India: The Dirty Business of Fishmeal
On November 5, 2020, a team of government investigators arrived to inspect a fishmeal plant named United Marine Products in the Cuncolim Industrial Estate in Goa, India.1 Fishmeal, a protein-rich dark-yellow powder made by pulverizing and cooking wild-caught fish, is used as feed for carnivorous farmed fish like shrimp, salmon, and tuna. The investigators were there to figure out why the plant smelled so bad and how it was disposing of its toxic wastewater.2 For years, local residents had said that the plant was making their air unbreathable and their drinking water deadly.
The stench that often accompanies these types of factories can be more than just a nuisance for people living nearby. It is an indicator of noxious chemicals like ammonia, hydrogen sulfide, cyanide, and methane, which have been known to contribute to serious health problems, including nausea, pulmonary edema, and even death among plant workers and neighbors.3 The worst part of the odor comes from trimethylamine, or TMA, a colorless gas that gives rotting marine creatures their “fishy” smell and was identified in 2021 as “strongly toxic and carcinogenic.”4 The stink also corrodes the local economy by undercutting tourism and scaring away restaurant patrons and beach visitors. As of 2025, more than 285,000 people, including over 6,400 children under the age of 15, live within a mile of fishmeal plants in India.5M
Using ground-penetrating radar, the inspectors who visited the United Marine plant discovered that the plant operators had employed a new and illegal way to dispose of the facility's wastewater.6 They had allegedly drilled hidden boreholes into the ground in a discreet field behind the plant, according to the Navhind Times.7 These holes were probably contaminating groundwater and likely the cause of sick villagers and livestock, the authorities later concluded.
In subsequent days, inspectors visiting other fishmeal plants in the area found a number of problems, including illegal timber used to power boilers, wastewater discharged directly into public rivers or streams, and air pollution reportedly leading to respiratory issues among the local population.8 Although authorities soon announced plans to file criminal charges, impose suspensions, and issue fines, the charges against United Marine Products and most of the other plants were dropped several weeks later, allegedly a result of pressure from politicians and industrial lobbyists, according to local media.9 United Marine said the investigation proved that the allegations of illegal borewells within its premises were unfounded.10
The subterfuge, raid, and weak enforcement at the Cuncolim Industrial Estate exemplified an industry that has become as powerful as it is unregulated. In a little over a decade, India has emerged as one of the world’s biggest producers of shrimp. In 2025, roughly a third of the shrimp eaten in the US and a quarter worldwide came from India.11 Virtually all of this shrimp is grown on more than 100,000 landlocked farms, most of which rely on fishmeal as a feed ingredient.12 Farmed shrimp accounted for nearly a third of fishmeal used globally in aquaculture in 2019.13 This fishmeal is made from fish caught primarily in near-shore waters by hundreds of Indian ships. It is then pulverized, cooked, and turned into flour or pelletized in more than 70 plants spread across the country.
Producing fishmeal in India is a dangerous and dirty business that sometimes sees toxic dumping, illegal fishing, plant explosions, and worker asphyxiations.M Between 2018 and 2024, at least 30 Indian fishmeal plants were involved in a variety of environmental violations and other legal infractions such as tax evasion, using illegal timber to fuel boilers, dumping waste into waterways and boreholes, or inadequate safety protections, according to news reports, government documents, and court filings.14M These plants were also the target of at least 18 instances of civil unrest during this period, including protests that sent hundreds of Indians to the streets in half a dozen cities and villages, with some blockading roads to stop trucks, violently clashing with police, and in one instance, spurring a boycott of local elections.15M
The industrial park in Cuncolim, where inspectors raided plants in 2020, was emblematic of an industry whose misbehavior is less rogue than routine, according to Vijay Prabhu, an Indian lawmaker. For years after the raid, local residents repeatedly protested the plants, leading to a complaint Prabhu lodged in November 2023 with Goa state authorities: “Over the past decade-and-a-half, and particularly in the last four months, the residents of Cuncolim have been subjected to an alarming level of environmental degradation due to unchecked activities of fishmeal plants and fish processing factories.”16
Beyond the problems on land, India’s fishmeal industry also has a spotty record offshore. Many of the ships supplying the country’s fishmeal plants fish illegally or unsustainably. About a third of all fish caught in Indian waters goes into making feed, with plants mostly processing small pelagic fish, which are a species that play a crucial role in the local ecosystem.17 Researchers and ocean conservationists fault this system—which processes large piles of fish inside factories—as unsustainable and wasteful, effectively extracting vital sustenance from poorer nations to produce seafood typically consumed in wealthier ones.
The consequences of this extraction are evident: Two of the key species, Indian oil sardine and Indian mackerel, were classified as “overfished” in Indian waters in a 2021 journal article, meaning they are caught faster than they can reproduce, shrinking the population and reducing its capacity to recover to healthy levels.18M Overfishing has persisted to the extent that some species have been brought to the verge of extinction, as Indian oil sardine—a staple food in southern India—saw a stock collapse in 2016, partially driven by fishmeal production.19M While subsequent stock assessments, including one by India’s Central Marine Fisheries Research Institute in 2024, indicate a significant increase in the biomass of Indian oil sardine and fluctuating increases for mackerel, scientists caution that the boom-bust nature of these fisheries makes it difficult to estimate the longer-term health of these waters.20
Dive deeper — 1 of 3 in this report — Footnotes 21–40
Why the Sea Became a Protein Mine
The science of animal feed—combining corn, soy, grain, and other ingredients like fishmeal to raise livestock faster, bigger, and more nutritionally—was central to the rise of modern civilization.21 Techniques of animal husbandry developed roughly 12,000 years ago in the so-called “Fertile Crescent,” an ancient area stretching from Mesopotamia to Egypt.22 Alongside advancements like irrigation and the plough, the domestication of livestock was essential for humans to create the stable food supply that they needed to settle and eventually to develop cities.23 Shifting from grazing to penning animals required farmers to provide them with balanced diets.24
Historically, marine life itself has experienced a conceptual shift. First, these creatures were animals that served mostly as sustenance for seabirds, marine mammals, and larger predatory fish, and, on a local scale, as food for humans. Next, they were seafood to be eaten by humans on an industrial and global scale. Then, with the rise of the reduction industry, marine creatures emerged as an ingredient in the form of flour, oil, or protein, destined as livestock feed.25 Ocean habitats became calorie factories.
Kristin A. Wintersteen explains how and when the modern world began using the sea as a protein mine.26 In her 2021 book, The Fishmeal Revolution, she chronicles how the Humboldt Current, which is a cold, nutrient-rich upwelling system that runs along the Pacific coast of South America, was reconceptualized from being a living marine ecosystem into a place to extract raw materials. This “revolution,” she explained, converted Peru into the fishmeal superpower it is today, now accounting for roughly a quarter of global production. This historical transformation made fishmeal the key ingredient that helped fuel the post-World War II expansion of industrial chicken, hog, and later fish farming—especially in the US and northern Europe. This shift, which has since extended far beyond the waters of Peru to include the coastline of West Africa, has also severed consumers from the ecological and human costs of production.27
Fishmeal and its rise as a staple feedstock have come with a variety of hidden costs that rarely show up on the balance sheets of the seafood companies that rely on it. These hidden costs, or what economists call “externalities,” are instead paid by the environment and by people who are far from where the seafood gets eaten.28 The oceans also pay an especially heavy and unseen toll from this industry. More than a fifth of all marine life pulled out of the water globally was swallowed up by the feed industry in 2022, according to the UN’s Food and Agriculture Organization (FAO).29 Reduction fishing often relies on purse-seine or trawl nets that can trap large amounts of non-target fish, or bycatch, significantly impacting the ecosystem by removing key prey species.30 As such, the reduction industry represents a stark example of “fishing down the food web,” where fishing shifts toward smaller, less valuable species as larger, predatory fish stocks decline. The true cost of farmed fish is not what appears on the restaurant menu or the grocery store packaging.
Most fishmeal is used by the aquaculture industry. This is ironic since, historically, the global push toward aquaculture has been bolstered by the idea that farming fish on land lessens the need to take so many from the sea. Using fishmeal to feed fish farms, however, has turned this goal upside down, and fish farming is accelerating ocean depletion. The toughest challenge to farming carnivorous fish is feeding them.31 The aquaculture farms that yield some of the most popular seafood, such as salmon, tuna, shrimp, carp, or European sea bass, often consume more fish than they ship to supermarkets and restaurants.32 Before it gets to market, a farm-raised tuna, for example, can eat more than 15 times its weight in free-roaming fish that has been converted into fishmeal.33M
Aquaculture has existed in rudimentary forms for centuries before it became industrialized on a large scale in the 1980s, and it has some clear benefits. Fish farming provides millions of people with year-round access to affordable protein.34 In India, aquaculture is a crucial source of jobs, especially for women.35 In Bangladesh, fish farming has driven an overall decline in the price of fish, making it more accessible for lower-income households.36 Even when feed—including ingredients like soy and fishmeal—and transport to the US are taken into account, some types of fish farming, such as tilapia and Atlantic salmon aquaculture, have lower greenhouse gas emissions per pound compared to beef and pork.37 Farming bivalves, including clams, oysters, scallops, and mussels, is particularly sustainable: These species typically require no feed and use minimal land and freshwater.38 They also produce shells that can function as a form of carbon capture, according to a 2020 Nature Food study.39 As of 2022, roughly a third of global aquaculture did not require external feed inputs.40
Western India is a major hub of the country’s fishmeal industry, especially in Kerala, Maharashtra, and Gujarat, as well as the southern state of Tamil Nadu.M In particular, the city of Ullal, in the state of Karnataka, is home to at least 12 plants, many of which have been the focus of persistent allegations of pollution and environmental violations.41M These plants lacked adequate procedures to remove plastic contamination from fish inputs, and workers observed untreated wastewater, known as stickwater, being dumped into nearby waterways and mangrove fields, according to a report from the Changing Markets Foundation.42
The pollution by this industry has sparked intense pushback. In the state of Tamil Nadu, for example, residents of Pottaloorani village in the Thoothukudi District waged an ongoing protest for over 175 days in 2024. The protestors demanded the closure of three nearby fishmeal and fish oil plants due to unbearable stench and alleged contamination of air, water, and soil. Villagers reported that for four years their groundwater had been spoiled and the government ignored complaints. The protests eventually culminated in a boycott of area elections and locals organizing parallel governance meetings, passing resolutions against the factories. During this long-running set of protests, tensions also boiled over when a state fisheries minister’s visit led to a violent clash between protestors and authorities in May 2024. The fallout reportedly even included a local school teacher, who helped organize the protests, being transferred, in a move that local news outlets described as retribution. Fishmeal from one of these plants has gone to feed shrimp at Indian farms that produce shrimp sold by Gordon Food Service, one of the largest food distributors in the United States, and Hanos, a wholesaler based in the Netherlands.43 Gordon Food Service and Hanos did not respond to a request for comment.44M
In some areas of India, pollution from fishmeal plants has become commonplace. In May 2024, sections of the Periyar River running through the Eloor-Edayar industrial area in a district of Kerala turned black, and thousands of dead fish rose to the surface, belly up.45 It was the 15th time in four months that parts of the river turned black and the eighth mass fish kill in a pattern that government regulators said was most likely caused by fishmeal and other factories dumping waste upstream.M
Dive deeper — 2 of 3 in this report — Footnotes 46–77
Fishmeal Sustainability: Walking South on a Northbound Train
The practice of using fish to grow more fish is highly inefficient, with shrimp consuming up to one and a half times their body weight in wild fish that is fed to them as fishmeal or fish oil, according to 2024 research in Science Advances.46M Despite the fishmeal industry claims about the benefits of aquaculture, “On net, it is very clear that the industry destroys food. It’s not feeding the world, but actually destroying people,” said Spencer Roberts, one of the study's authors.47 He added that this process often involves taking food from Global South countries, like India, and converting it into a product for consumption in Global North countries. Virtually all the shrimp grown in India is exported because it is too expensive for local buyers, despite the fact that much of the forage or pelagic fish caught along Indian shores and used as fishmeal could be eaten locally.
Fish In:Fish Out
It can take more than 730 wild-caught Peruvian anchoveta to grow a single farmed salmon.
Wild anchoveta needed per farmed animalMEvery mark is one anchoveta, at one size
730anchoveta 1 Salmon
390anchoveta 1 Trout
3anchoveta 1 Carp
1anchoveta 1 Shrimp
India, the world's most populated country, is also the third largest consumer of seafood, with at least a fifth of its protein coming from fish, according to a 2022 FAO estimate.48 The Indian oil sardine, a staple for many communities in southern India and rich in essential nutrients, has seen its stocks plunge, partly due to overfishing driven by the fishmeal industry in provinces like Kerala.49
Meanwhile, Indian fishing companies have historically benefited from government support, with India providing at least $200 million in harmful subsidies to its fishing industry in 2018, according to a University of British Columbia study.50 Such subsidies are controversial because researchers argue they can lead to an overabundance of fishing vessels, accelerating overfishing. The world took a step toward ending this practice when a World Trade Organization (WTO) agreement on fisheries subsidies, which India is a member of, entered into force in 2025. Under this agreement, member states agreed to prohibit subsidies that contribute to unregulated or illegal fishing and the targeting of overfished stocks.51
As the planet’s population has grown, so too has the competition for key nutrients. Countries are struggling to reduce their reliance on imported meat in a bid toward “protein sovereignty.”52 In response, investors are pursuing alternative protein sources like plant-based or lab-cultivated meat. Disruptions, such as the avian flu and the Russia-Ukraine War, have caused sharp jumps in meat prices, highlighting the volatility and interconnectedness of these commodity markets. This global competition is evident in a report from the Wilson International Center, “Land Grab? The Race for the World’s Farmland,” which notes that "wealthy, food-importing countries and private investors are acquiring farmland overseas" often for the purpose of growing more food.53
Within this global fight for prized resources, feed represents a hidden, crucial battle. Competition is especially fierce for crops fed to livestock, particularly soy. “China, the US, and Brazil are the world’s three largest producers of meat by far, and they all rely on and are bound together by one commodity: the soybean,” explained a 2024 podcast by the Carnegie Endowment for International Peace.54 “In 2024, US-China trade tensions are mostly centered on high-tech products like semiconductors or critical minerals. But in 2018, one of the first battlegrounds for these superpowers was the soybean.”55 As with soy, the scramble for fishmeal and fish oil is fueled by the same geopolitical desires for sovereignty and control over vital resources. And yet, this contest is happening not on land but at sea, where there is far less focus from journalists, governments, and environmental or human rights advocates.
- Indian oil sardine (Sardinella longiceps)Source
- Indian mackerel (Rastrelliger kanagurta)Source
The fishmeal industry and aquaculture industries have made a variety of arguments about their sustainability. For example, the IFFO, which is the international fishmeal association, has emphasized that its “role is not to advise which markets should use fishmeal and fish oil.”56 Véronique Jamin, a spokesperson from the organization, said that fish farming is “the most efficient animal protein system” and “is becoming more efficient over time, not less: lower inclusion rates of fishmeal/oil, higher digestibility of alternative ingredients, better feed formulation through precision nutrition.”57 She added: “Sustainability frameworks won’t work if they ignore real-world economics,” and seafood companies have to respond to “what people actually want to buy and eat.”58
Ocean researchers and marine historians, however, offer a different view about global demand for fishmeal and farmed fish.59 First, they contend that it was the aquaculture industry itself that is driving increased demand for farmed fish. "Classic market economics explains that making a resource cheaper and more efficient does not curb its use; it increases it," said a 2026 report by the Aquaculture Accountability Project. "Instead of meeting a preexisting need, confining hundreds of thousands or millions of fish in net pens to produce cheap seafood has created what economists call ‘supply-driven demand.’”60 A 2024 study by Science Advances furthered this point: Aquaculture companies have “driven an increase in demand for salmon, rather than having simply met a pre-existing demand.” The research concluded that the aquaculture industry has exponentially increased the supply of affordable “premium” fish like salmon, leading to higher demand, the opposite of its claim to be meeting an existing need.61
In defense of its sustainability, the feed industry has also emphasized that it is decreasing its reliance on fishmeal and fish oil, and especially on the use of whole fish or fish that can be eaten by people. Over 58 percent of fishmeal and fish oil globally comes from whole fish in 2026, according to international fishmeal association data. At least 90 percent of the fresh fish turned into fishmeal and fish oil is food-grade, edible to humans, according to a 2017 study published in the Fish and Fisheries journal.62 The IFFO has said on its website that between 2000 and 2020, the proportion of fishmeal in aquaculture feed at fish farms globally decreased from 23 percent to eight percent.63 Some experts have predicted, however, that the total amount of global fishmeal production could rise by nearly 10 percent between 2022 and 2032, mostly from trimmings—fish offcuts not suitable for human consumption—according to the FAO.64 Overall demand for fishmeal also seems to be increasing.65 Five of the world’s largest salmon companies, for instance, increased their absolute use of fishmeal and fish oil made from whole wild fish by as much as 39 percent between 2020 and 2024, according to a report from the Farm Animal Investment Risk and Return Initiative.66
Meanwhile, global fishmeal supplies could be tapped out as soon as 2028, according to Novel Sharma, a Rabobank analyst specializing in seafood and aquaculture.67 “A shortage is inevitable,” the report said.68 This means that the industry's claims about the supply, demand, and sustainability of fishmeal require broader context. While individual sectors or companies may be decreasing their use of fishmeal, the overall industry is not likely decreasing at a rate that makes it sustainable. The industry’s claims, then, resemble someone walking north on a southbound train: Individual actors may be moving in the right direction, but not nearly fast enough to change the outcome.
Assessing the climate impact of carnivorous fish farming is also complicated.69 The industry markets aquaculture seafood as a climate-friendly protein source.70 However, its true carbon cost is sometimes obscured by selective accounting, particularly the omission of fishmeal production, which accounts for at least half of industry emissions.71 Comparing the climate impact of food per pound can also make farmed fish appear artificially more efficient, but one pound of water-dense cod provides only a third of the calories of one pound of pork, distorting the reality of consumption.72 Meanwhile, over 165 million metric tons of CO2—equivalent to the annual emissions from all passenger cars in the UK—have been released into the atmosphere as mangroves and seagrass beds have been destroyed to make way for the global expansion of coastal fish farms, further undermining long-term carbon storage.73 When emissions from fishmeal, habitat loss, and global supply chains are accounted for, catfish and other intensive aquaculture products can rival or exceed poultry and pork in total climate impact, according to a 2018 Science study.74
Bill McKibben, a climate-change expert and author of Here Comes the Sun, said that hope is not lost, especially looking at promising trends tied to even some of the most intransigent global systems like fossil fuels.75 Between 2022 and 2024, the world nearly doubled its solar power capacity from two to three terawatts, and it was on track to increase by another three terawatts by the end of 2026. As of 2025, solar was growing faster than any other power source in history. The shift was largely driven by developments in the 2020s that enabled solar power, for the first time, to become cheaper than fossil fuels. China, Pakistan, and several countries across Africa led the charge to divest from distant supplies of oil and natural gas and take up local supplies of sun and wind.76 “If it can happen with energy, it can happen with food,” McKibben explained, adding that a relocalization of aquaculture, which pushes toward sustainable species like mollusks and away from those that rely on feed sources like fishmeal, is possible if international demand for things like salmon or shrimp decreases.77
India’s rise as a global leader in shrimp production was spurred partly by a void in the market left by Thailand. Starting in 2014, Thailand faced growing international criticism for labor abuses on its fishing ships and in shrimp peeling sheds or processing plants.78 When Western supermarkets began looking for other places to source their shrimp, many turned to India. The cruel irony, however, is that India’s shrimp industry has been dogged by many of the same labor abuses that were found in Thailand. In particular, India’s shrimp farms are often worked by migrants, many of them very poor and at times trafficked.
An investigation in 2024 by The Outlaw Ocean Project revealed how one US shrimp company operating in India, Choice Canning, trapped workers, failed to pay them, routinely misled labor auditors, and used antibiotics on shrimp shipped to the US and EU, despite bans on the practice.79 Choice Canning said that the company never underpaid workers, prevented them from leaving without permission, or maintained subpar living conditions, and denied misleading auditors or shipping shrimp containing antibiotics.80 A non-governmental organization called the Corporate Accountability Lab released a report the same year, revealing that many of the same problems existed at shrimp processing plants elsewhere in the country.81
These various revelations resulted in an initial reckoning by the Indian shrimp industry. This included a Food and Drug Administration warning notice tied to shipments from Choice Canning, the addition of Indian shrimp to the Department of Labor’s list of goods tied to forced labor in 2024, and a letter from lawmakers in March 2024 urging an immediate halt to shrimp imports into the US from India.82 But these actions toward the Indian shrimp industry focused primarily on the farms where the crustaceans are grown and on the processing plants where they are de-veined, cleaned, and prepared for export. These government efforts did not look further up the supply chain at the fishing ships and fishmeal plants involved in catching and preparing the feed for the shrimp.M
Work in India’s fishmeal plants can be dangerous, with fatalities resulting from asphyxiation, fires, and explosions.83 The process of cooking rotting fish not only produces foul odors but also dangerous gases, including hydrogen sulfide. The industry's reliance on old machines in India means sparks can ignite easily, and fishmeal itself is highly flammable and notorious for spontaneously combusting as it decays.
These hazards have led to tragic incidents. In December 2021, at Bismi Aquatic Products in the south of India, a migrant worker died after cleaning a wastewater tank, passing out from the fumes, and falling in.84 Two other workers who tried to save him were hospitalized, and government regulators criminally charged the plant for lax safety.85 In a written response to The Outlaw Ocean Project, Bismi Aquatic Products stated that the worker who died was not following safety protocols and added that the incident “left an indelible mark” with “lessons learned ensuring better operating safety guidelines.” The company also said that it provided financial compensation to the deceased worker’s family. A few months later, on February 20, 2022, two migrant workers were killed and three others injured in a boiler explosion at Bismi Fisheries Private Ltd, another fishmeal plant in the south of India.86 Government regulators criminally charged this plant with negligence. Bismi Fisheries did not respond to a request for comment.M
Fishmeal plants often rely on migrant labor. A 2019 Changing Markets Foundation report documented interviews where some of these workers described unsafe conditions, including a lack of protective gear. The report concluded that factories prefer migrant workers over local labor because they can pay them less and face a lower risk of unionization. Severe workplace injuries, such as amputations and fatalities from falls into effluent tanks, often went unresolved because companies sometimes bribe locals or use intimidation to silence dissent, the report said.87M
India’s fishmeal industry became so powerful partly because of massive demand from Americans for shrimp, which is the most-consumed seafood in the United States. Per capita, Americans eat more than five pounds of shrimp every year.88 This popularity is relatively recent. Shrimp used to be a luxury food, and it was virtually all wild-caught, primarily by trawlers operating near the coast of the Gulf of Mexico. In the second half of the 20th century, the cost of shrimp in the US was higher because these trawlers caught less, used expensive amounts of diesel, and fished only during particular seasons. That changed in the early 2000s, when imported and farm-grown shrimp became the norm.
Before the 1980s, less than one percent of the world’s shrimp were farm-raised. Aquaculture researchers had not yet figured out how to breed shrimp in captivity. Shrimp farmers did not know, for example, how best to combat viruses or how to adjust water salinity to maximize growth. This changed as researchers learned how to better clean farm pools using sophisticated filtration, purification systems, and, controversially, antibiotics. Farmed shrimp also grew in popularity as ocean conservationists began promoting aquaculture as a means of slowing overfishing at sea. Seeing the market possibilities, governments and companies in India, Thailand, and elsewhere in Asia and Latin America started clearing millions of acres of land to create shrimp ponds, where juvenile shrimp are released and grown to a market-ready size.89
US consumers preferred the imported farmed shrimp not only because it was cheaper than the wild-caught version from Louisiana and Alabama. Farmed shrimp was available year-round and could be grown to consistent sizes, which made them easier to advertise to a public that prefers uniformity. In 1974, Red Lobster introduced popcorn shrimp, a bite-sized, battered, and fried shrimp dish, which became wildly popular. Grocery chains soon began to stock bags of frozen, precooked shrimp in their stores. By 1985, the fast-food chain Popeyes introduced Cajun Popcorn Shrimp, a deep-fried dish meant to compete with McDonald’s Chicken McNuggets. Shrimp was no longer primarily found at fine-dining spots with tuxedoed waiters and white tablecloths. It had moved fully into being an everyday American staple.90
Dive deeper — 3 of 3 in this report — Footnotes 91–132
Certification & The Growing Risk of False Advertising
As the production of seafood has become more globalized, its supply chains have stretched longer, and it has become tougher for consumers to know how it was produced and whether it was harvested sustainably, safely, legally, or ethically.91 Most grocers who sell the seafood are in the dark as well. Partly, because tracking seafood is unusually difficult and costly. The other reason may be plausible deniability. Companies can escape blame or the need to fix problems if they are unaware of them.
Where government regulators in India have proven lacking in managing fish stocks, industry-led certification programs have sought to fill the gap. These programs claim to provide assurances that the supply chains connecting India’s fishmeal industry to seafood buyers elsewhere in the world are free from ships or plants that engage in unsustainable, illegal, or unethical practices.M But critics say that these programs serve as sustainability smokescreens because their purview is not broad enough. As a result, questionable practices farther up the supply chain get overlooked.92
Various researchers and advocates have concluded that seafood certification programs suffer from systemic flaws. For instance, Allie Brudney, a senior staff attorney at Corporate Accountability Lab, a strategic litigation non-profit organization, said that on land, at processing plants, or on farms, certification programs rarely conduct true spot checks to authenticate the reassurances given by managers at the factories.93 Instead, the programs frequently alert companies before inspectors show up, which gives them a chance to clean up the scene so there are no violations. At sea, these programs also often rely on self-reported information from ship captains rather than having auditors directly visit and check conditions offshore on vessels, where crimes are most common. The programs are rife with conflicts of interest, since they are typically funded by the companies that they are supposed to police, Brudney added.94
Certification programs also do not track seafood fully through the entire supply chain, which can result in inaccurate reassurances for consumers. “Without the chain of custody, standards are not able to provide an assurance to organisational buyers and consumers that the fish they are buying was caught in the socially responsible way they are purporting,” according to a 2022 study by the University of Nottingham.95M To properly trace aquaculture seafood would require knowing not just what happens at the fish farm but what goes into the feed supplied to the farm. This would entail following fishmeal and fish oil through five stages: from ship to plant to mill to farm to fork. Usually, a ship catches the fish that gets sent to the plant that turns it into oil, powder, or pellets.M The fishmeal is then sent to a mill, where it is mixed with other ingredients, like soy, wheat, and canola meal, to become “compound feed.”96 Next, the feed gets distributed to fish farms that grow the seafood, which is finally dispatched to grocery stores, restaurant chains, or food service companies. Many of these problems have been highlighted by academic and NGO studies, including a 2020 report by Changing Markets Foundation and a 2020 report by the University of Groningen.97
Skepticism
Food safety is another concern tied to the lack of seafood tracing. Food writer Michael Pollan said that aside from climate change and sustainability concerns, there are also intense food-safety problems buried within feed. “We are what we eat, but that’s only part of the story,” he said. “We are what what we eat eats too.” This was the case with beef, which, until mad cow disease, was routinely fed to other cattle. Cows are still fed fertilizer, chicken feces, and cow blood. “I’m imagining we know even less about what goes into fish feed than we do about cattle feed,” Pollan said.98 Consumer protection group Monterey Bay Seafood Watch has tried to warn the public of food safety and sustainability concerns tied to farmed seafood coming from certain countries. In 2021, the organization advised the public to avoid giant tiger prawn and whiteleg shrimp from India due to concerns related to the effects of escaped farmed fish and the release of antibiotics and other chemicals into the surrounding environment.99
Sara Lewis, director of programs for FishWise, a sustainability and labor non-profit organization, explained that one of the reasons these programs are flawed stems from how they were initiated. She said that aquaculture certification programs were designed on the heels of those that previously focused on wild catch and were not sufficiently tailored. “Though the intentions were to model aquaculture certifications on the wild certifications of a decade before, aquaculture has the tricky problem of needing to account for feed origins that wild fishery certifications don’t,” she said.100
Meaning & Methods of Improvement
Five certification programs are most popular in relation to aquaculture seafood. They include Best Aquaculture Practices (BAP) and Aquaculture Stewardship Council (ASC), which concentrate on the sustainability and legality of fish farming; MarinTrust, which focuses on the processing and traceability of fishmeal and fish oil; and Friend of the Sea, which certifies both fisheries and fishmeal and fish oil processors.101 Countries also rely on Fishery Improvement Projects (FIPs), which aim to improve the management of participating fisheries.M
Some ocean conservationists and labor groups have called for seafood companies and grocery chains to stop sourcing from companies or regions tied to labor, food safety, or sustainability concerns.102 Spokespeople from several certification programs disagreed with this perspective, arguing that a carrot-rather-than-stick approach is best for improving the industry. For example, Dave Martin, a spokesperson for the Sustainable Fisheries Partnership, which founded Fisheries Improvement Projects, said, “We ask our partners and those we work with around the world to stay and help fix the problems.” He added, “Fisheries in FIPs are by definition unsustainable,” which is why they are in the program. Asked by The Outlaw Ocean Project why, according to his organization’s own assessment, half of the fisheries reviewed had in recent years dropped into a “poorly managed” category, Martin cited two studies showing that fishery improvement projects help. He also pointed to factors that improvement programs cannot control, such as the performance of government regulators. In regions where governments have rolled back regulations and cut spending toward counting fish and enforcing quotas, Martin said his organization pushes for the companies that source from those waters to play a larger role in preventing overfishing.103
Responsibility
In response to questions from The Outlaw Ocean Project, the various organizations that make up the certification industry emphasized that each plays its own role and cannot be held accountable for others’ responsibilities.104
MarinTrust, for instance, emphasized that its program is not meant to be the “lone driver” but a “credible partner” to governments and NGOs. Regarding labor abuse, spokesperson Libby Woodhatch said MarinTrust’s purpose is strictly to check whether factories comply with national regulations and UN labor conventions.105 ASC spokesperson Gaynyr Dickson added that “certification alone cannot resolve all issues related to the industry” and that ASC does not police labor standards directly. Instead, it relies on fish farms to get their feed from mills that have themselves been certified by other organizations. When asked if the program checks for sustainability problems with feed mills and their fishmeal producers, Dickson said they put that responsibility on the feed mills to do their own “due diligence.”106 Paolo Bray, the founder of Friend of the Sea, similarly stated that his organization does not directly audit ships for labor concerns but relies on independent auditing firms that are supposed to talk to workers in port and review CCTV footage.107 The Global Seafood Alliance, which runs the BAP program, wrote that it is the industry’s “most comprehensive program for farmed seafood” but is also “removed from the auditing and certification decision process,” which is executed instead by third-party auditors.108
Division of labor exists in every industry, though some critics say that its stakes are higher in the certification industry. “The business model is simple,” said a 2025 report from Western Sahara Resource Watch. Exporters pay for certificates, certification bodies issue them, and standard owners license them. "But when things go awry, auditors blame standards, standards blame auditors, both depend financially on the companies they are supposed to control, and almost no one answers questions, the report said. “Everyone gets paid, and when problems emerge, everyone points elsewhere.”109
Certification programs are popular partly because they provide reassurances that allow importers, exporters, and retailers to raise their prices, lessen their legal risk, and attract more investment.110 Companies have a financial incentive to believe the reassurances passed along by certifications and by associates up the chain. The boat captains, fishery officials, fishmeal plant operators, feed mills, fish farmers, seafood brands, restaurateurs, grocers, and even the insurers, banks, and certifiers make up an industry full of stakeholders who receive and hand down such reassurances. Quite often, a compounding confidence snowballs from certifications to marketing claims. Based on their certifications, seafood sellers advertise themselves as more ethical than their competitors.M
Seafood entering Western markets is widely tainted by hidden problems tied to the feed they use in India. For instance, much of India’s fishmeal goes to Avanti Feeds, the country’s largest feed company, which supplies farms that grow shrimp destined for grocery stores globally. These include Walmart, Kroger, Stop & Shop, Costco Canada, and Albertsons, as well as Sysco, which is the world's largest food service company and caterer.111 In correspondence with The Outlaw Ocean Project, Avanti Feeds said that Mukka Group and its affiliates are not currently active suppliers to Avanti Feeds, and based on its sourcing records, Avanti has not sourced fishmeal or fish oil from Mukka operations in Ullal, Mangalore, Suratkal, or Veraval.112 Mukka Group company Mukka Proteins has disclosed at least twice to having received large purchase orders from Avanti for fish oil and fishmeal.113 Sysco takes seriously its obligation and commitment to upholding all international and local laws that protect labor, human and child labor rights, and the environment, and has a demonstrated track record of suspending or terminating supplier relationships when its Supplier Code of Conduct or standards are violated, said Sysco spokesperson Ramit Plushnick-Mast.114 Walmart, Kroger, Stop & Shop, Costco, and Albertsons did not respond to a request for comment.115
This supply chain includes Indian fishmeal plants with problematic records. For example, the plant where the raids discovered hidden bore wells in 2020, United Marine Products, feeds salmon sold at Safeway grocery stores in the US, as well as shrimp sold at Kroger.116M In correspondence with The Outlaw Ocean Project, United Marine Products denied any wrongdoing. “The investigation carried out provides ample testimony to the contrary of the unfounded and baseless allegations levelled against us as regards having 10 illegal borewells within our premises and discharge of waste water into water bodies,” a spokesperson from the company said, adding that the environmental fine imposed on the company was “levied for minor glitches.”117M Safeway’s parent company, Albertsons, did not respond to a request for comment.118
A plant called Blueline Foods that feeds shrimp destined for Target and Costco was temporarily shut down by government authorities for wastewater dumping and has faced criticism about the stench from neighbors and by investigators from an NGO who inspected the facility in 2019.119 Also, several plants owned by the Mukka Group, a company that produces roughly a third of the country’s fishmeal, have faced years of protests about toxic dumping and smell, according to court records, Facebook complaints by neighbors, and an online petition signed by more than 600 people.120 These plants feed shrimp in a dozen countries that get sold, for example, in Kroger in the US, Walmart and Metro in Canada, and US Foods, which supplies more than 250,000 restaurants.121M Target and US Foods did not respond to a request for comment.122 “All Metro suppliers are required to respect working conditions across the supply chain as outlined in our Supplier Code of conduct for responsible procurement (SCoC),” said company spokesperson Stephanie Bonk.123
In emailed correspondence with The Outlaw Ocean Project, the Mukka Group said it has addressed the pollution through increased monitoring, inspections, and “by investing in substantial upgrades to its Effluent Treatment Plants (ETPs) and odour control systems” in compliance with pollution control standards. The group’s facilities have state authorization “confirming that our operations remain within the approved environmental thresholds,” the company added. “In addition, our facilities are certified by globally recognized bodies, ensuring that our operations meet the highest standards of quality, safety, and sustainability.”124M Blueline Foods did not respond to a request for comment.125
Diminishing Deniability?
The disconnect between marketing and certification claims made by seafood companies, on the one hand, and the realities within their supply chains, on the other hand, has created opportunities for litigation. In 2026, for example, the Richman Law & Policy firm filed a lawsuit against Aqua Star, a major seafood distributor in the US. Filed in the District of Columbia Superior Court, the lawsuit alleged that Aqua Star used misleading language and labels to misrepresent to consumers how the company’s whiteleg shrimp products were produced.126 The firm alleged that these misrepresentations violated the D.C. Consumer Protection Procedures Act, which “establishes an enforceable right to truthful information from merchants about consumer goods and services.”127M Aqua Star did not respond to a request for comment.128
Seafood companies may face increasing legal challenges to problems within their supply chains. Historically, such companies have, intentionally or unintentionally, distanced themselves from the behaviors of their subcontractors and suppliers abroad, thereby avoiding culpability for the role of bad actors. A case brought in March 2025 by four Indonesian fishers against the canned-tuna giant Bumble Bee concerning the use of forced labor on fishing ships tied to the company could pierce that veil of plausible deniability.129 The fishers sued the company in the Southern District of California for violating the Trafficking Victims Protection Act (TVPA). The company argued in court documents that it was not responsible for the actions of the relevant fishing ships. In a landmark ruling, the district court allowed the lawsuit to move forward, finding that Bumble Bee “likely had ‘notice about the prevalence’ of forced labor on the vessels from which it sourced tuna, ‘failed to take adequate steps to train staff in order to prevent its occurrence’,” had an “active role in obtaining albacore tuna from the vessels on which Plaintiffs were subject to forced labor,” and resold such procured tuna for profit. Bumble Bee did not respond to a request for comment.130
The legal risks faced by seafood sellers may increase as they rely on countries like India, where the fishing industry is intensifying its efforts. As of 2022, Indian fishmeal plants produced over 300,000 tons of fishmeal annually, valued at roughly $200 million.131 As India’s shrimp industry continues to grow, so too will its production of fishmeal. This is a concern to ocean conservationists because fishmeal production in India is also a major driver of overfishing, especially in the absence of robust government oversight.132
For years, India has lacked clear rules aimed at protecting the health of its fishing stocks. The industry has largely gone unregulated, and yields have slowed in the past decade, including an unexpected and disruptive crash of the sardine catch in 2016. The sardine crash prompted changes beyond fishing regulations and led to a bust in the Indian fishmeal industry in the southern states of Karnataka and Tamil Nadu. This bust resulted in promises from fishmeal companies to stop targeting juvenile fish. In 2019, India created its first ministry of fisheries.133
Many of India’s fishmeal plants use bycatch, which refers to non-targeted species of fish killed inadvertently. They also use trimmings, which are offcuts from catch primarily destined for human consumption.134 However, the high demand for fishmeal in India incentivizes fishing boats to target juvenile and other fish that are not usually consumed by humans so as to sell them to fishmeal plants, according to researchers. This removes young fish before they can reproduce, undermining fisheries’ regeneration.135 While some Indian states have taken steps to regulate the fishery industry, including implementing laws against juvenile catch of certain species and restrictions on mesh size, these policies vary and have not historically been implemented nationally or industry-wide.136
Furthermore, fishmeal plants in India also typically pay in advance for a ship’s entire catch before that vessel has left port, which ends up being a driver of overfishing since the captains and operators of those boats are required to deliver a certain amount of catch to break even.137 Most of the fishmeal produced in India is reserved for domestic use, but as of 2024, the country was also the world’s third-largest exporter of it, especially to China, Vietnam, Japan, Taiwan, and Bangladesh.138 For fish oil, the biggest amounts went to Chile, Australia, Spain, Ecuador, and Belgium.M
Regardless of whether the world’s seafood industry doubles down on sourcing from India or turns away from it, fishmeal production is likely to grow. In 2019, the Indian government imposed a moratorium on registering new fishmeal plants—a move that was meant to curb overfishing of juvenile species and threats to local food security.139 The industry is bullish, and the government is supportive. “Rather than causing pollution,” Dawood Sait, the president of the Indian Marine Ingredients Association, said about fishmeal, “it helps clear pollution-causing waste.”140 The association has also said it aims to triple its output in coming years to keep up with the rising global demand for shrimp. Toward this end, the Indian government announced in 2024 plans to help the industry by lifting the moratorium on new fishmeal plants.141