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Coalition Clean Baltic

CCB

CCB is a network of national NGOs formed to organize cooperation among member organisations, and to via the international office staff represent all Baltic region grass root NGOs in international fora, to follow the development of processes and relevant environmental and marine policies on an EU level and act towards relevant bodies such as HELCOM, BSAC, EU Strategy for the Baltic Sea Region etc.

Lobbying Activity

Meeting with Isabella Lövin (Member of the European Parliament, Shadow rapporteur) and Seas At Risk

10 Dec 2025 · Marine multi-use windfarms and fisheries

Meeting with Costas Kadis (Commissioner) and

7 Nov 2025 · Participation of NGOs to Advisory Councils

Response to Implementing Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation

12 Aug 2025

The new wording of Article 12 2(c) is very positive. Each pot or trap in a trap line should be identifiable, especially if the line breaks and only fragments can be retrieved. It is important to have each pot labelled because in the case of bycatch, the pot can be assigned to a vessel and detailed information on gear setting requested. This will help to develop bycatch mitigation measures and to possibly prevent bycatches in the future. Regarding Article 21 (g iii and iv): (Marking of entry and exit of waters of third country waters). It would be beneficial if also ENTRY and EXIT of an area where fishing prohibitions apply, such as Marine Protected Areas (plus the 5 nm buffer zone according to Article 23) will be marked in the vessel position data accordingly. Minimum requirements for logbook data: In Art. 25 1. (a) of the draft implementing regulation there are references to Annex XV of this Regulation. However, there is no Annex XV in the draft regulation. We have therefore assumed that the Annex XV from implementing regulation 404/2011 and also other Annexes such as Annex VI and Annex XI which we will be commenting on here are proposed to remain unchanged. It is important to emphasise that reporting of all bycatch of protected species needs to be mandatory in logbooks, which still is not the case in the new draft implementing delegation. Annex VI in Reg. 404/2011 shows an example of logbook requirements but there are no specific fields for bycatch of protected species. It is unlikely that the fisherman would report bycatch in kilos, which is also very unhelpful as information on ETP species bycatch. In order to increase self-reporting of bycatch, separate fields for bycaught species and number thereof should be urgently added as mandatory logbook fields. It is also important to note that more detailed data on fishing effort is urgently needed for estimating bycatch of protected species (which is required by the Habitats Directive and the Marine Strategy Framework Directive). Therefore, in Annex XI, please change in the column 2 header optional to mandatory. Dimension of gear is very important information to estimate bycatch numbers. Also, there needs to be information about soak time. Thus, it is especially important to add the dimensions (length and height) and soak time of GILLNETS AND ENTANGLING NETS. For Pots it is very important to add the time the pots actually fished. Currently, only the number of pots shot per day is asked for (and this is only optional), and hence the fishing time cannot be deducted. The Commission requests ICES Advice on bycatch of protected species on an annual basis. However, if the data collected under EU regulations lacks important information such as gear dimension and soak time, then the bycatch calculation will lack in precision. ICES has repeatedly pointed out that gear dimension and soak time is needed to assess bycatch rates with enough precision. It should be of high priority, with this implementing regulation, to improve reporting so that estimates can finally achieve the quality needed under EU environmental legislation, and allow for effective and precise mitigation.
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Meeting with Eva Maria Carballeira Fernandez (Head of Unit Maritime Affairs and Fisheries) and ClientEarth AISBL and

15 Jul 2025 · Recommendations on how to address shortcomings in the ICES advice and requests

Response to The European Oceans Pact

17 Feb 2025

CCB sees the EU Ocean Pact as a unique opportunity to establish the much-needed overarching Ocean Law/Ocean Policy, which is required to create coherence and enforce full implementation of existing EU nature and marine policies, as well as to ensure a true ecosystem-based management of our seas. The Ocean Pact can set us on a path to a recovery of the marine environment under a sustainable and just blue economy, but only if the Ocean Pact and its roadmap include robust tools, deadlines, binding targets and if its implemented swiftly and fully. CCB highlights the following essential points that must be included: Legally Binding Targets: The roadmap must protect, restore, and conserve the seas, incorporating EU goals for biodiversity, restoration, and the blue economy. Clear targets should be set for 2030, with mid-term (2040) and long-term (2050) goals and the Pact should include commitments to draft new legislation ensuring full implementation of these objectives. Coherence: Align marine legislation, policies and strategies, including MSFD, CFP, Marine Action Plan, Biodiversity Strategy, NRR, WFD, RED, HD, BD and N2000-network, MSPD and address existing and emerging pressures, such as shipping, underwater noise, mining, gravel and sand extraction, ORE, CCS and of course commercial and recreational fishing. Regional Considerations: Acknowledge and address regional challenges, which for the Baltic Sea means that the substantial pressures from land-based sources and agriculture must be tackled. Ocean Fund: Establish a new fund aligned with legislation to implement the Ocean Pact. The Ocean Fund would replace EMFAF and be used to fund 1) ocean conservation & restoration, and 2) a just transition to a regenerative blue economy. Harmful subsidies like fuel tax exemptions for fishing vessels would be eliminated. Integration into MSPs: Incorporate MSFD (GES, EBM), Biodiversity Strategy (30x30, strictly protected areas), and NRR goals into national maritime spatial planning. Regional MSP on a sea basin level is essential to align the goals of the RED with those for the marine environment, and its also necessary to identify cumulative effects from i.a. ORE and CCS. Operationalizing the MSFD: Incorporate agreed MSFD TVs (e.g. for D6 and D11) into the roadmap with binding targets for their implementation and ambitious deadlines. Include commitments to establish TVs for all descriptors and to fully operationalize the directive, being aware of the potential MSFD review process. Full implementation of the CFP: The regulation is fit for purpose, but the Ocean Pact needs to ensure its full implementation, e.g. for articles 11, 12, 13, 17 and 20 and of EBFM. Better control and bycatch mitigation measures (including for the critically endangered Baltic proper harbour porpoise, see ICES special advice), as well as decarbonization (achieved by i.a. putting a price on emissions) of the industry as a whole, is also needed. Mandatory REM needs to be phased in on all vessels and the work from the ETP incorporated. The Pact should also include binding targets for implementing the Marine Action Plan fully and supporting a just transition towards low-impact, small-scale fisheries, which are more sustainable for the marine environment and have a lower carbon footprint, whilst they support local coastal communities. Lastly, the Baltic Sea faces specific problems that should be taken into account in the Ocean Pact. These include the severe effects from eutrophication, mainly due to nutrient runoff from land-based sources, as well as the high levels of other pollutants and hazardous substances. 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. Full implementation of the HELCOM BSAP is also essential for the region to reach GES and other EU targets. See the attached documents for more information.
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Meeting with Karin Karlsbro (Member of the European Parliament, Shadow rapporteur) and Världsnaturfonden WWF (WWF Sweden)

15 Oct 2024 · Hearing om framtida strömmingsfiske

Response to Evaluation of the Common Fisheries Policy

6 Sept 2024

CCB is fully convinced that the CFP basic regulation is functional and fit for purpose. The fact that we are not achieving the goals set by the CFP is because the intention, interpretation and implementation of CFP rules and targets by management and organisational structures are not right. There are multiple examples, that certain articles of the CFP are misinterpreted, misused or simply unused. An example for misinterpretation and misuse are the biological reference points: The CFPs fundamental MSY Objective explicitly applies to both fishing pressure and biomass, requiring that all stocks are maintained or restored above levels capable of producing MSY (=BMSY). The same objective is underpinned in the EU Multiannual Plans, where recovery actions for stocks under both Blim and Btrigger are required. Yet, the current EU fisheries management approach is not geared towards delivering such stock recovery above BMSY, but rather keeps stocks around the lowest available biological reference points Btrigger and Blim, which is far below the actual target of BMSY. The ongoing misinterpretation and misuse of these targets and safeguards by the EU Council have led to several ongoing court proceedings. An example for an unused article is Article 17 of the CFP Basic Regulation: The allocation of fishing opportunities is a key tool for moving away from environmentally damaging fishing practices towards low impact fishing supporting coastal communities. Art.17 specifically accounts for that by encouraging Member States (MS) to use transparent and objective criteria, including a social, economic and environmental nature in the allocation process. Yet, the current allocation is almost solely based on historic criteria, exacerbating the impact of large-scale and industrial fisheries, often using harmful fishing practices, at the expense of small-scale low-impact fishers and fragile marine ecosystems. The implementation of Art. 17 is an essential but unused tool to offer small-scale fisheries better opportunities and long-term stability despite the poor state of many fish populations (e.g. in the Baltic Sea). Until the CFP has been completely and comprehensively implemented, it is not possible to evaluate how and if the content of the regulation is bringing us closer to our goal of healthy and thriving fish populations and fisheries in the EU. Therefore, it is not relevant aiming to overhaul CFP in any way, but rather continue to investigate and identify the core reasons for failures and missed targets. In 2023, the Commission adopted the Marine Action Plan and the accompanying Joint Special Group, which have highlighted key deficiencies of the CFP implementation and the need for better coordination among fisheries and environmental institutions and regulations, such as the MSFD, Habitats Directive and NRL. It also pointed to the great differences in national implementation efforts and efficiency by the EU MS. With this, the Commission has not only started to evaluate and underline the reasons of failure, but has already started to build the new structure for the coordinated efforts we need to protect, rebuild and maintain healthy fish populations. CCB suggests that the following issues are evaluated and clarified before any changes are made to the CFP Basic Regulation: -How does the requested science input from ICES supports the CFP targets (different advices and scenarios including size and age structures, food webs etc.)? -What are the institutional and organisational hurdles of successful rebuilding of fish populations in the EU? -How can the CFP better support goals and targets of other EU legislation, such as the MSFD (GES, D3 and D4) and the NRL (passive restoration through trawl-free or no-fishing areas)? -How can the revised control regulation contribute to end the broadscale non-compliance with the Landing Obligation? -How is the European Maritime, Fisheries and Aquaculture Fund used and how it is contributing to the CFP targets?
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Response to Correction to the multiannual programmes for fisheries

31 Jan 2024

CCB does not approve of this proposal and suggests the best way forward is to withdraw it and start over. CCB considers that the Commission proposal is poorly justified, and that it is questionable both from a procedural point of view as well as from a legal point of view. CCB also notes that the multi-annual plans (MAPs) in place are different and a removal of one article is not possible without detailed scrutiny of each plan and the resulting consequences (e.g. target stock and bycatch stocks being treated very differently in the MAPs). Poorly justified: the recent decision in the Agrifish Council in October (the adoption of Council Regulation (EU) 2023/2638 fixing Baltic Sea TACs for 2024) showed that even with article 4.6 in place, the Council disregarded this provision and misused its powers under Article 16(4) of the CFP Basic Regulation by setting TACs based on other objectives than those recognised under Article 2(2) of the CFP. To remove the article and place trust in a very ambiguous article 5 is reduces both legal certainty and the level of protection of strained fish stocks. The two articles are neither redundant nor mutually exclusive as the Commission seems to argue for. Article 4 is about setting TAC for target species. Not to have a clear stop rule for setting TACs also for a scenario when stocks are or risk falling below Blim would quickly raise the argumentation to create such a rule. Considering the proposal text and background, it seems clear that it is not article 4 that needs amendment. It is, instead, article 5 that needs amendment: the more detailed provisions of what remedial measures should be implemented should be amended, if anything. It would be desirable to set timelines and restrictions on how to swiftly return to biomass levels above Btrigger (not only Blim, because this is not the target at all). Poor procedure: changes to the MAPs should be done with proper consultation and prior impact assessments. This did not at all take place in this case. Such a process would have shown that there are several parts of the MAP, including recitals, that needs to be updated to better handle situations such as in the Baltic Sea with several collapsing stocks, and actually reach the better consistency and clarity that the Commission seeks. The speed with which this proposal was developed and pushed forward to the co-legislators only underlines that it is a rushed job not quite done and fully thought-through. This leads us to our final point of legal nature. Legally questionable: a clear CFP objective is to avoid negative impacts on stocks and the wider ecosystem. The aim is to reach and maintain strong stocks and a resilient ecosystem. Explicitly this is stated in the CFP basic regulation in relation to setting TACs in line with MSY by 2020. This deadline and target is without question, recently again underscored by the Court of Justice of the EU in Case C-330/22. Thus, removing an article that halts fishing when stocks are below Blim is not only strange, but also a breach of the intentions of the MAPs and the CFP MSY objective. We remind the reader that the target is BMSY, not Btrigger and certainly not Blim. Stocks falling below Blim would even call for use of emergency measures under CFP art. 12. In a sense, the argument with demand to reach and maintain MSY level for target stocks would rather call for changing article 5.2 to be more explicit in terms of what must be done in such circumstances, as currently with stocks below Blim, for which article 4.6 notes that targeted fishing cannot take place. CCB does see needs to improve the MAPs and have stated since they were first drafted that they are empty and lack clarity. The intention to use regionalization to add details has not worked well. This targeted revision of the MAPs should not move forward without proper analysis and additions. We repeat our strong recommendation to withdraw the proposal at this stage.
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

21 Jul 2022

Recent events and the situation in Ukraine have put a new emphasis on the overdue development of renewable energy in the European Union needed in order to achieve climate targets. We welcome these new ambitions, but appeal to the policy makers that the expansion of renewable energies must not be achieved at the expense of biodiversity. The world is not only in a climate crisis, but also in a biodiversity crisis. Healthy oceans are crucial to help in tackling the climate crisis, thus the “overriding public interest” must not override any measures that help us to reach conservation targets and protect or restore biodiversity. Unfortunately, this proposal opens the door for this possibility. See attached document for a more detailed feedback.
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Response to Action plan to conserve fisheries resources and protect marine ecosystems

12 May 2021

CCB welcomes this initiative and fully agree with the described problems and linkages with existing legal frameworks and the EU Biodiversity Strategy. We appreciate efforts to make better use of existing rules under the CFP such as fish stock recovery areas, not at all utilized today (art. 8). We are also happy to note the shared approach now between DG mare and DG environment as one step of an ecosystem based management in merging multiple strands of management, opposed to silos. We see this action plan as a possibility to bridge gaps in and between existing legislation and addressing the lack of implementation, and not the least as a way to support the MSFD realization of the GES objective. This plan must really focus on concrete actions to achieve agreed goals. One gap is climate change mitigation where healthy ocean ecosystems play an important role and the scope of the action plan could be wider to fully adhere to this, for example by speeding up the reaching of well managed MPAs and strictly protected areas as part of the resilience needed for our oceans. Additionally, while we appreciate the focus on limiting the use of fishing gear most harmful to biodiversity and the seabed, we would like to point to the importance of an integrative approach as the legal framework for protecting marine habitats most subjected to bottom-contacting gear (deep soft bottoms) is currently lacking. The roadmap states: “The action plan will come on top and in full synergy with other actions already undertaken in the context of the common fisheries policy as well as with the implementation of the Biodiversity Strategy, such as the extension and effective management of the marine protected areas or the adoption of legally binding restoration targets.” We hope this means that this action plan together with setting new legally binding restoration targets is a package to address parts of the failures with implementing CFP and MSFD, for which another roadmap was just recently presented. Such a package should be in place before any review of the MSFD is considered, as new initiatives like this will require time, resources and expertise. The Commission now risk running parallel processes with one evaluating MSFD and two more trying to partly address the problems with the MSFD implementation before an evaluation and needs are made clear. Such dual approach will also create confusion unless this plan stays concrete and implementable in the short to medium term. To underline: 1.We feel the scope of the action plan is too limited and should consider introducing missing elements in the technical measures framework, actions to implement MPA management, reconsider prohibited species lists (e.g. by adding European eel and a number of red listed shark and ray species) and climate change mitigation needs. 2.The action plan must be able to propose regional actions but this is not mentioned in the roadmap. The Baltic Sea situation is dire and specific needs to introduce a new approach to management with concrete actions aiming to recover the collapsed ecosystem and its top predator, the Baltic cod must be a priority. 3.MSFD is repeatedly pointed to in the roadmap document as a vital legislation, and a review of MSFD is specifically mentioned. We feel such a review is very premature and instead consider the action plan as a key component to strengthen the MSFD implementation by closing several gaps and issues noted in the MSFD evaluation roadmap (Ref. Ares(2021)2411326 - 08/04/2021) 4.Commission should clarify how now several ongoing initiatives are concretely linked and in what order they are prioritized by presenting a clear timeline and approach to find the synergies noted in the roadmap. To conclude, we fully support the development of a concrete plan and are eager to engage with concrete proposals, but several issues noted here should be carefully considered by the Commission in coming months to make best use of a new biodiversity action plan.
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Response to Protecting the environment in the EU’s seas and oceans

5 May 2021

MSFD is a crucial framework with deep links to global agendas down to national legislation that has been updated because of its introduction in 2008. The logic of its objective as well as its wide range with an ecosystem based approach has even spread to other countries such as Canada. CCB acknowledge the presented initiative as both the legally stipulated evaluation (art. 23) as well as an attempt to consider MSFD in light of the Green Deal agenda and the Biodiversity Strategy to improve its implementation. It is vital that such other ongoing initiatives are considered as directly linked to the wishes to improve implementation of MSFD. CCB appreciates the published roadmap clarity on failures to set measurable targets, on poor regional coordination and difficulty to address economic activities such as fisheries and agriculture that have an impact on the marine environment. CCB also appreciates that there are a few not so well hidden frustrations embedded in the document of the shortcomings of implementation of MSFD so far. We greatly share this frustration of poor progress even though the tools and often the funding are both available. Considering the above, we are positive towards a full evaluation of links to new initiatives and other EU legislation as well as how better coherence and implementation can be ensured. However, we remain skeptical to opening the MSFD itself to reach the improvements needed. Such a process may take valuable time and resources away from both ongoing implementation and focus on making better use of the existing legal frameworks and planned initiatives such as the Action Plan for fisheries, binding restoration targets, Farm to fork etc. As stated by the EC in its implementation report(https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020D) we believe that it is up to the MS to deploy the necessary capacities to ensure that the EU seas are in GES by allowing sufficient financial and human resources and to the EC to ensure effective implementation of the MSFD by giving better guidance. Even though the roadmap clearly states that an evaluation will take place first, the document outlines possible paths to take. We appreciate the listing of policy options (on page 4) but think that it is premature to consider such options at this stage. The third option to “strengthen implementation and enforcement of the Directive without changing its provisions” seems to us the most relevant one to keep focus on during the evaluation. The Framework is well suited but it needs more legal support and enforcement – with a particular focus on how to ensure MS will address key pressures in the marine environment – and that is what all efforts should be directed at. So in summary: -MSFD is a crucial Directive, key for multiple other legislations, Regional Seas Conventions and national law -We do support a thorough evaluation of MSFD to pinpoint the needs to improve implementation and remain committed to taking part in the process -It is premature to consider any policy options before an evaluation and possible linkages and mutual support from other legislation are fully explored -MSFD needs better implementation through support legal acts to address key pressures in the marine environment as noted in the roadmap, including new initiatives that are coming. Also, better use of existing legislation such as the CFP to support reaching GES must be explored (technical rules, control rules but also Basic regulation articles 8, 11,17,19,20), particularly within the fisheries Action Plan (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12953-Action-plan-to-conserve-fisheries-resources-and-protect-marine-ecosystems-) -There is considerable risk of opening the Directive without a clear path for strengthening it as it will drain resources for years -Ongoing implementation is at serious risk of being slowed down or be completely stalled due to a signal of possible revision in 2023
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Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

16 Sept 2020 · Workings of the Advisory Councils

Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

CCB welcomes the opportunity to provide comments on the EU commission’s initiative to update of concentration limit values of persistent organic pollutants in waste. We believe that the issue of limit values of POPs in waste is very important in light of transition of EU and its member states to circular economy and implementation of the European Green Deal, and in particular stipulated ambition for toxic-free environment. The EU POPs Regulation should respect the objectives and requirements of the Stockholm Convention and should therefore not lead to or promote the recycling of POPs waste. This may be the case if the defined limits for the content of POPs in waste are too benevolent and if their setting is based more on the economic interests of industrial groups than on the protection of public health and the environment. We think that some of the limits for POPs in waste, as set today, are too weak and do not hinder the circulation of POPs in reused materials and recycled products. This is shown, for example, by studies showing the presence of high concentrations of PBDEs in toys or kitchen utensils made from recycled plastics (Kuang, Abdallah et al. 2018, Straková, DiGangi et al. 2018). The same phenomenon occurs by recycling ash from incinerators containing high concentrations of dioxins (Katima, Bell et al. 2018). Most POPs like DDT or technical PCBs have a limit of 50 ppm as their threshold definition for POPs waste. However, for POPs recently added to the Stockholm Convention, an option of 1,000 ppm for HBCD and the PBDEs, and an even higher option of 10,000 ppm for SCCPs are allowable under EU legislation. These thresholds cannot be supported on health and environmental grounds as the new POPs are just as hazardous as the old POPs. Even worse, they are more commonly found in our homes and domestic environments. Therefore, we suggest the EU tighten the limits for currently evaluated POPs. The current weak limits for some POPs in waste lead to contamination of the recycling chain. This applies to PBDEs, HBCD, SCCPs, PCDD/Fs and dl-PCBs in particular. Occurrence of these hazardous substances in recycled materials and products undermines public support for recycling and the circular economy. We underline that the EU does not decide only about its own environment when establishing low POPs content at „weaker“ or „stronger“ levels but also about environments in countries outside of Europe which often don’t have capacities to deal with POPs contaminated waste at all. This leads to the situation where, for example, e-waste plastic containing POPs can be exported to low income countries and is then openly burned to recover metals, creating dioxins which contribute to global contamination affecting food chains globally, including in the European Arctic region. Recent studies found that the current weak limits for dioxins (PCDD/Fs) in wastes (15 ppb) leads to uncontrolled use of hazardous waste and contamination of food chains at unacceptable levels. EFSA has recently lowered tolerable daily intake suggested for dioxins and dl-PCBs by seven fold (EFSA CONTAM 2018a). If limits for these POPs will be set too high, as it is suggested, it will go against EFSA’s suggestions to lower exposure of human population to these toxic compounds. We call on the European Commission to set up low POPs content limits which will protect human health and environment and which will take into account ALL economic implications including costs due to health damage consequences. This means support for more protective low POPs content limits for the following substances: • 1 ppb (= 1 ng/g WHO-TEQ) for PCDD/Fs + dl-PCBs with additional limit of 50 pg WHO-TEQ/g (0.05 ppb) of these substances for untreated waste used on land surface • 100 ppm (= 100 mg/kg) for HBCD • 50 ppm (= 50 mg/kg) for sum of PBDEs (including Deca-BDE) • 100 ppm (= 100 mg/kg) for SCCPs • 10 ppm (= 10 mg/kg) for sum of PFOA/PFHxS and related substances
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Meeting with Virginijus Sinkevičius (Commissioner) and

16 Jul 2020 · To discuss the fishing opportunities exercise for 2021, in particular for the Baltic Sea, as well as issues related to the Biodiversity Strategy.

Meeting with Virginijus Sinkevičius (Commissioner)

21 Jan 2020 · To discuss ecosystem-based approach in the Baltic and HELCOM Baltic Sea Action Plan

Response to A new Circular Economy Action Plan

20 Jan 2020

Coalition Clean Baltic (CCB) is a regional network of grass root environmental NGOs committed to protection and improvement of the environment of the Baltic Sea catchment area. The network was established in 1990 and includes 22 member organizations representing the main largest environmental non-governmental organisations with more than 800.000 individual members in the countries within the Baltic Sea catchment area, both within and outside the EU (in Russia, Belarus and Ukraine). CCB is working with circular economy issues as a part of its Hazardous Substances and Marine Litter working area (Working Upstream / Working on Land). CCB welcomes the development of new Circular Economy Action Plan EU Plastic Strategy, and would like to bring the following information to the attention: We support the general outline of the context, problem and possible achievements, which plan is going to achieve. We think that the issue of advancing of circular economy has a key importance for addressing of many current environment problems, including those related to chemicals and waste pollution of the marine environment. On Sustainable products policy: we think that policy shall also cover the issue of chemicals in products, and provide requirements for mandatory disclosure of information about the content and circularity aspects of the products by producers. This information shall not be regarded as confidential business information. On Consumers empowerment: it shall be ensured that consumers have a full access to information about the content of products, possible effects on environment/public health, and circularity aspects. On waste generation/management: in frame of the proposed plan, we urge EU not to consider waste incineration as a method of waste management, which corresponds to circular economy principles. Also, the issue of waste shipment from EU to Global South shall be properly addressed as at the moment, it doesn’t corresponds with circular economy principles. On high-impact sectors: we strongly support inclusion of textile into the Plan. On plastics we suggest also to focus on elimination of single-use plastic use in specific public sectors, e.g. HoReCa, and retail. Apart from working on bio-based and biodegradable plastic alternatives, we think that the plan shall also further promote usage of multi-use non-plastic alternatives.
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Response to Evaluation of the Eel Regulation

11 May 2018

CCB fully supports this process and want to see a thorough evaluation of the eel recovery plan and the national implementation via the set measures and monitoring. We appreciate the outlined approach related to the WFD RBMPs as this is important to look closely at since RBMPs has mostly ignored eel. Several other EU Directives and policies related to fishing, water and marine environment has changed since the eel recovery plan was concluded and they must all be considered carefully as noted in bullets below. Evaluation process - important highlights: 1.A truly external evaluation is important, as the Commission of course is aware. CCB wants to underline that regarding eel it is even more critical due to the rather small number of “experts” there are and same views have tended to dominate the discourse over a long period of time. An external should preferably include evaluators/experts from outside the EU. 2.Besides the six points listed as inputs used for the evaluation, CCB wants to underline the large IUU problems on both glass eel and adult eel that is a well known fact in several Member States. The evaluation should consider this with special focus and look for any attempts have been made to address the problem via traceability tools, targeted surveillance etc. 3.The evaluation should make an effort to consider socio-economic impacts of eel fishing and since this is a core discussion in several Member States and e.g. questions about effects of reduced fishing will be central. 4.We fully welcome a deep analysis of the restocking of wild eels across the EU and how public money has been spent on this considering the poor evidence of actual effect in light of the continuation of the downward trend of the eel stock. The basis of taking a “surplus” of glass eel and relocate is simply not possible in current situation, and it has been shown to take place to support the fishery rather than the eel recovery. Brexit is a factor to consider as well since glass eel has been moved from UK waters to the Baltic region for example. 5.Even though the situation is urgent for the eel, this evaluation and following proposals to strengthen the recovery process for eel should be done thoroughly and be allowed to take time. The proposed timeline should be sufficient but if it is not, CCB feels it more important to make a total overhaul and evaluation at this time than to stick to the timeline set today. 6.CCB concludes from Members States reactions during discussions in 2017 that eel management decisions should be taken at EU level. Regionalization seems not at all to apply for eel. However, the evaluation could consider and ask questions about whether a regional approach (linked measures, IUU/sales cooperation, closure timing etc) instead of country by country could have been a better option. Evaluation - follow up analysis Since the creation of the Eel recovery plan, several new Directives and the CFP has changed the waterscape. Such changes are perhaps not relevant to consider for evaluation per se, yet are crucial to consider for aligning with current EU as noted in the consultation document. Eel management is deeply linked to CFP goals and ambitions (EMFF, DCF, Control, Tech. measures), also WFD, MSFD. Regardless if recreational of commercial, fishing on eels must be in line with MSY and consider impacts across the entire life cycle and full distribution range of eel. Policies, Directives, instruments, processes important to consider: • CFP and MSY, including recreational fishing • WFD and upstream work • MSFD and linkages to WFD especially the coastal zone • Future EMFF and use of public money • Stronger PPP focus reg. hydropower • CITES and linked problems of illegal trade and “lost glass eels” • CMS commitments and the international level of eel management • CBD an EUs 7th Environment action program goal of no loss of biodiversity • SDGs and regional seas conventions actions related to biodiversity and eel
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Response to Strategic approach to pharmaceuticals in the environment

26 May 2017

Coalition Clean Baltic (CCB) is a regional network of grass root environmental NGOs committed to protection and improvement of the environment of the Baltic Sea catchment area. The network was established in 1990 and includes 18 member organizations representing the main largest environmental non-governmental organisations with more than 850.000 individual members in the countries within the Baltic Sea catchment area, both within and outside the EU (in Russia, Belarus and Ukraine). CCB is working with pharmaceuticals pollution as a part of its Hazardous Substances working area (Working Upstream / Working on Land). At moment we are working on assessment of the efficiency of the existing collection schemes for obsolete pharmaceuticals from the population in BSR countries with the aim to define regional pollution hotspots and elaborate approaches to minimize the impact in each region, with special focus on public involvement, and public awareness raising. More information is on our web-site: www.ccb.se CCB welcomes the roadmap proposals, and suggests the following additions: Part B under the heading: “What does the initiative aim to achieve and how”, CCB recommends to include the following details for how to achieve the defined goals: - Organizing public and professionals awareness raising about the effects of human and veterinary pharmaceuticals on the environment, and ways to minimize it. - Creating clear and mandatory regulation on the collection and disposal of obsolete pharmaceuticals. CCB would also like to point out the need to use the risk assessment of pharmaceuticals, and their metabolites in the environment when addressing the knowledge gaps. Also we think that it is important to assess the risk of various metabolites and transformation products in the environment. Also it is important to establish the threshold values for pharmaceuticals residues in different media. Also we think that the remaining process of the road map development shall include further consultations with key stakeholders, including environmental and public health NGOs. CCB also supports comments to the roadmap provided by HCWH Europe.
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Response to Interservice consultation on a Commission proposal for the GES Decision

11 Oct 2016

CCB wants to add to previous post since the first message was cut short: more detailed and important comments of individual Descriptors is available here http://www.ccb.se/wp-content/uploads/2016/10/NGO_comments_GES_decision_Oct2016.pdf
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