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:

Job vacancy: Marine Policy Officer (parental leave cover) - closed

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).

CCB´s submission to the EU Call for Evidence on the Ocean Act

By 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.