The Veterinary Regulation, Fisheries Conservation and Control Division within the Ministry for Resources and Rural Affairs, has never ‘cooked’ any figures and has nothing to conceal and does not play any role in any alleged international laundering racket.
ATRT’s accusations of the supply of incorrect information to the International Commission for the Conservation of Atlantic Tuna (ICCAT) and Euro Stat are unfounded. The VRFCC has always supplied the correct information to the European Commission that in turn, after consolidating it with that of other Member States, sends it to ICCAT. We insist, as stated in our previous reply published August 6, that in the 2007 season, we farmed 7,983,435 kgs of bluefin tuna of which 1,253,189 kgs were lost in a storm and of which 1,346,639 kgs were carried over to the 2008 fattening season.
The resultant 5,383,607 kgs of tuna inputted into the cages in 2007 yielded a maximum 6,729,509 kgs of bluefin tuna at harvest. Some of this tuna was harvested in the latter six months of 2007 and the rest was harvested in the early months of 2008. Most of these harvests were dispatched to Japan but the entry into Japan does not necessarily fall within the same timeframe as the harvest. This is in view of the fact that unless necessary for marketing, consignments are held in bond and released when and as necessary. These marketing and customs procedures add complications to any direct control of consignments. Each consignment has to be followed through its certification to origin and this is the only way that would show if discrepancies exist.
We reconfirm that around 11 million kilos of bluefin tuna caught in the 2007 season were sent to Japan from Malta and once again we reconfirm that this amount was however made up of tuna farmed in Malta (6,729,509 kgs), of tuna caught by Maltese longliners (143,700 kgs) and transshipments of bluefin tuna arriving from other Member States and third countries (4,433,282 kgs). We have never informed Japan, ICCAT or the EU Commission wrongly and all consignments to Japan or otherwise forming the above total gross weights were always declared in the correct manner and accompanied by the correct formal documentation. It is only ATRT and MaltaToday that are alleging, assuming and accusing otherwise. Their accusations are based on wrong assumptions and biased analysis.
The documents provided by the MaltaToday correspondent do not show anywhere that Malta exported 11 million kilos to Japan of Maltese farmed fish. This is an assumption and a gross miscalculation elaborated by ATRT and MaltaToday. It may be just a coincidence that the wrong calculation of round weights by these two correspondents add up to a figure similar to the total quantity of blue fin tuna of the 2007 season dispatched from Malta. Reality remains that although we dispatched in excess of 11 million kilos of round weight, this was made up from three different categories of bluefin tuna: caught by Maltese fishermen, fattened by Maltese tuna farmers and transshipped by various agents and brokers. Reality also remains that each of these consignments can be traced and followed from origin to destination.
In ICCAT circular 500/08, which is the Statistical Document Program carrying data for the second half of 2007 for imports into Japan, Malta figures only with statistical documents and re-export certificates. The statistical documents are for fish caught by Maltese or other Member States’ fishermen and the re-export certificates are for bluefin tuna that has been farmed in Malta but purchased under the quotas of other contracting parties to ICCAT that are Third Countries. MaltaToday sent the Department an extract of this document and an ATRT analysis applied to it on 12 August at 4.24pm. It is evident from this list that conversion factors were applied for each entry of different cuts of the fish. This is obviously a gross generic approach. This does not take into consideration the basic fact that the parts come from the same fish. When applying such a generic conversion across the board it will create a fictitious situation were the round weight is inflated.
As an example MLT F 35/07 covers a harvest of AJD carried out on 29 October 2007. The whole harvest rendered three bluefin tunas with a total round weight of 668.84 kgs. The entries in the certificate were: DR: 594 kgs and OT (belly meat): 27.5 kgs. This makes a total processed weight of 621.5 kgs. The Japanese in their listings show two different entries with the equivalent weights as per our certificate. The ATRT analysis applied conversion ratios of 1.126 and 1.80 to the different entries ending with an equivalent round weight of 668.92 kgs + 49.55 kgs which equals 718.47 kgs. The 49.55 extra kilos should not be added on since they originate from the same three fish.
During 2007, whenever we issued Statistical Documents and Re-export Certificates, we had to include the Additional Sheet which has got all the details of the harvest including the round weight from which the processed weight in the document has been extracted. The Commission itself and ICCAT had agreed on this procedure since the use of conversion factors applied generically was hugely exaggerating estimates of round weight. The documents appertaining to all these entries listed by Japan are available electronically giving free access for viewing.
The article once again enters into a full innuendo on Moroccan fish. ICCAT Circular 1316/07 that deals with the provisional catches of blue fin tuna for Morocco from January to July 2007 states that 2,440,596 kgs were caught by traps and 510,000 kgs were caught by purse-seiners in the Mediterranean. ICCAT Circular 129/08 which is the Bi-Annual Report Blue fin tuna Statistical Document Program – Croatia identifies 300 tons of the purse-seined fish mentioned in the prior circular as being transferred to Croatia. If we add to this the 210 tons that have been mentioned in our prior response as being transferred to a Maltese fish farm it adds up to their total declared purse-seine catch of 510 tons. The figures declared in the circulars are complimentary and tally perfectly with what we had declared earlier.
I can assure all concerned that the caging of the Blue fin tuna inputs for 2007 was completely declared to the European Commission before the 10th of July, when a draft compiled list was sent to the officers of the Commission. However we also hold the authorizations from all the Flag States concerned for each input of blue fin tuna into the cages. The Maltese government never concealed any information during co-ordination meetings as accused.
ATRTs claims are definitely not correct and VRFCC is not using trans-shipments to conceal a regular export of tuna. Each trans-shipment is dealt with separately and in the proper manner. It is processed only if we have a 72 hour pre-notification advice of its arrival and if all the necessary documents are presented. These must include original ICCAT statistical documents which are then endorsed after we confirm the weights of the trans-shipments. We hold copies of each of these certificates for all the fish that has passed through Malta.
The article makes another mistake when quoting that genuine Maltese re-export would be counted under Maltese ICCAT quota. This is probably a genuine mistake as Maltese re-exports are fish purchased by Maltese Tuna farmers under quotas of other contracting parties which are Third countries. The listings of Maltese re-exports sent to Japan is correct and has been checked on a one by one basis. We have never allowed any fish that was not caught by Maltese Flagged Vessels to appear under the Maltese quota as the article would make us believe. At any rate the Maltese total catch allocation for 2007 was a mere 355,590 kgs. This is just a drop in the ocean and can never suffice to cover the alleged extra 5 Million kilos. The Japanese import data in the statistical document list for July – December 2007 refer to bluefin tuna fished by Maltese fishermen with longlines in the 2007 season. The total gilled and gutted weights of product received by Japan amounts to 100,811 kgs. This would render a total round weight equivalent of 116,940.8 kgs. In FIDES, the reporting front for the European Commision we reported 143,700 kilos of round weight equivalent. The difference represents the amount of bluefin tuna sold in Malta during the 2007 fishing season. The landings of Maltese fishermen were regularly reported to the Commission both through FIDES and also through the ten days catch reports.
A further 190 tons were caught by purse-seiners flying the Maltese flag. This means that the total take up for the 2007 season was 333.7 tons out of the 355.59 tons allocated. The statistical documents for fish farmed in Malta accountable to quotas of other European Member States has been checked and traced to origin and all the re-exported figures are exactly as we declared them. The same has been done with the list of proper re-exports. The Japanese trade statistics for January – June 2008 are only supplied as a round figure of 3,670 tons but these cannot be traced to origin as the entries per certificate have not been provided yet. I can however safely state in advance that out of the 3670 tons mentioned in the Japanese trade statistics not more than 1200 tons can be fish that has been farmed in Malta in the 2007 season and harvested in 2007.
We will be in a position to absolutely confirm this total amount when the entries by certificate are provided.
Dr Anthony Gruppetta
Director of Fisheries
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