Dominic Whitmee, Chief Executive
As a sector we continue to face growing pressures from the animal rights community which is increasing its efforts to curtail the trade in pets - with some campaigns particularly targeting tropical fish. Sadly, we see more and more often that many of these campaigns are based on little in the way of solid facts.
We saw this lack of interest in relying on facts during the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) marine ornamental fishes’ workshop in Australia where one of the leading anti-aquarium trade representatives displayed a shocking lack of understanding about how our trade even operates. Disappointingly, many officials present did not acknowledge this failing, either through their own lack of knowledge or an unwillingness to tackle misplaced assumptions and statements. It is deeply concerning the sway these organisations have in influencing future policies that affect our industry but it was pleasing to see how the trade representatives present were able to coordinate their interventions to send very clear messages that helped to avoid inappropriate outcomes.
Reliance on the rhetoric and misinformation employed by the anti-trade lobby is not a tactic we will resort to. We will continue to be honest in our dealings with others, basing our lobbying positions on good quality science, evidence and facts. And in that regard, we are pleased to welcome our new Scientific Support Officer to help us continue to build our evidence base. This evidence-based approach does seem to be showing some benefits as we are increasingly being reached out to by many key decision-makers to assist in their deliberations.
As with many large institutions that engagement is variable and sometimes extremely poor. This is demonstrated most obviously in the Government’s continued failure to listen to the experience of the very many stakeholders advising on alternative courses of action around border controls. However, we now have a new Government and wait to see whether they will live up to their commitments to work in partnership with business to remove barriers to growth and build a stronger economy. We will lobby them extensively to hold them to account.
Focus on fish - our work on sustainable sourcing
This year we came to the end of one stage of a longstanding work programme looking at the trade in marine ornamental fish, prompted by the CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora). It had launched a significant project in 2019 at its Conference of the Parties (COP) to examine the conservation priorities and management needs of non-CITES listed marine ornamental fishes. Five years later, this initiative culminated in a pivotal workshop held in May 2024 in Brisbane, Australia, which brought together a diverse array of stakeholders to discuss how to tackle the trade and conservation of marine fish species.
Workshop Highlights
The workshop witnessed an impressive turnout, including trade representatives from Europe, the USA, and the Asia-Pacific region. Trade associations such as OATA (UK), Ornamental Fish International (OFI), Indonesia Ornamental Fish Exporters Association (INOFE), Indonesian Coral, Shell and Ornamental Fish Association (AKKII), the Sri Lankan Exporters’ Association, the Pet Advocacy Network (PAN, US), and the Pet Industry Association of Australia (PIAA) were present. They were joined by academics, anti-trade organisations, official bodies such as FAO, IUCN and WCMC, and government officials from different countries including source countries and the UK’s Joint Nature Conservation Committee (JNCC) and the Centre for Environment, Fisheries and Aquaculture Science (Cefas).
In the lead-up to the workshop, OATA and OFI conducted extensive preparatory work. We collated trade data to identify marine ornamental fish species in trade and developed a framework that could be used to prioritise species needing conservation efforts that had the backing of the global industry. This preparation provided valuable statistics and enabled a co-ordinated trade approach during the workshop. This enabled us to quash an attempted proposal to identify around 200 unnamed species for prioritisation, with no indication of what that prioritisation was for. Our continued efforts at the subsequent Animals Committee in July 2024 also ensured that recommendations remained on the need for further research to identify species that may be vulnerable to trade.
Sustainable Sourcing Initiatives
Preparing for all this has placed a huge burden on OATA’s small office team. But the preparatory work has broader applications, particularly for our ongoing projects aimed at developing tools to help businesses make sustainable purchasing decisions. These key initiatives include:
Database Development: We aim to develop a database of freshwater fish species in trade, equivalent to our existing marine species database developed for the CITES Marine Ornamental Fishes workshop. What this revealed is that the number of marine species actually in trade (1,040) is around half (2,035) of those mentioned in academic literature.
Framework Development: Our work developing a framework to help prioritise marine species in most need of conservation protection has helped with our plans to create a voluntary sustainability tool that retailers, wholesalers and importers could use to make informed decisions about the animals they stock.
Sustainable Sourcing Discussions: We have been involved in discussions with the public aquarium sector about possible means to identify whether fish have been sustainably and ethically sourced, including options for traceability, accreditation and certification schemes. These discussions resulted in a report for the public aquarium community, and we await further discussions about how its conclusions might be put into practice across the industry, including ours which supplies public aquariums, with minimal burdens.
Coral Reef Conservation: We are supporting Cefas, with its project focusing on coral reef conservation, management, and restoration, helping to link coral farmers with restoration projects.
Active Conservation Engagement: We continue to engage with relevant conservation activities, such as the ZSL UK sturgeon action report 2023, and continue to encourage our member businesses’ ongoing engagement with initiatives like Shoal.
Preparing for the CITES marine ornamental fishes’ workshop in Brisbane has been a significant workload for our small office team. While the outcome may not have met all expectations, the groundwork and the collaborative spirit demonstrated by the participants has been invaluable. Moving forward, we have learnt lessons about how to develop further tools to help industry make sustainable choices.
Focus on borders - navigating new import regulations
As we reflect on the past year, it’s important to address the significant regulatory changes impacting the importation of plants, animals, and their products into the UK from the EU. Eight years post-Brexit, 2024 marked a pivotal year with the introduction of the Border Target Operating Model (BTOM) on January 31st. This model has introduced new risk categories for plant and animal products with new checks/controls in place on products from the EU. This new system has led to considerable challenges for our members and is likely to present more challenges if the Government pursues what has been planned in the BTOM.
New Import Challenges and Our Response
One of the key changes has required importers to present consignments for physical and documentary checks at the border. These checks are a source of delays for consignments of plants or animal products coming into the UK, particularly when there has been issues with Government IT and lack of clarity on requirements on certain commodities. Live animals, categorised as high risk, will require comprehensive checks at Border Control Posts (BCPs) at some point in the future, and unfortunately, the trusted trader status we lobbied for has not been granted.
Despite the delay in introducing full checks on live animals—now postponed to 2025—we anticipate increased problems once these checks begin. Currently, Dover is the only seaport in the UK designated to handle live animal imports from the European mainland - through the inland border facility at Sevington - which we maintain creates a capacity issue that needs immediate attention or risks creating bottlenecks, backlogs and delays – which would all impact animal welfare. This remains a key message we continue to highlight to the new UK Government.
Our members have faced multiple complications with consignments under the new regime, and we foresee exacerbated challenges when live animal checks are fully enforced. Therefore, our focus remains on advocating for necessary changes to the BTOM.
Advocacy and Future Strategies
We are actively seeking several changes to the BTOM to mitigate its impact on our sector:
1. Aquatic Animals Categorisation: We are lobbying against the categorisation of aquatic animals as high risk, which prevents access to Trusted Trader schemes. Following our continued lobbying the Government has said it may review this categorisation based on the success of medium-risk product schemes.
2. Feed Categorisation Ambiguity: We seek clear distinctions between frozen and live feed categories to prevent potential welfare and economic impacts. We aim for derogation from stringent controls given the low biosecurity risk posed by these products.
3. Physical Checks Clarity: While the Government has indicated no increase in physical checks, we continue to demand clarity on this matter across a variety of products traded by our industry.
4. BCP Capacity Issues: The limited number of BCPs handling European traffic poses a significant bottleneck. In our election manifesto, we proposed several solutions, including reciprocal veterinary arrangements with the EU, continued use of Points of Destination for inspections, and broader application of Trusted Trader schemes based on species and country combinations. We also urged for the construction and funding of additional BCPs.
Improving IT Systems and Border Services
Ongoing discussions with the Fish Health Inspectorate (FHI), the Animal and Plant Health Agency (APHA), and other border officials aim to enhance IT systems and border services. These improvements are crucial for maintaining efficient and effective import processes. There are currently different approaches within Government to facilitating trade at the border and adopting a pragmatic, risk-based approach. Whilst we see plant health teams discuss openly the need to work with stakeholders to promote trade, in other areas of Government we see highly risk averse attitudes which penalise minor errors, delay shipments, increase costs and potentially impact animal welfare at the border.
Additional Border-Related Activities
We have actively engaged with the Government on reviewing CITES Wildlife Trade Regulations (WTR), advocating for the removal of redundant regulations that do not contribute to conservation. Our efforts to address poor service from the CITES licensing teams also led to the establishment of a working group to improve response times. Additionally, we are advocating for simpler licensing processes and the introduction of e-permitting. We have also highlighted the issue of BCP fees, particularly out-of-hours charges. Importers face higher fees without corresponding service standards, prompting us to work with major importers to push for fairer fee structures.
The past year has been one of significant regulatory challenges, but through continued advocacy and strategic collaboration, we are striving to mitigate these impacts and support our members. We will continue to highlight issues and seek necessary changes and improvements and hope the new UK Government will be more receptive than has been the case to date.
Other activities this year
1. Government Advisory and Consultations
Raised serious concerns about the Government’s consultation process for updating the Susceptible and Vector Species list and its reluctance to engage with stakeholders or provide any detail about the controls being planning.
2. Election Manifesto
Launched a manifesto with four key pledges in the lead-up to the UK General Election in July.
3. Support for Pet Know How Website
Supported the Pet Charity’s Pet Know How project by providing 15 aquatics tests for inclusion on the website. Pet Know How is an online tool to help first time pet buyers understand the basic needs of the animals they are thinking of purchasing and will help pet shops in meeting their licencing requirements
4. Companion Animal Sector Council (CASC) Activities
Collaborated with CASC on the English Animal Activity Licensing review, detailing proposed improvements, and the Welsh review, where we highlighted the need to fix problems with current requirements before moving to new areas to licence.
Submitted proposals for improvements to Defra as part of the Periodic Implementation Review, using feedback from our members and the industry, including how Defra can make animal activities licencing simpler and ensure better animal welfare.
5. Invasive Species Control
Collaborated with the GB Non-Native Species Secretariat (GBNNSS) in its work to develop a Pet Pathway Action Plan, which aims to educate the public and raise awareness about not releasing pets into the wild. We are also helping to the GBNNSS prepare a public awareness campaign about the plan.
Engaged continuously on proposed invasive species controls and listings, including the Chinese mystery snail and purple pitcher plant.
6. Water Hyacinth Delisting
Continued to press for the official delisting of water hyacinth to enable it to be sold in Great Britain. Unfortunately, the July election stopped the planned finalisation of the draft Statutory Instrument (SI) and we will continue to pursue this with the new Government.
7. Retailer Guidance on Pond Plants
Issued guidance to retailers to stop selling plants named Gunnera manicata due to the risk of misidentification with the banned G. tinctoria and promoted other Be Plant Wise messages during Invasive Species Week 2024.
8. New Team Member
Welcomed Emily Maunder as our new Scientific Support Officer. Emily joined from Pets at Home and has been contributing to our data analysis work for CITES, our annual Trade Statistics report and all our other research needs for work projects. She will also become an assessor on our City & Guilds training programmes.
9. Member Engagement
Launched a members’ Facebook group to enhance communication and engagement. We also created a new video giving advice to businesses on water testing based on our Water Quality Criteria document.
10. Research and Academic Collaboration
Recruited PhD and Masters students to partner on research into the sustainability of livestock sourcing, the industry’s role in achieving conservation and sustainability objectives, supporting livelihoods, and the social benefits of aquarium keeping.
Practical training for local authority inspectors
Continued the development of our practical training course for local authority inspectors to help them better understand the aquatic businesses they licence.
Reporting illegal trade
Continued to highlight and provide examples to law enforcement to tackle illegal imports.
Behind the scenes at OATA - introducing our small team
The Directors who sit on our Board (as at July 2024)
The office team is supported by our volunteer Board of Directors who each bring their particular industry expertise to our work. We are always interested in having new people join us so if you are interested in a seat on the Board then email or talk to our Office Manager Ray Valovec to find out more.
Laura Carlin (EcoMarines) CHAIR, Dr Donna Snellgrove (Mars WALTHAM) VICE CHAIR, Ben Bowles (Pets at Home) (stoepped down Sept 2024), Robert Edgecock (Independent Aquatic Imports Ltd), Caroline Everett (Anglo Aquatic Plants Co Ltd), Neil Hardy (Neil Hardy Aquatica Ltd), Paul Hughes (Advanced Aquarium Consultancy), Phil Jones (KKC/Swell Aquatics), Simon Langdale (Maidenheads Aquatics @ Iver), Philip Lawton (Kidsgrove Tropicals), Rob Peck (The Coral Centre), Max Pedley (Ornamental Aquatics Worldwide), Brian Schaff (TMC), Pete Smith (Aquasense UK Ltd), Matthew Stevenson (Seneye), Maurits van de Pol (Aquadistri UK Ltd)
The AGM is on Wednesday 4 December 2024 and all OATA members will be invited to attend.
Contact our office: 07946 167121, info@ornamentalfish.org, Wessex House 40 Station Road Westbury Wiltshire BA13 3JN
A company limited by guarantee and registered in England No. 2738119 Registered office: Wessex House, 40 Station Road, Westbury, Wiltshire, BA13 3JN