11. ACTIVIDADES A DESARROLLAR EN LA IMPLEMENTACIÓN DEL
11.1. Tibabúyes portátil
In the last decade, the expansion of international trade in fishery products has exceeded the growth in total fish production in the world. This rapid expansion reflects the large increase in consumption of marine products in the EU and US markets as well as many other regions of the world like Asia. Among these fast-growing markets, the European Union is not only the world’s largest market, but it is among the fastest growing markets for high-value imports like shrimp, tuna, bass and bream. The prospects for these markets continue to be favorable. Overall, the outlook for the global fishery market is robust, and our medium-term forecast is for EU imports to growth by 8 percent annually. For Indonesia, the rapid expansion of the global fishery market and the European Union’s strong market for high-value imports offers a number of excellent opportunities. In the first place, the industry has the chance to reverse the EU market share losses it suffered in the last decade because of external competition from large exporters like Ecuador and China, as well as the internal inertia in addressing EQI hindrances and trade impediment. Secondly, Indonesia’s exports could be increased in terms of traditional exports and diversified into various other fish species and processed products that are in high demand abroad, for example, the main exports from aquaculture are shrimp (unfrozen, frozen and canned), crabs (unfrozen, frozen and canned), frog legs (fresh or chilled), ornamental fish (freshwater and mariculture), mollusks (scallops and snails), including capture products like tuna, jelly fish and coral fish as well as fish fat and oil and shrimp crackers. A third opportunity lies in aquaculture growth and development, where opportunities exist for community-based economic activities and rural development, along with greater foreign exchange earnings from exported aquaculture products. Given that two-thirds of Indonesia‘s territory consists of marine and inland waters with an abundance of natural resources, the development of aquaculture and sustainable capture fisheries has the potential to make the fishery industry leading engines of growth and development for the country.
The risks to programs aimed at promoting Indonesia’s fishery exports are capacity and institutional constraints at the industry level and exchange rate policies at the macroeconomic level. There are two pressing problems that are internal to the industry. The first is capacity limitations of institutions providing EQI and the resulting limitations that these inadequacies create for fish and fishery exporters attempting to meet EU market access requirements. The issue has been made all the more important as large multinationals and some nationally large private retails in Europe introducing their own standards for food safety and quality, environmental sustainability, and social consciousness. In large part, these initiatives reflect the growing concern of the general public and the retail sector in Europe about overexploitation of fish stocks, and the need for certification of aquaculture in general and of shrimp in particular. The second issue is the lack of adequate coordination and collaboration among central and provincial government agencies and the armed forces in regulating the industry and policing EEZ waters to prevent IUU fishing.
While the challenges to the fishery industry appear wide-ranging, the dominant impediments to greater EU market access are concentrated on the supply side. The exchange rate pass-through into the export price of Indonesia in the EU market has been large, but their impact on EU demand for Indonesian fish and fishery products has not significantly impacted trade. In fact, our estimates found that the real cross-rate between the euro and the rupiah has not been statistically significant in determining the EU demand for Indonesian fish and fishery products. Instead, non-price factors appear to have consistently undermined Indonesia’s exports to the EU market. These non-price factors reflect (1) supply-chain weaknesses in both internal and external production processes affecting quality levels; (2) inadequate networking capabilities needed to ensure appropriate export services to foreign markets; (3) weak coordination between national, provincial and law enforcement authorities to control IUU fishing; and (4) EQI impediments to EU market access.
Specific findings on the supply side are as follows:
International Recognition of Laboratory Tests – The Ministry of Marine Affairs and Fishery (MMAF) has been appointed by the European Union as the Competent Authority for fishery products in Indonesia. The MMAF carries out testing for fish diseases and health certificates
through a total of 49 MMAF test laboratories and 39 provincial laboratories. These provincial laboratories are not under MMAF’s authority. Many of the laboratories have been accredited by Komite Akreditasi Nasional (KAN), but the scope of accreditation does not always include all parameters tested. Additionally, it is evident that a substantial number of these laboratories do not meet international standard requirements regarding quality management and competence. In order to ensure the status and function of the MMAF as the Competent Authority it must be ensured that all tests used for conformity assessment provide reliable test results that are internationally recognized. Exporters of fishery products rely on test and inspection facilities to ensure the smooth export of their products to the European Union and other markets.
Proficiency Testing and Certified Reference Material – In chemical testing, Certified Reference Materials (CRM) and Proficiency Tests (PT) are used as tools to achieve traceability. At present the utilization of CRM is very limited in Indonesia due to the fact that most CRM are imported and therefore comparatively expensive. Without CRM traceability to national and international reference standard cannot be achieved.
Test results must be traceable and comparable to results provided by any other test laboratory domestically and internationally. It is standard international practice to conduct proficiency tests on selected parameters with a group of test laboratories that serve as indicators for traceability. The need to produce CRM and to conduct regular proficiency tests in Indonesia had already been identified in TSP I.
The Research Center for Chemistry (RCChem) in the Indonesian Institute of Science (LIPI) has recently been appointed as the national metrology institute for chemical reference materials and proficiency tests in Indonesia. RCChem is supported by Physikalische Technische Bundesanstalt (PTB) Germany. It has been decided that a number of laboratories will serve as producers of CRM and providers of PTs, of which the National Center of Quality Control (NCQC) of MMAF is one. At present NCQC does not have the capability to produce CRM and conduct PTs as required.
Implementation of GAP in Farms – A considerable number of fish and shrimp farmers are not applying Good Aquaculture Practices (GAP). Antibiotics are still applied, which endangers export to the European Union and other export markets.
Implementation of GHP at Middlemen – A considerable number of middlemen are not applying Good Handling Practices (GHP), resulting in problems especially with regard to hygiene and an assured cooling chain. Additionally, the common practice of unrecorded collection and mixing does not allow traceability of products.
Quality in Processing Companies – The final report of a mission carried out to evaluate the control systems in place governing the production of fishery products intended for export to the European Union (2009) states that several processing companies have shortcomings with regard to HACCP and GMP. It is also evident that most processing companies do not conduct audits of their suppliers as required.
Quality Management System ISO 9001 in MMAF – The MMAF recently changed its structural organization with the objective of improving and streamlining its operations. Due to this restructuring, the existing quality management system (QMS) in MMAF does not suit the new organization and its operations.
Management Processes in MMAF – It has been observed that the MMAF presently has shortcomings in coordination and control of the provincial authorities in charge for NRCP, inspection control (vessels, farmers, middlemen, and processors), GAP certification, and medicine and feed control. Required recording of inspection results is not ensured.
Quality Management System ISO 17020 in Provincial Authorities – An analysis was recently conducted of the control systems governing the production of Indonesian fishery products for
export to the European Union.43 The findings showed that the quality management system of the provincial authorities is not functioning properly and the competence of the used inspectors is insufficient.
Information Channels - There is a large amount of actors involved in the value chain of fishery products consisting of the MMAF, provincial authorities, test laboratories, fish processors and their suppliers. It is currently not ensured that all involved parties are swiftly informed on new or revised EU regulations and on reports of the rapid alert system (RAS) applicable for their operations.
In an effort to address these issues, interventions could be integrated into the Government’s strategy and action plan for the industry, along with industry-based EQI activities supported by TSP II or other donor interventions. They would cover specific actions in the following areas: (1) planning and developing the fishery industry; (2) promoting the fish processing industry; (3) strengthening quality control laboratory facilities; (4) combating IUU fishing; (5) lowering costs of shrimp production; (6) developing a stronger image, market information and export promotion strategy, (7) and overcoming EQI impediments to market access.
43 European Commission, “Fisheries Partnership Agreement FPA 2006/20”. Annex 5: Indonesia Case Study”. Brussels, FPA 15/ IUU/2008.