Article 121(3) of the 1982 UNCLOS
Türkiye is a mainland state with a dominant uninterrupted coastline in the Eastern Mediterranean. In every important maritime decision, the mainland coast forms the primary reference line. This is not an opinion, but a consistent jurisprudence. In the North Sea Continental Shelf (ICJ 1969) case, the Court made clear that fairness, relevant circumstances and proportionality prevail over any mechanical equidistance. You cannot allow smaller elements to disrupt the natural projection of a mainland.
People keep shouting "UNCLOS" without actually understanding what they're saying.
Article 121 of UNCLOS recognizes that islands constitute an EEZ, but Article 121(3) limits rocks and small features that are uninhabitable. Even if islands apply, UNCLOS does not guarantee full effect in a delimitation dispute. Fairness still determines the outcome.
Every important case proves this:
Libya-Malta (1985) → minor elements reduced.
Romania-Ukraine (2009) → Snake Island was given disproportionately small influence.
Bangladesh-Myanmar (2012) → concave coasts and shear effects corrected.
Nicaragua-Colombia (2012) → islands adjusted to avoid an unfair outcome.
This is important because Greece is in compliance with Article IV of the UN Convention on the Law of the Sea (UNCLOS). It is not an archipelagic state under Part II (Articles 46-54). Only states such as Indonesia or the Philippines can benefit from this right. Greece cannot bring its entire scattered island system under the baseline of a single giant archipelago. It remains a mainland state with islands, and those islands are subject to reduced influence when they subvert a just outcome. Kastellorizo is a perfect example: it is 2 km from Türkiye and 570 km from Athens. No court would ever allow the creation of a 200 nautical mile barrier blocking the Anatolian shelf.
Greece's maximalist claims are based on the thesis that it is an "archipelago state". Article 46 of UNCLOS states that "in order for a country to have full jurisdiction over islands it must consist of an archipelago", i.e. it must be a country consisting solely of islands.
In seas narrower than 400 miles, the mainland's continental shelf applies since the islands are also within the mainland's continental shelf.
Greece determines its territorial waters by drawing a straight line between the islands of Crete and Rhodes, and has arbitrarily determined its EEZ as if there was no sea between the islands.
According to international law, islands that are far from the mainland and close to the opposing state have no influence on the maritime borders. Islands less than 200 miles from the mainland do not constitute a complete EEZ; that is, they are included in the mainland's EEZ; They cannot create a separate coastline or EEZ on it.
In order for a country to be considered an "Island State", it must consist entirely or largely of islands. Greece IS A PENINSULA WITH A MAINLAND: In international law, a mainland country has no continental shelf or EEZ other than the territorial waters of the islands under its sovereignty.
Greece's statements based on the principle of distance, which considers a part of the island as the "mainland", have no basis in international law.
The Greek islands cannot intersect with the Turkey-Libya coastal projection, and the Greek islands located on the opposite/wrong side of the midline between the mainlands cannot intersect with Türkiye's continental shelf, and are also too small to be compared to the ANATOLIAN mainland mass, unable to form a continental shelf/exclusive economic zone.
There is no continental shelf right around the islands in the Aegean. Since 1977, eight separate decisions have been taken regarding the maritime rights of the islands as a result of disputes. According to maritime law, the islands have no say in agreements between "Mainland" states.
Although the islands have continental shelf and EEZ rights, the principle that "the mainland dominates the sea" forms the basis of the principle of equitable sharing. The methodology for determining maritime boundaries was developed as a result of the decisions of the Court of Justice and the Court of Arbitration, as well as the Law of the Sea. In determining maritime borders, equity, equal distance, proportionality, geographical superiority, non-infringement and special and humanitarian conditions should be taken into account.
Greece's determination of a territorial waters border between the islands of Crete and Rhodes as if there was no sea and drawing the EEZ along this line is against international maritime law and constitutes a violation. Therefore, the Maritime Jurisdiction Agreement between Greece and Egypt is invalid.
Various examples have been documented by the United Nations, such as Indonesia, Sri Lanka, Cuba, Japan and the Philippines.
There is no principle or decision in UNCLOS, the International Court of Justice or the Court of Arbitration that would make Greece an "Island State".
Greece's signing of an EEZ agreement with Egypt lacks any legitimate or legal basis:
It is based on principles—such as equity, proportionality, non-enclosure, and geographical dominance—dictating that an island cannot intrude upon the opposite coasts and sever maritime jurisdiction areas.
1- Crete, Rhodes, Karpathos, and Kastellorizo do not constitute an "archipelago." As islands belonging to the Greek mainland, they cannot generate a coastline capable of establishing an EEZ.
2- A third country cannot cut across the Turkey-Libya coastal projection, nor can an island situated in front of two mainlands block the Turkey-Libya coastal projection or usurp their rights. By treating the line connecting Crete, Karpathos, Rhodes, and Kastellorizo as its relevant coastline, Greece attempts to exclude Türkiye from the Eastern Mediterranean. Greece's claims regarding the principle of distance from a baseline, median lines, and the treatment of these islands as "mainland" have no basis in international law of the sea.
Turkey possesses the longest coastline in the Eastern Mediterranean, spanning 2,280 km. Relevant judicial and arbitral rulings demonstrate that a set of equitable principles exists from which appropriate criteria can be selected during any delimitation process. The principle emphasized in these rulings is the "primacy of geography."
The concept of geography refers to the mainland geography within the area subject to delimitation between two countries. The most significant geographical factor is the length of the mainland coastline. In its judgment on the North Sea Continental Shelf cases, the International Court of Justice stated that "there is no question of reshaping geography." While UNCLOS grants islands "full effect," cases brought before international courts to date have not accorded full effect to the islands of mainland states.
Greek domestic law establishes a median line that grants full effect to all islands. These laws fundamentally contradict the jurisprudence of the International Court of Justice, as it is impossible to define a maritime boundary based solely on a median line—or to establish an equitable maritime boundary—without taking neighboring states into account. This approach violates Articles 74(1) and 83(1) of the 1982 Convention, as the median line is not a mandatory principle. By granting full effect to islands without considering the specific circumstances of the Eastern Mediterranean, Greece effectively treats itself as an archipelagic state.
Turkey and Libya have peacefully determined their boundaries through negotiations and established an outer continental shelf limit. Consequently, Turkey has exercised its legitimate rights under international law within the Eastern Mediterranean, where it possesses a 2,280-kilometer coastline. Acting as two sovereign states in accordance with the 1982 UN Convention on the Law of the Sea, international law, and Article 102 of the UN Charter, Turkey and Libya registered their respective continental shelves and exclusive economic zones through a maritime delimitation agreement that entered into force on September 30, 2020. The registration of this agreement with the UN is the result of actions taken in conformity with international law.
Greece made a major error in the delimitation agreements it signed first with Italy and subsequently with Egypt. Having abandoned the claim of "full effect" for its islands in the agreement with Italy, Greece reiterated this stance in the agreement with Egypt.
Above all, Greece abandoned the claim that, as an island state, all its islands generate their own Exclusive Economic Zones (EEZs).
The boundary in the agreement between Greece and Egypt extends between the 26° 00' 00" East and 27° 59' 02" East meridians. In this agreement, Egypt completely disregarded the island of Kastellorizo. Rhodes was accorded 50% effect; by accepting the 27° 59' 02" East meridian as the eastern boundary, Greece tacitly agreed to grant only partial effect to Rhodes and to limit Kastellorizo's maritime jurisdiction to its territorial waters.
More importantly, this agreement effectively eliminates the possibility of a maritime delimitation agreement between Greece and the Greek Cypriot administration.

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