Stockholm University Baltic Sea Centre

We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes.

Stockholm University Baltic Sea Centre would like to stress that the primary objective of the Ocean Act should be to restore and maintain a good environmental status of the ocean; the short-term goal should be improvement, while avoiding further (especially irreversible) damage. When developing a new Ocean Act, the issue of goal conflicts must be addressed.

We welcome a careful and limited revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals, REACH, to better protect humans and the environment against hazardous chemicals and promote a sustainable use of chemicals. It is key, however, that a revision does not lead to a weakened chemicals regulation, in any aspect.

We welcome the Commission’s analysis that the current directive is not sufficiently considering risks of modern society’s use of thousands of chemicals, and its ambition to address this weakness. We further agree with the Commission that the UWWTD needs to be part of the solution to fulfil and reach the targets under both the WFD and the MSFD.

Researchers at the Stockholm University Baltic Sea Centre (BSC) are deeply concerned about the lack of progress in attaining the MSFD GES. On the contrary, the marine ecosystems, not the least in the Baltic Sea, are degrading. The most apparent reasons for this failed status is the continued high and unsustainable fishing pressure and climate change.

Reply from Stockholm University Baltic Sea Centre: SUMMARY A deletion or change to Art. 4.6 in the Baltic multiannual plan (MAP) would in all probability lead to less legal clarity. Complaints of a lack of legal certainty or overlapping with other rules in the MAP are based on a misunderstanding. If there were uncertainty about how to interpret and implement the 5% rule it could be remedied by recourse to court.

Summary – for more information please read the enclosed document The Stockholm University Baltic Sea Centre (transparency reg no 514687319814-91) strongly supports the Commissions aim of closing the nutrient loops.

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

The Stockholm University Baltic Sea Centre’s comments to the Environmental Action Programme to 2030 (COM(2020) 652 final 1. An action programme covering such a broad area needs clear, coherent and mutually supporting policies. Although it contains a lot of positive elements, it is doubtful if the proposal meets these criteria. 2.

This submission from the Stockholm University Baltic Sea Centre focusses on conditions in the Baltic Sea. References may be found on our website https://www.su.se/stockholm-university-baltic-sea-centre/ . EELS The mismanagement of the European eel offers a clear illustration of the state of play of the common fisheries policy.

SUMMARY 1. Management has not been successful in the Baltic. 2. To take account of uncertainty in the scientific assessments, the Commission should propose TACs in line with F-lower for stocks assessed as being in good shape; for others, TACs should by 50% of Fmsy. 3.