THE EVERWIDENING NET:
Mapping the scale, nature and corporate
structures of illegal, unreported and unregulated
fishing by the Chinese distant-water fleet

A report by the Environmental Justice Foundation
1

The Environmental JusticeFoundation Charitable Trustis a UK registered charitythat believes we all share abasic human right to a securenatural environment.
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To protect the marine environment,
its biodiversity and the livelihoods
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2

CONTENTS

Executive Summary
Introduction
Methodology

4
6
7

Section 1 – Characteristics of the CDWF

11

			 1.1. Contemporary history
			 1.2. Main locations and areas of operation in 2019 and 2020			 1.3. Onshore structures of the various Chinese Distant-Water Fisheries

11
12
16

Section 2 – IUU fishing activities of the CDWF

21

			 2.1. Location of IUU fishing by CDWF
			 2.2. Location of IUU fishing incidents by gear type

21
25

Section 3 – Nature of IUU fishing and human rights abuses by CDWF30

			 3.1. Nature of IUU fishing by CDWF: Overview
			 3.2. Nature of IUU fishing by gear			 3.3. Nature of human rights abuses by CDWF

30
31
33

Section 4 – Identity of main offenders

38

			 4.1. Overview
			 4.2. Identity of main offenders: By gear

38
40

Conclusions
Recommendations45
46

Abbreviations» AIS: Automatic Identification Systems» CBP: United States Customs and Border Protection» CDWF: Chinese Distant Water Fleet» CITES: Convention on International Trade in Endangered Speciesof Wild Flora and Fauna» CNFC-QSL: China National Fisheries Corporation-Quick State
Limited» CNFC: China National Fisheries Corporation» DWF Regulation: Chinese Distant-Water Fishing Management
Regulation» DWF: Distant Water Fleet» EEZ: Exclusive Economic Zone
» FAO: Food and Agricultural Organisation of the United Nations» FMFO: Fish Meal and Fish Oil» IATTC: Inter-American Tropical Tuna Commission» IEZ: Inshore Exclusion Zone
» ILO: International Labour Organisation» IMO: International Maritime Organisation» IOTC: Indian Ocean Tuna Commission» IPO: Initial Public Offering» IUU: Illegal, Unreported, and Unregulated [fishing]» MARA: Chinese Ministry for Agricultural and Rural Affairs» MCS: Monitoring, Control, and Surveillance» NEAFC: North East Atlantic Fisheries Commission» NGO: Non-Governmental Organisation» NPC: National People’s Congress» PME: Pingtan Marine» Reefers: Refrigerated Cargo Ships» RFMO: Regional Fisheries Management Organisation» SIOFA: Southern Indian Ocean Fisheries Agreement» SPRFMO: South Pacific Regional Fisheries Management
Organisation» STCW-F: The 2012 Cape Town Agreement on Fishing Vessel Safety
and of the International Convention on Standards of Training,
Certification and Watchkeeping for Fishing Vessel Personnel» UVI: Unique Vessel Identifiers» VMS: Vessel Monitoring System» WCPFC: Western and Central Pacific Fisheries Commission

A Chinese longline fishing vessel in the Indian Ocean. © EJF

Executive Summary
decision-makers in China and globally. In large parts,
it focuses specifically on IUU fishing and associatedcrimes such as human rights abuses. The CDWF has
been chosen as the focus of the study given its sizeand global reach, the opacity of its operations, and its
significant presence within countries in the Global
South, where some fish populations are over-exploited
to the detriment of coastal communities who rely
heavily on healthy marine ecosystems.5

Driven by the depletion of fish populations in its
own national waters and its role as a key processing
and exporting state, the Government of the People's
Republic of China has supported the rapid expansionof the scale and technological capacity of its distantwater fishing fleet, i.e. vessels operating beyond its
exclusive economic zone (EEZ). Today, China has by far
the largest of such fleets, operating across the globe in
both areas beyond national jurisdiction and in the EEZs
of coastal states.1

It is informed primarily through a rigorous review ofdata published by the Chinese Ministry of Agriculture
and Rural Affairs (MARA) detailing its various offshore
fishery projects, i.e. vessels approved by MARA to
operate outside of Chinese waters; and information
retrieved from the Criminal Record of Fishing Vessels
and associated platform ‘Spyglass’.6 This is the firstsuch published analysis of official MARA data on its
DWF, supplementing reports produced elsewhere thathave relied on the use of non-governmental sources
such as satellite data to estimate the size and locationof the CDWF.

The burgeoning body of research that has explored theextent and behaviours of the Chinese distant-water
fleet (CDWF) has unveiled the widespread, and harmful,economic, environmental and human consequences
linked to overcapacity, high instances of illegal,
unreported and unregulated (IUU) fishing, destructive
practises such as bottom trawling and the use of forced,
bonded and slave labour and trafficked crew, alongside
the widespread abuse of migrant crewmembers.2
The CDWF has become a major operator in many
developing countries. IUU fishing is particularly
prevalent in these regions, augmenting the sufferingand vulnerability of many coastal communities.

The findings of this global review further build on EJF’s
field based investigations, which have identified a wide
range of IUU fishing offences, such as shark finningand fishing in restricted areas, as well as human rights
abuses such as physical violence, debt bondage andconfiscation of passports.

IUU fishing is facilitated by factors such as a lack oftransparency and the opacity of seafood supply chains,limited monitoring, control, and surveillance (MCS)
capacity, poor governance and corruption.3 In recent
years, EJF has identified continuous instances of IUU
fishing and human rights abuses associated with the
CDWF in West Africa, especially Ghana, where Chinesecompanies use elaborate schemes to hide the ultimate
beneficial ownership of their so-called Ghanaian
domestic vessels. These schemes include joint ventures,shell companies and subsidiaries.4

Illegal fishing, environmental and human rights abuses,
together with the failures of governance documented inthis report, present a case of profound environmental
injustice. These findings highlight the overarching
failure of the Chinese government to effectively control
and regulate its DWF. This is the latest in the long line of
instances in which wealthier nations have externalised
the costs of their operations – degrading the natural
resources of nations and communities whose
contribution to global environmental degradation iscomparatively negligible.

This report presents a comprehensive analysis of
China’s vast, opaque and at times illegal global
fisheries footprint, with the specific aim of informing
appropriate and effective responses by fisheries

4Key Findings•The Chinese fleet has become a substantial presence•Trawling vessels appear to be the most common type

•The CDWF has evolved from being entirely state-•China has put a clear emphasis on developing its

in multiple developing countries. Over a third of
the authorised CDWF operations in 2019 and 2020
covered 29 specific EEZs in Africa, Asia7 and SouthAmerica – the fisheries of many of the regions being
characterised by limited MCS capacity and coastal
regions heavily dependent on fishing for bothnutritional and livelihood needs.

of vessel covered by EEZ-specific approved offshore
fishery projects, with more than three in five fishingvessels using this gear. Bottom trawling, which is
a common mode of fishing employed by Chinese
trawlers, has significant ecological impacts including
high levels of by-catch, the destruction of habitats
and the associated release of carbon.

owned to being mostly privately owned. It has
been argued that this gradual change in ownership
structure has loosened the Chinese government’s
control over the activities of Chinese ﬁshingenterprises. This is also highly relevant to those
Chinese-owned vessels operating under a third
country flag, that are not registered as offshore
fishery projects.

capacity to target squid species in recent years:
vessels equipped to target squid now represent morethan two in three approved offshore fishery projects
covering oceanic areas.

•Whilst data is limited, human rights abuses seem tobe common amongst the CDWF, an issue that blights
distant-water fishing more generally. Interviews
conducted by EJF with 116 Indonesian crewmembers
who have worked on vessels belonging to the CDWF
indicate that 99% have experienced or witnessed
wages being deducted or withheld, 97% haveexperienced some form of debt bondage/confiscationof guarantee money and documents, 89% haveworked excessive overtime, 85% reported abusive
working and living conditions, 70% experienced
intimidation and threats, and 58% have seen or
experienced physical violence. These findings havebeen echoed in EJF interviews with Ghanaian crew
on board CDWF vessels in Ghanaian waters. All 10crew interviewed had experienced or witnessed
physical abuse by Chinese captains, and similarly
all 10 reported poor living conditions on the vessels
they operated on, including being forced to eat low
nutrition food and consume poor quality water –often resulting in sickness and diarrhoea.

•The CDWF is frequently associated with illegal

fishing. According to the data analysed, fishing
without a licence or authorisation is the mostcommon recorded illegal fishing incident,
constituting 42% of the total. Using prohibited
gear and the capture of prohibited species are thenext highest ranking offences, at 11.5% and 10.3%
respectively. The size of the fleet, coupled with thehigh instances of suspected IUU fishing, threatens
continued socio-economic stability and inflicts
ecological harm globally.

•With respect to the projects covering specific EEZs,

data published by MARA highlights the EEZ of
Mauritania as the one where the presence of the
CDWF is by far the most significant ­­­– accounting
for approximately 30%. Mauritania is a hub of the
fishmeal and fish oil industry – which has reaped
widespread ecological damage to both terrestrial
and marine ecosystems including the decimation of
locally important fish populations.

•This report makes a series of recommendations,

including the adoption of transparency measuresfrom the EJF charter for transparency, bilateral andmultilateral dialogues with China to end abuses
and for the rapid phasing out of all subsidies to the
CDWF ensuring a complete cessation of harmful
subsidies no later than December 2023.

•More broadly, Africa stands out by its apparent

importance for the activities of the CDWF, accounting
for 78.5% of the approved offshore fishery projects and
20 of the 29 EEZs mentioned in the notices published.
Many fish stocks in Africa are heavily exploited, acontinuation of which would spell certain disaster for
impoverished coastal dwelling communities.

5Introductionin which there is poor governance and insufficient
MCS capacity. West Africa, for instance, which issimultaneously home to communities extremely reliant
on fisheries and has long been considered a hotspot
for overfishing and IUU fishing, has seen an influx of
CDWF vessels since the mid-1980s.13 Estimates suggestthat the Chinese bottom trawl fleet catches an estimated
2.35 million tonnes per annum in the region – by someestimates, around 50% of China’s total distant-water
catch – valued at over US$ 5 billion.14

Globally, more than three billion people rely on theoceans for their livelihood, with over 200 million
directly or indirectly employed within the marine
fisheries sector8 – many of whom are coastal
communities in the Global South. However, theproliferation and increased capacity of the heavily
subsidised industrial fishing industry, combined withother aggravating factors such as IUU fishing and global
heating, has left many such communities in peril.
The latest estimates suggest that one third of global
fisheries are currently overfished,9 with economies
losing tens of billions of dollars annually to illicit fishingpractices. This assault on our ocean has fundamentally
undermined the human rights of coastal dwellers andothers reliant on fish for livelihoods and nutrition.

The CDWF is substantially bolstered by national
subsidies. According to recent estimates by the China
Ocean Institute and Oceana, the CDWF accounts for
22% of China’s total captured fish, however, the sector
receives 49% of harmful capacity enhancing subsidies
from the Chinese government to help with costs suchas fuel and the construction of vessels and harbours.15
These harmful subsidies amounted to 11.8 billion
yuan (approx. US$ 1.8 billion) in 2019. To put this inperspective, these subsidies accounted for over 38%
of all the harmful subsidies of the top ten subsidisingnations, and more than twice as many as any othersingle country.16,17 Moreover, researchers documented
that the Chinese government’s reporting on its subsidies
programme has reduced in transparency since 2012.18

The ramifications of this rapacious overfishing havebeen exacerbated by the activities of distant water
fishing fleets, in particular China’s, which is by far theworld’s largest.10 The CDWF operates across almost theentire globe – making China comfortably the largest
global fish producer.11 Its exact size is uncertain, thefleet has been linked to high instances of IUU fishing,12widespread use of harmful fishing gear such as bottom
trawls, and a strong presence in regions where fish
populations are in jeopardy due to overfishing andA fishing community in Senegal, West Africa. © EJF

6

Methodology
This report has sought to add to the existing body ofresearch that attempts to map the size, location andincidents22 of IUU fishing by the CDWF. By using novel
datasets that have yet to be analysed for these means, it
can further elucidate the true extent of the most globallysignificant fishing fleet operating today.

Estimates suggest that the
Chinese bottom trawl fleet
catches an estimated 2.35 million
tonnes per annum in the region –by some estimates, around 50% of
China’s total distant-water catch– valued at over US$ 5 billion.

The first such dataset is information published by MARA
in line with the Regulations of the People’s Republic ofChina on the Disclosure of Government Information.23
There is now publicly available information on vessel
inspections, offshore projects, IUU fishing notices, andvessel replacement (these categories of information are
explained in more detail below). Whilst the limitationsof some of these sources will be discussed, it is an
important step by MARA towards transparency.
Between March and October 2017, MARA initiated anoverseas distant-water fleet vessel inspection campaign
covering the major fishing grounds of the Chinese fleet
in every ocean except for the North Atlantic.24 The vessel
inspectors from the DWF department of 9 different
provinces were assigned to 41 countries in these fishinggrounds to inspect a total number of 1383 vessels for their
seaworthiness. These vessels were required to arrive at
the respective closest inspection site according to theschedule. This inspection plan provided us with thenames and associated companies of these vessels, as wellas their approximate fishing location.

A burgeoning body of research continues to map
the size, scope and behaviours of the CDWF,19,20 in an
attempt to comprehend the ecological, economic andsocial impacts of its operations. These efforts havebeen invaluable in providing a body of evidence tosupport advocacy for improved transparency amongst
the world’s distant water fleets (DWF), ultimately withthe aim of bringing fishing efforts down to sustainablelevels and addressing the myriad of environmental
injustices inflicted by many contemporary industrial
fishing practices.

Article 7(1) of the Distant-Water Fishing Management
Regulation (hereinafter DWF Regulation)25 prohibits
the act of engaging in distant-water fishing activities
without the consent of MARA. To engage in suchactivities operators must, in accordance with that
regulatory instrument, submit an “offshore fisheryproject” application for approval. In 2019 and 2020,
such information was published on the website of
MARA in the form of notices.26 Contained within thesenotices are the proposed location of fishing activities,
the identification of the legal persons responsible forthe implementation of the projects, the names, typesor – where applicable – gears of the fishing and fishingrelated vessels they cover, and their duration.

By using novel data sources, including official data
published by MARA and the Criminal Record of
Fishing Vessels,21 this report will serve as one of
the most comprehensive analyses of the scale andbehaviours of the CDWF to date. Analysis conductedat the fleet scale and by gear type shows where the
CDWF is operating, where suspected IUU fishingincidents are occurring, and their nature. Importantly,
the report also looks at the corporations involved inthese infringements – mapping the complex onshore
corporate structures of the fleet and highlighting theworst offenders according to available data.
Actionable recommendations are made to theGovernment of the People’s Republic of China, states
acting as local flags of the CDWF, coastal states, andthe governments of port and major market states to aid
in efforts to eliminate IUU fishing and human rights
abuses that persist within the fleet and the waters inwhich they operate.

MARA has taken an important step towards improved
transparency by releasing notices on IUU fishing
infringements involving Chinese vessels, which provide
data on the nature and location of the infringement, thestatus of any investigations, and any sanction imposed.

7

Data analysis
The information contained in the notices of approved
offshore fishery projects published by MARA in 2019and 2020 was aggregated in a single dataset which
also includes information retrieved from available
inspection lists. This offers unique insights into the
CDWF officially recognised by the Chinese authorities,
enabling EJF to not only map the fleets’ main locations
and areas of operation, but also to analyse the type ofvessels covered by these projects and, where applicable,
the gears they used. In addition, this dataset includes
information on reported ownership.

At the time of writing, these are currently only available
for the years 2017 to 2019, however, they provide animportant source of data on IUU fishing by China’s DWF
vessels which should be replicated and improved uponby other major flag states.27 EJF was able to retrieve six
IUU fishing notices published by MARA between 2018and 2020, for the infringements that took place between
2017 and 2019.28 In these notices, MARA publishedthe vessel and company names involved with the
infringements, source of the information (e.g., reported
by coastal states or Regional Fisheries Management
Organisations (RFMOs)), details of the IUU fishing
offence, whether the infringement needs to be further
investigated, and the sanctioning decision.29

Similar analyses were undertaken in order to map
the nature and location of IUU fishing incidents. Data
from the sources mentioned previously were collated,with duplicates removed so as to ensure accuracy ofanalysis. Once clean, the incidents linked to China wereextracted and offences (the categorisation of which canvary depending on the source) grouped together so as toallow for easier quantification.

In the beginning of 2021, MARA published a notice30
requesting that each provincial department in chargeof a DWF provide vessel data on those that havedisappeared (e.g., stolen or sold), were scrapped,
or deregistered (e.g., vessels’ names changed after
replacement31) in order for them to be deleted from thenational DWF vessel database. This dataset from eachprovincial authority assisted us with verifying andupdating active or inactive vessels, and their current
names and companies.

Data limitations
The industrial fishing sector is characterised in large
parts by a lack of transparency e.g. where vessels
are operating, who they are owned by, the nature offisheries agreements, etc. This opacity, coupled with theoften geographically remote operations of the fishingindustry and the clandestine nature of IUU fishing, canmake certain strands of research in fisheries, such as
in this report, challenging. In light of this, there are anumber of data limitations (and their potential impacts
on the results presented) that must be acknowledged.

The second of the novel datasets analysed in this reportis the spyglass.fish database, which derives its data fromthe Criminal Record of Fishing Vessels. This platform
is to date the most comprehensive, centralised andpublicly available dataset depicting the compliancehistory of fishing vessels – including both alleged andprosecuted cases from a wide variety of sources.32 Thisdataset provided information on the location andnature of offences, the actors involved (both vessels
and operators), and the source of the information(NGO report, official documentation, etc.). The period
2015-2019 was selected for the analysis due to thecompleteness of available data. At the time of writing,data for 2020 was not yet complete in the Spyglass
database, while MARA had only published notices of
IUU fishing incidents for the years 2017 to 2019.

Confidence level in data analysed
A diverse array of data sources were considered inthis study which may not be comparable in termsof confidence level/data quality. This is particularly
pertinent when considering data on IUU offences, ofwhich a total of 554 cases were collated from the above
listed sources between 2015-2019. Offences reported
by official government sources, and especially thosethat have resulted in sanctions, are associated witha higher degree of certainty compared to offences
reported by NGOs (e.g., detected through remote
Automatic Identification Systems (AIS) monitoring)that have not been confirmed by the relevant coastal
or flag state, or competent regional fisheries body.

Beyond the above, there were additional sources fromwhich data was collected. These include informationfrom Chinese provincial governments, the IHS Sea-Web
portal, NGO reports, corporate websites, published andunpublished data collected directly by EJF, publishedand unpublished government data (primarily fromcoastal states), and institutional reports.

8

Undercounting of the CDWF
Of the 554 cases analysed for this study, 55.1%
were categorised by EJF as confirmed where aconclusive decision was made by the authority
after investigation, while 44.1% were categorised assuspected offences with inconclusive results or thevessels fled from prosecution, etc. The remaining
0.8% were cleared of any allegations. Over half
(53.5%) of IUU fishing reports were from official
sources, with 20.9% of reports from NGOs (Table 1).

Throughout the course of the investigation, there
are a number of instances in which it appears thatthe total size of the CDWF according to official
MARA data has been undercounted. These potential
instances of undercounting manifested in a variety ofthe data sources.
Whilst there is no internationally-agreed definition of
a DWF, this concept is often understood as describing
fleets that operate outside the EEZ of their flag state.33,34
However, China’s understanding of its DWF diverges
from that definition. In a context of strong territorial
disputes in the China Seas, China excludes from thedefinition of its distant-water fishing activities all
operations carried out in the Yellow Sea, the East China
Sea and the South China Sea.35,36 On another note,
it puts on an equal footing vessels flying its flag andvessels flying the flags of foreign countries but “owned
by a citizen, legal person or any other organisation of[China]”.37 Excluding the second category would radicallychange the findings made, particularly in relation toactivities taking place in the EEZs of foreign countries
which, in a number of cases, imply flag changes to thesecountries as illustrated by the case of Ghana.38

Table 1: Sources of data on IUU fishing incidents
analysed in this study
Source ofdata
Official
NGO
Unknown
Totali

Number of incidents(2015-2019)

Percentage
of total

296

53.5

116

20.9

142

25.6

554

100

Notes:i

Reported in the media, or source not specified in the Spyglass dataset.

As footnoted previously in the methodology, EJF
could also only retrieve a partial number of notices ofapproved offshore fishery projects from the website of
MARA (five batches in 2019 and seven batches in 2020).

A Chinese industrial trawler at port in Montevideo, Uruguay. © EJF

9Fishers set their net in Gomoa Fetteh, Ghana. © EJF

This situation calls for full implementation of Article 6 of
the Regulations of the People’s Republic of China on the
Disclosure of Government Information which provides
that “administrative agencies shall disclose government
information in a timely and accurate manner”.

between the number of fishing vessels covered bylisted approved offshore fishery projects and the actual
number of vessels operating in the country had notbeen rectified.

Data bias

Cases of countries reporting vessels flying the flag ofChina operating in their waters whilst not being listed
amongst the EEZs covered by approved offshore fisheryprojects were also identified. That is for example thecase of the Seychelles whose authorities report having
authorised 44 vessels flying the flag of China to fishin their waters in 2019.39 Whilst no information on
licences granted by the Seychelles Fishing Authority to
CDWF vessels could be found for 2020, actual fishingactivities within the EEZ of Seychelles by this fleet could
be identified from data transmitted by vessels via AIS.

Within the industrial fishing industry, there remains
a dearth of accurate, comprehensive, and timely data
available to the public. There is therefore a strong
possibility that those states that do publish data mightthen create an over-representation of themselves whencompared to other nations who report less. Similarly,
certain flag states and regions, such as China and West
Africa respectively, have received disproportionate
attention from NGOs in recent years. This ‘spotlight’
effect may lead to their over-representation in theanalysis of IUU fishing prevalence. Conversely, remoteareas of the high seas are harder to monitor or may besubject to fewer management restrictions, leading totheir under-representation in the analysis; yet illegal
and unsustainable activities may be widespread.

The analysis of offshore fishery projects publishedby MARA also raises concerns about the reliability
and accuracy of data published. These concerns are
epitomised by the case of Ghana. According to the data
published by MARA, Ghana ranks as the 13th mostimportant EEZ in number of approved offshore fisheryprojects with 13 such projects for the period 2019-2020(covering 13 fishing vessels). This figure underestimates
the actual number of fishing vessels beneficiallyowned by Chinese natural and legal persons activein the country. As highlighted in a 2021 report,40 EJF
estimated that at the end of 2019, 8 companies basedin China beneficially owned 57 fishing vessels licensed
to operate in Ghana’s EEZ. On the basis of licence data
published by the Ministry of Fisheries and Aquaculture
Development of Ghana in June 2020, the discrepancy

Data bias may also be introduced due to spatial
variations in enforcement, monitoring andsurveillance effort. That there is a lack of identified
or recorded cases of IUU fishing or human rights
abuses does not necessarily mean that the instances
are reduced – and may well reflect a lack of capacity
or political will to monitor, record and act upon
any suspected contraventions of conservation andmanagement measures.

10Section 1 – Characteristics of the CDWF
1.1. Contemporary history
In 1950, global marine capture of fisheries was 16.7
million tonnes,41 increasing fivefold to 84.4 million
tonnes by 2018.42 This growth was driven by a rapidly
increasing demand as the world population tripledover the same period. Supply-related factors havealso made a significant contribution to increasing
catches, for example through an increased efficiency
in fishing vessels’ abilities to locate and capture larger
quantities of fish due to major technical developments.
Furthermore, public policies have seen substantial
government subsidies awarded to many of the world’s
largest fishing actors – making what would normally be
loss-making operations financially viable.

The governance of the CDWF occurs across two scales:
national and provincial. Compared to the national DWF
regulations which mainly provide a legal framework,
the provincial regulations play a more direct role inrestricting or encouraging aspects of distant-water fishery
activities. The dual governance system can often lead tofractured and sometimes contradictory messaging andaction being taken around the operations of the CDWF.

National Distant Water Fishery Bases of the People's
Republic of China

Over this period, Europe, the Americas and Asia are themain regions driving the increase in marine capture. In
Asia, the performance of China is notable, particularlyin the last four decades. Between 1987 and 2019, China’s
marine capture production increased by 150%, with ayearly average production growth of 3% over the period,
peaking at 8% in the 1990s.43
This coincided with the ramp-up of the deploymentof the Chinese fishing fleet in distant-fishing grounds,
which began in 198544 as a response to overfishing in
China’s coastal waters and surrounding seas and asa means of creating employment opportunities.45,46
Between 1987 and 2019, the yearly average productionof the CDWF grew by nearly 14%, much faster than the
country’s total marine capture production.47 The CDWF
now forms an integral part of the country’s politicalpriorities and is presented as an important componentof the implementation of China’s “Going Out” policyand “Belt and Road” initiative.48• Shandong: Weihai (Shawodao) DWF base (tuna, squid)• Zhejiang: Zhoushan DWF base (tuna, squid)• Fujian: Fuzhou (Lianjiang) DWF base (other fish)

The issues caused by the partial decentralisation of
CDWF governance can be seen in the recent difficulties
of reconciling national level demands for sustainability
against regional economic ambitions. According to
the Thirteenth Five-Year Plan52 for the national distantwater fishery strategy in 2017, MARA also establishedthe goal to limit the size of the national distantwater fishery fleet to a maximum of 3,000 vessels by
the end of 2020 and the total number of approved
DWF companies to 2016 levels. The national goal ofcontrolling the number of vessels and total tonnage is,however, in contradiction to the regional target whichis to further develop the distant water fishery sector.53
The provincial/prefectural level governments received
pressure from MARA to decrease both the fishing effortof their resource-depleted nearshore fishery54 and tocontrol the level of the DWF.

According to data published by the Food andAgricultural Organisation (FAO), in 2018, China49 was
the world’s largest producer of marine capture – with12.7 million tonnes produced.50 Alone, it accounted
for 15% of the world production – 20% of which wasreported to originate from its DWF. The China Fishery
Statistical Yearbook 202051 highlights that China’s
marine capture production slightly decreased to 12.1
million tonnes in 2019, with the share of the production
originating from the DWF remaining stable though
the number of vessels listed as distant-water vessels
reportedly increased by 47 to reach 2,701 vessels.

11

1.2. Main locations and areas ofoperation in 2019 and 2020

However, to fulfil the mandate of securing regional
food security and diversity and building a “strong ocean
province55”, provincial and regional governments provide
subsidies or rewards to encourage companies to purchasevessels from other provinces; to attract companies fromother areas to register in their province;56 or to trade fishat their provincial/prefectural trading centres.

One consequence of this lack of data is the difficulty
it creates for those attempting to effectively map its
areas of operation – even at the very general level of
FAO major fishing areas.60 This section of the reportseeks to contribute to these efforts through the analysisof MARA offshore fishery projects – exploring thegeographies within which the CDWF appears to be
most prevalent.

There has been a significant shift in the patterns ofownership seen in the CDWF. Whilst it has previously
been characterised by state-ownership, a significant
majority of vessels are now seemingly owned
privately. According to analysis conducted in thisreport, currently, approximately 68.8% of the vessels
are owned by private companies, 22.5% of which are
directly owned by Chinese government-controlled
companies, and an additional 8.7% of which the
Chinese government has indirect shareholdings.

The results of the analysis confirm that three decades
after the Chinese fishing fleet started expanding to
distant-fishing grounds, China has become a truly
global fishing nation which relies significantly on its
DWF to consolidate its position as the world's largest
marine capture producer and, as previously highlighted,
pursue its political agenda.

Whilst progress has been made, the availability of
information on the CDWF remains limited. Though the
FAO acknowledges that “the estimates of total catches
for China in the FAO database are generally considered
to be complete”,57,58 China only reports information on
species and fishing areas of its DWF for the fisheries
products marketed in China. These products represent
only about 40% of the catches made by its DWF.59

Based on the information retrieved, EJF found that
33.6% of the approved offshore fishery projects
published in 2019 and 2020 covered specific EEZs
whilst the remaining 66.4% referred to oceanic areas
such as the Indian Ocean or North Pacific. Africa stands
out by its apparent importance for the activities of the
CDWF, accounting for 78.4% of the approved offshore
fishery projects and 20 of the 29 EEZs mentioned in
the notices published. Asia ranks second, accountingfor 19.7%, followed by South America which accounts
for 1.9%. The top ten EEZs in which the CDWF had
approved offshore fishery projects can be found in
Figure 1 and the full list in Appendix 1.

Chinese squid vessels at port in Montevideo, Uruguay. © EJF

12

Of projects covering specific EEZs, the notices published highlight the EEZ of Mauritania as the one where thepresence of the CDWF is, by far, the most significant. Mauritanian fishing grounds account for approximately 30%of the vessels covered by projects related to specific EEZs. It is followed by Myanmar, Guinea-Bissau, Senegal and
Morocco. Mauritania is one of the most significant West African countries linked to the production of fish meal andfish oil (FMFO), much of which is exported to feed fish farms that serve China, Europe and other wealthier regions.61
FMFO production has transformed the political ecology of small-pelagic fisheries in the region – as they are caught
and sold for processing into FMFO. This puts small-scale fishers, who rely on these species for food and livelihoods,
in direct competition with large industrial vessels and multinational corporations (many of which are Chinese), whohave exerted their significant political and financial power to access vital natural resources in the country.

Figure 1. Ten foreign EEZs with the largest share of approved offshore fishery projects published by MARA
in 2019 and 2020

Mauritania

29.9%

Myanmar9.3%

Guinea-Bissau

8.6%

Senegal

6.7%

Morocco

5.8%

Guinea5.3%

Sierra Leone

4.1%

Madagascar

3.1%

Malaysia

3.1%

Iran

3.0%

Other areas
TOTAL

21.1%
100.0%

Table 2: Offshore fishery projects covering oceanic
areas for which information was published andcould be retrieved in 2019 and 2020

In respect of the projects covering oceanic areas,
the notices published on the MARA website forthe period 2019-2020 highlight the importanceof the Indian Ocean for the CDWF. It accounts forapproximately 27% of the approved offshore fisheryprojects covering oceanic areas. It is followed by
the North Pacific Ocean, Southwest Atlantic Ocean,Southeast Pacific Ocean and “Pacific Ocean”.62 The
Northwest Pacific, Atlantic Ocean and Southern
Ocean complete the list. This subdivision of the
Pacific Ocean – and to a lesser extent the Atlantic
Ocean – obscures the fact that the Pacific Ocean is theoceanic area where the presence of the Chinese DWF
is the most significant (approx. 52%). The full list ofoceanic regions can be found in Table 2.

Oceanic areas

Percentage of the total number ofvessels covered by projects related
to oceanic areas

Indian Ocean

27.0%

Pacific N

22.9%

Atlantic SW

20.2%

Pacific SE

20.0%

Pacific Ocean

5.0%

Pacific NW

4.3%

Atlantic Ocean

0.4%

Antarctica

0.2%

Source: MARA Offshore Fishery Project notices

13

Most common gear types registered in offshore fishery projects published by
Chinese Ministry for Agricultural and Rural Affairs in 2019 and 2020
Based on the information published by MARA for the period 2019-2020, trawlers were the mostcommon type of vessels covered by EEZ-specific approved offshore fishery projects, with more than
three in five fishing vessels operating trawls. This is followed by gillnets and stow nets, respectively
accounting for 11.3% and 9.0%; with gillnets mainly used in Mauritania and stow nets reported to
be used exclusively in Myanmar.
With regards to oceanic areas, vessels equipped to target squid would represent more than two
in three approved offshore fishery projects. The strong and relatively stable presence of vessels
equipped to target squid across all oceanic areas (with the exception of the Southern Ocean region)is consistent with the distribution and habitats of squid species,63 and the locations of the main
exploited fishing grounds.64,65

Large squid catch on a Chinese industrial vessel. © EJF

It is also consistent with the emphasis China has put on developing its capacity at targeting squid
species in recent years. In 2020, MARA described it as the “main object of fishing and utilisation [ofthe] country’s offshore fisheries” and highlighted that China had become the world’s largest squid
fishing nation, trader and consumer.66 Data published in the China Fishery Statistical Yearbook
2020 confirms this statement. In 2019, squid species alone accounted for 20% of China’s DWF
capture production.67 The increasing importance of that segment of the CDWF is illustrated by theevolution of the “Industrial Prosperity Index” over time. This index aims at serving as a barometerof the industrial development and prosperity of the sector. Between 2010 (the reference year) and2019, it increased by nearly 58% and peaked up to an increase of 74% in 2015 compared to thereference year.68

14

The notices published on the MARA website also show that refrigerated cargo ships (reefers) supporting the CDWF
were present in all oceans where catching vessels of the CDWF operate, with the exception of the Southern Ocean
region. Based on the information retrieved, they represent a non-negligible and relatively stable share across all
geographies of the approved offshore fishery projects covering oceanic areas (4.5%). Whilst the transfer of fish at
sea to reefers (known as at-sea trans-shipment) is often legal and in line with national or regional conservation andmanagement measures – at sea trans-shipment is a facilitator of IUU fishing and human rights abuses, isolatingcrew and allowing the ‘laundering’ of IUU caught fish.69

Figure 2. Global distribution of the CDWF based on the approved offshore fishery projects published by
MARA in 2019 and 2020

While there are many aspects to achieving sustainable management and conservation of fish populations, anderadicating IUU fishing and fisheries crimes, the public availability of credible information on fishing vessels’
activities is essential.70 The inability to draw up an accurate account of the main locations and areas of operationof China’s DWF from the data71 made public by MARA results in barriers for relevant states and actors in the
supply chain to make informed management decisions, and to be able to verify the status of vessels and ascertain
the legality of their activities.

15

1.3. Onshore structures of the various Chinese Distant-Water Fisheries
Key fisheries and methods of fishing that are associatedwith the CDWF each have particularities relating to theonshore governance structures. Most notably, perhaps,is the fact that they are often found to be associatedwith particular provinces. This was evident in dataobtained for this report, as well as the strategic papers
and the subsidies or rewards provided by the provincial
government. The following analysis looks at three key
fishing sectors that largely encompass the catch of the
CDWF: squid, trawl and tuna. Details of the proportionof CDWF registrations associated with each province
can be found in Table 3.

The Zhoushan base in Zhejiang is one of the threenational DWF bases in China73 – important logistic
hubs harbouring DWF vessels, distributing catches
returned to port and facilitating further processing foraquatic product processing companies. The annual
squid landing in Zhejiang province constitutes morethan 67% of the national squid yield.74 However, many
vessels and companies in Zhejiang still take advantageof the “dependency model”.75 In these cases, the DWF
companies do not operate and manage the vessels
and their production directly. This makes the DWF
management challenging for the provincial authority
but also for the enterprises themselves. To mitigate
the impact of loose management of the Zhejiang squid
jiggers, the DWF authority in Zhoushan has attempted
to tackle this problem by appointing a commander
vessel, Pu Yuan 801 – tasked with coordinating fishingvessels of different companies to ensure safe and lawful
production, and to provide medical treatments in theSouth-eastern Pacific squid fishing ground.76

1.3.1. Squid fishery
Zhejiang is the major squid-fishing province. Whileharbouring a quarter of the Chinese fleet and morethan 60% of the squid jigging vessels, companies
registered in Zhejiang province, however, arenumerous but generally smaller in scale. Except forsome large enterprises with complete industrial chainsfrom fishery through to market such as Zhoushan
Ningtai Ocean Fisheries, Pingtairong Ocean Fishery
Group, and China Wanxiang Holdings, about half of
the Zhejiang vessels are run by small to medium sizedcompanies which primarily focus on fishery. Moreover,a vessel’s ownership often belongs to individuals. Thisis partly due to the nature and the long history of thesquid fishery.72

The loose management of the squid fishery is also
reflected in the supply chain. In recent years, thesquid-fishing DWF companies in Zhoushan started tocollaborate with each other through “cooperatives”
which allow them to process, store, transport andsell caught fish as a single entity, facilitating better
regulated wholesale and retail prices.77 For instance,
the largest squid cooperative in Zhoushan – Zhoushan
City Pelagic Fishery Professional Cooperative –currently has 255 corporate or individual members whocollectively own 370 vessels. The squid cooperative
facilitated 20 marine trans-shipments of frozen squidamounting to 107,544 tonnes and achieved a 20.8%
increase in sold price per tonne compared to theprevious year. Moreover, the affiliate members of thecooperative also receive loans from local banks as apart of the banks’ Offshore Fishery Loan programme, toimprove the capital turnover of small and medium size
squid DWF companies which are highly dependent onfuel subsidies or easily affected by sluggish sales.78
The China National Fisheries Corporation (CNFC)
also sells raw squids through the squid cooperative.79
Moreover, judging from the IUU fishing cases thisreport has collected and analysed, the vessels belonging
to the same cooperative tend to fish together and arethus also more likely to be involved in IUU fishingincidents together (see Section 4 for more details).

Table 3: Proportion of top six provinces with
CDWF registrations
Province

Percentage of CDWF
registrations

Zhejiang

25.2

Fujian19.6

Liaoning

11.8

Beijing

10.7

Guangdong

8.3

Shanghai

3

Source: MARA Offshore Fishery Project notices

Even though Zhejiang constitutes a significant portionof the CDWF and the fishing effort, the authorities
have acknowledged the development bottleneck due

16A Chinese owned trawler in Ghana. © EJF

to the incomplete processing and distribution network
for most of the small or medium-size squid fishingcompanies. Consequently, since 2018, about two thirdsof the squid caught annually by the Zhejiang fleet was
sold to Fujian and Shandong provinces for further
processing.80 For instance, Shandong province only has
25% of the national squid fleet, however, more than
60% of the national squid catch was processed in thenational DWF base in Shawodao, Shandong, managed by
the Jinghai Group.81 In order to secure the overall profitof the province, the Zhoushan DWF base has provided
financial rewards for every tonne of fish shipped backto Zhoushan82 – for instance, 300 yuan (approx. US$ 47)
for each tonne of chilled or ultra-low temperature frozen
tuna; 100 yuan (approx. US$ 15) per tonne of squid,bonito, mahi mahi or saury; 200 yuan (approx. US$ 31)
per tonne for frozen tuna and all other kinds of fish.

company, whose chairman has been accused of using
PME and other Chinese and overseas subsidiaries tofinance international crimes of fraud, poaching, and evenhuman trafficking, something he strongly refutes.84
Fujian province has several important hubs for DWF
products. For instance, one of the three national DWF
bases is located in Lianjiang county, Fuzhou, Fujian.
Moreover, the Fujian government is expanding theMawei Free Trade Zone, which is currently the largest
distribution and processing centre of DWF products in
China, and an important seafood trading centre in Asia.
More than 500,000 tonnes of DWF products are traded
there annually, accounting for 35% of the annual DWF
production in China.85 Moreover, the Mawei Free Trade
Zone is also an important hub for distributing sharkscaught by CDWF vessels, part of the products allegedly
coming from West Africa.86 For instance, China Shark
Products Cooperative, located inside the Mawei Free
Trade Zone, buys sharks from vessels and distributes
them through their global network.87 Members of
the Cooperative may also have been involved in thenotorious illegal shark-transporting case of “FU YUAN
YU LENG 999” in the vicinity of the Galapagos Islands
in 2017.88 The shark species seized on the transporting
vessel include several species listed by the Convention
on International Trade in Endangered Species ofWild Fauna and Flora (CITES) such as scalloped
hammerheads, oceanic whitetip sharks, and pelagic
threshers, which are all advertised as saleable specieson the company website.89

1.3.2. Trawl fishery
The Fujian province has the second highest proportionof CDWF registrations (19.6%) with its fleet boasting
the largest coverage of the world ocean – Fujian
vessels are listed in every fishing ground except for the
Northern Atlantic and they contribute to every typeof fishery. Despite the higher diversity of its fishery, in
general, trawling is the Fujian fleet’s focus. Two Fujian
enterprises, Pingtan Marine (PME) and Hongdong
Fishery, alone own 11% of the entire Chinese DWF
vessels, and 95% of their vessels are trawlers. For
Hongdong, the caught fish was mainly to replenish theraw material for overseas fish meal factories. Hongdong
has been fishing for small pelagic species off the coast of
Mauritania since 2010 and subsequently also in Guyana83– a country that has not been identified as covered byapproved offshore fishery projects during EJF’s analysis.
The company owns industrialised fishing bases in bothcountries and is looking for further expansion. On theother hand, PME mainly fishes in Southeast Asia andthe Indian Ocean. PME is a Nasdaq Stock Market-listed

The Fujian fleet has the highest production at thenational level. By 2023, the Fujian government aims
to have 650 DWF vessels, an annual production of
600,000 tonnes, and 65% of the production shippedback to China.90 Within the province, Fuzhou – wheremost of the Fujian DWF companies are located – aimed
to achieve 600 operating vessels and 400,000 tonnesof annual production at the city-level by 2020.91

17Chinese industrial vessels at port in Montevideo, Uruguay. © EJF

The city authority acknowledged the difficultyof achieving the goal due to the controls on newvessel registry from the central government, andthat only 77% of the target vessel number and 81%of the production goal were achieved.92 However,
due to Fujian’s diverse fishery and a more complete
processing facility, a high percentage of fisheryproduct caught by the Fujian fleet is shipped back to
the province for further processing (e.g., 74% at thefirst half of the 2021).93

The Liaoning fleet only comprises 12% of the entire
CDWF. However, its vessels are predominantly trawlers,
making it the province with the highest percentage of
trawlers (25% of Chinese trawling vessels). Throughanalysis of the sanction data published by MARA, italso appears that despite being a relatively smaller fleet,
there appears to be high-instances of vessels linked to
Liaoning involved in IUU fishing activities.

Some of the DWF subsidiaries of the China Agricultural
Development Group have long-term collaborations withseveral overseas joint ventures on trawling projects.
For instance, as a subsidiary of CNFC, Zhongyu Global
Seafood manages at least 176 trawler and purse seine
vessels, company assets, and 11 fishing projects in
African countries, such as Guinea, Guinea-Bissau,
Sierra Leone, Senegal, and Madagascar.94 A trading
company CNFC-Quick State Limited (CNFC-QSL)
was established in Las Palmas in the Canary Islands,
Spain, in order to facilitate the sales of fish products
to European and African markets, and to coordinate
fishing and shipping from African fishing grounds.

1.3.3. Tuna fishery
Beijing is the only inland administrative district
involved in the DWF industry in China. All Beijingregistered companies are controlled by the state-owned
enterprise, China Agricultural Development Group,
which has several tuna-targeting DWF subsidiaries suchas the Chinese stock market-listed (A-share, domestic
shares) CNFC Overseas Fisheries and Zhejiang Fenghui
Ocean Fisheries. China Agricultural Development
Group owns 12.7% of the entire CDWF, and theirbusiness covers much more than fishing – including
seafood export, repair and maintenance. Most of thefishing projects of the China Agricultural Development
Group are in West Africa, the Pacific Islands, and theIndian Ocean. The Pacific Islands are the company’s
focus in the tuna industry, and among them, Fiji has an

Another province which is heavily involved in the
trawling industry is Liaoning, whose main fishinggrounds are in West Africa and the Indian Ocean.

18especially long collaboration history with CNFC. The CNFC’s representative in Fiji
manages 42 tuna longliners and 553 fishers fishing around the Pacific Islands. In
2016, the fleet landed 14,000 tonnes of tuna.95 The caught tuna were shipped backto Fiji to go through initial processing. The main clients of CNFC are primarily in
the United States and Japan.
In recent years, CNFC has extended their focus to Vanuatu. The Zhongwa Fishery isa joint venture of CNFC and the Vanuatuan government. Previously, tuna caught in
Vanuatu’s EEZ had been shipped to Fiji for further processing.96 However, Zhongwa
Fishery has since established ports and onshore processing sites in order tofacilitate fish landing, and to extend the tuna production chain in Vanuatu.97
In return, the Vanuatuan government has promised to facilitate the issuing offishing licences and the development of fishery resources within their EEZ.98
Another province focused on the tuna industry is Shandong. Its tuna vessels accountfor 30% of the national tuna fleet. The main fishing grounds for Shandong province
are the Indian Ocean, the Pacific Islands, and West Africa. Like Fujian province, theDWF industry in Shandong is controlled by several large enterprises that possess
fleets of a considerable size (more than 30 vessels) and mature processing and sales
capacity. Vessels from the top five Shandong DWF companies account for 34.8% of
the provincial vessels. Several Shandong DWF companies are listed on the national
stock exchange market, including Shandong Zhonglu Oceanic Fisheries99 andRongcheng Homey Ocean Fishing.100 Other important enterprises include Xinfa
Holdings (owns the DWF company Lanrun Group), Qingdao Luhaifeng Foodstuff
Group (owns Qingdao Yuantong Pelagic Fisheries), and Jinghai Group.
Rongcheng city in Shandong is one of the national DWF bases in China, and is
an important tuna landing site. For instance, the city has one of the largest tunaprocessing facilities in the country owned by Xinfa Holdings. Before 2010, 90%of tuna caught by the Chinese fleet was sold to foreign countries such as Japan forfurther processing due to the lack of technical ability.101 Enterprises such as Xinfa
Holdings and Qingdao Luhaifeng started to invest in extending the processing
chain and utilising tuna from flesh to bones. Today, 100% of tuna caught by Xinfa
Holdings is shipped back to China for further processing – ranging from tuna cansto collagen peptides powder.102 Since 2012, Qingdao city government in Shandong
has promulgated several notices and introduced subsidies and rewards targeting
further development of its DWF industry and the “blue granary” – the seafood
resources.103,104 Attracted by the financial rewards, five DWF companies from otherprovinces have since relocated to Qingdao city,105 whose fleet has grown 17-foldwithin the past eight years, with an additional 169 vessels since the introduction of
the new policy.106
In recent decades in Zhejiang province, larger enterprises like Zhejiang Ocean
Family (China Wanxiang Holdings) have switched their focus from squid to tuna.
Zhejiang Ocean Family has 15 branches and 18 subsidiaries scattered across China,
Argentina, Kiribati, and Hong Kong, and they cover various seafood-related sectors
ranging from fishing and catering, to retail.107 In recent years, Kiribati’s EEZ has
become an important fishing ground for Zhejiang Ocean Family, whose one billion
yuan (approx. US$ 157M) investment in the small island nation’s tuna industry is
Zhejiang Ocean Family’s highest overseas investment so far.108 In 2020, Zhoushan
DWF base landed and processed 120,000-140,000 tonnes of tuna and tuna-likespecies from the Chinese purse seine fleet operating in the Central and Western
Pacific, including 70,000 tonnes contributed by companies based in Zhoushan.109
About 43% of Ocean Family’s tuna was sold to overseas markets. For instance, its
long-time client, the Japanese Mitsubishi Group, contributes about 11% of Ocean
Family’s annual income.110

19Chinese trawlers at port in Dakar, Senegal. © EJF

Moreover, the tuna market within China is also growing,
including for high-end chilled fresh products such asBluefin Tuna. In relation to this particular species, it isreported that Ocean Family supplied 60% (300 tonnes)of China’s demand in 2018.111 Products are also sold via
emerging e-commerce platforms such as Fresh Hemaand Jingdong. Zhejiang Ocean Family is currently
seeking to be listed on the Chinese stock exchange.

national policy objectives114 – at least US$ 6.5 million
in the form of government subsidies in 2015, andapproximately $8.8 million in 2016.115
Although the size of the tuna fleet is relatively small
in Liaoning province, the CEO of one of Liaoning’s
largest tuna-fishing enterprises, Dalian Ocean Fishing,
Zhenyu Li, also associates with the large tuna-targeting
enterprise, the Shanghai Kaichuang Deep Sea Fisheries,
through investment. Dalian Ocean Fishing is a
Chinese subsidiary of the Cayman Islands-registeredshell company, China Tuna Industry Group Holdings
Limited.116 Its tuna longliner business in China ismanaged by the holding company, Dalian Longtai
Investment (Dalian Jinmu Investment Group). Dalian
Ocean Fishing has had several failed attempts to belisted on the Chinese stock market. In 2014, Greenpeace
revealed that the company used outdated data for bigeye
tuna populations and overestimated the sustainabilityof the species.117 Subsequently, the company pulled
its initial public offering (IPO) which was backed
by Deutsche Bank AG from the Hong Kong Stock
Exchange.118 In 2016 and 2018, Dalian Ocean Fishing had
another two failed attempts of reverse the takeover of
one ore smelting company and a food company to makeits way to the Chinese stock exchange.119

The majority shares of Zhejiang Ocean Family
appeared to be ultimately held by Wanxiang
Holdings (76.5%) with Chairman Weiding Lu listed
as the ultimate beneficiary, thus the company
considers itself a privately-held entity. However,
several state-owned companies together have aconsiderable indirect share of interest in the Zhejiang
Ocean Family (23.5%).112 Focusing on the agricultural
sectors, Wanxiang Group has been classified as anationally important corporation by the ChineseState Council. Based on the company’s 2015 annual
report, the previous CEO Guanqiu Lu, Weiding
Lu’s father, was formerly a member of the National
People’s Congress (NPC), and one of Wanxiang’sboard members had received a special salary fromthe State Council.113 The conglomerate also receives
government support in exchange for fulfilling20

Section 2 – IUU fishing activities of the CDWF
2.1. Location of IUU fishingby CDWF

Table 4: IUU fishing incidents associated with the
CDWF 2015-2019

An analysis of the spatial distribution of IUU fishing
offences between 2015 and 2019 (Table 4) showsthat West Africa was the region with the highest
number of incidents (within EEZs), accounting for
28% of offences for which location information was
specified (Figure 3). The highest number of offencesin West Africa were identified for Ghana, followedby Sierra Leone and Mauritania (Figure 4). EJF has
identified further instances of suspicious vessel
activity involving Chinese-owned trawlers in Ghana,including multiple alleged incursions into the
Inshore Exclusion Zone (IEZ) reserved for small-scale
fishers (Appendix 2).120 These incidents were notincluded in the analysis so as not to over-represent
Ghana with regard to IUU fishing prevalence due to
EJF’s presence in the country.

Year

Number of incidents(2015-2019)% of total

2015

18

3.2

2016

140

25.2

2017

253

45.8

2018

95

17.1

2019

48

8.7

Total
(2015-2019)

554

100.0

Source: Coastal state governments, EJF findings, MARA IUUfishing notices, media/NGO reports, Spyglass

Figure 3: Location of IUU fishing incidents involving Chinese-flagged or owned DWF vessels within EEZs
(2015-2019)21

As previously mentioned, West Africa has long been considered a hotspot for IUU fishing. The findings made on
the location of such incidents involving Chinese-flagged or owned DWF vessels within EEZs support such a claim.
However, the region has been the target of multiple joint operations by combinations of regional institutions (e.g. the
Sub-Regional Fisheries Commission)/NGOs/coastal states, as well as NGO investigations into illegal fishing activity,
as detailed in Case Studies 1-2. As highlighted in the methodology, the intensive focus of recent NGO campaigns inWest Africa – as well as the significance of the region for the activities of the CDWF – may serve to over-represent theregion in terms of IUU fishing. Nevertheless, the prevalence of IUU fishing has particularly critical implications, inview of local reliance on marine fisheries resources for livelihoods and food security in the region.

Figure 4: Distribution of IUU fishing incidents involving Chinese-flagged or owned DWF vessels acrossWest African coastal states (2015-2019)

A small-scale fishing community in Sierra Leone. © EJF

22

Case Study 1: Greenpeace and Sea Shepherd at-sea patrols inWest Africa
Greenpeace International and the Sea Shepherd Conservation Society are internationalNGOs working globally to conserve marine animals and combat IUU fishing. Bothorganisations have operations that involve collaborating with, and providing support
to, coastal states in West Africa to conduct at sea operations to apprehend vessels
suspected of IUU fishing.
Both NGOs have conducted monitoring and boarding of vessels suspected of IUU
fishing across the Gulf of Guinea, including in The Gambia, Guinea, Liberia and Sierra
Leone. On a number of occasions, vessels that were subject to inspection by the NGOs
were linked to Chinese ownership.
In 2017, the Sea Shepherd crew assisted Liberian authorities with the arrest of a
Chinese-flagged reefer ‘M/V HAI FENG 823’ at port in Monrovia, a 74 metre vessel
with a history of IUU fishing, and suspected of receiving fish from other IUU fishingvessels.121 A close inspection of the vessel and its cargo found that it was carrying
81 tons of unauthorised and unreported fish on board. The vessel was ultimatelyarrested for three charges: lying to a Liberian Coast Guard officer, presenting falsified
documents and conspiring to evade the tax and customs laws of Liberia.
In November 2020, this time in The Gambia, Sea Shepherd assisted in the detentionof Chinese flagged vessel ‘JURONG YU 9’ – which was arrested and taken to port in
Gambul. The vessel was found to have irregularities in its fishing log book, and failingto show proper markings on the vessel – with different names presented on its bow
and stern.122
In March of 2017, the Greenpeace vessel ‘Esperanza’ undertook joint surveillance
operations in the EEZs of Guinea Bissau, Guinea, Sierra Leone and Senegal – anexcursion that inspected 37 vessels and identified 17 vessels thought to be operating incontravention of relevant fishing regulations.
Of these 17 vessels, 9 were flagged to China, and were accused of a range of offences.
In Guinea Bissau, three Chinese vessels (the YI FENG 8, YI FENG 9 and YI FENG 10)
displayed their names only in Chinese. This is in breach of local laws that dictate allvessel names must be easily recognisable to local officials. A further Chinese vessel(the CHANG YUAN YU 05) was arrested for a previously unpaid fine for the use ofillegal nets in September 2016. Further vessels were arrested in Guinea, for offences
including shark finning and illegal net adjustments, and in Sierra Leone for illegal
nets, no logbooks and offloading without proper authorisation.

23

Case Study 2: E JF’s findings on illegal activities of Chinese-owned bottom
trawlers undermining human rights in Ghana
The economic benefits accruing to West African coastal states from bottom trawling are limited,123
making the destructive nature of this gear type all the more unpalatable.124 EJF has paid close
attention to the Chinese-owned trawl fleet in Ghana for a number of years, identifying how thisdestructive mode of fishing fundamentally undermines the human rights of small-scale fishingcommunities in the country. A 2021 report by EJF found numerous human rights issues arising inlarge part due to industrial overfishing and IUU fishing operations, including 80-90% of fishers
and post-harvest workers reporting a decline in income over the past 5 years, 75% of fishers
reporting increased encounters with trawlers and 70% claiming they have had fishing gear
damaged by them.125 The same study depicts the ripple effects of reduced income, with 50% offishers and 60% of post-harvest workers stating that they have gone without sufficient food in thelast year, 15-20% of children having left school before finishing primary education and between
70%-75% of respondents saying that their living conditions have declined over the past 5 years.
EJF has observed a wide-range of suspected IUU fishing by the fleet, frequently communicatingsuch instances to Ghana’s Ministry of Fisheries and Aquaculture Development (MOFAD). Using
both satellite tracking data and local informants, EJF has documented frequent suspected andconfirmed incursions by Chinese owned trawlers into the Ghanaian IEZ between 2017-2021.126
Beyond creating direct competition for fish stocks between large industrial vessels and local
communities, these incursions can damage fisher’s nets, endanger smaller vessels through therisk of collision and increase the risk of conflict – with some fishers reporting threats and abuse
when they have approached trawlers fishing illegally.127
One illegal practice that has become increasingly commonplace in recent years is the deliberatetargeting of severely depleted small pelagic fish populations – the mainstay of small-scale
fishers – and selling these species back to communities for profit. This practice, known locally as‘saiko’, involves the transfer of frozen fish – often caught in breach of the trawler’s fishing licenceconditions – to specially adapted canoes at sea. Industrial trawlers have been observed landing
small pelagics in significant quantities – with saiko evolving into a highly organised, illegal andlucrative industry. In 2017, EJF estimated that 100,000 tonnes of fish were traded through saiko,with a landed value of over US$ 50 million.128 In-port monitoring by EJF found that illegal saiko
landings increased by an estimated 28.5% between 2019 and 2020. In 2020, 704 saiko canoes
were observed landing openly at Elmina port, equating to an estimated 18,586-30,976 tonnesof fish and suggesting a rate of 33-45% of catches going unreported.129 Many of the fish landed
are juveniles, caught using illegal sized nets and harvested before they have had a chance toreproduce and contribute to rebuilding the fishery. The activities of the Chinese-owned trawl fleet
are considered a major factor in the recent collapse of the Round Sardinella (Sardinella aurita)
fishery in the country.130

24

Outside of coastal state EEZs, the highest number of IUU fishing offences involving CDWF vessels were identified
on the high seas,131 accounting for 7% of offences for which location information was specified (Figure 5), followedby the Western & Central Pacific Fisheries Commission (WCPFC), South Pacific Regional Fisheries Management
Organisation (SPRFMO) and Indian Ocean Tuna Commission (IOTC) Convention areas (accounting for 5%, 3% and
1% of total offences, respectively).

Figure 5: Location of IUU fishing incidents involving Chinese-flagged or owned DWF vessels outside of
EEZs (2015-2019).

2.2. Location of IUU fishing incidents by gear type
Vessel/gear type could be discerned for 350 of the 554 cases: of the 350 cases, 31% involved trawl vessels (demersal,
cephalopod and midwater trawlers), with longliners and squid jiggers accounting for 28% and 20% of cases, respectively(Table 5). Together, these three vessel types accounted for almost 80% of identified IUU fishing incidents involving the
Chinese DWF, with purse seiners accounting for a further 12% of the total.

Table 5: IUU fishing incidents linked to CDWF vessels by vessel/gear type (2015-2019)*
Vessel (gear) typeNo. of IUU fishingincidents identified(2015-2019)

Percentage of total
IUU fishing incidents
identified in this study

Percentage of IUU fishingincidents for which vessel/
gear type ascertained

Trawler

108

19.6

31.1

Longliner

98

17.7

28.0

Squid jigger

69

12.4

19.7

Seiner

42

7.6

12.0

Gillnetter

15

2.7

4.3

Reefer

7

1.3

2.0

Driftnet

7

1.3

2.0

Drifting longline

3

0.5

0.9

Other/not specified

205

36.9

-

Total

554

100.0

Notes * Where specified/possible to discern from the data available.
Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media/NGO reports, Spyglass

25

Chinese trawlers at port in Dakar, Senegal. © EJF

2.2.1. Trawlers
Of the total IUU fishing incidents analysed involving
trawlers, at least 44% of offences involved demersal
trawlers.132 The west coast of Africa is a key destination
for demersal trawling by the CDWF. According to someestimates, the region hosts around 350 Chinese DWF
vessels,133 an estimated three quarters of which arebottom trawlers targeting demersal fish and bottomdwelling invertebrates, notably shrimp. Analysing
the data published by MARA in 2019 and 2020 on theapproved offshore fishery projects, EJF found that 559
of such projects received approval in the region. As
previously highlighted, MARA’s data also highlighted
the intensive use of trawl gears in foreign EEZs by the
CDWF. Annual catches by China’s bottom trawl fleet inWest Africa have been estimated at around 2.35 million
tonnes per annum, or around 50% of the country’s total
distant-water catches, with a landed (ex-vessel) valueof approximately US$ 5.4 billion per year.134 The EEZsof Ghana, Indonesia and Guinea were the locationof over half (56%) of IUU fishing incidents involving

Chinese-flagged or owned industrial trawl vessels
identified during the period 2015-2019. The Gambia
and Sierra Leone were the location for a further 15%
of total offences by the trawlers of the CDWF.135 The
impacts on coastal communities in West Africa ofintensive trawling, overcapacity, IUU fishing andother interlinked stressors such as global heating,are devastating. However, not all feel these impacts
equally – with social structures and inequitable power
dynamics often meaning they can be worse dependingon gender, caste, wealth and age (Case study 3).

26Case Study 3: The gendered impacts of unsustainable fishing in West Africa
The pressures placed on West African fisheries following decades of overfishing by industrial trawlers has
had a catastrophic impact on coastal communities in the region – driving nutritional deficiencies, lost
livelihoods and poverty. Estimates suggest that the income of some canoe fishermen has fallen by 40% in
the last two decades.136 The knock-on effects of this reduction in catch and associated financial hardshipare reduced access to healthcare, education, and alternative livelihood opportunities – creating a cycle ofexacerbated poverty and human suffering, as well as further ecological degradation.

Ghanaian women sell fish at Bawjiase market, Central Region, Ghana. © EJF

Research continues to find, however, that women are disproportionately impacted by declining fish
populations.137 Broadly speaking, the various roles in the small-scale fishing communities of West Africa
are distinguished by gender – with men predominantly travelling out to sea to capture fish and womentasked with post-harvest roles, including the processing and sale of fish.
Whilst women are integral to the small-scale fishing economy, patriarchal social structures and genderbias across institutions often leave them disempowered – excluded from fisheries governance decisions
and having reduced access to capital. It has been noted that a response to the lack of financial income
resulting from reduced catch has forced some women in the region into transactional sex (known as ‘fish
for sex’), and left some vulnerable to predatory financial loans.138
Research from various West African nations including Ghana139 and Senegal140 has also found that womenin fishing communities find that their lack of access to capital and other resources is compounded bysocial norms in which they are responsible for household upkeep and childcare. As such, in the face of
declining fish stocks, women who could normally rely financially on their husbands are facedwith the ‘double burden’ of unpaid care work as well as engaging in the economy – often taking
the form of petty trading or fish processing.

27

2.2.2. Longliners

targeting squid in the region. Examples of this are
Chinese and Spanish vessels ‘going dark’ i.e. switching
off their AIS transmitters for large swathes of time,a behaviour associated with deliberate evasion ofmonitoring efforts.142

The majority of IUU fishing incidents involving
Chinese-flagged or owned industrial longline vessels
identified during the period of 2015-2019 occurredin areas beyond national jurisdiction (Figure 6). Just
under a third of all incidents (31%) occurred withinwaters governed by the WCPFC, with the high seas(in areas not covered by RFMOs) being the second
most common location (20%). The next three highest
regions were the EEZs of Tanzania (14%), Somalia (8%)
and the Galapagos Islands (5%).

From a broader perspective, it is of note that CDWF
vessels equipped to target squid maintain significant
operations in major squid fishing grounds not coveredby any regional fisheries management organisations or
arrangement. That is the case in the Southwest Atlantic
Ocean, but also in the Northwest Indian Ocean.143
To date, conservation and management measuresapplicable to high seas fishing grounds in these areas
continue to solely be in the hands of flag states. While
this situation may not qualify as “unregulated fishing”
as defined in the FAO International Plan of Action
to Prevent, Deter and Eliminate IUU Fishing, it does
raise serious concerns about the conditions in which
fishing activities are undertaken in the areas concerned;
particularly when considering the prevalence ofIUU fishing incidents involving Chinese-flagged orowned industrial squid jiggers in the EEZ of Argentina(bordering the high seas of the Southwest Atlantic
Ocean) and recent research highlighting the growing
importance of the Northwest Indian Ocean squid fisheryassociated with risk of illegal fishing activities.144

2.2.3. Squid jiggers
The majority of IUU fishing incidents involving
Chinese-flagged or owned industrial squid jigger
vessels identified during the period of 2015-2019
occurred within the EEZ of Argentina (61%), with thehigh seas under the jurisdiction of the SPRFMO second(16%) and the high seas third (6%) (Figure 7). The
largest number of instances occurred in the waters
surrounding South America, as the fertile squid fishinggrounds make the region appealing to DWFs.141 The
above findings support research conducted elsewherethat has identified suspected illicit behaviours by fleets

Figure 6: Location of IUU fishing incidents perpetrated by Chinese-flagged or owned longliners(2015-2019)145

28

WCPFC

26

High Seas

17

Tanzania

12

Somalia

7

Galapagos Isl. (Ecuador)

4

IOTC

4

Vanuatu3

New Zealand2

Philippines

2

Argentina

1

Australia

1

Benin

1

Cook Islands

1

French Polynesia

1Indonesia (Central)

1

Timor Leste1

Figure 7: Location of IUU fishing incidents perpetrated by Chinese-flagged or owned squid jiggers(2015-2019)146

Argentina

42

SPRFMO

11

High Seas

6

South Africa

5

Peru

2

SE Pacific2Indonesia (Central)

1

2.2.4. Purse Seiners
The majority of IUU fishing incidents involving Chinese-flagged or owned industrial purse seiners vessels
identified during the period of 2015-2019 occurred within the EEZ of Indonesia (50%), with the high seas second(15%) and the IOTC (10%) joint third with the EEZ of Somalia (Figure 8).
Figure 8: Location of IUU fishing incidents perpetrated by Chinese-flagged or owned purse seiners(2015-2019)147

Indonesia (Central)

29

10High Seas

3

IOTC

2

Somalia

2

Japan

1

Nauru

1

South Africa

1Section 3 – Nature of IUU fishing and human rights abusesby CDWF
3.1. Nature of IUU fishing by CDWF:
Overview
IUU fishing is a broad term, encompassing a range of
behaviours that vary depending on region, gear types,
fleets, and business models amongst other things. As
the findings of this report have shown above, the CDWF
is suspected of conducting IUU fishing operations at adisproportionately high rate – across much of the globe
both in the EEZs of coastal states and the high seas.
EJF’s analysis suggests that the most common offence
conducted by the CDWF is fishing without a licence/authorisation, with 237 instances constituting 42.7%of the total. Using prohibited gear types was thesecond most common unique offence with 64 counts
and 11.5% of the total. Fishing for prohibited species
was the next most frequent with 57 counts making
10.3% of the total. The full list of offences can be seen
below in Table 6.

A dolphin onboard a Chinese squid vessel. © EJF

The above findings on the nature of IUU fishingare consistent with information obtained throughinterviews conducted by EJF with Indonesian crew
onboard CDWF vessels. These found a high proportionof the 116 crew interviewed had seen some form of IUU
fishing. For example, 95% of those spoken to had seen
sharks being finned, 22% and 38% had seen dolphinsand false killer whales killed respectively, and 34%
reported seeing other protected species including seal
and turtles being caught and killed.

Table 6: Offences conducted by the CDWF
2015-2019148
Offencefishing without a licence/authorisation,
237 instances, 42.7% of the total
using prohibited gear types 64 counts,
11.5% of the totalfishing for prohibited species 57 counts,
10.3% of the total

Count Percentage
of total

Fishing without licence/authorisation

237

42.7

Other fisheries violation

181

32.6

Use of prohibited gear

64

11.5

Fishing for prohibited species

57

10.3

Violations relating to
documentation, identity,
markings and flaggings

50

9.0

Other (e.g. drugs)

39

7.0

Failure to report/declare catch

38

6.8

Shark finning

37

6.7

Fishing in IEZ/prohibited areas

18

3.2

Failure to report AIS/Vessel
Monitoring System (VMS)

17

3.1

Human rights abuses

16

2.9

Source: Coastal state governments, EJF findings, MARA IUUfishing notices, media/NGO reports, Spyglass30

3.2. Nature of IUU fishing by gear
3.2.1. Trawlers
The most common type of IUU fishing incident conducted by trawlers was unauthorised fishing (42 individual
offences149 representing 34% of the total), primarily fishing without a licence in coastal state waters. The illegal
discarding of catches accounted for 13% of the total, followed by gear-related infringements (use of illegal
mesh size, top-side chafers and obstruction of mesh) and area-related infringements (fishing in the IEZ or otherprohibited areas), which accounted for 13% and 7% of total individual offences, respectively.

Figure 9: Types of IUU fishing offences perpetrated by Chinese-flagged or owned trawlers (2015-2019)

3.2.2. Longliners
The most common type of IUU fishing incident conducted by longliners was shark finning (28 individual
offences150 representing 20% of the total). This was closely followed by the capture of protected species (19% of
individual offences), non-compliance with reporting requirements (19% of total) and unauthorised fishing (18%of individual offences).
Longline vessels were also found to have engaged in fraudulent activities (5% of individual offences), including useof illegal markings, under-reporting of gross register tonnage, and forgery of licences. Non-compliance with vessel
monitoring requirements (lack of functional VMS, tampering with vessel positions, and switching off AIS) andcatch reporting obligations (failure to maintain or complete a logbook) were also identified, accounting for 6% and
5% total individual offences, respectively.

31

Figure 10: Types of IUU fishing offences perpetrated by Chinese-flagged or owned longliners (2015-2019)

3.2.3. Squid jiggers
The most common type of IUU fishing incident conducted by squid jiggers was fishing in prohibited areas (46% of
the total individual offences). This was followed by fishing without authorisation (17% of individual offences) andfleeing/refusal to cooperate (10%). Some other noted offences by the fleet were unauthorised trans-shipment (9%)
and shark finning (6%).

Figure 11: Types of IUU fishing offences perpetrated by Chinese-flagged or owned squid jigging vessels(2015-2019)32

3.2.4. Purse seiners
The most common type of IUU fishing incident conducted by purse seiners was fraudulent activity (representing
55% of individual offences), followed by gear-related offences (18% of individual offences) and unauthorised
fishing (11% of individual offences).

Figure 12: Types of IUU fishing offences perpetrated by Chinese-flagged or owned purse seine vessels(2015-2019)

3.3. N ature of human rights abuses the US Customs and Border Protection (CBP) agency
banned all imports from Chinese firm Dalian Ocean
by CDWF
Fishing Co., Ltd. due to indications that human rights
abuses, particularly of migrant Indonesian workers,
was occuring on board their vessels.153 Case Study 4
details the infamous case of the Dalian Ocean FishingCo., Ltd. owned fishing vessel LONG XING 629 – fourof whom’s original crew died.

Human rights abuses have plagued global fisheries
for decades, with vulnerable crewmembers exposed toa litany of abuses ranging from insufficient food anddrink, to physical and verbal abuse, human trafficking,and, in extreme cases, murder.151 As an industry, it
represents the perfect storm for such crimes, given its
high reliance on migrant labour, the geographically
remote nature of its operations, the capacity ofvessels to remain at sea for years at a time, and thelack of sufficient global and national frameworks andinstitutions to identify and prevent them occurring.

Interviews conducted by EJF with Indonesian crew who
had worked for the CDWF between September 2020 andAugust 2021 uncovered a shockingly high frequencyof human right abuses. 116 crew from 88 vessels wereinterviewed, reporting a range of offences: physicalabuse, intimidation and threats, wage withholding anddeductions, debt bondage, abusive working and living
conditions, and excessive working overtime.154 Table 7
presents the proportion of interviewees who had
experienced each of the above.

As the CDWF comes under more scrutiny, thesystemic nature of human rights abuses on board
its vessels is becoming apparent. Given the extent
of its distant water operations and the highinstances of IUU fishing amongst this fleet, this ismaybe unsurprising – considering the inherently
intertwined nature of IUU fishing and human rights
abuses.152 This was exemplified in May 2021, when33Captain and crew onboard a Chinese trawler in Tema, Ghana. © EJF

Whilst a smaller sample set, findings from EJF’s investigation in Ghana found that Ghanaian crew on CDWF vessels
faced similar infringements on their human rights. All 10 crew interviewed had either personally experienced orwitnessed physical abuse, were forced to live in squalid conditions and eat food with very little nutritional value,and consume barely potable water resulting in sickness.155

Table 7: Human rights abuses experienced by Indonesian crew working on CDWF vessels between
September 2020 and August 2021
Human rights abuse

Number of crew

Percentage of total crew interviewed

Withheld wages and deductions

115

99.1%

Debt bondage and guarantee money, anddocuments confiscation

112

96.6%

Excessive overtime

103

88.8%

Abusive working and living conditions

99

85.3%

Intimidation and threats

81

69.8%

Physical abuse

67

57.8%

Source: EJF investigations

Due to a broader deficit of data available to quantify instances and types of human rights abuses in a similar fashion,
as done with IUU fishing incidents previously, this section of the report will instead present some high-profile
instances where egregious human rights abuses have been documented on board Chinese owned fishing vessels.

34

Case Study 4: Human rights abuses exposed on the Long Xing 629156
The case of the LONG XING 629 – a Chinese vessel operating in the Western Pacific – garnered extensive
attention from civil society, national governments and mainstream media. Four of the vessel’s original
crew members, all of Indonesian origin, passed away between December 2019 and March 2020 after
suffering symptoms including swelling and chest pain. The tragedy was a prolonged one, with one of thecrew dying on board the LONG XING 629, two after having been transferred to sister vessels, and one on
arrival at Busan, Korea. It is alleged that despite requesting medical care for months, the captain refused toreturn to port in order to access appropriate care.157
The appalling response of the captain to the poor health of his crew, and their untimely deaths, drewattention to the living and working conditions on board the vessel. Investigations by EJF and other civilsociety organisations uncovered a plethora of dreadful alleged human rights abuses. These included
average working days of 18 hours, one toilet shared between 22 of the Indonesian crew, confiscationof passports, deduction of wages, being forced to eat fish that was otherwise used as bait and drink
poorly treated salt water, as well as instances of physical assault by the Chinese crew. These abuses were
facilitated by a number of trans-shipments at sea, which meant the crew were kept at sea for 13 months.
Further investigation by EJF into the operations of this vessel evidenced the interlinkages between humanrights abuses and IUU fishing on the vessel.158 The illegal finning of sharks stands out as the vessel’s
predominant form of IUU fishing, which was also found to be prevalent on 11 sister vessels, indicating asystemic problem in the fleet. A wide-variety of shark species were caught, some of which are endangered,including Scalloped Hammerhead Sharks, Shortfin Mako Sharks and White Sharks.

Whale killing on a Chinese industrial fishing vessel. © EJF

35

It is commonplace for the CDWF to employ migrant
workers from poorer neighbouring countries in SouthEast Asia including Indonesia and the Philippines.
The countless and heart-wrenching accounts of theabuse of such migrant workers aboard Chinese vessels
vividly depicts the severity of the issue. For example,
two Indonesian crew working on a vessel reportedly
named LU QING YUAN YU 901 jumped overboard as
they were unable to stand the treatment and forced
labour occuring on the ship, but were fortunately
rescued by other fishers.159 Elsewhere, a Greenpeace
report from 2019 talks extensively about the abuseof Indonesian crew – including one who was forced
to drink water from an airconditioning unit andwas subject to physical abuse on board the Chinese
vessel HAN RONG 355.160 Most recently, in 2021
an Indonesian crew member tragically lost his life
trying to escape a Chinese-owned vessel upon which
egregious human rights abuses and IUU fishing werereported (see Case Study 5).

Mistreatment on board Chinese vessels is not confined
to migrant workers per se. EJF has also identified
human rights abuses of ‘local’ crews – i.e. nationals
of a coastal state where Chinese vessels are operating.
Such abuses have been identified in Ghana, where
national fisheries laws dictate that 75% of crew must be
Ghanaian nationals. In a recent report, EJF uncovered
shocking human rights violations on board Chineseowned trawlers operating in Ghanaian waters. In all
interviews conducted, crew members stated that they
had either witnessed or been a victim of physical abuse,
and were subjected to deplorable living conditions aswell as poor quality food and drink, and were working
without written contracts.161

Chinese trawlers at port in Dakar, Senegal. © EJF

36

Case Study 5: Routine abuse of migrant workers aboard the Liao Dong Yu fleet
in the Indian Ocean
Since September 2020, a fleet of Chinese flagged fishing vessels and a fish carrier vessel (including the
LIAO DONG YU 535, 571, 572, 575 and 577) were observed to be operating in the waters of Somalia. In June
2021, reports made to the fisher’s welfare organisation ‘Destructive Fishing Watch’ alerted them that the 13
Indonesian crewmembers working on the vessel had been stranded in Somalia since January 2021. Despite
their contracts having finished in December 2020, the crew were reportedly forced to continue working
and vessel operators refused to repatriate them.
As more information began to emerge, an increasingly grim picture was painted of the tragedies that
befell migrant workers on the vessels. In June 2021, one fisher was killed and one presumed killed aftera large wave hit the vessel, forcing open a heavy trawl door – killing one fisher on impact and throwing
another to sea. A further crew member lost his life in August 2021, as one of four fishers attempting to flee
the vessel for shore. Whilst three were found and brought back onto the vessel, one who could not swim
was lost at sea. Crew were eventually repatriated with the assistance of a range of local and internationalNGOs, including EJF.
The conditions on board the vessels provide some context as to why some crew find themselves willing torisk their life to reach shore. Reports from those on board indicate that they were subject to physical abuse
when they asked for information about repatriation, and should they refuse to work, they would be denied
breakfast for days as punishment. Some of the crew fell ill, reporting symptoms similar to those exhibitedby those suffering from beriberi disease or thiamine deficiency – with symptoms including difficulty
breathing and swollen legs, leaving some struggling to walk. Injury and sickness on the vessels was
unsurprising, given that crew were not provided sufficient safety equipment, were forced to drink unfilteredtap water and, if not willing to pay for vegetables, had to subside on a diet of porridge and anchovies.
As with the case of the LONG XING 629, aseries of suspected IUU fishing offences were
documented and reported by crew working on
board the fleet including: fishing without a valid
licence, fishing using prohibited gear, fishingin a restricted zone, fishing for protected or
endangered species, and conducting operationsin breach of the terms and conditions of the flagstate’s authority.
Species caught on board the vessels included
sharks, turtles and dolphins. Sharks were often
finned – a widely illegal and deeply inhumane
process in which sharks have their fins cut off
and then are often thrown back into the sea– a prolonged and painful death. Vulnerable
species such as leatherback turtles were also
documented on board, as well as the rare
megamouth shark.

Evidence of poor living conditions on a Chinese squid vessel. © EJF

37

Section 4 – Identity of main offenders
4.1. Overview
Many IUU fishing offenders have complex and opaque identities and relationships with business partners. Of the554 IUU fishing incidents analysed, 82 were conducted by fully or partially state owned entities, accounting foraround 15% of incidents analysed. However, some Chinese DWF companies set up joint ventures overseas which
participated in IUU fishing offences and could not be accounted for.162
Among the enterprise groups committing IUU fishing infringements, about 45% of them have a small fleet ofunder 20 vessels, while the other 45% are the ones with a certain commercial scale with a fleet of between 24-59
vessels. Only two enterprises have a large fleet of over 100 vessels (Table 8).
Vessels from each province have different likelihoods of committing IUU fishing offences. In fact, Liaoning only
has the fourth highest vessel number among all provinces, however, proportionally its registered vessels have thehighest likelihood of committing IUU fishing offences. This high ratio of offences to vessel numbers is also seen in
Shandong, Zhejiang, and Fujian provinces, in decreasing order. However, our analysis could not take into accountthe “ghost vessels” fishing without a port of registry or using stolen identities.
Vessels from the same company tend to commit similar types of IUU fishing offences. This could be related to theoperational strategy of a company or the collective decisions made by the captains on site. For instance, five vessels
from the company, Yantai Beijing Deep-Ocean Fishery, colluded with one another and fled from the inspection
request of the Argentine authorities in 2018. Subsequently, all five vessels were reported under an INTERPOL
purple notice upon the request from the Argentine authorities.163

Chinese industrial vessel in Montevideo, Uruguay. © EJF

38

Table 8: The top 20 enterprise groups with the highest recorded IUU fishing offences between 2015 and 2019
Conglomerate or company

IUU fishing
offences
2015-2019

Company
vesselState-owned

1

Pingtan Marine Enterprise (including Honglong)

25

188

N

2

China Wanxiang Holdings Co Ltd / Wanxiang Sannong
Group Co., Ltd

2245

Y (partial
interest)

3

Fuzhou Dongxinlong Ocean Fishing Co., Ltd.164

15

2

N

4

Dalian Jinmu Investment Co., Ltd.

13

37

N

5

Shandong Zhonglu Oceanic

13

24

Y

6

Qingdao Rongchang Ocean Fishery Co Ltd

12

10

N

7

China Agricultural Development Group Co., Ltd.

12

429

Y

8

Shandong State-owned Assets Investment Holding Co., Ltd.

11

10

Y

9

Dalian Lian Run Pelagic

10

24

N

10

Fujian Anfeng Ocean Fishery Co., Ltd.

10

10

N

11

Shandong Bodelong Group Co., Ltd.

10

28

N

12

Zhoushan Jiade International Fisheries Co Ltd

8

18

N

13

Changhai County Zhangzidao YiFeng Aquatic ProductCo., Ltd.

7

18

N

14

Dalian Meng Xin

7

31

N

15

Zhongguan Marine

6

26

N

16

Beijing Fisheries Co. Ltd

6

15

Y

17

Qingdao Changhai Ocean Fishing Co Ltd

6

6

N

18

Zhoushan Huali Ocean Fisheries165

6

1

N

19

Ningbo Wanhong Aquatic Products Co., Ltd.

5

26

N

20

Zhoushan National Pelagic Fishery Base Construction
Development Group Co., Ltd.

5

59

Y

Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media/NGO reports, Spyglass39

4.2. I dentity of main offenders:
By gearDalian Mengxin Ocean Fishery is reported to haveengaged in several IUU fishing offences and was the
subject of an investigation by China Dialogue Ocean in
2019.172 The main offences involving Dalian Mengxin's
vessels include dumping juvenile fish, using prohibited
gears, and illegal trans-shipment. MENG XIN 15, oneof the company's 31 trawling vessels, was also involvedin a case of a missing Ghanaian fishing observer.173
The company’s active fishing grounds are Ghana andSierra Leone. Dalian Mengxin is equally owned by
two shareholders: Dou Yongmeng and Lin Huimei.174
Yongmeng is also the supervisor and part-shareholder
of Dalian Mengyuan Trading Co along with Dou Wei.
Until at least 2019, Dalian Mengxin still actively shipped
squid and cuttlefish from Tema, Ghana, to China.175
Moreover, there is a business relationship between
Dalian Mengxin and Dalian Kaiyang World SeafoodCo.,Ltd.,176 which is the largest seafood distributor in
Dalian. There was also a separate but identically namedentity (Dalian Mengxin Ocean Fishery) in Hong Kong,which was established in 2017 and dissolved in 2019.
This entity was previously named Meredith Seafood
Trading and Shipping.177

4.2.1. Trawlers
The top five CDWF companies involved in IUU fishingincidents involving trawl vessels are set out in Table 9.
These Chinese vessels were mostly registered in
Shandong or Liaoning province. The IUU fishingcases from trawling vessels overwhelmingly occurredon the coast of West Africa. In early 2021, EJF had
already published a comprehensive and detailed
report on the Chinese-owned trawlers operating inWest Africa.166 In this section, we further dive into theidentity of the major Chinese companies conducting
IUU fishing infringements.
Two Shandong companies and one Liaoning company
were all charged with illegally discarding fish at sea.
Shandong Ocean Fishery Development Corporation,
which was associated with at least ten incidents during
the period 2015-2019, is majority owned by the Chinese
government.167 Several of the company’s vessels in
Ghana have been sanctioned for illegal activities thattook place between 2017 and 2019. The main offences –dumping fish, illegal trans-shipment and fishing in the
IEZ – were carried out by only five vessels, each one withmultiple offences. Although this company is relatively
small with only 10 registered trawlers, it is a subsidiaryof a large state-owned holding company, Shandong
State-owned Assets Investment Holding, which is also
the controlling shareholder of a leading DWF enterprisein Shandong, Shandong Zhonglu Oceanic Fisheries.168
Shandong Ocean Fishery Development Corporation
started to focus on the fishing ground off the coast of
Morocco in 2019 – they now have at least six vessels
operating at the location.169,170

Two other Liaoning companies were involved infraudulent cases and other types of IUU fishing
infringements. Zhangzidao in Dalian, Liaoning, isa fishing village with a long history in the seafoodindustry and is the home port for several DWF
companies registered in Liaoning. Dalian Ruitaifeng
Pelagic Fishery and the RUITAIFENG fleet (formerly
named Dalian Lianrun until 2019), has 30 trawler
vessels which fish mostly in West Africa in countries
such as Ghana and Guinea. Between 2015-2019, thecompany’s LIAN RUN fleet had several accounts ofIUU fishing activities including using illegal gear andmesh sizes, shark finning, and under-reported gross
tonnage, etc. Before 2015, the LIAN RUN fleet alreadyhad a history of gross tonnage and identity fraud.178

Rongcheng Marine Fishery belongs to the owners of
Shandong Bodelong Group (49%) which is involvedin the CDWF and real estate industry, and a fisherycompany called Rongcheng Derun Fishery (51%).
Rongcheng Marine Fishery mainly fishes in Ghana
and the Indian Ocean. There are 20 trawlers, 4 squid
jigging vessels, 2 purse seiners, and 2 reefers registeredunder the company’s name. The IUU fishing offencesfrom Rongcheng Marine Fishery were illegal discardingfish at sea and fishing in the IEZ. Currently, Shandong
Bodelong Group and the Rongcheng Derun Fishery are
seeking further collaboration with Argentina, looking
to increase the number of fishing vessels, expand thescale of investment, and develop onshore processing
facilities in Argentina.171

The IUU fishing offences from Changhai County
Zhangzidao Yifeng Aquatic Product were fishing
without authorisation, and tampering with vessel
position and markings. The company has 18 trawlers
and has been fishing in the waters of Guinea-Bissau
and Senegal. MARA ordered the Liaoning government
to sanction the four vessels which tampered with thepositioning system – the vessels’ fishing projects were
to be cancelled and the manager and captains of thevessels were to be blacklisted.179

40

Table 9: Top five Chinese DWF corporations involved in IUU fishing incidents by trawl vessels(2015-2019)
Company

Province

State-owned

No. of IUU fishingincidents

Location of IUU
fishing incidents

Shandong Ocean Fishery Development
Corporation

Shandong

Yes

10

Ghana

Rongcheng Marine Fishery Co. Ltd

Shandong

No

10

Ghana

Dalian Lianrun Pelagic Fishery Co. Ltd

Liaoning

No

9Ghana, Guinea

Dalian Mengxin Ocean Fishery Ltd

Liaoning

No

7

Ghana, Sierra Leone

Changhai County Zhangzidao YiFeng
Aquatic Product Co., Ltd.

Liaoning

No

6

Gambia, GuineaBissau

Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media/NGO reports, Spyglass

4.2.2. Longliners
The top 7 CDWF companies involved in IUU fishingincidents involving longline vessels are set out in Table
10 along with information on the incidents concerned.
Three out of the 7 companies were listed on the
Chinese or foreign stock market, one has made several
attempts on the listing, with another one currently inthe process of application. This probably underlinesthat the operation of tuna longline vessels is a capitalconcentrated business.

Shandong Zhonglu Fishery’s main type of offence
is also fleeing from authorities’ inspection. These
cases mostly occurred during the Sea Shepherd’sand Tanzanian authorities’ joint mission in 2018.
Afterwards, in the following fishing project approval
list for 2019-2020, the company applied for fishingprojects further into the Indian Ocean.
Dalian Ocean Fishing has the second most frequentIUU fishing incidents among longliners. Sharkfinning and targeting cetaceans are the main IUUfishing offences which occurred on the high seas in
the Indian Ocean and the Pacific Islands. Moreover,
several of the company’s vessels, especially thenotorious LONG XING 629, were involved in severe
human rights abuse cases. Consequently, the US
government has banned Dalian Ocean Fishing fromexporting seafood products to the US market sinceJune 2021 under forced labour violations.181

Zhejiang province had the highest number of IUU
fishing incidents conducted by its longliner fleet.
The China Wanxiang Holdings (Wanxiang Sannong)is the organisational group responsible for at least
two DWF companies that collectively are associatedwith at least 21 incidents on board 14 vessels during
the period 2015-2019. Offences by the two companies
occurred on the high seas, the jurisdiction of WCPFC,
and the EEZs of Somalia and Tanzania. The offences
include fleeing from authorities’ inspection, noncompliance (e.g., failed to provide trans-shipment
records to RFMOs), fishing without a licence, sharkfinning, and targeting cetaceans. Among them, halfof the vessels conducted multiple offences in different
time periods. As China switches focus to the PacificIslands, a secret deal between the governments ofChina and Kiribati has ensured the Chinese fishingcompanies like Zhejiang Ocean Family have an edgein tuna fishing in Kiribati’s EEZ.180

The IUU fishing cases which Pingtan Marine
Enterprise is associated with were shark finning andtransport. Four longliner vessels belonging to theenterprise’s subsidiaries and associates were involvedin the Galapagos shark poaching and transportingcase. Moreover, just a few months after the seizure
in August 2017, two of these vessels FU YUAN YU
7865 and FU YUAN YU 7866182 were approved forgovernment subsidies for vessel replacement andrenovation in November.183

41

Frozen tuna being unloaded at port in Montevideo, Uruguay. © EJF

Table 10: Top Chinese DWF corporations (groups) involved in IUU fishing incidents by longline vessels(2015-2019)
Company

Zhejiang Ocean FamilyCo., Ltd.

Group

Province

Stateowned

No. of IUU
fishing
incidents

Location of IUU
fishing incidents

15

WCPFC (40%), High seas
(26.7%), Tanzania (26.7%),
Somalia (6.7%)

6

WCPFC (100%)

China Wanxiang
Holdings Co Ltd/
Wanxiang Sannong
Group Co., Ltd

Zhejiang

Dalian Ocean FishingCo., Ltd.

Dalian Jinmu
Investment Co., Ltd.

Liaoning

No

13

Not reported (92.3%),
Benin (7.7%)

Shandong Zhonglu
Oceanic

Shandong Zhonglu
Oceanic

Shandong

Yes

10

Tanzania (88.9%), Highseas (11.1%)

4High seas (50%), Galapagos
Islands (Ecuador, 50%)

4Galapagos Islands(Ecuador, 50%), High seas(25%), WCPFC (25%)

6Somalia (100%)

Zhejiang Ocean
Fisheries Group Co Ltd/
Zhoushan Pacific Tuna
Pelagic Fishery Co., Ltd.

Fujian Pingtan County
Ocean Fishing Group
Co., Ltd.
Fuzhou Honglong Ocean
Fishing Company Ltd.
Qingdao Changhai
Ocean Fishing Co., Ltd.

Pingtan Marine
Enterprise

Fujian

Not
known

No

Qingdao Changhai
Shandong
Ocean Fishing Co Ltd

No

Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media/NGO reports, Spyglass42

4.2.3. Squid jiggers
The top eight CDWF companies involved in IUU fishing incidents with squid jigger vessels are set out in Table 11
along with information on the incidents concerned. All the vessels from Zhoushan belong to the same squid fishingcooperation. Almost half of the IUU fishing cases from squid jigging vessels are unauthorised entry into a country’s
EEZ, specifically into the Argentinian EEZ. In comparison to the high occurrence of shark finning by longliners,
trawlers, and purse seiners, only 7% of the squid jiggers were involved in shark finning and transport. This underlines
the correlations between types of vessel and the types of IUU fishing infringements.
The Zhejiang provincial government fined vessels entering the Argentinian EEZ during the 2016 spring fishingseason. These sanctions were the official response to a severe IUU fishing confrontation that took place earlier inMarch 2016, when the Argentinian coast guard sank a Chinese fishing vessel, LU YAN YUAN YU 010, after sending
several warnings ordering it to stop fishing inside the Argentinian EEZ.184 This high-profile case subsequently
pressed the Chinese government to sanction other vessels entering the Argentinian EEZ during that period of time.
This was the first but also the only time that the provincial government published the sanction results after receiving
the instructions from MARA. Captains were fined US$ 1,560 if they entered the EEZ once or twice, and US$ 3,125 ifthey entered the EEZ more than twice. The number of times these vessels entered Argentinian EEZ ranged from once
to 19 times, with a median of three times.

Table 11: Top Chinese DWF corporations involved in IUU fishing incidents by squid jigging vessels(2015-2019)
CompanyGroup

Province

Zhoushan Jiade
International Fisheries
Co LtdZhoushan Jiade International
Zhejiang
Fisheries Co Ltd

Yantai Beijing DeepOcean Fishery Company

Beijing Fisheries Co. Ltd

Zhoushan Huali Ocean
Fisheries

Not known

Zhoushan Mingxiang
Marine Fishery Co., Ltd.

Ningbo Wanhong Aquatic
Products Co., Ltd.

Stateowned

No. of IUU
fishing
incidents

Location of IUU
fishing incidents

8

Argentina

Yes

6

Argentina

Zhejiang

Not
known

6

Argentina, Indonesia

Zhejiang

No

5

Argentina, SPRFMO

China Aquatic Products
Zhoushan Marine
Fisheries Corp

China Agricultural
Zhejiang
Development Group Co., Ltd.

Yes

4

Argentina

Zhoushan Putuo DeepSea Fishery Corp

Zhoushan National Pelagic
Fishery Base Construction
Zhejiang
Development Group Co., Ltd.

Yes

4

SPRFMO

Beijing

No

Zhoushan Run Da Ocean
Not known
Fisheries Co Ltd

Zhejiang

No

4

Argentina

Zhoushan Shunhang
Ocean Fisheries Co Ltd

Zhejiang

No

4

Argentina

Not known

Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media and NGO reports, Spyglass43

4.2.4. Purse seiners
The top three CDWF companies involved in IUU fishing incidents involving purse seine vessels are set out in Table 12
along with information on the incidents concerned. The Qingdao Rongchang Ocean Fishery Co., Ltd tops this list,
associated with at least 11 incidents during the period 2015-2019. A privately owned corporation, it is reported tohave undertaken IUU fishing in South Africa, with other locations not reported. Their main offence – changing thefishing method from purse seine to trawling – was confirmed to be true according to MARA’s initial investigation.185
However, MARA’s final decision was not to further pursue the sanctioning due to insufficient evidence on thecompany’s second charge – smuggling 3,000 tonnes of illegally caught fish back to China.186
Fuzhou Dongxinlong Ocean Fishing and Fujian Zhengguan Fishery Development, the second and third on the
IUU fishing offences ranking for purse seiners, are connected through illegal activities and transferring of vessels.
Eight vessels from Fuzhou Dongxinlong Ocean Fishing and six vessels from Fujian Zhenguan Fishery Development
were collectively investigated by MARA for their involvement in several fraud cases including forging vessel
tonnage information, illegally changing fishing gear, tampering with AIS, etc.187 Moreover, Fuzhou Dongxinlong
subsequently sold six of their vessels to Fujian Zhengguan after the qualification of the former company wassuspended by MARA. These six vessels were involved in illegal fishing using prohibited drift nets in the north of
the Indian Ocean.188

Table 12: Top Chinese DWF corporations involved in IUU fishing incidents by purse seine vessels(2015-2019)
CompanyGroup

Qingdao Rongchang
Ocean Fishery Co., Ltd.
Fuzhou Dongxinlong
Ocean Fishing Co., Ltd.

Stateowned

No. of IUU
fishing incidents

Qingdao Rongchang
Zhejiang
Ocean Fishery Co., Ltd.

No

11South Africa,
not reported

Not known

FujianNo

7

Not reported

FujianNo

6

Not reported

Fujian Zhengguan Fishery
Zhongguan Marine
Development Co., Ltd.

Province

Source: Coastal state governments, EJF findings, MARA IUU fishing notices, media/NGO reports, Spyglass

44

Location of IUU
fishing incidents

Conclusions
Government of the People's Republic of China, and its
international partners, to address the often unsustainable
manner in which the CDWF operates. This will preventthe continued abuse of basic human rights, and safeguard
the livelihoods and food security of the communities thatare dependent on the ocean. Whilst this may initially be
associated with some costs, ultimately, no-one benefits
from depleted fish populations, and addressing theexistential threats to many ocean ecosystems will bringwith it financial benefits.

The rapid growth of the CDWF over the past three
decades has unquestionably put additional pressure
on marine ecosystems and all of those who rely on
them. Whilst there are numerous nations and actors
who have, either currently or historically, contributed
significantly to the observed decline of many fish
populations – the size of the CDWF, and of China asa market state, warrants attention. The need for thisscrutiny is made more urgent by the high instancesof IUU fishing amongst the Chinese fleet, as well as
its presence in vulnerable coastal regions where fish
populations are reportedly close to collapse.

Below we make a series of recommendations to boththe Government of the People's Republic of China andother relevant states. Implementing these will increasetransparency around the operations of the CDWF, andallow authorities to hold those responsible for IUU
fishing and human rights abuses to account.

This report has provided a timely addition to existing
literature that has sought to map the size, scale andbehaviours of the CDWF, particularly through its analysis
of novel data sources, and analysis not only at fleet
level, but also by gear type. The onus now sits with the

Frozen tuna being unloaded at port in Montevideo, Uruguay. © EJF

45

Recommendations
To the Government of thePeople's Republic of China• Ensure that government support in the form ofsubsidies, loans and other funds are not available tocompanies with a history of IUU fishing infringements,
in the context of eliminating harmful subsidies.

Alignment with best practises andcooperation with international partners• Establish a clearer protocol and chain of responsibility
for the investigation of IUU fishing offences, whichshould involve the local prefectural fishery law
enforcement in order to increase efficiency.

• Ensure the information on Chinese DWF vessels
uploaded to the FAO Global Record of Fishing Vessels,
Refrigerated Transport Vessels and Supply Vessels by
China is comprehensive and up to date.

• Continue to update and publish information about
fisheries-related offences and sanctions by distantwater fishing vessels to ensure the information
published is comprehensive, credible and accessible.

• Cooperate with the relevant foreign governments
to clarify Chinese ‘hidden’ ownership in their fishingsectors so as to enforce the relevant legal instruments.

Sustainability and transparency• Mandate International Maritime Organisation (IMO)
numbers as a prerequisite for approval of fishingvessels to operate overseas (or equivalent Unique Vessel
Identifiers (UVI) where the vessel is not eligible underthe IMO Ship Identification Number Scheme).

• Establish clear guiding principles and requirements
for fishing agreements (both those involving the
Chinese state and private companies) to ensure DWF
operations are transparent, legal and sustainable.
Some examples of pre-existing principles which would
be applicable and beneficial are the EJF ‘10 Principles
for Global Transparency’, and the ‘10 Priorities for
the Future of Sustainable Fisheries Partnership
Agreements’ devised by NGOs, Birdlife, The Coalition
for Fair Fisheries Agreement (CFFA) and WWF and their
African partners.189• Ratify and implement the International Labour
Organisation (ILO) Work in Fishing Convention C188
to address issues around labour abuses. Further
protections for workers on board vessels could include
the creation of a specific offence for the use of forced
or bonded labour by operators and the requirementof mandatory crew lists for DWF vessels. In addition,
ratification and implementation of the 2012 Cape
Town Agreement on Fishing Vessel Safety and of theInternational Convention on Standards of Training,
Certification and Watchkeeping for Fishing Vessel
Personnel (STCW-F), 1995 is recommended.

• Establish a cap on the capacity of the CDWF, in theform of overall engine power and gross tonnage for
specified gear types – as opposed to the current cap thatexists on the number of vessels.
• Reform the system for reviewing and approving
offshore fishery projects to include specific criteria toeffectively address abusive reflagging by the CDWF,
including: a requirement for operators to provide
information on vessel activities conducted under theflags of third countries (data on catches, fishing effort,
IUU fishing infringements) and for MARA to conductdetailed verifications of vessel activities conductedunder flags with known compliance issues.

Sanctions• Update the national law framework, if necessary,to ensure that Chinese nationals or any natural or
legal persons subject to China’s jurisdiction, who
are responsible for, benefiting from, supporting or
engaging in IUU fishing activities by fishing vessels
flying the flag of foreign countries (e.g. as operators,
effective beneficiaries, owners, logistics and service
providers, including insurance providers and otherfinancial service providers) can be prosecuted andsubject to deterrent sanctions.

• Mandate the publication of information on approved
DWF projects, including the period of projects andvessel details (e.g., name, beneficial owner, flag, UVI,
gear type, tonnage, allocated fishing opportunities).
Information should be available in a publicly accessible
and searchable database.

46

Montevideo port, Uruguay. © EJF• Improve catch data reporting to the FAO, ensuringthat information on species and fishing areas of the
CDWF is reported in a comprehensive way, irrespectiveof the final market destination of the products.

• Ensure that agencies responsible for flagging vessels
and fisheries management work in close cooperationand that fisheries managers have substantive input on
decisions on whether or not to flag a fishing vessel.

• Clarify the responsibilities for vessel monitoring andensure routine, proactive monitoring of VMS data andfollow up on suspected infringements.

• Ensure that fisheries authorities and ship registration
authorities from the former, other relevant states –including China – and the applicant flag state cooperate
and exchange vessel information before it is granted
entrance into the fleet. Refrain from issuing deletion
certificates to vessels which have failed to settle allfines and liabilities. Applicant flag states should refuse
applications of such vessels.

• Require mandatory AIS to significantly improvetransparency and coverage of fleet activities.
• Rapidly phase out all subsidies to the CDWF ensuring
a complete cessation of harmful subsidies no later thanDecember 2023.

• Scrutinise vessels with a history of flag-hopping tocombat abusive reflagging.
• Publish online lists of vessels registered to their flagand make the relevant information available throughthe FAO Global Record of Fishing Vessels, Refrigerated
Transport Vessels and Supply Vessels, mandating IMO
numbers for all eligible vessels and national unique
vessel identifiers for all other vessels.

To states that act as local flagsof the CDWF
• Require from all registered vessels, and as part of
all applications for entering the fleet register, details
on ownership arrangements and records on thedestination of profits from fishing activities. Unlessthere can be a clear assurance that a vessel’s beneficial
owner can be identified and held to account if needed,
the state should remove the vessel from their registryor refuse registration.

• Ensure all suspected fisheries infringements
by foreign-owned vessels, including those of the
CDWF flying the local flag, are subject to thoroughinvestigation, and that deterrent sanctions are imposed
where violations are confirmed, in accordance withminimum sanctions in the national law and regardlessof whether cases are settled in or out of court.

• Carry out background checks on any person
or company forming a new, or taking over anexisting, corporate entity and ensure that the stateis immediately notified of any proposed change toexisting ownership arrangements.

47

• Publish up-to-date information concerning fisheries
offences and sanctions by DWF vessels ensuring thatthe information published is comprehensive, credible
and accessible.

To coastal states• Ensure all suspected fisheries infringements
by vessels of the CDWF are subject to thoroughinvestigation, and that deterrent sanctions are imposed
where violations are confirmed, in accordance withminimum sanctions in the national law and regardlessof whether cases are settled in or out of court.

• Where relevant, clarify the role and responsibilities
of nationals acting as local representatives for foreign
entities in order to allow them access to EEZs, if
necessary developing regulatory instruments.
• Support progress in relation to regional cooperationand information-sharing on fishing activities throughthe relevant regional fishery bodies as well as with thepertinent national authorities and international bodies.

• Ensure that the number of fishing licences issued,
including to the CDWF, is sustainable in line with best
available scientific advice and MCS capacity.
• Ensure through legislation, monitoring, andenforcement, that IEZs strictly prohibit any and allindustrial activities, and, where necessary, expand
them to accurately represent the fishing grounds ofsmall scale fishers, accounting for the fact that this willcontinue to evolve in the face of climate change anddepleted fish populations.

• Undertake extensive studies of coastal livelihoods
to develop a nuanced understanding of the multiple
and interacting vulnerabilities that communities
are facing with a view to reduce precarity and devise
alternative livelihood options where necessary.
Ensure that such studies are conducted in a truly
participatory manner, making every effort to be
inclusive of marginalised groups within communities,
including women and the elderly.

• Phase out the use of industrial bottom trawling gear
given its widely-acknowledged negative ecologicalimpacts in inshore areas, so as to preserve vital
ecosystems and the biodiversity that inhabits them.

• Develop mechanisms through which crew members
and fisheries observers who are employed on
DWF vessels can safely and anonymously provide
information on IUU fishing and human rights abuses
that occur on board vessels. This mechanism shouldtake steps to tackle the incentives and drivers ofcorruption and failure to report such infractions,
including bribery, physical and verbal abuse of crew
and observers, and the withholding of wages.

• Adopt minimum transparency requirements forvessels operating within their EEZ, including the
publication of complete, updated and accessible
information on authorisations and beneficial
ownership, and requiring all eligible vessels granted
access to coastal waters have an IMO number.
• Conduct thorough background checks on vessels
requesting to fish in coastal waters, to ensure thatvessels whose beneficial owners are linked to IUUfishing are refused authorisation.

Small-scale fishing community, Ghana. © EJF

48

To port states

To key market states• Ratify and effectively implement the FAO Agreement
on Port State Measures, and, similarly and where relevant,effectively implement conservation and management
measures on port state measures adopted by RFMOs.

• Adopt import control mechanisms or, where
they exist, reinforce them and strive to align themto remove loopholes, provide clarity, and enable
information exchange, legal trade facilitation andinteroperability.190,191• In particular, and in determining which vessels to
inspect, increase scrutiny of companies identified inthis report as having possibly been associated with IUUfishing activities and/or human rights abuses.

• Increase scrutiny over imports of fisheries products
originating from vessels suspected of IUU fishing or
human rights abuses through standardised checks,
verifications and inspection procedures in accordancewith risk criteria.

• When sufficient proof that a CDWF vessel seeking
entry into a port has engaged in IUU fishing or related
offences and/or a port state has reasonable grounds
to believe that the vessel seeking entry has engaged
in such activities, port states should deny that vessel
port entry or allow entry exclusively for the purpose of
inspecting it and taking other appropriate actions inpreventing, deterring and eliminating IUU fishing andrelated offences in support of such fishing.

• In this context, verifications should be focused inpriority towards fisheries products stemming fromvessels and companies identified in this report as
having possibly been associated with IUU fishingactivities, human rights abuses, or both.
• When there is documented evidence of noncompliance with applicable laws and management
measures, close their markets to the products inquestion, and notify the flag state as well as, whereappropriate, other relevant countries than the flag state.

• Should such a vessel be found in a port, deny it theuse of the port for landing, trans-shipping, packaging,and processing of fish and for other port services
including, inter alia, refuelling and resupplying,
maintenance and drydocking.

• Improve routine and timely information sharing,
including on rejected consignments, which can allow
authorities to prevent trade diversion and restrict
market access to unscrupulous actors, with anemphasis on beneficial owners.

• Notwithstanding the above, a port state shall notdeny a vessel the entry to port for reasons of force
majeure or for the purpose of rendering assistance topersons in danger or distress. Similarly, a port stateshall not deny a vessel the use of port services essential
to the safety and health of the crew, provided theseneeds are duly proven.

• Increase coordination of bilateral cooperation
mechanisms, trade-based measures and on global
fisheries transparency policies, including in RFMOs,
so as to leverage market power to push China
to achieve the necessary reforms of its fisheries
governance framework through import requirements.
• In this context, align approaches to addressing
IUU fishing and human rights abuses in the CDWF
including taking actions that pressure China to makepublic, inter alia, China’s blacklist of IUU fishing
offenders, and the list of authorised CDWF and of thecountry’s fisheries agreements.
• Provide support to coastal states with a highpresence of the CDWF to increase their capacity
to fight IUU fishing and bring about fundamental
reforms of their fisheries policies.

Aerial view of saiko canoes landing fish at Elmina port, Ghana. © EJF

49

Appendix 1: O ffshore fishery projects covering specific EEZs for which information was
published and could be retrieved in 2019 and 2020

EEZContinent

Percentage of the total number of vessels
covered by projects related to specific EEZs

Mauritania

Africa29.9%

Myanmar

Asia

9.3%

Guinea-Bissau

Africa8.6%

SenegalAfrica

6.7%

MoroccoAfrica5.8%

GuineaAfrica5.3%

Sierra Leone

Africa4.1%

Madagascar

Africa3.1%

Malaysia

Asia

3.1%

Iran

Asia

3.0%

Gabon

Africa2.6%

Mozambique

Africa

2.6%

Argentina

South America

1.6%

Ghana

Africa

1.6%

India

Asia

1.5%

Kenya

Africa

1.5%

Pakistan

Asia

1.5%

Somalia (Puntland)

Africa1.5%

AngolaAfrica

1.2%

Oman

Asia

1.2%

The Gambia

Africa1.2%

Côte d’Ivoire

Africa1.0%

Liberia

Africa0.7%

Cameroon

Africa0.4%

Tanzania

Africa0.2%

UruguaySouth America

0.2%

Congo (Rep)

Africa0.1%

RussiaAsia

0.1%South Africa

Africa0.1%

50Appendix 2: Alleged incursions by industrial trawlers into the Ghanaian IEZ (2018-2021)192
Year

VesselStatusDate of occurrence

SourceOutcome2021

LONG XIANG 609

Suspected

1-2.5.21

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2021

JIN HAI 606

Suspected

6.3.21

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2021

LU RONG YUAN YU 916

Suspected

6-7.3.21

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2021

LONG XIANG 609

Suspected

24.11.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2021

LONG XIANG 602

Suspected

22-24.11.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2021

JIN HAI 605

Suspected

2-9.11.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LU RONG YUAN YU 930

Suspected

30.8.20-3.9.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LU RONG YUAN YU 917

Suspected

31.8.20-2.9.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LONG XIANG 606

Suspected

1-8.8.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LONG XIANG 606

Suspected

11-17.7.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

JIN HAI 605

Suspected

28-31.5.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

MENG XIN 14

Suspected

9-23.4.20 &14-15.7.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LONG XIANG 606

Suspected

April-July 2020

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2020

LONG XIANG 606

Suspected

24-26.3.20

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2018

LU RONG YUAN YU 920

Suspected

08.06.18

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

2018

LONG XIANG 606

Suspected

14.12.18

AIS (EJF)

Reported to FisheriesCommission. Outcome notreported.

51

Endnotes
1 Examples of reports that discuss the scale and scope of the CDWF
are: ODI. (2020). China’s distant-water fishing fleet, scale, impact andgovernance. Available at: https://cdn.odi.org/media/documents/chinesedistantwaterfishing_web.pdf and STIMSON. (2019). Shining alight: the need for transparency across distant water fishing. Available at:https://www.stimson.org/wp-content/files/file-attachments/Stimson%20
Distant%20Water%20Fishing%20Report.pdf.
2 See for example: Sea Shepherd. (2019). Sea Shepherd assists Liberian
Coast Guard in arrest of cargo vessel on suspicion of identity fraud and IUUfishing. Available at: https://www.seashepherdglobal.org/latest-news/seashepherd-assists-liberian-coast-guard-in-arres/ and The Guardian. (2020).
‘Hold on, brother’: the final days of the doomed crew on the Long Xing 629.
Available at: https://www.theguardian.com/environment/2020/jul/07/
hold-on-brother-final-days-of-doomed-crew-on-chinese-shark-finning-boat
3 EJF. (2020). EJF’s Charter for Transparency. Bringing the fisheries sector
out of the shadows. How best to implement principles three and four of theCharter for Transparency. Available at: https://ejfoundation.org/resources/
downloads/Report_Principles-three-four-final.pdf.
4 EJF. (2018). China’s hidden fleet in West Africa: A spotlight on illegal
practices within Ghana’s industrial trawl sector. Available at: https://ejfoundation.org/reports/chinas-hidden-fleet-in-west-africa-a-spotlight-onillegal-practices-within-ghanas-industrial-trawl-sector.
5 Cohen, P., Allison, E., Andrew, N., Cinner, J. et al. Securing a just spacefor small-scale fisheries in the Blue Economy. Frontiers in Marine Science. 6.
(171). 1-8.
6 Belhabib, D. (2018). The Criminal Record of Fisheries Vessels:Information
displayed on the Spyglass.fish platform, available at: https://spyglass.fish/
7 Including Russia.
8 Convention on Biological Diversity. (2018). People depend on marine andcoastal biodiversity for their livelihood. Available at: https://www.cbd.int/
article/food-2018-11-21-09-29-49
9 FAO. (2020). The State of World Fisheries and Aquaculture 2020,
Sustainability in Action. Rome.
10 Examples of reports that discuss the scale and scope of the CDWF
are: ODI. (2020). China’s distant-water fishing fleet, scale, impact andgovernance. Available at: https://cdn.odi.org/media/documents/chinesedistantwaterfishing_web.pdf and STIMSON. (2019). Shining alight: the need for transparency across distant water fishing. Available at:https://www.stimson.org/wp-content/files/file-attachments/Stimson%20
Distant%20Water%20Fishing%20Report.pdf.
11 FAO. (2020). The State of World Fisheries and Aquaculture 2020,
Sustainability in Action. Rome.
12 Vessels within the CDWF are allegedly heavily involved in illegal fishingpractices and fisheries related crimes (reference to major news headlines,
ODI report, GP report in WA, Oceana in Galapagos and IUU fishing index)
13	​​Mallory, T.G. (2013). China’s distant water fishing industry: evolving
policies and implications. Marine Policy, 38, 99–108.
14 Pauly, D. et al. (2013). China’s distant-water fisheries in the 21st century.
Fish and Fisheries, 15, 474–488.
15 Oceana. (2021). China’s Fisheries Subsidies Propel Distant-Water Fleet.
Available at: https://oceana.org/sites/default/files/994812/ChinaSubsidies_
ResearchSummary_Final.pdf.
16 Sumaila, U.R et al. (2019). Updated estimates and analysis of global
fisheries subsidies. Marine Policy. 109, 103695.
17 Oceana. (2021). Assessing the spatial burden of harmful fisheries
subsidies. Available at: https://oceana.org/wp-content/uploads/sites/18/
OceanaDWF_FinalReport.
18 Oceana. (2021). China’s Fisheries Subsidies Propel Distant-Water Fleet.
Available at: https://oceana.org/sites/default/files/994812/ChinaSubsidies_
ResearchSummary_Final.pdf.
19 STIMSON. (2019). Shining a light: the need for transparency acrossdistant water fishing. Available at: https://www.stimson.org/wp-content/
files/file-attachments/Stimson%20Distant%20Water%20Fishing%20
Report.pdf.
20 ODI. (2020). China’s distant-water fishing fleet: Scale, impact andgovernance. Available at: https://cdn.odi.org/media/documents/chinesedistantwaterfishing_web.pdf.
21 Belhabib, D. (2018). The Criminal Record of Fisheries
Vessels:Information displayed on the Spyglass.fish platform, available at:https://spyglass.fish/
22 It is noted that the term IUU fishing “incident” is used in this study.
A single IUU fishing incident may be associated with multiple separate
offences, e.g., fishing without a licence, document forgery and labour
abuses. An IUU fishing incident is typically characterised by the arrest ofa vessel on a specified date and subsequent investigation into the offences
identified.
23 State Council. (2019). Regulations of the People’s Republic of China
on Disclosure of Government Information (中华人民共和国政府信息公
开条例. Available at: http://www.gov.cn/zhengce/content/2019-04/15/
content_5382991.htm.
24 Ministry of Agriculture and Rural Affairs. (2017). Notice of the General
Office of the Ministry of Agriculture on Printing and Distributing the 2017
Work Plan for Overseas Inspection of Ocean Fishing Vessels and Overseas
Examination and Assessment of Ocean Fishing Crews (农业部办公厅关于印发2017年度远洋渔船境外检验和远洋渔业船员境外考试考核工作计划的通知). Available at: http://www.moa.gov.cn/gk/tzgg_1/tfw/201701/t20170117_5440615.htm.
25 Ministry of Agriculture and Rural Affairs. (2020). Order of the Ministryof Agriculture and Rural Affairs of the People’s Republic of China No. 2(2020) (中华人民共和国农业农村部令2020年 第2号). Available at:

http://www.moa.gov.cn/gk/tzgg_1/bl/202003/t20200310_6338553.htm.
26 For 2019, EJF could retrieve five notices of approved offshore fisheryprojects from the website of MARA (from the fourth “batch” to the eighth).
For 2020, seven notices could be retrieved (from the first batch to the eighth,
minus the second one).
27 EJF. (2020). EJF’s Charter for Transparency. Bringing the fisheries sector
out of the shadows. How best to implement principles three and four of theCharter for Transparency. Available at: https://ejfoundation.org/resources/
downloads/Report_Principles-three-four-final.pdf.
28 For 2018, EJF could retrieve two MARA IUU fishing notices publishedon 20 March and 20 June 2018. For 2019, three notices could be retrieved(published on 1 August, 23 September, and 29 October 2019). For 2020, one
notice published on 9 January 2020 was retrieved. These notices were titled“Notice of Illegal Issues and Handling Opinions of Some Distant Water
Fishing Enterprises and Fishing Vessels”
29 In some instances, the initial notices and the final sanctioning decisions
would be published in separate notices.
30 Ministry of Agriculture and Rural Affairs. (2021). Agriculture, Fishing
Vessel and Port notice 2021 No. 7, Notice on the Request for Confirmationof Data to be Cleared for Distant Water Fishing Vessels. Available at: http://zjjcmspublic.oss-cn-hangzhou-zwynet-d01-a.internet.cloud.zj.gov.cn/jcms_
files/jcms1/web2801/site/attach/0/745c8a2e0bba45ff93076e9b9f16abe0.pdf
31 Vessels replacement (“更新改/建造”) is to substitute an old vessel with a
newly built or purchased one using the same Certificate of Configuration of
Fishing Vessels, Nets and Gears. This system works similar to a vessel quota.
32 More details of the database, including its sources and limitations can befound here: https://spyglass.fish/about.
33 International Seafood Sustainability Foundation. (n.d.). Distant water
fishing nations [DWFNs]. Available at: https://iss-foundation.org/glossary/
distant-water-fishing-nations/.
34 Oceana. (2013). Ask Dr. Pauly: What are distant-water fishing fleets, andhow do they affect overfishing? Available at: https://usa.oceana.org/blog/
ask-dr-pauly-what-are-distant-water-fishing-fleets-and-how-do-they-affectoverfishing/.
35 Ministry of Agriculture and Rural Affairs. (2020). Order of the Ministryof Agriculture and Rural Affairs of the People’s Republic of China No. 2(2020) (中华人民共和国农业农村部令2020年 第2号). Available at:
http://www.moa.gov.cn/gk/tzgg_1/bl/202003/t20200310_6338553.htm.
36 Given the Chinese government’s definition of its DWF, data is unavailable
for offences occurring within this region. Should data have been available, it
is likely that these activities would radically change the panorama drawn inthis section.
37 Ministry of Agriculture and Rural Affairs. (2020). Order of the Ministryof Agriculture and Rural Affairs of the People’s Republic of China No. 2(2020) (中华人民共和国农业农村部令2020年 第2号). Available at:
http://www.moa.gov.cn/gk/tzgg_1/bl/202003/t20200310_6338553.htm.
38 EJF. (2018). China’s hidden fleet in West Africa: A spotlight on illegal
practices within Ghana’s industrial trawl sector. Available at: https://ejfoundation.org/reports/chinas-hidden-fleet-in-west-africa-a-spotlight-onillegal-practices-within-ghanas-industrial-trawl-sector.
39 Fisheries Transparency Index. (2021). Seychelles launches 1st FiTI report
ever! Available at: https://www.fiti.global/seychelles-launches-1st-fitireport-ever
40 EJF. (2021). At what cost? How Ghana is losing out in fishingarrangements with China’s distant water fleet. Available at: https://ejfoundation.org/reports/at-what-cost-how-ghana-is-losing-out-in-fishingarrangements-with-chinas-distant-water-fleet.
41 FAO. (2011). Review of the state of world marine fishery resources. FAO
fisheries and aquaculture technical paper. No. 569. Rome.
42 FAO. (2020). The State of World Fisheries and Aquaculture 2020.
Sustainability in action. Rome
43 Bureau of Statistics (统计局). (2020). China Fishery Statistical Yearbook(中国渔业统计年鉴2020). Available at: https://www.yearbookchina.com/
naviBooklist-n3020013079-1.html.
44 Ministry of Agriculture and Rural Affairs. (2020). White Paper on
China’s Offshore Fisheries Performance (2020) (中国远洋渔业履约白皮书(2020)). Available at: http://www.yyj.moa.gov.cn/gzdt/202011/
t20201120_6356632.htm.
45 FAO. (2001). Sea Farming and Sea Ranching in China. Available at:
http://www.fao.org/3/y2257e/y2257e04.htm#bm04.1.3.
46 Mallory, T.G. (2013). China’s distant water fishing industry: evolving
policies and implications. Marine Policy, 38, 99–108.
47 Bureau of Statistics (统计局). (2020). China Fishery Statistical Yearbook(中国渔业统计年鉴2020). Available at: https://www.yearbookchina.com/
naviBooklist-n3020013079-1.html.
48 Ministry of Agriculture and Rural Affairs. (2021). “Thirteenth FiveYear” Fishery Highlights (“十三五” 渔业亮点连载 | 我国远洋渔业 “十三五” 发展亮点纷呈). Available at: http://www.yyj.moa.gov.cn/gzdt/202101/
t20210104_6359366.htm.
49 Excluding Hong Kong and Macao
50 FAO. (2020). The State of World Fisheries and Aquaculture 2020.
Sustainability in action. Rome.
51 Bureau of Statistics (统计局). (2020). China Fishery Statistical Yearbook(中国渔业统计年鉴2020). Available at: https://www.yearbookchina.com/
naviBooklist-n3020013079-1.html.
52 Ministry of Agriculture and Rural Affairs. (2021). “Thirteenth FiveYear” National Offshore Fisheries Development Plan (“十三五”全国远
洋渔业发展规划). Available at: http://www.moa.gov.cn/gk/ghjh_1/201712/
t20171227_6128624.htm.

52

53 For instance, Fuzhou’s goal is to increase the number of vessels to 600
by 2020. Bureau of Ocean and Fisheries of Fuzhou city. (2015). Policy
Interpretation of the “Ten Measures to Further Accelerate the Developmentof Distant Water Fishing. Available at: http://www.fuzhou.gov.cn/zcjd/
bs/201711/t20171127_1894422.htm.
54 Ministry of Finance, Ministry of Agriculture and Rural Affairs. (2015)
Adjustment of fuel subsidy policy for domestic fisheries fishing andaquaculture to promote sustainable and healthy development of fisheries.
Available at: http://www.gov.cn/xinwen/2015-07/13/content_2895987.htm.
55 For instance, Shandong Bureau of Ocean and Fisheries. (2018). Action
plan for building a strong marine province in Shandong. Available at:https://www.waizi.org.cn/policy/60046.html; Fujian Bureau of Ocean
and Fisheries. (2021). Fujian’s RMB 1 trillion investment for promoting the
project implementation for a strong marine province during the “14th FiveYear Plan”. Available at: http://www.fj.xinhuanet.com/yuanchuang/202107/09/c_1127638534.htm; Zhejiang Bureau of Ocean and Fisheries. (2021).
Notice of the “Fourteenth Five-Year Plan” for the Development of Zhejiang
Provincial Ocean Economy. Available at: http://www.zj.gov.cn/art/2021/6/4/
art_1229019364_2301508.html.
56 Qingdao Daily. (2012). Qingdao’s offshore fishing industry has survived
a decade of glory (青岛远洋渔业历经十年辉煌). Available at: https://finance.
qingdaonews.com/content/2012-12/07/content_9522840.htm.
57 FAO. (2020). The State of World Fisheries and Aquaculture 2020.
Sustainability in Action. Rome.
58 ​​The FAO does not specify what should be understood by “distant-water
fishery” (i.e., whether it only includes distant-water fishing vessels flying
the flag of China or Chinese distant-water fishing vessels irrespectiveof their flag). However, EJF notes that the figure mentioned in the FAO
report corresponds with figures published by China in its fishery statistical
yearbooks which are understood to cover all Chinese distant-water fishingvessels irrespective of their flag.
59 FAO. (2020). The State of World Fisheries and Aquaculture 2020.,
Sustainability in Action. Rome.
60 FAO. (n.d.). FAO Major Fishing Areas. Available at: http://www.fao.org/
fishery/area/search/en.
61 Greenpeace Africa and Changing Markets. (2021). Feeding a monster:
How European aquaculture and animal feed industries are stealing foodfrom West African communities. Available at: http://changingmarkets.org/
wp-content/uploads/2021/05/Feeding-a-Monster-EN-low-res.pdf.
62 95.3% of the approved offshore fishery projects relating to the Pacific
Ocean are assessed by EJF to cover tuna and tuna-like fisheries whilst theareas mentioned as North Pacific, Northwest Pacific and Southeast Pacific areusually associated with non-tuna and tuna-like fisheries (e.g. squid and small
pelagics (such as mackerel, sardine, saury)). A similar distinction is madein the Atlantic Ocean with the projects related to the Southwest Atlantic
covering squid fisheries whilst the category ‘Atlantic Ocean’ relates to tunaand tuna-like fisheries. No such distinction is made in the Indian Ocean
though different types of fisheries are also found (e.g. tuna and squid).
63 FAO. (2005). Fisheries and Resources Monitoring System. Review of thestate of world marine fishery resources 2005. Squid - Global. Available at:
http://firms.fao.org/firms/resource/13335/en.
64 Stop Illegal Fishing, Trygg Mat Tracking and NFDS. (2017). Squid capturein the Northwest Indian Ocean: unregulated fishing on the high seas.
Gaborone, Botswana. Available at: https://fish-i-network.org/wp-content/
uploads/2017/06/Squid_capture_in_the_NWIO_FINAL_LR.pdf.
65 WWF, Trygg Mat Tracking. (2020). Unregulated fishing on the high seasof the Indian Ocean: the impacts on, risks to, and challenges for sustainablefishing and ocean health. Available at: https://wwfeu.awsassets.panda.
org/downloads/wwftmt_unregulated_fishing_on_the_high_seas_of_the_indian_ocean_2020.pdf.
66 Ministry of Agriculture and Rural Affairs. (2020). Notice of the Ministryof Agriculture and Rural Affairs on Strengthening the Conservation of Squid
Resources on the High Seas and Promoting the Sustainable Development of
the country’s Offshore Fisheries (农业农村部关于加强公海鱿鱼资源养护 促进我国远洋渔业可持续发展的通知). Available at: http://www.moa.gov.cn/
nybgb/2020/202007/202008/t20200811_6350178.htm.
67 Bureau of Statistics (统计局). (2020). China Fishery Statistical Yearbook(中国渔业统计年鉴2020). Available at: https://www.yearbookchina.com/
naviBooklist-n3020013079-1.html.
68 China Overseas Fisheries Association, Zhoushan National Oceanic FisheryBase Construction Development Group Co., Ltd.. (n.d).Oceanic squid index of
China (中国远洋鱿鱼指数). Available at: https://www.china-squid.com
69 Miller, N. et al. (2018). Identifying global patterns of transshipment
behaviour. Frontiers in Marine Science, 240(5). 0.
70 EJF. (2020). EJF’s Charter for Transparency. Bringing the fisheries sector
out of the shadows. How best to implement principles three and four of theCharter for Transparency. Available at: https://ejfoundation.org/resources/
downloads/Report_Principles-three-four-final.pdf.
71 As outlined in the ‘undercounting of the CDWF’ section of themethodology.
72 Zhoushan Offshore Fisheries Association. (2019). Chronology ofthe development of offshore squid fishing in Zhoushan (1989 - 2019).
Available at: http://www.zhoushan.cn/pd/youdiao/licheng/201909/
t20190911_941886.html.
73 Currently, the three largest national DWF bases in China are the tunabase of Rongcheng (Shandong province) in the northwest; the squid baseof Zhoushan (Zhejiang province) in the central-west; and Lianjiang Fuzhou(Fujian province) in the southwest. They all have sophisticated processing
plants and cold chain logistics.
74 Wang Zhenquan, Department of Finance, Zhejiang province, PRC.

(2019). Financial outlook to promote the high-quality development ofoffshore fishing in Zhejiang Province. Available at: http://czt.zj.gov.cn/
art/2019/11/22/art_1228972395_40466103.html.
75 Dependency model (挂靠): Individual vessel owners join DWF enterprises
with qualification by paying a fixed annual “dependency fee”, enabling thevessels to make use of fishing quota obtained by/allocated to DWF enterprises
approved by MARA. However, the ownership, investment, production
and operation of the vessel, including recruitment of crew, sales of fisheryproducts and mortgage financing, etc., are all decided by the individual vesselowners. The company does not intervene or have the right to involve itself inthe commercial decisions of independently operated fishing vessels.
76 Xinhua News Agency. (2017). Zhejiang Zhoushan builds the first highseas mobile base and South American office. Available at:
http://www.gov.cn/xinwen/2017-04/26/content_5189059.htm.
77 Chinese People’s Political Consultative Conference Zhoushan Putuo
District Committee. (2020). Suggestions on Solving the Sustainable
Development of Cooperative Marketing of Pelagic Squid Fishing (关于解决远洋鱿钓渔业合作销售可持续发展的建议). Available at: http://ptzx.putuo.gov.
cn/sqmy/zbszx/20211/921311201132722.html.
78 Financial News. (2021). Putuo Rural Commercial Bank’s three innovations
help offshore fisheries tide over the epidemic. Available at: https://www.
financialnews.com.cn/ncjr/nsh/202101/t20210128_210782.html.
79 Stock.us. (n.d.). Main clients of CNFC. Available at: https://stock.us/cn/
stock/sz/000798/footnotes/customer-supplier/customer.
80 Wang Zhenquan, Department of Finance, Zhejiang province, PRC.
(2019). Financial outlook to promote the high-quality development ofoffshore fishing in Zhejiang Province.
81 Subaoxw. (2021). Sixty percent of the squid in the country is
processed here in Shandong. Available at: http://sd.subaoxw.com/
sdyw/2021/1022/25281.html.
82 Zhoushan City Government. (2020). Several policies for accelerating
the high-quality development of offshore fishing in Zhoushan. Available at:
http://xxgk.zhoushan.gov.cn/art/2020/8/18/art_1229433794_38630.html
83 Hong Dong Fishery website. Available at: http://www.fzhongdong.com
84 Marcus Aurelius Value. (2017). Pingtan Marine: A Fraud That Finances
Human Trafficking and Poaching. Available at: http://www.mavalue.org/
research/pingtan-marine-fraud-finances-human-trafficking-poaching.
85 Chinese Academy of Fishery Sciences, Yellow Sea Fisheries ResearchInstitute. (2021). Fujian builds a strong ocean fishery province, leading thecountry in comprehensive strength (福建打造远洋渔业强省 综合实力全国领
先). Available at: http://www.ysfri.ac.cn/info/1110/36320.htm.
86 Zhou, C. (2020). The Truth Behind The Intrusion Of A Chinese Vessel
Carrying More Than 6000 Sharks Into The Galápagos Marine Reserve In
2017. Available at: https://tangchuanc.medium.com/the-truth-behind-theintrusion-of-a-chinese-vessel-carrying-more-than-6000-sharks-into-the2cae00bcb4d0.
87 China shark products cooperatives. (n.d.). Home. Available at:
http://www.china-shark.com.
88 Marcus Aurelius Value. (2017). Pingtan Marine: A Fraud That Finances
Human Trafficking and Poaching. Available at: http://www.mavalue.org/
research/pingtan-marine-fraud-finances-human-trafficking-poaching.
89 China shark products cooperatives. (n.d.). Home. Available at:
http://www.china-shark.com.
90 Fujian Provincial People’s Government. (2021). Notice of the General
Office of the People’s Government of Fujian Province on Eight Measures toPromote the High-quality Development of Ocean Fisheries (福建省人民政府
办公厅关于推动远洋渔业高质量发展八条措施的通知). Available at:https://fdi.swt.fujian.gov.cn/show-10571.html.
91 Bureau of Ocean and Fisheries of Fuzhou city. (2020). Fuzhou Municipal
Bureau of Ocean and Fisheries Special Funds for Offshore Fisheries - Project
Performance Evaluation Report (福州市海洋与渔业局远洋渔业专项资金项目绩效评价报告). Available at: https://hyj.fuzhou.gov.cn/zz/zwgk/zjxx/202107/
t20210712_4138495.htm
92 Ibid.
93 Chinese Academy of Fishery Sciences, Yellow Sea Fisheries ResearchInstitute. (2021). Fujian builds a strong ocean fishery province, leading thecountry in comprehensive strength (福建打造远洋渔业强省 综合实力全国领
先). Available at: http://www.ysfri.ac.cn/info/1110/36320.htm.
94 Beijing​​
Yachao Asset Appraisal Co., Ltd. (2014). Note on the valuationof all shareholders’ equity of Zhongyu Global Seafood Co. due to asset
integration initiated by CNFC Overseas Fisheries Co., Ltd (中水集团远洋股份有限公司拟重组中渔环球海洋食品有限责任公司所涉及的中渔环球海洋食品
有限责任公司股东全部权益评估说明). Available at:
http://quotes.money.163.com/f10/ggmx_000798_1642105.html.
95 State-owned Assets Supervision and Administration Commission Party
Committee, Propaganda Department (2017). 54 中水渔业斐济代表. Available
at: http://www.sasac.gov.cn/n4470048/n4470081/n7500405/n7500420/
n7500435/c7504771/content.html.
96 Ministry of Commerce, Economic and Commercial Office of the Embassyof the People’s Republic of China in the Republic of Vanuatu. (2016). Trial
operation of Zhongwa Fishery Company. Available at: http://vu.mofcom.gov.
cn/article/jmxw/201611/20161101610395.shtml.
97 NetEase. (2019). The commencement ceremony of Sino-Vanuatu FisheryCompany was held in Port Vila, the capital of Vanuatu. Yu Difei, Chairman ofChina Agricultural Development Group, attended the ceremony. Available
at: https://www.163.com/dy/article/ESTEVSR30550A54Z.html.
98 China National Agricultural Development Group Co., Ltd., China State
Farm Agribusiness Group Co,. Ltd. (2019). China Agricultural Development
Group Chairman Yu Difei Meets with the Prime Minister of Vanuatu.
Available at: https://csfa.cnadc.com.cn/jtyw/10924.jhtml.

53

99 Reuters. (n.d.).Shandong Zhonglu Oceanic Fisheries Co. Available at:https://www.reuters.com/companies/200992.SZ.
100 Reuters.(n.d.) Shandong Homey Aquatic Development Co. Ltd. Available
at: https://www.reuters.com/companies/600467.SS.
101 China Canned Food Industry Association. (2020). One tuna, one
industrial chain (一条金枪鱼，一条产业链). Available at:
http://www.topcanchina.com/hyzx/10788.
102 Ibid.
103 Qingdao Municipal Marine Development Bureau. (2013). Opinionsof Qingdao Municipal People’s Government on Accelerating theDevelopment of Offshore Fishing (青岛市人民政府关于加快远洋渔业发展的意见). Available at: https://www.zyszhjha.com/n12479801/n12480099/
n12480192/151212120419454215.htm.
104 Qingdao Municipal Bureau of Statistics. (2015). Qingdao’s “bluegranary” construction is beginning to bear fruit (青岛市“蓝色粮仓”建设初见成效). Available at: http://qdtj.qingdao.gov.cn/n28356045/n32561056/
n32561071/n32562216/180324165657258043.html.
105 Qingdao Daily. (2012). Qingdao’s offshore fishing industry has survived
a decade of glory (青岛远洋渔业历经十年辉煌). Available at: https://finance.
qingdaonews.com/content/2012-12/07/content_9522840.htm.
106 SeafoodSource. (2021). Qingdao distant-water fleet grew 17-fold in past
eight years. Available at: https://www.seafoodsource.com/news/premium/supply-trade/qingdao-distant-water-fleet-grew-17-fold-in-past-eight-years.
107 Caitong Securities Co., Ltd. (2021). The prospectus for initial public
offerings (IPO) of Zhejiang Ocean Family Co., Ltd. (浙江大洋世家股份有限公
司首次公开发行股票招股说明书). Available at: https://pdf.dfcfw.com/pdf/
H2_AN202106281500540089_1.pdf
108 Wanxiang Daily (万向报 版权所有). (2021). Ocean Family’s newly built
large fishing boat was launched smoothly (大洋世家新建大型渔船顺利下水).
Available at: http://www.cnepaper.net/html/198/2021/04/05/1.html.
109 Zsdinghai. (2021). Zhoushan’s tuna industry is growing rapidly in“adversity” (舟山金枪鱼产业“逆境”中快速成长). Available at:
http://dhnews.zjol.com.cn/xinwenzonglan/zhoushanxinwen/202102/
t20210201_3597782.shtml.
110 Caitong Securities Co., Ltd. (2021). The prospectus for initial public
offerings (IPO) of Zhejiang Ocean Family Co., Ltd. (浙江大洋世家股份有限公
司首次公开发行股票招股说明书). Available at: https://pdf.dfcfw.com/pdf/
H2_AN202106281500540089_1.pdf
111 Ynet.com. (2019). Ocean Family: China’s big tuna player (大洋世家：中国金枪鱼大玩家). Available at: http://life.ynet.com/2019/06/04/1864396t978.html
112 Zhejiang Ocean Family QCC page. Available at: https://www.qcc.com/fir
m/9fffc8981bf11630b586e6833c9fa162.html
113 Executive Office of the President, Office of the U.S. Trade Representative(USTR). (2018). Findings of the investigation into China’s acts, policies, andpractices related to technology transfer, intellectual property, and innovation
under Section 301 of the Trade Act of 1974. Available at: https://ustr.gov/
sites/default/files/Section%20301%20FINAL.PDF.
114 For instance, the following statement can be found in Wanxiang’s
newsletter, “...The implementation of the new purse seiner project is highly
compatible with the national development strategy of joining hands to build
a community of maritime destiny and promoting the Belt and Road Initiative”.
Wanxiang Daily (万向报 版权所有). (2021). Ocean Family’s newly built large
fishing boat was launched smoothly (大洋世家新建大型渔船顺利下水).
Available at: http://www.cnepaper.net/html/198/2021/04/05/1.html.
115 Executive Office of the President, Office of the U.S. Trade Representative(USTR). (2018). Findings of the investigation into China’s acts, policies, andpractices related to technology transfer, intellectual property, and innovation
under Section 301 of the Trade Act of 1974. Available at: https://ustr.gov/
sites/default/files/Section%20301%20FINAL.PDF.
116 Businesswire. (2014). China Tuna Industry Group Holdings Co., Ltd.
withdraws IPO application (中国金枪鱼产业集团控股有限公司撤回IPO申请).
Available at: https://www.businesswire.com/news/home/20141209006754/
zh-CN/
117 SeafoodSource. (2014). China Tuna pulls IPO amid fishing criticism.
Available at: https://www.seafoodsource.com/news/environmentsustainability/china-tuna-pulls-ipo-amid-fishing-criticism.
118 Stuff. (2014). China Tuna suspends IPO. Available at: https://www.stuff.
co.nz/business/10529956/China-Tuna-suspends-IPO.
119 China Business Network. (2018). The background story of DalianLongtai and the Dalian Tuna Fishing which were under the authority’s
scrutiny (被监管关注的大连隆泰和背后的金枪鱼钓是什么来头). Available at:https://www.yicai.com/news/100081376.html
120 EJF. (2021). A human rights lens on the impacts of industrial illegal
fishing and overfishing on the socio-economic rights of small-scale fishingcommunities in Ghana. Available at: https://ejfoundation.org/reports/ahuman-rights-lens-on-the-impacts-of-industrial-illegal-fishing-andoverfishing-on-the-socio-economic-rights-of-small-scale-fishing-communities-in-ghana.
121 Sea Shepherd. (2019). Sea Shepherd assists Liberian Coast Guard
in arrest of cargo vessel on suspicion of identity fraud and IUU fishing.
Available at: https://www.seashepherdglobal.org/latest-news/sea-shepherdassists-liberian-coast-guard-in-arres/.
122 Sea Shepherd. (2020). Another two trawlers arrested in the Gambia.
Available at: https://www.seashepherdglobal.org/latest-news/two-trawlersarrested-gambia/.
123 Research found public revenues equating to 2%-8% of the estimatedlanded value of the harvest in three out of four West African countries
studied: Virdin, J., Kobayashi, M., Akester, S., Vegh, T. and Cunningham, S.
(2019) West Africa’s coastal bottom trawl fishery: initial examination of a
trade in fishing services. Marine Policy, 100, 288–297. See also: EJF (2021).

At what cost? How Ghana is losing out in fishing arrangements with China’s
distant water fleet. Available at: https://ejfoundation.org/reports/at-whatcost-how-ghana-is-losing-out-in-fishing-arrangements-with-chinas-distantwater-fleet.
124 Jones, J. B. (1992). Environmental impact of trawling on the seabed: areview. New Zealand Journal of Marine and Freshwater Research, 26, 59–67;
Watling, L. and Norse, E.A. (1998). Disturbance of the Seabed by Mobile
Fishing Gear: A Comparison to Forest Clearcutting. Conservation Biology.
12(6), 1180-1197; Vincent, A. and Zhang, X. (in prep.). China’s bottom trawl
fisheries and their global impact.
125 EJF. (2021). A human rights lens on the impacts of industrial illegal
fishing and overfishing on the socio-economic rights of small-scale fishingcommunities in Ghana. Available at: https://ejfoundation.org/reports/ahuman-rights-lens-on-the-impacts-of-industrial-illegal-fishing-andoverfishing-on-the-socio-economic-rights-of-small-scale-fishing-communities-in-ghana.
126 EJF. (2021). Recommendations for the reform of Ghana's Inshore
Exclusion Zone (IEZ) reserved for small-scale fishing activities. Available at:https://ejfoundation.org/resources/downloads/Briefing_extension_IEZ_
boundary-2021-v2a.pdf
127 Ibid.
128 EJF and Hen Mpoano. (2019). Stolen at sea. How illegal ‘saiko’ fishing isfuelling the collapse of Ghana’s fisheries. Available at: https://ejfoundation.
org/resources/downloads/Stolen-at-sea_06_2019.pdf
129 EJF. (2021). Powerless bystanders: Ghana’s fisheries observers struggle tocurb crimes and ensure their own safety at sea. Available at:https://ejfoundation.org/resources/downloads/EJF-Powerless-bystanders2021-final.pdf
130 Lazar, N. et al. (2020). Status of the small pelagic stocks in Ghana in 2019.
Scientific and Technical Working Group. USAID/Ghana Sustainable Fisheries
Management Project (SFMP). See also: EJF (2020). The “people’s” fishery on
the brink of collapse: Small pelagics in landings of Ghana’s industrial trawl
fleet. Available at: https://ejfoundation.org/reports/the-peoples-fisheryon-the-brink-of-collapse-small-pelagics-in-landings-of-ghanas-industrialtrawl-fleet; Anum-Doyi, B. et al. (2019) Technical audit of fishing gears usedby industrial trawlers in Ghana. Report of a study commissioned by the
Fisheries Commission Board. October 2019. Unpublished; Aheto, D.W. etal.(in prep.). Fish species transshipped at sea (Saiko fish) in Ghana with a noteon implications for marine conservation. Preprint. Available at:https://www.researchsquare.com/article/rs-41329/v1
131 Unspecified high seas areas - presumably beyond RFMO jurisdiction.
132 Vessel/gear type was not specified in 48% of IUU fishing offences
identified for West Africa.
133 Including vessels flying the flag of China, and those flying third country
flags but with presumed Chinese beneficial ownership. See Pauly et al. (2014).
China’s distant-water fisheries in the 21st century. Fish and Fisheries, 15, 474-488.
134 Pauly et al. (2014). China’s distant-water fisheries in the 21st century. Fishand Fisheries, 15, 474-488.
135 It should be noted however that these countries are subject to the‘spotlight’ effect mentioned previously in the report, in which particularflag and coastal states have received high levels of attention from NGOs andthe media.
136 Ghanaian Ministry of Fisheries and Aquaculture Development. (2010).
Republic of Ghana fisheries and aquaculture sector development plan 20112016. Available at: https://www.fao.org/faolex/results/details/en/c/LEXFAOC178892/.
137 Nolan, C. (2019). Power and access issues in Ghana’s coastal fisheries:
A political ecology of a closing commodity frontier. Marine Policy, 108, 103621.
138 Ofakor-Yarwood, I., van den Berg Bhagwandas, S. (2021). Financial
security needed for women in West African fisheries. World Economic Forum.
Available at: https://www.weforum.org/agenda/2021/05/why-women-inthe-west-african-fishing-industry-need-more-financial-safety-nets.
139 Nolan, C. (2019). Power and access issues in Ghana’s coastal fisheries:
A political ecology of a closing commodity frontier. Marine Policy, 108, 103621.
140 Thorpe, A. et al. (2014). “Fishing na everybody business”: Women’s workand gender relations in Sierra Leone’s fisheries. Feminist Economics, 20(3), 53-77.
141 Global Fishing Watch. (2020). Follow the lights: squid fishing in thesoutheast Pacific Ocean. Available at: https://globalfishingwatch.org/
fisheries/squid-fishing-southeast-pacific/.
142 Oceana. (2021). Now you see me, now you don’t: Vanishing vessel along
Argentina’s waters. Available at: https://zenodo.org/record/4893397#.
YgpRyi-l1QI.
143 WWF and Trygg Mat Tracking. (2020). Unregulated fishing on thehigh seas of the Indian Ocean: The impacts on, risks to, and challenges forsustainable fishing and ocean health. Available at: https://wwfeu.awsassets.
panda.org/downloads/wwftmt_unregulated_fishing_on_the_high_seas_of_
the_indian_ocean_2020.pdf.
144 Ibid.
145 In some instances RFMO jurisdictions overlap with a country’s EEZ.
Where a country and an RFMO are compared alongside one another, thefigures given for the RFMO refer to its high seas area.
146 In some instances RFMO jurisdictions overlap with a country’s EEZ.
Where a country and an RFMO are compared alongside one another, thefigures given for the RFMO refer to its high seas area.
147 In some instances RFMO jurisdictions overlap with a country’s EEZ.
Where a country and an RFMO are compared alongside one another, thefigures given for the RFMO refer to its high seas area.
148 Based on the stratification provided by the Spyglass database, EJF pooledsimilar offences together and formed the categories listed. Please note thatduring a seizure/checkup of a vessel, multiple infringements could be found54

onboard. Hence, adding up the “percentage of total” column of this table will
end up with a number higher than 100%.
149 The number of individual offences may be more than the total number
of IUU fishing incidents, as a single incident may consist of multiple
different offences.
150 The number of individual offences may be more than the total number
of IUU fishing incidents, as a single incident may consist of multiple
different offences.
151 EJF. (2019). Blood and water: Exploring the links between illegal fishingand human rights abuses. Available at: https://ejfoundation.org/reports/
blood-and-water-human-rights-abuse-in-the-global-seafood-industry.
152 Links between IUU fishing and human rights are increasingly being
discussed. See for example: Mackat, M. et al. (2020). The intersection
between illegal fishing, crimes at sea, and social well-being. Frontiers in
Marine Science, 7; and Fishwise. (2018). The links between IUU fishing,human rights, and traceability. Available at: https://fishwise.org/wpcontent/uploads/2018/03/The-Links-between-IUU-fishing-human-rightsand-traceability.pdf.
153 CBP. (2021). CBP issues release order on Chinese fishing fleet. Available
at: https://www.cbp.gov/newsroom/national-media-release/cbp-issueswithhold-release-order-chinese-fishing-fleet.
154 This list of offences are an adapted version of the ILO Indicators ofForced Labour: ILO (2012). Indicators of Forced Labour. Available at:https://www.ilo.org/global/topics/forced-labour/publications/
WCMS_203832/lang--en/index.htm.
155 EJF. (2020). Fear, hunger and violence: Human rights in Ghana’s
industrial trawl fleet. Available at: https://ejfoundation.org/resources/
downloads/EJF_Ghana-human-rights-in-fisheries_2020_final.pdf.
156 A more detailed overview of the case can be found at: APIL et al. (2020).
A briefing on Longxing 629: A case of illegal, unreported and unregulated(IUU) fishing activities and related human rights abuses on a tuna longliner.
Available at: https://foeasiapacific.org/wp-content/uploads/2020/07/
Appendix-2.-A-Briefing-on-Longxing-629-written-by-Korea-IUU-Coalition.pdf
157 EJF. (2020). Four die on Chinese vessel allegedly fishing illegally.
Available at: https://ejfoundation.org/news-media/four-crew-from-chinesefishing-vessel-die-allegedly-denied-medical-care.
158 EJF. (2019). Blood and water: Human rights abuses in the global seafoodindustry. Available at: https://ejfoundation.org/resources/downloads/
Blood-water-06-2019-final.pdf.
159 Nusa Daily. (2020). Become the Victims of Forced Labor on ChineseFishing Vessels, Two Indonesian Crews Plunge into the Sea. Available
at: https://nusadaily.com/news/become-the-victims-of-forced-labor-onchinese-fishing-vessels-two-indonesian-crews-plunge-into-the-sea.html.
160 Greenpeace. (2019). Seabound: The journey to modern slavery on
the high seas. Available at: https://www.greenpeace.org/static/planet4southeastasia-stateless/2019/12/c4f6f6b4-greenpeace-seabound-b.pdf.
161 EJF. (2020). Fear, hunger and violence: Human rights in Ghana’s trawl
sector. Available at: https://ejfoundation.org/resources/downloads/EJF_
Ghana-human-rights-in-fisheries_2020_final.pdf.
162 For instance, Pingtan Marine Enterprise owns at least two companies
domiciled in Indonesia but off the record in China. Aurelius Value. (2017).
Pingtan Marine: A Fraud That Finances Human Trafficking and Poaching.
Available at: http://www.mavalue.org/research/pingtan-marine-fraudfinances-human-trafficking-poaching/?__cf_chl_managed_tk__=pmd_pz
Pl9b3Q5yFVlC3nJSQAOYy1KPWe1Hnoxb0fqmTMh7M-1634744788-0gqNtZGzNAyWjcnBszRZl.
163 Ministry of Agriculture and Rural Affairs. (2018). Circular of the General
Office of the Ministry of Agriculture and Rural Affairs on the investigationand handling opinions of some offshore fishery enterprises and fishing boats
suspected of violating laws and regulations.
164 Most of Fuzhou Dongxinlong’s vessels were sold and transferred after
their qualification was cancelled by MARA due to IUU fishing, however, theircurrent record on Sea-Web remained to be 8 vessels.
165 There were several cases of vessel transfer between Huali and othersquid fishing companies in Zhoushan in recent years. However, the record
on Sea-Web remained to be four vessels.
166 EJF. (2021). At what cost? How Ghana is losing out in fishingarrangements with China’s distant water fleet. Available at: https://ejfoundation.org/reports/at-what-cost-how-ghana-is-losing-out-in-fishingarrangements-with-chinas-distant-water-fleet.
167 Orbis database of company information: orbis.bvdinfo.com. Accessed
5.3.21.
168 Shandong State-owned Assets Investment Holding Co., Ltd. (2014).
Shandong Zhonglu Ocean Fishery Co., Ltd. (山东省中鲁远洋渔业股份有限公司). Available at: http://www.sdgzkg.com/art/2014/6/30/art_22_1225.html.
169 Sohu. (2020). Set sail and strive for success-Shandong Ocean FisheryCo., Ltd. set sail successfully for the new fishing project of Shandong Ocean
Fishery Co., Ltd. in Morocco (扬帆起航 争创佳绩——山东省远洋渔业有限公司驻摩洛哥渔业项目新造渔船胜利启航). Available at: https://www.sohu.
com/a/411624888_100023701.
170 Ministry of Agriculture and Rural Affairs. (2020). Notice of the Ministryof Agriculture and Rural Affairs on confirming the fifth batch of offshore
fishery projects in 2019 (农业农村部关于确认2019年度第五批远洋渔业项目的通知). Available at: http://www.moa.gov.cn/nybgb/2019/201908/202001/
t20200109_6334599.htm.
171 Weihai Municipal People’s Government, Foreign Affairs Office. (2021).
Argentine Ambassador to China Niu Wangdao and his party visited (阿根廷驻华大使牛望道一行来访). Available at: http://wb.weihai.gov.cn/
art/2021/10/20/art_13510_2695071.html.

172 Samari, M. (12.9.19). Investigation ties foreign-owned trawlers to illegal
fishing in Ghana. China Dialogue Ocean. https:// chinadialogueocean.
net/10050-investigation-illegal-fishing-in-ghana-pt-1/
173 Ibid.
174 Shuidi company credit check platform - Dalian Mengxin Ocean Fishery.
Available at: https://shuidi.cn/company-d19162301cc085f81c77c126a0af
1ec7.html; China’s company registry. Available at: https://www.gsxt.gov.
cn/index.html. See also: Samari, M. (12.9.19). Investigation ties foreignowned trawlers to illegal fishing in Ghana. China Dialogue Ocean. https://chinadialogueocean.net/10050-investigation-illegal-fishing-in-ghana-pt-1/
175 Export Genius. (n.d.). DALIAN​​
MENGXIN OCEAN FISHERY CO L.
Available at: http://www.exportgenius.in/dalian-mengx-ocean-fishery-co-limporter-in-ghana.
176 Glad Trust (格兰德企业信用管理). (n.d.). The clients of Dalian Kaiyang
World Seafood (大连凯洋世界海鲜股份有限公司有哪些客户). Available at:https://www.x315.cn/case/4FXMGu.
177 ‘Dalian Meng Xin Ocean Fishery Co., Limited’, Hong Kong Integrated
Companies Registry Information System, accessed 5.2.21. https://www.icris.
cr.gov.hk/csci/
178 Ministry of Agriculture and Rural Affairs. (2013). Notice of the General
Office of the Ministry of Agriculture on the handling of violations of fishingboats by Dalian Lianrun Ocean Fishery Co., Ltd. (农业部办公厅关于大连连润远洋渔业有限公司渔船违规事件进行处理的通知). Available at:
http://www.moa.gov.cn/govpublic/YYJ/201308/t20130828_3589507.htm.
179 Ministry of Agriculture and Rural Affairs. (2019). Announcement on theinvestigation and handling opinions of some deep-sea fishery enterprises
and fishing vessels suspected of violating laws and regulations (关于部分远洋渔业企业及渔船涉嫌违法违规问题调查情况和处理意见的通报). Available
at: http://www.yyj.moa.gov.cn/gzdt/201909/t20190923_6328680.htm.
180 SeafoodSource. (2015). China tuna firm boasts ‘record’ catches in
Pacific waters lured from US skipjack fleet. Available at: https://www.
seafoodsource.com/news/supply-trade/china-tuna-firm-boasts-recordcatches-in-pacific-waters-lured-from-us-skipjack-fleet.
181 SeafoodSource. (2021). US issues order against Chinese fishing company
accused of forced labor. Available at: https://www.seafoodsource.com/
news/environment-sustainability/us-issues-order-against-chinese-fishingcompany-accused-of-forced-labor.
182 Global Fishing Watch. (2017). Our data suggests transshipment involved
in refrigerated cargo vessel just sentenced to $5.9 million and jail time forcarrying illegal sharks. Available at: https://globalfishingwatch.org/impacts/
policy-compliance/transhippment-involved-in-reefer-sentenced-forcarrying-illegal-sharks/.
183 Fuzhou Municipal Bureau of Ocean and Fisheries. (2017). Proposed
allocation of special funds for offshore fishing in Fuzhou (福州市远洋渔
业专项资金拟分配表). Available at: http://hyj.fuzhou.gov.cn/zz/zwgk/
tzgg_3361/201711/P020171107632692162872.pdf
184 US National Intelligence Council. (2016). Global Implications of Illegal,
Unreported, and Unregulated (IUU) Fishing. Available at: https://irp.fas.org/
nic/fishing.pdf.
185 Ministry of Agriculture and Rural Affairs. (2018). The General Officeof the Ministry of Agriculture on some offshore fishery enterprises andNotification of fishing vessel violations of laws and regulations andtheir handling opinions (农业部办公厅关于部分远洋渔业企业及渔船违法违规问题和处理意见的通报). Available at: http://www.moa.gov.cn/
nybgb/2018/201803/201805/t20180528_6143244.htm.
186 Ministry of Agriculture and Rural Affairs. (2019). Regarding thesuspected violations of laws and regulations by some deep-sea fisherycompanies and fishing boats Notification of investigation status andhandling opinions (关于部分远洋渔业企业及渔船涉嫌违法违规问题调查情况
和处理意见的通报). Available at: http://www.yyj.moa.gov.cn/gzdt/201909/
t20190923_6328680.htm.
187 Ministry of Agriculture and Rural Affairs. (2018). Circular of theGeneral Office of the Ministry of Agriculture and Rural Affairs on theinvestigation and handling opinions of some offshore fishery enterprises
and fishing boats suspected of violating laws and regulations (农业农村部办公厅关于部分远洋渔业企业及渔船涉嫌违法违规问题调查情况和处理意见的通报). Available at: http://www.moa.gov.cn/nybgb/2018/201806/201809/t20180904_6156764.htm
188 Hong Kong Free Press. (2016). Feature: After ‘high seas pursuit’, Sea
Shepherd urges Beijing to prosecute illegal fishing fleet. Available at:https://hongkongfp.com/2016/04/14/feature-high-seas-pursuit-seashepherd-urges-beijing-prosecute-illegal-fishing-fleet/.
189 Birdlife, CFFA and WWF. (2020). 10 priorities for the future of
Sustainable Fisheries Partnership Agreements. Available at: https://www.
cffacape.org/publications-blog/ten-priorities-for-the-future-of-sustainablefisheries-partnership-agreements
190 EU IUU Coalition. (2020). A comparative study of key data elements
in import control schemes aimed at tackling illegal, unreported andunregulated fishing in the top three seafood markets: The European Union,
the United States and Japan. Available at: http://www.iuuwatch.eu/wpcontent/uploads/2020/11/CDS-2020-report-EN-WEB-Nov-2020.pdf.
191 Long Distance Advisory Council. (2021). LDAC recommendations for alevel playing field for EU and non-EU fish products. Available at:https://ldac.eu/images/EN_LDAC_Advice_LPF_25May2021.pdf.
192 It is noted that links to Chinese beneficial ownership have not been
established for all vessels in this table. For further details of ownership, see:
EJF. (2021). At what cost? How Ghana is losing out in fishing arrangementswith China’s distant water fleet. Available at: https://ejfoundation.org/
reports/at-what-cost-how-ghana-is-losing-out-in-fishing-arrangementswith-chinas-distant-water-fleet

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