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ClientEarth urges the European Commission to use the European Oceans Pact to move beyond 'paper parks' and policy silos. The organization calls for a systemic approach to enforcement of the Common Fisheries Policy and Habitats Directive, the creation of an EU Ocean Fund to replace the EMFAF, and the phasing out of fossil fuel subsidies in the maritime sector. It advocates for legally binding targets to protect 30% of EU seas by 2030 and a ban on destructive activities like bottom trawling in all Marine Protected Areas.

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.

The report argues that the UK, the Netherlands, and Germany are in breach of the EU Habitats Directive by failing to implement effective management measures for the Dogger Bank SACs. It concludes that most bottom-contacting fishing gears cause significant harm to the H1110 sandbank habitat and should be halted to restore the site's integrity.