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• Coherence: Align the goals and existing timelines of EU marine legislation, policies and strategies in the Act and make them binding. Furthermore, the Ocean Act must stipulate that national maritime spatial planning has to address all existing and emerging pressures, such as shipping, underwater noise, mining, gravel and sand extraction, Offshore Renewable Energy (ORE), Carbon Capture and Storage (CCS), tourism, aquaculture and commercial and recreational fishing.
• Breaking silos: The Act must foster collaboration between different agencies and ministries in national governments implementing it, by e.g. stipulating that its implementation should be shared between the environmental and fisheries ministries and that relevant ministries and agencies must consult each other.
• Targets for national & regional MSPs: The Act should mandate legally binding national MSPs as well as regional MSPs for each sea basin, where at a minimum all the national plans are collated and harmonized, leading to strengthening of regional cooperation, data sharing, and in the long-term to regional maritime spatial planning.
• Regional Considerations: Acknowledge and address regional challenges, which for the Baltic Sea include the severe effects from eutrophication, mainly due to nutrient runoff from land-based sources, primarily from agriculture, as well as the high levels of other pollutants and hazardous substances. The poor state of the Baltic Sea ecosystems and fish stocks must also be tackled. Climate change is also affecting the Baltic Sea faster than other marine regions and must be factored in when managing the sea area and its resources, to ensure EBM.
• Strengthening the role of RSCs: To improve coherence, coordination and effectiveness of marine governance the role of the Regional Seas Conventions in implementing the Act and EU marine legislation must be strengthened.
• Ocean Act adopted as a regulation: To ensure its swift and coherent implementation across EU seas in all Member States the Act should be adopted as a regulation instead of a directive.
• Land-sea interface: requirement in the existing MSPD must be strengthen in order to ensure that land-based activities don’t have detrimental impacts on the marine ecosystems. It is also important to include land-based efforts when planning for costal and marine restoration, a so-called Source-to-Sea approach, to ensure effective recovery of the Baltic Sea ecosystems.
• Fisheries and aquaculture: must be included in the national and regional MSPs as activities and pressures that are planned for in a way that reduces their impacts on the ecosystems, sensitive species as well as all harvested species. Likewise, aquaculture prohibition zones should also be implemented, as these can have considerable impact on achieving GES. The Ocean Act should align and support achieving the goals of the CFP regarding rebuilding fish stocks and ending overfishing. The Ocean Act must furthermore require that national and regional MSP map all essential fish habitats and that negative impacts on these by other sectors using the sea, including fisheries, are mitigated. In addition, zoning should prioritise restoration of essential fish habitats.
• Climate change: the EU goals for reducing greenhouse gases and reaching climate neutrality (as outlined in the European Climate Law and the EU Green Deal) should also be aligned into the Act and planned for when implementing it. Furthermore, national and regional MSPs should include climate change resilient spatial planning.

The full text of the submission is available here.

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Links to supplemental documents supporting our positions:

-Guiding Recommendations for Source-to-Sea Restoration in Riverine, Coastal, and Marine Ecosystems (Coalition Clean Baltic, 2025)

- Position Paper on Marine Protected Areas (Coalition Clean Baltic 2024)

- Don’t sink the Common Fisheries Policy – fulfil its potential (joint NGO Briefing 2025)

- Blue Manifesto (joint NGO paper)