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EAPO and Europêche have issued a joint letter to Commissioner Virginijus Sinkevicius regarding ATQs and the EEA

The European Association of Fish Producers Organisations (EAPO) and Europêche have written a joint letter to the Commissioner for the Environment, Oceans and Fisheries Virginijus Sinkevicius on the issue of Autonomous Tariff Quotas and European Economic Area.

The fisheries organisations outline to the Commissioner that the setting of Autonomous Tariff quotas (ATQs) must be done by finding a balance between maintaining the operational capacity of EU processing facilities and ensuring EU fish products can be marketed at their fair value.

The joint letter states:

“On the 31st of December 2023, Council Regulation (EU) 2020/1706 opening and providing for the management of autonomous Union tariff quotas for certain fishery products for the 2021–2023 period will end. Early 2023, the Commission initiated the review process to update the regulation for the 2024-2025 period by publishing a first proposal that was amended by the Spanish presidency of the Council in October 2023.

Firstly, EAPO (European Association of fish Producer Organizations) and Europêche understand the need for the processing industry to have rational tariff derogations. Considering that imports also play a role in the good functioning of the EU fishing ports and services, ATQs (autonomous tariff quotas) are indeed important for a healthy processing industry in the EU and to assist in meeting the demand for seafood products not sufficiently produced in Europe.

The latest presidency compromise is closer to the sector’s views when it comes to tariff free fish imports. Keeping the recent unlawful invasion of Ukraine in mind, EAPO and Europêche welcome the provisions to ensure that no Russian or Belarusian fish is imported in the EU tariff free. The Russian federation is an important supplier of Alaskan pollack, cod and haddock. The ban of trade preferences for these products should give the processing sector access to compensatory ATQs. However, ATQs must be adapted to the newly included provision to deny duty-free treatment to products originating from the Russian federation and Belarus, even if these products are further processed in other non-EU countries such as Norway or China. Keeping a 340 000 ATQ for Alaskan pollack when 70% of previously imported pollack originated from Russia is an open call to keep importing Russian products via a back door.

On a second note, EAPO and Europêche welcome the Council and Commission position of removing herring from the list of ATQs. Norway being the main beneficiary of herring ATQs, trading market access for fishing areas access is essential to guarantee sufficient quotas for the pelagic and demersal fisheries. In the spirit of compromise, we believe that a specific provision could be included that permits the inclusion of non-processed Norwegian herring in the ATQ regulation if all parties reach an agreement on quota sharing. However, it must be ensured that the import quotas are offered to Norway for the same period as the fishing opportunities sharing arrangement. We hope that similar discussions are taking place concerning the European Economic Area.

On a third note, the Presidency’ suggestion to remove Article 7 is seen as a proof of good faith to advance to the inclusion of sustainability provisions in the ATQ regulations to come. The inclusion of sustainability provisions in the next ATQ proposals is of utmost importance for the European fishing industry. Ensuring a level playing field while requiring that all sectors play their part in tackling the climate and biodiversity crisis is key for our profitability.

The European fishing sector being one of the most regulated in the world, it is only right that fishers can earn a livelihood without having to compete against less sustainable, lower cost imported products. Which is why EAPO and Europêche members see the increase of flatfish ATQs, iconic species for Belgian and Dutch fishers with concern. Flatfish quotas in the EU are abundant and absolutely no shortage in raw material occurs. There is no need for extra supply to the European market and the only justification for maintaining an ATQ of 7500 tons would be the high cost of EU fish for processors.

On a final note, EAPO and Europêche would like to address the issue of tuna loins. Every year, the ATQ quota for tuna loins is exhausted on the first days of January, namely on January 4th in 2023. This massive entrance of low standards, low value raw material from South-East Asian countries [1] creates a price distortion, preventing the European fleet from selling its products in the European Union at a fair price. Likewise, the Ukrainian war is impacting the commercialisation of Pacific and Argentine hake, for which the 110 000 tons ATQ mainly benefiting (at 95%) China’s production [2], is no longer necessary.

ATQs have huge implications for fishers, allowing imported products to compete with EU products is not acceptable when it drives EU fish prices down hindering the sector’s profitability. Setting ATQs must be done by finding a balance between maintaining the operational capacity of EU processing facilities and ensuring EU fish products can be marketed at their fair value. The fishing sector would be grateful if we could arrange a meeting at your earliest convenience to further discuss ATQs and the renewal of the European Economic Area agreements. Please let us know your availability, and we will make the necessary arrangements to ensure fishing industry stakeholders can participate in the meeting.”



1 China, Indonesia, Thailand, and Vietnam benefit and receive a 98% allocation of tuna loin quotas.

2 Average 2020-2022

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