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Europaudvalget 2019-20
KOM (2018) 0368 Bilag 2
Offentligt

Joint NGO priorities on the revision of

the EU Fisheries Control System

November 2019

We call on decision-makers

to support

the Co



issio ’s proposal to:



Introduce Remote Electronic Monitoring (REM) requirements to enable fully documented

fisheries (Article 1(23) of the proposal);

Allow for a better implementation of the enforcement provisions of the Control Regulation (Article

1 (69), Annexes III and IV);

Mandate the use of tracking devices and electronic reporting of catches and fishing operations for

small-scale fishing vessels (Articles 1 (6), 1 (11) and 1 (12));

Improve the control of recreational fisheries by introducing licencing and reporting systems

(Article 1 (44));

Strengthen current traceability provisions to ensure the effective tracking of fishery products via

electronic traceability systems, covering both lots of EU and imported seafood along the supply

chain (Articles 1 (11), 1 (46), 1 (54) and 1 (56));

Require full documentation of all catches and discards (Article 1 (11));

Improve the control of fishing capacity, notably by mandating the continuous monitoring of

engine power for certain categories of vessels (Articles 1 (33) to 1 (37));

Enlarge the scope of the current provisions on the control of fishing restricted areas to cover all

essels a d a eas i the high seas a d i thi d ou t ies’ ate s A ti le 1

;

Replace the paper-based catch certificate scheme with an electronic scheme under the European

U io ’s Regulatio to p e e t, dete a d eli i ate illegal, u epo ted a d u egulated fishi g EU

IUU Regulation) (Article 4 (6)).

We call on decision-makers

to amend

the Co



issio ’s proposal to:

Mandate the use of REM on board of vessels and extend the possible use of REM to other

monitoring needs, such as gathering information on bycatch;

Introduce measures that would allow the effective control of technical measures, in particular

measures set out to minimise the impact of fishing activities on the marine environment;

Complete the list of serious infringements of the rules of the Common Fisheries Policy (CFP);

Provide a clear definition of traceability and include key data elements that are missing from the

EU IUU Regulation catch certificate;

Improve data management and sharing, including for data on catches, landings, vessel positions

and enforcement actions; and establish an EU Fisheries Control Data Centre;

Introduce transparency requirements by making information on the implementation of the

Control Regulation, such as audit reports, infringements and sanctions, publicly available;

St e gthe EFCA’s a date, i pa ti ula o e i g the i ple e tatio of the e te al

dimensions of the CFP; and ensure EFCA has the resources to fulfil this mandate.

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1. Introduce mandatory Remote Electronic Monitoring requirements

Remote Electronic Monitoring (REM) is key to ensure fully documented fisheries. Indeed, data and

video footage using GPS, sensors and CCTV cameras enable the effective control and monitoring of

transparent and traceable fisheries. REM has already been introduced in some Member States (e.g.

Denmark, Spain and the U.K.); and the revision of the Control Regulation presents a unique

opportunity to establish it EU-wide.

recommend

to further expand the legal basis for the use of

REM in the EU or by EU vessels to ensure that it could also be consistently implemented by operators

for other purposes than the control and monitoring of the Landing Obligation (for example, to

improve bycatch management or data collection).

In addition, REM allows for the monitoring and control of the Landing Obligation. In this regard, it is

worth recalling that around 1.7 million tonnes of fish and marine life were discarded in EU fisheries

annually before 2011.

The reformed CFP introduced the Landing Obligation to eliminate this wasteful

practice of discarding unwanted catches. However, despite the serious environmental need and very

broad public support for this policy, the lack of effective monitoring and control at sea is leading to a

great degree of non-compliance including substandard catch reporting.

We therefore

support

the

Commission’s proposal to introduce Remote Electronic Monitoring (REM) to allow for the

monitoring and control of the

La di g O ligatio ’s effe ti e

implementation. In addition, we

recommend

increasing the monitoring capacity and powers of inspectors at sea to quantify the

amount of discards and gather clear evidence on compliance, or the lack thereof, with the Landing

Obligation.

2. Adapt the general control framework to the control of technical measures

The EU fishing fleet needs to apply all technical rules laid down in the Technical Measures Regulation.

This applies, for example, to acoustic devices, streamers, spatial-temporal restrictions and gear

modifications, which have been introduced to minimise the impact of fisheries on the environment -

such as via accidental catches of marine mammals, marine reptiles and seabirds. Indeed, the survival

of several species including the critically endangered Balearic shearwater and the vulnerable

Loggerhead sea turtle depend on the strict implementation of fishing rules.

However, these rules have been widely disregarded and neither the current Control Regulation nor

the Co

issio ’s p oposal e su e that

they are sufficiently controlled and enforced. Indeed,

inspectors on vessels will not need to check if vessels are complying with EU rules relating to

minimising their impact on the marine environment. At the same time, no provisions are taken to

COM (2011). Commission Staff Working Paper Impact Assessment

accompanying the document

Commission proposal for

a Regulation of the European Parliament and of the Council on the Common Fisheries Policy.

COM (2019). Commission Staff Working Document

accompanying the document

Communication from the Commission to

the European parliament and the Council on the State of Play of the Common Fisheries Policy and Consulting on Fishing

Opportunities for 2020.

Regulation (EU) 2019/1241 of the European Parliament and of the Council of 20 June 2019 on the conservation of fisheries

resources and the protection of marine ecosystems through technical measures. For a list of the current legislation

applicable, as of June 2018, see: https://ec.europa.eu/fisheries/cfp/fishing_rules/technical_measures_en. In addition, see

also the proposal for a Regulation of the European Parliament and of the Council on the conservation of fishery resources

and the protection of marine ecosystems through technical measures, COM (2016) 134.

Cf. Directive 2009/147/EC of the European Parliament and of the Council on the conservation of wild birds and Council

Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora.

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ensure that inspectors have sufficient training, capacity and resources to conduct these verifications.

Furthermore, the current legislation does not apply a fall-back option in emergency cases where

sanctions are not sufficient to stop destructive fishing practices - such as empowering the Commission

to close areas to some fisheries if a Member State does not respect its obligations to implement

technical measures for these fisheries.

Therefore, we

recommend

that:



The regulation specifically includes control and enforcement provisions for EU vessels on the

implementation of technical measures for conservation of fishery resources and the protection

of marine ecosystems;



The regulation explicitly states that inspectors shall be trained and well-resourced to ensure

that they can enforce the rules, including mitigation rules applied to fishing vessels to limit

accidental catches of sensitive species, placement of acoustic devices and streamers, as well as

testing the sink rate of weighted hooks;



A serious infringement is created to sanction licence holders and masters for not fulfilling the

obligations to mitigate against the accidental catches of sensitive species;



The Commission is empowered to prohibit fishing activities if technical rules have not been

implemented and sanctions have not been sufficient to stop destructive fishing.

3. Maintain and improve the EU legal framework for enforcement and sanctions

Even though the Control Regulation has been in place since 2010, there are very few Member States

that have issued effective and dissuasive sanctions. The number of sanctions imposed for

infringements is low and the level of these sanctions does not meet the criteria set in the Control and

IUU Regulations. Indeed, in 2017, the Commission itself recognised that

enforcement, especially

concerning sanctions and point system, follow up of infringements [...] are the areas that show the

iggest short o i gs

The continuous lack of political will from Member States to implement the

enforcement provisions of the Control and IUU Regulations, as well as the absence of concrete action

from the Commission to address this issue, are the roots of the problem.

The

issio ’s

proposal moves the enforcement provisions of the IUU Regulation into the new

Control Regulation, opening the current sanctioning system to revision. This has been done without a

proper online public consultation, without a public impact assessment, and without a study on the

effectiveness of the current sanctioning system.

Moreover, it remains unclear how the Commission

and the Member States will address the existing implementation gaps of the enforcement provisions

of the IUU and Control Regulations.

In order to create a culture of compliance, it is key that the current provisions on the penalty point

system, serious infringements, immediate enforcement measures and accompanying sanctions are

further harmonised and strengthened, not weakened.

We therefore

support

these aspects of the

enforcement regime proposed by the Commission.

The proposal distinguishes between infringements that are serious by nature and other serious

infringements of the CFP, whose seriousness should be assessed according to a list of criteria set in

Commission Staff Working Document SWD (2017) 134 Final, p.18.

As e ui ed the Co

issio ’s o

Bette Regulatio Guideli es a d Tool o .

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the Regulation. In addition, it proposes to use mandatory administrative sanctions in case of serious

infringements, for which it sets minimum levels of fines. The proposal further clarifies the rules

applicable within the penalty point system and makes explicit that any point assigned by the coastal

State must be enforced by the flag State.

In addition to these provisions, we

recommend

changing the list of serious infringements as follows:



Add

turning off Automatic Identification System (AIS) transmitters

to the list

–

if the AIS is

turned off for a legitimate reason such as the risk of piracy, the captain of a vessel should notify

the flag State and/or the coastal state;



Amend the

serious i fri ge e t “supplying

services to operators connected to a vessel engaged

in IUU fishing

benefitting from, supporting or engaging in IUU fishing including as

operators, effective beneficiaries, owners, logistics and service providers, including insurance

providers and other financial service providers ;



Add a serious infringement for licence holders and masters of fishing vessels who are not

fulfilling their obligations to mitigate against the accidental catches of sensitive species.

4. Mandate the use of cost-efficient tracking devices and the electronic

reporting of catches and fishing operations for small-scale vessels

Small-scale fisheries are critical in supporting the livelihoods of coastal communities and play an

important role in sustainable development, but they are not necessarily a synonym for low impact

fisheries. Therefore, their operations need to be properly assessed, monitored and controlled to

guarantee that their impacts are accurately accounted for, especially as 89% of the EU fleet

–

responsible for 25% of the

EU’s total seafood

catches

–

currently does not have a vessel monitoring

system on board.

In this context, the installation of tracking devices on board to automatically locate and identify small-

scale (under 12 meters) vessels is essential. Recent advances in technology have made these devices

small and cost-effective and they do not undermine the safe operation of the vessels and gears.

issio ’s proposal to e te d the use of

a vessel position data system to

therefore

support

the

small-scale fishing activities.

Under current legislation, vessels below 10m are not required to record fishing logbook data or

complete a landing declaration indicating their catches. This poses a serious threat to the quality of

stock assessments, as smaller vessels are also responsible for catching significant quantities of fish,

and without the appropriate information on the amount of catches, it is not possible to achieve the

objectives of the CFP.

We therefore

support

the Co

issio ’s proposal to i trodu e a a urate

and complete electronic fishing logbook to record small-scale vessel operations, including details of

all catches by species, category, type and gear used.

5. Improve the control of recreational fisheries

Recreational fishing can bring conservation and socioeconomic benefits when it is properly regulated.

However, very few assessments have been undertaken on the socio-economic importance and

European Court of Auditors, Special Report No 08/2017 :

EU fisheries controls : more efforts needed,

p. 8.

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environmental impact of recreational fishing activities

–

recent scientific studies have estimated that

marine recreational fishing represents between 2% and 72% of total catches, depending on the stock

and the region.

This is why

support

the Co

issio ’s proposal to i trodu e a registratio or

licencing system for recreational fishers and to collect data on their catches.

This licencing process

should not only monitor the number of persons involved in recreational fishing activities, but also

ensure that recreational fishers are well aware of the legislation in place, the species subject to a

recovery plan and the scientific rationale behind these.

Moreover, the obligation to report catches when stocks are subject to conservation measures is an

essential element to obtain greater accuracy on the status of fish stocks, as well as a clear

assessment of the share of catches from recreational fisheries in relation to commercial fishing.

Reporting of catches could be done in several different ways, but preference should be given to

electronic methods; this is particularly relevant for those recreational vessels fishing species subject

to a recovery plan. The fishing mortality data reported by recreational activities should then be taken

into account when estimating the quota allocation for the commercial sector.

In addition, we

recommend

that decision-makers ensure that the Control Regulation clearly

underlines that recreational catches require to be coherent with the multiannual and recovery

plans.

For this to be effective, some measures are required to control recreational mortality (e.g.

minimum landing sizes, fishing gear and catch limitations, or restricted areas and times). This should

take place in parallel with effective monitoring, control and surveillance schemes, which ensure that

Member States are regularly monitoring the catch effort of recreational fisheries and incorporate this

information in their fisheries resources management schemes.

6. Improve traceability requirements

Making fisheries products traceable from point-of-catch to final point-of-sale is a necessary pre-

condition to combatting illegal, unreported and unregulated (IUU) fishing, achieving sustainable

fisheries and healthy fish stocks, and safeguarding the livelihoods of fisheries-dependent communities

worldwide. This holds particularly true for the EU, which is the leading seafood market in the world

and imports over 60% of its seafood, mostly from developing countries.

However, while the EU food safety regulations ensure a degree of traceability for health, safety and

consumer purposes, they do not provide an adequate framework for ascertaining that products were

caught legally. Similarly, the Control Regulation has fallen short of adequately providing for this

framework.

support

the important steps taken by the Commission to rectify some of the traceability

loopholes in their proposal, including:



Mandating the electronic exchange of seafood traceability information along the supply chain

via electronic traceability systems;

Hyder, K., Radford, Z., Prellezo, R., Weltersbach, MS., Lewin, WC., Zarauz, L., Ferter, K., Ruiz, J., Twonhill, B., Mugerza, E.,

and Strehlow, HV., 2017, Research for PECH Committee,

Marine recreational and semi-subsistence fishing

–

Its value and its

impact on fish stocks,

European Parliament, Policy Department for Structural and Cohesion Policies, Brussels.

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

Mandating the tracking of lots of seafood along the supply chain through product

transformation, merging and transport, covering both EU-products as well as imported

products;

Ensuring that adequate information is passed along the supply chain to ascertain the legality of

EU-caught products.

Some key loopholes remain and we recommend that the following are addressed:



Providing a clear definition of traceability in the Regulation so that traceability requirements for

control purposes can be distinguished from labelling requirements for transparency to the

consumer;



Ensuring that sufficient information is also passed along the supply chain to ascertain the

legality of imported seafood products. This requires mandating the inclusion of key data

elements for traceability purposes in the catch certificate, as required under the EU IUU

Regulation, including the unique vessel identifier (IMO number) for all eligible vessels, the

catching method, better definition of catch areas with a clear distinction between the EEZ and

the high seas, and a link between catch areas and catch dates.

7. Improve data management and sharing

Many exceptions, gaps and discrepancies currently exist in the collection, sharing and reporting of EU

fisheries data, compromising the scientific information available for stock assessments and the

objective of achieving fully documented fisheries management as foreseen in Article 15 (1) of the

Common Fisheries Policy.

For example, current catches under 50 kg do not need to be recorded

–

an exemption that seriously

undermines the available fisheries information and reduces the controllability of adherence to the

Landing Obligation at sea. Indeed, the Scientific, Technical and Economic Committee for Fisheries

(STECF) has highlighted that the current scope of obligations needs to be expanded to improve

resolution in terms of catch reporting, inclusion of vessels not currently covered, and information at

an individual operational level, such as per haul.

In addition, the data reported by Member States to the Commission is often of poor quality. For

example, unexplained discrepancies exist between declared landings and the quantities recorded as

sold. Moreover, in a 2017 report, the European Court of Auditors found that Member States do not

sufficiently share and trace information concerning activities of EU-flagged vessels when fishing in the

waters of another Member State.

issio ’s proposal to ta kle so e of

these data deficiencies and discrepancies

support

the Co

by:



Removing the exemptions for vessels under 15 metres which allow them to not declare their

landings (vessels under 10 meters) and to provide their landing declarations on paper instead

of in electronic format (vessels between 10 and 15 meters);

Scientific, Technical and Economic Committee for Fisheries (STECF)

–

46th Plenary Meeting Report (PLEN-14-02). 2014.

Publications Office of the European Union, Luxembourg, EUR 26810 EN, JRC 91540, 117pp.

European Court of Auditors, Special Report No 08/2017 :

EU fisheries controls : more efforts needed,

p. 8.

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

Removing the exemption which allows vessels up to 15 meters to not have a Vessel Monitoring

System (VMS) on board;

Reducing the amount of catches that can be sold directly from vessels without a sales note

from 50 euros to 5 kg;

Requiring Member States to set up a system that allows the Commission as well as EFCA to

access fishing activity data and enforcement information (i.e. national register of

infringements) at all times and without prior notice, in a non-aggregated format;

Allowing scientific bodies of Member States to have access to vessel position data;

Establishing a direct electronic exchange system for Member States to exchange fisheries

information (i.e. vessel position data, electronic logbooks, landing declarations, sales notes

and inspection and surveillance reports);

Mandating the weighing of fishery products to take place on landing, on systems and by

operators approved by the competent authorities;

Requiring information on utilised conversion factors to be included in logbooks as well as

landing or transhipment declarations.

Another major problem identified is that the EFCA and the Commission do not have continuous and

sufficient access to fisheries data. The Commission receives relevant data from the Member States,

notably on catches, quota use, fishing effort and fishing fleet capacity, though it is not allowed to

analyse this information without an authorisation from the relevant Member State. EFCA, on the other

hand, receives information from Member States on the fleets engaged in the region covered by a Joint

Deployment Plan, but not on a structural basis. Despite these structural communication issues, the

Commission fails to propose the establishment of an EU-Fisheries Control Data Centre (FCDC), as

suggested by the European Court of Auditors, for an integrated European information system for

fisheries management. Indeed, the objective should be that data on fishing and enforcement activities

is available in near real time in a digital database that would allow direct electronic exchange between

Member States’ authorities and Commission services. EFCA should also have access to this database

for analysis and control purposes. In addition, non-EU countries should obtain access to parts of this

EU-wide database if a Sustainable Fisheries Partnership Agreement to which they are a contracting

party mandates this.

To strengthen the Commission’s proposal, we therefore

recommend

to:



Establish an EU Fisheries Control Data Centre or an EU-wide database accessible to Member

States, the Commission and EFCA;



Ensure that the Commission and/or EFCA has access to real time vessel position data;



Improve the standardisation of time intervals for communication of data, as well as other

relevant data fields, between Member States;



Grant access to relevant vessel position data from the EU-wide database to non-EU countries if

this is mandated by a Sustainable Fisheries Partnership Agreement to which they are a

contracting party;



Establish harmonised and EU-wide guidelines and systems that assist authorities in the cross-

checking of catch and landing data, including standardised conversion factors.

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8. Ensure the monitoring and control of fleet capacity

Monitoring and control of fleet capacity is essential to ensure that national capacity ceilings laid out

in Annex II of the CFP are respected.

The ceilings found in Annex II are expressed in both gross

tonnage (GT) and kilowatts (kW). The current Control Regulation obliges Member States to control

these fishing capacity elements, though the system in place has proven to be ineffective. Indeed, in

its 2017 report, the European Court of Auditors noted that

the Me er States e isited did ot

sufficiently verify

the a ura y of their fleets’ apa ity a d of the i for atio o the essels i the fleet

;

and a recent Commission study found that the measured engine power exceeded the

certified engine power during 51% of the undertaken verifications.

We therefore

support

the Commission’s

proposals

to improve the control of fishing capacity,

notably by mandating the continuous monitoring of engine power on board vessels that use trawls,

seines and surrounding nets.

9. Effectively control fishing restricted areas and marine protected areas

In order to secure and restore favourable conservation status in marine sites affected by fishing

activities, including marine Natura 2000 areas, Article 11 of the CFP gives the right to propose

restrictions, such as spatial or temporal closures, to an

i itiati g Me e State

that has

a pote tial

fisheries

a age e t i te est i a

site. In addition, the different EU fisheries technical measures

regulations, as well as agreements made under Regional Fisheries Management Organisations

(RFMOs) subsequently transposed into EU legislation, set out certain area closures aimed at

biodiversity conservation. To control and monitor fishing activities in these restricted areas, the

current Control Regulation establishes that vessels of 12 mete

s’ le gth o

greater that enter into

these areas shall be controlled by Member States with a Vessel Monitoring System (VMS) that detects

and records their transit through the area. The frequency of data transmission shall be at least once

every 30 minutes when a fishing vessel enters a fishing-restricted area.

While we

support

the Commission’s proposal to extend the scope of Article 50 of the current Control

Regulation to all vessels - irrespective of their size - and to fishing areas located in the high seas or

in third countries’

aters,

recommend

to shorten the current 30-minute interval for the

frequency of data transmission in order to guarantee an effective protection of marine sites.

10.

Introduce transparency requirements

Transparency is essential to assess if the Control Regulation is to be effectively implemented across

the EU. Having access to up-to-date, public and reliable data on this topic will help to inform

consumers, civil society organisations and decision-makers, as well as foster a culture of trust and

compliance.

Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on the Common

Fisheries Policy.

European Court of Auditors, Special Report No 08/2017: EU fisheries controls, more efforts needed, p. 7.

DG MARE, Final report on the study of engine power verification by Member States of 14 June 2019.

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However, access to data on the implementation of the Control Regulation is difficult: Member States

only have to submit a report to the Commission every five years, in which they provide details on the

steps they have taken to implement the rules (including aggregated data on sanctions and penalty

points), but these reports are not public. This has not always been the case: before 2009 and the entry

into force of the current Control Regulation, the Commission reported regularly to the European

Parliament and to the Council, and the information contained in these annual communications was

public. Similarly, at the national level, data on infringements and sanctions are currently kept in non-

public national registers of infringements of the rules of the CFP that Member States are obliged to

maintain.

The Co

issio ’s p oposal i p o es the s ope a d ualit

of the data that has to be

recorded in the national registers of infringements, though it fails to remedy the lack of transparency.

We therefore

recommend

that:



Just as for the IUU Regulation, Member States report on the implementation of the Control

Regulation every two years, based on aggregated data from their national registers of

infringements. These reports should be

auto ati all pu lished o the Co

issio ’s e site.

In addition, we recommend that the Commission uses the information submitted by the

Member States to prepare bi-annual communications to the European Parliament and to the

Council on the implementation of the enforcement provisions of the Control Regulation;



Member States annually publish aggregated data on the number and types of inspections,

number of infringements detected and reported, and type of follow-up actions (simple

warnings, administrative sanctions, criminal sanctions, immediate enforcement measures, and

number of penalty points administered).

Moreover, the audit reports of the Member States’

o t ol s ste s a ied out

the Co

issio

under Title X of the current Control Regulation are not made public. In other areas of EU law, such as

in the area of food law, animal health and animal welfare, reports from audits in both Member States

a d thi d ou t ies a e a aila le o the Co

issio ’s e site.

recommend

that audits carried

out by the Commission of the control systems of Member States are made public on the

issio ’s e site.

Lastly, Article 113 of the current Control Regulation contains provisions that severely undermine the

right of the public to have access to environmental information under the Aarhus Convention; and the

EU regulations implementing this Convention.

In particular, Article 113 gives Member States the

right to veto any decision taken by the European Commission to grant access to fisheries control data

to persons other than the competent control authorities of that Member State. This is in clear

contradiction of well-established jurisprudence from the European Court of Justice on access to

information matters, which says that Member States do not have the power to veto a decision from

the Commission to release their environmental data.

We therefore

recommend

that paragraphs 2

and 3 of Article 113 of the Control Regulation are either amended or deleted, in order to align the

fisheries control data transparency regime with the one set up under the Aarhus Convention on

See: http://ec.europa.eu/food/audits-analysis/audit_reports/index.cfm.

Convention of the United Nations Economic Commission for Europe (UNECE) of 25 June 1998 on access to information,

public participation in decision-making and access to justice in environmental matters (Aarhus Convention) and the

Regulation (EC) 1367/2006 of the European Parliament and of the Council of 6 September 2006 on the application of the

provisions of the Aarhus Convention on access to information, public participation in decision-making and access to justice

in environmental matters to Community institutions and bodies.

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access to information, public participation in decision making and access to justice in environmental

matters.

11. Minimise the amendments to the EU IUU Regulation by staying within the

s ope of the Co

issio ’s proposal a d

stre gthe i g o l those

provisions opened for review

The EU IUU Regulation is the most progressive anti-IUU legislation of its kind globally. It is widely

recognised as one of the most important and effective tools in driving fisheries reforms worldwide

and improving fisheries governance in non-EU countries; it therefore contributes to global fish stock

health, food security, and the livelihoods of vulnerable coastal communities.

Regrettably, the Commission has taken the decision to propose changes to the IUU Regulation without

holding a proper consultation or carrying out an impact assessment on the subject. These changes are

limited to articles that deal with the catch certificate and sanctions for infringements, but the hasty

revision process poses a real and significant risk to the Regulation. It is therefore key that amendments

to the EU IUU Regulation strengthen this piece of legislation and do not weaken it.

support

the digitalisation of the catch certification system. Electronic catch certificates as well

as the introduction of an EU-wide IT system for their processing, as these will provide decisive means

to improve seafood import controls and verifications, harmonise these practices among Member

States and bring added transparency to supply chains in a cost, labour and time-effective manner.

recommend

the mandated use of the new IT tool. The Commission has already launched the

new IT tool (called CATCH), which is currently voluntary to use. The mandated use of the new IT tool

is required to ensure the effectiveness and success of the tool. As few Member States already have

systems in place to analyse catch certificates, the Commission should provide support to ensure the

interoperability of the IT system with existing national systems.

12.

Revise the European Fisheries Control Agency mandate

EFCA has an important role to play in the implementation of the external dimension of the CFP,

especially relating

to the IUU Regulatio . We ould the efo e suppo t the e isio of EFCA’s a date

in order to fully incorporate this international dimension into its activities. EFCA is also key to ensure

the effective implementation of the Control Regulation and its activities related to data analysis,

exchange and coordination between Member States should be expanded.

We call on decision-makers to ensure that EFCA is given the appropriate resources to fulfil its

mandate. In addition, we

recommend

that the follo i g a ti ities are i luded i EFCA’s a date:



A more defined and active role in dialogues with third countries on IUU fishing, by way of

increased and more steady support to DG MARE missions and an extended capacity-building

programme for third country officials;



An expansion

of EFCA’s role i resear h a d data a al sis arried out prior to issio s i third

countries, as well as data analysis for EU waters.

kom (2018) 0368 - Bilag 2: Henvendelse af 4/6-20 fra Danmarks Naturfredningsforening, Greenpeace Danmark og Our Fish Danmark vedr. forhandlinger om revision af EU's kontrolforordning

Contacts

Béatrice Gorez

Nick Goetschalckx

Georg Werner

Jan Isakson

Emily Langley

Marta Marrero Martin

Dana Miller

Vanya Vulperhorst

Rebecca Hubbard

Nikolas Evangelides

Gonçalo Carvalho

Andrea Ripol

Antonia Leroy

Katrin Poulsen

CFFA

ClientEarth

EJF

The Fisheries Secretariat

The Nature Conservancy

Oceana

Our Fish

The Pew Charitable Trusts

Sciaena

Seas At Risk

WWF EPO

[email protected]

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