Feedback to the European Commission on the CFP’s state of play

The document argues that the EU has failed its legal obligation to harvest all stocks sustainably by 2020, noting that 83% of assessed stocks in the Mediterranean and Black Seas remain overfished and the North-East Atlantic overfishing rate rose to 43% in 2019. The NGOs identify four critical implementation gaps: the need to acknowledge real overfishing levels rather than using misleading metrics, the requirement to manage data-limited stocks according to the precautionary approach, the necessity of using science-based catch limits over 'last resort' remedial measures, and the urgent need to fully implement the landing obligation to prevent illegal discarding. They specifically criticize the Commission for using metrics like landing volumes that distort the status of depleted stocks and for setting Total Allowable Catches (TACs) that frequently exceed scientific advice, particularly for data-limited stocks.

• The EU has not met its legal commitment to end overfishing by 2020, with significant regional failures: 83% of assessed stocks in the Mediterranean and Black Seas are overfished, and the North-East Atlantic overfishing rate increased from 38% in 2018 to 43% in 2019.
• The European Commission is accused of using overly optimistic metrics, such as landing volumes and median fishing mortality, which mask the true state of depleted stocks and ignore the legal requirements of the CFP's Maximum Sustainable Yield (MSY) objective.
• There is a 'two-tier' approach to managing fish stocks where data-limited stocks are subject to less ambitious proposals than MSY-assessed stocks; in 2020, 35% of proposed TACs for data-limited stocks exceeded scientific advice, compared to 12% for MSY-based advice.
• The NGOs argue that 'last resort' remedial measures are insufficient if the primary tool—setting fishing limits—continues to ignore scientific advice, citing that Celtic Sea cod TACs exceeded scientific advice every year since 2015 except 2018.
• Widespread non-compliance with the landing obligation (LO) and the practice of setting TACs based on catch advice rather than landings advice allows for unsustainable catches and illegal discarding.

APA

ClientEarth (2021). Feedback to the European Commission on the CFP’s state of play. https://www.clientearth.org/media/uqymmk5f/joint-ngo-response-to-the-commission-consultation-on-the-setting-of-fishing-opportunities-for-2022-under-the-cfp.pdf

Chicago

ClientEarth. Feedback to the European Commission on the CFP’s state of play. 2021. https://www.clientearth.org/media/uqymmk5f/joint-ngo-response-to-the-commission-consultation-on-the-setting-of-fishing-opportunities-for-2022-under-the-cfp.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Feedback to the European Commission on the CFP’s state of play |date=10 August 2021 |url=https://www.clientearth.org/media/uqymmk5f/joint-ngo-response-to-the-commission-consultation-on-the-setting-of-fishing-opportunities-for-2022-under-the-cfp.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021feedback, author = {{ClientEarth}}, title = {{Feedback to the European Commission on the CFP’s state of play}}, publisher = {ClientEarth}, year = {2021}, month = aug, url = {https://www.clientearth.org/media/uqymmk5f/joint-ngo-response-to-the-commission-consultation-on-the-setting-of-fishing-opportunities-for-2022-under-the-cfp.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }