As requested by NGOs in the initial consultation, deep-sea mining (DSM) should be explicitly excluded from the scope of the Critical Raw Materials Act (CRMA), including explicit exclusion from the criteria of Strategic Projects. In the Commissions proposal, whether DSM is included in the scope of the Regulation or whether DSM operation could be given priority status as Strategic Projects is concerningly unclear.
EJF
Environmental Justice Foundation
Environmental organization · Belgium · EU Transparency Register 817535514065-10
7
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #211 by legislative files engaged, a count of participation, not a measure of influence.
16.4
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
5
EP accreditations
as declared to the register
2014
in the register since
Declares membership of
- The EU IUU Coalition.
- The Deep Sea Conservation Coalition.
- The Transform Bottom Trawling Coalition.
- The Coalition for Fisheries Transparency.
- The Med Sea Alliance.
- Import Control Group.
- Oceans & Bottom trawling campaign steering group of Patagonia campaign.
- Climate Action Network (CAN)
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Head office
- London, United kingdom
- EU office
- Berlin
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Environmental Justice Foundation filed 7 positions between 24 Nov 2022 and 20 Jul 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2023 · 1 filed2025 · 1 filed2026 · 4 filed
What they argued
EJF is an international non-governmental organisation working to protect the natural environment and human rights. EJF has offices in Brussels, Germany and the UK as well as on the African and Asian continents. The security of supply of critical raw materials is of paramount importance to any state or state-like entity.
The Ocean Act offers a crucial opportunity to move EU ocean governance from planning and designation to implementation and delivery. While the MSPD has been important in organising maritime space and coordinating uses, its effectiveness in translating strategic goals into concrete, ecosystem-based management outcomes has been limited.
The revision of the Marine Strategy Framework Directive (MSFD) is a critical opportunity to strengthen the EUs core framework for marine environmental protection and to move towards measurable ecological delivery.
The Environmental Justice Foundation (EJF) thanks the Commission for the opportunity to provide input on the call for evidence on the revision of fisheries management rules (Omnibus) and the Multiannual Management Plans (MAPs).
EJF welcomes the opportunity to provide evidence in preparation for the European Commissions initiative to amend Regulation (EU) 2021/1139 establishing the EMFAF, including the objective of completing implementation.
EJF protects marine ecosystems, biodiversity, and the livelihoods they support. We promote sustainable, legal, and equitable fisheries, combat illegal and destructive practices, and advocate for MPAs that enhance biodiversity, climate resilience, and community well-being, placing grassroots defenders at the heart of our approach.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
Showing 5 of 65.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.