European Association of Fish Producers Organisations

European Association of Fish Producers Organisations

European Association of Fish Producers Organisations

Association Européenne des Organisations de Producteurs dans le Secteur de la Pêche


Position Paper for the Meeting with Commission Representatives in Brussels on 23 April 2009

Review of COM 104/2000 (Common Organisation of the Market Regulation)

  1. General

An updated and renewed COM 104/2000 is of vital importance for EAPO and its members. EAPO has carried out its own thorough review of the regulation, highlighted a number of concerns it has with the review process and put forward a number of recommendations.

The Commission has indicated that the review process and a revised regulation should be completed by 2011. However, taking into account the slow progress to date and the fact that European Parliament elections are due this year, EAPO is very concerned with the timing in which a revised regulation will be in place. Given the importance of this document to EAPO, it is requesting that the Commission acts to ensure that the process is accelerated and that at the latest the new regulation is in place at the start of 2010. The market situation has deteriorated significantly over the last year and there is now an urgent need to made changes to the COM. The existing regulation is failing to meet one of its key objectives to stabilise prices and guarantee a minimum income to producers. EAPO is requesting as an urgent interim time limited measure in advance of the full review that the existing regulation 104/2000 is amended to address this situation as outlined in number 2 below.

EAPO requests that the suggested amendments that EAPO has already submitted to the Commission on COM 104/2000 and associated regulations be given due recognition by the Commission and that the Commission fully engage with EAPO on a detailed discussion on these.Almost four years ago in July 2005, EAPO has outlined the six main objectives for the review:

  1. Ensure that the continuation of market support mechanisms is the basis of the COM.
  2. Address the need for simplification.
  3. Extend the markets support mechanisms, withdrawals and carry-over aids to all species.
  4. Maintain the structure allowing Producer Organisations to establish autonomous prices for certain species.
  5. Improve funding for Producer Organisations to enable the implementation of Operational Programmes and to promote proactive initiatives in marketing and quality control.
  6. Only grant fully third country access to European Markets in return for access to resources for European fishermen.

EAPO has suggested to the Commission on a number of occasions over the last twenty four months to organize a workshop on the subject for all EU PO’s. We understood that the Commission was favourably disposed to this idea, but we still look for a clear initiative in this respect

To accelerate the process it seems to EAPO that additional staff resources should be assigned to this large task, particularly as the process involves several consultancy reports not to mention the drafting of a new regulation.

  1. Proposed Amendments to Common Organisation of the Market Regulation in Light of the Collapse of Prices

The following is a list of amendments to the market regulation which if implemented immediately would significantly increase the price obtained by the fishermen and reverse the downward trend in prices. Some of these amendments are of the short-term nature to try to address the lack of control of the markets.

Regulation 104/2000


Article 18 (1)

Change to provide for interim guide price changes in order to increase the guide price immediately.

Article 18

Provide for emergency measures to be taken during the year on guide prices where prices have dramatically decreased.

Article 18 (2)

Insert new indent providing for a guide price change which takes into account major fluctuations in fuel prices.


Article 21. 3. (a)

As a temporary measure in light of the current crisis, amend to allow for a financial compensation to be equal to 100% of the withdrawal price applied for quantities not exceeding 20% of annual quantities put up for sale.

Article 21. 6.

Delete the last line, “plus an amount equal to 10% of the withdrawal price applied by that organisation”


Article 23. 3.

Increase the percentage allowable from 18% to 20% of the quantities put up for sale.


Article 24. 3.

The amount of flat-rate aid shall be equal to 100% of the autonomous withdrawal price.

Article 24. 5.

The quantities eligible for flat-rate aid pursuant to paragraph 2 may not exceed 20% of the annual quantities put up for sale.

The quantities eligible for flat-rate aid under paragraph 2 and 4 may not together exceed 40% of the annual quantities put up for sale.


Article 10. 2. (a)

a) for Annex I and IV species, an amount in proportion to the number of member vessels, calculated digressively in accordance with the method set out in Annex IVA and a flat-rate amount of EUR 1000 per species covered by Article 9(l)(b), first indent, up to 10 species in all.

The figures in Annex VII A should be doubled.

b) funding needs to be made available for any marketing and quality initiatives or management measures implemented by the producer organisation under the operational programme.

REFERENCE PRICES (This relates to Imports & Tariffs)

Article 29. 3. (a) and (b)

The withdrawal price and selling price referred to in Article 26. 3. (a) and (b) respectively need to be deleted and the guide price inserted in their place.


Article 25. 4.

15 % should be increased to 25 %.

Premium should be doubled.

  1. Link with Autonomous Quota and Controls on Imports

The EAPO has responded to a request for input into an ACFA written contribution on Autonomous Quota. The opinion has been expressed that this hides a general and current extensive problem. There appears to be a proposal to increase the quantities of species under quota regulations coming into the E.U. on a tariff-free basis. All over the E.U. the current first sale prices of the own production are suffering from reductions versus last year, in some cases up to 70 %. Indeed, there are examples where such prices do not even reach the level of 20 years ago. Therefore the following main points have been put forward:

  1. EAPO is very concerned that imports are having a very damaging effect on the prices Community fishermen obtain. Some whitefish (round fish and flat fish) and nephrops fish prices have reduced by almost 50% over the last twelve months.
  1. EAPO does not support any increases in the quantities of imports allowed into the Community at zero tariff rated.
  1. EAPO is of the firm view that the quantities allowed into the Community tariff- free in the period 2010 to 2012 should in no circumstances be increased. In fact the present huge drop in prices suggests that these quantities should be reduced.
  1. An issue of vital importance to EAPO is the control on imports. For the meeting with the Commission today, on the reform of the COM, EAPO will again address the controls on imports and the need for immediate changes in the COM in this respect. EAPO is of the firm view that a level playing field does not exist with regards to environment including carbon footprint, hygiene, quality, and labour conditions that Community producers have to adhere to as against certain exporting third countries.

23 April 2009