The Gambia: Overfished & Under Threat
On the morning of May 22, 2017, residents of Gunjur, The Gambia, woke to discover that the famously biodiverse Bolong Fenyo lagoon had turned a cloudy crimson overnight. Dead fish floated on the surface. “Everything is red,” one local reporter wrote. “Every living thing is dead.” Some residents wondered if the apocalyptic scene was an omen delivered in blood. Government regulators soon discovered that a nearby plant called Golden Lead had dumped wastewater into the lagoon.1 Scientists attributed the mass die-off to the fishmeal waste spiking oxygen levels, killing the animals living there and turning the water red because of a sudden bloom of water fleas.2
The macabre scene was a moment of reckoning. In subsequent years, The Gambia faced intense protests over food security, air pollution, and lost tourism due to the stench of fishmeal, a protein-rich dark-yellow powder made by cooking and pulverizing fish. The Chinese owned at least two of the country’s three plants, which triggered nationalistic frustration from Gambians who argued that their government was selling off their natural resources while compromising food security and the environment.3
Pollution and odors from fishmeal plants have also impacted The Gambia’s tourism industry, the country’s largest economic sector.4 Hotel and restaurant owners complained that foul smells drove away tourists, while fish remains discarded by supply ships littered the beaches.5 “The beaches that were once beloved by tourists are covered in reeking fish carcasses. The toxic water reaches local farming and harvests go to waste,” a local activist in Gunjur told a news outlet in 2019.6
Neighbors of the Golden Lead fishmeal plant told a reporter for The Outlaw Ocean Project that they burned scented candles and incense to combat the rancid odor, and tourists wore white masks. The stench of rotten fish clung to clothes and was virtually impossible to remove. The beaches have been routinely despoiled by seaweed influx and piles of drifting sargassum.7 The blooms correlate with factory outflows, according to Anna Mbenga Cham, director of The Gambia's Ministry of Fisheries.8 In 2022, Cham said that she doubted that inland sewage was the cause and that it was more likely that fishmeal wastewater was triggering the algae growth.9 Excess nutrients fuel these blooms, which in turn cause low oxygen levels, or hypoxia, in coastal waters and smother seagrasses.10 Golden Lead did not respond to a request for comment.11
The stench from the plants is more than just a nuisance for people living nearby. It corrodes the local economy by undercutting tourism and scaring away restaurant patrons and beach visitors. The foul smell is also an indicator of the release of noxious chemicals like ammonia, hydrogen sulfide, cyanide, and methane, which have been known to contribute to higher levels of serious health problems, including nausea, pulmonary edema, and even death among plant workers and neighbors.12
The worst part of the odor comes from trimethylamine, or TMA, a colorless gas characterized by a “fishy” smell. In 2021, the Society of Chemical Industry identified TMA as “strongly toxic and carcinogenic.”13 More than 11,000 people, over 4,100 of whom are under the age of 15, live within a mile of fishmeal plants in The Gambia, according to news reports, government documents, trade records, and court filings compiled in Bait-to-Plate, a tool created by The Outlaw Ocean Project that tracks the world’s fishing and seafood industries.14M
Demand for fishmeal has skyrocketed around the world, especially since the early 2000s, primarily because it is used as a protein-rich supplement in the booming industry of fish farming, or aquaculture, which is the planet’s fastest-growing food sector.15 Global South countries like those in West Africa have paid a heavy price for the exponential growth of fishmeal and aquaculture.. This region is among the world’s fastest-growing producers of fishmeal: More than 50 processing plants operate along the shores of Mauritania, Senegal, and The Gambia.16 As of 2025, The Gambia’s three operating fishmeal plants were located in Sanyang, Gunjur, and Kartong. These plants primarily relied on catch from artisanal fishers rather than industrial trawlers, because the areas near the fishmeal factories lacked docks where large vessels could unload their catch, according to Muhammed Hydara from the Gambia Environmental Alliance.17M
The industry has played a destabilizing role in The Gambia. Between 2017 and 2024, all three of The Gambia’s fishmeal plants were targeted by protests and were involved in various labor infractions and environmental issues, according to The Outlaw Ocean’s Bait-to-Plate tool.18M Allegedly, the plants have polluted the environment at least eight times—often emitting noxious smoke that has caused respiratory issues among local communities—and have been the target of at least four instances of civil unrest.19M
Dive deeper — 1 of 3 in this report — Footnotes 20–43
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, more efficiently, and at a larger scale—was central to the rise of modern civilization.20 Techniques of animal husbandry developed roughly 12,000 years ago in the so-called “Fertile Crescent,” an ancient area stretching from Mesopotamia to Egypt.21 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.22 Shifting from grazing to penning animals required farmers to provide them with balanced diets.23
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.24 Ocean habitats became calorie factories.
Kristin A. Wintersteen explains how and when the modern world began using the sea as a protein mine.25 In her 2021 book, The Fishmeal Revolution, she chronicles how the Humboldt Current, 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.26
Fishmeal and its rise as a staple feed stock has 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.27 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).28 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.29 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. Food constitutes roughly 70 percent of this industry’s overhead, and so far, the only commercially viable form is fishmeal.30 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.31 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.32M
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
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.33 In India, aquaculture is a crucial source of jobs, especially for women.34 In Bangladesh, fish farming has driven an overall decline in the price of fish, making it more accessible for lower-income households.35 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.36 Farming bivalves, including clams, oysters, scallops, and mussels, is particularly sustainable: These species typically require no feed and use minimal land and freshwater.37 They also produce shells that can function as a form of carbon capture, according to a 2020 Nature Food study.38 As of 2022, roughly a third of global aquaculture did not require external feed inputs.39
As the planet’s population has grown, so too has competition for key nutrients. Countries are struggling to reduce their reliance on imported meat in a bid toward “protein sovereignty.”40 Investors are chasing alternative protein sources like plant-based or lab-cultivated meat. Disruptions such as the avian flu and the Russia-Ukraine War have led to sharp jumps in meat prices, casting new focus on the interconnectedness and volatility of these commodity markets. “With increasing frequency, wealthy, food-importing countries and private investors are acquiring farmland overseas,” said a report from the Wilson International Center titled “Land Grab? The Race for the World’s Farmland,” explaining that many of these purchases are for the sake of growing more food.41
In the context of this global fight for prized resources, feed represents a hidden battle behind the broader war. Competition is especially fierce for crops, particularly soy, that are fed to livestock. “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,” said a 2024 podcast by Carnegie Endowment for International Peace.42 “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.”43 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.
One of the biggest concerns about fishmeal and fish oil in West Africa has pertained to food security. The industry has been widely criticized for “food colonialism” because it redirects vital sources of protein from people who need it most and instead feeds it to livestock in richer countries for luxury products like salmon and shrimp.44
“It makes no sense!” Ahmed Manjang, a Gambian microbiologist, said.45 “The Chinese are exporting our bonga fish to feed it to their tilapia fish, which they’re shipping back here to The Gambia to sell to us, more expensively—but only after it’s been pumped full of hormones and antibiotics,” he said. Adding to the absurdity, he noted, tilapia are herbivores that normally eat algae and other sea plants.
Countries like The Gambia benefit to some degree through taxes and job creation from foreign investment tied to the fishmeal industry, which, in 2023, created roughly 269 permanent and non-permanent jobs in the country’s three plants, according to a 2024 study by Rampao.46 However, the factories typically employed local workers at lower levels, while skilled employees tended to be foreigners. Moreover, in a context of dwindling fishery resources, the industry could structurally threaten post-capture activities, notably by “depriving women processors of raw material,” a Food and Agriculture Organization report highlighted.47 In 2023, The Gambia's fishmeal and fish oil industry brought in over a quarter million dollars in export revenue.48
Fishing is The Gambia’s third-largest sector, behind tourism and agriculture, contributing over 10 percent to the national economy. The Gambia has one of Africa’s highest fish consumption rates at 25 kilograms per person per year, which is more than three times the African continental average.49 For protein, more than 80 percent of Gambians rely on small fish like bonga, a species often targeted in fishmeal and fish oil production. A third of artisanal catches have historically been bonga.50 Almost all of that catch traditionally went to local diets but is now largely redirected to fishmeal plants for export.
In the past, Gambian fishing companies have benefited from government support. The Gambia gave at least $17 million in harmful subsidies to its fishing industry in 2018, according to a study by the University of British Columbia.51 Fishing subsidies are controversial because many researchers say that they can put too many fishing ships on the water, which accelerates overfishing.52 Governments around the world took one step toward ending this practice when an agreement on fisheries subsidies passed by the World Trade Organization (WTO), of which The Gambia is a member, entered into force in 2025. Under this agreement, member states pledged to ban subsidies that contributed to unregulated or illegal fishing and the targeting of overfished stocks.53
At least seven species are used in fishmeal in West Africa, including sardine, flat and round sardinella, horse mackerel, chub mackerel, anchovy, and bonga.54 These pelagic stocks are shared by Mauritania, The Gambia, Morocco, and Senegal.55 The FAO categorized three of these species—bonga, round sardinella, and flat sardinella—as “overfished” in the region, noting in a 2019 report that both round and flat sardinella were “in a critical situation marked by heavy overexploitation.”56 This echoed a report it released in 2016, when round and flat sardinella were already overexploited, according to the FAO. Thus, the two fishmeal plants that opened after that year were targeting species already marked as overexploited.57
As this trend persists, it becomes increasingly difficult for the species to recover and for local communities to access them.58 By 2024, both flat and round sardinella were at risk of collapse, according to a 2024 study in Fisheries Research.59
Small pelagic fish are crucial for food security and employment. In The Gambia, fish provides about 50 percent of the population’s animal protein.60 However, these same species are heavily targeted by fishmeal plants, driving up prices, which is especially challenging for fish smokers and driers.61 Fishmeal plants outbid local fishmongers and processors, exacerbating food insecurity.
Dive deeper — 2 of 3 in this report — Footnotes 62–79
Fishmeal Sustainability: Walking North on a Southbound Train
In response to questions from The Outlaw Ocean Project about the sustainability of fishmeal, the IFFO, which is the international fishmeal association, emphasized that its “role is not to advise which markets should use fishmeal and fish oil.”62 Véronique Jamin, a spokesperson from the organization, added 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.”63 Jamin added that “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.”64 The feed industry, more generally, has 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. For instance, the IFFO 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.65
However, the total amount of global fishmeal production is predicted to rise by nearly 10 percent, mostly from trimmings—seafood offcuts not suitable for human consumption—between 2022 and 2032, according to the FAO.66 Overall demand for fishmeal is also increasing.67 For example, five of the world’s largest salmon companies 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.68
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. Global fishmeal supplies could be tapped out as soon as 2028, according to Novel Sharma, a Rabobank analyst specializing in seafood and aquaculture.69 “A shortage is inevitable.”70
The feed industry has further defended its extractive role in lower-income countries like The Gambia by highlighting the industry’s use of trimmings rather than whole fish in some factories. But most fishmeal and fish oil globally, over 58 percent, comes from whole fish, according to international fishmeal association data.71 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.72 Whether there is actual demand among locals to eat the types of fish the fishmeal industry targets varies from country to country and by species.
Assessing the climate impact of carnivorous fish farming is complicated. The industry markets aquaculture seafood as a climate-friendly protein source. 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.73 Comparing the climate impact of food per pound also can 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.74
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.75 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.76
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.77 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.78 “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.79
Since 2016, the price of bonga in the Gambia has reportedly quadrupled. “Our food security is under serious threat, the majority of Gambians live on less than $2 a day and local populations are in direct competition with the fishmeal factories,” an environmental activist from Gunjur said in a 2020 report.80 The FAO classified bonga and sardinella in West Africa as overexploited and warned that fishing pressure on these species must be urgently reduced, according to a report from 2021.81M
- Flat sardinella (Sardinella maderensis)Source
- Round sardinella (Sardinella aurita)Source
- Cunene horse mackerel (Trachurus trecae)Source
- European horse mackerel (Trachurus trachurus)Source
- Chub mackerel (Scomber colias)Source
- Anchovy (Engraulis encrasicolus)Source
Gambian fishers also face competition from Senegalese boats supplying the fishmeal plants. These boats are often larger and mechanized, allowing them to outcompete local fishers. Additionally, Senegalese fishers have been accused of dumping dead fish along beaches when their excess catch spoils before reaching factories.82 This practice raises concerns about overfishing and unfair competition for artisanal fishers.83
In 2023, Amnesty International produced a report about the fishmeal industry in The Gambia and its human-rights impacts, especially as connected to overfishing, food insecurity, and job loss for local fishers. The report said that the opacity of fishmeal supply chains was in contradiction with the International Covenant on Civil and Political Rights, which recognizes the rights of citizens to seek and receive information and to take part in the conduct of public affairs.84 Mustapha Manneh, a researcher based in The Gambia specializing in West Africa fishmeal and fish oil production, added that one consequence of failing fish stocks and job displacement caused by the fishmeal industry is migration. Many families who, for generations, have made a living from fishing are now selling or using their fishing boats to flee to Europe, Manneh explained.
The Gambian government has a mixed record in terms of policing the fishing and fishmeal industries. For example, a 2024 article in the Gambian newspaper The Republic questioned the Gambian government’s continued support for the fishmeal industry—particularly in the form of tax breaks—and weak regulation. In May 2018, the National Environment Agency forced a fishmeal plant called JXYG to cease operations after inspectors found that the company had discharged its wastewater through a pipe into the ocean.85 The agency’s director, Dr. Dawda Badgie, said in 2024 that wastewater disposal into the ocean was safe because the biological method deployed to treat the waste meant that the liquid “has already evaporated a lot of impurities” before being discharged into the sea, The Republic’s article reported.86 JXYG and the National Environment Agency did not respond to a request for comment.87
Other plants in The Gambia have faced penalties for pollution, only for the sanctions to be rescinded later. In 2017, the Gambian National Environment Agency briefly shut down the Golden Lead plant for dumping toxic wastewater into the ocean and a nearby wildlife reserve lagoon, but the plant soon reopened after an out-of-court settlement.88 In 2019, local activists noticed the lagoon had turned red, suggesting continued pollution. When the activists sought to test the wastewater, one had their life threatened, and another five were arrested. Alongside Golden Lead, at least one other plant was accused of violating wastewater regulations. All three plants have been known to emit noxious smells.89 None of the three responded to a request for comment.90
The Gambian government has tried to increase its oversight of fishing in its waters and the fishmeal industry on land. In 2019, the government forged a partnership with Sea Shepherd Global called “Operation Gambian Coastal Defense.” Sea Shepherd provided a civilian offshore patrol vessel, the MV Age of Union, formerly the Sam Simon, with a Gambian law enforcement detachment on board.91 The government also began to prosecute offenders and impose penalties—though not without controversy. Under Gambian law, illegal fishing carries a minimum fine of five million Gambian dalasis, about $100,000 per vessel. Some officials in government and representatives in the fishing and fishmeal industry said the penalties were unfairly and impractically high.
In late 2020, Fisheries Minister James Gomez and then-Permanent Secretary Bamba Banja suggested the five million Gambian dalasis minimum “does not make sense,” preferring to offer out-of-court settlements to offenders.92 When six trawlers were intercepted in November 2020, the ministry sent letters asking if the owners wished to settle the cases out of court. Many suspect such leniency stems from the influence of powerful fishing companies. This was starkly illustrated by a bribery scandal involving Banja, who was charged in 2021 with soliciting a bribe from the Chinese operator Golden Lead to free an illegal fishing vessel.93
In November 2022, Banja was found guilty of corruption. He had accepted at least five payments of $1,600 from Golden Lead between 2018 and 2020, according to Malagen, an investigative journalism outlet in The Gambia. A whistleblower who worked as a translator for Golden Lead provided prosecutors with a recording of a phone call between Banja and Golden Lead executives discussing a payment of 100,000 Gambian dalasis, or approximately $1,300. “Corruption has eaten so deep into our fabrics that it has now become a cankerworm,” the judge said during Banja’s case.94 He sentenced Banja to two years in jail and ordered him to pay a fine, but President Adama Barrow later pardoned Banja in 2024, according to The Point newspaper.95
Overfishing has also severely strained local fish stocks. Fishmeal consumption is the main driver of fish demand. In 2016, one of the country’s three fishmeal plants processed up to 40 percent of the country’s total reported catch, according to analysis by Changing Markets.96 Illegal fishing remains a deeply entrenched problem in local waters. Gambian regulators established a zone along the coast—approximately 10 miles from shore—where industrial fishing is prohibited to protect artisanal livelihoods. Yet illegal incursions into this zone have been routine. Reports have also surfaced of trawlers linked to Golden Lead allegedly using prohibited small-mesh nets to catch juvenile fish, threatening long-term stock sustainability.97M
In late August 2019, a reporting team from The Outlaw Ocean Project went to sea with a patrol by Gambian Navy and Fisheries officers on board a Sea Shepherd ship. The patrol caught two Chinese trawlers, the Lao Yuan Yu 010 and the Victory 205, fishing without logbooks and well inside the 10-mile zone; one was trawling just under two miles off the coast.98 Both vessels were detained in Banjul and found to have violated multiple laws, including by having blank logbooks.
When a reporter from The Outlaw Ocean Project asked a Chinese fishmeal boat captain why his logbook was blank, he angrily shouted, “No one keeps that!” He was not wrong. Paperwork violations are common, especially on fishing boats working along the coast of West Africa, where countries don’t always provide clear guidance about their rules. Fishing-boat captains tend to view log books as tools of bribe-seeking bureaucrats or as statistical cudgels of conservationists bent on closing fishing grounds. But the lack of proper logs makes it almost impossible to determine how quickly The Gambia’s waters are being depleted.99 Scientists rely on biological surveys, scientific modelling, and mandatory reports from fish dealers on shore to assess fish stocks. And they use log books to determine fishing locations, depths, dates, gear descriptions, and “fishing effort”—how long nets or lines are in the water relative to the quantity of fish caught.
Onboard inspections on these and a half dozen other fishmeal ships revealed subpar living conditions. On the Lu Lao Yuan Yu 010, for example, a worker recounted to an Outlaw Ocean Project reporter that his ship had broken the law and fished in banned areas. When asked why he was willing to reveal the ship’s violation, he said, “Follow me.” He led the reporter up two levels to the roof of the wheel room, where the captain worked, and revealed a large nest of crumpled newspapers, clothing, and blankets. It was there, he said, that several crew members had been sleeping for the past several weeks, ever since the captain hired more workers than the ship could accommodate. “They treat us like dogs,” the worker said.100
In 2024, another Navy patrol intercepted an even bigger haul in only 24 hours: eight trawlers—Majilac 03, Majilac 05, Majilac 06, Majilac 07, Zherui 100612, Hao Yun 1, Hao Yun 2, and Hai Hao 2—were all arrested for illegal fishing.101 Seven of them were fishing inside the artisanal zone, and four were using undersized mesh nets. Most of the vessels were targeting fish for fishmeal factories. None of the eight vessels had their mandatory Automatic Identification System (AIS) transponders on, a common tactic to avoid detection while poaching fish. In 2023, a half dozen other vessels were also caught engaging in a variety of types of illegal fishing.102 The fish from most of these vessels went into fishmeal plants, according to Sea Shepherd.
Public anger over these plants has sparked protests, some turning violent. On March 15, 2021, demonstrators burned down a police station and attacked a fishmeal plant in Sanyang.103 The unrest was triggered by a fish factory worker killing a Gambian man the previous day, but was fueled by broader grievances over pollution, threats to livelihoods, and access to fish.104 Dozens of protesters were arrested.105M
All three fishmeal plants in The Gambia are either partially or wholly owned by Chinese companies.106M These foreign investors receive tax breaks and other privileges in exchange for promises of job creation and economic development—many of which have not materialized, according to an investigation by the Changing Markets Foundation.107
Most of the fishmeal and fish oil produced in The Gambia is sent to China. In the past, plants in The Gambia have illegally sent fishmeal abroad. These products were sent without the required food-safety certificates or inspections, according to Gambian authorities and the Changing Markets Foundation’s report. Up until 2021, much of the fishmeal from The Gambia was exported to Vietnam and re-labeled on the black market and re-exported to China to circumvent food-safety controls and the absence of an export agreement for fishmeal between The Gambia and China, the investigation uncovered.108M
The Gambia is not alone when it comes to concerns about the fishmeal industry. Beginning in the early 2010s, foreign investment, largely from Chinese and European companies, poured into West Africa to build fishmeal and fish oil factories aimed at exporting feed ingredients to Europe and Asia. This led to a gold rush for small pelagics. By 2019, about 50 fishmeal and fish oil factories were operating across Mauritania, Senegal, and The Gambia, with at least 40 active in early 2019, according to Greenpeace.109 The fishmeal industry has grown tenfold along the West African coast over the past decade.110
Despite the risk of local stocks collapsing, West Africa has seen increased growth of fishmeal and fish oil factories. This factory growth, which in 2018 absorbed 90 percent of the total pelagic catch, has been correlated with stocks of flat and round sardinella dropping to their lowest levels in history, according to an analysis of fish stocks and fishmeal plants in 2024.111 This increase in fishmeal factories can be traced back to the heavy demand for farmed salmon in Europe, which was worth 8.4 billion euros, or approximately $9.5 billion in 2022, according to a 2025 Oceana blog.112M The demand from Europe continues as consumers are told their seafood is being obtained sustainably.
Dive deeper — 3 of 3 in this report — Footnotes 113–143
Certification & The Growing Risk of False Advertising
One fishmeal plant in The Gambia offers an illustrative example of a divide between marketing claims and reality on the ground. The Golden Lead Import and Export Trade plant makes fishmeal that goes to a feed mill in Vietnam, which, since 2011, has had a certification from Best Aquaculture Practices (BAP).113 This certification purports to guarantee “safe, responsible and ethical farm-raised seafood” and assures “healthful foods produced through environmentally and socially responsible means.”114 Since 2025, the mill has also held a certification from the Aquaculture Stewardship Council (ASC).115 This program describes itself as “setting the standard for seafood” by “accelerating the transformation of the seafood farming industry towards sustainability.”116 From The Gambia, fishmeal becomes feed in Vietnam that then gets dispatched to some of the largest shrimp farms in Vietnam. These farms supply major grocers, including Walmart and Sobeys in Canada.117 These grocers sell their shrimp with packaging that markets itself as a more sustainable option because it has been certified as BAP.M Walmart and Sobeys did not respond to a request for comment.118
The problem is that these particular BAP and ASC certifications also forbid feed that relies on fish that have been caught illegally.119 The 2022 bribery case concerning Golden Lead centered on allegations of company executives paying local officials to mitigate sanctions imposed after ships tied to the plant were discovered to have fished illegally in Gambian waters.120 Reports from local fishers in 2018 had previously raised the alarm about alleged illegal fishing methods being employed by ships linked to the plant. Later reporting documented widespread illegality among boats supplying Gambian fishmeal plants.121 The unauthorized fishing activities of ships supplying Golden Lead would seem to introduce a fishing violation into the supply chain that travels through the feed mill in Vietnam to shrimp farms, and ultimately onto the packaged seafood sold at these major grocery stores.
Most often, the reason for this apparent oversight is that seafood sellers and auditors like BAP do not rigorously check to see whether the business partners furthest upstream are fully complying with rules.M This may be one reason why some fish feed companies, such as Skretting and Mowi, have indicated in their sourcing policies that, since 2023, they have avoided sourcing fish oil and fishmeal from West Africa, including The Gambia.122
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.123 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 the Gambia 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 the Gambia’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.124
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.125 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.126
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.127M 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.”128 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.129
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.130
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.131
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.132 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.133 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.134
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.135
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.136 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.”137 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.138 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.139
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.”140
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.141 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 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.142 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.143
On May 26, 2025, history repeated itself. Eight years and four days after the Bolong Fenyo lagoon first turned red, residents of Gunjur awoke to discover that it had happened again. A local newspaper described the water as “pinkish, foamy, and odorous.” A worker from a restaurant near the lagoon pointed out to a newspaper reporter that the incidents in 2017 and 2025 coincided with periods of increased activity at the Golden Lead fishmeal plant.144
Manjang, the Gambian microbiologist, posted photos online of half a dozen critically endangered hooded vultures in the wildlife reserve that died of poisoning in the same month. He wrote that the birds likely perished after drinking water polluted by the fishmeal plant.145
Lamin Jassey, a schoolteacher and environmental activist who participated in some of the original protests of the factory, told reporters that the company also appeared to have illegally added a pipe discharging wastewater into the forest located in the wildlife reserve. “We’ve been raising this issue for years, trying to avoid confrontation with the factory,” he said, “but livelihoods are being compromised.”146