Over a hundred species are produced in European aquaculture, in such a wide range of systems that they defy precise categorisation. The study takes the five species that account for the large majority of European fish farming (Atlantic salmon, rainbow trout, common carp, gilthead sea bream and European sea bass), and a set of countries that cover major production sectors and small scale producers. It looks at common practices, important factors at different life stages of the fish, and brings forth much science from the literature on welfare issues and approaches that can be taken to improve welfare. 

Eurogroup for Animals welcomes that among the messages and conclusions of the report are two very important points:

• the central challenge for animal welfare in aquaculture is to progress beyond avoiding suffering, and to develop a good life for fish;
• the EU legislative framework should be updated to include clearly defined and species-specific provisions.

Important issues identified include the relationship between stress and health, stress and injuries associated with routine practices and treatments, high mortality rates, inappropriate stocking densities, lack of environmental complexity, and inappropriate water quality parameters. The study further provides a detailed synthesis of the most advanced welfare indicators and monitoring tools and approaches that have been developed in recent years.

While Eurogroup for Animals appreciates that the text has covered much ground, the study also falls short in terms of content, conclusions and sources.

1. Underplays the potential for specific legislation

Throughout the study, making legislation at this time is not presented as a feasible route to higher welfare. The study presents recommendations and a scenario whereby today only general principles can be established now and specific provisions could be developed only in the future.

For example, the Council of Europe recommendation on the welfare of farmed fish (2005) is covered in this study, but is quoted and represented as setting out general principles and highlighting knowledge gaps. Unfortunately, the study did not take the chance to highlight the sort of specific provisions that are defined there, such as:

• live fish are not put on ice;
• fish are not lifted by individual body parts only;
• ensure sites are only used if they have adequate water supply;
• construct equipment without sharp corners and such that inspections are possible;
• nets are to have a mesh size that avoids entanglement.

Opportunities available with higher fish welfare standards include economic benefits for the producer and product quality benefits for the consumer. The study gives acknowledgement of this within its text, however in its main SWOT analyses, legislation is always identified as a threat to operations, rather than an opportunity to drive improvements.

2. Overlooks important literature

For example, only 9 of the 14 European Food Safety Authority (EFSA) scientific opinions on fish welfare are listed.  

3. Misses serious welfare implications of RAS. 

Recirculating Aquaculture Systems (RAS) are highly intensive production systems with very high power demands to continually pump water. The study promotes them as ‘one of the systems that can ensure food security’ and promotes as an advantage the huge stocking densities used in them. While some welfare issues associated with RAS are identified, there is little recognition and no references for the many health and welfare problems faced by fish in RAS, that are especially important when RAS is used in a hatchery context with the early development of juveniles: E.g.:

• Nitrite easily accumulates in the water and causes damage to gills, intestines, liver, and endocrine system including in juveniles (see here; here and here);
• Water is often high in CO2 leading to kidney and anal damage, inflammations, haemorrhages and potentially death;
• Compared to other systems, RAS is seen to hinder the early development of the skeleton and skin;

4. Questions fish sentience. 

There has been scientific consensus that fish are sentient and feel pain for around 20 years. The EFSA published its conclusion in this respect in 2009. Yet, this study misrepresents the issue in its section ‘Are fish sentient beings?’, claiming that ‘the consciousness issue for fish persists’. This claim is made by reference to three research papers that each claim themselves that fish are conscious.

This study brings a lot of knowledge together and to the fore, but unfortunately leaves it to policymakers to identify themselves what they can formulate into specific provisions.