EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 5.2.2009 
SEC(2009) 103 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL 
On a European Community Plan of Action  for the Conservation and Management of 
Sharks 
IMPACT ASSESSMENT  
{COM(2009) 40 final} 
{SEC(2009) 104} {SEC(2009) 106} 
 
EN II   EN TABLE OF CONTENTS 
Executive Summary .............................................................................................................. ... IV 
1. Procedural issues and consulta tion of interested parties.............................................. 6 
1.1. Organisation and timing............................................................................................... 6 1.2. Consultation and expertise ........................................................................................... 6 2. Problem definition........................................................................................................ 7 2.1. Issues requiring action.................................................................................................. 7  
2.2. Underlying drivers of the problem............................................................................... 9 2.3. Who is affected?......................................................................................................... 1 2 
2.4. How would the problem evolve? ............................................................................... 16 2.5. Right to act .............................................................................................................. ... 19 
3. Objectives.................................................................................................................. . 20 
3.1. Policy objectives and scope ....................................................................................... 20 3.2. Consistency with other EU policies ........................................................................... 23 4. Policy options............................................................................................................. 2 4 
5. Analysis of impacts.................................................................................................... 25 5.1. Option A.................................................................................................................. ... 25 
5.1.1. Environmental impacts............................................................................................... 25 
5.1.2. Economic impacts ...................................................................................................... 27  
5.1.3. Social impacts .......................................................................................................... .. 29 
5.1.4. Risks, trade-offs / synergies, public opinion, enhancing measures............................ 31 5.2. Option B.................................................................................................................. ... 31 
5.2.1. Environmental Impacts .............................................................................................. 31 5.2.2. Economic Impacts...................................................................................................... 34  
5.2.3. Social Impacts .......................................................................................................... .. 39 
5.2.4. Risks, trade-offs/synergies, publ ic opinion, enhancing measures.............................. 41 
5.3. Option C.................................................................................................................. ... 43 
5.3.1. Environmental Impacts .............................................................................................. 43 5.3.2. Economic Impacts...................................................................................................... 43  
5.3.3. Social Impacts .......................................................................................................... .. 45 
 
EN III   EN 5.3.4. Risks, trade-offs/synergies, publ ic opinion, enhancing measures.............................. 46 
6. Administrative and management costs....................................................................... 46 7. Comparing the options ............................................................................................... 47 7.1. Option A: Status quo.................................................................................................. 48 7.1.1. Advantages.............................................................................................................. ... 48 
7.1.2. Drawbacks............................................................................................................... ... 48 
7.2. Option B: Proposed Fields of Action......................................................................... 48 7.2.1. Advantages.............................................................................................................. ... 48 
7.2.2. Drawbacks............................................................................................................... ... 49 
7.3. Option C: Strict Precautionary Approach .................................................................. 49 7.3.1. Advantages.............................................................................................................. ... 49 
7.3.2. Drawbacks............................................................................................................... ... 49 
7.4. Preferred option.......................................................................................................... 50 
8. Monitoring and evaluation ......................................................................................... 59 APPENDIX I..................................................................................................................... ....... 63 
APPENDIX II .................................................................................................................... ...... 72 
APPENDIX III ................................................................................................................... ...... 79 
1. Administration costs of Option B .............................................................................. 79 
1.1. Phase 1 Preparatory Analysis..................................................................................... 79 1.2. Phase 2: Data capture and standardization................................................................. 80 1.3. Phase 3: Calculation and reporting ............................................................................ 83 2. Administration costs of Option C .............................................................................. 89 3. management costs (Option B and C) ......................................................................... 93 4. Management and administ ration cost estimates......................................................... 96 
APPENDIX IV.................................................................................................................... ..... 97 
APPENDIX V ..................................................................................................................... ..... 99 
APPENDIX VI.................................................................................................................... ... 103 
 
EN IV   EN COMMISSION STAFF WORKING DOCUMENT 
accompanying 
the 
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL 
On a European Community Plan of Action for the Conservation and Management 
of Sharks 
EXECUTIVE SUMMARY  
This Impact Assessment (IA) concerns a proposal for a Co mmunication from the 
Commission to the European Parliament a nd the Council on a European Community Plan 
of Action for the Conservation and Management  of Sharks. The report has been drafted 
taking into consideration the results of pub lic and institutional consultations and a study 
commissioned from a private consultant on this subject. 
Three policy objectives and nine fields of action were initially envisaged by the draft 
submitted for consultation. Following the consul tation process, the fields of action have 
been reduced to five, by merging some of them while retaining all the particular 
measures initially proposed. 
The main policy objectives remain the same: 
(1) Broaden the knowledge both on shark fisheries and on shar k species and their role 
in the ecosystem. 
(2) Ensure that directed fisheries for shar k are sustainable and that by-catches of 
shark resulting from other fi sheries are properly regulated. 
(3) Encourage a coherent approach between the internal and external EC fishery 
policy for sharks. 
The policy options analysed by this IA are as follow: 
Option A : Status Quo with no Action Plan. 
Option B : Several fields of Action to be addressed (with the possibility for "hard" and 
"soft" sub-options). 
Option C : Application of a strict  precautionary approach. 
Following a detailed study of the environmen tal, economic and social impacts of each 
option and each field of action, the range of  measures initially proposed under the re-
arranged five fields of action has been slig htly reduced, mainly because other bodies are 
 
EN V   EN already dealing with them and in order to ensure a balance between available resources 
and effectiveness. However, a new measur e has been added (co-operation through the 
Convention on Migratory Species –CMS- and the Convention on Inte rnational Trade in 
Endangered Species of Wild Fauna and Flora -CITES). 
The IA therefore concludes that  the preferred option is an amended version of Option B. 
The main elements of the selected option comprise measures for data collection and 
scientific advice, management and technica l measures and further limitations on shark 
fining practices. The fields of action and co rresponding measures included in the revised 
draft Community Plan of Action (CPOA) are se t out in Section 7.4 of the present Impact 
Assessment and in the table annexed to  the Communication to the Commission. 
Finally, a series of impact indicators (of the broad CPOA policy objectives) and result 
indicators (for the specific aims of the i ndividual fields of acti on) have been proposed. 
In summary, there are long-term negativ e impacts associated  with the present status quo . 
The actions under option B shoul d go along way to reversing t hose impacts, particularly 
within Community waters, without unacceptabl e social and economic short-or medium 
term impacts. 
 
EN 6   EN Lead DG:  DG MARE 
Other involved services: DG ENV, DG RTD, DG DEV and the SG.  
Agenda planning reference: 2009/MARE/001 
1. PROCEDURAL ISSUES AND CONSULTA TION OF INTERESTED PARTIES  
1.1. Organisation and timing 
This impact assessment concerns a proposal  for a Communication from the Commission 
to the European Parliament and the Council  on a European Community Plan of Action 
for the Conservation and Management of Sharks. Its development is foreseen in Agenda Planning 2009/MARE/001 (Commission Comm unication on an EU Action Plan for 
sharks) and in the 2008 Annual Management  Plan of the Directorate General for 
Maritime Affairs and Fisheries under the spec ific objective "Improve  the governance of 
shark fisheries and ensure the su stainability of shark stocks". 
On 16 October 2007, an inter-service steeri ng group on an EU Plan of Action for the 
Conservation and Management of Sharks was convened by note of the DG FISH General 
Director to DGs ENV, RTD,  DEV, AIDCO, TRADE, RELEX, SANCO, the LS and the 
SG. Four meetings of the steeri ng group have taken place so fa r, with the pa rticipation of 
DGs MARE, RTD, ENV, DEV and the SG. 
On 13 March 2008, a contract has been signed between an external consultant and the 
Commission to carry out a study concerning the Impact Assess ment of the Commission's 
projected Plan of Action. The final report of this study has been delivered by the 
consultant on 18 July 2008. 
The adoption of the Communication by the Commission is foreseen in January 2009. 
1.2. Consultation and expertise 
As a first step of this assessment, the Commission identified nine fields of action that it 
believed should be addressed in an EU Action Plan for Sharks. 
On 11 December 2007, DG MARE launched a public consultation process through " Your 
Voice in Europe " on the measures to take, whic h was completed in March 2008. 
Furthermore, during the first part of 2008, the Commission services had contacts and 
exchange of views with NGOs and stakeholde rs and formal institutional consultations 
with all the RACs (Regional Advisory Councils), the ACFA (Advisory Committee on 
Fisheries and Aquaculture) and the STEC F (Scientific, Technical and Economic 
Committee on Fisheries).  
The input received in the consultation process has been used to info rm this report and the 
impact assessment of the envisaged Action Pl an. Appendix I to this report presents a 
brief summary of the contributions made by stakeholders to the EC. 
On 29 September 2008 the Impact Assessment Board issued its opinion on the 1 
September 2008 version of the draft im pact assessment report. The Board's 
 
EN 7   EN recommendations have led to changes which are included in the present draft. They can 
be summarised as follows: 
• The report has been re-structured to provi de more information on the general policy 
context and to improve the presenta tion and analysis of the options. 
• The analysis of option A better demonstrates the problems to be solved and the 
rejection of option C has been further justified. 
• Economic, social, trade and international cooperation c onsiderations have been 
incorporated to section 2.2. 
• Basic information on fisheries and areas most  concerned has been included in section 
2.3. 
• Further references to the EU and interna tional policy context in which the CPOA will 
be developed have been included in s ection 3.2 (Johannesburg World Summit, CFP 
reform, Communication on dis cards and IUU Regulation). 
• The policy objectives, scope and aimed vessels  of option B have been clarified and 
further developed in sections 4 and 5. 
• The operational objectives have been rede fined in order to make them "SMART". 
• Administrative and management costs ha ve been extended in section 6 and a 
comprehensive presentation about the es timation which was used is given in 
Appendix III. 
• Option B is now analysed at the same level of  detail than options A and C in the main 
text. 
2. PROBLEM DEFINITION  
2.1. Issues requiring action 
Despite their known vulnerabil ity to overfishing, chondricht hyans (sharks, rays and 
chimaeras) have been increasingly exploited in recent decades. A number of factors are 
responsible for this trend, in cluding improvements in fishing technology, processing and 
consumer marketing, expanding human populations and declines in other fish stocks, all 
of which have made sharks a more valuable fisheries resource. Thus , shark fisheries have 
experienced rapid growth since the mid-1980s  due to an increased demand for shark 
products (fins in particular, bu t also meat, skin, cartilage, etc), especially in Asian 
markets. Between 1984 and 2004, world catches  of sharks grew from 600,000 to over 
810,000 metric tons. In addition, many thousands of  sharks have been taken accidentally 
in tuna longline fisheries every year  since their introduction in the 1960s. 
Shark populations are generally fragile when targeted by unregulated fisheries, resulting 
in a pattern of “boom and bust”. Rising catch es are followed by rapid declines and very 
slow recoveries when stocks are protected. 
 
EN 8   EN Roughly one-third of European shark species o ccurring in the EU waters are considered 
by IUCN to be threatened with extinction. Of the pelagic species, porbeagle Lamna nasus  
has been assessed as Critically Endangered in the Northeast Atlantic and Mediterranean Sea, the shortfin mako Isurus oxyrinchus  is Critically Endangered in the Mediterranean, 
the white shark Carcharodon carcharias  is Endangered in the Mediterranean, and the 
basking shark Cetorhinus maximus  is Endangered in the Nort heast Atlantic. The blue 
shark Prionace glauca  is assessed as Vulnerable in th e Mediterranean. Deepwater sharks 
are of particular concern: in the Northeast Atlantic, the gulper shark Centrophorus is 
Critically Endangered whilst th e leafscale gulper shark Centrophorus squamosus  and 
Portugese dogfish Centroscymnus coelolepis  are both Endangered here. Two species of 
smoothhound Mustelus asterias  and Mustelus mustelus  are assessed as Vulnerable in the 
Mediterranean. Also of partic ular concern in European waters is the spiny dogfish 
Squalus acanthias , which is assessed as Critically Endangered in the Northeast Atlantic 
and Endangered in the Mediterranean. 
The high value and demand for fins has led to the highly wasteful practise of cutting off 
the fins and discarding the carcasses. This practice is banned by all RFMOs and under 
Council Regulation (EC) No. 1185/2003, but cutt ing the fins on board and keeping the 
carcasses is allowed under certain conditions. Thus, member States are permitted to issue 
Special Fishing Permits (SFP) that allow der ogation from the prohibition to remove shark 
fins at sea provided they do not have onboard more than  5% live weight of fins. 
However, this measure does not guaranty th at finning practices are 100% prevented. In 
2006 approximately 216 vessels (mostly Spanish) obtained this derogation, down from 232 in 2004. For other parties of RFMO’s, the current state of implementation of the 
shark finning ban is unknown. 
Within the framework of the Code of C onduct for Responsible Fisheries, the FAO 
adopted in 1999 the Inte rnational Plan of action for the conservation and management of 
sharks (IPOA SHARKS). This international plan  is voluntary but all concerned States are 
encouraged to implement it. It therefore fore sees the implementation by States of national 
plans to ensure the conservation, management  and long-term sustai nable exploitation of 
shark following the guidelines of the IPOA. 
The ability to manage elasmobranch stocks in both European waters and elsewhere is 
severely limited by the lack of detailed info rmation on catches, discards and landings. 
Traditionally, however, not only have catch es, discards and landings been under-
recorded, but trade in shark products has b een poorly understood and trade statistics are 
poor. 
For both EU and non-EU fleets, species cau ght are often aggregated under generic 
headings such as inter alia rajiformes, sharks nei, elas mobranchii, preventing a clear 
distinction of catches by spec ies, and therefore robust basi s for stock assessment. This 
may be caused by the inability of fishing masters to formally identify the various shark species and/or reluctance to declare catches of individual species si nce some of them may 
be under special status (IUCN red list, CITES listing). 
The European Community has the exclusive co mpetence for the management of fisheries 
resources; however, it has not yet developed an  EC Plan of Action for sharks, although it 
has adopted a number of measures aiming dire ctly or indirectly at the conservation and 
management of sharks. However, the range of existing measures is clearly insufficient to 
 
EN 9   EN ensure the rebuilding of ma ny depleted stocks fished by the Community fleet in 
Community and outside Community waters . Furthermore, given its weight at 
international level, the Community should assu me a leading role in the development of 
policies aiming at the rational exploitation  of fishing resources. Therefore, the 
Commission has foreseen the adoption at the end of 2008 of  a Communication on an EC 
Plan of Action for the Conserva tion and Management of Sharks. 
2.2. Underlying drivers of the problem 
Biological considerations  
In general, chondrichthyans have life hist ories characterised by low fecundity, large 
young, slow growth, late matur ity, long life and high surviv al of all age classes. 
This suite of life history characteristics re sults in low reproducti ve potential and low 
capacity for population increase, which has serious implications for chondrichthyan 
populations, as they limit thei r capacity to recover from ov er-fishing or other negative 
impacts. In contrast to teleosts, the recruitm ent of sharks to the adult population is very 
closely linked to the number of mature, br eeding females (Holden 1974). The result is 
that, as mature animals are caught, the produc tion of offspring that will support future 
generations also declines, which in turn limits future productivity of the fishery and the ability of chondrichthyan populat ions to recover from overfishing. In this respect, the 
reproductive potential and strategies of the chondrichthyans are more closely related to 
those of the cetaceans, large land mammals and birds than to the teleost fishes. Hence, 
long recovery periods are needed  in response to over-fishing. 
Data availability considerations
 
The European Commission is aiming to base  the management of shark fisheries 
following the management advice of independent International Scientific Fora, as well as 
the recommendations of the Regional Fisher ies Management Organisations (RFMOs). A 
crucial element of the present European  Community’s action plan will be the 
improvement of the knowledge on directed fish eries as well as on in cidental catches of 
sharks. 
Catch data for elasmobranchs in the ICES ar ea are poor, and there are several reasons for 
this. Landings data are not indicative of catch  levels because of the high discarding of 
some species. Even the available landings data for elasmobranchs are unreliable. Elasmobranchs are often not considered  of high commercial importance, and 
consequently not always recorded in offici al records, many fisheries are unregulated, 
some commercial teleost species may be misr eported as elasmobranchs, and the use of 
the more inappropriate, generic reporting categories hampers analyses. Methods to 
estimate elasmobranch catch data included sampling of mixed landings; establishing 
ratios of elasmobranch to target species , based on observers da ta, interviews with 
fishermen, processors and/or g ear manufacturers; and correl ating generic landings data 
with indicator species in official data (ICES, 2007). 
Concerning the European fleets, there are no data available on dis card rates of sharks 
species. The 2006 STECF Working Paper on dis cards from Community  vessels did not 
include any shark species in the 27 ‘p riority species’ lis ted (STECF, 2006). 
 
EN 10   EN The main data gaps are quite similar across the external fisheries exploited by European 
vessels. The quantity of sharks declared by the European vessels reflect basically the quantities retained onboard as per the reporti ng obligations imposed by the competent 
RFMO’s. However, raw data on total catche s and portion thereof di scarded have been 
collected through independent scientific observations, notab ly under the requirements of 
the Data Collection regulation. No  analysis of these discard da ta have been placed in the 
public domain so far. 
Considerations on the nature of the fishery
 
One of the most essential problems for the ma nagement of sharks in EC waters is the 
mixed nature of demersal fisheries, which makes it very difficult to target protective 
action on sharks without severe consequences  on the other species caught. Furthermore, 
the large overcapacity of the fleets that catch small sharks, skates and rays as by-catch in 
demersal fisheries is also an important driver  of the management problems in this area. 
Economic and social considerations  
An estimated 41% percent of the total value of all shark catches made by EU vessels is 
made from catches in the Northeast Atlantic , where most EU landings are skates, rays 
and dogfish. French vessels account for 37% of  the value of shark catches made in the 
North Atlantic and Spain 25%. Catches in the Central and Southern Atlantic (mainly by 
Spain and Portugal) are even more important representing 47% of the total value of EU 
catches of sharks1. The Indian Ocean (again mainly Spain and Portugal) accounts for 6%, 
and the Pacific (mainly Spain) for 2%. Almost  all landings in the Central and Southern 
Atlantic, Indian and Pacific Oceans are blue and mako shark. The Mediterranean 
accounts for just 3% of the total value of EU  shark catches. In the Southern Oceans the 
very small catches of less than 100 tonnes per year are mostly rays. The total catches of 
elasmobranchs must also be seen in the cont ext of total EU catches for all species - in 
2005, the volume of landings was recorded at 5.6 million tonnes, meaning that catches of 
elasmobranch represent just 1.8% of the to tal volume of landings. While in 2006 landed 
values for the EU-15 are recorded as Euro  6.68 billion, meaning that elasmobranch 
catches represent 2.9% of the value of landings. 
The main socio-economic indicators of the nu mber of vessels and employees that could 
to some extent be dependent upon elasmobran ch catches and which might therefore be 
affected by measures proposed under the CP OA are summarised in Table 1. Given the 
lack of data available on specific species being caught by specific fleets and the mixed 
nature of fisheries in Northern waters and th e Mediterranean, it is impossible to state with 
any accuracy the number of vessels actually re lying on shark catches in these areas. This 
necessitates an approach in estimating the socio-economic benefits which includes all 
vessels in each fishing area using g ears that could be catching sharks. 
In Northern waters and the Mediterranean this  results in average catches per vessel that 
are low, with average individual vessel depe ndencies typically between 2-5% of total 
values. The average catch volumes and valu es per vessel are however sure to hide 
significant differences between different vessels/metiers in each country, and in addition 
                                                 
1 Note that C&S Atlantic catches  are based on ICCAT data and include some pelagic shark catches 
made in Northern waters 
 
EN 11   EN are almost certainly an underestimate b ecause an unknown proportion of the vessel 
numbers in the table below may not catch any shark species at all. The lack of 
information on specific metiers in Northern wa ters catching sharks also means that it is 
not possible to make any meaningful estimates  about the percentage of total income for 
those particular metiers that might  be made up of shark catches.  
For surface longline vessels operating in the In dian Ocean and Pacific, shark catches are 
estimated to contribute around 40% of catch  volumes and 20-25% of total incomes. 
While in the Central and Sout hern Atlantic, shark catche s are around 65-70% of total 
catch volumes (the remainder being swordfish and tuna), and may contribute between 35-
45% of total catch values. 
The almost certain over-estimate of vessels  in Northern and Mediterranean waters 
potentially catching sharks also means that caution should be expressed in the estimates 
of the numbers of catching and processing la bour potentially involve d with shark catches 
– these estimates are also certain to be an ove r-estimate, but there is no way to refine the 
assessment given current data deficiencies, a de ficiency which is part of the very reason 
for the proposed CPOA.  
Table 1: Summary of the value and c ontribution of elasmobranch landings & 
downstream employment (MRAG Study on th e impact of measures under the CPOA on 
Sharks –July 2008-). 
RegionValue of 
elasmobranch 
landings (€ 
million)Contribution to 
total EC-15 
value of 
landingsMaximum 
EU vessels 
involvedAverage value 
of catch per 
vesselMaximum 
catching 
sector 
employmentMaximum 
processing/ 
ancillary 
sector 
employmentAverage 
value of 
landings 
per 
employee
NE & NW Atlantic 81.2                    1.22% 20 458 € 3 968 42 274 28 141 € 1 153
Mediterranean 5.7                      0.09% 32 727 €  175 63 140 20 160 €  69
C&S Atlantic 93.0                    1.39% 200 € 464 946 3 296 2 039 € 17 430
Indian Ocean 11.8                    0.18% 103 € 114 501 1 960 1 340 € 3 573
Pacific 4.1                      0.06%  12 € 340 853  224  140 € 11 248
Total / Average 195.8                  2.93% 53,500             € 184 889 110,894           51,820             € 6 695  
Trade considerations  
The demand for and the value and volume of shark products in trade have increased 
considerably over the past 15 years and continue to rise. 
The shark biomass represented by the global fi n trade is estimated to lie between 1.21 
and 2.29 million t/year with a median of 1.70 m illion t/year. This is some three to four 
times higher than indicated by FAO’s landings da ta. It should be stressed that only those 
sharks whose fins are taken fo r use in the international shark fin trade are represented in 
these estimates. Sharks which are a) discarded dead; b) released but subsequently die due 
to injury or stress; or c) are retained but w hose fins are either not used at all or used 
within the country of landing are not accoun ted for, therefore these estimates are 
considered to be minimum values. (Clarke S.C. 2008). 
Given what now appears to be a strong linka ge between shark catches and the volume of 
the fin trade, several leading shark scientis ts have called for urge nt consideration of 
effective fisheries management measur es for sharks (Dulvy et al. 2008). 
 
EN 12   EN International cooperation considerations  
In the North Atlantic, nearly two thirds of the total catch of shark species is made by the 
EC fleet. It is not possible to clearly establis h the share of the EC fleet in other areas of 
the world due to the lack of data, but for the most commercially important species EC 
catches in all waters are also almost two thirds of the total world catches. 
One of the stated specific obj ectives of the Plan of Actio n is "to ensure a coherent 
approach between the internal and external EC fishery policy for sharks". For some species, such as small-spotted catshark, and spurdog, most of the world catches are made 
by the EC fleet and in these cases internationa l cooperation is not so important to achieve 
their long term sustainable use. However, for other species, such as blueshark or shortfin 
mako the part of foreign fleet catches is  much more important and international 
cooperation is an essential element to achieve the general objective of  sustainable use of 
these species. 
2.3. Who is affected? 
The CPOA has the potential to impact on a wide number of stakeholders. It is recognised 
that a successful CPOA will have long-term be nefits to all, but its implementation may 
have implications for some re sources users. This impact assessment will aim to capture 
the economic, environmental and social cons equences for the affected stakeholders. 
As a framework for this assessment, the main  stakeholders have been identified as 
follows: 
Table 2: Key stakeholders in EU shark fishing effort 
Stakeholder Description Key interests 
Catching 
sector EC vessel owners, operators and crew. M aintaining profitability and livelihoods. 
Dependent 
businesses & 
communities  Business and communities dependent 
upon shark fisheries for their 
livelihoods. Maintaining profitability and livelihoods. 
Processing 
sector Those processing raw material from 
the EC shark catch (target and 
retained bycatch) Maintaining profitability and livelihoods. 
Sector 
regulators Regional, national and provincial 
bodies regulating EC shark fishing 
effort  Ensuring an efficient, effective and 
practical management framework that 
balances a wide range of stakeholder 
needs. 
Sector research Scientific research bodies contributing 
to the conservation and management 
of shark stocks. Contribution to an effective fisheries 
management regime through the timely 
access to high quality, robust data from fishery dependent and independent 
sources. 
Retailers Organisation selling shark and shark 
products to consumers Continuity of supply and, increasingly, 
sustainable credentials of the resource. 
Consumers Those persons consuming shark Availa bility, cost and quality of shark-
 
EN 13   EN products derived products with varying degrees of 
environmental scrutiny. 
NGOs Non-governmental organisations 
advocating responsible management 
of shark populations. To secure responsible, science-based 
shark fishing limits for long-term 
sustainability and ecosystem health. 
Civil society The wider public with an interest in 
and concern for, the sharks in 
particular and the marine environment in general To maintain shark populations and 
diversity. 
 
EN 14   EN The main fisheries involved and the priority for action have been identified as follows: 
Table 3: Summary risk table showing priorities for action 
Region (RFO) Nationality 
(EU only) Main Gear 
type Species Vulnerability (IUCN cat) Exposure and vulnerability Priority for 
action 
NE Atlantic 
skates and rays 
(ICES) France, UK, 
Spain, Portugal, 
Ireland & 
Belgium Trawl, nets Various skates, rays and small 
shark species Range from CR (common 
skate), EN (sandy white 
skate) to LC High volume mixed fishery including 
some with high vulnerability High 
NE Atlantic 
deepsea sharks (ICES) UK and 
Germany Gillnet & 
longline Portuguese dogfish 
Gulper shark EN 
VU/EN Low volume catch but probable high 
discards High 
Italy, Greece, 
Spain, France Gillnets Smoothhound, tope, spurdog VU Large number of vessels in a mixed 
fishery with increasing catches of 
vulnerable species (e.g. smoothhound) Medium Mediterranean 
(GFCM) 
Italy, Greece, 
Spain, France Trawl Various skates, rays, guitarfish 
and small shark species Ranges from EN(guitarfish), 
most VU, some LC Extensive mixed fishery including 
some with high vulnerability Medium 
Spain & 
Portugal Purse seine, 
Long lines Blue shark NT  High volume and medium sensitivity Medium Atlantic pelagic 
sharks (ICCAT) 
Spain & 
Portugal Purse seine, 
Long lines Mako, porbeagle VU Misreporting and high sensitivity High 
Long line Blue NT High volume Medium 
Long line Mako, porbeagle VU Misreporting and high sensitivity High Indian Ocean 
pelagic sharks 
(IOTC) Spain & 
Portugal 
Purse seine Unknown ?? Little known exposure and 
vulnerability ?? 
Spain and 
Portugal Purse seine Silky shark, mako, porbeagle, & 
oceanic whitetip VU Little known exposure and high 
vulnerability Medium Pacific Ocean 
pelagic sharks 
(WCPFC) Spain Longline Blue shark, mako LC, VU Low volume catch with some high 
sensitivity (mako) Medium 
Southern Oceans 
(CCAMLR) Spain & France Longline Rajiformes  & Bathyraja  spp. Not determined, but 
probably LC Low volume and low sensitivity Low 
 
EN 15   EN Vulnerability key : Critically Endangered (CR), Endangered (EN), Vulnerable (VU), NT Near threatened (NT) and LC Least concern (LC) 
 
EN 16   EN 2.4. How would the problem evolve? 
A number of legal measures have been ta ken to date concerning aspects of the 
conservation and management of sharks at both at the international level and by the 
European Community.  
At international level, the mo st high profile development to date has been the adoption by 
FAO in 1999 of the International Plan of Action (IPOA) for the conservation and 
management of sharks (‘IPOA SHARKS’2). IPOA SHARKS, which was developed and 
adopted within the framework of the ‘Code  of Conduct for Responsible Fisheries’ 
(CCRF), is like the CCRF itself voluntary but all concerned States are encouraged to 
implement it. It therefore foresees the implementation by States of national plans to ensure the conservation, mana gement and long-term sustaina ble exploitation of sharks. 
Otherwise the main actions taken to date ha ve been undertaken by regional international 
fisheries management organi sations (RFMOs) including: 
• the Inter American Tropical  Tuna Commission (IATTC); 
• the International Commission for the Cons ervation of Atlantic Tuna (ICCAT); 
• the Indian Ocean Tuna Commission (IOTC); 
• the North Atlantic Fisheries Organisation (NAFO); 
• the General Fisheries Commission for the Mediterranean (GFCM); 
• the South East Atlantic Fish eries Organisation (SEAFO);  
• the North East Atlantic Fisheries Commission (NEAFC); 
• the Commission for the Conservation of Southern Bluefin Tuna (CCSBT); and  
• the Western and Central Pacific Fisheries Commission (WCPFC).  
The EU is party to most of these of RFMOs
3 and a cooperating non-party in respect of 
the remainder.4 The measures taken are of somewhat  limited effect and do not generally 
including binding management measures. 
It is also important to note that a number of steps have been undert aken at international 
level and by the European Community conc erning the regulation of  the international 
trade in sharks and shark products. Such activ ity has taken place within the auspices of 
the Convention on International Trade in Enda ngered Species of Wild Fauna and Flora 
                                                 
2 The FAO International Plan of Action for the Conservation and Management of Sharks considers 
the term “shark” to include all species of sharks, skates, rays, and chimaeras (Class 
Chondrichthyes). The EU Action Plan will follow the same approach. 
3 The EU is party to ICCAT, the IOTC, NAFO, GFCM, SEAFO, NEAFC and the WCPFC.  
4 The EU is a cooperating non-party to the IATTC although France and Spain are parties. The EU is 
also a cooperating non-party to the CCSBT. 
 
EN 17   EN (CITES) which was signed in Washington DC  in 3 March 1973. All 27 Members of the 
EU are Parties to CITES although the Comm unity itself is not . Nevertheless the 
provisions of CITES have been implemente d in European Community law since 1982. 
Within the European Community the basic legal framework for the implementation of 
CITES is contained in Regul ation Council Regulation (EC) No 338/97 of 9 December 
1996 on the protection of species of wild fa una and flora by regulating trade therein5, as 
amended (the CITES Regulatio n). A number of shark species namely basking shark 
(Cetorhinus maximus), great white shark ( Carcharodon carcharias) and whale shark 
(Rhincodon typus), are included in CITES Appendix II m eaning that trade in them is 
strictly regulated . 
Furthermore , the basking shark and the great white shark are listed on the Appendices I and 
II of the Convention on Migratory Species (CMS). The whale shark is listed on Appendix II of this Convention. 
Turning to measures undertaken by the Eu ropean Community, a number of measures 
have been taken that aim directly or indire ctly at the conservation and management of 
sharks. These measures have been adopted  within the context of the basic legal 
framework established by Council Regulat ion (EC) No 2371/2002 of 20 December 2002 
on the conservation and sustainable exploi tation of fisheries resources under the 
Common Fisheries Policy6 (‘the Framework Regulation ’). 
In general terms, as regards fishing opportuni ties for sharks, two type s of Regulations lay 
down the rules for shark directed fi sheries and by-catches of sharks: 
a) Bi-annual Council Regulations fixing the fi shing opportunities for Community fishing 
vessels for certain deep-sea fish stocks every two years, for EU and NEAFC waters; 
b) Annual Council Regulations fixing fishi ng opportunities and associated conditions for 
certain fish stocks, applicable in Community  waters and, for Community vessels, in 
waters where catch limitations are require d (including NEAFC, NAFO and CCAMLR).  
Moreover, Regulation (EC) N°  2347/2002 of 16 December 20027 establishes specific 
access requirements and associated conditions a pplicable to fishing for deep-seas stocks, 
among others a wide rage of deep-water sharks. 
In addition, mention must be made of Commission Regulation (EC) No 1639/2001 of 25 
July 2001 establishing the minimum and extended Community programmes for the 
collection of data in the fisheries sector and laying down detailed rules for the application of Council Regulation (EC) No 1543/2000
8, as amended, which includes sharks within 
the mandatory sampling schemes for data  collection. A new regulation under new 
framework for data collection (Council Regul ation (EC) No 199/2008 of 25 February 
2008 concerning the establishment of a Community framework for the collection, management and use of data in the fisher ies sector and support for scientific advice 
                                                
 
5 OJ L 61, 3.3.1997, p. 1 
6 OJ L 358, 31.12.2002, p 59. 
7 OJ L351, 28.12.2002. 
8 OJ L 222, 17.8.2001, p. 53. 
 
EN 18   EN regarding the Common Fisheries Policy does no t add anything new related to shark catch 
sampling. 
Other measures, although not shark specific, may have an important bearing on them, 
especially for those taken as  a by-catch. Among them, we should mention measures taken 
in the context of multi-annual plans in th e framework of Regulation (EC) N° 1967/2006. 
Nevertheless, the range of ex isting measures is clearly insufficient to ensure the 
rebuilding of many depleted stocks. Furt hermore, the Community should assume a 
leading role at international level in the development of policies aimed at the rational 
exploitation of fishing resources. 
The only regulation adopted to date that is ex clusively concerned with sharks is Council 
Regulation (EC) No 1185/2003 of  26 June 2003 on the remova l of fins of sharks on 
board vessels. This regulation was intended to prevent the practice of shark finning 
within the European fleet. Pursuant to Article 3 (1) it is prohibited to remove shark fins 
on board vessels, and to retain on board, tran ship or land shark fins. Furthermore the 
purchase, offer for sale and sale of shar k fins which have been removed on board, 
retained on board, transhippe d or landed in contravention of the Regulation is also 
prohibited.  
However by way of derogation Article 4 prov ides that, subject to certain specified 
conditions, the removal and retention of shark fins from dead sharks on board and the 
transhipment or landing of such fins may be  permitted with regard to vessels which hold 
a special fishing permit. Such permits may only be issued to fishing vessels where a capacity to use all parts of sharks has been  demonstrated and where the need for the 
‘separate processing on board of shark fins and the remaining parts of sharks has been 
justified’ (Article 4(2)). The discard of the remaining parts of  sharks after removal of the 
fins is prohibited (except for those parts re sulting from basic processing operations, such 
as beheading, gutting and skinning). 
Article 4 goes on to specify that the weight  of the fins kept from the catch may not 
exceed the theoretical weight of the fins that  would correspond to the remaining parts of 
sharks retained on board, transhipped or landed and that in no circumstances the 
theoretical weight may exceed 5%  of the live weight of the sh ark catch. This approach is 
often complementary to the one most comm only taken by third countries and RFMOs 
which seeks to apply a ratio of 5% of total weight of sharks reta ined on board, although 
there is some lack of clarity as to whether they refer to total live or dressed weight. 
Regulation 1185/2003 does not provide detailed indications as to the justification 
necessary to permit the separate processing onboard of shark fins. 
According to this Regulation, Member States shall send to the Commission 
comprehensive annual reports on its implemen tation. On the basis of  these reports, the 
Commission has issued on 23.12.2005 a report to  the European Parliament and the 
Council on the operation  of this Regulation
9. According to this re port, the information 
made available by the Member States to the Commission on the operation of this 
Regulation, although not always complete, amou nts to a confirmation that the Regulation 
                                                 
9 Report on the operation of Council Regulation (EC) N° 1185/2003 on the renoval of fins of sharks 
on borrad vessels. COM(2005)700. 
 
EN 19   EN appears to be achieving its general objectives . Therefore, the Comm ission concluded that 
the Regulation did not appear to need an am endment at that stage. However, improved 
implementation of some aspects by some Member  States was desirable,  "in particular in 
terms of the criteria for allocation of  special fishing permits or reporting". 
Finning regulations in other parts of the world ar e stricter than in the EU as they use the 
ratio between wet fins and the processed car cass (Fin/Dressed weight), instead of the 
ratio provided by the EC Regulation (Fin/live weight). The ratio most widely applied by 
third countries is 5% of wet fin weight to ‘dressed’ (gutte d and beheaded) carcass weight, 
or 2% of wet fin weight to whole shark (‘r ound’ or ‘live’) weigh (5% in the EU). The 
finning recommendations or resolutions adopted by RFMOS all include a fin/body 
weight ratio. The common wording is th at Contracting Part ies, Cooperating non-
Contracting Parties and other bodies (CPCs): “ Shall require their vessels to have on 
board fins that total no more than 5% of th e weight of sharks on board, up to the first 
point of landing ”. 
However, there may well be some species di fferences and also the way finning is carried 
out makes a difference. For example, Asian crews tend to remove just the fins whilst 
Spanish crew are reported to take a piece of m eat off with the fin. There is also the issue 
of whether the rule might be applied to live weight or dressed weight and which measure 
is the most practical. Fin weights as a pr oportion of round weight (FW:RW) and dressed 
weight (FW:DW) differ significantly for different species and fleets. 
Some stakeholders advocate a move to five percent of dressed weight ratio from five 
percent of whole weight or a complete, uneq uivocal ban on finning. The latter approach 
is often advocated as it removes difficulty  over species id entification, enforcement and 
leaves little room for abuse. 
More systematic work on this standard needs to be carried out in the context of this 
measure. Meanwhile, a precautionary appro ach would recommend the more conservative 
general rule (5% FW:DW) while providing for the status quo (5% FW:RW) for those been able to fully justify this need. 
There are clear indications of  reductions of shark populations. The true status of most 
elasmobranch populations, however, remains un certain due to lack of stock specific 
information particularly over significant tim e series. For example, the common skate and 
angel sharks have virtually disappeared from North Sea fisheries and ICCAT (2007) 
reported up to a 50% reduc tion for the population of Isurus oxyrinchus . How widespread 
such reductions are remains to be determined. It is also clear that the international trade 
in shark and shark products is increasing, thus providing a future driver for continued 
fishing pressure. The situation is likely to persist as a result of this driver.  
Under Section 5, we will further develop thes e aspects and examine the risks and trade-
offs of the status quo option. 
2.5. Right to act 
The right of the European Community to legi slate in the sphere of fisheries is long 
established and has led to the adoption of  a large body of s econdary legislation 
exclusively in the form of re gulations. The right to legislat e derives from the provisions 
 
EN 20   EN in Article 32 of the Treaty Establishing the European Co mmunity (as amended) (the 
‘Treaty’) concerning the establishment of a common market for agricultural products, 
which term includes fisheries products. Such  a common market is to be accompanied by 
a common policy which in terms of fisherie s is the Common Fisher ies Policy (CFP).  
The scope of the CFP is currently defined in Article 1 of the Framew ork Regulation so as 
to cover the ‘ conservation, management and exploitation of living aquatic 
resources…where such activities are practi sed …in Community waters or by Community 
fishing vessels ’.  
3. OBJECTIVES  
3.1. Policy objectives and scope  
The general objective, in line with the FAO IPOA SHARKS, is to ensure the 
conservation and management of sharks and their long-term sustainable use worldwide. 
The scope of the initiative includes directed commercial, by-catch commercial, directed 
recreational, and by-catch re creational fisheries catching any chondrichthyans within 
Community waters by both EU flagged vessels  and foreign vessels. It also includes any 
fishery covered by current and potential agreements and part nerships between European 
Community and third countries, as well as fisher ies in the high seas and fisheries covered 
by RFMOs managing or providing non-binding  recommendations outside Community 
waters. 
The Plan of Action is based on the following three main specific objectives, aiming to: 
(1) Broaden the knowledge both on shark fi sheries and on shark species and 
their role in the ecosystem. 
(2) Ensure that directed fisheries fo r shark are sustainable and that by-
catches of shark resulting from ot her fisheries are properly regulated. 
(3) Encourage a coherent approach betw een the internal and external EC 
fishery policy for sharks. 
In order to achieve the three main objectives, the Commission in itially proposed in its EC 
consultation document nine ‘fields of action’ or operational objectives which it felt could 
help to fulfil these objectives (see table 4).  
Table 4: Initial ope rational objectives 
Specific objectives Operational objectives (field o action) 
– 1 Facilitate improved species-specific catch 
and landings data and monitoring of shark catches  Ensure a 
coherent approach 
between the 
internal and external EC Deepening the 
knowledge both on shark 
fisheries and on 
shark species and their role – 2 Facilitate the identification and reporting of 
species-specific biological and trade data  
 
EN 21   EN – 3 Compile the necessary information to assess 
threats to shark populations, determine and protect critical habitats, and implement harvesting strategies consistent with the 
principles of biologica l sustainability and 
rational long term economic use  
– 4 Develop research projects to assess threats 
to shark populations and implement harvesting strategies consistent with the 
principles of biologica l sustainability and 
rational long term economic use  in the 
ecosystem  
 
– 5 Improve and develop frameworks for 
establishing and coordinating effective consultation involving  stakeholders in 
research, management and educational initiatives within and between States  
– 6 Adjust fishing effort to the available 
resources  
– 7 Adjust catches to the available resources  
– 8 Minimize waste and discards from shark 
catches in accordance with article 7.2.2(g) of 
the Code of Conduct for Responsible Fisheries requiring the retention of sharks 
from which fins are removed and encourage the use of dead sharks  fishery policy 
for sharks 
Ensure that 
directed 
fisheries for shark are sustainable and that by-catches of shark resulting from other fisheries are properly 
regulated – 9 Identify and provide special attention in 
particular to vulnerable or threatened shark stocks  
Operational objectives 1-5 responded to th e objective of greater knowledge of shark 
fishers and their ecosystem linkages. Operat ional objectives 6-9 ai med at ensuring that 
directed shark fisheries are su stainable and that by-catches were regulated. All of them 
were required to ensure a coherent approach between the internal and external EC fishery 
policy for sharks. 
These fields of action include all the measur es originally proposed in the consultation 
document presented by the Commission, but, following the consultation process, they 
have been simplified/consolidated where pos sible and appropriate. This has involved 
merging fields of action 1 and 2, 3 and 4, 6 and 7, and distributing measures under field 
of action no. 9 throughout other fields of acti on. It is important to note that no measures 
have been dropped at this stage, only cons olidated under a lesser number of ‘fields of 
action’. It should also be noted that mergi ng fields of action was suggested by a number 
of stakeholders (see Appendix I). 
 
EN 22   EN Table 5: Justification for merging Fi elds of Action during option screening 
Merger Justification 
Fields 
1 & 2 Both have the same objective. Both look at facilitating 
improved data collection but at different points in the harvest 
chain. RFMO measures similar in both cases. 
Fields 
3 & 4 Both have the same objective. Both have the same intent, with 
FoA 3 looking at data collection and FoA 4 implements 
subsequent research and can thus  be compiled together. Merger 
also suggested by some stakeholders (see Appendix I). 
Fields 
6 & 7 Both have the same objective. Fo A 6 looks at controlling effort 
and FoA 7 looks at controlling catches. Both act at similar 
levels and effort / catch reduction mechanisms need to be complementary. Merger also suggested by some stakeholders 
(see Appendix I). 
Field 9 FoA 9 focuses on vulnerable or threatened species. Whilst a 
legitimate goal, it is considered th at all the measures in this field 
are already included in the earlier Fields of Actions, especially 6 
& 7. It does highlight the need to conduct risk assessments for 
the majority of the different measures in order to target 
vulnerable and threatened species across ALL the Fields of Action, rather than having a speci fic programme that addresses 
this separately. This merger is considered to have a number of 
effectiveness and efficiency advantages. 
Furthermore, the operational objectives have been redefined in order to make them 
"SMART". Table 6 offers a general vision of how the 5 selected operational objectives 
respond to each of the specific objectives. 
Table 6: Final operational objectives. 
Specific objectives Operational objectives 
– Having reliable and detailed 
species-specific quantitative and biological data on catches and landings as well as trade data for high and medium priority fisheries, after three 
years of implementation.  Ensure a 
coherent 
approach between the internal and external EC fishery policy 
for sharks Deepening the 
knowledge both on 
shark fisheries and on shark species and their 
role in the ecosystem
 
– Being able to efficiently 
monitor and assess shark stocks on a species specific level and develop harvesting strategies with the principles of biological sustainability and rational long term economic use, after three years of 
 
EN 23   EN implementation.  
– Improve and develop 
frameworks for establishing and coordinating effective consultation involving stakeholders in research, management and educational initiatives  
– Adjust catches and fishing 
effort to the available resources with particular attention to high priority fisheries and vulnerable or threatened shark stocks, after three years of implementation.
Ensure that directed fisheries for shark are sustainable and that by-catches of shark resulting from other fisheries are properly regulated – Minimize waste and discards 
from shark catches requiring the retention of sharks from 
which fins are removed and 
strengthening control measures. 
 
3.2. Consistency with other EU policies 
At the 2002 Johannesburg World Summit on Su stainable Development the EU Member 
States signed up to limiting fishing to sustainable levels by maintaining or restoring stocks to levels that can produce the maximu m sustainable yield. For depleted stocks, it 
was agreed that this should be achieved ur gently, and where possibl e not later than 2015. 
The new CFP which resulted from the 2002 refo rm intended to adopt measures aiming at 
ensuring the sustainable development of fi shing activities from an environmental, 
economic and social point of view. Cohe rence with other EU policies such as 
environmental policy was also a major element of the new CFP. 
The initiative is consistent with the comm unications from the Eu ropean Commission to 
the Council and the European Parliament that  pointed out the importance of a European 
Community biodiversity strategy
10 and that highlighted the relationships between 
                                                 
10 Communication from the Commission to the Council and the European Parliament on a European 
Community Biodiversity Strategy : COM(98)42 final. 
 
EN 24   EN fisheries management and nature conservation11 as well as with the Communications 
from the Commission to the Council and the Eu ropean Parliament on the review of the 
management of deep-sea fish stocks12 and on a policy to reduce unwanted by-catches and 
eliminate discards in European fisheries13. However, the EC communication on discards 
is general, and does not fully address the specificities of shark. For example shark fining 
results in the discard of the body of the shar k, a practice which is not covered by the EC 
communication on discards. 
The elimination of discards, including a discar d ban is an element of the Plan of Action 
itself. The new Fisheries Control Regulation will enhance the efficacy of the measures 
contained in the Plan but does not form part of it. 
The IUU Regulation adopted by the Council on 29 September is a broad instrument that 
will apply to all stocks. It will encompa ss shark catches and should contribute to a 
reduction of illegal fishing for such species. However, the ma nagement of sharks requires 
that specific rules are adopted in order to better address the speci fic problems posed by 
this fishery. Such rules are not laid down in  the IUU Regulation, whic h is a dedicated to 
control measures and no t conservation measures. 
4. POLICY OPTIONS  
The analysis of impacts presented in Secti on 5 considers three main options as follows: 
Option A: Status Quo with no Action Plan . 
This Option represents a c ontinuation of the current status quo  with no CPOA and 
keeping the current EC legislation on shar ks, while adapting it to new circumstances 
when necessary taking into consideration new scientific advice. 
This is a ‘do nothing more’ option and will be used as the baseline for the impact 
assessment in the next section of the report. This ‘no action plan’ scenario presumes that 
the existing measures continue to exist without the assistance of a specific Plan of Action. 
Option B: Action Plan : 
This option is based on the adoption of an Action Plan, which provides for the 
continuation of the current status q uo regarding EC legislation on sharks and
 for the 
introduction of new legislation or the adapta tion of existing one ai ming at ensuring the 
achievement of the objectives envisaged. This Action Plan will allow having a clear and comprehensive picture of what is already in force and what remains to be done in order to achieve a coherent and effective approa ch. Under some of the operational objectives 
foreseen by this option, different alternatives (i .e. softer or stricter  measures) have been 
considered for implementation. These alternativ es include, for example, a) voluntary vs. 
                                                
 
11 Communication from the Commission to the Council and the European Parliament on Fisheries 
Management and Nature Conservation in the Marine Environment. COM(1999)363 final. 
12 COM(2007) 30 final of 29.01.2007 
13 COM(2007) 136 final of 28.03.2007 
 
EN 25   EN optional activities/fundi ng, b) full vs. partial coverage, c) immediate or phased 
implementation. The table in Appendix II s hows the implementation alternatives which 
are subject to the IA in Sectio n 5. As a result of this analys is, section 7.4 will describe the 
preferred option as an ame nded version of option B. 
The policy objectives and scope have been described in section 3.1. The measures 
envisaged under this option wi ll be applicable to all vessels operating in Community 
waters and to all EU flagged vessels in all waters. Furthermore, in order to ensure a 
coherent approach between the internal and external EC fishery policy for sharks, the 
Community will seek that the relevant inte rnational bodies adopt similar measures to 
third country vessels outside Community waters. 
Option C: Application of a strict precautionary approach : 
Option C looks at taking a strict precautiona ry approach. Essentially  it seeks the adoption 
of a Plan of Action modifying the current  EC legislative framework on sharks and 
introducing a strict interpretation of th e precautionary approach by prohibiting all 
directed fisheries or indirect catches on sh arks by Community vessels, unless TACs and 
other regulatory measures have  been put in force, follow ing scientific advice. This 
Option includes all the measures and implem entation mechanisms specified in Option B, 
except that in this case, non regulated shark fisheries would not be allowed. Furthermore, 
only sharks complete with fins could be landed. 
5. ANALYSIS OF IMPACTS  
The following analysis has been developed on the basis of the information and data 
provided by the MRAG Study on the impact of measures under the CPOA on Sharks 
finalised in July 2008. 
5.1. Option A 
5.1.1.  Environmental impacts 
This option represents a continuation of the status quo . As such, no changes to the 
current impacts of the current status quo  are envisaged. The impacts of the status quo  are 
examined below. 
5.1.1.1.  Direct Impacts 
A major feature of the interaction of shark population and fisheries across the oceans is 
that it is not entirely clear what the status quo  is. The data gaps, part icularly at the species 
level, produce a very incomplete picture. Ca tch, landing and trade data  are poor or patchy 
and many of the demersal shark catches are not from targeted fisheries but exist as bycatch. Shark fisheries, per se , are consequently often not subject to direct regulation 
and reported catches refer only to that portion retained onboar d yet no systematic data on 
discard rates are in the published domain. Some high discard rate s (e.g. 60%) worldwide 
are reported and this is compounded by the pr actice of finning and di scarding the carcass. 
The study shows that there is a rather und erestimated view of impacts. There are 
indications that the actual catches for finni ng alone might be four times higher than FAO 
landing data. 
 
EN 26   EN The first direct impact observable is some reduction of shark populati ons. The true status 
of most elasmobranch populations, however, remains uncertain due to lack of stock 
specific information particularly over significant time series. This has lead to dispute in some areas over the extent of any decline, for example in the NW Atlantic (e.g. Baum et 
al 2003, Baum et al  2005, Burgess et al  2005a & Burgess 2005b). Even where limits 
have been imposed by ICES and some RMFOs this has mainly been based on catch trends since there has been inadequate information to construct stock models. 
Nevertheless, some fisheries have shown re ductions, for example, the common skate and 
angel sharks have virtually disappeared from North Sea fisheries and ICCAT (2007) 
reported up to a 50% reduction for Isurus oxyrinchus . How widespread such reductions 
are remains to be determined and a precautiona ry approach would be of advantage here 
which is reflected in the perception by NGOs th at some species now ar e under threat. It is 
also clear that the international trade in  shark and shark products is increasing (see 
Appendix V), thus providing a future driver fo r continued fishing pr essure. The situation 
is likely to persist as a result of this driver.  
The impacts of sustained fishing will reduce shark populations furthe r. Moreover, it is 
not just a question of the volume of a shark sp ecies taken which defines the risk, it is a 
function of the status of a stock and its in creased vulnerability which, in turn, is a 
function of its rate of replic ation, the degree of specialisation of the species and the time 
and place of catches. It is cl ear that particular species ha ve become threatened and in 
consequence, even small catches of such sp ecies would drive it to a higher category of 
threat. Therefore, if current tr ends continue it could be exp ected that there will be an 
increase in the number of species threatened  and a general upward trend of threatened 
species towards extinction. However, there is no sufficient technical evidence to prove it.  
Such impacts are likely to be greatest on t hose species with particularly low rates of 
replacement, low growth rates and greater l ongevity which almost certainly includes the 
deep sea sharks. Conversely, the blue shark provides the greatest catches amongst pelagic 
sharks but has one of the highest rates of re plication. It is, therefore, important to 
understand the biology to produce a management  plan for particular shark species. 
The above comments refer to the general im portance of continued fishing under the 
status quo  on sharks. Of course, the EU fleet is not  alone in contributi ng to this situation. 
The pressures, and therefore, the impacts vary greatly across the oceans. Thus, the EU fleet accounts for 70% of all sharks landed in the NE Atlantic, 89% for the 
Mediterranean, 39% for Central and Southern Atlantic, 8% for the Indian Ocean, 16% for 
the Pacific Ocean and a very small amount for the Southern Ocean. Clearly then the  
greatest regional impacts from the EU fleet ar e most likely to be felt in home waters 
which helps prioritise and re gulate actions. Taking into account the range of measures 
that are already being taken by the EC, a lik ely scenario under op tion A could also be 
that the very depleted state of  several stocks will not improve  or will improve too slowly, 
but will not necessarily deteriorate further. 
5.1.1.2.  Indirect and Ecosystem Impacts 
Most sharks are predators. Some, like skat es and rays, are bottom feeding predators on 
crustacean and molluscs, whilst others c onform to the stereotype of open water 
piscivores, and top predators. In ecosystem s, particularly aquatic ecosystems, top 
predators appear to have a significant regul atory effect on populations in the lower 
 
EN 27   EN trophic levels. Consequently the introduction or elimina tion of top predators has 
considerable impacts on other communiti es and the ecosystem as a whole.  
The elimination of top predators generally tends to have a simplifying effect on the 
ecosystem. Examples are rarely straightforwar d but it seems that the elimination of the 
larger predatory species for the Black Sea fisheries, such as tuna-like species and mackerels, contributed to the shift from a fishery typified by 24 species to one relying 
only on 6 species with the bulk being taken fr om a single plankton feeding anchovy. It is 
equally thought that the elimination of cod from the Grand Banks fishery and its failure 
to recover may well be due to crabs taki ng over the vacant feeding niche. This 
phenomenon of removal of top predators lead ing to a redistributi on of species lower 
down the trophic system has been termed  ‘fishing down the food chain’ (Pauly et al  
1998). 
Essentially, such impacts change the nature of  the target fisheries whilst also reducing 
biodiversity. Whilst this effect is yet to be recorded in sharks it w ould be most surprising 
if it didn’t follow the genera l pattern described by Pauly et al (1998). The impacts on 
biodiversity in terms of both numbers and relative abundance of ot her species in the 
system is likely to produce a dispropor tionate impact on biodiversity beyond the 
reduction in specific shark species. In this respect sharks and rays may be different 
depending upon their mode of feeding and trophic level. 
Whilst the EU may not be the main source of fishing mortality in external waters, doing 
nothing to rectify the above situation diminishes the in fluence of the EU in the 
international community to cont rol such environmental damage. 
5.1.2.  Economic impacts 
As noted in this Section, catches of elasm obranchs by the EU fleet are made in a number 
of different oceans. The lack of species-sp ecific reporting by metier restricts a detailed 
analysis of the economic benefits of elasmobr anch catches; indeed this lack of detailed 
information is itself one of the primary dr ivers of the problem. Nevertheless, some 
indicative figures on the value of catches by region, and the potential importance of these 
catches on an average vessel basis ar e presented. These figures on the current/short-term  
economic benefits to the catching sector , are summarised in the table below.  
Table 7: Summary of current annual econom ic benefits from elasmobranch landings 
(MRAG Study on the impact of measures under the CPOA on Sharks –July 2008-) 
Region Value of 
elasmobranch 
landings (€ 
million) Contribution 
to total EC-15 
value of 
landings Maximum 
EU vessels 
involved Avera ge value 
of catch per 
vessel 
NE & NW Atlantic 81.19  1.22% 20 458 € 3 968
Mediterranean 5.73  0.09% 32 727 € 175
C & S Atlantic 92.99  1.39%  200 € 464 946
Indian Ocean 11.79  0.18%  103 € 114 501
Pacific 4.09  0.06%  12 € 340 853
 
EN 28   EN  The table indicates that income dependency on elasmobranch catches for individual 
vessels  are most significant for the distant water fleets of Spai n, Portugal and France. For 
some vessels in these distant water fleets,  shark catches may represent between 20-45% 
of the total value of catches. For individual  vessels in Northern waters and the 
Mediterranean, vessel dependencies on shark ca tches are on average very much lower; 
while detailed quantification is not possible, taking the total va lue of national catches as a 
proxy, average individual vessel dependency may be in the order of 1.2 – 4.7%. Within 
the North Atlantic, while the total value of landings is significantly greater for France and Spain than for other EU MS, due  to numbers of vessels poten tially involved in catching 
elasmobranchs, the average income dependency on vessels is highest in Belgium, followed by France, Ireland, the UK and then Spain. These average
 figures, as already 
noted, do not of course captur e the fact that some individua l vessels may be much more 
dependent on the income from elasmobranch  catches on an annual basis, or during 
particular seasons. The status quo  would have no impacts on the costs to the catching 
sector of in terms of curre nt reporting requirements, any consultation, nor on the short-
term economics of fishing operations in term s of the ability of vessels to obtain 
exemptions from the ban on finning and their ab ility to land fins and shark carcasses in 
different ports. 
When considering the dependency of the EU fleet on different re gions, the table shows 
that catches made in Northern Atlantic waters (predominantly by gillnet and trawl 
vessels) represent 41% of the value of  total catches by the EU fleet, with 
Central/Southern Atlantic and distant wa ter longliners accoun ting for around 47%, the 
Indian Ocean 6%, the Pacific 2% and the Mediterranean the remaining 3% by value. 
To these direct  economic benefits should be added indirect  income multiplier benefits to 
the processing and ancillary sectors , and second-round multipliers in other sectors of the 
economy. A recent European Parliament study14 suggests that income multipliers in the 
processing / ancillary sectors across the EU as a whole are in the order of 1.9 times the 
income made in the catching sector (F rance 1.87, Spain 1.77, the UK 2.9, Portugal 1.1, 
and Ireland 1.64). 
However these economic benefits to both catching and processing/ancillary can be 
assumed to be of a short-term  nature only, if indeed stocks  are being overexploited as 
suggested in the preceding section on  the environmental impacts of the status quo . Thus, 
while the status quo  includes some regulations and ac tions to limit catches, reducing 
finning, etc in the long-term , without any improved  conservation measures and better 
knowledge of shark catches, it is highly likely  that the value of cu rrent economic benefits 
from landings would decline thr ough over-fishing, potentially to a significant  extent for 
some vessels. These declines will be particul arly marked for those vessels which depend 
to a great extent on shark ca tches to contribute to their total earnings e .g. the distant 
water fleets, and some selected fleets/metiers  in EU waters. Shark catches are thought to 
contribute around 25% of total ve ssel turnover for distant wa ter longliners. The current 
status quo  with limited specific reporting and cont rol of shark catches, and with shark 
being a bycatch in many fisheries, also doe s little or nothing to encourage innovation and 
research on species selectiv ity in fishing operations. 
                                                 
14 Regional dependency on fisheries. 2007. Directorate General Internal Policies of the Union 
 
EN 29   EN EU vessels catching elasmobranchs do so in many of the world’s oceans, in competition 
with other fishing nations. It is thus equally true that for third countries , continuation of 
the current status quo  would be likely  to result in the significant  long-term  declines in the 
economic benefits to both catching and pro cessing/ancillary sect ors through overfishing. 
For the EU  retail/food service sectors , and consumers  as the end point of the supply 
chain, current short-term  trade in shark products primarily involves shark meat. For 
catches made in the North East Atlantic, the primary products are skates, rays, and 
dogfish, which are generally sold in the country of landing, although France and Spain 
also import product from other EU countries. For catches made by the EU distant water 
fleet, primarily of blue shark, shark meat is sold in the EU, with fins generally being 
exported to the Asian markets. Current short- term availability of shark products to all 
consumers is highly likely  to decline significantly  in the longer-term  under the status quo  
option. This will particularly affect cons umers in France and Spain, where demand is 
high. This in turn is also highl y likely to result  in an increase in market prices for shark 
products as availability becomes more limited. 
For EU MS authorities , and for RMFOs , the current status quo  would have no direct  
short  or long-term  economic impacts over and a bove current reporting and control 
obligations. However, longer-term indirect  costs be incurred if vessel profitability 
declines as a result of over-fis hing, in turn resulting in increa ses in social support to those 
leaving the fishing sector. A nd declining economic benefits in third countries in the long-
term could also be contrary to MS  and EU development policy. The status quo  would 
also mean a continuation in the short- and longer-term  of a situation in which there is 
poor knowledge both on shark fish eries and shark species and th eir role in the ecosystem, 
and a lack of coherence betw een internal EC fisheries po licy and international best 
practice e.g. via requirements for a plan  of action as required by FAO in 1999. 
For NGOs and civil society , there are now a number of groups/organisations actively 
involved in trying to protect  shark species. Their activitie s require financial and human 
resources. A continuation of the status quo  would result in them continuing in both the 
short and long-term  to spend money and time research ing shark issues and lobbying for 
protection of sharks. 
5.1.3.  Social impacts 
The short-term  direct  social benefits to the catching and processing/ancillary sectors  of 
shark catches in different regions  are shown in the table below. 
Table 8: Summary of current social benefits  from elasmobranch landings (MRAG Study 
on the impact of measures unde r the CPOA on Sharks –July 2008-) 
Region Maximum 
catching 
sector 
employment Maximum 
processing/ 
ancillary 
sector 
employment Average 
value of 
landings 
per 
catching 
sector 
employee Average 
value of 
landings 
per 
processing 
sector 
employee 
NE & NW Atlantic 42 274 28 141 € 1 920 € 2 885 
 
EN 30   EN Mediterranean 63 140 20 160 € 91 € 284 
C&S Atlantic 3 296 2 039 € 28 213 € 45 606 
Indian Ocean 1 960 1 340 € 6 017 € 8 799 
Pacific  224  140 € 18 260 € 29 292 
It should be noted that these figures are a maximum  number of those potentially involved 
in catching sharks and in related processing /ancillary employment and are not full time 
equivalents but just the total number of pe ople who could potential ly be dependent on 
shark catches. Likewise, the table provides only an average  value of landings per 
employee. Again, the figures suggest that whil e the North East Atlantic may provide the 
greatest total dependency in  terms of employment to some degree  dependent on shark 
catches, social dependency in terms of the va lue of landings per employee is very much 
higher from catches made in distant waters . As with the economic impacts discussed 
above, labour in different countries will be dependent on shark landings to a lesser or greater degree. To these direct  employment benefits must be added the indirect  second-
round multiplier effects from economic activity related to shark catches and employment. 
In terms of regions which make significant catches of sharks, the importance of Galicia, 
Bretagne, NE Scotland, Highl ands and Islands, and the Algarve regions, should be 
highlighted as being especia lly dependent on fisheries. 
The longer-term  negative social impacts of this option on the catching and 
processing/ancillary sectors would be significant  and very likely  in regions particularly 
dependent on fisheries. In many countries, while catching sector employment is strongly 
dominated by men, the processing sector t ypically employs many  women. Employment 
on the distant water fleet could be particular ly susceptible to negative impacts in the 
longer-term because of the higher depende nce of individual vessels on blue shark 
catches, compared to those vessels catching skates, rays and dogfis h in the Atlantic. 
The status quo  option, with limited stak eholder consultation (to be  addressed specifically 
by one Field of Action in Option B), woul d also directly impact in both the short and 
long term  on the ability of catching and pro cessing sector stakeholders, along with NGOs 
and civil society,  to be involved in issu es of sector governance as  provided for in the 
Treaty and the new governance appro ach. These impacts would be both high likely  and 
significant . 
It should also be noted that many of the crew on these distant water vessels are from 
outside the EU, so the nega tive impacts on labour from third countries  would also be 
likely  and significant  in the longer term. Other longer-term  negative social impacts in 
third countries would also come from d eclining catches in these countries from 
overfishing, and would be both significant  and likely . 
The social impacts on consumers
 would be very likely  in the longer-term , and potentially 
significant , and would involve a declining availabi lity of shark products, which in some 
regions, are in high demand. 
For EU MS authorities , and for RMFOs , the current status quo  would have no direct  
short  or long-term  social impacts. However, longer-term indirect  social costs are likely , 
and in some regions could be significant , if vessel profitability declines as a result of 
 
EN 31   EN over-fishing, in turn resulting in necessa ry increases in social support to those 
unemployed on leaving the fishing sector. And de clining social benefits  in third countries 
from declining catches in the long-term  would also be significant  and highly likely  in 
terms of a lack of coherence with MS and EU development policy. 
5.1.4.  Risks, trade-offs / synergies, public opinion, enhancing measures 
The trade offs inherent in the status quo op tion are by definition all those environmental, 
economic and social impacts of the proposed policy options presente d in Option B (and 
the five Fields of Action), and Option C. The negative public opinion which would result 
from Option A would be very significant and very likely (despite the current initiatives 
already being taken as outlined in Section 2) given the significant decline in many shark populations in recent years and given increasing consumer concerns over the 
sustainability of seafood catches. 
The European Community has the exclusive co mpetence for the management of fisheries 
resources. Although it has adopted a number of measures aiming directly or indirectly at 
the conservation and management of sharks, it has not yet developed an EC Plan of 
Action for sharks. However, the range of ex isting measures is clearly insufficient to 
ensure the rebuilding of ma ny depleted stocks fished by the Community fleet in 
Community and outside Community waters . Furthermore, given its weight at 
international level, the Community should assu me a leading role in the development of 
policies aiming at the rational expl oitation of fishing resources. 
5.2. Option B 
Within Option B, the IA assesses individua lly a number of fields of action. It is 
appropriate to consider the likely impact of each  of the fields in turn, bearing in mind the 
original nine have been condensed to five (see Appendix II). The detailed analysis of the 
environmental, economic and social impact of every field of action is provided below. 
5.2.1.  Environmental Impacts  
Field of Action 1  
This provides for improved collection and ve rification of catches and related data by 
species and product backed up by pilot observer schemes to scrutinise catches and discards. Clearly catches and presumably the e quivalent effort data will go some way to 
defining the precise magnitude of the problem which currently contains many 
uncertainties. This is particularly the case if pilot observer schemes are used to obtain a proper estimate of discard rates. Once the s cale of the problem, in terms of accurate 
estimates of losses by species, is fully understood then the management and mitigation measures can be more clearly defined. 
Additional benefits can come fr om catch and effort data sin ce these will allow a start to 
be made on population assessments for key species as with other fisheries regulated under the CFP. The presence of observers often has effects beyond the collection of data. 
Their presence also tends to help towards compliance with recommended practices and responsible fishing. 
 
EN 32   EN Improved processing and landing data will al so help estimate the present and future 
pressure from the market driver and bette r monitoring of vulnerable species traded. 
Promoting similar data collection with across RMFOs will enlarge the scope of data 
collected but also be a way of  promoting equivalent measures  outside the EU. Linking up 
with FAO, CITES and other in ternational bodies with rela ted agendas on sharks will 
further internationalise actions. 
Field of Action 2  
Given the general lack of information on shar ks and the key role that differences in 
biology are likely to make both to management and stock recovery plans, this Field of 
Action should have a consider able impact towards positive r ecovery of the stocks. This 
element will provide the parameters in grow th, mortality and beha viour which together 
with the information gathered under Fields of Action 1 and from previous studies will 
enable population and fishery models to be c onstructed as for othe r regulated species. A 
more generalised risk assessment is also incl uded as a rapid appraisa l of relevant stocks 
which will enable those stocks for which a full model would be essential, to be prioritised. Again working with RMFOs would help disseminate the approach. Work on 
the identification of more sel ective technologies, similar to th at carried out on turtles and 
dolphins, would be very helpful. 
Field of Action 3  
This has a two-fold impact, to educate the industry as to those best practices which 
impinge least on their livelihoods  and to inform the civil society of the commitment of 
the EU to addressing the problem. This may add further pressure on the industry through 
market-based customer responses to further increase compliance. 
This will be a facilita ting measure which will underpin th e positive impacts of the other 
activities. 
Field of Action 4  
These are the regulatory measures stemming fr om the earlier actions data collection and 
research dealt with under the Fields of Action above . Given that the greatest 
proportionate impact of the EU fleet is with th e NE Atlantic, it is ap propriate that sharks 
are brought more generally under the ICES- based TAC and quota systems and the full 
regulations of the CFP. In  fact, ICES and some of the RMFOs have started to 
recommend TACs although these are often base d on catch trends rather than population 
analysis and have a precautionary element in  them. Some examples are shown in Table 9. 
Table 9: Summary table of current scientif ic advice and current TACs actually set 
Species /areas Recommended scientific 
advice on catch limits TACs actually set 
Deepwater sharks: 15ICES V, VI, VII, VIII, 
IX 0 (2006)16 6 763 (2006) 
                                                 
15 Includes Portuguese dogfish, leafscale gulper sh ark, birdbeak dogfish, kitefin shark, greater 
lantern shark, velvet belly, black dogfish, gulper shark, black mouth dogfish, mouse catshark and Iceland catshark. 
 
EN 33   EN Deepwater sharks: ICES XII 0 (2006)16 243 (2006) 
Basking shark: ICES I-XIV/EU 0 (2006-07)17 0 (2006-2008)
Porbeagle shark: EC and international 
waters of I, II, III, IV, V, VI, VII, VIII, IX, X, XII & XIV 0 (2006) [3] 
IIIa (Minimum bycatch) x 
IV (Minimum bycatch) x 
VIId (Minimum bycatch) x  0 (2007) 
581 (2008)
 
Thorny skate ( A. radiata: ) NAFO 3L, 3N, 
3O 11 000 (2006)18 13 500 (2005-
2007) 
White shark: EU 0  0 
Squalus acanthius:  EU (bycatch) 0 (2006-07)17 <5% retained 
weight  
Source: see footnotes 
Of course, many are tuna RM FOs and have no remit to set TACs on shark but do have 
recommendations on the treatment of bycatc h, most commonly the 5% rule. Several of 
the other points of action such as limitations in sensitive areas (or time periods) will also 
be feasible within Community waters to pr otect spawning or feeding areas or migration 
routes. It will be also  important, following stock assessm ents, to draw up recovery plans 
for the worst affected species. The commit ment to adjust fishing levels under 
international circumstances to appropriate resource levels maybe more difficult, 
particularly where sharks ar e not the target species. 
The prohibition of all discards could be a very powerful measure given the probable 
extent to which this distor ts the problem. Much depends  on upon the robustness of the 
animals themselves with regard to their su rvival on liberation. This may need some 
research. The problem, for example, for a tuna  long-liner is that if  the shark comes in 
dead, will the crew want to fill up the hold wi th shark rather than the target tuna? Thus, 
whilst it is potentially a powerful measure so me problems of implementation still remain, 
especially in international waters where c ontrol is difficult. Compliance with a discard 
regulation is a point where observers can have  a positive role. Where there is sufficient 
civil awareness, consumer driven market instruments can also positively re-enforce 
compliance. 
If fully implemented this action will have direct, very positive impacts to shark stocks 
and biodiversity.  
Field of Action 5  
It refers largely to a ban on finning and to th e current reflexion on di scards. Clearly this 
is a positive move which w ill underline the EU commitment but probably the most 
                                                                                                                                                 
16 ICES (2005). ICES Advice 2005, Book 10. 35 pp. 
http://www.ices.dk/products/icesadvice2005.asp  
17 ICES (2006). ICES Advice 2006, Book 9. 255 pp. 
http://www.ices.dk/products/icesadvice2006.asp  
18 NAFO (2005). Thorny skate (Amblyraja radiata) in Divisions 3L, 3N and 3O and Subdivison 3Ps. 
http://www.nafo.int/science/frames/science.html  
 
EN 34   EN important downstream effect will be as an  example for wider RFMO adoption although 
most have already gone down this route 
The impacts of finning really depend upon any additional mortality cau sed since this is a 
parameter in the context of managing the stocks . In this respect it is  really a specialised 
element of fishing mortality and therefore a component of FoA 4. In a targeted fishery, 
where the whole shark is take n but the fins sold separate ly, the practice of finning may 
have no specific impacts on shark populations. It  is the practice of finning the sharks and 
then discarding the carcase which may encour age incremental mortality since the fins 
take up very little storage space and therefore makes little demand on the hold space for target species. In this way, many more indivi dual sharks may be taken than if the whole 
carcass was being taken. It is al so for this reason that this  practice is being discouraged, 
to reduce or eliminate this incremental mortality as a negative impact. 
An element of trying to ensure  that only whole sharks are be ing landed is to specify the 
ratio of permissible fins to carcass weight, typically the ‘5% rule’. Where regulations on 
finning have been brought to bear, as in some  RMFOs for example, there appears to be a 
standardised concept that a fin should constitu te no more than 5% by weight of the shark 
catch. However, there is little systematic work  to show this is actually the case. There 
may well, therefore, be some species differe nces and also the way finning is carried out 
makes a difference. For example, Asian crews tend to remove just the fins whilst Spanish 
crew are reported to take a pi ece of meat off with the fin. There is also the issue of 
whether the rule might be applied to live (or round) weight (RW) or dressed weight 
(DW) and which measure is the most practic al. Clearly more systematic work on this 
standard needs to be carried out in the context of this measure. Meanwhile, a 
precautionary approach would recommend th e more conservative general rule (5% 
FW:DW) while providing for the status quo (5 % FW:RW) for those been able to fully 
justify this need. The final de finition may not, in itself, have  any direct impact on shark 
fishing mortality but the most rational ratio w ould be fairer and therefore more likely to 
achieve compliance. 
5.2.2.  Economic Impacts 
Field of Action 1  
Measures 1.1, 1.2 and 1.5, and 1.11, will all have direct  cost implications on the catching  
sector in the EU (recreational and commercia l), the processing sector in the EU, MS 
authorities and the Commission . For the catching and processing sectors direct costs in 
terms of the time spent providing additiona l data over current requirements are not 
expected to result in any reduced fishing ti me and therefore profitability. Rather costs 
will relate to some amounts of reduced  leisure time that might be involved
19. Measures 
1.6 through 1.9 will also have direct  cost implications for RFMO administrations  and all 
third country  contracting parties, in terms of th e collection, analys is and reporting of 
landings and trade data. Measur e 1.8 would also have some, as yet unspecified, direct 
costs of workshops. All these direct  costs can be expected to run indefinitely once 
improved data collection systems are put in place. All are certainly  going to occur, but all 
costs are deemed to be not significant  in terms of their magnit ude, given that existing 
                                                 
19 In investment appraisal (e.g. of fishing harbour investments) it is standard practice to value leisure 
time at around 30% of the hourly earnings made from fishing 
 
EN 35   EN data collection systems can be amended to  include provision of additional species-
specific data on sharks. 
Measures 1.3 and 1.4 will also have direct  cost implications. If this measure is put into 
practice then costs will definitely  occur. Likewise, measure 1.10 would be certain to have 
direct cost impli cations on RFMOs. 
Section 3 of Appendix III provides a detailed  explanation of the magnitude of the 
management costs involved by the observers schemes. 
There are also expected to be many positive indirect  economic impacts of FoA 1 in the 
longer term . Taken as a whole, if implemented FoA 1 can be expected to contribute 
towards safeguarding the current economic benefits from shark fisheries to all 
stakeholders  by ensuring long-term sustainability of catches. 
Field of Action 2  
All measures proposed in FoA 2 (2.1 to 2.8) will involve direct  economic impacts in the 
short, medium and long term . Some costs may be necessary only in the short-term e.g. 
related to identifica tion of space-time boxes, while others will be continuous into the 
future e.g. regular assessments proposed under measure 2.2. These costs will generate negative  direct impacts on those paying for them e.g. EC MS, Commission, RFMOs , and 
third countries , and positive  direct impacts for those being paid to undertake the 
proposed research and assessments e.g . researchers/scientists . If implemented the 
likelihood  of these economic impacts is high, but their magnitude  is not quantifiable in 
the absence of more specific information on exactly how the measures would be 
implemented, and to what extent. The direct eco nomic costs/benefits of  the measures will 
depend to a large extent on the financial resources that are available to implement the measures. 
Field of Action 3  
Measures 3.1, 3.3 and 3.4 propos ed in FoA 3 will involve direct  economic impacts in the 
short, medium and long term . Costs will generate negative  direct impacts on those paying 
for the measures e.g. EC MS, Commission, RFMOs , and third countries , and positive  
direct impacts for all stakeholder being pa id to undertake/organi se/attend the proposed 
awareness and consultation e nvisaged. If implemented the likelihood  of these economic 
impacts is high, but their magnitude  is not quantifiable in the absence of more specific 
information on exactly how the measures w ould be implemented. The direct economic 
costs/benefits of the measures will depend to a large extent on the fi nancial resources that 
are available to implement the measures. M easure 3.2 is not expected to involve any 
direct economic impacts over and above the ad ministrative costs disc ussed later in this 
report. 
Field of Action 4  
Measures 4.1 – 4.4 and 4.8 would all involve direct  costs in the short-term  on the 
catching sector (both in the EU and from third countri es), in the form of reduced shark 
catches and therefore revenues (subject to price elasticiti es of supply which are not 
known). The processing sector  and retailers/consumers  would also be negatively 
impacted in the short term through reduced availability of  shark species for processing 
and consumption, with asso ciated higher prices. The magnitude  of these impacts will be 
 
EN 36   EN directly related to a) the economic dependency on different shark fisheries in particular 
areas and by particular fleet segments, as already discussed, b) the extent of the 
limitations put in place, and c) the extent to which fishing strategy c ould be altered so as 
to minimise the economic impacts through fo cusing catches on other species/areas. At 
the present time, sufficient detail is unavail able on the implementation of the measures, 
or the specific fleets involved, to be able to quantify the sum of these negative short-term impacts. However, the cessation of the d eepwater shark fishery would impact most 
strongly on the German and UK registered ve ssels (10), which are Spanish owned, which 
prosecute this fishery. 
Measure 4.4 could potentially be implemented through a hard or soft approach. The costs 
involved with these sub-options would be the same, but the hard approach would result 
in costs being incurred immediately, while fo r the soft approach the associated costs 
would not commence until 2013.  
Measure 4.5 could have significant  negative economic impacts on the catching sector  in 
the short- and long-term , with the prohibition on any discards resulting in increased 
fishing hold space being used to store low value sharks (some potentially unmarketable if 
too small, or conversely very large specimens  filling alone a lot of space) instead of 
higher value species. A related impact on the ca tching sector could be to require vessels 
to make shorter fishing trips as fishing holds fill up more quickly. This could increase 
overall fuel costs related to steaming time between ports and fishing grounds, but could 
also increase unit prices received for all landed fish because of improved quality resulting from shorter trips. Impacts of this measure on the processing sector , and on 
retailers/consumers , could be to increase the availability of shark products for 
processing/consumption, but to reduce the availa bility of other spec ies, thus increasing 
prices for other species which may be in stronger demand, while reducing prices for 
shark products (again, subject to un known price elasticities of supply). 
Measures 4.6, 4.7 and 4.9 will involve direct  economic impacts in the short and medium 
term. These costs can be expected to be phased out over time as discards and bycatch are 
successfully reduced, an d as the impact of market mechanisms on conservation measures 
is better understood. These costs will generate negative  direct impacts on those paying 
for them e.g. EC MS, Commission, RFMOs , and third countries , and positive  direct 
impacts for those being paid to undertake the proposed research and assessments e.g . 
researchers/scientists . Direct costs could also be imposed on the catching sector  in the 
short -term through the need to modify fishing gear and fishing strategy. But these costs 
would in part be offset by increased size a nd species selectivity which should result in 
higher prices and a more efficient and targ eted fishing strategy. If implemented the 
likelihood  of these economic impacts is high, but their magnitude  is not quantifiable in 
the absence of more specific information on exactly how the measures would be 
implemented, and to what extent they would affect different fishi ng fleets. The direct 
economic costs/benefits of the measures will  depend to a large ex tent on the financial 
resources that are available to implement the measures. 
EU MS , the Commission , and RFMOs  can also be expected to face direct  economic costs 
in both the short  and long-term  from measures 4.1 – 4.8, in terms of both administration 
(discussed later), and increased budgetary  allocations for mon itoring, control and 
surveillance (MCS). Again, at the present time , sufficient detail is not available on the 
implementation of the measures to be able to quantify these costs. The likelihood  of some 
costs being incurred is very high, how ever given existing commitments for MCS 
 
EN 37   EN activities and the potential ability of existing operations to include the policing of new 
conservation measures, the magnitude  of these increased costs may not necessarily be 
significant. EU MS, the Comm ission, and RFMOs are also lik ely to incur some small 
direct  economic costs associated with the de velopment of any new effort regulation.  
Also to be expected are many positive indirect  economic impacts of FoA 4 in the longer 
term. Taken as a whole and if implemented, FoA 4 can be expected to contribute towards 
safeguarding the current economic be nefits from shark fisheries to all stakeholders , by 
ensuring long-term sustainability of catches. These positive indirect long-term benefits 
could take the form of a continuation of th e current level of economic benefits from the 
fishery, or if stocks can be re-bui lt, of actually increasing them. The magnitude  of these 
impacts should therefore be seen in the cont ext of the long-term economic costs/impacts 
associated with Option A. The reader is t hus referred the discussion of economic impacts 
in Option A. FoA 4 (along with FoA 5 – see fo llowing text) is estimated to be of special 
importance in generating/ensuring these long-term economic benefits  
Field of Action 5  
Assessment of the impacts of this FoA is underpinned by20: 
• the current use of derogations under existing regulations; 
• the fin: whole weight and the fin: dressed weight for different sp ecies being caught by 
EU vessels; and 
• current (and potential) fin cutting practices 
The fleets that have obtained derogations are primarily Spanish owned operating in the 
Atlantic, and total ar ound 200. These are almost all surf ace longline vessels targeting 
pelagic species (with catches very strongly dependent on blue shark and shortfin mako), 
but derogations have also been provided  for Spanish owned (German/UK-registered) 
deepwater shark vessels in Northern waters . Some Portuguese ve ssels operating in the 
North Atlantic have also previously obtai ned permits to remove fins onboard. French 
vessels in C&S Atlantic are no t thought to have requested a ny exemptions from the anti-
finning regulation.  
Fin weights as a proportion of a) round wei ght (FW:RW) and dressed weight (FW:DW) 
differ significantly for different  species and fleets, as shown in the table hereunder for 
key species being caught by EU vessels. 
Table 11: Fin weight ratios for different species and fleets 
Species FW:RW 
(EU) FW:DW (EU) FW:RW 
(US) FW:DW (US) 
Porbeagle ? ? 2.2% 3.6% 
Blue shark 6.6% 14.6% 2.1% 3.7 – 4.5% 
Shortfin mako 3.9 5.8% 1.6 – 1.7% 2.9 – 4.2% 
                                                 
20 Information on these three issues obtained from  a recent report by the European Elasmobranch 
Association – see http://www.lenfestocean.org/pub lications/SharkFinning_underlying_report.pdf 
 
EN 38   EN Deepwater sharks 1.6 6.5%   
However these % are based not just on the speci es, but also on a) whether just primary or 
all fins are retained, b) the cutting practices a nd the amount of meat attached to fins when 
cut from the carcasses, and c) the dressed weight products. Current  practices by the EU 
fleet increase FW:RW ratios compared to north American estimates, because generally all fins are retained (except from deepwa ter sharks where only the caudal fins are 
retained), and because fins ar e cut with more meat attached  than in fisheries in North 
America. It is estimated for example that if Portuguese vessels retained primary fins only 
from blue shark with improved cutting pract ices FW:RW would be 3.8%, and that "clean 
cutting" could result in a FW:RW of 6.56% fo r all fins. It is probable therefore that 
changed cutting practices could be sufficien t to bring all FW:RW figures below 5% for 
EU vessels. With regards to FW:DW figures, it is likely that "clean cutting" practices would result in figures of less than 5% for all species, except blue shark
 (see discussion 
below on measure 5.2) 
However, as noted and acknowledged in the st udy referenced on the previous page, the 
real/specific impacts on ratios of a) the fins retained b) the cutting practices and c) the 
forms of dressed products, are not well unde rstood. Ratios within a particular fleet 
segment can vary greatly. This  makes quantification of th e impacts of the proposed 
measures problematic, although some general co nclusions can certainl y be drawn and are 
presented below. 
Measure 5.1 would involve direct  economic costs for the catching sector  currently 
obtaining exemptions (primarily Spanish as noted above) in both th e short- and long-
term, and for their national administrations , in terms of the extra work required to 
provide additional/improved justification. Th ese costs are not quantifiable but could 
include the time and costs involved with both additional research and paperwork required to provide the improved justifications envisa ged by the measure. Such direct costs are 
expected to be insignificant . However, this measure could result in indirect  operational 
costs if vessels avoid the need for exempti ons, either by amending their cutting practices 
to reduce fin weights (and therefore potenti ally values, although the exact financial 
benefits of more/less meat on  fins is not known) so as to reduce the need to obtain 
exemptions, or by reducing discard practices, which could result in vessels having to use 
increased fishing hold space to store low va lue shark meat instead of higher value 
species
21. Quantification of the significance of th ese impacts is not possible due to the 
fact that it is impossible to know the exte nt to which a) vessels  would change their 
cutting practices to being fin weights under th e existing 5% rule as  opposed to incurring 
additional costs involved with obtaining derogations/exempti ons, and b) discarding is 
currently taking place and therefore the exte nt to which the measure would reduce 
discards and impact on operational costs. 
Measure 5.2 would potentially i nvolve all distant water surfa ce longline vessels  (247) i.e. 
catching sector , on the basis that all are expected to catch at least some blue shark, and a 
move to 5% dressed weight would m ean that all catches of blue shark could  fall foul of 
the new regulation, even if cutting practices  are improved. This would affect Spanish, 
Portugese and French vessels. For other spec ies it is expected that improved cutting 
                                                 
21 One can presume that vessels discard becaus e it is financially advantageous to do so 
 
EN 39   EN practices would bring FW:DW to below 5%. But important in assessing the economic 
impacts of this measure is that the measure pr ovides for 5% of live we ight to be retained 
if proven . In essence this means that research can be used to ensure that adverse 
economic impacts are not incurred. It is thus expected that the catching sector  and 
administrations  in Spain, France, and Portugal, as well as in RFMOs  would all incur 
direct  costs in the short-term involved with in vestigating whether the revised 5% rule 
should include blue shark or not. It is  expected that th ese costs would not  be significant . 
On the basis that research on blue shark eith er proves that 5% of live weight should be 
retained, or that improved cutting practices  could bring the FW:DW below 5% for blue 
shark as well as for other species, this  measure would then only involve the indirect  costs 
to the catching sector of changed values of fins with lower meat content, and costs are 
therefore expected to be insignificant . This measure could also result in indirect  costs to 
the catching sector associated with reduced di scards i.e. vessels having to use increased 
fishing hold space to store low value shark meat instead of higher value species. 
Quantification of the significance  of these indirect impacts is  not possible due to the fact 
that it is impossible to know the extent to which a) changed cutti ng practices would alter 
values, and b) discarding is currently taking place and therefore the extent to which the 
measure would reduce discards and impact on operational costs. 
A direct  impact of Measure 5.3 on the longline catching sector  exempted could be to 
increase fuel costs from landing fins and carcasses in the same port, but for these savings to be outweighed by the inability to sell different products into  ports commanding the 
best prices (on the basis that current prac tices maximise revenues/profits). In the US, 
similar regulations have resulted in vessels pa rt-cutting fins and fold ing them next to the 
carcass for freezing. Quantification of these im pacts is not possible, but stakeholder 
objections to this measure suggest that the industry feel they could be quite significant . 
The impacts of measures 5.1 to 5.3 on the processing sector, and on retailers/consumers , 
in both the short  and long-term  could be to increase the avai lability of pelagic shark meat 
for processing/consumption (in high demand in Spain in part icular), but to  reduce the 
availability of other species  (e.g. swordfish), thus increas ing prices for other species 
which may be in stronger demand, while reduci ng prices for shark products (subject to 
unknown price elasticity of supply). However, these negative economic impacts could be 
partially offset by the measures resulting in greater efforts of fishing fleets to improve selectivity. 
EU MS , the Commission , and RFMOs  can also be expected to face direct  economic costs 
in both the short  and long-term  from all measures, in terms of both administration 
(discussed later in this IA), increased budge tary allocations for monitoring, control and 
surveillance (MCS) (in distant water longline por ts in Spain and Port ugal especially), and 
for the specific data collection programm es mentioned in measure 5.2. Again, at the 
present time, sufficient detail is not available on the implementation of the measures to 
be able to quantify these costs. The likelihood  of some costs being incurred is very high, 
however given existing commitments for MC S activities and the potential ability of 
existing operations to incl ude the policing of new c onservation measures, the magnitude  
of these increased costs may not  necessarily be significant. 
5.2.3.  Social Impacts 
Field of Action 1  
 
EN 40   EN Measures proposed in FoA 1 will involve positive  direct  social impacts in the short, 
medium and long term , through the enhancement of indi vidual and organisational human 
capacity of all stakeholders  involved with the proposed da ta collection. These impacts 
are certain to occur and likel y to be significant. In a ddition, as with the economic 
impacts, there are also expected to be many positive indirect  social impacts of FoA 1 in 
the longer term . Taken as a whole, if implemented FoA 1 can be expected to contribute 
towards safeguarding the current social  benefits from shark fisheries to all stakeholders . 
Field of Action 2  
All measures proposed in FoA 2 (2.1 to 2.8) will involve positive  direct  social impacts in 
the short, medium and long term , through the enhancemen t of individual and 
organisational human capacity of researchers/scientists  involved with  the proposed 
research. These impacts are certain  to occur if the measures are implemented, and likely 
to be significant . 
Field of Action 3  
All measures proposed in FoA 3 will involve positive  direct  social impacts in the short, 
medium and long term , through the enhancement of knowledge to all stakeholders  
involved. This FoA will also directly generate positive social benefits in terms of sector 
governance as provided for in the Treaty  and the new governance approach. These 
impacts would be both high likely  and significant . 
Field of Action 4  
In the short-term, all measures under FoA 4 are expected to result in negative indirect  
social impacts, through a reduction in shar k catches that are currently generating the 
social benefits as previously discussed in  Section B and Option A. These impacts are 
likely to be most strongly felt by the catching and processing sectors, and are certain to 
occur. However, the effects should be medi um to low in most areas of the EU, but 
perhaps high in some especially dependent areas e.g. Galicia, Brittany. 
Measures 4.6, 4.7 and 4.9 will involve positive  direct  social impacts in the short and 
medium term , through the enhancement of individual and organisational human capacity 
of researchers / scientists  and the catching sector  involved with th e proposed research 
and programmes. These impacts are certain  to occur if the measures are implemented, 
and likely to be significant . 
In the longer term , FoA 4 can be expected to contribute towards safeguarding the current 
social benefits from shark fisheries to all stakeholders , by ensuring long-term 
sustainability of catches. These positive indirect long-term be nefits could take the form 
of a continuation of the current level of social  benefits from the fishery, or if stocks can 
be re-built, of actually increasing them. The magnitude  of these impacts should therefore 
be seen in the context of the long-term soci al costs/impacts associated with Option A. 
The reader is thus referred to the disc ussion of social impacts in Option A. 
Field of Action 5  
In the short-term, all measures under FoA 5 are expected to result in negative indirect  
social impacts, through a reduction in reve nues from pelagic shark catches that are 
currently generating the social benefits as  previously discussed in Option A. These 
impacts are likely to be most strongly felt by the catching and processing sectors 
 
EN 41   EN associated with the longline fleet in the Cent ral and Southern Atlant ic, Indian Ocean and 
the Pacific, and are certain to  occur. The impacts should be medium to low in most areas 
of the EU, but perhaps high in some especially dependent areas e.g. Galicia where most of the EU longline fleet is based. 
Measure 5.2 will involve positive  direct  social impacts in the short and medium term , 
through the enhancement of knowledge about the applicability/suitabili ty of the 5% rule 
to particular species. These impacts are certain  to occur if the measures are implemented, 
and likely to be significant . 
5.2.4.  Risks, trade-offs/synergies, pub lic opinion, enhancing measures 
Field of Action 1  
It is clear from stakeholder feedback on th e consultation document, that public opinion 
would in general be very favourable to this Fo A. Certainly public opinion is of the view 
that it is entirely appropriat e for the EC to act on the m easures proposed. Public opinion 
is unlikely to be consistent however with regards to the detailed implementation of the 
measures related to observer coverage (1.3  and 1.4). Certain NGOs have advocated for 
vessels of less than 24m to be included in m easures 1.3, and for the hard versions of 1.3 
and 1.4 to be introduced i.e. imme diately. The catching sector to be affected by measures 
1.3 and 1.4 would probably argue that the so ft versions are enti rely sufficient i.e. 
sufficient/representative (not total) observer coverage to be  phased in. As a result, it is 
likely there will be risks and trade-offs between the hard and soft sub-options of measures 1.3 and 1.4. Proposing the hard options could end up reducing enforceability and resulting in a deterior ation of relations between the catching sector and the 
Commission. The hard and soft versions of  measures 1.3 and 1.4 clearly represent a 
trade-off in terms of different costs relate d to different levels of observer coverage. 
Synergy with other proposed bycatch reducti on measures under Option B is envisaged, as 
these other measures would reduce the numbe r of vessels affected by Measure 1.3, and 
would therefore reduce the required observer costs. 
The FoA brings with it certain risks in te rms of implementation by third countries and 
RFMOs, given the lack of juri sdiction of the EC over these parties. The result in external 
waters could be increased costs being borne by EC stakeholders, no action being taken by 
third countries/RFMOs, and therefore a re duced impact on safeguarding/improving long 
term economic and social benefits. Given di ffering stakeholder views, no specific ways 
of enhancing the measures are recommended. 
Field of Action 2  
It is clear from stakeholder feedback on th e consultation document, that public opinion 
would in general be very favourable to this Fo A. All are likely to be of the view that 
management measures must be taken based on appropriate resear ch. Certainly public 
opinion is of the view that it is entirely ap propriate for the EC to act on the measures 
proposed. Public opinion is also likely to be fa irly consistent with re gards to the detailed 
implementation of the measures. The FoA br ings with it certain risks in terms of 
implementation by third countries and RFMOs, given the lack of ju risdiction of the EC 
over these parties. The result in external wa ters could be increased  costs being borne by 
EC stakeholders, no action being taken by third countries/RFMOs, and therefore a 
reduced impact on safeguarding/improving l ong term economic and social benefits. 
 
EN 42   EN Field of Action 3  
It is clear from stakeholder feedback on th e consultation document, that public opinion 
would in general be very favourable to this Fo A. All stakeholders are likely to be of the 
view that increased awareness and consultation is to be supported. 
Field of Action 4  
Public opinion would in general be favourable  to this FoA. NGOs and advisory bodies 
are particular supportive and view this FoA as perhaps the most important, while the 
industry is supportive to the extent that the detailed implementation mechanisms for all 
measures is based on suitably rigorous eviden ce and justification. Publ ic opinion is of the 
view that it is entirely appropriate fo r the EC to act on the measures proposed. 
The FoA brings with it certain risks in te rms of implementation by third countries and 
RFMOs, given the lack of jurisdiction of th e EC over these parties. There is also the 
added risk on non-acceptability by EC Member States as well. The result in external 
waters could be increased costs being borne by EC stakeholders, no action being taken by 
third countries/RFMOs, and therefore a re duced impact on safeguarding/improving long 
term economic and social benefits. Additional risks to this FoA relate to control of 
catches and fishing effort on shark resulting in displacement to other fisheries that may 
also be under pressure and susceptible to overfishing. 
Field of Action 5  
It is clear from stakeholder feedback on th e consultation document, that public opinion 
would in general be favourable to this Fo A. NGOs and advisory bodies are particular 
supportive and view this FoA as important, while the industry  is supportive to the extent 
that the detailed implementation mechanisms for all measures is based on suitably rigorous evidence and justification related to different species and the potential impacts. 
Public opinion is of the view that it is entirely appropriate for the EC to act on the measures proposed. 
The FoA brings with it certain risks in te rms of implementation by third countries and 
RFMOs, given the lack of jurisdiction of th e EC over these parties. There is also the 
added risk on non-acceptability by EC Member States as well. The result in external 
waters could be increased costs being borne by EC stakeholders, no action being taken by 
third countries/RFMOs, and therefore a re duced impact on safeguarding/improving long 
term economic and social benefits. Additional risks to this FoA relate to control of 
catches and fishing effort on shark resulting in displacement to other fisheries that may 
also be under pressure and susceptible to overfishing.   
Summarising the analysis of option B
, there are long-term nega tive impacts associated 
with the present status quo (option A). The above actions should go along way to 
reversing those impacts particularly within Co mmunity waters, in relation to both stock 
and ecosystem responses. The key effective ac tions are 1, and 4 wi th the other three 
providing a supporting function. The positiv e environmental impacts, however, could 
only be achieved with full implementation of at  least the two key ac tions which must be 
underpinned by a binding regulation. 
 
EN 43   EN 5.3. Option C 
5.3.1.  Environmental Impacts 
Essentially the actions are similar to thos e outlined in Option B but would attempt to 
reverse the negative impacts much more imme diately to ensure no further damage is 
done. It would be more interven tionist with highly restrictiv e harvesting practices which 
would further impact on other fish and fisher ies within the immediate target fishery. 
Based upon an initial rapid risk assessment on existing data, all high and medium priority 
fisheries would be closed down immediately and only sharks co mplete with fins could be 
landed.  
In terms of environmental impacts the effects would be positive, like Option B, but 
occurring more immediately. This may mean less damage might be  incurred du ring the 
implementation period so stocks are in a be tter condition to recove r since the regulation 
is more immediate. Positive environmenta l impacts may therefore be achieved more 
completely and more quickly. 
The effects would be felt particularly in the NE Atlantic where the mixed nature of 
fishery with an inevitable shark/ray catch mi ght seriously interfere with the fishery if 
Option C is fully implemented. 
5.3.2.  Economic Impacts 
This option would result in a complete ban on the catches of many shark species in the 
short- to medium term , and until such time as TACs are established for individual 
species. In the case of the N. Atlantic and th e Mediterranean, given that most sharks are 
caught in mixed fisheries, the potential eco nomic impact of this option would be a 
complete cessation to all stakeholders  of all current benefits being generated from non-
TAC shark fisheries as outlined in Option A.  As a recommended TAC is only available 
for a few species including t horny skate (11,000 tonnes), this c ould reduce catches in the 
North Atlantic and Mediterranean from around 54,000 tonnes of sh ark to around 10,000 
tonnes. This would result in a direct  and significant  cost of reduced sales values of shark 
species by the catching sector of around Euro 69 million per year22. Given the low 
average  dependency on shark catches in Nort hern and Mediterranean waters, these 
impacts would probably be insignificant  in terms of individual vessel viability for most 
vessels, but could be significant  for some specific metiers/fleets relying heavily on shark 
catches (e.g. specific French fleets in Ba y of Biscay targeting sharks). Further 
quantification is not possible given the lack of current sp ecies reporting which precludes 
an analysis of economic be nefits being generated by specific species or fleets.  
Impacts in the short- to medium-term  on the processing sector  as a whole  would be 
significant  in terms of reduced product for processing and subsequent sale. This would 
mean that current margins/profits on ar ound 43,000 tonnes of product would be forgone. 
Sufficient data/information is not available on margins/profits made specifically from processing shark species in Northern waters  to estimate the economic costs that would 
result. However, it can be assumed that gi ven other species availa ble for processing and 
                                                
 
22 It should be noted that this lost value to the cat ching sector, could to some extent be recovered by 
increases of catches of other non-TAC species. 
 
EN 44   EN the relatively small percentage that sharks make up of total catches in Northern waters, 
that these impacts would probably not be sign ificant enough to result in the difference 
between processors being economically vi able or not, except in cases where any 
individual processors rely strongly on shark catches. Th e impacts can therefore be 
viewed as not significant . 
For the distant water pelagic fisheries, as  already noted shark catches represent a 
significant proportion of total turnover of longline vessels (aro und 25-45% depending on 
the fishery). In the absence of TACs for spec ific shark species, a ban on catches of all 
sharks would result in the short- to medium term  in a loss of revenue  of Euro 93 million 
from the C&S Atlantic, Euro 12 million in th e Indian Ocean and Euro 4 million in the 
Pacific. These impacts are obviously very significant. In the current clim ate of increased 
operational costs (e.g. from fuel price rises), the impacts on i ndividual vessels could very 
well make such fisheries unviable for the catching sector . This is especially likely given 
operational fishing strategies wh ich rely on different species at  different times of the year 
depending on both market prices and species av ailability in different locations. Impacts 
in the short- to medium-term  on the processing sector  as a whole would be significant  in 
terms of reduced product for processing and subsequent sa le. This would mean that 
current margins/profits being made on ar ound 48,000 tonnes of pelagic shark product 
would be forgone. Sufficient data/information is not available on margins/profits made 
specifically from processing pelagic shark sp ecies from distant waters to quantify the 
costs that would result. Some very specialis t shark processing operations could also be 
expected to be so negatively affected as to render them unvi able due to reduced landings 
of shark, but the impacts on the processing sector would be less severe than on the 
catching sector, as it can be expected that processors are engaged with processing other 
species as well as sharks. 
In the longer term, and as TACs are phased in  for all species, Option C can be expected 
to contribute towards re-establishing or increasing the current economic benefits from 
shark fisheries to all stake holders by ensuring long-term sustainability of catches. 
However, it must be remembered that the short-term impacts as discussed above could be very significant for some specific fleet se gments, potentially meaning that operations 
could have ceased to exist by the time stoc ks recovered and/or TACs introduced. The 
magnitude  of the balance of these s hort- and long term impacts should therefore be seen 
in the context of the discussion of the curr ent economic benefits of shark fisheries.  
For the new measure proposed for FoA 5 in Op tion C (landing of all sharks with fins 
with no exceptions), there would be no mer it in stakeholders spending any monies on 
research to demonstrate/ju stify exemptions, so these short-term  costs associated with 
Option B would be saved. Short- and long term  economic costs would therefore involve 
the direct  impact on the catching sector  for those pelagic shark vessels currently gaining 
exemptions (mostly Spanish) of increased fuel costs from landing fins and carcasses in the same port, but for these savings to be outweighed by the inability to sell different products into ports commanding the best pric es (on the basis that current practices 
maximise revenues/profits). Quantification of these impacts is not possible, but 
stakeholder objections to this measure suggest that the industry feel they could be quite 
significant . Likewise a requirement to  land all fins without a ny exceptions, would also 
result in indirect  operational costs if vessels are forced to amend their cutting practices to 
reduce fin weights (and therefore potentially va lues) so as to fall under the 5% rule. The 
measure would also result in costs to the ca tching sector of reduced discard practices, 
 
EN 45   EN which could result in vessels having to us e increased fishing hold space to store low 
value shark meat instead of higher value spec ies. Quantification of the significance of 
these impacts is not possible due to the fact that it is impossible to know the extent to 
which a) changes to cutting pr actices would reduce sales valu es and b) discarding is 
currently taking place and therefore the exte nt to which the measure would reduce 
discards and impact on operational costs. 
5.3.3.  Social Impacts 
In the case of the North At lantic and the Mediterranean, given that most  sharks are 
caught in mixed fisheries, this option would mean that around 50,000 vessels, 100,000 
catching sector jobs, and 50,000 processing sect or jobs could be impacted. Given the 
relatively low importance of shark species as  a proportion of total catches in northern 
waters, these impacts would prob ably not be significant overa ll, but could be significant 
for some specific metiers/fleets and areas, such  as the longline fishery for porbeagle from 
Isle d’Yeu. However a detailed quantification is not possible given the lack of current 
species reporting which precludes an analysis  of economic benefits  being generated by 
specific species or fleets.  
For the distant water pelagic fisheries, as  already noted shark catches represent a 
significant proportion of total turnover of  longline vessels (around 25-45%) and some 
regions e.g. Galicia are very dependent on fish eries. A complete ban on shark fisheries in 
distant waters given the lack  of TACs would affect more  than 300 longline vessels and 
around 5,000 crew, an additional 56 purse se ine vessels and thei r crew, and around 3-
4000 processor sector jobs. In the absence of TACs for sp ecific shark species, a ban on 
catches of sharks, especially in the current  climate of increased operational costs (e.g. 
from fuel price rises), could very well make  such distant water fisheries unviable for the 
catching sector, with resulting social  implications in terms of job losses. This is 
especially likely given operational fishing st rategies which rely on different species at 
different times of the year depending on both market prices and spec ies availability in 
different locations. Some very specialist shark processing operations  could also be 
expected to be so negatively affected as to render them unvi able due to reduced landings 
of shark, with resulting negativ e social impacts in terms of  employment, but given the 
ability/likelihood of processing companies obtaining species from other sources and not 
be entirely dependent on longl ine catches, the impacts may not  be as severe as for the 
catching sector. 
In the longer term, and as TACs are phased in  for all species, Option C can be expected 
to contribute towards re-establishing or increasing the current social benefits from shark fisheries to all stakeholders  as discussed earlier in Op tion A, by ensuring long-term 
sustainability of catches.  
For the new measure proposed for FoA 5 in Op tion C (landing of all sharks with fins 
with no exceptions), the short and long-term direct and indirect so cial impacts would be 
the same as those described under FoA 5 for Option B, except even  greater because no 
vessels would be afforded the de rogations. Impacts would be both certain  and 
significant . 
 
EN 46   EN 5.3.4.  Risks, trade-offs/synergies, pub lic opinion, enhancing measures 
It is clear from stakeholder feedback on the consultation document, that while some 
NGOs might be supportive of this Option,  the industry would certainly not be. 
Compliance and enforceability issues would certainly therefore be a significant concern. In addition, it must be rememb ered that the short-term impacts as discussed above would 
be very significant. The magnitude  of the balance of these s hort- and long term impacts 
should therefore be seen in the context of the discussion of the current social benefits of 
shark fisheries, and the proba ble trade-off between short-term costs and long-term gains 
could be unacceptable and hardly supported by politicians. 
The Option also brings with it certain risks in terms of implementation by third countries 
and RFMOs, given the lack of jurisdiction of the EC over these partie s. There is also the 
added risk on non-acceptability by EC Member States as well. The result in external 
waters could be increased costs being borne by EC stakeholders, no action being taken by 
third countries/RFMOs, and therefore a re duced impact on long term economic and 
social benefits. Additional risks to this FoA relate to control of catches and fishing effort on shark resulting in displacement to other fish eries that may also be under pressure and 
susceptible to overfishing. 
In summary, implementation of Option C woul d have similar environmental impacts to 
Option B in that it would slow down or reverse the decline in shark populations, 
particularly the more vulnerable species, and reverse negative trends in ecosystem 
structure. It would, however, achieve these positive impacts more immediately and more 
extensively than Option B. Never the less the social and economic impacts would also be 
more immediate for an unprepared industry an d consequently cause some hardship in 
some fishing regions. 
6. A
DMINISTRATIVE AND MANAGEMENT COSTS  
Administrative costs  are those that are defined as “the  costs incurred by enterprises, the 
voluntary sector, public authoriti es and citizens in meeting legal obligations to provide 
information on their action or production, eith er to public authorit ies or to private 
parties” (EC Impact Assessment Guidelines, Sept 2006 update). The administrative costs were estimated using the EU Standard Cost Model. Please find here the estimation's main 
results (see the detailed calc ulation in Appendix IV.):  
Option A  (the status quo ) results in no net change  to administration costs.  
Option B  (the proposed CPOA) is estimated to  result in administration costs of around 
€19 million.  Around 99% of these costs relate to Field of Action 1. The proposed 
measure to change catch reporting for elasmobr anchs to species level results in 55% of 
the costs incurred by the catc hing sector through additional labour a llocated to more 
detailed catch reporting and 20% is incurr ed by the post-harvest sector for resulting 
alterations to reporting. A fu rther 24% is incurred by Memb er States resulting from 
additions to the DCR, but mainly through th e administration costs associated with the 
proposed observer scheme. 
 
EN 47   EN With the large numbers of vessels and s eafood enterprises aff ected by the proposed 
change to reporting requirements, the addi tional administration costs estimated for 
RFMO and RAC secretariats to increase rese arch and information on elasmobranch are 
comparatively minimal. These will however  have budgetary implications and require 
future funding. 
The total administration costs for Option C  (application of a strict precautionary 
approach) are estimated to be just over €17 million . Option C incurs similar levels and 
target group apportionment of costs as Optio n B. Some costs savi ngs result from the 
outright ban on high and medium  priority fisheries resulting in no observer scheme in 
these fisheries and no costs associated with the application for and processing of finning 
and landing exemptions. 
Management costs  essentially cover the cost of imple mentation – be this management or 
research – and are considered separately. The total management costs for options B and C are estimated to be from the first year between just over €4 million (soft option) and 
almost €14 million (hard option). This amount can be from the fifth year about €5 
million.  
The total anticipated costs  (both management and administrative) are included in 
Appendix IV. Option B results in  marginally higher overall co sts compared to Option C, 
with the hard options both totalling just ove r €30m in the first year, decreasing to annual 
costs of approximately €23m in Year 5. 
7. C
OMPARING THE OPTIONS  
The options for applying the Shark Action Plan have been examined above along with 
their relative impacts. It remains to assess th e effectiveness of these options for achieving 
the stated objectives of the Plan. These objectives were: 
• Ensuring a coherent approach between inte rnal and external EC fishery policy for 
sharks. 
• Deepening the knowledge both on shark fisherie s and on shark spec ies and their role 
in the ecosystem. 
• Ensure that directed fisheries for shark are sustainable and that by-catches of shark 
resulting from other fisher ies are properly regulated. 
The probable effectiveness of the three optio ns of achieving these objectives can be 
compared and an indication of their relativ e efficiencies can be gained by comparing 
their advantages and drawbacks. 
Advantages, drawbacks and rela tive efficiency of options 
 
EN 48   EN 7.1. Option A: Status quo 
7.1.1.  Advantages 
In the short-term, there are currently signi ficant economic and soci al advantages to no 
change in the present situation. Current catches are worth around EUR 196 million annually with significant income dependency particularly for the external fleets and 
amongst the major fishing regions of the Comm unity. This benefit extends to secondary 
and tertiary tiers of the indus try. In addition, much of the sh ark is retailed and consumed 
within the EU therefore it makes a signi ficant contribution to EU fish supplies. 
7.1.2.  Drawbacks 
Most of the advantages listed above are shor t-term. All the indicators suggest that current 
stocks are declining rapidly and that some may be already badly damaged. This is, in 
itself, a drawback in environmental term s, of doing nothing, but it would have the 
additional disadvantages of undermining the economic and social benefits from shark 
fishing described above. These progressively negative effects would affect some of the 
most sensitive fishing regi ons of the Community, such as Galicia, Brittany and NE 
Scotland. Clearly, market supplies would also su ffer. Such effects might also be felt in 
third party countries who often supply crew for th e distant water flee t. With such long-
term costs this cannot be rega rded as an efficient option. 
With increasing damage to shark stocks, the ro le of many sharks as top predators with a 
regulatory role in ecosystem function, may ha ve wider effects within the ecosystem and 
its biodiversity as they are progressively removed. 
There will also be drawbacks for the Co mmission itself since doing nothing on an issue 
widely perceived to be a serious problem w ill lead to increasing fr iction with NGOs, civil 
society and concerned Member States. This would also compromise the standing of the 
EU in international manage ment and conservation bodies. 
This option is neither effective nor efficient in the long-term. 
7.2. Option B: Proposed Fields of Action 
7.2.1.  Advantages 
The main advantages of Option B are init ially environmental along with improved 
governance and best practice. If all the actions included in this option were fully 
implemented and complied with, the objectives of the Plan would be achieved and the 
negative impacts on shark populations and biod iversity minimised or reversed through 
the positive impact of the actions. 
Governance should be linked with improved c oherence between home and external fleets 
since the outputs of the CPOA should take in to account and address the interests of both 
fleets. It will also require much closer collaboration with RMFOs and international 
bodies. Moreover the EU can be seen to be taking the initiative in a plan of some significance in the marine environment, th ereby increasing its political capital. 
 
EN 49   EN Ultimately, in the longer term although there may have been initial costs within the 
industry the management of the shark stocks will guarantee a more stable and sustainable 
activity within the industry th ereby conferring more long term benefit and more supply. 
The consultation action (Activity 3) will also  help a more informed civil society and 
industry. 
7.2.2.  Drawbacks 
There are significant direct and indirect cost s associated with both the data collection 
elements (Actions 1 and 2) and the manage ment elements (Actions 4 and 5). Data 
collection always has a cost attached to it. Catch and effort monitoring will have some administrative associated with it both w ithin the industry and the Commission. The use 
of observer pilot schemes could be particularly costly (Section 6). In addition to monitoring and observer costs there would al so be research costs particularly for 
measures of Action 2. The consultation proce ss envisaged in Option 3 would also have a 
cost. 
The implementation of Option 4 and 5 would have their costs on the industry. As 
management measures are implemented there w ill be a curtailment in fishing for sharks 
which will have economic and social costs w ithin the industry and fishing communities. 
The extent of these costs would depend upon the degree of limitations put in place and 
the extent to which fishing strategies could be  altered so as to minimise economic costs. 
The prohibition of discards could prevent th e full benefit of fishing from the target 
species to be realised. This would also be the case in Option 5 where fishing costs may 
also be increased due to increas ed frequency of landings needed. 
In the longer term many of these costs would be  offset by the more sustainable sub-sector 
as described under ‘advantages’. 
To be fully effective new regul ations would had to be of a binding nature which brings 
additional costs of ensuring complia nce through inspection and monitoring. 
This option is likely to be effective but will ha ve its costs, particularly in the short term. 
If properly adjusted, however,  it should be reasonably cost effective and efficient. It 
seems to offer the most efficient way of achieving effectiveness of the objectives. 
7.3. Option C: Strict Precautionary Approach 
7.3.1.  Advantages 
It should achieve the objectives of data collection and management as per Option B but 
achieve them more quickly and with less dama ge being done to shark stocks during the 
implementation period. 
7.3.2.  Drawbacks 
The range of costs is likely to be similar to Option B but the immediate curtailment of all 
medium and high risk fisheries will have ra pid and more profound consequences for the 
industry. The more rigorous regulations, whic h will be binding, will present much greater 
issues of compliance. This could further increase the risks of compliance not being 
achieved. 
 
EN 50   EN The ultimate effectiveness will be achieved in advance of Option B but the increased 
costs, largely economic and social, will largely be felt by the industry and also the consumer as market supplies are more reduced . The efficiency of th is option may be less 
than that for Option B. 
7.4. Preferred option 
Given the evidence for a deteriorating situ ation for a number of shark populations, it 
cannot be said that Option A
 will enable an effective systematic response to be arrived at 
by the EU in a timely fashion and the present situation could become unacceptable. The overall negative impacts of continuing with the status quo  were outlined in the previous 
Section. It is this that the Commission intends to mitigate th rough fields of action within 
the CPOA. 
If fully implemented and complied with Option C
 would be highly effective in achieving 
both data and management objectives. Howeve r, the strong drawbacks pointed out above 
do not allow the choice of this option as the preferred one. It is important to recall that 
this option also brings with it certain risks in terms of implementation by third countries and RFMOs, given the lack of jurisdiction of  the EC over these parties. The result in 
external waters could be increased costs be ing borne by EC stakeholders, no action being 
taken by third countries/RFMOs. 
Our preferred option is an amended version of Option B
 (including the "soft" sub-
option for measures 1.3, 1.4 and 1.10 and the "hard" sub-option for measure 4.4 –see 
Appendix II). 
Following the analysis made in the previous se ctions, it could be inferred that not all the 
proposed actions seem compulso ry. A number of them could be dismissed without major 
detriment for the whole Plan of Action in consideration of the workload involved in 
relation to the availa ble human resources. 
In the preferred option, measures 2.2, 2.3, 2.4, 2.5, 2.7 and 3.3 are dropped and a new 
measure (4.10) is added. 
The measures to be dropped  are the following ones: 
Under Field of Action 2 : 
2.2 To conduct regular assessment in order to  identify threats to  shark populations 
and to determine the fishing mortality by stoc ks and, if possible, partitioned by fishery. 
 Reason: This task should be accomplished by relevant scientific advisory bodies without 
specific resort to Community action. Although the existing mechanism s could be considered 
insufficient, the lack of human resources  in DG MARE does not allow making further 
progress. Furthermore, the relative weight of this action in the whole CPOA has been 
considered low to medium and its implementation optional. 
2.3 Identification of space-time boxes in ar eas where juveniles or spawners are 
abundant. 
 Reason: Already covered by measure 4.8 
 
EN 51   EN 2.4 Study biology and ecology of sharks. 
 Reason: This task should be accomplishe d by relevant national and international 
research bodies without specific resort to Community action. Although the existing 
mechanisms could be considered insufficien t, the lack of human resources in DG MARE 
does not allow making further progress. Furthe rmore, the relative weight of this action 
in the whole CPOA has been considered lo w to medium and its im plementation optional. 
2.5 Develop prototypes, monitor experime nts and propose measures for improving 
size selectivity and for reducing unwanted by-catch and discarding of no commercial 
species. 
 Reason: DG Research is financing a collaborative project, MADE , selected 
through FP7, which perfectly fits into th is particular action. MADE addresses the 
objective of "mitigating adverse ecological impacts of open ocean fisheries", i.e. of 
pelagic long lines and FAD fis heries. Sharks are concerned as by-catch for these two 
fisheries. The field of the programme co rresponds to the main fishing grounds of 
European fleets in the Indian and Atlantic  oceans, and in the Mediterranean Sea. 
The programme begun in May 2008 and will end in 2012 but deliverables will be 
available from December 2009 on. Therefore, it seems appropriate to see this action in 
the context of the EC Plan of Action. 
Although this could be considered insufficien t, the lack of human resources in DG MARE 
does not allow making further progress. Furthe rmore, the relative weight of this action 
in the whole CPOA has been considered lo w to medium and its im plementation optional. 
2.7 Foster implementation of internationally  coordinated studies on straddling and/or 
shared stocks. 
 Reason: This task should be accomplishe d by relevant inte rnational research 
bodies without specific reso rt to Community action. Alt hough the existing mechanisms 
could be considered insuffi cient, the lack of human resources in DG MARE does not 
allow making further progress. Furthermore,  the implementation of this measure has 
been considered optional. 
Under Field of Action 3 : 
3.3 Foster stakeholder awareness and cons ultation regarding sh ark management and 
best practices to reduce unwanted by-catch  through programs promoted by RFMO and 
international fishermen associations. 
Reason: This task should be accomplished by relevant international bodies without 
specific resort to Community action. Although the existing mechanisms could be considered insufficient, the lack of human resources in DG MARE does not allow making 
further progress. Furthermore, the implementa tion of this measure has been considered 
optional. 
The measure to be added
 is the following one: 
4.10 Co-operate through CMS and CITES to controlling shark fishing and trade. 
 
EN 52   EN  Reason: The Community is already coope rating with these two international 
Conventions. However, strengthened participation on shark conservation related activities is advisable. Additi onally, this measure has been  suggested by a number of 
stakeholders and is clearly relevant and appropriated. 
The Fields of Action and th e corresponding measures actual ly included in the draft 
CPOA can be found in the following table: 
 
EN 53   EN Operational objectives, measures and implemen tation mechanisms resulting from the IA 
Operational 
objective Basic Measures Implementation mechanisms and options 
Increase investment in shark data collection at 
landing sites and by processing and marketing industries. Increase the requirements of the DCR to specify shark landings by 
species.  
Use of Control regulation 
Establish systems to provide verification of catch 
information by species and by fishery. As above. Focus should be on strengt hening implementation of existing 
control regulations 
Mandate representative coverage on EC fishing 
vessels by on-board observers for vessels over 24 m 
and with recent by-catches figures of more than 
10% to 15% (depending on the particular fishery) of sharks over the total catch. Soft option
: 40% observer coverage for hi gh priority pelagic fisheries 
that catch more than 10% shark bycatch by 2013. 1. Having reliable and detailed species-
specific 
quantitative and biological data on catches and landings as well 
as trade data for 
high and medium priority fisheries, after three years of implementation.
23 EC level 
For all the distant water fleets not covered by the 
measure above and taking sharks as a by-catch, 
mandate at least 10% obser ver coverage by 2013. 
For high priority shallow-water fisheries in the NE Atlantic, mandate pilot-based observer scheme (e.g. c. 25 observers) by 2013. Soft option
: 10% observer coverage of a ll distant water fleets not 
covered by Measure 1.3 by 2013 and pilot-based observer scheme (e.g. 
c. 25 observers) by 2013 on high priority shallow-water fisheries in the 
NE Atlantic. Refine over time with better landings data from Measure 
1.1 and 1.2. 
                                                 
23 Fields of Action 1 & 2 merged 
 
EN 54   EN Operational 
objective Basic Measures Implementation mechanisms and options 
Ensure that all landings and trade of shark fins, meat 
and oil are recorded separately by commodity and to the species level. Adapt Reg. 1921/2006 on landings to presentation of shark commodities 
by species. 
 Promote improved species-specific catch and 
landings data and monitoring of shark catches by 
fishery. Promote adoption of regulatory measures for shark catches reporting 
(see Measure 2.6) through binding measures. 
Improve, in cooperation w ith FAO and relevant 
fisheries management bodies, the monitoring and 
reporting of catch, bycatch, discards, market and international trade data, at the species level where possible. Financial support to FAO, and cont ribution to Working Groups and 
RFMO meetings.  
Request through the FAO and Regional Fisheries 
Management Organisations where appropriate that 
these organisations develop and implement Regional Shark Plans and associated measures to assist in species identification and monitoring, as 
called for in the IPOA–Sharks, by mid-2009 in 
order to report to the 15th Meeting of the CITES Conference of Parties. Contribution to Working Groups and RFMO meetings to assist NPOA 
development. Consider technical and financial assistance through FPAs. 
NPOA outputs  RFMO 
level 
Promote the identification and reporting of species-
specific biological and trade data. RFMO alter reporting requirements accordingly through 
recommendations. 
 
EN 55   EN Operational 
objective Basic Measures Implementation mechanisms and options 
Encourage representative coverage on fishing 
vessels by on-board observers for vessels over 24 m fishing in the high seas and with recent by-catches 
figures of more than 10% to 15% (depending on the 
particular fishery) of sharks of the total catch. For other fleets not covered by the measure above and taking sharks as a by-catch, mandate at least 10% observer coverage by 2013. Soft option
: 40% observer coverage for hi gh priority pelagic fisheries 
that catch more than 10% shark bycatch by 2013. 
Member State level Monitor recreational catches and distinguish 
between the fishing mortality exerted by recreational and commercial fishing. Mandatory reporting of recreational seafishing landings of 
elasmobranchs. 
Studies into mortality following release in both recreational and 
commercial fisheries  
2. Being able to 
efficiently 
monitor and assess shark stocks on a species specific 
level and 
develop harvesting strategies with the 
principles of EC and 
RFMOs 
level Enhance EC and RFMOs research programmes to 
facilitate data collection, monitoring and stock 
assessment on a species-specific level. Following ICES and RFMOs advice, seek specific scientific advice 
based on MoU with JRC and STEFC through specific requests. 
Promote specific research programmes through the 7th Framework 
Programme (2007-2013). 
Contribution to Working Groups and RFMO meetings. Finance provided 
to studies. 
 
EN 56   EN Operational 
objective Basic Measures Implementation mechanisms and options 
biological 
sustainability and rational long term economic use, after three 
years of 
implementation.
24 Member 
State level Develop national expertise Promote uptake of courses, facilitate exchange and mobility of 
researchers through funding available under FP7. 
Facilitate stakeholder awareness and consultation 
regarding shark management and best practices to reduce unwanted by-catch through RAC programs. Solicit inclusion of shark management issues on agenda of RACs  
EC level Encourage Member States to allow public access to 
relevant aggregated data for fleets and information on shark fisheries, while protecting the right of 
confidentiality. Establish internet-based resources either on Europa website or via 
independent provider, but respecting issues of individual vessel / owner 
confidentiality. 3. Improve and develop 
frameworks for 
establishing and coordinating effective consultation involving 
stakeholders in 
research, management and educational 
initiatives Member 
State level Launch educational programs aimed specifically at 
educating fishermen and the public about shark and 
ray conservation programs and restrictions. Promote specific programmes with financial support of EFF or through 
NGOs. 
Limitation or prohibition of fishing activities in 
areas that are considered sensitive to endangered 
stocks. Specific legislation. 4. Adjust catches 
and fishing 
effort to the available resources with EC level 
Stronger limitation of fishing effort by relevant 
fisheries. Specific legislation.  
                                                 
24 Fields of Action 3 & 4 merged 
 
EN 57   EN Operational 
objective Basic Measures Implementation mechanisms and options 
Foster programmes and analysis to adjust fishing 
effort at international level. Active contribution to Working Groups  and RFMO meetings to develop 
resolutions to limit shark-related effort. 
Establish catch limits by stocks in conformity with 
the advice provided by ICES and by the relevant RFMOs. Hard option
: Immediate imposition of TA Cs and other management 
measures as recommended by ICES and by the relevant RFMOs. 
Prohibit all shark discards and require that all 
catches (including by-catches) are landed. Unwanted by-catches of sharks that have a chance 
to survive must be releas ed back into the water. Provide derogations for species with high post-discard survivability e.g. 
some ray species. 
Propose discard ban at RFMO level. Provide derogations for species 
with high post-discard survivability e.g. blue shark. 
Increase size and species selectivity in order to 
reduce undersized catches and unwanted by-catch. Develop joint research programmes that would test different gear 
options. Possible maximum size limits to conserve large breeding 
females. 
Establish bycatch reduction programs for shark 
species considered Critically Endangered or 
Endangered by relevant in ternational organisations. Dedicated RFMOs working groups on shark fisheries that would analyse 
data available and make  management recommendations to the Plenary. 
Establishment of space-time boxes in areas where 
juveniles or spawners are abundant, esp. for 
vulnerable or threatened species. Specific legislation.  particular 
attention to high priority fisheries and vulnerable or threatened 
shark stocks, 
after three years of implementation.
25 Both EC 
and RFMO levels 
Provide international cooperation in CMS and 
CITES with a view to controlling shark fishing and 
trade. Proactive participation in CMS and CITES in support of shark 
conservation measures. 
                                                                                                                                                                                                                                                        
25 Fields of Action 6 and 7 merged 
 
EN 58   EN Operational 
objective Basic Measures Implementation mechanisms and options 
Examine the possible impact of market mechanisms 
on conservation measures, including for shark species within the framework of the ongoing 
evaluation of the Common Market Organisation in 
fishery and aquaculture products. Review the applicability of market intervention measures to endangered 
shark species. 
Confirm the ban of finning practices26. As a general 
rule, it will be prohibited to remove shark fins on 
board, tranship or land shark fins. Any exception to this rule will have to be fully justified on solid and 
objective grounds and documented prior to the 
issuing by the Member State of the special permit. 
Member States should not issue special permits to vessels not having fulfilled this condition. 
To review the 5% rule by requiring that in no case 
shall the weight of the fins exceed 5% of the 
dressed  (gutted and beheaded) carcass weight of the 
shark catch. However, Member States having set up 
and implemented data collection programmes 
proving that this percentage could be increased in certain cases, could do so up to a percentage corresponding to 5% of the live weight of the shark catch. 5. Minimize 
waste and 
discards from shark catches requiring the 
retention of 
sharks from which fins are removed and strengthening control 
measures. Both EC 
and RFMO 
levels 
For vessels of Member States having been exempted 
from the obligation of landing of sharks with fins 
attached, introduce the requirement to land shark fins and carcases at the same time in the same port. Amendment of Reg. 1185/2003. 
                                                 
26 Practice whereby the fins are removed from sharks, with the reminder of the shark being discarded at sea. 
 
EN 59   EN 8. MONITORING AND EVALUATION  
Identification of core indicators 
A series of indicators have been drafted in  the table overleaf. Th ese have been divided 
into: 
• Impact indicators: CPOA broad policy objectives 
• Result indicators: CPOA Fields of Action (specific objectives) 
 
EN 60   EN Table 8: Core indicators for monitoring and evaluation 
OBJECTIVE LEVEL TARGET OBJECTIVELY VERIFIABLE 
INDICATORS MEANS OF 
VERIFICATION  IMPORTANT RISKS AND 
ASSUMPTIONS 
Broad policy objectives  
1. Deepening the knowledge both on 
shark fisheries and on shark species and 
their role in the ecosystem. Activity and outputs of elasmobranch-specific 
Working Groups 
Number and focus of species and fisheries-
specific management mechanisms elucidated ICES, STECF and 
RFMO reports Research is focused on vulnerable 
and threatened species. Dependent 
upon regular risk assessment and 
prioritisation. 
Shark populations recover to sustainable 
levels.  ICES, STECF and 
RFMO reports 2. Ensure that directed fisheries for shark 
are sustainable and that by-catches of 
shark resulting from other fisheries are 
properly regulated. Number of species in the IUCN Red List CR, 
EN & VU categories IUCN Red List updates Some species are already critical and 
their potential for recovery 
uncertain. 
3. Encourage a coherent approach 
between the internal and external EC 
fishery policy for sharks Uptake and consistency of internal EC 
regulations related to sharks into RFMO 
resolutions. EC Regulations and 
relevant RFMO 
resolutions  The adoption of a precautionary 
approach may not be acceptable to 
all RFMO CPs. 
Fields of Action - specific objectives  
1. Facilitate improved 
identification and reporting 
of species-specific catch, landings and market data MS / EC / 
RFMO Increased proportion of catches and landings 
reported to species level. 
Level of observer coverage on high priority 
and other fisheries. 
DCR regulations update  and strengthened to 
reflect the Action Plan. Eurostat, ICES and FAO 
databases Nomenclature can be clarified and 
agreed 
2. Conduct research and 
compile the necessary 
information to assess threats to shark populations and 
protect critical habitats, and 
implement sustainable and 
rational harvesting strategies  MS / EC / 
RFMO New stocks assessed. 
New national expertise developed ICES, STECF and 
RFMO reports FP7 funding priorities coherent with 
Action Plan-related research needs 
 
EN 61   EN EC RACs incorporate shark management issues 
MS public access portal providing access to 
relevant information on sharks RAC reporting 
Website or other portal Regional issues recognised 
Technical and financial resources 
made available. Public information 
needs identified. 3. Improve stakeholder 
awareness and consultation 
processes 
MS EFF fund uptake includes education & 
awareness building for shark conservation MS mid-term review of 
EFF uptake National fisheries administrations 
encouraged to include shark issues 
in EFF programmes 
4. Adjust fishing effort and 
catches to the available 
resources EC / 
RFMO Number of fisheries where effort and / or catch 
is limited (all fishery / spatial / seasonal) due to 
shark-related concerns 
Imposition of a discard ban (except for certain 
species / fisheries where post-discard mortality 
is acceptable) 
Imposition of maximum size limited for 
certain species. Relevant regulations and 
resolutions. Key risk is the acceptability of EC 
measures to RFMOs and their 
Contracting Parties.  
5. Minimize waste and 
discards from sharks EC / 
RFMO Amendments to Reg. 1185/2003, with 
sufficiently justified applications for 
derogations Revised regulation(s) 
and MCS records Consensus agreed within Member 
States. 
 
EN 62   EN Monitoring and evaluation 
The following is proposed: 
• An interim evaluation report on the qualitative and quantit ative implementation of the 
programme and on the results so far achie ved after three year s of implementation. 
• A communication on the continuation of the programme. 
• A full evaluation report after six years of implementation. 
 
EN 63   EN  
APPENDIX I 
Summary of stakeholder feedback presented to the European Commission 
Prior to the commencement of this study, the Commission identif ied nine fields of action 
that it believed should be addressed in an EU Action Plan for Sharks. Stakeholders were 
invited to express their views on these fields of action, and present their opinions as to 
what further measures would be appropriate  to reinforce the policy of the European 
Community on the conservation and management  of sharks. The input received in the 
consultation process has been used to info rm this report and the impact assessment 
conducted of the envisaged Action Plan. This Appendix presents a brief summary of the 
contributions made by stakeholders to th e EC. It is not inte nded to be an all 
encompassing presentation of all the views contained in the contributions, and more 
detail on the specific views of stakeholders is  contained in the cont ributions themselves, 
which can be found at the relevant EC website. 
http://ec.europa.eu/fisheries/cfp/gover nance/consultations/consultation_111207_contribut
ions_en.htm  
Field of Action No. 1: Facilitate improve d species-specific catch and landings data 
and monitoring of shark catches. 
Sector Some specific comments and concerns 
Industry • Appropriate for Community to act, question whether data will improve knowledge about 
status of sharks in eco-system 
• Important for processing/marketing sectors of contracting parties to RMFOs to be 
included 
• Should be easy in recreational fisheries 
• Could have large negative economic/social impact in developing countries 
• Strong environmental benefits through better knowledge 
Recreational • Important to distinguish between landings and mortality, and also be sub-sectors of the 
recreational sector in terms of data collection and regulation 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
• Declaration systems need to be more precise 
NGO and 
others • Very important and entirely appropriate for EC to act 
• Should include data collection at sea and should include FPAs 
 
EN 64   EN • Could be facilitated by dedicated landing ports for shark 
• Commission could play an important role in standardizing names across 
countries/regions 
• Could be facilitated through incentives not just penalties 
• EU action should not be held up by lack of international or regional action 
• Not properly distributed – need more emphasis on MS and international level, not just 
RMFOs 
• Only minor economic/social costs of better data collection and reporting, but impacts of 
not doing so could be very serious 
• Very important environmental benefits 
• Use CCAMLR and DCR as model 
STECF • An appropriate area where progress has been made in recent years 
• There is a need to collate and verify existing information. 
• The recording of the catch of sharks as bycatch is required, as is biological information 
for stock assessment purposes  
 
Field of Action No. 2: Facilitate the iden tification and reporting of species-specific 
biological and trade data.  
Sector Some specific comments and concerns 
Industry • Appropriate for Community to act but terms need to be gradual  
• Concern about lack of reporting of Asian vessels and ability to enforce, and proposed 
measures not complete at regional level 
• Impacts on EU fleet would be serious, and the proposed extent of coverage is not 
needed in order to obtain reliable information 
• Port sampling would be better in developing countries 
• Limited environmental impact on Community directed fisheries given existing 
reporting, but significant on non-EU fleets 
Recreational • Supportive 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
• Declaration systems need to be more precise 
 
EN 65   EN NGO and 
others • Separate catch reporting in field of action 1, and trade issues in FoA 2 i.e. move 
observer coverage measures to FoA 1 
• >24m cut off for observer coverage too large 
• Suggest 10% observer coverage, and move from full to partial coverage must be phased 
• Observers when bycat ch more than 10% 
• Trade data to be covered could be broadened to include all/additional products 
• Use CCAMLR and DCR as model 
• Potential problems with trade species-specific data should not delay FoA 1. 
STECF • The proposals for full observer coverage for >24 m vessels and those with >10-15% 
bycatch may encourage misreporting by those not carrying observers. 
• It should be mandatory for all vessels wishing to land shark fins without the 
accompanying carcass, to carry observers on board. 
• Increasing observer coverage is expensive. 
 
Field of Action No. 3: Compile the necessa ry information to assess threats to shark 
populations, determine and protect critica l habitats, and implement harvesting 
strategies consistent with the principles of  biological sustainability and rational long 
term economic use.  
Sector Some specific comments and concerns 
Industry • Appropriate to act, but need be tter mapping for space-time boxes 
• Proposed measures not complete at regiona l level, and will be difficult to enforce 
• Limited impact on Community directed fisheries but could be impacts on incidental 
catches 
• Significant costs implications on developing countries 
• Needs amending to be effective on Asian fleets 
• Positive environmental impact 
Recreational • Supportive but need to be aware of value of recreational fisheries 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
NGO and 
others • Appropriate to act. Proposals will be particular ly relevant for establishing Natura 2000 
sites for any sharks listed under the Habitat Directive. 
 
EN 66   EN • Recommend the models & approaches used by the international expert WG convened 
last year by the Lenfest Ocean Program to set annual catch limi ts for a variety of 
fisheries 
• No new shark fisheries to be allowed without EIA to include threats 
• Properly distributed 
• Social/networking and raised profile benefits  of better research, and identification of 
economically sustainable fisher ies. Economic and social impacts of no action would be 
serious 
• Need to foster technical expertise at national level 
STECF • No comments 
 
Field of Action No. 4: Develop research  projects to assess threats to shark 
populations and implement harvesting strate gies consistent with the principles of 
biological sustainability and ra tional long term economic use.  
Sector Some specific comments and concerns 
Industry • Appropriate to Act, especially  to ensure that management decisions are taken based on 
proven data and not just on speculation 
• Proposed measures not complete at regional level 
• Impacts on EU and developing countries dependent on harvesting strategies chosen and 
balance of imports 
• Environmental impacts positive, but less implementable if social/economic impacts very 
large and negative on fleets 
Recreational • Supportive but need to be aware of value of recreational fisheries 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
NGO and 
others • Suggest merging FoA 3 and 4, because the title of FoA 4 is broader than its measures  
• Conservation targets could be broadened and should seek to minimize not reduce 
bycatch 
• Need to foster technical expertise at national level 
• Appropriate to act because the proposals in this field of action are consistent with an 
ecosystem-based approach to fisheries ma nagement, a stated goal of the Community. 
• Not distributed properly because the document proposes no role for Member States and 
neglects to include bycatch reduction research in programmes fostered regionally. 
 
EN 67   EN • Social/networking and raised profile benefits  of better research, and identification of 
economically sustainable fisher ies. Economic and social impacts of no action would be 
serious 
• Determining important parameters and learning how to minimise shark bycatch and 
discard mortality are key steps toward safe guarding shark popula tions & the ecosystems 
they support. 
STECF • Suggests that the Community level proposal “Study biology and ecology of sharks” 
should be reworded to reflect the true focus which is to target gaps in knowledge which 
are important for assessing threats in the shark populations. 
 
Field of Action No. 5: Improve and de velop frameworks for establishing and 
coordinating effective consultation involvi ng stakeholders in research, management 
and educational initiatives within and between States.  
Sector Some specific comments and concerns 
Industry • Appropriate to act, but m easures need modification 
• Measures not properly distributed. Too much emphasis on RACs and not enough on 
industry representation 
• Public access should only be co nsidered from a standpoint of  aggregate data for fleets, 
protecting the right of confidentiality 
• Community and regional measures should be the same 
• Strongly positive social impacts, economic impacts uncertain 
• Environmental impacts positive, but less implementable if social/economic impacts very 
large and negative on fleets 
Recreational • Supportive. Anglers must not be overlooked and can play important part in tagging 
programmes 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
NGO and others • Need a broad definition of stakeholders 
• Need to include advice with regards to mi nimizing bycatch, not just unwanted animals 
• Education also needs to focus on threats to sharks, not just about conservation 
programmes and regulations 
• Appropriate to act and well distributed 
• Strong positive economic, social and environmental benefits 
STECF • No comments 
 
EN 68   EN  
Field of Action No. 6: Adjust fishing effort to the available resources.  
Sector Some specific comments and concerns 
Industry • Must be carefully studies to assess social/economic impacts 
• Measures equally distributed, , but must be based on scientific data and evidence, not 
speculation 
• Economic/social impacts could be great but handled, but concern over Community fleet 
being affected with less effo rt/concern on non-EU vessels 
• Suggest merging fields of action 6 and 7 
• Positive environmental impact but must be equally imposed on all fleets, not just EU 
Recreational • Supportive and suggest that some species  could be for recreational catches only 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
NGO and 
others • One of the most crucial FoA 
• Should specify emergency measures to protect from excess effort 
• Potential for eco-tourism ‘effort’ 
• Need closed areas in-shore, and no  expansion of effort with EIA 
• Appropriate to act in line with FAO, and Commission’s stated goals of substantially 
reducing EC fishing capacity and adopting an ecosystem approach. 
• In terms of distribution, should propose options for encouraging meaningful and 
enforceable reductions in fishing effort, as we ll as closed areas, at the national level and 
guard against effort displacement to other sensitive areas or the waters of other 
countries. 
• Essential for economic, social and environmental benefits 
STECF • No comments 
 
Field of Action No. 7: Adjust catches to the available resources.  
Sector Some specific comments and concerns 
Industry • Suggest merging fields of action 6 and 7 
• Need for good mapping 
• Need to carefully consider different character istics of fisheries and species in the detail 
 
EN 69   EN of the measures 
• Balance in distribution between Community and RMFO, but must be based on scientific 
data and evidence, not speculation 
• Economic/social impacts would depend on application of measures in EU and 
developing country fleets 
• Positive environmental impact but must be equally imposed on all fleets, not just EU 
Recreational • Need to distinguish between discards in co mmercial fisheries and releases in angling 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
• In favour of the adoption of catch limits for sharks, fixed on the basis of the best 
possible evaluations produced by ICES or the scientific committees of concerned RFMOs or, when these evaluatio ns are not available, in favour of the adoption of 
precautionary TACs to be established on the basis of fishing statistics and 
recommendations of independent and institu tionally recognized scientific authorities 
NGO and 
others • One of the most crucial FoA 
• Need realistic timelines 
• In favour exceptions to the EU discard ban fo r shark species with a high discard survival 
rates and a chance to survive capture. Should also grant exceptions for shark species that 
are considered by IUCN as Threatened (Critically Endangered, Endangered or 
Vulnerable), and Commission should promote re lease of shark species that are legally 
protected. 
• Trawl fisheries with high bycat ch of skates and rays should be among the first fisheries 
subjected to the new discard ban rules. 
• Should not be reserved for undersized sharks 
• Fisheries management measures under this field of action should include not only Total 
Allowable Catches (TACs) and quotas, but size limits (minimum, maximum, and slot) and restrictions on fishing gear, and sharks should be regularly considered as part of the 
review of technical measures. 
• Urge precautionary approach, EIAs, and emergency measures 
• Appropriate to act, but need more measures at MS level 
• Short term costs will be outweighed by long-term benefits 
STECF • Concern is raised over “unpredictable behaviour” that may result from a discard ban, its 
enforceability without observers and the impact on post discard mortality. 
 
 
EN 70   EN Field of Action No. 8: Minimize wast e and discards from shark catches in 
accordance with article 7.2.2(g) of the Co de of Conduct for Responsible Fisheries 
requiring the retention of sharks from which fins are removed and encourage the 
use of dead sharks.  
Sector Some specific comments and concerns 
Industry • Valid for non-EU fleets. But for EU sector there must be careful analysis of the 
implications of introducing an obligation to  land shark fins and carcasses at the same 
time, as it could have a negative impact on the marketing of sharks, whilst failing to make a positive impact on the goal of conservation 
• Balance in distribution between Community and RMFO, but measures flawed because 
1) different marketing channels and ports of landing for fins and meat, 2) for some species fin ratio needs to be increased 
• Economic/social impacts would be devastating for EU and developing country fleets, 
but Asia fleets would avoid enforcement 
• Environmental impacts limited because would result in discards of fins 
Recreational • Supportive but see no need for 5% 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
• Need research on minimizing bycatch 
NGO and 
others • 5% proposed is better than current 5% of total body weight but problematic for some 
species and governments moving away from  ratios, and still not warranted/justified 
• Support same port of landing for fins and carcasses until finning completely prohibited 
• Urge the Commission to eliminate the derogation that allows shark fins to be removed 
on board vessels and thereby ensure that all sharks are landed with  their fins attached. 
Commission should facilitate the rapid development of pilot programmes to study and document the practical execution of a fins-attached rule in EU waters. 
• Appropriate to act, but need more measures at MS level 
• Negative impacts minimal, positive impacts will be significant 
STECF • Recommends that finning should be eradicated without exception. 
• Agrees that the current 5% ratio be reviewed  and supports the proposal to oblige vessels 
to land carcases and fins in the same port in order to improve the quality of landing statistics. 
 
EN 71   EN Field of Action No. 9: Identify and provi de special attention in particular to 
vulnerable or threatened shark stocks.  
Sector Some specific comments and concerns 
Industry • Appropriateness of Community action would depend on approach 
• Could be conflict of jurisdiction and hence not properly distributed 
• Major economic/social impacts because there wo uld be a lack of action and enforcement 
from RMFOs on Asian fleets 
Recreational • Supportive but could exempt recreational fishers 
Advisory • Need to measures to be carefully tailored to  reflect difference in species, and different 
dependencies on shark by commercial and recreational interests 
• Need for measures to be adequately res earched and agreed, and subject to impact 
assessment and objective specification, so as to ensure applicability 
NGO and 
others • Roughly one-third of European shark populations are considered by IUCN (World 
Conservation Union) to be threatened with extinction. 
• Commission should clarify that TACs of zer o and/or prohibited status are possible 
options under this field and that measures to protect these species are not limited to 
bycatch reduction programmes. 
• Need to clarify that ‘season’ refers to seas onal closures, not open seasons on threatened 
species 
• Recovery plans and implementation of scie ntific advice for threatened spurdog and 
porbeagle sharks to be identified in the CPOA as priority actions. 
• May need emergency measures and some year-round closures 
• Appropriate to act, but need distribution of  measures at MS level, & also suggest 
international measures should include promotion of complementary protective measures 
for threatened sharks by not only RFMOs but  also various wildlife treaties, including 
CMS & CITES. 
• Short term costs will be outweighed by long-term benefits 
STECF • STECF agrees that the proposed bycatch redu ction programmes are desirable but should 
be applied regardless of whether a TAC has been set. 
• Would consider convening a meeting to expedite providing definitions for each of the 
IUCN Red List threatened cat egories and their criteria. 
 
EN 72   EN APPENDIX II 
Option B: Fields of Action, measures and im plementation mechanisms  subject to the IA 
Field of Action Basic Measures Implementation mechanisms and options 
1.1 Increase investment in shark data collection 
at landing sites and by processing and marketing industries. Increase the requirements of the DCR to  specify shark landings by species.  
Use of Control regulation Mandatory 
1.2 Establish systems to provide verification of 
catch information by species and by fishery. As above. Focus should be on strengt hening implementation of existing 
control regulations 
Mandatory 
Hard : 100% observer coverage for high priority pelagic fisheries28 that catch 
more than 10% shark bycatch immediately. 
Mandatory  1.3 At an initial phase , mandate full coverage 
on fishing vessels by independent on-board observers for vessels >24 m and with recent by-
catches figures of more than 10- 15% (depending 
on the particular fishery) of sharks over the total catch. At a later stage , once the basic information 
on the fisheries has been obtained, full coverage could be replaced by a part ial coverage, at a level 
ensuring representative coverage. Soft
: 40% observer coverage for high priority pelagic fisheries that catch 
more than 10% shark bycatch by 2013. 
Mandatory 1. Facilitate 
improved identification and reporting of 
species-specific 
catch, landings and market data
27 EC level 
1.4 For other fishing vessels taking sharks as a 
by-catch, mandate sampling scheme for representative coverage of fishing operations by 
independent, on-board observers. Hard
: 10% observer coverage of all dist ant water fleets not covered by 
Measure 1.3 immediately and pilot-based observer scheme (e.g. c. 100 
observers) by 2013 on high priority shallow-water fisheries in the NE 
Atlantic. Refine over time with bette r landings data from Measure 1.1 and 
1.2. 
Mandatory  
                                                 
27 Fields of Action 1 & 2 merged 
28 See  
 
EN 73   EN Field of Action Basic Measures Implementation mechanisms and options 
Soft: 10% observer coverage of all di stant water fleets not covered by 
Measure 1.3 by 2013 and pilot-based observer scheme (e.g. c. 25 observers) 
by 2013 on high priority shallow-water fisheries in the NE Atlantic. Refine over time with better landings data  from Measure 1.1 and 1.2.  
Mandatory 
1.5 Ensure that all landings and trade of shark 
fins, meat and oil are recorded separately by commodity and to the species level. Adapt Reg. 1921/2006 on landings to presentation of shark commodities by 
species. 
Mandatory 
1.6 Promote the facilitation of improved 
species-specific catch data and monitoring of shark 
catches by fishery. Promote adoption of regulatory measures for shark catches reporting (see 
Measure 2.6) through binding measures29  
Mandatory 
1.7 Improve, in cooperation with FAO and 
relevant fisheries management bodies, the 
monitoring and reporting of catch, bycatch, 
discards, market and international trade data, at the species level where possible. Financial support to FAO, and contri bution to Working Groups and RFMO 
meetings.  
Optional 
1.8 To organise through FAO and regional 
fishing management organizations where 
appropriate, workshops on RPOA as called for in the IPOA–Sharks, by mid-2009 in order to report to the 15th Meeting of the CITES Conference of Parties. Contribution to Working Groups and RFMO meetings to assist NPOA 
development. Consider technical a nd financial assistance through FPAs. 
NPOA outputs  
Optional RFMO 
level 
1.9 Promote the identification and reporting of 
species-specific biological and trade data. RFMO alter reporting requirements a ccordingly through recommendations 
Optional 
                                                 
29 Note resolutions binding, recommendations do not require obligatory action on the part of contracting parties. 
 
EN 74   EN Field of Action Basic Measures Implementation mechanisms and options 
Hard : 100% observer coverage for high priority pelagic fisheries30 that catch 
more than 10% shark bycatch immediately.  
Mandatory  1.10 Full coverage on fishing vessels by 
independent on-board obser vers for vessels over 24 
m fishing in the high seas and with recent by-catches figures of more than 10% to 15% 
(depending on the particular fishery) of sharks of 
the total catch and the introduction of sampling schemes for representative coverage of other fishing vessels taking sharks as a by-catch by independent, on-board scientific observers. Soft
: 40% observer coverage for high priority pelagic fisheries that catch 
more than 10% shark bycatch by 2013.  
Mandatory  
Member 
State 
level 1.11 Monitor recreational catches and 
distinguish between the fishing mortality exerted 
by recreational and commercial fishing. Mandatory reporting of recreational seafishing catches of elasmobranchs  
Studies into mortality following release in both recreational and commercial 
fisheries  
Optional 
 
Field of Action Basic Measures Implementation mechanisms and options 
2.1 Enhance programs to facilitate data 
collection, monitoring and stock assessment on a 
species-specific level. Seek specific scientific advice based on MoU with JRC and STEFC 
through specific requests 
Optional 
2.2 To conduct regular assessment in order to 
identify threats to shark populations and to determine 
the fishing mortality by stocks and, if possible, partitioned by fishery
32. Seek specific scientific advice based on MoU with JRC and STEFC 
through specific requests 
Optional 
2.3 Identification of space-time boxes in areas 
where juveniles or spawners are abundant. 2. Conduct research and 
compile the necessary information to assess threats to 
shark populations 
and protect critical habitats, and implement EC level 
2.4 Study biology and ecology of sharks. Promote specific research programmes through the 7th Framework 
Programme (2007-2013). 
Seek scientific advice based on MoU with JRC and STEFC through 
                                                 
30 See 
 
EN 75   EN Field of Action Basic Measures Implementation mechanisms and options 
2.5 Develop prototypes, monitor experiments 
and propose measures for improving size selectivity and for reducing unwanted by-catch and discarding of no commercial species specific requests. 
Link to Measure 4.8 Optional 
2.6 Foster enhanced programs to facilitate data 
collection, monitoring and stock assessment on a 
species-specific level. Promote adoption of regulatory measures for shark catches reporting 
(see Measure 1.6) plus additional stock assessment work commissioned 
Optional RFMO 
level 
2.7 Foster implementation of internationally 
coordinated studies on straddling and/or shared 
stocks. Contribution to Working Groups and RFMO meetings. Finance provided 
to studies.  
Optional sustainable and 
rational harvesting strategies 
31 
Member 
State 
level 2.8 Develop national expertise Promote uptake of  courses, facilitate exch ange and mobility of 
researchers through funding available under FP7 
Optional 
 
3.1 Facilitate stakeholder awareness and 
consultation regarding shark management and best 
practices to reduce unwanted by-catch through RAC programs. Solicit inclusion of shark management issues on agenda of RACs  
Optional 3. Improve 
stakeholder 
awareness and 
consultation 
processes EC level 
3.2 Direct Member States to allow public access 
to relevant fishing permit information on sharks. Establish internet-based resources e ither on Europa website or via 
independent provider, but respecting issues of individual vessel / owner 
confidentiality  
Optional 
                                                                                                                                                                                                                                                        
31 Fields of Action 3 & 4 merged 
32 Includes measure for vulnerable or threaten ed species from origin al Field of Action 7 
 
EN 76   EN Field of Action Basic Measures Implementation mechanisms and options 
RFMO 
level 3.3 Foster stakeholder awareness and 
consultation regarding shark management and best practices to reduce unwanted by-catch through programs promoted by RFMO and international 
fishermen associations. Develop and disseminate  a code of conduct 
(or equivalent) for tuna and 
swordfish-directed fisheries to reduce bycatch and improve post-discard 
survival. 
Optional 
Member 
State 
level 3.4 Launch educational programs aimed 
specifically at educating fishermen and the public 
about shark and ray conservation programs and restrictions. Promote specific programmes with fi nancial support of EFF or through 
NGOs  
Optional  
 
Field of Action Basic Measures Implementation mechanisms and options 
4.1 Limitation or prohibition of fishing activities in 
areas that are considered sensitive to endangered stocks. New regulation. Link to Measure 2.3 
Mandatory EC level 
4.2 Stronger limitation of fishing effort by relevant 
fisheries. As for Measure 4.1 (new effort regulation)  
Mandatory 
RFMO 
level 4.3 Foster programmes and analysis to adjust fishing 
effort at international level. Active contribution to Working Gr oups and RFMO meetings to 
develop resolutions to limit shark -related effort. Similar to Measure 
3.3 
Mandatory 4. Adjust 
fishing effort 
and catches to the available resources
33 
Both EC 
and 
RFMO 4.4 Establish catch limits by stocks in conformity with 
the advice provided by ICES and by the relevant RFMOs. Hard : Immediate imposition of TACs and other management 
measures as recommended by ICES and by the relevant RFMOs 
Mandatory 
                                                 
33 Fields of Action 6 and 7 merged 
 
EN 77   EN Field of Action Basic Measures Implementation mechanisms and options 
Soft: Imposition of TACs and other management measures as 
recommended by ICES and by the relevant RFMOs, to be phased in by 2013 
Mandatory  
4.5 Prohibit all shark discards and require that all 
catches (including by-catches) are landed. Unwanted by-catches of sharks that have a chance to survive must be released back into the water. Provide derogations for species with  high post-discard survivability 
e.g. some ray species (i.e. link to Measure 1.10) 
Propose discard ban at RFMO level.  Provide derogations for species 
with high post-discard survivability e.g. blue shark 
Mandatory 
4.6 Increase size and species selectivity in order to 
reduce discards of undersize and unwanted by-catch. Develop joint research programmes that would test different gear 
options.Possible maximum size limits to conserve large breeding 
females. 
Mandatory (after 2010) 
4.7 Establish bycatch reduction programs for shark 
species considered Critically Endangered or Endangered by 
IUCN, where a zero TAC or prohibited status is not in 
force for these species. Dedicated working groups on shark fisheries that would analyse data 
available and make management r ecommendations to the Plenary. 
Voluntary . 
4.8 Establishment of space-time boxes in areas where 
juveniles or spawners are abundant, esp. For vulnerable or 
threatened species. Link to Measure 2.3.  
Voluntary  levels 
4.9 Within the framework of the ongoing evaluation of 
the Common Market Organisation in fishery and 
aquaculture products, the Commission will examine the 
possible impact of market mechanisms on conservation measures, including for shark species. Funds for studies (FP7), and EFF funding towards the certification 
e.g. MSC or other responsible fish ing scheme, of ‘well managed’ and 
sustainable fisheries where sh ark bycatch is an issue. 
Voluntary 
 
EN 78   EN  
Field of Action Basic Measures Implementation mechanisms and options 
5.1 To ban finning practices as the general rule. Any 
exception to this general rule will have to be fully justified on solid and objec tive grounds and documented 
prior to the issuing by the Member State of the special 
permit. Member States should not issue special permits 
to vessels not having fulfilled this condition. Provide sufficient level of justification for derogations. 
Mandatory  
5.2 To review the 5% rule by requiring that in no 
case shall the weight of the fins exceed 5% of the 
dressed  (gutted and beheaded) carcass weight of the 
shark catch. However, Member States having set up and implemented data collection programmes proving that 
this percentage could be increased in certain cases, 
could do so up to a percentage corresponding to 5% of the live weight of the shark catch. Have this issue included in the Terms of Reference of the scientific 
working groups, and then revise Regulation No. 1185/2003. 
Mandatory 5. Minimize 
wastes and discards from sharks Both EC 
and RFMO levels 
5.3 For vessels of Member States having been 
exempted from the obligation of landing of sharks with 
fins attached, introduce the obligation to land shark fins and carcases at the same time in the same port. Amendment of Reg. 1185/2003. To date 5 German, 198 Spanish and 
20 UK vessels have obtained this derogation.  
Mandatory  
 
EN 79   EN APPENDIX III 
ADMINISTRATIVE AND MANAGEMENT COSTS 
As Option A  relates to the status quo , no net change to administrative costs is anticipated. 
For Option B  a three-phase process was undertak en in line with the guidance. 
Option C  was then assessed to determine any differences  in administration cost s compared with those 
estimated for option B. 
1. ADMINISTRATION COSTS OF OPTION B 
Phase 1 Preparatory Analysis 
Those incurring administration costs as  a result of the measures (the target groups) are identified as DG 
MARE, Regional Fisheries Manageme nt Organization (RFMO) secretar iats, Regional Advisory Council 
(RAC) secretariats and Member Stat e fishery departments. In the priv ate sector target groups identified 
are owners of over 10m vessels a nd fish merchants/wholesalers. 
The following assessment has been made in relation to  identification of inform ation obligations, required 
actions and target groups for the proposed fields of action:  
Field of Action 1: Facilitate improved identifi cation and reporting of species-specific catch, 
landings and market data 
The proposed measure requiring catch and commodity  reporting to species level has a recurrent 
administrative cost for vessel owners, merchants a nd Member State fishery departments due to the 
required adjustment of existing regular reporti ng practices. Monthly reporting by vessel owners and 
merchants is assumed, with amendments to the a nnual submission of the DCR for member state fishery 
departments.  
The main costs for observer programmes such as  observer wages, deployment, support structure, 
training etc. are included in the main Impact Assessment and not within  this assessment of 
administration costs. 
Observer programmes result in additional administrative costs to fishery departments due to additional 
data collection and reporting from on board inspecti on, but not to fishing vessels as it is the observer 
rather than vessel owners re quired to report this data. 
Co-ordination with FAO and RFMOs primarily result s in administrative costs for RFMO secretariats 
through incorporating additional meetings, workshops and agenda items, along with additional financial 
management with EC support for these activities. 
The reporting of recreational elasmo branch catches will result in a dditional regulatory costs from the 
collation and reporting of that da ta. The significant costs associat ed with producing such data are 
included in the main Impact Assessment. 
Field of Action 2: Conduct research a nd compile the necessary information 
 
EN 80   EN The main administrative costs relate to those incurred by DG MARE in es tablishing and managing 
additional information requests on elasmobranchs incl uding the development of research programmes. 
RFMOs will incur additional administrative cost s through commissioning new research and stock 
assessments for elasmobranch fisheries. 
Member state fishery departments will incur admini stration costs through efforts to develop national 
expertise. 
Field of Action 3: Improve  stakeholder awareness and consultation processes 
Regional Advisory Councils (RACs) will incur addi tional administrative costs through expanding their 
current scope of works to more explicitly include el asmobranch issues, specifically in their reporting to 
the EC. 
DG MARE will incur additional costs through the design of information material and RFMOs will incur 
some cost associated with dissemination of material  to and subsequent consu ltation with stakeholders. 
Member states should incur no additional administra tive costs associated with  proposed measures under 
this field of action as required actions would be supported thr ough EFF project funding. 
Field of Action 4 - Adjust fishing effo rt and catches to the available resources 
Administration costs are primarily associated with one off costs to ensure familiarization with the 
proposed new regulation. These would be in curred by DG MARE and RFMO secretariats. 
The development of research programmes and de dicated working groups would result in recurring 
additional meeting and reporting requ irements for RFMO secretariats. 
Field of Action 5 - Minimize wa stes and discards from sharks 
In relation to banning finning practices and the landing of  shark carcases at the same time as shark parts, 
fishing vessel owners and member state fishery departments will incur additional administration costs in the application for derogation or ex emption. The precise details of such  as measure would determine the 
extent of likely applications for exemptions and their frequency (i.e. one- off or annual licences).  
One-off costs would be incurred by all member stat e fishery departments associated with informing 
vessels of the new regulations and by vessel operators familiarizing themselves with the new regulations. 
In relation to step 3 of the administration cost assessm ent process, the regulatory origin is identified as 
being 100% from the EU. 
1.1. Phase 2: Data capture and standardization 
This section examines the incremental administrative costs that would be incurr ed as a result from new 
legislation being promulgated directly  as a result of the CPOA. These administrative costs are defined as 
“the costs incurred by enterprises, the voluntary sector, pub lic authorities and citi zens in meeting legal 
obligations to provide information on  their action or production, either to  public authoritie s or to private 
parties” (EC Impact Assessment Guidelines, Sept 2006 update). Implementation costs – be they 
management or research costs – are considered separately. 
The following data was used as the basis for calculations: 
 
EN 81   EN Hourly tariff  
Eurostat data on EU 27 labour cost s (excluding apprentices) per employ ee per hour were collated using 
the following categories to disti nguish costs for target groups:  
Labour costs for the private sector (fishing vessel owners and merchants) we re based on category G51 
(wholesale trade and commission trade). It was assume d that fishing vessel reporting associated with 
larger vessels would be undertaken by vessel agen ts or owner/operators a nd therefore the service 
category was more appropriate than the lower wage levels recorded fo r those engaged in fishing, which 
includes the inshore/ artisanal sectors. 
Labour costs for the public sector (member state fi shery departments, RFMO secretariats and RAC 
secretariats) were based on categ ory L (public administration) 
Labour costs for DG MARE were based on category L (public administration) for Belgium. Labour costs data were from 2004. To bring these up to  date an annual inflation rate of 2.3% was applied 
based on the Harmonised Indices of Consumer Prices (HICPs) for EU27. 
A 25% overhead figure was applied across all groups to derive the following hourly tariffs: private 
sector: €29.23/hour; public sect or €26.51/hour; DG MARE €45.17/hour. 
Time 
The number of hours spent on a specific action is estim ated based on expert assessment. For initial 
recording catches to species leve l an additional 0.5 hours is assume d for the catching sector and 0.25 
hours for merchants for more extensiv e recording of shark and ray species . This reporting is assumed to 
simply be an extension to catch reporting on a per landing basis for the catch ing sector and a monthly 
basis for the merchanting sector. 
More significant time costs are assumed for memb er state fishery departments however this would 
amount to additional collation and reporting for the annual submission of the DCR.  
Significant one-off administration cost s are assumed for RFMO secretar iats in setting up meetings and 
adopting resulting changes in reporting procedures. Recurrent annual costs for member states are 
identified for the reporting of recreational elasm obranchs, which is not a current requirement.  
The administration costs associated with the esta blishment and reporting of new working groups are 
assumed to be 2 weeks initial set- up plus 3 days preparation and 3 days reporting for 2 working groups 
per year. 
Equipment costs 
No additional equipment costs are expected  as a result of the proposed measures. 
Frequency of Actions 
As proposed in the guidelines, one-off costs are distinguished from annual costs by ‘ 1’ being in italics in 
the reporting sheet, Table  below. 
 
EN 82   EN Private sector reporting for the me rchanting sector was assumed to be  on a monthly basis, while for the 
catching sector this was assumed to be on a per landi ng basis. Frequency of landings (44) was estimated 
based on an average 5 day trip  length over 220 working days. 
The additional administration costs for Member State fishery departments associated with inspections 
relate to daily reporting for the number of vessels requiring observe r coverage (247) and the average 
number of working days (220). For the observer programme associated with a sample of vessels 
operating in other distant wate r fleets, an estimate of 500 observers has been made. 
Number of entities 
The number of >10m vessels was derived fr om data within the EC Fleet Register 
(http://ec.europa.eu/fi sheries/fleet/index.cfm ) for all gear types (21,196)  excluding those with no 
potential for elasmobranch catch such as pots, traps, dr edges, purse seines, etc. (5,227) to give a total of 
15,969. 
The number of fish merchant ente rprises in EU27 (43,000) was derived from Eurostat data (NACE) for 
the number of enterprises under the category 'Wholesale of other food  including fish, crustaceans and 
molluscs' for 2005. 
The number of RFMO secretariats (13) relates to the marine RFMO s where EU vessels may operate, 
namely: APFC, CCAMLR, CCSBT, CECAF, GFCM, IATTC, ICCAT, NEAFC, NAFO, SEAFO, SWIOFC, WECAFC, and WCPFC. 
There are currently seven RACs, each of relevan ce to the proposed measures : Baltic, Mediterranean, 
North Sea, NW Waters, SW Waters, Pelagic Stocks and Distant Waters. 
The number of fishing vessels seek ing derogation from proposed regul ations is based on the number of 
vessels currently receiving derogation (223) and the di fferent member state departments associated with 
those vessels (3). 
 
EN 83   EN 1.2. Phase 3: Calculation and reporting 
Table 15: Summary administrati on costs per field of action an d target group (Option B) 
Field 
of 
Action Target group Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total no. 
of  
actions Total  
cost % of 
total 
cost 
>10m fishing vessel owners € 15  44 15 969  702 636  €10 269 025 55%
fish merchants and traders 7 €  12 43 000  516 000  €3 770 670 20%
M.S. fishery departments €2 558  458  936  164 826  €4 463 661 24%
RFMO secretariats  €822 3  39 39  €10 684 0%FOA 1 
Sub-total €3 402  517 59 944 1 383 501  €18 514 040 99%
DG MARE €2 936 4  4 4  €2 936 0.0%
RFMO secretariats  €265 1  13 13  €3 446 0.0%
M.S. fishery departments  € 530 1  27 27  €14 315 0.1%FOA 2 
Sub-total € 3 731 6  44 44  €20 698 0.1%
RAC secretariats  € 265 1  7 7   €1 856 0.0%
DG MARE € 6 776 1  1 1   €6 776 0.0%
RFMO secretariats € 1 988 1  13 13   €25 847 0.1%FOA 3 
Sub-total € 9 029 3  21 21   €34 478 0.2%
DG MARE  € 28 796 4  4 4   €28 796 0.2%
RFMO secretariats € 7 595 5  65 65   €98 736 0.5% FOA 4 
Sub-total € 36 391 9  69 69   €127 532 0.7%
M.S. fishery departments € 1 683 3  57 57   €39 089 0.2%
fishing vessel owners  € 205 2  446 446   €45 628 0.2% FOA 5 
Sub-total € 1 888 5  503 503   €84 717 0.5%
Total for all fields of action   €54,441  540 60 581 1 384 138  €18 781 465 100%
 
 
EN 84   EN Table 16: Report sheet for administrative costs associ ated with Shark management measures - Option B 
Community Plan of Action for the Co nservation and Management of Sharks Tariff
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
No. FOA Orig. 
Art. Type of 
obligation Description of 
required action(s) Target group i e i e           Int EU N
at Reg 
1 1.1   Submission of 
(recurring) 
reports Adjusting existing 
data >10m fishing vessel 
owners 29   0.50  14.6 44.00 15 969 702 636 10 269 
025   100%     
2 1.1   Submission of 
(recurring) 
reports Adjusting existing 
data fish merchants and 
traders 29   0.25  7.3 12.00 43 000 516 000 3 770 670   100%     
3 1,1   Submission of 
(recurring) 
reports Adjusting existing 
data MS fishery departments 
27   5.00  132.6 1.00 27 27 3 579   100%     
4 1.3   Inspection Filling forms and 
tables MS fishery departments 27   1.00  26.5 220.00 247 54 340 1 440 553   100%     
5 1.3   Inspection Producing new data MS fishery departments 27   10.0  265.1 1.00 27 27 7 158   100%     
6 1.3   Inspection Submitting the 
information  MS fishery departments 27   0.50  13.3 1.00 27 27 358   100%     
7 1.4   Inspection Filling forms and 
tables MS fishery departments 27   1.00  26.5 220.00 500 110 000 2 916 100   100%     
8 1.4   Inspection Producing new data MS fishery departments 27   10.0  265.1 1.00 27 27 7 158   100%     
 
EN 85   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
9 1.5   Submission of 
(recurring) 
reports Adjusting existing 
data MS fishery departments 
27   5.00  132.6 12.00 27 324 42 946   100%     
10 1.6   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation RFMO secretariats 
27   3.00  79.5 1.00 13 13 1 034   100%     
11 1.7   Application for 
subsidy or grant Filling forms and 
tables RFMO secretariats 27   4.00  106.0 1.00 13 13 1 379   100%     
12 1.8   Other Holding meetings RFMO secretariats 27   24.0  636.2 1.00 13 13 8 271   100%     
13 1.9   Submission of 
(recurring) 
reports Adjusting existing 
data MS fishery departments 
27   24.0  636.2 1.00 27 27 17 178   100%     
14 1.10   Submission of 
(recurring) 
reports Producing new data MS fishery departments 
27   40.0  1 060.4 1.00 27 27 28 631   100%     
15 2.1   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation DG MARE 
45   10.0  451.7 1.00 1 1 452   100%     
16 2.2   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation DG MARE 
45   10.0  451.7 1.00 1 1 452   100%     
17 2.3   Non-labelling 
information for Designing 
information material DG MARE 45   40.0  1 806.8 1.00 1 1 1 807   100%     
 
EN 86   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
third parties 
18 2.6   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation RFMO secretariats 
27   10.0  265.1 1.00 13 13 3 446   100%     
19 2.7   Application for 
subsidy or grant Filling forms and 
tables DG MARE 45   5.0  225.9 1.00 1 1 226   100%     
20 2.8   Other Designing 
information material MS fishery departments 27   20.0  530.2 1.00 27 27 14 315   100%     
21 3.1   Submission of 
(recurring) 
reports Adjusting existing 
data RAC secretariats 
27   10.0  265.1 1.00 7 7 1 856   100%     
22 3.2   Non-labelling 
information for 
third parties Designing 
information material DG MARE 
45   150.
0  6 775.5 1.00 1 1 6 776   100%     
23 3.3   Non-labelling 
information for 
third parties Copying 
(reproducing 
reports, labels or 
leaflets) RFMO secretariats 
27   75.0  1 988.3 1.00 13 13 25 847   100%     
24 4.1   Notification of 
(specific) 
activities Designing 
information material 
(leaflet conception) DG MARE 
45   225.
0  10 163.3 1.00 1 1 10 163   100%     
25 4.2   Notification of 
(specific) Designing 
information material DG MARE 45   225.
0  10 163.3 1.00 1 1 10 163   100%     
 
EN 87   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
activities (leaflet conception) 
26 4.3   Non-labelling 
information for 
third parties Designing 
information material RFMO secretariats 
27   75.0  1 988.3 1.00 13 13 25 847   100%     
27 4.4   Notification of 
(specific) 
activities Designing 
information material DG MARE 
45   75.0  3 387.8 1.00 1 1 3 388   100%     
28 4.6   Notification of 
(specific) 
activities Designing 
information material DG MARE 
45   112.
5  5 081.6 1.00 1 1 5 082         
29 4.6   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation RFMO secretariats 
27   37.5  994.1 1.00 13 13 12 924   100%     
30 4.7   Submission of 
(recurring) 
reports Holding meetings RFMO secretariats 
27   120.
0  3 181.2 1.00 13 13 41 356   100%     
31 4.7   Submission of 
(recurring) 
reports Producing new data RFMO secretariats 
27   48.0  1 272.5 1.00 13 13 16 542   100%     
32 4.7   Submission of 
(recurring) 
reports Submitting the 
information  RFMO secretariats 
27   6.0  159.1 1.00 13 13 2 068   100%     
33 5.1   Application for 
general Filling forms and MS fishery departments 27   37.5  994.1 1.00 27 27 26 841   100%     
 
EN 88   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq  
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
authorisation or 
exemption tables 
34 5.1   Application for 
general 
authorisation or 
exemption Filling forms and 
tables fishing vessel owners 
29   5.0  146.2 1.00 223 223 32 591   100%     
35 5.2   Application for 
general 
authorisation or 
exemption Filling forms and 
tables MS fishery departments 
27   10.0  265.1 1.00 3 3 795   100%     
36 5.3   Notification of 
(specific) 
activities Designing 
information material MS fishery departments 
27   16.0  424.2 1.00 27 27 11 452   100%     
37 5.3   Notification of 
(specific) 
activities Familiarising with 
the information 
obligation fishing vessel owners 
29   2.0  58.5 1.00 223 223 13 037   100%     
                   
          Total administrative costs (€) 18 781 465     
 
EN 89   EN 2. ADMINISTRATION COSTS OF OPTION C 
Option C was assessed in relation to the individu al elements of the Option B assessment with 
the same assumptions adopted (see 1). In admi nistrative terms the ban on high and medium 
priority fisheries should result in similar costs for familiarisation with the new regulation, but would save administration costs associated with: 
Observer schemes for high and medium priority fisheries  
(estimated to amount to €1 448 069) 
Applications for exemptions from finning and landing requirements 
(estimated to amount to €84 717) It is assumed that all other measures di scussed under option B, including the observer 
schemes associated with fisheries where shark is taken as by-catch, are retained. 
The above saving results in administration cost s estimated to total €17 248 679 for Option C, 
as illustrated in Table 17 overleaf.  
 
EN 90   EN Table 17: Report sheet for administrative costs associ ated with Shark management measures - Option C 
Community Plan of Action for the Co nservation and Management of Sharks Tariff 
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq 
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
No. FOA Orig. 
Art. Type of obligation Description of 
required action(s) Target group i e i e           Int EU Nat Reg 
1 1.1   Submission of 
(recurring) reports Adjusting existing 
data >10m fishing vessel 
owners 29   0.50  14.6 44.00 15 969 702 636 10 269 025   100%     
2 1.1   Submission of 
(recurring) reports Adjusting existing 
data fish merchants and 
traders 29   0.25  7.3 12.00 43 000 516 000 3 770 670   100%     
3 1,1   Submission of 
(recurring) reports Adjusting existing 
data member state fishery 
departments 27   5.00  132.6 1.00 27 27 3 579   100%     
4 1.4   Inspection Filling forms and 
tables member state fishery 
departments 27   1.00  26.5 220.0
0 500 110 000 2 916 100   100%     
5 1.4   Inspection Producing new data member state fishery 
departments 27   10.0  265.1 1.00 27 27 7 158   100%     
6 1.5   Submission of 
(recurring) reports Adjusting existing 
data member state fishery 
departments 27   5.00  132.6 12.00 27 324 42 946   100%     
7 1.6   Notification of 
(specific) activities Familiarising with 
the information 
obligation RFMO secretariats 
27   3.00  79.5 1.00 13 13 1 034   100%     
8 1.7   Application for 
subsidy or grant Filling forms and 
tables RFMO secretariats 27   4.00  106.0 1.00 13 13 1 379   100%     
9 1.8   Other Holding meetings RF MO secretariats 27   24.0  636.2 1.00 13 13 8 271   100%     
10 1.9   Submission of Adjusting existing member state fishery 27   24.0  636.2 1.00 27 27 17 178   100%     
 
EN 91   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff 
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq 
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
(recurring) reports data departments 
11 1.10   Submission of 
(recurring) reports Producing new data member state fishery 
departments 27   40.0  1 060.4 1.00 27 27 28 631   100%     
12 2.1   Notification of 
(specific) activities Familiarising with 
the information 
obligation DG MARE 
45   10.0  451.7 1.00 1 1 452   100%     
13 2.2   Notification of 
(specific) activities Familiarising with 
the information 
obligation DG MARE 
45   10.0  451.7 1.00 1 1 452   100%     
14 2.3   Non-labelling 
information for 
third parties Designing 
information material DG MARE 
45   40.0  1 806.8 1.00 1 1 1 807   100%     
15 2.6   Notification of 
(specific) activities Familiarising with 
the information 
obligation RFMO secretariats 
27   10.0  265.1 1.00 13 13 3 446   100%     
16 2.7   Application for 
subsidy or grant Filling forms and 
tables DG MARE 45   5.00  225.9 1.00 1 1 226   100%     
17 2.8   Other Designing 
information material member state fishery 
departments 27   20.0  530.2 1.00 27 27 14 315   100%     
18 3.1   Submission of 
(recurring) reports Adjusting existing 
data RAC secretariats 27   10.0  265.1 1.00 7 7 1 856   100%     
19 3.2   Non-labelling 
information for 
third parties Designing 
information material DG MARE 
45   150.  6 775.5 1.00 1 1 6 776   100%     
 
EN 92   EN Community Plan of Action for the Co nservation and Management of Sharks Tariff 
(€ per 
hour)  
Time 
(hour) Price 
(per 
action) Freq 
(per 
year) No.  
of  
entities Total 
no. 
of  
actions Total  
cost Regulatory 
origin 
(%) 
20 3.3   Non-labelling 
information for 
third parties Copying RFMO secretariats 
27   75.0  1 988.3 1.00 13 13 25 847   100%     
21 4.1   Notification of 
(specific) activities Designing 
information material DG MARE 45   225  10 163.3 1.00 1 1 10 163   100%     
22 4.2   Notification of 
(specific) activities Designing 
information material DG MARE 45   225  10 163.3 1.00 1 1 10 163   100%     
23 4.3   Non-labelling 
information for 
third parties Designing 
information material RFMO secretariats 
27   75.0  1 988.3 1.00 13 13 25 847   100%     
24 4.4   Notification of 
(specific) activities Designing 
information material DG MARE 45   75.0  3 387.8 1.00 1 1 3 388   100%     
25 4.6   Notification of 
(specific) activities Designing 
information material DG MARE 45   112.
5  5 081.6 1.00 1 1 5 082         
26 4.6   Notification of 
(specific) activities Familiarising with 
the information 
obligation RFMO secretariats 
27   37.5
0  994.1 1.00 13 13 12 924   100%     
27 4.7   Submission of 
(recurring) reports Holding meetings RFMO secretariats 27   120  3 181.2 1.00 13 13 41 356   100%     
28 4.7   Submission of 
(recurring) reports Producing new data RFMO secretariats 27   48.0  1 272.5 1.00 13 13 16 542   100%     
29 4.7   Submission of 
(recurring) reports Submitting the 
information RFMO secretariats 27   6.0  159.1 1.00 13 13 2 068   100%     
          Total administrative costs (€) 17 248 679     
 
EN 93   EN 3. MANAGEMENT COSTS (OPTION B and  C) 
Only under measures 1.3 and 1.4 will have direct and significant cost im plications. According 
to Article 11 of Council Regulation (EC) No 199/2008 of 25 February 2008 concerning the 
establishment of a Community framework for the collection, management and use of data in 
the fisheries sector and support for scientific  advice regarding the Common Fisheries Policy34 
and Article 16 of Council Regulation (E C) No 861/2006 of 22 May 2006 establishing 
Community financial measures for the implemen tation of the common fisheries policy and in 
the area of the Law of the Sea35, 50% of these costs will be covered by the EC and 50% by the 
Member States. 
In assessing the magnitude of observer costs on EU vessels (measures 1.3 and 1.4), for the 
purpose of this assessment an average of  Euro 125/day is estimated per observer36. For 
measure 1.3, there is a ‘hard’ and a ‘soft’ option. For the hard option, measure 1.3 would 
involve 100% observer coverage on  all longline vessels in the Ce ntral and Southern Atlantic, 
Indian Ocean and Pacific (except the 33 sma ll French longliners in the Indian Ocean)37. This 
coverage would start immediatel y and continue thereafter for a period until full coverage 
could be replaced by partial coverage. 247 vessels would thus be involved in the short- to 
medium term. Taking an average of 300 days of fishing a year, total observer costs are 
estimated at Euro 9.26 million per year. In the longer term a partial 40% observer coverage 
(typically considered sufficient in many fisher ies) would reduce annual costs to Euro 3.7 
million. For the soft option of measure 1.3, annua l costs would be Euro 3.7 million from 2013 
onwards. These two levels of observer coverage is also expected to be extended to the non-EU vessels through RFMO actions in Measure 1.10, although this does not have any direct 
costs to the EU. 
For measure 1.4 hard and soft options are also envisaged. Both would involve the pelagic and 
pole and line vessels not covered under m easure 1.3 along with th e 33 smaller French 
longliners in the Indian Ocean and all distan t water purse seiners. Total vessel numbers 
involved would thus be 102. The hard option w ould involve immediate costs of Euro 382 500 
per year for the EU fleets in the central and S outhern Atlantic, Indian Ocean and the Pacific. 
The hard option for measure 1.4 also envisages a pilot observer scheme  of 100 observers in 
the NE Atlantic to collect data on shallow wate r high risk fisheries. These observers would be 
deployed on a rotating basis betw een high risk fisheries. This would involve immediate costs 
of Euro 4.56 million per year. The soft often wo uld result in similar costs of Euro 382 500 per 
year for the pelagic shark fleet, but only beginning in 2013. While costs for a reduced 
observer scheme of 25 observers for the NE A tlantic from 2013 would re sult in annual costs 
thereafter of Euro 1.14 million. 
It is also important to remember that, whil e not costed as part of this CPOA, observer 
coverage on EU longline vessels should be comp leted by similar levels of observer coverage 
on vessels from third countries  e.g. Asian vessels. Given that th e EC might decide to act with 
regards to its distant water fleet (to demonstr ate best practice) with no guarantee that other 
                                                
 
34 O.J. L 060, 05/03/2008 
35 O.J. L 160, 14/06/2006 
36 Based on a range of observer costs in other fisheries 
37 Shark bycatches in purse seine fisheries are genera lly thought to be well below 10%, except for some 
specific temporal/spatial fishing on FADs 
 
EN 94   EN countries will do the same given that vessels fro m third countries are not directly responsible 
to the EC, the likelihood  and magnitude  of observer costs being incurred by third countries 
and RFMOs (Measure 1.10) are less certain and not quantifiable. 
Table 18: Management cost s for measures 1.3 and 1.4 
1.3 Measure  1.4 M easure  TOTAL 
Options 
Year 1 Year 5 Year 1 Year 5 Year 1 Year 5 
HARD 9.26 M€ 
247 > 24 m 
vessels; 
300 days; 125€/day. 3.7 M€ 
40% 4.56 M€ 
102 LD 
vessels; 
100 SW 
observers 1.52 M€ 
Only SW 
vessels 13.82 M€ 5.22 M€ 
SOFT 2.94 M€ 
30% 3.7 M€ 
40% 1.14 M€ 
25 observers 1.52 M€ 
(0.382 M€ 
LD vessels + 1.14 M€ 25 observers) 4.08 M€  5.22 M€ 
LD: Long distance fleet. 
SW: Shallow water fleet. 
 
EN 95   EN Table 19: Summary of management (imp lementation) and administrative costs 
OPTION B ANNUAL COSTS OPTION C ANNUAL COSTS 
Hard option Soft option Hard option Soft option Field of Action 
Year 1 Year 5 Year 1 Year 5 Year 1 Year 5 Year 1 Year 5 
Management 13 820 000 5 220 000 4 082 500 5 222 500 13 820 000 5 220 000 4 082 500 5 222 500 
Administration 18 514 040 18 486 178 18 514 040 18 486 178 17 065 971 17 038 109 17 065 971 17 038 109 FoA 1 
 
 Sub-total 32 334 040 23 706 178 22 596 540 23 708 678 30 885 971 22 258 109 21 148 471 22 260 609 
Management  na  na  na  na   na  na  na  na  
Administration 20 698 14 541 20 698 14 541 20 698 14 541 20 698 14 541 FoA 2 
 
 Sub-total 20 698 14 541 20 698 14 541 20 698 14 541 20 698 14 541 
Management  na  na  na  na   na  na  na  na  
Administration 34 478 1 856 34 478 1 856 34 478 1 856 34 478 1 856 FoA 3   
Sub-total 34 478 1 856 34 478 1 856 34 478 1 856 34 478 1 856 
Management  na  na  na  na   na  na  na  na  
Administration 127 532 63 353 127 532 63 353 127 532 63 353 127 532 63 353 FoA 4   
Sub-total 127 532 63 353 127 532 63 353 127 532 63 353 127 532 63 353 
Management  na  na  na  na   na  na  na  na  
Administration 84 717 795 84 717 795 - - - - FoA 5   
Sub-total 84 717 795 84 717 795 - - - -  
Management 13,820,000 5 220 000 13 820 000 5 220 000 13 820 000 5 220 000 13 820 000 5 220 000 
Administration 18,514,040 18 486 178 18 514 040 18 486 178 17 065 971 17 038 109 17 065 971 17 038 109 
Total 32,601,465 23 786 723 22 863 965 23 789 223 31 068 679 22 337 859 21 331 179 22 340 359 
 
EN 96   EN 4. MANAGEMENT AND ADMINISTRATION COST ESTIMATES  
Table 19 overleaf summarises the various cost s that can be been quantified for each option 
under each Field of Action. The table collates th e management and monitoring costs, and the 
administrative costs above. Option B results in marginally higher overall costs compared to Option C with the hard options both totalling ju st over €30m in the first year, decreasing to 
annual costs of approximately €23m in Year 5.  
For the hard option, the reduction in costs over time is evident due to two factors: 
Monitoring and management is proposed to change by 2013 including reduced levels of 
observer coverage which re sults in cost savings. 
Some administration costs are one-of f costs only incurred in year 1 
The soft option with a lower proportional obs erver coverage from Year 1 amounts to 
approximately €22m. This increases by Year 5 as the existing lower level of observer 
coverage continues (in line with the hard op tion) plus additional obs erver programmes come 
on stream for other fisheries by 2013. 
Management and monitoring costs and administra tive costs are predominan tly associated with 
Field of Action 1 as this relates to increas ed reporting and observer schemes, while other 
fields of action relate to research, awareness raising and co-ordination. It is not possible to 
quantify the direct economic costs of these as  they are dependent upon allocated budgets, but 
some increase in administrative costs resulting from meetings and reporting requirements are 
assumed. 
Management and monitoring cost s are the same for both Opti on B and Option C, while the 
stricter but simpler Option C does create so me small savings in administrative costs.  
 
EN 97   EN APPENDIX IV 
Markets and trade in sharks and shark products 
According to Globefish (2008), the largest exporters of shar ks are Taiwan, China, Japan, 
Spain, Panama and the United Arab Emirates (s ee figure below). Products include fins, meat, 
and other shark products such as liver oil, skin s and cartilage. Spain represents approximately 
11% of total world trade of sharks products in  value over the last 6 years (2000-2005). At the 
same time, Spain and Italy are significant im porters of shark species (15 000 t and 10 000 t 
respectively) suggesting that there is a domesti c market that is insufficiently supplied by 
national fleets. The development of markets for shark products is demonstrated by catches 
from the deepwater Atlantic fishery; initially only the sharks’ livers were landed, but a limited 
market for fresh shark developed for fish caught in  the last days of a trip. Gradually the meat 
of the fish has become the main product and since 1999 deepwater sharks have been landed for human consumption of the meat, initially in to the French market and more recently as 
frozen siki ‘backs’ into the Spanish market. 
Exports (in Million USD) of sharks by countries. 
050 000100 000150 000200 000250 000300 000
2000 2001 2002 2003 2004 2005Other
Japan
UA E
Panama
China
Spain
Taiw anTonnes
 
The demand for and the value and volume of  shark products in trade have increased 
considerably over the past 15 years and continue  to rise. However, membership of China to 
WTO appears to have decreased the volume traded. Estimates of the total number of sharks 
traded annually worldwide range from 26–73 m illion/year with an overall median of 38 
million/year. The shark biomass represented by the global fin trade is estimated to lie between 
1.21 and 2.29 million t/year with a median of 1.70 million t/year. This is some three to four 
times higher than indicated by FAO’s landings data, and does not include sharks that are 
discarded at sea or that are wholly processed and utilised domestically (for example those 
taken by the Japanese and Taiwan ese fleets). (Clarke, S.C. 2008).   
According to the Marine Resource Economic s (Clark 2007), although Hong Kong has long 
been the world’s largest shark fin trading center,  handling shark fin trad ing activity has shifted 
from centralized channels in Hong Kong to a diversified Mainland China network. Today, 
shark fin is available in most, if not all, ma jor cities in China, and with population growth 
between 2000 and 2005 of 9.5 million persons per year, a large number of consumers are 
 
EN 98   EN sampling shark fin for the first time. While traders insist that the shark fin market is driven by 
demand in Mainland China, due to statistical problems involving combining frozen shark fins 
(a significant portion of the mark et) with frozen shark meat in the Mainland customs data, it is 
not possible to accurately track trade levels in recent years. However, it appears that the trend 
in the Mainland fin trade is dow nward since 2000 (Clarke 2008). Af ter increasing at a rate of 
6% per annum, shark fin imports to Hong Kong have also declined si nce 2000. This trend is 
matched by an observed decline in global sh ark catches since 2000 based on FAO capture 
production data. It is not known whether these trends may be caused by over-exploitation of 
sharks, a reduction in fishing effort due to highe r fuel prices, or a combination of these or 
other factors. Nevertheless, the downturn in catches in combinati on with similar trends in the 
fin trade, despite indications that demand fo r fins is growing, is worrying. Given what now 
appears to be a strong linkage between shark cat ches and the volume of the fin trade, several 
leading shark scientists have cal led for urgent consideration of effective fisheries management 
measures for sharks (Dulvy et al. 2008).  
 
EN 99   EN APPENDIX V 
Acronyms Used 
ACP African, Caribbean, and Pacific 
CAP Community Action Plan 
CCAMLR Commission for the Conservation of Antarctic Marine Living Resources 
CCR Joint Research Centre (JRC) CCSBT Commission for the Conservation of Southern Bluefin Tuna CECAF Fishery Committee for the Eastern Central Atlantic  CFCA Community Fisheries Control Agency 
CFP Common Fisheries Policy 
CNRO Centre National de Recherches Océanographiques COFREMAR Joint Technical Commission for the Argentina / Uruguay Maritime Front COREP Regional Fisheries Committee for the Gulf of Guinea CP Contracting Party CPOA Community Plan of Action 
CPPS Comisión Permanente del Pacífico Sur 
CpUE Catch per Unit Effort CRO Centre de Recherches Océanologiques  CSRP Sub Regional Fisheries Commission (West Africa) DCR Data Collection Regulations 
DELASS Development of Elasmobranch Assessments 
DNAP Direcção Nacional de Administração Pesqueira DPS Demersal and pelagic species DWF Distant Water Fleet EC European Commission EEZ Exclusive Economic Zone 
EP European Parliament  
EU European Union 
 
EN 100   EN FA Fisheries Agreement 
FAD Fish Aggregating Device 
FAO Food and Agriculture Organisation 
FFA Forum Fisheries Agency FIAS Fisheries Information and Analysis System  FOC Flag of Convenience FP7 Framework Program (7
th of) 
FPA Fisheries Partnership Agreement 
GDP Gross Domestic Product 
GFCM General Fisheries Commission for the Mediterranean GRT Gross Registered Tons GVA Gross Value Added HACCP Hazard Analysis and Critical Control Point 
HMS Highly Migratory Species 
IATTC Inter-American Tropical Tuna Commission IBSFC International Baltic Sea Fishery Commission  IBTS International Bottom Trawl Survey  ICCAT International Commission for the Conservation of Atlantic Tunas  
ICES International Council for the Seas 
ICRAM Italian Centre for A pplied Marine Research  
IEO Instituto Español de Oceanografía  IFC International Fisheries Commission IIP Instituto de Investigação Pesqueira IOC International Oceanographic Commission 
IOTC Indian Ocean Tuna Commission 
IPIMAR Instituto de Inves tigação das Pescas e do Mar 
IPOA International Plan of Action IRD Institut de Recherche pour le Développement 
 
EN 101   EN ISTAM Improve Scientific and Techni cal Advices for fisheries Management 
IUCN International Union for the Conservation of Nature 
IUU Illegal, Unregulated and Unreported 
JRC Joint Research Centre LME Large Marine Ecosystem LOSC Law of the Sea Convention MCS Monitoring, Control and Surveillance MEU Marine Environment Unit  
MPA Marine Protected Area 
MS Member State (of the EU) MSY Maximum Sustainable Yield NAFO Northwest Atlantic Fisheries Organisation NEAFC Northeast Atlantic Fisheries Commission 
NOAA National Oceanographic and Atmospheric Administration 
NTZ No Take Zone RAC Regional Activity Centre RFB Regional Fisheries Body RFMO Regional Fisheries Management Organisation 
RIP Regional Indicative Programme 
RPOA Regional Plan of Action RTD Research and Technological Development RTTP Regional Tagging Programme  SBT Southern Bluefin Tuna SEAFDEC Southeast Asian Fisheries Development Center 
SEAFO South-East Atlantic Fisheries Organisation 
SPC Secretariat of the Pacific Community SPRFMO South Pacific Regional Fisheries Management Organisation SRFC Sub-regional Fisheries Commission 
 
EN 102   EN STA Scientific and Technical Advice 
STECF Scientific, Technical and Economic Committee for Fisheries  
SWIOFC South-West Indian Ocean Fisheries Commission 
TAC Total Allowable Catch ToR Terms of Reference UN United Nations  UNCLOS United Nations Convention on the Law of the Sea UNEP United Nations Environment Programme 
VMS Vessel Monitoring System 
WCPFC Western and Central Pacific Fisheries Commission WECAFC Western Central Atlantic Fishery Commission WGEF Working Group on Elasmobranch Fisheries (ICES) WIO Western Indian Ocean 
WSSD World Summit on Sustainable Development 
 
EN 103   EN APPENDIX VI  
References 
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