ocean

care

Frozen in Time

HOW MODERN N ORWAY CL I NGS TO I T S WH A L I NG PA ST

A REPORT BY SANDRA ALTHERR, KATE O’CONNELL,
SUE FISHER AND SIGRID LÜBER

© 2016
Suggested citation: Altherr, S., O’Connell, K., Fisher, S., Lüber, S. (2016). Frozen in Time. Report by
Animal Welfare Institute, OceanCare and Pro Wildlife. 23 pp.
cover photo: baleen whale vertebrae, Svalbard, Norway 2011by Weymuller Photography (www.weymullerphotography.com)

Frozen in Time

HOW M ODERN NORWAY CLIN GS TO ITS WHALING PASTA REPORT BY SANDRA ALTHERR, KATE O’CONNELL, SUE FISHER AND SIGRID LÜBER

CONTENTS
Section 1 › Executive Summary...................................................................................................................................... 2
Section 2 › Background.................................................................................................................................................... 3
Section 3 › Norway Ignores International Provisions............................................................................................4
3.1. Undermining the IWC.......................................................................................................................................4
3.2. CITES.......................................................................................................................................................................8
Section 4 › Government Support for Commercial Hunts.................................................................................. 11
Section 5 › IWC Responses and Resolutions on Norway...................................................................................14
Section 6 › Norwegian Whaling and Welfare Concerns.....................................................................................16
Section 7 › Contaminants in Norwegian Whale Products.................................................................................17
Section 8 › Conclusions and Recommendations.................................................................................................18
8.1. Conclusions........................................................................................................................................................18
8.2. Recommendations..........................................................................................................................................18
Section 9 › References................................................................................................................................................... 20

GLOSSARYCITES Convention on International Trade in Endangered
Species of Wild Fauna and Flora
CoP Conference of the Parties
EFTA European Free Trade Association
ICRW International Convention for the Regulationof Whaling
IWC International Whaling Commission

IWMC
NAMMCOPCB
RMPRMS
UNCLOSInternational Wildlife Management Consortium
North Atlantic Marine Mammal Commission
Polychlorinated Biphenyls
Revised Management Procedure
Revised Management Scheme
United Nations Convention on the Law of the Sea

ONE

EXECUTIVE SUMMARY
FOR years, headlines have focused on Japan’s whaling
in the Antarctic whale sanctuary and Iceland’s hunt ofendangered fin whales. Yet Norway has quietly become
the world’s leading whaling nation, killing more whalesin the past two years than Japan and Iceland combined.
With the attention of media, politicians and the public
focused elsewhere since the beginning of the new
century, Norwegian whaling has boomed, exploiting
loopholes in international whaling and trade bansand using unapproved science to set its own quotas
for hundreds – sometimes more than a thousand –whales a year. Now with its domestic market for whale
meat saturated due to low demand, Norway is not
only exporting meat to established markets in Japan,
it is even funding the development of new foodsupplement and pharmaceutical products derived fromwhale oil in an effort to secure new customers, both athome and abroad.

Since resuming commercial whaling in 1993 – underan objection to the International Whaling Commission’s(IWC) 1982 moratorium on commercial whaling –Norwegian whalers have killed more than 11,800 minke
whales, most in the last decade. During that time,
Norway has systematically dispensed with national
monitoring and control measures, as well as the IWC’s
scientific requirements for setting quotas. It has also
become much less transparent about the management
and welfare implications of its hunt, refusing to provide
data to the IWC. Norway has even sought to makewhales the scapegoat for global overfishing.
Norwegian whalers have exported more than 230
tonnes of whale products in the past 15 years under areservation to the international ban on commercial tradein whale products implemented by the Convention on
International Trade in Endangered Species of Wild Fauna
and Flora (CITES). Not satisfied with this, Norway also
tried repeatedly to overturn this ban.
Despite all this, the IWC has been almost silent on
Norwegian whaling and trade since 2001, even as it
continued to adopt resolutions on Japanese whaling.
Similarly, the international community has taken only
token diplomatic measures against Norwegian whaling
during this time.
For as long as Iceland and Japan continue to take all
the heat for whaling and trade, Norway will maintainits business-as-usual approach to both. Strong andunambiguous diplomatic action against Norway isurgently needed, including at forthcoming CITES and
IWC meetings.

Norwegian whaling ship ‘Reinebuen’ south of Svalbard, May 30, 2015
(N. Seeliger)

2 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PASTTWO

BACKGROUNDWHALING in Norway dates back to 9th century Vikings,
a fact often used by Norwegian whaling lobbyists tocharacterise the country’s modern hunt as a longstanding
cultural tradition.1 A curator of Norway’s whaling museum
has even attempted to reframe it as a custom dating ‘backto the Stone Age’.2 However, Norway has evolved into oneof the world’s most developed and sixth richest country(in GDP per capita)3 making a justification of whaling as acultural imperative increasingly implausible.
Although the remote Norwegian islands of Svalbard
and Jan Mayen have been centres of whaling for
centuries, large-scale whaling there in the 15th and16th centuries was dominated by the Dutch and British.
Norway developed key technological advances in the
19th century such as the exploding harpoon cannon anda tethering device to secure harpooned whales, which
made whaling ruthlessly efficient, enabling its expansion
to an industrial scale.4 By the 1890s, Norwegian whalers
were killing roughly 3,000 large whales annually off theircoasts and, in response to dwindling local populationsof whales, the Norwegian parliament banned whaling
off its northern shores in 1904.5
Norway’s whaling companies had already turned theirattention to pelagic whaling and simply moved their new
floating factories and fast-moving catcher boats to moredistant waters, including the Antarctic. By the mid-1930s,
Norway dominated the global whaling industry, taking
more than half of all whales killed and producing a large
share of the world’s whale oil.6 With a shortfall of whale oilfor its own market, some of Norway’s whalers returned totheir own waters after the First World War, establishing thefoundation of modern Norwegian whaling.
Intense global competition for whale oil decimatedstocks of large whales in the early 20th century. In 1946,
Norway and 14 other nations7 agreed to the International
Convention for the Regulation of Whaling (ICRW), which
established the IWC to regulate hunting and conserve
whales. However, the over-exploitation continued for
decades, much of it undetected and in violation of IWC
regulations, and whale populations continued to decline.
Finally, in 1982, the majority of IWC member statesagreed to a moratorium on whaling for commercial
purposes, which came into force in 1986. However,as permitted by Article V of the ICRW, Norway lodged
a formal objection to the moratorium exempting itself
from the provision's effect (Section 3).
Unlike Japan, which was ‘persuaded’ to lift its objection
by the United States’ revocation of access to its fishinggrounds,8 Norway suffered no consequences for its
defiance of the moratorium. It maintained its objection,
under which it carried out commercial hunts in 1986 and1987. It then conducted six seasons of special permit or‘scientific’ whaling, even though it had called on the IWC
to prevent the abuse of this treaty provision in 1956.9
Emboldened by the absence of political or economic
repercussions, Norway again relied on its objectionin 1993, resuming commercial whaling under selfallocated quotas. Having taken an average of 48 whales
a year under special permit,10 its commercial hunt
surged within only six years from 157 minke whales in its
first season to 625 in 1998 (see Box 1).11
In 2014, Norway took the greatest number of minke
whales (736) since the previous peak in 2003, yet the
IWC has not commented on its whaling since passing a
resolution in 2001 calling on Norway to ‘reconsider its
objection and to halt immediately all whaling activities’.
In contrast, the IWC has adopted several resolutions on
Japanese whaling since 2001.12
Yet, while Norwegian fishermen and politicians try tokeep commercial whaling alive, including by finding newmarkets for whale products, the global whale-watchingindustry continues to boom. Although whales aboundand whale watching offers a more financially andecologically sustainable alternative to whaling, Norway’s
whale-watching industry has grown at a lower rate (4.9%
per year) than corresponding whale-watching industries
in other European regions (7.1% per year).13 Studies haveshown that the whaling and whale-watching industries
are not compatible14 and experience in Norway bears
this out; in both 2006 and 2015, tourists reported being
disturbed to witness a whale hunt or its aftermath when
their whale-watch vessel encountered a whaling vessel.15

3THREENORWAY IGNORESINTERNATIONAL PROVISIONSTHE United Nations Convention on the Law of the
Sea (UNCLOS) entered into force in 1994, the year
after Norway resumed commercial whaling. Article 65
makes clear that states are obligated to ‘cooperate witha view to the conservation of marine mammals and in
the case of cetaceans shall in particular work throughthe appropriate international organizations for theirconservation, management and study’. The IWC was
the only relevant international organisation in existenceat the time and its competency to both manage andconserve whales has been explicitly acknowledgedby the United Nations. Chapter 17 of the Agenda 21
consensus of the first UN Conference on Environmentand Development held in Rio di Janeiro in 1992 andthe follow-up Rio+20 Conference held in 2012 both
recognised that UNCLOS continues to provide the legal
framework for the conservation of the oceans.16
Yet, Norway, which ratified UNCLOS in 199617
and agreed to the consensus on Agenda 21, hasrepeatedly failed to cooperate with the IWC – notonly by continuing to hunt whales in defiance of themoratorium but also by undermining its scientificadvice. It has also defied and undermined CITES,
whose deference to the IWC led it to list all whales in its
Appendix I – banning international commercial trade –in response to the IWC’s adoption of the moratorium.

3.1. UNDERMINING THE IWC
Objection against the moratorium
Norway was one of the founding nations of the ICRW,
which established the IWC in 1946 to regulate whaling in
the hope of preventing the extinction of large cetaceans.
Norway proceeded to kill more than 350,000 whales
between 1946 and 1986.18 Norway voted against thecommercial whaling moratorium in 1982 and refuses tobe bound by it.
In the decade before the moratorium was adopted,
Norway caught about 2,000 minke whales per year – far
fewer than in the heyday of commercial whaling for oilin the late 1940s and 1950s, when it took approximately
20,000 whales a year.

4 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

Even after the moratorium was approved, Norway did
not intend to stop whaling and, taking advantage of aprovision in Article V of the ICRW that allows contracting
governments to exempt themselves from otherwisebinding decisions, it filed a formal objection to themoratorium and continued to take almost 2,000 whales
annually for the next two years. Provoked by a findingby the US Secretary of Commerce in June 1986 that it
had not ‘given any indication that it would comply withinternational standards for whale conservation’ andfacing the threat of sanctions, Norway announced that it
would suspend commercial whaling on July 3, 1986. As
a result, in August 1986, President Reagan opted not to
impose sanctions on Norway.19
Although it abstained from commercial whaling from1988 until 1994, an emboldened Norway chose instead
to use the ‘special permit’ provision in Article VIII of the
ICRW to keep its whaling industry active, taking 289
minke whales under the guise of scientific research overthat six-year period. The IWC responded with a series ofresolutions on ‘Special Permit Catches by Norway’ (seeBox 5) that called on it to ‘reconsider’ its special permit
whaling. Simultaneously, conservation groups sought
consumer boycotts of Norwegian seafood products inthe early 1990s in retaliation for its resumed commercial
whaling.20 But Norway judged that continuing whaling
was worth the risk.
The whaling nations’ gamble that the moratorium oncommercial whaling would be short-lived and neverenforced has paid off. Although the ban remains in place
today, the IWC has consistently acted as though it is atemporary measure and has worked on its replacement.
These efforts included commencing plans for a‘Comprehensive Assessment of Whale Stocks’ in 1985,21
instructing its Scientific Committee in 1991 to devise
components of a Revised Management Procedure(RMP) that would set sustainable quotas when themoratorium was lifted, and tasking itself with negotiatinga Revised Management Scheme (RMS) to oversee futurewhaling. Each of the whaling nations has influenced
the development of these mechanisms, but none more
intensely or persistently than Norway.

BOX 1: NORWAY’S COMMERCIAL WHALING UNDER THE MORATORIUM
Quotas, actual catches and numbers of vessels involved in the hunt24

YEAR

TUNINGLEVEL 25QUOTA

CATCH 26

% OF QUOTANO. OFVESSELS 27

1993

0.72

296

157

53.04

27

1994

0.72

301

206

68.43

29

1995

0.72

232

218

93.97

32

1996

0.72

425

388

91.29

31

1997

0.72

580

503

86.72

32

1998

0.72

671

625

93.14

34

1999

0.72

753

591

78.48

34

2000

0.72

655

487

74.35

33

2001

0.66

549

552

100.55

33

2002

0.62

671

634

94.49

34

2003

0.62

711

647

91.00

34

2004

0.62

670

544

81.19

34

2005

0.62

797

639

80.18

31

2006

0.60

1,052

545

51.81

28

2007

0.60

1,052

597

56.75

28

2008

0.60

1,052

536

50.95

27

2009

0.60

885

484

54.69

21

2010

0.60

1,286

468

36.39

18

2011

0.60

1,286

533

41.45

19

2012

0.60

1,286

464

36.08

18

2013

0.60

1,286

594

46.19

17

2014

0.60

1,286

736

57.23

23

2015

0.60

1,286

660

51.32

22

TOTAL

11,808Abuse of the RMP
A key element of the RMP devised by the ScientificCommittee is its ‘tuning level’ – the fraction of thepre-exploited population that would be left after 100
years of operating the RMP. The higher the tuning level
used, the smaller the whaling quota. The IWC adopted
the most conservative tuning level (0.72) offered by the
Scientific Committee in 1991, rejecting an alternativeof 0.66 proposed by Norway and other whaling
nations.22 The Scientific Committee completed themain scientific components of the RMP in 1994, andthe IWC accepted all the specifications, including thetuning level, noting that they ‘should not be modified,reconfigured or adjusted’.23
From 1996 until 2000, the Norwegian government used
the IWC-agreed-upon tuning level of 0.72 to set its own
national quotas for minke whales. However, in 2001,
when that tuning level would have led to a lower quota
due to a higher proportion of female whales having

5

been killed in past hunts, Norwegian officials dropped toa 0.66 tuning level. In 2003, when a new, lower minke
whale population estimate would again have led to a
reduced quota, Norway responded with another drop in
the tuning level to 0.62.28
Although the IWC adopted a resolution in 2001 callingon the government of Norway to reconsider its lessconservative tuning level in the setting of its quotas,
Norway has faced no real consequences for its abuseof the RMP.
In 2004, the Norwegian government issued a policy
statement on marine mammal use, which included areference to the need to ‘cull’ whales in order to ensure
healthy fish stocks.29 Many researchers, including
Norwegians, have countered that culling whales is notnecessary for sound fisheries management and could,in fact, be damaging to fish stocks.30 Norway’s Fisheries
Ministry has responded, however, by reducing thetuning level again, to 0.60 – lower than the number
explicitly rejected by the Scientific Committee in 1991 –resulting in a quota of 797 whales.31
In addition to its failure to use the most conservative
tuning level, Norway also led an assault on otherelements of the RMP in order to justify higher quotas.
In 2004, the Scientific Committee of the IWC began arigorous review of a proposal by Norway to amend what
is known as the Catch Limit Algorithm, the mathematicalformula at the heart of the RMP that uses information
on historic catches and an abundance estimate for thewhale population to be targeted. Finally, the ScientificCommittee determined in 2015 that the proposal’s
conservation performance was ‘unacceptable’.32
Revised Management Scheme
To provide a management context for the RMP, the IWC
agreed that it should not be implemented until the IWC
had agreed to a Monitoring, Control and Surveillance(MCS) regime as part of an overall RMS.33 The IWC
debated the RMS for years, finally acknowledging in 2006
that agreement could not be reached on what criteria
should be included in the RMS and how it should be paid
for.34 The failure was due, in large measure, to opposition
by Norway, Iceland and Japan to mechanisms that are
implemented, and paid for, in other fisheries. For example,
while conservation-minded nations were proposing anentirely independent, international observer scheme for

6 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

all whaling vessels to be administered through the IWC,
Norway continued to insist that national inspectors be
used, with IWC observers allowed only on some vessels.
Norway also insisted that observers should not haveaccess to vessel communication systems, nor be able toreport infractions in real time to the IWC.35
Objection against the listing of the Northeast Atlantic
minke whale as a Protection StockIn 1976, the IWC’s Scientific Committee identified four
stock units of minke whales in the North Atlantic:
1) the Canadian East Coast Stock, 2) the West Greenland
Stock, 3) the Central North Atlantic Stock (EastGreenland-Iceland-Jan Mayen) and 4) the Northeast
Atlantic Stock. Concerns about the status of theNortheast Atlantic stock were raised for a number ofyears, including the fact that catch reports for the stock
might not reflect all whales taken.36 In response to theseworries, in 1986, the IWC voted to list the Northeast
Atlantic stock of minke whales as a Protection Stock,
thereby forbidding whaling. As it had done with themoratorium decision, Norway entered an objection tothis decision and continued hunting.37
Establishment of NAMMCO
In 1992, Norway, together with Iceland, Greenland
and the Faroe Islands, established the North Atlantic
Marine Mammal Commission (NAMMCO) – a regional
management institution that they hoped to use to evade
the IWC moratorium and to exert political pressure on
the IWC to lift it.38 However, this effort has failed as1) other institutions, including CITES, still recognise theIWC, not NAMMCO, as the appropriate internationalorganisation for the management, conservation andstudy of whales; 2) Iceland, which renounced its IWC
membership when NAMMCO was established, rejoined the IWC in 2002; and 3) by 2013 even Norway
acknowledged that, ‘so far NAMMCO has been more ofa supplement to the IWC than an alternative’.39
Nevertheless, an analysis of annual Norwegian
government budgets for the last 10 years shows that
Norway consistently spends far more money on
NAMMCO-related activities than on the IWC.40 In 2016,
for example, the Norwegian government budgeted
only US$80,058 for participation at the IWC, compared
to US$294,251 for NAMMCO meetings.41 In addition,
Norway has stopped submitting welfare data from its
hunts to the IWC, instead presenting the informationto, and seeking advice from, NAMMCO on welfare
matters (see Section 6). And rather than accepting
IWC international observers on board whaling vessels,
Norway has turned to NAMMCO to provide occasional
observer coverage, suggesting that it continues toresist the role of the IWC in whale conservation andmanagement.
Failure to report required information to the IWC
Paragraph 27 (b) of the binding Schedule, which

implements the ICRW, calls on governments to notify
the IWC as to the ‘aggregate amounts of oil of each
grade and quantities of meal, fertilizer (guano), andother products derived from them. ...’ Further, theCommission has adopted numerous resolutions callingon member governments to report to the Commission
on the availability, source and extent of trade in whale
products.42 Norway has not complied with Scheduleparagraph 27 (b), nor has it provided other information
requested in various resolutions.

BOX 2: THE ONGOING ISSUE OF UNWANTED, WASTED WHALE PRODUCTS
In addition to providing between 1,200 and 1,500 kg ofmeat,43 minke whales yield another 500 kg of blubber,
for which there is no demand for human consumption
in Norway. Some blubber is stockpiled and theNorwegian government is encouraging research into
uses of oil, including in pharmaceuticals and foodsupplements (see Section 4).

As Norway’s whaling industry continues to battle theproblem of low domestic demand, it has increasingly
sought to find overseas markets for its products.

Other uses of whale products include feed for pet
dogs, sled dogs, farmed mink and foxes, and otheranimals.44 Internal data from the cooperative ofNorwegian fur farmers, Rogaland Pelsdyrfôrlag, (seetable) show that in 2014 alone, 113,700 kg of whale
meat was used as food for fur animals.
However, much blubber, offal, meat and bones arestill dumped at sea and not always in compliance with
Norwegian regulation J-33-2013 that requires that‘the dumping of whale remains must be done in sucha way that it will not hamper or cause a disturbanceof fishing activities or be a public nuisance’. In August
2015, communities in northern Norway raised a public
outcry against the dumping of whale remains, with one
local stating, ‘I found stinking whale stomachs, blubber
and intestines floating in the fjord and stuck on land’.
Whaler Bjørn Andersen, who had been hunting in thearea, admitted that this was a common practice.45

7

The world’s No. 1 whale killing nation
Commercial catches in Norway under its objection to
the IWC moratorium total 11,808 minke whales throughthe 2015 season (see Box 1). Over the last decade (from2006 to 2015), a total of 5,617 whales were killed in
Norway, compared to 1,199 whales in Iceland and5,436 whales in Japan – making Norway the leading
whaling nation. In fact, for the years 2014 and 2015,
Norwegian whalers killed more whales than Icelandand Japan combined.

Reservations and downlisting proposals
Norway entered reservations against the CITES Appendix I
listing of five whale species:47›› fin whale (Balaenoptera physalus) in 1981›› sei whale (Balaenoptera borealis) in 1981›› sperm whale (Physeter macrocephalus) in 1981›› northern minke whale (Balaenoptera acutorostrata)
in 1986›› southern minke whale (Balaenoptera bonaerensis)
in 19863.2. CITES

Due to the loophole provided by their reservations,
Norway, Iceland and Japan are not bound by the CITES
Appendix I international commercial trade ban and areable to trade whale products legally with each otherand with non-parties to CITES for primarily commercial
purposes. Of course, each would benefit from
opportunities to trade with new markets and would liketo avoid the criticism that they abuse this loophole.48
Consequently, they have attempted on several
occasions to persuade CITES to transfer certain whale
species or populations from Appendix I to Appendix
II, which allows commercial trade under permit. Eachattempt at ‘downlisting’ – including Norway’s in 1994,
1997 and 2000 to downlist minke whales – have failed.49
Nevertheless, in December 2015, the NorwegianMinke Whalers Association wrote to the governmentof Norway urging that minke whales be downlisted toenable them to sell whale products in countries otherthan Japan as well as ‘take advantage of’ a shortfall inwhale meat on the Japanese market’.50 However, no
proposal was submitted to CITES CoP17 in 2016.

The Convention on International Trade in Endangered
Species of Wild Fauna and Flora was agreed to in March
1973 and entered into force in July 1975. Large whales
were among the first species protected under CITES:At the first CITES CoP in 1976, blue, humpback, grayand right whales were listed in Appendix I (effectively
banning international commercial trade). At CoP2 in
1979, all great whales were included either in Appendix
I or II (i.e., international trade restrictions). At CoP3 in
1981, fin, sei and sperm whales were transferred toAppendix I, with the result that all whales then protectedby the IWC also received CITES’s strongest protection.
In 1986, CITES responded to the IWC moratorium by
including the last remaining great whales in Appendix I.46
However, like the ICRW, CITES allows parties to lodge aformal reservation within 90 days of a CITES decision,
exempting them from its effect.

Exports of whale products despite commercial
trade ban
For years, the Norwegian government complied with
the Appendix I listing, refusing to issue export permits forwhale products. However, at the IWC annual meetingin 2000, following the third defeat of a Norwegian
downlisting proposal at CITES, Norway stated that its
government ‘had decided that there was no basis forcontinuing the ban on issuing export permits’.51 Since
then, the government has supported international tradeby issuing export permits – obviously in the hope thatexternal markets will help to ensure the survival of the
flagging Norwegian whaling industry.
In early 2013, Japan's NYK line ship ‘Olympus’ transported over four
tonnes of Norwegian whale products to Japan. (Keith Murray)

8 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

Actual exports of whale products from Norway arerecorded by Statistics Norway, while information on

BOX 3: NORWAY’S EXPORTS OF WHALE PRODUCTS
Sources: UNEP-WCMC CITES Trade Database and Statistics Norway

YEAR

DESTINATIONAMOUNT IN kg(UNEP-WCMC)AMOUNT IN kg(STATISTICS NORWAY)

2002

Iceland39,10524,605

2002

Faroe Islands

-

431

2003

Iceland

-

4,268

2003

Faroe Islands

10,600

8,345

2005

Faroe Islands

-

60

2006

Faroe Islands

-

250

2008

Japan

5,600

5,195

2009

Faroe Islands

1,920

1,920

2010

Faroe Islands

1,000

-

2011

Faroe Islands

468

468

2012

Japan

30

-

2012

Faroe Islands

500

473

2013

Faroe Islands

2,000

994

2013

Japan

41,61853

7,337

2014

Japan

96,371

82,3942014

Iceland10,000

1,013

2014

Faroe Islands

1,000

526

2015

Japan

not available yet

90,2252015

Icelandnot available yet

3,589

2015

Faroe Islands

not available yet

2,160

TOTAL

210,212234,253

CITES export permits is reported to the CITES trade
database, maintained by the United Nations Environment
Programme – World Conservation Monitoring Centre(UNEP-WCMC).52 Comparison of export data from
Statistics Norway and UNEP-WCMC shows discrepancies(see Box 3); actual shipments may include lower
amounts than what is reported on an export permit, andrecording of data may be delayed due to transport times.
As UNEP-WCMC data were only available until 2014 at
the time of this report, the following section also relies
on data provided by Statistics Norway (2015).
In March 2001, the Japanese and Norwegian ministers
in charge of fisheries met to discuss plans for the

resumption of trade in whale meat. However, Norway’s
first exports of whale products (by the Myklebust whaling
company) were sent to Iceland in 2002.54 This was anecessary first step for Iceland, which at that time waspreparing the foundation for its resumption of whaling toreactivate its domestic market for whale products.
Even after Iceland resumed whaling and produced
its own whale products, Norwegian and Icelandic
whaling interests continued to collaborate; in 2008, alarge shipment of Icelandic fin whale meat exported toJapan was accompanied by five tonnes of Norwegianwhale meat.55 However, the export ended in adisaster for Norway’s whalers, as Japanese authorities

9discarded the full shipment due to concerns overbacterial contamination.56
Norway’s export of whale meat to the Faroe Islands(which is a non-party to CITES) began in 2003 andhas continued on a regular basis. However, Norway’s
biggest customer for whale products is Japan. Since
exports resumed in 2013 with a shipment of 41,616 kg,
they have skyrocketed to 82,394 kg in 2014 and 90,225
kg in 2015. This coincides with Japan’s own reduced
whaling success in recent years.
Due to phytosanitary concerns, the Kyodo Senpaku
company (which operates Japan’s whaling
programmes) has placed inspectors on board
Norwegian whaling vessels since 2013. In 2015, Kyodo
Senpaku inspectors conducted 40 on-board whaling
inspections, in place of Norwegian health inspectors(who inspect products dockside).57 A spokesperson for
Norway’s Food Safety Authority (FSA) acknowledged in
April 2016 that the meat from the Kyodo Senpaku trips
should not be considered safe for human consumption
without FSA inspection. In response to this decision, theNorwegian whale meat company whose vessel carried
Kyodo Senpaku inspectors on board appealed.

In response, the FSA indicated that efforts were
underway to try to change the regulations in order tofacilitate trade in whale products.58
Overall, from 2002 to 2015, Norway exported a total of234,253 kg of minke whale meat (see Box 3), equivalent
to over 150 minke whales. Japan has been the leading
destination for these products (185,151 kg), followed by
Iceland (33,475 kg), and the Faroe Islands (15,627 kg).
This volume has not gone unnoticed: UNEP-WCMC
noted Norway’s large exports of minke whale in its 2013
analysis of trade under reservation, where it warned thatsuch trade may ‘undermine the effectiveness’ of CITES.59
Furthermore, responding to the ongoing, and growing,international trade in whale products between Norway,
Iceland and Japan, CITES has issued several Notifications(e.g., No. 2015/02060) reminding parties that CITES
Resolution Conf. 11.4 (Rev. CoP12) recommends that noexport or import permit should be issued for any whale
species protected from commercial whaling by the IWC.
However, Norway ignores these and other reminders,continuing to export ever-larger shipments of whale
meat and refusing to submit information on domestic
stockpiles of whale products.

BOX 4: KEY PLAYERS FOR EXPORT OF WHALE PRODUCTS
The main exporters of whale products in Norway are
the companies Myklebust Hvlaprodukter and Lofothval.
Kristján Loftsson, the owner and operator of the
Icelandic fin whaling company Hvalur hf holds a
12 percent share in Lofothval. Lofothval’s manager
is Rune Frovik, former secretary of the High North
Alliance, a pro-whaling lobbying organisation, which
was subsidised by the Norwegian government in the
1990s (see Section 4).
Norway’s largest exporter of whale products is
Myklebust Hvlaprodukter. In 2014, the year it exported

10 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

34,282 kg of whale meat in a single shipment to Japan,
Myklebust built new freezer storage facilities – a strong
indication of ongoing confidence in this export market.
Myklebust was also the source of whale meat sold by
the retailer Arktisk Meny at the agricultural fair Green
Week, in Berlin, Germany, in January 2014.61 Both the
shipment to and the sale of 34 kg of whale meat inGermany violated CITES and EU Council Regulation
338/97, which prohibits possession and sale of whale
products within the European Union.

FOUR

GOVERNMENT SUPPORT FOR COMMERCIAL
HUNTS AND USE OF WHALE PRODUCTS

DEMAND for whale products is low in Norway andfor whale blubber, in particular, there is little domestic
market. On average, Norwegian citizens only eat 0.25 kgof whale meat per year.62 By 2011, it was reported thatless than 5 percent of Norwegian citizens regularly eat
whale meat,63 down from 7 percent in 2009.64 A market
analysis showed that whale meat was considered oldfashioned and just a ‘niche product’.65 Since that time,
however, improved packaging and better marketing
have led to a variety of supermarket chains, such as
SPAR/EuroSPAR, Meny, REMA 1000 and Coop offering
whale meat for sale,66 occasionally offering special pricediscounts in an effort to increase sales.
Since the 1990s, the Norwegian government has
been trying to reanimate the whaling industry both byproviding financial support (estimated at a mean annual
value of NOK 22 million, equivalent to US$2.5 million67)
and by easing conditions for whalers.68
Financial support
The Norwegian fishing fleet, including whaling vessels,
is exempt from the basic tax on petrol and diesel fuel,69
which has led to tens of millions of US dollars’ worthof savings for the fleet.70 The fishing industry also
receives distribution and storage support in the formof grants. Between 1999 and 2004, the Norwegian
government allocated US$2.66 million outright, andloaned an additional US$3.2 million, for building new
freezer units.71 Over the period 1993-2006, about
US$10.5 million was spent by the government to cover
the costs of national inspectors on board whaling
vessels.72 In order to reduce the high costs of inspection,
an electronic system (‘blue box’) was developed, forwhich the government provided a subsidy of about
US$213,000 between 2001 and 2005.73
Since 1997, Norway has maintained a register ofthe DNA of all whales hunted, both for scientificpurposes and to facilitate trade. Between 2001 and2010, all costs related to the development of thescheme, totalling NOK 19.56 million (US$2.24 million)
were covered by the government.74 In some years,
government subsidies reached at least half of theeconomic value of whale meat landings. For the period
1993-2009, the government supported whaling withsubsidies of at least US$20 million.75
The Norwegian government has also expended
significant sums to support lobbying efforts to shore
up support for the whaling industry. Between 1992
and 2010, the government spent US$6.9 million ‘toinform the outside world of Norwegian resource
management, and in particular whaling and sealing’.
This included payments to pro-whaling lobbyinggroups such as the High North Alliance,76 the European
Bureau for Conservation and Development (which
includes Norwegian government whale researcher
Dr Lars Walløe on its board of directors77), the IWMCWorld Conservation Trust (IWMC), and the NorwegianFishermen’s Association (Norges Fiskarlag), especially forsupport of these groups’ efforts at conferences focusing
on the ‘whales versus fish’ issue and attendance at
IWC and CITES meetings. The IWMC received annual
support in the amount of US$34,000 from 2009 to 2014
from Norges Fiskarlag for its work at the UN’s Food andAgriculture Organization (FAO), CITES and IWC.78
Relaxing whaling regulations to maximise hunting
To prevent depletion of any local populations, the IWC
divided the region in which Norway whales into fivedifferent small management areas: ES (Svalbard-BearIsland area), EB (Eastern Barents Sea), EW (Norwegian
Sea and coastal zones off North Norway, including
the Lofoten area), EN (North Sea), and CM (Western
Norwegian Sea-Jan Mayen area).
Allocating catches by small areas is an integral part of
the RMP. However, in recent years less whaling has been
conducted in the Lofoten area, and it appears to havestopped entirely off Jan Mayen. Instead, the bulk of thehunting effort has shifted to Svalbard.79 In June 2011,
midway through the whaling season, the Norwegian
government, responding to calls from whalers frustrated
by the fact that quotas in the other whaling areas had beenused up, removed the quota limit of 65 for Svalbard.80,81
The following year, it abrogated all the small area and pervessel quotas, providing an entirely open hunting season.

11

In 2014, researchers from Norway's Institute for Marine
Research (IMR) wrote that the whales in the Norwegianhunt were from ‘one and the same stock’ and that there
was no genetic basis for dividing the hunt into fivedifferent hunting areas.82 The authors acknowledge,
however, that information on breeding locations andmigration remains scarce. Norway’s 2016 whaling
regulations have partly returned to small area quotas inthat 647 minkes can be hunted in the EW and ESB areas,
63 in the EN area, and 170 in the CM area around Jan
Mayen, for an overall quota of 880.83

an electronic trip recorder, the so-called ‘blue box’.
Although the blue box records GPS location and thetimes when the harpoon is fired and the whale is hauledon board, it is not a real-time recording device. Althoughspot checks by inspectors during whaling trips were
initially promised and are in theory still possible, they are
rarely conducted.87 Since 2013, whaling vessels longer
than 15m have been required to use Vessel Monitoring
Systems (VMS) to allow real-time vessel tracking.
However, at least three whaling vessels were given adispensation from this requirement in 2015.88

The whaling season in Norway traditionally lasted fromthe beginning of April to the end of August, although
the season was often extended – e.g., once in 2010
and twice in 2012, apparently in response to low catch
numbers.84 However, since 2013, whaling regulations
have not included a specific end date for the season,
referring instead to a continuation of whaling ‘asconditions warrant’.85

Stimulation of demand and creation of new uses
In response to the declining domestic consumption ofwhale meat, the Fisheries Research Institute of Norway
commissioned a study in 2000 to examine the reasonsfor the reduction. The analysis found that whale meatin Norway was considered to have an ‘old-fashioned
image.’89 As a consequence, a public relations
campaign was launched, including the creation of
more modern recipes, such as whale burgers, whale
ham and whale pastrami.90,91

From 1993 until 2003, all Norwegian whaling vessels
were required to carry a national inspector on board
in order to record data, including sex, age, lengthand circumference of the whale, as well as blubber
thickness.86 However, in 2004 the government reduced
the inspector scheme’s coverage to 50 percent. Then,in 2007, all national inspectors were replaced by

From 2004 to 2009, the public relations programme
cost US$400,000/year.92 Although it did not
immediately result in the desired effect,93 revenues atseveral of the leading whale meat companies haveincreased in recent years. For example, Lofothval’s

The Netherlands-based SPAR group continues to defy international condemnation by selling whale meat in its Norwegian outlets. (Paul Thompson)

12 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

revenue rose from US$1.1 million in 2012 to US$1.6
million in 2014.94 Myklebust Hvalprodukter’s income
rose from US$1.3 million to US$1.7 million over thesame time period.95
In 2011, the Fisheries’ Ministry provided US$4.6 million
to Innovation Norway, the government’s institution forresearch and development, ‘with the aim of establishingcommitted cooperation between parties in the value
chain in order to ensure a stable supply of consumer
oriented minke whale products to the market’.96 A
more recent project aimed at developing new uses forminke whales looked at ways to produce ‘balenin’, aproduct claimed to enhance stamina.97 The project was
co-funded by Myklebust Hvalprodukter (US$79,500);
Møre and Romsdal County (US$42,810); and FHF, theNorwegian Seafood Research Fund (US$36,694).
Support has also been given to a variety of marketingand public relations campaigns to promote whale
meat consumption, including development of thewebsite http://norskhval.no/. For several years, a ‘whale
mobile’, partly funded by the Råfisklaget (the NorwegianFishermen’s Sales Organisation), was sent to morethan 40 cities and towns across Norway, offering freesamples of whale meat and promoting recipes at avariety of events.98 In 2014, a new branding association‘Kvalitetshval Fra Norskehavet’ (‘Quality Whale from

Norwegian Waters’) was started, financed by Innovation
Norway with grants from the Norwegian government.
Its purpose was to improve the reputation of whale
meat and to increase domestic demand, including bypromoting new recipes for whale dishes.99 By May 2015,
six whale meat processors had signed up and, to date, a
total of US$619,421 has been allotted to the promotional
effort. Råfisklaget also supports the project.100
A series of government-funded studies has examinedcommercial possibilities for different whale products,
including whale oil as a dietary supplement,101 formedical treatments102 or as a component in fish feed.103
In 2015, Myklebust Hvalprodukter announced thelaunch of a series of new products based on whale
oil, including hand cream that it claimed would help
chronic psoriasis.104 The company also markets whale
oil health capsules and balenin capsules to ‘increaseenergy levels and endurance’.105
In summer 2015, a meeting in Tokyo of government
and whaling industry representatives from Japan,
Iceland and Norway106 included a discussion of the
trade in products such as whale oil, extracts andwhale meal on its agenda. This clearly shows that thewhaling nations continue to collaborate to seek ways
to maximise their investment in whaling by expanding
international trade.107

The development and sale of whale-based health products are part of an effort to increase sales for an industry challenged by limited demand forwhale meat. (http://nettbutikk.hvalprodukter.no/categories/helseprodukter)

13

FIVE

IWC RESPONSES ANDRESOLUTIONS ON NORWAY
SINCE the IWC enacted the commercial whaling
moratorium, it has adopted a series of resolutions
focused on or referring to Norway; first targeting its‘scientific whaling’ (1998-1994), then addressing its
commercial whaling and trade in whale meat andexpressing concerns over contaminant levels innorthern minke whales (2001). However, since 2001,
the IWC has not adopted a single resolution directly
addressing Norway’s whaling and trade, despite
increases in both over that time (see Box 5).
Officials and media in Norway interpret the IWC’s
recent silence as acceptance of Norwegian whalingby the international community.108 In 2011, Mr Karsten
Klepsvik of the Norwegian Foreign Ministry (and IWC
Commissioner from 2005 until 2010) told Norwegian
media: ‘We have noticed that there’s more calmaround the whaling issue. This has been a gradualdevelopment over several years’.109 Indeed, despite allof Norway’s assaults on the IWC and CITES and its hightake of whales over the last 14 years, fewer diplomatic
measures have been taken against Norway than against
other whaling nations. The only measures taken havebeen a demarche in 2006 delivered by 12 countries,110
an official diplomatic protest by the US made in 2009,111
and an intervention by the US Commissioner during the2014 meeting of the IWC.112
Norway and the European Union
While not a member of the European Union (EU),
Norway is a member of the European Free Trade
Association (EFTA), part of the European Economic
Area. Although the EU has repeatedly affirmed its
strong support for the IWC moratorium on commercial
whaling113 and the CITES trade ban and ‘called upon
Norway to reconsider its position on these issues’, it has
not taken a strong position against Norway’s whaling.
This is likely due to the close ties between Norway andits Nordic neighbors that are members of the EU.

14 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

BOX 5: IWC RESOLUTIONS ON NORWAY‘S WHALING
1988-1
Resolution on Norwegian Proposal for Special Permits:
considers that Norway’s proposal ‘does not satisfy eachof the criteria’ for scientific research programmes in linewith the IWC’s Resolutions of 1986 and 1987.
1989-2
Resolution on Norwegian Proposal for Special Permits:
repeats its substantial critique against Norway’s scientificresearch programme and invites Norway to reconsider
the proposed take of minke whales.
1990-1
Resolution on Norwegian Proposal for Special Permits:
repeats the content and appeal of 1988-1 and 1989-2.
1992-6
Resolution on Norwegian Proposal for Special Permits:
invites Norway to reconsider the proposed take of minke
whales under special permit, as its scientific whaling
programme does not satisfy the IWC criteria.
1993-8Resolution on Norwegian Proposal for Special Permits:‘invites the Government of Norway to reconsider the
proposed take of minke whales in 1993 and 1994 under“special permit”’.
1994-11
Resolution on Special Permit Catches by Norway:‘… welcomes the decision of the Government of
Norway not to issue special permits in 1995’.
1995-5Resolution on North-eastern Atlantic Minke Whales:’… aware that Norway, having lodged an objection toparagraph 10(e) … , has unilaterally authorised commercial
whaling in 1994 and 1995, and that catches are currently
underway … calls on Norway to reconsider its objection …
and to halt immediately all whaling activities’.
1995-6
Resolution on Improving Mechanisms to Prevent Illegal
Trade in Whale Meat: calls for whaling nations to reporttheir stockpiles of whale meat and urges a disposal in
the near future.

1996-3
Resolution on Improving Mechanism to Restrict
Trade and Prevent Illegal Trade in Whale Meat:commends Norway for its ban on exports of whale
meat and blubber and urges its maintenance and full
enforcement; calls on Norway to immediately halt all
whaling activities and to maintain its policy against theexport of whale meat.
1996-5Resolution on Northeast Atlantic Minke Whales: regrets
the unilateral setting of quotas for commercial whaling,
especially in the absence of valid abundance estimates.
1997-2
Resolution on Improved Monitoring of Whale Product
Stockpiles: encourages whaling nations to provide dataon remaining stockpiles, to inventory DNA samples, andto make the DNA database available to the IWC.
1997-3
Resolution on North-Eastern Atlantic Minke Whales:
calls upon the Norwegian government to reconsider its
objection to the moratorium and to halt immediately all
whaling activity under its jurisdiction.
1998-1
Resolution on Norwegian Whaling: calls upon the
Norwegian government to reconsider its objection to
the moratorium and to halt immediately all whaling
activities under its jurisdiction.
2001-5Resolution on Commercial Whaling: concernedthat Norway ‘has continued unilaterally to authorisecommercial whaling on minke whales’ and that ‘contrary
to the precautionary approach, the Government of
Norway has opted to employ a less conservative ‘‘tuning
level’’ in the setting of its quotas … requests that Norway
refrains from issuing export permits for whale products,
calls upon Norway to reconsider the less conservative‘‘tuning level’’, to reconsider its objection and to halt
immediately all whaling activities’.

15

SIX

NORWEGIAN WHALING
AND WELFARE CONCERNSTHE IWC defines humane killing of a whale as ‘causing
its death without pain, stress or distress perceptible
to the animal. That is the ideal. Any humane killing
technique aims first to render an animal insensitive
to pain as swiftly as is technically possible’.114 The
exploding harpoon – invented by a Norwegian in 1865
and still manufactured in Norway – while far fromperfect, is the most effective method of achieving thisgoal today, given the whalers’ objective of preserving
as much meat as possible.
A penthrite grenade harpoon fired from a bow-mounted
cannon penetrates the whale’s body and detonates. The
resulting shock waves are intended to cause massive
trauma to the brain, rendering the whale irreversibly
insensible, if not dead. Spring-loaded claws are releasedby the harpoon upon impact and embed into thesurrounding flesh in order to secure the whale’s bodyso it can be hauled on board or lashed to the vessel
for transport to land. If the whalers determine thatthe harpoon has not killed the whale, a rifle is used
as a secondary method. Gunner experience, sea andweather conditions, the size of the whale, the distance
fired and the location and angle of the grenade’s
penetration all impact the accuracy of the kill and thetime the whale takes to die (its time-to-death, or TTD).115

Norway has conducted research into whale killing
methods, and is responsible for improvements in boththe proportion of whales that die instantaneously (theinstantaneous death rate, or IDR) and the average
TTD. However, whales continue to suffer inhumane
deaths due to Norwegian whaling. In one case, a paper
discussed at the IWC 2006 Workshop on Whale Killing
Methods and Associated Welfare Issues reported ona hunt in which a whale took more than 14 minutes
to die.116 For more than 5,000 minke whales killed by
Norwegian whalers in the period 1981 to 2012, 18
percent did not die instantly, and average TTD, while
improved, has not fallen below one minute.117
Until 2004, Norway provided detailed information,
including IDR and TTD data, to the IWC where it was
discussed in a standing working group on whale killing
methods and associated welfare issues, as well as
at technical workshops. Since then, however – theyear the first national inspectors were replaced by the‘blue box’ – Norway has only reported the numbers ofhunted whales to the IWC. Since 2012, it has presented
data on TTD from its hunts only to NAMMCO.118
According to an internal report to Norway’s Directorateof Fisheries, 18 percent of whales in the 2012 hunting
season were not instantaneously killed and the median
TTD was six minutes.119
Norwegians are split over whaling and apparently
ambivalent about its humaneness; according to polls,
31 percent support whaling, regardless of potential
suffering of the animals, but 42 percent oppose whaling
if some whales suffer before dying.120

Norwegian explosive harpoon. 18 percent of harpooned minke whales
in Norway do not die instantaneously. (Kai Friis)

16 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PASTSEVENCONTAMINANTS IN
NORWEGIAN WHALE PRODUCTS
OVER the last two decades, an increasing number ofscientific studies have identified alarmingly high levels ofcontaminants in cetacean (whale and dolphin) products,
including minke whales caught by Norway.121
A July 2000 study found more than 50 different PCBs
in whale blubber, including dioxin-like substances andknown hormone-disrupting chemicals.122 Nevertheless,
Norwegian whale hunters contracted with Japanesecompanies to ship whale products to Japan, receiving
explicit support from the Norwegian Parliament.123
Japanese consumer organisations protested and called
on Japan not to import contaminated whale products.124
An official of the Norwegian government subsequently
confirmed the high levels of PCBs and advised against
consuming large amounts of blubber.125 This wasfollowed by new reports of high dioxin levels in blubber.126
In 2001, the IWC passed Resolution 2001-5, which
expressed concern about contamination levels in whale
blubber from Norway. The following year, Japan officiallyrefused to allow imports of Norwegian blubber.127 In
2003, two studies examined contaminant levels in minke
whales hunted in Norway and found mercury levels inexcess of Norwegian health standards in muscle tissue.128
The same year, Norway’s FSA advised pregnant andnursing women not to consume whale meat.129
Regardless of these concerns, the Norwegian whaling
companies Myklebust (see Box 4) and Olavsen exported
more than five tonnes of frozen whale meat to Japan in
2008. However, their effort to break into the Japanesemarket was thwarted when the whale meat was rejected
in 2009 by Japan’s Ministry of Health due to bacterial
contamination exceeding safety limits.130

Fresh whale meat steaks on sale in 2014 at a fish market in Bergen,southeast Norway. (ProWildlife)

A 2013 study by the Norwegian Seafood Research Fund
looked at contaminant levels in a variety of Norwegianwhale products, including whale oil capsules, findingthat the oil had elevated levels of organic contaminants,
especially PCB, that exceeded human health limits.131
Although a 2012 Norwegian study showed a decline in
the level of contaminants in whale meat and Norway's
FSA lifted its warnings against eating whale products
in 2013,132 the Japanese government rejected importsof Norwegian whale products again in 2014 after tests
showed pesticide levels twice as high as Japanesesafety limits for aldrin, dieldrin and chlordane. The
Japanese Ministry of Health recommended that thewhale meat be discarded.133

At its 64th Meeting in 2012, the IWC unanimously
passed Resolution 2012-1, which recalls that organic
contaminants and heavy metals ‘… may have asignificant negative health effect on consumers of
products from these marine mammals’ and urges
parties to ‘… responsibly inform consumers about
positive and negative health effects, related toconsumption of some cetacean products’.

17

EIGHT

CONCLUSIONSAND RECOMMENDATIONS
8.1. CONCLUSIONS
Whaling in Norway is a relic from the past and in recent
decades has become more of a supplement to fishingincome than a main source of revenue for most whalers,
especially given that the Norwegian fishing industry has
diversified beyond its traditional focus on cod. Whalingis actively supported by the government (Section 4);
however, it is estimated that less than 1 percent of
Norwegian fishermen are engaged in whaling.134 Most
whaling vessels take only a few whales,135 and rely on anumber of fishing concessions for other species suchas cod, haddock and saithe for both the domestic andexport markets.136
In addition, the domestic market for whale meatand especially for blubber is shrinking, even as thegovernment tries to increase domestic demand(including funding research and development ofalternative uses of whale oil and other whale products).
Furthermore, efforts to get the CITES international

A north Atlantic minke whale off Svalbard, Norway. (Anne-Line Brink)

18 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

trade ban lifted in order to expand international trading
opportunities for whale products have thus far failed.
In recent years, expanding whaling by Japan and Iceland
has dominated both headlines and diplomacy; Japan
lost a legal challenge to its special permit or ‘scientific’whaling programme at the International Court ofJustice and Iceland remains the target of diplomatic
sanctions by the United States. In contrast, Norway has
been spared international attention and diplomaticpressure, and has made the most of this vacuum.
Since 2010, the Norwegian government has continued
to use an unapproved method to set its quotas, andrelaxed a number of whaling regulations that it originallyintroduced in response to criticism by the IWC. It has
subsidised research into new uses of whale oil and otherproducts and quietly prepared the ground for increased
exports, resulting in nearly 150 tonnes of whale meat andblubber being exported to Japan. It has also become lesstransparent about the welfare implications of its hunt.

Although Norway has a reputation for progressive
environmental policies, its credibility is underminedby its whaling policy.137 Norway continues to give theimpression that its whaling is sustainable.138 However,by arbitrarily lowering the precautionary tuning levelset by the IWC, by allowing open hunts rather thansetting quotas by small area, and by making whales thescapegoat for collapsing fish stocks, Norway has called
its scientific integrity into question.
A forceful and unambiguous rejoinder to Norway’s
strategy is long overdue; the IWC has not formallycommented on its whaling since 2001 and theinternational community has not presented a demarche
to Norway since 2006. Demarches were, however,presented in 2015 against Japan and Iceland, eventhough those countries combined took fewer whales
than Norway. For as long as this remains the case,
Norway will continue to let Iceland and Japan take theheat for whaling and maintain its business-as-usualapproach to whaling.

8.2. RECOMMENDATIONS
To the Norwegian government›› Norway should immediately stop commercial
whaling and trade in whale products.
›› Norway should withdraw its objections against the
IWC moratorium and the listing of the Northeast
Atlantic stock of minke whales as a Protection
Stock, as well as its reservations against the CITES
Appendix I listing of whale species.
›› Norway should cease providing subsidies for thewhaling industry and instead increase its support
for whale watching.

›› Contracting governments should prohibit any
transit of protected whale species through theirports and encourage their international port
management authorities (at seaports, airports andother ports of arrival) to reject any conveyance(vessel, ship, air carrier, train, etc.) carrying whale
products.
To CITES parties›› CITES parties should raise concerns about
escalating commercial exports of whale products
under reservation by Norway, discrepancies in
official trade data, and shipments to CITES member
states that violate the trade ban (e.g., Germany in2014, see Box 4) at the next CITES CoP in 2016 andat the 69th Standing Committee meeting in 2017.
To the European Union›› The EU should take the lead in implementing theabove measures. This would be in line with the
EU Common Position on commercial whaling
adopted by the European Council in 2012139 andthe EC Council Decision in 2014 on EU relations
with Non-EU Western European countries, whichcalled upon Norway to reconsider its position on
whaling and associated trade.140

To the IWC member states›› Contracting governments should use their fullrange of diplomatic and economic measures toconvince Norway to permanently end commercial
whaling and trade in whale products, including
the preparation and issuance of a joint demarche
against Norway’s whaling.
›› Contracting governments should adopt a
resolution at the 66th IWC meeting, urging Norway
to immediately halt all whaling activities under its
jurisdiction, to refrain from issuing export permits
for whale products, and to withdraw its objections
and reservations.

19

NINE

REFERENCES
1
Smith, R. (2013). Viking whalers. http://ngm.nationalgeographic.
com/2013/06/viking-whalers/smith-text
2
Sacks, K. (2014). Whale meat is a tough sell in Norway. Article in
Munchies Vice, 18th September.

IMF, International Monetary Fund. (2015). World Economic Outlook(October 2015).

3

Halverson, S.M. (2004). Small State with a Big Tradition: Norway
Continues Whaling at the Expense of Integration and Nordic
Cooperation, 31 SYRACUSE J.INT’L L.&COM:121, 128–29 (2004).

4

Ellis, R. (1999). Men and Whales. The Lyons Press. pp. 255–265. ISBN
978-1-55821-696-9.

5

Nystrom, J. (2014). United States Policy and Norwegian Commercial
Whaling: A Cooperative Approach. Seattle University Law Review [Vol.
37:1].

6

The fifteen original member countries were Argentina, Australia,
Brazil, Canada, Denmark, France, Iceland, Mexico, Netherlands,
Norway, Panama, South Africa, Soviet Union, United Kingdom andUnited States (Iiwc.int/).

78

http://www.presidency.ucsb.edu/ws/index.php?pid=35644

Report of the Scientific Sub-Committee. (1957). Eighth meeting of theInternational Whaling Commission. P26.
910https://iwc.int/table_permit

11

https://iwc.int/table_objection

The following resolutions have been passed related to Japan's
special permit and community-based whaling: 2001-6; 2001-7; 20018; 2003-2; 2003-3; 2004-2; 2005-1 and 2007-1.

22
1991-Appendix 4: Resolution on the Revised Management
Procedure. Resolution 2001-5 (Resolution 2001-5 Resolution on
Commercial Whaling), and Chair’s Report of the Forty-Third Annual
Meeting, Agenda Item 10.
23

As can be seen in Box 1, the actual number of animals killed eachyear is consistently and significantly lower than the quotas issued,
reaching only half of the limit or even less, ranging from 36 to 57
percent, likely due to the lack of demand for whale products.

https://www.regjeringen.no/no/dokumenter/Norwegianminke-whaling-background-and-determination-of-catch-limits-/
id419378/ and http://www.imr.no/filarkiv/havets_ressurser_og_
miljo_2009/1.4.3_vagehval.pdf/nb-no. The RMP suggests that quotas
be fixed within a multi-year block period, and carryover of unused
quotas account for differences in quota within those blocks.

25

26

Kuo, H. et al. (2012). Estimating the impact of whaling on global
whale-watching. Tourism Management. 33(6): 1321–1328.

Parsons, E.C.M.and Rawles, C. (2003). The resumption of whaling by
Iceland and the potential negative impact in the Icelandic whalewatching market. Current Issues in Tourism, Vol. 6, No. 5 and Kuo et.al.
2012.

14

http://www.nordlys.no/nyheter/hvalsafari-endteblodig/s/1-79-2179087 and Seeliger, N. (2015). Blutige Jagd geht
weiter: Hier verstößt Norwegen gegen das Walfangverbot. Article in
Bild, 6th June.

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Holt, S.J. (1999). Whaling and International Law and Order, Marine
Pollution Bulletin Vol. 38, No. 7, pp. 531-534 and “The Future We Want,Rio+20 Outcome Document”, A/CONF.216/L.1 Agenda Item 10.
16

http://www.un.org/depts/los/reference_files/chronological_
lists_of_ratifications.htm#Agreement%20relating%20to%20the%20
implementation%20of%20Part%20XI%20of%20the%20Convention

17

Statistisk Sentralbyrå, Norges offisielle statistikk: Norges hvalfangst
1905-1972 and Småhvalfangsten. 1939-2007.

18

Reagan, R. (1986, August 4). Message to the Congress on Norwegian
Noncompliance With the International Whaling Commission
Conservation Program.
19

Betsill, M.M. and Corell, E. (2008). The Influence ofNongovernmental Organizations in International Environmental
Negotiations, The MIT Press: Cambridge, Massachusetts.
20

21

Chair’s Report of the Thirty-Seventh Annual Meeting, Agenda Item 7.

20 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

https://iwc.int/table_objection

Norges Råfisklaget Årsberetning. (2014). http://www.nrk.no/mr/deltakelsen-i-hvalfangsten-stuper-1.7958814 and http://www.
dagligvarehandelen.no/2015/47-v%C3%A5gehval-skutt-s%C3%A5langt-i-%C3%A5rets-fangst

27

Papastavrou, V. and Cooke, J. (2006). Sustainable use of ocean
wildlife: what lessons can be learned from commercial whaling? In:
D. M. Lavigne (Ed.), Gaining Ground: In pursuit of ecologicalsustainability. Ampersand Printing: Guelph, Canada.

28

29

12

13

IWC Resolution 1994 on RMP.

24

St.meld. nr. 27 (2003-2004). Norsk sjøpattedyrpolitikk.

Lislevland, T. (2009). Nødvendig med norsk hval- og selfangst?.
Forskning, University of Oslo. See also Corkeron, P.J. (2009). Marine
mammals' influence on ecosystem processes affecting fisheries
in the Barents Sea is trivial. Biol. Lett. 5 204-206; DOI: 10.1098/
rsbl.2008.0628. Morissette, L. et al. (2010). ‘Whales eat fish’?
Demystifying the myth in the Caribbean marine ecosystem. Fishand Fisheries 11(4): 388-404 and http://www.sciencemag.org/
news/2014/07/rebounding-whale-populations-are-good-oceanecosystems
30

31

See supra, note 27.

Annex D-Report of the Sub-committee on the Revised Management
Procedure IWC/SC 66a. and IWC/66/Rep01, page 14.

32

33
IWC Resolution 1994–5. 'Resolution on the Revised Management
Procedure.

IWC 2007 Annual Report of the International Whaling Commission
2006, pp. 1–59. Cambridge, UK.

34

35
Rose, G. and Paleokrassis, G. (1996). Compliance with International
Environmental Obligations: A Case Study of the International
Whaling Commission. In: J. Cameron, J. Werksman & J. Roderick(Eds.), Improving Compliance with International Environmental Law.
Foundation for International Law and Development: London. https://law.lclark.edu/clinics/international_environmental_law_project/our_work/whaling/

International Whaling Commission. (1986). Report of the subcommittee on North Atlantic minke whales. Rep. inr. Whal. Commn 36:
79-88. See also: Øien, N.I. (1990). Absolute and Relative Abundance ofminke whales (Balaenoptera acutorostrata Lacepede) in the Northeast
Atlantic. Thesis. University of Bergen. 140 pp.

36

37
Horwood, J.W. (1990). Biology and Expolitation of the Minke Whale.
CRC Press: Boca Raton, Florida. 248 pp.

Sanderson, K. (1995). Introducing NAMMCO: A New Regional
Approach to Marine Mammal Conservation, The Pilot No. 13 pp10-12.
38

Norwegian Ministry of Trade, Industry and Fisheries. (2013).
Norwegian Whaling Based on a balanced ecosystem. Available atwww.fisheries.no/ecosystems-and-stocks/marine_stocks/mammals/
whales/whaling/#.Vwv4fz9ssxU

39

40

Statsbudsjett 2006/2007 to 2015/2016.

Prop. 1 s. (2015-2016). Proposisjon til Stortinget (forslag til
stortingsvedtak) FORBUDSJETTÅRAT 2016.
41

42

Resolutions 1994-7, 1995-7, 1996-3, 1997-2, 1998-8 and 2007-4.

Norges Råfisklaget Årsberetning. (2014) and (1998, May 3).
Norwegian minke whaling: The hunt is on. News report by High North
Alliance.

43

dpa (2015, January 23). Agrarmesse in Berlin: Zoll beschlagnahmt
Walfleisch auf Grüner Woche. Article in Spiegel online. http://www.
spiegel.de/wirtschaft/gruene-woche-berlin-zoll-beschlagnahmtillegales-walfleisch-a-945130.html
61

Tinch, R. & Phang, Z. (2009b). Economics of subsidies to whaling.
Eftec report to WWF & WDCS dated June 2009. Unpublished.
62

Tinch, R. et al. (2011). Norwegian use of whales: Past, present andfuture trends. Eftec report to WSPA, Dyrebeskyttelsen Norge & NOAH.
84 pp. http://old.dyrebeskyttelsen.no/uploads_nye_dyrebeskyttelsen_
no/hvalrapport_2011_full.pdf

63

Boncheva, S. (2011). Whales as natural resources. Masters Thesis,
Department of Economics. Aarhus School of Business, University of
Aarhus. 100 pp. http://pure.au.dk/portal-asb-student/files/34355886/
Whales_as_natural_resources.pdf

64

http://www.canis.no/ekspertpanel/spmsvar.php?spmid=9242&sokres=1. Dahl, a well-known sled dog runner, also recommended whale
meat in posts in 2000 and 2003. http://www.ninaskramstad.com/
index.php?id=4801; http://www.dagbladet.no/2016/04/01/nyheter/hvalfangst/pelsdyroppdrett/43715738/. The director claimed that themeat used would have been unfit for human consumption, and could
have included offal.

65

67

See supra, note 63.

http://www.nordlys.no/moter-dette-synet-utenforstueveggen/s/5-34-220478

68

See supra, note 62.

69

See supra, note 63.

44

45With the exception of the West Greenland stock of minke whales
which remains on Appendix II.

46

CITES. (2015a). Reservation entered by Parties. https://cites.org/eng/
app/reserve.php

47

See CITES Notifications (the most recent as of April 2015: CITES
2015b) and Resolution Conf. 11.4.
48

The Norwegian proposal to CoP 11, however, did gain a majority of
votes in favour.

49

Lønnsomheten i kvalfangstnæringen med fokus på omsetingen. Letterfrom the Norwegian Minke Whalers Association to the Industry and
Fisheries Department and the Fisheries Directorate, December 6, 2015.

50

Chair’s report of the Fifty-third Annual Meeting of the International
Whaling Commission, Agenda Item 9.2.2. Revised Management
Scheme (RMS) Commission Discussion and Action Arising.

51

UNEP-WCMC. (2016). trade.cites.org. Search for Balaenoptera
acutorostrata from Norway, extracted on 29th February.

52

53
This number includes 15,051 kg of whale products imported from
Iceland for re-export to Japan.

http://www.mbl.is/greinasafn/grein/678440/ Company director Ole
Mindor Myklebust is quoted as saying, ‘Restoring exports of whale
meat is a major step toward bringing whaling back to normal.’

5455

http://news.bbc.co.uk/2/hi/science/nature/7431568.stm

56

http://www.mhlw.go.jp/english/topics/importedfoods/05/9-2.html

Letter from Astrid Holtan, Royal Norwegian Ministry of Trade,Industry and Fisheries to Senior Fisheries Negotiator Hideki Moronuki,
MAFF, February 4, 2016. Norwegian law requires that all whale meatdeliveries be inspected by an NFSA veterinarian, although the Authority
can allow for an exemption when it does not conflict with Norway's
obligations under international law (Regulation on Control of Marine
Mammals (FOR-2003-03-06-288)).

57

Torsvik, N. (2016). Hvalkjøtt solgt ulovlig til Japan. FiskeribladetFiskaren.
April 28, 2016. http://fiskeribladetfiskaren.no/nyheter/?artikkel=46660
5859

https://cites.org/eng/cop/16/inf/E-CoP16i-34.pdf

CITES Notification to the Parties Number 20. (2015). Available atwww.cites.org

60Østli, J. (2000). Hvalkjøtt i Norge En fokusgruppeundersøkelse.
økonomisk Fiskeriforskning Volume 10:1.

See e.g., http://www.hvalprodukter.no/?id=15&title=ProdukterDagligvare and https://www.rema.no/oppskrifter/grillspyd-medhvalbiff-og-gr%C3%B8nnsaker/REC-34628

66

Palmer, B. (2014, Oct. 9). Norwegians Hate Whale Meat. So Why
Does the Country Insist on Whaling? Article in the Huffington Post
online.

70

See supra, note 62. Blubber still had to be disposed of at leastin 1999, 2002 and 2007 due to limited storage capacities andcontamination, which incurred costs of NOK 11 million (US$1.26
million) (NOAH et al. 2011).

71

Tinch, R. & Phang, Z. (2009a). Sink or swim – The economics ofwhaling today. A report by WWF & WDCS. http://www.wwf.org.au/
crawl_publications.cfm?1502/Sink-or-Swim-The-Economics-ofWhaling-Today

72

73

See supra, note 63.

74

Id.

75

See supra, note 63.

Frovik, R. & Jusnes, L. (2006). Risikoanalyse sel og hval - Fokus
på verneorganisasjonenes kampanjer mot fangst - FHF prosjektnr.
221034.

7677
http://www.zoominfo.com/p/Lars-Wall%C3%B8e/6462147. Dr
Walløe has been a member of the Norwegian IWC delegation.
78
Anmødning om økonomisk støtte til IWMS [sic], Letter from
Sveinung Flam, director of the Norwegian Fisheries Sales Cooperative
Association, to the Norwegian Fisheries Department, November 17,
2014. In 2014, the whaling industry also received a small grant fromthe government to enable attendance at IWC meetings, in the amountof US$5,500.

https://www.stortinget.no/no/Saker-og-publikasjoner/Sporsmal/
Skriftlige-sporsmal-og-svar/Skriftlig- sporsmal/?qid=48788

79

80
https://www.regjeringen.no/no/aktuelt/kvote-for-fangst-avvagekval-i-2011/id629357/
81

http://fiskeribladetfiskaren.no/nyheter/?artikkel=22458

http://www.imr.no/publikasjoner/andre_publikasjoner/
kronikker/2014_1/unodvendig_med_fem_fangstomrader_for_
vagehval/nb-no

82

83
http://www.fiskeridir.no/Yrkesfiske/Regelverk-og-reguleringer/Jmeldinger/Gjeldende-J-meldinger/J-53-2016
84

Regulation J-154-2012.

21

85

Regulations J-86-2013; J-90-2014; J-65-2015 and J-53-2016.

Raymakers, C. (2001). Monitoring progress in Norway’s developmentof a DNA register as part of its domestic management system forwhale meat, investigating local whale meat trade, and investigating
reports of illegal trade in blubber. TRAFFIC Europe, 26 pp. www.traffic.
org/.../traffic_species_mammals5.pdf
86

87

See supra, note 62.

88
Anon (2015): Slipper elektronisk dagbok. Article in Kyst og Fjord,
dated 13th February. Available at www.kystogfjord.no/nyheter/forsiden/
Slipper-elektronisk-dagbok

See supra, note 65.

89

In addition, the plan introduced modernized packaging for whale
meat, including ‘ready to heat and serve’ meals.

90

http://fiskeribladetfiskaren.no/?side=101&lesmer=32346 ; http://archive-no.com/page/851490/2012-12-05/http://www.lofotprodukt.
no/VisProdukt/Produkt/20 and http://www.dagligvarehandelen.no/xp/
pub/hoved/avisen/tidligere_utg/13539
91

92

See supra, note 62.

93

See supra, note 63.

As per annual statement for Lofothval filed at www.proff.no,
Lofothval’s overall operating profit in 2014, however, was down
somewhat year on year.

94

As per annual statements for Myklebust Hvalprodukter filed at www.
proff.no.

95

96

See supra, note 63.

97

http://www.fhf.no/prosjektdetaljer/?projectNumber=901025

See http://www.dagbladet.no/magasinet/2007/08/06/508065.html ;http://www.siste.no/innenriks/pa-turn-med-hvalmobil/s/1-79-2122107
and http://www.nsl.no/uploads/filer/norsksjomat/nr2_2010.pdf

9899

http://www.ht.no/incoming/article9815912.ece

http://horecanytt.no/Nyheter/Siste-nytt/Arkiv/2013/
September-2013/Hvalkjoett-paa-dagsorden-i-horeca

100

Oversikt over hvalspekk og hvalolje’ (2006) Core Competence
AB for FHF, http://www.fiskerifond.no/files/projects/attach/223011_
spekk_oljer_sluttrapportrev.pdf
101

102
Bjørkkjær, T., Araujo, P., Madland, T., Berstad, A. & Frøyland, L.,(2009). A randomized double blind comparison of short-term
duodenally administrated whale and seal blubber oils in patientswith inflammatory bowel disease and joint pain. In: Prostaglandins,
Leukotrienes and Essential Fatty Acids, Volume 81, Issue 5, pp. 425-432
and Bonncheva 2011.

WDC. (2010). Reinventing the whale: The whaling industry's
development of new applications for whale oil and other products
in pharmaceuticals, health supplements and animal feed. WDC:
Chippenham, UK, 12 pp.

103

104

http://nettbutikk.hvalprodukter.no/products/hudkrem

http://nettbutikk.hvalprodukter.no/products/hvalolje-i-kapsler andhttp://nettbutikk.hvalprodukter.no/products/balenin-tabletter

105

The meeting, held July 1, 2015, included representatives fromthe Norwegian Ministry of Trade, Industry and Fisheries, the National
Institute of Nutrition and Seafood Research, and the NorwegianEmbassy in Tokyo, as well as representatives of the whaling
industry. The Norwegian delegation was headed by Astrid Holtanof the Fisheries and Industry Ministry (NFD). Other members of theNorwegian delegation included Livar Frøyland (NIFES), Mari Dirdriksen(NFD), Dr. Lars Walløe, and Ole Mindor (Myklebust).

106

Draft agenda of the Expert Meeting regarding trade in whale
products, June 30 to July 1, 2015.

107

22 | FROZEN IN TIME: HOW MODERN NORWAY CLINGS TO ITS WHALING PAST

Skagestad, O.G. (2002). Norwegian Trade in Edible Whale products.
In: Report of the World Council of Whalers’ General Assembly andConference. Torshaven, Faroe Islands. pp. 16-19.
108109
http://www.newsinenglish.no/2011/07/05/whaling-protests-diedown/
110
Argentina, Australia, Austria, Belgium, Brazil, Czech Republic,
France, Great Britain, Germany, Netherlands, New Zealand, and Spain.
111
A cable entitled ‘Norway uncompromising on whale catch limits’as of 12 December 2009 stated: ‘The Ambassador urged the GON[government of Norway] to show flexibility on catch limits to enable acompromise reform of the International Whaling Commission.’
112

Chair’s report of the 65th Meeting, at page 25.

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A5201
1PC0495

113

114
Report of the Workshop on Humane Killing Techniques for Whales.
Presented to the 33rd meeting of the IWC as paper IWC/33/15.
115
Brakes, P., Butterworth, A., Simmonds, M. and Lymbery, P. (2004).
Troubled Waters. Chapter 5: The IWC and whale welfare. p.30-36
and Chapter 8: Weather, sea condition and ship motions affecting
accuracy in whaling. p. 63-68. WSPA Publication ISBN Number: ISBN
0-9547065-0-1.
116
Lonsdale, J., Garces, L., Butterworth, A. and Perry, C. A Review
of a Norwegian Whale Hunt. IWC/58WKM&AWI 12, Agenda Item
4.2 The paper was the result of an undercover investigation by theEnvironmental Investigation Agency (EIA) and World Society for theProtection of Animals.

Report of the Expert Group Meeting on Assessing Time to Death
Data from the Large Whale Hunts. NAMMCO. November 4-6, 2015,
Copenhagen, Denmark. Available at http://nammco.no/publications/hunting-committee/expert-group-meeting-reports/

117

Report of the Working Group on Whale Killing Methods andAssociated Welfare Issues IWC/64/Rep 6 Agenda item 11.

118

119
Øen, E. (2015). The Norwegian minke whale hunt 2011 and 2012 Studies on killing efficiency in the hunt. Report to the Directorate ofFisheries in Norway, October 2015.

NOAH, Dyrebeskyttelsen & WSPA (2011). Seas of change: Why
Norwegian whaling belongs in the past. Report, 20 pp.
120

Altherr, S. & Lüber, S. (2012). Toxic Menu: Contamination of whale
meat and impact on consumers’ health – A Review. Pro Wildlife &OcenaCare: Munich, Wädenswil, 32 pp.
121

122
WWF (2000). Norwegian whale meat contains deadly toxins. wwf.
panda.org/?2124/Norwegian-Whalemeat-contains-deadly-toxins

Moy, R. (2001). Enter into agreement legal export of whale
blubber. Article in Aftenposten, dated 10th January and https://www.
stortinget.no/no/Saker-og-publikasjoner/Publikasjoner/Referater/
Stortinget/2000-2001/010516/ordinarsporretime/13/#a2

123

124

http://www.ens-newswire.com/ens/mar2002/2002-03-06-03.html

Kirby, A. (2001). Japan warned on 'contaminated' blubber. Article
by BBC News as of 24th January 2016. http://news.bbc.co.uk/2/hi/
science/nature/1132889.stm.
125

126
Fisheries Directorate's Nutrition Institute, (2001). Based on blubbersamples from 1999 and 2000.
127
Japan Times (2002). Blubber may be ‘months’ away. Article as of 1st
August.

Grønvik, S. (2003). Norway. Progress report on cetacean research,
January 2002 to December 2002, with statistical data for the calendar
year 2002. SC/55/ProgRepNorway, presented at IWC 53.

128

Doyle, A. (2003). Norway Advises Pregnant Women Against
Whale Meat. Available as of 27 April 2016. http://www.smh.com.au/
articles/2003/05/13/1052591789427.html
129

Per www.mhlw.go.jp and EIA. (2015). Recent Cases of Violation of
the Food Sanitation Law that were Found on the Occasion of Import
Notification. Available at: https://eia-international.org/wp-content/
uploads/Recent-Cases-of-Violation-of-the-Food-Sanitation-LawsWhale-Meat-.pdf

130

Kjemisk testing av hvalolje og sammenligning med tidligere
produkt av spekk. (2013). FHF sluttrapport. http://www.fhf.no/prosjektdetaljer/?projectNumber=900921.

131

132

http://www.handelsbladet.no/id/27596.0

www.mhlw.go.jp/english/topics/importedfoods/14/xls/14-05a.xls;
www.mhlw.go.jp/english/topics/importedfoods/14/xls/14-06a.xls andNorway whale meat dumped in Japan after pesticide finding. (2015,
March 12). Japan Times.
133

134

See supra, note 63.

A small number of vessels account for a large share of the numberof whales killed each year. In 2014, five boats took 320 whales,
approximately 43% of the whales kiled that year. In 2015, the same
five boats killed 311 of the 660 whales, or 47% of the annual kill. Of
these five boats, two boats alone that year accounted for 236 deadwhales. http://www.kystogfjord.no/nyheter/forsiden/Maa-finne-nyomsetningsordning

135

136

Per vessel information at www.fiskeridir.no137

See supra, note 4.

Norway (2013). Norwegian whaling – based on a balanced
ecosystem. Article as of 19th March 2013, published on the Norwegian
Ministry of Trade, Industry and Fisheries’ website: http://www.fisheries.
no/ecosystems-and-stocks/marine_stocks/mammals/whales/
whaling/#.VcPLP_mOI6w
138

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A5201
1PC0495139

http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/er/146315.pdf

140

23

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