Joint NGO recommendations on Baltic Sea fishing opportunities for 2022

CCB • October 8, 2021

In October 2021, EU fisheries ministers will agree on fishing opportunities in the Baltic Sea for 2022. As the deadline to end overfishing by 2020 at the latest as legally prescribed by Article 2(2) of the Common Fisheries Policy (CFP)1 has passed, all fishing limits must be in line with sustainable exploitation rates.

Last year, fisheries ministers set 2 out of 10 Total Allowable Catches (TACs) in the Baltic Sea exceeding the best available scientific advice for 2020, thereby contravening the CFP deadline. The European Commission proposal already included these 2 TACs, for eastern Baltic cod and western Baltic herring, exceeding scientific advice, while ministers also further increased catch limits beyond levels proposed by the European Commission for western Baltic cod, Baltic sprat, Baltic plaice and salmon in the Gulf of Finland.

The results of the holistic assessment by the Baltic Marine Environment Protection Commission (Helsinki Commission, HELCOM) on the state of the Baltic Sea reflect that several action areas lag behind in implementation, despite the deadline for achieving Good Environmental Status (GES) of the marine environment by 2020 according to the Marine Strategy Framework Directive (MSFD) and by 2021 according to the Baltic Sea Action Plan (BSAP)2. The European Green Deal3 commits the EU to tackling the impacts of climate change and protecting and restoring biodiversity. Specifically, the EU Biodiversity Strategy4 commits to ecosystem-based management, a transition to more selective and less damaging fishing methods, and to set all fishing limits at or below Maximum Sustainable Yield (MSY) levels, in order to restore ocean health. The Action Plan to conserve fisheries resources and protect marine ecosystems noted as a deliverable in the Biodiversity Strategy must become a crucial strategy to improve implementation of, and fill obvious gaps in, EU policies to put European fisheries management on a path where the full ecosystem and climate impacts of fishing are properly measured and mitigated. We are running against the clock to stop the collapse of the Baltic Sea ecosystem and deliver on political promises to halt the climate and nature crises.

The setting of fishing opportunities at sustainable levels is an essential precondition to deliver on these promises. The European Ombudsman has confirmed that fishing opportunities documents contain ‘environmental information’ within the meaning of the Aarhus Convention, and made recommendations to improve the transparency of the Council when setting fishing opportunities. The Ombudsman further confirmed a finding of maladministration in April 20205, expressing disappointment that Council decision-making contravened key democratic and transparency standards.

The October AGRIFISH Council provides the Commission and fisheries ministers with a clear and attainable opportunity to deliver on their commitments in the updated HELCOM Baltic Sea Action Plan and the Our Baltic Declaration from 2020, as well as on their legal obligations according to the CFP to end overfishing. It is also an opportunity to begin to realise the ambition of the Biodiversity Strategy.

The following text outlines the joint NGO recommendations on Baltic Sea fishing opportunities for 2022 in the context of environmental regulations, EU fisheries legislation, scientific advice on catch limits, and the sharing of stocks with third countries.

Download the full joint NGOs recommendations (PDF).

By CCB June 15, 2026
The European Commission's evaluation confirms what environmental NGOs across Europe have long argued: the Common Fisheries Policy (CFP)'s challenge is not its design, but its implementation.
By CCB June 10, 2026
The poor status and decline of many Baltic Sea fish populations have been thoroughly documented over several decades, indicating that the entire ecosystem is in great distress. So far, policy interventions have not reversed, or even halted, the negative trend concerning many of these populations. The European Commission itself recently recognised in its Common Fishery Policy (CFP) evaluation report that progress on stock rebuilding is lacking and the number of stocks “ threatened by collapse due to impaired recruitment has increased during the reporting period ”. Fish populations that once formed the cornerstone of the Baltic Sea fishery, such as the eastern and western Baltic cod and the western Baltic herring, are now doing so poorly that the International Council for the Exploration of the Sea (ICES) is advising zero catch for these stocks. Yet, even with the targeted fishery being closed for some years now, none of these three stocks are showing sufficient signs of recovery. The condition (such as size and weight-at-age) of many flatfish populations, such as plaice, also raises alarm bells. The salmon spawning migration has fallen short of the target level in the past three years5. As a result, even the healthiest salmon stocks are now unlikely to produce enough smolts corresponding to sustainable levels in the coming years. To address the crisis facing Baltic populations and the broader ecosystem, political will and ambition to improve fisheries management, alongside full implementation of the CFP provisions, are needed. The recent INI report on the Baltic Sea Multi-Annual Plan shows that the European Parliament recognises the importance of ecosystem-based fisheries management as well as the need for consideration of environmental legislation when making decisions on fishing opportunities.6 Fisheries managers must now act swiftly and decisively on the commitment the Commission and Baltic Sea Member States made at last year’s October Agrifish Council to rebuild Baltic Sea stocks. This document presents the joint NGO recommendations regarding Baltic Sea fishing opportunities for 2027, prioritising long-term ecosystem health and sustainable fisheries management over short-term economic interests. The recommendations are based on the ICES advice, the objectives and requirements of the CFP8 and the Baltic Multiannual Plan (MAP), specifically to apply the precautionary approach and implement an ecosystem-based approach to fisheries management, and the objective of achieving Good Environmental Status (GES) under the Marine Strategy Framework Directive (MSFD). Last year’s overarching joint Briefing Series on TAC-setting, co-signed by almost 30 organisations across the EU and the UK, including environmental NGOs, recreational fishers, and fishing rights owners, remains valid and provides further context, background and detailed explanations on the cross-cutting issues raised in this document. Read the Joint NGO recommendations on Baltic Sea fishing opportunities for 2027 here .