No C 337/18 Official Journal of the European Communities 31. 12. 
been expressed with regard to establishing producer The Committee urges the Commission to amend their 
groups. proposal to include these sectors. 
Done at Brussels, 27 October 1988. 
The Chairman 
of the Economic and Social Committee 
Alberto MASPRONE 
Opinion on the situation of the herring market 
(88/C 337/09) 
On 15 december 1987 the Economic and Social Committee, acting under the fourth paragraph 
of Article 20 of its rules of procedure, decided to draw up an Opinion on the situation of 
the herring market and market for sardines in the Community. 
On 29 September 1988 the Economic and Social Committee decided to split the document 
into two parts and draw up two separate Opinions. 
The section for agriculture and fisheries, which was responsible for preparing the Committee's 
work on the situation of the herring market, adopted its Opinion on 6 October 1988. The 
rapporteur was Mr Hancock. 
At its 259th plenary session (meeting of 27 October 1988) the Economic and Social Committee 
unanimously adopted the following Opinion. 
1. Market update and introductory remarks 
Since the publication of the Commission report on 
9 November 1987, the market situation has continued 
to evolve. 1.1. Total allowable catches for EEC fleets for 1988 
were set at 502 900 tonnes [Council Regulation (EEC) 
No 3977/87] (*) allocated as follows: 
Denmark 
United Kingdom 
Netherlands 
West Germany 
France 
Ireland 
Belgium 155 550 tonnes 
107 460 tonnes 
88 350 tonnes 
71 240 tonnes 
37 670 tonnes 
33 440 tonnes 
9 190 tonnes (30,9 % of EEC total allowable catch) 
(21,4% of EEC total allowable catch) 
(17,6% of EEC total allowable catch) 
(14,2% of EEC total allowable catch) 
(7,5 % of EEC total allowable catch) 
(6,6 % of EEC total allowable catch) 
(1,8 % of EEC total allowable catch) 
This was some 47 000 tonnes lower than in 1987 
because of a downward revision of scientific projec­
tions. These were not so serious, however, as to invali­
date the conclusions in the Commission document. It 
is anticipated that, eventually, available stocks could 
reach 800 000 tonnes, or more, per annum. The ques­
tion now arises as to what methods should be employed 
so that these stocks may be disposed of in a commercial 
manner. 1.2. Withdrawal prices for 1988 were reduced by 9 % 
excluding green rate adjustments. From the fourth table 
in the Annex to the Commission report « Evolution of 
herring prices», it will be seen that, in 1986, there 
were wide variations in the average prices obtained in 
different Member States. 
OJ No L 375, 31. 12. 1987. 
31. 12. 88 Official Journal of the European Communities No C 337/19 
In 1987, although official Community figures are still 
unavailable regarding prices in individual Member 
States, it would appear that prices stabilized. Returns 
in United Kingdom (effectively Scotland) improved by 
8% per tonne sold but there were slight declines in 
Ireland, the Netherlands and Denmark. The average 
Community price during 1987 was 242,73 ECU per 
tonne for fresh herring. 
It must be pointed out that the talk of average prices 
is somewhat misleading as what is involved are several 
different markets, each with its distinctive level of price, 
product requirement and associated problems. 
1.3. At present price levels it is reported that only 
larger boats, i.e. those with freezing or chilled water 
storage capacity can operate profitably and that in 
consequence fishermen are no longer fishing herring 
and quotas not being fully utilized. Based on provisional 
figures for quota utilization this would appear too 
broad a statement. These figures show the levels of 
quota landed as being: 
Belgium 
Denmark 
France 
Ireland 
Netherlands 
United Kingdom 
West Germany 0,4% 
89,0% 
23,0% 
102,0 % 
101,0% 
98,0% 
18,0% 
Thus whilst Belgium has virtually ceased to catch her­
ring and France has apparently markedly reduced its 
activity three countries have used or virtually used their 
quota. West Germany is a special case in that traders 
buy herring on international and Community markets 
because of the particular demands of their processing 
industry. The unfortunate publicity on nematodes is 
also likely to have had an effect on quantities fished by 
West Germany. In the case of Ireland and the United 
Kingdom major quantities were supplied to Klondijkers (factory ships operating wholly at sea for extended 
periods). It should be pointed out that these factory 
ships originate in non-Member States and that the 
whole operation is difficult to control by the autorities. 
Declared deliveries to Klondijkers in 1986 were: 
— Vessels of the Union of Soviet Socialist Repub­
lics : 53 734 tonnes, 
— Vessels of the German Democratic Republic: 
12 297 tonnes, 
— Polish vessels: 5 165 tonnes, 
— Bulgarian vessels: 555 tonnes. 
The situation vis-a-vis the United Kingdom improved 
substantially in 1987 in that fishermen stood out for 
higher prices and delivered lower quantities. This hel­
ped to mitigate a continuing downward pressure on 
Community prices. 
1.4. The Commission report, whilst strong on analy­
sis, is less positive in terms of conclusions. Possibly this 
is because of differences of opinion at the political level. 
Although this opinion would be better divided between 
problems that could be dealt with in the short term and 
those that require a longer perspective, for the sake of 
clarity it will deal with the points in the same order as 
in the Commission document. This will be followed by 
a separate evaluation of some of the social aspects of 
the herring industry. 
2. Control of imports 
2.1. Imports are used almost entirely by the process­
ing industry substantially in West Germany. In 
1986 they amounted to 108 743 tonnes of which 
81 518 tonnes were fresh or chilled, whole, headless or 
in pieces. The remainder, and the figures do not quite 
balance, of 21 664 tonnes, was imported frozen. 
Principal suppliers of fresh and chilled were: 
(39,6%) Sweden 
(53,92%) Norway 
(3,4%) Faroes 32 284 tonnes (94 % to Denmark) 
43 954 tonnes (67% to Denmark, 22% to FR of Ger­
many) 
2 774 tonnes (all to Denmark) 
(96,92%) 
Principal suppliers of frozen were 
(49,32%) Norway 
(23,79%) Iceland 
(23,56%) Canada 10 685 tonnes (49% to FR of Germany, 25% to United 
Kingdom, 10% to France, 10% to Nether­
lands) 
5 155 tonnes (41% to United Kingdom, 34% to FR of 
Germany, 17 % to France) 
5 105 tonnes (78% to FR of Germany, 7% to Nether­
lands, 7 % to United Kingdom) 
(96,67%) 
So, in each category, three countries accounted for over 96 % of total quantities imported. 
No C 337/20 Official Journal of the European Gommunities 31. 12. 88 
In 1987 there was an apparent decline in imports of 
fresh herrings to 72 440 tonnes. This was largely 
because of a 50% decline in imports from Sweden. 
Norwegian herring imports increased to 50 920 tonnes 
and now account for 70% of the total. This apparent 
decline was of little value to Community fishermen in 
that the imports from Sweden consist of a special variety 
of herring not available within the Community and 
required for processing. Thus, competition from 
Norwegian fresh herring imports actually increased. 
Figures for frozen differed little, increasing slightly from 
21 664 to 22 683 tonnes. Iceland shipped less but Nor­
way ( + 769 tonnes) and Canada (+ 1 688 tonnes) ship­
ped more. 
A reservation has to be entered about the accuracy 
of the statistics in respect of importations. Under the 
customs nomenclature it is impossible to distinguish 
between whole herring and herring flaps. So although 
the total weight is accurate one herring flap is the same 
in terms of useable weight as two whole herrings. Thus 
the figures do not account for the weight of useable 
material entering the Community. This could be 
increasing whilst imports are apparently declining. This 
is clearly an unsatisfactory situation and it is rec­
ommended that the nomenclature be altered so that 
import statistics can be both accurate and useable. 
In addition quotas of the General Agreement on Tariffs 
and Trade (GATT) should be expressed in terms of 
whole equivalent. 
2.2. To limit imports could bring some help to the 
Community herring market. Indeed questions can be 
raised about the real need for some of these imports. It 
is possible that some of the blame be laid at the door 
of the Community fishing industry for not trying harder 
to meet the real needs of the processing sector, although 
this could easily be exaggerated; transport costs are 
probably an equal factor. A total allowed catch (TAC) 
allocated in zone 2a would also help to improve the 
overall quality of Community landings. 
2.3. It is further maintained, by the General Com­
mittee for agricultural co-operation in the EEC (COGE-
CA), that a considerable quantity of the fresh herring 
imported fr^m third countries does not meet the specific 
quality standards of the processing industry. If correct, 
this can only serve to depress prices as these substan­
dard supplies must be diverted to the fresh market. 
Clearly greater attempts must be made to enforce qual­
ity standards on imports, particulary those arriving by 
road transport. 2.4. Some Member States would like the obligations 
for the importation of herring under GATT renego­
tiated. Whilst this is possible the process would be 
time consuming and almost certainly require reciprocal 
concessions in other fields. In any case, this would 
not solve the problem. Neither would the fixing of a 
reference price for fresh herring flaps and pieces. In 
1986 imports of whole herring greatly exceeded the 
duty free quotas and customs duties were paid on the 
excess quantities. The problem of the past is that, 
during a period of shortage, arrangements were made 
whereby substantial additional quantities can be 
imported duty free at certain times of the year. This 
leads to a situation where 90% of all imports are 
allowed to enter the Community duty free. These 
arrangements are no longer necessary in that adequate 
Community supplies are now available and these 
arrangements could and should be re-negociated. 
2.5. It has been suggested that reference prices which 
now apply only to fresh or chilled herring should also 
include frozen, particulary now that Norwegian purse 
seiners are beginning to now both fillet and freeze on 
board. This could only be of value if: 
— the reference price system was altered from that 
laid down under Article 21 of the basic Regulation 
(EEC) No 3796/81. Presently, the reference price is 
equal to the withdrawal price and is a maximum of 
90 % of the guide price. For 1988 the reference price 
for fresh herring (size 1) is 199 ECU per tonne. It 
has been noted that the average Community price 
in 1987 was 242,73 ECU per tonne. This would 
indicate that even if the present reference price 
was genuinely charged on imports, users could buy 
substantial quantities, even paying duty at 15 % and 
still be better off, particularly as transport costs 
from the peripheral regions can substantially exceed 
the amounts levied in import duty. 
Evidence suggests that the reference price (withdrawal 
price) effectively becomes the market price. This is 
going to have a long term effect on the efficiency of the 
Community fleet in that fishing will be insufficiently 
profitable to allow for investing in new and improved 
fishing vessels. The average age of the Danish fleet is 
now 30 years. 
2.5.1. It is alleged that prices shown on invoices 
covering imports are, in some instances, only proforma 
prices and that those actually paid were somewhat less. 
This could be clearly possible in the case of Norway 
where subsidies to the fleet are believed to amount to 
100 million ECU per annum. The Commission has 
never been provided with concrete evidence regarding 
such allegations. This is hardly surprising as the only 
way that such infractions could be discovered would 
be by spot checks being carried out by the customs 
31. 12. 88 Official Journal of the European Communities No C 337/21 
authorities of a Member State on the actual premises 
of an importer. There would have to be grounds for 
reasonable suspicion but such checks are already being 
carried out in the case of raisins where a minimum 
import price applies. Consequently, it is recommended 
that equally stringent checks be carried out in relation to 
the importation of herrings. These checks must include 
better policing of quantities actually landed as opposed 
to those declared as being landed. 
If all third country registered vessels landing fish in 
Community ports had to be calibrated in the same 
way as are Community vessels, this would make such 
checking easier. 
2.5.2. Whilst a countervailing duty can be applied, 
based on the difference between the reference price and 
the free at frontier price (as defined under Article 21.4 
of the basic Regulation) difficulties arise in that imports 
from a specific third country must remain below the 
reference price for three consecutive market days. In 
turn a duty is laid on Member States to promptly report 
the actual prices at which herring are being imported. 
Otherwise no action is possible. In practice, by the time 
reports are received and collated, the market has already 
been disturbed and it is too late to take action. 
2.5.3. As the present system does not work it is 
suggested that an examination be made of possible 
changes such as: 
— disturbance being based on quantity and/or price 
and applied to the market in each Member State, 
— that there be a reference price for each Member 
State, as far as imports are concerned, 
— that disruption can be said to have been caused even 
if supplies originate in more than one country, 
— how Member States be empowered to apply the 
countervailing duty promptly. 
2.5.4. Nevertheless, as any changes in the reference 
price system will only make a small contribution to 
resolving the problems of the herring market, care must 
be taken to see that they do not cause difficulties in 
respect of the importation of other species necessary 
for the efficient operation of the Community processing 
industry. 
2.5.5. Finally, it has to be pointed out in respect of 
reference prices that, despite strong suspicions that 
fleets catching herring subsequently imported to the 
Community are being subsidized, the Community does 
nothing to counter what, if true, are clearly distortions 
of free competition. 
After an investigation, the government of the United 
States closed its borders to Canadian fish until subsidies were removed. The Committee does not know what 
the situation is in relation to Canada and the EEC. 
However, it cannot be fair that whilst Canada can 
export to the Community, Community fleets are 
excluded from Canadian waters. 
It is recommended that an investigation be mounted 
into subsidization of all those fleets which enjoy quotas 
allowing them to send supplies to the EEC. Should 
unfair practices be discovered then supplies from that 
country should be excluded or, subjected to a counter­
vailing duty, until the matter is remedied. The alterna­
tive, should this prove impractical and conciliation 
procedures fail, would be for the Community to request 
the establishment of a GATT panel to investigate this 
matter. 
2.5.6. The Norwegian system whereby arrivals and 
landings by Community vessels are controlled does 
appear to have had a substantial effect on returns in 
that country. It would therefore seem both sensible and 
logical to apply the system in reverse. 
2.6. It would appear that negative solutions, of what­
ever kind, will not provide more than a marginal 
answer. What is needed are more positive attempts 
by Community producers to supply the quality that 
processors require. 
Historically, most herring used for processing was 
caught in the North Sea (zones IV and VII d). A best 
estimate of the annual requirement of the Community 
processing industry is plus or minus 300 000 tonnes. 
Claims are made that up to 40 to 50 000 tonnes would 
be of a quality to provide a suitable alternative to 
imports, were the situation pointed out in 2.4 properly 
resolved. 
More investigations are clearly needed in respect of this 
matter. 
2.6.1. This raises the question as to whether, in a 
situation of overabundant supply, there is still a need 
for quotas to be allocated to individual states in those 
areas where supplies are abundant. A case could be 
made for setting an overall TAC in those waters and 
allowing those states who have genuine outlets i.e. deep 
frozen herrings for export, to have the opportunity to 
catch their total requirements. Council, with whom 
the ultimate decision lies are asked to examine this 
question. 
In view of the very real difficulties that would lie in 
reaching a decision, an intermediate solution would 
appear the negotiation of quota swaps between the 
Member States concerned, with or without reciprocal 
concessions. 
No C 337/22 Official Journal of the European Communities 31. 12. 88 
In any case with a complete review of the quota system 
due in time for the end of 1992, it might be better to 
leave more fundamental decisions until the commence­
ment of such a review. 
2.6.2. The question of size does raise a problem in 
that the North Sea herring, which was at one time 
widely used for kippering, is now regarded as too small 
for this purpose and imports are used in their stead. 
Attention must be directed as to how consumers can 
be made aware of the good flavour of the North Sea 
herring so that processors once again have an incentive 
to use them. 
2.6.3. Size is not the sole criteria when it comes to 
processing. Fat content is all important. Also important 
is handling on board ship (protection against sunlight, 
wetting and fast chilling and careful handling) rancidity 
being a problem with herring. Attention is drawn to 
Table 2 of document COM(84) 629 final, which clearly 
explains the varying requirements of the industry. 
2.6.4. Although there are notable exceptions, it is 
unlikely that the industry will carry out the necessary 
measures to improve standards of their own volition. 
The Commission's intention to table proposals in the 
area of fish hygiene and marketing are therefore wel­
comed in principle. Perhaps also, consideration should 
be given to the introduction of a quality mark, as 
has been done for fruit, which gives the consumer 
confidence in product quality. 
2.6.5. It is also recommended that much stricter poli­
cing of landings and quality standards for all herrings 
be carried out by Member States. 
3. Development of intra-Community trade and of 
domestic consumption 
3.1. The Commission makes several concrete pro­
posals under this heading. 
3.1.1. Introduction of a regional withdrawal price 
as provided for in Article 12.2 of Regulation (EEC) 
No 3796/81, to assist those producers in landing areas 
far distant from the main centres of consumption. This 
would particularly enable them to supply processors at 
competitive prices and still obtain a proper return for 
their activities and such a system has previously been 
applied to a number of species including mackerel and 
at one time to herring. 
There would appear to be both political and commer­
cial objections on the grounds that: 
— it would distort competition, — it would only have a marginal effect upon the 
problem, 
— it would be a step backward from the principle of 
unified prices in the run up to 1992. 
The second objection may have merit but the other two 
are flawed. In considering the first, the distortion of 
competition, it must be remembered that there are 
groups of wholesalers and processors who are in a 
strong position in relation to producer organizations 
and can in consequence force prices down to unecon­
omic levels. This incidentally also has the serious effect 
of reducing the incentive of the fishermen to present 
their fish in the best possible manner. Clearly such 
interests would like the present situation to persist. 
Additionally, it should be pointed out that the main 
problem now and in the forseeable future is with distor­
tions caused by third country imports. 
It cannot be said that regional variations in price would 
be a step backward in a situation where they already 
exist: between 288 ECU per tonne in Denmark and 
165 ECU in the United Kingdom in 1986. This situation 
is likely to persist whilst the market price roughly 
equates to the withdrawal price as the difference is 
largely accounted for by the cost of transport to major 
markets. 
On the other hand such a major departure should not 
be contemplated without the most exhaustive evalu­
ation of cost/benefit effects. The Commission are there­
fore recommended to define the regions affected and to 
undertake the necessary studies with the least possible 
delay. 
Preferably the study should be widened to see if 
measures under Regulation (EEC) No 355/77 and suc­
cessive legislation to induce the establishment of more 
processing facilities where surplus stocks exist might 
prove either a more cost effective solution or one that 
might be complementary. The fact that the herring 
would have had value added through processing might 
lead to a situation where transportation costs became 
more bearable when expressed as a percentage of prod­
uct value. 
3.1.2. Widening the fourchette or margin of toler­
ance on the withdrawal price. 
There is currently a 5% positive and 10% negative 
margin although it has now been agreed to extend this 
at the positive end. This question clearly cannot be 
separated from that of regional withdrawal prices. In 
the absence of the latter there would appear to be a 
case for a widening of the margin to 10% positive and 
as much as 20% negative, even though this would be 
difficult with the financial compensation limit set at 
85% of the withdrawal price. Nevertheless, whilst pro­
viding some assistance, this would only have a marginal 
effect on the problems of the industry, possibly even 
31. 12. 88 Official Journal of the European Communities No C 337/23 
shifting the problems within the Community to differ­
ent areas. 
3.1.3. It is noted that the Council has agreed to 
include herring in the list of species to which the carry­
over premium can apply. Nevertheless it is not felt that 
this will deal with the real problem. In addition, 80% of 
the quantities taken into consideration for the carryover 
premium are included in the financial compensation 
scheme when fish are withdrawn from the market. 
Presently the rules governing the carryover premium 
are extremely restrictive (see Article 14 of the basic 
Regulation). Only 15% of annual quantities landed can 
qualify, also various processing methods have to be used 
which could cause difficulties. Such facilities cannot 
be maintained on the basis that they will be used 
infrequently and in an unpredictable manner. Conse­
quently the facility of the carryover premium has sel­
dom been used for species presently covered. 
Whilst a review of the regulation covering the carryover 
premium may be overdue, it is doubtful whether any 
changes would materially assist the stabilizing of the 
herring market. Where supplies with the correct fat 
content and other characteristics are being landed, pro­
cessors are already buying in stocks to enable them to 
continue processing throughout the year. Thus, even 
were sufficient storage capacity available, it is more 
unlikely that a better market situation would exist when 
stocks were put back onto the market. 
On the contrary, in view of the over-supply, after some 
time newly-landed catches would face competition from 
herring which had benefited from the premium. The 
overall effect of this would be to depress prices. 
Thus any further change or refinement in the Regu­
lation would only be effective if brought into force at 
the same time as measures to improve the capacity 
of the processing industry. It is important that any 
successive arrangements to those laid down in Regu­
lation (EEC) No 355/77 maintain the same width of 
application, preferably with enhanced funding. 
3.2. Other alternatives being canvassed include: 
3.2.1. More research into how to improve quality 
standards. This is essential if consumers are to have 
more confidence in the product. The Danish and Dutch 
are already carrying out research in this field. It would 
appear that a complementary Community research pro­
gramme, in this area, would be beneficial. 
3.2.2. Easing the effects, even temporarily, of the 
system of degressive payments. Having examined the 
problem it has been concluded that a widening of the fourchette, as recommended in 3.1.2, is a much more 
responsive mechanism and consequently preferable. 
3.2.3. The problem of klondijking has to be addres­
sed particularly as it has led to a reduction of export 
opportunities, particularly in Eastern Europe. Never­
theless, it is important that the Community does not 
over-react. 
Although it is true that prices obtained in selling to 
Klondijkers are not high, they do, given sensible con­
trols, provide a safety valve in conditions of abundant 
supplies. Also the geographical location of some of the 
herring ports means that there is no substitute for 
factory vessels if the catch is to be processed. During 
the last twelve months a tripartite committee has been 
in operation in Ireland. This has representatives of 
catchers, processors and the Government. Licences for 
Klondijkers are only issued when it is agreed that a 
situation of over-supply exists. Even then licences are 
only for a period of 24 hours, stipulate the port where 
loading can take place and specify the vessels which 
can make supplies. Such system, if it were generally 
applied, taking into account that different regions have 
different problems, could bring a beneficial system of 
control into effect. 
A growing number of EEC fishing concerns are begin­
ning to practice klondijking. Both advantages and dis­
advantages arise from this situation, which will need the 
urgent attention of the Commission and the Council. 
3.2.4. The basic problem with the Community her­
ring market is that except for a limited period of the 
year when there is a good demand for the supply of 
matjes or virgin herring for processing, there is an 
unhealthy dependence on one Community market. 
Whilst no blame can attach to the Member State in 
question, it is an inevitable consequence of such a 
situation where there is one predominant customer that 
there is a degressive effect on prices. Consequently the 
major priority must be to broaden the market which 
will, of itself, increase competition between processors 
and therefore market returns for the catchers. 
3.2.5. It is important that arrangements be made to 
counter the damage to consumer confidence caused by 
misleading media comment as in the case of nematodes. 
To this end, contingency plans should be made in 
conjunction with Member States to enable rapid coun­
ter-action to be taken. 
4. Introduction of promotional measures with a view 
to increasing domestic consumption 
This would seem a positive avenue to explore. The 
world 'promotional' as used in the Commission report 
No C 337/24 Official Journal of the European Communities 31. 12. 88 
should perhaps be replaced by 'marketing' as research 
and new product development, as well as the improve­
ment of raw material standards already referred to, 
would all play a part. Advertising alone is unlikely to 
be a solution. To revive the consumption levels of the 
early 70's would help (circa 640 000 tonnes in 1975) 
but, in some markets there has been a secular decline 
in fresh and smoked herring consumption since the first 
two decades of this century. 
It must also be remenbered that we may be seeing the 
need in the future to dispose of up to 800 000 tonnes 
per annum. 
In such a situation, there must be surprise at the Com­
mission's lack of urgency in trying to improve the 
climate by promotional measures. In particular why it 
took until 26 July 1988 to table implementary measures 
under Articles 29 (3) and 31 (2) of Regulation (EEC) 
No 4028/86 although the Council had earlier agreed to 
the allocation of promotional funds. 
It is to be hoped that now action has been taken, funds 
allocated will be sufficient to achieve the necessary 
objectives. Looking at the size of the fisheries budget 
this would appear doubtful. Consequently, the import­
ance to the peripheral regions of this programme should 
be taken into account and perhaps additional funds 
allocated from the enlarged regional and social funds. 
It would also seem logical that they be extended to 
cover sales outside the Community. If it is felt that this 
goes beyond the purpose of the original Regulation, 
then perhaps national aids could be allowed for this 
purpose, subject always to prior Commission approval. 
4.1. If herring consumption is to be increased then 
new products have to be introduced that meet the 
desires of today's consumers. Market research has 
shown that younger housewives do not like handling 
and preparing certain forms of whole wet fresh fish in 
the kitchen. This particularly applies to herring with 
its definite aroma. Older housewives lost the habit of 
purschasing fresh herring during the shortages of the 
1970's. Thus there is no realistic chance of reviving 
traditional consumption levels of fresh herring. 
Additionally, other developments in the field of hygiene 
regulations will make it impossible to place fresh her­
ring on the market in at least one Member State, pre­
viously a major consumer. 
4.1.1. The only realistic options are: 
— the development of new convenience foods which 
have herring as a major ingredient, — the introduction of herring in a form whereby it is 
ready for cooking i.e. whole but gutted and pre­
pared, with added garnish such as peppercorns, etc. 
In the meantime only limited generic advertising with 
a high below-the-line component (in-store demon­
strations, etc.) is likely to prove cost effective. 
4.1.2. It has to be recognized that these products will 
be trying to enter a highly competitive market, i.e. that 
for grocery where buying is highly centralized. Only if 
major supermarkets and catering outlets are prepared 
to stock these items will significant additional sales 
result. In turn, especially in the case of supermarkets, 
they will only place the goods on their shelves if they 
believe that they will attract the housewife and they are 
supported by a heavy level of promotional activity. In 
practice this means that only if major food manufac­
turers see that this is a profitable area to exploit will 
this exercice be successful. 
4.1.3. This process is too important to be left to 
chance. The Commission is recommended to fund prod­
uct development research in independent institutes. 
When products emerge from this process pilot market 
research studies should be carried out to guage con­
sumer response. When favourable in respect of a par­
ticular product or product group, the test results should 
be communicated on a transparent basis to all associ­
ations of food manufacturers within the Community. 
4.1.4. When products are introduced following the 
above exercise it will be for the Commission to judge 
whether or not further support is required in order to 
ensure the successful lauch of the products in question. 
This is likely to have to be decided on a case by case 
basis. 
4.2. Claims have been made that a substantial mar­
ket for herring, of the correct quality, could exist in 
southern Member States. This is felt to be questionable 
as the product would have to be frozen and, as such, 
compete with locally caught fresh fish. Nevertheless, 
no potential market opportunities should be dismissed 
without investigation. 
It would seem feasible for the Commission to have a 
market study undertaken to judge the true potential. 
Great care, however, must be taken to ensure that a 
market for herrings is not developed purely at the 
expense of other varieties in surplus such as sardines. 
Some concern must be expressed at the potential adver­
tising costs of developing what is effectively a new 
market. 
5. Export refunds and the encouragement of exports 
5.1. The recent export achievements of one Member 
State, made on a fully commercial basis, show that 
31. 12. 88 Official Journal of the European Communities No C 337/25 
a widespread scheme of export refunds is probably 
unnecessary. On the other hand evidence has been 
presented which shows that if there was a limited 
scheme providing export refunds on a reducing basis 
over a five year period, this could be of value. Processors 
once engaged in exports would be likely to continue as 
they have with mackerel on a marginal cost pricing 
basis but would not sell at such prices in the first 
instance when they would have all the additional costs 
of establishing a market. 
5.2. There is a case for considering the provision of 
funds for the general advertising of herring to the trade 
and consumers in both new markets and those where 
Community sales are presently at a low level. 
5.3. Such funds should only be allocated for frozen 
products from shore-based processors using fish caught 
by Community vessels or both caught and processed 
on board the same Community vessel. 
5.4. Additionally it would seem that there are mar­
kets for frozen and canned herring in both undeveloped 
and Middle East markets where an unsatisfied demand 
exists. On the other hand serious problems of finance 
and, in some countries, difficulties with receiving autho­
rities effectively prevent this trade materialising. The 
financial problem could probably be overcome by some 
form of insurance scheme partially or wholly financed 
by premiums payable by the exporters. Those with 
receiving authorities clearly need attention from the 
Council and Commission so that they can enter into 
bilateral negotiations with those markets where the 
problem exists. 
6. Industrial fishing 
6.1. Whilst industrial fishing for herring is only 
occurring in one area on an informal basis, it would be 
more satisfactory if this were properly regulated and 
provision made for future industrial fishing. 
6.2. If in future a point is reached where there is 
a TAC, purely as an example, of 700 000 tonnes in 
Community waters with an underutilized portion in 
excess of perhaps 100 000 tonnes, the situation would 
be different. Particularly as the fishmeal industry is 
developing products with a higher added value and in 
consequence has a brighter economic future in the 
medium term. 
6.3. Even so, full account will have to be taken of 
environmental considerations as well as those of fishery 
conservation. The situation in regard to the North Sea 
sprat will have to be taken into account at the time. 6.4. The strictest control measures are already and in 
the future clearly necessary and should, as a minimum, 
include the following provisions: 
— The administration should be clearly under national 
control. 
— Boats should be individually licensed. 
— These boats should be engaged in normal fishing 
but allowed an additional quota which can be sup­
plied for industrial purposes. 
— All deliveries to fishmeal plants should be regarded 
as being of herring and counted against this quota 
unless the vessel in question requests specific inspec­
tion to show that another species, i.e. gurnard is 
being landed. 
7. Alternative uses 
The Committee is not in a position to make a major 
contribution in this area. For example, it is unable to 
comment on the Commission's imaginative suggestion 
regarding the use of herring gonads in the treatment of 
Aids. 
On the other hand, there are certain areas in which 
positive action could be contemplated; 
7.1. Making the knowledge of the possibility of using 
herring instead of white fish in the production of Surimi 
more widely known, as this is a rapidly growing market. 
7.2. The encouragement and even possible support 
of the research already being conducted into the wider 
use of fish oils for pharmaceutical purposes. In New 
Zealand and in Canada successful advertising cam­
paigns have been carried out to the public to promote 
the varieties of Omega H3 in lowering cholesterol levels, 
etc. which had a positive effect on the consumption 
of fish oils. This would be particularly useful in the 
utilization of smaller-sized fish. 
7.3. It is understood that there may be a greater use 
of fish oils as an ingredient in food products because 
of considerations of health. Investigations should be 
carried out to see how this could be encouraged. 
7.4. The increase in fish farming, particularly of 
salmon, means that there is an increasing need for 
fishmeal to feed the stock. At current rates of growth, 
Ireland, in two years' time, will need 150 000 tonnes of 
herring if this were used as the sole feedstock. This 
would obviously provide an additional usage providing 
a high value product even at second hand. 
No C 337/26 Official Journal of the European Communities 31. 12. 88 
8. Social factors 
In all matters related to fisheries, it is to be remenbered 
that one fisherman at sea supports six jobs on shore. 
When looking at the herring market particularly in 
Ireland and Scotland, which accounts for over 95 % of 
the United Kingdom catch, and Northern Denmark, 
this activity is being conducted in peripheral regions. It 
is therefore a vital source of both employment and 
revenue. In Northern Denmark it would appear that at 
least 25 % of all employment is dependent on the her­
ring industry. 
Through various factors including the problems with 
nematodes in Germany, the Irish industry is also facing 
grave problems to the extent that at least two processing 
factories have closed their doors. There is virtually no 
alternative employment in this area. 
8.1. The Community has to decide whether it is 
going to allow the present virtually unrestricted level 
of imports (70% of these are landed in Denmark) so 
allowing the local industry to gradually wither away, 
or take action. If not, it will then be faced with the 
problem of spending considerable sums of money in 
order to try to attract alternative employment. 
8.2. It would seem better whilst avoiding wholesale 
subsidy to see what could also be done through the 
Regional and Social Funds to prevent this totally unsat­
isfactory situation arising. 
9. Conclusions 
This investigation has clearly demonstrated that there 
are no instantaneous or miracle solutions. Nor that 
tinkering with the Community mechanisms governing 
the herring market will have more than a marginally 
beneficial effect. Our recommendations are: 
9.1. The customs nomenclature should be altered so 
as to distinguish between whole herring and herring 
flaps. 
9.2. GATT quotas should be expressed in terms of 
whole equivalent. 
9.3. A TAC should be allocated in zone 2 a where 
herring of the quality required by the processing indus­
try are located. 
9.4. Greater attempts should be made to enforce 
quality standards on imports, particularly those arriv­
ing by road transport. 9.5. Arrangements whereby substantial quantities of 
herring, over and above GATT quotas, are permitted 
to be imported duty free, should be renegotiated. 
9.6. Customs authorities of the Member States 
should carry out stringent checks on the premises of 
importers to see that the regulations regarding the refer­
ence price are being observed. 
9.7. All vessels from third countries landing fresh or 
processed on board fish at Community ports should 
have to be calibrated in the same manner as Community 
vessels. 
9.8. To avoid disturbance of the market by imports, 
changes of the nature of those suggested in 2.5.3 should 
be examined. 
9.9. Either investigations should be instituted into 
unfair subsidisation of imports or a request should be 
made for the establishment of a GATT panel to exam­
ine the matter. 
9.10. There should be a system of control on the 
arrivals and landings of fishing vessels from third 
countries. 
9.11. A quality mark, as in the case of fruit, should 
be instituted for herrings meeting strict quality criteria, 
so increasing consumer confidence. This should go hand 
in hand with the much stricter policy, of existing quality 
standards. 
9.12. The Commission should examine the cost/ben­
efit effects of introducing a regional withdrawal price 
system as provided for in Article 12.2 of Regulation 
(EEC) No 3976/81. This should be combined with a 
study as to whether the encouragement of more process­
ing facilities in areas where surplus stocks exist might 
be helpful. 
9.13. A widening of the fourchette as suggested 
in 3.1.2. 
9.14. Measures to make the carryover premium more 
effective by encouraging the expansion of the capacity 
of the processing industry should be instituted. 
9.15. A Community research programme into the 
improvement of quality standards should be instituted. 
9.15.1. To inhibit a repetition of misleading scares 
like that concerning nematodes, the Commission in 
conjunction with Member States should devise a contin­
gency plan for bringing the truth rapidly before the 
public. 
31.12.^ C^fficial]ournal of the European communities ^oCh337B27 
9.1^. Licensing of ^londi^ers^mamanner roughly 
equivalent to that used in Ireland^ should be considered^ 
as should the situation relating to community ^lonD 
diners. 
917 Asfunds under Articles29 ^ and31 ^ 
of Regulation ^EEC^ ^o ^2^^ for promotional 
measures are lively to prove insufficient additional 
amounts from the Regional and^or social Eund should 
he allocated in qualifying regions. 
9.1^. The scope of the promotional programme 
should he extended to allovB the use of funds vBith 
proper safeguards^ outside the community. 
9.19. Lhe community should fund research into the 
development of nev^consumer products based on her^ 
ring and the results should be communicated to associD 
ations of food manufacturers in Member states. 
9.2t^. Theclaimthatamar^etforhernngexistsin 
southern Member states should be examined by means 
of market research. 
9.21. Export refunds shouldbeprovidedunder the 
conditions recommended in sections^.lto^.3. 
Poone at Brussels^ 27 COctober 19^. 9.22. Means of overcoming the obstacles to the 
export of frozen and canned herring to Middle Eastern 
markets and underdeveloped countries should be 
devised. 
9.23. Provision should be made for the possibility of 
industrial fishing be allowed in the future and the 
existing system regulated. 
9.2^. The encouragement of alternative uses for her 
ring and herring oil in sunm4 pharmaceutical products 
and foodstuffs should be undertaken positively. 
9.2^. The use of herring asafeedstocl^ for fish farm 
ing requires consideration. 
9.2^. Early attention must be given to the social 
problems that v^ould arise in the peripheral regions 
due to a further decline in the herring industry and 
appropriate measures tal^en as a matter of some 
urgency. Particularly as it v^illtal^e time for the adop 
tionofthema^ontyof the other recommendations to 
tal^e effect. 
oGiven the imagination and the v^illofboth commission 
and Council it is believed that apositiveprogramme 
can be developed in respect of the community herring 
market. It is essential that suchavaluable food resource 
providing vitalemploymentinpenpheralareasisnot 
allowed to go to v^aste.