COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the Commission's assessment of the Member States’ programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive (2008/56/EC)
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, EU action, biodiversity, climate change, climate change policy, environmental protection, marine ecosystem, marine environment, marine pollution, prevention of pollution

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 1 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the Commission's assessment of the Member States’ programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive (2008/56/EC) {COM(2025) 3 final}  
 
 
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Marine Strategy Framework Directive  

Assessment of Member 
States’ second 
programmes of 
measures 

ENVIRONMENT 
ENVIRONMENT 

 
 
 
 
 
 
 
5.3 

3.3 

3.1 

3.2 

4.1 
4.2 

5.1 
5.2 

INTRODUCTION ....................................................................................................................................... 3 
1. 
2.  GENERAL OVERVIEW OF MEASURES ............................................................................................. 5 
3.  TACKLING THE TRIPLE PLANETARY CRISIS .............................................................................. 16 
Towards zero pollution seas and ocean ........................................................................................................................................................................................ 16 
Reducing marine litter ....................................................................................................................................................................................................... 17 
3.1.1 
Reducing nutrient losses ................................................................................................................................................................................................. 20 
3.1.2 
Reducing harmful contaminants ............................................................................................................................................................................ 21 
3.1.3 
Reducing underwater noise ......................................................................................................................................................................................... 24 
3.1.4 
Bringing marine nature back into our lives.................................................................................................................................................................................. 26 
Protecting and restoring marine ecosystems ........................................................................................................................................... 27 
3.1.5 
Replenishing fish and shellfish populations ............................................................................................................................................... 34 
3.1.6 
3.1.7 
Mitigating invasive alien species ........................................................................................................................................................................... 36 
Limiting permanent alterations to hydrographical conditions ............................................................................................... 38 
3.1.8 
Tackling the climate crisis .............................................................................................................................................................................................................................. 40 
4.  REGIONAL COHERENCE .................................................................................................................... 44 
Regional cooperation & cooperation on transboundary measures .................................................................................................................. 44 
Regional coherence of measures .......................................................................................................................................................................................................... 46 
North-East Atlantic................................................................................................................................................................................................................ 46 
4.2.1 
Baltic..................................................................................................................................................................................................................................................... 63 
4.2.2 
Mediterranean ............................................................................................................................................................................................................................ 82 
4.2.3 
5.  GOVERNANCE ....................................................................................................................................... 99 
Public consultations.............................................................................................................................................................................................................................................. 99 
Cross-policy cooperation ............................................................................................................................................................................................................................ 100 
Cooperation across different authorities ................................................................................................................................................... 101 
5.2.1 
5.2.2 
Integration of eu policy objectives ................................................................................................................................................................... 102 
Integration of socio-economic considerations into the design of the PoMs ....................................................................................... 103 
Costs and benefits of msfd programmes of measures ........................................................................................................... 103 
5.3.1 
Economic and social impacts of msfd measures ........................................................................................................................... 105 
5.3.2 
5.3.3 
Funding MSFD measures ........................................................................................................................................................................................... 107 
Evidence of member states’ commitment to implement the measures ............................................................................................... 108 
6.  MEMBER STATE CONCLUSIONS ................................................................................................. 111 
Belgium ......................................................................................................................................................................................................................................................................... 111 
Cyprus ............................................................................................................................................................................................................................................................................. 120 
Germany ....................................................................................................................................................................................................................................................................... 126 
Estonia ............................................................................................................................................................................................................................................................................ 136 
Spain................................................................................................................................................................................................................................................................................. 144 
Finland ............................................................................................................................................................................................................................................................................ 154 
France .............................................................................................................................................................................................................................................................................. 162 
Ireland ............................................................................................................................................................................................................................................................................. 170 
Italy .................................................................................................................................................................................................................................................................................... 178 
Latvia ............................................................................................................................................................................................................................................................................... 185 
Lithuania ...................................................................................................................................................................................................................................................................... 193 
Netherlands ............................................................................................................................................................................................................................................................... 201 
Poland ............................................................................................................................................................................................................................................................................. 208 
Portugal ......................................................................................................................................................................................................................................................................... 218 
Romania ....................................................................................................................................................................................................................................................................... 226 
Sweden .......................................................................................................................................................................................................................................................................... 234 
Slovenia......................................................................................................................................................................................................................................................................... 242 
7.  COUNTRY-SPECIFIC RECOMMENDATIONS ............................................................................ 252 
Recommendations for immediate improvements .......................................................................................................................................................... 252 
Recommendations for third programmes of measures ........................................................................................................................................... 253 
Cross-cutting issues ......................................................................................................................................................................................................... 253 
7.2.1 
Methodological recommendations .................................................................................................................................................................. 254 
7.2.2 
Descriptor-specific recommendations ......................................................................................................................................................... 258 
7.2.3 
ABBREVIATIONS ......................................................................................................................................... 262 

6.1 
6.2 
6.3 
6.4 
6.5 
6.6 
6.7 
6.8 
6.9 
6.10 
6.11 
6.12 
6.13 
6.14 
6.15 
6.16 
6.17 

7.1 
7.2 

5.4 

2 

 
1. Introduction 

The Marine Strategy Framework Directive (MSFD) is the main legal instrument of the European Union 
for the protection and sustainable use of the European Seas. According to this Directive, each Member 
State should develop a marine strategy for its marine waters which, while being specific to its own 
waters, reflects the overall perspective of the marine region or subregion concerned. The final stage 
in the preparation of the marine strategies is the identification of measures needed to achieve or 
maintain good environmental status (GES) (Article 13(1)) and the integration of those measures into 
a programme of measures (PoM) to be reported to the European Commission by 31 of March 2016 
(Article  5(2)(b)(i)  and  Article  13(9))  and  updated  every  6  years  after  that  (Article  17(2)).  It  was 
therefore  expected  that  Member  States  would  report  an  updated  programme  of  measures  by  31 
March 2022. 

Following  receipt  of  these  submissions,  according  to  Article  16,  the  European  Commission  must 
assess these reports and provide guidance to Member States on modifications considered necessary. 

MSFD Article 16 – Notifications and Commission’s assessment 

On the basis of the notifications of programmes of measures made pursuant to Article 13(9), the Commission shall assess 
whether, in the case of each Member State, the programmes notified constitute an appropriate framework to meet the 
requirements of this Directive and may ask the Member State concerned to provide any additional information that is 
available and necessary. 

In drawing up those assessments, the Commission shall consider the coherence of programmes of measures within the 
different marine regions or subregions and across the Community. 

Within six months of receiving all those notifications, the Commission informs Member States concerned whether, in its 
opinion, the programmes of measures notified are consistent with this Directive and provides guidance on any modifications 
it considers necessary. 

The technical  assessments on which this  document is based  analyse Member States’ reporting of 
their programmes of measures. These technical assessments consist of: 

-  An EU-level technical analysis (1) of the information reported electronically by Member 
States providing an overview of the level of completeness and harmonisation of the measures 
according to their purpose, type and coverage of descriptors, pressures, features and marine 
areas among others.  

-  Member State-specific assessments (2) looking at the completeness and adequacy of the 
content  of  the  measures,  in  particular  how  the  measures  address  the  pressures  on  the 
Member States’ marine waters, as identified under Article 8, how the measures contribute to 
achieving  GES  and  targets,  as  defined  under  Article  9  and  10  and  whether  governance 
mechanisms are in place to support the implementation of the Programmes of Measures.  

(1) This analysis was prepared by the European Commission, Joint Research Centre: Louropoulou, E., Alonso Aller, E., 
Cardoso, A.C., Carravieri, A., Druon, J., Magliozzi, C., Martini, E., Mendes, C., Palma, M., Piroddi, C., Ruiz-Orejón, L.F., Zupan, M. 
and Hanke, G., Programmes of Measures under the Marine Strategy Framework Directive to achieve or maintain Good 
Environmental Status, Publications Office of the European Union, Luxembourg, 2024, JRC139180.] 
(2) These assessments were carried out by an external consultant. National reports for each Member State can be 
consulted at: https://environment.ec.europa.eu/topics/marine-environment/implementation-marine-strategy-framework-
directive_en#second-implementation-cycle-2018--2023  

3 

 
 
-  Regional  coherence  assessments  comparing  several  elements  of  the  Member  States’ 
national reporting and drawing conclusions on the level of coherence between Member States 
in the same marine region. In particular, the assessment looked into coverage of pressures 
and  activities,  purpose  and  content  of  measures,  approach  to  the  assessment  of  gaps  to 
achieve GES, use of MSFD-specific measures or measures from other instruments and use of 
exceptions. 

Only five Member States reported by the deadline, a further nine with up to one-year delay and finally 
three with more than one-year delay but still on time to be included in this assessment (3). In total, 
the Programmes of Measures from these 17 Member States could be assessed (out of 22 coastal 
Member States): Belgium, Germany, Ireland, Spain, Estonia, France, Italy, Cyprus, Latvia, Lithuania, 
Netherlands, Poland, Portugal, Romania, Slovenia, Finland and Sweden. This late- or non-reporting has 
limited the Commission’s ability to perform fully encompassing regional coherence assessments, in 
addition to checking the adequacy and completeness of the reports received. 

This Staff Working Document starts with a general EU-level overview of the types of measures taken 
by  Member  States  in  their  second  programmes  of  measures  and  their  coverage  of  descriptors, 
pressures,  features  and  marine  areas  among  others,  and  related  comparisons  with  the  measures 
taken in the first MSFD cycle of implementation.  

In a second stage, the content of the measures is analysed to attempt to answer the question: how 
do the measures taken under the MSFD contribute to tackling the triple planetary crisis? The SWD 
then focuses on the  regional  coherence of measures  and the governance mechanisms in place to 
support the implementation of the PoMs, including coordination between different authorities, public 
involvement and level of investments.  

The sixth chapter of this document provides the country-specific conclusions from the assessment of 
adequacy of the measures to achieve good environmental status by descriptor and for cross-cutting 
issues based on the Member States’ reports. The final chapter provides a list of Member State-specific 
recommendations for a number of topics as well as per descriptor.     

Overarching conclusions from this analysis together with general recommendations for all Member 
States are presented in the Commission’s report (4). Moreover, the findings of this assessment of the 
countries’ programme of measures have also fed into the MSFD evaluation which has been carried 
out in parallel (5).  

(3)  On time – BE, IT, RO, SE, FI; up to 6 months delay – NL, DE, FR, PL, ES; up to 1 year delay – IE, PT, SI, EE; by 1 September 
2023 – CY, LT, LV. 
(4) Report from the Commission to the Council and the European Parliament on the Commission's assessment of the Member 
States’ programmes of measures as updated under Article 17 of the Marine Strategy Framework Directive (2008/56/EC) – 
COM(2025) 3.  
(5) Commission Staff Working Document, Evaluation of 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 (Marine Strategy 
Framework Directive), SWD(2025) 50 (available in the first semester of 2025). 

4 

 
 
 
 
 
2. General overview of measures 

This report presents key outcomes from the Commission’s assessment of the second programmes of 
measures, which all Member States had to report to the Commission by 31 March 2022. The analysis 
includes programmes of measures presented by the 17 Member States which reported by September 
2023. In total 2046 measures were reported, covering all marine regions, descriptors and pressures 
on marine ecosystems. 

As shown in Figure 1,  60%  of the measures  reported  for the second cycle  prolong  measures 
reported in the first cycle, including 16% with some modifications. Almost  a third (27%) are 
new measures introduced specifically for the second cycle of implementation. 

Figure 1. Comparison with first cycle of implementation 

Looking at individual Member States, differences can be observed, with a few Member States (6) 
exceeding 30% of new measures (even reaching 88% for one Member State (7)), while several 
others (8) have high shares of measures that are the same, i.e. not modified, as the first programmes 
of measures. In most instances, the changes made to measures prolonged from the first cycle are 
quite limited, having mostly to do with adaptations due to other legislation being updated, while 
improvements in the way measures are being designed and implemented remain modest.  

According to Member State’s reporting, over 50% of measures are fully implemented on the 
ground: almost 40% of measures have been reported as “implemented”, indicating that all planned 
components (in time and space) of these measures are fully completed, and for an additional 17% 
of  measures,  implementation  is  reported  as  “ongoing”,  indicating  that  these  measures  are 
implemented  and  continuing  into  the  future.  For  almost  a  quarter  of  measures  (23.5  %), 
implementation is reported as already started, indicating that as of the time of reporting the 
second  programmes  of  measures  to  the  Commission,  one  or  more  planned  components  of  these 
measures have been started. Finally, for 17% of measures, implementation is reported as not 
having  started.  Only  2.5  %  of  the  measures  across  all  Member  States  have  been  withdrawn 
between the first and second cycles. Logically, most of the ‘implemented’ measures (63%) are those 

(6) BE (35%), EE (67%), ES (35%), PL (33%), SI (38%) 
(7) LV 
(8) CY (78%), IE, (71%), IT (75%), RO (81%) 

5 

 
 
 
originating from the first programmes of measures while the majority (57%) of measures, for which 
implementation has not started are ‘new’ measures to this cycle. 

Regarding obstacles to implementation, many Member States reported that there was no obstacle (in 
48%  of  cases).  Among  obstacles  encountered,  financing  was the most prominent  reason  for  not 
implementing measures for four Member States (9) followed by technical implementation issues 
(10) and national mechanisms for implementation (11). 

Overall, the majority of measures reported in the second cycle (58%) are existing measures 
adopted  for  other  EU  legislation,  Regional  Sea  Conventions,  international  agreements  or  national 
legislation, which are designed for the implementation of those policies but are also relevant to the 
MSFD.  

Member States have associated their measures to other frameworks at national, EU, regional and 
international levels, which can be seen as drivers for taking these measures (besides the MSFD itself). 
National policies are the most frequently linked to MSFD measures (19%) (12) and the four European 
Regional Sea Conventions close behind (14%), in particular HELCOM (6%) and OSPAR (5%) (Figure 
2) (13).  

Grouping references by topics, land-based pollution instruments (18%) are most frequently linked 
to MSFD measures, in particular the Water Framework Directive and other water-related legislation 
(e.g. on Urban Wastewater Treatment or Bathing Waters directives), waste legislation (e.g. Single Use 
Plastics  Directive),  chemicals  legislation  (e.g.  REACH),  agriculture-related  legislation  (on  Nitrates, 
Sewage  Sludge  or  Plant  Protection  Product)  and  international  conventions  (e.g.  the  Minamata 
Convention on mercury or the Stockholm Convention on persistent pollutants). Biodiversity-related 
instruments  are  also  frequently  referenced  (15%),  including  EU  legislation  (Birds  and  Habitats 
Directives,  Invasive  Alien  Species  Regulation)  and  EU  policies  (Biodiversity  Strategy)  as  well  as 
international  conventions  (Convention  on  Biological  Diversity,  Convention  on  Migratory  Species, 
Wadden Sea Convention, etc.).  

In comparison, references to maritime pollution and shipping policies are less frequent (8%) but 
focus in particular on instruments related to the International Maritime Organization (IMO). 8% of 
references are made to fisheries-related policies, in particular the Common Fisheries Policy (CFP) 
but also the European Maritime and Fisheries Fund (EMFF) and the Data Collection Framework (DCF), 
as  well  as  the  international  dimension  of  fisheries  with  references  to  the  Regional  Fisheries 
Management Organisations such as the General Fisheries Commission for the Mediterranean (GFCM), 
the International Convention for the Conservation of Atlantic Tuna (ICCAT) and the North East Atlantic 
Fisheries  Commission  (NEAFC).  Finally,  6%  of  references  to  other  frameworks  are  linked  to  EU 
planning policies (Maritime Special Panning and Environmental Impact Assessment Directives). 

(9) DE, ES, PT and RO 
(10) CY, DE, EE, ES, FR, PT 
(11) DE, EE, ES, FR, PT 
(12) It should be noted that in several MS, the legal basis for implementing EU Directives lies within their national 
legislation. 
(13) It should be noted that these shares were calculated after excluding from the total number of references those made 
to the MSFD itself (approx. 18% of the total). 

6 

 
 
Figure 2. References to other national, EU and international instruments in MSFD Programmes 
of measures 

Biodiversity instruments 
Land pollution instruments  
Fisheries and seafood instruments 
Shipping and maritime pollution  
Planning (MSP/EIA)  
Other  
Regional Sea Conventions 
National instruments  

7 

 
 
  
 
  
 
  
  
  
 
  
 
 
  
 
  
 
Unsurprisingly, the EU instruments most often linked to MSFD measures are the Habitats Directive 
(10%), the Water Framework Directive (8%), the Common Fisheries Policy (6%), the Birds Directive 
(5%) and the Maritime Spatial Planning Directive (4%).  

Approximately 42% of the measures included in the second programmes of measures (14) 
are MSFD-specific measures devised in order to achieve or maintain GES. Approximately half of 
these (20% of all measures) build upon existing implementation processes of other EU legislation 
and international agreements but go beyond what is already required under these (category 2.a) and 
the other half (22% of all measures) are not driven by any other instrument than the MSFD (category 
2.b). This is a substantial increase compared to the first cycle where only 25% of measures 
were defined as ‘new’ measures put into place specifically for the purposes of the Directive (15).  

Almost half of the measures in this second cycle can be considered ‘direct’ measures, designed to 
prevent further inputs of pressure (25%), reduce existing levels of pressure (17%) or restore 
species or habitats (5%). Still, 37% of the measures are designed to indirectly prevent inputs of 
a  pressure  (e.g.  through  governance  mechanisms,  financial  incentives  or  awareness  campaigns) 
while measures linked to knowledge improvement make up approximately 17% of the total.  

Almost 60% of measures in the second programmes of measures are reported to be covering coastal 
waters, and a little over 50% also territorial waters and the exclusive economic zone (EEZ) 
(16). An important share of measures  is reported  as covering inland waters (35%)  and transitional 
waters (30%), pointing to the inclusion in the MSFD programmes of measures from the River 
Basin Management Plans and other measures aiming to prevent pollution at source. A small share 
of  measures  is  also  reported  as  covering  the  extended  continental  shelf  and  waters  beyond 
Member States’ jurisdiction. The latter is particularly interesting since these waters do not fall in 
the scope of the MSFD. Coastal waters, which are both very rich in marine biodiversity and very busy 
in terms of human activities, remain the best covered part of Member States’ marine waters. 

In terms of coverage of marine regions and subregions, the analysis is skewed by the fact that one 
Member State from the Black Sea (out of two in the region) and three Member States from central 
and eastern Mediterranean (out of six in the two subregions) have not reported in time to be included 
in the analysis. Unsurprisingly, therefore, the subregions best covered by measures are the Baltic 
Sea (39%) and the Greater North Sea (31%), followed by the Western Mediterranean Sea (23%) 
and the Bay of Biscay and Iberian Coast (18%).  

Overall, all descriptors of good environmental status (17) have been covered by the Member 
States’  Programmes  of  Measures,  some  better  than  others.  Over  30%  (18)  of  Member  States’ 
measures  have  been  associated  with  biodiversity  (Descriptor  1),  28%  with  seafloor  integrity 
(Descriptor  6),  24%  with  contaminants  (Descriptor  8)  and  22%  with  marine  litter  (Descriptor  10). 
These numbers include measures that are associated to several descriptors. Logically, biodiversity 
descriptors come out strong in this comparison as many measures addressing pressures are reported 
by  Member  States  as  also  addressing  biodiversity.  The  descriptors  least  frequently  associated  to 

(14) This includes both measures prolonged from the first cycle, and new measures taken for the second cycle.  
(15) Report from the Commission to the European Parliament and the Council assessing Member States' programmes of 
measures under the Marine Strategy Framework Directive, Brussels, 31.7.2018 COM(2018) 562 final 
(16) Note that one measure can be implemented spatially in more than one area, hence percentages do not sum up to 
100%. 
(17) The 11 qualitative descriptors are defined in Annex I of Directive 2008/56/EC and are further specified in Commission 
Decision (EU) 2017/848: D1 — Biodiversity, D2 — Non-indigenous Species, D3 — Commercial fish and shellfish, D4 — Food 
webs,  D5  —  Eutrophication,  D6  —  Sea-floor  integrity,  D7  —  Hydrographical  changes,  D8  —  Contaminants,  D9  — 
Contaminants in seafood, D10 — Litter, D11 — Energy, including underwater noise). 
(18) Note that one measure can be reported against several descriptors, hence percentages do not sum up to 100%. 

8 

 
 
measures are hydrographical conditions (Descriptor 7; 8%), contaminants in seafood (Descriptor 9; 
9%), non-indigenous species (Descriptor 2) and underwater noise (Descriptor 11) at 10% each.  

Many  measures  reported  by  Member  States  address  several  descriptors  (Table  1).  This  might  be 
because the subject of the measure is relevant to several descriptors: for instance, in the case 
of  measures  aiming  to  reduce  levels  of  pressure,  which  in  turn  contribute  to  the  achievement  of 
several descriptors (e.g. improvement in wastewater treatment helps reduce levels of contamination, 
eutrophication, litter and restore biodiversity). In other cases, Member States include cross-cutting 
measures, which are linked to governance and stakeholder participation or to the implementation of 
broad policies and link those to all descriptors. 

Table 1. Examples of cross-cutting measures in Member States’ reports 

MS 

Measure Name (Translated) 

Associated GES Descriptor 

DE 

ES 

FR 

IE 

SE 

Integrated Coastal Zone Management 
Promoting marine citizen science activities for the 
improvement of the management of the marine 
environment 

Spatial planning of maritime uses and activities 

Licensing; regulation and planning for the marine and 
coastal environment 
Authorities and municipalities working on the MSFD 
programme of measures need to report on the measures 
implemented. 

D1; D4/D1; D5; D6/D1; D7; D8 

D1; D2; D3; D4/D1; D5; D6/D1; D7; D8; D9; 
D10; D11 

D1; D2; D3; D4/D1; D5; D6/D1; D7; D8; D9; 
D10; D11; 
D1; D2; D3; D4/D1; D5; D6/D1; D7; D8; D9; 
D10; D11 

D1; D2; D3; D4/D1; D5; D6/D1; D7; D8; D9; 
D10; D11; 

To refine the analysis, it is interesting to also look at the measures which have been associated to 
only one descriptor (called ‘descriptor-specific’ measures) (figure 4) and compare the result with the 
descriptor coverage of all measures (figure 3).  

Figure 3. Share of all measures, by descriptor 

35%

30%

25%

20%

15%

10%

5%

0%

D1

D6

D8

D10

D4

D5

D3

D2

D11

D9

D7

9 

 
 
Figure 4. Share of ‘descriptor-specific’ measures, by descriptor 

16%

14%

12%

10%

8%

6%

4%

2%

0%

D1

D10

D6

D8

D5

D4

D2

D11

D3

D7

D9

As can be seen on figure 4, almost 14% of ‘descriptor-specific’ measures reported by the Member 
States for the second programmes of measures address marine litter exclusively. Out of these 14%, 
over  50%  are  reported  as  being implemented  specifically  for  the  MSFD  (i.e.  not  linked  to  another 
instrument). This shows a clear commitment on the part of the Member States to tackle the issue of 
marine litter and identifying the MSFD as the most appropriate instrument to do so. A counter 
example  is  descriptor  3  which  is  addressed  by  16%  of  all  measures  (figure  3)  but  only  3%  of 
‘descriptor-specific’ measures focus on D3 specifically (figure 4), and out of these 3% only a third are 
taken specifically for the MSFD,  confirming that the issue of the health of commercial fish is still 
dealt mainly through other frameworks, especially instruments linked to the Common Fisheries Policy.  

Grouping  the  three  biodiversity  descriptors  together  in  a  ‘biodiversity-cluster’  shows  a  slightly 
different  picture  (Figure  5),  where  ‘biodiversity-specific’  measures  make  up  22%  of  all  measures 
reported by the Member States in this second cycle of implementation.   

10 

 
 
 
 
Figure 5. Share of ‘descriptor-specific’ measures (with biodiversity cluster) 

25%

20%

15%

10%

5%

0%

The split of biodiversity measures by biodiversity components also informs about the species best 
covered by MSFD measures (birds, mammals, fish) and the species and habitats that are still suffering 
from a lack of dedicated attention (cephalopods, turtles, pelagic habitats) (Figure 6) (19). This finding 
is supported by the analysis of the content of the biodiversity measures in section 3.2. 

(19) It should be noted that cephalopods and turtles are not present in all EU marine regions.  

11 

 
 
 
Figure 6. Number of measures by biodiversity components 

70

60

50

40

30

20

10

0

s
e
r
u
s
a
e
m

f
o
r
e
b
m
u
N

Birds

Mammals

Fish

Reptiles (turtles)

Cephalopods

Pelagic habitats

At  the  (sub)regional  level,  both  the  Baltic  Sea  and  Greater  North  Sea  Member  States  have 
associated their measures most frequently with biodiversity (D1), closely followed by nutrients (D5) 
and  contaminants  (D8)  in  the  Baltic,  and  seafloor  integrity  (D6)  in  the  Greater  North  Sea.  In  the 
Western Mediterranean Sea and Adriatic Sea, Member States have associated their measures mainly 
with  seafloor  integrity  (D6),  followed  by  biodiversity  (D1)  and  litter  (D10)  for  the  Western 
Mediterranean Sea, and commercial fish and shellfish (D3) for the Adriatic Sea. In the Bay of Biscay 
and Celtic Seas, measures associated with biodiversity (D1 and D6) also come out first, followed by 
litter (D10) in the Bay of Biscay and commercial fish and shellfish (D3) in the Celtic Seas.  

Looking  at  ‘descriptor-specific’  measures,  a  different  picture  emerges  where  some  pollution 
descriptors (D5, D8 and D10) come out in the Baltic and Greater North Sea, whereas in the Western 
Mediterranean, Celtic Seas and Bay of Biscay, Member States have taken more descriptor-specific 
measures for litter and biodiversity (D1 and D6).  

The  measures  included  in  the  second  programmes  of  measures  cover  all  the  different  types  of 
pressures listed in Annex III of the MSFD (Figure 7). Some pressures are more covered than others. 
For example, the top pressures addressed by measures (20) are the input of contaminants (24%), 
the  extraction,  mortality/injury  of  wild  species  (23%),  the  input  of  litter  (23%),  the 
disturbance of species (21%), and the input of nutrients (20%).  

(20) Note that one measure can be reported against several pressures, hence percentages do not sum up to 100%. 

12 

 
 
 
 
 
 
Figure 7. Share of measures addressing the top 10 Annex III pressures  

30%

25%

20%

15%

10%

5%

0%

Member States report on pressures as categorised according to Annex III MSFD and the Commission 
Decision (21). This categorisation allows to select and analyse measures that address very specific 
pressures in the marine environment. Member States have, however, not always been consistent in 
the use of the different categories in their reporting. For instance, the least covered pressures 
according to the electronic reporting are continuous low frequency sound (3%), impulsive sound 
in water (3%), and species affected by incidental by-catch (3%). These three pressures, 
however,  are  likely  to  have  been  covered  by  other  pressure  categories,  such  as  ‘input  of 
noise’, which covers both continuous and impulsive sound (12%), and ‘disturbance of species’, which 
also includes bycatch (21%). The reporting might therefore give a skewed picture of how well certain 
pressures in the marine environmental are dealt with through the Programmes of Measures.  

Grouping these specific Annex III pressures into ‘headline pressures’ (22), a slightly different picture 
emerges  than  the  one  presented  above  (Figure  8).  Litter  becomes  the  pressure  most  frequently 

(21) For instance, the headline pressure ‘contaminants’ is split into: Input of other substances (e.g. synthetic substances, 
non-synthetic substances, radionuclides); Contaminants – non ubiquitous, persistent, bioaccumulative and toxic (uPBT) 
substances; Contaminants – uPBT substances; Contaminants – in seafood; Acute pollution events 
(22) This analysis was done by grouping together specific pressures under these broader ‘headline’ pressures, as follows: 
Eutrophication (Input of nutrients; Input of organic matter; Eutrophication); Contaminants (Input of other substances 
(e.g. synthetic substances, non-synthetic substances, radionuclides); Contaminants - non uPBT substances; Contaminants - 
uPBT substances; Contaminants – in seafood; Acute Pollution Events); Litter (Input of litter (solid waste matter, including 
micro-sized litter); Litter in the environment; Micro-litter in the environment; Litter and micro-litter in species); Noise (Input 
of anthropogenic sound (impulsive, continuous); Impulsive sound in water; Continuous low frequency sound); Other forms 
of energy (Input of other forms of energy (including electromagnetic fields, light and heat)); NIS (Input or spread of non-
indigenous species; Newly-introduced non-indigenous species; Established non-indigenous species; Microbial Pathogens; 

13 

 
 
 
 
addressed by Member States’ measures (28%), closely followed by contaminants (27%). Over 20% 
of  all  measures  address  disturbance,  extraction  of  species  and  eutrophication.  Noise,  seabed 
disturbance and non-indigenous species are each addressed by over 10% of all measures and other 
forms  of  energy,  adverse  effects  on  species  and  habitats  and  hydrographical  changes  are  each 
addressed by less than 10% of measures.  

Figure 8. Share of measures addressing headline pressures 

30%

25%

20%

15%

10%

5%

0%

Differences  can be seen  at  the  (sub)regional  level. Unsurprisingly, the Baltic Member States 
cover eutrophication-related pressures more than other regions,  but input of contaminants and of 
litter  are  also  well  covered.  In  the  Greater  North  Sea,  the  most  addressed  pressures  are  input  of 
contaminants,  input  of  litter  and  disturbance  of  species.  In  the  Western  Mediterranean,  the 
disturbance of species is the first pressure addressed by measures, closely followed by input of litter. 
In  the  Bay  of  Biscay,  Macaronesia,  Ionian  and  Central  Mediterranean  and  Aegean-Levantine 
subregions, the input of litter is the first pressure addressed, whereas in the Celtic and Black Seas it 
is the extraction of wild species (fisheries) and in the Adriatic Sea, input of contaminants.  

Finally,  looking  at  “Key  Types  Measures”  (KTMs),  which  are  used  in  the  MSFD  and  the  WFD  to 
categorise Member States’ measures according to certain pressures or certain types of actions, not 
all KTMs are equally covered by the Member States’ second programmes of measures (Figure 9).  The 
greatest coverage is observed for “Measures to reduce marine litter” (MSFD29), “Measures to restore 

Genetically Modified Species); Physical disturbance and loss of seabed (Physical disturbance to seabed; Physical loss 
of the seabed); Disturbance of species (Disturbance of species (e.g., where they breed, rest and feed) due to human 
presence; Species affected by incidental by-catch; Loss of, or change to, natural biological communities due to cultivation 
of animal or plant species); Extraction of species (Extraction of, or mortality/injury to, wild species (by commercial and 
recreational fishing and other activities)); Adverse effects on species and habitats (Adverse effects on species or 
habitats); Hydrographical changes (Hydrographical changes; Input of water). 

14 

 
 
 
& conserve marine ecosystems” (MSFD37), “Measures to reduce biological disturbances in the marine 
environment from the extraction of species” (MSFD35) and “Measures to reduce contamination by 
hazardous  substances”  (MSFD31).  In  contrast,  little  coverage  occurs  for  “Measures  to  reduce 
interferences  with  hydrological  processes  in  the  marine  environment”  (MSFD30)  and  other  KTMs 
common  to  the  WFD.  This  is  broadly  in  line  with  previous  results  showing  a  predominance  in  the 
measures covering marine litter, contaminants and biological disturbance.  

Figure 9. Share of measures addressing MSFD and WFD KTMs  

18%

16%

14%

12%

10%

8%

6%

4%

2%

0%

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15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3. Tackling the triple planetary crisis 

Based  on  the  adequacy  assessments  of  Member  States’  programmes  of  measures,  this  chapter 
analyses how Member States’ measures address the 11 descriptors of the MSFD and contribute to 
the achievement of good environmental status and to tackling the triple planetary crisis. For ease of 
analysis, the 11 descriptors have been split into two categories – pollution (D5, D8, D9, D10 and 
D11) and biodiversity (D1, D2, D3, D4, D6 and D7) – although it is clear that measures taken to 
reduce  pollution  levels  greatly  contribute  to  improving  biodiversity.  The  contribution  of  MSFD 
measures  to  fighting  climate  change  has  been  assessed  by  looking  at  measures  across  all 
descriptors.  

Due  to  shortcomings  in  how  Member  States  have  determined  what  is  good  environmental  status 
(GES) for their marine waters, and what targets are needed to reach GES, at the start of the second 
cycle of implementation (23), notably a lack of quantification of the boundaries between ‘GES’ and 
‘not GES’, Member States’ measures still do not express in a quantitative manner the extent to which 
they  will  contribute  to  reach  targets  and  GES.  It  is  in  turn  very  difficult  to  examine  whether  the 
measures taken by Member States, individually or collectively, will sufficiently reduce the pressures 
and  impacts  and  thereby  achieve  or  maintain  good  environmental  status.  The  analysis  therefore 
remains qualitative.  

3.1  Towards zero pollution seas and ocean 

Reducing water pollution is a key dimension of the EU Green Deal and the Zero Pollution 
Action Plan (ZPAP). This section covers four major categories of pollution affecting the 
marine environment: marine litter, nutrients/eutrophication, harmful contaminants and 
underwater noise. In 2021, the ZPAP set targets for some of these pollution categories at 
the time when Member States were finalising their MSFD programme of measures. Whilst not many 
Member States have made direct reference to the ZP targets, they are likely to be an important driver 
of measures in future WFD and MSFD planning cycles. 

Overall, the new or updated measures taken by Member States in this second implementation cycle 
to address pollution issues are moderately adequate in terms of coverage of relevant pressures 
and contributing to achieve GES and targets (24) (Figure 10). Marine litter is the only pollution 
descriptor that achieves a good level of adequacy in this assessment.  

(23) See C(2022)1392 “Commission Notice on recommendations per Member State and region on the 2018 updated 
reports for Articles 8, 9 and 10 of the Marine Strategy Framework Directive (2008/56/EC)” 
24 A detailed analysis of adequacy of each Member State’s programme of measures by descriptor is provided in Section 6 
of this report. 

16 

 
 
 
Figure 10. Assessment of adequacy of Member States’ measures to address pollution issues 

3.1.1  Reducing marine litter  

The importance of the MSFD to address marine litter is once again confirmed by the analysis of the 
Member  States’  updated  programmes  of  measures.  22%  of  all  the  measures  reported  by 
Member States in this reporting round are related to Descriptor 10 – marine litter, of which 
60% target marine litter exclusively (compared to 28% on average for all descriptors). In addition, on 
average  across  all  Member  States,  D10  is  the  only  pollution  descriptor  that  achieves  a  ‘good’ 
adequacy score.   

The pressure of marine macro-litter input on beaches (and to a lesser extent, in the water column) 
is best addressed in many of the second programmes of measures, while litter on the seabed is often 
addressed only indirectly. Most of the direct measures to reduce current levels of the pressure tackle 
macro-litter on beaches, through cleanup actions, or fishing for litter (although this also covers the 
other elements). Micro-litter is less clearly addressed by the Member States, which all link to 
the  lack  of  clear  indicators  and  guidance.  Some  Member  States  (25)  have  included  a  dedicated 
measure to indicator-setting or otherwise in their programmes of measures, while for several Member 
States, micro-litter is only indirectly addressed (26)  or not even covered (27).  Almost  none  of the 
Member  States  have included  dedicated  measures for  the  problem  of litter ingested by 
biota and the issue of indicator-setting on the adverse effects of litter. Mediterranean countries (28) 
have clear targets specified for Caretta caretta but either do not include any measure for it, or only 
measures  to  increase  knowledge  base  on  entanglement  for  instance.  Two  Member  States  in  the 
North-East Atlantic (29) include a measure related to Northern fulmar or gannet in their programme 

(25) PT, NL, IT, BE, DE, EE and ES 
(26) E.g. SI 
(27) E.g. RO, FR, CY, LT, LV 
(28) such as IT, CY and ES 
(29) NL and DE 

17 

 
 
 
of measures. In the Baltic Sea, only one Member State (30) mentions both issues but does not translate 
this into a new measure in its programmes of measures.  

Almost all Member States (31) have adequately identified the main sources of litter input in their 
marine environment. In this respect, Member States report many measures focusing on activities such 
as  sewage  or  other  land-based  sources  (e.g. industry,  agriculture, tourism),  for  which  new  EU 
policy initiatives have been developed (e.g., the Single Use Plastic Directive, the  Urban Wastewater 
Treatment Directive) and several Member States (32) have developed Waste Management Plans. 
Many  Member  States  (33)  also  identify  riverine  input  of  litter  as  one  of  the  main  contributing 
factors.  

Regarding  sea-based  sources  of  litter  input,  virtually  all  Member  States  identified  fisheries  as  an 
important source. Most MSFD-specific measures in the second programmes of measures focus on 
litter input from fisheries (including ghost nets) and do this in an active way, through either clean-
up actions (directly reducing current levels of the pressure) or prevention of further input. Shipping, 
recreational activities and tourism are also often mentioned as important sources of litter. Only 
a few Member States (34) specifically added aquaculture to this list. Maritime transport is mainly 
addressed  through  references  to  initiatives  related  to  IMO,  MARPOL,  port  reception  facilities,  etc. 
Relatively few Member States have established MSFD-specific measures to address litter input from 
shipping.  Identification  of  marine  pollution  hotspots  was  a  recommendation  to  many  of  the 
Member States after the previous round of assessments but has been clearly addressed only by a 
few Member States (35).   

Only three Member States (36) have at some point in their text report made reference to the  Zero 
Pollution Action Plan, but clear linkages can be seen directly in the additional measures identified 
in the second cycle (37). The value of regional cooperation and RSCs is referred to by almost all 
Member States, although some Member States (38) do not link measures to coordinated action through 
the RSCs, or only marginally. 

(30) EE 
(31) Except for IE, CY 
(32) Except for IE, CY 
(33) E.g. IT, NL, FR, DE, SI, and EE 
(34) IT, FR, and SI 
(35) E.g. BE, ES 
(36) SE, PL, and LV  
(37)For instance a number of measures tackle single plastic uses for the purpose of implementing the Single Use Plastics 
Directive and an increasing number of direct measures address microliter, thus contributing the Zero Pollution target to 
reduce plastic litter and microplastic for 2030 
(38) E.g. IT, FI, CY and ES 

18 

 
 
Good examples 

Spain defined several measures linked to the implementation of the Single Use Plastics Directive, for instance:  Special 
tax on non-reusable plastic waste. The purpose of the tax is to promote the prevention of the generation of non-reusable 
plastic packaging waste, as well as the promotion of the recycling of plastic waste, contributing to the circularity of this 
material.  

Germany defined a measure to identify objects that are particularly problematic for the marine environment on the basis 
of the results of the scouring analysis, the examination of the stomach contents of fulmars and the results of the pilot 
monitoring of other marine compartments and possible indicator species. 

Spain and Germany defined measures for clean-up activities targeting not only beaches, but seabed and surface water 
specifically. These are implemented together with communication activities to raise public awareness. 

Germany defined a measure to develop containment systems for microlitter. Similarly, also Italy defined a measure for 
development  of  purification  plants  for  microlitter  (prototypes).  Estonia  defined  a  measure  specifically  focusing  on 
treatment of stormwater and wastewater to reduce the amounts of microplastics. 

Contribution to achieving GES 

Overall,  programmes of  measures for marine litter have improved: Member States have  actively 
taken up the recommendations based on the first programmes of measures through both 
existing and MSFD-specific measures. However, almost no Member States have reported that GES is 
achieved.  

Assessment of progress towards GES is most clearly made in relation to macro-litter on 
beaches.  In  some  cases  (39),  clear  reference  to  the  EU  Beach  litter  threshold  of  20  litter 
items/100 m coastline is made, although for many Member States such reference is lacking, or only 
briefly  introduced  in  the  text  without  explaining  how  it  is  being  dealt  with  in  the  programmes  of 
measures (40). One Member State (41) seems to use different threshold levels, based on which it is 
concluded that its waters are in GES (at least for macro-litter on beaches) although the values used 
seem to be higher than the EU beach litter threshold value. One Member State (42) stands out as the 
only one that puts forward an even stricter threshold value for beach litter than the EU-level threshold.  

For  other  litter  elements,  and  especially  for  micro-litter,  Member  States  point  to  the  lack  of 
threshold values (litter on seabed, water column) or even indicators (micro-litter) as well as the lack 
of baseline data (many Member States only recently started monitoring micro-litter for instance) to 
explain the difficulty of assessing progress towards GES.  

While almost all Member States indicate that GES is not achieved, only very few (43) clearly mention 
when they expect GES to be achieved.  

Three  Member  States  (44)  reported  an  exception  for  D10.  One  Member  State  refers  to  the 
current level of knowledge regarding microplastics which does not allow a measurable assessment 
of the current state of marine litter as well as the presence of marine litter may also be of cross-
border origin. Two others invoke the transboundary problem of litter input in respectively Baltic Sea 

(39) BE, RO, SE, LV and PL  
(40) NL, DE, CY and LT 
(41) IE 
(42) PL 
(43) SE, PL and EE (for macrolitter); arguably also FR but less obvious from the report 
(44) RO, SE and SI  

19 

 
 
(Skagerrak) and Mediterranean (Adriatic Sea), and the need for regional cooperation (through HELCOM 
Baltic Sea and UNEP Mediterranean Action Plans). 

3.1.2  Reducing nutrient losses  

Nutrient pollution is clearly an important source of pressure for marine ecosystems as confirmed by 
the  fact  that  19%  of  the  measures  reported  by  Member  States  are  related  to  Descriptor  5  – 
eutrophication,  either  exclusively  (42%  of  D5  measures)  or  in  combination  with  other  descriptors 
(58%  of  D5  measures).  The  assessment  of  Member  States’  programmes  of  measures  shows,  on 
average, a moderate-to-high level of adequacy of the measures taken by Member States in 
this cycle to address eutrophication.   

Pressures from urban wastewater, agriculture and shipping are generally well addressed by the 
Member States, due to longstanding existing European and international legislation. Pressures from 
airborne  emissions  are  less  consistently  recognised  notwithstanding  legislation  concerning  air 
quality and emissions to air. Relatively few Member States (45) have referenced the revised National 
Emissions Ceiling Directive (which entered into force in December 2016) as a driver for measures in 
relation to nutrients, although airborne nutrient inputs are a significant contributor to inputs 
especially  in  enclosed  seas  such  as  the  Baltic  and  Black  seas.  The  Directive  sets  new  emission 
reduction commitments for each Member State for emissions of nitrogen oxides (NOx), sulphur oxides 
(SOx), non methane volatile organic compounds (NMVOC), ammonia (NH3) and fine particulate matter 
less than 2.5 µm (PM2.5) in 2020 and 2030 and should therefore be considered as a relevant update 
for the programmes of measures.   

River  Basin  Management  Plans  (RBMPs)  provide  an  important  focus  for  measures  to  reduce 
nutrient  inputs  to  the  marine  environment,  as  many  of  the  key  pressures  stem  from  land-based 
activity. There has been good progress in identifying pressures and developing additional measures 
since the first cycle, particularly amongst Baltic Sea Member States (46). In particular, the 3rd RBMP 
cycle has provided opportunity to update measures addressing many of the key nutrient pressures, 
some of these measures being quite innovative. For example, one Member State (47) is seeking to 
promote  alternatives  to  red  meat  (livestock  production  is  a  significant  contributor  to  nutrient 
loadings).  

Only one Member State (48) has explicitly referenced the Zero Pollution target to reduce nutrient 
losses by 50% by 2030. The target, however, was agreed at a time when many Member States were 
finalising their reports on programmes of measures.   

Some Member States (49) are starting to explore restoration measures, recognising the role that 
healthy  marine  habitats  can  play  in  nutrient  cycling  and  reducing  the  adverse  effects  of 
eutrophication.  These  include  measures  to  restore  biogenic  habitats  such  as  blue  mussel  beds, 
seagrass beds and saltmarsh. 

Unsurprisingly, the region most covered by measures against eutrophication is, by far, the Baltic Sea 
(223 measures on D5 for the Baltic against 85 for the Greater North Sea). Most but not all Member 
States  (50)  mentioned  policy  developments  within  the  Regional  Sea  Conventions.  Such  regional 

(45) DE, FI, FR, IE, RO and SE 
(46) EE, FI, LV and SE 
(47) FI 
(48) LV 
(49) Defined by SE, BE, FI and DE  
(50) including CY, FR, IT, NL, PT and SI 

20 

 
 
cooperation  is  important,  particularly  in  ensuring  a  coordinated  approach  to  tackling  nutrient 
pressures and eutrophication. 

Good examples 

Finland is seeking to improve the use of recycled manure in biogas production and the sustainable use of wastewater 
sludge products in green infrastructure. 

Germany is seeking to restore and preserve seagrass populations in transitional and coastal waters as a contribution to 
denitrification. A pilot project is initially planned in the Outer Ems area. 

Sweden is taking additional measures under the National Emissions Ceiling Directive to reduce atmospheric inputs of 
nutrients.  

Regional cooperation within the Baltic Sea under the auspices of HELCOM has been immensely valuable. Modelling carried 
out to inform the Baltic Sea Action Plan has identified nutrient reduction targets aimed at achieving GES for D5 and 
assessed various existing measures to identify the role they can play in meeting the reduction targets. This collaboration 
has provided much greater clarity to Member States concerning the contribution of existing measures and where additional 
efforts need to be focused in moving towards GES.  

Contribution to achieving GES 

There has been good progress in identifying pressures and developing additional measures 
to reduce nutrient losses since the first programmes of measures, however, airborne emissions 
remain less consistently addressed. Member States are unclear about GES achievement in relation to 
D5. The gap analyses prepared by five Member States (51) are insufficient to identify whether GES is 
currently being achieved throughout their waters. No Member State has explicitly incorporated WFD 
assessments within their gap analyses. 

Overall,  there  is  widespread  recognition  that  the  response  time  of  marine  ecosystems  to 
reduction in nutrient pressures can be slow, particularly in relatively enclosed systems such as 
the  Baltic  Sea  where  there  is  already  a  large  pool  of  nutrients  from  historic  inputs.  Furthermore, 
progress towards GES often requires cooperation amongst Member States and third countries.  

In these circumstances exceptions are applied in relation to Art 14(1)(a) (action required by other 
Member States) or Article 14(1)(e) (natural conditions which do not allow timely improvement in the 
status of the marine waters concerned). For example, most Member States with marine waters 
in the Baltic (52) have applied exceptions for D5, recognising the long time it will take to achieve 
GES. One Member State (53) has not applied an exception, although it acknowledges that GES will not 
be achieved for many years in its Baltic Sea waters. The same occurs in the North Sea where some 
Member States have applied exceptions (54), but others have not (55), although they recognised that 
GES will not be achieved for at least a decade.  

3.1.3  Reducing harmful contaminants 

24% of the measures reported by Member States are related to D8 – contaminants and 9% to D9 – 
contaminants in seafood. The assessment of Member States’ programmes of measures shows, on 

(51) ES, FR, IE, IT, NL and PT 
(52) EE, FI, LT (LT did not formally apply an exception but has assumed that the previous exception applied in 2015 will 
continue), LV, PL, SE 
(53) DE 
(54) E.g. FR and NL 
(55) E.g.DE and BE  

21 

 
 
average, a moderate level of adequacy of the measures taken by Member States in this 
cycle to address contamination and contamination in seafood.   

Pressures  from  urban  wastewater,  agriculture,  industry  and  shipping  are  generally  well 
addressed  by  Member  States  due  to  longstanding  existing  European  and  international  legislation, 
although challenges remain in addressing novel and emerging substances (including pharmaceuticals) 
and in addressing legacy impacts from persistent contaminants (heavy metals (mercury, cadmium, 
lead),  polycyclic  aromatic  hydrocarbons  (PAHs),  Polybrominated  diphenyl  ethers  (PBDEs),  PFOS, 
tributyltin (TBT)). There has been good progress in identifying land-based pressures and developing 
additional measures since the first cycle. In particular, the 3rd RBMP cycle has provided opportunity 
to update RBMP measures to reduce contaminant inputs to the marine environment, although Member 
States  have  rarely  elaborated  on  the  contribution  these  WFD  measures  might  make  in  terms  of 
progress towards GES. 

Pressures  from  airborne  emissions  are  less  consistently  addressed  notwithstanding  legislation 
concerning air quality and emissions to air. Increasing controls on airborne emissions through the 
Industrial Emissions Directive and National Emissions Ceiling Directive should contribute to reducing 
contaminant inputs to marine waters, including beyond 12 nautical miles. Only seven Member States, 
however,  mentioned  the  Industrial  Emissions  Directive  (IED)  (56)  and  even  fewer  (57)  have 
referenced the revised National Emissions Ceiling (NEC) Directive (which entered into force in 
December  2016)  as  a  driver  for  measures  in  relation  to  air  contamination.  The  NEC  Directive,  in 
particular, sets new emission reduction commitments for each Member State for the total emissions 
of NOx, SOx, NMVOC, NH3 and PM2.5 in 2020 and 2030 and is therefore a relevant modified existing 
measure for contaminants (particularly in relation to PM2.5 and contaminants associated with such 
particles).  

Some of the measures proposed by Member States as being applied to shipping (environmentally 
friendly  antifouling,  emission  controls,  cleaner  ship  concepts),  linked  to  the  implementation  of 
MARPOL or IMO agreements, are also expected to have a positive impact on Member States waters, 
including areas beyond 12 nautical miles.  

Pressures relevant to D8 are generally relevant to Descriptor 9 (contaminants in seafood). There has 
been  limited  progress  in  identifying  pressures  and  developing  additional  measures 
specifically for D9 since the first cycle. This can be partly explained by the fact that many Member 
States  (58)  reported  being  in  GES  for  D9  in  2018  and  it  is  often  accepted  that  D8  measures  are 
sufficient to address D9. It should be noted, however, that Regulation (EC) 1881/2006 was updated 
in 2023 to cover a broader range of heavy metals and persistent organic substances (59). This means 
that achieving GES has now been put into question in many Member States’ waters. However, this 
update took place in 2023, after many Member States had already updated their  programmes of 
measures. 

Only  one  Member  State  (60)  has  explicitly  referenced  the  Zero  Pollution  target  to  reduce 
contaminant  inputs,  although  the  commitment  was  established  in  May  2021.  For  those  Member 
States that submitted their Article 13 reports on time, this may have been because the targets were 

(56) DE, FI, SE, IE, NL, SI (and CY national legislation) 
(57) Directly mentioned: DE, IE, SE and LV; indirectly mentioned: FR (linked to in measure for regional climate, air and 
energy plans for preservation of air quality), RO (related measure on managing and reducing diffuse pollution sources), 
and FI (national air protection programme 2030 which may relate to NEC) 
(58) BE, CY, FI, IE, LV, NL, PT, RO and SI for at least over half of their marine waters 
(59) Commission Regulation (EU) 2023/915 of 25 April 2023 on maximum levels for certain contaminants in food and 
repealing Regulation (EC) No 1881/2006 
(60) LV 

22 

 
 
agreed at a time when the Article 13 reports were being finalised. The targets are likely to be an 
important driver of measures in future RBMP and MSFD planning cycles.   

Policy developments within the Regional Sea Conventions have been mentioned by all Member States 
except one (61). Such regional cooperation is important, particularly in ensuring a coordinated approach 
to tackling contaminant pressures. In particular, within the Baltic Sea, modelling carried out to inform 
the  Baltic  Sea  Action  Plan  has  identified  pressure  reduction  targets  for  four  contaminants 
(mercury, TBT, PFOS and diclofenac) and assessed various existing measures to identify the role they 
can play in meeting the reduction targets. This collaboration has provided much greater clarity 
to Member States concerning the contribution of existing measures and where additional efforts 
need to be focused in moving towards GES.  

Good examples 

Some innovative measures are starting to be identified to address sea-based contamination. For example: 

Finland and Belgium are seeking to evaluate and manage contaminants released from wrecks; 

•  Belgium and The Netherlands are introducing measures to phase out the use of lead in recreational fishing gear; 
• 
•  Germany is seeking to develop a system for tracking and retrieving containers lost at sea;  
• 

France is seeking to reduce contaminant inputs from shipping by supporting local decarbonisation strategies. 

Regional cooperation within the Baltic Sea under the auspices of HELCOM has been immensely valuable in developing 
contaminant reduction targets for mercury, TBT, PFOS and diclofenac aimed at achieving GES for D8 and assessing various 
existing measures to identify the role they can play in meeting the reduction targets. This collaboration has provided much 
greater clarity to Member States concerning the contribution of existing measures and where additional efforts need to be 
focused in moving towards GES. This analysis is also relevant to D9 to some extent on the basis that if GES for mercury 
can be achieved for D8, this will facilitate achievement for D9. 

Contribution to achieving GES 

There has been good progress in identifying pressures and developing additional measures 
to reduce harmful contaminants since the first cycle, however few Member States have assessed 
the contribution of their updated programme of measures in terms of progress towards GES.  

Overall, there is widespread recognition that the response times of marine ecosystems to 
reductions in  contaminant  pressures  can  be slow, particularly in relatively enclosed  systems 
such as the Baltic Sea where there are historic problems with contaminants such as mercury and 
PBDEs. Furthermore, progress towards GES often requires cooperation amongst Member States 
and third countries.  

Exceptions are applied in relation to Art. 14(1)(a)  (action required by other Member States) or Art 
14(1)(e) (natural conditions which do not allow timely improvement in the status of the marine waters 
concerned).  For example, most Member States with marine waters in the Baltic have applied 
exceptions for D8, recognising the long time it will take to achieve GES.  Two Member States (62) 
have not applied an exception, while acknowledging that GES will not be achieved for many years in 
its Baltic Sea waters. The same occurs in the North Sea where some Member States have applied 

(61) PT 
(62) DE and LV 

23 

 
 
exceptions (63), but others have not (64) although it is recognised that GES is not yet being achieved 
for a range of substances.  

In relation to D9, where GES is not currently achieved, this is often due to legacy issues associated 
with persistent contaminants, for example, mercury and dioxin and dioxin like PCBs in the Baltic 
Sea. In such circumstances, natural conditions preclude the achievement of GES in the short-term and 
Member States have applied exceptions (65). 

3.1.4  Reducing underwater noise 

Underwater noise due to human activities at sea can harm marine biodiversity, leading for example 
to hearing impairment and behavioural  disturbances. Despite being the only EU framework where 
measures can be taken to address underwater noise, only 11% of the measures reported by Member 
States in their second programmes of measures are related to Descriptor 11.  

Apart for one Member State (66) which adequately identified relevant significant gaps, the gap analysis 
is in most cases not reported, poor or not clear. Despite this, ten Member States (67) have modified 
or defined additional MSFD-specific measures in their second programmes of measures. 
The relevant pressures (impulsive noise and low frequency continuous noise) are well addressed for 
six  Member  States  (68),  poorly  addressed  for  four  Member  States  (69)  in  their  programmes  of 
measures’ update, and without clarity for two (70).   

The coverage of the pressure of underwater noise on the marine environment has improved since the 
first  cycle,  although  most  of  the  measures  are  still  focused  on  improving  the  monitoring 
efforts and the knowledge base rather than having a direct impact on the reduction of the input 
or level of the pressure. The measures that were defined in the first cycle are mostly unchanged, a 
few have been updated. The first cycle measures seem to be currently implemented in most cases. 

On the other hand, the introduction of other forms of energy (magnetic, light, and heat)  is still not 
well addressed except for a few Member States (71) developing research into possible effects of 
electromagnetic fields on vulnerable habitats (gravel beds) and associated species72, monitoring 
light pollution together with noise at one monitoring station (73) or taking measures to reduce loads 
from heat discharges74. 

Member States  rely  a lot  on  the frameworks  defined  at  regional  level as  well  as on  EU-
funded projects to improve the knowledge base on underwater noise. In general, the programmes 
of measures of some of Member States from the Baltic Sea (75) refer to the research, framework and 
plans  developed  collectively  in  the  HELCOM  Baltic  Sea  Action  Plan  2021-2030,  which  was 
supported by EU-funded projects such as BIAS (76). A few of them (77) have materialised those plans 

(63) e.g. FR, NL and BE 
(64) DE 
(65) PL, SE and PT 
(66) BE 
(67) BE, DE, ES, FI, FR, PL, PT, SE, SI, EE  
(68) BE, DE, FI, PL, SE, EE 
(69) ES, FR, LT, PT 
(70) RO, SI 
(71) BE, DE, ES 
(72) BE 
(73) ES 
(74) DE 
(75) DE, SE, EE 
(76) BIAS – Baltic Sea information on the acoustic soundscape, https://biasproject.wordpress.com/  
(77) EE, SE, DE 

24 

 
 
with the definition of D11 specific measures aimed at implementing selected action from the HELCOM 
Regional Action Plan on Underwater noise actions, for instance implementing appropriate regulations 
to establish speed limits near sensitive areas or during sensitive times (78). 

In  the  North  East  Atlantic,  three  Member  States  (79)  refer  to  the  OSPAR  North-East  Atlantic 
Environment Strategy 2021-2030, which is developing specific methodologies and measures for 
impulsive  and  low  frequency  continuous  noise.  Some  Member  States  from  the  Mediterranean  (80) 
have  taken  up  the recommendations  from  ACCOBAMS  (81),  but  no  real  development  has  been 
done to turn these high-level recommendations into a detailed and precise set of measures tuned to 
the  challenges  inherent  to  the  Member  States’  national  waters  and  properly  linked  to  operational 
targets.  Two  countries  (82)  refer  to  the  findings  and  recommendations  of  QUIETMED  (83)  and 
QUIETSEAS (84) European projects.  

For impulsive noise, the recommendation from the Technical Group on Underwater Noise to 
file the impulsive noise registry held by ICES (85) is now applied by almost all Member States 
(86), but it seems that Member States do not envision yet how to analyse, leverage and convert those 
data into tangible mitigation measures. 

Although it is not always clearly stated whether the measure addresses low frequency continuous 
noise or impulsive noise, the  most popular  concrete  measures  tackle  offshore  and  coastal 
infrastructure  construction,  either  directly  through  limitation  of  noise  levels  or  indirectly,  for 
instance through the consideration of underwater noise in Environmental Impact Assessment studies. 
A few Member States also address military operations in their programmes of measures, which 
goes beyond the requirements of the MSFD. 

Good examples 

Belgium has addressed a prior gap and has covered impulsive noise from unexploded ordnances (UxO) by focusing on 
limiting the amount of impulsive noise events. With regards to continuous noise, Belgium has defined a measure focussing 
on  optimizing  shipping  approach  routes  during  construction/maintenance  of  offshore  wind  farms  or  other  offshore 
infrastructure to avoid vulnerable areas functioning as a biodiversity hotspot, breeding or nursery spots for herring, sharks, 
rays, etc. 

Similarly  to  other  countries  in  the  Baltic  Sea,  Estonia  has  committed  to  actively  contribute  to  HELCOM  activities  on 
underwater noise, and to apply HELCOM recommendations and action plan in Estonian waters. This commitment ensures 
that the management of underwater noise will be at the state-of-the-art of practices in the region, and consistent with the 
implementation made by the other Member States of the region. 

Contribution to achieving GES 

Member  States’  reporting  on  D11  has  improved  mainly  through  the  definition  of  additional 
measures, especially for Member States who had poorly done so during the first cycle. Almost no 

(78 )EE 
(79) BE, ES, and PT 
(80) ES, SI, CY 
(81) Agreement on the Conservation of Cetaceans of the Black Sea, Mediterranean Sea and Contiguous Atlantic Area, 
https://accobams.org/  
(82) ES, IT 
(83) Joint programme for GES assessment on D11- noise in the Mediterranean Marine Region, https://quietmed2.eu/  
(84) Assisting cooperation for the implementation of the Marine Strategy Framework Directive on underwater noise, 
https://quietseas.eu/  
(85) https://www.ices.dk/data/data-portals/Pages/impulsive-noise.aspx  
(86) The Member States that submit to ICES: FI, DE, LT, ES, SE, FR, PT, BE, NL, IE, EE. 

25 

 
 
Member  State  (87),  however,  has  reported  that  GES  is  achieved  for  underwater  noise,  either  for 
impulsive noise or low frequency continuous noise, and they often state that it is not possible to 
estimate whether current measures are sufficient to achieve GES. Moreover, many Member 
States (88) have not yet defined GES clearly for underwater noise under Article 9 and this is recognised 
as a limit in their programmes of measures.  

Although they are mostly adequate, the contribution of the modified and  additional MSFD specific 
measures defined in the second programmes of measures to meet the operational environmental 
targets, and ultimately GES, are partially described for most of Member States. The reason is mainly 
that the linkage with operational targets for underwater noise is rarely clearly made. 

3.2  Bringing marine nature back into our lives   

Europe’s seas cover more than 11 million km2 by area and range from shallow, semi-
enclosed seas to vast expanses of the deep ocean. They host a wide and highly diverse 
range of coastal and marine ecosystems with a large variety of habitats and species (89). 
Our quality of life, livelihoods and economies depend on them being in good condition, 
providing our societies with vital ecosystem services, including food, energy, clean air and climate 
change mitigation.   

Marine  biodiversity  is  suffering,  both  globally  and  in  EU  waters.  Marine  species,  habitats  and 
ecosystems are under a number of pressures from anthropogenic activities, including climate change, 
extraction of living and non-living resources, pollution and invasive alien species, which accumulate 
and disrupt essential marine ecosystem processes and food webs, and affect ecosystem resilience 
(90).  The  EU  has  not  succeeded  in  halting  the  loss  of  marine  biodiversity  by  2020  (91)  and  recent 
regional assessments are still painting a bleak picture (92).  

Renewed  commitments  to  protect  marine  biodiversity  have  been  made  in  the  EU  Biodiversity 
Strategy for 2030 (93) and its commitment to protect legally and effectively 30% of our seas, with 
one third being strictly protected. MPAs designated under the Marine Directive contribute to this target.  

This call was echoed at the global level with the adoption of two historic agreements in 2022-2023: 
the Global Biodiversity Framework (94) at CBD COP15 and the Treaty on the conservation and 
sustainable use of marine biological diversity of areas beyond national jurisdiction (95). At 
the EU level, the adoption in February 2023 of the Marine Action Plan (96) contributes to delivering 
on these objectives by calling on Member States to take action to reconcile  fishing activities with 
environmental  protection  objectives,  notably  by  improving  gear  selectivity,  addressing  bycatch  of 
sensitive species, protecting the seabed and helping on transition and knowledge exchange. 

(87) GES reported as not achieved in all Member States except IE.  
(88) BE, DE, EE, ES, FR, LT, PL, PT, SE, SI. 
(89) State of Europe's seas — European Environment Agency (europa.eu) 
(90) Europe’s marine biodiversity remains under pressure — European Environment Agency (europa.eu) 
(91) Report from the Commission on the implementation of the Marine Strategy Framework Directive (Directive 2008/56/EC), 
COM/2020/259 final, Brussels, 25.6.2020 
(92) Such as OSPAR’s Quality Status Report 2023 or HELCOM Holistic Assessments (HOLAS) 2023 report. 
(93)  Communication from the Commission, EU Biodiversity Strategy for 2030 Bringing nature back into our lives, 
COM/2020/380 final, Brussels, 20.5.2020. 
(94) Conference of the parties to the Convention on Biological Diversity, Decision 15/4. Kunming-Montreal Global 
Biodiversity Framework, CBD/COP/DEC/15/4, 19 December 2022 
(95) Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of 
Marine Biological Diversity of Areas beyond National Jurisdiction, New York, 19 June 2023 
(96) Communication from the Commission, EU Action Plan: Protecting and restoring marine ecosystems for sustainable and 
resilient fisheries, COM(2023) 102 final, Brussels, 21.2.2023 

26 

 
 
Overall, the new or updated measures taken by Member States in this second implementation cycle 
to address biodiversity issues are moderately adequate in terms of coverage of relevant pressures 
and  contributing  to  achieve  GES  and  targets  (97)  (Figure  11).  Based  on  the  adequacy  scores, 
Descriptor 2 (non-invasive species) is the only biodiversity descriptor that achieves overall 
a good level of adequacy in this assessment (98) but measures under Descriptors 1 (biodiversity), 
6 (seafloor integrity) and Descriptor 7 (hydrographical conditions) also come close to a good level of 
adequacy. 

Figure 11. Assessment of adequacy of Member States’ measures to address biodiversity issues 

3.1.5  Protecting and restoring marine ecosystems 

Protecting marine life 

31% of all measures reported by Member States in their second programmes of measures are related 
to D1 – biodiversity covering all species groups and pelagic habitats. Descriptor 1 is the descriptor 
most  covered  by  measures,  confirming  that  biodiversity  is  a  concern  to  Member  States  and  that 
increasingly Member States are linking their measures addressing pollution and other pressures to 
the achievement of GES under Descriptor 1.  

The most frequently reported direct pressures on biodiversity are the extraction of wild species 
(23%),  disturbance  of  species  (21%),  physical  disturbance  of  the  seabed  (12%)  and 
physical loss of the seabed (10%).  

Measures addressing the disturbance of species and the physical disturbance or loss of the seabed 
are often of a direct nature. The most common measure under D1 is the implementation of marine 

(97) A detailed analysis of adequacy of each Member State’s programme of measures by descriptor is provided in Section 
6 of this report. 
(98) Although less than half of the Member States’ assessments for D2 were concluded as being ‘good’ or ‘very good’, 
many were assessed as ‘moderate’, only one ‘poor’ and none ‘very poor’. This makes D2 the only descriptor which achieves 
an overall good level of adequacy for almost all Member States. 

27 

 
 
 
 
protected areas (MPAs) in areas of high human activity. These MPAs frequently plan to regulate 
activities which disturb and damage the species and habitats, such as tourist activities (recreational 
boating and water sports) and fishing, particularly with bottom-trawling gear. As well as protection, 
Member States report spatial measures which aim to reinstate and restore vulnerable habitats 
in areas of degradation. MPAs can potentially have a significant impact on pressures, depending on 
the  size  of  the  MPA  and  on  whether  management  measures  are  implemented  or  planned.  This 
information  is  seldom  reported  by  Member  States  beyond  simply  stating  that  harmful  human 
activities will be controlled.  

Member States frequently report the expansion or designation of Natura 2000 sites as a measure 
under  Descriptor  1  to  address  biodiversity,  making  direct  reference  to  the  Habitats  and  Birds 
Directives.  In  rarer  cases,  Member  States  have  included  in  their  programmes  of  measures  the 
designation of MPAs which are not Natura 2000 sites. These  are designated either under national 
legislation (99) or international protection regime (100) and are reported by the Member States as also 
contributing to the achievement of GES under the MSFD. Most of the Member States (101) mention 
links to the Biodiversity Strategy to 2030 in their programmes of measures but links are, however, 
not  clearly  made  to  the  targets  of  protecting  30%  of  EU  seas  by  2030,  including  10%  in  strict 
protection. Only two Member States (102) have clearly mentioned the extent coverage of new MPAs 
reported under MSFD programmes of measures.   

Species-specific  measures  tend  to  focus  on  fish,  marine  mammal,  and  bird  species,  while 
measures for cephalopods, marine reptiles, and pelagic species (e.g. plankton) are rarer. The most 
commonly  identified  activity  causing  pressures  on  species  is  commercial  fishing  and  the  main 
pressure on seabirds and marine mammals in most European waters is incidental bycatch. Relevant 
measures,  for  example  the  use  of  specialist  gear  to  reduce  the  chance  of  bycatch  or  the 
implementation  of  new/extended  protected  areas,  are  put in  place to mitigate  this  pressure.  Gear 
adaptations or changes concern both trawl fisheries (103) and gillnet fisheries (104), especially for birds 
and cetaceans. These measures typically fall in the scope of the Technical Measures Regulation (105), 
which supports the objective of the MSFD in terms of species and habitats protection.  Regulations 
inside MPAs to protect species include regulating fishing activities by making use of the CFP Article 
11 joint recommendation mechanism (106), increased monitoring of fishing activities and training of 
fishers to improve recording and avoidance of bycatch incidents (107).  

The  main  threat  to  fish  species  is  extraction  beyond  safe  levels  and, besides measures  taken 
under D3 for the health of commercial fish populations, the spatial conservation measures taken by 
Member States under D1 can also benefit the health of commercial and non-commercial fish species, 
notably by protecting nursery/spawning grounds (108) or reducing seabed disturbance (109). Obstacles 
in migratory corridors of fish is also reported as an important threat to the health of fish populations.  

(99) E.g. SI reports the designation of a protected area for the protection of detritus beds through national legislation.  
(100) E.g. FR is working on reducing the risk of cetacean vessel collisions by submitting for a Particularly Sensitive Sea Area 
(PSSA) under the International Maritime Organisation 
(101) BE, CY, DE, EE, FI, FR, IE, IT, LV, NL, RO, SE.  
(102) NL, LV 
(103) SE 
(104) BE, PL 
(105)  The Technical Measures Regulation (EU) 2019/1241 on the conservation of fisheries resources and the protection of 
marine ecosystems through technical measures. 
(106) DE 
(107) IT, PT (through the CetAMBICion project) 
(108) BE, EE, FI, FR 
(109) See section on ‘seafloor integrity’ measures 

28 

 
 
Four  Member  States  (110),  including  three  in  the  Baltic,  report  measures  which  aim  to  reduce 
blockages  to  fish  migratory  corridors  and  ensure  their  health  and  maintenance,  including  by 
using  acoustic  monitoring  to  determine  and  protect  important  migratory  pathways  for  fish  (111), 
removing  old  barriers  (e.g  dams)  (112)  or  re-opening  migratory  pathways  and  stimulating  fish 
populations in estuarine/coastal areas (113). In the Mediterranean, measures for coastal fish include 
preventing negative impacts from aquaculture (114). 

Measures  for  marine  reptiles  are  rare.  Some  Member  States  focus  on  raising  awareness  of 
vulnerable turtle species through the development of management plans (115). Others address one of 
the main threats to the species, incidental bycatch, through schemes to improve the monitoring, risk 
assessment and response to turtle bycatch116 or the training of fishers (117). One Member State (118) 
also covers the risk of vessel collision with turtle in its training measure. Measures specifically for 
cephalopods are not reported by any of the Member States to date, and Member States rather 
regularly group cephalopods with fish species and apply measures to both species groups. Pelagic 
habitats are also often overlooked under D1, but efforts are made under D5, D8, D9 and D10 
to return the water column habitat to good condition. Species which are important to this habitat such 
as phytoplankton and zooplankton are not assigned specific measures by any Member States, and 
gap analyses are rarely completed with regard to their status. Only two Member States (119) report a 
clear status update for plankton, both determining that GES has not been achieved. Neither, however, 
has taken measures to progress towards GES for these species. 

Input of substances, anthropogenic noise, and energy into the marine environment are also mostly 
addressed by spatial  measures under D1. The  regulation  of  human  activities within MPAs will 
indirectly reduce the amount of input into the area but will not directly target the sources of inputs. 
Direct measures targeting activities are mostly found under relevant pressure descriptors but some 
Member States (120) have taken measures targeting activities to reduce their impact on biodiversity 
under D1. Most measures that directly target a pressure/ human activity under D1 concern 
fisheries,  e.g.  reducing  the  area  of  seafloor  that  can  be  trawled  (121),  enforcement  of  a  ban  on 
gillnetting and rammel net fishing (122) and the application of technologies and specialised gear to 
reduce bycatch (123), as discussed before. Other activities addressed by D1 measures include fines for 
exceeding permissible nutrient concentrations in wastewater (124), increased regulation of damaging 
tourist activities (125) and measures to reduce pollution impacts from ships (126). 

(110) EE, BE, PL, LT 
(111) LT 
(112) PL 
(113) EE 
(114) SI 
(115) PT, ES 
(116) ES 
(117) FR 
(118) FR 
(119) RO, SE 
(120) e.g. SE. PL, BE, EE, and FR 
(121) SE 
(122) BE 
(123) EE 
(124) PL 
(125) FR 
(126) SE 

29 

 
 
Good examples 

Germany reported two restoration measures: restoring rocky reefs in areas where fisheries no longer pose a threat and 
areas which encourage reef interconnectivity, and fostering the reintroduction of Sabellaria reefs in the North Sea. These 
habitats will then be protected, allowing natural state to be restored and providing refuge for unique communities of other 
organisms. 

Slovenia defined a measure to implement assigned tourist boat anchoring sites to ensure that the environmental impact 
that comes with anchoring is kept in a concentrated area. 

Belgium includes measures tackling fish migration bottlenecks through the removal of human barriers such as dams, the 
tagging of several fish and shark species to identify frequently used areas, and the development of a barrier map for 
seabird migration routes to ensure that threats such as wind energy turbines are not constructed in migration pathways. 
These measures have targeted aims which can be carried out through carefully designed practical methodologies, making 
them practical and achievable. 

Sweden has taken some measures to reduce the impact of shipping on biodiversity, reducing the use of biocide containing 
anti-fouling paints, and the active phasing out of two-stroke engines and carburettors on recreational boats. All of these 
measures are targeted, achievable, and will have a direct impact on addressing the pressures of species and habitat 
disturbance. 

Marine Protected Areas 

Although  often  reported  in  little  detail,  MPAs  can  be  considered  practical  and  direct  measures  if  they  have  clear 
conservation objectives and management measures in place. Several Member States report the planned designation of 
protected areas for specific habitats and species such as meadows, rocky reefs, and detritus beds. These MPAs have been 
designed with the health of these specific habitats in mind, often in response to requirements of the Habitats Directive. 
Regulations can be tailored to fit the needs of these vulnerable environments. Examples include the restriction of fishing 
activities over Zostera beds to avoid gear becoming caught on the plants and damaging or destroying them (Slovenia).  

MPAs can also aim to provide a specific service for species, making regulations more targeted and therefore likely to be 
successful. One such example is the provision of a refuge for fish, marine mammals and seabirds (Germany). Within these 
MPAs the habitats used by these species for rest will be restored and maintained to allow respite from areas of high 
anthropogenic activity.  

Contribution to achieving GES 

Member States that showed progress since the first cycle (127) were those that carried out a thorough 
gap analysis, and identified areas in which further measures were required to ensure biodiversity 
improvement. As biodiversity is such a large topic to cover, without an effective gap analysis to work 
from, measures reported in the updated Programmes of measures can end up very vague, reducing 
their ability to have any real effect on progress towards GES.  

Overall, progress made under D1 since the first cycle has been limited. Five Member States 
report GES as having been achieved for seabird or commercial fish (128). One Member State (129) report 
GES  to  be  achieved  for  large  marine  mammals.  Five  Member  States  (130)  report  that  measures 
reported in the first cycle of implementation were not sufficient to meet GES and five Member States 
(131)  do  not  provide  an  update  on  progress  towards  GES,  due  to  a  lack  of  data.  There  are  many 
examples  of  Member  States  (132)  failing  to  complete  an  effective  gap  analysis  and  therefore 

(127) SE, BE, DE, EE, FI, and FR 
(128) LT, LV, PL, BE, EE 
(129) IE 
(130) FI, FR, DE, NL, and SE 
(131) IT, ES, SI, RO, and PT 
(132) LT, LV, NL, PT, RO, SE, SI, ES, IE, and IT 

30 

 
 
implementing  only  overarching,  cross-cutting  and  vague  measures  for  D1.  Furthermore,  within 
Member States, certain species groups (mammals, birds, fish to some extent) receive the majority of 
focus, whilst others (cephalopods, reptiles) are overlooked. 

10 Member States (133) reported exceptions for D1. The majority of the exceptions are justified by 
action  or  inaction  for  which  the  Member  State  is  not  responsible  and  to  a  smaller  extent  natural 
conditions. In two cases, the Member States (134) reported the failure of measures from the previous 
programmes of measures as a justification for not reaching GES.  

Restoring the seabed  

28% of all measures are reported as addressing D6 – seafloor integrity. As with Descriptor 1, the 
overarching  nature  of  seabed  integrity  means  that  all  biological,  physical,  and  substance  input 
pressures have an impact on this descriptor, whether directly or indirectly.  

Across  Member  States, there  is  a  clear  focus  on  the  physical  preservation  of  the  seafloor. 
Biological pressures, such as the extraction of mobile species which use the seafloor, also have an 
impact on seafloor integrity, but these pressures tend to be  addressed more through  D1 species-
specific measures.  

Physical disturbance and loss of the seabed habitat are addressed by a range of measures including: 
Marine Protected Areas, habitat restoration, limitation to mobile bottom fishing, boating regulations, 
the removal of lost fishing gear, and the implementation of best practice dredging methods.  

Designing Marine Protected Areas specifically to protect seabed habitats means that conservation 
measures  within  the  areas  are  tailored  to  the  relevant  habitats.  In  some  cases,  this  may  be  the 
banning of fishing in the area to prevent further damage to fragile organisms, and in others it may 
be the restoration or recovery of specific habitats. Although most MPAs reported under MSFD have 
been designated to protect specific habitats covered by the Habitats Directive, a few Member States 
(135)  report  protection  or  restoration  plans  of  seabed  habitats  not  covered  by  the  Habitats 
Directive.  

A number of measures focus on active habitat restoration (passive and active), e.g. restoration of 
oyster reefs, Saballeria reefs, Zostera beds and Posidonia meadows (136). These restoration measures 
improve not only the physical health of the seabed but also of the biological communities and species 
which these habitats support and the ecosystem services associated. One Member State (137) commits 
to restricting traditional gangui fishing over Posidonia beds as the gear damages the fragile plants. 

Most Member States have identified bottom-contacting fishing as the main threat to the health 
of seabed habitats in their waters. Some of these Member States subsequently  develop measures 
which aim to reduce the impact of current bottom-contact fishing levels or reduce levels in vulnerable 
areas. These measures include the implementation of best practices and promotion of selective gears, 
the  designation  of  new  MPAs  and  the  strengthening  of  existing  ones  with  measures  specifically 
restricting mobile  bottom fishing. In addition,  three Member States (138) explicitly  report measures 
which aim to reduce current levels of bottom-contact fishing throughout national waters, 
without the use of spatially-limited protection. 

(133) BE, EE, FI, FR, IT, LT, PL, RO, SE and SI 
(134) FI and PL 
(135) BE (gravel beds), NL (soil beds), PL (Fucus and Fucellaria medows), SI (detritus beds) 
(136) NL, PL, BE, DE, SL, SE and FI 
(137) FR 
(138) PL, SE, and FR 

31 

 
 
Seven Member States (139) report measures which regulate and improve the way in which activities 
take place, ensuring that there is no lasting effect on the seabed. Threats such as lost fishing gear, 
which can cause ghost fishing and topographical change in the seabed structure,  can be removed 
through  efficient  schemes,  whilst  best  practice  guidelines  can  reduce  the  chances  of  fishing  gear 
being lost in the first place. Other examples include improved management and sustainable use of 
materials (dredging) and moratoriums on recreational fishing of vulnerable bottom-species. Four 
Mediterranean Member States report measures specific to anchoring which limit the area in which 
boats are permitted to anchor (140).  

Finally, a few Member States have identified certain blue economy developments as potential threats 
to seabed integrity, for example the installation of wind turbines or underwater cables and have 
introduced  mitigation  measures.  These  measures  include  preparing  and  implementing  minimum 
requirements  for  Environmental  Impact  Assessments,  to  be  submitted  before  blue  economy 
development (141) and the mapping of vulnerable seabed habitat types to avoid the installation of 
cables causing disturbance and damage (142). 

Good examples 

Protected areas for vulnerable seabed habitats are reported as measures across many Member States. These include 
Zostera beds, detritus beds and rocky reefs in Slovenia, Sabelleria reefs in Germany, and gravel beds in Belgium.  

Within these protected areas, damaging human activities such as bottom-gear fishing or the dropping of anchors will be 
restricted or banned to allow the passive regeneration of these fragile habitats. Within some protected areas, Member 
States also plan to implement active restoration. This includes reef reconstruction in Germany, and the recovery of Oyster 
beds in Belgium. This method is used when the habitat is degraded to a point at which simple passive recovery alone will 
not be sufficient. Once reinstated, these habitats will be protected to ensure they have the best chance of returning to their 
natural state. Member States often refer to best practice guidance which they intend to use and successful examples 
which will be followed. 

Measures which aim to alter the way in which certain practices are conducted are also often practical. Examples include 
the implementation of best environmental techniques for dredging in Finland, ensuring that in areas where trawling is 
permitted, it is conducted in a way which has the least impact on the seabed environment.  

Another example is a reduction in the trawl-swept areas in Sweden through the promotion of low impact and selective 
gears. These selective gears are often in the best interest of the fishermen, as it reduces the rate at which bycatch species 
are caught, which cost them time and money. The encouragement of their use is therefore good for the economy, and for 
the seabed environment.   

Contribution to achieving GES 

Some progress has been made for D6 since the first cycle, in particular with regard to measures 
aimed at reducing the harm caused by mobile bottom-contact fishing methods. An area in which less 
improvement has been seen is the identification of pressures impacting the biological health of the 
seabed.  

GES  threshold  values  for  D6  were  adopted  only  in  2023,  too  late  for  their  integration  into  the 
programmes of measures assessed. In some cases, Member States (143) mentioned that they were 
awaiting the thresholds in order to design effective measures. Regarding progress towards GES, 

(139) PL, SE, SI, BE, FI, FR, and IT 
(140) CY, IT, FR and SI 
(141) EE 
(142) BE 
(143) NL and PL 

32 

 
 
seven Member States do not provide an update for D6, with one Member State reporting that there 
is  not  enough  data  to  determine  the  status  of  seabed  habitats  (144),  and  the  remaining  six  not 
providing a detailed current status update within their gap analyses (145). Nine Member States provide 
an update on status for D6: GES has been met for D6 in one case (146); in three cases (147), GES has 
been  partially  met  (e.g.  met  in  some  habitats  but  not  others  or  met  for  physical  loss  but  not 
disturbance); and in six cases (148), GES has not been met overall for D6. Only four Member States 
(149) have provided and adequate gap analysis, with the remaining Member States often reporting 
overarching and non-specific D6 measures as a result of inefficient identification of gaps in progress. 

Only  two  Member  States  (150)  reported  an  exception  under  D6.  Exceptions  reported  were  justified 
mainly by action or inaction for which the Member State is not responsible. In addition, the Member 
States reported an exception justified by natural conditions and one by economic or social activities 
fulfilling specific obligations of public services.   

Restoring food webs 

In  the  updates  of  their  programme  of  measures  few  Member  States  reported  modified  or  new 
measures addressing food webs. 19% of all measures cover D4 – food webs but when looking at 
measures that cover  only D4, this falls to only 1%. As for D1, all pressures can also be indirectly 
linked  to  food  web  health.  Often,  the  measures  reported  under  D1  and  D6  are  also  reported  as 
relevant to D4 by proxy, as biodiversity, seabed integrity, and food web health are intrinsically linked. 
D4-specific measures are much rarer. 

The  most  commonly  addressed  pressures  by  measures  under D4  are  physical  disturbance  and 
loss  of the  seabed,  biological  disturbance of  species  and  extraction  of  species. All these 
pressures have an impact on the health of the local food web by affecting the populations making 
up each trophic level, and therefore the web in its entirety.  

There are very few examples of practical direct measures under D4. Most measures reported 
for food web health are those which aimed at biodiversity in general. These include the designation 
or expansion of protected areas, or species-specific measures such as the mapping of bird migration 
routes.  Whilst  these  measures  to  preserve  populations  of  vulnerable  species  are  important  for 
maintaining populations and thus the local food web, the overall impact on food webs can be more 
indirect.  

Measures which directly address the imbalance of food webs focus on extraction and disturbance 
of entire trophic guilds to ensure that all guilds are sufficiently healthy not to impact their position 
in the trophic levels. A large proportion of commercially and recreationally targeted fish hold a high 
trophic  level  as  these  tend  to  be  the  larger  (and  therefore  more  commercially  valuable)  animals. 
Removing these species from the food chain will have sometimes irreparable effects on the species 
lower down the food chain and on the habitat.  

Measures directly relevant to D4 therefore include measures targeting commercial fishing, for 
instance  by  restricting  fisheries  at  a  certain  trophic  level  (e.g.  of  predatory  fish  or  forage  fish), 
restricting fisheries of commonly fished species to ensure the health of their trophic level (151), or 

(144) FI 
(145) CY, DE, ES, PT FR, and IT 
(146) EE 
(147) NL, SI, and IE 
(148) LT, LV, PL, SE, SI and BE 
(149) LV, PL, DE and EE 
(150) FR and PL 
(151) IT and FI 

33 

 
 
reducing fishing levels overall (152). Measures which reinstate or improve fish migratory routes are 
also directly relevant to food web health as they allow populations of migratory fish to continue (153). 
Certain species-disturbing activities, such as tourism or offshore constructions, can be also so 
disturbing that some species will flee the area, therefore impacting the balance of local food webs. 
Very few measures have been adopted to address this in the context of D4, however, and the only 
clear examples identified have been reported under D1, e.g. regulation of tourist recreational activities 
within protected areas (154). 

Good examples 

One  measure  from  Finland  aims  to  collaborate  with  other  Baltic  regions  to  promote  the  health  of  predatory  fish 
populations  through  fisheries  management.  As  the  largest  and  most  energy  expensive  organisms  in  the  food  chain, 
predators are key to ensure that populations of prey species remain controlled and are also not easily compensated for 
by the remainder of the food web. Therefore, their protection will allow the top of the food chain to remain stable.  

In Italy one measure implements a Moratorium on recreational fisheries for specimens of high conservation value species. 
This measure directly reduces the extraction of these species, such as red cernia, which is a predatory species and therefore 
is also valuable in the local food chain. 

In Estonia one measure aims to reduce the number of fishing gear licenses issued to fishermen in Estonian maritime areas 
in order to reduce fishing efforts to a level that possible under GES. The measure aims to reduce the amount of fishing 
gears at use in Estonian waters whilst considering and reducing any possible socio-economic impacts. 

Contribution to achieving GES 

No  noticeable  progress  has  been  made  for  D4  since  the  first  cycle  with  regard  to  the 
contribution of the measures to GES achievement. Food web health remains a consequence of actions 
aimed at species and seabed integrity. As a result, gap analyses for D4 are infrequent and often GES 
for food web health has not been defined by the Member State, meaning no assessment of current 
status can be made.  

Only two Member States (155)  reported  an exception under D4. Most of the exceptions referred to 
action or inaction for which the Member State is not responsible; only one exception referred to natural 
conditions  but  the  Member  State  did  not  provide  enough  information  to  justify  it,  including  an 
approximate timeline for GES.   

3.1.6  Replenishing fish and shellfish populations 

16% of all measures reported by Member States in their updated programmes of measures relate to 
D3  –  commercial  fish  and  shellfish.  Logically,  fishing  is  consistently  identified  as  the  main 
activity causing the pressure for D3.  

All Member States addressed the relevant pressure – extraction of, or mortality/injury to, wild species 
(by commercial and recreational fishing and other activities), to some degree. Not all stocks and 
sources relevant to this pressure, however, are covered across programmes of measures, 
in particular in relation to the coverage of both CFP-managed stocks and local/nationally-managed 
stocks and fishing pressure from both commercial and recreational fisheries. 

(152) SE, FR, EE and PL 
(153) EE, BE, Pl and LT 
(154) FR 
(155) FR and LT 

34 

 
 
The management measures implemented through the Common Fisheries Policy aim to ensure that 
commercial fish and shellfish populations are exploited at levels which are sustainable over the long-
term.  Almost  all  Member  States  have  incorporated  CFP-related  measures  into  their 
programmes  of  measures  (156).  Some  have  done  this  at  a  high  level  (i.e.  CFP  and  associated 
regulations are reported as a single measure), others have reported specific regulations as individual 
measures  (e.g.  updated  Technical  Measures  Regulation,  EMFAF  regulation  and  multi-annual 
management  plans  for  particular  species).  A  number  of  Member  States  have  also  incorporated 
existing  national  regulations  for  fisheries  into their  programmes  of measures  (157),  and  some 
have specific measures directed at local or inshore stocks (158). This provides confidence that local or 
nationally-managed stocks are also addressed.   

A  few  Member  States  also  identify  other  pressures  relevant  to  D3.  For  example:  one  Member 
State (159) identifies eutrophication as potentially affecting the recovery of the Baltic cod, and another 
(160) identified eutrophication and physical disturbance of the seabed as relevant pressures and has 
identified measures to address water quality, beach construction and dredging, which are relevant to 
the coastal and migratory stocks in its waters. 

While D3 builds on the CFP and its key concept of maximum sustainable yield (MSY), it also goes 
further by requiring that these populations also include older and bigger animals. In general, Member 
States’  measures  in  their  updated  programmes  of  measures  focus  on  reducing  the  fishing 
mortality  rate  and  increase  the  spawning  stock  biomass,  rather  than  on  improving 
population  age/size  distribution.    Eight  Member  States  (161)  defined  measures  to  address 
age/size distribution to some extent, for example (updating) minimum size regulations, measures 
to reduce the catch of juvenile fish, regulations to promote more selective fishing, and updates to 
mesh  size  and  configuration  in  gillnets  and  trawl  codends.  For  the  Member  States  that  used 
population  age/size  distribution  to  define  GES,  some  include  measures  specifically  focussed  on 
improving  age/size  structure  (162),  whereas  others  do  not  (163).  Not  all  details  of  measures  were 
available, however, e.g. the content of local management plans has not been assessed, and these 
may include management that addresses this issue.  

(156) Member States that did not clearly report CFP as a measure were: LT, LV 
(157) CY, DE, FI, FR, IE, IT, SE 
(158) BE, DE, ES, FI, FR, IE, IT, SE 
(159) PL 
(160) FI 
(161) ES, IE, FI, SE, EE, BE, RO, CY 
(162) BE, FI, EE, RO, CY 
(163) DE, IT, LT, SI 

35 

 
 
Good examples 

Ireland  reported  existing  measures  to  manage  local  stocks  including:  support  sustainable  inshore  stocks;  effort 
management for crab fisheries; effort management of scallop fishing; and protection measures for shellfish species. 

Italy reported existing measures covering local stocks and recreational fishing including: local management plans for 
management units; management of bivalve molluscs fisheries; management of sport and recreational fisheries; and an 
additional MSFD specific measure for a moratorium on recreational fishing of specimens of high conservation value 
species such as groupers and cob, by recreational and non-professional underwater fishing activities. 

Sweden introduced a new measure to ‘Promote a sustainable size distribution of coastal fish communities to retain 
important ecological functions in the food web’. 

Romania has an existing measure to implement control requirements on turbot nets used in the fisheries sector (material, 
mesh size and thickness). 

France introduced new measures in the second cycle specifically focussed on management of local stocks and controlling 
recreational  fishing  pressure.  In  addition,  France  updated  its  environmental  targets  so  that  they  focus  on  reducing 
pressures (adjust fishing mortality, adapt catches) with the aim of moving towards GES. 

Contribution to achieving GES 

The majority of the Member States have made limited or no progress with the programmes 
of  measures  for  D3  (164).  Three  countries  (165)  have  made  some  progress,  and  only  two  (166)  are 
considered to have made good progress. 

Six Member States reported an exception for D3 (167). Exceptions reported are justified in different 
ways, e.g. natural conditions, Member State not responsible, action needed by another Member State 
or by non-EU states (all of which are considered appropriate for D3 (168)). 

3.1.7  Mitigating invasive alien species 

Only 10% of all measures reported by Member States in their updated  programmes of measures 
relate to D2 – non-indigenous species (NIS), however the ratio between measures addressing several 
descriptors and measures addressing only D2 is high (over 50%) meaning that many D2 measures 
are measures focused only on the issue of NIS. In addition, on average across all Member States, D2 
is the only biodiversity descriptor that achieves a ‘good’ adequacy score (169).   

Member States consistently identified the two key pathways of NIS introductions, namely shipping 
(ballast water and hull fouling) and aquaculture. Nearly all of the Member States reference Regulation 
(EU) No 1143/2014 (Prevention and management of the introduction and spread of invasive alien 

(164) FR, IE, FI, SE, EE, BE, RO, CY, NL, DE, IT. Some countries have made some progress (EE, FI, BE), and only a few are 
considered to have made good progress (FR, SE). 
165 EE, FI, BE 
166 FR, SE 
(167) FI, LT, PL, RO, SE, SI 
168 While RO used the exception justification 14(1)(d) 'economic or social activities fulfilling specific obligations of public 
services' which is not fully appropriate, their justification ('Given that the commercial stock is divided across the marine 
region or subregion, the achievement of the GES for Descriptor 3 depends on the mode of action of all Black Sea states') is 
more in line with exception 14(1)(a) 'action or inaction for which the member state is not responsible'. A reporting error is 
therefore suspected.  
(169) Although less than half of the Member States’ assessments for D2 were concluded as being ‘good’ or ‘very good’, 
some of these ‘good’ or ‘very good’ assessments received high scores; in addition many MS were assessed as ‘moderate’, 
very few ‘poor’ and none ‘very poor’. On average, therefore, the total score for the D2 assessments is the only one that 
reached the threshold of 60, which is the boundary between a ‘moderate’ and ‘good’ level of adequacy. 

36 

 
 
species) in their programmes of measures in relation to D2 (170) and/or Regulation (EC) No. 708/2007 
concerning the use of alien and locally absent species in aquaculture (171).  

Shipping is widely recognised by the Member States as the main pathway of introduction, and 
most Member States have in place measures relating to the implementation of the IMO Ballast Water 
Convention. A few Member States from the Mediterranean (172) have made specific reference to the 
challenges  brought  by  the  Suez  Canal,  a  major  source  of  introduction  of  non-indigenous  species. 
Managing biofouling on ship’s hulls was addressed by some Member States (173).  

Aquaculture  is  another  activity  which  carries  risks  when  it  comes  to  NIS  introductions  and  the 
development of aquaculture activities (174) could increase levels of intentional introductions of NIS for 
aquaculture purposes and unintentional introductions via ‘hitchhiking’ species. The 2021 European 
Commission’s  Guidelines  for  Sustainable  Aquaculture  refers  to  the  need  to  ensure  that 
mitigation measures are in place in line of EU environmental legislation (including MSFD) to ensure 
that  ‘aquaculture  activities  do  not  significantly  harm  ecosystems  or  biodiversity’,  with  a  specific 
reference to Regulations (EC) 708/2007 and 1143/2014, and encouraging the set-up of ‘management 
practices [for] the prevention of escapees […] including their potential for becoming invasive’ (175).  

Mitigation of this risk is largely through existing regulations mentioned above. Some Member States 
have  taken  additional  measures,  including  early  detection  through  monitoring  in  hotspots 
including aquaculture areas (176). 

Other pathways of introduction, such as recreational boating, angling, and accidental releases, 
were identified by some Member States and corresponding measures have been implemented. For 
example,  some  Member  States  (177)  addressed  hull  fouling  on  recreational  vessels  by 
implementing the IMO biofouling recommendations or creating guidance and regulatory frameworks 
for managing biofouling on recreational vessels. Another Member State (178) implemented an action 
plan to reduce the risk of introduction and spread of invasive alien species transported by 
recreational  boating  and  watercraft  activities.  Other  examples  include  measures  which  provide 
training and raise awareness of mitigating against NIS introductions with the recreational  boating 
and angling sector (179).  

One Member State (180) also recognised the potential role that offshore structures such as wind 
farms  might  play  as  stepping-stones  for  NIS  spread,  however,  no  mitigation  measures  were 
implemented. With the increase in offshore structures being planned, such as offshore wind farms, 
this could be an important future pathway to consider.  

Early warning systems which rely on frequent monitoring/surveillance along with an alert system 
and  appropriate  plan  to  respond  to  introductions  are  crucial  for  the  rapid  detection  of  NIS  and 

(170) For example, NE, EE, SE, SI 
(171) For example, DE, IE, SE 
(172) CY, SI 
(173) for example BE, IT and PL  
(174) E.g. European Green Deal, Farm to Fork Strategy, Sustainable Blue Economy Policy, etc.  
(175) Communication from the Commission, Strategic guidelines for a more sustainable and competitive EU aquaculture for 
the period 2021 to 2030, COM/2021/236 final 
(176) ES, PT,  
(177) DE, LV and SE 
(178) IE 
(179) ES and LT 
(180) BE 

37 

 
 
increasing the chances of eradication. Several Member States (181) set out measures to implement 
early warning systems.  

Finally, some Member States have adapted measures under existing instruments to prevent new 
introductions from water pathways (182).  

Good examples 

Poland is implementing a measure relating to educating aquarists and anglers about the dangers of NIS releases.  

Ireland is implementing an ‘Invasive Alien Species Recreational Boating and Watercraft Pathways Action Plan’.   

Estonia is yet to implement a measure regarding early warning systems, but is investigating the use of environmental 
DNA techniques as a potential early warning system. This is an emerging technique which has the potential to detect NIS 
introductions from water samples. However, it requires further testing and may take some time to become effective.  

Contribution to achieving GES 

Measures in the second programmes of measures have generally filled gaps which were identified in 
the  first  cycle  and  progress  has  been  made  in  setting  and  implementing  appropriate 
measures aimed at achieving GES for D2. GES was described as being achieved in some countries 
(183) but maintaining it remains a challenge given the need for international cooperation to reduce NIS 
introductions.  Some Member States (184), particularly those with territorial waters within the Baltic 
Sea or Mediterranean Sea, identified such a need for international cooperation.   

Many Member States only report against the primary criterion for D2 (D2C1 “Non-indigenous species 
introduced by human activities are at levels that do not adversely alter the ecosystems”). A small 
proportion  of  Member  States  report  against  both  the  primary  and  secondary  criterion  (D2C2  and 
D2C3) (185). 

Four Member States (186) apply for an exception for D2. Exceptions reported were justified, in different 
ways, mainly action needed by another Member State or by non-EU states, natural conditions and 
natural causes.   

3.1.8  Limiting permanent alterations to hydrographical conditions  

D7 is linked to pressures that can permanently change physical characteristics of the water column 
(e.g.  currents,  waves,  temperature,  salinity,  depth  etc.)  and  affect  marine  ecosystems,  including 
benthic habitats and the species that depend upon these habitats. Climate change is also a powerful 
driver of such changes. These pressures are mainly caused by large infrastructure projects (e.g. dams, 
costal works, dredging, aggregates extraction, windfarms etc.) and projects and activities, both marine 
and terrestrial that can change energy fluxes, flows, freshwater supply, salinity directly or indirectly 
(e.g.  wind  and  other  atmospheric  parameters).  Such  permanent  alterations  are  likely  to  affect 
ecosystem mainly in coastal and shallow areas. 

(181) DE, ES, IT, LT, LV and SI 
(182) E.g. the Invasive alien species recreational boating and watercraft pathways action plan by IE; measure to address 
ballast sediment from ships to avoid further input and spread of non-indigenous species by SE. 
(183) For example IE, NL 
(184) For example, EE, SI 
(185) DK, EE, ES, LT, RO and SI  
(186) CY, LT, PL and RO 

38 

 
 
8% of all measures reported by the Member States in their updated programmes of measures relate 
to D7. It is the least well covered descriptor of all, however, overall, measures for D7 have a moderate-
to-high level of adequacy.  

The  main  measures  to  control  the  pressures  related  to  D7  are  linked  to  the  River  Basin 
Management Plans for terrestrial and coastal projects (e.g. by controlling the flow of fresh water or 
sediment from rivers), and to strategic environmental assessment (SEA) and environmental 
impact assessment (EIA) requirements for all projects and activities, which is adequate provided 
that impact assessment regulations actually refer to the achievement of GES for D7 as a frame of 
reference for the assessments. As several causes can influence hydrographical conditions, Maritime 
Spatial  Planning,  coupled  to  modelling  and  SEA,  is  a  strong  instrument  to  address  cumulative 
permanent alterations of hydrographical conditions linked to projects and activities and to climate 
change.   

While most Member States adequately report regulation of authorisations through EIA procedures, 
only a few elaborate on their relevance to achieve GES for D7. Only some Member States (187) took 
benefit  of  rules  laid  out  in  the  Maritime  Spatial  Planning  Directive  (Directive  2014/89/EU)  to 
assess  and  control  cumulative  effects  that  could  lead  to  permanent  alteration  of  hydrographical 
conditions. Also, only a part of them adequately refer to the RBMPs (188). Only a few Member States 
(189)  explicitly  based  their  programmes  of  measures  update  on  an  inclusive  baseline  scenario  or 
forward-looking vision of the development of large-scale activities such as windfarms and marine 
aquaculture which are supported by EU policies, although this is the best way to identify and quantify 
future pressures to be addressed. 

At regional level, some NEA Member States have reported that OSPAR has provided significant support 
to implementation of MSFD for D7 by providing a common approach and recommendations. However, 
cross-border and regional coordination is still weak. 

Good examples 

In its gap analysis, Belgium adequately identifies existing pressures or future pressures, including windfarms, energy atoll, 
sand extraction, dredging, and coastal defense projects. Based on these scenarios, Belgium reports possible gaps, including 
gaps in addressing relevant pressures individually or cumulatively, and in addressing these pressures at planning level 
(Strategic Environmental  Assessment  of  the  Belgian maritime  spatial plan  (190)). To address these gaps, Belgium has 
defined a measure intended to develop a methodology for the assessment of cumulative impact. 

In its gap analysis, even if GES for D7 is reported as achieved, Finland explains whether and how future socio-economic 
developments are taken into account to determine future environmental pressures. Finland has carried out an assessment 
of future activities likely to cause pressures linked to hydrographical changes; this assessment duly takes into account the 
likely influence of climate change.   

Contribution to achieving GES 

Only  a  few  Member  States  (191)  have  made  progress  in  addressing  the  topic  of 
hydrographical  conditions:  GES  is  still  often  not  determined  at  criteria  level  and  the  status  of 
marine areas against GES is not or partially assessed. As a result, most gap analyses are not sufficient 

(187) E.g. BE, SE and ES 
(188) E.g. DE 
(189) E.g. BE and NL 
(190) https://www.health.belgium.be/en/marine-spatial-plan  
(191) SE, BE, NL, FI and EE 

39 

 
 
to define adequate measures to limit pressures and ultimately achieve GES for D7. Environmental 
targets are often too vague, not clearly linked to pressures and not operational enough to effectively 
guide towards achieving or maintaining GES. Finally, even when the extent of pressures is adequately 
addressed, the link with potentially harmed habitats is weakly addressed.  

One Member State (192) has reported one exception under Art. 14, justified by overriding public interest. 
Achieving GES would require destruction of major infrastructures that are deemed necessary to public 
services. In this case ad hoc mitigation measures have been planned. 

3.3  Tackling the climate crisis 

2023 was the warmest year ever recorded in many parts of the North Hemisphere (193). 
As a result, the Atlantic Ocean has been warmer than average across most of its basins, 
especially in Europe (194). The European Climate Risk Assessment report (195) confirms that 

all European seas are heavily affected by climate risks and anthropogenic pressures.  

The ocean  plays a  key role  in  climate  regulation. Scientific evidence shows the ability of the 
ocean to be our ally in the fight against climate change. In particular, the ocean has taken up more 
than 90% of the excess heat in the climate system and has absorbed 20-30% of total anthropogenic 
CO2  emissions  since  the  1980s  causing  further  ocean  acidification  (196).  This  capacity,  however,  is 
threatened by increased greenhouse gas emissions. The latest Intergovernmental Panel on Climate 
Change (IPCC) report on the ocean and cryosphere in a changing climate (197) indicates that the ocean 
is warming, acidifying and suffering from deoxygenation. The growing trajectory of this ‘deadly 
trio’ changes oceanographic conditions and will reduce the ocean’s ability to absorb carbon dioxide 
and preserve life on the planet. 

It is therefore necessary to act and take measures to support this ocean-climate nexus. In particular, 
the ocean can contribute to climate change mitigation by  

•  Preserving  the  capacity  of  the  oceans  to  act  as  carbon  sinks.  This  carbon  sequestration 

capacity is ensured by healthy coastal and marine ecosystems.  

•  Reducing greenhouse gases emissions by developing ocean renewable energies and greening 

blue economy sectors. 

The  European  Green  Deal  (198)  boosted  actions  to  make  the  European  Union  climate  neutral  by 
2050.  

In addition, short-term actions to adapt to the effects of climate change and reduce stressors in 
particular on marine ecosystems are essential. The EU has a Strategy on Adaptation to Climate 
Change (199) that sets out how it can adapt to the unavoidable impacts of climate change and become 
climate resilient by 2050. Biodiversity policies are also known to contribute to climate adaptation. For 
example, the Biodiversity Strategy to 2030 aims to strengthen climate adaptation objectives (through 
the  protection,  restoration  and  resilience  of  ecosystems).  Horizon  Europe,  notably  through  the  EU 
Missions  ‘Restore  our  Ocean  and  Waters  by  2030’  and  ‘Adaptation  to  Climate  Change’, 

(192) PL 
(193) State of the Global Climate 2023  
(194) The European heatwave of July 2023 in a longer-term context | Copernicus  
(195) European Climate Risk Assessment — European Environment Agency (europa.eu)  
(196) IPCC Special Report on the Ocean and Cryosphere in a Changing Climate  
(197) AR6 Synthesis Report: Climate Change 2023 — IPCC  
(198) The European Green Deal - European Commission (europa.eu)  
(199) EUR-Lex - 52021DC0082 - EN - EUR-Lex (europa.eu)  

40 

 
 
provides  funding  for  scientific  research  on  the  ocean  and  climate  nexus,  thus  strengthening  the 
European and global scientific capacity to better understand the drivers of change in the oceans and 
to tackle emerging threats.  

The  link  between  ocean  and  climate  is  also  now  an  integral  part  of  international  climate 
agreements. Since the Paris Agreement (200), the ocean has been mentioned several times in climate 
agreements and recognised as playing a key role in the global climate system. The last development 
was during COP28, where the role of a healthy ocean was recognised as one of the best defences 
against climate change.  

Addressing climate change through the MSFD 

To  date,  climate  change  is  not  explicitly  addressed  by  the  MSFD  as  it  is  not  covered  by  a 
descriptor  nor  listed  as  a  pressure.  The  achievement  of  GES  for  many  descriptors,  however,  is 
influenced  by  climate  change  and  the  Directive  mentions  that  in  order  to  address  “the  impact  of 
climate change, it is essential to recognise that the determination of good environmental status may 
have to be adapted over time” (201). Moreover, the holistic marine strategies provide a good framework 
to  monitor  climate  change  impacts  and  explore  climate  change  mitigation.  This  approach  was 
confirmed by the assessment made for the previous cycle, where Member States have highlighted 
that  the  impacts  caused  by  climate  change  and  ocean  acidification  are  important  transboundary 
issues that are addressed through MSFD monitoring programmes (202). 

As climate change is of concern for all marine regions and is a pressure on the marine environment, 
a number of Member States now consider climate change as a frontline issue and some of 
them include measures related to the matter. These measures can be:  

•  Mitigation measures i.e involving all the processes that human activities can use to reduce 
and prevent emission of greenhouse gases, such as the development of renewable energy, 
reducing emissions from maritime transport, protecting and restoring blue carbon ecosystems 
to sequester carbon, etc.; 

•  Measures  addressing  adaptation  and  resilience,  the  former  consisting  in  all  actions 
undertaken  to  reduce  climate  change  impacts  (e.g.  building  flood  systems,  adapting 
construction to face heatwaves or extreme cold temperatures) and the latter relating to the 
way communities prepare themselves to address and recover from future deteriorations. 

In the second programmes of measures, 15 of the 17 Member States assessed have included 
measures related to climate change: 

-  84  measures,  accounting for  4%  of  the  total  number  of measures,  are  directly  related  to 
climate change: the largest number was recorded in Spain, with 25 measures (11% of the 
total number of measures in that country), followed by Slovenia (13 measures, 14% of the 
total) followed by Portugal and Ireland (with 7 measures, respectively 13% and 5% of the 
total); 

-  Most  climate  change  related  measures  concern  adaptation  or  resilience  (60  including  22 
related with the key types of measures (KTM) under the WFD “Climate change adaptation” 
out  of  84),  one  third  is  related  to  mitigation  (22  measures)  and  two  are  related  to  both 
adaptation and mitigation (Figure 12). 

(200) https://unfccc.int/sites/default/files/english_paris_agreement.pdf ( 
(201) See recital 14, Article 3.4 and 3.5of Directive 2008/56/EC 
(202) Report on the implementation of the Marine Strategy Framework Directive (europa.eu) 

41 

 
 
 
Figure 12. Measures related to climate change 

Some important measures stem from the Regional Sea Conventions programmes or are linked to 
them  (203),  others  already  inserted  in  their  national  Climate  Action  Plans  or  National  Adaptation 
Strategies (204). Some of the Member States also include measures related to strategy for their coasts 
(205). Finally, two of the 17 Member States of which programmes of measures were assessed still do 
not have clear measures relating to the climate change in their programme of measures (206). 

Examples of measures related to climate change mitigation:  

Blue carbon ecosystem protection - Spain is quantifiyng the CO2 capture service by seagrass meadows and macroalgae forests. This 
work should contribute to identify the most vulnerable grasslands and forests and thus evaluate projects that may threaten these 
communities or to propose conservation projects, mitigation and restoration of climate change in Spanish waters. 

Offshore wind and renewable energy - Portugal is drawing up of the Public Initiative Allocation Plan for Offshore Renewable Energy 
(PAER). The plan applied the ecosystem-based approach to maritime spatial planning in order to define the areas dedicated to the 
development of offshore wind farm while protecting marine ecosystems and habitats. France will set up the National Offshore Wind 
Observatory to disseminate existing studies and data on offshore wind power and to share the knowledge. 

Greening shipping - Spain will make an analysis the impacts of liner ferries possibility in view of a possible adjustment of the frequency 
of inter-island ferries to the real demand. This option would have the purpose of reducing the potential impact on cetacean populations 
in these areas and reducing greenhouse gas emissions into the atmosphere.   

Examples of measures related to adaptation and resilience:  

Study/assessment impact of climate change – Latvia is carrying out an assessment of the effectiveness of the measures taken to 
protect seals, taking into account trends in seal populations as well as the impact of climate change on the marine environment.  

Flood  protection  –  Finland  is  implementing  nature-based  solutions  to  reduce  flood  impacts  in  river  basin  districts.  Slovenia  is 
implementing measures to prevent adverse effects of flood events on important nature protection habitats. 

In addition to taking measures to address climate change, Member States were also asked to take 
into account climate change concerns in the design of their second programmes of measures and in 

(203) IE, SE, EE, CY, SL  
(204) PL, IE, SE, CY, FI, ES, FR 
(205) ES, CY, PT, DE 
(206) NL and LT 

42 

 
 
 
the selection of measures. Out of 17 Member States assessed, only two (207) did not include climate 
change considerations in the design of their programmes. Several Member States (208) have adopted 
clear methodologies to integrate climate change considerations in the selection and design 
of measures, while others take climate change impacts into account but without a clear explanation 
of how this supports the selection and design of MSFD measures.   

In relation to climate adaptation, a few Member States (209) explicitly describe how their measures 
contribute to their national adaptation strategies. In some cases (210), some or all MSFD measures 
are embedded in national adaptation strategies, in other cases, links to actual strategies are unclear 
but the contribution of MSFD measures to climate adaptation and to building resilience of marine 
ecosystems is recognised (211). The importance of flexibility and responsiveness of MSFD measures 
to future climate conditions is also highlighted (212).  

In  relation  to  climate  mitigation,  only  a  few  Member  States  (213)  demonstrate  that  they  have 
considered  the  impact  of  MSFD  measures  on  greenhouse  gas  (GHG)  emissions,  for  instance  by 
mentioning the potential of some measures to contribute to carbon storage (214), assessing 
the measures’ impacts on GHG emissions (215) or by recognising the importance of marine and coastal 
habitats as carbon sinks (216). 

This assessment shows that some Member States have not taken climate change into account when 
drawing up their programme of measures but have taken adaptation or mitigation measures against 
climate change. 

Good examples 

Noteworthy practices include Germany’s  "climate check" to ensure future measure effectiveness, Estonia inclusion of a 
study to assess climate change impacts, and Slovenia’s emphasis on habitat protection. These examples highlight proactive 
steps taken by some countries to integrate climate change considerations into their marine strategies comprehensively. 

Ireland included the National Climate Action Plan as a measure to make sure that marine considerations were included in 
its development. In the country, the public consultation process specifically addressed how the impact of climate change 
could be considered in the programmes of measures.  

Cyprus  recognition  of  climate  change  as a  cross-cutting issue and Portugal  emphasis  on the  key  role  of  the MSFD  in 
addressing climate change and pollution underline the multifaceted approach needed to tackle environmental challenges 
effectively. 

(207) FR and RO 
(208) e.g. EE, DE, SE, SI 
(209) DE, PT, SE. 
(210) DE, PT, SE 
(211) ES 
(212) DE, SE 
(213) DE, FI, SE, SI. 
(214) DE, SE 
(215) FI 
(216) SI 

43 

 
 
 
4. Regional coherence  

4.1  Regional cooperation & cooperation on transboundary 

measures 

The MSFD requires EU Member States to use existing institutional cooperation structures 
such as the Regional Sea Conventions (RSCs) to implement the marine strategies in the 
most coherent way at the regional level. Member States reported that their programme 
of measures was a result of a cooperation with neighbouring countries through bi- (217) or 

trilateral (218) meetings or through joint work in RSCs.  

Although relatively few measures have been reported as adopted under the framework of the RSCs 
(14% of the total measures reported), regional cooperation, organised within RSCs has played 
a  significant  part  in this  second-cycle reporting  exercise. All 17 Member States referred in 
their programmes of measures to the relevant RSC that they are signatories to. Coordinated work 
under these RSCs that are related to the development of national second programme of measures 
for the MSFD has also been highlighted. This was demonstrated strongly by Member States that 
are signatories to HELCOM (219). These Member States explained how their participation in HELCOM 
meetings and working groups and the Baltic Sea Action Plan (BSAP) (220) influenced the development 
of their second programme of measures. In addition, the Sufficiency of Measures analysis (221) helped 
many Baltic Member States with their gap analysis and selection of additional measures in the second 
cycle. The use of this tool has led not only to a higher level of regional coherence but also to a higher 
level of quality of the measures put forward in these countries. Additionally, some Member States 
(222)  listed  actions  under  the  BSAP  that  are  linked  with  individual  new  measures  included  in  their 
second programme of measures.  

Member  States  that  are  Contracting  Parties  to  OSPAR  (223)  also  highlighted  how  regional 
cooperation  influenced  the  setting  of  environmental  targets/objectives,  measures 
selection and the overall development of their second programmes of measures. One Member State 
(224) reported that their measures for marine litter are influenced by the implementation of the second 
OSPAR  Regional  Action  Plan  for  Marine  Litter,  while  another  one  (225)  took  into  account  the 
OSPAR  Measures  and  Actions  Programme  in  the  development  of  their  second  programme  of 
measures.  Four  Member  States (226)  also  referred  to  regional  cooperation  through  UNEP-MAP 
(227). For example, one Member State (228) reported participation in several initiatives under UNEP-MAP 

(217) RO and BG (reported by RO) 
(218) FR, ES, PT (reported by the three countries); SE, FI, DK (reported by Sweden) 
(219) DE, FI, PL, SE, EE, LV, LT 
(220) Baltic Sea Action Plan – HELCOM 
(221) https://helcom.fi/baltic-sea-action-
plan/som/#:~:text=The%20aim%20of%20the%20sufficiency,GES)%20in%20the%20Baltic%20Sea.  
(222) E.g. EE and LT 
(223) BE, DE, ES, FR, IE, NL, PT and SE 
(224) IE 
(225) NL 
(226) ES, FR, CY and SI  
(227) IT also identified UNEP-MAP in their electronic reporting as relevant under “Policies and Conventions”, but did not 
further elaborate on this in their text report.  
(228) ES 

44 

 
 
to coordinate the implementation of the MSFD in the Mediterranean sea, while another (229) stated 
that their second programmes of measures are aligned with the requirements of UNEP-MAP.  

The  analysis  indicated  that  eight  Member  States  (230)  declared  cooperation  with  their 
neighbouring Member States in the implementation of measures. Most cooperation seems to 
be happening in the Baltic Sea. However, inconsistencies and conflicting information were identified 
among the country reports. Sometimes the cooperation is only reported from one country but not by 
the other.  

Cooperation  between  neighbouring  countries  is  essential  in  jointly  addressing  many 
transboundary issues. Member States provided information on bilateral and multilateral cooperation 
and meetings with other countries to exchange information and coordinate on measures that 
require transboundary cooperation. For example, three Member States sharing waters (231) held 
trilateral meetings to identify common issues related to the management of protected areas, marine 
litter and underwater noise. Some Member States (232) explicitly named the authorities or bodies who 
participate in regional, bilateral and/or multilateral work in their text reports (233). Two Member States 
(234) also explicitly identified the authorities responsible for communicating transboundary impacts of 
measures to neighbouring Member States. The actual impact of transboundary measures remains, 
however, hard to estimate. 

(229) SI 
(230) DE, EE, ES, FI, FR, PT, RO, SE 
(231) FR, ES and PT 
(232) CY, FI, FR, RO, SE 
(233) Maritime Prefects in FR or Ministry of Environment and Water Management in RO 
(234) SE and SI 

45 

 
 
 
4.2  Regional coherence of measures 

4.2.1  North-East Atlantic 

Descriptor 

Pollution 

Coherence of 
programmes 
of measures 

Justification  

Eutrophication 
(D5) 

Moderate 
coherence 

Coherence of gap analyses  

• 
Only some Member States provide an overview of the current status of the marine environment in 
relation to D5: BE, DE and SE report that they have not achieved GES for D5 while PT reports that it 
has achieved GES already. Five Member States (BE, DE, ES, IE and SE)  provide a partial analysis of 
the gaps to achieve GES for D5. None of the Member States provide a detailed analysis of the 
activities causing nutrient pressures nor how current measures taken under other frameworks 
address these pressures. Only DE assesses the potential contribution of individual measures within 
the programmes of measures to the achievement of the GES. It is unclear for most Member States 
when GES might be achieved with a general lack of information on timelines for achieving GES. 

•  MSFD-specific measures vs other measures  
Overall, the Member States relied more on measures taken under other legislative/policy frameworks 
(68%) compared to MSFD-specific measures (32%) although this varied significantly between 
Member States (235). Out of 90 measures reported for D5, 40 were WFD measures and 6 Member 
States out of 8 refer to the WFD as a driver for their D5 measures. Other frameworks referred to by 
Member States for D5 include UWWTD and OSPAR. Less than half of the Member States mention 
MARPOL or existing legislative/policy frameworks relevant to controlling air emissions. Only BE, DE, 
ES and FR) reported new MSFD-specific measures, including measures to address airborne nutrient 
inputs, inputs from aquaculture and shipping, handling of fertiliser in ports and restoration of 
seagrass beds and tidal nature.  

Coverage of pressures and activities  

• 
Only DE and SE adequately covered all relevant pressures with their measures in this second cyle 
and BE and ES did so partially. 90% of the measures for D5 address the input of nutrient, 55% also 
address the input of organic matter and only 5% of measures address biological disturbance. Key 
activities related to D5 pressures identified by Member States include urban wastewater, agriculture, 

(235) For example, all of IE and NL’s measures were measures taken under other legislative/policy frameworks. 

46 

Use of exceptions in the region 

Three Member States out of eight applied 
for exception, FR, NL and SE. Two Member 
States, NL and FR, applied exceptions under 
Art. 14(4), both citing the disproportionate 
cost of reducing eutrophication.  

Two Member States, NL ands SE, applied 
exceptions under Art. 14(1)(e), justifying 
that the factors contributing to 
eutrophication are complex, making 
estimating any date for achieving GES 
highly speculative. In addition, one Member 
State, NL, also applies for exception under 
Art. 14(1)(a), that other Member States’ 
actions also influence eutrophication. 

 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

shipping, airborne emissions and urban run-off. DE also identifies aquaculture and handling of 
fertiliser at ports as activities giving rise to pressures that require management. 

Use of exceptions in the region 

Contaminants 
(D8) 

Moderate 
coherence 

Coherence of gap analyses 

Purpose and content of measures 

• 
Given that legislation and policy is well established in this area, the measures across Member States 
have a similar focus. There is evidence of further measures being brought forward, particularly in 
relation airborne emissions, ship emissions and nutrient inputs from agriculture and aquaculture. 
Some measures seeking to reduce the effects of eutrophication are also being implemented, for 
example, restoring tidal nature (BE) and restoring seagrass meadows (DE).   
• 
None of the Member States provided a clear and comprehensive gap analysis, all reported partial 
(BE, DE, IE, SE and NL) to poor (ES, FR and PT) information. The main gaps identified are in relation to 
Hg, Pb, PCBs and TBT. FR did not provide a quantitative gap analysis, although clear thresholds have 
been set for D8. BE, IE, NL, and SE provided an overview of the current status of contaminants, with 
IE reporting that it has achieved GES for D8. In the remaining Member States, although GES is not 
achieved for D8, some report progress for some substances, e.g. BE reports a positive trend for 
priority substances (EQS) and illegal discharges (GES ≥ 50%) and NL highlights that pollutant 
concentrations have been significantly reduced and are still decreasing or stable. NL highlights that 
for most substances GES is likely to be achieved in the period 2022-2028. However, for persistent 
substances it is still difficult to demonstrate the impact of the policy. SE notes that despite the 
reduction of some pollutants above the GES thresholds, the current rate of reduction will not be 
sufficient to achieve GES in the near future. No Member State analyse how first cycle and updated 
existing measures will reduce the pressures. No Member State clearly presented conclusions on 
future socio-economic development to determine future environmental pressures. Only DE indicates 
that MSFD-specific measures have been subject to an appropriate level of socio-economic impact 
assessment.  

•  MSFD-specific measures vs other measures  
All Member States reported measures falling under the WFD, all but PT and SE reported measures 
taken under OSPAR, all but ES and SE refer to MARPOL, ES, IE, PT, and SE refer to UWWTD and BE, 
DE, NL, and SE refer to the Bonn Agreement. BE, DE, ES, FR, IE refer to IMO International Convention 
on Oil Pollution Preparedness, Response and Co-operation while BE, DE, FR, and NL refer to 
International Convention on the Control of Harmful Anti-fouling Systems on Ships. Only DE and FR 
referred to the National Emissions Ceiling Directive. No Member States refer to the Zero Pollution 

47 

Four Member States out of eight applied 
for an exception: FR, NL, PT and SE. Among 
those Member States, coherence is 
considered as moderate. 

FR, NL and SE applied for exceptions under 
Art. 14(1)(e). The reasons given by these 
three Member States are linked: persistent 
contaminants are a long-term issue, and it 
can take many years for measures to be 
effective. PT applied for an exception under 
Art. 14(4) - 'No significant risk or 
disproportionate cost', however, it did not 
provide details to understand the spatial 
extent of contamination is and whether 
there are ongoing contaminant inputs that 
might delay recovery.  

FR additionally applied for exception under 
Art. 14(1)(a), reasoning that harmonised 
rules for the use of scrubbers in specific 
areas is the responsibility of the IMO and 
the EU and the adoption of Sulphur 
Emission Control Areas (SECA) is the 
responsibility of IMO. 

 
 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

targets. All of IE and NL’s measures and between 63-75% of measures in BE, DE, FR, PT and SE 
come from other legislative/policy frameworks. On the other hand, ES reported most measures as 
MSFD-specific.  DE, IE, PT and SE include measures from the 3rd RMPBs under the WFD. In no 
Member State in the region is the link between the measures and the gap analysis clear. 

Coverage of pressures and activities  

• 
All Member States in the region reported measures concerning input of nutrients and input of organic 
matter. All Member States except IE reported measures for input of synthetic and non-synthetic 
substances. BE, ES, IE, PT, SE also reported measures concerning contamination from ubiquitous, 
persistent, bioaccumulative and toxic (uPBT) substances and measures concerning acute pollution 
events. Only DE, ES, and SE reported measures related to the input of water-point sources (e.g. brine), 
while BE, ES, IE, and SE reported measures concerning adverse effects on species or habitats. It is 
worth noting that Member States reported a large number of pressures not specifically related to D8 
(contamination in seafood (ES, IE, SE), eutrophication (BE, ES, IE, PT, SE) and newly introduced non-
indigenous species (BE, ES, SE), as well as various physical and biological pressures. There is 
moderate coherence in the activities identified by Member States in the region. BE, ES, FR, SE and DE 
linked their measures to most activities relevant to D8, while PT and IE focused on a smaller number 
of activities. MSFD-specific measures in BE, DE, SE focus on anti-fouling, while ES, FR, and SE focus 
on recreational activities. DE and SE tackle underwater munitions, BE shipwrecks, ES and FR cover 
dredging, SE addresses contaminated sediment and DE takes measures related to mining. 
Aquaculture is tackled by BE and DE, and DE, FR, and SE focus on shipping. ES and FR refer to 
scrubbers. NL takes measures referring to PFAS, ES to oiled fauna, BE to fishing lead, DE to 
sunscreen, and FR has a number of measures focused on education and raising awareness. 

Purpose and content of measures  

• 
The types of measures reported by Member States are moderately coherent, although it is noted 
that neither IE nor NL reported the purpose of measures in the electronic reporting, and BE and DE 
did not do so for a significant share of measures. The other Member States took direct measures to 
prevent further inputs of a pressure (e.g. by managing the source activity), BE, DE, ES and SE took 
direct measures to reduce existing levels of the pressure (e.g. removal of litter or oil spill clean-up) 
and all except PT took measures to indirectly prevent further inputs of a pressure (e.g. by governance 
mechanisms, financial incentives, awareness campaigns). DE, ES, FR, SE, PT also took measures to 
improve the knowledge based and/or establish monitoring programmes. Only SE reported measures 

48 

 
 
 
Use of exceptions in the region 

No Member State applied for an exception. 

Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Contaminants in 
seafood (D9) 

Poor 
coherence 

Coherence of gap analyses 

to assess the effectiveness of measures and PT reported a measure to directly restore a species or 
habitat.   
• 
BE, IE and NL did not carry out a gap analysis because they assess that GES is currently achieved in 
their waters for D9 and should continue to be without the need for further measures. The other 
Member States reported either a partial gap analysis (DE, SE) or insufficient information on the main 
elements of the gap analysis (ES, FR, PT). Half of the Member States provide clear information on the 
current status of contaminants in seafood (BE, IE, NL, SE). In addition to the three Member States 
concluding that GES is currently achieved for D9, SE indicates that GES is achieved for contaminants 
in food in the North Sea. DE reports on GES for D8 in the North Sea, but not for D9. For the remaining 
Member States, the current status is not known (ES, FR, PT). No Member State provides information 
on the extent to which current measures will reduce pressures. In most Member States it is unclear 
whether the baseline used to inform the gap analysis takes into account future development activity, 
considers alternative scenarios or indicates the extent to which socio-economic factors have been 
taken into account. In addition, no Member State provides information on the effectiveness of the 
measures. All Member States fail to report on a timeline for achieving GES. 

•  MSFD-specific measures vs other measures  
Looking at all measures reported under D9, 75% of them fall under other legislative/policy 
frameworks. While FR, IE and SE relied heavily on measures under other legislative/policy frameworks 
(90% of their measures), BE relied mostly on MSFD-specific measures (85% of their measures). DE, 
ES, NL and PL defined a balanced mix of already existing and MSFD-specific measures. The most 
common reference to an existing framework is obviously the Regulation setting maximum levels for 
certain contaminants in foodstuffs (BE, ES, FR, IE, NL and PT). The WFD is also reported as relevant to 
D9 by ES, FR, IE, PT and SE, and the UWWTD by PT and SE. ES and PT link to the MSP Directive. Only 
DE and FR link their measures to OSPAR and SE links D9 measures to many additional frameworks 
related to pollution (e.g. REACH, Stockholm Convention, etc.) Even if gaps were not clearly identified in 
any Member State, DE, ES, FR, IE and SE modified MSFD-specific measures from the first cycle or 
defined additional ones in the second cycle. This includes one measure to improve data collection on 
contaminants in fishing products and for the proposal of new contaminants (ES) and the other to 
raise awareness among boaters on the issue of managing discharges from offshore pleasure craft 
(FR). It is noted that most MS report that they have either achieved GES or are close to doing so – 
this would explain the lack of additional/modified measures (moderate coherence). 

49 

 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

Coverage of pressures and activities  

• 
All Member States except BE address the D9-specific pressure of ‘Contaminants in seafood’. Other 
pressures linked to D9 measures directly overlap with D8: ‘Input of other substances (e.g. synthetic 
substances, non-synthetic substances, radionuclides)’ (DE, ES, FR, NL, PT, SE), ‘Input of organic matter’ 
(ES, FR, IE, PT, SE) and ‘Input of nutrients’ (FR, SE). Of all the measures related to the pressure 
'Contaminants in seafood', 31% are linked to specific activities, in particular ‘Waste treatment and 
disposal’ (FR, SE), ‘Agriculture’ (IE, SE), ‘Military operations’ (DE, SE), ‘Research, survey and educational 
activities’ (FR, SE) and ‘Tourism and leisure activities’ (FR, SE). One Member State partially addresses 
the relevant pressures (SE) and three Member States insufficiently (DE, ES, FR). For the remaining 
Member States, no MSFD-specific measures for D9 were adopted in the second cycle, either because 
they do not correspond to relevant pressures (PT) or because GES for D9 is considered to be 
achieved in their waters (BE, IE, NL). 

Coherence of gap analyses 

Purpose and content of measures  

• 
Looking at both first and second cycle measures, only 58% of the measures for D9 are linked to a 
‘measure purpose’ (IE did not report a measure purpose for its D9 measures). Most of the measures 
reported will have an indirect impact on the pressures, either by indirectly preventing further inputs of 
a pressure (DE, FR), improving the knowledge base (DE, ES, PT) or establishing monitoring 
programmes (DE, ES, PT). Few measures aim at directly preventing further inputs of a pressure (SE 
only) or directly reducing existing levels of the pressure in the marine environment (DE, ES). 
• 
Almost all Member States (except PT) provide a clear overview of the current status of the marine 
environment in relation to D10, mainly focusing on beach litter as all acknowledge the lack of data 
for assessing other D10 criteria, but only DE and SE elaborate baseline scenarios against which 
alternative options are compared. Only half of Member States (SE, NL, BE and FR) provide an 
estimation of how much the first cycle measures will reduce pressures and the related measures 
needed in the second cycle. Only ES and BE clearly identify gaps to be addressed (microliter and litter 
from fishing) and only NL refers to socio-economic developments to determine future environmental 
pressures. No Member State provided a timeline for achieving GES. 

Two Member States out of eight (BE and 
SE) applied for exceptions, but under 
different Articles. BE applied under Art. 
14(1)(a), and SE under Art. 14(1)(e). BE’s 
exception however may be a reporting 
mistake (237). SE’s justification is that 80 % 
of litter found on its beaches are from other 
countries, with estimates that more time is 
therefore required to meet the threshold (4-
5 management cycles).  

Marine litter 
(D10) 

Moderate to 
high 
coherence 

(237) BE applied for an exception, with the reason of action caused by a third party for which the Member State is not responsible. However, the relevant pressure reported is: 'Loss of, or 
change to, natural biological communities due to cultivation of animal or plant species'', which is not relevant for D10. Moreover, the Exception name and justification reported state: 'no 
exception', which seems confusing. BE reported no exceptions for D10 in the first cycle. 

50 

 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

•  MSFD-specific measures vs other measures 
IE and SE mostly relied on measures taken under other legislative/policy frameworks for D10, while 
DE and ES mostly on MSFD-specific measures. The other four (FR, BE, NL and PT) adopted a 
balanced mix of already established and MSFD-specific measures. EU legislation (236) is a clear driver 
for defining measures. Additional measures from other frameworks mostly focused on tackling single 
plastic uses and fisheries-induced litter. All but two Member States (BE and FR) explicitly refer to the 
OSPAR Regional Action Plan on Marine Litter.  

Coverage of pressures and activities 

• 
All Member States in the region except IE have made progress during the second cycle in terms of 
pressure coverage. 47% of MSFD-specific measures aim at reducing the input of litter while 30% 
aim at reducing the pressure level in the environment. Of those that aim at reducing the input, 
however, only 20% are direct measures, managing the source activities and 40% are indirect, aiming 
at preventing further inputs of a pressure (e.g. by governance mechanisms, financial incentives, 
awareness campaigns). Almost 30% of measures are still dedicated to improving the knowledge 
base and therefore have no immediate effect on reducing marine litter. All Member States in the 
region report addressing the same group of activities with their D10 measures: fisheries, shipping, 
tourism and recreational activities, port operations, industry and urban areas. In addition, some 
Member States identify other sources at sea (e.g. offshore installations in DE), and on land (e.g. 
packaging in DE and NL, aquaculture in FR and DE) as main contributors to the litter problem and 
defined new measures to address them. 

Purpose and content of measures 

• 
As far as macrolitter is concerned, all Member States put their main focus on beach litter and less on 
seabed or water column litter. DE and ES specify that their cleaning actions should address litter in all 
areas, not only the beach, and NL defines different measures for different categories of litter (e.g. 
measures specifically dedicated to doly rope, balloons, plastic pellets). In total, 54 measures in five 
Member States (BE, NL, ES, DE and SE) address microlitter, targeting industry and urban areas as 
well as tourism/recreational activities and to a small degree fisheries (measures for better 
management of fishing gears). Some measures are directly aimed at reducing the input of the 
pressure (e.g. management of fishing gears), while the majority are aimed at reducing the pressure 
level (e.g. fishing for litter, beach and street clean-up activities).  

(236) Waste Framework Directive (BE, NL, FR, ES, SE and IE), Water Framework Directive (all except PT, SE and NL), Port Reception Facility Directive (all except FR), UWWTD (ES, FR and IE), 
Single Use Plastic Directive (all except FR and PT), Packaging Waste Directive (only NL and SE), Common Fishery Policy (DE, ES, FR, PT and SE). 

51 

 
 
Use of exceptions in the region 

No Member State applied for an exception. 

Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Underwater 
noise (D11) 

Moderate 
coherence 

Coherence of gap analyses 

• 
The information regarding the gap analysis varies a lot across the Member States in the region. BE is 
the only Member State that provides a complete gap analysis, identifying which additional measures 
are in place to address gaps. DE, IE and NL do not provide all information, but have, to some extent 
identified significant gaps to achieve targets and ultimately GES for D11. It is not clear whether ES, 
FR and SE have adequately addressed all significant gaps to achieve GES. For ES, a gap analysis 
was carried out focused mainly on progress against environmental targets. There is no information 
about the current GES status baseline scenario, consideration of how much current measures will 
reduce pressures, future socio-economic developments, or an indication of the timeline for when GES 
will be achieved. Similarly, FR carried out a gap analysis but with limited details and SE explained 
how the gap analysis was performed and how it was the basis for the selection of the new 
measures for the second cycle. PT does not provide a gap analysis for D11. 

•  MSFD-specific measures vs other measures  
Some Member States, such as DE, ES and FR, provide many links to various relevant existing policies 
for D11, while others only refer to a few. IE only refers to OSPAR and IMO and NL only to IMO. 
Overall, measures are aften linked to OSPAR (DE, ES, FR and IE), and IMO guidelines for reduction of 
underwater noise from commercial shipping (FR, NL, IE) and the Habitats and Birds Directive (ES, FR). 
Overall, the Member States relied both on measures taken under other legislative/policy frameworks 
and MSFD specific measures. While IE and NL defined only measures taken under other 
legislative/policy frameworks, the other Member States defined a mix of both types. As a result of 
the gap analysis, even if clear shortcomings were not identified in most Member States, all Member 
States except IE and NL modified MSFD-specific measures from the first cycle or defined additional 
ones in the second cycle to address the gap to achieve GES.   

Coverage of pressures and activities  

• 
All Member States in the region have made some progress during the second cycle in terms of 
pressure coverage. BE reinforced the first cycle measure to tackle the most prominent source of 
underwater noise in their water. DE updated its MSFD-specific measure by leveraging HELCOM 
recommendations to reduce the use of continuous and impulse sound. SE implemented guidelines 
for minimizing the risk of adverse effects to marine mammals from seismic surveys. PT addresses 
explicitly continuous noise but not impulsive noise. Its measures are still focused on improving the 
knowledge base. ES also sets out to increase their knowledge of the current state of underwater 
noise. Except for one measure generally addressing ‘industrial operations’, most of FR measures are 

52 

 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

‘soft measures’ aimed at raising awareness and knowledge. In terms of activities, all Member States 
address some relevant human activities causing both impulsive (defence operations (DE, SE, BE, ES, 
FR, NL), renewable energy (BE, DE, NL, SE, ES) and continuous noise (shipping (all MS), recreational 
activities (ES, FR), fishing (ES, FR). FR talks generally about ‘industrial operations’. 

Purpose and content of measures  

• 
Considering both first and second cycle reporting, around 35% of the measures are direct measures 
(aimed at directly reducing further input of the pressure or aimed at directly reduce existing levels of 
the pressure in the marine environment) and this is from all Member States except FR. The majority 
of the measures (60%) are indirect, including, around 34% of the measures dedicated to improving 
the knowledge base (from all Member States except IE and SE) and establishing monitoring 
programmes (DE, ES and PT). Continuous and impulsive sound are equally addressed by most 
Member States except PT, which only addresses continuous noise explicitly. DE and BE remain the 
only Member States to have defined specific measures to address other form of energy, including 
electromagnetic fields, light and heat (e.g. in DE application of threshold values for the introduction of 
heat and development and application of environmentally sound lighting of offshore installations; in 
BE, investigating the impact of electromagnetic fields on gravel beds and associated fauna). NL 
reported a measure to address light on oil and gas platforms in 2016, but it seems to have been 
dropped in the second cycle. 

Biodiversity 

Biodiversity (D1) 

Moderate to 
high 
coherence 

Coherence of gap analyses  

• 
A gap analysis was undertaken by almost all Member States in the region (BE, DE, ES, FR, IE, NL, 
SE).Almost all Member States provide a clear overview of the current status (BE, DE, FR (Bay of 
Biscay & Iberian Coast), IE, NL, SE), focusing on four feature groups (birds, mammals, fish and 
pelagic habitats) and identifying pressures and activities affecting the marine environment. Only DE 
elaborates a baseline scenario to use as a benchmark against which alternative options are 
compared and only FR presents an estimate of how much the first cycle measures will reduce 
pressures. BE, DE and FR consider future socio-economic development to determine future 
environmental pressures and present clear conclusions of the effectiveness of the measures. All 
Member States fail to report on a timeline for achieving GES. 

•  MSFD-specific measures vs other measures  
All Member States defined measures linked to the Habitats and Birds Directives. The CFP was also 
linked to biodiversity measures by all Member States, the MSP Directive by most (BE, DE, ES, IE, PT, 

Two Member States out of eight, FR and 
SE, applied for the same type of exception 
(Art.(1)(a) for Descriptor 1 but provide 
different justifications.  

Both Member States invoke the need to 
involve higher-level processes to adopt 
measures to protect biodiversity against 
fisheries impacts. FR mentions the 
processes of mapping Vulnerable Marine 
Ecosystems under the Deep-Sea Access 
Regulation and the joint adoption of 
technical measures applicable to all EU 
vessels under the Technical Measures 

53 

 
 
Use of exceptions in the region 

Regulation. SE considered that the GES for 
fish depends heavily on implementation of 
the EU Common Fisheries Policy (CFP).  

Descriptor 

Coherence of 
programmes 
of measures 

Justification  

SE) and OSPAR in a majority (DE, ES, FR, IE, NL, PT). Four Member States (DE, FR, IE, NL) mentioned 
the CBD but only two DE and FR have measures linked to the EU Biodiversity Strategy. Overall, most 
Member States (BE, DE, FR, PT, SE) defined a balanced mix of measures taken under other 
legislative/policy frameworks and MSFD-specific measures for D1. A few Member States (ES, IE, NL) 
relied more heavily on the former than the latter when drawing up their PoMs. MSFD-specific 
measures directly address the pressures in ES, FR and SE, and partially in DE, IE and NL (238).  

Coverage of pressures and activities  

• 
All Member states have recognised the need to address pressures on marine species and habitats 
and have made progress since the previous cycle. There is a general trend towards implementing 
spatial protection measures and targeting specific pressures like species disturbance (all Member 
States), fisheries (ES, FR, and DE), and bycatch (all but IE). All but one Member States (IE) defined 
measures addressing disturbance of species (e.g., where they breed, rest and feed) due to human 
presence, and all but two (NL, PT) defined measures addressing extraction of, or mortality/injury to, 
wild species by commercial and recreational fishing and other activities. DE, ES and FR reported 
measures targeting loss of, or change to, natural biological communities due to cultivation of animal 
or plant species. The primary activities causing pressures on marine biodiversity, including fish and 
shellfish harvesting, maritime transport, tourism and recreational pursuits, port operations, industrial 
processes, urban development and hunting, are broadly and effectively addressed by all Member 
States.  

Purpose and content of measures  

• 
Over half of the new MSFD-specific measures aim to directly reduce or prevent inputs of pressures, 
the rest focusing on monitoring, gaining knowledge, or assessing effectiveness of measures. BE, ES, 
PT, and SE report considerably more direct measures than other Member States and FR reports more 
indirect measures. IE reports only a small number of MSFD-specific measures, a few are dedicated to 
MPA legislation and management, and one is linked to the OSPAR North-East Atlantic Environment 
Strategy 2030. Around a third of the measures continues to focus on enriching the knowledge base, 
as reported by all Member States except IE and NL, with a notable number of such measures in FR 
and ES. Only ES, FR, and SE have dedicated measures to evaluate their effectiveness. In addition to 
the activities mentioned before, several Member States pinpoint additional sources at sea (e.g., 
offshore installations in DE) and on land (e.g., packaging in DE and NL; aquaculture in FR and DE) as 
significant contributors to biodiversity pressures, introducing new measures to tackle these 

(238) DE and IE do not cover all relevant pressures; PT use mostly indirect measures. 

54 

 
 
Use of exceptions in the region 

No Member State applied for an exception. 

Descriptor 

Coherence of 
programmes 
of measures 

Justification  

NIS (D2) 

Moderate 
coherence 

Coherence of gap analyses 

challenges. BE, NL and FR focus on fishing and development plans for specific species.  PT defines as 
main issues human activities such as tourism, recreational activities, and urban development. ES and 
SE cover different activities through monitoring, research and improving knowledge. IE mainly 
focuses on MPAs designation and OSPAR activities.  All Member States use spatial protection 
measures, but only BE, ES, PT, SE expand existing MPAs or create new ones.  
• 
A gap analysis was undertaken by all Member States in the region. Almost all Member States 
provide a clear overview of the current status (BE, DE, IE, NL, SE) mainly focusing on newly 
introduced NIS (D2C1) as information on established NIS and adverse effects is missing (only BE 
stated that two NIS could lead to changes in the ecosystem). All Member States except PT present 
pressures and activities causing NIS: shipping, aquaculture (BE, DE, ES, IE, NL, SE), recreational 
activities (IE and SE), offshore windfarms (BE) and release of species (FR and SE). The other elements 
of the gap analysis are less coherent. DE, SE and partially IE provide an estimation of how much the 
first cycle measures will reduce pressures, concluding on the need to define additional measures in 
the second cycle. While gaps are not clearly defined in most Member States, ES and DE clearly 
identify priorities for the second programmes of measures, including early warning system for NIS. 
The elements of the gap analysis that were more difficult to elaborate on are baseline scenarios and 
consideration of future socio-economic development to determine future environmental pressures 
(only presented by BE). Most importantly, all Member States fail to report on a timeline for achieving 
GES. 

•  MSFD-specific measures vs other measures  
All Member States except BE and DE refer to the Invasive Alien Species Regulation, FR, NL, PT and SE 
refer to the IMO Ballast Water Convention and DE, ES, FR and IE refer to OSPAR. Other EU legislation 
are also a clear driver for defining measures: Habitats Directive (ES, FR, BE IE and PT), regulation on 
the use of alien and locally absent species in aquaculture (DE, IE and SE), WFD (ES, FR and SE) and 
CFP (ES and FR). Member States relied to a different degree on measures taken under other 
frameworks. IE and NL only relied on measures taken under other frameworks while ES relied mostly 
on MSFD-specific measures. FR, BE, DE, PT and SE defined a balanced mix of already established 
measures and MSFD-specific. 39% of the measures are specific to D2, i.e. they specifically address 
the implementation of guidelines for biofouling, tackle invasive species (e.g. the proliferation of 
Rugulopteryx okamurae) or define early warning systems. These measures have addressed to a 
great extent the relevant pressures. The other measures (61%) are reported as being relevant to 
more than one descriptor (in particular they also cover D1, D10, D6 and D8). 

55 

 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

Coverage of pressures and activities  

• 
Half of the Member States in the region have made some progress during the second cycle in terms 
of pressure coverage (SE, BE, NL, DE). DE and SE adequately address all pressures with their new 
measures in the second cycle, while FR, ES, BE and PT) do this only partially. IE and NL do not report 
any MSFD-specific new measures for D2. Relevant activities are targeted by most Member States: 
shipping for both ballast water and hull fouling (BE, DE, ES, IE, NL and SE) and aquaculture (All 
Member States except NL). In addition, other Member States identify other pathways of NIS 
introduction: recreational boating (IE and SE), offshore windfarms (BE) and release of species (FR and 
SE).  

Coherence of gap analyses 

Purpose and content of measures  

• 
There are more MSFD-specific measures aimed at reducing the input of NIS (68% from BE, DE, ES, 
FR, and SE), than measures aimed at reducing the pressure level in the environment (13% from ES, 
FR and SE). In addition, of those that aim at reducing the input, 46% of the measures are direct 
measures, managing the source activities and 54% are indirect measures aiming at preventing 
further inputs of a pressure (e.g. by governance mechanisms, financial incentives, awareness 
campaigns). A high proportion of measures is still dedicated to improving the knowledge base (19% 
- defined by ES, FR, PT and SE). BE, DE, ES and SE defined measures aimed at establishing 
monitoring programmes and only SE defined measures aimed at assessing their effectiveness. FR 
and SE are the only Member States that established measures aimed at restoring habitats. 
• 
A gap analysis was undertaken by all Member States in the region. Most provided a clear overview of 
the current status (BE, DE, IE, NL, SE) mainly focusing on the status of the different commercially 
fished stocks. Across multiple Member States it is acknowledged that GES for D3 has not been fully 
achieved (BE, DE, ES, FR, NL, PT). Although some stocks were showing ‘good status’ or improving 
trends (BE, IE, NL, SE), most stocks in the NEA region remain ‘not good’ and ‘poor’ status (BE, DE, IE, 
NL, PT). All Member States identified the main pressure as extraction of fish and shellfish species, 
resulting from fishing activities. The other elements of the gap analysis are less coherently presented. 
Five Member States partially provided an estimate of how much first cycle measures reduced 
pressures (BE, DE, ES, NL, SE) concluding on the need for additional measures (ES, BE, FR) or 
strengthening implementation of first cycle measures (DE, NL, SE). The following priorities were 
identfied for D3 measure updates: recreational fisheries (ES, FR), control of artisanal fishing (ES), 
locally-managed stocks (FR) and collection of data for dogfish, sharks and rays (BE).  The elements 
of the gap analysis that were less well elaborated were baseline scenarios (only presented by BE 

56 

Only SE applied for an exception, under Art. 
14(1)(a), with the reason that SE is not 
responsible for all the measures that would 
need to be taken. Good environmental 
status for commercially exploited fish and 
shellfish is highly dependent on the 
implementation of the EU Common 
Fisheries Policy (CFP) and that regulation 
taking into account the objectives of the 
MSFD. This means that SE cannot, on its 
own, influence whether different fish 
species meet the set thresholds.  

Commercial fish 
and shellfish 
(D3) 

Moderate 
coherence 

 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

and partially by IE) and consideration of future socio-economic development (only presented by BE). 
Most importantly, all Member States failed to report on a timeline for achieving GES. NL stated that 
existing policies are adequate to achieve GES in the coming years, however it did not provide a clear 
timeframe for this. 

•  MSFD-specific measures vs other measures  
All Member States linked their D3 measures to the CFP. Some Member States reported only the main 
CFP regulation (Regulation (EU) No 1380/2013) as a measure (e.g. DE, PT, NL), while others reported 
additional regulations (multi-annual plans, Technical Measures Regulation, EMFAF, DCF) (e.g. BE, SE, 
FR, IE, ES). ES and PT also specifically referred to regulations from ICCAT. FR, IE and PT mostly relied 
on measures taken under other frameworks for D3, while ES and SE on MSFD-specific measures. BE 
and DE defined a mix of already established measures and MSFD-specific. NL only relied on already 
established measures.  

Coverage of pressures and activities  

• 
Only FR and SE adequately address all pressures with the new measures in the second cycle, while 
BE, DE and ES did this only partially. NL and PT did not report any new measures specific for D3 and 
new measures reported by IE are considered to be cross-cutting to all descriptors. Logically, all 
Member States identify fishing as the main activity causing the pressure for D3 and all have 
measures that address commercial fishing activity but only some explicitly address recreational 
fishing (ES, BE, FR, SE). In addition, some Member States identified other relevant activities for the 
health of fish and shellfish populations, such as tourism (ES and SE), aquaculture (ES, IE, SE), 
agriculture (ES, SE), extraction of minerals (BE, ES and SE), renewable energy generation (ES, SE) and 
research (ES, IE) and defined new measures to address them (e.g. to minimise tourism impact, SE 
report a measure on the protection of the habitat of specific species). 

Purpose and content of measures  

• 
In total 165 measures address the extraction of species by Member States in the region, 37 
measures (22.4%) are directly aimed at reducing the input of the pressure (e.g. by implementing the 
CFP, enforcing technical measures, introducing fisheries resources management plans and enhancing 
control over commercial fishing activities) and at reducing the pressure level (e.g. promoting the 
collection of lost fishing gear and ensuring compliance with discard policies). Increasing monitoring 
efforts is covered by 10 measures from BE, ES and SE; and raising awareness by 50 measures 
(34%) from BE, DE, ES, FR, PT and SE. Most Member States in the region cover also nationally/locally 
managed stocks (ES, BE, DE FR, IE and SE). It is unclear whether this is the case for PT and NL. 23 

57 

 
Use of exceptions in the region 

Only FR has reported exceptions for 
Descriptor 4 under Art. 14(1)(a), reasoning 
that fishing of fodder species is covered 
under the Common Fisheries Policy (CFP). 
As France is not solely responsible for the 
CFP, the European Commission must 
ensure that actions are being taken to meet 
this objective under the CFP and that fodder 
species are being protected. 

Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Foodwebs (D4) 

Poor 
coherence 

measures explicitly mention ‘recreational fisheries’ from BE, ES, FR, IE and SE, ranging from 
regulating recreational fishing, in particular for sea bass (FR), improving fishing gear regulations (SE), 
implementing monitoring systems (BE). Most Member States do not have specific measures for “age 
and size distribution” (D3C3). Measures on this include “Promote a sustainable size distribution of 
coastal fish communities to retain important ecological functions in the food web” but lack practical 
details on implementation (SE). 
• 
Coherence of gap analyses 
None of the Member States in the region has carried out an adequate gap analysis for food webs.  
FR, IE, and SE have done so only partially and BE, NL and PT have not done any. Information for DE 
and ES is unclear. Assessment of current status is patchy: IE simply reports status as ‘unknown’, while 
SE limits discussion to the size structure of different fish communities.  DE concludes that food webs 
are not in good condition but reports that owing to a lack of methods for assessing food webs, it is 
not possible to provide a large amount of detail.  ES does not include discussion of food webs in its 
gap analyses. Only IE, SE, and DE discuss pressures on food webs, with IE reporting commercial and 
non-commercial fishing as the main pressure, and the associated damage to benthic habitats.  Clear 
conclusions of the effectiveness of the measures are reported by FR, DE, and SE. Baseline scenarios 
have been prepared by DE and FR whose analysis also considered future socio-economic 
development. DE also attempts to provide an indication of a timeline for achieving GES, but it is 
vague. 

•  MSFD-specific measures vs other measures  
All Member States linked their D4 measures to other legislative/policy frameworks, in particular the 
Habitats and Birds Directives (all Member States), the WFD (DE, FR, IE, NL, and SE) and the CFP (DE, 
ES, FR, IE, and SE).  Links to OSPAR are also made by all Member States apart from BE while only DE 
and FR mentioned the Biodiversity Strategy. Five Member States (BE, DE, ES, PT, and SE) defined 
MSFD-specific measures for D4.  

Coverage of pressures and activities  

• 
Only ES, FR, and SE have successfully addressed previously identified pressures.  IE and PT are 
considered as partially addressing pressures and information for BE and DE is not clear. NL has not 
reported new measures for D4 in the second cycle. The main pressures addressed by Member States’ 
measures are species extraction and disturbance, introduction of invasive species, input of sound and 
disturbance of seabed habitats.  Only BE, DE, and SE address all of these.  Extraction of species (i.e. 
fishing) is addressed by all Member States and disturbance of species by all except NL. NL and PT 
also address input of sound and PT also physical disturbance of the seabed. The main activities 

58 

 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

addressed by measures are extraction of species, restructuring of habitats, aquaculture, production 
of energy, transport, extraction of non-living resources and research. DE, ES, BE, FR, and SE address 
all these activities.  NL does not mention activities at all, and IE and PT only a few. 

Coherence of gap analyses 

Purpose and content of measures  

• 
Birds, mammals, benthic habitats and ecosystems are addressed by all Member States and DE, ES 
and FR also address fish, cephalopods and hydrological characteristics.  D4 food webs specifically 
links to pelagic habitats, and only NL fails to address this in its measures. BE, DE, ES, and SE report 
developing new MPAs, covering both D4 and D1, and FR and PT also take MPA-related measures for 
D4. Several Member States (DE, ES, FR, IE, SE) reported fisheries-related measures including 
addressing monitoring of fisheries, bycatch, or the reduction of fishing gear loss. Slightly fewer than 
one third of the measures aim to reduce or prevent inputs of pressures – the rest relate to 
monitoring, gaining knowledge, or assessing effectiveness of measures.  BE and SE report 
considerably more direct measures, FR more indirect measures, and DE and ES about the same. 
• 
A gap analysis was carried out for D6 by BE, DE, FR, IE, NL and SE, while only partially by ES and PT. 
Only a few Member States provide a detailed overview of the current status of the seabed (BE, DE 
and NL). SE, IE and FR only provide partial overviews of the status of seabed integrity. ES and PT do 
not provide an overall view of the current state of the seabed. DE, BE, FR and NL identify significant 
gaps in achieving GES for D6, whilst gaps are only partially identified by SE and IE, and not identified 
at all by ES and PT. Most of the Member States present pressures affecting seabed integrity (FR, NL, 
SE, BE, DE, ES, and IE), i.e. physical disturbance and physical loss (with biological disturbance and 
species extraction also reported frequently), however, only DE and IE assign a main contributing 
human activity to these pressures (bottom-gear fishing and dredging). PT does not identify pressures 
or activities affecting seabed integrity. DE discusses the extent to which measures could reduce 
relevant pressures and only provides a vague estimate of the timeline for the expected impact of 
these measures. FR provides information on the potential for measures to impact pressures, however 
the pressures reported are more relevant to D1 than D6. BE and SE outline clearly how planned 
measures will reduce relevant pressures. Only BE and DE consider future socio-economic 
development to determine future environmental pressures. Only DE provides conclusions on the 
effectiveness of the measures in achieving GES and identifies significant gaps in achieving GES 
(partially identified by BE, IE, NL, SE, and not at all by ES and PT). All Member States fail to report on 
a timeline for achieving GES. 

59 

FR is the only Member State to apply for an 
exception under Art. 14(1)(a). FR reasons 
that action is required from the European 
Commission for the measures to be 
implemented, which is out of the control of 
the Member State. FR argues that the 
European Commission must undertake the 
necessary mapping of VMEs under the 
deep-sea fisheries regulation using Member 
State data.  

Seabed habitats 
(D6) 

Moderate 
coherence 

 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

•  MSFD-specific measures vs other measures  
All Member States link their D6 measures to the Habitats and Birds Directives, all except BE link to 
the CFP and all but FR and NL mention the MSP Directive. Only DE, IE and NL link to the EIA Directive. 
The CBD is mentioned by half of the Member States (DE, FR, IE, NL). All Member States except BE 
link their PoM to OSPAR. Overall, considering both first and second cycle measures, IE and NL mostly 
relied on measures taken under other legislative/policy frameworks for D6, while ES, PT and SE on 
MSFD-specific measures. The others (BE, DE and FR) defined a balanced mix of already established 
measures and MSFD-specific. As a result of the gap analysis, even if clear shortcomings were not 
identified in most Member States, all of them modified measures from the first cycle or defined 
additional ones in the second cycle. New measures cover the training of fishermen to manage 
negative impacts in PT, national species protection plans in NL, and the coordination of the HELCOM 
Joint Action plan and OSPAR NE Atlantic Strategy and the regulation of water management under 
the Water Framework Directive in SE. 

Coverage of pressures and activities  

• 
The technical adequacy assessment concluded that only SE and ES adequately addressed all 
pressures while BE and DE only partially covered the relevant pressures. NL, FR, PT and IE 
insufficiently covered the two essential pressures. The main pressures affecting seabed habitats 
include both physical loss (addressed by 108 measures) and physical disturbance of the seabed 
(addressed by 132 measures). However, less than half of all measures reported for D6 in the North-
East Atlantic are linked to these pressures. Overall, most D6 measures overlap with descriptors D1 
and D4, indicating a general approach rather than specificity to the essential pressures affecting 
seabed integrity. Only 39% of measures for D6 are tied to activities that cause these two essential 
pressures on seabed integrity (and ES and PT do not report any activity). The most common activity 
causing physical loss and disturbance of the seabed is bottom trawl fishing, and the other most 
common activities are seabed mining and dredging. BE, DE, ES, FR and SE have made progress in 
improving the coverage of D6 pressures in the second cycle. Strong progress is seen particularly in FR 
while IE and PT seem to have stagnated.  

Purpose and content of measures  

• 
Looking at both first and second cycle reporting, BE, DE, ES, IE, PT and SE report more measures that 
prevent further inputs of the pressure than measures aimed at directly reducing its existing level in 
the environment (only ES) or measures directly restoring a species or habitats (only BE, DE, ES and 
SE). However, of those that aim at reducing the input, only 48% of the measures are direct 

60 

 
 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

No Member State applied for an exception. 

Coherence of gap analyses 

measures, managing the source activities; 52% are indirect measures aiming at preventing further 
inputs of a pressure (e.g. by governance mechanisms, financial incentives, awareness campaigns). 
Additionally, a few measures are dedicated to improving the knowledge base (BE, DE, ES, PT and SE), 
establishing monitoring programmes (SE only) and assessing measure effectiveness (SE only). Most 
Member States rely on spatial protection and MPA measures to reduce both physical loss and 
disturbance of sensitive seabed habitats, with all Member States in the region reporting new spatial 
protection measures in the second cycle apart from PT and IE. These measures range from designing 
and implementing new protected areas (SE, DE, FR, BBE), to improving and enlarging the scope of 
existing protection (NL). PT does not report any new spatial protection measures at all and IE reports 
measures for the development of a framework which can be used to designate protected areas.  
• 
Almost all Member States reported a gap analysis for D7 (BE, DE, ES, IE, NL, SE). A majority of 
Member States provide an overview of the current status (BE, DE, IE, NL, SE), all of which note there 
are no changes since the first cycle (BE) or that GES is achieved (DE, IE, NL, SE). Activities and 
pressures, such as offshore structures, dredging, and coastal developments, are explicitly mentioned 
in the assessments of the majority Member States (BE, IE, NL, PT, SE), and all Member States that 
have performed gap analyses for D7 mention (large scale) human activities as having an effect on 
hydrography. Most Member States estimate how much measures taken under other legislative/policy 
frameworks will reduce pressures. Some of these measures are seen as sufficient to reach GES (BE, 
NL, SE), while for other Member States they are not (DE, ES, PT). France, despite not having a gap 
analysis for D7, included a qualitative appraisal of the contribution of the measures taken under 
other legislative/policy towards GES. None of the Member States report a baseline, nor consider 
future socio-economic development to determine future environmental pressures, even for EU policy-
based activities such as renewable energy and aquaculture, and when reference is made to marine 
plans under MSP. Clear conclusions on the effectiveness of the measures are given by most of the 
Member States. Some of them state that there are no changes for this descriptor (BE), or that GES is 
achieved (DE, IE, NL, SE). The Member States for which GES was not achieved do not give a timeline 
for when it would be achieved. No common forward vision has been reported for future activities and 
pressures that could hamper achievement of GES for D7 by causing permanent alteration in 
hydrological conditions. 

•  MSFD-specific measures vs other measures  
Some Member States (FR, PT) report multiple links to various existing policies, while some Member 
States (BE, IE, NL, SE) assign few specific measures to D7.  The legislation most cited is the WFD (DE, 

61 

Hydrographical 
changes (D7) 

Poor 
coherence 

 
 
Descriptor 

Coherence of 
programmes 
of measures 

Justification  

Use of exceptions in the region 

ES, FR, PT, SE), followed by the Habitat Directive (DE, FR, PT) and UWWTD (FR). The MSP (ES, PT, SE) 
was cited, without reference to regional cooperation under this Directive; Member States also cited 
the Birds Directive (DE) and the EIA Directive (DE, NL). Only IE and ES cited OSPAR for D7. Considering 
the measures taken under other legislative/policy frameworks and MSFD-specific measures, half of 
the Member States defined a balanced mix of both (DE, ES, FR, PT), whereas IE and NL relied more 
on other frameworks, and BE and SE more on MSFD-specific measures.  

Coverage of pressures and activities  

• 
Almost all Member States report MSFD-specific measures (BE, DE, ES, FR, PT). Almost all Member 
States report measures that address a D7-related pressure, which is related to reducing the level of 
impact on hydrographical changes (BE, DE, ES, IE, PT, SE). According to the adequacy assessment, 
however, none of the Member States comprehensively cover all pressures. BE and NL are the only 
Member States that show progress since the first programme of measures (BE did not have any 
measures for D7 in 2016, and NL improved by taking into account future impacts). Activities 
targeted by the measures include sand management (BE, DE, ES, FR), reducing turbidity (BE, DE), the 
consideration of freshwater supply needs (FR), and a monitoring study on the conditions of the state 
of the sea and marine currents (PT). 

Purpose and content of measures  

• 
Considering both first and second cycle reporting, about half of the measures aim at reducing the 
input of pressures, of which the majority addresses the pressures directly (DE, ES, FR, SE), and only a 
few measures do so indirectly (BE, DE, ES). A majority of the measures aim at improving the 
knowledge base, for example by conducting research (DE, FR, ES, PT, SE). There is a clear trend 
towards improving the knowledge base and management of physical disturbances to the seabed 
and hydrographical changes. However, the content and focus of the measures vary significantly, 
ranging from an impact assessment methodology in BE to targeted measures addressing salinity 
changes in FR and PT, and sediment management in FR, ES, and DE.  

62 

 
 
 
 
 
 
4.2.2  Baltic 

Coherence of 
Programmes of 
measures 

Justification  

Descriptor 

Pollution 

Eutrophication 
(D5) 

High to moderate 
coherence 

Coherence of gap analyses 

• 
All Member States have provided an overall coherent analysis of pressures and impacts 
drawing on information prepared for the Baltic Sea Action Plan (BSAP).  HELCOM has facilitated 
co-operation to undertake detailed modelling of nutrient pressures and estimate the potential 
nutrient reductions required to achieve GES in different parts of the Baltic Sea. All Member 
States provide an overview of current status. GES for D5 is not met by any Member State.  The 
main activities giving rise to nutrient pressures are well understood. While the BSAP analysis 
takes account of measures that have been implemented, it does not take account of updates 
to RBMPs under WFD.  Member States have generally sought to analyse the impact of such 
measures qualitatively. The baseline scenario contained within the BSAP modelling work (and 
used by all Member States) reflects the situation as of 2030 taking account of known trends, 
looking at how nutrient pressures might change over time as a result of development activities. 
Some Member States have explicitly recognised future pressures in their gap analysis (EE, FI, 
LT, LV PL) but others have not (DE, SE). Only FI has indicated that it has sought to take account 
of climate change.  All Member States have indicated broad timelines for achieving GES for D5. 
It is likely to be many decades before GES can be achieved in all Member State waters and 
only if all relevant parties take the necessary action to further reduce nutrient inputs by 
significant amounts. 

•  MSFD-specific measures vs other measures  
All Member States refer to the WFD, HELCOM and the Nitrates Directive (except EE and LV). 
25% of the measures reported for D5 in the region are WFD measures. Half of the Member 
States refer to MARPOL but few Member States refer to legislation and policy relating to 
airborne emissions (Industrial Emissions Directive (FI, SE), National Emissions Ceiling Directive 
(DE, FI, SE)). Only FI and SE refer to the UWWTD and only LV mentions the Zero Pollution 
targets. The Member States rely slightly more on measures taken under other frameworks 
(60%) compared to MSFD-specific measures (40%) although this varies significantly between 
Member States. In EE and SE around 90% are measures taken under other frameworks, while 
in PL around 90% are MSFD-specific measures. All Member States apart from SE report new 
MSFD-related measures: the 41 new MSFD-specific measures reported address airborne 
nutrient inputs, inputs from aquaculture and shipping, handling of fertiliser in ports, reducing 

63 

Use of exceptions in the region 

Five Member States out of seven applied for 
exceptions, all under Art. 14(1)(e) (EE, FI, LT, 
PL and SE). All five Member States provided 
the same reason for exception: that there is a 
long time lag for measures to reduce 
eutrophication to have effect, and GES is only 
likely to be achieved in the long term. EE 
additionally mentions the effects of climate 
change on eutrophication, and SE states that 
it is not responsible for the measures needing 
to be taken. LT provides a very limited 
justification unrelated to D5 which could be a 
reporting error. Applying for an exception is 
probably justified also for LT.  

PL additionally applied for an exception under 
Art. 14(1)(a), with the reason that 
eutrophication is an issue requiring action 
from other Member States. 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

impact of food production and consumption, sustainable use of wastewater sludge and 
removal of dead plant biomass as well as a range of actions to better understand nutrient 
sources and pressures.  

Coverage of pressures and activities  

• 
The coverage of pressures and activities is assessed as adequate for DE, FI and SE and 
partially adequate for the other Member States. Of the more than 200 measures relevant to 
D5, over 90% of the measures address the pressure input of nutrients. Approximately 50% of 
the measures also address input of organic matter. The sources of nutrient pressures are 
generally well understood and already addressed through existing legislation. Key activities 
related to D5 pressures identified by Member States include urban wastewater, agriculture, 
shipping, airborne emissions and urban run-off. Some Member States also identify aquaculture 
(DE, FI) and handling of fertiliser at ports (DE, FI, PL) as activities giving rise to pressures that 
require management. 

Coherence of gap analyses 

Purpose and content of measures  

• 
Around 40% of the measures aim to directly prevent or reduce nutrient pressures and a further 
40% to indirectly reduce pressures. Around 10% of measures aim to improve knowledge. Given 
that legislation and policy are well established in this area, the measures across Member 
States have a similar focus. There is evidence of additional measures being brought forward, 
particularly in relation to airborne emissions, ship emissions and nutrient inputs from 
aquaculture. Some measures seeking to reduce the effects of eutrophication are also being 
implemented, for example removal of dead plant biomass from the marine environment (FI 
and LT).   
• 
Member States’ gap analyses have benefitted from regional modelling and work within 
HELCOM for the Baltic Sea Action Plan. This work assessed a number of substances including 
mercury, TBT, PFOS and diclofenac in the Baltic Sea. However, only FI provided a complete gap 
analysis, the remaining Member States have only partially covered the different elements of 
the gap analysis. All Member States provide an overview of the current status drawing on the 
BSAP modelling study. The most recurrent substances identified as not meeting GES are Hg, 
mercury, PBDEs, PFOS and TBT. PL and SE note that, despite the reduction of some pollutants 
above the GES thresholds, the current rate of reduction will not be sufficient to achieve GES in 
the near future. EE, FI, LT, LV and PL have provided information on the pressures and their 
impact on the achievement of GES, with FI even indicated how pressures have changed over 

64 

Five out of seven Member States applied for 
exceptions  under  Art.  14(1)(e):  EE,  FI,  LT,  PL, 
and  SE.  Although  the  specific  substances 
mentioned  are  not  always  the  same,  the 
reason given by all five Member States is that 
it  takes  a  long  time  for  the  concentration  of 
existing substances to reduce. 

LT applied for an exception under Art. 14(1)(e), 
however, since it was noted that the issue of 
contaminants  cannot  be  addressed  by  LT 

Contaminants 
(D8) 

Moderate 
coherence 

 
 
Use of exceptions in the region 

alone, the basis for the exception should have 
rather be Art. 14(1)(a). PL additionally applied 
for  an  exception under Art.  14(1)(a),  with  the 
reason  that  actions  by  PL  may  not  be 
sufficient, and responsibility for the necessary 
measures  should  be  shared  by  emitting 
countries.  

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

time. No Member State provides information on the activities causing the pressures, nor 
analyse how first cycle and updated existing measures will reduce the pressures. EE, LT and LV 
elaborate on baseline scenarios reflecting the situation in 2030. No Member States clearly 
presented conclusions on future socio-economic development to determine future 
environmental pressures. Similarly, no Member State clearly presented conclusions on the 
effectiveness of measures. Nevertheless, gaps are identified for all Member States, indicating a 
range of high concentrations of persistent substances. Only FI reports on a timeline for 
achieving GES. FI points out that PBDEs may not be in good condition by 2027, as they are 
persistent in the environment and there are largely no external sources of loading. 

•  MSFD-specific measures vs other measures  
All Member States report measures falling under the WFD and HELCOM. Measures relating to 
MARPOL and the IMO Convention on Oil Pollution Preparedness are reported by DE, EE, FI, LT, 
PL, and the convention on ships anti-fouling is covered by DE, FI, LT, and LV. On the other hand, 
UWWTD is only covered by FI, LT, and SE, and REACH and PRF by DE, FI, and SE, which are the 
only three countries to mention legislative/policy frameworks relevant to combatting air 
pollution (Industrial Emissions Directive, CLRTAP). Only LV has referred to the Zero Pollution 
targets. DE, EE, FI, LT, and SE reported most measures as measures under other 
legislative/policy frameworks (68-85%) while LV and PL both reported most measures as 
MSFD-specific (75-89%).  All Member States have included WFD-related measures (assumed 
to be part of the 3rd RBMP) related to control of contaminants from land-based sources 
including wastewater treatment, agriculture, industry and urban run-off. LT and PL both have 
additional measures concerning pollution from agriculture, DE and EE on ship emissions and LV 
on waste management (generally and with regard to mercury) and persistent organic 
pollutants (specifically with regard to PBDE and PFOS). PL refers to priority (hazardous) 
substances and pollution from urban areas/transport/built infrastructure. SE refers to mercury 
and the coast guard (which seems to be national legislation with ties to EU fisheries and 
pollution policies). LT refers to emergency response, in particular oil spills, and sediment. In PL, 
FI, and EE, PBDE, PFOS, new pharmaceuticals or microplastics are not clearly addressed. In 
addition in EE emissions from power generation and industrial plants are missing and in PL, 
coal combustion and heavy industry (heavy metals) are not directly targeted by the measures.  

• 

Coverage of pressures and activities  

65 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

All Member States in the region reported measures to address the input of synthetic and non-
synthetic substances and radionuclides.  The other pressures identified as being specifically 
relevant to D8 were not reported by all Member States: only EE and SE reported contamination 
from (non)UPBT substances, and DE and SE were the only to report ‘input of water-point 
sources (e.g. brine)’. DE, EE, and FI report measures concerning acute pollution events. It is worth 
noting that Member States reported a large number of pressures linked to other descriptors 
(eutrophication, newly introduced non-indigenous species (EE, SE), as various physical and 
biological pressures (DE, EE, FI, SE, PL)).  Measures concerning litter in the environment were 
reported by DE, EE, FI, PL, and SE. There is poor coherence in the activities identified by Member 
States in the region. EE reported measures covering all activities, while DE and SE included all 
activities except the extraction of salt and water. FI and LV did not report any activities, LT only 
reported ship and air transport, while PL reported agriculture, fish and shellfish harvesting, 
military operations, research, canalisation and other watercourse modifications survey and 
educational activities, restructuring of seabed morphology, including dredging & depositing of 
materials, land transport, urban and industrial uses and waste treatment and disposal. 

Contaminants in 
seafood (D9) 

Poor coherence 

Coherence of gap analyses 

Purpose and content of measures  

• 
All Member States but LV reported direct measures to prevent further inputs of a pressure (e.g. 
by managing the source), all but FI reported direct measures to reduce existing levels of a 
pressure in the marine environment (e.g. removal of litter or oil spill clean-up), all reported 
indirect measures to prevent further inputs of a pressure (e.g. by governance mechanisms, 
financial incentives, awareness campaigns) and all Member States reported measures to 
improve the knowledge base (e.g. by research or one-off surveys).  
• 
Only PL provided a clear gap analysis. Of the remaining Member States, most provided partial 
(DE, FI, SE) or poor information on the key elements of the gap analysis (EE), while LT and LV 
did not provide any information on the gap analysis for D9. Overall, for most Member States, 
the technical assessment concludes that the gap analysis prepared for D8 is, to some extent, 
relevant for D9. Only a few Member States provided clear information on the current status of 
contaminants in seafood (FI, LV and PL), while SE also provides information, but only partially. 
FI and LV indicate that the GES level for D9 is currently reached. PL reports that GES is met in 
its waters, with the exception of PBDE. SE states that for hazardous substances in food, GES is 
not achieved since the marketing limit values for dioxins and dioxin-like PCBs are often 
exceeded in wild-caught herring, salmon and trout. For other Member States, no specific 

66 

Two Member States out of seven, PL and SE, 
applied for exceptions under Art. 14(1)(e). The 
reasons  are  different.  PL’s  justification  for 
exception is that no effective measures can be 
taken to accelerate the achievement of GES for 
PBDE – there are no significant ongoing inputs, 
PBDE is widespread in sediments in the marine 
environment  and  achievement  of  GES  is 
therefore  dependent  on  natural  degradation 
which  only  occurs  slowly 
in  the  marine 
environment. 

 
 
Use of exceptions in the region 

SE  provides  the  reason  that  a  reduction  of 
contaminant inputs through SE’s measures will 
not  be  sufficient  to  achieve  GES  and  that 
actions and inactions of neighbouring Member 
States  will  impact  the  achievement  of  GES. 
SE’s  justification  seems  more  appropriate  for 
an  exception  under  Art.  14(1)(a)  –  requiring 
action from other Member States. 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

information was given (DE, EE and LT). No Member State provides information on the extent to 
which current measures will reduce pressures or on the effectiveness of the measures. In most 
Member States it is unclear whether the baseline used to inform the gap analysis takes into 
account future development activity, considers alternative scenarios or indicates the extent to 
which socio-economic factors have been taken into account (DE, EE, PL and SE). Only FI and PL 
report on a timeline for achieving GES before 2030 for FI, not before 2050 for PL because the 
slow degradation of PBDE). 

•  MSFD-specific measures vs other measures  
All Member States reported measures falling under HELCOM and EE, FI, PL and SE under the 
WFD. Other policies are mentioned by fewer countries, e.g. MARPOL (FI, LT and PL) and the 
International Convention on Oil Pollution Preparedness, Response and Co-operation (EE and LT). 
FI and SE link their D9 measures to the UWWTD, the REACH Regulation, the Convention on 
Long-Range Transboundary Air Pollution (CLTRAP) and the Minamata Convention on Mercury. 
Other policies include the Port Reception Facilities Directive (SE) and the Stockholm Convention 
on persistent organic pollutions (POPs) (FI). All Member States, except DE, took more measures 
under other legislative/policy frameworks for D9 than MSFD-specific measures. Only SE has 
defined additional measures.  

Coverage of pressures and activities  

• 
Although no measures were reported specifically for D9, five Member States address the D9 
specific pressure Contaminants in seafood (DE, EE, FI, PL and SE). As all measures overlap with 
D8, the most frequently reported pressure remains Input of synthetic substances and non-
synthetic substances. Other reported pressures include Input of nutrients and Input of organic 
matter (EE, FI, PL, SE). Waste treatment and disposal and agriculture are the two activities most 
linked to D9 measures (PL and SE). Other activities include shipping (EE), aquaculture (EE, SE), 
military operations (DE, SE), industrial uses (PL, SE) and urban uses (PL, SE). Only one Member 
State adequately addresses the relevant pressures (PL), three Member States partially (EE, FI, 
SE), and one Member State insufficiently (DE). For LT and LV, no MSFD-specific measures were 
identified in the second cycle. In PL, the updated measures will not directly contribute 
significantly to pressure reduction, but when considered together with measures under other 
legislative/policy frameworks, relevant pressures will continue to be reduced. EE and FI had 
already adequately addressed pressures in 2016. 

67 

 
 
 
 
 
Use of exceptions in the region 

No Member States applied for an exception 
(239). 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Coherence of gap analyses 

Purpose and content of measures  

• 
All the reported measures for D9 are linked to a ‘measure purpose’. Most of the measures aim 
directly at preventing further inputs of a pressure (EE, FI, PL, SE); fewer aim directly at reducing 
existing pressure levels in the marine environment (DE only). Other reported purposes are: 
indirectly preventing further pressures (DE only), establishing monitoring programmes (DE, SE), 
improving the knowledge base (DE only) or improving the effectiveness of measures (SE only).  
• 
A gap analysis was undertaken by all Member States in the region, although partially in most 
of them (DE, FI, LT, LV, PL). All Member States provide a clear overview of the current status 
mainly focusing on beach litter as all acknowledge the lack of data and/or indicators for 
assessing micro-litter and other D10 criteria. SE, LV and PL specifically refer to EU Beach litter 
thresholds in their report. EE states that the status for macrolitter in the water column and 
microlitter in surface waters is good but everything else is not achieved/unknown. GES is 
reported as not achieved by the other Member States. FI highlights the lack of a clear definition 
of GES, thus the current status could not be assessed. All Member States have provided a 
coherent analysis of pressures and impacts that need to be addressed to close the gaps to 
achieve GES, drawing on information prepared for the BSAP. Pressures and activities causing 
litter are: tourism and leisure activities, followed by fisheries, shipping, and land-based sources. 
Microlitter and litter in water column and seabed are identified as knowledge gaps to be 
addressed. An estimate of how much the first cycle measures reduce pressures, as well as 
clear conclusions on the effectiveness of the measures were given by EE, FI, LT, LV, PL and SE. 
Baseline scenarios were drawn up by DE, EE, LV, PL, SE, with EE, LV and PL also considering 
future socio-economic development. SE refers to 2050 for achievement of GES, while EE states 
that GES will be reached for macrolitter by the end of implementation of the second 
programme of measures. 

Marine 
(D10) 

litter 

Moderate to high 
coherence 

•  MSFD-specific measures vs other measures  
DE, EE, FI and SE provide many links to relevant existing policies for D10, while LT and LV 
provide far fewer such links. Six out of seven Member States refer to HELCOM (47 measures, 
DE EE, FI, LT, PL and SE), but only DE and SE specifically refer to the HELCOM Regional Action 
Plan on marine Litter. Member States refer to a lesser extent to MARPOL (11 measures, DE, EE, 
FI, LT and PL). EU legislation is also a clear driver for defining measures: the higher number of 

(239) SE’s exception for D10 applies only to its North Sea waters, not to the Baltic, owing to the fact that litter from the North Sea is drifting with streams to the Skagerrak. 

68 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

measures are linked to the Single Use Plastic Directive (16 measures, DE, FI, LT and SE) and the 
EU Strategy for Plastics in a Circular Economy (11 measures, DE, FI and LT). Other legislations 
are mentioned less frequently, including Waste Framework Directive, WFD, PRF Directive and 
UWWTD. FI and SE rely more on measures taken under other frameworks, while DE and PL 
more on MSFD-specific measures. EE, LT and LV defined a balanced mix of already established 
measures and MSFD-specific.  

Coverage of pressures and activities  

• 
All Member States have made some progress during the second cycle in terms of pressure 
coverage. DE, EE and PL adequately address all pressures with the new measures in the second 
cycle, while FI, LT, LV and SE do this only partially. There are more MSFD-specific measures 
aimed at reducing the input of litter (81% from all Member States), than measures aimed at 
reducing the pressure level in the environment (14% from DE, EE, FI and SE). Of those that aim 
at reducing the input, the majority (63%) are direct measures (e.g. managing the source 
activities), while 44% are indirect measures (e.g. by governance mechanisms, financial 
incentives, awareness campaigns). A small proportion of measures is still dedicated to 
improving the knowledge base (7% - defined by all Member States except EE). The most 
relevant activities causing the pressures are targeted by all Member States: fisheries (mainly by 
DE, PL, SE, FI and EE), shipping including port operations (mainly by DE, EE, SE, FI, LT and PL), 
tourism and recreational activities (DE, EE, LT and SE), industry and urban areas (DE, EE, LT, PL, 
SE). Some Member States identify other sources at sea (e.g. offshore installations DE), and on 
land (aquaculture SE, DE) as main contributors to the litter problem and defined new measures 
to address them. FI made progress defining many additional direct measures, covering a gap 
from the first cycle (mainly indirect measures). SE made progress in addressing 
tourism/recreation which was not covered in the first cycle. 

Purpose and content of measures  

• 
As far as macrolitter is concerned, all Member States put their main effort and focus on litter on 
beaches and less on seabed litter and surface litter. Only DE, FI and SE specify that cleaning 
actions specifically address all elements of litter and not only beach litter. FI defines different 
measures for different categories of litter (e.g. specifically dedicated to tire, artificial turfs, 
plastic pellets). Measures addressing microlitter target industry and urban areas, shipping, as 
well as tourism/recreational activities and to a small extent fisheries (measures for better 
management of fishing gears). 36% of the MSFD-specific measures tackles microlitter, through 
different approaches (e.g. reducing microplastic loads from road traffic (FI), treatment of 

69 

 
Use of exceptions in the region 

No Member State applied for an exception. 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Underwater 
noise (D11) 

High to moderate 
coherence 

Coherence of gap analyses 

stormwater and wastewater to reduce amounts of microplastics (EE), lobbying for a ban on 
micro- and nanoplastic particles (PL) or tackling microparticles through management of fishing 
gears (SE)). More measures aim to reduce the input of the pressure than the pressure level in 
the environment (e.g. fishing for litter, beach and street clean-up activities).  
• 
The information regarding the gap analysis varies a lot across the Member States in the region. 
PL is the only Member State that provides a complete gap analysis: it clearly provides an 
overview of the current status and of progress on the targets and assesses progress made by 
first cycle measures, concluding that they are not sufficient to achieve GES. It also explains how 
future developments are taken into account, focusing on increased level of shipping and as 
offshore wind infrastructure. DE and EE have partially identified significant gaps to achieve 
targets and ultimately GES for D11. DE clearly addresses the effectiveness of its measures and 
states that for underwater sound it is not possible to estimate whether current measures are 
sufficient to achieve good environmental status. It also considers other anthropogenic energy 
sources such as light in their gap analysis. EE also does not present a complete gap analysis, 
but acknowledges the benefits of the HELCOM Baltic Sea Action Plan which provides data, 
analysis and recommendations, including for underwater noise and on this basis defined a new 
measure for D11 in the updated PoMs. SE and FI explained how the gap analysis was 
performed and how it was the basis for the selection of the new measures for the second cycle 
but did not specify conclusions on underwater noise. LT and LV do not provide a gap analysis 
for D11. It must be noted that neither Member State defined GES for D11 under Article 9. 
Despite this, LT acknowledges in the text report lack of data regarding underwater noise and 
defines monitoring measures to address the gaps in the updated PoMs; LV, on the other side, 
does not address underwater noise in its updated PoMs. 

•  MSFD-specific measures vs other measures  
Some Member States, such as SE, FI and DE provide many links to various relevant existing 
policies for D11, while others, such as EE, LT and PL mainly refer to HELCOM and national 
legislations/policies. LV does not define any D11 specific measure and appears to have 
withdrawn the horizontal measures from the first cycle that were relevant for D11. All Member 
States, except LV, refer to HELCOM. This shows a high level of coherence. However, other 
policy/legislation are mentioned by a few Member States only: only DE and SE mention the 
Habitats and Birds Directive, only DE and FI the EU Biodiversity Strategy, and only FI and PL 
explicitly link some measures to IMO guidelines on underwater noise from shipping, although 

70 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

also DE has measures to address this pressure from shipping; only FI and SE refer to MSP. 
Overall, considering both first and second cycle measures, PL defined only MSFD specific 
measures, while the other Member States defined a mix of both measures taken under other 
legislative/policy frameworks and MSFD-specific measures. Three Member States (SE, EE and FI) 
define measures to implement the HELCOM Regional Action Plan on underwater noise, 
although SE categorises it as ‘existing measure’ while EE as ‘MSFD specific measure’. The same 
measure from FI is from the first cycle and it is not clear if it has been updated.  As a result of 
the gap analysis, even if clear shortcomings were not identified in most Member States, all of 
them, except LV, either modified measures from the first cycle or defined additional ones in the 
second cycle. 

Coverage of pressures and activities  

• 
All Member States in the region, except for LV, have made some progress during the second 
cycle with regard to D11 in terms of pressure coverage. The technical adequacy assessment 
concluded that five MSs (EE, SE, PL, FI and DE) adequately address all pressures with the 
modified and the additional new measures in the second cycle, while LT does this only partially. 
LV does not report any measure for D11 in the second cycle and has withdrawn D11 relevant 
(horizontal) measures from the first cycle. In terms of activities, DE, EE, FI and SE define 
measures that target different sources of activity of the pressures (e.g. marine-based 
renewable energy generation, defence operations, shipping, extraction of minerals). PL defined 
one measure to address noise from shipping and two measures to address noise from defense 
operations. LT still focuses its measures of the establishment of monitoring systems. 

Purpose and content of measures  

• 
All Member States defined direct or indirect measures to tackle impulsive sound, while all 
Member States except LT (and LV) defined direct or indirect measures to tackle continuous 
sound. Considering both first and second cycle reporting, there are more MSFD-specific 
measures aimed at reducing the input of sound (69% from all Member States except LV), than 
measures aimed at reducing the pressure level in the environment (21% from EE, FI and SE). 
For both types of measures, continuous and impulsive sound are somewhat equally addressed. 
A few measures are still dedicated to improving the knowledge base (DE, LT and PL) and 
establishing monitoring programmes (DE only). DE remains the only Member State to have 
defined specific measures to address other form of energy, including electromagnetic fields, 
light and heat. Potentially EE, SE and FI will also implement some actions to reduce impact 

71 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

from other noise sources through their general measure implementing the Baltic Regional 
Action Plan on Underwater Noise (RAP NOISE) recommendations. In particular, EE in the 
measure description refers to action 29 of the RAP NOISE (‘Reduce the impact from acoustic 
deterrent devices by developing and agreeing on common guidelines and regulation of the 
design and use of deterrent devices’). SE and FI on the other side do not provide details on 
‘other form of energy’ in the description of the measure implementing RAP NOISE 
recommendation.   

Biodiversity 

Biodiversity 
(D1)  

Moderate 
coherence 

Coherence of gap analyses 

• 
Most Member States have adequately identified all gaps, LV and SE (240) have partially done 
so and LT is considered not to have produced an adequate gap analysis. DE, EE, PL and SE 
presented a clear overview of current status of all four relevant feature groups (birds, fish, 
mammals and pelagic habitats). Reasons for not reaching GES/targets include high level of 
pressure caused by fisheries/bycatch (DE, EE, LT, LV, PL), eutrophication (DE, EE, LV) and 
pollution (LV, PL). Only FI provided an estimation of how much the first cycle and updated 
existing measures will reduce pressures. Three Member States provide clear conclusions on the 
effectiveness of the measures (DE, EE, FI) and only DE and PL consider future socio-economic 
development to determine future environmental pressures. 

•  MSFD-specific measures vs other measures  
Clear links between biodiversity measures and existing legislation and policies are made, in 
particular with HELCOM (DE, EE, FI, LT, LV, PL), the Habitats Directive (DE, EE, FI, LT, LV, PL), the 
Birds Directive (DE, EE, FI, LT, SE) and Biodiversity Strategy (DE, EE, FI). A smaller number of 
measures are also linked to the CFP (DE, EE, FI, LT, PL, SE), the MSP (DE, FI, SE), the EIA 
Directive (DE, FI ) and Convention on Biological Diversity (DE, FI, PL). Five Member States (DE, 
EE, LV, FI and SE) rely both on MSFD-specific measures and measures from existing 
instruments, while LT and PL do not report any MSFD-specific measures. 

Coverage of pressures and activities  

• 
Only EE and SE have fully addressed previously identified pressures, all others address them 
only partially either by relying prominently on indirect measures or not addressing identified 

Five Member States out of seven applied for 
exceptions (EE, FI, LT, PL and SE). Across those 
Member States’ applications for exception, 
coherence is poor. 

For Descriptor 1, all five applied for exceptions 
under Art.(1)(e) (natural conditions), with FI, PL 
and SE giving the same reason that GES may 
not be achieved due to long breeding / life 
cycle of species which makes species 
recovery slow, EE invoking climate change and 
LT the need to maintain the structure of the 
nutrient network.  

FI, PL and SE also applied for exceptions for 
Descriptor 1 under Art.(1)(a) (action for which 
the Member State is not responsible) for 
species not residing full time within national 
boundaries. FI and PL report that the seabirds 
do not reside all year round within the 
national boundaries, while SE reports that the 
GES for fish depends heavily on 
implementation of the EU Common Fisheries 
Policy (CFP). PL additionally identifies nutrient 

(240) LV has not addressed all biodiversity aspects of the three relevant (species) groups; SE does not distinguish between the need to expand existing measures and develop new MSFD-
specific measures.  

72 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

pressures (bird hunting in FI or bird bycatch in LT). The main pressures addressed include 
extraction and disturbance of species, physical disturbance of seabed, input of nutrients, 
underwater noise, physical loss of seabed habitats and introduction of invasive species. Primary 
activities addressed include fisheries, maritime transport, tourism and recreational activities, 
port operations, and urban development. In addition, certain Member States have identified 
further pressures, both at sea (e.g., underwater noise and the introduction of non-indigenous 
species in DE) and on land (e.g., agricultural runoff affecting eutrophication in EE and SE; 
industrial discharges in PL). Other activities include extraction of production of electricity, 
aquaculture, extraction of non-living material and research.  

Purpose and content of measures  

• 
Five Member States (DE, EE, FI, PL, SE and LV) address all relevant features (fish, birds, 
mammals, pelagic habitats, ecosystems). LT predominantly focus on fish species. More than 
half of the new measures aim at reducing or preventing the inputs of pressures, in particular 
from fisheries, nutrients and hazardous substances, while the others focus on enhancing 
monitoring, expanding the knowledge base, including the development of innovative 
technologies (in EE and LT), or assessing the effectiveness of existing measures. A number of 
measures also focus designating new MPAs (DE, FI, and SE ) and improving their management 
(EE, PL and LV) and governance, as well as on active restoration of certain habitats (in DE and 
SE). Only LT does not include MPA-related measures. 

Coherence of gap analyses 

• 
A gap analysis was undertaken by all Member States in the region. All Member States provide 
a clear overview of the current status with most Member States stating not to have been able 
to achieve GES (except FI). FI concludes that GES has been achieved but acknowledges that the 
situation is not good when looking at the input and spread of already established alien species. 
The others have not achieved GES mainly because existing measures are insufficient. Most 
Member States (EE, FI, LV, PL) state that shipping activities (ballast water, ship hull fouling) are 
the main source and pathway of introductions and contributing to the existing pressure. DE, EE 
and PL provide partial information regarding how much the first cycle and updated existing 
measures will reduce pressures but most Member States conclude on the need to define 
additional measures in the second cycle. None of the Member State clearly state by when GES 
is expected to be achieved. EE, DE, PL and SE identify key gaps highlighting the need for 
additional measures and implementation of existing legislation /policies.  

73 

NIS (D2) 

Moderate 
coherence 

Use of exceptions in the region 

concentrations in the water as also dependent 
on neighbouring states. 

PL additionally applied for an exception for 
Descriptor 1 under Art.(1)(b) (natural causes), 
using the same justification as its application 
under Art.(1)(a).  

Two Member States out of seven, LT and PL, 
applied for exceptions.  

LT applied for an exception under Art.14(1)(e) 
but did not report a robust and detailed 
justification based on scientific evidence for 
the exception. It does however provide the 
required estimation of when GES is expected 
to be achieved (2033).  

PL applied for exceptions under Art. 14(1)(a) 
and Art. 14(1)(b). For Art. 14(1)(a), PL reports 
that the transfer and introduction of NIS is an 
international responsibility and PL cannot bear 

 
 
 
Use of exceptions in the region 

sole responsibility for introductions to its 
waters. In addition, the spread of that species, 
already in the Baltic Sea, to PL waters is out 
of their control. For Art. 14(1)(b), justification 
relates to eradication of NIS being difficult 
and unlikely once the NIS is established.   

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

•  MSFD-specific measures vs other measures  
All Member States provide links to relevant existing policies for D2, in particular the Invasive 
Alien Species Regulation. All Member States except PL and DE refer to the IMO Ballast Water 
Convention. The CFP is only mentioned by EE. Most Member States (DE, EE, LT, LV, FI) refer to 
HELCOM.  All Member States except PL and LV rely to some degree on measures taken under 
other framework. DE and EE defined a balanced mix of already established measures and 
MSFD-specific measures whereas PL rely only on MSFD -specific measures. LT, SE and LV 
adapt measures taken under other frameworks in the first cycle, e.g. developing guidance for 
authorities and commercial operations for the disposal of contaminants and fouling in the 
cleaning of ship hulls and reducing the spread of contaminants from recreational crafts. Almost 
70% of the MSFD-specific measures were newly proposed for the second cycle. A number of 
measures are specific to D2 focusing on shipping and establishing early warning system (LT, 
DE, LV). 

Coverage of pressures and activities  

• 
All Member States except FI have made progress during the second cycle on D2 in terms of 
pressure coverage. PL, EE and SE have adequately addressed all pressures with their new 
measures, while DE and LT do this only partially. FI stated to have achieved GES and relied on 
measures taken under other frameworks. There are more MSFD-specific measures aimed at 
reducing the input or spread of NIS (63% of all measures) than measures aimed at reducing 
existing level of pressure (15% from PL, FI, SE). Of those that aim at reducing the input, only 
46% are direct measures, managing the source activities; 51% are indirect aiming at 
preventing further inputs of a pressure (e.g. by governance mechanisms, financial incentives, 
awareness campaigns). A very small proportion of measures is dedicated to improving the 
knowledge base (6% - defined by LT, PL and SE). The most relevant activities causing the 
pressures are addressed by DE, SE and EE: shipping, tourism and recreational activities, 
aquaculture – freshwater and marine, including infrastructure. Most Member States in the 
region (FI, LV, LT and PL) do not provide data on relevant activities but some of their measures 
clearly target main activities, e.g. PL (fisheries), LV (ship’s ballast water and deposition), LT 
(investigations to assess the impact of recreational navigation).  

Purpose and content of measures  

• 
The measures addressing newly introduced NIS target shipping and to a small degree tourism, 
aquaculture and recreational activities. Most of the measures focus on managing sources of 

74 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Coherence of gap analyses 

activities by directly preventing further inputs of a pressure (e.g. EE - Ensuring environmental 
safety of shipping, SE- measure addresses reduction of the populations of invasive Gobiidae 
species in transitional waters through biomanipulation employing predatory fish). FI, PL and SE 
focus on measures directly restoring a species or habitat(s). Some Member States report 
measures to establish monitoring programmes (of relevant activities, pressures, or impacts) 
and measures to indirectly prevent further inputs of a pressure (e.g. by governance 
mechanisms, financial incentives etc.), e.g. PL -measure on educating aquarists and anglers on 
the dangers of releasing specimens of invasive alien species into the natural environment. 
• 
A gap analysis was undertaken by all Member States in the region, except for LV. FI, LT, EE and 
PL based their gap analysis on the HELCOM Sufficiency of Measures (SOM) analysis, providing 
high level of coherence to the approach across the region. SE and DE carried out a more high-
level, qualitative assessment to understand gaps. Almost all Member States provided a clear 
overview of the current status (DE, EE, FI, LV, PL and SE) mainly focusing on the status of some 
commercial fishing stocks. Some Member States also provided explanation on why GES has 
not yet been achieved (DE, FI, PL and SE). All Member States, except LT, explicitly presented 
pressures and activities for D3. EE, FI and PL clearly estimated how much the first cycle and 
updated existing measures will reduce pressures and DE and SE did so partially. No information 
on this was presented by LT and LV. Only FI and PL elaborated baseline scenarios and EE, FI 
and LV considered future socio-economic development. Regarding barriers to achieving GES, EE 
and LT stressed the need to address knowledge gaps, DE highlighted the inefficiency of the 
implementation process of its measures and FI underscored the inefficiency of the measures in 
covering all key species for D3. EE, FI, LV and PL provided a timeline for achieving GES, while 
DE, LT and SE did not mention it in their reports. 

•  MSFD-specific measures vs other measures (241)  
Most Member States link their measures to the CFP, some reporting only the main CFP 
regulation as a measure (e.g. DE), while others report additional regulations such as multi-
annual plans, technical measures, EMFAF and the DCF. Only LT did not clearly report any CFP-
related legislation for D3.  EE relies more on measures taken under other frameworks for D3, 
while FI, PL and SE rely more on MSFD-specific measures. DE defined a balanced mix of 
already established measures and MSFD-specific. The only measure proposed by LT is MSFD-

Four Member States out of seven, FI, LT, PL 
and SE, applied for exceptions.  

FI, PL and SE applied under Art. 14(1)(a). The 
reasons given are the same: that fish stocks 
are dependent on other countries’ actions. PL 
additionally highlights eutrophication as a 
problem and SE specifically mentions the 
implementation of the EU Common Fisheries 
Policy (CFP).  

FI, PL and LT applied under Art. 14(1)(e), with 
different justifications, although both LT and 
PL note the broader marine environment (e.g. 
deoxygenation) as a factor.  

FI gave the reason of delayed effect of 
measures, with the good status of stocks 
expected to be achieved by 2030. LT gave 
the reason that biological changes in the stock 
have reduced the stocks’ reproductive 
potential. This is due to high natural mortality, 
close to zero fishing mortality (targeted 
fishing for eastern cod has been prohibited in 

Commercial fish 
and shellfish 
(D3) 

Moderate to high 
coherence 

(241) LV did not define any measures for D3. It is therefore not included in the next sections of the analysis, but it is considered to draw conclusions on the coherence level. 

75 

 
 
 
 
 
Use of exceptions in the region 

the Baltic Sea from 2020 to 2022), and 
changes in the ecosystem (poor oxygen 
conditions, reduced availability of prey, high 
levels of parasites). PL gave the reason that 
the fishing ban in place for the past few years 
is not “a sufficiently strong impulse to allow 
swift regeneration of the population”. PL also 
argued that restoration of GES with regard to 
cod stocks will likely require an improvement 
of the environmental conditions, and that 
climate change may derail the expectation of 
achieving GES after 2050. 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

specific. Among the new measures, Member States propose to improve the condition of fish 
spawning areas (EE), cross-border cooperation and action plans to promote more sustainable 
fish stocks (FI) and promotion of a sustainable size distribution of coastal fish communities 
(SE).  

Coverage of pressures and activities  

• 
All Member States have measures that address the main pressure for D3, which is extraction of 
species, and measures that address physical disturbance of the seabed. Although not directly 
related to achieving GES for D3, fisheries management measures can contribute to GES for D6. 
Some Member States address additional pressures: bycatch (DE, SE), seaweed harvesting (EE), 
eutrophication (PL), disturbance of species (FI). EE, FI and SE adequately address all pressures 
with the new measures in the second cycle, while DE and PL do this only partially. PL’s 
measures predominantly focus on reducing nutrient enrichment, as this has been identified as 
a pressure that may hinder the recovery of Baltic cod. LT measures will not reduce pressures 
relevant to D3. LV does not report any measures for D3 and states that GES will be achieved 
through measures under LV fisheries policy.  The primary activity exerting pressure, i.e. 
commercial fishing, is targeted by all Member States in the region. There is an evident gap in 
relation to recreational fishing (SE is the only MS that addresses the pressure from recreational 
fisheries). Some Member States identified other activities impacting the health of fish and 
shellfish populations: production of energy and aquaculture (SE); construction of canalisation 
and other water course modifications (EE) and agriculture (PL).  

Purpose and content of measures  

• 
In total 50 measures are reported that address the extraction of species in the region, as direct 
measures (FI, PL and SE), indirect measures (DE) and a mix of both direct and indirect (EE). 
More than half of the measures (30) are aimed at directly reducing the input of the pressure 
(e.g. by establishing fishing restrictions and size limits, implementing new marine protected 
areas, or promoting the use of selective and low impact fishing gears) and at directly reducing 
the pressure level (e.g. by developing guidance for the implementation of ecosystem based 
marine management). Raising awareness measures are adopted by DE, EE, FI, LT and SE, while 
monitoring efforts measures are adopted by SE only. While all Member States present 
measures to cover CFP-managed stocks, there is inconsistency in the coverage of stocks and 
sources, especially concerning locally/nationally managed stocks (addressed by SE, LT and FI 
only), and from the recreational sector (addressed only by SE).  

76 

 
Use of exceptions in the region 

LT is the only Member State in the region to 
apply for an exception for Descriptor 4, under 
Art. 14(1)(e) (natural conditions). LT’s 
justification is that the nutrient network in the 
Baltic is a natural condition and cannot be 
controlled on a Member State level and needs 
to be maintained by all Baltic countries. LT 
does not provide an approximate timeline for 
achieving GES.   

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Food webs (D4) 

Poor coherence 

Coherence of gap analyses 

• 
Not all Member States have carried out a gap analysis for food webs in the region.  Only PL 
has adequately identified all gaps, and DE, EE, and SE partially.  LT and LV are missing 
elements in their analysis and FI analysis is only sparsely completed. PL, DE, EE, and SE present 
an assessment of current status. DE does not provide sufficient details to make a conclusion 
and SE’s assessment is based only on size structure of fish communities. DE, PL, and SE 
identify pressures affecting food webs, with DE linking these with pressures affecting D1 and 
D6, and PL listing a broad range, including destruction of habitats, fishing pressure, nutrient 
input, underwater noise, and pollution, especially from heavy metals. DE, FI, and PL present 
clear conclusions of the effectiveness of the measures. DE mentions the poor implementation 
of measures from the first cycle. Only DE and PL present a baseline scenario and consider 
future socio-economic development, and only DE attempts to provide an indication of a 
timeline for achieving GES, but this is only vague. 

•  MSFD-specific measures vs other measures  
All Member States but LV link their D4 measures to other legislative/policy frameworks. 
HELCOM is cited most often by nearly all the Member States, followed by the Habitats and 
Birds Directives, the WFD and the CFP. DE, EE, and PL also cite the Biodiversity Strategy as a 
driver for D4 measures. Considering both MSFD and second cycle measures, DE, EE, FI, and SE 
present a mix of MSFD-specific and measures based on existing frameworks for D4, although 
SE relies heavily on MSFD-specific measures. 

Coverage of pressures and activities  

• 
EE and SE successfully address previously identified pressures, FI and PL only partially, LT and 
LV not at all, and the information for DE is not clear. The main pressures addressed include 
species extraction and disturbance, introduction of invasive species, microbial pathogens or 
genetically modified organisms, input of sound and cultivation/artificialisation of natural 
habitat. Only one pressure, extraction of species (i.e. fishing), is addressed by all Member States 
(except LV), while disturbance of species is addressed by all except LV and LT. FI and PL also 
address input of sound, and PL also introduction of invasive species.  The main activities 
addressed include fisheries, restructuring of habitat, extraction of non-living resources, 
production of energy, aquaculture, transport, urbanisation, tourism, military and research. DE, 
EE, and SE address all these activities, while LT and LV do not mention activities at all.  

• 

Purpose and content of measures  

77 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Coherence of gap analyses 

The main features covered by D4 measures include birds, mammals, fish, benthic and pelagic 
habitats, hydrological characteristics and ecosystems. DE, EE, PL and SE address all of these 
(except hydrological characteristics for PL). FI address most habitats and species, while LT only 
reports on fish. Most Member States (DE, EE, FI, PL, SE) reported fisheries-related measures, 
such as promoting a sustainable fishing industry, monitoring fishing efforts, or developing 
alternative fishing gear to prevent bycatch. Slightly fewer than half of the measures for D4 are 
measures to reduce or prevent inputs of pressures while the rest relate to monitoring, gaining 
knowledge or assessing effectiveness of measures.  EE, PL, and SE report considerably more 
direct measures and DE, FI, and LT equally direct and indirect. DE, FI, and SE report developing 
new MPAs linking also to D1, EE and PL focus on improving the management of existing MPAs. 
• 
All Member States in the region carried out a gap analysis for D6, except LT. Only DE reports on 
almost all elements of the gap analysis. The majority of Member States provide a clear and 
detailed overview of the current status of the seabed (DE, EE, LV, PL). SE, LT and FI provide a 
limited overview. LT focuses on human activities undertaken on the seabed and their extent, 
while FI assessment of the current status is clear but covers only some habitats due to 
insufficient data for others. DE, EE, FI, LV, and PL adequately identify gaps in achieving GES, 
only partially by SE, and not at all by LT. All Member States present pressures and activities 
affecting seabed integrity (DE, EE, FI, LV, PL, SE), with the exception of LT. The most important 
pressures and activities listed include bottom trawling (DE, EE, PL, SE), excessive nutrient flow 
(DE, FI, PL), dredging (EE, FI), climate change (DE) and construction of permanent facilities, 
coastal erosion defences, and shipping (EE). Only DE and FI discuss the extent to which the 
measures could reduce the pressures. DE provides only a vague estimate of the timeline for the 
expected impact of these measures. In four Member States, the gap analysis elaborates on 
baseline scenarios that serve as a benchmark against which alternative options are compared 
(DE, EE, LV and PL). Only DE and EE consider future socio-economic development to determine 
future environmental pressures. Only DE provides conclusions on the effectiveness of the 
measures in achieving GES, describing the ability of each measure to reduce anthropogenic 
pressures. Only FI reports on a timeline for achieving GES, which has been set to 2027. FI 
however stresses the challenge to provide a timeline for when GES will be reached, pointing out 
that restoring habitats can take decades.  

•  MSFD-specific measures vs other measures  

78 

PL is the only Member State to apply for 
exceptions. PL applied for exceptions under 
Art. 14(1)(a), Art. 14(1)(e), and Art. 14(1)(d). 
The reason given under Art. 14(1)(a) and Art. 
14(1)(e) is that reducing nutrient 
concentration in Polish waters requires 
significant action on the part of other 
neighbouring states. The reason given under 
Art. 14(1)(d) is that PL does not believe that 
reversing all physical loss in PL waters is in 
the public interest. Ensuring no loss will 
require the removal of several structures 
which would have a negative economic 
impact and may cause a loss of jobs.  

Seabed habitats 
(D6) 

Moderate 
coherence 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

All Member States link their D6 measures to HELCOM and the Habitats Directive, five mention 
the Birds Directive (DE, EE, FI, LT and SE) and four the MSP Directive (DE, FI, PL, SE). Only DE, FI 
and LT mention the EIA Directive and DE, FI and PL the CBD. The CFP is mentioned by all 
Member States, except LV. DE is the only country reporting links to OSPAR. However, as shown 
below, Member States do not always clearly link the actual measures to these other 
legislative/policy frameworks. Overall, considering both the first and second cycle measures, 
Member States mostly relied on MSFD-specific measures for D6. Only LT relied heavily on 
measures taken under other legislative/policy frameworks. As a result of the gap analysis, even 
if clear shortcomings were not identified in most Member States, all of them, (except LT which 
did not carry out a gap analysis), modified measures taken under other legislative/policy 
frameworks identified in the first cycle or defined additional ones in the second cycle. 

Coverage of pressures and activities  

• 
The coherence of approaches taken across the region to address pressures is low. Only 39% of 
all measures reported for D6 in the Baltic Sea are linked to the pressures of physical loss and 
physical disturbance of the seabed. Other recurrent reported pressures include biological 
disturbance to species (EE, FI, LT, LV and SE) and extraction of species (DE, EE, FI, LT, LV, PL and 
SE). As a result, most D6 measures overlap with descriptors D1 and D4, indicating a general 
approach rather than an approach specific to the pressures affecting seabed integrity. Only half 
of the measures addressing physical loss and disturbance of the seabed (DE, EE, FI and SE) are 
tied to activities (and FI does not report any activity). The most common activity is fishing, as in 
the first cycle, with the measures of DE, EE and SE mainly targeting commercial and 
recreational fish and shellfish harvesting. The other most common activities reported for 
causing physical loss and disturbance are extraction of minerals (DE and EE), restructuring of 
seabed morphology including dredging and depositing of materials (DE, EE and SE) and 
offshore structures other than for oil/gas/renewables (DE and EE).  

Purpose and content of measures  

• 
Looking at both first and second cycle reporting, ES, EE, FI and SE report more measures that 
prevent further inputs of the pressures than measures aimed at directly reducing its existing 
level in the environment (only FI and SE) or measures directly restoring a species or habitats 
(only DE, EE and SE). Of those that aim at reducing input, only 27% of the measures are direct 
measures, managing the source activities; 44% are indirect measures aiming at preventing 
further inputs of a pressure (e.g. by governance mechanisms, financial incentives, awareness 

79 

 
 
 
Use of exceptions in the region 

Only  PL  applied  for  an  exception  under  Art. 
14(1)(d),  with  the  reason  that  achieving  GES 
for D7 in three transitional water bodies would 
require  destruction  of  major  infrastructures 
that are deemed necessary for public services 
and  economic  activities  and  in  some  cases 
threaten wild species that live in these areas. 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Hydrographical 
changes (D7) 

Moderate 
coherence 

Coherence of gap analyses 

campaigns). A few measures are dedicated to improving the knowledge base (DE, FI and SE), 
establishing monitoring programmes (DE, EE and SE) and assessing measure effectiveness (EE, 
FI and SE). Aside from LT, all Member States in the region reported new spatial protection 
measures also for D6. 
• 
All Member States reported a gap analysis (DE, EE, FI, LT, LV, PL, SE). A majority of the Member 
States provided an overview of the current status (DE, EE, FI, LV, PL, SE) and some of them 
mention GES is achieved (DE, FI, SE). Human activities and pressures such as dams and 
windfarms are explicitly mentioned in the assessments of almost all Member States (DE, EE, FI, 
LT, PL, SE), and all Member States that have performed a gap analysis for D7 mention these 
large scale human activities as having an effect on hydrography. Climate change as a pressure 
is mentioned by a few Member States (FI, PL). A few Member States estimate how much 
measures taken under other legislative/policy frameworks will reduce pressures (DE, EE, FI, SE). 
None of the Member States reported a baseline. Some Member States consider future socio-
economic development to determine future environmental pressures (FI, LT, PL). Clear 
conclusions on the effectiveness of the measures are given by most of the Member States (DE, 
EE, FI SE). It should be noted that several Member States are not adopting new MSFD-specific 
measures (FI, LT, LV), in case of FI and SE because the Member States do not see the need. The 
Member States for which GES was not achieved do not give a timeline for when it would be 
achieved. Coherence is moderate in both the methodological approach and the conclusions on 
assessment of status and gap analysis. Despite the work done within HELCOM, no common 
forward vision has been reported for future activities and pressures that could hamper 
achievement of GES for D7 by causing permanent alteration in hydrological conditions. 

•  MSFD-specific measures vs other measures  
The most cited legislation is the WFD (DE, FI, PL, SE). followed by HELCOM, the Habitats 
Directive (DE, EE, FI), and the Birds Directive (DE).  The MSP was referred to only a few times 
(DE, FI, SE) as was the EIA Directive (DE). DE is the only Member State that links multiple 
existing policies to more than one measure. Considering the measures taken under other 
legislative/policy frameworks and MSFD-specific measures, almost all Member States defined 
a balanced mix of both (DE, FI, PL, SE), whereas EE relied purely on MSFD-specific measures.  

• 

Coverage of pressures and activities  

80 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Compared to the 2016 assessment, no progress in terms of pressure coverage has taken place 
with regard to D7.  Three Member States report additional or modified MSFD specific measures 
(DE, PL and EE). They primarily address changes to hydrological conditions (DE, EE), and 
disturbance of the seabed (DE, PL). These three Member States cover various activities with 
their D7 measures: DE focuses on sediment management, EE’s measures relate to 
infrastructure and renewable energy, and PL measures focuses on the protection of the 
seafloor. Several Member States do not report new D7 measures in the second cycle (FI, LT, LV, 
SE). 

Purpose and content of measures  

• 
Considering both first and second cycle reporting, most of the MSFD-specific measures aim at 
reducing the input of pressures, of which the majority addresses the pressures directly (DE, EE, 
FI, PL, SE), and some measures do so indirectly (DE, FI, PL). Some Member States (DE, EE, FI) 
provide measures to assess the impact/effectiveness of measures or restoring of an 
ecosystem. Only a few measures aim at improving the knowledge base, for example by 
conducting research (DE, SE). Overall, the measures across Member States do not cover similar 
content or purposes in the Baltic region. While some Member States focus on sediment 
management (DE) or on improving environmental governance and data management (EE), 
others (PL) have a mix of indirect measures focusing on governance and knowledge 
improvement. Some Member States have been assessed as not reporting D7 relevant 
measures because GES is achieved (FI, SE) or because of a lack of information (LT, LV). 

81 

 
 
 
 
 
Use of exceptions in the region 

No Member State applied for an exception.  

4.2.3  Mediterranean  

Coherence of 
Programmes of 
measures 

Justification  

Descriptor 

Pollution 

Eutrophication 
(D5) 

Moderate 
coherence 

Coherence of gap analyses 

• 
CY, ES and SI have provided a partial gap analysis. CY, ES and SI report to be achieving GES for 
D5. Insufficient information has been provided by FR and IT to inform such an assessment. 
While all five Member States (242) provide some reference to pressures and activities, none of 
the Member States provide a detailed analysis of the activities causing nutrient pressures nor 
how current measures under other frameworks address these pressures apart from some 
limited analysis by SI. It is thus unclear to what extent the measures will support achievement 
of GES for D5. None of the Member States provided a baseline scenario or alternative 
scenarios to inform the gap analysis. Nor do Member States indicate whether the gap analysis 
has taken account of future development activity or socio-economic factors. No timelines for 
achieving GES are provided by IT and FR (the others having already achieved GES for D5).   

•  MSFD-specific measures vs other measures  
All Member States refer to the WFD, UWWTD and Nitrates Directive, apart from FR which has 
not identified any specific measures for D5 in the Mediterranean. Of the total of 55 measures, 
11 are specifically identified as WFD measures. ES and IT refer to MARPOL. CY and SI refer to 
the Industrial Emissions Directive. Only ES refers to UNEP-MAP. No Member States refer to the 
Zero Pollution targets. The Member States rely more on measures taken under other 
frameworks (65%) compared to MSFD-specific measures (35%) although this varies between 
Member States. In CY and SI all the identified measures are taken under other frameworks. For 
ES, 14 of the 15 measures are MSFD-specific measures.  Only ES and IT report new MSFD-
related measures, including measures to address water pollution in port areas through 
improvements to port waste reception facilities and measures to address inputs from shipping.  

Coverage of pressures and activities  

• 
The coverage of pressures and activities is considered partially adequate for ES, not clear for IT 
and not relevant to CY and SI as they have not identified any new measures for D5 (as D5 is 
considered as being achieved). Similarly, FR has not identified any specific new measures for 
D5, although it is unclear whether FR is achieving GES for D5. Nutrient pressures are overall 

(242) HR, EL and MT had not reported their programmes of measures by the cut-off date and are therefore not included in the assessment 

82 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

well understood and addressed by existing laws and policies that seek to manage the input of 
nutrients into marine waters. Key activities related to D5 pressures identified by the Member 
States include urban wastewater, agriculture and urban run-off. Some Member States also 
identify aquaculture (CY, IT) and ports/shipping (CY, ES, IT) as activities giving rise to pressures 
that require management. ES references pressures from shipping. 

Coherence of gap analyses 

Purpose and content of measures  

• 
Of the 55 measures, around 85% of the measures aim to directly prevent or reduce nutrient 
pressures and a further 10% aim to indirectly reduce pressures. This is reasonably consistent 
across Member States. Given that legislation and policy is well established in this area, the 
measures across Member States tend to have a similar focus. There is evidence of some 
further measures being brought forward by ES and IT, including in relation to ship emissions, 
nutrient inputs from agriculture and aquaculture and from recreational vessels. No measures 
have been identified that are seeking to reduce the effects of eutrophication within the marine 
environment.    
• 
None of the Member States in the region provided a clear gap analysis so it cannot be 
considered that a coherent approach has been used. CY and SI provided partial gap analyses, 
while in ES it was not clear. No gap analysis was presented by FR or IT. No Member States 
clearly presented conclusions on future socio-economic development to determine future 
environmental pressures or a timeline for achieving GES, an analysis of how first cycle and 
updated existing measures will reduce pressures, or clear conclusions on the effectiveness of 
measures. Only SI and ES presented information on pressures/impacts and their influence of 
GES achievement, and FR makes some reference to pressures/activities. GES is considered 
achieved in some Member States (CY), and it is unclear in others (FR). Gaps identified related to 
coverage of PCB (ES) and TBT in seawater and mercury/benzo(a)pyrene in sediment (SI). There 
does not seem to be any coherence with regard to the gaps or barriers to achieving GES. 

•  MSFD-specific measures vs other measures  
Member States in the region have made clear links with existing legislation and policies. All 
Member States refer to UNEP-MAP, while all except SI refer to the WFD. CY, ES, FR and IT refer 
to the Nitrates Directive and IMO, specifically MARPOL (CY, FR, IT), and the London Convention 
(CY and FR). Other policies include the UWWTD (CY, ES, SI), while CY and SI refer to the IED. FR 
and IT refer to REACH, while ES and FR also refer to the Habitats Directive. No references are 

83 

Contaminants 
(D8) 

Moderate 
coherence 

Two  Member  States  out  of  five,  FR  and  SI, 
applied for exception, both under Art. 14(1)(a), 
but  for  different  reasons.  In  addition,  both 
applied for an exception under Art. 14(1)(e). FR’s 
justification was that action is needed either by 
the  EU  (e.g.  CFP)  or  by  another  international 
Competent Authority (e.g. IMO). SI applied two 
exceptions with separate justifications for TBT 
recent 
and  mercury.  However, 
monitoring data indicates that GES is now being 
achieved (and likely to continue to be achieved) 
and 
is  therefore  questionable  why  an 
exception is still needed. 

for  TBT, 

it 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

made to Zero Pollution targets, Barcelona Convention or National Ceilings Emissions Directive 
which are all potentially relevant updated existing measures for D8. Overall, considering both 
first and second cycle measures, the Member States relied to a similar degree on measures 
taken under other legislative/policy frameworks. CY and IT have reported only measures taken 
under other legislation/policy frameworks, and at 75% for FR and SI. ES is the outlier with most 
measures reported as being MSFD-specific (59%). Only CY and SI have taken new measures 
under other legislative/policy frameworks, e.g. on radioactivity pollution, sulfur emissions, 
agriculture and pollution from maritime transport.  

Coverage of pressures and activities  

• 
All Member States reported measures to address the pressure of input of synthetic and non-
synthetic substances and radionuclides. This pressure was reported for 100 out of 122 relevant 
measures. CY, ES, and IT also reported measures to address the input of water–point sources 
(e.g. brine). One ES measure also addresses (non)UPBT substances and acute pollution events 
specifically. The pressures reported can therefore be considered coherent across Member States 
in the region.  Almost all relevant activities are considered addressed by FR and ES and 4 out of 
the 5 countries also reported aquaculture and shipping.  

Purpose and content of measures  

• 
The new/modified measures in ES, FR, CY and SI cover some of the same pressures, in 
particular those caused by maritime transport and ports/marinas. However, the measures 
reported cover a wide variety of topics, including measures to improve knowledge and monitor. 
The measures also focus on the source activities, with only SI referring to reducing specific 
contaminants. It is noted that the majority of contaminants covered under D8 do not seem to 
be covered under the reported measures. In terms of the purpose of measures, there is 
moderate coherence. All Member States report measures to directly reduce existing levels of 
the pressures in the marine environment (e.g. removal of litter or oil spill clean-up). Most 
Member States (except IT) report measures to directly prevent further inputs of a pressure (e.g. 
by managing the source activity) or to directly prevent further inputs of a pressure (e.g. by 
governance mechanisms, financial incentives etc.). Measures to improve knowledge were only 
reported by ES and FR, while CY, ES and FR reported measures to establish monitoring 
programmes. Only CY reported D8 measures to directly restore a species or habitat. 

84 

 
 
 
Use of exceptions in the region 

No Member State applied for an exception. 

Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Contaminants  in 
seafood (D9) 

Poor coherence 

Coherence of gap analyses 

• 
None of the Member States provided a clear gap analysis, most reported partial (CY) to poor (ES, 
FR and SI) information on the essential elements of the gap analysis. Additionally, IT failed to 
submit  any  information  on  the  gap  analysis  for  D9.  It  is  worth  noting  that  neither  FR  nor  SI 
provided a quantitative gap analysis, although clear thresholds have been set for D9. As for ES, 
it is unclear whether all significant gaps to the achievement of GES for D9 have been identified, 
as the gap analysis provided is general and not broken down by descriptor. None of the Member 
States provide clear information on the current status of contaminants in seafood. However, CY 
refers to WFD and MED POL monitoring data, which suggest that GES is currently achieved for 
D9.  SI  states  that  the  available  monitoring  data  indicate  that  the  standards  laid  down  in 
Regulation 1881/2006 are met. No Member State referred to pressures/activities in relation to 
the gap analysis. No Member State provides information on the extent to which current measures 
will reduce pressures. In all Member States it is unclear whether the baseline used to inform the 
gap analysis considers future development activity, considers alternative scenarios or indicates 
the  extent  to  which  socio-economic  factors have been  taken into  account.  No  Member  State 
provides information on the effectiveness of the measures. All Member States fail to report on a 
timeline for achieving GES. 

•  MSFD-specific measures vs other measures  
All Member States, except ES, reported more measures under other legislative/policy frameworks 
than MSFD-specific measures for D9. IT and FR linked all their D9 measures to other frameworks. 
On the other hand, ES reported only MSFD-specific measures. Surprisingly, only CY explicitly refers 
to  Regulation  1881/2006  setting  maximum  levels  for  certain  contaminants  in  foodstuffs. 
Looking at the other policies linked to D9 measures, the most common are the WFD (ES, FR and 
IT) and the REACH Directive (FR and IT). Other frameworks are reported but only by one or two 
Member States every time (nitrates, MSP, UWWTD, UNEP-MAP and IMO instruments). Only ES 
defined an additional measure for D9 in the second cycle, although they did not carry out a gap 
analysis specifically for D9, focusing on studies to improve data collection on contaminants in 
fishery products and to propose new contaminants.   

Coverage of pressures and activities  

• 
Although specific to D9, the pressure ‘Contaminants in seafood’ is only reported by CY and ES, 
and for only 10% of all measures reported under D9. However, the two Member States do not 
associate  their  measures  with  a  specific  activity  causing  the  pressure.  The  most  frequently 

85 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

reported  pressure  is  ‘Input  of  other  substances  (e.g.  synthetic  substances,  non-synthetic 
substances, radionuclides)’, accounting for 84% of all reported pressures under D9 (ES, FR, IT and 
SI). Other pressures reported include: ‘Input of nutrients’ (ES, FR, IT, SI), ‘Contaminants - non UPBT 
substances’ (ES, FR), ‘Input of litter’ (ES, FR, IT) and ‘Input of organic matter’ (ES, FR, IT). Few of the 
measures (32%) are linked to the specific activities causing the pressures. ‘Waste treatment and 
disposal’ (FR) and ‘Urban uses’ (FR, SI) are the two most reported activities. Other activities include 
‘Transport  –  shipping’  (FR,  SI),  ‘Agriculture’  (SI),  ‘Industrial  uses’  (SI)  and  ‘Research,  survey  and 
educational activities’ (FR). Only ES and FR have identified MSFD-specific measures to address 
relevant pressures. However, the technical adequacy assessment concluded that it is not clear 
whether these measures address all relevant D9 pressures. This is due to the lack of detailed 
information from the gap analysis on significant pressures (ES) and the lack of quantification of 
the contribution of the measures to pressure reduction (ES, FR). It is also noted for both Member 
States that the vast majority of the measures identified are cross-cutting in nature, which is likely 
to have a limited impact on progress towards/maintenance of GES for D9.  

Marine 
(D10) 

litter 

Moderate to 
high coherence 

Coherence of gap analyses 

Purpose and content of measures  

• 
Considering all reported measures for D9 (first and second cycle), all measures reported under 
D9 are linked to a ‘measure purpose’. Most of the measures aim at indirectly preventing further 
pressure  inputs  (CY,  ES,  FR,  SI) and/or  directly  reducing  existing pressure  levels  in the  marine 
environment (ES, FR, IT). Fewer measures directly prevent further pressures (only SI), improve the 
knowledge base (ES, FR) and establish monitoring programmes (ES, FR). 
• 
All Member States in the region, except IT, provided a gap analysis which was considered 
partially adequate. Only SI present a clear overview of the current status as part of the gap 
analysis (GES is not achieved). ES, SI and CY provide some details regarding relevant pressures 
and activities causing marine litter and identify the priorities to be addressed by the update (e.g. 
reduction of litter inputs from various sources (aquaculture, fisheries, tourism, leisure and 
submerged vessels) (SI), focus on fishing-related waste and river-based input into the sea (both 
from agricultural as well as other sectors) (ES), seabed and floating microplastics (CY)). None of 
the Member States provide an estimation of how much the measures from the first cycle will 
reduce pressures nor conclusions on the effectiveness of the second cycle measures to close 
the gaps. Similarly, none of the Member States elaborate on baseline scenarios or considers 
future socio-economic developments. Finally, none of the Member States indicate a timeline for 
achieving GES.  

86 

Only SI applied for an exception under Art. 
14(1)(a), Art. 14(1)(b) and Art. 14(1)(e). SI’s 
reason is that marine litter is a transboundary 
problem (Art. 14(1)(a)), litter is brought to SI via 
marine currents and various rivers (Art. 
14(1)(b)), and the shallowness and enclosed 
nature of the Adriatic Sea mean concentrations 
of litter tend to accumulate in the northern part 
of the Adriatic Sea (Art. 14(1)(e)).  

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

•  MSFD-specific measures vs other measures  
ES, FR and CY provide many links to relevant existing policies, while IT and SI make fewer of 
such links. All Member States refer to UNEP-MAP in general (20 measures), while MARPOL is 
mentioned only by ES, FR and IT (9 measures). EU legislation is also a driver for defining 
measures, in particular the Waste Framework Directive (48 measures, all except SI). Other EU 
legislation is mentioned less frequently: WFD, SUP Directive, CFP, UWWTD or PRF Directive. All 
Member States except ES defined a balanced mix of measures taken under other frameworks 
and MSFD-specific. ES relied mostly on MSFD-specific measures. As a result of the gap 
analysis, all Member States, except CY, modified MSFD-specific measures from the first cycle 
or defined additional ones in the second cycle. The vast majority of these measures (86%) are 
specific to D10, i.e. they uniquely target marine litter. 

Coverage of pressures and activities  

• 
All Member States in the region, except CY, have made some progress during the second cycle 
in terms of pressure coverage. All Member States partially address the relevant pressures with 
new measures in the second cycle. The most relevant activities causing the pressure of litter 
inputs are targeted by all. The main focus is on specific litter sources in the marine environment 
(e.g., fisheries, shipping, leisure & tourism). In addition ES, SI and IT also include specific 
measures tackling land-based sources (waste waters), and IT and SI also tackle aquaculture 
specifically. Overall, there is more focus on macro-litter but some Member States (e.g. ES, IT) 
included specific direct measures for microlitter too. For some countries, the reported measures 
lack detailed descriptions making it difficult to assess their effectiveness fully (IT, FR). Around 
25% of measures (from ES FR and SI, the vast majority from ES) aim to directly prevent further 
inputs of a pressures (by reducing the source activity), 43% of measures (from ES, IT and SI) 
aim to directly reduce existing levels of the pressure in the environment (e.g., through removal 
of litter) and 26% of measures aim to indirectly prevent further input of a pressure. 

Purpose and content of measures  

• 
As far as macrolitter is concerned, IT, SI and FR put effort and focus on seabed and surface 
litter in addition to beaches. SI does this through measures that tackle fisheries, shipping and 
tourisms activities. Other Member States have more specific measures, e.g. expert group to 
identify the most appropriate measures to combat the impacts of litter on the seabed (IT) or a 
dedicated measure on macrolitter on beaches, seabed and sea surface for the highly touristic 
Western Med region (FR).  All Member States, except CY, address microlitter, but to different 
degrees. SI does so only indirectly with the inclusion of a measure on ‘fishing for litter’, as well 

87 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

No Member State applied for an exception. 

Underwater 
noise (D11) 

Moderate 
coherence 

Coherence of gap analyses 

as a measure to support municipalities in the implementation of the SUP Directive. FR and IT 
address microlitter together with macrolitter with a measure on waste- and storm-waters. ES 
takes several soft but specific measures to close knowledge gaps and raise awareness. Litter in 
biota is marginally addressed. SI has identified accumulation of micro-waste in fish as a 
significant pressure but does not take a measure. IT, ES and CY mention loggerhead turtle 
(Caretta caretta) in one of their targets but fail to include dedicated measures in their 
programmes of measures (except for knowledge improvement measures). 
• 
The information regarding the gap analysis varies across the Member States in the region. For 
ES, a gap analysis was carried out and described, but it focused mainly on progress against 
environmental targets. There is no information about the current GES status baseline scenario, 
consideration of how much current measures will reduce pressures, future socio-economic 
developments, or an indication of the timeline for when GES will be achieved. Similarly, FR 
carried out a gap analysis, but does not present enough details. SI and CY both stated that they 
did not carry out a gap analysis due to lack of data for impulsive noise or continuous noise. SI 
acknowledges that thresholds were not yet defined in 2022 when the PoMs was being 
updated. CY participated and benefited from the QuietMED2 and QuietSEAS European project, 
which are considered as contributing to the gap analysis. No conclusions or summary of 
findings from the project are presented though, and no rational, plan or measures are built 
upon those projects. However, CY does at identify the main activities causing the pressures in 
its waters: fishing and pleasure vessel for low continuous noise, and hydrocarbon exploration 
for impulsive noise. No information regarding the gap analysis was provided by IT. 

•  MSFD-specific measures vs other measures  
Measures for D11 are often linked to the Habitats Directive (ES, FR and IT) and the EIA Directive 
(CY, ES, IT). CY, ES and FR refer to UNEP/MAP policies. In particular, ES has a dedicated measure 
to implement Recommendations, decisions and documents approved by the Barcelona 
Convention (2016-2021) although it is a cross-cutting measure, and CY has a dedicated 
measure to implement the Offshore Protocol. ACCOBAMS is mentioned by ES and SI only, while 
IMO Guidelines on the assessment of impacts and the limitation of submarine noise are 
mentioned by IT and SI only. Overall, considering both first and second cycle measures, the 
Member States relied more heavily on measures taken under other legislative/policy 
frameworks than MSFD specific measures. ES, FR and SI defined both MSFD specific measures 
and measures taken under other legislative/policy frameworks, while CY and IT only relied on 

88 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

the latter. As a result of the gap analysis, even if clear shortcomings were not identified in most 
Member States, three MS (ES, FR and SI) have modified some measures from the first cycle or 
defined several additional ones in the second cycle, e.g. mitigation measures derived from IMO 
and ACCOBAMS to reduce continuous and impulsive underwater noise (SI) or measuree 
implementing LIFE projects (FR aimed at restoring and maintaining the good conservation 
status of natural marine habitats, ES consisting of pilot activities to mitigate underwater noise 
in areas of the Natura 2000 Network). 

Coverage of pressures and activities  

• 
The Member States in the region did not make much progress on D11 during the second cycle 
in terms of pressure coverage. The technical adequacy assessment concluded that ES and FR 
have partially adequately addressed all pressures. One measure from ES aims to minimise the 
emission of underwater noise in general and specifically from commercial and industrial 
activities. FR aims to collect and disseminate impulsive noise data from industrial operations. SI 
has two MSFD-specific measures, one addressing continuous sound for individual vessels and 
specific activities such as dredging and drilling and another one addressing impulsive sound. In 
terms of activities, all Member States address some relevant human activities causing both 
impulsive (dredging and pile drilling, defence operations (SI), renewable energy (ES)) and 
continuous noise (recreational activities (ES, FR and SI), fishing (ES, FR, SI), shipping (ES, FR), 
port activities (ES, SI)). FR talks generally about ‘industrial operations’. In the second cycle, IT did 
not report in detail, so it is impossible to understand what activities are addressed by its two 
D11 measures (one implementing EIA, VAS and environmental impact assessment and the 
other one ‘Guidelines relating to the assessment of impacts and the limitation of submarine 
noise’).  

Purpose and content of measures  

• 
Considering both first and second cycle reporting, most of the measures from all Member 
States in the region aim to reduce the input of sound. There are no measures aiming to reduce 
the pressure level in the environment. Around 32% of the measures are direct measures. 
Another 35% (mainly from FR) are indirect measures and there are several measures (mainly 
from ES and FR) still dedicated to improving the knowledge base and establishing monitoring 
programmes. Continuous and impulsive sound are equally addressed by ES, FR and SI. CY does 
not explicitly address activities causing continuous noise, while it is not clear what type of noise 

89 

 
 
 
Coherence of 
Programmes of 
measures 

Justification  

is addressed by the measures defined by IT. None of the Member States in the region address 
other anthropogenic input source such as heat/light.   

Use of exceptions in the region 

Descriptor 

Biodiversity 

Coherence of gap analyses 

• 
A gap analysis was undertaken by four out of five Member States in the region. Only FR is 
considered to adequately identify all significant gaps. SI and CY partially identify significant 
gaps, and ES very partially. Only CY and SI reported on the current status with detailed updates 
on the status of birds, marine mammals, reptiles, fish, cephalopods, and pelagic habitats. The 
FR gap analysis focuses on design of new measures and not current status. The ES analysis is 
restricted to progress on environmental targets. The need for additional data collection is 
identified by CY, FR and SI, in particular in relation to demographic and distribution data which 
is essential for mapping and tracking species populations. Only FR considers future socio-
economic development to determine future environmental. None of the Member States 
prepared a baseline scenario, nor indicated a timeline for achieving GES. 

Two Member States out of five, IT and FR, 
applied for exceptions for Descriptor 1, under 
Art. 14(1)(a) with different justifications. 

IT mentions “Benthic-feeding birds” but 
provides no other justification for the exception.  

FR’s justification is that the control to 
implement the measures lies with EU 
processes rather than France, notably under 
the Deep-Sea Access Regulation and the 
Technical Measures Regulation.  

Biodiversity (D1)  

Moderate 
coherence 

•  MSFD-specific measures vs other measures  
All Member States have measures linked to the Habitats and Birds Directives, the CFP and 
UNEP/MAP.  Links to MSP Directive (ES), EIA Directive (CY, IT), Biodiversity Strategy (FR, IT) and 
CBD (FR, IT) are less common. 
specific measures. IT and SI adpoted a larger number of extising measures, while the opposite 
is true for ES; CY did not adopt any MSFD-specific measures. With their MSFD-specific 
measures, ES and FR cover relevant pressures through direct measures while SI cover pressures 
indirectly.  

FR adopted a balanced mix of existing and MSFD-

Coverage of pressures and activities  

• 
CY, ES, FR, SI have all made some progress since the first cycle, but only FR has improved in 
terms of addressing pressures with targeted measures for habitats and species. FR, ES, SI and 
CY all aim to address disturbance of species, and extraction or mortality/harmfulness of wild 
species, but only FR and ES do it adequately, using direct and indirect measures. SI and IT 
measures are all indirect.  There is a lack of uniformity in addressing the same kind of pressure 
among the Member States: incidental bycatch is a common concern, yet approaches vary 
significantly. ES and FR aim to tackle a broader range of pressures, but with different focuses 
(species vs. habitats). CY, FR, SI also report on the activities causing pressures, in particular fish 
and shellfish harvesting (professional, recreational) and shipping. 

90 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Purpose and content of measures  

• 
While there is coherence in terms of the types of features that are addressed, the specific 
features on which Member States focus vary.  Generally, benthic broad habitats are the 
features most often targeted by D1 measures in the Mediterranean (ES, FR, IT, SI) although 
protection of seabed habitats falls more naturally under D6. Measures include protection of 
Posidonia beds (SI) or mapping of biogenic seabed (IT). Small-toothed cetaceans (all Member 
States) and baleen whales (CY, ES, FR, IT) are also commonly targeted features, for example 
through the education of fishermen on reducing bycatch (IT), the improvement of response to 
strandings (ES), and reducing the risk of collisions with vessels (FR).  Improvement or expansion 
of MPAs are reported by all Member States. ES, IT and SI report developing new MPAs, ES and 
FR focus on strengthening the management of existing MPAs. In some cases, particular 
features are targeted (e.g. biogenic reefs in SI) while in other cases protection is more general, 
based on the precautionary principle where data on biodiversity is limited. With the exception of 
CY, the Mediterranean Member States have made progress with regards to the protection 
target, with all reporting an aim to increase the percentage of their national waters which are 
protected. 
• 
Only ES and SI undertook a clear gap analysis. Except IT, all other Member States provide a 
clear overview of the current status. GES has not been achieved in these Member States 
acknowledging lack of data for assessing NIS introductions. Only three Member States 
specifically present pressures and activities causing new introductions: CY (aquaculture, ballast 
waters and hull fouling), FR (import of fauna and flora, ballast waters and introduction and 
transfer of aquaculture species); SI (hull fouling and ballast water discharges). While the gaps 
are not clearly defined in most Member States, FR identifies priorities for the measures update 
for D2 and SI states that GES for D2 should be achieved through cross-border (sub)regional 
responses. The elements of the gap analysis that were more difficult to elaborate on are 
baseline scenarios (only SI), and consideration of future socio-economic development to 
determine future environmental pressures. Most importantly, all Member States fail to report on 
a timeline for achieving GES. 

Coherence of gap analyses 

•  MSFD-specific measures vs other measures  
All Member States link their measures for D2 to relevant existing policies. All Member States 
refer to the Invasive Alien Species Regulation. FR, IT, CY, and ES refer to the CFP, FR and SI refer 
to UNEP-MAP, only FR and CY mention the IMO Ballast Water Convention. SI has referred to 

91 

Only CY applied for an exception in this region 
for D2 under Art. 14(1)(a), giving the reason 
that the Suez Canal is the most significant 
source of introduction and increase in NIS, and 
there are inherent difficulties in dealing with 
and preventing the introduction of NIS through 
it. Taking preventive measures is not possible 
since the management of the Suez Canal is 
not under the control of the EU or any Member 
State and therefore no measures can be 
taken/implemented at this level. 

NIS (D2) 

Moderate 
coherence 

 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

national and other policies. All Member States in the region are coherent in linking their 
measures to specific legislation/policies. CY considered measures only taken under other 
legislative/policy frameworks for D2, whereas ES mostly relied on MSFD-specific measures. FR, 
IT and SI adopted both measures under other legislative/policy frameworks and MSFD-specified 
measures. FR, IT and ES identified additional MSFD-specific measures as a result of gap 
analysis. Few measures are specific however. 

Coverage of pressures and activities  

• 
ES, FR, IT have made some progress during the second cycle regarding D2 in terms of pressure 
coverage, but they have only partially addressed the relevant pressures. SI does not report any 
modified or additional MSFD specific measures specific for D2 and rather rely on measures 
taken under other frameworks. The most relevant activities causing the pressures for D2 are 
targeted by most Member States (FR, CY, SI, ES) in the region: aquaculture, tourism and 
shipping. CY have also identified some measures which cover research, survey and educational 
activities.  

Purpose and content of measures  

• 
Most of the measures focus on managing sources of activities by directly preventing further 
inputs of a pressure (e.g. CY - Control and / or limitation of the use NIS in aquaculture through 
the implementation of regulation, SI - regulating the introduction of NIS into the aquatic 
environment); a small portion of measures from ES and IT are aimed at directly reducing 
existing levels of the pressure in the marine environment (e.g. control and management of 
biofouling of vessels to minimize the transfer of aquatic invasive species respectively). Most 
Member States (IT, ES, FR, SI) report measures to establish monitoring programmes (of relevant 
activities, pressures, or impacts) and measures to indirectly prevent further inputs of a pressure 
(e.g. by governance mechanisms, financial incentives etc.) 
• 
A gap analysis was undertaken by all Member States in the region, except for IT. Only SI 
provided an overview of current status for D3, highlighting the overfishing conditions of its 
stocks and declining trends in cephalopods’ landings. FR, CY and ES provides a partial overview 
of current status. Only FR and SI state clearly that professional or recreational fishing activities 
are contributing to the pressure. No information regarding how much the first cycle measures 
reduce pressures is presented by any of the Member States. CY, ES, and SI still conclude on the 
need to define additional measures (e.g. monitoring programmes for pelagic species (CY) and 
measures for recreational fisheries (ES)). FR highlights the need for additional measures for 

Coherence of gap analyses 

92 

Commercial fish 
and shellfish 
(D3) 

Moderate to 
high coherence 

No Member State applied for an exception. 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

locally-managed stocks and recreational fisheries. The elements of the gap analysis that were 
more difficult to elaborate are baseline scenarios, and consideration of future socio-economic 
development to determine future environmental pressures (only presented by FR). Most 
importantly, all Member States failed to report on a timeline for achieving GES.   

•  MSFD-specific measures vs other measures  
All Member States provide links to relevant existing policies for D3 in particular the CFP. ES and 
CY also refer explicitly to EMFAF and CY, ES and IT to the DCF. All Member States except ES 
refer to the GFCM. Other EU legislation and policies are also drivers for defining measures, e.g. 
Birds and Habitat Directives (ES, FR and IT) and WFD (ES and FR), Biodiversity Strategy (IT) and 
MSP Directive (ES). ES, FR and IT also refer to UNEP-MAP. CY and SI rely only, and IT 
predominantly, on measures taken under other frameworks and ES mostly relied on MSFD-
specific measures. FR defined a balanced mix of already established and MSFD-specific 
measures. As a result of the gap analysis, all Member States except CY have modified or 
added MSFD-related measures. ES and FR have included measures regarding the strengthening 
of control and surveillance of fisheries (e.g. fight against IUU fishing and installation of onboard 
remote electronic monitoring systems – ES or developing skills of different users such as 
community agents or coast guard – FR) and the same plus IT have added or modified a 
regulatory framework for recreational fishing (e.g. moratorium on recreational fishing of species 
of high conservation value such as grouper and corvina).  

Coverage of pressures and activities  

• 
All Member States have measures that address the main pressure for D3, which is extraction of 
species. Only FR adequately address all relevant pressures with the new measures in the 
second cycle, ES, IT, SI and CY only partially address relevant pressures, while SI and CY did not 
report any new measures specific to D3. The most relevant activity causing the pressures, 
fishing (both commercial and recreational), is targeted by all Member States in the region. In 
addition, some Member States identified other sources of pressure that might impact D3 such 
as activities related to research (CY and ES), dredging (FR and ES), and aquaculture (ES, FR and 
SI) as contributors to the status of fish and shellfish and defined new measures to address 
them. 

Purpose and content of measures  

• 
In total 97 measures address the extraction of species (fishing) by all Member States. The vast 
majority (80% of all measures) aim to directly reduce the pressure level in the environment 

93 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

(e.g. implementation of fishing management plans, enforcement of discard policy, measures to 
protect specific species) or the input of the pressure (e.g. limiting the use of trawl nets, 
adaptation of practices of professional fishermen); 7% of measures aim to indirectly prevent 
further input of the pressure (e.g. governance mechanisms, financial incentives or awareness 
campaigns). Another 13% of measures aim to improve knowledge and establishing monitoring 
programmes (from ES, FR and IT) and three measures by CY, ES and FR also aim to directly 
restore species or habitats (e.g. fish population restoration by implanting artificial reefs (FR)). A 
few measures (explicitly) mention recreational fisheries in ES, FR and IT. The adequacy 
assessment particularly underscores the efforts of ES, IT and FR in implementing measures 
that effectively cover local and national stocks not regulated under the CFP.   
• 
None of the Member States in the region have carried out an adequate gap analysis, FR and SI 
have done so only partially, CY and IT do not report a gap analysis for D4, and information is 
unclear for ES. None of the Member States describe current status in a great extent. SI limits 
discussion to the state of primary seabed producers under D5 (human-induced eutrophication) 
and FR focuses on status of species linked to D1. Fra and SI discuss pressureson food webs, 
though SI limits this to eutrophication and FR assumes that the same pressures as D1 apply on 
food webs. Only FR reports clear conclusions of the effectiveness of previous measures, 
presents a baseline scenario and considers future socio-economic development, but together 
with D1, not separated for D4.  No timelines for achieving GES are discussed. 

Coherence of gap analyses 

•  MSFD-specific measures vs other measures  
All Member States link their D4 measures to other frameworks.  SI only reports three measures 
for D4, all national, so is not covered by the following analysis.  Member States make links to 
the Habitats and the Birds Directives, the CFP and the WFD (only FR), as well as UNEP-MAP. CY, 
FR, and IT mention the Biodiversity Strategy. Only ES defined MSFD-specific measures for D4. 

Coverage of pressures and activities  

• 
Only ES and FR have adequately addressed previously identified pressures, while SI does this 
only partially and the information is not clear for IT due to a lack of detail in the gap analysis 
and the measures themselves. CY only reports first cycle measures. The main pressures 
addressed by measures are species extraction and disturbance, introduction of invasive species, 
input of sound and disturbance of seabed habitats. Only CY, ES, and FR address all of these, 
but extraction and disturbance of species are addressed by all Member States (apart from SI).  
The main activities addressed by measures include, extraction of species (fishing), tourism, 

94 

Only FR has reported exceptions for Descriptor 
4 under Art. 14(1)(a), reasoning that fishing of 
fodder species is covered under the common 
fisheries policy (CFP). As FR is not solely 
responsible for the CFP, the European 
Commission must ensure that actions are 
being taken to meet this objective under the 
CFP and that fodder species are being 
protected. 

Food webs (D4) 

Poor coherence 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

research, restructuring of habitats, aquaculture, transport, urban uses, military activities, and 
extraction of non-living resources. ES, FR, and SI address all these activities, while CY only 
mentions three: fish harvesting, fish processing and research, and IT only tourism.  

Purpose and content of measures  

• 
The main features covered include birds, mammals, fish and benthic habitats, with mammals 
and fish covered by all Member States and pelagic habitats by all except IT. Cephalopods, 
reptiles and ecosystems overall are also addressed, but to a lesser extent. Fisheries-related 
measures reported by almost all Member States (ES, FR, IT, SI) included monitoring of fisheries, 
development of training measures for fishing operators, and prevention of negative impacts of 
marine aquaculture. ES addresses D4 through the expansion of existing MPAs, designation of 
new sites and review of management plans. FR, IT and SI partially address D4 pressures 
through spatial protection, but details are lacking.  No new spatial measures are reported for 
CY. Slightly less than half of the measures aim to reduce or prevent inputs of pressures, the 
rest relate to monitoring, gaining knowledge or assessing effectiveness of measures. CY and IT 
report considerably more direct measures, FR more indirect measures and ES and SI an equal 
share of direct and indirect measures. 
• 
Coherence of gap analyses 
A clear gap analysis was carried out by FR and SI. The gap analysis provided by ES was not 
clear, and only consisted of a table of targets and associated measures. CY provided only a 
partial gap analysis and IT did not provide any. SI is the only Member State to provide a clear 
overview of the current state of the seabed. FR falls short of providing a comprehensive 
overview on the current environmental status of seabed habitats. ES, CY, and IT do not provide 
any overview of the current state of the seabed. None of the five Member States explicitly 
identify relevant pressures and activities. Only SI assessment of the current state implicitly 
identifies pressures and activities causing damage by detailing the state of seabed habitats 
and the extent of their degradation or loss. While the gaps are not clearly defined for CY, ES 
and IT, SI and FR identify clear gaps in the progress towards GES, however FR gaps are tailored 
more to D1. Clear conclusions are not provided for FR, IT or ES regarding the effectiveness of 
measures. ES explains this lack of effectiveness analysis is due to a lack of information, lack of 
monitoring programmes and poorly defined targets. The gap analysis for FR focuses more on 
presenting new measures to fill gaps and does not discuss effectiveness, and IT does not report 
any gap analysis information. None of the Member States elaborated on baseline scenarios as 
a benchmark against which alternative options are compared, nor did they consider future 

95 

FR is the only Member State to apply for an 
exception under Art. 14(1)(a). FR reasons that 
action is required from the European 
Commission for the measures to be 
implemented, which is out of the control of the 
Member State. FR argues that the European 
Commission must undertake the necessary 
mapping of VMEs under the deep-sea fisheries 
regulation using Member State data.  

Seabed habitats 
(D6) 

Moderate 
coherence 

 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

socio-economic development to determine future environmental pressures. All Member States 
fail to report on a timeline for achieving GES. 

•  MSFD-specific measures vs other measures  
All five Member States link their D6 measures to the Habitats and Birds Directives, the WFD 
and the CFP. Only ES reports the MSP Directive as relevant and only two Member States 
mention the CBD (FR, IT). All Member States establish links between their D6 measures and the 
Barcelona Convention. Overall, considering both first and second cycle measures, Member 
States mostly relied for D6 on measures taken under other legislative/policy framework. Only 
ES relied heavily on MSFD-specific measures. CY did not report any MSFD-specific measures 
under D6. As a result of the gap analysis, even if clear shortcomings were not identified in most 
Member States, all of them, except CY, modified measures from the first cycle or defined 
additional ones in the second cycle. The proportion of these measures which are specific to D6 
is low at only 23%. These specific measures target seabed integrity through reducing relevant 
pressures such as extraction, physical loss, and physical disturbance. The remaining measures 
are reported as relevant to more than one descriptor and are therefore more general actions 
(often also cover D1 and D4). 

Coverage of pressures and activities  

• 
The main pressures affecting seabed habitats include both physical loss and physical 
disturbance of the seabed. Considering both first and second cycle measures, only ES and SI 
identified additional measures addressing both pressures. Overall, most D6 measures overlap 
with descriptors D1 and D4, indicating a general approach rather than specificity to the 
essential pressures on seabed integrity (physical loss and disturbance). Other recurrent 
pressures include biological disturbance to species and extraction of species (CY, ES, FR, IT and 
SI), biological cultivation of habitats (ES, FR, IT, and SI) and input of litter (CY, ES, FR, IT and SI). 
Only half of the measures addressing physical loss and disturbance of the seabed reported by 
ES and SI are tied to activities. The most common activity causing physical loss and 
disturbance of the seabed is identified as fishing, as in the first cycle. Others include transport 
infrastructure, tourism and recreation, and agriculture. The technical adequacy assessment 
concluded that ES and SI adequately address all the relevant pressures with the MSFD-specific 
measures reported in the second cycle. FR and IT only partially covers the relevant pressures. All 
Member States in the region, with the exception of CY, have made progress in improving the 
coverage of D6 pressures in the second cycle.  

96 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Purpose and content of measures  

• 
Looking at both first and second cycle reporting, ES and SI (the only Member States to address 
the two relevant pressures) report more measures that prevent further inputs of the pressure 
(86 %), than measures aimed at directly reducing its existing level in the environment (13 % 
from only ES) or measures directly restoring a species or habitats (19% from only ES). Only 
32% of the measures are direct measures, managing the source activities; 53% are indirect 
measures aiming at preventing further inputs of a pressure (e.g. by governance mechanisms, 
financial incentives, awareness campaigns). Additionally, a high proportion of measures is 
dedicated to improving the knowledge base (32% from ES and SI), and a few measures are 
aimed at establishing monitoring programmes (9% from ES) and even fewer aimed at 
assessing their effectiveness (2% from ES). Most Member States rely on spatial protection and 
MPA measures to reduce both physical loss and disturbance of sensitive seabed habitats. Aside 
from CY which did not report any new measures, all four remaining Member States reported 
new spatial protection measures. A large proportion of the spatial protection measures reported 
under D6 are also reported under D1. In some cases (notably in SI), habitat-specific protected 
areas are proposed, for example to protect Zostera beds, detritus beds, rock reefs or biogenic 
reefs.  
• 
Almost all Member States (CY, ES, FR, SI) reported a gap analysis, but only CY and ES do so 
with D7 specific findings. SI merely reports information about expected improvements related 
to permanent alteration of hydrographical conditions. CY, ES and SI mention that there is a 
need for better data, knowledge, and understanding of the effects of human activities and 
hydrographical changes on marine ecosystems. An overview of the current status is not given 
by any of the Member States, nor it is estimated how much measures taken under other 
legislative/policy frameworks will reduce pressures. A baseline or consideration of future socio-
economic development to determine future environmental pressures was not given either, and 
clear conclusions on the effectiveness of measures were missing as well as a timeline for when 
GES would be achieved. Coherence is poor in both the methodological approach and the 
conclusions on assessment of status (missing for all Member States) and gap analysis. No 
common forward vision has been reported for future activities and pressures that could hamper 
achievement of GES for D7 by causing permanent alteration in hydrological conditions. 

Coherence of gap analyses 

•  MSFD-specific measures vs other measures  

97 

Hydrographical 
changes (D7) 

Poor coherence 

No Member State applied for an exception 

 
 
 
Descriptor 

Coherence of 
Programmes of 
measures 

Justification  

Use of exceptions in the region 

Most Member States report a single policy linked to the measures relevant to D7: EIA Directive 
(CY, IT) Habitats Directive (FR, SI) and WFD (ES, FR). The MSP (ES), Birds Directive (SI) and 
UWWTD (FR) were least mentioned. Few Member States (FR, SI) mention measures linked to 
UNEP/MAP. Considering the measures taken under other legislative/policy frameworks and 
MSFD-specific measures, SI defines a balanced mix of both, whereas CY relied more on the 
first type, and ES relied more on the second type. The Member States in the region fail to 
mobilise the MSP Directive that could provide forward-looking vision of activities, pressures and 
impacts. Almost all Member States report MSFD-specific measures (ES, FR IT, SI), but only a 
small portion of the measures are linked specifically to D7 (ES, FR). The other measures are 
reported as being relevant to more than one descriptor (and also cover in particular D1 and D6). 

Coverage of pressures and activities  

• 
According to the adequacy assessment, none of the Member States have made progress on 
the coverage of relevant pressures. Only ES and FR report measures on a D7-related pressure, 
which are related to reducing the level of impact on hydrographical changes. In the second 
cycle the Member States do not cover activities in a coherent way. Both ES and FR have 
measures related to sediment management, while the other Member States’s measures cover 
activities that are less relevant for D7. SI D7 measures mostly cover aquaculture, and 
protection of the seabed. In IT, the D7 measures are related to the input of sound and energy. 

Purpose and content of measures  

• 
Considering both first and second cycle reporting, more than half of the MSFD-specific 
measures aim at reducing the input of pressures, of which about half addresses the pressures 
directly (ES, FR, SI), and half do so indirectly (ES, FR, SI). Only one MS (ES) provides a few 
measures to assess the impact/effectiveness of measures or restoring of an ecosystem. Half of 
the measures aim at improving the knowledge base, for example by conducting research (ES, 
FR, IT, SI). Regarding the content of measures, there is great variety between the second cycle 
MSFD-specific measures reported by the Member States (ES, FR, IT, SI; CY did not report). While 
ES and FR measures focus on sediment management, ES reports measures to improve the 
knowledge base on coastal and marine ecosystems, while FR measures are linked to salinity 
changes. The measures of other Member States are not related to D7 content-wise (IT, SI). 

98 

 
 
 
 
5. Governance 

Out of the 17 Programmes of measures assessed, six Member States (243) provided highly adequate 
information with regard to cross-cutting and governance issues, eight Member States (244) provided 
information of average quality and three Member States (245) scored low. 

The  following  sections  look  in  more  details  at:  public  consultations;  cooperation  with  other 
authorities/policy  areas;  integration  of  EU  policy  objectives;  integration  of  socio-economic 
considerations into the design of the programmes of measures; and funding.  

5.1  Public consultations  

The  majority  of  Member  States  reported  conducting  a  public  consultation  and 
provided the dates the consultation ran for (see table 1). Only two Member States (246) 
did  not  report  holding  a  public  consultation,  two  (247)  reported  conducting  a  public 
consultation  but  not  receiving  any  views  and  another  two  (248)  provided  very  limited 

information which does not allow for the assessment of the scope of their consultation and  

The  remaining  eleven  Member  States  (249)  provided  detailed  information  on  the  public 
consultation they conducted, including the dates of the consultation (often lasting between one 
and three months) and the type of engagement with stakeholders (although they did not all provide 
information on the stakeholders who were invited or who participated). Some Member States (250) 
explicitly stated they made the entire programmes of measures available for comment to the public.  

Five Member States (251) offered various means of giving feedback besides or ahead of the online 
consultation: they organised workshops, seminars and bilateral meetings with targeted stakeholders 
to gather a broad range of comments. Only one Member State (252) indicated consulting neighbouring 
countries as part of its consultation process.  

Two  Member  States  (253)  conducted  an  active  promotion  campaign  to  advertise  the  public 
consultation, one (254) by inviting participants on social media while  the other (255) launched it in a 
national  newspaper  and  followed  up  with  an  intensive  promotion  campaign.  That  Member  State 
reported a high level of engagement as a result with the submission of 188 contributions. 

Overall, the public consultation process was duly followed (Table 2).  

(243) EE, FI, LT, LV, PL and SE 
(244) BE, CY, DE, FR, IE, NL, PT and SI 
(245) ES, IT and RO 
(246) IT and LT 
(247) CY and SI 
(248) FI and RO 
(249) BE, DE, ES, FR, IE, NL, PL, PT, SE, EE and LV 
(250) DE, FR, LV, PL and PT 
(251) BE, DE, ES, IE, NL, SE and PL 
(252) EE 
(253) IE and PL 
(254) IE 
(255) PL 

99 

 
 
Table 2. Overview of public consultation periods conducated by Member State 

Member state 
Belgium 
Cyprus 
Germany 
Estonia 
Spain 
Finland 
France 
Ireland 
Italy 
Lithuania 
Latvia 
Netherlands 
Poland 
Portugal 
Romania 
Sweden 
Slovenia 

Public consultation period 
1 July – 30 September 2021 
April 2023 for 3 weeks 
1 July – 31 December 2021 
15 December 2022 – 13 January 2023 
8 July – 15 September 2022 
1 February – 14 May 2021 
20 May – 20 August 2021 
7 March – 30 May 2022 
No information 
No information 
15 November – 14 December 2022 
20 October – 10 November 2020 
7 July – 5 October 2021 
2 November – 3 December 2022 
March 2022 
1 November 2020 – 30 April 2021 
December 2021 – January 2022 

While the majority of Member States were diligent in conducting a public consultation, they differ 
greatly in their responses about reporting information from the public consultation.  

Two Member States (256) did not mention whether the views received from the public consultation 
were taken into account when finalising the  programmes of measures. Seven Member States (257) 
reported taking into account the results of the consultation into the final programmes of measures. 
They do not explain, however, to what extent the programme of measures was amended 
as  a  result  or  which  specific  measures  were  added,  adjusted  or  removed  following  the  public 
consultation. Four Member States (258) provided extensive information, both quantitative and 
qualitative,  on  the  feedback  received  during  the  public  consultation.  They  all  reported 
dedicating time to address the feedback using a comprehensive methodology and reported amending 
the programmes of measures resulting from the feedback received.  

5.2  Cross-policy cooperation  

Member States overall acknowledged the links between their MSFD Programmes 
of measures and other EU legislation (in particular the Water Framework Directive 
(WFD), the Maritime Spatial Planning (MSP) Directive, the Common Fisheries Policy (CFP), 
and  the  Habitats  and  Birds  Directives).  Member  States  described  how  policies  and  international 
agreements impact the update of their Programmes of measures and explained that some of the 
measures included in their MSFD Programmes of measures are or will be delivered under 

(256) RO and LV 
(257) DE, ES, FI, EE, IE, NL and SE 
(258) BE, FR, PL and PT 

100 

 
 
 
other policies. Most Member States, however, did not elaborate on the governance and coordination 
mechanisms between the different policies and the outcomes of these processes.  

5.2.1  Cooperation across different authorities 

Nine (259) out of 17 Member States clearly reported coordination between the MSFD and the WFD 
through measures that will be delivered under their national River Basin Management Plans (RBMPs) 
that  will  also  address  MSFD  objectives  related  to  D5  (Eutrophication),  D8  (contaminants)  and  D9 
(contaminants in seafood). Four Member States (260) provided additional detail on the governance 
mechanisms  to  coordinate,  implement  and  monitor  measures  from  the  RBMPs  and  the  second 
programmes of measures. The other eight Member States (261) described links between the MSFD and 
the WFD but did not elaborate on the mechanisms and/or governance for coordination or the 
outcomes of coordination. 

Coordination between the MSFD and the WFD: examples 

In Germany, coherence between the MSFD and WFD is ensured through work by LAWA (Federal Government/Länder 
Working Group on water issues) and BLANO (Federal Government/Länder Working Group on the North Sea and Baltic 
Sea).  For  example,  both  authorities  established  a  common  catalogue  of  measures  which  are  relevant  to  both  the 
objectives of the MSFD and the WFD. This catalogue will be updated according to the implementation cycles of the MSFD 
and the WFD.  

In Spain,  coordination  occurs  between  competent  authority  for  the  implementation  of  MSFD  (sub-directorate  for  the 
protection of the Sea of the Directorate General of the Coast and Sea) and the inter-community river basin districts who 
are  responsible  for  the  implementation  of  RBMPs.  For  example,  the  authorities  responsible  for  the  MSFD  submitted 
contributions to the 2022-2027 RBMPs for ten inter-community river basin districts and thirteen intra-Community river 
basin districts during the consultation periods of the different RBMPs.  

In Finland, coordination between the MSFD and the WFD was organised through close cooperation between planning 
systems at the ministerial, agency, and expert levels. For example, the Åland provincial government cooperated with the 
Ministry  of  the  Environment  and  the  Southwest  Finland  ELY  Centre.  Additionally,  the  Åland  provincial  government 
developed its own second Programmes of measures with strong consideration of the contents of its RBMP for the WFD.  

Fourteen (262) out of 17 Member States provided high-level descriptions of the common objectives 
between  the  MSFD  and  the  MSP  in  their  text  reports.  Thirteen  Member  States  (263)  included 
measures related to maritime spatial planning in their second programmes of measures. 
For example, one Member State (264) included a measure on establishing areas that will be free from 
permanent anthropogenic interference via its maritime spatial plans, while another (265) included a 
measure on the review of the national maritime spatial planning framework every six years.  

None of these Member States, however, provide information on coordinated governance 
for the two policies. Two Member States (266) provided information on the national legal framework 
for implementing maritime spatial planning in their marine waters and highlighted that the authorities 

(259) CY, DE, EE, ES, FI, LV, LT, PL, SI 
(260) ES, FI, DE and PL 
(261) BE, FR, IE, IT, NL, PT, RO, SE. 
(262)  BE, DE, EE, ES, FI, FR, IE, IT, LV, NL, PL, PT, RO, SE,  
(263) CY, BE, DE, EE, ES, FR, IE, IT, LV, PL, RO, SE, SI.  
(264) PL 
(265) IE 
(266) CY and SE 

101 

 
 
responsible for delivering specific objectives under the MSFD are the same ones who are responsible 
for delivering their national maritime spatial plans.  

5.2.2 

Integration of EU policy objectives  

Only a few Member States (267) explicitly refer to the broader objectives of the European Green Deal 
in their programmes of measures. On the other hand, most of the Member States (268) mention 
links to the Biodiversity Strategy, although specific reference to the target of 30% protected sea 
area  of  which  10%  must  be  strictly  protected  (30/10  protection  target)  are  limited.  Many  of  the 
measures  defined  in  the  second  programmes  of  measures  contribute  to  the  objectives  of  the 
Biodiversity Strategy, and in particular D1-related measures designating MPAs in areas of high human 
activity,  but  it  is  often  unclear  to  what  extent,  in  the  absence  of  quantified  data  on  these  new 
designations.  Member  States  rarely  detail  mechanisms  and  outcomes  for  coordination 
between the MSFD and the Zero Pollution Action Plan (269), however, clear linkages can be seen 
directly in the additional measures for litter, nutrients and contaminants identified in the second cycle.  

As for the Fit for 55 package and the EU’s target of reducing net greenhouse gas emissions by at 
least  55%  by  2030,  only  two  Member  States  (270)  present  initiatives  that  contribute  to  climate 
objectives, with one of them (271) aligning its National Energy and Climate Action Plan and the National 
Strategy for Adaptation to Climate Change with the MSFD programmes of measures. The other one 
(272) highlights the role of the MSFD in contributing to climate neutrality. Most Member States included 
measures that directly or indirectly relate to climate change in their Programmes of measures. It is, 
however, complex to understand the degree to which the measures contribute to tackling the climate 
crisis. More details are provided above in section 3.3. 

Linking national Programmes of measures to EU policy targets  

Latvia stands out among all Member States for its explicit presentation of European Green Deal priorities and how they 
are linked to the MSFD, as well as how governance in other regional and national policies is linked to achieve common 
Green Deal objectives. It also describes in detail how the objectives of the Biodiversity Strategy are incorporated into its 
marine  and  coastal  management  strategies.  The  country  presents  the  Biodiversity  Strategy  in  connection  with  other 
regional and national policies, which embrace the sustainable blue economy approach (273) and plan to contribute to the 
protection of 30% of the EU’s marine area. It is finally one of two Member States to clearly link its MSFD Programmes of 
measures to the Fit for 55 climate targets.  

(267) BE, CY, NL, PT 
(268) BE, CY, DE, EE, FI, FR, IE, IT, LV, NL, RO, SE.  
(269) Only LV and CY do so explicitly: Latvia connects its delivery of the EGD through the ZPA and presents the HELCOM Baltic 
Sea Action Plan as a way to address issues like eutrophication and waste. Cyprus  makes reference to the national plans 
compatible with ZPA without detailing their integration with the MSFD.  
(270) LV and CY  
(271) CY 
(272) SI 
(273) See the Communication on a new approach for a sustainable blue economy in the EU Transforming the EU's Blue 
Economy for a Sustainable Future COM/2021/240 final 

102 

 
 
 
5.3  Integration of socio-economic considerations into the design 

of the programmes of measures 

5.3.1  Costs and benefits of MSFD programmes of measures 

Out of the 17 Member States assessed, 16 Member States (274) reported performing a 
cost-benefit  (CBA)  and/or a  cost-effectiveness  analysis  (CEA).  Six  Member  States  (275) 
performed such analyses for all new measures, while ten (276) only analysed some of 
their new measures. These analyses were useful and a timely input in the evaluation of 

the MSFD which was carried out in parallel.   

Methodologies 

Five Baltic Member States (277) carried out a cost-benefit analysis which involved a comparison 
between  the  total  cost  to implement  the  second  programmes  of measures  against  a  quantitative 
estimate of the benefits of improvements in the status of the marine environment.  

One Member State (278) used a different approach by looking rather at the use of marine resources 
and costs of degradation (279). They reported that added value from activities related to the marine 
environment (e.g. fisheries, maritime transport, marine aquaculture, tourism) is estimated at EUR 545 
million in 2016. They also reported that around 14,600 people (full-time equivalent) were employed 
in marine sectors and activities, representing 2.2% of total employment in the country. 

The ‘effectiveness’ part of the cost-effectiveness analysis performed by Member States involved 
developing effectiveness criteria and using expert judgement to assess individual measures against 
these  criteria  (280).  A  number  of  Member  States  (281)  summarised  the  most  and  least  cost-
effective  measures  and  the  descriptors  they  are  relevant  for.  Only  two  Member  States  (282), 
however, explained how the CEA results influenced the selection of measures for their second-cyle 
Programmes  of  measures.  Some  Member  States  (283)  stated  that  these  analyses  influenced  the 
selection or prioritisation of their measures, but there is no sufficient information in their reports to 
demonstrate  how  this  was  done  (e.g.  abandoning measures  due  to  poor  cost-efficiency)  and  only 
details on the methodology for the CBA and/or CEA were provided.   

Costs 

Eight  Member  States  (284)  provided  a  summary  of  the  monetary  amounts  associated  with 
implementing the measures. The information, however, is not fully consistent: one Member States 
(285) provided information on the budget for their programme of measures, while seven others (286) 
provided information on the (estimated) costs attributable to measures for individual or groups of 

(274) BE, EE, DE, ES, FI, FR, IE, IT, LV, LT, NL, PL, PT, RO, SE and SI. CY also reported undertaking a CBA and a CEA but their 
text-based report only showed a categorisation of cost for each measure given three categories of high, low and medium.   
(275) ES, FR, SE, LV, LT and EE.  
(276) BE, DE, FI, IE, IT, NL, PL, PT, RO and SI.  
(277) FI, LT, LV, PL, SE. 
(278) SI 
(279) Article 8c of the MSFD. 
(280) Not all Member States (e.g. IT, PT) reported on the methodology used for their cost-effectiveness analysis.  
(281) FR, EE, LV, LT 
(282) SE and PL 
(283) IT, LV, LT, NL, RO, SI 
(284) EE, FI, LT, LV, NL, PL, SE, SI 
(285) NL 
(286) EE, FI, LT, LV, PL, SE, SI.  

103 

 
 
descriptors. Three Member States (287) presented the estimated costs of individual measures in the 
context of the CBA and/or the CEA. One Member State (288) provided a breakdown of the budget set 
aside for MSFD-related activities over the period 2022 to 2030 focusing on biodiversity and fisheries: 
EUR 5 million for monitoring, research, and nature restoration, EUR 14 million for maintenance of 
fisheries measures and EUR 19 million for restructuring and sustainability of the cutter fleet.  

The cost of the second MSFD programmes of measures, as reported by Member States 

Estonia reported a cost of EUR 46.3 million to implement their programmes of measures over the 2022 to 2027 period. 
These costs cover one-off and recurring costs. 

Finland reported a cost of EUR 299 million for their programmes of measures over the period 2022 to 2027, with EUR 
223 million for investments, EUR 59 million for direct costs, and EUR 9 million to cover the workload of authorities. 

Lithuania  reported  a  one-off  cost  of  EUR  5.5  million  plus  EUR  0.5  million  of  recurring  costs  for  their  programmes  of 
measures.  

Latvia reported that the total direct financial cost of the measures is between EUR 2.473-2.533 million for the 2022 to 
2027 programming period, or EUR 0.412-0.422 million on average per year.  

Poland reported a total cost of PLN 2.9 billion for their second programmes of measures. They stated that this amount 
does not include running costs of some continuous measures.  

Sweden estimated that in the period 2022 to 2040, the measures included in their second programmes of measures cost 
between SEK 0.18-0.87 billion, with a mid-point estimate of SEK 0.53 billion. 

Slovenia reported a total cost of EUR 18.23 million for their second programmes of measures over the period 2022 to 
2027.  

After adjustments of the data provided by six of these Member States (289) to reflect equivalent annual 
costs  in  EUR  (290)  and  in  2020  prices  (291),  MSFD  measures  in  this  second  programmes  of 
measures have been estimated at an average cost of 724 EUR per km2 of marine area per 
year (Table 3).  

Table 3. Cost of Measures for selected Member States 

Member 
State 

Estonia 
Finland 
Latvia 
Lithuania 

2022-2027 cost of 
marine measures 
national currency, 
current prices 

Annual cost of 
marine measures 
national currency, 
current prices 

Annual cost of 
marine 
measures 
EUR million, 
2020 prices 

Area of 
marine 
waters 
thousand 
Km2 

Annual unitary 
cost of marine 
measures  
EUR per Km2 

46.3 (EUR mill) 
299.0 (EUR mill) 
2.5 (EUR mill) 
8.5 (EUR mill) 

7.7 (EUR mill) 
49.8 (EUR mill) 
0.4 (EUR mill) 
1.4 (EUR mill) 

6.9 
48.6 
0.4 
1.3 

36.6 
82.5 
28.3 
6.4 

188 
589 
12 
202 

(287) LV, PL, SI 
(288) NL 
(289) Slovenia’s costs were not included in these calculations because their equivalent unit cost is an outlier due to very 
high costs reported against a small marine area. The average cost for Slovenia is estimated at: EUR 12,634 per km2 per 
year. 
(290) Using the average ECB Euro foreign exchange reference rate where necessary: 
https://www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/html/index.en.html; using the 
average exchange rate between the Euro and the Swedish krona and the Polish złoty over the period 01 January 2019 to 
31 December 2020. 
(291) Using Eurostat harmonised index of consumer prices (HICP) data (HICP - annual data (average index and rate of 
change) [prc_hicp_aind$defaultview], downloaded from Eurostat on 21.02.2024) 

104 

 
 
Poland 
Sweden 
Average 

2 900.0 (PLN mill) 
530.0 (SEK mill) 

3 337 
17 
724.3 
Sources: Member State reporting, ECB (Exchange rates), Eurostat (HICP) and WISE Marine (https://water.europa.eu/marine/countries-and-
regional-seas/country-profiles)  

483.3 (PLN mill) 
88.3 (SEK mill) 

110.6 
2.6 

33.1 
155.6 

Based  on  this  data,  the  cost  of  MSFD  measures  for  the  entire  marine  waters  of  the  EU  can  be 
estimated. For all measures included in the programmes of measures, i.e. also measures taken under 
other instruments, the total annual cost is EUR 5.8 billion (292). Based on Member States’ reporting of 
the share of their measures that are specific to the MSFD (i.e. category 2 measures, 42%), the cost 
of MSFD-specific measures for the entire EU marine area is estimated at EUR 2.4 billion 
per year.  

Benefits 

In five Baltic Member States, benefits were estimated through primary economic valuation studies 
(e.g. contingent valuation) or through benefits transfer.  

Quantifying the benefits from the marine environment: examples from three Member States 

Finland reported benefits of achieving GES for selected descriptors in the Finnish waters of the Baltic Sea. They estimated, 
via benefits transfer from a willingness to pay study (293), that the present value benefits is EUR 2,351 million by 2040. 
These estimates  are  reliant  on  the  assumption  that  GES  is  achieved  for  Descriptors  1,  3  and  6  by  2040,  but  not  for 
Descriptor 5.  

Latvia reported benefits valued at EUR 16.2 million per year for improvements in the marine environment and the provision 
of ecosystem services. These improvements are associated with improvements in biodiversity and with the reduction of 
eutrophication, of hazardous pollutants, of the introduction and impacts of invasive non-native species, and of marine litter.  

Sweden reported present value benefits from additional ecosystem services of between SEK 0.96 – 12.50 (approximately 
EUR 0.08-1.09) billion over the period 2022 to 2040. These benefits are assumed to result from the reduction of pressures 
from the marine environment and were estimated via a willingness to pay study. 

Two  Member  States  (294)  provided  qualitative  descriptions  of  expected  improvements  in 
ecosystem  service  benefits  expected  from  the  new  measures  in  their  second  programmes  of 
measures. For example, one Member State  (295)  reported that the measure to promote the use of 
more environmentally friendly alternative antifouling products is expected to reduce pollution in the 
marine environment thus resulting in healthier bathing waters and recreation benefits.  

5.3.2  Economic and social impacts of MSFD measures 

Eight  Member  States  (296)  provided  in  their  text-based  reports  qualitative  information  on  the 
activities and sectors whose operations will be affected due to the implementation of their 
second programmes of measures. For example, two Member States (297) provided summaries of 
individual measures that include information on sectors or social groups that need to be involved in 

(292) Total km2 of marine waters of 22 EU Member States (7 958 556) * average cost of minotring per km2 (724) = EUR 5 
764 104 242 
(293) The original contingent valuation study by Niemenen et al (2019) examined the benefits of achieving GES for all 
Descriptors. However, the benefit values reported in Finland’s second Programmes of measures are only associated with a 
few Descriptors to reflect the assessments and conclusions in their Programmes of measures.  
(294) ES and BE 
(295) BE 
(296) CY, DE, EE, ES, FI, FR, LV and SE.   
(297) CY and EE 

105 

 
 
  
  
  
 
the implementation of the measure. A number of Member States reported on the activities addressed 
by  some  of  their  MSFD  measures.  While  it is  not  clearly  defined  how the  measures  ‘address’  the 
different activities, it can be assumed that it shows activities that are likely to be most impacted by 
MSFD measures. The graph below summarises this information, showing the number of measures 
reported against different activities (298). Fisheries (commercial and recreational) and shipping 
are the top two activities addressed by MSFD measures, with 233 and 220 measures respectively 
(Figure 13).  

Figure 13. Number of measures that address a specific activity 

Only two Member States(299) also covered aspects related to social issues and human well-
being. There is no information in these Member States’ reports, however, to indicate that they further 
investigated the impacts of measures on particularly vulnerable groups, the social acceptability of 
the measures or the distribution of impacts across groups or generations. Additionally, there is no 
information on how these Member States used the results of these assessments in the selection of 
measures. The other fifteen Member States did not investigate social issues or impacts. They only 
reported  undertaking  stakeholder  and  public  consultation  wherein  they  raised  awareness  of  the 
second programme of Measures. 

(298) Some measures cover more than one activity, therefore the information presented in the graph will not equal the 
number of measures reported by the 17 Member States.  
(299) FI and EE 

106 

 
 
 
Consideration of social and human well-being in the second programmes of measures 

Finland examined the well-being improvement that may result from the implementation of the programmes of measures, 
represented by indirect effects on human health, living conditions and comfort. For example, they described how measures 
on eutrophication will reduce toxic algal blooms and improve the cleanliness of beaches, which are expected to benefit 
human health and coastal aesthetics. 

Estonia included a category of human well-being and health in their cost-effectiveness analysis, where this category also 
covers local community, traditions, cultural heritage and employment. They indicated if each individual new measure is 
expected to have a positive, negative or no impact on this category. For some measures, they also provided qualitative 
descriptions of expected improvements in this category of human well-being and health. For example, Estonia stated that 
a reduction in marine litter is expected to have significant impacts on human well-being and health.  

5.3.3  Funding MSFD measures 

All  Member  States  reported  on  the  source  of  funds  that  will  be  used  to  implement  their  second 
programmes of measures. 16 Member States (300) will be mobilising a mix of national (301) and 
EU funds, with some Member States (302) listing EU funds for over half of their measures (and up to 
80%).    Nine  Member  States  (303)  also  mentioned  the  mobilisation  of  funds  from  the  private 
sector. Some Member States (304) describe this as costs to the private sector to adhere to measures 
that are implemented (e.g. as a capital investment) while others (305) refer to funding provided by 
environmental foundations for the implementation of MSFD measures.  

Sixteen  out  of  17  Member  States  clearly  reported  the  use  of  EU  funds  that  will  support  the 
implementation of their second  programmes of measures. Of these, two Member States (306) only 
referred  to  ‘EU  funds’  without  more  details.  One  Member  State  (307)  did  not  explicitly  provide 
information regarding the use of EU funds, although they mentioned mobilising a “recovery fund” (308) 
for the implementation of new measures. Fourteen Member States (309) named the types of EU funds 
they are expecting to use for individual measures. Thirteen of the 17 Member States (310) mentioned 
the use of the European Maritime, Fisheries and Aquaculture Fund (EMFAF) (or its predecessor 
the  European  Maritime  and  Fisheries  Fund  (EMFF),  six  Member  States  (311)  mentioned  the  LIFE 
Programme, and three Member States (312) mentioned the Horizon Europe research programme. 
Other EU funds mentioned by Member States include the Common Agricultural Policy, the Cohesion 
Fund,  the  European  Social  Fund  Plus,  the  NextGeneration  Recovery  and  Resilience  facility,  the 

(300) Excluding IT.  
(301) Some Member States only refer to a general ‘national’ fund, while some reported details on the level of governance 
(e.g. regional, local) from which the funds are expected to come from.  
(302) Data from the e-reporting shows that EU funds are mentioned in 80% of RO measures, 59% of PT measures, 50% of 
SI measures and 49% of CY measures. 
(303) DE, ES, FI, LT, LV, PL, PT, SE, SI.  
(304) LV and LT 
(305) DE and PT 
(306) ES and SI 
(307) IT 
(308) It is possible that Italy referred to EU recovery funds, but this is not made explicit in IT’s reporting.  
(309) BE, CY, DE, EE, FI, FR, IE, LT, LV, NL, PL, PT, RO, SE. 
(310) This excludes IT, ES, SI and FI.  
(311) BE, FR, PT, RO, CY and LV.  
(312) LV, PT and RO.  

107 

 
 
 
European  Regional  Development  Fund,  the  Connecting  Europe  Facility  (Transport),  the  European 
Agricultural Fund for Regional Development and the INTERREG Programme (313).  

The use of EU funds for the implementation of the MSFD 

The Netherlands reported that EUR 5 million is available from EMFAF for specific MSFD measures and research, although 
they did not elaborate on what types of measures or for which descriptors this funding will target.  

Lithuania provided estimates of funds they foresee to be made available from the Cohesion fund and ERDF, EAFRD, EMFAF, 
Horizon Europe and the LIFE programme. They also provided estimates on the amount they will mobilise from the fund to 
support MSFD measures, and examples are below.  

- 
- 

- 

Cohesion Fund and ERDF: EUR 440 million for measures affecting the water sector. 
EARDF: almost EUR 787 million for measures to contribute to the improvement of the environmental status of 
surface waters. 
EMFAF: EUR 5.4 million for more sustainable fishing practices; EUR 2.45 million income support in case of loss 
of income due to permanent or temporary cessation of fishing activities; EUR 4.5 million for the protection and 
restoration of aquatic biodiversity and ecosystems; EUR 730.000 for the fisheries management to protect birds 
and compensation for damage caused by protected marine mammals.  

5.4  Evidence of member states’ commitment to implement the 

measures  

Article 13 of the MSFD requires Member States to ensure that measures are cost-effective 
and  technically  feasible  and  to  carry  out  impact  assessments  (including  cost-benefit 
analyses) prior to implementation of new measures. Article 22 states that implementation 
of  the  MSFD  ‘shall  be  supported  by  existing  community  financial  instruments’,  and  ‘co-
financed by the EU’, while Article 6 of the Directive emphasises regional coordination and cooperation. 
The Directive also recognises overlaps with other existing EU Directives (e.g. the Habitats and Birds 
Directives,  the  Water  Framework  Directive)  and  policies  (e.g.  maritime  policy  and  the  Common 
Fisheries Policy).  

Based  on  these,  four  key  factors  were  defined  to  assess  the  likelihood  of  Member  States 
implementing the new measures they have included in this second cycle of implementation, namely: 

1.  Consideration  of  the  socio-economic  impact  of  new  and  additional  measures  in  the 

development of their programme of measures. 

2.  Sources of financing, including the use of EU funds. 
3.  Coordination with key EU policies and regional cooperation (314). 
4.  Information on the implementation on where, how and when the modified and additional 

measures will be implemented (315). 

(313) There are instances where Member States have referred to Programmes that are funded by other sources, e.g. the 
Operational Programme for Large Infrastructure that is funded by the Cohesion Fund and the Regional Development Fund.  
(314) This includes: the Common Fisheries Policy (CFP), the Habitats and Birds Directives (HBD), Maritime Spatial Planning 
(MSP) and the Water Framework Directive (WFD), among others. 
(315) ‘Where’ relates to the spatial coverage; ‘how’ relates to the operationalisation (e.g. description of the measure, 
authority responsible for implementation, the mode of action for implementation (e.g. technical, legislative, economic and 
financing); ‘when’ relates to the temporal scope. 

108 

 
 
 
The scores (316) for each one of the factors were aggregated into an overall qualitative score of the 
likelihood of implementation (Table 4).  

Table 4. Overall score on the likelihood of implementation 

Score 

Member 
States 

High 

Medium-High 

Medium 

Medium-Low 

Low 

Total 

9 

4 

2 

1 

1 

17 MS 

Out of the 17 analysed Member States, a total of 13 Member States are considered to have a 
high  or  medium-high  likelihood  of  implementing  the  new  and  additional  measures,  two 
Member States are considered to have a medium likelihood and two Member States are considered 
to have a medium-low or low likelihood that they will implement the new or additional measures 
from their second programme of measures. 

Individual scores and justifications are presented together with Member States’ conclusions in the 
next chapter but the following conclusions can be drawn for all 17 Member States.  

With respect to the socio-economic impact of the new and additional measures, one Member State 
(317) obtains a full score as it undertook adequate analysis of the economic impact of the measures 
to support their selection. In addition, it examined short-term and long-term impacts on activities and 
well-being. Seven Member States (318) obtain a partial score either because of partial analyses of both 
economic and social impacts or because social issues were not investigated, despite a good economic 
analysis. The remaining eight Member States (319) carried out only partial economic analyses (mainly 
in relation to only a few measures) and did not investigate social issues at all. Finally, one Member 
State (320) made some qualitative categorisation of the measures but did not perform an economic 
impact analysis nor investigate the social impacts of the measures. 

With  respect  to  the  sources  of  funding,  four  Member  States  (321)  provided  clear  information  on 
sources (coming from the national budget or from EU funds), including amounts and breakdowns. 
When relevant, additional funding from municipal, port or private sources are also reported. Twelve 
Member States (322) listed the different sources but without indicating the total amounts, the amounts 
allocated  to  specific  measures  or  if  the  funding  has  been  secured.  In  one  Member  State323  the 
information on financing sources is very limited. 

With  respect  to  the  coordination  with  key  EU  policies  and  cooperation  with  Regional  Sea 
Conventions and international agreements, one Member State (324) reported that the core of its 
proposed programme of measures corresponds to existing and planned measures from other policies 
(mainly the WFD, the HBD, the CFP and the MSP). In addition, it described in detail its participation in 

(316) A Member State is assigned a score, ranging from high to low, given their performance against all four Key Factors. 
The overall score for a Member State reflects commitment in implementing their second Programme of Measures. The 
score against each Member State was also reviewed relative to the scores of other Member States to ensure consistency 
and comparability. 
(317) EE 
(318) DE, FI, FR, LT, LV, PL, SE 
(319) BE, ES, IE, IT, NL, PT, RO, SI 
(320) CY 
(321) CY, LT, LV, PT 
(322) BE, DE, EE, ES, FI, FR, IE, NL, PL, RO, SE and SI 
(323) IT 
(324) CY 

109 

 
 
 
 
 
 
 
different regional and international agreements and organisations. In eleven Member States (325) this 
is  only  achieved  partially,  either  because  the  links  with  other  policies  are  mentioned  but  not  the 
mechanisms of coordination, or no information on the authorities for implementing and coordinating 
the measures is provided. In four Member States (326) the information is even more partial as only 
refers  to  some  of  the  measures.  In  one  Member  State  (327),  relevant  policies  connected  with  the 
programme  of  measures  were  identified,  but  very  scarce  information  on  coordination  with 
neighbouring countries was provided. 

With respect to the implementation of measures, six Member States (328) obtain a very high score 
by providing the details on where, how and when six to ten new measures will be implemented. In 
seven Member States (329) those details are provided to about four to six measures. In three Member 
States  (330)  details  on  implementation  are  provided  for  only  two  or  three  measures.  Finally,  one 
Member State (331) does not report any new measure in its second programme of measures. 

(325) BE, EE, ES, FI, FR, IE, NL, PL, PT, SE and SI 
(326) DE, LT, LV, RO 
(327) IT 
(328) SE, EE, LT, DE, PL and FI 
(329) PT, LV, FR, BE, ES, RO and SI 
(330) IT, IE and NL 
(331) CY 

110 

 
 
 
 
6. Member State conclusions  

The technical assessments (332) on which this  part of the annex is based analyse Member States’ 
reporting of their programmes of measures per descriptor, under Article 13(9) of the MSFD. This part 
of the annex provides a summary assessment of the strengths and weaknesses of the measures 
included by Member States in their programmes of measures for each descriptor identified in Annex 
I of the MSFD.  

The  assessment  (333)  looked  in  particular  at  how  measures  address  the  relevant  pressures,  as 
identified by Member States in their 2018 Article 8 assessments, and support the achievement of 
targets and ultimately GES, as well as how specific and direct measures are, whether implementation 
mechanisms are well-explained and timing and spatial scope clearly reported (334).  

The  assessment  focused  on  measures  reported  as  having  been  taken  specifically  for  the  MSFD. 
Therefore, it does not prejudge conclusions regarding the effectiveness of certain measures 
to address pressures regulated by other frameworks (e.g. nitrates directive, WFD, CFP, etc.).  

The assessment also looked at how Member States have addressed cross-cutting issues, such as the 
integration of climate change in their programmes of measures, coordination with other authorities 
and  assessing  the  socio-economic  impacts  of  the  programmes  of  measures.  Member  States’ 
programmes of measures have been assessed as ‘adequate’, ‘moderately adequate’ or ‘not adequate’ 
(335) to address pressures and contribute to achieving GES and targets, based on the assessment of 
their measures and cross-cutting issues. Based on these conclusions, a set of recommendations were 
drawn up and assigned to Member States (Section 7).  

6.1  Belgium 

Summary: 

Overall, the second programme of measures presented by Belgium is considered as adequate to address the 
pressures acting on the Belgian marine environment and contributes to achieving Belgium’s GES and targets.  

In terms of strengths, Belgium has carried out multicriteria analyses for the selection of new measures, followed 
by  CBA/CEA  analyses  for  specific  measures  and  detailed  gap  analyses  leading  to  adoption  of  appropriate 
measures, in particular for D1, D10 and D11. In addition, Belgium shows leadership with D11 by covering not 
only noise but also other sources of energy, showing a good anticipation of future threats. 

On the downside, Belgium does not describe well coordination mechanisms across different authorities for the 
implementation of measures stemming across different policy/sectoral areas (e.g. environment/ fisheries) and 
does  not  seem  to  have  considered  social  issues  in  its  socio-economic  assessment.  New  measures  for 
eutrophication and contaminants have been assessed as only moderately adequate to address the pressures. It 
should be noted that in its 3rd RBMP under the WFD, Belgium has asked for an exemption for its coastal surface 
water body for ecological status on grounds of technical feasibility, disproportionate costs and natural conditions 
and for chemical status on grounds of disproportionate costs and natural conditions.  

Based  on  the  information  reported  in  their  programmes  of  measures,  Belgium’s  commitment  to  the 
implementation of their second programme of measures has been assessed as ‘medium-high’. 

(332) The technical Member State-specific assessments were prepared for the Commission by an external consultant and 
are  found  at  https://environment.ec.europa.eu/topics/marine-environment/implementation-marine-strategy-framework-
directive_en#second-implementation-cycle-2018--2023  
(333) The methodology used for the assessment of adequacy is provided in the Member States’ technical reports.  
(334) The weight of the different criteria used to assess the programmes of measures were adapted in the case where 
Member States have reported already having achieved GES for a certain descriptor in 2018.   
(335) ‘Not adequate’ covers countries with ‘poor adequacy’ and ‘very poor’ adequacy scores. 

111 

 
 
The  adequacy  of  Belgium’s  programme  of  measures  for  cross-cutting  issues  is 
considered moderate. 

The second programme of measures of Belgium did not have major changes since the first MSFD 
cycle in terms of methods applied for measures selection, reported links between the MSFD and other 
policies,  regional  and/or  international  cooperation,  and  public  consultation.  Belgium  respected  the 
MSFD reporting guidelines in terms of information that needed to be reported.  

Topic 

Strengths 

Weaknesses 

Socio-economic 
assessment 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

(e.g. 

analysis. 

Additional 

The  selection  of  measures  relied  on  a  multi-
qualitative 
criteria 
information was provided by Belgium on cost 
categories 
cost, 
implementation  cost,  personnel  cost),  and 
increased  fishing 
(e.g. 
benefits  assessed 
production,  scientific  value,  etc.).  Quantitative 
information  (on  costs  and  benefits)  was 
provided when it was possible.   

preparation 

Concerning the social issues, Belgium did not 
present  any  indication  of  considered  social 
issues  and  analysis 
the 
development  of 
the  programmes  of 
measures.   

support 

to 

Belgium  considered  the  effects  of  climate 
change  on  the  marine  environment  while 
developing/  elaborating  on 
the  updated 
programme of measures.  

Belgium’s  3rd  RBMP  also  assesses  the  main 
impacts  of  climate  change  on  the  coastal 
water body, e.g. storm related floods, coastal 
erosion and loss of natural wetlands.   

Belgium  did  not  report  any  information  on 
how  climate  change  considerations  were 
taken  into  account  in  measures  selection 
i)  reducing  greenhouse  gas 
notably  on 
emissions, or ii) enhancing adaptive capacity 
and resilience of marine ecosystems. It is also 
unclear if the proposed measures are part of 
the  climate  change  adaptation  strategy  of 
the country or not.  

Belgium  did  not  mention  any  additional 
information  concerning  mechanisms  and 
outcomes of coordination.  

No further information was given by Belgium 
on whether all EU funding opportunities were 
seized or not, and on amounts mobilised by 
each funding source and sectors/descriptors 
targeted.    

Belgium did not specify if the transboundary 
impacts  of  proposed  measures  have  been 
assessed or not.   

It  could  be  assumed  that  transboundary 
impacts  were  discussed  with  neighbouring 
countries,  yet  it  is  not  clear  from  the  text 
whether this was the case.   

Belgium  refers  to  links  between  MSFD  and 
other EU policies, namely WFD, MSP, CFP, and 
BHD.  Coordination  between  MSFD  and  the 
different  directives  was  pointed  out  for 
different 
different  measures 
descriptors,  such  as  eutrophication  (D5)  and 
pollutants (D8 and D9) for the WFD.  

targeting 

At regional level, Belgium cooperated with the 
neighbouring  countries  within  OSPAR  which 
helped  Belgium  in  measures  selection.  New 
the 
measures  were  defined  based  on 
programmes of measures of the neighbouring 
countries.  

At international level, Belgium cooperated with 
other countries through different international 
and  European  treaties  and  agreements  (e.g. 
International  Maritime  Organization,  EU 
Integrated Maritime Policy, and Convention on 
Biological Diversity).  

112 

 
 
 
 
 
 
 
Topic 

Strengths 

Weaknesses 

the 

Belgium  electronic  reporting  provided  a  clear 
responsible/  competent 
indication  of 
implementation  and 
for 
authority 
coordination 
regional,  and 
international levels) of each measure.  

(at  national, 

the 

There is no indication of the evolution of the 
administrative process since the first cycle.   

Public consultation 
and administrative 
process 

in 

the 

relevant, 

Comments  from  different  stakeholders  were 
final 
considered,  when 
programme of measures. In its RBMP Belgium 
seemed 
level  of 
engagement with the public and stakeholders 
who apparently continue to be involved in their 
implementation 

indicate  a  higher 

to 

The adequacy of Belgium’s programme of measures to address 
pollution issues is considered good. 

D5 - Eutrophication  

Adequacy  

Strengths  

Weaknesses  

Progress since 2016  

D8 – Contaminants  

Adequacy  

The adequacy of Belgium’s programme of measures for D5 is considered moderate  

-  Eutrophication pressures and relevant measures are well understood.     
-  Measures are in place to address many of the key pressures contributing to eutrophication.     
-  A gap analysis has been carried out and has identified the main land-based pressure sources 
as  river  input  coming  from,  inter  alia,  run-off  of  agricultural  activities,  urbanisation  and 
industry (including ports). 

-  Belgium  has  provided  some  of  the  necessary  information  on  where,  when,  and  how  the 

modified and additional MSFD specific measures will be implemented. 

-  The gap analysis does not assess the extent to which individual measures may contribute to 

pressure reduction and thus to achieving GES.   

-  Updates  to  measures  from  other  relevant  frameworks,  in  particular  WFD  or  National 
Emissions Ceiling Directive, are not mentioned by Belgium under D5 unlike measures adopted 
under other EU legislations, which seems to be an omission, despite identifying the relevant 
pressures in their gap analysis. It is of particular importance as Belgium’s RBMP highlights 
that  in  its  coastal  water  body,  eutrophication  is  caused  mainly  by  nutrient  pollution  from 
agriculture and to some extent point source industrial pollution from upstream, all of which 
need to be tackled under land-based legal frameworks.   

-  The MSFD-specific measures are not linked to operational targets.   
-  Implementation and financing of the measures remain unclear.    
-  It is unclear whether the measures are complete and will fully address the pressures and 
therefore  whether  and  when  GES  might  be  achieved  for  D5:  industrial  emissions  remain 
unaddressed and agricultural run-off are addressed via an indirect measure only.  

-  In 2016 the coverage of pressures was assessed as partial as there were identified gaps 

relating to agriculture and industry. In 2022, the coverage is also assessed as partial.  

-  In 2016, the programme of measures was considered to only partially cover all components 
of GES and targets as there were identified gaps relating to agriculture and industry. There is 
no progress in 2022 as the targets are not sufficiently developed and are not considered as 
operational.   

The adequacy of Belgium’s programme of measures for D8 is considered moderate.  

113 

 
 
 
 
 
 
 
Strengths  

Weaknesses  

Progress since 2016  

-  The  key  pressures  contributing  to  excessive  concentrations  of  contaminants  in the  marine 

environment are well identified.    

-  Belgium  has  provided  some  of  the  necessary  information  on  where,  when,  and  how  the 

additional MSFD-specific measures will be implemented.   

-  The gap analysis does not quantify gaps or indicate the extent to which measures will address 
the pressures and does not identify how specific measures contribute to achieving GES.    
-  It  remains  unclear  whether  and when  GES  might be  achieved  for  D8.  Belgium’s  3rd  RBMP 
concludes that its coastal water body is not in good chemical status especially because of 
uPBT substances, such as mercury, PAHs and PBDEs.   

-  Measures from other relevant frameworks, in particular WFD or National Emissions Ceiling 
Directive, are not mentioned by Belgium under D8 unlike measures adopted under other EU 
legislations, which seems to be an omission. Belgium’s RBMP shows however that Belgium is 
taking measures under WFD of high relevance to D8 under the MSFD, including prohibition to 
use tributyltin (TBT) in shipping, waste management plans in harbour areas, quality control of 
sediments  discharged  in  sea  areas,  incident  management  or  the  ban  of  use  of  certain 
pesticides in aquaculture and lead in fisheries. 

-  The MSFD-specific measures, which include the restoration of estuarine ecosystems, are only 
'partially' linked to operational targets, many of which have previously been assessed as poor. 

-  Implementation and financing of the measures remain unclear.   
-  In  2016  pressures  had  been  assessed  as  being  fully  addressed  by  the  programmes  of 
measures. In 2022, the coverage is considered to be partial because the gap analysis does 
not provide sufficient information.  

-  In 2016, the programme of measures was assessed as covering all components of GES and 
targets. In 2022, coverage of GES and targets is considered only partial because most of the 
targets are considered not to be operational by the Commission.    

D9 — Contaminants in seafood  

Adequacy  

Strengths  

Weaknesses  

Progress since 2016 

D10 — Marine litter  

Adequacy  

Strengths  

The adequacy of Belgium’s programme of measures for D9 is considered very good  

-  GES is achieved and measures are in place (in relation to D8 which will benefit D9) to address 
many of the key pressures contributing to concentrations of relevant contaminants in fish and 
shellfish flesh.    

-  Additional  MSFD  specific  measures  identified  for  D8  will  help  to  ensure  that  GES  for  D9 

continues to be achieved.  

-  None identified. 
-  In 2016, the coverage of pressures for D9 had not been addressed because Belgium did not 
provide sufficient linkage to measures under D8 which relate to many of the key pressures 
on seafood contamination. On the other hand, the programme of measures was considered 
to partially cover all components of GES and targets. 

-  As  GES  is  achieved,  and  no  modified  or  additional  MSFD  specific  measures  have  been 

identified in 2022, no proper assessment of progress can be made.  

The adequacy of Belgium’s programme of measures for D10 is considered good  

-  Belgium reports a clear gap analysis for D10 marine litter, including the need for progress on 

microlitter, as well as targeting hot spots for marine litter input (e.g. incl. ghost nets).    

-  The  additional  MSFD  specific  measures  are  considered  adequate  to  address  the  main 

pressures for D10 (commercial shipping, fisheries, tourism, etc.).   

-  All the measures are linked to the environmental targets reported under Article 10.   
-  Belgium provides adequate details on how and where the measures will be implemented.   

114 

 
 
 
-  Belgium shows that it will be following up closely on the development of clear indicators for 

micro-litter (TG Litter).    

-  Belgium  also  makes  correct  reference  to  the  EU  Threshold  levels  for  beach  litter  and  to 

operational objectives set by OSPAR (2021-2030).   

-  All the measures are linked to the environmental targets reported under Article 10; however, 
these  were  considered  not  operational  because  they  either  referred  to  reduction  of  the 
pressure as a trend or to the desired level of a pressure (ingested litter) in fulmar.    

-  Belgium does not specify a temporal scope for its measures.    
-  References to the EU level recent policy developments such as the Zero Pollution targets are 

missing.   

-  Belgium’s measures have not deteriorated. In both reporting cycles, the measures address the 

relevant pressures and activities identified in Belgium’s Article 8 reporting.    

-  Following the gap analysis, Belgium has included additional MSFD specific measures that 
target litter hot spots. Micro-litter is also better covered in this second cycle, although via 'soft 
measures' (development of indicators).     

-  No progress was made regarding the coverage of environmental targets.  

Weaknesses  

Progress since 2016  

D11 — Underwater noise and energy  

Adequacy  

The adequacy of Belgium’s programme of measures for D11 is considered very good.  

Strengths  

-  Belgium has clearly identified the gaps with regard to D11 and addressed them in the updated 

programme of measures.    

-  Belgium provides a clear and well-thought programme of measures in the current cycle and 

addresses well the most pressing issues linked to D11.   

-  Belgium has taken a pro-active stance and shows it has a vision for the future by including 
other energy sources such as electromagnetic fields, light and heat when addressing D11. 
This  precautionary  stance  is  commendable  and  should  be  taken  as  an  example  when 
addressing continuous noise as well, which is another energy source with many knowledge 
gaps.   

-  New measures proposed in the current cycle are well described.    
-  Belgium includes a measure related to other forms of energy input which was missing in the 

previous cycle.   

-  Description  of  MSFD  specific  measures  should  include  an  overall  implementation  plan 

Weaknesses  

including a time schedule (e.g., start/end date etc.)  

Progress since 2016  

-  The measures partially address the D11 GES and targets.   
-  Belgium’s  report  on  D11  ‘Energy,  including underwater  noise’  under  Article  13  has  slightly 

improved since 2016. 

-  In  2016  Belgium  identified  marine-based  renewable  energy,  defence  operations,  marine 
research, and shipping as key activities contributing to underwater noise, but shipping was 
covered  by  an  indirect  measure  (communication  and  raising  awareness).  This  gap  is  now 
partially  addressed  with  the  additional  MSFD  specific  measure  on  optimisation  of 
work/maintenance access routes during the construction of new wind farms or other offshore 
infrastructure.  

The adequacy of Belgium’s programme of measures to address 
biodiversity issues is considered good. 

D1 — Biodiversity  

Adequacy  

The adequacy of Belgium’s programme of measures for D1 is considered good  

115 

 
 
 
 
 
 
-  A detailed gap analysis is provided for the areas which need to improve to progress towards 

GES.   

-  Good amount of detail is reported for each new and updated measures, which allows to 

see the potential success of these measures.   

-  A cost-benefit analysis is conducted for each measure, considering what is required for 

each stage of implementation and subsequent monitoring.    

-  Adequate links between measures and pressures are made, with each of the measures 

presented addressing pressures reported under D1 in Article 8.    

-  Reporting  of  new  spatial  protection  measures  is  sound,  with  a  large  amount  of  detail 

provided.    

-  Measures  have  been  put  forward  to  reduce  the  disturbance  for  seabirds,  key  marine 
mammal  species  such  as  harbour  porpoises  and  seals,  and  sharks  and  rays.  The 
implementation of new spatial protection measures will also address pressures for pelagic 
habitats.   

-  Links between environmental targets and new measures are not always clear.   
-  Several of the updated and new measures still aim to increase knowledge gaps and collect 

new data rather than manage pressures.    

-  Stronger justification is needed for reasons to update or withdraw existing measures.   
-  More  information  is  needed  on  coordination  between  fisheries  and  environmental 

authorities for measures that implement change in fishing regulations.    

-  More information is required on where spatial protection measures will take place and how 

large these areas will be.   

-  A clear link to how these new spatial protection measures contribute to other EU legislation, 
such  as  Biodiversity  Strategy  targets,  would  help  to  set  these  measures  in  the  bigger 
picture.   

-  Ecosystem structure is an aspect of the GES definition which could benefit from more work.  
-  The measures do not cover all the different aspects of Belgium’s GES definition for all four 

species groups.   

-  Progress has been made in the coverage of pressures by addressing species disturbance, 

which is a significant and relevant to all four species groups.  

-  Progress  has  been  made  with  regards  to  the  coverage  of  GES  and  targets.  All  targets 
presented by Belgium for D1 in Article 10 are covered by at least one new or updated 
measure. 

Strengths  

Weaknesses  

Progress since 2016  

D2 — Non-indigenous species  

Adequacy  

Strengths  

Weaknesses  

The adequacy of Belgium’s programme of measures for D2 is considered moderate  

-  Belgium has identified all relevant gaps in achieving GES for D2C1 in terms of the main 
pathways  of  introductions  and  acknowledged  that  more  could  be  done  to  reduce  the 
introduction of NIS via shipping.    

-  Three additional MSFD specific measures have been identified which all aim to reduce the 

introduction of NIS and ultimately achieve GES for D2C1.   

-  It is not clear if the introduction of the 8 NIS since the last reporting period were due to the 

shipping sector or other pathways.   

-  The new measures do not address the potential introduction of NIS through aquaculture or 
offshore windfarms which are deemed to be potential pathways in the future in the gap 
analysis.   

-  More information could have been provided on how some of the additional MSFD specific 

measures will be implemented.   

Progress since 2016  

-  Some progress has been made since 2016 with respect to the coverage of pressures, with 
all pressures being adequately covered by the additional MSFD specific measures.    

116 

 
 
-  While  the  2016  assessment  recommended  that  Belgium  address  aquaculture  as  a 
pathway of introduction, Belgium considers aquaculture as not a priority due to the low 
number  of  marine  farms  (one  mussel  farm)  in  Belgian  waters.  No  new  measures  are 
implemented to address this pathway as it is unlikely to be affecting the current status of 
GES.    

-  Similar  to  2016,  the  measures  being  implemented  from  the  second  programmes  of 
measures are likely to prevent the introduction of NIS through improved management of 
NIS pathways shipping.   

D3 — Commercial fish and shellfish  

Adequacy  

Strengths  

Weaknesses  

Progress since 2016  

D4 — Foodwebs  

Adequacy  

Strengths  

Weaknesses  

The adequacy of Belgium’s programme of measures for D3 is considered moderate  

-  Belgium  undertook  a  gap  analysis  and  has  provided  justifications  for  the  revised 

programmes of measures.    

-  The additional MSFD specific measures partially address the priority pressures identified by 

the gap analysis and are linked to targets.   

-  Belgium provides information on where and how the additional MSFD specific measures 

will be implemented.    

-  Some aspects of the gap analysis were not included (progress against targets, estimate of 

how much existing measures will reduce pressures).   

-  The  measures  represent  monitoring  actions  to  improve  knowledge  rather  than  actions 

specifically to reduce pressures and achieve targets.   

-  Belgium does not state when the measures will be implemented, nor provide a timeframe 

for achieving GES in the future.   

-  There  are  discrepancies  between  the  e-reports  and  text  report,  with  regards  to  both 
modified and additional MSFD specific measures. As a result, it is unclear which measures 
are linked to D3 in the updated programmes of measures.   

-  The updated Programmes of measures, however, still does not include measures specific 

to aquaculture.   

-  It  is  not  clear  whether  the additional  MSFD  specific  measures  are  linked  to  operational 

environmental targets.    

-  Some progress has been made by Belgium regarding coverage of pressures and achieving 

GES.   

-  The 2016 assessment concluded that whilst the D3 measures addressed the key pressure 
identified  in  Belgium’s  Article  8  reporting,  i.e.  extraction  of  species,  fish  and  shellfish, 
aquaculture was not addressed which had been identified as a key activity contributing to 
this  pressure.  As  mentioned  before,  however,  Belgium  considers  aquaculture  as  not  a 
priority due to the low number of marine farms (one mussel farm) in Belgian waters.  
-  The 2016 assessment concluded that the measures addressed the D3 GES and targets, 
although,  it  is  not  clear  whether  the  additional  measures  are  linked  to  operational 
environmental targets.   

The adequacy of Belgium’s programme of measures for D4 is considered poor  

-  None identified.  
-  No real gap analysis is presented for D4, meaning the reasons for not attaining GES are 

not identified.    

-  The only new and updated measures reported as relevant to D4 are the D1 overarching 
and general measures. This means that there is no plan to ensure that D4 is addressed, it 
will just be an indirect impact from D1 efforts.   

117 

 
 
 
Progress since 2016  

D6 — Seafloor integrity  

Adequacy  

-  Although there are clear overlaps between D1 and D4, this does not mean that D4 should 

not be reported and assessed in its own right.   

-  No definite conclusion can be made as to whether Article 8 pressures are addressed by the 

measures, because Article 8 was not reported for D4 in 2018.    

-  Both  the  new  and  updated  measures  which  are  reported  under  D4  are  reported  to  be 
relevant to targets for D1 only, as targets are still yet to be set for D4. Therefore, no progress 
has been made with regards to meeting GES for D4 as no specific targets have been set, 
and any progress continues to only be made as a side effect of work on other descriptors.  

The adequacy of Belgium’s programme of measures for D6 is considered good  

-  Belgium provides a detailed gap analysis of the areas in which improvement is needed to 
progress towards GES. Belgium clearly links the gaps found in the 2016 programmes of 
measures  with the  new  and  updated measures  presented in  the  2021  programmes  of 
measures.    

-  A good amount of detail is reported for each of the new and updated measures in the 

Strengths  

2021 programmes of measures.    

-  A cost-benefit analysis has also been conducted for each measure, considering what is 

required for each stage of implementation and subsequent monitoring.    

-  Belgium pairs the new and updated measures with relevant pressures and targets well.    
-  The links drawn between the new and updated measures and D6 environmental targets 

are also strong.    

-  More  information  on  coordination  between  fisheries  and  environment  is  needed  with 

regards to measures implementing change in fishing regulations.   

-  Stronger justification is needed for reasons to update or withdraw existing measures. Three 
of  the  four  withdrawn  measures  are  relevant  to  the  health  of  the  seabed,  covering  the 
banning  of  fishing  in  seabed  protection  zones  and  the  implementation  of  gravel  bed 
restoration areas. Belgium should clarify what is different about the new measures, and 
why they are more likely to work than those which have been withdrawn.  

-  Overall, progress has been made since 2016, and pressures are addressed better even if 

not fully yet.    

-  The pressures are only partially addressed due to the size of the areas to be protected. In 
order to see significant difference in the quality of the seabed habitat, large areas will need 
to be protected to allow communities to regrow.    

-  Belgium is looking into quantifying these pressures, which will make a significant positive 

difference in future programmes of measures.    

-  As in 2016, the new measures cover the environmental targets, and contribute towards 

Weaknesses  

Progress since 2016  

D7 — Hydrographical changes  

achieving GES.    

Adequacy  

Strengths  

The adequacy of Belgium’s programme of measures for D7 is considered very good  

-  A new measure is introduced to better assess cumulative impacts from all human activities 
considering future large projects and infrastructures that are likely to cause hydrographic 
changes (including windfarms and coastal defense projects).    

-  This  methodological  development  could  provide  strong  support  to  a  more  holistic 
implementation  of MSFD  in  the future, in  general, and  progress towards  GES  for  D7  in 
particular, but should be carried at a wider scale and higher level than national ones (e.g. 
OSPAR).    

-  Other measures are reported in the text report that could have positive impacts on the 

achievement of GES for D7.    

118 

 
 
 
Weaknesses  

Progress since 2016  

-  Belgium did not assess the status of GES in its EEZ for D7.   
-  The  new  measure  introduced  is  not  specific  to  D7,  nor  directly  linked  to  environmental 

targets defined for D7 and its temporal framework is not defined.   

-  There are some discrepancies between the e-reporting and the text report.   
-  In 2016, Belgium’s programme of measures for D7 was assessed as "No conclusions" as 
there were no measures reported for D7. The report in 2022 has substantially improved; 
existing measures are reported, a gap analysis has been carried out and three additional 
MSFD specific measures have been proposed, which also address weaknesses identified in 
2016, although all of them are indirect measures.     

Based  on  the  information  reported  in  their  programme  of  measures,  Belgium’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘medium-high’.  

Key  Factor  1:  Socio-
economic impacts of new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

CEA  and  CBA  for  some  new 
measures,  but  no  detail  on 
how  these  affect  measures 
selection.  No  information  on 
social impacts of measures.  

Presented  EU  and  national 
financing  sources  that  will 
be mobilised to implement 
the  second  programme  of 
measures.  Three  EU  funds 
are  planned  to  be  used: 
EMFAF,  LIFE  Programme 
and  Green  Deal,  but  no 
indication of amounts from 
each of them and if funding 
has been secured.  

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

Links  between  with  CFP, 
MSP,  WFD  and  HBD  are 
terms  of 
in 
highlighted 
common  objectives  and 
measures.  Mechanisms  for 
coordination 
not 
mentioned.  

is 

Regional  cooperation  via 
OSPAR 
status 
for 
assessments and objective, 
and 
through 
governmental agencies and 
MSFD working groups.   

done 

for 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 
Where: Measures for seven 
descriptors (D2, D3, D5, D7, 
have 
D8,  D10,  D11) 
sufficient 
(e.g. 
details 
Belgian  EEZ  in  the  North 
Sea)  of  spatial  coverage. 
three 
Measures 
descriptors  (D1,  D4,  D6) 
have  partial  details  of 
spatial coverage (336).  
How:  Measures  for  three 
descriptors (D1, D2 and D3) 
have  sufficient  details  on 
operationalisation, 
and 
measures for six descriptors 
(D2,  D5,  D6,  D7,  D8  and 
D11)  have  partial  details. 
Details  are  unclear  for  D4 
measures. 
When:  Measures  for  four 
descriptors (D1, D4, D6, D8) 
have  partial  details,  and 
measures  for  another  four 
(D2, D3, D7, D10) have no 
details.  Measures  for  two 
descriptors (D5 and D11) do 
not have clear details.  

(336) Belgium did not report modified and additional MSFD specific measures for D9.  

119 

 
 
 
 
 
 
 
6.2  Cyprus 

Summary: 

Overall,  the  second  programme  of  measures  presented  by  Cyprus  is  considered  moderately  adequate  to  address  the 
pressures acting on the Cypriot marine environment and partially contributes to achieving Cyprus’ GES and targets.  

In terms of strengths, Cyprus has provided high-level information on sources of financing, i.e. national budget and EU funds 
including those under the 2021-2027 Multi-annual Financial Framework, to support implementation and enforcement of 
the measures. They have also made progress in describing how relevant measures are associated and coordinated with 
other key EU policies and legislation (e.g. the WFD, MSP, CFP and HBD). To support the selection of new measures, Cyprus 
has carried out gap analyses, integrating the outcomes of the data from their monitoring programmes for a number of 
descriptors.  

Cyprus has, however, often not reported where they currently stand with regard to GES, reducing the effectiveness of the 
gap analysis and the selection of effective new measures. For several descriptors, measures have been considered as 
adequate (D5, D8, D9) or moderately adequate (D6, D10, D7), for others they have been considered as not adequate (D1, 
D2, D3, D4). Measures for underwater noise (D11) have been assessed as particularly poor.  

Based on the information reported in their programme of measures, Cyprus’ commitment to the implementation of their 
second programme of measures has been assessed as ‘medium-low’. 

The  adequacy  of  Cyprus’  programme  of  measures  for  cross-cutting  issues  is 
considered moderate. 

The assessment of the MSFD programme of measures pointed out that CY did not report on its efforts 
to coordinate MSFD implementation with national, European and regional processes. Cyprus made 
progress on this topic for its second programme of measures describing efforts to coordinate such 
processes.  

Topic 

Strengths 

Weaknesses 

A qualitative categorisation of financial costs 
is presented for each measure. 

Climate  change  is  recognised  as  a  cross-
cutting issue in the programme of measures.  

Socio-economic 
assessment 

Interactions with 
climate change 

Cyprus  did  not  undertake  cost-benefit  nor 
analyses 
cost-effectiveness 
the 
second 
in 
measures 
programme of measures.  

included 

the 

on 

There  is  neither  reporting  nor  assessment 
on the social impacts of the measures. 

Cyprus  does  not  provide  information  to 
indicate  that  impacts  of  climate  change 
and  contributions  towards  climate  change 
efforts  have  been  considered 
the 
technical and economic assessment of the 
measures. 

in 

Cyprus provided information on national and 
EU  funding  to  support  implementation  and 
enforcement  of  the  measures,  and  they 
provided details on how relevant measures 
are  associated  and  coordinated  with  other 

Cyprus  does  not  describe  if  and  how 
coordination between the MSFD and other 
EU legislation has evolved since the MSFD 
programme of measures.  

120 

 
 
 
 
 
 
 
 
Links to other 
policies 

key EU policies and legislation (e.g. the WFD, 
MSP, CFP and HBD).  

The  programme  of  measures 
includes 
measures  that  can  be  linked  to  European 
strategies  and  action  plans  such  as  the 
European  Green  Deal,  Biodiversity  Strategy, 
Zero Pollution Action Plan, and Fit for 55. 

The  programme  of  measures  does  not 
present  detailed 
the 
outcomes of coordination of the MSFD with 
the national and EU strategies. 

information  on 

Cyprus described its participation in different 
regional  and  international  agreements  and 
organisations related to marine environment 
issues. They also provide information where 
measures  have  been  developed  on 
coordination with other countries via regional 
and international agreements.  

Cyprus does not provide information on any 
transboundary impacts of the measures or 
the assessment of transboundary impacts 
in  the  second  programme  of  measures. 
They  only  stated  that  the  implementation 
of  national  laws  will  not  create  risks  or 
negative impacts to other countries. 

Regional 
cooperation and 
transboundary 
impact 

Cyprus  provided  details  on  the  process  to 
the  second  programme  of 
implement 
measures,  including  legislation  under  which 
these  measures  are  enforced,  authorities 
responsible for implementation, the timeline 
for  implementation  and  further  processes 
required. They also reported on the rationale 
for  changes  to  measures  from  the  MSFD 
programme of measures. 

Public consultation 
and administrative 
process 

Cyprus does not report any information on 
the public consultation process. 

The adequacy of Cyprus programme of measures to address 
pollution issues is considered moderate. 

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Cyprus’ programme of measures for D5 is considered good.  

-  The  programme  of  measures  acknowledges  the  measures  in  the  3rd  River  Basin 
Management Plan (RBMP) of the Water Framework Directive. Incidentally, these were 
not submitted in time to be integrated into the Commission’s assessment of WFD’s 
RBMPs and cross-checking could not be done.  

-  The gap analysis takes into account WFD and MEDPOL monitoring data. 
-  Cyprus reports that GES is currently achieved for D5337. 
-  The 3rd RBMP measure are not identified as an updated existing measure. 
-  References to Zero Pollution targets, the continuing work of the Barcelona Convention 

and the updates to the National Emissions Ceiling Directive are missing.   

-  The gap analysis does not include all the elements expected, a baseline scenario, the 
consideration of how much current measures will continue to reduce pressures, or future 
socio-economic developments. 

-  In 2016, it was considered that coverage of pressures had been addressed, pending 

clarification of WFD status.  The situation in 2022 remains the same. 

337 Although it should be noted that nutrient concentrations (D5C1) were reported as in not good status in 2018 on the 
basis of WFD assessments. 

121 

 
 
 
 
 
 
 
 
D8-Contaminants 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  In 2016, it was considered that the measures addressed the components of GES and 
targets, again pending results from the WFD assessment.  The situation remains the 
same in 2022.  

The adequacy of Cyprus’ programme of measures for D8 is considered good.   

-  The gap analysis takes into account the WFD and MEDPOL monitoring data as well as 

trends in oil spills and illegal discharges. 

-  Cyprus reports that GES is currently achieved for D8.  
-  Measures are in place to address the main anthropogenic pressures (introduction of 
synthetic  and  non-synthetic  compounds,  and  accidental  pollution)  and  activities 
(industry, agriculture, urban activities, and shipping).   

-  To  maintain  GES,  Cyprus  defines  additional  measures  to  strengthen  its  approach  in 

tacking contaminants by port activities and sulfur emissions.  

-  The  gap  analysis  is  missing  a  baseline  scenario,  consideration  of  how  much  current 

measures will reduce pressures, and future socio-economic developments.  

-  There is no reference to WFD RBMPs as an existing measure for D8, nor of updates in 

the 3rd RBMP.   

-  The  references  to  Zero  Pollution  targets,  the  continuing  work  of  the  Barcelona 
Convention and to the updates to the National Emissions Ceiling Directive are missing.   
-  In 2016, it was considered that coverage of pressures had been addressed and it was 

considered that the measures addressed the components of GES and targets.  

-  As no modified or additional MSFD specific measures have been identified in 2022, no 

proper assessment of progress can be made. 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Cyprus’ programme of measures for D9 is considered good. 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

-  The gap analysis takes into account the WFD and MEDPOL monitoring data. 
-  Cyprus reports that GES is currently achieved for D9, thus no updates were made to the 

measures.  

-  The  measures,  combined  with  the  D8  measures,  address  the  relevant  pressures 
(introduction  of  hazardous  compounds)  and  activities  (industry,  agriculture,  urban 
activities, shipping). . 

-  There is no reference to WFD RBMPs as an existing measure for D8, nor of updates in 

the 3rd RBMP.   

-  The  references  to  Zero  Pollution  targets  and  the  continuing  work  of  the  Barcelona 

Convention are missing.   

-  In 2016, it was considered that coverage of pressures had been addressed and that the 

measures addressed the components of GES and targets.  

-  As no modified or additional MSFD specific measures have been identified in 2022, no 

proper assessment of progress can be made. 

The adequacy of Cyprus’ programme of measures for D10 is considered moderate 

-  The modified and additional measures from other initiatives for D10 are clearly listed 
and the text report includes a short description of each of these measures and a link 
with the achievement of the GES.  

-  The gap analysis explains how knowledge gaps on beach litter and litter impacts on 
turtles (Caretta caretta) have been filled over recent years and how gaps still exist for 
litter on the seabed and floating (micro)plastics. Efforts are made to fill in these gaps.  

Weaknesses 

-  There is no reference to the Zero Pollution targets.  

122 

 
 
 
 
-  No results or status of the efforts to fill in the knowledge gaps are listed and Cyprus 
has also not included any modified or additional MSFD specific measures aiming to fill 
these gaps in its second programme of measures.  

-  Some pressures such as micro-litter and mortality of Caretta caretta are not addressed 
by the existing measures, and no modified or additional MSFD specific measures for 
D10 have been included in the programme of measures. 

-  Cyprus does not report whether GES for D10 has been achieved or not and when GES 

is expected to be achieved. 

-  The adequacy of Cyprus programme of measures for D10 has not improved since the 

previous assessment. 

Progress since 2016 

-  In 2016, it was considered that the measures partially addressed the reported pressures 

and activities as for second programme of measures. 

-  In 2016, it was considered that the measures partially addressed GES and targets. This 

is still the case in 2022. 

D11 — Underwater noise and energy 
Adequacy 

-  The adequacy of Cyprus’ programme of measures for D11 is considered very poor 

Strengths 

Weaknesses 

-  Cyprus highlighted its participation to two EU-funded projects on underwater noise in 
the Mediterranean Sea (QuietMED2 and QuietSEAS).  Benefits from those projects are 
considered as contributing to the gap analysis. 

-  Reference  to  the  recommendations  of  setting  thresholds  made  by  TG  Noise  is 

acknowledged. 

-  No conclusions or summary of findings from the QuietMED2 and QuietSEAS projects 
are presented in the text report, and no rational, plan or measures are built upon and 
take advantage of the results of those projects.  

-  No information is provided on whether the two existing measures from the first cycle 

that are specific to D11 will be enough to achieve GES.  
-  No measure is proposed to achieve the threshold’s value.   
-  No progress has been made on D11. 
-  In 2016, coverage of pressure was considered partially adequate, and it is still the case 

Progress since 2016 

in 2022.  

-  As  in  2016,  Cyprus  still  does  not report  any  D11-related  targets,  it  is  therefore 

impossible to assess whether the measures will contribute to achieving them. 

The adequacy of Cyprus programme of measures to address 
biodiversity issues is considered poor. 

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Cyprus’ programme of measures for D1 is considered poor 

-  The  gap  analyses  identified  knowledge  gaps  which  need  to  be  addressed  to  improve 

progress towards GES.  

-  The reporting of the updated existing measure does not provide an adequate explanation 

on how they will ensure progress towards GES.  

-  Despite  the  identification  of  gaps  in  knowledge,  no  new  measures  are  put  forward  by 

Cyprus to fill in this gap.  

-  The absence of new measures is not justified as GES is not achieved. The design of species 
or habitat specific measures is challenging given the limited knowledge and the lack of 
gap  analysis  to  identify  areas  for  improvement;  however,  this  does  not  prevent  the 
implementation of new precautionary measures such as the designation of new protected 

123 

 
 
 
 
 
 
areas or the design of measures for pressures, such as by-catch, are well-known in the 
Mediterranean.  

-  It is difficult to confirm that the updated programme of measure will allow Cyprus to meet 

GES in the relevant timeline. 

-  In  2016,  it  was  considered  that  the  measures  only  partially  addressed  pressures  and 
environmental targets. In 2022, little progress has been made in the areas identified for 
improvement in 2016.  

-  In 2016, it was considered that the measures entirely addressed pressures effecting and 
targets relating to fish. No progress has been made as no further measures have been put 
in place to reduce pressures or increase knowledge. 

Progress since 2016 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Cyprus’ programme of measures for D2 is considered poor. 

Strengths 

-  Cyprus  has  clearly  explained  how  the  updates/changes  to  the existing  measures under 

other frameworks from the first cycle contribute to achieving GES.  

-  The  link  between  modified/additional  measures  under  other  frameworks  and  the  other 

policies is clear and relevant, and relevant KTM are reported. 

-  A description of these measures for D2 and their current status is provided, and relevant 

pathways of introduction are reported to be well framed by existing measures. 

-  GES was not assessed under Article 8 and only a qualitative assessment is presented in 
the programme of measures. Cyprus therefore does not have a baseline scenario to assess 
NIS introductions. 

Weaknesses 

-  It  is  not  clear  whether  Cyprus  has  adequately  identified all  significant  gaps  to  achieve 

targets and GES. 

-  Environmental targets were also not reported by Cyprus under Article 10 in 2018 and no 

supporting explanation was provided. 

-  In 2016, measures were considered to have partially addressed the relevant pressures. In 
2022, no new measures have been identified in the second cycle. An additional existing 
measure has been introduced for shipping.  

-  In 2016, measures were considered to address GES and targets. In 2022, no new measures 
have been identified in the second cycle and it is not clear from the report how and to what 
extent the existing measures are contributing to achieving GES.  

Progress since 2016 

D3 — Commercial fish and shellfish 

Adequacy 

-  The adequacy of Cyprus’s programme of measures for D3 is considered poor 

Strengths 

Weaknesses 

-  Measures considered part of the monitoring programme are removed. 
-  Cyprus  more  clearly  links  measures  to  the  delivery  of  the  CFP  requirements  by 
consolidating D3 measures under one overarching measure covering implementation of 
CFP Fisheries Legislation and International Fishing Obligations. 

-  The gap analysis states GES has been achieved for D3 however does not provide adequate 

evidence to support this statement. GES was not achieved for D3 in 2018.  

-  It is not clear whether Cyprus has adequately identified all significant gaps to maintain 

targets and GES.  

-  Cyprus has only partially explained how updates to the existing measures contribute to 

achieve GES.  

-  Cyprus  has  not  updated  any  of  the  existing  measures  from  the  first  cycle  of  the 

programme of measures.  

124 

 
 
 
-  In 2016, it was concluded that Cyprus had partially addressed MSFD needs to progress 
towards GES but it was not clear whether all commercial fish species were addressed. In 
2022, Cyprus did not change any of its measures but just consolidated them in a single 
measure. 

-  In 2016, it was considered that the relevant GES and target components were addressed 
by the programme of measures for national species but with a lack of links reported to the 
CFP. Cyprus addresses this recommendation in 2022. 

The adequacy of Cyprus’s programme of measures for D4 is considered poor 

-  The  programme  of  measures  includes  a  description  of  the  methodology  followed  to 

modify the measures and improve progress towards GES. 

-  A gap analysis has not been completed for food webs and it therefore not possible to 
conclude whether GES has been met and what progress has been made towards GES and 
environmental targets.  

-  There remain no targets dedicated to descriptor 4. 
-  There is a lack of knowledge regarding food web health in Cypriot waters. 
-  The updated measure is only to research potential protected areas, and not to implement 

them. This measure is indirect and does not contribute to achieve GES. 

-  References to D4 are only made as an addition to the biodiversity status of species and 

habitat groups.  

-  No real progress appears to have been made with regards to introducing measures which 

are well aligned to identified gaps in progress. 

-  In 2016, the measure partially addressed both pressures and environmental targets. Once 
again, this descriptor has been reported and therefore assessed as a part of descriptors 1 
and 6, and not in its own right. Progress since 2016 is therefore extremely limited, if not 
absent.  

The adequacy of Cyprus’s programme of measures for D6 is considered moderate. 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

-  The programme of measures includes the methodology followed to define the measures.   
-  The additional existing measures introduced in the programme of measures will contribute 

Weaknesses 

Progress since 2016 

to reduce disturbance to coastal seabed habitats. 

-  The gap analysis is not detailed and fails to outline the current status of seabed habitats 
in Cypriot waters and the progress made towards the outlined environmental targets.  
-  The additional existing measures are at a small scale when compared to the Cypriot EEZ. 
This implies that these measures are not sufficient to cause significant progress towards 
GES without being paired with new measures.  

-  In 2016, it was considered that measures partially addressed pressures. Progress has been 
made  since  2016,  as  Cyprus  has  introduced  two  additional  existing  measures  which 
address coastal defences and their disturbance of the seabed and port operations.  

-  With regards to environmental targets, the 2016 assessment stated that they were mostly 
covered. Progress has also been made since 2016 with regards to environmental target 
coverage.  

D7 — Hydrographical changes 

Adequacy 

The adequacy of Cyprus’s programme of measures for D7 is considered moderate 

Strengths 

-  Cyprus has updated its GES determination for D7 since its report under Art. 9.  
-  The additional measures from other initiatives that will support port projects and activities 
and  coastal  protection  projects  to  SEA  and  EIA  are  considered  adequate  to  reduce 
pressures linked to D7 and contribute to achieving GES. 

125 

 
 
 
 
-  The gap analysis is limited.  
-  Studies on the expected developments of activities likely to alter hydrographical conditions 

in the future are missing.  

Weaknesses 

-  No  explanation  is  given  on  how  the  modified  existing  measure  can  limit  permanent 

alteration of hydrographical conditions. 

-  No reference is given to measures under WFD, nor to regional or cross-border cooperation 

in this field. 

Progress since 2016 

-  Cyprus has progressed in the definition of its GES, but neither provides the assessment of 
the contribution of the existing measures to achieve GES, nor information about future 
evolution of pressures linked to hydrographical conditions 

Based  on  the  information  reported  in  their  programmes  of  measures,  Cyprus’ 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘medium-low’.  

Key 
Socio-
Factor  1: 
economic  impacts  of  new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

Did not undertake a CBA or CEA. 
Categorised  cost  of  measures 
into low, medium and high with 
no comparison on effectiveness. 
Described  groups  that  need  to 
be 
the 
implementation  of  measures, 
but  no  information  on  social 
impacts of measures.  

involved 

in 

sources 

information  on 
Provided 
financing 
(e.g. 
national  sources,  EMFAF, 
EU’s 
NextGeneration 
recovery  and 
resilience 
facility), but did not provide 
estimates  on  amounts 
expected 
each 
funding source.  

from 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Cyprus  did  not  report  any 
additional  MSFD  specific 
measures  for  their  second 
programme of measures.   

3: 
Factor 
Key 
Coordination  with  EU 
policies  and  regional 
coordination 

Reported  that  the  core  of 
its proposed programme of 
measures are existing and 
planned  measures  from 
the WFD, the HBD, and the 
CFP.  There  is  a  horizontal 
the 
measure 
implementation 
of 
Maritime Spatial Planning.  

on 

regional 

Described  participation  in 
different 
and 
international  agreements 
and  organisations,  and 
national 
the 
named 
agencies  responsible  that 
contribute to or participate 
Reported 
in 
examples  of  outcomes 
from  cooperation,  such  as 
proposed 
on 
integrated  coastal  zone 
management. 

actions 

these. 

6.3  Germany  

Summary: 

Overall, the second programme of measures presented by Germany is considered to be adequate to address the pressures 
acting on the German marine environment and contributes to achieving Germany’s GES and targets.  

126 

 
 
 
 
In terms of strengths, Germany presents a very complete and clear list of measures supported by solid gap analysis. The 
reporting is supported by tables providing clear links between measures and German targets and presenting the impacts 
of measures on ecosystem components. The impacts of climate change on the marine environment were considered while 
selecting measures.  

On  the  downside,  there  is  a  lack  of  clarity  on  how  some  previous  measures  have  evolved  and  how  recent  policy 
developments have  fed  into  the  measure  selection  process.  There  is  also  a  lack  of  information on  the  outputs  of  the 
CEA/CBA and some doubts regarding funding of the programme of measures.  

Measures for eutrophication, contaminants, litter, noise, biodiversity, invasive species, seafloor integrity and hydrological 
changes are all considered adequate, whereas measures for food webs and commercial fish and shellfish are considered 
only moderately adequate and measures for contaminants in seafood are considered to be poor. 

Based on the information reported in their programmes of measures, Germany’s commitment to the implementation of 
their second programmes of measures has been assessed as ‘medium-high’. 

The adequacy of Germany’s programme of measures for cross-cutting issues is 
considered good. 

The  second  programme  of  measures  did  not  show  major  changes  as  compared  to  the  MSFD 
programme of measures in terms of methods applied for measures selection, reported links between 
the MSFD and other EU policies, regional and international cooperation, and public consultation.    

 Topic  

Strengths  

Weaknesses  

Germany undertook the CEA and CBA for all 
new  measures  (52  new  measures)  and 
whenever possible for existing measures.  

Germany  did  not  provide  additional 
information  on 
the 
the 
methodology on the final list of measures.    

influence  of 

Germany  did  not  provide  any  additional 
information  presenting  the  methodology 
and  outcomes  of  the  social  assessment 
making it difficult to understand how social 
assessment 
the  measures 
selection.  

influenced 

The quantification and impact of measures 
on  GHG  reduction  and  on  socio-economic 
activities were not presented.  

Some methodologies might be missing.    

The  measures  selection  was  carried  out  by 
taking 
factors: 
into  account  different 
technically  feasible,  cost-effective,  and  by 
undertaking an impact assessment including 
cost-benefit  analysis.  The  methodology 
followed was well described and reported in 
the programmes of measures.  

(when 

Qualitative  information  on  cost  categories 
was  given 
for  each 
measure. The  benefits  were  estimated  in 
market  value  and  non-market  value  of 
environmental improvements.  

relevant) 

Regarding  social  issues,  the  impacts  of 
measures  on  employment  and  changes  in 
human activities were assessed.  

in  water 

investigated  a) 

the  adaptive 
Germany 
capacity  of  measures  (able  to  respond  to 
future  changes 
temperature, 
displacement of plankton, rains, etc.), and b) 
in  preserving 
how 
ecosystems  and  their  ecosystem  services 
which  contribute  both  to  climate  change 
adaptation and mitigation.  

the  measures  help 

In  Germany’s  3rd  RBMP  under  the  WFD,  a 
climate check was also undertaken to select 

127 

Socio-economic 
assessment 

Interactions with 
climate change 

 
 
 
 
 
 
 
 
Germany did not provide further information 
on the mechanisms and outcomes of such 
cooperation,  making 
to 
understand synergies and outcomes of such 
cooperation,  notably  regarding  measures’ 
selection.  

difficult 

it 

Germany  did  not  provide  any  additional 
information on the amounts mobilised from 
to  understand 
each  source  allowing 
priorities  and 
sectors  and 
targeted 
descriptors.  Also,  uncertainty  still  exists 
regarding EU funding opportunities.   

It  was  not  clear  from  the  text  if  all  EU 
funding  opportunities  have been  seized  or 
not.    

Trilateral  Wadden  Sea  Cooperation 
mentioned with no further details.  

is 

is  unclear  how  stakeholders’  views 
It 
effectively led to modifications between the 
draft programme of measures and the final 
version of the programmes of measures.  

There is no indication in the programme of 
measures  of  any  evolution 
the 
administrative process that has been made 
since the first cycle.  

in 

the  measures  by  checking  the  two  above 
items. 

The  programme  of  measure  refers  to  the 
links  between  the  MSFD  and  other  EU 
policies.   

Coordination is the strongest with WFD and 
was  done  at  the  level  of  both  the  Federal 
Government and Länder. On the contrary, it 
was  identified  that  some  of  Germany’s 
RBMPs  include  only  superficial  reference  to 
the MSFD and that the coordination between 
competent authorities is limited in particular 
when  it  comes  to  land-based  pollution 
sources for the marine.  

Cooperation between the MSFD and other EU 
legislations  (MSP,  CFP,  BHD,  and  BS)  also 
existed and was presented in the programme 
of  measures  text.   For  the  second  cycle, 
coordination  with  the  CFP  also  took  place 
(this element that was not mentioned in the 
MSFD programme of measures)  

The funding sources are well described. 

Regional  cooperation  is  carried  out  through 
OSPAR and HELCOM  with  Germany  playing 
an active role in the respective committees.    

The transboundary impacts of the proposed 
measures  were  identified,  assessed  and 
notified to neighbouring countries  

The  consultation included  all  the  measures, 
and  the  environmental  report  and  provided 
supplementary fact sheets for each measure. 
The general public’s views were received and 
revised.   

from 

Prior to the public consultation, the different 
stakeholders 
the  economic  and 
environmental sectors were consulted and a 
couple  of  workshops  were  carried  out  with 
governments and NGOs.  

Germany  presented  well  the  administrative 
framework to implement the programme of 
measures and their responsible authorities. 

128 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public consultation 
and administrative 
process 

 
 
 
 
  
  
The adequacy of Germany’s programme of measures to address 
pollution issues is considered good. 

D5- Eutrophication  

Adequacy  

Strengths  

Weaknesses  

The adequacy Germany’s programme of measures for D5 is considered good.  

-  Eutrophication pressures and relevant measures are well understood. 
-  Several additional measures have been identified to address the key pressures and activities 

contributing to eutrophication.   

-  Germany has updated the existing measures, based on the 3rd RBMP programme 2022-
2027, in particular the amendments for the transposition of the Nitrates Directive as well as 
the HELCOM Baltic Sea Action Plan 2021-2030.  

-  Germany has  provided  most  of the  necessary  information  on  where,  when,  and  how  the 

specific additional MSFD specific measures will be implemented. 

-  The  gap  analysis  does  not  quantify  the  extent  to  which  specific  measures  contribute  to 
achieving GES noting that their effectiveness will depend on how and to what extent they 
are implemented.  

-  The updated and additional new measures address the identified pressures. However, it is 
unclear whether the measures will sufficiently address the pressures due to uncertainties 
concerning how and the extent to which measures will be implemented.  

-  The assessment of Germany’s 3rd RBMP considers that the lack of setting and achievement 
of maximum nutrient loads impedes the achievement of the objectives of both WFD and 
MSFD. 

-  The  detail  of  some  of  the  measures  is  lacking,  for  example,  financing  for  some  of  the 

measures remain unclear.    

Progress since 2016  

-  In 2016 it was considered that pressures for D5 had been covered, as in 2022.  
-  In 2016 it was considered that the measures addressed the definitions of GES and targets, 

as in 2022. 

D8-Contaminants  

Adequacy  

Strengths  

Weaknesses  

The adequacy of Germany’s programme of measures for D8 is considered good.  

-  Contaminant  pressures  and  relevant  measures  are  reasonably  well  understood  while 

recognising the complexities of multiple diffuse sources entering the sea via rivers.  

-  Several additional measures have been identified to address the key pressures and activities 

contributing to contaminants.   

-  Germany has updated the existing measures, based on the 3rd RBMP programme 2022-
2027,  the HELCOM  Baltic  Sea  Action  Plan  2021-2030  and  OSPAR  North-East  Atlantic 
Environment  Strategy  2021-2030  as  well  as  the  Gothenburg  Protocol  and  the  National 
Emission Ceilings Directive. 

-  Germany has  provided  most  of the  necessary  information  on  where,  when,  and  how  the 

specific additional MSFD specific measures will be implemented. 

-  Not all measures have yet been implemented. 
-  The  gap  analysis  does  not  quantify  the  extent  to  which  specific  measures  contribute  to 
achieving GES, noting that their effectiveness is uncertain due to limited monitoring data on 
the effectiveness of current measures and the persistent nature of some contaminants.   
-  The detail of some of the measures is lacking, for example, financing of some measures 

remain unclear.   

Progress since 2016  

-  In 2016 it was considered that pressures for D8 had been covered, as in 2022.  

129 

 
 
 
 
 
-  In 2016 it was considered that the measures addressed the definitions of GES and targets, 

D9 — Contaminants in seafood  

as in 2022. 

Adequacy  

Strengths  

The adequacy of Germany’s programme of measures for D9 is considered poor.  

-  The information provided on the modified new measure is reasonably complete  
-  The gap analysis does not clarify the extent to which GES for D9 is currently being achieved 

nor how existing or modified measures contribute to achieving GES for D9  

Weaknesses  

-  It is unclear whether financing has been secured.   
-  The analysis for D8 is relevant to D9, which is not stated and links between D8 and D9 are 

Progress since 2016  

D10 — Marine litter  

Adequacy  

Strengths  

Weaknesses  

not made.   

-  There is no specific consideration of pressures in relation to D9  
-  In 2016 it was considered that pressures for D9 had been covered, whereas in 2022, it is 

considered that measures cover pressures only poorly.  

-  In 2016 it was considered that the measures addressed the definitions of GES and targets, 
whereas in 2022 it is considered that the coverage of components of GES and targets is 
poor because there is no specific consideration of pressures in relation to D9.   

The adequacy of Germany’s programme of measures for D10 is considered good.  

-  Litter pressures and relevant measures are reasonably well understood and linked to targets 

DE put forward. 

-  Measures  reported  by  DE  address  all  key  pressures  for  marine  litter,  and  focus  both  on 

primary criteria D10C1 and D10C2, as well as secondary criterion D10C3.  

-  Among existing measures, the new EU Single Use Plastics Directive and RSC Action plans for 
respectively North Sea (through OSPAR) and Baltic Sea (through HELCOM) have been taken 
into account in the second programme of measures, which also refers to the EU Beach Litter 
threshold value.  

-  The Annex 1 to the text-based report provides an overview of detailed fact sheets for each 
modified  or  additional  MSFD  specific  measure  with  all  detailed  information  on  the 
description,  method  of 
towards 
implementation. 

implementation,  spatial  coverage  and 

timeline 

-  The second programme of measures is somewhat confusing on the existing measures in the 

e-reporting versus text-based report (and annexes)  

-  The targets are partially operational.  
-  Other recent EU-level and regional developments regarding marine litter, such as the Zero 

Pollution targets, are not mentioned.  

-  Quantification of how much the existing measures from the first cycle and updated existing 
measures will reduce anthropogenic pressures such as fisheries, shipping, municipal waste 
and riverine input of litter is not reported.  
-  Funding is not yet secured for all measures.  
-  Timelines for implementation of additional MSFD specific measures are not mentioned.  
-  The adequacy of Germany’s measures for D10 has not deteriorated compared to 2016. 
-  In 2016 it was considered that pressures for D10 in both Germany’s North Sea and Baltic 

Sea were covered, which remains valid for 2022.   

Progress since 2016  

-  In 2016 it was considered that the measures addressed the definitions of GES and targets, 

as is the case in 2022.   

-  Compared to 2016, the second programme of measures for D10 provides clearer timelines 

for implementation of the different measures   

130 

 
  
 
D11 — Underwater noise and energy  

Adequacy  

The adequacy of Germany’s programme of measures for D11 is considered good.  

-  Germany provides a clear description of the actions planned for the new programmes of 

measures.  

-  Germany introduces an interesting concept of a low-noise area for marine species.  
-  Underwater  noise pressures  and  relevant  measures  are  reasonably  well  understood  and 

linked to two targets put forward by the Member State.  

-  The measures reported address all key pressures for underwater noise and focus both on 

primary criteria D11C1 and D11C2.  

-  Among existing measures, the RSC Action plans for respectively North Sea (through OSPAR) 
and Baltic Sea (through HELCOM) have been taken into account in the second programme 
of measures.  

-  Germany addresses other anthropogenic energy sources such as light, which is expected to 

be reduced thanks to the measure’s implementation.  

-  Quantification of how much the existing measures from the first cycle and updated existing 

measures will reduce anthropogenic pressures is not reported.  

-  Individual measures planned in the first cycle have not yet been fully effective. Specifically, 
with regards to D11 Germany states it is not possible to estimate whether current measures 
are sufficient to achieve good environmental status.  

-  Funding is not yet secured for all measures.   
-  There is no relevant measure on electromagnetic forces emissions   
-  Germany ‘s report on D11 has not deteriorated.  
-  Both in 2016 and 2022 the measures address all of the pressures and activities identified 

in Germany’s Article 8 which cause noise inputs.   

-  As for the targets, both in 2016 and 2022 the measures are considered comprehensive and 
address  all  aspects  of  the  GES  definition,  except  the  one  on  electromagnetic  forces 
emissions.  

Strengths  

Weaknesses  

Progress since 2016  

The adequacy of Germany’s programme of measures to address 
biodiversity issues is considered good. 

D1 — Biodiversity  

Adequacy  

Strengths  

Weaknesses  

The adequacy of Germany’s programme of measures for D1 is considered very good.  

-  Germany provides a very strong gap analysis and successfully identifies areas which 

are preventing the achievement of GES.   

-  An  effort  has  been  made  to  design  new  measures  to  fill  these  gaps,  as  analysis 
showed  that  without  these  new  measures,  GES  would  not  be  met.  In  particular, 
Germany clearly addresses the pressures derivated from fishing activities.  

-  The measures put forward in the programme of measures will protect certain habitats, 

such as seagrass and reefs and measures are developed for noise mitigation.  

-  The practicalities of the new measures are well reported.  
-  The reporting of the new MPA supplementary measure is also comprehensive, with 
links made to the current MPA areas as well as other policies such as the 30x30 target 
of the Biodiversity Strategy.  

-   The gap analysis is lacking the timescale over which it is now expected that GES will 

be achieved.  

131 

 
 
  
 
 
 
-  There  are  uncertainties  regarding  the  implementation  of  measures,  especially 
regarding the coordination e.g. regional cooperation, it is unclear and financing of some 
of the measures is not secured yet.   

-   Follow-up measures regarding more complete management plans for Natura 2000 
sites of the EEZ, habitat loss, and fisheries would be needed to completely address the 
pressures and achieve the desired status.  

-  For  pelagic  habitats,  Germany  does  not  clearly  identify  how  these  measures  will 
address relevant pressures on this habitat. Hence, the measures partially address the 
pressures on these habitats.  

-  For seabed habitats, the programme of measures does not provide information on how 

a number of activities causing these pressures are addressed.  

-  With regard to the pressures addressed, progress has been made since 2016. Germany 
has now addressed the pressure of fisheries, a pressure not previously addressed by 
the  2016  programme  of  measures,  which  is  significant  and  relevant  to  all  species 
groups, including measures that promote ecosystem-friendly fishing gear. Measures 
have been put forward to protect certain habitats, such as seagrass and reefs. 

-  The coverage of environmental targets and GES, in 2016 were considered addressed 
by the measures reported for birds, mammals, fish, and cephalopods. However, they 
were partially addressed for pelagic and seabed habitats. Germany did not present 
specific  measures  for  water  column  habitats  through  measures  addressing  species 
groups of D1.    

The adequacy of Germany’s programme of measures for D2 is considered good.  

-  Gaps for achieving GES under D2 were adequately identified within the programme of 
measures, namely that new measures and implementation of current measures are 
required to further address current rates of NIS introduction.   

-  The  new  and  modified  measures  aim  to  reduce  the  number  of  NIS  introductions 

through shipping both indirectly and directly, similar to 2016.  

-  The new measures for D2 continue to address the environmental target, which is linked 
to reducing the total number of introduced species to zero in order to achieve GES.   
-  These measures all address the D2 operational target by aiming to achieve the target 

value/indicator of a decreasing trend in the introduction of new NIS.  

-  Germany  generally  clearly  states  how  and  when  the  new  measures  will  be 

implemented.   

-  More could be detailed on the different pathways of introduction and acknowledging 

potential gaps more specifically.  

-  It is unclear whether the implementation of some measures (e.g. the new measure as 
accounting for addressing NIS introductions in mariculture) is specifically linked to D2.  
-  There is a confusion over the measure which addresses aquaculture activities, as it did 

not always appear to be clearly linked to D2.  

-  Germany  partially  addresses  pressures  with  the  new/modified  measures  in  2022 

whereas it was considered that the 2016 measures fully addressed pressures.  

-  Germany have maintained good coverage of the GES and environmental targets since 

Progress since 2016  

D2 — Non-indigenous species  

Adequacy  

Strengths  

Weaknesses  

Progress since 2016  

D3 — Commercial fish and shellfish  

2016.  

Adequacy  

Strengths  

The adequacy of Germany’s programme of measures for D3 is considered moderate.  

-  The 2022 programme of measures aims to reinforce and better implement the first 
cycle of measures and expand the spatial scope of implementation of one measure.    

132 

 
 
 
-  Germany  describes  the  lack  of  achievement  of  environmental  targets,  but  also 
identifies  progress  in  setting  quotas  in  line  with  MSY  targets  and  reducing  fish 
mortality.  

-  A gap analysis has been carried out and identifies failures in implementation of existing 

measures and reasons for not currently achieving GES.  

-  Local/nationally managed fish stocks outside the scope of the CFP quota regulations 

are addressed in some measures.  

-  Germany  provides  details  on  where,  how  and  when  the  modified  measure  will  be 

implemented.   

-  The gap analysis is considered partially adequate.   
-  Age- and size- structure is not explicitly addressed.  
-   It is not clear whether all relevant stocks are covered.  
-  It is not clear whether mortality from recreational fishing is adequately considered and 

addressed.   

-  A timeframe for achieving GES in the future is not provided.   
-  The measure is linked to environmental targets, but the targets were not considered 

operational in the Art 12 assessment.  

-  It is not clear whether the modified new measures will fully address all aspects of the 
source of the relevant pressures (e.g. commercial and recreational fishing, and on CFP 
and nationally managed stocks).  

-  In 2016, it was concluded that Germany had addressed the key pressure (i.e. extraction 
of  species,  fish  and  shellfish). In  2022,  coverage  of  pressures  by  modified  and 
additional MSFD specific measures is assessed as partially addressed.  

-  This  is  a  slight  improvement  overall,  but  some  concerns  remain  over  whether  the 
programme of measures adequately addresses all sources of pressures on fisheries 
(e.g. including recreational fisheries) and the extent to which locally/nationally managed 
stocks are covered.  

The adequacy of Germany’s programme of measures for D4 is considered moderate.  

-  The overall gap analysis (all biodiversity descriptors together) is very strong. 
-  The gap analysis clearly identifies gaps in progress to GES as a whole, and the new 

measures have been designed to address these gaps.  

-  It is made clear that without the changes made to the programme of measures 2021, 

GES would not be reached for descriptor 4.  

-  The  reporting  of  measures  is  also  strong.  All  new  measures  are  linked  to  relevant 

operational environmental targets which were presented in Article 10.   

-  The practicalities of where each new measure will be implemented are also reported 

fully.  

-  The reporting of the new MPA supplementary measure is comprehensive, with links 
made to the current MPA areas as well as other policies such as the 30x30 target of 
the Biodiversity Strategy.  

-  Detail of the current environmental status for descriptor 4 is missing.  
-  Methodologies for the assessment of the quality of food webs in German waters are 
less developed than those for biodiversity and seabed integrity, meaning the current 
status of food webs is less well known.   

-  All pressures are grouped together it is not clear whether the measures are addressing 

some of the specific pressures on food webs.  

133 

Weaknesses  

Progress since 2016  

D4 — Foodwebs  

Adequacy  

Strengths  

Weaknesses  

 
 
Progress since 2016  
D6 — Seafloor integrity  

Adequacy  

Strengths  

Weaknesses  

Progress since 2016  

D7 — Hydrographical changes  

Adequacy  

Strengths  

-  Schema  fields  were  missed  for  both  how  and  when  the  new  measures  will  be 

implemented.  

-  The lack of specific pressures reported in Article 8 under descriptor 4 makes it hard to 

determine the relevance of the new measures to these pressures.  
-  The assessment of progress for D4 has been made together with D1. 

The adequacy of Germany’s programme of measures for D6 is considered good.  

-  The gap analysis provided is very strong and successfully identifies the gaps in the 
2016  programme  of  measures  which  prevented  the  achievement  of  GES  under 
descriptor 6.  

-  The analyses clearly present the current status of the environment and why GES has 

not been achieved. 

-  Main pressures are identified, in this case, bottom trawling.   
-  New measures have then been designed in order to fill these gaps.  
-  The reporting of modified and additional MSFD specific measures is also strong. All 
measures are  well  linked  to  both  relevant  pressures and  operational  environmental 
targets.  

-  The practicalities of the new measures are well reported.  
-  The reporting of the new MPA supplementary measure is also comprehensive, with 
links made to the current MPA areas as well as other policies such as the 30x30 target 
of the Biodiversity Strategy.  

-  The only area in which the gap analysis is lacking is the timescale over which it is now 

expected that GES will be met.   

-  More specific measures could have been presented to directly address bottom trawling, 
taking  into  account  the  identification  of  this  activity  as  the  main  pressure  for  the 
seabed. 

-  Information is missing with regard to how implementation will take place, specifically, 
regarding the coordination between agencies and countries as well as securing funding 
for some measures.   

-  The impact of human-made structures on seabed habitats has not been sufficiently 
addressed and the programme of measures does not include measures which aim at 
protecting seabed habitats from destructive offshore activities, apart from noise input 
or in MPAs.  

-  In 2016 the measures were considered to partially cover the pressures. In 2022 clear 
progress has been made, with 10 new updated and additional MSFD specific measures 
under descriptor 6, which all address pressures reported under Article 8.  

-  In 2016, the measures were considered to partially address the targets for seabed 
habitats.  In 2022, it is uncertain if progress has been made regarding this because 
some measures are reported to be linked to targets that are not reported under Art.10 
or in the 2022 programme of measures.  

The adequacy of Germany’s programme of measures for D7 is considered good.  

-  The programme of measures adequately linked to the WFD programmes of measures 
and to actions at regional level (HELCOM and OSPAR).  This is supported by the fact 
that  Germany  has  included  the  largest  number  of  measures  in  relation  to 
hydromorphological  alterations  in  its  3rd  RMPB  under  the  WFD.  The  extent  to  which 
these will have an impact on hydrographical conditions in coastal waters is however 
not fully clear.  

134 

 
 
 
-  A gap analysis has been carried out.   
-  The  2022  programme  of  measures  covers  all  relevant  pressures  and  all  GES 

components.  

-  Germany provides an assessment of progress against the environmental targets.   
-  Germany provides adequate details on where, how and when the two measures will 

be implemented.  

-  A gap analysis is considered partially adequate.  
-  Germany does not report any modified or additional MSFD specific measure relevant 
for D7 in the e-reporting. However, in the text report, one additional measure relevant 
to D6 in the NEA Greater North Sea region is mentioned as being relevant to D7 as 
well in view of the expected sea level rises due to climate change. 

-  The two measures considered in the update are linked to environmental targets, but 

the targets were not considered operational in the Art. 12 assessment.  

-  Like  the  first  cycle's  programme  of  measures,  the  2022  Programme  of  measures 

covers all relevant pressures and all GES components.    

-  The 2022 report clearly refers to the first cycle programme of measures report; no 
significant progress has been detected, the only changes are linked to improving the 
implementation of 2016 measures and building on measures implemented at regional 
level (HELCOM).  

Weaknesses  

Progress since 2016  

Based  on  the  information  reported  in  their  programme  of  measures,  Germany’s 
commitment to the implementation of their second  
programme of measures is assessed as ‘medium-high’.  

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

for  new 
CEA  and  CBA 
measures  which  helped 
in 
measures  selection.  Social 
assessment  of  measures 
focused  on 
impacts  on 
employment and activities.  

EMFAF, 

support 

Named the funding sources 
to 
second 
programme  of  measures: 
federal  government 
the 
fund,  länder  fund,  EU  fund 
(e.g. 
Interreg), 
environmental  foundations 
fund,  and  other  funding 
sources  (e.g.  other  policies 
sources  of  financing  for 
new  measures).  Did  not 
provide 
information  on 
amounts  from  each  EU 
funding  or  if  funding  has 
been secured. 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 
Where:  Measures  for  ten 
descriptors  have  sufficient 
details on spatial coverage; 
and measures for one (D9) 
have partial information.   

Key 
3: 
Factor 
Coordination  with  EU 
policies  and 
regional 
coordination 

Presented links between the 
MSFD,  the  WFD,  the  CFP, 
the  MSP  and  the  HBD. 
of 
Provided 
coordination  between  the 
MSFD  and  the  WFD  (i.e. 
working  groups  in  LAWA 
and BLANO) only.  

details 

cooperation 
is 
Regional 
via  HELCOM 
achieved 
(Baltic  Sea),  OSPAR  (North 
Sea),  and  TWSC  (Wadden 
Sea). 
second 
The 
programme  of  measures 
takes into account HELCOM 
and  OSPAR  actions  and 
include regional measures.  

135 

 
 
 
 
 
 
6.4  Estonia 

Summary: 

Overall, the second programme of measures presented by Estonia is considered adequate to address the pressures acting 
on the Estonian marine environment and contributes to achieving Estonia’s GES and targets. 

In terms of strengths, Estonia has carried out a thorough cost environmental analysis on 26 new measures, which also 
takes  into  account  short  and  long-term  effects  on  socio-economic  activities,  marine  environment  and  well-being. 
Additionally,  Estonia  reported  the  financing  sources  for  each  of  the  measures  included  in  their  second  programme,  at 
regional, national and EU levels. The new measures are strongly linked to other regional, national and European policies, 
strategies and legislation and international agreements.  

On the downside, there is no evidence on the quantitative benefit for achieving GES, especially in terms of social benefits 
or benefits for the most vulnerable groups. No details are given on how the implementation of the measures affect the 
green house emissions, or climate change, and how the measures interact at regional, national or European level.  

Measures for litter, noise, biodiversity, NIS, commercial fish, seafloor integrity and hydrological changes are all considered 
adequate, whereas measures for eutrophication, contaminants and foodwebs are considered only moderately adequate 
and measures for contaminants in seafood are considered to be poor. 

Based on the information reported in their programmes of measures, Estonia’s commitment to the implementation of their 
second programme of measures has been assessed as “high” 

The  adequacy  of  Estonia’s  programme  of  measures  for  cross-cutting  issues  is 
considered good. 

Estonia follows the MSFD reporting guidelines and provides the required information. However, some 
information was still missing, particularly regarding how social issues were considered, how views 
received from the public consultation process informed the finalisation of the second programme of 
measures, and how the programme of measures is linked to Estonia's and the EU's efforts on climate 
change. 

Topic 

Strengths 

Weaknesses 

Estonia  reported  the  financial  costs  of 
implementing  measures,  and  these  costs 
cover  one-off  investment  costs  and  annual 
recurring costs.  

is 

Estonia  reported  carrying  out  a  CBA,  but 
the 
there 
quantitative/monetised 
from 
achieving GES. 

on 
benefits 

evidence 

no 

Estonia  reports  the  results  of  a  cost-
effectiveness/multi-criteria  analysis  wherein 
the  measures  against 
they  evaluated 
socio-economic 
and 
environmental 
considerations.  

There  is  no  information  to  suggest  that 
Estonia carried out further investigation on 
the social impacts of the measures in terms 
of  social  acceptability  of  the  measure  or 
impacts on groups that are vulnerable. 

Socio-economic 
assessment 

described 

quantitatively 

Estonia 
the 
expected  benefits  from  implementing  the 
new measures in terms of improvements to 
the  marine  environment  and  positive 
impacts on society.  

Estonia considered the social impacts of the 
measures by examining which stakeholders 
and  activities  will  be  affected  by  individual 

136 

 
 
 
 
 
 
measures as part of their evaluation on the 
socio-economic 
cost-
impacts 
effectiveness of measures. 

and 

Estonia provided information to indicate that 
they  considered  the  impacts  of  climate 
change on descriptors and their future state. 
Estonia  stated  that  the  need  for  new 
measures is also driven by climate change. 
The new measures are proposed not only to 
improve the state of the marine environment 
but to also ensure future benefits. 

Estonia  reported  the  financing  sources  for 
each  of  the  measures  included  in  their 
second  programme  of  measures,  which 
include national and EU funding sources. 

Estonia stated that new measures proposed 
in  the  second  programme  of  measures 
regional,  national  and 
consider  other 
European policies, strategies and legislation 
and international agreements (WFD, the HBD 
, the MSP Directive, the Urban Waste Water 
Treatment Directive, the Industrial Emissions 
Directive, 
Impact 
Assessment Directive, the Nitrates Directive, 
the Bathing Water Directive, the EU Strategy 
for  the  Baltic  Sea,  the  EU  Biodiversity 
Strategy,  the  CFP,  and  the  EU  Common 
Agricultural Policy). 

Environmental 

the 

Interactions with 
climate change 

Links to other 
policies 

For each of the measures proposed in their 
second  programme  of  measures,  Estonia 
listed specific actions in the Baltic Sea Action 
Plan  2021 
the 
implementation of the measure. 

linked  with 

that  are 

Regional 
cooperation and 
transboundary 
impact 

Estonia undertook a Strategic Environmental 
Impact Assessment (SEA) which included the 
identification  of  transboundary  impact  of 
measures.  They  also  consulted  their  draft 
second programme of measures and the SEA 
report with neighbouring countries. 

information  on 

Estonia  provided 
authorities  responsible  for 
their second programme of measures. 

the 
implementing 

Public consultation 
and administrative 
process 

According  to  the  RBMP  assessment,  public 
consultation  and  public  discussions  of  the 
draft  programme  of  measures  was 
organised together with the draft RBMP. 

137 

There is no information to suggest that they 
assessed 
individual  measures 
contribute or reduce GHG emissions.  

how 

There  is  no  information  to  suggest  that 
their  second 
Estonia  considered  how 
programme  of  measures  is  linked  with 
regional, national, and European strategies 
on climate change. 

Estonia does not report on the amount or 
proportion  of  funding  from  these  national 
and EU sources. 

Estonia  does  not 
to 
coordination mechanisms since their MSFD 
programme of measures. 

report  changes 

Estonia made no references to a change in 
mechanisms  of  cooperation,  so  it  is  not 
clear if there has been no change or if there 
has been a change but not reported. 

Estonia  does  not  provide  information  on 
what changes were made specifically from 
the feedback received. 

There  was  no  information  found  on  how 
Estonia  will  monitor 
the  progress  of 
implementation of measures. They did not 
provide  information  on  changes  to  the 
the 
process 
implementation 

and/or 

 
 
 
 
 
 
 
administrative  framework  since  the  first 
cycle.   

The adequacy of Estonia’s programme of measures to address 
pollution issues is considered good. 

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

The adequacy of Estonia’s programme of measures for D5 is considered moderate 

-  Estonia has provided some information on progress achieving GES for D5 in its gap 

analysis, based on the Baltic Sea Action Plan targets for nutrient reduction. 

-  Estonia has provided most of the necessary information on where, when, and how 

the specific additional MSFD specific measures will be implemented. 

-  Estonia has provided some information on ten additional existing measures but has not 

quantified the extent to which these measures will reduce nutrient pressures. 

-  There is no reference to updated WFD measures nor to Zero Pollution targets which are 

potentially relevant updated existing measures for D5. 

-  The  effect  of updated  existing measures  and additional  MSFD specific  measures  in 
reducing nutrient pressures has not been quantified. This quantification is in particular 
lacking as the assessment of Estonia’s 3rd RBMP identified that the trends in dissolved 
inorganic nitrogen (and orthophosphate concentrations) in coastal and marine waters 
for the period 1980-2021 are increasing in Estonia and that eutrophication remains a 
large-scale problem in the Baltic Sea. 

-  Given the limitations of the gap analysis it is not possible to determine the measures’ 

contribution on achieving operational targets and GES. 

-  The additional MSFD specific measures are partially linked to targets. 
-  There  remains  uncertainty  concerning  whether  funding  of  the  measures  has  been 

secured. 

-  In 2016, the assessment considered that coverage of pressures had been addressed. In 
2022, the assessment considers that coverage of relevant pressures was partial - the 
modified and additional MSFD specific measures address relevant nutrient pressures 
but it is unclear whether the measures will be sufficient to achieve GES due to current 
limitations in the gap analysis.   

-  In  2016, it  is  considered  that  the  measures addressed  the  components  of  GES  and 
targets.  In  2022,  the  assessment  considers  that  coverage  of  GES  and  targets  was 
partial. While some of the measures were linked to operational targets, others were not.  

The adequacy of Estonia’s programme of measures for D8 is considered moderate. 

-  Estonia has provided some information on progress towards achieving GES for D8 in its 
gap analysis, based on the Baltic Sea Action Plan targets for reduction in contaminant 
pressures. 

Strengths 

-  The additional MSFD specific measures are all linked to targets that were assessed as 

operational. 

-  Estonia has provided most of the necessary information on where, when, and how the 

additional MSFD specific measures will be implemented 

-  Estonia  has  not  quantified  to  what  extent  these  measures  will  reduce  contaminant 

pressures. 

Weaknesses 

138 

 
 
 
 
 
 
-  Given the limitations of the gap analysis it is not possible to determine the measures’ 
contribution on achieving operational targets and GES. It is of particularly relevance as, 
according to the assessment of Estonia’s 3rd RBMP, none of the coastal waters are in 
good chemical status. 

-  The  effect  of updated  existing measures  and additional  MSFD specific  measures  in 

reducing contaminant pressures has not been quantified. 

-  There  is  no  reference  to  the  National  Emissions  Ceiling  Directive,  the  WFD  or  Zero 
Pollution targets which are potentially relevant updated existing measures for D8.  
-  There  remains  uncertainty  concerning  whether  funding  of  the  measures  has  been 

secured. 

-  In 2016, the assessment considered that coverage of pressures had been addressed. In 
2022, the assessment considers that coverage of relevant pressures is partial – the 
additional MSFD specific measures address relevant contaminant pressures but it is 
unclear  whether  the  measures  will  be  sufficient  to  achieve  GES  due  to  current 
limitations in the gap analysis.   

-  The  2016  Article  13  report  considered  that  the  measures  partially  addressed  the 
components of GES and targets. The 2022 assessment considers that coverage of GES 
and targets was also partial. 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Estonia’s Programme of Measures is considered poor  

Strengths 

-  The  specific  measures  address  some  of  the  relevant  pressures  (reduction  in 
inputs)  from  aquaculture,  pharmaceuticals  and  blue  economy 

contaminant 
development 

-  Estonia has provided most of the necessary information on where, when, and how the 

additional MSFD specific measures will be implemented 

-  Estonia has provided very little information in its gap analysis for D9  
-  The effect of additional MSFD specific measures in reducing contaminant pressures has 

not been quantified.  

-  None of the measures address issues associated with dioxins and dioxin-like PCBs and 

only tangentially for cadmium.   

Weaknesses 

-  The additional MSFD specific measures are not linked to targets that were assessed as 

operational. 

-  There is no reference to updated existing measures under D8 which could be relevant 
to D9 or to the National Emissions Ceiling Directive, the WFD or Zero Pollution targets. 
-  There  remains  uncertainty  concerning  whether  funding  for  the  measures  has  been 

secured 

-  In 2016, the assessment considered that coverage of pressures had been addressed. In 
2022, the assessment considers that coverage of relevant pressures was partial. 
-  The 2016 report considered that the measures partially addressed the components of 
GES  and  targets.  In  2022,  the  assessment  considers  that  additional  MSFD  specific 
measures  in  the  second  cycle  did  not  contribute  to  meeting  the  operational 
environmental targets (and ultimately GES). 

The adequacy of Estonia’s programme of measures for D10 is considered very good 

Progress since 2016 

D10 — Marine litter 

Adequacy 

-  The  gap  analysis  provided by Estonia is  considered adequate  and  provide  sufficient 

information. 

Strengths 

-  Information is provided on the MSFD results of monitoring and/or studies on trends in 
relation to the different D10 criteria as well as on the socio-economic forecast of the 
relevant pressures, and on the justification for the implementation of new measures. 

139 

 
 
 
-  All relevant details on where, how and when the additional MSFD specific measures will 

be implemented and how implementation supports the achievement of GES. 

-  The  additional  MSFD  specific  measures  that  are  specifically  addressing  D10  are  all 

linked to one or both operational targets defined by Estonia. 

-  Reference  is  made  to  relevant  policy  frameworks  and  decisions  such  as  HELCOM 

initiatives and the SUP Directive.  

-  It is not clear how the additional existing measures will contribute to achievement of 

GES, particularly for D10. 

-  The  references  to  Zero  Pollution  targets  and  EU  beach  litter  thresholds  are  not 

mentioned in Estonia's report. 

-  The adequacy score of Estonia's report on D10 in the second programme of measures 

has improved compared to the 2016 assessment. 

-  The coverage of pressures for D10 Marine Litter was considered to be addressed in 
2016, with measures addressing the reported pressures and activities. Similarly, the 
2022  assessment  of  the  second  programme  of  measures  also  concludes  that 
measures cover the relevant pressures.  

-  In the 2016 assessment, it was considered that the measures only partially addressed 
the GES components and targets. The 2022 assessment concludes that all relevant 
targets are addressed. 

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Estonia’s programme of measures for D11 is considered good 

Strengths 

Weaknesses 

Progress since 2016 

-  Estonia has reported one modified existing measure aimed at creating an impulsive 
sound register as recommended by TG Noise. While the noise register does not 
constitute a measure by itself, it is an essential input to define measures to target 
impulsive underwater noise. 

-  The active contribution of Estonia to HELCOM activities indicates that Estonia is 

addressing the significant gaps at regional level, which will possibly help to achieve 
the impulsive and continuous noise targets and ultimately GES. 

-  Estonia's report presents all relevant details on where, how and when this measure 
will be implemented and how implementation supports the achievement of GES. 

-  One measure is aimed at directly preventing further inputs of a pressure and is 

considered adequate to address both continuous and impulsive noise. This measure 
ensures that the management of underwater noise will be at the state-of-the-art 
practices in the entire Baltic Sea, and consistent with the other Member States of the 
region. 

-  The gap analysis provided by Estonia is considered partially adequate as it does not 

cover all the aspects defined in the guidance document. 

-  The measure which aimed at directly preventing further inputs of a pressure is not 

linked to D11- specific environmental targets. 

-  The adequacy score of Estonia's report on D11 in the second programme of measures 

remained the same as in 2016. 

-  The coverage of pressures for D11 underwater noise was to be addressed in 2016. 

Estonia has strengthened its approach towards tackling underwater noise. 

-  In the 2016 assessment, it was considered that the measures only partially addressed 
the GES components. As for targets, in 2016 there were uncertainties regarding the 
ability of the measures to cover all elements of the targets’ definitions. Estonia has 
made a step back in the definition of targets as there are no D11-specific targets 
reported under Article 10 anymore. It is therefore impossible to judge whether the 
measures will contribute to achieving the targets and ultimately GES. 

140 

 
 
 
The adequacy of Estonia’s programme of measures to address 
biodiversity issues is considered good. 

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Estonia’s programme of measures for D1 is considered very good 

-  The gap analysis reported by the Member State clearly outlines the current status of 
each of the species’ groups and the habitat under descriptor 1 and whether they are 
currently at GES. 

-  The pressures can be clearly linked to the new measures introduced in the 2021 

programme of measures, demonstrating that the Member State has used the gap 
analysis as a tool for designing new and effective measures. 

-  The baseline scenario is also summarised, stating that with no further action 
pressures will continue to rise, having a negative impact on biodiversity. 

-  All new measures reported in the programme of measures address relevant pressures 
(especially those identified in the gap analysis as still problematic) and contribute to 
all relevant environmental targets under descriptor 1. 

-  Where, when and how the measures will be implemented is reported in a partially 

adequate manner. 

-  The single new updated spatial protection measure also addresses the relevant 

pressures indirectly through reviewing and improving the effectiveness of Estonian 
MPAs. 

-  Socio-economic  developments  and  their  impacts  on  measure  effectiveness  are  not 

discussed. 

-  Some information is missing such as action modes and some information requiring 
further details, for example the timelines of implementation steps within each measure. 
-  In 2016, the assessment determined that pressures and environmental targets were 
partially covered by the measures. Progress has therefore been made since 2016, with 
measures now implemented to reduce bycatch of vulnerable species.  

-  Targets related to fish are not entirely addressed by the measures.  
-  For  pelagic  habitat,  progress  has  not  been  made  since  the  2016  assessment,  as 
nutrient  input  from  land-based  activities  is  not  addressed  by  any  of  the  measures 
reported under descriptor 1 in the programme of measures. 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Estonia’s programme of measures for D2 is considered very good 

Strengths 

-  Estonia  has  provided  a  detailed  gap  analysis  which  includes  the  current  state  of 
introductions,  assessment  concluding  that  GES  has  not  been  achieved  for  D2,  the 
current progress and limitations of the 2015 measures, and has identified where future 
measures are needed. 

-  Estonia  acknowledges  the  importance  of  the  international  implementation  of  the 
measures relating to shipping and aquaculture in the Baltic to mitigate the spread of 
NIS. 

-  The  measures  adequately  address  the  pressures  relating  to  D2  both  directly  and 
indirectly and Estonia also addresses gaps relating to hull fouling and aquaculture. 
-  The  additional  MSFD  specific  measures  only  address  Estonia's  operational 

environmental target of reducing NIS introductions to zero. 

-  Adequate details are provided on where, how and when the additional MSFD specific 

measures will be implemented.  

141 

 
 
 
 
 
Weaknesses 

-  The  future  threat  of  NIS  introduction  posed  by  the  future  potential  development  of 

aquaculture in European seas is not addressed in the programme of measures. 

-  Clarity  on  which  environmental  targets  the  measures  address  is not  provided  in  the 

Progress since 2016 

reporting. 

-  Estonia has progressed on developing adequate measures. In 2016, the measures were 

assessed only partially to address the pressures relating to D2.  

-  In the 2022 programme of measures, the additional MSFD specific measures address 
hull cleaning and the implementation of minimum requirements for EIAs to address the 
management and monitoring of NIS in maritime developments.  

-  In  2016,  the  measures  only  partially  addressed  the  targets  and  ultimately  partially 
contributed to achieving GES. The 2022 programme of measures with additional MSFD 
specific  measures  are  directly  addressing  the  introduction  of  NIS  by  implementing 
actions to limit their introductions from shipping and maritime developments.  

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Estonia’s programme of measures for D3 is considered good 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

-  Estonia identified the need for new measures to reduce fishing effort and improve the 

possibilities for restocking fish populations. 

-  All relevant pressures are addressed by the additional MSFD specific measures. 
-  All measures are linked to environmental targets and are well detailed in the reporting.  
-  Estonia explains where, how, and when measures will be implemented. 
-  Estonia has partially identified all significant gaps to achieve GES. The main obstacles 
to GES are excessive fishing, environmental obstacles and limited reproduction rate. 
-  In 2016, Estonia's measures were considered to partially address the reported pressures 
and activities. There has not been progress on addressing recreational fishing through 
the new measures. 

-  In 2016 it was considered that the measures address the D3 GES and targets. In 2022, 
the  relevant  measures  remain  in  place  and  the  additional  MSFD  specific  measures 
should further contribute to progress towards GES. 

The adequacy of Estonia’s programme of measures for D4 is considered moderate. 

-  The gap analysis provided by the Member State covers well the current status of food 

web health. 

Strengths 

-  Estonia addresses all relevant environmental targets with the new measures as there 

are many overlaps with those of descriptor 1. 

-  A measure is taken to reduce the number of fishing licenses awarded in Estonian waters  
-  Estonia does not identify pressures specific to descriptor 4, which continues to prevent 

progress towards GES. 

Weaknesses 

-  Estonia does not clearly explain how and where the new measures are needed and 

where current measures are failing. 

-  New additional and updated measures do not cover all of the pressures identified for 

food web health. 

-  Timelines not only for the implementation of the measure but the implementation steps 

within each measure are not provided. 

-  In  2016,  the  assessment  determined  that  measures  only  partially  addressed  both 

targets and pressures under descriptor 4.  

-  Limited progress has been made since 2016. Targets remain generally addressed by 
the high-level measures applied to marine mammals, however more direct measures 
are required. 

Progress since 2016 

142 

 
 
 
D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  There remain no measures under descriptor 4 for Atlantic Salmon and Perch. For real 
progress  to  be  seen,  more  species-level  measures  are  required,  especially  for  the 
species selected as indicators of food web health. 

The adequacy of Estonia’s programme of measures for D6 is considered good 

- 

- 

- 

- 

The gap analysis provided by the Member State is adequate, providing clear and 
detailed reporting on the current status of seabed integrity in Estonian waters, which 
currently meets GES, as well as the pressures which could cause this status to be 
lost.  
There are clear links between the pressures around the projected increase in human 
activity and the use of marine resources and the new measures introduced in the 
2021 programme of measures. 
Planning  for  the  compensation  of  any  negative  impacts  of  sustainable  marine 
energy development, which is projected to expand rapidly in Estonian waters, is a 
good step towards maintaining seabed health 
Several new measures do not directly address relevant pressures and targets as their 
focus is not on the physical integrity of the seabed. 

-  More direct measures which remove physical pressures and would ensure the safety 

- 

- 

- 

of the GES of seabed habitats are not provided. 
The reporting of where, when and how the new measures will be implemented is 
provided but not in detail.  
In 2016, the assessment determined that descriptor 6 pressures were not addressed 
by the measures, and targets were partially addressed. 
Progress has been made since 2016, with pressures which were not addressed in 
the first cycle of the programme of measures now addressed by new and updated 
measures. 

-  With regards to targets, measures have been introduced to reduce pressures. 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Estonia’s programme of measures for D7 is considered very good 

- 

- 

- 

Estonia defines two operational targets that will guide progress towards ultimately 
achieving GES. 
Estonia’s 2023 report shows a very complete assessment of all relevant pressures 
from existing and future activities that are likely to permanently alter hydrographical 
conditions.  
The gap analysis provided sufficient justifications for the modified and additional 
MSFD specific measures in the second cycle. 

- 

-  Measures are adequately linked to Estonia’s programme of measures under WFD, to 
other directives and legislations and actions carried out in the framework of HELCOM. 
The measures are not clearly linked to the environmental targets: the report does not 
indicate which way and to what extent these actions will contribute to achieving the 
environmental targets. 
Estonia’s adequacy score for its report on its programme of measures for D7 has 
improved since 2016. 

- 

Strengths 

Weaknesses 

Progress since 2016 

Based  on  the  information  reported  in  their  programme  of  measures,  Estonia’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘high’.  

143 

 
 
 
 
 
 
Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

did 

not 

CEA on 26 new measures, and 
benefits  analysis 
covered 
qualitative  expected benefits, 
provide 
but 
information  on  how 
this 
influenced measure selection.  
short-term  and 
Examined 
long-term 
on 
activities and well-being. 

impacts 

Named national (e.g. funds 
from  different  Ministries), 
(e.g.  municipality 
local 
funds) and EU (e.g. EMFAF, 
ERDF)  funding  sources  to 
support  implementation  of 
programme  of  measures. 
Highlighted  that  EMFAF  is 
only  a  potential  source  of 
funding  and  no  amounts 
have  been  allocated 
to 
specific measures. 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

New  measures  considered 
other  European, 
regional 
policies, 
national 
and 
strategies  and  legislation 
and 
international 
agreements,  including  the 
WFD,  MSP,  CFP  and  HBD. 
Authorities  responsible  for 
implementing  measures 
were identified. 

Regional cooperation is via 
HELCOM, 
relevant 
and 
actions  in  the  Baltic  Sea 
Action  Plan  2021  have 
been linked with the second 
Programme  of  Measures. 
is  a  cross-cutting 
There 
measure 
ensure 
to 
international  and  regional 
cooperation 
the 
protection  of  the  marine 
environment  given  existing 
cooperation frameworks. 

for 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  ten 
Descriptors  have  sufficient 
details on spatial coverage; 
and measures for one (D9) 
have partial information.   

How:  Measures  for  five 
Descriptors  (D2,  D3,  D7, 
D10,  D11)  with  sufficient 
details,  e.g.  the  Ministry  of 
the Environment of Estonia 
is the responsible authority 
for 
of 
implementation 
measures for D2. Measures 
for six Descriptors (D1, D4, 
D5, D6, D8, D9) have partial 
information. 

When:  Measures  for  eight 
Descriptors (D2, D3, D5, D7, 
D8,  D9,  D10,  D11)  have 
sufficient 
on 
temporal scope. Three (D1, 
D4, D6) with partial details. 

details 

6.5  Spain 

Summary: 

Overall, the second programme of measures presented by Spain is considered to be moderately adequate to address the 
pressures acting on the Spanish marine environment and partially contributes to achieving Spain’s GES and targets.  

In terms of strengths, Spain carried out CBA/CEA for all new measures, targeting all descriptors. Spain is actively participating 
in coordination and implementation at regional level (Barcelona Convention and OSPAR) and at EU level (through the CIS). 
Spain’s  updated  programme  of measures  report  is  quite  complete.  It  gives  a  comprehensive  overview  of  the  required 
information:  measures  and  their  characteristics,  detailed measure  factsheets,  gap analysis  and  significant  progress  on 
spatial protection measures (12 new measures). Spain presents a stronger programme of measures for biodiversity issues 
than for pollution issues.   

On the downside, there is a lack of detailed information on the cost and benefit categories assessed, and no consideration 
of  the  social  issues.  There  is  a  lack  of  clarity  over  the  gap  analyses  for  D1,  D4  and  D7  (although  overall  adequacy 
assessment for those descriptors is good), or only qualitative analyses (D8, D9), and only partial justification for withdrawal 
of certain measures (D4 and D6). Measures for commercial fish, invasive species, eutrophication, contaminants in seafood 
and litter have been considered as only moderately adequate to address the relevant pressures. 

Based on the information reported in their programmes of measures, Spain’s commitment to implementing their second 
programmes of measures has been assessed as ‘high’. 

144 

 
 
The  adequacy  of  Spain’s  programme  of  measures  for  cross-cutting  issues  is 
considered poor. 

Spain’s updated programmes of measures did not have major changes since the first cycle in terms 
of methods applied for measures selection, of regional and international cooperation, and of public 
consultation. 

Topic 

Strengths 

Weaknesses 

All  new  measures  were  subjected  to  an 
economic  assessment  including  a  Cost-
Benefit  Analysis  and  Cost-Effectiveness 
Analysis  which  helped 
in  prioritizing 
measures.  

The economic assessment methodology was 
well-explained 

Some  of  the  measures  (existing  and  new) 
outlined in Spain’s programmes of measures 
included  initiatives  concerned  with  climate 
change 
increased 
knowledge  of  climate  change  effects  on 
ecosystem  services,  and  socio-economic 
activities. 

adaptation, 

and 

The  programme  of  measure  refers  to  the 
links  between  the  MSFD  and  other  EU 
policies (WFD, MSP, CFP, BHD). 

Spain  presented  various  financing  sources 
for the implementation of the programmes 
of measures 

The  coordination  between  Spain  and 
neighbouring  countries  was  carried  out  at 
European and regional levels.  

145 

Socio-economic 
assessment 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 

Spain failed to provide detailed information 
on  the  costs  and  benefits  categories 
assessed. 
It  only  provided  general 
estimations  which  makes  it  difficult  to 
understand  what  cost  categories  and 
benefits were assessed and considered.  

Spain  did  not  present  any  indication  of 
social  issues  considered,  and  a  social 
assessment was not carried out to support 
the  development  of  the  Programmes  of 
measures 

The  programmes  of  measures  did  not 
elaborate on how the updated programmes 
of  measures  took  into  account  climate 
change  considerations  (although  Spain  is 
the  country  with  the  largest  number  of 
measures  that  can  be  categorised  as 
‘climate  change  measures’  –  see  Section 
3.3).  

Coordination mechanisms and interactions 
between the MSFD and other policies were 
only provided for the WFD and not for other 
EU policies. This lack of information makes 
it 
how 
to 
coordination  was  done, 
the  potential 
synergies,  and  the  outcomes  of  such 
cooperation with other EU policies.  

challenging 

understand 

Spain did not provide specific details on the 
the  amounts 
funds  and 
sources  of 
This 
source. 
each 
mobilized 
information  could  have  given  additional 
insights  into  the  priorities  and  targeted 
sectors/descriptors.  

from 

While  the  regional  coordination  was  well 
explained,  Spain  did  not  provide  any 
information 
the 
on 
transboundary impacts of measures.  

assessing 

The  reference  to  exchange  of  information 
and collaboration at different levels is not 

 
 
 
 
 
 
 
 
it 

is  not  clear  whether 
explicit,  and 
neighbouring countries have been informed 
on the transboundary impacts during these 
information exchanges/meetings. 

The report does not mention to what extent 
the  programmes  of  measures  was 
modified to incorporate the outcome of the 
public consultation. 

No 
information  was  provided  on  the 
evolution  of  the  implementation  process 
since the first cycle. Even if a no-evolution 
would  have  occurred,  this  was  not  made 
explicit in the text. 

transboundary 
impact 

Public consultation 
and administrative 
process 

civil 

society, 

Several  workshops,  and  bilateral  meetings 
with 
stakeholders,  and 
competent  authorities  were  held  to  discuss 
the new measures to put in place. This was 
followed by an online public consultation. All 
the collected views were taken into account 
in the final programmes of measures. 

provided 

on 
programmes 

the 
information 
Spain 
implementation 
of 
of 
measures and on the authorities in charge of 
the 
coordinating 
measures. 

implementing 

and 

The RBPM assessment highlighted that there 
does  not  seem  to  have  been  a  fully 
coordinated  development  of  the  planning 
tools of the WFD and MSFD, nor concurrent 
or 
jointly  organised  public  participation 
processes. 

The  adequacy  of  Spain’s  programme  of  measures  to  address 
pollution issues is considered moderate.  

D5- Eutrophication 

Adequacy 

The adequacy of Spain’s programme of measures for D5 is considered moderate. 

-  Spain  has  undertaken  a  gap  analysis  to  identify  where  additional  measures  might  be 

required to address pressures. 

Strengths 

-  The  reporting  identifies  updated  RBMPs  as  updated  measures  and  also  references  the 

continuing work of the OSPAR and Barcelona Conventions. 

-  The gaps identified are addressed with the definition of additional measures targeting port 

activities. 

-  Spain  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

specific additional MSFD specific measures will be implemented in the e-reporting. 

-  There is no reference to updates to the National Emissions Ceiling Directive.   
-  The  gap  analysis  appears  to  be  qualitative.  It  is  unclear  whether  the  MSFD  specific 
measures that form part of the second cycle will be sufficient to achieve GES. There is a 
lack of detailed information from the gap analysis concerning the significant pressures and 
no  quantification  of  the  contribution  of  the  MSFD  specific  measures  to  addressing  the 
significant pressures. 

-  Because of the lack of quantification of the gaps, it is unclear whether the measures will 

be sufficient to achieve GES. 

Weaknesses 

Progress since 2016 

-  There remains some uncertainty concerning the funding of some of the measures. 
-  In 2016 pressures were considered to be partially covered. Similarly, the 2022 assessment 

also considers that coverage of pressures is partial. 

146 

 
 
 
 
 
 
-  In  2016,  measures  were  considered  to  address  the  components  of  GES  and  targets.  In 
2022 measures are considered to partially cover the components of GES and targets, which 
suggests lack of progress. 

D8-Contaminants 

Adequacy 

The adequacy of Spain’s programme of measures for D8 is considered good. 

-  Spain  has  undertaken  a  gap  analysis  to  identify  where  additional  measures  might  be 

required to address pressure. 

-  The  report  identifies  updated  RBMPs  as  updated  measures  and  also  references  the 

continuing work of the OSPAR and Barcelona Conventions. 

-  Spain  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

Strengths 

specific additional MSFD specific measures will be implemented in the e-reporting. 

-  The programme of measures is considered to address the reported pressures and activities 
in all Spanish marine subdivisions. The programme of measures also targets additional 
activities such as dredging, fishing or tourism. 

-  The modified and additional MSFD specific measures are considered to be partially linked 

to operational targets.  

-  There is no reference to Zero Pollution targets or references to updates to the National 

Emissions Ceiling Directive.   

-  The gap analysis appears to be qualitative. It is unclear whether the modified and additional 
MSFD specific measures that form part of the second cycle will be sufficient to achieve 
GES. 

-  There  remains  some  uncertainty  concerning  the  funding  of  some  of  the  measures,  for 
example confidence was assessed by ES as 'low' in terms of obtaining funding for one 
measure and 'moderate' for most others.  

-  In 2016, it was considered that the Programmes of measures addressed pressures well. In 
2022 coverage of relevant pressures is not clear as there is a lack of detailed information 
from the gap analysis concerning the significant pressures and no quantification of the 
contribution of the MSFD specific measures to addressing the significant pressures.  

-  In 2016 the measures were considered to address the components of GES and targets. In 
2022 the measures were assessed to address only partially the components of GES and 
targets, pointing to a certain deterioration.  

Weaknesses 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Spain’s programme of measures for D9 is considered moderate. 

Strengths 

-  Spain  has  undertaken  a  gap  analysis  to  identify  where  additional  measures  might  be 

required to address pressures. 

-  The report identifies where updates to RBMPs are relevant to D9. 
-  Spain  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

specific additional MSFD specific measures will be implemented.  

-  Some of the modified and additional MSFD specific measures relevant to D8 will also be 

relevant to D9 where they reduce inputs of relevant contaminants. 

-  The programme of measures is considered to address the reported pressures and activities 
in all Spanish marine subdivisions. The programme of measures also targets additional 
activities such as dredging, fishing or tourism. 

-  The justification for withdrawing one measure on handling bulk liquids in port is considered 

inadequate. 

Weaknesses 

-  The  gap  analysis  appears  to  be  qualitative.  It  is  unclear  whether  the  MSFD  specific 
measures that form part of the second cycle will be sufficient to achieve GES. There is a 
lack of details provided in the gap analysis and some discrepancies in the environmental 
targets reported under Article 10 and Article 13.   

147 

 
 
 
-  All of the modified new measures and 13 of the additional MSFD specific measures are 
cross-cutting and likely to make only a very minor contribution to achieving GES for D9.  
-  Given the total number of measures in the ES programmes of measures for contaminants 
(D8) and the single D9 specific measure reported by the Member State, it is considered 
that  more  explicit  references  could  have  been  made  about  contamination  in  species 
intended for human consumption. 

-  There remains some uncertainty concerning the funding of some of the measures.   
-  In  2016,  it  was  considered  that  the  programmes  of  measures  covered  the  relevant 
pressures.  In  2022  the  coverage  of  pressures is  not  clear  as  there  is  a  lack  of detailed 
information  from  the  gap  analysis  concerning  the  significant  pressures  and  no 
quantification of the contribution of the modified and additional MSFD specific measures 
to addressing the significant pressures. 

-  In  2016  it  was  considered  that  the  measures  addressed  the  components  of  GES  and 
targets. In 2022 the measures do not cover targets as they are considered not operational. 

The adequacy of Spain’s programme of for D10 is considered moderate. 

-  The  gap  analysis  provides  an  overview  of  the  priority  lines  relevant  to  D10  where  new 

measures should focus on. 

-  Spain  has  modified  some  existing  measures,  or  identified  additional  ones  in  order  to 
incorporate recent EU- or regional level policy updates and ES refers to important recent 
EU-level and regional developments such as those within OSPAR (guidelines) and Directive 
(EU) 2019/904. 

-  Adequate justification is provided when relevant measure is withdrawn. 
-  Spain has provided most of the necessary information on where, when, and how the specific 

additional MSFD specific measures will be implemented  

-  Spain programmes of measures lacks a quantitative gap analysis of the contribution of 
measures towards GES, which makes it difficult to assess whether the measures will be 
sufficient to achieve GES for D10. 

-  It is not clear from the reporting whether the combined set of modified and additional MSFD 

specific measures will be able to achieve GES. 

-  The modified and additional MSFD specific measures are considered to be partially linked 

to operational targets. 

-  Aquaculture in the Bay of Biscay is not specifically addressed by any of the new measures. 
-  In  2016,  it  was  considered  that  the  programmes  of  measures  covered  the  relevant 
pressures. The lack of detailed gap analysis on which were exactly the gaps to achieve 
MSFD targets and GES hampers clear conclusions on the coverage of pressures in the 2022 
assessment. 

-  In 2016, Spain did not report clear timelines for reaching GES. While the 2022 assessment 
concludes that timelines for measures of the second programme of measures are clear, it 
is not specifically mentioned whether Spain will have reached GES by 2030 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Spain’s programme of measures for D11 is considered good. 

Strengths 

-  Spain has updated existing measures and created additional ones in line with recent policy 

developments and research projects recently started. 

-  Recent  developments  within  OSPAR  are  considered,  including  recommendations  and 

guidelines specific to underwater noise.  

-  Spain  identifies  where  the  additional  MSFD  specific  measures  will  be  implemented, 
specifying  the  relevant  (sub)region  and  marine  reporting  unit  for  each  measure,  and 

148 

 
 
 
whether the measure applies in coastal waters, territorial waters, transitional waters, and/or 
the EEZ. 

-  Spain  has  explained  how  the  additional  MSFD  specific  measures  will  be  implemented, 
providing a description of how the measure will be implemented, details on relevant policies, 
on lead competent authorities and on financing.   

-  Two of the new measures focus on the gathering of data, indirectly affecting underwater 

noise instead of actively reducing the pressures.  

-  Demonstration projects proposed in the form of defining intensity thresholds are promising 

and a step in the right direction.  

-  One measure also relevant to D1 refers to the protection (prevention and mitigation) of 

marine mammals against the risk of collisions and the impacts of ambient noise. 

-  It is not clear whether Spain has adequately identified all significant gaps to achieve MSFD 

targets and GES. Spain has not estimated when GES is expected to be achieved. 

-  The  gap  analysis  does  not  contain  elements  expected  such  as  a  baseline  scenario, 
consideration of how much current measures will reduce pressures, future socio-economic 
developments, or an indication of the timeline for when GES will be achieved. 

-  The  work  of  TG  Noise  in  setting  up  threshold  values  for  D11  criteria  is  not  mentioned, 
although Spain is making efforts toward the definition of threshold values as demonstrated 
by the additional MSFD specific measures defined. 

-  Spain does not address any other anthropogenic input source such as heat/light. 
-  Spain has made some progress in the updated programmes of measures by establishing 

new measures that are relevant for D11.  

-  In 2022, as in 2016, Spain has only partially addressed the pressures and activities. The 
gaps identified in 2016 are addressed by one measure set up to mitigate underwater noise. 
This  includes  setting  intensity  thresholds, enforcing  measures  to reduce  the  emission  of 
underwater  noise,  implementing  innovation  techniques  for  underwater  noise  monitoring, 
and  implementing  awareness  measures.  However,  two  of  the  four  additional  measures 
focus on the gathering of data, indirectly affecting underwater noise instead of actively 
reducing the pressures. 

Weaknesses 

Progress since 2016 

The  adequacy  of  Spain’s  programme  of  measures  to  address 
biodiversity issues is considered good. 

D1 — Biodiversity 

Adequacy 

Strengths 

The adequacy of Spain’s programme of measures for D1 is considered good. 

-  The modified and the additional MSFD specific measures in the second programme of 

measures address all relevant pressures. 

-  Spain reports 28 ‘direct’ measures for D1 although a majority are considered addressing 

pressures only indirectly.  

-  ‘Direct’ measures reported include the designation of protected areas, the regeneration of 
habitats,  the  reduction  of  disturbance  from  human  activities,  and  the  reduction  of 
incidental species extraction through bycatch. These measures directly address pressures 
such as species disturbance and species extraction, both of which pose a significant threat 
to local biodiversity. 

-  It is considered that Spain has explained where and how the additional MSFD specific 

measures will be implemented.  

-  Measure  descriptions  are  provided,  links  to  international  and  national  policies  are 
provided, responsible authorities and organisations are identified and the level at which 
co-ordination is required is specified.  

149 

 
 
 
 
 
-  The additional MSFD specific measures relating to MPAs adequately address relevant 

pressures.  

-  There is only a partial explanation of how the updates to the existing measures from the 

first cycle contribute to achieving GES. 

-  There is a lack of clarity over the gap analysis (e.g. no information is presented regarding 
the current conservation status of habitats or species and the effectiveness of first cycle 
measures is not assessed), meaning that the gaps identified are not entirely reliable. 
-  Spain only provides partial justification for the withdrawal of two measures relevant to 

D1-biodiversity. 

-  A number of measures are studies, or measures with the explicit aim of improvement of 
knowledge. Whilst essential for the long-term health of marine biodiversity, knowledge 
acquisition measures do not have immediate direct impacts on the relevant pressures.  

-  There is insufficient emphasis on the water column habitats. 
-  Overall, progress made in the programmes of measures is limited as the assessment for 

the 2016 report is generally the same.  

-  Spain  was  assessed  as  addressing  pressures  in  all  species  groups  in  2016,  though 
pressures on water column habitats were only partially adequately described. While the 
same result is seen in the current programmes of measures, there is perhaps still a focus 
on pressures relating to species, with less on pelagic habitats. 

-  Regarding the coverage of GES and targets in 2016, it is considered that Spain addresses 
again GES and targets for all species groups, with a strong emphasis on bycatch and the 
regulation of human activities. 

Weaknesses 

Progress since 2016 

D2 — Non-indigenous species  

Adequacy 

The adequacy of Spain’s programme of measures for D2 is considered moderate. 

-  There is overall good coverage of the pressures relating to D2 by the new measures. 
-  Relevant  targets  for  each  new  measure  are  reported  and  the  new  measures  are 

Strengths 

considered to contribute to the targets.  

-  Adequate detail on where, how and when the new measures will be implemented was 

Weaknesses 

Progress since 2016 

provided. 

-  It is not clear which of these measures are modified or new measures. It is also unclear 
how these measures will contribute to achieving GES for D2. Spain states that a gap 
analysis has been undertaken; however, it is not clear what gaps are identified for D2 as 
no baseline is provided nor any progress from the first cycle measures. 

-  It is unclear the status of NIS introduction and impact in Spanish waters under D2C2 and 

D2C3 

-  More detail should be provided on the relevance of some of the cross-cutting measures 

to D2. 

-  The  2016  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed. In the 2022 assessment, the coverage of pressures is also considered partially 
adequate. 

-  The 2016 assessment considered that the measures addressed the components of GES 
and targets. The new measures also address the targets which were considered adequate 
for the achievement of GES in the Article 10 assessment.  

D3 — Commercial fish and shellfish 

Adequacy 

Strengths 

The adequacy of Spain’s programme of measures for D3 is considered moderate. 

-  Spain  identifies  where  the  additional  MSFD  specific  measures  will  be  implemented, 
specifying  the  relevant  (sub)region  and  marine  reporting  unit  for  each  measure,  and 
whether the measure applies. 

150 

 
 
 
-  Spain has explained how the additional MSFD specific measures will be implemented, 
providing  a  description  of  how  the  measure  will  be  implemented,  details  on  relevant 
policies, lead competent authorities, and financing. 

-  Implementation timeline of the additional MSFD specific measures has been stated. 
-  Spain  only  partially  explains  how  the  updates  to  existing  measures  contribute  to 

achieving GES. 

-  It  is  not  clear  whether  Spain has  adequately  identified  all  significant  gaps  to  achieve 

MSFD targets and GES. 

-  The gap analysis does not contain the elements expected of a gap analysis, such as a 
baseline  scenario,  consideration of  how  much  current  measures will  reduce  pressures, 
future socio-economic developments, or an indication of the timeline for when GES will 
be achieved.  

Weaknesses 

-  The  justification  provided  for  withdrawing  new  measures  from  the  first  cycle  is  only 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

partially adequate. 

-  It  is  unclear  if  the  additional  measures  will  contribute  to  meeting  operational 
environmental targets. This is partly because it is not clear whether the targets they are 
linked to are relevant or operational, but also several of the measures promote increased 
monitoring which will not in itself reduce pressures.  

-  Given  the  state  of  fisheries  resources  in  the  Mediterranean,  it  is  considered  not  clear 
whether the management measures proposed represent a sufficient departure from the 
status quo to address the problem. 

-  In  2016,  Spain’s  programme  of  measures  report  was  considered  to  partially  address 
relevant  pressures  from  commercial  and  recreational  fisheries  as  well  as  seaweed 
harvesting in all Spanish subdivisions, except the Western Mediterranean ones. In 2022, 
the programme of measures is still considered to partially address relevant pressures as 
the gap in the Mediterranean subregion was not addressed by the additional measures. 

The adequacy of Spain’s programme of measures for D4 is considered good. 

-  The modified and the additional MSFD specific measures in the second programme of 

measures address all relevant pressures. 

-  As measures get more specific in their actions, the list of relevant pressures becomes 

more focussed. 

-  ES has indicated four measures as relevant only to D4, three are fisheries management 
measures, aimed at reducing pressures related to the extraction of biological species, the 
other one relates to seabed habitat restoration and is also relevant to D6.  

-  All measures are linked to operational targets.  
-  Spain has explained where and how the modified and additional MSFD specific measures 
will be implemented. Measure descriptions are provided, links to international and national 
policies are provided, responsible authorities and organisations are identified and the level 
at which co-ordination is required is specified. 

-  It is considered that the modified and additional MSFD specific measures relating to MPAs 

adequately address relevant pressures. 

-  There is only a partial explanation of how the updates to the existing measures from the 

first cycle contribute to achieving GES. 

-  There is a lack of clarity over the gap analysis. No information is presented regarding the 
current  environmental  status  of  food  web  stability.  The  effectiveness  of  individual 
measures is not assessed. 

-  ES only provides partial justification for the withdrawal of one measure relevant to D4-

food webs. 

151 

 
 
Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

-  Few  measures  can  be  considered  as  specific  to  food  webs,  and  only  one,  relating  to 
application  of  the  discard  regulations,  can  be  seen  as  directly  impacting  a  relevant 
pressure.  While  the  overarching  D1  biodiversity  measures  are  relevant,  there  are 
opportunities for expanding the number of measures specific to D4 food webs. 

-  Spain has only partially explained when modified and additional MSFD specific measures 

will be implemented. 

-  The adequacy of Spain’s report under Art.16 for D4 is considered ‘Good’. This is the same 

as the assessment for the 2016 report. 

-  Regarding the coverage of pressures, Spain was assessed as addressing pressures on 
food webs in 2016, based on analysis of fish, cephalopods, mammals, and reptiles. The 
same conclusion was reached in assessing the current programmes of measures. 

-  Regarding the coverage of GES and targets in 2016, again it was considered that Spain 
addressed  GES  and  targets,  based  on  analysis  of  fish,  cephalopods,  mammals,  and 
reptiles, with a strong emphasis on bycatch and the regulation of human activities. The 
same conclusions are reached for the current programmes of measures.  

The adequacy of Spain’s programme of measures for D6 is considered good. 

-  The additional MSFD specific measures in the second programme of measures address 

all relevant pressures.  

-  Details of relevant pressures are provided for each measure. 
-  In addition to broad measures which may have a positive impact on pressures, such as 
development of MPA management plans, a number of measures are more focussed on 
D6 and directly address damage and disturbance to seabed habitats (e.g. closing areas 
to demersal fishing, management of anchorages, habitat restoration projects). 

-  It is considered that Spain has explained where and how the modified and additional 
MSFD specific measures will be implemented. While the reported spatial scope of most 
of the measures is appropriate. 

-  It is considered that the modified and additional MSFD specific measures relating to MPAs 

adequately address relevant pressures. 

-  There is only a partial explanation of how the updates to the existing measures from the 

first cycle contribute to achieving GES. 

-  There is a lack of clarity over the gap analysis. No information is presented regarding the 
current  conservation  status  of  habitats  or  species.   Similarly,  the  effectiveness  of 
individual measures is not assessed. 

-  Progress towards GES is only reported in terms of whether, and how well, environmental 

Weaknesses 

objectives are being met. 

-  Spain  does  not  provide  adequate  justification  for  the  withdrawal  of  two  measures 

relevant to D6-seabed. 

-  Spain has only partially explained when modified and additional MSFD specific measures 

will be implemented. 

-  There is a gap in linking the modified and additional MSFD specific measures relating to 
MPAs to the management of specific activities such as fishing and aggregate extraction. 
-  Regarding  the  coverage  of  pressures  in  2016,  Spain  was  assessed  as  only  partially 
addressing pressures relating to physical loss and damage. The current programme of 
measures is considered to adequately address all pressures. 

-  Regarding  the  coverage  of  GES  and  targets  in  2016,  it  was  considered  that  Spain 
addressed GES and targets for seabed habitats, though this was despite GES not begin 
defined for seabed habits in North and South Atlantic subdivision or Macaronesia. There 
is a good coverage of relevant targets in the current programmes of measures. 

Progress since 2016 

D7 — Hydrographical changes 

152 

 
 
Adequacy 

The adequacy of Spain’s programme of measures for D7 is considered good. 

-  Spain  presents  the  methodology  used  to  assess  the  efficiency  of  existing  and  new 
measures from the first cycle, identify gaps, define priorities for the second cycle and 
select  relevant  actions  (withdraw  existing  measures  from  first  cycle,  modify  them,  or 
implement additional MSFD specific measures) 

-  The  second  cycle  is  structured  according  to  the  progress  against  the  achievement  of 

environmental targets. 

-  Spain partially explains how the updates to existing measures contribute to achieving 

GES. 

-  For D7, several limitations are identified: lack of knowledge of status of waters against 
GES, lack of monitoring and reporting, environmental targets too broad or not operational 
enough, and lack of clear description of the reference scenario for future human activities 
that  should  provide  the  baseline  for  identifying  pressures  to  be  addressed  by  the 
programmes of measures. 

-  It  is  not  easy  to  establish  the  specific  link  between  the  measures  of  the  updated 
programmes of measures and D7, and their expected contribution to progress towards 
ultimately achieving GES for D7. 

-  Potentially  important  pressures  linked  to  future  activities  (such  as  the  planned 
development of offshore windfarms) that should affect hydrographical conditions are not 
addressed under D7.  

-  No clear measure about desalination in the Mediterranean Sea was reported. 
-  Cumulative impacts were explicitly referenced, and it was not clear how or if they are 

addressed. 

-  It is difficult to assess if the second programme of measures will contribute to achieving 

the environmental targets or to progress towards GES for D7, and to which extent. 

-  No  additional  progress  has  been  observed  in  Spain's  report  on  D7  in  the  second 

programme of measures. 

Strengths 

Weaknesses 

Progress since 2016 

Based  on  the  information  reported  in  their  programmes  of  measures,  Spain’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘high’.  

Factor  1:  Socio-
Key 
economic  impacts  of  new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

Spain’s 
report  presents 
general information on the 
funding  sources  without 
specifying  exact  sources. 
No  information  on  which 
EU funds will be mobilised.  

An  impact  analysis  of  new 
measures  prior  to  adopting 
them, including  a  Cost-Benefit 
Analysis 
(CBA)  and  Cost-
Effectiveness Analysis (CEA) is 
undertaken.  This  helped 
in 
prioritisation. 
measure 
However,  no  information  on 
social  impacts  of  measures  is 
provided. 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

report  highlights 
Spain’s 
the 
the 
links  between 
MSFD  and  the  CFP,  WFD, 
MSP  and  HBD  in  terms  of 
objectives and measures. It 
relevant 
the 
names 
regional 
and 
national 
groups 
ensure 
that 
coordination  between  the 
WFD and MSFD.  

Reported  cooperation  via 
MSFD  and  regional  sea 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

for 

Measures 
all 
Descriptors  have  sufficient 
details on spatial coverage. 
For example, all measures 
for D4 are applicable to the 
Western 
Mediterranean 
Sea, the Bay of Biscay and 
the 
Iberian  Coast,  and 
Macaronesia. 

Measures  for  all  but  one 
Descriptor  (i.e.  D10)  have 

153 

 
 
 
 
 
 
(i.e.  OSPAR, 
conventions 
UNEP-MAP) 
working 
groups,  and  the  purpose 
and 
of 
outcomes 
cooperation.  

sufficient 
operationalisation. 

details 

on 

for 

Measures 
eight 
Descriptors  (D2,  D3,  D4, 
D5, D7, D8, D9, D10, D11) 
have  sufficient  details  on 
the  temporal  scope,  and 
three 
measures 
Descriptors  (D1,  D4,  D6) 
only 
partial 
have 
information. 

for 

6.6  Finland 

Summary: 

Overall, the second programme of measures presented by Finland is considered to be adequate to address the pressures 
acting on the Finnish marine environment and contributes to achieving Finland’s GES and targets.  

In  terms  of  strengths,  Finland  has  done  very  strong  gap  analyses  for  a  number  of  topics,  in  particular  eutrophication, 
contaminants  and  biodiversity,  and  assessed  the  extent  to  which  GES  is  achieved  with  existing  measures  and  what 
additional measures are needed. Finland also carried out CBA/CEA for all new measures. Finland also presented what it 
has done in terms of regional cooperation for each measure for almost all topics (except non-indigenous species and 
hydrographical conditions). Details are provided on coordination between the MSFD and the WFD in terms of measures’ 
objectives, coordination and implementation. It is explained that the measures targeting the River Basin Management Plan 
(RBMP) are essential to reach GES. It should be noted that Finland’s 3rd RBMP under the WFD concludes that there has been 
a decrease in the area of coastal waters in good status (from 27% to less than 15%), signalling a deterioration, which may 
be due to improved monitoring. Therefore, Finland should ensure that the appropriate measure are taken and implemented 
to achieve the objective of both WFD and MSFD.  

On  the  downside,  measures  for  contaminants  in  seafood  and  non-indigenous  species  are  considered  only  moderately 
adequate to cover relevant pressures. No information is provided on the amounts foreseen for each source of fundings.  

Based on the information reported in their programmes of measures, Finland’s commitment to implement their second of 
programme of measures has been assessed as ‘high’. 

The  adequacy  of  Finland’s  programme  of  measures  for  cross-cutting  issues  is 
considered good. 

The update of the programme of measures has not experienced major changes since the first cycle 
in  terms  of  methods  applied  for  measures  selection,  reported  links  between  the  MSFD  and  other 
policies,  regional  and/or  international  cooperation,  and  public  consultation.  Finland  respected  the 
reporting  guidelines  and  reported  all  the  needed  information.  Nevertheless,  clarifications,  allowing 
better understanding, are still needed for different sections of the cross-cutting, such as economic 
analysis, climate change considerations, public consultation, etc.  

Topic 

Strengths 

Weaknesses 

154 

 
 
 
 
 
 
Socio-economic 
assessment 

Interactions with 
climate change 

Measures selection was done by undertaking 
a CEA and CBA. 

Finland provided information on the different 
cost  categories  considered  and  benefits 
assessed for improving/achieving GES. 

Social  assessment  of  potential  social 
impacts  of  measures  was  provided  in  the 
programme of measures. 

The impact of climate change on the marine 
environment, notably on ecosystem services 
has been presented by Finland.  

The  programme  of  measures  mentions  for 
each measure (when relevant), the potential 
reduction in GHG.  

For  some  measures,  the  reason  for  not 
undertaking  the  CBA  and  CEA  is  not 
provided. 

The  methodology  followed,  the  outcomes 
of CEA and CBA and how they influence the 
selection of measures are not presented in 
the programme of measures.  

in 

the  social 
Uncertainty  still  exists 
assessment  methodology  and  results  as 
they are not reported in the programme of 
measures. 

in  enhancing 

Uncertainty still exists on i) the role of new 
measures 
the  adaptive 
capacity  to  climate  change,  ii)  the  role  of 
new  measures  in  the  climate  change 
adaptation strategy, and iii) the effects of 
new  measures  in  preserving  ecosystem 
services and socio-economic activities. 

The  link  between  MSFD  and  WFD  is  made 
and the coordination between both directives 
is done at the ministerial level. 

Uncertainty still exists on the mechanisms 
and outcomes of coordination between the 
MSFD and the mentioned directives. 

The programme of measures clearly states 
that measures considered in the River Basin 
Management Plan (RBMP) are important for 
to 
marine  management  and  essential 
reaching GES. 

Finland  does  not  provide  additional 
information on the amounts mobilised from 
each  source  making  it  difficult  to  better 
understand  priorities  and  the  targeted 
sectors and descriptors.  

Links to other 
policies 

Finland  presents  the  coordination  done 
between  the  MSFD  and  many  other  EU 
legislations/policies  such  as  the  BHD,  MSP, 
CFP,  EU  Biodiversity  Strategy,  EU  REACH 
Directive,  Flood  Directive,  Nitrates  Directive, 
Single  Use  Plastic  Directive,  and  Urban 
Wastewater Treatment Directive. 

On  the  regional  level,  cooperation  is  taking 
place through HELCOM, namely through the 
HELCOM GEAR Working Group. 

It is unclear if Finland communicates with 
neighbouring 
the 
countries 
transboundary impacts. 

on 

Finland  participated  in  elaborating  on  the 
Baltic Sea Action.  

Regional 
cooperation and 
transboundary 
impact 

On  the  EU  level,  Finland  coordinates  with 
other EU Member States through the Marine 
Strategy Coordination Group and its working 
the 
group 
recommendation 
operational 
programme. 

POMESA  which 

updated 

the 

on 

Transboundary  impacts  of  the  proposed 
measures are addressed in the programme 

155 

 
 
 
 
 
of measures and are assessed for different 
descriptors. 

Feedback from public consultation has been 
the 
in 
considered 
programme of measures.  

finalisation  of 

the 

Public consultation 
and administrative 
process 

Finland  provides  a  clear  indication  of  the 
responsible  authority 
the  MSFD 
implementation and coordination at different 
levels. 

for 

in  all 

its  RBMPs, 

Unlike 
the  MSFD 
programme of measures does not include 
a summary of the changes made after the 
consultation. 

The  adequacy  of  Finlands’s  programme  of  measures  to  address 
pollution issues is considered good.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

The adequacy of Finland’s programme of measures for D5 is considered very good 

-  Eutrophication pressures and relevant measures are well understood.  
-  Measures  have  been  identified  to  address  the  key  pressures  contributing  to 
eutrophication. It is consistent with Finland’s reporting under the WFD where, for some 
RBMPs, Finland mentioned that the measures to reduce the nutrient load were designed 
with the requirements to improve the status of marine waters, in addition to that of 
surface waters.   

-  Finland has provided most of the necessary information on where, when, and how the 

specific additional MSFD specific measures will be implemented. 

-  The  gap  analysis  quantifies  the  extent  to  which  specific  measures  contribute  to 
achieving GES noting that their effectiveness will depend on how and to what extent 
they are implemented. 

-  Not all measures have yet been implemented.  
-  The  timing  of  implementation  of  some  of  the  measures  appears  optimistic  and 

financing of many of the measures remains unclear.  

-  In 2016, the assessment considered that coverage of pressures for D5 in the Baltic Sea 
had been addressed. In 2022, the assessment considers that all relevant pressures are 
addressed.  

-  In 2016, the assessment considered that the measures addressed the definitions of 
GES and targets. Similarly, in 2022, the assessment considers that all components of 
GES and targets are covered. 

The adequacy of Finland’s programme of measures for D8 is considered very good 

-  Contamination pressures and relevant measures are well understood. 
-  Measures have been identified to address pressures where feasible. 
-  The gap analysis recognises that GES may not be achieved for PBDEs for which no 

Strengths 

additional measures can be taken.  

-  The  gap  analysis  qualitatively  evaluates  the  extent  to  which  specific  measures  in 

relation to shipping can contribute to achieving GES.   

-  A range of additional actions are also being taken to manage pollution risks.  

156 

 
 
 
 
 
 
 
 
-  Finland has provided most of the necessary information on where, when, and how the 

additional MSFD specific measures will be implemented 

-  Not all measures have yet been implemented as the measures under the Baltic Sea 

Weaknesses 

Action Plan. 

Progress since 2016 

-  The financing of many of the measures is not clearly provided. 
-  In  2016,  pressures  for  D8  were considered  to be addressed.  Similarly,  in  2022,  the 

assessment considers that all relevant pressures are addressed.  

-  In  2016,  measures  were  considered  to  address  the  definitions  of  GES  and  targets. 
Similarly,  the  second  cycle  assessment  considers  that  the  assessment  covered  all 
components of GES and targets. 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Finland’s programme of measures for D9 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  Contamination pressures and relevant measures for D8 (which are relevant to D9) are 

well understood.   

-  Finland has provided most of the necessary information on where, when, and how the 

specific additional MSFD specific measures will be implemented. 

-  No specific gap analysis is provided for D9.  
-  Not all measures for D8 (which are relevant to D9) have yet been implemented. 
-  The timing of implementation of some of the measures is not clear. 
-  The financing of many of the measures is not clearly provided. 
-  In 2016, pressures for D9 were considered to be covered. However, in 2022, relevant 
pressures are considered to be only partially addressed due to limited reporting specific 
to D9.  

-  In 2016, the measures were considered to address the definitions of GES and targets. 
In 2022, components of GES and targets are considered to be only partially covered 
due to limited reporting specific to D9. 

The adequacy of Finland’s programme of measures for D10 is considered good 

-  A gap analysis is provided. 
-  The  main  pressures  related  to  litter  input  are  addressed  by  the  combined  set  of 

measures in the second cycle.  

-  All new measures are linked to operational targets. 
-  Timelines have been indicated for all additional MSFD relevant measures in the second 
cycle and for the most part it is clear how and where measures will be implemented. 
-  Some aspects of the gap analysis are missing: no baselines are mentioned; it is stated 
that good environmental status is not defined for D10 due to lack of a quantitative 
determination of GES. 

-  Existing measures are not linked to the environmental targets in a quantitative way.  
-  Compared  to  the  previous  assessment,  Finland  has  updated  its  programme  of 
measures with several additional MSFD specific measures to better account for all the 
main pressures in its Baltic waters related to D10 (marine litter). 
-  As in 2016, Finland addresses the main pressures related to D10. 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Finland’s programme of measures for D11 is considered good 

Strengths 

-  Finland has proposed ambitious new measures to reduce underwater noise through 

speed limits, technological innovations, and limiting noise generation. 

-  New measures are clearly described including an implementation plan, timetables, and 

spatial scope.  

157 

 
 
 
 
Weaknesses 

-  A clear gap analysis was not provided for D11. 
-  There is not a quantitative determination of GES. 
-  No  measure address  heat  impacts  and  heat  discharges  and  there  is  no  associated 

Progress since 2016 

target.   

-  Finland's report on D11 underwater noise for the Baltic Sea has made little progress 

since 2016. 

-  As in the first cycle, the measures do not address the second part of the GES definition 

dealing with heat impacts and heat discharge. 

The adequacy of Finland’s programme of measures to address 
biodiversity issues is considered good.  

D1 — Biodiversity 

Adequacy 

The adequacy of Finland’s programme of measures for D1 is considered very good 

-  A  strong  gap  analysis  is  presented,  which  has  been  conducted  using  a  model 

successfully used by HELCOM (HELCOM SOM). 

-  Weaknesses  in  the  previous  programme  of  measures  have  been  identified  and 
additional MSFD specific measures introduced to help strengthen the current cycle and 
achieve GES. 

-  The gap analysis identifies the measures necessary to address most of the pressures. 
-  The  modified  and  additional  MSFD  specific  measures  address  the  main  pressures 

Strengths 

threatening biodiversity and are linked to operational environmental targets.  

-  Each measure is matched well with both the relevant pressures and environmental 

targets.  

-  The practicalities of each new measure are well presented: it is clearly indicated when 

each measure will be implemented, on what scale, and for how long.  

-  New MPA measures are well reported, with profiles presented for each measure that 
explain how it will be implemented, as well as links with current policies and with other 
measures.  

-  The gap analysis presents limited updates on the progress of environmental targets. 
-  Updates  are  also  difficult  to  find  for  descriptor  1  owing  to  the  structure  of  the 

programme of measures itself. 

-  There is no clear chapter that refers to biodiversity, as it is linked to many pressures, 

Weaknesses 

making information on the descriptor difficult to pick out.  

-  Information on how the measure will be implemented is not complete, making the 

effectiveness of the implementation of these measures uncertain 

-  Measures are needed for the hunting of seabirds and to protect spawning areas for 

migratory fish. 

-  The majority of the recommendations made by the Commission have been covered 
in the updated programme of measures, showing real progress in the last 5 years. 
-  With regard to the pressures addressed, the assessment concludes that progress has 

been made in the second programme of measures. 

-  With  regard  to  the  coverage  of environmental  targets and  GES, the  assessment  in 
2016  considered  these  addressed  partially  by  the  measures.  In  2022,  it  can  be 
considered that progress has been made since the coverage of targets is considered 
adequate  and  in  addition,  modified  and  additional  MSFD  specific  measures  are  in 
place. 

Progress since 2016 

D2 — Non-indigenous species 

158 

 
 
 
 
 
Adequacy 

The adequacy of Finland’s programme of measures for D2 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

-  A  range  of  measures  have  been  implemented  to  mostly  target  shipping  (ballast 
water), which is recognised as the main pathway associated with the introduction of 
NIS. 

-  Finland has described measures which were not reported in the e-reporting in 2015. 
-  Finland states that IMO updates to the biofouling guidance will be incorporated in the 

future. 

-  Ship hull fouling has been identified as a potential pathway of introduction; however, 

it is not currently being addressed in the programme of measures. 

-  A new measure regarding the removal of alien predators was recognised by Finland; 
however, this does not directly link to the pressure related to D2 on the input or spread 
of NIS or the primary criterion for D2C1.  

-  It remains unclear if other pathways such as aquaculture, recreational vessels or hull 

fouling are accounted for in the measures. 

-  Progress has been made since 2016 as Finland have stated they have achieved GES 

for D2. 

-  It was highlighted in the previous assessment that it was not clear what pathways the 
other measures target and if aquaculture was addressed. In 2022, the assessment 
remains unclear if other pathways such as aquaculture, recreational vessels or hull 
fouling are accounted for in the measures. 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Finland’s programme of measures for D3 is considered good 

-  Finland carried out a comprehensive gap analysis; and identified that even though all 
the first cycle measures had been implemented, progress to GES was insufficient. 
-  10 additional MSFD specific measures and one updated MSFD specific measure are 
included in the updated programme of measures to address the gaps identified in their 
analysis and progress towards achieving GES 

-  The  updated  programme  of  measures  continues  to  address  all  relevant  pressures 

associated with D3. 

-  Discrepancies in reporting are detected, particularly with regards to the environmental 

targets associated with the additional MSFD specific measures.  

-  There is a lack of detail for some fields for additional MSFD specific measures. 
-  No change to existing measures from the first cycle is reported but several existing 

measures identified as from the first cycle are from after 2015. 

-  Two of the additional MSFD specific measures are classified as ‘new’ but it appeared 
from the reporting that they were extensions of MSFD specific measures from the first 
cycle programme of measures. 

-  Finland  does  not  explain  how  the  effectiveness  of  the  additional  MSFD  specific 

measures will be assessed. 

-  There is no measure covering recreational fishing. 
-  In 2016, the assessment concluded that Finland had addressed the key pressure.  In 
2022,  the  coverage  of  pressures  was  also  assessed  as  being  fully  addressed. 
Finland has improved its coverage of pressures by including additional MSFD specific 
measures in its updated programme of measures.  

-  In the 2016 assessment, Finland was considered to address all components of GES 
and targets. However, in 2022, the coverage of GES and targets is assessed as being 
partially addressed. 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

159 

 
 
 
Adequacy 

The adequacy of Finland’s programme of measures for D4 is considered good 

-  The reporting of the relevance of new measures to operational environmental targets 

is good.  

Strengths 

-  The practicalities of the new measures are also well reported: Finland clearly indicates 

when each measure will be implemented, on what scale and for how long. 

-  The reporting of new MPA measures is good, with a large amount of detail provided 

Weaknesses 

about each new measure. 

-  The details include justification for each measure, as well as conservation objectives 

and the relation of some measures to Natura 2000.  

-  No real gap analysis is provided, making it a major weak point. 
-  The  current  status  reports  that  food  webs  meet  GES;  however,  it  also  reports  that 
eutrophication threatens lower trophic levels. Finland does not report how GES is going 
to be maintained outside of the measures put in place under D5.  

-  Finland still reports additional MSFD specific measures for D4; however, in most cases, 

these measures are aimed at other descriptors. 

-  Information on how the measures will be implemented is not complete, making the 

effectiveness of the implementation of these measures uncertain. 

-  A  large  proportion  of  these  recommendations  have  not  been  addressed,  meaning 

moderate progress has been made towards GES in the last 5 years. 

-  In 2016 it is stated that Finland partially covers all relevant pressures. With regard to 

Progress since 2016 

the pressures addressed in 2022, progress is moderate. 

D6 — Seafloor integrity 

Adequacy 

-  In 2016, Finland covered targets and GES. In 2022, the assessment concludes that 
GES has been achieved for descriptor 4, meaning progress is expected to be minimal, 
and the GES should simply be maintained. 

The adequacy of Finland’s programme of measures for D6 is considered good 

-  A strong gap analysis is presented and this gap analysis has been conducted using a 

model successfully used by HELCOM. 

-  The gap analysis clearly identifies areas in which the current measures are lacking and 

Strengths 

proposes additional measures to fill these gaps. 

Weaknesses 

Progress since 2016 

-  All reported new MPA measures adequately address the identified pressures. Finland 
makes clear why each new MPA measure is necessary to achieve the GES and what 
it will do to achieve it. 

-  There are limited updates regarding the progress of environmental targets. 
-  Information on the practicalities of new measures is lacking, mostly for how measures 

will be implemented. 

-  The majority of the recommendations made by the Commission have been covered 
by Finland in the updated programme of measures, showing real progress in the last 
5 years. 

-  Clear progress has been made since 2016. 
-  In 2016, the following conclusions were drawn on pressures: the measures address 
physical loss and damage caused by dredging but Finland does partially cover nutrient 
enrichment.  In  2022,  measures  are  in  place  to  address  eutrophication  as  a  main 
pressure for seabed. 

-  In 2016, it was concluded that measures partially address seabed species and key 
habitats, and the targets are addressed by the measures defined for seabed habitat. 
In 2022, out of the 18 updated and additional MSFD specific measures, 8 measures 
do not correspond to an operational environmental target. 

D7 — Hydrographical changes 

160 

 
 
 
Adequacy 

The adequacy of Finland’s programme of measures for D7 is considered very good 

Strengths 

-  Finland considers that its waters are at GES for D7, "hydrographical changes". 
-  Finland carried out a gap analysis for D7, including an assessment of the effectiveness 
of  the  existing  measures  and  an  assessment  of  future  activities  likely  to  cause 
pressures linked to hydrographical changes which also considers the likely influence of 
climate change. 

-  Finland considers that existing and future activities have and will have in the future 
only local and limited effects and that existing measures (exclusively based on existing 
legislation) will be sufficient to maintain GES for this descriptor.  

-  The measures are adequately linked to measures implemented under WFD and at 

regional level (HELCOM).  

-  While Finland has defined several environmental targets, none of these environmental 

objectives can be clearly linked to D7. 

Weaknesses 

-  No mention is made of the way cumulative impacts are addressed. 
-  Finland’s  RBMPs  provide  little  details  on  measures  to  address  hydromorphological 

Progress since 2016 

pressures. 

-  The programme of measures was considered adequate in 2016 and is unchanged in 

2022. 

-  No additional progress was made, except that now all measures are now reported 

"ongoing" or "implemented". 

Based  on  the  information  reported  in  their  programmes  of  measures,  Finland’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘high’.  

Key  Factor  1:  Socio-
economic impacts of new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

provides 
Finland 
information  on 
funding 
sources  for  each  measure, 
which includes national and 
EU (e.g. CAP) funds, private 
funding, and project funds. 
It  is  not  clear  if  project 
funding 
to 
European research projects, 
and there is no indication if 
funding has been secured.  

related 

is 

Finland carried out an impact 
analysis  of  new  measures 
to  adopting 
prior 
them, 
Cost-Benefit 
including 
a 
(CBA)  and  Cost-
Analysis 
Effectiveness  Analysis  (CEA), 
but there is no information on 
influences 
how 
or 
measure 
prioritisation. 

selection 

these 

assessment 

Social 
of 
measures focuses on impacts 
on well-being, human health, 
living conditions, comfort, and 
on employment. 

Key 
3: 
Factor 
Coordination  with  EU 
regional 
policies  and 
coordination 

Finland  provides  details  on 
coordination  between  the 
MSFD and the WFD in terms 
and 
of 
objectives 
of 
implementation 
(including 
measures 
responsible 
authorities). 
However, it did not elaborate 
on  links  of  MSFD  with  the 
CFP, MSP and HBD.  

undertook 
Finland 
and 
coordination 
cooperation  with  countries 
for  each  measure.  Also 
presented 
regional 
coordination  via  HELCOM 
and  at  EU  level  (e.g.  MSFD 
working groups).   

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  nine 
Descriptors  (all  except  D2 
and  D7)  have  sufficient 
detail  on 
their  spatial 
coverage.  

How: Measures for only one 
(D11) 
Descriptor 
has 
detail,  while 
sufficient 
eight 
measures 
Descriptors 
have 
partial details. 

for 
only 

When:  Measures  for  eight 
Descriptors (except for D5) 
have sufficient information 
on  the  temporal  coverage. 
Finland  reports  that  these 
measures  have  not  yet 
implemented  but 
been 

161 

 
 
 
 
 
 
an 
provides 
implementation  timeframe 
for 2022-2027. 

6.7  France  

Summary: 

Overall, the second programme of measures presented by France is considered to be moderately adequate to address the 
pressures acting on the French marine environment and partially contributes to achieving France’s GES and targets.  

In terms of strengths, France defined a number of new operational targets for which they designed specific measures for 
almost all descriptors. France carried out CBA/CEA for new measures and CEA results were used to select measures. Social 
assessment of measures covered impacts on employment and activities. France provided information on funding sources 
for each measure, including national, regional, local and public funds, and authorities responsible for implementing the new 
measures have been identified. Measures for litter, biodiversity, including food webs and seafloor integrity, and commercial 
fish are considered to adequately address pressures identified in French waters.  

On the downside, France has not always carried out a thorough gap analysis to allow for the identification of gaps to GES 
and the definition of adequate measures. Measures for eutrophication and contaminants are considered partly insufficient 
to cover relevant pressures. France also does not specify the amounts of funding mobilised for different measures and 
how they will be prioritised. The consultation with neighbouring countries on the transboundary impacts of the measures is 
unclear.  Little  information  is also  provided  on  the administrative  framework  in  place  to  implement  the  programme  of 
measures.  

Based on the information reported in their programmes of measures, France’s commitment to implement their second 
programme of measures has been assessed as ‘high’. 

The  adequacy  of  France’s  programme  of  measures  for  cross-cutting  issues  is 
considered moderate. 

The updated programme of measures did not witness major changes since the first cycle, notably for 
methods applied for measures selection, regional/international cooperation, and public consultation. 
Overall, for the second cycle, France reported the required information however some of it is missing 
and/or  incomplete.  Better  understanding  and  a  higher  assessment  score  may  have  resulted  from 
more information on the various cross-cutting topics. 

Topic 

Strengths 

Weaknesses 

Socio-economic 
assessment 

The  selection  of  new  measures  has  been 
done  by  following  three  main  steps:  gap 
analysis, analysing the sufficiency of existing 
measures,  and  defining  and  adopting  new 
measures.  A  Cost  Effectiveness  Analysis 
(CEA) is carried out for new measures.  

The  CEA  results  are  used  to  identify  cost-
efficient  measures and 
the 
measures. 

compare 

France  undertook  an  assessment  of  social 
issues.  

162 

Additional  information  should  have  been 
provided  on  the  cost-efficiency  of  the 
comparison  between 
measures, 
measures and the methodology influencing 
measure selection. 

the 

A  Cost  Benefit  Analysis  is  not  undertaken 
prior 
implementation  of  new 
measures.  

the 

to 

France  does  not  provide  additional 
information  on  the  methodology  followed 

 
 
 
 
 
 
 
to assess social issues nor on the results of 
the assessment 

Climate  change  is  not  considered  in  the 
updated programme of measures. 

information 

No  additional 
the 
mechanisms and outcomes of coordination 
between  MSFD  and 
the  mentioned 
directives was given by France. 

on 

France  does  not  specify  the  amounts  of 
targeted 
funding  mobilized,  nor  on 
sectors/descriptors for the financing sources 
mentioned.  

A transboundary assessment of measures 
could have been performed. 

The consultation of neighbouring countries 
on  transboundary  impacts  of  measures  is 
not explicitly mentioned in the programme 
of measures.  

Information provided by France was limited 
and 
and 
little 
superficial 
gave 
the  administrative 
understanding  of 
the 
to  make 
in  place 
framework 
programme of measures operational. 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Links between MSFD and other EU policies, 
notably WFD, CFP and BHD were presented 
by France for every measure.  

According  to  the  RBPM  assessment,  all 
French  RBMPs  include  objectives  for  the 
MSFD.  

It  should  also  be  noted  that  the  French 
programmes  of  measures  has  been 
developed together with the French maritime 
spatial plans. 

Regional  cooperation  was  done  through 
OSPAR (for North Atlantic Regional Sea) and 
UNEP/MAP (for Mediterranean Regional Sea). 

Additionally,  meetings  with  neighbouring 
countries  prior  to  programme  of  measures 
to  discuss 
adoption  were  organized 
measures. 

Feedback from stakeholders were taken into 
account 
the 
in 
programme of measures. 

final  version  of 

the 

Public consultation 
and administrative 
process 

for 

Responsible 
the 
authorities 
implementation of each measure as well as 
temporal coverage and expected year of end 
of  implementation  are  presented  in  the 
programme of measures.  

The adequacy of France’s programme of measures to address 
pollution issues is considered moderate.  

D5- Eutrophication 

Adequacy 

Strengths 

The adequacy of France’s programme of measures for D5 is considered poor. 

-  The additional MSFD-specific measures which seek to reduce excessive nutrient inputs are 

linked to operational targets. 

-  France  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

additional MSFD-specific measures will be implemented. 

163 

 
 
 
 
 
 
 
 
 
 
Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  There is no gap analysis presented. 
-  France has not clearly identified any new or updated existing measures in its reporting. 
-  There  are  possible  omissions  in  the  reporting  of  measures  including  updated  existing 
measures  (e.g.  updated  measures  for  WFD)  and  new  existing  measures  (National 
Emissions Ceiling Directive).  

-  There is a lack of information on progress towards GES in any of the sub-regions and no 
clear  assessment  is  provided  of  the  contribution  that  existing  or  new  measures  make 
towards achieving GES.  

-  Financing of the measures remain unclear.  
-  In 2016, pressures had been assessed as partially covered. In 2022, it is unclear the extent 
to which the measures will fully address the pressures owing to limitations in the reporting 
of progress towards GES and in the gap analysis. 

-  In 2016, measures were assessed as partially covering all components of GES and targets. 

In 2022, the measures are clearly linked to targets considered to be operational. 

The adequacy of France’s programme of measures for D8 is considered moderate. 

-  The  additional  MSFD-specific  measures  proposed  by  France  are  linked  to  operational 
targets. These are measures that will lead to a reduction in the input of contaminants over 
time. 

-  France  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

additional MSFD specific measures will be implemented 

-  A gap analysis is not presented in the programme of measures. 
-  The  progress  towards  GES  is  not  detailed  and  no  clear  assessment  is  provided  of  the 

contribution of existing or new measures make towards achieving GES. 

-  There  are  possible  omissions  in  the  reporting  of  measures  including  updated  existing 
measures  (e.g.  updated  measures  for  WFD)  and  new  existing  measures  (National 
Emissions Ceiling Directive). These measures are relevant to substances such as Pb, Cd, 
Hg,  dioxins  and  dioxin-like  substances,  PCBs  and  PAHs  (as  specified  in  Regulation 
1881/2006). 

-  The  detail  of  some  of  the measures is  lacking and  financing  of most  of the  measures 

remains unclear.  

-  In  2016,  pressures  had  been  assessed  as  addressed.  In  2022,  as  no  clear  analysis  of 
pressures  and  relevant  activities  is  presented  for  any  of  the  four  subregions,  it  is  not 
possible to assess progress. 

-  In  2016,  all  components  of  GES  and  targets  were  partially  addressed.  In  2022,  the 

measures are linked to targets considered to be operational. 

D9 — Contaminants in seafood 

Adequacy 

Strengths 

Weaknesses 

The adequacy of France’s programme of measures for D9 is considered moderate. 

-  The new measure specific to D9 and applicable in the Bay of Biscay and Celtic Sea sub-

regions is linked to an operational target. 

-  France  has  provided  most  of  the  necessary  information  on  where,  when,  and  how  the 

specific additional MSFD specific measures will be implemented. 
-  A gap analysis is not presented in the programme of measures. 
-  There  are  possible  omissions  in  the  reporting  of  measures  including  updated  existing 
measures  (e.g.  updated  measures  for  WFD)  and  new  existing  measures  (National 
Emissions  Ceiling  Directive).  The  progress  towards  GES  is  not  detailed  and  no  clear 
assessment  is  provided  of  the  contribution  existing  or  new  measures  make  towards 
achieving GES. 

-  Financing appears to not be secured for the additional MSFD specific measures.  

164 

 
 
 
Progress since 2016 

D10 — Marine litter 

Adequacy 

-  In  2016,  the  pressures had been  assessed as  addressed. In  2022,  as  none  of  the  text 
reports for the subregions clearly identify the pressures and relevant activities contributing 
to contaminants in biota it is not possible to assess progress.  

-  In  2016,  all  components  of  GES  and  targets  were  considered  addressed.  In  2022,  the 

measures are linked to operational targets. 

The adequacy of France’s programme of measures for D10 is considered good 

-  France  has  provided  several  modified  and  additional  MSFD-specific  measures  clearly 

linked to its two operational targets. 

Strengths 

-  France has adequately explained where, how and when modified and additional MSFD-

specific measures will be implemented. 

-  Effort is made to include measures tackling certain knowledge gaps for D10. 
-  A quantitative gap analysis is lacking for the four different marine reporting units and a 
qualitative appraisal of the contribution of the first cycle programme of measures towards 
GES is provided only for the Greater North Sea. 

-  France’s programme of measures focuses on further preventing input of marine litter but 
does not include any measure related to reducing the already existing level of marine litter. 
-  Recent EU-level developments (e.g., Zero Pollution targets, EU Beach litter thresholds) are 
not mentioned and there is no reference to the work of OSPAR and Barcelona Convention 
with regard to marine litter, in particular regional action plans against litter. 

-  Funding mechanisms are only provisional, and it is not explained to what extent France will 

be able to secure financial means for implementation of all new measures. 

-  Environmental  targets  have  been  revised  since  2016  in  order  to  make  them  more 

operational, and measures of the second cycle are clearly linked to those targets. 

-  In  2016,  it  was  concluded  that  France  had  addressed  the  key  pressures  and  activities. 
France was also considered to address almost all components of GES and targets for D10 
except for micro-litter.  

-  France has identified a number of modified and additional MSFD specific measures which 
are still considered to address most of the relevant pressures. However, measures explicitly 
linked to micro-litter, as well as secondary criteria for D10 are still lacking.  

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of France’s programme of measures for D11 is considered moderate. 

-  France has  improved the  content  of  its  programme  of measures  by  defining  a  specific 
measure  that  address  impulsive  noise  from  industrial  operations,  although  this  is  an 
indirect measure aiming at improving the knowledge base.  

-  Measure descriptions are overall of good quality, France has adequately explained where, 
how and when modified and additional MSFD-specific measures will be implemented.  

-  The results of the gap analysis are not presented for underwater noise.  
-  Some recommendations from the first cycle were not implemented, such as better linking 
the programme of measures with monitoring programmes to measure the effectiveness 
of  measures,  and  establishing  links  with  EU  policies  and  international  instruments  for 
underwater noise and energy. 

-  The programme of measures is lacking specific measures to tackle continuous noise from 
shipping sources and inputs from other anthropogenic sources such as heat and light. 
-  In  2016,  all  pressures  relevant  to  D11  were  considered  addressed.  In  2022,  France 
enhances its approach to develop the knowledge base on impulsive noise from industrial 
operations. Continuous noise from shipping activities and any other anthropogenic input 
such as heat or light sources remain gaps.  

165 

 
 
 
-  As  for  the  environmental  targets,  in  2016  the  assessment  found  that  the  measures 
addressed  the  D11  GES  definition  and  the  targets  as  they  contributed  to  addressing 
impulsive and continuous sound issues.  

-  In  2022,  both  impulsive  and  continuous  noise  continue  to  be  addressed  although  to 

different degrees and not all relevant activities are covered. 

The  adequacy  of  France’s  programme  of  measures  to  address 
biodiversity issues is considered good.  

D1 — Biodiversity 

Adequacy 

Strengths 

The adequacy of France’s programme of measures for D1 is considered very good 

-  A good range of species are addressed in the gap analysis.  
-  Additional gaps relating to public awareness, education and monitoring of species and 

habitats are also identified.   

-  All  relevant  pressures  are  addressed  by  the  updated  and  additional  MSFD  specific 
measures in the second cycle, with measures addressing gaps identified in the gap 
analysis. 

-  The modified and additional MSFD specific measures in the second cycle contribute to 

meet the operational environmental targets.  

-  A completely new set of targets has been developed for the current programme of 

measures. 

-  All additional or updated measures are linked to targets qualitatively. 
-  Details of how the measures will be implanted are extensively reported. France has 
explained when, how and where the modified and new measures will be implemented; 
potential funding sources are identified. 

-  France only partially reports on where the actions will be carried out, with only broad-

Weaknesses 

scale indications of the areas covered by measures being provided. 

Progress since 2016 

-  The new MPA measures are only partially adequate in addressing identified pressures.  
-  Progress has been made since 2016. 
-  In 2016, France was considered to fully address pressures. The modified and additional 
MSFD specific measures in the second cycle are also considered to address all relevant 
pressures. 

-  In the previous assessment, France was considered as fully addressing the coverage 
of GES and targets. The modified and additional MSFD specific measures in the second 
cycle  are  also  considered  to  be  linked  to  a  completely  new  range  of  habitat  and 
species-specific environmental targets. 

D2 — Non-indigenous species 

Adequacy 

The adequacy of France’s programme of measures for D2 is considered moderate 

-  A range of new cross-cutting measures have been identified which have the potential 

to indirectly address the input and spread of NIS. 

Strengths 

-  An additional MSFD-specific measure implemented in each French region will directly 

Weaknesses 

and indirectly address the input and spread of NIS 

-  Details are provided on where, when and how the measures will be implemented.  
-  The gap analysis could have provided more detail on where the current measures were 
not  adequate  and  what  new  measures  needed  to  address,  for  example,  NIS 
introductory pathways. 

-  The link between the additional MSFD specific measure and the operational targets for 

D2 is not clear as the measure is linked only to 1 of the 4 targets.  

166 

 
 
 
 
 
 
Progress since 2016 

-  Since the last reporting period, it has been acknowledged by France that the measures 

from the first cycle have not been successful in achieving GES for D2.  

-  It was assessed in 2016 that the pressures for D2 were addressed by the measures. 
In  the  second  cycle,  the  range  of  modified  and  additional  MSFD  specific  measures 
predominately directly and indirectly address the input and spread of NIS but some 
clarifications are needed.  

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of France’s programme of measures for D3 is considered good 

Strengths 

-  A gap analysis has been carried out, and where measures were considered insufficient 
to meet targets, additional measures have been identified; it is considered likely that 
the key gaps have been addressed. 

-  France has identified a number of modified and additional MSFD specific measures 

which are considered to address all relevant pressures. 

-  All the modified and additional MSFD specific measures are linked to environmental 

targets. 

-  France has revised all of its environmental targets and the new environmental targets 
appear to be broadly operational as they focus on reducing pressures with the aim of 
moving towards GES. 

-  France explains where and when the modified and additional MSFD specific measures 

will be implemented. 

-  France partially identifies all significant gaps to achieve the targets and ultimately GES. 
-  The documentation does not provide a clear overview of current status and failings for 

Weaknesses 

GES, nor of baseline scenarios for the gap analysis.   

Progress since 2016 

D4 — Foodwebs 

Adequacy 

-  Potential funding sources are only mentioned for the implementation.  
-  A timeframe for achieving GES in the future is not provided.  
-  In  2016,  the  assessment  concluded  that  France  had  addressed  the  key  pressures. 
France was also considered to address all components of GES and targets for D3. 
-  In  2022,  pressures  are  also  assessed  as  being  fully  covered.  The  modified  and 

additional MSFD specific measures provide good coverage of the targets. 

The adequacy of France’s programme of measures for D4 is considered good 

-  All  relevant  pressures  are  addressed  by  the  modified  and  additional  MSFD  specific 

measures in the second cycle. 

-  The modified and additional MSFD specific measures in the second cycle contribute to 

meeting the operational environmental targets for D4.  

Strengths 

-  A  complete  new  set  of  targets  relating  to  biodiversity  has  been  developed  for  the 

current programme of measures. 

-  France has clearly explained when, how and where the modified and additional MSFD 

specific measures for biodiversity will be implemented. 

-  Details on the implementation of the measures are provided. 
-  No separate gap analysis has been carried out for descriptor 4 and all three biodiversity 
descriptors (D1, D4 and D6) are covered by common text reporting due to extensive 
overlap.  

-  The analysis has only partially identified significant gaps to achieving the targets. 
-  Most measures reported under descriptor 4 are considered indirect. 
-  France was considered to fully address pressures in 2016. In the current report there is 
a single additional MSFD specific measure which only addresses one aspect of the 
pressures and so it is considered that only partial progress has been made. 

Weaknesses 

Progress since 2016 

167 

 
 
 
D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  In 2016, France was considered as fully addressing the coverage of GES and targets. 
In  the  current  report  there  is  a  single  additional  MSFD  specific  measure  aimed  at 
conservation of forage fish stocks. Though relevant for D4, it only addresses one aspect 
and so it is considered that only partial progress has been made. 

The adequacy of France’s programme of measures for D6 is considered good 

-  A  complete  new  set  of  targets  has  been  developed  for  the  current  programme  of 

measures. 

-  Additional  and  updated  new  measures  are  reported  as  directly  addressing  gaps 
identified in the gap analysis, they are linked to targets and will address the relevant 
pressures. 

-  Several direct measures are proposed in the programme of measures and additional 
measures have been identified addressing pressures indirectly, focussing on education 
and community awareness. 

-  the modified and additional MSFD specific measures in the second cycle contribute to 

meeting the operational environmental target. 

-  France has explained when, how and where the modified and new measures will be 
implemented. Details of how the measures will be implanted is extensively reported in 
the reporting.   

-  Potential funding sources are identified for most of the measures 
-  No separate gap analysis has been carried out for D6-seabed and all three biodiversity 
descriptors (D1, D4 and D6) are covered by common text reporting due to extensive 
overlap. 

-  France only partially reports on where the actions will be carried out, with only broad-

scale indications of the areas covered by measures being provided. 

-  The content and scale of the measures themselves do not seem enough to achieve 
GES. Indeed, the focus of the measures on the whole is too restricted, targeting specific 
species or only small-scale fishing. 

-  There are few measures from France which aim to reduce the scale of bottom fishing 
in  national  waters and addressing  the  damage  caused by  the  construction  of  wind 
farms. 

-  Progress has been made by France.  
-  France was considered to address pressures only partially in 2016. It is considered that 

pressures are better addressed in the current report. 

-  Regarding  coverage  of  GES  and  targets,  the  previous  assessment  considered  that 
seabed habitats were adequately addressed. Modified and additional MSFD-specific 
measures are linked to appropriate environmental targets in the current report. 

D7 — Hydrographical changes 

Adequacy 

The adequacy of France’s programme of measures for D7 is considered moderate 

-  France takes specific measures for the different marine regions. 
-  A  qualitative  appraisal  of  the  contribution  of  first  cycle  measures  towards  GES  is 

provided for the Greater North Sea. 

Strengths 

-  The  additional  MSFD-specific  measures  relevant  for  D7  adequately  address  the 

pressures.  

-  France has adequately explained where, how and when the additional MSFD specific 

measures will be implemented. 

Weaknesses 

-  There  is  a  lack  of  knowledge  of  the  current  status  against  GES  for  D7  and  the 

environmental targets are not operational. 

168 

 
 
 
-  The lack of clear scenarios for future activities, expected in the next cycle (including 
large-scale  development  of  offshore  windfarms),  weakens  the  gap  analysis  and 
hampers the identification and the design of adequate measures.  

-  The measures are general or cross-cutting to all descriptors, thus it is not explained 

how they are relevant to D7. 

-  Some  pressures  are  not  covered  such,  as  large-scale  development  of  offshore 

windfarms and fishing gear towed on the bottom that affects turbidity. 

-  The  additional  MSFD  specific  measures  only  partially  contribute  to  meeting  the 

operational environmental targets. 

-   The programme of measure is not clear on securing the funding to implement the 

measures as only potential funding sources are reported.  

-  No progress has been identified since 2016. Coverage of pressures is only partially 

addressed in 2022. 

Progress since 2016 

-  As in 2016, it is not clear how agriculture and industrial activities are covered in the 
Mediterranean region. Targets to reduce impacts or turbidity and to reduce impacts on 
turbidity and currents remain unaddressed. 

Based  on  the  information  reported  in  their  programmes  of  measures,  France’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘high’.  

Key  Factor  1:  Socio-
economic impacts of new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

France carried out an impact 
analysis  of  new  measures 
them, 
to  adopting 
prior 
Cost-Benefit 
including 
a 
Analysis 
(CBA)  and  Cost-
Effectiveness  Analysis  (CEA), 
which were  used  to  prioritise 
measures.  

assessment 

Social 
of 
measures covered impacts on 
employment and activities. 

provides 
France 
information  on 
funding 
sources  for  each  measure, 
including  national,  regional 
and 
local  funds,  public 
establishment  funds  (e.g. 
Water  Agency,  Agency  for 
the 
and 
Environment 
Energy  Management),  and 
EU funds (e.g. EMFAF, LIFE 
Programme). No additional 
information  provided  on 
the  funding  amounts  by 
each source. 

for 

The links between MSFD and 
WFD,  CFP  and  BHD  were 
every 
presented 
measure.  Measures  under 
the relevant directives were 
into  account  and 
taken 
existing 
considered 
Authorities 
measures. 
responsible 
for 
implementing  measures 
were listed.  

as 

reported 

France 
on 
mechanisms for regional (i.e. 
UNEP-MAP) 
OSPAR, 
coordination. It also reported 
with 
cooperating 
neighbouring  countries 
in 
the 
the  development  of 
second 
of 
programme 
measures and the outcomes 
of cooperation.   

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  nine 
Descriptors (D2, D3, D4, D5, 
D7, D8, D9, D10, D11) have 
sufficient 
information  on 
spatial coverage. Measures 
for  two  descriptors  have 
partial information.  

have 

How:  Measures  for  four 
Descriptors  (D1,  D4,  D9, 
sufficient 
D11) 
information 
on 
operationalisation. 
Measures 
seven 
for 
Descriptors (D2, D3, D5, D6, 
D7,  D8,  D10)  have  partial 
information.  For  example, 
details on modes of action 
for  two  D2  measures  are 
missing.    

When: Measures for all 11 
Descriptors  have  sufficient 
information 
the 
on 
temporal coverage. 

169 

 
 
 
 
 
6.8  Ireland 

Summary: 

Overall, the second programme of measures presented by Ireland is considered as adequate to address the pressures 
acting on the Irish marine environment and contributes to achieving Ireland’s GES and targets.  

All required information has been included: overview of environmental objectives, update of existing measures from the 
first  cycle  and  gap  analysis,  identification  and  selection  of  new  additional  measures  for  the  second  cycle.  Ireland  has 
identified new spatial protection measures, including marine protected areas with a section entirely devoted to these two 
new spatial protection measures. It provides further details on MPA development which is meant to be participatory and 
ecosystem-based. Climate change considerations were included, for the first time, in the updated programme of measures 
of Ireland. 

Measures for several pollution descriptors, as well as NIS and hydrographical conditions, have been assessed as “good” as 
Ireland has reported having acheived GES for these descriptors and therefore needs to have in place only measures to 
maintain GES. The rest of the measures have been assessed as “moderate” as Ireland only partially addressed the identified 
gaps to achieve targets and ultimately GES with its new MSFD-specific measures. No economic analysis was carried out 
to support the selection of measures. Some information that would have allowed for better understanding the programme 
of measures is missing; specifically, regarding outcomes of methodologies and coordination between policies. 

Based on the information reported in their programmes of measures, Ireland’s commitment to the implementation of their 
second programmes of measures has been assessed as ‘medium-high’. 

The  adequacy  of  Ireland’s  programme  of  measures  for  cross-cutting  issues  is 
considered moderate. 

Ireland  respected  the  MSFD  reporting  guidelines  for  information  to  be  reported.  However,  some 
information  that  would  have  allowed  for  better  understanding  is  still  missing,  specifically 
regarding outcomes of methodologies, coordination between legislations/policies and climate change 
considerations. Additional information could have allowed a better understanding of the programme 
of measures, and, eventually, a higher assessment score. 

Topic 

Strengths 

Weaknesses 

Socio-economic 
assessment 

The  measure  selection  involved  identifying 
gaps in achieving GES and putting in place 
measures to fill those gaps.  

The  updated  programme  of  measures 
targeting  all 
includes  153  measures 
descriptors.  

Ireland  does  not  explicitly  state  having 
conducted  an  economic  analysis  and  no 
justification is provided on the absence of 
this analysis.  

(CBA)  was 
A  Cost  Benefits  Analysis 
undertaken  for  only  one  MSFD  specific 
measure, while no economic analysis (CBA 
and/or CEA) was carried out for the rest of 
measures. 

Concerning  social  issues,  Ireland  does  not 
present  any  indication  of  social  issues 
considered;  no  social  assessment  was 
carried out to support the development of 
the programme of measures. 

170 

 
 
 
 
 
 
 
Ireland does not provide information on the 
outcomes  of  such  process,  notably  on  (a) 
the potential impact of measures on GHG 
emissions (b) the adaptive and adaptability 
capacities of the measures, and (c) whether 
the  proposed  measures  contribute 
to 
preserving  ecosystem  services  and  socio-
economic activities.  

Ireland  does  not  provide  additional 
information  explaining  mechanisms  of 
coordination 
different 
between 
Directives  and  on  outcomes  of  such 
coordination.  

the 

information  was  provided  on  the 

No 
amounts mobilised from each fund.  

change 

considerations  were 
Climate 
included,  for  the  first  time,  in  the  updated 
programme of measures.  

Both cycles took into consideration measures 
from  various  EU 
legislation/policies  as 
existing measures to reach GES.  

Ireland’s  updated  programme  of  measures 
was  developed  based  on  existing  policy 
frameworks  and  measures  arising  from 
these frameworks.  

Ireland  provided  a  list  of  the  different 
financing 
the 
sources  mobilised 
the  programme  of 
implementation  of 
measures.   

for 

Regional  cooperation  was  carried  out 
through OSPAR.  

No information is provided on assessing the 
transboundary impacts of measures. 

agreed 

Measures 
regional 
agreements  were  included  in  the  updated 
programme of measures.  

upon 

in 

and 

discussed 

Ireland 
exchanged 
information  on  overlapping  measures  with 
neighbouring  countries  and  this  regional 
cooperation  had  an  impact  on  measure 
selection. 

The  consultation  of 
the  neighbouring 
countries on transboundary impacts is not 
made  explicit 
the  programme  of 
measures. 

in 

first 

cycle 

The 
provided  more 
comprehensive  information  on  regional 
cooperation,  including  coordination  at  the 
EU  level,  as  well  as  bilateral  cooperation 
and  collaboration  with  NGOs  for  the 
development  of 
the  programme  of 
measures.  

Ireland provided information on the different 
competent  and  responsible  authorities  in 
charge of implementing and coordinating the 
programme of measures.  

is  not  clear 

It 
text  how 
from 
stakeholders' views influenced the final list 
of measures.   

the 

The level of information is not sufficient to 
understand  the  implementation  process 
and the monitoring and follow-up actions in 
regard to measures.  

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public consultation 
and administrative 
process 

The adequacy of Ireland’s programme of measures to address 
pollution issues is considered good.  

D5- Eutrophication 

171 

 
 
 
 
 
 
 
 
 
Adequacy 

The adequacy of Ireland’s programme of measures for D5 is considered good. 

-  A gap analysis has been undertaken.  
-  The programme of measures clearly makes a link with the WFD reporting.  
-  Ireland  has  identified  a  number  of  updated  measures  from  other  initiatives,  including 

OSPAR.  

-  Ireland indicates that GES is being achieved for D5, although it is noted that some transition 

and near coastal waters remain at risk of eutrophication.  

-  The  pressures  deriving  from  agriculture,  forestry,  urban  and  industrial  discharges  are 

adequately addressed by existing measures mainly.  

-  Some of the requirements of the gap analysis are missing, such as baseline scenarios and 

a clear assessment of progress against targets. 
-  There is no reference to the Zero Pollution targets. 
-  Not enough explanations are provided on the modifications made to the existing measures 

to understand how they will contribute to maintaining GES for D5. 

-  As in 2016, the 2022 assessment considers that the pressures and ultimately GES are 

addressed by the updated existing measures.  

The adequacy of Ireland’s programme of measures for D8 is considered good. 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

-  A gap analysis has been undertaken.  
-  Ireland  provides  information  on  the  current  state  of  the  descriptor  (at  least  for 
concentrations in water and some biota) and indicates that GES is being achieved for D8338.  
-  Ireland has identified a number of updated and new existing measures, many of them are 

linked to WFD.  

-  The pressures are addressed by existing measures mainly.  
-  Some of the requirements of the gap analysis are missing, such as baseline, alternative 

scenarios and a clear assessment of progress against targets. 

-  No further detail on specific actions relevant to D8 is provided regarding the implementation 

of the OSPAR Environmental Strategy measure.  
-  There is no reference to the Zero Pollution targets. 
-  Not enough explanations are provided on the modifications made to the existing measures 

to understand how they will contribute to maintaining GES for D8. 

-  As in 2016, the 2022 assessment considers that the pressures and ultimately GES are 

addressed by the updated existing measures.  

Weaknesses 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Ireland’s programme of measures for D9 is considered good. 

Strengths 

-  Ireland has identified a number of updated and new measures from other initiatives. 
-  A gap analysis has been undertaken.  
-  Ireland provides information on the current state of the descriptor and indicates that GES is 

being achieved for D9.  

-  The  pressures  are  addressed  by  existing  measures  mainly  which  consist  of  several 
measures that are the same as for D8 as well as some D9 specific measures, e.g. measures 
implementing the Foodstuffs Regulation 1881/2006 and Council Directive 2006/88/EC and 
associated Regulations.  

338 Although it should be noted that the Article 12 assessments noted limitations in Ireland's assessment of progress 
towards GES 

172 

 
 
 
 
 
Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  Some of the requirements of the gap analysis are missing, such as the consideration of 
climate change, baseline, alternative scenarios and a clear assessment of progress against 
targets.   

-  No  analysis  of  the  individual  contribution  of  the  measures  towards  achieving  GES  is 

provided.  

-  Only  one  additional  MSFD  specific  measure  has  been  reported  but  it  is  a  cross-cutting 
measure related to OSPAR’s Strategy with no details provided on specific actions relevant 
to D9. 

-  Similarly, to 2016, the assessment in 2022 considers that the pressures and ultimately 

GES are addressed by the updated existing measures.  

The adequacy of Ireland’s programme of measures for D10 is considered moderate 

-  Ireland updates and includes clear links to other policy instruments in the programme of 
measures (implementation of the MSP Directive and/or OSPAR Regional Action plan; EU 
Single Use Plastic Directive and Microbeads Prohibition Act). 

-  A gap analysis has been undertaken. 
-  Some of the requirements of the gap analysis are missing, such as baseline, alternative 

scenarios and a clear assessment of progress against targets.  

-  There  is  only  one  new  MSFD-specific  measure  relevant  for  D10  which  refers  to  the 

implementation of the OSPAR NEAES 2030 and is a cross-cutting measure. 

-  Ireland does not report any details on how it will implement this measure in relation to the 

targets for D10, and also does not include a clear timeline. 

-  It is thus not clear how Ireland aims to achieve/maintain GES for macrolitter on beaches, 
nor which actions it foresees to achieve GES for the other elements and criteria of D10. 
-  It is noted that while Ireland has indeed reported a decline in the number of beach litter 
items over the period 2013-2018, the numbers are still higher than the EU Beach litter 
threshold of 20 litter items/100m coastline. 

-  The adequacy of Ireland's report for D10 in the second programme of measures remains 

similar to the previous assessment.  

-  Regarding pressures, in 2016, the assessment stated that the measures reported by Ireland 
addressed the pressures. The second programme of measure is less clear on the actual 
pressures  covered,  especially  since  there  is  only  one  additional  MSFD  specific  measure 
relevant for D10. 

-  As in 2016, the impacts on biota (secondary criteria for D10) are not covered in Ireland's 

D11 — Underwater noise and energy 

second programme of measures.  

Adequacy 

-  The adequacy of Ireland’s programme of measures for D11 is considered moderate 

Strengths 

-  The pressures are addressed by existing measures mainly.  
-  Ireland  has  adequately  updated the  existing  measures  to  ensure  coherence  with  recent 

policy developments.  

-  A gap analysis has been undertaken. 
-  Ireland states that GES has been achieved for anthropogenic impulsive sound element. 
-  Ireland makes specific reference the work of TG Noise to establish spatial and temporal 
thresholds for C1 and C2 of descriptor 11 relating to the spatial and temporal extent as 
well as the sound pressure levels required to define Good Environmental Status. 

-  The most significant pressures and activities causing impulsive noise, including hydrocarbon 
exploitation, marine research and surveys are presented and addressed in the programme 
of measures. 

173 

 
 
 
Weaknesses 

Progress since 2016 

-  Some of the requirements of the gap analysis are missing, such as baseline, alternative 

scenarios and a clear assessment of progress against targets. 

-  Continuous  underwater  noise-causing  activities  were  not  assessed  due  to  the  lack  of 

developed data and methodologies.  

-  One measure addressing noise from shipping sources has been withdrawn without a clear 

justification.   

-  The implementation plans for proposed/modified measures are not provided.  
-  The programme of measures lacks specific measures to tackle continuous noise and inputs 

from other anthropogenic sources such as heat and light. 

-  The adequacy of Ireland's report on D11 in the second programme of measures slightly 
deteriorated  compared  to  the  previous  assessment  as  no  progress  was  made  in  the 
identification of gaps regarding continuous noise. The measures reported by Ireland address 
the  pressures  and  related  activities  for  impulsive  underwater  noise.  However,  with  one 
measure addressing shipping withdrawn, the programme lacks specific measures to tackle 
continuous noise as well as anthropogenic sources such as heat and light. 

-  In 2016, the assessment considered that the pressures and ultimately GES were addressed 
by the updated existing measures. In 2022 this remains true for impulsive noise but not for 
continuous noise. 

The adequacy of Ireland’s programme of measures to address 
biodiversity issues is considered moderate.  

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Ireland’s programme of measures for D1 is considered moderate 

-  Ireland has prolonged 15 measures related to D1 from its first cycle PoM. 
-  Ireland has fully explained where and when the three MFSD-specific measures relevant 
for D1 will be implemented. Timescales for each are provided either explicitly, or through 
linkage to the timetable for the OSPAR NEA Environment Strategy 2030. 

-  Adequate justification has been provided for the withdrawal of measures from the first 

cycle. 

-  Ireland has only partially identified gaps to achieve MSFD targets, and ultimately GES.  
-  Relevant pressures are only partially addressed by the MSFD-specific measures and it is 
not  clear  whether  measures  from  the  first  cycle  are  sufficient  to  address  current 
pressures, such as fisheries.  

-  The two measures that specifically refer to the establishment of MPAs and the reporting 
of  MPA  data  and  management  updates  to  OSPAR  are  not  sufficient  in  addressing 
identified pressures. 

-  Ireland does not explain how each measure in the OSPAR implementation plan will be 

delivered.    

-  It seems that Ireland made a step back since the 2016 report. Elements relating to the 
gap analysis, pressures addressed, the linkages to operational targets, and designation 
of MPAs are only partially addressed in the current programme of measures. 

-  Regarding the coverage of pressures, Ireland was assessed as fully addressing pressures 
in 2016.  However, the assessment of the current programme of measures does not 
match this conclusion. 

D2 — Non-indigenous species 

174 

 
 
 
 
 
Adequacy 

The adequacy of Ireland’s programme of measures for D2 is considered good. 

Strengths 

-  The  modified  and  additional  measures  from  other  initiatives  have  the  potential  to 
contribute to achieving and maintaining GES, especially since Ireland has reported that 
GES is achieved for D2. 

-  The modified measure on recreational vessels is considered to be addressing a pathway 

of introduction. 

Weaknesses 

-  Partial information was provided in the gap analysis relating to the identification of the 
pressures that lead to NIS introduction in Irish waters, and no baseline or threshold levels 
have been established to compare progress from the first cycle measures. 
-  No modified or additional MSFD specific measures were reported by Ireland. 
-  In both 2016 and 2022, Ireland considered that GES had been achieved339.  
-  The new and modified measures from other initiatives reported in 2016 and 2022 are 
considered to address GES by addressing key introduction pathways, but there remain 
some unclarity as to which pressures may have led to the introduction of NIS in Irish 
waters.  
D3 — Commercial fish and shellfish 

Progress since 2016 

Adequacy 

The adequacy of Ireland’s programme of measures for D3 is considered moderate 

-  Ireland has explained how the updates/changes to the existing measures from the first 
cycle contribute to achieving GES. The updates include consolidation of measures and 
reflect the latest relevant legislative developments and progress in implementation. 

-  A gap analysis has been undertaken and is described.  
-  Ireland  has  reported  a  large  number  of  measures  for  D3  overall,  most  of  these  are 
reported  as  measures  coming  from  other  initiatives,  adopted  under  EU  legislation, 
Regional Sea Conventions, other international agreements of national legislation. 

-  The programme of measures covers inshore stocks. 
-  It is considered that Ireland only partially identifies gaps to achieve the MSFD targets 
and ultimately GES. It is therefore unclear to what extent measures taken under other 
frameworks are sufficient or whether additional measures are needed. 

-  Some of the requirements of the gap analysis are missing, such as baseline scenarios 

and a clear assessment of progress against targets.  

-  Ireland has reported three additional MSFD specific measures against D3 in 2022 but 
they  are  considered  to  be  generic/cross-cutting  measures  and  are  not  specifically 
focused on achieving GES for D3.  

-  It  is  not  clear  if  recreational  fishing  is  adequately  addressed  by  the  programme  of 

measures. 

-  The adequacy of Ireland's report for D3 in the second cycle remained similar to the 2016 
assessment.  In  2016,  Ireland's  programme  of  measures  was  considered  to  partially 
address relevant pressures and to address GES and targets.  

-  In 2022, no additional MSFD specific and measures were reported that were specific to 
D3. Some first-cycle measures from other measures are reported that would address 
locally/nationally managed stocks so this is likely to be adequately addressed; however, 
it is not clear whether recreational fishing is adequately addressed by the programme of 
measures.  

The adequacy of Ireland’s programme of measures for D4 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

339 Although it should be noted that there are some limitations in the GES determination of D2C1 (introduction of NIS). 

175 

 
 
 
 
 
Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  There are six measures described as modified since 2015 that relate to D4-food webs 
-  Ireland has fully explained where and when the modified and additional MSFD specific 

measures relevant for D4 will be implemented. 

-  Timescales  for  each  measure are  provided  either  explicitly,  or  through  linkage  to  the 

timetable for the OSPAR NEA Environment Strategy 2030. 

-  Ireland has only partially identified gaps to achieve targets, and ultimately GES. 
-  Relevant pressures on food webs, in particular commercial and non-commercial fishing, 
are only partially addressed by the modified and additional MSFD specific measures, 
which are broad in scope.  

-  The two measures that specifically refer to the establishment of MPAs and the reporting 
of  MPA  data  and  management  updates  to  OSPAR  are  not  sufficient  in  addressing 
identified pressures for D4. 

-  No progress has been made since the 2016 report.  
-  Regarding the coverage of pressures, Ireland was assessed as fully addressing pressures 
in 2016.  However, the assessment of the current programme of measures does not 
match this conclusion as the additional and updated new measures do not fully address 
all pressures identified by the gap analysis performed in 2021.  

-  Regarding the coverage of GES and targets, in 2016 Ireland’s programme of measures 
was  assessed  as  addressing  general  GES  components.  In  the  current  programme  of 
measures, the targets are not considered operational. 

The adequacy of Ireland’s programme of measures for D6 is considered moderate 

-  Adequate justification has been provided for the withdrawal of measures from the first 

cycle. 

-  Ireland has fully explained where and when the three modified and additional MSFD 
specific measures relevant for D6 will be implemented.  The measures are all strategic 
and so apply to all of Ireland’s marine regions. 

-  Timescales  for  each  measure are  provided  either  explicitly,  or  through  linkage  to  the 

timetable for the OSPAR NEA Environment Strategy 2030. 

-  The two measures that specifically refer to the establishment of MPAs and the reporting 
of MPA data and management updates to OSPAR are addressing identified pressures 
for D6 but are necessarily limited in scope. 

-  Ireland  has  only  partially  identified all  significant  gaps  to  achieve  MSFD  targets,  and 

ultimately GES.  

-  Relevant pressures are only partially addressed by the modified and additional MSFD 

specific measures. 

-  The modified and additional MSFD specific measures are not linked to targets that can 

be considered operational. 

-  Ireland has only partially explained how the measures will be implemented. While modes 
of action for each measure are described in the text reporting, no indicators are reported 
for any. 

-  Progress has been made since 2016. 
-  Ireland was assessed as fully addressing pressures in 2016.  However, the assessment 
of the current programme of measure does not match this conclusion as the additional 
and updated MSFD specific measures do not fully address all pressures identified by the 
gap analysis performed in 2021.  

-  Regarding the coverage of GES and targets, in 2016 Ireland’s measures were considered 
as only partially ensuring sea-floor integrity, ecosystem functioning and the protection 

176 

 
 
of benthic ecosystems. Measures in the current programme of measure will help address 
this deficiency, though these are not linked to operational targets. 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Ireland’s programme of measures for D7 is considered good. 

Strengths 

Weaknesses 

Progress since 2016 

-  Ireland's programme of measures for the second MSFD cycle is very similar to its first 
cycle, which is consistent with Ireland's assessment that its marine waters are at GES 
for D7. 

-  The programme of measures is adequately linked to work at regional level in OSPAR. 
-  In  the  gap  analysis,  Ireland  identified  potential  issues  linked  to  its  plans  to  develop 
offshore  windfarms  and  considers  that  these  additional  pressures  can  be  addressed 
through the update of guidance on offshore wind energy 

-  The main changes are linked to updates of policy instruments. Ireland does not explain 

clearly how these changes can contribute to maintaining GES. 

-  No detail is provided on how the additional MSFD specific measure will be implemented 
and will contribute to maintaining GES for D7 in Ireland's waters, or to achieving the only 
environmental target for D7. 

-  In 2016, it was concluded that the measures adequately covered all pressures, GES and 

target definitions. In 2022, the assessment provides similar conclusions.  

Based  on  the  information  reported  in  their  programmes  of  measures,  Ireland’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘medium-high’.  

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

Ireland  has  undertaken  a 
Cost-Benefit  Analysis  for  one 
new measure only. 

is  no 

reference 

There 
to 
investigation of social impacts 
of measures. 

Ireland 
relies  mostly  on 
national  funds;  EMFAF  is 
planned 
co-fund 
to 
measure  to  support  the 
effective  delivery  of  CFP 
and  addressing  the  many 
impacts of the EU-UK Trade 
and 
Cooperation 
Agreement. 

No  information  is  provided 
on  the  amount  from  the 
European fund.  

Key 
3: 
Factor 
Coordination  with  EU 
policies  and 
regional 
coordination 

Links  between  the  MSFD 
and  other  key 
relevant 
policies  (WFD,  MSP,  CFP, 
and  HBD)  are  mentioned, 
and  relationships  between 
the  MSFD  descriptors  and 
other  policies  are  also 
Authorities 
outlined. 
for 
responsible 
implementing 
and 
coordinating  measures  are 
identified.  

Ireland has reported on the 
outcomes  of  coordination 
and 
cooperation  within 
OSPAR and how these have 
fed into the development of 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  three 
Descriptors (D1, D4, D6)340 
provide 
sufficient 
these 
information,  and 
measures  cover  the  whole 
of Ireland’s marine region.  

How:  Measures  for  three 
Descriptors (D1, D4 and D6) 
provide  partial  information 
on operationalisation.  

When:  Measures  for  three 
Descriptors  (D1,  D4,  D6) 
sufficient 
provide 
temporal 
information  on 
coverage.  

340 Ireland reported modified and additional MSFD specific measures only for the biodiversity-related Descriptors: D1, D4 
and D6.  

177 

 
 
 
 
 
 
 
the  second  programme  of 
measures.  

6.9  Italy 

Summary: 

Overall, the second programme of measures presented by Italy is considered to be not adequate to address the pressures 
acting on the Italian marine environment.  

Italy did not provide sufficient information in the different sections that would have allowed a proper assessment and/or 
better understanding of what has been done in the updated programme of measures. Because of this lack of information, 
it has proven very difficult to assess progress since 2016; in addition, because of the lack of a proper gap analysis, it is 
impossible to assess the potential of the few additional measures presented by Italy to support the achievement of GES. 
Out of all descriptors, only measures for non-indigenous species are considered to be moderately adequate, the rest has 
been assessed as either ‘poor’ or ‘very poor’. 

Based on the information reported in their programmes of measures, Italy’s commitment to the implementation of their 
second programme of measures has been assessed as ‘low’.  

The adequacy of Italy’s programme of measures for cross-cutting issues is 
considered very poor. 

Information is very partial and does not allow understanding of the methodology followed nor results 
and  outcomes.  Due  to  lack  of  information,  there  is  not  enough  information  and  data  allowing  to 
analyse progress since 2016.   

Topic 

Strengths 

Weaknesses 

An impact analysis of new measures prior to 
adopting  them,  including  a  Cost-Benefit 
(CBA)  and  Cost-Effectiveness 
Analysis 
Analysis (CEA) is undertaken.  

information 

is  provided  on 

No 
the 
methodologies followed for both analyses, 
nor  on  results  and  outcomes.  Whether 
economic  analysis  carried  out  helped  in 
decision-making,  notably 
for  selecting 
measures, is uncertain.   

Socio-economic 
assessment 

Interactions with 
climate change 

The programme of measures lacks element 
referring  to  the  social  impact  of  the 
measures. 

Climate  change  is  not  covered  in  the 
updated programme of measures. 

178 

 
 
 
 
 
 
 
 
 
 
Links  between  the  MSFD  and  other  EU 
legislations,  notably  WFD,  MSP,  CFP,  and 
BHD are mentioned.  

The  mechanisms  and  outcomes  of 
coordination between MSFD and other EU 
legislations are not presented.   

In its 3rd RBMP reporting under the WFD, the 
coordination between MSFD and WFD is less 
clearly reported: references to synergies and 
coordination are reported in only two of the 
RBMPs  examined  in  detail  and  in  rather 
general terms.    

The  programme  of  measures  does  not 
include  much  information  on  financing 
sources  mobilised  by  Italy,  except  the 
“recovery fund”, which is assumed to be the 
European Recovery and Resilience Fund. 

Italy  does  not  provide  any  additional 
information regarding European funds.   

The Mediterranean Action Plan (UNEP-MAP) 
is mentioned. 

Italy  does  not  provide any  information  on 
coordination with neighbouring countries. 

Italy provides information on the competent 
authorities in charge of the implementation 
of the programme of measures.  

Italy  does  not  provide any  information  on 
regional  cooperation  and  therefore  no 
information on the transboundary impacts 
of the proposed measures is provided.   

reference 

No 
is  made  to  the  public 
consultation,  how  Italy  took  into  account 
stockholders  views  and  the administrative 
process.  This  is  different  from  the  WFD 
RBMP  exercise  where  Italy  has  reported 
extensive public consultation exercises. 

The information provided was not enough 
to understand if the administrative process 
proposed  makes 
the  programme  of 
measure operational.   

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public consultation 
and administrative 
process 

The  adequacy  of  Italy’s  programme  of  measures  to  address 
pollution issues is considered very poor.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Italy’s programme of measures for D5 is considered poor. 

-  The additional MSFD specific measures identified by Italy in the programme of 
measure directly address pressures relevant to D5 (input of nutrients and organic 
substances).  It  is  consistent  with  the  assessment  of  Italy’s  RBMPs  which  all 
include measures to reduce nutrient pollution. 

-  Italy does not report any information regarding whether a gap analysis has been 
carried out and how this analysis might affect the selection of additional MSFD 
specific measures and modification of existing ones. 

-  No additional information is provided regarding how other pressures are being 

addressed and how Italy is acting to achieve GES. 

-  The two additional MSFD specific measures are linked to a partially operational 

target.  

179 

 
 
 
 
 
 
 
 
 
-  Italy  has  provided  only  partial  information  on  how,  when,  and  where  the 

measures will be implemented.  

-  The programme of measures does not refer to the Zero pollution Action plan. 
-  It  remains  unclear  whether  or  when  GES  might  be  achieved  for  D5.  The 
assessment  of  Italy’s  RBMPs  concludes  that  nutrient  pollution  from  diffuse 
agricultural  and  urban  wastewater  point  sources  are  the  main  reasons  for 
ecological  status  failure  for  all  water  bodies,  showing  that  it  remains  an 
important pressure that needs to be tackled. 

-  In 2016, it was considered that coverage of pressures had been addressed for 
all the activities. In 2022, the extent to which relevant pressures are addressed 
by the additional MSFD specific measures is not clear as the measures identified 
are lacking information. 

-  In 2016, it was considered that the measures addressed D5 GES and targets. 
However, in the 2022 assessment, it is considered that the measures address 
partially  D5  GES  and  environmental  targets  since  the  targets  linked  to  the 
additional MSFD specific measures are not wholly consistent and a target was 
considered only partially operational.  

The adequacy of Italy’s programme of measures for D8 is considered very poor. 

Progress since 2016 

D8-Contaminant 

Adequacy 

Strengths 

-  None identified. 

Weaknesses 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

-  No information is provided on: the updates/changes to the measures, the gap 

analysis, the current status of marine waters.  

-  No additional MSFD specific measures have been identified. 
-  The Italian programme of measures remains unclear on whether or when GES 

might be achieved for D8. 

-  In  2016,  it  was  considered  that  coverage  of  pressures  had  been  partially 
addressed.  As  no  modified  or  additional  MSFD  specific  measures  have  been 
identified in 2022, no proper assessment of progress can be made.  

-  The  2016  assessment  considered  that  the  programme  of  measures  partially 
addressed components of GES and targets. As no modified or additional MSFD 
specific  measures  have  been  identified  in  2022,  no  proper  assessment  of 
progress can be made. 

The adequacy of Italy’s programme of measures for D9 is considered poor. 

Strengths 

-  GES is reported as achieved under Article 8. 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

-  No information is provided on: the updates/changes to the measures, the gap 

analysis, the current status of marine waters.  

-  No additional MSFD specific measures have been identified. 
-  In 2016, it was considered that coverage of pressures had been addressed. As 
no modified or additional MSFD specific measures have been identified in 2022, 
no proper assessment of progress can be made.  

-  In 2016, it was considered that the assessment partially addressed components 
of GES and targets. As no modified or additional MSFD specific measures have 
been identified in 2022, no proper assessment of progress can be made. 

180 

 
 
 
Adequacy 

The adequacy of Italy’s programme of measures for D10 is considered poor. 

Strengths 

-  New measures from the second cycle are linked to operational targets. 
-  Italy has adequately explained where additional MSFD specific measures will be 

implemented. 

-  Italy does not report any information regarding whether a gap analysis has been 
carried out and how this analysis might affect the selection of additional MSFD 
specific measures and modification of existing ones.  

-  It is also not entirely clear whether the pressures addressed by the new measures 

are indeed the most relevant to marine litter in Italian waters.  

-  Italy  does  not  report  clear  or  extensive  measure  descriptions  for  the  new 

measures.  

-  Existing  measures  have  not  been  updated,  nor  have  any  measures  been 

withdrawn.  

-  As the status of the new measures is indicated as ‘implemented’, it is difficult to 
assess how Italy aims to further improve progress towards GES and how and 
over which timeline Italy aims to use this set of new measures.   

-  In 2016, Italy reported marine litter as a pressure, with shipping, tourism, fisheries 
and urban areas activities identified as contributing sources. In 2022, almost all 
new measures intent to tackle the pressure of marine litter input; however, it is 
not clear that the new set of new measures covers all relevant pressures.  

-  In 2016, the existing and new measures have been linked to two specifics targets. 
In 2022, Italy has not reported new targets in the programme of measures. 

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Italy’s programme of measures for D11 is considered very poor. 

Strengths 

-  None identified. 

Weaknesses 

Progress since 2016 

-  No information is provided on: the updates/changes to the measures, the gap 

analysis, the current status of marine waters. 

-  The Italian programme of measures remains unclear on whether or when GES 

might be achieved for D11. 

-  In 2016, it was considered that coverage of pressures had been addressed and it 
was considered that the measures partially addressed components of GES and 
targets because they did not address the impact of noise.  

-  As  no  modified  or  additional  MSFD  specific  measures  have  been  identified  in 

2022, no proper assessment of progress can be made. 

The  adequacy  of  Italy’s  programme  of  measures  to  address 
biodiversity issues is considered poor. 

D1 — Biodiversity 

Adequacy 

The adequacy of Italy’s programme of measures for D1 is considered very poor. 

Strengths 

-  Italy has partially explained where new measures will be implemented. 

181 

 
 
 
 
 
 
 
 
- No  information  regarding  the  gap  analysis  was  provided.  The  lack  of  gap  analysis 
prevents  us  from  knowing  which  pressures  should  be  addressed  by  the  updated 
programme of measures in order to achieve the environmental targets and ultimately 
GES. Therefore, there is no certain way to know how adequate the measures proposed 
are.  

- Not all the relevant pressures are addressed by the proposed updated and additional 

MSFD specific measures.  

- Other pressures might be covered by the existing measures from 2016 programme of 
measures that is still in place or by measures linked to pressure descriptors; however, 
since  Italy  has  not  provided  any  additional  information  regarding  these  links  this  is 
uncertain.  

- How the new measures will be implemented is unclear, because no description of the 
"modes of action" is reported, and the implementation mechanisms are incompletely 
reported.  

- Italy has poorly explained when new measures will be implemented: it is unclear how 

the new measures can be fully implemented in 2022. 

- The new MPA measure is identifying the subject of protection unclearly and detailed 

information on how to reach the targets set is missing. 

-  In 2016, the assessment considered that coverage of pressures was addressed except 
for water column habitats. However, in 2022, not all of the relevant pressures are 
addressed by the proposed modified and additional MSFD specific measures. 

-  In 2016, Italian targets were partially addressed for all biodiversity components of the 
assessment. In 2022, not all measures are linked to operational environmental targets.  

Weaknesses 

Progress since 2016 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Italy’s programme of measures for D2 is considered moderate. 

Strengths 

Weaknesses 

Progress since 2016 

- The new measures do address all relevant D2 pressures and their potential sources. 
- Italy has also partially linked new measures to operational targets.  
- Italy has adequately explained where the modified and additional MSFD measures will 

be implemented. 

- Italy does not report any information regarding whether a gap analysis has been carried 
out  and  how  this  analysis  might  affect  the  selection  of  additional  MSFD  specific 
measures and modification of existing ones. 

- The information provided on how and when these will be implemented is incomplete 

or even unclear. 

- In  2016,  the  measures  addressed  the  pressure  of  the  introduction  of  NIS  and  all 
relevant  activities  including  aquaculture  and  shipping.  Similarly,  in  2022,  the  new 
measures do address all relevant D2 pressures and their potential sources. 

- In 2016, the measures addressed the GES and targets. In 2022, Italy has partially linked 

new measures to operational targets, but not all. 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Italy’s programme of measures for D3 is considered poor. 

Strengths 

- Italy  provides  details  on  how,  where,  and  when  the  two  additional  MSFD  specific 

measures will be implemented. 

- The new measures, in combination with the existing measures, broadly address most 
aspects  of  pressures  for  D3  (fishing  pressure),  through  CFP  regulations,  as  well  as 
measures  specifically  linked  to  local  management  plans  (for  non-CFP  stocks)  and 
recreational fishing.  

182 

 
 
 
 
 
- Italy does not provide information regarding the updates to existing measures from the 
first cycle, the current status of the environment regarding D3 and the gaps to achieve 
GES.  

- The reporting is brief and does not provide details on the gap analysis; it is therefore 

not possible to assess the adequacy of the updated programme of measures.  
- Italy does not provide any information on the extent to which GES is achieved.  
- The measures only partially addressed relevant pressures to D3, and they are not linked 

to environmental targets reported under D3.  

- Measures related to monitoring should not be reported as a measure.  
- The  measures  do  not  appear  to  specifically  address  age/size  distribution  of  stocks, 

despite Italy including D3C3 in their determination of GES under Article 8. 

- In 2016, it was concluded that Italy had addressed the key pressure (i.e extraction of 
species,  fish  and  shellfish)  for  D3.  In  2022,  coverage  of  pressures  by  modified  and 
additional MSFD specific measures is partial.  

-  In 2016, Italy was considered to partially address all components of GES and targets 

for D3. The coverage of GES and targets is also considered partial in 2022.  

- In 2016 it was considered that new measures were necessary to address the pressure 
from  recreational  fishing.  An  additional  MSFD  specific  measure  is  presented  in  the 
2022 programme of measures to address this.  

The adequacy of Italy’s programme of measures for D4 is considered poor. 

- Italy has well explained where new measures will be implemented.  
- The new MPA measure partially identifies the subject of protection, it aims to expand 
the  network  of  MPAs  and  enhances  existing  measures  in  MPAs;  however,  detailed 
information on how to reach the targets set is missing. 

- No  information  regarding  the  gap  analysis  was  provided.  The  lack  of  gap  analysis 
prevents to clarify which pressures should be addressed by the updated programme of 
measures to achieve the environmental targets and ultimately GES.  

- There is no certain way to know how adequate the measures proposed are. 
- The lack of gap analysis makes it unclear which pressures are to be addressed, and 
therefore it is unclear whether these measures adequately cover the relevant pressures. 

- How the new measures will be implemented remains unclear. 
- Italy has poorly explained when new measures will be implemented: it is unclear how 

the new measures can be fully implemented in 2022.  

- In 2016, pressures were considered covered. However, in 2022, not all the relevant 
pressures  are  addressed  by  the  proposed  updated  and  additional  MSFD  specific 
measures.  

- In 2016, the targets were partially addressed by the measures. In 2022, none of the 
new measures proposed in this programme of measures are linked to an operational 
environmental target. 

The adequacy of Italy’s programme of measures for D6 is considered poor. 

Weaknesses 

Progress since 2016 

D4 — Food webs 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

-  The  majority  of  new  measures  proposed  by  Italy  represented  actions  to  achieve 

operational environmental targets. 

-  Italy has partially explained where new measures will be implemented. 

183 

 
 
 
- No  information  regarding  the  gap  analysis  was  provided.  The  lack  of  gap  analysis 
prevents  to  clarify  which  pressures  should  be  addressed  by  the  programme  of 
measures to achieve the environmental targets and ultimately GES.  

- The lack of gap analysis prevents to know how adequate the measures proposed are. 
- The  relevant  pressures  are  not  addressed  by  the  proposed  updated  and  additional 

MSFD specific measures. 

- How the new measures will be implemented is unclear, because no description of the 
"modes of action" is provided and the reporting of the implementation mechanisms is 
incomplete.  

- Italy has poorly explained when new measures will be implemented: it is unclear how 

the new measures can be fully implemented in 2022.  

- The new MPA measure is missing information on how to reach the targets set. 
- The programme of measures lacks information regarding the conservation objectives 
and  none  of  the  pressures  reported  for  the  sea-floor  integrity  descriptor  are 
addressed.     

- In 2016, the measures partially addressed the relevant pressures for D6. In 2022, the 
relevant pressures are not addressed by the proposed updated and additional MSFD 
specific measures.  

- In  2016,  the  seabed  habitats  targets  were  partially  addressed  by  the  measures 
proposed  by Italy.  In  2022,  most  of  the  new  measures  proposed  by  Italy  represent 
actions to achieve operational environmental targets.  

Weaknesses 

Progress since 2016 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Italy’s programme of measures for D7 is considered poor. 

Strengths 

- GES is reported as achieved under Article 8. 

Weaknesses 

Progress since 2016 

- There is a lack of information on gap analysis and on the current status of marine 

waters. 

- Inconsistencies in reporting do not allow to understand if modified measures relate to 

D7.  

- The cumulative impacts do not appear to be covered, no modified nor additional MSFD 
specific measures have been defined for D7 by the Member State to address them. 
- The measures aim to increase knowledge and not address the pressures, so targets 

defined for D7 are not addressed by any modified measure. 

- As highlighted in the assessment of Italy’s RBMPs, Italy still needs to set type-specific 
reference  conditions  as  regards  hydro-morphological  quality  elements  for  coastal 
waters. 

- In 2016, the measures reported covered all possible pressures, since all projects which 
could adversely impact hydrological conditions are subject to the existing regulatory 
procedures. It should however be noted that cumulative impacts do not appear to be 
covered. In 2022, not update has been made to cover cumulative impacts.  

- In 2016, Italy did not provide detailed information on its existing measures for D7. In 

2022, no additional MSFD-specific measures have been defined for D7 by Italy. 

Based  on  the  information  reported  in  their  programmes  of  measures,  Italy’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘low’.  

184 

 
 
 
 
 
Key Factor 1: Socio-
economic impacts of new 
measures 

Key Factor 2: Financing 
sources and use of EU 
funds 

An  impact  analysis  of  new 
measures  prior  to  adopting 
them, including a Cost-Benefit 
Analysis 
(CBA)  and  Cost-
Effectiveness Analysis (CEA) is 
undertaken. However, there is 
no  mention  of  how  results 
influenced measures selection 
or  prioritisation.  There  is  no 
reference to the investigation 
of social impacts of measures 

Very limited information on 
financing 
(i.e. 
sources 
from  national 
‘secured’ 
budget),  and  no  specific 
information on EU financing 
sources 
for  a 
except 
mention  of  mobilising  a 
‘recovery 
This 
recovery  fund  could  be 
related  to  the  European 
recovery fund however it is 
not clear from the text. 

fund’. 

Key Factor 3: 
Coordination with EU 
policies and regional 
coordination 

Italy  identified  relevant  EU 
legislation, notably the CFP, 
MSP, WFD and HBD that are 
linked to the measures.  

Italy  did  not 
However, 
information  on 
provide 
with 
coordination 
neighbouring 
countries, 
except for a mention of the 
UNEP-MAP.  

Key Factor 4: 
Implementing modified 
and additional MSFD 
measures: where, how 
and when 

on 

Where:  Measures  for  five 
Descriptors341  (D2,  D3,  D4, 
D5,  D10)  have  sufficient 
information 
spatial 
coverage. Measures for two 
Descriptors  (D1  and  D6) 
information, 
have  partial 
while  measures  for  D7  do 
not  have  clear  information 
on spatial coverage.  

How:  Measures  for  three 
Descriptors (D2, D4 and D5) 
have partial information on 
operationalisation. 
Measures 
five 
for 
Descriptors (D1, D4, D6, D7, 
D10)  do  not  have  clear 
on 
information 
operationalisation. 
For 
example,  financing  for  all 
measures  is  reported  as 
‘secured’  under  the  state 
national  budget  but  no 
further details are provided 

information 

When:  Measures  for  two 
Descriptors  (D3,  D5)  have 
partial 
on 
scope,  while 
temporal 
measures 
six 
Descriptors (D1, D2, D4, D6, 
D6, D10) do not have clear 
temporal 
information  on 
scope.   

for 

6.10 Latvia 

Summary: 

Overall, the second programme of measures presented by Latvia is considered as moderately adequate to address the 
pressures acting on the Latvian marine environment and partially contributes to achieving Latvia’s GES and targets.  

Latvia has undertaken a socio-economic assessment of the new measures adopted including a financial cost assessment 
and  has  undertaken  a  strategic  environmental  impact  assessment  including  transboundary  impacts  of  its  updated 

341 Italy did not report modified and additional MSFD specific measures for D8, D9 and D11.  

185 

 
 
 
programme of measure. For several descriptors, Latvia has identified all significant gaps towards the targets and ultimately 
GES. In general, Latvia provides detailed information on where, when, and how the new measures will be implemented. 
Measures for eutrophication, contaminants and non-indigenous species have been assessed as adequate to address the 
relevant pressures.  

However, the lack of new measures for underwater noise, hydrographical conditions, commercial fish and food webs has 
been  assessed  as  particularly  problematic.  In  several  instances,  Latvia  has  not  explained  how  measures  from  other 
frameworks contribute to achieving GES making it difficult to know whether new measures are needed.   

Based on the information reported in their programmes of measures, Latvia’s commitment to implement their second 
programme of measures has been assessed as ‘high’. 

The  adequacy  of  Latvia’s  programme  of  measures  for  cross-cutting  issues  is 
considered good. 

Overall, Latvia reported on all the items of information required, but some information provided is 
incomplete or not sufficient. The programme of measures demonstrates Latvia's understanding of 
how achieving objectives of the MSFD is also contingent on efforts in other policy areas (European 
Green Deal, the updated Baltic Sea Action Plan…). Compared to the fist cycle programme of measures, 
Latvia  undertook  a  comprehensive  cost-benefit  and  cost-effectiveness  analysis  on  the  additional 
MSFD specific measures.  

Topic 

Strengths 

Weaknesses 

a 

provides 

Latvia 
socio-economic 
assessment of the additional MSFD specific 
measures,  where  a  cost-benefit  and  cost-
effectiveness analyses as well as a financial 
cost assessment were performed. 

There is no evidence that social impacts of 
measures were considered in the selection 
and  development  of  individual  measures 
and  on  the  overall  second  programme  of 
measures. 

Socio-economic 
assessment 

Latvia  performed  a 
cost-effectiveness 
analysis  on  some  of  the  MSFD  specific 
measures  that  directly  address  pressures 
and 
the  most  cost-effective 
measures. 

identified 

Latvia  provides  qualitative  information  on 
the indirect financial costs of the measures 
that  will  be  incurred  by  marine/coastal 
sectors and users. 

Interactions with 
climate change 

Latvia mentioned different national, regional 
and European policies, strategies, plans and 
initiatives  related  to  climate  change  which 
are linked to marine environmental policy. 

There  is  no  clear  evidence  that  Latvia's 
second programme of measures has been 
developed  to  be  part  of  Latvia's  climate 
change adaptation strategy. 

Latvia reports measures linked with the WFD 
and  highlighted  which  measures  will  be 
delivered  under  the  country's  2022-2027 
River  Basin  Management  Plan.  They  also 
report measures related to spatial protection 

Latvia has  not  reported  on  any measures 
that  are  related  to  the  CFP  as  their  gap 
analysis has not concluded that measures 
related 
(commercial  fish  and 
shellfish) are required. 

to  D3 

186 

 
 
 
 
 
 
 
 
Links to other 
policies 

under  maritime  spatial  planning;  however, 
this  was  explicitly  linked  with  the  Habitats 
Directive. 

Latvia reported the national and EU financing 
sources that will support the implementation 
of the measures.  

Latvia  made  references  to  the  European 
Green  Deal,  the  Biodiversity  Strategy  2030 
and  the  Zero  Pollution  Action  Plan  and 
described how national and regional policies 
and governance link with these EU policies. 

Latvia has not reported on whether or not 
coordination between the MSFD and other 
EU legislation (e.g. WFD, CFP, HBD and MSP) 
has  evolved  since  the  first  programme  of 
measures. 

Where a measure is expected to be funded 
by a mix of sources, Latvia has not provided 
details  on  the  proportion  or  amounts  that 
come from the different sources. 

Latvia  presented  how  the  work  done  via 
HELCOM, the Baltic Sea Action Plan and at 
the  EU  level  are  expected  to  contribute  to 
achieving GES. 

Latvia  has  not  reported  any  changes  in 
mechanisms  of  coordination,  so  it  is  not 
clear 
this 
if  nothing  changed  or 
information was missed in the reporting. 

if 

Regional 
cooperation and 
transboundary 
impact 

They also presented how work at the EU and 
regional 
the 
level  has  contributed 
development of Latvia's second programme 
of measures.  

to 

Latvia undertakes a strategic environmental 
impact assessment including transboundary 
impacts. These impacts were used to further 
develop 
second  programme  of 
measures. 

the 

Latvia  held  a  public  consultation  for  its 
second  Programme  of  measures  and  the 
Environmental Report.  

Public consultation 
and administrative 
process 

For  each  measure,  Latvia  reported  the 
progress  and  timeline  of  implementation 
(e.g. implemented in 2022, to end in 2027), 
the 
responsible  authority  and  other 
institutions  involved  in  the  implementation, 
the  expected  result  from  implementing  the 
measures, 
assess 
effectiveness of the measure, the indicative 
cost  of  the  measure  and  the  source  of 
funding for the measure. 

indicator 

the 

to 

information 

is  provided 

No 
if  Latvia 
consulted with other Member States on the 
transboundary impacts of measures during 
the consultation, or through HELCOM. 

The  approach  to  public  consultation  of 
Latvia's second programme of measures is 
simpler compared to the one deployed for 
the  first.  The  consultation  of  the  latter 
involved several events such as meetings, 
discussions  and  seminars  with  different 
stakeholder  groups,  whereas  the  second 
programme  of  measures  was  put  out  for 
consultation online. 

Latvia has not reported on how results from 
the  public  consultation  were  taken  into 
and 
account 
finalisation  of  the  second  programme  of 
measures.  

development 

the 

in 

The  adequacy  of  Latvia’s  programme  of  measures  to  address 
pollution issues is considered moderate.  

D5- Eutrophication 

Adequacy 

The adequacy of Latvia’s programme of measures for D5 is considered good. 

187 

 
 
 
 
 
 
 
 
Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  Latvia has provided information on how updates to existing measures and additional 

measures from other initiatives contribute to achieving GES. 

-  The  programme  of  measures  references  most  of  the  relevant  measures  including 

reference to the EU Green Deal, WFD, and Zero Pollution targets. 

-  Latvia has undertaken a relatively detailed gap analysis taking account of the nitrogen 

and phosphorus reduction targets identified in the Baltic Sea Action Plan. 

-  The new measures are linked to the targets and the indicators that will be used to 

monitor implementation of the measures. 

-  Latvia  has  provided  all  necessary  information  on  where,  when,  and  how  the  new 

specific measures will be implemented. 

-  The gap analysis has not yet fully quantified the contribution of updated and new 
measures from other initiatives (particularly WFD measures) towards achieving GES.  
-  In 2016, the assessment considered that coverage of pressures had been addressed. 
In  2022,  the  coverage  of  relevant  pressures  is  addressed  as  the  new  measures 
address the relevant pressures, but it is unclear whether the measures will be sufficient 
to achieve GES due to current limitations in the gap analysis. 

-  In 2016, it was considered that the measures addressed the components of GES and 
targets. In 2022, the modified and new measures are considered to partially address 
GES and targets. 

The adequacy of Latvia’s programme of measures for D8 is considered good. 

-  Latvia has provided information on how modified and additional measures from other 

initiatives contribute to achieving GES.   

-  Latvia  has  undertaken  a  relatively  detailed  gap  analysis  taking  account  of  the 

contaminant reduction targets identified in the Baltic Sea Action Plan. 

-  The  programme  of  measures  links  the  new  measures  to  the  target  and  describes 

indicators that will be used to monitor implementation of the measure. 

-  Details  of  where, how,  and when  the  new  measures  will be  implemented are well 

presented.  

-  The programme of measures makes references to the EU Green Deal, WFD, and the 

Zero Pollution targets. 

-  The gap analysis has not yet fully quantified the contribution of new measures from 

other initiatives (particularly WFD measures) towards achieving GES. 

-  The measures will support reductions in inputs from key substances such as TBT, PBDE 
and  PFOS  although  these  reductions  and  their  contribution  in  terms  of  progress 
towards GES have not been quantified due to current limitations in the gap analysis. 
-  In 2016, the assessment considered that coverage of pressures had been addressed. 
In 2022, the assessment considers that coverage of relevant pressures was partially 
addressed,  as  the  new  measures  address  the  relevant  pressures,  but  it  is  unclear 
whether the measures will be sufficient to achieve GES due to current limitations in 
the gap analysis. 

-  In 2016, the assessment considered that the measures addressed the components of 
GES and targets. In 2022, the assessment considers that the modified and additional 
MSFD specific measures has not adequately addressed GES and targets. 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Latvia’s programme of measures for D9 is considered moderate. 

Strengths 

-  GES is reported as achieved under Article 8.  

188 

 
 
 
-  Some of the D8 additional measures from other initiatives and new MSFD measures 

will contribute towards achieving targets and maintaining GES for D9. 

-  Latvia has not provided any information on how the measures from other initiatives 

(including additional ones) contribute to maintaining GES. 

-  Latvia has not undertaken a gap analysis for D9 on the basis that GES is already being 
achieved.  The  programme  relies  on  the  analysis  done  for  D8.  However,  the  gap 
analysis should have taken account of potential future pressures and their influence 
in maintaining GES. 

-  In 2016, the assessment considered that coverage of pressures and GES and targets 
had been addressed. In the absence of new measures, in particular to ensure that GES 
is maintained, no assessment of progress can be made.  

The adequacy of Latvia’s programme of measures for D10 is considered moderate. 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

-  Reference is made to EU beach litter thresholds as well as Zero Pollution targets. 
-  The gap analysis is rather complete for D10. 
-  Latvia  has  provided  all  necessary  information  on  where,  when,  and  how  the  new 

Weaknesses 

Progress since 2016 

measures will be implemented. 

-  Latvia has reported two new measures from other initiatives in its second cycle but is 
not entirely clear how to which extent they will contribute to achieving GES for D10.  
-  The gap analysis is focused on macrolitter on beaches and no assessment is made 

for either (micro-)litter in the water column, or impact on marine species. 

-  Direct  measures  are  missing  in  Latvia's  programme  of  measures,  and  pressures 

related to litter input from shipping and tourism are not specifically addressed. 

-  The programme of measures is lacking measures specifically targeting litter on the 

seabed or in the water column, or litter ingested by animals. 

-  Broad  timelines  are  provided  for  all  new  measures,  but  it  remains  unclear  when 
implementation of some of these measures will start exactly or when GES is expected 
to be reached. 

-  The adequacy of Latvia's measures for D10 remains partial, as was the case in the 

2016 assessment. No progress has been made. 

-  In  2016,  the  assessment  considered  coverage  of  pressures  addressed.  The 
assessment of the second cycle concludes that measures partially cover the relevant 
pressures associated with D10. 

-  In 2016, Latvia had not defined GES for D10 and indicated that the D10 target would 
be addressed through the measures. In the 2022 assessment, the measures are only 
aimed at indirectly preventing further litter input. 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Latvia’s programme of measures for D11 is considered very poor 

Strengths 

-  None identified. 

Weaknesses 

Progress since 2016 

-  There is no mention of D11, impulsive noise or low frequency continuous noise in the 

programme of measures. 

-  Latvia  does  not  define  any  D11-specific  measure  in  its  second  programme  of 

measures. 

-  Latvia  has  withdrawn  some  of  the  research  and  monitoring  measures  reported  as 

relevant to D11 in 2016. 

-  The adequacy of Latvia's Art 13 report on D11 has deteriorated. No progress has been 

made.  

189 

 
 
 
-  In  2016,  the  assessment  considered  coverage  of  pressures  partially  addressed.  It 
appears that in the 2022 programme of measures, Latvia has withdrawn some of the 
relevant measures for D11. 

-  The coverage of GES and related targets is, similarly to the first cycle assessment, 

inadequate.  

The  adequacy  of  Latvia’s  programme  of  measures  to  address 
biodiversity issues is considered poor. 

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D2 — Non-indigenous species 

Adequacy 

Strengths 

The adequacy of Latvia’s programme of measures s for D1 is considered moderate 

-  Latvia has explained how the updates to the existing measures from the first cycle 

contribute to achieving GES. 

-  Implementation of the additional measures are well described. 
-  Three measures refer to the introduction of new spatial protection through MPAs. 
-  Where,  how  and  when  modified  and  additional  MSFD  specific  measures  will  be 

implemented is reported clearly. 

-  A clear financial source is provided for all MSFD specific measures.  
-  Latvia demonstrates plans to coordinate with other legislation in order to meet MSFD 

targets. 

-  The gap analysis is considered partially adequate, as not all biodiversity elements 

are included. 

-  Fish species and pelagic habits are not included in the gap analysis.  
-  Modified  and  new  measures  in  the  second  cycle  only  partially  address  relevant 
pressures as most of the measures are linked to a single pressure, disturbance of 
species.  

-  Several  measures  refer  only  to  the  gathering  of  knowledge  and  so  cannot  be 

considered as addressing pressures. 

-  None of the additional MSFD specific measures contribute to meeting operational 

targets. 

-  For  the  new  MPAs,  the  range  of  species  and  pressures  addressed  is  limited  and 

details of conservation objectives and measures are not provided. 

-  The  adequacy  of  Latvia’s  report  on  D1-biodiversity  in  the  second  programme  of 

measures shows only little progress since the 2016 assessment.  

The adequacy of Latvia’s programme of measures for D2 is considered very good 

-  Latvia has adequately identified all significant gaps to achieve the MSFD targets 

and ultimately GES. All relevant pressures are identified. 

-  The gap analysis provides an overview of the current status and expected changes 
in loads until 2027 (‘baseline scenario’) and quantifies the gap to achieve GES and 
as a consequence the need for specific measures to address a specific pressure. 

-  An overview of progress on the environmental target is provided.  
-  All relevant pathways have been identified in the gap analysis. 
-  An overview of how existing policy measures will reduce pressure during the ‘base-

case’ period is provided.  

190 

 
 
 
 
 
 
Weaknesses 

Progress since 2016 

-  Latvia explained where the modified and additional MSFD specific measures will be 
implemented - all the required schema fields are specified for all relevant measures 
and the implementation locations are considered adequate. 

-  Latvia  has  partially  explained  how  updates  to  existing  measures  contribute  to 

achieving GES. 

-  Latvia has not reported any first cycle measures as having been withdrawn, although 
there were five measures reported in the first cycle that have not been included in 
the reporting for the updated programme of measures. 

-  The adequacy score of Latvia's report on D2 in the second programme of measures 

has improved compared to the 2016 assessment.  

-  Regarding the coverage of pressures, Latvia was assessed as partially addressing 
pressures in the 2016 assessment. In the second programme of measures, Latvia 
has  made  good  progress  by  directly  addressing  previous  recommendations  on 
pressures. 

-  The 2016 assessment flagged some of the measures as more suitable for the MSFD 
Monitoring  Programmes  (Article  11)  rather  than  the  programme  of  measures.  It 
seems that Latvia has moved these across to monitoring although this is not clear 
in the reporting.  

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Latvia’s programme of measures for D3 is considered very poor 

Strengths 

-  None identified. 

-  Latvia has not included any measures related to D3 and it is not clear whether the 

2016 measures reported for D3 are still in place.  

-  Latvia refers to the achievement of GES through the implementation of the CFP but 
there  are  no  measures  reported  in  2016  or  2022  about  delivery  of  the  CFP  or 
national regulations. 

-  Updates to existing measures have not been clearly explained and their contribution 

to achieving GES is not presented.  

-  Latvia does not adequately identify all significant gaps to achieve the MSFD targets 

and GES. 

-  In 2016, the assessment concluded that Latvia had addressed the key pressures. In 
2022,  the  coverage  of  pressures  was  not  assessed  as  no  modified  or  additional 
MSFD  specific  measures  were  reported.  However,  as  measures  addressing  the 
pressure  were  not  reported  as  part  of  the  programme  of  measures  it  can  be 
considered  that  the  pressures  have  not  been  adequately  addressed  by  the 
programme of measures. 

-  In the 2016 assessment, Latvia was considered to address all components of GES 
and targets for D3. In 2022, the coverage of GES and targets was not assessed as 
there were no modified or additional MSFD specific measures reported for D3. In 
2022, no measures being reported for D3, the programme of measures cannot be 
considered to adequately address GES and targets. 

The adequacy of Latvia’s programme of measures for D4 is considered very poor. 

Weaknesses 

Progress since 2016 

D4 — Food webs 

Adequacy 

Strengths 

-  None identified. 

Weaknesses 

-  There are no updated existing measures and insufficiency of data made not possible 

to assess GES compliance.  

191 

 
 
 
-  The gap analysis only considers descriptors where GES has been shown not to be 

achieved, so D4-food webs is not included.   

-  As no new pressures are identified, nor any new measures reported, the assessment 

of pressure, targets or implementation is not possible.   

-  No  specific  links  between  MPA  measures  and  D4-food  webs  are  made  and  no 

pressures are identified.  

-  The  adequacy  of  Latvia’s  report  on  D4-food  webs  in the  second  programme  of 

measures shows no progress since the 2016 assessment.  

-  GES  is  still  not  clearly  defined  or  assessed,  and  no  new  measures  have  been 
proposed, including activities which could have addressed the data deficiency and 
allowed progress. 

The adequacy of Latvia’s programme of measures for D6 is considered moderate. 

-  Latvia has explained how the updates to the existing measures from the first cycle 

contribute to achieving GES. 

-  The gap analysis is complete and, even if seabed integrity was assessed as in good 
condition,  an  assessment  of  GES  for  benthic  habitats  under  D1-biodiversity  has 
been included. 

-  Details of where, how, and when measures will be implemented are well presented.  
-  A clear financial source is provided for all new measures. 
-  Latvia  demonstrates  plans  to  coordinate  with  other  legislation  in  order  to  meet 

MSFD targets. 

-  Modified and new measures in the second cycle do not address relevant pressures. 
Five additional MSFD specific measures are reported, all linked to a single pressure: 
disturbance of species.   

-  Several  measures  refer  only  to  the  gathering  of  knowledge  and  so  cannot  be 

considered as addressing pressures. 

-  None of the additional MSFD specific measures contribute to meeting operational 

targets. 

-  New MPA measures do not address a full range of pressures nor do they include 

details of objectives or management. 

-  The adequacy of Latvia’s report on D6 in the second programme of measure shows 

some progress since the 2016 assessment.   

-  Although new measures are presented, GES is still poorly defined and associated 
targets are not operational.  The gap analysis has identified pressures on seabed 
habitats, though these are not addressed in the new measures.   

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Latvia’s programme of measures for D7 is considered poor. 

Strengths 

-  Some of the main elements of the gap analysis are presented.  

Weaknesses 

-  No measures are reported for D7, as in 2016.   
-  Latvia mentions that one measure (environmental impact assessment, linked to the 

EIA Directive) is implemented, but this is not explicitly reported. 

-  Latvia's updated Programme of Measures is still not sufficient to ensure that the 
GES for D7 will be achieved or maintained by the end of the second MSFD cycle. 
-  One environmental target has been defined; however, it is not operational and not 

clearly covered by the updated programme of measures. 

Progress since 2016 

-  Like in 2016, no measures are defined for D7. 

192 

 
 
 
-  Pressures  coverage  remains  as  "Not  addressed"  in  2022  as  no  measures  are 

defined. 

Based  on  the  information  reported  in  their  programmes  of  measures,  Latvia’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘high’.  

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

Latvia  has  undertaken  an 
impact  analysis  of  some  of 
the  new  measures  prior  to 
adopting  them,  including  a 
Cost-Benefit  Analysis  (CBA) 
and 
Cost-Effectiveness 
Analysis  (CEA).  However, it  is 
not  clear  how  results  have 
influenced 
measure 
prioritisation or selection.  

has 

examined 
Latvia 
qualitative 
of 
measures  on  employment 
and activities. 

impacts 

Latvia  has  reported  the 
following 
of 
sources 
national 
the 
funding: 
budget, EU funds (e.g. LIFE 
programme, 
EMFAF, 
Interreg  BSR),  and  private 
funding where relevant (e.g. 
for ports to provide ballast 
water  deposition  facilities). 
Latvia  has  not  provided 
information 
the 
proportion of the total cost 
of  measures  that  will  be 
funded by the EU funds. 

on 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

and 

Latvia  has  highlighted  the 
links between the MSFD, the 
CFP, MSP, WFD and HBD in 
terms  of  objectives  and 
measures 
the 
authorities  responsible  for 
implementation. It has also 
highlighted 
national 
strategies  and  actions  (e.g. 
Latvian  Maritime  Spatial 
Planning  2030)  that  are 
linked to these EU policies. 

Regional  coordination 
is 
done through HELCOM and 
Latvia  has  presented  how 
work at the EU and regional 
level has contributed to the 
development of the second 
programme of measures. 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  six 
Descriptors (D1, D2, D5, D6, 
D8, D10) provide sufficient 
information 
spatial 
coverage.342  For  example, 
measures  for  D6  cover 
Latvia and their EEZ.  

on 

How:  Measures 
for  six 
Descriptors (D1, D2, D5, D6, 
D8, D10) provide sufficient 
information 
on 
operationalisation 

When:  Measures  for  six 
Descriptors (D1, D2, D5, D6, 
D8, D10) provide sufficient 
information  on 
temporal 
scope. 

6.11 Lithuania 

Summary: 

Overall, the second programme of measures presented by Lithuania is considered as not adequate to address the pressures 
acting on the Lithuanian marine environment.  

Lithuania performed a financial cost analysis, a cost-effectiveness analysis and a cost-benefit analysis for existing and 
additional MSFD specific measures. Lithuania has considered the impacts of climate change in their assessment of the 
state of the descriptors. For a number of topics, Lithuania has provided relatively good information on where, when and 
how the specific additional MSFD specific measures will be implemented. 

On  the  downside,  no  descriptor  was  considered  to  be  covered  by  adequate  new  measures,  although  measures  for 
contaminants, eutrophication, litter and non-indigenous species have been assessed as moderately adequate to address 
pressures. For most descriptors, Lithuania has undertaken at most a very partial gap analysis if at all. Consequently, no 

342 Latvia did not report modified and additional new measures for D3, D4, D7 and D9. Latvia made no mention of 
underwater noise (D11) in their second Programme of Measures.  

193 

 
 
 
 
 
 
additional measures are provided for a number of descriptors; notably on underwater noise, birds or seafloor integrity. For 
most descriptors, no information is provided to indicate what contribution the measure might make towards achieving 
operational targets and GES. There is no or very limited references to other initiatives, in particular WFD. There is uncertainty 
on whether funding of the measures has been secured. 

Based on the information reported in their programmes of measures, Lithuania’s commitment to implement their second 
programme of measures has been assessed as ‘high’. 

The adequacy of Lithuania’s programme of measures for cross-cutting issues is 
considered moderate. 

There are topics such as the cost-benefit and cost-effectiveness analysis where Lithuania provided 
in-depth information on the approach and results. However, there are several areas (e.g. outcomes of 
regional seas conventions or international agreements) where the information provided is limited, and 
there are cases where Lithuania has not reported the information (e.g. public consultation). 

Topic 

Strengths 

Weaknesses 

financial 

cost 
Lithuania  performed  a 
analysis, a cost-effectiveness analysis and a 
cost-benefit  analysis  for  41  additional  and 
existing measures. 

Lithuania  has  not  reported  on  how  the 
economic  assessments 
the 
selection  of  the  final  list  of  measures 
included in their programme of measures. 

influenced 

Lithuania  provided  in-depth  information  on 
the approach and results of the cost-benefit 
and cost-effectiveness analysis.  

Socio-economic 
assessment 

There  is  no  evidence  to  indicate  that 
Lithuania investigated specific social issues 
relevant  to  the  implementation  of  the 
social 
programme 
acceptability  of  the  measures  given  the 
distribution  of 
impact  on 
vulnerable groups. 

of  measures. 

impacts, 

Lithuania considered the impacts of climate 
change  in  their  assessment  of  the  state  of 
the descriptors. 

Lithuania has not reported if and how they 
considered climate change in the selection 
of measures. 

Interactions with 
climate change 

As  for  its  3rd  RBMPs  under  the  WFD, 
Lithuania does not sufficiently build on the 
findings  to  define  measures  and/or  to 
future-proof measures. 

Lithuania  does  not  provide  additional 
information on mechanisms and outcomes 
of  coordination  and  whether  coordination 
with  other  EU  policies/legislation  helped 
and/or influenced measures selection.   

Lithuania's work for their second cycle of the 
MSFD  contributed  to  their  National  Water 
Plan,  which 
national 
implementation  of  the  Water  Framework 
Directive and the Floods Directive. 

includes 

also 

Links to other 
policies 

Lithuania also provided a breakdown of the 
value  of  funding  they  anticipate  to  receive 
from some of the European Funds.  

Lithuania does not report a specific amount 
that will be spent specifically for the MSFD 
and the measures. 

Lithuania  showed  strong  considerations  of 
multilateral  actions  in  the  Baltic  Sea  via 
HELCOM and listed existing measures (same 
as  in  the  MSFD  programme  of  measures) 

194 

Lithuania does not report on key outcomes 
of cooperation with other agreements.  

Lithuania does not present information on 
transboundary  impacts  of  measures,  and 
they  notified 
they  don’t 

report 

if 

 
 
 
 
 
 
 
 
 
that  are  in  line  with  specific  actions  in  the 
Baltic Sea Action Plan. 

neighbouring  Member  States  of 
transboundary impacts of measures. 

the 

Regional 
cooperation and 
transboundary 
impact 

the 

Lithuania provided a high-level description of 
how the MSFD (alongside the WFD and the 
Floods  Directive)  will  be  implemented  in 
terms  of 
the  authorities 
timeline, 
responsible,  the  requirement  for  monitoring 
progress  against  objectives,  the  source  of 
funds  to  support  implementation,  and  the 
requirement  to  inform  the  public  annually 
about the implementation progress. 

Public consultation 
and administrative 
process 

Lithuania has not provided information on 
the public consultation they carried out.  

Lithuania  has  not  reported  if  there  have 
implementation 
been  changes 
process 
administrative 
framework since the first cycle of the MSFD. 

the 
the 

and/or 

in 

The adequacy of Lithuania’s programme of measures to  address 
pollution issues is considered poor.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminant 

The adequacy of Lithuania’s programme of measures for D5 is considered moderate 

-  Lithuania  has  provided  a  partial  gap  analysis  which  quantifies  the  contribution  of 

existing Baltic Sea Action Plan measures being applied in Lithuanian waters. 

-  The  additional  MSFD  specific  measures  are  linked  to  targets  that  were  assessed  as 

operational. 

-  Lithuania has provided some of the necessary information on where, when and how the 

specific additional MSFD specific measures will be implemented 

-  Lithuania  has  not  provided  information  on  how  updates  to  existing  measures  and 

additional measures from other initiatives contribute to achieving GES. 

-  The  gap  analysis  does  not  take  account  of  the  effect  of  other  existing  measures. 
Therefore, in the absence of a detailed gap analysis it is not possible to quantitatively 
determine what contribution the measures might make towards achieving operational 
targets and GES. 

-  There is no reference to the WFD which is extremely relevant for D5 if measures are 
implemented.  However,  according  to  the assessment  of Lithuania’s  3rd  RBMPs,  more 
effective measures to improve the ecological status of coastal water bodies, including 
measures to reduce nitrate and nitrogen pollution are needed.   

-  There  remains  uncertainty  concerning  whether  funding  of  the  measures  has  been 

secured. 

-  In 2016, the assessment considered that coverage of pressures had been addressed. 
The  2022  assessment  considers  that  the  modified  and  additional  MSFD  specific 
measures partially cover the relevant pressures. 

-  In 2016, the assessment considered that the measures addressed the components of 
GES and targets as the measures. In 2022, the assessment considers that the measures 
partially cover GES and targets.  

195 

 
 
 
 
 
 
Adequacy 

The adequacy of Lithuania’s programme of measures for D8 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

-  The  additional  MSFD  specific  measure  is  linked  to  a  target  that  was  assessed  as 

operational. 

-  Lithuania  has  provided  all  necessary  information  on  where,  when,  and  how  the 

additional MSFD specific measure will be implemented. 

-  Lithuania  has  provided  a  partial  gap  analysis  which  quantifies  the  contribution  of 
existing Baltic Sea Action Plan measures being applied in Lithuanian waters referring to 
four specific substances (mercury, TBT, PFAS and diclofenac), 

-  Lithuania  has  not  provided  information  on  how  updates  to  existing  measures  and 

additional measures from other initiatives contribute to achieving GES. 

-  Lithuania’s gap analysis does not take account of the effect of other existing measures. 
The gap analysis refers only to four specific substances, although GES is currently not 
being achieved for a wider range of substances in Lithuania's waters.  

-  There is no reference to Zero Pollution targets or National Ceilings Emissions Directive 

as ‘existing’ measures. Both are potentially relevant updated measures for D8.  

-  There is no reference to the WFD which is extremely relevant for D8 if measures are 
implemented. However, according to the RBMP assessment, measures must in particular 
be taken to improve the poor chemical status of Lithuania’s coastal water bodies, based 
on a source-to-sea-approach that also identifies origins of coastal pollution inland. 
-  In 2016, the assessment considered that coverage of pressures had been addressed. In 
2022, the assessment considers that coverage of relevant pressures was not clear as 
no  analysis  has  been  provided  as  to  whether  the  additional  MSFD  specific  measure 
addresses the relevant pressures. 

-  In  2016,  the  assessment  considered  that  the  measures  partially  addressed  the 
components of GES and targets. In 2022, the assessment considers that the measures 
partially covered GES and targets. 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Lithuania’s programme of measures for D9 is considered very poor  

Strengths 

-  None identified. 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

-  Lithuania has not provided information on how updates to existing measures and new 

existing measures contribute to achieving GES.  

-  No additional MSFD specific measures have been identified relevant to D9. 
-  It  is  unclear  whether  GES  is  currently  being  achieved  for  D9  and  the  assessment  of 
Lithuania’s 3rd RBMPs concluded that all coastal water bodies are reported to be in a 
poor chemical status. 

-  Lithuania has not provided any information on its gap analysis for D9. 
-  In 2016, the assessment considered that coverage of pressures had been addressed. In 

2022 no modified and additional MSFD specific measures are identified.  

-  In  2016,  the  assessment  considered  that  the  measures  partially  addressed  the 
components  of  GES  and  targets.  In  2022,  the  assessment  has  not  identified  any 
modified or additional MSFD specific measures.  

The adequacy of Lithuania’s programme of measures for D10 is considered moderate 

-  Lithuania  has  provided  a  partial  gap  analysis  which  focuses  on  quantifying  the 
contribution of existing Baltic Sea Action Plan measures to the status for (mainly macro-
) litter in Lithuanian waters.  

196 

 
 
 
 
-  Lithuania  has  partially  explained  where,  when,  and  how  the  new  measures  will  be 

implemented.  

-  There is reference to EU beach litter threshold values in the reporting. 
-  It remains unclear how the updates to the measures will contribute to achieving GES. 
-  It  is  not  clear  whether  and  how  the  effect  of  other  existing  measures  has  been 
considered. GES is currently not being achieved for D10 (macro-litter on beaches and 
seafloor) in its waters. 

-  New  measures  are  linked  to  an  environmental  target  that  was  not  considered 

operational. 

-  There remains uncertainty on the implementation status of the additional D10-related 
measure, given that "implementation has not started" but no reasons are given for the 
delay. 

-  Lithuania  continues  to  lack a  clear  definition  of  GES under  MSFD  D10  and  does  not 

provide any environmental targets. 

-  No specifics are given on the inclusion of macro- versus micro-litter, or the impact of 

litter on marine species. 

-  A clear timeline to achieve GES is also lacking. 

-  The adequacy of Lithuania's Art.13 report on D10-Marine Litter has not improved since 

the first cycle assessment. 

-  In  2016,  the  assessment  considered  coverage  of  pressures  addressed,  but  the 
assessment  of  the  second  cycle  concludes  only  partial  coverage  of  the  relevant 
pressures to achieve GES, as micro-litter and litter input from sources such as shipping 
are not translated into dedicated measures in the second cycle. 

-  The  coverage  of  GES  and  related  targets  is,  similar  to  the  first  cycle  assessment, 

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

inadequate.  

Adequacy 

The adequacy of Lithuania’s programme of measures for D11 is considered poor 

Strengths 

-  None identified. 

Weaknesses 

Progress since 2016 

-  There is no gap analysis reported for D11 measures. 
-  Lithuania reports one existing measure aimed at developing two measurement stations 

on underwater noise. This measure does not directly contribute to achieving GES. 

-  The  measures  defined  by  Lithuania  are  still  at  a  very  early  stage  of  defining  the 

monitoring and gathering data for both impulsive and low continuous noise. 

-  None  of  the  measures  aim  at  mitigating  or  reducing  pressures  to  reduce  noise,  and 

possibly achieving GES. 

-  In 2016, the assessment considered coverage of pressures partially addressed. In the 
second  programme  of  measures,  the  measures  are  still  focused  on  improving  the 
monitoring efforts and therefore do not have a direct impact on reduction of the pressure. 
-  The  coverage  of  GES  and  related  targets  is,  similar  to  the  first  cycle  assessment, 
inadequate. Lithuania has still not defined GES under Article 9 and the D11 target under 
Article 10 is not operational. 

The  adequacy  of  Lithuania’s  programme  of  measures  to 
address biodiversity issues is considered poor. 

197 

 
 
 
 
 
D1 — Biodiversity 

Adequacy 

The adequacy of Lithuania’s programme of measures for D1 is considered poor 

Strengths 

-  Lithuania  is  making  efforts  towards  the  conservation  of  birds  and  marine  mammal 

species in other frameworks which may contribute towards GES. 

-  No  gap  analysis  is  provided  by  the  Member  State  aside  from  a  brief  update  on  the 

current status of fish and bird species in Lithuanian waters. 

-  No reporting on the current status of marine mammals or pelagic habitats is provided. 
-  No new measures regarding birds reported. 
-  The contribution to the MSFD targets is not clearly stated. 
-  Current, existing and new measures do not cover pelagic species, meaning they are not 

covered at all by the current programme of measures. 

-  No detailed locations are provided for the new measures and very little information on 

the implementation steps and the timeline of these actions is reported. 

-  It is difficult to determine how effective these measures will be at addressing pressures 

and contributing towards targets and GES. 

-  In 2016, the assessment determined that pressures and targets were partially addressed 
by the measures in the programme of measures. The lack of gap analysis means that it 
is not clear how much progress these measures can make towards GES, and how much 
work is needed from new MSFD-specific measures. 

-  For Pelagic habitats, no progress has been made since 2016 with no references made 

Weaknesses 

Progress since 2016 

D2 — Non-indigenous species 

to this habitat.  

Adequacy 

The adequacy of Lithuania’s programme of measures for D2 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

-  The  three  modified  measures  have  the  potential  to  indirectly  reduce  the  pressures 

relating to D2 and improve knowledge base. 

-  The link between the modified measures and other policies is clear. 
-  A gap analysis is included in the separate report, 'Strengthening Environmental Protection 
Management of the Lithuanian Baltic Sea - Final Report', based on HELCOM’s Suffiency 
of  Measures  analysis,  on  the  extent  to  which  existing  measures  are  contributing  to 
achieving GES. 

-  Lithuania has explained where the new measures will be implemented. 
-  The four new measures will only indirectly address the pressures relating to D2 as they 
are focused on trainings, early warning systems and improving the knowledge based. 
Although these measures can also contribute to reducing pressure levels, there is a lack 
of more direct measures addressing the relevant introduction pathways.  

-  The single target reported for D2 under Article 10 was not considered measurable or 

operational.  

-  In 2016, Lithuania's measures were considered to have partially addressed the pressure 
of NIS and the activities reported under Article 8. In 2022, the assessment remains the 
same. 

-  In 2016, Lithuania's measures were considered to address GES and targets. In 2022, in 
the absence of information regarding achieving of GES, it is not clear whether measures 
are sufficient to achieve GES or not.  

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Lithuania’s programme of measures for D3 is considered poor 

198 

 
 
 
 
Strengths 

Weaknesses 

Progress since 2016 

D4 — Food webs 

Adequacy 

-  The  gap  analysis  includes  a  quantitative  and  qualitative  analysis  of  the  impact  of 

existing and new measures 

-  Lithuania  has  not  clearly  explained  how  updates  to  existing  measures  contribute  to 

achieving GES. 

-  Lithuania partially identifies the gaps to achieve the MSFD targets and ultimately GES. 
-  The  additional  MSFD  specific  measures  do  not  represent  actions  that  will  reduce 
pressures, and are not relevant to D3 species (cod, herring, sprat and flounder). They will 
therefore not contribute to reducing pressures for GES under D3. 

-  Additional  measures  are  needed  to  address  the  poor  status  of  age/size  structure  for 

herring. 

-  In  2016,  Lithuania's  programme  of  measures  was  considered  to  partially  address 
relevant pressures on fish stocks. In 2016, the programme of measures was considered 
to partially address GES and targets. 

-  In  2022,  there  is  one  updated  existing  measure  and  three  additional  MSFD  specific 
measures  for  D3  reported.  These  measures  are  considered  not  to  be  relevant  to 
pressures related to D3; therefore, no progress can be considered to have been made in 
relation to pressures or coverage of GES/targets. 

The adequacy of Lithuania’s programme of measures for D4 is considered very poor 

Strengths 

-  None identified. 

-  Food web health is not explicitly referred to. 
-  An update on the current status of food web health is not provided. 
-  The new measure introduced under D4 is evidently designed for D1. 
-  The reporting of the new measure itself is also inadequate, with little to no information 

about when and how the measure will be implemented. 

-  Only one of the pressures is covered by the new measures, and only indirectly through 

gathering more knowledge.  

-  Measures which address only two species groups, whilst beneficial, will not cover food 

web health entirely as this is dependent on the health of every trophic level.  

-  In 2016, the assessment determined that pressures were partially addressed under D4 

by the measures in the programme of measures. 

-  No  progress  has  been  made  since  2016,  measures  continue  to  partially  address 

pressures and do not address targets for both fish and marine mammals. 

-  There has also been no progress made in assessing and managing D4 in its own right.  

The adequacy of Lithuania’s programme of measures for D6 is considered very poor 

-  The  programme  of  measures  gives  a  brief  update  of  the  current  status  of  seabed 

habitats. 

-  No  proper  gap  analysis  is  provided  for  seabed  integrity  and  no  update  on  progress 

towards environmental targets is provided. 

-  Despite seabed integrity status being poor due to human activity pressures, no additional 
MSFD specific or updated measures are introduced under D6, in particular to directly 
reduce the pressure of physical disturbance and loss from damaging human activities, 
such as bottom-trawl fishing. 

-  In  2016,  the  assessment  determined  that  neither the  pressures  nor  the  targets  were 

addressed by the measures in the programme of measures.  

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

199 

 
 
 
-  No progress has been made since 2016.  
-  Pressures and targets for seabed integrity remain unaddressed by the measures as no 
new  measures  have  been  introduced  for  descriptor  6  in  the  updated  programme  of 
measures.  

D7 — Hydrographical changes 

Adequacy 

The adequacy of Lithuania’s programme of measures for D7 is considered poor. 

Strengths 

Weaknesses 

Progress since 2016 

-  Lithuania produced an assessment of pressures from existing and future activities that 

are likely to affect hydrographical conditions. 

-  Some existing measures from the WFD programme of measures or linked to EIA are 

already implemented. 

-  Lithuania  has  not  defined  any  operational  environmental  targets  that  could  guide 

progress towards ultimately achieving GES. 

-  No measure is identified to limit these pressures from existing and future activities. 
-  No updated or new measures are reported.  
-  Lithuania's  adequacy  score  for  its  report  on  its  programme  of  measures  for  D7  has 
slightly progressed since 2016, since some elements of the gap analysis are provided in 
the programme of measures. However, like in 2016, no measures are defined for D7. 

Based  on  the  information  reported  in  their  programmes  of  measures,  Lithuania’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘high’.  

Key  Factor  1:  Socio-
economic impacts of new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

Lithuania  has  carried  out  an 
impact  analysis  of  new 
measures  prior  to  adopting 
including  a  Cost-
them, 
Benefit  Analysis  (CBA)  and 
Cost-Effectiveness  Analysis 
(CEA),  but 
is  no 
information  on  how  these 
influences  measure  selection 
or prioritisation. 

there 

has 

not 
Lithuania 
investigated  or  reported  on 
social  impacts  of  measures, 
but presented the benefits of 
achieving  GES  using  a 
of 
benefits 

transfer 

to 

support 

reported 
Lithuania  has 
national, 
municipal, 
Klaipeda  port  and  EU  (e.g. 
Programme, 
Horizon 
EAFRD,  Cohesion  policy) 
the 
funds 
implementation 
of 
It  has  also 
measures. 
provided  a  breakdown  of 
the  value  of  funding  it 
anticipates  receiving  from 
the  European 
some  of 
Funds,  but  the  amount  to 
be spent specifically for the 
MSFD  and  the  measures 
are not reported.  

Key 
3: 
Factor 
Coordination  with  EU 
policies  and 
regional 
coordination 

River 

Lithuania has described the 
alignment  of  some  of  the 
measures 
the  second 
in 
programme  of  measures 
with  the  measures  for  the 
Nemunas 
Basin 
Management  Plan  for  the 
WFD. Links to the MSP and 
HBD are highlighted through 
two  measures,  but  there  is 
no  reference  to  the  CFP. 
Authorities  responsible  for 
implementation  are 
listed 
against each measure.  

cooperation 

is 
Regional 
done  via  HELCOM,  and  the 
of 
second 

programme 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  six 
Descriptors (D2, D4, D5, D8, 
D10,  D11)  have  sufficient 
spatial 
information 
coverage, and measures for 
D1 
partial 
have 
information343.  

on 

for 

How:  The  measure  for  D8 
has  sufficient  information 
on  operationalisation,  and 
five 
measures 
Descriptors  (D2,  D4,  D5, 
D10, D11) only have partial 
is  no 
information.  There 
on 
information 
operationalisation  provided 
for measures for D1.  

343 Lithuania did not report modified or additional MSFD specific measures for D3, D6, D7 and D9.  

200 

 
 
 
 
 
 
 
ecosystem services valuation 
from other Baltic countries. 

been 
has 
measures 
developed  with 
actions 
under  the  Baltic  Sea  Action 
Plan in mind. 

for 

When: The measure for D8 
is reported to have already 
implementation. 
started 
Measures 
four 
Descriptors  (D2,  D4,  D5, 
D10,  D11)  have  partial 
information 
their 
temporal 
scope,  while 
measures for D1 and D4 do 
not have information.  

on 

6.12 Netherlands 

Summary: 

Overall, the second programme of measures presented by the Netherlands is considered to be moderately adequate to 
address the pressures acting on the Dutch marine environment and partially contributes to achieving the Netherlands’ GES 
and targets.  

The updated PoMs presented by the Netherlands is very complete; both e-reporting and text reporting give a clear overview 
of  the  required  information.  The  financing  sources  that  will  support  the  implementation  of  measures  are  clear  and 
appropriate and regional collaboration and policy integration are well described. Measures for seafloor integrity (D6) and 
hydrographical changes (D7) have been assessed as highly adequate to address relevant pressures. 

Little information however was provided on the economic analysis carried out, notably on the categories of costs and 
benefits  and  on  how  economic  analysis  helped  in  selecting  measures.  Similarly,  how  the  Netherlands  has  taken  into 
consideration  climate  change  in  the  selection  of  its  measures  is  not  clear.  Measures  against  eutrophication  and 
contamination, as well as measures to protect foodwebs, have all been considered as poor or very poor. 

Based on the information reported in their programmes of measures, the Netherlands’ commitment to the implementation 
of their second programme of measures has been assessed as ‘medium’.  

The adequacy of the Netherlands’ programme of measures for cross-cutting issues 
is considered moderate. 

The updated programme of measures of the Netherlands did not experience significant changes since 
the first cycle in terms of methods applied for measures selection, reported links between the MSFD 
and other policies, regional and/or international cooperation, and public consultation. 

Topic 

Strengths 

Weaknesses 

New measures were developed with an 
objective to reach good environmental 
status (GES) when gaps were identified. This 
selection of the measures was done by 
undertaking a Cost-Benefit Analysis (CBA). 

The Netherlands did not provide any 
information on how results of CBA were 
used to select/adapt/remove measures 
initially considered. 

The Netherlands did not present an 
indication of social issues considered and 
analysis to support the development of 
the programme of measures. 

Socio-economic 
assessment 

201 

 
 
 
 
 
 
The Netherlands considered the effects of 
climate change on the marine environment 
while developing/elaborating the updated 
programme of measures. 

The Netherlands will take action to enhance 
knowledge on the understanding of the 
impacts of ocean acidification on 
ecosystem services. 

The Netherlands did not report detailed 
information on how climate change was 
considered in selecting measures notably 
on reducing greenhouse gases emissions 
or enhancing the adaptive capacity and 
resilience of marine ecosystems.  

In its 3rd RBMP reporting under the WFD, 
the Netherlands refer to the National 
Climate Change Adaptation Strategy as a 
vehicle to address, amongst others, water 
issues. However, for the MSFD 
programmes of measures it is unclear if 
the proposed measures are part of the 
climate change adaptation strategy of the 
country or not.  

It is unclear whether new measures will 
help preserve ecosystem services and 
socio-economic activities against climate 
impacts. 

The programme of measure refers to the 
links between the MSFD and other EU 
policies (WFD, MSP, CFP, BHD). 

Coordination mechanisms between the 
MSFD and the different policies were not 
listed nor described. 

Financing of new measures is majorly done 
by national sources. 

The amount of funding mobilized by NL for 
the period of 2022 - 2027 was estimated 
at 88 million EUR 

The Netherlands cooperates with 
neighbouring countries through OSPAR and 
the EU CIS MSCG. 

The Netherlands allowed OSPAR contracting 
parties to express their views on the 
programme of measures. 

A more detailed analysis would be 
required to understand whether all EU 
financing opportunities have been seized 
or not. 

The Netherlands did not specify if 
transboundary impacts of the proposed 
measures have been assessed or not or 
considered in the consultation. 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public consultation on the draft of the 
programme of measures was carried out by 
means of a written consultation and 
discussed with stakeholders during 
individual discussions. It is in line with the 
assessment of the Dutch 3rd RBMPs which 
concludes that the Netherlands provides a 
case of good practice for public 
involvement. 

Public consultation 
and administrative 
process 

It is unclear if feedback from the 
consultation process has led to changes in 
measures selection 

202 

 
 
 
 
 
 
The adequacy of the Netherlands’ programme of measures to 
address pollution issues is considered moderate. 

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8 — Contaminants 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Netherlands’ programme of measures for D5 is considered poor. 

-  Eutrophication and relevant measures are well understood and in place to address them. It 
is  consistent  with  the  assessment  of  Netherlands’  3rd  RBMPs  which  mentions  that 
measures to address nutrients/pesticides and point source are in place. 

-  Measures  are  in  place  to  address  many  of  the  key  pressures  contributing  to  elevated 

concentrations of nutrients in the marine environment. 
-  Information relevant to a gap analysis has been presented. 
-  The gap analysis does not identify how existing measures contribute to achieving GES and 

what new measures are needed to achieve GES. 

-  The Netherlands has not clearly identified any new measure and has not identified any 
existing measures that need to be updated, for instance under the WFD, despite the fact 
that the RBMPs have been updated since the last cycle.  

-  Some new measures may have been introduced in relation to improving the number of 

farms and associated livestock.  

-  It remains unclear whether and when GES might be achieved for D5. 
-  No  references  have  been  made  to  the  National  Emissions  Ceiling  Directive  or  the  Zero 

Pollution Action Plan.  

-  In 2016, all pressures were considered addressed. In this cycle, it is unclear whether all 

relevant pressures are addressed.  

-  Recommendations  made  in  the  last  cycle  have  not  all  been  addressed,  notably  the 

Netherlands still cannot determine whether or when GES will be achieved for D5. 

The adequacy of Netherlands’ programme of measures for D8 is considered poor. 

-  Relevant  measures are  proposed  to address many  of  the  key  pressures  contributing  to 

elevated concentrations of contaminants in the marine environment. 

-  The gap analysis included most of the relevant information.  
-  For D8, the Netherlands assesses that 'good environmental status is likely to be achieved 
for most substances in the period 2022-2028. For persistent substances only, the effects 
of  the  policy  are  still  difficult  to  demonstrate'.  At  the  same  time,  the  assessment  of 
Netherlands’ RBMPs concludes that none of the coastal water body are in good chemical 
status.  

-  The  evolution  of  substance  concentrations,  including  the  increase  of  copper,  is  closely 

monitored. 

-  The gap analysis does not identify how existing measures contribute to achieving GES and 

what new measures are needed to achieve GES. 

-  The Netherlands has not clearly identified any new measure neither any existing measures 

that need to be updated.  

-  Some  new  measures  may  have  been  introduced,  for  example  in  relation  to  PFAS  and 

managing risks of lead contamination from fishing. 

-  No  references  have  been  made  to  the  National  Emissions  Ceiling  Directive  or  the  Zero 

Pollution Action Plan.  

Progress since 2016 

-  In 2016, all pressures were considered addressed. In this cycle, it is unclear whether all 

relevant pressures are addressed.  

203 

 
 
 
 
 
-  Recommendations  made  in  the  last  cycle  have  not  all  been  addressed,  notably  the 

Netherlands has not attempted to quantify the level of pressures for D8. 

D9 — Contaminants in sea food 

Adequacy 

The adequacy for Netherlands’ programme of measures for D9 is considered good. 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  GES is currently achieved and is expected to continue to be achieved based on existing 

actions.  

-  There may be some additional MSFD specific measures under D8, which would also be 

relevant to maintaining GES for D9. 

-  No information is provided on updates/changes to existing measures, although there could 
be some relevant updates/changes to measures within RBMPs and measures required in 
relation to the National Emissions Ceiling Directive. 

-  GES for D9 is assessed as being (and will continue to be) achieved - therefore no additional 

measures are required to address the pressures. 

The adequacy for Netherlands’ programme of measures (programmes of measures) for D10 
is considered good. 
-  The  Netherlands  provides  a  gap  analysis,  including  an  overview  of  the  current 

environmental status on all features within D10. 

-  The Netherlands has adopted a list of 9 modified new measures and 5 additional new, in 
addition  to  an  elaborate  list  of  11  existing  measures.  These  measures  are  considered 
adequate to address GES. 

-  The  Netherlands  provides  adequate  details  on  how  and  where  the  measures  will  be 
implemented  and  specifies  a  temporal  scope  for  all  new  measures  of  the  second 
programme of measures. 

-  The Netherlands will be following up closely on the indicators for micro-litter. 
-  There is a reference to the EU Threshold levels for beach litter in the introduction of the 

dedicated chapter on Marine Litter in the text report. 

-  The lack of distinction between existing and new measures complicates the assessment on 

how existing measures from the first cycle contributed to achieving GES. 

-  The Netherlands does not clearly report on a baseline scenario or a timeline showing when 

the measures, initiatives and/or policies will achieve GES. 
-  The indicators for micro-litter are still being developed today. 
-  It remains unclear whether the EU Threshold levels for beach litter were incorporated in the 

programmes of measures. 

-  In 2016 the measures were considered to be addressing the relevant pressures by targeting 
both macro and micro litter. This is also the case for the second programme of measure. 
-  In 2016, the report stated that all measures would support the progress towards GES by 
2020.  In  the  2022  report,  the  overall  conclusion  for  D10  is  that  the  amount  of  litter  in 
marine environments, (both macro and micro) is indeed decreasing over time and that the 
amount of waste and micro-waste absorbed by marine animals is at a level that is not 
harmful to the health of the species concerned. 

-  A  specific  timeline  had  not  been  provided  in  2016,  whereas  the  e-reporting  in  2022 

provides some clarity on this (although not for all measures). 

D11 — Underwater noise and energy 

Adequacy 

The adequacy for Netherlands’ programmes of measures for D11 is considered moderate. 

-  The Netherlands provides an overview of the measures implemented in the first cycle and 

Strengths 

of GES and environmental targets. 

-  Both impulsive noise and continuous noise are considered in the programmes of measures. 

204 

 
 
 
 
Weaknesses 

-  The gap analysis is limited to presenting the knowledge needs for the second cycle. 
-  Only  two  additional  measures  are  defined:  Developing  an  assessment  framework  for 

seismic research and Support IMO review and update guidelines. 

-  Continuous  noise  is  not  adequately  addressed  and  proposed  measures  in  the  current 
programmes of measures to tackle these pressures are not clearly defined and seem to be 
postponed until revisions are concluded by IMO. 

-  The Netherlands has made just a small update to the programmes of measures, adding 

two category 1. a measure and no new measures. 

-  The D11 measures address the reported pressures and cover the GES and target definition 

Progress since 2016 

for D11. 

-  Since  2016,  the  Netherlands  has  updated  a  number  of  existing  measures  that  show 
progress  with  the  management  of  impulsive  noise  but  the  Netherlands  has  not  shown 
progress with regard to continuous noise. 

The adequacy of the Netherlands’ programme of measures to 
address biodiversity issues is considered moderate. 

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy for Netherlands’ programmes of measures for D1 is considered moderate. 

-  The  Netherlands  successfully  identifies  gaps  in  how  2016  measures  supported 

progress towards GES. 

-  The gap analyses for some species groups are clear. 
-  An  effort  has  clearly  been  made  by  the  Netherlands  to  identify  areas  in  which 

improvement can be made. 

-  The proposed protective areas are useful for addressing some pressure. 
-  The links are made between additional and updated new measures and the identified 
pressures which they aim to combat, as well as clear reporting of its implementation. 

-  The gap analyses for some species groups are insufficient.  
-  The additional new and updated measures presented in this programme of measures 
do not completely cover the gaps identified in the gap analysis. For instance, gaps in 
knowledge  on  seabirds  and  a  complete  lack  of  assessment  methods  for  pelagic 
habitats are not addressed at all, despite preventing the achievement of GES. 

-  Areas in which improvement can be made have not been addressed. 
-  The links between the new additional and updated new measures and environmental 

targets is not clear. 

-  The justification of updated and additional measures from other initiatives and their 

role in the progress towards GES is not clear. 

-  Overall, progress since 2016 is minimal.  
-  The  measures  implemented  in  the  2016  programmes  of  measures  showed  some 
efforts  in  reducing  relevant  pressures.  The  new  and  adapted  measures  show  little 
progress towards reducing significant pressures and achieving targets, since most of 
these are enlargement or designation of protected areas but still on a relatively small 
scale. 

D2 — Non-indigenous species 

Adequacy 

Strengths 

The adequacy for Netherlands’ programmes of measures for D2 is considered good. 

-  The  Netherlands  have  made  clear  that  all  existing  measures  have  been  fully 

implemented for D2. 

205 

 
 
 
 
 
 
-  GES for D2C1 has been considered to be achieved by the Netherlands, and hence no 

specific gaps were identified for achieving D2. 

-  In the gap analysis it is mentioned that investigation is needed into whether further 
measures are needed to prevent non-indigenous or farmed seaweed species being 
grown in the North Sea and the potential risks posed by the use of hard substrates in 
the North Sea 

-  No updated or additional MSFD specific measures were identified for maintaining GES, 
including on emerging issues identified although the Netherlands is investigating other 
pathways of introduction with the aim to minimise new introductions further. 

-  In 2016, the Netherlands measures adequately addressed pressures relating to the 
introduction  of  NIS,  specifically  from  shipping  and  aquaculture  pathways.  In  2022, 
these measures have now been fully implemented and the Netherlands states that 
introductions have reduced.  

Weaknesses 

Progress since 2016 

D3 — Commercial fish and shellfish 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

The adequacy for Netherlands’ Programmes of measures for D3 is considered moderate. 

-  The text report provides a brief summary of fish stock status in relation to the fish 
community (D1) and highlights that not all commercial species are fished at F<Fmsy 
(D3C2).  

-  The existing measures from the last MSFD programmes of measures have not been 

explicitly updated. 

-  The gap analysis is very brief and does not appear to comprehensively consider issues 

across different stocks or different fleet segments.  

-  Despite  conclusions  on  currently  failing  GES  for  certain  stocks,  the  Netherlands 
concludes that it is possible to achieve GES for D3C1 and D3C2 without additional 
measures to be taken for the duration of this programmes of measures. 

-  It is not clear whether mortality from recreational fisheries is adequately considered 

and addressed. 

-  In the 2016, it was concluded that, the Netherlands had addressed the key pressures. 
It  was  highlighted  at  the  time  that  it  was  not  clear  whether  recreational  fishing  is 
included  in  its  programmes  of  measures.  In  2022,  there  were  no  modified  or  new 
measures  reported.  The  question  over  whether  recreational  fishing  is  adequately 
addressed therefore remains. 

-  In  2016,  the  Netherlands  was  considered  to  address  all  components  of  GES  and 
targets  for  D3,  as  the  measures  addressed  fishing  mortality  and  spawning  stock 
biomass, as well as discards and improving selectivity. There are no modified or new 
measures in 2022 therefore status remains the same. 

The adequacy for Netherlands’ programmes of measures for D4 is considered very poor. 

-  None identified. 
-  The gap analysis and update of the current environmental status is insufficient, due to 
a lack of indicators. The Netherlands reports that progress towards GES will only be 
achieved through other descriptors (D1 and D6). 

-  There  is  no  reported  progress  in  the  measures  from  the  previous  cycle,  and  no 
new/updated measures for 2021. The Netherlands makes it clear that it is not in a 
position to create measures for D4, as it is considered as an extension of D1. D4 is not 
considered in its own right, therefore has not designated its own measures. 

-  No environmental targets or measures specific to D4 have been assigned to ensure 

that improvement is seen. 

206 

 
 
 
Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

-  The 2016 technical assessment concluded that measures for D1, D4 and D6 together 
covered all  relevant  pressures.  The  2022  assessment  is that  no progress  has been 
made, as no new or updated measures are reported for D4 specifically. 

The adequacy for Netherlands’ programmes of measures D6 is considered very good. 

-  The gap analysis shows progress towards GES. 
-  Two  areas  of  weakness  are  successfully  identified,  and  most  of  the  measures 

successfully address these gaps. 

-  The  links  between  additional  and  updated  new  measures,  relevant  pressures  and 

Strengths 

environmental targets are clear. 

-  Clear reporting of measures implementation. 
-  Links between new MPA measures and pressures/environmental targets are clear. 
-  The conservation objectives behind the protected areas and whether they are Natura 

2000 sites are also clear. 

-  The justification of updated and additional measures from other initiatives and their 

role in the progress towards GES is not fully clear. 

-  The measures introduced in the 2021 programme of measures directly cover only two 
pressures: species disturbance and species extraction, and the extent of the protected 
areas designated or planned to be designated is not large enough to be sufficient to 
reach GES. 

-  Progress has been made since 2016. As the condition of seabed habitats in the Dutch 
North Sea does not currently meet GES, changes to the measures have been made, 
and new measures have been introduced. 

-  Measures  reported  in  the  2016  programme  of  measures  aimed  to  reverse  the 
deterioration of seabed habitats and improve the quality of broad habitat types. The 
measures presented in the 2021 programme of measures work towards the same 
aims, but with more specific objectives. 

Weaknesses 

Progress since 2016 

D7 — Hydrographical changes 

Adequacy 

The adequacy for Netherlands’ programmes of measures D7 is considered very good. 

Strengths 

Weaknesses 

Progress since 2016 

-  The Netherlands did not propose modified existing measures or new measures since 
the GES for D7 is already achieved. However, the assessment of Netherlands’ RBMPs 
concludes that for some coastal water bodies, ‘other aquatic flora’ and several general 
physico-chemical quality elements seem insufficiently monitored and hence not used 
for status assessment. 

-  The  Netherlands  reported  in  2022  that  the  existing  measures  implemented  in  its 

programme of measures in the MSFD first cycle are sufficient to maintain GES. 

-  The  programme  of  measures  adequately  refers  to  actions  at  regional  level  and  to 
measures pursuant to WFD that are applied in the coastal part of its marine zone.  
-  It remains not clear whether pressures from activities not subject to local/project scale 
Environmental  Impact  Assessment  (EIAs)  (e.g.,  fishing,  maritime  transport)  are 
considered. This gap hampers the assessment of cumulative effects. 

-  The MSFD programmes of measures only apply to EEZ. 
-  The  Netherlands  improved  its  programme  of  measures  since  2016  by  explicitly 
including cumulative impacts and a prospective vision of future activities likely to have 
strong influence on hydrographical changes (D7) such as offshore windfarms and sand 
extraction to mitigate climate change effects. 

207 

 
 
 
 
Based on the information reported in their programmes of measures, the Netherlands’ 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as ‘medium’.  

Key  Factor  1:  Socio-
economic  impacts  of 
new measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

Key Factor 4: Implementing 
modified  and  additional 
MSFD  measures:  where, 
how and when 

No information if CBA 
and/or CEA was used and 
did not report social 
impacts of measures.  

Reported various funding 
sources such as the 
national fund (e.g. Ministry 
of Infrastructure and Water 
Management), the 
Monitoring and Research 
Nature Strengthening and 
Restoration of Resources 
programme, and European 
funds (e.g. EMFAF). 
Planning to mobilise 88 
million EUR of National 
funds for the period of 
2022 - 2027 and 5 million 
EUR from EMFAF for 
specific MSFD measures 
and research.  

Reported  the  coordination 
between  the  MSFD,  WFD, 
MSP, CFP, and BHD in terms 
of  how  measures  achieve 
common 
objectives. 
Authorities  responsible  for 
implementing  measures 
are  listed,  but  there  is  no 
information  on  authorities 
involved 
in  coordinating 
policies.  

Coordination with 
neighbouring countries is 
done through OSPAR and 
EU working groups and the 
OSPAR action programme 
was considered in the 
development of the second 
programme of measures.  

Where: Measures for two 
Descriptors (D6 and D10) 
provide sufficient information 
on spatial coverage. Measures 
for D1 only provide partial 
information, while measures 
for D5 and D8 do not have 
clear information on spatial 
coverage.  

How: Measures for D10 
provide sufficient information 
on operationalisation. For 
example, details on the mode 
of action, responsible 
authorities and financing are 
provided.  Measures for D1 
only have partial information, 
and measures for D5 and D8 
do not provide clear 
information on 
operationalisation. 
Where: Measures for two 
Descriptors (D6 and D10) 
provide sufficient information 
on temporal scope. Measures 
for D1 only provide partial 
information, while measures 
for D5 and D8 do not have 
clear information on temporal 
scope.  

6.13 Poland  

Summary: 

Overall, the second programme of measures presented by Poland is considered to be adequate to address the pressures 
acting on the Polish marine environment and contributes to achieving Poland’s GES and targets.  

In terms of strengths, Poland carried out a good CBA/CEA for the proposed measures and used it for measure prioritisation. 
The impact on climate change has been adequately analysed, in particular for impacts on eurtophication, commercial fish 
and biodiversity. Poland participated to working groups at regional level, enhancing the transboundary nature of the Polish 

208 

 
 
 
 
programme  of  measures.  Measures  for  eutrophication,  contaminants  in  seafood,  litter,  noise,  biodiversity,  food  webs, 
seafloor integrity, commercial fish and non-indigenous species have all been assessed as adequate to address pressures.  

On the downside, no information was provided on the amounts foreseen to implement the new cycle of measures and 
social issues do not appear to have been fully considered. Measures for contaminants and hydrographical conditions have 
been assessed as only moderately adequate to address pressures. 

Based on the information reported in their programmes of measures, Poland’s commitment to implement their second 
programme of measures has been assessed as ‘high’. 

The  adequacy  of  Poland’s  programme  of  measures  for  cross-cutting  issues  is 
considered good. 

Poland followed the MSFD reporting guidelines and provided all required information. However, some 
information  was  missing,  particularly  regarding  how  social  issues  had  been  considered  when 
developing the programme of measures, and mechanisms and outcomes of coordination with other 
EU policies/legislations. Poland’s updated programme of measures did not have major changes since 
the  first  cycle  in  terms  of  methods  applied  for  measures  selection,  regional  and  international 
cooperation, and public consultation. 

Topic 

Strengths 

Weaknesses 

Socio-economic 
assessment 

Interactions with 
climate change 

The  measures  selection  process  involved  a 
followed  by  proposing 
gap  analysis, 
measures  to  reduce  the  gap.  A  Cost-
Effectiveness  Analysis  and  Cost-Benefits 
Analysis  were  undertaken  to  evaluate  the 
the 
associated  costs  and  benefits  of 
proposed measures.  

Poland  defined  a  methodology  to  select 
high-priority  measures  to  put  in  place  and 
decision-making follow-up processes. 

The impact of climate change on the efficacy 
of protective measures for certain descriptors 
(D5, D3, and D1) has been accounted for. 

Concerning  social  issues,  Poland  does  not 
present  any  indication  of  social  issues 
considered and no social assessment was 
carried out to support the development of 
programme of measures. 

Poland  does  not  provide  additional 
information  on  the  impact  of  climate 
change  and  on  (i)  the  potential  impact  of 
measures  on  GHG  emissions,  (ii)  whether 
the  measures  were  part  of  a  climate 
change  adaptation  strategy  and  their 
adaptability, and (iii) whether the proposed 
measures 
preserving 
ecosystem  services  and  socio-economic 
activities. 

contribute 

to 

Likewise,  in  its  3rd  RBMP  reporting  under 
WFD,  Poland  provides  limited  information 
on the impacts of climate change on water 
management,  and  some  measures  are 
indicated to be adaptation measures. 

209 

 
 
 
 
 
 
 
Links  with  other  EU  policies/legislations, 
namely  WFD,  CFP,  MSP,  and  BHD  were 
explored and mentioned in the reporting. 

on 

additional 

information 

the 
No 
mechanisms and outcomes of cooperation 
was  provided,  making 
to 
understand how coordination was done and 
what the synergies and outcomes of such 
cooperation  on  the  final  list  of  measures 
were. 

it  difficult 

Links to other 
policies 

While  the  funding  sources  were  clearly 
listed  and  the  process  of  allocating  funds 
was  explained,  there  was  no  further 
the  specific  amounts 
information  on 
This 
source. 
from 
mobilized 
information  could  have  provided  better 
insights 
targeted 
into  priorities  and 
sectors/descriptors. 

each 

Regional  coordination  was  carried  out 
through  HELCOM,  where  PL  actively 
participated in different working groups.  

Poland did not mention any communication 
with 
on 
neighbouring 
transboundary impacts. 

countries 

Regional 
cooperation and 
transboundary 
impact 

Poland’s  updated  programme  of  measures 
was largely a result of coordinated regional 
efforts.  Poland  used  the  regional  database 
and discussions with neighbouring countries 
to update the programme of measures. 

The  assessment  of  Poland’s  3rd  RBMPs 
highlighted  that  no  joint  consultation  with 
the RBMP had been carried out.  

Thanks  to  public  consultation,  participants 
had  the  chance  to  send  feedback  through 
different  ways:  online  questionnaire,  email, 
etc.  The  consultation  was  widely  promoted 
through  press  briefings,  online  conferences, 
promotion 
intensive 
campaign.  The  public  consultation  process 
had an important impact on the final list of 
measures.  

information 

and 

information  on 
the 
Poland  provided 
implementation  of 
the  programme  of 
measures  and  on  the  responsible  and 
of 
competent  authorities 
coordination 
of 
measures 

charge 
implementation 

and 

in 

Public consultation 
and administrative 
process 

The  adequacy  of  Poland’s  programme  of  measures  to  address 
pollution issues is considered good.  

D5- Eutrophication 

Adequacy 

The adequacy of Poland’s programme of measures for D5 is considered good 

210 

 
 
 
 
 
 
 
 
 
Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

Weaknesses 

-  Poland  has  identified  a  number  of  measures  from  other  relevant  frameworks,  in 
particular WFD or National Emissions Ceiling Directive, in its reporting and quantified 
the contribution that existing measures collectively make towards GES. 

-  Poland has presented a detailed gap analysis for D5. 
-  Additional measures have been identified that would enable Poland to take the actions 
necessary (in co-operation with other countries) to achieve GES but these measures 
have not yet been adopted. The implementation of this measures will be of particular 
importance in coastal water as the assessment of Poland’s RBMPs points out that none 
of the coastal water bodies reach good ecological status.   

-  Poland has provided some of the necessary information on where, when, and how the 

specific additional new measures will be implemented. 

-  The programme of measures includes headline target which establish a direction of 

change relative to baseline and linked to a reduction in pressure.    

-  Four first cycle measures have been withdrawn but specific reasons for withdrawing 

the measures have not been provided. 

-  The  additional  MSFD  specific  measures  are  considered  to  be  partially  linked  to 

operational targets as the targets are a repetition of the GES determination. 

-  There  is  a  general  lack  of  detail  around  the  specific  location  and  timing  of 

implementation and the extent to which funding has been secured. 
-  The measures adopted they would be insufficient to achieve GES. 
-  The adequacy of Poland's report on D5 in the second programme of measures remains 

the same as in the 2016 assessment. No progress has been made. 

-  In  2016,  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed. The 2022 assessment considers that coverage of relevant pressures had 
been partially addressed.  

-  In  2016,  the  assessment  considered  that  the  measures  partially  covered  the 
components of GES and targets. In 2022, the assessment considered that the measures 
partially covered the components of GES and targets.  

The adequacy of Poland’s programme of measures for D8 is considered moderate 

-  The updated measures concern contaminants and are related to WFD measures.  
-  Poland has presented a gap analysis for specific substances not currently achieving 

GES for D8. 

-  The update of the programme of measures clearly sets out the range of pressures. 
-  Poland has provided some of the necessary information on where, when, and how the 

specific additional MSFD specific measures will be implemented. 

-  The gap analysis cannot be considered fully complete as it is unclear how the baseline 
to inform the gap analysis has taken account of future development activity, it does 
not appear that different scenarios have been considered in the analysis, and it is not 
clear whether socio-economics and climate change have been taken into account in the 
gap analysis. 

-  Poland has identified a number of updated of measures from other relevant framework 
in  its  reporting  but  has  not  quantified  the  contribution  that  existing  measures 
collectively make toward GES. 

-  Four  measures  from  other  relevant  framework  have  been  withdrawn  but  specific 

reasons for withdrawing the measures have not been provided.  

-  The additional MSFD specific measures are considered to partially represent actions to 
achieve operational targets as while the actions are linked to operational targets, the 
actions will be insufficient to achieve GES. 

211 

 
 
-  While the measures adopted in the second cycle addressed some of the key pressures, 
some important pressures are not effectively addressed. In particular, coal combustion 
and heavy  industry  are  identified  as  key  sources  of heavy  metal  contaminants, but 
additional measures are currently only linked to improved knowledge of contaminant 
sources  rather  than  reduction  of  the  pressures.    This  is  consistent  with  the  the 
assessment of Poland’s RBMPs which highlights that Poland should take all necessary 
measures  to  prevent  the  emissions  of  polyaromatic  hydrocarbons  (PAHs),  mercury, 
polybrominated  diphenyl  ethers  (PBDEs),  hexabromocyclododecane,  heptachlor  and 
heptachlor epoxide, and perfluorooctane sulphonic acid (PFOS). 

-  There is a general lack of detail around specific locations and timing of implementation 

and the extent to which funding has been secured. 

-  Neither the National Emissions Ceiling Directive (2016/2284/EU) nor the 2021 update 

to the Baltic Sea Action Plan or the Zero Pollution targets are mentioned. 

-  In 2016, the assessment considered that coverage of pressures had been addressed. 
In  2022,  the  assessment  considers  that  coverage  of  relevant  pressures  had  been 
partially addressed. 

-  In 2016, the assessment considered that the measures address both GES and targets. 
In  2022,  the  assessment  considered  that  the  measures  partially  covered  the 
components of GES and targets. 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Poland’s programme of measures for D9 is considered very good 

Strengths 

Weaknesses 

Progress since 2016 

-  Poland has  presented  a  gap  analysis  for  specific  substances  of  concern  relevant  to 
Regulation 1881/2006. The gap analysis indicates that GES is and will continue to be 
achieved for all substances except PBDE. 

-  Measures  from  other  relevant  framework  will  help  to  contribute  to  the  continued 
reduction in other substances of concern (particularly mercury and lead) and provide 
confidence that the reduction targets and GES for these substances will be met. 

-  The gap analysis gives a clear overview of the current state of the descriptor, as well 
as highlights several possible contaminants which may threaten the achievement of 
GES (mercury and lead levels). 

-  Some  measures  may  provide  additional  knowledge  that  could  lead  to  measures  to 

further reduce heavy metal inputs. 

-  The additional MSFD specific measures are considered to sufficiently represent actions 
to achieve operational targets as the actions are linked to operational targets which 
focus on pressure reduction. 

-  Poland has provided some of the necessary information on where, when, and how the 

specific additional MSFD specific measures will be implemented. 

-  Poland has not clearly explained how the updated existing measures contribute to GES. 
-  It is not clear whether alternative scenarios, the socio-economic impacts and climate 

change have been adequately taken into account in the gap analysis. 

-  There is a general lack of detail around the timing of implementation and the extent to 

which funding has been secured. 

-  In 2016, the assessment considered that coverage of pressures had been addressed. 
In 2022, the assessment also considers that coverage of relevant pressures had been 
sufficiently addressed. 

-  In 2016, it was considered that the measures address both GES and targets. In 2022, 
the assessment also considered that the measures covered the components of GES 
and targets as alongside measures from other frameworks could contribute to pressure 
reduction.   

212 

 
 
D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Poland’s programme of measures for D10 is considered good. 

-  Poland has linked existing measures to the updated River Basin Management Plans for 

the Oder and Vistula River. 

-  A clear gap analysis is provided for criterion D10C1 (macro-litter) on beaches.  
-  Information  on  the  spatial  and  temporal  scope,  as  well  as  the  implementation 

mechanisms of the MSFD specific measures is complete. 

-  A timeline for achieving GES by 2027 is anticipated by Poland in its second programme 

of measures.  

-  Recent EU-level developments, such as EU Zero Pollution Action plan, are referenced in 

the text 

-  Poland fails to explain how the modifications to the measures from other frameworks 

will contribute to GES for D10. 

-  A fully quantitative gap analysis is lacking for the remainder of elements under D10C1, 

as well as for the other criteria D10C2, D10C3 and D10C4. 

-  Individual contribution of measures towards GES is not assessed for any of the criteria. 
-  Recent EU-level developments are not translated into modified existing measures. 
-  Poland's second programme of measure has not deteriorated compared to the previous 

assessment cycle and even improved on some aspects. 

-  Regarding pressures, in 2016, the assessment stated that the measures reported by 
Poland addressed the main pressures related to litter input, which is still the case in 
2022. 

-  While  the  2016  reporting  on  the  1st  cycle  programme  of  measures  lacked  clear 
indications  of  timelines  for  the  different  measures,  the  2nd  cycle  programme  of 
measures manage to include timing of implementation for the additional and modified 
MSFD specific measures.  

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Poland’s programme of measures for D11 is considered very good 

Strengths 

-  The gap analysis provided in relation to D11 is considered adequate. 
-  Poland  presents  all  recent  policy  developments  relevant  to  the  management  of 
underwater noise and refers to the HELCOM Guidelines for continuous noise monitoring. 

-  Poland identifies the key pressures and related activities. 
-  Poland explains how future socio-economic developments are taken into account to 

determine future environmental pressures. 

-  Both  continuous  and  impulsive  noise  are  addressed  by  the  modified  and  additional 
MSFD specific measures in the second cycle, covering different main sources as well as 
affected species groups. 

-  Poland specifies that the thresholds recommended by the EU Expert Group TG Noise in 
2018  on  impulsive  underwater  noise  will  be  considered  the  basis  for  monitoring 
activities. 

-  Measures are also linked to D1 and D4 targets which is appropriate considering they 
are focused on the reduction of the pressure affecting specific marine mammals and 
restoring a species or habitats. 

-  Poland provides adequate information regarding the spatial and temporal scope of the 

measures as on the implementation of the measures. 

Weaknesses 

-  One  MSFD  specific  measure  from  the  first  cycle  was  withdrawn;  the  justification 

provided refers to cost-effectiveness, however, no further details are provided. 

213 

 
 
 
-  Of the six modified and additional MSFD specific measures, only one is linked to the 

operational targets defined for D11. 

-  Some information is lacking regarding the funding source and indicators for some of 

the measures. 

-  Poland has improved its programme of measures for the 2nd cycle.  
-  Poland was assessed as partially addressing pressures and partially addressing GES 
and targets in 2016. For the second cycle, Poland has defined measures that directly 
address the pressures and thus also directly contributing to achieving GES for D11. 

Progress since 2016 

The  adequacy  of  Poland’s  programme  of  measures  to  address 
biodiversity issues is considered good.  

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Poland’s programme of measures s for D1 is considered good 

-  The programme of measures describes how river basin management plans have been 

revised, providing a reason for update of the D1 specific measure. 

-  The  programme  of  measures is based  on a  good  gap  analysis:  the analysis  provides 
details of whether existing measures are sufficient to reach GES, based on a series of 
indicators, and knowledge gaps are also identified. 
-  The withdrawal of measures is adequately justified. 
-  Timescales for delivery of measures are fully presented. 
-  No  specific  measures  relating  to  the  designation  of  new  marine  protected  areas  are 

reported. 

-  The  gap  analysis  does  not  provide  an  assessment  of  the  impacts  of  pressures  from 

human activities.  

-  The additional MSFD specific measures partially address the relevant pressures for D1-

biodiversity and only partially contribute to meeting operational targets. 

-  Some issues identified in the gap analysis, for example around indicators linked to seal 
reproduction, or the large fish index, have relevant targets, but no associated measures. 
-  Where and how additional MSFD specific measures will be implemented is only partially 

explained. 

-  Information  on  the  assessment  of  D1-biodiviersty  in  2016  is  not  available,  so  no 

comparison can be made. 

-  Poland should link the gap analysis with the development of MSFD specific measures 

more clearly to ensure that gaps are filled and progress to GES is not limited. 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Poland’s programme of measures for D2 is considered very good 

Strengths 

-  The gap analysis is comprehensive and identified key pathways of introduction of NIS to 
Polish waters and the Baltic Sea and assessed recent introductions against an appropriate 
baseline. 

-  The  gap  analysis  identified  potential  future  pressures  relating  to  the  spread  and 

introduction of NIS.  

-  All modified and additional MSFD specific measures address relevant pressures relating 

to D2 and those identified in the gap analysis. 

-  The MSFD specific measures are considered to address the operational target. 

214 

 
 
 
 
 
 
Weaknesses 

Progress since 2016 

-  Information  on  when,  where  and  how  the  new  measures  will  be  implemented  are 

adequately detailed, particularly in the measure descriptions. 

-  No details are provided on why a measure from the 1st cycle was withdrawn. 
-  Not all targets relating to D2 are considered to be operational.  
-  The adequacy of Poland's report for D2 in the second programme of measures remained 
similar  to  the  2016  assessment  as  the  measures  well  address  both  pressures  and 
targets. 

-  In  both  the  2016  and  2022  assessments,  it  was  considered  that  the  measures  are 
adequately  addressing  the  relevant  pressure  relating  to  limiting  the  introduction  and 
spread of NIS. 

-  In  addition,  Poland's  measures  in  both  2016  and  2022  address  GES  and  relevant 

D3 — Commercial fish and shellfish 

operational targets. 

Adequacy 

The adequacy of Poland’s programme of measures for D3 is considered good 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

-  The  programme  of  measures  includes  an  extensive  section  on  existing  management 

instruments and action plans relevant to D3. 

-  Poland  has  provided  a  gap  analysis  that  adequately  identifies  all  significant  gaps  to 

achieve GES for D3. 

-  Poland reports measures which are considered to partially address all relevant pressures 
as they mostly focus on reducing eutrophication pressures but Poland justified this choice. 
-  Poland has explained where and when the additional MSFD specific measures will be 

implemented, and explained how they will be implemented. 

-  Information is provided on the relevant policies and regulations for implementation, the 

responsible organisation and sources of funding. 

-  Recreational fishing, and extraction of seaweed and other sea-based food harvesting, 
were  identified  in  the  first  cycle  programme  of  measures  as  potentially  not  being 
adequately addressed; the modified and additional new measures do not address these 
areas. 

-  Most  of  the  modified  and  additional  new  measures  are  focused  on  reducing  nutrient 

inputs, rather than directly focusing on D3 issues and targets. 

-  The adequacy of Poland's report on D3 in the second programme of measures remains 

the same as in the 2016 assessment. No progress has been made. 

-  In 2016, Poland's programme of measures was considered to partially address relevant 
activities causing the pressure 'extraction of species'. In relation to GES and targets, the 
programme of measures was considered to partially address relevant aspects. 

-  In 2022, the updated programme of measures was considered to continue to partially 
address relevant pressures, as the aspects identified as missing or not clearly addressed 
in the first cycle programme of measures continue to not be addressed in the updated 
programme of measures. 

The adequacy of Poland’s programme of measures for D4 is considered good 

-  The programme of measures is based on a good gap analysis. In particular, the analysis 

also considers future scenarios, taking socio-economic factors into account. 

-  The analysis provided details of whether measures are sufficient to reach GES, based on 

a series of indicators, and knowledge gaps are also identified. 

-  Poland  reports  a  wide  range  of  targets  as  being  relevant  to  the  new  and  additional 

updated measures. 

215 

 
 
 
-  The  programme  of  measures  includes  several  measures  focused  on  improving  the 
protection offered by existing sites, both by strengthening broader MPA management and 
addressing specific issues related to disturbance of marine mammals in MPAs. 

-  The  gap  analysis  does  not  provide  an  assessment  of  the  impacts  of  pressures  from 

human activities. 

-  The additional MSFD measures only partially address the relevant pressures for D4-food 

webs. 

-  One group of measures are assessed as only indirectly addressing pressures, with no 

clear link to food web stability. 

-  Only one target is addressed by additional and modified MSFD specific measures. 
-  Where  and  how  additional  and  modified  new  measures  will  be  implemented  is  only 

partially explained. 

-  Information  on  the  assessment  of  D4-food  webs  in  2016  is  not  available,  so  no 

comparison can be made. 

The adequacy of Poland’s programme of measures for D6 is considered good 

-  The programme of measures is based on a good gap analysis. The analysis provides 
details of whether existing measures are sufficient to reach GES, based on a series of 
indicators, and knowledge gaps are also identified. 

-  The gap analysis provides details for all five criteria under which GES for D6 are assessed. 
-  Poland  reports  a  wide  range  of  targets  as  being  relevant  to  the  new  and  additional 

updated measures. 

-  Direct measures are listed under D1, but Poland makes a clear link to D6. These include 

several that will address the pressure on seabed habitats from bottom dredging. 

-  The additional MSFD specific measures address relevant pressures which pose a threat 

to the health of benthic habitats and contribute to meet operational targets.  

-  Timescales for delivery of measures are fully reported. 
-  Several measures are focused on improving the protection offered by existing sites, both 
by strengthening broader MPA management and addressing specific issues related to 
disturbance of marine mammals in MPAs. 

-  The  gap  analysis  does  not  provide  an  assessment  of  the  impacts  of  pressures  from 

human activities. 

-  According to the gap analysis, pressure from bottom-towed fishing gear is a barrier to 
achieving GES. The withdrawal of a measure linked to reducing this pressure is surprising 
although Poland has introduced two new additional and updated measures with similar 
purposes to replace it. 

-  Given the range of targets reported under D6, it could also be argued that more measures 
may be required to ensure that they are met. Given the gap analysis concludes that none 
of the D6 criteria meet GES, more action may be required to move in the right direction 
and reduce limitations to progress. 

-  Where  and  how  additional  and  modified  new  measures  will  be  implemented  is  only 

partially explained.  

-  Information on the assessment of D6-seabed in 2016 is not available, so no comparison 

can be made. 

-  For real progress to be made towards GES for D6, more attention must be paid to the 
largest threats to seabed health, such as physical disturbance and loss, which are caused 
by human activities such as trawling, which can be restricted. 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D7 — Hydrographical changes 

216 

 
 
Adequacy 

The adequacy of Poland’s programme of measures for D7 is considered moderate 

Strengths 

-  Poland presented an extensive analysis of scenarios for future maritime and terrestrial 
human activities and of their consequences on the evolution of pressures on the marine 
environment. 

-  The measures are adequately described and clearly linked to the limitation of pressures 

and WFD 

-  While Poland considers that the main future pressures in its waters will be linked to the 
development of offshore wind farms, the programme of measures mainly focuses on 
limiting pressures in coastal areas and no measure seems to address the development 
of offshore windfarms. 

-  Poland's gap analysis is partially adequate in identifying all significant gaps to achieve 

GES for D7. 

-  No information is provided about the link with work done at regional level on actions 

related to this descriptor, except a general reference to HELCOM. 

-  The measures are not adequately linked to measurable and operational environmental 

targets thus it remains unclear how they will contribute to achieve GES. 

-  Some  activities  are  still  not  addressed  such  as  waste  disposal,  shipping  and  tourism, 

except for the restrictions of tourist infrastructure in Natura 2000 zones. 

-  Spatial management measures that could locally lead to limitations of pressures linked 

to D7 are planned but not described in detail. 

-  The adequacy of Poland's report on D7 in the second cycle remains the same as in the 

2016 assessment.  

-  Poland's programme of measures has not progressed on the coverage or pressures or 

the coverage of GES and targets.  

-  Cumulative  impacts  are  only  partially  addressed  in  2022,  through  the  measure  on 
guidelines for conducting environmental impact assessments for projects involving the 
exploration and extraction of minerals. 

Weaknesses 

Progress since 2016 

Based  on  the  information  reported  in  their  programmes  of  measures,  Poland’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as “high”. 

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

Key 
3: 
Factor 
Coordination  with  EU 
policies  and 
regional 
coordination 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

41  new  measures  subject  to 
CEA  and  CBA,  and  results 
influenced 
measure 
prioritisation.  Did  not  refer  to 
social issues investigated.  

Reported  the  mobilisation 
of national funds (e.g. state 
funds,  national  fund  for 
environmental 
protection 
and  water  management, 
etc.),  private  funding  (own 
resources  of  farms),  and 
(e.g. 
European 

funds 

Links  and  importance  of 
coordination  between  the 
MSFD and other EU policies, 
notably the WFD, CFP, MSP 
and  HBD  were  presented. 
information 
Exchange  of 
between  both  MSFD  and 
WFD  authorities  during  the 

Where: Measures for seven 
Descriptors (D2, D3, D5, D8, 
D9,  D10,  D11) 
have 
information  on 
sufficient 
coverage,  while 
spatial 
four 
measures 
Descriptors (D1, D4, D6, D7) 
have partial information. 

for 

217 

 
 
 
 
 
provide 

European 
EMFAF, 
infrastructure  funds).  Did 
not 
further 
information  on  the  specific 
amounts  mobilized  from 
each source 

and 
implementation 
monitoring 
both 
Programme  of  Measures 
was mentioned.  

of 

to 

Regional  coordination 
is 
done  through  HELCOM  at 
the  ministerial  level  and 
for 
regular  meetings 
various  working  groups. 
Specific 
the  MSFD, 
Poland  is  part  of  HELCOM 
working  groups  dedicated 
to  the  implementation  of 
the 
Strategy 
focusing on three key areas: 
Good Environmental Status, 
Socio-Economic  Analysis, 
and  Information  and  Data 
exchange.  

Marine 

How:  Measures  for  four 
Descriptors (D2, D3, D7, D9) 
have  sufficient  information 
on operationalisation, while 
seven 
measures 
Descriptors (D1, D4, D5, D6, 
D8,  D9)  only  have  partial 
information.  

for 

When:  Measures  for  seven 
Descriptors (D2, D3, D4, D6, 
D7,  D10,  D11) 
have 
information  on 
sufficient 
temporal 
coverage. 
Additional  and  modified 
new measures are reported 
to have started in 2022 will 
continue  until  2025-2027. 
Measures 
four 
Descriptors (D1, D5, D8 and 
D9)  only  have  partial 
information  on 
temporal 
coverage. 

for 

6.14 Portugal 

Summary: 

Overall, the second programme of measures presented by Portugal is considered as not adequate to address the 
pressures acting on the Portuguese marine environment.  

In terms of strengths, Portugal’s measures are designed to enhance the resilience of marine ecosystems as part of an 
integrated response to the overall climate change issues. Regional cooperation is addressed via OSPAR and Portugal 
undertook regional/ subregional coordination of measures with France and Spain specifically. Funding sources are all 
clearly identified.   

On the downside, the absence of detailed gap analyses for all of the descriptors makes it very difficult to assess the 
appropriateness of the new measures presented by Portugal. There is also no clear description of coordination 
mechanisms across different authorities for the implementation of measures stemming across different policy/sectoral 
areas (e.g. environment/ fisheries). No descriptor was considered to be covered by adequate new measures, although 
measures for litter, eutrophication, noise, biodiversity, food webs, hydrographical conditions and non-indigenous species 
have been assessed as moderately adequate to address pressures. 

Based on the information reported in their programmes of measures, Portugal’s commitment to the implementation of 
their second programmes of measures has been assessed as “high”. 

The  adequacy  of  Portugal’s  programme  of  measures  for  cross-cutting  issues  is 
considered moderate. 

Portugal’s updated programme of measures witnessed minor changes since 2016. Portugal provided 
the information requested in the MSFD reporting guidelines; however, some information that would 
have  allowed  for  better  understanding  are  still  missing,  specifically  regarding  outcomes  of 

218 

 
 
 
 
 
methodologies,  climate  change  considerations,  coordination  between  the  different  policies,  etc. 
Additional information could have allowed a better understanding of the programme of measures, 
and, eventually, a higher assessment score.  

Topic 

Strengths 

Weaknesses 

Only one measure was subject to a 
Cost Effectiveness Analysis 

Portugal  does  not  present  any 
issues  and 
indication  of  social 
analysis 
the 
development of the programme of 
measures.    

support 

to 

not 

does 

Portugal 
provide 
information  on  (a)  the  contribution 
of  measures  in  reducing  GHG,  (b) 
the  adaptive  capacity  of 
the 
measures,  and  (c)  whether  the 
proposed measures help preserving 
ecosystem  and  socio-economic 
activities 

Portugal does not provide additional 
information explaining mechanisms 
of 
the 
coordination  between 
different directives and policies, and 
more importantly on the outcomes 
of such coordination. 

No  information  was  provided  the 
assessment  on  the  transboundary 
impacts of measures. 

to 

understand 

The  level  of  information  was  not 
sufficient 
the 
implementation  process  and  the 
monitoring  and  measures’  follow-
up actions.  

Socio-economic 
assessment 

Interactions 
with climate 
change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public 
consultation and 
administrative 
process 

The  selection  of  the  measures  relies  on  a  four  steps 
approach defined by Portugal and clearly described in the 
programme of measures.  

The  programme  of  measures 
includes  measures 
designed to enhance the resilience of marine ecosystems 
and  are  part  of  an  integrated  response  to  the  overall 
climate change issues.  

Portugal takes into consideration the different measures 
carried  out  under  other  EU  policies,  notably  WFD,  CFP, 
BHD,  and  MSP  while  updating  the  programme  of 
measures 

Regional cooperation was carried out on two levels.  

On  regional  level  through  OSPAR  Convention.  Portugal 
adopted the Environmental Strategy for the Protection of 
the North-East Atlantic and participated in the technical 
and coordination groups of OSPAR. 

Trilateral meetings were organised with France and Spain 
in order to adopt measures of a cross-border nature (e.g. 
management of MPAs, marine litter, etc.) 

Portugal carried out public consultation at regional and 
national levels.   

The methodology that aimed to incorporate the views of 
the  different  stakeholders  into  the  final  programme  of 
measures is presented.  

Information  on  the  different  competent/responsible 
authorities in charge of implementing and coordinating 
the implementation of the programme of measures as 
the  information  regarding  the  stakeholder  process,  the 
organisation  of  specific  consultation  and 
raising 
awareness activities are provided.  

219 

 
 
 
 
 
 
 
 
The adequacy of Portugal’s programme of measures to address 
pollution issues is considered poor.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

The adequacy of Portugal’s programme of measures for D5 is considered moderate. 

-  Portugal has identified some updates to existing measures, including measures linked to 

the WFD reporting.  

-  Portugal presents an operational target referring to a reduction in the level of pressure 

for Macaronesia. 

-  No information is presented on progress towards GES, although it is noted that GES is 

reported as achieved under Article 8.    

-  Portugal relies mainly on existing measures to maintain GES for D5. However, there are 
notable gaps and some inconsistencies in the reporting and there is no information on 
how updated existing measures contribute to the maintainance of GES. 

-  Portugal has not presented a detailed gap analysis and it is unclear whether all significant 

gaps to achieve MSFD targets and GES have been identified.  

-  In  2016,  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed  and  that  the  measures  partially  addressed  the  components  of  GES  and 
targets. 

-  In  2022,  the  assessment  considers  that  coverage  of  relevant  pressures  and  of  the 
components of GES and targets was not relevant as no modified or additional MSFD 
specific measures specific to D5 have been identified. 

The adequacy of Portugal’s programme of measures for D8 is considered poor 

-  Portugal has undertaken a gap analysis to identify where additional measures might be 

required to address pressures. 

-  There  are  notable  gaps  and  some  inconsistencies  between  e-reporting  and  the  text 

reports. 

Weaknesses 

-  The gap analysis is only qualitative and not quantitative. 
-  Portugal has not provided information on how updated existing measures contribute to 

the achievement of GES. 

-  There is no reference to the Zero Pollution targets and to the updates of the National 

Emissions Ceiling Directive.   

-  In 2016, the assessment considered that coverage of pressures and the components of 
GES and targets had been partially addressed. As no modified/ additional MSFD specific 
measures  specific  to  D8  have  been  identified,  in  2022,  the  coverage  assessment  of 
relevant pressures and of the components of GES and targets is not performed. 

-  The gaps identified in 2016 remain.  

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

Strengths 

-  The adequacy of Portugal’s programme of measures for D9 is considered poor 

-  Portugal has undertaken a gap analysis to identify where additional measures might be 

required to address pressures. 

220 

 
 
 
 
 
 
 
-  There are notable gaps and some inconsistencies between the e-reporting and the text 

reports. 

Weaknesses 

-  The gap analysis is only qualitative and not quantitative.  
-  There are no links between relevant measures for D8 and D9.  
-  Portugal has not provided information on how updated existing measures contribute to 

the achievement of GES. 

-  There is no reference to the Zero Pollution targets and to the update of the National 

Emissions Ceiling Directive.   

-  The summary report does not mention why the measure has been withdrawn. 
-  In  2016  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed. In 2022, as no modified or additional MSFD specific measures specific to D9 
have been identified the assessment of the progress is not possible.  

-  In 2016, it was considered that the measures partially addressed the components of GES 
and targets.  In 2022, the assessment considered that the coverage of the components 
of  GES  and  targets  was  not  relevant  as  no  modified  or  additional  MSFD  specific 
measures specific to D9 have been identified. 

The adequacy of Portugal’s programme of measures for D10 is considered moderate 

-  Portugal referred in its programme of measures to the EU Port Reception Facilities and 

the Common Fisheries Policy for sea-based litter. 

-  Portugal describes the methodology for selecting additional MSFD specific measures in 

its programme of measures. 

-  Reference is made to the OSPAR Regional Action Plan for Marine Litter 
-  Adequate  detail  is  provided  on  how,  when  and  where  the  new  measures  will  be 

implemented.  

-  There is no gap analysis reported for D10, so it remains unclear what the current status 
of marine litter is, what the contribution of the first cycle measures to achieving GES is, 
and where the main gaps are situated and how the second programme of measures 
aims to address all those aspects.  

-  Several  of  the  new  targets  set  forward  by  Portugal  to  achieve  GES  for  D10  are  not 

supported by new measures. 

-  The additional MSFD specific measures are only indirectly aiming to prevent further litter 
input  in  the  marine  environment,  so  it  remains  unclear  how  GES  is  expected  to  be 
achieved through these measures. 

-  Recent EU-level developments such as the Zero Pollution Action Plan and the EU beach 

litter threshold are not included in the programme of measures. 

-  In  2016,  Portugal  was  considered  to  partially  address  the  relevant  pressures  and 

activities related to D10, which is still the case in the 2022 reporting.  

-  In  2016,  the  measures  partially  addressed  GES and  targets.  This  remains  largely  the 

same in the 2022 reporting,  

-  Similar as in 2016, Portugal includes clear timelines for the new measures in its second 

programme of measures but fails to report when GES will be achieved. 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Portugal’s programme of measures for D11 is considered moderate 

Strengths 

-  Portugal refers to the work of OSPAR and the North East Atlantic Environmental Strategy 
2020-2030, the methodology proposed by the Commission’s Technical Group on Noise.  

221 

 
 
 
-  The additional MSFD specific measure will aim at directly reducing existing levels of the 

pressure in the marine environment and improve knowledge base.  

-  The  regional  project  “Jonas  –  Joint  Framework  for  Ocean  Noise  in  Atlantic  Seas”, 
which developed  an  approach  to  assess  the  risks  of  acoustic  pressures  on  marine 
biodiversity and to improve ocean noise monitoring is mentioned in the programme of 
measures. 

-  No  gap  analysis  is  provided  and  there  is  no  information  on  the baseline,  the  current 

status, the contribution of the first cycle measures to achieve GES for D11. 

-  No measure is implemented in the Madeira area. 
-  The programme of measures is lacking any active measures addressing impulsive noise. 
-  No progress in Portugal's programme of measures has been identified since 2016.  
-  In 2016, Portugal was considered to partially address the pressures relevant to D11, the 

GES determination and targets. In the second cycle, the same gaps remain. 

Weaknesses 

Progress since 2016 

The  adequacy  of  Portugal’s  programme  of  measures  to  address 
biodiversity issues is considered poor.  

D1 — Biodiversity 

Adequacy 

The adequacy of Portugal’s programme of measures for D1 is considered moderate 

-  All additional measures from other initiatives are well reported, and Portugal provides 

details on their objectives and how they will contribute to GES.  

-  The reason for withdrawing one of the two measures is well explained. 
-  A good amount of information is provided on each measure in both the e-reporting and 

Strengths 

the text report.  

-  The  measures are  assessed  to directly  address  relevant  pressures,  as  well as  directly 

covering operational environmental targets. 

-  The implementation of the measures is well described: where and when the measures 
will be implemented, and the location to a detailed scale is included for the measure 
linked to the implementation of MPAs. 

-  The gap analysis is very poor as the programme of measures only provides the method 
used  to  determine  new  measures.  There  is  no  information  reported  on  any  gaps  to 
progress to GES or on the current environmental status for any of the six biodiversity 
species groups.   

-  The justification for the updating of existing measures and the introduction of additional 

measures from other initiatives is partially adequate.  

-  Two measures are focused on the acquisition of knowledge, and do not directly address 
relevant pressures or targets. Their benefit, although recognised, is envisaged on a long-
term  basis  as  they  will  not  likely  lead  to  the  achievement  of  GES  within  the  MSFD 
timeframe.   

-  Details are missing with regard of the MPA measures: how it will be implemented, which 
human activities will be restricted. The conservation objectives of these proposed MPAs 
could also be made clearer providing details on the species and habitats which are to be 
protected.   

-  The  new  updated  and  additional  measures  introduced  in  the  second  programme  of 
measures are unlikely to allow Portugal to achieve GES within the MSFD timeframe. 
-  The progress made between the first and the second programme of measures is difficult 
to assess due to the lack of gap analysis but it seems that no progress is made as new 

222 

Weaknesses 

Progress since 2016 

 
 
 
 
 
measures introduced in the programme of measures do not cover the gaps identified in 
the previous assessment.  

D2 — Non-indigenous species 

Adequacy 

-  The adequacy of Portugal’s programme of measures for D2 is considered moderate 

Strengths 

-  The cross-cutting modified existing measure reported by Portugal has the potential to 

indirectly reduce the pressures relating to D2. 

-  Several  new  targets  to  achieve  GES  have  been  set  for  the  second  programme  of 

measures.  

-  Adequate  details  are  provided  on  how,  when  and  where  the  new  measures  will  be 

implemented.  

-  The method behind selecting new measures is thoroughly described in the programme of 

measures,  

-  No gap analysis is provided so the programme of measures does not include information 
related to the baseline or the contribution of the first cycle measures to achieving GES for 
D2C1. 

-  No pathways of NIS introduction, which require to be addressed, were identified in a gap 

Weaknesses 

analysis. 

-  Some  modified  new  measures  aim  to  increase  knowledge  and  monitoring  of  the 
introduction and impact of NIS in Portugal's waters. However, they will not directly reduce 
the pressures relating to D2. 

-  No measures specifically address the pathways of introduction.  
-  In 2016, Portugal was considered to not address the pressures relevant to D2 with the 
identified  measures.  In  2022,  there  are  still  no  measures  which  address  specific 
pathways; the measures aim to increase knowledge base.  

-  In 2016, Portugal was considered to partially address GES determination and targets. In 
2022,  new  targets  have  been  set  for  each  sub-region,  however,  the  measures  only 
partially cover the targets. It is unclear how GES will be achieved/maintained since not all 
targets were linked to the new measures. 

Progress since 2016 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Portugal’s programme of measures for D3 is considered poor 

Strengths 

Weaknesses 

Progress since 2016 

-  The updates to existing measures are identified, including to the Common Fisheries Policy, 
the EduMar programme, and a number of measures are withdrawn or merged into the 
CFP measure. 

-  The overall approach for defining the second cycle of measures is presented. 
-  Portugal  has  withdrawn  one  new  measure  from  the  first  cycle  and  has  provided  an 

adequate justification. 

-  Portugal does not provide a clear gap analysis for D3 in its second cycle.  
-  The programme of measures does not detail the specific gaps relating to D3. 
-  Portugal does not provide any baseline, information on progress to GES or environmental 

targets. 

-  One modified new measure is considered to be a generic/cross-cutting measure and not 

specifically focused on achieving GES for D3.  

-  In 2016, Portugal's report was considered to adequately address relevant pressures. The 

programme of measures was considered to partially address GES and targets.  

-  In  2022,  no  modified  or  additional  MSFD  specific  measures  were  reported  that  were 
specific to D3. As one existing measure is withdrawn it is not clear whether pressures will 
continue to be adequately addressed. 

223 

 
 
 
D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Portugal’s programme of measures for D4 is considered moderate 

-  The  programme  of  measures  presents  a  flow  chart  of  the  process  undertaken  to 

determine the need for new measures, 

-  The justification for the withdrawal of one measure under D4 is clear. 
-  Reporting on the practicalities of the measures is a stronger point in the programme of 
measures. Details of when and where the measure will be implemented are provided.  
-  Portugal includes a list of possible locations for the proposed MPAs where habitats of 

importance have been identified. 

-  The explanation of updates made to existing measures is inadequate. It is not clear how 
the measure has been updated, and how the update will help progress towards GES for 
D4.  

-  The gap analysis is also considered inadequate, with most of the requested information 

not provided. 

-  The  lack  of  gap  analysis  limits  the  ability  of  any  of  the  measures  which  have  been 

proposed in the programme of measures to make real progress towards GES. 

-  There is no update on the current environmental status, on the progress towards targets 

and on the gaps identified.  

-  The measure is focused on spatial protection and could be described as more suitable for 
D1 than D4, which requires more specific measures to focus on threatened trophic levels. 
-  Portugal does not provide enough details on the activities to be managed/restricted or on 

the species and habitats to be protected. 

-  The lack of quantification of the size of the planned MPAs and the size of the target for 

protected areas increases the difficulty in monitoring progress towards GES.  

-  Information on how the measure will be implemented is not complete.  
-  It is difficult to determine overall progress since the first cycle. 
-  No improvement has been made as no gap analysis has been performed for D4, meaning 

that the ability of measures to help progress towards GES is limited.  

The adequacy of Portugal’s programme of measures for D6 is considered poor 

-  The reason for the introduction of new measures is well justified in the programme of 

measures.   

-  The practicalities of the new updated and additional measures are adequately presented 

by Portugal.   

-  Portugal provides detailed information on the measures regarding the specific locations 
where  the  actions  will  take  place,  as  well  as  when  and  how  the  measure  will  be 
implemented.  

-  A gap analysis is not provided, only a designation of new measures is briefly mentioned. 
The  justification  on  the  updates  to  the  modified  existing  measure  is  not  provided. 
Therefore, Portugal does not justify why these updates will help improve the measure 
and to contribute towards achieving GES. 

-  Given the lack of data on benthic communities across Portuguese waters, the removal of 

the associated measure is not justified in the programme of measures.  

-  The  links  between  new  updated  and  additional  measures,  and  pressures  and 

environmental targets are considered inadequate. 

-  No relevant pressures for D6 are reported in the programme of measures.  

224 

 
 
 
-  All the new updated and additional measures reported under D6 focus on knowledge 
acquisition and will therefore not have short-term and immediate positive impacts on 
threats such as biological and physical loss and disturbance.  

-  The measures reported will be implemented on a small scale, for the most part, which 

will limit their contribution to GES further.  
-  Little progress has been made under D6.  
-  In 2016, it was considered that the measures under D6 did not adequately address the 
relevant pressures, and the measures only partially contributed towards the achievement 
of environmental targets. The same conclusions can be drawn from the assessment of 
the second cycle.  

Progress since 2016 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Portugal’s programme of measures for D7 is considered moderate. 

Strengths 

Weaknesses 

Progress since 2016 

-  The overall approach for defining the second cycle of measures is presented in the text 

report. 

-  Adequate detail is provided on how, when and where the modified and additional MSFD 

specific measures will be implemented. 

-  Portugal partially explains how the additional MSFD specific measure will contribute to 

meet the operational environmental targets. 

-  No information is presented on progress towards GES, although it is noted that GES is 

reported as achieved under Article 8.    

-  The information provided for D7 is generally limited or not specific enough. 
-  Portugal neither provides adequate assessment of existing or future pressures that could 
be relevant for D7, nor a clear assessment of the gaps in the first cycle programme of 
measures that should be addressed in the updated programme of measures.  

-  Modified  and  additional  MSFD  specific  measures  reported  by  Portugal  in  its  updated 
programme of measure for D7 do not adequately address relevant pressures as they aim 
at improving the knowledge base. 

-  In 2016, the assessment considered both coverage of pressure and coverage of GES and 
targets as not addressed. The gaps and weaknesses assessed in 2016 are still visible in 
the  2022  report  as  all  measures,  modified  or  additional  are  only  focusing  on  the 
development of the knowledge base.  

Based  on  the  information  reported  in  their  programmes  of  measures,  Portugal’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as “high”. 

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

Key 
3: 
Factor 
Coordination  with  EU 
regional 
policies  and 
coordination 

Only  one  new  measure 
subjected to CEA. Did not refer 
to social issues investigated. 

three  main 
Presented 
sources:  national 
funds, 
European  funds  (e.g.  the 
LIFE+  programme,  Horizon 
and 
EMFAF, 
2020, 
international  funding  such 
as JPI Oceans, EEA Grants, 

The  second  Programme  of 
Measures 
considered 
different  measures  carried 
out  under  the  WFD,  MSP, 
HBD. 
and 
CFP 
Responsible/competent 
authorities 

the 

for 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where: Measures for seven 
Descriptors (D1, D2, D4, D6, 
D7,  D10  and  D11)10  have 
information  on 
sufficient 
For 
coverage. 
spatial 
example,  the  measure  for 
identify, 
study, 
D1 

to 

225 

 
 
 
 
 
stated 
The  MS 
etc. 
mobilizing 392 million EUR 
(for  the  period  of  2021  - 
2027) from EMFAF. 

and 
implementation 
coordination 
the 
measures were presented.  

of 

on 

two 

Coordination 
with 
neighbouring countries was 
done 
levels: 
regionally  via  OSPAR  and 
trilaterally  with  France  and 
Spain. 
Trilateral  work 
enabled the identification of 
regional 
national 
and 
objectives  which  required 
cooperation 
sub-regional 
transboundary 
and 
measures 
(e.g.  
management of MPAs).  

and 
characterize 
georeference 
marine 
habitats  and  biocenoses  is 
applicable  to  the  Madeira 
archipelago. 

have 

How:  Measures  for  four 
Descriptors  (D2,  D7,  D10, 
sufficient 
D11) 
on 
information 
while 
operationalisation, 
measures 
three 
for 
Descriptors  (D1,  D4,  D6) 
have partial information.  

When:  Measures  for  seven 
Descriptors (D1, D2, D4, D6, 
D7,  D10  and  D11)11  have 
sufficient 
information  on 
temporal scope. 

6.15 Romania  

Summary: 

Overall, the second programme of measures presented by Romania is considered as not adequate to address the pressures 
acting on the Romanian marine environment.  

In terms of strengths, Romania uses a CEA and a CBA for selecting its measures.   Cooperation with neighbouring countries, 
especially Bulgaria, is taking place via bilateral agreements and transboundary impacts of new measures were assessed 
and communicated to neighbouring countries through the Black Sea Commission and the Bucharest Convention.  Measures 
for marine litter have been assessed as adequate to address the pressures. It is also positive that in its 3rd RBMP reporting 
exercise under the WFD, Romania pays also attention to the objectives of the MSFD and includes those addressing e.g. 
aquaculture industry, preserving the morphological status of the Romanian Black Sea coast, sturgeon species (protection 
measures for sturgeon, preservation and restoration of ecological corridors) to mention just a few. 

On  the  downside,  Romania  provides  very  few  details  regarding  governance  mechanisms  and  financing  sources. 
Coordination  between  different  authorities  and  policies  and  their  impact  on  the  new  measures  is  not  described.  Only 
measures  for  litter  have  been  considered  as  adequate  to  address  pressures,  those  for  eutrophication,  biodiversity, 
commercial fish and hydrological conditions only moderately adequate and those for contaminants and noise particularly 
insufficient. 

Based on the information reported in their programmes of measures, Romania’s commitment to the implementation of 
their second programme of measures has been assessed as ‘medium’. 

The adequacy of Romania’s programme of measures for cross-cutting issues  is 
considered poor. 

The  updated  of the  programme  of  measures presented  little  information  on the process  followed 
which makes it challenging to compare the results with the previous cycle assessment. In most cases, 
uncertainty  existed  on  the  methodology/results  applied/reported.  The  updated  programme  of 

226 

 
 
 
 
 
measures not in accordance with the MSFD reporting guidelines, in terms of structure to be followed 
and information to be reported. 

Topic 

Strengths 

Weaknesses 

Socio-economic 
assessment 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

The methodology followed for CBA and CEA 
is not provided. 

The  programme  of  measures  provides 
information  on 
categories  and 
cost 
qualitative information on benefits only for 
two  new  measures.  Uncertainty  exists 
regarding  the  reason  for  not  providing 
information  on  costs  and  benefits  for  the 
other 29 new measures. 

Romania does not present any indication of 
investigating specific social issues 

in 

There was no reference to climate change 
considerations 
the  programme  of 
measures.  On  the  contrary,  Romania’s  3rd 
RBMP  has  a  dedicated  chapter  on 
quantitative aspects and climate change. 

Ambiguity  on 
the  mechanisms  and 
outcomes  of  coordination  between  MSFD 
and  the  mentioned  directives  and  policies 
exists as it was not presented nor described 
in the programme of measures. 

The programme of measures is not clear on 
the coordination with other EU legislations 
and  in  particular  on  how  it  impacted  the 
measures selected. 

Romania  does  not  provide  any  additional 
information on the amounts mobilized from 
each source (national or European), nor on 
the distribution of funds making it difficult 
to  understand  the  relative  share  allocated 
for each sector/descriptor 

More precision is needed in the programme 
of  measures  on 
i)  how  views  of 
neighbouring  countries  were  considered  in 
the  final  programme  of  measures,  ii)  key 
types  of  measures  responsible  for  the 
transboundary 
iii)  main 
descriptors impacted by the programme of 
measures. 

impact,  and 

The  same  methodology  for  measures’ 
selection as the first cycle was followed for 
the second cycle. 

A  Cost-Effectiveness  Analysis  (CEA)  and  a 
Cost-Benefit  Analysis  (CBA)  is  used  for  the 
identification of the new measures. 

Information  on  stakeholder  processes  and 
organization  of  specific  consultation  with 
stakeholders as well as raising awareness. 

Coordination  between  MSFD  and  other  EU 
policies, notably WFD, MSP, CFP, and BHD, is 
reported  in  the  updated  programme  of 
measures.  This  is  confirmed  by  the  RBMP 
assessment  which  confirmed  that  the  3rd 
RBMP pays attention to the objectives of the 
MSFD  and  includes  those  addressing  e.g. 
aquaculture 
the 
morphological status of the Romanian Black 
Sea coast. 

preserving 

industry, 

Other  EU  and  international  directives  and 
policies/legislations  such  as  EU  nitrates 
directive,  EU  Biodiversity  Strategy,  EU  EIA, 
Convention on Biological Diversity, and Black 
Sea Convention were also considered in the 
programme of measures. 

taking  place 

Cooperation  with  neighbouring  countries  is 
mainly 
through  Bilateral 
Agreements.  Romania  coordinated  with 
Bulgaria  for  developing  and  implementing 
16 joint measures. 

Transboundary  impacts  of  new  measures 
were  assessed  and  communicated 
to 
neighbouring countries through the Black Sea 
Commission. 

227 

 
 
 
 
 
 
 
indication  of  the 
Romania  provides  an 
responsible/competent  authorities  for  the 
implementation  and  coordination  of  each 
measure  at  different 
(regional, 
national),  as  well  as  the  time  frame  of 
implementation for each measure. 

levels 

Public consultation 
and administrative 
process 

the  public 
information  on 
Additional 
consultation  process  (aspects  discussed, 
results 
consultation, 
stakeholders’  views),  that  allows  better 
understanding, is still needed. 

public 

the 

of 

On  the  contrary,  in  its  RBMP,  Romania 
detailed  the  consultation  processes  and 
included  a  chapter  on  public  information, 
consultation  and  participation  which 
includes 
the  public 
results  of 
the 
consultation.  

Romania  does  not  provide  a  detailed 
description  of  the  role  of  each  competent 
authority,  nor  of 
follow-up  and 
the 
monitoring of measures. 

The  adequacy  of  Romania’s  programme  of  measures  to  address 
pollution issues is considered poor.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

-  The adequacy of Romania’s programme of measures for D5 is considered moderate 

-  A gap analysis was undertaken.  
-  There  is  a  reasonable  assessment  of  the  current  status  and  what  level  of  nutrient 

reduction might be needed to achieve GES. 

-  The effect of climate change in exacerbating eutrophication impacts is acknowledged. 
-  A  range  of  measures  are  planned  to  address  key  pressures  contributing  to 
eutrophication,  agriculture,  urban  activities,  industry,  shipping  and  port  operations  as 
tourism and recreation. 

-  Romania did not make an update to its programme of measures for D5 in the second 

cycle.  

-  The effectiveness of the measures and how the individual measures will contribute to 
the  achievement  of  GES  is  not  presented  in  the  programme  of  measures.  This  is  of 
particular importance as the RBPM assessment highlighted that nutrient pollution and 
organic pollution are the most significant pressures affecting the highest percentage of 
surface water bodies.  

-  Many of the measures are yet to be implemented. 
-  In 2016, the assessment considered that coverage of pressures had been addressed. In 
2022, there is no update to the measures, despite the gaps identified in the gap analysis. 
-  In 2016, the assessment considered that the assessment addressed all components of 
GES and targets. In 2022, as no updates were made to the measures, it is impossible to 
assess the progress made between the two cycles. 

The adequacy of Romania’s programme of measures for D8 is considered very poor 

-  Romania continues to rely on the same measures from the first cycle which partially 

addressed the pressure and activities.  

228 

 
 
 
 
 
 
 
 
Weaknesses 

Progress since 2016 

-  No information is provided on updates/changes to existing measures. 
-  The assessment of the status is limited and there is no indication of specific pressures 

or substances of concern. 

-  The effectiveness of existing measures is not included in the programme of measures.  
-  Many of the measures are yet to be implemented. 
-  There is no systematic analysis of how the individual measures will contribute to the 

achievement of GES. 

-  In  2016,  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed.  In 2022, as no modified or additional measures are identified, the progress 
assessment is not performed.  

-  In  2016,  the  assessment  considered  that  the  assessment  partially  addressed  all 
components of GES and targets. In 2022, as no modified or additional measures from 
other  initiatives  have  been  identified,  it  is  impossible  to  assess  the  progress  made 
between the two cycles. 

D9 — Contaminants in seafood 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Romania’s programme of measures for D9 is considered poor. 

-  GES was reported as achieved under Article 8. 
-  The updates and changes are broadly focused on reducing contaminant pressures and 

will also contribute to reduce new contaminants impacting fish/shellfish (D9) 

-  There is a limited assessment of the current status of the measures and no indication 
of  specific  pressures  or  substances  of  concern.  No  information  is  provided  on 
updates/changes  to  existing  measures,  although  there  could  be  some  relevant 
updates/changes to measures within RBMPs and measures required in relation to the 
National Emissions Ceiling Directive.  

-  No modified and additional MSFD specific measures have been identified relevant to D9 
-  Many of the measures are yet to be implemented. 
-  In  2016,  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed.  In 2022, as no modified or additional MSFD specific measures have been 
identified, no progress assessment is reported.  

-  In  2016,  the  assessment  considered  that  the  assessment  partially  addressed  all 
components of GES and targets. In 2022, as no modified or additional MSFD specific 
measures have been identified, no progress assessment is reported.  

The adequacy of Romania’s programme of measures for D10 is considered good. 

-  Romania has included a few measures for the second cycle of measures. 
-  A brief mention of the gap analysis and the status GES for the Black Sea is provided in 

the programme of measures. 

-  The  reported  new  measures  for  D10  in  Romania's  second  cycle contain  the  required 

information on how, when and where they will be implemented. 

-  Romania uses the EU Beach Litter threshold value as adopted by MSCG in 2020 as 

indicator for assessing macrolitter on beaches (D10C1). 

-  It is unclear whether some of these measures are modified from the first cycle. 
-  The existing measures are briefly mentioned in the programme of measures.   
-  The set of modified and additional MSFD specific measures tackles some but not all of 

the main litter sources in Romania's Black Sea. 

-  Romania still does not include dedicated new measures in the second cycle for criteria 

D10C2. 

229 

 
 
 
 
-  No details on how the first cycle of measures contributed to the achievement of GES for 

marine litter. 

-  The first cycle of measures have yet to be fully implemented. 
-  Romania  does  not  include  dedicated  new  measures  to  address  the  pressures  of 

microlitter and litter ingested by animals. 

-  Romania's report on D10 in the second cycle remains the same as in the first cycle. No 

progress has been made. 

-  Regarding  the  coverage  of  pressures,  Romania  was  assessed  as  fully  addressing 
pressures in 2016. No further progress has been made despite a few new measures for 
D10 in the second cycle. 

-  Regarding coverage of GES and targets, Romania's first cycle measures were assessed 
as fully addressing GES and the targets. Romania only still focuses on macrolitter (beach, 
seabed, water column). 

Progress since 2016 

D11 — Underwater noise and energy 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Romania’s programme of measures for D11 is considered very poor 

-  Romania continues to rely on the same measures from the first cycle which partially 

addressed the pressure and activities. 

-  Romania does not report any additional MSFD specific measures.   
-  The implementation description is very vague and lacks important details. 
-  No gap analysis is provided for D11, GES and targets are not defined and the status 

assessment for D11 is not carried out. 

-  The  programme  of  measures  is  not  clear  on  how  the  measures  could  contribute  to 

achieving GES for D11.  

-  It is not clear from the updated programme of measures if the measures have been 

successfully implemented as there is no mention of underwater noise 

-  Romania seems to have made little progress regarding D11. 
-  It is not clear from the updated programme of measures if these measures have been 

Progress since 2016 

successfully implemented.  

-  Regarding the targets, these are not defined for D11 under Article 10, so no progress 

seems to have been made.  

The adequacy of Romania’s programme of measures to  address 
biodiversity issues is considered poor.  

D1 — Biodiversity 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Romania’s programme of measures for D1 is considered poor 

-  Most of the additional MSFD specific measures aim to increase knowledge, monitoring and 

rise awareness.  

-  The geographical scope of the measures is considered adequate. The objective, monitoring, 

increase knowledge and raise awareness aspects of these measures are addressed. 

-  The gap analysis is a weakness, most requested information is not provided.  
-  Gaps  in  progress  towards  GES  and  targets  are  not  identified,  which  makes  it  almost 
impossible to assess if the measures reported are adequately addressing all the pressures 
and gaps. 

-  The reporting of new measures is insufficient. The measures mainly focus on marine litter 

but do not mention other pressures negatively affecting biodiversity. 

230 

 
 
 
 
 
 
-  The implementation mechanisms are insufficiently described, lacking key details such as 
how much budget is mobilised for the implementation of the measures, how coordination 
will be carried out, and the mode of action of most of the measures. 

-  The implementation time frame is unclear, with only one measure already implemented.  
-  The  2022  programme  of  measures  presents  no  progress  regarding  the  coverage  of 

pressures.  

Progress since 2016 

-  Regarding  the  coverage  of  environmental  targets  and  GES,  the  first  cycle  assessment 
considered GES and target as partially addressed by the measures. In 2022, no progress 
seems to be made in this regard. The modified and additional MSFD specific measures only 
contribute partially to the targets reported for D1. 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Romania’s programme of measures for D2 is considered moderate. 

Strengths 

Weaknesses 

Progress since 2016 

-  A gap analysis is performed for D2. 
-  New actions to be implemented under the MSFD’s second cycle, building on measures 
established during the first cycle, have been mentioned as having the potential to address 
the environmental objectives not achieved in the first cycle.  

-  These  include  establishing  the  number  of  newly  introduced  non-native  species  and 

generating a list of them to track their evolution in the future 

-  There is little/no information on the number of introductions during the period of 2012-
2017. Baseline scenario and the identification of the different pathways of introduction 
are not provided. 

-  Romania has not implemented any new existing or second cycle of measures for D2. 
-  The first cycle measures have yet to be fully implemented. 
-  Regarding the coverage of pressures, Romania was assessed as fully addressing pressures 
in 2016. Progress has not been made as no new measures were reported in the second 
cycle. 

-  Regarding coverage of GES and targets, Romania's first cycle of measures was assessed 
as fully addressing GES and the targets. In 2022, no progress is made as the measures 
do not focus on reducing relevant pressures and impacts for D2. 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Romania’s programme of measures for D3 is considered poor. 

Strengths 

-  Romania provided details on how, where and when the additional MSFD specific measures 

addressing marine aquaculture in the Black Sea will be implemented.  

-  The modified and new measures do appear to be linked to an operational environmental 

Weaknesses 

Progress since 2016 

target. 

-  Romania  has  not  provided  information  on  whether  their  measures  contribute  to  the 
achievement of GES and environmental objectives due to delays in the implementation of 
their first cycle. 

-  The text report is brief and does not provide details on the results of the gap analysis. 
-  There are discrepancies between the e-reports and the text, which results in their updated 

programme of measures being unclear and inadequate for several metrics. 

-  In 2022, coverage of pressures by modified and additional MSFD specific measures is 
assessed as being 'not clear'. A gap identified in the first cycle assessment was the lack 
of measures explicitly addressing recreational fishing, and Romania has still not explicitly 
addressed this aspect in their updated programme of measures.  

-  In 2016, the programme of measures was considered to address all components of GES 
and targets for D3. In the second cycle, it is unclear whether improvements have been 
made. 

231 

 
 
 
D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

The adequacy of Romania’s programme of measures for D4 is considered poor 

-  The practicality of the new measure is provided in the programme of measures.  
-  The geographical scope of the presented measures is considered adequate, taking into 
account the aim of the D4 measures, for which adequate monitoring tools are presented.  
-  No  update  of  existing  measures,  nor  withdrawn  of  measures  is  reported.  No  spatial 

protection measures are presented. 

-  The  gap  analysis  is  not  provided  for  descriptor  4.  Gaps  in  progress  towards  GES  are 
therefore  not  identified,  which  makes  it  difficult  to  assess  if  the  measure  reported  is 
adequately addressing all the pressures and gaps relevant to achieve GES.  

-  The  measure  identified  is  indirect  and  follow-up  measures  are  necessary  to  directly 

address the reduction of pressures on food webs.  

-  The implementation mechanisms are insufficiently described, lacking details such as how 

coordination will be carried out and the mode of action of most of the measures.  

-  The implementation time is uncertain, as the implementation has not started yet and what 

will happen after 2024 remains unclear. 

-  The  assessment  of  the  first  cycle  made  different  conclusions  for  each  of  the  species’ 
groups covered under descriptor 4 when addressing pressures and coverage of targets but 
the  pressures  were  mainly  addressed.  In  2022,  no  progress  is  made  regarding  the 
coverage of pressures.  

-  In  2016,  measures  addressed  GES  and  targets  partially. In  2022,  no  progress  was 
registered in this regard. The modified and additional MSFD specific measure is reported 
to be not relevant to the Descriptor 4 target. 

-  The  text  report  stated  that  only 4  of  the  29  measures  from  the  first  cycle  have  been 

implemented, so progress is limited. 

The adequacy of Romania’s programme of measures for D6 is considered poor 

Strengths 

-  Romania reported the practicalities of the new measures. 
-  The geographical scope of the measures is considered partially adequate, as there is no 

further indication of the areas, habitats, or species to be monitored.   

-  This descriptor does not assign its own targets and is assessed under descriptor 1.  
-  No update of existing measures and no spatial protection measures are presented.  
-  Gaps in progress towards GES are not identified, which makes it difficult to assess if the 
measure reported is adequately addressing all the pressures and gaps relevant to achieve 
GES. 

-  The measure does not address relevant pressures for D6 directly but focus on monitoring, 
therefore follow-up measures are necessary to directly address the reduction of pressures 
and ensure sea-floor integrity. 

-  The implementation mechanisms are insufficiently described, lacking key details such as 

how coordination will be carried out and the mode of action of the measure. 

-  The implementation time frame is uncertain, as the implementation has not started yet 

and what will happen after 2024 is not clear. 

-  It is difficult to assess whether any progress has been made since 2016 as not enough 

detail is provided. 

-  However,  it  is  stated  that  only  4  of  the  29  measures  from  the  first  cycle  have  been 
implemented, so progress is limited. There is also only one new measure under descriptor 
6. 

Weaknesses 

Progress since 2016 

232 

 
 
 
D7 — Hydrographical changes 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Romania’s programme of measures for D7 is considered poor 

-  Spatial  information  on  the  measures  is  clear  and  appropriate,  and the  organisation  in 

charge of implementing is specified. 

-  Romania has neither assessed the status of its waters for D7, nor the gaps to achieve GES 

or the environmental target.  

-  One of the additional MSFD specific measures reported by Romania is relevant to D7 but 

not listed as relevant for D7. 

-  Romania  provides  partial  information  regarding  the  implementation  details  for  the 

measures. 

-  No clear forward-looking plan is presented for the measures which have not started yet.   
-  The  first  cycle  programme  of  measures  was  considered  adequate  for  D7.  No  positive 
progress  has  been  made  between  the  first  cycle  and  the  second  cycle  even  if  one 
additional MSFD specific measure was defined, which appears to be addressing relevant 
pressure. 

Based  on  the  information  reported  in  their  programmes  of  measures,  Romania’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as “medium”. 

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

Key 
3: 
Factor 
Coordination  with  EU 
regional 
policies  and 
coordination 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

clear 

CBA  and  CEA  of  all  new 
measures  but  only  presented 
results  for  two  measures  so 
not 
process 
influenced  measure  selection 
or  prioritisation.  Did  not  refer 
to social impacts of measures 
investigated.  

how 

2020, 

sources 

Presented 
different 
from 
financing 
national and European (e.g. 
LIFE 
Horizon 
EMFAF, 
Programme, 
Operational Programme for 
Large  Infrastructure)  funds. 
No  additional  information 
on the amounts that will be 
mobilised from each fund.   

CFP 

links 

Presented 
of 
measures  with  the  WFD, 
MSP, 
and  HBD. 
Mentioned  that  measures 
implemented  under  other 
EU directives, notably WFD 
and  HBD,  were  considered 
as 
"existing  measures" 
relevant for achieving GES. 

Coordination  was  done 
bilaterally with Bulgaria and 
via 
Bucharest 
the 
Coordination 
Convention. 
with Bulgaria resulted in the 
development 
and 
implementation of 16 joint 
measures, but no additional 
information  on  this  was 
provided.  

have 

Where:  Measures  for  four 
Descriptors  (D1,  D3,  D7, 
sufficient 
D10) 
information 
spatial 
coverage,  while  measures 
for  two  Descriptors  (D4, 
D6)12  only  have  partial 
information.  

on 

for 

two 
How:  Measures  for 
Descriptors  (D3  and  D10) 
have  sufficient  information 
on operationalisation, while 
four 
measures 
Descriptors (D1, D4, D6, D7) 
only 
partial 
have 
information. For example, it 
is unclear how much budget 
the 
is  mobilized 
for 
of 
implementation 
the 
for  D1,  how 
measures 
coordination  will be  carried 

233 

 
 
 
 
 
out, and the mode of action 
of most of the measures.  

temporal 

When:  Measures  for  two 
Descriptors  (D3  and  D10) 
have  sufficient  information 
coverage, 
on 
while  measures  for  four 
Descriptors (D1, D4, D6, D7) 
only 
partial 
have 
information. 

6.16 Sweden 

Summary: 

Overall, the second programme of measures presented by Sweden is considered to be adequate to address the pressures 
acting on the Swedish marine environment and contributes to achieving Sweden’s GES and targets.  

The completeness of the Swedish report is very good. The measures and their characteristics are clearly listed and the 
rationale  behind  any  change  is  well  presented.  Sweden  has  well  described  the  administrative  process  for  the 
implementation and follow-up of the measures and has put in place an implementation plan for each measure, which 
clarifies  and  times  sub-operations,  activities,  and  work  processes.  New  biodiversity  protection  measures are  identified, 
including a reduction in the area of trawl nets and increasing the use of selective and low impact gears. New marine 
protected areas and other spatial protection measures as proposed on a sufficient scale to support the achievement of 
GES. 

The links between MSFD and other relevant EU legislation are mentioned. However, the mechanisms and outcomes of 
coordination are not presented; additional information would be necessary. While the regional/international cooperation is 
clearly described, little information exists on the assessment of transboundary impacts of measures. Measures for noise 
and contaminants have been assessed as only moderately adequate to address pressures.  

Based on the information reported in their programme of measures, Sweden’s commitment to the implementation of their 
second programme of measures has been assessed as ‘high’. 

The  adequacy  of  Sweden’s  programme  of  measures  for  cross-cutting  issues  is 
considered good. 

The programme of measures has not experienced significant changes since the first cycle in terms of 
methods  applied  for  measure  selection,  reported  links  between  MSFD  and  other  policies,  regional 
and/or  international  policies,  and  public  consultation.  For  both  cycles,  Sweden  applied  the  same 
methodology. 

The programme of measures respected the MSFD reporting guidelines and provided all the needed 
information  notably  on  how  results,  from  different  methodologies,  influenced  measure  selection. 
However,  some  information  is  still  incomplete  such  as  for  example  information  concerning  the 
economic analysis and the link between MSFD and other EU legislations.  

Topic 

Strengths 

Weaknesses 

234 

 
 
 
 
 
 
 
Sweden does not provide any information 
on the usefulness of CBA and CEA results; 
additional information could have helped in 
better  understanding  the  results  of  the 
economic analysis. 

issues 

investigated  and 

Sweden  provides  partial  information  on 
social 
no 
information is provided on the methodology 
followed  nor  on  the  social 
indicators 
investigated. 

Sweden seems to go further in its 3rd RBMP 
reporting  exercise  by  emphasising  the 
importance of setting-up measures due to 
climate change and setting a requirement 
for all competent authorities to take climate 
change into account within their activities. 

Sweden does not provide any information 
on the mechanisms nor on the outcomes of 
cooperation. 

Sweden does not provide clear information 
impact 
on  whether  a 
assessment was undertaken or not.  

transboundary 

to 

Sweden  does  not  mention  the  level  of 
modification 
the  programme  of 
measures after the public consultation. It is 
not clear from the text if stakeholder views 
led to reviewing or removing some of the 
measures. 

The  programme  of  measures  does  not 
mention any change in the evolution of the 
administrative process to implement MSFD 
specific measures. 

Socio-economic 
assessment 

Interactions with 
climate change 

Links to other 
policies 

Regional 
cooperation and 
transboundary 
impact 

Public consultation 
and administrative 
process 

The  selection  of  measures  was  done  by 
following  a  four-step  approach  clearly 
presented  in  the  programme  of  measures. 
Sweden  undertook  a  CBA  and  CEA  for  all 
MSFD  specific  measures  and  provided 
information  on  cost  categories  considered 
and the estimated benefits. 

Climate change has been considered in the 
programme  of  measures  where  MSFD 
specific  measures  have  been  subject  to  a 
climate review. 

Sweden  mentions  links  between  the  MSFD 
and other EU legislations, namely WFD, MSP, 
and CFP. The programme of measures also 
referred  to  other  EU  policies  such  as  the 
REACH  directive,  the  EU  Environmental 
Damage  directive,  the  Single-use  plastics 
directive, etc. 

Cooperation with neighbouring countries was 
done  through  the  European  Commission, 
regional sea conventions as well as through 
bi-and multilateral contracts.  

Information  on  regional  cooperation  is  well 
reported in the programme of measures and 
the cooperation with neighbouring countries 
had  an  impact  on  the  selection  of  the 
measures. 

The  public  consultation  addressed 
the 
authorities,  municipalities,  organizations, 
operators,  the  general  public,  and  other 
stakeholders  concerned  by  the  programme 
of measures.  

Likewise,  the  timetable,  work  programme, 
consultation  plan,  overview  of  significant 
water  management  issues  and  the  draft 
RBMPs  were  subject  to  public  consultation 
for six months.  

The  administrative  process  to  make  the 
programme  of  measures  operational  was 
well presented. 

235 

 
 
 
 
 
 
 
 
The  adequacy  of  Sweden’s  programme  of  measures  to  address 
pollution issues is considered good.  

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

The adequacy of Sweden’s programme of measures for D5 is considered good. 

-  Sweden has identified updates/changes to the existing measures from the first cycle.  
-  Measures  have  been 

identified  addressing  the  key  pressures  contributing  to 

eutrophication. 

-  The modified and additional MSFD specific measures address relevant pressures. 
-  The modified and additional MSFD specific measures are linked to operational targets. 
-  Sweden has generally provided the necessary information on where, when, and how the 

modified and additional MSFD specific measures will be implemented. 

-  Sweden  does  not  clearly  describe  how  the updates/changes  to  the existing  measures 
contribute to achieve GES. This is regrettable, as the assessment of Sweden’s 3rd RBMPs 
concludes that implementation of measures to tackle nutrient pollution from agriculture 
needs to be accelerated as loads from agriculture represent 18-35 % of total nutrient 
load in coastal waters.   

-  A gap analysis has been carried out but little detail is provided. 
-  The gap analysis does not quantify the extent to which specific measures contribute to 
achieving GES. The assessment of Sweden’s 3rd RBMPs concludes that 80 % of coastal 
water bodies are not in good ecological status. 
-  Not all measures are linked to operational targets. 
-  The financing of the measures remains unclear in the programme of measures.  
-  In 2016, the assessment considered that coverage of pressures in the Baltic and North 
Seas had been partially addressed. In 2022, the assessment considers that all relevant 
pressures are addressed.  

-  Some progress has been made since 2016 in more clearly identifying relevant pressures. 

The measures continue to cover all relevant components of GES and targets. 

The adequacy of Sweden’s programme of measures for D8 is considered moderate 

-  Contaminant  pressures  and  relevant  measures  are  reasonably  well  understood  by 

Sweden. 

-  Measures have been identified to address the key pressures contributing to contaminants. 
-  All of the additional MSFD specific measures are linked to targets.  
-  Sweden has generally provided the necessary information on where, when, and how the 

additional MSFD specific measures will be implemented. 

-  Sweden has identified updates/changes to the existing measures from the first cycle but 

has not clearly described how these measures contribute to achieving GES. 

-  A  gap  analysis has been  carried  out but  little  detail is  provided  in  the  programme  of 

measures.  

Weaknesses 

-  The gap analysis does not quantify the extent to which specific measures contribute to 

achieving GES. 

-  Some of the additional MSFD specific measures do not appear to be targeted toward 
those  contaminants  that are  currently  causing  failure  of  GES  for  D8. According  to  the 
assessment of Sweden’s 3rd RBMPs, the measures in the Bothnian Bay and Bothnian Sea 

236 

 
 
 
 
 
should  in  particular  target  dioxins  and  furans  as  these  contaminants  are  the  primary 
substance causing EQS failures in coastal water bodies. More generally, Sweden should 
take all necessary measures to prevent the emissions of mercury and PBDE as well as 
perfluorooctanesulfonic acids (PFOS), Cadmium, Nickel, polyaromatic hydrocarbons (PAH) 
and tributyltin (TBT). 

-  Not all measures are linked to operational targets. 
-  The financing of the measures remains unclear in the programme of measures.  
-  In 2016, the assessment considered that coverage of pressures in the Baltic and North 
Seas had been partially addressed. In 2022, the assessment considers that all relevant 
pressures are partially addressed. 

-  In  2016,  the  programme  of  measures  for  the  Baltic  and  North  Seas  covered  all 
components  of  GES  and  targets.  Some  progress  has  been made  since  2016  in  more 
clearly identifying relevant pressures but there continues to be a lack of clarity concerning 
the specific impact that particular measures will have in making progress towards GES. 
The measures continue to cover all relevant components of GES and targets. 

Progress since 2016 

D9 — Contaminants in seafood 

Adequacy 

The adequacy of Sweden’s programme of measures for D9 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

Strengths 

-  Sweden has identified updates to the existing measures from the first cycle even if it has 

not clearly described how these measures contribute to achieve GES. 
-  All additional MSFD specific measures are linked to operational targets. 
-  Sweden has generally provided the necessary information on where, when and how the 

modified and additional MSFD specific measures will be implemented. 

-  A gap analysis has been carried out but little detail is provided. 
-  The gap analysis does not quantify the extent to which specific measures contribute to 

achieving GES.   

-  Some of the modified MSFD specific measures may contribute marginally to addressing 

the key pressures causing failure of GES for D9  
-  The financing of the measures remains unclear.  
-  The modified existing and MSFD specific measures are only likely to have a marginal 

beneficial impact 

-  In 2016, the assessment considered that coverage of pressures in the Baltic and North 
Seas had been partially addressed. In 2022, the assessment considers that coverage of 
relevant pressures was unclear. 

-  In 2016, the assessment considered that the assessments for the Baltic and North Seas 
covered all components of GES and targets. Some progress has been made since 2016 
in more clearly identifying relevant pressures but there continues to be a lack of clarity 
concerning  the  specific  impact  that  particular  measures  will  have  in  making  progress 
towards GES. 

The adequacy of Sweden’s programme of measures for D10 is considered good. 

-  Sweden reports the existing measures and provides clear links to relevant policies such 
as OSPAR North-East Atlantic Environment Strategy (NEAES) 2030 and HELCOM Baltic 
Sea Action Plan (BSAP) 2021-2030 as well as EU or national initiatives. 

-  The link to the overall objective of reducing litter input in the marine environment is clear. 
-  The  “gap’  related  to  the  problem  of  fisheries-related  litter  is  clearly  addressed by  the 

additional MSFD specific measures of the second cycle. 

237 

 
 
 
Weaknesses 

Progress since 2016 

-  For all MSFD specific measures, the reporting clearly mentions the spatial and temporal 

scope of the measures as well as how they will be implemented 

-  The gap analysis is considered partially adequate as, at least for beach litter, there is no 

clear mention of the measures still needed, and why.   

-  The additional MSFD specific measures mainly focus on the pressure macro litter and 
beach litter rather than micro-litter and seabed and surface litter which are important to 
cover in the programme of measures with dedicated measures. 

-  Not all relevant pressures are tackled with the programme of measures. 
-  Compared to the 2016 assessment, Sweden’s report on D10 Marine Litter for the Baltic 

Sea under Art. 13 has slightly improved and certain progress has been made. 

-  Regarding  ‘coverage  of  GES  and  targets’,  few  improvements  have  been  made  in 
Sweden’s programme of measures, since all measures reported are linked to the same 
two targets 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Sweden’s programme of measures for D11 is considered good 

Strengths 

Weaknesses 

Progress since 2016 

-  Sweden  identified  the  main  contributors  of  impulsive  noise  and  implement  existing 

measures to limit the impulsive noise from offshore wind construction. 

-  Sweden has created a new category 1.a measure to address continuous noise, prevent 
further  inputs  of  pressure,  reduce  existing  levels  of  pressure  and  establish  monitoring 
programmes.  

-  Impulsive noise seems to be covered fully with the various existing measures. 
-  The gap analysis does not provide enough details. 
-  With regards to continuous noise, there is still a lack of consensus on which sound levels 
produce a negative effect at population level. This complicates action work as it is not 
possible to assess the impact of measure.  

-  Sweden has not carried out a national assessment of the status of underwater noise. 
-  Some  progress  is  seen  in  the  coverage  of  pressures;  Sweden  addressed  the  relevant 

human activities causing underwater noise. 

-  There is no progress regarding the coverage of environmental targets. 

The  adequacy  of  Sweden’s  programme  of  measures  to  address 
biodiversity issues is considered very good. 

D1 — Biodiversity 

Adequacy 

Strengths 

The adequacy of Sweden’s programme of measures for D1 is considered very good 

-  Sweden proposes both updates to existing measures and a series of additional MSFD 
specific measures to address a full range of pressures, including the introduction of 
non-indigenous  species,  physical  loss  and  disturbance  of  the  seabed,  the  input  of 
nutrients and hazardous substances, and anthropogenic sound.   

-  All measures are aimed at the relevant spatial scale, with most being applied to both 

coastal and offshore waters. 

-  Where relevant, MSFD specific measures may also apply to terrestrial habitats. 
-  All measures are linked to targets. 

238 

 
 
 
 
 
 
Weaknesses 

Progress since 2016 

-  Few of the relevant targets are considered fully operational, leaving a gap between 

aspiration and delivery. 

-  Sweden’s score in 2022 for the coverage of pressures in the Baltic region and Greater 
North  Sea  remains  unchanged  since  2016,  with  this  being  considered  as  fully 
addressed. 

-  As in 2016 the assessment considered only updated or additional measures, and no 
measures are reported as being withdrawn, it is considered that progress has been 
made in addressing pressures through the programme of measures. 

D2 — Non-indigenous species 

Adequacy 

The adequacy of Sweden’s programme of measures for D2 is considered good 

-  Sweden  identifies  new  measures  from  other  initiatives  which  aim  to  reduce  NIS 

introductions in both the Baltic Sea and North Sea. 

-  Gaps for achieving GES under D2 were adequately identified within the programme 

of measures. 

Strengths 

Weaknesses 

Progress since 2016 

-  MSFD  specific  measures  developed  for  for  the  Baltic  and  the  North  Sea  aim  to 
produce  guidance 
in  management 
plans/conservation plans for marine protected areas. These measures all address the 
D2 target by aiming to achieve the target value/indicator of a decreasing trend in the 
introduction of new NIS. 

recognising  and  managing  NIS 

for 

-  How  and  when  the  updated  and  additional  MSFD  specific  measures  will  be 

implemented are stated by Sweden. 

-  A baseline scenario in line with the Swedish environmental target for criterion D2C1 
“a downward trend in the number of NIS introduced through human activities” has not 
yet been established. This has hindered the assessment of other potential gaps. 
-  Knowledge gaps still exist regarding how and when GES will be achieved and may 

require several more years of monitoring to establish this.  

-  Progress for D2 regarding addressing relevant pressures has been made since the 

2016 programme of measures for both the Baltic and the North Sea regions. 

-  In 2016, it was assessed that the programme of measures only partially addressed 
the relevant pressures. Updated MSFD specific measures have addressed this gap by 
focussing on producing guidance for vessel hull cleaning. 

-  In 2016, it was assessed that the programme of measures only partially addressed 
GES and targets for D2. MSFD specific updated measures in 2021 address this gap 
and contribute towards GES and the operational target with the aim to directly reduce 
introduction of NIS. 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Sweden’s programme of measures for D3 is considered good 

Strengths 

-  The  gap  analysis  provided  information  on  existing  measures  and  ways  in  which 
Sweden has sought to improve the implementation of EU fisheries policies, as well 
as implementation of recent national initiatives.  

-  All relevant pressures are addressed in Sweden’s updated programme of measures. 
-  Sweden  has explained  where, how  and  when  the MSFD  specific  measures  will  be 

implemented. 

-  The reported measures constitute an appropriate range of measures to address the 

various pressures under D3 and will contribute to achieving GES. 

Weaknesses 

-  The gap analysis did not specifically reference the environmental targets. 

239 

 
 
 
Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

-  Some measures only refer to the desired state of an ecosystem component, and do 

not focus on reducing relevant pressures and impacts. 

-  In  the  2016  assessment,  it  was  concluded  that  Sweden  had  addressed  the  key 

pressure but had only partially addressed all components of GES and targets. 

-  In 2022, Sweden is assessed to be continuing to address all relevant pressures in its 

updated programme of measures. 

-  Sweden continues to partially address GES and targets in 2021. 

The adequacy of Sweden’s programme of measures for D4 is considered good 

-  Additional or updated measures relevant to D4 in the 2022 programme of measures 
addresses  a  broader  range  of  pressures,  complementing  those  in  the  2016 
programme. 

-  Targets addressing a wider range of biodiversity elements are included in the 2022 

programme of measures. 

-  Measures partially address pressures on mammal habitats through improvements 
to spatial protection, MPA management, Maritime Spatial Planning and reduction of 
by-catch. 

-  Additional or updated measures relevant to D4 in the 2022 programme of measures 
are all linked to one or more targets relating to hazardous substances, introduced 
alien species, fish populations and community structure, seabed, biogenic structures, 
hydrographic change, and marine litter. 

-  No  timelines  for  delivery  of  the  measures  were  specified  in  the  programme  of 

measures. 

-  The MPA measure is only indirectly relevant to D4 as it will limit activities causing 

physical disturbance to the seabed, which is directly related to D6.   

-  Overall, it is considered that measures are only partially linked to operational targets. 
-  The  assessment  in  2022  for  coverage  of  pressures  in  the  Greater  North  Sea  is 

considered addressed. 

-  It is considered that progress has been made in addressing pressures though the 

programme of measures. 

-  Sweden’s score in 2022 for the coverage of GES and targets in the Baltic region and 

Greater North Sea has declined since the last report 

The adequacy of Sweden’s programme of measures for D6 is considered very good 

-  Additional or updated measures relevant to D6 seabed habitats webs in the 2022 
programme of measures addressed a broader range of pressures, complementing 
those in the 2016 programme. 

-  Sweden proposes both updates to existing measures and a series of MSFD specific 
measures which address a full range of relevant pressures, including physical loss 
and disturbance of the seabed, and input of nutrients and hazardous substances.   
-  All measures are aimed at the relevant spatial scale, with most being applied to both 

coastal and offshore waters. 

-  Where relevant, MSFD specific measures may also apply to terrestrial habitats. 
-  All measures are linked to targets. 
-  Only four targets (of a total of 22), two for the Baltic region and two for the Atlantic, 
relating to the introduction of nutrients and hazardous substances, are considered 
operational,  so  overall  it  is  considered  that  measures  are  only  partially  linked  to 
operational targets.  

240 

 
 
 
-  Sweden’s  score  in  2022  for  the  coverage  of  pressures  in  relation  to  D6  remains 
unchanged since 2016, i.e. fully addressed. It is considered that progress has been 
made in addressing pressures though the update of the programme of measures.  
-  Sweden’s score in 2022 for the coverage of GES and targets remains unchanged 
since  2016,  i.e.  partially  addressed. It  is  considered  that  some  progress  has been 
made in linking measures to operational environmental targets. 

Progress since 2016 

D7 — Hydrographical changes 

Adequacy 

The adequacy of Sweden’s programme of measures for D7 is considered very good 

Strengths 

Weaknesses 

Progress since 2016 

-  Sweden’s  programme  of  measures  is  considered  adequate  for  achieving  or 

maintaining GES for D7 in both marine regions. 

-  The gap analysis was done through an evaluation of the status of Sweden’s marine 

against GES for D7 after the first MSFD cycle based on expert advice. 

-  Sweden’s  updated  programme  of  measures  adequately  addresses  all  relevant 

pressures for D7. 

-  Cumulative impacts are not considered in the gap analysis. 
-  Sweden has not defined any target value nor indicators for D7 environmental target, 
which  weakens  the  link  between  the  programme  of  measures  and  the  ultimate 
objective of GES. 

-  The first cycle of the Swedish programme of measures adequately addressed both 
coverage of pressures and of GES/targets. There are no major changes since 2016 
regarding the measures. 

Based  on  the  information  reported  in  their  programmes  of  measures,  Sweden’s 
commitment  to  the  implementation  of  their  second  programmes  of  measures  is 
assessed as ‘high’.  

Key  Factor  1:  Socio-
economic impacts of new 
measures  

Key Factor 2: Financing 
sources  and  use  of  EU 
funds 

Sweden  has  carried  out  an 
impact  analysis  of  new 
measures  prior  to  adopting 
including  a  Cost-
them, 
Benefit  Analysis  (CBA)  and 
Cost-Effectiveness  Analysis 
(CEA).  

Sweden has investigated the 
potential  social  impacts  but 
only with respect to fisheries 
and 
(professional 
recreational). 

Sweden  relies  mostly  on 
government  grants  and 
other organizations to fund 
implementation  of 
the 
measures,  but  EU  funding 
(i.e.  EMFAF)  is  also  listed. 
Partial  information  on  the 
funding 
of 
amounts 
mobilized 
(approximately 
2.2  billion  euros  for  the 
2021  -  2027  period)  was 
no 
provided 
information  was  provided 
on  the  amounts  mobilised 
from the EU funds. 

but 

Key 
3: 
Factor 
Coordination  with  EU 
policies  and 
regional 
coordination 

Finaland  reported  the  links 
between  the  MSFD,  WFD, 
MSP,  CFP 
terms  of 
in 
common  measures  and 
objectives. However, there is 
no mention of links with the 
HBD.  

coordination 
International 
took  place 
the 
through 
European  Commission,  the 
regional  sea  conventions 
(OSPAR  and  HELCOM),  as 
well  as 
through  bi-and 
multilateral contracts. This is 
led  by  the  Swedish  Agency 
for  Marine  and  Water 

Key 
4: 
Factor 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 

Where:  Measures  for  10 
Descriptors  (except  D7344) 
have sufficient information 
on spatial coverage.  

How:  Measures  for  eight 
Descriptors (D1, D2, D3, D4, 
D6,  D9,  D10,  D11)  have 
information  on 
sufficient 
operationalisation,  while 
measures 
two 
measures  (D5,  D8)  only 
have partial information.  

for 

When:  Measures  for  10 
Descriptors 
(except  D7) 
have sufficient information 

(344) Sweden did not propose additional and modified MSFD specific measures for D7.  

241 

 
 
 
 
 
 
Under 
Management. 
cooperation, 
regional 
reported  having 
Sweden 
effectively 
identified 
required  measures  and 
excluded  measures  already 
in  place  in  the  RSC  action 
plans 
the 
Programme of Measures of 
neighbouring countries.  

and/or 

in 

in 

implemented 

on  temporal  coverage.  For 
example,  D8  measures  for 
the Baltic Sea will generally 
be 
the 
period  2022  to  2027,  and 
for  some  measures,  an 
action 
being 
prepared  which  will  further 
inform implementation.  

plan 

is 

6.17 Slovenia 

Summary: 

Overall, the second programme of measures presented by Slovenia is considered as moderately adequate to address the 
pressures acting on the Slovenian marine environment and partially contributes to achieving Slovenia’s GES and targets.  

In terms of strengths, Slovenia provides a very comprehensive report, linking well its assessment to environmental targets 
and measures. Slovenia has set up clear administrative framework/processes for implementing the measures, including for 
public consultations, and provide an estimation on the costs of each individual measure and their implementation. Climate 
change ecosystem resilience is strategically approached, including through the protection of carbon sinks. Measures for 
litter and seafloor integrity have been considered as adequate. 

On the downside, the programme of measures does not explain how the measures were selected based on the cost-benefit 
analysis. Slovenia does not make any references to the Biodiversity Strategy, Fit for 55 or the Zero Pollution Action Plan. 
The measures for noise and hydrological conditions have been considered as not sufficient to address pressures.  

Based on the information reported in their programme of measures, Slovenia’s commitment to the implementation of their 
second programme of measures has been assessed as ‘medium-high’. 

The  adequacy  of  Slovenia’s  programme  of measures  for  cross-cutting  issues  is 
considered moderate.  

Most of the required information has been reported, although there are areas where only partial or 
no information have been provided. Slovenia's general approach to developing its second programme 
of measures from the perspective of cross-cutting issues has stayed consistent. However, it is difficult 
to conclude if there has been any change in implementation processes and coordination mechanisms 
as Slovenia did not report on these issues. 

Topic 

Strengths 

Weaknesses 

The  programme  of  measures  includes  an 
estimation  on  the  costs  of  each  individual 
the 
measure  and  presents  costs 
implementation. 

for 

Slovenia updates the initial assessment and 
includes  the  'socio-economic'  benefits  in  a 
wider perspective. Benefits are expressed in 
quantitative and qualitative terms. 

The  programme  of  measures 
lacks 
evidence on the results of the cost-benefit 
and cost-effectiveness analysis.  

Benefits are not assigned or distributed to 
individual.  

The  potential  distribution  of  impacts  and 
the  acceptability  of  measures  amongst 

Socio-economic 
assessment 

242 

 
 
 
 
 
 
 
Slovenia  includes  a  strategic  objective  on 
tackling  climate  change,  and  highlights 
measures  that  contribute  to  ecosystem 
resilience 
change  and 
climate 
protection of carbon sinks. 

from 

current  and  future  stakeholders  is  not 
presented.  

the  assessment  on  how 

The  programme  of  measures  does  not 
the 
include 
measures  could  contribute 
to  climate 
change (emissions reduction and increase). 

Slovenia  reported  the  different  national, 
regional,  EU  and  private  sector  funding 
sources for each measure. 

The  reference  to  ‘EU  funds’  doesn’t  not 
allow to understand to which fund Slovenia 
is referring to.  

Interactions with 
climate change 

It is clearly specified whether the measures 
are to be delivered under the WFD, the MSP, 
the  CFP  or  the  HBD and  on how  the  MSFD 
terms  of 
these  policies 
links  with 
environmental 
the 
and 
objectives 
implementation of measures. 

in 

. 

Links to other 
policies 

Slovenia presented the different regional and 
international cooperation mechanisms linked 
to  the  programme  of  measures.  They  also 
described  how  these  are  linked  with  the 
MSFD in terms of objectives and the delivery 
of measures. 

The programme of measures recognised the 
transboundary impacts and includes a sub-
measure  on  transboundary  environmental 
impact assessments. 

Details  are  provided  on  when 
the 
consultations were done and the hyperlinks 
to consultation documents is reported, 

The  programme  of  measures 
on 
information 
implementation of the measures. 

the 

includes 
operational 

Regional 
cooperation and 
transboundary 
impact 

Public consultation 
and administrative 
process 

The  information  is  missing  on  how  or 
whether  coordination  between  EU  policies 
and the MSFD has evolved since the MSFD 
programme of measures.  

Several measures can be linked with the EU 
Biodiversity Strategy, Zero Pollution Action 
Plan and Fit for 55 but no reference is made 
to  these  policies.  A  reference  in  terms  of 
policy 
the 
European Green Deal but without linking it 
to  strategic  objective  on  tackling  climate 
change and relevant measures. 

requirements 

is  made 

to 

international  and/or 
The  evolution  of 
regional  cooperation  mechanisms  is  not 
presented in the programme of measures. 

to 

is  no 

reference 

There 
specific 
consultation  with  other  Member  States 
regarding  measures  with  transboundary 
impacts. 

The  programme  of  measures 
is  not 
elaborate  on  how  long  the  consultation 
periods  were  or  if  there  were  any  active 
promotion or targeting of the consultation.  

No  information  is  provided  on  whether 
there  have  been  any  changes  to  the 
implementation 
the 
process 
administrative  framework  since  the  MSFD 
programme of measures. 

and/or 

243 

 
 
 
 
 
 
The  adequacy  of  Slovenia’s  programme  of  measures  to  address 
pollution issues is considered moderate. 

D5- Eutrophication 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D8-Contaminants 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

The adequacy of Slovenia’s programme of measures for D5 is considered moderate 

-  Slovenia has explained how updates to existing measures and additional measures 

from other initiatives contribute to achieving GES. 

-  The programme of measures makes linkages between the existing measures and the 
WFD-River Basin Management Plan (RBMP). Incidentally, these were not submitted in 
time to be integrated into the Commission’s assessment of WFD’s RBMPs and cross-
checking could not be done. 

-  Slovenia has undertaken a gap analysis taking into account data monitoring. 
-  The additional existing measures identified will directly address discharges of urban 

wastewater into the marine environment and wastewater from vessels. 

-  The  references  to  Zero  Pollution  targets,  the  continuing  work  of  the  Barcelona 
Convention and  the updates  to  the  National Emissions  Ceiling  Directive  as  “existing 
measures” are missing. 

-  The  gap analysis has  not included  all  the elements  expected,  for  example,  to  what 
extend  the  current  measures  will  reduce  pressures,  or  future  socio-economic 
developments.  

-  In  2016,  the  assessment  considered  that  coverage  of  pressures  had  been  partially 
addressed. In 2022, it is considered that there is a broader coverage of the pressure.  
-  In 2016, it was considered that the measures addressed the components of GES and 
targets. The situation improved in 2022, thanks to two additional existing measures 
aimed at reducing contaminants from wastewater. 

The adequacy of Slovenia’s programme of measures for D8 is considered moderate 

-  Information on how some updates to existing measures and additional measures from 
other initiatives contribute to achieve GES are provided in the programme of measures. 

-  Slovenia has undertaken a gap analysis taking into account data monitoring.  
-  The  necessary  information  on  where,  when,  and  how  the  specific  additional  MSFD 

specific measures will be implemented are included in the e-reporting. 

-  The modified and additional MSFD specific measures are not considered to be linked 

to operational targets.  

-  The programme of measure is not clear on whether the gap analysis has included all 
the elements expected, for example, to what extend the current measures will reduce 
pressures, or future socio-economic developments.  
-  The target reported are not considered as operational. 
-  The  reference  to  Zero  Pollution  targets,  to  the  continuing  work  of  the  Barcelona 
Convention and to the updates on the National Emissions Ceiling Directive are missing.  
-  GES is not currently being achieved for some substances including TBT, mercury and 
benzo(a) pyrene and the measures will not address benzo(a)pyrene contamination in 
sediments. 

-  There remains uncertainty whether funding for the measures has been secured.  
-  In 2026, it was considered that coverage of pressures had been addressed. In 2022, 
the assessment considers that coverage of relevant pressures was partially addressed 

244 

 
 
 
 
 
as the modified and additional MSFD specific measures address most of the relevant 
pressures  to  some  extent,  although  the  measures  will  not  address  benzo(a)pyrene 
contamination in sediments.  

-  In 2016, the measures addressed the components of GES and targets. In 2022, the 
assessment considers that the modified and additional MSFD specific measures did 
not adequately address GES and targets. 

D9 — Contaminants in seafood 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

D10 — Marine litter 

Adequacy 

The adequacy of Slovenia’s programme of measures for D9 is considered moderate. 

-  The additional existing measures identified will directly address discharges of urban 

wastewater into the marine environment and wastewater from vessels. 

-  Slovenia has undertaken a gap analysis, although it is limited due to limited available 

monitoring data. GES is reported as currently achieved for D9. 

-  Slovenia  has  not  clearly  explained  how  updates  to  existing  measures  contribute  to 
maintaining GES.It is unclear whether the gap analysis has included all the elements 
expected,  for  example,  consideration  of  how  much  current  measures  will  reduce 
pressures,  or  future  socio-economic  developments.  The  contribution  which  D8 
measures make towards D9 targets is not recognised. 

-  There  is  no  reference  to  WFD,  Zero  Pollution  targets  or  the  continuing  work  of  the 

Barcelona Convention. 

-  In  2026,  the  coverage  of  pressure  was  considered  as  addressed.  In  2022,  the 
assessment  considers  that  there  is  a broader  coverage  of  the  pressure  through  the 
additional existing measures.  

-  In  2016,  the  assessment  considered  that  the  measures  mostly  addressed  the 
components  of  GES  and  targets.  The  situation  improved  in  2022,  thanks  to  two 
additional existing measures aimed at reducing contaminants from wastewater. 

The adequacy of Slovenia’s programme of measures for D10 is considered good. 

-  The gaps identified during the first cycle and how these have been addressed in the 

second programme of measure are well described. 

Strengths 

-  The modified and additional MSFD specific measures address relevant pressures. 
-  Slovenia has provided most of the required information on where, how and when the 

new measures will be implemented. 

-  One  of  the  additional  MSFD  specific  measures  addresses  submerged  end-of-life 

Weaknesses 

vessels. 

-  The gap analysis by Slovenia is partially adequate as it does not specify how much the 
relevant pressures associated with D10 have been or will be further reduced by the 
combined modified existing measures. 

-  Slovenia reports that the current state in relation to GES for D10 is poor for most litter 
elements but does so without specifically referring to important recent developments 
such as the EU beach litter threshold value or Zero Pollution Targets. 

-  The programme of measure doesn’t specify how the existing measures will effectively 

contribute to GES. 

-  Some targets referenced (D10C1 and D10C2) were not considered operational. 
-  Future socio-economic developments are not mentioned in relation to achieving GES 

for D10. 

Progress since 2016 

-  In 2016, it was considered that the measures cover the relevant pressures. The same 
conclusion in made in 2022. It is noted, however, that measures specifically targeting 

245 

 
 
 
micro-litter  and  litter  ingested  by  animals  are  not  included  in  Slovenia's  second 
programme of measures.  

-  In  2016,  it  was  considered  that  the  measures  addressed  the  GES  components  and 
targets definitions. In 2022, the modified and additional MSFD specific measures do 
not adequately address GES and targets.   

-  While  broad  timelines  are  provided  for  all  relevant  new  measures,  the  timeline  to 
achieve GES remains unclear in the 2022 assessment, as was the case in the 2016 
assessment. 

D11 — Underwater noise and energy 

Adequacy 

The adequacy of Slovenia’s programme of measures for D11 is considered poor 

Strengths 

Weaknesses 

Progress since 2016 

-  Slovenia has started to produce simplified sound maps to assess continuous noise.  
-  The  modified  new  measures  aimed  at  directly  reducing  pressures  in  the  marine 

environment and preventing further inputs of pressure. 

-  Slovenia  leverages  the  recommendations  made  by  regional  and  international 

organisations (IMO, HELCOM, ACCOBAMS). 

-  Environmental targets for D11 are adequately defined and addressed by the modified 
new measures that, if properly implemented, will lead to the reduction of impulsive 
noise and continuous noise. 

-  Slovenia  did  not  carry  out  a  gap  analysis  for  D11  due  to  lack  of  information/data 

availability. 

-  The nature of the missing data is not clearly identified, neither for impulsive noise nor 
for continuous noise; there are no details on how the missing data will be gathered.  
-  Reference  to  the  implementation  of  TG  Noise  guidance  as  to  the  decisions  and 
recommendations  made  by  TG  Noise  on  how  to  implement  a  regional  monitoring, 
implement regional assessment and set targets on low frequency continuous noise are 
yet missing. 

-  The maps produced do not consider the variability of the marine environment and have 
not yet been calibrated/compared with in-situ measurements made by a network of 
hydrophones. Those maps can therefore be misleading on where and when measures 
shall be implemented.  

-  The implementation of the modified new measures should be detailed.  
-  The relationship between the findings of the monitoring program and the measures is 

not provided. 

-   Energy  input  such  as  heat  or  electromagnetism  is  not  addressed  by  the  updated 

programme of measures. 

-  The  adequacy  of  Slovenia's  report  on  D11  in  the  second  programme  of  measures 
deteriorated  compared  to  the  2016  assessment.  This  is  mainly  because  the  gap 
analysis was not carried out due to lack of data for D11. 

-  In 2016 it was concluded that the measures adequately covered all pressures, GES and 
target definitions. In 2022, not much progress was made, except for the description of 
the measures.  The lack of data remains the main gap to be addressed. 

The  adequacy  of  Slovenia’s  programme  of  measures  to  address 
biodiversity issues is considered moderate. 

D1 — Biodiversity 

246 

 
 
 
 
 
 
Adequacy 

The adequacy of Slovenia’s programme of measures for D1 is considered moderate 

-  The current status is reported in detail for all 6 of the ecosystem components as well 

as an update on progress towards GES and environmental targets.  

-  A gap analysis is performed and shows that the existing measures from the first cycle 

were not sufficient to meet GES for descriptor 1. 

-  Updated and additional MSFD specific measures reported in the updated programme 

of measures address the relevant pressures and targets. 

-  Slovenia brings forward 18 new updated and additional measures under Descriptor 1, 
which shows commitment to improve biodiversity in national waters. Slovenia now has 
a substantial number of Descriptor 1 measures compared to the size of their national 
coastline.  

-  All descriptive information on the measures is presented. 
-  The new spatial protection measures address relevant pressures and have identified 

target habitats. 

-  The biggest gap identified by the gap analysis is a distinct lack of data and knowledge 
regarding  local  species  populations,  but  this  gap  is  not  addressed  in  the  updated 
programme of measures. 

-  The targets and pressures which are reported are those for descriptor 6. 
-  There  is  no  justification  provided  by  Slovenia  regarding  updates  made  to  existing 
measures and additional measures from other initiatives introduced in the second cycle 
and how they will progress towards GES. 

-  Measures focus on the maintenance and protection of seabed habitats only. Protection 

of habitats which are important to pelagic and bird species are not considered. 

-  Timelines are only provided for the entire measure implementation (and not for each 
stage),  and  the  description  of  how  measures  will  be  implemented  is  more  of  a 
summary.  

-  Not enough information is provided to confirm the potential effectiveness of the new 

spatial protection measure.  

-  In  2016,  the  assessment  determined  that  pressures  and  targets  were  partially 
addressed by measures. Progress made since 2016 has been limited, with updated and 
new measures in the second cycle. 

-  More  direct  measures  for  the  species  not  meeting  GES  are  required  to acknowledge 

Strengths 

Weaknesses 

Progress since 2016 

D2 — Non-indigenous species 

significant progress. 

Adequacy 

Strengths 

Weaknesses 

The adequacy of Slovenia’s programme of measures for D2 is considered moderate 

-  Slovenia, thanks to NIS monitoring, establishes a baseline scenario of the number of NIS 

introductions and NIS distributions within its waters. 

-  The gap analysis highlighted the need for cross-border, regional level approaches to NIS 

introductions which is being addressed already by an existing measure. 

-  The contributions to the modified and additional existing measures to achieve GES are 

not provided. 

-  No indication is given on the progress of any first cycle measures. 
-  The gap analysis relating to other pathways of introduction, such as hull fouling and 
aquaculture, has not been clearly undertaken, which prevents further measures to be 
implemented to reduce the pressure. 

247 

 
 
 
Progress since 2016 

-  Progress  has  been  made  since  2016  in  terms  of  NIS  monitoring.  However,  no  new 
measures were proposed for the 2022 programme of measure and hence no additional 
progress has been made in 2022 to address gaps linked to the introduction of NIS. 
-  In 2016, it was assessed that the programme of measures only partially addressed 
relevant  pressures  for  D2.  In  2022,  no  new  measures  are  identified  to  address  the 
pressure.  

-  In 2016, it was assessed that the programme of measures addressed GES and targets 

for D2. It is similar in the 2022 programme of measures. 

D3 — Commercial fish and shellfish 

Adequacy 

The adequacy of Slovenia’s programme of measures for D3 is considered moderate 

Strengths 

Weaknesses 

Progress since 2016 

D4 — Foodwebs 

Adequacy 

Strengths 

Weaknesses 

-  Slovenia's gap analysis is partially adequate: a summary of status on GES is provided, 
and the first cycle measures already in place and additional existing and new measures 
are identified.   

-  Slovenia  has  partially  explained  how  updates  to  existing  measures  contribute  to 

achieving GES. 

-  Some information from the gap analysis is missing baseline scenario, analysis of how 
much  current  measures  will  reduce  pressures,  and  how  future  socio-economic 
developments might affect the achievement of GES.  

-  In 2016, Slovenia's programme of measures report was considered to address relevant 
pressures from commercial and recreational fishing and the programme of measures 
was considered to address D3 GES and targets.  

-  In 2022, no modified or additional MSFD specific measures were reported that were 
specific to D3. There was therefore no explicit assessment of whether pressures and 
GES and targets are being addressed 

The adequacy of Slovenia’s programme of measures for D4 is considered moderate 

-  Updated and additional MSFD specific measures reported in the updated programme 
of measures address the relevant pressures and targets reported in the e-reporting. 

-  All descriptive information on the measures is provided.  
-  New spatial protection measures address relevant pressures (although indirectly) and 

have identified target habitats. 

-  There is no justification on existing measures updates and on additional measures from 
other  initiatives  introduced  in  the  second  cycle  and  how  they  will  improve  progress 
towards GES for descriptor 4.  

-  The provided gap analysis simply states that there is not enough available information 

or a sufficient method to assess food web health in Slovenian waters. 

-  The targets and pressures which are reported are the same as for descriptor 6. 
-  Measures  also  focus  on  the  maintenance  and  protection  of  seabed  habitats  only, 
despite many pelagic and bird species being reported as in decline in the current status 
analysis. 

-  Information on how, when and where each measure will be implemented is also sparse. 
-  Timelines are only provided for the entire measure implementation (not for each stage), 
and the description of how measures will be implemented is more of a summary.  

-  The effectiveness of the new spatial protection measures should be presented.  
-  Slovenia should design and implement measures which investigate local food webs, 

and then attempt to protect them. 

248 

 
 
 
Progress since 2016 

D6 — Seafloor integrity 

Adequacy 

Strengths 

Weaknesses 

Progress since 2016 

-  No  progress  has  been  made  since  2016,  with  descriptor  4  rarely  mentioned  in  the 
written  report,  and  discussed  mainly  as  a  consequence  of  descriptor  1.  To  progress 
towards GES in food web health, this descriptor must be considered in its own right and 
food webs must be assessed for vulnerabilities.  

The adequacy of Slovenia’s programme of measures for D6 is considered good 

-  The gaps in the progress towards GES are identified by the gap analysis as well as a 

clear picture of the current status of Slovenian seabed habitats. 

-  All relevant pressures are well addressed by the measures. 
-  Slovenia  introduced  several  protected  areas  which  aim  to  provide  solace  for  several 

important and vulnerable seabed habitats. 

-  Most of the descriptive information on new measures is found in the reporting. 
-  A clear effort has been made to increase the percentage coverage of seabed protection 

as well as the variety of vulnerable habitats under protection. 

-  The justification of updates made to existing measures and additional measures from 
other initiatives and how they will improve progress towards GES is not provided.  
-  The  gap  analysis  doesn’t  include  the  socio-economic  development,  the  baseline 

scenarios, the links to new measures and environmental targets. 

-  Measures to fill the knowledge gaps are not presented in the updated programme of 

measure.  

-  the targets which focus on the biological community are not contributing to address the 
pressure. There is no explicit mention of the need to reduce or remove the pressure of 
bottom-trawler fishing in these protected areas, despite being one of the main pressures 
facing seabed habitats. 

-  The  effectiveness  of  management  and  the  scale  of  the  protected  areas  could  be 

clarified.  

-  Timelines are only provided for the entire measure implementation (not for each stage), 
and the description of how measures will be implemented is more of a summary. 
-  In 2016, the assessment concluded that all pressures were addressed by measures, but 
targets were only partially addressed. Progress since 2016 has been made. All relevant 
pressures remain covered by the reported measures, many of the targets are also met 
thanks to the measures introduced in the updated programme of measures.  

-  In  2016,  the  assessment  states  that  GES  has  been  addressed  by  the  measures. 
However, in the gap analysis of the updated programme of measures, it is reported that 
infralittoral  habitats  are  not  currently  meeting  GES,  therefore  leading  to  an  unclear 
statement.  

D7 — Hydrographical changes 

Adequacy 

The adequacy of Slovenia’s programme of measures for D7 is considered poor 

Strengths 

-  Slovenia  has  updated  its  programme  of  measures  for  D7  and  reported  that  21 

measures will address pressures potentially linked to hydrographical alteration.  

Weaknesses 

-  No gap analysis has been carried out by Slovenia for this descriptor and no analysis of 

relevant pressures (existing or linked to future developments) has been provided. 

-  No justification is provided on the links between the new measures and D7. Therefore, it 
is  not  possible  to  understand  how  the  measures  will  contribute  to  achieving 
environmental targets and ultimately GES for D7. 

249 

 
 
 
-  No clear analysis is provided on future developments that could cause pressures linked 
to  hydrographical  changes,  even  if  some  mentions  are  made  in  the  text  report  (e.g. 
marine aquaculture or tourism). 

-  The information insufficiently describes the actions planned and the expected outputs 

and outcomes. 

-  Slovenia does not mention cross-border or regional cooperation, despite its geographical 

situation. 

-  Based on the 2022 report, the assessment shows a regression. This is partly linked to 
higher expectations for the second cycle (such as a better determination of GES for D7, 
proper  assessment  of  status  (pressures,  state,  threats)  and  sound  definition  of 
operational environmental targets.  

-  Slovenia's report on its programme of measure has been assessed adequate, based on 

a rather qualitative assessment. 

Progress since 2016 

Based  on  the  information  reported  in  their  programmes  of  measures,  Slovenia’s 
commitment  to  the  implementation  of  their  second  programme  of  measures  is 
assessed as “medium-high”.  

Key  Factor  1:  Socio-
economic  impacts  of  new 
measures  

Key  Factor  2:  Financing 
sources  and  use  of  EU 
funds 

3: 
Factor 
Key 
Coordination  with  EU 
policies  and 
regional 
coordination 

CBA  and  CEA  for  some  new 
measures,  and  not  clear how 
influence  measure 
results 
selection  or  prioritisation.  No 
evidence 
investigating 
of 
social impacts of measures.  

include 
Funding  sources 
the 
municipal  budgets, 
EU 
budget, 
national 
funding,  regional  funding, 
and  private  sector  and 
public  sector  investments. 
There  is  no  information  on 
the  proportion  of  cost  or 
amount that will be funded 
by EU funds, and there is no 
information  on  which  EU 
funds will be used or if they 
are appropriate.  

in 

terms 

Describes the links between 
the  MSFD  and  other  EU 
of 
policies 
environmental 
objectives/targets  and  the 
implementation 
of 
Measures 
measures. 
specifically  linked  with  the 
CFP,  HBD,  WFD  and  MSP 
were 
and 
identified, 
authorities  responsible  for 
implementation 
of 
individual  measures  were 
listed.  

identified. 
the 

The 
and 
regional 
international  mechanisms 
linked  with 
the  second 
Programme  of  Measures 
  These 
were 
Barcelona 
include 
IMAP 
Convention, 
the 
(for  marine 
Programme 
monitoring), 
the  General 
Fisheries  Commission  for 
the Mediterranean, and the 
International 
Maritime 
Organisation.  

250 

on 

4: 
Factor 
Key 
Implementing  modified 
and  additional  MSFD 
measures:  where,  how 
and when 
Where:  Measures  for  four 
Descriptors  (D7,  D8,  D10, 
D11)14 
sufficient 
have 
information 
spatial 
coverage.  For  example, 
measures for D10 cover the 
Mediterranean  Adriatic  Sea 
and include coastal waters, 
territorial 
waters, 
transitional  waters  and 
terrestrial  parts  of  the  MS. 
Measures 
three 
Descriptors  (D1,  D4,  D6) 
only 
partial 
have 
information.  
How:  Measures  for  seven 
Descriptors (D1, D4, D6, D7, 
D7,  D10,  D11)  only  have 
partial 
on 
operationalisation.  

information 

for 

When:  Measures  for  two 
Descriptors (D10 and D11) 
have  sufficient  information 
on temporal coverage, and 
four 
measures 
Descriptors (D1, D4, D6, D8) 
information. 
have  partial 

for 

 
 
 
 
 
coverage 

of 
Spatial 
measures  for  D7  is  not 
clear. 

251 

 
 
 
7. Country-specific recommendations 

7.1  Recommendations for immediate improvements 

1.  Member States should identify and put in place, as appropriate, additional measures 

to reduce persistent environmental challenges (pressure) that prevent the 
achievement of good environmental status. 

a.  On pollution, this involves: 

i.  stepping up action to reduce underwater noise pollution, including by 

tackling the main sources of continuous noise – such as shipping – and 
by setting up low-noise areas for marine species; 

ii.  stepping up action to reduce nutrient pollution to achieve the objectives 

of the MSFD, WFD and the Nitrates Directive; 

iii.  reducing chemical pollution from sea-based sources, in particular 

hydrocarbon extraction, and from novel substances, including PFAS, 
pharmaceuticals or microplastics; 

iv.  continuing action to reduce the impact of litter on marine life, while 

reducing the inputs at source. 

b.  On biodiversity, this involves: 

i.  completing the network of coherent, representative, effectively managed 
MPAs to reach the 2030 target set in the biodiversity strategy to protect 
30% of waters, including 10% strictly, in line with the ambition set in the 
marine action plan and the obligations under the Kunming-Montreal 
Global Biodiversity Framework; 

ii.  stepping up action to reduce the bycatch of sensitive species, starting 
with the priority species as recommended in the marine action plan; 

iii.  implementing without delay the obligations under the Nature Restoration 
Regulation as critical contributions to achieving GES under the MSFD;  

iv.  tackling the risks to marine ecosystems linked to the projected expansion 
of offshore renewable energy production, together with the cumulative 
impacts of existing activities at sea, through forward-looking ecosystem-
based maritime spatial planning. 

c.  Regarding climate change, all Member States should seek to factor climate 
change in the design and selection of their measures and in particular: 

i.  prioritise measures that help limit/reduce greenhouse gas emissions, 

including by restoring blue carbon ecosystems; 

ii.  ensure that other measures or groups of measures do not increase 

greenhouse gas emissions; 

iii.  take measures to strengthen the adaptive capacity of coastal 

communities to climate change, e.g. by restoring coastal ecosystems. 

252 

 
2.  Member States should increase investment and provide sufficient financing to 

implement the programme of measures to reach the MSFD objectives. This involves 
in particular: 

a.  developing a strategic outlook for investments to achieve good environmental 
status, avoiding a piecemeal approach to funding individual measures and 
reducing inefficiencies across different policy areas; 

b.  clearly identifying the source of financing needed to implement all measures; 

c.  making use of existing financial instruments and tools that support the 

development of measures for marine protection and sustainable use, including 
through research and innovation, such as the Cohesion, Recovery and Resilience 
Facility, regional funds, EMFAF, LIFE and Horizon Europe in its different clusters 
(e.g. Missions and Partnerships), among others. 

3.  Member States should put in place governance mechanisms that support the 
design and implementation of ambitious, coherent, coordinated, fair and 
effective programmes of measures. This involves: 

a. 

b. 

c. 

d. 

tackling decisively the obstacles to implementing the measures, such as 
insufficient financing; 

improving coordination across authorities to ensure that MSFD measures 
dependent on other policies are fully implemented by the authorities dealing with 
implementation of these policies, notably in relation to fisheries, agriculture and 
energy; 

involving the public and stakeholders at the planning stage, taking their 
contributions into account in the design of measures and ensuring social 
acceptability of the measures proposed, adopting accompanying measures to limit 
potential negative impacts if necessary; 

increasing early coordination of programmes of measures with neighbouring 
Member States to ensure coherence, synergies and the complementarity of 
measures in the region and planning joint action where necessary; 

e.  operationalising the spatial aspects of MSFD programmes of measures through 

maritime spatial plans to ensure that the spatial protection measures and spatial 
pressure reduction measures planned are fully taken up in the MSP. 

7.2  Recommendations for third programmes of measures 

In addition to the recommendations for immediate improvements laid out in the section above, the 
analysis of Member States’ programmes of measures has allowed the identification of a number of 
actions to be taken in the preparation and design of the third programmes of measures.  

7.2.1  Cross-cutting issues 

Topics 

Recommendations 
•  Assess impacts of measures on  different  social groups and 
the social acceptability of measures. Indicate if the update of the 
programme  of  measures  has  been  influenced  by  concerns  on 
human well-being and/or the well-being of specific groups.  
•  Use  the  outcomes  of  the  socio-economic  analysis  of  the 
programme of measures in order to:  

Member States 
BE, CY, DE, EE, ES, FI, FR, IE, IT, 
LT, LV, NL, PL, PT, RO, SE, SI 

BE, CY, DE, ES, FI, FR, IE, IT, LT, 
NL, PT, SE, SI 

253 

 
 
Topics 
Socio-economic 
assessment 

Recommendations 
o  Adapt the list of measures initially proposed (removing or 

adding some measures).  
o  Adapt the scale of measures.  
o  Adopt accompanying measures to limit potential negative 

impacts.  

Member States 

o  Set up priorities for the allocation of financial resources.  
•  Carry  out  a  climate  assessment  of  the  programme  of 
measures and use the outcomes to support the selection, design, 
or adaptation of the proposed measures in particular in order to 
take into consideration how the programme of measures for the 
MSFD  link  to and  contribute  to national,  regional and  European 
strategies and efforts on climate change. 

BE, CY, DE, EE, ES, FI, FR, IE, IT, 
LT, LV, NL, PT, RO, SI 

Interactions with 
climate change 

•  Strengthen  synergies  between  the  MSFD  and  other  EU 
legislation (notably WFD, MSP, BHD, and CFP) by taking adequate 
and coherent measures. 
•  When links between the MSFD and other EU legislations exist, 
put  in  place adequate  coordination  mechanisms  to  ensure  that 
fully 
MSFD  measures  dependent  on  other  policies  are 
implemented by the relevant authorities and ensure outcomes of 
this coordination. 
•  Provide additional information on the total amount that will be 
mobilized,  the  relative  share  of  financing  allocated  to  different 
sectors and/or descriptors in order to understanding the coherence 
between pressures/problems to be solved and the mobilisation of 
EU funds (e.g. European Maritime, Fisheries and Agriculture Fund, 
Cohesion Fund…).  
•  Take into account the transboundary (positive and negative) 
impacts  in  the  identification  of  the  measures.  When  possible 
transboundary  impacts  have  not  been  assessed,  the  Member 
States should summarise the reasons justifying this choice.   

•  Share  details  of  planned  programme  of  measures  with 
neighbouring  Member  States  in  advance  in  order  to  increase 
coherence  of  measures  in  the  region  and  consult  neighbouring 
Member  States  as  provide  information  on  the  outcome  of  this 
consultation.  
•  Ensure  that  all  relevant  stakeholders  are  involved  in  the 
planning  process  and  that  their  contributions  are  taken  into 
account adequately when finalising the programme of measures 
and  provide 
information  on  how  the  views  of  different 
stakeholders were considered in the final programme of measures 
and how they influenced the final programme of measures. 
•  Provide  additional  information  on  the  evolution  of  the 
administrative  framework  between  planning  cycles.  Information 
provided should help understanding the reasons for such changes, 
the  changes  made,  as  well  as  the  resulting  improvements 
expected in the MSFD implementation.  

BE, DE, FI, FR, IT, LT, NL, PL, RO 

CY, DE, ES, FI, FR, IE, PL, PT, SE 

BE, DE, ES, FI, FR, IE, IT, LV, NL 
PL, RO, SE, SI 

BE, ES, FI, FR, IE, IT, LT, NL, PL, 
PT, RO, SE 

BE, EE, ES, FR, IE, IT, PL 

DE, ES, FI, IE, IT, LV, NL, RO, SE 

BE, DE, EE, FR, IE, IT, LV, PT, RO, 
SE, SI 

Links to other 
policies 

Public 
consultation and 
administrative 
process 

7.2.2  Methodological recommendations  

Topics  

Gap analysis 

Recommendations  
•  The gap analysis should include a baseline scenario 
differentiating between measures that are adopted and 

BE (D1, D4, D6) 
CY (D1, D2, D4, D6, D11) 

Member State  

254 

 
 
 
  
 
 
 
 
 
 
  
 
  
Topics  

Recommendations  
already  implemented  and  measures  adopted  but  not 
yet/fully implemented. The baseline scenario should be 
used  as  the  benchmark  against  which  alternative 
options should be compared.  

•  The  gap  analysis  should  include  an  estimation  of 
how  the  measures  currently  in  place  (from  the  first 
cycle) will have reduced anthropogenic pressures in the 
timeframe of the baseline scenario and the consequent 
change in each of the state components.  

•  The gap analysis should include a clear conclusion 
on  whether  the  measures  from  the  first  cycle  and 
updated  existing  measures  are  sufficient  to  achieve 
MSFD  environmental  targets  and  achieve  or maintain 
GES.  

•  The gap analysis should include a clear timeline of 
when GES will be achieved.  

255 

Member State  

EE (D11) 
ES (D2) 
FI (D6) 
FR (D1, D2, D3, D4, D6, D7)  
IE (D2) 
IT (D1, D2, D4, D5, D6, D7, D8, D9, D10, D11) 
LT (D1, D4, D6, D11) 
NL (D1, D4, D6, D10, D11) 
PT (D2) 
SE (D1, D4, D11) 
SI (D1, D4, D6)   
BE (D6, D4, D10)  
CY (D1, D3, D4, D11, D6, D7) 
DE (D3, D10, D11) 
EE (D1, D4, D7, D11) 
ES (D7) 
FR (D7) 
IE (D10) 
IT (D1, D3, D4, D6, D7)  
LT (D1, D4, D6, D11, D10) 
LV (D3) 
NL (D1, D3, D4, D6, D11) 
PL (D3, D10) 
PT (D5, D7, D8, D9, D11) 
RO (D1, D2, D3) 
SE (D3, D9, D11) 
SI (D1, D3) 
BE (D1, D4, D6) 
CY (D1, D11, D3, D4, D6) 
DE (D4, D7) 
EE (D11, D3, D7) 
ES (D3) 
FI (D4) 
FR (D10, D11, D7) 
IE (D2) 
IT (D1, D2, D3, D4, D5, D6, D7, D8, D9, D10) 
LT (D2, D1, D3, D4, D6, D10, D11) 
LV (D2, D3) 
NL (D2, D1, D11, D4, D6) 
PT (D1, D4, D6) 
RO (D2, D1, D4, D6, D7) 
SE (D11) 
SI (D1, D10, D11, D4) 
BE (D3, D7, D10) 
CY (D3, D4, D6) 
DE (D3) 
EE (D1, D2, D4, D7, D9) 
ES (D1, D2, D3, D5, D7, D8, D9, D11) 
FI (D5) 
FR (D3) 
IE (D3, D4, D6, D8, D9) 
IT (D2, D9) 
LT (D1, D2, D8, D9, D10, D4, D6, D7, D5) 
LV (D1, D2, D5, D6, D8) 
NL (D3, D5, D8, D1, D4, D6) 
PT (D1, D4, D6) 

 
Topics  

Recommendations  

Member State  

•  Member  States  should  quantify  the  pressures 
present  in  their  waters  and  their  expected  level  of 
reduction as a result of the established measures. This 
could  be  facilitated  by  further  efforts  to  address 
knowledge gaps and define the methodology for such 
estimations at regional or EU level. Such quantification 
will  also  contribute  to  linking  the  measures  with  the 
achievement of GES.  

RO (D2, D3, D5, D7, D8, D11) 
SE (D11) 
SI (D7) 
BE (D1, D4, D6, D5, D8, D9, D10) 
CY (D1, D2, D4, D5, D6, D8, D9, D7) 
DE (D1, D5, D6 D8, D9) 
EE (D1, D3, D4, D5, D6, D8, D9) 
ES (D1, D2, D5, D7, D8, D9) 
FI (D6, D8, D9) 
FR (D1, D5, D6 D8, D9, D10) 
IE (D4, D6, D7, D10) 
IT (D1, D3, D6) 
LT (D5, D6, D8, D9) 
LV (D1, D4, D6, D5, D8, D9) 
NL (D1, D4, D5, D6, D8, D9) 
PL (D1, D8, D9, D4, D6) 
PT (D1, D4, D5, D6, D8, D9) 
RO (D1, D4, D5, D6, D8, D9) 
SE (D1, D2, D4, D5, D6, D8, D9) 
SI (D4, D5, D6, D8, D9, D7) 
BE (D5, D7, D8, D9) 
CY (D1, D4, D6) 
EE (D4, D6, D1, D8, D9) 
FI (D8, D9, D5) 
IE (D7) 
IT (D4, D6, D1) 
LT (D1, D4, D6) 
NL (D4) 
PT (D1, D4, D6) 
RO (D1, D4, D6) 
SI (D1, D4, D6) 
BE (D1, D2, D3, D4, D6, D7, D8, D10, D11) 
CY (D1, D4, D6 
DE (D1, D4, D6, D7) 
EE (D1, D4, D6) 
ES (D1, D2, D4, D6, D10) 
FI (D3, D1, D6, D5, D8, D9) 
FR (D1, D6, D2, D3, D5, D7, D8, D9) 
IE (D3, D5, D6, D8, D9, D10, D11) 
IT (D2, D3, D5, D10, D1, D4, D6) 
LV (D10, D3) 
LT (D1, D4, D6, D2) 
NL (D10, D3, D5, D1, D4, D6, D11) 
PL (D5, D8, D9, D1, D4, D6, D11) 
PT (D1) 
RO (D1, D2, D4, D6, D7) 
SE (D5, D8, D9, D6) 
SI (D1, D4, D6, D7, D10, D11) 
CY (D1, D2, D4, D6) 
DE (D1) 
EE (D4, D6) 
FI (D1, D4, D6) 
IT (D1, D4, D6) 
LT (D1, D4, D6) 
LV (D8, D10) 
PT (D2, D10, D9) 

Effectiveness of 
measures  

•  Member States should make better  links between 
the  groups  of  measures 
for  pressure 
descriptors  and  their  effects  on  the  state  descriptors. 
This would allow a comprehensive view of the impact 
of measures affecting all descriptors.  

reported 

•  Member  States 
their 
modified/additional new measures will be implemented. 
In particular, Member States should clearly identify: 

should  ensure 

that 

•  the  timelines  for  implementation  for  all  new 
measures and include and implementation plan; 
•  the source of financing for implementation of all 
measures and ensure that financing is in place to 
implement all measures; 

•  the  entities  in  charge  of  implementation  for  all 

their measures 

•  Member  States  should  ensure  a  better  balance 
between  direct  and  indirect  measures  when  many 
indirect measures have been reported.  

256 

 
 
Topics  

Recommendations  

Member State  

•  Member  States  should  explain  better  how  a 
measure reported for several descriptors is relevant for 
each one of these descriptors 

RO (D1, D4, D6) 
SI (D1, D4, D6) 
BE (D1, D4, D6) 
CY (D1, D4, D6) 
DE (D4) 
EE (D1, D4, D6) 
ES (D1, D10, D2) 
FR (D2) 
IE (D11, D8, D9) D2, D10)  
IT (D1, D4, D6) 
NL (D1, D4, D6) 
PT (D1) 
SI (D1, D4, D6) 
BE (D3, D1, D6) 
ES (D3, D1, D4, D6) 
FI (D7)  
IE (D11) 
LT (D3) 
LV (D3) 
PL (D1, D3, D10, D11, D5) 
PT (D3) 
BE (D1, D4, D6, D7) 
CY (D4, D6) 
EE (D1, D10, D4, D6) 
FI (D10) 
IE (D2, D6) 
LT (D10) 
LV (D1, D4, D6) 
PL (D7) 
PT (D1, D7) 
SI (D1, D4, D6, D7) 
BE (D2, D4, D3) 
CY (D6, D7, D3) 
FI (D6) 
IE (D4, D6) 
IT (D1, D4, D6) 
NL (D4)  
PL (D11, D3) 
RO (D1, D4, D6, D3) 
SE (D1, D4, D6, D3) 
BE (D1, D4, D6, D8, D9) 
CY (D5, D7) 
EE (D1, D4, D5, D6, D8, D9)  
FI (D8) 
FR (D5, D8, D9, D11) 
LT (D1, D4, D5, D6, D8, D9, D11) 
LV (D1, D4, D5, D6, D8, D9) 
PL (D1, D4, D5, D8, D9) 
PT (D1, D4, D5, D6, D8, D9)  
RO (D3) 
SE (D4, D6) 
SI (D1, D4, D7) 
BE (D10, D3, D4)  
CY (D4) 
DE (D10, D11, D3) 
EE (D11) 

•  Member  States  should  justify  the  withdrawal  of 
certain  measures  explaining  why  those  measures  are 
not relevant anymore.  

•  Member States should define the spatial scope of 
measures  in  detail.  Furthermore,  the  spatial  scope  of 
measures should be expanded to cover marine waters 
beyond  coastal  waters,  where  relevant  pressures  are 
present.  
•  The  Member  States  should  consider  establishing 
additional measures beyond spatial protection efforts to 
address species and habitats. 

•  Member States should ensure consistency of their 
determinations of GES, environmental targets and the 
programme  of  measures.  This  would  allow  to  use 
environmental  targets  systematically  as  milestones 
towards  achieving  GES  through  the  measures,  and 
monitor  this  progress  through  the  MSFD  monitoring 
programmes.  

Consistency of 
marine 
strategies  

•  Member States should ensure better links between 
their  programme  of  measures  and  monitoring 
programmes, in order to ensure that the effects of the 
measures, and hence their efficiency and effectiveness 
in meeting targets and GES, are measured through the 
monitoring programmes.  

•  Member  States 
should  define  operational 
environmental targets under Art. 10 to ensure that the 
modified and/or additional new measures contribute to 
their achievement.  

257 

 
Topics  

Recommendations  

•  Member  States  should  fully  populate  e-reporting 
and  ensure  consistency  between  e-reporting  and  text 
report.  

Data, information 
& reporting  

If  knowledge  gaps  are  still  substantial,  Member 
• 
States  should  develop  more  research  efforts/  data 
collection to fill knowledge gaps, provide an assessment 
on when GES will be achieved and implement concrete 
management measure.  

Member State  
ES (D1, D4, D6, D10, D11, D3, D7) 
FI (D3, D7) 
IE (D10, D5, D8, D9 
IT (D1, D3, D5, D8, D9) 
LT (D7) 
LV (D10, D2, D7) 
NL (D4, D10) 
PL (D2, D3, D5, D7) 
PT (D3, D4, D10, D5) 
RO (D3) 
SE (D10, D1, D3, D4) 
SI (D10, D8, D4) 
BE (D2, D3, D5, D7, D8, D9)  
CY (D3, D2, D11) 
DE (D3, D5, D8) 
ES (D2) 
EE (D3) 
FI (D3, D8, D9) 
LT (D2, D3) 
LV (D5) 
NL (D3, D10, D5, D9) 
PL (D3) 
PT (D5, D8, D9) 
RO (D3) 
SE (D3, D10) 
BE (D3, D4, D11) 
CY (D2, D10) 
DE (D1, D4, D2, D6, D5, D8, D9) 
IE (D4, D6) 
IT (D1, D4) 
LT (D11) 
NL (D4, D6) 
PT (D11, D5, D8, D9) 
RO (D5) 
SE (D1, D10, D11, D2, D4, D6) 
SI (D1, D11) 

7.2.3  Descriptor-specific recommendations 

Descriptor 
Pollution  

Recommendations 

Member State 

•  Establish  more  links  with  existing  EU  policies  and  international 
instruments  for  eutrophication,  including  the  WFD,  Zero  Pollution 
targets and the National Emissions Ceiling Directive.  
•  Continue to work and strengten within the auspices of the regional 
sea  convention,  the  implementation  of  regional  measures  against 
eutrophication. 
•  Consider the need for additional measures in relation to nutrients 
inputs from: 

All MS 

All MS except LV 

Descriptor 5 

• 
• 
• 
• 

agriculture and industry 
aquaculture 
fisheries 
recreational activities  

258 

BE, CY, EE, FI, LV, PT 
CY, EE, FR, LV, SI 
ES, PL 
FR, IT 
BE, FI, LT, RO, SE 

 
  
 
 
Descriptor 

Recommendations 

Member State 

• 

atmospheric deposition (NOx) from sea-based and 
land-based sources 

All MS 

links  with 

BE, CY, DE, EE, ES FI, FR, IE, IT,  LT, 
LV, NL, PL, PT, RO, SE, SI 

BE, CY, DE, EE, ES, FI, FR, IE, IT, LT, 
LV, NL, PL, PT, RO, SE, SI 

BE, FR, PT, RO, SE 

recent  EU-level  and 

Improve measures for atmospheric deposition, contaminants from 

DE, EE, ES, FI, FR, LV, NL, PL, PT, 
RO, SL 

•  Establish  more  links  with  existing  EU  policies  and  international 
instruments for contaminants, and contaminants in seafood including 
the  WFD,  Zero  Pollution  targets  and  the  National  Emissions  Ceiling 
Directive. 
•  Continue  to  work  within  the  auspices  of  the  regional  sea 
convention to ensure that regional measures against contaminants are 
implemented. 
•  Explain the manner in which the D8 measures contribute to D9 
targets including how measures will reduce levels of contaminants in 
fish and fish product.  
• 
agriculture and contaminants from marine hydrocarbon extraction.  
•  Establish  more 
regional 
developments and explain how measures contribute to reaching the 
threshold value for beach litter and Zero Pollution targets for plastic 
and microplastic reduction.  
•  Address marine litter, both in coastal areas and in the open sea, 
from  aquaculture,  urban  areas,  tourism  and  recreational  activities 
(other than recreational fisheries), as well as the removal of existing 
litter 
• 
gear, etc.) and takes measures to reduce the existing stock.  
Include  specific  measures  related  to  litter  ingested  by  animals 
• 
especially when MS have defined targets specifically for the impact of 
litter on species. 
•  Address micro-litter better preferably through direct measures, in 
accordance with recommendations of the Technical Group on Litter.  
•  Establish  more  links  with  existing  EU  policies  and  international 
instruments for underwater noise and energy, integrate the work of the 
regional  sea  conventions  and build  on  the  results  of EU  projects  to 
define practical measures to achieve GES.  
•  Establish  direct  measures  to  cover  activities  that  are  known  to 
produce  high  levels  of  noise  (e.g.  shipping,  fisheries,  recreational 
activities,  industry  (oil  and  gas),  marine  research  and  defence 
operation activities), including through the establishment of low-noise 
areas. 
•  Define GES and targets for underwater noise and energy (D11).   CY, DE, EE, ES, IT, LT, LV, NL, PT, 

Identify  pollution hot  spots  (e.g. from  plastic  pellets,  lost  fishing 

BE, CY, EE, ES, FR, LT, NL, PT, SI 

CY, EE, FI, FR, IT, LV, LT, PT, RO 

CY, FR, IE, LT, LV, PL, PT, RO, SE  

CY, ES, FR, IE, IT, RO, SI 

CY, EE, FI, FR, LV, LT, PL, RO,  SI,  

EE, FI, FR, LV, PT 

•  Establish  measures  addressing  other  anthropogenic  inputs  (e.g. 
heat or light) and create new measures addressing electromagnetic 
fields.  

CY, DE, ES, FI, FR, IE, IT, LT, LV, PL, 
PT, SE, SI 

RO, SE 

•  Provide  information  about  spatial  protection  measures  (size, 
number  and  location  of  MPAs,  conservation  objectives,  species 
protected, etc.) and explain how MPAs reduce pressures on biodiversity. 
•  Establish measures beyond spatial protection measures to ensure 
that pressures on biodiversity are addressed across all marine waters.  

CY, EE, ES, FR, IE, IT, LT, LV, NL, PL, 
PT, RO, SE, SI,  

BE, CY, ES, NL, PL, PT, SI 

Descriptor 8 and 
Descriptor 9  

Descriptor 10  

Descriptor 11  

Biodiversity 

Descriptors 1, 4 
and 6  

259 

 
Descriptor 

Recommendations 

Member State 

Include all biodiversity elements (species groups and habitats) in 

•  Take measures covering, as appropriate, hydrocarbon extraction, 
port operations, land claim and coastal defence, recreational activities 
(e.g., fishing, vessels mooring, diving), aquaculture, industry, agriculture 
and urban areas.  
• 
the gap analysis. 
including  spatial  protection 
•  Establish  additional  measures, 
measures,  to  address  relevant  pressures  on  mammals  beyond  by-
catch (e.g. impacts on mammals due to shipping (collision), underwater 
noise, entanglement, and ingestion of litter).  
•  Establish  additional  measures  to  directly  address  pressures  on 
birds,  such  as  physical  disturbances  (light  pollution,  oil  spill), 
disturbances on nesting sites by predation, oil spills, effects of NIS and 
litter ingestion, as well as measures covering birds’ food sources.  
•  Designate new MPAs including in open sea areas to protect non-
commercial fish species and cephalopods from various pressures (NIS, 
by-catch, noise and contaminants) as well as functional fish habitats. 
•  Establish  measures  for  plankton  populations,  cephalopods  and 
turtles 
• 

Include D4-food webs in the gap analysis. 

•  Design D4-specific measures, for instance by reducing fishing at a 
certain trophic level (e.g. of forage fish, that are an important source 
of food for other animals). 
Implement measures relating to bottom-towed fishing gear and 
• 
/or  provide  timescales  and  estimates  of  how  spatial  restrictions  of 
seabed damaging activities will allow for GES to be achieved. 
•  Take spatial and/or temporal measures to enhance the protection 
of mobile species which use seabed habitats (e.g. seagrass meadows) 
as nurseries (e.g. seasonal fishing restrictions) 
•  Address  also  physical  damage  from  hydrocarbon  extraction, 
coastal  development  and  protection,  and 
large-scale  shipping 
mooring. 
•  Make  reference  to  recent  EU-level  and  regional  developments, 
such as the Commission Guidelines for sustainable aquaculture, the 
Regulation (EU) No 143/2014 on the prevention and management of 
the introduction and spread of invasive alien species and Regulation 
(EC) No 708/2007 concerning use of alien and locally absent species 
in aquaculture. 
•  Take new measures to address certain pressures and activities as 
pathways of introduction: aquaculture, (including seaweed farming), 
offshore  constructions  and  hard  structures,  shipping  (including  hull-
fouling) and recreational activities. 
• 
analysis. 
•  Develop NIS early warning systems and registries 
•  Cover  nationally-managed  stocks  as  well  as  CFP-managed 
stocks.  
•  Cover  recreational  fishing  activities  where  they  exert  significant 
pressure on commercial stocks. 

Identify  where  NIS  are  still  being  introduced  through  the  gap 

260 

All MS 

All MS 

All MS 

All MS 

Descriptor 1 
(specific)  

Descriptor 4 
(specific)  

Descriptor 6 
(specific)  

Descriptor 2 

Descriptor 3 

BE, CY, DE, ES, FR, IT, LV, LT, NL, 
PT, RO 

ES, IE, IT, LT, LV, NL, PT, RO 

BE, CY, ES, FI, FR, IE, LV, NL, PT, SE 

CY, ES, IE, IT, LT, NL, PL, PT, RO, SI 

CY, ES, LT, LV, PL, PT, SI 

CY, IT, LV, LT, PL, PT, SI 

BE, CY, ES, FR, IE, IT, LT, LV, NL, PT, 
RO, SI 

BE, CY, DE, EE, ES, FR, IT, LT, LV, 
NL, PT, RO, SI 

BE, CY, FI, FR, IE, LV, NL, PT 

BE, CY, DE, EE, LT, PL 

EE, FR, NL, PT 

CY, DE, ES, LV, NL, PL, PT, SI 

CY, DE, EE, ES, FI, IE, NL, PL, PT, RO 

 
Descriptor 

Recommendations 

Member State 

•  Consider measures to address the shortcomings of D3 (including 
age/size distribution of stocks)  
•  Strengthen the links between WFD and MSFD measures to address 
the  impacts  of  terrestrial  and  marine  projects  and  activities  in 
coastal/shallow water areas, where most hydrographical changes are 
likely to occur  
•  Strengthen  regional  work  and  cross-border  cooperation  on  D7 
including in  relation  to  potential effects  of  climate  change,  such as 
changes in salinity. 
•  Explicitly  include  hydrographical  conditions  in  EIA  and  SEA 
procedures to limit pressures on benthic habitats.   
•  Address  cumulative  impacts  on  habitats  by  multiple  stressors, 
including marine hydrocarbon extraction, port operations, tourism and 
recreational activities. 
•  Address pressures from activities not subject to local/project scale 
EIAs (e.g., fishing, maritime transport).  
•  Make  use  of  the  Maritime  Spatial  Planning  Directive  and  SEA 
impacts,  tackle  hydrographical 
procedures  to 
conditions at a larger scale and support the development of forward-
looking scenarios  

limit  cumulative 

BE, CY, ES, FR, IT, LT, PL 

CY, FR, LT, LV, RO, SI 

BE, DE, IE, LT, LV, PL, PT, SI, SL 

BE, DE, IE, LT, RO 

CY, EE, FI, FR, IT, NL, LT, LV, NL, PL, 
PT, SE, SI 

CY, DE, ES, FR, IE, IT, LV, NL, PL, PT, 
SE, SI 

CY, EE, ES, FR, IE, LV, LT, NL, SE, SI 

Descriptor 7 

261 

 
 
 
Abbreviations 

BWMC 
CFP  
EIA 
EQS 
GES  
GFCM 
HELCOM 
ICCAT 
IED 
IMO 
MARPOL 
MPA  
MSFD  
MSP 
NEC 
NIS 
OSPAR 
PoM 
RBMP 
REACH 
SEA 
UNEP/MAP 

UWWTD  
WFD  

Ballast Water Management Convention 
Common Fisheries Policy 
Environmental Impact Assessment 
Environmental Quality Standards 
Good Environmental Status 
General Fisheries Council for the Mediterranean 
Convention on the Protection of the Marine Environment of the Baltic Sea Area 
International Commission for the Conservation of Atlantic Tuna 
Industrial Emissions Directive 
International Maritime Organisation 
International Convention for the Prevention of Pollution from Ships 
Marine Protected Area 
Marine Strategy Framework Directive 
Maritime Spatial Planning 
National Emissions Ceiling Directive 
Non-Indigenous Species  
Convention for the Protection of the marine environment of the North-east 
Programme of Measures 
River Basin Management Plan 
Registration, Evaluation, Authorisation and Restriction of Chemicals 
Strategic Environmental Assessment 
United Nations Environment Programme / Mediterranean Action Plan (Barcelona 
Convention) 
Urban Waste Water Treatment Directive 
Water Framework Directive 

262