Revision of the European Maritime, Fisheries and Aquaculture Fund

ClientEarth has submitted feedback on the European Commission's plan to amend the European Maritime, Fisheries and Aquaculture Fund (EMFAF). While ClientEarth welcomes the opportunity to engage and supports the transposition of the WTO Agreement on Fisheries Subsidies, we have serious procedural and substantive concerns about the preparation process of this package.
  
This process repeats the mistakes found by the Ombudswoman earlier this year: skipping an Impact Assessment and reliance on informal stakeholder meetings bypasses the basic principles of transparent and evidence-based lawmaking. In addition, setting a short 4-week feedback window undermines democratic participation.  
 
To truly transform the EMFAF for ocean health, social justice, and climate resilience, the WTO transposition must be coupled with:

1. Preserving Safeguards & Supporting Small-Scale, Low Impact Fishers: "Simplification" must NOT mean removing safeguards or watering down conditionalities. We need dedicated, ring-fenced budgets and simplified access for small-scale, low-impact fishers.  
2. Dedicated Funding for Biodiversity: A binding 25% minimum allocation of national envelopes must be dedicated exclusively to marine restoration and protection.  
3. An holistic (Energy) Transition: Decarbonisation isn't just about swapping engines on industrial trawlers. Energy transition funds must follow strict capacity limits and prioritize low-impact, energy-efficient practices.