Comments on the Commission’s Communication “Sustainable fishing in the EU: state of play and orientations for 2027”

Summary

• EU fisheries policy has given too low a priority to key objectives in the Common Fisheries Policy regulation and, in particular, to the multiannual plan for the Baltic Sea: restoring and maintaining commercially fished stocks to productive levels, and minimizing the environmental impact of fisheries.
• Given the uncertainties in fisheries assessments, achieving the stock objective is important to avoid the collapses in commercially fished stocks that have afflicted Baltic Sea fisheries in the past decade or two.
• Lower catch levels are important for the recovery of depleted stocks. It is likely that they would also contribute to better achievement of other aspects of the Good Environmental Status that was to be achieved in European waters back in 2020, according to the Marine Strategy Framework Directive.
• The Commission should request that ICES provides headline advice consistent with the regulations, and propose lower catch levels needed to achieve fisheries and environmental targets.

The full submission

An overriding objective of fisheries policy should be to avoid collapses of important stocks. All other objectives are dependent on that. This objective might be said to be implicit in EU fisheries policy. But it is unstated and there is little discussion of the risks involved in different policy alternatives.

This has practical importance. A number of fish stocks, previously important for commercial fisheries in the Baltic have effectively collapsed.[1] (See attached Annex for references.)

The stock objective in the CFP and MAP – restoring and maintaining stocks at levels capable of producing the maximum sustainable yield – can be seen as a tool to avoid stock collapse. This tool is needed as there are major model and observational uncertainties. These uncertainties include i.a. assessments of Fmsy, F, recruitment and sometimes landing volumes, leading to spurious estimates of SSB. ICES has not presented these uncertainties and risks clearly enough.

In its proposal for Baltic catch limits for 2027, the Commission chronicles a number of ICES assessments and forecasts that in retrospect have been shown to be overly optimistic. This has contributed to decline or collapse of stocks managed on the basis of those assessments and forecasts. Academic research has also identified serious weaknesses in basing fisheries management on a type of MSY-approach that seeks to maximize short term catches at levels thought to be sustainable as well as structural risks in the ICES approach [2], [3], [4].

The stock objective is also reflected in the criteria for Good Environmental Status that was to have been achieved by 2020 under the MSFD.

Despite the importance of the stock objective, the Commission has downplayed it. For example, the Commission does not provide clear information on the of achievement of this objective in the Communication or the accompanying Staff Working Document. The Commission does not request ICES to provide explicit information, in the headline advice, on catch levels or other measures forecast to achieve the MSYBtrigger in the coming year. The Commission does not appear to have requested that STECF explicitly assess achievement of the stock objective in the report forming the basis for the Communication.

The Council for its part has largely ignored the stock objective in setting Baltic TACs. The recent Council decision to increase the TAC for the Gulf of Bothnia herring was a step in the opposite direction.[6] It also risks creating unused quotas that, through CAP Art. 15.9 interannual flexibility, can undermine future TAC decisions. The 2025 fisheries agreement between the EU, the UK and Norway provides that inter-annual flexibility will not be applied for stocks below Bpa.[7] Non-use of interannual flexibility can help stocks recover and should also not be used for Baltic stocks below MSYBtrigger. [8]

The Commission should request that ICES headline advice is in line with the legislation, including art. 3.1, 3.3, 4.6 and 5 in the MAP. It should propose TACs that are consistent with at least a 50% probability of achieving SSB > MSYBtrigger the next year where this is possible. This is also in line with a recent report from the EEA which suggested that ”MSFD ‘good environmental status’ (GES) serves as the single, outcome-driven, enforceable EU boundary for sustainable marine use.” [5] Alternatively, a group of scientists have recently proposed that when stocks fall below Btrigger, catch limits should be set at 50% of Fmsy. [9]

Intensive fishing can also depress fish stocks through environmental effects such as impacts on biodiversity (including the population structure of target fish), the food-web, on sea-floor habitats or the age- and size distribution. These are all descriptors of good environmental status under the MSFD – and they are all ignored in ICES forecasts of potentially sustainable catch levels. The Commission should include an environmental discount of ICES forecasts in its TAC proposals.

REFERENCES:

1. Charles Berkow, Stockholm University Baltic Sea Centre, A new objective for fisheries management: avoid stock collapses? 9 Jun 2026.
2. Graham J. Edgar et al. Stock assessment models overstate sustainability of the world’s fisheries.Science385,860-865(2024).
3. Rainer Froese et al., Systemic failure of European fisheries management.Science388,826-828(2025)
4. Winker, H., Cardinale, M., Gerritsen, H., Herrera, J.G., Castellanos, P., Farias, I., Sampedro, P., Moura, T., Mosqueira, I., Kell, L., 2025. The ICES MSY approach to reference point estimation is not precautionary.europe ICES J. Mar. Sci. 82, fsaf204.
5. Jesper Andersen et al. ETC BE Report 2026/3: Marine Messages III. State, pressures, and choices for the future, 17 Jul 2026.
6. Henrik Hamrén, Stockholm University Baltic Sea Centre, Strömmingskvoten I Bottniska viken höjs med 15 000 ton, 24 Aug 2026.
7. Scottish Government, Marine Directorate, Publication – Agreement European Union, Norway and the United Kingdom – fisheries consultations: agreed records 2025, 6 Dec 2026.
8. Paul S. Kemp, Freya I. Palmer, Noa Steiner, Philippa Grundy, Sarah Coulthard, Lessons in marine fisheries resource management: Anatomy of the Celtic Seas and English Channel pollack fisheries closure, Marine Policy, Volume 191, 2026, 107148, ISSN 0308-597X.
9. Touloumis K, Tsikliras AC and Dimarchopoulou D (2026) Revisiting rebuilding options of European fisheries. Front. Mar. Sci. 13:1685780.