EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 3 Central and Eastern European countries. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.

EURO COOP welcomes the European Commission Action Plan (COM (2002) 186) to integrate environmental protection requirements into the Common Fishery Policy (CFP) as there is a need to promote sustainable development in the fishery sector.

It is of utmost importance that environmental concerns become the basis for the CFP due to the fact that fish stocks and the biodiversity of oceans are at risk. Furthermore, consumers have become more aware of and have concerns about these issues.

A new report by FAO (The United Nations Fisheries and Agriculture organisation): "State of World Fisheries and Aquaculture 2002" warns that almost half the world's marine stocks have been fully exploited, and offer no expectations of expansion. Fishing on the high seas has almost tripled since 1976, and catches of oceanic tunas have particularly increased.

EURO COOP therefore agrees with the objective and guiding principles outlined in the Action Plan and looks forward to see how the work plan as outlined in the annex will develop.

However, EURO COOP has the following specific comments to make:

Development of Aquaculture:

EURO COOP believes that the role and development of the aquaculture should be included in the proposed Action Plan in order to reflect the impact it has on the environment.

According to the FAO report, aquaculture accounted for 29% of the world's fish supply in 2001. Since 1970 fish farming have grown at 9.2% per year, while capture fisheries trailed at 1.4% growth.

Furthermore, the Commission should promote the development of aquaculture in the Action Plan to counteract the social, economic and regional consequences of the restructuring of fishery.

Fish Products as Animal Feed:

There is also a need to address the role of fish products used as animal feed within the framework of the Common Agricultural Policy (CAP). Because as long as it is profitable to buy fish meal to produce land-based animal products, like eggs and chickens, in the EU, it becomes difficult to reduce the fishing pressure on fishing grounds to sustainable levels. In order to safeguard the eco-system, there is therefore a need to look into the price policy on animal feed products as well as to explore the possibilities for finding alternatives to these.

Fraudulent Behaviour:

Furthermore, EURO COOP believes that it is necessary to develop a traceability system in order to, as much as possible, avoid fraudulent behaviour in terms of fishing boats unloading their catch in non-EU countries.

Development of Eco-labels on Fish:

Finally, EURO COOP would welcome the development of eco-labels on both fish from aqua-culture and wild catch. To EURO COOP's knowledge there already exists criteria for organic aqua-culture and some systems for eco-labelling of wild catch have been or are being developed.