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

CCB • December 7, 2020

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: 

 


 

  1. 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.
  2. 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.
  3. 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.
  4. 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].
  5. 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].
  6. 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]. 
  7. 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

 

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