Gallifrey Foundation

The European Ocean Act must directly confront unsustainable fishing practices and harmful subsidies as the primary drivers of European ocean decline. Bottom trawling is an urgent crisis that causes catastrophic environmental and climate damage: - Releases 340-370 million tons of CO2 annually from disturbed seafloor sediments - emissions rivaling entire nations - Costs European society 10.8 billion annually, far…

We welcome the Commissions European climate resilience and risk management initiative and its ambition for a comprehensive, science-based framework for preparedness and regular risk assessments. Scope and global responsibility Climate impacts and risks cross borders.

Please find herewith our input and commentary points for EU Single Use Plastics Directive Implementation: 1. Draft Fails Core Environmental Objectives Issue: The proposal allows recycled content claims without ensuring materials actually return to plastic production, contradicting the Directive's circular economy goals.

True economic sustainability requires healthy marine ecosystems. The EU strategy must prioritize biodiversity protection, bycatch reduction, and genuine partnerships over market access advantages. Key Reforms Needed 1.

++ The proposed amendment introduces a Unintentional Trace Contaminant (UTC) limit for polychlorinated biphenyls (PCBs), addressing legal uncertainty by setting a 0.2 mg/kg threshold for most substances and a gradual reduction for organic pigments and dyes from 25 mg/kg to 10 mg/kg over three years.