Study, evaluation of the marketing standards framework for fishery and aquaculture products : final report : annexes.
Date: 2019-11-25
Institutions: Directorate-General for Maritime Affairs and Fisheries
Subjects: aquaculture, fisheries policy, fishery product, marketing, report

Study – Evaluation of the 
marketing standards 
framework for fishery and 
aquaculture products 

Specific Contract No. 5 

under Framework contract EASME/EMFF/2016/029 

Final Report - Annexes 

Consortium led by Coffey International 

2019 

Fisheries 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products 

Directorate-General for Maritime Affairs and Fisheries  

2019 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

EUROPEAN COMMISSION 

DG MARE - Directorate-General for Maritime Affairs and Fisheries 

Directorate A — Maritime Policy and Blue Economy 

Unit A.4 — Economic Analysis, Markets and Impact Assessment 

E-mail: mare-A4@ec.europa.eu 

European Commission 
B-1049 Brussels 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Study – Evaluation of the 
marketing standards 
framework for fishery and 
aquaculture products 

Specific Contract No. 5 

under Framework contract EASME/EMFF/2016/029 

Final Report - Annexes 

Directorate-General for Maritime Affairs and Fisheries  

2019 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Table of content 

Annex 1. 

Intervention logic of the CMO Regulation (Regulation (EC) 1379/2013) ............... 1 

Annex 2.  Description of control activties: control regulations, activities and principles for 

fishery and aquaculture products ............................................................................. 2 

Annex 3. 

List of other standards for processed products .................................................. 6 

Annex 4.  CODEX Standards for Fishery Products ............................................................ 7 

Annex 5.  Comparison between codex and EU marketing standards ................................... 9 

Annex 6.  National Laws and regulations for marketing of fishery products ....................... 13 

Annex 7.  Questionnaire for the National Authorities ...................................................... 18 

Annex 8.  Summary of answers to the national authorities survey ................................... 28 

8.1.  Administrative organization, control and monitoring ........................................ 28 
8.2.  Compliance ................................................................................................ 31 
8.3.  Main impacts .............................................................................................. 34 
8.4.  Coherence with other regulations and standards ............................................. 35 
8.5.  Potential for simplification ............................................................................ 36 

Annex 9. 

List of interviews and contributions ............................................................... 37 

Annex 10. 

Annex 11. 

Discussion guides for case studies ................................................... 40 

Summary of case studies ................................................................ 53 

11.1.  Fresh products from fisheries ....................................................................... 54 
11.2.  Canned sardines and tunas .......................................................................... 57 
11.3.  Aquaculture products (fresh) ........................................................................ 59 
11.4.  Other processed products ............................................................................ 60 

Annex 12. 

Annex 13. 

Questionnaire for the recommendations ........................................... 61 

Summary of answers to the consultation on recommendations ............ 64 

Annex 14. 

public consultation and as a result of the targeted consultations ................................ 73 

Summary  and  analysis  of  the  contributions  received  during  the  open 

14.1.  Outline of the consultation strategy............................................................... 73 
14.2.  Profile of stakeholder groups ........................................................................ 76 
14.3.  Short description of the methodology and tools used to process the data ........... 77 
14.4.  Description of the results of the consultation phase ......................................... 78 
14.5.  Explanation on how the information gathered has been taken into account in the 

evaluation work .......................................................................................... 83 

Annex 15. 

Annex 16. 

Annex 17. 

Annex 18. 

Evaluation questions matrix ............................................................ 85 

Fish sold by quality grades in a sample of auctions ............................ 99 

Data on inspections and infringements in joint Deployment plans ...... 100 

Availability of information on conservation of species under marketing 

standards but without mcrs ................................................................................. 101 

Annex 19. 

Comparison between Minimum marketing sizes and MCRs ................ 103 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

List of tables 

Table 1: Number of administrative entities involved in the control and implementation of 
marketing standards ......................................................................................28 

Table 2: Answer to the question : How much time do inspections take on average ? .....30 

Table 3: Number of FTE dedicated to the control of marketing standards in 2017 .........30 

Table 4: Evolution of the number of anomalies observed ...........................................31 

Table 5: Evolution of volumes of fish/fish products inspected .....................................32 

Table 6: Number of consulted stakeholders (persons participating in interviews and focus 
groups) ........................................................................................................54 

Table 7: Answers to the question: do you agree with the following recommendations? ..65 

Table 8: Answers to the question: do you agree with the following recommendations? ..68 

Table 9: Proportion of fish sold per freshness grade (by weight) in Hanstholm auction 2014-
17 ................................................................................................................99 

Table 10: Proportion of fish sold per freshness grade (by weight) in Nord auction 2014-18
 ...................................................................................................................99 

List of figures 

Figure  1:  Answer  to  the  question  :  Are  controls  of  marketing  standards  combined  with 
other types of controls ? .................................................................................29 

Figure 2: Answer to the question: How have evolved ... ? ..........................................31 

Figure 3 : Ranking of the type of anomalies or irregularities from the most frequent to the 
least frequent ................................................................................................33 

Figure 4 : Extent to which EU marketing standards contribute to ...? ..........................34 

Figure 5: Answer to the question: are there other public standards / codes of practice for 
fishery and aquaculture products? ....................................................................35 

Figure 6: Answer to the question: do you think the following could be simplified without 
hindering the achievements of EU marketing standards?.....................................36 

Figure 7: Breakdown of respondents by type of organisation ......................................64 

Figure 8: Breakdown of respondents by sector .........................................................65 

Figure 9: Answers to the question: Do your clients already include product specifications 
related to sustainability (environmental and/or social)? ......................................70 

Figure 10: Distribution of contributions by Member States .........................................76 

Figure 11: Distribution of contributions by sector ......................................................77 

Figure 12 : Contribution of the different subsectors for the targeted consultations ........77 

Figure 13: Landings by quality grade on Guilvinec auction 2014-17* ..........................99 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Figure 14: Number of inspections and infringements on Joint Deployment Plans 2012-2017
 ................................................................................................................. 100 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Table of acronyms 

Acronyms/ 
Abbreviations 
AC 
AFNOR 
CAFIA 
CFP 
CMO 
CSR 
DG MARE 
EASME 
EMFF 
EQ 
EQM 
EU 
EUMOFA 

IUU 
JC 
Lwe 
MAC 
MCRS 
MMS 
MSC 
MS 
NA 
OPC 
PDO 
PEFA 
PO 
RASFF 
SCM 
SME 
TOR 

Definition 

Advisory Councils 
French standards association (Association Française de normalisation) 
Czech Agriculture and Food Inspection Authority  
Common Fisheries Policy 
Common Market Organisation 
Corporate Social Responsibility 
Directorate-General for Maritime Affairs and Fisheries 
Executive Agency for Small and Medium-sized Enterprises 
European Maritime Fisheries Fund 
Evaluation Question 
Evaluation Questions Matrix 
European Union 
European  Union  Market  Observatory  for  Fisheries  and  Aquaculture 
products 
Illegal, Unreported and Unregulated 
Judgement criteria  
Live Weight Equivalent 
Market Advisory Council 
Minimum Conservation Reference Size  
Minimum Marketing Size 
Marine Stewardship Council  
Member State 
National Authority 
Open Public Consultation 
Protected Designation of Origin 
Pan European network of Fish Auctions 
Producer organisation 
Rapid Alert System for Food and Feed  
Standard Cost Model 
Small and Medium-sized Enterprise 
Terms of Reference 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 1. 

INTERVENTION LOGIC OF THE CMO REGULATION (REGULATION (EC) 1379/2013) 

       Specific contributions of marketing standard to the CMO objectives. 

1 

 
 
        
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 2.  DESCRIPTION OF CONTROL ACTIVTIES: CONTROL REGULATIONS, ACTIVITIES AND PRINCIPLES FOR FISHERY 

AND AQUACULTURE PRODUCTS  

The following table presents the control activities that have to be carried out at the different stages of the supply chain of fisheries and 
aquaculture products. 

Topic  

Regulation 
reference 

Item(s) to be controlled  

Objectives  

Control activities /principles  

Conservation 
measures  

Reg (EC) No 
1380/2013 

MRCS  

Marketing 
standards  

Reg (CE) No 
2406/1996 
– Art. 7 

Minimum marketing sizes  

Ensuring the protection 
of juveniles of marine 
organisms  

The control shall be based on the primacy of 
the MCRS over the minimum marketing 
sizes.  

Ensure that the 
standards apply without 
prejudice to health rules 
and rules adopted  as 
part of stock 
conservation 

- 

- 

- 

is  no  MCRS,  the  minimum 

if  there 
marketing size applies,  
if there is no minimum marketing size, the 
MCRS applies,  
if  there  is  both  minimum  marketing  size 
and a MCRS, the MCRS applies.  

Stage in the supply 
chain 

First 
sale 

Retail  All 

stages 

x 

x 

x 

x 

x 

x 

Size categories  

Improve products quality  

Make marketing easier  

Define uniform trade 
characteristics for the 
products across the 
entire Community market 
in order to prevent 
distortions of competition  

Freshness categories  

The lots presented for sale must be 
homogenous.  

x 

Small lots could not be homogenous. In this 
case, the lot shall be placed in the lowest 
size category represented therein.  

The size category and presentation must be 
clearly and indelibly marked on labels affixed 
to the lot.   

The lots presented for sale must be 
homogeneous. Small lot could not be 
homogenous. In this case, the lot should be 
placed in the lowest category represented 
therein.  

Products classified as “not admitted” cannot 
be sold.  

x 

x 

x 

Marketing 
standards  

Reg (CE) No 
2406/1996 
– Art. 8 

Marketing 
standards  

Reg (CE) No 
2406/1996 
– Art. 5  

Reg (EC) No 
1224/2009 
– Art. 57  

2 

 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Topic  

Regulation 
reference 

Item(s) to be controlled  

Objectives  

Control activities /principles  

Stage in the supply 
chain 

First 
sale 

Retail  All 

stages 

Marketing 
standards  

Reg (CE) No 
2406/1996 
– Art.11 

Compliance with marketing 
standards 

Information to be marked in 
packages:  

Ensure compliance with 
the same requirements 
both for imports and 
products originating from 
within the Union 

Inspections shall control the compliance of 
products with the marketing standards as 
well as the presence of the information 
clearly and legibly marked in packages.    

x 

x 

x 

Freshness categories must be clearly and 
indelibly marked on labels affixed to the lot.  

-  country  of  origin,  printed  in 
Roman  letters  at  least  20  mm 
high,  

-  scientific  name  of  product  and 

its trade name,  

-  presentation,  
freshness and size categories, 
- 
-  net  weight  in  kilograms  of 

products in the package,  

-  date  of  grading  and  date  of 

dispatch,  

-  name and address of consignor. 

Traceability  

Reg (EC) No 
1224 / 2009 
– Art. 58  

The minimum labelling 
information requirements for all 
lots: 

- 

- 

identification  number  of  each 
lot 
identification number and name 
of fishing vessel  

Contributing to the 
traceability of products 
and the access to clear 
and comprehensive 
information for 
consumers  

All lots of fisheries and aquaculture products 
shall be traceable at all stages of production, 
processing and distribution, from catching or 
harvesting to retail stage.  

Products placed on the market in the 
Community shall be adequately labelled to 
ensure the traceability of each lot.  

x 

x 

x 

-  FAO code of each species  
-  date of production  
-  quantities  of  each  species  (net 
the  number  of 

weight  or 
individuals) 
 name and address of suppliers 
information to consumers  

- 
- 

3 

 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Topic  

Regulation 
reference 

Item(s) to be controlled  

Objectives  

Control activities /principles  

Consumer 
information  

Reg (EC) No 
1379/2013  

Traceability  

Reg (EC) No 
1224/2009 

Facilitating consumer 
access to information on 
fishery and aquaculture 
products  

All lots of fisheries and 
aquaculture products 
shall be traceable at all 
stages of production, 
processing and 
distribution, from 
catching or harvesting to 
retail stage. 

-  whether  the  products  have 
been previously frozen or not.  
-  commercial  designation  of  the 
species and its scientific name  

-  production method 
-  area  of  production  (and  the 

category of fishing gear) 

-  whether  the  product  has  been 

defrosted  

-  date of minimum durability.  

The minimum labelling and 
information requirements for all 
lots shall include:  

-  the  identification  number  of 

each lot; 

-  the  identification  number  and 
name  of  the  vessel  or  the 
aquaculture production unit; 
-  the  FAO  alpha-3  code  of  each 

species; 

-  the quantities of each species in 
in  net 
kilograms  expressed 
weight  or,  where  appropriate, 
the number of individuals; 

-  the  name  and  address  of  the 

suppliers; 

-  the  information  to  consumers 
provided  for  in  Article    8  of 
Regulation (EC) No 2065/2001.  

Stage in the supply 
chain 

First 
sale 

Retail  All 

stages 

-  

X 

Fisheries and aquaculture products placed on 
the market in the Community shall be 
adequately labelled to ensure the traceability 
of each lot. 

x 

x 

x 

Food and feed 
low, rules on 
animal health 
and welfare  

Reg (EC) No 
625/2017  

Reg (EC) 
882/2004 

Controls and other official 
activities performed to ensure the 
application of food and feed law, 
rules on animal health and 
welfare. 

Preventing, eliminating or 
reducing to acceptable 
levels risks to humans 
and animals.  

Official controls shall be carried out at any of 
the stages of production, processing and 
distribution for feed or food and of animals 
and animal products.  

x 

x 

x 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Stage in the supply 
chain 

First 
sale 

Retail  All 

stages 

x 

x 

x 

Evaluation of the marketing standards framework for fishery and aquaculture products  

Topic  

Regulation 
reference 

Item(s) to be controlled  

Objectives  

Control activities /principles  

Guaranteeing fair 
practices in feed and food 
trade and protecting 
consumer interests, 
including feed and food 
labelling and other norms 
of consumer information. 

Hygiene rules  

Reg (EC) 
854/2004  

Official controls of fishery 
products are to include at least 
the following elements to ensure 
they are in accordance with EU 
legislations:  

-  Organoleptic examinations  
-  Freshness indicators: when the 
organoleptic 
examination 
reveals  any  doubt  as  to  the 
freshness  of  fishery  products, 
samples  may  be  taken  for 
laboratory analysis.  

-  Histamine 
-  Residues and contaminants:  
-  Microbiological checks  
-  Parasites  
-  Poisonous 

i)  poisonous 

fishery  products: 
checks to take place to ensure 
that: 
fish  of 
specific families are not placed 
on the market, and ii) to ensure 
that fishery products placed on 
the  market  do  not  contain 
toxins  dangerous  to  human 
health.   

5 

Official controls on the production and 
placing on the market of fishery products are 
to include, in particular 

-  a  regular  check  on  the  hygiene  conditions 

- 

of landing and first sale, 
inspections  at  regular  intervals  of  vessels 
and  establishments on  land,  including  fish 
auctions  and  wholesale  markets  to  check 
whether the conditions for approval are still 
fulfilled,  whether  the  fishery  products  are 
handled  correctly,  for  compliance  with 
hygiene and temperature requirements and 
the cleanliness of establishments, including 
vessels, and their facilities and equipment 
and staff hygiene.  

-  Checks 

on 

storage 

and 

transport 

conditions.  

Controls have to take place at all stages of 
production, processing and distribution.  

 
 
 
 
 
 
 
 
 
  
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 3. 

LIST OF OTHER STANDARDS FOR PROCESSED PRODUCTS  

MS 

Type of 
standards 

Concerned products 

Austria  

National 
law  

The national law provides definitions for various products, including 
frozen fish fingers, marinated herring and surimi packs 

Germany   National 

law  

The national law provides definitions for few products, including 
frozen fish fingers (similar requirements as in Austria), frozen fish 
fillets and sauces used with fishery products.  

Spain  

National 
law  

France  

AFNOR 
voluntary 
use 

National laws provide some general definitions on the terms “fresh”, 
“frozen”, “salted”, etc. and there are two specific laws that establish 
quality standards for cooked and frozen mussels, cockles and 
clams and for canned mussels, clams and scallops, an important 
segment of the fish processing industry in Spain. 

NF V45-069 Canned product with topping (2013) – Canned tuna and 
sardine  

NF V45-071 Canned sardine « Traditional preparation » (2015) – 
Canned sardine 

NF V45-070 Level of fulfilment of cans for canned tuna (1997) – 
Canned tuna  

NF V45-065 Saumon fumé (décembre 2012) – Smoked salmon  

NF V45-064 Conserves appertisées de maquereaux (août 2013) – 
Canned mackrel 

NF V45-073 Rillettes, terrines et mousses d’animaux aquatiques 
(septembre 2013) – Spreadable / pâtés  

NF V45-066 Anchois salés et préparations à base d’anchois salés 
(septembre 2014) – Salted Anchovy  

NF V45-068 Surimi et spécialités à base de surimi (février 2016) – 
Surimi  

NF V45-067 Filets de hareng fumé (septembre 1996) – Smoked 
herring flet 

NF V45-074 Portions de filet de poisson surgelé (avril 1999) - Frozen 
pieces of fish (filled, back..) 

Professional 
decision 

N°39 – Conserves de crustacés et de mollusques - 18/01/1955 - 
Canned crustaceans and molluscs 

N°61 – Fabrication des semi-conserves – sauf « Anchois » - Semi-
preserved products (except anchovy) 

N°64 – Article 3 « Bouillabaisses » - 16/10/2017 - Bouillabaisse 
(traditional meal from Southern part of France) 

Code of 
conducts 

Soupes de poissons, bisques de crustacés et potages à base de 
poisson - Soup 

Tarama et produits dérivés - Tarama and derived products 

Crevettes vendues réfrigérées - Shrimps sold chilled 

Anchois salés et préparations à bases d’anchois salés - Salted 
anchovy 

6 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 4. 

CODEX STANDARDS FOR FISHERY PRODUCTS 

CODE No. 

Title 

Year of 
latest 
Version 

Year of 
Adoption 

Years of 
Revision 

Years of 
Amendments 

CODEX 
STAN 
1981 

Standard 
Salmon 

3-

for  Canned 

2011 

1981 

CODEX 
STAN  36-
1981 

Standard for Quick Frozen 
Finfish, Uneviscerated and 
Eviscerated 

2017 

1981 

1991, 
1995 

1995, 
2017 

Standard 
Shrimps or Prawns 

for  Canned 

2016 

1991 

1995 

Standard for Canned Tuna 
and Bonito 

2016 

1981 

1995 

Standard for Canned Crab 
Meat 

2016 

1981 

1995 

Standard for Quick Frozen 
Shrimps or Prawns 

2017 

1981 

Standard 
for  Canned 
Sardines  and  Sardine-
Type Products 

2016 

1981 

Standard for Quick Frozen 
Lobsters 

2017 

1981 

Standard 
Finfish 

for  Canned 

2016 

1981 

1995, 
2017 

1995, 
2007 

1995, 
2004, 
2017 

1995 

2011 

2013 

2011, 
2016 

2011, 
2016 

2011, 
2016 

2011, 
2014 

1979, 
2011, 
2016 

2011, 
2014 

2011, 
2016 

2013, 

2013, 

2013, 

2013, 

1989, 
2013, 

2013, 

2013, 

Standard for Quick Frozen 
Blocks  of  Fish  Fillets, 
Minced  Fish  Flesh  and 
Mixtures  of  Fillets  and 
Minced Fish Flesh 

Standard for Quick Frozen 
Fish Sticks (Fish Fingers), 
Fish  Portions  and  Fish 
Fillets  -  Breaded  or  in 
Batter 

Standard  for  Salted  Fish 
and  Dried  Salted  Fish  of 
the  Gadidae  Family  of 
Fishes 

Standard  for  Dried  Shark 
Fins 

2017 

1989 

1995, 
2017 

2011, 
2014, 2016 

2013, 

2017 

1989 

1995, 
2004, 
2017 

2011, 
2014, 2016 

2013, 

2016 

1989 

1995, 
2005 

2011, 
2016 

2013, 

1993 

1993 

na 

na 

CODEX 
STAN  37-
1991 

CODEX 
STAN  70-
1981 

CODEX 
STAN  90-
1981 

CODEX 
STAN  92-
1981 

CODEX 
STAN  94-
1981, 
formerly 

CODEX 
STAN  95-
1981 

CODEX 
STAN  119-
1981 

CODEX 
STAN  165-
1989 

CODEX 
STAN  166-
1989 

CODEX 
STAN  167-
1989 

CODEX 
STAN  189-
1993 

7 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

CODE No. 

Title 

Year of 
latest 
Version 

Year of 
Adoption 

Years of 
Revision 

Years of 
Amendments 

CODEX 
STAN  190-
1995 

CODEX 
STAN  191-
1995 

CODEX 
STAN  222-
2001 

CODEX 
STAN  236-
2003 

Standard for Quick Frozen 
Fish Fillets 

2017 

1995 

2017 

2011, 
2014 

2013, 

Standard for Quick Frozen 
Raw Squid 

1995 

1995 

na 

na 

Marine 

Standard 
from 
Freshwater 
Crustaceans 
Molluscan Shellfish 

for  Crackers 
and 
Fish, 
and 

2016 

2001 

na 

2011, 
2016 

2013, 

Standard  for  Boiled  Dried 
Salted Anchovies 

2003 

2003 

na 

na 

CODEX 
STAN  244-
2004 

Standard 
Atlantic 
Salted Sprat 

for 
Herring 

Salted 
and 

2016 

2004 

na 

2011, 
2016 

2013, 

CODEX 
STAN  291-
2010 

CODEX 
STAN  292-
2008 

CODEX 
STAN  302-
2011 

CODEX 
STAN  311-
2013 

CODEX 
STAN  312-
2013 

Standard 
Caviar 

for  Sturgeon 

2010 

2010 

na 

na 

Standard for Live and Raw 
Bivalve Molluscs 

2015 

2008 

2014, 
2015 

2013 

Standard for Fish Sauce 

2013 

2011 

na 

2012, 2013 

2016 

2013 

na 

2016 

2016 

2013 

na 

2016 

for  Smoked 
Standard 
Fish, 
Smoke-Flavoured 
Fish  and  Smoke-Dried 
Fish 

Standard for Live Abalone 
and for Raw Fresh Chilled 
for 
or  Frozen  Abalone 
Direct Consumption or for 
further Processing 

CODEX 
STAN  315-
2014 

Standard  for  Fresh  and 
Quick Frozen Raw Scallop 
Products 

2017 

2014 

2017 

2016 

8 

 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 5. 

COMPARISON BETWEEN CODEX AND EU MARKETING STANDARDS  

Items  

Codex 

EU MKTS 

Tuna and bonito 

Species 

- Thunnus alalunga 
- Euthynnus affinis 
- Thunnus albacares 
- Euthynnus alleteratus 
- Thunnus atlanticus 
- Euthynnus lineatus 
- Thunnus obesus 
- Katsuwonus pelamis (syn. Euthynnus 
pelamis) 
- Thunnus maccoyii 
- Sarda chilensis 
- Thunnus thynnus 
- Sarda orientalis 
- Thunnus tonggol 
- Sarda sarda 

Definition of 
Solid (skin-
on or 
skinless) 

Fish cut into transverse segments 
which are placed in the can with the 
planes of their transverse cut ends 
parallel to the ends of the can. The 
proportion of free flakes or chunks 
shall not exceed 18% of the drained 
weight of the container. 

Definition of 
Chunk  

Definition of 
Flake or 
flakes  

Pieces of fish most of which have 
dimensions of not less than 1.2 cm in 
each direction and in which the original 
muscle structure is retained. The 
proportion of pieces of flesh of which 
the dimensions are less than 1.2 cm 
shall not exceed 30% of the drained 
weight of the container. 

A mixture of particles and pieces of fish 
most of which have dimensions less 
than 1.2 cm in each direction but in 
which the muscular structure of the 
flesh is retained. The proportion of 
pieces of flesh of which the dimensions 
are less than 1.2 cm exceed 30% of 
the drained weight of the container. 

Definition of 
Grated or 
shredded  

A mixture of particles of cooked fish 
that have been reduced to a uniform 
size, in which particles are discrete and 
do not comprise a paste. 

9 

(a) Albacore or longfinned tuna (Thunnus 
alalunga) 
(b) Yellowfin tuna (Thunnus (neothunnus) 
albacores) 
(c) Bluefin tuna (Thunnus thynnus) 
(d) Bigeye tuna (Thunnus (parathunnus) 
obesus) 
(e) Other species of the genus Thunnus. 
(Euthynnus (Katsuwonus) pelamis). 
(a) Atlantic bonito (Sarda sarda) 
(b) Pacific bonito (Sarda chiliensis) 
(c) Oriental bonito (Sarda orientalis) 
(d) Other species of the genus Sarda. 
Atlantic little tuna (Euthynnus alleteratus) 
(b) Eastern little tuna (Euthynnus affinis) 
(c) Black skipjack (Euthynnus lineatus) 
(d) Other species of the genus Euthynnus 
(a) Frigate mackerel (Auxis thazard) 
(b) Auxis Rochei. 

The musculature is cut transversely and 
is presented as a whole slice formed by a 
single portion or reconstituted by the 
compact assembly ,of several portions of 
flesh. The presence of flakes, accounting 
for up to 18 % of fish weight, shall be 
tolerated. However, when the 
musculature is canned raw, the presence 
of flakes shall be prohibited ; fragments 
of flesh may be added as makeweight ; 

Fragments of flesh, the initial muscle 
structure of which is maintained and the 
shortest side of which is not less than 1,2 
cm. The presence of flakes, accounting 
for up to 30 % of fish weight, shall be 
tolerated 

Fragments of flesh the initial muscle 
structure of which is maintained and 
which are of heterogeneous size 

Separate particles of flesh of uniform 
dimension which do not constitute a paste 

 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Definition of 
Fillets 

 Not in the standard. 

 The name of the product as declared on 
the label shall be "tuna" or "bonito", and 
may be preceded or followed by the 
common or usual name of the species, 
both in accordance with the law and 
custom of the country in which the 
product is sold, and in a manner not to 
mislead the consumer. 

The name of the product may be qualified 
or accompanied by a term descriptive of 
the colour of the product, provided that 
the term "white" shall be used only for 
Thunnus alalunga and the terms "light", 
"dark" and "blend" shall be used only in 
accordance with any rules of the country 
in which the product is sold. 

The standard does not apply to speciality 
products where the fish content 
constitutes less than 50% of the 
contents. 

(a) longitudinal strips of muscle taken 
from the musculature parallel to the 
vertebral column ; 
(b) strips of muscle from the abdominal 
wall ; in this case, the fillets may be 
described as abdominal fillets, too ; 

Where there is an established trade usage, 
the type of fish used (tuna or bonito) and 
the species may appear in the trade 
description under the name normally 
used in the Member State in which the 
products are marketed. 

Not in the standard. 

The ratio between the weight of the fish 
contained in the container after sterilisation 
and the net weight expressed in grams shall 
be at least:  
(a) in the case of presentations in solid, 
chunks, fillets, flakes or grated/shredded 
tuna:  
 - 70% in the case of the covering medium 
"in olive oil", "natural", "in vegetable oil".  
- 65% in the case of other covering media.  

Not allowed 

Allowed in preparations entailing 
disappearance of the muscular structure and 
provided that tuna or bonito account for 
25% of the net weight 

-Sardina pilchardus 
-Sardinops melanostictus, S. 
neopilchardus, S. ocellatus, S. sagax, 
S. caeruleus, 
-Sardinella aurita, S. brasiliensis, S. 
maderensis, S. longiceps, S. gibbosa 
-Clupea harengus 
-Clupea bentincki 
-Sprattus sprattus 
-Hyperlophus vittatus 
-Nematalosa vlaminghi 
-Etrumeus teres 
-Ethmidium maculatum 
-Engraulis anchoita, E. mordax, E. 

Sardina pilchardus 
Since 2003, following the WTO 
proceedings: 
(a) Sardinops melanosticus, S. 
neopilchardus, S. ocellatus, S. sagax, S. 
caeryleus; 
(b) Sardinella aurita, S. brasiliensis, S. 
maderensis, S. longiceps, S. gibbosa; 
(c) Clupea harengus; 
(d) Sprattus sprattus; 
(e) Hyperlophus vittatus; 
(f) Nematalosa vlaminghi; 
(g) Etrumeus teres; 
(h) Ethmidium maculatum; 
(i) Engraulis anchoita, E. mordax, E. 

Labelling – 
name of the 
food  

Ratio 
between the 
weight of 
the fish 
contained in 
the 
container 
after 
sterilisation 
and the net 
weight 
expressed 
in gr 

Mix with 
other 
species 

Sardines 

Species 

10 

 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ringens 
-Opisthonema oglinum 

Presentation  Any presentation of the product shall 

be permitted provided that it: 
(i) contains at least two fish in each 
can; and 
(ii) meets all requirements of this 
standard; and 
(iii) is adequately described on the 
label to avoid confusing or misleading 
the consumer; 
(iv) contains only one fish species 

Labelling – 
name of the 
food  

The name of the product shall be: 

(i) "Sardines" (to be reserved 
exclusively for Sardina pilchardus 
(Walbaum)); or  

(ii) "X sardines" where “X” is the name 
of a country, a geographic area, the 
species, or the common name of the 
species, or any combination of these 
elements in accordance with the law 
and custom of the country in which the 
product is sold, and in a manner not to 
mislead the consumer. 

The standard does not apply to 
speciality products where fish content 
constitute less than 50% m/m of the 
net contents of the can. 

Ratio 
between the 
weight of 
the fish 
contained in 
the 
container 
after 
sterilisation 
and the net 

11 

ringens; 
(j) Opisthonema oglinum; 
Since 2008: (k) Strangomera bentincki. 

1. sardines: the basic product, fish from 
which the head, gills, internal organs and 
caudal fin have been appropriately 
removed. The head must be removed by 
making a cut perpendicular to the 
backbone, close to the gills; 
2. sardines without bones: as the basic 
product referred to in point 1, but with 
the additional removal of backbone; 
3. sardines without skin or bones: as the 
basic product referred to in point 1, but 
with the additional removal of the 
backbone and skin; 
4. sardine fillets: portions of flesh 
obtained by cuts parallel to the backbone, 
along the entire length of the fish, or a 
part thereof, after removal of the 
backbone, fins and edge of the stomach 
lining. Fillets may be presented with or 
without skin; 
5. sardine trunks: sardine portions 
adjacent to the head, measuring at least 
3 cm in length, obtained from the basic 
product referred to in point 1 by making 
transverse cuts across the backbone; 
6. any other form of presentation, on 
condition that it is clearly distinguished 
from the presentations defined in points 1 
to 5. 

1. ‘preserved sardines’ means products 
prepared from fish of the species Sardina 
pilchardus; 
2. ‘preserved sardine-type products’ 
means products marketed and presented 
in the same way as preserved sardines 
and prepared from the species added to 
the regulation since 2003 (c.f. row 
species).  
preserved sardine-type products may be 
marketed in the Community under a 
trade description consisting of the word 
‘sardines’ joined together with the 
scientific name of the species and the 
geographic area where the species was 
caught. 
The ratio between the weight of sardines 
in the container after sterilization and the 
net weight:  

a)  For the presentations defined in 

points 1 to 5 in the row 
presentation, the ratio shall be 
not less that:  

-  70%  for  the  following  covering  media: 
olive  oil,  other  refined  vegetable  oils 
(including  olive-residue  oil  used  singly 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

weight 
expressed 
in gr 

or  in  mixtures),  natural  juice  and 
marinade with or without wine.   

-  65% for tomato sauce.  
-  50% for the other covering medium.  

12 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 6.  NATIONAL LAWS AND REGULATIONS FOR MARKETING OF FISHERY PRODUCTS 

Country 

Name  in  national 
language and link 

English Name 

year 

Binding 
Instrument 

Scope of the regulation 

Specific requirements related to product quality  

Austria 

Österreisches 
Lebensmittel-
buch  

Austrian Food 
Book 

2017 

yes 

Definition of various fishery product, 
indications on maximum water content 
of stockfish, salt content of klipfish, 
definition of smoked fish and 
temperature, definition of caviar (type 
of sturgeon to be used), storage 
temperature of caviar, other types of 
roes, marinated products for 
anchovies and herring, definition of 
canned fish, and minimum fish 
content, definition of surimi, indication 
on live bivalves marketing, description 
of tests on fish marketing to be 
executed, the annex contains the list 
of official names of fish species.  

Fish content in fish fingers higher 65%, Austrian law 
on salting is stricter than the EU law, Indications on 
glazing at 20%, lower than EU regulations, the net 
weight of marinated herring has to be at least 40%, 
in solid tuna pack fillets have to be greater than 2.5 
cm, and the share of flakes should not be greater 
than 15%, canned tuna steaks have to be of one 
piece, for canned tuna flakes, the majority (more 
than 85%) have a length of 4 mm, and a diameter 
of 6 mm; it is not allowed to add crabs or something 
alike on the surimi packs, less than 10% of live 
clams can be open;  

13 

 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Definition of various types of fish cuts; 
definition of crabs and molluscs for 
human consumption, regulations on 
sauces; regulations on the cream for 
herrings; definitions of the various 
cuts of frozen fish; definition and 
norms for fish fingers; definition of 
stockfish and klipfish; definition of hot 
smoking and cold smoking; definition 
of hard salting and mild salting; 
definition of matjesherring; definition 
of anchovies; definition and norms for 
rollmops; definition of minimum fish 
weight in various fish products; 
definition of canned products with 
reference to EU regulation for canned 
tuna and bonito; norms for glazed 
crustaceans and for glazed molluscs;  

Fish content in fish fingers should be higher 65%, 
Indications on glazing at 20%, lower than EU 
regulations; sauces used with fishery products need 
to have at least 10% fat; cream for herring 
(Sahnehering) need to have at least 4% milkfat; a 
frozen filet can contain up to 25% of fish pieces if 
they origin from the preparation; a product 
“practically without bones” can have up to 2 bones 
per 1 kg fillet; a fish finger should have the weight 
of 30 g and should not contain more than 25% of 
fish pieces; for small battered fish fillets, the net fish 
content should be greater than 50%; for small 
formed battered products the fish contents should 
be greater than 40%; for fish fillet portions 
(Schlemmerfillet and there like) the fish content has 
to be greater than 50%; water content in stockfish 
not greater than 18%; water content in klipfish not 
greater than 48%; hot smoking heat greater than 
60o, cold smoking heat greater than 30o; hard 
salting more than 20% of salt per fish weight, mild 
salting between 6-20%; fat content of matjesherring 
more than 12%; the filling of rollmops should be 
less than 20% of the total product weight; in all fish 
products with sauces etc the fish weight should 
exceed 50%; glazing of crustaceans or molluscs 
should not exceed 20%; for battered crustaceans 
and for battered molluscs the net weight should be 
greater than 50%, only for very small shrimp and 

Germany  

Deutsche 
Leitsätze für 
Fische, 
Krebstiere und 
Produkte daraus 

Guidelines for 
Fish, 
Crustaceans 
and Products 
thereof 

2011 

yes 

14 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

small molluscs (squid rings below 4 cm in size) 40% 
is acceptable;  

15 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Country 

Name  in  national 
language and link 

English Name 

year 

Binding 
Instrument 

Scope of the regulation 

Specific requirements related to product quality  

Allow to distribute for human consumption salmon, 
caught in the Baltic Sea and the Gulf of Riga, only if 
the length of whole salmon not exceeds 72 cm and 
weight 4.4 kg (inclusive); 
Allow to distribute for human consumption fillet of 
salmon, caught in the Baltic Sea and the Gulf of 
Riga, if the weight of whole salmon is greater than 
4.4 kg but not exceeding 6 kg. 

The water content in dried fish should not exceed 
15%;  

Latvia 

Par lašu 
izplatīšanas 
aizliegumu 

 On the 
prohibition of 
the distribution 
of salmon” 

2005 

yes 

Salmon marketing norms 

Decreto 
2484/1967, de 
21 de 
septiembre, por 
el que se 
aprueba el texto 
del Código 
Alimentario 
Español  

Decree 2484 / 
1967, of 21 
September, 
which approves 
the text of the 
Spanish food 
code 

1967, but 
rev. 2017 

yes 

In chapter XII, fish and fishery 
products are described in detail, 
definition of the five main products 
forms (fresh, frozen, salted, smoked 
and dried) and derived products such 
as canned, semi-conserves, soups and 
ready meals; in chapter XIII it defines 
crustaceans and molluscs products 

Spain 

16 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Country 

Name  in  national 
language and link 

English Name 

year 

Binding 
Instrument 

Scope of the regulation 

Specific requirements related to product quality  

Norma de 
Calidad para los 
Mejillones, 
Berberechos y 
las Almejas 
Cocidos y 
Congelados. 

Quality norms 
for cocked and 
frozen 
mussels, 
cockles and 
clams 

1984, corr. 
1985 

yes 

Commercial classification of mussels, 
cockles and clams 

Mussel 
Big: > 7.5 g 
Medium: > 5.5 g 
Small: < 5.5 g 
Clam 
Giant: > 7 g 
Big: > 5 g 
Medium: > 3 g 
Small: < 3 g 
Cockles 
Big: > 1.7 g 
Medium: > 1.2 g 
Small: < 1.2 g 

Norma de 
calidad para el 
mejillon, almeja 
y berberecho en 
conserva 

Quality norms 
for canned 
mussels, clams 
and scallops 

1984, corr 
1985 

yes 

Defines various forms of canned clams 
and mussels, their sauces,  

10% tolerance (10% medium acceptable in big etc.) 

Definition of “natural” if the filling is either water or 
brine and if  the sodium chloride is less than 7%; 
various minimum molluscs content is defined by 
type of filling material, type of can, and by type of 
mollusc.  

17 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 7.  QUESTIONNAIRE FOR THE NATIONAL AUTHORITIES 

The  questionnaire  will  be  delivered  online  or  through  an  Excel  form.  If  online,  the 
questionnaire will be accessible with an identifier and password per MS, in order to allow 
for multiple respondents. 

Introduction 

The  objective  of  the  evaluation  is  to  examine  the  relevance,  effectiveness,  efficiency, 
coherence and EU added value of the current marketing standards for fishery products, in 
accordance  with  the  Better  Regulation  Package  Guidelines.  The  regulatory  framework 
under evaluation is: 

-  Council  Regulation  (EEC)  No  2136/89  of  21  June  1989  laying  down  common 

marketing standards for preserved sardines; 

-  Council  Regulation  (EEC)  No  1536/92  of  9  June  1992  laying  down  common 

marketing standards for preserved tuna and bonito;  

-  Council  Regulation  (EC)  No  2406/96  of  26  November  1996  laying  down  common 

marketing standards for certain fishery products; and 

-  Regulation (EU) No 1379/2013 of the European Parliament and of the Council of 11 
December  2013  on  the  common  organisation  of  the  markets  in  fishery  and 
aquaculture products – Chapter III – Common Marketing Standards; 

This  is  the  first  evaluation  carried  out  specifically  on  the  implementation  of  marketing 
standards for fishery products and feedback from national administrations and in particular 
control authorities is critical to analyse their efficiency and enforceability.  

The questionnaire includes the eight following sections: 

-  Contacts; 
-  Administrative  organisation  of  the  implementation,  control  and  monitoring  of  EU 

marketing Standards; 

Impacts of EU marketing standards; 

-  Compliance; 
- 
-  Coherence with other EU rules and standards or norms; 
-  Potential for simplification; 
-  Conclusion 

Please  circulate 
organisations/units. 

the  questionnaires  (log 

in 

information) 

to  all 

the  relevant 

If you have any issue with filling in the questionnaire or if you wish to send us additional 
documentation please contact Séverine Renault (severine.renault@and-international.com) 
or Safa Souidi (safa.souidi@and-international.com) 

Contacts 

Please list the relevant organisations and contacts. We may contact you for follow-up on 
specific issues. 

1.  Country:  

18 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

2.  List of respondents to the questionnaire: 

Organisation/unit 

Name 

Email address 

Administrative organisation of the implementation, control and monitoring of EU 
marketing Standards 

3.  What  are  the  administrations  involved  in  the  implementation  and  control  of  EU 
Marketing  Standards?  Please  describe  the  main  activities  carried  out  by  each 
organization.   

Organisation/unit 

Activities 

4.  Are  some  of  these  services  also  involved  with  the  control  of  other  relevant  EU 

regulations (please check all relevant answers) 

i.  EU rules on food safety 
ii.  Consumer  information  rules  (Regulation  (EU)  No  1169/2011  and 

Chapter IV of the CMO Regulation; 

iii.  Hygiene rules for food of animal origin (Regulation 853/2004); 
iv.  National  standards  or  codes  of  practices,  if  so  please  specify  the 

products covered: 

v.  International standards (e.g. Codex), if so please specify:  

5.  How is the implementation of EU marketing Standards controlled? Please list the items 
checked  during  the  inspections  and  specify  at  what  stage  of  the  supply  chain 
inspections take place. 

Regulations 

Items inspected at the different Stage of the supply chain 
/types of operators 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Reg.  2136/89  for  preserved 
sardines and Reg. 1536/92 for 
preserved tunas and bonitos 

Reg.  2406/96 
fishery products 

for  certain 

6.  Can  you  please  provide  the  total  number  of  FTEs  dedicated  to  the  control  of  EU 

marketing standards in 2017 (even approximately)?: _____________ 

7.  How  much  time  do  inspections  take  on  average  (in  hours,  even  approximately)? 

____________ 

8.  How  much  time  do  inspectors  have  to  spend  before  and  after  the  inspection  itself 
(preparation and reporting/ follow up), in hours? _____________________________ 

9.  Are controls of EU marketing standards usually combined with other types of controls 
(e.g.  controls  of  landings,  controls  of  MCRS,  controls  of  hygiene  rules,  etc.)? 
(Never/Sometimes/Always) 

10. If 9=Always, please specify which types of controls are combined 

11. If 9= Sometimes, please explain in which cases they are combined and what prevents 

from always combining them with other controls 

12. If 9 = No, please explain what prevents from combining with other types of controls. 

13. What type of Information Technology tools do you have for the control of EU marketing 

standards? Please describe the main tools. 

14. Can you please provide the recurring annual costs for managing those tools (in local 
figure)? 
(even 

currency) 
2017 
_____________________________________________ 

approximate 

for 

an 

15. Do you have other costs related to the control of marketing standards? Y/N 

16. If 15 = Yes, please detail those expenditures and the corresponding amounts 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Expenditures 

Amount  for  2017  (in 
currency) 

local 

17. Have new technologies (e.g. electronic auctions, development of e-commerce, landing 
of products already packed, etc.) raised new issues in terms of controlling EU marketing 
standards? (Y/N/don’t know) 

18. If 17=Yes, please explain: 

Compliance 

19. How have the intensity if inspections, the number of observed anomalies, the volumes 

of fish inspected and the penalties evolved over the past 5 years:  

Sharp 
decrease  

2 

3 

4 

Sharp 
increase  

Don’t 
know  

Number of inspections 

Number 
observed 

of 

anomalies 

Volumes  of 
fish 
products inspected 

/fish 

Amount of penalties 

20.  Can you please provide those statistics for the past 5 years (2013 to 2017): (check relevant items)? 

-  Number of inspections per year  

-  Number of anomalies per year 

-  Volumes of fish/fish products inspected per year 

-  Amount of penalties per year 

21. Please fill in the following table (should only show the lines where statistics are available 

based on answers to the previous question):  

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

2013 

2014 

2015 

2016 

2017 

Number of inspections 

Number  of  anomalies 
observed 

Volumes  of 
fish 
products inspected 

/fish 

Amount of penalties 

22. Do you have explanations on the evolution of the number of observed anomalies? 

23. Please rank the type of anomalies or irregularities from the most frequent to the least 

frequent (1=most frequent / 5=least frequent) 

- Infringement to the minimum marketing size criteria  

- Infringement to the minimum freshness criteria 

- Wrong grading/sorting of catches  

- Infringement to the provisions on imported products  

- Infringement to the provisions on canned sardines and canned tunas and bonitos 

24. Please describe the consequences for operators for the different types of anomalies 

Type of anomalies 

Consequences for operators (products removed, amount of penalties, 
etc.) 

Infringement 
the 
minimum  marketing  size 
criteria  

to 

Infringement 
minimum 
criteria 

the 
to 
freshness 

Wrong  grading/sorting  of 
catches 

Infringement 
the 
provisions  on  imported 
products 

to 

Infringement 
provisions  on 

to 

the 
canned 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

sardines 
tunas and bonitos 

and 

canned 

25. Are there issues of compliance specific to some species / products? Please explain which 

species and why. 

26. Are  there  issues  of  compliance  specific  to  some  operators?  Please  explain  which 

operators and why. 

Impacts of EU marketing standards 

27.  Please provide the following data if available (for the most recent year available):  

Volumes (t) 

Year 

Volumes  of  fish  products  not  marketed  for  direct  consumption 
because they do not comply with EU marketing standards criteria for 
canned products 

Volumes of fresh fish not marketed for direct consumption because 
they do not meet EU marketing standards minimum size criteria 

Volumes of fresh fish not marketed for direct consumption because 
they do not meet EU marketing standards minimum freshness criteria 

28. Do you have additional information or data on products not complying with marketing 
standards  (e.g.  %  of  products  destroyed,  main  outlets  outside  direct  human 
consumption, etc.)  

29. To what extent do you agree with the following sentences?   

Completely 
disagree 

Somewhat 
disagree 

Neutral 

Somewhat 
Agree 

Completely 
agree 

Don’t 
know 

marketing 

EU 
standards 
contribute to …. 

Improve  products 
quality  

the  sustainability  of 
fishery 
products 
marketed in the EU 

fairness  and 
the 
transparency of the 
internal market 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

The  profitability  of 
operators along the 
supply chain 

Ensure  a 
level-
field 
playing 
between  EU  and 
non-EU products 

30. Please  explain  how  the  different  provisions  and  criteria  of  EU  marketing  standards 

contribute to those objectives.  

Contribution to the objectives above 

Minimum 
requirements 
preserved products 

content 
for 

Trade  descriptions  and 
contents  for  preserved 
products  

marketing 
Minimum 
standards for fresh fish 

Provisions  on  grading 
for fresh fish 

Provisions  on  imported 
products 
fresh 
products 

for 

31. From your perspective, have marketing standards had other positive impacts? Please 

explain.  

32. Have they led to negative impacts? Please explain. 

Coherence of marketing standards with other regulations and public standards 

33. Are  there  national  or  regional  public  standards  or  codes  of  practices  setting  quality 
criteria (e.g. minimum requirements, quality grades, definitions for trade description, 
product  presentations  or  contents)  for  fishery  and  aquaculture  products  in  your 
country? Y/N/Don’t know 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

34. If  33  =  Yes,  Please  specify  the  name  and  scope  (geographical,  products  and  main 

requirements) of those standards (if available, provide a link to the website). 

35. Can  you  provide  examples  of  synergies/complementarities  between  EU  marketing 

standards and: 

Examples  

Conservation rules 

EU rules on food safety 

Consumer  information  rules  (Regulation 
(EU) No 1169/2011 and Chapter IV of the 
CMO Regulation) 

Hygiene  rules  for  food  of  animal  origin 
(Regulation 853/2004) 

International standards (e.g. Codex) 

National or regional standards or codes of 
practices (If relevant) 

Control  Regulation 
the  Common 
Fisheries  Policy  (Council  Reg.  (EC)  No 
1224/2009) 

for 

Other norms or standards (please specify) 

36. Can you provide examples of conflicts between EU marketing standards and: 

Examples  

Conservation rules 

EU rules on food safety 

Consumer  information  rules  (Regulation 
(EU) No 1169/2011 and Chapter IV of the 
CMO Regulation) 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Hygiene  rules  for  food  of  animal  origin 
(Regulation 853/2004) 

International standards (e.g. Codex) 

National or regional standards or codes of 
practices (If relevant) 

the  Common 
Control  Regulation 
Fisheries  Policy  (Council  Reg.  (EC)  No 
1224/2009) 

for 

Other norms or standards (please specify) 

Potential for simplification 

37. Do you think the following could be simplified without hindering the achievements of 

marketing standards? 

To 

5 
great 
extent  

a 

4 

3 

2 

1  Not  at 
all 

Don’t 
know 

Size criteria 

Freshness criteria 

Provisions 
fresh/chilled products 

on 

imported 

Trade descriptions for preserved 
products 

Presentation  requirements  for 
preserved products 

Species  names  for  preserved 
products 

Minimum  content  requirements 
for preserved products 

Control procedures 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

38. Please provide examples (only show rows for which the rate in previous question is 2 

Examples  

or more) 

Size criteria 

Freshness criteria 

Provisions 
fresh/chilled products 

on 

imported 

Trade descriptions for preserved 
products 

Presentation  requirements  for 
preserved products 

Species  names  for  preserved 
products 

Minimum  content  requirements 
for preserved products 

Control procedures 

Conclusion 

39. Do you have any other comment or recommendation on EU marketing standards?  

Thank you for your time! 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 8. 

SUMMARY OF ANSWERS TO THE NATIONAL AUTHORITIES SURVEY  

The National Authority (NA) survey was disseminated through an online tool and by email 
to Member States in June 2018. By October 2018, when the survey was close, 25 member 
states had answered. 

The  objective  of  the  survey  is  to  understand  how  controls  of  Marketing  Standards  are 
managed  in  the  MS,  and  gather  feedback  on  the  different  national  norms,  the  level  of 
compliance with marketing standards at the different stages of the supply chain, and the 
main  impacts  perceived  by  national  authorities  in  charge  of  marketing  standards 
implementation and control.  

8.1.  Administrative organization, control and monitoring 

According  to  the  results  of  the  survey  among  the  25  MS,  between  one  and  five 
administrative  entities  are  involved  in  the  implementation  and  controls  of  EU  marketing 
standards, depending on the organization in each MS. 

Table 1: Number of administrative entities involved in the control and 
implementation of marketing standards 

No of countries 

1 Administrative Services 

2 Administration Services 

3 Administration Services 

4 Administration Services 

5 Administration Services 

6 

10 

6 

1 

2 

Source : NA survey, N=25 

The basic scheme involves the Department of Agriculture and/or Fishery, in addition to the 
Veterinary Services. The third administrative entity is usually a market control service. All 
these structures are also engaged in other types of controls. Inspections can cover various 
topics : control of the supply chain – from the catch sector to retailers -, transport, sales 
notes, market or food labelling, in both fresh and canned industry. In Spain, the situation 
varies  between  autonomous  communities,  and  the  number  of  services  involved  ranges 
between one (like Cataluña and Cantabria) to five (Galicia). 

28 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Figure 1: Answer to the question : Are controls of marketing standards combined 
with other types of controls ? 

Standards not controlled

Never combined

Sometimes combined

Always combined

Non response

0

2

4

6

8

10

12

14

Nb of MS

Source : NA survey, N=25 

For 80 % of the national services interviewed, marketing standards controls are always or 
sometimes  combined  with  other  inspections,  usually  hygiene,  traceability,  laboratory 
sample checks, control of storage conditions and labelling. Three countries (Luxembourg, 
Cyprus and Austria) do not combine controls on marketing standards. In this category, in 
two cases, marketing standards controls are not performed at all, and in the last case  they 
are not applied because of legal issues of involved services in this types of checks. Most of 
the time, combining the types of control with other checks is a way to optimize expenditure 
and reduce administrative burden for the public services. 

Out of the 25 MS interviewed in the NA survey, 14 declared to use IT tools supported by 
national database to register data and prepare controls. These data include various aspects 
(landing  database,  traceability  information  system,  digitalized  sale  notes,  tracking  of 
catches,  inspections  and  laboratory  tracking  or  electronic  auctions  database).  Cross-
checking  those  IT  tools  can  be  used  by  the  various  services  in  charge  of  controls  and 
traceability. Ireland declares being developing a unique electronic database that will cover 
the relevant aspects of the marketing standards and will guide inspectors in completing an 
assessment. 

Concerning the specific controls related to Reg. 2136/89 for preserved sardines and Reg. 
1536/92 for preserved tunas and bonitos, among the 14 MS that provided an answer, a 
large majority indicated that controls are performed at the industry, wholesale and retail 
level. Laboratory sample and labelling checks are the most common type of checks. 

Concerning control related to Reg. 2406/96 for fresh and chilled fishery products, 16 MS 
indicated that size and freshness controls on other type of fishery products are performed 
at various stages, by public services. Only in Netherlands, the industry is in charge of the 
controls since 2017. Private controller are mainly mobilized at the auction stage. 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Table 2: Answer to the question : How much time do inspections take on 
average ? 

No of NAs 

Non response 

10 

Less than 60 

From 60 to 119 

From 120 to 179 

From 180 to 239 

From 240 to 299 

300 and more 

Total 

1 

7 

3 

1 

1 

2 

25 

Source : NA survey, N=25 

Within the 25 MS interviewed, two third could provide an answer concerning the average 
duration time of inspections. Excluding the time of preparation and the time of reporting, 
the  median  time  of  inspection  is  one  hour.  Extreme  values  are  reported  for  Greece  and 
Czech Republic, with controls reaching 5 to 6 hours. These figures had to be estimated in 
most cases, as marketing standards controls are performed in combination with other types 
of checks. 

The  data  provided  in  relation  to  the  number  of  FTE  dedicated  to  marketing  controls  are 
partial,  with  a  response  rate  of  48  %.  Within  the  answers,  a  large  majority  (78.6%) 
indicated less than 200 FTE dedicated to the task. Denmark and Czech Republic indicate 
employing more than 400 FTEs on such type of controls.  

Table 3: Number of FTE dedicated to the control of marketing standards in 2017 

No of FTEs  

Non response 

12 

Less than 1 

From 1 to 5 

From 6 to 9 

From 10 to 49 

50 and more 

2 

3 

2 

0 

6 

Total 

25 

Source : NA survey, N=25 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

8.2.  Compliance 

Figure 2: Answer to the question: How have evolved ... ? 

Amount of penalties

Volume of fish/fish
products inspected

Number of anomalies
observed

Number of inspection

0%

20%

40%

60%

80%

100%

Sharp increase

Slow increase No change

Slow decrease

Sharp decrease Non response

Source : NA survey, N=25 

Over the past five years, for the majority of MS, the number of anomalies observed, the 
volume  of  fish  or  fish  products  inspected  and  the  amount  of  penalties  was  reported  as 
stable, respectively for 50%, 29% and 42%. Only the number of inspections is reported to 
have increased over the period, for a third of the sample. In France, NA underlined that 
the number of inspections has increased, as a  consequence of the professionalization of 
fisheries control and the strengthening of regulatory obligations. In Spain, a slow increase 
is  reported.  In  Czech  Republic  too,  were  even  if  the  number  of  inspections  increased 
significantly,  the  number  of  anomalies  related  specifically  to  marketing  standards  (i.e. 
violation  on  minimum  size  criteria,  freshness  criteria  and  violation  of  provisions  on 
imported  sardines,  tuna  and  bonito  tins)  is  very  low  and  not  statistically  significant  in 
comparison with other types of controls. 

From  to 10 to 14 MS could provide full or partial data on the number of anomalies observed 
during  controls  of  the  EU  marketing  standards,  related  to  the  volume  of  fish  and  fish 
products controlled.  

Table 4: Evolution of the number of anomalies observed 

Mean 

Median 

Frequency 

2013 

2014 

2015 

2016 

453 

374 

334 

317 

54 

71 

84 

81 

9 

10 

12 

13 

According  to  the  14  MS  that  could  provide  full  or  partial  answers,  the  number  of 
irregularities reported during controls has decreased  from 2013 to 2017, with a median 
value in progression in 2014 and 2015. 

31 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Table 5: Evolution of volumes of fish/fish products inspected 

Mean 

Median 

Frequency 

2013 

2014 

2015 

2016 

2017 

1558 

1149 

2876 

11669 

4032 

499 

546 

888 

920 

769 

7 

7 

10 

10 

10 

The 10 NA that could provide data on the volume of products controlled underlined a global 
increase from 2013 to 2017. In 2016, an important peak of volumes checked is reported. 
This is the consequence of the increase in controls mentioned in the Netherlands, as the 
responsibility  of  control  for  marketing  standards  has  been  shifted  to  the  industry.  All 
products  that  go  through  the  auction  are  controlled  by  private  contractors,  most  of  the 
fresh  fish  products  pass  the  auction,  and  all  shrimp  products  are  legally  obliged  to  go 
through  auction  via  an  acknowledged  sieving  location.  Products  that  do  not  go  through 
auction are periodically controlled by the NA. 

The NA survey also aimed to determine the amount of penalties reported each year. The 
data  are  not  reliable  according  to  the  answers  provided,  as  some  NA  understood  the 
question as the number of violations of the marketing standards reported. Furthermore, 
the perimeter of the controls is often wider than the marketing standards themselves, as 
for  80%  of  the  NA,  controls  are  always  are  sometimes  combined  with  other  types  of 
controls. 

When  asked  about  the  frequency  of  anomalies  reported  during  controls,  by  priority 
(1=most  frequent  and  5=least  frequent),  8  NAs  (out  of  16  answers)  pointed  out 
infringement  related  to  the  minimum  marketing  size  criteria  as  the  most  frequent 
irregularity observed. 4 NAs indicated wrong grading/sorting of the catches as the main 
anomaly  reported.  As  most  frequent  irregularities,  both  are  related  to  size  issue  of  the 
products. 

According  to  the  NA  survey,  infringement  to  the  minimum  freshness  criteria  and  on 
provisions on imported products occur mainly from 2 to 4 in the top five ranking. Issues 
related to provisions on canned sardines and canned tunas and bonitos are mentioned as 
the least frequent anomalies by 5 MS (out of the 8 MS that provided an answer). 

To  sum  up,  the  results  of  the  survey  indicate  that  the  most  frequent  irregularities  are 
related  to  size  issues,  irregularities  on  imports  and  freshness  are  middle  range  is  the 
ranking and the least frequent anomalies concern preserved and canned products. 

32 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Figure 3 : Ranking of the type of anomalies or irregularities from the most frequent to 
the least frequent 

t
s
o
m
=
1
(

s
e

i
l

a
m
o
n
a

f

o

y
c
n
e
u
q
e
r
F

5

4

3

2

1

)
t
n
e
u
q
e
r
f

t
s
a
e

l

=
5

/

t

n
e
u
q
e
r
f

0%

20%

40%

60%

80%

100%

Infringement to the minimum marketing size criteria
Infringement to the minimum freshness criteria
Wrong grading/sorting of catches
Infringement to the provisions on imported products

The evolution of the number of anomalies yet is indicated for 25 % of the cases to have 
decreased.  This  is  the  consequence  of  targeted  inspections  (Hungary,  Poland),  the 
intensification of checks and an effort to perform exhaustive survey during controls in few 
cases (France, Spain). Yet, it is underlined that infringement to marketing standards is also 
reduced by the law of supply and demand, as buyer will not be interested in products not 
following the EU regulation (Croatia). 

Among the 15 answers concerning specific issues on species, 9 MS reported that there are 
no particular compliance anomalies related to specific species of products, such as in France 
and Italy, a major fish operator in EU. For fresh or chilled products, CZ reported Gadidae 
fish.  In  general,  high  value-added  species  issues  are  more  related  to  minimum  size 
infringement (Spain, Ireland), while low value-added products can have issues regarding 
freshness  criteria.  For  instance,  the  NA  in  Netherlands  underlined  issues  related  to  sole 
and  plaice,  concerning  size  anomalies.  Sole  is  also  often  pointed  out  in  Poland,  where 
Limanda aspera is sometimes sold as Solea vulgaris, as importers and restaurants use a 
different  terminology,  what  misleads  consumers.  It  is  also  reported  in  some  MS  that 
anomalies  are  more  often  observed  in  canned  products,  with  substitution  of  tuna  and 
bonito with other species (Spain). Furthermore, laboratory inspections in CZ highlight the 
deficiencies under the term “fish meat” in canned products. 

Some operators present more anomalies than others among the MS in the survey. Within 
the answers reported in the survey, 21 % of NA reported issues of compliance specific to 
some  operators,  when  a  third  didn’t.  Operators  involved  are  fishing  companies  and 
auctions. In Denmark, it is underlined that fishing vessels often do not correctly sort by 
size and the boxes of products are often overweight. Issues of compliance are also pointed 
out at retail level, in particular with street vendors and restaurants, but it appears to be 
more a traceability issue than a problem specifically related to marketing standards. 

33 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

When controlled products do not comply with marketing standards, merchandise is used 
for purposes other than human consumption, mostly as fish meal for animal feeding, as 
mentioned by 20,8% of the 25 NA interviewed. 

8.3.  Main impacts 

Figure 4 : Extent to which EU marketing standards contribute to ...? 

Ensure a level-playing field between EU and non-EU
products

Improve products quality

The fairness and transparency of the internal market

The profitability of operators along the supply chain

The sustainability of fishery products marketed in the
EU

Completely agree Somewhat Agree Neutral Somewhat disagree Completely disagree Non response

0%

50%

100%

Source: NA survey, N=25 

The  vast  majority  of  NAs  and  control  authorities  consider  EU  marketing  standards  as  a 
positive regulation in terms of quality, sustainability, transparency of the market, fairness 
of  international  trade  and  for  the  operators  all  along  the  supply  chain.  Even  if  the 
implementation of marketing standards relies mainly on the first operators of the supply 
chain (i.e. fisheries and auctions) the contribution of those regulation is considered to also 
benefit to the downstream operators. 

Various impacts of EU marketing standards have been spotlighted by the NA. First of all, 
NA consider marketing standards as an essential tool to improve the quality of products 
and preserve the fish stocks. 

The  main  issues  underlined  by  NA  is  that  marketing  standards  do  not  ensure  equal 
treatment  between  EU  and  non-EU  products  (except  for  preserved  products)  (Croatia). 
Another issue mentioned was the extra-cost related to the implementation of marketing 
standard. Extra expenditure can rely on operators, like sorting and grading by freshness 
and size (Greece), or on public administrations, as they are in almost all cases in charge 
of controls, except in the Netherlands. 

34 

 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

8.4.  Coherence with other regulations and standards 

Figure 5: Answer to the question: are there other public standards / codes of 
practice for fishery and aquaculture products?  

Non response 

Yes 

No 

I don't know 

Total 

Number 

5 

8 

10 

2 

25 

Source : NA survey, N=25 

Among  the  NAs  covered  by  the  survey,  a  third  declared  to  have  implemented  local 
standards  setting  quality  criteria  for  fishery  and  aquaculture  products.  These  extra 
regulations cover various aspects, from labelling of canned products, to hygiene criteria. 
When relevant, national ministries of agriculture and/or fisheries promote decrees to define 
standards as regards labelling for consumers, but the criteria mentioned by MS are mainly 
different from marketing standards. Focusing specifically on size criteria, private label can 
overlap  marketing  standards  requirement.  As  mentioned  in  the  Netherlands,  producers 
need  to  land  a  minimum  size  of  6.8  mm  (v.s.  6.5mm  under  marketing  standards 
requirements) to keep acquire and keep the MSC label on Crangon crangon. 

As a consequence, local standards, private or promoted by public administrations, can be 
a  complement  to  EU  marketing  standards.  Concerning  conservation  rules,  the  minimum 
size criteria enhances the sustainability of fish stocks and prevents environmental issues. 
Marketing standards are also complementary to wider food safety regulations. For instance, 
it  is  underlined  in  Croatia  that  freshness  regulated  by  marketing  standards  works  in 
synergy with other aspects of food safety on fish products, like best before date or date of 
catch. It is also highlighted that – in Spain – there is a total synergy between marketing 
standards and labelling of preserved products. 

On the other hand, conflicts can occur between marketing standards and other regulations. 
For instance, conservation rules are often pointed out by the NA, as minimum size criteria, 
as  written  in  Reg  2406/96  establish  minimum  marketing  size  for  certain  species  not 
covered by MCRS (as mentioned in Spain on the confusion due to the alignment between 
minimum marketing sizes and minimum conservation size, with consequence to make it 
more difficult to understand the whole regulation (France). 

35 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

8.5.  Potential for simplification 

Figure 6: Answer to the question: do you think the following could be simplified 
without hindering the achievements of EU marketing standards? 

Control procedures

Minimum content requirements for preserved products

Species names for preserved products

Presentation requirements for preserved products

Trade description for preserved products

Provision on imported fresh/chilled products

Freshness criteria

Size criteria

To a great extent

To some extent

Not at all

Non response

0%

50%

100%

Source: NA survey, N=25 

Within the 25 MS covered by the NA survey, from 32 % to 60 % did not provide any answer 
concerning the potential of simplification of the various aspects  related to EU marketing 
standards. In general, NA consider that EU marketing standards can be simplified to some 
extent to a great extent. 

Concerning  size  criteria,  NA  highlighted  that  simplification  should  focus  on  correlation 
between minimum conservation size and size defined in EU marketing standards, to avoid 
overlapping  regulations,  as  minimum  reference  size  is  considered  as  sufficient. 
Furthermore, one NA think that there are too many size criteria by fish species (Denmark). 
Yet, for 24 % the NA, simplification of size criteria could lead to a less effective regulation. 

As  example,  the  Dutch  NA  highlighted  that  for  the  criteria  related  to  canned  products, 
labelling is already regulated by the general consumer information rules (Regulation EU No 
1169/2011).  

36 

 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 9. 

LIST OF INTERVIEWS AND CONTRIBUTIONS  

High level interviews  

Position 
EU  staff  in  charge  of  scientific  advice 
and data collection 
EU staff in charge of sanitary control 
European Commission 
EU staff in charge of market and trade   European Commission 

European Commission  

Organisation 

- 

Federation of European Aquaculture producers  

Representatives of EU organisations were interviewed during the case studies: 

-  AIPCE 

-  EAPO 

Europeche and Eurocommerce were contacted but did not provide feedback.  

Interviews in the context of case studies 

Organisation, Company 

Sector 

Croatia 
MARE CROATICUM (association of professional fishermen) 
Mišlov d.o.o. 
Mirna d.o.o., part of Podravka Group 
Podravka d.d. 
Ricciotti Bullo s.a.s. 
Denmark 
Danish Fishermen’s association and producer organisation 
Danish pelagic producer organisation 
Hanstholm Auction 
Fish auction Nord (the auction consists of two auctions in 
Hirtshals and in Strandby)  
Focus group study.  
Fishermen in Hirtshals (at fish auction Nord)  
Danish Aquaculture Association 
Danish Seafood Association (DSA) 
Royal Greenland 

Danforel 

The Association of Danish fishmongers 
France 
Union du mareyage de France 
Association nationale des organisations de producteurs 
(ANOP) 

ADEPALE 
Comité Interprofessionnel des Produits de l'Aquaculture 
Comité national de la conchyliculture 
Association des directeurs et responsables des halles à 
marée de France 

37 

Fishing 
Fishing and processing 
Processing 
Processing 
Auctions 

Fishermen association  
Large pelagic fishing fleet  
Fish auction 
Fish auction 

Fishermen 

Aquaculture sector 
Fish processors/wholesalers  
Processor/wholesaler. Shrimp processing 
and trade, largest in EU 
Processor/wholesaler. EUs leading 
smoked trout processer and trader 
Fishmongers association 

Wholesale 
Catching sector 

Processing 
Aquaculture 
Shellfish farming  
Auction 

 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Catching sector, retail 
Retail  
Catching sector, wholesale 
Shellfish farming  
Shellfish farming 
Shellfish farming 

Catching sector 

Canning industry 
Canning industry 

Regional authority 
Auction 
Catching sector 

Région Bretagne 
Le Guilvinec auction 
Comité Départemental des Pêches Maritimes et des élevages 
Marins du Finistère 
Producer organisation « Pêcheurs de Bretagne » 
Association Bretonne des Acheteurs des Produits de la Pêche  Wholesale, auction 
Scapêche 
Distribution Casino France 
Pêcherie des Brisants 
Ets François CADORET  
Ets CHELLET BERTEAU PRODUCTION 
Ets LES BOUCHOLEURS BIZEUL ET FILS 
Italy 
ANCIT Director 
ANCIT  President  and  Quality  Assurance  Director  of  Bolton 
Alimentari 
ANCIT  Vice  President  and  General  Manager  of  Generale 
Conserve S.p.A 
ANCIT  Vice  President  and  Commercial  Director  of  Nino 
Castiglione 
Representative of Nireus group exporting in Italy 
Veneta Pesca, in Porto Viro 
Associazione Produttori Pesca “San Marco” di Chioggia and 
representative of Federcoopesca 
LOMAR S.r.l 
Commisioner/Auctionist (astatore) in Chioggia’s Auction 
Chioggia  Wholesale  Fish  Market,  officer  and  Director 
respectively 
Associazione Piscicoltori Italiani 
Secretariat and director respectively 
Alleanza Cooperative Italiane 
Livorno  Market,  Labronica  motopescherecci 
cooperativa arl. 
Netherlands 
VisNed 
Vissersbond 
PFA 
W van der Zwan / Quotter  
Auction Urk 
Visfederatie 

Aquaculture 
Wholesaler 
Catching sector 

Catching sector 
Catching sector 

Canning industry 

Canning industry 

Aquaculture 

società 

Catching  sector  (intermediary  between 
catching sector and buyers 
Auction Organization 

Flatfish sector association 
Mixed flatfish fish and shrimp association 
Pelagic fleet association, frozen fish 
Fresh demersal fish 
Largest flat fish auction 
Wholesale / processing association / 
AIPCEE 
Fish importers association 
Shrimp trade association 
Shrimp processing 
Specialized fish retailers association 

3rd largest auction in Galicia (main 
species: Hake, Mackerel, Albacore Bogue 
and Blue Whiting) 

Vereniging van Visimporteurs 
Vebega 
Klaas Puul 
Vereniging van Nederlandse Visspecialisten (VNV) 
Spain 
Auction of Burela (auction + meeting with the auction 
manager, the Junta de Galicia, OPAGA - PO, and 
Decaexport – wholesale company) 

38 

 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Auction of Fisterra (auction + meeting with auction 
manager, the Junta de Galicia, one vessel-owner and one 
buyer for a restaurant 
ARVI 

CEPESCA 
Nueva Pescanova 

APROMAR 
Mejillon de Galicia and 4 shellfish producers (3 members of 
OPMEGA, including the president and 1 producer outside 
OPMEGA) 
ANFACO + Conservas selectas de Galicia (Group Bolton) 
AEPMP (Asociación de Empresarios Mayoristas de Pescados 
de Madrid) 
FEDEPESCA 

Small-scale coastal fisheries, fresh fish, 
mainly not included in Annex I 

Catching sector (Vigo), main species: 
hake, megrim and monkfish 
National ass.: all types of fleet 
Fish farming, Trade/wholesale, Frozen 
fish 90% (mainly imports of hake, 
squids) and fresh fish 10% (Spanish 
auctions and sold to supermarkets) 
Fish farming (marine and continental) 
Shellfish sector (mainly mussels, under 
PDO) 

Processing industry, in particular canning 
Wholesale 

Specialised fish retailers (covers different 
types of fish products but answers are 
mainly about fresh products, which they 
know better) 

Complementary interviews in MS not covered by the case studies 

Country 

Organisation 

LV 
PL 
PL 
GR 

Karavela Sia (canning industry) 
PSTRAG PUSTELNIA Fish Farm (Aquaculture) 
Association of Fish Market Development (Trade) 
Nireus (Aquaculture) 

Written contributions received following dissemination of the questionnaires by 
the Expert Group for Fisheries and Aquaculture Products 

Country 

Organisation 

Federal Food Retailers and Wholesalers Association 
Auction of Zeebrugge & Oostende 
Auction of Livorno 
Coordinamento Pesca - ALLEANZA COOPERATIVE ITALIANE 
DG Pesca - Madeira 
SESIBAL (fresh fish) 
Armalgarve 
Auction in Portugal mainland  
ANICP 
Gothenburg Fishery Auction 

AT 
BE 
IT 
IT 
PT 
PT 
PT 
PT 
PT 
SW 

39 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 10.  DISCUSSION GUIDES FOR CASE STUDIES  

Interview guide for the auctions 

General instructions for the interviewer 

Ideally these items should be discussed in a meeting with different types of stakeholders 
but can also be discussed in individual interviews.  

The  first  section  of  the  guide  (Background)  should  be  filled  in  prior  to  the 
meeting/interviews with the main point of contact. 

The  guide  should  be  sent  to  the  main  point  of  contact  but  not  to  individual  participants 
/interviewees.  

In  case  of  focus  group/collective  meeting,  the  length  of  the  meeting  should  be 
discussed with the auction main point of contact. It should be at least 1h30 and ideally 2 
hours (a few min for presentation and introduction and approximately 15 min for each of 
the  question).  If  it  is  a  1H30  meeting,  then  the  two  first  questions  (awareness  and 
relevance) can be skipped for the discussion with the group and discussed with the main 
point of contact. In any case a follow-up should be organised with the main point of contact 
to complete items that could not be covered or not sufficiently during the meeting.  

If done through individual interviews, the whole guide should be covered with the auction 
main point of contact and questions should be adapted for other operators based on the 
specific organisation of the auction and the type of operators interviewed. 

In any case, the objective is to have a good understanding of how marketing standards 
are implemented at auction level, how useful they are, if there any practical issues and 
what are the costs for the different types of operators (auction, sellers, buyers). 

As far as statistics are concerned in the background section, please ask for long-
term series (annual data) whenever available, or most recent year available if not possible 
to have series. Please also check if it is possible to have them in electronic and usable 
format (Excel, csv) rather than pdf. 

Country 

Auction location 

Interviewer name 

Date 

List of participants 

Introduction 

40 

 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

The  objective  of  the  evaluation  is  to  examine  the  relevance,  effectiveness,  efficiency, 
coherence and EU added value of the current marketing standards for fishery products, in 
accordance  with  the  Better  Regulation  Package  Guidelines.  The  regulatory  framework 
under evaluation is: 

-  Council  Regulation  (EEC)  No  2136/89  of  21  June  1989  laying  down  common 

marketing standards for preserved sardines; 

-  Council  Regulation  (EEC)  No  1536/92  of  9  June  1992  laying  down  common 

marketing standards for preserved tuna and bonito;  

-  Council  Regulation  (EC)  No  2406/96  of  26  November  1996  laying  down  common 

marketing standards for certain fishery products; and 

-  Regulation (EU) No 1379/2013 of the European Parliament and of the Council of 11 
December  2013  on  the  common  organisation  of  the  markets  in  fishery  and 
aquaculture products – Chapter III – Common Marketing Standards; 

Background on the auction: for the auction main point of contact 

1.   What was the volume of fish auctioned in 2017?   

2.  What was the value of fish auctioned in 2017? 

3.  What were the main species? 

4.  Who are the main sellers? 

5.  Who are the main buyers (wholesalers, foodservice, processing industry, retail…)? 

6.  What share of the fish landed in the port actually goes through auction? 

7.  Do  you  have  statistics  on  prices  for  some  of  the  main  products  sold  through  the 
auction by categories of size and freshness? Can you please provide them to us, if 
possible for the past 10 years? 

8.  Interviewer should show Annex I of the Regulation 2406/96 with the list of 
species covered by Marketing Standards. What are the main species sold in the 
auction that are not included in Annex I of the Reg. 2406/96?  Are there specific issues 
with  the  marketing  of  these  products,  due  to  the  fact  that  they  do  not  have  EU 
marketing standards? 

9.  Do you have statistics on the percentage of products not complying with marketing 
standards? Do you have a breakdown by species and/or by type of irregularity (not 
complying with minimum size, minimum freshness criteria, wrong grading)? Can you 
please provide them to us? 

10. Have inspections on EU Marketing Standards taken place at your auction? Y/N 

If Yes, ask the following questions 

11. When was the last time?  

12. In a 5-year period, how often would you expect inspections to take place?  

13. Do you remember the last time inspection resulted in sanctions?  

If Yes, how long ago was it? What were the sanctions on that occasion?  

Items to be discussed with operators 

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Relevance of criteria used by EU Marketing Standards  

14. Do  you  know  the  different  criteria  used  for  EU  marketing  Standards  (in  EU  Reg 

2406/96)? Can you provide an example please? 

If Not or examples provided do not correspond to EU marketing standards, interviewer should provide 
examples from the Annex I of EU Reg 2406/96 for relevant species. 

15. Are the size and freshness categories defined in EU marketing standards used to set 
prices  (e.g.  are  they  used  in  auction  sales,  contracts)?  Are  there  other 
references/criteria used to grade fish and set prices? Which ones?   

Implementation of EU marketing standards 

16. At what point is the fish sorted according to EU marketing standards (on board, at 
landing, at the auction)? Who is in charge? What are the tasks involved? How long 
does it take? Is the sorting automated or by hand? What are the costs involved? How 
is the grading controlled and by whom?  

17. What happens with products that do not comply with marketing standards? How often 
do buyers reject products because they do not comply with marketing standards? Do 
you think that most operators generally comply? Has the level of compliance changed 
over time? How and why? 

18. What  factors  have  most  impacted  how  EU  marketing  standards  are  or  should  be 
implemented over the past 10 years (regulatory changes, development of other norms 
and  standards,  sustainability  issues,  technological  changes,  changing demand  from 
consumers)? Please explain. 

Benefits of EU Marketing standards 

19. Do you think EU marketing standards are useful? In what ways do you think they are 
beneficial for your activity? Do they facilitate selling? Do they help to get better prices? 
Do  they  contribute  to  a  better  quality  of  products?  Are  there  any  other  positive 
impacts,  including  in  terms  of  broader  social  considerations,  such  as  fairness  of 
competition, transparency, sustainability or other environmental considerations?  

Conclusion  

20. On balance, do you think the benefits outweigh the costs involved? Do you think EU 
marketing  standards  should  be  kept  as  they  are,  or  that  they  should  be 
modified/updated, or that they should be removed? If you think that there should be 
changes, what are the two or three changes that should be given the highest priority? 

21. Would you accept to be contacted again to discuss the recommendations of this study? 

42 

 
 
 
 
 
 
 
 
 
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Thank you for your time! 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Final version of interview guidelines for professional organisations 

Evaluation of the marketing standards framework for fishery and aquaculture products 

Interview guide for professional organisations  

Only relevant questions for the products covered by the organisation should be asked. 

Country 

Auction location 

Interviewer name 

Date 

List of participants 

Introduction 

Interviewer to briefly introduce the objective of the evaluation and this interview 

The  objective  of  the  evaluation  is  to  examine  the  relevance,  effectiveness,  efficiency, 
coherence and EU added value of the current marketing standards for fishery products, in 
accordance  with  the  Better  Regulation  Package  Guidelines.  The  regulatory  framework 
under evaluation is: 

-  Council  Regulation  (EEC)  No  2136/89  of  21  June  1989  laying  down  common 

marketing standards for preserved sardines; 

-  Council  Regulation  (EEC)  No  1536/92  of  9  June  1992  laying  down  common 

marketing standards for preserved tuna and bonito;  

-  Council  Regulation  (EC)  No  2406/96  of  26  November  1996  laying  down  common 

marketing standards for certain fishery products; and 

-  Regulation (EU) No 1379/2013 of the European Parliament and of the Council of 11 
December  2013  on  the  common  organisation  of  the  markets  in  fishery  and 
aquaculture products – Chapter III – Common Marketing Standards; 

The questionnaire includes the following sections: 

-  Presentation of the organisation; 
-  Relevance of criteria used by EU marketing standards; 
-  Benefits and costs of EU marketing standards; 
-  Enforcement and compliance; 
-  Other standards and norms; 
-  Simplification of marketing standards; 
-  Conclusions and perspectives. 

Short presentation of the organisation interviewed 

1.  How  many  members  are  registered  in  your  organisation  and  what  is  their  profile 
(fishermen,  wholesalers,  processors,  etc.)?  Please  provide  some  figures  on  the 
representativeness of your organisation. 

44 

 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

2.  What are the main product types covered by your organisations (only fresh and chilled 

products, frozen products, preserved products, etc.)? 

3.  What are the main missions of your organisation? Do you (or your members in case of 
federations of organisations) have a role in the marketing of fishery products? Please 
explain.  

Relevance of criteria used by EU marketing standards  

4.  Do you know the different criteria used for EU marketing Standards? 

Fresh products 

Canned products 

Tunas and bonitos 

Sardines 

Size  

Type of fish (tuna or bonito), 

Freshness 
categories  

Provisions 
for 
products from third 
countries 
(information  to  be 
provided 
on 
packages, 
including  size  and 
freshness 
categories) 

Commercial  presentation  (solid/ 
chunks/ 
flakes/  grated-
shredded), 

fillets/ 

Culinary  preparations  (in  olive  oil/ 
natural/ in vegetable oil/ other), 

Ratio  between  the  weight  of  the 
fish contained in the container after 
sterilization  and  the  net  weight 
expressed in grams. 

Designations for sardines and sardine-
types products 

Commercial  presentation 
(sardines/ 
without  bones/  without  skin  or  bones/ 
fillets/ trunks/ other), 

Culinary preparations (olive oil/ natural/ 
refined  vegetable  oils/  tomato  sauce/ 
natural juice / marinade, with or without 
wine/ other), 

Ratio  between  the  weight  of  the  fish 
the  container  after 
contained 
the  net  weight 
sterilization  and 
expressed in grams, 

in 

Appearance of product in the container 
after sterilization (uniformed in size and 
in  orderly  manner/  no 
arranged 
significant  breaks, 
foreign 
free  of 
bodies, etc..).  

5.  In your view, to what extent are these EU Marketing Standards relevant to assess the 

quality of the products for both fresh and canned products?  

6.  In your view, to what extent is the price of fresh fish, crustaceans and molluscs set on 
the  basis  of  the  marketing  standards  (size  and  freshness  categories)?  What  are  the 
other criteria used? Is there a difference between EU and imported products? 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

7.  For other non-processed products that are NOT covered by Reg. 2406/96 (aquaculture 
products, other fresh wild fish not included in Annex I of the Reg. 2406/96 and frozen 
fish,  crustaceans  and  molluscs),  what  are  the  criteria  used  by  operators  to  assess 
quality and determine prices? 

8.  For  canned  sardines,  tunas  and  bonitos,  in  your  view,  to  what  extent  are  the  trade 
descriptions and composition provisions defined in EU marketing standards relevant for 
business-to-business activities?   

9.  For  other preserved and processed products,  what are the  references used  for trade 

descriptions and composition provisions? 

10. Do you think that EU marketing standards are relevant to final consumers?  

11. Do  you  think  that  technological  changes  (e.g.  e-commerce,  electronic  auctions, 
changes in the way products are manipulated, stored, controlled, etc..) have had an 
impact on the relevance of marketing standards or on the way they are implemented? 
Please explain. 

Benefits and Costs of EU marketing standards 

12. In what ways do you think EU Marketing Standards are beneficial for your members? 

Please describe the benefits 

13. In  what  ways  do  EU  Marketing  Standards  impose  costs  on  your  members?  Please 

explain the tasks and costs involved. 

14. On balance, do the marketing standards improve or reduce operators' profitability in 

the short-term or in the long-term? If so, how? 

15. Apart  from  any  effects  on  operators'  profitability,  do  you  think  there  are  benefits  or 
costs  in  terms  of  broader  social  considerations,  such  as  fairness  of  competition, 
transparency, sustainability, food waste reduction or environmental considerations?  

16.  What  factors  have  most  impacted  how  EU  marketing  standards  are  or  should  be 
implemented over the past 10 years (regulatory changes, development of other norms 
and  standards,  sustainability  issues,  technological  changes,  changing  demand  from 
consumers)? Please explain?  

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

17. Could the role of EU marketing standards be left to the market? If so, all functions or 

specific parts? Could you please explain? 

Enforcement and compliance 

18. How  often  are  you  or  your  members  likely  to  be  inspected  for  compliance  with  EU 

Marketing Standards during a 5-year period? On what aspects? 

19. In general, what are the consequences for operators if inspections find anomalies or 

irregularities? Do you think sanctions are adequate? 

20. Do  you  think  that  most  operators  generally  comply,  or  are  there  big  differences  in 

compliance rates between operators? If so, what might account for such differences? 

21.  Do you think that compliance has been improving or deteriorating? Do you have an 

explanation why? 

22. Are  you  aware  of  any  specific  issues  related  to  the  application  of  EU  marketing 

standards to imported products (from non-EU countries)? 

23.  Are  you  aware  of  trade  disputes  related  to  EU  marketing  standards?  What  are  the 
subjects of the disputes? How often do they happen? Has the frequency of this kind of 
dispute evolved over time? 

Other standards and norms 

24. What  are  the  other  standards  or  norms  (e.g.  private  certifications,  other  public 
standards, codes of practices) commonly used in your sector? Please specify the names, 
scope (products,  criteria, geographical scope), if they are voluntary or mandatory, if 
they are public or private, how they are set up and controlled and the relevant markets. 

25. When  those  standards/norms  apply  to  products  already  covered  by  EU  marketing 
standards, do you consider these standards/norms to be complementary, redundant or 
in conflict with EU standards? Please explain, and please explain what is the incentive 
to use them in addition to EU marketing standards? 

26. When  those  standards/norms  apply  to  products  NOT  covered  by  EU  marketing 
standards, do you think they are sufficient? Are there shortcomings? In your view, what 
difference  would  it  make  if  there  were  EU  marketing  standards  for  these  products? 
Please explain. 

47 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

27. In your opinion, how do the burden and costs caused by the implementation of these 

norms or standards compare to the burden caused by EU marketing Standards? 

Simplification of marketing standards  

28. For fresh products, would it be possible to simplify freshness and size criteria without 
compromising  the  effectiveness  of  marketing  standards?  Please  provide  specific 
examples. 

29. For imported fresh/chilled products, would it be possible to simplify the provisions for 
those  products  (country  of  origin,  scientific  name  and  trade  name,  presentation, 
freshness  and  size  categories,  net  weight,  date  of  grading  and  dispatch,  name  and 
address of consignor) without compromising the effectiveness of marketing standards, 
in  particular  considering  provisions  under  other  regulations  (hygiene,  conservation 
rules, etc.) that did not exist in 1996 ? Please provide specific examples. 

30. For  canned  products,  would  it  be  possible  to  simplify  the  standards'  requirements 

without compromising their effectiveness? Please provide specific examples. 

31. To  what  extent  could  controls  be  simplified  without  increasing  the  risk  of  non-

compliance? 

Conclusions and perspectives 

32. What do you think should be kept unchanged about EU marketing standards? Please 

explain why. 

33. What are the main changes that you would like to see? Please explain why. 

34. Would you be interested in being involved in the consultation that will be carried out to 

test the recommendations on marketing standards? 

35. Do you have any other comment? 

48 

 
 
 
 
 
 
  
 
 
 
Final version of interview guidelines for operators 

Interview guide for operators along the supply chain of fresh fish (other than fishermen)  

Country 

Auction location 

Interviewer name 

Date 

List of participants 

Introduction 

Interviewer to briefly introduce the objective of the evaluation and this interview 

1.  Please describe the main activities of your company (wholesale, retail, imports, etc.)? 

2.  What are your main products (main species and product forms)?  

3.  Please describe your main sources of supply (wild fish/aquaculture, imports/domestic, 

through auctions, wholesale markets or directly from producers, etc…)?  

4.  Who  are  your  main  clients  (wholesalers,  foodservice,  processing  industry,  retailers, 

final consumers…)? 

5.  What is your turnover in fish (for 2017)? 

6.  What is the volume of fish sold in a year (for 2017)? 

Relevance of criteria used by EU marketing standards  

7.  Do  you  know  the  different  criteria  used  for  EU  marketing  Standards  (in  EU  Reg 

2406/96)? Y/N 

8.  If 7=Yes, can you provide an example please? 

If  7=No  or  example  provided  does  not  correspond  to  EU  marketing  standards, 
interviewer should provide examples from the Annex I of EU Reg 2406/96 for relevant 
species. 

9.  Do you think the criteria used in EU marketing standards are relevant to assess the 

quality of fresh fish? To what extent does it depend on the species? 

−  Size: 

−  Freshness criteria (skin colour, flesh appearance, smell, eyes, etc..): 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

10. Do you rely exclusively on EU marketing standards categories (Extra/A/B or size) to 
assess the quality of fish? If not, please explain what you rely on to assess the quality 
of fish. 

11. Do  you  rely  on  EU  marketing  standards  to  determine  the  price  of  fresh  fish  from 
fisheries  (i.e.  size  and  category  of  freshness  Extra/A/B)?  What  other  factors  can 
influence prices? Can you rank those factors (including EU standards) by decreasing 
importance? To what extent does it depend on the market segments (e.g. foodservice 
vs retail)? 

12. For  companies  that  also  market  farmed  fish/frozen  or  processed  fish,  what  are  the 

criteria used to determine prices for those types of products?  

Implementation of EU marketing standards 

13. Can  you  please  briefly  describe  the  tasks  involved  with  the  implementation  of  EU 
marketing standards at your level (e.g. checking the compliance of purchased fish..)  
how long they take and how often they take place? 

14. Who  is  in  charge  of  sorting?  Who  is  primarily  responsible  for  ensuring  that  the 
standards are complied with? Please describe the role and responsibilities of the person 
in charge. 

15. What happens if you assess that products from your suppliers are not compliant with 

marketing standards, e.g. not correctly sorted/classified?  

16. What  happens  if  your  buyer  assess  that  your  products  are  not  compliant  with 

marketing standards, e.g. not correctly sorted/classified?  

17. Do  you  have  product  waste  as  a  result  of  EU  marketing  standards?  Please  explain. 
What does that represent in terms of % fish volume and value? Could that be avoided?  

18. Have you ever been inspected on EU Marketing Standards? Y/N 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

If 18=Yes, ask questions 19 to 22. 

19. When was the last time?  

20. In a 5-year period, how often would you expect to be inspected?  

21. Do you remember the last time inspection resulted in sanctions?  

22. If 21=Yes, how long ago was it? What were the sanctions on that occasion? 

23. Do you think that most operators more or less comply, or are there big differences in 
compliance rates between operators? If so, what might account for such differences? 

24.  Do you think that compliance has been improving or deteriorating? Do you have an 

explanation why? 

25. Are  you  aware  of  any  specific  issues  related  to  the  application  of  EU  marketing 

standards to imported products (from non-EU countries)? 

Benefits of EU marketing standards 

26. In what ways do you think EU Marketing Standards are beneficial for your activity?  

27. In what ways do EU Marketing Standards impose costs on your activity? 

28. On  balance,  do  the  marketing  standards  improve  or  reduce  your  profitability  in  the 

short-term or in the long-term? If so, how? 

29. Apart from any effects on your profitability, do you think there are benefits or costs in 
terms of broader social considerations, such as fairness of competition, sustainability 
or other environmental considerations? 

Other standards and norms 

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30. Do you use other types of standards or norms (e.g. private certifications, other private 

or public standards)?  

−  Which ones (please specify nature and origin)?  

−  For which species?  

−  For which markets?   

31. Are they related to product quality or other aspects (e.g. sustainability)? 

32. Do you consider these certifications to be complementary, redundant or in conflict with 
EU standards? Please explain, and please explain what is the incentive to use them in 
addition to EU marketing standards? 

33. For  companies  that  also  market  farmed  fish/frozen  or  processed  fish,  do  you  use 
private or public quality standards for those products? And if so which? What are the 
advantages?  Are there shortcomings? Please explain. 

34. In your opinion, how does the workload and costs involved by the implementation of 
those certifications or standards compare to the workload involved by EU marketing 
Standards? 

Simplification of marketing standards  

35. Would it be possible to simplify freshness and size criteria without compromising the 

effectiveness of marketing standards? Please provide specific examples.   

36. What do you think would change in your activity and in general if there were no more 
EU  marketing  standards?  Would  you  or  your  clients  require  new  standards  or 
certifications (e.g. private ones)? 

Other comments 

37. Do you have any other comment or suggestion to make to improve the situation with 

respect to EU marketing standards? 

52 

 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 11.  SUMMARY OF CASE STUDIES  

The  MSs  were  selected  as  they  include  a  large  proportion  of  the  EU  seafood  trade,  yet 
provide a range of scales and types of seafood markets across a number of different sea 
basins. 

All  stages  of  the  supply  chain  were  covered  in  the  6  MSs,  which  provided  a  general 
understanding of how marketing standards are implemented and used in the different MSs 
and  how  operators  deal  with  products  not  covered  by  EU  marketing  standards.  The 
fieldwork focused on the industry, through the national representative organisations and a 
sample of operators in each country. 

National authorities were contacted to follow up on the online survey and discuss specific 
points raised in their answers. The NAs also informed the main stakeholder organisations 
to help the planning of the interviews.  

Representative organisations assisted the team in identifying relevant targets and provided 
contact  information.  The  list  of  interviews  evolved  during  the  fieldwork  as  some 
stakeholders engaged with the evaluation and others chose not to. 

Depending on circumstances in the case study MS, the fieldwork included either 1 focus 
group  +  7  to  10  interviews  or  10  to  15  interviews  and  no  focus  group  (but  including 
individual  interviews  with  operators  going  through  auctions).  The  total  number  of 
interviews in the three larger countries (FR, ES and IT) was at the high end of these ranges 
to ensure a good overview of the sector. 

The marketing of fresh fish products included in Reg. 2406/96 was covered in the 6 MS 
through  interviews  with  national  organisations,  interviews  or  focus  groups  in  at  least  1 
auction and, where relevant, with wholesale and retail interests. In addition, there was the 
following thematic focus in each MS: 

•  FR: shellfish farming  

•  ES: shellfish farming, canning industry 

• 

IT: fish farming, canning industry 

•  NL: extra-EU trade 

•  DK: processing 

•  HR: fish farming, processing 

The  findings  are  based  on  six  case  studies  (DK,  ES,  FR,  HR,  IT  and  NL).  In  total  82  
individuals  from  the  fisheries  sector  contributed,  either  in  focus  groups  or  in  individual 
interviews.  In  addition,  10  written  contributions  were  received  in  IT.  The  interviewees 
reflect well the total distribution chain, from the catching sector to retail, as shown in the 
following table.  

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Table 6: Number of consulted stakeholders (persons participating in interviews and 
focus groups) 

DK 

ES 

FR 

HR 

IT 

NL 

Total 

Auction managers 

Catching sector  

Aquaculture sector 

Wholesalers 

Canning industry 

Other processing industry  

Retail 

Regional authority 

2 

2 

1 

3 

1 

5 

6 

8 

2 

6 

1 

2 

6 

5 

2 

1 

2 

2 

4 

3 

1 

4 

1 

2 

2 

1 

4 

2 

2 

1 

13 

24 

17 

7 

10 

7 

4 

2 

Total 

9 

28 

18 

5 

12 

10 

84 

11.1.  Fresh products from fisheries 

Level of knowledge 

Stakeholders involved in EU fisheries and landing fresh fish are in general well aware of 
the existence of the marketing standards. This applies particularly to species with which 
they are regularly working. They do not necessarily know exactly what the total content of 
the Regulation is in terms of all covered species, specific sizes and precise descriptions of 
the quality. In countries where specific additional standards apply, the stakeholders do not 
always know whether these standards are national or originate from the EU legislation.  

The  only  exception  is  HR,  where  the  stakeholders  in  the  catching  sector  were  not  well 
aware of the existence of the EU marketing standards. 

Criteria used at the different stages and relevance of marketing standards 

There  is  full  consensus  that  the  marketing  standards  are  highly  relevant  for  market 
transparency and price formation. Prices depend on 3 main aspects: supply and demand, 
size of fish and quality.  

Supply  and  demand  depend  on  the  specific  situation  of  the  moment,  i.e.  (expected) 
landings, stocks at wholesale / processing stage, delivery contracts, etc. This may lead to 
exceptional situations where smaller fish of lower quality fetches momentarily higher price 
than larger fish of better quality at another moment.  

Price  statistics  are  maintained  by  size  category,  which  illustrates  the  importance  of  this 
criterion. Despite the exceptions mentioned above, statistics show that on average larger 

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fish  is  always  better  priced.  Various  interviewees  indicated  (DK,  ES,  IT,  NL)  that  the 
‘market’  may  demand  other  /  more  detailed  size  classifications  than  those  set  in  the 
marketing standards. Such classifications may be used either directly at the auction (ES) 
or  in  subsequent  trade  (NL).  However,  this  does  not  mean  that  the  current  marketing 
standards should be changed. 

The  organoleptic  freshness  criteria  of  the  marketing  standards  are  applied.  Many 
respondents indicated that, when it comes to quality, the buyers also rely on the reputation 
of  the  vessel  from  which  the  fish  comes.  Other  important  aspects  are  the  time  elapsed 
since the catch, as it determines the shelf-life, and in some cases the fishing gear used. 
The interviews and the available statistics indicate that large part of the landings is quality 
A.  Fish  caught  shortly  before  landing  or  fish  from  small  scale  coastal  fisheries  will  be 
classified as Extra. The B quality is relatively rare, for various reasons: increasing quality 
awareness on board, available technologies and the importance attached to shelf life after 
landing  by  buyers.  The  marketing  standards  have  made  this  improvement  visible,  e.g. 
quality of landings of HR vessels at Trieste auction has improved thanks to accession to 
EU.   

Some  of  the  interviewees  are  of  the  opinion  that  the  quality  assessment  may  differ 
somewhat between auctions and MS. There are many quality criteria and although they 
are  linked,  it  is  up  to  the  individual  staff  member  at  the  auction  to  decide  on  the  final 
quality level (E-A-B). Such decision is taken  rather quickly, time not allowing to inspect 
fish in the boxes in detail. Experience of the auction staff plays an important role and a 
certain subjectivity cannot be avoided. In the end it is the buyer who must be satisfied and 
it  is  in  the  interest  of  the  vessel  owner  as  well  as  of  the  auction  to  provide  reliable 
information. 

The  marketing  standards  are  mainly  applied  at  first  sale  /  auction.  As  the  fish  passes 
through  the  chain,  their  application  becomes  increasingly  ‘difficult’.  Size  may  not  be 
recognizable  after  processing  and  quality  may  gradually  deteriorate  with  time.  The 
marketing  standards  related  to  size,  are  used  to  a  limited  extent  (or  implicitly)  at 
processing / wholesale stage, e.g. when whole (frozen) fish is traded.  Given the specificity 
of many market segments, the interviewees could not provide generalized details. There 
is  a  general  consensus  that  the  marketing  standards  as  such  have  no  relevance  at  the 
consumer / retail level, although size evidently plays a role in retail trade when fish is sold 
whole. The  stakeholders beyond the  first sale  are relatively more concerned  with issues 
like complexity of labels, commercial designations and cost of traceability. 

Tasks and costs involved 

Fish  sold  through  auctions  is  usually  size  /  quality-graded  according  to  the  marketing 
standards, although exceptions have been reported in ES and IT. The grading takes place 
on board or in the auction. The buyers may  size-grade the fish further according to the 
demand of their clients (e.g. NL). Size-grading is done either by hand (important part of 
white fish) or mechanically1 (some plaice, shrimp, small pelagics). Fish sold on contract 

1 Mechanical grading takes place on shore. 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

and delivered directly to processing plants is size-graded on board and/or at the buyer’s 
premises, in which case the marketing standards may or may not be applied.  

The specific costs have been presented for some MS (NL, DK). However, there is a general 
agreement that if the present marketing standards would not exist, a comparable system 
would  have  to  be  developed  and  the  costs  would  be  similar.  Consequently,  many 
interviewees believe that the marketing standards as such do not lead to additional costs, 
in comparison with other systems. The marketing standards play a decreasing role as the 
fish passes through the chain so that the interviewees  could not pin point specific costs 
related to marketing standards in wholesale, processing or retail. 

Compliance issues and trends 

All case studies indicate that compliance is not a problem. The controls are carried out with 
different intensities in different auctions and MS, from continuous to occasional. It is not 
always  possible  to  distinguish  between  controls  of  marketing  standards  and  controls  of 
other Regulations (minimum conservation reference sizes, logbooks, hygiene, etc.).  

Identification of non-compliance is very rare. In such cases, the vessel owner or trader are 
given a warning or advice how to prevent this in the future. There is no evidence at all of 
any  legal  proceedings  or  imposition  of  fines  due  to  non-compliance  with  the  marketing 
standards.  

It seems likely that compliance with the marketing standards is not only a result of legal 
obligation,  but  at  least  as  much  a  result  of  the  relation  between  the  trading  partners. 
Meeting  agreed  characteristics  of  the  product  is  important  to  maintain  the  necessary 
mutual trust between sellers, buyers and facilitators (auctions and wholesale markets).  

Main perceived benefits 

The case studies show a very consistent view on the benefits of the marketing standards 
in relation to market transparency and level playing field. The marketing standards set one 
basic common denominator for the classification of the main landed species. The fact that 
they do not always reflect exactly the size classification required by the following chains in 
the market does not compromise the importance of having one standard classification at 
first sale. 

The main benefits occur at first sale. The relevance of the marketing standards decreases 
as the product passes through subsequent chain links. There are no direct benefits to the 
consumers.  

Other norms and standards used 

Although other norms are used in the fresh fish chain, no conflict or overlap between them 
and the marketing standards has been mentioned. These norms are complementary and 
serve other specific purposes: 

•  MSC and ASC for sustainability; 
•  HACCP, ISO, BRC, IFS for quality assurance during the production process; 
•  BSCI for social responsibility. 

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In some cases specific ‘local’ norms have been developed, e.g. QIM (Urk, NL) and specific 
rules for bivalves in FR (which are not under the marketing standards). 

Recommendations (simplification, removal) 

There is a general agreement that the marketing standards should remain as they are. The 
system has worked for a long time well and all stakeholders are used to it. Some of the ES 
interviewees  are  of  the  opinion  that  the  marketing  standards  could  be  removed,  but 
nothing would change. The marketing standards are well adapted to daily practice of first 
sale and seem to be based on it. The stakeholders agree that the marketing standards do 
not impose any additional costs. 

It is desirable to clarify what the role of the marketing standards is beyond the first sale. 
The case studies show that while the marketing standards play an important role at first 
sale / auction, their purpose, implementation and control throughout the following steps in 
the chain is not clear.  

Several very specific recommendations have been made by interviewees: 

•  DK: several new species could be added: witch, turbot and halibut. 
•  DK: for some species the largest size class should be further split, e.g. cod:12 kg, 

hake > 4 kg. 

•  DK and ES: the differences in MCRS for some species should be eliminated, as it 
may  lead  to  problems  in  the  chain.  This  regards  mackerel  in  the  North  Sea  and 
Western waters and hake in Atlantic and Mediterranean. 

•  FR:  control  should  be  strengthened  and 

further  harmonization  of 

the 

implementation should be pursued. 

•  HR: attention should be given to dissemination of information about the marketing 

standards applicable to the fresh fish sector. 

•  NL: shrimp minimum size should be increased from 6.5 to 6.8 mm in order to ensure 
that MSC certification will not be jeopardized by a small number of non- producer 
organisation (PO) producers. It was suggested that it could be supplemented with 
a maximum count per kg. 
IT: canning industry strongly recommends not to change anything in the relevant 
regulations. 

• 

•  ES:  harmonization  of  minimum  marketing  sizes  for  species  that  have  different 

MCRS, depending on the origin. 

•  General:  clarification  is  required  regarding  the  application  and  control  of  the 

marketing standards after first sale. 

11.2.  Canned sardines and tunas2 

Level of knowledge 

The representatives of the canning industry are all very well acquainted with the marketing 
standards as they are very relevant to their daily operation. 

2 This section is based on case studies from ES, FR and IT 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Criteria used at the different stages and relevance of marketing standards 

The  criteria  defined  in  the  two  Regulations  in  terms  specification  of  species,  covering 
medium and product form are  considered highly  relevant throughout the chain. As they 
reflect the nature of the contents of the can, they also reflect the costs of the raw materials 
used and consequently the price of the final product. 

Some ES interviewees outside the canning industry pointed out that the term ‘sardine-type 
products’ in combination with the Latin name  of the species used  can be misleading for 
final consumers who lack the detailed knowledge. 

Tasks and costs involved 

The tasks involved in implementing the marketing standards are checking quality of raw 
material,  defining  products  characteristics,  labelling,  controlling  the  quality  of  final 
products, incl. the weight after sterilization. These tasks are integral part of the production 
process and the canning companies have their own laboratories for quality monitoring.  

As the above tasks would have to be implemented even if marketing standards would not 
exist, the marketing standards do not increase the production costs. 

Compliance issues and trends 

Interviewees in the four relevant MS (ES, FR, HR, IT) indicated that there is high level / 
full compliance with the Regulations. Only one case of non-compliance could be mentioned 
in FR, but that was quickly solved in cooperation between the industry and the authorities. 
There  have  been  no  legal  procedures  against  canning  companies  in  relation  to  the 
marketing standards. 

Main perceived benefits 

Marketing  standards  promote  a  level-playing  field  (between  EU  and  non-EU  products), 
ensure  minimum  quality  and  contribute  to  the  positive  image  of  the  products.  They 
stimulate fair competition, based on the transparent choice of raw materials. The fact that 
marketing  standards  apply  throughout  the  supply  chain  obliges  all  operators  to  deliver 
good quality products to the consumers.  

It is important for the canning industry that the marketing standards provide a solid basis 
for  the  main  products,  while  they  do  not  impose  restriction  on  development  of  new 
products. 

Other norms and standards used 

FR and IT interviewees have pointed to a large number of standards which play specific 
roles in the production processes and marketing, e.g. Friend of the Sea, MSC, Dolphin safe, 
BRC, IFS, and of course ISOs and HACCP. Some of the private standards and certification 
schemes are increasing their impact on trading practices. Although they are voluntary they 
may  become  de  facto  mandatory  when  compliance  is  imposed  by  big  retailers.  In  such 
situations  certification  and  /  or  other  market  requirements  become  new  marketing 
standards. 

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These norms pursue specific aims and they are complementary to the marketing standards.  

Recommendations (simplification, removal) 

There is full consensus among the case studies that the marketing standards for canned 
products serve well their purpose and therefore should certainly not be removed or even 
simplified.  

Some  interviewees  have  expressed  fear  that  intention  to  adapt  the  present  Regulations 
will open discussion among all MS, while only very few are really involved in canning tuna 
and sardines. This may become a time consuming exercise for the stakeholders and it could 
have undesirable consequences. 

Expansion of marketing standards to new species (e.g. calamar) may be considered, but 
preferably  should  be  avoided  as  only  few  MS  or  producers  are  involved,  which  may  not 
justify a generic (EU-wide) standard. The small number of producers makes it also feasible 
to agree on a common private standard, which is consistent with the subsidiarity principle.   

11.3.  Aquaculture products (fresh) 

Criteria used at the different stages  

Criteria to classify aquaculture products are quite comparable to those used in the fisheries 
sector.  Prices  depend  on  supply  and  demand,  size  and  sometimes  other  criteria,  e.g. 
country of origin or the reputation of the producer. 

The  fish and some shellfish is classified by size. The size  classes are determined by the 
clients, often the supermarket chains.  

The quality is a determinant for shelf-life. As aquaculture has a regular production process, 
the quality is determined by the date the fish has been harvested and slaughtered. 

In some MS national standards exist, often specified by the industry itself.  These standards 
exist in relatively small market niches and seem to have little effect on internal market. 

Other norms and standards used  

FR and IT indicate that national or sectorial norms have been formulated for specific farmed 
specie. In IT aquaculture farms use various private, voluntary certifications, like HACCP, 
ISOs, IFS, Global gap and BRC.  

Recommendations (simplification, removal) 

The  stakeholders  in  the  aquaculture  sector  do  not  see  any  need  to  formulate  EU  wide 
marketing standards for their products. The present situation offers them the flexibility to 
meet closely the demands of their buyers in terms of sizes. Quality is guaranteed as food 
safety  and  similar  legislation  is  applicable.  Other  objectives  of  the  marketing  standards 
(market  transparency)  does  not  seem  to  be  sufficiently  important  argument  for  the 
aquaculture representatives to plead for introduction of marketing standards in this sector. 

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11.4.  Other processed products 

Criteria used at the different stages  

Other processed products are mainly fresh products based on species not mentioned under 
the marketing standards, frozen, smoked and dried products and canned products other 
than tunas and sardine-type species. The trade practices are similar whether the product 
is of EU origin or imported. 

Criteria used are determined by the precise needs of the buyers and consumer demand. 
The  characteristics  of  processed  products  are  ‘demand-driven’,  e.g.  weight  of  fillets  or 
portions,  which  may  differ  between  MS.  Production  processes  take  into  account  the 
different requirements in different markets in their product range. 

Other norms and standards used  

Standards used for other processed products regard production processes, hygiene, food 
safety  etc.  They  are  identical  to  standards  already  mentioned:  MSC  and  ASC  for 
sustainability; HACCP, ISO, BRC, IFS for quality assurance during the production process; 
BSCI for social responsibility. 

Non-EU producers must be certified as ‘authorized establishments’ to be allowed to export 
to the EU (Regulation 854/2004).  

Recommendations (simplification, removal) 

Apart from coincidentally mentioned products (e.g. smoke trout fillets in DK), there does 
not seem to be any need for introduction of EU marketing standards for other processed 
products.  Should  such  need  arise,  FR  recommends  to  harmonise  the  national  standards 
through the European Committee for Standardisation (ECS). 

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ANNEX 12.  QUESTIONNAIRE FOR THE RECOMMENDATIONS 

Evaluation  of  the  marketing  standards  framework  for  fishery  and  aquaculture 
products 

Consultation on preliminary recommendations 

Identification 

Name: 
Organisation: 
Email address: 
Type of organisation (company/ trade organisation/ 
public authority/ NGO/ individual/other): 
Sector 
wholesale/ retail/ other) 

aquaculture/ 

processing/ 

(fisheries/ 

Recommendations on the specific Marketing Standards Regulations 

The evaluation has found that although the scope and criteria used in individual regulations 
are generally considered adequate, some specific issues were raised either by stakeholders 
or during the analysis. Recommendations are proposed below to address those issues.  

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Recommendations 

Fresh products (reg. 2406/96) 

R1: Keep the current regulation as it is. 

R2: The present regulation could be removed and its content re. size 
and freshness grades provided as an EU ‘Recommendation' in order to 
take into account the difficulty to implement the grading in some cases 
(e.g. absence of auctions or small volumes landed for each species).  

R3: If R2 is implemented, the article about Minimum Conservation 
Reference Sizes constituting Minimum Marketing Sizes should remain 
in the CMO Regulation. as this allows to apply the same minimum sizes 
to EU and non-EU products from the same sea areas. 

R4: If the Regulation remains, it should include an exemption from the 
obligation to control marketing standards beyond the first sale in the 
EU (including imports). 

R5:  Keep freshness criteria as they are despite inconsistency of the 
implementation, as the existing system can be implemented at a fairly 
low  cost,  through  visual  checks  whereas  suggested  improvements 
would  either  significantly  raise  the  implementation  costs  or  would 
reduce the effectiveness of marketing standards 

R6: Quality specifications for crustaceans should be revised to better 
take into account the specificities of those products (e.g. specify that 
shrimps should not stick to each other) 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

R7: Provide one single up-to-date list of applicable minimum sizes in 
length  (MCRS)  and  weight  (MMS)  in  order  to  reduce  possible 
misinterpretation due to scattered information. 

Preserved sardines and sardine-type products (reg. 2136/89) 

R8:  Request  an  assessment  of  the  technical  applicability  of 
presentations,  trade  descriptions  and  minimum  weight  requirements 
to sardine-type products and clarify the text accordingly as the current 
text  leads  to  different  interpretations  as  whether  some  of  those 
specifications  apply  only  to  Sardina  Pilchardus  or  to  all  the  species 
covered by the Regulation.  

Preserved tuna and bonitos (Reg. 1536/92) 

R9:  Request  an  assessment  the  similarity  between  the  product 
characteristics  of  Auxis  species  and  other  species  authorised  in  the 
Regulation  and  in  particular  in  the  ‘bonito’  category,  as  well  as  the 
socio-economic impact of potentially removing those species as those 
species are not authorised under the Codex standards. 
R10:  Clarify  the  legal  obligations  under  the  current  regulation  as 
regards the possible use of commercial designations of specific species 
in addition to the terms ‘tuna’ and ‘bonito’. 
R11: Strengthen controls on the use of trade designations in order to 
avoid fraudulent practices.  

Please comment on your above assessment and explain the potential benefits or risks 
associated with these recommendations (refer to specific recommendations by using the 
numbers R1, R2, etc.) 

Perspectives on the role of Marketing Standards within the CMO framework  

The following questions explore if and how different types  of marketing standards  could 
better contribute to achieving the CMO objectives (sustainability, functioning of the internal 
market, competitiveness of the EU producers, level-playing field). 

If you are in the fishery and aquaculture sector, do your clients (or your members’ clients) 
already  include  product  specifications  related  to  sustainability  (environmental  and/or 
social)? Yes/No 

If Yes,  

a.  please indicate which ones: 

b.  In your opinion, would there be an interest in harmonising this information at 

EU level, please explain why or why not? 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Considering  that  EU  marketing  standards  apply  by  definition  to  both  EU  and  non-EU 
products  and  can  deal  with  product  specifications  primarily  relevant  in  business-to-
business activities, 

a.  Are there commonly used specifications or trade descriptions that could be worth 

harmonising at EU level? Which ones? What would be the difficulties? 

b.  Are there other minimum requirements that could be established, for all products 
marketed in the EU, in order to improve the level-playing field between EU and 
imported products? 

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ANNEX 13.  SUMMARY  OF  ANSWERS 

TO 

THE 

CONSULTATION  ON 

RECOMMENDATIONS  

Overview of profile of respondents  

The questionnaire was sent to the stakeholders consulted during the data collection phase 
who  declared  welling  to  participate  to  the  consultation  phase  on  recommendations, 
including the OPC respondents. In total, 31 respondents participated to the consultation 
on recommendations and answered the questionnaire, from Spain (9 answers), Italy (6), 
Denmark (5), France, (5), Netherlands (3), Croatia (2) and Estonia (1). We noticed a good 
level  of  feedback  from  respondents  that  have  been  met  during  the  consultation  phase. 
However, we had little feedback from the OPC respondents (6 respondents). Some answers 
correspond to more than one respondent. In Spain, we received a collective single answer 
from an organisation and 4 producers involved in production of Mejillon de Galicia. We also 
received  three  collective  answers  from  respondents  in  France  Denmark  and  Netherland. 
Out  of  the  31  respondents,  16  were  professional  organisations  involved  in  fishery  and 
aquaculture  products  (fresh  or  processed),  8  were  private  companies,  3  were  public 
authorities,  2  were  NGOs,  1  was  private  research  centre  and  another  was  an  auction. 
Overall, most respondents cover more than one sector: 16 respondents represented the 
fishery  sector,  12  the  aquaculture,  10  the  processing  sector,  7  were  involved  in 
wholesale/trade,  2  represented  the  retail  sector  and  1  respondent  represented  another 
sector.  

This  sample  is  not  statistically  representative  and  the  feedback  gathered  should  be 
considered  as  only  an  indication  of  the  relevance  and  applicability  of  suggested 
recommendations. 

Figure 7: Breakdown of respondents by type of organisation  

Nbr 

 Professional organisation 
 Private company 
 Public Authority 
 NGO 
 Private research center 
 Auction 

Total 

16 

8 

3 

2 

1 

1 

31 

Source: Consultation on recommendations, N=31  

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Figure 8: Breakdown of respondents by sector  

Nbr 

 Fisheries 
 Aquaculture 
 Processsing 
 Wholesale/trade 
 Retail 
 Other 

Total 

16 

12 

10 

7 

2 

1 

31 

Source: Consultation on recommendations, N=31  

Fresh products (regulation 2406/96) 

Table 7: Answers to the question: do you agree with the following 
recommendations?  

No 
response 

Strongly 
agree 

Agree 

Neither 
agree nor 
disagree 

Disagree 

Strongly 
Disagree 

Not my 
area of 
expertise 

R1 

R2 

R3 

R4 

R5 

0.0% 

19.4% 

6.5% 

19.4% 

12.9% 

16.1% 

25.8% 

0.0% 

3.2% 

16.1% 

6.5% 

12.9% 

32.3% 

29.0% 

3.2% 

12.9% 

35.5% 

3.2% 

6.5% 

9.7% 

29.0% 

0.0% 

6.5% 

6.5% 

25.8% 

9.7% 

3.2% 

48.4% 

0.0% 

19.4% 

35.5% 

9.7% 

9.7% 

3.2% 

22.6% 

Total 

0.6% 

12.3% 

20.0% 

12.9% 

10.3% 

12.9% 

31.0% 

Source: Consultation on recommendations, N=31 

R1: Keep the current regulation as it is. 

From 31 respondents, 8 respondents indicated that this is out of their area of expertise. 
Out of the 23 respondents concerned by this recommendation, 8 responded that they agree 
(2 answers) or strongly agree (6 respondents) with this recommendation.  

Table 4 indicated that respondents who agree with this recommendation are mainly from 
countries  where  marketing  standards  are  well  known,  understood  and  implemented  by 
stakeholders  (e.g.  France,  Denmark  and  Netherlands).  However,  although  marketing 
standards are well known and implemented in Spain, stakeholders rather disagree to keep 
this regulation as it is now. Respondents who agreed the most with this recommendation 
are respondents involved in wholesale/trade sector. 

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Stakeholders who agree with this recommendation recall the importance of this regulation 
to constitute a shared bases for analysing freshness all along the supply chain as well as 
the  importance  of  size  grading  in  price  formation.  They  indicate  that  the  transparency 
ensured by this regulation justify why it should be maintained. One of these respondents 
recall the necessity of reinforcing the uniformity of its application.  

R2:  The  present  regulation  could  be  removed  and  its  content  re.  size  and 
freshness  grades  provided  as  an  EU  ‘Recommendation'  in  order  to  take  into 
account  the  difficulty  to  implement  the  grading  in  some  cases  (e.g.  absence  of 
auctions or small volumes landed for each species). 

From the 31  respondents to this questionnaire, 9 indicated that the issue is out of their 
area  of  expertise.  Out  of  the  22  respondents  concerned  by  this  recommendation,  6 
indicated that they agree (5 respondents) or strongly agree (1 respondent). Respondents 
who agreed the most with this regulation include respondents from retail.  

Table 4 indicated that respondents who agree with this regulation are mainly from countries 
where the consultation phase  showed that marketing standards are not well known and 
understood  by  stakeholders  and  thus  not  well  implemented  (i.e.  Croatia  and  Italy). 
Although, the consultation phase showed that marketing standards are well implemented 
in Spain, respondents from Spain to this questionnaire, 3 out of 7 respondents concerned 
by this recommendation (2 respondents indicated this recommendation is out of their area 
of expertise) agree with it.  

One  of  the  respondent  who  agree  to  remove  the  regulation  commented  that  freshness 
could be removed but not sizes explaining that thy are very subjective and they have never 
been implemented effectively. 

Respondents  who  disagree  with  this  recommendation  emphasize  the  risk  of  removing 
freshness  criteria  on  the  market.  One  of  these  respondents 
indicated  that 
recommendations  make  compliance  more  difficult  which  harm  market  transparency  and 
fair competition. Another respondent indicated that removing freshness criteria would have 
strong  impact  on  products  from  small  scale  fishing  as  they  are  mostly  classified  in  the 
category Extra which allow to get good prices. In addition, as marketing standards support 
the  selling  through  electronic  auctions,  removing  this  regulation  will  hinder  the 
development  of  this  new  selling  model.  According  to  some  stakeholders,  removing 
marketing  standards  could  ultimately  lead  to  the  disappearance  of  freshness  categories 
and would undermine the steps undertaken to improve products quality in the EU.  

Opinions of stakeholders involved in the fisheries sector (who are the most concerned by 
R1  and  R2)  concerning  the  two  first  recommendations  seemed  shared  between 
stakeholders who agree with them  and others who disagree.  

R3.  If  R2  is  implemented,  the  article  about  Minimum  Conservation  Reference 
Sizes  constituting  Minimum  Marketing  Sizes  should  remain  in  the  CMO 

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Regulation,  as  this  allows  to  apply  the  same  minimum  sizes  to  EU  and  non-EU 
products from the same sea areas. 

21  respondents  indicated  they  are  concerned  by  this  recommendation  (9  respondents 
indicated that this recommendation is out of their area of expertise and 1 did not answer 
the question).  

Out of the 21 respondents concerned by this recommendation, 15 respondents indicated 
that they agree (11) to strongly agree (4) with it. Respondents who agreed the most with 
this recommendation include respondents from retail and aquaculture sectors, followed by 
respondents from the fisheries sector. Respondents to this question did not comment their 
answers.  

R4:  Quality  specifications  for  crustaceans  should  be  revised  to  better  take  into 
account the specificities of those products (e.g. specify that shrimps should not 
stick to each other) 

16  respondents  declared  concerned  by  this  recommendation  (15  respondents  indicated 
that  this  recommendation  is  out  of  their  area  of  expertise).  Out  of  the  16  respondents 
concerned by this recommendation, 4 respondents agree (2 agree and 2 strongly agree) 
and 4 disagree with it (2 disagree and 2 strongly disagree). Opinions of stakeholders from 
the  different  sectors  on  this  recommendation  seem  the  closest3  (stakeholders  the  most 
agree  with  this  recommendation  are  those  involved  in  wholesale/trade,  followed  by 
processing and aquaculture, etc.).  

One of the respondents who agree with this recommendation indicated that the revision of 
quality  specifications  of  crustaceans  is  important.  However,  this  requires  to  analyse  the 
additional  costs  and  the  feasibility  of  implementing  any  specification,  particularly  when 
products  have  to  be  sorted  onboard  (e.g.  the  space  onboard  of  the  vessels).  Another 
respondent  indicated  that  there  is  no  additional  benefit  from  adding  other  quality 
specification as long as these quality specifications are managed between producers and 
buyers.  One  of  the  respondents  who  disagree  with  this  recommendation  indicated  that 
there is no other option and the only way to qualify crustaceans are either dead or alive.  

R5:  Provide  one  single  up-to-date  list  of  applicable  minimum  sizes  in  length 
(MCRS) and weight (MMS) in order to reduce possible misinterpretation due to 
scattered information 

24  respondents  provided  their  opinion  on  this recommendation  (7  respondents  declared 
not concerned by this recommendation). Two respondents who are not directly involved in 
fresh fish (one in aquaculture and the second in processing) answered this question. Out 
of the 24 respondents concerned by this recommendation, 17 agree (6 strongly agree and 
11 agree) with it.  

There is a clear trend that respondents tend to agree with this recommendation. This trend 
concerns all sectors consulted (fishing, aquaculture, processing, retail, wholesale / trade 

3 This means that the rates of positive feedbacks (agree or strongly agree) in comparison to the total number of respondents 
involved in each sector are almost equivalent.  

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Evaluation of the marketing standards framework for fishery and aquaculture products  

and  others).  Stakeholders  who  agree  the  most  with  this  regulation  are  from  Croatia, 
France,  Italy  and  Netherlands.  In  addition,  respondents  provide  additional  thoughts  on 
recommendations  that  could  be  implemented  in  fresh  fish.  Particularly,  one  respondent 
indicated  that  in  addition  to  the  species’  sizes,  it  is  important  to  provide  the  control 
authorities  with  a  list  of  the  common  local  names  of  species.  Another  respondent 
emphasized the fact that the importance for the sector is to have minimum sizes in cm and 
not in weight which facilitate the control.  

Preserved products (regulation 1536/92 and regulation 2136/89)  

Table 8: Answers to the question: do you agree with the following 
recommendations? 

Strongly 
agree 

Agree 

Neither 
agree nor 
disagree 

Disagree 

Strongly 
Disagree 

Not my 
area of 
expertise 

R6 

R7 

R8 

R9 

13.3% 

23.3% 

6.7% 

0.0% 

3.3% 

53.3% 

6.5% 

12.9% 

9.7% 

0.0% 

16.1% 

54.8% 

6.5% 

9.7% 

12.9% 

3.2% 

6.5% 

61.3% 

22.6% 

12.9% 

6.5% 

3.2% 

3.2% 

51.6% 

Total 

12.2% 

14.6% 

8.9% 

1.6% 

7.3% 

55.3% 

Source: Consultation on recommendations, N=31 

R6: Apply presentations (“without bones”, “filets”, etc.), trade descriptions (olive 
oil,  other  refined  vegetable  oils,  tomato  sauce,  marinade,  etc.)  and  minimum 
weight  requirements  to  sardine-type  products  (e.g.  sprat,  herring,  sardinella, 
anchovy, Pacific/South Atlantic pilchard). 

14  respondents  indicated  they  are  concerned  by  this  recommendation  (17  respondents 
indicated  that  this  recommendation  is  out  of  their  area  or  expertise).  Out  of  the  14 
respondents  concerned  by  this  recommendation,  11  respondents  agree  (4  respondents 
strongly disagree and 7 respondents agree), 2 respondents neither agree nor disagree and 
only  one  respondent  strongly  disagree.  Respondents  who  agree  the  most  with  this 
recommendation  are  stakeholders  involved  in  retail.  Opinions  of  stakeholders  from  the 
industry  sector  are  shared.  Respondents  who  agree  emphasize  the  necessity  of 
harmonisation of the information communicated to consumers for both sardine and sardine 
type species and limit the sources of different interpretations. Stakeholders from Croatia, 
France and Italy agree the most with this regulation.  

R7: Include the following provision from Codex in the regulation: “The name of 
the product may be qualified or accompanied by a term descriptive of the colour 
of  the  product,  provided  that  the  term  "white"  shall  be  used  only  for  Thunnus 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

alalunga  and  the  terms  "light",  "dark"  and  "blend"  shall  be  used  only  in 
accordance with any rules of the country in which the product is sold”. 

14 respondents indicated that they are concerned by this recommendation (17 respondents 
indicated  that  this  recommendation  is  out  of  their  area  of  expertise).  Out  of  the  14 
respondents  concerned  by this recommendation, 6  respondents agree (2  strongly agree 
and  4  agree),  3  respondents  neither  agree  nor  disagree  and  5  respondents  strongly 
disagree  with  it.  Overall,  stakeholders  involved  in  processing  tend  to  disagree  with  this 
recommendation. Overall, stakeholders in all countries tend to agree  with R7, except in 
Croatia (with only one respondent) who tend to disagree with this recommendation. One 
of  respondents  who  strongly  disagree  indicated  that  this  information  will  complicate 
commercial designations of products without additional benefit for consumers. In addition, 
most  respondents  who  disagree  with  this  recommendation  indicated  that  the  term  of 
“blend” cannot be used in accordance with the EU regulation as the mixing of different tuna 
species is not permitted.  

Another  respondent  indicated  that  these  terms  are  already  fixed  in  different  versions  of 
the EU regulation (EEC) No 1536/92 (namely ES, PT, FR, DE, IT) and that only Thunnus 
alalunga may have this name4.  

R8:  Reconsider  the  inclusion  of  Auxis  species  (not  included  in  the  Codex 
standards) in the list of species authorised for canned tunas and bonitos. 

12 respondents indicated that they are concerned by this recommendation (19 respondents 
indicated  that  this  recommendation  is  out  of  their  area  of  expertise).  Out  of  the  12 
respondents  concerned  by  this  recommendation,  5  respondents  agree  (2  respondents 
strongly  agree,  3  respondents  agree),  4  respondents  neither  agree  nor  disagree  and  3 
respondents disagree (1 respondent disagrees and 2 respondents strongly disagree) with 
it.  Stakeholders  involved  in  the  processing  sector  tend  to  disagree  with  this 
recommendation. Only respondents from Netherlands (one respondent) and Italy tend to 
agree with it.   

Respondents  who  agree  with  this  recommendation  indicated  that  reconsidering  the 
inclusion  of  Auxis  could  limit  fraudulent  practices  to  mislead  consumers.  Two  of 
respondents who strongly disagree highlighted the fact that current regulation ensure that 
the most valuable tuna species have different designations than Auxis species.  

R9: Add a provision in the Regulation to specify the trade designations that can 
be used for the products listed in Annex I in order to avoid fraudulent practices. 

15 respondents indicated that they are concerned by this recommendation (16 respondents 
indicated  that  this  recommendation  is  out  of  their  area  of  expertise).  Out  of  the  15 
respondents  concerned  by  this  recommendation,  11  respondents  agree  (7  respondents 
strongly agree and 4 respondents agree), 2 respondents neither agree nor disagree and 2 
respondents disagree (1 disagree and 1 strongly disagree). While, stakeholders from the 

4  It  has to  be  noted that  the  provision  to  which the  respondent made  reference  do  not  concern the color  of  the  species  but  it 
concerns the local vernacular name of Thunnus alalunga according to the languages.  

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Evaluation of the marketing standards framework for fishery and aquaculture products  

retail sector tend to agree with this recommendation, stakeholders from wholesale/trade 
rather disagree with it. Respondents from Croatia, France and Italy agree the most with 
this recommendation.  

Only  two  respondents  who  agree  with  this  recommendation  commented  on  this.  They 
indicated  that  national  lists  have  to  be  in  line  with  the  EU  regulation  in  order  to  avoid 
fraudulent practices.  

Only one respondent from those who disagree with this recommendation commented on 
this, saying that this is not necessary, as this concerns fraudulent practices. To cope with 
this situation, control should be reinforced.  

Perspectives on the role of Marketing Standards within the CMO framework  

•  Harmonisation of sustainability information  

In this section, stakeholders were asked if their clients (or their members’ clients) already 
include  products’  specifications  related  to  sustainability  (environmental  and/or  social). 
83% of respondents answered yes. When asked about the type of specifications related to 
sustainability  required  by  respondents’  clients/members’  clients,  most  of  respondents 
mentioned certifications rather than type of specifications. MSC for fishery products and 
ASC  for  aquaculture  products  were  the  most  common  certifications  indicated  by 
respondents. Other types of certification were mentioned such as Friend of the Sea, Global 
Gap, Dolphin Safe, etc.  

Only  two  respondents  indicated  what  could  be  these  specifications.  They  mentioned 
specifications  that  may  concern  fish  (e.g.  species,  size,  species  stocks,  etc.),  fishing 
method (e.g. seine, with or without DCP), certification, landing port, ethical certification of 
processing sites, etc.  

Figure 9: Answers to the question: Do your clients already include product 
specifications related to sustainability (environmental and/or social)?  

Yes

No

17%

83%

Source: Consultation on recommendations  

When asked if there would be an interest in harmonising sustainability information at EU 
level,  stakeholders’  opinions  were  divided  between  those  who  agree  with  the  need  for 
harmonisation and those who disagree with it. The respondents profiles are very different 
and  we  cannot  conclude  whether  there  are  specific  type  of  respondents  who  agree  and 

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others who disagree with harmonisation at EU level. The table below represents the main 
comments indicated by 24 respondents to argue their opinions.   

Table V – Summary of the main comments indicated by respondents who agree 
and disagree with harmonising sustainability information at EU level  

Agree 

Disagree 

-  A  harmonised  information  regarding 

•  Complicated to implement as many 

sustainability would: 
•  help consumers make their choices 
regarding sustainable products.  
•  Increase transparency all along the 

supply chain.  

•  Increase  the  value  and  promote 
reared 
caught 

or 

products 
sustainably.  

-  Even though private standards cover a 
significant  share  of  fisheries  market, 
many  operators  are  open  for  simpler 
and more cost-effective standards.  
-  One  of  the  respondents  highlighted 
the  necessity  to  adopt  a  gradual 
information about sustainability. They 
consider  that  there  is  no  sustainable 
and  unsustainable.  But  all  fishing 
activities has more or less an impact.  

Source: Consultation on recommendations  

criteria could be considered.  

•  This  will  add  additional  burdens  to 
fishermen  and  these  specifications 
shall  be  built  on  arrangements 
between operators.  

•  Similar private standards exist with 
the same scope and then there is no 
need for additional standards.  
•  Expectations  in  terms  of  societal 
sustainability  are  very  different 
between  EU  MS.  Environmental 
standards  are  applied  in  different 
ways  according  to  organisations 
interests.  Thus, 
and 
to 
neither 
seems 
harmonisation 
possible nor desirable.  

their 

•  There  is  no  agreed  definition  of  a 

sustainable fishery.  

•  Harmonisation of trade descriptions or other commonly used specifications  

6  respondents  did  not  answer  this  question,  8  respondents  support  the  need  for 
harmonisation  of  trade  descriptions  or  other  commonly  used  specifications  and  17 
respondents did not agree with this. Overall, in their comments, respondents highlighted 
the necessity of  ensuring that EU and non-EU products apply the  same  rules, indicating 
several examples where the legal framework has to be reinforced without specific focus on 
trade  descriptions.  For  example,  one  of  the  respondents  indicated  that  EU  and  non-EU 
aquaculture products should apply the same rules (e.g. imported products should respect 
the  same  rules  regarding  the  use  of  some  substances  in  breeding  cycle  as  products 
produced in EU). Another respondent indicated the necessity to indicate the origin of fishery 
and aquaculture products either fresh or processed, as well as by products. The examples 
provided concern the Sturgeon’s eggs and the tolerance granted to batches of fish where 
distributors can indicate a list of countries of a batch of fish without having to indicate the 
proposed quantity of each origin. This leads to partial information to consumers. Several 
respondents  suggested  that harmonisation should be done  for commercial designations. 
One respondent indicated specific example of harmonisation that needs to be done at EU 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

level. It concerns the following products: anchovy (Engraulis encrasicolus), the Bonito del 
Norte (Thunnus alalunga) and the Sardine (Sardina pilchardus).  

Respondents  who  did  not  support  the  idea  of  harmonisation  indicated  that  the  current 
regulations ensure the flexibility needed by the market. FAO standards ensure a broader 
level of harmonisation and the existing of scientific names on products’ packages make the 
need of harmonisation of commercial designations not desirable. One respondent indicated 
that harmonisation of commercial designation is not desirable as it will lead to the loss of 
the diversity of high-quality products. 

When asking if there are other minimum requirements that could be established to improve 
the  level  playing  field,  12  respondents  indicated  that  there  is  no  need  to  add  other 
minimum  requirements  for  non-EU  products  marketed  in  the  EU.  According  to  these 
respondents, the different EU regulations already ensure that imported products apply the 
same  rules  as  EU  products,  particularly  through  the  different  CMO  provisions.  15 
respondents indicated that they support the idea of establishing requirements to ensure 
level playing field between EU and non-EU products.  Overall, these  respondents did not 
provide a clear idea of which requirements shall be added, but they underline the necessity 
of ensuring the current rules are properly applied by non-EU products and of reinforcing 
control. 

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ANNEX 14.  SUMMARY  AND  ANALYSIS  OF  THE  CONTRIBUTIONS  RECEIVED 
DURING  THE  OPEN  PUBLIC  CONSULTATION  AND  AS  A  RESULT  OF  THE 
TARGETED CONSULTATIONS  

14.1.  Outline of the consultation strategy  

The objective of this 13th-month evaluation was to examine the relevance, effectiveness, 
efficiency, coherence and EU added value of the current marketing standards framework 
for fishery and aquaculture products, in accordance with the Better Regulation Guidelines.    

The evaluation covers EU marketing standards that are underpinned by the CMO Regulation 
for  fishery  and  aquaculture  products.  This  regulation  includes  specific  reference  to 
marketing standards in its Chapter III, as well as in Article 47 as part of the regulation's 
final provisions, as well as the three following regulations: 

•  Council Regulation (EC) No 2136/89: preserved sardines and sardine-like products; 

•  Council Regulation (EC) No 1536/92: preserved tuna and bonito products; and 

•  Council Regulation (EC) No 2406/96: fresh and chilled fishery products. 

In  the  context  of  the  evaluation  of  the  marketing  standards  for  fishery  and  aquaculture 
products, the consultation strategy aimed to:  

-  Obtain information from stakeholders and general public on the effects of marketing 
standards  and  their  contribution  to  ensuring  a  fair  and  sustainable  market  for 
fishery and aquaculture products; 

-  Gather  feedback  on  the  relevance  of  these  standards  in  comparison  to  private  / 

international requirements; 
Identify the benefits and burdens generated by these standards; and 

- 
-  Detect issues in the applicability and enforcement of these rules. 

The  consultation  strategy  mapped  the  following  as  relevant  stakeholder  groups  to  be 
consulted during the consultation phase:  

-  Representative organisations/ associations at national and EU levels;  
-  Operators involved in the supply chain covered by marketing standards;  
-  Operators  involved  in  the  supply  chain  of  products  not  covered  by  marketing 

standards; 

-  Standards setting bodies, whether private or public; 
-  National authorities in charge of controls as well as customs officials and any other 
authority which may be concerned by these standards (e.g. health ministries); 

-  Citizens as consumers, even though not directly affected by these standards. 

This mapping ensured that all types of stakeholders regardless of their influence and stake 
in  the  supply  chain  are  consulted.    The  following  types  of  consultations  have  been 
conducted: 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

-  A  public  consultation  of  4  weeks  carried  out  by  the  Commission  prior  to  the 
evaluation, in order to give stakeholders the opportunity to provide feedback on the 
evaluation roadmap;5 

-  A public consultation of 12 weeks carried out by the Commission in order to allow 
all stakeholders (including citizens, consumer organisations and scientists, etc.) to 
express their views EU marketing standards for fishery and aquaculture products,6;  
-  A  written  consultation  of  Member  States'  public  authorities,  carried  out  by  the 

evaluators, in order to gather the views of public administrations; 

-  Targeted  consultations  of  stakeholders  in  the  supply  chain  carried  out  by  the 
evaluators in six Member States (Croatia, Denmark, France, Italy, Netherlands and 
Spain) through bilateral interviews and focus groups, complemented by a few phone 
interviews in other Member States in order to complete the information gathered 
during the case studies on specific topics (aquaculture in Greece, canned sardine-
type products in Latvia and aquaculture and intra-EU exchanges in Poland); 

-  Dissemination of the evaluation questionnaires used for the fieldwork in all Member 
States through the EC expert group on markets and trade in fishery and aquaculture 
products to complement the targeted consultations7. 

Besides  those  consultation  activities,  the  Market  Advisory  Council  (MAC)  and  the  South 
Western  Waters  Advisory  Council  (SWWAC)  published  opinions  on  this  topic  during  the 
timeframe of the evaluation. 

The consultation phase carried out in the context of the evaluation of marketing standards 
for fisheries and aquaculture products included the following consultations:   

•  National authorities survey: it was carried out from June to the end of September 
2018  and  targeted  the  28  Member  States.  National  Authorities  (NA)  were  asked 
about the implementation and control of the EU marketing standards for fishery and 
aquaculture  products,  and  about  the  existence  of  other  relevant  standards  at 
national level. The survey was disseminated in four languages (EN, FR, DE and ES) 
through  an  online  tool.  By  October  2018,  25  responses  were  received  from  MS 
National  Authorities  for  consideration  by  the  evaluation  team.  MS  that  did  not 
answer  the  survey  are  Slovakia,  Slovenia  and  Portugal.  The  survey  provided 
information on how controls of EU marketing standards are managed in the MS, the 
resources  allocated,  the  level  of  compliance  with  marketing  standards  at  the 
different  stages  of  the  supply  chain,  further  information  on  other  norms  and  the 
main impacts as perceived by those national authorities. 

•  Targeted  consultation  of  stakeholders:  case  studies  were  carried  out  in  six 
Member  States:  Croatia,  Denmark,  France,  Italy,  Netherlands  and  Spain.  These 
Member States were selected as they include a large proportion of the EU seafood 

5 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-594424_en 

6 
products_en#about-this-consultation 

https://ec.europa.eu/info/consultations/public-consultation-eu-marketing-standards-fishery-and-aquaculture-

7 See Evaluation report for the detailed methodology of targeted consultations and Annex 9 of the evaluation report for the full list 
of interviews and written contribution received. 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

production and trade and reflect the diversity of the supply chains within the EU. 
Operators and representatives of the supply chain were targeted through a mix of 
individual interviews and focus groups in order to gather feedback at different levels 
of  the  supply  chain.  Interview  guides  for  operators  were  drafted  and  adapted  to 
each type of operator according to their role and place in the supply chain. A larger 
number of interviews was carried out in the three larger countries (FR, ES and IT) 
to take into account the diversity of operators in those countries. The marketing of 
fresh  fish  products  included  in  Reg.  2406/96  was  covered  in  the  6  MS  through 
interviews with national organisations, meetings with at least 1 auction per country 
and, where relevant and possible, with wholesale and retail interests. In addition, 
canned  sardines  and  sardine-type  products,  covered  by  Reg.  2136/1989,  canned 
tuna  and  bonito,  covered  by  Reg.  1536/92,  and  products  not  covered  by  the 
marketing standards (aquaculture and other processed products) were investigated 
through specific thematic focuses in the different MS: shellfish farming in France, 
shellfish farming and canning industry in Spain, fish farming and canning industry 
in Italy, extra-EU trade in Netherlands, processing in Denmark and fish farming and 
processing  in  Croatia.  These  interviews  were  a  key  element  to  provide  a  general 
understanding  of  how  marketing  standards  are  implemented  and  used  in  the 
different MS and how  operators deal with products not covered by EU marketing 
standards.  In  total,  63  contributions  were  gathered  from  private  companies  and 
representative  organisations  all  along  the  supply  chain.  In  addition  to  these 
consultations, the questionnaires used for field work in the six MS were distributed 
through the Commission’s Expert Group on Fisheries and Aquaculture to all Member 
States and 10 additional written contributions from operators in 5 Member States 
(Austria, Belgium, Italy, Portugal and Sweden) were received.  
The data collection described above was complemented by five additional interviews 
with the Federation of European Aquaculture Producers (FEAP) and with operators 
in MS not covered by case studies (Greece, Poland and Latvia). Specific interview 
guides were developed for each type of stakeholders including targeted questions 
in order to focus on specific topics (aquaculture, internal trade, canned sardine-type 
products).  

•  Public  Consultation:  The  European  Commission’s  Directorate-General  for 
Maritime  Affairs  and  Fisheries  published  a  Public  Consultation  (PC)  to  gather  the 
public’s feedback on marketing standards for fishery and aquaculture products. The 
PC took place from 16 July to 9 October 2018. It aimed to gather opinions on the 
EU marketing standards and relevant topics (e.g. views on the quality of fishery and 
aquaculture  products)  from  the  broadest  possible  range  of  stakeholders  –  both 
expert  and  non-expert  stakeholders  (the  questionnaire  was  designed  to  be 
accessible  to  a  non-expert  audience).  The  PC  also  fulfilled  the  consultation 
requirement  stipulated  in  the  Commission’s  Better  Regulation  Guidelines.  155 
contributions were received. 

•  Consultation on recommendations: a consultation in the final stage of the study 
was  carried  out  to  obtain  feedback  from  the  stakeholders  interviewed  during  the 
data collection phase and from some of the  PC respondents, on a set of possible 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

recommendations for the current marketing standards and on the perspectives for 
the  evolution  of  the  general  framework  for  EU  marketing  standards.  The 
questionnaire for the consultation was translated into the 6 languages in use in the 
case  studies  (FR,  ES,  IT,  NL,  HR,  DK)  and  disseminated  via  e-mail  to  119 
participants. When the questionnaire was sent in English, possibility to answer in 
local  language  was  provided  and  notified  to  participants.  31  operators  and 
organisations provided feedback. 

14.2.  Profile of stakeholder groups  

In total, 259 stakeholders from 28 Member States  contributed to the  evaluation. Out of 
these contributions, 19% were from Spain, 16% from Italy, 15% from France, 6% from 
Germany, 6% from Portugal, 5% from Netherlands and Belgium, 4% from Denmark and 
24% from other countries.  

Figure 10: Distribution of contributions by Member States  

Other
24%

Spain 
19%

Denmark 
4%
Belgium 
5%
Netherlands 
5%

Portugal 
6%

Italy 
16%

Germany 
6%

France 
15%

Contributions  have  been  gathered  from  stakeholders  operating  at  all  the  supply  chain 
stages and sub-sectors, with 69% of contributions from stakeholders responding on behalf 
of  their  companies  or  organisations  and  31%  from  people  responding in  their  individual 
capacity  (in  the  context  of  the  Public  Consultation).  The  figure  below  indicates  that  all 
stages  of  the  supply  chain  were  consulted  and  covered,  including  operators  in  fishing 
(11%), aquaculture (8%), processing (5%), trade and marketing at first sale (i.e. auctions) 
and beyond (i.e. wholesale, retail, etc.) (11%), as well as public authorities and research 
institutions. Moreover, 14% of contributions concern operators or organisations involved 
in more than one sub-sector (e.g. fishing and processing, fishing/ processing and trade, 
etc.).  Both  operators  from  SMEs  and  large  companies  were  consulted  in  addition  to 
representative organisations which cover all types of companies, including SMEs. Individual 
members  of  the  Market  Advisory  Council  were  interviewed  during  the  fieldwork.  Final 
consumers were also reached out through the Public Consultation. 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Figure 11: Distribution of contributions by sector  

Individual 
responses
34%

Other 
2%

Research 
3%

Fishing 
11%

Aquaculture
8%

Processing
5%

Trade and 
marketing
11%

Public 
authorities
12%

Industry -
various stages 
14%

Respondents to the public consultation can only be classified according to the above main 
categories but the detailed analysis of stakeholders who contributed through the targeted 
consultations shows that all stages of the supply chain contributed8. 

Figure 12 : Contribution of the different subsectors for the targeted 
consultations 

30
25
20
15
10
5
0

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s
r
e
d
o
h
e
k
a
t
s

f
o
r
e
b
m
u
N

14.3.  Short description of the methodology and tools used to process the data  

Data  gathered  through  the  targeted  consultation  were  mainly  qualitative  and  were 
processed  using  qualitative  methods  (synthesis  of  feedback  gathered  by  key  themes, 
comparative analysis between Member States and stakeholder groups).  

The only quantitative data collected from stakeholders were: 

•  National authority survey: the number of FTEs allocated to controls of marketing 
standards,  number  of  controls,  volumes  of  products  controlled  and  number  of 
infringements.  However,  only  very  few  reliable  and  comparable  answers  were 
provided to these questions, which were therefore processed as qualitative answers 
rather than through classical statistical analysis. 

8 Each stakeholder can operate in more than one sub-sector, so there is some overlap among the different categories 

77 

 
 
 
 
 
                                           
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

•  Auctions price statistics: some auctions provided price series. Likewise, the data 
provided did not allow to carry out statistical analysis but were used as examples. 

To  process  the  feedback  received  through  the  public  consultation,  we  reviewed  and 
analysed the data using appropriate tools and techniques. We used statistical techniques 
such as bivariate and multivariate analysis to understand both the overall patterns and the 
differences between groups of respondents (i.e. professionals, consumers, scientists, etc.). 
We  also  analysed  the  qualitative  data  in  order  to  understand  the  reasons  behind  the 
patterns or main variations. The results of this analysis has been taken into consideration 
of the evaluation.  

14.4.  Description of the results of the consultation phase  

The  different  consultation  activities  allowed  to  obtain  complementary  information  and 
opinions.  Overall,  feedback  received  from  the  different  types  of  operators  provided  a 
realistic and coherent picture of the implementation of the current marketing standards. 
Views on the possible evolution of those standards were however fairly heterogeneous and 
contradictory.  

National Authority survey 

Questions to national Authorities focused on the organization of controls for EU marketing 
standards in their Member States and their views on the achievements of EU marketing 
standards toward the objectives set by the CMO. 

The survey showed that between one and five administrative entities are generally involved 
in  the  implementation  and  controls  of  EU  marketing  standards,  depending  on  the 
organization in each MS. The basic scheme involves the Department of Agriculture and/or 
Fishery, in addition to the Veterinary Services. The third administrative entity is usually a 
market control service. All these structures are also engaged in other types of controls. 

20 out of 23 MS who provided information on this topic answered that marketing standards 
controls  were  always  or  sometimes  combined  with  other  inspections,  usually  hygiene, 
traceability, laboratory  sample checks, control of storage conditions and labelling. When 
they are not, it is because they are not carried out at all (2 MS) or because of legal issues 
concerning specific competences of the different services (1 MS).  

Only  13  MS  provided  answers  on  the  resources  allocated  to  the  control  of  marketing 
standards, and only 6 of them were actually used for the analyses. Other answers seemed 
to include other types of controls and not only marketing standards. The fact that controls 
of marketing standards are often combined with other controls makes it difficult for NAs to 
precisely assess the resources specifically dedicated to this specific set of regulations. The 
answers that were considered reliable, also crossing with feedback from the case studies, 
indicated  that  MS  generally  dedicate  between  0  and  9  FTEs/year  for  the  control  of 
marketing standards. Feedback on the number of inspections and reported anomalies was 
difficult to interpret as well, as it was not always clear whether answers provided were for 
marketing  standards  only  or  if  they  covered  other  EU  regulations.  In  general,  answers 
provided by MS indicated a good level of compliance with marketing standards. They also 
indicated that the number of infringements of marketing standards have reduced in the 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

past  years  due  to  the  increasing  requirements  of  buyers  and  the  efforts  undertaken  by 
producers  to  satisfy  them.  When  asked  about  specific  types  of  anomalies  related  to 
marketing standards, MS indicated that most frequent irregularities were  related to  size 
issues while anomalies regarding preserved and canned products were the least frequent. 

The  vast  majority  of  NAs  and  control  authorities  consider  EU  marketing  standards  as  a 
positive regulation in terms of quality, sustainability, transparency of the market, fairness 
of international trade and for the operators all along the supply chain. They also generally 
considered them coherent with other national and EU regulations.  

Finally, feedback from the NAs does not show a strong call for simplification. Depending 
on  the  criteria,  between  one  third  and  over  half  of  the  NAs  did  not  express  an  opinion. 
Overall the strongest support for simplification is for the freshness and size criteria, with 
about a third of the NAs expressing no opinion, a quarter being opposed to simplification 
and  about  40%  being  in  favour.  Those  in  favour  indicated  in  particular  that  minimum 
conservation reference size could be sufficient.   

Targeted consultation of stakeholders  

The consultations in the six MS, as well as additional interviews and contributions allowed 
to provide an overall understanding of the implementation and the benefits of marketing 
standards as well as the costs related to their application.  

Stakeholders  involved  in  fresh  fish  supply  chain  are  in  general  aware  of  the  existing 
marketing standards. The only exception is Croatia, where the stakeholders in the catching 
sector were not well aware of these standards. Operators of the canning industry are all 
very well acquainted with the marketing standards. 

When operators in the fresh fish supply chain were asked about the relevance of the criteria 
defined by marketing standards (i.e. size and freshness), the respondents indicated that 
price statistics in first sale locations are maintained by size categories (in some cases more 
detailed  size  classifications  than  those  set  in  marketing  standards  are  used),  which 
illustrate  the  importance  of  the  size  criterion.  The  organoleptic  quality  criteria  of  the 
marketing  standards  are  also  applied.  However,  many  respondents  indicated  that 
operators may rely on other criteria to assess the product's quality (e.g. the reputation of 
the  vessel,  the  time  elapsed  since  the  catch  and  in  some  cases  the  fishing  gear  used). 
These  respondents  are  of  the  opinion  that  the  quality  assessment  may  differ  somewhat 
between auctions and MS. In addition, the consultation phase of operators indicated that 
the  specific  context  of  the  small  polyvalent  fisheries  in  the  Mediterranean  region  (high 
number  of  species  landed  in  small  volumes)  made  the  implementation  of  marketing 
standards difficult in that area. 

Overall,  price  statistics  provided  during  the  case  studies  showed  that  on  average  larger 
and higher quality fish is better priced. 

This  consultation  phase  also  confirmed  that  marketing  standards  for  fresh  fish  are  only 
relevant at first sale/ auction, as expected. As the fish travels through the supply chain, 
their application becomes increasingly difficult and loses relevance. According to operators, 
the inconsistent application of marketing standards does not compromise the benefits of 

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having one basic common denominator for the classification of the main landed species. 
Concerning  canned  products,  the  criteria  defined  in  the  two  regulations  are  considered 
highly relevant through the chain.  

Operators indicated that compliance with the marketing standards has increased and that 
it is not only a result of legal obligation, but at least as much a result of the relation between 
the trading partners. Meeting agreed characteristics of the product is important to maintain 
the necessary mutual trust between sellers, buyers and facilitators. Operators in the fresh 
fish supply chain indicated that controls are carried out with different intensities in different 
auctions  and  MS  and  that  distinguishing  between  controls  of  marketing  standards  and 
controls of other regulations (e.g. conservation, hygiene, etc.) is not always possible, but 
that identification of non-compliance is very rare. 

The consultation indicated that there is no equivalent standards to marketing standards. 
In some MS, more detailed grading systems may be used, but they are generally based on 
the EU marketing standards. Private standards and certification schemes have developed, 
but they focus on processes and sustainability, rather than quality. Those standards can 
however  have  a  significant  impact  on  trading  practices  when  they  become  de  facto 
mandatory to enter certain markets (e.g. with large retailers in some countries).  

Some operators are of the opinion that marketing standards for fresh products could be 
removed but the majority of them consider that they should be maintained, as they are 
well adapted to daily practice at first sale and seem to be based on it. Similarly, operators 
in the canning supply chain agreed that marketing standards for canned products serve 
well their purpose and therefore should not be removed or simplified.  

Finally, the fieldwork did not show a need or expectations to extend the existing marketing 
standards to products currently not covered (i.e. aquaculture products and other processed 
products). 

Public consultation for the evaluation roadmap9 

Two contributions were received at that stage, from the AIPCE and CEP (representing EU 
fish  processors,  traders,  importers  and  exporters)  and  from  the  ANFACO-CECOPESCA, 
representing  Spanish  fish  processors,  and  in  particular  the  canned  tuna  and  canned 
sardines industry. The two contributions stressed the usefulness of marketing standards 
for canned tuna and bonito and for canned sardines and sardine-type products, and the 
fact that the rationale for the evaluation (e.g. reported lack of compliance and rigidity of 
the marketing standards) did not apply to marketing standards for preserved products. 

9 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-594424_en 

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Public consultation for the evaluation10 

The Public Consultation aimed to gather feedback about respondent choices when buying 
seafood, their assessment of seafood quality and sustainability in their country and the EU, 
the need for standardisation, the usefulness and impact of the marketing standards, and 
potential ways to improve them. 

Appearance and origin clearly came out as the most important criteria when buying fresh 
seafood  products  for  most  respondents.  Size  and,  notably,  price  are  considered  less 
important.  Respondents  are  the  most  satisfied  with  the  quality  of  fresh  seafood  in  their 
countries, but most have doubts about seafood sustainability and feel that information on 
seafood quality is not easily accessible. Public authorities are trusted more to control the 
implementation of the standards than private certification bodies. 

Very few respondents answered negatively about the usefulness of the various criteria used 
in the current marketing standards, but the number of respondents who did not know or 
were neutral about them is significant.  

When asked about the impacts of the EU’s marketing standards, ‘harmonisation of trade 
description  and  composition  provision  for  preserved  products’  and  ‘protect  consumers 
against  the  marketing  of  products  unfit  for  consumption’  were  the  effects  that  most 
respondents  agreed  with.  Then  came  ‘improve  quality’,  ‘avoid  fraudulent  practices’  and 
‘fair  competition  in  the  EU’.  Respondents’  opinions  on  the  contribution  that  the  existing 
standards provide to the sustainability of seafood products were more mitigated and the 
contributions that respondents agreed the least with were ‘level-playing field between EU 
and non-EU products’ and ‘profitability of the EU producers’. It should be noted however 
that comments to open questions indicate that there is some confusion between marketing 
standards and consumer information rules. 

The reported difficulties in implementing or controlling the marketing standards are often 
related to other aspects of the common fisheries policy, consumer information rules or food 
law (e.g. labelling requirements about production methods or catch areas). Differences in 
application  are  also  mentioned,  but  again  it  is  not  always  clear  whether  it  is  related  to 
marketing standards (e.g. the use of the term “white tuna”) or to other regulations (e.g. 
enforcement of the rules in third countries). Answers about possible improvements are also 
primarily  related  to  consumer  information,  sustainability  and  conservation  issues  rather 
than the existing marketing standards themselves. 

Responses about possible simplification are mixed. Over a third of the respondents agreed 
that it would be possible 1) to simplify freshness and size criteria without compromising 
the  effectiveness  of  marketing  standards;  2)  to  simplify  freshness  and  size  criteria  to 
improve  the  effectiveness  of  marketing  standards;  and  3)  to  simplify  EU  marketing 
standards  for  preserved  products  without  compromising  their  effectiveness.  In  each 

10 
aquaculture-products_en.pdf   

https://ec.europa.eu/info/sites/info/files/summary-results-consultation-on-marketing-standard-framework-for-fishery-and-

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Evaluation of the marketing standards framework for fishery and aquaculture products  

question, between a fifth and a fourth of them chose the ‘don’t know’ answer, and around 
one in five believed that such simplifications were not possible. 

The respondents could not say much about the coherence of the marketing standards and 
other  standards.  The  EU  standards  were  generally  considered  as  a  minimum  common 
reference. 

Codes of practice were seen as the most possible ‘candidate’ to replace the EU marketing 
standards,  but  none  of  the  options  (private  standards,  codes  of  practice  or  national 
standards) received more than 40% of positive answers. 

The  respondents  were  supportive  of  expanding  marketing  standards,  especially  for 
aquaculture. Comments show, however, that what is expected is not necessarily to expand 
current  rules  to  other  products.  Instead,  common  definitions  and  rules  should  be 
established in a more general way in order to guarantee minimum quality for consumers 
across  the  EU,  protect  EU  producers  from  unfair  competition,  in  particular  from  non-EU 
products, increase transparency among stakeholders, contribute to better-quality products 
and therefore increased added-value, and increase sustainability. 

Consultation on recommendations  

The consultation aimed to obtain feedback from stakeholders on possible recommendations 
that  came  out  of  the  broader  evaluation.  These  addressed  both  the  existing  marketing 
standards’  criteria  and  implementation,  as  well  as  the  perspectives  for  the  general 
framework. We received 31 answers to the consultation. Answers to the consultation did 
not bring further factual elements and rather confirmed the main findings of the first phase 
of consultations.  

Feedback from stakeholders in the fresh fish supply chain were heterogenous and indicated 
two contradictory situations. On the one hand, some operators, generally from countries 
where  marketing  standards  are  well  known  and  implemented,  call  for  maintaining  the 
regulation and in some cases to establish more elaborated grading systems (further size 
grades for instance, or expansion to other species). They indicated that the transparency 
ensured  by  these  standards  justify  that  they  be  maintained.  On  the  other  hand,  some 
operators,  generally  in  countries  where  marketing  standards  are  not  known  or  not 
consistently  applied,  call  for  simplifying  marketing  standards  by  removing  some  criteria 
(e.g. minimum marketing sizes or simpler grading systems with only small, medium, large 
for sizes) or by removing the regulation.  

Concerning  regulations  laying  down  marketing  standards  for  preserved  tuna  and  bonito 
and for preserved sardines  and sardine-type products,  feedback  from operators differed 
according to whether they are involved or not in the canning industry. There is consensus 
among  operators  from  the  canning  industry  that  these  standards  should  neither  be 
removed  nor  simplified.  However,  operators  from  the  tuna  fishing  sector  call  for 
reconsidering the inclusion of Auxis species (not included in the Codex standards) in the 
list  of  species  authorised  for  canned  tunas  and  bonitos  and  for  changes  in  the  trade 
description requirements.  

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On the general perspectives, the consultation did not allow to identify any specific need 
that could be addressed through existing marketing standards, for products currently not 
covered  (i.e.  aquaculture  products  and  other  processed  products).  Most  operators  who 
replied to the recommendation questionnaire indicated that their buyers included product 
specifications  related  to  sustainability.  However,  replies  as  to  whether  sustainability 
information could be harmonised at EU level were more nuanced. 

Ad hoc contributions 

The SWWAC published an opinion on 24/12/2018 on the marketing standards for canned 
tunas11 to recommend a revision of the species authorised and the trade designations for 
canned  tuna  on  the  grounds  that  trade  designations  used  in  the  current  marketing 
standards could be misleading for consumers and result in unfair competition.   

The  MAC  published  an  opinion  on  28/3/2019  on  the  marketing  standards  for  fresh 
products 12, based on its members’ feedback. It concluded that freshness categories were 
no longer considered useful (i.e. no longer determinant in the assessment of quality) but 
that size criteria were still useful. The MAC opinion also makes some recommendations in 
order  to  increase  the  flexibility  of  marketing  standards  and  facilitate  a  harmonised 
implementation. 

Conclusion 

Feedback received from the different consultation activities is generally coherent as regards 
how  existing marketing standards are implemented and controlled, as well as regarding 
their usefulness.  

The  feedback  received  from  the  PC,  calling  for  increased  transparency,  especially  as 
regards  sustainability,  confirms  feedback  from  the  industry  that  these  requirements  are 
included  in  purchase  contracts.  Whether  the  industry  sees  scope  for  new  possible 
marketing standards in this area remains more debated.   

14.5.  Explanation on how the information gathered has been taken into account 

in the evaluation work 

Factual information received through the public consultations and targeted consultations 
on  the  implementation  and  control  of  marketing  standards  was  analysed  and  fed  the 
answers  to  the  evaluation  questions.  Stakeholders’  opinions  on  the  relevance, 
effectiveness, efficiency, coherence and EU added-value of the marketing standards were 
also used as indicators, among others, to answer the evaluation questions. 

The arguments presented in the SWWAC opinion were taken into account for the evaluation 
questions  and  triangulated  with  available  data  (tuna  prices,  production  data  for  the 
different tuna species, analysis of the relevant regulations).   

11 http://cc-sud.eu/images/img-ccs/avis/Avis-2018-2019/126-ConservesThons/Avis126-conserves-EN.pdf 

12 https://marketac.eu/wp-content/uploads/2019/04/MAC-Advice-Marketing-Standards-FRESH-28.03.2019.pdf 

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The  MAC  opinion  was  not  taken  into  consideration  for  the  evaluation  work  as  it  was 
published after the delivery of the draft final report. 

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ANNEX 15.  EVALUATION QUESTIONS MATRIX  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

Relevance 

EQ1. To what extent are the 
existing 
marketing 
standards still relevant? 

To what extent marketing 
standards are relevant for 
stakeholders  involved  in 
the supply chain? 

•  Quality 

criteria 

by 
stakeholders  are  based  on  the 
marketing standards 

used 

•  Comparison  of  quality  criteria 

and marketing standards 

•  Qualitative 

interviews 

with 
stakeholders 
(fishermen, 
wholesaler,  importer,  processor, 
retailer,  Market  Advisory  Council) 
and 
and  UE 
Conservation) 

(Market 

staff 

•  Desk  research  on  criteria  used  by 
marketing 

relevant 

other 
standards 

•  No  additional 

standards  are 
necessary 
for  stakeholders  or 
additional  standards  rest  on  EU 
marketing standards 

•  Use of additional standards by 

stakeholders 

•  Content 

additional 
of 
standards  compared  to  EU 
marketing standards 

•  Desk  research:  criteria  defined  in 
the  marketing  standard  and other 
private standard 

•  Desk 

research 

on  market 
penetration  of  other  existing 
marketing standards 

For 
and 
crustaceans 
molluscs,  to  what  extent 
the  marketing  standards 
the 
are  relevant  with 
the 
of 
characteristics 
products?  

•  Key  criteria  used  by  stakeholders 
for the description of the products 
are  defined 
in  the  marketing 
standards 

To  what  extent 
the 
marketing  standards  are 
relevant  for  the  sales  to 
the  final  consumer  (size, 
freshness)?  

•  Coherence  between  marketing 
market 
stage 

standards 
segmentation  at 
(freshness and size) 

retail 

and 

•  Comparison of key criteria and 

•  Qualitative 

interviews 

marketing standards 

•  Comparison 
standards 
segmentation 
consumers 

of  marketing 
market 
and 
final 

for 

stakeholders 
wholesaler,  processor, 
and UE staff (Market) 

with 
(fishermen, 
retailer) 

•  Desk  research:  criteria  defined  in 

the marketing standard  

•  Desk  research  on  certifications 
used for crustaceans and molluscs 

•  Qualitative 

interviews 

with 
retailers and UE staff (Market and  
Health)  and  an  Open  Public 
Consultation 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

To  what  extent  the  sizes 
and  freshness  defined  in 
marketing  standard  are 
used for pricing of EU and 
imported products? 

To  what  extent  the  size 
in  marketing 
defined 
standards  are  coherent 
with  conservation  issues 
for species not covered by 
MCRS 

To what extent marketing 
standards  allows  a  good 
trade  description  and 
composition provision for 
processed 
products 
covered by EU marketing 
standards  compared  to 
processed  products  not 
covered  by  marketing 
standards.  

86 

Relevance 

•  Stakeholder opinion on the criteria 

•  Ranking  of  the  criteria  for 

•  Qualitative 

for pricing of product 

pricing 

interviews 

with 
(Fishermen, 

stakeholders 
wholesalers, importers, retailers) 

•  Existence  of  evidence  showing 
differences  in  prices  for  different 
freshness and size categories 

•   Comparison  of  prices  by 
category  based  on  available 

•  National/regional sources on prices 
for each size and freshness state 

data  from  specific  auctions  or 

other  stages  of  the  supply 

•  Desk research by country expert+ 

Data from sales notes 

chain 

•   

•  Size from marketing standards are 
coherent with conservation issues 

•  Relevance  of  minimum  sizes 
defined in marketing standards 

•  Answer 

from  other  EQ  on 

effectiveness and coherence 

for  products  not  covered  by 

minimum 

conservation 

reference size 

•  Qualitative interviews 

•  For  canned  tunas  and  sardines 
only: 
and 
composition provision are based on 
EU marketing standards  

description 

trade 

•  For  canned  tunas  and  sardines 
only:  no  additional  standards  are 
needed  for  stakeholders  for  trade 
description 
composition 
and 
provision  

•  Comparison  of  EU  marketing 
standards  for  canned  tunas 
and 
trade 
sardines  with 
descriptions and provisions on 
composition 
by 
stakeholders 

used 

•  Feedback from stakeholders on 
the use of other standards for 
canned  tunas  and  sardines, 
and  comparison  with  actual 
trade 
and 
description 
provisions on composition 

•  Qualitative 

interviews 

with 
(wholesalers, 

stakeholders 
processors and retailers)  

•  Qualitative 

with 
interviews 
stakeholders  (operators 
in  the 
trade  and  processing  sector)  and 
EU staff (Market)  

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

Relevance 

•  For  other  canned  and  processed 
products only: some shortcomings 
in 
and 
trade 
are 
composition 
identified in the supply chains not 
covered by marketing standards. 

description 
provisions 

for 

•  Feedback from stakeholders on 
standards  used 
trade 
descriptions or on the absence 
of standards for some products 
and the consequences for Intra 
and extra-EU trade. 

•  Qualitative 

with 
interviews 
stakeholders  (operators 
in  the 
trade  and  processing  sector)  and 
EU staff (Market) 

•  What  are  the  methods  for  quality 
in  the  aquaculture 

assessment 
supply chain? 

•  Method  for  quality  description 
(standard, 

by  stakeholders 
etc.) 

•  Qualitative  interviews  (Operators 
in  the  aquaculture  sector  and 
trade) and EU staff (Market) 

•  Do stakeholders use standards for 
/ 

(private 

quality  description 
public)? 

•  Identification  and  description 
by 

standards 

used 

of 
stakeholders 

•  Qualitative  interviews  (Operators 
in  the  aquaculture  sector  and 
trade) and EU staff (Market) 

•  Desk  research  on  the  content  of 

standards 

•  Qualitative  interviews  (Operators 
in  the  aquaculture  sector  and 
trade) and EU staff (Market) 

in 

of 

are 

What 
the 
the 
consequences 
absence of EU marketing 
the 
standards 
aquaculture 
supply 
chain?  To  what  extent 
in  quality 
shortcoming 
description 
are 
identified? 

•  Are there shortcoming identified in 
between 
description 

quality 
stakeholders? 

•  Identification of shortcoming in 

product description 

87 

 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

EQ2. To what extent have 
the current marketing 
standards met the 
objectives? 

To what extent have the 
marketing standards 
contributed to improve 
the quality of the 
products in the interest 
of producers, traders 
and consumers? 

Effectiveness 

•  Extent to which the marketing 
standards have improved the 
quality of products 

Change in quality grades of 
products placed on the market. 

•  Factors helping or hindering 
improved quality of products 
(including technical innovations). 

To what extent do the 
marketing standards 
ensure that the EU 
market is supplied with 
sustainable products? 

•  Extent to which the marketing 
standards have ensured the 
sustainability of seafood products 
in the EU market. 

•  Performance of the supply 

chain in relation to marketing 
standard requirements (level 
of infringements, sanctions). 

•  Factors helping or hindering 

•  Trend in share of EU 

ensuring the supply of sustainable 
products 

landed/traded products 
covered by marketing 
standards. 

•  Change in % of seafood 
products certified as 
sustainable. 

•  Stakeholder Consultation Sources: 

EU-wide survey to control 
authorities, interviews with 
operators, designated experts and 
trade organisations and EU staff 
(market and conservation) and 
Open Public Consultation  

•  Possibly sales notes data 

•  Stakeholder Consultation Sources: 

EU-wide survey to control 
authorities, interviews with 
operators, designated experts and 
trade organisations and Open 
Public Consultation 

•  Data analysis Sources: DCF data 
on discard levels, sustainable 
seafood availability in EU markets. 

•  Stakeholder Consultation 

(interviews with operators of 
trade and processing sector, 
scientists, environmental NGOs 
and trade organisations) and an 
Open Public Consultation  

•  Open Public Consultation  

88 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

Effectiveness 

•  Extent to which the marketing 
standards have facilitated fair 

•  Change in extent of seafood 
trade disputes within the EU. 

competition. 

To what extent do the 
marketing standards 
facilitate market 
activities based on fair 
competition and improve 
the profitability of 
production? 

•  Extent to which the marketing 
standards have facilitated 

•  Change in profitability within 

seafood chains. 

profitability. 

•  Factors helping or hindering  

•  Change in perceptions of 

operators regarding 
fairness/transparency and 
profitability. 

•  Review of trade dispute instances. 

•  Stakeholder Consultation 
Sources: interviews with 

operators of trade and processing 

sector, UE Staff on conservation 

and trade and trade organisations 

•  Open Public Consultation 

•  Stakeholder Consultation 
Sources: interviews with 

operators of trade and processing 

sector, UE Staff on conservation 

and trade    

•  Data analysis Sources: DCF data 
on production and processing 

economics 

•  Stakeholder Consultation 
Sources: interviews with 

operators of trade and processing 

sector, UE Staff on conservation 

and trade  and trade 

organisations 

•  Open Public Consultation 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

To what extent do the 
marketing standards 
ensure a level-playing 
field between EU and 
non-EU products? 

Effectiveness 

•  Extent to which EU and non-EU 

•  Performance of the supply 

products face the same regulatory 
requirements. 

chain in relation to marketing 
standard requirements 
involving imports  (level of 
infringements, sanctions). 

•  Desk review Sources: WTO, DG 
Trade, Competition information 
and Review of trade dispute 
instances. 

•  Data sources: COMEXT, FAO 

•  Trend in share of imported 

FISHSTAT (imports) 

products covered by 
marketing standards 

•  Stakeholder Consultation 
Sources: interviews with 

operators of trade and processing 

and trade organisations, UE Staff 

on conservation and trade  

•  Open Public Consultation  

•  Open Public Consultation  

•  Factors helping or hindering 

achieving a level playing field. 

•  Extent to which marketing 

standards help to avoid fraudulent 
practices. 

•  Level of compliance with 
marketing standards for 
preserved seafood products. 

•  Desk review Sources: Control & 
compliance reports at all stages 

in the supply chain. Consumer 

•  Change in the amount of 
fraudulent practices in 
preserved products. 

•  Consumer perception of 

seafood products. 

perceptions of seafood.  

•  Stakeholder Consultation 

Sources: EU-wide survey to 

control authorities, interviews 

with operators, designated 

experts and trade organisations 

and UE staff on Market, Health 

and Conservation  

•  Open Public Consultation  

To what extent are the 
marketing standards 
effective in helping to 
avoid fraudulent 
practices and misleading 
consumers in the trade 
description of preserved 
products?  

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

Effectiveness 

•  Factors  helping 

or  hindering 
fraudulent practices and misleading 
consumers. 

EQ3. To what extent has 
the implementation of 
marketing standards 
caused unexpected or 
unintended effects? 

No sub-question 

What unexpected or unintended 
effects were caused by the 
marketing standards? 

•  Stakeholder Consultation 

Sources: EU-wide survey to 

control authorities, interviews 

with operators, designated 

experts and trade organisations 

•  Open Public Consultation 

•  Changes in levels of loss & 

•  Desk review 

waste throughout the seafood 
supply chain. 

Sources:  DG  Env  reports  on  food 
waste, consumer perceptions. 

•  Consumer perceptions of 

•  Stakeholder Consultation 

seafood (understanding and 
confidence in the information 
related to the marketing 
standards). 

interviews 

Sources:  EU-wide  survey  to  control 
authorities, 
with 
operators,  designated  experts  and 
trade  organisations  and  UE  staff  on 
Conservation, Health and Market   

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

EQ4. To what extent are the 

No sub-question 

incurred costs 
justifiable and 
proportionate to the 
benefits achieved? 

Efficiency 

•  Extent to which the benefits of 
having marketing standards in 
place outweigh the costs of 
implementation and control 

•  FTEs dedicated to control of 
MKTS and costs identified – 
examples from specific MS   

•  Costs compared to the 

benefits of EU marketing 
Standards (Questions on 
effectiveness) 

Sources: EU-wide survey to control 
authorities, interviews with 
processors, traders, and trade 
organization 

Answers from EQ 2 and 3, Eurostat 
(labour costs)  

91 

 
 
 
 
 
 
  
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

EQ5. Could the use of other 

policy instruments or 
mechanisms have 
provided better cost-
effectiveness? 

Could the same objectives 
be achieved without 
marketing standards 
regulations (i.e. without 
the related costs)? 

Efficiency 

•  Perception of stakeholders 
about costs vs benefits. 

•  Extent to which minimum 

•  % of landings covered (in 

Landings data : EUROSTAT 

conservation reference sizes 
alone would allow to achieve 
the same objectives 

EU-wide survey to public authorities, 
interviews with processors, traders, 
control agencies, designated experts 
and trade organization.  Answers 
from EQ 1 to 4 

volumes and value) 

•  Relevance of minimum 

reference sizes compared to 
other quality criteria 

•  Objectives that could be 
achieved by minimum 
conservation reference sizes  

•  Objectives that would not be 

achieved 

•  Extent to which other 
applicable norms and 
standards alone would achieve 
similar results 

•  Relevance of those norms and 
standards for the different 
types of products and for the 
operators at the different 
stages of the supply chain 

EU-wide survey to public authorities, 
interviews with processors, traders, 
control agencies, designated experts 
and trade organization.  Answers 
from EQ 1 to 4 

Open Public Consultation  

•  Objectives that could be 
achieved by minimum 
conservation reference sizes  

•  Objectives that would not be 

achieved 

To what extent do MS 
implementation choices 
impact the cost-
effectiveness of marketing 
standards? 

•  Extent to which the cost-

•  Evidences of significant 

effectiveness of marketing 
standards depend on MS 
implementation choices 

differences in terms of cost-
effectiveness among MS 

•  Identification of cost drivers 

related to MS implementation 
choices 

Cross-analysis based on previous 
questions and answers to Q4 + 
check opinion of NA and EU staff 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

Efficiency 

EQ6. To what extent is there 

a potential for 
simplification of 
marketing standards? 

To what extent is there a 
potential for simplification 
of freshness/size criteria? 

Extent to which the 
implementation of freshness/size 
criteria leads to unnecessary/ 
disproportionate costs 

•  Evidence of unnecessary or 

disproportionate costs 

Analyses will build on Questions 4 
and 5 and Interviews operators and 
public authorities, in particular 
control authorities, processors, 
trader, control services in airports  

To what extent is there a 
potential for simplification 
of the provisions on 
imported fresh/chilled 
products? 

Extent to which the 
implementation of the provisions 
on imported fresh/chilled 
products leads to unnecessary/ 
disproportionate costs 

To what extent is there a 
potential for simplification 
of presentation 
requirements for preserved 
products? 

Extent to which the 
implementation presentation 
requirements for preserved 
products leads to unnecessary/ 
disproportionate costs 

•  Evidence of unnecessary or 

disproportionate costs 

•  Evidence of unnecessary or 

disproportionate costs 

To what extent is there a 
potential for simplification 
of control procedures? 

Extent to which control 
procedures lead to unnecessary/ 
disproportionate costs 

•  Evidence of unnecessary or 

disproportionate costs 

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

Coherence  

EQ7 To what extent are 
marketing standards and 
other norms having the 
same effect as marketing 

No sub-question 

•  Extent to which conflicts have 
been identified with other 
norms and rules acting as 
marketing standards  

•  Identification and description 

•  Desk review  

of possible conflicts  

•  Volumes/value of products 

falling under conflictual rules 

•  Stakeholders’ consultation: 
Control authorities, traders, 
processors, designated experts 

93 

 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

standards coherent with one 
another? 

EQ8. To what extent are 
marketing standards 
coherent with other EU rules 
(e.g. EU rules on food safety, 
food information to 
consumers, conservation 
rules)? 

To what extent are the 
marketing standards 
coherent with other EU 
rules on food safety? 

To what extent are the 
marketing standards 
coherent with the control 
system for marketing 
standards established in 
Regulation (EC) No 
1224/2009 and Regulation 
(EU) 2017/625. 

To what extent are the 
marketing standards 
coherent with Consumer 
information rules 
(Regulation (EU) No 
1169/2011 and Chapter IV 
of the CMO Regulation). 

94 

Coherence  

(depending on previous 
indicator) 

and EU staff in market and 
conservation  

•  Detailed interviews in several MS  

•  Landings data: Eurostat 

•  Extent to which the 

•  Stakeholder’s feedback on 

•  Desk review  

marketing standards are 
coherent with other EU rules 
on food safety. 

perceived external coherence 

•  Stakeholders’ consultation:  

(or lack thereof) 

Management authorities, control 
authorities, traders, processors, 
designated experts and EU staff in 
market and Health  

•  Open Public Consultation  

•  Detailed interviews in several MS 

•  Extent to which the marketing 
standards are coherent with 
regulation 1224/2009 and 
2017/625 

•  Evidence of intra-policy 

•  Desk review 

coherence 

•  Stakeholder’s feedback on 
perceived complementarity 

and/or synergies between the 

•  Stakeholders’ consultation: 

Management authorities, national 
fisheries control and food safety 
agencies and EU staff in market  

policies (or lack thereof) 

•  Detailed interviews in several MS 

•  Extent to which the marketing 
standards are coherent with 
EU rules on consumer 
information. 

•  Evidence of intra-policy 

•  Desk review 

coherence 

•  Stakeholder’s feedback on 
perceived complementarity 

and/or synergies between the 

•  Stakeholders’ consultation: 

Management authorities, retailers, 
food safety agencies and EU staff 
in market and Health 

policies (or lack thereof) 

•  Detailed interviews in several MS 

•  Open Public Consultation  

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods and sources 

Coherence  

•  Extent to which the marketing 
standards are coherent with 
EU hygiene rules 

To what extent are the 
marketing standards 
coherent with Hygiene 
rules for food of animal 
origin (Regulation 
853/2004).  

•  Evidence of intra-policy 

•  Desk review  

coherence 

•  Stakeholder’s feedback on 
perceived complementarity 

and/or synergies between the 

•  Stakeholders’ consultation: 

Management authorities, retailers, 
food safety agencies and EU staff 
in market and Health  

policies (or lack thereof) 

•  Detailed interviews in several MS 

EQ9. To what extent are EU 
marketing standards 
coherent with international 
standards? 

To what extent are the 
marketing standards 
coherent with international 
standards (e.g. Codex and 
Global Food Safety 
Initiative) 

•  Extent to which the marketing 
standards are coherent with 
Codex and FGSI 

•  Evidence of intra-policy 

coherence 

•  Stakeholder’s feedback on 
perceived complementarity 

and/or synergies between the 

policies (or lack thereof) 

To what extent are the 
marketing standards 
coherent with private 
standards? 

•  Extent to which the marketing 
standards are coherent with 
private marketing standards. 

•  Stakeholder’s feedback on 
perceived complementarity 

and/or synergies between the 

policies (or lack thereof) 

•  Open Public Consultation  

•  Literature review of Codex, Global 
Food Safety Initiative and other 
recognised standards/codes. 

•  Stakeholders’ consultation: 

management authority, traders, 
processors, control agencies and 
designated experts and EU staff 
on market  

•  Detailed interviews in several MS 

•  Consultation with FAO Codex 

team. 

•  Desk review of private marketing 

standards. 

•  Stakeholders’ consultation: 

management authority, traders, 
processors and designated 
experts and EU staff on market  

•  Detailed interviews in several MS. 

95 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

European Added Value 

Would national/regional 
standards provide the 
same result? 

•  National / regional 

organisation would not be 
able or interested to develop 
marketing standards 

•  Interest and ability of 
national / regional 
organisations to implement 
marketing standards 

•  Fishery markets are 

international   

•  Level of internationalisation 
of the fishery market (intra-
EU trade, level of imports) 

•  What is the level of 

coherence of the different 
national standards the ones 
with the others and with EU 
marketing standards? 

•  Comparison of the content of 
national and EU marketing 
standards 

•  Qualitative interviews to 

management authorities, designated 
experts, national and regional 
organisations dealing with 
certification   

•  COMEXT statistics on trade 

•  Desk analysis on national and EU 

marketing standards 

•  Qualitative interviews to 

management authorities, designated 
experts, national and regional 
organisations dealing with 
certification   

•  COMEXT statistics on trade 

•  Desk analysis on national and EU 

marketing standards 

•  Qualitative interviews to 

management authorities, traders, 
processors, control agencies, 
designated experts, national and 
regional organisations dealing with 
certification and EU staff on market 

•  COMEXT statistics on trade 

•  Desk analysis on national and EU 

marketing standards 

EQ10. To what extent are EU 
marketing standards 
justifiable and provide added 
value in addition to 
international marketing 
standards (e.g. Codex)? 
Would national/regional 
standards provide the same 
result? What is the added 
value of the EU marketing 
standards compared to private 
standards in place in the 
supply chain? 

96 

 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

European Added Value 

•  In case of high coherence 

•  Comparison of the content of 

•  Qualitative interviews to 

between the national 
standards: to what extent 
mutual recognitions could be 
developed between these 
national standards? 

national standards.  

Opinion of stakeholders on 
recognitions between 
national standards.  

management authorities, traders, 
processors, control agencies, 
designated experts, national and 
regional organisations dealing with 
certification and EU staff on market 
COMEXT statistics on trade 

•  Desk analysis on national and EU 

marketing standards 

•  In case of low coherence 

•  Comparison of the content of 

•  Qualitative interviews to 

between national standards, 
to what extent does it affect 
the functioning of the 
internal market? 

national standards. 

Opinion of stakeholders on 
the impact of national 
standards on internal 
market.  

What is the added value 
of the EU marketing 
standards compared to 
private standards in 

•  Content and geographical 
scope of EU marketing 
standards are more relevant 
than existing private 
standards  

•  Comparison of relevance of 

the content and geographical 
scope of EU marketing 
standards and existing 
private standards 

management authorities, traders, 
processors, control agencies, 
designated experts, national and 
regional organisations dealing with 
certification   

•  COMEXT statistics on trade 

•  Desk analysis on national and EU 

marketing standards 

Qualitative interviews: Catching sector, 
traders, processors, control agencies 
and designated experts 

97 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Evaluation questions 

Sub-questions 

Judgement criteria 

Indicators 

Methods 

place in the supply 
chain? 

European Added Value 

•  Applicability across supply 
chains is higher for EU 
marketing standards than for 
existing private standards. 

•  Comparison of the 

applicability across supply 
chains of EU marketing 
standards and existing 
private standards 

Qualitative interviews: Catching sector, 
traders, processors, control agencies 
and designated experts 

•  Specific features of the 

fishery sectors would lower 
the impact of private 
standards (in particular the 
low concentration of the 
sector) 

•  Shortcomings are identified 
in the supply chains not 
covered by EU marketing 
standards 

•  Marketing standards in the 
fishery sector are assessed 
to be useful 

•  Specific features of supply 
chains covered and not 
covered by marketing 
standards which would 
impact the implementation of 
marketing standards.  

•  Identification of features for 
the fishery sector which 
would lower the impact of 
private scheme  

Qualitative interviews: Catching sector, 
traders, processors, control agencies 
and designated experts and EU staff on 
market  

•  Shortcoming identified in the 
aquaculture and processed 
products supply chains 
related to the absence of EU 
marketing standards 

•  EU marketing standards and 
their implementation in the 
fishery sector are assessed to 
be relevant, effective, 
coherent and efficient 

•  Specific features of supply 

chains 

•  Interviews with operators: Catching 
sector, traders, processors, control 
agencies and designated experts and 
EU staff on market  

•  Interviews with operators: Catching 
sector, traders, processors, control 
agencies and designated experts 

Interviews with operators: Catching 
sector, traders, processors, control 
agencies and designated experts 

•  No sub-question 

EQ11. To what extent would 
EU marketing standards have 
been useful for the 
sectors/products currently not 
covered? 

98 

 
 
 
ANNEX 16.  FISH SOLD BY QUALITY GRADES IN A SAMPLE OF AUCTIONS 

Hantsholm & Nord (DK): 

The tables below show the recent trends in the proportion of fish per freshness grade for 
Hanstholm  and  Nord  auctions.  This  relatively  limited  time  series  does  not  show  clear 
trends, other than the reduction in non-graded fish to near zero. The very small amounts 
of ‘B’ grade fish remain at around 0.3% of total landed weight. 

Table 9: Proportion of fish sold per freshness grade (by weight) in Hanstholm 
auction 2014-17 

E 

A 

B 

X 

2014 

64.5% 

35.0% 

0.5% 

0.0% 

2015 

59.2% 

40.5% 

0.3% 

0.0% 

2016 

54.4% 

45.3% 

0.3% 

0.0% 

2017 

53.6% 

46.2% 

0.3% 

0.0% 

Source: Hantsholm auction 

Table 10: Proportion of fish sold per freshness grade (by weight) in Nord 
auction 2014-18 

E 

A 

B 

X 

Source: Nord auction 

2014 

78.6% 

20.8% 

0.3% 

0.3% 

2015 

88.5% 

11.2% 

0.3% 

0.1% 

2016 

84.1% 

15.7% 

0.2% 

0.0% 

2017 

68.8% 

31.0% 

0.2% 

0.0% 

2018 

58.8% 

41.0% 

0.3% 

0.0% 

Danish stakeholders stated that the freshness grade is very important in the first-hand sale 
of fresh and chilled products at auction. The name of the fishing vessel is also important in 
assessing quality as certain vessels are known for quality catch handling. 

Guilvinec (FR):  

The figure below shows the proportion of landings by size grade.  The  ‘v’ grade used for 
landings of live crustaceans and molluscs is not included in the totals. There are no evident 
trends  in  the  years  reported.  2015  appears  anomalous  with  substantially  more  E  grade 
landings, but also nearly 1/3 of landings given ‘B’ grade. In 2014 the grading included an 
A+ grade, but this was not used in subsequent years.  

Figure 13: Landings by quality grade on Guilvinec auction 2014-17* 

Source: Guilvinec auction 

* excluding ‘v’ grade for live landings 

 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 17.  DATA  ON 

INSPECTIONS  AND 

INFRINGEMENTS 

IN 

JOINT 

DEPLOYMENT PLANS 

The  2017  evaluation  of  the  Community  Control  System 13  found  that  the  number  of 
infringements  detected  concerning  marketing  standards  across  18  member  states 
increased from 780 in 2010 to 990 in 2014. During this reporting period the number of 
onshore  inspections  increased,  representing  close  to  80%  of  total  inspections  (20% 
offshore  inspections).  The  ratio  of  infringements  detected  increased  from  8.3%  of 
inspections in 2010 to 12.6% of inspections in 2014. These results are thought to represent 
improved  control  and  inspection  procedures  rather  than  an  increased  tendency  towards 
non-compliance  with  marketing  standards.  Indeed,  the  NA  survey  suggested  that  most 
non-compliance  identified  from  market  inspections  were  not  related  to  the  marketing 
standards, but to hygiene, traceability and MCRS. 

Figure 14: Number of inspections and infringements on Joint Deployment Plans 
2012-2017 

Source: EFCA 

13 https://publications.europa.eu/en/publication-detail/-/publication/0edfa926-d328-11e6-ad7c-01aa75ed71a1  

100 

 
 
 
 
                                           
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 18.  AVAILABILITY  OF  INFORMATION  ON  CONSERVATION  OF  SPECIES 

UNDER MARKETING STANDARDS BUT WITHOUT MCRS  

Species 

Latin name 

Management 
measures14 

Existence of assessment, 
number of stocks assessed 
and comments ( assessment 
are by ICES, unless stated 
otherwise) 

Spotted 
dogfish 

Scyliorhinus spp. 

No measure 

No  

Dab 

Limanda limanda 

No measure 

Lemon sole  

Microstomus kitt 

No measure 

Conger eel  

Conger conger  

No measure 

Picked 
dogfish 

Squalus acanthias 

Prohibited to retain on 
board (art. 45) 

Ray's bream 

Brama spp. 

No measures 

No 

No 

No 

No 

No 

Anglerfish 
(Atlantic) 

Blue whiting 

Lophius spp. 

TAC 

Yes 

5 stocks 

Micromesistius 
poutassou / Gadus 

TAC 

p. 

Yes 

1 stock 

Albacore 

Thunnus alalunga 

Big-eye tuna 

Thunnus obesus 

TAC and capacity 
restriction, incl. non-EU 
waters 

Boghe 

Boops boops 

No measures 

Picarel 

Maena sararis 

No measures 

Trigla spp. 

No measures 

ICCAT and other 
RFMOs 

ICCAT and other 
RFMOs 

Yes 

Yes 

No 

No 

No 

No measures 

Yes 

1 stock (grey gurnard) 

Gurnard / 
Tub gurnard 

Other 
Gurnard 

Skate 

Raja spp. 

TACs and other 
restrictions 

Frostfish 

Lepidopus caudatus  No measures 

Flounder  

Platichtbys flesus 

No measures 

Yes 

No 

No15 

14 COUNCIL REGULATION (EU) 2018/120 of 23 January 2018 fixing for 2018 the fishing opportunities for certain fish stocks and 
groups  of  fish  stocks,  applicable  in  Union  waters  and,  for  Union  fishing  vessels,  in  certain  non-Union  waters,  and  amending 
Regulation (EU) 2017/127 

15 ICES prepares an assessment of flounder (Platichthys flesus)  

101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                           
Evaluation of the marketing standards framework for fishery and aquaculture products  

Species 

Latin name 

Management 
measures14 

Existence of assessment, 
number of stocks assessed 
and comments ( assessment 
are by ICES, unless stated 
otherwise) 

Black 
scabbardfish 

Aphanopus carbo 

By catch counted 
against quota of (blue) 
ling  

Yes 

1 stock 

Cuttlefish 

Sepia officinalis and 
Rossia macrosoma 

No measures 

Crangonid 
shrimps 

Crangon crangon 

No measures 

No 

No 

MSC certification of 
crangon fishery 
requires a minimum 
size of 6.8 mm 

Pandalid 
shrimps 

Pandalus borealis 

Black sea 
bream 

Spondyliosoma 
cantharus 

TACs and other 
restrictions 

No measures 

Sprat 

Sprattus sprattus 

TAC 

Yes 

1 stock 

No 

No 

102 

 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

ANNEX 19.  COMPARISON BETWEEN MINIMUM MARKETING SIZES AND MCRS 

Scale of market size 

Minimum conservation 
reference sizes 

Herring 

Clupea 
harengus 

Size 

kg per fish 

Region 

Number 
of fish per 
kg 

1 

2 

3 

> 0.25 kg 

4 or less 

Areas 1-5, except A  20 cm 

0.125  -  0.25 
kg 

 5 - 8 

A 

18 cm 

0.085 
0.125 kg 

- 

 9 - 11 

4 (a) 

0.05 - 0.085  12 - 20 

Baltic  herring,  Caught 
and landed South of 59o 
30’ 

4 (b) 

0.036 
0.085 

- 

12 - 27 

Baltic  herring,  Caught 
and landed North of 59o 
30’ 

4  (c) 

0.057 
0.085 

- 

12 - 17 

5 

6 

7 (a) 

Baltic herring caught and 
landed  in  waters  under 
the 
and 
sovereignty 
jurisdiction  of  Estonia 
and Latvia 

0.031 
0.057 

0.023 
0.031 

0.023 
0.036 

- 

18 - 32 

- 

 33 - 44 

- 

28 - 44 

7 (b) 

0.014 
0.023 

- 

45 - 70 

8 

0.01 - 0.014  71 - 100 

Baltic  herring,  Caught 
and landed in the Gulf of 
Riga  

103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Sardine 

Sardina 
pilchardus 

Mediterranean 

Spotted 
Dogfish 

Scyliorhinus 
spp. 

Piked 
dogfish 

Squalus 
acanthius 

Redfish 

Sebastes 
spp. 

Cod 

Gadus 
morhua 

1 

2 

3 

4 

1 

2 

3 

1 

2 

3 

1 

2 

3 

1 

2 

3 

4 

104 

> 0.067 kg 

15 or less 

Areas 1-5, except A  11 cm 

0.042 
0.067 kg 

0.028 
0.042 kg 

0.015 
0.028 kg 

- 

16 - 24 

Mediterranean 

11 cm 

- 

25 - 35 

- 

36 - 67 

0.011 
0.028 kg 

- 

36 - 91 

> 2 kg 

1 - 2 kg 

0.5 - 1 kg 

2 or less 

> 2.2 kg 

1 - 2.2 kg 

0.5 - 1 kg 

2 or less 

> 2 kg 

0.6 - 2 kg 

0.35 - 0.6 kg 

 2 - 3 

> 7 kg 

Areas 1-5, except A  35 cm 

4 - 7 kg 

2 - 4 kg 

1 - 2 kg 

A 

30 cm 

Baltic 

38 cm 

subdivisi
on  22-
32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Saithe 

Pollachius 
virens 

5 

1 

2 

3 

4 

0.3 - 1 kg 

3 or less 

South  of 
59o30'N 

35 cm  

> 5 kg 

Areas 1-5, except A  35 cm 

3 - 5 kg 

A 

30 cm 

1.5 - 3 kg 

0.3 - 1.5 kg 

3 or less 

Baltic 

South  of 
59o30'N 

30 cm  

Haddock  Melanogram

1 

> 1 kg 

Areas 1-5, except A  30 cm 

mus 
aeglefinus 

Whiting 

Merlangius 
merlangus 

2 

3 

4 

1 

2 

3 

4 

0.57 - 1 kg 

2 or less 

A 

27 cm 

0.37  -  0.57 
kg 

 2 - 3 

0.17  -  0.37 
kg 

 3 - 6 

> 0.5 kg 

2 or less 

Areas 1-5, except A  27 cm 

0.35 - 0.5 kg 

 2 - 3 

A 

23 cm 

0.25  -  0.35 
kg 

 3 - 4 

0.11  -  0.25 
kg 

 4 - 9 

Ling  

Molva spp. 

1 

> 5 kg 

Areas 1-5, except A  63 cm 

2 

3 

3 - 5 kg 

1.2 - 3 kg 

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Evaluation of the marketing standards framework for fishery and aquaculture products  

Mackerel  Scombrus 
scombrus 

Mediterranean 

Scomber 
japonicus 

Anchovy 

Engraulis 
spp. 

1 

2 

3 

1 

2 

3 

4 

1 

2 

3 

4 

Plaice 

Pleuronectes 
platessa 

1 

> 0.5 kg 

2 or less 

Areas  1-5,  except 
North Sea 

20 cm 

0.2 - 0.5 kg 

 2 - 5 

North 
Sea 

30 cm 

0.1 - 0.2 kg 

06-ott 

Mediterranean 

18 cm 

0.08 - 0.2 kg 

 5 - 13 

> 0.5 kg 

2 or less 

0.25 - 0.5 kg 

 2 - 4 

0.14  -  0.25 
kg 

05-lug 

0.05  -  0.14 
kg 

 7 - 20 

> 0.033 kg 

30 or less 

3, except ICES IXa)  12 cm 

0.02  -  0.033 
kg 

 31 - 50 

 ICES 
IXa) 

10 cm 

0.012  -  0.02 
kg 

 51 - 83 

Mediterranean 

9 cm 

- 

 84 - 125 

0.008 
0.012 kg 

> 0.6 kg 

Areas 1-
5 

27 cm 

2 

3 

4 

0.4 - 0.6 kg 

2 or less 

0.3 - 0.4 kg 

 2 - 3 

0.15 - 0.3 kg 

 4 - 6 

Baltic 

subd 22-
32 

25 cm 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

1 

2 

3 

4 

5 

1 

2 

3 

4 

Hake 

Merluccius 
merluccius 

Mediterranean 

Megrim 

Lepidorhom
bus spp. 

Mediterranean 

> 2.5 kg 

Areas 1-5, except A  27 cm 

1.2 - 2.5 kg 

A 

30 cm 

0.6 - 1.2 kg 

Mediterranean 

20 cm 

0.28 - 0.6 kg  3 or less 

0.2 - 0.28 kg 

 4 - 5 

0.15  -  0.28 
kg 

 4 - 6 

> 0.45 kg 

2 or less 

Areas 1-5, except A  20 cm 

0.25  -  0.45 
kg 

 2 - 4 

A 

25 cm 

0.20  -  0.25 
kg 

 4 - 5 

0.11  -  0.20 
kg 

 6 - 10 

0.15  -  0.28 
kg 

03-giu 

Ray's 
bream 

Brama spp 

1 

> 0.8 kg 

2 

0.2 - 0.8 kg 

 1 - 5 

Lophius 

1 

> 8 kg 

2 

3 

4 - 8 kg 

2 - 4 kg 

Anglerfis
h 

whole 
gutted 

107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

1 - 2 kg 

0.5 - 1 kg 

> 4 kg 

2 - 4 kg 

1 - 2 kg 

0.5 - 1 kg 

0.2 - 0.5 kg 

> 0.25 kg 

4 or less 

0.13 - 0.25 

 5 - 7 

> 0.6 kg 

0.35 - 0.6 kg 

 2 - 3 

0.15  -  0.35 
kg 

 3 - 6 

> 4 kg 

1.5 - 4 kg 

> 70 kg 

Mediterranean 

30 kg or 
115 cm 

50 - 70 kg 

25 - 50 kg 

10 - 25 kg 

6.4 - 10 kg 

4 

5 

1 

2 

3 

4 

5 

1 

2 

1 

2 

3 

1 

2 

1 

2 

3 

4 

5 

head 
removed 

Dab 

Limanda 
limanda 

Lemon 
sole 

Microstomus 
kitt 

Albacore 
tuna 

Thunnus 
alalunga 

Bluefin 
tuna 

Thunnus 
thynnus 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Bigeye 
tuna 

Thunnus 
obesus 

Pollack 

Pollachius 
pollachius 

Blue 
whiting 

Micromesisti
us 
poutassou 

Pouting 

Trisopterus 
spp. 

1 

2 

1 

2 

3 

4 

1 

2 

3 

4 

1 

2 

3 

4 

> 10 kg 

3.2 - 10 kg 

> 5 kg 

Areas 1-5 except A  30 cm 

3 - 5 kg 

1.5 - 3 kg 

0.3 - 1.5 kg 

> 0.14 kg 

7 or less 

0.07  -  0.14 
kg 

 8 - 14 

0.04  -  0.07 
kg 

14 - 25 

0.03  -  0.04 
kg 

26 - 30 

> 0.4 kg 

2 or less 

0.25 - 0.4 kg 

 3 - 4 

0.125  -  0.25 
kg 

 5 - 8 

0.05  -  0.125 
kg 

9 - 12 

Boghe 

Boops boops  1 

> 0.2 kg 

5 or less 

2 

3 

0.032  -  0.2 
kg 

giu-31 

0.014 
0.032 kg 

- 

 32 - 70  

109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

Picarel 

Maena 
sararis 

Conger 
eel 

Conger 
conger 

1 

2 

3 

1 

2 

3 

> 0.05 kg 

20 or less 

0.025  -  0.05 
kg 

21 - 40 

0.011 
0.025 kg 

- 

41 - 90 

> 7 kg 

5 - 7 kg 

0.5 - 5 kg 

Gurnard 

Triglia spp 

1 

> 1 kg 

Areas 2-
3 

58 cm 

Other 
Gurnard 

Horse 
mackerel 

Trachurus 
spp. 

2 

3 

4 

1 

2 

1 

2 

3 

4 

5 

0.4 - 1 kg 

 1 - 2 

0.2 - 0.4 kg 

 3 - 5 

0.06 - 0.2 kg  giu-16 

> 0.25 kg 

4 or less 

0.2 - 0.25 kg 

 4 -5 

> 0.6 kg 

0.4 - 0.6 kg 

2 or less 

0.2 - 0.4 kg 

 2 - 5 

0.08 - 0.2 kg 

  6 - 12 

Areas 1-
3, 5 

15 cm 

0.02  -  0.08 
kg 

 13 - 50 

Mediterr
anean 

12 cm 

Mullet 

Mugil spp. 

1 

> 1 kg 

Areas 2-
3 

20 cm 

2 

0.5 - 1 kg 

2 or less 

110 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

3 

4 

1 

2 

3 

4 

1 

2 

1 

2 

Skate 

Raja spp. 

wings 

Flounder 

Platichthys 
flesus 

0.2 - 0.5 kg 

 3 - 5 

0.1 - 0.2 kg 

 6 - 10 

> 5 kg 

3 - 5 kg 

1 - 3 kg 

0.3 - 1 kg 

3 or less 

> 3 kg 

0.5 - 3 kg 

> 0.3 kg 

3 or less 

0.2 - 0.3 kg 

 4 - 5 

Areas 1-
3 

Baltic 
Sea 

Mediterr
ean 

11 cm 

24 cm 

25 cm 

21 cm 

18 cm 

Subdivis
ions  22 
to 25  

Subdivis
ions  26 
to 28 

Subdivis
ions  29 
to 
32, 
south  of 
59°  30’ 
N 

Sole 

Solea spp. 

1 

> 0.5 kg 

2 or less 

Areas  1-
5 

24 cm 

2 

3 

4 

0.33 - 0.5 kg 

 2 - 3 

0.25  -  0.33 
kg 

 3 - 4 

0.20  -  0.25 
kg 

 4 - 5 

111 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products  

0.12 - 0.2 kg 

 5 - 8 

Mediterr
ean 

20 cm 

> 3 kg 

2 - 3 kg 

1 - 2 kg 

0.5 - 1 kg 

2 or less 

> 3 kg 

0.5 - 3 kg 

2 or less 

> 0.5 kg 

2 or less 

0.3 - 0.5 kg 

 2 - 3 

0.1 - 0.3 kg 

 3 - 10 

> 0.05 kg 

20 or less  Whole  area,  except 
Region  3  and  ICES 
VIa,  VIIa: 
total 
length  

0.033  -  0.05 
kg 

21 - 30 

ICES  VIa,  VIIa; 
Region 3:  

total 
length 
85  mm, 
carapac
e length 
25 mm 

total 
length 
70  mm, 
carapac
e length 
20 mm 

0.025 
0.033 kg 

- 

31 to 40 

Norway lobster tails 

< 0.025 kg 

> 40 

5 

1 

2 

3 

4 

1 

2 

1 

2 

3 

1 

2 

3 

4 

Frostfish 

Lepidopus 
caudatus 

Black 
scabbardf
ish 

Aphanopus 
carbo 

Cuttlefish  Seppia 

officinalis 

Rossia 
macrosoma 

Norway 
lobster 

Nephrops 
norvegicus 

112 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the marketing standards framework for fishery and aquaculture products 

tails 

1 

> 0.017 kg

60 or less  Whole 

46 mm 

area, 
except 
Region 
3 
ICES 
VIa, 
VIIa: 

and 

ICES 
VIa, 
VIIa; 
Regione 
3: 

37 mm 

2 

3 

4 

1 

2 

0.008 
0.017 kg 

- 

61 - 120 

0.005 
0.008 kg 

- 

121 to 180 

< 0.005 kg 

> 180

> 6.8 mm

> 6.5 mm

Crangoni
d shrimp 

Crangon 
crangon 

Pandalid 
shrimp 

Pandalus borealis 

fresh or chilled 

boiled or steamed 

1 

1 

2 

> 0.004 kg

250 or less 

> 0.006 kg

160 or less 

0.004 
0.006 kg 

- 

 161 - 250 

113 

K
L
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0
3
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1
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E
N
-
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ISBN:978-92-76-12798-7 
doi: 10.2771/380476

111111311

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