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To the European salmon industry,

Hereby, we present an urgent and significant proposal concerning the future of our industry. As salmon processors in Europe, we are facing a crucial challenge that affects us all, and it is high time we take collective action.

Norway categorizes salmon as Superior, Ordinary, and Production Grade salmon (also known as prod-fish). It allows Superior and Ordinary to be exported but prohibits the sale of prod-fish. Prod-fish must be processed domestically into fillets so that visual deformities can be removed and the quality image of Norwegian salmon is secured. The share of production fish, however, used to be less than 8% of the total harvested salmon volume in Norway, but in recent years this share rose to over 40% in some months, creating a disorderly and chaotic situation for both farmers and European processors. It is evident that we can no longer remain passive while this ban harms and threatens the very existence of our industry.

This export ban favors a couple of domestic Norwegian salmon processors, while leaving thousands of EU salmon buyers with lacking availability and extreme prices for superior and ordinary salmon.

Therefore, we wish to collectively address the European Commission, presenting the following arguments:

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Disinformation

The argument that Norwegian salmon would suffer reputational damage by allowing prod-fish into the open market is unfounded. Other salmon farming countries, such as the Faroe Islands, Scotland, and Ireland, have no or less stringent rules and still enjoy an excellent reputation, selling their salmon at premium prices compared to Norwegian salmon.

Fraud

The current situation encourages fraud, with prod-fish being illegally exported. This creates an uneven playing field and undermines our industry’s integrity. Both the authorities and the industry have completely lost grip on the situation, making it impossible to enforce law and order.

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Protectionism

The ban on the export of production-grade salmon results in unfair competition and amounts to illegal protection for Norwegian processors. This goes against the principles of free trade that the European market stands for.

Price instability and market inefficiency

The ban causes extreme high pricing for Superior and Ordinary fish and extreme low pricing for prod-fish, none of which reflect the real market price. Returns for both Norwegian farmers and EU processors are negatively impacted by this.

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Vague regulation

Although the authorities strictly forbid the export of production fish, they have given a 10-year dispensation to one single salmon harvesting company. This company uses a vessel to harvest salmon in Norwegian waters and then sails to the EU, where its complete harvest (including prod-fish) may be bought by EU processors.

As salmon processors in the EU, we request the export ban on prod-fish to be lifted, or at least to be given a dispensation for as long as the prod-fish share exceeds 8% of the total harvest volumes. We are committed to delivering high-quality products to our customers. We have established systems and procedures to correct any deviations and prevent damaged salmon from entering the market. Our options to correct and upgrade Production Grade Salmon into premium value-added products are limitless.

In addition to these arguments, we can also refer to case law supporting our position. The European Court of Justice has repeatedly made rulings emphasizing the importance of the free movement of goods and the need for fair competition within the internal market. The Norwegian ban on the export of production-grade salmon is in conflict with these principles and must be challenged based on European legislation.

We invite anyone who is negatively impacted by this export ban to participate in this important initiative. Let us unite our forces and protect our industry for future generations.

Sincerely,
EU Salmon Processors Union

ESP Union is an initiative supported by multiple salmon processors from all major EU based processing countries.