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Fiskesekretariatet

FishSec

The Fisheries Secretariat (FishSec) is a politically independent, non-profit organisation dedicated to the protection and restoration of marine ecosystem services, with a focus on fisheries.

Lobbying Activity

Meeting with Costas Kadis (Commissioner) and

7 Nov 2025 · Participation of NGOs to Advisory Councils

Meeting with Eva Maria Carballeira Fernandez (Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and

15 Jul 2025 · Recommendations on how to address shortcomings in the ICES advice and requests

Response to The European Oceans Pact

17 Feb 2025

FishSec welcomes the European Commissions initiative to develop the European Oceans Pact. The initiative responds to increasing demands to further protect and restore marine ecosystems and offers a fresh opportunity to meet global objectives for a healthy ocean to the benefit of all people. It represents a critical opportunity to address the inter-connected challenges facing our oceans and to ensure their health, resilience and productivity for future generations. The Oceans Pact must deliver a coherent, legally binding framework to restore marine ecosystems and ensure sustainable ocean governance by 2030. This is our key priorities: 1. Policy coherence, integration and co-operation: FishSec strongly supports the Commissions aim to achieve a single framework for all ocean-related policy actions. There is an urgent need to align legislation that directly apply to the oceans, such as the MSFD, the CFP, the MSPD, and frameworks for other pressures affecting the oceans, such as industry, water and agriculture policies, as well a global and EU objectives for nature protection and biodiversity. All pressures, not just direct activities like fisheries, shipping, offshore wind development and underwater noise and extractive industries, need to be addressed in a coherent framework. The Oceans Pact must bring coherence but also co-operation to decision-making and management to break the tradition of sector-focused work. 2. Legally binding targets and a clear time table: The Oceans Pact must include a roadmap with legally binding targets and a clear time table to protect and restore our seas, enabling sustainable long-term blue growth. 3. Full implementation of the CFP: Both commercial and recreational fishing greatly affects marine ecosystems and biodiversity. In the CFP, the EU already has a good basis for ensuring both environmental, economic and social sustainability but implementation remains piecemeal. The Oceans Pact needs to ensure its full implementation of its overarching objectives and operationalise the ecosystem-based approach. Implementation of articles 11, 12, 13, 14, 15, 17 and 20 warrant particular attention, but it is also fundamental to keep managing fishing capacity. We also need better control and enforcement, as well as fleet decarbonisation. 4. Moving towards a regenerative blue economy: the Oceans Pact needs to ensure a transition towards a regenerative blue economy, with long-term benefits to both coastal communities and marine ecosystems. A shift towards low-impact, small-scale fisheries that have a smaller carbon footprint, while also supporting local coastal communities is an important part of this. 5. Establish a new Ocean Fund: Establish a new fund to implement the aims of the European Oceans Pact and use it to fund both ocean protection and restoration efforts, and a just transition to a regenerative blue economy to the benefit of coastal communities and marine ecosystems. Harmful subsidies like fuel tax exemptions for fishing vessels should be eliminated. Ensure a participatory transition process that involves fishers, NGOs, scientists, and other stakeholders in decision-making. 6. Regional considerations: The Oceans Pact also needs to acknowledge regional challenges and contain enough flexibility to address them. For the Baltic Sea, for example, that means tackling the substantial pressures from land-based sources and agriculture to reduce eutrophication and pollution in order to achieve greater ecosystem health. 7. Marine knowledge, innovation and investment: Invest in technologies and solutions that reduce environmental impacts, such as gear innovation, habitat restoration, and decarbonization of the fishing industry. Support research and innovation to advance marine knowledge and ensure the competitiveness of EU ocean technologies. Incorporate the work of the European Fisheries Control Agency (EFCA) and the European Technology Platform (ETP) into the European Oceans Pact. Thank you!
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Response to Correction to the multiannual programmes for fisheries

31 Jan 2024

It is FishSecs view that the Commissions proposal should be rejected. We also object to the procedural handling of this proposal. A) The Commissions proposal to remove the failsafe from the multiannual management plans, i.e. Art. 4(6) of the Baltic MAP, which is there to protect vulnerable fish stocks in decline, will further jeopardize fish populations and the fisheries that depend on them. With the removal of Art. 4(6), the Baltic multiannual plan will no longer have a backstop which ensures that when a stock is at high risk of collapse, fishing opportunities have to be reduced to prevent it. Article 5 does not provide explicit details on preventing this high-risk scenario. It focuses on drastic action once the spawning stock biomass has already fallen below Blim, rather than a more preventative approach that aims for recovery before this critical point. We also question how the removal of this safeguard (Art. 4(6) and its equivalents) in the multiannual plans is coherent with the CFP objectives and the legal requirements of ecosystem-based fisheries management (EBFM) and the GES target descriptors concerning healthy fish stocks under the Marine Strategy Framework Directive (MSFD). To enable continued fishing on stocks on the verge of collapse cannot be done under the auspices of sustainable and ecosystem-based management. It also defies the precautionary approach. Two reasons are given in the Commission proposal for why these articles should be removed: 1) that there are inconsistencies between provisions under the two articles [in the Baltic MAP, between Art. 4(6) and Article 5], and 2) that there will be large socio-economic consequences if the article remains. We would argue that both of these statements are erroneous. First of all, Article 4(6) and Article 5 are not conflicting but rather complementary, sometimes overlapping; they differ in starting points i.e. trigger for action, targets and time frames. That leaves the socio-economic argument, which in essence means that fishing should be allowed to continue even when a stock is on the verge of collapse to prevent loss of income in the fishing sector, which is a very short-term approach that may well result in even larger socio-economic consequences. This increases the risk that the stock will indeed collapse, leaving a completely depleted recourse which negatively affects both the fishing industry and the ecosystem. B) Regarding the procedural aspects of this proposal and indeed the feedback process, we must object to the statement in the section Stakeholder consultation claiming that the Commission discussed the 5% rule with BSAC (and BALTFISH), as stated in point 3, as no formal discussion did take place. A proper consultation with stakeholders about potential inconsistencies and their effects, and how best to address any issues, BEFORE the proposal was finalised and published would have been appropriate. We disagree with the Commissions view that this step was unnecessary. An environmental impact assessment of the potential effects of this proposal would also have been relevant. Furthermore, we strongly disapprove of the attempt by the Commission and the Council to apply a fast track approach to approve this proposal, thereby circumventing the normal democratic procedures. To conclude, we consider the proposal and the procedures of which it has been presented to be of great concern and that the proposal should be rejected.
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