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Environmental Justice Foundation

EJF

The Environmental Justice Foundation is a global environmental and human rights organization that combats illegal fishing, protects marine ecosystems, supports climate justice and environmental defenders.

Lobbying Activity

Meeting with Rasmus Nordqvist (Member of the European Parliament)

3 Dec 2025 · Implementing fishing discard bans (webinar)

Meeting with Costas Kadis (Commissioner) and

7 Nov 2025 · Participation of NGOs to Advisory Councils

Response to An EU strategy for fisheries external action

8 Sept 2025

EJF protects marine ecosystems, biodiversity, and the livelihoods they support. We promote sustainable, legal, and equitable fisheries, combat illegal and destructive practices, and advocate for MPAs that enhance biodiversity, climate resilience, and community well-being, placing grassroots defenders at the heart of our approach. As a global actor, the EU has a responsibility to promote transparent and responsible fisheries governance. Despite strong tools, implementation and enforcement remain weak. The Fisheries External Action Strategy should focus on the full and effective application of existing EU laws and policies as the way for the EU to enhance global governance of fisheries and ensure that fisheries globally are environmentally, socially, and economically sustainable. - Priorities for a comprehensive strategy -- Strengthen the implementation and enforcement of ocean and fisheries laws and policies. This must include rigorous measures on fisheries control, tackling IUU fishing, and protecting marine biodiversity, with swift action against breaches. -- Ensure that the EUs strong framework for ocean protection is maintained and actively advanced on the global stage. - Combating IUU and associated human rights (HR) abuses through transparency The strategy must maintain the fight against IUU fishing as a priority, recognising its devastating impacts. To realise the EUs zero-tolerance ambition and secure a level playing field, the strategy must close enforcement gaps and commit to advancing global fisheries transparency with the Global Charter for Fisheries Transparency as a key framework to secure systemic transparency. This includes ensuring consistent import controls, stronger sanctions, and disclosure of vessel beneficial ownership (BO). The strategy must also identify unregulated fisheries as a priority concern. -- Strengthen import controls as a market tool: Commit to improvements in import control to prevent seafood linked to environmental destruction and HR abuses from entering the EU, including through increased verification of imports from China and imports stemming from unregulated fisheries. The Commission should prioritise infringement actions against non-compliant Member States (MS). The EU must also act decisively against seafood products linked to forced labour. -- Achieve transparency in vessel BO: Ensure that MS systematically collect information on EU nationals who are BO of fishing vessels (whether EU- or non-EU-flagged) and use this data to enforce obligations to sanction those linked to IUU. At present, the enforceability of these obligations is undermined by the widespread failure to gather such information. Adequate and consistent data collection is the essential first step toward accountability and compliance, and should be treated as a priority. At the same time, the EU should promote BO transparency as a global standard to prevent hidden gains from illegal operations. -- Ensure implementation of fisheries control systems: Guarantee the full and timely implementation of the upgraded fisheries control system, particularly the use of REM. The strategy should further commit to expanding mandatory REM regimes internationally to create a level playing field. -- Strengthen IUU fishing dialogues: Adopt a strategic approach to IUU dialogues, prioritising engagement with countries like China, where increased transparency and stronger anti-IUU measures can have a major impact. Dialogues must also address unregulated fisheries. The strategy should also commit to decisive action, including systematically closing EU markets and ports to pressure flags of convenience into reform. -- Equitable SFPAs: Ensure SFPAs are truly equitable, driving value localisation, transparency, and civil society engagement throughout their lifecycle. New measures should require partner countries to commit to BO transparency. EJF remains available to engage further and discuss our recommendations in more detail.
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Meeting with Fernando Andresen Guimaraes (Director Maritime Affairs and Fisheries) and

5 Sept 2025 · Meeting on the EU’s fisheries external action and policy observations related to a vessel case

Environmental Justice Foundation urges EU to protect civil society

29 Aug 2025
Topic — A proposal for a comprehensive framework to strengthen and protect EU civil society.
Message — EJF requests an EU protection mechanism for environmental defenders and sustainable funding. They also want mandatory dialogue requirements and assessments of laws impacting civic space.12
Why — This would protect their staff from intimidation and provide financial security for their advocacy.3
Impact — Entities using legal harassment to suppress dissent would lose their ability to silence critics.4
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Meeting with Sebastian Everding (Member of the European Parliament)

15 Jul 2025 · EU-Beschwerde zu Grundschleppnetzfischerei in deutschen Natura-2000-Gebieten

Meeting with Costas Kadis (Commissioner) and Greenpeace European Unit and

10 Jul 2025 · Review of the Common Fisheries Policy, Oceans Pact, and future situation of the fishing activity and marine environment

Meeting with Francesca Arena (Cabinet of Commissioner Costas Kadis)

8 Jul 2025 · Implementation of the Control Regulation

Meeting with Costas Kadis (Commissioner) and

1 Jul 2025 · Priorities for the IUU fishing coalition

Meeting with Eoin Mac Aoidh (Acting Head of Unit Maritime Affairs and Fisheries)

22 May 2025 · Exchange of views of article 11 and 20 of the Common Fisheries Policy Regulation.

Meeting with Costas Kadis (Commissioner) and

13 May 2025 · Bottom Trawling in Marine Protected Areas (MPAs)

Meeting with Ilaria Flores Martin (Cabinet of Commissioner Jessika Roswall) and ClientEarth AISBL and

8 May 2025 · Bottom trawling in Natura 2000 sites

Meeting with César Luena (Member of the European Parliament, Delegation chair)

19 Mar 2025 · Exploitation of North Korean workers on Chinese ships

Response to The European Oceans Pact

13 Feb 2025

The EU has the tools to protect the ocean from destructive and illegal practices, but they are not fully implemented or enforced. The Pact should outline actions to ensure the effective implementation of EU laws aimed at combating IUU fishing and protecting marine biodiversity, while also preventing emerging threats like deep-sea mining (DSM). Combating IUU fishing and associated human rights abuses with transparency measures: To achieve its zero-tolerance ambition on IUU fishing and commitment to uphold a level playing field, the Commission must place promoting global fisheries transparency with low- to no-cost, readily available measures, as outlined in the Charter for Fisheries Transparency, at the core of the Pact. To do this credibly, it must focus on ensuring full and effective implementation of the EU anti-IUU fishing framework and preventing any weakening of EU environmental laws or rollback on international commitments. Strengthening this framework will also support the EUs competitiveness agenda by ensuring fair competition and protecting EU fisheries operators from being undercut by IUU fishing and other illegal activities, including forced, bonded, and slave labour. In particular, the Pact should: 1) Include commitments to ensure significant improvements in Member States import controls to prevent seafood linked to environmental destruction and associated human rights abuses from entering the EU market, including increasing seafood import verifications from China; 2) Outline steps to be taken at the EU and national levels to ensure verified information on who ultimately owns or controls EU-flagged or EU-owned fishing vessels (i.e. ultimate beneficial owners) is collected in centralised and publicly accessible databases, enabling Member States authorities to hold accountable those who profit most from illegal fishing and other illegal activities; 3) Commit to ensuring full and timely implementation of the upgraded fisheries control system - particularly the application of remote electronic monitoring to ensure the accuracy of catch reporting and reduce bycatch and unwanted catch discarding; 4) Secure sustained IUU fishing dialogues, prioritising engagement with key fishing players and flags of convenience; and 5) Ensure truly equitable SFPAs that drive value localisation in partner countries while ensuring transparency and meaningful CSO engagement throughout their lifecycle. Ending destructive fishing in EU marine protected areas: The Pact must drive efforts to ensure the effective protection of marine Natura 2000 sites, especially against destructive fishing like bottom trawling. While recognising the major role played by Natura 2000 in protecting essential biodiversity, the European Court of Auditors has concluded that the EU Nature Directives are not being implemented to their full potential. To protect Europes most precious habitats and species, the Pact should prioritise the full implementation and enforcement of the EU Nature Directives and the Nature Restoration Law, ensuring that harmful practices like bottom trawling are banned within Natura 2000 sites. Global moratorium on DSM: The Commission should use the Pact to reaffirm its stance against DSM and actively advocate with Member States and third countries for a de-facto global moratorium on commercial DSM through the International Seabed Authority. Over 900 marine scientists and policy experts warn that DSM will cause biodiversity loss, irreversible damage to ecosystems, and threaten the oceanic carbon cycle and marine food webs. The EU must reject the false narrative that deep-sea minerals are essential for the energy transition and, as recommended by the EASAC, focus on circular economy strategies, recycling, and battery innovations, which could reduce raw material demand by 58%, cut emissions by 39%, and create 700,000 EU jobs.
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Meeting with Thomas Bajada (Member of the European Parliament) and WWF European Policy Programme and

3 Dec 2024 · Event on Seafood Labelling

Meeting with Michal Wiezik (Member of the European Parliament)

26 Sept 2024 · Guided tour of exhibition on Pantanal ecosystem

Meeting with César Luena (Member of the European Parliament)

18 Jul 2024 · Wetlands and deforestation regulation

Meeting with Hildegard Bentele (Member of the European Parliament) and Greenpeace European Unit and

26 Jan 2024 · Meeting mit Umweltverbänden: Resolution zu Tiefseebergbau in Norwegen

Meeting with Caroline Roose (Member of the European Parliament) and Seas At Risk

26 Jan 2024 · Projet de la Norvège d'exploitation minière des grands fonds

Meeting with Isabel Carvalhais (Member of the European Parliament)

15 Nov 2023 · Impacts of bottom trawling in Senegal and level playing field

Response to EU-Senegal fisheries Agreement and Protocol – Way forward

15 Sept 2023

The Environmental Justice Foundation (EJF) advocates the conclusion of SFPAs as a mean towards sustainable ocean governance, and as a contribution to the fight against IUU fishing. To achieve their desired outcomes, it is essential that they drive full transparency by employing clear conditionality allowing for key metrics to be publicly available for scrutiny to support management practices that promote seafood production free from illegal practices. SFPAs must also be truly equitable instruments. This requires enhanced engagement with CSOs in their negotiation and implementation. As such, EJF would like to thank the Commission for launching this call for evidence. EJF takes note of the possible negotiation of a renewal of the Protocol on the implementation of the SFPA between the EU and Senegal. A retrospective evaluation and a forward-looking evaluation are to be carried out in that context. As part of a possible negotiation of a renewal of the Protocol, it should be carefully assessed whether the EU's support to Senegal in fighting IUU fishing had long-term effects. Field-based evidence indicates that it remains a serious issue with, for example, pervasive incursions of trawlers into the area reserved for artisanal fishers. In recent years, Senegal has also been associated with IUU fishing and issues of non-compliance on the international scene (e.g., in RFMOs), and was identified for activities related to IUU fishing by the U.S. NOAA in its 2021 Report to Congress, and, in 2022, as one of the priority flag states amongst the regions at high risk for IUU fishing under the U.S. Maritime SAFE Act. EJF urges the Commission to reinforce scrutiny over the performance of Senegal in fighting IUU fishing as a prerequisite for any possible renewal of the Protocol. The Commission should be prepared to use all tools foreseen under the EU IUU Regulation if it is demonstrated that Senegal has failed to discharge its duties under international law. It must also ensure effective implementation of Article 39 of the EU IUU Regulation by Member States in case EU nationals are found to engage in or support IUU fishing. EJF also wishes to underline the critical importance for the retrospective evaluation to consider to what extent Senegal effectively delivered on its "commitment to promoting sustainable fishing and protecting marine biodiversity, in accordance with the principles of non‐discrimination, transparency and good governance" (Article 2 of the Protocol). The lack of transparency in Senegal's fishing sector has long been denounced by CSOs. EJF notes that Senegal doesn't meet most of the policy principles of the Global Charter for Fisheries Transparency. It is vital to consider how a renewed Protocol could contribute to remedy this situation. The transparency provisions in Article 2 of the current Protocol are particularly weak in comparison to other SFPAs. As such, the EU-Senegal SFPA stands out as the only SFPA lacking a transparency clause. EJF also wishes to highlight the limits inherent in Article 3 (on non-discrimination) of the Agreement considering Senegal's policy of "sénégalisation" of fishing vessels. It is essential that any future renewed Protocol incorporates strengthened transparency, non-discrimination, and human rights clauses. These clauses must be effectively implemented. Finally, EJF is concerned by the fact that coastal small pelagics, which are a vital resource for artisanal fisheries, are in a situation of overexploitation in the Senegambia zone, as are the majority of assessed demersal fish populations (including deep-water hake for which fishing possibilities exist under the current SFPA). The Commission must ensure that any renewed Protocol scrupulously meets the principles and objectives of Article 31 of the CFP and is a truly equitable instrument of mutual benefit to the EU and Senegal, including its local population relying on marine fisheries for their food and livelihoods.
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

19 Jul 2023 · Forced Labour

Response to European Critical Raw Materials Act

29 Jun 2023

As requested by NGOs in the initial consultation, deep-sea mining (DSM) should be explicitly excluded from the scope of the Critical Raw Materials Act (CRMA), including explicit exclusion from the criteria of Strategic Projects. In the Commissions proposal, whether DSM is included in the scope of the Regulation or whether DSM operation could be given priority status as Strategic Projects is concerningly unclear. Consistent with the precautionary principle, the CRMA should prevent the extraction, processing and importation into the EU of critical raw materials exploited from the deep sea, until the scientific gaps are properly filled. At present little is known about fragile deep sea-ecosystems. However, research suggests that mining this pristine environment for these materials could have devastating environmental impacts including: biodiversity loss and habitat destruction; disruption of the carbon cycle; and the loss of livelihoods and food sources. It risks impacting 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 of the raw materials considered strategic and critical under the CRMA, such as copper, manganese, and nickel, are found in the deep sea, and at present the Regulation does not provide the necessary environmental and social safeguards to prevent the exploitation of the deep sea for these materials. Developments at the international level, in the International Seabed Authority, could see commercial exploitation contracts for deep-sea mining being approved by mid-2023. EU Member States should strongly stand against DSM and ensure that projects related to DSM are not endorsed by the EU and that critical raw materials from the deep sea do not enter the EU market. This is in line with the Commissions commitment to protect the seabed and prohibit deep-sea mining until scientific gaps are properly filled, no harmful effects arise from mining and the marine environment is effectively protected (JOIN(2022)28), and the multiple calls from the European Parliament for an international moratorium on DSM. Importantly, it is not necessary to exploit the deep sea and destroy its unique ecosystems in order to achieve the goals and benchmarks of the CRMA. Industry is continually developing solutions that can use cheaper and more widely available resources, and studies have shown that a transition towards a 100% renewable energy supply can take place without DSM, even with very high projected growth in demand under the most ambitious energy scenarios. Deep-sea minerals are not needed, nor could they fill any gap in nickel or cobalt demand before the 2030s because of the need to set up the transport and processing chains. This means that they would not contribute to achieving the benchmarks set out in the CRMA, which need to be achieved by 2030. Materials exploited from the deep sea will not contribute to the digital transition as major companies such as BMW, Volvo, VW, Samsung and Google have already taken a stand against DSM and committed not to use metals produced from DSM until the environmental risks are comprehensively understood. Rather than engaging in new, environmentally destructive practices like DSM, we need to reduce demand for virgin metals and build a circular economy. The EUs priority needs to shift from economic growth to meeting peoples needs, while staying within the Earths ecological limits. Given the negative consequences for the oceans ecosystems and biodiversity as well as carbon cycle, and in line with the EUs role as a champion for a green future and its climate targets, critical raw materials sourced from the deep sea have no place in the EU. The CRMA needs to ensure that the EU door to materials exploited from the deep sea is closed. Please see the attached amendments on how we believe a high level of protection for the deep sea could be reached.
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Meeting with Nikolaj Villumsen (Member of the European Parliament, Shadow rapporteur for opinion) and Anti-Slavery International and

11 Apr 2023 · Regulation on forced labour ban

Meeting with Pierre Karleskind (Member of the European Parliament, Rapporteur)

22 Mar 2023 · pêche INN

Meeting with Grace O'Sullivan (Member of the European Parliament, Shadow rapporteur)

20 Mar 2023 · Fisheries Control - taken by assistant

Meeting with Michal Wiezik (Member of the European Parliament)

15 Mar 2023 · Pantanal tropical wetlands

Meeting with Rosa D'Amato (Member of the European Parliament, Rapporteur for opinion)

9 Mar 2023 · Proposal prohibiting products made with forced labour on the Union market

Meeting with Rosa D'Amato (Member of the European Parliament, Rapporteur for opinion)

16 Feb 2023 · Proposal prohibiting products made with forced labour on the Union market

Meeting with Francisco Guerreiro (Member of the European Parliament, Shadow rapporteur)

9 Feb 2023 · The implications of Chinese fishing operations on EU fisheries and the way forward

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Dec 2022 · Trade and sustainable development; deforestation

Meeting with João Albuquerque (Member of the European Parliament)

6 Dec 2022 · Proteção do Pantanal no Brasil

Response to European Critical Raw Materials Act

24 Nov 2022

EJF is an international non-governmental organisation working to protect the natural environment and human rights. EJF has offices in Brussels, Germany and the UK as well as on the African and Asian continents. The security of supply of critical raw materials is of paramount importance to any state or state-like entity. Of equal importance is the preservation and restoration of our natural environment the basis of all economic activities, with planetary boundaries forming the limits. The European Union has a disproportionate demand for metals, with 20% of global mineral production destined for the Single Market, to cater for demand created by less than 10% of the worlds population. It is critically important that the Critical Raw Materials Act (CRMA) focus on the proposed Objective 4, which is to advance the circular economy model and shift the EUs priority from economic growth to meeting peoples needs, while staying within Earths ecological limits. Critical raw materials will gain in importance in the renewable energy transition. To secure and diversify the supply of these minerals, the EU is seeking new sources. EJF is highly concerned that deep-sea mining (DSM) could be considered a solution to this challenge. However, DSM could irreversibly damage the delicate environment of the deep sea, and open one of the worlds largest carbon sinks with devastating consequences for life on earth. Therefore, DSM should be explicitly excluded from the proposed CRMA: Exclusion of DSM is coherent with decisions by the European Commission to prohibit DSM (JOIN(2022)28). The European Parliament (2020/2273(INI)) has also called on EU Member States (MS) and the Commission to support a moratorium on DSM until scientific gaps have been properly filled to ensure no marine biodiversity loss nor degradation of marine ecosystems. A growing body of scientific research including multi-year EU-funded research like the MIDAS and Mining Impact 1 and 2 projects stresses how DSM would lead to large-scale and irreversible loss of biodiversity in the deep sea through destruction of species, habitats and ecosystems. Moreover, DSM will remineralise the sedimentary carbon to CO2 in one of Earths largest carbon sinks the deep sea leading to increased ocean acidification. Decreasing oxygen levels will alter the composition of biodiversity and the physiology of marine organisms. The body weight of commercially important fish species could decrease by 14-20%. Lastly, deoxygenation, acidification and overheating could exacerbate negative trends in global fisheries: fish populations migrate to shallower water, increasing vulnerability to overexploitation. Hence, DSM endangers the maritime food web and threatens the livelihoods of people who depend on it. These and currently unknown risks of mining the deep sea recently moved major EU MS to clear opposition on DSM: Germany rejects plans to sponsor any plans of work for exploitation, advocating for a precautionary pause, Spain stated the time has come for a pause, and France became the first country to rule out DSM entirely, as President Macron announced that France supports the ban on all exploitation of deep seabeds. The environmental concerns are shared by the European Investment Bank which listed DSM under Bank-wide excluded activities, stating it was unacceptable in climate and environmental terms (EIB Eligibility, Excluded Activities and Excluded sectors list). Other institutions like the High-Level Panel for a Sustainable Ocean Economy and UNEP exclude DSM from the definition of a sustainable ocean economy. Major companies, e.g. BMW, Volkswagen, Samsung, Philips, and Google have spoken out against DSM. We strongly encourage the European Commission to acknowledge the opposition to DSM by scientists, businesses, civil society actors and an increasing number of states such as EU MS Germany and France against DSM and explicitly exclude DSM from the proposed CRMA.
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Meeting with Grace O'Sullivan (Member of the European Parliament, Shadow rapporteur)

20 Nov 2022 · Fisheries Control Regulation Review, taken by assistant

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Anti-Slavery International and

17 Nov 2022 · forced labour

Meeting with Francisco José Millán Mon (Member of the European Parliament, Shadow rapporteur)

10 Nov 2022 · Fisheries Control

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Oct 2022 · Prohibition of products made by forced labour in the EU Market

Response to Communication on the functioning of the Common Fisheries Policy

22 Sept 2022

The Environmental Justice Foundation (EJF) would like to thank the European Commission for launching this call for evidence. Earlier this year, EJF submitted a thorough reply to the targeted consultation on the 2022 Report on the Functioning of the CFP. EJF would like to take the opportunity of this call for evidence to highlight once again some of our recommendations to strengthen the CFP and its implementation, in particular to improve the transparency of global fisheries governance and to fight IUU fishing which we consider as a major threat to our ocean and the people dependent upon it, alongside overfishing and labour and human right abuses in the seafood industry. Please find attached EJF's feedback to the call for evidence.
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Meeting with Caroline Roose (Member of the European Parliament)

30 Aug 2022 · Pêche IUU en Afrique de l'Ouest

Meeting with Caroline Roose (Member of the European Parliament)

27 Aug 2022 · Atelier sur la pêche internationale aux Journées d'été des écologistes

Meeting with Ska Keller (Member of the European Parliament)

28 Apr 2022 · Presentation of a Study on Fisheries Policy (Staff Level)

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

8 Mar 2022 · International ocean policies and IUU fishing

Response to Setting the Course for a Sustainable Blue Planet -Update of the International Ocean Governance Agenda

1 Feb 2022

The Environmental Justice Foundation (EJF) would like to thank the European Commission and the European External Action Service for launching this call for evidence. In 2020 and 2021, EJF has actively taken part in discussions and consultations on the International Ocean Governance Agenda. EJF would like to take the opportunity of this call for evidence to repeat, in the document attached, its recommendations for targeted actions in improving transparency in the framework of global fisheries governance and fighting IUU fishing which we consider as a major threat to our oceans and the people dependent upon them alongside overfishing and labour and human right abuses in the seafood industry.
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Meeting with Virginijus Sinkevičius (Commissioner) and

28 Oct 2021 · NGOs presented their expectations for an ambitious reform and shared views on specific topics in the revision of the EU fisheries control system.

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

11 May 2021 · Discussion on IUU

Response to Evaluation of SFPAs

23 Feb 2021

The Environmental Justice Foundation (EJF) welcomes the initiative to carry out a thorough assessment of the SFPAs policy to support future improvements and the opportunity to provide feedback. EJF is a non-governmental organisation working to secure a world where natural habitats and environments can sustain, and be sustained by, the communities that depend upon them. For over a decade, EJF has worked to combat IUU fishing including in countries with which the EU has concluded SFPAs. EJF notes that SFPAs call for sustainable exploitation of marine resources, sectoral capacity-building and contributing to the global fight against IUU fishing. In assessing its SFPA policy, EJF encourages the Commission to carefully review to which extent this policy has contributed to building capacity to fight against IUU fishing in a durable way in partner countries and to assume their obligations under international law as flag, coastal, port and market states. We believe that this assessment will be an opportunity to identify improvement measures that should be implemented by the Commission. In this context, particular attention should be given to policy consistency between the EU’s policy on SFPAs and the EU’s policy to fight against IUU fishing, and as to whether and how the EU can better capitalise on its partnerships to achieve improved compliance in regional fora. EJF believes that increased transparency in the fishing sector is key to eliminate IUU fishing. As such, we encourage the Commission to identify and remedy transparency gaps in SFPAs. In this context, EJF considers that it is imperative to assess to which extent this policy has effectively contributed to achieving improved global transparency – and a level playing field – in partner countries, including in respect to non-EU country fishing fleet agreements and licences. Increased transparency should also be understood in terms of meaningful engagement with civil society organisations and other relevant bodies in SFPA negotiations and raising awareness about SFPAs both in the EU and in partner countries. EJF also encourages the Commission to carefully review to which extent its policy on SFPAs has contributed to the defence of human rights in the partner countries. EJF’s empirical data from investigations show that human rights abuses and labour violations on board fishing vessels are not, from a global perspective, uncommon. Improving transparency along with ratifying and effectively implementing key international instruments to protect workers on fishing vessels can contribute to addressing these exploitative and abusive practices. Finally, EJF wishes to underline the relevance of analysing SFPAs from a trade and market perspective – especially from the EU and SFPA partner countries angles, but also considering regional dynamics. In this context, EJF notes that the provisions enshrined in SFPAs, together with the EU Control, IUU and SMEFF Regulations, govern fishing activities of EU vessels in SFPA partner countries and ultimately of fisheries products that will, at least in part, be marketed in the EU. Moreover, EJF notes that in-country capacity building through SFPAs can help partner countries gain access to the EU and other international markets. This is explicitly enshrined in a number of SFPAs. SFPAs also include provisions relating to promoting cooperation among economic operators to notably encourage the establishment of an environment favourable to the development of business and investment. SFPAs can thus allow for new economic revenue streams, particularly for local communities making a living from marine resources. This must be compatible with the imperative of contributing to food security and building sustainable fisheries value chains in SFPA partner countries and beyond. When considering exports from SFPA partner countries, EJF wishes to also underline the relevance of sanitary-related aspects which form an integral part of some SFPAs.
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Response to EU strategy for sustainable textiles

26 Jan 2021

The Environmental Justice Foundation welcomes this initiative and the opportunity to provide feedback. Please find our up-to-date report on cotton and carbon footprint attached. A comprehensive EU framework is urgently needed, including concrete, proactive and transparent measures to face the significant climate, environmental and human rights impacts of the textiles industry. Currently, organic cotton is the only viable option with the potential for mass-market reach that will not exacerbate the climate emergency and social injustices. Its value chains are short and transparent instead of opaque and exploitative. It’s a viable alternative to conventional cotton because the knowledge, infrastructure and consumer confidence are already in place. However, organic cotton production only accounts for 0.93% of global totals (Textile Exchange 2020). The lifecycle of textiles accounts for approx. 6.7% of all global greenhouse gas emissions (Quantis 2018). Overall, the textile industry emits between up to 2.93 billion tonnes of CO2 every year (EMF 2017; Niinimäki et al. 2020). Estimates suggest that those figures are likely to rise dramatically in the coming decade as production and consumption increase. Globally, conventional cotton accounts for 220 million tonnes of CO2 every year and uses 8.2 million tonnes of pesticides and synthetic fertilisers (Soil Association 2016). Other fibres are no better: 342 million barrels of petroleum oil are required annually to meet demand for plastic-based fibres. Further, the disintegration of synthetic fabrics such as polyester or nylon is responsible for between 20 and 35% of all microplastics in the marine environment (IUCN 2017). Alongside other measures, support for organic cotton production can contribute greatly to sustainable textiles as it uses less chemical pesticides and fertilisers, whilst contributing to reduced use of freshwater and protecting soils. In addition, organic cotton also confers significant social and economic benefits to communities in the Global South (reductions in costly inputs; and premiums paid to producers). Most impacts occur outside the EU as 80% of cotton production is concentrated in seven countries: China, India, the US, Pakistan, Brazil, Turkey and Uzbekistan. There is a severe risk that the production of conventional cotton is linked to human rights abuses affecting value chains that involve these raw materials. Thus, a human rights-based approach must be a core element of the EU strategy including environmental duty of care and due diligence. For instance, a great amount of cotton production in Xinjiang (China) - which produces more than 20% of the world’s cotton - is overshadowed by forced labour of Turkic Muslim minority people (CGP 2020). Another example is Uzbekistan where EJF investigations exposed the wholescale use of state-sponsored forced child labour in cotton production (EJF 2005). Uzbekistan has taken some steps to tackle forced labour though a recent report found that many adults are still compelled to work in the cotton fields (HRW 2020). Recommendations: 1. Introduce a Border Carbon Adjustment on conventional cotton, the proceeds of which should underwrite the cost of transition to, and the certification process for, organic cotton. 2. A legally binding, comprehensive mHREDD regulation that covers textiles. All EU companies and financial institutions must continuously, proactively and transparently ensure that their activities, including these of subsidiaries and suppliers, align with human rights and environmental law. 3. Incentivise wholescale conversion to organic cotton production using fiscal and regulatory measures, and discourage conventional cotton production. 4. Commit to public procurement contracts that prioritise organic cotton. 5. Incentivise and apply circular economy principles to all sectors of the textile industry. 6. Targets aiming to reduce overall consumption of natural resources and raw materials.
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Meeting with Francisco José Millán Mon (Member of the European Parliament, Shadow rapporteur) and FUNDACION OCEANA

21 Jan 2021 · Fisheries Control

Response to Strengthening the EU’s contribution to rules-based and effective multilateralism

15 Jan 2021

The Environmental Justice Foundation welcomes the initiative of the European Union to strengthen rules-based multilateralism and the opportunity to provide feedback. EJF strongly encourages the European Union to centre environmental justice in its approach to existing and future multilateral engagements in order to lead the world towards a greener, healthier and more just planet. Article 21 of the Treaty of the European Union states that “action on the international scene shall be guided by the rule of law, the universality and indivisibility of human rights and fundamental freedoms, respect for human dignity, the principles of equality and solidarity and respect for the principles of the United Nations Charter and international law”. However, environmental justice remains at the margins of European multilateral strategies and EU law does not contain an explicit recognition of environmental justice as an essential principle in the development of its environmental policies or its multilateral engagements. To extend multilateralism to global realities that call for urgent action, the EU should adopt environmental justice as a guiding principle leading its multilateral strategies in all areas of operation. Before the Covid-19 crisis struck the world, multilateralism was already under threat. A just pandemic recovery and renewed intergovernmental initiatives go hand in hand and present a unique momentum for positive change. The EU should use its power to drive forward an effective, just multilateralism based on the principles of environmental justice. The climate crisis reveals the shortcomings of the current reality of multilateralism. It falls disproportionately and unfairly on the poorest and most marginalized communities that have contributed least to the damage to ecosystems and to our heating climate. Climate change and other environmental pressures will contribute to large-scale transboundary migration over the coming decades. Since 2008, weather-related hazards – which are increasing in frequency and severity as a result of climate change – have displaced an average of more than 21 million people each year (IDMC 2016), and experts predict that there may be 1.4 billion people displaced by climate change worldwide by 2060 (Hadlock 2017). However, the international community turns a blind eye to these vulnerable groups: an international legal framework for their protection is still lacking due to a failure of decisive, coordinated multilateral agreement. Without a thorough multilateral strategy and a new legally-binding framework that recognizes the rights of climate refugees and protections due to them, international cooperation will fail to meet the needs of these vulnerable people. Furthermore, intergovernmental initiatives must fully engage civil society. Increasing consultative participation within and outside the EU should become an important aspect of EU multilateral governance; giving people a strong voice and the power to articulate their concerns through citizens’ assemblies. Another critical element for a more effective and just EU-led multilateralism is embracing transparency. EJF commends the EU’s existing efforts in promoting transparency in EU governance, and encourages that transparency forms the heart of all future EU multilateral engagements, including in trade deal negotiations and the implementation of international environmental and human rights safeguards. Environmental justice is about protecting the most fundamental human right to a secure and healthy environment. The development, implementation and enforcement of environmental policies and laws must enshrine fairness, equality and non-discrimination for the traditional custodians and beneficiaries of natural resources. To move away from fragmentary approaches, EU policy, as well as member states’ policies, should be led by a justice-oriented perspective based on a truly accountable, proactive, inclusive and rejuvenated multilateral system.
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Meeting with Virginijus Sinkevičius (Commissioner) and

4 Dec 2020 · Following 2 briefs published by NGOs coalition against Illegal, unreported and unregulated (IUU) on this, to discuss the role that the fight against IUU plays in achieving the implementation of the Farm to Fork Strategy and the Biodiversity Strategy

Meeting with Francisco José Millán Mon (Member of the European Parliament, Shadow rapporteur) and FUNDACION OCEANA

4 Nov 2020 · Fisheries Control

Meeting with Virginijus Sinkevičius (Commissioner) and

29 Jan 2020 · To discuss illegal, unreported and unregulated fishing

Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

16 Jan 2020 · Oceans priorities, illegal, unregulated and unreported (IUU) fishing, transparency as the key to combating IUU fishing

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

15 Jan 2020 · climate change and marine protection

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)

20 May 2019 · + other NGOs: Exchange of views on the workings of the IUU Coalition

Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels

7 Mar 2019

The Environmental Justice Foundation echoes the concerns of many EU citizens and other stakeholders in regard to the draft delegated act and its serious loopholes that will allow deforestation to flourish. Our primary concern relates to the criteria proposed to define food crops for use in EU biofuels (‘High ILUC Risk’) which are fundamentally flawed and weaken the entire objective of the delegated act. Soy and all palm oil derivatives that are closely implicated with high levels of deforestation must be included as ‘High ILUC risk’ biofuels. Furthermore, there cannot be exemptions for certain palm oil products to be used for biofuels (the so-called 'Low ILUC Risk) and this loophole should be removed. We call on President Juncker and Vice-President Timmermans to take a leadership role for our shared world. Destroying forests to fuel Europe's cars and lorries is madness. We need to resist industry pressure that will cost our global climate, irreplaceable biodiversity and future generations dearly.
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Meeting with Karmenu Vella (Commissioner) and

5 Feb 2019 · IUU Fishing

Meeting with Isaac Valero Ladron (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

25 Jan 2018 · Climate change and its role in conflict and displacement

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

21 Sept 2016 · IUU fishing

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and WWF European Policy Programme and The Pew Charitable Trusts

30 Apr 2015 · IUU fishing

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

17 Apr 2015 · Illegal, Unreported and Unregulated Fishing