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How exporting fish meal starves source countries for global profit despite attendant risks to environment

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In order to produce food for livestock, including pigs in China, Vietnam and a number of other countries, the largely Chinese-owned fish meal and fish oil factories in The Gambia starve people of one of the cheapest available sources of protein and also dismantle their source of income and livelihood.

These factories are supported by the Gambia government in the form of tax breaks, and in the case of Golden Lead, gentlemanly handling of allegations of unlawful conducts including bribing public officials and releasing untreated waste into the sea without environmental approval.

This investigation has found that though the National Environmental Agency certifies factories’ ‘untreated’ liquid waste being discharged into the sea safe for marine life, studies in both Gambia and Mauritania point to the contrary.

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The fish meal and fish oil factories are a magnet for controversies in communities where they operate along The Gambia’s coastline. All the three factories in the country are established on beaches, less than 100 meters from the shores. These beaches have a lot of lodges, restaurants and bars which support the local tourism industry. At the peak of their operations, the businesses complain of stench from the factories, often chasing away their customers.

On June 15, 2017, business owners and environmental activists protesting against the Chinese-owned Golden Lead factory and officials from the Ministries of Fisheries, Environment and the National Environmental Agency, gathered at the conference hall of the Ministry of Environment to find a sustainable solution. According to the minutes of the meeting seen by The Republic, a former Permanent Secretary at the Fisheries Ministry, Dr Bamba Banja, characterised the foul stench from the factory as the “scent of money”.  But money that leaves Gambia’s shores. Dr Banja was sentenced to a 2-year jail term for receiving a D100, 000 ($1, 410) bribe from the Golden Lead for releasing their fishing boat caught for fishing in the wrong zone in September 2018.

In 2021, a violent protest erupted in Sanyang, a coastal fishing town home to Gambia’s third biggest fish landing site. Dozens of young people, who would later be charged with arson by Gambia police, took to the streets, burning tyres— after setting part of the community’s only fish meal and fish oil factory ablaze.

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The local newspapers reported the protest was in response to the killing of a Gambian national by a group of fishermen from Senegal. A local environmental activist, Muhammed Jabang, said the Senegalese arrive in their community from December to June, when fish meal and fish oil factories are in operation, to supply them with fish. What was not apparent— and not mentioned in the news articles— the protest was a manifestation of grievances of a people who felt they were not benefiting from their resources being exploited by “foreigners”.

“In Sanyang only 5 people are employed at the fish factory,” Muhammed Jabang, one of the activists who have been protesting for the closure of Nessim, told journalists at the Sanyang Fish Landing Site.

“Those who bring the fish, they are foreigners. Most of the agents are foreigners. The owners of the fish meals and fish oil factories are foreigners.”

Not only are the essential staff of fish meal and fish oil factories foreigners, the Gambians employed in the sector are mostly part-timers. The factories only operate for 6 months— December to June when night fishing opens in the country. The 6-month closure of night fishing is a measure put in place to, among other reasons, allow fish to regenerate. The local fishers who use much smaller boats neither have the capacity to fulfill the demands of the factories nor compete with the Senegalese boats.

Although it is difficult to establish the exact number of boats from Senegal that supply fish to the factories, sources interviewed for this story placed the number between 200 to 400 boats every season. The boats from mainly St Louis, Joal and Mbour in Senegal descend on the coastal fishing communities. The boats, measuring 25 meters length and about 7 meters width, have the capacity to land 1000 trays of fish, with each carrying at least 50kg of fish, mostly bonga, sardinella. With a tray of fish costing D800, ($11.44) the fishermen can make D800, 000 ($11,440) a day.

The artisanal fishing sector in The Gambia is scarcely regulated. Section 14 of Gambia’s Fisheries Regulation amended in 2024 requires the authorities to issue licenses to artisanal fishing boats before going to sea. This clause has been dormant as both local and Senegalese artisanal fishing boats are not registered by the Department of Fisheries.

During their six-month stay in Gambia to fish in the country’s waters, Senegalese fishermen, who are mostly paid in CFA, typically only pay a D3500 ($50.05) seaworthy certificate issued by the Gambia Maritime Administration (GMA). In 2022, the GMA issued seaworthy certificates to at least 282 boats from Senegal, according to the data provided by the GMA. In 2023, this number declined to 168 artisanal boats. It is unclear what explains the decline.

But lack of a licensing regime for the artisanal boats by the Department means the GMA could only register those who reported themselves or those they come across during their routine inspections at landing sites.

“There is no system in place for proper monitoring…,” said a senior official of the fisheries ministry who does not want to be named.  “The Ministry and the Department (of Fisheries) are focussing on the industrial sector due to its lucrative nature, and neglecting the artisanal sector…”

According to sources at the Department of Fisheries, the factories are only required to pay a yearly half a million dalasi fee.

“I think that 85% of the benefits of the fish meal and fish oil factories are leaving the country,” said Dawda F. Saine, a marine biologist and the secretary general of the National Association of Artisanal Fisheries Operators (NAAFO). 

Mirroring the situation in the Gambia, a study by the Food and Agriculture Agency of the United Nations published in 2022 found that fishmeal factories encourage an “over exploitation” of bonga and sardinella in host countries, while their economic benefits are largely shipped outside.

The raw materials used by the fish meal and fish oil factories are not fish offal – the traditional inputs of fishmeal factories – but freshly caught and human consumption-grade flat and round sardinella and bonga fish, the cheapest source of protein for populations in Gambia, Mauritania and Senegal. Several studies have already shown these species are overexploited.

Studies by the Food and Agriculture Organisation of the United Nations in 2018 and 2022 have linked production of fish meal and fish oil factories to the overexploitation of small pelagics in these three countries. 

In the majority of communities in Senegal, Gambia and Mauritania, fishing is largely a men’s trade while women sell their catch. With the buying power of the factories in the equation, a lot of fishers opt for the factories which guarantee quick money and less risk of spoilage. 

In The Gambia, the majority of suppliers of factories are from Senegal, though local Gambian fishermen sell them their excess catch. In preparation for the opening of the night fishing, agents working with the factories go to Joal, Mbour and St Louis in Senegal to recruit fishermen. Many people interviewed for this story claimed the fishermen are sometimes pre-financed up to about CFA3m ($4,994), and provided with engines, boats and nets.

Their presence in the water creates competition for local fishers which drives scarcity. “The fish meal plants are encouraging pressure on the small pelagics,” said Saine. “…It is the scarcity that is driving the price.”

This is felt at the markets in Gambia. A basket of sardinella and Bonga has increased by at least 6 fold— from $6 to $29— from 2019 to 2024, hurting the profit margin of women vendors. “I prefer fish to meat, as do my children, but we can’t afford it anymore,” said Sainabou Touray, a Gambian fish consumer. And like for many consumers, cheap imported chickens become the preferred options.

Elsewhere in Mauritania and Senegal, the story is the same. Sohna Fye is a fish vendor at the Soumbédioune fish landing site in Dakar. She is among hundreds of women who source their fish from this landing site. “When I started this fish business five years ago, fish like sardinella, mackerel and bonga were going for as low as CFA 2,000 ($3.20),” she recalls. “But now the same fish goes for as high as CFA 10,000 ($16).”

Gambia has three factories with an average yearly production capacity of 3, 616 tons of fish, according to the data from the Gambia Ports Authority. They mainly export their produce to China, Chile and Vietnam. In Senegal, at least 6 factories are in operation with a yearly production capacity of 12, 000 tons, according to FAO. The numbers are much higher for Mauritania with an increase from 5 factories in 2010 to 35 in 2019. The average daily processing capacity, according to FAO, is 611.5 tons.

In Nouakchott, as in Dakar and Banjul, demand has shot up. Competition between fishing for daily survival of the majority poor and production for fish meal and fish oil has intensified. In Nouakchott, the price of sardinella has increased by 50% in three years, from 10 to 15 MRU— from $0.25 to $0.37.

The price hike of sardinella, according to Ali Muhammed, a fisherman from Nouakchott, is driven by scarcity which is caused by over-consumption. The factories are the major driver. “We used to fish for sardinella near the coast. But now the boats (that supply the fish meals) are competing with us for the yaboye (a local name for sardinella) which they transport to Nouadhibou,” adds Ali, a Mauritanian fisherman. Nouadhibou is the economic capital of the country where the overwhelming majority of Mauritania’s 39 fish meal and fish oil factories operate.

‘Environmental pollution in Gambia’

Environmental protection groups have repeatedly protested against fish meal and fish oil factories in Gambia. The Republic has confirmed with Gambia’s National Environmental Agency that all the fish meal and fish oil factories have a pipe from their factories discharging wastewater into the sea.

In March 2018, activists in Gunjur forcibly removed the pipe discharging waste into the sea from the Golden Lead. In December of the same year, the activists in Sanyang also forcibly removed the pipe at Nessim discharging wastewater into the sea. The pipes were later restored.

In 2017, a sample of waste water collected from Golden Lead and Nessim was tested at a lab in Germany, showing ‘alarming’ high levels of phosphate, Sulphate, and Arsenic in the effluent samples, according to activist and microbiologist Ahmed Manjang. Manjang shared a collection of their test results with The Republic.

“According to our test results, the fishmeal waste coming from Golden Lead is loaded with Arsenic, Phosphate, and Sulphate,” said Manjang. 

“…the sample of seawater collected from the Bolong Fenyo Wildlife Reserve on 22 May 2017, GL and Nessim Fishmeal company are starkly higher than levels necessary for the protection of marine aquatic life.” Manjang, a lab scientist at the country’s referral hospital, Edward Francis Small Teaching Hospital— also leads a local environmental advocacy group in his native Gunjur village. He led several protests against the operation of Golden Lead in his community.

The operation of factories such as fish meal and fish oil requires an environmental approval prior to commencement. In September 2019, a former minister of environment Lamin Dibba told a popular weekly show on Kerr Fatou that the Golden Lead did not conduct an environmental impact assessment during the era of the former president Yahya Jammeh whose administration ended in January 2017. The Golden Lead started operations in 2014 and exported at least three 20-foot containers of fish meal that year, according to records from Gambia Ports Authority. It only got an environmental approval from NEA a year later, in October 2015, according to the environmental watchdog. But even after that, there were still issues. 

In 2017, the NEA dragged the company to court, in a matter that was later settled out of court due to pressure from the Ministry of Trade, for discharging wastewater into the sea without a treatment plant. According to an environmental audit of the institution seen by The Republic, the NEA said the wastewater collected from the “septic tank” at the Golden Lead was found to have “very high biochemical oxygen demand values and therefore cannot be discharged into any environment without prior treatment.” The available evidence shows the factories still do not have a treatment plant.

The Republic has learned the factories employ a process called sedimentation, a pre-treatment method which allows separation of liquid and solid waste. The liquid, filtered through three different tanks, is then released into the sea through waste pipes laid from the factories into the sea. There is very little information on production capacity of the factories. But according to the data quoted in the NEA audit, the Golden Lead produced over 27, 500 gallons of waste water when in operation daily. During the time the factory was not allowed to discharge waste into the sea, waste trucks they hired would make over 5 trips, discharging their waste “indiscriminately” in the outskirts of Gunjur.

“The results from the septic tanks indicate a high level of turbidity… and also suspended solids… The hardness of the water was very high as well as the total coliform or the level of bacteria in the wastewater. This was to be expected as the wastewater contains very high levels of protein from the fish processing and as such will need to be treated before disposal,” said the Agency in its review of the environmental issues at the Golden Lead. A study conducted in Mauritania and published by the Nature Environment and Pollution Technology— an international quarterly scientific journal— in 2023 has also found that the wastewater effluent from fish meal and fish oil factories is not safe to be discharged into marine environments without treatment.

“In general, all analysed parameters have values that exceed the international standards for wastewater, especially chemical oxygen demand, biological oxygen demand values and suspended matter content,” concluded the scientific study.

The last time Gambia’s environmental watchdog received the report of their periodic test of water samples from the factories was May 2024. It shows the waste was safe to be discharged into the environment, according to the Agency’s executive director Dr Dawda Badgie.

“We have a biological way of treating waste… They have about 4 to 5 ponds. Each of those stages has processes. Before the liquid reaches the fourth or the fifth one, it has already evaporated a lot of impurities… Whatever goes out, which is also discharged 200 meters into the sea, is safe based on the tests we are receiving,” said Dr Badgie.

“You don’t need chemicals in your production for this. Natural chemicals are generated during processes,” said Omar Malmo Jr, an activist and an expert in environmental impact assessment.

“The liquid waste should be tested in a lab to meet standards that it’s free from all toxic substances and the facility should have a fish pond to indicate that the final discharged product can cater for life and not be toxic.”

At the beach in Gunjur and Sanyang, a lot of dead seaweeds have washed on the shore. The microbiologist, Manjang, blames it on the discharge of waste into the sea by the factories.

“There is a strong likelihood that the death of the seaweeds is because of the waste water the factories are pumping into the sea,” said Manjang.

Meanwhile, in October 2020, a whistleblower from Golden Lead revealed damning pieces of evidence implicating the factories in a number of bribery scandals. A former permanent secretary of the fisheries ministry Dr Banja would be sentenced for taking a D100, 000 bribe from the factory to release their fishing boat in 2018. Neither the company nor its officials were ever charged.

The whistleblower claimed the factory had a number of insiders at the NEA and Department of Water Resources, the institution that conducts water quality testing for the institution. “Everytime they come for testing, they inform us. We remove the waste from our tanks and put fresh water in it,” said the whistleblower.

Workers without protective gears

The allegation of poor waste management is not all. Staff welfare has been an issue. In their audit, Gambia’s environmental watchdog has observed that in one of their visits to Golden Lead, “none of the staff present wore the required protective gear”. In November 2022, the National Assembly committee on environment found the same thing.

“It was observed that employees are not presented with safety gear, risking their lives. Additionally, the delegation was informed that staff are employed verbally, and no contract signed, with no job security,” said the lawmakers, after visiting the three factories along the coastline.

The study by the FAO recognised a similar impact of operations of fish meal and fish oil factories on the environment in other countries in the region.

“Most of the existing fishmeal and fish oil factories have negative impacts on the health of workers and local communities while also degrading the aquatic ecosystems near their locations,” concluded the FAO report which conducted a detailed study of factories’ operations in Mauritania, Senegal and Gambia.

Weak regulations

Senegal and Gambia have a fishing agreement which allows the French-speaking country to put 250 boats in Gambian waters, from 40 horse power to industrial trawlers. Article 1 of the agreement allows the Senegalese boats to take all their catches home. The Republic has learned that the artisanal fishermen who supply the factories are outside of that arrangement.

The fishermen who are supposed to utilise the agreement are licensed trawlers and boats who fish for local consumption and export. And while the agreement provides a limit of the number of boats allowed to come from Senegal— 250— there is no monitoring mechanism to ensure proper implementation.

A visit to the communities where fish meal and fish oil factories are and conversation with officials and activists show the Gambia government does not take data on the daily quantity of fish processed by the factories.

The fisheries officials stationed on various landing sites in the three coastal communities where the fish meals operate have told The Republic they are not taking records of fish being processed by the fish meal and fish oil factories. Our request for data from the Department of Fisheries went unanswered.

However, the data we received from the Gambia Ports Authority has shown that the three factories have exported 1,346 tons of fish oil and 4, 441 tons of fish meal from 2014 to 2021. This is estimated to be equivalent to at least 28, 935 tons of fresh fish.

“We have made some noise several years ago, through a press conference, to be able to know the data for the fish meal production. We were promised that they will hire people to collect the data but that has not been done until now,” said marine biologist Saine. 

“We are a data deficient country. You need data to inform your conservation measures. Fisheries management should be based on scientific certainty.”

The fisheries Ministry has no specific regulation guiding the operation of fish meals. The fish meals have environmental certificates but there remain serious concerns in their host communities about environmental pollution. And the demand for fish these factories generate is unlikely to be sustainable, bearing in mind the embattled situation of fish stocks the inputs are being sourced from.

‘Tax breaks’

Gambia has three fish meal and fish oil factories all of which are exempted from paying tax, according to a source from Gambia Revenue Authority. The Republic has learned that at least one of the companies, the Golden Lead, did not conduct an environmental impact assessment— one of the requirements for a special investment certificate– before its issuance.

The special investment certificate which was issued by Gambia Investment and Export Promotion Agency (GIEPA) exempts companies from paying customs duties on import materials for the business, corporate tax, withholding tax and in some cases import vat. 

The first, Golden Lead, was established in Gunjur in 2014; Nessim was established in Sanyang in 2016 and JXYG Aquatic Products Limited in Kartong in 2016.

Nessim is owned by Mauritanian nationals, Golden Lead Chinese, while the factory in Kartong is 92% owned by a Chinese. The 8% is owned by a Mauritanian national who serves as the company director.

Our requests for information from the Department of Fisheries, GIEPA and Food Safety and Quality Authority of the Gambia went unanswered until the time of this publication. The fish meal and fish oil factories did not also respond to our requests for interviews.

This article was developed through a mentorship with the Global Initiative against Transnational Organized Crime (GITOC) as part of a capacity building programme with a group of investigative journalists in Mauritania, Cape Verde, Guinea, Guinea-Bissau, The Gambia and Senegal. However, the journalism is fully independent, and the article’s narrative does not necessarily express the views of GITOC.

The Republic

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