Seas At Risk

We welcome the EU Circular Economy Act (CEA) as a potential for a coherent framework for sustainable resource use. However, in its current direction, the proposal risks falling short of this potential. According to the International Resource Panel (2024), global resource use is projected to grow by 60% by 2060, threatening to derail progress on climate, biodiversity and prosperity.

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.

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.

Seas At Risk welcomes the revision of the EU Emissions Trading System and Market Stability Reserve as a vital step toward climate-aligned, ocean-safe shipping. We strongly support extending the ETS to smaller maritime vessels (4005,000 GT), which make up a significant share of emissions and operate close to coasts and communities.

The EU umbrella NGO network of marine organnisations SEAS AT RISK is taking part in the implementation of the second OSPAR's Regional Action Plan on marine litter and actively engaged in a specific action of this action plan addressing single-use plastics.

Protecting nature will not be enough to reverse biodiversity loss - the world needs to be more ambitious on nature restoration. Nature restoration is already partially required from the Member States in existing EU legislation. However, significant implementation and regulatory gaps hinder progress, and stronger implementation support and enforcement is required.

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.

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.

The Seas At Risk marine NGO network is pleased to share feedback on the draft Implementing Decision laying down rules for the application of the EU Directive 2019/904 as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles.

SEAS AT RISK welcomes a consultation of this implementing act of the Single-use plastics' Directive. First, we would like to underline a problem in the calculation baseline between the proposal under consultation and the SUP Directive. In the articles 3.1 and 4.1 of the proposal, the weight of plastic is calculated based on the amount of plastic collected from economic operators.

Seas At Risk welcomes the opportunity to provide input to the consultation on the European Grids Package. Through the following recommendations, we aim to ensure that the upgrade and expansion of grid infrastructure at sea is done with minimal impact on the marine and coastal environment (please consult the attached document for further details): 1. Halve energy demand by 2040; 2.

As seen in attached policy paper, Seas At Risk highlights nine critical policy areas that the EU will need to consider as part of the review of its EU Arctic Policy. The EU should support the development of a dedicated international governance framework for the Central Arctic Ocean.

Seas At Risk welcomes this opportunity to share its insights on CO2 transportation infrastructure and markets. The past decade, several scientific warnings have been issues about the significant risks that Carbon Capture and Storage (CCS) poses to the marine and coastal environment. These include risks related to pipeline construction, port expansion, seismic surveys, increased ship traffic, and ocean storage.

Pleasse find attached the full contribution of Seas At Risk to the Call for Evidence on applying the DNSH principle under the next MFF, it notably highlights the need to transform DNSH into a binding, enforceable eligibility condition across all EU funding instruments, ensuring that public spending is fully aligned with environmental objectives.

This Vision for the Future of Fisheries, attached to this contribution, is the result of a three-year multi-stakeholder process involving environmental NGOs, low-impact fishers and scientists, who came together to co-develop a shared vision for a fair, resilient and sustainable future for the sector, under Seas At Risk Future of Fisheries project (2023-2025).

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)…

Seas At Risk's response to the European ocean research and innovation strategy consultation, 31 July 2026 Seas At Risk (SAR) welcomes the opportunity to input to the call for evidence on the development of an ocean research and innovation strategy.

At its adoption in 2008, the MSFD offered an ambitious and holistic framework for the restoration of the marine environment and the eco-system based management of human activities at sea. In practice however, implementation by Member States has been weak, due mainly to lacks in political will, poor funding and limited enforcement.

Please find attached the full contribution of Seas At Risk on the Call for Evidence on the revision of fisheries management rules through the proposed Fisheries Omnibus initiative. We consider that the current Multiannual Plans (MAPs) remain largely fit for purpose and that the main challenge lies in their insufficient and inconsistent implementation, rather than in shortcomings of the legal framework itself.

Please find attached the full contribution of Seas At Risk this call for evidence. Seas At Risk strongly supports transposing the WTO fisheries subsidies agreement in the current EMFAF (and the next MFF), however, the revision of the European Maritime, Fisheries and Aquaculture Fund (EMFAF) should not be regarded as a purely technical exercise aimed at transposing the WTO Agreement on Fisheries Subsidies and…

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.

Please find attached Seas At Risk's feedback on sustainable fishing in the EU: State of play and orientations for 2027 attached. This Briefing Series, supported by the 29 undersigned organisations, is designed to assist the responsible decision-makers in the European Union (the European Commission, the Council of the EU and the Member States) and the United Kingdom (the UK Government and devolved administrations) in…

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…

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…

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.

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.

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…