EU Faces Dilemma Over Further Sanctions On Russian Fish Imports

Russian imports of fish into the European Union have largely continued despite sanctions following the country’s invasion of Ukraine in 2022. Apart from crustaceans, caviar, and caviar substitutes—which were banned as part of the fifth package of economic and individual sanctions in April 2022—fish, including cod and Alaska pollock, remain unaffected.

It has been suggested that the EU is considering extending sanctions to include Russian fish, nearly two-and-a-half years after the first sanctions were implemented. The main issue with this potential ban is that some EU member states, particularly Germany, are heavily reliant on Russian fish imports, especially Alaska pollock, as initially reported by The Fishing Daily on 23 April 2022.

Alaska pollock, which is classified as a member of the Gadus family (Alaska pollock – Gadus chalcogrammus and Cod – Gadus morhua), is commonly used in fast-food outlets as a substitute for cod. Reports indicate that 85 percent of Alaska pollock consumed in Germany is sourced from Russia. This presents a significant challenge for Germany. Stefan Meyer, the Managing Director of the Federal Association of the German Fishing Industry and Fish Wholesalers, stated, “If supplies from Russian pollock fishing in Alaska were to stop completely due to sanctions, there would be no replacement for them at the moment.”

Germany became heavily reliant on Russian gas imports during Angela Merkel’s tenure as Chancellor, and after Russia’s initial invasion of Ukraine and annexation of Crimea, Germany found it difficult to reduce its dependence on Russian gas, only taking substantial action after Russia’s second attack on Ukraine’s sovereignty. Similarly, Germany is reported to have only six deep-sea trawlers and does not engage in deep-sea fishing, further highlighting its reliance on imported fish.

This over-reliance on imported fish has become institutionalised across the EU, with the Commission seemingly willing to reduce the capacity of national fishing fleets to facilitate more cheap imported fish, allowing for greater profit margins on resale.

Across the Atlantic, the United States imposed a ban on fresh fish imports from Russia in April 2022, though Russian-caught produce continued to enter the market via China. On 22 December 2023, US President Joe Biden signed an executive order expanding the US ban on Russian seafood to include imports of Russia-originated seafood processed in third countries, including China. The US is the second-largest importer of Alaska pollock into the EU, which could exacerbate issues for EU fish processors if the Commission decides to impose further sanctions on Russian seafood imports.

Although Russian vessels are prohibited from landing in EU member state ports, this has not significantly reduced the amount of Russian fish entering EU markets via Norway and other routes. The Fishing Daily contacted the EU Commission to clarify the current situation regarding Russian-caught fish entering the EU and what a potential ban might entail if it comes to fruition.

In response to the potential inclusion of a fish import ban in the EU’s new sanctions package against Russia, an EU Commission spokesperson provided clarification on several key points regarding the current and future status of Russian-sourced fish imports into the EU market.

1. Current Status of Imports: It remains legal to import Russian-originating fish into the EU, with the exception of certain crustaceans, caviar, and caviar substitutes, which have been banned under previous sanctions. Other fish products from Russia continue to be subject to standard customs tariffs.
2. Future Sanctions: The spokesperson emphasised that any future sanctions, including a possible ban on Russian fish imports, would be decided by the EU Council and would require unanimous approval from all Member States. The timing and specifics of such measures are still under review.
3. Imports via Norway and the Faroe Islands: The EU has measures in place to ensure that Russian-caught fish entering the EU via Norway or the Faroe Islands is treated as Russian fish and subjected to existing restrictions. Customs controls are applied to ensure compliance, and only goods originating from these countries can benefit from preferential tariffs under bilateral agreements with the EU.
4. Fisheries Agreements and Dutch Investments: The spokesperson noted that there are currently no restrictions on the export of fishmeal or other fish products from the EU to Russia. Additionally, EU sanctions policy does not currently address third-country activities related to food processing, such as those by Dutch companies in the Faroe Islands.
5. Dependence on Russian Fish: Germany and other EU countries that rely heavily on imports of Russian fish, such as Alaska pollock, will continue to operate under the existing legal framework. The possibility of higher tariffs or other compensatory measures, such as increasing quotas for national fleets, remains under continuous assessment but was not commented on in detail.

The spokesperson’s responses underscore the complexities of managing trade relations amidst ongoing geopolitical tensions and highlight the careful consideration required for any changes to EU sanctions policy.