Political ambition and actions fall short in the updated Baltic Sea Action Plan

CCB • October 20, 2021

 

20 October – Lübeck, Germany – The updated plan to achieve a Good Environmental Status of the Baltic Sea lacks strong commitments to protect one of the world’s most threatened marine ecosystems, say WWF and the Coalition Clean Baltic (CCB). 

 

The updated Baltic Sea Action Plan (BSAP) [1], intended to ‘drastically reduce pollution to the Baltic Sea and restore a good ecological status by 2030’, was adopted today by Ministers of Environment and Senior Government Officials from all Contracting Parties of the Baltic Marine Environment Protection Commission (HELCOM) and the Commissioner for Environment of the European Union in Lübeck, Germany. According to WWF and CCB, the BSAP actions fall short, and a much stronger political ambition is required for the coming 9 years.

 

Originally, the proposed measures did indeed include many of the ambitious actions and tough decisions that are so urgently needed. Over time, however, lack of political will and ongoing political and economic disagreements between sectoral ministries have successively weakened the plan” says Mikhail Durkin, Executive Secretary, Coalition Clean Baltic .

 

Out of all measures included in the original Baltic Sea Action Plan, only 25% of national measures have been implemented by all countries. Whilst the actions that the Contracting Parties will take are outlined in the updated plan, clear political commitments on the implementation of those actions are crucial to ensure that measures are followed through on a national level.

 

In their Baltic Shadow Plan [2] and letter to the HELCOM Ministers, NGOs and scientists [3], NGOs have outlined what they believed to be some of the major failures [4] of the plan and traced these failures to the lack of political will and leadership of the governments.

 

In order for the Baltic Sea environment to improve, Contracting Parties need to significantly reduce the cumulative, negative impacts from human activities and support the development of a minimal impact, climate-resilient and zero-carbon world.

 

Despite the plan’s overall shortcomings, WWF and CCB maintain that the original intention of the BSAP remains valid and urges Heads of States and Heads of Governments around the region to take responsibility to initiate a process to actually deliver what was originally promised by their governments – to take dramatic action to save the Baltic. ”The plan contains important measures like protecting 30 % of the Baltic Sea. To reach this goal, cooperation and commitment on a regional level is of the utmost importance” says Valerie De Liedekerke, Manager and Interim Director of the WWF Baltic Ecoregion Programme.

 

For further information:

 

Valerie de Liderkerke, Interim Director, WWF Baltic Ecoregion Programme, valerie.deliedekerke@wwf.se

 

Hannah Griffiths Berggren, Communications Manager, WWF Baltic Ecoregion Programme hannah.griffiths.berggren@wwf.se

 

Mikhail Durkin, Executive Secretary, Coalition Clean Baltic mikhail.durkin@ccb.se

 

Federica Pastore, Communication Officer, Coalition Clean Baltic federica.pastore@ccb.se

 

Notes to the editors:

 

CCB – Coalition Clean Baltic is a politically independent, non-profit association, which unites 23 member organizations and 1 observer, 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 Baltic 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/

 

The update process – HELCOM launched the Baltic Sea Action Plan (BSAP) process nearly two years ago and WWF and CCB have been active participants in the ongoing stakeholder process to develop the plan. WWF and CCB participated as official HELCOM Observers to the Ministerial Meeting today, and WWF delivered a joint statement made on behalf of the environmental NGOs, stating the concern that this plan lacks the very tough actions and commitments that are needed to achieve its objectives. For more detail on the background, goals and objectives of the HELCOM Baltic Sea Action Plan please visit: http://www.helcom.fi/BSAP/en_GB/About_BSAP/

 

  • [1] The updated Baltic Sea Action Plan (BSAP):
    https://helcom.fi/baltic-sea-action-plan/
  • [2] The Baltic Shadow Plan: For the future of the Baltic Sea –
    http://ccb.se/the-baltic-shadow-plan-for-the-future-of-the-baltic-sea/
  • [3] Letter to HELCOM Ministers, NGOs and scientists – 
    http://ccb.se/letter-from-ngos-and-scientists-calls-to-take-action-for-the-baltic-sea
  • [4] Major failings highlighted to the HELCOM Contracting Parties have included:No concrete measures for how countries will ensure implementation of the BSAP (for example ensuring funding and HELCOM capacity-building).
  • No concrete measures on how countries will ensure a “green recovery” post-Covid.
  • Lack of concrete, ambitious and measurable climate change adaptation and mitigation actions. The ministerial declaration should contain clear adaptation and mitigation commitments like for example phasing out oil and gas production in the region.
  • Weak formulation of commitment to the global environmental goals. The Baltic Sea states should clearly state their commitments to:
  • reaching the goals of the Agenda 2030, not just by contributing to the implementation
  • reaching the goals of the Paris Agreement

 

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)