Is tuna ecolabeling causing fishers more harm than good?

Abstract

Nearly 70,000 fishing crew are currently at sea catching the ecolabeled tuna in your sandwich or sushi. Their catch equals half of the world’s tuna supply. The purpose of this research was to collect tuna data from the website of the Marine Stewardship Council ( fisheries/msc.org) to learn what the data reveal about protecting tuna fishers from labour violations while fishing on certified vessels. The standard-setter does not have a fishing labour standard but posts data to its website ( fisheries/msc.org ) it says demonstrate that vessels in the program operate with well-managed labour risks. To confirm this, a database of 3260 tuna vessels was built from vessel lists, annual catches, and labour statements and queried for fishing job identifiers. Fishing employers ( vessel owners ) were identified in the vessel data for 1291 vessels representing 26% of the ecolabeled tuna catch. In labour statements, employers were identified for 1238 vessels and 14% of the tuna catch. Flag state labour laws were identified for 1617 vessels and 50% of the tuna catch. Few tuna vessels were owned by the certificate-holding entities (4%) that submitted labour statements and these data were scant on vessel practices. Certificate-holders disavowed debt bondage, forced and child labour as “non-applicable” on MSC-engaged vessels overall. Jobs, risks, and vessel employment practices could not be tracked from the data. Seven vessels currently listed in the program were reported by fishers for forced labour. Yet, all owners of certified vessels gain logo rights and benefits, due to certification’s pooling mechanism.

Full text

Is tuna ecolabeling causing shers more harm than
good?
Katrina Nakamura (  Katrina@Sustainability-Incubator.com )
Article
Keywords:
Posted Date: December 11th, 2023
DOI: https://doi.org/10.21203/rs.3.rs-3717953/v1
License:   This work is licensed under a Creative Commons Attribution 4.0 International License. 
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Additional Declarations: No competing interests reported.

Title: Is tuna ecolabeling causing fishers more harm than good?
Authors: Katrina Nakamura, PhD1*
Affiliation:
1Sustainability Incubator, Honolulu USA
*Corresponding author. Email: Katrina@Sustainability-Incubator.com
Abstract: Nearly 70,000 fishing crew are currently at sea catching the ecolabeled tuna in your
sandwich or sushi. Their catch equals half of the world’s tuna supply. The purpose of this
research was to collect tuna data from the website of the Marine Stewardship Council
(fisheries/msc.org) to learn what the data reveal about protecting tuna fishers from labour
violations while fishing on certified vessels. The standard-setter does not have a fishing labour
standard but posts data to its website (fisheries/msc.org) it says demonstrate that vessels in the
program operate with well-managed labour risks. To confirm this, a database of 3260 tuna
vessels was built from vessel lists, annual catches, and labour statements and queried for fishing
job identifiers. Fishing employers (vessel owners) were identified in the vessel data for 1291
vessels representing 26% of the ecolabeled tuna catch. In labour statements, employers were
identified for 1238 vessels and 14% of the tuna catch. Flag state labour laws were identified for
1617 vessels and 50% of the tuna catch. Few tuna vessels were owned by the certificate-holding
entities (4%) that submitted labour statements and these data were scant on vessel practices.
Certificate-holders disavowed debt bondage, forced and child labour as “non-applicable” on
MSC-engaged vessels overall. Jobs, risks, and vessel employment practices could not be tracked
from the data. Seven vessels currently listed in the program were reported by fishers for forced
labour. Yet, all owners of certified vessels gain logo rights and benefits, due to certification’s
pooling mechanism.
One-Sentence Summary: A leading tuna ecolabel promotes lower risks of forced labour on
certified vessels but fishing jobs cannot be tracked with its data.
Table of Contents:
Introduction page 2
Results page 4
Discussion page 10
Conclusion page 11
Materials & Methods page 12

Acknowledgements page 14
Funding Sources page 14
Data Availability Statement page 14
References page 14
Introduction:
A tuna catch equal to half of the world’s supply comes from 46 fisheries that are certified by the
Marine Stewardship Council (MSC), which the ecolabel defined as “wild food, good jobs, and
healthy oceans” (1) in 20221. The MSC is a private sector ecolabeling organization and UK-
based charity that exerts significant influence on market perceptions of sustainability. It is
currently operating with £45 million in assets and £30 million income (2) and earns revenues
from licensing the use of its ecolabel to the wild-caught seafood trade, including tuna harvested
from 21 of 23 global tuna stocks. Recently, the MSC signaled that industrial fishing labour is a
new area it seeks to promote as a standards-setter. It codified its eligibility requirements2 and
said its data indicate that well-managed fisheries are highly likely to have risk mitigating
measures in place, also, that it is sending a strong signal by withdrawing certification if fisheries
are convicted of forced or child labour abuses (3-4). The purpose of this research was to query
the data from the MSC website (fisheries/msc.org) for tuna to learn what the data reveal about
protecting fishers from labour violations while tuna fishing on certified vessels.
Forced labour in fishing is an experience lived by fishers. Prevention of labour violations is an
enormous challenge in High Seas fishing due to the captive nature of the job and the ways fishers
are recruited to work. INTERPOL described how the recruitment of fishing labour can be
manipulated into forced work in a Purple Notice it issued to police forces in 2019 (5). Debt
bondage for example occurs when vessel owners recruit foreign fishers through agents to save
costs (6) and fisher employment is secured by debt (7). An estimated 128,000 fishers are trapped
in forced labour aboard fishing vessels (8) by businesses recruiting fishers for very low wages to
work intensely in hazardous and remote conditions who then experience untended injuries,
illness, unpaid or withheld wages, psychological or physical abuse (9). Fishers do not control
their work hours or access to food, potable water, documents, wages, first aid or hospital care,
1 Readers will note that data on a private website may change over time and date-based versions can be confirmed
with the help of a web archives reader (for example, https://web.archive.org/).
2 Fisheries certificate-holders are to provide a list of vessels that must be uploaded to the MSC database by the
certifier (requirement 7.29.15di, MSC Fisheries Certification Process v3.0, October 2022). As clients they also fill a
templated labour statement (requirement 4.1.1, Labour Eligibility Requirements v1.0, November 2022). Certifiers
are to “confirm that all sections are filled and include all entities in the unit of certification”. (7.4.2.7-8 in the
Fisheries Certification Process (v2.2 2020). Clients are instructed not to include an entity that has been convicted for
a forced or child labour violation in the last 2 years (requirement 3.1.1, Labour Eligibility Requirements). A
‘conviction for a serious crime’ within the past 2 years is grounds for clients to self-disqualify a vessel (requirement
1.1.5 in the Fisheries Standard v3.0, 2022). Like illegal fishing, trafficking in persons is listed as a serious crime
however certifiers are not instructed to search the standing of vessels against published forced labour violations or
the Combined IUU Black List. The Chain of Custody standard (v5.1, 2023) says certificate-holders must avoid
purchasing fish from vessels on the black list but no specific instructions were found. There is also an exclusion for
fisheries certificate-holders (see footnote 6). Overall, the procedures instruct clients to follow the honour system.

and a foreign fisher might lack access to their identity documents and officials who speak their
language. Vessel owners have this control. Fishers are their employees3 (10) and their employer
duties are defined in law (11). Therefore, risks of violations reside in the employment practices
of vessel owners. Fisher reports are the most credible source of data to ascertain risk.
The MSC publishes some data on its website (fisheries/msc.org) that could allow for fishing jobs
and employment practices to be tracked. Importantly, fishing vessels are not a unit of assessment
in the MSC Fisheries Standard. It is not a vessel compliance standard4. MSC ecolabeling is
unlike other ecolabels for say cobalt for cell phones or clothing where the private sector entity
making a product hires a certifier to assess their facility’s process of production to a technical
standard (12). Instead of a fishing vessel-owning entity, the responsibility for meeting the
Fisheries Standard is assigned to a public sector entity by the MSC because fish are a public
resource. Private sector clients hire a certifier to assess whether government decisions and
information meet the technical standard and, where they do, the client receives a certificate and
may use the logo on their products by paying license fees to the standard-setter. The certificate-
holder is not necessarily the fishing operation but could be a distributor that lists vessels they
purchase fish from on their certificate; for example, five tuna distributors hold 16 tuna
certificates. Certificate-holders and vessel owners gain logo rights and benefits from the
standards-setter’s influence on market perceptions about how the product was made.
The client data posted on the MSC website (fisheries/msc.org) might contain identifiers which
are essential for measuring risk of labour violations. Identifiers might include the vessel owning
entities or crew origins, as for example, around 85% of crew on tuna vessels are foreign fishers
according to the labour statement data. The presence or absence of some data might show the
compliance of clients with the program’s eligibility requirements. Each client has a dedicated
page where vessels are listed, annual catches are specified by tuna species, and labour statements
are posted by the MSC together with the certification documents. Fisheries certifiers collect this
data from their clients and post it to the MSC database but they do not confirm the data or
measure it against any performance or confidence threshold (and neither do certifiers for the
3 Fishing crew members are employees according to the International Labour Organization, and not self-employed
or dependent contractors unless they have registered independently as business entities in their country.
4 Performance indicator 3.2.3 for compliance and enforcement contains inferential language in scoring issue D
which could imply a private sector responsibility for regulatory compliance overall, but in fact is strictly limited to
“systematic non-compliance” by the fleet as a whole with “governing sustainable fishing practices on the water”
which are specified as Monitoring/Control/Surveillance, Marine Protected Areas and habitats only. (See MSC
Fisheries Standard v3.0, 2022, page 94 and MSC Certification Process v3.0 2022, pages 42-43.

Chain of Custody Standard5). The client labour data are protected by a disclaimer6. Although the
secondary quality and bias of self-reported data suggest that it does not have good confidence,
these data are valuable because the certificate-holding entity is communicating their ecolabeled
tuna catch to the commodity tuna market as well as the vessels responsible for it.
It is imperative to look into the Marine Stewardship Council tuna data in light of current
controversies over forced and child labour in fishing (13, 14, 15, 16, 17, 18, 19, 20, 21) and tuna
fishing specifically (22, 23, 24, 25). This research was motivated by four factors. First, the MSC
logo is found on tuna products in supermarkets worldwide from 21 of 23 global tuna stocks so it
is consequential to perceptions about forced labour in tuna fishing. Second, hundreds of tuna
fishing vessels and entities worldwide have been associated with forced labour recently by
governments and investigators (26, 27, 28, 29, 30, 31, 32). Third, in spite of barriers like long
stints at sea and power imbalances, tuna fishers are reporting forced labour on tuna fishing
vessels7, and some of their reports are highly-accessible (33, 34, 35). Fourth, given its reach, the
ecolabel could contribute to the prevention of forced labour in tuna fishing by aligning its market
signals with its workplace-level evidence and by educating the fishing industry to close gaps.
Results:
Collected in a database (provided in Supplemental Materials) the tuna data on the website of the
Marine Stewardship Council (fisheries/msc.org, as of February 2, 2023) depict that 2,416,057
metric tonnes (MT) of ecolabeled tuna are harvested from the sea each year. The catch is
equivalent to 50% of the estimated worldwide catch of 4.8 million MT in 2022 (36). It is
attributed to 3260 tuna vessels in the MSC program that are fishing on 21 of 23 tuna stocks in 46
fisheries, or 3046 distinct tuna vessel workplaces after removing duplicates listed to more than
one certificate. This catch is large considering that MSC-engaged tuna vessels account for less
than 10% of the 30,966 tuna vessels listed to the registries of the tuna regional fishery
5 Fisheries certificate-holders appear to be exempted from the labour requirements which are specified for onshore
facilities (Chain of Custody standard v5.1, 2023). The updated standard does not require its certifiers to review the
vessels for serious crime convictions for either of human trafficking/forced labour or illegal, unreported and
unregulated fishing (see 5.3.6 guidance) even if an intent is stated in the Fisheries Standard v3.0 (Box GSA2). No
specific instructions were found that require either a Chain of Custody certifier or client to provide information to
the MSC concerning labour violations on fishing vessels, in any of the Labour Eligibility Requirements 1.0, 2022,
Fisheries Standard v3.0 (2022), MSC Fisheries Certification Process v2.2 (2020), Chain of Custody Standard, (v5.1,
2023) and MSC General Certification Requirements v2.4.1 (2019). When applying, Chain of Custody clients fill a
labour risk checklist where, should they score three or more high risks (of 5) then a social audit of their facility may
be required (Table 5 and Table 6, MSC Chain of Custody Certification Requirements v5.1, 2023).
6 “Disclaimer: The Certificate Holder Forced and Child Labour Policies, Practices and Measures Template is
intended for at-sea fishery and supply chain certificate holders to provide a statement on measures, policies and
practice in place in the fishery to ensure the absence of Forced and Child Labour. Submission of this statement is a
requirement to confirm eligibility to participate in the MSC program. It has not been audited or verified by any
third-party entity. It is provided for information purposes and should not be construed to constitute certification of
performance against a labour standard.”
7 Noting that the MSC’s 2-year timeframe for convictions is poorly matched to the real world outcomes for a tuna
fisher leaving forced work. They would likely be without funds and agency and might have been at sea for years. It
could take years for a case to reach a decision, should the fisher find bring one forward, and the decision would
more likely be taken in a labour, immigration, fisheries, or anti-trafficking process than a criminal court.

management organizations (tuna RFMOs) and less than half of vessels in the world’s largest tuna
fishery8.
Who are the people behind the MSC logo for tuna? From the data, the certificate-holding entities
appear to be 32 distinct client groups comprised of 15 producer associations (2403 vessels), 12
tuna manufacturers (296 vessels), and 5 distributors (561 vessels) (Table 1) with each distributor
named as the client on multiple certificates. Fishers are not enumerated in the MSC program
data. However, an estimated 68,773 fishing crew members are working on certified tuna vessels
based on the vessel gears and sizes described in the certification documents (see Materials and
Methods). Some identities for vessel owners (fishing employers) were given in the vessel data
and labour statements. On vessel lists, owner names were given for 1291 vessels representing
26% of the ecolabeled tuna catch (Table 2). Most of these vessels (920) appeared on a single
certificate (MSC-F-31498). In the labour statements of tuna clients, vessel owners were given for
1238 vessels and 14% of the tuna catch.
Without names for most vessel owners, it is not possible to trace the jobs of an estimated 33,871
fishing crew members from the vessel lists or 31,420 tuna fishing crew members from the labour
statements. A member of the public, fisher representative, or public defender would be unable to
locate a fishing employer from these data. Overall, vessel owner identities were not found for
twenty-two tuna certificates (48%) on any of the client pages, vessel lists, certificates, public
certification reports, surveillance reports or labour statements. Fishing jobs on these tuna vessels
are unknown to the MSC and public. Therefore, the employment practices of vessel owners are
unknown and so is the fisher experience on the vessels. This raises questions about the
information and units used by the MSC to “withdraw certification if fisheries are convicted of
forced or child labour abuses” (37). Vessel owners hold the employment responsibility and are
the entity named in convictions. Furthermore their employment compliance cannot be known
unless the applicable labour laws are identified. Applicable labour laws were identified for 1617
vessels in the labour statements and 50% of the tuna catch.
In the MSC program, fishing employment practices are represented in labour statements
submitted by the certificate-holders who may not be fishing employers or privy to proprietary job
information. In order to compare the certificate-holders and vessel owners, the missing identities
were searched on vessel registries of government fisheries authorities named in the certification
documents. For example, a tuna vessel named on the vessel list for a certified fishery in the
Western or Central Pacific Ocean was searched on the vessel registry of the Western and Central
Pacific Fisheries Commission. If not found there, the vessel name was searched on the national
registry or four other vessel registries of tuna regional fisheries management organizations
(RFMOs). If not found there, the vessel name was searched on platforms Marine Traffic and
8 The MSC certificate states that 249 purse seine vessels are certified in the Parties to the Nauru Agreement fishery
for Western and Central Pacific skipjack, yellowfin and bigeye tuna. It is the only tuna certificate that did not
publish a vessel list on fisheries/msc.org. The certifier provided a hyperlink to a regional registry for the Parties to
the Nauru Agreement (https://www.pnatuna.com/registered-vessels) where the number of purse seine vessels listed
was greater than the 249 vessels noted in the certification documents, making it nearly impossible to distinguish
those in the MSC program precisely. Purse seine vessels were also mixed with longline vessels on the registry.
Parsing required hours of work and gear knowledge and could prevent labour advocates from identifying vessels.

Vessel Finder. This was deemed necessary because tuna vessels can move across oceans and the
spelling of tuna vessel names can vary across platforms.
After this lengthy process, 1100 vessel-owning entities were identified and brought the total
number of vessels with known owners to 2391 of 3260. However, 152 vessels could not be
located on government registries and 869 were located but the vessel-owning entities were not
provided for five certificates (MSC-F-31527, MSC-F-31246, MSC-F-31486, MSC-F-31408).
Still, it was possible to compare the names of certificate-holding entities and vessel-owning
entities for 73% of the certified tuna vessels, which had the same name for 87 of the 2391
vessels, or 4%. Most certificate-holding entities are not vessel owning-entities so while
illustrative, the labour statement data is of secondary or tertiary quality and does not represent
vessel employment practices with good confidence.
Finally, a closer look at the labour statement content revealed certificate-holders’ knowledge,
perceptions and expectations for fishing labour. Furthermore it revealed that single labour
statements tend to represent multiple fleets, flags, crew origins, and oceanic areas (17 flags for
MSC-F-31362). Some statements had identical phrasing. Content responses were generic and
lacked vessel-level examples. A few certificate-holders said that the expenses of labour
recruitment are borne by the company (MSC-F-30011, MSC-F-31452) but overall, certificate-
holders disavowed that tuna fishers could be exposed to debt bondage, with responses that
included “No child or forced labour can exist”, “Debt bondage N/A”, “it simply does not exist”
or equivalent (MSC-F-31349, 31558, 31537, 31530, 31556, 31157, 31452, 31408, 31555, 31341,
31498, 31245, 30029, 31553, 31554, 30002). One certificate-holder said crew are responsible for
the cost of their return if they have to leave the fishing vessel for any reason (MSC-F-31440)
which could be construed as working under threat in captivity—an exposure to forced labour.
These examples were selected because they reveal that forced labour and its risks in fishing on
the High Seas might not be well-understood by the industry. When asked, for example, how
fishers can report abuse, some said fishers could report to the union (MSC-F-31275), others that
“local people’s governments are responsible” (MSC-F-31399) or that “[fishery] observers report
any crew grievances made to them” (MSC-F-31362, MSC-F-31553) although this is not a
mandate of fisheries observers. Of highest concern was apparent confusion about the legal age of
work for tuna fishing on the High Seas. Most responses said age sixteen (or, “the younger, the
better” (MSC-F-31497). Yet, child hazardous work laws prohibit the recruitment of anyone
younger than eighteen years old into industrial fishing in numerous countries, for example in
Indonesia. A certificate-holder mis-stated the legal age of fishing work as 15 in Indonesia (MSC-
F-31471) and appeared to condone illegal employment when it said, “if children aged between
15-18 years are involved in the scope of certification, then the provisions in the Fair Trade
standard (FHR-PC 1) applies”.
One tuna labour statement stood out from the others (MSC-F-31349) for inconsistency with the
lived experience of fishers. Fishers on three of the vessels had recently reported forced labour
when it was posted to the MSC website. Their testimonies were amplified in 2019 in a high-
profile, English language report by Greenpeace with the Indonesian Migrant Worker Union (38).

After the US government banned tuna imports from one of these vessels, due to the debt bondage
and forced labour experienced by the fishers (39) then that vessel’s name was removed from the
MSC certificate in 2021. However, the other vessels and vessel owners are still named on the
certificate (Table 3) despite that the threshold for a trade ban is sufficiently high to say with
confidence that the company has benefitted from forced labor. Several questions are raised here.
The first is about untrue data. The certificate-holder said in their 2019 labour statement that
“there is no evidence of any debt bondage”. Another question raised is about how the MSC
applies its eligibility criteria, because in this case, neither the fishery or certificate-holder were
disqualified although those are the entities that the criteria name (per 3.1.1 in the Labour
Eligibility Requirements, v1.0, 2022). Two of these vessels, and five others that tuna fishers have
reported for forced labour, are currently listed on MSC tuna certificates (Table 3).
Table 1: Certificate pages and certificate-holding entities for ecolabeled tuna (fisheries/msc.org
as of February 2, 2023):
Tuna Producer Associations
Tuna Manufacturers
Tuna Distributors
1. Producer Association, Indonesia
The Maluku Indonesian Handline
Yellowfin Tuna Fishery
2. Producer Association, Philippines
Philippine Small-Scale Yellowfin Tuna
(Thunnus albacares) Handline Fishery
3. Producer Association, Australia
Australia Eastern Tuna and Billfish
Fishery (albacore tuna, yellowfin tuna,
bigeye tuna and swordfish)
4. Producer Association, Maldives
Maldives pole & line skipjack tuna
5. Producer association, Japan
Katsuo Ippon-zuri Gyogyo albacore
and skipjack pole and line fishery
6. Producer Association, New Zealand
New Zealand albacore tuna troll
7. Producer Association, Indonesia
Indonesia pole-and-line and handline,
skipjack and yellowfin tuna of Western
and Central Pacific archipelagic waters
8. Producer Association, Japan
Fukuichi Western and Central Pacific
Ocean longline bigeye, yellowfin and
albacore tuna
9. Producer association, OPEGUI,
Spain
North Atlantic albacore artisanal
fishery
10. Producer Association, Mexico
Northeastern Tropical Pacific Purse
Seine yellowfin and skipjack tuna
fishery
11. Producer Association, Parties to the
Nauru Agreement
1. Tuna manufacturer, French
Polynesia.
French Polynesia albacore,
yellowfin and swordfish longline
fishery
2. Tuna manufacturer group, Fiji
Fiji Albacore, Yellowfin and
Bigeye Tuna longline
3. Tuna manufacturer, Japan
Japanese Pole and Line skipjack
and albacore tuna fishery
4. Tuna Manufacturer, China
Kiribati albacore, bigeye and
yellowfin tuna longline fishery
5. Tuna manufacturer, Indonesia
PT Citraraja Ampat, Sorong pole
and line Skipjack and Yellowfin
Tuna
6. Tuna manufacturer, Taiwan
Tuna Alliance Atlantic albacore
longline fishery
7. Tuna manufacturer, China
Pacific and Indian Ocean longline
tuna and swordfish fishery
8. Tuna Manufacturer, Japan
Usufuku Honten Northeast Atlantic
longline bluefin tuna fishery
9. Tuna manufacturer, Spain
Echebastar Indian Ocean purse
seine skipjack tuna
10. Tuna Manufacturer, Japan
Owasebussan Co. Ltd. North
Pacific Longline Fishery for
Albacore, Yellowfin, & Bigeye
Tuna
11. Tuna manufacturer, Spain
1. Distributor, Luen Thai, China
SZLC CSFC & FZLC FSM EEZ
Longline Yellowfin and Bigeye
Tuna
SZLC, CSFC & FZLC Cook
Islands EEZ South Pacific
albacore, yellowfin and bigeye
longline
MIFV RMI EEZ Longline
Yellowfin and Bigeye Tuna
2. Distributor, Trimarine,
Singapore
Eastern Pacific Ocean tropical
tuna - purse seine
(TUNACONS) fishery
Solomon Islands longline
albacore and yellowfin tuna
fishery
Tri Marine Pacific Ocean
longline tuna fishery
Tri Marine Western and Central
Pacific Skipjack and Yellowfin
Tuna
Tri Marine Atlantic Albacore
longline fishery
Solomon Islands skipjack and
yellowfin tuna purse seine and
pole and line
3. Distributor, Dongwon, Korea
DFC/HEC Western and Central
Pacific longline bigeye,
yellowfin and albacore tuna
fishery
Pan Pacific yellowfin, bigeye
and albacore longline fishery

PNA Western and Central Pacific
skipjack, yellowfin and bigeye tuna
purse seine fishery (FAD and non-FAD
sets)
12. Producer Association, Ecuador &
Panama
Eastern Pacific Ecuador Purse Seine
Tropical Tuna Fishery (FSC and FAD
set fishery)
13. Producer Association, Spain
Sant Yago TF Unassociated purse seine
Atlantic yellowfin tuna fishery
14. Producer Association, Hawaii USA
Hawaii longline swordfish, bigeye and
yellowfin tuna fishery
15. Producer Association, France
SATHOAN French Mediterranean
Bluefin tuna artisanal longline and
handline fishery
JC Mackintosh Greenstick,
handline and fishing rod bluefin
tuna fishery
12, Tuna manufacturer, Spain
AGAC four oceans Integral Purse
Seine Tropical Tuna Fishery
AGAC four oceans Integral Purse
Seine Tropical Tuna Fishery
AGAC four oceans Integral Purse
Seine Tropical Tuna Fishery
AGAC four oceans Integral Purse
Seine Tropical Tuna Fishery
US Pacific Tuna Group Purse
Seine FSC and FAD Set Fishery
4. Distributor, Itochu, Japan,
Korea
SI WCPO skipjack and
yellowfin tuna purse seine
fishery
TTKV WCPO skipjack and
yellowfin tuna purse seine
fishery
5. Distributor, FCF, Taiwan
WPSTA Western and Central
Pacific Skipjack and Yellowfin
Purse Seine Fishery
Nauru skipjack, yellowfin, and
bigeye tuna purse seine fishery
Table 2: Fishing job identifiers found in tuna vessel and labour data on the MSC website
(fisheries/msc.org as of February 2, 2023):
Fishing employers were identified
(vessel owners or operators)
For:
Represenng a poron of crew
from an esmated 68,773
populaon:
On the vessel lists
1291 tuna vessels
40%
34,902 tuna fishing crew members
51%
In the labour statements
1238 tuna vessels
38%
37,353 tuna fishing crew members
54%
Fishing labor jurisdictions or
authorities were identified for the
vessel workplaces
1617 tuna vessels
50%
29,364 tuna fishing crew members
43%
Any example is provided of a vessel
practice for mitigating labour abuse.
1017 tuna vessels
31%
33,538 tuna fishing crew members
49%
Table 3: Vessels tuna fishers have reported for forced labour that are currently listed to MSC
tuna certificates
Vessel name:
Vessel flag:
MSC
Fisheries
certificate:
Violation and date:
Date:
Source:
Win Star 636
Taiwan
30076
Missing observer
2020
https://www.apo-
observers.org/observer-
safety/misses/
Sea Queen
USA
31564
Civil suit by crew to the
vessel owner based on
violations of the Trafficking
Victims Protection Act
2018
https://www.justice.gov/cr
t/page/file/1360366/downl
oad

Zhong Da 2
Fiji
31349
Fisher testimonials of forced
labor were published by the
Indonesia Migrant Workers
Union, Serikat Buruh Migran
Indonesia (SBMI) and
Greenpeace
2019
https://www.greenpeace.o
rg/usa/news/new-
testimonials-suggest-
modern-slavery-for-
southeast-asian-migrant-
fishers-working-at-sea
Hangton 115
Fiji
31349
Fisher testimonials of forced
labor were published by the
Indonesia Migrant Workers
Union, Serikat Buruh Migran
Indonesia (SBMI) and
Greenpeace
2019
https://www.greenpeace.o
rg/usa/news/new-
testimonials-suggest-
modern-slavery-for-
southeast-asian-migrant-
fishers-working-at-sea
Chin Chun
#12
Vanuatu
In
assessment,
Tri Marine
Pacific
Ocean
longline
tuna fishery
Fisher testimonials of forced
labor were published by the
Indonesia Migrant Workers
Union, Serikat Buruh Migran
Indonesia (SBMI) and
Greenpeace
2019
https://www.greenpeace.o
rg/usa/news/new-
testimonials-suggest-
modern-slavery-for-
southeast-asian-migrant-
fishers-working-at-sea
Fwu Mann
#88
Taiwan
In
assessment,
Tri Marine
Pacific
Ocean
longline
tuna fishery
Fisher testimonials of forced
labor were published by the
Indonesia Migrant Workers
Union, Serikat Buruh Migran
Indonesia (SBMI) and
Greenpeace
2019
https://www.greenpeace.o
rg/usa/news/new-
testimonials-suggest-
modern-slavery-for-
southeast-asian-migrant-
fishers-working-at-sea
Shin Jaan
Shin
Taiwan
In
assessment
Tri Marine
Pacific
Ocean
longline
tuna fishery
Fisher testimonials of forced
labor were published by the
Indonesia Migrant Workers
Union, Serikat Buruh Migran
Indonesia (SBMI) and
Greenpeace
2019
https://www.greenpeace.o
rg/usa/news/new-
testimonials-suggest-
modern-slavery-for-
southeast-asian-migrant-
fishers-working-at-sea
Discussion:
People harvest tuna from the sea. In a genuine surprise, the tuna data collected for this study
seem to indicate that fishers who are reporting forced labour today are not heard by the Marine

Stewardship Council. The standard-setter lacks a channel into its own data which would allow it
to detect labour violations on vessels in its program. The prevalent absence of fishing job
identifiers in the tuna data raises a question about the MSC’s conceptual framework for
protecting fishers from labour violations. Upon close examination of this data model, it appears
to be a client-centered data model (not fisher-centered9) with a design less in step with the notion
of preventing forced labour in fishing and more in step with the notion of disconnecting
ecolabeled products from market risks.
Opaque sustainability reporting serves to disconnect a business from corporate problems and
violations which are widely reported by external sources, according to scholars in the rising field
of counter-accounting, and this is achieved by employing neutralization techniques like “head in
the sand,” “self-proclaimed green leadership,” “wait and see,” or “start of a new era” (40). These
techniques can be distinguished by the language used and the extent that statements made by
firms are coupled to, or decoupled from, their company’s actions (41). Certification is very often
the strategy that businesses choose for externalizing a sustainability problem, particularly in low
price sensitive markets with a fairly large informed-consumers market and low ratio of
certification cost to production cost (42). That is because certifications establish a pooling
equilibrium where all participating firms choose the same claim and their results are pooled,
which creates the power to change market perceptions without necessarily increasing the
transparency of specific operations or revealing the different strategies of the firms (43). One
firm could take substantial action and another only a symbolical adoption intended to do only the
bare minimum for the same result (44).
From the perspective of these scholarly insights, the MSC’s current data model for fishing labour
might be characterized as a ‘head in the sand’ or ‘don’t ask/don’t tell’ neutralization proposal
that is being marketed as the ‘start of a new era’. The data overall paint a better picture of tuna
middlemen than tuna fishers and their employers. The Marine Stewardship Council has recently
codified procedures which will reproduce similar data going forward due to (at least) three
procedural omissions which could place its eligibility requirements in conflict with the notion of
protecting fishers from fishing labour violations. The first is the omission of a firm rule that
vessel owners must be identified. This omission functions like a hidden tunnel in the program.
Approximately half of the fishing jobs could not be traced in the MSC tuna data because
certificate-holders were not required to identify the fishing employers, and there are many more
consequences.
The second is the omission of a requirement for certifiers to screen vessel and vessel owner
names against highly-publicized lists of implicated vessels such as the Notice of Sanctions
Actions published on the Federal Register of the United States, which identifies individuals and
entities that are sanctioned for serious human rights abuse in their fishing operations (45). There
are many such lists, and due to this omission, implicated vessels can join the program
undetected. Tuna buyers and consumers could become complicit and misled. The third is an
9 The word client appears 430 times in the ecolabel’s process documents and the word fisher appears 44 times: MSC
Chain of Custody Standard, Default version 5.1 2023 (client 7, fisher 0), MSC Fisheries Standard v3 2022 (client 48,
fisher 3), MSC Fisheries Certification Process v2.2 2020 (client 201, fisher 7), MSC General Certification
Requirements v2.4.1 2019, MSC Labour Eligibilty Requirements v1 2022 (client 10, fisher 0).

omission from the labour statement template and its disclaimer. The MSC is aware, from its
research (46), that the majority of certificate-holders in the program are not vessel owners. Its
tuna data show that few certificate-owners are vessel owners. The MSC should state this
knowledge clearly in the template and its disclaimer, as a default. Due to this omission, the
market could misperceive10 that vessel conditions were closely examined and the effect for
fishers is potentially less detection and assistance than ever, if they experience egregious abuses.
These findings raise questions about what it means for fishers when consumers buy ecolabeled
tuna made from forced work but thinking that the logo means it was fished with respect for
human rights. What happens for fishers when a supermarket decides not to perform human rights
due diligence because they think it has already been done for certified tuna? What happens for
fishers when a tuna distributor gives their customer an MSC certificate number as proof of
meeting their human rights policies, or a government creates a fast-track for ecolabeled tuna
imports, because they think the logo stands for good fishing jobs? If a fisher comes forward with
a forced labour case, what happens to the outcome when their employer denies it and shows a
certificate and disqualification procedures as their proof?
Conclusion:
The Marine Stewardship Council logo is prominent in nearly every supermarket in the UK where
it is headquartered. The standard-setter has established the sustainability agenda for the seafood
sector since the 1990s without substantially changing its Fisheries Standard in scope, even as
norms shifted well beyond a single species-based definition of sustainability to include the
ecosystem, climate and social priorities. In light of fishing labour controversies which have
grown exponential in number (47) when the MSC was revising its Fisheries Standard in 2022, it
might have cited Convention 188 on Work in Fishing to direct attention. When codifying its
Labour Eligibility Requirements in 2022, it might have required its clients to perform human
rights due diligence11 (48-49). It might have revised its labour statement template to be more
educational for certificate-holders about what they can do to prevent forced labour in fishing12,
for example by adding citations to the UN Guiding Principles on Business and Human Rights,
C188, ILO core labour conventions, UN Law of the Sea, Code of Conduct for Responsible
Fisheries (social factors) and ILO guidelines to promote decent work in fishing. However,
10 The Marine Stewardship Council describes its Fisheries Standard as a set of requirements for sustainable fishing,
which could be construed to mean that vessel practices for fishing must meet MSC requirements which is not the
case.
11 The business duty “to address adverse human rights impacts with which they are involved, for their prevention,
mitigation and, where appropriate, remediation” entered force in 2011 when the U.N. Guiding Principles on
Business and Human Rights (UNGP) (11) were adopted by the United Nations Human Rights Council in Resolution
17.4. Its legal framework is the 2003 Protocol to Prevent, Suppress and Punish Trafficking in Persons Especially
Women and Children of the United Nations Convention against Transnational Organized Crime was ratified by 180
countries in 2003. The UNGP “protect, respect, and remedy framework” has established a universal human rights
yardstick for all business concerns that is a true departure from, and has replaced, previous notions of corporate
social responsibility where companies could voluntarily determine how to behave in a socially responsible manner.
12

instead, the Marine Stewardship Council published a Sustainable Tuna Handbook (2022). It
stated “concerns about the scale of forced labour and human rights issues in tuna supply chains”
and that “the best way for tuna buyers to significantly reduce exposure to the above risks [of
forced labour in fishing] is to choose MSC certified tuna.” (page 6). This is an underwhelming
response to a major challenge of the times by a powerful and influential organization in the tuna
sector.
In conclusion, these results have shown that the Marine Stewardship Council has established a
very low standard of care for fishing labour on tuna vessels, and potentially lower than the law
allows. The ecolabel announced that 59% of the global wild tuna catch comes from MSC
engaged fisheries, or 2,969,000 metric tonnes in April 2023 (50) and confirmed its influence.
More research is needed to increase the visibility of tuna fishing jobs on certified vessels. More
research is needed to establish the labour risks that fishers experience on vessels operating on the
High Seas. Scholars might use this database to pursue new knowledge about fisheries
transparency and beneficial ownership in the tuna fisheries sector. Policy-makers should regard
product assurances with caution when the businesses making the product are not identified.
Materials and Methods:
A database was built from tuna vessel, catch, and labour data that were present on the website of
the Marine Stewardship Council (fisheries/msc.org) on February 2, 2023. It is provided in
Supplemental Materials. Vessel lists and labour statements were downloaded in February 2023
and are available upon request. Readers may also confirm the data with a web archives reader.
The database elements and relationships are summarized in Table 4.
Table 4: Database Elements and Relationships
Database elements
Relationships
Certificate and client identifiers: Name and
number of the tuna fishery certificate
(hyperlinked), Ecolabel client, eligibility dates
and certifier ID
Certificate coverage by ocean(s) and species, Fishery
jurisdiction, Client identity, Client group composition &
transparency
Vessel workplace identifiers: Vessel name,
Gear type, Flag State(s), Vessel registration
number with a fishery authority, Call sign
Labour jurisdiction per vessel and on the certificate, Vessels’
legal standing to fish with the fishery authority, Discrepancies
between vessel identities on the certificate versus the vessel
registry of the fishery authority, Data coverage per criterion
Fishing employers: Vessel owner and/or
operator
Number of vessel employers per certificate and data coverage,
Number of fishing jobs per certificate, Differentiation of
fishing employers from post-harvest entities in the client
groups

Ecolabeled tuna catches: Annual catches by
certificate number, year, and species names
Sum of catches for each certificate and for the cohort, Catches
per vessel and labour criteria
Labour statement content: Employer names,
Labour jurisdictions and authorities, Crew
origins and recruitment methods, Contract
terms to prevent forced labour, Child work,
Company policies and practices to mitigate
egregious abuses
Data coverage per criterion (present, absent or partially filled
data) for each certificate and summed for the cohort, Number
of fishing jobs left out per criterion due to absent data,
Volume of catch certified on the basis of absent data,
Significance of the data coverage relative to ecolabeling
warrants of ‘good jobs’ and mitigated egregious labour abuse
in certified fisheries
Fishing jobs were enumerated from the tuna data by assigning a fishing crew value to all
certified vessels according to the fishing gear and size described in the certification documents.
These values were 15 crew members for a distant water longline vessel, 5 crew per small
longline vessel, 28 crew per purse seine vessel, 30 crew per pole and line vessel, 20 crew per
handline vessel, and 3 crew per troll vessel. The values were researched in literature published
by the Secretariat for the Pacific Community on tuna vessels and they were cross-checked with a
tuna monitoring-control-surveillance specialist. Data coverage was assessed on the basis of data
availability, not quality, and was measured as present, partially present, or absent.
Initially, the intention was to replicate the analysis by Tindall et al. (51) using the data categories
they described. However, the data were substantially different and the methods a poor fit.
Authours of that study said that 32% of the labour statements in their review were submitted
directly by the vessel owners, for example, while approximately 4% of tuna labour statements
were submitted directly by vessel owners. Furthermore that study followed a methodology which
involved splitting the mechanisms of labour protection from the businesses and authorities
responsible for labour protection13. That approach was rejected on grounds that splitting could
misrepresent that fishing labour practices are ‘voluntary’ where they are mandatory and involve
specific roles and duties for business and flag states that are defined in law.
Due to information gaps in the database, a decision was taken to search and fill the names of
vessel owners and operators from government vessel registries that included the Western and
Central Pacific Fisheries Commission (WCPFC), Inter-American Tropical Tuna Commission
(IATTC), International Commission for the Conservation of Atlantic Tunas (ICCAT), and the
Indian Ocean Tuna Commission (IOTC). This online search, as well as the search for fisher
reports of forced labour, was kept intentionally simple to demonstrate that it could be done
without requiring special skills or training.
13 The absence of flag state laws and authorities was considered a negative outcome in the current research. In
contrast, the Tindall et al authours appeared to see it as a positive outcome that MSC labour statements “confirmed
the overarching flag state responsibility for labour across fisheries although the flag state for all vessels was not
always stated”. It was considered a negative in the current research because the actual question in the labour
statement template asks certificate-holders to state the responsibility for labour regulations and to specify the flag
state authorities (question 2).

Acknowledgement: Humanity United and The Freedom Fund are acknowledged for funding
this research in its entirety and for providing excellent peer review throughout it. Margo
Prebenda and acknowledged for helpful comments. Agnieszka Fryszman is acknowledged for
providing an interpretation of legal significance.
Funding: This research was provided by grant FL12354/22ER to KN from Humanity United
and the Freedom Fund.
Competing interests: The author declares that they have no competing interests.
Data Availability Statement: The database is provided with three sheets which include (1) the
vessel data collected from tuna fishery certificates at Fisheries/msc.org, (2) a second version of
the vessel data containing vessel owner names and other identifiers collected in a public search,
and (3) an analysis of data coverage with catch and labour data and counts.
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Supplementary Files
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MSCTunaVesselDatabase2023.xlsx