Memorandum by The Institute for European
Environmental Policy
INTRODUCTION
The Institute for European Environmental Policy
(IEEP) has established itself as an independent and effective
centre of new thinking and, increasingly, a key player in the
area of fisheries and the environment in the UK and Europe. IEEP
has a long track record of working on a coherent set of initiatives
on detailed areas such as subsidies, indicators and inshore fisheries
management and made significant contributions to the major review
of the Common Fisheries Policy (CFP) in 2002.
IEEP policy researchers includes economists,
political scientists, lawyers and natural scientists and, by consistently
focusing on the core policies actually or likely to affect UK
and EU fisheries, IEEP has plugged a major gap in the policy debate,
strongly complementing the work of other actors. IEEP has also
played a key role in guiding the European Commission, NGOs and
national policy-makers on various aspects of fisheries policy
during the 2002 Reform. We thank you for this opportunity to provide
evidence for this critical inquiry on the performance of the CFP
over the last five years.
GENERAL COMMENTS
The Common Fisheries Policy (CFP) provides the
framework for fisheries management in the EU. Indeed, Member States
can only act to conserve fish stocks if they are given express
powers to do so under the CFP. Securing sustainable fisheries
at national or local level in any of the Member States therefore
depends on getting the EU policy framework right, as well as ensuring
its correct implementation on the ground or at sea.
Prior to 2002, the CFP was criticised for mismanaging
the fisheries sector and forcing fishermen to overfish,
leading to irreversible damage to stocks of major economic importance,
as well as to invaluable marine ecosystems. During the reform
of the CFP in 2002, policy actors were forced to contemplate the
changes required to address the alarming state of EU fish stocks
and new measures to change fisheries management. A new approach
to management of EU fisheries was reflected in the 2002 CFP reform
and the new Basic Regulation adopted by the European Commission
in December 2002.
At the end of December 2002, the Council agreed
to an important package of reforms to the CFP. These were primarily
legislative changes to the conservation and structural policies.
They reflected:
1. a move towards a more long-term approach
to fisheries management. The revised CFP should lead to a shift
away from annual decision-making on Total Allowable Catches (TACs),
to multi-annual planning;
2. a commitment to the progressive implementation
of the ecosystem approach to management;
3. a new fleet policy to limit and gradually
reduce over-capacity. Members States are given more responsibility
to match capacity with fishing possibilities, while vessels' renewal
and modernisation subsidies are phased out;
4. a better application of the rules. This
is to be achieved through an increased co-operation between national
authorities and a more uniform control and sanction system throughout
the EU; and
5. improved governance. The aim is to involve
stakeholders more closely into the policy making process. This
is to be achieved through the setting up of Regional Advisory
Councils (RACs).
The 2002 deal was significant, but in many ways
just marked the beginning of a longer term reform process. The
new CFP framework Regulation sets out the objectives, principles
and instruments to support EU fisheries management in the 21st
century. However, real change on the ground or at sea required
the subsequent adoption and successful implementation of detailed
"daughter" legislation.
Five years after the 2002 reform agreement,
it is time to judge whether the new CFP has been transformed from
paper to practice. The European Commission made some efforts to
implement the reform agenda, by developing its ideas on various
aspects of management, from inspection and enforcement, to scientific
issues. It also came forward with a series of important legislative
proposals, covering recovery plans, cetacean by catch, regional
advisory councils and deep sea fisheries. A more in-depth analysis
of progress is provided below under the various elements of the
CFP.
SPECIFIC COMMENTS
Conservation Policy
The cornerstone of EU fisheries management fisheries
management in the North East Atlantic and the Baltic Sea has traditionally
been the TACs and national quotas. The TAC system has several
advantages—it is relatively simple and it has built-in subsidiarity,
allowing Member States to decide how quotas are distributed among
their fleets. Nevertheless, it is rather a crude management tool
and not sufficient to conserve European fish stocks and the system
of TACs was heavily criticised during the 2002 reform. Despite
its shortcomings, TACs and quotas were retained as a key management
measure post 2002. In addressing some of these shortcomings, the
European Commission and ICES have placed increasing emphasis on
the precautionary approach in proposing TAC levels. The calendar
for setting the annual TACs was brought forward, in 2006, to allow
enough time for stakeholder consultations prior to the drafting
of legislative proposals and decisions. Through improving the
basis for TACs and increasing and transparency it is hoped that
the year on year fluctuations and deviations from scientific advice,
which happens on an annual basis, will be reduced. In addition
to these modifications to the establishment of TACs, the Commission
has also adopted a longer term approach to management which should
lead to better conservation of stocks in the long term.
A longer-term approach: the use of multi-annual plans
and recovery plans
The reform of the CFP in 2002 had a clear ambition
to adopt a longer-term approach to fisheries management. Consequently,
two types of multi-annual plans have been developed as crucial
components of this approach: management plans and recovery plans.
Management plans are implemented to maintain stocks at safe biological
levels (above limit spawning biomass) before stocks reach a critical
level. However, certain fish stocks are already in a dangerously
depleted state and, in these cases, recovery plans are developed
and implemented as a means to halt and ultimately reverse further
decline. During the years following the CFP reform, the Council
has largely acted on implementing those multi-annual plan although
it has also adopted a series of management plans and species recovery
plans since 2004: North Sea cod, Northern hake, Southern hake
and Norway lobster stocks recovery plans, as well as Bay of Biscay
sole multi-annual plan; and more recently the long awaited recovery
plans for European eels and the Baltic Sea cod to enter into force
this year.
The implementation of recovery plans in Europe
has been a fairly new development. It is too early to evaluate
the effectiveness of these plans and their associated measures
although stakeholders and decision-makers have begun to comment
and proceed with preliminary evaluations and there are indications
that most of these plans have failed. The lack of success in these
cases has been attributed to a number of factors including:
— The lack of stakeholder participation
in the plan drafting, implemention or monitoring.
— The lack of progressive reduction
in fishing mortality to complement other measures in the plan.
— Ill-defined recovery process (eg
unclear harvest control rules); unclear references and target
points, as well as the lack of precise timeframes for subsequent
action.
— The lack of socio-economic data to
ensure efficient management options were used for recovery planning.
— The lack of data on the social impacts
of existing recovery plans.
— Ineffective Monitoring, Control and
Surveillance measures (MCS) to ensure compliance with the measures
in the plans.
Regardless of these shortcomings, it may be
too early to draw conclusions on the success or failure of the
recovery plans in Europe. Importantly, there are claims that the
slow recovery of biomass (a key objective of the recovery plans)
is not necessarily due to overfishing and excess of fishing capacity.
Environmental conditions may also be affecting recruitments and
further slowing down the recovery of some of these stocks. Further
studies are needed to evaluate the impact of other environmental
factors during the period of the recovery plans. A thorough evaluation
of the recovery plans would therefore require more time and more
accurate data in order to reach a conclusion.
Technical Measures
Fisheries in EU waters and by EU vessels in
international waters are covered by different technical measures
regulations, one for each of the areas of the Mediterranean (Council
Regulation 1626/1994), the North Sea (including Kattegat and Skagerrak)
and the Atlantic (Council Regulation 850/1998), the Baltic Sea
(Council Regulation 88/1998) and the Antarctic (Regulation 600/2004).
The current Regulation for the North Sea (Council Regulation 850/1998)
which came into effect in 2000 and the rules were simplified and
adapted to the current needs of the industry to promote conservation
of fish stocks.
In 2004, the Commission set out its plans for
improving technical measures in its Communication, COM(2004) 438.
In this Communication, the Commission presented a set of actions
and timelines which included:
— A review of current technical measures
Regulations;
— A reduction of discards;
— Research in support of environmentally
fishing methods through the 6th Framework Programme of Research;
and
— Proposals for new financial incentives.
By 2007, the Commission has progressed on all
four proposals. In relation to technical Regulations, the North
East Atlantic Regulation was revised in 2004. A further revision
of this Regulation and those for the Baltic and the Mediterranean
are currently underway. In relation to discards, the Commission
funded a pilot project to address the problem of ghost fishing
in Community waters. IEEP was involved in this project which contributed
to the Commissions final decision on ghost fishing.
The need to address by-catch and discards was
identified by the Commission as an important objective during
the reform of the CFP in 2002. In 2003, the Fisheries Council
adopted conclusions inviting the Commission to explore ways to
resolve the problem. However, very few projects have materialised
and demonstrated good results and by-catch and discards still
remain a problem for most fisheries. On 28 March 2007, the Commission
adopted a Communication to the Council and the Parliament on a
policy to reduce by-catch and discards in European Fisheries (COM(2007)136).
In this Communication the Commission presents issues for discussion
and outlines the policy approach to reduce unwanted by-catch and
progressively eliminate discard based on an internal working paper
on preliminary impact assessment of three policy options. The
first option—to take no specific actions but to continue
fisheries management as it currently stands. The second—to
take supplementary direct measures and adapt CFP instruments including
real time closures and selective fishing gear and the third option—to
a) implement a discard ban as a stand-alone option or b) to implement
a discard ban, supplemented with additional measures. The European
Commission is planning to propose a new Regulation on discards
in May 2007, based on further analysis of the various options.
IEEP has been assisting the Commission with the analysis. Further
analysis of the options available to the Commission indicates
that there may different approaches to different fisheries depending
on the levels of discarding and the social, economic and environmental
impacts. In addition, due to the complex nature of EU fisheries,
there is no one-size-fits-all solution to the discard problem
and the European Commission will need to look very closely at
the environmental benefits of various options versus the social
and economic costs.
The EFF Regulation[1],
adopted in 2006 provides financial incentives for the promotion
and use of environmentally-friendly fishing, including the development
and use of more selective gears while compensating for short term
losses for vessels participating in trials of more environmentally-friendly
fishing methods (Axis 1 and Axis 3). The allocation of funds to
these axes and activities should included in the National Operational
Programmes (NOPs) currently being prepared by Member States. Not
all Member States have completed this process and therefore it
is too early to judge whether the new EFF will result in the use
of more environmentally-friendly fishing gear (see below).
Structural Policy
Regulation 1198/2006[2]
establishes the European Fisheries Fund (EFF), the structural
policy for fishing activities for the period 2007-13, succeeding
the 2000-06 Financial Instruments for Fisheries Guidance (FIFG).
Unlike its predecessor, the EFF is no longer a structural fund.
Although funding is still allocated using multi-annual programming,
the EFF includes more responsibility to Member States with the
development of national strategic plans and operational programmes.
Also, measures available for funding fall under five priority
axes clearly defining the range of actions to undertake:
— Adaptation of the Community fishing
fleet.
— Aquaculture, inland fishing, processing
and marketing.
— Promoting collective interest.
— Sustainable development of fishing
areas.
— Technical assistance to facilitate
the delivery of assistance.
The objectives of the EFF remain slightly similar
to those of the FIFG, although they are certainly "greener"
and more in line with the objectives of the 2002 CFP reform. Funding
for an increase in fishing capacity of any sort is strictly ruled
out. The EFF also provides more room for measures contributing
to more environmental integration and stakeholders' participation.
The EFF is also more devolved to socioeconomic issues and the
integration of the fishing economy into national economies. This
is shown by the opportunities for funding retraining and alternative
job opportunities. The EFF also aims at providing specific help
to less favoured and remote fishing areas within the EU, by means
of differential funding between "convergence" and "non-convergence"
regions.
The EFF therefore marks a further step towards
funding of sustainable fishing activities. However, at the beginning
of 2008 the EFF is still at its early stage of implementation
with the adoption of 19 of the 27 operational programmes, and
some uncertainties remain about the uptake by Member States of
measures consistent with the objectives defined by the European
policy. The early stages of the EFF implementation process have
already highlighted some dissimilarity among Member States regarding
the consultation of stakeholders and the integration of environmental
objectives (eg financing Natura 2000).
As the breakdown of national budgets by priority
axis has been published recently, it is possible to get an overview
of Member States' priorities. The EU-15 are more prone to allocate
to traditional funding (ie capacity adjustment) while new Member
States dedicate a large part of their budget to axis 4 "sustainable
development of fishing areas" (up to 23% for Latvia and Estonia
and 33% for Romania). This is likely to create more opportunities
for funding new "conservation type projects" in new
Member States, whereas old Member States will stick to their "business-as-usual"
funding. However, it is recommended to be careful about the uptake
of axis 4 funding, measures are ranging from regeneration of coastal
communities to environmental protection and eco-tourism. Hence,
if not correctly assessed, the important proportion given to "new"
measures could be used rather for preserving social fabrics than
helping the fishing economy and funding vital measures linked
with safety onboard, increasing competitiveness of the fleet,
developing marketing and distribution of fish and fish products,
etc.
Monitoring and evaluation of the EFF is based
on a close exchange between the Commission and Member States,
which had to produce ex ante programme evaluations when submitting
their operational programmes. Moreover, once the EFF is in operation,
Member States will have to produce annual progress reports about
the uptake of the EFF budget. The structural policy therefore
appears to be effectively monitored and evaluated throughout the
process, but efforts will be required from Member States to report
correctly to the Commission and vice versa.
The CFP structural policy seems to have no long-term
planning and appears to be quite unenthusiastic to review what
has been achieved so far. The ex-post evaluation of the 2000-06
FIFG is still pending and is not likely to be conducted before
the end of 2009 or 2010. Meanwhile, the Commission is planning
a mid-term review of the EFF at the latest by mid-2011. This will
be a strategic period for the Commission to assess its past, current
and future structural policy. It is important that the FIFG's
ex-post evaluation feed the review of the EFF and allow for a
forward-thinking strategy for the upcoming fund after 2013.
The EFF surely provides a promising perspective
to the CFP, but a lot still remains to achieve a well-balanced
and sustainable fisheries sector and the overall CFP structural
policy has to keep in line with these recent progresses by going
three steps forward and two steps back. Indeed, the de minimis
aid approved mid-2007, by increasing the state aid ceiling from
3,000 to 30,000 euros has opened the back door for further cost-reducing
subsidies (eg fuel subsidies) while the Commission is claiming
that the solution is not to give subsidies to meet part of the
increased costs due to ongoing external pressure (eg rising fuel
costs). The policy is bound to be radically different from 2013
onwards. Subsidies to the fishing sector will have to be phased
out, according to the global context and recent WTO outcomes.
This leads to further uncertainties about long-term sustainability
of the European fisheries sector.
Governance
One of the most concrete actions taken by the
Commission to date on implementing a new approach to EU fisheries
governance under CFP since 2002 is the establishments of the RACs.
There are plans for seven RACs:
— The Baltic Sea RAC (operational in
March 2006);
— The North Sea RAC (operational in
November 2004);
— The Mediterranean Sea RAC (in the
process of being established);
— The North-western waters RAC (operational
since September 2005);
— The South-western waters RAC (operational
since April 2007);
— The Pelagic Stocks RAC (operational
since August 2005); and
— The Distant water fisheries RAC (operational
since March 2007).
RACs were originally intended to primarily provide
advice to the Commission and national fisheries managers on management
issues including development and implementation of the ecosystem
approach. RACs were meant to support resource management, including
progressive implementation of the ecosystem-based approach. They
should aim to do so, taking full consideration of existing EU
legislation regarding environmental and other issues. Despite
their lack of legal "teeth", RACs should be influential
if their advice were allowed to drive the decision-making process.
It is for this reason that industry and non-governmental groups
have taken a close interest in their evolution and functioning.
It is too early to judge the influence of the
RACs but their influence on decision-making is growing. In recognition
of their contribution to the development of the CFP, the Council
recently agreed to continue funding RACs beyond the period originally
agreed. Initially, it was intended that RACs would benefit from
start-up aid which would last the first five years. The Council
has now agreed that TACS will receive permanent funding of €250,000
every year in order to continue their activities. The wider role
of the RACs within the new European Maritime Policy is unclear
but it is evident that they need to be involved and can continue
to play a key role in promoting sustainable management on a regional
scale.
Control and enforcement
In October 2007, the Commission made a proposal
for a Council Regulation establishing a Community system to prevent,
deter and eliminate illegal, unreported and unregulated (IUU)
fishing. The aim of this proposal is to ban imports into the EU
of fisheries products caught illegally. The proposal lays out
two sets of rules. Firstly, it proposes rules to deal with illegal
landings by EU vessels and secondly, it proposes actions against
foreign-flagged vessels which are involved in IUU fishing activities.
In the previous strategy, the EU focussed on improving monitoring,
control and surveillance (MCS) at sea and identifying IUU fishing
operations. However, the new proposal aims to extend the framework
to the rest of the supply chain and improve its effectiveness
using trade measures.
Specifically, the EU seeks to address all fishing
and related activities linked to IUU practices. This includes
transhipments, processing, harvesting and landing. The inclusion
of the trade dimension is very important and is based on the recognition
that the EU is the biggest market and lead importer of fisheries
products—recent assessments have shown that the volume of
illegal fisheries products imported into the EU each year amounts
to approximately 500,000 tonnes to a value of €1.1 billion.
Several new developments have come up from this
plan, including that the Commission proposes fines ranging from
€300,000 to €500,000, though it was to be defined by
Member States before. Importantly, the plan includes a catch certificate
to be filled-in by vessels. One can argue that this certificate
which requires an important set of data is likely to prevent developing
countries fishing fleets to enter the EU market. Accordingly,
this may constitute an important non-tariff barrier to the entry
of developing countries fisheries goods in the EU.
On April 2005 the Council adopted the Regulation
establishing a Community Fisheries Control Agency (CFCA). Its
main task is to achieve the effective implementation of the CFP
and to establish uniform inspections and enforcement throughout
the Community. Developing and monitoring joint deployment plans,
implemented by the Member States, will be central to achieving
these tasks. While the Agency cannot directly strengthen enforcement
measures such as penalties, it will play a key coordinating role,
which is an important step in taking forward the "post-2002"
CFP as it could significantly improve implementation and enforcement.
The preparation of Joint Deployment Plans (JDP)
is one of the CFCA's main tools for insuring effective enforcement
and equal treatment for all those involved in a particular fishery.
The criteria for a JDP is that the fish stock concerned must be
subject to a long-term recovery plan or a multi-annual management
plan and a specific control and enforcement plan has to be adopted
by the Commission. A JDP for the North Sea cod fisheries has recently
been adopted by the CFCA on July 2007. This plan comes as a complement
to the tightening of cod recovery plan enforcement that requires
Member States to develop their national control programmes and
will pool the resources from seven Member States by using inspectors,
control vessels or aircrafts to ensure effective and uniform control
of fishing activities. Two other JDP will be also put in place
next year, focusing on cod in the Baltic Sea and bluefin tuna
in the Mediterranean.
The effectiveness of the agency depends to a
large extent on the details of the "control and inspection
programmes" to be implemented, in which the Member States
plays a central role. While the CFCA is currently moving to be
based in Vigo (Spain), it is still too early to assess its effectiveness
and the commitment of Member States on the enforcement of the
CFP measures.
The release at the end of 2007 of a Court of
Auditors report on the existing system of control applicable to
the CFP[3]
has highlighted some weaknesses in the functioning of the EU's
control system at a national level. According to this document,
shortcomings have been observed on the catch registration systems,
whose data are neither complete nor reliable. Additionally, inspection
activities are ineffective and inefficient, and controls of resources
are too concentrated on inspections at sea rather than at the
time of landing. Also, the follow-up of reported infringements
does not necessarily lead to sanctions, which are in any event
recognized as non-dissuasive. Importantly, these shortcomings
are even more emphasized by the pervasive reduced profitability
of the EU fisheries sector that prompts fishing vessels to non-compliance.
The Commission has therefore decided to begin
the reform of its control process. This reform encompasses several
objectives, which aims to strengthen some key elements of the
EU system control: the capacity of the Commission; the mandate
of the CFCA; the cooperation across national authorities and with
the CFCA; the level and harmonisation of sanctions; the involvement
of stakeholders into the so-called "culture of compliance";
cost effectiveness of the control process; and the use of modern
technologies.
The plan to review the control regime in 2008
and propose a new improved Regulation signals the Commission's
commitment to addressing the shortcomings of the current regime.
However, the challenges brought by the reform of controls in the
EU fisheries sector are considerable and these need to be addressed
in earnest if the new control regime is to be successful.
EU's external policy
The bilateral fisheries partnership agreements
(FPAs) have been developed according to a Commission Communication
in 2002[4].
There have been encouraging changes in the structure and approach
of FPAs compared to former fisheries access agreements (FAs).
This is particularly true about developing partnerships with third
countries, by means of a percentage of the financial contribution
attached to the agreement to be set aside to support the sectoral
fisheries policy in the third country. This percentage ranges
from 18% for Micronesia to 100% to Ivory Coast.
Moreover, the general trend in FPAs away from
mixed agreements and towards tuna agreements is likely to offer
a more coherent exploitation of stocks and avoid conflicts between
EU and small scale third-countries fleets. FPAs are likely to
provide more revenue to the fishing sector, and hence better contribute
to the development of the third-country fisheries sector regarding
stock assessment, monitoring and control, processing and distribution,
etc.
Nonetheless, FPAs show some weaknesses in the
evaluation of impacts of the EU fleets. Ex ante evaluation
of FPAs are imprecise with regard to EU fishing effort, evaluation
of marine resources available for fishing and their valuation.
It should also better address the benefits provided to the third-countries
economies. Practically, one has to make sure that enforcement
capacities from third-countries are sufficient to prevent the
EU fleet from taking advantage of such weaknesses.
From a market perspective, FPAs are likely to
reduce third countries' trade in fish and fish products in case
of no local landings. The implementation of FPAs by the EC has
voluntarily put aside the fisheries sector from the general EU
trade policy, which is mostly based on the Economic Partnership
Agreements (EPAs). Accordingly, this can threaten the sustainability
of exports of fisheries goods to the EU.
CONCLUSIONS—ONGOING
CHALLENGES
Despite the progress towards implementing the
reformed CFP since 2002, there is still a need to transform the
new Regulation into specific legal requirements and to ensure
the successful implementation and supporting regulations. A key
area which requires further actions is "bringing fishing
effort in line with the fisheries resources". Despite long
standing fisheries management efforts, the CFP still has not managed
to balance fishing activity with fishing opportunities. Excessive
fleet capacity is a major contributing factor. This is the legacy
of many years of inadequate management, combining aid for building
new vessels, weak fleet reduction requirements, limits on landings
rather than catches and poor enforcement policies.
The challenge is still to find feasible ways
to bring fishing capacity back in line with available resources.
Rights based instruments—notably Individual Transferable
Quotas (ITQs) for fish have been strongly promoted by economists
on grounds of economic efficiency. In countries such as New Zealand,
they have been instrumental in reducing fishing effort and waste
and foster a general sense of legitimacy and ownership in the
resource management. To date several stakeholders with vested
interests in Europe have been strongly opposed to them. Within
RBM systems the most controversial aspect that emerges is the
transferability of rights. Introducing a resource price for fishing
rights may lead to the buying of rights on a large scale, therefore
concentrating ownership of quotas, geographical distribution and
fleet composition while the environmental benefits may not be
clear. The consultation on RBM is due to last 12 months after
which the Commission will then report to the Council and the European
Parliament and, if and when appropriate, make proposals or recommendations
for follow-up.
EU enlargement will continue, and with it the
EU waters will grow. Although the EU already includes all of the
European Seas, if Turkey joins the EU will become a significant
player in the Black Sea beyond what it is now with only Bulgaria
and Romania as coastal Member States. This growth, together with
the joining of Croatia, will increase the EU's role in the Mediterranean.
Management can be expected to improve in both cases, but the extent
will be limited by the fact that there will continue to be many
other countries to cooperate with in the two regions.
The growing importance of the Black and Mediterranean
Seas can be expected to deepen the trend towards regionalisation
of the CFP. Management plans and cooperation at a regional level
will become more prominent, and effective, as more countries join
the EU.
The EU Maritime Policy (MP) was adopted in 2007
and the EU Marine Strategy Directive was recently adopted by the
Council. The EU MP is aimed at ensuring better integration of
maritime policies including the CFP towards better conservation
and protection of European waters, while the MSD is reliant on
Member States achieving "good environmental status"
by 2020. Whilst these policies have the potential to add value,
by filling some gaps that the CFP is unlikely to close, there
is scepticism whether this will be the case.
The current CFP has five more years to run its
course. In the next two years, it is important that evaluation
of key sub-policies is undertaken to ensure that the CFP can be
adapted to meet the challenges after 2012.
3 March 2008
1 Council Regulation (EC) No 1198/2006 of 27 July 2006
on the European Fisheries Fund. Official Journal. 15.8.2006.
L 223/1. Back
2
Council Regulation (EC) No 1198/2006 of 27 July 2006 on the European
Fisheries Fund, OJ L 223 of 15.8.2006 Back
3
Special Report No 7/2007 pursuant to Article 248(4) second paragraph,
EC, on the control, inspection, and sanction systems relating
to the rules on conservation of Community fisheries resources.
http://eca.europa.eu/portal/pls/portal/docs/1/673627.PDF Back
4
Communication from the Commission on an integrated framework for
Fisheries Partnership Agreements with third countries COM/2002/0637
final Back
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