IUU Fishing Risk Index a pseudo-scientific trap framed by Western discourse

The Global Initiative against Transnational Organized Crime (GI-TOC), in partnership with Poseidon Aquatic Resource Management, released the latest edition of the IUU Fishing Risk Index 2025 on Nov 24. The report scores the fishing risk index of 152 coastal countries of the world based on a suite of 40 indicators including their vulnerability to, prevalence of and response to illegal, unreported, and unregulated (IUU) fishing across coastal, flag, port and general state responsibilities. On close examination of the report, however, one notices significant methodological shortcomings, such as unscientific indicator design, opaque evaluation process, prejudiced assumptions and limited data sources. As a result, it falls short of serving as an objective, impartial, or scientifically credible reference for international fisheries governance.

First, the report's indicator system is methodologically flawed in that it effectively — if not explicitly — discriminates against developing countries.

The report relies on 40 indicators that suffer from serious methodological problems and, in practice, build structural bias against developing countries into the scoring system. Several objective variables that simply reflect the size and economic activity of a country's fishing sector — such as "size of exclusive economic zone", "dependency on fish for protein", "number of fishing ports", "distant-water vessels registered with a regional fisheries management organization" and "volume of catches" — are treated as so-called risk indicators in their own right. The logic is perverse: the larger a nation's fisheries scale, the higher its "risk" score. This amounts to a presumption of guilt by scale, untethered from actual regulatory capacity. It virtually labels major fishing nations with large sea areas — China among them — as "high risk" regardless of their management performance.

Besides, the report assigns weight to subjective measures such as "view of fisheries observers on flag state compliance incidents" and "views of Marine Stewardship Council practitioners on flag state compliance incidents". Perception-based indicators are easily skewed by non-representative samples, personal impressions and the surrounding political climate. They also lack a data foundation that is verifiable and reproducible.

Additionally, the report elevates the number of "MSC-certified products" to a core benchmark while ignoring the reality that certification can cost between $15,000 and $120,000 — an expense beyond the reach of many small and medium-sized fishing enterprises. By treating a Western-led commercial certification scheme as a universal measure of good governance, this index effectively penalizes fisheries in developing countries that lack the resources to pay for an external label. Finally, the report folds in broad socioeconomic indicators with no necessary or direct relationship to fisheries compliance — such as "gross national income per capita" and "perception of levels of corruption". This approach overlooks the resource constraints and governance policies of countries at different stages of development and shifts the focus away from fisheries management. The result is not a targeted assessment of IUU risk, but a proxy ranking of development levels.

Second, the report's assessment process lacks transparency and shows serious selection bias in its "expert opinion" and "responses by states".

The report claims to supplement its dataset with "expert opinion", yet it provides no meaningful disclosure about who these experts are. Their names, institutional affiliations and geographic distribution are not published. Without that basic transparency, readers cannot judge whether the experts are globally representative, or whether their views are independent. GI-TOC and Poseidon also decline to make their review and validation procedures public, further weakening confidence in the report's credibility. The same opacity appears in the handling of "responses by states". Of the 152 countries assessed, only a small minority submitted official input, and those responses reportedly come largely from European states and smaller countries more closely aligned with the West. The report then extrapolates from this narrow and uneven pool to score and rank the world's major fishing nations, including China, without explaining how the information provided by those nations and their stated positions were weighed, verified, or incorporated into the final results. A global ranking built on such incomplete and unbalanced inputs cannot credibly claim scientific rigor or international representativeness.

Third, the report's conclusions misrepresent China's fisheries governance and overlook measurable progress.

The report downplays China's concrete, substantive actions to strengthen fisheries governance. Though it concedes that China has made "improvements in every iteration of the index", it still places China at the very top of the fishing risk index. That outcome suggests the index is less a neutral assessment of compliance than a scoring exercise shaped by a built-in double standard. In practice, China as a responsible major fishing nation, has implemented the United Nations Convention on the Law of the Sea and the multilateral fisheries agreements it has joined.

China has also tightened distant-water management in specific, operational ways: Since 2016, China has strictly controlled the number of distant-water fishing enterprises and vessels. It implemented strict quota management for species such as bigeye tuna, Pacific saury and mackerel. Currently, China implements the strictest position monitoring system for distant-water fishing vessels, fully enforces electronic fishing log management for high-seas fishing vessels, continuously strengthens supervision of high-sea transfers, independently conducts high-sea fishing moratoriums, and actively conserves fishery resources.

On international compliance and cooperation, China joined the Agreement on Port State Measures to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (PSMA) in April 2025. Accession to the PSMA signals a concrete commitment to multilateral fisheries governance and to meeting international obligations — an important step in China's ongoing efforts to curb IUU fishing and protect marine resources.

Yet the report largely overlooks these specific, verifiable actions and contributions. An approach that mechanically assigns "top-scoring" country as having the "highest risk" — primarily on the basis of industrial scale — is neither logically coherent nor supported by facts. Even more concerning, the report lists the Taiwan island as an "independent country" in its statistical tables — an explicit violation of the one-China principle.

Fourth, the report's data sources lack independence and global representativeness.

The report claims its database contains 5,706 individual data entries. Yet its core sources are heavily concentrated in European Union and United States-led non-governmental organizations and certification schemes — an imbalance that bakes bias into the dataset from the outset. Public data cited primarily come from institutions such as the Pew Charitable Trusts and the MSC, both of which benefit from US financial support. These organizations have repeatedly produced reports framed around predetermined narratives — narratives that are then echoed and amplified by media outlets through sensational coverage that disproportionately targets the fisheries sectors of certain countries.

Meanwhile, the report's publishers — GI-TOC and Poseidon — also receive project-based funding from the EU, the US and affiliated agencies. Given this funding structure, claims of complete neutrality ring hollow, particularly when the report evaluates key fishing nations such as China. Elevating such publications as "authoritative" is itself a symptom of the unequal power dynamics that shape global fisheries narratives.

Furthermore, several of the report's indicators rest explicitly on some unilateral regulatory frameworks. For example, two indicators under "general" category — presented as measures of general states' responsibilities — are "Carded under the EU IUU Regulation" and "Identified by the (US) National Oceanic and Atmospheric Administration for IUU fishing". The report further treats "Mentions of IUU fishing in media reports" as a major scoring input — despite the fact that media coverage is neither standardized nor widely recognized as a legitimate international benchmark. Using such non-universal metrics to judge the world's major fishing nations effectively elevates domestic or regional rules above international norms. It weakens the principle of sovereign equality and runs counter to the spirit of multilateral cooperation.

Fifth, the report functions as a narrative tool and a barrier-setting device aligned with Western interests.

The report is not a neutral academic exercise. It operates as a strategic instrument in the contest over rules and discourse power in global ocean governance. In recent years, the EU and the US have been tightening trade restrictions on Chinese seafood, with the IUU fishing risk index likely to serve as the basis for these measures. By branding China as "high risk", the report offers an "external pretext" for the EU, the US and other markets to tighten trade scrutiny or impose restrictions, particularly by using MSC certification and MSC practitioners' perspectives as evaluation criteria. In practice, this "risk label" constitutes trade barriers and amounts to protectionism.

Besides, under the banner of "risk assessment", the index tries to concentrate evaluative authority in a Western-dominated ecosystem of standards, certifiers, and narratives. The effect is to shrink the policy space available to developing countries in fisheries governance.

The report, wrapping political judgement in the language of "science", tries to strengthen the Western institutional discourse power and the Western certification system. The report itself makes the framing clear: In 2025, the "10 worst-performing countries" are primarily developing nations, highlighting the widespread issue of increasing IUU fishing risks among coastal developing countries. Conversely, it concludes that "Europe remained the best-performing region" across all categories. Presented this way, the index does not encourage cooperation; it intends to reinforce a simplistic North-South divide and deepen mistrust, and risks undermining the shared goal of conserving global fishery resources.

Taken together, it is evident that the report is not an objective or neutral scientific assessment. It is a set of instruments wrapped in the language of data, designed to advance Western narratives and reinforce Western-dominated approaches to governance. Built on flawed methods, biased source material, and latent conflicts of interest, the index tries to effectively recast routine fishing activity of developing countries such as China as inherent "risks". In doing so, it selectively ignores or distorts the ongoing governance reforms and international contributions made by China and other states, while creating leverage for pressure through public opinion, trade measures and diplomacy. The international community should remain alert to — and push back against — such pseudo-scientific traps masquerading as technical authority.

Lyu Ming is a professor at the College of Marine Living Resource Sciences and Management, Shanghai Ocean University; Liu Sen is a graduate student at the same university.

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