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The document expresses alarm over widespread non-compliance with the landing obligation and argues that current management approaches, such as setting Total Allowable Catches (TACs) based on scientific catch rather than landings, undermine the goal of minimizing unwanted catches. The NGOs recommend rectifying shortcomings in the North Western Waters bycatch reduction plan, tightening the criteria for exemption requests, and introducing Remote Electronic Monitoring (REM) to ensure accurate catch documentation.

The document expresses concern over the lack of action by the North Western Waters regional group in developing ambitious bycatch reduction plans for Irish Sea whiting, West of Scotland whiting and cod, Celtic Sea cod, and plaice in area 7h-k. The signatories argue that current draft plans are vague and rely on existing measures, failing to address the 'dire state' of stocks for which ICES issued zero catch advice for 2019. They request the Commission to monitor the process, ensure STECF review via a dedicated Expert Working Group, and confirm that bycatch TACs will be decreased or withdrawn if plans are insufficient.

ClientEarth and Seas At Risk recommend that the European Commission reject or strictly condition landing obligation exemptions that lack sufficient scientific evidence. They argue that 'temporary' exemptions should be limited to one year and tied to binding roadmaps for improving selectivity and survivability. The authors highlight a decline in the quality of data submitted for de minimis exemptions and warn that failing to account for dead discards in 'high survival' exemptions could increase fishing mortality and jeopardize Maximum Sustainable Yield (MSY) objectives.

The document examines how the transition from regulating landings to regulating catches under the Common Fisheries Policy (CFP) landing obligation complicates the monitoring of TACs. It highlights that 'top-up' calculations—adding previously discarded amounts to landings advice—are hindered by missing scientific data on discards, a lack of transparency regarding the European Commission's methodology, and the absence of official records for proposed top-up quantities. The author argues that without accessible data on fleet-segment discards and clear methodology, civil society cannot verify if TACs align with scientific advice or the MSY objective.

The document outlines five key priorities for the 2019 discard plan joint recommendations (JRs), emphasizing that the landing obligation must cover all species subject to catch limits and that exemptions must be based on rigorous scientific evidence. The authors argue against using de minimis exemptions to solve quota-related choke issues and call for improved documentation of discards to ensure reliable stock assessments.