COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Strategic guidelines for a more sustainable and competitive EU aquaculture for the period 2021 to 2030
Date: 2021-05-12
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: EU strategy, adaptation to climate change, animal welfare, aquaculture, common fisheries policy, competitiveness, conservation of resources, job creation, sustainable development, sustainable fisheries

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.5.2021  SWD(2021) 102 final  COMMISSION STAFF WORKING DOCUMENT    STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  Strategic guidelines for a more sustainable and competitive EU aquaculture for the period 2021 to 2030 {COM(2021) 236 final}  
 
 
 Introduction 

The  Common  Fisheries  Policy  sets  as  one  of  its  objectives  the  promotion  of  aquaculture 
production  in  the  EU1  in  a  way  that  is  sustainable  from  the  environmental,  economic  and 
social  point  of  view.  In  this  regard,  it  calls  on  the  Commission  to  develop  non-binding 
strategic  guidelines  for  the  sustainable  growth  of  the  sector  and  on  EU  Member  States  to 
adopt  Multiannual  National  Strategic  Plans  on  aquaculture  taking  into  consideration  the 
specificities of their respective sector. The Commission adopted in 2013 the Communication 
"Strategic Guidelines for the sustainable development of EU aquaculture”2 which have served 
as a basis for the drafting and  adoption by  EU  Member States of their  multiannual  national 
strategic plans.  

An  interim  evaluation  of  the  Open  Method  of  Coordination  for  sustainable  development  of 
EU aquaculture3 – the voluntary method of coordination among Member States facilitated by 
the Commission – launched in October 2017, concluded, inter alia, on the need to revise the 
Strategic Guidelines in order to take into consideration recent developments in the sector.  

The process of revising these Guidelines was carried out in a consultative manner, including 
all  relevant  stakeholders  using  appropriate  consultation  methods.  In  addition  to  regular 
meetings with some targeted stakeholders (EU Member States experts on aquaculture and the 
Aquaculture Advisory Council), DG MARE has gathered and examined the feedback to the 
roadmap of this initiative and undertaken a more detailed public consultation. 

This  synopsis  report provides information  on the overall  consultation  work, summarises the 
main results of the consultation activities related to the review of the Strategic Guidelines, and 
gives an analysis of these results.  

1.  Consultation strategy 

1.1.Objectives of the consultation 

The  consultation  of  different  stakeholders  aimed  at  gathering  views  on  the  challenges  and 
opportunities  of  the  EU  aquaculture  sector.  More  particularly,  the  consultation  had  the 
objective of identifying the main elements for unlocking the potential of this sector to grow 
and meet the demand for high quality, nutritious food produced in a way that is respectful of 
the  environment,  and  provide  employment  and  economic  development  to  coastal  and  rural 
communities.  Gathering  opinions  and  calling  for  experience  sharing  from  all  interested 
stakeholders  had  the  objective  of  allowing  the  Commission  to  produce  new  informed 
Strategic  Guidelines  that  reflect  a  shared  vision  of  the  way  ahead  for  a  sustainable  and 

1  EU  Regulation  No  1380/2013  of  the  European  Parliament  and  of  the  Council  of  11  December  2013  on  the 

Common Fisheries Policy (CFP Regulation). 

2  Communication  "Strategic  Guidelines  for  the  sustainable  development  of  EU  aquaculture”,  COM(2013)  229 

final. 

3  Interim  evaluation  of  the  Open  Method  of  Coordination  for  sustainable  development  of  EU  aquaculture, 

SWD(2020) 6 final. 

1 

 
 
 
 
                                                           
competitive aquaculture sector in the EU. With the adoption of the European Green Deal, the 
consultation also looked at identifying ways for the EU aquaculture sector to contribute to this 
broader  policy  strategy.  Furthermore,  the  consultation  also  took  into  consideration  lessons 
learnt from the impact of the Covid-19 epidemic on the EU aquaculture sector.  

The consultation took as a basis the evaluation of progress on the areas identified under the 
2013  Strategic  Guidelines  for  EU  Aquaculture.  It  also  took  into  consideration  the  new 
developments  affecting  the  sector,  in  particular  with  regard  to  its  environmental,  social  and 
economic sustainability (including in terms of research and innovation), as well as emerging 
issues for which there is increasing public attention (e.g. environmental performance, animal 
welfare).  

1.2.Mapping of stakeholders 

Consultations were aimed at all stakeholders with an interest in EU aquaculture. This included 
in  the  first  place  EU  Member  States  and  the  Aquaculture  Advisory  Council  (AAC), 
representing the EU aquaculture industry and other interest groups such as non-governmental 
organisations (NGOs). The Commission also involved other EU institutions, in particular the 
European Parliament and the Committee of Regions. In addition, the Commission sought the 
reach out to an even broader range of stakeholders with the launch of a public consultation on 
the initiative. Stakeholders targeted included aquaculture producers, related sectors (e.g. feed, 
processing), civil  society organizations active on various aspects  relevant  to  the aquaculture 
sector,  from  environmental  performance  and  animal  welfare  to  social  rights,  as  well  as 
scientists and researchers. In addition, it also targeted the individual citizen who considers that 
aquaculture production touches in any way its personal sphere, including as a consumer. 

1.3.Methods and tools of the consultations 

The successive meetings and discussions with stakeholders made it possible to define in detail 
the content of a discussion paper initially proposed by the Commission for the consultations 
on the new Strategic Guidelines. This document has served as a basis for the work on the new 
Strategic Guidelines.  

The Commission held detailed discussions on the future Guidelines with aquaculture experts 
in EU Member States on the basis of a discussion paper in the context of the technical expert 
seminars held under the Open Method of Coordination for EU aquaculture policy established 
in the Common Fisheries Policy Regulation. The update of the Strategic Guidelines was the 
topic  of  discussion  during  technical  seminars  held  on  17-18  October  2019,  on  20-21  April 
2020 and on 29-30 June 2020.  

In this context, EU Member States had also the opportunity to provide written contributions. 
Contributions made by EU Member States experts (either orally or in writing) were examined 
by the team in the Commission responsible for the review of the Guidelines and shared with 

2 

 
 
 
 
other  associated  services  in  the  Commission.  Each  contribution  was  examined  taking  into 
consideration the nature, purpose and policy objectives pursued by the review of the Strategic 
Guidelines,  the  feasibility  of  what  was  proposed,  and  their  value  in  achieving  an  overall 
balanced  proposal  considering  the  double  objective  of  supporting  the  sustainability  and  the 
competitiveness of the EU aquaculture sector.  

Finally, those contributions were further discussed with Member States experts in the context 
of the technical seminars on aquaculture, and the Commission explained how it had taken into 
consideration the contributions received.  

The Commission also presented on two occasions the progress on the work on the review of 
the Strategic Guidelines to the Fisheries Working Group of the Council (November 2019 and 
September  2020)  and  made  also  a  presentation  to  the  EMFF  Member  States  Expert  Group 
(December 2020).  

The  same  type  of  approach  was  used  in  the  consultations  with  the  Aquaculture  Advisory 
Council  (AAC).  The  Commission  held  detailed  discussions  with  the  AAC  on  several 
occasions,  the  latest  in  June  2020,  and  four  Opinions  from  this  consultative  body  were 
received  (dating  October  2019,  January  2020,  May  2020  and  June  2020).  The  Commission 
also  organised  joint  sessions  with  EU  Member  States  experts  and  members  of  the  AAC  to 
discuss the work on the new Guidelines.  

The  Commission  examined  the  four  Opinions  issued  by  this  Advisory  Council,  as  well  as 
other contributions made during discussions on the work on the review of the Guidelines with 
its members. The Commission explained how it had taken them into consideration. Moreover, 
the Commission reacted directly to comments provided during the presentation of the work on 
the Guidelines on the occasion of different meetings with other institutions or expert groups 
(as  mentioned  above),  and  took  into  consideration  those  comments  that  were  considered 
relevant in its further work on the review of the Guidelines.  

The  Commission  presented  its  approach  to  the  review  of  the  Guidelines  to  the  European 
Parliament’s Committee on Fisheries (PECH Committee) on two occasions (in September 
2019 and during a public hearing in February 2020). 

DG MARE representatives also participated in several workshops and conferences organised 
by different entities and bodies, including the Committee of the Regions (November 2019), 
where  the  main  ideas  underpinning  the  work  towards  the  Guidelines  were  presented  and 
where interesting contributions from stakeholders were collected.  

The roadmap of this initiative was published on the European Commission webpage “Have 
Your  Say”,  and  feedback  to  this  initiative  was  open  from  24  March  to  21  April  2020. 
Seventeen replies were received and can be consulted in the above-mentioned webpage. 

Finally, a public consultation on the basis of a questionnaire linked to the overall initiative 
took place from 14 July to 27 October 2020 and ran for an exceptional period of 15 weeks. 
The 110 contributions can be found on the dedicated webpage. 

3 

 
 
 
The  analysis  of  the  replies  to  the  questionnaire  of  the  public  consultation  allowed  the 
Commission to verify whether the approach of the work on the revision of the Guidelines was 
the correct one. In addition to the replies to the questionnaire, participants were also given the 
possibility  to  provide  written  contributions  on  some  aspects.  These  contributions  were  also 
examined taking into consideration their relevance for the work on the Guidelines. 

2.  Consultation activities 

-  A  roadmap  was  published  on  23  March  2020  and  a  feedback  exercise  was  held  from  24 

March to 21 April 2020.  

-  Three consultations on the basis of a  discussion paper were held with EU Member States’ 
experts  on  aquaculture,  in  the  framework  of  the  Aquaculture  Technical  Seminar  on  17-18 
October 2019, 20-21 April 2020 and 29-30 June 2020. 

-  The  Aquaculture  Advisory  Council  was  invited  to  join  the  three  Aquaculture  Technical 
Seminars  mentioned  above  and  was  also  consulted  on  the  basis  of  a  discussion  paper  in 
parallel  of these meetings. The AAC has provided three  general  recommendations4  on the 
future EU Aquaculture Strategic Guidelines as well a specific recommendation on shellfish5. 

-  Fisheries Working Party of the Council: two presentations on progress on the work on the 

new Guidelines were given on 19 November 2019 and on 16 September 2020. 

-  Member States Expert Group (MSEG) on Integrated Maritime Policy: a presentation on the 

state of play of the work on the Guidelines was made on 5 December 2019. 

-  A  presentation  on  the  state  of  play  of  the  work  on  the  Guidelines  with  the  Integrated 
Maritime Policy (IMP) Friends of Presidency of the Council was given on 17 June 2020. 

-  A  presentation  on  the  state  of  play  of  the  work  on  the  Guidelines  was  organised  with  the 

European Maritime and Fisheries Fund (EMFF) Expert Group on 19 November 2020. 

-  Several information points on progress of the work on the new Guidelines have been tabled 
during  PECH  Committee  meetings  on  24  September  2019,  19  February  2020  (public 
hearing on sustainable EU aquaculture), and 10 June 2020 (short update in the context of the 
presentation on Farm to Fork).  

-  A  presentation  on  the  Commission  views  on  the  review  of  the  Guidelines  was  made  at  a 
workshop organised by the Committee of Regions on freshwater fisheries and aquaculture 
on 13 November 2019. 

-  A public consultation was held from 14 July to 27 October 2020.  

Consultation 
Activity 

Feedback 
the 
to 

Information 
session with 

Exchange 
of  views 

Presentation 
the 
to 

Presentation 
the 
to 

Public 
Consultation 

4  Recommendation  on  the  Future  Strategic  Guidelines  for  the  sustainable  development  of  EU  aquaculture 
(30/10/2019), Second Recommendation on the Future Strategic Guidelines for the Sustainable Development 
of  EU  Aquaculture  (23/01/2020),  and  Third  Recommendation  on  the  Future  Strategic  Guidelines  for  the 
Sustainable Development of EU Aquaculture (20/05/2020). 

5  Strategic  Guidelines  IV  –  AAC  recommendation  on  the  development  of  shellfish-specific  guidelines 

(26/06/2020). 

4 

 
 
 
 
                                                           
roadmap 

the 
Aquaculture 
Advisory 
Council 

with 
Member 
States 
Experts 

European 
Parliament 

Council 
Fisheries 
Working 
Party 

Indicative 
Planning 

24  March 
2020 – 21 
April 
2020 

October 
2019  

April 2020 

Targeted 
Stakeholders 
Citizens 
Industry 
Member  States 
Authorities 
EU Institutions 
Research 
bodies 
NGOs 

x 
x 
x 

x 

x 

x 

x 

3.  Results of the consultation activities 

June 2020  

June 2020 

July  2020  – 
October 
2020 

October 
2019 

April 
2020 

June 2020 

x 

x 

x 

x 

x 
x 
x 

x 
x 

x 

The analysis of the contributions and comments received during the consultation exercises has 
confirmed  the  need  to  review  the  Strategic  Guidelines  in  order  to  provide  a  vision  for  the 
sector  for  the  coming  years.  The  great  majority  of  stakeholders  agree  with  this  view,  with 
industry stakeholders sometimes putting more emphasis on the competitiveness aspects, while 
NGOs tend to focus on the sustainability angle.  

The  roadmap  of  the  initiative  aimed  to  inform  citizens  and  stakeholders  about  the 
Commission's work in order to allow them to provide feedback and to participate effectively 
in  the consultation  activities. Citizens and stakeholders were in  particular invited to  provide 
views on the Commission's understanding of the problem and possible solutions and to make 
available any relevant information that they could have. 

Seventeen  feedback  contributions  were  received  from  different  stakeholders.  All  these 
contributions  were  analysed  and  contributed  to  structure  and  feed  the  work  on  the  new 
Strategic Guidelines. For example, topics such as administrative hurdles, better information to 
consumers/citizen, feed efficiency, reduction of nutrient losses or concrete proposals on fish 
welfare were highlighted in the feedback to the roadmap and were included in the work on the 
new Strategic Guidelines. 

As for the public consultation, one hundred and ten responses have been received. Although 
participation in this public consultation was overall very balanced, the majority of the survey 
respondents  participated  on  behalf  of  a  business  organization  or  association  with  24  and  14 
respondents  respectively.  It  worth  noting  also  the  high  participation  of  NGO  with  21 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
respondents,  and  EU  citizens  with  17  respondents.  Moreover,  this  public  consultation  was 
very balanced in terms of the organization sizes of respondents and brought together 33% of 
micro (1 to 9 employees) organisations, 25% of large ones (250 and more), 13% of small and 
12% of medium-sized organisations.  

The main concerns identified by the respondents had already been addressed in the work on 
the  new  Strategic  Guidelines  (see  Figure  1),  resulting  from  the  consultations  within  the 
Commission,  with  EU  Member  States  experts  and  with  the  Aquaculture  Advisory  Council. 
For  instance,  the  consultations  confirmed  that  environmental  sustainability  is  a  key  topic  to 
address.  Improving  environmental  performance  has  been  identified  as  one  of  the  main 
objectives of the proposed Guidelines, and it is a consideration that should cut through most 
topics  addressed  in  them.  Indeed,  the  Guidelines  are  in  particular  aimed  at  ensuring  that 
aquaculture plays a role in the context of the European Green Deal and Farm to Fork Strategy 
and  should  include  guidelines  and  recommendations  for  future  action  in  terms  of 
“environmental  performance”.  The  future  Guidelines  will  also  have  as  a  key  objective  the 
strengthening of the competitiveness of the EU aquaculture sector. 

The results of the consultations also support the view that achieving these objectives requires 
a  comprehensive  approach  taking  into  consideration  multiple  aspects.  They  confirm  that 
issues such as access to space and water and administrative burden (areas already identified in 
the 2013 Guidelines) remain an obstacle for unlocking the potential of the sector, especially 
SMEs,  and  require  further  efforts.  They  stress  the  need  to  increase  the  environmental 
performance  of  the  sector  (including  by  further  mitigating  and  monitoring  its  impacts  and 
supporting  the  most  environmentally  friendly  forms  of  aquaculture).  They  also  confirm  the 
need  to  ensure  appropriate  adaptation  of  the  sector  to  climate  change  impacts.  Improving 
communication  on  EU  aquaculture  activities,  including  the  efforts  of  the  EU  aquaculture 
sector in terms of sustainability, is also considered an important issue to address, not only to 
provide  transparency  and  information  to  the  citizen/consumer,  but  also  to  ensure  a  level 
playing  field  for  EU  aquaculture  producers  in  the  EU  market.  Animal  health  has  been 
identified  as  an  important  challenge  for  the  industry  also.  Further  work  on  animal  welfare 
targeting the aquaculture sector is also widely supported.  

The work on the new Strategic Guidelines has considered the results of the consultation in the 
work on the new Strategic Guidelines and, in particular, has served to set an order of priority 
of actions and tools proposed. 

To illustrate what has been said, the 110 respondents of the public consultation were asked to 
rate the degree of importance of 16 specific areas in terms of importance for the development 
of EU aquaculture: going from 1, not important, to 5, very important. To have a method for 
analysing these results that is both realistic and inclusive, scores 4 and 5 are added together as 
indicating a high importance attributed to the subject. As such, Figure 1 (below) presents the 
rating by areas from the top most supported to the least ones. 

6 

 
 
 
F I G URE 1 .  A R EAS  C O NSI DERED A S  P R I ORI T I ES F O R T H E 
D E VEL OP MENT O F  E U  A Q U AC UL TURE  

E N V I R O N M E N T A L   S U S T A I N A B I L I T Y  

66 

33 

6 

3 
1 

2 

A N I M A L   H E A L T H  

I M P R O V E   T H E   P E R C E P T I O N   A N D   T H E  
I N F O R M A T I O N   O F   T H E   C O N S U M E R / C I T I Z E N  

A N I M A L   W E L F A R E  

53 

52 

51 

E N S U R E   S K I L L E D   W O R K F O R C E   A N D   T R A I N I N G  

29 

49 

E N S U R E   F A I R   M A R K E T   C O M P E T I T I O N  

A D A P T A T I O N   T O   C L I M A T E   C H A N G E  

B E T T E R   R E G U L A T I O N   F O R   T H E   A Q U A C U L T U R E  
S E C T O R  

S I M P L I F I C A T I O N   O F   A D M I N I S T R A T I V E  
P R O C E D U R E S  

A C C E S S   T O   S P A C E   A N D   W A T E R  

I M P R O V E   E U ' S   I N D U S T R Y   C O M P E T I T I V E N E S S  

I N T E G R A T I O N   O F   T H E   A Q U A C U L T U R E   S E C T O R  
I N   T H E   L O C A L   E C O N O M Y  

F I N A N C I N G  

W O R K I N G   C O N D I T I O N S  

D E V E L O P M E N T   O F   C O A S T A L   A R E A S  

41 

46 

47 

52 

48 

30 

33 

36 

13 

16 

41 

28 

36 

9 

7 

2 

3 

33 

32 

37 

28 

25 

14 

5 

3 

3 

15 

8 

2 
2 

26 

0 
1 

5 

20 

2 

4 

6 

26 

0 
4 

6 

18 

10 

7 

3 

20 

8 

14 

11 

5 

18 

13 

16 

10 

5 

35 

31 

23 

24 

26 

5 

12 

4 

9 

4 

7 

23 

9 

12 

7 

42 

6 

2 

6 

33 

14 

11 

8 

P R O M O T I O N   O F   G E N D E R   B A L A N C E  

11 

29 

30 

17 

17 

6 

5

4

3

2

1

No Answer

7 

 
 
 
F I G URE 2 .  B E S T  W AY S  T O  P RO VI DE B E T TER I NF ORMATI ON O N 
A Q U AC ULT URE P R O DU CTS A N D S E RVI CES T O  T H E 
C O NSUMER/ CI TI Z EN  

%
6
7

%
7
6

%
1
5

%
0
4

%
8
2

Non Governmental Organisations

Industry promotion campaigns

By retailers and Horeca

Public information campaigns

On the label of the product

Analysis of the Aquaculture Advisory Council (AAC) consultation activities.  

The Commission has worked closely with the AAC from the very beginning of the initiative, 
by attending AAC’s working groups, following-up on the on-going work on the Guidelines. 
In return, the AAC contributed to the Guidelines in various ways.  

In  October  2019  and  January  2020,  following  the  announcement  of  on-going  work  on  the 
update of the Strategic Guidelines and ahead of consultation work, the AAC adopted its two 
first Recommendations on the Guidelines. The first Recommendation focused on identifying 
three  priorities  and  invited  to  review  the  Guidelines  every  18  months,  in  order  to  ensure 
flexibility in adapting the priorities to challenges. The Commission has nevertheless explained 
that  18  months  might  not  be  a  sufficiently  long  period  to  see  the  results  from  the  actions 
proposed and has therefore suggested that an assessment every three years is more appropriate 
and efficient. Priorities issues identified by the AAC were the following: securing sustainable 
growth 
the 
competitiveness  of  EU  aquaculture  and  promoting  a  level  playing  field.  The  first 
the  second 
Recommendation  detailed 
Recommendation listed actions by involved partners (Member States, European Commission 
and AAC). The Commission has taken into consideration the AAC’s specific proposals in the 
work  on  the  discussion  paper,  which  served  as  a  basis  for  the  drafting  of  the  updated 
Guidelines.  

licensing  procedures  and  use  of  space,  enhancing 

these  priorities,  while 

through  optimising 

ideas  between 

the 

The  Commission  also  presented  the  work  on  the  Guidelines  and  the  discussion  paper  while 
attending all working groups of the AAC where dedicated agenda points were included. The 
Commission joined these meetings in June 2019, October 2019, June 2020 and October 2020. 

8 

 
 
 
 
 
 
 
 
Exchanges  of  views  with  AAC  members  were  thus  taken  into  consideration  and  helped  to 
frame the discussion paper on the Guidelines.  

The  AAC  members  were  invited  to  join  the  Member  States  Aquaculture  Experts  in  a  joint 
session dedicated to a draft outline of the Guidelines. AAC Chair and Vice-Chairs were also 
associated to all Member States aquaculture Experts seminars in 2019 and 2020.  

The  AAC  further  adopted  a  third  general  Recommendations  on  the  Guidelines  on  20  May 
2020,  welcoming  proposals  detailed  in  the  continuously  evolving  discussion  paper  and 
proposing  specific  inputs.  The  Working  Group  on  Shellfish  further  worked  on  a  fourth 
Recommendation,  namely  a  specific  Recommendation  on  the  development  of  Shellfish-
specific guidelines, adopted on 26 June 2020. 

The third general Recommendation, adapted to the evolution of the discussion paper, brought 
forward specific proposals, such as: 

- 
- 

- 

a pledge for fish welfare to be considered broadly in the Guidelines,  
importance  of  scientific  monitoring  of  environmental  services  and  of  environmental 
legislation implementation across Member States,  
support  to  an  EU-wide  communication  campaign  if  educational  on  sustainability 
issues, 

-  overall support to the idea of EU aquaculture sector being carbon neutral by 2050, 
- 

encouragement to widen the scope of indicators in terms of data and monitoring and of 
indicators on environmental performance. 

The  Commission  has  also  taken  into  consideration  these  proposals  in  the  work  on  the  new 
Strategic Guidelines.  

Finally, the fourth Recommendation, dedicated to Shellfish-specific guidelines brought up the 
following supports and proposals: increasing availability of space across Member States and 
ensuring appropriate water quality; the creation of a network of statistics specific to shellfish 
sector; a reorganisation of representative structures of the sector, particularly at transnational 
and EU level; the development of the traceability of shellfish products; ensuring the adequacy 
between  consumer  demand  in  the  EU  and  an  increased  EU  shellfish  production  (namely 
referring  to  a  better  knowledge  of  distribution  channels),  and  applied  research  and 
development efforts. Some of these recommendations could be applicable also to other parts 
of  the  EU  aquaculture  sector  and  were  incorporated  to  the  work  on  the  new  Strategic 
Guidelines. In addition, work on the Guidelines took into consideration issues that are specific 
to the shellfish sector as mentioned by the AAC. 

In  parallel,  the  AAC  and  its  members  participated  in  the  feedback  on  the  Roadmap  of  the 
initiative as well as to the Public Consultation (see above).  

9