17.5 million salmon died prematurely in Scottish fish farms in a year. Here's what we need to do

But behind this booming industry lies a reality that many find hard to stomach: the staggering scale of welfare issues and the lack of clear, enforceable welfare standards to prevent those issues. Think about this: in 2022 alone, an estimated 17.5 million farmed salmon died prematurely and they were not included in the total production figure of 37.7 million a year.

Undercover footage shows that on Scottish fish farms, these fish experience a whole host of welfare problems. For example, due to overcrowding in sea cages, the fish also experience aggression, fin damage, and increased susceptibility to diseases. Sea lice infestations are a major problem, causing painful lesions and requiring treatments which can themselves also negatively impact the fish.

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Deadly jellyfish blooms

Many of these issues are not fixable. I have spoken to fish farmers who do everything they can within the current system to mitigate negative impacts and protect the animals they farm, but they can’t stop a tide.

Our changing climate results in destructive events and jellyfish blooms as the water warms, and unpredictable weather events are becoming more and more extreme. However, that does not mean that more can’t be done to protect these animals.

Farmed fish do have some minimal protections under the Animal Health and Welfare (Scotland) Act 2006. This legislation protects them from unnecessary suffering and requires that their welfare needs are met, for example the need for a suitable environment in which to live.

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These are the same protections that are applied to animals like pigs and chickens. I’ve seen these protections printed and hung on the walls of fish farm offices; but when I asked the workers what a suitable environment for a fish is, what implementing this act looks like in the context of a fish farm, and how to tell whether a fish is happy, they – understandably – can’t say.

Because, unlike pigs and chickens, fish do not benefit from formal government-issued guidance to help producers and regulators understand what the law means and what they should do to meet these obligations. Instead, the sector relies on the industry-authored code of good practice, a voluntary framework that – while it contains some useful standards – is neither legally enforceable nor comprehensive.

Fish can feel pain

This is where the problem becomes a Catch-22. When campaigners raise concerns about fish welfare, the Scottish Government defers to the industry’s code of good practice. But when asked to ensure that this code is enforced, it claims it can’t – because it’s not the government’s code. Accountability is denied and millions of fish suffer as a result.

This legal ambiguity benefits no one – not the farmers, who are left without clear rules; not you and me, who want assurance that the animals are treated humanely; and certainly not the fish, who – as scientific evidence shows – are capable of experiencing pain.

As a member of the Scottish Parliament’s Rural Affairs and Islands Committee, I recently took part in an inquiry into salmon farming in this country. One of the clearest conclusions we reached was that we are failing to uphold the welfare of farmed fish due to the absence of official government guidance.

In fact, despite years of documented concerns, there has never been a single prosecution or formal notice issued relating to fish welfare on Scottish farms. This lack of enforcement speaks volumes.

The solution is simple and achievable. The Scottish Government must issue official guidance. This would provide the clarity needed to interpret the law, set a clear baseline for welfare standards, and ensure that they are properly enforced. It would also close the loophole that currently allows welfare breaches to go unpunished simply because no one understands them.

Farmers committed to high standards

The Scottish Government's "Vision for Sustainable Aquaculture” strategy has prompted the introduction of mandatory reporting on mortality and sea lice numbers, which is a useful start. However, the path forward is still murky.

The Scottish Animal Welfare Commission, in its detailed report on fish sentience, specifically recommended that the government issue official guidance to make the law meaningful in practice. This is about more than just data collection: it is about creating a clear framework that supports everyone involved.

I’ve spoken with farmers who are committed to high standards but find it challenging to know what is legally expected of them without this kind of guidance. Providing clear, government-backed standards would create a level playing field, ensuring that good practice is the norm, and not the exception. This is a chance for Scotland to lead on animal welfare, and official guidance is the crucial next step.

This view is shared by expert lawyers at the Animal Law Foundation, which continues to push for the law that protects fish to mean something in practice and sees official guidance as one of the key ways of achieving this.

We cannot allow fish welfare to be compromised. Industry-led codes – regardless of how well-intentioned they are – are no substitute for government responsibility and legal clarity. Scotland must commit to and take pride in standing by high standards of animal welfare – and that includes fish.

It’s time to break the cycle. It’s time to get farmed salmon out of this Catch-22.

Emma Roddick is a Scottish National Party MSP for Highlands and Islands