Fisheries ministers poised to breach EU law and exacerbate Baltic ecosystem crisis, NGOs warn

CCB • October 19, 2023

On 23rd October, EU fisheries ministers will set Baltic Sea fishing limits for next year. Their decisions will likely breach EU law and worsen the dire state of the Baltic Sea, as Member States have made clear that they don't support cuts to Baltic fishing opportunities in order to bring them in line with legal obligations. NGOs are urging fisheries ministers to suspend the fishing of severely depleted stocks, as foreseen by EU law in these circumstances.

To prevent the collapse of fish populations, EU multiannual management plans require that fishing opportunities are set so that fish populations are at the very least kept above a minimum level (1). This year, due to persistent overfishing, scientific data shows that two herring stocks in the central and northern Baltic are now at or below this clear red line. Any targeted fishery on these herring stocks would be in breach of EU law. 


Detailed rules for how to set fishing quotas and agree on emergency measures, including the option of complete fisheries closures, are set out under EU multi-annual management plans, in line with the objectives of the EU’s Common Fisheries Policy (CFP). Following the rules of the Baltic multi-annual management plan and the status of these herring populations, the European Commission has proposed to close the targeted fishery for herring in these two areas. 


To date, however, Baltic Member States have argued that the Commission proposal is going too far, and have questioned the interpretation of the regulations in place. In doing so, the Member States are disregarding the very clear rules and the obvious fact that both these herring populations are below the agreed minimum levels.


Nils Höglund, Senior policy officer at CCB, said: “By aiming to evade the rules in the Baltic management plan and the CFP in relation to avoiding fish stock collapse, and pushing to keep what is largely a fishmeal fishery open, the Council is breaching both EU fisheries and environmental legislation, such as the Marine Strategy Framework Directive (MSFD). The possibility to reach good environmental status is likely made near impossible by the Agrifish Council. This approach must be deemed doubly illegal”. 


Sara Söderström, Policy officer at the Fisheries Secretariat, said: “The health of the Baltic Sea ecosystem depends on forage fish such as herring and sprat, which feed other fish, mammals and seabirds. It is clear that when we remove large amounts of biomass it disrupts the food web and negatively affects the age and size distribution of herring, defying the targets in both the CFP and the MSFD. If we are to achieve an ecosystem-based approach to fisheries management, a much more precautionary approach must be applied.” 


Bruno Nicostrate, Senior Policy Officer at Seas At Risk, said: “If EU Fisheries Ministers fail to comply with EU law not only will they contribute to the disappearance of Baltic herring populations, they will also pave the way for the decimation of other fish species. EU Member States must respect the very laws they have co-designed and signed up to and prevent this impending ecocide by putting a stop to fishing of endangered fish populations." 


Javier Lopez, Campaign Director of sustainable fisheries at Oceana in Europe, said: “It is inconceivable to see EU Member States attempting to set catch limits for Baltic stocks that ignore the very rules they have created themselves. Several populations of iconic species such as eastern Baltic cod and central Baltic herring are in a critical state and targeted fishing of them must stop. Ministers cannot cherry-pick the law for political expediency, but must rather apply it comprehensively for the sake of the health and sustainability of fisheries.”


ClientEarth marine wildlife and habitats lawyer Arthur Meeus said: “According to EU law, overfishing should have ended by 2020 for all stocks. Instead, overfishing of already depleted stocks continues not only in the Baltic, but throughout the EU’s seas. It is high time for a clear court decision to put an end to this systemic issue. Multiple court cases are already underway to get this much needed clarity and we are eagerly awaiting the first judgment of the Court of Justice of the European Union. This official ruling from the EU’s top Court will be crucial to finally give EU fisheries rules the teeth needed to ensure Member States can only manage fisheries in line with science and the law going forward.”



BACKGROUND 


Herring and sprat play key roles in the Baltic ecosystem as they are a food source for predators, like cod and salmon and also regulate plankton. Today, this valuable resource is mainly used for fish meal, rather than human consumption.

According to the latest scientific data, herring in the central Baltic Sea is in a critical condition with a disheartening outlook. The Bothnian herring is also in a critical state and experts note that even with a complete fishing closure, the stock will not recover in the short term. Article 4(6) of the Baltic multiannual management plan explicitly requires that “Fishing opportunities shall in any event be fixed in such a way as to ensure that there is less than a 5 % probability of the spawning stock biomass falling below Blim”. The herring stocks in question are already below this biological reference point Blim, below which reproduction is impaired and the risk of stock collapse is very high. Setting fishing limits at levels associated with a higher than 5% risk of the stocks remaining below this level, as seems to be the intention of Baltic Member States, will be in breach of the law.


In 2020, Friends of the Irish Environment and ClientEarth challenged the EU Council’s decision to set limits for several Northeast Atlantic fish stocks above sustainable levels before an Irish Court.


In a legal first, the Irish judge asked the Court of Justice of the EU (CJEU) to judge on the validity of this European regulation setting fishing limits in the Northeast Atlantic. Following a hearing held in March 2023 in front of the CJEU, Advocate General Ćapeta delivered an Opinion in June 2023 claiming that unsustainable fishing limits in the Northeast Atlantic were illegal and recommended that governments set all fishing limits at sustainable levels from now on. The environmental groups are now waiting for the final ruling from the CJEU.


ClientEarth is also expecting hearings this year for two other cases launched in 2022 against the EU Council for the setting of unsustainable fishing limits for EU-only stocks and stocks shared between the EU and the UK.


NOTES: 


(1) Article 4.6 of the multiannual plan for the stocks of cod, herring, and sprat in the Baltic Sea states that: “Fishing opportunities shall in any event be fixed in such a way as to ensure that there is less than a 5 % probability of the spawning stock biomass falling below the limit spawning stock biomass reference point (Blim) set out in particular in Annex II, column B.” https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02016R1139-20201201 



ENDS 


CONTACTS 

Petition launched to stop new oil and gas drilling in the Baltic Sea

By CCB • October 3, 2025
3 October 2025 - Coalition Clean Baltic, together with its Member Organization BUND - Friends of the Earth Germany and the citizens’ initiative “ Lebensraum Vorpommern ”, have launched a petition to stop new oil and gas drilling projects in the Baltic Sea . The petition comes in response to plans to exploit a deposit just 6 km offshore Świnoujście , Poland, in the transboundary waters of the Oder Estuary and Pomeranian Bay. The planned site lies at the heart of NATURA 2000 protected areas , which are vital for biodiversity, climate action, and local communities. Oil and gas extraction in the Baltic Sea poses severe threats to its fragile ecosystems. Industrial activities such as drilling, pipeline construction, and ship traffic risk polluting the water with chemicals, oil leaks, and toxic waste. Underwater noise from pile driving and increased traffic would further degrade marine habitats. These pressures add to the already critical challenges faced by the Baltic Sea, including biodiversity loss, eutrophication, and the accelerating impacts of climate change. The consequences extend far beyond nature. Local communities rely on a clean and healthy Baltic for tourism, fishing, and quality of life. Expanding fossil fuel infrastructure would also undermine Europe’s climate commitments and lock in carbon emissions for decades to come. The petition calls on the Ministry of Climate and Environment of Poland, the Helsinki Commission (HELCOM), the European Commission, and the Secretariat of the Espoo Convention to : Stop the plans for oil and gas extraction in the Oder Estuary and the Pomeranian Bay; Ban any new oil and gas extraction across the Baltic Sea; Ensure strong cross-border cooperation and communication amongst all involved states. The petition is open through the WeMove Europe´s platform and can be signed here .

(Closed) Job vacancy: Coalition Campaign Manager - Common Fisheries Policy

By CCB • October 1, 2025
Job Title: Coalition Campaign Manager - Common Fisheries Policy Position type : Full-time consultancy contract. Open to part-time arrangements initially if needed. Contract duration: Short-term contract until end of March 2026, with possibility of extension subject to funding availability Reports to: Steering Committee Location : Flexible(remote/home office) with regular travel. Working in Brussels is of advantage. Starting date : ASAP In close cooperation with the Steering Group of the coalition, lead, plan, coordinate, and support the campaign of an NGO network working together towards the implementation of the EU Common Fisheries Policy (CFP) and the evaluation thereof. The campaign manager's responsibility is to develop and ensure the successful and timely delivery of political advocacy and public engagement activities of the campaign, both at EU and Member State level. Job description Strategy & Planning Develop and implement short-, and long-term campaign strategies aligned with coalition objectives, in close cooperation with the Steering Group. Set clear goals, timelines, and performance indicators for the campaign and ensure timely delivery thereof. Analyse policy development, political climate, media and public opinion, and stakeholder landscapes to inform tactics. Campaign Delivery Manage day-to-day execution of the campaign activities at Brussels and Member State level. Coordinate coalition partners and ensure communication between Steering Group and coalition members, as well as relevant groups/coalitions/experts and other stakeholders outside the coalition. Advise coalition members on strategic delivery of advocacy activities at all levels, including Member State level. Join Steering Group meetings in an advisory capacity. Report back to the Steering Group on the delivery of the campaign's activities, meeting of targets and milestones, and report back on activities, budget and impact. Advocacy & Stakeholder Engagement Build and maintain relationships with policymakers, key stakeholders, and allies to support campaign aims. Analyse opportunities of engagement, advise on policy language. Organise/coordinate/prepare and support relevant activities, including events, briefings, and advocacy activities in close cooperation with coalition members. Ensure relevant knowledge management and information flow within the coalition and across partner organisations. Liaise with communication experts on message framing, strategy and timelines. Management Support CCB administrative and finance staff managing grants to coalition partners. Ensure coalition partners receive information and materials that enable them to effectively contribute to achieving campaign goals (political information, policy briefings, templates, policy language, opportunity analyses). Support fundraising efforts as needed/requested by the Steering Group. Lead on funders narrative reporting. Qualifications & Skills required The consultant must be legally authorised to provide services and work as a consultant within the EU, based in an EU Member State. Fisheries and ocean expertise (preferred), or other environmental background. Degree (or equivalent experience) in communications/campaign management, political science, resource management, fisheries, or related field. Proven track record in designing and delivering successful advocacy or public campaigns at EU or Member State levels involving a larger coalition. Strong understanding of political processes at EU level and Member State levels, media landscapes, and public engagement. Excellent project management and organisational skills. Skilled communicator and coordinator, able to craft persuasive messages and engage a larger network into a common goal within tight deadlines. Ability to work under pressure, meet deadlines, and adapt to rapidly changing circumstances. Fluency in English is required; additional EU languages are a plus. Application Should you be interested in applying for this assignment, please send your CV (max. 2 pages) together with a personal letter (max. 1 page) before 9 October 2025 , COB, to secretariat@ccb.se Please include your consultancy rate in your application inclusive VAT (if applicable). Applications should be submitted in English. Incomplete applications (e.g. lacking either CV or personal letter) will not be considered . Any inquiries related to this assignment should be forwarded to the above email or to CCB Executive Secretary Mikhail Durkin at mikhail.durkin@ccb.se and +46 739 770 793. In the application and hiring process, CCB will not discriminate against any individual based on race, colour, sex, language, religion, national or social origin, property, disability, age, family status, sexual orientation and gender identity, economic and social situation. .