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European Dredging Association

EuDA

The European Dredging Association (“EuDA”), which celebrated its 30th Anniversary in 2023, was founded in 1993 as a non-profit industry organisation for European dredging companies and related organisations to interface with the various European Union’s Institutions, including the European Parliament.

Lobbying Activity

Response to Foreign Subsidies Review Report

18 Nov 2025

EuDA welcomes the adoption of the FSR as a first step in correcting a discrimination stemming from the fact that EU State Aid Regulations only apply to Member States and not to all companies working in the EU: only the European companies have to comply with the State Aid rules and not the non-EU ones. With the 2026 FSR Evaluation & Revision (hereafter ER), the FSR should become more effective, proportionate & enforceable in the construction sector, especially in dredging, highly exposed to non-EU subsidised State-owned Enterprises. Lowering the notification thresholds The FSR high notification thresholds (250Mn for public procurement) dont capture much of the EU construction market: most construction projects are much smaller than 250Mn. In the upcoming ER, we suggest lowering the thresholds to 50Mn. High thresholds have been deliberately designed to reduce the administrative burden on the EU administration. The EU should strike a balance between the purpose of FSR (protecting the market from harm) and its cost (in terms of administration). Simplifying the procedure In view of the upcoming ER, we suggest simplifying the FSR procedure. In particular, the Commission should consider a much less burdensome approach: repeating the same administrative activities would unnecessarily inflate costs for EU companies, while a system extending the validity of the required information (provided for a specific bid) for a period of 12 months would be better. Clarifying foreign financial contribution The definition of State Aid is broad. However, the State Aid Regulations make a clearer distinction between the normal government economic and financial interventions in the market and the illegal state aids. This has reduced the administrative burden by focusing on the targeted (suspicious) activities. In the FSR, the definition of foreign financial contribution is broad and can include activities performed outside the EU whereby a financial contribution (e.g. contractual payment) is made by a non-EU public entity. Reporting on these financial contributions (through notifications or declarations) may create a disproportionate administrative burden (especially for European companies receiving normal payments for their contractual services to non-EU public administrations), requiring companies to implement complex verification processes to identify potential foreign contributions and assess their impact. As the list of examples in the legal definition is not exhaustive and covers a wide range of benefits (e.g. tax concessions), the Regulation does not allow for easy identification of these elements within standard accounting and reporting systems. In the upcoming ER, the definition of a foreign financial contribution under FSR should be clarified and made more targeted. Clarifying the balancing test In the balancing test, the FSR identifies the positive impacts of the foreign subsidy and does not explicitly refer to the full picture of negative impacts (only the market distortions). In the upcoming ER, all negative impacts (including below-standard environmental performance and working conditions, impacts on the local economy and jobs, ) should be considered. Clarifying the ex officio procedure The ex officio procedure is the only remaining instrument to safeguard the level playing field in the parts of the economy falling below the high thresholds. The information necessary to trigger a market investigation (at the Commissions discretion) is accessible and available through the Commission's investigative powers (not to any European companies). In view of the upcoming ER, EuDA considers that the ex officio tool should be strengthened to address cases not covered by the procurement tool (below the thresholds and private), and that more detailed guidance on the procedural aspects of ex officio investigations is necessary (in particular, the information required to trigger Commission action).
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

EuDA supports the extension of the ETS to shipping and to dredging and offshore. EuDA notes that the IMO has recently agreed a Net Zero Framework that will bring shipping net GHG emissions to zero by (or around) 2050, and that the current EU ETS legislation contains provisions to align with international legislations (IMO). Like shipping, dredging and offshore activities are global and global legislation should be preferred, particularly when considering level playing field. Having two systems working in parallel will increase the risks of double charging and of doubling the administrative burden. The key objectives for the ETS should be simplification and clarification. These will increase certainty and reduce administrative burden. The Commission should make sure that data requirements from ETS and IMO are aligned or at least compatible. Unclarity of scope and definitions can also create extra costs, burden and loopholes (affecting the level playing field). We recommend that the Commission should review the list of vessels for offshore and dredging activities: instead of a list of included vessels, the ETS should use a definition of the offshore and dredging activities with a short list of excluded vessels (eg <5,000GT).The IMO definition for offshore activities (IMO IP) specifies: offshore industrial activities mean the construction, maintenance, decommissioning, operation or servicing of offshore facilities related, but not limited, to exploration and exploitation of resources by the renewable or hydrocarbon energy sectors, aquaculture, ocean mining or similar activities. To cover dredging activities, works on maritime infrastructures (incl. ports, waterways, subsea cables/pipelines, beaches) could be included in the definition. Moreover, the ETS frame for shipping, executing exclusively 'transport works', should be adapted to take into account the reality that dredging and offshore vessels do not transport 'cargo' from port to port and that they use energy to provide specialised construction/engineering services in well-define sea locations. We recommend that the Commission reflects on the 'Port Call' concept and creates a 'Virtual Port Call' version (where offshore and dredging works are taking place) to fill the legislative gap that may lead to competition distortions with non-EU companies. Finally, project crew should be considered under the definition of crew for the purpose of ETS: because the dredging and offshore activities would not be executed without this crew, so changing this crew is also part of the activities. Considering the project crew (IMO industrial personnel and special personnel) as 'passengers" is conflicting with the IMO legislation and will create confusion and more problems.
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Meeting with Stéphane Séjourné (Executive Vice-President) and

1 Jul 2025 · EU Strategic Dialogue on the EU Industrial Maritime Strategy.

Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Industrial Maritime Strategy

Response to Foreign Subsidies Guidelines

2 Apr 2025

EuDA welcomed the adoption of the FSR as a first step in correcting a discrimination stemming from the fact that EU State Aid Regulations only apply to Member States and not to all companies working in the EU: only the European companies have to comply to the State Aid rules and not the non-EU ones. Before FSR, some foreign companies benefitted from foreign subsidies and distorted the European market because no real instrument was available to counter such unfair practices. Nevertheless, FSR can and should be improved to become more effective, proportionate and enforceable in the construction sector, including dredging. Lowering the notification thresholds for public procurement The FSR high notification thresholds (250 Mn for public procurement) dont capture much of the EU construction market: indeed, most construction projects are much smaller than 250 Mn. Therefore, EuDA recommends to lower the thresholds to 50 Mn. High thresholds have been deliberately designed to reduce the administrative burden on the EU administration. The EU should strike a balance between the purpose of FSR (protecting the market from harm) and its cost (in administration). Simplifying the procedure Besides, the Commission should consider a much less burdensome approach overall: repetition of the same administrative activities would unnecessarily inflate costs for EU companies, while a system extending the validity of the required information (provided for a specific bid) for a period of 12 months would be more advisable. Clarifying foreign financial contribution The definition of State Aid is broad. However, the State Aid Regulations better distinguish and target the distortive practices from the carved out normal government economic and financial interventions in the market. This has reduced the administrative burden to focus on the targeted (suspicious) activities. In the FSR, the definition of foreign financial contribution is broad and can include activities performed outside the EU whereby a financial contribution (e.g. contractual payment) is made by a non-EU public entity. Reporting on these financial contributions (through notifications or declarations) may create a disproportionate administrative burden (especially for European companies receiving normal payments for their contractual services to non-EU public administrations), requiring from companies to implement complex verification processes to identify potential foreign contributions and assess their impact. As the list of examples in the legal definition is not exhaustive and covers a wide range of benefits (e.g. tax concessions), the Regulation does not allow for easy identification of these elements within standard accounting and reporting systems. The definition of a foreign financial contribution under FSR should be clarified and made more targeted. Clarifying the balancing test In the balancing test, the FSR is identifying the positive impacts of the foreign subsidy and does not explicitly refer to the full picture of negative impacts (only the market distortions). All negative impacts (including below standard environmental performance and working conditions, impacts on local economy and jobs, ) should be considered. Clarifying of procedural aspects of ex officio investigations The ex officio procedure is the only instrument left to safeguard level the playing field in the parts of the economy not captured by the high thresholds. The information necessary to trigger a market investigation (at the Commissions discretion) is accessible and available through the Commission's investigative powers (not to any European companies). EuDA considers that the ex officio tool should be strengthened to address cases not covered by the procurement tool (below the thresholds and private), and that more detailed guidance on the procedural aspects of ex officio investigations is necessary (in particular, the information required to trigger Commission action).
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Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

The European Dredging Association (EuDA) welcomes the general initiatives of the Commission to simplify the administrative burden (under the Omnibus Package) placed on companies to monitor and stimulate their green transition. The Green Deal's ambitions can only be achieved in cooperation with administrations, industry and the other stakeholders. For multidisciplinary cooperation, it is essential to first understand each other then to trust each other, before to finally cooperate with each other (co-create, co-design, co-finance, co-own). Simplification of a procedure can also happen through its clarification: what is not clear is perceived as complex or can become complex to handle due to the chain of external intermediaries (verifying or certifying bodies) needed in the procedure (e.g. non-financial reporting). The lack of clarity can lead to differences in implementation (and to reduced level playing field). The European Dredgers would like to reiterate their recommendation to the Commission to include dredging activities in the Delegated Acts on Climate Change (Adaptation and Mitigation) under 6.16: the dredging activities are an integral part (and key enablers) of the activities under 6.16 (CCA and CCM) and therefore should not be excluded. Dredging activities are proving to be more and more strategic for waterborne transport and offshore energy infrastructure. EuDA would welcome discussions on the possible revision of DA CCA and CCM and is ready to take part and contribute regarding the inclusion of dredging activities under 6.16.
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Response to Evaluation of the Public Procurement Directives

7 Mar 2025

The revision of the Public Procurement Directives (2014/23-24-25/EU) gives the opportunity to the EU to improve its legislative processes while achieving its highest policy objectives. Dredging Services are Strategic Dredging companies provide more and more strategic services to Europe: dredgers are key enablers for the construction of EU strategic assets such as maritime and inland transport infrastructure, including ports, which are crucial for the competitiveness of the entire EU economy, for its strategic autonomy, for promoting economic development and territorial and social cohesion; dredgers also enable the implementation of key EU policies, including the Green Deal, by building defences against sea level rise, coastal protection against storms and floods, by restoring marine habitats; dredgers carry out offshore energy infrastructure projects that make crucial contributions to Europes climate change mitigation targets and that become increasingly important from a geopolitical perspective; dredgers also play a significant role in telecommunications infrastructure, by installing, repairing and protecting subsea cables, which are increasingly security sensitive (recent cases of subsea cables sabotages in the Baltic Sea). More Level Playing Field in EU Public Procurement The 2014 Public Procurement (PP) Directives (Directives) do not explicitly exclude third country bidders from EU PP and thus principally allow non-EU economic operators to participate in tenders in the EU. However, the Directives also state that ONLY the economic operators from those third countries that either (i) have a Free Trade Agreement (FTA) covering PP with the EU or (ii) are a signatory of the WTO Agreement on Government Procurement (GPA) are guaranteed a treatment no less favourable than EU economic operators, meaning that those operators may rely on the PP Directives provisions. The main issue of public procurement for dredging projects is the unfair competition from non-EU State-owned Enterprises (SoEs), which creates competition distortions that damage both the targeted markets and the competitors. The activities of non-EU construction SoEs in and around the EU have become a growing concern over the past decade. Public procurement plays a central role in creating a true level playing field in the EU (including EU funded projects such as CEF projects). Recommendations for the Revision of the PP Directives EuDA recommends that dredging services, with higher employment and sustainability standards compared to their non-EU competitors, should be given favourable treatment (European preference) in public procurement procedures, and that publicly procured dredging projects (especially the security sensitive projects) shouldn't be performed by economic operators from countries that are systemic rivals of the EU, and which might not solely be driven by economic motives. EuDA recommends that the text of the Directives should explicitly integrate the recommendations of the Commissions 2019 Guidance on the participation of third-country bidders and goods in the EU procurement market and exclude these non-EU economic operators (without GPA nor FTA commitments) from the EU procurement market. Moreover, the revised Public Procurement Directives should also consider excluding bidders that have a track record of confirmed dumping and subsidies practices or of highly suspicious competition behaviour targeting the EU. In order to reduce price only decisions in PP, EuDA recommends promoting the highest employment standards in the EU and to enhance the sustainability standards in publicly procured projects by aligning the PP Directives requirements with the Green Deal objectives (e.g. Green Taxonomy). EuDA recommends clarifying and enhancing provisions regarding abnormally low tenders.
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Meeting with Kathleen Van Brempt (Member of the European Parliament)

16 Jan 2025 · Internationale Handel, Green Deal en Taxonomie in het licht van de activiteit van Europese baggerbedrijven

Meeting with Caroline Nagtegaal (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2024 · EU ETS Maritime

Meeting with Kathleen Van Brempt (Member of the European Parliament, Shadow rapporteur)

14 Jun 2023 · Maritime Port Strategy (APA)

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

The European Dredging Association (EuDA) welcomes the publication of Technical Screening Criteria (TSC) for the 4 environmental objectives (Taxo4: Water-Circular Economy-Biodiversity-Pollution). EuDA would like to congratulate the Commission and the Experts of the Platform on Sustainable Finance (PSF 1.0) for the titanic work produced (covering so many objectives and sectors). In the Taxo4, EuDA particularly welcomes the Water & Adaptation TSCs for Nature-based Solutions for flood & drought risk prevention and control, the Adaptation TSC for Civil Engineering, the Pollution TSC for Remediation of contaminated sites and the Biodiversity TSC for restoration of habitats, ecosystems and species. With regard to the revision of the Annexes of the DA on Climate Change (CC), EuDA regrettably cannot find science-based or fact-based arguments to justify the exclusion of dredging of waterways from the 6.16 on water infrastructures (to Sustainably Contribute (SC) to CC Mitigation (CCM) and to CC Adaptation(CCA)). Indeed, dredging activities are critical for the Construction, modernisation and maintenance of waterborne transport infrastructure which cannot be properly executed without a dredging component. Therefore the construction, modernisation and maintenance of infrastructure enabling low carbon water transport should include dredging activities, including maintenance (with clear TSCs for SC and Do Not Significant Harm (DNSH)). Moreover, the construction, modernisation and maintenance of adapted waterborne transport infrastructure should also include dredging activities. Finally, EuDA would like to highlight that the European dredgers have build 10,000 years storm defences, sea level rise protections, coastal and riverine flood defences, they also continuously invest in new technologies and sustainable approaches (including Nature-based Solutions through Building with Nature). They are a solution-minded and problem solving and are always ready to constructively engage in the policy-making process and in particular in the Green Deal initiatives to which they are contributing and will continue to. If dredging activities were to be considered as an enabler of the activities that these infrastructures will host, then EuDA recommends to the Commission to develop ad hoc TSCs for dredging as an enabler for Adaptation and as an enabler for Mitigation. (See enclosed file)
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Response to Detailed procedures for addressing distortive foreign subsidies

3 Mar 2023

The European Construction Industry, represented by FIEC (European Construction Industry Federation), EIC (European International Contractors) and EuDA (European Dredging Association), hereby submit their comments on the draft Implementing Regulation of the Foreign Subsidies Regulation (FSR). The European contractors welcome the FSR as it is designed to fill the legislative gap whereby European companies are reversely discriminated against, as EU State Aid regulations only apply to EU Member States subsidies and not to subsidies from non-EU countries. The majority, if not all, of the construction contractors projects concern budgets well below the (still too high) thresholds and are not covered by the notification procedures of the FSR. The ex officio procedure would offer some possibilities for the European construction companies to re-level the playing field, but action (e.g. a market investigation) will remain at the discretion of the Commission. A quite wide legislative gap will remain for the construction contractors. And we would like to urge the Commission to present the draft implementation regulation for the ex officio procedure in a very near future. Looking at the notification requirements, it is quite clear that the requested information is accessible and available to the subsidised companies that need to notify the Commission. However, this information is often impossible to find for their (private European) competitors which do not have the Commissions investigative powers and rights to obtain confidential documents which would provide evidence of the subsidys form, source and purpose. The benefit of the subsidy for the non-EU recipient company would usually translate in an unduly advantageous tender in a publicly procured construction project. This is why our sectors still request the reversing of the burden of proof in cases involving subsidised companies from non-EU countries that do not have Market Economy Status, that are not signatory of the GPA agreement nor of an FTA with the EU. Finally, the balancing test is supposed to balance the overall positive and negative impacts of the award of a public tender to a subsidised entity. Therefore, all negative impacts, other than the subsidys, should also be taken in the balance against all possible positive impacts.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Feb 2023 · public procurement, foreign subsidies

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

15 Feb 2018 · Ongoing trade negotiations

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

23 Feb 2016 · TTIP