EU IUU Red Card — Cameroon identified as non-cooperating third country in fighting illegal fishing

Mechanism

IUU carding process under Regulation (EC) No 1005/2008

The EU's carding regime operates in two steps under Article 31 of the IUU Regulation:

1. Commission Implementing Decision — identifies the country as non-cooperating ("red card") and publishes the finding in the Official Journal (L series). 2. Council Implementing Decision — confirms the identification and lists the country formally among non-cooperating third countries. This second step activates the full set of import and operational prohibitions under Articles 38–39 of the IUU Regulation.

For Cameroon, the process ran:

Findings against Cameroon

The Commission identified three categories of flag-state failure:

1. Systemic reflagging without due diligence — Cameroon registered fishing vessels previously associated with IUU activities into its flag register without verifying their compliance history or demonstrating the capacity to monitor their subsequent operations. The reflagging dynamic made the Cameroonian registry a laundering mechanism for IUU vessels seeking a flag of convenience after delisting from other registries.

2. Inadequate control over vessels operating outside territorial waters — Cameroonian flag-state obligations under UNCLOS and the FAO Agreement on Port State Measures were not met: no evidence of systematic VMS coverage, no effective logbook verification, and no enforcement actions documented against vessels reported for IUU conduct.

3. Non-engagement with EU remediation dialogue — Prior to red-card issuance, the Commission conducted structured dialogue (the equivalent of a yellow-card phase, though formally the full yellow-card instrument was not applied here) and Cameroon failed to adopt corrective measures sufficient to close the identified gaps.

Trade consequences (Articles 38–39 IUU Regulation)

Upon Council confirmation on 20 February 2023:

• Import ban: EU Member States must refuse entry of any wild-capture marine fishery products

caught by vessels flying the Cameroonian flag, even where those products are accompanied by catch certificates validated by Cameroonian authorities (which are no longer considered reliable).

• Chartering and flagging ban: EU operators are prohibited from using vessels flying the

Cameroonian flag for fishing activities, including under chartering arrangements.

• Transhipment and purchasing prohibition: EU operators may not purchase or receive

transhipment of fishery products from Cameroon-flagged vessels in any waters globally.

• No joint-venture operations: EU operators may not enter into joint-venture arrangements

with Cameroon-flagged vessel operators.

Precedent significance

At the time of adoption, only two other countries had been red-carded and confirmed as non-cooperating under the IUU Regulation without subsequent removal:

• Cambodia (first red-carded 2014; delisted 2015 after reforms)
• Comoros (red-carded 2017)

Cameroon became the first West African country to receive a confirmed EU red card, and directly exposed a regional pattern: the Gulf of Guinea has historically served as a reflagging hub for IUU vessels operating under flags of convenience throughout the Atlantic. The decision raised the enforcement stakes for the entire West African flag-state cohort.

Downstream implications

• Cameroon seafood export industry — Cameroon's EU-directed seafood exports (predominantly

shrimp, tilapia, and tuna caught or flagged via Cameroonian vessels) face a hard import prohibition until the Council formally removes Cameroon from the non-cooperating list upon demonstrated corrective reform.

• Gulf of Guinea reflagging dynamic — other flag states that have received or are at risk

of EU pre-identification (yellow card) face heightened scrutiny; the Cameroon decision signals the EU's willingness to follow through from dialogue to full sanction.

• EU seafood importers with prior Cameroon exposure — must immediately verify flag-state

provenance for any seafood supply chain that may have used Cameroon-flagged vessels or transited through Cameroonian ports, and substitute supply sources or re-flag purchases.

• Regulation 2023/2842 linkage — the December 2023 recast of the EU fisheries control

framework (Regulation 2023/2842) codified and reinforced the carding architecture under which this decision operates, establishing a cleaner escalation pathway and extending IUU-control requirements to digital catch documentation (CATCH system from 2026).

Open questions

• Whether Cameroon will undertake the legislative and administrative reforms required to

achieve delisting from the non-cooperating country list — as of the filing date, no roadmap has been officially communicated.

• Long-run trade diversion: the EU import ban may accelerate Cameroon's shift toward Asian

seafood markets (China, Japan, South Korea) that apply lower IUU-compliance standards, reducing the overall effectiveness of the carding instrument.

• Interaction with the Cameroonian 2023 Mining Code (Loi 2023-014): broader context of

Cameroon's natural-resource regulatory environment and its relationship with foreign buyers / enforcement partners.