Positions & Papers

Joint follow up letter to Commissioner Kadis on ICES scientific advice

December 10, 2025

FishSec, together with a broad coalition of environmental organisations, recreational fishers, and representatives of the small-scale fisheries sector, has sent an open letter to the EU Fisheries Commissioner. In it, we urge the European Commission to strengthen the scientific advice that guides EU fishing limits. For Baltic forage fish such as herring and sprat, already under considerable pressure, the current advisory framework does not fully reflect ecosystem needs or ongoing environmental change, nor does it support the timely rebuilding of depleted stocks. Forage fish are central to the Baltic Sea food web, yet the present ICES advice relies heavily on single-stock MSY calculations and does not sufficiently account for natural mortality, other human-driven pressures beyond fishing, or the need to rebuild biomass to levels resilient to climate-driven and ecological stressors. The letter calls on the Commission to use the renewal of its agreements with ICES to ensure advice that is precautionary, ecosystem-based, and explicitly oriented toward stock recovery. It also urges the EU to request proper rebuilding advice for depleted Baltic stocks and to apply more cautious catch limits until improved scientific guidance is available. Strengthening the advisory system is essential for delivering ecosystem-based fisheries management, and for enabling the recovery of herring, sprat, and the wider Baltic Sea ecosystem.

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Joint NGO briefing: Don’t sink the Common Fisheries Policy – fulfil its potential

November 20, 2025

As the European Commission prepares its evaluation of the Common Fisheries Policy (CFP), environmental NGOs across Europe and beyond urge EU and national policymakers to help build a sustainable and resilient fishing sector by upholding regulatory stability and prioritising the effective implementation of existing law

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Open Letter to the Danish Fisheries Minister (in English): Leading the Way Toward Precautionary Baltic Sea Fisheries

October 13, 2025

Open letter sent on behalf of 11 organizations ahead of the negotiations on the fishing opportunities for the Baltic Sea for 2026 (in English).

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Open letter to the Danish Fisheries Minister (in Danish): Vis vejen til forsigtighedsbaseret fiskeriforvaltning for Østersøen

October 13, 2025

Open letter sent on behalf of 11 organizations ahead of the negotiations on the fishing opportunities for the Baltic Sea for 2026

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Statement on the recovery of European eel in the Baltic Sea region

September 18, 2025

Statement on the recovery of European eel in the Baltic Sea to all representatives of Baltfish and the Baltfish Presidency. Jointly signed by eight NGOs. The signatories highlight the urgent need for stronger, coordinated measures to protect the critically endangered European eel. Despite long-standing EU regulations, HELCOM commitments, and additional protective measures, progress on recovery has been slow and limited. The most recent ICES advice (2024) calls for zero catch of eels at all life stages across all habitats, yet significant commercial and recreational catches continue in the Baltic region. Restocking practices are not considered true conservation measures under EU law, as they primarily sustain fisheries rather than recovery. The signatories call for:

A full closure of all eel fisheries until the population has recovered.
Agreement on a regionally coordinated approach to protect eel migration, based on science and best available knowledge about migration routes.
That national eel management plans prioritise other measures, such as restoration of habitats and migration routes, that will aid eel recovery.

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Open letter: Öppet brev till ministrarna – Our Baltic III (Swedish)

September 16, 2025

Uppmaning till Sveriges landsbygdsminister och Sveriges klimat- och miljöminister att påskynda återuppbyggnaden av Östersjöns fiskpopulationer i samband med konferensen Our Baltic III den 30 september. Med anledning av den stundande konferensen Our Baltic III vill vi - miljöorganisationer, fiskerättsinnehavare och sportfiskare - uttrycka vårt stöd för de åtaganden som gjordes under de tidigare konferenserna Our Baltic I och Our Baltic II. Vi välkomnar initiativet till en ny konferens och vill betona behovet av ytterligare insatser för att skydda och återställa havsmiljön, och påskynda återuppbyggnaden av Östersjöns fiskpopulationer. Östersjöns ekosystem befinner sig fortfarande i ett kritiskt tillstånd och det krävs omedelbara politiska åtgärder, ambitiösa åtaganden och en stark beslutsamhet att genomföra dem.

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Call to European Commissioners to Accelerate Fish Population Rebuilding in Connection with the Our Baltic III Conference

September 11, 2025

Joint letter to the European Commissioners for Fisheries and Environment ahead of the Our Baltic III Conference in September 2025. The letter welcomes earlier commitments from previous Our Baltic conferences but highlights that Baltic Sea fish populations remain in critical decline due to overfishing, habitat loss, pollution, and climate change and stresses that urgent political action, ambitious commitments as well as a strong determination in their implementation are needed.

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Joint briefing series – Cover Briefing: Key recommendations on setting fishing opportunities

July 18, 2025

Cover briefing of the joint briefing series ‘Recommendations to the EU and the UK on the Setting of Fishing Opportunities’, co-signed by 29 organisations (including environmental NGOs and recreational representatives) calling for recovery-focused, precautionary, and ecosystem-based fishing opportunities. The series, consisting of 11 briefings, was produced by ClientEarth, with FishSec as one of the co-signers. The Briefings covering the following topics related to the setting of fishing opportunities:

Briefing 1- Cover Briefing: Key recommendations on setting fishing opportunities
Briefing 2 - Context and legal framework
Briefing 3 - “Best available” is not good enough - addressing shortcomings in the current scientific advice
Briefing 4 - Shared fish stocks
Briefing 5 - Fishing opportunities in an ecosystem context
Briefing 6 - Mixed fisheries considerations
Briefing 7 - The fishing effort regime in the Western Mediterranean Sea
Briefing 8 - Landing obligation challenges
Briefing 9 - Depleted stocks with zero or very low catch advice
Briefing 10 - Stocks not managed by a TAC
Briefing 11 - Deep-sea stocks

Report: Small fish with a big impact

July 17, 2025

Report on Baltic Sea forage fish published by FishSec in 2025. The report was produced as part of our forage fish project Small Fish – Big Impact and is based on a review of scientific literature. It provides an overview of population health and the significance of sprat and herring stocks in the Baltic Sea, as well as our policy recommendations.

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Executive Summary: Small fish with a big impact report

July 15, 2025

Executive summary of the report Small Fish – Big Impact: The Importance of Forage Fish in the Baltic Sea, published in July 2025. The report was produced as part of our forage fish project and is based on an extensive review of scientific literature. It provides an overview of population health and the significance of sprat and herring stocks in the Baltic Sea, as well as policy recommendations.

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