EU imports of fishmeal and fish oil from Senegal, Mauritania, and Gambia
Dear Health and Food Safety,
Under the right of access to documents in the EU treaties, as developed in Regulation 1049/2001, I write to request documents in the TRACES NT system regarding the import of fish products originating in particular countries.
In particular, I would be grateful to receive documents on imports into the EU of (i) fishmeal or (ii) fish oils originating in Gambia, Mauritania, or Senegal (regardless of whether they have arrived in the EU via a third country) during 2022, 2023, and 2024.
I would be grateful if the data could be disaggregated to show, for each shipment:
- the date of the shipment
- the name or description of the product imported
- the quantity of the product imported
- the value of the product imported
- the name of the importer
- the name of the original exporter
- the country of the original exporter (Gambia, Mauritania, Senegal)
- the name and country of any intermediary supplier in the shipment
I would like to receive this information electronically.
Should my request be denied wholly or partially, please explain the denial or all deletions referring to specific exemptions in the regulation. Also I would expect the partial release of documents in case of partial exemption according to article 4.6. I reserve the right to appeal.
My address is:
DeSmog UK
5 Brayford Square
London, E1 0SG
Please confirm having received this application. I look forward to your reply within 15 business days, according to the regulation.
With thanks,
Brigitte
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 08/08/2024 and registered on 08/08/2024 under the case number
2024/4200.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 30/08/2024. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Health and Food Safety - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear Ms Wear,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2024/4200.
Kind regards,
European Commission
Directorate-General for Health and Food Safety
Unit G-4: Official Controls
Dear Health and Food Safety,
Dear Directorate General for Health and Food Safety,
Thank you very much for your reply. Please see below clarifications to your questions:
- The CN (HS) codes I am interested in are 1504 for fish oil and 2301 for fishmeal.
- I would like to receive the importer. Please provide the name of the buyer (company) where this is available.
- What I mean by the “original exporter” is the company or person who exported the product.
- I would also like the exporter country.
- What I mean by “intermediary supplier in the shipment” is the company or person who may have acted as an intermediary trader of the product between the exporter and the importer. For example, if a shipment went from Senegal to a country in Europe via Spain, the intermediary supplier in the shipment would be the company in Spain, if this information is recorded in TRACES.
Please let me know if you have any further questions.
Thank you very much,
Brigitte Wear
Dear Health and Food Safety,
Please could you confirm receipt of my clarifications and let me know when I can expect to receive the full response?
Thank you!
Brigitte Wear
Dear Ms Wear,
Thank you very much for your email and for replying to our clarification request, which we safely received.
The unit in charge of the file is currently working on your request. They are aiming in sending a reply by the first deadline of 9 September 2024, but consultations are required. If an extension will be necessary due to these consultations with external parties, the new deadline to send you the requested documents will be 30 September 2024.
Please let us know if you have any additional questions and thank you again for your request and further clarification.
With kind regards,
SANTE ACCESS TO DOCUMENTS
Dear Ms Wear
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2024/4200.
Kind regards,
European Commission
Directorate-General for Health and Food Safety
Unit G-4: Official controls
Dear Ms Wear,
Thank you for your request for access to documents with reference EASE
2024/4200.
We acknowledge that the time limit expires today, 30 September 2024, and
apologise for the delay. The assessment and consultation of the
documents/data falling within the scope of your request required more time
than foreseen.
We would like to inform you that your request is being handled and the
data have been identified, assessed and the reply prepared and will be
sent to you as soon possible.
Please be reassured that we are doing our utmost to provide you with the
required documents as soon as possible.
Thank you very much for your understanding.
Best regards,
G4 Official controls
European Commission
Directorate General for Health and Food Safety (DG SANTE)
Directorate G- Crisis preparedness in food, animals and plants
Unit G4: Official controls
Dear DG SANTE,
Thanks for your email. Please could you let me know if there is any update on this request?
Yours sincerely,
Brigitte
Dear Ms Wear,
We acknowledge that the time limit expired on 30 September 2024, and
apologise for the delay.
We would like to inform you that the reply to your request is in the
workflow and will be sent to you as soon as it is signed at the
appropriate level.
Please be reassured again that we are doing our utmost to provide you with
the required documents as soon as possible.
Thank you very much for your understanding.
Best regards,
G4 Official controls
European Commission
Directorate General for Health and Food Safety (DG SANTE)
Directorate G- Crisis preparedness in food, animals and plants
Unit G4: Official controls
Dear Ms Wear,
Please find attached a message concerning your request for access to
Commission documents registered under the above case number 2024/4200.
Please acknowledge the receipt of this message by return email.
Kind regards,
SANTE ACCESS TO DOCUMENTS
Dear DG Sante,
Thank you for your response. I would like to request an internal review of the decision to redact the following information:
The consignee/importers
The consignor/exporters
The establishment of origin
I believe there is an overriding public interest in disclosing the redacted data of the requested documents.
The fishmeal and fish oil (FMFO) industry in West Africa is driving the depletion of already overfished and declining fish stocks of small pelagic fish – mainly round and flat sardinella, and bonga. [1,2] As a result, the FAO found that the industry in the region is threatening food security and livelihoods. [3] Multiple reports by campaign groups and non-profit organisations have also found human rights abuses and ecological harms linked to this industry. [4, 5, 6, 7]
Small pelagic fish used by the FMFO industry provide vital and often irreplaceable sources of micronutrients (calcium, selenium, iron) and are especially important in the diets of pregnant women and infants in their first 1000 days of life. The fish can be prescribed by doctors for malnourished children, but their price has increased substantially in the past 10 years, causing this essential food to be out of reach for local people. [8, 9, 10] This is largely driven by demand from the FMFO industry.
The region of Western Africa is suffering from increasing food insecurity, and the decreasing stocks of small pelagic fish is contributing to this crisis. As the number of fishmeal factories have increased in the region between 2010 and 2020, pelagic fish consumption in Senegal halved.[11]
The increasing production of FMFO is driven in large part by European companies using these ingredients in fish feed for farmed fish like salmon and sea bass. [12]
Consumers of European farmed fish products have the right to know whether the products they buy are linked in their supply chains to West African fishmeal and fish oil, and thus contributing to food insecurity and threatening livelihoods of fishworkers in the region.
Previous consumer campaigns have also demonstrated an overwhelming public interest in the supply chains of salmon fed on West African FMFO and found in Europe. A petition on taking farmed salmon off the menus of UK restaurant chain Wagamama’s due to its supply chain links to food insecurity in West Africa gathered over 100,000 signatures this year. [13]
Journalistic investigations on other European food products have also been received with immense public interest. For example, multiple articles have focused on the use of soya in animal feed and its links to deforestation.
It is therefore in the public interest to disclose the names of these European companies (consignees/importer) for the traceability of these supply chains.
It is also in the public interest to disclose the names of consignors/exports and establishments of origins, as local people in West Africa also have a right to know which factories and companies are directly threatening their food security and livelihoods.
I hope that DG Sante will review this decision and provide me with the redacted information.
Thank you very much,
Brigitte
[1] https://openknowledge.fao.org/server/api...
[2] https://www.sciencedirect.com/science/ar...
[3] https://openknowledge.fao.org/items/4f1c...
[4] https://www.greenpeace.org/static/planet...
[5] https://img1.wsimg.com/blobby/go/20e99f0...
[6] https://www.greenpeace.org/static/planet...
[7] https://feedbackglobal.org/wp-content/up...
[8] https://newint.org/immersive/2021/09/20/...
[9] https://capacity4dev.europa.eu/library/v...
[10] https://www.amnesty.org/en/documents/afr...
[11] https://www.fao.org/faostat/en/#data/FBS
[12] https://ig.ft.com/supermarket-salmon/
[13] https://actions.eko.org/a/wagamama-salmon
[14] https://www.nytimes.com/2019/07/29/busin...
[15]https://www.thebureauinvestigates.com/st...
[16] https://www.thebureauinvestigates.com/st...
[17] https://www.theguardian.com/environment/...
[18] https://trellis.net/article/soaring-soy-...
[19] https://www.theguardian.com/environment/...
[20] https://unearthed.greenpeace.org/2020/11...
[21] https://www.theguardian.com/environment/...
[22] https://www.globalwitness.org/en/press-r...
Dear Sir or Madam,
We hereby acknowledge the receipt of your request for access to documents
sent on 22/10/2024 and registered on 23/10/2024 under the case number
2024/5636.
We will handle your request within 15 working days as of the date of
registration. The time-limit expires on 14/11/2024. We will let you know
if we need to extend this time limit for additional 15 working days.
To find more information on how we process your personal data, please see
[1]the privacy statement.
Yours faithfully,
Directorate-General for Health and Food Safety - Access to Documents
European Commission
References
Visible links
1. https://ec.europa.eu/info/principles-and...
Dear Sir or Madam,
We hereby acknowledge the receipt of your confirmatory request for case
2024/4200, sent on 22/10/2024 and registered on 23/10/2024.
We will handle your confirmatory request within 15 working days as of the
date of registration. The time-limit expires on 14/11/2024. We will let
you know if we need to extend this time limit for additional 15 working
days.
Yours faithfully,
Secretariat-General - Access to Documents
European Commission
Dear applicant,
We are writing concerning your confirmatory request for access to
Commission documents for case EASE 2024/4200 registered on 23 October
2024.
We are currently working on your confirmatory request. However, we have
not yet been able to gather all the elements necessary to carry out a full
analysis of your request. We will not be able to send you the reply within
the prescribed time limit expiring on 14 November 2024.
A new deadline is needed as the consultations regarding your file are
still ongoing.
Therefore, in line with Article 8(2) of [1]Regulation (EC) No 1049/2001 we
need to extend this time limit by 15 additional working days. The new time
limit expires on 5 December 2024.
We apologise for any inconvenience this may cause.
Kind regards,
SG.C1 Access to Documents Team
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
Dear Health and Food Safety,
As the new deadline expired today, please could you provide an update of when the documents will be ready?
Thank you,
Brigitte Wear
[1]access to documents request - EU imports of fishmeal and fish oil from
Senegal, Mauritania, and Gambia - Ares(2024)8701138 (Please use this link
only if you are an Ares user – Svp, utilisez ce lien exclusivement si vous
êtes un(e) utilisateur d’Ares)
Dear Ms Wear,
Thank you for your e-mail which you sent to DG SANTE.
We sincerely apologize for the failure to reply within the statutory time
limit.
We would like to confirm that the internal consultations in relation to
your application are fully ongoing. Therefore, we cannot commit to a
specific timeframe within when the decision will be adopted.
However, we would like to assure you that we are doing our utmost to
provide you with a reply as soon as possible.
Please accept our apologies for the inconvenience this delay may cause to
you and thank you for your understanding.
Kind regards,
Access to Documents Team
European Commission
Secretariat-General Unit C.1 (Transparency, Document Management and Access
to Documents) - CR
Dear SG ACCES DOCUMENTS,
I'm just writing to follow up on this request. Please could you let me know if there is any update and when I can expect the full response?
Yours sincerely,
Brigitte Wear
Dear SG ACCES DOCUMENTS,
I'm just writing to follow up on this request, which is now long overdue. Please could you let me know if there is any update and when I can expect the full response?
Yours sincerely,
Brigitte Wear
[1]access to documents request - EU imports of fishmeal and fish oil from
Senegal, Mauritania, and Gambia - Ares(2024)8701138 - Ares(2025)69335
(Please use this link only if you are an Ares user – Svp, utilisez ce lien
exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Ms Wear,
Thank you for your e-mail.
We sincerely apologize for the failure to reply within the statutory time
limit.
We would like to confirm that the internal consultations in relation to
your application are fully ongoing. Therefore, we cannot commit to a
specific timeframe within when the decision will be adopted.
However, we would like to assure you that we are doing our utmost to
provide you with a reply as soon as possible.
Please accept our apologies for the inconvenience this delay may cause to
you and thank you for your understanding.
Kind regards,
Access to Documents Team
European Commission
Secretariat-General Unit C.1 (Transparency, Document Management and Access
to Documents) - cr
Dear SG ACCES DOCUMENTS,
I'm just writing to follow up on this request as it is now long overdue. Please could you let me know if there is any update and when I can expect the full response?
Yours sincerely,
Brigitte Wear
Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
[1]FW: access to documents request - EU imports of fishmeal and fish oil
from Senegal, Mauritania, and Gambia - Ares(2024)8701138 - Ares(2025)69335
- Ares(2025)1572118 (Please use this link only if you are an Ares user –
Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)
Dear Ms Wear,
Thank you for your e-mail.
We would like to take this opportunity to apologize again for the failure
to reply within the statutory time limit.
As confirmed in our previous correspondence of 7 January 2025, the
internal consultations regarding your file are still ongoing and we are,
unfortunately, not in a position to commit to a specific timeframe within
when the decision will be adopted.
However, we would like to assure you that we are doing our utmost to
provide you with a reply as soon as possible.
Please accept our apologies for the inconvenience this delay may cause to
you and thank you for your understanding.
Kind regards,
Access to Documents Team
European Commission
Secretariat-General Unit C.1 (Transparency, Document Management and
Access to Documents) - cr
Dear SG ACCES DOCUMENTS,
I'm just writing to follow up on this request as it is long overdue. Please could you let me know if there is any update and when I can expect the full response?
Yours sincerely,
Brigitte Wear
Your message has been received by the Transparency Unit of the
Secretariat-General of the European Commission.
Requests for public access to documents are treated on the basis of
[1]Regulation (EC) No 1049/2001 of 30 May 2001 regarding public access to
European Parliament, Council and Commission documents.
The Secretariat-General will reply to your request within 15 working days
upon registration of your request and will duly inform you of the
registration of the request (or of any additional information to be
provided in view of its registration and/or treatment).
L’unité «Transparence» du secrétariat général de la Commission européenne
a bien reçu votre message.
Les demandes d’accès du public aux documents sont traitées sur la base du
[2]règlement (CE) n° 1049/2001 du 30 mai 2001 relatif à l’accès du public
aux documents du Parlement européen, du Conseil et de la Commission.
Le secrétariat général répondra à votre demande dans un délai de 15 jours
ouvrables à compter de la date d’enregistrement de votre demande, et vous
informera de cet enregistrement (ou vous indiquera toute information
supplémentaire à fournir en vue de l'enregistrement et/ou du traitement de
votre demande).
Ihre Nachricht ist beim Referat „Transparenz“ des Generalsekretariats der
Europäischen Kommission eingegangen.
Anträge auf Zugang zu Dokumenten werden auf der Grundlage der
[3]Verordnung (EG) Nr. 1049/2001 vom 30. Mai 2001 über den Zugang der
Öffentlichkeit zu Dokumenten des Europäischen Parlaments, des Rates und
der Kommission behandelt.
Das Generalsekretariat beantwortet Ihre Anfrage innerhalb von
15 Arbeitstagen nach deren Registrierung und wird Sie über die
Registrierung Ihres Antrags (oder die Notwendigkeit weiterer Informationen
im Hinblick auf dessen Registrierung und/oder Bearbeitung) unterrichten.
References
Visible links
1. https://eur-lex.europa.eu/legal-content/...
2. https://eur-lex.europa.eu/legal-content/...
3. https://eur-lex.europa.eu/legal-content/...
[1]FW: FW: access to documents request - EU imports of fishmeal and fish
oil from Senegal, Mauritania, and Gambia - Ares(2024)8701138 -
Ares(2025)69335 - Ares(2025)1572118 - Ares(2025)4610727 (Please use this
link only if you are an Ares user – Svp, utilisez ce lien exclusivement si
vous êtes un(e) utilisateur d’Ares)
Dear Ms Wear,
We are writing in reply to your message of 23 May 2025, in which you ask
for an update regarding the status of file EASE 2024/4200. Specifically,
you inquired about the expected deadline for receiving a response.
We would like to apologise for the considerable delay in proving you with
a reply to your confirmatory request. Additionally, we would like to
sincerely thank you for your patience and understanding.
Please note that, while we are doing our best to handle your case within
the deadlines provided by the Regulation, delays are due to the very high
volume of requests currently reaching our services.
We sincerely regret that we cannot provide you with more concrete
information about the final reply of the Commission and when you can
expect to receive it, but please be assured that we endeavour to finalise
the internal decision-making process in its regard as soon as possible.
Yours sincerely,
SG.A2 - Document Management and Access to Documents - cr