COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Recommendation for a COUNCIL DECISION authorising the opening of negotiations on behalf of the European Union on a new implementing protocol to the Fisheries Partnership Agreement with the Democratic Republic of São Tomé and Príncipe, and possible amendments to the Fisheries Partnership Agreement or a new text of a Sustainable Fisheries Partnership Agreement
Date: 2024-07-12
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: São Tomé and Príncipe, agreement (EU), catch quota, financial compensation of an agreement, fishing agreement, fishing area, fishing rights, interim agreement (EU), protocol to an agreement, sea fishing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.7.2024  SWD(2024) 177 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  Accompanying the document Recommendation for a  COUNCIL DECISION authorising the opening of negotiations on behalf of the European Union on a new implementing protocol to the Fisheries Partnership Agreement with the Democratic Republic of São Tomé and Príncipe, and possible amendments to the Fisheries Partnership Agreement or a new text of a Sustainable Fisheries Partnership Agreement       {COM(2024) 295 final} - {SWD(2024) 178 final}  
 
 
Table of contents 

1. 

INTRODUCTION .................................................................................................................. 1 

Purpose and scope of the evaluation ........................................................................................... 1 

Methodology of the evaluation.................................................................................................... 2 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ......................... 3 

2.1 

Description of the intervention and its objectives ........................................................... 3 

2.1.1 

Sustainable Fisheries Partnership Agreements (SFPAs) ............................................. 3 

Fisheries Partnership Agreement between the EU and the Democratic Republic of 

2.1.2 
São Tomé and Principe ............................................................................................................... 4 

2.2 

Point(s) of comparison .................................................................................................... 7 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ........... 8 

3.1.  Utilisation of fishing opportunities .................................................................................. 8 

3.2.  Catches ............................................................................................................................ 8 

3.3. 

3.4. 

Scientific Cooperation ..................................................................................................... 9 

Technical Measures ......................................................................................................... 9 

3.4.1.  Monitoring, control and surveillance .......................................................................... 9 

3.4.2. 

Embarkation of seamen ............................................................................................. 10 

3.4.3. 

Observers ................................................................................................................... 11 

3.5. 

Sectoral support ............................................................................................................. 11 

3.6.  Monitoring of sectoral support ...................................................................................... 11 

3.7. 

Financial aspects: .......................................................................................................... 12 

3.8.  Reporting Obligations ................................................................................................... 12 

4. 

EVALUATION FINDINGS (ANALYTICAL PART) ......................................................... 12 

4.1. 

4.2. 

Effectiveness :to what extent was the intervention successful and why? ..................... 12 

Efficiency and Economy ............................................................................................... 19 

4.3.  Coherence: ..................................................................................................................... 22 

4.4. 

EU added value ............................................................................................................. 23 

4.5.  Relevance ...................................................................................................................... 25 

4.6.  Acceptability ................................................................................................................. 25 

5.  WHAT ARE THE CONCLUSIONS AND THE LESSONS LEARNT ............................... 26 

5.1.  Conclusions ................................................................................................................... 26 

5.2. 

Lessons learned ............................................................................................................. 27 

6. 

EX-ANTE EVALUATION................................................................................................... 28 

 
 
 
 
6.1. 

Problem analysis and needs assessment ........................................................................ 28 

6.2.  Current and future needs of São Tomé and Principe ..................................................... 28 

6.3.  Current and future needs of the EU ............................................................................... 29 

6.4.  Current and future needs of São Tomé and Principe and the EU together .................... 29 

6.5.  Current and future needs of the EU fleet ....................................................................... 29 

6.6. 

6.7. 

6.8. 

EU added value ............................................................................................................. 30 

Policy and management objectives ............................................................................... 30 

Policy options, including associated risks ..................................................................... 31 

6.9.  Results and impacts ....................................................................................................... 34 

6.9.1. 

Environmental-Economic-Social impacts ................................................................. 34 

Comparison according to standard evaluation criteria (relevance, effectiveness, 

6.9.2. 
efficiency and coherence) .......................................................................................................... 37 

6.10. 

Preferred option ......................................................................................................... 38 

Option concerning a modification to the Agreement or the negociation of a new 

6.11. 
Agreement in addition to the implementing Protocol. .............................................................. 38 

6.12.  Monitoring of a future implementing Protocol ......................................................... 39 

ANNEX I:   PROCEDURAL INFORMATION ............................................................................. 40 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 41 

ANNEX III. EVALUATION MATRIX ......................................................................................... 44 

1 
Effectiveness – The extent to which the objectives of the Implementing Protocol to the 
Agreement were achieved ..................................................................................................... 44 

2 
Efficiency – The extent to which the desired effects are achieved at a reasonable  
costs ....................................................................................................................................... 50 

Economy – the extent to which resources are available in due time, in appropriate 
3 
quantity and quality at the best price ..................................................................................... 51 

4  Relevance – the extent to which the objectives of the Protocol match current needs and 
problems ................................................................................................................................ 52 

5  Coherence – The extent to which the Agreement and its Protocol do not contradict and 
is coherent other interventions with similar objectives ......................................................... 53 

6 

The EU added value – The extent to which the intervention brings EU added value ... 54 

7  Acceptability – The extent to which stakeholders accept the policy in general and the 
particular instrument proposed or employed ......................................................................... 55 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ............................................................. 57 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................... 60 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

SFPA 

CFP 

EU 

IUU 

ICCAT 

SDG 

STP 

Sustainable Fishery Partnership Agreement 

Common Fisheries Policy Regulation  

European Union 

Illegal, unreported, unregulated (fishing activities) 

International  Commission  for  the  conservation  of 
Atlantic Tunas 

United Nations Sustainable Development Goals 

São Tomé and Principe  

 
 
 
1. 

INTRODUCTION 

Purpose and scope of the evaluation 

The evaluation’s purpose is determined by the following provisions:  

-  Article 31(10) of the Common Fishery Policy Regulation5 requires the European 
Commission to arrange for ex-ante and ex-post evaluations of each implementing 
protocol to a Sustainable Fishery partnership Agreement (SFPA) before it submits 
to  the  Council  a  recommendation  to  authorise  the  opening  of  negotiations  for  a 
successor protocol.  

-  Article  34  of  the  Financial  Regulation1,  requires  the  Commission  Services  to 
undertake both ex-ante and ex-post evaluations for all programmes and activities 
which entail significant spending. 

These  evaluations  aim  to  inform  decision  makers  before  adopting  a  Council  Decision 
authorising the opening of negotiations on behalf of the EU. 

These  evaluations  should  assess  how  financial  instruments  have  been  effective  for  the 
achievement of the policy objectives of the Union, based on performance review, analysis 
of relevance and of added value of Union involvement.  

Policy objectives pursued by Union with the SFPA instrument are defined in section 2.1.  

The evaluation draws upon an external ex post and ex ante evaluation study of the current 
implementing Protocol 2019-2024, performed by an external consultant through a specific 
contract, whose final report is published on the EU bookshop2.  

The ex-post evaluation study covers the period of application of the current implementing 
Protocol of the Agreement, starting from 19 December 2019 to December 2023 (while the 
protocol expires in December 2024). The geographical scope is São Tomé and Principe 
and  concerned  Member  States  are  France,  Spain  and  Portugal  (as  per  the  fishing 
opportunities allocation3). 

The evaluation covers the 5 criteria of effectiveness, efficiency, coherence, relevance and 
EU added value, as well as economy (together with efficiency) and acceptability, through 
specific questions and suggested indicators for each criterion. 

The ex-ante evaluation study analyses the relevant objectives for the Agreement and its 
implementing protocol, considering the current and future needs for this intervention. It 

1 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). 

2 https://op.europa.eu/fr/publication-detail/-/publication/55fcd1d2-132e-11ef-a251-01aa75ed71a1 

3 Council Regulation (EU) 2019/2219 of 24 October 2019 on the allocation of fishing opportunities under 
the Protocol on the implementation of the Fisheries Partnership Agreement between the Democratic Republic 
of São Tomé and Príncipe and the European Community (OJ L 333, 27.12.2019, p. 31–32), 

1 

 
 
considers the lessons learned from previous implementing protocols and the results of the 
ex-post evaluation of the current implementing Protocol.  

Two policy scenarios are considered in the ex-ante evaluation study: 

•  A renegotiation of the current implementing Protocol for the Agreement (status quo 

with some adaptations if needed);  

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

Methodology of the evaluation 

The results of this Staff Working Document (SWD) are mainly informed by an evaluation 
study  conducted  by  an  external  consultant.  This  evaluation  study  took  place  from 
December 2023 to February 2024 under the guidance of an interservice group established 
by different services of the European Commission and within the framework of the terms 
framework  contract 
of 
MARE/2021/OP/0001.  

reference  of  specific  contract  number  6  under 

the 

targeted  questionnaires  and  semi  directed 

The  study’s  methodology  is  based  on  information  and  data  gathering  from  literature, 
Commission  database, 
interviews  of 
stakeholders (fishing operators, fish processors, fishery authorities in EU Member States 
and Partner Third country, civil society representatives4), synthesis of their satisfaction or 
dissatisfaction  on  the  implementation  of  the  Protocol,  and  a  standardised  economic 
analysis  establishing  the  repartition  of  the  generated  economic  added  value.  EU 
stakeholders were consulted between January and February 2024. São Tomé and Principe 
stakeholders were consulted during the consultant’s field mission to São Tomé. See details 
in Annex II.  

The methodology is deemed to be reasonably robust. Its limitations are related to the time 
constraints  of  the  evaluation,  the  incomplete  period  of  the  initiative  submitted  to  the 
evaluation (given the target date for the study’s final report, one year of the implementation 
period is not covered), the lack of available reliable official data in third country statistics 
or within operators due to commercial confidentiality.  

4  A  feedback  period  on  the  “have  your  say”  portal,  from  08  January  -  05  February  2024,  resulted  in  2 
comments  one  from  an  NGO  and  one  from  an  EU  citizen.  https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/13773-EU-Sao-Tome-e-Principe-fisheries-agreement-negotiation-
mandate-for-a-new-protocol_en  

2 

 
 
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 Common Fishery Policy (CFP)5 provides that the Commission negotiates and 
implements  Sustainable  Fisheries  Partnership  Agreements  (SFPAs)  with  third 
countries  to  create  a  legal,  environmental  economic  and  social  governance 
framework  for  fishing  activities  carried  out  by  Union  fishing  vessels  in  third 
country waters6. 

−  Union  fishing  activities  outside  Union  waters  should  be  based  on  the  same 
principles and standards as those applicable under Union law and promote a level 
playing field for Union operators and non-EU operators. 

−  Union  fishing  activities  in  third  country  waters  should  be  based  on  the  best 
available  scientific  advice  and  relevant  information  and  relevant  information 
exchange. 

−  They should ensure a sustainable exploitation of the marine biological resources, 
transparency  as  regards  the  determination  of  the  surplus  and,  consequently,  a 
management  of  the  resources  that  is  consistent  with  the  objectives  of  the  CFP. 
SFPA should provide for access to resources commensurate with the interests of 
the Union fleet in exchange for a financial contribution from the Union. 

−  SFPA should ensure, in particular, efficient data collection, monitoring, control and 

surveillance measures. 

−  The EU is to provide the partner country with a financial compensation for access 
to its waters and a 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. 
In the case of São Tomé and Principe, access has been sought for the EU industrial 
fleet targeting tropical tunas and associated migratory species (swordfish and some 
authorised shark species), which are entering the global food chain as a commodity, 
participating to international trade, including EU supply of fish.  

− 

−  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 

5 Regulation (EU) 1380/2013 of 11 December 2013 on the Common Fisheries Policy (OJ L354, 28.12.2013, 
p. 22) 

6 SFPA’s policy objectives and reform proposals are detailed in  the Commission’ Communication  to the 
European  parliament,  the  Council,  the  Economic  and  Social  Committee  and  the  Committee  of  the 
regions  on  the  external  dimension  of  the  CFP  (COM(2011)424  final  of  13  July  2011).  The  Council 
the  CFP  on  19  March  2012 
adopted  Conclusions  regarding 
the  External  Dimension  of 
(http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/agricult/129052.pdf) 
the 
European Parliament expressed its views in European Parliament’s report on the External Dimension of 
the Common Fisheries Policy of 22 November 2012.  

and 

3 

 
 
European  Commission 
implementation of the SFPAs. 

is 

therefore  responsible  for 

the  negotiation  and 

−  Under Article 31(5) of the CFP Basic Regulation, 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. 

2.1.2  Fisheries  Partnership  Agreement  between  the  EU  and  the  Democratic 
Republic of São Tomé and Principe  

The Fisheries Partnership Agreement between the EU and the Democratic Republic of São 
Tomé  and  Principe  (STP),  and  its  current  implementing  Protocol,  provide  fishing 
opportunities  to  fish  for  Union  fishing  vessels  in  STP’s  waters  and  establishes  the 
principles on the economic, financial, technical, and scientific cooperation in the fisheries 
sector. It promotes responsible fishing in STP, conservation and sustainable exploitation 
of fisheries resources and through sectoral support contributes to develop the STP fisheries 
sector. 

of 

the 

Duration 
Agreement 
Date of application or 
entry into force of the 
Agreement 
Date of application or 
entry into force of the 
Protocol 
Duration 
Protocol 
EU 
opportunities  

fishing 

the 

of 

EU 
contribution  

financial 

Licence  and  catches 
fees  paid  by  the  EU 
operators 

Four years from its entry into force, tacitly renewable 

Signature on 30.10.2007, entry into force 29.08.2011 

Signature on 19 December 2019 

5 years: 19 December 2019- 18 December 2024 

Highly migratory species  

•  28 freezer tuna seiners (Spain, France) 
•  6 surface longliners (Spain, Portugal) 
•  EUR 400 000 per year for access 
•  EUR 440 000 per year for sectoral support 

Highly migratory species 

•  Freezer tuna seiners: EUR 70/t with a non-recoverable lump-
sum advance of EUR 9100 for 127 t for 2 years, then EUR 
70/t with a non-recoverable lump-sum advance of EUR 8 890 
for 130 t 

•  Surface longliners: EUR 70/t with a non-recoverable lump-

sum advance of EUR 3 255 for 46,5 t 
•  Support vessels: EUR 3 500 per year  

The sectoral support component is used for programmed activities in the following areas: 
(1)  reinforcing  the  monitoring,  inspection  and  surveillance  of  fisheries  activities;  (2) 
improved  scientific  knowledge  on  fish  stocks;  (3)  improve  fish  products  quality;  (4) 
support  small-scale  fisheries;  (5)  strengthening  international  cooperation  and  (6) 
strengthening aquaculture. 

4 

 
Figure  1  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. 

5 

 
Figure  1.  Intervention  logic  of  the  Fisheries  Partnership  Agreement  between  the  EU  and  the 
Democratic Republic of São Tomé and Principe (STP) and its current implementing Protocol  

6 

 
 
 
 
 
 
 
2.2 Point(s) of comparison  

The most relevant and accessible point of comparison is the previous implementing Protocol 
under  the  same  Fishery  Partnership  Agreement.  Indeed,  the  situation  in  the  absence  of 
Fishery agreement would date from nearly 40 years ago (1985). 

Under the Protocol 2014-2018 (evaluated from 2014-2017)7:  

-  EU fleet access to the waters of São Tomé and Principe was granted to up to 28 purse 

seiners and up to 6 longliners.  

-  The  annual  mean  of  tropical  tuna  catches  by  purse  seiners  was  6700t  (97%  of 

reference tonnage), and the generated income for São Tomé and Principe:  

o  EUR 1.15 million per year (mean of catches value per year, table 16 p. 33).  
o  EUR  3.233  million  over  nearly  4  years  of  implementation  (total  of 

contributions EU and shipowners in table 17, p. 34) 

-  Public contribution transferred to São Tomé and Principe was EUR 1.747 million in 

2018 (p. 34) taking into account the delays on sectoral support transfers. 

The fishery resource targeted by the Union fleet is scientifically assessed by the International 
Commission for the Conservation of Atlantic Tunas (ICCAT), the relevant RFMO. 

-  The status of the 3 main targeted stocks is (indicators relate to biomass for overfished 
status and to fishing mortality for overfishing status, for a concerned specie cf table 
49 p. 92):  

o  Yellow fin tuna: slightly overfished, no overfishing occurring 
o  Big eye tuna: overfished, overfishing occurring 
o  Skipjack: likely not overfished, likely no overfishing occurring 
o  Swordfish not overfished, no overfishing occurring 

-  Calculation turnover for the EU fleet is EUR 11.37 million (table 25) for the 2 years 
evaluated, added value  (direct  and indirect)  has  a  mean of  EUR  5.454 million, of 
which EUR  3.274 million  go to  EU and  EUR  1.038  million go to  São Tomé and 
Principe, and the remaining EUR 4.142 million go to other ACP countries (p. 44).  
-  Level and repartition of the generated added value: It is estimated that for each euro 
of public investment, EUR 17.12 are generated in added value, out of which EUR 
6.49 for the EU (p. 46). 

-  Situation  of  the  control  and  surveillance  system  in  São  Tomé  and  Principe:  a 
Surveillance center had been equipped but not yet made fully functional (p. 54). 

-  The direct and indirect employment effects were not evaluated at that time. 
-  Sectoral  support  contribution transferred to  São  Tomé and Principe EUR  325 000 

(par. 1). 

7 Reference pages in this section are to the evaluation final report of September 2017 of SC n° 3 under MARE 
2015/23  framework  contract  https://op.europa.eu/en/publication-detail/-/publication/b2a08ce7-bac1-
11e7-a7f8-01aa75ed71a1  

7 

 
 
 
 
 
3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?8 

With regard to the implementation of the Protocol, the current state of play is the following: 

3.1.  Utilisation of fishing opportunities 

On an annual average, almost 73% of the maximum number of 34 fishing licenses for all EU 
vessels  were  granted  in  the  period  2019-2023.  This  percentage  ranged  from  67%  in  the 
category of tuna seiners to 100% in the category of surface longliners (page 41 table 5) 9. 

Average annual fishing authorisations granted to EU vessels (per vessel category) in the 
SFPA fishing zone  

Vessel Category 

Fishing 
Licences 
provided  in  the  current 
Protocol 

Fishing 
Authorisations 
obtained 

Percentage  (%)  of  utilized 
fishing opportunities 

Tuna purse seiners 

28 

Surface longliners 

6 

TOTAL 

34 

3.2.  Catches  

19 

6 

25 

67% 

100% 

73% 

On average, EU tuna vessels caught 71% of the reference tonnage of 8 000 tons agreed under 
the Protocol (table 6, page 43). EU catches varied between 43% of the reference tonnage 
caught in 2020 and 117% in 2021, with, hence, one year during which total catches were 
higher than the reference tonnage, confirming the highly migratory nature of the tuna species 
and the unpredictability of the catches in São Tomé and Principe waters. EU purse seiners 
represented almost 90% of the total catches. 

Annual catches by EU vessels in the STP FPA fishing zone (tonnes) per calendar year under 
the 2019-2024 Protocol 

Category   2020 

2021 

2022 

2023 

Tuna 
seiners 

2 572 

8 668 

3 832 

5 337 

Average 
(2020-
2023) 

5 112 

8 Reference pages in this section are to the evaluation report of SC n° 6 under MARE 2021/OP001 framework 

contract. 

9 See report, page 28 

8 

 
 
 
 
 
Surface 
longliners 

829 

657 

385 

354 

Total 

3 401 

9 326 

4 217 

5 732 

557 

5 669 

3.3. 

Scientific Cooperation  

The  stocks  targeted  by  the  EU  fleet  are  scientifically  evaluated  by  ICCAT,  the  relevant 
RFMO, to which both the EU and São Tomé and Principe are active members, and which 
has provided the best available scientific advice for the management decisions taken by Joint 
Committee.  

Scientific cooperation between the EU and São Tomé and Principe takes place within the 
multilateral  framework  of  ICCAT,  whereas  sectoral  support  is  also  granted  for  the 
participation of São Tomé and Principe delegates in ICCAT meetings. 

Tuna and tuna-like species are under the management mandate of ICCAT. The status of the 
three  main  targeted  stock  (yellowfin  tuna,  bigeye  tuna,  swordfish  and  blue  shark)  was 
assessed as follows10 (p. 36 table 4): 

•  Yellowfin tuna (Thunnus albacares): not overfished, no overfishing occurring, 
•  Big eye tuna (Thunnus obesus): overfished, no overfishing occurring, 
•  Skipjack (Katsuwonus pelamis): not overfished, no overfishing occurring, 
•  Swordfish (Xiphias gladius): overfished and overfishing, 
•  Shortfin mako shark (Isurus oxyrhinchus): not overfished, no overfishing occurring, 
•  Blue shark (Prionace glauca): not overfished, overfishing (2019). 

Stock management and conservation measures are decided and implemented within ICCAT 
(inter alia, fishing capacity limits, catch limits, restrictions on the use of FADs) and in the 
case of tropical tunas, a 13 314 tons of bigeye tuna allocated to the EU for the whole ICCAT 
area,). They apply to all ICCAT Parties. 

3.4.  Technical Measures  

3.4.1.  Monitoring, control and surveillance  

The Protocol lays down the monitoring, control and surveillance regime (Chapter V of the 
Annex to the Protocol) applying to all EU tuna vessels operating in São Tomé and Principe’s 
fishing zone.  

10 Indicators relate to biomass for overfished status and to fishing mortality for overfishing status, for a 
concerned species. 

9 

 
 
 
 
 
 
The Joint Committees’ minutes indicate a generally satisfactory level of compliance with 
the relevant clauses.  

Since the end of the previous Protocol, the FMC has been equipped with an integrated vessel 
positioning (VMS) and catch declaration system (ERS) applicable to Union vessels. Union 
vessels and the flag Member States use this system to send notifications, indicate positions 
and daily catches, which has replaced the previous system of emails for the follow up of 
fishing activities. This has reduced the administrative burden linked to manual reporting and 
compilations. However, the FMC in São Tomé e Príncipe experience regular power short 
cuts which impairs the continuous reception of data. Data have to be resubmitted again and 
some data losses maybe experienced, which create difficulties in data sets comparisons. 

Sectoral  support  also  includes  reinforcement  of  SCS  (inspections  at  sea,  in  particular). 
Finally,  no  infringement  proceedings  have  been  initiated  by  the  São  Toméan  authorities 
against  an  EU  vessel  since  the  entry  into  force  of  the  implementing  Protocol  (December 
2019).  

3.4.2.  Embarkation of seamen 

In quantitative terms, the EU vessels are required to employ a minimum of fishers which are 
São Tomé and Principe nationals, ranging from 2 to 10 for the tuna seiners and 2 for the 
surface  longlingers.  From  a  qualitative  point  of  view,  the  Protocol  provides  for  the 
application  of  the  International  Labour  Organisation  (ILO)  Declaration  on  Fundamental 
Principles  and  Rights  at  Work  in  the  context  of  employment  contracts  with  the  seamen. 
Notably, the level of pay cannot be lower than the minimum wage and, in any case, not lower 
than ILO standards.  

During the period assessed by the evaluation, EU vessels have employed significantly fewer 
fishers  than  the  minimum  number  provided  for  in  the  Protocol,  and  no  fishers  from  São 
Tomé e Príncipe has been engaged.  

The São Toméan authorities regret the EU’s lack of willingness to apply the clause. Member 
States and EU tuna associations active in São Toméan waters during the Protocol put forward 
the following reasons: the possibility of paying a compensatory amount in the event of non-
embarkation of São Toméan seamen, inappropriate training of seamen, failure to transmit a 
list  of  suitable  seamen  for  some  years,  and  difficulty  in  recruiting  São  Toméan  seamen, 
bearing in mind that other Protocols in the region have similar requirements. In the beginning 
of the application of the Protocols, frontiers were closed due to the COVID pandemic.  

As  a  results,  the  penalties  for  non  embarking,  supposed  to  be  applicable  in  exceptional 
circumstances,  became  recurrent.  It  generated  extra  revenue  for  São  Tomé  e  Príncipe  of 
around  EUR  158 800  (p.  47)  with  an  increasing  trend,  due  to  the  progressivity  of  the 
obligations in embarked seamen numbers, and a higher presence of Union vessels in São 
Tomé  e  Príncipe  EEZ,  as  monitored  by  the  VMS  system.  In  2023  longliners  from  Spain 
however boarded 3 fishermen from São Tomé e Príncipe.  

From  a  qualitative  aspect,  the  transport  federations  in  the  EU  and  the  international 
representing the ITF/ETF seafarers’ unions pointed out that in 2023,  the ITF/ETF and its 

10 

 
European  and  African  affiliates  started  a  dialogue  with  Europêche  and  its  member 
employers’  groups.  Discussions  focused  on  the  wages  paid  to  local  fishermen  and  the 
possibility  to  negotiate  a  collective  agreement  covering,  inter  alia,  the  entire  EU  long 
distance  fleet,  in  order  to  respond  to  fishermen’s  complaints.  The  ITF/ETF  therefore 
supported  the  renewal  of  the  Protocol  with  some  improvements  to  the  clause  on  the 
contracting of seafarers. (page 91) 

3.4.3.  Observers 

The  Protocol’s  clauses  regarding  embarkation  of  observers  designated  by  São  Tomé  e 
Príncipe on EU vessels,  supported by  a  contribution  of  EUR  250  annually per vessel  for 
financing the observers, were not fully implemented.  

The main issue raised was that EU shipowners would not employ observers designated by 
the partner country. Nevertheless, their contributions to financing the observers programme 
were duly paid.  

In  the  absence  of  a  regional  observer  programme  for  tropical  tunas  by  ICCAT,  EU  tuna 
vessels are monitored by scientific observers in accordance with the obligations of the EU 
(Data Collection Framework – DCF), ICCAT and for monitoring the terms of reference of 
their commitments. Scientific observers must therefore have a level of qualification which 
enables  them  to  comply  with  the  specifications  of  the  various  observer  programmes.  In 
practice, observations are carried out by specific human observers recruited and trained by 
private companies and by electronic monitoring through the analyses of camera recordings 
carried out by independent third parties. In the context of the observer embarkation clause, 
the  São  Toméan  authorities  thus  recognise  the  ‘single  and  permanent  common  observer 
programme’ (OCUP programme) set up by the association of French tuna seiners’ owners 
carried out on the basis of shipowners’ funding, with an independent third party. As part of 
this programme, some São Toméan nationals were trained and able to be deployed on French 
vessels.   

The number of observers on board per year was two on average over the period 2020-2022. 
They were taken on board French tuna seiners. The São Toméan authorities would like to be 
able to take São Toméan observers on board Spanish tuna vessels (seiners and longliners) as 
well. (page 48) 

3.5. 

Sectoral support 

The current implementing Protocol has earmarked a budget of EUR 440 000 per year – or 
EUR 2.2 million over a period of  five years – to  contribute to  the implementation of the 
national strategy for fisheries and aquaculture and support the sustainable management of 
fishery resources and the development of the fisheries sector in São Tomé and Principe.  

3.6.  Monitoring of sectoral support  

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. 

11 

 
However, the monitoring of the implementation of sectoral support is not documented by 
the  annual  progress  reports  provided  for  in  the  Protocol  –  nor  have  the  Joint  Committee 
meetings been regular, whereas the Protocol requires at least one Joint Committee meeting 
to be held per year.  

3.7.  Financial aspects: 

•  Generated income for access on average for São Tomé and Principe of EUR 910.380 
(EU yearly public contribution plus shipowners contributions average, tables 8, 9 and 
10 p. 45). 

•  Calculation  turnover  for  the  EU  fleet:  EUR  9.3  million  (p  62),  added  value  EUR 
3.207 million (table 20 p. 65), of which EUR 2.250 million go to EU and 0.957 go 
to São Tomé and Principe (p. 65). 

•  Level and repartition of the generated added value: It is estimated that for each euro 
of public investment, EUR 6.60 are generated in added value, split in EUR 5.33 for 
the EU and EUR 1.27 for São Tomé and Principe. 

•  Direct and indirect employment: estimated just under 180 full time equivalent at the 
end of the evaluated period, mostly indirect (p. 69), from related and downstream 
activities, performed by other non EU countries nationals.  

•  Sectoral support contribution transferred to São Tomé and Principe EUR 1.3 million 

up to March 2024. 

3.8.  Reporting Obligations 

The implementation of the Protocol entails reporting obligations:  

-  For Union vessels to their Flag Member States as regards real time vessels positions 
daily  catches,  landings,  transhipments,  sales.  These  are  aligned  to  either  the  EU 
control regulation or international obligations (ICCAT) and use the mechanisms and 
IT tools foreseen by such those provisions.  

-  Additionally operators should report to their flag Member State on the compliance 

to boarding seamen and observers and related payments once a year.  

-  Flag  Member  state  should  report  aggregated  catches  and  effort  data  to  the 
Commission  for  transmission  to  the  Coastal  country  (using  IT  tools  and  formats 
defined in the EU legislation), as well as the information mentioned above.  

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

4.1.  Effectiveness :to what extent was the intervention successful and why?  

For each component (access and sectoral support) success criteria have been proposed and 
evaluated, by objective, for effectiveness.  

Objective  1:  contribute  to  the  conservation  of  resources  and  environmental 
sustainability through rational and sustainable exploitation of São Tomé and Principe 
’s fisheries resources 

12 

 
 
1.1 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  concept  of  surplus  available  in  São  Tomé  and  Príncipe  waters  is  related  to  the 
sustainable  management  of  the  highly  migratory  species  spread  throughout  the  Atlantic 
Ocean and subject to the conservation and management rules adopted under the multilateral 
framework  of  the  competent  Regional  Fisheries  Management  Organisation  (ICCAT)  to 
which  the  EU  and  São  Tomé  and  Príncipe  are  contracting  parties.  In  other  words,  the 
Protocol allows the EU to exploit the fishing opportunities granted to it by ICCAT in São 
Tomé and Príncipe waters, as opposed to the exploitation of fishing opportunities for local 
stocks under the responsibility of São Tomé and Príncipe. 

ICCAT’s assessments  of the state of resources (see section 5.2) indicate that  most of the 
stocks targeted by EU tuna seiners are within sustainability limits. On the other hand, the 
status  of the bigeye tuna stock is  assessed as overexploited.  ICCAT has adopted specific 
conservation and management measures to restore this stock and to ensure the conservation 
of other stocks (section 5.4). They apply to all fishing entities of RFMO Contracting Parties, 
including the EU and São Tomé and Príncipe, wherever they operate. The Protocol does not 
derogate from or conflict with any of these rules. In particular, the fishing capacity authorised 
under the Protocol (maximum of 28 tuna seiners and 6 surface longliners) is compatible with 
the capacity limits defined by the EU on the basis of ICCAT requirements (maximum of 34 
tuna seiners and 269 surface longliners). 

São Tomé and Príncipe delegations participate in ICCAT meetings. Nevertheless, São Tomé 
and Príncipe’s commitment to ICCAT’s work does not match expectations. The review of 
the  ICCAT  Compliance  Committee  reports  indicates  significant  and  recurrent  reporting 
problems in São Tomé and Príncipe, including the absence of an annual report for two years 
allowing,  inter  alia,  the  sharing  of  data  on  the  activities  of  vessels  flying  its  flag  and  on 
foreign vessels operating in national waters. Failure to comply with reporting obligations 
has led ICCAT to identify São Tomé and Príncipe, which is a first step towards possible 
trade sanctions under ICCAT Rec. 06-13. São Tomé and Príncipe also presents relatively 
substantial arrears of its compulsory contributions to ICCAT. 

1.2  Implementation  of  principles  and  standards  for  fisheries  management  as  those 
applied in EU waters 

The environmental impact of the activities of EU tuna vessels is known and monitored in 
ICCAT’s multilateral framework. These impacts, which are common to all fleets, are the 
subject of specific measures adopted by ICCAT. With regard to tuna seiners, the measures 
aim in particular to maintain the coverage of all fishing operations by scientific observations, 
to limit the number of Fish Aggregating Devices (FADs) and to prohibit their use for a period 
of  72  days,  and  to  require  the  use  of  non-entangling  FADs  made  from  biodegradable 
materials.  With  regards  to  surface  longliners,  the  measures  aim  to  reduce  the  accidental 

13 

 
 
 
 
 
 
mortalities of protected species, and to prohibit the practice of shark finning of sharks to 
keep only their fins on board. These measures are applicable throughout the Atlantic Ocean, 
including São Tomé and Príncipe’s fishing zone. The EU and São Tomé and Príncipe, which 
are two of the 52 ICCAT contracting parties, cooperate in the identification of measures. 
The Protocol does not derogate from any of the rules in force. 

The measures to reduce the impact of fisheries adopted under ICCAT are complemented by 
unilateral measures implemented by EU tuna seiners in the context of Fisheries Improvement 
Projects (FIP) whose performance is audited by third parties and reports made public. The 
unilateral measures provided for by the FIPs also apply in São Tomé and Príncipe’s fishing 
zone. In addition, EU rules on shark finning go further than ICCAT rules by requiring EU 
vessels to keep fins attached to carcasses. 

1.3 Improvement of technical and scientific assessment of the fisheries  

EU vessels are subject to the monitoring obligations arising from the EU Control Regulation, 
most of which are set out in the Protocol, and from the EU Regulation on the collection of 
scientific data. EU vessels are also subject to ICCAT’s specific obligations, in particular as 
regards the coverage of fishing operations by independent observations. 

Data from the monitoring of EU vessels shall be transmitted to ICCAT. An analysis of the 
publications of the ICCAT Standing Committee on Research and Statistics indicates that the 
data  collected  on  the  activities  of  EU  tuna  seiners  form  one  of  the  main  bases  of  the 
abundance time series used for stock assessments. Bycatch data collected by observers on 
EU  tuna  vessels  is  almost  the  only  source  of  data  used  for  scientific  publications  on  the 
subject for the Atlantic Ocean. 

Scientists  from  the  EU  and  São  Tomé  and  Príncipe  participate  in  ICCAT  meetings,  as 
evidenced by the attendance lists of the meetings. 

1.4 Ensuring control and compliance with EU fleet rules 

The EU fleet is properly monitored by EU Member States’ surveillance authorities and by 
São  Toméan  authorities  under  the  terms  of  the  Protocol  and  in  accordance  with  EU 
legislation.  

There  are  malfunctions  in  satellite  tracking  on  the  São  Toméan  side,  but  EU  vessels  are 
monitored  remotely  by  the  surveillance  centres  of  their  respective  flag  states.  Sectoral 
support also includes reinforcement of MCS (inspections at sea, in particular). Finally, no 
infringement proceedings have been initiated by the São Toméan authorities against an EU 
vessel since the entry into force of the Protocol (May 2019). 

As regards the observation of fishing activities, EU tuna vessels are monitored under ICCAT 
observer programmes and EU scientific data collection (DCF). On the clause on embarkation 
of São Toméan observers in the Protocol (to be recalled that observers may be taken on board 
in the São Toméan fishing zone under this clause at the request of the São Toméan authorities 

14 

 
by forwarding a list of observers and designated vessels), the São Toméan authorities apply 
the regional programme organised by the French tuna armaments association Orthongel: the 
OCUP programme coordinated by an independent body. Observers of São Toméan origin 
have been deployed using this programme since 2021. At a meeting of the Joint Committee, 
the São Toméan authorities expressed the wish that scientific observations by São Toméan 
observers should be made on certain tuna vessels flying the Spanish and Portuguese flags in 
order  to  also  respond  to  this  clause.  The  EU  encouraged  the  São  Toméan  authorities  to 
facilitate  observation  on  these  vessels  by  providing  the  list  of  observers  to  board.  An 
association of Spanish tuna seiners consulted (OPAGAC) suggested establishing a regional 
mechanism similar to that of the OCUP programme with the support, in the short term, of 
IEO and AZTI, which coordinate Spanish observer programmes on Spanish tuna vessels.  

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

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

As regards tuna purse-seiners, São Tomé and Príncipe’s fishing  zone  is significant, since 
almost 100% of the number of tuna seiners active in the Atlantic Ocean have taken a fishing 
authorisation under the Protocol. As confirmed during the consultations, the importance of 
access to São Tomé and Príncipe’s fishing zone is explained by the possibility of fishing 
activities in a zone south of the equator, with possible access to the Gabonese zone under 
the Fisheries Memorandum of Understanding in force since 2021, and in adjacent fishing 
zones  under  direct  authorisation  regimes  (Angola).  These  possibilities  of  access  to  areas 
under the jurisdiction of coastal States, complemented by access to sea areas, compensate to 
some extent for the impossibility of accessing the fishing zone of Equatorial Guinea. The 
importance of access to São Tomé and Príncipe’s fishing zone is also measured by the fact 
that EU tuna seiners caught on average 6% of their annual catches in the Atlantic Ocean in 
the period 2020-2022 and up to 10% in 2021. 

For surface longliners, the rate of utilisation of fishing opportunities has been 100% since 
the start of the Protocol. This suggests that access to São Tomé and Príncipe’s fishing zone 
is crucial for supporting vessel strategies in the southern Atlantic Ocean, particularly in the 
offshore areas. Spain indicated that the number of fishing authorisations for vessels of this 
category could be increased to meet the demand from operators. 

The question of the quantity available does not arise. The reference tonnage defined by the 
Protocol is not a catch limit, but an indicator used to set the flat-rate amount of EU financial 
compensation  for  access.  The  reference  tonnage  was  exceeded  in  2021,  resulting  in  the 
additional payments provided for in the Protocol. 

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

15 

 
The level of fees set for EU tuna vessel owners for access to the fishing zone is aligned with 
the levels of fees set at the time under comparable EU tuna fishing agreements. 

It was not possible to obtain information on the amounts of fees paid by owners of non-EU 
tuna vessels entering the fishing zone under arrangements with national authorities (‘trade 
agreements’  under  the  2022  Fisheries  Law).  Transparency  on  these  financial  conditions 
would have responded better to the objective set by Article 1 (5) of the Protocol. 

That said, the systems for setting the level of charges are likely to be different and prevent 
any comparison. Fees paid by non-EU armaments are generally flat-rate and therefore not 
linked  to  the  catches  obtained,  as  confirmed  by  the  draft  implementing  text  of  the  2022 
Fisheries Law revised during the evaluation mission for direct access to fishing licenses for 
non-EU foreign tuna vessels. 

For  EU  vessels,  the  fees  shall  consist  of  a  flat-rate  part  and  a  variable  part  based  on  the 
quantities  of  catches  obtained.  Depending  on  the  catches  obtained  in  São  Tomé  and 
Príncipe’s fishing zone, DG MARE data for the period 2020-2022 indicate that an EU tuna 
seiner may pay the minimum annual fee of EUR 9 100 in the case of catches of less than 130 
tonnes,  but  may  pay  an  annual  fee  of  up  to  EUR  70  000  as  noted  for  tuna  seiners  who 
obtained catches of the order of 500 tonnes in 2021, with a record of almost EUR 90 000 in 
the case of one vessel. For surface longliners, vessels may pay the minimum annual fee of 
EUR 5 600 for catches of less than 46.5 tonnes, but a longliner paid EUR 25 000 in 2020 for 
catches above this threshold. 

As regards the technical rules governing fishing in the area, they are likely to be the same 
for all tuna seiners irrespective of their flags. The conditions applicable in São Tomé and 
Príncipe’s fishing zone are those imposed by ICCAT on all vessels, without less restrictive 
arrangements possible. This is in line with that of an NGO consulted for which the access 
conditions between the EU and non-EU tuna fleets would be close. As regards additional 
conditions  such  as  the  embarkation  of  national  seamen  or  the  embarkation  of  designated 
observers, the comparison cannot be made due to the lack of relevant information. 

It is to be noted that the Protocol  does not specify the need to make available to the public 
and between the two parties the amounts and the method(s) for calculating access fees paid 
by non-EU tuna vessels in order to be authorised to fish in the São Toméan EEZ.  

2.3 Ensuring supply for the EU market 

The promotion of interactions between EU tuna vessels and São Tomé and Príncipe provided 
for in Article 8 of the Protocol has not been the subject of any specific activity, apart from 
the  compulsory  embarkation  of  national  seamen  during  fishing  operations  in  the  EEZ 
(Chapter V of the Annex to the Protocol).  

EU tuna vessels operating in São Toméan waters do not land their fishery products in São 
Tomé and Príncipe. Landing ports – transshipments used historically by these vessels, when 
active in this part of the South Atlantic, include the ports of Abidjan (Côte d’Ivoire) of Tema 

16 

 
(Ghana) and Dakar (Senegal), for EU tuna seiners, and Walvis Bay (Namibia) for EU surface 
longliners (targeted consultation, experience of consultants).  

The encouragement of port calls from EU vessels in São Tomé and Príncipe is, in practice, 
commercially  complex.  This  would  require  the  development  of  port  infrastructure  in  an 
integrated way and in competition with the ports mentioned above. A study is under  way 
concerning the supply, at least, of fuel and water to tuna vessels active in São Toméan waters. 
In terms of on-site landings and sales to local industries, the national market is probably too 
narrow to absorb landings from EU vessels without competing with local fishermen. Due to 
the challenges linked to the insularity and remoteness of the country, the development of 
industrial tuna processing plants is rather unrealistic at this stage. 

2.4  Encouraging  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   

As indicated above, catches obtained under the Protocol do not supply the local market and 
the São Toméan processing industry. EU tuna vessels operating in São Toméan waters do 
not use São Tomé and Príncipe’s port services. EU tuna vessels prefer to use their historical 
ports in West Africa where they are used to call, board their crews, land their catches, supply 
water – fuel – salt, etc.  

The tuna fleet using the Protocol’s fishing opportunities provides marginal support for port 
and related activities in the EU. EU tuna vessels mainly use the services of the ports of call 
in West Africa to carry out their maintenance operations. 

Synergies in the implementation of the Agreement to the economic and social development 
of the country take place in particular through the use by the São Toméan Government of 
access rights and other charges paid by the EU and its tuna fleet and by the use of sectoral 
support funds, and to a marginal extent by taking on board a few São Toméan seamen and 
observers. 

2.5 taking into account specific interests: the nearby outermost regions of the EU and the 
EU fleet 

The majority of EU tuna seiners use Abidjan in Côte d’Ivoire for their port calls and to land 
their  catches  caught  in  the  Gulf  of  Guinea.  Spanish  longliners  use  mainly  Walvis  Bay 
(Namibia) to land their catches on the high seas and off the coast of São Tomé e Principe. 
The São Toméan fishing zone meets the interests of this fleet fishing on the high seas (EU 
tuna seiners and longliners) and in the network of waters under the sovereignty of the coastal 
States  of  Central  and  West  Africa,  in  particular  for  the  sea  basin  concerned  for  EU  tuna 
seiners Gabon, Angola and São Tomé and Príncipe.  

The Canary Islands, a territory of Spain, is the EU outermost region ‘closest’ to São Tomé 
and Príncipe. They are close to the Moroccan coasts and very far from São Toméan waters. 
The EU tuna fleet operating in São Toméan waters and the Gulf of Guinea does not regularly 
use  port  and  landing  services  or  transhipment  services  in  the  Canary  Islands,  apart  from 
occasional maintenance operations in the port of Las Palmas.  

17 

 
Objective 3: Supporting the development of a sustainable fisheries sector in partner 
countries  

3.1 Contribute to social, environmental, and economic development in Sao Tome e Principe. 
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? 

Sectoral  support  contributes  to  the  functioning  and  development  of  the  fisheries  sector 
through support for fisheries monitoring with training, acquisition of equipment, payment of 
contributions  to  the  collection  of  scientific  data,  and  development  of  small-scale  fishing 
(improvement of fishermen’s conditions through support for fleet and equipment renewal). 
However, the level of implementation of activities for small-scale fishing is still low at just 
under one year from the end of the Protocol.  

The use of sectoral support is not sufficiently documented due to the absence of an annual 
activity monitoring report. The annual report on the results of the sectoral support provided 
for in Article 4 (4) of the Protocol, the content of which had been described in a document 
annexed to the minutes of the Joint Committee meeting in October 2020, was not submitted 
to the Joint Committee by the national authorities.  

Implementation was nevertheless monitored by exchanges in the Joint Committee and by 
exchange of letters to validate the payment of tranches 2 and 3 of the sectoral support funds 
(out of 5 instalments in total). The information available does not allow a third party to have 
a clear picture of the activities carried out. These reports would have made it possible, for 
example,  to  draw  up  a  ‘detailed  analysis  of  sectoral  support  on  the  economic  and  social 
benefits expected throughout the geographical area covered by the current Protocol. 

3.2  Promote  the  employment  of  local  seafarers,  improve  infrastructure  and  encourage 
landings,  support  the  third  country  in  the  development  of  local  fisheries  and  processing 
industry  in  the  EU,  domestic  markets  and  those  of  certain  third  countries.  Creating 
employment directly and indirectly.    

EU  vessels  are  required  to  take  on  board  a  minimum  number  of  São  Tomé  and  Príncipe 
seamen each year during their fishing activities in São Toméan waters; for example, from 
2022, at least ten seamen are to be taken on board (Annex to the Protocol, Chapter V). The 
number of São Toméan seamen used by EU tuna vessels accessing the fishing zone in São 
Toméan waters has so far been low: between 2 and 3 São Toméan seamen per year for the 
entire EU tuna fleet in 2022 and 2023, which is below the minimum number required by the 
Protocol.  

The main reasons for this are (a) the use of well-trained and experienced crew already in 
place and contracted over the long term; (b) the possibility of meeting the clause by paying 
a compensatory amount in the event of non-embarkation of São Toméan seamen; and (c) a 
clause in its current terms which are too restrictive because it does not take account of the 

18 

 
need  for  arms  to  comply  with  similar  clauses  in  other  protocols  implementing  SFPAs  in 
West Africa.  

Some Member States also indicate that they have not received the list of qualified and fit 
seamen referred to in the Protocol (Chapter V of the Annex) or that the seamen do not meet 
the qualifications required by Appendix 6 to the Protocol. However, São Toméan seamen 
have been trained in Portugal. The 2019-2024 sectoral support funds financed these training 
courses in Portugal. The situation seems to be slightly improving, although the number of 
seamen  signed  on  per  year  is  still  below  the  limits  laid  down  in  the  Protocol:  three  São 
Toméan seamen were signed on Spanish longliners in 2023. 

The catches landed are marketed in the EU market and in the markets of other third countries 
in West Africa (no landing in São Tomé and Príncipe). 

4.2.  Efficiency and Economy11 

Efficiency: 

Success criterion (s) 
The EU financial contribution is proportionate to the fishing 
opportunities made available in the Protocol and by category  
Shipowners’  contribution  is  proportionate  to  their  actual  catches  and 
benefits compared to their operational costs and total revenues  
São Tomé and Principe  benefits from a fair share of the added value of 
catches.  

Objective 
The  Protocol  is  cost-effective 
for the EU 
SFPA provides good value for money 
for EU shipowners 
The financial compensation for fishing 
opportunities is beneficial for the EU 
and São Tomé and Principe  
The sectoral support and cooperation 
measures in the Blue Economy, small-
scale 
food  security 
approved  in  the  initial  programming 
matrix were carried out at reasonable 
costs. 
Since  the  entry  into  force  of  the  Protocol  at  the  end  of  2019,  annual  catches  of  EU  tuna 
vessels have remained below the reference tonnage of 8 000 tonnes in 2020, 2022 and 2023, 
but exceeded it in 2021. This indicates that the financial contribution for access was above 
needs for three years but proportionate to the needs in 2021. This reflects the unpredictable 
nature of tuna abundance in the Sao Tomean fishing zone. For the record, the minimum EU 
access contribution is relatively modest compared to EU budget commitments under other 
agreements (EUR 440 000 per year). 

All activities included in sectoral support have been properly used and have 
benefited the EU and São Tomé and Principe  in environmental, social and 
economic terms. 

fisheries  and 

The  analysis  of  the  economic  impact  of  the  access  part  of  the  Protocol  shows  a  positive 
cost/benefit ratio for the EU side. It is estimated that every euro invested by the EU in the 
financial compensation for access to the resource generated EUR 6,60 in added value for the 
benefit of both parties, including EUR 5,33 for the benefit of the EU. 

Moreover,  the  activities  of  sectoral  support  focused  on  three  strands  of  intervention: 
strengthening  fisheries  governance  by  improving  fisheries  monitoring  and  national  and 
international governance of the sector, developing aquaculture and developing local fisheries 

11 See page 78 of the evaluation report 

19 

 
 
 
(small-scale fisheries). Within these axes of intervention, the funds have been used correctly 
in terms of improving fisheries monitoring, acquiring fisheries data, financing compulsory 
contributions  to  regional  fisheries  organisations,  basic  training  in  aquaculture.  Small 
infrastructure  has  been  rehabilitated  or  built  for  the  benefit  of  fishing  and  vendor 
communities for a total of around EUR 200 000: Praia Melão, Mouro Peixe, and Agua Izé. 
According to the information collected during the evaluation by the external consultant, the 
funds are used in a reasonable manner: no budget overrun on the activities to be carried out. 

However, the pace of implementation is slow, with a total payment of 60% of the EUR 2.2 
million available for sectoral support and a budget execution of just over 30% of the EUR 
2.2 million that can be committed (cf. “economy” evaluation criterion below). The planned 
activities for the development of aquaculture have made very little progress. The feasibility 
study of a hatchery for the supply of fry should take place at the beginning of this fifth and 
final year of the Protocol.  

The  contribution  of  EU  shipowners  under  the  2019-2024  Protocol  is  aligned  with  the 
contribution provided for under the other EU agreements at the time (EUR 70 per tonne).  

On average over the period 2020-2022, fees paid by EU tuna seiners accounted for 6% of 
turnover and 3% for EU surface longliners (Table 18). The difference is explained by the 
fact that both categories are subject to the same level of access pricing (EUR 70 per tonne), 
but with higher first-sale catch values for surface longliners than for tuna seiners (Table 29). 
The proportion of the cost of access fees in the value added generated by fishing operations 
in São Tomé and Príncipe’s zone confirms a greater weight for tuna seiners (18%) than for 
surface longliners (10%).  

Regarding cost-effectiveness of the Protocol, the period covered by the Protocol coincided 
with a period during which the profitability of the EU tuna seiners segment was significantly 
lower than in previous years, particularly in 2021 and 2022 as a result of the reduction in the 
number  of  days  at  sea  attributable  to  the  COVID  pandemic,  the  impact  of  ICCAT 
management measures on tuna seiners’ operations, and the inflation of input costs following 
the Ukrainian crisis from 2022. According to the evaluation study’s estimates, the segment 
of  surface  longliners  has  maintained  a  positive  level  of  profitability,  but  at  a  relatively 
marginal level. The period covered by the Protocol was therefore a period during which the 
EU tuna fleet was economically unprofitable, as confirmed by STECF analyses and recent 
decisions to terminate the activities of certain armaments. 

It should also be noted that the system for fixing the amount of access fees for EU vessels 
provided for in the Protocol makes it possible to maintain a certain degree of proportionality 
between the amount of the fees and the actual catches by incorporating a variable share based 
on  the  quantities  caught.  In  the  context  of  the  2019-2024  Protocol,  the  variable  share  of 
contributions accounted for the majority (52%) of total contributions paid by the shipowners. 

Furthermore, the economic analysis shows that São Tomé and Príncipe received financial 
compensation  for  access  equivalent  to  EUR  160  per  tonne  of  tuna  caught  in  its  area  on 
average  per  year  (EU  share  and  shipowner  share).  This  amount  is  above  the  minimum 

20 

 
amount  provided  for  in  the  Protocol  (EUR  120  per  tonne)  on  account  of  catches  which 
averaged over the period 2020-2023 at 71% of the reference tonnage of 8 000 tonnes,  

The  economic  benefits  of  EU  tuna  vessels  in  São  Tomé  and  Príncipe’s  fishing  zone 
generated a total economic added value of EUR 7.2 million per year over the period 2020-
2022,  with  EUR  1  million  (13%)  going  to  São  Tomé  and  Príncipe.  The  added  value 
generated for São Tomé and Príncipe is limited to EU and shipowners’ access payments (94 
%) and compensation paid by shipowners for non-embarkation of seamen (6%). Due to the 
lack of interaction between EU fleets and the national fishing sector (use of national ports, 
landings/sales  of  catches  to  local  industries,  employment  of  nationals),  São  Tomé  and 
Príncipe did not benefit from any indirect economic benefits stemming from the agreement. 
The value-added distribution balance shows that the majority (56%) of the economic benefits 
of EU vessels’ activities in the fishing zone are captured by other countries that interact with 
the EU tuna fleet (Côte d’Ivoire, Ghana, Senegal, Cabo Verde). 

Economy:  

sectoral 

support, 

Objective 
The  EU  contribution,  in  particular 
is 
for 
proportionate  to  the  needs  of  São 
Tomé  and  Príncipe  and 
its 
absorption capacity 
Sectoral  support  payments  were 
made  within  the  time  limits  laid 
down  in  Articles  3  and  4  of  the 
current Protocol. 

Success criterion (s) 
The EU contribution for sectoral support is aligned with 
national  and  local  needs  and  absorption  capacity.  The 
total  amount  of  sectoral  support  shall  be  used  in 
accordance with the agreed schedule and adapted to the 
needs of the partner country. When there were amendments 
to the initial Sector Support Programme, they promoted the 
use of financial support and contributed to the sustainable 
development of the country. 

According to the Protocol, the sectoral support funds are to be disbursed annually, i.e. in 5 
tranches  of  EUR  440  000,  which  makes  a  total  of  EUR  2.2  million  over  five  years,  in 
accordance  with  Article  3  of  the  Protocol.  These  payments  must  be  made  after  the  Joint 
Committee  has  given  a  favourable  opinion  on  the  proper  absorption  and  use  of  sectoral 
support funds in accordance with Article 4 of the Protocol and in accordance with Article 32 
(2) of the CFP (Regulation (EC) No 1380/2013).  

The EU contribution for sectoral support is broadly aligned with national and local needs, 
which  are  important  in  particular  for  inter-ministerial  fisheries  monitoring  (e.g.  in 
collaboration  with  the  coast  guard),  for  the  acquisition  of  fisheries  data  (collection  – 
processing – data analysis), and for supporting the sustainable development of small-scale 
fisheries.  

However,  the  Directorate  for  Fisheries  and  Aquaculture  of  São  Tomé  and  Príncipe  has 
encountered  difficulties  in  using  the  sectoral  support  budgets  under  the  current  Protocol 
owing,  inter  alia,  to  the  COVID  crisis  in  2020,  changes  in  direction  weakening  the 
sustainability of the implementation of the activities accepted by both parties at the start of 
the Protocol, and also a significant proportion of sectoral support initially dedicated to the 
development of aquaculture (fish farming), 43% of the total funds, which have been very 

21 

 
 
little  consumed  so  far  (see  8.4  ‘relevance’  below).  Delays  that  are  manageable  and  not 
manageable by DPA have also taken place in the selection of providers planned to carry out 
the activities. 

As a balance sheet, at the end of the first quarter of 2023, that is to say, after three years of 
application of the Protocol, consumption of the first tranche of sectoral support reached an 
implementation rate of almost 90%. The two parties had agreed at the first meeting of the 
Joint Committee to ensure that the next instalment would be paid on the basis of a utilisation 
of at least 80% of the previous instalment. At the request of the São Toméan authorities and 
the submission of a revised programme for 2023 and 2024, the two parties agreed, following 
the  agreement  of  this  new  programming,  to  make  the  combined  payment  of  the  2  and  3 
annual  instalments  of  the  sectoral  support  to  speed  up  the  use  of  the  remaining  sectoral 
support funds. The two instalments were paid in August 2023. 

The amendments to the initial programme should encourage the implementation of the funds 
by  redirecting  part  of  the  funds  allocated  to  axis  2  for  the  development  of  aquaculture 
towards sustainable development activities improving working conditions in the small-scale 
fisheries subsector. Article 4 (5) of the Protocol requires, however, that the final payment of 
sectoral  support  funds  be  made  within  6  months  of  the  end  of  the  current  Protocol.  The 
implementation rate for tranches 2 and 3 was around 30% in January 2024, i.e. around one 
third  of  all  the  funds  of  the  sector  support  which  can  be  committed  at  approximately  11 
months from the end of the Protocol (estimates by the evaluators on the basis of the data 
made available to them).  

As regards the payment rules for sectoral support, payments from the funds must take place, 
according  to  the  Protocol,  on  ‘the  Fisheries  Development  Fund  account’.  However,  in 
February 2020, tranche 1 of Sectoral Support 2019-2024 was paid into the Public Treasury 
account,  an  account  used  to  pay  access  fees  and  sectoral  support  under  the  2014-2018 
Protocol, which is not in accordance with the terms of the 2019-2024 Protocol. In the Joint 
Committee of March 2023, the two parties agreed that these fees should be paid into a bank 
account  of  a  commercial  bank  under  the  name  “Fisheries  Development  Fund”.  The 
procedure for the use of an account in a commercial bank had been authorised by the State 
Treasury  in  the  Joint  Committee  in  March  2023  and  each  expenditure  effected  using  the 
funds on that account was countersigned by the Treasury Directorate. In August 2023, in 
accordance with the decision of the Joint Committee in March 2023, tranches 2 and 3 were 
paid into this bank account. 

60% or, more optimistically, 75%, of the EUR 2.2 million of the funds available for sectoral 
support should be used quite easily, taking into account the fact that regular expenditure will 
come on the 3-4 tranches, expenditure on fishing equipment and the renewal of the small-
scale fishing fleet, and the possibility for the Joint Committee to approve payment of the 
final balance of the sectoral support funds within 6 months of the 2019-2024 Protocol having 
expired. 

4.3.  Coherence:  

Objective 

Success criterion (s) 

22 

 
organisations 

Coherence  between  the  Protocol  and 
the  CFP  in  general,  and  with  its 
international  dimension,  and  with 
regional fisheries policy (RFMOs, and 
other 
including 
COPACE, and the network of regional 
and sub-regional PAPDS) 
To  what  extent  the  Protocol  and  its 
implementation  are  consistent  and 
complementary  with 
other  EU 
interventions  such  as  EEAS,  INTPA, 
SANTE,  TRADE  and  TAXUD  DG 
MARE B4, B2, B1. 

The  Protocol  is  aligned  with  the  CFP  in  general  and  contributes  to 
achieving the EU’s objectives at regional level – including the creation of a 
regional network of APPDS; and consists of other APPDS in the region and 
with the objectives of the RFMOs and other organisations  

The Protocol makes a substantial contribution to the effectiveness of other 
EU  policies  and  vice  versa.  The  Protocol  and  its  implementation  are 
coherent and contribute positively to other interventions.  

is 

the  agreement  and 

its 
How 
implementing protocol consistent with 
national  fisheries  policy  and  well 
coordinated with regional policies? 
How does the Agreement contribute to 
the achievement of the United Nations 
Millennium Development Goals? 

The Protocol contributes to the achievement of the objectives identified at 
national,  local  and  regional  level.  Authorities,  stakeholders  and  STPil 
society are informed of the contribution. 

The Protocol contributes to the sustainable management of fishing in the 
fishing zone covered by the current Protocol.  

At international level, the Protocol contributes to the implementation of the 
United Nations Millennium Development Goals (MDGs).  

Overall, the Protocol is consistent with the common fisheries policy. It participates in the 
network of fishing areas accessible to EU tuna vessels through the implementing protocols 
of other SFPAs on the coast of the eastern Atlantic. The fishing conditions laid down by the 
Protocol are in line with the conservation and management rules adopted by ICCAT, and 
with the regional fisheries policies of COREP and CECAF. 

The Protocol and its implementation are compatible, coherent and complementary to other 
EU  interventions  in  São  Tomé  and  Príncipe,  in  particular  the  FISH4ACP  programme 
focusing on strengthening the value chains of fishery products in São Tomé and Príncipe. 
The  services  of  the  European  Commission  and  the  EU  ensure  complementarity  of  their 
ongoing and future interventions through inter-service dialogues. 

Finally, the Protocol meets national objectives both in terms of access and development of 
the partner country’s fisheries sector. The intervention is consistent with the UN Sustainable 
Development  Goals  (SDGs).  However,  the  provision  of  public  information  on  the 
contribution of sectoral support to the São Toméan national fisheries policy is virtually non-
existent. 

4.4.  EU added value 

intervention  under 

Objective 
What is the value added resulting from 
the  EU 
the 
Protocol, compared to the absence of 
an agreement/protocol. To what extent 
could Member States have put in place 
appropriate alternative measures. 

Success criterion (s) 
EU intervention adds value compared to Member States’ interventions  

23 

 
  
  
  
 
What  is  the  added  value  of  EU 
intervention under the Agreement and 
its  Protocol  compared  to  what  could 
be achieved by the EU fleet outside the 
framework of the Agreement 

The agreement and its protocol bring substantial benefits) the EU and at 
local and national level, compared to private agreements.  

First  of  all,  in  the  absence  of  a  fisheries  agreement  between  the  EU  and  São  Tomé  and 
Príncipe, EU tuna vessels would be free to negotiate direct authorisations for access to the 
São Toméan fishing zone. This negotiation is then framed, for EU shipowners, by Section 3 
of  Regulation  (EU)  2017/2403  on  the  sustainable  management  of  external  fishing  fleets, 
known as the SMEFF Regulation. In view of Article 13 of the current SFPA, this assumption 
is  uncertain,  however:  the  possibilities  for  termination  of  the  SFPA  are  limited  to  the 
occurrence of “abnormal events”. In view of São Tomé and Príncipe’s interest in attracting 
tuna vessels to its fishing zone, an interest confirmed by the authorisations given to vessels 
flying other flags, it is likely that EU tuna vessels will be able to get their requests for access 
accepted,  where  appropriate.  In  this  case,  shipowners  are  not  supported  by  the  EU  when 
negotiating  their  access  conditions,  but  will  nevertheless  have  to  comply  with  ICCAT’s 
minimum conservation and management rules which apply irrespective of the fishing zones. 

In addition,  the EU’s involvement  through the implementation of a Protocol  to  an  SFPA 
offers the following added values:  

•  The establishment of a platform for sectoral dialogue between the EU and São Tomé 
and Príncipe. It aims to ensure that the objectives of the Common Fisheries Policy 
(CFP)  are  promoted  at  both  national  and  sub-regional  level.  It  complements  and 
operationalises  the  one  already  established  under  the  general  framework  of  the 
Cotonou Agreement and its successor the Samoa Agreement. 

•  The possibility to monitor the activities of vessels flying the flag of an EU Member 

State when operating in São Tomé and Príncipe’s fishing zone.  

•  The involvement of the EU makes it possible to establish binding access conditions 
in line with applicable international obligations and provisions in other agreements 
in the region, with the possibility for the European Commission on behalf of the EU 
to ensure that these access conditions are fair and non-discriminatory. 

•  The  EU  also  ensures  that  sectoral  development  is  carried  out  in  synergy  with  the 
interventions  of  its  Member  States  in  the  development  of  the  fisheries  sector  and 
consistent  with  those  carried  out  in  neighbouring  coastal  states  with  active 
FPAs/SFPAs (e.g. Gabon). 

In  the  event  that  the  SFPA  were  terminated,  in  comparison  with  direct  shipowners 
intervention, EU intervention brings added value to the EU through the allocation of a fund 
for  the  development  of  the  fisheries  sector  and  public  compensation  for  access,  both 
implemented  in  accordance  with  the  objectives  of  the  Common  Fisheries  Policy.  Within 
direct interventions, part of the revenue for São Tomé and Príncipe could be used as sectoral 
support. Its amount and objectives of intervention would then be at the sole discretion of the 
following two parts: the Government of São Tomé and Príncipe and EU tuna vessel owners. 
The EU would then no longer be involved. 

24 

 
 
4.5.  Relevance  

To what extent do the objectives set out 
in  the  FPA  and  its  implementing 
protocol still correspond to the needs 
of the EU, its Member States and EU 
vessel owners? 

to 

is  relevant 

The  Protocol 
the 
objectives  of  the  RFMOs  and  the  EU 
Regional  Network  of  Agreements.  To 
what  extent  is  it  relevant and  creates 
significant impacts 

The  implementation  of  the  JPA  and  its  Protocol  is  aligned  with  the 
objectives  of  resource  and  environmental  sustainability;  support  for  the 
development  of  a  sustainable  fisheries  sector  at national  and  local  level; 
facilitating  the  integration  of  coastal  states  into  the  world  economy; 
improving  scientific  and  technical  knowledge,  supporting  economic 
exchanges  and  sustainable  economic  and  social  development)  and 
adequately addressing the national and local needs of the EU and its fleet  
For  highly  migratory  species,  the  Protocol  contributes  to  the  objectives 
defined at the level of RFMOs and other regional organisations, including 
CECAF,  and  maintains  a  network  of  SFPAs  in  the  region.  It  creates 
synergies between the EU and neighbouring countries in the RFMOs.  

The Protocol meets the needs for the tuna fishing fleet of the EU, the EU and São Tomé and 
Príncipe.  The  programming  of  sectoral  support  is  generally  relevant,  in  line  with  the 
principles of the Common Fisheries Policy: support for the fight against IUU fishing, the 
improvement  of  scientific  knowledge  and  the  sustainable  development  of  the  fisheries 
sector.  Although  meeting  the  expectations  of  the  São  Toméan  authorities,  the  initial 
allocation of almost half of the sectoral support funds for the development of aquaculture 
seems disproportionate. However, the reallocation of part of these funds in the 4th year to 
the other areas of intervention has taken place and could still take place in the final year of 
the Protocol in order to speed up the absorption of sectoral support funds. The relevance of 
sectoral support to the objectives of the CFP would then be improved. 

In  addition,  the  Protocol  is  part  of  a  coherent  regional  network  of  protocols  for  the 
implementation of EU fisheries agreements allowing EU tuna vessels access to important 
fishing areas under the binding framework of these agreements. The Protocol contributes to 
the  objectives  of  ICCAT  by  ensuring  that  the  management  and  conservation  measures 
applicable to the exploitation of tuna in the São Toméan fishing zone are aligned with those 
adopted by ICCAT, to which both parties are signatories. 

4.6.  Acceptability 

Objective 
EU vessel owners are satisfied with the 
Protocol 
Local, national and EU civil society is 
satisfied with the Protocol 

The national and local fishing sector is 
satisfied by the Protocol 

Success criterion (s) 
EU vessel owners are met by the technical and financial conditions of the 
Protocol and support its renewal (with possible adaptations) 
Civil society representatives are satisfied with the environmental and social 
conditions  of  the  SFPA  and  the  Protocol  and  support  its  renewal  (with 
possible adaptations) 
National and local fish owners and processors in São Tomé and Príncipe 
do not compete with the EU fishing fleet and fish processors. They benefit 
from  purchasing  opportunities  and  support  the  renewal  of  the  Protocol 
(with possible adjustments). 

Fish processors in the EU are satisfied 
with the Protocol 

The needs of fish processors in the EU are met by the technical and financial 
conditions  of  the  Protocol  and  support  its  renewal  (with  possible 
adaptations) 

The local and national administration 
is satisfied with the Protocol 

The  local  and  national  partner  administration  is  satisfied  with  the 
implementation of the Protocol and supports its renewal 

25 

 
The EU shipowners are generally satisfied with the technical and financial conditions of the 
Protocol and support its renewal with some improvements (see the following ex-ante chapter 
for more details on the latter). 

For national and international civil society, the Fisheries Agreement between the EU and 
São  Tomé  and  Príncipe  promotes  the  acquisition  of  external  funds  for  the  state  and 
contributes to the development of the sector. However, it regrets the lack of information on 
access  for  non-EU  foreign  tuna  vessels  despite  the  Protocol’s  transparency  clause.  It 
recommends regular consultation of non-state actors in the EU and São Tomé and Príncipe 
for the programming and implementation of sectoral support with a view to improving its 
social and economic impact on stakeholders in the fisheries sector. It supports the renewal 
of  the  Protocol  but  calls  on  the  parties  to  fully  implement  the  transparency  and  non-
discrimination clauses included in the principles of good governance of fisheries agreements, 
as well as an improvement of the clause relating to the embarkation and contracting of São 
Toméan seamen. 

The local national fisheries sector has not expressed any particular dissatisfaction with the 
Protocol. There is no direct competition with fishermen in the archipelago: the EU tuna fleet 
operates far from the coast of the archipelago and their products are not landed in São Tomé 
and  Príncipe.  However,  local  stakeholders  would  have  liked  and  would  like  to  be  more 
consulted, particularly in the event of a renewal of the current Protocol. 

With regard to the partner country’s administration, it is generally satisfied with the Protocol 
and asks for it to be renewed with certain improvements. 

5.  WHAT ARE THE CONCLUSIONS AND THE LESSONS LEARNT 

5.1.  Conclusions 

Based on the evaluation and on objective analysis of the information gathered, the evaluation 
concludes that  criteria are generally fulfilled. The FPA with  São  Tomé e Príncipe is  less 
performant in providing a share of economic added value to the country as there are little 
economic interactions between the EU operators, using more performant port infrastructures 
for landing and transforming in Côte d’Ivoire. There is also little perspective for São Tomé 
e Príncipe to be able to compete with such established processing pattern and gain shares in 
this market.  

Furthermore,  specific  and  relevant  recommendations  for  future  negotiations  on  the  new 
protocol between the EU and São Tomé and Principe can be made. 

Among all options considered, the renewal of the Protocol at the end of its implementation 
period (18 December 2024) clearly appears to be in the interest of both parties and as the 

26 

 
 
most beneficial policy option. On the other hand, the option of not renewing the Protocol 
would not be beneficial for any of the parties12.  

Regarding the access conditions for the future Protocol, the setting of the reference tonnage 
should  be  based  on  the  level  of  utilisation  of  fishing  opportunities  of  the  current 
implementing Protocol. 

With regard to technical measures, the embarkation of national seamen seems to be the focus 
for São Tomé e Príncipe, while the EU operators would give preference to the training of 
seamen and their adaptation to the working environment as a prerequisite to any boarding 
obligations.  

Concerning the sectoral support component, the future Protocol should provide for clauses 
on monitoring and evaluation, including the submission by São Tomé and Principe to the 
Joint Committee of annual progress report and a final evaluation report (before the expiration 
of the Protocol) about the impact of the sectoral support on the development of their sectoral 
fisheries  policy.  Clauses  related  to  the  visibility/communication  of  the  sectoral  support 
activities  should  also  be  included.  Particular  attention  should  further  be  attributed  to  the 
efficient  programming  of  the  sectoral  support  activities,  refraining  from  very  complex 
objectives  that  hinder  implementation  and  seeking  external  technical  expertise  when 
necessary. The programming of sectoral support should be guided by the activities identified 
by the national sectoral policy for the coming period, while the possibilities for supporting 
the implementation of this national policy will depend on the budget availability which will 
be the result of the negotiation process.  

5.2.  Lessons learned  

The ex-post evaluation of the Protocol implementing the Fisheries Partnership Agreement 
for the period 2019-2024 shows that the Protocol has generally succeeded in achieving its 
main objectives.  

The main learnings stemming from this ex-post evaluation are: 

•  On  technical  conditions,  compulsory  boarding  of  seamen  should  be  built  up 

progressively, and starting from adequate training of candidate seamen.  

•  On sectoral  support, some support was agreed in favour  of the  aquaculture  sector 
without  sufficient  analysis  of  the  strengths  and  weaknesses  of  such  sector  in  São 
Tomé e Príncipe.  

•  The implementation of the activities funded under the sectoral support by São Tomé 
and  Principe  has  been  subject  to  noticeable  delays  despite  the  relatively  modest 
annual budgets (around EUR 440 000 per year). These delays were partly explained 
by cyclical events outside the control of the authorities responsible, administrative 
problems,  but  also  by difficulties linked to  the implementation of the multiannual 
programme adopted at the beginning of the Protocol. It is therefore much needed to 
prepare  a  clear  and  detailed  programme  for  a  future  sectoral  support  component 

12 See report, page 76 

27 

 
 
aiming  at  improving  the  pace  of  implementation,  meeting  both  national  and  EU 
priorities. 

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 Fisheries Partnership Agreement between the EU and 
São Tomé and Principe.  

6.1.  Problem analysis and needs assessment   

In the context of the intervention logic in Figure 1, this section outlines the possible current 
and future needs of both Parties to the current implementing Protocol and the Agreement. 

6.2.  Current and future needs of São Tomé and Principe  

São Tomé and Príncipe’s fishing zone is an attractive zone as it is on the route of migration 
of  highly  migratory  species  from  the  Atlantic.  Access  agreements  with  foreign  interests 
enable the country to exploit its fishing potential and strategic position on tuna migration 
routes  through  budgetary  revenue  and  spill-over  effects  on  the  employment  of  national 
seafarers. 

Through  its  programme  for  the  sustainable  intensification  of  agricultural  production  in 
fisheries  and  livestock  farming,  São  Tomé  and  Príncipe  has  ambitions  to  support  the 
development  of  its  fisheries  sector  by  improving  the  legal  framework,  improving  the 
working conditions of small-scale fishermen, increasing the contribution of fisheries to the 
food balance and improving scientific knowledge. São Tomé and Príncipe therefore needs 
to be able to secure multiannual budgetary resources to meet the priorities identified for the 
sustainable development of its sector. 

The São Toméan authorities support the renewal of the Protocol. According to the results of 
the consultations, a new protocol should incorporate the following elements: 

• 

Issue of fishing authorisations through a local representative (an agent) pursuant to 
the implementing legislation of the 2022 Fisheries Act; 

•  Desire to maintain and apply more strictly the São Toméan seamen’s embarkation 
clause, with a possible increase in the compensatory payment in the event of non-
compliance to make the penalty dissuasive; 

•  Willingness to increase the number of national scientific observers on the basis of 

the observer clause in the current Protocol. 

As  São  Tomé  and  Príncipe  officially  declared  its  application  for  the  FiTI  Fisheries 
Transparency  Initiative in  December 2023, sectoral  support for the possible future  SFPA 
protocol to finance a website to improve the level of transparency required, inter alia, by the 
Protocol and FiTI requirements, shall be envisaged. 

28 

 
 
6.3.  Current and future needs of the EU  

For  the  EU,  the  agreement  creates  a  framework  for  cooperation  on  improving  ocean 
governance and developing the country’s fisheries sector and blue economy. 

The EU is committed to improving ocean governance. In addition to its actions with relevant 
RFMOs, such as ICCAT, the EU can encourage the establishment of coherent measures to 
preserve and conserve stocks exploited through its network of fisheries agreements when 
they  are  active  (with  a  protocol  in  force).  It  also  aims  to  promote  management  based  on 
scientific advice, and transparency with due regard for fair treatment between the different 
fishing  fleets.  The  SFPA  between  the  EU  and  São  Tomé  and  Príncipe  complements  a 
network of agreements covering a large part of the fishing areas of coastal states bordering 
the western tropical Atlantic. 

As part of its efforts to improve ocean governance, the EU considers the international fight 
against  illegal,  unreported  and  unregulated  (IUU)  fishing  as  one  of  its  priorities.  This  is 
achieved in  particular through Regulation  (EU)  No 1005/2008  and support for numerous 
development programmes aimed at strengthening the capacity of developing coastal states 
to  combat  this  scourge.  To  this  end,  EU  vessels  must  maintain  exemplary  behaviour, 
regardless of their fishing zone. This implies the establishment of oversight mechanisms to 
enable  the  EU  and  the  Member  States  concerned  to  assume  their  responsibilities  as  flag 
States. For example, the EU needs to have framework mechanisms in place to supervise the 
activity  of  fleets  in  the  waters  covered  by  a  possible  future  protocol,  while  respecting 
international law and the objectives of the EU’s Common Fisheries Policy (CFP). By means 
of sectoral support for a possible future protocol, the EU’s objective is thus to contribute in 
particular to the fight against IUU fishing. 

In its external action, the EU committed to the international community to play a leading 
role in the implementation of the 2030 Agenda for Sustainable Development adopted by the 
United Nations in 2015. The EU therefore needs to be able to mobilise an instrument that 
contributes to achieving the United Nations Sustainable Development Goals, in particular 
the objectives relating to life below water (SDG 14) in São Tomé and Príncipe waters, in 
synergy with other interventions by the EU and its Member States. 

6.4.  Current and future needs of São Tomé and Principe and the EU together 

The creation of a framework for sectoral policy dialogue with dedicated funding in synergy 
with  other  EU  interventions  enables  both  parties  to  exchange  and  jointly  implement 
initiatives  to  promote  the  sustainable  development  of  the  fisheries  sector,  including 
initiatives to cooperate in the fight against IUU fishing and to strengthen fisheries research. 

6.5.  Current and future needs of the EU fleet 

For EU shipowners, there is a need for stable access agreements for multiannual periods, 
allowing vessels  to  plan their regional fishing  strategies over several  seasons. Fleets  also 
need access conditions framed by a robust legal instrument which clearly sets out the rights 
and  obligations  of  each  party  (vessels  and  coastal  States),  with  opportunities  for  fair 
arbitration in the event of a presumption of non-compliance by one of the two parties. 

The owners of EU fishing vessels consulted and representing the two categories of fishing 
authorised  to  fish  in  São  Toméan  waters  under  the  2019-2024  Protocol  recommend  the 
renewal of the current Protocol. 

29 

 
6.6.  EU added value   

Should the Protocol be renewed, only the EU is competent to negotiate in accordance with 
the Treaty on the Functioning of the European Union (TFEU). 

Beyond  this  obligation  stemming  from  the  TFEU,  the  involvement  of  the  EU  in  the 
negotiation of a new Protocol brings a clear added value similar to that identified in the ex-
post part of the evaluation. This is related to:  

(i) a mandate from the EU to ensure that the Protocol and its implementation are in line with 
international and CFP standards and consistent with other agreements concluded with coastal 
States in the region,  

(ii) the possibility for the EU to have an instrument to implement its sectoral policy at sub-
regional  level  through  the  leverage  effect  given  by  a  network  of  agreements  and  its 
interventions within ICCAT, and  

(iii) a specific instrument for bilateral sectoral cooperation with São Tomé and Principe , as 
well as the possibility of coordinating with its other Member States’ cooperation and  São 
Tomé and Principe , will be able to have an instrument enabling it to implement its sectoral 
policy at sub-regional level by means of the leverage given by a network of agreements and 
its interventions within ICCAT. 

6.7.  Policy and management objectives   

The  objectives  of  fisheries  agreements  are  guided  by  Articles  31  and  32  of  the  CFP 
Regulation, taking into account the 2012 Council conclusions13 on the external dimension 
of  the  CFP.  In  line  with  EU  policy  on  fisheries  agreements,  the  objectives  of  future 
intervention under the Fisheries Partnership Agreement concluded between the EU and São 
Tomé and Principe in 2008 must be based on the general and specific objectives which guide 
the EU’s intervention logic for all FPAs and SFPAs, namely: 

General  objective  1:  a  contribution  to  resource  conservation  and  environmental 
sustainability through the rational and sustainable exploitation of marine resources in São 
Tomé and Principe waters, with the following specific objectives (SOs): 

•  SO  1.1:  Ensure  the  conservation  of  tuna  stocks  through  the  application  of 
conservation  and  management  measures  adopted  within  the  ICCAT  multilateral 
framework. 

•  SO 1.2: Promote the same principles and apply the same standards as those applied 

in EU waters for fisheries management. 

•  SO 1.3: Improve the scientific and technical evaluation of fisheries in São Tomé and 
Principe waters, in particular through support for data collection and transparency of 
the management framework. 

•  SO 1.4: Ensure compliance with the applicable rules and combat IUU fishing. 

General  objective  2:  support  for  the  activity  of  the  EU  distant  fishing  fleets  and  the 
maintenance  of  employment  linked  to  the  activities  of  these  vessels,  with  the  following 
specific objectives (SOs): 

13 Council conclusions on the external dimension of the CFP. 19.03.2012, 7086/12 

30 

 
 
•  SO 2.1: Obtain an appropriate share of available fishery resources in full proportion 
to the interests of around 20 EU tuna seiners in São Tomé and Principe waters 
•  SO 2.2: Ensure that fees paid by EU shipowners for fishing activities are fair, non-
discriminatory and proportionate to the benefits of access conditions while avoiding 
any discriminatory treatment towards EU vessels by promoting a level playing field 
between different fleets 

•  SO 2.3: Securing supply to the EU market and certain developing third countries 
•  SO 2.4: Encouraging the creation of a favorable environment for private investment 

and economic activities in São Tomé and Principe  

General  objective  3:  support  for  the  development  of  a  sustainable  fisheries  sector  in  São 
Tomé and Principe, with the following specific objectives (SOs): 

•  SO 3.1: contribute to the capacity building of São Tomé and Principe (in particular 
by  improving  the  management  framework,  control  and  surveillance  and  the 
collection of scientific data) 

•  SO 3.2: the definition of annual and multiannual objectives to be achieved in order 

to support the implementation of the national sectoral policy 

•  SO 3.3: evaluation of the results achieved in terms of impact, as well as on budgetary 

and financial needs 

•  SO 3.4: promote the employment of national seamen under conditions aligned with 
those  of  international  standards,  and  encourage  landings,  support  São  Tomé  and 
Principe  in  the  development  of  the  national  fisheries  sector  and  the  processing 
industry. 

6.8.  Policy options, including associated risks   

Two options are available: 

•  Renewal of the current protocol – option A (option A1 for maintaining the status quo 

and option A2 with adaptations where necessary), 

•  Non-renewal of the Protocol – option B. 

The information obtained from meetings of the Joint Committee and collected during the 
evaluation  shows  that  both  parties  are  willing  to  identify  ways  of  improving  the  overall 
effectiveness of the Protocol.  

Option A1 (status quo with identical terms) 

In the event of renewal under the same terms under option A1, discussions by the various 
parties on mechanisms to improve the implementation of the Protocol would not take place, 
in  particular  on  the  provision  of  information  on foreign  fishing  activities  in  São  Toméan 
waters, the more effective application of the seamen’s clause and the better monitoring of 
sectoral  support  by  means  of  activity  and  implementation  reports.  The  main  risk  of  this 
would be to encounter the same problems as the current Protocol 2019-2024. 

Option A2 (status quo with some improvements) 

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: 

31 

 
 
 
•  Duration of the Protocol: Around 5 years to ensure minimum short and medium-

term planning for the EU shipowners. 

•  Period of validity of licenses: It should include a mechanism of annual licenses per 
calendar year with a license pro rata temporis to cover the first calendar year of the 
Protocol would be appropriate. 

•  Issue of fishing authorisations: The granting of electronic fishing licenses in the 
medium term could be introduced in the possible future Protocol, with a contribution 
from the sectoral support for the Protocol to ensure that the São Toméan authorities 
use this system and are trained to do so.  

•  Compulsory embarkation of São Toméan seamen: There is  a strong likelihood 
that  the  seamen  clause  will  again  include  an  obligation  to  sign  on  São  Toméan 
seamen  (rather  than  ACP  seamen).  In  this  case,  the  minimum  threshold  of  São 
Toméan seamen to be signed on could be defined according to a percentage of São 
Toméan seamen to be taken on board in the São Toméan fishing zone out of the total 
number of seamen employed on board all tuna vessels active in São Toméan waters 
(and  not  according  to  a  minimum  number  over  the  whole  tuna  fleet).  The  term 
‘active’  should  also  refer  to  tuna  vessels  which  have  actually  carried  out  fishing 
activities in the São Toméan fishing zone. 

The  terms  of  the  clause  on  the  transmission  of  a  list  of  qualified  seamen  at  the 
beginning  of  each  year  should  also  be  more  precise  so  that  the  São  Toméan 
authorities provide the EU with the name of the seamen and all the evidence that a 
seafarer is actually fit and qualified. 

•  Sectoral support: It is paramount to prepare a clear and detailed programme for a 
future sectoral support component aiming at improving the pace of implementation, 
meeting both national and EU priorities.  An annual activity report is essential for 
effective and robust monitoring of the implementation of sectoral support by the Joint 
Committee.  The  results  of  sectoral  support  implementation  should  be  subject  to 
review by the Joint Committee of the activity report, either at the Joint Committee 
meeting or, exceptionally, by exchange of letters between the two parties. 

The  need  for  visibility  in  the  design,  implementation  and  monitoring  of  sectoral 
support should be included in the possible future protocol based on the terms used in 
other  current  FPA/SFPA  implementing  protocols.  To  this  end,  a  budget  line  for 
communication  and  visibility  activities  of  the  Protocol  could  be  included  in  the 
sectoral support programme. 

Additionally,  the  two  parties  could  envisage  a  modification  of  the  2007  framework 
Agreement  (other  than  the  Protocol).  Such  modification  was  not  in  the  scope  of  the 
evaluation  of  the  external  consultant.  The  modification  of  the  Agreement  could  address 
matters of mutual interest for the benefit of both parties, that are not covered by the Protocol. 
However,  should  the  Agreement  be  reviewed,  the  revision  should  be  limited  in  scope, 
allowing for a timely conclusion of the negotiations.  

Option B (non-renewal of Protocol) 

32 

 
Without the conclusion of a new protocol, the EU fishing fleet can no longer access fishery 
resources  in  the  fishing  zone  covered  by  the  SFPA  as  of  19  December  2024  under  the 
exclusivity clause of Article 6.1 of the SFPA.  

In the absence of a protocol, there would be no access to these resources for the EU fleet, 
unless the SFPA is terminated by one of the two parties. However, according to Article 13 
of  the  SFPA,  the  SFPA  may  be  terminated  by  one  of  the  parties  only  in  the  event  of 
‘abnormal’ events relating, inter alia, to: 

•  The degradation of the stocks concerned,  

•  The  discovery  of  a  reduced  level  of  utilisation  of  fishing  opportunities  granted  to 

Community vessels, or  

•  Failure to comply with the Parties’ commitments to combat illegal, unreported and 

unregulated fishing. 

It is rather unlikely that the conditions for such termination would be met. 

During  this  period  of  “dormant”  SFPAs,  historically  active  EU  fleets  will  redirect  their 
activities in the sub-region to other accessible fishing areas: for EU tuna seiners in Gabon 
(currently active SFPA), but also in Angola (by direct authorisations at present, and at sea; 
and offshore in the vicinity of São Toméan waters for EU longliners. 

In the very hypothetical scenario of a termination (depending on the specific circumstances 
mentioned above), the EU fishing fleet could have access to fishery resources in the fishing 
zone  covered  by  the  current  Protocol  through  direct  authorisations  on  the  basis  of  the 
technical and financial conditions laid down by the partner country, and under the general 
framework of Regulation (EU) 2017/2403 on the sustainable management of external fishing 
fleets (SMEFF Regulation). 

Moreover, the SFPA is a specific instrument for bilateral EU sectoral cooperation. It enables 
it to disseminate best practices of the CFP outside EU waters and more specifically in the 
waters covered by the SFPA – its protocol and those of the sub-region, including for the fight 
against IUU fishing. Its absence could weaken the means of implementing its sub-regional 
strategy. 

EU support for São Tomé and Príncipe’s sectoral policy could then be redirected within the 
EU’s cooperation instruments,  in  particular with the assistance of the European  Fund for 
the  European  Neighbourhood,  Development  and 
Sustainable  Development  within 
International Cooperation Instrument (NDICI).  

The  dialogue  between  the  EU  technical  services  and  São  Tomé  and  Príncipe’s  technical 
directorates and the mobilisation of funds to improve the governance of the fisheries sector, 
scientific knowledge and support for the fight against IUU fishing are not as direct as in an 
active SFPA in which a sectoral dialogue platform exists (the Joint Committee). 

In the event of a dormant SFPA, the pace of implementation of sectoral policy by São Tomé 
and Príncipe could also be partly slowed down by a lack of continuity in the SFPA’s sectoral 
support through a possible future protocol. São Tomé and Príncipe should then identify, at 
least in the short term, external financing in addition to those available under the State budget 
for the sustainable development of the fisheries sector. 

33 

 
6.9.  Results and impacts   

6.9.1.  Environmental-Economic-Social impacts 

The following table compares the different options in terms of environmental, economic and 
social  impacts  and  the  associated  risks.  At  this  stage,  the  impacts  remain  essentially 
qualitative. Measuring these impacts requires knowing the main features of a future Protocol, 
which will be the result of the negotiation, and changes in the fishing opportunities available 
under EU fisheries agreements with other countries in the sub-region. 

34 

 
 
 
Impacts/Option 

Protocol renewed unchanged – status quo 
Option A1 
•  Availability  of  a  scientific  information  flow  to  support  the 
management  of  stocks  fished  nationally:  financing  of  the 
compilation of the statistical bulletin by sectoral support (case 
of the 2019-2024 SAL), strong assumption of continuity of this 
funding 

•  EU  support  for  the  governance  and  reform  of  the  fisheries 

management system 

(Impacts) 
Environmental 

Effectiveness, efficiency,  coherence of  EU  support  weakened  in 
the  absence  of  an  annual  activity  report  requirement  for 
implementation – monitoring of sectoral support activities 

Protocol concluded with some improvements 
Option A2 
•  Impacts identical to option A1 

Risk  of  Option  A1  minimised  by  the  requirement  of  an  annual 
activity report 

No new Protocol 
Option B 
•  Loss of a platform for sectoral dialogue between technical staff 
of the European Commission (DG MARE) and the Directorate 
for Fisheries and Aquaculture in São Tomé and Príncipe 

Loss  of  information  exchange  to  improve  the  quality  of 
management,  monitoring  and  surveillance  of  fisheries  in  São 
Toméan waters (and by extension outside São Toméan waters to 
monitor the current or future São Toméan fishing fleet) 

•  Loss of resources (human and material) for monitoring – control 

– fisheries surveillance 

•  Loss  of  information  on  local  fishing  data:  financing  of  the 
compilation of the statistical bulletin by sectoral support (case 
of sectoral support 2019-2024) 

•  Weakened local fisheries management (at least in the short term 
pending  obtaining  alternative  sources  of  funding  replacing 
sectoral support funds for the activities referred to above) 

EU Party 
•  Compensation  for  access  is  less  proportionate  in  terms  of 
reference tonnage and exploitable fishing opportunities than for 
Option A2 

EU Party 
•  Compensation  for  access  is  more  proportionate  in  terms  of 

EU Party 
•  No public compensation to be paid to São Tomé and Príncipe 

reference tonnage compared to Option A1 

Economic 

São Tomé and Principe 
•  — 

Reduction of risk under option A2 
São Tomé and Principe 
•  Review of access fees paid by EU shipowners harmonisation of 

prices per tonne in protocols signed more recently 

In the event of a slight decrease in the reference tonnage, loss of 
resources in case access rights are not adapted 

Social 

EU Party 
•  Low but not zero impact by reorienting tuna fishing activities 

EU Party 
•  Possible increase in the number of seamen signed on EU tuna 

São Tomé and Principe 
•  Loss of financial resources for the State 
•  Loss  of  specific  support  to  support  the  governance  and 

development of the sector 

Compensation  for  loss  of  revenue  by  allowing  access  to  third 
country flagged vessels less committed to the sustainability of the 
sector and transparency of access 
EU Party 
•  Low but not zero impact by reorienting tuna fishing activities 

on other fishing areas 

vessels 

on other fishing areas 

35 

 
 
  
  
  
  
  
  
  
  
  
  
 
  
  
  
 
  
São Tomé and Principe 
•  Loss  of  opportunities  for  a  few  jobs  obtained  through  the 

seamen clause (compared to option B) 

Failure to improve the seamen clause creates a risk of recurrence 
of the problem of non-use of São Toméan seamen in accordance 
with the terms set out in the current Protocol (compared to option 
A2). 

Difficulty in monitoring the implementation of sectoral support 

São Tomé and Principe 
•  Hypothesis  of  modification  of 

the  sectoral  support’s 
intervention  axes  in  the  Protocol:  social  benefits  of  sectoral 
support  activities  more  focused  on  the  small-scale  fisheries 
sector  and 
(than  on  aquaculture 
development) 

fisheries  monitoring 

São Tomé and Principe 
•  — 

36 

 
  
 
 
  
 
  
  
  
  
  
 
  
 
 
 
6.9.2.  Comparison according to standard evaluation criteria (relevance, 

effectiveness, efficiency and coherence) 

The table on this page compares the different options in terms of relevance, effectiveness, 
efficiency and coherence. 

Criterion/Option 

No new protocol 

Option B 

renewed 

Protocol 
(status quo) 
Option A1 

unchanged 

Conclusion of an adapted protocol 
Option A2 

Relevance 

Efficiency 

Efficiency 

Consistency 

Option  B  does  not  meet 
identified needs 

the 

Option  A1  partly  meets  the  needs 
identified for both parties 

for 

(under 

bilateral, 

and  Príncipe 

EU-São  Tomé 
cooperation  
in  the  fisheries  sector  and  the 
maritime  economy 
the 
sectoral 
current  protocol 
support) should then be carried out 
within the general framework of the 
EU’s 
and 
continental cooperation policy. 
This framework does not offer the 
same flexibility as sectoral support 
to  meet  São  Tomé  and  Príncipe’s 
needs  and  does  not  include  a 
platform 
sectoral 
dialogue with technical staff in DG 
MARE 
European 
of 
Commission 

regional 

direct 

the 

for 

Fishing  opportunities  remain  the 
same. 

A  new  Protocol  would  make  it 
possible  to  continue  the  sectoral 
dialogue  and  scientific  cooperation 
initiated  under 
the  current  and 
previous Protocol. 

the 

The effectiveness of sectoral support 
cannot  be  assessed  ex  ante:  it  will 
depend  on 
implementation 
conditions  of  the  sectoral  support 
(programming, 
and 
financial  management  of  activities, 
monitoring and evaluation).  

technical 

The  renewal  of  the  Protocol  (option  A2) 
meets the needs identified for both parties: 
desired  improvements  on  the  access  and 
sectoral support components 

slightly 
Fishing  opportunities  would 
increase  for  longliners  if  both  parties 
agree.  
Note:  as  tuna  resources  are  managed  at 
ICCAT level, this increase does not affect 
the sustainability of the targeted stocks. 

the 

the 

A  new  Protocol  will  make  it  possible  to 
continue 
sectoral  dialogue  and 
scientific  cooperation  initiated  under  the 
current Protocol. 
The  effectiveness  of  sectoral  support 
cannot be assessed ex ante. It will depend 
on 
conditions 
implementation 
(programming,  technical  and  financial 
management of activities, monitoring and 
evaluation).  The  proposals  submitted  for 
option  A2,  however,  making  payment 
conditional on the transmission of ICCAT 
data  and  an  annual  monitoring  report  to 
improve  the  effectiveness  and  efficiency 
of the Protocol under option A2 compared 
to option A1. 

specific  EU 

No 
commitment in this case.  

budgetary 

that 

could 

Activities 
be 
programmed  through  the  sectoral 
support  of  a  protocol  would 
possibly  be  financed  by  other 
intervention  (s)  of  the  EU  (or  its 
Member 
Reduced 
States). 
efficiency  in  the  short  term:  the 
preparation  and  reorganisation  of 
EU  interventions  could  take  time 
compared to the implementation of 
sectoral  support  as  soon  as  the 
Protocol 
is  signed  and  as  a 
continuation  of  current  Protocol 
interventions if all parties so wish. 

Better proportionality between the fishing 
opportunities  negotiated  and  the  EU’s 
investment  in  the  financial  contribution 
for 
fishing 
access 
opportunities. 

adjusting 

by 

The  efficiency  of  EU  investment  in 
sectoral  support  cannot  be  assessed  ex-
ante.  It  will  depend  on  the  conditions  of 
implementation  and  the  results  achieved. 
The efficiency of sectoral support could be 
improved by means of an annual activity 
report  on  which  payments  from  sectoral 
support funds are conditional. 

The  proportionality  between 
the 
fishing opportunities negotiated and 
the EU’s investment in the financial 
contribution  for  access  could  be 
slightly  improved  by  adapting  the 
current  Protocol  (sub-option  A2  on 
the right)  

The  efficiency of  EU  investment  in 
sectoral  support  cannot  be  assessed 
ex-ante.  It  will  depend  on 
the 
conditions  of  implementation  and 
the results achieved.  

37 

 
                               
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Criterion/Option 

No new protocol 

Option B 

this 

option 

Under 
(without 
protocol),  the  EU  would have less 
resources  to  implement  the  sub-
regional  strategy  in  line  with  the 
principles of the CFP. 

However,  the  general  principles 
guiding the Cooperation Policy will 
continue  to  apply  to  the  EU-São 
Tomé  and  Príncipe  cooperation 
framework,  using  EU  intervention 
policies  at  national,  regional  and 
African level. 

renewed 

Protocol 
(status quo) 
Option A1 

unchanged 

Conclusion of an adapted protocol 
Option A2 

A  Protocol  makes  it  possible  to  implement  in  a  coherent  and  complementary 
manner activities supporting the objectives of: 
• 
• 

the CFP – its external dimension in particular, and  
the EU’s sustainable development cooperation policy with national, regional 
and continental development strategies.  

Activities contribute to the Sustainable Development Goals, in particular SDG 14 
on life below water 
(comparison with option B) 

— 

The  proposed  improvements,  including 
the  requirement  of  an  annual  activity 
report,  should  a  priori 
the 
coherence  of  the  Protocol  in  its  sectoral 
support  component  (comparison  with 
option A1). 

improve 

6.10.  Preferred option  

A  comparison  of  the  options  indicates  that  sub-option  A2  (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  A2,  sub-option  A1,  which  considers  a  renegotiation  of  the 
current  implementing  Protocol,  has  as  its  main  weaknesses  (i)  maintaining  fishing 
opportunities in excess of needs and (ii) slow absorption of sectoral support funds. 

The sub-options A1 and A2 will allow the EU to mobilise specific EU funding for sectoral 
support,  decoupled  from  the  EU  compensation  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 B of non-renewal of the Protocol does not meet any of the needs of 
both parties.  

6.11.  Option  concerning  a modification  to  the  Agreement  or  the  negociation  of a 

new Agreement in addition to the implementing Protocol.  

Should the partner country request and insist on amending the Agreement, it could also be 
advantageous, to amend the existing protocol or to draft a new framework agreement at 
the same time as a new Protocol. As noted above, the modification of the Agreement could 
address matters of mutual interest for the benefit of both parties that are not covered by the 
Protocol. However, it should be limited in scope to avoid as much as possible preventing 
the rapid conclusion of the negotiations of the new implementing Protocol, as expressed 
by both parties, and avoid the interruption of the fishing activities. 

38 

 
                               
 
 
 
 
 
   
 
6.12.  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 partner country’s 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. 

39 

 
 
ANNEX I:   PROCEDURAL INFORMATION 

Directorate-General for Maritime Affairs and Ocean   
PLAN/2022/2080 - MARE - EU-São Tomé e Príncipe fisheries agreement - negotiation mandate for a new protocol 
Organisation and timing of the evaluation study on which the Staff Working Document was mainly based   

1. 

Tasks   

Time   

Signature of the contract    

7 December 2023   

Kick-off meeting   

11 December 2023   

Report of the Kick-off meeting   

13 December 2023 (v.2 validated 17 December 2023) 

Submission of the inception report    

18 December 2023   

Comments to the inception report   

11 January 2024 - 17 January 2024  

Submission of the draft final report   

4 March 2024   

Meeting to discuss draft final report    

15 March 2024  

Submission of the final report    

29 March 2024   

2. 

Better regulation application 

40 

 
 
 
 
  
 
This initiative does not require an impact assessment as it sets out a general policy approach and does not commit to any 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 will be carried out. 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 results of this SWD are mainly informed by an evaluation study conducted by an independent consultant. This evaluation study took place from 
December 2023 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 6 under the 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.  

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

Elements presented in this SWD are mainly taken from the above-mentioned evaluation study conducted by an independent consultant.  

The methodology is based on data collection, targeted consultations, data analysis and synthesis of this analysis and consultations outputs.  

1. 

Data collection 

The external study had to collect information on the: 

-  Fishing sector in the third country 
-  Activities of EU and other fleets in the partner country 
-  Stock assessments for the main concerned species 
- 
Institutional set up relevant on fisheries issues 

41 

 
 
 
 
-  Trade figures and data collected on the spot for local processing facilities 
-  Fishing data and economic data collected from EU companies as well as in other studies (costs structures)  
-  Reports of technical meetings, local fishery attaché reports and joint committee meetings 
-  Structured interviews with stakeholders: representatives from administrations, fishery sector, Santomean society.  

The information was then analysed and fed an evaluation:  

-  Critical review of the appropriateness and performance of the use of EU funds under sectoral support component 
-  Critical review of compliance to the binding provisions of the Protocol for each Party. 

Data used were provided by the Commission (database fed by Member States for authorisations and catches; Commission database on payments amounts 
and timing), by the Third country, by EU or third countries companies (economic results) or by other public sources (COMEXT data, EUMOFA selling 
price database, RFMOs reports).  

2. Consultations  
The consultations were carried out for the purposes of this evaluation study, with the assistance of the independent consultants, according to a strategy 
validated by the ISG, and included:  

Consultation  of  stakeholders  in  the  EU:  administrations  of  the  flag  Member  States  of  EU  vessels  benefiting  from  fishing  opportunities,  the 
• 
professional associations grouping EU operators using the negotiated fishing opportunities and EU civil society. The consultation period ran from January 
to March 2024;  
Consultation of stakeholders in São Tomé and Principe: a mission was organised in São Tomé and Principe between 9 and 16.01.2024. During 
• 
the mission, face-to-face discussion sessions were held with the various departments of the Santomean authorities involved in monitoring the Agreement, 
representatives of the private sector in the industrial and artisanal sectors, civil society and representatives from the EU Delegation to Gabon and Sao Tome 
and Principe. 

3. Preparation of the evaluation study   
The preparation of this evaluation study takes into account the guidelines and tools recommended by the EU in this area, as well as the methodological 
elements specific to the external dimension of the Common Fisheries Policy, such as those concerning the methods for evaluating the socio-economic 
impact of EU SFPAs. 

42 

 
 
 
 
Uncertainty in the analytical results and their robustness are influenced by:  

-  The evaluated period which is by necessity shorter than the full period of the initiative (more than one year of implementation is not evaluated) 
-  The lack of available information (such as precise and accurate data distinguishing landings and transhipments of EU catches, discrepancies between 

different data sources, or confidential economic information such as selling prices or precise costs structure per individual companies).  

-  Use of aggregated data. 

43 

 
ANNEX III. EVALUATION MATRIX 

The evaluation matrix applied has been the following:  

1 

Effectiveness  –  The  extent 

to  which 

the  objectives  of 

the 

Implementing  Protocol 

to 

the  Agreement  were  achieved 

Questions 

Success criteria 

Suggested indicators 

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

extent 
1.1  To  what 
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. 

Stocks  targeted  by  the  EU  fleet  are  not  overexploited  at  the  regional  level 
(highly  migratory  species-  Tuna)  or  at  national  level,  and  the  EU  fishing 
capacity  is  within  the  limits  established  or  recommended  by  the  relevant 
RFMO or RFO. The Protocol takes into account the management strategies 
expressed  by  RFMOs  and  São  Tomé  and  Principe.  São  Tomé  and  Principe 
takes part in the relevant RFMO/RFOs and provides data on activities carried 
out  by  vessels  flagging  its  flag  and  by  other  foreign  fleets  operating  in  its 
waters. 

scientific 
and 

State  of  the  stocks  targeted  under  the 
Protocol (scientific advice analysis that São 
Tomé  and  Principe  conducted,  meetings, 
reports  and  data, 
regional 
RFMO/RFO 
scientific 
national 
institutes);  All  fleets  catches  and  fishing 
effort in São Tomé and Principe  and in the 
region; possible impact on the environment 
of all the fleets operating in these waters. All 
considering  that  the  target  is  tuna  like 
migratory species  

44 

 
 
 
 
Questions 

Success criteria 

Suggested indicators 

1.2  To  what  extent  the 
has 
implementation 
followed 
same 
the 
principle and promote the 
for 
standards 
same 
fisheries  management  as 
applied in EU waters. 

1.3  To  what  extent  the 
scientific  and 
technical 
evaluation of the fisheries 
have 
concerned 
improved? 

The EU and São Tomé and Principe adopt management measures to reduce 
by-catches and discards and reduce the possible impacts on the ecosystem. 

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 scientists from São Tomé and 
Principe actively participate in scientific meetings and RFMO/RFO scientific 
committees.  Cooperation  between  scientific  institutes  is  encouraged  and 
supported  where  appropriate.  Joint  scientific  analysis  at  regional  level  at 
RFMO level are taken into account.   

State of the stocks taken as by-catch by EU 
vessels;  management  measures  adopted  at 
the regional, national or EU level or in the 
framework of the Protocol. Strategies aimed 
at  conservation  measures  for  protected 
species such as sharks 

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

1.4  To  what 
extent 
compliance and control of 
EU-fleet  activities  have 
been ensured 

The activity of the EU fleet is properly monitored (VMS, ERS, 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). 

45 

in 

the  Agreement  and 

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

reporting 

and 

 
Questions 

Success criteria 

Suggested indicators 

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 

The Agreement and its Protocol provide for access to fishing zones that are 
important  for  the  EU  fleet.  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.  

The Agreement and its Protocol offer similar conditions to all foreign fleets 
operating in the fishing zones and management areas in the current Protocol. 

The cost benefit ratio is acceptable and reasonable for the EU ship owners and 
for São Tomé and Principe. 

Utilisation  of  fishing  licenses;  catches  in 
waters  covered  by  the  current  Agreement 
and Protocol compared to overall catches at 
national,  regional  and  sub-regional  level  if 
appropriate; 
and 
employment 
indirect 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. 

(direct 

Level  of  fees  and  technical  conditions 
applied to third countries fleets in the fishing 
zones and management areas in the current 
Protocol.  Proportion  between  fees,  (all) 
costs  and  (all)  benefits  for  the  EU  ship 
owners and for São Tomé and Principe. 

the 

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

and 

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

46 

 
Questions 

Success criteria 

Suggested indicators 

The  Agreement  offers  a  reasonable  framework  to  foster  landings  and  thus 
supplying local markets and trade with third countries. The Agreement fosters 
trade  on  fisheries  cooperation  between  the  EU  and  São  Tomé  and  Principe 
and/or third countries. 

Percentage  of  landings  versus  local  and 
neighbouring countries market’s needs. 

Trade  figures  on  fish  (and  composition) 
between the EU and São Tomé and Principe. 

Commercial balance  and relation  with  São 
Tomé  and  Principe  and  neighbouring 
countries related to fish caught in São Tomé 
and Principe waters 

Part  of  the  fish  caught  in  the  framework  of  the  Agreement  supplies  local 
market and processing industry; the EU-fishing supports port- and ancillary 
activities and the economic and social development in the EU and in the area 
covered  by  the  current  Protocol.  The  agreement  could  have  an  important 
impact  regionally.  There  are  synergies  between  the  implementation  of  the 
Agreement and the economic and social development of the country. 

Number of initiatives to ensure cooperation 
between economic operators of the EU and 
local.  Benefits  that  such  activities  are 
brought  to  the  EU,  national  and  locally. 
Number of initiatives that have had a local, 
national and regional benefit. 

for 

2.3  To  ensure  supply  for 
the 
the  EU  and 
markets of São Tomé and 
Principe 
third 
countries. 

and 

to 

that 

the 
2.4  To  encourage 
secure 
creation  of  a 
is 
environment 
favourable 
private 
investment and economic 
activities  contributing  to 
sustainable 
the 
the 
development 
country  and  reinforcing 
its  cooperation  with  the 
EU. 

of 

2.5  To  take  into  account 
the  specific  interests  of 
the  

The Agreement covers the specific needs of the EU fleet based in outermost 
region and in the EU by ensuring the continuity of their fishing grounds 

Number  of  vessels  originating  from  the 
outermost 
the 
Agreement  and  percentage  of  catches 

region  operating  under 

47 

 
Questions 

Success criteria 

Suggested indicators 

−  Union's outermost 
regions  located  in 
the vicinity 
−  Union’s fleet.  

comparted to total catches. The same for the 
EU  vessels  originating  from  other  EU 
regions. 

Objective 3: To support the development of a sustainable fisheries sector in partner countries (through the governance framework that the Agreement 
creates and also 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 impacts. 

to 
3.1  To  contribute 
capacity  building  and 
social, environmental and 
economic development in 
São Tomé and Principe . 

transparency, 

The sectoral support and the economic activity that the implementation of the 
Agreement creates, contributes to the functioning of the fisheries sector, better 
governance, 
social  and  economic 
development of the area covered by the current Protocol. Moreover, it provides 
for  adequate  training,  equipment  and  infrastructures  namely  in  the  areas  of 
science and MCS. 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). 

inclusiveness  and 

48 

impact  of 

Results achieved with sectoral support and 
economic  and  social 
the 
implementation  of  the  current  Protocol;  % 
of  the  EU  contribution  to  the  different 
strategies,  policies  and  value  of  indicators 
for  assessing  the  social  and  economic 
impact in the EU and in the areas covered by 
the current Protocol, budget of the national 
fisheries  strategy;  comprehensiveness  and 
level  of  detail  of  the  sectoral  support 
cooperation  on  Blue 
reporting 
Economy, 
scale  and  artisanal 
fisheries, aquaculture, data collection, MCS, 
food security and policy areas. 

and 
small 

 
Questions 

Success criteria 

Suggested indicators 

the 

promote 
3.2 
To 
local 
of 
employment 
improving 
fishers, 
and 
infrastructures 
landings, 
encouraging 
third 
supporting 
in  developing 
country 
and 
fisheries 
local 
processing  industry  EU 
and  for  the  markets  of 
certain 
developing 
create 
countries. 
employment  directly  and 
indirectly. 

To 

EU vessels recruit part of their staff locally: they benefit from good working 
conditions and appropriate training, equivalent to ILO standards. Part of the 
catches is landed and processed locally. 

Catches landed traded in the local and neighbouring markets. Successful trade 
flows generated. Identification of elements that facilitate the trade relation and 
the ones that discourages it.  

Respect  of  the  minimum  number  of  local 
fishers embarked, respect of the standard for 
fair  and  safe  working  conditions,  amount 
and  composition  of  wages;  catches  (value 
and  volume,  including  by  catches)  landed, 
namely 
landing 
in  comparison  with 
obligations, processed and marketed locally.  

Quantities  of  landings  and  transshipments 
from  EU/Non  EU  fleets  in  São  Tomé  and 
Principe  Ports,  

Number  of  jobs  supported  in  Port  and 
Processing facilities related to EU /Non EU 
and 
frequentation 
fleets 
landing/transshipments activities 

Social  indicators  of  current  work  force  in 
São  Tomé  and  Principe    (age  distribution) 
and  related  needs  for  training  of  young 
potential fishermen 

Employment created directly and indirectly 
in the EU and in São Tomé and Principe  or 
in the sub region/sub region. 

49 

 
 
 
 
Questions 

Success criteria 

Suggested indicators 

Percentage  of  supplies  to  the  local  and 
neighbouring  markets.  Percentage  of  the 
fish  caught  by  the  EU  fleet  that  supplies 
these  markets  and  comparison  with  other 
sources. 

2 

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

Questions 

Success criteria 

Suggested indicators 

To  what  extent  does  the  Protocol  offer 
value-for-money to the EU? 

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

Utilisation of the fishing opportunities and 
positive cost-benefit ratio per category and 
globally.  

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

All activities included in the sectoral support have been properly 
used and benefited in environmental, social and economic terms 
in the EU and São Tomé and Principe . 

To  what  extent  does  the  Protocol  offer 
value-for-money 
the  EU  ship-
to 
owners? 

The EU ship-owners' contribution is commensurate to effective 
catches and profits compared to total costs and benefits.  

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 and to 
other  donor  contributions.  Contribution  to 
the sustainable development of the country. 

Volume  of  catches;  evolution  of  first  sale 
prices,  operating  and  all  costs  and 
estimation  of  the  profitability  for  each 

50 

 
is 

the 
the 

financial 
To  what  extent 
fishing 
for 
compensation 
possibilities  under 
the  Agreement 
advantageous  for  the  EU  and  for  São 
Tomé and Principe?  

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

segment  of  the  EU  fleet,  category,  vessel, 
gear type and country (if applicable). 

Ratio overall EU contribution /added value 
generated by the activity of the EU fleet in 
the fishing zone. 

Ratio  of  the  benefits  of  all  financial 
compensation  to  the  concerned  population 
proportional to the fishing activities. 

Ratio of the economic and social indicators. 

3 

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

Questions 

Success criteria 

Suggested indicators 

To what extent is all the EU contribution 
and  specifically  its  sectoral  support 
commensurate to the needs of São Tomé 
and Principe 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 to the needs 
of  the  country.  In  case  of  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. 

51 

Consumption  of  the  EU  contribution  for 
sectoral 
geographical 
distribution  compared  to  the  local  and 
national needs in the related policy area. 

support 

and 

and 

Geographical 
social  distribution 
impacts  and  benefits  of  all  financial 
compensation. 

Absorption capacity of the sectoral support; 
success  stories;  %  of  sectoral  support 

 
compared  to  the  national  and  local  budget 
for 
other  donor 
fisheries 
contributions. 

and 

to 

To what extent has the sectoral support 
payments  been  made  yearly  time  and 
according  to  the  programming  defined 
in article 4 of the Protocol? 

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. 

Calendar  of  payments  and  considered 
allocations. 

Results  of 
financial 
indicators and methods of control and audit. 

the  budget  and 

Achievement  of  the  criteria,  reports  and  procedures,  budget, 
financial indicators and methods of control and audit. 

Achievements of annual and multi-year objectives 

4 

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

Questions 

Success criteria 

Suggested indicators 

To  what  extent  have  the  objectives  set 
out  in  the  Agreement  and  the  Protocol 
still  correspond  to  the  needs  of  EU, 
Member  States,  its  ship-owners  in  the 
area covered by the current Protocol? 

there  have  been  different 

Should 
objectives? 

The implementation of the Agreement and its Protocol are in line with 
the objectives of resource and environmental sustainability; support to 
the development of a sustainable fisheries sector at national and local 
level;  facilitation  of  the  integration  of  coastal  states  into  the  global 
economy; improvement of scientific and technical knowledge, support 
to  the  economic  exchanges,  strengthening  sustainable  economic  and 
social  development,  effective  governance,  and  address  correctly  the 
national and local needs and those of the EU and its fleet. 

between 

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

52 

 
How  is  the  Agreement  relevant  to  the 
policy objectives of RFMOs and to the 
EU's  regional  network  of  fisheries 
agreements? To what extent is relevant 
and creates an important impact? 

For  highly  migratory  species,  the  Protocol  contributes  to  achieving 
objectives set  at  RFMOs and other regional organisations14 including 
CECAF15  and  to  maintaining  a  network  of  SFPAs  in  the  region  on 
fisheries management and scientific issues. It creates synergies with the 
EU and neighbouring countries at RFMOs.  

to 

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

such 

in 

5 

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

Questions 

Success criteria 

Suggested indicators 

How coherent is the Protocol with CFP 
in  general  and  with 
its  external 
dimension  and  the  regional  fisheries 
policy (RFMOs and other organisations 
including  CECAF  and  network  of 
SFPAs  at  national,  sub  regional  and 
regional scale)? 

The Protocol is in line with the CFP in general, contribute to achieving 
EU  objectives  at  regional  level  -  including  the  creation  of  a  regional 
network of SFPAs - is consistent with other SFPAs in the region and 
RFMOs and other Organisations objectives.  

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

14 International Commission for the Conservation of Atlantic Tuna (ICCAT), The Ministerial Conference on fisheries cooperation among African States bordering the Atlantic Ocean 
(ATLAFCO/COMHAFAT) 

15 Fishery Committee for the Eastern Central Atlantic (CECAF) 

53 

 
 
Questions 

Success criteria 

Suggested indicators 

To  what  extent  is  the  Protocol  and  its 
implementation consistent and coherent 
and  complements  with  the  other  EU 
the  Association 
policies,  such  as 
-INTPA, 
Agreement, 
SANTE, TRADE, EMPL and TAXUD 
policies and legislation?  

the  EEAS, 

The Protocol makes a substantial contribution to other EU policies and 
conversely.  The  Protocol  and  its  implementation  is  complementary, 
coherent and cooperates very positively with other EU interventions. 

In  what  ways  are  the  Agreement  and 
Protocol  consistent  with  the  national 
fisheries  policy  and  other 
related 
policies  and  are  well  coordinated  with 
regional  fisheries  policies  and  the  EU 
cooperation? 

The  Protocol  contributes 
identified 
to  achieving 
nationally, locally and regionally. Authorities, stakeholders and society 
are aware and informed on the contribution. 

the  priorities 

The Protocol contributes to the sustainable management of fisheries at 
local, national and regional level 

Consistency  with 
strategies / policy orientations. 

the  main  EU 

Implementation  of  social  clauses. 
And contribution to sustainable food 
security. 

Coherence  of  the  Agreement  with 
EU  policies  in  the  region  and  the 
country. 

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. 

6 

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

Questions 

Success criteria 

Suggested indicators 

What  is  the  additional  value  resulting 
from  the  EU  intervention  under  the 

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

Data  on  the  implementation  within 
the  current  Protocol  in  economic, 
terms 
social  and  environmental 

54 

 
 
Questions 

Success criteria 

Suggested indicators 

Protocol,  compared  to  the  absence  of 
Agreement/Protocol? 

To  what  extent  would  Member  States 
have had the ability or possibility to put 
alternative 
appropriate 
place 
in 
measures? 

To  what  extent  the  overall  benefits  of 
the  Agreement  and  Protocol  have  an 
added value for the EU? 

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? 

Evidence  of  the  need  and  usefulness  of  the  benefits  arising  from  the 
Agreement, in particular in terms of good governance, natural resources 
conservation, sound implementation of sectoral policies, 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 fishing species included in the agreement are the ones of interest 
for  the  EU  fleet  considering  the  species  available  and  fishing 
possibilities for all fleets operating in the same area. 

The  Agreement  and  its  implementing  Protocol  provide  substantial 
benefits to the EU and nationally and locally over private agreements. 

compared  to  other  agreements  or 
with no agreement. 

Uptake  of  licenses,  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 

7 

Acceptability – The extent to which stakeholders accept the policy in general and the particular instrument proposed or employed 

Questions 

Success criteria 

To what extent are the EU ship-owners 
satisfied with the Protocol? 

The  EU  ship-owners  are  satisfied  with  the  technical  and  financial 
conditions set up by the Protocol and support its renewal (with possible 
adaptations). 

Suggested indicators and sources 

Result  of  interviews  of  ship  owners 
and fisheries associations, and fishers 
in  EU 
representatives  (embarked 
vessels under the SFPA framework) 

55 

 
 
To  what  extent  is  the  Protocol  is 
developed in consultation, coordination 
and supported by the civil society in the 
EU and nationally and locally? 

the  sector 

To what extent is the Protocol supported 
by 
(ship  owners  and 
processors) in the EU and in the partner 
country, nationally and locally? 

Representatives of the civil society are consulted, involved and satisfied 
with the environmental and social conditions set up by the SFPA and its 
Protocol and support their renewal (with possible adaptations). 

The national and local ship-owners do not experience competition by 
the  EU  fleet  and  fish  processors  benefit  from  purchase  opportunities 
generated by the Protocol and support its renewal 

To  what  extent 
the  administration, 
stakeholders  and  civil  society  are  in 
the 
with 
satisfied 
general 
implementation of the Protocol? 

National and national and administration, stakeholders and civil society 
in  general  are  satisfied  with  the  implementation  of  the  Protocol's 
obligations and seek its renewal; they praise the benefits of the fisheries 
partnership. 

Further details are available in the report of the consultant, in its chapter 8. 

56 

Result  of 
representatives 
stakeholders, 
local 
representatives 
fishers’ 
locally/nationally/regionally 

interviews  of  NGO 
other 
population, 
and 

and 

Result  of  interviews  of  industry, 
fishing  operators  and  content  of 
articles,  press,  reported 
incidents 
between fleets. 

Level  of  compliance  with 
the 
Protocol's  obligations  in  terms  of 
seamen embarked, respect of fair and 
safe  working  condition  on  board  of 
EU  vessels, 
landing  obligation, 
observers,  data  reporting  etc,  Impact 
of the Agreement’s implementation to 
national/local population in social and 
communication 
economic 
impact, 
their 
activities 
communication 
press 
activities, 
statements, content of articles, etc. 

terms, 
and 

 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

As the initiative submitted to the evaluation is not applying to EU citizens, and only to a very small number of EU companies, costs and benefits have been 
identified and assessed for those EU companies benefitting from the initiative, and for the partner third country, as well as the EU generally (EU institutions), 
as a partner to the agreement. 

A simplified table accompanied with an explanatory narrative present an overview of these costs and benefits. 
The cost/benefit analysis of the current implementing Protocol, for the EU budget and for the partner country, is based on the access component and for 
the periods for which complete economic data are available. The cost/benefit ratio of the sectoral support component cannot be estimated at this stage, as 
this would require the identification and measurement of the impacts of the various projects, which was not possible within the framework of the external 
evaluation.  

The ratios recommended by the economic evaluation methodology in order to harmonise the elements for comparing the economic performance of the 
various agreements are set out in the tables below. 

The relative cost of access, taking into account actual catches, is in the order of EUR 160/tonne of fishery products caught, 47 % of which is borne by the 
EU (EUR 75/tonne) and 53 % by EU shipowners benefiting from fishing opportunities (EUR 85/tonne). The cost of one tonne of tuna (EUR 120/tonne) 
and the indicators for allocating the cost of access between EU public authorities and EU shipowners in the case of the current Protocol are different from 
the ex-ante allocation (EUR 50/tonne for the EU and EUR 70/tonne for shipowners). This is the result of catch levels below the reference tonnage established 
by the Protocol to fix the amount of the flat-rate part of the access contribution (catches represent 71 % of the reference tonnage as an annual average). For 
the year 2021 in which catches exceeded the reference tonnage, the distribution of access costs converges to that provided for in the Protocol. 

Indicators relating to the cost of the agreement in relation to the catches obtained (average value 2020-2022) 

57 

 
 
  
 
 
 
Financial 
compensation 
access only 

for 

financial 
Total 
contribution  (access 
+ sectoral support) 

EU financial compensation (EUR kEUR) 

422 

Sectoral support (kEUR) 

Access fees paid by shipowners (kEUR) 

482 

Total EU and shipowners’ payments (EUR kEUR) 

904 

Total payments in% turnover 

EU payments in% turnover 

Shipowners’ payments in% turnover 

Average cost of tonne of fish caught (EUR/tonne) 

Average cost incurred by the EU (EUR/tonne) 

10 % 

5 % 

5 % 

160 

75 

Average cost incurred by EU shipowners (EUR/tonne)  85 

Percentage of cost to be borne by shipowners 

53% 

422 

440 

482 

1 344 

14 % 

9 % 

5 % 

238 

153 

85 

36% 

Source: Table 21 of consultant’s evaluation 
Note: Average value over the first three years 

As regards value-added ratios, the main lesson to be taken into account is that each euro invested by the EU in the financial compensation for access to the 
resource generated EUR 6.60 in added value for the benefit of both parties, of which EUR 5,33 for the EU and EUR 1,27 for São Tomé and Príncipe. The 
Protocol therefore has a significant leverage effect for the EU side, but less significant for São Tomé and Príncipe due to the lack of economic interactions 
between EU tuna vessels and São Tomé and Príncipe’s fisheries sector. 

Cost/benefit indicators relating to the value added generated by the EU fleets benefiting from fishing opportunities (average value 2020-2022) 

58 

 
 
 
 
 
Ratio Value 

Compensation 

Payments 

Total payments 

Added on: 

for access 

shipowners for 

for access 

(EUR/EUR) 

access (EUR/EUR) 

(EUR/EUR) 

EU 

Direct 

Indirect 

Total 

Direct 

São Tomé and Principe 

Indirect 

Total 

Direct 

EU and São Tomé and Príncipe 

Indirect 

Total 

2,78 

2,55 

5,33 

1,27 

0,00 

1,27 

4,05 

2,55 

6,60 

4,67 

1,11 

5,78 

2,49 

0,59 

3,08 

Source: Table 22 of consultant’s evaluation 
Note: (I) The data carried over refer to the annual average of the years 2020 to 2022 

(II) the amount of financial compensation for access shall be considered as direct added value for the benefit of São Tomé and Príncipe. The amounts of sectoral support are not taken into account in the calculations. 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

Background    
In line with the Terms of Reference and the Better Regulation ‘toolbox’, a consultation strategy was elaborated by the independent consultant to obtain 
evidence from relevant stakeholders. The strategy defined the best means of consulting relevant stakeholders both in the EU and in the partner country 
concerned.     

To obtain stakeholders’ views on the implementation of the ongoing protocol, as well as on the possible renewal of the protocol, including the 

Objectives    
The aim of the consultation:     
1. 
different options;     
2. 
Target groups 

To use the results of this consultation in the evaluation report.   

•  Organisations representing EU fishing vessels with fishing opportunities under the current Protocol and, where appropriate, of EU fishing vessels 

with a possible interest in obtaining them in the future; 

•  Competent authorities of EU Member States (MS) whose fishing vessels use fishing opportunities under the current Protocol and having a possible 

interest in obtaining them in the future   

•  Civil society: NGOs active in the field of fisheries and the marine environment and trade unions of seamen signed on board EU fishing vessels or 

their representative organisations 

•  Consultations with development cooperation organisations of EU Member States active in São Tomé and Príncipe 

List of targeted organisations consulted at the end of this Annex V. 

Method of consultation 

•  By electronic consultation on the basis of questionnaires tailored to each of the target groups in four languages (ES, FR, EN and PT). Supplemented, 

where appropriate, by telephone interviews. 

• 

Results of the consultation 
Response rate: 78 % 

Total number of organisations consulted (outside European Commission DGs, LDAC and MAC): 18 

60 

 
  
 
Number of replies received: 14 

List of consulted stakeholders  

Entities 
A- Stakeholders responsible for the implementation of the 
SFPA 

Method 

Response 

DG MARE 

Member State 
ESP – Spain 

FRA – France 

PRT – Portugal 

B- stakeholders benefiting from the SFPA 
PS – ANABAC 

PS – OPAGAC 

SP FR – Orthongel 

LL ES – ORPAGU (cc: CEPESCA) 

LL ES – OPP-7 Burela/OPP LUGO 

LL – PT – VIANAPESCA 

LL – PT – ARVIA 

C- stakeholders with an interest in the SFPA  
EU institutions 

DG INTPA 

DG ENV 

Advisory committees 

D 

Q_MS 

Q_MS 

Q_MS 

Q_undue 

Q_undue 

Q_undue 

Q_undue 

Q_undue 

Q_undue 

Q_undue 

D 

D 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Long distance AC (for consultation of its members) 

Q_undue Q_CS 

x 

61 

 
  
  
  
  
  
  
  
 
 
 
  
 
  
 
 
  
 
Entities 

Market AC (for consultation of its members) 
Technical and financial partners of EU MS (selection)  – 
central services 

Method 

Response 

Q_other organisations  x 

AFD 

BMZ 

Portuguese cooperation 
Civil Society (SC) – non-governmental organisations and 
seafarers’ unions 
Europêche 

ETF – European Transport Federation 

WRAPPER 
WWF  –  Oceana  –  Environmental  Justice  Foundation  (joint 
reply) 
BirdLife 

Q_organisations * 

x 

Q_organisations 

* * * 

Q_organisations 

Q_CS 

Q_CS 

Q_CS 

Q_CS 

Q_CS 

x 

 x (reply with ITF) 

x 
x 

Information regarding the exact content of the consultation, including detailed responses of the stakeholders, can be found in Annex 7 of the evaluation of the external 
consultant.  

62