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.
By CCB February 24, 2026
Coalition Clean Baltic – CCB is a politically independent network, uniting 28 environmental non-profit organizations, as well as partners and experts from 11 countries surrounding the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the environment and natural resources of the Baltic Sea region by encouraging new and constructive approaches and engaging people to become part of the solution instead of part of the problem. CCB Secretariat is based in Uppsala, Sweden. About the Role Coalition Clean Baltic (CCB) is seeking a Marine Policy Officer (parental leave cover) to join its International Secretariat and contribute substantively to regional and EU-level marine advocacy, with a particular focus on the Baltic Sea. The Marine Policy Officer will support the implementation of EU and international marine environmental policy frameworks — notably the EU Marine Strategy Framework Directive (MSFD), the EU Maritime Spatial Planning Directive (MSPD) and the HELCOM Baltic Sea Action Plan (BSAP) . All work is grounded in the promotion of ecosystem-based management. The role includes close collaboration with the rest of the Secretariat team as well as CCB member organisations to deliver policy initiatives, advocacy actions, and strategic programme objectives. The Marine Policy Officer will also support the International Secretariat in fundraising, with a focus on the EU LIFE operational grant application. Key Responsibilities Policy & Advocacy Support the implementation of CCB’s strategic plan on marine biodiversity policy. Contribute to marine policy advocacy at EU and at Baltic Sea regional levels (e.g. HELCOM, EU Commission expert groups). Provide input to the implementation and revision of the Marine Strategy Framework Directive. Collect evidence and views to provide NGO inputs to the forthcoming EU Ocean Act and related initiatives. Support the implementation of the Helsinki Convention and Baltic Sea Action Plan. Engage in the revision processes related to the Marine Spatial Planning Directive (MSPD). Programme & Grant Delivery Provide critical support in fundraising, i.e. project proposal development, especially for securing core grant funding (e.g. for the EU LIFE Programme and potentially Horizon programme). Contribute to CCB´s project management, implementation and reporting activities for various projects. Coordination & Monitoring Closely coordinate marine biodiversity policy work with CCB member organisations. Monitor global, EU, and regional marine policy developments. Liaise with partner NGOs and civil society organisations. Communications & Policy Products Draft position papers, policy briefings, consultation inputs and technical reports on relevant files. Support communications and outreach on marine policy issues. Help organise workshops, conferences, and stakeholder events. Represent CCB in policy dialogues, expert groups, and stakeholder forums at the EU and Baltic Sea level. Cross-organisational Support within the Secretariat and its members Contribute to other CCB thematic working areas as required. Profile We are seeking a policy professional who is: Solutions-oriented and adaptable Experienced in advocacy or campaigning Collaborative and team-driven Passionate about marine conservation Organised, diplomatic, and stakeholder-confident Required Qualifications & Experience Demonstrable professional experience in marine or environmental policy. Working knowledge of key EU frameworks, particularly the EU Marine Strategy Framework Directive (MSFD). Knowledge of Helcom BSAP is an asset. Postgraduate qualification in marine science, ecology, conservation, water management, or related discipline with substantial marine focus. Eligibility to work and travel within the EU (citizenship or valid permit) with residency in Sweden. Excellent written and spoken English. CCB also welcomes applicants from broader environmental policy/law backgrounds who can demonstrate relevant knowledge. Desirable Skills Experience within the NGO or civil society sector preferred. Advocacy or campaigning experience within the EU, the Baltic Sea or international environmental policy processes. Working knowledge of a Baltic Sea region language (e.g. Swedish, Danish, Finnish, German, Polish, Latvian, Lithuanian, Estonian).
By CCB February 19, 2026
Uppsala, February 2025 - CCB supports the Ocean Pact and Ocean Act objectives for improving coherence, coordination and effectiveness of EU ocean governance. Yet, in order to achieve this, the Act has to deliver truly ecosystem-based management of our seas and make reaching Good Environmental Status, as defined in the Marine Strategy Framework Directive (MSFD), a cornerstone of the Act. The Ocean Act can set us on a path to recovery of the marine environment under a sustainable and just blue economy, but only if the Act includes the points outlined below and is implemented swiftly and fully.