EFTTA against watering down the fish stocks protection

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EFTTA response to EU consultation on "Correction to the multiannual programmes for fisheries"

EFTTA, the European Fishing Tackle & Trade Association does not agree with changes, which water down the protection of fish stocks against overfishing.

We agree that the MAP texts could be phrased better, but this should not be achieved by lowering the stock protection level, which seems to be the case according to the Stockholm University Baltic Sea Centre. Cuttings from their analysis published on 7 Dec 2023:


ANALYSIS: “Those are our rules, and if you don’t like them, well, we’ll make others” 
Commission is removing the safety belt
We at the Baltic Sea Centre have pointed out that the TAC decisions are based on forecasts over stock growth, and that they by nature are uncertain. That it is imprudent to base management decisions on the assumption that the growth forecasts will always be realised in full. There are plenty of examples of fish growth forecasts not being realised. It would make sense to apply a bigger precautionary buffer.

Instead, the Commission is now proposing to remove the safety belt.

It claims that application of the seat belt may not be compatible with other provisions of the MAP, presumably the safeguard “remedial measures” that have failed to deliver. After all, Art. 5.2 only says that targeted fisheries MAY be closed, not that they MUST be closed. That means, its redundancy is not detailed enough.

The Commission also says that applying the seat belt may “result in potentially severe socioeconomic implications”. Not reflecting on the socioeconomic implications of two more herring stocks potentially going down the tubes like the cod and Western Baltic herring. 

For more information see also the following articles by the Stockholm University Baltic Sea Centre:


EFTTA has been the first respondent to the public consultation, which means that we are on top of the respondent list, no matter how many new responses are delivered.

EFTTA urges:

1) To not remove the articles 4(6) and 4(7) as proposed by the Commission but to merge the content with other articles, without lowering the protection level.
2) To take more seriously the term "rapid" in the MAPs ["to ensure rapid return of the stock concerned to levels above those capable of producing MSY"].

The European angling community - anglers and the dependant businesses - has been very accommodating, patient and suffered a lot with regard to the EU restrictions put on anglers' catches of bass, Baltic cod, Baltic salmon and eels in the hope that the management of commercial fisheries would follow suit so the overfished stocks could bounce back rapidly, more rapidly than what we see, or not see, these days.



NB! This concerns not only the Baltic Sea but all EU seas or species with a multiannual plan:


“Almost all important stocks and fisheries are managed by means of multiannual plans, which contain goals for fish stock management.”

Regulations establishing multiannual plans

Cod, herring and sprat stocks in the Baltic Sea

Demersal stocks in the North Sea

Demersal stocks in western Mediterranean Sea

Stocks fished in western waters