COMMISSION STAFF WORKING DOCUMENT EVALUATION to the Protocol to the Sustainable Fisheries Partnership Agreement between the European Union, of the one part, and the Government of Greenland and the Government of the Kingdom of Denmark, of the other part Accompagnant le document Recommendation for a Council Decision authorising the opening of the negotiations on behalf of the European Union for the conclusion of an Implementing Protocol to the Sustainable Fisheries Partnership Agreement between the European Union, of the one part, and the Government of Greenland and the Government of the Kingdom of Denmark, of the other part
Date: 2024-05-13
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: Denmark, Greenland, catch area, fishing agreement, fishing rights, negotiation of an agreement (EU), protocol to an agreement, ratification of an agreement, sea fishing, sustainable fisheries

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.5.2024  SWD(2024) 128 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  to the Protocol to the Sustainable Fisheries Partnership Agreement between the European Union, of the one part, and the Government of Greenland and the Government of the Kingdom of Denmark, of the other part  Accompagnant le document  Recommendation for a Council Decision authorising the opening of the negotiations on behalf of the European Union for the conclusion of an Implementing Protocol to the Sustainable Fisheries Partnership Agreement between the European Union, of the one part, and the Government of Greenland and the Government of the Kingdom of Denmark, of the other part   {COM(2024) 199 final} - {SWD(2024) 129 final}  
 
 
Table of Contents 

1. 

INTRODUCTION ................................................................................................................................ 4 

1.1. 

1.2. 

1.3. 

Purpose of the evaluation ........................................................................................... 4 

Scope of the evaluation ............................................................................................... 4 

Methodology of the evaluation ................................................................................... 5 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ....................................... 7 

2.1 

Description of the intervention and its objectives ...................................................... 7 

2.1.1 

Sustainable Fisheries Partnership Agreements (SFPAs) .............................................. 7 

2.1.2 

Sustainable Fisheries Partnership Agreement between the EU and Greenland ........ 9 

2.2 

Point(s) of comparison .............................................................................................. 12 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ....................... 15 

Current state of play.................................................................................................................. 15 

Reporting obligations ................................................................................................................ 30 

4. 

EVALUATION FINDINGS ............................................................................................................... 36 

4.1 To what extent was the intervention successful and why? ................................................ 36 

4.2 How did the EU intervention make a difference and to whom? ........................................ 46 

4.3 Is the intervention still relevant? ........................................................................................ 50 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................................. 51 

5.1 Conclusions .......................................................................................................................... 51 

5.2 Lessons learned ................................................................................................................... 52 

6. 

EX-ANTE EVALUATION................................................................................................................. 53 

6.1 Problem analysis and needs assessment ............................................................................ 53 

6.2 EU added value .................................................................................................................... 55 

6.3 Policy and management objectives ..................................................................................... 55 

6.4 Policy options, including associated risks ............................................................................ 55 

6.4.1 Option A ........................................................................................................................... 56 

6.4.2 Option B ............................................................................................................................ 56 

6.5 Results and impacts ............................................................................................................. 57 

6.5.1 Option A ........................................................................................................................... 57 

6.5.2 Option B ............................................................................................................................ 58 

6.6 Preferred option .................................................................................................................. 59 

6.7 Risks  60 

6.8 Monitoring of a future implementing Protocol .................................................................. 61 

1 

 
 
ANNEX I:   PROCEDURAL INFORMATION ........................................................................................... 62 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................................... 63 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................................. 69 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................................... 75 

ANNEX V. SIMPLIFICATION AND BURDEN REDUCTION ................................................................ 78 

ANNEX VI. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................................ 80 

2 

 
 
 
 
 
 
Glossary 

Term or acronym 

Definition 

SFPAs 

EU 

CFP 

Sustainable Fisheries Partnership Agreements 

European Union 

Common Fisheries Policy 

IUU fishing 

Illegal, Unreported and Unregulated fishing. 

JSC 

JSM 

VMS 

ERS 

FMC 

RFMOs 

MCS 

EEZ 

NAFO 

NEAFC 

ICES 

FAO 

WB 

GNB 

Joint Scientific Committees  

Joint Scientific Meetings  

Vessel Monitoring System 

Electronic Reporting System  

Fisheries Monitoring Centre 

Regional Fisheries Management Organisations 

Monitoring, Control and Surveillance  

Exclusive Economic  Zone  

North Atlantic Fisheries Organisation 

North East Atlantic Fisheries Commission 

International Council for the Exploration of the Sea 

Food and Agriculture Organisation 

World Bank 

Gross National Benefit 

3 

 
 
 
1. 

INTRODUCTION 

1.1.  Purpose of the evaluation  

In the framework of the external dimension of the EU's Common Fishery Policy (CFP)1, 
implements  Sustainable  Fisheries  Partnership 
the  Commission  negotiates  and 
Agreements  (SFPAs)  with  third  countries.  The  SFPAs  create  a  legal,  environmental 
economic  and  social  governance  framework  for  fishing  activities  carried  out  by  Union 
fishing  vessels  in  third country waters.  In exchange,  the EU provides  a partner country 
with financial compensation for access to its waters and financial assistance to implement 
a national strategy for fisheries and blue economy. The EU contribution is complemented 
by fees payable by EU vessel owners. 

According  to  Article  3(1)(d)  and  (e)  of  the  Treaty  on  the  Functioning  of  the  European 
Union, the EU has exclusive powers on the conservation of marine biological resources 
under  the  CFP  and  the  common  commercial  policy.  The  European  Commission  is 
therefore responsible for the negotiation and implementation of the SFPAs.  

According  to  Article  31(10)  of  the  CFP  Basic  Regulation1,  the  European  Commission 
shall  arrange  for  independent  ex-ante  and  ex-post  evaluations  for  each  implementing 
protocol  to  a  SFPA,  before  it  submits  to  the  Council  of  the  EU  a  recommendation  to 
authorise the opening of negotiations for a successor protocol.  

This obligation is complemented by Article 34 of the Financial Regulation2, according to 
which Commission Services have to undertake both ex-ante and ex-post evaluations for 
all  programmes  and  activities  which  entail  significant  spending  and  –  as  stated  in  the 
Commission’s Better Regulation Guidelines3 - in the form of a staff working document 
(SWD). 

Importantly, under Article 31(5) of the CFP Basic Regulation1, Union vessels cannot fish 
if  there  is  no  protocol  implementing  an  SFPA  between  the  EU  and  a  third  country.  In 
order  for  Union  vessels  to  continue  fishing  under  an  SFPA  after  an  implementing 
protocol expires, a successor protocol must be negotiated.  

1.2. 

Scope of the evaluation  

This  SWD  makes  an  ex-ante  and  an  ex-post  evaluation  covering  the  application  of  the 
the 
current 

implementing  Protocol  (hereinafter, 

implementing  Protocol)  of 

the 

1  Regulation  (EU)  1380/2013  of  11  December  2013  on  the  Common  Fisheries  Policy  (OJ  L354, 

28.12.2013, p. 22) 

2 Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on 
the  financial  rules  applicable  to  the  general  budget  of  the  Union,  amending  Regulations  (EU) 
No 1296/2013,  (EU)  No 1301/2013,  (EU)  No 1303/2013,  (EU)  No 1304/2013,  (EU)  No 1309/2013, 
(EU)  No 1316/2013,  (EU)  No 223/2014,  (EU)  No 283/2014,  and  Decision  No 541/2014/EU  and 
repealing Regulation (EU, Euratom) No 966/2012 (OJ L 193, 30.7.2018, p. 1). 

3 SWD(2021) 305 final of  3 November 2021 - Better regulation: guidelines and toolbox (europa.eu) 

4 

 
 
 
Sustainable Fisheries Partnership Agreement  concluded between the EU and Greenland 
(hereinafter, the Agreement). These evaluations are primarily informed by an evaluation 
study conducted by an independent consultant4. 

The  ex-post  evaluation  covers  most  of  the  period  of  application  of  the  current 
implementing  Protocol  of  the  Agreement,  starting  from  the  April  2021  to  December 
2023.  It  provides  an  overall  assessment  of  the  implementing  Protocol,  drawing 
conclusions  in  terms  of  its  effectiveness,  efficiency,  relevance,  coherence,  acceptance, 
EU added value of the intervention. The detailed evaluation questions corresponding to 
these evaluation criteria can be found in Annex III and further addressed in section 4.  

The  ex-ante  evaluation  analyses  the  relevant  objectives  for  the  Agreement  and  its 
implementing protocol, considering the current and future needs for this intervention.  It 
considers the lessons learned from previous implementing protocols and the results of the 
ex-post evaluation of the current implementing Protocol.  

Finally, the ex-ante evaluation considers and draws conclusions on the possible impacts 
of the following three policy scenarios: 

•  A renegotiation of the current implementing Protocol for the Agreement;  

•  No negotiation of a successor implementing protocol for the Agreement.  

•  A negotiation of an improved implementing protocol for the Agreement;  

1.3.  Methodology of the evaluation  

The  results  of  this  SWD  are  mainly  informed  by  an  evaluation  study  conducted  by  an 
independent  consultant.  This  evaluation  study  took  place  from  January  to  March  2024 
under the guidance of an inter-service group (ISG) established by the following services 
of  the  European  Commission:  EEAS,  DG  MARE,  DG  SANTE,  DG  TRADE,  DG 
INTPA, DG ENV and SG and within the framework of the terms of reference of specific 
the  framework  contract  MARE/2021/OP/0001.  The 
contract  number  9  under 
methodology  of  this  evaluation  study  consisted  of  three  main  components:  analysis  of 
available information, consultations, and preparation of an evaluation report. 

On  the  analysis  of  available  information,  DG  MARE  provided  all  relevant  internal 
documents  and  databases  to  the  independent  consultant.  Other  external  documentation 
was  also  used,  such  as  regulatory  texts  and  reports  from  relevant  scientific  working 
groups.  

On  the  consultation,  the  independent  consultant  consulted  stakeholders  in  the  EU  and 
Greenland.  EU  stakeholders  were  consulted  in  February  2024.  Greenland  stakeholders 
were  consulted  online  as  the  consultant  did  not  conduct  a  field  mission  due  to  time 
constraints  and  weather  conditions  at  that  time  of  the  year  in  Greenland.  Moreover,  a 

4 Evaluation pending publication. 

5 

 
 
‘call  for  evidence’  document  was  also  published  in  the  Commissions  Have  Your  Say 
Portal for feedback for the period of 11 January 2024 - 08 February 20245. The document 
attracted 3 feedbacks6. See more detailed information about the stakeholder consultations 
in Annex V. ‘Synopsis Report’.  

The evaluation study was submitted to the European Commission in 2024 and the overall 
level  and  quality  of  findings  gathered  is  robust.  Nevertheless,  the  following  general 
elements should be highlighted:  

•  This SWD, and the evaluation study on which it is based, considers all information 
available  as  of  December  2023.  It  does  not  consider  information  beyond  this  date 
because the evaluation must be finalized at least a year before the expiry date of the 
implementing  Protocol  to  obtain  a  mandate  for  negotiation  and  subsequently 
negotiate a successor protocol.  

•  Due to the tight deadline and weather conditions in Greenland at this time of the year, 
the  consultant  has  not  been  able  to  visit  Greenland  and  carry  out  an  evaluation 
mission on the ground. All relevant consultations have been carried out telematically. 
Despite this, the level of engagement of all stakeholders has resulted in a high-quality 
evaluation. 

Detailed information on the methodology, including how the supporting evaluation study 
was conducted can be found in Annex II.  

5 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14014-EU-Greenland-fisheries-
agreement-and-protocol-way-forward_en  
6 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14014-EU-Greenland-fisheries-
agreement-and-protocol-way-forward/feedback_en?p_id=32488597 

6 

 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1   Description of the intervention and its objectives 

2.1.1  Sustainable Fisheries Partnership Agreements (SFPAs) 

The  CFP  Basic  Regulation  covers  the  conservation  of  marine  biological  resources  and 
the  management  of  fisheries  and  fleets  exploiting  such  resources  within  Union  waters 
and  by  Union  fishing  vessels  outside  Union  waters.  The  first  fisheries  agreements 
between the EU and third countries date back to the late 1980s and are enshrined in the 
CFP.  In  accordance  with  UN  Sustainable  Development  Goal  14  (life  below  water),  the 
SFPAs should contribute towards resource conservation and environmental sustainability 
of  the  exploitation  of  living  marine  resources  of  a  coastal  partner  state.  The  SFPAs 
should  also  contribute  to  efficient  data  collection;  monitoring,  control  and  surveillance 
measures; and the respect for democratic principles and human rights.  

The SFPAs establish a legal, environmental economic and social governance framework 
for fishing activities carried out by Union fishing vessels in third country waters. Under 
the  framework  of  the  SFPAs,  Union  vessels  shall  only  catch  surplus  of  the  allowable 
catch,  as  referred  to  in  Article  62(2)  and  (3)  of  the  United  Nations  Convention  on  the 
Law of the Sea (UNCLOS)7. This surplus must be identified, in a clear and transparent 
manner, on the basis of the best available scientific advice. In addition, in order to ensure 
the  sustainable  exploitation  of  surpluses  of  marine  biological  resources,  the  EU  must 
endeavour to ensure that the SFPAs are mutually beneficial to the Union and to the third 
country concerned, including its local population and fishing industry. 

In  terms  of  financial  compensation,  the  EU  provides  a  partner  country  with  financial 
compensation  for  access  to  its  waters  and  financial  assistance  to  implement  a  national 
strategy  for  fisheries  and  the  blue  economy.  The  EU  contribution  is  complemented  by 
fees payable by EU vessel owners. 

Importantly,  SFPAs  are  exclusive  and  rendered  operational  only  through  their 
implementing  Protocols.  In  order  for  Union  vessels  to  continue  fishing  under  an  SFPA 
after  an  implementing  protocol  expires,  a  successor  protocol  must  be  negotiated 
(“exclusivity clause”).  

The implementation of an SFPA and its implementing protocol is monitored by a Joint 
Committee  composed  of  representatives  from  both  parties,  as  well  as  a  Joint  Scientific 
Committee  composed  of  scientists  from  both  parties,  though  in  the  case  of  the  SFPA 
between  the  EU  and  Greenland  such  Joint  Scientific  Committee  does  not  exist  as  the 
scientific  evaluation  of  the  stocks  is  conducted  in  the  framework  of  the  Northwest 

7 https://www.un.org/Depts/los/convention_agreements/convention_overview_convention.htm  

7 

 
 
 
 
 
Atlantic Fisheries Organisation (NAFO)8, the North East Atlantic Fisheries Commission 
(NEAFC)9 and the International Council for the Exploration of the Sea (ICES)10.  

In  July  2011,  the  Commission  adopted  a  Communication  on  the  external  dimension  of 
the  CFP11  and  proposed  several  actions  to  reform  FPAs.  The  Council  adopted 
Conclusions regarding the External Dimension of the CFP on 19 March 201212 and the 
European Parliament expressed its views in a report adopted in November 201213.  

General and specific objectives of Sustainable Fisheries Partnership Agreements 

The  overarching  objective  of  the  external  dimension  of  the  CFP  is  to  promote  high 
standards  in  terms  of  fisheries  management  at  the  international  and  regional  levels  as 
well as under bilateral agreements, with the aim to ensure a level playing field. General 
and specific objectives of SFPAs are the following: 

1)  To  contribute  towards  resource  conservation  and  environmental  sustainability 
through  rational  and  sustainable  exploitation of  living  marine  resources  of  the 
coastal state, in particular by: 

a.  directing fisheries exclusively at surplus resources and preventing the overfishing of 
stocks, on the basis of the best  scientific advice and  reinforced transparency on the 
global fishing efforts in third countries' waters;  

b.  following  the  same  principle  and  promoting  the  same  standards  for  fisheries 

management as applied in EU waters; 

c.  improving the scientific and technical evaluation of the fisheries concerned (notably 

by improving data collection and transparency on fishing efforts); and 

d.  ensuring compliance and combating IUU fishing. 
2)  To contribute to continuing the activity of the Union fleets and the employment 

linked to the fleets operating within SFPAs by: 

a.  seeking appropriate share of the surplus resources, fully commensurate with the EU 

fleets interests; 

b.  ensuring  that  the  level  of  fees  payable  by  Union  ship-owners  for  their  fishing 
activities  is  fair,  non-discriminatory  and  commensurate  to  the  benefits  provided 
through  the  access  conditions  while  avoiding  any  discriminatory  treatment  towards 
EU vessels and promoting a level playing field among the different fleets; 
c.  ensuring supply for the EU and for the markets of certain developing countries; 
d.  encouraging  the  creation  of  a  secure  environment  that  is  favourable  to  private 

investment and economic activities; and 

e.  taking into account the specific interests of the Union's outermost regions located in 

the vicinity14. 

8 https://www.nafo.int/ 
9 https://www.neafc.org/ 
10 https://www.ices.dk/ 
11 Communication from the Commission to the European parliament, the Council, the Economic and Social 
Committee and the Committee of the regions on the External Dimension of the Common Fisheries Policy, 
COM(2011)424 final, of 13.7.2011. 
12  Council 
(http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/agricult/129052.pdf) 
13 European Parliament’s report on the External Dimension of the Common Fisheries Policy, of 
22.11.2012. 
14 this specific objective is not applicable for this SFPA/protocol. 

the  CFP,  19.03.2012,  7086/12 

external  dimension  of 

conclusions  on 

the 

8 

 
 
3)  To support the development of a sustainable fisheries sector in partner countries 

by: 

a.  contributing  to  the  capacity  building  in  the  third  countries  (notably  by  improving 

fisheries legal framework, control and surveillance and science); 

b.  defining annual and multiannual objectives to be achieved with the aim of developing 

sustainable fishing activities; 

c.  assessment  of  the  results  obtained  in  terms  of  impacts,  and  also  on  budgetary  and 

financial requirements; and 

d.  promoting 

the  employment  of 

infrastructures  and 
local  seamen, 
encouraging landings, supporting the third country in developing local fisheries and 
processing industry. 

improving 

2.1.2  Sustainable  Fisheries Partnership Agreement between the EU and 

Greenland 

The  EU  -  Greenland  fisheries  relations  are  of  special  nature  as  they  originate  in  the 
decision  by  Greenland  to  withdraw  from  the  Community  in  1985  and  the  need  to 
maintain access to its waters for EU vessels following that withdrawal.   

The Sustainable Fisheries Partnership Agreement between the EU and Greenland, and its 
current  implementing  Protocol,  provide  fishing  opportunities  to  fish  for  Union  fishing 
vessels in Greenland’s waters and provides significant sectoral support for the sustainable 
development  of  the  Greenlandic  national  fisheries  sector.  The  SFPA  is  also  a  key 
component of the fishing  quotas exchange network in  the North  Atlantic region,  which 
enables  the  EU  to  swap  fishing  opportunities  in  Greenlandic  waters  for  quotas  in  the 
waters of Northern Agreement partners, such as Norway or Faroe Islands.  

It  establishes  the  principles  on  the  economic,  financial,  technical  and  scientific 
cooperation  in  the  fisheries  sector  with  a  view  to  promoting  responsible  fishing  in 
Greenland’s  waters  to  ensure  the  conservation  and  sustainable  exploitation  of  fisheries 
resources and contribute in the development of the Greenland fisheries sector.  

The Agreement has a duration of 6 years (from 22 April 2021 to 21 April 2027), it can be 
tacitly  extended  for  additional  periods  of  6  years.  The  current  4  years  implementing 
Protocol will de facto expire on 31 December 2024 since the parties agreed the first year 
of application would run from the date of provisional application from 22 April 2021 to 
31  December  2021  and,  for  subsequent  years,  from  1  January  to  31  December.  The 
duration  of  the  Protocol  could  be  extended  for  another  two  years  if  the  parties  would 
agree,  however,  the  Greenlandic  Government  informed  the  EU  of  its  decision  not  to 
extend the current implementing protocol for another two years, so the current protocol, 
which  de  facto  expires  on  31  December  2024,  needs  to  be  renegotiated  in  order  to 
maintain fishing opportunities for the EU fleet after that date. 

There  are two main types of SFPAs: bilateral  agreements for highly migratory species, 
(such as tunas and tuna-like species), and multi-species agreements. Unlike most SFPAs, 
the agreement with Greenland is a multi-species agreement; 10 stocks are covered under 
the current protocol:  

9 

 
cod, pelagic and demersal redfish, Greenland halibut East & West, prawn East & West, 
capelin,  grenadier  East  &  West.  The  SFPA  between  the  EU  and  Greenland  is  the  only 
SFPA under which quota allocation between EU Member States is included in the annual 
Council  regulation  fixing  fishing  opportunities  for  most  fish  stocks  in  EU  and  non-EU 
waters (TAC and Quota Regulation)15. 

6  EU  Member  States  are  involved  DE,  DK,  FR,  LT,  EE,  and  SE.  PL  and  ES  are 
interested in entering the Agreement as well.  

The current Protocol includes an annual EU financial contribution for access  – EUR 13 
590  754  -  and  for  sectoral  support  –  EUR  2  931  000.    The  EU  contribution  is 
complemented by fees payable by EU vessel owners on licences and catches.  

The  following  table  sets  out  the  main  features  of  the  Protocol  implementing  the  EU-
Greenland SFPA for the period 2021-2024. 

Figure 1. Main elements of the current implementing Protocol of the Sustainable 
Fisheries Partnership Agreement between the EU and Greenland 

Duration of the 
Agreement 
Date of entry 
into force of the 
Agreement 
Date of entry 
into force of the 
Protocol 
Duration of the 
Protocol 
EU fishing 
opportunities  

EU financial 
contribution  

Six years renewable 

22 April 2021 

22 April 2021 

4 years: 22 April 2021 – 21 April 2025 (tacitly, 31 December 2024) 

•  Cod - 1,950 tonnes 
•  Pelagic Redfish - 0 tonnes 
•  Demersal Redfish - 1,840 tonnes 
•  Greenland Halibut - West  - 2,250 tonnes 
•  Greenland Halibut – East - 4,950 tonnes 
•  Northern Prawn – West - 2,600 tonnes 
•  Northern Prawn – East - 4,850 tonnes 
•  Capelin - 13,000 tonnes  
•  Grenadier spp. - West  - 100 tonnes 
•  Grenadier spp. – East - 100 tonnes 
•  Bycatch - 600 tonnes 
•  13 590 754 EUR per year for access 
•  2 931 000 EUR per year for sectoral support 

Licence fees paid 
by the EU 
operators 

Stock 

Cod 

EUR per tonne (21-22)  EUR per tonne (23-24) 

160 

200 

15 https://oceans-and-fisheries.ec.europa.eu/fisheries/rules/fishing-quotas_en 

10 

 
 
 
Pelagic Redfish 

Demersal Redfish 

93 

93 

Greenland halibut 

216 

Northern Prawn - East 

100 

Northern Prawn - West 

159 

Capelin 

14 

131 

131 

309 

181 

240 

22 

The sectoral support component is used for programmed activities in the following areas: 
(1)  administration;  (2)  control  and  enforcement;  (3)  support  of  scientific  research  and 
advice.  

Figure  2  provides  a  visual  description  of  the  intervention  logic.  It  seeks  to  connect  the 
needs, objectives, actions and expected achievements. The latter is discussed in terms of 
the outputs, results and impacts of the implementing Protocol.   

Figure 2. Intervention logic of the Fisheries Partnership Agreement between the EU and 
Greenland, and its current implementing Protocol  

11 

 
 
 
 
2.2 Point(s) of comparison  

The  EU  -  Greenland  fisheries  relations  are  of  special  nature  as  they  originate  in  the 
decision  by  Greenland  to  withdraw  from  the  Community  in  1985  and  the  need  to 
maintain  access  to  its  waters  for  EU  vessels  following  that  withdrawal.  As  mentioned 
above,  the  current  Agreement  was  concluded  on  21  April  2021,  and  it  will  be  tacitly 
renewed for six-year periods.  

The previous protocol with Greenland was applicable from 1 January 2016 and expired 
on 31 December 2020. Following 4 month of interruption of the implementing protocol, 
due  to  5  rounds  of  negotiation  during  2020  during  the  COVID  pandemic  and  snap 
election in Greenland in early 2021 which delayed the signing of the current SFPA and 
protocol,  the current  implementing Protocol  was signed and applied  provisionally as  of 
21 April 2021. 

During the four-month period where no implementing protocol was in force – the Union 
fleet  was  not  allowed  to  operate  in  Greenland.  Due  to  the  exclusivity  clause  of  the 
Agreement,  EU  vessel-owners  were  not  allowed  to  enter  private  agreements  with 
Greenland to access their waters and fisheries resources.  In addition, Greenland did not 
receive any EU financial compensation for access nor sectoral support.  

Based  on  the  findings  of  the  evaluation  of  the  former  implementing  protocol  to  the 
Agreement16 include proper reference– applicable from 1 January 2016 to 31 December 
2020 – the negotiation of the current implementing Protocol was the preferred option for 
the  EU  and  Greenland.  The  evaluation  provided  an  overall  assessment  of  the  first  36-
months  of  the  former  implementing  protocol,  concluding  that  it  was  effective  in 
achieving  its  objectives  and  economically  relevant,  with  some  areas  for  improvement 
regarding  efficiency  and  coherence,  such  as  increasing  sectoral  support  funding  with 
additional  emphasis  on  issues  of  blue  growth,  helping  to  ensure  that  scientific  research 
capacity  was  strengthened  and  to  updating  the  underlying  framework  to  the  Protocol, 
such  that  it  be  changed  from  the  former  FPA  to  an  SFPA  to  fully  reflect  CFP 
prescriptions.  The  protocol  was  considered  an  added  value  for  both  Parties  and  largely 
accepted by stakeholders.  

Importantly,  the  conclusions  and  recommendations  contained  in  the  evaluation  of  the 
former  implementing  protocol,  formed  the  basis  for  the  negotiation  mandate  of  the 
negotiation for the current implementing Protocol.  

In  this  context,  the  points  of  comparison  considered  for  the  ex-post  and  ex-ante 
evaluation of the current implementing Protocol are the following: 

a)  The  prior  implementing  protocol  (1  January  2016  to  31  December  2020), 
including  the  conclusions  and  recommendations  of  its  ex-post  and  ex-ante 
evaluation and the negotiating mandate; and 

b)  The reference situation at the start of the current implementing Protocol (21 April 

2021). 

16  Ex  ante  and  ex  post  evaluation  study  of  the  Fisheries  Partnership  Agreement  between  the  European 

Union and Greenland - Publications Office of the EU (europa.eu) 

12 

 
 
 
 
 
 
 
 
 
These points of comparison were used, alongside the general and specific objectives of 
SFPAs (see figure 2), to identify certain indicators when assessing the implementation of 
the current implementing Protocol. Importantly, given the nature of these objectives, it is 
not always possible to provide a quantitative indicator for this analysis.  
In terms  of the  access  component, and based on the relevant specific objectives under 
general objectives (1) and (2), the following success criteria and indicators will be used 
for evaluating the implementation of this Protocol, vis-à-vis the points of comparison: 

Figure  3.  Objectives  related  to  the  access  component  and  their  corresponding  success 
criteria and indicators 

Specific objectives 
1.a To what extent fisheries 
activities addressed 
exclusively at surplus 
resources and prevent the 
overfishing of stocks, on the 
basis of the best scientific 
advice and improved 
transparency on the global 
fishing efforts in the waters 
included in the current 
Protocol. 

1.b To what extent the 
implementation has followed 
the same principles and 
promoted the same standards 
for fisheries management as 
applied in EU waters. 

2.a To seek appropriate share 
of the surplus resources, fully 
commensurate with the EU 
fleets interests and their 
regional and sub-regional 
fishing strategy. 

2.b To ensure that the level of 
fees payable by Union ship-
owners for their fishing 
activities is fair and 
proportional considering the 
revenues and costs, non-
discriminatory and promotes a 
level playing field among the 
different fleets. 

Success criteria   
The EU fishing opportunities are 
within the limits established or 
recommended by the relevant 
RFMO/RFO. 

The implementation of the Protocol 
takes into account the management 
strategies and recommendations 
proposed by the relevant 
RFMO/RFO, and Greenland.  

Indicators  
State of the stocks targeted under the 
Protocol and their 
monitoring/management (scientific 
advice analysis by the joint scientific 
committee meetings, RFMO/RFO and 
national scientific institutes).  

Utilisation rate of fishing opportunities, 
including the evolution of EU vessels, 
licences and catches under the Protocol. 

The EU fleet operating under the 
implementing Protocol follow the 
same principles and standards as 
vessels operating in EU waters, 
according to the CFP, and any 
additional standards required by 
Greenland.  
Fishing opportunities covered by the 
Protocol correspond to the needs of 
the EU fleet and are acceptable 
considering the activities of fleets 
active in the same waters at national, 
sub regional and regional level.  

The Protocol offers similar conditions 
to other foreign fleets operating in 
the fishing zones and management 
areas of the Agreement. 

The cost benefit ratio is acceptable 
and reasonable for the EU ship 
owners and for Greenland. 

Compliance of fisheries management 
measures applicable in the 
framework of the Protocol, in the EU 
and in Greenland.  

Utilisation rate of fishing 
opportunities, 
including the evolution of EU vessels, 
licences and catches under the Protocol. 

Level of contribution to the supply of 
the EU market (volume and value). 
Level of fees and technical 
conditions applied to third countries 
fleets in the fishing areas of Greenland  

Proportion between fees, costs and 
benefits for the EU ship owners and 
for Greenland. 

In terms  of assessing  the  implementation  of the  technical conditions  established under 
the  current  Protocol,  and  based  on  the  relevant  specific  objectives  under  these  general 
objectives,  the  following  success  criteria  and  indicators  will  be  used  for  evaluating  the 
implementation of this Protocol, vis-à-vis the points of comparison: 

13 

 
 
  
 
 
 
 
 
 
 
Figure 4. Objectives related to the technical conditions and their corresponding success 
criteria and indicators 

Specific objectives 
1.c To what extent the scientific 
and technical evaluation of the 
fisheries concerned have 
improved? 

Success criteria   
EU fishing activities follow a scientific 
data collection framework. This 
information is transmitted to the 
relevant RFMO/RFO and national 
research institutes.  

Indicators  
Compliance with scientific data 
collection obligations (e.g. logbook 
and scientific observers) under the 
Protocol.  

1.d Ensuring compliance and 
combating IUU fishing 

EU scientists and scientists from 
Greenland actively participate in  
RFMO/RFO scientific committees.  
The activity of the EU fleet is 
properly monitored (VMS, AIS, 
etc.), in accordance with the Protocol.  

2.c To ensure supply for the 
EU and for the markets of 
Greenland and third countries. 

The Protocol offers a framework to 
foster landings to supply local 
markets. 

The Agreement fosters trade on 
fisheries cooperation between the 
EU and Greenland and/or third 
countries.  
EU vessels land part of their caches in 
Greenland.    

3.d Improving infrastructures and 
encouraging landings, supporting 
the third country in developing 
local fisheries and processing 
industry. 

*Landings are treated under 2.c. 
and improvement of 
infrastructure is treated under 
the sectoral support component. 

Regular collection and analysis of 
relevant data in relevant RFMO/RFO, 
and implementation of their 
recommendations.   
Compliance with reporting obligations 
(e.g. logbook, VMS, observers) under 
the Protocol.  

Level of implementation of the 
monitoring, surveillance and control 
(MCS) provisions under the Protocol. 
Level of contribution to the supply of 
the EU market (volume and value), 
including for the processing sector. 

Compliance with landing obligation in 
local market, and level of landing in 
local market versus neighbouring 
countries markets. 

Compliance with obligation to land 
catches in Greenland to supply local 
processing factories. 

In  terms  of  the  sectoral  support  component,  and  based  on  the  relevant  specific 
objectives under general objective (3), the following success criteria and indicators will 
be  used  for  evaluating  the  implementation  of  this  Protocol,  vis-à-vis  the  points  of 
comparison: 

Figure 5. Objectives related to the sectoral support component and their corresponding 
success criteria and indicators 

Specific objectives 
3.a To contribute to capacity 
building and social, 
environmental and economic 
development in Greenland. 

Success criteria   
The sectoral support contributes to capacity 
building and social, environmental and economic 
development in Greenland. 

In particular, the sectoral support contributes to 
adequate training, equipment and 

Indicators  
Improvement of level of 
capacity (social, 
environmental, and economic) 
through sectoral support of 
the implementing Protocol 

14 

 
 
 
 
 
 
 
 
 
 
 
 
3.b defining annual and 
multiannual objectives to be 
achieved with the aim of 
developing sustainable fishing 
activities 

infrastructures namely in the areas of science 
and control, monitoring and surveillance.  
Utilisation of the sectoral support has been duly 
reported in accordance with the Protocol. 

Multiannual programming has been jointly 
established in accordance with the national 
fisheries and aquaculture and with the Protocol. 

3.c assessment of the results 
obtained in terms of impacts, 
and also on budgetary and 
financial requirements 

Effective and timely execution of sectoral 
support funds by Greenland and corresponding 
timely payments by the EU. 

Percentage of the EU 
contribution to the different 
policy areas in Greenland, in 
accordance with the national 
fisheries strategy. 

Comprehensiveness and level 
of detail of the sectoral 
support reporting. 

Execution rate of sectoral 
support by Greenland and 
corresponding timely payment 
by the EU. 

The indicators mentioned to assess the access, sectoral support and technical components 
of the current implementing Protocol will be referenced throughout the next section, and 
often vis-à-vis the points of comparison.  

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

Current state of play 

3.1 Joint Committee  

The  Joint  Committee,  established  under  Article  12  of  the  Agreement,  is  the  body 
responsible  for  monitoring  the  implementation  of  the  Agreement  and  its  implementing 
protocols. It is composed of delegations from the EU and Greenland and should meet on 
annual basis. At the time of this evaluation, and like in the 2016-2020 Protocol, the Joint 
Committee  met  on  annual  basis  (three  times)  throughout  the  current  implementing 
Protocol: 

•  June 2021 by videoconference 
•  May 2022 in Nuuk 
•  May 2023 by videoconference 

3.2 Access component  

As  described  in  Figure  1,  the  current  implementing  Protocol  provides  fishing 
opportunities  for the EU fleet  to  target  demersal  and small  pelagic  species.  The fishing 
opportunities obtained were  allocated by the Council to  seven EU Member States:  DE, 
Denmark, France, Lithuania, Estonia and Sweden. 

The  number  of  vessels  with  authorisations  in  the  years  2021  to  2023  was  4-5  for 
Germany, 1 for Denmark, 3 for Estonia, 0-1 for Sweden, and 0-1 for Lithuania. Typically 
each year Germany has  4 vessels fishing, Denmark and Lithuania 1, and Estonia 2. All 
vessels are large pelagic or demersal trawlers, between 60 and 90 metres in length. 

15 

 
 
 
 
 
 
 
 
 
 
 
 
 
As  described  in  Figure  3,  several  indicators  have  been  used  to  assess  the  current 
implementing  Protocol’s  access  component,  in  relation  to  the  objectives  of  the 
intervention logic. These indicators will be outlined in this section.  

State of the stocks targeted under the current implementing Protocol  

The latest scientific advice for stocks targeted under the Protocol suggests that there are 
only five of 15 species stock components which can be said with some certainty not to be 
over-exploited.  This  compares  to  six  during  the  previous  Protocol.  Nine  of  the  species 
stock  components  are  either  data  limited  with  a  precautionary  approach  to  assessment 
and  resulting  advice  or  are  assessed  as  having  either  stock  status  lower  than  maximum 
sustainable yield (MSY) or stocks being subject to overfishing. Northern prawn stocks in 
East  Greenland  are  of  special  concern  with  biomass  below  Bmsy  and  fishing  mortality 
above Fmsy. During the previous Protocol there were three species stock components of 
special concern.  

The management of fisheries relevant  to  the Protocol  frequently involves shared stocks 
and  the  need  for  joint  management.  Greenland  is  a  party  to  multilateral  or  bilateral 
agreements for the following stocks and shares data on the activities of its vessels where 
relevant:  pelagic  redfish,  with  the  EU,  Faroe  Islands,  Iceland  and  Norway;  West 
Greenland  halibut,  with  Canada;  East  Greenland  halibut,  with  Iceland;  capelin,  with 
Iceland  and  Norway.  Additionally,  Greenland  has  joint  management  of  East  Greenland 
cod  with  Iceland  as  part  of  the  cod  management  plan.  Greenland  is  party  to  all 
agreements  currently  in  place  for  joint  management  of  shared  stocks  relevant  to  the 
Protocol.  Because  Greenland  is  not  a  party  to  a  Coastal  States  Agreement  (CSA)  on 
mackerel, no quota for mackerel has been provided to the EU under the current Protocol. 

The  Protocol  text  and  technical  provisions  are  aligned  well  with  the  management 
strategies of NAFO, NEAFC, and Greenland.  Greenland sets quota for fish stocks which 
are  included  in  the  Protocol.    Advice  is  provided  by  ICES  or  the  NAFO  scientific 
committees based on a mix of full analytical assessments, or a precautionary approach.  

Mechanisms  are  in  place  through  the  Joint  Committee  to  discuss  and  agree  the  part  of 
Greenland’s quota to be allocated to the EU, based on the scientific advice. Apart from 
Northern prawn in East Greenland, Greenland quota and the part of it allocated to the EU 
through the Protocol is lower than the TAC advice. Northern prawns in East Greenland 
have an inshore component  and managers justify TACs above advice, with  the need to 
maintain coastal communities, but EU quota in offshore areas is itself above TAC advice.  

Mitigating  this  situation  however  is  that  the  EU  quota  represents  a  relatively  small 
proportion  of  total  Greenland  quota  for  most  species,  apart  from  demersal  redfish, 
Greenland halibut and Northern prawn in East Greenland.  

Utilisation rate of fishing opportunities 

16 

 
 
 
Before  explaining  the  rate  of  utilisation  of  fishing  opportunities  we  will  focus  on 
explaining  the  complex  mechanism  of  quota  allocation  in  each  Joint  Committee,  the 
transfers of quotas to Norway and between Member States. 

The quota allocated to the EU through the Protocol is agreed by Greenland and the EU at 
meetings of the Joint Committee. Greenland offers the EU a volume of quota for fishing 
opportunities in Greenlandic waters, and the EU then either accepts the quota, accepts a 
proportion  of  the  quota,  or  declines  the  quota  (for  example  over  concerns  over  stock 
status or management arrangements). The resulting quotas agreed each year by the Joint 
Committee  can  vary,  and  in  practice  have  varied,  from  the  indicative  fishing 
opportunities as outlined in the Protocol.  

For capelin, the preliminary advice from ICES forms the basis of capelin quota offered to 
the  EU,  which  is  then  revised  following  the  Icelandic  survey  for  capelin,  taking  place 
once  capelin  fishing  in  Greenlandic  waters  has  ended.  The  in-season  revision  may  be 
upwards or downwards. 

Figure  1:    Indicative  fishing  opportunities  defined  in  the  Protocol  and  agreed  quotas 
(tonnes),  by  species  and  area,  for  the  last  Protocol  (indicative  quota)  and  current 
Protocol (agreed quota for 2021, 2022, and 2023) 

Species 

Cod 
Pelagic 
redfish1 
Demersal 
redfish 
Greenland 
halibut 
Greenland 
halibut 
Northern 
prawn 
Northern 
prawn 

Capelin3 

Mackerel2 

Area 
ICES V, XII, XIV & 
NAFO 1F 
ICES V, XII, XIV & 
NAFO IF 
ICES V, XIV & NAFO 
Subarea 1F 

NAFO 1 

ICES V, XII, XIV 

NAFO Subarea 1 

ICES V, XIV 

ICES V, XIV 
ICES subareas II, V, 
XII, XIV 

Grenadier 

ICES V, XIV 

Grenadier 

NAFO Subarea 1 

Bycatch 

Total 

% of indicative annual quota 
% of indicative quota excluding 
capelin 

Indicative 
annual last 
Protocol 

Indicative 
annual 
current 
Protocol 

Agreed 
2021 

Agreed 
2022 

Agreed 
2023 

1 800 

2 200 

2 000 

2 500 

5 200 

2 600 

5 100 

1 950 

1 950 

1 950 

1 950 

0 

1 840 

2 250 

4 950 

2 600 

4 850 

0 

1 840 

2 250 

4 950 

2 600 

4 850 

0 

1 530 

2 250 

4 950 

2 600 

4 850 

0 

1 530 

2 025 

5 150 

2 600 

5 000 

20 000 

13 000 

13 053 

66 959 

16 356 

- 

100 

100 

1 126 

42 726 

0 

100 

100 

600 

32 240 

0 

100 

100 

600 

32 293 

100% 

0 

90 

90 

600 

85 869 

266% 

0 

30.6 

30.6 

237.3 

34 910 

108% 

100% 

98% 

98% 

17 

 
 
 
 
 
 
 
 
After  the  Joint  Committee  has  agreed  quotas  to  be  allocated  to  the  EU  through  the 
Protocol, the EU exchanges parts of the quotas for some species with Norway, in return 
for  fishing  opportunities  for  the  EU  fleet  in  Norway.  The  EU  swapped  quota  for 
Greenlandic  fishing  opportunities  with  Norway  in  2021,  2022,  and  2023.  The 
Greenlandic  fishing  opportunities  transferred  from  the  EU  to  Norway  are  presented 
below. 

Figure 2:  EU agreed quota in Greenland, and quota transferred to Norway for relevant 
species (2021 - 2023) 

2021 

2022 

2023 

EU/ GRL 
agreed 

NOR 

% 

EU/ GRL 
agreed 

NOR 

% 

EU/ GRL 
agreed 

NOR 

% 

Area 
ICES V, XIV & 
NAFO 
Subarea 1F 

NAFO 1 

1 840 

2 250 

0 

550 

650 

ICES V, XII XIV 

4 950 

Species 

Demersal 
redfish 
Greenland 
halibut 
Greenland 
halibut 
Northern 
prawn 

ICES V, XIV 

4 850 

1 000 

Capelin * 

ICES V, XIV 

13 053 

10 000 

0 

24 

13 

21 

77 

1 530 

2 250 

4 950 

300 

550 

650 

4 850 

1 701 

20 

24 

13 

35 

1 530 

2 025 

5 150 

556 

325 

850 

5 000 

2 123 

66 959 

69 623 

100 

16 356 

10 000 

36 

16 

17 

43 

61 

Total 

12 200 

72 824 

13 854 

Quotas  transferred  to  Norway  represented  relatively  low  proportions  (13-24%)  in  the 
case of Greenland halibut, but 100% of the EU’s capelin quota in 2022, and an increasing 
proportion of Northern prawns over 2021-2023 (up to 43% in 2023). In total the transfers 
to Norway represented 38% of the total EU agreed quota in Greenland in 2021, 97% in 
2022, and 46% in 2023. 

Following  the  transfers  of  quota  to  Norway,  the  remaining  EU  quota  is  distributed 
amongst  the  EU  Member  States  using  relative  stability  keys17,  resulting  in  the  quota 
allocations shown in the following three tables (for 2021, 2022, and 2023). The volumes 
of quota that each Member State initially receives are thus dependent on both the overall 
quota  agreed  at  the  Joint  Committee  meeting  and  the  volume  that  is  transferred  with 
Norway. 

Germany receives the highest volume of quotas and receives the majority of quotas for 
cod,  Greenland  halibut,  and  redfish  (both  pelagic  and  demersal).  France  also  receives 
small quantities of redfish, with Denmark and France each receiving 50% of the total EU 
quota for Northern prawn.  

After  the  initial  allocation  of  quotas  to  Member  States,  quota  can  then  be  transferred 
between them to match available quotas to the needs of the fishing industry. Estonia, and 
Lithuania acceded to the EU in 2004 and receive no Greenlandic quota through relative 
stability,  so  these  Member  States  rely  on  intra-EU  transfers  of  quota  to  obtain  fishing 
opportunities in Greenland. 
Intra-EU Member State transfers were around 4 000 – 5 000 tonnes a year over 2021 to 
2023,  and  almost  all  relate  to  Northern  prawn.  These  transfers  equated  to  24%  of  the 
EU’s total quota remaining after transfers to Norway in 2021 and 2022, and 17% in 2023. 

17 Introduced in 1983 based on the historical practices during the period 1973-1978 by Member States of the EU at that time. 

18 

 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
The general stability in intra-EU transfers between years is expected as the quota swaps 
are often a product of joint ventures and/or long-standing arrangements for cooperation 
between Member States. Northern prawn quota is transferred from France to Denmark as 
the  Danish  fishing  vessel  is  co-owned  by  French  and  Danish  companies.  Similarly, 
Northern  prawn  quotas  are  transferred  in  some  years  between  Denmark  and  Estonia  as 
the Estonian fishing companies are in a joint venture with Danish companies. 

Following  these  transfers,  Germany  and  Denmark  remain  the  largest  quota  holders  as 
shown in the tables below, but the transfers allow for quota to be provided to Estonia and 
Lithuania. 

In  all  three  years,  authorisations  for  target  species  as  a  proportion  of  total  EU  agreed 
quota  (after  transfers  to  Norway)  were  very  high  at  93%  in  2021,  100%  in  2022,  and 
100% in  2023, with  only  Northern prawn in  East  Greenland showing less than optimal 
uptake of 63% in 2021. The proportion of the total agreed quota for targeted species that 
was then caught was also extremely high at 90%, 96% and 98% in 2021, 2022 and 2023 
respectively, with almost full utilisation for all species. 

Figure  9:    Quota  (tonnes),  quota  after  flexibility  (tonnes),  quota  authorised  in  vessel 
authorisations  (tonnes),  proportion  of  quota  authorised  (%),  catch  (tonnes)  and  %  of 
quota  caught,  for  fishing  opportunities  under  the  EU–Greenland  Fisheries  Partnership 
Agreement, 2021 (after transfers to Norway) 

Species 

Cod 
Pelagic 
redfish 
Demersal 
redfish 
Greenland 
halibut 
Greenland 
halibut 
Northern 
prawn 
Northern 
prawn 

Capelin 

Mackerel 

Area 
ICES V, XII, XIV & 
NAFO 1F 
ICES V, XII, XIV & 
NAFO IF 
ICES V, XIV & 
NAFO Subarea 1F 

NAFO 1 

ICES V, XII XIV 

NAFO Subarea 1 

ICES V, XIV 

ICES V, XIV 
ICES subareas II, 
V, XII, XIV 

Grenadier 

ICES V, XIV 

Grenadier 

NAFO Subarea 1 

Bycatch 
Total (excluding Grenadier and 
bycatch) 
Total 

Quota 

Quota after 
flexibility and 
transfer 

Authorised 

% of indicative 
authorised 

Catch 

% of EU 
agreed quota 
caught 

1 950 

1 950 

 1 950 

100% 

1 950 

100% 

0 

0 

0 

n/a 

0 

1 840 

1 840 

1 700 

1 700 

4 300 

4 050 

2 600 

2 521 

3 850 

3 653 

0 

0 

75 

60 

600 

0 

0 

75 

60 

600 

1 831 

1 700 

4 300 

2 581 

2 305 

0 

0 

n/a 

n/a 

n/a 

100% 

1 827 

100% 

1 690 

106% 

4 050 

100% 

102% 

2 521 

100% 

63% 

2 032 

n/a 

n/a 

n/a 

n/a 

n/a 

0 

0 

41 

7 

225 

n/a 

99% 

99% 

56% 

n/a 

n/a 

55% 

12% 

38% 

90% 

87% 

16 240 

15 714 

16 975 

16 449 

14 667 

14 667 

93% 

14 070 

14 343 

19 

 
 
 
 
 
  
 
 
Figure  10:    Quota  (tonnes),  quota  after  flexibility  (tonnes),  quota  authorised  in  vessel 
authorisations  (tonnes),  proportion  of  quota  authorised  (%),  catch  (tonnes)  and  %  of 
quota  caught,  for  fishing  opportunities  under  the  EU–Greenland  Fisheries  Partnership 
Agreement, 2022 (after transfers to Norway) 

Species 

Cod 
Pelagic 
redfish 
Demersal 
redfish 
Greenland 
halibut 
Greenland 
halibut 
Northern 
prawn 
Northern 
prawn 

Capelin 

Mackerel 

Area 
ICES V, XII, XIV & 
NAFO 1F 
ICES V, XII, XIV & 
NAFO IF 
ICES V, XIV & 
NAFO Subarea 1F 

NAFO 1 

ICES V, XII XIV 

NAFO Subarea 1 

ICES V, XIV 

ICES V, XIV 
ICES subareas II, 
V, XII, XIV 

Grenadier 

ICES V, XIV 

Grenadier 

NAFO Subarea 1 

Bycatch 
Total (excluding Grenadier and 
bycatch) 

Total 

Quota after 
flexibility and 
transfer  

Quota  

Authorised 

% of indicative 
authorised 

Catch 

% of EU 
agreed 
quota 
caught  

 1 950 

1 950 

1 950 

100% 

1 949 

100% 

0 

0 

0 

n/a 

0 

n/a 

1 230 

1 224 

1 700 

1 700 

4 300 

4 550 

2 600 

2 471 

3 148 

3 346 

0 

0 

50 

35 

600 

0 

0 

50 

35 

600 

14 928 

15 241 

15 613 

15 926 

1 224 

1 700 

4 550 

2 581 

3 345 

0 

0 

n/a 

n/a 

n/a 

15 350 

15 350 

100% 

 1 197 

98% 

100% 

1 660 

98% 

100% 

4 440 

98% 

104% 

2 142 

87% 

100% 

3 265 

98% 

n/a 

n/a 

n/a 

n/a 

n/a 

0 

0 

30.8 

2.8 

225 

101% 

14 653 

14 912 

n/a 

n/a 

62% 

8% 

38% 

96% 

94% 

20 

 
 
 
  
 
 
Figure  11:    Quota  (tonnes),  quota  after  flexibility  (tonnes),  quota  authorised  in  vessel 
authorisations  (tonnes),  proportion  of  quota  authorised  (%),  catch  (tonnes)  and  %  of 
quota  caught,  for  fishing  opportunities  under  the  EU–Greenland  Fisheries  Partnership 
Agreement, 2023 (after transfers to Norway) 

Quota  

Quota after 
flexibility and 
transfer  

Authorised 

% of indicative 
authorised 

Catch 

% of EU 
agreed quota 
caught  

1 950 

1 950 

1 950 

100% 

1 949.5 

100% 

0 

974 

0 

974 

1 700 

1 700 

4 300 

4 300 

2 600 

2 729 

2 877 

2 809 

0 

0 

60 

45 

600 

0 

0 

60 

45 

600 

0 

969 

1 700 

4 300 

2 729 

2 809 

0 

0 

n/a 

n/a 

n/a 

n/a 

0 

99% 

944 

100% 

1 690 

100% 

4 286 

100% 

2 651 

100% 

2 719 

n/a 

n/a 

n/a 

n/a 

n/a 

0 

0 

0 

4 

53 

14 401 

14 462 

15 106 

15 167 

14 457 

14 457 

100% 

14 240 

95%  

14 297 

n/a 

98% 

98% 

98% 

87% 

98% 

0% 

n/a 

51% 

6% 

38% 

98% 

94% 

Species 

Cod 
Pelagic 
redfish 
Demersal 
redfish 
Greenland 
halibut 
Greenland 
halibut 
Northern 
prawn 
Northern 
prawn 

Capelin 

Mackerel 

Area 
ICES V, XII, XIV & 
NAFO 1F 
ICES V, XII, XIV & 
NAFO IF 
ICES V, XIV & 
NAFO Subarea 1F 

NAFO 1 

ICES V, XII XIV 

NAFO Subarea 1 

ICES V, XIV 

ICES V, XIV 
ICES subareas II, 
V, XII, XIV 

Grenadier 

ICES V, XIV 

Grenadier 

NAFO Subarea 1 

Bycatch 
Total (excluding Grenadier and 
bycatch) 

Total 

Number of fishing licences 

The  three  tables  below  present  the  number  of  vessels  with  authorisations  for  different 
species in 2021, 2022, and 2023. The total number of vessels authorised declined by one 
vessel each year. Germany had the most authorised vessels in each of the three years. All 
vessels are pelagic or demersal trawlers, with gross registered tonnage and length overall 
(LOA) ranging between 1 410 and 4 290 tonnes and 58 and 92 metres respectively. 

Figure  12:    Number  of  vessels  authorised  by  Member  State  and  authorisation  type  in 
2021 

MS 

Cod 

GRL 
halibut – 
east 

GRL 
halibut – 
west 

North 
prawn – 
east 

North 
prawn – 
west 

DE 

DK 

FR 

EE 

4* 

- 

- 

- 

5* 

- 

- 

- 

4* 

- 

- 

- 

- 

1 

- 

3* 

21 

Ca
pel
in 
- 

- 

- 

- 

- 

1 

- 

- 

Demersal 
redfish 

Total 
vessel
s 

3* 

- 

- 

- 

5 

1 

0 

3 

 
 
 
 
 
 
LT 

SE 

- 

- 

- 

- 

- 

- 

1 

- 

- 

- 

- 

- 

- 

- 

1 

0 

4 

5 

Total 
Source:  European  Commission,  DG  Mare.  Note:  east  =  east  Greenland,  west  =  west 
Greenland. ‘Total vessels’ shows number of different vessels from each MS, not the number of 
authorisations. * = vessel authorisation(s) used collectively by more than one vessel. 

10 

1 

3 

5 

0 

4 

Figure  13:    Number  of  vessels  authorised  by  Member  State  and  authorisation  type  in 
2022 

MS 

Cod 

GRL 
halibut – 
east 

GRL 
halibut – 
west 

North 
prawn – 
east 

North 
prawn – 
west 

DE 

DK 

FR 

EE 

LT 

SE 

Total 

4* 

4* 

4* 

-  

-  

-  

-  

- 

4 

-  

-  

-  

-  

- 

4 

-  

-  

-  

-  

- 

4 

- 

1 

- 

3* 

- 

- 

4 

Ca
pel
in 
- 

- 

- 

- 

- 

1 

1 

- 

1 

- 

- 

- 

- 

1 

Demersal 
redfish 

Total 
vessel
s 

3* 

- 

- 

- 

- 

- 

3 

4 

1 

0 

3 

0 

1 

9 

Source:  European  Commission,  DG  Mare.  Note:  east  =  east  Greenland,  west  =  west 
Greenland. ‘Total vessels’ shows number of different vessels from each MS, not the number of 
authorisations. * = vessel authorisation(s) used collectively by more than one vessel. 

Figure  14:    Number  of  vessels  authorised  by  Member  State  and  authorisation  type  in 
2023 

MS  Cod 

GRL 
halibut – 
east 

GRL 
halibut – 
west 

North 
prawn – 
east 

North 
prawn – 
west 

DE 

DK 

FR 

EE 

LT 
Tot
al 

4* 

4* 

4* 

-  

-  

-  

-  

4 

-  

-  

-  

-  

4 

-  

-  

-  

-  

4 

- 

1 

- 

3* 

- 

4 

- 

1 

- 

- 

- 

1 

Ca
pe
lin 
- 

- 

- 

- 

- 

0 

Demersa
l redfish 

Total 
vessel
s 

3* 

- 

- 

- 

- 

3 

4 

1 

0 

3 

0 

8 

In  comparison  with  the  previous  Protocol,  in 2016, 2017 and 2018 the total number of 
vessels authorised was stable at 12 EU vessels each year. Germany had four authorised 
vessels in each of the three years, all of which fished under the agreement. Germany (2 
vessels), the UK (1 vessel) and Estonia (1 vessel) introduced new vessels to their fleets 
fishing in Greenland over the 2016-2018 period, replacing older vessels. All vessels were 
pelagic  or  demersal  trawlers,  with  gross  registered  tonnage  and  length  overall  (LOA) 
ranging between 1 410 and 4 290 tonnes and 58 and 92 metres respectively.  

22 

 
 
 
Number of catches  

The  table  below  shows  the  total  catches  by  species  and  area  made  in  Greenland  waters 
over  the  2021  -  2023  period.    Catches  of  41  555  tonnes  compare  to  catches  of  42  579 
tonnes over 2016 – 2018. Over 2021 – 2023 the value of German catches was 61.2% of 
total  revenue,  Danish  revenues  accounted  for  28.8%,  and  Estonian  and  Lithuanian 
revenues combined for just under 10%. The average first sale price of catch declined from 
EUR  4  543/tonne  over  2016  –  2018  to  EUR  3  661/tonne  over  2012  –  2023,  driven  by 
lower  prices  for  Northern  prawn  and  Greenland  halibut  (with  higher  prices  for  cod), 
explaining the lower catch revenues over 2021  – 2023 despite catch volumes remaining 
largely similar over the two 3-year periods. 

Figure  15:    Total  catch  (tonnes)  and  estimated  revenue  (EUR),  by  country  and  species, 
aggregated over 2021 - 2023 

Member 
State 

Germany 

Denmark 

Estonia 

Latvia 

Total 

Species 
Cod 

Greenland 
halibut 
Greenland 
halibut 
Demersal 
redfish 
Northern 
prawn 
Northern 
prawn 
Northern 
prawn 
Northern 
prawn 

Area 
ICES XIV & NAFO 1 

Catch 

Revenue 

6 067 

35 920 659 

ICES V, XIV 

NAFO 1 

ICES V, XIV & NAFO 1 

ICES V, XIV 

NAFO 1 

ICES V, XIV 

ICES V, XIV 

13 140 

38 563 698 

5 076 

14 802 753 

4 004 

3 593 547 

4 104 

15 416 936 

7 387 

28 343 393 

997 

12 339 297 

680 

2 775 301 

41 455  151 755 586 

Access fees for licences and catches 

The fishing authorisation fees paid by EU vessels are shown in Figure 16 and rise during 
the Protocol every two years. Fees are not paid for bycatches. If authorised quantities are 
not  fished,  the  fee  corresponding  to  any  such  unused  authorised  quantity  is  not 
reimbursed (unless the Protocol is suspended or terminated).  

Figure 16:  Fishing authorisation fees by species (EUR/tonne) 

Species 

Cod 
Redfish 

EUR per tonne 
2021/2022 

EUR per tonne 
2023/2024 

EUR per tonne 
2025/2026 

160 
93 

200 
131 

241 
169 

23 

 
 
  
  
  
  
 
Greenland halibut 
Northern prawn – east 
Northern prawn – west 
Capelin 

216 
100 
159 
14 

309 
181 
240 
22 

402 
263 
322 
29 

Figure  17  presents  the  access  fees  as  a  proportion  of  turnover,  and  the  access  fees  as  a 
proportion  of  direct  Gross  Value  Added  (GVA)  in  Greenlandic  waters.  These  ratios 
provide a comparison between access fees paid and economic performance of the vessels. 
Access  fees have an impact  on the fleet  profitability  measured through the  Gross  Profit 
(GRP) indicator (discussed above). 

Access  fees  paid  by  the  EU  vessels  represented  5.6%  of  their  income  over  the  2021  - 
2023 period with  variation between 4.4%  and 7.2%, compared to  3.3%  of their income 
over the 2016 – 2018 period during the last Protocol. Access fees as a percentage of value 
added were 8.8% over 2021 – 2023 (compared to 6.8% over 2016 – 2018). 

Figure 17:  Access costs as a percentage of turnover from catches in Greenland, and as a 
percentage  of  gross  value  added  from  catches  in  Greenland,  for  EU  vessels  benefiting 
from fishing opportunities in Greenland 

Access fees / turnover 

Access fees / GVA 

2021 

2022 

2023 

All years 

5.5% 

4.4% 

7.2% 

5.6% 

10.4% 

6.6% 

10.2% 

8.8% 

The EU’s financial contribution to Greenland in 2021 - 2023 is shown in the table below, 
and averaged EUR 17.76 million over the three-year period, or 107.5% of the payments 
envisaged in the Protocol. 

Figure 18:  EU payments for financial compensation (adjusted taking account of agreed 
fishing opportunities) 2021 to 2023 (EUR) 

 EU budget payments 

Financial compensation 

2021  
14 024 766  

2022  
17 089 034 

2023  
13 383 921 

Taking account of authorisation fees paid by EU fishing vessel operators, which were a 
yearly average of EUR 2.86 million over 2021 – 2023 (as compared to EUR 2.09 million 
over 2016 – 2018 during the last Protocol), total payments from the EU budget and from 
EU  private  sector  operators  combined  were  EUR  61.86  million  over  2021  –  2023  or  a 
yearly average of EUR 20.62 million (see Table 29). 

Thirty-eight  percent  of  total  EU  fishing  vessel  operator  payments  over  2021  -  2023 
related  to  authorisations  for  Greenland  halibut  in  East  Greenland,  15%  for  Greenland 
halibut in West Greenland, 26% for Northern prawns in East and West Greenland, 12% 
for cod, 5% for demersal redfish, 3% for pelagic redfish, and 0.5% for capelin. 

24 

 
 
  
 
 
 
  
 
  
  
Figure  19:    Total  EU  contributions  (access  and  sectoral  support)  and  payments  by  EU 
fishing vessel operators, 2021 to 2023 (EUR) 

Payments 

EU budget 

2021 
16 955 766 

2022 
20 020 034 

EU vessel operators 

2 492 162 

2 528 196 

Total 

19 447 928 

22 548 230 

2023 
16 314 921 

3 546 636 

19 861 557 

Overall,  the  EU  financial  contribution  for  access  and  sectoral  support  has  increased 
steadily,  alongside  the  increase  in  fishing  opportunities  and  categories  over  the  past 
implementing Protocols. This increase is  also reflected in the EU financial contribution 
for sectoral support, which has also augmented.  

Level of fees and technical conditions applied to EU vessels 

The  principal  of  non-discrimination  in  the  current  implementing  Protocol  prohibits  the 
granting of more favourable technical conditions to other fleets than those granted to EU 
operators in Greenland. It has been mostly respected.  

Fishing  by  other  foreign  countries  is  therefore  subject  to  similar  conditions,  with 
legislation  applying  to  fishing  vessels  irrespective  of  flag.  This  applies  certainly  to 
Greenlandic technical conditions/regulations. In line with the SFPA text (Article 3.3 and 
3.4)  Greenland  makes  available  information  about  the  overall  TAC  and  fishing 
opportunities to  foreign fleets.  It  is  expected that foreign  fishing vessels would not  pay 
for  fishing  opportunities  originating  from  Greenland’s  other  agreements  as  these 
agreements  operate  on  the  basis  of  a  mutual  exchange  of  fishing  opportunities,  rather 
than  financial  compensation  for  access  to  fishing  opportunities  in  the  case  of  the  EU–
Greenland SFPA 

Compliance of fisheries management measures by EU vessels 

The  SFPA  and  Protocol  place  obligations  on  the  parties.  These  obligations  cover:  the 
timing of financial contributions from the EU to Greenland; management of the sectoral 
support  through  a  multi-annual  framework  and  annual  reporting;  frequency  of  Joint 
Committee meetings and the topics they should cover; reporting by Greenland on use of 
sectoral  support  funds;  scientific  cooperation;  the  timing/speed  for  the  issuing  of 
authorisations;  sharing  of  information  by  Greenland  with  the  EU  on  technical 
conservation  measures;  recording  and  reporting  of  catch  and  bycatch;  transmission  of 
information  about  vessels  entering  and  leaving  the  Greenlandic  fishing  zone,  and  about 
landings  in  Greenland  and  any  transhipment;  satellite-based  monitoring  of  vessels; 
inspections  of  EU  vessels  at  sea  or  in  port;  an  observer  scheme;  handling  of  any 
infringements by EU vessels; experimental fisheries. 

Consultations with stakeholders in both the EU and Greenland provided evidence that by-
and-large, all requirements of the SFPA and Protocol have been complied with, and that 
the  parties  do  not  face  difficulties  in  complying  with  the  legal  texts.  However,  it  was 
noted that: 

•  An electronic licensing/authorisation system is a stated intention (not a legal requirement) 

but has not been introduced. 

25 

 
 
 
  
•  An electronic reporting system (ERS), which is also a stated intention of both the current 
and  previous  Protocol  (not  a  legal  requirement)  is  still  to  be  put  in  place  by  Greenland 
Fisheries License Control Authority (GFLK). The lack of harmonisation with e-logbooks 
used  by  EU  vessels,  and  the  fact  that  Greenland  does  not  use  the  Fisheries  Language 
Universal  eXchange  (FLUX)  system  of  data  exchange,  means  that  records  of  catches 
retained  by  the  EU  and  by  Greenland  differ  by  small  amounts,  because  EU  catches  are 
recorded  based  on  landings  data/sales  notes,  while  Greenland  uses  logbook  data  for  its 
records of catches by EU vessels. 

•  There  are several  stocks for  which  fishing  opportunities agreed by the Joint Committee 
are  based  on  TACs  that  are  not  in  line  with  the  scientific  advice,  even  though  the  EU 
allocation is generally a small proportion of the overall TAC. 

•  Greenland does not deploy observers on EU vessels at all times (although EU observers 
are present). The Protocol requires EU vessels to take onboard Greenlandic observers if 
they can be present in time at ports from which EU vessels depart, and EU vessels have 
been willing to do so. However, the fact that many EU vessels land into Iceland or more 
often EU ports mean that it is difficult for Greenland to deploy observers.  

•  There has been no mutually reciprocated interest in establishing joint enterprises/ventures 
(an  intention,  but  not  a  legal  requirement)  due  to  the  priorities  of  the  private  sector  in 
Greenland  and  in  EU  MS,  coupled  with  regionally  uncompetitive  economics  for 
Greenlandic-based operations. This was also the case under the previous Protocol. 

•  Quota allocated to EU vessels that is subsequently transferred to non-EU fishing nations 

results in Greenland receiving no private sector payments for that quota. 

Economic benefits for the EU and Greenland 
The cost-benefit ratios in relation to value of access payments for quota not transferred to 
Norway,  and  the  catches  made  only  in  Greenland,  are  shown  in  Table  40.  In  total, 
Greenland is estimated to have received an average of 945 EUR / tonne from the EU and 
EU  shipowners  for  fish  caught  by  EU  operators  in  its  fishing  zone  (compared  to  750 
EUR/tonne  during  the  last  Protocol  over  2016  –  2018),  with  21.6%  borne  by  EU 
shipowners (compared to 19.7% over 2016  – 2018). The monies received by Greenland 
represent  25.8%  of  the  first  sales  price  of  the  catch  (up  from  16.5%  during  the  last 
Protocol).  

Figure  20:    Cost  benefit  indicators  in  relation  to  average  price  paid  for  each  tonne 
caught by EU vessels aggregated over the 2021 - 2023 period 

Compensation element 

2016 - 2018 

EU payments for access (quota not transferred, EUR) 

25 663 071 

Access fees paid by EU shipowners in Greenland (EUR) 

6 276 206 

Total EU payments (EUR) 

31 939 277 

Average access cost per tonne caught in Greenland (EUR/tonne) 
Access cost paid by the EU for catches in Greenland 
(EUR/tonne)  
Access cost paid EU shipowners for catches in Greenland 
(EUR/tonne) 
Average proportion borne by EU shipowners 

26 

2021 - 
2023 
30 722 
596 
8 456 8
49 
39 179 
445 
945 

741 

204 

750 

603 

147 

19.7% 

21.6% 

 
 
  
Average first sales price of catch in Greenland (EUR/tonne) 
Average proportion of market value received by Greenland 
Source: consultant analysis based on earlier tables 

4 543 
16.5% 

3 661 
25.8% 

Concerning cost-benefit ratios in relation to GVA, the main finding is that every EUR 1 
invested  from  the  EU  budget  in  the  compensation  payment  for  access,  supports  the 
creation of EUR 6.88 of value added (compared  to  EUR 7.61 during the last Protocol). 
This  is  shared  between  the  EU,  Greenland  and  third  country  entities.  For  the  EU,  most 
economic benefits are from direct GVA, with fewer benefits from activities of ancillary 
activities both upstream and downstream. For Greenland, the Protocol has only minimal 
multiplier effects through indirect GVA, and a large proportion of benefits are the direct 
added  value  in  the  form  of  the  compensation  payments  from  the  EU.  For  each  EUR  1 
invested  from  the  EU  budget,  when  considering  the  compensation  payments,  EU 
authorisation fees paid by EU private sector vessels, and value added generated in up- and 
down-stream  activities,  the  Protocol  generates  value-added  for  Greenland  of  EUR  2.13 
(compared to EUR 1.92 during the last Protocol). 

Figure  21:  Value-added  indicators  generated  by  EU  vessels  benefiting  from  fishing 
opportunities, for the aggregated period 2021 - 2023 

GVA 

Direct GVA 
Indirect GVA 
Total GVA 
Direct GVA 
Indirect GVA 
Total GVA 
Direct GVA 
Indirect GVA 
Total GVA 
Direct GVA 
Indirect GVA 
Total GVA 

All entities 

EU 

Greenland 

Other entities 

Catches 

Compensatio
n 

Shipowner
s fees 

Total 
payments 

(EUR / t) 

(EUR* / EUR)  (EUR/EUR) 

(EUR/EUR) 

2 369 
1 240 
3 609 
2 331 
807 
3 138 
32 
55 
87 
7 
378 
385 

5.21 
1.67 
6.88 
3.14 
1.09 
4.23 
2.05 
0.07 
2.13 
0.01 
0.51 
0.52 

11.61 
6.08 
17.69 
11.42 
3.96 
15.38 
0.16 
0.27 
0.43 
0.03 
1.85 
1.89 

2.51 
1.31 
3.82 
2.47 
0.85 
3.32 
0.03 
0.06 
0.09 
0.01 
0.40 
0.41 

Source:  consultant  analysis.  Note  *:  EU  and  private  sector  payments  to  GRL  considered  as 
direct GVA. 

Costs of the Protocol 

The EU’s annual financial contribution to Greenland is outlined in the Protocol, with the 
financial compensation based on payment for quotas at 17.5% of the reference price for 
the agreed fishing opportunities for different species. 

An  overview  of  the  timing  of  events  affecting  the  EU’s  financial  contributions  is 
presented in the table below. 

Figure 22: Timing of events affecting the EU’s financial contributions 

27 

 
 
  
  
  
Date 

Action 

February 
2021 

Fishing opportunities for 2021 were agreed through exchange of letters and 
were the indicative fishing opportunities listed in the Protocol. 

Agreed through an extraordinary JC meeting that financial contribution for 
access for 2021 would be EUR 13 590 754, and EUR 2 931 000 for 
sectoral support. 
Due to the late start of agreements during the year, consideration given to 
transferring any unfished quota at the end of the year to 2022. 
Greenland presented the annual implementation report for sectoral support 
for 2020. JC meeting notes that despite Covid-19, funds available through 
the sectoral support for 2020 had been fully utilised. 
Agreement reached to pay EUR 2.931 million for the 2021 sectoral support. 

Sectoral support for 2021 paid. 

April 2021 

June 2021 

23 June 
2021 

30 June 
2021 

Deadline for payment of EU contribution for 2021 (compensation for access 
and sectoral support). 

November 
2021 
1 March 
2022 

May 2022 

15 May 

Agreement reached over the fishing opportunities allocated for 2022, with an 
associated financial contribution of EUR 12 654 049. 

Deadline for payment of EU contribution for 2022 for access. 

Greenland presented the annual implementation report for sectoral support 
for 2021 and JC approved the 2021 annual status matrix. 
Agreement reached to pay EUR 2.931 million for the 2022 sectoral support. 
Sectoral support for 2022 paid. 

1 June 2022  Deadline for payment of EU contribution to sectoral support for 2022. 

November 
2022 
1 March 
2023 

May 2023 

Agreement reached over the fishing opportunities allocated for 2023, with an 
associated financial contribution of EUR 12 746 921. 

Deadline for payment of EU contribution for 2023 for access. 

Greenland presented the annual implementation report for sectoral support 
for 2022 and JC approved the 2022 annual status matrix. 
Agreement reached to pay EUR 2.931 million for the 2023 sectoral support. 

1 June 2023  Deadline for payment of EU contribution to sectoral support for 2023. 

6 June 2023  Sectoral support for 2023 paid. 

Agreement reached over the fishing opportunities allocated for 2024, with an 
associated financial contribution of EUR 12 479 154. 

November 
2023 
The EU’s financial contribution to Greenland in 2021 - 2023 is shown in the table below, 
and averaged EUR 17.76 million over the three-year period, or 107.5% of the payments 
envisaged in the Protocol. 

28 

 
  
Figure 23: EU payments for financial compensation (adjusted taking account of agreed 
fishing opportunities) and sectoral support, 2021 to 2023 (EUR) 

 EU budget payments 

Financial compensation 

Sectoral support 

2021  
14 024 766  

2022  
17 089 034 

2 931 000 

2 931 000 

Total EU contribution 

16 955 766 

20 020 034 

2023  
13 383 921 

2 931 000 

16 314 921 

Taking account of authorisation fees paid by EU  fishing vessel operators, which were a 
yearly average of EUR 2.86 million over 2021 – 2023 (as compared to EUR 2.09 million 
over 2016 – 2018 during the last Protocol), total payments from the EU budget and from 
EU  private  sector  operators  combined  were  EUR  61.86  million  over  2021  –  2023  or  a 
yearly average of EUR 20.62 million. 

Thirty-eight  percent  of  total  EU  fishing  vessel  operator  payments  over  2021  -  2023 
related  to  authorisations  for  Greenland  halibut  in  East  Greenland,  15%  for  Greenland 
halibut in West Greenland, 26% for Northern prawns in East and West Greenland, 12% 
for cod, 5% for demersal redfish, 3% for pelagic redfish, and 0.5% for capelin. 

Figure  24:  Total  EU  contributions  (access  and  sectoral  support)  and  payments  by  EU 
fishing vessel operators, 2021 to 2023 (EUR) 

Payments 

EU budget 

2021 
16 955 766 

2022 
20 020 034 

EU vessel operators 

2 492 162 

2 528 196 

Total 

19 447 928 

22 548 230 

2023 
16 314 921 

3 546 636 

19 861 557 

When  examining  reference  prices  compared  to  first  sale  landed  prices  in  the  EU 
(calculated using EUMOFA volume and value landings data), apart from cod for which 
the  reference  price  is  lower  than  first  sale  landed  price,  reference  prices  for  all  other 
species  are  considerably  higher  than  landed  prices  in  the  EU  MS  catching  different 
species under the Protocol (see following table).  

Figure  26:  Reference  price,  Member  State  landed  prices,  and  reference  price  as 
percentage by species, average 2022-2023 (EUR/tonne) 

Species 

Reference price 

EU Member State landed 
price 

Cod 

Pelagic redfish 

Demersal redfish 

Greenland halibut 

Northern prawn 

Capelin 

2 203 

1 890 

1 890 

4 640 

4 080 

364 

29 

6 213 

861 

3 690 

3 549 

3 549 

n/a 

Referen
ce price 
as % of 
MS 
landed 
price 

35% 

220% 

220% 

126% 

115% 

n/a 

 
 
  
  
 
  
Grenadier spp. 

1 735 

634 

257% 

Figure 27 below shows that authorisation fees paid by EU private sector operators to fish 
in  Greenland  ranged  from  4.4%  to  9.1%  of  reference  prices  (compared  to  2.4  –  7.6% 
during  2016  –  2018  of  the  last  Protocol,  with  an  average  of  6.6%  (compared  to  4.5% 
during  the  last  Protocol  over  2016  -  2018).  Authorisation  fees  as  a  percentage  of  EU 
landed prices ranged from 3.2% to 15.2% for different species with an average of 7.7% 
(compared to 0.9% - 5.4% of EU MS first sale prices with an average of 2.8% during the 
last Protocol). (Norwegian and vessels fishing in Greenland using EU quota transferred to 
Norway are not required to pay authorisation fees). 

Figure 27: Authorisation fees as a percentage of the reference price, and average 2022-
2023 EU Member State landed prices 

As % 
of 
Membe
r State 
landed 
price 
3.2% 

15.2% 

15.2% 

8.4% 

5.1% 

5.1% 

As % of reference 
price 

9.1% 

6.9% 

6.7% 

4.4% 

5.9% 

6.9% 

n/a 
9.1% 
6.6%  7.7% 

Species 
Cod 

Pelagic redfish 

Demersal redfish 

Greenland halibut 

Northern prawn – west 

Northern prawn – east 

Capelin 

Average 

Reporting obligations 

Authorisation fee 
200 

131 

131 

309 

240 

181 

25 

181 

A reporting requirement/obligation (RO) is a ‘requirement stemming from EU legislation 
that obliges Member States authorities, private organisations and/or public organisations 
to  provide  (in  principle  periodically)  structured  or  unstructured  data  (qualitative  or 
quantitative) to competent authorities at EU or national level’18.  

In this report the administrative burden from reporting requirements was noted as a point 
of comparison. The figure below provides an assessment of the ROs which stem from the 
SFPA/Protocol, noting whether they are additional either to the previous FPA/Protocol or 
to  other  reporting  obligations  stemming  from  legislation,  such  as:  Regulation  on  the 
sustainable management of external fishing fleets (SMEFF Regulation)19; fisheries control 
regulation20; Greenlandic legislation; RFMO requirements. As evident from the table, the 

18  Call  for  evidence  -  Rationalisation  of  reporting  requirements:  https://ec.europa.eu/info/law/better-

regulation/have-your-say/initiatives/13990-Administrative-burden-rationalisation-of-reporting-
requirements_en 

19 Regulation (EU) 2017/2403 of the European Parliament and of the Council of 12 December 2017 on the 
sustainable  management  of  external  fishing  fleets,  and  repealing  Council  Regulation  (EC)  No 
1006/2008, (OJ L 347, 28.12.2017, p. 81–104) - http://data.europa.eu/eli/reg/2017/2403/oj 

20 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Union control system for 
ensuring  compliance  with  the  rules  of  the  common  fisheries  policy,  amending  Regulations  (EC)  No 

30 

 
 
  
  
 
current  SFPA/Protocol  does  not  entail  any  reporting  obligations  over  and  above  those 
which would otherwise be required, or which were required under the previous Protocol. 

Figure 38: Reporting obligations from SFPA/Protocol 

Additional  to  other  EU,  Greenlandic,  or 
RFMO legislation and requirements? 
No  
(requirements  included  in,  and  the  same  as 
the last Protocol) 

last 

last 

and 

and 

2023/2842 

Protocol, 
(EU) 

Protocol, 
(EU) 

No  
(requirements  included  in,  and  the  same  as 
required  by 
the 
and 
REGULATION 
Greenlandic legislation) 
No  
(requirements  included  in,  and  the  same  as 
required  by 
the 
REGULATION 
and 
Greenlandic legislation) 
No  
(requirements  included  in,  and  the  same  as 
required  by 
the 
REGULATION 
and 
Greenlandic legislation) 
No  
(requirements  included  in,  and  the  same  as 
the 
required  by 
NAFO/ICES) 

Protocol, 
(EU) 

2023/2842 

2023/2842 

Protocol, 

and 

and 

last 

last 

No  
(requirements  included  in,  and  the  same  as 
the 
required  by 
REGULATION (EU) 2023/2842) 

Protocol, 

and 

last 

No  
(requirements  included  in,  and  the  same  as 
the last Protocol) 

No  
(requirements  included  in,  and  the  same  as 
the last Protocol) 

Reporting obligation 

to 

authorities 

Monitoring  and  reporting  by 
the  Joint 
Committee - SFPA Article 12 - and results of 
the annual and multiannual programming by 
Joint 
the 
Greenlandic 
Committee (not explicit, but implicit) 
Reporting  by  shipowners  (by  species  and 
gear)  of  catch,  bycatch  and  discards  -
Protocol  Article  2.4.(b),  and  Annex  Chapter 
the  electronic 
IV,  Section  1  (through 
reporting system when established) 
Transmission of landings data by masters of 
vessels  required  by  the  Agreement  through 
the  ERS  to  the  competent  Greenlandic 
authority - Annex Chapter IV, Section 1 

Reporting of vessel position by vessels to the 
FMC  of their flag  state and by the flag  state 
to  the  Greenlandic  authorities  -  Annex 
Chapter IV, Section 2 

in  an 

Observer  report  by  the  observer  to  the 
master  of  the  vessels  (in  electronic  form), 
and  by  the  Greenlandic  competent  authority 
to  the  Union  of  flag  Member  State  (if 
requested) - Annex Chapter IV, Section 4 
inspection 
included 
Infringements 
report  to  be  sent  by  Greenlandic  authorities 
to  vessel  owners,  the  Union  competent 
authority and the flag State - Annex Chapter 
IV, Section 5 
A  weekly  report  on  catches  per  day  and  by 
haul,  and  an  evaluation  report  by  the  Union 
vessels  to  EU  and  Greenlandic  parties  no 
later than 30 days after the conclusion of an 
experimental fishery - Annex Chapter VI 
EU flag State reports to the Union authorities 
on catches of pelagic redfish taken under the 
Greenlandic quota in Greenlandic waters and 
in  the  NEAFC  regulatory  area  under  the 
flexibility  scheme,  and  flag  State  FMCs  to 
report  to  the  Greenlandic  authorities  catch 
statistics– Appendix 5  

3.3 Technical conditions  

As  described  in  Figure  4,  several  indicators  have  been  used  to  assess  the  current 
implementing  Protocol’s  technical  conditions,  in  relation  to  the  relevant  specific 

847/96,  (EC)  No  2371/2002,  (EC)  No  811/2004,  (EC)  No  768/2005,  (EC)  No  2115/2005,  (EC)  No 
2166/2005, (EC) No 388/2006, (EC) No 509/2007, (EC) No 676/2007, (EC) No 1098/2007, (EC) No 
1300/2008, (EC) No 1342/2008 and repealing Regulations (EEC) No 2847/93, (EC) No 1627/94 and 
(EC) No 1966/2006, latest consolidated version: http://data.europa.eu/eli/reg/2009/1224/2024-01-09 

31 

 
  
 
 
objectives.  These  indicators  will  be  outlined  in  this  section.  Importantly,  EU  vessels 
generally complied with the technical conditions of the current implementing Protocol, as 
they had done in the 2015-2019 Protocol.  

On scientific data collection, EU fishing activities are subject to an appropriate reporting 
obligation framework (logbook, VMS, observers etc.) in the Agreement and a scientific 
data  collection  framework  (size  composition  of  the  catches,  biological  parameters  etc.). 
This information is transmitted to the relevant RFMO and national research institutes.  
EU  scientists  and  Greenland  scientists  actively  participate  in  scientific  meetings  and 
RFMO/RFO scientific committees. 

On  monitoring,  control  and  surveillance,  the  activity  of  the  EU  fleet  is  properly 
monitored  (VMS,  AIS,  observers  aboard,  etc.);  reporting,  monitoring  and  control  takes 
place as stipulated in the Protocol and as legislation requires. Moreover, there is adequate 
monitoring,  reporting  and  control  of  all  catches  and  catch  composition,  possible 
infractions are sanctioned;  sectoral  support is  used to  reinforce monitoring, control and 
surveillance (MCS).  

On  provisions  regarding  the  boarding  of  observers,  Greenland  does  not  deploy 
observers on EU vessels at all times (although EU observers are present). The Protocol 
requires EU vessels to take onboard Greenlandic observers if they can be present in time 
at  ports  from  which  EU  vessels  depart,  and  EU  vessels  have  been  willing  to  do  so. 
However, the fact that many EU vessels land into Iceland or more often EU ports mean 
that it is difficult for Greenland to deploy observers.  

On employment, The Protocol was important for the EU fleet in terms of employment 
creation,  supporting  around  177  jobs  onboard  vessels,  with  168  of  those  being  for  EU 
nationals. Additionally, around 600 jobs in the processing sector in the EU are estimated 
to  be  dependent,  to  some  extent,  on  the  catches  made  in  Greenlandic  waters  and 
processed in the EU. 

On social clauses applicable to seamen on board EU vessels, there are no indications 
of possible non-compliance by EU vessels. 

On  food security,  in  the  current  implementing  Protocol,  vessel’s  activity  support  port-
related businesses in the EU and provides raw material for the EU processing sector. 

3.4 Sectoral support component  

The EU’s total annual sectoral support contribution as outlined in the Protocol is EUR 2 
931 000. This must be spent by Greenland in accordance with Article 4 of the Protocol. 
Specifically, the Protocol states that the Joint Committee should agree on a multiannual 
sectoral  programme  and  implementing  rules.  The  Joint  Committee  assumes  the 
responsibility for programming the sectoral policy support payment from the EU for the 
duration of the Protocol. 

As  described  in  Figure  5,  several  indicators  have  been  used  to  assess  the  current 
implementing Protocol’s sectoral support component, in relation to the relevant specific 
objectives. These indicators will be outlined in this section.  

Monitoring of sectoral support  

32 

 
 
 
The Joint Committee is responsible for adopting annual and multi-annual programming 
and monitoring sectoral support. Any changes to programming must be approved by the 
Joint Committee.  

The annual sectoral matrices provided by Greenland were comprehensive in terms of the 
indicators  and  targets  included,  and  the  annual  reports  prepared  by  the  Greenland 
authorities  were  comprehensive  and  informative  in  their  presentation  of  budgets, 
expenditure, and achievements. Annexes to the annual reports provided additional detail. 

 Greenland has submitted reports on activities implemented with sectoral support funds. 
At the time of this evaluation, the following reports have been submitted: 

• 
• 
• 

Implementation report for the first tranche (May 2021) 
Implementation report for tranche 2 (May 2022) 
Implementation report for tranche 3 (June 2023) 

Payment of sectoral support 

The current implementing Protocol has earmarked an EU financial contribution of EUR 
2.93  million  per  year  (2021-2024)  towards  sectoral  support.  The  current  implementing 
Protocol  provides  for  the  EU  to  suspend  payments  in  whole  or  in  part  if  the  Joint 
Committee  considers  that  results  are  not  in  line  with  programming.  The  Protocol 
stipulates  that  sectoral  support  payments  may  not  be  made  beyond  6  months  after  the 
Protocol expires (December 2024). 

Figure 39. EU sectoral support payments in the 2021-2024 Protocol21 

EU payment  

Date 

Amount (EUR) 

Tranche 1  

Tranche 2 

Tranche 3 

Total  

Maximum EU financial contribution to sectoral 
support by December 2024 

Programming of sectoral support  

23/06/2021 

2 930 000 

17/05/2022 

2 930 000 

06/06/2023 

2 930 000 

8 790 000 

11 720 000 

A  summary  description  of  the  content  and  focus  of  the  sectoral  support,  along  with 
budget  over  the  five-year  Protocol,  is  provided  below.  The  policy  priority  areas  and 
budget  allocated  to  different  objectives  are  largely  unchanged  from  the  previous 
Protocol. 

1. Policy priority 1.: administration and management (Ministry of Fisheries 
Hunting and Agriculture/APNN - - Aalisarnermut, Piniarnermut, 
Nunalerinermullu Naalakkersuisoqarfik): 

21 For more information on the payment of sectoral support, please see Section 6.4.1 of the evaluation study 

(pending publication).  

33 

 
 
 
 
 
1.1 Enhancement of the legal framework for sustainable fisheries (EUR 80 000) 

1.2 Enhancement and implementation  of the Framework of Management,  Development 
and Administration of the Fisheries (EUR 20 000) 

1.3 International cooperation, obligations and management (EUR 75 000) 

1.4 Capacity building of fisheries officials (EUR 5 000) 

1.5. Financial support fund for the inshore fisheries component (EUR  470 000) 

2. Policy priority 2.: control and enforcement (Greenland Fisheries License Control 
Authority - GFLK): 

2.1. Inspection and control of fisheries (EUR 940 000) 

2.2. Education and training of inspectors and GFLK staff (EUR 30 000) 

2.3. Enhancement of international cooperation for fisheries control (EUR 10 000) 

2.4. Digitalization projects, database expansion and improvement (EUR 60 000) 

2.5. Procurement and maintenance of equipment (EUR 10 000) 

3.  Policy  priority  3.:  support  of  scientific  research  and  advice  on  stock  status 
(Greenland Institute of Natural Resources - GINR): 

3.1. Drafting and presenting advice on stock status (EUR 240 200) 

3.2. Conducting research and surveys in Greenlandic EEZ (EUR 840 700) 

3.3. Drafting and publishing scientific publications in relation to research (EUR 120 100) 

The administration and management policy area accounts for 23% of the planned sectoral 
support budget of EUR 2.931 million each year, control and  enforcement for 36%, and 
support for scientific research and advice on stock status for 41%. 

Implementation of sectoral support  

The sectoral support provided through the agreement was outlined earlier. A comparison 
of the proposed budget for 2021 - 2023 for Greenland’s policy programme and the actual 
expenditure (in 2021 and 2022 as 2023 actual expenditure is not yet known), along with 
the  EU  share  of  expenditure  provided  by  the  sectoral  support,  can  be  gleaned  from  the 
annual  matrices  and  reports  prepared  by  the  Greenlandic  authorities  and  is  presented 
below. As shown in the table, scientific research and advice on stock status accounts for 
the  largest  share  of  the  budget  with  EU  funding  as  a  proportion  of  actual  expenditure 
being greatest for administration by the Ministry. Overall, the EU funding provided just 
over  26%  of  the  total  Greenlandic  expenditure.  There  was  full  utilisation  of  the  EU 
sectoral support budget in both 2021 and 2022 (and this is expected to be the case also in 
2023). 

Figure  40:    The  budget,  expenditure,  and  EU  share  of  expenditure  provided  by  the 
sectoral support (EUR, totals over 2021 - 2023) 

34 

 
  
  
Activity 

Budget 
(2021-2023) 

Actual 
expenditure 
(2021-2022) 

EU funding 
(2021-2022) 

EU 
funds 
as 
share 
of 
expe
nditu
re 
(202
1-
2022
) 

Administration by the Ministry 

5 675 880 

2 946 758 

1 360 000 

46% 

8 820 000 

8 696 257 

2 100 000 

24% 

Control and enforcement by 
GFLK 
Scientific research and advice 
on stock status by GINR 
Total 

2 402 000 
22% 
5 862 000  26% 
Source:  2021  -  2023  annual  sectoral  matrices.  Actual  expenditure  for  2023  not  available  at 
time of writing. 

16 361 180 
30 857 060 

11 140 000 
22 783 016 

The main achievements under the priority policy areas, were as follows, with the specific 
targets for related indicators set in the  annual matrices generally being achieved, and in 
some cases exceeded. 

Policy priority 1, administration (Ministry of Fisheries Hunting and 
Agriculture/APNN): 

•  Seven  Fisheries  Commission  meetings  in  2021  with  a  report  of  recommendations  for  a 

new fisheries Act and work progressed on the Act in 2022. 

•  The  introduction  of  3  species-specific  executive  orders  in  2021  (snow  crab,  lumpfish, 

salmon) and 3 in 2022 (salmon, inshore Greenland halibut, and scallops) 

•  Finalizing,  adopting,  and  implementing  lumpfish,  salmon  and  snow  crab  management 
plans  (2021),  and  plans  for  offshore  Greenland  halibut  in  East  Greenland  2.  inshore 
Greenland halibut in West Greenland (2022). 

•  Numerous Consultations/negotiations with bilateral partners and RFMOs. 
•  Completion of a series of trainings for staff in the Ministry that is responsible for fisheries 

• 

administration and management (important given staff turnover). 
financial  support  for  inshore  fisheries  through  two  separate  funds,  one  for  vessels  (>  6 
meters) and one for dinghies (< 6 meters). 

Policy priority 2, control and enforcement (GFLK): 

•  Development and testing of ERS and the vCatch system. 
•  158 port State controls (2021) and 173 (2022). 
•  2  control  expeditions  of  the  inshore  fishery  in  2021  and  17  full  landing  inspections  in 

2022 

•  70  vessels  less  the  6  meters  long,  and  64  fishing  vessels  above  6  meters  long  were 
controlled (2021), and 65 vessels less than 6 meters and 50 fishing vessels above 6 meter 
were controlled (2022). 11 hygiene checks were also carried out in 2022. 

•  Several campaigning trips and meetings were conducted. 

35 

 
  
  
•  The  observer  coverage  in  the  offshore  fisheries  of  18.7%  for  the  demersal  fisheries  in 
2021 and 15% in 2022, and 4.2% in 2021 and 2.3% in 2022 for the pelagic fisheries and 
experimental  fisheries.  The  observer  coverage  for  the  entire  Greenland  Economic 
Exclusive zone was 16.4% in 2021 and 13% in 2022. 

•  Training of staff. 
•  Participation  by  staff  in  meetings  to  support  International  Cooperation  for  Fisheries 

Control. 

•  Work on the adoption of the fisheries database systems to be compatible with the NEAFC 

FLUX standard. 

•  Purchasing of 3 new 7.7-meter patrol boats in 2022 and purchasing of 3 drones to be used 
by the fisheries and wildlife officers in 2021, and repair and purchase of other equipment. 

•  New executive order on control of fisheries was adopted in 2021 and updated in 2022. 
•  Report prepared and presented on a risk-based approach to control (2022). 

Policy priority 3, support of scientific research and advice (GN): 

•  14 stocks assessed, 37 advisory documents, and participation in 80 international meetings 

(in 2021), with corresponding figures for 2022 of 24, 36 and 50. 

•  13  research  cruises  and  95  survey  days  completed  (in  2021),  and  15  cruises  and  232 

survey days in 2022. 

•  17 reviewed publications produced in 2021, and 14 in 2022. 

4.  EVALUATION FINDINGS  

4.1 To what extent was the intervention successful and why?  

Following  the  intervention  logic  in  Figure  2,  this  section  considers  to  what  extent  the 
current  implementing  Protocol  was  successful  in  reaching  the  general  and  specific 
objectives it set out to achieve through a lens of effectiveness, efficiency and coherence.  

Effectiveness: To what extent was the intervention successful and why? 

The  current  implementing  Protocol  is  effective  on  achieving  the  following  objectives, 
with some specific areas for improvement:  

Objective  1:  To  contribute 
towards  resource  conservation  and  environmental 
sustainability through rational and sustainable exploitation of living marine resources of 
Greenland. 

1.a Fisheries activities are addressed exclusively at surplus resources and prevent the 
overfishing of stocks, based on the best scientific advice and improved transparency 
on the global fishing efforts in the waters included in the current Protocol. 

As described in the previous section, the latest scientific advice for stocks targeted under 
the Protocol suggests that there are only five of 15 species stock components which can 
be  said  with  some  certainty  not  to  be  over-exploited.  This  compares  to  six  during  the 
previous  Protocol.  Nine  of  the  species  stock  components  of  the  supporting  evaluation 
study  (compared  to  6  during  the  previous  Protocol)  are  either  data  limited  with  a 
precautionary  approach  to  assessment  and  resulting  advice  or  are  assessed  as  having 

36 

 
  
  
 
 
 
 
either stock status lower than maximum sustainable yield (MSY) or stocks being subject 
to  overfishing.  Northern  prawn  stocks  in  East  Greenland  are  of  special  concern  with 
biomass  below  Bmsy  and  fishing  mortality  above  Fmsy.  During  the  previous  Protocol 
there were three species stock components of special concern.  

The  main  weakness  under  this  specific  objective  is  that  The  Protocol  provides 
mechanisms  which  are  only  partially  adhered  to,  to  ensure  that  quota  offered  to,  and 
accepted by the EU relates to  surplus  resources  and prevents  the overfishing  of stocks. 
Stock status has not improved overall since the last Protocol. However, one stock is now 
of major concern, the Northern prawn stock in  East  Greenland  ICES XIV and V being 
over-fished and subject to overfishing, while three were of major concern in the previous 
Protocol.  There  is  a  lack  of  up  to  date  and  robust  assessments  for  several  stocks,  and 
some  are  over-fished  or  subject  to  overfishing.  Mitigating  this  however  is  that  the  EU 
quota  represents  a  relatively  small  proportion  of  Greenland  quota  for  most  species 
(except for Northern prawn stock in East Greenland ICES XIV and V) . 

1.b  Implementation  of  principles  and  standards  for  fisheries  management  as  those 
applied in EU waters 

Bycatches  by  EU  and  Greenland  vessels  in  Greenland’s  offshore  fisheries  are  low. 
Management  measures  have  been  introduced  in  Greenlandic  legislation  to  both  reduce 
bycatches and reduce possible impacts on the ecosystem. These also apply to EU fishing 
vessels and include: the mandatory use of sorting grids in Northern prawn shrimp trawl 
fisheries to reduce bycatch of finfish species; a landing obligation, with derogations for 
species and fisheries where release mortality  is  low and prawn trawlers; and maximum 
bycatch rates. 

As stated in the Protocol, bycatches by EU fishing vessels count against SFPA quotas for 
species  where  the  EU  has  fishing  opportunities,  ensuring  that  bycatches  are  taken  into 
account for management of the fisheries. 

Given the low bycatch rates of EU fishing vessels and the landing obligation effective in 
Greenlandic waters, bycatches by EU fishing vessels are likely to have no adverse impact 
on stocks that are also the subject of targeted fisheries. The presence of specific bycatch 
quota in the Protocol for grenadier (introduced during the last Protocol) serves to support 
bycatch management. The latest scientific advice for grenadier (ICES, 2023 and NAFO, 
2014) is provided on a precautionary basis. 

Greenland has implemented measures to protect the corals and the benthic environment, 
which  apply  to  all  vessels  in  Greenland  whether  domestic  or  foreign.  These  include 
closed areas to  protect  concentrations of coral  and sponge communities,  move-on rules 
for bycatches of corals and sponges and technical conservation measures to mitigate the 
impact of bottom contact gears on benthic communities. 

Greenland  has  implemented  mandatory  reporting  of  seabird  bycatches,  although 
interactions  relate  primarily  to  coastal  gillnet  fisheries  in  West  Greenland  not  to  EU 
vessels.  Interactions  between  endangered,  threatened  and  protected  (ETP)  species  and 
EU vessels are minimal, with only limited potential interactions between Northern prawn 
trawl fisheries and the Greenland halibut fishery with Greenland shark. 

1.c Improvement of technical and scientific assessment of the fisheries  

37 

 
 
 
 
  
  
  
  
As  described  in  Section  3.2  of  this  evaluation,  the  EU  fishing  activities  in  Greenland 
under the Protocol are subject to a robust data collection framework in terms of catches, 
bycatches, etc. There are requirements for EU fishing vessels to comply with: obligations 
for  catch  reporting  through  logbook  data  submission;  vessel  monitoring  system  (VMS) 
requirements;  and  Greenland’s  observer  scheme.  These  obligations  are  complied  with, 
with EU vessels providing the required data to the Greenlandic authorities. 

Scientists from the EU (i.e. EU MS and EU joint research institutes), and GINR attend 
relevant  meetings  of  working  groups  in  ICES  and  NAFO  to  contribute  towards 
management  advice,  as  well  as  meetings  in  the  context  of  bilateral  and  multilateral 
agreements  for  joint  management.  EU  sectoral  support  funding  is  used  to  support 
participation  by  Greenlandic  officials  in  these  and  other  relevant  meetings,  as 
documented  in  the  Annual  Status  Reports  which  present  information  about  the 
implementation of fisheries sectoral policy in Greenland and the EU’s contribution to it. 
For example, in 2022, 28 international meetings were attended by Ministry staff.  

The annual sectoral support status matrices for 2021 to 2023, indicate significant levels 
of funding available for the collection of scientific data to support management advice, 
including  surveys  and  biological  data.  Greenland  undertakes  research  surveys  for 
economically important species targeted by EU vessels (as well as other species) in West 
Greenland.  

There has  been longstanding  cooperation and collaboration between scientific institutes 
of  Greenland  and  EU  Member  States  in  relevant  ICES  and  NAFO  working  group 
meetings, as well as outside of them with scientists from EU MS supporting and working 
with GINR.  

1.d Ensuring control and compliance with EU fleet rules 

As  detailed  in  Section  3.2  and  3.3  of  this  evaluation,  monitoring  of  EU  fleet  activity 
through the catch reporting framework provided for by the Protocol is robust and adhered 
to,  as  is  monitoring  through  VMS.  However,  implementation  of  an  electronic  catch 
reporting  system  (ERS)  which  is  the  intention  of  both  the  EU  and  Greenlandic 
authorities,  has  been  several  years  ‘in  the  making’  and  is  still  not  operational  –  this 
despite  sectoral  support  funds  having  been  used  to  support  is  development  and  testing 
over recent years. 

Greenland can effectively control fishing activities within its EEZ, given staffing levels 
and  enforcement  assets.  The  GFLK  administers  the  registration  and  control  of 
Greenlandic  and  foreign  catches  and  landings,  as  well  as  international  agreements  on 
control and enforcement. Data are exchanged with countries that Greenland has fisheries 
agreements with on a daily basis. Control is  based on a risk analysis built on historical 
control data and current information from the ports. Actual offshore inspection of vessels 
at  sea  is  performed  by  the  Royal  Danish  Navy’s  Arctic  Command  (AKO),  and  most 
foreign flagged offshore vessels do not call into port in Greenland. Compliance observers 
onboard vessels, vessel monitoring system (VMS) and data reporting are the main means 
of monitoring compliance. 

Joint Committee meeting minutes and Greenlandic MCS reports do not raise any specific 
issues with regards to non-compliance by the EU fleet, and there were no instances which 
gave rise to a need to sanction EU operators for infringements of fishing regulations. 

38 

 
The annual sectoral support status matrices for 2021 to 2023, indicate significant levels 
of funding available for MCS, with good achievement of targets as assessed against the 
relevant  indicators.  The  substantial  contribution  of  sectoral  support  to  control  activities 
strongly  suggests  that  it  is  allowing  a  more  comprehensive  level  of  control  than  would 
otherwise be possible. 

Objective 2: to contribute to the continuity of fishing activities by the EU distant water 
fleet and employment linked to fleets.  

2.a To seek appropriate share of the surplus resources, fully commensurate with the 
EU fleets interests and their regional and sub-regional fishing strategy. 

As outlined in Section 3.2 of this evaluation, the current implementing Protocol provides 
fishing opportunities that are very important to a small part of the EU fleet, as evidenced 
by  high  rates  of  authorisations  for  EU  quota  (>95%  -  see  Table  20),  and  high  rates  of 
utilisation/catches of authorisations at over 90%. The high rates of utilisation suggest that 
the Protocol fishing opportunities match the fishing patterns of the EU fleet. The Protocol 
quotas were also used in quota transfers with Norway through the EU-Norway agreement 
to  access  fishing  opportunities  in  Norwegian  waters.  The  Protocol  therefore  provided 
access  to  important  fishing  opportunities not  only  in  Greenland, but  elsewhere.  Fishing 
opportunities through the SFPA in Greenlandic and Norwegian waters form an important 
component of total fishing opportunities in northern areas required for EU fishing vessels 
to secure sufficient fishing opportunities for their fishing strategy. 

While recognising  the needs of Greenland to  meet  the needs of its own  fleet  and other 
countries allocated quota in Greenlandic waters, of concern with regards to meeting the 
objective of fulfilling EU fleet needs is that indicative fishing opportunities specified in 
the Protocol are lower than during the previous Protocol for all species (except  for cod 
which had a small increase, and Northern prawns in West Greenland which remained the 
same).  These  declines  are  not  just  based  on  stock  status  and  therefore  lower  overall 
quota, but also on a declining share of TACs in some cases, e.g. for Northern prawn in 
West  Greenland,  and  for  cod  which  has  showed  recent  improvements  in  stock  status, 
which have not been matched by corresponding increase in cod quota to the EU). Further 
reductions  could  compromise  the  ability  of  the  Protocol  to  be  effective  in  supporting 
viability for a number of vessels, especially given the high (and increased since Brexit) 
reliance by the EU vessels concerned on fishing opportunities in Greenland (and Norway 
through  EU  quota  in  Greenland  swapped  with  Norway  in  exchange  for  fishing 
opportunities for EU vessels in Norway). 

For  German  and  Danish  fleets,  the  agreement  is  critically  important  in  terms  of  the 
fishing opportunities it provides in Greenlandic waters. For the German fleet, catches in 
Greenland accounted for an average of 62% of the total value of landings from the 4-5 
vessels concerned over 2021 to 2023 (compared to 59% during the last Protocol), while 
for the Danish vessel targeting Northern prawn, the agreement provided for 89% of the 
value  of  its  catches  over  the  same  period  (compared  to  66%  during  the  last  Protocol). 
These  vessels  combined  accounted  for  more  than  90%  of  the  aggregated  volume  of 
catches in Greenland over 2021 – 2023 by EU vessels. Given the concentration of access, 
for other EU MS the agreement is of less importance given either initial quota allocations 
that are low based on relative stability, or the small amounts of final quota available after 
transfers  between  EU  MS  and  catches  by  Estonian  and  Lithuanian  vessels.  However, 
fishing  opportunities  for  EU  vessels  in  Norway  enabled  through  the  Protocol  are 

39 

 
important for a number of EU MS (notably Germany, Spain, France, and Portugal), even 
though  (with  the  exception  of  Germany)  they  do  not  end  up  fishing  EU  quota  in 
Greenland. 

The Protocol was important for the EU fleet in terms of employment creation, supporting 
around 177 jobs onboard vessels, with 168 of those being for EU nationals. Additionally, 
around  600  jobs  in  the  processing  sector  in  the  EU  are  estimated  to  be  dependent,  to 
some extent, on the catches made in Greenlandic waters and processed in the EU. 

The number of vessels taking  up authorisations  in  Greenlandic waters declined slightly 
from 10 to 8 over 2021 to 2023, but with 8 vessels typically actually fishing each year, 
and  investments  in  German  vessels  in  recent  years  underscores  the  importance  of  the 
agreement and the opportunities it provided. 

Catches  by  EU  vessels  of  cod,  redfish,  Greenland  halibut,  grenadier,  and  Northern 
prawns in Greenlandic waters in 2021 accounted for around 50% of the total EU catches 
for those species. The agreement also allowed for (unquantifiable) additional EU catches 
in Norway and the Faroe Islands.  

2.b  Level  of  fees  paid  by  EU  vessel  owners  for  their  fishing  activities  is  fair  and 
proportionate to costs and revenues, and non-discriminatory 

of 

flag.  This 

As outlined in Section 3.2 and 3.3 of this evaluation, fishing by other foreign countries is 
generally  subject  to  similar  conditions,  with  legislation  applying  to  fishing  vessels 
irrespective 
technical 
conditions/regulations. In line with the SFPA text (Article 3.3 and 3.4) Greenland makes 
available information about the overall TAC and fishing opportunities to foreign fleets. It 
is  expected  that  foreign  fishing  vessels  would  not  pay  for  fishing  opportunities 
originating from Greenland’s other agreements as these agreements operate on the basis 
of  a  mutual  exchange  of  fishing  opportunities,  rather  than  financial  compensation  for 
access to fishing opportunities in the case of the EU–Greenland SFPA. 

to  Greenlandic 

certainly 

applies 

Shipowners pay  authorisation fees which range for different  species between 3.2% and 
15.2% of landed prices in the EU.  

2.c. Ensure supply for the EU market. 

EU  catches  of  14  000  –  15  000  tonnes  per  year  in  Greenlandic  waters  during  2021  to 
2023  made  only  small  (0.14%)  contributions  to  EU  market  supplies,  when  considering 
total supplies to the EU market and apparent consumption of around 10.6 million tonnes 
of fish in 2021. However, cod landed and processed in Iceland is typically destined for 
the EU market, redfish and Greenland halibut is mainly destined for the EU market with 
some  sold  to  Asia,  and  around  10%  of  prawns  caught  in  Greenland  and  processed  in 
Europe (e.g. Denmark) are for the EU market (with the balance sold to a wide variety of 
international  markets).  Supplies  made  available  to  the  EU  market  through  EU 
opportunities in Norway are an additional benefit of the agreement. 

40 

 
 
2.d  Encourage  the  creation  of  a  favourable  environment  for  private  investment  and 
economic activities that contribute to the sustainable development of the partner country 
and strengthen its cooperation with the EU. 

On encouraging cooperation between economic operators, investment by EU shipowners 
in  the  types  of  vessels  required  to  take  up  fishing  authorisations  to  fish  in  Greenlandic 
waters is very considerable, and having certainty over access to quota is thus critical. The 
current Protocol only lasts for four years (with the potential to extend it by a further two 
years,  which  has  not  been  agreed)  and  will  tacitly  expire  less  than  four  years  after  it 
started. This is not creating the secure business environment required by EU shipowners. 

EU vessels support  economic activity in  the EU  ports in  which they  are  based or visit, 
through the purchase of goods and services, and through the supply of some catches for 
processing in the EU. EU catches in Greenlandic waters made important contributions as 
raw material inputs to the EU processing sector - only cod caught in Greenlandic waters 
was  processed  in  Iceland,  and  around  30%  of  Northern  prawns  caught  in  Greenlandic 
waters  was  processed  outside  of  Europe  (mostly  in  Greenland),  with  other  EU  catches 
processed in Europe. 

There  have  been  no  temporary  joint  ventures  in  Greenland  for  Protocol  species,  even 
though the Protocol allows for them. The notion of joint ventures may be more applicable 
to SFPAs with developing countries and an objective to support the development of the 
third country sector, given that Greenland’s domestic fishing sector is already relatively 
well developed. In addition, EU stakeholders suggest that the procedure for establishing a 
temporary  joint  venture  (Chapter  V,  Section  1  of  the  Annex  to  the  Protocol)  would  be 
unlikely to be fast enough to allow for such an initiative to catch uncaught Greenlandic 
quota in a specific year (which would be the focus of EU interest in such a venture). 

Objective  3:  To  support  the  development  of  a  sustainable  fisheries  sector  in  partner 
countries (through the governance framework that the Agreement creates and through the 
sectoral support; cooperation on blue economy, to the small scale and artisanal fisheries, 
to direct and indirect job creation, development of the local and national sectoral policies, 
etc.) and analysis of geographic, social, environmental, and economic impacts. 

3.a Contribute to social, environmental, and economic development in Greenland. To 
what  extent  the  SFPA  and  the  activities  implemented  with  the  EU  contribution  for 
sectoral  support,  have  generated  significant  positive  /  unintended  /  longer  term  / 
broader effects? 

All of the EU catch of Northern prawns in West Greenland are landed and processed in 
Greenland  even  though  there  is  no  mandatory  requirement  for  any  EU  catches  to  be 
landed in Greenland. No other EU catches are landed in Greenland or supply its domestic 
market. This is explained by the fact that apart from the Danish vessel fishing for prawns 
in  West  Greenland, other EU vessels  generally do not  visit  Greenlandic  ports, due to  a 
lack of landing sites in East Greenland where most EU vessels fish. 

Upstream  benefits  to  Greenlandic  enterprises  take  the  form  of  purchases  and  services 
made by the Danish  prawn vessel fishing  out  of Nuuk, which totalled around EUR 2.7 
million  in  2023.  Other  vessels  fishing  in  East  Greenland  do  not  generally  visit 
Greenlandic  ports  due  to  the  lack  of  ports  in  the  East  of  the  country.  Downstream 
activities in Greenland resulting from the agreement are relatively limited as most of the 

41 

 
  
fish caught under the framework of the SFPA/Protocol supplies the EU market and/or the 
EU  processing  industry.  Nevertheless,  the  agreement  is  estimated  to  generate  around 
EUR 3.6 million per year in combined upstream and downstream indirect value added for 
the Greenland economy (in addition to access fees and direct value added in the form of 
crew wages). 

As noted above, there have been no temporary joint ventures in Greenland for Protocol 
species, even though the Protocol allows for them. 

With  regards  to  the  sectoral  support  component,  EU  funding  makes  significant 
contributions  to  social,  environmental,  and  economic  development  in  Greenland.  The 
support for inshore fisheries is notable (with a potential economic and social benefit), as 
is the role of sectoral support funding in improving governance and the functioning of the 
fisheries  sector  through  scientific  research  and  control  of  fishing  activity  in  support  of 
environmental sustainability. 

3.b  Contribute  to  strengthen  capacities  of  Greenland  to  monitor  and  control  fishing 
activities and to promote sustainable fishing practices in its waters.  

As  outlined  in  Section  3.4  of  this  evaluation,  sectoral  support  funding  provided  by  the 
agreement has achieved considerable results, across three main areas: administration and 
management  (by  the  Ministry  of  Fisheries  Hunting  and  Agriculture);  control  and 
enforcement (by GFLK); and scientific research and advice on stock status (by GINR). 
EU  sectoral  support  funding  as  a  share  of  total  government  expenditure  on  these  three 
areas contributed 46%, 24% and 22% respectively over the period 2021 - 2022, or 26% 
of total government expenditure in the fisheries sector over the same period . The sectoral 
support contributes to training and equipment in support of both science and MCS. 

The  Greenlandic  authorities  prepare  a  detailed  annual  status  report  each  year  on  the 
achievements in meeting pre-defined targets related to activities under each of the three 
main areas of funding. Specific targets for related indicators set in the annual matrices are 
generally achieved and if not, are explained by the authorities. Activities and purchases 
funded though the sectoral support are in line with the mandates and responsibilities  of 
the three organisations concerned. 

In  some  minutes  of  the  Joint  Committee,  it  has  been  noted  that  actual  expenditure  has 
slightly exceeded total budgets, but divergence is identified in the matrices, explanations 
have  been  provided  by  Greenland,  and  EU  contributions  were  not  increased.  It  is  also 
noted  that  there  is  no  fisheries  attaché  in  Greenland  to  monitor  sectoral  support 
implementation, or any office of the EU. 

3.c Assessment of results obtained in terms of impacts 

Implementation  of  the  impact  of  sectoral  support  is  jointly  monitored  by  the  Joint 
Committee, on the basis of supporting documents supplied by the Ministry of Fisheries, 
and through technical missions of the EU dedicated to monitoring technical support.  

Importantly,  the  reports  and  documentation  provided  by  the  Ministry  of  Fisheries 
generally identify the activities implemented and the main challenges encountered by the 
national authorities, but there is room for improvement in their analysis of economic and 

42 

 
  
  
 
 
  
  
 
 
social  benefits.  It  should  be  noted,  however,  that  the  Protocol  does  not  specifically 
address the need to address this dimension.  

3.d Promote employment of local fishers and create direct and indirect employment in 
Greenland. To promote decent working conditions in the fisheries sector. 

The Protocol was important for the EU fleet in terms of employment creation, supporting 
around 177 jobs onboard vessels, with 168 of those being for EU nationals. Additionally, 
around  600  jobs  in  the  processing  sector  in  the  EU  are  estimated  to  be  dependent,  to 
some extent, on the catches made in Greenlandic waters and processed in the EU.  

Employment of Greenlandic nationals on EU vessels is estimated to be around 5 people, 
working  under  decent  working  conditions.  As  noted  above,  all  of  the  EU  catch  of 
Northern prawns in West Greenland are landed and processed in Greenland, which along 
with port visits generates onshore employment in Greenland. 
Efficiency: to what extent were the expected effects achieved at reasonable costs?  

In terms of the cost-benefit for the EU, Rates of utilisation of EU quota by the fleet are 
very  high  averaging  95%  for  all  species  over  the  period  2021  –  2023.The  financial 
contribution to Greenland by the EU and EU shipowners in 2021 - 2023 averaged EUR 
20.58 million a year (compared to EUR 15.3 million a year during the last Protocol), with 
slightly  less  than  EUR  3  million  per  year  being  for  sectoral  support,  and  the  balance 
financial compensation for access. These payments allowed for catches by the EU fleet in 
Greenland waters of EUR 152 million over the years 2021 - 2023 (compared to EUR 193 
million over 2016 – 2018), plus additional catches in Norwegian and Faroese waters. 

The average access cost per tonne of fish caught in Greenland was EUR 945, with EUR 
741 paid by the EU (and the balance by private sector operators). EU payments of EUR 
30.7 million over 2021 - 2023 related to catches made in Greenland waters by EU vessels 
(not additional payments for quota transferred to Norway) represented 18.1% of the catch 
revenue  by  EU  vessels  when  fishing  in  Greenland.  Concerning  cost-benefit  ratios  in 
relation  to  GVA,  every  EUR  1  invested  from  the  EU  budget  in  the  compensation 
payment  for  access,  supports  the  creation  of  EUR  6.88  of  value  added.  This  is  shared 
between  the  EU  (EUR  4.23),  Greenland  (EUR  2.13)  and  third  country  entities  (EUR 
0.52). 

In terms  of  the cost-benefit for EU operators,  aggregated shipowner  catches  totalled 
41  455  tonnes  over  2021  –  2023  (compared  to  42  579  tonnes  during  the  last  Protocol 
over  2016  –  2018),  valued  at  EUR  152  million.  Access  fees  paid  by  EU  vessels 
represented  5.6%  of  their  income  from  the  aggregated  catches  over  the  2021  -  2023 
period    (compared  to  3.3%  over  2016  –  2018).  Access  fees  as  a  percentage  of  value 
added were 8.8% over 2021 – 2023 (compared to 6.8% over 2016 – 2018). 

The costs of access were therefore a relatively small part of the overall cost structure for 
EU vessels, and the Protocol can be considered as efficient from the perspective of EU 
vessel  operators,  generating  a  gross  profit  from  catches  in  Greenlandic  waters  of  EUR 
21.0 million per year on average over the 2021 - 2023 period. 

43 

 
 
In term of the cost-benefit of the actions of sectoral support, as already noted, and as 
discussed more fully in previous sections, specific targets for related indicators set in the 
annual  matrices  are  generally  achieved  or  exceeded,  and  where  not,  reasons  are 
articulated in the annual reports prepared by the Greenlandic authorities. Data show that 
all  EU  budgeted  sectoral  support  funds,  were  fully  utilised  in  2021  and  2022  and  are 
expected to be fully utilised also in 2023. 

In  terms  of  financial  compensation  for  fishing  opportunities  benefits  the  EU  and 
Greenland,  Greenland  received  compensation  for  access  from  the  EU  and  shipowners 
equivalent  to  25.8%  of  the  average  price  at  first  sale  of  the  fish  caught  in  Greenland 
under the Protocol over 2021 – 2023. For catches made in Greenlandic waters, Greenland 
received  30.9%  of  the  total  value  added.  When  also  considering  catches  made  by  EU 
vessels in Norway following transfers enabled by the Protocol, this figure is 24.6%. Total 
GVA  generated  for  Greenland  in  Greenland  is  calculated  at  slightly  over  EUR  65.3 
million  over  the  period  2021  -  2023  with  94%  of  that  figure  being  from  the  access 
payments.  Greenland  also  benefits  to  a  small  extent  in  terms  of  direct  GVA  from  the 
activities  of  EU  vessels,  through  small  numbers  of  Greenlandic  crew  employed,  and 
some  limited  indirect  GVA  in  upstream  and  downstream  activities  related  to  the  EU 
vessel  fishing  for  Northern  prawns  in  West  Greenland  which  lands  into  Nuuk  and  is 
partly  supplied  by  Greenlandic  companies.  The  Greenlandic  economy  obtained  EUR  1 
576 of GVA per tonne of fish caught by EU vessels in its fishing zone over the period 
2021 - 2023, equivalent to EUR 1.23 of GVA per EUR 1 paid by the EU in exchange for 
access (not accounting for sectoral support, and excluding quota transferred by the EU to 
Norway).  

The financial compensation is absorbed with central government revenue/income, to be 
spent  as  part  of  the  national  budget  benefitting  all  regions  and  social  groups  in  the 
country. 

Coherence 

Overall,  the  current  implementing  Protocol  is  coherent  and  cooperates  positively  with 
other EU interventions and contributes to the priorities identified by both Parties.  

On  coherence  with  the  CFP  in  general  and  with  its  external  dimension  and  the 
regional fisheries policy, the SFPA and Protocol are coherent with the objective of the 
common fisheries policy (CFP), as set out the ‘Basic Regulation’1, to ensure that fishing 
activities  are  environmentally,  economically,  and  socially  sustainable  and  are  managed 
consistently with the objectives of achieving economic, social and employment benefits, 
and of restoring and maintaining fish stocks above levels which can produce maximum 
sustainable yield and that they are contributing to the availability of food supplies. The 
current  Protocol  is  consistent  with  the  CFP  objectives  since  it  safeguards  the  Union’s 
interests in terms of access rights and conditions, and it is coherent with CFP objectives 
of sustainability.  
The Protocol is also fully coherent with both Regulation on the sustainable management 
of external fishing fleets (SMEFF)19, and Regulation (EU) 2023/2842 as regards fisheries 
control. 
At  regional  level,  the  SFPA  and  Protocol  contribute  to  the  EU  objectives  of  good 
regional management of shared stocks, through: 

− 

the  agreement  of  quotas  for  the  EU  within  the  context  of  overall  regional 
agreement, and 

44 

 
 
 
− 

 the engagement by Greenlandic  authorities with NAFO  and NEAFC  (enhanced 
through the sectoral support).  

And  they  contribute  to  the  objective  of  providing  a  regional  network  of  fishing 
opportunities for the EU fleet, not just in Greenlandic waters, but also in Norway through 
the quota transfers with those third countries. 
As mandated by the CFP Regulation, SFPAs and their underlying texts reflect a stronger 
emphasis  than  older  generation  of  FPAs  on  human  rights,  combatting  IUU  fishing, 
supporting development of Sustainable Development Goal 14 ‘Life below water’, and on 
SFPAs being limited to surplus catches. The introduction of the SFPA in 2021 to replace 
the previous FPA thus increased coherence of the agreement with EU policy.  
On  coherence  with  the  other  EU  policies,  the  Protocol,  with  the  emphasis  on 
cooperation  and  sustainable  exploitation  of  resources,  is  in  line  with  the  Joint 
Communication by the European Commission  and high  representative of the Union for 
foreign  affairs  and  security  policy  on  a  stronger  EU  engagement  for  a  peaceful, 
sustainable  and  prosperous  Arctic,  which  focuses  on:  contributing  to  maintaining 
peaceful  and  constructive  dialogue  and  cooperation;  addressing  the  ecological,  social, 
economic  and  political  challenges  arising  as  a  consequence  of  climate  change;  and 
supporting the inclusive and sustainable development of the Arctic regions to the benefit 
of its inhabitants.   

It is coherent with the Joint Declaration by the European Union and the Government of 
Greenland  and  the  Government  of  Denmark,  on  relations  between  the  European  Union 
and Greenland, signed in Brussels on 19 March 2015, which committed to strengthening 
relations  and  cooperation  based  on  broadly  shared  interests  and  to  endow  their  mutual 
relations with a long-term perspective. 
 It  is  coherent  with  the  Decision  on  the  association  of  the  Overseas  Countries  and 
Territories  (OCTs)  with  the  European  Union22  to  support  sustainable  development  and 
diversification  of  Greenland’s  economy.  The  decision  has  objectives  to:  foster  and 
support  cooperation  with  OCTs,  including  in  addressing  their  major  challenges  and 
reaching the SDGs; and support and to cooperate with Greenland in addressing its major 
challenges such as the raising of education level and to contribute to the capacity of the 
administration of Greenland to formulate and implement national policies.  
Under the Decision, Greenland has a wide-ranging political and policy dialogue with the 
EU, receives funding, and has preferential trade arrangements to access the EU market. 
Greenland  is  one  of  the  largest  recipients  of  EU  support  per  capita  in  the  OCTs  (EUR 
225 million foreseen between 2021 and 2027). 
 SFPA/Protocol  objectives  are  consistent  with  the  first  common  objective  stated  in  the 
2006  Joint  Declaration  by  the  EU  and  the  Governments  of  Greenland  and  Denmark, 
namely  cooperation  in  sustainably  managing  fish  stocks  and  the  environment  and 
provision  of  fishing  opportunities  for  EU  fishing  vessels.  The  Protocol  has  supported 
capacity  building  through  contributing  to  the  training  of  personnel  in  Greenlandic 
authorities responsible for fisheries policy, management, and control through the sectoral 
support programme.  

On Greenlandic fisheries policy and other related national policies, the objectives of 
the  SFPA/Protocol  are  fully  coherent  with  the  main  objectives  of  Greenland’s  fisheries 

22 Council Decision (EU) 2021/1764 of 5 October 2021 on the association of the Overseas Countries and 
Territories with the European Union including relations between the European Union on the one hand, 
and  Greenland  and  the  Kingdom  of  Denmark  on  the  other  (Decision  on  the  Overseas  Association, 
including Greenland) (OJ L 355, 7.10.2021, p. 6–134) - http://data.europa.eu/eli/dec/2021/1764/oj 

45 

 
  
 
policy. These are to ensure the largest possible, long-term socio-economic beneﬁts from 
ﬁshing on a sustainable basis, and that ﬁsheries legislation and other relevant initiatives 
create coherent, stable framework conditions that reduce uncertainty and hence create an 
attractive investment climate for the beneﬁt of further development of the industry. The 
SFPA  and  Protocol  are  also  coherent  with  Greenland’s  underlying  policy  principles  of 
biologically  sustainable  exploitation  of  ﬁshery  resources  to  ensure  reproduction  and 
optimal  utilization,  and  appropriate  output  limitation  (TAC  and  quotas)  and  input 
limitation  in  the  form  of  capacity  regulation  to  create  a  stable  and  lasting  balance 
between the ﬁshing ﬂeet's capacity and its ﬁshing opportunities over a longer period. 

The EU’s sectoral support made substantial contributions to activities over 2021 - 2023 
to ensure that Greenland can achieve the objectives and priorities of its fisheries policy, 
and to updating the Fisheries Act. 

4.2 How did the EU intervention make a difference and to whom? 

EU Added Value 

The current implementing Protocol mostly responds to the needs of both Parties through 
the  interventions  provided  for  under  the  access  and  sectoral  support  components.  The 
EU's added value lies mainly in the following three elements: 

•  The additional value resulting from the EU intervention under the Protocol, compared 
to the absence of Protocol. To what extent would Member States have had the ability 
or possibility to put  in place appropriate alternative measures? To what  extent have 
the overall benefits of the Agreement and Protocol had an added value for the EU?; 

In the absence of a Protocol but with the SFPA in force, EU shipowners would have been 
prevented from negotiating direct  access  due to  the exclusivity principle:  Article 5.3 of 
the SPFA states that Union vessels can only engage in fishing activities in Greenland if 
they  hold  a  fishing  authorisation  issued  under  the  Agreement.  However,  even  if  the 
SFPA was not in place along with the absence of a Protocol it would be likely that EU 
shipowners would have found it difficult to negotiate access to Greenlandic waters with 
the Greenlandic authorities, given pressure from the Greenlandic private sector to fish for 
quota currently allocated to the EU. 

 Compared to both scenarios: 

1.  The Protocol therefore allows EU vessel access to Greenlandic (and Norwegian) 
waters  that  would  otherwise  not  be  the  case,  generating  considerable  and 
additional  value  to  the  EU  fleet  in  terms  of  catches  of  species,  which  are 
important  for  the  fleet  as  evidenced  by  high  authorisation  rates  and  catches 
compared to the quota offered to the EU by Greenland. 

2.  The  EU  intervention  adds  value  in  terms  of  the  following  features  of  the 
Agreement,  which  would  have  been  difficult,  if  not  impossible  to  generate 
otherwise: 

−  dialogue and direct  exchange between EU  and Greenlandic  authorities, in  terms 
of scientific cooperation and a framework for joint monitoring and control of EU 
activities. 

−  promotion  of  responsible  fishing  practices,  including  more  transparent  access 

conditions.  

46 

 
 
−  coherence with EU policies. 
− 

financing of actions aimed at achieving the objectives of the Greenlandic sectoral 
policy. 

 On the last point, the high  additional value of EU involvement is  demonstrated by the 
100% absorption of the sectoral support funding and the amounts of funding involved (at 
just  under  EUR  3  million  a  year),  and  the  significant  proportion  of  national  budget  for 
fisheries that is provided for by the sectoral support (26% over 2021 - 2022). 

•  The additional value resulting from the EU intervention under the Agreement and the 
Protocol,  compared  to  what  could  be  achieved  by  the  Union  fleet  outside  the 
framework of the Agreement; 

EU vessel operators that are provided with quota through relative stability keys express a 
preference  for  accessing  Greenlandic  waters  through  the  mechanism  of  the  Agreement 
and  the  Protocol.  Those  EU  operators/MS  that  do  not  receive  quota  through  relative 
stability keys might be expected to prefer private agreements as this might enable them to 
access quota. 

An element of uncertainty remains for the EU operators given the way that the Protocol 
includes  indicative  quota  that  is  mutually  agreed  between  Greenland  and  the  EU  each 
year,  and  which  may  and  often  does  vary  from  the  indicative  quota.  Nevertheless, 
variations  from  indicative  quota  are  not  normally  significant  (apart  from  capelin).  The 
Protocol  thus  provides  a  more  stable  environment  and  guaranteed  lawful  access  to  the 
Greenlandic  fishing  zone  over  a  4-year  period  than  would  be  the  case  under  private 
agreements.  

The  strong  uptake  of  authorisations  is  reflective  of  vessel  owner  satisfaction  with  the 
Protocol,  and  while  the  costs  of  operating  under  private  agreements  cannot  be  known, 
data  provided  earlier  have  shown  that  the  cost  of  access  paid  by  vessel  owners  to 
Greenland,  as  negotiated  by  DG  MARE  and  included  in  the  Protocol  as  authorisation 
fees, are not prohibitive.  

 EU  vessel  owners  recognise  the  benefits  the  Protocol  has  in  supporting  sustainability 
which  ultimately  benefits  them,  as  well  as  the  positive  role  that  the  EU  plays  in 
negotiating on behalf of EU MS and the benefits of a Protocol in protecting quota, given 
pressure within Greenland by its private sector for quota. 

Acceptability23 

•  To what extent are the EU shipowners satisfied with the Protocol? 

EU  shipowners  fishing  in  Greenlandic  waters  under  the  Protocol,  and  consulted  during 
this  evaluation,  expressed  very  strong  support  for  renewal  of  the  Protocol  given  its 
strategic importance in terms of their overall fishing strategy and the benefits it facilitates 
in terms of gross value added and employment.  

No  major  concerns  were  expressed  over  the  content  of  the  technical  and  financial 
conditions of the Protocol.  

23 For a full report of the consultations conduction, see Annex 6 of the evaluation study. 

47 

 
  
  
 
However,  shipowners  identified  a  number  of  issues  which  if  addressed  would  enhance 
their satisfaction with the Protocol even further. These included: 

−  sharing of bycatch information by Greenland (as required for EU vessels) which 

would advance research. 

−  a longer Protocol (6 years minimum), given the necessary investments made by 

EU vessels and the need for certainty. 

− 

−  experimental fisheries for prawn in northern areas which are opening up due to 
less ice cover. Currently no experimental fisheries for Protocol species are 
possible, but consideration could be given to areas north of a certain latitude 
where such fisheries could be allowed. 
if quotas are not fully utilised by the year end, paid authorisation fees could be 
credited or transferred to the following year. 
increased  flexibility  regarding  vessel  entry  and  exit  from  the  Greenland  zone, 
especially concerning vessels carrying fresh catches.  
increasingly flexibility arrangements for Northern prawns to be better aligned 
with conditions applying to Greenlandic vessels in being able to roll over quota 
until the end of April in the following year. 

− 

− 

−  revision of reference prices specified in the Protocol during the Protocol to better 

align them with market prices. 

•  To  what  extent  is  the  Protocol  developed  in  consultation,  coordination  and 

supported by the civil society in the EU and nationally and locally? 

There  are  few  civil  society  organisations  in  Greenland  involved  in  the  fisheries  sector. 
The Greenland Business Association noted in its response to consultation that it was not 
in favour of the SFPA/Protocol or its renewal, given that Greenlandic vessels could catch 
quota which is  allocated to  the EU. It  did  not  however have specific concerns over the 
technical  clauses  in  the  Protocol  aimed  at  supporting  environmental  sustainability, 
although  commented  on  levels  of  EU  bycatch  quota  suggesting  these  were  high.  The 
fishers and hunters’ association (KNAPK) did not respond to  consultation requests, but 
during the last evaluation expressed general satisfaction with the Protocol and supported 
its  renewal.  Inshore  fisheries,  and  KNAPK  specifically,  receive  direct  funding  through 
the  sectoral  support  programme.  They  recognised  at  that  time  (2019)  that  the  EU 
allocation  is  from  offshore  quotas  and  so  not  directly  impacting  their  fishing 
opportunities. Also, the taxation of the offshore sector goes to central government, with 
no certainty that the EU quota share going to Greenlandic offshore vessels instead would 
result in increased support to the inshore sector. However, the organisation wished to see 
greater emphasis through the sectoral support on funding for the inshore fishery (not just 
for  investment  in  inshore  vessels/dinghies,  but  rather  in  education  and  in  funds  to 
increase the ability of inshore fishermen to access inshore quota, which are reported to be 
quite consolidated with/in larger companies). 

 Civil  society  organisations  in  the  EU  were  approached  for  their  views  during  this 
evaluation,  but  none  responded.  This  may  be  suggestive  of  the  fact  that  that  these 
organisations have no major concerns over the Protocol, or just that are more interested 
in Agreements with developing countries. EU civil society organisations are part of the 
Long-Distance  Advisory  Council  (LDAC)  working  group  on  Bilateral  Relations  with 
Third Countries and are thus afforded the opportunity through working group meetings to 
engage  with  the  European  Commission  about  the  Protocol,  its  implementation,  and  its 
possible renewal. 

48 

 
  
•  To what extent is the Protocol supported by the sector (ship owners, traders, and 

processors) in Greenland 

Greenlandic shipowners of larger vessels operating in the offshore fishery, are in direct 
competition  for  quota  allocated  to  the  EU.  The  Greenlandic  offshore  private  sector 
recognises that a renewal of the Protocol is likely for political reasons but considers that 
Greenlandic  companies  have  the  capacity  to  catch  EU  quota  themselves  (i.e.  they 
therefore  do  not  consider  there  to  be  a  surplus).  They  would  wish  however  for  the 
indicative quota specified in the Protocol to be reduced. The previous evaluation in 2019 
also noted that they commented that EU quota transferred to Norway does not result in 
any authorisation fees to the Greenlandic Government when Norwegian vessels take up 
authorisations  for  that  quota,  and  that  the  Government  could  make  more  money  from 
taxing catches made by Greenlandic companies if they were allocated additional quota. 

•  To what extent are the Greenlandic and EU MS administrations, satisfied with the 

implementation of the Protocol? 

The  Greenlandic  authorities  are  generally  satisfied  with 
its 
implementation, and with the good working relations with the EU which are important for 
successful 
the  benefits  of  good  geo-political 
relationships with the EU that are enabled by the SFPA/Protocol and seek its renewal. 

implementation.  They  recognise 

the  Protocol  and 

While  recognising  that  the  Greenlandic  authorities  and  the  Commission  may  have 
differing  views  when  it  comes  to  negotiating  the  Protocol,  during  implementation  there 
appears  a  good  spirit  of  partnership  and  collaboration  between  the  two  parties,  good 
levels of communication, and the Joint Committee functions well.  

Greenlandic  authorities  are  satisfied  with  the  sectoral  support  funding  provided  and  its 
use  on  the  three  main  priority  areas  and  recognise  the  benefits  of  it.  They  are  also 
satisfied  with  most  the  technical  clauses  of  the  Protocol  and  the  respective  obligations 
those place on the Government, on the EU, and on EU shipowners. However, they: 

−  do  not  support  fixed  reference  prices  and  would  prefer  for  implementation  to 
include a mechanism to adjust the price levels at least once in the Protocol period 
to reflect market prices. 

−  commented that for some species when scientific advice results in reduced overall 
quota, quota reductions for the EU fleet are less than for Greenlandic vessels. 
−  observed  that  the  process  of  accepting  capelin  offers  means  that  when  the  EU 
does  not  accept  Greenland’s  offer  it  is  difficult  for  the  Greenlandic  fleet  to  fish 
any quota that they EU does not want to accept during the short season. 

−  commented  that  with  regards  to  observers,  reaching  the  required  observer 
coverage rate requires sacrificing manhours that could be allocated on control of 
the  coastal  fleet.  They  would  wish  more  dialogue  and  flexibility  about  observer 
coverage. 

−  suggested that the Joint Committee to discuss sectoral support could be conducted 

online. 

EU Member States are satisfied with the implementation of the Protocol, and the benefits 
of  the  partnership,  also  being  complementary  about  the  role  that  the  European 
Commission and Greenlandic authorities play. They seek its renewal. 

49 

 
  
  
 
 
 
4.3 Is the intervention still relevant? 

•  To  what  extent  the  original  objectives  of  the  SFPA/Protocol  still  correspond  to 

the needs of the EU and Greenland? 

For both the EU and the Greenlandic authorities, the objective of resource and  environmental 
sustainability  provided  for  by  the  SFPA  and  Protocol  is  highly  relevant  to  the  needs  of  both 
parties. There is a requirement of the legal texts to consider sustainability during the process to 
fix EU fishing opportunities. And the objective to improve scientific and technical knowledge in 
Greenland,  enhanced  through  the  sectoral  support  funding,  further  helps  to  ensure  that  the 
requirement for sustainability is supported. 

For Greenlandic shipowners, providing access to the EU fleet to Greenlandic waters through the 
SFPA  and  the  Protocol  is  becoming  less  relevant  over  time,  as  the  Greenlandic  fleet  is 
increasingly capable of catching fish resources in Greenlandic waters given investments in new 
vessels.  In  this  sense  the  needs  of  the  EU  and  Greenlandic  shipowners  are  potentially  and 
increasingly opposed. However, the EU agreed quota represents only a small proportion of total 
Greenlandic quota for concerned species. 

The  SFPA  and  Protocol  are  relevant  to  the  needs of EU  shipowners  in  providing  access  to  the 
Greenlandic  fishery  zone  for  a  part  of  the  EU  fleet,  and  through  the  transfer  of  EU  quota  in 
Greenland to Norway which allows the EU fleet access to Norwegian waters in return. The SFPA 
and Protocol are most relevant to the needs of German and Danish fleet operating in Northern 
waters and are also relevant to Estonia and Lithuania who can access to quota through intra-EU 
MS quota swaps. The SFPA/Protocol are also relevant to the needs of Germany, Spain, France 
and Portugal who gain access to Norwegian waters through the quota transfers between the EU 
and Norway. 

Supporting the development of a sustainable fisheries sector in Greenland remains relevant to 
needs  in  Greenland  and  is  provided  for  in  the  SFPA/Protocol  through  the  sectoral  support 
funding and the  potential for joint ventures. However, are noted above,  Greenland’s fisheries 
sector,  especially  its  offshore  sector  which  is  now  technologically  advanced,  efficient,  and 
generating tax revenues for the government, has developed considerably over recent decades, 
and  recent  private  sector  investments  in  the  sector  and  the  existing  status  of  the  domestic 
fishery  are  evidence  that  the  need  to  develop  the  domestic  sector  is  declining,  except  in 
supporting  an  enabling  environment  provided  by  its  government.  In  association,  for  the 
Government  of  Greenland  the  ability  to  extract  resource  rent  through  taxes  from  its  own 
increasingly  developed  domestic  sector  when targeting  the  same  stocks  as  EU  vessels, means 
that  in  purely  financial  terms  the  needs  of  Government  for  the  financial  compensation  for 
access has reduced. However, the Government of Greenland views the SFPA and Protocol not 
just  in  financial  terms,  and  the  agreement  remains  highly  relevant  to  the  Greenlandic 
government  in  terms  of  contributing  to  its  objective  to  improve  fisheries  governance  and  to 
retain close cooperation and good relations with the EU. 

•  To what extent is the Agreement relevant to the policy objectives of RFMOs and 

to the EU's regional relations with other northern partners? 

50 

 
The Protocol includes a provision for mackerel quota to EU vessels, should Greenland be part of 
a CSA for mackerel and set quota based on agreement between all Coastal States (UK, Norway, 
the  EU,  the  Faroe  Islands,  Iceland,  and  Greenland).  There  is  currently  and  still  no  such 
agreement on quota distribution between the Coastal States, although they do jointly agree to 
TAC (which for 2024 is in line with scientific advice).   

The  SFPA/Protocol  contributes  to  the  objectives  of  the  Artic  Council  and  to  building  relations 
between  the  EU  and  other  parties  to  it,  and  it  contributes  to  the  sustainability  objectives  of 
NAFO  and  NEAFC,  both  RFMOs,  through  the  sectoral  support  which  allows  Greenlandic 
scientists to engage with ICES, NEAFC and NAFO. 

The SFPA and Protocol are relevant to the needs of both parties, with a strong emphasis 
on  sustainability.  However,  there  are  tensions  between  the  competing  needs  of  the 
Greenlandic and EU private sector fishing fleets for access to resources, a reduced need 
to  support  development  of  the  Greenlandic  private  sector  (due  to  success  in  its 
development),  and  in  purely  financial  terms,  less  relevance  for  the  Greenlandic 
government on the financial compensation for access. However, the agreement remains 
relevant to the Greenlandic government in the broader sense in terms of contributing to a 
sustainable development of its fisheries sector and maintaining levels of cooperation with 
the EU. 

The  Protocol,  contributes  to  the  objectives  of  RFMOs  and  other  regional  organisations 
and helps to foster EU relations with them. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1 Conclusions 

As for the conclusions, the intervention, in the form of the SFPA and associated Protocol, 
was highly effective in meeting the 3 general objectives and 11 specific objectives. Nine 
of the 11 specific objectives evaluated through relevant success criteria were satisfactorily 
achieved.  Two  others  were  generally  achieved  but  with  some  issues  of  concern:  noting 
that  EU  quota  represents  a  relatively  small  proportion  of  Greenland  quota  (except  for 
Northern prawn stock in East Greenland ICES XIV and V) for most species, stock status 
has  not  improved  since  the  last  Protocol,  there  is  a  lack  of  up  to  date  and  robust 
assessments  for  several  stocks,  and  some  are  over-fished  or  subject  to  overfishing; 
additionally,  the  length  of  the  Protocol  does  not  provide  a  sufficiently  secure  business 
environment for EU shipowners. 
The  Protocol  was  highly  efficient.  Answers  to  all  four  evaluation  questions  suggest 
success  in  terms  of  value  for  money  for  the  EU,  value  for  money  for  EU  shipowners, 
sectoral  support  being  well  implemented  with  positive  economic,  environmental,  and 
social  impacts  at  a  reasonable  cost,  and  the  good  benefits  to  Greenland  in  terms  of  the 
revenues  and  value  added  generated  by  allowing  EU  vessels  access  to  its  fisheries 
resources. 

There  was  a  high  level  of  economy,  with  EU  sectoral  support  matching  well  with 
Greenland’s needs  and being fully absorbed, and with EU disbursements of the sectoral 
support financial contributions made in a timely manner consistent with the Protocol. 

 The  SFPA  and  Protocol  were  highly  coherent  in  terms  of  alignment  with  the  CFP  in 
general  and  with  its  external  dimension,  and  with  the  regional  fisheries  policy.  It  also 

51 

 
made an effective contribution to a wide range of EU policies for the region as well as to 
include  cooperation,  collaboration,  and  sustainable 
Greenland’s  policies,  which 
exploitation  of  natural  resources.  The  SFPA  and  Protocol  are  also  coherent  with 
Greenland’s  policy  priorities  in  terms  of  alignment  of  objectives  and  use  of  sectoral 
support funding. 

The EU added value of the intervention was high. Compared to any other mechanism 
for  gaining  fisheries  access  for  EU  vessels  to  Greenlandic  waters,  the  Agreement 
delivered a wide range of benefits to both EU and Greenlandic stakeholders in terms of 
sustainability  contributions,  transparency,  equity,  and  national  development.  The 
Protocol,  and the EU’s  role in  negotiating it, generated  considerable additional value to 
EU shipowners in terms of certainty over quota quantities provided. 

The  intervention  was  moderately  acceptable.  Globally  speaking,  the  EU,  EU 
shipowners,  and  the  Greenlandic  authorities  all  wish  to  see  a  new  Protocol.  However, 
many Greenlandic private sector interests  would  rather there was no Protocol,  and both 
the  EU  and  Greenland  consider  that  some  improvements  to  the  content  of  the  Protocol 
could be made. 

The  Protocol  was  moderately  relevant  to  the  needs  of  the  EU  and  Greenland,  with  a 
strong  emphasis  on  sustainability,  contributing  to  good  relations  between  the  parties 
which  are  needed,  and  to  the  objectives  of  RFMOs  (NAFO  and  NEAFC)  and  other 
regional organisations which helps to foster EU relations with them. However, there were 
tensions between the competing needs of the Greenlandic and EU private sector fishing 
fleets for access to resources. 

5.2 Lessons learned 

As for the lessons learned, the ex-post evaluation provides important lessons as follows: 

• 

Implementation  arrangements  for  the  Protocol  (access  and  sectoral  support 
components)  function  well,  having  evolved  over  time  and  being  based  on  good 
relations  between  the  EU  and  Greenlandic  authorities.  Along  with  many  of  the 
technical  clauses  and  requirements  of  the  Protocol,  they  do  not  therefore  need 
amendment. 

•  The SFPA/Protocol is of very high importance to the EU given the benefits derived, 
as  evidenced  by  the  high  rates  of  utilisation  by  the  EU  fleet  and  the  fishing 
opportunities that are provided in both Greenland and Norway through quota swaps. 
•  Greenland  also  benefits  considerably  in  financial  terms  from  the  financial 
compensation,  and  from  the  sectoral  support  funding.  However,  there  is  an 
increasing  ability  and  willingness  over  recent  years  by  Greenland’s  own  offshore 
sector 
technological 
advancements that have been made. 
Indicative  fishing  opportunities  provided  to  the  EU  have  been  decreasing  over 
successive  Protocols,  while  costs  for  access  paid  by  the  EU  (reference  prices)  and 
shipowners (authorisation fees) have been increasing. 

to  catch  Greenland  quota,  given 

investments  and 

the 

• 

•  Not  all  species  being  caught  under  the  Protocol  are  assessed  as  being  sustainably 

exploited and/or are subject to full analytical assessments of stock status. 

•  Reference  prices  in  the  Protocol  are  fixed  for  its  duration,  meaning  that  they  are 

unlikely to reflect market prices that change over time. 

52 

 
 
 
 
•  The  EU  is  typically  unable  to  utilise  indicative  or  offered  fishing  opportunities  for 

capelin due to timing issues. 

•  The length of the current Protocol (four years) could be increased to provide greater 

certainty to all related parties. 

•  The shared nature of stocks in the region that change in size and distribution, and the 
wishes  by  several  fleets  from  different  countries  to  exploit  them,  makes  joint 
agreement  and  management  of  stocks  and  fishing  opportunities  complex  when 
considered in light of the different interests by countries fishing in northern waters. 

6.  EX-ANTE EVALUATION 

The ex-ante evaluation of the current implementing Protocol provides a forward-looking 
perspective that is complementary to the ex-post evaluation. Expressly, it reflects on the 
lessons learned and outlines the possible ways forward, through a set of available policy 
options,  for  the  implementation  of  the  Sustainable  Fisheries  Partnership  Agreement 
between the EU and Greenland. 

6.1 Problem analysis and needs assessment  

In  the  context  of  the  intervention  logic  in  Figure  2,  this  section  outlines  the  possible 
current  and  future  needs  of  both  Parties  to  the  current  implementing  Protocol  and  the 
Agreement. 

Current and future needs of Greenland 

Greenland  needs  to  ensure  that  it  can  generate  revenue  from  its  fishery  resources, 
supporting  and  developing  its  inshore  and  offshore  sectors.  Furthermore,  the  country 
would benefit from landings of fisheries in Greenland so that downstream economic and 
social benefits are created. These needs can be mutually met with allocation of quota to 
its  offshore  sector,  taxation  of  the  offshore  sector,  and  use  of  resulting  government 
revenues to support the inshore sector. 

At the same time, the Greenlandic authorities are aware that the capacity of the country’s 
fishing fleet has increased, and it is possible that they will seek to accommodate internal 
demands  for  increased  quota  of  key  resources  to  its  own  vessels,  particularly  in  West 
Greenland. Nonetheless, the government appreciates alternative channels of revenue such 
as financial compensation provided for granting access to EU vessels which contributes 
to the diversification of Greenland’s revenue base.  

Regarding sectoral support, Greenland would prefer to continue receiving funds for the 
development of its fisheries sector, with priorities to be defined at a later stage.  

In  general,  Greenland  has  expressed  needs  for  aligning  the  Protocol  to  its  national 
legislation, ensuring coherence. Moreover, it is rather essential that the country continue 
to benefit from tariff-free access to the EU market that could be lost in case of a “non-
renewal” of the implementing Protocol.  

Current and future needs of the EU 

53 

 
 
In  the  event  of  a  new  Protocol  being  concluded,  the  interests  of  the  European  Union 
would be served if the two following needs are met: 

•  Alignment of the financial contribution for access with the demand of EU vessels: 
the high utilisation rate of the fishing opportunities provided for in the Protocol is 
an  indicator  of  the  high  demand  of  the  EU  fleet  for  access  to  the  Greenlandic 
waters  which  is  expected  to  be  the  case  also  in  the  future.  Nevertheless,  and 
pursuant to the requirements of the European Court of Auditors, it is essential for 
the EU to ensure that it avoids paying for fisheries access which is not utilised. 

•  With regard to sectoral support, the EU needs to ensure sound management of the 
funds,  following  the  recommendations  of  the  report  of  the  European  Court  of 
Auditors  in  its  2015  report  “Are  the  Fisheries  Partnership  Agreements  well 
managed  by  the  Commission”24:  i)  clearly  differentiated  from  overall  funding 
from other sources with respect to specific activities supported; ii) used in areas 
with  the  greatest  impact;  iii)  used  as  much  as  possible  for  activities  rather  than 
salaries;  iv)  assessed  through  a  robust  set  of  indicators;  v)  clearly  reported  on 
through detailed annual reports; and vi) guided by a multi-annual sectoral matric 
and annual matrices. 

Current and future needs of the EU fleet/processors/consumers 

The  EU  shipowners  have  a  clear  interest  in  a  new  Protocol.  Continued  access  to 
Greenland’s  EEZ  would  serve  to  support  a  network  of  regional  fishing  opportunities, 
both  through  the  fishing  opportunities  provided  in  Greenland,  and  through  the 
opportunities  that  are  provided  to  fish  in  Norway  in  exchange  for  those  third  countries 
being allowed to fish for EU quota provided under the EU/Greenland Protocol. Although 
the EU vessels fishing in Greenlandic waters are of a small number (typically 8 vessels 
per  year),  the  fishing  opportunities  provided  are  very  important.  Danish  and  German 
vessels  are  highly  dependent  on  fishing  under  the  Protocol,  while  for  others  fishing  in 
Greenland, for instance  Lithuanian and Estonian vessels, that are not  so  dependent,  the 
Protocol nevertheless offers fishing opportunities that are vital in contributing to catches 
made within northern waters more generally (e.g. NAFO, NEAFC, Norway, Iceland) and 
therefore  allow  for  year-round  activity.  A  failure  to  agree  a  new  Protocol  would  have 
very serious consequences for the EU fleet  in  terms  of the resulting  impacts  on fishing 
possibilities, fishing strategy, and reduced profitability. The EU shipowners would hence 
prefer to maintain or increase the amount of the allocated quota. 

Furthermore,  a  longer  Protocol  (6  years  minimum)  would  provide  for  a  more  secure 
investment climate for the EU operators as it would increase certainty. They would also 
prefer that authorisation fees do not increase in a new Protocol and that, in case of non-
utilised quotas, authorisation fees to be credited or transferred to the following year.  

Regarding level-playing field, the EU fleet needs to operate on a level playing field with 
other fishing nations active in Greenlandic waters. This is currently not the case as non-
EU foreign vessels fishing in Greenland for EU quota provided under the EU/Greenland 
Protocol, or for quota provided under mutual exchanges of opportunities with Greenland, 
do not pay authorisation fees (even though there is reciprocal access and quota transfers). 

24  Special  Report  No  11/2015:  Are  the  Fisheries  Partnership  Agreements  well  managed  by  the 

Commission? | European Court of Auditors (europa.eu) 

54 

 
 
As per the EU processing sector, it also has needs in raw material aquatic products which 
would be partially met  with  the maintenance or increase of fishing  opportunities in  the 
Protocol. Apart from cod, which is processed in Iceland, all other species provided for in 
the Protocol are processed in the EU with significant downstream effects, both in terms 
of economic (value added) and social (employment) benefits.  

EU consumers’ needs for the supply of fish are partly met by the Protocol, and there is a 
need for a continued supply of fish from Greenlandic (and Norwegian) waters by the EU 
fleet.   

6.2 EU added value  

The  EU  holds  exclusive  competence  to  negotiate  the  implementing  protocols  to  the 
SFPAs, in  accordance  with  Article 3 of the Treaty  on the  Functioning  of the European 
Union. In  addition  to  the added value outlined in  Section 4.2,  the EU’s involvement in 
the negotiation of a new implementing protocol also brings the following benefits: 

i. 

ii. 

a  mandate  from  the  EU  that  ensures  that  the  Protocol  and  its  implementation  are 
aligned  with  international  law  and  the  CFP  and  consistent  with  other  agreements 
concluded with partner countries in the region,  

the possibility for the EU to have an instrument to strengthen sectoral policy at sub-
regional level, which is facilitated by a network of agreements and EU interventions 
within NAFO and NEAFC, and  

iii. 

a  specific  instrument  of  bilateral  cooperation  with  Greenland,  and  its  interventions 
within NAFO and NEAFC. 

6.3 Policy and management objectives  

The objectives of SFPAs are guided by Articles 31 and 32 of the Basic Regulation on the 
CFP and the Council conclusions on the external dimension of the CFP. The objectives 
of  a  future  intervention  under  the  Fisheries  Partnership  Agreement  concluded  between 
the EU and Greenland must be based on the general and specific objectives (see Section 
2.1.1) which guide the EU’s intervention logic for all SFPAs. This intervention logic is 
outlined in Figure 2.  

6.4 Policy options, including associated risks  

Two options are available when the current implementing Protocol to the Agreement de 
facto expires on 31 December 2024:  

•  Option  A:  non  negotiation  of  the  Protocol  implementing  the  Agreement  when  the 

current implementing Protocol expires. 

•  Option  B:  negotiation  of  a  new  protocol  implementing  the  Agreement  with  two 

possible sub-options:  

o  Sub-option  B1:  negotiation  of  a  new  implementing  protocol  with  the  same 

conditions as the current Protocol (status quo) 

55 

 
o  Sub-option  B2:  negotiation  of  a  new  implementing  protocol  with  adjusted 

conditions  

6.4.1 Option A 

The  Agreement  becomes  dormant  without  an  implementing  protocol.  The  instruments 
provided  for  in  Articles  31  and  32  of  the  CFP  become  non  applicable,  except  for  the 
provision on the exclusivity clause which prevents EU vessels from accessing the fishing 
areas in Greenland. 

6.4.2 Option B 

Under option B, the EU and Greenland agree on the conclusion of a new implementing 
protocol  under  the  Agreement  for  a  new  multiannual  period.  The  conclusion  of  a  new 
protocol will make it possible to implement the tools provided for by the CFP to establish 
the  framework  under  which  EU  vessels  may  operate  in  Greenlandic  waters  and  to 
mobilise  an  EU  financial  contribution  for  access  and  sectoral  support.  The  financial 
contribution  in  question  will  be  the  result  of  a  negotiation  and  are  not  known  at  this 
stage. 

Sub-option B1  

Sub-option  B1  consists  of  negotiating  a  new  protocol  without  any  adjustment  to  the 
conditions of the current implementing Protocol (same conditions for the implementation 
of the access component and sectoral support, same financial commitments – status quo) 

Sub-option B2  

The main conclusions of the ex-post evaluation and the lessons learned suggest that there 
are  areas  for  improvement  in  the  conditions  of  the  current  implementing  Protocol.  The 
proposed adjustments would many address the following issues: 

•  Agreement  of  a  6-years  implementing  Protocol  (minimum)  to  ensure  a  safe 

business environment for EU shipowners 

• 

Improved quota alignment with scientific advice and better stock assessment 

•  The indicative bycatch quota offered to the EU would be reduced  

•  The  reference  prices  included  in  the  Protocol  should  better  reflect  the  actual 

market prices and, if necessary, readjusted mid-Protocol 

•  The fishing authorisation fees should reflect a fair contribution paid by the EU 

shipowners 

• 

If quotas are not fully utilised by the year end, paid authorisation fees could be 
credited or transferred to the following year 

Ability to roll over unutilised quota until the end of April of the following year and up 
to 10% 

56 

 
•  Experimental  fisheries  for  Northern  prawn  above  the  agreed  latitude  could  be 

envisaged, especially in West Greenland 

•  A slight increase of sectoral support funds could be considered  

6.5 Results and impacts  

As  presented  earlier,  some  of  the  expected  results  and  impacts  are  shared,  some  are 
specific to the EU, and some are specific to Greenland.   

6.5.1 Option A 

Under option A, EU vessels would no longer have access to the Greenlandic fishing zone 
as a result of the application of the exclusivity clause. The result from not having a new 
Protocol  between  the  EU  and  Greenland,  i.e.  Option  A,  would  be  the  loss  of  these 
benefits  to  the  EU.  The benefits  lost  from  not  being  able  to  fish  in  Greenlandic  waters 
would  be  compounded  from  the  associated  impacts  that  would  occur  under  Option  A 
from  the  reduced  possibility  for  the  EU  to  exchange  part  of  its  quota  in  Greenland  for 
quota in Norway. The implications of a failure to agree a new Protocol in terms of loss of 
access to Greenlandic waters, and potentially reduced access to Norwegian waters, would 
be  very  significant  for  the  EU.  It  would  cause  significant  disruption  to  the  fishing 
activities of the Member State operators involved.   

Option A is not therefore considered a good option in any sense for the EU if benefits are 
to be maintained, as EU vessels would be prevented from fishing in Greenlandic waters, 
either because private agreements with Greenland are not a possible if the SFPA were to 
remain in  force given the  exclusivity clause, or if the SFPA was denounced Greenland 
would be expected to allocate all quota to its domestic fleet. 

As  per  Greenland,  Option  A  would  result  in  a  lack  of  this  sectoral  support  and  a 
reduction in contributions to the financial capacity of Greenland to implement its national 
fisheries  policy.  Other  results  of  Option  A  would  include  cessation  of  financial 
contributions  by  the  EU  (based  on  reference  prices)  and  vessel  owners  (based  on 
authorisation fees). While Greenland could conceivably use quota not provided to the EU 
under  Option  A  in  quota  exchanges  with  other  countries,  the  direct  financial 
contributions  from  third  countries  (the  EU  in  this  case)  would  cease  as  other  countries 
fishing in Greenlandic waters do so under quota exchanges rather than based on financial 
contributions, and vessels from other countries fishing under Greenland’s agreements do 
not pay authorisation fees.   

Changes to the overall financial benefits to the Greenland government from its catching 
sector  would  thus  depend  on  any  increases  in  taxes  that  could  be  generated  from 
allocating  a  greater  share  of  Greenland  quota  to  the  domestic  fleet,  or  the  taxation  of 
benefits  generated  by  its  fleet  from  increased  fishing  opportunities  in  other  third 
countries through greater quota exchanges with other non-EU countries. As this revenue 
is  strongly  reliant  on export prices, over-reliance on this source represents  a significant 
risk  for  Greenland  should  export  prices  reduce,  and  maintaining  high  taxation  levels 
would impact on profitability of the domestic sector. With this uncertainty over future tax 
revenues,  it  is  not  possible  to  know  whether  in  net  terms,  benefits  to  the  Greenlandic 
government  would  be  increased  or  decreased  under  Option  A  over  the  duration  of  a 
future Protocol.   

57 

 
Option A would provide increased benefits to the Greenlandic domestic offshore sector 
from  increased  fishing  opportunities.  This  assumes  that  the  Greenlandic  offshore  fleet 
takes  up  the  fishing  opportunities  not  exploited  by  the  EU,  rather  than  these  being 
transferred  to  other  fishing  nations.  It  could  also  result  in  increased  upstream  and 
downstream  benefits  in  Greenland,  assuming  that  a  proportion  of  the  increased  catches 
by Greenlandic vessels were landed in Greenland.  

From  a  geo-political  perspective  however,  Option  A  would  reduce  the  level  of 
engagement  with  the  EU,  thus  generating  potentially  serious  negative  impacts  on 
EU/Greenland relations of a non-financial nature. Perhaps most importantly, these would 
include lost/reduced collaboration on resource management and scientific collaboration. 
The  failure  to  re-negotiate  the  agreement/Protocol  could  also  have  an  impact  on  a)  the 
future OCT Decision, and b) the exemption from customs duties of Greenlandic products 
exported to the EU; the Protocol of 1985 (No. 15) annexed to the EU Treaty on special 
arrangements  for  Greenland,  states  that  these  exemptions  apply  ‘if  the  possibilities  for 
access  to  Greenland fishing  zones granted to  the Community pursuant  to  an  agreement 
between the Community and the  authority responsible for Greenland are satisfactory to 
the Community.  

6.5.2 Option B 

Having a new Protocol (either option B1 or B2) could be expected to result in the overall 
and specific objectives specified above being achieved, as without a new Protocol there 
would be neither the joint  efforts by both parties aimed  at  sustainable exploitation,  nor 
the considerable benefits that are derived from the Protocol.   

The granting of access  within a framework guided and managed jointly by the EU and 
Greenland  and  overseen  by  the  Joint  Committee,  coupled  with  the  sectoral  support, 
represents a key difference between both Options B1 and B2, and Option A. In addition, 
the  engagement  and  communication  between  the  EU  and  Greenland  fostered  through 
having  a  new  Protocol  (options  B1  and B2)  serve  to  support  regional  coordination  and 
cooperation  between  all  parties  interested  in  fishing  for  and  managing  shared  stocks  in 
northern  waters  (e.g.  the  EU,  Greenland,  and  other  northern  countries  through  NAFO, 
NEAFC or other coastal state agreements).   

Sub-option B.1 

In  case  the  status  quo  is  maintained,  the  already  identified  needs  stemming  from  the 
weaknesses of the current Protocol would remain unmet. Whereas good utilisation of the 
fishing  opportunities,  strong  scientific  cooperation,  good  functioning  of  the  Joint 
Committees and good implementation of the sectoral support component will most likely 
remain  the  case,  issues  regarding  acceptability  of  the  Protocol  by  the  entirety  of  the 
stakeholders,  misalignment  of  reference  prices  with  actual  market  prices  and 
overexploitation  of  certain  stocks  (due  only  partially  to  EU  vessels)  would  probably 
persist.  

Sub-option B.2 

The revised Protocol as defined in Option B2 would better meet the shared needs than the 
unchanged  Protocol  specified  in  option  B1.  For  the  shared  need  of  sustainable 
exploitation, Option B2 is preferable because fishing opportunities offered by Greenland 
to the EU and accepted by the EU would be more closely aligned with scientific advice, 

58 

 
and with a potential increase in sectoral support the contribution to science and research 
would be enhanced. Option B2 would also ensure the most equitable sharing of benefits 
due to the modifications to the Protocol in terms of adaptation of reference prices during 
the Protocol.   

Option B2 better addresses the EU needs  and addresses a number of weaknesses in the 
current  Protocol  as  identified  in  the  ex-post  evaluation,  providing  better  results  for  the 
EU  than  option  B1.  Improvements  would  relate  to  the  need  for  increased  flexibility, 
which  would  benefit  the  EU  fleet.  The  longer  duration  of  the  Protocol  in  option  B2 
compared to option B1 would also result in additional benefits to stakeholders in the EU 
(i.e.  the  private  sector,  and  the  Commission),  in  terms  of  a)  the  greater  security  of  the 
benefits  generated  and  b)  the  need  to  engage  with  negotiations  for  a  new  Protocol  less 
frequently. However, it should also be noted that better alignment of quota with scientific 
advice under option B2 could potentially, but not necessarily, have a negative impact on 
the amount of quota offered to the EU, thereby reducing the benefits to the EU fleet (and 
upstream  and  downstream  sectors  in  the  EU).  Whether  this  was  the  case  or  not  would 
depend  on  whether  amounts  of  quota  allocated  to  the  EU,  generally  being  small 
proportions of total Greenland quota, would be ring-fenced/maintained even in the event 
that  TACs  for  certain  species  might  need  to  be  reduced  in  order  to  be  in  line  with 
scientific advice.   

In  comparing  the  results  between  options  B1  and  B2  (both  of  which  would  ensure 
continued benefits to Greenland in terms of financial contributions and sectoral support 
from  the  EU),  the  different  financial  benefits  would  only  be  revealed  following 
negotiations  over  indicative  and  agreed  quota,  reference  prices  and  authorisation  fees, 
and  possible  increases  in  sectoral  support,  and  would  also  be  based  on  authorisations 
taken up by EU vessels. In addition, the longer duration of the Protocol under option B2 
would  benefit  Greenland  by  increasing  its  security  over  the  benefits  resulting  from  the 
Protocol. The non-financial benefits of option B2 would also be greater than under option 
B1, in terms of enhanced collaboration on sustainability issues and scientific research.   

6.6 Preferred option 

A  comparison  of  the  options  indicates  that  sub-option  B2  (negotiation  of  a  new 
implementing  protocol  with  some  adjustments)  is  the  preferred  option.  Adjustments  to 
ensure  greater  proportionality  between  the  fishing  opportunities  negotiated  and  the 
effective use of these opportunities will improve the efficiency of the EU’s investment in 
the financial contribution for access.  

Compared  with  sub-option  B2,  sub-option  B1,  which  considers  a  renegotiation  of  the 
current  implementing  Protocol,  has  as  its  main  weaknesses  (i)  maintaining  fishing 
opportunities in excess of needs and (ii) maintaining a category of small pelagic fisheries 
whose technical arrangements are not suitable for EU operators specialising in this type 
of fishery.  

The  sub-options  B1  and  B2  will  allow  the  EU  to  mobilise  specific  EU  funding  for 
sectoral  support,  decoupled  from  the  EU  counterpart  for  access.  The  performance  of 
sectoral  support  will  depend  on  its  implementation  conditions  (available  budget, 
programming, technical and financial management of planned activities, monitoring and 
evaluation). By comparison, option A of non-renewal of the Protocol does not meet any 
of the needs of both parties. 

59 

 
6.7 Risks 

Option 2 is high risk for the EU, given the benefits that would be lost to EU stakeholders 
both  from  fishing  in  Greenland, and in  Norway.  It  would also  pose risks to  Greenland: 
any net change in benefits to Greenland from being able to allocate quota to its own fleet 
or to include such quota in exchanges with other third countries is unknown and would 
be  highly  dependent  on  export  prices.  Additional  risks  to  Greenland  could  relate  to 
impacts on the OCT Decision and exemption from customs duties. The key risk to both 
parties is therefore that a new Protocol is not agreed. A failure to agree a new Protocol 
would result in a cessation of all benefits currently being generated by the Protocol, while 
not necessarily increasing financial benefits in Greenland.  

Given the exclusivity clause, an additional risk is that a new Protocol (under either option 
1 or option 3) is not agreed before the existing one expires at the end of December 2024, 
i.e. a failure to  have  a new Protocol  in  force in  time would result in  a cessation  of EU 
vessel  activity.  The  mitigating  measure  is  to  ensure  that  negotiation  mandates  are 
provided  to  both  negotiation  teams  in  plenty  of  time  to  allow  for  negotiations  to  be 
concluded to the satisfaction of both  parties,  and a new Protocol  formally approved by 
both sides in advance of the tacit expiry of the current Protocol on 31 December 2024. 

As noted earlier, given the shared nature of stocks in northern waters and the extensive 
use  of  quota  exchanges  between  different  parties,  it  must  also  be  recognised  that  other 
fisheries  agreements  and  management  arrangements  in  the  region  could  impact  on  a 
future Protocol. Failure to agree quota at the regional level by all parties, or a failure of 
potential fisheries management plans to be agreed at the regional level, could result in the 
EU having  to decline fishing  opportunities offered to  it by Greenland for sustainability 
reasons. 

Under both options 1 and 3, there is a risk of a failure by EU vessels to utilise the fishing 
opportunities provided. However, based on recent utilisation rates and species currently 
included in the Protocol, this risk is considered as low. 

A failure by parties to agree on the content of the sectoral support matrix, given different 
views  about  priority  objectives  and  needs,  as  well  as  implementation,  is  also  a  risk. 
However,  this  risk  is  not  considered  a  major  one,  especially  as  sectoral  support  needs 
may continue broadly in line with those under the current Protocol.  

A  failure  by  the  Joint  Committee  to  adequately  monitor  the  implementation  of  the 
Protocol so as to achieve both its overall objectives as specified above, and the detailed 
arrangements and agreements contained within the Protocol  and Annexes, is  a risk that 
should  be  mitigated  by  ensuring  that  regular  Joint  Committee  meetings  are  held  as 
scheduled, are of sufficient duration to adequately consider all issues of relevance at the 
time,  and  by  any  future  ex  post  evaluations  carefully  reviewing  the  functioning  of  the 
Joint Committee. 

Both options 1 and 3 also have inherent risks with regard to uncertainty over fish prices, 
and the impact such price fluctuations might have on achieving fair and mutual benefits. 
Given that financial compensation for access is based on reference prices, divergence of 
these  prices  from  actual  values  could  benefit  one  party  over  the  other.  This  risk  is 
inherent  in  all  SFPAs/Protocols  but  is  mitigated  in  option  3  by  the  proposal  to  review 
reference prices mid-way through the Protocol. 

60 

 
 
 
 
 
 
 
Both  options  1  and  3  also  have  risks  in  relation  to  the  exploitation  of  fish  stocks.  As 
already  noted,  not  all  species  have  historically  been  exploited  in  line  with  scientific 
advice.  However,  option  3  provides  for  a  closer  alignment  of  catches  with  advice, 
thereby serving as the mitigating measure for this risk. In any case the process of annual 
confirmation/agreement of indicative fishing opportunities allows for scientific advice to 
be considered. 

6.8 Monitoring of a future implementing Protocol 

Once it enters into force, a new implementing protocol would continue to be monitored 
through  the  ongoing  technical  dialogue  between  the  Greenlandic  authorities  and  DG 
MARE. This technical dialogue should continue to encourage, as was the case under the 
current  implementing  Protocol,  the  preparation  of  the  annual  meetings  of  the  Joint 
Committee, which has the power to make decisions on the implementation of the access 
and sectoral support components of the Agreement.  

The  monitoring  framework  should  continue  to  incorporate  indicators  on  the  use  of 
fishing  opportunities.  The  monitoring  framework  should  also  add  indicators  for  the 
periodic  monitoring  of  the  application  of  the  provisions  of  the  Protocol  concerning  the 
embarkation  of  national  seamen  and  observers,  and  the  contribution  in  kind  to  food 
security. 

For  the  sectoral  support  component,  the  monitoring  framework  should  continue  to 
consider disbursement indicators to measure progress in implementation. Where possible, 
it would be appropriate for the monitoring include more systematically indicators on the 
number  of  direct  beneficiaries  of  activities  and,  where  appropriate,  indicators  on  the 
economic benefits of activities.  

In  accordance  with  the  requirements  of  the  EU  Financial  Regulation  and  the  CFP,  the 
Protocol will have to be the subject of an independent ex-post evaluation, which it will be 
necessary to implement approximately 18 months with the date of expiry of the Protocol 
in order to give the European institutions time to prepare for a possible negotiation under 
the ordinary legislative procedure without interruption of access possibilities. 

61 

 
 
 
 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

Directorate-General for Maritime Affairs and Ocean  

PLAN/2023/2011  -  EU-Greenland  Sustainable  Fisheries  Partnership  Agreement  – 
negotiation mandate for a new protocol 

1.  Organisation and timing  

The results of this SWD are mainly informed by an evaluation study conducted by 
an independent consultant. This evaluation study took place from January to March 
2024  under  the  guidance  of  an  interservice  steering  group  established  by  different 
services  of  the  European  Commission  and  within  the  framework  of  the  terms  of 
reference  of  specific  contract  number  9  under 
framework  contract 
MARE/2021/OP/0001. The evidence base of this evaluation study consisted of two 
main  components:  analysis  of  available  documentation  and  consultations  with 
stakeholders. 

the 

2.  Format of the Evaluation 

This initiative does not require an impact assessment as it sets out a general policy 
approach and does not commit to any new action. This is in line with the standard 
flexible  application  of  better  regulation  rules  to  Sustainable  Fisheries  Partnership 
Agreements  that  entail  a  tight  schedule  for  proposing  and  adopting  individual 
agreements and unavoidable legal requirements for the preparation of the renewal or 
revision  of  agreements.  There  was  no  choice  of  alternative  policy  options  in  this 
case a non-continuation of the agreement was not desired, which the findings of the 
evaluation  also  support.  However,  a  retrospective  and  forward-looking  evaluation 
was  carried  out  instead  of  an  impact  assessment  and  presented  with  this  staff 
working  document.  For  the  retrospective  evaluation,  the  questions  look  at  the 
effectiveness,  efficiency,  economy,  relevance,  coherence,  EU  added  value  and 
acceptance of the Protocol. 

For  the  prospective  evaluation,  the  questions  focus  on  identifying  problems  and 
needs,  the  objectives  to  be  achieved,  the  options  available  (conclusion  or  not  of  a 
new Protocol) and the associated risks, and lessons learned. 

3.  Evidence, sources and quality  

The details on the stakeholders consulted and the feedback received can be found in 
the synopsis report in Annex VI. 

62 

 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

For  the  evaluation  as  a  whole,  the  following  methodology  was  applied  by  the 
independent consultant, which was in line with the Terms of Reference:  

information; 

ii)  a  consultation  phase 

•  A phasing of the evaluation activities with: i) a short inception/planning period to 
develop  an intervention logic, agree consultation tools, and collect  relevant  data 
and 
involving  extensive  (remote) 
consultations with EU and Greenland stakeholders (those private sector operators 
directly  affected,  the  EU  MS  and  Greenlandic  authorities  responsible  for 
implementing the Protocol, and civil society and (i)NGOs with an interest in the 
Protocol)  –  see  Annex  6  for  synopsis  report;  and  iii)  a  data  analysis  and  report 
writing phase.  

•  The  construction  of  an  economic  model  to  assess  value-added  to  EU  and 

Greenlandic parties  

•  The use of an  evaluation questions matrix,  with  relevant  indicators, as the basis 

for answering questions related to the ex-post evaluation criteria.  

•  Monitoring  and  guidance  of  the  evaluation  by  an  Inter-service  Steering  Group 
(ISG)  consisting  of  officials  from  Commission  services  and  the  EEAS,  which 
assisted  with  identifying  aspects  to  consider,  discussing  and  approving  the 
methodology  documented  in  the  inception  report,  commenting  on  the  draft  and 
final reports, and assessing the quality of the evaluation.  

•  Peer review and quality control by the staff of the contractors not engaged in the 

evaluation and analyses, to ensure reliability and robustness.  

•  The  evaluation  period  (three  months)  did  not  allow  for  in-person  consultations, 
but  remote  consultations  were  characterised  by  good  engagement  and  feedback 
by  stakeholders  with  the  evaluators,  ensuring  that  the  robustness  of  the 
methodology was not compromised.  

•  Throughout the evaluation there was rapid and effective communication between 
the consultants and DG MARE, and the consultants and Greenlandic authorities 
to  facilitate  the  work  of  the  consultants,  for  example  with  the  provision  of  data 
and answers to specific questions required and posed by the consultants.  

•  All  major  data  requirements  of  the  consultants  to  complete  the  evaluation  were 
available from public available sources (e.g. EUMOFA, STECF, ICES, NAFO), 
or  made  available  by  relevant  stakeholders  (EU  shipowners,  DG  MARE, 
Greenlandic authorities), and are assessed as being reliable. 

63 

 
 
Specific objectives 

Success criteria 

Indicators 

Data sources 

Objective 1: To contribute towards resource conservation and environmental sustainability through rational and sustainable exploitation of living 
marine resources of Greenland 

ICES, NAFO, GINR 
Protocol text 
JC minutes 
CSAs 

reports, 

State  of  the  stocks  targeted  under  the 
Protocol  (scientific  advice  analysis  that 
Greenland  conducted,  meetings,  regional 
scientific 
data, 
CSA/RFMO/RFO  and  national  scientific 
institutes);  All  fleets  catches  and  fishing 
effort  in  Greenland  and  in  the  region; 
possible impact on the environment of all 
the fleets operating in these waters. 

and 

Fisheries  activities  are  addressed 
exclusively  at  surplus  resources  and 
prevent  the  overfishing  of  stocks, 
based  on  the  best  scientific  advice 
and  improved  transparency  on  the 
global  fishing  efforts  in  the  waters 
included in the current Protocol. 

the 

is  within 

Stocks  targeted  by  the  EU  fleet  are 
not overexploited at the regional level 
or at national level, and the EU fishing 
capacity 
limits 
established  or  recommended  by  the 
relevant Coastal States Arrangements 
(CSA),  RFMO  or  regional  fisheries 
organisation (RFO).  
The 
the 
management  strategies  expressed  by 
CSA, RFMOs, RFOs and Greenland.  
Greenland  takes  part  in  the  relevant 
CSA/RFMO/RFOs  and  provides  data 
on  activities  carried  out  by  vessels 
flagging  its  flag  and  by  other  foreign 
fleets operating in its waters. 

considers 

Protocol 

64 

 
 
 
 
Implementation  has  followed  the 
same  principle  and  promote  the 
fisheries 
standards 
same 
management  as  applied 
in  EU 
waters. 

for 

Scientific and technical evaluation of 
the 
has 
improved. 

concerned 

fisheries 

The  EU  and  Greenland  adopt 
management  measures  to  reduce 
bycatches  and  discards  and  reduce 
the 
the 
ecosystem. 

possible 

impacts 

on 

Management  measures  adopted  at  the 
regional,  national  or  EU  level  or  in  the 
framework  of  the  Protocol.  Strategies 
aimed  at  bycatch  and  conservation 
measures for protected species.  

Relevant 
management 
measures 
strategies 

and 

collection 

framework 

EU  fishing  activities  are  subject  to  an 
appropriate 
obligation 
reporting 
framework  (logbook,  VMS,  observers 
etc.) in the Agreement and a scientific 
data 
(size 
composition of the catches, biological 
parameters  etc.).  This  information  is 
transmitted  to  the  relevant  RFMO 
and national research institutes.  
EU scientists and Greenland scientists 
actively  participate 
scientific 
meetings  and  RFMO/RFO  scientific 
committees.  

in 

Inclusion  of  data  collection  provisions  in 
the  Agreement  and  timely  availability  of 
relevant  data  at  the  management  and 
scientific  operators;  amount  and  quality 
of  data  collected;  number  of  reports  to 
RFMOs 
institutes; 
participation  rate  in  RFMO/RFO  scientific 
committees; 
achieved  with 
sectoral  support;  number  of  meetings 
between  scientists  and  managers  at 
country level. 

scientific 

results 

and 

JC minutes 
Sectoral support 
Annual 
Implementation 
Reports (AIRs) 

JC minutes 
AIRs 

Compliance  and  control  of  EU-fleet 
activities have been ensured. 

The activity of the EU fleet is properly 
monitored 
(VMS,  AIS,  observers 
aboard,  etc.);  reporting,  monitoring 
and  control  takes  place  as  stipulated 
in  the  Protocol  and  as 
legislation 
requires. Moreover, there is adequate 
monitoring,  reporting  and  control  of 

65 

of 

of 

Level 
the 
implementation 
monitoring  provisions  in  the  Agreement 
and  its  Protocol;  level  of  implementation 
of  the  monitoring,  reporting  and  control 
provisions;  results  achieved  with  sectoral 
support  in  terms  of  MCS.  Number  of 

 
infringements by EU vessels. 

all  catches  and  catch  composition, 
possible  infractions  are  sanctioned; 
sectoral  support  is  used  to  reinforce 
monitoring,  control  and  surveillance 
(MCS). 

Objective 2: To contribute to continuing the fishing activity of the EU long distance fleet and the employment linked to the fleet operating within 
the Agreement and its Protocol 

resources, 

To  seek  appropriate  share  of  the 
fully 
surplus 
commensurate  with  the  EU  fleets 
interests and their regional and sub-
regional fishing strategy. 

Species and quantities covered by the 
Protocol  correspond  to  the  fishing 
patterns of the EU fleet.  
The fishing opportunities  allowed  are 
acceptable  considering  the  activities 
of all fleets active in the same waters 
at national, sub-regional and regional 
level.  

Data  provided  by  DG 
MARE 
Consultations  with 
stakeholders 
Trade data 

Utilisation  of  fishing  licences;  catches  in 
waters covered by the current Agreement 
and Protocol compared to overall catches 
at  national,  regional,  and  sub-regional 
level  if  appropriate;  employment  (direct 
and 
jobs)  for  EU  operators; 
evolution  of  the  number  of  EU  vessels  in 
the  region;  contribution  to  the  supply  of 
the  EU  market  and  EU  processing  sector 
(volume  and  value)  and  to  the 
local 
processing sector. 

indirect 

66 

 
  
To  ensure  that  the  level  of  fees 
payable  by  Union  shipowners  for 
their  fishing  activities  is  fair  and 
the 
proportional 
revenues 
non-
discriminatory and promotes  a  level 
playing  field  among  the  different 
fleets. 

considering 
costs, 

and 

To ensure supply for the EU market. 

To  encourage  the  creation  of  a 
secure 
is 
environment 
investment 
favourable  to  private 
and economic activities in the EU. 

that 

The Agreement and its Protocol offer 
similar  conditions to  all foreign  fleets 
operating  in  the  fishing  zones  and 
management  areas 
in  the  current 
Protocol. 
Fishing  authorisation  fees  paid  by  EU 
shipowners are reasonable. 

The  Agreement  offers  a  reasonable 
framework  to  foster  landings  in  the 
EU  or  trade  of  fish 
into  the  EU 
market. 

length  of 

the  Protocol 

The 
is 
sufficiently long for EU shipowners to 
have  certainty  about  access  when 
making  investment  and  maintenance 
decisions about their vessels. 

Level  of  fees  and  technical  conditions 
applied  to  third  countries  fleets  in  the 
fishing  zones  and  management  areas  in 
the  current  Protocol.  Fees  paid  by  EU 
shipowners. 

JC minutes 
GRL consultations 
Protocol 

Catches as proportion of EU consumption  DG MARE for catches 
for 

EU  shipowners 
trade flows 
EUMOFA 

Number of years of Protocol. 
Provision  of  raw  material  to  EU  fish 
processors 
Number of temporary joint ventures with 
Greenland 

Stakeholder 
consultations 
Protocol 

Vessel  activity  support  port-related 
businesses  in  the  EU,  and  provides 
raw  material  for  the  EU  processing 
sector.  

Objective  3:  To  support  the  development  of  a  sustainable  fisheries  sector  in  partner  countries  (through  the  governance  framework  that  the 
Agreement creates and through the sectoral support; cooperation on blue economy, to the small scale and  artisanal fisheries, to job direct and 
indirect creation, development of the local and national sectoral policies, etc.) and analysis of geographic, social, environmental, and economic 

67 

 
impacts. 

to 

and 

contribute 

social, 
economic 

To 
environmental, 
development in Greenland. 
To  what  extent  the  SFPA  and  the 
activities  implemented  with  the  EU 
contribution  for  sectoral  support, 
have generated significant positive / 
unintended  /  longer  term  /  broader 
effects?  

and 

that 

support 

sectoral 

the 
The 
the 
activity 
economic 
implementation  of  the  Agreement 
creates contributes to the functioning 
sector,  better 
of 
the 
transparency, 
governance, 
inclusiveness, 
and 
social 
and 
economic  development  of  the  area 
covered by the current Protocol.  

fisheries 

Results  achieved  with  sectoral  support 
and  economic  and  social  impact  of  the 
implementation  of  the  current  Protocol; 
EU contribution to budget of the national 
fisheries  strategy;  extent  of  economic 
(level  of  purchases  in  EUR)  and  social 
activity  (employment)  in  Greenland  due 
to EU vessel activity. 

support 

Sectoral 
matrices 
AIRs 
GRL budgets 
GRL consultations 

fish  caught 

Part  of  the 
in  the 
framework of the Agreement supplies 
and 
Greenlandic  market 
the 
processing 
industry;  and  the  EU-
fishing  supports  port-  and  ancillary 
activities and the economic and social 
development in Greenland. There are 
synergies 
the 
implementation  of  the  Agreement 
and 
social 
and 
economic 
development of the country. 

between 

the 

to 

contribute 

To 
strengthen 
capacities  of  Greenland  to  monitor 
and  control  fishing  activities  and  to 
fishing 
sustainable 
promote 

The  sectoral  support  contributes  to 
adequate  training,  equipment,  and 
infrastructures namely in the areas of 
science and MCS.   

Results  achieved  with  sectoral  support; 
comprehensiveness  and  level  of  detail  of 
reporting  and 
support 
the 
cooperation on Blue Economy, small scale 

sectoral 

Sectoral 
matrices 
AIRs 
GRL budgets 

support 

68 

 
practices in its waters. 

Utilisation of the sectoral support has 
been  duly  reported  (detailed  results 
on  expected  economic  and  social 
benefits in all geographic scope of the 
current Protocol). 

and  artisanal  fisheries,  aquaculture,  data 
collection,  MCS,  food  security  and  policy 
areas. 

GRL consultations 

To  promote  employment  of  local 
fishers and create direct and indirect 
employment 
in  Greenland.  To 
promote  decent  working  conditions 
in the fisheries sector. 

Greenlanders  are  employed  on  EU 
vessels. 
Part  of  the  catch 
processed 
employment. 

landed  and 
generating 

locally 

is 

directly 

and 
created 
Employment 
indirectly in the EU and in Greenland or in 
the sub region/sub region. 
Landings  by  EU  vessels 
processing 

local 

for 

(for 

Protocol 
obligations) 
GRL (for landings and 
employment in GRL) 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Effectiveness – The extent to which the objectives of the Implementing Protocol to the Agreement were achieved 

Efficiency – The extent to which the desired effects are achieved at a reasonable cost 

Questions 

Success criteria 

Possible indicators 

Data sources 

To  what  extent  does 
Protocol 
offer 
money to the EU? 

the 
value-for-

is 
The  EU  financial  contribution  for  access 
commensurate 
fishing  opportunities 
offered  by  the  current  Protocol  and  per 
category. 

to  all 

Utilisation of the fishing opportunities and 
positive cost-benefit ratios.  

DG MARE data 
Economic model 

69 

 
 
 
 
To  what  extent  has  sectoral 
support  and  cooperation  on 
blue  economy  actions,  policy 
area,  small  scale  and  artisanal 
fisheries,  food  security,  etc. 
initial 
agreed 
programming,  been  achieved 
at reasonable cost 

the 

in 

All  activities  included  in  the  sectoral  support 
have been properly implemented and benefited 
social,  and 
in  environmental, 
Greenland 
economic terms. 

the 

Degree  of  completion  of 
initial 
programming;  %  of  sectoral  support 
activities and projects compared to overall 
EU  contribution,  to  the  national  budget 
for  fisheries,  marine  and  maritime  issues 
contributions. 
and 
Contribution 
sustainable 
development of the country. 

to  other  donor 
the 

to 

the 
To  what  extent  has 
Protocol  offered  value-for-
money to the EU shipowners? 

EU 

shipowners' 

is 
The 
commensurate  to  effective  catches  and  profits 
compared to total costs and benefits.  

contribution 

Volume and value of catches. 
Gross profit from catches 
Access fees as % of income from catches 

support 

Sectoral 
matrices 
JC minutes 
AIRs 

DG MARE data 
Economic model 
STECD 
performance data 
Consultations 

fleet 

To what extent is the financial 
compensation  for  the  fishing 
possibilities 
the 
Agreement  advantageous  for 
the EU and for Greenland?  

under 

Greenland benefits from a fair part of the added 
financial 
the  catches  and  all 
value  of 
compensation.  This  financial  compensation  is 
distributed  geographically  and  socially  fairly  in 
Greenland.   

compensation 

Financial 
Greenland 
GVA to Greenland 

received  by 

Economic model 

Economy – the extent to which resources are available in due time, in appropriate quantity and quality at the best price 

70 

 
 
Questions 

Success criteria 

Possible indicators 

Data sources 

sectoral 

To  what  extent  is  all  the  EU 
contribution  and  specifically 
its 
support 
commensurate  to  the  needs 
of  Greenland and  absorption 
capacity? 

The total EU contribution is in line with national 
and  local  needs  and  absorption  capacity.  The 
total  amount  of  sectoral  support 
is  used 
according to the foreseen calendar and adapted 
In  case  of 
to  the  needs  of  the  country. 
modifications  of  the  initial  programming  of  the 
sectoral  support,  these  have  helped  to  better 
use  of  the  financial  support  and  contributed 
successfully  to  the  sustainable  development  of 
the country. 

and 

support 

Consumption  of  the  EU  contribution  for 
geographical 
sectoral 
distribution  compared  to  the  local  and 
national needs in the related policy area. 
social  distribution 
Geographical  and 
impacts  and  benefits  of  all  financial 
compensation. 
sectoral 
Absorption  capacity  of 
support;  success  stories;  %  of  sectoral 
support  compared  to  the  national  and 
local  budget  for  fisheries  and  to  other 
donor contributions. 

the 

AIRs 
Sectoral 
matrices 
Consultations 

support 

To  what  extent  have  the 
sectoral  support  payments 
been  made  yearly  in  time 
and 
the 
programming  defined  in  the 
Protocol? 

according 

to 

Contributions  have  been  paid  consistently  with 
the  Protocol  provisions,  and  so  that  they  could 
be  allocated  to  the  national  or  local  budget  in 
compliance  with  the  engagements  of  the 
Protocol. 
Achievement  of 
procedures,  budget,  financial 
methods of control and audit. 

reports  and 
indicators  and 

the  criteria 

Calendar  of  payments  and  considered 
allocations. 
Results  of  the  budget  and 
financial 
indicators  and  methods  of  control  and 
audit. 

JC minutes 

Relevance – the extent to which the objectives of the Protocol match current needs and problems  

71 

 
 
 
 
Questions 

Success criteria 

Possible indicators 

of 

Extent  to  which  the  original 
objectives 
the 
SFPA/Protocol  still  correspond 
to  the  needs  of  the  EU  and 
Greenland? 

is 

extent 

the 
To  what 
Agreement  relevant  to  the 
policy objectives of RFMOs and 
to  the  EU's  regional  relations 
with other northern partners? 

The  SFPA  and  Protocol  are  in  line  with  SFPA 
(resource  and  environmental 
objectives 
sustainability;  support  the  development  of  a 
sustainable  fisheries  sector 
in  Greenland; 
improve  scientific  and  technical  knowledge, 
and address correctly the needs of Greenland 
and of the EU shipowners. 

to  achieving 
contributes 
The  Protocol 
objectives  set  at  RFMOs  and  Coastal  State 
Arrangements (CSA) and by the Artic Council, 
and  support  relation-building  with  other 
regional partners of the EU. 

Comparison between original Agreement’s 
objectives  and  national  and  local  needs 
and those of the EU and its fleet improved 
with 
the 
implementation 
Agreement and the Protocol. 

the 

of 

to 

the 

Comparison  between  SFPA  and  these 
organisations  objectives  and  how  the 
Protocol 
implementation 
of 
objectives; 
contributes 
consistency,  coherence,  and  cooperation 
with  objectives  of  other 
fisheries 
Agreements  in  the  region  and  the  EU’s 
interest  and  objectives  in  such  regional 
organisations. 

their 

Data sources 

Agreement 
Protocol 
Consultations 

and 

Council  Regulations 
on quota swaps 
ICES/NAFO 
CSAs 

Coherence – The extent to which the Agreement and its Protocol do not contradict and is coherent other interventions with similar objectives 

Questions 

Success criteria 

Possible indicators 

How coherent is the SFPA and Protocol 
with  the  CFP  in  general  and  with  its 
external  dimension  and  the  regional 

The Protocol is in line with the CFP in 
general,  contribute  to  achieving  EU 
is 
objectives  at 

regional 

level, 

Consistency  with  the  CFP  and  its  external 
dimension  and  the  main  strategies  policy 
orientations  at  regional  and  sub  regional 

Data sources 

Protocol 
EU regulations 

72 

 
 
fisheries policy? 

consistent  with  RFMOs/RFOs  and 
other 
organisations’ 
objectives.  

relevant 

level. 

To  what  extent  is the  Protocol and  its 
implementation 
and 
coherent  and  complements  with  the 
other EU policies?  

consistent 

In  what  ways  are  the  Agreement  and 
Protocol  consistent  with  Greenlandic 
fisheries  policy  and  other  related 
national policies? 

The  Protocol  makes  a  substantial 
contribution to other EU policies. The 
Protocol  and  its  implementation  is 
complementary,  ensures  coherence 
for sustainable development including 
its  social  dimension  and  cooperates 
positively with other EU interventions. 

The  SFPA  and  Protocol  contribute  to 
identified 
the  priorities 
achieving 
nationally  and 
line  with 
is 
regulations  to 
implement  national 
policy. 

in 

Consistency with the main EU strategies / 
policy orientations. 
Implementation  of  social  clauses.  And 
contribution to sustainable food security. 
Coherence  of  the  Agreement  with  EU 
policies in the region and the country. 

Protocol 
EU Consultations 
EU 
Other 
documents 

policy 

Consistency with the national and regional 
Fisheries,  marine  and  maritime  policies, 
and  sectoral  policies 
in  the  country. 
Benefits to the governance of the country 
and  to  the  protection  and  sustainable 
management  of  natural  resources  and  to 
the society. 

Protocol 
GRL consultations 
National policies and 
strategy documents 

The EU added value – The extent to which the intervention brings EU added value  

Questions 

Success criteria 

Possible indicators 

Data sources 

is  the  additional  value 
What 
resulting from the EU intervention 
under  the  Protocol,  compared  to 
the absence of Protocol? 
To  what  extent  would  Member 

Financial contribution, in particular sectoral 
support,  successfully  used  to  support  and 
develop  the  national  and  local  fisheries 
sector. 
Evidence of the need and usefulness of the 

Data  on  the  implementation  within  the 
current Protocol in economic, social, and 
environmental terms compared to other 
agreements or with no agreement. 

Consultations 
AIRs 
Sectoral 
matrices 

support 

73 

 
 
 
States  have  had  the  ability  or 
in  place 
possibility 
to  put 
appropriate 
alternative 
measures? 
To  what  extent  have  the  overall 
benefits  of  the  Agreement  and 
Protocol  had  an  added  value  for 
the EU? 

of 

good 

sectoral 

conservation, 

benefits  arising  from  the  Agreement,  in 
governance,  natural 
terms  of 
resources 
sound 
policies, 
implementation 
infrastructure, social services, the setting-up 
of  businesses,  vocational  training,  and  of 
programmes  aimed  at  developing  and 
modernising  the  fisheries  sector,  to  ensure 
that  this  distribution  benefits  the  country, 
its natural resources and the population.  
The 
the 
agreement  are  the  ones  of  interest  for  the 
EU  fleet  considering  the  species  available 
and 
fleets 
fishing  possibilities 
operating in the same area. 

included 

for  all 

species 

fishing 

in 

What 
is  the  additional  value 
resulting from the EU intervention 
under  the  Agreement  and  the 
Protocol, compared to what could 
be  achieved  by  the  Union  fleet 
outside  the  framework  of  the 
Agreement? 

The  Agreement  and 
implementing 
Protocol provide substantial benefits to the 
EU fleet compared to private agreements. 

its 

Uptake  of  licences,  comparison  of  all 
costs  and  benefits  of  operating  under 
this Agreement, other SFPAs and private 
agreements,  degree  of  legal  certainty 
provided by the Agreement and its legal 
framework. 

Data from DG MARE 
Consultations 

74 

 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS 

Tables show cost and benefits compared to no Protocol. In most cases EU fleets and EU MS would have the same obligations/costs associated with 
control and enforcement of vessel activity either in Greenland waters or elsewhere, and Greenland authorities would have similar control and 
enforcement costs if they allowed EU vessels access their waters. Recurrent costs are annual. 

EU citizens/ 
consumers 

GRL citizens/ consumers 

EU businesses 

GRL businesses 

MS adminis-
trations 

GRL administration 

EU commission services 

Costs 
Direct compliance costs 

Negotiation of Protocol 

Design of sectoral 
support component 

one-off / 
recurrent 

one-off 

one-off 

Monetary value, ranges and/or qualitative comment 

 n/a 

 n/a  

  n/a 

  n/a 

  n/a 

  n/a 

 n/a  

  n/a 

 n/a 

  n/a 

Some staff time, but 
not quantifiable 

Some staff time, but 
not quantifiable 

3 person months FTE 
estimated (DG MARE) 

 n/a  

recurrent 

  n/a 

Not quantifiable/proportionate 
within scope of evaluation as 
not certain if GRL vessels caught 
fish instead of EU how much 
exported and sold locally 

  n/a 

 € 43 210 510  

  n/a 

 n/a  

 n/a  

recurrent 

  n/a 

 n/a  

 n/a  

Not easily 
quantifiable/ 
proportionate within 
scope of evaluation 
but could be around 
EUR 32 million if GVA 
of GRL vessels same as 
EU ones from catches 

 n/a  

  n/a 

 n/a  

recurrent 

  n/a 

  n/a 

  n/a 

  n/a 

 n/a  

Not easily quantifiable 
as depends on export 
values, tax rates, and 
utilisation which 
aren’t known. But if 
same profits as EU 

  n/a 

Catch (value) not 
available as caught by 
EU 

Gross value added from 
catches not available to 
GRL fleet 

Tax revenue on catches 
if made by GRL fishing 
companies instead 

75 

 
  
  
  
  
  
  
  
  
  
  
Costs 

one-off / 
recurrent 

Monetary value, ranges and/or qualitative comment 

EU citizens/ 
consumers 

GRL citizens/ consumers 

EU businesses 

GRL businesses 

MS adminis-
trations 

GRL administration 

EU commission services 

vessels and assuming 
20% tax on vessel 
profits c.a. EUR million 

Enforcement costs 

Sectoral support 
oversight 
Data management and 
vessel oversight as 
'super-flag state' 
Indirect costs 
Upstream and 
downstream value 
added if catches made 
by GRL fishing 
companies instead 

recurrent 

 n/a  

recurrent 

  n/a 

 n/a  

  n/a 

  n/a 

 n/a  

 n/a  

 n/a  

  n/a 

  n/a 

1 FTE/year estimated 
(consultants) 

1/2 FTE/year estimated (DG 
MARE) 

 n/a  

1/2 FTE/year estimated (DG 
MARE) 

recurrent 

  n/a 

 n/a  

  n/a 

Not quantifiable/ 
proportionate within 
scope of evaluation 

 n/a  

 n/a  

  n/a 

EU citizens/ 
consumers 

GRL citizens/ consumers 

EU businesses 

GRL businesses 

MS adminis-
trations 

GRL administration 

EU commission services 

Benefits 
Direct 

financial compensation for 
access (EU and shipowners) 
sectoral support for 
admin/management, MCS, 
and research/science 
German catch value from 
GRL available as input to EU 
processors 

one-off / 
recurrent 

recurrent 

n/a 

recurrent 

 n/a  

recurrent 

 n/a  

Monetary value, ranges and/or qualitative comment 

  n/a 

  n/a 

 n/a  

 n/a  

 n/a  

 € 27 267 357 
(economic model) 

  n/a 

  n/a 

 n/a  

 n/a 

 n/a  

  n/a 

 € 17 651 523  

 € 2 931 000  

  n/a 

 n/a  

  n/a 

 n/a  

76 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Costs 

one-off / 
recurrent 

Monetary value, ranges and/or qualitative comment 

EU citizens/ 
consumers 

GRL citizens/ consumers 

EU businesses 

GRL businesses 

MS adminis-
trations 

GRL administration 

EU commission services 

recurrent 

Not quantifiable/ 
proportionate 
within scope of 
evaluation as not 
all EU catch 
destined for EU 
market and value 
of catches in 
Norway not 
modelled 

 n/a  

  n/a 

  n/a 

 n/a  

  n/a 

  n/a 

recurrent 

  n/a 

 n/a  

recurrent 

112 (employment 
analysis) 

5 (employment 
analysis) 

 € 43 979 753 (crew 
wages and profits 
from economic 
model)  

 € 438 816 (crew 
wages from economic 
model) 

  n/a 

  n/a 

recurrent 

 n/a  

 n/a  

 € 17 229 939 
(economic model)  

 € 759 801 (economic 
model) 

recurrent 

559 (employment 
analysis) 

Not quantifiable/ 
proportionate within 
scope of evaluation 

  n/a 

  n/a 

 n/a  

  n/a 

 n/a  

  n/a 

  n/a 

  n/a 

 n/a  

  n/a 

 n/a 

 n/a 

 n/a  

  n/a 

EU catches in GRL and 
Norway available to 
consumers (after 
processing) 

Direct value added to EU 
fleet 

Crewing/employment (FTE) 
Indirect 

Indirect value added 

Upstream/downstream 
employment (FTE) 

77 

 
  
  
  
  
  
  
  
  
  
  
 
 
 
ANNEX V. SIMPLIFICATION AND BURDEN REDUCTION 

Simplification and burden reduction (savings already achieved)  

Citizens/Consumers/Workers  

Businesses  

Administrations  

[Other…] _ specify  

A list of reporting obligations (ROs) related to the Protocol is provided in Figure 38 on page 28 and shows that there are a several obligations on EU MS, EU shipowners, and Greenlandic authorities 
which relate primarily to: 

i) 
ii) 

reporting on the sectoral support provided by the EU;  
control of EU fishing vessel activity and reporting by them of catches and landings.  

The ROs stemming from the intervention are the same as those in the previous Protocol and are considered the minimum ROs necessary to ensure sustainable exploitation of resources, effective 
monitoring of the use of sectoral support funding, and compliance with Greenlandic legislation and legislation in the EU such as Council Regulation (EC) No 1224/2009 of 20 November 2009 
establishing a Union control system for ensuring compliance with the rules of the common fisheries policy, as amended mostly recently by Regulation (EU) 2023/2842 (the Control regulation25).  

There is no administrative burden on EU citizens/consumers/workers stemming from the intervention/Protocol.  

Potential simplification and burden reduction (savings)  

Citizens/Consumers/Workers  

Businesses  

Administrations  

[Other…] _ specify  

As noted above, the ROs stemming from the Protocol are the same as those in the previous Protocol and are considered the minimum ROs necessary to ensure sustainable exploitation of 
resources, effective monitoring of the use of sectoral support funding, and compliance with Greenlandic legislation and legislation in the EU such as the Control regulation14.  

Additionally, as indicated in Figure 38 on page 28, none of the ROs are additional to those in previous Protocols or to the requirements contained in other legislation. No potential additional 

25 https://oceans-and-fisheries.ec.europa.eu/fisheries/rules/enforcing-rules/control-regulation_en latest access: 11.3.24 

78 

 
 
 
                
 
  
 
 
simplification and savings in terms of ROs are there identified to make the Protocol more effective or efficient without prejudicing its objectives, for example of fish stock sustainability and 
supporting sustainable development of the Greenlandic fisheries sector. 

79 

 
 
 
ANNEX VI. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This  short  synopsis  report  covers  all  consultation  activities.  It  provides  a  summary  of 
both  the  consultations  completed  by  the  contractors,  as  well  as  contributions  made  by 
stakeholders through Have your say.  

The consultations completed by the  contractor involved remote  emailed questionnaires, 
with  an initial  period of two weeks to  provide  responses. For those stakeholders which 
did not provide responses within two weeks, a reminder email was sent providing for an 
additional  one  week  to  provide  responses.  In  the  tables  below,  ‘*’  indicates  that  a 
stakeholder provided a completed or partially completed questionnaire.  

Through  the  Have  Your  Say  Portal,  3  submissions  were  made,  one  from  Denmark 
(private sector fishing  organisation), one from Estonia (public authority),  and one from 
Germany (EU citizen). 

Summary of EU stakeholder views 

Government  and  private  sector  EU  stakeholder  views26  about  the  current  and  potential 
future Protocol were largely consistent and/or covered the following points. 

There  is  strong  support  for  the  current  SFPA/Protocol.  EU  vessels  that  fish  in 
Greenlandic  waters  rely  on  the  Agreement  for  high  percentages  of  total  catches  and 
profitability, and utilisation rates are always very high. Some MS that are not allocated 
quota through the TAC and quota regulation (based on relative stability) or which do not 
obtain it through swaps (e.g. Latvia, Poland27) would like to fish in Greenlandic waters 
(for example for cod, Greenland halibut and Northern prawn). 

The  list  of  species  covered  by  the  Protocol  is  acceptable  and  appropriate  and  is 
considered sustainable. There are concerns over declining fishing (indicative and actual) 
opportunities provided over successive Protocols for a number of species, which in some 
cases (e.g. West Greenland Northern prawn) represent declining percentages of the TAC. 

Stakeholders  widely  recognise  the  importance  of  the  EU/Greenland  SFPA/Protocol  in 
providing  fishing  opportunities  in  Norwegian  waters  (e.g.  for  the  Norwegian  artic  cod 
stock)  through  swaps  of  EU  quota  in  Greenland  with  Norway.  Access  to  Norwegian 
waters,  and  to  Greenlandic  waters  through  the  Greenland  Protocol,  is  more  important 
than  ever  following  Brexit.  Consistency  in  swaps  with  Norway  between  years  is  also 
important.  

26 EU civil society organisations did not provide responses to consultation requests. 

27 Poland had track record of catches in Greenlandic waters until 2012 and has track record in Norway, but 

is not allocated quota in Greenlandic of Norwegian waters. 

80 

 
 
 
Regarding  a  level  playing  field  and  the  technical  clauses  in  the  Protocol,  there  are 
concerns by EU stakeholders about the amounts of quota allocated to Greenland vessels 
(e.g. for Northern prawn in West  and East Greenland) which they claim are not caught 
but which are not allocated to EU vessels. Likewise, different arrangements for inter-year 
flexibility over the use of quota for Greenlandic and EU vessels do not represent a level 
playing field. EU vessels would also like to see more transparency (and therefore a more 
level  playing  field)  in  the  sharing  of  information  by  Greenland  about  bycatches  by  its 
vessels in line with requirements for EU  vessels  to provide such data. A move towards 
implementation of the electronic reporting system is favoured. 

In  terms  of  Protocol  implementation,  EU  stakeholders  report  that  the  Joint  Committee 
meetings  generally  work  well,  although  more  time  could  be  provided  for  them, 
documents could usefully be circulated in advance, and it could be useful to organize the 
Joint  Committee  meeting  on  fishing  opportunities  more  in  advance  of  EU  Norway 
bilateral consultations. EU Member State and private sector are appreciative of the good 
work the Commission services do in acting on behalf of EU Member States and the EU 
private  sector 
issuing  of  vessel 
authorisations  (in  association  with  the  Greenlandic  authorities).  A  specific  timing  issue 
with regards to implementation of the Protocol is the need for early/earlier notification of 
capelin fishing opportunities which can be critical given sea ice in allowing fishing trips 
to Greenland waters to be planned and for quota to be utilised. 

in  negotiations,  Protocol 

implementation,  and 

Thinking  towards  a  possible  future  Protocol,  EU  stakeholders  are  unanimous  in 
emphasizing  the  need  for  a  new  one  –  failure  to  re-negotiate  the  Protocol  would  have 
profound impacts on the EU fleet operating in both Greenlandic and Norwegian waters, 
and result in some vessels likely becoming inoperative. Stakeholders do not feel the need 
for  a  change  in  the  species  for  which  fishing  opportunities  are  provided,  although  if 
Greenland were to become part of an international coastal state agreement involving any 
of the Union’s shared pelagic species, some quota for those species could be included.  

However,  important  for  EU  stakeholders  is  that:  i)  fishing  authorisation  fees  do  not 
continue  to  rise  as  they  have  done  over  recent  years,  and  ii)  the  quota  allocated  to  EU 
vessels  should  remain  at  current  or  increased  levels  for  operations  to  be  economically 
viable,  and  EU  vessels  would  like  more  quota.  The  new  management  plan  for  East 
Greenland  cod  and  increased  biomass  in  the  area  could/should  provide  for  more  cod 
quota to the EU. 

A  future  Protocol  could  consider  a  longer  Protocol  period  to  provide  greater  certainty, 
which is important given the high levels of investments made in vessels. In this context 
the  potential  re-negotiation  of  the  Protocol  in  2024  is  regrettable.  Other  views  about 
possible  changes/improvements  in  a  future  Protocol  are  to  address  the  concerns  over 
technical  clauses  listed  above,  and  if  quotas  are  not  fully  utilized  by  the  year  end  that 
paid  authorisation  fees  can  be  credited  or  transferred  to  the  following  year.  Additional 
flexibility could also usefully be provided to allow part of the capelin quota to be fished 
in Icelandic waters. Again, and related to flexibility, there could be increased flexibility 
regarding vessel  entry  and exit from  the Greenland zone, especially  concerning vessels 
carrying fresh catches as the current rules appear more suited to frozen-at-sea catches and 
do  not  fully  accommodate  the  dynamics  of  fresh  catch  operations.  Finally,  EU 
stakeholders  would  like  to  see  a  requirement  for  authorisation  documents  including 

81 

 
 
 
 
 
 
annexes issued by Greenland to be accessible electronically (rather than transmission by 
e-mail). 

EU stakeholders consulted 

Name of organisation 

Denmark: Danish Ministry of Food, Agriculture and Fisheries 
Germany: Management and Control of Sea Fisheries, IWC, Federal Ministry of Food and Agriculture 
Estonia: Permanent Representation of Estonia to the EU 
Lithuania: Ministry of Agriculture 
Latvia: Fisheries Department, Ministry of Agriculture 
Spain: Ministry of Agriculture, Fisheries and Food 
Poland: Ministry of Foreign Affairs 
Sweden: Ministry of Rural Affairs and Infrastructure Department for Rural Affairs 
France: Direction Générale Des Affaires Maritimes, De La Pêche Et De L'Aquaculture 
Denmark/France: Ocean Prawns 
Denmark: Danish Pelagic Producers Organisation 
Estonia: Estonia Long Distance Fishing Association 
Germany: Deutsche Fischfang-Union GmbH & Co. KG 
Germany: Nordbank Hochseefischerei GmbH 
Spain: Cooperativa de Armadores del Puerto de Vigo / ARVI ANAMER ANAVAR.  
Poland: High Seas Fish Producers Organization 
Lithuania and Latvia: Marlinas 
Sweden: BC Pelagic 
Sweden: Swedish Pelagic Federation Organisation 
President of the LDAC and representative of cod/haddock and pelagic vessels 
Netherlands: Pelagic Freezer Trawler Association 
Europeche 
Coalition for Fair Fisheries Agreements (CFFA) 
Oceana 
WWF Belgium  
Environmental Justice Foundation 
The Danish Society for a Living Sea  
Pew Europe 
Long Distance Fleet Advisory Council (LDAC) 

Greenlandic stakeholders consulted  

Name of organisation 
Ministry of Fisheries and Hunting,  
Ministry of Agriculture, self-sufficiency, Energy and Environment 
Greenland Institute of Natural Resources 
Ministry of Independence and Foreign Affairs 
Ministry of Finance and Taxes 
Greenland Representation to the EU, Brussels 
Statistics Greenland 
Greenland Fisheries License Control Authority (GFLK) 
Joint Arctic Command 
Arctic Prime 
Polar Seafoods 
Royal Greenland 
Oceans North Kalaallit Nunaat 
Greenland Business Association 
Greenland Fishers and Hunters Association (KNAPK) 
Sulinermik Inuussutissariuteqartut Kattuffiat (SIK), Greenland’s labour union 
Qalerualinniat Aalisargarniallu Kattuffiat (QAK)  

82 

Type of stakeholder 

Government * 
Government * 
Government * 
Government * 
Government * 
Government * 
Government * 
Government * 
Government * 
Private sector * 
Private sector 
Private sector * 
Private sector * 
Private sector * 
Private sector 
Private sector * 
Private sector 
Private sector * 
Private sector * 
Private sector  
Private sector 
Civil society 
Civil society 
Civil society 
Civil society 
Civil society 
Civil society 
Civil society 
Civil society 

Type of stakeholder 
Government* 
Government* 
Government 
Government* 
Government* 
Government* 
Government 
Government* 
Government 
Private sector  
Private sector  
Private sector*  
Civil society 
Civil society* 
Civil society 
Civil society 
Civil society