Exclusive economic zone
The exclusive economic zone of France covers about 7% of the combined area of every such zone on Earth. French land, by contrast, makes up only 0.45% of the planet's dry land. That gap raises a puzzle. How can a country hold sea far larger than itself, and who agreed to let it? An exclusive economic zone, or EEZ, is a band of ocean where a coastal state controls fishing, energy production and other uses of marine resources. This documentary follows the questions the idea leaves behind. Where exactly do the lines run, and who drew them? Why do some tiny islands anchor seas larger than whole countries? And what happens when two neighbours draw circles that collide?
Between 12 and 200 nautical miles from a coastline, a state holds a special power. The 1982 United Nations Convention on the Law of the Sea grants it. Inside 12 nautical miles lies the territorial sea, where a state has full sovereignty over the water. Past that line, the law grants only what it calls a "sovereign right." The right concerns what lies in and beneath the sea. It covers energy made from water and wind. The surface waters above remain international waters.
Where two coasts sit less than 400 nautical miles apart, both 200-mile circles cannot fit. The neighbouring states must then agree on the real boundary themselves. Without an agreement, a point inside the overlap generally defaults to whichever state is nearer.
The seabed follows its own geometry. A state can hold rights to an extended continental shelf reaching 350 nautical miles from its baseline, well past the zone itself. The legal shelf is not quite the geologist's shelf, because it also takes in the continental rise and slope. Since the zone begins where the territorial sea ends, it also contains the contiguous zone. Claims to the deeper seabed go before the United Nations Commission on the Limits of the Continental Shelf.
For a long stretch of history, a country's sovereign waters ended 3 nautical miles from shore, roughly the range of a cannon shot. Today the territorial sea extends 12 nautical miles. The push to give states control over the waters beyond it gained acceptance only in the late 20th century.
The United States made one of the first assertions of exclusive jurisdiction past the traditional limit. It did so in the Truman Proclamation of the 28th of September 1945. Chile and Peru, however, were the first to claim zones of 200 nautical miles. Chilean President Gabriel Gonzalez Videla signed the Presidential Declaration Concerning Continental Shelf on the 23rd of June 1947. Peruvian President Jose Luis Bustamante y Rivero followed with Presidential Decree No. 781 on the 1st of August 1947.
A claim is not yet a rule. The 200-mile zone was formally adopted only in 1982, through the UN Convention on the Law of the Sea.
Ireland shows how the change felt on the ground. Since independence, her territorial waters had been limited to 3 nautical miles. In 1964 they were extended to 12 nautical miles, covering 41,000 square kilometres. Several European countries kept fishing rights between 6 and 12 nautical miles. In 1976 her exclusive economic zone was extended to 200 nautical miles, which raised her maritime area to 450,000 square kilometres.
The largest exclusive economic zone in the world belongs to the United States, at 11,351,000 square kilometres. It spreads across three oceans, the Gulf of Mexico and the Caribbean Sea. Alaska alone accounts for 3,770,021 square kilometres, and the northwestern Hawaiian islands for another 1,579,538. The territory-by-territory figures actually add up to about 12,234,403 square kilometres, a reminder that these totals depend on how they are counted.
Australia declared its zone on the 1st of August 1994. Its 8,148,250 square kilometres actually exceed its land territory. About 2,000,000 of that lies off the Australian Antarctic Territory. Russia's zone, the fourth largest, totals 8,095,881 square kilometres, with 3,419,202 in the Pacific and 3,277,292 off Siberia. The United Kingdom ranks fifth at 6,805,586 square kilometres, because the count includes the Crown Dependencies and the British Overseas Territories. Indonesia is sixth at 6,159,032 square kilometres, a product of its 13,466 islands. Japan is eighth at 4,479,674.
Some countries break the pattern. Canada's zone of 5,599,077 square kilometres is slightly smaller than its territorial waters. Those waters also take in inland marine waters such as Hudson Bay, about 300 nautical miles across. New Zealand's zone of 4,083,744 square kilometres is roughly fifteen times its land area. One government publication gave it as about 4,300,000.
The real surprises sit on small islands. Chile's Easter Island has 164 square kilometres of land but 720,412 of exclusive economic zone. The Desventuradas Islands add 449,836 square kilometres of sea around just 5 of land. Norway's Bouvet Island, with 49 square kilometres of land, anchors 436,004. Brazil's Trindade and Martim Vaz Islands command 468,599, and the Saint Peter and Saint Paul Archipelago 413,636. Macquarie Island gives Australia 471,837, and the Prince Edward Islands give South Africa 466,879. Portugal's zone is split into three sub-zones that do not touch, and the Azores alone account for 953,633 square kilometres.
At the small end, Germany declared its zone on the 1st of January 1995. It covers 32,982 square kilometres, about 70% of it in the North Sea. Poland's, entirely in the Baltic Sea, covers 30,533.
In April 2008, the United Nations Commission on the Limits of the Continental Shelf confirmed Australia's rights over 2.5 million more square kilometres of seabed. Australia's separate claim off its Antarctic Territory was deferred at its own request. A year later, in April 2009, the commission approved Norway's claim to another 235,000 square kilometres. It found that Norway and Russia both had valid claims over part of the shelf in the Barents Sea.
Pakistan's case ran for two decades. Its coast is 1,046 kilometres long, from Sir Creek in the east to Gwatar Bay in the west. The Pakistan Navy, working with the National Oceanographic Organization, started the case at ministerial level in 1995. On the 26th of August 2013, a seven-member sub-commission was formed to weigh the technical details. Its members came from Japan, China, Mozambique, Kenya, Denmark, Georgia and Argentina. On the 13th of March 2015 the commission accepted recommendations extending the outer limits of Pakistan's shelf to 350 nautical miles. By then 80 countries had submitted claims, and recommendations on 22 of them were finalised. Pakistan became the first country in its region to win that extension. Its zone grew from 240,000 to 290,000 square kilometres. Some of the territory overlapped Omani claims, and the verdict is believed to have followed negotiation with Oman.
Other states have sought the same reach. Portugal submitted a claim in May 2009 for an additional 2.15 million square kilometres of adjacent shelf. Chile filed partial claims in 2020 and 2022, and India is seeking to extend its zone to 350 miles.
Ireland ratified the Convention in 1996, which allowed claims out to 350 nautical miles. She claimed the Porcupine Abyssal Plain in 2005 and was awarded it in 2007, adding 39,000 square kilometres of seabed. Her claim to the Celtic Sea and the Bay of Biscay, filed in 2006, is still under discussion with France, Spain and the United Kingdom.
Fisheries management, usually following guidelines from the Food and Agriculture Organization, gives states a practical way to control an exclusive economic zone. Its central idea is the stock. Transboundary stocks range through the zones of at least two countries. Straddling stocks range both inside a zone and out on the high seas. A single stock can be both.
Norway shows how fishing and sea boundaries can diverge. Its exclusive economic zone is 819,620 square kilometres, yet its fishing zone is 1,878,953. The fishing zone includes waters around Svalbard and Jan Mayen.
Croatia's story shows how a fishing zone can become a diplomatic problem. In 2003 it proclaimed an Ecological and Fisheries Protection Zone, known as ZERP, in the Adriatic Sea. It caused friction with Italy and Slovenia and created problems during Croatia's accession to the European Union. The zone was not enforced against EU states, especially Italy and Slovenia. In 2021 it was upgraded to a full exclusive economic zone, together with Italy and Slovenia.
The Cod Wars between the United Kingdom and Iceland flared on and off over many decades. A final agreement ended them in 1976.
In 1992, an arbitral tribunal ruled on the Canada-France Maritime Boundary Case. The case centred on the waters around the French islands of Saint Pierre and Miquelon. The tribunal agreed with Canada's arguments on the whole. France was awarded 18% of the area it had originally claimed.
Seven years later, after the Hanish Islands conflict, the Permanent Court of Arbitration set the zones of Yemen and Eritrea. It ruled that they should be divided equidistantly between the two mainlands, without regard to who held sovereignty over the islands.
In 2009, the UN International Court of Justice faced a dispute between Romania and Ukraine over Snake Island. The court decided that the island has no exclusive economic zone beyond 12 nautical miles of its own land.
The year 2010 brought two agreements. Israel and Cyprus signed one in Nicosia, fixing the limit at the maritime halfway point. Israeli Infrastructure Minister Uzi Landau and Cypriot Foreign Minister Markos Kyprianou signed it to safeguard rights to oil and gas reservoirs under the sea. The two countries also agreed to cooperate on any cross-border resources found. Norway and Russia, meanwhile, settled a dispute over waters around the Svalbard archipelago, whose unique treaty status affected Russia's zone. A treaty was agreed in principle in April 2010, then ratified. It was signed in Murmansk on the 15th of September 2010.
In 2014, the Netherlands and Germany resolved an old argument over the exact border in Dollart Bay. Portugal and Spain followed a quieter path. Spain had argued that the southern edge of Portugal's zone should sit halfway between Madeira and the Canary Islands. Portugal exercises sovereignty over the Savage Islands north of the Canaries, and claimed a border further south. Since 2015, Spain has stopped disputing the Portuguese claim.
A wedge of the Beaufort Sea, reportedly rich in oil, is claimed by both Canada and the United States. Further south, the uninhabitable rock of Rockall sits in the zone of the United Kingdom. Denmark, Iceland, Ireland and the United Kingdom all compete for the continental shelf nearby. Since Brexit the United Kingdom has claimed a 12 nautical mile exclusion zone around the rock, which Ireland does not recognise.
In 1996, the Dominican Republic and the United Kingdom signed a boundary agreement for the Turks and Caicos. It put Mouchoir Bank on the Turks and Caicos side and Silver and Navidad Banks on the Dominican side. Neither party ratified it. In 2007 the Dominican Republic declared itself an archipelagic state and claimed Mouchoir Bank, and the United Kingdom does not accept that status. The same declaration pressed on the line shared with Puerto Rico, which the United States also rejects. The boundary expert Victor Prescott argued that an equidistance line suits two states with short coastlines and few offshore islands.
Mauritius claims a zone of 2.3 million square kilometres. That includes Tromelin Island, which it contests with France, and the British Indian Ocean Territory, which it contests with the United Kingdom. The United Kingdom's own list of disputes also includes Argentina over the Falkland Islands and South Georgia, and Spain over Gibraltar.
In the Pacific, the South China Sea is the setting for several ongoing disputes among China, Taiwan, Vietnam, the Philippines, Indonesia, Malaysia and Brunei. Vietnam's main quarrel is with the People's Republic of China over the nine-dash line. Japan claims a zone around Okinotorishima, but China, Taiwan and South Korea call it an islet that cannot generate one. North Korea declared its zone in 1977, after contesting the Northern Limit Lines drawn following the Korean War. It has never specified its coordinates. Only its border with Russia has been determined, the single such border in East Asia.
The Mediterranean holds some of the tightest tangles. Turkey holds that no island, Cyprus included, can have a full zone, and that each is entitled only to 12 nautical miles. The Turkish Republic of Northern Cyprus, recognised only by Turkey, also claims part of Cyprus's waters. Turkey is one of few countries not to have signed the Convention. Greece calls the maritime deal between Libya's GNA government and Turkey illegal, and signed a counter agreement with Egypt. Lebanon says the agreement between Cyprus and Israel overlaps its own zone.
Algeria added a new dispute on the 17th of April 2018, when Presidential Decree No. 18-96 established its zone. Spain's mission to the United Nations objected on the 27th of July 2018, and Italy's followed on the 28th of November 2018. Both said Algeria had acted unilaterally without consulting them. Algeria replied on the 25th of November 2018 that it did not recognise the coordinates in Spain's Royal Decree 236/2013. It argued that Spain's delimitation ignored the special circumstances of a sea where coasts face each other, citing article 74 of the Convention. Another Algerian communication, dated the 20th of June 2019, went to the Italian and Spanish embassies in Algiers.
Updated
Common questions
How far does an exclusive economic zone extend?
It stretches from the outer edge of the territorial sea at 12 nautical miles out to 200 nautical miles from the coast, as set by the 1982 United Nations Convention on the Law of the Sea.
What is the difference between the territorial sea and the exclusive economic zone?
The territorial sea gives a state full sovereignty over the water. In the exclusive economic zone a state holds only a sovereign right over the resources in and beneath the sea, and the surface waters remain international waters.
What happens when two countries' zones overlap?
When coastal baselines are less than 400 nautical miles apart, the states must agree on the boundary themselves. Without an agreement, a point in the overlap generally defaults to the nearest state.
Who first claimed a 200 nautical mile zone?
Chile and Peru did, in 1947. Chile's declaration was signed on the 23rd of June and Peru's decree on the 1st of August. The zone was formally adopted in 1982.
Can a state claim seabed beyond 200 nautical miles?
Yes. A state can hold rights to an extended continental shelf up to 350 nautical miles from its baseline. Claims go before the United Nations Commission on the Limits of the Continental Shelf.
What is the difference between transboundary and straddling fish stocks?
Transboundary stocks range through the zones of at least two countries. Straddling stocks range both inside a zone and on the high seas. A stock can be both.
All sources
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