Otabek Khazeev, representant Russian Fisch Union, på Havbrukskonferansen 22. november 2011 på Radisson Blu Scandinavia i Oslo.

1. RUSSIA:
WHAT HAPPENS IN THE NORWAY SECOND
LARGEST SALMON MARKET?
Dear ladies and gentlemen,
Thank you for the invitation and for the opportunity to speak at this meeting. We especially
would like to thank the Norwegian Seafood Export Council. We have enjoyed fruitful
cooperation with the Council and hope to continue enjoying it in the future. The Council has
always had a clear vision and transparent standpoint on the seafood export policy and this
contributed very much to the development of cooperation between our countries. Thank you
again for the invitation to speak at this seminar.
The Russian market of fresh salmon and trout has recovered its pre-crisis volumes, is growing
and will continue to grow in the future. Market growth will be secured by higher degree of
processing of imported fish and higher market penetration in the different regions of the Russian
Federation. Within 9 months of the current year Russia has already imported almost 73
thousand tons of salmon and trout from Norway. The Norwegian Seafood Export Council
forecasts the export of Norwegian farmed salmon to Russia this year will grow by 25% in
comparison to the previous year when the sales to Russia were record high. The forecast for the
next year is also very optimistic. We believe there will be 25% growth of Norwegian salmon
imports to Russia year on year in 2012 subject to absence of any limitations in exports from the
Norwegian side.
The influence of Russian wild salmon catch on the dynamics of fresh farmed Norwegian salmon
market has been very limited. Fresh farmed Norwegian salmon and trout and frozen Russian
wild salmon are different products and their influence to each other is minor.
The Russian market of fish and seafood has become an integral part of the common market for
three countries – Belorussia, Kazakhstan and Russia – after the Customs Union between those
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2. countries has become effective. Furthermore Russia is going to become an integral part of WTO
in the nearest future. Therefore inspection rules and export approvals issuance rules have
already changed and will become effective after Russia joins the WTO. While issuing export
approval the appropriate officials in Russia, Kazakhstan and Belorussia must take in
consideration the opinions of their colleagues in other countries of the Union and furthermore
the issuing authority of a given country has to be in full consensus with the opinions of other
Customs Union members. Kazakhstan, Belorussia and Russia already enjoy the common
customs and veterinary area. Veterinary documents issued by any veterinary inspector of the
Union member country are accepted throughout the Union.
Rosselkhoznadzor officials, representatives of the main seafood market associations and major
fish and seafood market players met in Rosselkhoznadzor November 11th to discuss the situation
around attempts of the members of The Association of Fish Processing and Trading Companies
to monopolize the Russian market of Norwegian salmon and trout. During that meeting Evgeniy
Nepoklonov the Deputy Head of Rosselkhoznadzor informed the participants that
Rosselkhoznadzor doesn’t have any market regulatory functions in terms of market dynamics on
both sides Russian and Norwegian. He said that it is not Rosselkhoznadzor’s purpose and
objective to control the number of players on any side of the border and influence their
interaction with each other. Rosselkhoznadzor has neither rights nor means of influence for
limitation of the Norwegian salmon exporters’ number. The only Rosselkhoznadzor’s purpose
and objective is fish safety and quality and the only legal tool to secure it is veterinary
control. The members of the Association has informed the participants of the meeting that they
as well only can ask their Norwegian partners to conclude exclusive long-term contracts and
don’t have any means of influence on the suppliers.
At the same time many Russian seafood importers keep getting refusals for their requests to
purchase salmon for cash money at prepayment terms at market prices from Norwegian
suppliers because of the limitations introduced by Mattilsynet allegedly in accordance with
Rosselkhoznadzor officials’ request. I bring to your attention the fact that we possess official
Rosselkhoznadzor’s responses to our requests for clarification of this matter and these responses
contain clear and unequivocal answer that Rosselkhoznadzor has no right to introduce any
limitations of the Norwegian seafood exporters’ number. The only term and condition for fish
export to the Russian Federation and the Customs Union is the approval for export awarded by
Rosselkhoznadzor or its counterpart in the Customs Union member country and correspondence
of fish and seafood supplied to quality and safety requirements effective in the Customs Union.
The present safety and quality control system for seafood imported from Norway has proved not
to be perfect. The Fish Union will act in order to make Rosselkhoznadzor’s actions more
transparent and open to the public. The inspections of Norwegian producers and sampling for
laboratory tests have to acquire more systematic and fundamental nature. Not a single market
player should doubt the inspections will become more unbiased and at the same time there will
be no chance for producers to avoid inspections including those who signed exclusive contracts
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3. with Russian importers. The most important for us is quality and safety of exported fish and
seafood and the unified control procedures both towards Norwegian suppliers and Russian
importers. Rosselkhoznadzor firmly keeps this point of view and we fully support it. We are not
against long-term contracts, we even support such actions. However we are totally against
binding such long-term exclusive contracts with alleged Rosselkhoznadzor malicious actions.
Such things undermine trust! It is an outright lie that if a Norwegian exporter doesn’t sign an
exclusive contract its Customs Union exports approval will be discontinued. This is a technique
used by several unfair importers. Rosselkhoznadzor safety and quality control system already
has more fundamental and overall nature and it will become more perfect in the nearest future.
If a Norwegian producer breaks the Customs Union rules then its export approval has to be with
no doubt temporary barred. From the other hand Rosselkhoznadzor will be able to reissue the
approval for exports subject to Mattilsynet’s more prompt activity in determination of the
causes which had led to a breach of the rules. In the meat industry similar formalities namely
inspection, tests and re-issuance of the approval for export take approximately three months.
This is normal practice.
As I have already told you export-import operations between Norway and Russia will 100%
take place without contract confirmation system. Sergey Dankvert – Head of Rosselkhoznadzor
has informed Interfax agency during his interview of November the 2nd about the Ministry’s
plans to this kind of trading rules and workflow simplification in the nearest future. Thus there
are no selected importers in Russia. Any company has the right to cooperate with any
Norwegian producer who has approval for exports.
Exclusive contracts are private matter of every company however if those contracts are
concluded allegedly by the appointment of Rosselkhoznadzor those producers are not going to
avoid repeated inspections. Exclusive contract with any Russian company is absolutely not a
guarantee of immunity from Rosselkhoznadzor inspections and knowingly positive results of
inspections. In accordance with the current legislation seafood safety and quality requirements
are the same for everybody and Rosselkhoznadzor actions are not of selective nature. Public
seafood quality control is complementary measure for law enforcement in this area.
Taking into consideration all which has been just said we would like to ask our Norwegian
partners:
Have you got fish for exports to Russia?
Is it safe and of the appropriate quality? Does it correspond to the Customs Union requirements
in terms of fish and seafood quality and safety?
If yes then why contrary to all international free trade principles do you keep using non-market
free trade limiting measures towards Russian importers? Why do you keep using those non-
market free trade limitation tools when dealing with Russian importers? Why do you keep
limiting the free trade within Norway and why do you keep free market limitations introduced
by Norwegian companies? I don’t think I have to explain why these non-market limitations are
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4. evil. I’ll only tell you about the most important things: for Russian consumers it is the quality
deterioration and sharp increase of prices and for Norwegian producers it is dependence on
unpredictable factors and absence of freedom of maneuver in situations when market trends and
environment change and are volatile. This kind of things is extremely dangerous for you in the
environment of low prices and excess fish biomass.
Many Russian companies – fish and seafood market players - would like to get answers to these
questions because the support to the process of Russian fresh farmed salmon market
monopolization rendered by the Norwegian companies directly contradicts the current Antitrust
legislation and is contrary to the international norms of law.
We’ve got questions almost to all the producers who currently have approvals for export to
Customs Union: Why do you keep supporting such a system? Are you scared or is it a way to
make money? Everybody knows and discusses the actions and pressure of Association
members. They say to the Russian media in their interviews that you sign those exclusive
contracts voluntary BUT we think that it is not so. Such deception has been in place since 2006,
it just can’t be so for ever. It is time to give public assessment to those events.
We have a question to Mattilsynet:
In accordance with the Russian rules any Russian company can supply seafood from any
packing station which has approval for exports. In accordance with Norwegian rules any
Norwegian exporter can supply fish to any country. An only for salmon exports to Russia you
limit the number of exporters by only one company. Why?
There is great interest to this issue in Russia from all market participants. There is a heated
public discussion in the fish and seafood community and in the media. Russian government has
initiated the following procedures: Federal Antitrust Service is investigating the case against
Rosselkhoznadzor about the illegal limitation of competition in fish import; the Ministry for
Economic Development is collecting the information on the same topic from the market players;
Government commission headed by Vice Prime Minister Mr. Zubkov has ordered to prepare the
proposals for transfer of veterinary control over seafood to the Federal Fishing Agency and to
Rospotrebnadzor. Yesterday the Federal Antitrust Service heard the case against
Rosselkhoznadzor and the Fish Union participated in the hearings. Federal Antitrust Service
found Rosselkoznadzor had broken the Antitrust law dew to the limitation of competition in
seafood imports by rejecting in issuance of import permits to Russian importers based on the
absence of import contract confirmations from the appropriate foreign ministries. The official
text of the decision will be available within 10 days. I’d like to take this opportunity to turn to
you – our Norwegian partners and colleagues – please discuss the problems arising on the way
of free trade in your professional and public communities, unions and associations, bring these
questions in front of your government and appropriate Ministries. Only by discussing such
matters in the public we will be able to achieve really effective and efficient long-term mutually
profitable relations!
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5. Thank you for your attention!
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