COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council Second report on the implementation of the Multiannual Plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting those stocks, and on the delegation of powers conferred to the Commission by this Mutliannual Plan
Date: 2024-09-04
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: Baltic Sea, European Commission, catch by species, catch quota, conservation of fish stocks, fishing area, fishing regulations, sea fish, sea fishing, transfer of competence

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.9.2024  SWD(2024) 703 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document  Report from the Commission to the European Parliament and the Council Second report on the implementation of the Multiannual Plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting those stocks, and on the delegation of powers conferred to the Commission by this Mutliannual Plan {COM(2024) 703 final}  
 
 
This  staff working document provides:  (i) more  details  about  certain  chapters of the  second 
report1 on the implementation of the multiannual plan for the Baltic Sea (the ‘MAP’)2; (ii) some 
information about control-related aspects; and (iii) the detailed replies given in the stakeholder 
consultation. Like the second report itself, this document focuses on developments since 2020, 
and therefore does not repeat general information set out in the first report or the staff working 
document accompanying that first report3.  

Contents 

1.  Total allowable catch (TAC) setting ................................................................................... 2 

2.  Landing obligation .............................................................................................................. 2 

3.  Ecosystem-based approach ................................................................................................. 2 

4.  Socio-economic developments ........................................................................................... 3 

5.  Delegation of powers to the Commission ........................................................................... 4 

6.  Control and enforcement ..................................................................................................... 5 

7.  Stakeholder consultation ..................................................................................................... 7 

7.1.  Baltic Sea Advisory Council ............................................................................................... 8 

7.2.  Estonia ............................................................................................................................... 17 

7.3.  Latvia ................................................................................................................................ 24 

7.4.  Poland ............................................................................................................................... 29 

7.5.  BalticWaters ...................................................................................................................... 35 

7.6.  Darłowska Grupa Producentów Ryb i Armatorów Łodzi Rybackich............................... 41 

7.7.  Fischereischutzverband Schleswig-Holstein..................................................................... 46 

7.8.  Low Impact Fishers of Europe (LIFE) .............................................................................. 52 

7.9.  Swedish Pelagic Federation PO ........................................................................................ 58 

7.10.  WWF – World Wide Fund For Nature, The Baltic Sea Programme ......................... 63 

ANNEX ...................................................................................................................................... 70 

1  
2  

3  

COM(2024) 703 
Regulation (EU) 2016/1139 of the European Parliament and of the Council of 6 July 2016 establishing a 
multiannual plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting 
those stocks (OJ L 191, 15.7.2016, p. 1). 
COM(2020) 494 final, and SWD(2020) 171 final, both of 14.9.2020. 

1 

 
 
 
 
 
 
 
1.  Total allowable catch (TAC) setting 

General  information  about  the  Baltic  Sea  fisheries  and  the  rules  of  the  MAP  governing  the 
setting of TACs were presented in detail in the staff working document accompanying the first 
report.  

The landings in the Baltic stemming from stocks covered by the MAP and  for which TACs 
were set at FMSY have reached almost 100% of total landings since 2022. This is because all 
stocks  except  eastern  cod  (and  western  cod  for  2024)  receive  a  maximum  sustainable  yield 
(MSY) assessment and TACs for these stocks are set in-line with FMSY, except in the case of 
western  herring,  the  targeted  fisheries  for  which  are  closed.  However,  the  annual  aggregate 
tonnage corresponding to fishing at the FMSY point value has continued to continuously decrease 
since 2017 from above 700 000 tonnes down to less than 500 000 tonnes for 2020 and less than 
350 000 tonnes for 2024. Details are provided in the Annex. This is due to: (i) the closure of 
the targeted fisheries for both cod stocks, western herring and partly main basin salmon; and 
(ii)  decreasing  stock  trends  and  hence  TACs  for  Bothnian  and  central  Baltic  herring.  The 
objective is to rebuild all Baltic fish stocks to healthy biomass levels. 

2.  Landing obligation 

There have not been many developments during the reporting period (2020-2023/2024). In its 
latest annual stock advice, ICES estimated discard rates in 2022 of 5% for eastern Baltic cod, 
around 23% for western Baltic cod, 36-45% for plaice, and 9-19% for flounder depending on 
the area.4 However, ICES indicates that the sampling level has become very low, notably for 
eastern Baltic cod (which is mostly caught by Russia, and Russia has not reported data since 
2022) but also for certain flatfish species. On plaice, ICES had previously indicated that, under 
certain circumstances, discards could account for up to 100% of a vessel’s catch.5 It should be 
noted  that  during  the  reporting  period  flatfish  has  become  the  target  species  in  demersal 
fisheries as it is no longer permitted to target cod.  

3.  Ecosystem-based approach 

As set out in the staff working document accompanying the first report, the Convention on the 
Protection  of  the  Marine  Environment  of  the  Baltic  Sea  Area  (‘Helcom’)  supports  the  EU 
Member  States  in  implementing  the  Marine  Strategy  Framework  Directive  2008/56/EC 
(MSFD). 6 Helcom updated its Baltic Sea action plan in 20217 which continues to pay special 
attention to eutrophication, biodiversity, hazardous substances and marine activities. 

4  

5  
6  

7  

ICES Advice 2024 – cod.27.22-24; cod.27.24-32; ple.27.21-23; ple.27.24-32; fle.27.2223; bzq.27.2425; 
bwp.27.2729-32; all of 31 May 2024. 
ICES Advice 2018 – ple.27.24-32 of 31 May 2018. 
Directive  2008/56/EC  of  the  European  Parliament  and  of  the  Council  of  17  June  2008 establishing  a 
framework for community action in the field of marine environmental policy (OJ 164, 25.6.2008, p. 19). 
https://helcom.fi/baltic-sea-action-plan/. 

2 

 
 
 
Article  3(3)  of  the  MAP  provides  that  the  MAP  aims  to  ensure  that  the  conditions  of  the 
MSFD’s descriptor 3 of good environmental status are fulfilled. Descriptor 3 is directly linked 
to the TAC (and hence to the MAP).  

As mentioned in the second report, ICES continues to be able to assess only 2 of the 3 criteria 
of descriptor 3 (fishing pressure and biomass, but not age-size distribution). In its latest advice8, 
ICES estimated that in 2022 Gulf of Riga herring and Bothnian herring were the only target 
stocks under the MAP fulfilling the two assessed criteria of descriptor 3; western Baltic herring 
fulfilled the fishing pressure criterion, and sprat the biomass criterion. On the by-catch stocks 
under the MAP,  the situation was  that: (i)  plaice in  areas  21-23  and  24-32 fulfilled  the two 
criteria; (ii) the status of brill and turbot was unknown; (iii) 3 out of 4 flounder stocks fulfilled 
the fishing pressure criterion while the biomass criterion was unknown.  

Article 3(3) of the MAP also provides that the MAP aims to contribute to the fulfilment of other 
relevant  descriptors  in  proportion  to  the  relative  role  played  by  fisheries  in  affecting  these 
descriptors. On descriptor 6 (sea floor integrity), it is to be noted that the Commission’s marine 
action plan presents actions to reduce the impact of fisheries.9 ICES does not assess in detail 
the status of these other descriptors, but it still provides qualitative indications that go some 
way to show the general status of the descriptor. The staff working document accompanying 
the first report also contains some discussions of these other descriptors and of the impact that 
the ecosystem has on the fish stocks. These considerations are still valid. 

4.  Socio-economic developments 

According to the latest Annual Economic Report of the Commission’s Scientific, Technical and 
Economic  Committee  for  Fisheries  (STECF)10,  in  2021  the  Baltic  fleet  overall  generated 
EUR 30 million in gross profits, a 33% decrease compared to 2020. Net profits fell even more, 
decreasing by 42% to EUR 6 million. The fleets of Denmark and Germany suffered net financial 
losses  in  2021.  However,  the  net  profit  of  the  Polish  fleet  improved  substantially,  mainly 
because of the improved profitability of the small-scale fleet. Revenue (income from landings 
and other income) generated in 2021 across the whole Baltic fleet was estimated at EUR 173 
million, a decrease of 12% from the previous year. Three Member States accounted for over 
60% of all revenues: Sweden and Finland (EUR 37 million each), and Poland (EUR 35 million). 

The total number of days at sea has been continuously decreasing. In 2021, days at sea were 
only 75% of the 2013-2020 average. The total number of vessels decreased by 26% between 
2013  and  2021.  In  2021,  small-scale  coastal  fisheries  were  responsible  for  62%  of  total 
employment in the Baltic fishing fleet. Nevertheless, the large-scale fleet  has been the main 
actor in the region and has been responsible for the majority of the landed weight and landing 
value. Landings from the Baltic increased slightly from 2013 to 2018. However, from 2019 to 

8  

9  

10  

ICES  Advice  2022  –  Baltic  Sea  Ecoregion  Fisheries  Overview,  version  2  of  6  February  2023,  p.  31 
(https://doi.org/10.17895/ices.advice.21646934). 
COM(2023) 102 final of 21.2.2023, Communication from the Commission ‘EU Action Plan: Protecting 
and restoring marine ecosystems for sustainable and resilient fisheries’. 
STECF 23-07, Annual Economic Report of the EU Fishing Fleet, pp. 103-115. 

3 

 
 
 
2021 the weight of landings decreased by 7%. The value of landings decreased significantly in 
2014 (due to a drop in prices for small pelagic species) and, after a slight recovery in 2015, has 
been continuously falling. In 2021, the value of landings decreased by a further 14% compared 
with 2020. 

Gross value added in 2021 was estimated at over EUR 88 million, gross profit at EUR 29.4 
million and net profit at EUR 6.3 million. Overall, the gross profit margin in the region fell 
from  23%  in  2016  to  19%  in  2021,  with  the  Latvian  fleet  the  most  profitable  (30%  profit 
margin), followed by Sweden (18%) and Estonia (17%). Fuel costs continue to be one of the 
main drivers of the Baltic fleet’s performance. In 2021, fuel consumed per landed weight of 
seafood, was 7% lower than in 2020 and 14% lower than the 2013-2020 average, indicating an 
improvement in energy efficiency of the Baltic Sea fleet. 

Total employment in the Baltic Sea fishing fleet amounted to 3 301 full-time equivalents (FTEs) 
in 2021, a 10% reduction compared to 2020. The total number of vessels operating in the Baltic 
Sea fell by 26% between 2013 and 2021. 

Finally, it should be mentioned that the former European Maritime and Fisheries Fund (EMFF) 
and  current  European  Maritime,  Fisheries  and  Aquaculture  Fund  (EMFAF)  Regulations11 
support the CFP objectives, and therefore also support the implementation of the MAP. In this 
context, Member States use funds from the EMFF and EMFAF to support fisheries control and 
enforcement activities. Some Member States also use these two funds to help: (i) reduce fishing 
capacity; (ii) develop more selective fisheries; and (iii) mitigate the socio-economic impact on 
fishers of specific conservation measures. Based on Member States’ reporting, the Commission 
provides annual reports on the implementation of these two funds12. 

5.  Delegation of powers to the Commission 

As set out in the staff working document accompanying the first report, an exemption from the 
landing obligation based on Article 7 of the MAP was adopted in 2017 by way of a delegated 
act based on a joint recommendation for cod and plaice caught with certain passive gears13. The 
relevant  Member  States  had  to  provide  information  by  March  2019  about  discard-survival 
estimates  to  allow  both  the  STECF  to  evaluate  this  exemption  by  August  2019  and  the 
Commission to evaluate the exemption in the course of 2020. The Commission asked to receive 
information on discard-survival estimates in February 2020 and again in March 2024, but so 

11  

12  

13  

Regulation  (EU)  508/2014  of  the  European  Parliament  and  of  the  Council  of  15  May  2014  on  the 
European Maritime and Fisheries Fund and repealing Council Regulations (EC) No 2328/2003, (EC) No 
861/2006,  (EC)  No  1198/2006  and  (EC)  No  791/2007  and  Regulation  (EU)  No  1255/2011  of  the 
European Parliament and of the Council (OJ L 149, 20.5.2014, p. 1); Regulation (EU) 2021/1139 of the 
European Parliament and of the Council of 7 July 2021 establishing the European Maritime, Fisheries 
and Aquaculture Fund and amending Regulation (EU) 2017/1004 (OJ L 247, 13.7.2021, p. 1). 
For  the  latest  reports,  see  https://oceans-and-fisheries.ec.europa.eu/publications/emff-implementation-
report-2022_en 
https://oceans-and-fisheries.ec.europa.eu/publications/famenet-emfaf-
implementation-report-june-2023_en. 
Commission Delegated Regulation (EU) 2018/306 of 18 December 2017 laying down specifications for 
the implementation of the landing obligation as regards cod and plaice in Baltic Sea fisheries (OJ L 60, 
2.3.2018, p. 1). 

and 

4 

 
 
 
far  the  Member  States  have  not  yet  provided  any  information.  Furthermore,  a  joint 
recommendation  for  a  high-survivability  exemption  from  the  landing  obligation  for  plaice 
caught with other types of gears had been submitted to the Commission in 2019 but received a 
negative STECF assessment. A second joint recommendation was submitted in April 2022 but 
was also negatively assessed by the STECF14 so the Commission did not adopt a delegated act. 

As set out in the staff working document accompanying the first report, based on Article 8 of 
the MAP and a joint recommendation, a delegated act was adopted in 2017 allowing fishing 
operators to use a T90 codend with a smaller mesh-size in the targeted demersal cod fisheries.15 
It was subsequently discovered that this delegated act contained a technical error which made 
it impossible to build that gear according to the technical specifications set out in the delegated 
act,  meaning  that  the  alternative  gear  could  not  be  built  and  used  in  practice.  A  joint 
recommendation  to  correct  this  mistake  was  adopted  in  2019  and  the  STECF  assessment16 
confirmed the error in the original delegated act. However, given the closure of the targeted 
eastern cod fisheries and the new need to develop gears which substantially reduce cod catches 
in demersal fisheries rather than increase them, the Commission decided in 2020 not to correct 
the  delegated  act  and  hence  to  keep  it  unusable  in  practice.  Finally,  based  on  a  joint 
recommendation  from  2021,  the  Commission  still  plans  to  adopt  in  2024  delegated  and 
implementing legislation which in the main cod-distribution area will make it mandatory to use 
gears and devices in demersal fisheries that are expected to substantially reduce by-catches of 
cod. However, it should be noted that the legal basis for this legislation will be the Technical 
Measures Regulation (EU) 2019/124117, not the Baltic MAP. 

6.  Control and enforcement 

As set out in the staff working document accompanying the first report, the MAP contains a 
few specific provisions on control and enforcement in addition to the general provisions under 
EU rules including the Fisheries Control Regulation. In particular, the MAP contains a more 
lenient  rule  for  the  margin  of  tolerance  (MoT)  for  unsorted  landings,  namely  10%  of  total 
catches instead of 10% per species. The recent revision of the Control Regulation18 modified 
the  MoT  rule  in  the  MAP  to  gradually  align  it  to  the  baseline  MoT  rules  in  the  Control 

14  
15  

16  
17  

18  

STECF EWG 22-05, item 8.1, pp. 165-169. 
Commission Delegated Regulation (EU) 2018/47 of 30 October 2017 authorising the use of alternative 
T90 trawls in the Baltic Sea fisheries (OJ L 7, 21.1.2018, p. 21). 
STECF 60th plenary meeting report (PLEN-19-01), item 6.12, pp. 142-148.  
Regulation  (EU)  2019/1241  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  the 
conservation of fisheries resources and the protection of marine ecosystems through technical measures, 
amending  Council  Regulations  (EC)  No  1967/2006,  (EC)  No  1224/2009  and  Regulations  (EU)  No 
1380/2013,  (EU)  2016/1139,  (EU)  2018/973,  (EU)  2019/472  and  (EU)  2019/1022  of  the  European 
Parliament and of the Council, and repealing Council Regulations (EC) No 894/97, (EC) No 850/98, (EC) 
No 2549/2000, (EC) No 254/2002, (EC) No 812/2004 and (EC) No 2187/2005 (OJ L 198, 25.7.2019, p. 
105). 
Regulation  (EU)  2023/2842  of  the  European  Parliament  and  of  the  Council  of  22  November  2023 
amending  Council  Regulation  (EC)  No  1224/2009,  and  amending  Council  Regulations  (EC)  No 
1967/2006  and  (EC)  No  1005/2008  and  Regulations  (EU)  2016/1139,  (EU)  2017/2403  and  (EU) 
2019/473 of the European Parliament and of the Council as regards fisheries control (OJ L, 2023/2842, 
20.12.2023).  

5 

 
 
 
Regulation:  the  MoT  rule  in  the  MAP  will  be  20%  per  species  until  10 January 2028,  and 
thereafter the baseline MoT rules will apply. 

The membership of the Baltic Sea Advisory Council (BSAC) is split. Some members are of the 
opinion that the MoT rule has allowed significant misreporting in mixed pelagic fisheries and 
that  this  has  had  negative  consequences  for  some  fish  stocks.  Other  members  of  the  BSAC 
disagree.  Some  members  argue  that  the  new  MoT  rules  are  too  restrictive  and  cannot  be 
implemented. The Member States responding to the consultation are divided, as two think that 
the MoT rule has not had – nor will have – many effects on fish stocks, while one is of the view 
that the effects of the MoT rule will be significant. One Member State stresses that the new 
MoT rules are likely to be difficult to implement in some fisheries.  

Following suspicions over inadequate weighing and catch-registration practices in Baltic Sea 
Member States, the Commission services conducted a verification series from 2021 to 2024 in 
Baltic  Sea  Member  States,  focusing  on  unsorted  pelagic  species  intended  for  human 
consumption and industrial purposes. To date, these verifications (covering all but one Member 
State) unveiled deficiencies in certain Member States in the region. These deficiencies include: 
(i) inadequate procedures and systems for weighing catches; (ii) misreporting of species and 
quantities;  (iii)  deficiencies  in  data  cross-checking  mechanisms;  and  (iv)  weaknesses  in 
inspection and enforcement, including the imposition of sanctions.  

These  findings,  against  the  background  of  the  derogation  from  the  MoT  rule  for  unsorted 
pelagic  landings,  indicate  that  there  has  been  substantial  misreporting  of  sprat  and  herring 
landings. This misreporting might weaken the accuracy and reliability of  the assessments of 
these stocks and contribute to overfishing. 

It  is  worth  noting  that  all  issues  mentioned  above  were  already  raised  previously  on  many 
occasions, including in the public consultation on the evaluation of the Control Regulation.19 
However, the discussions held in this context also highlighted the need to address these issues 
at  EU  level  rather  than  at  regional  level  in  order  to  avoid  distorting  competition.20  The 
Commission proposal for the revision of the fishery control system21 took this into account. 

To address these critical issues, the revised Control Regulation introduces a range of measures 
to:  (i)  improve  fisheries  control  and  enforcement;  and  (ii)  tighten  the  rules  to  make  more 
operators  weigh  unsorted  catches.  These  measures  include:  (i)  the  harmonisation  of  serious 
infringements; (ii) the standardisation of sampling and control plans; and (iii) the modification 
and gradual phasing out of the lenient MoT rule set by the MAP. Some rules will enter into 
force gradually between now and 2028. However, the basic principles behind catch registration 
and weighing remain the same in the revised Control Regulation.  

19  
20  
21  

COM(2017) 192 final of 24 April 2017. 
SWD(2018) 280 final of 30 May 2018. 
COM(2018) 368 final of 30 May 2018. 

6 

 
 
 
 
7.  Stakeholder consultation 

As  they  did  when  preparing  the  first  report,  the  Commission  services  undertook  a  targeted 
stakeholder  consultation  when  preparing  this  second  report.  The  targeted  stakeholder 
consultation was based on a questionnaire. The main consulted stakeholders were the BSAC, 
the Baltic Sea Member States group (‘BaltFish’), and their respective members.  

This  staff  working  document  reproduces  the  content  of  the  replies  as  received  by  the 
Commission  services.  Questions  1  to  5  of  the  questionnaire  refer  to  the  identity  of  the 
respondent and are therefore not reproduced in this document. After extending the deadline for 
reply, neither BaltFish nor 5 out of the 8 consulted Member States had replied. The replies of 
the BSAC are reproduced first. This is followed by the replies of the Member States, which are 
in turn followed by the replies of the other organisations in alphabetical order.  

7.1. Baltic Sea Advisory Council 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

In the BSAC’s opinion, the MAP has not contributed to increasing the number of TACs set at 
MSY and has not helped in dealing with difficult cases such as the eastern and western Baltic 

7 

 
 
 
cod stocks, western herring and that the provisions in the MAP have in some cases been counter-
productive.  

In the BSAC’s opinion, the unsuccessful rebuilding of the Baltic cod stocks exemplifies the 
ineffective framework provided for by the MAP.. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and  implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  

8 

 
 
• 

No opinion 

Q13: Free text 

The BSAC is of the opinion that the implementation of the Landing Obligation has not been 
fully successful. The BSAC is eagerly waiting for a report from EFCA on the implementation 
of the LO in the Baltic Sea in 2019-2021.  

Some BSAC members highlight that the control of discards has not been properly implemented.  

The BSAC is of the opinion that the MAP has not contributed to achieving the implementation 
of  the  Landing  Obligation.  For  example,  it  has  not  provided  enough  help  in  terms  of  the 
developments of alternative gears or facilitating the removal of gears that do not work. Some 
of the provisions of the MAP have even been counterproductive in the implementation of the 
Landing Obligation, for instance the specific measures for flatfish, which have encouraged bad 
practices in the fishery.  

In the opinion of the BSAC, the MAP should be revised in order for it to be more adaptative. 
There is a need to adapt fishing mortality to spatial distribution/abundance and interactions with 
other species. 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

9 

 
 
Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

The BSAC is of the opinion that the MAP has actually been counterproductive in implementing 
an ecosystem-based approach to fisheries, whereby environmental factors and interactions are 
to become a more integral part of managing the fisheries. Moreover, the MAP does not take 
into consideration the importance of species interactions and age structure of the stock.  

This should include the impact of interdependency between fish species and also account for 
the role of non-fish species predators such as seals and cormorants on the fish stocks, including 
diseases transmitted by these predators.  

Some  BSAC  members  are  of  the  opinion  that  the  MAP  has  failed  to  facilitate  the 
implementation of MSFD (descriptor 3).  

In the opinion of the BSAC, the MAP should be revised in order for it to be more adaptative to 
take account of the changing environmental conditions  

The BSAC is of the opinion that current reference points (fishing mortality) should be revised 
to take account of e.g. decreasing trend in stock status, unfavorable changes in age and size 
distribution, negative impact on the status of other species or disruptions in food web or other 
environmental conditions that will likely decrease productivity of the stocks. There is a need to 
adapt fishing mortality to spatial distribution /abundance and interactions with other species.  

Setting TAC at MSY should not be per se an objective. The MAP and the technical measures 
should  be  revised  to  take  account  of  the  changes  in  the  state  of  the  fish  stocks  and  the 
environment.  

The MAP has no crisis mechanism to deal with unexpected developments of the ecosystem. 
Under the current unexpected developments of stocks, TAC and quotas and socio-economic 
impacts are not well dealt with by the existing MAP. For example, on the ecosystem aspect, we 
clearly  see  in  the  Baltic  that  the  predators  have  to  be  taken  into  account  if  we  talk  about 
“ecosystem based management”. Concretely, we need more active management of predators if 
we want to make full use of the potential value of the Baltic Sea for European food security. 

Some  BSAC  members  highlight  that  the  MAP  should  better  adapt  the  fishing  effort  to  the 
reproductive capacity of the fish stocks. In particular, the lack of selectivity of trawl fishing 
gear needs to be addressed in order minimize bycatch.  

10 

 
 
Other BSAC members highlight that further effort reduction does not have significant impact 
of the reproductive capacity of the fish stocks. So far, considerable effort reduction has deprived 
the fishing communities of work and income, without any positive impact on the fish stocks. 
Therefore, the reasons behind the current state of resources should be sought elsewhere, and 
may include predators or change in the stock structure as a result of excessive selectivity. 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Some BSAC members point that there have been significant volumes of catch misreported in 
the  mixed  sprat  /herring  fishery.  The  Margin  of  Tolerance  has  provided  an  incentive  to 
misreport  catches.  This  has  resulted  in  poor  quality  catch  data  being  submitted  to  stock 
assessors  and  has  contributed  to  the  poor  status  of  the  central  Baltic  herring.  ICES  have 
highlighted  the  impact  of  catch  misreporting  in  these  fisheries  in  the  stock  assessments  and 
working group report for a number of years.  

Some BSAC members point that regarding the problem of compliance with the rules concerning 
the  margin  of  tolerance  (MOT)  in  the  case  of  fishing  vessels  retaining  unsorted  catches,  in 
particular kept on board in refrigerated tanks. Such vessels are adapted to keep fish in the above 
tanks and transport the catch from the fishing gear to the hold by means of a non-contact pump 
system. Shipowners have retrofitted their boats with such systems to comply with the so-called 
'discard ban'. It is impossible for the skipper on such a vessel to estimate the species composition 

11 

 
 
with such a high degree of accuracy. With a catch of several tens of tonnes, a 20% MOT for 
non-target species is unfeasible.  

Example: the catch is 20 tonnes in which the skipper estimates that there are about 200kg of 
non-target species. In port after landing, the result shows that he made a mistake and there is 
not 200kg of non-target but 300kg. He has exceeded the MOT under the new regulation. He 
was  wrong  by  several  tens  of  kilograms  in  a  weight  of  several  tens  of  thousands.  Such  a 
restrictive  regulation  will  lead  to  massive  violations  and  an  avalanche  of  administrative 
proceedings and penalties, not because not because the skipper or crew is unwilling or wilfully 
breaks a rule, but because of a rule that is impossible to enforce. The fishing sector questions 
such unrealistic regulations, impossible for some segments of the fleet  to comply with.  The 
representatives  of  the  fishing  sector  are  of  the  opinion  that  the  creation  of  such  regulations 
shows  incredible  incompetence.  Some  see  it  as  a  deliberate  act  to  eliminate  the  last  group 
operating  on  the  available  raw  material  and  supplying  it  in  quality  for  direct  human 
consumption,  as  a  supplier  of  raw  material  to  fish  processing  plants  and  a  link  in  the  food 
security chain.  

Other BSAC members point out that if controls  are implemented that lead to more accurate 
catch data the recently adopted changes to the MOT have a positive impact. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

The  BSAC  is  of  the  opinion  that  the  MAP  has  not  facilitated  regional  cooperation  and  its 
functioning  is  not  helped  by  regional  cooperation.  The  BSAC  underlines  that  the  regional 

12 

 
 
process of the implementation of the MAP will not work unless there are sufficient resources 
onboard.  

Predator management and the impact on natural mortality for certain fish species is an example 
where the MAP has not triggered improved regional cooperation where one would have hoped. 
Some BSAC members highlight that there is intensive cooperation between stakeholders in the 
form of a lively exchange of arguments. Unfortunately, in most cases no common solution is 
found  because  the  interests  regarding  the  management  of  fish  stocks  are  too  diverse.  For 
example, semi-industrial trawling is geared towards mass catches, while small-scale fishing is 
geared towards quality. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

13 

 
 
Some BSAC members put forward that the small-scale coastal fleet is more dependent on larger 
stocks with larger individuals, but the implementation of the MAP fails to deliver this, thereby 
having a significant socio-economic effect on the industry.  

Other BSAC members remind that it is not a specific segment but the entire fisheries that are 
dependent on large stocks.  

The MAP  tries to  fish all  species at  their maximum sustainable yield simultaneously on the 
basis  of  single  stock  assessments.  This  was  criticized  by  the  BSAC  members  at  several 
occasions. Achieving the MSY objective for every single species at the same time, taking into 
account the species dependency such as between sprat and cod, is impossible and has negative 
socio-economic impact.  

For some BSAC members, the implementation of the MAP therefore necessarily favours fishers 
catching lower trophic level species.  

Some BSAC members highlight that the MAP fails to account for there to be sufficient prey 
availability  for  predator  species,  thereby  causing  repressed  biomass  growth  amongst  certain 
species that some fleet segments are more dependent on.  

Other BSAC members highlight that, taking into consideration the diet scheme e.g in cod diet 
is 20-40% of clupeide, there is enough of food for the predator species. The problem comes 
from the size/age structure which results from the management approach, which makes some 
species like cod unable to hunt effectively. The fact that MAP does not include real age/size 
structure and species dependency diverges from  the assumed goals, so this fact has also big 
correlation with socio-economic development. 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

In the opinion of the BSAC fisheries representatives, the MAP should include socio-economic 
considerations. It should be more of a fisheries management plan and focus on socioeconomic 
and less on conservation and MSY targets.  

The  BSAC  is  of  the  opinion  that  the  MAP  should  more  specifically  address  western  spring 
spawning  herring.  The  MAP  has  not  been  accepted  by  Norway,  a  key  coastal  state  for  the 
management of the stock. Thus, ICES does not provide scientific advice based on the MAP. 

In addition, the BSAC has published a reply to the European Commission’s open feedback on 
the proposed changes to the Baltic Multiannual Plan (Article 4.6, ie the 5% rule) in January 
2024 .  

The  BSAC  highlight  the  need  for  sustainable  management  of  fish  stocks  through  proper 
approach to selectivity of fishing gears.  

14 

 
 
Some BSAC members highlight the need improving selectivity in trawl fishing and call for an 
end to the permanent subsidization of uneconomical fishing operations. 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

The BSAC is of the opinion  that there is  value in having  a Multiannual Plan for the Baltic. 
However,  the  MAP  has  not  lived  up  to  its  expectations  and  has  not  delivered  the  expected 
results during 6 years of its implementation.  

In the opinion of the BSAC, the MAP should be revised to include specific major changes. 

7.2. Estonia 

Member of the 'BaltFish' Member States group 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 

Significantly  
A little 

15 

 
 
 
• 
• 
• 
• 

Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

SSBmsy is a problem, at the beginning of the implementation of the Regulation the situation 
with pelagic stocks was good and it seemed that MAP played its role well, i.a justified itself. 
Now  situation  is  changed,  all  herring  stocks  with  one  exception  and  cod  stocks  are  below 
SSBmsy  level.  So,  it  seems  some  environmental  elements  are  not  considered  when  MSY 
approach is applied. It is difficult to give final assessment as also  ICES does not have clear 
picture  on  the  reasons  behind  herring  stocks.  However,  interspecies  relations  should  be 
considered more flexibly when TACs are set. It is not applied at all due to lack of relevant ICES 
recommendation. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  

16 

 
 
• 

No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

Our fleet targets pelagic stocks, discard of pelagic stocks is marginal and therefore the impact 
of the discard to pelagic stocks is marginal as well. As regards the groundfish species like cod 
and flatfish, there is discard issue recognised. However, the impact of the discard to plaice stock 
is small as the stock is in good shape. As regards the impact of the discard to the cod stocks, as 
the stock is in very bad condition, therefore every activity which increases mortality (including 
discard) has negative effect to the cod stocks. 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

17 

 
 
Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

Apparently changes in ecosystem have taken place in the Baltic sea which affects negatively 
Baltic sea stocks (predators - seals, birds; eutrophication; changes in abiotic indicators; non-
indigenous/alien species). MAP objective foresees, article 3 point 3: "The plan shall implement 
the ecosystem-based approach to fisheries management in order to ensure that negative impacts 
of fishing activities on the marine ecosystem are minimised". MAP can not do much in terms 
of  ecosystem  consideration  to  fish  stocks,  but  at  least  interspecies  connections  should  be 
possible to consider, e.g mixed fisheries of sprat and herring. Sprat is doing better and is more 
resilient to ecosystem changes (temperature changes etc), adapts better, but stocks compete over 
the food chain. Big sprat stock dominates over herring stocks and further impacts herring stocks 
negatively. When TACs are set these considerations should be considered. In the future MAP 
could  foresee  also  limitation  of  predators  which  significantly  affects  fish  stocks  (Great 
cormorant, grey seal etc). 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  

18 

 
 
• 
• 

Counterproductive  
No opinion 

Q20: Free text  

We do not feel that MOT changes have had significant effects on Baltic sea stock, new general 
rule - 10% MOT to each specie makes life for fishers very difficult. It is doable when in mixed 
fisheries herring or sprat portion is over 20%, less than that creates problem. When some specie 
represents less than 10% or 2 % (as the departure point in the amendment of control regulation) 
the 10% MOT is clearly to restrictive. Therefore the solution (10% MOT from all quantities) 
for listed ports is important for our sector. So, the measures which will apply in listed ports 
should be reasonable and doable also when fish is landed/caught for human consumption, e.g 
water separation is a possible problem- the landings for human consumption always include 
water (keeping fish quality). Also, landings for human consumption is pretty small (20-30 tons) 
comparing to industrial landings, fishing trip lasts less than one day, etc, therefore investments 
for  ports  in  order  to  use  listed  port  derogation  should  be  reasonable,  e.g  requirement  to 
independent weigher is unproportional requirement. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

MAP  has  triggered  regional  cooperation  on  Baltic  sea  TACs  and  quotas,  for  some  years 
BALTfish have been successful and agreed on joint proposal on TACs and quotas. Also, MS 
have moreless same interpretation on different stocks reference points and sustainability levels 
etc. 

19 

 
 
Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

Socio  economic  impact  is  closely  related  to  the  stock  situation,  e.g  directed  fishing  for  cod 
stocks is banned, therefore the fleet is reoriented to finished its activity, main basin; Bothnian 
and  western  herring  socks  have  reduced  significantly  and  clearly  there  is  negative  socio 
economic effect, fleet has reduced accordingly. in the Baltic sea alternative are difficult, at least 
in Northern part, in southern part North sea could give some alternative, but in the North if 
TACs are in a very low level, it means that fishing effort and fleet follows the same trend. 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

20 

 
 
As mentioned above - interspecies influence should be taken into account in mixed fisheries, 
impact of predators should be considered and further activity agreed upon. 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

It gives basis to set derogations for landing obligation (e.g necessary for salmon fishing). MOT 
derogation was set in the MAP regulation, it is important tool. Also it gives good basis to set 
additional remedial measures for the protection of stocks. Etc.  

7.3. Latvia 

Member of the 'BaltFish' Member States group 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  

21 

 
 
 
• 
• 

Counterproductive  
No opinion 

Q8: Free text 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  

22 

 
 
 
• 
• 

Counterproductive  
No opinion 

Q13: Free text 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

Section 4 – Control enforcement  

23 

 
 
 
 
On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  

24 

 
 
 
• 

No opinion 

Q23: Free text  

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

25 

 
 
 
 
 
Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

7.4. Poland 

Member of the 'BaltFish' Member States group 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

26 

 
 
 
 
The MAP is a useful instrument that allows TACs to be set transparently through the rules it 
sets out. However, it does not provide enough flexibility in some cases.. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

27 

 
 
 
Q13: Free text 

The issue of discards is of a horizontal nature, therefore the assessment of the impact of MAP 
on the implementation of the landing obligation should be made jointly for the entire Baltic Sea 
by one institution. 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

28 

 
 
 
 
 
Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Recently adopted changes to the MOT will contribute to more accurate reporting of catches in 
pelagic fisheries. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 

Significantly  
A little 
Not much  

29 

 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q23: Free text  

MAP  provided  a  new  stimulus  for  strengthening  regional  cooperation  within  BALTFISH, 
especially  in  terms  of  setting  TAC's  levels.  An  example  of  this  good  cooperation  was  the 
agreement that BALTFISH reached on fishing opportunities in recent two years. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

30 

 
 
 
 
Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

As mentioned above - interspecies influence should be taken into account in mixed fisheries, 
impact of predators should be considered and further activity agreed upon. 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

MAP is a necessary tool, but at least a discussion on changing it should begin in order to adapt 
the plan's provisions to the current situation of fish stocks in the Baltic Sea. The adoption of the 
plan only in 2016 did not allow it to be fully exploited, which would have been possible had it 
been  adopted  earlier  or  if  the  situation  of  fish  stocks  had  been  better.  The  discussion  on  a 
possible amendment of the MAP should be conducted first of all among fishermen themselves, 
so that the solutions developed by them could contribute to improving their economic situation, 
but also could take into account their practical knowledge. Their proposals should be evaluated 
in order to adopt the best solutions that could improve their situation and could have a positive 
impact on the fish stocks in the Baltic Sea.  

7.5. BalticWaters 

Member of the Baltic Sea Advisory Council, other interest group 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 

Significantly  
A little 
Not much  

31 

 
 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

In theory, the MAP could have improved the situation of stocks in the Baltic Sea. Tha MAP 
itself provide an somewhat clear frameworke and goals. Unfortunately, in practice there is a 
lack of compliance and control of compliance. In our world, stocks would not be in this critical 
state if the CFP, the MAP and the MSFD had been followed.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

32 

 
 
 
Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

Neither herring nor sprat are considered as a by-catch species in the MAP, they are fished in a 
mixed fisheries and misreporting occur. 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 

Significant  
Some 

33 

 
 
 
• 
• 
• 
• 

Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

As already stated, the MAP has potential but in real life it lacks compliance and control. 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

34 

 
 
 
 
 
Q20: Free text  

MOT should not be set higher but rather lower. A correct reporting of Baltic Sea fishstocks is 
highly important for scientific assesments. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

Som  tidigare  nämnts  har  MAP  potential  att  bidra  till  ett  bättre  samarbete,  men  hela  kvot-
processen måste vara transparent i alla steg (ICES, BALTFISH, EU-Commission, Council of 
minister to set qoutas). 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

35 

 
 
Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

Contraproductive because - today, only a few fisheries benefit, and these are the large-scale 
trawlers that fish for fishmeal. Coastal fishermen who fish for human consumption (and food 
safety in our region) do not benefit; their socio-economic impact is and will be much worse 
than  that  of  the  large-scale  fishermen.  But  even  the  socio-economic  impact  of  large-scale 
fishermen will worsen in the long-term when the fish run out. 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

Compliance 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

36 

 
 
 
 
Q30: Free text 

MAP has potential but today there are shortcomings where some of them is adressed above. 

7.6. Darłowska Grupa Producentów Ryb i Armatorów Łodzi Rybackich 

Member of the Baltic Sea Advisory Council, fisheries sector 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

Naszym zdaniem założenia MAP nie były wdrażane i respektowane, w związku z czym nie 
przyniosły oczekiwanych efektów.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 

Significantly  
A little 
Not much  

37 

 
 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and  implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 

Significantly  

38 

 
 
 
• 
• 
• 
• 
• 

A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

Zupełny brak wdrażania założeń MAP 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

39 

 
 
 
Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 

Significantly  

40 

 
 
  
 
• 
• 
• 
• 
• 

A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

41 

 
 
 
 
 
Q30: Free text 

7.7. Fischereischutzverband Schleswig-Holstein 

Member of the Baltic Sea Advisory Council, fisheries sector 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

Die  Berechnung  des  MSY  beruht  auf  falschen  Zahlen,  weil  die  Beifänge  in  der 
Schleppnetzfischerei nicht in die Berechnung eingeflossen sind. Deshalb hat sich, wie man sieht 
der  beabsichtigte  Erfolg  nicht  eingestellt.  Der  Dorsch  und  Heringsbestand  ist  entgegen  der 
Berechnungen teilweise oder ganz zusammengebrochen.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 

Significantly  
A little 

42 

 
 
 
• 
• 
• 
• 

Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

Es macht für die Bestandserhaltung keinen Sinn Rückwürfe zu managen, weil die Fische tot 
und  deshalb  für  die  Reproduktion  in  jedem  Fall  verloren  sind.  Die  Erfahrung  zeigt  darüber 
hinaus, dass die Kontrolle der Rückwürfe bisher nicht erfolgreich umgesetzt werden konnte. 
Die Differenz zwischen gemeldeten Rückwürfen und Seekontrollen stützt diese Feststellung. 

43 

 
 
 
 
 
Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

Indem der Fangaufwand der Reproduktionsfähigkeit der Fischbestände besser angepasst wird. 
Hier ist bei der Selektivität der Fanggeräte in der Schleppnetzfischerei anzusetzen um Beifänge 
besser zu minimieren. 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

44 

 
 
• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Man sucht die Ursachen für die bisher nicht gelungene Bewirtschaftung der Fischbestände nun 
entsprechend  der  Anzahl  der  Fahrzeuge  in  der  Kleinfischerei  mit  passiven  Fanggeräten. 
Aufgrund  des  viel  geringeren  Fangaufwandes  dieser  Fahrzeuggruppe  und  der  hohen 
Selektivität  der  dort  verwendeten  Fanggeräte  wird  auch  die  neue  Kontrollverordnung,  wie 
schon  die  vorangegangene  in  ihrer  Wirkung  weit  hinter  den  in  sie  gesetzten  Erwartungen 
zurückbleiben. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  

45 

 
 
• 

No opinion 

Q23: Free text  

Es  gibt  zwar  eine  intensive  Zusammenarbeit  von  Interessenträgern  in  Form  von  regem 
Austausch  von  Argumenten.  Leider  wird  in  den  meisten  Fällen  kein  gemeinsamer 
Lösungsansatz  gefunden,  weil  die  Interessenlage  hinsichtlich  der  Bewirtschaftung  von 
Fischbeständen zu verschieden sind. So ist z.B. die halbindustrielle Schleppnetzfischerei auf 
Massenfänge ausgerichtet, die Kleinfischerei eher auf Qualität. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

46 

 
 
 
 
 
Q27: free text 

Das bisher im Wesentlichen verfolgte Prinzip " so viel wie möglich" ist gescheitert, weil es die 
Reproduktionsfähigkeit  der  meisten  Fischbestände  übersteigt.  Daraus  folgend  ist  ein 
wirtschaftlich erfolgreicher Betrieb in der Fischerei zur Zeit nicht mehr möglich. 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

Nachhaltige Bewirtschaftung der Fischbestände durch eine Verbesserung der Selektivität in der 
Schleppnetzfischerei.  Beendigung  der  Dauersubventionierung  von  unwirtschaftlichen 
Betrieben. 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

Verbesserungswürdig! 

7.8. Low Impact Fishers of Europe (LIFE) 

Member of the Baltic Sea Advisory Council, fisheries sector 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 

Significantly  
A little 

47 

 
 
 
 
 
• 
• 
• 
• 

Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q8: Free text 

Since the MAP was implemented, total stock biomass for the majority of stocks in the Baltic 
has declined. It is not possible to fish all stocks at the Fmsy point value simultaneously and 
have the resulting SSB for all stocks above Bmsy. Clear problem is that single species Fmsy 
values are derived from  MSYBtrigger. The fact that MSYBtrigger = Bpa is a huge problem 
because we are using depressed biomass levels as the basis for sustainable fishing mortality.  

Only one stock, Gulf of Riga herring, has biomass levels equal to Bmsy = 2Bpa. It is no surprise 
that this is also the only stock which the fishing industry has been able to exploit with high and 
stable quotas.  

Biomass for all other Baltic stocks are too low. In addition, the lack of old and large fish, key 
components  of  successful  MSY  management, 
the 
counterproductive nature of the MAP implementation.  

represent  a  key 

indicator  of 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

48 

 
 
 
Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

There are two separate issues. Firstly, illegal and unreported discards (demersal trawl segment). 
Secondly, misreported and unreported catches (pelagic trawl segment).  

These problems have persisted throughout the implementation of the MAP. They have not been 
successfully mitigated against.  

According to the scientific data, cod catches are negligible. While minor, in certain trawl flatfish 
fisheries unnaccounted for discards represent a significant portion of catches.  

Of far more significance is the unnaccounted for and misreported catches of sprat and herring. 
Huge  volumes  of  catches  are  not  accurately  reported  and  have  increased  the  uncertainty  of 
scientific recommendations. 

49 

 
 
 
Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

As long as the MAP allows for sprat and herring catches to be fished at MSY so that in the 
long-run  their  biomass  levels  are  depleted  to  MSYBtrigger  levels  the  situation  will  remain 
critical for small-scale coastal fishers. The MAP needs to contribute to significant stock biomass 
growth. Without that first step, we will not have an ecosystem that supports fishermen. 

Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

50 

 
 
 
Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

That  the  Baltic  received  a  20%  exemption  level,  double  for  the  rest  of  the  EU,  is  another 
example  of  the  countrerproductive  nature  of  the  legislation.  There  have  been  significant 
problems with the implementation of the Control Regulation throughout the Baltic region. In 
particular, the pelagic trawl fleet segment. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  

51 

 
 
• 
• 

Counterproductive  
No opinion 

Q23: Free text  

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

As outlined above, the MAP has contributed to significant stock decline in the biomass levels 
for Baltic fish stocks. This  is  the  basis for the core socioeconomic problem  that small-scale 
coastal fishers face. 

52 

 
 
 
 
Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

7.9. Swedish Pelagic Federation PO 

Member of the Baltic Sea Advisory Council, fisheries sector 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 

Significantly  
A little 
Not much  

53 

 
 
 
 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q8: Free text 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 

Significant  
Some 
Not much  

54 

 
 
 
• 
• 
• 

None at all  
Counterproductive  
No opinion 

Q13: Free text 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

55 

 
 
 
 
 
Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

18. The MOT is related to how well the skipper can estimate the catch on board, and has no real 
control value as we see it. It also has no impact on stock status. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 

Significantly  

56 

 
 
 
• 
• 
• 
• 
• 

A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

57 

 
 
 
 
 
Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

7.10. 

WWF – World Wide Fund For Nature, The Baltic Sea Programme 

Member of the Baltic Sea Advisory Council, other interest group 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP, MSY had to be achieved for all relevant stocks by 2020 and maintained 
thereafter. In your opinion: 

Q6: To what extent has the MAP contributed to increase the number of TACs set at MSY and 
to keep them at MSY thereafter? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q7: Has the MAP provided an effective framework to contribute to rebuilding fish stocks in 
the Baltic Sea above healthy levels?  

• 
• 
• 

Significantly  
A little 
Not much  

58 

 
 
 
 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q8: Free text 

Currently we don’t see positive development in the fish stocks and therefore we see that the 
MAP hasn’t contributed to rebuilding fish stocks. The only positive example is the increase of 
Gulf of Riga herring spawning stock biomass (out of 10 Baltic fish stocks managed by TACs), 
but  we  see  that  the  positive  development  is  largely  due  to  local  and  national  management 
measures.  

Regarding fishing  mortality,  Baltic Sea MAP  described mortality  reference points as ranges 
which extended beyond the limits in Article 2 of the CFP (i.e. introducing fishing mortality 
ranges which exceed the FMSY point estimate). Thus some of the agreed Baltic TACs were set 
above F-MSY point value risking overfishing of the targeted stock. 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion:  

Q9: To what extent do undocumented and illegal discards continue? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q10: To what extent has the MAP contributed to avoiding discards and implementing the 
landing obligation? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q11:  To  what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed 
fisheries – management of by-catch stocks and avoidance of choking situations?  

• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  

59 

 
 
• 
• 

Counterproductive  
No opinion 

Q12: What is the impact on the fish stocks of the current level of discards and implementation 
of the landing obligation? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q13: Free text 

It  is  currently  difficult  to  assess  the  implementation  –  and  therefore  effectiveness  –  of  the 
landing  obligation  due  to  a  lack  of  reliable  catch  data  and  use  of  monitoring,  control  and 
surveillance tools. The new Fisheries Control Regulation, which entered into force on the 1st of 
January, will mandate the use of Remote Electronic Monitoring to ensure compliance with the 
landing obligation for vessels above 18m. This obligation must be put into place as soon as 
possible (and by no later than 2027, as per the legal requirement) and to expand this requirement 
to vessels below 18m at risk of non-compliance with the landing obligation. 

Baltic  Sea  MAP  allowed  the  use  of  upper  ranges  as  a  means  to  address  challenges  in  the 
management of mixed fisheries, but then contradicted that allowance by basing provisions on 
single species stock management. In case of mixed fisheries and high bycatch rates we highlight 
that fishing mortality for the stronger stock should be set in such a way to avoid overfishing of 
weaker stocks.  

Baltic MAP omits measures to avoid bycatch (such as developing more selective fishing gear, 
or  other  mitigating  measures  such  as  avoidance  measures  or  spatio-temporal  closures),  but 
instead includes delegated powers for these to be developed separately. 

Section 3 – Ecosystem-based approach  

On  the  ecosystem-based  approach  to  fisheries  management  and  against  the  background  that 
‘good environmental status’ was not achieved by 2020, in your opinion: 

Q14: To what extent has the MAP contributed to implement the ecosystem-based approach 
to Baltic Sea fisheries management? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

60 

 
 
Q15: What is the impact on the relevant stocks of the current situation of the ecosystem (cf. 
ICES ecosystem overview https://doi.org/10.17895/ices.advice.21725438)? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q16: To what extend can the MAP contribute to addressing the current issues of the Baltic 
Sea ecosystem?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q17: Free text  

The Baltic MAP has some potential in bringing in ecosystem considerations as among others it 
refers to achieving the good environmental status under MSFD, however we observe lack of 
implementation  of  these  provisions.  The  Baltic  Sea  ecosystem  is  changing  rapidly  with 
unexpected and sudden impacts on fish stocks and therefore the ecosystem perspective (such 
as  changes  in  the  food  web)  should  be  taken  into  account  with  high  priority  in  fisheries 
management.  

We  acknowledge  some  steps  in  a  direction  on  ecosystem-based  fisheries  management 
implementation in the Baltic Sea region, such as EU Fisheries Council (AGRIFISH) decision 
on plaice TAC (for the year 2023, 2024) being set below maximum threshold advised by the 
scientists, in order to protect depleted Baltic cod stocks from by-catch.  

Baltic  Sea  MAP  omits  measures  to  address  specific  environmental  and  wider  fisheries 
challenges in the Baltic (e.g. the incidental catches of sensitive species such as seabirds, harbour 
porpoises and other marine mammals, or the protection of essential fish habitats). Article 3.3. 
and 8.1 of the MAP  provides opportunity  to  steer fisheries towards low impact  gear/fishing 
practicies, but we consider that it was never properly considered/applied.  

Baltic  Sea  MAP  focused  primarily  on  fishing  mortality  and  biomass  reference  points,  as 
opposed to a broader ecosystem approach. 

61 

 
 
 
 
Section 4 – Control enforcement  

On control and enforcement, in your opinion: 

Q18: What have been the effects of Article 13 (MOT) on the relevant Baltic Sea fisheries and 
on the status of the related stocks? 

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q19: What effects on the relevant stocks do you expect from the recently adopted changes to 
the MOT?  

• 
• 
• 
• 
• 
• 

Significant  
Some 
Not much  
None at all  
Counterproductive  
No opinion 

Q20: Free text  

Baltic pelagic fisheries have had a more lenient MoT and this has led to a large decline in the 
accuracy of catch reporting. An audit by the Commission found underreporting of sprat by 78% 
in one country combined with an overreporting of over 800% of bycatch species not subject to 
quota. In another instance they found an average underreporting of herring of 36% and of 63% 
in  the case of sprat.  The increase of MOT, combined with  mis- and unreporting of catches, 
means that the catch data used by ICES would become considerably less reliable, leading to a 
less reliable stock assessments and possible errors when defining sustainable fishing mortality 
levels. We see that the possible inaccuracy of stock assessments and misreporting of sprat as 
herring have very likely influenced overfishing via underreporting catches and have hindered 
the outcomes of the Baltic MAP. 

Section 5 – Regional cooperation  

On regional cooperation, in your opinion: 

Q21:  To  what  extent  has  the  MAP  strengthened  regional  cooperation,  including  with 
stakeholders, on the preparation of joint recommendations? 

• 
• 
• 

Significantly  
A little 
Not much  

62 

 
 
• 
• 
• 

Not at all  
Counterproductive  
No opinion 

Q22: Has the MAP triggered strengthened regional cooperation on other topic?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q23: Free text  

We consider that these questions are more relevant to the Baltic Member state representatives. 
For us as a stakeholder it is difficult to assess the impact because we are not involved in the 
Baltfish high level group. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion:  

Q24:  How  has  the  overall  socio-economic  situation  of  the  Baltic  Sea  fisheries  sector 
developed since the last report on the implementation of the MAP? 

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q25: Are there differences between different (sub-)sectors?  

• 
• 
• 
• 
• 
• 

Significantly  
A little 
Not much  
Not at all  
Counterproductive  
No opinion 

Q26:  Do  you  see  a  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic developments? 

• 
• 

Significantly  
A little 

63 

 
 
• 
• 
• 
• 

Not much  
Not at all  
Counterproductive  
No opinion 

Q27: free text 

The lack of implementation of crucial elements of the Baltic MAP, such as Ecosystem Based 
Fisheries Management and the art. 2.2 of the CFP has most probably contributed to the current 
dire  situation  of  socio-economic  development.  Abundant  fish  stocks  would  provide  positive 
socio-economic development for the fisheries sector, which is currently not the case. 

Section 7 – Additional measures 

Q28: Are there any additional measures that would contribute to the faster achievement of 
the objectives provided for in Article 3 of the MAP? 

The current Baltic MAP contains no provisions on harvest control rules which should be used 
to safeguard the stock if its biomass is below critical reference points. Article 5.1 only stipulates 
“to  take  into  account  the  decrease  in  biomass”.  Article  5.2  allows  suspending  the  targeted 
fishery  if  a  stock  falls  below  Blim  levels  (limit reference  point  for  spawning  stock  biomass 
(SBB)), but does not require any concrete action within a specific timeframe.  

The  MAP  also  omits  measures  to  avoid  bycatch  (such  as  developing  more  selective  fishing 
gear, or other mitigating measures such as avoidance measures or spatio-temporal closures), 
but instead includes delegated powers for these to be developed separately.  

Furthermore, the MAP doesn’t address specific environmental and wider fisheries challenges 
in the Baltic (e. g. the incidental catches of sensitive species such as seabirds, harbour porpoises 
and other marine mammals, or the protection of essential fish habitats). 

Section 8 – Overall assessment 

Q29: What is your overall assessment of the Baltic MAP? 

• 
• 
• 
• 
• 
• 

Very beneficial  
Beneficial  
Neutral  
Negative  
Very negative  
No opinion 

Q30: Free text 

The Baltic MAP has streamlined the process of setting fishing opportunities but on the other 
hand it seems to simplify the overall concept of fisheries management, leading to a tendency to 

64 

 
 
 
ignore wider ecosystem considerations (e.g. food web interactions and changes in fish stocks 
productivity).  Implementation  of  Ecosystem  Based  Approach  to  fisheries  management  is 
almost completely lacking. 

65 

 
 
 
 
 
ANNEX 

1 In May 2021 the ICES advice was upgraded to category 1 (MSY) advice and increased from 65.018 tonnes to 117.458 tonnes; the initial TAC was subsequently adjusted accordingly. 
2 The TAC proposal for 2022 was made after the adoption of the formal Commission proposal. 
3 The figures indicated as ICES advice are reduced by the historic Russian share (9.5% for central herring and 10.08% for sprat; the 5% for cod are no longer applied given the 0-catch advice). 
4 The figure indicated as ICES advice takes account of the mixing between central herring and Gulf of Riga herring; for its 2024 proposal the Commission considered the FMSY point value to be 
35.000 tonnes (the central Baltic herring migrating into the Gulf of Riga was not added since the Commission proposed to close the targeted fishery for central Baltic herring). 
5 The TAC proposal for 2020 was made after the adoption of the formal Commission proposal. 
6 The figure indicated as ICES advice relates only to commercial catches for 2020 and 2021; since 2022 the figure relates to total commercial and recreational catches. 

66 

Fmsy pointFmsy upperFmsy pointFmsy upperFmsy pointFmsy upperGulf of Bothnia herring (HER/30/31)1 865.10865.10875.00172.958na65.01865.018119.52871.700Yes111.345111.714111.345111.345123.29877.281YesWestern herring (HER/3BC+24)2 82.6513.1504.1163.878No1.5751.5751.7971.540No788788788569NoCentral herring (HER/3D-R30)3 4 8153.384190.107153.384153.384167.782151.111Yes97.551na97.55197.551112.057104.922Yes62.353na44.70953.65360.53855.237YesGulf of Riga herring (HER/03D.RG)434.44539.15734.44534.44534.95833.192Yes39.44645.09839.44639.44640.91237.961Yes47.69754.88447.69747.69750.64842.968YesEastern Baltic cod (COD/3DX32.)5 8 2.0002.0002.000561na595595595176na595595595202naWestern Baltic cod (COD/3BC+24)2 6 85.105na3.0653.8064.7403.295Yes4.635na3.3954.0004.4741.326Yes698na324489489136YesPlaice (PLE/3BCD-C)7 86.8946.8947.9784.226Yes7.75410.7916.8947.2408.0382.731Yes11.08316.0067.2409.0509.8541.803YesSprat (SPR/3BCD-C)3 8203.027210.147203.027210.147223.825214.492Yes222.958284.896210.147222.958232.291227.093Yes262.337335.590222.958251.943257.141249.159YesTotal467.873470.574478.934520.400483.713437.362424.621438.383519.692447.449495.513435.656475.560503.351427.35500065.01865.018ICES adviceICES adviceICES adviceadapted TAC6.894000202020212022COM proposalinitial TACadapted TACLandingsTAC at MSYCOM proposalinitial TACadapted TACLandingsTAC at MSYCOM proposalinitial TACLandingsTAC at MSYFmsy pointFmsy upperFmsy pointFmsy upperFmsy pointFmsy upperGulf of Bothnia herring (HER/30/31)1, 8102.719103.05980.04780.04792.37766.936Yes63.049na1.00055.000YesWestern herring (HER/3BC+24)2, 8788788788555No394788NoCentral herring (HER/3D-R30)3, 4, 884.140na61.05170.82275.34870.353Yes45.500na28.55040.368Yes111.034naGulf of Riga herring (HER/03D.RG)445.64352.49645.64345.64350.70847.962Yes37.95943.42736.51437.959Yes41.63547.637Eastern Baltic cod (COD/3DX32.)5, 8 595595595188na595595naWestern Baltic cod (COD/3BC+24)2, 6, 8943na48948948988Yes24na136340na24naPlaice (PLE/3BCD-C)7, 813.31519.14011.31311.31312.2981.758Yes17.93926.91611.31311.313Yes20.14929.837Sprat (SPR/3BCD-C)3, 8224.114285.860201.554224.114232.096219.780Yes217.250222.735171.815201.000Yes148.320152.083Total470.874401.480433.811464.699407.620381.721250.317347.363321.1620002025ICES adviceICES advice202302024COM proposalinitial TACTAC at MSYCOM proposaladapted TACICES adviceLandings00advice postponedinitial TACTAC at MSY 
 
 
 
 
7 The figure indicated as ICES advice is a combination of the ICES advice for subdivisions 24-32 and a certain share for subdivisions 21-23 indicated in the ICES advice. ICES has provided 
category 1 (MSY) advice for 21-23 since 2020, and category 2 (MSY) advice for 24-32 since 2022.  
8 The TAC proposal for 2024 was made after the adoption of the formal Commission proposal. 

67