2. Review of the Sourcing Code for Fishery Products and Recommendations for Improvement

Issues regarding Fishery Products

Humans have historically been harvesting food from the oceans. In recent years, the importance of fishery products as a global source of protein has increased, with the average seafood consumption per capita rising from 9.0 kg in 1961 to 20.3 kg in 2016. Meanwhile, it has been pointed out that 33% of marine resources are already depleted due to the effects of global overfishing. In addition, the value of production from IUU (illegal, unreported and unregulated) fishing, a major obstacle for effective resource management, is estimated to be between $1 billion and $2.3 billion per year worldwide. Some scientists estimated that the introduction of a proper resource management system could increase profits by about $5 billion annually.
Given this situation, securing sustainable sourcing of fishery products is regarded as important not only for the conservation of marine ecosystems but also for the improvement of global food security and the livelihood of coastal areas. It could also promote the introduction of appropriate resource management frameworks and the improvement of compliance from the perspective of consumption. Japan being one of the world's leading countries in seafood consumption, it is expected to play a major role in driving sustainable consumption of fishery products.
The following risks are commonly associated with the sourcing of fishery products.

  • Whether production activities have any adverse effects on biodiversity and/or local communities is not reviewed, or adverse effects have actually occurred. (Sourcing of depleted resources, the bycatch, and insufficient consideration on the human rights and working environment for local stakeholders including producers.)
  • Legality based on the suppliers’ self-declaration cannot guarantee the environmental and social risk management, and it cannot sufficiently mitigate the risk of  marine resource depletion.
  • The origin of the procured fishery products cannot be identified due to insufficient management of various documents and without the establishment of full-chain traceability from the fishing stage.
  • As a particular risk of the Olympic and Paralympic Games, when international stakeholders interested in sustainability of fishery products conduct follow-up surveys, they might find that procurement according to the sourcing code does not actually conform to the sourcing policy aimed at “contribution to the Sustainable Development Goals (SDGs)”.

Given that the Olympic and Paralympic Games are global events, the above-mentioned risks must be managed carefully to ensure the use of fishery products sourced in a sustainable manner. For this reason, the legality standards should be set to match the strictest standards such as those of the EU, and at least items mentioned below shall be checked.

Issues Regarding the Sourcing Code for Fishery Products

The fundamental principles for sustainable sourcing stipulate that the Tokyo 2020 Organising Committee considers the conservation of resources, biodiversity, and ecosystems for items provided during the preparation and operation of the Games (including ingredients of food provided in athlete’s village) – who is supplying, where they are supplied from, and how they are supplied.

However, the existing sourcing code, or standards that define how such considerations are actually fulfilled, is deemed inadequate to conserve ecosystems and ensure sustainability. Below is a summary of where the challenges lie and what criteria are needed.

Current Sourcing Code for Fishery Products

The fundamental principles for sustainable sourcing stipulate that considerations should be given to conservation of resources, biodiversity and ecosystems regarding who is supplying, where they are supplied from, and how they are supplied.

See below for the fundamental principles for the sourcing code (Tokyo Organising Committee of the Olympic and Paralympic Games)

While the fundamental principles cover the main points for ensuring sustainability, the each criterion under the principles which define how to satisfy the sustainability is not sufficient.
It is particularly insufficient in guaranteeing the conservation of ecosystems and therefore their sustainability.
The following are the three major issues.

Three Issues of the Sourcing Code for Fishery Products

  • Even if the product does not receive eco-label certification, it can be accepted if the producer has established Resource Management Plan (fishery) or Fishing Ground Improvement Plan (aquaculture) and the plan has been confirmed by the government. These plans often do not fully consider the standpoint of conserving marine ecosystems.
  • Certification systems that have some issues regarding transparency etc. are accepted, and accordingly, fishery products that have obtained these certifications are also accepted.
  • 90% of domestic products are applicable under the existing code. It is not strict enough to promote sustainable sourcing.


Regarding the procurement of fishery products, as a principle (Sustainable Sourcing Code for Fishery Products Section 2), not only resources but also ecosystems are taken into account. The underlying intention is commendable.
However, in order to ensure the sustainability of fishery products, all three points (the state of fishery resources, the ecological impact, and the management system) must be fully addressed.

Status of Fishery Resources Whether resources are maintained in good condition and resources are managed properly
Ecological Impact Whether endangered species are not being fished, other seafood and marine life are not being caught as by-products, and fisheries and aquaculture are not adversely impacting the surrounding environment and biodiversity
Management System Whether regulations and systems are in place to regulate the above two points, and whether they are being properly operated and managed for compliance

The problem with the existing sourcing code is that not all these points are addressed.
In particular, impact on the ecosystems can be completely disregarded in the procurement of fishery products.

The main issue is Section 4, which sets the standards for fishery products other than certified fishery products.

Sustainable Sourcing Code for Fishery Products (Section 4)

In the event that suppliers need fishery products without any certification specified in Section 3, any of the following methods shall apply to procured fishery products.

(1) Fishery products that are caught based on a national/local government-recognised plan for resource management, and whose satisfaction of condition (iv) in Section 2 has been confirmed through the procedure designated in the appendix. (2) Fishery products that are raised in farms managed based on a national/local government-recognised plan for maintenance and improvement of the fishery environment, and whose satisfaction of condition (iv) in Section 2 has been confirmed through the procedure designated in the appendix.

In the event that no resource management plan or fishing ground improvement plan has been prepared or has not been confirmed by a government agency:

(3) Fishery products whose satisfaction of (i) to (iv) in Section 2 has been confirmed through the procedure designated in the appendix, including fishery products caught or raised by fisheries or aquaculture based on improvement plans whose progress toward obtaining certifications specified in Section 3 can be monitored in a transparent and objective manner.

*Section 2 (iv): Confirm that appropriate measures have been taken in catching or producing the fishery products in light of relevant laws and regulations.

As such, non-certified fishery products can be procured (that is, sustainability is assumed to be ensured) if in compliance with laws and regulations and a resource management plan or a fishery management plan is available.

*Resource Management Plan (for fishery): voluntary resource management measures for each fish species or fishery type prepared by the fishery operator based on the resource management guidelines established by the national and prefectural governments. Contains information such as the current status of the target fish species and fishery types, marine areas, resource management measures (such as suspension of fishing, catch limit, expansion of mesh size, etc.), and the implementation period of activities.

* Fishery Management Plan (for aquaculture industry): voluntary management measures developed by fish farmers themselves to maintain and improve the environment of aquaculture and fisheries by limiting the environmental impact of aquaculture within the range of the fishing grounds and to achieve sustainable aquaculture production, created jointly or independently by fishing cooperatives. It contains information such as the target fish species, water area, types of flora and fauna in the water area, improvement targets for fishing grounds, measures for improvement, etc.

However, having a management plan does not necessarily guarantee proper environmental considerations.

Furthermore, these plans may not give adequate considerations for the management of overall ecosystems and other environmental concerns outside of the target fish.

From the sustainability point of view, it is not sufficient to only protect the target species of that particular fishery or aquaculture industry. The omission of considerations for total ecological impacts shows that sustainability cannot be ensured.

If the management plan ensures sustainability and it is being executed properly, then having a plan alone would be sufficient.

However, according to the Fisheries Agency's data, of the 1930 existing fisheries resource management plans, fish stocks have increased in only 36.7% of them and have remained constant or are decreasing in the remaining 63%. (Source: Fisheries Agency-Regulatory Reform Promotion Council, Fisheries Working Group)

In other words, looking at just one of the three factors to ensure sustainability, status of fishery resources, it can be seen that over 60% of the resources are not increasing.

The third point, the management system, is also not transparent, as it is not required to clarify whether there is a mechanism in place to ensure that the fisheries resource management plan and fishing ground improvement plan are implemented.

90% of Japan's catch falls under the fish species covered by the fisheries resource management plan. 90% of Japan's aquaculture production is covered by the fishing ground improvement plan.

This means that a sourcing code that recognises all fisheries covered by these plans carries the risk of considering virtually any fishery product as sustainable.

If the sourcing code can be met in spite of inadequate resource status, ecological considerations, and poor management systems, fishery products can be procured without any improvement in the current situation, without any guarantee of sustainability.

For the above reasons, there is a major issue in the sustainable sourcing code for fishery products.

In addition, certified fishery products are recognised as meeting the criteria for sustainability.

Certification Systems Approved by the Organising Committee

The Organising Committee recognises MSC, ASC, MEL and AEL as acceptable sustainable certification systems (Sourcing Code for Fishery Products Section 3). Of these, MSC and ASC are internationally recognised certification systems. To ensure reliability they use scientific and objective indicators and third-party verification on the “status of fishery resources,” “marine environmental impact,” and “management system.”

However, MEL and AEL are domestic certification systems that do not have procedures in place to ensure transparency. There is not enough information to determine the level of their reliability and sustainability.

Recommended Sourcing Code for Fishery Products

Thinking about the kind of standards currently needed to ensure sustainability at a large-scale international event and to leave them as a legacy for the future, WWF Japan recommends the following sourcing standards.

■Check Items

  • Stock status of target species and forage fish for aquaculture
  • Impact on the marine ecological environment due to production activities, such as bycatch
  • Appropriate mid- and long-term resource management system and fishery management system
  • Existence of any social conflicts involving indigenous peoples and local communities, and the working environment of workers
  • Traceability from products to the fishing sites or farms

Recommended Method of Checking

  • Establish a sourcing policy committed to eliminate fishery products derived from IUU (illegal, unreported and unregulated) fishing, to conserve marine area with high conservation values (HCVs), to consider the social aspects such as securing the proper working environment, and to request the suppliers to comply with the sourcing policy.
  • Establish transparent traceability that can be traced back to production sites by keeping appropriate records
  • To ensure sourcing in line with the policy, it is necessary to procure MSC certified products for wild fish and ASC certified products for farmed fish, after obtaining Chain of Custody (COC) certification necessary for the management of processing, distribution and sales. In the event of difficulty in procuring MSC and ASC certified products, employ methods that use scientifically and objectively verifiable indicators to conduct a risk assessment on the three main factors: (1) status of fish stock, (2) marine environmental impact, and (3) management system (structure and system). Prioritize procurement from producers that collaborate with various stakeholders to implement medium- to long-term management and improvement plans for fisheries and aquaculture, for which progress can be objectively confirmed.
  • In the event of difficulty procuring certified products or products for which medium- to long-term management / improvement plan is in place, conduct a risk assessment on the (1) status of fish stock, (2) marine environmental impact, and (3) management system (structure and system) using scientific and objective indicators for fishery products to be potentially procured. Based on their results, select low-risk products and avoid high-risk products.
  • For the review and selection of specific methods, ensure a transparent process that allows participation of various stakeholders, including domestic and foreign suppliers, domestic and foreign experts, NGOs, and private companies.

i. Food and Agriculture Organization of the United Nations (FAO), 2016
ii. WWF-ZSL, 2018, “Living Blue Planet report”
iii. D.J. Agnew, J. Pearce, G. Pramod, T. Peatman, R. Watson, J.R. Beddington and T.J. Pitcher. 2009. Estimating the worldwide extent of illegal fishing. PLoS ONE, 4(2): e4570
iv. The World Bank-FAO, 2008, The Sunken Billions: The Economic Justification for Fisheries reform
v. FAO, 2016