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SURFRIDER FOUNDATION EUROPE

Surfrider Europe

Surfrider Foundation Europe protects the ocean, coastline and aquatic environments through grassroots activism on marine litter, water quality and coastal management.

Lobbying Activity

Response to A strategic vision for sport in Europe: reinforcing the European sport model

8 Dec 2025

This consultation covers a wide range of topics, including sport and inclusion, sport and education, sport and the economy, and sport and culture. However, in any long-term strategic thinking, it is no longer possible to separate these issues from sustainability concerns. As such, Surfrider Foundation Europe believes it is essential to contribute in order to remind everyone that any vision for European sport must be consistent with current and future climate realities. Sport can only remain a vehicle for health, education and cohesion if it is fully integrated into the ecological transition, particularly for outdoor and water sports that are directly exposed to the effects of climate change. Please find attached Surfrider Foundation Europes contribution. The document outlines our main positions: the need to place sustainability at the core of the future European Sport Model; the importance of recognising the specific vulnerability of outdoor and water sports to climate change; the current gaps in European standards and policies relating to sustainability in sport; and our recommendations to strengthen environmental governance, support stakeholders, integrate ocean protection, and embed education and climate resilience across all sporting activities. This contribution draws on Surfriders long-standing expertise and key European projects such as GSHE, OSES and CONNECT+
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Meeting with Paula Duarte Gaspar (Head of Unit Environment) and Seas At Risk

21 Oct 2025 · Blue carbon Marine Strategy Framework Directive

Response to Roadmap towards Nature Credits

30 Sept 2025

Although blue carbon credits are not explicitly mentioned in the roadmap accompanying this public consultation, the text does explicitly reference the Ocean Pact released in June, which reflects the European Commissions intention to develop European blue carbon reserves and new business models for coastal communities. Surfrider Foundation Europe has therefore chosen to use this consultation as an opportunity to share its perspective (see attached) on blue carbon credits and would like to thank the Commission for its consideration.
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Meeting with Christophe Clergeau (Member of the European Parliament) and Seas At Risk

9 Sept 2025 · SEArica

Meeting with Jessika Roswall (Commissioner) and

1 Jul 2025 · Circular and toxic-free plastic

Meeting with David Cormand (Member of the European Parliament) and European Environmental Bureau

22 May 2025 · Event: "Watering the Future: Improving Agricultural Practices for Water Resilience"

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 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 Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and Seas At Risk and Environmental Investigation Agency

7 Apr 2025 · Pellets Regulation

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and Environmental Investigation Agency and Fidra

24 Mar 2025 · Webinar: How can the EU lead the way in addressing pellet pollution?

Response to European Water Resilience Strategy

4 Mar 2025

SURFRIDER FOUNDATION EUROPE welcomes the European Commission's announcement to put forward a European water resilience strategy. Water bodies in Europe - both fresh and marine waters - are under unprecedented pressure from unsustainable human activities including pollution, overexploitation and climate change. The findings of the latest EEA report on the state of waters in Europe are very clear: we will not be able to achieve resilient water bodies without addressing these three interconnected issues. The reason is simple: the resilience of our waters depends on their ability to self-regulate and regenerate in the face of human impacts. The more impacts there are, the more the resilience of our waters is altered: pollution, overexploitation and climate change directly undermine this ability by degrading water quality, threatening biodiversity, and disrupting aquatic ecosystems. Any initiative aimed at strengthening water resilience must therefore necessarily include actions for pollution prevention and reduction, for climate mitigation, the transition of our economy starting with water-intensive activities and those with the highest impacts on our waters, a precautionary approach to ways of diversifying our water supply and be associated with resources to protect and restore our waters. Please find attached our answer to the call for evidence.
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Response to The European Oceans Pact

17 Feb 2025

Surfrider Europe welcomes the European Commission's commitment to propose an Oceans Pact and appreciates the opportunity to share its views. Alongside the Blue NGOs a coalition advocating for healthy and resilient seas and oceans in Brussels and the EU, comprising BirdLife, ClientEarth, Oceana, Seas At Risk, Surfrider Europe, and WWF we published our Ocean Elections Manifesto and Blue Manifesto last year. In these documents, we explicitly called for the urgent adoption of such an instrument and outlined the key measures that an Ocean Deal or Ocean Pact should include. At the same time, the Blue Up coalition, made up of civil society members united in the goal of prioritizing ocean protection on the EU agenda ahead of the 2024 EU elections, presented its demands for candidates and EU institutions for the 2024-2029 mandate. Following extensive drafting, consultation efforts, and the involvement of over 140 organizations, including NGOs, private sector actors, and think tanks, these two documents form the foundation of the Oceans Pact we want to see. They should serve as a reference point for the Commission in shaping and developing the European Oceans Pact. Please find in the document attached more details on our views.
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Meeting with Karin Karlsbro (Member of the European Parliament, Shadow rapporteur) and Seas At Risk

13 Feb 2025 · Plastpellets

Meeting with Christophe Clergeau (Member of the European Parliament)

5 Feb 2025 · SEARICA/ENVI

Meeting with César Luena (Member of the European Parliament, Rapporteur) and Seas At Risk and Environmental Investigation Agency

22 Jan 2025 · Pellets Regulation

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 Isabella Lövin (Member of the European Parliament)

2 Oct 2024 · Ocean Lab: MEPs meet the ocean

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

11 Sept 2024 · Introductory Meeting with Blue NGOs

Surfrider Europe opposes increased use of recycled manure fertilizers

17 May 2024
Topic — The consultation concerns proposed updates to rules for using recycled livestock manure fertilizers.
Message — Surfrider Foundation Europe rejects the interim solution authorizing RENURE fertilisers above current established limits. They urge the Commission to drop these proposed measures and instead focus on better enforcing existing legislation.12
Why — Stopping the proposal helps the organization maintain water quality for its recreational members.3
Impact — Public health and marine ecosystems suffer from increased nutrient pollution and worsening eutrophication.45
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Meeting with João Albuquerque (Member of the European Parliament, Rapporteur) and Seas At Risk and Environmental Investigation Agency

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

Response to GreenData4All - Revision of EU legislation on geospatial environmental data and access to environmental information

25 Mar 2024

Surfrider Europe welcomes the initiative of the European Commission to update and revise the public environmental data sharing framework as part of its Green Deal effort. As a non-profit organisation, Surfrider Europe both uses data and generates data in support of and as part of its own educational, research and advocacy activities, be them on climate change (for example on erosion, and the evolution of the coastline or regarding the impacts of offshore oil and gas platforms), on marine litter (for example on the plastic pollution generated by the spills of biomedia from waste water treatment facilities, the spills of plastic pellets or the loss of containers at sea) or water quality and water pollution (resulting for example from discharges at sea from vessels, water quality of bathing sites). We welcome the Commissions intention to look at and possibly include citizen science data as stated in the supporting document of this consultation. From our experience, this data is extremely valuable. As a matter of fact, most the data we generate is citizen-science based. We take great care and deploy important efforts to share this data with the competent authorities (our data is visible on the EMODNET platform). At the same time, we are also constantly looking for data on our different areas of work and finding it can be extremely challenging. We therefore applaud the Commission intent to facilitate its access, to make sure all players contribute to this European space of data, including private actors, and to extend it to the areas and data types which today do not fall under the scope of the INSPIRE directive. Its extremely important to make sure this data is made accessible to all for environmental protection purposes only and is made accessible so that this data can be aggregated, and matched up in order, among things, to facilitate the control of the implementation of EU laws, and of provisions and targets set in EU environmental law.
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Surfrider Europe urges total ban on all harmful bisphenols

8 Mar 2024
Topic — The Commission is proposing restrictions on bisphenols used in food contact materials.
Message — The organization requests a blanket prohibition on all bisphenols meeting CMR and EDC criteria. They also propose harmonizing the scope of prohibitions for all food contact materials to streamline enforcement.12
Why — A comprehensive ban would protect the marine ecosystems and biodiversity that Surfrider preserves.3
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Surfrider Europe urges stricter enforcement to curb nitrate pollution

8 Mar 2024
Topic — Evaluation of EU rules protecting water quality from agricultural nitrate pollution.
Message — Surfrider recommends strengthening enforcement of current rules instead of creating new legislation. They advocate for closing the implementation gap and integrating water policy with other sectors. Additionally, they demand strict limits on exemptions for nitrogen fertilizer limits.12
Why — Cleaner coastal waters would protect aquatic recreation and prevent beach closures.34
Impact — The agricultural sector loses the flexibility to exceed nitrogen usage limits.5
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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 Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion)

7 Dec 2023 · Preventing plastic pellet losses to reduce microplastic pollution

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur for opinion)

6 Dec 2023 · Plastic Pellet Losses

Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and

16 Nov 2023 · Green Deal

Meeting with Marina Mesure (Member of the European Parliament)

27 Sept 2023 · Réemploi et recyclage des emballages

Meeting with Marie Toussaint (Member of the European Parliament) and Zero Waste France

14 Sept 2023 · recyclage emballages

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

3 May 2023 · UWWTD

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

27 Apr 2023 · UWWTD

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and European Environmental Bureau

13 Apr 2023 · Urban wastewater treatment

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

29 Mar 2023 · Stakeholder Consultation on Urban Waste Water Treatment Directive

Response to Revision of the Urban Wastewater Treatment Directive

14 Mar 2023

Surfrider Europe welcomes the ECs proposal for a revised Urban WasteWater Treatment Directive. UWWTPs intervene at the very end of the water cycle as our last defence against water pollution, protecting the marine and aquatic environments as well as our own health.The proposal is a welcome overhaul of the 30-year-old Directive which has the potential to provide a solid baseline to ensure UWWTPs can address the new pressures faced by society today. However, some concerns remain regarding the strengthening of certain provisions to ensure an efficient implementation on the ground. We praise the ECs efforts to address the remaining sources of untreated wastewater pollution. The proposal introduces new definitions strengthening some of the provisions on the collection and treatment of wastewater which should help cover an important share of the remaining pollution load that is left to be treated in Europe. Yet, we are still concerned with the way some of these provisions will unfold. The requirements for small agglomerations and individual systems should be better articulated and clarified to avoid loopholes and ensure decentralised systems and nature-based solutions are used when possible. Stormwater overflows and urban runoff are important sources of pollution from bacteria, hazardous substances, litter and microplastics which ultimately pose a threat to the environment and our health. Though the introduction of integrated wastewater plans is a definite step forward, the current indicative objectives are too weak to ensure these plans are enforced comprehensively across the Union and to effectively reduce the occurrence and impact of SWOs and runoffs. Provisions on public information (Art24) should ensure individuals are notified of such events and have access to the relevant data, given the known health risks especially near bathing and recreational sites. Urban wastewater is the reflection of what is put on the market by the industry for use in our households and chemical substances are now found everywhere in the products we use daily. Given the growing concern over the impact of chemical pollutants on our ecosystems and our own wellbeing, we welcome the introduction of quaternary treatment. It should give the impetus for higher water quality in European waterways. The enshrinement of the polluter pays principle through the introduction of an EPR scheme is an absolute necessity to protect the health of EU citizens while ensuring a fair distribution of costs across all actors. Exemptions should be therefore strictly limited. Biomedia leakage from WWTPs is a significant source of chronic and acute plastic pollution in the marine and riverine environment. After years of raising this issue, we welcome the ECs initiative to address it. To ensure enforceability and feasibility, the proposed measures should be secured, specified, and further developed. A comprehensive definition of biocarriers/biomedias will futureproof the proposal as MBBR technologies are continuously developing and increasingly used by UWWTPs. Condition approval of discharge authorisation on specific criteria along with compulsory reporting of technologies used by plants including biomedia use if applicable would guarantee legal certainty and a level playing field. Mandatory monitoring and reporting of plastic biomedia leakage, and frequent control of WWTPs would ensure appropriate preventive measures are taken. In case of leakage, spill, pollution, any company involved should be held accountable by law and responsible to take appropriate remediation measures pursuant to the polluter pays principle. The UWWTD has potential to tackle microplastic pollution, conceding that monitoring requirements in the outlets of facilities are improved, and that sewage sludge disposal is prescribed in line with the best overall environmental outcome principle. Please find attached our joint NGO analysis along with our policy recommendations on biomedia spills.
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Surfrider Europe Demands Faster Phase-Out of Toxic Water Pollutants

14 Mar 2023
Topic — EU consultation on updating lists of chemical pollutants affecting surface and groundwaters.
Message — The group opposes deleting the 20-year deadline for phasing out hazardous substances. They request monitoring chemical groups to better address toxic mixture effects.12
Why — Stricter legislation provides stronger protection for the marine environments they represent.34
Impact — Chemical producers would bear higher monitoring costs and face stricter regulatory oversight.5
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Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and European Alliance to Save Energy

28 Feb 2023 · Recast of the UWWTD

Meeting with Catherine Chabaud (Member of the European Parliament)

15 Feb 2023 · Discussion sur les microplastiques

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur) and Danfoss A/S

6 Feb 2023 · Recast of the UWWTD

Meeting with Pierre Karleskind (Member of the European Parliament)

9 Dec 2022 · Sécurité maritime

Meeting with Marina Mesure (Member of the European Parliament) and Zero Waste France

12 Oct 2022 · Déchets, économie circulaire et recyclage

Surfrider Europe urges smoke-free beaches to protect aquatic environments

20 Jul 2022
Topic — The Commission is updating recommendations to expand smoke-free zones to additional outdoor spaces.
Message — Surfrider wants to include all beaches and vulnerable blue spaces in the smoke-free scope. They also advocate for ambitious waste responsibility schemes for tobacco producers.123
Why — This measure would reduce the massive plastic and chemical pollution affecting marine ecosystems.4
Impact — Tobacco companies would face increased costs from mandatory environmental cleanup and responsibility schemes.5
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Meeting with Themis Christophidou (Director-General Education, Youth, Sport and Culture)

13 Jun 2022 · The EurOcean Youth network will present to DG Christophidou a set of recommendations, in the perspective of the Ocean Week 2022 and in the context of the European Year of Youth.

Meeting with Caroline Roose (Member of the European Parliament) and WWF European Policy Programme and FUNDACION OCEANA

13 Jun 2022 · Conférence "There is no ocean B."

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

15 Feb 2022

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the Commission Initiative to update the Ocean Governance agenda as called for by the Mission Starfish 2030’s report published in December 2020. Our Ocean is global and affected by issues that require ambitious collective action at the highest level. Significant steps must be taken, and measures adopted to protect, restore and strengthen the resilience of the ocean. Beyond the instrumental need to ensure better ocean governance to further protect the Ocean, Surfrider has been seeing first-hand the importance to increase cooperation and international efforts to draw strong policies at the international level, due to the very nature of its network with Surfrider Foundation members being present on the 5 continents (Argentina, Australia, Brazil, Canada, Europe, Japan, Morocco, Senegal and the Unites States of America). Our Ocean is one, and the various pressures our Ocean faces requires to update the international framework in order to best address plastic pollution, acidification, climate change, exploitation and irreversible marine and coastal habitat and biodiversity loss. The multisector and multilevel segmentation of the policy frameworks weakens the ocean governance framework. At the end, it makes no doubt enhancing Ocean governance and protecting the Ocean and its resources contribute to ensuring peace and to protecting the world as a whole, as there can’t be life without the ocean. Surfrider Europe is pleased to provide, as follows, its main recommendations for the EU to play a role of both leader in international ocean governance and model of effective ocean governance if key action is taken.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

SURFRIDER FOUNDATION EUROPE welcomes the European Commission’s initiative on microplastics and supports its current efforts to shape strong measures that will address microplastic pollution at source. Surfrider Europe calls for urgent action to prevent and reduce all sources of unintentionally released microplastics. We are pleased to provide further comments in a document attached.
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Meeting with Pierre Karleskind (Member of the European Parliament)

13 Jan 2022 · One Ocean summit

Meeting with François Alfonsi (Member of the European Parliament, Rapporteur)

15 Dec 2021 · Pollution en méditerranée

Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Surfrider Foundation Europe welcomes the European Commission's initiative to reflect on the -yet to be proven- role of biobased, biodegradable and compostable plastics and its analysis of the main challenges they pose and would like to detail as follows the priorities that should be addressed in this initiative. Full position: see RPa's feedback. Biobased, biodegradable and compostable plastics are absolutely not a solution to plastic pollution and to the harm caused by plastics to the marine and coastal environment. We consider they should by no means be considered as alternatives to so called 'conventional' single use plastics, as they continue to be most often single use. With more than 400 million tonnes of plastic produced each year worldwide and our Blue planet drowning in plastics, reducing our plastic production and use of plastics - no matter the material used and their degradability claims - have proven to be the only solutions to put an end to plastic pollution. On terminologies, we support the Commission's wanting to establish clear definitions in particular to stop the confusion around the use of the 'bioplastics' terminology. This terminology is ambiguous, confusing, subject to different understandings and interpretations. The use of 'bioplastics' should no longer be permitted on products or for claims. On the biodegradable terminology, we consider industrially compostable to be the only terminology which makes sense and has the potential to bring clarity to consumers with regard to their end of life. Its use should yet only be permitted in the case of consumer products if the entire product or packaging is fully industrially compostable. It should concern a limited list of applications under a series of criteria. Outside these applications, no biodegradability claim should be allowed. Biodegradable and compostable plastics indeed perpetuate a linear model where items are used once and with a short lifetime before being disposed of, contributing to the loss of valuable resources and to externalities associated with their production and end-of-life. Most often, they are not composted but end up in incineration or landfills, or risk polluting the marine environment as they are disposed of incorrectly. On marine biodegradability, we oppose the development of a standard which we see unrealistic and dangerous. It is not possible to develop environmentally sound criteria for the marine biodegradation of plastic that can ensure no environmental risk during the biodegradation process in all possible environmental compartments they will encounter and which differ in many ways from one to another (temperature, salinity, oxygen levels, sand, etc). More importantly, we consider that designing products for “marine biodegradability” is not desirable. Plastics by no means belong to the marine environment, should end up there nor their presence there should be legitimised in any way. We consider the risks to develop such a standard to overcome largely any supposed benefits. The mere existence of such a standard could create a market, generating new uses, to the detriment of reusable alternatives and the protection of the marine environment and could encourage people to believe these products were designed to be abandoned in the marine environment, or that their presence in the marine environment is unlikely to have any risk or impact for this vulnerable environment. Such a standard could de facto increase plastic pollution and harm to the marine environment. Indeed, it does not address and even less prevent harm to wildlife and ecosystems that will occur during the biodegradation period that tends to be long in this complex environment. On claims, no terminology should be used in the absence of supportive standards and adequate control. Unclear claims which use bio-based or biodegradability characteristics as a marketing tool and those omitting to mention the presence of plastics should be banned.
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Response to Revision of the Directive on ship-source pollution

2 Jun 2021

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the Commission initiative to revise the EU rules on illegal discharges from ships. This Directive is a strong tool in European law to fight against marine pollution, which is in the heart of Surfrider’s mission. However, the NGO regrets that several issues are not considered in the Directive. First of all, air pollution must be strongly considered as an illegal discharge from ships, that needs to be tackled by European policies. In addition, containers’ loss at sea should be finally defined as a waste pollution from shipping in the Directive. Surfrider supports the general approach adopted to adopt a new SECA in the Mediterranean Sea, to ban open-loop scrubbers from the European waters and to adopt new measures regarding routing and tracking of the containers’ loss at sea.
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Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

Surfrider Europe would like to thank the Commission for the present opportunity to provide feedback to this roadmap. Surfrider Europe firmly believes the MSFD has been providing a clear framework for action to protect the marine environment and is necessary to allow for an holistic approach to ocean protection at EU level. The Marine Directive has been critical in giving the necessary structure for setting up national programs of measures and has the potential to ensure a similar and high level of protection across all European seas and to allow for enhanced coordination within and between Member States. However, despite more than 10 years of implementation, the main objectives of the MSFD have not been reached, in particular its main objective of reaching the good environmental status (GES) of EU seas by 2020. The implementation of the MSFD has been too slow, due to limited ambition in setting up definitions, targets and measures, lack of political will to adequately fund and enforce necessary measures, and limited involvement of the relevant sectors. We consider greater coherence -together with greater ambition in this legislation- is needed with other key legislation under the EU Green Deal as the Directive could contribute significantly to delivering the EU Green Deal and Zero Pollution ambition for water. Yet, for its objective to be met, the MSFD needs to be complemented by new legislative tools or incorporation of new measures in existing legislation including measures against microplastic and chemical pollution, incorporated among other legislation into a revised Directive on bathing waters and urban waste water treatment, on shipping and by a strong direction given to end oil and gas offshore exploitation and exploration in EU seas. This needs to materialise finally via an alignment of the Sustainable Blue Economy agenda with the objective of good environmental status and a healthy ocean. Surfrider Europe considers the failure to achieve healthy waters so far lies in insufficient implementation and enforcement and lack of sufficient support and resources deployed/ provided to Member States and internally within Member States. Taking the example of descriptor 10 on marine litter, the SUP Directive has shown the power of (and need for extra) EU -wide legislation setting targets and obligation for both Member States and businesses to support the MSFD implementation and achieve real change to meet our objectives. Indeed, we believe existing legislative tools, adoption of new complementary legislation, delegated/implemented acts, development of further guidance or infringement actions, and additional funding should ensure better implementation and compliance with the Directive. It would also help to improve GES definitions, increasing effectiveness of measures to address pressures, better coordination at MS and regional levels, ensuring timely reporting, while increasing protection, management and enforcement of MPAs. Surfrider Foundation Europe therefore supports the option proposed by the Commission to strengthen implementation and enforcement of the Directive without changing its provisions.
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Response to Bathing water quality – review of EU rules

1 Apr 2021

Surfrider Europe is very pleased to see the official review of the Bathing Water Directive being finally launched and would like to thank the Commission for the opportunity to provide its feedback to the roadmap. Surfrider Europe believes the EU Directive on bathing waters is needed more than ever, yet it needs to be urgently revised and updated to adapt to its times and the current state of knowledge we have on the consequences of pollution for both the environment and our health. Indeed, the current Directive falls short of what is needed to address both existing and emerging issues and pollutants impacting human and environmental health in a number of aspects, as well as what is needed to protect the millions of Europeans who go and enjoy EU waters through recreation and water sports, outside designated bathing sites. Surfrider Europe would like to recall the objective of the Bathing Water Directive which is to protect human health and to preserve, protect and improve the quality of the environment. Surfrider Europe regrets those two objectives have not been taken on board equally by public authorities and considers the revision of the Directive should be seized to ensure the Directive fulfils and achieves those two objectives with equal ambition and with the adoption of corresponding measures to address both health issues and environmental issues which relate to water quality and is equipped to face existing, emerging and new challenges. Surfrider Europe would like to make clear that a high or even acceptable level of health protection will never be achieved without a healthy environment. For all these reasons, Surfrider Europe would like to ask for the following changes (justifications are provided in the document attached) : 1. Extension of Water Quality control to recreational areas 2. Monitoring the quality of water throughout the year 3. Adding new parameters to be monitored: Surfrider Europe strongly recommends the addition of the following parameters: waste, algae bloom, cyanobacteria, and chemical pollutants. 4. Obligations regarding identifying, assessing, and preventing pollution: under the current Directive, there is no obligation for Member States to avoid, reduce or eliminate sources of pollution. The revised Directive shold impose on Member States to put a strict end to pollution, regardless of the classification of water and, the potential of profiles should be fully seized. 5. Standardised, more accessible, and better relayed public information on water quality 6. Strengthening and encouraging public participation: the opportunities for public participation should be strongly encouraged as they are currently hardly known and under-exploited. 7. Aligning all policies with an impact on water and the protection of the marine environment Surfrider Europe is pleased to provide in its Manifesto for Health Waters available here (https://surfrider.eu/wp-content/uploads/2021/03/manifesto_web_ven.pdf) on line its full perspective on the protection of bathing and recreational waters and here attached its feedback to the present consultation process. Surfrider Europe looks forward to participating into the stakeholder discussions and to contributing to the future policy discussions on how to best revise the Bathing water directive to achieve the best possible impact for the health of our environment and the health of all Europeans. Surfrider Europe considers the possibility of revising the Directive now should be fully seized given the number of scientific findings alerting on current and possibly emerging pollutants, justifying acting now. We can’t afford to wait for 15 extra years to have such a potentially impactful Directive to be amended.
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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 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the minimum level of training of seafarers

12 Jan 2021

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the Commission initiative to codify the different EU rules related to the minimum level of training of seafarers. However, the NGO regrets that environmental training is not strongly taken into account in the Directive proposal. Marine pollution, and above all the fight against oil spills and container losses at sea is a major challenge that could really be enhanced by the Commission initiative. Surfrider supports the general approach adopted to create a European standard for seafarers in order to secure the prevention of marine pollution within the shipping industry.
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Response to Green Recovery for the Blue Economy (tentative)

7 Dec 2020

Surfrider Foundation Europe (SFE) supports the Commission Initiative to lead the maritime sector towards a green post-Covid future. Several fields could be part of that movement, in particular the shipping sector, but also marine renewable energies or sustainable tourism. However, the NGO fears that this post Covid future will encourage a ‘blue economy’ that does not take into account the protection of marine environment. The development of an ocean-related economy has undoubtly negative effects on the ecosystems, and those impacts need to be part of all development policies that concern sea and coastal management. Surfrider supports the general approach adopted to encourage a green transition of the shipping, energy and tourism sector. This policy has to create new jobs related to alternative to fuels, sustainable ports, local partnerships and low-impact tourism practices.
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Response to Port State control - Further improving safety, security and sustainability of maritime transport

20 Nov 2020

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the Commission initiative to review the Port State Control (PSC) Directive (2009/16/EC). This Directive is a strong legal tool in the fight against flags of convenience, which is in the heart of Surfrider’s Programme on Climate change. The database associated with Port State controls is also a very helpful way to improve the efficiency of the legal basis. However, the NGO regrets that the Port State Control classification is not strict enough to fight against flags of convenience. The database could also be extended to a larger number of ships and the PSC inspectors better trained. The ban conditions from European waters for vessels should also be strengthened. Surfrider supports the general approach adopted to modify the Port State Control Directive towards an efficient digitalization of the PSC, with the recruitment of inspectors with a strong maritime background. This legislative tool must position the European Union as a leader in the fight against flags of convenience.
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Response to Maritime Accident Investigation

20 Nov 2020

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the Commission Initiative to revise Directive 2009/18/EC on maritime accident investigation. This Directive is a very useful legislation to standardize investigation methods within the European Union, which help environmental stakeholders to act when a marine pollution case is established. There is, therefore, a strong link between this directive and Surfrider’s Coastal Defenders Programme that fights against marine pollutions. However, the efficiency of this legislative tool could be improved, especially regarding Surfrider’s objective to inform and fight against loss of containers at sea - a new type of marine pollution that needs to be recognized. Surfrider supports the general approach adopted to review the text, encourage better cooperation between Member State for international maritime accidents such as containers loss at sea, make the EMCIP data public, and accelerate the publication of investigation reports.
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Response to Compliance with Flag State requirements (shipping)

20 Nov 2020

SURFRIDER FOUNDATION EUROPE (SFE) welcomes the European Commission initiative on compliance with Flag State requirements regarding shipping issues and fully supports the revision of Directive 2009/21/EC. We are convinced that the Flag State has a strong role to play in enhancing the respect of international rules and, therefore, fighting against marine pollutions from ships, which is an objective in the heart of Surfrider’s programme on Climate Change. However, the NGO regrets that the Directive 2009/21/EC does not encourage the European Flag States to enhance their control level enough. Some flags such as the Maltese and Cyprus ones still figure on the ILO flags of convenience list. The European Union should take the lead in fighting against flags of convenience by showing an excellence level of requirements and control over its vessels. The responsibility of some European Flag States in maritime accidents leading to marine pollutions is also still established nowadays, showing that the control of Flag States onboard in not strong enough. Surfrider supports the general approach adopted to strengthen the Flag State control on board, to strengthen the requirements and controls for the EU-certified classification societies and to improve the frequency of control visits. We invite European Commission to consider the role of a high-level standard of European flag and urge for a new strategy on Green shipping in Europe. That will enable Europe to give a vision on what we could call Green shipping, inspiring from taxonomy principle and fitting with MSFD and biodiversity strategy purpose and Mission Starfish.
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Response to Revision of the Urban Wastewater Treatment Directive

8 Sept 2020

SURFRIDER FOUNDATION EUROPE (SFE) welcomes and fully supports the considered revision of the Urban Waste Water Treatment Directive (UWWTD) and the pursued objective of making sure that urban wastewater is clean and safe in order to both protect public health and the environment. These two objectives are at the heart of Surfrider Europe’s programme on Water Quality. While we acknowledge the Directive has played a crucial role in the reduction of pollutants – especially bacteriological pollutants- impacting water bodies (including bathing sites) by requiring by law the collection and treatment of waste water in Europe under certain conditions and by increasing treatment obligations, water pollution is still massively observed across Europe with concrete and repeated pollution of bathing and recreational sites, in many cases in violation of the UWWTD or because these sites or pollutants do not fall under the scope of the Directive. Indeed, chemical pollution in its entirety is not being addressed by the Directive, with a high number of chemical pollutants falling outside the scope of the Directive, despite their severe implications for the environment and human health. For recreational sites, failure in the (or absence of) treatment of wastewater remains the number one reason for poor water quality. We’re calling the Commission to fully address the issue of water pollution in recreational water areas which, because of their frequentation all year long should be considered as priority areas. On the other hand, some countries are still lagging behind in the implementation of the Directive and need to step up its implementation. Massive needs for investments and resources are also lacking in most EU countries to implement it fully and adequately. Nature based solutions to reduce water pollution should be considered as equally valid options and receive funds. Surfrider Europe regrets the implementation is not taken seriously and invites the Commission to ensure the timely and duly implementation of the Directive in all Member States, including in outermost regions - vulnerable areas which host incredible biodiversity and where – yet – continuous failure in the treatment of waste water and pollution are reportedly common. Surfrider Europe finally fully supports the Commission’s intention to update the Directive so it can address increasing and remaining challenges such as urban run-off and stormwaters as well as emerging sources of pollution which include microplastics and pharmaceuticals but not only. We think the revision is also justified due to climate change and changes in human development (densification of agglomerations and urban areas, soil artificialisation, separative and unitary networks, etc.) which have become more acute since 1990 when the Directive was adopted. Similarly, new methods and approaches in water treatment and the emergence or recognition of combined environment and public health issues (chemical substances, cocktail effects, biodiversity loss, endocrine disruptors, antimicrobial resistance, etc.) justify its revision together with an increased recreational use of water, beyond merely bathing. We would like therefore to invite the Commission to incorporate chemical pollution and biomedia pollution as additional sources of pollution the Directive needs to address and where huge impacts can be expected if legal measures were adopted and increase its treatment requirements. We strongly believe a revised UWWTD would help to achieve the objectives of the Bathing Water Directive and of the two major Directives regulating fresh and marine waters: the Water Framework Directive and the Marine Strategy Framework Directive. Our announced failure in reaching the objectives set in these two Directives are already per se immense justifications for more robust action on waste water treatment.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

16 Jun 2020 · European Green Deal, new circular economy action plan and the circular plastics economy

Response to Climate Law

30 Apr 2020

Surfrider Foundation Europe welcomes the EC ambition in reaching climate neutrality by 2050. However, we are disappointed to see that the Climate Law did not contain any mention of the ocean, despite the role it plays in regulating climate and absorbing CO2 emissions. We know, that 93% of the excess heat generated by human activities via the greenhouse effect is absorbed by the ocean, thus mitigating the increase in temperature of the atmosphere. The global ocean has a major role in the regulation and control of the large natural planetary balances. Climate fluctuations would be much more rapid and more powerful if they were only governed by the atmosphere. Consequently, if we want to achieve climate neutrality, it is crucial that we protect ocean's health and resilience. We also expect the Climate law to be backed by concrete measures that would pave the way for a real decrease in emissions, needed to reach climate neutrality and reduce pressure on the ocean. For instance, Europe must commit to abandoning fossil fuel and ban offshore gas and oil exploration and exploitation in EU waters, starting with Marine Protected Areas (MPAs) and Arctic waters. The EU should also set ambitious emissions reduction targets for the shipping sector towards its complete decarbonisation by 2050.
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Response to FuelEU Maritime

24 Apr 2020

At first Surfrider Foundation Europe wants to underline the importance in Europe to achieve Paris Agreement objectif and in particular the Objectif 3 of d'Aichi Convention : decarbonisation will be a way to do it. Both objectives are compulsory and complementary and in our orientation it's important to keep in mind the 1.5 degrre necessity and the fact that we have to stop to give subsidies to action that are still having negative impact on biodiversity. Heavy fuel and fossils fuels are still really well knonw for that kind of impacts so we have to stop to subsidies those activities. Surfrider Foundation Europe position is standing for a global life cycle assessment. This assessment will anable an eco-conception of new vessels and retrofitting of the old ones. We hardly encourage to launch a progressive phase out of the oldest vessels (More than 20 years) like it has be done for double hull regulation. Those are, in average, the more unsafe and pollutant at global level. We encourage a compulsory to retrofiting the other and an ecoconception of the new ones. Eco-conception in Europe shipbuildyard is very well knowne so we advocate to encourage this activity in Europe instead of Asia, and we also advocate for dismantling shipyard in Europe. This global revision of environnemental performance of ships can find a cost effective balance while using wind as propulsons alternative or assistance. Wind is natural, is free, don't need storage, available every where and the equipment of sails or other types of wind propulsion are cost effectives. By the way the companies or project like, Airseas, Beyondthesea, Neoline, Conoship, Zephyr &Borée, VPLP, Esprit de Velox are fralgships of the european expertise and knowledge and are new jobs sources. Europe should explore that sector and promote it as a solution, as a real alternative to fuel that could be combine with other technologies like hydrogene, biomethane or electricity having in mind the necessity of energy efficiency on board include in passengers cabine for the cruises. We encourage also europe to dedicate funds, our to facilitate a signal to funders to encourage wind propulsion but also adaptation of ports infrastructures in Europe. This is an emergency issue for environment and health. We finally encourage European Sustainable Shipping forum to consider wind as an alternative to fuel. On the other hand Surfrider Europe want to bring the attention to the European Commission upon the launching by the end of april of a label we manage considering all kind of environmental performance that could emphasis shipowners. Its name is Green Marine Europe. Fuel alternative and carbon footprint efficciency regarding MRV datas is one of the criteria assess, in this framework, going beyond legislation exigence and rewarding those efforts. It definitely encourage a decarbonisation progressive and efficient curb launching an environment competition between all shipowners. This label can be a way and an inspiration to facilitate a switch from fuel to other behaviour and solutions. The first selected volontary shipowners will be revealed in the automn 2020. This project benefit from ADEME, french ministry but also Life Operating Grants from European Commisison funds. We join a presentation of the project . We also support Transport & Environment contribution to this consutation. Antidia Citores
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Greenpeace European Unit and

18 Oct 2018 · discussion on Plastics Strategy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Friends of the Earth Europe and

13 Apr 2018 · discussion on single-use plastics legislation

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and

13 Apr 2018 · Single use plastic

Meeting with Elżbieta Bieńkowska (Commissioner) and

30 Jan 2018 · Exchange of views regarding strategy on plastics

Response to Evaluation of the General Union Environment Action Programme to 2020 (7th EAP)

6 Dec 2017

Surfrider Foundation Europe (SFE) welcomes the launch of a public consultation on the evaluation of the 7th EAP early 2018 and will provide detailed information and recommendations in this context. SFE would like to highlight that the serious environmental challenges the EU (and the world) is facing require ambitious timely, effective and coordinated action. Linking and ensuring consistency between the different environmental challenges, as well as ensuring the integration of environmental policy across EU policies, are critical if the EU is to effectively tackle those challenges. In that regard, EAPs have an important role to play by providing a framework for EU action. SFE is concerned by the fact that the Commission is considering discontinuing environmental action programmes. While the implementation of the 7th EAP is largely imperfect, the UE should aim at the adoption of a strong 8th EAP, which addresses the pitfalls and insufficiencies of the current EAP identified during the evaluation. In view of the current and emerging environmental challenges, and of the fact that the nine priority objectives of the 7th EAP and many environmental legislative targets, such as achieving a good environmental status in the marine environment, have to be met by 2020, an ambitious framework for action beyond 2020 is needed.
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Meeting with Frans Timmermans (First Vice-President) and European Environmental Bureau and

6 Nov 2017 · Discussion on EU Plastics Strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Friends of the Earth Europe and

26 Oct 2017 · Plastic strategy

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

28 Mar 2017 · Our Ocean Conference 2017, marine pollution, plastics

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

21 Oct 2015 · Ocean Governance

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Mar 2015 · Circular Economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

3 Mar 2015 · Marine Litter