Fisheries experts on the Council’s TAC decision: Too big risk – May be illegal
A doubling of the total allowable catch (TAC) of herring in the central Baltic Sea and a substantial increase in the Gulf of Bothnia were among the outcomes of the negotiations on catch limits for 2025 in the EU Council of Ministers. “Absolutely devastating for the herring stocks and for the Baltic Sea ecosystem”, comments fisheries scientist Henrik Svedäng at the Baltic Sea Centre.

Published 2024-10-30.
On Tuesday 22 October, the EU Council of Ministers reached a decision on fishing opportunities for herring, cod, plaice, sprat and salmon in the Baltic Sea. The Council's press release states that the catch limits are in line with scientific advice from the International Council for the Exploration of the Sea (ICES), but this is a misconception, according to Charles Berkow, policy analyst at the Baltic Sea Centre.
"The ministers seem to have confused forecasts with recommendations, stopped reading after the first few lines, missed all the caveats and warnings in the advice, and forgotten the objectives of their own regulations," he says.
The regulation of TACs is one of the tools in the multi-annual plan for Baltic fisheries, which is based on the EU's Common Fisheries Policy. One of the objectives of the multi-annual plan is to ensure that fish stocks are productive. In technical terms, this means that stocks should be at least at a level known as MSY-Btrigger.
Doubled TAC for Central Baltic herring
The Council of Ministers' decision means that the TAC for Central Baltic herring will be increased by 108 per cent next year, in line with the Commission's proposal. The increase comes despite the fact that the Commission's scientific documentation shows that even if fishing were to cease completely, there is a high risk (55 per cent) that the MSY-Btrigger target will not be reached.

"The ministers' decision is not in line with the objectives of the Common Fisheries Policy and may therefore be illegal," says Charles Berkow.
Fisheries scientist Sara Söderström at the Baltic Sea Centre points out that the situation for the central herring stock has been critical for several years.
"Now, according to the latest assessments, it has just risen above the disaster level. But instead of allowing the stock to recover, it is being allowed to continue to fluctuate at a subsistence level. It would be much better to let it rebuild properly," she says.
Environmental objectives to be taken into account
Another objective of the multi-annual plan is to achieve good environmental status, as set out in the Marine Strategy Framework Directive. Good environmental status includes biodiversity (in the case of herring, for example, the maintenance of subpopulations) and a natural age and size distribution within populations.
“The population structure of the central fish stock is probably already depleted and several sub-populations may be close to extinction”, says Henrik Svedäng, fisheries scientist at the Baltic Sea Centre. “This development is clear from both our own studies and fishermen's accounts. It is therefore particularly serious to continue fishing at a level that will most likely result in the stock not reaching its target."
But it is not only the herring stock itself that is affected by high fishing pressure. Henrik Svedäng points out that because herring are such an important part of the food chain, declining herring stocks have a major impact on the whole ecosystem.
“What is calculated as maximum sustainable yield (MSY) for a fish stock is basically based on very uncertain calculations and assumptions. But fishing at MSY for an important forage fish like herring is completely unreasonable, as it means pulling the rug out from under species higher up the food chain," he says.
Increased TACs in the Gulfs of Bothnia and Riga
The TACs for the herring stocks in the Gulf of Bothnia and the Gulf of Riga are also increased, by 21 per cent and 10 per cent respectively, as proposed by the Commission.
However, the scientific information from ICES for herring in the Gulf of Bothnia also contains several warnings. Even with zero fishing, the stock is not expected to reach the management plan's MSY trigger level. It also notes that older fish are in short supply, making the stock as a whole more vulnerable, and that local sub-populations are at risk of being wiped out, threatening to undermine the productive capacity of the stock.
"All this argues for lower quotas, but ministers have not taken this into account in their decision," says Charles Berkow. "There are particularly large uncertainties in the forecasts, and if the older year classes are fished out, there are greater risks to the stock. In addition, the actual quotas could be up to 10 per cent higher than the Council decision if Sweden and Finland use the possibility to carry over unused quotas from previous years (so-called ´inter-annual flexibility´) as they have in the past."

Henrik Svedäng points out that herring stocks in the Gulf of Bothnia have been declining for almost 35 years in a row.
"The increased TAC makes it even less likely that the stock will recover," he says. "The skewed age distribution with few older individuals shows that fishing pressure is likely to be higher than the stock can withstand."
Fisheries closure with minimal effect
In addition to the TACs, the Council for 2024 decided on a seasonal fishing closure, so-called spawning closure for the pelagic fisheries in performed with vessels larger than 12 metres in Gulf of Bothnia. The Council decision makes no mention of such a closure for 2025.
For 2025 the Council agreed on a closure of pelagic trawling in the central Baltic Sea between 1 May and 31 July, according to the Council to protect spawning sprat. Sweden and Latvia have an opportunity to compensate fishers if they close their fishery an extra month.
“If such a closure were to have an effect, it would have to be placed during a time when fishing is taking place. In the case of herring in the central Baltic Sea, for example, it makes no sense to place it during the summer when there is hardly any fishing at all,” says Henrik Svedäng. “If the fishers are compensated for this closure, it will be a clandestine subsidy to the industry.”
“Cod sacrificed for plaice fishery”
For the collapsed eastern and western cod stocks and the western herring stock, only by-catch fishing will be allowed in 2025. For cod, the TACs for by-catch (430 and 266 tonnes respectively) are lower than this year's, but higher than proposed by the Commission. For the western herring stock, this year's by-catch limit (788 tonnes) is maintained, despite the Commission's proposal to halve it.
"The EU needs to clarify what is meant by 'by-catch', how it will be managed and what the consequences will be," Berkow continues:
"The management plan specifies what the target catch is - herring, sprat and cod. Flatfish are classified as by-catch. But the European Commission and the Council of Ministers have repeatedly treated herring and cod as by-catches instead. In other words, they are prepared to ignore EU stock targets for cod and herring in order to catch flatfish and sprat. Increasing the by-catch quota for cod effectively means sacrificing cod for plaice fishing".
Reduced quotas for sprat
The TAC for sprat will be reduced next year (to 139,500 tonnes), but the Commission had proposed a larger reduction. The sprat stock used to be strong, but current projections only reach the stock target based on assumptions that ICES itself has described as optimistic.

“Recruitment of sprat has been poor for several years in a row, yet they are not deciding on a reduction as large as proposed”, says Sara Söderström.
The fisheries experts explain that the TAC decision clearly violates article 4.6 in the multi-annual plan, in which it is stated that TACs should be set at a level where the risk is less than 5 per cent that the spawning stock biomass of stock in question will fall below the crisis level MSY-Blim. The same point is made by the Commission, in a news announcement, as well as in the document from the Council:
”However, the Commission is concerned that some elements of the agreement are less likely to contribute to the recovery of certain stocks than the Commission proposal and may not be in line with the applicable legal framework, including the Baltic multiannual plan. This is the case for the total allowable catches (TACs) for sprat and western herring, as well as continued targeted commercial fisheries for western Baltic herring and recreational fisheries for main basin salmon.”
“The situation is indeed very concerning”, says Sara Söderström. “If you combine the sprat and herring fisheries, we are talking about 330,000 tonnes of biomass being removed from the Baltic Sea. It is clear that this has a major impact on the ecosystem. This year's TAC decision is far too risky for both fish stocks and the Baltic Sea environment.”
Text: Lisa Bergqvist
TAC:s 2024 (tonnes) |
Kommissionens förslag 2025
|
Council agreement 2025 (tonnes) |
Variation (%) |
|
Herring |
||||
Bothnian herring | 55 000 | 66 446 | 66 446 | +21% |
Western herring |
788 |
394 (by-catch only) |
788 |
0% |
Central herring | 40 368 | 83 881 | 83 881 | +108% |
Riga herring | 37 959 | 41 635 | 41 635 | +10% |
Cod |
||||
Eastern cod | 595 (bifångst) | 191 (bifångst) |
430 (bifångst) |
-28% |
Western cod | 340 (bifångst) | 93 (by-catch only) | 266 (by-catch only) |
-22% |
Plaice |
11 313 | 11 313 | 11 313 | 0% |
Salmon |
||||
Main basin | 53 967 specimens | 34 787 specimens (by-catch only) | 34 787 specimens (by-catch only) | -36% |
Gulf of Finland | 10 144 specimens | 8 117 specimens | 10 144 specimens | 0% |
Sprat |
201 000 | 117 070 | 139 500 | -31% |
Further reading
Policy memo: Decision-makers need to read the ’fine print’ in ICES advice (Policy memo från Stockholm University Baltic Sea Centre)
A proposal for no progress towards unmet goals, based on uncertainties (analysis by Charles Berkow)
Svedäng et al 2023: A Baltic pelagic fish community revisited: Indications of profound changes in species composition in the Stockholm Archipelago (scientific study published in Fisheries Research)
Last updated: October 30, 2024
Source: Baltic Sea Centre