COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the Multiannual Plan for the fisheries exploiting demersal stocks in the Western Mediterranean Sea
Date: 2024-07-29
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: Mediterranean Sea, authorised catch, catch quota, deep-sea fishing, fishing area, fishing rights, fund (EU), marine ecosystem, monitoring report, regional cooperation, sea-bed

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.7.2024  SWD(2024) 195 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the Multiannual Plan for the fisheries exploiting demersal stocks in the Western Mediterranean Sea {COM(2024) 322 final}  
 
 
This staff working document provides more details about certain chapters of the report1 on the 
implementation  of  the  multiannual  plan  for  the  fisheries  exploiting  demersal  stocks  in  the 
Western  Mediterranean  Sea  (hereinafter  the  ‘plan’)2,  some  information  on  control-related 
aspects and the detailed replies given in the stakeholder consultation.  

Contents 

1. 

Setting of fishing opportunities ....................................................................................... 2 

1.1.  State of the stocks ............................................................................................................ 2 

1.2.  Trawling effort regime .................................................................................................... 5 

1.3.  Longliner effort regime ................................................................................................... 6 

1.4.  Catch limits for two shrimp species ................................................................................ 7 

1.5.  Compensation mechanism for trawlers ........................................................................... 7 

1.6.  Court of justice judgment, case C-224/22 ..................................................................... 16 

1.7.  Conclusion on the setting of fishing opportunities ........................................................ 16 

2. 

3. 

4. 

5. 

6. 

Support from EU funds & socio-economic development ............................................. 18 

Landing obligation ........................................................................................................ 19 

Ecosystem-based approach............................................................................................ 23 

Control ........................................................................................................................... 26 

Stakeholder consultation ............................................................................................... 27 

6.1.  Mediterranean Sea Advisory Council ........................................................................... 28 

6.2.  Western Mediterranean High-level group (PescaMed) ................................................. 38 

6.3. 
Individual MedAC member: Representatives of the French fishing sector (CNPMEM - 
CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE) ...................................... 43 

6.4. 

Individual MedAC member: Representatives of Spanish sector (UNACOMAR) ....... 50 

6.5.  Detailed MedAC advice on the consultation questions ................................................ 58 

1 COM(2024)322. 
2  Regulation  (EU)  2019/1022  of  the  European  Parliament  and  of  the  Council  of  20 June  2019  establishing  a 
multiannual  plan  for  the  fisheries  exploiting  demersal  stocks  in  the  western  Mediterranean  Sea  and 
amending Regulation (EU) No 508/2014 (OJ L 172, 26.6.2019, p. 1). 

1 

 
 
 
 
 
 
1. 

Setting of fishing opportunities 

During the transition period of the multiannual  management plan for the demersal stocks in 
the Western Mediterranean Sea,  fishing  opportunities were set  in  five  annual  rounds (2020-
2024),  with  the  fifth  currently  being  implemented.  Since  2020,  decisions  on  fishing 
opportunities  have  been  increasingly  supplemented  by  measures  as  scientific  advice  has 
become more comprehensive and there is a need to manage the state of different stocks.  

Discussions  with  Member  States  and  stakeholders  have  fed  into  the  development  of 
complementary measures alongside the main trawling effort regime in mixed fisheries.  This 
section provides more details on the information provided in Chapter 2 of the report. 

1.1. 

State of the stocks 

Western  Mediterranean  demersal  fisheries  are  composed  of  many  species  of  fish  and 
crustaceans, highly sought after by fishers due to their high commercial value. The Scientific, 
Technical and Economic Committee for Fisheries (STECF) provides best available scientific 
advice for the annual assessment of the state of the stocks as well as for the transition path to 
achieve fishing mortality securing maximum sustainable yield (‘MSY’) by 1 January 2025 at 
the  latest.  In  its  latest  plenary  report3,  STECF  presents  the  assessment  of  20  Western 
Mediterranean demersal stocks based on data up to December 2022, except for some stocks in 
Italian waters where the MEDITS survey was not conducted in 2022.  

STECF  concluded  that  Fmsy,  the  fishing  mortality  rate  securing  MSY,  has  decreased  since 
the plan was adopted in 2019. The F/Fmsy indicator shows a clear downward trend, both in 
the median as well as in the arithmetic mean. However, STECF concludes that there is still a 
substantial level of overfishing of stocks in the Western Mediterranean Sea, as reported in the 
high  levels  of  F/Fmsy  in 2022 (around 2).  It  concludes that  downward trend in  F/Fmsy  has 
not  resulted  in  a  parallel  increase  in  the  biomass  ratio,  B/Bmsy.  STECF  also  highlights  the 
discrepancy  between  stock  sizes  in  Spanish-French  waters  and  in  Italian  waters  where  the 
decrease in F/Fmsy is more significant. However, STECF notes that two stocks, blue and red 
shrimp in Italian waters (ARA 8-9-10-11) and red mullet in the South and Central Tyrrhenian 
Sea (MUT 10), have not been covered by analytical assessments since 2021.  

There is clear scientific evidence that the plan has started to yield results, as four out of the 
14 stocks with an analytical assessment have a fishing mortality reaching MSY and five more 
are not far from having a fishing mortality reaching MSY. However, STECF concludes that 
more time is needed to observe whether there will be an increase in biomass as a response to 
the  reduction  in  fishing  pressure  achieved  by  the  plan.  In  particular  for  hake,  STECF 
estimates it will take time before we see a full recovery of biomass, which could be achieved 
after several years of maintaining fishing mortality at reduced and sustainable levels.  

Figures 1 and 2 below illustrate the STECF conclusions and present the trends in F/Fmsy and 
B/Bmsy by stock under the plan. Namely, blue and red shrimp (ARA), giant red shrimp (ARS), 

3 75 STECF Plenary report (STECF-PLEN 24-01). 

2 

 
 
 
deep-water rose shrimp (DPS), hake (HKE), red mullet (MUT) and Norway lobster (NEP) in 
geographical  areas  (GSA):  Northern  Alboran  Sea  (1),  Alboran  Island  (2),  Balearic  Islands 
(5), Northern Spain (6), Gulf of Lion (7), Corsica (8), Ligurian and Northern Tyrrhenian Seas 
(9), South and Central Tyrrhenian Sea (10) and Sardinia (12). 

Figure 1: Trends in fishing mortality ratio F/Fmsy of the 14 stocks analytically assessed. 
Stocks in GSA 8-9-10-11 are in black. 

3 

 
 
 
Figure  2:  Trends  in  biomass  ratio  B/Bmsy  of  12  out  of  14  stocks  analytically  assessed 
(DPS  1  and  DPS  5-6-7 do  not have  a  trend  as  Bmsy  is  not  estimated  for  these  stocks). 
Stocks in GSA 8-9-10-11 are in black. 

In  more  detail,  STECF  concludes  that  three  of  the  four  stocks  with  F/Fmsy<=1  and/or 
B/Bmsy>=1 (DPS 1, MUT 7, MUT 9) show an increasing biomass coupled  with decreasing 
fishing mortality that had started prior to the plan implementation. STECF concludes that the 
results could be taken as evidence of the influence of the plan on relative biomass and the risk 
of  overfishing.  Despite  the  challenges  of  demonstrating  the  influence  of  factors  such  as  the 
plan implementation, STECF highlights that the F/Fmsy indicator decreased both before and 
after the plan was adopted. 

STECF observes that currently four (DPS 1, DPS 5-6-7, MUT 7 and MUT 9) out of 14 stocks 
assessed  analytically  show  a  value  of  fishing  mortality  equal  or  below  the  reference  level 
(F/Fmsy<=1).  Currently,  two  stocks  (MUT  7  and  MUT  9)  show  a  corresponding  biomass 
equal  or  above  the  reference  threshold  (B/Bmsy>=1),  but  this  indicator  is  not  available  for 
DPS 1 and DPS 5-6-7. Overall, the assessments indicate that seven out  of 20  stocks can be 
considered  fished  close  to  a  fishing  mortality  at  MSY.  Ten  out  of  20  stocks  remain 
significantly overfished, including three stocks below Blim (hake in GSA 1-2-5-6-7, hake in 
GSA 8-9-10-11 and nephrops in GSA 6) and four stocks below Bpa (red mullet in GSA 1, red 
mullet in GSA 6, blue and red shrimps in GSA 5 and blue and red shrimps in GSA 6-7). In 
addition, STECF experts were unable to estimate reference points to evaluate the status of six 
stocks against Fmsy.  

4 

 
 
 
 
Lastly, STECF experts estimated the trends in biomass and the stock trajectories  in terms of 
the ‘transition to Fmsy’, i.e. assessing annual fishing mortality levels in order to reach Fmsy 
in  2025  with  equal  and  gradual  steps  between  2019  and  2024.  This  enables  the  experts  to 
identify four stocks for which biomass is increasing. With continued management measures in 
2024, those four stocks could have a fishing mortality close to Fmsy by 1 January 2025. 

STECF observed that the median across stocks of the F/Fmsy values in 2022 is ~1.81, while 
the mean value is ~2.17, showing that fishing levels are still roughly twice sustainable levels 
across the assessed demersal species in the Western Mediterranean Sea. When comparing the 
two management units under the plan (Spanish-French waters and Italian waters) the median 
and mean values are higher (~2.61 and ~3.21) in Spanish-French waters than in Italian waters 
(~1.29  and  ~1.37).  STECF  observes  that  both  the  median  and  mean  B/Bmsy  values  across 
stocks in 2022 are ~0.49. The median and mean value are lower (~0.39 and ~0.28) in Spanish-
French waters than in Italian waters (~0.74 and ~0.64).  

STECF  observed  a  downward  trend  in  F/Fmsy,  mainly  driven  by  stocks  in  Italian  waters. 
However,  in  both  management  units  (Spanish-French  waters  and  Italian  waters)  this  trend 
started in 2019, one year before the plan was implemented. STECF notes that the downward 
trend in F/Fmsy is faster than the upward trend for biomass, even though median B/Bmsy in 
2022  is  the  highest  value  of  the  time  series  (again  driven  by  stocks  in  Italian  waters).  This 
may be due to biomass inertia to react to changes in fishing mortality, but the expected trend 
in biomass is also more variable than the trend in fishing mortality (F-trend) due to the impact 
of recruitment variation. 

1.2.  Trawling effort regime 

During the detailed discussions of the plan adoption process, the main tool identified to tackle 
overfishing and achieve fishing mortality at Fmsy by 2025 at the latest has been the trawling 
effort regime. Following scientific advice and the legal obligation in Article 7(3) of the plan, 
the number of trawling days has been gradually reduced by 40% compared to the 2015-2017 
baseline  number.  This  has  been  adopted  gradually  in  the  annual  process  to  set  fishing 
opportunities in December Agrifish Councils. It has resulted in a progressive adaptation of the 
fleets to the plan measures and the sector has become familiar with more detailed monitoring 
following  EU-strandards.  To  achieve  effective  monitoring  of  the  trawling  fishing  days,  the 
plan sets out a range of monitoring, control and enforcement obligations by Member States, 
such  as  annual  notification  of  authorised  vessels  and  their  activity  at  sea  (e.g.  fishing  day 
duration, location in relation to closure areas).  

In addition to a 40% reduction in trawling fishing days between 2020 and 2024 stipulated in 
the  legal  basis  of  the  plan,  several  monitoring  tools  have  been  developed  for  the  Western 
Mediterranean  Sea  since  2020.  Conversion  factors  have  been  estimated  and  adopted  at 
national  level  to  secure  fair  transfers  of  fishing  days  between  fleet  segments  targeting  the 
same  mix  of  species  but  with  different  levels  of  fishing  efficiency.  Following  validation  by 
STECF of conversion factors for transferring fishing days between fleet segments, there has 
not been any overshooting of effort trawling allocations between 2020 and 2023.  

5 

 
 
As the plan is the only EU multiannual management plan with the Fmsy deadline postponed 
to  2025  (Article 4(1)  of  the  plan),  the  fishing  opportunities  set  during  the  transition  period 
from  2020  to  2024  did  not  have  to  be  aligned  to  fishing  mortality  at  Fmsy.  However,  the 
STECF made an annual assessment of the state of stocks and the estimated pace of transition 
for  each  stock  under  the  plan  to  achieve  fishing  mortality  at  Fmsy  by  2025  at  the  latest.  In 
2021, STECF looked at all the information available for each stock and reassessed the amount 
of fish in the sea, the fishing pressure and how far the stock was from being in a sustainable 
state. As the legal obligation was to bring fishing mortality of the stock to MSY by 2025 at 
the latest, STECF advised complementing the trawling effort regime with additional measures 
to help kickstart the recovery of most overfished stocks.  

The  trawling  effort  regime  was  therefore  complemented  from  2022  onwards  by  additional 
measures.  Since  2022,  the  Commission  has  proposed  a  package  approach  combining  all 
management  tools,  including  catch  limits  for  blue  and  red  shrimp  and  giant  red  shrimp, 
freezing  of  the  effort  for  longliners  to  specifically  tackle  the  fishing  mortality  of  hake 
spawners  and  a  compensation  mechanism  to  incentivise  more  sustainable  practices.  The 
package  approach  ensures  an  efficient  reduction  in  fishing mortality  while  minimising 
socio-economic  impacts.  The  complementary  measures  to  the  trawling  effort  regime  are 
outlined below. 

1.3.  Longliner effort regime 

Article 7(3)  of  the  plan  allows  for  a  fishing  effort  regime4  in  which  the  Council  fixes  the 
maximum allowable fishing effort each year and can complement it with ‘any other relevant 
technical or conservation measures adopted in accordance with Union legislation’5. 

Following  STECF  scientific  advice  and  given  the  difficult  situation  of  hake  stocks,  the 
Commission  worked  on  complementing  the  main  trawling  effort  regime  in  the  plan  with 
additional  measures  to  specifically  tackle  the  fishing  mortality  of  the  most  overexploited 
stocks, such as hake. STECF showed that significant catches of hake spawners were caught 
by longliners, which had an impact on hake stock growth, hake stock health and the speed of 
recovery.  To  avoid  undermining  the  objective  of  achieving  maximum  sustainable  yield  by 
2025 for all demersal stocks, the Commission proposed specific measures for longliners as an 
addition to the main trawling effort regime. For the 2022 fishing opportunities regulation, the 
Commission  proposed  an  effort  regime  for  longliners  to  consolidate  other  management 
measures  that  aim  to  reduce  fishing  mortality  of  hake.  The  Commission  has  maintained  its 
proposal  of a ceiling  of  longliner effort in  the fishing  opportunities for 2023 and 2024.  The 
Council  followed  the  Commission  proposal  in  2022,  2023  and  2024  in  adopting  an  effort 
regime for longliners. 

4 Article 3(1) of the plan. 
5 Article 7(3)(b) of the plan. 

6 

 
 
 
1.4.  Catch limits for two shrimp species 

As  STECF  advised  in  2021  to  complement  the  trawling  effort  regime  with  additional 
measures to help kickstart the recovery of the most overfished stocks, the Commission sought 
a  balanced  solution  for  the  two  shrimp  species  (blue  and  red  shrimp  and  giant  red  shrimp), 
targeted  by  a  selective  single-species  fishery,  while  proposing  fishing  opportunities  to  help 
rebuild the stocks and secure sufficient profitability for the fleet. Using Article 7 of the plan, 
for  2022  the  Commission  proposed  a  13%  reduction  in  the  catch  limit  for  blue  and  red 
shrimps  in  Spanish  waters  and  21%  for  both  deep-water  shrimp  species  in  Italian  waters  to 
complement the reduction in trawling effort and the freeze in longliners effort. In line with the 
plan,  the  Council  reduced  the  catch  limits  by  5%  for  all  blue  and  red  shrimp  and  giant  red 
shrimp stocks as a complementary measure to the trawling effort reduction.  

In 2021, STECF used for the first time in the Mediterranean Sea a methodology to estimate 
biomass reference points. This resulted in a fundamentally different picture for some stocks, 
as  for  three  stocks,  STECF  assessed  the  amount  of  fish  in  the  sea  as  being  below  the 
dangerous  limit  level,  Blim.  STECF  assessments  in  2022  and  2023  included  updates  of  the 
stock biomass reference points and confirmed the importance of taking additional measures to 
help support the recovery of the most overfished stocks.  

For 2023 and 2024, the Commission proposed reducing catch limits ranging from 7% and 9% 
coupled  with  incentives  stemming  from  a  compensation  mechanism  that  grants  additional 
fishing days for vessels that adopt more sustainable practices, such as  bigger mesh sizes for 
deep-water  fisheries.  The  Commission  made  this  proposal  as  STECF  estimated  that  this 
would  help  rebuild  the  stock  above  Blim  by  2025  at  the  latest.  In  line  with  the  plan,  the 
Council  set  the  catch  limits  at  a  level  between  3%  and  5%  less  than  the  catch  limits  set  in 
previous years.  

1.5.  Compensation mechanism for trawlers 

Past  catch  levels  show  that  significant  quantities  of  hake  catches  occurred  in  the  Western 
Mediterranean  Sea.  Before  the  plan  was  adopted,  STECF  was  able  to  quantify  this 
phenomenon  and  evaluated  different  management  options.  These  options  had  direct 
implications on the whole mixed fisheries in coastal areas of the Western Mediterranean Sea. 
The  Commission  discussed  the  implications  of  each  management  option  with  the  Member 
States  concerned  during  the  plan  adoption  process.  Based  on  these  discussions  and  on  best 
available  scientific  advice,  the  Commission  developed,  under  the  framework  of  the  plan,  a 
compensation  mechanism  to  the  trawling  effort  regime  as  an  additional  measure  to 
complement and strengthen the management dynamics to help the recovery of stocks such as 
hake.  

Following  STECF  assessments  in  2021  on  the  state  of  hake  stocks,  the  Commission 
encouraged the Western Mediterranean Member States to agree on a way forward to support 
the  sector  in  developing  more  sustainable  fishing  practices.  The  Fishing  Opportunities 
Regulation for 2022 adopted for the first time the compensation mechanism: a 2% additional 
trawling  days  for  vessels  demonstrating  voluntary  sustainable  practices.  The  compensation 

7 

 
 
mechanism was further developed in the regulations for the following years, for 2023 (up to 
3.5% for two criteria) and for 2024 (up to 6% for 3 criteria). The mechanism became a fully-
fledged  article  with  more  criteria  related  to  sustainable  measures  and  allowing  vessels  to 
cumulate up to three criteria and the associated additional trawling days. 

Based  on  best  available  scientific  advice,  the  development  of  the  compensation  mechanism 
has led to the science-based fishing effort reduction for trawlers complemented by additional 
measures  designed  to  kickstart  stock  recovery,  in  particular  for  hake  stocks.  Overall,  it  has 
seen  excellent  buy-in  of  the  trawling  fleet  to  adopt  more  sustainable  measures  such  as 
efficient  closure  areas  during  spawning  periods  and  more  selective  gear.  Despite  voting 
against  the  regulation,  Spain  started  partly  implementing  the  compensation  mechanism  in 
2022.  France  focused  on  the  criterion  related  to  efficient  closure  areas  since  2022.  By 
contrast,  Italy  requested  it  for  the  first  time  in  2023  but  the  fleet  did  not  use  the  additional 
days. Table 1 summarises implementation of the compensation mechanism since 2022. 

8 

 
 
 
Table 1a: Implementation of the compensation mechanism in 2024 

Member State  Legal basis – Fishing opportunities 

2024: Article 8 

Number 
vessels 

of 

eligible 

Additional days from the 
Compensation 
Mechanism 

List of vessels for 2024 

France  

Article 8(1)(d)  –  temporary  closures 
areas  in  order  to  reduce  by  at  least 
25%  catches  of 
juveniles  of  all 
demersal  species  or  by  at  least  20% 
catches  of  spawners  of  all  demersal 
species’ 

43  trawlers  (21  trawlers 
between  18-24 m  and  22 
trawlers > 24 m) out of 48 
authorised trawlers in 2024 

570  additional  days  from 
the 4.5% compensation  

47 trawlers 

921 longliners  

Italy 

No data transmitted  

- 

- 

656 trawlers 

Spain 

5%  compensation  mechanism,  two 
criteria on a mandatory basis:  

563 trawlers  

6 116 additional days from 
a 5% compensation 

588 trawlers 

1 431 longliners 

4 051 longliners 

Article 8(g)  –  closure  period  of  at 
least  4  continuous  weeks  for  fishing 
activities  with  trawlers  in  the  areas 
and  periods  recognised  as  important 
for the protection of spawners of hake 
stocks.  

Article 8(i) 
the  Member  State 
concerned  has  set  a  closure  for 

- 

9 

 
 
 
fishing  activity  with  trawlers  at  a 
depth higher than 800 m 

additional 

Third 
measure, 
voluntary basis to be chosen by fleet 
vessels:  

Article 8(a)  -  the  use  of  a  trawl  net 
with 45mm square-mesh codend 

Article 8(b)  -  the  use  of  a  trawl  net 
with 50 mm square-mesh codend 

Article 8(k)  -  the  use  of  a  trawl  with 
flying  or  mid-waters  doors  or  other 
doors which reduce the contact of the 
doors and the gear with the seabed 

Table 1b: Implementation of the compensation mechanism in 2023 

Member State 

Legal  basis  –  Fishing 
opportunities 
2023: 
Article 8 

Number  of  eligible 
vessels 

France 

Article 8(4)(d) 
Member 

‘The 
State 

55 
(26 
trawlers 
trawlers  between  18-

10 

days 
3.5% 

Additional 
from 
the 
Compensation 
Mechanism 

of 

the 
Uptake 
additional  days  from 
the 
Compensation 
Mechanism 

List  of  vessels  for 
2023 

443 additional days   0 

uptake 

to 
permanent  cessations 

due 

48 trawlers 

 
 
 
24 m and 29 trawlers > 
24 m) 
56 
out 
authorised  trawlers  in 
2023 

of 

of  trawlers in the Gulf 
of Lion  

1 143 longliners 

640 eligible vessels  

3 597 
fishing days  

additional 

0 uptake 

695 trawlers 

4 099 longliners 

Italy 

has 
concerned 
established 
temporary 
closure areas in order to 
reduce  by  at  least  25% 
catches  of  juveniles  of 
all  demersal  species  or 
by  at  least  20%  catches 
all 
spawners  of 
of 
demersal species’.  

‘The 
Article 8(4)(d) 
State 
Member 
has 
concerned 
established 
temporary 
closure areas in order to 
reduce  by  at  least  25% 
catches  of  juveniles  of 
all  demersal  species  or 
by  at  least  20%  catches 
of 
all 
spawners  of 
demersal species’.  

Spain 

Two criteria used:  

‘the 
Article 8(4)(b) 
vessel  uses  a  trawl  net 
with  a  50  mm  square-
mesh  codend  for  deep-
water  fisheries  in  order 

Under  Article 8(4)(f): 
571 eligible vessels 

Under 
Article 8(4)(a)  and 
(f):  3 428  additional 
days 

100%  -  all  days  were 
used 

571 trawlers 

1 455 longliners 

11 

 
 
 
 
 
 
 
Under  Article 8(4)(b): 
22 eligible vessels  

Under 
Article 8(4)(b):  853 
additional days  

In 
total: 
additional days  

4 281 

to  reduce  by  at  least 
25% catches of blue and 
red 
shrimps  with  a 
carapace  length  (CL)  of 
in 
than  25  mm 
less 
geographical subareas 1, 
2,  5,  6,  7,  8,  9,  10  and 
11  and  to  reduce  by  at 
least  25%  catches  of 
giant  red  shrimp  with  a 
CL  of  less  than  35  mm 
in 
geographical 
subareas  8,  9,  10  and 
11’ 

the 

‘the 
Article 8(4)(f) 
Member 
State 
concerned  has  set  a 
closure  of  at  least  four 
for 
continuous  weeks 
fishing  activities  with 
trawlers in the areas and 
periods  recognised  as 
important,  on  the  basis 
of 
the  best  available 
scientific advice, for the 

12 

 
 
 
 
 
 
protection  of  spawners 
of  hake  stocks.  Such 
areas  shall  also  account 
for  spatial  patterns  of 
spawners’  distribution, 
including  depths  from 
150 m  to  500 m.  The 
periods of the temporary 
fishing  closure  shall  be 
from February to March 
to 
and  from  October 
November.’ 

Table 1c: Implementation of the compensation mechanism in 2022 

Member State 

France  

Legal  basis  –  Fishing 
opportunities 
2022: 
Annex III footnotes (2) 
and (3) 

(d) State concerned must 
have  adopted  temporary 
closure areas in  order to 
reduce  by  at  least  25% 
the  catches  of  juveniles 
of demersal species or at 
least  20%  of  catches  of 

Number  of  eligible 
vessels 

days 
2% 

Additional 
from 
Compensation 
Mechanism 

the 

of 

the 
Uptake 
additional  days  from 
the 
Compensation 
Mechanism 

List  of  vessels  for 
2022 

57 
(26 
vessels 
trawlers  between  18-
24 m  and  31  trawlers 
above 24 m) 

114  additional  days 
for  the  56  trawlers 
and  139  additional 
days 
the  one 
above 24 m. 

for 

111 days consumed for 
the  trawlers  between 
18 and 24 m. 

62 trawlers 

1 143 longliners 

13 

 
 
 
spawners of all demersal 
species’ 

Italy 

IT did not request it 

Spain 

Two criteria used:  

in  order 

b)  ‘vessels  must  use  a 
trawl net with mesh size 
codend of 50 mm square 
mesh size for deep water 
fisheries 
to 
reduce  by  at  least  25% 
of  catches  of  blue  and 
red  shrimps  […]  and  to 
reduce  by  at  least  25% 
red 
catches  of  giant 
shrimps […]; or’ 

d)  ‘the  Member  State 
concerned  must  have 
temporary 
adopted 
closure areas in  order to 
reduce  by  at  least  25% 
the  catches  of  juveniles 

817 trawlers 

1 758 longliners 

Under criterion b): 16 
eligible vessels 

Under criterion d): 24 
eligible vessels 

Under  criterion  b): 
total 
50.7 
of 
additional days.  

Under  criterion  d): 
total 
79.3 
of 
additional days. 

100%  -  all  additional 
days were used 

579 trawlers 

1 471 longliners  

In 
total: 
additional  days 
2022 

129.6 
in 

14 

 
 
 
 
 
 
 
 
 
 
 
 
of demersal species or at 
least  20%  of  catches  of 
spawners of all demersal 
species.’ 

15 

 
 
 
 
1.6.  Court of justice judgment, case C-224/22 

Two of the complementary measures in the package approach were preserved by the ruling of 
the  European  Court  of  Justice  on  the  case  Spain  v  Council,  C-224/226.  On  16 November 
2023, the Court of Justice issued its judgment dismissing the case for annulment brought by 
Spain against Council Regulation 2022/110 fixing fishing opportunities in the Mediterranean 
and Black Seas for 2022.  

The  judgment  clarifies  the  Council’s  margin  of  discretion  in  setting  catch  limits  during  the 
transition period of the plan. The Court also accepted the arguments raised by the Council and 
supported  by  the  Commission,  defending  a  broad  interpretation  of  the  term  ‘significant 
catches’ to cover catches that are significant not only from a purely quantitative perspective, 
but also looking at qualitative aspects. 

1.7.  Conclusion on the setting of fishing opportunities 

Since  its  adoption  in  July  2019,  the  plan  has  been  in  a  transition  period of  implementation. 
Between  December  2019  and  December  2023,  fishing  opportunities  were  set  in  five  annual 
rounds, the latest exercise being ongoing, during which a total of 22 decisions were adopted 
(Table  2).  In  2022,  the  fishing  opportunities  included  supplementary  decisions  on  the 
adoption  of  an  effort  regime  for  longliners,  catch  limits  of  two  shrimp  species  and  a 
compensation  mechanism  for  trawlers.  Since  2019,  five  decisions  focused  on  the  fishing 
effort  regime  for  trawlers,  combined  with  five  decisions  related  to  the  compensation 
mechanism,  three  decisions  on  the  fishing  effort  for  longliners  and  nine  decisions  on  catch 
limits of blue and red shrimp and giant red shrimp.  

Being  based  on  the  latest  scientific  advice,  the  adoption  of  complementary  measures  has 
provided more flexibility in helping to reduce the fishing mortality rate of the most overfished 
stocks, while taking into account the transition pace of mixed fisheries. 

Table 2: Summary of the decisions adopted in the fishing opportunities regulations  

FO2020 

FO2021 

FO2022 

FO2023 

FO2024 

Reduction 
trawling effort 

of 

-10% 

Proposed -
15% 

Proposed -
7.5% 

Proposed -
7.5% 

Adopted  

Adopted  

Adopted  

-7.5% 

-6% 

-7% 

Proposed 
& 
Adopted  

-9.5% 

Total 
number  of 
decisions 

5 

6 Case C-224/22: Action brought on 29 March 2022, Kingdom of Spain v Council of the European Union, 
OJ C 207, 23.5.2022, p. 20. 

16 

 
 
 
 
 
Longliner 
fishing effort 

Catch  limits  for 
blue 
red 
and 
shrimp and giant 
red shrimp 

Compensation 
mechanism 

3 

9 

5 

ceiling 

ceiling 

ceiling 

Ceiling 
adopted 
for  the  3 
stocks 

Adopted  -
5%  and  -
3%  for  2 
stocks 

Adopted  -
5%  and  -
3%  for  2 
stocks 

+2% 
(1 
criterium) 

+3.5%  (1 
criterium) 

+4.5%  (1 
criterium), 
(2 
5% 
criteria) 
and  6%  (3 
criteria) 

Total  number  of 
decisions 

1 

1 

6 

6 

8 

22 

The  Commission  proposed  reducing  the  fishing  effort  of  trawlers  following  the  scientific 
advice  issued  by  STECF  in  order  to  achieve  the  legal  obligation  to  reduce  fishing  days  for 
demersal trawlers by up to 40% compared with the 2015-2017 baseline. 

In  addition,  following  scientific  advice  promoting  more  sustainable  ways  of  fishing,  the 
Commission  proposed additional trawling  days for fishing  opportunities for 2022, 2023 and 
2024  (respectively  FO2022,  FO2023,  FO2024).  It  used  a  mechanism  that  compensates 
trawling  vessels  that  adopt  one  or  more  sustainable  criteria,  such  as  more  selective  gear  or 
respecting closure areas to protect juveniles and spawners. 

The  Commission  proposed  a  fishing  effort  regime  for  longliners  to  step  up  monitoring  and 
prevent any increase of the impact of longliners, in particular on the fishing mortality of hake 
spawners. This proposal was adopted in accordance with Article 7(5) of the plan and followed 
by the Council, apart from Spain who voted against. 

Finally, the Commission proposed reducing three catch limits for shrimp species in the fishing 
opportunities for 2022 and onwards as complementary measures to the trawling effort regime 
to  support  the  recovery  of  these  stocks.  This  proposal  was  designed  to  help  reduce  fishing 
mortality in the two deep shrimp species (Aristeus antennatus and Aristaeomorpha foliacea) 
in very selective fisheries. This proposal was adopted in accordance with Article 7(3)b of the 
plan  and  followed  by  the  Council,  apart  from  Spain  who  voted  against  in  2021,  2022  and 
2023 as well as from Italy in 2023. 

From 1 January 2025, all articles in the plan will start applying. Specifically, for fish stocks 
with  a  data-rich  assessment,  the  plan  will  set  upper  limits  for  annual  fishing  opportunities 
while  enabling  some  flexibility  for  healthy  stocks  (e.g.  Fmsy  ranges).  For  stocks  under 
pressure, which have so little fish in the sea that they are below dangerous minimum levels, it 

17 

 
 
 
 
 
 
 
 
 
creates a safety net. The safety net reduces fishing opportunities of stocks under pressure to a 
minimum  and  takes  additional  complementary  or  if  necessary  remedial  measures  to  rebuild 
them.  

2. 

Support from EU funds & socio-economic development 

During  its  transition  period,  the  plan  postpones  the  achievement  of  the  environmental 
objective  in  pursuit  of  socio-economic  objectives.  The  objective  is  to  progressively  and 
incrementally achieve fishing mortality of all stocks at Fmsy by 2020, where possible, and by 
1 January  2025  at  the  latest.  By  agreeing  to  postpone  the  deadline  for  achieving  the  Fmsy 
objective  referred  to  in  Article 4(1)  of  the  plan  for  Western  Mediterranean demersal  stocks, 
the co-legislators took a specific decision to ensure that fishing activities are environmentally 
sustainable over the long term and are managed in a way that is consistent with the objectives 
of achieving economic, social and employment benefits.  

This has also been the objective for the Commission in proposing and the Council in adopting 
a package approach that takes into account the socio-economic pillar in implementing the 
CFP Basic Regulation when fixing fishing opportunities. 

In  addition  to  the  five-year  transition  for  a  progressive  adaptation  of  the  sector  to  a  more 
sustainable  management  framework,  the  plan  includes  specific  support  from  EU  funds  to 
tackle  the  imbalance  in  fleet  capacity  and  to  help  the  sector  transition  to  more  sustainable 
practices. For instance, in fisheries targeting blue and red shrimp and giant red shrimp that are 
further away from the coast and in deeper waters, the Commission highlighted the economic 
incentives  to  use  EU  funds  in  the  energy  transition.  Member  States  can  also  support  their 
fisheries  local  action  groups  to  develop  alternative  economic  activities  and  diversify  the 
income  of  local  communities  that  depend  on  fisheries.  Small-scale  coastal  fishers  are  also 
eligible  for  higher  support  rates  under  many  measures  of  the  European  Maritime  Fisheries 
Fund  (EMFF)7  and,  since  2021,  the  European  Maritime  Fisheries  and  Aquaculture  Fund 
(EMFAF)8.  The  EMFAF,  running  until  2027,  is  implemented  under  shared  management, 
meaning that the Member States decide on which measures to focus the EU support.  

Based on Member States’ reporting, the Commission provides a yearly report on EU support 
for the sector, covering the end of the EMFF and the beginning of EMFAF implementation9. 

7 Regulation (EU) 508/2014 of the European Parliament and of the Council of 15 May 2014 on the European 
Maritime and Fisheries Fund and repealing Council Regulations (EC) No 2328/2003, (EC) No 861/2006, (EC) 
No 1198/2006 and (EC) No 791/2007 and Regulation (EU) No 1255/2011 of the European Parliament and of the 
Council (OJ L 149, 20.5.2014, p. 1). 
8 Regulation (EU) 2021/1139 of the European Parliament and of the Council of 7 July 2021 establishing 
the European Maritime, Fisheries and Aquaculture Fund and amending Regulation (EU) 2017/1004. OJ L 247, 
13.7.2021, p. 1. 
9 For the latest report, see EMFF implementation report 2022 - European Commission (europa.eu). 

18 

 
 
 
 
 
3. 

- 

Landing obligation 

State of play 

The landing obligation came into force gradually, starting in 2015 and full implementation as 
of January 2019. The objective is to reduce the wasteful practice of discarding fish by giving 
fishers  incentives  to  fish  more  selectively  and  avoid  unwanted  catches,  ultimately  avoiding 
wasting  resources.  With  the  introduction  of  the  landing  obligation,  the  fishing  opportunities 
proposed  must  reflect  the  change  from  amount  landed  to  amount  caught.  Discards  may  be 
very  high  in  fisheries  regulated  by  total  allowable  catches  and  quotas  due,  for  example,  to 
quota completion in mixed fisheries or high-grading. In these fisheries, the landing obligation 
represents  a  fundamental  shift  in  the  management  approach  to  EU  fisheries:  from  landing 
quota  to  catch-quota  management,  as  all  catches  must  now  be  recorded  against  the  relevant 
quotas, to produce a significant reduction in fishing mortality.  

Overall, scientific analyses by STECF10 and recent EU studies11 show that, despite the landing 
obligation being in force for nearly ten years, there is little evidence of a change in behaviour 
or major improvements  in selectivity in  EU fisheries. The STECF scientists feel  very much 
that the approach taken by Member States is to request exemptions to maintain the status quo. 

In the Mediterranean Sea, the landing obligation entered fully into force on 1 January 2019. 
The  landing  obligation  is  implemented  in  a  specific  context  where  discards  of  regulated 
species are relatively low,  the destination of landings of catches of fish under the  minimum 
conservation  reference  size  (MCRS)  is  limited  and  exclude  sale  for  human  consumption. 
These  differences  explain  that  the  landing  obligation  has  been  implemented  in  the 
Mediterranean  Sea  mainly  using  flexibility  instruments  such  as  the  de  minimis  and  high 
survival exemptions. A recent study12 estimated the discard ratios of the species included in 
the plan as generally low (0.15). The size at which 50% of the individuals are discarded (L50) 
for these species were usually below MCRS, however improvements were observed in many 
cases, showing that  some progress  has  been made  in  discard patterns  in  the fisheries in  this 
region.  

The  study  also  showed  that  discard  ratios  of  the  species  under  the  Western  Mediterranean 
multiannual management plan for demersal fisheries were generally low, with some increases 
recorded in 2018 and 2019 (e.g. hake in demersal trawlers in GSAs 5 and 9). Specifically, of 
the 18 species/fisheries combinations assessed, eight were above the MCRS in the most recent 
period with adequate data (usually 2018-19). In six more cases, increases were recorded, but 
the L50 values were still below MCRS. The L50 was lower than the MCRS and at the same 
time presented a downward trend in only two species (red mullet in GSA1 and hake in GSA 
9). For the given species, the L50 of Nephrops was above MCRS in both GSAs with adequate 

10 Evaluation of Joint Recommendations on the landing obligation and on Technical Measures Regulation 
(STECF-23-04 & 23-06). Publications Office of the European Union, Luxembourg, 2023. 
11 MedBLand, Synthesis of the Landing Obligation Measures and Discard Rates for the Mediterranean and the 
Black Sea, November 2021. 
12 MedBLand, Synthesis of the Landing Obligation Measures and Discard Rates for the Mediterranean and the 
Black Sea, November 2021. 

19 

 
 
 
data.  For  deep-water  rose  shrimp,  it  was  above  MCRS  in  two  out  of  three  GSAs  that  was 
estimated and for hake and red mullet, it was above MCRS in two GSAs each. 

- 

Derogations 

Before the entry into force of the plan, under Article 15(6) of the CFP Basic Regulation13, a 
high  survivability  exemption  from  the  landing  obligation  was  granted  in  2018  for  Norway 
lobster  (Nephrops  norvegicus) caught  with  all bottom  trawls for a duration of three years.14 
Regarding Norway lobster, the Member States concerned were to provide information in 2018 
about  estimated  discard  survivals,  in  particular  in  summer.  The  delegated  act  included  a  de 
minimis  exemption  for  hake  (Merluccius  merluccius)  and  red  mullet  (Mullus  spp.),  up  to  a 
maximum of 7% for 2017 and 2018 and up to a maximum of 6% in 2019 of the total annual 
catches of these species by vessels using trawl nets.  

Similarly,  a  first  amendment  in  2018  (EU  2018/153)  included  a  de  minimis  exemption  for 
hake  and  red  mullet  caught  using  bottom  trawls.  A  second  amendment  in  2018  (EU 
2018/203615) granted a de minimis exemption for hake and mullet up to a maximum of 6% for 
2019 and 2020, and up to a maximum of 5% in 2021 of total annual catches of those species 
by vessels using bottom trawls.  

In  addition,  de  minimis  exemptions  were  adopted  in  2018  for  European  seabass 
(Dicentrarchus  labrax),  annular  seabream  (Diplodus  annularis),  sharpsnout  seabream 
(Diplodus  puntazzo),  white  seabream  (Diplodus  sargus),  two-banded  seabream  (Diplodus 
vulgaris), groupers (Epinephelus spp.), stripped seabream (Lithognathus mormyrus), Spanish 
seabream (Pagellus acarne), red seabream (Pagellus bogaraveo), common pandora (Pagellus 
erythrinus), common seabream (Pagrus pagrus), wreckfish (Polyprion americanus), common 
sole  (Solea  solea),  gilthead  seabream  (Sparus  aurata)  and  deep-water  rose  shrimp 
(Parapenaeus  longirostris),  up  to  a  maximum  of  5%  in  2019  of  the  total  annual  catches  of 
those  species  made  by  vessels  using  bottom  trawls.  The  second  amendment  in  2018  also 
included  de  minimis  exemptions  for  anchovy  (Engraulis  encrasicolus),  sardine  (Sardina 
pilchardus), mackerel (Scomber spp.) and horse mackerel (Trachurus spp.), up to a maximum 
of 5% in 2019 of total annual by-catches of those species by vessels using bottom trawl. 

After the plan was adopted, STECF evaluated the exemptions under Article 15(5) of the CFP 
Basic Regulation on the ground of disproportionate costs for the de minimis derogations. New 

13 Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on the 

Common Fisheries Policy (OJ L 354, 28.12.2013, p. 22). 

14 Commission Delegated Regulation (EU) 2018/153 of 23 October 2017 amending Delegated Regulation (EU) 
2017/86 establishing a discard plan for certain demersal fisheries in the Mediterranean Sea. Followed by 
Commission Delegated Regulation (EU) 2021/2066 of 25 August 2021 supplementing Regulation (EU) 
2019/1022 of the European Parliament and of the Council regarding details of implementation of the landing 
obligation for certain demersal stocks in the western Mediterranean Sea for the period 2022-2024. 

15 Commission Delegated Regulation (EU) 2018/2036 of 18 October 2018 amending Delegated Regulation (EU) 
2017/86 establishing a discard plan for certain demersal fisheries in the Mediterranean Sea. C/2018/6718 - OJ L 
327, 21.12.2018, p. 27-40. 

20 

 
 
 
derogations  were  adopted  in  201916  for  2020  and  some  in  202117  on  the  basis  of  joint 
recommendations.  A  de  minimis  exemption  was  adopted  for  2020  and  2021  for  European 
seabass (Dicentrarchus labrax), annular seabream (Diplodus annularis), sharpsnout seabream 
(Diplodus  puntazzo),  white  seabream  (Diplodus  sargus),  two-banded  seabream  (Diplodus 
vulgaris),  groupers  (Epinephelus  spp.),  striped  seabream  (Lithognathus  mormyrus),  Spanish 
seabream (Pagellus acarne), red seabream (Pagellus bogaraveo), common pandora (Pagellus 
erythrinus), common seabream (Pagrus pagrus), wreckfish (Polyprion americanus), common 
sole  (Solea  solea),  gilthead  seabream  (Sparus  aurata)  and  deep-water  rose  shrimp 
(Parapenaeus longirostris), up to a maximum of 5% of total annual catches of those species 
made by vessels using bottom trawls.  

STECF  also  estimated18 that discards of small  pelagic species are negligible in  the  Western 
Mediterranean Sea since anchovy, sardine, mackerel and horse mackerel are not target species 
of  the  trawler  fishery,  and  related  by-catches  are  mostly  landed,  especially  in  targeted 
industrial  demersal  trawler  fisheries.  Discards  by  static  coastal  gears  are  also  considered 
minor.  A  de  minimis  exemption  was  therefore  adopted  for  2020  and  2021  for  anchovy 
(Engraulis  encrasicolus),  sardine  (Sardina  pilchardus),  mackerel  (Scomber  spp.)  and  horse 
mackerel  (Trachurus  spp.),  up  to  a  maximum  of  5%  of  total  annual  by-catches  of  those 
species by vessels using bottom trawls. In 2021, a high survivability derogation was adopted 
for  Norway  lobster  (Nephrops  norvegicus)  caught  with  all  bottom  trawls  and  a  de  minimis 
exemption  for hake (Merluccius  merluccius) and mullet (Mullus spp.), up to  a maximum of 
5% for 2022 and 2023 of total annual catches of those species caught by vessels using bottom 
trawls.  

Lastly, in 2021 a de minimis derogation was adopted for 2022 and 2023 for European seabass 
(Dicentrarchus  labrax),  annular  seabream  (Diplodus  annularis),  sharpsnout  seabream 
(Diplodus  puntazzo),  white  seabream  (Diplodus  sargus),  two-banded  seabream  (Diplodus 
vulgaris),  groupers  (Epinephelus  spp.),  striped  seabream  (Lithognathus  mormyrus),  Spanish 
seabream (Pagellus acarne), red seabream (Pagellus bogaraveo), common pandora (Pagellus 
erythrinus), common seabream (Pagrus pagrus), wreckfish (Polyprion americanus), common 
sole  (Solea  solea),  gilthead  seabream  (Sparus  aurata)  and  deep-water  rose  shrimp 
(Parapenaeus longirostris), up to a maximum of 5% of total annual catches of those species 
caught by vessels using bottom trawls. 

In 2023, the Commission conducted a full review of the Western Mediterranean exemptions 
to  assess the data collected since the landing obligation  entered into force  in  the region  and 
the selectivity improvements adopted. STECF assessed the joint recommendation and all the 
data  provided  by  Western  Mediterranean  Member  States.  Based  on  Article 15(4)(b)  of  the 
CFP  Basic  Regulation,  STECF  confirmed  that  the  scientific  evidence  demonstrated  high 

16 Commission Delegated Regulation (EU) 2020/4 of 29 August 2019 amending Delegated Regulation (EU) 
2017/86 establishing a discard plan for certain demersal fisheries in the Mediterranean Sea. C/2019/6204 - OJ L 
2, 6.1.2020, p. 5-10. 
17 Commission Delegated Regulation (EU) 2021/2066 of 25 August 2021 supplementing Regulation (EU) 
2019/1022 of the European Parliament and of the Council regarding details of implementation of the landing 
obligation for certain demersal stocks in the western Mediterranean Sea for the period 2022-2024. C/2021/6175 -  
OJ L 421, 26.11.2021, p. 17-21. 
18 Evaluation of Joint Recommendations on the landing obligation and on Technical Measures Regulation 
(STECF-23-04 & 23-06). Publications Office of the European Union, Luxembourg, 2023. 

21 

 
 
 
survival rates in the Western Mediterranean Sea for scallop (Pecten jacobaeaus) caught with 
mechanised dredges,  carpet  clams  (Veneupis spp.) caught  with  mechanised dredges,  red sea 
bream  (Pagellus  bogaraveo)  caught  with  hooks  and  lines,  lobster  (Homarus  gammarus) 
caught with nets and with pots and traps as well as crawfish (Palinuridae) caught with nets. A 
high survivability exemption19 was adopted for those species for 2024, 2025, 2026 and 2027.  

Similarly,  STECF  evaluated 
the  data  available  for  de  minimis  exemption  under 
Article 15(4)(c)  of  the  CFP  Basic  Regulation  and  supported  an  exemption  for  2024,  2025, 
2026 and 2027 for hake (Merluccius merluccius) and mullet (Mullus spp.) up to a maximum 
of 5% of total annual catches of those species caught by vessels using bottom trawls; for hake 
and mullet up to a maximum of 1% of total annual catches of those species caught by vessels 
using  gillnets  and  trammel  nets;  for  European  seabass  (Dicentrarchus  labrax),  annular 
seabream  (Diplodus  annularis),  sharpsnout  seabream  (Diplodus  puntazzo),  white  seabream 
(Diplodus  sargus),  two-banded  seabream  (Diplodus  vulgaris),  groupers  (Epinephelus  spp.), 
striped  seabream  (Lithognathus  mormyrus),  Spanish  seabream  (Pagellus  acarne),  red 
seabream  (Pagellus  bogaraveo),  common pandora (Pagellus erythrinus), common seabream 
(Pagrus  pagrus),  wreckfish  (Polyprion  americanus),  common  sole  (Solea  solea),  gilthead 
seabream  (Sparus  aurata)  and  deep-water  rose  shrimp  (Parapenaeus  longirostris)  up  to  a 
maximum  of  5%  of  total  annual  catches  of  those  species  caught  by  vessels  using  bottom 
trawls; for European seabass, annular seabream,  sharpsnout seabream, white seabream, two-
banded  seabream,  groupers,  striped  seabream,  Spanish  seabream,  red  seabream,  common 
pandora,  common  seabream,  wreckfish,  common  sole  and  gilthead  seabream  up  to  a 
maximum of 3% of total annual catches of those species caught by vessels using gillnets and 
trammels  nets;  and  for  European  seabass,  annular  seabream,  sharpsnout  seabream,  white 
seabream,  two-banded  seabream,  groupers,  striped  seabream,  Spanish  seabream,  common 
pandora,  common  seabream,  wreckfish,  common  sole  and  gilthead  seabream  up  to  a 
maximum of 1% of total annual catches of those species caught by vessels using hooks and 
lines. 

For  the  other  fisheries,  the  officially  reported  discards  have  been  reduced  to  close  to  zero 
since the landing obligation entered into force. STECF however stresses that illegal discarding 
continues.  Overall, STECF  estimates that  a majority of the estimated discards in  weight are 
caught by active gears. Although the subsequent mortality rate cannot be quantified, STECF 
estimates  it  could  be  have  been  increasing.  In  conclusion,  STECF  reiterated  one  of  the  key 
issues  associated  with  the  landing  obligation:  the  difficulty  in  assessing  with  precision  the 
different  levels  of  discarding  in  a  context  of  mixed  fisheries  like  Western  Mediterranean 
trawlers. 

- 

Technical measures to improve selectivity 

Technical measures can contribute to reducing unwanted catches and therefore Article 18 of 
the  plan  also  empowers  the  Commission  to  adopt  delegated  acts.  However,  unlike  in  other 
sea-basins,  no  joint  recommendation  was  submitted  for  the  use  of  alternative  or  more 

19 Commission Delegated Regulation (EU) 2023/2462 of 22 August 2023 supplementing Regulation (EU) 
2019/1022 of the European Parliament and of the Council by specifying details of the landing obligation for 
certain demersal stocks in the western Mediterranean Sea. 

22 

 
 
 
selective  gears.  Therefore,  no  delegated  act  was  adopted.  The  Commission  continues  to 
suggest developing studies and to provide evidence on improved gear selectivity. 

From a socio-economic perspective, most stakeholders agree on the need for more selective 
gear that reduces unwanted catches while keeping the catch per unit of effort (CPUE) for the 
wanted  part  of  the  catch  as  high  as  possible.  Cooperation  between  Member  States  on 
developing and using selective gears has been reported as crucial in creating a level playing 
field for fishers. 

4. 

Ecosystem-based approach 

Under  Article 2(3)  of  the  CFP  Basic  Regulation,  the  CFP  must  implement  the  ecosystem-
based approach to  fisheries management to  reduce  the negative impacts  of fishing  activities 
on the marine ecosystem. Article 3(3) also provides that the plan must be coherent with EU 
environmental law and in particular with the objective of achieving good environmental status 
by 2020 as set out in the Marine Strategy Framework Directive 2008/56/EC (the ‘MSFD’).20  

Assessing the status of the Western Mediterranean Sea ecosystem and the plan’s impact on it 
is  complex.  The  ecosystem  has  been  in  a  difficult  situation  for  decades  due  to  overfishing, 
pollution  and  the  consequences  of  climate  change.  The  Western  Mediterranean  Sea  is  a 
subregion of the Mediterranean Sea, an atypical sea basin due to its geography and biology as 
a  semi-enclosed,  highly  diverse  and  one  of  the  most  rapidly  warming  seas  due  to  the 
consequences  of  climate  change.  While  the  scientific  community  is  still  investigating  the 
impact  of  climate  change  on  the  region,  it  is  expected  that  the  increased  upper  ocean 
stratification and associated warmer and more saline surface waters will disrupt the  Western 
Mediterranean natural processes of strong seasonal vertical stratification of the water column.  

In addition, recent studies have identified changes in nutrient distribution in some areas of the 
Western  Mediterranean  Sea21.  All  this  combined  means  a  likely  irreversible  disruption  of 
seasonal changes in productivity and species biology. It is this water column stratification that 
leads  to  a  high  diversity  of  fish  species,  allowing  mixed  fisheries  to  catch  a  wide  range  of 
species besides the six target species of the plan – hake, red mullet, nephrops, deep-water rose 
shrimp, blue and red shrimp and giant red shrimp. 

In  1976,  the  coastal  states  signed  the  Convention  for  the  Protection  of  the  Marine 
Environment  and  the  Coastal  Region  of  the  Mediterranean  Sea, known  as  the  Barcelona 
Convention.22  The  Barcelona  Convention  and  its protocols  form  the  legal  framework  of  the 
Mediterranean  Action  Plan  (approved  in  1975),  developed  under  the United  Nations 
Environment Programme (UNEP) Regional Seas Programme. The key goal of the Barcelona 

20  Directive  2008/56/EC  of  the  European  Parliament  and  of  the  Council  of  17 June  2008  establishing  a 
framework for the community action in the field of marine  environmental policy (OJ  164, 25.6.2008, 
p. 19). 

21 Among others, Feuilloley G, Fromentin JM, Stemmann L, Demarcq H, Estournel C, Saraux C, Concomitant 
changes in the environment and small pelagic fish community of the Gulf of Lion, Progress in Oceanography, 
Volume 186, 2020. 
22 Barcelona Convention and Protocols | UNEPMAP 

23 

 
 
 
 
Convention  is  to  ‘reduce  pollution  in  the  Mediterranean  Sea  and  protect  and  improve  the 
marine  environment  in  the  area,  thereby  contributing  to  its  sustainable  development’.  To 
implement the MSFD and restore the Mediterranean marine environment to good ecological 
status,  EU  Member  States  can  support  specific  measures  that  pay  special  attention  to 
eutrophication, biodiversity, hazardous substances and marine activities.   

In  order  to  determine  good  environmental  status,  the  MSFD  provides  eleven  qualitative 
descriptors.  Article 3(3)  of  the  plan  also  states  that  the  plan  must  aim  to  ensure  that  the 
conditions  of  descriptor  3  are  fulfilled,  and  to  contribute  to  the  fulfilment  of  other  relevant 
descriptors  in  proportion  to  the  relative  role  played  by  fisheries.  It  focuses  on  descriptor  3 
because  it  is  directly  linked  to  fishing  opportunities  (and  hence  to  the  plan).  It  reads  ‘the 
populations of all commercially exploited fish and shellfish are within safe biological limits, 
exhibiting a population age and size distribution that is indicative of a healthy stock’. Fishing 
activities have an impact on the descriptors relating to biological diversity (1), the food web 
(4), sea-floor integrity (6) and marine litter (10). The contribution made by fishing to the other 
descriptors is at best indirect and/or not substantial.23 

According to a recent study24, the environmental status for the whole Mediterranean Sea was 
assessed as ‘moderate’. However, there were notable differences between ecoregions, with the 
Western  Mediterranean  Sea  achieving  ‘good’  status.  Protected  areas  in  the  Western 
Mediterranean Sea mostly achieved ‘good’ or ‘high’ status. The no-trawl area was assessed as 
very effective and in a ‘high’ environmental status, while trawled control areas were ‘poor’ or 
‘bad’. 

One  of  the  most  important  impacts  of  fisheries  on  marine  ecosystem  is  the  removal  of 
predators  and  prey  species  from  the  food  web  and  the  disturbance  of  associated  marine 
communities. Demersal fisheries are also linked with an abrasion of the seabed and with the 
risk  of  sensitive  species  by-catch.  However,  STECF  and  other  internationally  recognised 
scientific  institutions  have  not  fully  quantified  the  effects  of  fisheries  on  the  Western 
Mediterranean ecosystems. 

Regarding  descriptor  3,  the  latest  STECF  report  on  stock  assessments  in  the  Western 
Mediterranean Sea only looks at two of the three criteria for most stocks (biomass and fishing 
pressure);  it  lacks  data  on  age  and  size  distribution  for  all  stocks  targeted  by  the  fisheries 
under the plan. STECF estimated that in 2023, red mullet in the Gulf of Lion (GSA 7) and red 
mullet in Ligurian and Northern Tyrrhenian Seas (GSA 9) were the only target stocks under 
the plan that met the two assessed criteria of descriptor 3. Deep-water rose shrimp in GSA 1 
and GSAs 5-6-7 and Norway lobster in GSA 9  met only the fishing mortality criteria. Only 
limited  data  has  been  available  on  by-catch  stocks  under  the  plan  and  STECF  could  not 

23 Introduction of non-indigenous species (2), human-induced eutrophication (5), hydrographical conditions (7), 
level  of  contaminants  in  the  sea  (8),  level  of  contaminants  in  fish  and  seafood  (9),  introduction  of 
energy including underwater noise (11). 

24 Fraschetti, S., Fabbrizzi, E., Tamburello, L., Uyarra, M. C., Micheli, F., Sala, E., Pipitone, C., Badalamenti, F., 
Bevilacqua, S., Boada, J., Cebrian, E., Ceccherelli, G., Chiantore, M., D’Anna, G., Di Franco, A., Farina, S., 
Giakoumi, S., Gissi, E., Guala, I., Guidetti, P., Katsanevakis, S., Manea, E., Montefalcone, M., Sini, M., 
Asnaghi, V., Calò, A., Di Lorenzo, M., Garrabou, J., Musco, L., Oprandi, A., Rilov, G., and Borja, A. (2022) An 
integrated assessment of the Good Environmental Status of Mediterranean Marine Protected Areas. Journal of 
Environmental Management 305: 114370. 

24 

 
 
 
conduct an assessment. The status of stocks not covered by the plan was unknown for most 
species (e.g. anglerfish spp.) except for the stock size of European eel, assessed as negative.  

On  Mediterranean  ecosystems,  ICES25  has  also  been  working  to  improve  knowledge  on 
functional  biodiversity  and  its  resilience  and  to  integrate  the  concept  of  resilience  into  food 
web modelling. The conclusions provide clear insights to continue refining ecosystem-based 
tools (e.g. indicators and critical thresholds) to drive management and conservation measures. 

ICES or STECF do not assess in detail the status of the other MSFD descriptors, but for some 
they  provide  qualitative  indications.  In  the  context  of  this  report,  which  looks  at 
implementation  of  the  plan  and  not  of  the  MSFD  in  the  Western  Mediterranean  Sea,  the 
following aspects should be noted regarding the other relevant descriptors. Fishing activities 
contribute  to  the  challenge  of  maintaining  biodiversity.  ICES  and  STECF  experts  state,  for 
example, that size-selective fishing may disrupt fish population stability, and fishing gear is a 
threat to endangered seabirds (e.g. Balearic shearwater), sea turtles and marine mammals. In 
many  coastal  areas,  the  increased  abundance  of  invasive  species  such  as  blue  crab  and  a 
concurrent  decrease  in  piscivorous  fish  indicate  that  the  ecosystem  is  deteriorating,  though 
recently  there  have  been  some  signs  of  improvement.  Parasites  and  invasive  species  have 
been  shown  to  impact  fish  stocks  and  can  lead  to  lower  productivity  and  changes  in 
indigenous  fish  distribution,  disrupting  the  predator-prey  spatial  overlap  and  food  web 
functioning.  Fisheries  have  a  high  impact  on  upper  trophic  levels,  which  cascade  down  the 
food  web.  In  addition,  bottom  trawlers  physically  destroy  and  disturb  seabed  habitats, 
reducing the diversity and biomass there and changing habitat composition.  

Secondary effects are the smothering and resuspension of sediments and nutrients, as well as 
food web effects. However it is not possible to quantify the impact of these effects due to a 
lack of studies and information on the thresholds of environmental impact. Abandoned, lost or 
discarded fishing gear is also an unsolved problem. The impact of abandoned fishing gear on 
the environment is also unquantified but fishing pressure is estimated to range from 20% of its 
usual net capacity after three months to a maximum of 6% after two years26. Finally, although 
not  fisheries-related,  the  presence  of  slowly  degrading  contaminants  such  as  dioxins  and 
polychlorinated biphenyls are of special concern for the fishing sector. It is related to the issue 
of trawlers re-suspending sediments in which those contaminants deposit and accumulate. 

Conversely,  the  ecosystem  also  affects  fish  stocks,  but  ICES  and  STECF  are  not  able  to 
specify the  relative contribution  of each environmental  factor on the  fishing  mortality  rates. 
Due to climate change and its consequences on large-scale atmospheric processes, the average 
temperature in surface waters and the average salinity levels have increased27. This could lead 
to  considerable  changes  in  the  geographic  distribution  of  fish  stocks,  and  changes  in  their 
condition and productivity levels. 

25 ICES, 2023, Working Group on Comparative Ecosystem-based Analyses of Atlantic and Mediterranean 
marine systems (WGCOMEDA, outputs from 2022 meeting). ICES Scientific Reports 5:38, 48 pp. 
https://doi.org/10.17895/ices.pub.22598164. 
26 Gilman, E., Musyl, M., Suuronen, P. et al., Highest risk abandoned, lost and discarded fishing gear, Sci 
Rep 11, 7195 (2021). https://doi.org/10.1038/s41598-021-86123-3. 
27 Observations in the Spanish Mediterranean Waters: A Review and Update of Results of 30-Year Monitoring, 
J. Mar. Sci. Eng. 2023, 11(7), 1284. 

25 

 
 
 
The  stakeholders  consulted  underlined  the  importance  of  ecosystem-based  management  of 
fisheries and the contribution of fisheries to achieving good environmental status. They also 
pointed  out  that  non-fishery-related  factors  play  an  important  role.  Member  States  consider 
that  fish  stocks  would  probably  be  in  a  worse  state  without  the  plan.  The  Mediterranean 
Advisory  Council  is  of  the  view  that  the  plan  has  been  counterproductive  since  it  lacks 
provisions on how specifically to implement an ecosystem-based management of fisheries. 

5. 

Control 

In addition to the general provisions of the Control Regulation, (EC) No 1224/200928 and its 
recent revision by Regulation (EU) 2023/2842, the plan brought in specific provisions. These 
included a fishing effort regime for trawlers, established closure areas, restricted the daily and 
weekly trawling time and includes the possibility to manage recreational fisheries. However, 
it  has  taken  time  to  develop  an  efficient  control  and  enforcement  of  all  plan  measures  and 
effort from control experts from both the Commission and Member State administrations.  

In  particular,  work  was  carried  out  to  achieve  for  all  three  Member  States  (i)  reliable  data 
crosschecking  and  effort  allocation  system  in  line  with  the  plan;  (ii)  enforcement  of  fishing 
stops  concerning  breaches  of  the  maximum  allowable  fishing  effort;  (iii)  monitoring  of 
compliance with closure area restrictions, notably for trawlers between 12-15 meters of length 
that  are  exempt  from  vessel  monitoring  system  requirements  and  do  not  use  an  automatic 
identification  system;  and  (iv)  systematic  monitoring  of  the  daily  and  weekly  trawling  time 
limits  set  in  the  plan.  In  general,  as  in  other  sea-basins,  the  limited  efficiency  of  Member 
States to monitor the obligation on land catches, the lack of a fully electronic system for catch 
reporting and poor control of engine power are considered to affect compliance with the CFP. 

On  control,  the  stakeholders  consulted  presented  a  wide  range  of  opinions.  Overall,  they 
considered that the plan resulted in few specific control measures. Member States highlighted 
their work on improving their control system in the Western Mediterranean Sea by developing 
more modern tools such as VMS and e-logbooks on board more vessels. Some representatives 
of the sector called on the Commission to stop taking a blanket approach to control across all 
EU  sea  basins.  Others  highlighted  the  lack  of  compliance  in  closure  areas  and  the  need  to 
improve training for control authorities and to step up controls in recreational fisheries. NGOs 
called for the use of VMS on all vessels to secure a level playing field between all vessels.  

It  is  worth  noting  that  all  issues  mentioned  above  had  already  been  raised  on  numerous 
occasions, including in the public consultation on the evaluation of the Control Regulation.29 
The  discussions  held  in  this  context  also  highlighted  the  need  to  tackle  these  issues  at 
European  level  rather  than  regional  level  in  order  to  avoid  distorting  competition.30  In 

28  Council  Regulation  (EC)  No 1224/2009  of  20 November  2009  establishing  a  Union  control  system  for 
ensuring compliance with the rules of the common fisheries policy (OJ L 343, 22.12.2009, p. 1). 

29 COM(2017) 192 final of 24 April 2017. 
30 SWD(2018) 280 final of 30 May 2018. 

26 

 
 
 
 
November  2023,  the  revision  of  the  Control  Regulation  was  adopted  including  measures  to 
address those issues and modernise the fisheries control system 31.   

6. 

Stakeholder consultation 

To prepare this first report on implementation of the Western Mediterranean Sea multiannual 
plan, the European Commission carried out a targeted stakeholder consultation, as it did when 
it  prepared  the  initial  legislative  proposal  on  the  multiannual  plan.32  The  consultation  was 
based on a questionnaire.  The stakeholders  consulted  were the  Mediterranean  Sea  Advisory 
Council  (MedAC),  the  Western  Mediterranean  high-level  regional  group  (PescaMed)  and 
members of these two organisations. Several members of the PescaMed and MedAC groups 
also sent a contribution to the consultation which are reproduced in this document. In addition 
to its answers to the stakeholder consultation questionnaire, MedAC sent a separate detailed 
advice to the Commission33.   

This  staff  working  document  reproduces  the  content  of  the  replies  as  received  by  the 
Commission. The first question in the questionnaire asks about the respondents' identity and is 
therefore not reproduced in this document. The replies from the Mediterranean Sea Advisory 
Council and the high-level regional group for the Western Mediterranean Sea are reproduced 
first followed by replies from the other organisations of the targeted stakeholder consultation. 
The replies received outside the targeted stakeholder consultation are reproduced last.  

31 Regulation (EU) 2023/2842 of the European Parliament and of the Council of 22 November 2023 amending 
Council  Regulation  (EC)  No 1224/2009,  and  amending  Council  Regulations  (EC)  No 1967/2006  and 
(EC)  No 1005/2008  and  Regulations  (EU) 2016/1139,  (EU) 2017/2403  and  (EU) 2019/473  of  the 
European Parliament and of the Council as regards fisheries control. 

32 COM(2018) 115 final. 
33 110_letter_from_mare_to_medac_pescamed_on_reply_to_west_med_map_eu_survey.pdf (med-ac.eu) 

27 

 
 
 
 
 
 
 
 
 
6.1. Mediterranean Sea Advisory Council 

Section 1 – Progress made towards sustainable fishing levels 

According  to  the  MAP,  MSY  is  to  be  achieved  for  all  relevant  stocks  on  a  progressive, 
incremental  basis  by  2020  where  possible,  and  by  1 January  2025  at  the  latest.  All  stocks 
covered by the MAP are managed by yearly fishing opportunities, including since 2022 catch 
limits  for  species  of  deep-water  shrimps.  Out  of  20  stocks,  15  received  an  analytical 
assessment  by  STECF  in  2022  of  which  7  had  estimated  biomass  above  Bpa  and  4  had 
estimated biomass below Blim. Out of the 20 West Med demersal stocks, 5 stocks were near 
MSY in 2020 and 7 stocks were near MSY as of 2022.  

In your opinion 

Q2: Has  the existence of a MAP facilitated the process  of setting of  fishing opportunities 
for the relevant stocks?  

Percentages of answers: significantly 6% - a little 19% - not much 19% - not at all 6% 

- no opinion 50% 

Q3: To what extent has the MAP contributed to increasing the number of stocks at MSY?  

Percentages  of  answers:  significantly  31%  -  a  little  50%  -  not  much  6%  -  not  at  all 

13% 

Q4: Has the MAP helped in dealing with difficult cases such as European hake or other 
sensitive stocks? 

Percentages  of  answers:  significantly  44%  -  a  little  38%  -  not  much  6%  -  not  at  all 

13%  

Q5: Do you have specific management suggestions to address the specific case of European 
hake? 

OP du Sud – France and UNACOMAR – Spain; 

- The selectivity and the increase of the MCRS will have important consequences for the fleet. 

- Further reductions are impossible to be implemented by the fishery sector. 

CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE - France and 
AGCI-AGRITAL 
e  LEGACOOP 
AGROALIMENTARE – Italy: 

–  CONFCOOPERATIVE 

FEDAGRIPESCA 

-  The  Mediterranean  sector  notes  the  progress  made  in  the  number  of  stocks  managed  at 
MSY.  It  would  seem  necessary  not  only  to  take  into  account  the  pressure  of  fishing  on  the 
stocks  but  to  adopt  a  global  ecosystem-based  approach  which  takes  into  account  all  the 
pressures on the marine environment (climate change, pollution, other marine activities, etc.) 
(UNACOMAR and UILAPESCA too). 

28 

 
 
 
 
 
 
-  Regarding  specific  measures  relating  to  hake,  some  Mediterranean  fisheries  concerned  by 
the management plan are multi-specific. In this sense, the Mediterranean sector is opposed to 
the management method by TAC for stocks. More specifically for hake, the introduction of a 
TAC is not desirable given the proportion of hake catches, which may contribute to a risk of 
choke effect. (UNACOMAR and OP du SUD too) 

-  Furthermore,  the  increase  in  the  minimum  catch  size  for  hake  will  lead  to  an  increase  in 
discards  of  undersized  fish  and  could  make  the  derogations  established  under  the  delegated 
acts incompatible (de minimis exemptions). 

-  Following  the  establishment  of  large  spatio-temporal  closure  areas  in  the  Gulf  of  Lion 
(6000km²  over  a  total  area  of  12 000-13 000km2)  to  protect  juveniles  and  adults  of  hake, 
which  have  demonstrated  their  effectiveness  (Ifremer,  Evaluation  des  fermetures  spatio-
temporelles  mises  en  œuvre  à  partir  du  1er  janvier  2020  pour  la  pêche  au  chalut  en  mer 
Méditerranée, 2021), it seems impossible to agree to the closure of additional areas in French 
waters (UNACOMAR too). 

- In addition, it seems impossible to absorb further reductions in fishing effort because they 
would  jeopardise  the  sustainability  of  the  enterprises  while  the  fishing  sector  has  made 
substantial efforts since the beginning of the management plan in 2020. 

-  Finally,  the  replenishment  of  biological  stocks  is  a  process  that  takes  time.  A  study  by 
Ifremer (Leforestier, S., Lehuta S., Mahévas, S., Jadaud, A., Vaz, S., 2020. Rapport du projet 
PECHALO (Pêche Chalutière Occitanie): Etude de l’impact de l’adaptation des stratégies de 
pêche  et  des  navires  de  la  flottille  chalutière  occitane  pour  améliorer  leur  viabilité  et  la 
durabilité  de  l’activité’)  has  shown  in  particular  that  a  period  of  two  to  three  years  is 
necessary  to  see  the  effect  of  the  reduction  in  fishing  effort  by  trawlers  on  the  hake  stock. 
(UNACOMAR, OP du SUD and EMPA too). 

Federpesca – Italy: 

- Implement a common policy in order to use a common process, but only apply it where it is 
needed, GSA by GSA. 

FNCCP – Spain: 

- It is necessary to continue to look for sustainability measures for trawling while maintaining 
the  socioeconomic  viability  of  the  fishing  sector  and  its  local  populations.  In  Catalunya 
trawling accounts for 

approximately sixty per cent of the total catches in euro. 

- The MSY achievement in 2025 is not possible, as recognised by the scientific institutes. It is 
necessary to establish a new Co-management Plan. 

WWF: 

29 

 
 
-  Once  the  effectiveness  of  Selectivity  measures  are  proved  to  be  effective,  they  should  be 
mandatory. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q6: To what extent have discards been eliminated and the landing obligation actually been 
implemented?  

Percentages  of  answers:  a  little  13%  -  not  much  13%  -  not  at  all  19%  - 

counterproductive 56% 

Q7: To what extent has the MAP contributed to achieving the current situation, notably via 
discard plans and technical measures?  

Percentages of answers: a little 19% - not much 31% - not at all 13% - no opinion 38% 

Q8: To what extent do you support more selectivity measures?  

Percentages  of  answers:  significantly  13%  -  a  little  19%  -  not  much  6%  -  not  at  all 

63%  

Q9: if yes, which selectivity measures do you support specifically? 

OP du Sud - France: 

-  Not  support  to  further  selectivity  measures  because  they  are  socio-economically 
unsustainable for the fishing sector. (UNACOMAR too) 

-  Support  to  the  spatial-  temporal  closures  as  the  best  management  measure  to  improve 
selectivity. 

AGCI-AGRITAL 
and  LEGACOOP 
–  CONFCOOPERATIVE  FEDAGRIPESCA 
AGROALIMENTARE - Italy and CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - 
CRPMEM CORSE - France:  

-  The  Mediterranean  sector  notes  that  the  management  plan  has  heightened  interest  in  the 
topic  of  selectivity.  However,  some  studies  (Project  IMPLEMED  and  the  Scientific, 
Technical and Economic Committee for Fisheries (STECF) – Evaluation of the fishing effort 
regime  in  the  Western  Mediterranean  –  part  VI  (STECF-21-13).  Publications  Office  of  the 
ISBN  978-92-76-43488-7, 
European  Union,  Luxembourg,  2021,  EUR 28359  EN, 
doi:10.2760/121901, JRC126965) have shown strong unsustainable economic losses during a 
mesh change, with a loss of catches for stocks already close to the MSY (mullet for example) 
in some cases or stocks which are not affected by the management plan (UNACOMAR too). 
Furthermore,  they  demonstrated  that  the  effectiveness  of  increasing  selectivity  is  strongly 

30 

 
 
 
 
 
 
related  to  the  species,  the  depth  range  and  the  area  where  fishing  takes  place.  It  should  be 
recalled that some Member States have opted for selectivity via the establishment of spatio-
temporal closures, by closing access to fisheries to certain areas at key times for the biological 
cycle of species. 

-  Regarding  the  landing  obligation,  the  dogmatic  application  of  Article 15  in  the  context  of 
mixed  fisheries  remains  impossible  without  serious  socio-economic  consequences  on  the 
fisheries concerned (UNACOMAR too). 

EMPA – Spain: 

- Time to the measures already taken is needed. It is counterproductive to continuously take 
measures without checking the results of those already taken, leading to the confusion of not 
knowing for sure which ones are effective (UNACOMAR too). 

UNACOMAR – Spain: 

-  It  is  important,  in  addition  to  continuing  to  study  the  45  and  50  mm  meshes,  to  continue 
investigating the use of flying trawl doors, which avoid contact with the seabed, with all the 
advantages that this measure has, in addition to significant savings in fuel and a reduction in 
carbon emissions. 

Federpesca – Italy: 

-  Selectivity  measures  should  be  indicated,  evaluated  and  agreed  upon  through  monitoring, 
verification between the fishers operating in the area and the research institutes, maintaining a 
balance of the parties in the evaluations.  

FNCCP – Spain: 

-It is necessary to find the balance between the sustainability of the fishing resource and the 
survival  of  the  fishers  and  other  agents  in  the  circuit  of  the  commercialisation  of  fish  and 
seafood. A program should be established based on the scientific method of trial and error, in 
the  implementation  of  technical  measures,  step  by  step.  It  is  also  necessary  to  apply  the 
measures in each territory, the principle of territorialisation has been lost in the application of 
the rules, what is good in one place may not be positive in another. 

WWF:  

- T90/grids on bottom trawling. 

Section 3 – Ecosystem-based approach  

Q10:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status, been achieved?  

31 

 
 
 
 
 
Significantly. Percentages of answers: significantly 38% - a little 25% - not much 31% 

- counterproductive 6% 

Q11: To what extent have the closure areas contributed to the current situation?  

Percentages of answers: significantly 56% - a little 38% - not at all 6% 

Q12: To what extent has the MAP contributed to the current situation?  

Percentages of answers: significantly 38% - a little 50% - not much 13% 

Q13: do you have specific comments on this point? 

OP du Sud - France  
- The spatio-temporal closures adopted in France had effective results in the ecosystem 
situation.  

CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE, France and 
AGCI-AGRITAL – CONFCOOPERATIVE FEDAGRIPESCA e LEGACOOP 
AGROALIMENTARE, Italy and UNACOMAR, Spain: 
- The successive reduction in fishing effort by trawlers during the management plan has had a 
very negative impact on the profitability of companies and the economic performance of 
fleets (STECF – Stock Assessments: demersal stocks in the western Mediterranean Sea. 
(STECF-22-09). Publications Office of the European Union, Luxembourg, 2023, 
doi:10.2760/00380JRC132120; Arrêté du 28 avril 2022 relatif à la mise en œuvre d’un plan 
de sortie de flotte pour les navires pêchant au moyen d’un chalut dans le cadre du plan de 
gestion pluriannuel en faveur de la conservation et de l’exploitation durable des stocks 
démersaux en Méditerranée en zone CGPM 37.GSA7), thus jeopardising the continuation of 
their activity, particularly in a context of increased fuel prices as observed in 2021 and 
Covid19. In this context, a plan for the withdrawal of fishing vessels from the fleet was 
implemented by France (Arrêté du 28 avril 2022 relatif à la mise en œuvre d’un plan de sortie 
de flotte pour les navires pêchant au moyen d’un chalut dans le cadre du plan de gestion 
pluriannuel en faveur de la conservation et de l’exploitation durable des stocks démersaux en 
Méditerranée en zone CGPM 37.GSA7), for which a third of the French trawler fleet of the 
GSA7 subscribed. Impacts on supplies to fish auctions and fish markets are to be expected 
with landing losses estimated at nearly 1 300 tonnes for more than €6 million for the 
Occitanie fish auctions. 

- In Italy the last withdrawal of fishing vessels from the fleet was done by 31/12/2017, 
according to regulation  508/2014: at that time, the European Commission was convinced that 
the demolition would no longer take place. 

- The various scenarios of the STECF (Evaluation of the fishing effort regime in the Western 
Mediterranean – part VI (STECF-21-13), Evaluation of the fishing effort and catch regime for 
demersal fisheries in the western Mediterranean Sea – PART IX (STECF-22-11), STECF – 
69th Plenary Report (PLEN-22-01), STECF – Evaluation of fishing effort regime in the 
Western Mediterranean – part V (STECF-20-13)) have also demonstrated a significant 
negative economic impact for trawlers in the short and medium term with a reduction in their 
gross added value. This is why STECF suggested in its last report (STECF-22-11) to conduct 
a detailed impact assessment for the further implementation of the management plan in order 

32 

 
 
 
 
 
 
 
 
to calculate possible scenarios (including mitigation and adaptation measures possible) 
regarding the implementation of effort reduction and the possible economic performance of 
the fishing fleets. It should be remembered that the fishing fleet is structural for the fishing 
industry in the Mediterranean (fish auctions, wholesalers, cooperatives, fishmongers). 
Therefore, this reduction in the effort quota weakens the entire sector on the Mediterranean 
coast.  

- Concerning the closure areas more specifically, France has defined two spatio-temporal 
closures in the Gulf of Lion in accordance with Article 11 of the management plan - one of 
3 368 km² for eight months, the other of 3 468 km² for six months – to meet the objectives of 
protecting juvenile and spawning hake. These two areas represent 49% of the area exploited 
in the Gulf of Lion and a significant part of French activity. It should be recalled the 
demonstrated effectiveness of these spatio-temporal closures (Ifremer, Evaluation des 
fermetures spatio-temporelles mises en œuvre à partir du 1er janvier 2020 pour la pêche au 
chalut en mer Méditerranée, 2021) and the strengthening of management measures in the 
GFCM FRA area of the Gulf of Lion in 2021 (Recommendation GFCM/44/2021/5). 

EMPA – Spain: 

- Good environmental status does not depend exclusively on fisheries management.  

Federpesca – Italy 

- The nursery areas have effectively contributed to an ecosystem approach to fisheries 
management. We now need to move on to phase 2: the involvement of fishers as guardians of 
the nursery areas with appropriate training courses. 

- It should be deepening the knowledge of the current state of play and of various factors, 
such as logistics of the area, number and characteristics of vessels, local customs, and 
traditions.  

Section 4 – Control and enforcement  

Q14:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  allowed  the 
national competent authorities to ensure compliance with the MAP itself?  

Percentages of answers: significantly 25% - not much 13% - no opinion 63% 

Q15:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Coldiretti – Italy:  
- Control of the mesh size of the nets  

UNACOMAR – Spain:  
- Reducing available working days is not an appropriate measure. But, in any case, new 
reductions can no longer be applied, since the fishing micro-enterprises are working below the 
break-even point. 

33 

 
 
 
 
 
 
 
 
 
 
 
- No new control measures are needed. The fishers are the guardians of the sea. And they are 
the ones who have a real interest in ensuring that the sea and natural resources are in the best 
conditions.  

Federpesca – Italy: 
- Control measures are especially those implemented on the trawling and floating trawl 
fishing, through the compulsory AIS. At least 30% of the vessels are exempt, and a good 20% 
not manage well the measures. 

Q16:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Coldiretti – Italy: 
- Landing obligation 

EMPA – Spain:  
- No 

UNACOMAR – Spain:  
- New reductions can no longer be applied, since the fishing micro-enterprises are working 
below the break-even point. 

Federpesca – Italy: 
- Those control measures that are not applied due to exemptions in favour of certain 
categories that are thus able to fish in nursery areas and do not monitor harvested production. 

Q17:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

UNACOMAR and EMPA - Spain  
- No, there is not needed to implement more specific control measures.  

Federpesca – Italy:  
- Improvement and facilitation of current electronic control procedures for all professional 
and recreational fishing vessels.  
- Rewarding conditions related to turnover and not to tonnage or engine power.  
- It also should be better the training in the sector of control authorities. 

WWF:  
- VMS on all vessels. 

Section 5 – Regional cooperation  

34 

 
 
 
 
 
 
 
 
 
 
 
Q18:  To  what  extent  has  the  MAP  in  your  opinion  strengthened  regional  cooperation, 
including with stakeholders?  

Percentages of answers: significantly 6% - a little 75% - not much 6% - not at all 13% 

Q19: Do you have specific comments on this point? 

OP du Sud – France, EMPA and UNACOMAR - Spain: 
- Strengthened collaboration and communication among the Italian, French, and Spanish 
fishing sector representatives.  

CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE - France 
AGCI-AGRITAL – CONFCOOPERATIVE FEDAGRIPESCA and LEGACOOP 
AGROALIMENTARE – Italy and UNACOMAR - Spain:  
- The management plan is a regulatory framework allowing Member States to put in place 
regional measures. The Mediterranean sector thus participates actively in the MEDAC which 
provide advice on the joint recommendations. Likewise, the Mediterranean sector works 
closely with its administrations on these issues. From this experience, the Mediterranean 
sector emphasises the importance of fluid and regular communication aimed at strengthening 
collaboration between actors. 

UNACOMAR – Spain:  
- The EC should pay more attention to the MEDAC advice and contributions, considering its 
valuable work. 

Federpesca - Italy  
- The role of FLAGs should be prioritised.  

WWF  
- Consultation at national level is weak in some cases. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q20: Given the Covid  and the fuel  crises, has the overall socio-economic situation of the 
fisheries sector improved since the entry into force of the MAP?  

Percentages of answers: a little 6% - not much 6% - not at all 75% - counterproductive 

6% - no opinion 6% 

Q21:  Given  the  Covid  and  the  fuel  crises,  do  you  see  a  positive  correlation  between  the 
implementation of the MAP and the socio-economic situation of the fisheries sector?  

Percentages  of  answers:  a  little  13%  -  not  much  13%  -  not  at  all  56%  - 

counterproductive 13% - no opinion 6% 

35 

 
 
 
 
 
 
 
 
 
 
 
Section 7 – Overall assessment   

Q22: What is your overall assessment of the western Mediterranean MAP?  

Percentages of answers:  beneficial 6%  - neutral  19% - negative 50%  - very negative 

19% - no opinion 6% 

Q23: Do you have final comments? 

CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE – France - 
AGCI-AGRITAL – CONFCOOPERATIVE FEDAGRIPESCA e LEGACOOP 
AGROALIMENTARE - Italy: 
- The format of the consultation does not allow a proper answer on certain aspect of the MAP 
(OP du SUD too) 
- The collaboration of fishery sector in the Med has positive effects, however factors other 
than fishing pressure should be further studied (pollution, demographic pressure, climate 
change, invasive species, etc.) 
- It is necessary to take into account the three pillars of sustainability in order to guarantee 
fishing activities that are environmentally, socially and economically sustainable (EMPA, 
UNACOMAR too). 
- It seems important to implement scientific resource to improve means of knowledge in the 
Med (assessment of stocks, evaluation of other anthropogenic factors, etc.) and to evaluate the 
impacts of management measures on the fishing resource and fishing activities. (OP du SUD 
and EMPA too) 

OP du Sud – France: 
- Improvement of the stock status of red mullet in GSA7 has been noted.  
- However the fast implementation of the MAP and the complexity of the current economic 
period due to the fuel crisis and COVID consequences are having a strong impact on the 
fishing fleet with a great reduction of fishing vessels (UNACOMAR and Federpesca too).  

EMPA – Spain:  
- There is no economic sector that can resist a 40% reduction in its production (Federpesca 
too).  
- Overlapping of continuous and different measures (selectivity, area closures, techniques,…) 
for the same objectives, which do not allow to identify which are effective and which are not 
(FNCCP too). 

UNACOMAR – Spain:  
- the Food Sovereignty and Food Security in EU is hampered by the current restrictive 
measures, because the new restrictions are several and applied in a short timeframe (5 years): 
the food supply is provided by third countries without the EU regulation (FNCCP too).  
- Study and analysis of all measures is required before their application. And after its 
application, it is also necessary to study and analyse its effects. And for all this it is necessary 
to have enough time. 

Federpesca – Italy:  
- The fishing sector should have an essential role in the policy decisions to be taken for the 
West Med MAP.  

36 

 
 
 
 
 
 
 
- It’s time to take decisions, because otherwise the fishing sector will disappear in few years.  

FNCCP – Spain: 
- the implementation of the MAP caused the economic unsustainability of the sector and the 
consequent lack of generation turnover.  

37 

 
 
 
6.2. Western Mediterranean High-level group (PescaMed) 

Section 1 – Progress made towards sustainable fishing levels 

According  to  the  MAP,  MSY  is  to  be  achieved  for  all  relevant  stocks  on  a  progressive, 
incremental  basis  by  2020  where  possible,  and  by  1 January  2025  at  the  latest.  All  stocks 
covered by the MAP are managed by yearly fishing opportunities, including since 2022 catch 
limits  for  species  of  deep-water  shrimps.  Out  of  20  stocks,  15  received  an  analytical 
assessment  by  STECF  in  2022  of  which  7  had  estimated  biomass  above  Bpa  and  4  had 
estimated biomass below Blim. Out of the 20 West Med demersal stocks, 5 stocks were near 
MSY in 2020 and 7 stocks were near MSY as of 2022.  

In your opinion 

Q2: Has  the existence of a MAP facilitated the process  of setting of fishing opportunities 
for the relevant stocks?  

A little. 

Q3: To what extent has the MAP contributed to increasing the number of stocks at MSY?  

A little. 

Q4: Has the MAP helped in dealing with difficult cases such as European hake or other 
sensitive stocks? 

A little. 

Q5: Do you have specific management suggestions to address the specific case of European 
hake? 

The effects of the implementation of the West Med MAP have not yet been felt, as more time 
is needed to see the results at a longer term since fishing mortality is being reduced, due to the 
biological response of the stocks, and will reduce the pressure on the resource. Moreover, the 
profession is facing numerous crises since the implementation of the management plan: Covid 
crisis,  fuel  crisis,  conflicts  of  use  on  the  occupation  of  space  (deployment  of  offshore  wind 
farms in particular). It has been shown that vessels are struggling or just reaching their break-
even point, putting them in a complicated economic situation, not allowing them to make new 
investments. If another reduction were to be implemented, this would put the owners of the 
remaining vessels in a critical financial situation. 

SPAIN points out that selectivity should be enough incentivised with additional fishing days, 
since  reduction  of  fishing  days  is  already  a  measure  with  short  margin  of  effectiveness  and 
important implications at the socioeconomic level. 

For the Gulf of Lion,  FRANCE points  out  that it is  worth  noting the lack of knowledge on 
most  stocks  and  on  its  functioning.  For  example,  only  8  stocks  are  analysed  out  of  the  274 
landed.  For  the  remainder  of  the  management  plan,  in  particular  for  hake,  an  ecosystem 

38 

 
 
 
 
 
 
approach seems essential in order to give the most accurate account possible of the situation. 
More specifically in the case of hake, closed areas have been set up to protect the juveniles 
and  breeders  of  this  species,  as  well  as  the  spawning  and  nursery  areas.  These  closed  areas 
cover  a  large  part  of  the  Gulf  and  have  proved  their  effectiveness  by  reducing  catches  of 
juvenile  hake  by  more  than  50%.  Moreover,  increasing  the  minimum  size  would  lead  to  an 
increase in discards and increasing mesh sizes would lead to an unsustainable economic loss 
for the industry. 

ITALY points out  that compensation mechanism should be more ambitious in  order to  take 
over the reluctance of the fishermen. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q6: To what extent have discards been eliminated and the landing obligation actually been 
implemented?  

Counterproductive. 

Q7: To what extent has the MAP contributed to achieving the current situation, notably via 
discard plans and technical measures?  

Not much. 

Q8: To what extent do you support more selectivity measures?  

See detailed answer in next question. 

Q9: if yes, which selectivity measures do you support specifically? 

Regarding  selectivity  measures,  the  three  Member  States  involved  have  different  views, 
according to their fleet management strategies. On this regard, different answers for the prior 
question ‘to what extent do you support more selectivity measures?’ are indicated below: 

For  SPAIN  the  answer  would  be  ‘Significantly’,  but  with  sufficient  incentive  for  fishing 
industry  to  address  the  loss  of  catches  at  short  and  medium  term.  SPAIN  would  support  a 
reasonable  increase  in  mesh  size  at  economic  level  for  fishing  industry  and  incentivised 
enough with additional fishing days. 

For ITALY, the answer would be ‘A little’, indicating that more incentive is needed. The use 
of grid could be envisaged, together with temporal closures. 

For FRANCE, the answer would be  ‘Not much’, as it was already implemented the closure 
areas in the Gulf of Lion. The main strategy for protecting resource lies in the establishment 
of the temporal closure areas, especially to protect hake, spawning grounds and nurseries. 

39 

 
 
 
 
 
 
Section 3 – Ecosystem-based approach  

Q10:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status, been achieved?  

A little. 

Q11: To what extent have the closure areas contributed to the current situation?  

Significantly. 

Q12: To what extent has the MAP contributed to the current situation?  

A little. 

Q13: do you have specific comments on this point? 

It should not be forgotten that the West Med management plan has important economic 
consequences, in particular on the trawler fleet, whose days at sea have decreased 
significantly since the beginning of the implementation of the plan.  

Moreover, since the beginning of the plan, the professionals have been faced with numerous 
crises: the Covid crisis leading to a reduction in activities, the fuel crisis leading to great 
insecurity over prices and an increase in the operating costs of vessels. This has de facto 
raised the break-even point of the vessels by increasing their costs. Therefore, an ecosystem 
approach taking into account all factors should be considered (climate change, offshore wind 
development, fisheries, measures already in place, socio-economic consequences …). Also, 
systemic changes in the Mediterranean (plankton, impact of climate change) must also be 
subject of scientific analysis, since changes in plankton have a significant impact on the entire 
trophic chain, even though the causes and consequences are unknown. 

Section 4 – Control and enforcement  

Q14:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  allowed  the 
national competent authorities to ensure compliance with the MAP itself?  

A little. 

Q15:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

It is considered that the MAP does not include any specific control measures in addition to 
those in the Control Regulation. 

Q16:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

40 

 
 
 
 
 
 
 
 
 
Not indeed. 

Q17:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

It is mentioned here additional measures that have been implemented by MMSS: 

SPAIN has developed a specific National Control Plan for demersal species in the 
Mediterranean, which will soon be implemented. In addition, it is an obligation for all 
trawlers to have installed on board the VMS despite the length overall. 

FRANCE: In its national control plan 2021-2022 and its newly adopted control plan for 2023-
2024 (part II), France has set up guidelines to enhance compliance of the West Med Plan and 
to consolidate its framework on this issue. This plan will apply during the period 2023-2024 
and to all control units involved. EFCA measures (specific action on West Med and ABM) 
have also contributed to compliance. 

ITALY:  Within the National Control Plan on the West Med Map, Italy has implemented the 
obligation of Electronic logbook for all vessels using towed gears despite the length overall. 

Section 5 – Regional cooperation  

Q18:  To  what  extent  has  the  MAP  in  your  opinion  strengthened  regional  cooperation, 
including with stakeholders?  

A little. 

Q19: Do you have specific comments on this point? 

Regarding relations with the stakeholders at national level, there are regular contacts and 
close consultations in the three Member States involved in order to adapt internally to the 
MAP implementation. 

At regional level, MEDAC is having a role, at least sending their opinion to COM on such 
implementation at EU level. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q20: Given the Covid  and the fuel  crises, has the overall socio-economic situation of the 
fisheries sector improved since the entry into force of the MAP?  

Counterproductive. 

41 

 
 
 
 
 
 
 
Q21:  Given  the  Covid  and  the  fuel  crises,  do  you  see  a  positive  correlation  between  the 
implementation of the MAP and the socio-economic situation of the fisheries sector?  

Not at all. 

Section 7 – Overall assessment   

Q22: What is your overall assessment of the western Mediterranean MAP?  

See detailed answer in next question. 

Q23: Do you have final comments? 

Regarding the previous question above, more detailed positions of the three MMSS involved 
are given below: 

For SPAIN, the overall assessment of the Western Mediterranean MAP is negative, since 
although some fishing stocks are improving, social and economic dimensions of CFP are not 
being respected due to the implementation which is being done from COM proposals. 

For FRANCE  the overall assessment is beneficial for the stocks, but maybe neutral taking 
into account the socio-economic consequences. 

For ITALY the overall assessment is negative for the situation of the hake, neutral related to 
benefits for shrimps. 

As a common view: many sustainability measures are already in place in the Mediterranean 
Sea, some of which are already beginning to bear fruit. However, it is necessary to take into 
account the biological response of the stocks on the one hand and the ecosystem approach on 
the other, in order to make the best assessment. Improved knowledge of the stocks and the 
dynamics of the basin also seems necessary (few species assessed, lack of knowledge, etc.). 

It is not possible to continue with the fishing effort reduction. It is necessary to find a more 
suitable and economically sustainable solution for achieving the objectives of the MAP and it 
is paramount to foreseen incentives for the fishermen for this purpose. The aims of the MAP 
are achievable but probably the issue is the way how the MAP is being implemented. The 
socioeconomic pillar of the CFP should be duly taken into account. 

42 

 
 
 
 
 
    
 
 
6.3. Individual MedAC member: Representatives of the French fishing sector 

(CNPMEM - CRPMEM PACA - CRPMEM OCCITANIE - CRPMEM CORSE) 

Section 1 – Progress made towards sustainable fishing levels 

According  to  the  MAP,  MSY  is  to  be  achieved  for  all  relevant  stocks  on  a  progressive, 
incremental  basis  by  2020  where  possible,  and  by  1 January  2025  at  the  latest.  All  stocks 
covered by the MAP are managed by yearly fishing opportunities, including since 2022 catch 
limits  for  species  of  deep-water  shrimps.  Out  of  20  stocks,  15  received  an  analytical 
assessment  by  STECF  in  2022  of  which  7  had  estimated  biomass  above  Bpa  and  4  had 
estimated biomass below Blim. Out of the 20 West Med demersal stocks, 5 stocks were near 
MSY in 2020 and 7 stocks were near MSY as of 2022.  

In your opinion 

Q2: Has  the existence of a MAP facilitated the process  of setting of fishing opportunities 
for the relevant stocks?  

No opinion. 

Q3: To what extent has the MAP contributed to increasing the number of stocks at MSY?  

Significantly. 

Q4: Has the MAP helped in dealing with difficult cases such as European hake or other 
sensitive stocks? 

Significantly. 

Q5: Do you have specific management suggestions to address the specific case of European 
hake? 

The French sector notes the progress made in the number of stocks managed at MSY. Indeed, 
the  STECF  (1)  showed  that  94%  of  stocks  were  not  at  MSY  in  2020  compared  to  73%  in 
2022. It also demonstrated that some stocks could already respond positively to the measures 
of  the  management  plan,  in  particular  9  of  the  14  stocks  assessed  have  a  declining  fishing 
mortality. For the GSA7 and GSA8, this assessment points to the encouraging results on the 
evolution of recruits in GSA7 and GSA8 and of the biomass in GSA8 of hake, as well as the 
biomass of red shrimp in GSA7.  

In addition, more than half of the stocks are not scientifically assessed in the Mediterranean 
today: according to Ifremer (2), 54% of landings made by French Mediterranean fisheries in 
2021 represent stocks not subject to scientific assessment. Ifremer adds that of the 263 species 
landed, only 9 are assessed in the Mediterranean. 

It  would  also  seem  necessary  not  only  to  take  into  account  the  pressure  of  fishing  on  the 
stocks  but  to  adopt  a  global  ecosystem-based  approach  which  takes  into  account  all  the 
pressures on the marine environment (climate change, pollution, other marine activities, etc.) 

43 

 
 
 
 
 
 
Regarding specific measures relating to hake, some Mediterranean fisheries concerned by the 
management  plan  are  multi-specific.  In  this  sense,  the  French  sector  is  opposed  to  the 
management  method  by  TAC  for  stocks.  More  specifically  for  hake,  the  introduction  of  a 
TAC is not desirable given the proportion of hake catches in total French catches (less than 
10% by weight (3)), which may contribute to a risk of choke species. 

Furthermore,  the  increase  in  the  minimum  catch  size  for  hake  will  lead  to  an  increase  in 
discards  of  undersized  fish  and  could  make  the  derogations  established  under  the  delegated 
acts incompatible (de minimis exemptions). 

Following  the  establishment  of  large  spatio-temporal  closure  areas  in  the  Gulf  of  Lion 
(6000km²  over  a  total  area  of  12 000-13 000km2)  to  protect  juveniles  and  adults  of  hake, 
which have demonstrated their effectiveness (4), it seems impossible to agree to the closure of 
additional areas in French waters. 

In  addition,  it  seems  impossible  to  absorb  further  reductions  in  fishing  effort  because  they 
would  jeopardise  the  sustainability  of  the  companies  while  the  French  profession  has  made 
substantial efforts since the beginning of the management plan in 2020. 

Finally, the replenishment of biological stocks is a process that takes time. A study by Ifremer 
(5) has shown in particular that a period of two to three years is necessary to see the effect of 
the reduction in fishing effort by trawlers on the hake stock. 

1  Scientific,  Technical  and  Economic  Committee  for  Fisheries  (STECF)  –  Stock 
the  western  Mediterranean  Sea.  (STECF-22-09). 
Assessments:  demersal  stocks 
2023, 
of 
Publications 
doi:10.2760/00380JRC132120 

Luxembourg, 

European 

in 
the 

Union, 

Office 

2 Ifremer, « Diagnostic 2022 sur les ressources halieutiques débarquées par la pêche française 
(métropolitaine) », janvier 2023. 

3 Scientific, Technical and Economic Committee for Fisheries (STECF)  - The 2022 Annual 
Economic  Report  on  the  EU  Fishing  Fleet  (STECF  22-06),  Prellezo,  R.,  Sabatella,  E., 
Virtanen, J. and Guillen, J. editors, Publications Office of the European Union, Luxembourg, 
2022, doi:10.2760/120462, JRC130578. 

4  Ifremer,  Evaluation  des  fermetures  spatio-temporelles  mises  en  oeuvre  à  partir  du  1er 
janvier 2020 pour la pêche au chalut en mer Méditerranée, 2021 

5  Leforestier,  S.,  Lehuta  S.,  Mahévas,  S.,  Jadaud,  A.,  Vaz,  S.,  2020.  Rapport  du  projet 
PECHALO (Pêche Chalutière Occitanie): Etude de l’impact de l’adaptation des stratégies de 
pêche  et  des  navires  de  la  flottille  chalutière  occitane  pour  améliorer  leur  viabilité  et  la 
durabilité de l’activité’ 

44 

 
 
 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q6: To what extent have discards been eliminated and the landing obligation actually been 
implemented?  

Counterproductive. 

Q7: To what extent has the MAP contributed to achieving the current situation, notably via 
discard plans and technical measures?  

No opinion. 

Q8: To what extent do you support more selectivity measures?  

Not at all. 

Q9: if yes, which selectivity measures do you support specifically? 

The  French  sector  notes  that  the  management  plan  has  heightened  interest  in  the  topic  of 
selectivity.  However,  some  studies  (6.7)  have  shown  strong  unsustainable  economic  losses 
during a mesh change, with a loss of catches for stocks already close to the MSY (mullet for 
example) in some cases or stocks which are not affected by the management plan.  

Furthermore,  they  demonstrated  that  the  effectiveness  of  increasing  selectivity  is  strongly 
related  to  the  species,  the  depth  range  and  the  area  where  fishing  takes  place.  It  should  be 
recalled that France has opted for selectivity via the establishment of spatiotemporal closures, 
by closing access to fisheries to certain areas at key times for the biological cycle of species. 

Regarding the landing obligation, the French sector questioned his administration and the EC 
repeatedly  on  the  issue  of  choke  species,  without  a  satisfactory  response.  The  dogmatic 
application of Article 15 in the context of mixed fisheries remains impossible without serious 
socio-economic consequences on the fisheries concerned. 

6 Project IMPLEMED - Improving the selectivity of trawl gears in the Mediterranean sea to 
advance the sustainable exploitation pattern of trawl fisheries 

7 Scientific, Technical and Economic Committee for Fisheries (STECF)  – Evaluation of the 
fishing  effort  regime  in  the  Western  Mediterranean  –  part  VI  (STECF-21-13).  Publications 
Office of the European Union, Luxembourg, 2021, EUR 28359 EN, ISBN 978-92-76-43488-
7, doi:10.2760/121901, JRC126965’ 

Section 3 – Ecosystem-based approach  

45 

 
 
 
 
 
 
 
Q10:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status, been achieved?  

Significantly. 

Q11: To what extent have the closure areas contributed to the current situation?  

Significantly. 

Q12: To what extent has the MAP contributed to the current situation?  

Significantly. 

Q13: do you have specific comments on this point? 

At the beginning of the management plan, the French fleet of trawlers was represented by 57 
vessels in GSA7 and allowed the contribution of more than 80% of the fish auctions on the 
French Mediterranean market. 

The successive reduction in fishing effort by trawlers during the management plan has had a 
very negative impact on the profitability of companies and the economic performance of 
fleets (1, 8), thus jeopardising the continuation of their activity, particularly in a context of 
increased fuel prices as observed in 2021 and Covid19. 

In this context, a plan for the withdrawal of fishing vessels from the fleet was implemented by 
France (9), for which a third of the French trawler fleet of the GSA7 subscribed. Impacts on 
supplies to fish auctions and fish markets are to be expected with landing losses estimated at 
nearly 1 300 tonnes for more than €6 million for the Occitanie fish auctions. 

The various scenarios of the STECF (7, 8, 10, 11) have also demonstrated a significant 
negative economic impact for trawlers in the short and medium term with a reduction in their 
gross added value. This is why STECF suggested in its last report (8) to conduct a detailed 
impact assessment for the further implementation of the management plan in order to 
calculate possible scenarios (including mitigation and adaptation measures 

possible) regarding the implementation of effort reduction and the possible economic 
performance of the fishing fleets. 

It should be remembered that the trawl fleet is structuring for the fishing industry in the 
Mediterranean (fish auctions, wholesalers, cooperatives, fishmongers). Thus, this reduction in 
the effort quota weakens the entire sector on the Mediterranean coast. 

Concerning the closure areas more specifically, France has defined two spatio-temporal 
closures in the Gulf of Lion in accordance with Article 11 of the management plan - one of 
3 368 km² for eight months, the other of 3 468 km² for six months – to meet the objectives of 
protecting juvenile and spawning hake. These two areas represent 49% of the area exploited 
in the Gulf of Lion and a significant part of French activity. It should be recalled the 
demonstrated effectiveness of these spatio-temporal closures (4) and the strengthening of 
management measures in the GFCM FRA area of the Gulf of Lion in 2021 (12). 

46 

 
 
 
 
 
 
8 Scientific, Technical and Economic Committee for Fisheries (STECF) – Evaluation of the 
fishing effort and catch regime for demersal fisheries in the western Mediterranean Sea – 
PART IX (STECF-22-11). Publications Office of the European Union, Luxembourg, 2022. 

9 Arrêté du 28 avril 2022 relatif à la mise en oeuvre d’un plan de sortie de flotte pour les 
navires pêchant au moyen d’un chalut dans le cadre du plan de gestion pluriannuel en faveur 
de la conservation et de l’exploitation durable des stocks démersaux en Méditerranée en zone 
CGPM 37.GSA7 

10 Scientific, Technical and Economic Committee for Fisheries (STECF) – 69th Plenary 
Report (PLEN-22-01). EUR 28359 EN, Publications Office of the European Union, 
Luxembourg, 2022, ISBN 978-92-76-51973-7, doi:10.2760/192738, JRC129241 

11 Scientific, Technical and Economic Committee for Fisheries (STECF) – Evaluation of 
fishing effort regime in the Western Mediterranean – part V (STEC-20-13). EUR 28359 EN, 
Publications Office of the European Union, Luxembourg, 2020, ISBN 978-92-76-27701-9, 
doi:10.2760/143313, JRC122924 

12 Recommendation GFCM/44/2021/5 on the establishment of a fisheries restricted area in 
the Gulf of Lion (geographical subarea 7) to protect spawning aggregations and deep-sea 
sensitive habitats, repealing Recommendation GFCM/33/2009/1’ 

Section 4 – Control and enforcement  

Q14:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  allowed  the 
national competent authorities to ensure compliance with the MAP itself?  

No opinion. 

Q15:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

  / 

Q16:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

  / 

Q17:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

  / 

47 

 
 
 
 
 
 
 
Section 5 – Regional cooperation  

Q18:  To  what  extent  has  the  MAP  in  your  opinion  strengthened  regional  cooperation, 
including with stakeholders?  

A little. 

Q19: Do you have specific comments on this point? 

The management plan is a regulatory framework allowing Member States to put in place 
regional measures. The French sector thus participates actively in the AC which provide 
opinions on the joint recommendations. Likewise, the French sector works closely with its 
administrations on these issues. 

From this experience, the French sector emphasises the importance of fluid and regular 
communication aimed at strengthening collaboration between actors. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q20: Given the Covid  and the fuel  crises, has the overall socio-economic situation of the 
fisheries sector improved since the entry into force of the MAP?  

Not at all. 

Q21:  Given  the  Covid  and  the  fuel  crises,  do  you  see  a  positive  correlation  between  the 
implementation of the MAP and the socio-economic situation of the fisheries sector?  

Not at all. 

Section 7 – Overall assessment   

Q22: What is your overall assessment of the western Mediterranean MAP?  

Negative. 

Q23: Do you have final comments? 

On the form of the consultation, it should be noted that the format does not allow us to 
comment on certain aspects of the management plan, which nevertheless seem important to 
raise. In this context, certain elements were brought in when answer boxes were available. 

Regarding the subject of this consultation, it should be noted that the French sector in the 
Mediterranean has been applying, on its own initiative and for years, sustainability measures, 
always seeking the collaboration and support of the responsible administrations and scientific 
research. The constructive dynamic carried by the French sector produces positive effects on 

48 

 
 
 
 
 
 
 
 
the resource, in particular due to the significant efforts made to apply the measures of the 
management plan (trawl and longline fishing effort quota, spatio-temporal closures, catch 
limit for shrimps). It should also be noted that factors other than fishing pressure, already 
highlighted by scientists and the European Commission themselves (pollution, demographic 
pressure, climate change, invasive species, etc.), can influence stocks and deserve to be 
studied further. 

In addition, the application of the management plan has so far focused too much on fixing 
fishing opportunities in the short term, without taking into account the socio-economic 
impacts. Article 3.3 of the management plan states that ‘The plan shall implement the 
ecosystem-based approach to fisheries management in order to ensure that negative impacts 
of fishing activities on the marine ecosystem are minimised’. It therefore seems necessary to 
take into account the three pillars of sustainability in order to guarantee fishing and 
aquaculture activities that are environmentally, socially and economically sustainable. The 
CFP must contribute to guaranteeing a decent standard of living for the fishing sector. The 
achievement of these objectives must contribute to the security of the food supply and bring 
about spin-offs in terms of employment. Thus, the socio-economic dimension of the CFP 
must be reinforced and Article 2.1 of the CFP must be taken into account when establishing 
management measures. 

It is now necessary for the sector to focus on future developments in order to face the 
challenges ahead. 

That being said, it seems important to deploy scientific resource to improve means of 
knowledge in the Mediterranean (assessment of stocks, evaluation of other anthropogenic 
factors, etc.) and to evaluate the impacts of management measures on the fishing resource and 
fishing activities. 

49 

 
 
      
 
 
6.4. Individual MedAC member: Representatives of Spanish sector (UNACOMAR) 

Section 1 – Progress made towards sustainable fishing levels 

According  to  the  MAP,  MSY  is  to  be  achieved  for  all  relevant  stocks  on  a  progressive, 
incremental  basis  by  2020  where  possible,  and  by  1 January  2025  at  the  latest.  All  stocks 
covered by the MAP are managed by yearly fishing opportunities, including since 2022 catch 
limits  for  species  of  deep-water  shrimps.  Out  of  20  stocks,  15  received  an  analytical 
assessment  by  STECF  in  2022  of  which  7  had  estimated  biomass  above  Bpa  and  4  had 
estimated biomass below Blim. Out of the 20 West Med demersal stocks, 5 stocks were near 
MSY in 2020 and 7 stocks were near MSY as of 2022.  

In your opinion 

Q2: Has  the existence of a MAP facilitated the process  of setting of fishing opportunities 
for the relevant stocks?  

No opinion. 

Q3: To what extent has the MAP contributed to increasing the number of stocks at MSY?  

Significantly. 

Q4: Has the MAP helped in dealing with difficult cases such as European hake or other 
sensitive stocks? 

Significantly. 

Q5: Do you have specific management suggestions to address the specific case of European 
hake? 

It is urgently necessary not only to take into account the pressure of fishing on the stocks but 
to adopt a global ecosystem-based approach which takes into account all the pressures on the 
marine environment (climate change, pollution, other marine activities, etc.).  

The  European  Commission  recognises  that,  apart  from  the  economic  crisis  and  the  energy 
crisis  (both  exacerbated  by  the  Russian  invasion  of  Ukraine),  it  exist  a  triple  crisis  due  to 
Climate Change, Biodiversity Loss and Pollution. 

None  of  these  three  crises  has  its  origin  in  professional  fishing.  A  holistic  vision  must  be 
applied urgently, and stop acting only on fishing activity. The precautionary principle cannot 
lead  to  the  decision  to  act  even  if  we  do  not  have  all  the  information.  That  is  absurd.  The 
precautionary  principle  requires  that  decisions  not  be  made  hastily.  Much  less  that  they  are 
taken by acting solely on the Fisheries. 

It  should  not  be  forgotten  that  Fishing  and  Aquaculture  are  the  only  human  activities  that 
require  the  state  of  the  resource  to  be  the  best.  The  rest  of  the  activities  (Tourism,  offshore 
wind energy, merchant marine, etc.) do not care what the state of the resource is. 

50 

 
 
 
 
 
 
Regarding  specific  measures  relating  to  hake,  we  cannot  forget  that  the  Mediterranean 
fisheries  concerned  by  the  management  plan  are  multi-specific.  In  this  sense,  the 
Mediterranean sector is opposed to the management method by TAC for stocks. The TAC for 
the Red Shrimp is a new error. And what doesn’t have sense is to apply several measures over 
an activity without knowing how every one of these measures is working and affecting. It is 
needed to continue developing scientist studies (that at least needs more than 3-4 years to get 
a real feedback) in order to know which could be the best management measures, look about 
how the measures already applied are ‘working’ and how are the initial results observed, and 
so on. 

In  this  way,  the  introduction  of  a  TAC  for  the  Hake  is  not  desirable,  especially  for  fleets 
whose proportion of hake catches in total catches is low, which could contribute to a risk of 
choke species. 

Furthermore,  the  increase  in  the  minimum  catch  size  for  hake  will  lead  to  an  increase  in 
discards  of  undersized  fish  and  could  make  the  derogations  established  under  the  delegated 
acts incompatible (de minimis exemptions). 

In  addition,  it  seems  impossible  to  absorb  further  reductions  in  fishing  effort  because  they 
would  jeopardise  the  sustainability  of  the  companies  while  the  profession  has  made 
substantial efforts since the beginning of the management plan in 2020.  

Following  the  establishment  of  large  spatio-temporal  closure  areas  in  the  Gulf  of  Lion 
(6000km²  over  a  total  area  of  12 000-13 000km2)  to  protect  juveniles  and  adults  of  hake, 
which  have  demonstrated  their  effectiveness,  it  seems  impossible  to  agree  to  the  closure  of 
additional areas in French waters. 

Finally, the replenishment of biological stocks is a process that takes time. A study by Ifremer  
has shown in particular that a period of two to three years is necessary to see the effect of the 
reduction in fishing effort by trawlers on the hake stock. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q6: To what extent have discards been eliminated and the landing obligation actually been 
implemented?  

Counterproductive. 

Q7: To what extent has the MAP contributed to achieving the current situation, notably via 
discard plans and technical measures?  

No opinion. 

Q8: To what extent do you support more selectivity measures?  

51 

 
 
 
 
 
A little. 

Q9: if yes, which selectivity measures do you support specifically? 

The Mediterranean sector notes that the management plan has heightened interest in the topic 
of selectivity.  

However,  some  studies,    have  shown  strong  unsustainable  economic  losses  during  a  mesh 
change,  with  a  loss  of  catches  for  stocks  already  close  to  the  MSY  (mullet  for  example)  in 
some  cases  or  stocks  which  are  not  affected  by  the  management  plan.  Furthermore,  they 
demonstrated that the effectiveness of increasing selectivity is strongly related to the species, 
the depth range and the area where fishing takes place. 

Has we have explain before, it is needed to have more time, in order to continue developing 
scientist  studies  looking  for  selectivity  improvements.  There  are  several  works  on  the  way 
about the use of the square mesh on 45 and 50 mm.  

As long as its usefulness for the benefit of the sustainability of the target species is not known, 
nor  is  its  impact  at  an  economic  and,  therefore,  social  level,  the  direct  and  thoughtless 
application of new measures cannot be expected. Even less continue to apply a reduction in 
available work days. 

The situation of fishing microenterprises is becoming more complicated every day. But while 
some fishing companies apply measures to try to remain operational (staff reduction, etc.), the 
representative  structures  that  allow  the  work  of  our  Fishermen  and  compliance  with  the 
complicated  Community  regulations,  such  as  Brotherhoods,  Associations,  Producer 
Organisations,  Cooperatives  etc.  are  suffering  the  direct  effects  of  the  loss  of  economic 
performance of  fishing  micro-enterprises, but  without the possibility of adjusting  their costs 
(the  occupancy  fees,  rates,  etc.  charged  by  the  Public  Administrations  remain  the  same  or 
increase, as do the wages, energy costs, etc.) or passing them on. If these structures fail, then 
it  will  be  impossible  for  the  fishing  vessels  to  continue  working.  And  this  is  a  reality  that 
nobody takes into account. 

It is absolutely urgent that the Community Administrations come to know the existing social 
and economic reality in our ports. This is also a necessary task in the application of the MAP, 
in addition to maintaining a continuous and exquisite follow-up on the effects produced by the 
multiple measures applied on each of the three pillars:  environmental, economic and social. 
This is the true exercise of application of the Precautionary Principle. 

It should be recalled that some Member States have opted for selectivity via the establishment 
of spatio-temporal closures, by closing access to fisheries to certain areas at key times for the 
biological cycle of species. 

In the Catalonia case, there are not only temporal closures going from two to three months per 
year (from long  time ago;  Long before the  application  of the MAP) but  there  are definitive 
closures of a total of almost 500 square kilometres. 

52 

 
 
 
It  is  important,  in  addition  to  continuing  to  study  the  45  and  50  mm  meshes,  to  continue 
investigating the use of flying trawl doors, which avoid contact with the seabed, with all the 
advantages that this measure has, in addition to significant savings in fuel and a reduction in 
carbon emissions. 

Regarding  the  landing  obligation,  the  dogmatic  application  of  Article 15  in  the  context  of 
mixed  fisheries  remains  impossible  without  serious  socio-economic  consequences  on  the 
fisheries concerned. 

Section 3 – Ecosystem-based approach  

Q10:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status, been achieved?  

Significantly. 

Q11: To what extent have the closure areas contributed to the current situation?  

Significantly. 

Q12: To what extent has the MAP contributed to the current situation?  

Significantly. 

Q13: do you have specific comments on this point? 

The successive reduction in fishing effort by trawlers during the management plan has had a 
very negative impact on the profitability of companies and the economic performance of 
fleets, thus jeopardising the continuation of their activity, particularly in a context of increased 
fuel prices as observed in 2021 and the impact of the Covid19. 

In this context, impacts on supplies to fish auctions and fish markets are being and suffering 
with enormous landing losses for the fish auctions and, for this reason, in the fisheries 
representative entities that manage them (Brotherhoods, Cooperatives, Associations, Producer 
Organisations). 

This means that the entire backbone structure of professional fishing is being dynamited from 
its roots. Many of these structures are suffering significant economic losses in the last 4 years, 
which cannot be sustained much longer in time, which is why imminent bankruptcies are 
going to occur that will drag down entire fleets. 

The various scenarios of the STECF  have also demonstrated a significant negative economic 
impact for trawlers in the short and medium term with a reduction in their gross added value. 
This is why STECF suggested in its last report to conduct a detailed impact assessment for the 
further implementation of the management plan in order to calculate possible scenarios 
(including mitigation and adaptation measures possible) regarding the implementation of 
effort reduction and the possible economic performance of the fishing fleets. 

53 

 
 
 
 
 
 
It should be remembered that the trawl fleet is structured for the fishing industry in the 
Mediterranean (fish auctions, wholesalers, cooperatives, fishmongers) which is typical of 
Coastal Fishing. There is no artisanal fishing nor industrial fishing. We are always talking, in 
the Mediterranean, of its own and characteristic socioeconomic reality, of coastal fishing, of 
local and proximity production, of fishing activity of the day, leaving and returning to the 
same port. 

Thus, this reduction in the effort quota weakens the entire sector on the Mediterranean coast. 

Concerning the closure areas more specifically, it must be remembered that (e.g.) France has 
defined two spatio-temporal closures in the Gulf of Lion in accordance with Article 11 of the 
management plan - one of 3 368 km² for eight months, the other of 3 468 km² for six months 
– to meet the objectives of protecting juvenile and spawning hake. These two areas represent 
49% of the area exploited in the Gulf of Lion and a significant part of French activity. It 
should also be recalled the demonstrated effectiveness of these spatio-temporal closures and 
the strengthening of management measures in the GFCM FRA area of the Gulf of Lion in 
2021. O, también, cuanto hemos expuesto anteriormente sobre las medidas que se aplican, 
desde hace años, en Cataluña, región limítrofe con Francia en esa misma zona (GSA 6 and 7). 

Section 4 – Control and enforcement  

Q14:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  allowed  the 
national competent authorities to ensure compliance with the MAP itself?  

No opinion. 

Q15:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

As we try to explain, the socioeconomic reality of the Mediterranean is unique and different 
from that of other areas (such as the Atlantic). This reality has not been taken into account, 
and the Commission has limited itself to the horizontal application of measures thought and 
designed for other realities. This, however, has produced some valuable effects. 
Reducing available work days is not an appropriate measure. But, in any case, new reductions 
can no longer be applied, since the fishing micro-enterprises are working below the break-
even point. 
The legal regulations of the different member states contemplate a total of 260 working days a 
year. Leaving companies for less than 150 days is outrageous and can never be described as a 
‘management measure’. 
As has been stated, regions of Spain, France and Italy have been applying different types of 
measures for some time, in most cases at the initiative of the fishermen. Space-time closures 
and definitive closures, type of mesh, reduction in working hours, etc. These are measures 
that have been in place for a long time. 
A holistic vision is required, which takes into account the reality of the Mediterranean, which 
takes into account each and every one of the activities that Man carries out, which takes into 
account the Triple Crisis of which the European Commission speaks (Change Climate, 
Biodiversity Loss and Pollution), taking into account the economic and energy crisis, the 
Russian invasion of Ukraine, the lingering effects of the COVID-19 pandemic, etc. 

54 

 
 
 
 
The Fishing Sector wants to continue researching the use of flying trawl doors, meshes of 
other sizes, better materials that allow greater selectivity and fuel savings, etc. 
The control that exists over fishing activity in the European Union is the largest in the world. 
Our fishermen are the most supervised. But the problem is not our fishermen. They are the 
most formal and experienced professionals. For centuries they have been organised in 
structures recognised as true legal orders, and this long before the appearance of the structures 
of modern States. There are regulations from the fourteenth and fifteenth centuries, and much 
earlier, with courts and sanctioning systems. 
Instead of applying the ‘presumption of guilt’ to our fishermen, media should be used to learn 
their social and economic reality in depth. 
And more technical and economic means must be used to continue investigating the state of 
the resource, technological improvements, etc. 
We don’t need more controls. Our fishermen are not criminals. They are the guardians of the 
sea. And they are the ones who have a real interest in ensuring that the sea and natural 
resources are in the best conditions, even if it is an exercise in pure selfishness: fishermen 
have always been aware that they live off the resource. Now you should be aware of all this, 
and stop applying measures in a multilateral way, without time for reflection or study. That is 
an error. 
We don’t ask for anything else. 

Q16:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Reading the previous answer gives an answer to this one. 

Q17:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

As with the previous one, reading the previous answer gives an answer to this one. But to be 
more clear: no, there is not needed to implement more specific control measures.  

What it is needed is to know better the Fisheries reality in the Mediterranean. What is needed 
is to construct an own Common Fisheries Policy specific for the Mediterranean. 

Are you ready for this? 

Section 5 – Regional cooperation  

Q18:  To  what  extent  has  the  MAP  in  your  opinion  strengthened  regional  cooperation, 
including with stakeholders?  

A little. 

Q19: Do you have specific comments on this point? 

55 

 
 
 
 
 
 
The management plan is a regulatory framework allowing Member States to put in place 
regional measures. The Mediterranean sector thus participates actively in the MEDAC which 
provide opinions on the joint recommendations. Likewise, the Mediterranean sector works 
closely with its administrations on these issues. 

From this experience, the Mediterranean sector emphasises the importance of fluid and 
regular communication aimed at strengthening collaboration between actors.  

The Advisory Council carries out its work in an exquisite and responsible manner. Now, what 
is necessary and desirable is that the Member States collaborate among themselves, and with 
the Fishing Sector, with the Advisory Councils,,. 

In the same way, the European Commission should be more attentive to the approaches of the 
Member States and, above all, to the work carried out by MEDAC and to that carried out by 
the representative organisations that are part of it. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q20: Given the  Covid  and the fuel  crises,  has the overall socio-economic situation of the 
fisheries sector improved since the entry into force of the MAP?  

Counterproductive. 

Q21:  Given  the  Covid  and  the  fuel  crises,  do  you  see  a  positive  correlation  between  the 
implementation of the MAP and the socio-economic situation of the fisheries sector?  

Counterproductive. 

Section 7 – Overall assessment   

Q22: What is your overall assessment of the western Mediterranean MAP?  

Neutral. 

Q23: Do you have final comments? 

I believe that the MAP has produced some positive effects, but it is also producing many 
negative effects that, coinciding in time with situations as serious as the COVID-19 
Pandemic, and the Economic Crisis, the Energy Crisis and the triple Crisis of Change climate 
change, the loss of biodiversity and pollution are leading fishing to a dead end situation. 

Instead of applying a holistic vision, and of the precautionary principle also with respect to 
the other two pillars of the Common Fisheries Policy (economic and, above all, social), the 
Commission limits itself to applying highly restrictive measures, several measures at the same 
time, with a short-term time frame (only 5 years), etc. with which the situation that has been 

56 

 
 
 
 
 
 
 
caused is very serious, and it is ruining the Coastal Fisheries and the local economies of our 
coast, harming elementary principles such as those of Food Sovereignty and Food Security. 

In fact, a decapitalisation of our primary production structure (not only at sea) is taking place, 
with which we are placing European citizens in the hands of third countries where there is no 
regulation such as the Community, nor does it exist a culture of sustainability like the 
European one. And, therefore, we are feeding Europe with productions that do not meet the 
high demands of the EU. This is how we harm our citizens and the environment. 

That is not the ‘construction of the European house’, but rather its dismantling. 

Study and analysis of all measures is required before their application. And after its 
application, it is also necessary to study and analyse its effects. And for all this it is necessary 
to have enough time. Short-termism is destroying sustainable and absolutely necessary 
activities for our subsistence as a society and for the sustainability of our sea and its resources. 

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6.5. Detailed MedAC advice on the consultation questions 

Public answer available at: 
110_letter_from_mare_to_medac_pescamed_on_reply_to_west_med_map_eu_survey.pdf (med-ac.eu) 

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