Written Evidence submitted by Crustacean Compassion (FS0054)

Crustacean Compassion[i] welcomes the opportunity to submit evidence to the Committee’s inquiry on food security. Ensuring that food security is maintained and improved in the coming decades is an important task and we welcome the focus the issue is receiving from government. Due to the focus of our organisation, we have limited the detailed comments in our response to the welfare of decapod crustaceans (animals such as crabs, lobsters, prawns and nephrops), alongside some general responses on animal welfare.


General Comments


  1. The United Kingdom is a nation of animal lovers, something which has been reflected in the policies of successive governments over many years government policy for many years. While we welcome the mention of animal welfare throughout the government’s food strategy, we believe a systematic approach to ensure animal welfare at every stage of the process is needed.


  1. We are concerned that the animal welfare focus of the strategy appears to be focussed exclusively on land-based farmed animals. With no mention of the welfare for animals taken from the wild for food or aquaculture. These are both key sectors within UK food production and more consideration must be given to the welfare of these animals. Similarly, where there is mention made in the strategy of a need to support farmers we believe this should be extended to also include those involved in the fishing and aquaculture industries. Robust support for the fishing sector during significant challenges - such as the current fuel price crisis - would help to maintain a resilient industry and attract new entrants who may otherwise be deterred by the high cost of entry and operating risks.


  1. The food strategy is a missed opportunity to set clear boundaries on what is acceptable practice in terms of animal welfare. We believe that the strategy should also include clear guidance on issues such as purchasing live animals for consumption through the post and home-slaughter. Two outdated practices which cause suffering to the animals involved and we believe should be banned[ii], especially since the passage of the Animal Welfare (Sentience) Act 2022.


  1. Improving animal welfare in the fishing industry can make the industry more sustainable and aligns with the UK government’s support of the UN 2030 Sustainable Development Goals[iii]. For example, in the UK, declawing and returning crabs to the sea is seen to promote a sustainable food source – one claw can be torn off for sale, and the crab put back into the water, where it is assumed another will grow back. However, evidence shows that crabs who are returned to sea following manual removal of one or both claws experience seriously poor welfare. In addition to the painful wounds caused by declawing, when returned to the sea the practice also seriously affects a crab’s quality of life and reduces their ability to feed and access key food sources, ability to fight or defend themselves against predators, ability to compete for important resources, such as territory, shelter or mating partners and survival rates [iv] [v] [vi] [vii]. At a time when the fishing industry faces many uncertainties it is vital that it is made as sustainable as possible, both in terms of environmental impact and sustainability of fishing stocks.


  1. We are concerned at the lack of detail on how the strategy will be implemented and overseen. There is also a lack of detail about accountability for delivering the strategy, either through the Department of Environment, Food and Rural Affairs or through Parliament. This is something which needs to be addressed if the strategy is to have a meaningful impact in the future.


  1. We would commend the Scottish governments recent announcement[viii] that it will establish a statutory Food Commission, following an amendment to the Good Food Nation Bill. We believe that similar bodies elsewhere in the UK, with similar powers for oversight and scrutiny, would improve both the delivery of the food strategy and the aspirations contained within it.


Specific comments on the Strategy


  1. We welcome the government’s commitment in the strategy[ix] to a ‘prosperous agri-food and seafood sector that ensures a secure food supply in an unpredictable world and contributes to the levelling up agenda’ (paragraph 16). It is important that fishing industries are sustainable from an economic viewpoint if they are to continue to contribute towards food security, and investment from government in these areas would be welcomed.


  1. While we welcome the £100million Seafood Fund pledged by the previous administration – we believe that some clarification is needed on how the fund will be allocated. The strategy sets out £24m to support ‘seafood science and innovation’ along with ‘at least’ £65m for an ‘an infrastructure scheme’[x]. Previous announcements included funding from the Seafood Fund to support the fishers affected by the mass die-off in the North-East[xi]. If there is to be continued public confidence in the fund, we believe that allocation of funds must be clear and the fund should be extended if necessary to fulfil stated objectives. The science and innovation allocation should include a focus on the field of humane stunning and slaughter of aquatic animals. Not only are UK companies playing a key role in advancing this area of R&D – such as Scotland’s Ace Aquatec[xii] – these technological advancements and their early adoption will assist the UK food industry to stay at the forefront of higher animal welfare policy.


  1. The strategy contains a commitment to consult on Government Buying Standards for Food and Catering Services, mentioning an aspirational target of 50% of food spend being on local produce – this could both support local fishing communities but also reduce welfare concerns associated with travel, especially for animals like decapod crustaceans who have complex environmental needs.


  1. Objective 1 refers to the contribution that the food industry can make to food security and the levelling up agenda. Developing stronger shellfish demand in the domestic market has the potential to reduce reliance on export markets, boost food security with shorter supply chains, create more jobs and improve animal welfare by reducing transportation times for live decapod crustaceans.
  2. Paragraph 1.2.1 raises overseas food production. As an island nation with rich fishing waters and heritage we believe the UK government should be focussing on improving the sustainability of the UK fishing fleet, while working with international partners to drive up animal welfare standards in fishing around the world.


  1. We welcome the recommitment in the strategy to ensure that ‘FTAs protect domestic standards’. Through our work as part of the Trade Animal Welfare Coalition[xiii], alongside other animal welfare organisations, we have raised concerns around a number of FTAs including that recently signed with Australia.


  1. We welcome the commitment within the strategy to tackle illegal, unreported and unregulated fishing. This is important both from an animal welfare perspective but also in ensuring sustainability of food supply.
  2. Section 2.3 refers to creating a more transparent food system. We welcome this commitment and strongly endorse the inclusion of decapod welfare standards and reporting modalities in the Food Data Transparency Partnership’s scope. Since decapod crustaceans were included in the Animal Welfare (Sentience) Act 2022, issues regarding their welfare has been widely reported. This year we will launch a new annual benchmark report, which evaluates UK seafood companies on their management practices and reporting on decapod crustacean welfare. The project can be considered a key part of the drive to elevate transparency and accountability in the UK seafood industry. Seafish’s 2021 Strategic Review[xiv] highlighted the need to improve the industry’s reputation on issues such as animal welfare. Greater access to supply chain data enables both consumers and producers to make informed choices, while enhancing the UK seafood industry’s reputation at home and abroad.


[i] https://www.crustaceancompassion.org/

[ii] https://www.crustaceancompassion.org/online-sales

[iii] https://sdgs.un.org/goals

[iv] Duermit, E., Kingsley-Smith, P.R., and Wilber, D.H. (2015). The Consequences of Claw Removal on Stone Crabs Menippe spp. and the Ecological and Fishery Implications. North American Journal of Fisheries Management 35, 895–905.

[v] Patterson, L., Dick, J.T.A., and Elwood, R.W. (2009). Claw removal and feeding ability in the edible crab, Cancer pagurus: Implications for fishery practice. Applied Animal Behaviour Science 116, 302-305

[vi] Davis, G.E., Baughman, D.S., Chapman, J.D., MacArthur, D., and Pierce, A.C. (1978). Mortality associated with declawing stone crabs, Menippe mercenaria. South Florida Research Center. National Park Service, Report T-552. 20 pp.


[viii] https://www.parliament.scot/-/media/files/committees/rural-affairs-islands-and-natural-environment-committee/correspondence/2022/good-food-nation-bill-cab-sec-rai-to-con-6-june-2022.pdf

[ix] https://www.gov.uk/government/publications/government-food-strategy/government-food-strategy

[x] https://www.gov.uk/guidance/uk-seafood-fund

[xi] https://hansard.parliament.uk/commons/2022-06-28/debates/94C1B49B-4029-4369-883B-BA96A269F1E3/DeadCrustaceans(North-EastCoast)

[xii] https://aceaquatec.com/

[xiii] https://tawcuk.org/

[xiv] https://www.seafish.org/about-us/governance-and-performance/strategic-review-of-seafish-in-2021/



September 2022