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.


_END


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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.




 

CCB's submission on sustainable fishing in the EU

By CCB • August 31, 2026
Uppsala, 31 August 2026 - Coalition Clean Baltic (CCB) welcomes the Commission’s recognition that declining fishing pressure has not consistently delivered higher biomass, that recruitment and biomass are deteriorating for a number of stocks, and that Baltic fisheries urgently need rebuilding trajectories. These findings must now shape the Council’s decision on the 2027 fishing opportunities and the Commission’s position during the Council negotiations. The poor status and decline of many Baltic Sea fish populations have been documented over several decades and show that the ecosystem is in severe distress. Cumulative human pressures have contributed to major ecosystem shifts, and at the same time climate change is making the shallow, semi-enclosed Baltic Sea warmer and less saline. These combined pressures affect not only fish biomass but also recruitment, population age and size structures, species interactions and the functioning of the wider food web. The Baltic crisis reflects the persistent failure to fully implement the CFP and the Baltic MAP, including their precautionary safeguards and the legal obligation to apply ecosystem-based fisheries management. Fishing opportunities for 2027 must therefore mark the first concrete step towards ambitious, timebound rebuilding trajectories that reduce fishing pressure and enable depleted populations to recover to healthy levels. These trajectories must include implementation of an ecosystem based approach by accounting for species interactions, food-web needs, habitat conditions, environmental and climatic change and scientific uncertainty, while reinforcing, not replacing the CFP’s objectives and the Baltic MAP’s existing safeguards in Art. 4.6. The Commission’s 2027 proposal is now before the Council. The October Council must turn the commitment to rebuild Baltic fish populations into measurable action by adopting fishing opportunities that deliver rapid and sustained recovery. Under no circumstances should the TACs adopted be higher than levels proposed by the European Commission. Fishing opportunities aligned with scientific evidence, legal safeguards and ecosystem needs are the basis for both a recovering Baltic Sea and viable fisheries in the long term. Read the full CCB's submission and recommendations here .

NGOs urge EU fisheries ministers to turn fragile progress into lasting recovery

By CCB • August 25, 2026
25 August 2026 - Following yesterday’s European Commission proposal for 2027 Baltic Sea fishing opportunities , environmental and angling organisations call on EU fisheries ministers not to treat the early signs of recovery for some Baltic Sea fish populations as a licence for steep quota increases. The latest scientific assessment on central Baltic herring shows some encouraging signs of improvement. This is welcome, but the changes are recent and do not mean that the population has fully recovered. An increase in biomass alone does not demonstrate that fish populations are healthy and resilient or justify higher catch limits. Fishing limits for small pelagic fish in the Baltic Sea have been set too high for years; last year’s Agriculture and Fisheries Council’s (AGRIFISH) decisions provide a recent example [1]. Herring proposals support recovery, but sprat’s wider ecosystem role must not be overlooked NGOs support the Commission’s proposed 2027 catch limit of 143,860 tonnes for central Baltic herring. Although 49% higher than last year, the proposal reflects the population’s recent growth, whilst also increasing the chances of the still fragile population to continue rebuilding. NGOs also cautiously welcome the proposed catch limit of 57,308 tonnes for Bothnian herring, a 3% increase, and the retention of the three- month spawning closure. Nevertheless, the population remains vulnerable and continues to be below healthy levels according to scientific advice [2]. An even more cautious fishing level would be needed in order to restore the population to the required healthy level. NGOs therefore strongly recommend a lower Total Allowable Catch (TAC) of 45,544 tonnes. For sprat, the proposed catch limit of 291,590 tonnes and proposed removal of the spawning closure do not sufficiently account for the observed and documented misreporting issues, or for species’ vital role in the wider Baltic Sea ecosystem. “The Commission has taken a careful approach to herring, and the same is needed for sprat. Sprat may be small, but they play a vital role in the Baltic Sea as key prey for cod, salmon and seabirds. Fisheries ministers should set a lower catch limit that leaves enough sprat in the sea to help the fragile Baltic Sea ecosystem recover,” says Cathrine Pedersen Schirmer, Senior Fisheries Policy Advisor, Coalition Clean Baltic. Cod remains in crisis Scientists continue to advise zero catch for both eastern and western Baltic cod in 2027, a reminder of how depleted these populations remain. NGOs welcome the Commission's proposal to reduce cod bycatch quotas by 51% (to 211 tonnes) for eastern Baltic cod and by 88% (to 31 tonnes) for western Baltic cod, and to maintain the current conservation measures. However, to increase the chances for recovery for Baltic cod populations, EU decision makers must walk the talk. New legal obligations require the use of fishing gear in flatfish fisheries designed to avoid accidental catches of cod. With this gear now mandatory, cod bycatch quotas should be reduced and set as close as possible to the advised zero catch. For plaice, the Commission proposes to keep the same fishing opportunity as in 2026. However, cod is also caught as bycatch in the plaice fishery. NGOs therefore urge ministers to keep the plaice quota at a lower level, no higher than 1,593 tonnes for 2027, to help reduce accidental cod catches. "Fishing opportunities for 2027 should reflect the objectives of the Nature Restoration Regulation. As Member States prepare their national restoration plans, fishing limits must help rebuild fish populations and support the recovery of resilient marine ecosystems. Overfishing and neglecting an ecosystem-based approach would undermine restoration efforts," says Justyna Zajchowska, Fisheries Lead for WWF Baltic Sea Programme. E ncouraging salmon returns do not show recovery across all rivers Salmon returns to several large rivers in Sweden and Finland have been encouraging in 2026 [3]. However, several smaller northern Swedish populations remain at critically low levels, and the effects of the three previous poor years are expected to persist. The regional picture therefore remains uneven. NGOs welcome the Commission’s proposal not to increase fishing opportunities for Baltic salmon. However, for both the Main Basin salmon and the Gulf of Finland salmon, fishing should only take place on compensatory released salmon or salmon from rivers where stocks are at full reproductive capacity. “Good returns to the Torne and several other large rivers are welcome, but Baltic salmon cannot be judged by a few rivers alone. Many smaller populations remain at critical levels, and there is no room to increase fishing pressure on wild salmon,” says Thomas Johansson, Chairman, Östersjölaxälvar i Samverkan, and Secretary General, Baltic Salmon Fund. Fisheries ministers must turn promises into action for a real recovery of the Baltic Sea When agreeing the Baltic Sea fishing opportunities for 2027 in October, EU fisheries ministers must apply a precautionary and ecosystem-based approach and: Follow the Commission’s proposal on fishing opportunities for: Central Baltic herring, Western Baltic herring, Eastern Baltic cod, Western Baltic cod; Set lower, more precautionary and ecosystem-based fishing opportunities for: sprat, Bothnian herring, Gulf of Riga herring, plaice, Main Basin salmon, Gulf of Finland salmon; Under no circumstances set fishing opportunities for Bothnian herring higher than the Commission’s proposal. A higher level of fishing would lead to a decrease in stock size; Honour the October AGRIFISH 2025 commitment by agreeing to a clear timetable for ambitious, time-bound rebuilding plans for every depleted Baltic Sea fish population, based on rebuilding trajectories that restore populations to healthy levels as quickly as possible; and Ensure that Baltic Sea fishing opportunities are aligned with EU nature restoration objectives, so that public and private work and investments in marine restoration are not undermined by continued overfishing, insufficient rebuilding measures and lack of implementation of ecosystem-based fisheries management. In October 2025, the Commission and the eight Baltic EU Member States agreed [4] on the urgent need to rebuild Baltic Sea fish populations. The 2027 fishing-opportunities decision is the first real test of that commitment. Some improvements in Central Baltic herring and sprat show that recovery is possible ministers must now adopt fishing limits that secure that progress in the long term and give every depleted Baltic Sea fish population a credible chance to recover. - ENDS The full press release is available in PDF here . Extra info For the full joint NGO recommendations on Baltic Sea fishing opportunities for 2027, please see: https://www.ccb.se/joint-ngo-recommendations-on-baltic-sea-fishing-opportunities-for-2027 Central Baltic herring remains below the level at which rebuilding measures should begin. The International Council for the Exploration of the Sea (ICES) expects the population to move only slightly above that level in 2027. Even then, fishing at the rate associated with maximum sustainable yield would leave a 36% probability of it falling below the threshold again in 2028 [5]. ICES also warns that the stock contains genetically distinct spawning groups and is therefore vulnerable to losses in genetic diversity and overall productivity [6]. The sprat population has grown and is now above key biomass reference points. However, fishing pressure is already at the level associated with maximum sustainable yield. ICES cautions that persistent misreporting of herring and sprat adds uncertainty to its assessment and advice [7]. Sprat is an important food source for cod, salmon and other marine wildlife [8], while ICES reports that industrial sprat fisheries can include substantial catches of herring [9]. Higher fishing pressure on sprat could therefore affect vulnerable herring populations as well as species that depend on sprat for food. Media contacts 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 Joonas Plaan , Board member, Marine and Climate programme, Estonian Fund for Nature, joonas.plaan@elfond.ee 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 *** Notes [1] See joint NGO press release on the outcome: https://www.ccb.se/fisheries-ministers-risk-breaking-eu-law-jeopardising-baltic-sea-recovery [2] ICES (2026). Herring (Clupea harengus) in Subdivisions 30 and 31 (Gulf of Bothnia). ICES Advice: Recurrent Advice. Report. https://doi.org/10.17895/ices.advice.30932087.v1 [3] Finnish monitoring of salmon returns: https://luonnonvaratieto.luke.fi/numerotieto/raportit?panel=nousulohiseuranta&inits=REGION_ID%3D3&lang=en&state=REGION%3D3%3BREPORT%3Dfi%3Asalmon_run_monitoring%2F89%3BYEAR%3D2026 [4] Council of the European Union (2025), Draft minutes of the Agriculture and Fisheries Council , 27–28 October 2025, document 14646/25, p. 13, joint statement on the urgent need for rebuilding fisheries in the Baltic Sea. [5] ICES, Herring in subdivisions 25–29 and 32, excluding the Gulf of Riga, pp. 1–2. The stock is currently below MSY Btrigger; projected biomass for 2027 is only 5% above it. Under the FMSY scenario, ICES estimates a 36% probability of biomass being below MSY Btrigger in 2028. https://ices-library.figshare.com/articles/report/Herring_i_Clupea_harengus_i_in_subdivisions_25-29_and_32_excluding_the_Gulf_of_Riga_central_Baltic_Sea_/30932081?file=65083161 [6] Ibid., p. 4. ICES identifies genetically distinct spawning components and warns of vulnerability to losses in genetic diversity and overall productivity. [7] ICES, Sprat in subdivisions 22–32: ICES advice . [8] Birgersson, L. and Pedersen Schirmer, C. (2025). Small fish with a big impact – a review of forage fish importance for a healthy Baltic Sea. FishSec (Fiskesekretariatet), Stockholm, Sweden. [9] ICES. 2026. Baltic Fisheries Assessment Working Group (WGBFAS). ICES Scientific Reports 8:39, section 7.2.5, p. 531. ICES reports that industrial sprat fisheries in several Baltic countries may include large bycatches of other species, predominantly herring. https://doi.org/10.17895/ices.pub.32455056