Joint NGO position on Baltic Sea internal loading

CCB • October 4, 2016

Baltic environmental NGOs, represented by Coalition Clean Baltic network consisting of 18 grass-root organizations from 11 countries in the Baltic Sea catchment and the WWF Baltic Ecoregion Programme forwarded for consideration of HELCOM Contracting Parties a joint statement regarding the issue of internal load in the Baltic Sea.

Some of the Contracting Parties state that most of the nutrient source reductions on land have already been achieved, for example through efficient sewage treatment and elimination of excess usage of fertilizer and manure in agriculture. Therefore, those countries consider further land-based reductions to have limited effects at high costs, instead arguing for innovative sea-based measures.

The environmental NGO signatories to this joint statement strongly believe that the real reason for promoting alternative, sea-based solutions to the eutrophication problem might be tightly connected with observed poor implementation of BSAP MAI/CART commitments and lack of will to enforce stricter HELCOM requirements at national level in comparison to EU law, by some Contracting Parties/EU Member States. Actually, the cost-efficiency of already applied measures in terms of delivering good environmental status for the Baltic Sea with regards to eutrophication has been very poorly assessed – both at national and HELCOM level, and the EU financial support mechanisms often cause continued high inputs of nutrients with minor consideration of environmental objectives for the marine environment.

This view is strongly backed by the findings of the recent EU Court of Auditors’ report “Combating eutrophication in the Baltic Sea: further and more effective action needed” ( 2016 ), echoed by the EU Council Conclusions on the ECA’s Report.

Our main points on this matter are as follows:

  1. Internal load is not a cause of eutrophication, but it is a consequence of numerous years of mismanagement of nutrient inputs from the Baltic Sea catchment.
  2. There is no evidence that the Contracting Parties have taken and implemented all relevant measures to reduce eutrophication, as agreed in HELCOM BSAP – especially from land-based sources, so there is no sense and need to change the path and turn to sea-based measures.
  3. Although positive effects of reduced land-based input could be seen in some coastal areas, there is still a need for further improvement, especially addressing diffuse runoff and losses from agriculture.
  4. Proposed sea-based measures to address internal loading have not proven to be (a) effective, (b) cost-efficient, (c) polluter-specific and (d) harmless at a larger scale and in a longer-term perspective.
  5. Very few end-of-pipe solutions have appeared to be more efficient than source reduction measures, hence the latter should be further promoted and supported.
  6. External nutrient reduction before entering the sea is the only truly effective long-term strategy to combat eutrophication.

Don't reopen the EU Common Fisheries Policy (CFP). Implement it.

By CCB • June 15, 2026
The European Commission's evaluation confirms what environmental NGOs across Europe have long argued: the Common Fisheries Policy (CFP)'s challenge is not its design, but its implementation.

Joint NGO recommendations on Baltic Sea fishing opportunities for 2027

By CCB • June 10, 2026
The poor status and decline of many Baltic Sea fish populations have been thoroughly documented over several decades, indicating that the entire ecosystem is in great distress. So far, policy interventions have not reversed, or even halted, the negative trend concerning many of these populations. The European Commission itself recently recognised in its Common Fishery Policy (CFP) evaluation report that progress on stock rebuilding is lacking and the number of stocks “ threatened by collapse due to impaired recruitment has increased during the reporting period ”. Fish populations that once formed the cornerstone of the Baltic Sea fishery, such as the eastern and western Baltic cod and the western Baltic herring, are now doing so poorly that the International Council for the Exploration of the Sea (ICES) is advising zero catch for these stocks. Yet, even with the targeted fishery being closed for some years now, none of these three stocks are showing sufficient signs of recovery. The condition (such as size and weight-at-age) of many flatfish populations, such as plaice, also raises alarm bells. The salmon spawning migration has fallen short of the target level in the past three years5. As a result, even the healthiest salmon stocks are now unlikely to produce enough smolts corresponding to sustainable levels in the coming years. To address the crisis facing Baltic populations and the broader ecosystem, political will and ambition to improve fisheries management, alongside full implementation of the CFP provisions, are needed. The recent INI report on the Baltic Sea Multi-Annual Plan shows that the European Parliament recognises the importance of ecosystem-based fisheries management as well as the need for consideration of environmental legislation when making decisions on fishing opportunities.6 Fisheries managers must now act swiftly and decisively on the commitment the Commission and Baltic Sea Member States made at last year’s October Agrifish Council to rebuild Baltic Sea stocks. This document presents the joint NGO recommendations regarding Baltic Sea fishing opportunities for 2027, prioritising long-term ecosystem health and sustainable fisheries management over short-term economic interests. The recommendations are based on the ICES advice, the objectives and requirements of the CFP8 and the Baltic Multiannual Plan (MAP), specifically to apply the precautionary approach and implement an ecosystem-based approach to fisheries management, and the objective of achieving Good Environmental Status (GES) under the Marine Strategy Framework Directive (MSFD). Last year’s overarching joint Briefing Series on TAC-setting, co-signed by almost 30 organisations across the EU and the UK, including environmental NGOs, recreational fishers, and fishing rights owners, remains valid and provides further context, background and detailed explanations on the cross-cutting issues raised in this document. Read the Joint NGO recommendations on Baltic Sea fishing opportunities for 2027 here .