CCB´s submission to the EU Call for Evidence on the Ocean Act
CCB • February 19, 2026
Uppsala, February 2026 - 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.
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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)
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.
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 .
