Why did MarineFauna not seek recertification with MAC?
Some visitors of the MAC website may have noticed that MarineFauna (MF) is not listed as certified exporter since August 2005. MF was approached by MAC for recertification but we feel that in the current situation MAC has to work out substantial aspects of its program in order to raise the certification status to an attractive level. In the following we share a short summary of the reasons why the management of MF decided not to seek recertification at this point of time:
MAC certified fish supply is limited to the following species: Mandarin, Banded sharks and their eggs, Tomato, Maroon, Percula, Chelmon and every two to three months a single blue face angel. According to our export data, the amount of MAC certified fish is by number 2 to 4 % of our total animal sale, despite the fact that we try to satisfy our orders with exclusively MAC certified fish.
We were promised by MAC that the situation will change in favor of higher and more diverse supply by the middle of 2004 which did not.
Currently, we can't comply with the minimum traceability requirement of MAC to identify any supplied MAC certified fish by an individual collector. So far we received from our supplier in Batasan only the number of individuals of a single species, the different collectors' IDs and the entire batch together in a bag (Mandarin), or in individual plastic bags (Chelmon) but without individual identification number of the respective collector.
We do not feel that the individual collectors' identity must be with each fish. We consider it as sufficient enough, to be able to trace any batch of fishes back to a group of collectors at a definite to trace back any problems through the entire chain of custody. However, it's a core requirement and we can't be certified unless this is changed (core requirements have to be met for certification according to the MAC Standards). It is surprising to us that Batasan passed recertification without satisfying this minimum traceability requirement.
Our DOA and DAA reports from importers as well as our own DOA and DAA in the facility reduce the number of MAC certified fish saleable as such to 0.2 to 0.4% of our entire animal sales because of exceeding the cumulative and added DOA mortality allowance for MAC certified fish. Unfortunately, the availability of data from other certified exporters have not been accessible yet, despite several announcements by MAC in the past, so we can't compare our actual standing regarding DOA and DAA with other exporters.
MAC does not differentiate DOA and DAA between species that ship easily (e.g. Mandarin) and species that ship usually with higher DOA (e.g. Wrasses).
The feedback of certified importers does not allow us to record data as required. Feedback is sometimes a single sentence such as "good shipment" or "very few DOA only".
We have experienced, that the transport starting from the moment the shipment is turned over to the cargo section of the airline until such time that the client receives the cargo from the customs in the importing country, must have a major impact on the DOA and DAA of the shipment. We had shipments ranging from 0 DOA up to 40% DOA. The suppliers and our handling and packing standards have been both the same for extremely different shipments. This fact is not considered in the MAC mortality allowance.
In the past we have been asked frequently about the sustainability in the trade mandated by MAC. So far we couldn't answer the questions and we believe that MAC needs urgently to come up with data to prove sustainability of the collection areas. So far all fish ordered will be caught.
In the certification assessment the exporter is asked about how he is ensuring that the MAC label packs are not used by unauthorized users. This is ridiculous because the MAC label packs have been promised for 2 years now, but were never received.
The paper work required for documentation is far too much and we feel it's overdone, particularly considering the lacking availability of MAC certified fish. We strongly propose to trim down the documentation to minimum core documentation and probably a very limited set of docs. Documentation of staff training records, equipment maintenance plans, calibration of measuring devices etc. is in the foremost interest of the exporter and shouldn't need MAC control.
Communication of MAC with certified exporters is unsatisfactory. No direct written information is provided to certified parties about new certifications (except biannual webpage corrections), updates, events etc. The newsletter from the email MAC subscription is more for public information and can't replace the direct communication with certified parties. For instance, MarineFauna learned from the webpage of MAC that it is not listed under the certified exporters anymore.
The number of MAC certified importers is far below the predicted goals of MAC. Feedback from companies who turned down the certification can be grouped into the following criticism: impractical documentation, MAC fish is not healthier than other fish from good exporters, DOA and DAA values are arbitrary figures without scientific basis, few MAC fish available only, expensive certification and no visible market advantage with MAC fish.
Despite the issues above we are still supportive of the initial MAC certification program. Currently, there is a striking mismatch between the required commitment to the MAC certification and the actual advantages of MAC. MF management has decided to wait with the application for recertification until the issues mentioned above are solved.