Call for evidence outcome

Summary of responses: call for evidence on the scale and impacts of the import and export of shark fins

Updated 15 August 2021

1. Foreword

The UK has a strong track record in marine conservation and places great importance on ensuring that appropriate protection and management is in place for all shark species. Following the end of the transition period.

We have begun to explore further options consistent with World Trade Organisation (WTO) rules to address the trade of shark fins. In relation to this, we opened a call for evidence in December 2020 to help us better understand the trade of shark fins and its impacts both in the UK and overseas. This document provides a summary of responses to this Call for Evidence.

2. Introduction

The purpose of the call for evidence was to seek advice on four key areas:

• the scale of shark fin trade in the UK
• conservation impacts of shark fin trade in the UK
• economic, social, and cultural impacts of further restrictions on shark fin trade in the UK
• international issues

The call for evidence ran for 4 weeks, from 6 December 2020 to 4 January 2021.

3. Number of responses

In total, the call for evidence received 21 responses. These consisted of:

• 13 representatives of Environmental non-governmental organizations (eNGOs) and other conservation organisations
• 6 individuals
• 2 representatives from academia

None of the respondents wished for their responses to be kept confidential.

4. Headline messages

Some useful evidence was provided in response to this Call for Evidence. The majority of respondents were clearly supportive of stricter controls on trade in shark fins, with no respondents being opposed to them.

4.1 Conservation impacts

Most respondents notably welcomed increased efforts for shark conservation and emphasised strong opposition to shark finning and the trade of detached shark fins.

A number of respondents felt that additional restrictions on the shark fin trade would have positive effects on the conservation of sharks, with some respondents commenting on the UK becoming a global leader and setting a positive example on shark fin trade that could influence other key players, such as the EU.

Several respondents correlated higher value shark fins from species with poorer ecological status, with some respondents noting insufficient checks at the UK border on what species were being imported as a contributing factor to declining shark populations.

Many respondents expressed the need for shark conservation efforts to go further than just tighter restrictions on trade, emphasising the importance of needing to stop the unsustainable commercial exploitation of sharks.

4.2 Business impacts

Many respondents believed that stricter controls on shark fin trade would have minimal or low impact on businesses, and consumers, and individuals and would not impact jobs and livelihoods of fishers in the UK.

There were some references to various businesses that may experience some impacts from stricter controls, with some specific mention of Chinese restaurants.

Some respondents provided evidence on the impact that shark fin trade has on supporting local livelihoods in other countries, with general agreement among respondents that ensuring sharks are caught sustainably will support marine ecosystems and livelihoods in the long-term.

5. Responses by question

5.1 Scale of shark fin trade in the UK

Q5. Please provide any evidence you have of the amount and value of shark fins entering and leaving the UK, including through the personal import allowance, and which shark species these are derived from.

Imports

Respondents referenced data from HMRC and the TRAFFIC (2019) report as reliable sources of data for shark trade.

The latter report identifies the UK as an importer of more than 300 tonnes of shark fins between 2013 and 2017 based on the trade flows from the UN Comtrade database.

However, some respondents also provided information that suggested the extent of shark fin trade in the UK after 2017 was minimal and not in all cases commercial.

Exports

Again, respondents referenced data provided by HMRC and alternative sources, for example, they stated that an estimated 25 tonnes of shark fins are exported from the UK each year.

An eNGO-based respondent highlighted a 2019 report analysing HMRC data which demonstrates that up to 50 tonnes of shark fins have been exported from the UK between 2016 and 2018, mostly to Spain, from where they are believed to be exported to key market countries in Asia.

However, respondents from another eNGO indicated that the UK was not a major player in the global market for shark fins. They drew attention to Food and Agriculture Organisation (FAO) analysis which states that the UK does not feature in the top 20 of global nations exporting or importing shark fins, instead arguing that Hong Kong, Singapore and mainland China are the major 'hubs' for shark fin trading.

Personal allowance

A respondent from an eNGO stated that the personal import allowance is exempt from border control declaration. They also stated that as such there are no records of the amount in weight, value of, or species of fins transported via this means. .

Overall, respondents from all categories were consistent in their view that the ability to import 20kg of dried shark fins into the UK for personal consumption was excessive.

According to a representative of an eNGO, depending on the size of the sharks or fins, 20kg of shark fin can equate to around 500 individual fins, from up to 60 sharks. Another respondent from an eNGO mentioned that 20kg of shark fins can be sufficient to produce in excess of 700 bowls of shark fin soup.

Respondents reflected the idea that more rigorous border checks are needed at customs on the personal import allowance in its current state.

Value and amount

A single respondent from an eNGO provided information about the value of shark fins themselves and the value of the current trade of shark fins.

The respondent mentioned that according to National Geographic a single pound of dried shark fin can sell for $400, whilst the Smithsonian reported that shark fins were worth an estimated $500 a pound (around $1,100 a kilogram). Respondents did not provide information on which markets these prices are found at.

Landings

A respondent from an eNGO highlighted that, according to the report of the Scientific, Technical and Economic Committee for Fisheries (STECF) the UK has reported between 2,000 tonnes and 3,000 tonnes of 'marketable fin' shark species landings per year between 2015 and 2018 with 12,000 tonnes and 14,000 tonnes landings per year reported by the UK under the Finning Regulation.

Thereby the UK ranked number four with regard to shark landings within EU coastal states, after Spain, Portugal, and France.

Ecology

Respondents from academia reflected the difficulty in identifying species (and thus endangered species) from dried shark fins. It was made clear that it is very difficult to ascertain which shark species dried fins are derived from without accurate DNA testing, which was described as time consuming and expensive.

Therefore, UK imports and exports of species of shark not currently listed on the CITES Appendices and the EU Wildlife Trade Regulation Annexes are harder to estimate, since there is no associated permit requirement.

A respondent representing an eNGO listed important species identified in the UK trade as being Carcharhinus leucas (bull shark), Sphyrna lewini (scalloped hammerhead), Isurus oxyrinchus (shortfin mako) and Sphyrna tudes (smalleye hammerhead), with the remaining fins assigned to the Carcharhinus genus (requiem sharks). Both I.oxyrinchus and S.tudes are listed as threatened. However, most significant is S.lewini which is endangered and was added to appendix II of CITES.

Q6: Please provide any evidence you have to assist our understanding of the number and size of companies and the number of jobs, and in which sectors, supported by the movement of shark fins between the UK and other countries.

Respondents were largely unable to provide evidence on the economic impacts relating to value loss that would result from a ban on the trade of detached shark fins. Most respondents generally believed that the impact that a ban on the trade of detached shark fins would have on jobs and livelihoods would be minimal.

Some did mention that business in countries that accept our import of detached shark fins, such as Spain, would be affected by the policy.

Respondents added that jobs and businesses do not depend on shark fin products to any substantial extent, simply as there are no companies or jobs existing that specialise on business with shark fin or shark fin products other than if ' participating in the illegal harvesting and trading of fins'.

Respondents noted that wholesalers and processors in the UK are the ones achieving the biggest profit in the fin trade as the unit value of imported unprocessed frozen or dried shark fin is much lower than that of re-exported processed fin.

Respondents overwhelmingly viewed the impact on UK business of a ban on the trade for detached shark fins as being small, with some reference to airlines, restaurants and hotels having already banned shark fin products. It was generally noted that the number of businesses and jobs in the UK being supported by the movement of shark fins is extremely low.

One representative of an eNGO made the link between the consumption of shark fins in the UK and the Chinese community. They were of the opinion that Chinese restaurants and grocery stores selling shark fins in some form would be affected by a ban.

However, it was suggested that this would be marginal, as no such businesses are dependent on shark fins. This was not, however, backed up by any quantitative evidence.

Some respondents emphasised the thin margins on shark fin soup within retail/hospitality. One respondent used the case of a manager in a restaurant in Hong Kong, who claimed that due to the low margins on shark fin soup, the restaurant would prefer not to offer the dish and therefore only did so on occasions that elderly customers would request it.

A number of respondents highlighted the positive impacts a ban on trade would have, particularly where substantial illegal trade continues to exist in South East Asia. They noted that a ban on trade would help to ensure the UK was not involved with these illegal and unsustainable activities.

5.2 Conservation impacts of shark fin trade

Q7: Please provide any evidence you have on the impacts on species conservation of the import and export of shark fins to and from the UK.

Respondents providing information and opinions on conservation were mostly representatives of eNGOs. Responses were mostly anecdotal, with many responses emphasising the ecological value of living sharks rather than dead ones.

Respondents outlined the difficulties that exist in the current border enforcement system, especially regarding the challenges in identifying shark species from their dried fins.

Given the lack of import or export permit requirements for many species and the 20kg personal allowance, respondents believed that it is difficult to accurately estimate the impact that the UK's involvement in trade might have on the conservation of particular shark species.

Respondents also highlighted that regulation would not only protect sharks but promote the UK as a global leader on the issue, especially where we are early to join a growing list of countries who have also banned the trade of detached shark fins, such as Canada.

Overall, there was general agreement that any advance on ending shark fin trade in the UK would have a positive impact on the conservation of sharks.

Respondents noted that tighter import standards, with the addition of clear provenance and traceability, and evidence of sustainable management would reduce the likelihood of fins being traded from unsustainable illegal, unreported, and unregulated fishing (IUU) sources.

Respondents reflected on unsustainable practices and their relationship to the global shark fin trade with great detail, 5 respondents referred to this topic specifically, with the majority of them representing eNGOs.

Q8: Are there greater conservation impacts from the import and export of shark fins to and from the UK on some species that others?

Respondents highlighted the difficulties of determining impacts on a species-by-species basis. Since the level of imports and exports of shark fins from different species is not well documented or understood, it is difficult to make judgements on the species-specific impacts that UK imports or exports might have.

It was also noted that HMRC currently does not ask for species information for shark fins exported or imported.

It was also suggested that regulations for individual species would be ineffective. If the ban is adhered to then trade from one species would likely shift to another species and would therefore be insufficient in protecting sharks.

Additionally, the regulations and infrastructure needed to monitor a ban on a particular species are not in place, therefore, a ban would only be effective if all shark (and ray) fins are banned.

Respondents stated that commercial interests in profits from fins and meat are often the main drivers for shortcomings in the conservation of sharks in Regional Fisheries Management Organisations (RFMOs).

The species that are the most sought after and most expensive are also the ones often most endangered and in need of the strongest protection.

Respondents in eNGOs made the link between shark fin trade and the decline in shark populations, leaving their ecological status in doubt. Respondents made mention of the fact that the sharks most at risk of exploitation were those whose fins were considered the most valuable.

Shortfin mako sharks were described by respondents as being a species in high demand for its fins, namely due to its value. Species like tope are also fished and traded for their fins, however, their fins carry less value.

The blue shark (which can be found in UK waters) is the main species of shark found in the Hong Kong trade, and is the main landed species in weight and value in Spain.

5.3 Economic, social, and cultural impacts of further restrictions on shark fin trade in the UK

Q9: How would stricter controls on the import and export of shark fins affect businesses (for example, importing and exporting companies, fishing industry)?

Nine responses stated that stricter controls on the import and export of shark fins was likely to have little to no impact on legitimate business ventures, at least not to any extent they could not recover from.

It was indicated that there are no legitimate businesses that are totally dependent on the shark fin trade, and so stricter controls should not have particularly adverse impacts, either on the fishing industry, importing and exporting companies, or UK Chinese restaurants and grocery importers.

Some respondents said that there could be impacts on smaller businesses that have the fin trade as a core part of their focus (although no specific businesses were provided), but this would not significantly impact the UK financially.

The impacts on businesses that respondents noted mainly concerned industries having to change their practices to align with stricter controls.

Asian restaurants that still serve shark fin dishes, industries that use squalene (an oil found in shark livers), trading companies engaged in the import and export of shark fin, and the fishing industry, which would have to adopt more sustainable practices.

Respondents also made note of the importance of sharks to the marine ecosystem given their position as apex predators and their importance in maintaining ocean health and noted the associated benefits stricter controls would bring.

It was also suggested that ecological benefits would also boost tourism and the fishing industry through their role in the food chain.

Question 10: Please provide any evidence you have on what shark fins are used for in the UK and what the impact of stricter controls on the import and export of shark fins would be on consumers and individuals?

An eNGO noted that shark fins are mostly used in Asian restaurants, in shark fin soup and dumplings. Based on research their organisation had carried out, they identified that there are 14 restaurants in the UK that currently serve shark fin soup, which accounts for 0.68% of UK Chinese restaurants (of which there are a total of 2,074) ^{[footnote 1] [footnote 2]} . Shark fins are also sold in Asian supermarkets which stock ingredients for Chinese cuisine across the UK.

Along with this, shark cartilage – of which fins are comprised – has been reported as an alternative cancer therapy, but according to one conservationist respondent, there is no scientific research or evidence to support this treatment. Supplements containing shark cartilage are available over the counter in food health shops.^{[footnote 3]}

In terms of economic impacts, respondents suggested that stricter controls on shark fin trade would have limited or no significant impact on consumers and individuals, given that the UK is not a major global market destination for shark fins.

However, impacts on the restaurant and Asian grocery store industry were noted, but respondents also noted that without possession of shark fins being completely illegal, there would still be a supply of shark fins to these vendors.

One respondent also noted that stricter controls should ensure fin products that are available in the UK would be of known provenance from sustainably managed fisheries that apply best practice.

Respondents noted that in terms of social and cultural impacts, shark fin use is centred around the Chinese community and their traditional cuisine, therefore any effect here must be considered.

Given that shark fin soup is considered a luxury dish, it was proposed that the Chinese community would not be largely affected by stricter controls on a day-to-day basis.

Furthermore, 2 respondents mentioned a growing movement away from shark fin products especially amongst younger Chinese people.

Q11: Please provide any evidence of the impact that import and export of shark fins to and from the UK has on supporting local livelihoods in other countries.

An individual commented on the potential drop in tourism revenue that could be seen if sharks were to be extinct in certain waters. Another respondent from an eNGO went into more detail and pointed out that the value of the ecotourism industry that sharks provide is likely to exceed the value of total sharks landed within the next 20 years.

Using Indonesia as an example, it was also highlighted that 7% of their $1billion tourism industry is generated by shark tourists, which could lose around 25% of shark tourism expenditure in the absence of sharks^{[footnote 4]}.

Shark-diving tourism is increasingly popular and can be seen as a way to draw income from sharks without killing or consuming them.

Several respondents have spoken about the UK's position against finning as being an important step towards showing 'leadership' against the fin trade worldwide.

They stated that the UK's strong international stance, backed up by robust domestic fin trade policy can demonstrate shark conservation leadership and drive fundamental change globally. It is believed that this may lead to other similar policies being implemented across the globe, and notably in the EU, if the UK were to take a firm stance against the trade in shark fins.

Respondents generally commented on the fact that a ban on fin trade would be a step towards supporting livelihoods in the developing world and in other countries which are dependent on healthy marine ecosystems for their fishing and export of seafood products.

In relation to the 'global leadership' that the UK could show through policy implementation, if other countries were to implement similar regulations subsequently, they would be able to do so in a way that suits them and protects those who rely on sharks for food security or livelihoods.

Q12: We are interested in finding out more about other countries' restrictions on the import or export of shark fins. Please provide any information and/or evidence that you are aware of on this.

All respondents that answered this question gave examples of where they knew current restrictions existed, and altogether provided a good range of information on current laws and regulations worldwide. Canada was the most frequently commented on, with half of the respondents making reference to Canada's recent ban on the trade of shark fins.

One respondent noted that Canada's ban on shark fins not attached to a carcass makes it much easier to identify shark species that are traded. Identification of species with the fins alone can be a challenging task without the right professionals, so having the whole carcass present makes it easy to monitor, report and record the types of sharks that are being traded.

Respondents noted that several US states have taken a similar approach to Canada and banned the movement of shark fins, as well as sale and possession. The ban on the movement of shark fins within the US started with Hawaii in 2010^{[footnote 5]}, with 13 other states following their lead. Florida, the main hub of shark fin trade for the US, banned the sale, import and export of shark fins in September 2020.

Respondents also noted that in the past decade, many other countries have adopted policies such as Fins Naturally Attached (FNA) for shark landings to try and reduce the practice of shark finning. They referred to countries such as Ecuador, Egypt, Honduras, and many others that have imposed bans on shark fishing for many years.

One respondent provided an extensive list of companies, such as Amazon, the Fairmont Hotels Group, Carrefour, and many others have banned shark fin soup.

They stated that Thailand has one of the most extensive lists of companies that have banned shark fin soup, with 111 hotels, 4 supermarkets and 9 restaurants involved in the restriction under Thailand's 'Fin Free Thailand' program.

The respondent also said that most major airlines have banned the transportation of shark fins, including Virgin Atlantic, Emirates, British Airways and Qatar Airways to name a few, with many major shipping companies also following this trend (Maersk, MSC, Evergreen Shipping Line).

5.4 Current problems with regulations

Under current EU FNA policy, one respondent mentioned that ' batoids are exempt from the policy which allows the removal of ray wings at sea without providing a clear definition of ray'. As such, it could provide a loophole for finning of 'Rhinopristiformes', which could include some of the most endangered but highly valuable species in the fin trades. EU regulations have the same loopholes as the UK.

The respondent noted that there are also several exemptions under existing FNA policies allowing fin-to-carcass ratios for some commercially valuable species, such as spiny dogfish in the US.

The respondent also stated due to varying levels of monitoring and surveillance where this is method is used, it is difficult to know levels of compliance. In some countries, loopholes for compliance existed as there was no clear definition of 'shark' in a number of nations (for example, Japan, India, Taiwan).

Respondents suggested that enforcement within the EU is extremely low for ensuring compliance with FNA regulations. Between 2013 to 2017 Spain only inspected 2% of shark landings, whilst France in 2018 inspected 799 landings of sharks out of 137,000. Respondents also suggested that the regulation for EU vessels outside of the EU is also likely to be very poor, with almost no information existing for compliance.

Overall, regulations for banning shark finning at sea are very inconsistent and different in various regions and jurisdictions, with a range of loopholes being pointed out by some respondents and poor monitoring surprisingly common.

Q13: Please provide any evidence on the effect additional restrictions on the trade in shark fins could have in the context of global shark conservation efforts?

Four of the respondents spoke about the UK becoming a 'global leader' against the trade of shark fins. It was noted that a fin trade ban would send a clear message to the international community, and the UK could be the first country in Europe to implement a ban on the trade of shark fins.

Respondents stated that the EU is the world's largest shark catching region and there was general agreement amongst respondents that if the UK were to take action against the trade in shark fins, that other countries would implement similar protective measures for sharks.

One of the respondents from an eNGO opposed the view that a ban on fin trade would be entirely positive on shark conservation efforts and emphasised that the trade in shark meat is a growing market, whilst the fin trade shows a declining trend.

It was suggested that a ban on fin trade may not curtail the demand for sharks, and that a 'wider package of actions' would be needed to ensure appropriate conservation management.

Respondents said that Canada, the United Arab Emirates (UAE), and India all currently ban shark fin imports and exports. The UAE was one of the first countries worldwide to implement a complete ban on the imports and exports of all shark products (in 2014).

Two respondents noted that the UK could influence EU countries in the same way that those countries have prompted the UK to consider the issue in more detail.

5.5 Further evidence

Q14:please provide any other relevant evidence you would like to include in considerations for imposing stricter controls on shark fin trade in the UK.

Respondents tended to use the further evidence section as an opportunity to express moral or emotive judgements more than the other sections. Respondents conveyed the view that it is our 'responsibility' to protect shark species and their environment, noting that 'the moral question is stronger than any 'fact'.

The act of shark finning (which the UK does not permit) was described as 'indefensible.' Respondents mentioned that there was little that differentiated finning a live shark or a shark that has been landed, as both acts contribute to a global trade in detached fins.

Sharks were described by respondents as ecologically vulnerable due to their slow maturation and reproductive rates. Additionally, as apex predators, their existence was noted by respondents as necessary in maintaining the balance of marine ecosystems.

Some respondents noted continued unsustainable commercial exploitation of sharks is resulting in the serious decline and, in some cases, collapse of shark populations.

This was noted by respondents as having calamitous consequences for marine ecosystems such as the breakdown of marine food chains ^{[footnote 6]} , and knock-on impacts for climate change.

In relation to potential impacts of a ban on the trade of detached shark fins on businesses, incomes and livelihoods, representatives of 2 eNGOs highlighted work led by Bite-Back Shark & Marine Conservation.

6. List of organisations that responded

• Angling Trades Association Ltd
• Saltwater Life
• Born Free Foundation
• Shark Guardian
• Bite-Back Shark & Marine Conservation
• One Voice for Animals UK
• Sharkproject International
• Wildlife Conservation Society
• WildAid.com
• On the Hook campaign
• Blue Marine Foundation
• Shark Trust
• Humane Society International (HSI)
• International Fund for Animal Welfare (IFAW)
• The Bloom Association, Hong Kong

7. Next steps

The UK government continues to place the utmost importance on the appropriate protection and management of all shark species.

The evidence provided in response to this Call for Evidence has been used to develop a policy measure that seeks to ban all fins that are not naturally attached to the shark carcass from being imported to and exported from the UK, subject to specific scientific and training exceptions.

This ban will apply to detached fins brought into the UK commercially or under the personal import allowance.

Through this, our aim is to deliver effective shark conservation benefits globally, as well as demonstrate leadership in shark conservation issues and signal our strong opposition to any ongoing finning practices.

1. Bite back ↩

2. CGA and AlixPartners report (2019) ↩

3. Shark Cartilage Supplements Put to the Test to Cure Cancer ↩

4. The Economic Value of Shark and Ray Tourism in Indonesia and Its Role in Delivering Conservation Outcomes ↩

5. https://www.capitol.hawaii.gov/session2010/bills/SB2169CD1.htm) ↩

6. Bournemouth University research on how sharks can help prevent climate change ↩