The Federation of European Aquaculture Producers (FEAP) warned the European Commission that its recently released overview report on farmed fish welfare overlooks critical scientific and operational challenges.
While the federation said it supports advancing good farming practices, it stressed that the document fails to address the practical realities of European fish farming.
According to FEAP, welfare needs are not homogeneous across different species, production systems or life stages. It noted that the commission failed to acknowledge how these biological differences, such as the varying oxygen requirements of rainbow trout and sturgeon, affect its conclusions.
Significant scientific uncertainty also surrounds stunning technologies, with a lack of academic consensus on measurement and interpretation. The federation cautioned against premature regulatory requirements, stating that electric stunning is not universally effective and sometimes leaves fish immobilised but not insensate.
FEAP noted that unlike terrestrial livestock, fish stunning and slaughter in most European Union member states occur on farm premises rather than in dedicated slaughterhouses. This on-farm practice imposes severe limitations on implementable technologies and poses worker safety risks on small vessels or in open-air fields.
Furthermore, it remarked that advanced stunning systems are cost-prohibitive for thousands of small enterprises, and percussion is technically impossible for small portion-sized fish. Traditional pond farming, which includes centuries-old coastal lagoons in Italy, Greece and Spain, was also overlooked in the report.
Addressing fish sentience, the federation argued that differences exist within species, noting that domesticated carp or salmon show different stress responses to wild conspecifics.
It also urged the commission to consult Eurobarometer surveys rather than relying almost exclusively on studies by non-governmental organisations to understand public concern.
The federation stressed that the core issue facing the sector is the lack of reliable documentation measures rather than unacceptable current practices. It added that there is an urgent need to separate mature scientific knowledge ready for legal requirements from topics that still require years of research.
"FEAP fully supports science-based welfare improvements, but they must be practical, achievable, and proportionate," said Javier Ojeda, FEAP Secretary General.
"Legislation that ignores farm-level realities will not improve fish welfare; it will simply drive production outside the EU, where standards may be lower," Ojeda added.
"We need to focus on developing reliable documentation measures before imposing unworkable legal demands."