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European Oceans Pact Call for Evidence
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.
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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
Case C-330/22 on fishing opportunities and the 2020 MSY Deadline
The CJEU ruled in case C-330/22 that the EU Council has a margin of discretion to set TACs above scientific advice for by-catch stocks within multiannual plans to avoid premature fishery closures. However, the Court affirmed that for target stocks, the MSY deadline is a strict obligation with no flexibility to depart from scientific advice. This overturned an earlier Advocate General's opinion which argued that the 2020 deadline applied to all stocks without exception.
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Document type: Briefing
The Ocean Is Not a Dumping Ground
The document reviews the history of ocean dumping regulations, focusing on the London Convention and Protocol, and examines the challenges of enforcing these rules against radioactive waste and emerging climate mitigation technologies.
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Document type: Policy brief
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
Future fishery conflict narrative scenarios
The document presents four science-based narrative scenarios for fishery conflicts occurring between 2030 and 2060. These scenarios are designed to address a gap in existing projections by incorporating broader societal trends alongside environmental stressors like climate change and overfishing. The scenarios focus on the North-East Atlantic, the East China Sea, the coast of West Africa, and the Arctic, serving as tools to enhance anticipatory governance for ocean security.
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Document type: Research paper
ClientEarth’s feedback to the Offshore Renewable Energy Strategy Roadmap
ClientEarth's feedback on the EU's Offshore Renewable Energy Strategy emphasizes the need for high environmental standards, public transparency, and regional cooperation. It argues that the strategy must adhere to the 'do no harm' principle and the precautionary principle, ensuring that the deployment of offshore wind and other ocean energies does not compromise biodiversity or ignore the rights of public participation under the Aarhus Convention. The document suggests a regional approach to grid development and targeted financial support for technologies that have not yet reached grid parity, such as wave energy.
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Document type: Statement
No EU aid for fleet renewal or the modernisation of fishing vessels
A coalition of NGOs argues that reintroducing subsidies for fleet renewal and vessel modernisation would increase overcapacity and overfishing, contradicting the Common Fisheries Policy (CFP) and international commitments like UN SDG 14. The authors contend that capacity ceilings based on tonnage and power are inadequate measures of fishing ability and that engine modernisation is difficult to control due to under-declaration of power. They propose redirecting funds toward crew safety training, research into selective fishing gear, and stock recovery, noting that the majority of small-scale fishers benefit more from recovered stocks than from vessel subsidies.
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Document type: Statement