Joint NGO recommendations on Baltic Sea fishing opportunities for 2025

CCB • June 19, 2024

On Friday, 31 May, the International Council for the Exploration of the Seas (ICES) published its scientific advice on how much fish can be caught in the Baltic Sea next year. In response, environmental NGOs from around the Baltic Sea region urge the European Commission to propose, and fisheries ministers to adopt fishing opportunities at levels well below the ICES headline advice to safeguard ecosystem needs and dynamics and allow for the recovery of fish populations.

The decline of fish populations in the Baltic Sea ecosystem has by now been extensively documented and analysed. The decline has been ongoing for decades but has escalated in recent years with some fish populations collapsing and the effects of the climate crisis manifesting itself. So far any policy interventions have not been ambitious enough to reverse or even just halt the negative trends. The third HELCOM Holistic Assessment of the State of the Baltic Sea (HOLAS 3) that came out last December, concludes that the ecosystem is in extreme distress and that species extraction is one of the main threats to Baltic Sea biodiversity. This year the ICES assessment shows yet again that populations of commercially harvested stocks are not in a healthy state: Both cod populations remain in a state of collapse, there is high uncertainty on the status of the herring populations, salmon is in decline and sprat has had very low recruitment for the fourth year in a row. Of the fish populations with catch advice, only the plaice spawning stock biomass is high, however alarming signals indicate a high number of small and skinny fish, leading to high levels of discards.


Overall, we urge the European Commission to propose, and fisheries ministers to adopt fishing opportunities at levels well below the ICES headline advice (and below the FMSY point value where available) to safeguard ecosystem needs and dynamics and allow for the recovery of fish populations.


Concretely this means the following:


For TAC-setting for 2025


1. Set catch limits well below the best available scientific advice provided by ICES, in order to
effectively and rapidly rebuild all fish populations and ensure long-term population and
ecosystem health and productivity, namely:
a) at a fishing mortality level below the FMSY point value for stocks for which MSY reference
points are available.
b) at a fishing mortality level below ICES headline advice for stocks with advice based on
the ICES precautionary approach for data-limited stocks.


2. In the absence of concrete catch scenarios in the ICES advice that are explicitly geared
towards fully incorporating ecosystem needs and delivering a rapid stock recovery. We
recommend to incorporate an additional level of precaution into TAC-setting, by setting
all TACs well below the respective ICES headline advice. This is important to accommodate
for stock-specific uncertainties, low recruitment trends, inter-species dynamics and mixed
fisheries interactions as well as other pressures on the Baltic Sea ecosystem (pollution,
eutrophication, climate change etc.). This could be done by deducting a precautionary
safeguard amount or percentage from the headline advice catch level, the size of which
would depend on population status.


3. Fully utilise the precautionary approach by closing areas with high mixing where we do
not have a robust understanding of the impact on individual (sub-)populations and/or by
substantially reducing quotas to safeguard depleted and vulnerable populations or sub populations and the risk of genetic depletion;


4. Consider the widely recognised lack of implementation of the Landing Obligation (LO)4 by
setting TACs sufficiently below ICES catch advice to ensure illegal, unreported discarding
does not lead to actual catches exceeding ICES catch advice;


5. Provide transparent calculations for TACs based on the ICES advice on fishing opportunities.


With regards to fisheries management beyond TAC-setting


6. Underpin sustainable TAC-setting by robust controls and full catch documentation using
remote electronic monitoring (REM; supported by observer coverage as appropriate) for all
vessels above 12 m and for medium and high-risk vessels below 12 m.


7. Develop and implement effective rebuilding plans (reflecting the findings of ICES
WKREBUILD7) for all populations below MSY B
trigger, geared towards rapid rebuilding above
B
MSY, including strong safeguards to prevent future population declines or stagnation below
MSY B
trigger, and subject to close monitoring and enforcement using REM with cameras.


8. Prioritise and apply environmental and social criteria for national allocation of fishing
opportunities, for example through incentivising use of selective fishing gear and low
impact fishing practices. The European Commission should provide a precise definition
of low-impact fishing, monitor compliance with Article 17 of the CFP Basic Regulation, and
require the Member States to make their allocation criteria public.


9. Agree on ecosystem-based fisheries management objectives to inform the ICES advice
request process8. International commitments on biodiversity conservation, such as Global
Biodiversity Framework Directive, Baltic Sea Action Plan (BSAP) of HELCOM Commission as
well as the Marine Strategy Framework Directive (MSFD) should provide a basis for these
ecological objectives and be considered alongside the rules and objectives of the CFP.


10. Change the requests for ICES advice on fishing opportunities to
a) aim for rapid recovery of depleted or at-risk stocks,
b) fully reflect ecosystem dynamics and needs, also reflecting Good Environmental Status
(GES) requirements under the Marine Strategy Framework Directive (MSFD), and
multispecies considerations, and
c) provide sufficiently precautionary alternative catch options where a full incorporation of
these aspects is not yet possible, to minimise risks to stocks and the overall ecosystem.


11. Improve transparency by making publicly available any proposals subsequent to the official
Commission proposal, including Commission non-papers as well as Council Working Party,
AGRIFISH Council, and BALTFISH documents and minutes.


Read the full recommendations here.

By CCB March 30, 2026
Brussels, 30 March 2026 - Today, Fisheries Ministers from EU Member States meet with the European Commission for the AGRIFISH Council. On this occasion, Oceana, BLOOM, ClientEarth, Coalition Clean Baltic (CCB), Environmental Justice Foundation (EJF), Seas At Risk and WWF EU, handed a symbolic ''Pandora’s Box'' to the EU Commissioner Costas Kadis, sending a clear message as the European Commission prepares its 2026 evaluation of the Common Fisheries Policy (CFP). The box represents the risks of revising EU’s main fishery policy framework: once opened, competing demands from Member States, industry, small-scale fishers, and coastal communities could quickly spiral into division, regulatory delays and uncertainties. This would put at risk the hard-won progress made in restoring Europe’s fish populations and improving the profitability of the fishing sector. NGOs urge decision makers to build on the progress made to date and to prioritise the full and timely implementation of the existing rules. Reopening the CFP and its related provisions would undermine ocean health and the long-term future of Europe’s fishing communities. '' Europe's fisheries policy is facing a credibility test. The law is already there. The tools to rebuild our seas already exist. What's missing is the political will to deliver. Overfishing should have ended by 2020 at the latest. Reopening the CFP would signal that missed deadlines carry no consequences, erode trust, revert the progress made, and put the future of our fisheries and coastal communities at stake ’’, said the NGO coalition. *** Oceana: Vera Coelho, Executive Director and Vice President in Europe BLOOM: Claire Nouvian, Founder and General Director ClientEarth: John Condon, Lead of Marine Ecosystems Coalition Clean Baltic (CCB): Ida Carlén, Co-Chair Environmental Justice Foundation: Steve Trent, CEO/Founder Seas At Risk: Dr Monica Verbeek, Executive Director WWF EU: Ester Asin, Director
By 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: *** [Short version]*** 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 . *** Links to supplemental documents supporting our positions: CCB’s submission to the Call for Evidence for the Ocean Act Guiding Recommendations for Source-to-Sea Restoration in Riverine, Coastal, and Marine Ecosystems (Coalition Clean Baltic, 2025) Position Paper on Marine Protected Areas (Coalition Clean Baltic 2024) Don’t sink the Common Fisheries Policy – fulfil its potential (joint NGO Briefing 2025) Blue Manifesto (joint NGO paper)