Proposal to amend the Transshipment CMM 2023-03

Explanatory Notes:

Paragraph 3
Japan inserts a foot note for “a fishing vessel”. At the TCC SWG Ops on 25 October 2023,members agreed that paragraph 12 of CMM2023-03 obligates both offloading and receiving vessels to submit advance notification for all transshipments (Paragraph 12 of meeting summary of SWG Ops on 25 October 2023). This proposed footnote intends to reflect the agreement. Also, same ambiguities can be seen not only in paragraph 12 but also in other paragraphs, so Japan proposes to have this footnote in paragraph 3.

Paragraph 10
At the TCC SWG Ops on 25 October 2023, members could not reach consensus as to what comprises transshipment records required in paragraph 10 of CMM2023-03, specifically whether a mate’s receipt should be considered as a transshipment record (Paragraph 11 of meeting summary of SWG Ops on 25 October 2023).From the inspection perspective, inspectors need to check daily activities during the trip in addition to each transshipment conducted. Transshipment Declaration is good enough to show how each transshipment activity was conducted, but is insufficient to show what other activities the fishing vessel has been engaged during the trip. For example, during a HSBI, a fishing vessel provides Transshipment Declaration on 1stJanuary and 3rdJanuary to the inspector. In that case, the inspector cannot know what the fishing vessel was doing on the rest of the days (e.g. 2ndJanuary). If the inspector can see the navigation logbook or similar documents indicating that the daily activities of the fishing vessels, the inspector can conclude that the fishing vessel was not engaged any fishing activities on the rest of the days during the trip. The documents relating to commercial transactions, such as Mate’s Receipt cannot provide such information. In the light of above, Japan is proposing to amend paragraph 10 of CMM2023-03.