CCB´s submission to the EU Call for Evidence on the EU Marine Strategy Framework Directive (MSFD)

CCB • March 10, 2026

Uppsala, March 2026 - CCB has closely worked with the implementation of the EU Marine Strategy
Framework Directive (MSFD) ever since its adoption and welcomed the opportunity to give feedback to this crucial directive for marine biodiversity and ocean health through the EU Call of Evidence.


Evaluations conducted by the EU Commission previously found many positive effects for EU marine waters stemming from the directive, but also that the directive has some shortcomings. CCB however, maintains that the largest obstacle to fully implementing the directive and achieving Good Environmental Status (GES) is the lack of political will among Member States to do so. This forthcoming revision must therefore result in a framework directive that is more easily enforceable, measurable and implementable, accompanied by sufficient funding to carry out the measures.

Furthermore, in order to achieve GES as fast as possible other key pieces of EU legislation must also support reaching it and focus on achieving the goals of the MSFD in their objectives. Seeing that European seas generally are in poor condition and under mounting pressure from human activities and that in the Baltic Sea the situation is especially dire there is an urgent need for truly ecosystem-based management of our seas and for reaching GES. The revised MSFD can help us achieve this, but only if it includes the points outlined below and the directive is fully and swiftly implemented:


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  • Operationalise the overarching GES goal:

EU sea areas were supposed to reach GES already in 2020, but due to low political ambition, sadly did not do so. Member States should therefore strive to reach GES as fast as possible now. Setting a new overall deadline for when to reach GES is not the answer on how to achieve this goal most efficiently, instead tools that address pressures and measure progress and ensure actual, timely implementation of ambitious measures must be included in the revised directive in order to operationalise achieving the overall GES goal. CCB therefore recommends making the existing and forthcoming threshold values for the descriptors and their criteria legally binding and part of the main directive.

  • Improving regional coordination and implementation:

To improve the coherence, coordination and effectiveness of MSFD implementation, assessment of GES, monitoring and the national PoMs the role of the Regional Seas Conventions (RSCs) must be clarified. CCB would welcome collating all the national PoMs into one regional PoM for the Baltic Sea, which should be aligned with, in addition to reaching the goals of the MSFD, with achieving the goals of the Baltic Sea Action Plan (BSAP).

  • Land-sea interface:

For the Baltic Sea to achieve GES it is key that land-based pressures, primarily nutrient runoff from agriculture causing severe eutrophication, is also addressed and that implementation of the MSFD goes hand in hand with the implementation of the Water Framework Directive (WFD). The goals of the MSFD and achieving GES should also be included when implementing and shaping the Common Agricultural Policy (CAP), as well as any synergies with implementing the EU Zero Pollution Action Plan which are also important to identify and utilise. The Baltic Sea also has a too high prevalence and level of other pollutants and hazardous substances affecting marine life.

  • Fisheries and aquaculture:

As one of the main pressure factors on the marine environment in general, as well as in the Baltic Sea, fisheries and aquaculture and the effects they have on the marine ecosystem and its biodiversity must be addressed in order to achieve GES. This is especially crucial when considering the MSFD descriptor for Biodiversity (D1), Fish and Shellfish (D3), Food webs (D4) and the one for Seabed integrity (D6).

  • Climate change:

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 and the full implementation of the MSFD and achieving GES. The effects of the climate crisis should be accounted for when setting pressure reduction targets and threshold values for the descriptors and their criteria, in a way that when an effect cannot be measured nor predicted the precautionary principle must be used.

  • Revising Art. 14 of the MSFD:

Article 14 in the MSFD outlines the acceptable exceptions when reaching GES is not possible. The article needs to be revised in the forthcoming revision, since it contains too many and too broad in scope possibilities for exemptions (e.g. in Art. 14(4)), which jeopardise the implementation and fulfilment of the directive as a whole. A possible way of modifying it would be to introduce an obligation for Member States to demonstrate that they have taken all measures within their control nationally and that they have tried to address the problem and advance solving it on a regional level through cooperating with other Member States, before they can apply for a possible exemption.

  • Make the Programme of Measures contain ambitious & concrete measures:

One of the cornerstones of the MSFD is the national PoMs that are published every six years and are precluded by an assessment of GES in national waters and a monitoring programme. Unfortunately, the current approach to PoMs where Member States freely can choose measures has led to an overall too low level of ambition in the PoMs, and to large differences within regions and between neighboring countries in terms of which measures are included. In order to fully implement the directive and to achieve GES it is of paramount importance that the national PoMs have a high level of ambition and contain concrete, implementable measures and that there is regional coordination.

  • Easing the reporting burden:

One of the results from the evaluation of the MSFD was that the current reporting burden is considered to be too high and a possible way to address this is to align the reporting obligations of the MSFD to more reassemble those of the WFD, that has a more simplified 6-year cycle compared to the MSFD. The implementation cycle however should not be revised or at least not in a way that delays reaching GES.

  • Improve coherence with other legislation:

To ensure that the revised MSFD is fully implemented it is essential that coherence with other relevant legislation is improved. The MSPD (foundation for the forthcoming Ocean Act) is also currently being revised and to reach the goals for both the directives achieving GES needs to be a cornerstone of the Ocean Act. This is the only way to deliver truly ecosystem-based management of our seas, and the revision of both directives should therefore be coordinated and focused on achieving GES.


CCB looks forward to continuing to provide input to the revision process of the MSFD as well as working with the implementation of the MSFD, especially in the Baltic Sea. CCB expects that the revision will result in a more enforceable directive that leads to the fast implementation of ambitious measures to improve the state of the Baltic and European Sea areas and to the achievement of GES.


The full text of the submission is available here.


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Links to supplemental documents supporting our positions:

NGOs Welcome European Commission Decision to Stick With Common Fisheries Policy in 2027 Workplan, Urging Attention on Full Implementation

November 5, 2026
Brussels, 4 November 2026: Environmental NGOs welcome the European Commission’s decision to not include a revision of the Common Fisheries Policy (CFP) in its 2027 Workplan, announced today, and call on the Commission to maintain this course. To improve ocean health and biodiversity, BirdLife, BLOOM, Coalition Clean Baltic, ClientEarth, Environmental Justice Foundation, Oceana, and Seas At Risk urge the Commission to prioritise full implementation and enforcement of the existing CFP to rebuild fish populations, protect marine ecosystems, and secure a sustainable future for fishers and coastal communities. “The Commission has rightly chosen to follow the findings of its own CFP evaluation , published in April this year, and to focus on holding Member States accountable for implementing the law”, said the NGOs. “Reopening a policy that has not yet reached its full potential would halt timely implementation, waste valuable time and delay the meaningful action that European fishers and marine ecosystems urgently need.” A competitive and resilient fisheries sector can only be built on: healthy fish populations; a system that gives a fair share of space and resources to fishers that have a low impact on the marine ecosystem; and a fleet that is enabled to make a just transition to lower environmental impact, reducing dependence on subsidised fossil fuels, and responding properly to the climate crisis. The CFP outlines a precautionary pathway forward, centering fisheries management on scientific advice and ecosystem protection, minimising the impact of fishing on the marine environment while aiming to provide a sustainably sourced food source for people throughout Europe. “The European Commission must now demonstrate its political ambition by delivering on the CFP, which will allow fish populations to recover, will help achieve food security, along with the wellbeing of European fishers and coastal communities, and protect ocean health”, said the NGOs. “With imminent annual fisheries negotiations between the Commission, Member States and third countries, including the UK and Norway, this will be a key opportunity to finally close a major CFP implementation gap by setting fishing limits that are geared towards rebuilding struggling fish populations and fisheries.” The environmental NGOs call on member states to cooperate with the European Commission on stronger implementation measures to fulfil the objectives of the CFP, and put European citizens and environment at the heart of their position going forward.

NGOs urge stronger action as 2027 Baltic Sea fishing limits fall short of securing full recovery of fish populations

By CCB • October 27, 2026
27 October 2026 , Luxembourg - EU fisheries ministers increased central Baltic and Bothnian herring catch limits beyond the European Commission’s proposals and significantly increased the sprat catch limit, falling short of the precaution needed to protect the role of herring and sprat in the Baltic Sea food web. The Council also rejected proposed cuts to accidental catches of severely depleted cod and western Baltic herring populations. NGOs warn that fishing limits remain too high and urge EU ministers to follow the agreement with concrete plans to rebuild depleted fish populations. Herring: further measures needed to safeguard fragile recovery and protect vulnerable populations EU fisheries ministers increased the catch limit for central Baltic herring to 165 228 tonnes, a 71% increase compared with 2026. The population has shown signs of improvement after years of depletion. However, the central Baltic herring population remains vulnerable, and rebuilding must restore healthy age and size structures as well as overall abundance. Although below the scientific headline catch advice, the Council’s decision exceeds the Commission’s proposal, which was more precautionary and recovery-oriented and should have been followed by the ministers. “Ministers have recognised the need for caution, but still allowed more herring to be caught than the Commission proposed. These vulnerable populations need a stronger chance of lasting recovery, with clear rebuilding targets, a timetable for reaching them and measures that are implemented and enforced ,” said Cathrine Pedersen Schirmer, Senior Fisheries Policy Advisor at Coalition Clean Baltic. For Bothnian herring , ministers retained the three-month spawning closure but increased the Total Allowable Catch (TAC) by 12% , despite the population remaining below healthy levels. The Commission’s proposed TAC for this fish population was already a compromise between population rebuilding and maintaining fishing opportunities. The agreed higher TAC poses a risk to the recovery of the Bothnian herring population and creates increasing uncertainty for the industry. “ Fisheries decisions must also account for the risks to fish population recovery. Even catch limits within the ICES advice range can leave stocks at risk of remaining below the biomass levels that should trigger recovery measures. Fishing opportunities must give depleted populations a real chance to recover to healthy level s,” said Beatrice Rindevall, Chairperson of the Swedish Society for Nature Conservation. The Gulf of Riga herring TAC was also set above NGOs’ recommendations, with an increase of 11% compared with 2026, despite the recent decline in its spawning biomass and its importance to the Baltic food web. Lower limits for this fish population would have better supported population health and long-term resilience. Sprat: recovery must extend to the Baltic Sea food web The sprat agreement remains a significant concern. The Council’s decision, in line with the Commission’s proposal, to increase the sprat catch limit by 44% to 291 590 tonnes exceeds the level NGOs recommended. Although the population has increased, the agreed limit does not sufficiently account for sprat’s importance as prey for cod, salmon, seabirds and other marine wildlife, persistent catch misreporting or the risk of catching vulnerable herring alongside sprat. “ Herring and sprat are vital to the Baltic Sea ecosystem. When setting fishing opportunities, decision makers must leave enough prey in the water to support predators like cod and salmon, to rebuild ecosystem health and align with the EU’s nature restoration ambitions ,” said Justyna Zajchowska, Fisheries Lead for WWF Baltic Sea Programme. Salmon: no increase in catch limits, but stronger protection needed NGOs welcome the decision not to increase salmon fishing opportunities. However, fishing should be restricted to compensatory hatchery-released salmon or salmon from rivers where populations are at full reproductive capacity. Fishing on vulnerable wild populations must be avoided and, if returning salmon numbers are insufficient, additional adaptive management measures should be deployed immediately, considering the impact of recent poor spawning runs. “ Good returns to some large rivers are encouraging, but they do not demonstrate recovery across the Baltic region. Many smaller river populations remain in serious difficulty. We need fishing restrictions that protect those vulnerable salmon throughout their migration and allow enough fish to reach their spawning grounds ,” said Thomas Johansson, Chairman of Östersjölaxälvar i Samverkan and Secretary General of the Baltic Salmon Fund. Cod, western Baltic herring and plaice: Council misses opportunity to curb bycatch Both Baltic cod populations and western Baltic herring remain severely depleted. Targeted cod fisheries remain closed, while ministers retained the small-scale fisheries exemption for western Baltic herring. Yet ministers agreed bycatch quotas well above the Commission’s proposals for 2027 and at the same level as 2026, falling short of the protection sought by NGOs. For all three populations, the agreed bycatch quotas permit continued catches despite ICES advice for zero catch. The Council’s decision to increase the plaice TAC to 11,237 tonnes , well above the level NGOs recommended, missed an opportunity to secure a reduction in accidental cod catches. The decision also does not reflect the very low reported landings of this species. Declining weight and condition of plaice also warrant greater caution. The TAC must be combined with effective enforcement of mandatory selective gear to reduce cod bycatch and the implementation of the landing obligation. Annual fishing limits must support lasting recovery The Council’s decisions on Baltic Sea fishing opportunities for 2027 are not ambitious enough to secure restoration of all Baltic Sea fish populations. These decisions should be seen in the context of last year’s joint commitment by the European Commission and Baltic Sea Member States to seek dedicated scientific advice from ICES on rebuilding pathways for fish populations. In the absence of such rebuilding-oriented advice, and whilst we are waiting for it, decisions should be more cautious and based on the available recovery-focused catch options provided by the scientists in their traditional advice. Fisheries management must also support EU marine restoration objectives and the achievement of good environmental status in the Baltic Sea. Restoring fish populations and food webs is essential to the recovery of the sea itself and to the long-term future of Baltic fisheries and the coastal communities that depend on them. ENDS *** Further information: Link to Council decision Link to Commission’s proposal Link to Joint NGO recommendations on Baltic Sea fishing opportunities for 2027 Media contact: Beatrice Rindevall, Chairperson, Swedish Society for Nature Conservation, ordforande@naturskyddsforeningen.se Cathrine Pedersen Schirmer , Senior Fisheries Policy Advisor, Coalition Clean Baltic, Cathrine@ccb.se Justyna Zajchowska , Fisheries Lead, WWF Baltic Sea Programme, jzajchowska@wwf.pl Dr. Katja Hockun, Senior Expert Meeresschutz, Deutsche Umwelthilfe e.V., hockun@duh.de Konrad Stralka , Executive Director, BalticWaters, konrad.stralka@balticwaters.org Magda Jentgena , Baltic Sea and Freshwater Programme Manager, Pasaules Dabas Fonds, mjentgena@pdf.lv Regan McEnroe , Chairperson, Nature and Youth Sweden, ordforande@faltbiologerna.se Tapani Veistola, Executive Director, Suomen luonnonsuojeluliitto (Finnish Association for Nature Conservation), tapani.veistola@sll.fi Thomas Johansson , Chairman, Östersjölaxälvar i Samverkan, and Secretary General, Baltic Salmon Fund, thomas@balticsalmonfund.com .