AIPCE–CEP represents processors and traders of fish and fishery products supplying the EU market. Our membership consists of 20 EU National Associations and 2 Associations in Third countries, comprising around 3,500 companies employing some 120,000 people, many at SME level. The overall value of the output of our industry amounts to around EUR 27 billion, or three times the turnover of the catching sector.
We source raw materials from the EU fleet, from aquaculture and from wider international supply chains. But the balance of supply and demand (including for species not available in EU waters) means that imports account for a significant share of the current market.
It is however vital for consumer confidence that fish from all origins are responsibly and sustainably sourced and that capture fisheries are effectively managed in accordance with applicable legislation and conservation advice.
The CFP’s Fisheries Control System is fundamental to this and we fully support the objectives of the current proposals to ensure that it is fit for purpose and consistently and fairly applied.
In our earlier position paper responding to the stakeholder consultation exercise, we expressed a preference for improved implementation and enforcement of existing measures over the introduction of substantive new requirements. We also drew attention to the need to distinguish between measures relating to the conduct of fishing and farming activities and the existing body of food law relating to safety and consumer information and the need to ensure a level playing field between fishery products and other types of food.
As responsible business operators, we strive to be fully compliant with all relevant rules and regulations. We and our retailer customers also operate internal systems of control on a business to business level which provide additional guarantees. These systems are tried and tested and it will be important to ensure that any new provisions take necessary account of this. This is particularly relevant to the proposal to bring processed products falling under CN codes 16.04 and 16.05 within the scope of Title V, which is the subject of the majority of our comments in the attached document.
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