Published in China Dialogue

Hong Kong is synonymous with seafood. Every night, tourists pile into the famous seafood restaurants of Sai Kung, Lei Yu Mun and Lamma Island. They pick their dinners from gurgling glass water tanks stacked from floor to ceiling, teeming with a colourful array of marine life.

This, they’re told, is an authentic local experience. But what they might not realise is that the fish on their plates has travelled just as far to get there as they have.

Locals do love their seafood: Hong Kong people place second in Asia only to the Japanese in terms of seafood consumption. But less than 10% of what they eat is pulled from the overexploited waters of the Pearl River Delta. Instead, a unique mix of history, trade links and culture have made this Special Administrative Region the global hub for the destructive and often illegal, but incredibly profitable, Live Reef Fish Food Trade (LRFFT).

According to a report published recently by the University of Hong Kong’s Swire Institute of Marine Sciences, ADM Capital Foundation and the WWF Coral Triangle Program, popular wild-caught reef fish species could even disappear from our plates within our lifetimes. To avoid this, they say, immediate action needs to be taken all along the supply chain. Locally, that means reining in Hong Kong-registered vessels that illegally take live reef fish from Southeast Asia and then smuggle them via Hong Kong into mainland China.

A Tanka boat woman sculls her boat through the waters of Aberdeen Harbour. Reef fish are smuggled via Hong Kong into mainland China

Endangered species

“The rate at which we are taking reef fish from our oceans, including juveniles, is simply not sustainable,” says Dr Yvonne Sadovy, a professor of biological sciences at Hong Kong University and lead author of the report.

The popular Napoleon wrasse, an apex predator in its natural environment, is already listed as endangered by the International Union for Conservation of Nature, and Sadovy says the camouflage grouper should now be considered threatened as well.

The species targeted by the trade are under immense pressure, but they are not alone.

Cyanide fishing, which sees concentrated sodium cyanide squirted onto reefs in order to stun fish, is widespread in the LRFFT. These toxic chemicals kill coral polyps and algae as well as other collateral damage to fish species, turning swathes of the Coral Triangle area – a global centre of biodiversity hailed as the “Amazon of the seas” – into marine deserts.

The coral triangle is home to 76% of all known coral species and many types of reef fish. Source: thecoraltriangle.com/Google Maps

Legal loopholes

Source countries have awakened to this threat and have sought to stamp out or contain the trade. Sadovy explains that Pacific island countries such as Fiji, Palau and the Seychelles reversed their positions on the LRFFT after it began to rapidly expand in the 1980s and 90s.

“They saw that too many fish were being taken too quickly and saw rapid declines as a result,” she says, adding that these countries objected to the widespread use of cyanide, feeding target species other reef fish as they awaited transportation in sea pens, and the bribery and corruption that always seemed to follow in the trade’s wake.

Sadovy estimates that only about 40% of the cargo imports on live fish carriers will be legitimately marketed in Hong Kong, and even some of that is illegally sourced. The rest is secreted across the border to mainland China through a network of smuggling routes at sea, on the road, and in the air. The subterfuge pays off.

By bringing the fish to Hong Kong first, sometimes holding them temporarily in nearshore aquaculture zones, traders evade the steep 17% tariff levied on imports into the mainland, and slip straight into a market of 1.3 billion people. 

Only 40% of the cargo imports on live fish carriers will be legitimately marketed

Most live reef fish passing through Hong Kong today come from the Philippines or Indonesia. In both places, the seaborne export of live, wild-caught reef fish is illegal but enforcement is lax, due to a lack of resources and huge sea areas that need to be patrolled. When boats from Hong Kong pull into Indonesian waters to collect their shipments, they do so under the guise of receiving cultured rather than wild-caught fish, facilitated by locals who stand to profit.

Hong Kong, a modern metropolis with overflowing coffers and a relatively small sea area, could easily address this problem. But owing to an outmoded legal loophole, this trade, technically illegal at both source and destination, is able to operate with virtual impunity.

Workers at Aberdeen Wholesale Fish Market during the midafternoon lull. Reef fish are available in the market

All “marine fish” brought into Hong Kong, which are by definition dead, must be marketed through the territory’s Fish Marketing Organisation (FMO); and incoming cargo ships, like anywhere else in the world, need to present manifests to customs authorities. But live fish arriving by sea or by air are exempted from reporting to the FMO by omission in relevant laws drafted before the LRFFT began to flourish, since they are not classified as “marine fish.”

“Traders, transport and logistics carriers are allowed to exploit a vacuum created by inadequate and outdated regulation, loopholes in the law and lax enforcement of live seafood trade into, within and through Hong Kong,” says Dr Geoffrey Muldoon, senior manager with the WWF Coral Triangle Program and co-author of the report.

Although a 2007 update to the law demands large vessels declare live fish in their holds within 14 days, this is breached more often than observed. Unlike other vessels, fishing boats are not tracked or required to report their entry and exit to relevant departments. For unknown reasons, they are exempted by the director of the marine department, a hangover from the days when the constant ebb and flow of the local fishing fleet rendered such oversight an impractical burden on fishermen and officials alike.

Muldoon, Sadovy and the report’s other co-authors are calling for an end to what ADM Capital Foundation environmental director Sophie Le Cure calls Hong Kong’s “culture of deliberate tax avoidance, poor governance, and lack of transparency in the marketing and transport of live fish.”

Authorities must make common sense changes to laws on the import of live fish, improve vessel reporting and traceability, and better monitor and control live fish carriers, they say. Additional measures such as requiring windows on polystyrene transport containers and introducing commodity codes for more species could also broaden oversight.

Reef fish is the new shark

Retailers and consumers can also help by supporting sustainable fisheries and ensuring that the Napoleon fish they buy is legally licensed.

“We are not talking about not eating fish at all. What we are talking about is not eating so many wild fish that we destroy their populations,” says Sadovy. “We need to know where seafood comes from, that it’s legally sourced, safe to eat, and that it is sustainable. We need legal trade to ensure sustainable trade.”

Squaretailed groupers and coral trout do not enjoy the same public profile as sharks or elephants, but progress made recently by anti-ivory and shark fin campaigners is cause for optimism. In response to awareness campaigns and a government clampdown on official banquets, consumers in mainland China have turned away from shark fin soup, according to another recent report from advocacy group WildAid. As a result, consumption of shark fin soup in China no longer constitutes the single greatest threat to sharks.

The government of Hong Kong has also clamped down on illegal Napoleon wrasse sales, which have dropped by two-thirds over the last year, and public interest in the species is said to be growing.

“We can do more than just sharks,” concludes Stan Shea, marine programme director at the conservationist group BLOOM Hong Kong and another of the report’s co-authors.

“But we need the momentum. We need your help.”