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Seas At Risk

SAR

Seas At Risk is an association of environmental organizations from across Europe working to ensure abundant, diverse, and climate-resilient marine life not threatened by human activities.

Lobbying Activity

Meeting with Isabella Lövin (Member of the European Parliament, Shadow rapporteur) and Coalition Clean Baltic

10 Dec 2025 · Marine multi-use windfarms and fisheries

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall) and ClientEarth AISBL and FUNDACION OCEANA

8 Dec 2025 · Implementation of marine/nature laws; MSFD revision and the upcoming European Ocean Act

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Transport and Environment (European Federation for Transport and Environment) and

19 Nov 2025 · Exchange of views on raw materials, on the side of the EU Raw Materials Week 2025

Meeting with Costas Kadis (Commissioner) and

7 Nov 2025 · Participation of NGOs to Advisory Councils

Seas At Risk urges binding EU material reduction targets

5 Nov 2025
Topic — EU Circular Economy Act aims to enhance competitiveness through sustainable production and recycling.
Message — The organization requests binding EU-wide material footprint targets with reduction to 58 tonnes per capita by 2050. They argue recycling alone won't deliver systemic change and call for prioritizing reduced material demand through product longevity and reuse. They also seek fiscal reforms phasing out subsidies for resource extraction.123
Why — This would reduce Europe's dependency on imported raw materials from high-risk third countries.4
Impact — Resource extraction industries lose subsidies and face higher costs from environmental externalities being internalized.56
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Meeting with Paula Duarte Gaspar (Head of Unit Environment) and SURFRIDER FOUNDATION EUROPE

21 Oct 2025 · Blue carbon Marine Strategy Framework Directive

Meeting with Rasmus Nordqvist (Member of the European Parliament)

16 Sept 2025 · Textile and plastics

Seas At Risk urges EU to halt CCS infrastructure plans

10 Sept 2025
Topic — The European Commission is developing legislation for CO2 transportation infrastructure and markets.
Message — The organization calls for an immediate halt to infrastructure development and a ban on carbon storage in marine environments. They demand that the EU prioritize deep emission cuts and ecosystem restoration over high-risk technological solutions.123
Why — The organization would secure better protection for marine ecosystems and ensure funding goes to nature-based solutions.4
Impact — Energy companies lose the infrastructure support needed to maintain fossil fuel-based business models.5
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Seas At Risk urges inclusive offshore renewable energy transition

10 Sept 2025
Topic — A consultation on empowering citizens and communities within the EU's energy transition.
Message — Seas At Risk calls for mandatory environmental checks and community engagement in offshore renewable projects. They recommend using social criteria in energy auctions to ensure local benefits.12
Why — Environmental groups ensure marine protection while reducing the risk of project-stalling legal challenges.34
Impact — Energy developers lose the option to bypass environmental assessments through fast-track permitting zones.5
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Meeting with Christophe Clergeau (Member of the European Parliament) and SURFRIDER FOUNDATION EUROPE

9 Sept 2025 · SEArica

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

8 Sept 2025 · Deep Sea Mining

Response to Sustainable fishing in the EU: state of play and orientations for 2026

28 Aug 2025

On behalf of 25 NGOs (Baltic Salmon Fund, Baltic Salmon Rivers Association, BalticWaters, BirdLife Europe, BlueMarineFoundation, Coalition Clean Baltic, ClientEarth, Danmarks Naturfredningsforening, Deutsche Stiftung Meeresschutz, DUH e.V., Ecologistas en Acción, FishSec, Irish Wildlife Trust, Marine Conservation Society, North Sea Foundation, Oceana, Sciaena, Seas At Risk, SFACT, SharkProject, SharkTrust, SUNCE, WDC, WWF, Zero) we present our response to the 2025 European Commissions public consultation on the progress towards achieving more sustainable fisheries, the state of fish stocks and the setting of fishing opportunities. This policy briefing, attached as pdf, provides analysis and recommendations to ensure the adoption of sustainable fishing opportunities that prioritise long-term ocean health through rebuilding fish populations, safeguarding and boosting ecosystem resilience in the face of mounting pressures like climate change, and fostering transparent and accountable fisheries management. Our key policy recommendations: 1. Ending overfishing: fully applying the precautionary approach to fisheries management and ensuring the full implementation of the Landing Obligation (LO), so that all catches are reliably documented and accounted for; 2. Restoring and maintaining fish populations above healthy and productive levels: rapidly recovering depleted and struggling fish stocks and generally investing in larger, healthier, more resilient, and more productive fish populations; and 3. Fully applying the ecosystem-based approach to fisheries management: explicitly factoring ecosystem integrity and dynamics into the setting of fishing opportunities and the scientific advice that underpins them, and minimising incidental catches, to safeguard and boost ecosystem health, resilience and productivity. 4. Respecting the legally binding safeguards in the EUs Multi-Annual Plans (which are part of Retained EU Law in the UK), by proposing and setting catch limits that do not exceed the legal 5% risk limit of stocks falling below a level where reproductive capacity may be reduced. Our overarching key recommendation to achieve the above remains to propose and set fishing opportunities well below - and under no circumstances above - the best available scientific single-stock advice provided by ICES, where this does not yet fully reflect and safeguard ecosystem integrity and dynamics and/or is not explicitly geared towards rapid recovery and/or maintaining populations above sustainable biomass levels. We urge the Commission to consider the points covered in the attached pdf file not only in the EU's internal approach but also during negotiations with third countries such as the UK and Norway.
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Seas At Risk Demands Stricter Rules for Plastic Recycling Content

18 Aug 2025
Topic — EU rules for calculating recycled plastic content in single-use beverage bottles.
Message — The organization requests that recycled content targets only include post-consumer plastic waste as input, excluding pre-consumer waste even when mixed. They demand removal of dual-use output concepts and prioritization of segregation and controlled blending models for accounting. They call for European sustainability criteria on plastic recycling technologies before accepting chemical recycling.123
Why — This would prevent chemical recycling from counting toward targets without proven environmental benefits.45
Impact — The chemical recycling industry loses ability to claim recycled content credits without guarantees.67
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Seas At Risk Urges Nature Protection in EU Grid Expansion

5 Aug 2025
Topic — The consultation proposes measures to accelerate the upgrade and expansion of European grid infrastructure.
Message — The group demands halving energy demand by 2040 and maintaining mandatory environmental assessments. They insist grid infrastructure avoid protected areas and incorporate mandatory nature-inclusive design. They also oppose using derogations that bypass environmental legislation for grid expansion.123
Why — Stricter rules would prevent industrial damage to vulnerable marine ecosystems and ensure biodiversity recovery.4
Impact — Grid operators would face restricted construction zones and increased costs from mandatory nature-inclusive requirements.5
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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 Jessika Roswall (Commissioner) and

1 Jul 2025 · Circular and toxic-free plastic

Seas At Risk urges shift to regenerative blue bioeconomy

23 Jun 2025
Topic — A consultation on creating a circular, climate-neutral, and competitive EU bioeconomy.
Message — Seas At Risk advocates for a transition from extractive practices to regenerative models prioritizing ecological integrity. They request new aquaculture guidelines to reduce wild-fish feed and a Sustainable Resource Management Directive with binding reduction targets.12
Why — These measures would protect marine biodiversity and ensure the long-term viability of fisheries-dependent communities.34
Impact — Industrial sectors relying on high-impact extraction, fossil fuels, or single-use bioplastics face phase-outs.56
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Meeting with Rasmus Nordqvist (Member of the European Parliament) and Deutsche Umwelthilfe e.V.

12 Jun 2025 · EU Oceans Pact

Meeting with Patrick Child (Deputy Director-General Environment) and

3 Jun 2025 · Exchange of views on LIFE

Meeting with César Luena (Member of the European Parliament)

26 May 2025 · Bycatch in EU waters

Meeting with Eoin Mac Aoidh (Acting Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and FUNDACION OCEANA

22 May 2025 · Exchange of views on the Article 17 of the Common Fisheries Policy Regulation and vade mecum on allocation of fishing opportunities by Member States

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and

20 May 2025 · Exchange of views on the upcoming Ocean Pact and Water Resilience Strategy

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall) and

20 May 2025 · Ocean Pact and Water Resilience

Meeting with Costas Kadis (Commissioner) and

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

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Youth Forum and

23 Apr 2025 · Environmental action

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and SURFRIDER FOUNDATION EUROPE and Environmental Investigation Agency

7 Apr 2025 · Pellets Regulation

Meeting with Rasmus Nordqvist (Member of the European Parliament)

24 Mar 2025 · Oceans pact

Meeting with Lynn Boylan (Member of the European Parliament)

18 Mar 2025 · Offshore wind and biodiversity protection

Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Seas At Risk welcomes the opportunity to provide input to the draft implementing act specifying the pre-qualification and award criteria for auctions for the deployment of energy from renewable sources. We will focus on auction criteria for offshore renewable energy. Non-price criteria can be a strategic tool to ensure that Member States select offshore renewable energy projects that avoid and minimise their impact on the environment and facilitate the participation of citizens and energy communities. Member States must therefore dedicate a substantial percentage of auction award points to non-price criteria related to social and environmental performance. We recommend a few changes to strengthen the effectiveness of the implementing act, and we attach an Annex with concrete examples of non-price criteria related to the social and environmental performance of offshore wind projects.
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Seas At Risk demands legally binding targets for ocean restoration

17 Feb 2025
Topic — The European Oceans Pact establishes a holistic framework for EU marine and coastal policies.
Message — Seas At Risk calls for a roadmap with binding targets to restore ecosystems by 2030. They demand bans on bottom trawling in protected areas and global deep-sea mining. The group urges a transition to a blue economy supported by an Ocean Fund.12
Why — Stronger enforcement would ensure environmental laws are no longer ignored by Member States.3
Impact — Industrial fishing, mining, and energy firms would face strict bans and restricted resource access.4
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Meeting with Karin Karlsbro (Member of the European Parliament, Shadow rapporteur) and SURFRIDER FOUNDATION EUROPE

13 Feb 2025 · Plastpellets

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

11 Feb 2025 · Future of the EU Green Deal

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

27 Jan 2025 · Ocean Policy

Meeting with César Luena (Member of the European Parliament, Rapporteur) and SURFRIDER FOUNDATION EUROPE and Environmental Investigation Agency

22 Jan 2025 · Pellets Regulation

Meeting with Jan Dusik (Deputy Director-General Climate Action)

16 Jan 2025 · Ocean Climate Issues

Meeting with Jutta Paulus (Member of the European Parliament) and Deutsche Umwelthilfe e.V.

15 Jan 2025 · Podiumsdiskussion: Wind and Waves – Advancing Offshore Wind and Solutions for Marine Sustainability

Meeting with Isabella Lövin (Member of the European Parliament)

15 Jan 2025 · Deep Sea Mining: Presentation for Swedish Young Greens

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and FUNDACION OCEANA and

14 Jan 2025 · Meeting with representatives of BirdLife Europe, ClientEarth, Oceana, Seas At Risk, Surfrider Foundation and the WWF Europe to present the upcoming Oceans Pact and civil society interaction.

Meeting with Carola Rackete (Member of the European Parliament)

21 Oct 2024 · Ocean health, Blue Manifesto

Meeting with Eric Sargiacomo (Member of the European Parliament) and FUNDACION OCEANA

16 Oct 2024 · PCP, accord pêche UE-Guinée Bissau

Meeting with Michal Wiezik (Member of the European Parliament) and WWF European Policy Programme and

15 Oct 2024 · Ocean Pact

Meeting with Isabella Lövin (Member of the European Parliament)

3 Oct 2024 · Criminalising Ecocide to Save Our Ocean - A panel discussion

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

3 Oct 2024 · Océan et pêche

Meeting with César Luena (Member of the European Parliament, Rapporteur) and Ecologistas en Accion

2 Oct 2024 · Microplastics

Meeting with Emma Wiesner (Member of the European Parliament) and ClientEarth AISBL and FUNDACION OCEANA

1 Oct 2024 · Lansering av rapport & panelsamtal

Meeting with Isabella Lövin (Member of the European Parliament) and Low Impact Fishers of Europe

1 Oct 2024 · Rethinking Fisheries! For Thriving Seas and Communities

Meeting with Thomas Bajada (Member of the European Parliament) and WWF European Policy Programme and

11 Sept 2024 · Introductory Meeting with Blue NGOs

Meeting with Mélissa Camara (Member of the European Parliament) and Stichting BirdLife Europe and FUNDACION OCEANA

10 Sept 2024 · Réunion de présentation de leurs travaux

Response to Ex-post evaluation of European Maritime and Fisheries Fund (EMFF) 2014-2020

5 Sept 2024

The European Maritime, Fisheries and Aquaculture Fund (EMFAF) plays a crucial role in supporting the EUs fisheries policy. However, despite its exclusion of certain activities (such as constructing new fishing vessels or increasing vessel power) and the implementation of safeguards against harmful effects, its decentralised structure allows Member States to finance activities that can be detrimental to biodiversity, and to some extent to the livelihood of fishers and coastal communities. The EMFAF provides 1.114 billion annually. Of this, between 5% and 12% (59 million to 138 million) could potentially be allocated to subsidies that harm biodiversity each year according to recent reports by WWF. Even the most cautious prediction of the amount of these potentially harmful subsidies exceeds the 53.4 million that the EMFAF can invest annually in biodiversity protection and restoration. The maximum prediction amount is 2.5 times higher, showing a clear lack of balance. Given that the primary goal of the EMFAF is to ensure the long-term sustainability of a sector reliant on a healthy ecosystem, a reallocation of funds towards protection and restoration efforts is necessary. Moreover, the EMFAF, EU fishers benefit from tax exemptions, allowing them to pay less for fuel than the general public. This reduces fishing costs and may contribute to increased fishing capacity and overfishing. In 2023 alone, the fishing industry avoided approximately 597 million in fuel taxes. Since the primary objective of EMFAF funding is to ensure the long-term sustainability of a sector that relies on a healthy and thriving ecosystem, a reallocation of funds towards protection and restoration efforts is necessary. The Fisheries Local Action Groups programme is in most cases a success. They have led to improved relationships between the small-scale fishing sector and wider local social and economic networks, helping the sector reimagine its role within local economies. In the perspective to maintain important coastal communities´ life and economic activities, this programme should be significantly reinforced. This programme should also play a central role in the development of the so-called Blue Economy and allow fishing communities, small-scale and artisanal, to adapt their activities to new challenges and activities. Finally, it is essential that the EMFAF plays a key role in decarbonising the sector hand-in-hand with a transition to low-impact fisheries and promote generational renewal. The EMFAF should not be a tool to maintain the status quo, contributing to bigger and more technologically equipped vessels that contribute to unsuitability of fish stocks and the marine environment. In her Political Guidelines presented in July 2024, President Ursula von der Leyen announced a future Ocean Pact, akin to what environmental organisations called for (an Ocean Deal). To support the implementation of an ambitious Ocean Pact, an EU Ocean Fund is needed (see attached Manifesto). This fund should be based on two components: one dedicated to measures for the long-term restoration and conservation of the marine environment, and another one dedicated to the just transition of ocean-related economic sectors towards more sustainable, fair, decarbonised and low-impact activities for the benefit of all. In addition to the establishment of this fund, subsidies which are harmful to the marine environment should be identified and eliminated as soon as possible and no later than 2027, both at the EU and Member State levels. Taxpayers money should be invested in delivering the objectives of the Ocean Deal. The revision of the EU Multiannual Financial Framework (MFF) in 2027 will be an opportunity to do so, and to increase the level of funding dedicated to the Ocean overall.
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Response to Evaluation of the Common Fisheries Policy

5 Sept 2024

Last year, the EU Commission published its report on the functioning of the Common Fisheries Policy (CFP), recognizing tangible progress towards more sustainable fishing, but stating that full and forceful implementation of the CFP is needed. Seas At Risk welcomes the Commissions initiative of evaluating the functioning of the CFP, however we are convinced that the current CFP framework is fit for purpose despite lacunar implementation by Member States and a lack of enforcement by the EU institutions regarding key provisions, such as the Landing Obligation. The objectives set out by the CFP are even more relevant now as they were in 2013. We regret that the intention, interpretation and implementation of CFP rules and targets by management and organisational structures are off target. The first objective of ensuring that fisheries activities are environmentally sustainable and ending overfishing is not achieved, too many stocks overfished or fished at an intensive MSY rate not considering discards, bycatch of sensitive species and juveniles, as well as prey/predators' interactions and wider ecosystemic considerations. The current lack of implementation and enforcement of the CFP lead to impoverishment of fish stocks, both in quantity and quality, which jeopardize the availability of food supplies. With the decrease of fishers and workers in the fishing-related sectors, the lack of implementation of the CFP is detrimental to fair standards of living for those who depend on fishing activities. Certain articles of the CFP are misinterpreted, misused or simply remain unused. For instance, the proper implementation of the Articles 11 and 17 of the CFP would solve many hurdles on the way to a just transition to low-impact fisheries, as well as a shift to fully precautionary and ecosystem-based fisheries management that respects and safeguards ecosystem integrity and dynamics and prioritises long-term ocean health. The current allocation of fishing opportunities is almost solely based on historic criteria, in an untransparent and non-objective manner. While this allocation practices help maintain stability, allowing fishers to make long-term plans and reduce uncertainties, it also perpetuates social disparities and destructive fishing practices. Solutions can be found in good uses of CFP article 17, which exist and can easily be scaled up (see attached report). Regarding incidental captures of endangered, threatened and protected species, as well as of other unwanted animals, the article 7 of the CFP and to some extend the articles 9 and 10 defining multiannual plans are well designed to address these issues. It is the lack of implementation and enforcement of their respective implementing regulations that prevent fulfilling their objectives. The recommendations listed in second evaluation report of the Technical Measures Regulation can improve the situation. Both for the fisheries sector and all stakeholders, it is important to provide policy that safeguards long term actions. New legislation from the previous mandate will shape the future of the fisheries sectors, not in the least the new Control Regulation, which complements the CFP, and the Nature Restoration Law. Reopening the CFP now would provide regulatory uncertainty regarding the application of some key provisions, which would be unfit to deliver on concrete change for fishers and the ocean before 2030. Therefore, it is not relevant to aim at overhauling the CFP but would rather be more efficient to continue investigating and identifying the core reasons for the failures and missed targets and ensure that the goals of the CFP are met with the strongest possible political will. Concrete solutions can be found in the current policy framework and the toolbox the EU Commission can use, without revising the CFP framework, its goals, and objectives.
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Meeting with Anja Hazekamp (Member of the European Parliament)

5 Sept 2024 · Seas at risk meeting

Response to Sustainable fishing in the EU: state of play and orientations for 2025

30 Aug 2024

On behalf of BirdLife Europe & Central Asia, Blue Marine Foundation, ClientEarth, Danmarks Naturfredningsforening, Deutsche Stiftung Meeresschuts, Deutsche Umwelthilfe e.V., Ecologistas en Acción, North Sea Foundation, Oceana, The Fisheries Secretariat, Sciaena and Seas At Risk, we present our response to the 2024 European Commissions public consultation on the progress towards achieving more sustainable fisheries, the state of fish stocks and the setting of fishing opportunities. This policy briefing, attached as pdf, provides analysis and recommendations to ensure the adoption of sustainable fishing opportunities that prioritise long-term ocean health through rebuilding fish populations, safeguarding and boosting ecosystem resilience in the face of mounting pressures like climate change, and fostering transparent and accountable fisheries management. All references to fishing opportunities relate to both TAC-setting in the Northeast Atlantic and Baltic Sea, as well as fishing effort restrictions in the Western Mediterranean. At a time when the ocean, and with it everyone that depends on it, faces unprecedented challenges like the climate and biodiversity crises, the Commission, the Council and individual EU Member States should urgently focus on future-proofing EU fisheries by: 1. rapidly recovering depleted and struggling fish populations; 2. generally investing in larger, healthier, more resilient and more productive fish populations; and 3. explicitly factoring ecosystem integrity and dynamics into the setting of fishing opportunities; while 4. fully applying the precautionary approach to fisheries management in the face of knowledge gaps or uncertainty, for example about climate change impacts or predator-prey interactions; and 5. fully implementing the Landing Obligation (LO) and ensuring that all catches are reliably documented and accounted for. The upcoming fishing opportunities setting cycle for 2025 is the key opportunity for the Commission, as well as the Council, to demonstrate their genuine commitment to fully precautionary and ecosystem-based fisheries management that goes beyond simply not overfishing key commercial stocks, and instead finally explicitly prioritises the rapid recovery of depleted and struggling fish populations and maximises long-term ecosystem health and resilience. We urge the Commission to consider the points covered in the attached pdf file not only in the EU's internal approach but also during negotiations with third countries such as the UK and Norway. As every year, in addition to this joint NGO response to the Commissions consultation, we will also provide further, more detailed joint NGO recommendations on TACs and quotas to feed into the TAC-setting process for 2025, and urge the Commission to consider the already public NGO recommendations on Baltic TACs.
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Meeting with Christophe Clergeau (Member of the European Parliament)

25 Jul 2024 · Protection des océans

Meeting with Eric Sargiacomo (Member of the European Parliament)

23 Jul 2024 · Tous sujets PECH

Meeting with João Albuquerque (Member of the European Parliament, Rapporteur) and SURFRIDER FOUNDATION EUROPE and Environmental Investigation Agency

9 Apr 2024 · Preventing plastic pellet losses to reduce microplastic pollution

Seas At Risk urges 75% non-price criteria for wind auctions

1 Mar 2024
Topic — The consultation seeks guidance on using qualitative criteria in renewable energy auction design.
Message — Seas At Risk recommends allocating 75% of auction points to social and environmental performance. They call for strict lifecycle analysis, material circularity, and mandatory marine habitat restoration.123
Why — This shift ensures that offshore wind expansion does not compromise marine biodiversity goals.45
Impact — Price-focused bidders lose their advantage as environmental criteria take precedence over cheap energy.67
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Seas At Risk (SAR) welcomes this opportunity to provide input to the development of guidelines for mapping acceleration areas for renewable energy. Our input focusses on guidelines for offshore renewable energy (ORE) and draws on our paper Planning offshore renewable energy with nature in mind - Seas At Risk (seas-at-risk.org) https://seas-at-risk.org/publications/planning-offshore-renewable-energy-with-nature-in-mind/. This paper sets out guiding principles for offshore renewable energy planning at regional (sea basin) and national levels, aligned with key EU objectives for biodiversity restoration and nature protection. SAR members also contributed case studies for Denmark, Sweden, Portugal and the Netherlands.
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Meeting with Virginijus Sinkevičius (Commissioner) and

19 Feb 2024 · NGOs presented to the Commissioner their Manifesto: An Ocean of Change 2024, and in particular the idea of an Ocean Deal

Meeting with María Soraya Rodríguez Ramos (Member of the European Parliament) and Ecologistas en Accion

14 Feb 2024 · Discuss the proposed Regulation on preventing plastic pellet losses to reduce microplastic pollution

Response to Correction to the multiannual programmes for fisheries

31 Jan 2024

On December 6, 2023, the European Commission has unexpectedly proposed the removal of Article 4(6) from the Baltic and North Sea Fisheries Multi Annual Plans (MAPs) and Article 4(7) from the Western Waters MAPs. These articles concern a safeguard for fisheries management in those sea basins, stipulating that fishing opportunities must be set to maintain a less than 5% probability of the spawning stock biomass falling below the reference point, Blim (referred to as the '5% rule'), endangering their ability to replenish. In essence, the Commission's proposal seeks to eliminate a vital safeguard that prevents fish stocks from collapsing. Seas At Risk is highly concerned about the Commissions proposal, as it contradicts the precautionary approach which is a cornerstone of the EUs policymaking. The European Commission's proposal deviates from the original regulations' purpose of ensuring adequate safeguards to prevent fish stocks from dropping below critical limits. Seas At Risk considers essential that "Blim" should always function as a strict limit to ensure proper management of fisheries. Clear and legally-binding safeguards, including obligations to temporarily halt targeted fisheries, are necessary to ensure thriving marine ecosystems. We disagree with the assertion that the safeguards and remedial measures in other articles of the MAPs are enough to prevent fish stocks from reaching critical levels. Removing Articles 4(6)/(7) would eliminate a safety net that ensures reduced fishing opportunities when a stock faces a high-risk of collapse. The MAPs would lack a concrete element prevent such high-risk scenario, and only focus on drastic measures to be put in place after the spawning stock biomass has already reached a critical point. If implemented, this proposed revision of the MAPs will increase the likelihood of continued depletion in fish population, and in turn of stocks collapsing. The adverse consequences will impact not only the livelihoods of fishermen and related industries but also the communities they are part of, and, significantly, the health of the marine environment and ecosystems. The absence of an environmental impact assessment on the Commissions proposal raises the concern that the long-term impact on marine ecosystems has not been properly taken into account. Prior to any change to the MAPs, we ask of the Commission to present a comprehensive assessment of environmental impacts arising from the proposed changes. The Commission's proposal follows the Council's 2024 fishing opportunities for the Baltic, which already breached this legal safeguard. The Baltic Sea ecosystem is in a critical state, with major commercial fish stocks facing collapse or already collapsed. In light of this, it is crucial for EU decision makers to enforce existing laws and manage Baltic Sea fisheries sustainably to support the restoration of fish stocks. Similarly, fish stocks in the North Sea and Western Waters are severely depleted due to consecutive years of overfishing. The deletion of these crucial safeguards raises concerns about the sacrifice of the health of our marine ecosystems and about the possibility to retroactively legalize a potentially unlawful Council Regulation. Seas At Risk also regrets the lack of prior stakeholder consultation on the proposal before its publication. This limited feedback period raises strong concerns about the effectiveness of the consultation process, especially since co-legislators have already started discussions or agreed on a position before this feedback period concludes. This rapid consultation brings much uncertainty about how inputs from stakeholders will be properly taken into account in such an important change of the EUs fisheries regulations.
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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 Environmental Justice Foundation

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

Meeting with Caroline Roose (Member of the European Parliament, Shadow rapporteur) and International Fund for Animal Welfare

13 Nov 2023 · Plan d'Action ressources halieutiques et écosystèmes marins

Meeting with Emma Wiesner (Member of the European Parliament) and Climate Leadership Coalition

9 Nov 2023 · Moderator Renew Civil Society Day: Workshop Climate & Environment

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

20 Sept 2023 · Nature Restoration Law

Meeting with Pierre Karleskind (Member of the European Parliament) and FUNDACION OCEANA and

11 Jul 2023 · écosystèmes marins

Meeting with Pierre Karleskind (Member of the European Parliament) and European Association of Fish Producers Organisations

29 Jun 2023 · écosystèmes marins

Meeting with Caroline Roose (Member of the European Parliament, Shadow rapporteur for opinion) and European Association of Fish Producers Organisations

29 Jun 2023 · Conférence SEArica "La dimension marine de la Loi sur la Restauration de la Nature"

Response to European Critical Raw Materials Act

22 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 (see attachment). This reflects a growing body of scientific evidence stresses how deep-sea mining would entail large-scale and irreversible loss of biodiversity in the deep seas through destruction of species, habitats and ecosystems. This also includes concern 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 DSM. Including the extraction of mineral occurrences under water, which essentially means seabed mining, within the scope of the CRMR, also goes against the position repeatedly expressed by 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, it is urged that an explicit exclusion of deep-sea mining is incorporated to the future CRMR. Finally, as the EASAC Statement on Deep Sea Mining reiterates, deep-sea mining on any scale should not be considered until recycling potentials have been fully explored. While the proposed CRMR 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, it is suggested that: - An explicit exclusion of deep sea mining is included in Recital 19 or in a new item, with reference to the and 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 CRMR, or, alternatively, add but excluding 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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Seas At Risk demands stricter tracking for recycled plastic content

25 May 2023
Topic — Commission initiative defining common rules for reporting recycled content in plastic beverage bottles.
Message — Seas At Risk wants calculations based on total bottles sold, including those littered. They demand mandatory third-party certification for all operators to ensure chemical and physical traceability.12
Why — Stricter rules would verify environmental claims and protect the reputation of European recyclers.34
Impact — Importers and low-standard manufacturers would lose the ability to use unverified recycling claims.5
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Seas At Risk urges stronger marine standards in EU Taxonomy

14 Apr 2023
Topic — EU initiative defining sustainable investment criteria for water and biodiversity protection.
Message — The organization requests a direct reference to the Marine Strategy Framework Directive within the taxonomy's technical standards. They argue this directive is the overarching legislative framework for protecting the marine environment in the EU.12
Why — This would ensure financial rules align with the primary legislative framework for ocean health.3
Impact — Marine industry developers would face more rigorous criteria for their activities to be labeled sustainable.4
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Meeting with Caroline Roose (Member of the European Parliament)

6 Mar 2023 · Conférence Exploitation Minière des Grands Fonds - Intergroupe SEArica

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

27 Feb 2023 · Nature Restoration Law

Meeting with Virginijus Sinkevičius (Commissioner) and

20 Feb 2023 · To explain the “Fisheries and Oceans “ package adopted during that week: CFP Communication, Marine Action Plan and Decarbonisation Initiative.

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Environmental Coalition on Standards

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Environmental Coalition on Standards

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and Environmental Coalition on Standards

18 Jan 2023 · Green Deal implementation on the fight against microplastic pollution

Meeting with Margrete Auken (Member of the European Parliament) and Environmental Coalition on Standards

13 Jan 2023 · Microplastic in EU law

Response to Energy transition of EU fisheries and aquaculture sector

5 Dec 2022

SAR welcomes the initiative to develop a strategy and roadmap for a much-needed energy transition of the EUs fisheries and aquaculture sector. If done in the right way the energy transition of the fishing sector can be an important puzzle piece and opportunity to transition the fishing fleet towards a climate-resilient and ecologically sound economy that puts the long-term wellbeing of the environment and fishers at its core. Many tools already exist within legal frameworks like the CFP to decarbonise the fishing industry towards net zero by reducing fuel use, fleet overcapacity and carbon-intensive fishing methods. This strategy should therefore be well aligned with ongoing and upcoming EU initiative like the EU Green Deal, fit for 55 climate package and the Action Plan to conserve fisheries resources and protect marine ecosystems as well as the Farm to Fork Strategy and the upcoming Sustainable Food System Law and make use of tools already in place. The fishing industry, including the entire supply chain needs to contribute to the EUs climate objective and should reduce its carbon footprint and introduce alternative sources of sustainable renewable energy. The energy transition of the fishing sector needs to be aligned with an overall necessary and just transition towards low-impact fishing. The marine environment is one of our biggest allies in fighting human-induced climate change and biodiversity loss. Overfishing and destructive fishing have been the main driver for biodiversity loss for the last 40 years and critical undermine the resilience of marine wildlife including fish to climate change and hinders the marine ecosystems ability to sequester carbon and mitigate climate impacts. Mobile bottom-contacting fishing gears have a particular high fuel consumption and climate impact and are adversely impacting carbon-rich seabed habitats impacting their ability to sequester carbon. Therefore, passive gears and more local forms of fishing (which reduces the fuel consumption) should be prioritised. -This includes allocating fishing quotas to small-scale, low impact fisheries by better implementing Art 17 of the CFP by using environmental, social and climate criteria including the carbon footprint per unit catch, and the impact on blue carbon habitats and other marine carbon storages including the seabed. -Harmful fisheries subsidies that keep afloat the fleet segments with the highest carbon footprint need to be eliminated. The ongoing review of the ETD can incentives the energy transition by removing the fuel tax exemption that contribute to skewed competition by providing substantial support to fuel-intensive bottom trawling fisheries and leaving passive fisheries at a relative disadvantage. -Destructive fishing gears should be prohibited to safeguards fisheries and biodiversity (incl. carbon-rich habitats) and strengthen the oceans resilience to climate impacts. This includes prohibiting destructive bottom-contacting gear in MPAs, sensitive coastal areas and over known VMEs. -Prioritise existing technology to decarbonise fishing vessels. The EMFAF should be used to test solutions and support the transition to sustainable and low-carbon fishing. -Fishing vessels should be switching to MGO with distillate filters in the short term, while cleaner renewable energy for propulsion (incl. wind and batteries) are deployed. -High efforts should be placed to reduce energy demand onboard of fishing vessels and along the entire supply chain by implementing initiatives to slow vessels down to reduce energy consumption. -The upcoming Sustainable Food Systems Law should consider the energy and carbon impact of sea food production and facilitate the transition to low impact, carbon neutral aquatic food systems through consumer incentives (e.g. labelling) and sustainable, localized supply chains. That should include alternatives to industrial fisheries, such as algae permaculture (ocean farming) and low impact aquaculture
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Response to European Critical Raw Materials Act

24 Nov 2022

Seas At Risk comments: On deep-sea mining: Deep-sea mining (DSM) should be explicitly excluded from the scope of the proposed Critical Raw Materials Act (CRMA), including explicit exclusion from the definition of strategic projects. Exclusion of DSM is coherent with a number of decisions by the Commission, European Parliament and other EU institutions, including the Joint Communication on the EUs International Ocean Governance agenda (JOIN(2022)28) that calls for a ban of DSM or the European Parliament resolutions of 9 June 2021 on the EU Biodiversity Strategy for 2030 (2020/2273(INI)) and of 6 October 2022 on momentum for the ocean (2022/2836(RSP)), both calling upon the Commission and MS to support an international moratorium on DSM. Furthermore, the European Investment Bank, in its EIB Eligibility, Excluded Activities and Excluded sectors list has explicitly listed DSM 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, both excluding DSM from the definition of a sustainable ocean economy. A growing body of scientific evidence stresses how DSM would entail large-scale and irreversible loss of biodiversity in the deep seas through destruction of species, habitats and ecosystems. This also includes concern 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 DSM. The oceans are the planets main carbon sink, capturing a quarter of CO2 emitted by human activity (some 2 billion tonnes per year) and also locking away methane. The disturbance of the seabed could contribute to the release of carbon sequestered for millions of years, and interfere with the carbon pump, thus contributing to climate change while suppressing or limiting the capacity of carbon-fixing organisms such as phytoplankton and compromising existing absorption capacity. Additionally, underwater hydrothermal vents play a key role in regulating climate and ocean geochemistry. Their disturbance could affect the amount of nutrients available, with potential effects for the marine food chain. Comments on raw material demand: The EU has a substantial share of responsibility for growing global metal demand, using up 20% of global mineral production for less than 10% of the worlds population. While Commissioner Thierry Breton has stated (in relation to the CRMA) that the cheapest and cleanest raw material is the one we dont use, the call for evidence makes no single reference to reducing demand as a keystone component of raw materials policy. The Intergovernmental Panel on Climate Change (IPCC) 2018 Global Warming of 1.5°C special report warned that the only viable way ahead was for rich countries to decisively cut their rates of material production and consumption; the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), the International Resource Panel (IRP) and the European Environment Agency reached similar conclusions, with the later stating in its Growth without economic growth briefing that political initiatives for a sustainable future require not only technological change but also changes in consumption and social practices. Therefore, the CRMA 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, shifting its priority from economic growth to meeting peoples needs without overshooting Earths ecological limits.
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Meeting with Caroline Roose (Member of the European Parliament)

10 Nov 2022 · Deep-Sea Mining (assistant·e·s)

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

14 Oct 2022 · Implementation of the EU Biodiversity Strategy for 2030 and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and

14 Oct 2022 · Implementation of the EU Biodiversity Strategy for 2030 and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Meeting with Anthony Agotha (Cabinet of Executive Vice-President Frans Timmermans)

30 Sept 2022 · Black carbon risk

Meeting with Caroline Roose (Member of the European Parliament) and ClientEarth AISBL and

21 Sept 2022 · Loi européenne sur la restauration de la nature

Seas At Risk Demands Binding Targets for Marine Restoration

22 Aug 2022
Topic — The EU is proposing legally binding targets to restore nature and biodiversity.
Message — The group demands binding deadlines, numerical targets, and an immediate ban on active bottom-contacting fishing gear. They also call for the strict protection of all seagrass meadows by 2030.123
Why — Healthy marine ecosystems would boost climate resilience and sequester millions of tons of carbon.45
Impact — The commercial fishing industry would face significant operational restrictions and a phase-out of subsidies.67
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Seas At Risk: Protect Marine Habitats from Renewables Expansion

27 Jul 2022
Topic — The Commission is developing guidance to speed up permitting for renewable energy projects.
Message — Seas At Risk demands a ban on wind farms in protected marine areas. They advocate for reducing energy demand through economic and lifestyle changes.12
Why — This approach secures the NGO's primary goal of preserving marine wildlife habitats.3
Impact — Renewable energy developers face restricted access to offshore sites and slower permitting timelines.4
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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 Catherine Chabaud (Member of the European Parliament) and FUNDACION OCEANA

28 Jun 2022 · UN conférence sur l'océan

Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and FUNDACION OCEANA

19 May 2022 · Nature Restoration Law and the Action Plan on marine ecosystmes.

Response to Improving environmental protection through criminal law

21 Apr 2022

Seas At Risk (SAR) welcomes the possibility to provide feedback to the proposal of the revised Environmental Crime Directive for improving EU rules on environmental protection through criminal law. SAR supports the main elements of the proposal and in particular welcomes the inclusion of the killing of and trade in protected wildlife species among the conducts that constitute a criminal offence. SAR would like to highlight the following important aspects of the proposal that should be improved focusing on fisheries and seafood markets: - The Directive will be reliant upon legislative amendments in the future, every time the EU environmental law acquis is extended. Recital 10 states that the Directive will cover any updated or amended relevant Union legislation and that it should be amended in order to cover new legal instruments prohibiting conducts harmful to the environment. However, it is not clear how this could happen in a systematic and effective way, in order to ensure that new categories of criminal offences are promptly included in the scope of the Directive. For instance, thresholds for underwater radiated noise pollution are being proposed under the Marine Strategy Framework Directive: once adopted, serious breaches of these thresholds should be promptly added to the categories of criminal offences under Art3.1(h). - The proposed system still relies upon a list of secondary legislation and lacks a general definition of what constitutes an environmental crime. - The scope should be extended to cover also the most serious infringements of illegal, unreported and unregulated fishing and the introduction of energy like acoustic emissions into the marine environment when this causes or is likely to cause substantial harm to marine animals. As underwater radiated noise (URN) may involve deleterious effects to aquatic life, and it is considered pollution according to several internal bodies and agreements (including IWC, IUCN, UNCLOS, UNGA) and under the Directive 2010/75/EU and the EU Marine Strategy Framework Directive, this needs to be covered by the Environmental Crime Directive. - The revised Directive should take into account the legislative work underway regarding the revision of the Regulation no 1224/2009 and the Regulation no 1005/2008. In the interest of general legislative consistency, it is crucial that amendments of the Directive are consistent and aligned with the revised European legislation in the area of the Common Fisheries Policy as well as the inclusion of serious infringements to the CFP rules in Article 3 of the Directive. - Concerning aggravating circumstances: these should include offences which cause destruction or irreversible or long-lasting substantial damage to the conservation of populations or protected wild animal species. - Concerning enforcement: Statistical data gathered at Member State level should be made public in its raw form rather than via consolidated reviews.
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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

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and FUNDACION OCEANA and Our Fish

16 Mar 2022 · Discussion on EU nature restoration law and action plan to conserve fisheries resources and protect marine ecosystems

Meeting with Virginijus Sinkevičius (Commissioner) and

22 Feb 2022 · A regular meeting with NGO to discuss various fisheries matters: 2022 TAC setting, upcoming new Commission initiatives, WTO negotiation, cetaceans by-catch in the Bay of Biscay and in the Baltic Sea, control regulation negotiations etc.

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

15 Feb 2022

Seas At Risk welcomes this opportunity to provide feedback to the Commission’s initiative to update the international ocean governance agenda. Our global ocean is the life support system of our planet. A healthy and resilient ocean is critical to address our combined nature, climate and biodiversity crisis. Implementing ocean solutions at a global level could account for up to one fifth of the emissions reductions needed to limit global warming to 1.5°C. In recognition of this UNFCCC COP27 provides an opportunity to set more ambitious climate plans which include the ocean. However, over-exploitation of ocean resources risks overriding environmental and climate concerns, as the global push for growth of the blue economy is leading to ever more human activities at sea. A strong and coordinated international governance is therefore essential to keep human activities such as fishing, resource extraction and shipping within environmental limits, and to move away from endless growth. Please find further details and our recommendations in the attached file.
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Response to Measures to reduce microplastic pollution

16 Dec 2021

HORIZONTAL RECOMMENDATIONS ● Legal base should be article 192 of the TEU, not 114 ● Not accurate to say that tyres textiles and pellets account for ⅔ of the total: Eunomia did not study all MP sources ● All economic sectors are both a source and a solution to microplastic pollution. An integrated approach is needed with complementary measures across all responsible sectors ● Secondary microplastics should be addressed for significant sources (see below) ● Third goal under A should be to mandate the monitoring of MP pollution using indicators such as sediment, biota, water, soil and air rather than agreeing on harmonised measuring ● Prevention at source should be preferred to downstream mitigation measures ● The EU also needs to address toxic additives and the ability of microplastics to generate nanoparticles FOR SPECIFIC SOURCES Textiles • Minimum eco-design requirements for textiles, setting a maximum loss threshold and criteria to select the best performing fabrics at the design stage • Limit microplastic release throughout the lifecycle and assess the environmental impacts of particularly problematic manufacturing techniques: cutting, dyeing and 3D printing • Mandate industrial pre-washing of new textiles and garments and the use filters to capture microplastics released throughout the manufacturing process • Ensure that washing and drying appliances for domestic and industrial use are equipped with filters • Incentivise investment in upstream solutions vs unsustainable chemical recycling Tyres • Reduce road transport (passenger and freight) and speed to limit microplastics release at source • Introduce mandatory threshold limits for microplastic release from tyres • Need to broaden the scope of measures to address additional sources such as brake pad dust and road abrasion with specific prevention steps • Investigate the environmental impacts of recycled tyre use (e.g. in road asphalt and school playgrounds) and prohibit the use and storage of tyres underwater or in the open environment Pellets • Mandate the implementation of handling, storage and transportation best practices for the whole plastic supply chain, with yearly staff training to prevent pellet loss, as OCS has no obligation for signatories to take effective prevention steps • Ban the use of plastic granules, flakes or pellets in the open environment (school playgrounds, sports pitches) • Mandate the containment of all pellet handling sites (plastic production and recycling facilities) Agriculture / Soil protection • Phase out the use of synthetic polymers and of intentionally added microplastics in agriculture and horticulture • Develop measures to secure an adequate maintenance and the use of toxic free geotextiles • Promote sustainable alternatives to plastic mulch and other soil-polluting microplastics such as synthetic geotextiles • Set reduction targets for microplastic release from effluent and by-products (fat, sludge) of WWTP and regulations to achieve zero emissions of microplastics in the longer run Shipping industry • Regulate to prevent overloading of cargo ships and mandate the storage of pellet containers below deck • Regulate the release of microplastics in greywater for all ships Fishing / aquaculture • Monitor microplastics in wild and farmed fish and seafood • Mark and track fishing gear to disincentivise discarding and mandate the reporting of lost gear to public authorities • Promote ecodesign for fishing gear with low impact and durable materials Packaging • Phase out synthetic foam polymers which release microplastics throughout their lifecycle • Set targets and promote packaging-free options to reduce overpackaging in consumer products and delivery services Wastewater • Legislate to ensure that buildings have microplastic filtering systems installed between the greywater and sewage systems • Include biomedia in the scope of study and introduce binding obligations for the wastewater treatment sector to prevent their spills
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Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and FUNDACION OCEANA

2 Dec 2021 · To discuss Nature Restoration Law and marine aspects

Meeting with Virginijus Sinkevičius (Commissioner) and

29 Oct 2021 · To discuss with the NGOs the perspectives for the 2022 annual fishing opportunities ahead of international consultations and the December AGRIFISH Council.

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.

Response to Non-compliance cases and serious non-compliance cases with Common Fisheries Policy rules by Member States under EMFAF

23 Aug 2021

We welcome the opportunity to provide feedback on this draft implementing act (IA). We expected it to clarify as much as possible the rules set out in the EMFAF regulation. As it stands, however, several grey areas remain, making this provision difficult to implement or inapplicable in the future. Triggering of the procedure: we consider that the interruption/suspension of a payment is a tool that can be extremely effective, capable of dissuading Member States (MS) from maintaining situations of non-compliance, or strongly encouraging them to remedy such situations, in the same way as the compliance tools provided for in Title XI of Regulation 1224/2009. It would therefore be normal for an interruption of payment to be triggered at the very moment when the Commission has identified situations of non-compliance that are sufficiently significant to open a pre-litigation procedure against a given MS, as it is not normal for a MS to receive money from European public funds to implement the CFP when there is an identified non-compliance situation concerning its implementation. We therefore encourage the Commission to refer to Title XI of Regulation 1224/2009 and to clearly specify when such a procedure may be triggered, in order to give it full effect. Severity criteria: Articles 42.3 and 43.3 of the EMFAF Regulation provide that interruption/suspension shall be proportionate to the "nature, severity, duration and repetition of the non-compliance". However, the draft IA gives no indication as to the possible definition and application of such criteria. While we understand that a case-by-case analysis must be carried out to take into account certain specific contextual elements, this leaves considerable room for manoeuvre in the interpretation of these criteria and their use, and undermines legal certainty. As it stands, it is impossible to know at what point the Commission will consider that a situation of non-compliance may justify the initiation of such a procedure. There is a serious risk of never being able to trigger these procedures without provoking objections that the criteria mentioned have not been fulfilled. We invite the Commission to specify in greater detail what is meant by the criteria mentioned in the EMFAF regulation, articles 42 and 43. Deadline for a MS to submit information on the situation of non-compliance: Articles 42.2 and 43.2 of the EMFAF Regulation provide that a MS concerned has a reasonable time to respond and submit information. This time limit is vague and needs to be specified in the IA in order to avoid lengthy procedures jeopardizing the application of the provisions of the EMFAF Regulation, since triggering the interruption or possible suspension of a payment linked to an irregularity when this payment has already been made would make this procedure ineffective or at least unnecessarily complicated (leading to calculations of reimbursements, etc). Transparency of the solutions implemented by the MS to remedy cases of non-compliance: Article 2 of the draft IA does not define the rules governing the resolution of a situation of non-compliance, i.e. the rules which make it possible to establish/conclude that such a situation is no longer problematic and will therefore not lead to the suspension of a payment. It is also necessary to define transparency rules regarding the publication of concrete solutions (actions and deadlines for implementation) put in place by the State targeted by an interruption procedure. Effective interruption/suspension of payments: we consider that this should apply to the EU contribution allocated to the EMFAF specific objectives related to the cause of the non-compliance, and not to the effects of non-compliance (e.g., environmental objectives). The cases of non-compliance referred to in Article 1: please find attached a document with additional suggestions to the Annex of the draft IA.
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Meeting with Virginijus Sinkevičius (Commissioner) and

13 Jul 2021 · To exchange views with the ‘’blue’’ NGOs on the upcoming Action Plan on sustainable fisheries and protection of marine resources, annual exercise of fixing total allowable catches and ongoing WTO negotiations on fisheries subsidies.

Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

17 Jun 2021

The objective of Article 9 SUPD is the separate collection of plastic bottles in order to ensure that they don’t end up in the open environment. Putting an end to plastic pollution of SUP products is one of the main parts of the Plastic Strategy’s vision. Furthermore, a high-quality bottle-to-bottle recycling is necessary in order to reach the recycled content target of 30 percent, the successful implementation of which will also be a decisive first step towards the recycled content targets announced in the CEAP. Therefore, although the SUPD not only allows for separate collection through DRS, but also other collection modes together with other recyclables, the term “separate collection” should be defined as strictly and precisely as possible. Any weakening of the definition can drastically undermine the core objectives Article 9 had in the first place. Thus, we recommend the draft Implementing Act should be adapted so that: • It clearly defines strict requirements for the quality of the material, even if it is collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible: SUP bottles should be collected in a way that allows for recycling into food-grade material. In a previous draft version of the Implementing Act, this requirement for foodgrade quality was mentioned explicitly. We think that it would be important to make this quality aspect very clear again. At the moment, the requirements are not explicit enough and allow for loopholes. It should be stated very strictly that bottles should not be collected with hazardous waste/contaminated materials, and such a requirement should also not be controlled by industry itself, but by an independent body. • A collection with the residual waste, mixed waste, black bin, etc. should be explicitly ruled out from being counted as separate collection of SUP bottles for recycling. This point should be made absolutely clear by naming all those terms explicitly in the Implementing Act, and not leaving this point ambiguous in any way. Bottles recovered from waste-splitting of residual waste could otherwise be counted as separately collected. Their quality will however be low, and the Implementing Act should not support modes of collection that do not reach 90 % collection rate with the specific system set up for separate collection, but where bottles from waste-splitting would have to be calculated in. • The definition of separate collection should be aligned with what the Waste Framework Directive defines as separate collection, otherwise this could set a precedent for future deviation, to the detriment of the environment. Article 3(11) of the Waste Framework Directive defines separate collection as a procedure “where a waste stream is kept separately by type and nature so as to facilitate a specific treatment”. Despite this very clear definition, there have been ongoing discussions among certain stakeholder groups on whether SUP bottles that have been pulled out of the residual/mixed waste can be added to the number of separately collected SUP bottles, in order to reach the separate collection targets set in Article 9 SUPD. Especially in the light of the comprehensive measures to prevent waste and promote recycling that are envisioned within the Green Deal and the Circular Economy Action Plan, the SUPD should be leading the way to strict and consequent legislation, the purpose of which cannot be undermined by ambiguous definitions. SEAS AT RISK and its European member organisations are very concerned about this article, as it is very important to protect our environment from plastic littering: plastics that contains hundreds of unknown substances with absolutely unknown effects on human health and remains in the environment for hundreds of years. We support strongly the joint NGO Position Paper coordinated by our partner Reloop. Please see attached the detailed position of the Rethink Plastic Alliance we are an active member of.
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Response to Action plan to conserve fisheries resources and protect marine ecosystems

12 May 2021

No matter where you are, you depend on the ocean and its unique and rich biodiversity for the production of oxygen, food, energy, and the enormous amount of heat and carbon it absorbs. Yet, none of the European seas are healthy, and fishing remains the biggest driver of marine biodiversity loss. The EU already has a comprehensive body of policy and legislation aimed at protecting the marine environment, but they are not being implemented. The current challenges and the ambition set out in the European Green Deal and the Biodiversity Strategy will not be met by 2030 without bold and courageous steps, starting from 2022. To improve the health of marine ecosystems, deliver climate action and create a lasting legacy for future generations, the Action Plan must address the restructuration of the EU fleet and fisheries footprint to address the impacts of destructive fishing gear (particularly bottom-towed gear), mitigate the ecosystem and climate impacts of fishing, and put European fisheries on a path of adaptation to the climate emergency. This should complement and articulate other EU policies, such as the future restoration law, the fisheries technical measures regulation and the Marine Strategy Framework Directive. The EU seabed is the most bottom-trawled in the world, more than five times the global average, and 80% of EU coastal areas are disturbed by trawling. Bottom-towed gear is widely used in the EU, including in sensitive coastal areas and even inside Marine Protected Areas (MPAs), with some studies indicating a higher intensity of trawling inside than outside designated areas. Achieving the 2030 objectives for seabed integrity, protection and restoration of all marine habitats requires action in the short term. To start with, the Action Plan must make a strong political statement that all bottom-towed fishing must end inside MPAs and other sensitive areas immediately, while preventing the increase of bycatch of sensitive species caused by other types of fisheries. It should also commit to set a clear target for the reduction of all bottom-trawling by 2025 at the latest. Furthermore, fishing remains the greatest threat to the survival of protected and sensitive species. Mitigation of bycatch must be addressed as a matter of urgency to preserve marine biodiversity in EU waters. Therefore, the Action Plan must include the political commitment to eliminate bycatch of sensitive species through mandatory introduction of remote electronic monitoring, clear guidance on mitigation measures for each sea basin evaluated by scientific bodies, and national action plans. Finally, a central pillar of the Action Plan must be to eliminate the threat that overfishing poses to the critical role the ocean plays in regulating the climate and serving as a carbon sink. Enshrining a just transition to low-impact, localised fisheries and value chains will have far-reaching positive impacts on ocean health, the climate and our coastal communities. The Action Plan is a timely opportunity to fill policy gaps and realise our moral obligation to ensure EU fisheries adapt to changing circumstances and comply with our climate laws and international biodiversity commitments by 2030. More than 100 environmental NGOs have summarised the key actions that must happen in this regard in the Blue Manifesto, whose focus is broader than fisheries, but serves as roadmap to deliver healthy European seas in 2030. Acting with urgency on these key measures will deliver multiple benefits in terms of climate resilience, biodiversity protection, food provisioning, job security and healthy coastal communities. We only have eight years. Please find in the attachment a detailed and illustrative timeline proposed by environmental NGOs for the EU Action Plan.
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Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

The MSFD is the cornerstone of EU marine policies to protect and preserve EU seas, centred around an ecosystem approach and the objective to achieve Good Environmental Status (GES) through national marine strategies. It is the key piece of EU marine legislation and important reference at national, regional (e.g. in regional sea conventions such as OSPAR) and international level. Any review of the text should strengthen its provisions and their implementation. However, despite more than 10 years of implementation, the main objective of the MSFD - GES of EU seas by 2020 - has not been reached. That’s mainly due to poor ambition from member states and competing sectoral economic interests (in particular from the fishing industry), which undermines the overarching goal of preserving our seas (cf. European Court of Auditors Special Report: Marine environment: EU protection is wide but not deep). The European Commission tacitly accepted this lack of ambition, while people and nature pay the price of continuing degradation of our seas. There is an urgent need for greater marine policy coherence, which has to be built on the respect of planetary boundaries indicated by the Good Environmental Status of our seas, and characterised by a just transition to a political economy that centres wellbeing of people and planet instead of unlimited economic growth. To that end, the MSFD must be strengthened, by developing complementary approaches, such as targeted new legislation, the development of delegated and/or implementing acts, or enhanced implementation tools. Importantly, legal action (including infringement procedures) must be taken to ensure that Member States apply the law. We therefore urge the European Commission to use all existing legal tools to improve the implementation of the Directive, and to align other initiatives with the MSFD and the objective of good environmental status and a healthy ocean, such as the Sustainable Blue Economy agenda, the Zero Pollution Action Plan, the EU Action Plan to conserve fisheries and protect marine ecosystems and the future EU restoration law, which could help to tackle ocean-based pressures such as destructive fishing in marine protected areas and strengthen the ocean’s resilience as well as its role in mitigating climate change. We recognise the weaknesses of the Directive on implementation, and lack of capacity in MS to ensure achievement of MSFD objectives. However, as stated by the EC in its implementation report, we believe that it is up to the MS and EC to deploy the necessary capacities to ensure that EU seas reach GES by allocating sufficient resources and ensure effective implementation of the MSFD by providing better guidance. The primary goal and scope of a review should be to reach GES in EU waters as soon as possible. A revision of the MSFD, even targeted, is a lengthy process and carries the risk of causing further delays and failings in implementation, as it may be used as an excuse or opportunity to do nothing or very little until the revision is concluded. Furthermore, any attempt to simplify and reduce the administrative burden for MS must not result in a lowering of the overall level of ambition of the MSFD. Therefore, Seas At Risk as the umbrella organisation of over 30 organisations committed to defending the ocean and representing millions of EU citizen, supports the strengthening of the implementation and enforcement of the Directive without changing its provisions, as outlined in option 3 of the roadmap. Above all, stronger political will and ambition is needed in order to achieve the objectives of the MSFD. The EC should use all possible legal pathways to improve and promote the implementation of the Directive without reopening it.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and FUNDACION OCEANA and Funding Fish

17 Mar 2021 · EU 2030 Biodiversity Strategy and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and FUNDACION OCEANA and Funding Fish

17 Mar 2021 · EU 2030 Biodiversity Strategy and the preparation of the Action Plan to conserve fisheries resources and protect marine ecosystems

Response to Revision of EU Programme for biological, environmental and socio-economic data collection in fisheries and aquaculture

15 Mar 2021

Seas At Risk response on Fisheries data collection There is a lack of data on the impact of fisheries on the marine environment, including on bycatch of sensitive species, and existing data are not statistically robust and reliable. This hinders the ability to assess the impact on the marine environment and consequently to define, apply and monitor appropriate mitigation measures and rules. Reliable, robust data obtained from monitoring programmes and frameworks, that cover an adequate percentage of the fishing fleet are urgently required. Therefore, the Delegated Decision should include the following: 1)All vessels fishing within and outside Union waters are required to record their (by)catches at all time electronically in logbooks including data on the impact on marine biological resources and ecosystems. Therefore, electronic logbooks must include a dedicated field to record sensitive and protected species bycatch (incl. marine mammals, seabirds, turtles, sharks, VMS, corals, and all protected species under EU and international law applicable to the EU) including those released alive, in sufficient detail to allow for proper impact assessments and the calculation of bycatch rates. The information recorded in the electronic logbooks should include: • Number of individuals, • Species, • Time, date of occurrence, • Information about the individual (size, a picture, if the individual was released alive, etc.) • Information on how the individual was captured (gear type, during setting, hauling, etc) • Any feature that might have triggered the catch (type of bait, season, time, depth, etc.) Furthermore, the fishing effort per métier must be recorded to allow for the comparable estimation of the environmental impact of the fisheries. This should be done in meaningful units (e.g., net length combined with soaking time for static nets; number of hooks for longlines). Tracking of all vessels, including small-scale vessels must be implemented to understand the impact of fisheries on the marine environment. 2)Data collected via logbooks needs to be verified via supplementary, independent means of data collection (Ref: Report Workshop on Remote Electronic Monitoring with Regards to Bycatch of Small Cetaceans, October 2015). Therefore, adequately trained independent observers need to be deployed onboard of vessels in a representative manner to allow for robust estimates on actual bycatch rates, the potential mortality of sensitive species and the wider impact on marine ecosystems. Where safety, operational or other concerns prevent a vessel from accepting an observer on board, Remote Electronic Monitoring Systems (REM), including CCTV, must be used for the collection of independent data. The cameras should be appropriately placed, including over the side of the vessels where the gear is hauled, to ensure the detection of individuals that fall out of the nets before they reach the deck. Fishers and onboard observers should obtain sufficient and adequate training, including on the identification of species. The data collection by observers and Remote Electronic Monitoring should cover a sufficient high percentage of fishing effort to ensure representative, reliable, and accurate data to ensure robust estimates of bycatch rates and impact on the marine environment. The required levels of coverage need to be adapted to the characteristics of the fisheries and especially cover all fleet segments and métiers where there is a risk of bycatch, or where there are insufficient data to assess the risk. 3)The data collection on marine biological resources and marine ecosystems should follow a standardised collection methodology adopted at the regional level, to ensure that the data are comparable and harmonised (e.g. http://www.fao.org/gfcm/data/vulnerablespecies). Furthermore, it is vital that the collected data are freely available and accessible for public use and that the data collection process is transparent.
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Meeting with Virginijus Sinkevičius (Commissioner) and

12 Feb 2021 · To discuss different blue/marine related issues, in particular bycatch emergency measures, EU-UK negotiations and implementation of the Biodiversity Strategy.

Response to Towards a strong and sustainable EU Algae sector

14 Jan 2021

Algal farming in Europe should follow an eco-system-based approach and be in line with the natural carrying capacity of the areas designated for this economic activity, to allow its potential to unfold of being both environmentally beneficial and profitable. Input regarding option 2: 1. Only native species should be farmed – introduced macroalgal species have become invasive in numerous locations around the world, and it is important that non-native species – even those which have already become established in European waters – are not given the opportunity to spread further and become invasive pests. 2. In open-water farming in the ocean, or if the farm has water exchange with the ocean, seaweeds in farms should to as large extent as possible be based on native genetic material from the area in question. This is important to ensure continued genetic diversity of the species in the farm area, which will minimise the risk of detrimental effects on local algal habitats. Domestication of an algae (as well as of plants and animals) decreases the genetic diversity within the farmed varieties, and if selected cultivars from other locations have competitive advantages over wild varieties such as high growth rates, local varieties may be outcompeted if there is spread of reproductive material from the farms. A continued high genetic diversity in wild seaweed populations is vital to maintain adaptive potential in a changing climate. 3. All farms should be placed in areas where they will have minimally negative effect on the surrounding environment – for example, any farming in areas where farms may negatively affect already existing marine habitats such as seagrass or natural macroalgal beds by shading should be avoided. Prior to the establishment of an algae farm environmental impact assessments/strategic environmental assessment (SEA) should be mandatory. 4. In open-water farming in the ocean any and all addition of nutrients or fertilizer should be avoided. For algal farms to have a positive effect on the marine environment they need to secure a net decrease of nutrients. 5. Operational measures should be put in place to reduce/eliminate any marine litter coming from algae farms/ Materials chosen for the establishment of algae farms should be reusable, recyclable and degradable as to not impact the environment in a negative manner. In addition to this we would like to affirm the point made in Option 3 regarding the quota setting and environmental impact assessment on the harvest of wild macroalgae. Harvesting of wild seaweeds have been going on across the globe for a long time and is in many cases a culturally and economically important activity that, if executed in a responsible fashion, can be both sustainable and environmentally friendly. We would, however, like to raise concerns regarding overharvest and unsustainable harvesting methods. Macroalgae commonly support diverse marine communities and host a wide range of organisms, while contributing important ecosystems services - it is vital that the development of a European algae industry does not compromise the importance of natural macroalgal beds. Harvest of wild seaweeds have in many locations around the world resulted in over-exploitation of the resource with ensuing environmental problems. Natural macroalgal beds, such as kelp forests, are important players in marine carbon sequestration given their large export of organic material to deeper areas where the carbon is stored in the sediment. This clearly illustrates that, in addition to the importance of macroalgae for biodiversity purposes, natural algal beds may constitute an important piece of the puzzle in marine carbon sequestration. We therefore stress the necessity of suitable scientific monitoring and evaluation of the harvest and its potential side effects to ensure a sustainable use of the wild seaweed resources. Harvest of wild seaweeds should be made redundant following the wide spread establishment of the sector
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Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL and Stichting BirdLife Europe

14 Dec 2020 · Fisheries related matters

Response to Green Recovery for the Blue Economy (tentative)

7 Dec 2020

Seas At Risk welcomes this opportunity to provide feedback on the Commission’s roadmap for a sustainable blue economy. Please find our submission attached. It is important to note that a healthy ocean is a precondition for a sustainable blue economy. However, Europe’s seas are in a dire state due to overexploitation and weak implementation of environmental legislation, exacerbated by climate change (see reports by the EEA, DGEnvironment, European Court of Auditors). The Blue Manifesto, supported by over 100 NGOs, provides a roadmap with specific policy actions to ensure a healthy ocean. In addition, it is key that EU recovery funds are not spent on subsidies which are harmful for the environment, but rather invested in policies which will enable the marine environment to recover and to sustain a fair and resilient Blue Economy - the joint NGO report "Turning the tide" provides concrete examples of such win-win investments. The current Commission strategy is one of blue growth, focused on technology and innovation to improve efficiency of sectors, but is has proven to be insufficient to keep economic developments within environmental limits. Maritime spatial planning is an important tool that can help, but it is often done on a sector-by-sector basis instead of using an ecosystem-based approach. Nature is dealt with as another ‘user’ of the sea, rather than the basis for a sustainable blue economy, with economic activities being planned in marine protected areas without looking at the cumulative impacts and consequences for the marine environment. A much more integrated and effective implementation of the MSP, MSFD and other environmental legislation is direly needed and fragmentation of the governance of those legislations (at EU and MS level) needs to be remedied. Maritime Spatial Planning should develop into a tool that regenerates marine life – as outlined in Seas At Risk's guidance on MSP - rather than one that tries to accommodate growth in all sectors. The EEA assessment of our seas also shows that growth of the blue economy leads to further overexploitation of our seas, as complete decoupling of human activities from environmental impacts has not been achieved despite innovative and efficient technologies. The consequence is that in our intensively used European seas, a sustainable blue economy that focuses on new maritime activities with less impact on the environment like marine renewables requires that other activities are phased out. The removal of deep-sea mining as a priority sector for the blue economy would be in line with the green deal and the biodiversity strategy.The Commission should work towards establishing a moratorium on deep sea mining in the EU territorial waters and support the numerous calls for a global moratorium on deep sea mining in international waters, in line with the European Parliament’s 2018 International Ocean Governance Resolution. In a similar vein, any support for oil and gas exploration and extraction needs to be stopped – it is incompatible with the aim of carbon neutrality. To ensure a coherent approach by all sectors of the Blue Economy there should be a common understanding and acknowledgement of the drivers of resource use and environmental pressures. A recent report by the club of Rome, endorsed by president Von der Leyen, presents a system change compass for implementing the European Green Deal in a time of recovery. It shows the path to rethinking all aspects of economy, taking societal needs – and sufficiency - as a reference point for all economic activities. This can help to reframe the European Blue Economy, putting nature and wellbeing of people at its heart.
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Response to Protecting biodiversity: nature restoration targets

6 Nov 2020

Policy context 1. The new restoration law must be targeted and result in urgent large-scale restoration across the EU. 2. The new law should be additional to the relevant EU Directives. 3. The restoration law should create synergies between the biodiversity and climate crisis agenda. Main elements Objectives As the main objective, the law must contribute to halting and reversing biodiversity loss, resulting in the restoration of habitats, species and ecosystem functioning,connectivity and resilience at landscape level across the EU. As the supportive objective, the restoration law should contribute to climate change mitigation and adaptation. Targets The legally binding EU targets for nature restoration on land and sea should be expressed in quantitative and similar terms for each Member State EU-wide, the targets should be to restore by 2030: 1. at least 1.000.000 km2 of sea (15% of the EU sea area, sea area to be adapted to EU27 EEZ); Restoration measures and criteria Firstly, restoration measures should result in permanent change aiming to restore high quality and resilient nature, with a very significant improvement from the starting condition. Secondly, restoration measures must result in significant management change(again to avoid greenwashing) that puts nature on a path towards sustaining ‘high quality’. Thirdly, action on restoration should not discriminate between restoration activities inside or outside already protected areas. Fourthly, restoration measures should also increase connectivity between habitats. Lastly, restoration measures should specifically encourage interventions that restore natural processes. In the restoration law, restoration measures should encompass both active and passive restoration actions. Illustrative examples of restoration actions: - Establishing no take zones to restore fish stocks and banning bottom-trawling to restore seabed communities - Oyster reef / Boulder reef restoration through the active provision of artificial substrates (on top of protective measures above) - Restoration of seagrass meadows and kelp forests by seabottom stabilization and active propagation (on top of protective measures above) - Restoration of marsh lands and dune systems by blocking drainage, relocating flood defences, land re-profiling, changing grazing regimes etc. - Removing barriers from rivers to restore fish migration and natural river flows/free-flowing rivers Governance - The restoration law should require Member States to draft science-based national restoration plans. The plans should include clear quantitative targets in terms of locations,areas, types of ecosystems to be restored, financial tools to be used, requirements for active public participation, deadlines etc. The restoration plans will also need to show how the restoration measures will contribute to: - Improving the connectivity of the Natura 2000 and wider protected area network - Achieving the target of 10% of the EU’s land and sea area to be strictly protected - Supporting the objectives of the Birds and Habitats Directives, Water Framework Directive and Marine Strategy Framework Directive while being additional to existing legal requirements under these Directives. More stringent objectives should always apply. - Supporting climate change adaptation and mitigation- Contributing to the recovery of wild pollinators - Ensuring the long-term protection and improvement of the restored habitats - Restoration plans should then be assessed by the Commission - The restoration law should explicitly include obligations for Member States to actively engage the public - To be effective, the restoration law must contain clear deadlines - The restoration law further needs to include safeguards to ensure the restoration and protection of the restored habitats is permanent.
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Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius) and FUNDACION OCEANA and Funding Fish

5 Nov 2020 · Action Plan fisheries and fishing opportunities, offshore renewable energy strategy

Meeting with Virginijus Sinkevičius (Commissioner) and

14 Oct 2020 · To discuss the upcoming Commission proposals for fishing opportunities for the North Sea/ Atlantic and for the Deep Sea.

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

16 Sept 2020 · Workings of the Advisory Councils

Meeting with Carmen Preising (Cabinet of Commissioner Virginijus Sinkevičius) and FUNDACION OCEANA and Funding Fish

1 Jul 2020 · economic recovery and marine ecosystems