The Institute for European Environmental Policy (IEEP) has published a study reviewing the implementation of the EU IUU regulation. ‘Based on published and new information collected through a short survey, the study found that both the Commission and member states faced some challenges in implementing specific components of the regulations…. Our analysis of the first 18 months of implementation suggests that there are a number of areas where the EU IUU regulation is deficient.’
For example the IEEP analysis concluded that ‘the catch certification scheme as it stands is not working to prevent illegally fished products from entering the EU market as the paper certificates are open to fraud. A move towards compulsory electronic certificates may help to reduce opportunities to commit fraud. However without big efforts to inspect and validate consignments and certificates the measure will continue to be ineffective’. It also highlights that ‘greater efforts should be put into understanding and investigating these lucrative illegal trade flows and closing up the loopholes that allow them to flourish’.
On trade aspects, it also highlights that ‘A simple analysis of the impact of the regulation on imports, looking at total imports of fisheries products before and after the entry into force of the regulation, was done as part of this study. However, further analysis of global trade data is required to full understand the impact of the regulation. Trade flows between countries need to be analysed in depth to establish whether there have been any changes in movements of fish products previously imported into the EU’.
Some aspects of the methodology followed in this analysis are open to question. For example, the approach of looking at total imports of fish products before and after the entry into force of the regulation, and then trying to draw conclusions about how the IUU regulation has impacted on trade flows may need to be refined, given the variety of factors that influence fish trade flows. Moreover, undertaking an assessment of such a complex regulation only 18 months after its entry into force may only provide some indications of issues encountered during the implementation phase. A detailed evaluation is expected to follow by October 2013.