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WWF Portugal

WWF Portugal is a Portuguese non-profit association legally recognized as an ENGO, that works in alignment with the global vision and strategy of WWF.

Lobbying Activity

Meeting with Ana Vasconcelos (Member of the European Parliament)

26 Aug 2025 · 2040 climate targets

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

4 Jun 2025 · Exchange of views on EU priorities for 2025 in GFCM

Response to Guidance to facilitate the designation of renewables acceleration areas

21 Feb 2024

A energia renovável offshore constitui uma parte importante na promoção da transição energética europeia para uma economia resiliente e totalmente descarbonizada, mas deve ser considerada sob o ponto de vista da crescente degradação da saúde do nosso oceano. A energia eólica offshore, assim como outras energias renováveis marinhas e as infraestruturas de rede, deve progredir com respeito pela conservação da natureza e de acordo com as capacidades ecológicas dos ecossistemas, de forma a providenciar soluções sustentáveis para combater a crise climática e a crise de biodiversidade As propostas de designação de zonas de aceleração da implantação de energias renováveis no oceano (do inglês renewables acceleration areas - RAA) devem assentar num processo transparente, baseado na melhor evidência científica disponível e participado por todos os atores relevantes, de forma a garantir o planeamento adequado destas áreas e minimizar os potenciais impactos nas comunidades locais dependentes dessas áreas. . Para que este processo seja transparente e robusto, e de forma a cumprir os objetivos a que se propõe a União Europeia, a designação de RAA seguindo uma abordagem precaucionária para o ecossistema marinho permite cumprir a hierarquia de mitigação. Esta começa com a prevenção de impactes, que deve forçosamente garantir que as áreas a afetar se encontram fora de zonas de elevado risco para a biodiversidade. Como tal, consideramos que a definição das RAA deve obrigatoriamente seguir um conjunto de critérios se queremos realmente promover uma transição energética justa para o ambiente e para as pessoas. Os critérios e exemplos de boas e más práticas em Portugal encontram-se no ficheiro em anexo.
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Meeting with Sara Cerdas (Member of the European Parliament)

30 Jun 2023 · Reunião ANP/WWF Lei da Restauração da Natureza

Response to Policy Statement 2022

30 Aug 2021

ANP|WWF welcomes the EC’s report yet deplores the confirmation that overfishing has increased in EU waters. If “fisheries in the EU grow in sustainability”, they aren’t all doing so at a pace reflecting the urgency of the situation, or at all, and remedial measures to restore certain fish stocks will not suffice in themselves so long as quotas are set unsustainably. As we continue to distance ourselves from the legally prescribed 2020 deadline to end overfishing, marine ecosystems across EU waters remain at risk of collapse. Despite being a precondition to deliver on the CFP’s objectives, fishing limits are yet to all be set at sustainable levels, using an ecosystem-based approach to fisheries management in line with best scientific advice. Therefore, the usual recommendations remain unchanged: fishing opportunities must be set at or below MSY levels, or in accordance with the ICES data-limited precautionary approach where data is lacking. In fact, all TACs should be set at more precautionary levels to accommodate for uncertainties (e.g. unreported discards), inter-species interactions, and the increasing and cumulative pressures on marine ecosystems, such as climate change and pollution. To do so, the EU must notably work towards SSB levels of at least 40%, aiming for SSB50% for all EU stocks. In mixed fisheries, this means protecting the most vulnerable stock (i.e. by setting TACs of all species accordingly, or through area closure). WWF welcomes the EC’s willingness to further speed up work on the ecosystem effects of fishing. As rightly pointed out, the persisting control and enforcement challenges regarding the landing obligation allow for illegal discarding and overfishing to continue, putting the sustainability and financial viability of fisheries at risk. This must be addressed by enshrining the use of remote electronic monitoring tools within the revised Control Regulation, which provides the most effective and cost-efficient manner to improve monitoring and enforcement, paving the way towards a culture of compliance in all EU sea basins. Until then, the landing obligation cannot be assumed to be fully complied with and TACs must be set accordingly. Investments are needed to develop facilities to collect, manage and transform what should be compulsorily landed. Improving selectivity remains a critical necessity to reduce unwanted catches, and promote the implementation of the landing obligation. The EC’s evaluation of MS’ progress in implementing current by-catch reduction measures will support this. Nonetheless, the move towards more selective fishing techniques, and more generally towards low-impact fisheries, remains too slow and must be better incentivized. Whilst STECF concluded a slight improvement in the Mediterranean, it deplored the decreasing number of stock assessments, and fishing mortality remains more than twice above sustainable level. The data and reporting shortfalls must be addressed to ensure accurate and comprehensive management. The West Mediterranean MAP is, amongst others, a pivotal tool to ensure sustainable fisheries, but remains to be fully implemented. The 2025 MSY deadline is already a major drawback and simply cannot be missed. The communication reiterates that stocks that are sustainably caught lead to improved economic performances and salaries. This highlights the need to establish a better understanding of how socio-economic interacts with environmental sustainability. The socio-economic dimension of the CFP remains too often overlooked and insufficiently understood by policy-makers and stakeholders, yet such understanding is key to guide policies that will restructure the EU fishing fleet and ensure balance between fishing capacity and opportunity, which, as mentioned, is still far from achieved. The post COVID-19 recovery must include the recovery of EU fish stocks for the benefit of both people and the planet.
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Response to Action plan to conserve fisheries resources and protect marine ecosystems

13 May 2021

ANP|WWF belives that the Action Plan (AP) must ensure the full and coherent implementation of both EU fisheries and environmental regulations, along with sufficient funding, to protect and restore the marine environment for the benefit of people and the planet. Specifically: -Address bycatch through the adoption of selectivity measures; spatial and temporal closures; collection and publication of data using REM; and the mandatory use of mitigation measures for all fish products consumed in the EU. This must be set up urgently for populations of all ETP species. The AP must include SMART targets on bycatch reduction. The EU must also update and harmonise the species list that should be managed and protected by the different EU policies in line with the best scientific advice and other lists of ETP species (e.g. CMS, CITES). -Develop a network of a 30% minimum effectively managed protected MPAs with at least 10% strictly protected, designated/improved to maximise and prioritize biodiversity protection and ecosystem restoration, according to the best available scientific advice. MPAs must also be created to protect the seabed and reach GES for seabed integrity under the MSFD. -EBM must finally be implemented based on the rules of the CFP art.2(3). The EU must make use of CFP arts.11, 18 and 8, inter alia, to protect marine ecosystems in compliance with the MSFD, the BHD and other environmental regulations. -To restore ecosystems, meet GES and align with the ambitions of the Biodiversity Strategy, limit the use of fishing gear most harmful to biodiversity by restricting and phasing out non-selective, harmful fishing gear and operations in EU waters and by EU operators, notably mobile bottom contacting gear. -The AP must be used to align marine policies with the EU climate ambitions. -Low-impact fishing must be better defined, funded (e.g. EMFAF, NextGenEU) and incentivized. Art.17 must be observed to ensure allocation systems are fair and transparent, and include clear environmental, compliance, economic and importantly, social criteria. The AP must ensure a just and fair transition. -The CFP’s MSY objective must be achieved by ensuring fishing limits are set at a maximum of BMSY (with BMSY at a minimum of 50% of Bmax) and reach SSB levels of 40% (aiming for 50%) for all EU stocks, to account for their ecological role and provide a buffer for climate change. -To fulfil their role as tailored, ecosystem-based conservation measures based on the precautionary approach, MAPs must cover all fisheries comprehensively and include clear environmental and socio-economic objectives. They must also include selectivity and bycatch mitigation measures. -Adopt the necessary fisheries management measures under art.6 of the Habitats Directive and as per CFP art. 11, and ensure the TMR implementation is in line with biodiversity objectives. -Reduce fishing effort through temporal and spatial fisheries measures, including FRAs that can be counted as OECMs and contribute to the EU biodiversity/restoration targets, and integrate fisheries management measures in all MPAs. -Align the internal and external dimensions of the CFP. In RFMOs, this means improved and harmonized management measures and standards by promoting EBM; data collection and traceability tools; better target reference points; and bycatch reduction measures; more transparency and better anti-IUU measures. SFPAs must be inclusive in their development and implementation, and ensure transparency and sufficient data collection. -Fisheries products, both fresh and processed, must be traceable from ‘bait to plate’ using an effective digital system to create transparency, improve consumer information and help tackle IUU fishing and food fraud. The EU must reach a level playing field in terms of sustainable requirements between EU and non-EU operators. -Fisheries control must be improved by mandating REM, e-logbooks and tracking vessels in all fisheries segments.
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Response to Access to Justice in Environmental matters

10 Dec 2020

Delivery of the Green Deal depends on the implementation and enforcement of EU environmental law by EU institutions. To ensure compliance in practice, the EU needs strong mechanisms that allow civil society to hold EU institutions to account when they fail to deliver for the environment and human health. Presently, there are no effective means for the public to seek judicial review of EU acts that breach environmental law. We therefore welcome the Commission’s proposal to amend the Aarhus Regulation as a first step in remedying this situation. However, it needs to be significantly improved by the co-legislators. As it stands, it fails to ensure meaningful accountability of the EU institutions, the EU’s compliance with its international law commitments under the Aarhus Convention and effective delivery of the Green Deal. It is widely accepted that the internal review mechanism contained in the Aarhus Regulation does not work because the definition of the acts that can be subject to review is too narrow. Since its adoption, the vast majority of the almost 50 NGO requests for internal review brought to the Commission were rejected as inadmissible and never assessed by the EU courts. For instance, the following Commission decisions are currently excluded from internal review: • Decision to approve active substances that can be used in pesticides, such as glyphosate, which has been labelled as “probably carcinogenic”; • Decision to approve the list of new fossil fuel energy infrastructure projects (the so-called PCI list); • State aid decisions that fuel climate change; • Decisions regulating real time emissions tests for motor vehicles; • Decisions setting the total allowable catches of fish stocks in EU waters. Rather than ensuring that these acts can be subject to review in the future, it is unclear whether the Commission’s proposal would remedy or maintain this situation. This is unacceptable. When EU bodies do not respect the laws made by the European Parliament and the Council, it must be unequivocally clear that the public can hold them to account. This is also a matter of international law. The Aarhus Convention Compliance Committee found the EU to be in violation of the access to justice provisions in the Convention. Unless it is improved, the EU will continue to be in breach of the Aarhus Convention. The co-legislators need to amend the following aspect of the Commission’s proposal to remedy this situation: 1. Make acts that entail “implementing measures” and all acts that produce legal effects subject to internal review (Art 2.1g). The proposal’s definition of what constitutes an “administrative act” contains unjustified and unclear exclusions which could insulate many, if not most, acts of the EU bodies which contravene environmental law from review. This would undermine the benefit of the amendment. 2. Make State aid decisions subject to internal review (Art 2.2). The CJEU has explicitly confirmed that the Commission needs to ensure that its State aid decisions only authorise projects that comply with EU environmental law. NGOs must therefore be able to request an internal review if there is evidence that the Commission may have failed to do so. 3. Introduce cost protection and effective court review (Art 12). The proposal does not give NGOs cost protection when they lose in front of the Court, nor does it ensure that the Court will look at all of the substantive and procedural claims that an NGO may bring forward. Both of these issues are barriers to obtaining effective court remedies that need to be addressed in this amendment process. Last but not least, the EU has formally sought the Compliance Committee’s advice on whether the proposal would address its non-compliance with the Aarhus Convention, which is due to be delivered in Dec2020. We call on the co-legislators to take the Committee’s advice into due account. A more detailed analysis & suggestions for amendments are contained in the attachment.
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Response to Offshore renewable energy strategy

13 Aug 2020

According to the latest science, the world is on a sinister course for an increase in global average temperature of over 3°C by 2100, with catastrophic consequences for human and natural life. To limit global temperature increase to 1.5°C as set in the Paris Agreement, the EU must reach climate neutrality by 2040, thereby eliminating fossil fuels and achieving a 100% renewables-based energy mix as soon as possible. The EU 2030 climate and energy targets are insufficient to meet this objective and so the European Commission’s offshore renewable energy Strategy should announce a revision of the Renewable Energy Directive by 31 June 2021. The Communication ‘A Clean Planet for all’ recognizes that increasing offshore renewable energy production will be an essential part of the future energy transition towards a resilient and fully decarbonized economy. Huge efforts are needed to set up the enabling conditions at EU level for increasing substantially renewable energy capacity during this decade. The strategy should aim to encompass and distinguish between all forms of offshore energy production, such as offshore floating wind power and offshore floating solar power, which will require different regulatory approaches both in terms of environmental impact as well as financial support for innovation and deployment. The Strategy must also recognize the importance of regional cooperation and planning at a sea-basin scale and propose the establishment of regional High Level Groups based on the North Sea Energy Cooperation example for the Baltic Sea, the Black Sea and the Mediterranean Sea. Given the limited sea space and the electricity-intensity of hydrogen, priority should be given to direct electrification with renewables and shifting away from gas. Both onshore and offshore renewable hydrogen shall only be produced from a surplus of renewables capacity. The clean transition is overall expected to be positive for jobs, and the Strategy must ensure that renewable value chains, such as the manufacturing of offshore renewable infrastructure, benefit regions which have been negatively impacted by the transition. Climate change will increasingly pressure the ocean, its ecosystems, and the services it provides to our societies. Besides, European seas already count amongst the most intensively used in the world and fail to reach Good Environmental Status and effective spatial protection targets. When developing offshore renewables, it is crucial to adopt an integrated approach, use marine space carefully and support ocean resilience by staying within ecosystem boundaries. As a first principle, future renewable energy developments should not be placed within Marine Protected Areas (MPAs) and other ecologically valuable areas for sensitive species and habitats and/or providing climate refugia. In countries where renewable energy projects already lie within MPAs or are at the stage of having an environmental impact and appropriate assessment carried out, the environmental impacts of these projects should be robustly assessed on a case-by-case basis according to the relevant nature conservation legislation, science-based and subject to the precautionary principle. Offshore renewables development must be included in ecosystem-based marine spatial plans factoring the cumulative impact assessments of other large-scale human activities on both national and regional scales and guided by sensitivity mappings. Based on a participatory approach, it also needs to consider socio-economic factors. It must be complemented with a robust and independent monitoring of impacts, favor best-proven technologies and be accompanied by broad-scale research into new technologies to address any adverse impacts on the marine ecosystems. Finally, the Strategy should be developed in alignment with a coherent action plan for marine conservation and restoration, consistently articulated with existing European and international conservation policies and targets.
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