NGOs New Year’s “resolution list” to ensure Ministers deliver a future-proof plan to save the Baltic Sea

December 2020 – Another year has come and gone, and we, the Coalition Clean Baltic and WWF Baltic Ecoregion Programme are taking stock of the Baltic Sea Action Plan (BSAP) presently being revised by all Baltic Sea coastal countries.

We have a special resolution for HELCOM Heads of Delegation after a year of the revision process: to deliver an actionable Baltic Sea Action Plan (BSAP) that is future-proof. The revised plan must go beyond “business as usual” to address the challenges of the coming decade, including seven priority areas for action that are not yet included in the revised BSAP.

The current plan ends in 2021 and has not met its aim to prevent further deterioration of the environment by the agreed timeline [1]. A new 10-year BSAP is being revised [2] for adoption at next year’s HELCOM Ministerial Meeting in October. Today, a first draft of the new BSAP is being presented at the 59th Meeting of the Heads of Delegation. In our opinion, there are priority areas that still need addressing to fulfil the pre-existing goals and additional pressures we foresee will continue to halt the sea from reaching good environmental status in the coming decade.

To help with this task NGOs across the Baltic Sea region have collectively produced a Shadow plan [3] setting recommended actions across all segments of the BSAP. There are seven of these priority action areas we want to underscore be included to ensure a future-proof action plan:

Actions reducing underwater noise: A recently published paper on the matter clearly states that we know enough to act [4]. It is crucial that underwater noise is measurably and continuously reduced as soon as possible, and several possible actions are readily available.
Actions to protect our endangered species: Eel –Recent scientific advice from the International Council for the Exploration of the Seas (ICES) shows no improvements in eel stocks [5]. The proposal to close recreational fishing is supported by the anglers themselves [6]. Measures such as banning recreational fishing must be included in the update. Harbour porpoise – ICES has published scientific advice on how to minimize bycatch of the Baltic harbour porpoise. This is discussed within Baltfish [7], but not all HELCOM Contracting Partners are EU Members, so it also needs to be discussed within HELCOM . We strongly urge support of this measure.
Actions reducing input of hazardous substances: Both source-reduction measures such as restrictions on over-the-counter pharmaceuticals [8] and end-of-pipe technologies like the promotion of constructed wetlands in wastewater treatment are not supported, despite proof of their effects to reduce inputs of hazardous substances.
Actions addressing nutrient inputs from agriculture: Economic instruments to discourage overuse of mineral fertilizers (Nitrogen and Phosphorus) and limit livestock densities in agriculture have not been endorsed [9], [10], [11]. Instead mostly voluntary measures were supported, which we can see from the current Common Agriculture Policy, does not incentivize the appropriate reduction of fertilizer in the Baltic sea region [12].
Actions addressing lost fishing gear: This is the deadliest form of marine litter. Prevention measures should be prioritized in order to reduce the scale of the problem. It is crucial that the updated BSAP recognizes the importance of fishing gear marking and gear loss reporting proper implementation on national and regional level [13].
Actions addressing climate change: A healthy and thriving Baltic Sea will not be possible without a plan to include climate mitigation and adaptation measures that build long-term resilience to climate change in our marine and coastal ecosystems. We strongly urge including binding climate targets and developing a roadmap to achieve climate neutrality in the Baltic Sea Area by 2040 [3].
Actions addressing Marine Protected Areas (MPAs): MPAs are endorsed by the BSAP to cover 30% of the sea by 2030, but it does not go far enough to regulate human activities in those areas. A 10% target for strictly prohibited areas will ensure we meet the 2030 EU Biodiversity strategy goals.

"The NGO community send this resolution list to all Baltic countries to take the lead in propelling the updated BSAP to be ambitious and action oriented. HELCOM has the platform, it’s now time for decisive action to empower change and save our beloved Baltic Sea”

says the Coalition Clean Baltic and the WWF Baltic Ecoregion Programme.

We look to the national HELCOM representatives meeting today in the Head of Delegation to assure the revised BSAP contains measures for all relevant pressures on the Baltic Sea – measures which have set timelines for prompt implementation and which will show a measurable reduction of the pressures.

–END—

Notes to editors:

CCB – Coalition Clean Baltic is a politically independent, non-profit association, which unites 23 member organizations and 1 observers, with over 850,000 members in all countries around the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the Baltic Sea environment and its natural resources. More info at www.ccb.se.

WWF Baltic Ecoregion Programme – is an ambitious and highly influential force working to conserve and restore the health of the Balitc Sea. The programme is comprised of WWF and NGO partners in each of the nine coastal Baltic Sea countries. Representing the region’s largest membership network, the programme’s approach has been to work with public and private sector partners toward ensuring a healthy, productive Baltic Sea through sustainable, ecosystem-based management. More info at: https://www.wwfbaltic.org/

[1] The HELCOM State of the Baltic Sea Report – shows that despite a few promising trends in the last 12 years, the objectives of the current BSAP have not been reached and countries have missed the 2020 deadline – outlined in the European Union’s Marine Strategy Framework Directive – to achieve and maintain a ‘Good Environmental Status’ in the sea.

[2] The update process – An updated plan is currently being developed and negotiated by the ten HELCOM members – the nine Baltic Sea countries plus the European Union – and is due to be adopted at a Ministerial Meeting 2021. Its focus will be on the same areas as the current plan with some adaptation to include additional pressures from human activities including: climate change, eutrophication, hazardous substances and litter, sea-based activities and achieve a healthy and resilient ecosystem. It will also address emerging issues to be tackled on a regional scale such as, marine litter, underwater noise and seabed disturbance.

[3] The Baltic Shadow Plan: For the future of the Baltic Sea

[4] CCB paper on underwater noise

[5] ICES 2020 – Advice on fishing opportunities, catch and effort. Ecoregions in the Northeast Atlantic: http://ices.dk/sites/pub/Publication Reports/Advice/2020/2020/ele.2737.nea.pdf

[6] EEA position on the rebuilding of the European Eel (Anguilla anguilla) stock: https://www.eaa-europe.org/positions/eel-2018.html

[7] Joint NGO letter to EU Commission on Baltic proper harbour porpoise

[8] HELCOM Baltic Marine Environment Protection Commission: proposal for the update of the BSAP – ‘Implement restrictions on over-the-counter pharmaceuticals’: https://portal.helcom.fi/workspaces/BSAP%20UP%20NEW%20ACTIONS-183/Shared%20Documents/Synopses%20-%20proposals%20received/Implement%20restrictions%20on%20over-the-counter%20pharmaceuticals.pdf

[9] HELCOM Baltic Marine Environment Protection Commission: proposal for the update of the BSAP – ‘Levy on nitrogen in mineral fertilizer’: https://portal.helcom.fi/workspaces/BSAP%20UP%20NEW%20ACTIONS-183/Shared%20Documents/Synopses%20-%20proposals%20received/Levy%20on%20nitrogen%20in%20mineral%20fertilizer.pdf

[10] HELCOM Baltic Marine Environment Protection Commission: proposal for the update of the BSAP – ‘Levy on mineral phosphorus in animal fodder and on mineral fertilizer P’: https://portal.helcom.fi/workspaces/BSAP%20UP%20NEW%20ACTIONS-183/Shared%20Documents/Synopses%20-%20proposals%20received/Levy%20on%20mineral%20phosphorus.pdf

[11] HELCOM Baltic Marine Environment Protection Commission: proposal for the update of the BSAP – ‘Reducing livestock densities and coupling livestock to the area of available farmland’: https://portal.helcom.fi/workspaces/BSAP%20UP%20NEW%20ACTIONS-183/Shared%20Documents/Synopses%20-%20proposals%20received/Reducing%20livestock%20densities%20and%20coupling%20livestock%20to%20the%20area%20of%20available%20farmland.pdf

[12] Potentials for circularity in the agrifood system: https://wwwwwfbalticorg.cdn.triggerfish.cloud/uploads/2020/09/metabolic_report_wwfse_potential-for-circularity-in-the-agrifood-system_17032020_hr.pdf

[13] HELCOM Baltic Marine Environment Protection Commission: proposal for the update of the BSAP – ‘Development of strategies for preventing fishing gear loss in the Baltic Sea by analyzing the fishing strategic context and available options for fishing gear marking’: https://portal.helcom.fi/workspaces/BSAP%20UP%20NEW%20ACTIONS-183/Shared%20Documents/Synopses%20-%20proposals%20received/Strategies%20for%20preventing%20fishing%20gear%20loss.pdf

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Tampering with EU Fisheries Policy would ‘open Pandora’s Box’, NGOs warn

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

CCB´s submission to the EU Call for Evidence on the EU Marine Strategy Framework Directive (MSFD)

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)