By Alejandra Jimenez
Albania is blessed with a long marine coast and abundant inland waters including rivers, lakes, agricultural reservoirs and coastal lagoons. But in spite of the abundance of its water resources, Albania is a net importer of fish. The Ministry of Agriculture, Rural Development and Water Management wants to turn this situation around by understanding and eliminating the constraints on exports faced by the aquaculture industry in general and the mussel industry in particular.
In 1994, after a cholera outbreak, the European Union (EU) imposed a ban on all exports of living products from the fishery sector, and Albanian mussel production collapsed. Mussels had been produced primarily in the Butrint lagoon, at Albania’s southern tip, since the 1960s, with annual production ranging from 2,000 tons to a maximum of 5,000 tons in 1989. Our objective, as Harvard CID interns in the Ministry of Agriculture, was set in front of us eight weeks ago: understand why Albania has not been able to eliminate this ban on mussel exports that is now over 20 years old.
Our work has consisted of visits to aquaculture production sites, talks with all relevant stakeholders, and independent investigative research. We first catalogued the assumptions we encountered about the export ban, and then searched for evidence to support or debunk them. We found that the persistence of the ban has been attributed by various hypotheses:
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Mussels produced in the Butrint lagoon are not safe for human consumption
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Though mussels are safe for human consumption, the Albanian government does not have the capacity to prove compliance with European food safety standards and stop eventual hazardous batches from reaching the market
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Production and consumption of mussels is informal and does not create the incentives to produce in accordance with costly food safety standards
- EU countries, particularly Greece and Italy, are interested in maintaining the ban so as to protect their exports from competition from the famous Butrint mussels
So which, if any, is correct? Let’s turn to the evidence, checking the hypotheses in reverse order. The most optimistic numbers place the potential for Albanian mussel production at 8,000 tons a year, a number that is almost insignificant when compared with the more than 300,000 tons of Mediterranean mussel produced elsewhere in Europe. In this context, a conspiracy to ban Albanian mussels based out of Italy or Greece is highly unlikely.
The third hypothesis, however, seems more plausible. Mussel production and sales are, in fact, very informal. Only 25 mussel farmers have approval to produce in the Butrint lagoon (photo). The inspectors in the zone know these farmers personally and do not always enforce all contract clauses, including the government’s requirement that the mussels from the lagoon must undergo a purification process (called depuration) before entering the market. The inspectors argue that the tests done on the water imply the mussels are safe for consumption and therefore that depuration is unnecessary. Besides, restaurants buy the mussels even if they haven’t undergone the depuration process. Meanwhile, the inspectors do not face a punishment from the central authority when they do not enforce the food safety procedures established by law. Central authorities argue that the production is too small to make the purification process profitable, and that it would be done if production were large enough. They believe they have the capacity to enforce the food safety standards but will only do so when the production is large enough to make the process worthwhile.
The Food and Veterinary Office of the European Commission has a different assessment, in line with the second hypothesis. In audits made in 2007 and 2011, they point out deficiencies, both in implementation and in technical capacity, that undermine enforcement of the standards meant to guarantee that mussels produced in the country, and in the Butrint lagoon specifically, are safe for human consumption. The 2011 audit states that the government has made progress since 2007, but that some work remains to be done before food safety is ensured and the ban can be lifted. Testing of both the water and of the mussels needs improvement. The government laboratory is not able to run some of the tests that the EU requires and transportation of the samples is slow, allowing microorganisms to grow and the tests to be undermined. Additionally, inspections fail to meet standards for formalization and documentation. The EU’s regulatory bottom line remains that the depuration process must happen as long as the lagoon waters are classified as a “B” area by the Ministry of Agriculture, which they currently are, and the inspectors must be able to respond immediately to stop a hazardous batch of mussels.
Accordingly, the first hypothesis, and whether or not the waters of the Butrint lagoon are free of pollution and mussels produced are generally safe for human consumption, is irrelevant because there is no system in place to attest that this is the case for each mussel to be exported. In reality, safety for human consumption is not a constant as environmental conditions can damage mussels at any time, which is why the EU requires a reliable system be in place to ascertain food safety continuously. That said, local and central authorities have worked hard to improve the quality of the Butrint lagoon water, and sources of pollution have been reduced: there is almost no agriculture in the zone, and no untreated waters are discharged into the lagoon by the towns nearby.
So what is the reason that the ban is still in place? It is not the mussels themselves and it is not a conspiracy. The second and third hypotheses both hold some truth, and given this situation, removing the ban on Albanian mussel exports has become a chicken-and-egg problem. Inspectors do not have an incentive to fulfill their responsibilities because they are convinced that the problem is not their control, but in the low production.The domestic market remains small and the ban on exports removes any profit incentive for higher production by cutting off sellers from international buyers. Removing the ban requires a system with reliable testing where inspections to assess compliance with regulatory standards are properly done. However, both testing and inspections seem overly costly at the current levels of production.
Breaking the cycle implies a shock to the system. This could be a strong initiative within government to make the public inspection and testing system work; it could be organized pressure on the government from the communities that stand to benefit from mussel exports; or this could be the entry of a large private player that would own the mussel production and internalize the need for EU compliance. Any solution would entail better organization on the part of the government and also paying some form of upfront costs—as even the entry of a private company would require contracting and oversight. Meanwhile, fixing the system is not outside the capabilities of the ministry, and the government has even received external assistance for this goal. However, as is often the case, the challenge is not only technical but also bureaucratic—someone must take the initiative to reverse the cycle. Our hope is that by debunking some of the myths of this curious case, we can make this outcome more likely.