Den nye fiskesalslagslova endrer reglene om minstepriser

11 Dec 2013

Den nye fiskesalslagslova ble vedtatt av Stortinget før sommeren og er offisielt benevnt som  lov av 21. juni 2013 nr. 75. Regjeringen har imidlertid bestemt at loven ikke skal tre […]

Den nye fiskesalslagslova ble vedtatt av Stortinget før sommeren og er offisielt benevnt som  lov av 21. juni 2013 nr. 75. Regjeringen har imidlertid bestemt at loven ikke skal tre i kraft før årsskiftet slik at råfiskloven først fra 1. januar 2014 blir erstattet av den nye fiskesalslagslova.

I denne artikkelen vil jeg beskrive reglene om fastsettelse av minstepris slik de blir etter den nye loven.

Regelverket er i realiteten et helt annet enn den tidligere reguleringen i Råfiskloven, selv om loven fortsatt gir fiskesalgslagene rett til å bestemme minstepriser dersom partene ikke blir enige om prisene. Råfisklovens § 4 inneholder en enkel regel som slår fast at salgslagene kan fastsette ”alminnelige salgsvilkår”. Dette er tolket som en adgang for salgslagene til å fastsette minstepriser.

Fiskesalslagslova har en mer omfattende regulering, både ved at loven er mer innholdsrik og ved at forarbeidene til loven kommenterer reguleringsspørsmålene og gir veiledning når lovens skal tolkes.

Fastsettelsen av minstepris er regulert i fiskesalslagslova §§ 11 og 12, og det er her beskrevet en prosess som skal følges ved fastleggelse av minstepriser. Først skal det gjennomføres forhandlinger mellom det aktuelle fiskesalgslaget og øvrige parter. Oppnås det ikke enighet skal spørsmålet om minstepris gå til mekling.

Reglene for meklingen er enda ikke fastsatt, og det er mulig at den utsatte iverksettelsen av loven skyldes at Fiskeridepartementet trenger tid for å lage dette regelverket. Som jeg kommer tilbake til vil det anbefalte forslaget som kommer ut av meklingen være svært viktig fordi meklingsnemnda vil være bundet av de samme reglene som salgslaget ved fastsettelsen av minsteprisene.

Dersom verken forhandlinger eller mekling fører frem er det så i lovens § 12 andre ledd slått fast at det er salgslaget som avgjør.  Dette forslaget om at fiskernes eget salgslag skal avgjøre uenighet om pris har vært omstridt. Det kommer blant annet frem i diskusjonene som har foregått ved utarbeidelsen av lovens forarbeider; både i arbeidsgruppen som har foreslått loven og i høringsrunden. Diskusjonene er referert i Fiskeridepartementet lovforslag; Prop. 93 L (2012-2013), særlig s. 20 – 25.

Spørsmålet er så hvilke rettslige rammer som gjelder for fiskesalgslagets fastsettelse av minstepris i et tilfelle der det ikke oppnås enighet. Det er ikke slik at fiskesalgslaget i et slikt tilfelle fritt kan sette den pris som fiskerne ønsker.

Lovens § 11 første ledd annet punktum har en bestemmelse om formålet med minsteprisen som beskriver denne situasjonen:

”Formålet med minstepris er å få til ei rimeleg fordeling mellom fiskar og industri av inntekt frå marknaden.”

Denne formålsbestemmelsen er viktig fordi det er den eneste bestemmelsen som styrer hva som er et riktig prisnivå.

Bestemmelsen kommenteres slik i forarbeidene (Prop. 93 L (2012-2013) s. 43 – 44):

”Subjektivt sett kan det tenkjast at fiskarsida og industrisida er usamde om kva som er ei rimeleg fordeling av inntekt frå marknaden. Spørsmålet om kva som er rimeleg må likevel ta utgangspunkt i ei objektiv vurdering av forholda, og nødvendigvis byggje på ei heilskapsvurdering av ei rekkje ulike forhold.”

Denne kommentaren er upresis, men setter allikevel krav til prosessen ved fastsettelsen av minstepriser.

Når vi skal ta stilling til salgslagets forpliktelser ved fastleggelsen av minsteprisene er det viktig å merke seg at dette er en form for offentlig myndighetsutøvelse med hjemmel i lovens § 12.  Det fastslås i lovens § 11 at forvaltningslovens kapittel VII ikke gjelder, men det betyr kun at de formelle reglene for behandling av forskrifter ikke gjelder.

Videre vil situasjonen være at salgslagenes prisfastsettelse ikke vil skje i noe vakuum. Forhandlingssystemet som er beskrevet foran innebærer at meklingsnemnda skal ha gjort sitt arbeid før salgslagene eventuelt overtar og setter prisene, og meklingsnemnda må gjennomføre sitt arbeid for å finne fram til en pris som stemmer i forhold til de styringssignaler som ligger i lov og forarbeider. I den grad meklingen ender opp med et anbefalt forslag vil dette være meklingsnemndas oppfatning av hva som i den konkrete situasjonen er riktig pris etter lovens § 11.  

I slike situasjoner vil salgslagets utgangspunkt være at de har et konkret prisforslag som laget eventuelt skal fravike, og de må ha en begrunnelse for å gjøre det. Praksis kan derfor utvikle seg slik at meklingsresultatet blir styrende for prisfastsettelsen til salgslagene.

Uansett hvor klar konklusjonen fra meklingen er vil fiskesalslaget ved fastleggelsen av minsteprisene være underlagt et rettslig saklighetskrav som gjelder ved enhver offentlig myndighetsutøvelse.

Ut fra de bestemmelsene som er referert over er salgslagets oppgave ved fastleggelse av minsteprisen å foreta en vurdering av hva som i det konkrete tilfellet er en pris som gir en rimelig fordeling av overskudd mellom fiskeren og industri. Denne vurderingen må bygge på objektive forhold og ikke kun på en subjektiv vurdering hos salgslaget. Slik forarbeidene uttrykker seg vil salgslaget ha et visst spillerom for skjønn når det gjelder hvilke objektive forhold de vil legge vekt på når de fastsetter en minstepris. Bestemmelsene forutsetter imidlertid at salgslaget må kunne begrunne sin fastsettelse av minstepris på en saklig og god måte med referanse til relevante objektive forhold.

I lovens forarbeider understreker Fiskeridepartementet også at salgslagene har et betydelig ansvar når de får myndigheten til å fastsette minstepriser. Det heter i Prop. 93 L (2012-2013) s. 26:

”Forslaget om ei mekling der salslaget likevel har siste ordet dersom meklinga ikkje fører fram, sikrar på same måten som dagens system at ein kan peike på kven i næringsstrukturen som er ansvarleg for den minsteprisen som vert fastsett. Når dette er eit salslag, eigd og styrt av fiskarane gjennom deira organisasjonar og der dei som vert valt til å styre laget står til ansvar overfor fiskarane, må ein kunne leggje til grunn at denne klare samanhengen mellom myndigheit og ansvar sikrar at det vert teke ansvarlege avgjerder.”

Departementet presiserer i tillegg at fiskernes interesser ikke er høyest mulige minstepriser, men ”langsiktige moglegheiter for sal av fangsten sin, og dermed av at kjøparane også har ei rimeleg avkastning på verksemda si”.

Den prosessen som er beskrevet over vil nettopp sikre at salgslagene foretar ansvarlige og langsiktige vurderinger slik departementet ønsker og forventer. En lovbestemt ordning der den ene parten i et avtaleforhold får lovbestemt rett til å bestemme prisene ved uenighet mellom partene fremstår som svært uvanlig. Utviklingen de siste årene har generelt gått i retning av stadig strengere konkurranserettslige regler for å sikre at ingen får utnytte en dominerende stilling i markedet, og fiskesalslagslovas løsning er i utgangspunktet oppsiktsvekkende i en slik sammenheng. Det gjør at man må forvente reaksjoner dersom salglagene ikke bruker sin myndighet på en balansert måte.

Fiskesalslagslova er ny og dette er skjønnsmessige regler. Innholdet vil antakelig bli klarere når loven har virket en stund, og det vil bli særlig interessant å se hvordan meklingsordningen vil påvirke minsteprissettingen. Uansett må man ønske at salgslagene er så lydhøre for innspill fra de involverte aktørene at det blir få konflikter om praktiseringen av den nye loven.

Om forfatteren

Halfdan Mellbye
Halfdan Mellbye Halfdan Mellbye har i 25 år arbeidet med ulike juridiske problemstillinger innenfor fiskeri- og havbruksnæringen. Han har blant annet arbeidet svært mye med næringsreguleringsspørmål og han har i tillegg særlig gode kunnskaper om de biologiske og miljømessige utfordringene for næringsutøverne. Han har i en årrekke vært faglig ansvarlig for faget Havbruksjus ved Universitetet i Bergen. Han har nylig utgitt boken "Rettslig regulering av norsk akvakultur" som er utgitt på Universitetsforlaget 2018. Halfdan har møterett for Høyesterett.

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