EU Regulation 2023/2842 — Revised Fisheries Control Framework (IUU / CATCH / REM)

Mechanism

Regulation (EU) 2023/2842 entered into force on 9 January 2024 (20 days after OJ publication) but most operative provisions apply from 10 January 2026, with the final phase (universal electronic reporting for small-scale vessels) from 10 January 2028. The regulation amends six existing EU legal instruments simultaneously:

CATCH electronic catch-certification system

From 10 January 2026, the CATCH IT platform is the mandatory channel for all EU importers and Member State competent authorities to submit, validate, and endorse catch certificates for wild-capture marine fishery products entering the EU. Paper certificates validated before 10 January 2026 remain accepted until 10 January 2028 (transition window for third-country exporters with legacy workflows). CATCH effectively makes the EU the world's first major seafood market to require end-to-end digital catch documentation as a condition of market access — a structural compliance-cost uplift for all non-EU flag-state exporters.

Vessel monitoring and surveillance upgrades

The regulation introduces a three-tier vessel coverage expansion:

1. VMS (Vessel Monitoring System): Now mandatory for EU vessels ≥12 m (previously ≥15 m). Vessels under 12 m are exempted from VMS hardware but must carry a simpler localisation and identification device.

2. Remote Electronic Monitoring (REM) / CCTV: Mandatory for high-risk EU vessels ≥18 m operating under high discard-risk fisheries. REM combines CCTV cameras, sensors (catch detection, weight estimation), and software to verify compliance with the landing obligation — closing the monitoring gap that sustained systematic misreporting.

3. Electronic Reporting System (ERS) — universal by 2028: All EU fishing vessels must report catches electronically by 10 January 2028. Vessels under 12 m may use mobile apps as a lighter-weight reporting pathway.

IUU carding regime — tighter flag-state enforcement

Amendments to Reg (EC) No 1005/2008 (IUU Regulation) establish a more structured identification and escalation process for non-cooperating third countries:

• Red-card identification (Commission Implementing Decision) → confirmed by **Council

Implementing Decision** → triggers total prohibition on import of fishery products from red-carded flag-state vessels and bars EU vessels / operators from that flag state

• Yellow-card pre-identification opens a formal dialogue and remediation window before

red-card escalation

• Decisions under the amended IUU Regulation are now directly cross-referenced: the Cameroon

red card (Commission Implementing Decision 2023/97 + Council Decision 2023/405) and the Senegal yellow card (Commission Decision C/2024/3277) are operative under the IUU Reg as amended by this regulation

Downstream implications

• All non-EU seafood exporters — Norway, Iceland, Morocco, Senegal, Viet Nam, Thailand,

Indonesia, Ecuador, Chile, Peru, Philippines, South Korea, Faroe Islands, Greenland — must integrate with the CATCH IT system or lose EU market access from 10 January 2026

• EU seafood importers / traders face a hard transition from paper catch certificates to

CATCH electronic submissions; legacy paper documents are valid only until 10 January 2028

• Flag states with IUU compliance deficits now face a cleaner escalation pathway: yellow

card → red card → full import ban. The EU seafood import market (~EUR 24 bn/year) is the world's largest; exclusion is a high-magnitude commercial threat for DWF-dependent exporters

• EU vessels ≥18 m in high-risk fisheries face REM/CCTV installation costs; fishing

sector lobbying to narrow the scope will likely continue through delegated acts

• Small-scale EU inshore fleets gain a mobile-app reporting alternative (from 2028),

reducing compliance burden relative to original proposals

Open questions

• Delegated acts specifying the list of "high-risk" fisheries triggering mandatory REM/CCTV

have not yet been finalised — scope and timing subject to Commission secondary legislation

• CATCH system readiness: third-country exporting administrations must build API integrations;

risk of last-minute delays or partial go-live on 10 January 2026

• EU-Senegal SFPA protocol non-renewal (expired Nov 2024) creates legal uncertainty about

catch-certificate validation for Senegalese-flagged vessels in the interim period

• Whether EU Council will extend the 2028 full-ERS deadline for small-scale fleets, as

lobbied by several Mediterranean member states