Official Journal of the European Union

C 288/68

Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the European Parliament and of the Council establishing a multi-annual plan for small pelagic stocks in the Adriatic Sea and the fisheries exploiting those stocks’

(COM(2017) 97 final — 2017/0043 (COD))

(2017/C 288/09)




European Parliament, 01/03/2017

Council, 04/04/2017

Legal basis

Articles 43(2), 114(1) and 304 of the Treaty on the Functioning of the European Union



Plenary assembly decision




Section responsible

Agriculture, Rural Development and the Environment

Adopted in section


Adopted at plenary


Plenary session No


Outcome of vote



1.   Conclusions and recommendations


The EESC agrees with the GFCM-FAO (1) on the need to act to protect stocks of small pelagic species that are distressed due to over-exploitation, and supports the overall aim of urgently implementing a sustainable fisheries system and achieving maximum sustainable yield (2) in accordance with the common fisheries policy (3) (PCP).


The Committee supports the Commission’s decision to opt for a regulation as the legislative instrument for introducing a multiannual plan to protect stocks of small pelagics in order to standardise the rules in force and strengthen governance processes.


While agreeing with the environmental protection and biodiversity objectives, the EESC considers that the Commission’s proposal is incomplete and contradictory in many areas. These problems are the natural consequence of a series of contradictions in the CFP that the Committee has already pointed out in previous opinions (4). More specifically, the EESC is highly concerned that if suitable additions and readjustments are not made to the present proposal, it may jeopardise the attainment of these objectives and prove highly prejudicial to the sector’s businesses and workers (5).


The Committee considers that the management model proposed by the Commission, based on the Council setting annual fishing possibilities, cannot be brought into line with the biological characteristics of small Adriatic pelagics and the mix of species (6) it contains, the types of vessel and gear (small-scale fisheries) (7) or the number and size of ports. For all these reasons, the Committee considers that the MEDAC (8) proposal to step up measures concerning fishing efforts via a ‘traffic light’ approach is best suited in terms of both substance and method, as it stems from broad agreement by organised civil society as a whole.


The EESC is surprised to note that the Commission’s proposal is not based on a detailed economic and social impact assessment (9). This shortcoming is aggravated by the fact that the fisheries sector throughout the Mediterranean has been in crisis for more than 20 years (10) and new, drastic rules that are not properly thought out could deliver the final blow to the sector. The EESC also notes a total lack of measures to provide financial support for and/or convert businesses and workers to accompany the proposal to reduce catches of sardine and anchovy although these are a crucial economic resource for the small local (and often island) communities and ancillary sectors (11).


The Committee therefore advocates prompt involvement by the DG for Employment and the launch of a sector-based social dialogue, consulting the EU Sectoral Social Dialogue Committee — Sea Fisheries (EUSSDC) to identify the most appropriate measures to compensate the economic and social impact. In this respect, the EESC views the EMFF as the most appropriate financial instrument for supporting businesses and working in the transition to sustainable fisheries. The EESC also considers that converting businesses to fishing tourism (Blue Economy (12)) or aquaculture (13) can certainly offer a valid alternative, but cannot under any circumstances replace the for the principle that traditional fishing, primarily due to the biological characteristics of fish (e.g. their need for space), cannot be rescaled or abolished.


Given the significant environmental, economic and employment-related consequences of the provision, the Committee considers that the new fisheries management plan cannot be implemented by means of delegated acts, and calls on the Commission to immediately make this absolutely clear, in the interests of all the relevant stakeholders (14).


The Committee emphasises that all environmental protection measures may prove ineffective unless the problems of unfair competition and illegal fishing are tackled upstream. stepping up controls, imposing heavier penalties and introducing a full ‘sea-to-table (15)’ traceability system with exhaustive health checks both at the borders and the point of origin. The Committee considers it essential in particular to relaunch cooperation between all the countries around the Mediterranean Sea, on the basis of the programme and the objectives laid down in the Ministerial Declaration signed in Malta on 30 March 2017 (16).


The Committee considers that the MSY objective should be met within a reasonable timescale. The deadline of 31 December 2020 does not appear feasible. This proposal is based on an awareness of the natural repopulation times of small pelagic fish stocks and for control authorities, businesses and workers to adjust to the new legislative provisions (especially in the event that these are drastically amended by a shift from effort to quotas). Further, the EESC considers that the possible use of safeguard clauses is not a valid option due to the excessive impact they would have in social and economic terms.


The Committee urges the Commission to define the operational aspects of regionalisation more clearly, linking from the outset the sustainability objectives for fish stocks with the actual costs levels borne by businesses, in order to ensure their survival.


In the interests of European consumers, the EESC calls for a detailed impact assessment to be made as soon as possible on the price trends for protected species, covering both fish for direct sale and fish for processing. The Committee also urges the Commission to devise ‘sustainable fish’ quality certification schemes, in order to increase consumer awareness and generate added value for businesses (17).

2.   Introduction


The Adriatic (18) is a sub-region of the Mediterranean which is very rich in fish stocks and small pelagic species (19), principally anchovy and sardine (20), are among the most profitable. According to recent data from the GFCM-FAO (21) and STECF (22), stocks of anchovy and sardine are distressed as a result of over-exploitation and require greater protection.


The majority of catches are made by Italy and Croatia, in the northern part of the Adriatic. Slovenia takes part marginally (less than 1 %), together with Albania, Bosnia and Herzegovina and Montenegro, who account for an equally residual share (approximately 1 %) (23).


The existing management framework is based on limitation of fishing effort (24), coupled with additional measures such as spatio-temporal closures and minimum landing sizes. These measures have not however been implemented in a coordinated, continuous and uniform way by States (especially during fishing biological recovery periods (25)), leading to confusion among operators and hampering reconstitution of stocks.


In keeping with its mandate, MEDAC has drawn up an opinion on small pelagics in the Adriatic including operational proposals drawing on a two-year consultation among all relevant stakeholders (entrepreneurs, workers, cooperatives, environmentalists, consumers), published on 11 March 2016 (26).

3.   Gist of the Commission proposal


In order to protect stocks small pelagic species in the Adriatic Sea, sardine and anchovy in particular, the European Commission has drawn up a regulation intended to establish a multi-annual plan to tackle this environmental emergency. The ultimate aim is to achieve maximum sustainable yield (27) (MSY) by 2020, as set out in the common fisheries policy (CFP). The multi-annual plan as a whole should be evaluated every five years.


The proposal for a regulation breaks with all management measures so far applied in this geographical area, introducing a single governance system, limiting national derogations (closed biological recovery periods and control methods in particular) and, most importantly, stipulating that the management system be based on limiting catches (28) (TACs) and no longer on reducing the fishing effort.


The proposal, which is modelled on the approach and content of the multi-annual plan for certain fish stocks in the Baltic Sea (29), is founded on the STECF opinion and is, at the same time, at loggerheads with the MEDAC opinion based on a more restrictive adjustment of the fishing effort (traffic light system (30)).


More specifically, the Commission proposes setting conservation reference points, expressed in tonnes of spawning stock biomass and fishing mortality ranges. When scientific advice states that any of the stocks is below the reference point, catches for that stock must be reduced. The Commission points to delegated acts as the means for the entire practical implementation of the new management system.


The proposal envisages regional cooperation between Member States for adopting specific conservation measures. Particular technical measures (e.g. mesh sizes, fishing gear characteristics) may also be amended by means of ‘regionalisation’.


The proposal also enables the competent authorities to identify, locate and systemically control the activity and catches of all vessels of or above eight metres, by means of the relevant digital instruments (e.g. electronic logbooks). Moreover, all ports must be equipped with digital instruments capable of checking the catches of all vessels once unloaded. To this end, all vessels must notify the competent authorities of their arrival in port at least four hours in advance.

4.   General comments


In the light of the scientific studies published on the question, the EESC agrees that it is necessary to take action to protect small pelagic stocks in the Adriatic that are currently distressed.


The Committee also agreed on the need to opt for a regulation as the legal instrument in order to strengthen governance and make the rules uniform and binding for all relevant countries and stakeholders, so as to resolve environmental impact problems in fisheries, caused principally by uneven and uncoordinated application of the current management measures.


In line with the CFP and with its previous opinions, the EESC maintains that the priority is to reach maximum sustainable yield (MSY) in order to protect environmental, food-related, economic and productive requirements jointly (31).


The EESC however considers that the Commission proposal is incomplete and contradictory in many key sections, and fears that these shortcomings may both jeopardise the attainment of the environmental sustainability objectives and be excessively prejudicial to workers, businesses and local communities.


5.1   Need for adequate economic and social impact assessment and measures to offset the effects of the multi-annual plan on businesses and jobs


In contrast with the wishes of the GFCM-FAO and MEDAC, an in-depth assessment of the socio-economic impact is lacking (32). This aspect is of crucial given that the fisheries sector in the Mediterranean has been in crisis for a number of years (33) and that a poorly thought-out reform could be harmful to businesses and workers.


It is also pointed out that the Commission has issued its proposal without waiting for the outcome of the GFCM-FAO working group, set up under paragraph 14 of Recommendation 40/2016/3 and tasked with assessing the impact of a series of measures including catch limitations and fishing effort regime for the sustainable management of the fishing of small pelagic stocks in the Adriatic Sea.


The EESC further considers that the proposed measures cannot be cost-free given a 30 % reduction in catches, a 25 % reduction in revenue for businesses and the loss of 10 % of jobs. In addition to the previously mentioned problem with the data collection method, the Commission fails to introduce any measures to cushion the effects of the regulation, transferring the economic and social cost of the multi-annual plan to the Member States alone.


The EESC points out that the Commission has not fully assessed the impact on the ancillary sectors, local (often island) communities traditionally involving in fishing, the probable increase in prices and the questionable quality and sustainability of products necessarily imported from non-EU countries (primarily North Africa) to meet internal demand.


The regulation introduces no mechanism to support businesses financially or convert them (e.g. aquaculture), and there are no measures to supplement income, provide training and/or find new jobs for workers (fishermen or in ancillary sectors) who will lose their employment.

5.2   Biological characteristics of the Adriatic


The EESC considers that the successful model offered by the multi-annual plan for fish stocks in the Baltic is unsuitable for the Adriatic. As highlighted by the GFCM-FAO, the Baltic is a single-species sea in which it is easy to carry out targeted fishing because few types of fish coexist there and in which it is consequently easy to set catch limitations. In contrast the Adriatic, like the rest of the Mediterranean, is a multi-species sea in which many species of fish can be found together in the same area (34). The only precedent for catch limitations in the Mediterranean concerns bluefin tuna, a proposal supported in principle by the EESC (35), since it related to species whose characteristics (mainly size) and fishing methods are very different those of small pelagics.


The EESC also notes that fishing in the Adriatic is traditionally carried out with very different methods to those in the Baltic. Adriatic fisheries are family businesses using small vessels (8-12 metres). Owners are often fishermen themselves, with average crews of three people. Fish are therefore landed in many small ports, but have for centuries been an important economic factor for the (often island) communities concerned.

5.3   Management system and delegated acts


The new catch-based management system is not clearly and precisely detailed in the body of the proposal, which simply puts forward a legislative framework to be fleshed out subsequently via delegated acts. Since this is a highly sensitive issue on account of the environmental, economic and employment aspects involved, this would be a major constraint for businesses when planning the fishing activity on which their own survival depends.

5.4   Need for a timescale commensurate with the maximum sustainable yield (MSY) objective


The regulation in force for the Baltic, adopted in 2016, allowed businesses — and fish stocks — five years (until 2020) to reach sustainable fisheries levels, corresponding to the end of the CFP. In contrast, for the Adriatic, the Commission plans to impose a far stricter road map, of less than two years (2019-2020), with the sole aim of coinciding with the end of the CFP, without taking account of the natural reproduction cycles of small pelagics (variable due to many factors) or the time required for businesses and local authorities to adjust to more restrictive management measures that are completely different from those in force over the last 30 years. This entails a very real risk of failing to meet the pre-determined environmental objective and destroying a sector (along with its ancillaries) on which hundreds of coastal communities depend.

5.5   Unfair competition from third countries and illegal fishing


The fisheries sector in the Mediterranean, including the Adriatic, has been in crisis for more than twenty years for a variety of reasons, including unfair competition from third countries (principally from North Africa where fishing and sales are not subject to any controls) and illegal fishing (behind which illegal employment is also often to be found). At present, the majority of legal businesses are already only just hanging on (36), and it is only the strong personal and family ties between owners and their small crews that has prevented the sector’s final collapse.


The EESC therefore considers that the sole effect of moving from an effort-based system to one based on catches (reduced by 30 %), without appropriate arrangements to offset unfair or illegal practices, would be the immediate closure of a very high number of businesses operating legally, together with loss of jobs, without necessarily solving the environmental problems.

5.6   Regionalisation


The proposal makes no detailed provision for ‘taxation’. This loophole could create a serious problem of competition between States due to the different costs for businesses from country to country, arising from factors such as pay, social and welfare charges and markets.


The EESC notes in particular that if regionalisation is defined solely in terms of protection of fish stocks, the EU would have to manage new and sharp conflicts in which company profits would vary according to business costs rather than the product of fishing.

5.7   Technological provision and controls


The EESC agrees with the need to make controls more effective by adopting digital technologies, although it would point out that, unlike the Baltic, the Adriatic coast features a large number of small ports (FAO-AdriaMed lists 238 fisheries ports between Italy, Slovenia and Croatia (37)) and many small vessels. The relevant authorities and businesses (already in crisis) will therefore need time and resources to adjust to the new legislative plan.


In contrast to the Commission’s argument, the EESC considers that selecting between ports for landing fish (ruling out the smaller ones) would be highly damaging for local communities. The Committee also considers that the economic impact on this measure on smaller vessels should be examined in greater detail, since under the regulation it would apply to vessels of eight metres or more.

5.8   Quality certification


The proposal makes no provision for quality certification/labelling mechanisms to support the economic sector affected by the reform. This aspect would be highly appreciated by consumers, who are constantly looking for healthy, high-quality and sustainable products. Such a measure would also be effective in tackling illegal practices and unfair competition.

5.9   Price variation


The Commission does not take sufficient account of the adoption of measures designed to counter the natural increase in the prices for small pelagics due to reduced catches, the main effect of which will be for these species to be bought by third countries lacking adequate controls and guarantees, particularly in environmental terms.

5.10   involvement of organised civil society


The EESC is surprised that the MEDAC opinion, summarising the views of all the relevant stakeholders (entrepreneurs, workers, cooperatives, environmentalists and consumers), published on 11 March 2016 (38) and representing more than two years’ work, has not been taken into sufficient consideration, to the extent that the Commission’s proposal appears radically different and in some areas in absolute opposition.

Brussels, 31 May 2017.

The President of the European Economic and Social Committee

Georges DASSIS

(1)  General Fisheries Commission for the Mediterranean.

(2)  Maximum sustainable yield (MSY) indicates the maximum quantity of fish that may be caught over an unspecified period of time without damaging stocks. This principle is one of the cornerstones of the common fisheries policy (CFP).

(3)  Regulation (EU) No 1380/2013.

(4)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183).

(5)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 1.17: ‘The EESC is disappointed that the proposal does not address the social dimension, which is taken into account throughout the fisheries and aquaculture sector (production, processing and marketing), and puts forward no concrete measures to improve working and living conditions and believes that the participation of the social partners at the appropriate level should be promoted’.

(6)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 1.6: ‘The EESC supports the proposal to establish multiannual plans with the aim of restoring and maintaining, as far as possible, all fish stocks above levels which can produce the MSY by 2015. Though laudable, this objective is difficult to apply in the case of mixed fisheries, and the EESC therefore calls upon the Commission to provide practical solutions to resolve any problems which may arise in those forms of fishery’.

(7)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 1.19: ‘The EESC believes that a definition of small-scale fishing based solely on vessel length is too simplistic and results in a large proportion of the small-scale fleet falling into the category of industrial fishing’.

(8)  MEDAC is a consultative body bringing together European and national civil society organisations representing the fisheries sector operating in the Mediterranean area. The role of MEDAC is to prepare opinions on fisheries management and socio-economic aspects relating to fisheries conservation in the Mediterranean, which are submitted to the Member States and the European institutions in order to facilitate the achievement of the objectives of the CFP, providing technical solutions and suggestions at the request of the Member States.

(9)  EESC opinion on Reform of the common fisheries policy (Green Paper) (OJ C 18, 19.1.2011, p. 53), point ‘Socio-economic impact assessments should be carried out alongside the process of improving fisheries resources and maintaining them at sustainable levels, with financial support measures to boost employment and encourage businesses to invest in innovation and development and provide professional training. Fishermen also need to be guaranteed a decent wage while stocks are recovering’.

(10)  According to the STECF (2016), more than 10 000 jobs were lost in the Mediterranean between 2008 and 2014, with a reduction in vessels of 14 % and job losses of 8 %. If ‘small scale’ fishing (vessels of less than 12 metres), which accounts for more than 50 % of the sector, is taken separately, the reduction in the number of vessels was of 16 % and jobs fell by 13 %. It should also be borne in mind that if not properly thought out, the plan could have a devastating impact on the countries directly affected — in Croatia, for example, small pelagics account for 90 % of fishing. In Italy between 2004-2015 fishing fleet capacity fell by 17 % in terms of numbers of vessels, with job losses at time of more than 20 %.

(11)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 3.3.6: ‘… the Committee considers that the application of measures to maintain or restore fish stocks above levels which can produce maximum sustainable yield by 2015 will have an impact on the fishing capacity of Member States’ fleets (…). The Commission should therefore provide for adjustment measures by offering social and labour-related alternatives for the fisheries sector to prevent the current loss of jobs due to the poor state of fish stocks’.

(12)  EESC opinion on The European Union Strategy for the Adriatic and Ionian Region (OJ C 458, 19.12.2014, p. 27), points 3.3, 3.4 and 3.5.

(13)  EESC opinion on Removing obstacles to sustainable aquaculture in Europe (OJ C 34, 2.2.2017, p. 73).

EESC opinion on Innovation in the Blue Economy (OJ C 12, 15.1.2015, p. 93), point 1.7.

(14)  EESC opinion on Delegated acts (OJ C 13, 15.1.2016, p. 145), point 1.8.

(15)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 1.21.

(16)  IP/17/770, European Commission secures 10-year pledge to save Mediterranean fish stocks.

(17)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183), point 4.5.

(18)  The Adriatic corresponds to GFCM Geographical Subareas 17 and 18.

(19)  These are small-sized species that live close to the surface (e.g. mackerel, herring, horse mackerel, blue whiting, boarfish, anchovy, argentine, sardine, sprat, etc.).

(20)  In Croatia, small pelagics account for 90 % of total catches.

(21)  The General Fisheries Commission for the Mediterranean was established in 1949 within the FAO. The main task of the GFCM is to promote the development, conservation and proper management of living marine resources.

(22)  The Scientific, Technical and Economic Committee for Fisheries was set up in 1993; it is a consultative body reporting directly to the European Commission. It comprises a pool of experts who are asked to submit opinions to the Commission on fisheries management.

(23)  GFCM, The State of Mediterranean and Black Sea Fisheries, 2016, p. 25.

(24)  Fishing effort management combines restrictions on fleet capacity with the amount of time they can remain at sea.

(25)  Fishing is banned in specific areas during the biological recovery periods. It is an instrument that the EU has been using for 30 years to conserve marine fish stocks, fostering the natural reproduction of the most heavily fished species. Stopping fishing for a certain number of days effectively means giving fish time to complete their reproductive cycle undisturbed, thereby conserving fish stocks.

(26)  MEDAC, Medac advice on LTMP for small pelagics in GSA 17 (Northern Adriatic), Prot. 94/2016, March 2016.

(27)  Maximum sustainable yield (MSY) indicates the maximum quantity of fish that may be caught over an unspecified period of time without damaging stocks.

(28)  Total allowable catches or TACs are catch limits for specific fish stocks, expressed in tonnes. The Commission lays down these limits on the basis of scientific opinions on the state of stocks, provided by advisory bodies such as ICES and STECF.

(29)  Including cod, herring, sprat and salmon.

(30)  MEDAC, Medac advice on LTMP for small pelagics in GSA 17 (Northern Adriatic), Prot. 94/2016, March 2016, pp. 7-8.

(31)  EESC opinion on the Common Organisation of the Markets in Fishery and Aquaculture Products (OJ C 181, 21.6.2012, p. 183).

(32)  SWD(2017) 63 final.

(33)  Ministry for Agricultural, Food and Forestry Policy, National Fisheries Plan 2017-2019. In Italy between 2004-2015 fishing fleet capacity fell by 17 % in terms of numbers of vessels, 26 % in terms of tonnage and 21 % in terms of engine power (kW). Downsizing of fishing capacity was particularly significant between 2010 and 2012, due in part to the economic crisis and in part to the spontaneous withdrawal of numerous vessels, encouraged by the permanent cessation measure proposed by the EFF.

(34)  GFCM, The State of Mediterranean and Black Sea Fisheries, 2016, p. 26.

(35)  EESC opinion on A multiannual recovery plan for bluefin tuna in the eastern Atlantic and Mediterranean (OJ C 24, 28.1.2012, p. 116), point 1.1: ‘The EESC endorses the European Commission’s proposals and acknowledges the efforts that both the Member States and fishermen are making to comply with the International Commission for the Conservation of Atlantic Tunas (ICCAT)’s tough bluefin tuna recovery plan. The plan is now yielding results, but its implementation is having serious socio-economic effects, which should be taken into account’.

(36)  The average income per fisherman is EUR 18-20 000 per annum, compared to EUR 60-80 000 per annum in the Baltic and North Seas.

(37)  Number of ports broken down by individual countries: Croatia 147; Italy 89; Slovenia 3 (www.faoadriamed.org).

(38)  MEDAC, Medac advice on LTMP for small pelagics in GSA 17 (Northern Adriatic), Prot. 94/2016, March 2016.