Review of Objections to RFMO Conservation and Management Measures under EU Law: Bloom v. Commission

Valentin Schatz

doi:10.1163/15718085-20261026

Review of Objections to RFMO Conservation and Management Measures under EU Law: Bloom v. Commission

Valentin Schatz^*

^*Corresponding author for this work

Junior professorship of Public Law, European Law and Public International Law, in particular Environmental Law and the Law of the Sea

Research output: Journal contributions › Journal articles › Research › peer-review

Abstract

On 23 July 2025, the Seventh Chamber of the European Union (EU) General Court rendered its judgment in Bloom v. Commission. In this case, the French non-governmental organisation Bloom sought the annulment of a European Commission decision rejecting as inadmissible a previous request of Bloom for internal review, under the EU Aarhus Regulation, of an earlier Commission decision to object to a conservation and management measure of the Indian Ocean Tuna Commission. The General Court held that decisions of the Commission to use the objection procedures of regional fisheries management organisations (RFMO s) can constitute ‘administrative acts’ subject to internal review under the Aarhus Regulation, and, by extension, are subject to (indirect) judicial review by the General Court. This case note analyses the judgment and discusses its significance for the future internal and judicial review of the legality of such decisions in other RFMO s and ocean governance institutions with a law-making competence.

Original language	English
Journal	International Journal of Marine and Coastal Law
Volume	41
Issue number	2
Pages (from-to)	472-483
Number of pages	12
ISSN	0927-3522
DOIs	https://doi.org/10.1163/15718085-20261026
Publication status	Published - 06.2026

Bibliographical note

Publisher Copyright:
© Valentin Schatz, 2026. Published with license by Koninklijke Brill BV. This work is published by Koninklijke Brill BV. Koninklijke Brill BV incorporates the imprints Brill, Brill Nijhoff, Brill Schöningh, Brill Fink, Brill mentis, Brill Wageningen Academic, Vandenhoeck & Ruprecht, Böhlau and V&R unipress. Koninklijke Brill BV reserves the right to protect the publication against unauthorized use and to authorize dissemination by means of offprints, legitimate photocopies, microform editions, reprints, translations, and secondary information sources, such as abstracting and indexing services including databases. Requests for commercial re-use, use of parts of the publication, and/or translations must be addressed to Koninklijke Brill BV.

UN SDGs

This output contributes to the following UN Sustainable Development Goals (SDGs)

SDG 14 Life Below Water

Research areas and keywords

Politics
Commission
Annulment
Principle of legality
Judicial review
European union
Subject (documents)
Fisheries management
Law
Aarhus Regulation
conservation and management measures (CMMs)
Court of Justice of the European Union (CJEU)
internal and judicial review
objection procedures
regional fisheries management organisations (RFMOs)

ASJC Scopus Subject Areas

Oceanography
Geography, Planning and Development
General Environmental Science
Management, Monitoring, Policy and Law
Law
Environmental Science(all)

Access to Document

10.1163/15718085-20261026

Cite this

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title = "Review of Objections to RFMO Conservation and Management Measures under EU Law: Bloom v. Commission",

abstract = "On 23 July 2025, the Seventh Chamber of the European Union (EU) General Court rendered its judgment in Bloom v. Commission. In this case, the French non-governmental organisation Bloom sought the annulment of a European Commission decision rejecting as inadmissible a previous request of Bloom for internal review, under the EU Aarhus Regulation, of an earlier Commission decision to object to a conservation and management measure of the Indian Ocean Tuna Commission. The General Court held that decisions of the Commission to use the objection procedures of regional fisheries management organisations (RFMO s) can constitute {\textquoteleft}administrative acts{\textquoteright} subject to internal review under the Aarhus Regulation, and, by extension, are subject to (indirect) judicial review by the General Court. This case note analyses the judgment and discusses its significance for the future internal and judicial review of the legality of such decisions in other RFMO s and ocean governance institutions with a law-making competence.",

keywords = "Politics, Commission, Annulment, Principle of legality, Judicial review, European union, Subject (documents), Fisheries management, Law, Aarhus Regulation, conservation and management measures (CMMs), Court of Justice of the European Union (CJEU), internal and judicial review, objection procedures, regional fisheries management organisations (RFMOs)",

author = "Valentin Schatz",

note = "Publisher Copyright: {\textcopyright} Valentin Schatz, 2026. Published with license by Koninklijke Brill BV. This work is published by Koninklijke Brill BV. Koninklijke Brill BV incorporates the imprints Brill, Brill Nijhoff, Brill Sch{\"o}ningh, Brill Fink, Brill mentis, Brill Wageningen Academic, Vandenhoeck \& Ruprecht, B{\"o}hlau and V\&R unipress. Koninklijke Brill BV reserves the right to protect the publication against unauthorized use and to authorize dissemination by means of offprints, legitimate photocopies, microform editions, reprints, translations, and secondary information sources, such as abstracting and indexing services including databases. Requests for commercial re-use, use of parts of the publication, and/or translations must be addressed to Koninklijke Brill BV.",

year = "2026",

month = jun,

doi = "10.1163/15718085-20261026",

language = "English",

volume = "41",

pages = "472--483",

journal = "International Journal of Marine and Coastal Law",

issn = "0927-3522",

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N1 - Publisher Copyright: © Valentin Schatz, 2026. Published with license by Koninklijke Brill BV. This work is published by Koninklijke Brill BV. Koninklijke Brill BV incorporates the imprints Brill, Brill Nijhoff, Brill Schöningh, Brill Fink, Brill mentis, Brill Wageningen Academic, Vandenhoeck & Ruprecht, Böhlau and V&R unipress. Koninklijke Brill BV reserves the right to protect the publication against unauthorized use and to authorize dissemination by means of offprints, legitimate photocopies, microform editions, reprints, translations, and secondary information sources, such as abstracting and indexing services including databases. Requests for commercial re-use, use of parts of the publication, and/or translations must be addressed to Koninklijke Brill BV.

PY - 2026/6

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N2 - On 23 July 2025, the Seventh Chamber of the European Union (EU) General Court rendered its judgment in Bloom v. Commission. In this case, the French non-governmental organisation Bloom sought the annulment of a European Commission decision rejecting as inadmissible a previous request of Bloom for internal review, under the EU Aarhus Regulation, of an earlier Commission decision to object to a conservation and management measure of the Indian Ocean Tuna Commission. The General Court held that decisions of the Commission to use the objection procedures of regional fisheries management organisations (RFMO s) can constitute ‘administrative acts’ subject to internal review under the Aarhus Regulation, and, by extension, are subject to (indirect) judicial review by the General Court. This case note analyses the judgment and discusses its significance for the future internal and judicial review of the legality of such decisions in other RFMO s and ocean governance institutions with a law-making competence.

AB - On 23 July 2025, the Seventh Chamber of the European Union (EU) General Court rendered its judgment in Bloom v. Commission. In this case, the French non-governmental organisation Bloom sought the annulment of a European Commission decision rejecting as inadmissible a previous request of Bloom for internal review, under the EU Aarhus Regulation, of an earlier Commission decision to object to a conservation and management measure of the Indian Ocean Tuna Commission. The General Court held that decisions of the Commission to use the objection procedures of regional fisheries management organisations (RFMO s) can constitute ‘administrative acts’ subject to internal review under the Aarhus Regulation, and, by extension, are subject to (indirect) judicial review by the General Court. This case note analyses the judgment and discusses its significance for the future internal and judicial review of the legality of such decisions in other RFMO s and ocean governance institutions with a law-making competence.

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KW - Commission

KW - Annulment

KW - Principle of legality

KW - Judicial review

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KW - Subject (documents)

KW - Fisheries management

KW - Law

KW - Aarhus Regulation

KW - conservation and management measures (CMMs)

KW - Court of Justice of the European Union (CJEU)

KW - internal and judicial review

KW - objection procedures

KW - regional fisheries management organisations (RFMOs)

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DO - 10.1163/15718085-20261026

M3 - Journal articles

AN - SCOPUS:105038010392

SN - 0927-3522

VL - 41

SP - 472

EP - 483

JO - International Journal of Marine and Coastal Law

JF - International Journal of Marine and Coastal Law

IS - 2

ER -

Review of Objections to RFMO Conservation and Management Measures under EU Law: Bloom v. Commission

Abstract

Bibliographical note

UN SDGs

Research areas and keywords

ASJC Scopus Subject Areas

Access to Document

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Cite this