ILLEGAL IMPORTS OF LIVE FISH

The Centre for Environment Fisheries and Aquaculture Science is an agency of the Department for Environment Food and Rural Affairs and is responsible for the prevention of serious fish disease in England and Wales. Its head office is located at Lowestoft and it has other laboratories in Burnham, Weymouth and Whitehaven. The Weymouth laboratory is the European Union national reference laboratory for fish diseases in England and Wales. It is home to the Fish Health inspectorate, a team of fourteen fish health inspectors, including eight field inspectors and five administrative and support staff. The inspectorate is responsible for carrying out routine inspections of all fish farms in England and Wales, and for licensing and monitoring all legal imports and exports of live fish and shellfish from the EU and third countries. CEFAS is also responsible for the prevention of illegal imports of live fish.

All imports of live fish into Great Britain from EU member states must be accompanied by a movement document attesting that the fish are healthy and free from disease. The documents must be issued and signed by the veterinary authorities in the country of origin. Prior notice must also be sent to CEFAS. Imports which fail to meet these criteria are illegal.

Throughout the European Union there are ‘approved’ farms and zones (EC directive 91/67) These are EC-designated areas which have been tested for and shown to be free of certain of the most serious fish diseases. Great Britain is currently an approved zone for VHS and IHN. Live fish may be legally transferred between areas of equivalent status or when the supplying zone is of a higher health status, provided the above procedure is complied with. Imports which fail to comply contravene the provisions of the Fish Health Regulations 1997. There are also specific additional regulations to further protect UK fish stocks against other serious diseases, such as Spring Viraemia of Carp, which are prevalent on the continent.

The dangers to indigenous fish of introducing diseased foreign imports may be evidenced by the increasing number of unexplained diseases and mortalities in our waters. Testing fish from previous interceptions of illegal consignments have established that they carried a variety of diseases including SVC. Illegally imported fish pose a very real problem which must be addressed if we are to remove the risk of spreading disease, and the possible demise of many of our waters.

The ecological effect of naturalised fish on native aquatic communities was summarised by Taylor et al (1984) as follows:

• Habitat alterations (eg through consumption or uprooting vegetation
• Introduction of parasites, pathogens and diseases
• Trophic alteration (eg by competition for food or predation)
• Genetic degradation (eg through hybridisation)
• Spatial alterations
• Environmental effects

There are large profits to be made by importers who steal fish, or purchase them cheaply from non-approved sites on the continent and sell them for large profits to fishery owners in the UK. Similar profits can be made by the fishery owners who impose high charges on anglers who are prepared to pay to catch larger, or different species of fish than may otherwise be available.

Although carp, wels catfish, sturgeon and zander are the obvious species, recent interceptions of illegal imports have included roach, bream and various species of ornamental fish. France, Belgium and Holland have been the traditional source countries for many large coarse fish in the past. However, it is believed that fish have been smuggled in from several of the Eastern European countries, including Hungary, Croatia and Poland, where carp are not only plentiful, but in less demand and therefore cheap.

Individuals and groups are involved on a regular basis in organising and arranging illegal imports. It is suspected that few of those responsible at the strategic level are involved in the physical act of importing the fish, being more inclined to employ others to do it for them. These friends, or associates, who could for example be members of fishing syndicates, are known to use hired vans or borrowed vehicles and seldom use their own transport for obvious reasons. It is likely that, like us, a significant number of the fishing public and the popular fishing press know the identities of many of the individuals who are regularly involved in organising illegal imports, and the names of those waters which are prepared to introduce illegally-imported foreign fish. However, knowing it and proving it are two very different things.

Three of the most recent cases brought against illegal importers have resulted in the following penalties:

1. Fined £2,000 and ordered to pay £1,000 costs. All fish forfeited
2. Fined £3,700 and ordered to pay £3,960.36 costs. All fish forfeited.
3. 240 hours Community Service Order and ordered to pay £3,428.18 cost. All fish forfeited.

The main reason more people are not caught is because it is a relatively simple matter to smuggle fish in from the continent. The introduction of the European free-trade regime in 1993 made smuggling across Europe significantly easier. Illegal imports are only one of many responsibilities for CEFAS which has only limited resources, but these could be used to better effect if more information was available on the activities of the smugglers. Strenuous efforts are being made to address these issues, but without question the biggest problem is the dearth of timely and accurate information. The trade will not be stopped without the active support and co-operation of those involved in the industry.

The current strategy incorporates the following features:

• CEFAS is combining a more robust and imaginative approach to the problem of illegal imports (and indeed to other areas of enforcement) with a more measured long-term gathering of information and evidence with other agencies. This will hopefully lead to a culture of shared-knowledge resulting in more information, better co-ordination, and more targeted operations against those responsible. Offences such as fish smuggling, fish thefts and illegal movements all represent potential disease risks and are often closely linked. For this reason we, along with the Environment Agency, are seeking information from the public and all other interested parties who may have information.
• CEFAS is developing liaison and co-operation with the Environment Agency, HM Customs, police forces, State Veterinary Service, the press and other interested parties such as the recently-formed ECHO (English Carp Heritage Organisation) whose stated aim is the elimination of all illegally imported fish. ECHO comprises individuals from across the board, (press, fishery owners, carp breeders, anglers, specialist authors, consultants etc) who are determined to protect the heritage of English carp. ECHO is due to be formally launched in December and CEFAS strongly supports its aims and objectives.
• Routine monitoring and inspections of imported fish consignments at points of arrival and destination.
• Targeted operations against suspected offenders.
• Meetings and liaison with the authorities in other EC and eastern European countries to advise them of the current situation and seek their assistance in combating fish thefts and illegal movements.
• More advanced training in investigative and enforcement techniques for our inspectors.
• A more structured approach to the problems surrounding illegal imports and fish-movements generally. The development by CEFAS, with the Environment Agency, National Assembly for Wales Agriculture Department and DEFRA of the new Live Fish Movements Database is an example of this approach. The recent creation by the Environment Agency of the new post of National Enforcement Co-ordinator will also significantly assist this process.
• The adoption of an open and more positive approach with the press and media to make the public more aware of what we do and why we do it. We also endeavour to candidly explain problem areas such as illegal imports, and seek the media’s assistance to educate the public over the potential dangers and threats involved, in an attempt to reduce the market for smuggled foreign animals. We also publish our ‘confidential hot line’ number to encourage the public to contact us with information.
• Attempting to establish the nature, extent and patterns of offending.

Whilst it is generally accepted that illegal imports is a continuing problem no one, including CEFAS, has sufficient reliable data to establish the full extent and implications of this trade. This is another area where we are seeking the support of other agencies and organisations.

• Introduction of the efishbusiness.com internet site which sets out details of the relevant legislation, the various procedures involved and other items of helpful information.

CEFAS needs information. Any information they may have concerning illegal imports can be sent in strict confidence to:-

Stephen Maidment
Investigations Inspector
CEFAS Weymouth Laboratory
Barrack Road
The Nothe
Weymouth
Dorset, DT4 8UB

Tel: 01305 – 206681 (out of hours answerphone)

01305 – 206673 (general office)

Fax: 01305 – 206602

E-mail: s.b.maidment@cefas.co.uk

Information relating to illegal movements and thefts of fish should be sent in strict confidence to:-

Christopher Window
National Enforcement Co-ordinator
Environment Agency HQ
Bromholme Lane
Brampton
Huntingdonshire, PE28 4NE

Tel: 01480 – 483021

Fax: 01480 - 433873