Fisheries Ministers Risk Breaking EU Law, Jeopardising Baltic Sea Recovery

CCB • October 28, 2025

EU Council decision on 2026 fishing limits fails to implement legally required safeguards, jeopardising the fragile marine ecosystem

Luxembourg, 28th of October 2025 - Environmental organisations across Europe (Baltic Salmon Fund, Bund für Umwelt und Naturschutz Deutschland, Coalition Clean Baltic, Danmarks Naturfredningsforening, Deutsche Umwelthilfe, FishSec, Oceana, Östersjölaxälvar i samverkan, Pasaules dabas fonds, Seas At Risk, WWF Baltic Sea Programme) express grave concern following today’s EU Fisheries and Agriculture Council of Ministers' (AGRIFISH) decision on Baltic Sea fishing opportunities for 2026, warning that the agreement fails to provide the precautionary approach necessary  to rebuild the Baltic Sea’s critically depleted fish populations and fragile marine ecosystem.


Despite clear scientific warnings[1] about the dire state of the Baltic Sea ecosystem, well-established legal frameworks to remedy the situation, as well as a good, precautionary and recovery-oriented proposal on fishing opportunities for 2026 from the European Commission, the Council set fishing limits that breach legal requirements[2] under both the Common Fisheries Policy (CFP) and the Baltic Sea Multiannual Plan (MAP), prioritising short-term economic interests over long-term ecosystem recovery.


"The evidence is clear: the Baltic Sea ecosystem is in severe distress, and current management approaches are not working," said Aimi Hamberg, Marine Policy Officer at Coalition Clean Baltic. "We need fishing limits set well below single-stock scientific advice to account for ecosystem interactions, data uncertainties, and the critical role these fish species play in the Baltic food web. Instead, the Council has yet again continued to push biological limits to their breaking point."


Breaking the law on herring stocks


Of particular concern are the decisions on pelagic forage fish populations—herring and sprat—which form the backbone of the Baltic Sea food web. The Council's Total Allowable Catch (TAC) for central Baltic herring and Gulf of Bothnia herring exceeds the levels required to comply with Article 4.6 of the Baltic Sea MAP, which mandates that fishing opportunities must be set to ensure a less than 5% chance of stocks falling below critical biomass levels (Blim).


The Council agreed to increase the central Baltic herring  quota by 15% compared to 2025 levels, despite the stock being in poor condition and barely above critical levels[3]. This decision violates the Baltic Sea MAP by creating an unacceptably high risk and exceeding the legal 5% probability limit of falling to critically low levels that could impair the population’s reproduction.[4]


For Gulf of Bothnia herring, while the Council reduced the quota by 41%, this reduction also falls far short of what is needed to comply with the law. The agreed TAC creates a much higher probability of the spawning stock falling below Blim, thereby directly violating legally binding safeguards designed to prevent irreversible damage to fish populations.


Sprat: Reckless 45% increase despite uncertain recruitment forecast


The Council's decision to increase the sprat  quota by 45% compared to 2025 is particularly alarming given the scientific uncertainties and the stock's decreasing trend. From 2021 to 2023, Baltic Sea sprat suffered some of the lowest recruitment rates ever recorded for the stock. While the International Council for the Exploration of the Sea (ICES) advised catches based on a seemingly strong 2024 year class, this estimate relies on a single autumn survey in northeastern areas, making its contribution to overall sprat biomass highly uncertain.


The sprat decision is further complicated by ongoing issues with misreporting between sprat and herring, as well as mixing with degraded herring stocks in fisheries—factors that demand extra precaution rather than quota increases.


Cod: recovery remains elusive with a too high bycatch quota


ICES continues to advise zero catch for both eastern and western Baltic cod stocks, which remain below critical biomass limits despite years of severe catch restrictions. Despite the Commission’s proposal to reduce the bycatch quota on both stocks, the Council failed to acknowledge the severity of the situation or prioritise the recovery of these depleted top predators by maintaining the unacceptable high bycatch quota.


Maintaining a high by-catch quota for threatened species is not only against the scientific advice of zero catch, but it also does not incentivise the fishing industry to fish more selectively. 


Further restrictions on salmon fisheries are necessary


Baltic salmon populations
  have suffered from poor survival during their feeding migration in the sea. This has led to a drastic decrease in the number of returning spawners in the rivers. It is impossible to predict the survival of salmon during their sea phase in advance, so the current status and development of salmon stocks are on very uncertain grounds.


The Council decided to decrease the main basin salmon TAC in line with the ICES advice by 27% and maintain the ban on commercial salmon fishing in the main basin of the Baltic Sea. In the Gulf of Finland, it was decided to increase the level by 1% compared to 2025 due to the stable or improving status of the Gulf of Finland wild salmon populations.


Joint commitment offers hope, but action is needed now


While the Council's decisions on Baltic Sea fishing opportunities are deeply disappointing, there is a glimmer of hope in the joint commitment issued by the European Commission and Baltic Sea Member States agreeing on the need to request ICES to provide specific scientific advice on fish stocks rebuilding trajectories. Although this commitment is not legally binding and falls short of the immediate action needed, environmental organisations hope it signals a turning point in efforts to rebuild the fragile fish populations of the Baltic Sea.


The full joint PR is available here.


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EXTRA NOTES TO EDITORS


 The Baltic Sea Multiannual Plan (Regulation EU 2016/1139) establishes legally binding rules for managing cod, herring, and sprat stocks in the Baltic Sea.

 Article 4.6 of the Baltic Sea MAP requires that fishing opportunities be set to ensure less than 5% probability of stocks falling below Blim.

 ICES has advised zero catch for western Baltic herring since 2019, for eastern Baltic cod since 2020, and for western Baltic cod since 2025.

 The Common Fisheries Policy (Regulation EU 1380/2013) requires that all fishing opportunities be set according to the precautionary approach (Article 2.2) and ecosystem-based approach to fisheries management (Article 2.3)

 Full NGO recommendations on Baltic Sea fishing opportunities for 2026 are available here


FOR MORE INFORMATION AND INTERVIEWS, PLEASE CONTACT:


● Aimi Hamberg, Marine Policy Officer, Coalition Clean Baltic (CCB), aimi.hamberg@ccb.se

● Arielle Sutherland-Sherriff, Policy Advisor, Oceana, asutherland@oceana.org

● Cathrine Pedersen Schirmer, Senior Fisheries Advisor, FishSec, Cathrine@fishsec.org

● Joonas Plaan, Member of the Management Board, sustainable fisheries expert, Estonian Fund for Nature, joonas.plaan@elfond.ee

● Justyna Zajchowska, Fisheries Lead, WWF Baltic Sea Programme, jzajchowska@wwf.pl

● Claudia Romero-Oliva, Policy Officer Marine Conservation, Deutsche Umwelthilfe e.V., romero@duh.de 

● Magda Jentgena, Baltic Sea and Freshwater Programme Manager, Pasaules dabas fonds, mjentgena@pdf.lv

● Morten Rosenvold Villadsen, Havpolitisk rådgiver, Danmarks Naturfredningsforening, Morten@dn.dk

● Rémi Cossetti, Marine Policy Officer, Seas At Risk, rcossetti@seas-at-risk.org

● Thomas Johansson, Chairman, Östersjölaxälvar i samverkan and Secretary General of the Baltic Salmon Fund, thomas@balticsalmonfund.com

● Valeska Diemel, Fisheries Policy Officer, Bund für Umwelt und Naturschutz Deutschland (BUND), valeska.diemel@bund.net


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NOTES

[1] See for instance the HELCOM HOLAS assessment (HELCOM (2023): State of the Baltic Sea. Third HELCOM holistic assessment 2016-2021. Baltic Sea Environment Proceedings n°194 or ICES (2024). Baltic Sea Ecoregion – Ecosystem Overview. ICES Advice: Ecosystem Overviews. Report. https://doi.org/10.17895/ices.advice.27256635.v1

[2] Preamble 10 and Art. 2.2 of the CFP requires that sustainable exploitation of marine biological resources should be based on the precautionary approach. In addition, Art 4.6 of the Baltic Multiannual Plan mandates that fishing opportunities be set to ensure less than 5% probability of stocks falling below Blim.

[3] ICES assessment of central Baltic herring shows that this stock has a relative spawning-stock size below MSY Btrigger and below the precautionary limit Bpa, and only slightly higher than the critical limit reference point Blim, below which reproduction is likely to be impaired.

[4] An estimated catch of 103 073 t corresponds to 5% for p(SSB(2027)<Blim)=5% (ICES advice for central Baltic herring, Table 2). However, in order to account for Riga herring to be taken in SD 28.2 and central Baltic herring to be taken in the Gulf of Riga (SD 28.1), as well as for the Russian share, the catch should be below 89 827t.




 


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 .
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. .