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 ‘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.