Following four years of market survey and analysis of available trade and catch data in Sabah, Shark Stewards has released a comprehensive report on Shark and Ray Catch and Trade in Sabah, Malaysia in September 2018.

Final Report

On behalf of the Sabah Shark Protection Association, a collaborative group of non-profits, businesses, and registered organizations in Malaysia and in Sabah, Shark Stewards has undertaken this report to (1) consolidate existing and unpublished data to better define the quantity and breadth of the catch of chondricthyan fish (sharks, skates and rays) in Malaysia and the trade of their meat and products, and (2) to make recommendations with the goal of increasing management, protection and conservation of these important fish, especially in Sabah waters.

Malaysia is a treasure trove of shark and ray diversity, with many endemic species valuable to the natural heritage and ecology, and with increasing value to the Malaysian economy that extends beyond fishing. As the population increases and more people rely on the oceans for food, managing marine food resource sustainably is increasingly urgent. In this report, we present market data on shark catch and shark fin in Malaysia, Sabah in particular. Additionally, we evaluate the current law on shark and ray catch as well as shark fin trade in Malaysia in general, and in Sabah specifically, and evaluate available market and catch data. We conclude with recommendations for increased management of catch and directed fishing of shark, skates, and rays, and the development of a comprehensive conservation strategy for elasmobranchs in Sabah. A very promising trend is the increasing government focus, NGO support and public attention to marine conservation. A hopeful trend towards marine protection and dive ecotourism can benefit sharks and rays while providing long-term economic benefits, as well as an enduring impact on ecosystem health.

We gratefully recognize the Ministry of Tourism, Culture and Environment, the Department of Fisheries Sabah, the University of Malaysia Sabah, LEAP Spiral, Forever Sabah, the Sabah Shark Protection Association (SSPA), WWF-Malaysia, Scuba Junkie, Scubazoo, TRACC, and Malaysia Conservation Society for providing information and support for this document. We recognize with great appreciation the Shark Conservation Fund for the resources to produce this report.

This report could not have been compiled without the support of Sabahans and residents, including Aderick Chong (Chairman of the SSPA), Cynthia Ong (LEAP Spiral and Forever Sabah), Harry Jonas (Forever Sabah and Future Law), and the volunteers and the passionate people who love sharks and the seas of Sabah. Contributors include Dr. Steve Oakley, Harry Jonas, Amber Platowski, Viktoria Kuehn, Nicole Young, Alice Zhao, Elle Cardenas (cover art), Scubazoo and SEAS. Any errors or omissions remain those of the author.

David McGuire SHARK STEWARDS


Summary of Recommendations

i.     EXECUTIVE SUMMARY

Centered in the heart of the Coral Triangle, Borneo is well known as a region of high biological diversity and endemism. A diverse population of sharks and rays (elasmobranches) are among many species unique to Malaysian Borneo. However, population growth, increased fishing and a growing market demand for fins and ray gill-rakers is placing severe pressure upon many of Malaysia’s elasmobranch populations. Evidence provided by dive tourism operators show a decline in large species of sharks and rays such as hammerhead sharks, whale sharks, and reef sharks. (Sharks and Rays Domestic Trade Report, 2015).

Sharks and rays are in peril globally, and Malaysia is no exception. The first systematic analysis of threats for a globally distributed lineage of 1,041 chondrichthyan fishes, sharks, rays, and chimaeras was published in a report by the IUCN Shark Specialist Group (SSG) in 2014, entitled: the Global Conservation Status of Sharks and Rays. It estimated that one-quarter are threatened according to IUCN Red List criteria due to overfishing (targeted and incidental). The SSG identified Malaysia, located within the Indo-Pacific Biodiversity Triangle, as among three main global hotspots where the biodiversity of sharks and rays is most seriously threatened. The authors emphasize the need for national and international action to protect sharks and rays from overfishing. Large-bodied, shallow- water and freshwater species are at the greatest risk and five out of the seven most threatened families are rays and sawfish. Many of species in these families are limited to and even endemic to Borneo, including 4 species of sawfish, and are at grave risk.

The state of sharks in Malaysia parallels the state of sharks globally, where a lack of accurate, species-specific harvest data often hampers quantitative stock assessment and sustainable stock management. Moreover, confusion in designation of shark fin in trade data makes shark fin exports and imports more difficult to define and grossly underestimates the quantity of shark fin in the Malaysian market. The findings of the Global Conservation Status of Sharks and Rays report, however, indicates a large decline in reef sharks and hammerhead sharks. This report identifies an active shark and ray fishery within Malaysia, including Sabah. As a result, many species of sharks and large rays are on the decline and are traded despite international protections for trade under CITES.

Although the total declared value of world trade in shark products approaches USD 1 billion traded per year, current knowledge of this increasing globalized market remains limited. According to the Food and Agriculture Organization of the United Nations, Malaysia is currently ranked as the world’s 9th largest producer of shark products and 3rd largest importer in terms of volume (Food and Agriculture Organization of the United Nations, State of the Global Market for Shark Products report, 2015). Ranked as the third largest importer of shark fin globally, trade and consumption of shark fin in the country is among the highest. Consumption and trade of shark fin in Sabah is high, as observed by the high import to export ratio, market surveys cited herein and the widespread availability of shark fin soup available to both tourists and locals. Import/export codes make tracking of trade difficult, or even absent in the case of gill rakers, and the trade is believed to be largely underreported.

Shark and ray meat consumption in Malaysia is an important source of protein, particularly for subsistence and artisanal fishers. However, these landings are not included in official fisheries statistics leading to management concerns for a sustainable fishery. Malaysia Market and trade surveys of shark catch and shark fin conducted in Malaysia by the author and other investigators

indicate that a more significant shark and ray fishery exists in Malaysia than is reported in statistics under the Department of Fisheries. Much of this catch is underestimated or unaccounted for in official records. Large sharks, and increasingly Manta rays and their cousins in the family Mobulidae are harvested, targeted primarily for their fins and brachial gills respectively, but also for their meat. Although Malaysia appears to be efficient in overall use of shark and ray meat, and shark finning is uncommon (finning is defined as removing the fins at sea from a live or dead shark and often discarding the body), the catch of many species is driven by the lucrative fin value versus the comparatively low value of the meat. Once detached and dried, shark fins are extremely difficult to distinguish the species of shark, or if the shark was legally or illegally harvested.

Shark finning is not illegal in Malaysia and although it is believed to be rare, cases of fins without the associated carcass is common, and allows for the trade of fins from unidentified, unaccounted and threatened species. A legal ban on shark finning has been adopted by over fifty countries and the practice has been condemned by the United Nations. Large sharks are disappearing from landing sites and endangered and protected species are landed in all the Borneo markets observed. Also, shark fin imports and consumption in Malaysia is one of the highest in the world; a market that threatens shark populations globally. While the perception by some may be that shark finning does not exist, and that all sharks and rays are bycatch, the fact remains that Malaysia does catch fish sharks and rays in numbers significant to cause population decline and threatens some species. Additionally, through the large importation and consumption of shark fin domestically, Malaysia is a responsible party in the global shark decline of sharks and contributes to the shark finning problem as a major consumer. To demonstrate that the country is protecting sharks in earnest, a shark finning regulation should be adopted with associated penalties significant enough to deter the practice.

On a positive note, the economic benefits of an expanding dive tourism market targeted at seeing sharks and rays, particularly in Sabah, is providing hope for the economy and a growing population dependent on the ocean for their livelihoods. Additionally, newly gazetted marine protected areas offer hope for healthy ecosystems and communities, providing alternative livelihoods for native people when properly managed and well enforced. Education efforts by the SSPA and their partners is having a positive effect on consumers and shark fin purveyors, and many restaurants and consumers have pledged not to consume shark fin soup in Sabah.

We endorse recommendations made in the Malaysian National Plan of Action for Sharks, by the Sabah government and by external reviewers, and add additional recommendations on how the Sabah can sustainably manage fisheries, protect habitat, and reduce future threats to sharks and rays in Sabah and Malaysia. More rigorous record keeping and trade restriction of protected and targeted species is necessary. The trade and consumption of fin and shark products needs increased monitoring and enforcement. Increased education for tourists purchasing and consuming shark fin, as well as for locals consuming shark fin and meat from protected species will aid in reducing threats to species of concern. Because sharks play such an important role in assuring a well-balanced and healthy ecosystem, prohibiting harvest and exports of listed species will ease pressure on the entire reef system. Supporting and developing the existing dive tourism network and applying science and enforcement to existing marine protected areas will ensure sharks, the marine ecosystem and the Sabah economy will flourish.

Detailed recommendations by category are provided and we provide a list of these most important recommendations on the following page.

I.       SUMMARY OF RECOMMENDATIONS

  • 1. Amend the Fisheries Act to make shark finning illegal and require that all sharks are landed with fins attached. Require all landings of larger sharks of special interest to occur at public landing centers where these landings can be recorded.
  • 2. Increase training of fisheries inspectors and improve data collection of sharks and ray landings by species.
  • 3. Develop a vessel management or automated information system to determine trawler catch and landings, discards and specific regions of catch.
  • 4. Reevaluate Malaysia’s classification of ‘bycatch’ to recognize that sharks and rays and their products are in fact targeted catch and a reconciliation for consistency of language between Federal and State fisheries laws, and recategorize as byproduct.
  • 5. Require that all landings of protected and CITES listed species are prohibited and that their products are illegal for trade and consumption.
  • 6. Increasing protection of endangered species and enforcement of landings of listed species.
  • 7. Reduce shark fin import and consumption through a national and state campaign to stop serving shark fin soup. Build on education targeted towards reducing shark fin imports/ exports and internal shark fin consumption.
  • 8. Adopt clear legislation making shark finning illegal and the selling and trade of shark fins illegal from any protected, threatened or listed species. List all CITES species of elasmobranches in appendix I and II in the ESA and enforce regulation of the trade of-listed species.
  • 9. Reconcile Federal and State fisheries definitions and regulations for shark and ray fishing to allow consistent enforcement.
  • 10. Develop consistent trade coding for shark fin and ray gill rakers for imports, exports and re- exports.
  • 11. Support an increased training and enforcement program for staff within established Marine Parks utilizing a community-based conservation model to train and provide skilled jobs for locals who may have previously depended on shark fishing for income.
  • 12. Institute a shark tourism fee across all snorkel and SCUBA resorts that will go directly to enforcement infrastructure such as patrol boats and enforcement officers.
  • 13. Prohibit exports of any undocumented or uncoded seafood product for personal use (e.g. tourist personal exports of fins, seahorses, fish maw, live fish, ray gills etc).
  • 14. Support citizen science and adopt consistent data collection protocols, and endorse well managed shark and ray diving ecotourism at a state and national level.
  • 15. Develop a state and national working group that will support sustainable dive tourism that protects shark populations through shark conservation tourism with direct revenues to local communities with clear deadlines and deliverables.

In addition, we recommend Malaysia endorse the recommendations listing elasmobranches proposed including Blue sharks but especially wedgefish and guitarfish under CITES at the Conference of the Parties 18 in Sri Lanka in May 2019.

This report concludes by underscoring that shark ecotourism is currently contributing to the Sabah economy and can provide additional long-term economic benefits to key areas including marine protected areas. Shark ecotourism will benefit all stakeholders and help protect biodiversity hot spots and their abundance of threatened species. This economic sector can develop and support alternative livelihoods to local, indigenous subsistence and artisanal fishers.