Ten actions on our Christmas “wishlist” to ensure Ministers deliver a concrete plan to save the Baltic Sea

CCB • December 17, 2019

As the end of the year approaches, children and adults alike, will be writing their wish lists in the hopes that they might get a present on Christmas Eve. We, the Coalition Clean Baltic and WWF Baltic Ecoregion Programme, have a special wish this year: a Baltic Sea Action Plan (BSAP) with a focus on real actions to significantly improve the state of the Baltic Sea. We propose to start with ten things that Ministers should do to ensure that the Baltic gets the action plan it deserves.

So far, the Baltic Sea Action Plan has not met any of the four goals that were set back in 2007 [1] In our view, it needs a revolutionary update in order to fulfill any of the pre-existing goals, let alone any additional ones that are added during the update process [2]. The updated plan needs to be more than just a plan – it needs concrete actions that deliver measurable results.

Here are ten actions that all Ministers can do to ensure that Baltic Sea region gets the action plan it deserves:

  1. Adopt an ecosystem-based approach to marine management as a fundamental principle for the entire plan and all activities, to ensure the region is managed as a whole rather than separate components.
  2. Replace all ‘recommendations’ with ‘committed actions’.
  3. Include actions to address Climate Change, with no allowance of human activities which cause for an overshoot of 1,5 °C global warming threshold.
  4. Apply scientific knowledge and data on the potential risks and impacts associated with marine investments, as well as adopt indicators to monitor maritime sectors.
  5. Apply best practices to reduce and mitigate the impact of continuous underwater noise throughout the Baltic Sea Area.
  6. No more  ‘paper parks’ – ensure that Marine Protected Areas are effectively implemented and protected with comprehensive management plans that address all cumulative stressors that impact the MPAs biodiversity.
  7. Ensure the plan links food webs and interspecies considerations to rebuilding fish stocks to reach a stable size and age structure as well as resilient levels of biomass.
  8. Promote the drastic reduction of nutrient run-off, including improved management of nutrient balanced fertilisation as a required measure for all farms.
  9. Waste collection and filtration of pharmaceutical residues should be mandatory in all Countries, coupled with Extended Producer’s Responsibility and wide public awareness in off-and online pharmacies and healthcare institutions. 
  10. Ensure all ports have adequate reception facilities for ship-generated sewage and wastewater.

“The state of our oceans and seas is alarming. We can and must turn the tide on the downward spiral of biodiversity loss. Now more than ever, we need concrete implementation of the Baltic Sea Action Plan by all Baltic Sea countries in order to avoid continued loss of species and habitats that are symbolic of and essential to this brackish sea. We, in the NGO community, send this wishlist to all Baltic countries to propel them to take the lead and make the updated action plan ambitious and action-oriented. HELCOM has the platform and passion to empower change and save our loved Baltic sea”, says the Coalition Clean Baltic and the WWF Baltic Ecoregion Programme.

It is the responsibility of the national governments and Ministers involved in the update process to ensure that the action plan effectively benefits both people and nature. In light of the highly disappointing outcomes from COP25 [3], we can not help but wonder – will a Baltic Sea Action Plan (BSAP) be more than a plan or will that remain on our Christmas wish list again next year?

Note to editors:

CCB – Coalition Clean Baltic is a politically independent, non-profit association, which unites 22 member organizations and 2 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: panda.org/baltic

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The update process –

Contact:

Federica Pastore
Communication Officer, Coalition Clean Baltic (CCB)
federica.pastore@ccb.se
+46707662175

Hannah Griffiths-Berggren
Communications Manager, WWF Baltic Ecoregion Programme
hannah.griffiths.berggren@wwf.se
+46739237439

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)