meeting (9 15 November, 2009) ICCAT still failed to agree on appropriate measures that would lead to the recovery of Atlantic bluefin tuna stocks, despite the fact that the proposal to list the species on CITES Appendix I had already been tabled. Instead, ICCAT agreed to postpone consideration of a new science-based recovery plan to its 2010 meeting, and specified that even in 2010 it would only adopt a recovery plan with a 60% chance of success. Attempts have been made to promote the quota reduction for the Eastern stock agreed at the meeting (a reduction from 19,950 tonnes to 13,500 tonnes for just one year) as an ICCAT success. In reality, however, a quota of 13,500 tonnes has a far lower than 50% chance of recovering the stock (according to the SCRS, a quota of 8,000 tonnes, implemented perfectly, has a 50% chance of recovering the stock), and a significant probability of causing further stock decline. This is without taking into account extensive IUU fishing (see section above). The capacity of the bluefin tuna fishery vastly exceeds the quotas that are set. In 2008, WWF revealed that the Mediterranean fishing fleet alone had the capacity to catch 54,784 tonnes of Atlantic bluefin tuna per year almost double the annual total quota set by ICCAT for the entire Eastern Atlantic bluefin tuna fishery (28,500 tonnes in 2008.) 9 This overcapacity fuelled by the 8 European Community. Report on the implementation of the ICCAT Recovery Plan for Bluefin tuna in 2009. 15 October 2009. 9 WWF Mediterranean Programme Office (2008) Race for the last bluefin: Capacity of the purse seine fleet targeting bluefin tuna in the Mediterranean Sea and estimated capacity reduction needs. Available at: http://assets.panda.org/downloads/med_tuna_overcapacity.pdf Page 4 of 5
demand from international markets is one of the major causes of overfishing, the main driver behind quotas being set far higher than scientific advice, and a major cause of illegal catches. While ICCAT agreed to an improved capacity reduction scheme at its 2009 meeting, this scheme, even if implemented perfectly, might still allow for 38% of the initial over capacity to remain at the end of the 3 year adjustment period. ICCAT s 2009 meeting also highlighted the entrenched lack of compliance with agreed management measures. The vast majority of ICCAT Contracting Parties were issued letters of identification the first step towards sanctions for failure to comply with ICCAT regulations. With this level of compliance failure, it is difficult to see how any faith can be placed in ICCAT s efforts to recover the struggling Eastern stock. Role of CITES CITES has a crucial role to play in ensuring full recovery of the Atlantic bluefin tuna, and the return of a healthy and sustainable fishery. It is clear that regulation of catch levels is only one part of the picture, and that it is also necessary to implement controls from the catch through to the end consumer. Once IUU fishing has occurred, illegal trade follows; eliminating this trade will reduce IUU fishing. Listing on CITES Appendix I is an extremely effective management measure in cases where international trade has caused precipitous population declines, as is the case for Atlantic bluefin tuna. CITES Appendix I is a tool that would assist ICCAT in reducing the IUU fishing which has so plagued the industry. CITES Appendix I prohibits international trade for commercial purposes, but does not make any provisions related to catches, and has no impact on domestic fisheries within a country s Exclusive Economic Zone (EEZ) that do not involve international trade. CITES Appendix I would therefore not take over from ICCAT, nor would it be an affront to the predominance of fisheries authorities over fishery resources: management of the Atlantic bluefin tuna fishery is and will remain the mandate of ICCAT. Conclusion: A CITES Appendix I listing would enable the conservation of the Atlantic bluefin tuna by: Eliminating the primary driver of overexploitation, international commercial trade Allowing the species sufficient time to recover from recent dramatic population declines Reducing IUU fishing by eliminating legal trade, thus effectively helping to resolve one of the greatest problems with the existing management of the fishery Providing ICCAT and its Contracting Parties the time to reduce Atlantic bluefin tuna fishing capacity to levels consistent with a sustainable harvest Providing ICCAT and its Contracting Parties the time to ensure that appropriate reporting mechanisms are effectively adhered to, and to develop the enforcement measures necessary to ensure the elimination of IUU fishing not just in the EU, but across the entire fishery Inclusion of Atlantic bluefin tuna in CITES Appendix I is probably the last available mechanism to ensure the survival of the species, and a future for the thousands of livelihoods that are dependent on healthy bluefin tuna stocks. WWF urges all CITES Parties to vote in favour of this proposal at CoP15. Further information: More information in support of this proposal can be found at www.panda.org/cites. This includes the following briefings: A full outline of the science demonstrating why Atlantic bluefin tuna meets the criteria for CITES Appendix I A full outline of the outcomes of the 2009 ICCAT meeting, and why the decisions made there do not negate in any way the necessity for a CITES Appendix I listing. Page 5 of 5