NGOs to EU decision makers: Commit to a Genuine Baltic Sea Recovery Plan

CCB • May 28, 2025

Key Baltic fish populations are in crisis, warn environmental NGOs. New scientific advice from the International Council for the Exploration of the Sea, ICES, confirms the poor condition of key Baltic fish populations, several of which remain collapsed (1). EU fisheries ministers must set 2026-catch limits well below ICES advice and prioritise long-term recovery over short-term economic gains.

Cod collapse requires continued zero catch


The alarming state of Baltic cod populations  persists. ICES maintains its zero-catch advice for Eastern Baltic cod in 2026 and 2027. Despite closure of the direct fishery since 2020, the stock shows no signs of recovery. 


For the first time, ICES also recommends zero catch for Western Baltic cod. The stock has suffered from weak recruitment since 2016. Despite the targeted direct fishery being closed since 2022, scientists now advise a full fishing halt for 2026 and 2027 (2). 


ICES also recommends actions to restore degraded marine ecosystems affected by pollution and the climate crisis. These measures, if implemented, are expected to have both direct and indirect effects on reducing mortality and improving the poor condition of both cod populations.


Higher catch advice, despite low herring biomass and sprat data uncertainty


Compared to last year, the ICES advice for Central Baltic herring  and sprat has increased, Central Baltic herring biomass is marginally above critical levels and risks genetic diversity loss, while the sprat advice increase relies on potentially unrepresentative recruitment data from a single Northeastern survey (3). NGOs warn that these apparent improvements mask significant concerns. 


On paper these catch limit increases look encouraging, but a closer reading of the ICES advice shows we’re still walking a tightrope,” said Cathrine Pedersen Schirmer, Senior Fisheries Policy Advisor at FishSec. “These fish populations remain fragile, and the uncertainties in the underlying data should make decision-makers proceed with caution.


Uncertainty also clouds Gulf of Bothnia herring (4). Gulf of Riga herring, the only Baltic herring population consistently fished in line with the Baltic Sea Multiannual Plan, yet shows a declining spawning stock biomass (5). The advice for Western Baltic herring remains zero catch for 2026.


Herring and sprat are vital to the Baltic Sea’s ecosystem and economy, serving as both valuable catches and essential prey for larger fish, marine mammals and birds” said Cathrine Pedersen Schirmer. “Overfishing, pollution, habitat loss, and a warming, oxygen-starved sea now threaten these species. Setting cautious catch limits—alongside habitat restoration—is crucial to protect the Baltic’s entire ecosystem.


ICES headline advice does not consider legal safeguards for two herring stocks


In addition, ICES headline advice does not take into account legal safeguards under the EU Baltic Multiannual Management Plan designed to prevent the collapse of fish stocks (6) When it comes to Total Allowable Catches (TACs) for 2026 this important provision applies to Central Baltic and Gulf of Bothnia herring  (7). Most concerningly warn NGOs, as the Fisheries Council has broken this legal rule twice already in relation to Baltic stocks. 


We cannot once again ignore the fact that the advised catches would push both these herring stocks beyond the determined biological and legal risk limit. These are not just numbers”, said Aimi Hamberg, Marine Policy Officer at Coalition Clean Baltic, “they reflect real threats to the reproductive capacity of the stocks. Ignoring the legal safeguards in the Baltic Sea Multi Annual Plan once again could lead to long-term stock collapse and socioeconomic fallout.


ICES advice on fishing opportunities should always be used in conjunction with the existing binding law. We understand and expect that ICES advice for the Baltic Sea fish stocks will be used by the decision makers respecting the provisions of the Baltic Sea Multiannual Plan and considering its important safeguards. In practice this would mean much lower catch levels for Central Baltic herring and Gulf of Bothnia herring, compared to the headline advice.” said Justyna Zajchowska, Fisheries Lead in WWF Baltic Sea Programme.


Scientists flag poor flatfish condition and call for habitat restoration


ICES flag the poor flatfish conditions and call for habitat restoration. Over the last five years, Baltic plaice  — and other flatfish — have shown sharp declines in weight-at-age and overall condition, a clear sign of ecosystem stress (8).


Fisheries management must account for the reality that our marine ecosystem has been damaged by human activities and climate change,” said Lioba Schwarzer, Lead of Marine Conservation at DUH. “ICES scientists are now recommending habitat restoration efforts, specifically improving oxygen levels on the seafloor, which will ultimately help improve the health of the plaice stock.“


Ecosystem failure and data gaps demand more precautionary limits



ICES’ latest advice exposes significant uncertainties and data gaps, such as misreported landings (especially for herring and sprat), missing Russian catch figures, and incomplete biological data, that undermine Baltic Sea stock assessments. 


In light of the current biodiversity and climate crises, it is imperative to rebuild all fish populations well above sustainable and productive levels in order to enable them to cope with and mitigate mounting pressures”, said Rémi Cossetti, Marine Policy Officer at Seas At Risk, “policymakers must invest in the resilience of fish populations and ecosystems by adopting fishing limits well below the maximum catch level advised by ICES to ensure the long term sustainability and resilience of the fisheries sector and the coastal communities that depend on them.”


NGOs therefore urge EU decision-makers to urgently agree on a Baltic Sea Recovery Plan, that includes adopting precautionary limits that restore and maintain resilient fish populations amid the ecosystem and climate crisis.


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CONTACTS:

  • Aimi Hamberg, Marine Policy Officer, Coalition Clean Baltic, aimi.hamberg@ccb.se 
  • Cathrine Pedersen Schirmer, Senior Fisheries Policy Officer, FishSec, Cathrine@fishsec.org +45 21977905
  • Lioba Schwarzer, Team Lead Marine Conservation, Deutsche Umwelthilfe, schwarzer@duh.de, +49 171 9851538
  • Justyna Zajchowska, Fisheries Lead, WWF Baltic Sea Programme, jzajchowska@wwf.pl
  • Rémi Cossetti, Marine Policy Officer, Seas At Risk, rcossett@seas-at-risk.org
  • Magda Jentgena, Baltic Sea and Freshwater Programme Manager, Pasaules Dabas Fonds, mjentgena@pdf.lv, +371 28652770
  • Joonas Plaan,Board member, Marine and Climate program, Estonian Fund for Nature (ELF), joonas.plaan@elfond.ee, +372 5665 2979



NOTES


  1. Linkto ICES advice. 
  2. Western Baltic cod: Last year, ICES had advised no more than 24 tonnes catch for both recreational and commercial fishing. However, Ministers set a bycatch quota of 266 tonnes for 2025 to avoid limiting the flatfish fishery, which catches significant amounts of cod when using bottom trawls. As a result, commercial landings reached 155 tonnes in 2024, of which 123 tonnes are estimated to have been discarded—a practice that is illegal under the Common Fisheries Policy. ICES highlights that reducing cod bycatch in flatfish fisheries could enhance stock recovery.
  3. ICES advice for Central Baltic herring: a maximum of 154,542 tonnes for 2026 (taking account of the mixing between the Central Baltic herring and Gulf of Riga herring) vs 125,000 tonnes for 2025, sprat: a maximum of 230,518 tonnes vs 165,000 tonnes for 2025. Central Baltic herring biomass remains just above the critical conservation reference point, and with vulnerable sub-populations not being managed separately there is a risk that genetic diversity may be lost forever. ICES’s higher sprat advice is based on promising recruitment data from just one northeastern survey that may not reliably predict biomass increases across the entire Baltic stock area. 
  4. Gulf of Bothnia herring: ICES advises a decrease to a maximum of 62,684 tonnes for 2026 (down from 74,515 tonnes), noting fluctuating weight-at-age linked to changing prey availability. 
  5. Gulf of Riga herring: ICES limits 2026 catches to a maximum of 34,367 tonnes (down from 45,235 tonnes). Western Baltic spring-spawning herring (WBSS): ICES advises zero catch for 2026 and has done so since 2019. ICES highlights that without additional area and seasonal restrictions on the herring fishery in the North Sea in 2026, catches of WBSS herring in the North Sea will be unavoidable, delaying the recovery of the stock. 
  6. Art. 4.6 of the Baltic Sea Multiannual Plan requires fishing opportunities to be set in such a way that there is less than a 5% probability of the stock’s spawning biomass (SSB) falling below critical biomass levels (Blim).
  7. ICES headline advice for Central Baltic herring and Gulf of Bothnia herring does not take into account the safeguard under Art. 4.6 of the Baltic Sea Multiannual Plan, which requires fishing opportunities to be set in such a way that there is less than a 5% probability of the spawning stock biomass (SSB) falling below critical levels (Blim) – “the 5% rule”.  If fishing limits for Bothnian herring are set in line with the ICES headline advice of 55,869 to 62,684 tonnes, the probability of the spawning stock biomass falling below Blim in 2027 is 9-10%, well above the 5% legal limit. To comply with the law, the total catch in 2026 cannot exceed 25,560 tonnes. For Central Baltic herring, the probability of spawning biomass being below critical levels in 2027 after fishing the recommended 120,378 to 157,996 tonnes is 5.9-8.1%—also above the 5% rule. To comply, the total catch in 2026 must stay under 103,073 tonnes.
  8. ICES advises a maximum of 16,533 tonnes for the plaice quota in 2026. This is a decrease compared to the separate advice of 5,303 tonnes for subdivisions 24–32 and 20,062 tonnes for SD 21–23, given for 2025. 


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 .
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