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Statement on State of Alaska Commissioner’s letter

Statement from MSC in response to the letter from Alaska Department of Fish and Game Commissioner, Doug Vincent-Lang.

We are deeply dismayed by the troubling accusations detailed in the letter from Alaska Department of Fish and Game Commissioner, Doug Vincent-Lang. While we recognize the concern in Mr. Vincent-Lang’s letter about the war in Ukraine, we believe that it does not capture the reality of MSC’s current operations relating to Russia and welcome the opportunity to set the record straight. Just to be clear, we have not lowered MSC’s certification requirements to enable Russian fisheries to stay in the program. We have asked the Commissioner for a meeting and look forward to explaining this to him in person.

We have unreservedly condemned the invasion of Ukraine by Russia and we are acutely aware of the suffering and anguish caused by the conflict. Like many international organizations, we have been grappling with how best to respond to consequences of the war. We are a global not-for-profit with a non-political mandate to end overfishing. Overfishing is an enormous environmental problem which threatens the future of our ocean and seafood supplies. It goes beyond national and regional considerations.

The Commissioner questions this motivation, stating instead we are seeking to protect our revenue. But the MSC’s program is set up in a way, precisely to protect against this potential conflict of interest. The certification activities are not carried out by MSC, but by third party, independent assessors whose activities are overseen by an independent assurance body. While we do derive logo fee revenue from ecolabeled products with certified Russian fish, the track record of our program is that fisheries which fail to meet requirements are suspended or lose their certificates, irrespective of how much revenue they generate for MSC’s not-for-profit activities. A case in point is 2019/20 when North-East Atlantic (NEA) fisheries had their certificates suspended due to concerns with the fisheries’ management, even though NEA mackerel and herring were among the top species generating logo license revenue for MSC.

The Commissioner’s assertion that it is our program that has kept Russian seafood flowing into Western markets is also far from the mark. Despite the war, Russian seafood continues to be traded globally. The US prohibited the import of seafood from the Russian Federation in March 2022, but indirect imports have continued. Many countries have not imposed restrictions, including important trading blocs like the EU – due to food security and affordability concerns. If the MSC ecolabel disappeared from products, it may cause short-term disruption for retailers who have made sustainability commitments, but the legal trade in Russian seafood would continue. What would be lost would be the incentives for Russian fisheries to maintain the environmental performance needed if we are to tackle the challenges facing fisheries and wider ocean health.

This is not to say that the operation of the MSC program in Russia has been unaffected by the war – it has. The MSC’s Board of Trustees decided in March 2022 that there will be no new activity in Russia, although existing certificates will be maintained subject to extra due diligence. All certified entities in Russia must demonstrate their compliance with international sanctions including any sanctions targeted at individuals linked to the Russian government. A 2022 review by the independent oversight body, ASI, confirmed that the independent assessment bodies (CABs) were able to uphold the requirements of the program. But of course, this is kept under constant review by the MSC, the assessment bodies, and ASI.

The variations that the Commissioner cites, (and which are publicly available on the MSC’s Track a Fishery website) are not an indication of special treatment to Russian certificate holders. Far from it. The applications for the time extensions have been assessed and granted in the same way as requests for all certified fisheries world-wide. Globally, the MSC regularly allows reasonable adjustments to assessment timelines without compromising environmental performance. We granted 180 in 2022. In fact, several Alaskan fisheries – including pollock, flatfish, cod, and salmon – have previously had similar variations (31) approved on the surveillance schedule, reporting deadlines, and certificate length. Every variation is assessed on its own merits. For example, the certification of the 10 Russian salmon fisheries that the Commissioner refers to had one on-site auditor, as well as additional remote auditors, to assure the assessment.

The Commissioner refers to labor practices in his letter. During Covid there were exceptional measures (derogations) applied globally which allowed for self-declarations for our forced and child labor requirements in place of audits, with the possibility of audits being triggered at a future date. As the effects of the Covid pandemic come to an end, all supply chain companies will need to comply in full with our requirements which include the possibility of in-person labor audits, where warranted.

Finally, the Commissioner rightly draws attention to the high standards of the Alaskan fishing industry. We are proud of the long-standing partnership between MSC and the Alaska fisheries. They were some of the first in the world to be certified to the MSC Fishery Standard, galvanizing the global sustainable seafood movement. Our collaboration stretches back decades, and we have the utmost respect for the industry’s leadership.

Read our full response to Alaska Department of Fish and Game Commissioner, Doug Vincent-Lang.