“The disease prevention and control rules for listed species referred to in Article 9 (1) of Regulation (EU) 2016/429 shall apply to the categories of listed diseases for the listed species and groups of listed species referred to in the table set out in the Annex to this Regulation.”
In typical EU “language,” the above paragraph takes you on a convoluted journey through regulations, articles, annexes and tables that is not for the fainthearted.
The regulation in question deals with transmissible animal diseases and amends (and repeals) “certain aspects in the area of animal health, i.e. the Animal Health Law.” Article 9 (1) deals with the rules that need “to be applied to different categories of listed diseases” in order to prevent or minimize their threat. The listed diseases, in turn, include one that is of particular relevance to our industry: viral haemorrhagic septicaemia (VHS), plus two others.
If you are persistent—and patient—and are prepared to work hard at obtaining the necessary data, you will eventually get to Commission Implementing Regulation (EU) 2018/1882, and if you next check out the table in the annex, and then examine the listed diseases and species in detail, you will eventually arrive at the entry for VHS. This entry lists numerous fish species as being susceptible to, or potential vectors of, VHS. Among these, we find the following: common carp and koi (Cyprinus carpio) and wrasses—listed as Labridae, i.e., the whole family is listed, not selected species.
Common carp, koi, goldfish (Carassius auratus) and the grass carp (Ctenopharyngodon idella) are also listed under koi herpes virus (KHV), with the first three also appearing under epizootic haematopoietic necrosis (EHN), but the fish that I’d like to concentrate on in this piece (owing to space limitations) are the wrasses.
At close to 560 species, the Labridae is very diverse and its species occupy habitats extending from cold, temperate waters to tropical seas and reefs. It would therefore not appear sensible, or genuinely scientific, to devise a familywide rule regarding their importation into the EU.
Strictly speaking, five species have been highlighted as presenting a threat of VHS to the salmon aquaculture sector: Centrolabrus exoletus, C. rupestris, Labrus mixtus, L. bergylta and Symphodus melops. All of these inhabit temperate waters and can, thus, potentially come into contact with aquacultured salmon and transmit VHS if they are carrying the disease. Consequently, it is logical that preventive measures should be taken against the importation of the species.
However, the regulation lists the whole family, thus lumping in all the tropical species that are traded within the aquarium industry, none of which can survive the conditions under which salmon are cultured. As a direct result of this, consignments of tropical wrasses have been severely impacted over the past few months. Members of Ornamental Fish International (OFI) have reported that shipments, especially those from Kenya, Sri Lanka and the Philippines (and others), have been rejected by EU authorities if they’ve contained any wrasses, irrespective of the species involved.
Such unwarranted action, despite what the regulation might say, is causing significant losses, as the EU wrasse wholesale trade, U.K. excluded, is worth around €2.7-3 million (U.S. $3-3.3 million), which translates to around €5-7 million (U.S. $5.5-7.8 million) at retail level.
The industry has, of course, reacted vigorously to this situation, with OFI writing to the EU authorities, suggesting that they consider:
• a revision of the labrid species list, and
• the reintroduction of “closed system status” for tropical aquaria, taking account of the fact that the species traded by our sector do not (and cannot) pose a threat to the salmon aquaculture industry.
OFI EU affairs officer Nathalie Gamain has been researching the matter in some detail and, on checking the latest scientific evidence, has found that the VHS virus cannot withstand high temperatures, a finding that is in accordance with the World Organisation for Animal Health (OIE) data on the disease.
We, therefore, find ourselves in a similar situation to that which I’ve reported on several times: the Europe-wide ban on the importation of several aquatic plants, even though they can’t survive northern European winters. As far as the wrasses are concerned, large quantities of northeastern Atlantic species are actually being used within the salmon sector as cleaner fish, and these do, in fact, pose a health risk to the salmon. In sharp contrast, none of the labrid species traded within the aquarium industry can pose this problem.
With a little luck and commonsense, the whole matter may be resolved in the near future as Gamain informs me that wrasses have been added to the agenda for the next meeting of the EU Standing Committee on Plants, Animals, Food and Feed (PAFF Committee) to be attended by the European Commission and EU Member State representatives. This meeting was due to be held during April so, at the time of writing, I am awaiting details of the outcome.
I am grateful to Nathalie Gamain, Ornamental Fish International (OFI) EU affairs officer, for keeping me abreast of developments.
John Dawes is an international ornamental aquatic industry consultant. He has written and/or edited more than 50 books and has contributed more than 4,000 articles to hobby, trade and academic publications. He is the editor of the OFI Journal and a consultant to AquaRealm, the trade show that took place June 2017 in Singapore.