customs

Summary

As of 10 January 2026, the EU Catch Certification IT system (CATCH) becomes mandatory for imports of fishery products into the European Union. While CLECAT fully supports the objectives of combating Illegal, Unreported and Unregulated (IUU) fishing and strengthening traceability, the mandatory implementation of CATCH in its current form poses serious operational, legal and systemic risks for customs intermediaries, logistics service providers and EU traders.

CATCH appears to have been developed largely outside the customs policy framework, even though its implementation relies on controls at the point of importation. As observed with several recent EU sector-specific initiatives, this approach risks insufficiently reflecting the operational realities of international supply chains.

A core structural flaw lies in the assumption that third-country authorities would directly issue and validate electronic catch certificates in CATCH. As most third countries are not yet able to use the system, EU operators will be forced to manually re-enter data from paper certificates and upload scanned documents.

CLECAT considers that the current approach contradicts the EU’s stated objectives of administrative simplification and supply chain resilience.

CLECAT therefore calls for:

• a coordinated transitional phase with administrative tolerance and parallel use of paper certificates;
• the urgent implementation of a mandate/delegation function for customs intermediaries;
• technical improvements, including bulk upload functionalities, to eliminate manual data re-entry;
• stronger horizontal coordination, preferably led by DG TAXUD, for all systems enforced at import;
• systematic involvement of customs intermediaries and logistics service providers in system design and governance.

Introduction

As of 10 January 2026, the use of the EU Catch Certification IT system (CATCH), developed under the framework of the EU Illegal, Unreported and Unregulated (IUU) fishing control regime, becomes mandatory for the submission of catch certificates and related documents for imports of fishery products into the European Union. The objective of CATCH is to digitalise and centralise the management of catch certificates, strengthen controls and improve traceability. CLECAT fully supports the EU’s objectives to combat IUU fishing and recognises the importance of effective and reliable control mechanisms.

However, the mandatory go-live of CATCH in its current form raises serious operational, legal and systemic concerns for customs intermediaries and logistics service providers. Based on feedback from several CLECAT members as well as the analyses and statements of sectoral trade associations, such as Seafood Europe, it is evident that the current design and implementation of CATCH does not reflect the operational reality of international supply chains and import procedures.

A recurring structural problem in EU import-related legislation

CATCH is yet another example of an EU regulatory requirement that is formally enforced at the point of importation but has been designed outside the customs policy framework and without sufficient involvement of actors who actually manage import processes on a daily basis. While the legal obligation to ensure compliance is placed on the EU importer, the practical execution of import formalities, including the submission of data to EU authorities, is in reality carried out by customs intermediaries and logistics service providers in an estimated over 95% of all import operations.

This disconnect between legal design and operational reality is not new. CLECAT has repeatedly warned that sectoral regulations developed by services in the European Commission , when implemented at the border or at import, systematically underestimate the role of customs agents and freight forwarders and ignore established representation models. CATCH follows this unfortunate pattern, with tangible negative consequences for supply chain efficiency, legal certainty and compliance capacity.

Misunderstanding of roles in the import process

It is particularly concerning that the current CATCH framework appears to reflect a recurring and fundamental misunderstanding of how import procedures operate in practice. The inability of newly designed control systems, used to implement EU greening and other sectoral legislation at the point of import, to properly anticipate and accommodate the role of customs intermediaries is once again apparent, notably through the absence of a functional mandate or delegation mechanism. This demonstrates a lack of awareness of how import procedures are actually organised. In most cases, importers are neither structurally nor operationally equipped to perform these tasks themselves and rely almost entirely on specialised service providers.

With regard to the CATCH implementation, CLECAT members reported that in some Member States the division of control responsibilities between port authorities and customs has yet to be clearly established, leaving stakeholders uncertain about compliance expectations just days before the launch.

Manual data entry and data regression

CATCH was designed on the assumption that third-country authorities would directly create and validate electronic catch certificates within the system. In practice, the vast majority of third countries are currently unable to use CATCH. As a result, the burden of data entry has shifted almost entirely to EU operators, who are required to manually re-enter data from paper certificates and upload scanned documents.

Feedback from industry shows that the manual entry of a single, simple catch certificate can take approximately 50 minutes, while more complex certificates covering multiple vessels or fishing licences may require several hours. Data input is manual, based on paper certificates, and requires repeated upload of the same data elements, CLECAT members report. At this point, there is no clarity on whether a digital data entry option will be introduced and, if so, when, or whether a system-to-system connection is foreseen as the default option for traders.

For operators handling hundreds or thousands of certificates per month, this represents a massive and unsustainable administrative burden. Rather than delivering digitalisation benefits, CATCH in its current state leads to a clear regression, duplicating data that already exists and significantly increasing the risk of human error.

Organisational and staffing impacts

The introduction of this additional workload has been imposed without a meaningful transitional phase. Teams responsible for import operations, customs formalities and regulatory compliance are not resourced to absorb such an increase at short notice. Companies are facing immediate needs for additional staff, specialised training and internal process redesign, all within an implementation timeline that does not allow for safe and controlled adaptation.

For customs intermediaries and logistics service providers, this creates serious liability risks, as they are expected to manage complex data inputs without having been formally recognised or properly enabled within the system.

Lack of delegation functionality and disruption of established practices

A critical flaw of the current CATCH architecture is the absence of a mandate or delegation function allowing importers to formally authorise customs agents or freight forwarders to complete and submit catch certificates on their behalf. This breaks with long-standing and well-established operational practices across the EU.

As a result, importers are forced to internalise tasks that have historically and efficiently been performed by specialised intermediaries. This not only undermines operational efficiency but also creates legal uncertainty regarding responsibility and liability for data accuracy and compliance.

Risks to logistics flows, ports and supply chains

The combination of manual data entry, lack of delegation, system instability and limited user readiness creates a high risk of delays in the validation and processing of catch certificates. In the context of just-in-time logistics, limited port storage capacity and perishable goods, even small delays can have cascading effects.

These include prolonged container immobilisation at terminals, congestion at ports, disruption of delivery schedules, increased demurrage, detention and handling costs, and ultimately higher costs for EU traders and consumers. For fresh and processed seafood products, delays also pose a direct risk to product quality and food security.

Contradiction with EU simplification and digitalisation objectives

In the absence of widespread third-country uptake of CATCH, the mandatory reliance on manual data entry stands in stark contrast to the European Commission’s stated objectives of administrative simplification, burden reduction and digitalisation. Instead of facilitating trade while ensuring compliance, the current approach places disproportionate strain on EU operators and intermediaries.

Need for coordinated governance and TAXUD involvement

CLECAT has consistently called for DG TAXUD to take a stronger coordinating role where sectoral controls are performed at the point of import. Customs procedures are horizontal by nature, and any system interfacing with import declarations and border processes must be designed in close cooperation with customs authorities and the private sector actors who operate these processes.

The repeated failure to ensure such coordination not only undermines the effectiveness of individual systems like CATCH, but also cumulatively endangers supply chain security and the competitiveness of the EU logistics sector and EU traders.

CLECAT recommendations

CLECAT supports the objectives of the EU IUU framework and the move towards digitalisation. However, the mandatory implementation of CATCH in its current form is not fit for purpose. CLECAT therefore calls for:

• the introduction of a coordinated and realistic transitional phase allowing continued use of paper certificates alongside CATCH, with clear administrative tolerance;
• the urgent development of a functional mandate and delegation module enabling customs agents and freight forwarders to act on behalf of responsible operators;
• technical improvements, including bulk upload functionalities, to avoid manual re-entry of data;
• structured coordination, preferably led by DG TAXUD for all import-related IT systems developed by sectoral DGs;
• meaningful involvement of the logistics sector in the design and governance of such systems.

Without these corrective measures, CATCH risks becoming another compliance layer that undermines, rather than supports, secure, efficient and resilient EU supp