Although blue flag uses the word beach all through their papers i can´t find
any direct equirement that there really have to be sand. Maybe the
availability requirement demands that there are a slope into shallow water
rather than ladders directly into deep sea.

A sidetrack:
Regarding the tagging of bathing waters, I have also been doubtful of the
use of natural=beach to tag a bathing place but I have come to terms with
the use of leisure=beach_resort even if there is no beach or it isn´t a
resort.

There are some discussion on the matter at
http://lists.openstreetmap.org/pipermail/tagging/2012-March/009542.html. As
lesiure=bath was to general I made a proposal at
http://wiki.openstreetmap.org/wiki/Proposed_features/sea_bath.

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