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Deep Sea Conservation Coalition

DSCC

The objectives of the DSCC in the EU are: • Securing protection for vulnerable deep‐sea ecosystems and ensuring sustainable deep-sea fisheries; • Substantially reducing the greatest threats to life in the deep seas; and • Safeguarding the long-term health, integrity, and resilience of deep-sea ecosystems.

Lobbying Activity

Response to An EU strategy for fisheries external action

16 Sept 2025

The Deep Sea Conservation Coalition (DSCC) comprises more than 130 organizations globally, working to ensure the protection of vulnerable marine ecosystems and deep-sea biodiversity from destructive practices. The DSCC holds observer status and is actively engaged in all deep-sea Regional Fisheries Management Organizations (RFMOs), as well as CCAMLR and CAOFA. This submission focuses specifically on global fisheries governance, a strategic EU approach, and regional fisheries management organisations (RFMOs). Summary of recommendations: - Ensure the full and continued implementation of the EU Deep Sea Access Regulation to ensure international positions are backed by domestic credibility. - Ensure EU positions are consistent across all deep-sea RFMOs, based on the consistent application of best available science and the precautionary approach to management of VMEs. Meet and advocate for the baseline international standard for protection, as articulated in the international policy framework, including UNGA Resolutions - in particular 61/105 and 77/118, FAO Guidelines, Convention on Biological Diversity resolutions, and IUCN motions. The EU advocate and actively support full and final implementation of all relevant UNGA bottom fisheries resolutions; - The EU calls on all countries that continue to pursue destructive fishing practices on seamounts and other VMEs to immediately transition away from those practices. - Full political support for the ratification of the BBNJ Agreement by those EU member states that have not yet ratified; - Swift incorporation of BBNJ obligations (including environmental impact assessments and area-based management tools) into the EU acquis upon entry into force; - Alignment of relevant EU policy (including on environmental protection, fisheries, and trade) with BBNJ; - Leadership in driving RFMOs towards BBNJ-readiness, and active engagement across all RFMOs to ensure consistent application of BBNJ. - Avoid habitat destruction by prioritising fisheries and fishing methods that do not have a significant adverse impact on seamounts, other VMEs, and EBSAs - Advocate for the protection of seamounts, to help prevent the extinction of a wide range of species. - Advocate stronger precautionary measures in all RFMOs and globally, acknowledging that the cumulative impact of climate change and destructive fishing practices can lead to irreversible biodiversity loss. - Consistently advocate application of FAO VME criteria and implementation of UNGA resolutions (to protect seamounts and other VMEs) at all deep sea RFMOs. - Strengthen scientific advice: decisions must be guided by peer-reviewed, independent, and precautionary science, not short-term political or economic pressures - Ecosystem approach: promote the adoption of an ecosystem-based fisheries management framework that accounts for cumulative impacts, including climate stressors interacting with habitat destruction. - Independent review: call for periodic independent performance reviews of RFMO science processes to ensure rigor and transparency. - Climate-informed stock assessments: integrate climate change impacts (e.g., shifting species distributions, ocean warming, acidification) into stock assessments and conservation measures of the habitats - Precautionary closures: apply precautionary closures or adaptive spatial management where species or habitats are especially vulnerable to climate impacts; - Future-proofing measures: Ensure that RFMO conservation and management measures are flexible and adaptive, so they can respond quickly to environmental shifts; - EU leadership: position the EU as a driver of climate-smart fisheries governance, leveraging its membership in all deep-sea RFMOs to set ambitious, science-based standards.
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Meeting with Eva Maria Carballeira Fernandez (Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and

15 Jul 2025 · Recommendations on how to address shortcomings in the ICES advice and requests

Meeting with Milena Mihaylova (Head of Unit Maritime Affairs and Fisheries)

2 Apr 2025 · Exchange of views on EU priorities in the Mediterranean.

Meeting with Costas Kadis (Commissioner) and

3 Feb 2025 · New Commission mandate & Vulnerable Marine Ecosystems

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius), Eglantine Cujo (Cabinet of Commissioner Virginijus Sinkevičius)

5 Mar 2024 · Protection of seamounts in the high seas

Meeting with Francisco Guerreiro (Member of the European Parliament, Rapporteur) and FUNDACION OCEANA and

11 Oct 2023 · NEAFC transposition

Response to European Critical Raw Materials Act

27 Jun 2023

The draft Critical Raw Materials Act text, in its current form, does not exclude deep-sea mining from its scope. Article 2(6) includes mineral occurrence(s) under water within its definition of extractive activities under the scope of the regulation, which essentially refers to seabed mining. Including deep-sea mining within the scope of the proposed regulation stands at odds with the European Commissions position regarding deep-sea mining. In its June 2022 Joint Communication on the EUs International Ocean Governance agenda (JOIN(2022)28), the Commission called to prohibit deep-sea mining until scientific gaps are properly filled, no harmful effects arise from mining and the marine environment is effectively protected. Furthermore, the European Investment Bank, in its EIB Eligibility, Excluded Activities and Excluded sectors list has explicitly listed the extraction of mineral deposits from the deep sea as Bank-wide excluded activities, considering it unacceptable in climate and environmental terms. This is consistent with the conclusions of the High Level Panel for a Sustainable Ocean Economy and the UNEP guide to financing sustainable ocean recovery. In June 2023 the European Academies of Science Advisory Council (EASAC) issued a Statement on Deep Sea Mining urging a moratorium of deep-sea mining and warning of the dire consequences on marine ecosystems [https://easac.eu/publications/details/deep-sea-mining-assessing-evidence-on-future-needs-and-environmental-impacts]. The EASAC report stresses how deep-sea mining would entail large-scale and irreversible loss of biodiversity in the deep sea through destruction of species, habitats and ecosystems. It also raises concerns about impacts on fish populations, including those of commercial interest, and the potential release of sequestered greenhouse gases from the ocean floor and other impacts on climate change. Several scientific studies, including multi-year EU-funded research like the MIDAS and MiningImpact 1 and 2 projects, have documented and warned about the known or probable impacts of deep-sea mining. Including the extraction of mineral occurrences under water, which essentially means seabed mining, within the scope of the CRMA, also goes against the position repeatedly expressed by the European Parliament through resolutions calling upon the Commission and States to support an international moratorium on deep-sea mining (June 2021 on EU Biodiversity Strategy for 2030 [2020/2273(INI)] and of October 2022 on momentum for the ocean [2022/2836(RSP)]. Therefore, we urge the Commission to ensure an explicit exclusion of deep-sea mining is incorporated into the future CRMA. Finally, as the EASAC Statement on Deep Sea Mining reiterates that deep-sea mining on any scale should not be considered until recycling potentials have been fully explored. While the proposed CRMA seeks to encourage secondary metals through recycling and re-mining waste, it should go beyond securing demand and instead set binding EU material-footprint reduction targets for the next decades (particularly for metals), addressing the urgent need to downscale the EUs economic consumption. Based on the current draft, we recommend that: - An explicit exclusion of deep sea mining is included in Recital 19 or in a new item, with reference to the UN High Seas Treaty and previous calls by the Commission (JOIN(2022)28) and Parliament (2021/2188(INI) and 2022/2836(RSP)) for a moratorium or ban of deep-sea mining. - Article 2(6) is revised to exclude mineral occurrence(s) under water from the definition of extraction under the scope of the CRMA, or, alternatively, ensure explicit exclusion of the extraction of minerals from the seabed; - The list of Union legislation or international instruments for the Assessment of the recognition criteria for Strategic Projects in ANNEX III is extended to include the European Investment Bank (EIB) Eligibility, Excluded Activities and Excluded sectors list.
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Jul 2022 · To exchange views, upon NGO request, on the upcoming Action plan to conserve fisheries resources and protect marine ecosystems, on Commission implementing act on vulnerable marine ecosystems and on European eel status

Meeting with Caroline Roose (Member of the European Parliament)

11 Jul 2022 · Exploitation minière des fonds marins (assistant·e·s)

Meeting with Virginijus Sinkevičius (Commissioner) and

1 Apr 2022 · To discuss deep sea mining and the negotiations of the mining code in the International Seabed Authority