Positions & Papers

December 9, 2021

NGOs ask Commissioner for Environment, Oceans and Fisheries, Mr. Virginijus Sinkevičius, for the prohibition of catches of tope shark (Galeorhinus galeus) in the Northeast Atlantic as this is the only logical outcome for the management of this threatened species in European waters after over a decade of ineffective management1.
211208 Tope shark protection letter


Joint NGO recommendations Northeast Atlantic fishing opportunities 2022

October 14, 2021

NGO signatories of this document wish to present our recommendations on the setting of fishing opportunities for north east Atlantic fish stocks 2022. Our intent is to assist the European Commission, the Council of the EU and the Member States in making decisions on fishing opportunities that finally end overfishing, significantly contribute to restoring and/or maintaining all fish stocks above healthy levels and safeguard marine ecosystem functions.  
210831 FINAL_NGO recommendations NEA on FO to EU


Updated FINAL NGO recommendations Baltic TACs 2022 based on ICES advice for salmon and western baltic cod

October 8, 2021

When our first Joint NGO recommendations Baltic TACs 2022 was released International Council for the Exploration of the Sea (ICES) had not been able to produce their advice for a number of stocks. As soon as the advice was released the Joint recommendations was complemented with a non-paper that was circulated to stakeholders. This updated version of the joint recommendations includes the final recommendations from the non-paper. In October 2021, EU fisheries ministers will agree on fishing opportunities in the Baltic Sea for 2022. We have provided a range of recommendations regarding the principles for setting sustainable fishing quotas in line with the Common Fisheries Policy and also specific recommendations for the Total Allowable Catches for each of the Baltic fish stocks that are managed by quota. Read the NGO briefing. 211008 FINAL Joint NGO recommendations Baltic TACs 2022  


Joint NGO EU Parliament voting recommendations (January 2021)

February 10, 2021

2019/2177(INI) report on “​Securing the objectives of the landing obligation under Article 15 of the Common Fisheries Policy​”
These joint NGO recommendations on the amendments tabled for ​Mr Gade’s own initiative report on the landing obligation are supported by ClientEarth, BirdWatch Ireland, Deutsche Umwelthilfe, Dutch Elasmobranch Society, The Danish Society for Nature Conservation, FishSec, Fundació ENT, Oceana, Our Fish, Sciaena and Seas At Risk. We broadly support Mr Gade’s draft report: it reflects both the urgent need for and the challenges of a proper implementation of the landing obligation (LO) in a balanced manner.


Joint NGO recommendations on Baltic Sea fishing opportunities for 2021

June 9, 2020

In October 2020, EU fisheries ministers will agree on fishing opportunities in the Baltic Sea for 2021. We have provided a range of recommendations regarding the principles for setting sustainable fishing quotas in line with the Common Fisheries Policy and also specific recommendations for the Total Allowable Catches for each of the Baltic fish stocks that are managed by quota. Read the NGO briefing here.


It’s there for a reason: Why Ministers must not exceed scientific advice on fishing quota

November 25, 2019

In a briefing by Griffin Carpenter of the New Economics Foundation the reasons and benefits for Ministers not exceeding scientific advice are laid out and provide a timely reminder ahead of the December Council meeting at which quotas for the Northeast Atlantic and North Sea will be set.

The message is clear: “Past inaction by fishing Ministers has come at a cost. Through their delay, Ministers have reduced the environmental and socio-economic benefits that will result from ending overfishing.”

The briefing highlights one of the key commitments from the reformed EU Common Fisheries Policy (CFP) from 2013, an end to overfishing “by 2015 where possible and, on a progressive, incremental basis at the latest by 2020 for all stocks”.

We have now reached the deadline set in the reformed CFP to end overfishing but with four out of ten stocks still being overfished in the Northeast Atlantic and nine out of ten in the Mediterranean and Black Sea, celebration for the EU commitment, it seems, was premature.

The Council of Ministers which has the ultimate say in setting fishing quota has exceeded scientific advice in every six out of ten cases since the CFP reform. With the upcoming quota negotiations for 2020, this practice must end for the CFP objective to be met.

The briefing provides detail on the environmental benefits of ending overfishing, a greater abundance of marine life in a more resilient ecosystem. Moreover, the socio-economic benefits of ending overfishing are explained, more catches and fewer trips. In addition, the cumulative profits generated from sustainable management and the quota implications for a wide range of stocks are expanded upon.


Joint NGO priorities on the revision of the EU Fisheries Control System

November 14, 2019

A broad coalition of NGOs have together drawn up a series of recommendations based on the EU Commission proposal for the revision of the Fisheries Control System, this includes both an analysis of the proposal as well as a detailed 12 point plan for reform.


Transparency: A question to the incoming Finnish presidency of Baltfish

October 2, 2019

In a letter to the incoming Finnish presidency of Baltfish, 15 organisations have called for improvements to transparency and access to documents and positions taken by member states. "Transparency has been part of the work programme and agenda during the previous Swedish, Danish, German and Polish Presidencies and a successful outcome has yet to be reached. We call on the Finnish Presidency to end this long running saga and fulfil the transparency requirements of the European Union." These 15 organisations comprise a broad coalition of environmental organisations, segments of the fishing industry, as well as organisations representing anglers and recreational fishermen.

The letter states: "Our transparency request to Baltfish is for timely access to:
  • Draft texts being proposed;
  • Positions taken by national members;
  • Meeting notes or minutes;
  • And for all documents to be publicly available online."
The letter notes that these criteria are within the Baltfish memorandum of understanding, adopted in December 2013, and is also in line with the Aarhus Convention to which the EU and its Member States are contracting parties. Further, the letter references two inquires launched by the European Ombudsman on transparency within EU bodies with regard to fisheries policy. In case OI/2/2017/TE the Ombudsman found that there was maladministration with regard to “access to documents relating to Council preparatory bodies when discussing draft EU legislative acts”. In her recommendations, she insisted on the need to “systematically record the identities of Member States expressing positions in preparatory bodies.”


An assessment of the effectiveness of the Baltic Sea MAP

September 24, 2019

Fit for purpose? An assessment of the effectiveness of the BSMAP is a joint analysis of the Baltic Sea Multiannual Management Plan (BSMAP) by Pew Charitable Trusts, Birdlife International, WWF, FishSec and Oceana. We conclude that the BSMAP has failed to improve fisheries management in the Baltic Sea. The state of the Baltic ecosystem and its fish stocks speaks for itself. In place since July 2016, the BSMAP, was the first management plan adopted by the EU after the reform of the Common Fisheries Policy in 2013. Having been in place for three years it is being evaluated by the European Commission and has had a stakeholder consultation. We conclude that the BSMAP has failed to improve fisheries management in the Baltic Sea and recommend that MAPs and the CFP definine a maximum level of fishing mortality in future. The state of the Baltic ecosystem, its fish stocks and the decision-making process speaks for itself.

In summary:
  • MAPs were introduced in the CFP to address three specific challenges: the need for longer-term (multiannual) management geared towards achieving the CFP’s objectives; the need to take into account regional and ecosystem specificities; and the desire to bring decision-making closer to the regions in question.
  • The Baltic MAP was instrumentalised to serve other purposes, key among which was the facilitation of the implementation of the LO and providing decision-makers with flexibility regarding fisheries management – not only in the Baltic region, but first and foremost in other European seas.
  • The flawed design of the Baltic MAP led to management decisions and fishing practices that have failed to fulfill the intent of the CFP and achieve the MSFD’s Good Environmental Status target. The intended regionalisation elements have failed to ensure the MAP delivers on the specific needs of the Baltic in a timely manner, and lastly the MAP has failed to help deliver TACs in line with MSY and scientific advice.


Joint NGO response to the Commission consultation on the setting of fishing opportunities for 2020 under the CFP

August 21, 2019

In response to the Commission Communication on fishing opportunities for 2020, The Pew Charitable Trusts, Oceana, ClientEarth, Seas At Risk, FishSec and Our Fish have provided a joint response.

We urge the Commission to ensure that the TACs proposed and set for 2020 meet the objectives and requirements of the Common Fisheries Policy (CFP), ensure that the Landing Obligation (LO) is effectively implemented, and commit to a process of proposing and setting fishing opportunities that is transparent to citizens and civil society organisations.

In our recommendations to the Commission we call on them to follow scientific advie in all of its TAC proposals for 2020, for both target and bycatch stocks. Moreover, we highlight the need for correct implementation of the LO and provide seven policy improvements. In addition, we call on the Commission to improve the transparency and accountability of the TAC setting process.