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Navigating Security Challenges: The Future of Marine Infrastructure in European Seas
The document identifies increasing vulnerabilities in European marine infrastructure—which supports energy, communication, and transport—and advocates for cross-border cooperation and data-sharing to address these threats sustainably.
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Document type: Policy brief
Recommendations to the EU on the setting of fishing opportunities for 2025
The document argues that the EU has failed its legal deadline to end overfishing by 2020 and calls for 2025 Total Allowable Catches (TACs) to be set well below scientific advice to build ecosystem resilience against climate change. It specifically recommends stricter management for the Western Mediterranean, depleted stocks with zero-catch advice, and deep-sea species, while urging the full implementation of the Landing Obligation through remote electronic monitoring.
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Document type: Statement
NGOs call on you to set sustainable, ecosystem-based fishing opportunities for 2025
The document is a letter to the Hungarian Minister of Agriculture calling for a precautionary, ecosystem-based approach to setting 2025 fishing limits. The NGOs argue that the EU has failed its legal obligation to end overfishing by 2020 and that current scientific advice does not fully account for ecosystem integrity. They demand catch limits below ICES and STECF advice, full implementation of the western Mediterranean multiannual plan, the elimination of bycatch and discards, and increased transparency in decision-making to ensure long-term ocean health and climate mitigation capacity.
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Document type: Statement
Common Fisheries Policy – evaluation
ClientEarth asserts that the Common Fisheries Policy (CFP) is a sound framework but suffers from systemic failures in implementation and enforcement. The organization argues that the EU has missed the 2020 deadline to end overfishing in all European sea basins and calls for the strict application of maximum sustainable yield (MSY), the landing obligation, and the integration of environmental legislation. Key recommendations include the deployment of remote electronic monitoring (REM) to combat illegal discards, the use of transparent social and environmental criteria for quota allocation, and the redirection of the European Maritime, Fisheries and Aquaculture Fund (EMFAF) away from harmful subsidies toward small-scale, low-impact fisheries.
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Document type: Statement
Joint NGO feedback to the European Commission on the “Sustainable fishing in the EU: State of play and orientations for 2025” consultation
A joint response from twelve NGOs urging the European Commission to adopt a fully precautionary, ecosystem-based approach to setting 2025 fishing opportunities, arguing that current Total Allowable Catches (TACs) fail to prioritise the rebuilding of depleted stocks and ignore critical ecosystem dynamics.
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Document type: Statement
Draft national targets put EU just short of REPowerEU
Analysis of draft NECPs indicates that while EU member states have significantly increased wind and solar targets since 2019, the current trajectory falls short of REPowerEU goals. Renewables are projected to generate 66% of EU electricity by 2030, missing the 72% target. The report highlights a lack of data transparency in the drafts, particularly regarding power system flexibility and post-2030 decarbonisation pathways.
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Document type: Research paper
Turns in the Long War as Drivers for Arms Control
The document argues that a prolonged conflict between Russia and Ukraine increases the risk of nuclear and conventional escalation, necessitating flexible, region-specific arms control mechanisms. It identifies critical risks—including the security of the Zaporizhzhia Nuclear Power Plant, potential Russian nuclear testing, and the deployment of nuclear weapons in Belarus—as catalysts for urgent multilateral risk reduction. The authors suggest that provisional 'inter-bellum' frameworks, such as no-fly zones in Eastern Europe or naval limits in the Black Sea, could eventually evolve into permanent treaties following a decisive Ukrainian victory.
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Document type: Policy brief
Request for an urgent meeting to discuss the Commission proposal to amend multiannual plans
A coalition of NGOs, led by ClientEarth, is urging the European Commission to withdraw a proposal published on 6 December 2023 that would remove critical safeguards from multiannual plans (MAPs) for the Baltic Sea, North Sea, and Western Waters. The NGOs argue that deleting the requirement to ensure less than a 5% probability of stocks falling below the limit level (Blim) would endanger depleted fish stocks and damage the EU's international reputation for sustainable fisheries management. They further allege that the proposal was issued without proper stakeholder consultation or impact assessment and appears intended to legalise an unlawful Council Regulation regarding 2024 fishing opportunities.
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Document type: Statement
NGOs call on you to set sustainable, ecosystem-based fishing limits for 2024
A group of environmental NGOs has called on the Spanish Minister of Agriculture, Fisheries and Food to lead the EU in setting 2024 fishing limits based on scientific advice rather than exceeding it. The letter highlights failures in the Common Fisheries Policy (CFP) to end overfishing by 2020 and notes specific crises in the Baltic Sea and Northeast Atlantic. The NGOs argue that overfishing undermines marine biodiversity and the capacity of oceans to mitigate climate change, urging the adoption of an ecosystem-based approach, the elimination of bycatch, and increased transparency in decision-making.
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Document type: Statement
Joint NGO feedback to the European Commission on the “Sustainable fishing in the EU: state of play and orientations for 2024” consultation
A joint response from eleven NGOs arguing that the EU has failed to meet binding obligations to end overfishing and wasteful discarding. The document calls for Total Allowable Catches (TACs) to be set at or below scientific advice, the implementation of Remote Electronic Monitoring (REM) to enforce the landing obligation, and the integration of climate adaptation and ecosystem-based approaches into fisheries management.
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Document type: Statement
Legal Study on the Relationship between Certain Aspects of the Common Fisheries Policy Basic Regulation and Key Provisions of the Nature Restoration Regulation Including an Evaluation of Existing Options on Improving the Joint Recommendation Procedure and Proposal of Additional Options
The report examines the legal friction between the EU's Common Fisheries Policy (CFP) and the proposed Nature Restoration Law (NRL). It argues that the CFP's Article 11 'joint recommendation' process—used to protect marine areas from fishing—is plagued by delays, a de facto veto for fishing states, and a lack of accountability, which risks undermining the binding restoration targets of the NRL. The author proposes that the NRL be drafted with specific triggers and deadlines to force the CFP process forward and recommends that the European Commission take a more active role as a facilitator and mediator to prevent the watering down of environmental protections.
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Document type: Research paper
Towards a sustainable blue economy in Sweden
The report examines Sweden's maritime sectors—including blue food, offshore energy, tourism, and shipping—and argues for a shift from a sector-based approach to a multifunctional, ecosystem-based model. It identifies significant growth potential in offshore wind and sustainable aquaculture but warns that the current state of marine ecosystems is dire. The document recommends national coordination of marine spatial planning, the adoption of net-zero goals for maritime transport, and the modernization of regulatory frameworks to support circular and fossil-free technologies.
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Document type: Report
NGOs call on you to end overfishing when agreeing fishing limits for 2023
The document is a letter from a group of NGOs to the Czech Minister for Agriculture, arguing that the EU has failed its legal obligation to end overfishing by 2020. The authors call for the 2023 fishing limits to be based on the best available scientific advice from the International Council for the Exploration of the Sea (ICES) and the application of an ecosystem-based approach. Specific concerns are raised regarding the Baltic Sea cod crisis and the fact that 28% of assessed stocks in Northeast Atlantic waters remain subject to overfishing. The NGOs advocate for 'climate buffers' to protect species vulnerable to climate change and the implementation of remote electronic monitoring (REM) to ensure compliance with landing obligations.
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Document type: Statement
Russia’s War in Ukraine Is a Stress Test of Norway’s Public Debate – Peace Research Institute Oslo (PRIO)
The authors contend that Norway's public debate regarding the war in Ukraine has become overly emotional and ideologized, hindering the ability to discuss complex strategic dilemmas. They call for a more open discourse on NATO's role, the implications of NATO expansion into Finland and Sweden, the potential for EU membership, and the risks associated with food and energy price hikes.
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Document type: Statement
The Incremental Approach to Governing Mercury
The document traces the path from the 1972 Stockholm Conference to the 2017 entry into force of the Minamata Convention on Mercury. It highlights the role of activism and scientific evidence in driving global action and details the treaty's mechanisms for phasing out mercury-added products and regulating artisanal and small-scale gold mining (ASGM). The brief also explains that the discrete nature of mercury's industrial sources and a stronger scientific consensus on its global threat allowed it to move toward a binding treaty, whereas lead and cadmium remain managed through voluntary partnerships and regional agreements.
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Document type: Policy brief
The Sustainable Food Systems Initiative Framework
ClientEarth critiques the current EU agricultural and fisheries policies for failing to meet sustainability targets and urges the European Commission to adopt a new, comprehensive legislative framework. The organization argues that existing tools like the Common Agricultural Policy (CAP) and Common Fisheries Policy (CFP) are insufficient or poorly implemented. It advocates for an 'umbrella law' that covers the entire food value chain, integrates fundamental rights and access to justice, and utilizes public procurement to drive systemic change toward environmentally positive and healthy food systems.
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Document type: Statement
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.
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Document type: Statement
COMMON FISHERIES POLICY: MISSION NOT YET ACCOMPLISHED
The report argues that while the CFP provides a strong legal framework, it has failed to meet its 2020 deadline to end overfishing due to Member State inaction, insufficient Commission oversight, and industry resistance. It identifies nine critical challenges, including the dire state of the Mediterranean Sea, poor compliance with the landing obligation, and the absence of climate change considerations in the policy. The authors call for a transition to low-impact fisheries, the elimination of harmful subsidies, and the use of remote electronic monitoring to ensure sustainability.
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Document type: Report
20210512_joint-ngo-ec-letter-misleading-info-re-overfishing-4c87338e489b830f.pdf
The document challenges the European Commission's claim that 99% of fish bought by consumers come from sustainable sources, arguing this figure focuses on landing volumes rather than the number of stocks. It cites STECF data showing that 43% of North East Atlantic and 83% of Mediterranean stocks are overfished, and notes that the number of stocks outside safe biological limits in 2019 (17) is the same as in 2013.
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Document type: Statement
How energy taxation can end destructive fishing
The report examines how fuel subsidies artificially lower operating costs, enabling overfishing and the expansion of industrial fleets at the expense of small-scale fishers and marine ecosystems. It posits that removing these subsidies is essential for meeting EU climate and biodiversity goals, as well as international obligations under the WTO and the Paris Agreement. The author identifies the revision of the Energy Taxation Directive (ETD) as a critical opportunity to end fuel tax exemptions, suggesting that resulting revenues and existing funds like the Just Transition Fund be used to support low-impact fisheries.
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Document type: Report