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. 

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)