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Reducing Phosphorus Input into the Baltic Sea—An Assessment of the Updated Baltic Sea Action Plan and Its Implementation through the Common Agricultural Policy in Germany

Research Unit Sustainability and Climate Policy, 04229 Leipzig, Germany
Faculty of Agricultural and Environmental Sciences, University of Rostock, 18051 Rostock, Germany
Water 2023, 15(2), 315;
Submission received: 21 November 2022 / Revised: 6 January 2023 / Accepted: 9 January 2023 / Published: 11 January 2023
(This article belongs to the Section Water Resources Management, Policy and Governance)


The eutrophication of the Baltic Sea is a longstanding environmental issue which is caused by excessive nutrient input including phosphorus. In response, neighbouring states of the Baltic Sea adopted the Helsinki Convention and the updated Baltic Sea Action Plan. The Helsinki Convention aims at the ecological restoration of the Baltic Sea. The updated Baltic Sea Action Plan summarises actions to achieve a good environmental status of the Baltic Sea. It lists the Common Agricultural Policy of the EU as supporting legislation. Against this backdrop, this article aims to assess the extent to which the measures of the Common Agricultural Policy in Germany (Mecklenburg-Western Pomerania) implement the agriculture actions of the updated Baltic Sea Action Plan and thereby contribute to the objective of the Helsinki Convention. To this end, a qualitative governance analysis is applied. Results show that the Common Agricultural Policy addresses most agriculture actions of the updated Baltic Sea Action Plan. Agri-environment climate commitments in particular have the potential to reduce phosphorus input into the Baltic Sea. However, their potential will likely be offset by (1) unclear uptake due to voluntariness, (2) limited funding and (3) continuation instead of real reform of the Common Agricultural Policy. These shortcomings are supplemented by weak actions of the updated Baltic Sea Action Plan. Therefore, other effective policy instruments at the EU level are needed.

1. Introduction

The Baltic Sea is heavily eutrophicated. Excessive input of phosphorus (P) and nitrogen (N) via air and water have caused algae blooms and oxygen-deprived zones and altered the food web [1,2,3]. The primary land-based source of P discharge into water bodies is the agricultural sector [4] [5] (p. 20) [6,7]. Unsustainable P management, i.e., fertilisation that is, for example, not adapted to plant demand and soil characteristics, and agricultural practices that induce soil degradation benefit P discharge into water bodies and thereby contribute to P accumulation in the Baltic Sea (on soil management and nutrient discharge, see [8] (Ch. 16) [9,10,11]). Climate change adds further pressure on these issues. A warming climate is expected to increase P discharges from croplands due to increased precipitation [4,12,13]. Moreover, changes in the P status of the Baltic Sea require very long time scales because only 3% of the water (by volume) is exchanged per year [14] (p. 6) and P is stored in the sediments [15,16]. Monitoring of the German Baltic Sea waters shows that they fail to achieve a good ecological status. P nutrient concentrations exceed the threshold values in all open (99.9%) and nearly all coastal (99.7%) areas. A direct effect of nutrient accumulation is decreasing water transparency. The threshold values on water transparency are exceeded in all coastal and open areas. Nutrient accumulation also indirectly impacts dissolved oxygen in the bottom of the water. The monitoring shows that threshold values are partly complied with in the open sea areas and widely complied with in coastal areas [17] (pp. 34–37). Hence, immediate and effective measures are needed to combat eutrophication in the Baltic Sea.
To address the pollution of the Baltic Sea including eutrophication caused by P discharges, the Convention on the Protection of the Marine Environment of the Baltic Sea Area—Helsinki Convention—was adopted in 1974 and updated in 1992. The Helsinki Convention requires Contracting Parties to take measures to prevent and eliminate pollution to promote the ecological restoration of the Baltic Sea Area (Art. 3 (1) Helsinki Convention). The goal of the Helsinki Convention is in line with several other European and international goals related to biodiversity and water. At the global level, the Kunming-Montreal Global biodiversity framework establishes long-term goals and short-term targets. Goal A requires the maintenance and restoration of natural ecosystems. Target 7 aims to reduce pollution including by reducing nutrient losses by at least half [18]. The United Nations Convention on the Law of the Sea obligates states to protect and preserve the marine environment which includes the Baltic Sea (Art. 192 United Nations Convention on the Law of the Sea). To this end, states have to adopt measures which, inter alia, address the release of harmful substances from land-based sources (Art. 194 (3) lit. (a) United Nations Convention on the Law of the Sea) such as P discharge. The legally non-binding Sustainable Development Goal 14 requires conserving and sustainably using oceans, sea and marine resources for sustainable development including combatting eutrophication [19] (p. 54). At the EU level, the Marine Strategy Framework Directive requires Member States to achieve or maintain good environmental status in the marine environment by the year 2020 (Art. 1 (1) Marine Strategy Framework Directive—Directive currently under evaluation). The proposal for an EU Nature Restoration Law aims at the continuous, long-term and sustained recovery of biodiverse and resilient nature across the Union’s sea areas through the restoration of ecosystems (Art. 1 (1) Proposal for a Nature Restoration Law).
Article 5 of the Helsinki Convention establishes a reference to eutrophication. It provides that Contracting Parties have to prevent and eliminate pollution of the Baltic Sea Area caused by harmful substances, such as P compounds, from all sources (Art. 5 i. c. w. Annex I Part 1.2 (g) Helsinki Convention). The Contracting Parties have furthermore developed the Baltic Sea Action Plan (BSAP) which concretises measures for the Helsinki Convention’s implementation. The BSAP was adopted in 2007 and updated in 2021. It aims to achieve good environmental status in the Baltic Sea. It includes a segment ‘Eutrophication’ aiming at a ‘Baltic Sea unaffected by eutrophication’. To this end, the EU’s Common Agricultural Policy (CAP) is listed as supporting legislation [5] (p. 9). EU Members to the Helsinki Convention are expected to fund ‘adequate measures’ under the CAP to implement the updated BSAP (ibid, p. 59).
Previous studies investigated the national implementation of the Helsinki Convention in Sweden and Poland [20], nutrient policies in the Baltic Sea Region including the CAP [21] and the extent to which countries have implemented measures of Annex II of the Helsinki Convention for example through the CAP [22]. Focussing on the original BSAP, a study discusses the enabling and constraining factors for the Plan’s national implementation [23]. Another study assesses the extent to which an ecosystem approach has been applied in the Plan [24]. Issues of the original BSAP such as high costs for nutrient reduction measures were identified [25] and proposals made to improve the policy framework for limiting nutrient discharge into the Baltic Sea, including the CAP [26]. However, little research has covered the updated BSAP, and studies have so far not addressed the extent to which the CAP contributes to the objective of the Helsinki Convention through action implementation of the updated BSAP. This article fills this research gap. It focusses on (1) measures for reducing P discharge into the Baltic Sea which is one of the two major nutrients addressed by the updated BSAP, and (2) the national implementation of the CAP in Germany, which is a Contracting Party to the Helsinki Convention. The federal state Mecklenburg-Western Pomerania serves as an example for the second pillar measures of the CAP (Figure 1). The article finds that the CAP in Germany covers most agriculture actions of the updated BSAP. However, this broad coverage will most likely not lead to substantial P input reductions into the Baltic Sea due unclear adoption and limited funding of the most effective and promising CAP measures. Furthermore, continuation instead of real CAP reform will impede substantial P reductions. Overall, this article finds that the national implementation of the CAP in Germany will, only to a limited extent, contribute to the objective of the Helsinki Convention, if at all. Hence, other effective policy instruments at the EU level are needed.
The section hereafter describes the qualitative governance analysis. The results section analyses the updated BSAP and the relevant provisions of the CAP. The discussion covers the potential and limitations of the CAP measures and shortcomings of the up-dated BSAP to reduce P discharge into the Baltic Sea, and the conclusions follow this.

2. Materials and Methods

This article provides the results of a qualitative governance analysis (Figure 2). The qualitative governance analysis aims to identify effective and concrete policy instruments to achieve a goal (for details, see [27,28,29,30]). As introduced in the previous section, multiple legal goals are relevant for this analysis, but the primary focus is on the objective of the Helsinki Convention.
Achieving these legal goals requires effective policy instruments. Policy instruments aim to change the behaviour of the addressees. However, inducing behavioural change is complex. To identify effective and concrete policy instruments, the qualitative governance analysis triangulates findings from different research backgrounds to develop novel insights. It firstly builds on findings from behavioural studies. Previous research shows that, e.g., a lack of knowledge, which informational and educational policy instruments aim at, is seldomly a primary barrier for behavioural change [31,32,33,34]. Instead, emotional factors such as self-interest, anxiety, habits, concepts of normality and path dependencies appear to be important barriers [35,36,37,38]. For example, policy instruments which induce higher prices for resource-intensive products are likely to target concepts of normality by, e.g., making the application of mineral P fertilisers, car driving or eating meat too expensive for regular doing. These barriers equally apply to all humans including farmers, consumers, politicians and entrepreneurs. The qualitative governance analysis takes these complexities into consideration. For example, when proposing an informational instrument, it will frequently be necessary to argue that this instrument alone will be insufficient to achieve substantial behavioural change. Aside from that, the findings from behavioural studies shed light onto potential governance issues of policy instruments. Potential governance issues include enforcement problems, rebound and shifting effects. Rebound effects describe situations where resource savings in one place, e.g., decreased P fertiliser application, leads to rising resource use in another place, e.g., increased cultivation area. Shifting effects describe situations where environmental problems are shifted from one sector to another, or from one region to another, for example due to differing fertilising standards [27] (Chapter 4.4) [28] (shifting effects found by [39,40]). When assessing the effectiveness of existing policy instruments and developing new policy instruments, these instruments are analysed with a view to potential governance issues.
Alongside findings from behavioural studies, the qualitative governance analysis secondly builds on findings from natural sciences, e.g., soil science and agronomy. For the purpose of this article, research on P and soil management is relevant. In short, unsustainable P management is related to, among others, inefficient P use, contamination of P rock fertilisers with heavy metals such as cadmium and uranium, and P hotspots caused by intensive livestock farming. Where the P storage capacity of soils is exceeded or, e.g., heavy rainfall clashes on bare soils, P leaches into water bodies. As limiting nutrient, P accumulation in water bodies causes increased algae growth which can ultimately result in eutrophication as in the Baltic Sea [13,26,41,42,43]. In turn, sustainable P management aims to close P cycles by, e.g., reducing P discharges into the environment, enhancing P use efficiency and P recycling, and is thereby closely intertwined with sustainable soil management and deep transformations of the agricultural sector in general. Sustainable P management requires in particular needs-based, site-adapted and crop-specific fertilisation [44,45,46], P-mobilising measures such as planting catch crops [47], replacement of fertilisers containing phosphate rock with organic/recycled fertilisers [48,49,50,51] and increased efficiency in animal feeding [52]. Besides that, the contamination of fertilisers containing phosphate rock with heavy metals has to be eliminated. Finally, as intensive livestock farming is a major driver of P accumulation in soils (and a substantial source of agricultural greenhouse gases), reducing livestock numbers is essential [53,54,55]. In doing so, sustainable P management not only contributes to closing P cycles but also to combatting climate change and biodiversity loss. For this qualitative analysis, this knowledge is used to assess the extent to which the actions of the updated Baltic Sea Action Plan and the CAP contribute to reducing P discharges into the Baltic Sea.
Against this background, the present qualitative governance analysis aims to identify effective and concrete policy instruments to achieve legal goals which result in a Baltic Sea that is not affected by eutrophication. The Baltic Sea is a semi-enclosed relatively shallow water body in Europe bordered by Russia and eight EU countries including Germany. Figure 1 shows the different sub-basins of the Baltic Sea. The Baltic Sea has a small connection to the North Sea. Inflow and exchange of water is limited which contributes to the expansion of areas with poor oxygen conditions, and substance accumulation caused by human activities. Eighty-five million people live in the catchment area of the Baltic Sea and exercise pressure on the marine environment. Sea-based pressure includes for example fishing and construction of offshore energy production. Land-based pressure covers industrial and agricultural activities [14] (Chapter 4) [16] [17] (pp. 17–22). In Germany, half of the total P load originates from agricultural activities followed by urban areas (22%) and point-sources (20%) [56] (p. 22). Twenty-nine wastewater treatment plants and two industrial plants directly release treated wastewater into the Baltic Sea [57]. In 2014, three rivers transported approximately 110 tonnes of P into the Baltic Sea [58] (p. 103). Two of these rivers, Warnow and Peene, are located in Mecklenburg Western-Pomerania. Nearly 60% of the land in the state is used for agricultural production [59] (pp. 188–189). Permanent grassland covers two thirds of the agricultural land. One third is used for crop production (ibid, p. 193). Overall, the pressure on the Baltic Sea is heavier than on most other water bodies globally [60].
For the analysis, literature was sourced from multiple databases including Google Scholar and Science Direct as well as from topical journals from different publishers including Springer, Elsevier and Wiley. Besides that, ‘snowballing’ was applied. For P specifically, earlier research on policy instruments for sustainable P management of my research unit provided a literature basis [11,28,46,53]. Besides that, literature was sourced from the publication lists of the funding projects InnoSoilPhos ( (accessed on 8 January 2023)) and Leibniz ScienceCampus Phosphorus Research Rostock ( (accessed on 8 January 2023)). For the analysis of legal acts, official national sources were used. In Germany, first pillar measures of the CAP are regulated at the federal level, and second pillar measures at the state level (Art. 4 (1) and Art. 9 (1) GAKG) (Gesetz über die Gemeinschaftsaufgabe “Verbesserung der Agrarstruktur und des Küstenschutzes” (GAKG)). Hence, the first pillar is implemented through two federal laws (GAP-Direktzahlungen-Gesetz (GAPDZG) and GAP-Konditionalitäten-Gesetz (GAPKondG)) and two federal regulations (GAP-Direktzahlungen-Verordnung (GAPDZV) and GAP-Konditionalitäten-Verordnung (GAPKondV)). The second pillar programs will be implemented through state regulations but not been adopted yet. The second pillar measures of Mecklenburg-Western Pomerania serve as example because the state has a large coastline along the Baltic Sea (Figure 1). (Proposed) area-related measures of Mecklenburg-Western Pomerania are sourced from an official document published by the Ministry for Climate Protection, Agriculture, Rural Areas and the Environment in September 2022 [61]. Measures which address investment support and knowledge exchange and dissemination of information are sourced from Germany’s revised Strategic Plan as no further details have so far been provided by Mecklenburg-Western Pomerania.

3. Results

This section is divided into three subsections. The first two subsections provide the basis for the analysis of the national implementation of the CAP in Germany and the updated BSAP in the third subsection. The first subsection covers the EU framework of the CAP. The second subsection analyses the provisions of the Helsinki Convention which are relevant for P management. The third subsection investigates the updated BSAP and the extent to which CAP measures in Germany implement the actions on eutrophication with a focus on P.

3.1. The EU Framework of the CAP 2023–2027

The CAP is the central agricultural policy of the EU. The five objectives of the CAP are established in the Treaty on the Functioning of the European Union (TFEU) and have been unchanged since the CAP’s implementation: (1) increase agricultural productivity, (2) ensure a fair standard of living, (3) stabilise markets, (4) assure the availability of supplies and (5) ensure that supplies reach consumers at reasonable prices (Art. 39 (1) TFEU). During its 60 years long existence, the CAP was reformed multiple times [62]. The most recent reform started in June 2018 when the EU Commission published its proposal for the CAP beyond 2021 (COM (2018) 392 final) and was concluded one year later [63]. The new CAP regulation establishes that, in accordance with the objectives of Art. 39 TFEU, CAP support must improve the economic, environmental and social sustainable development of the sector (Art. 5 Regulation (EU) 2021/2115). Besides these general objectives, the new CAP regulation establishes specific objectives. Relevant for this article are the objectives to foster sustainable development and efficient management of natural resources such as water and soil including by reducing chemical dependency, and to contribute to halting and reversing biodiversity loss (Art. 6 (1) lit. (e), (f) Regulation (EU) 2021/2115).
The CAP includes a comprehensive subsidy scheme which addresses farmers and beneficiaries (e.g., public or private law bodies). As in the past, the reformed subsidy scheme is divided into two pillars. The first pillar covers market management and income support. The second pillar covers rural development. Funded through the European Agricultural Guarantee Fund, first pillar subsidies are sole funded by the EU. Second pillar subsides are funded through the European Agricultural Fund for Rural Development and require co-funding from Member States (Art. 91 Regulation (EU) 2021/2115). Approximately three quarters of the EU CAP budget are allocated towards the first pillar, one quarter to the second pillar [64]. The recent reform led to substantial budget EU budget cuts for the second pillar [65]. Likewise, funding for the second pillar in Mecklenburg-Western Pomerania decreased by approximately 22% (2014–2020: EUR 1198 million; 2023–2027: EUR 940 million) [66,67] while funding for agri-environment-climate commitments of this pillar has always been low. It never exceeded 6% of the CAP budget [68].
For the funding period 2023–2027, Member States have to submit a Strategic Plan to the Commission. The Strategic Plan establishes the national implementation of the EU subsidies (Art. 1 lit. (c) Regulation (EU) 2021/2115). Once the Commission has approved the Strategic Plan, the national CAP framework enters into force (Art. 118 Regulation (EU) 2021/2115).
The first pillar of the CAP continues to provide hectare-based income support to farmers. Receipt is conditional upon compliance with the requirements established in Conditionality. Conditionality includes statutory management requirements (SMRs) and standards of good agricultural and environmental conditions of land (GAEC) (Arts. 12 and 13, Annex III Regulation (EU) 2021/2115). SMRs cover union law obligations and have to be fully implemented into national law. In contrast, Member States have flexibility in implementing GAEC. SMR 1 incorporates an obligation of the Water Framework Directive which demands controlling diffuse sources of pollution by phosphates for example through prohibiting pollutant entry into water, prior authorisation or registration (SMR 1) (Art. 11 (3) lit. (h) Directive (EU) 2000/60/EC). SMR 2 demands water protection against nitrate pollution from agricultural sources as established in the Nitrates Directive (Annex III Regulation (EU) 2021/2115). GAEC 4 requires farmers to establish buffer strips along water courses (ibid.). Member States furthermore have to provide support for certain sectors if a Member States has producer organisations in that sector (Chapter III Regulation (EU) 2021/2115).
A new instrument in the reformed CAP are voluntary annual eco-schemes (‘schemes for the climate, the environment and animal welfare’). Member States have to allocate approximately one quarter of the first pillar budget towards the eco-schemes (Art. 97 (1) Regulation (EU) 2021/2115). Eco-schemes have to go beyond the requirements of Conditionality (Art. 31 (5) lit. (a), (b) Regulation (EU) 2021/2115). Germany offers farmers seven eco-schemes. Some of these eco-schemes, such as crop diversification and extensive management of permanent grassland (Art. 20 GAPDZG). Reduced stocking densities in extensively managed grassland limit P input into the soils and hence the risk of P discharges into water bodies. Farmers receive fixed payment rates for the eco-schemes (Art. 16 (1) and Annex 4 GAPDZV). Hence, on paper, the CAP contains provisions which can reduce P discharge into the Baltic Sea. However, except for the new eco-schemes, ongoing dramatic soil and nutrient-related issues in the EU [69,70,71] question their potential.
The second pillar of the CAP provides support for rural development. In contrast to the income support of the first pillar, support is addressed at farmers and beneficiaries. Some of the measures of the second pillar have to be offered by Member States while others can be offered. For example, Member States of the EU have to provide support for advisory services (Art. 15 Regulation (EU) 2021/2115) and agri-environment-climate commitments which includes support for converting to and maintaining of organic farming (Art. 70 (8) Regulation (EU) 2021/2115). Member States can offer support for cooperation which includes support for the European Innovation Partnership ‘Agricultural Productivity and Sustainability’ (Art. 77 Regulation (EU) 2021/2115), and support for knowledge exchange and dissemination of information (Art. 78 Regulation (EU) 2021/2115). Hence, the overall CAP structure and finding imbalances remain.

3.2. The Helsinki Convention and P

The governing body of the Helsinki Convention is the Baltic Marine Environment Protection Commission (HELCOM) whose obligations include to keep the implementation of the Convention under observation, to make (non-binding) recommendations, and to define objectives for pollution reduction and objectives for measures implemented under the Convention (Art. 20 (1) Helsinki Convention) [20] (p. 229) [72] (p. 475). An enforcement mechanism is not established [20,60,73]. In addition, the Convention addresses principles and obligations for pollution from land-based sources such as P discharge. Contracting Parties are required to prevent and eliminate pollution of the Baltic Sea Area from land-based sources by using Best Environmental Practice for all sources (e.g., P discharge from agriculture) and Best Available Technology for point sources (e.g., P discharge from wastewater treatment plants). These measures must include the catchment area of the Baltic Sea (Art. 6 (1) Helsinki Convention) (Figure 1). Best Environmental Practice means ‘the most appropriate combination of measures’. Measures may include informational and educational instruments, the development and application of Codes of Good Environmental Practice, and measures for resource savings (Annex II Helsinki Convention). Contracting Parties are furthermore required to implement measures of Annex III of the Helsinki Convention (Art. 6 (2) i. c. w. Annex III Helsinki Convention): To better manage nutrients, Contracting Parties must integrate certain principles into their legislation or guidelines. These principles include for example a livestock-to-land ratio, application rates for nutrients, having winter crops in ‘relevant regions’, and establishing water protection measures and nutrient reduction areas (Annex III Part II Helsinki Convention). The updated BSAP adopts these measures as analysed below.

3.3. The Updated Baltic Sea Action Plan and CAP Implementation

The BSAP (in part) evolved from EU provisions. The Helsinki Convention is one of four Regional Sea Conventions which cover the marine waters of the EU. It is integrated into different EU policies including the Marine Strategy Framework Directive 2008/56/EC. The Directive establishes that Member States must use, where practical and appropriate, existing regional institutional cooperation structures, i.e., Regional Sea Conventions such as the Helsinki Convention, to facilitate cooperation between Member States which share a marine (sub)region (Arts. 5 (2) and 6 (1) Directive (EU) 2008/56/EC). This obligation led to the development and implementation of the first BSAP in 2007 [5] (p. 4) [74] [75] (p. 374).
The failure to achieve the objectives of the original BSAP required an update of the Plan in 2021 [5] (pp. 4–5). The original BSAP had aimed a good environmental status of the Baltic Sea by 2021 including a Baltic Sea unaffected by eutrophication [76] (pp. 5, 7). However, neither was the overall goal achieved nor eutrophication eradicated. This is in part because Contracting Parties have not reached the targets for nutrient inputs. While P reduction from point sources such as wastewater treatment plants and the industry, i.e., low hanging fruits, has been achieved, issues persist with P (and N) inputs from non-point sources from agriculture [5,60,73]. Some argue that failure to implement effective measures is connected to the public good character of the Baltic Sea and an asymmetry of cost and benefit distribution between the neighbouring states of the Baltic Sea [77]. Others see the issue in the allocation of property rights of agricultural land [78]. Connected to that are findings which highlight the cost ineffectiveness of the nutrient targets and perceived unfairness with regard to the abatement costs [25]. Economic inequalities of farmers, the failure to address livestock hotspots, lacking knowledge and inadequate funding for effective measures complement the picture [26].
An updated BSAP, which aims again at achieving a good environmental status in the Baltic Sea, was adopted in 2021 [5] (p. 5). The Plan is divided into four segments, each with one overall goal and multiple ecological objectives and management objectives. The segment ‘Eutrophication’ aims again at a Baltic Sea unaffected by eutrophication (overall goal) and adopts the ecological objectives of the original BSAP: (1) concentrations of nutrients close to natural levels, (2) clear waters, (3) natural level of algal blooms, (4) natural distribution and occurrence of plants and animals and (5) natural oxygen levels. The management objective of this segment aims to minimise the nutrient inputs from human activities (ibid, pp. 20–22). While the updated BSAP as a whole has to be implemented by 2030 (ibid, p. 5), nutrient input reduction measures have to be implemented by 2027 (ibid, p. 22).
The updated BSAP includes specific nutrient targets to combat eutrophication. To achieve the ecological objectives, the updated BSAP, like its predecessor, establishes maximum allowable inputs of nutrients to the Baltic Sea sub-basins (sub-basins shown in Figure 1). Maximum allowable inputs establish the maximum nutrient level to the Baltic Sea and its sub-basins. For example, the maximum allowable input of P for the entire Baltic Sea is 21716 tonnes of total P annually [5] (p. 22). Net nutrient input ceilings lay down the maximum inputs via water and air for the sub-basins for each Contracting Party (Table 1). They are a share of the maximum allowable inputs. The maximum allowable P input into the Baltic Proper is 7360 tonnes per year. Germany is allocated a net nutrient input ceiling of 109 tonnes of P per year. The maximum allowable P input into the Danish Straits is 1601 tonnes per year. Germany is allocated a net nutrient input ceiling of 401 tonnes of P per year. In 2017, Germany’s estimated P inputs exceeded the net nutrient ceiling in the Baltic Proper by 372 tonnes and stayed below the net nutrient ceiling in the Danish Straits by 51 tonnes. Hence, current policy measures appear ineffective to reduce P input into the Baltic Sea and more effective measures are needed.
Besides that, the updated BSAP lists actions to achieve the ecological objectives. These actions are divided into five themes:
  • Follow-up of the implementation of nutrient input targets;
  • Agriculture;
  • Atmospheric nitrogen emissions;
  • Wastewater sector;
  • Nutrient recycling.
With 15 actions, the theme agriculture includes most actions followed by the themes wastewater sector and nutrient recycling each with seven actions [5]. Even though some actions of theme nutrient cycling could possibly be implemented through the CAP in Germany, to keep the focus of the article, this article analyses only the actions of theme ‘agriculture’. In general, the agriculture actions frequently do not express an obligation but ‘soft’ action. Actions require Contracting Parties to ‘promote’, ‘investigate, ‘discourage’, ‘improve’ and ‘review’. Where imperatives express an obligation such as ‘implement’, ‘enforce’, ‘apply’ and ‘establish’, the corresponding obligations are weak: ‘Apply as a minimum the EU’s updated Best Available Techniques (BAT) Reference Document…’ [5] (pp. 24–25). One exception is the obligation to establish buffer zones to reduce nutrient discharges from agricultural land which could be an effective action to combat eutrophication in the Baltic Sea through P (ibid, p. 24).
Figure 3 presents the first pillar measures of the CAP which can implement agriculture actions on eutrophication of the updated BSAP. Figure 4 covers second pillar measures. Not depicted in Figure 4 because of their overarching character are two actions. These actions address national instruments and can hence only be implemented through the second pillar of the CAP. E 16 covers a review of national regulations and voluntary measures to reduce P losses from agriculture. E 17 demands national measures to reduce nutrient surplus from fertilisation practices. The analysis below will show that Germany adopted second pillar measures to reduce both P losses from agriculture and P surpluses, and hence covers these actions.
The figures highlight that, in addition to E 16 and E 17, eight of the 15 agriculture actions of the updated BSAP can principally be implemented through the CAP. First pillar measures only address three actions, second pillar measures address nearly all actions. Some CAP measures can implement two or three actions of the updated BSAP. For example, to receive income support, Conditionality requires farmers to establish buffer strips along water courses with a minimum width of three metres (Art. 15 (1) GAPKondV). This requirement can implement actions E 5 and E 6. Mecklenburg-Western Pomerania offers additional support for wider buffer strips and buffer strips at the edges of protected biotopes under the second pillar of the CAP which hence addresses the same actions of the updated BSAP. Second pillar support for the conversion to and maintenance of organic farming addresses the promotion of organic farming (E 9) and a ‘balanced’ livestock density (E 5) as organic farming requires land-related livestock production (Art. 5 (f) lit. (ii) Regulation (EU) 2018/848). Support for extensively managed grassland also addresses a ‘balanced’ livestock density (E 5) as this measure demands a reduced livestock density. In addition, this CAP measure can implement site-specific fertilisation (E 7) as fertiliser application is only permitted on permanent grassland where nutrient levels are below the optimum and thus reduce P surpluses.
Other CAP measures address single actions of the updated BSAP. Sectoral support includes support for better water management which can cover action E 19. However, Member States to not have to implement this measure as they are free to pick suitable measures from a list established in Art. 42 of Regulation (EU) 2115/2022. Second pillar support for winter greening in the vegetable sector addresses one element of E 5. In addition, Mecklenburg-Western Pomerania offers multiple agri-environment-climate commitments for soil protection. Soil protection measures include support for erosion control areas, strip-till farming and direct seeding, and crop diversity. Support for erosion control areas contributes to E 7 (site-specific fertilisation) as fertiliser application is prohibited on these areas. CAP investment support for farm modernisation includes support for precision farming machinery. Hence, this measure contributes to one element of E 7 (promote precision fertilisation). Finally, Mecklenburg-Western Pomerania offers different measures for actions E 11 and E 12 such as support for advisory services. Within the first pillar, SMR 1 of Conditionality and GAEC 2 touch upon the water protection measures of Part 2 of Annex III of the Helsinki Convention (E 5). GAEC 2 covers a minimum protection for wetlands and peatlands by keeping and restoring wetlands and thus preventing P discharges into water bodies. A third obligation of Conditionality obligates farmers to have a minimum soil cover ‘in periods that are most sensitive’ (GAEC 6) and thereby also addresses one element of E 5. Besides Conditionality, an eco-scheme of the first pillar can contribute to implementing action E 5 (‘balanced’ animal density). The eco-scheme provides support for the extensification of permanent grassland with reduced livestock numbers per hectare (Section 3.1). Overall, second pillar measures appear dominant in implementing the eutrophication actions of the updated BSAP.
The CAP does not address two actions. Action E 8 demands the protection of clay soils to reduce P losses and action E 10 to not apply manure and other organic fertilisers in the autumn in fields without green plant cover in winter. In turn, three actions do not appear applicable to the CAP (E 13–E 15). For example, action E 14 requires Contracting Parties to develop recommendations for manure management for horses, sheep, goats, and fur farming by 2025. Still, overall, Germany’s CAP implementation covers most agriculture actions of the updated BSAP.

4. Discussion

The results show that CAP measures can principally implement most agriculture actions on eutrophication of the updated BSAP in Germany. In doing so, CAP measures address different aspects of sustainable P management (Section 2) including, e.g., site-specific fertilisation through supporting the extensification of permanent grassland (Pillar II) and reduced livestock density through organic farming support (Pillar II) and eco-schemes (Pillar I). In addition, the inclusion of managing P pollution into the mandatory requirements of Conditionality is a welcome addition (Section 3.1). Moreover, using approximately one quarter of the first pillar budget for eco-schemes instead of direct payments will likely reduce the negative impacts of CAP support [81,82,83,84] and might contribute to reducing P discharges into the Baltic Sea and hence the objective of the Helsinki Convention. However, these benefits might be offset by three major issues of the CAP in Germany:
  • Unclear adoption: Two policy instruments of the ‘green architecture’ of the CAP, i.e., eco-schemes and agri-environment-climate commitments, are voluntary instruments (Section 3.1). As voluntary instruments, their uptake is unknown and hence effects on P discharges uncertain. Voluntariness not only impacts the general uptake but also the geographical implementation [21,73]. Geographical implementation is an important aspect as the catchment area of the Baltic Sea does not cover the entire area of Mecklenburg-Western Pomerania (Figure 1). To achieve P discharge reduction into the Baltic Sea and to avoid shifting effects, catchment-scale implementation appears useful [85,86,87] but is missing in the proposed measures of Mecklenburg-Western Pomerania.
  • Limited funding: The issue of limited funding impacts strongly the second pillar including agri-environment-climate commitments which can benefit climate and biodiversity (Section 3.1) [88,89,90]. However, more funds could have also been allocated to the eco-schemes. In Germany, funding for eco-schemes is at the lowest end of the permitted funding range. In fact, the Commission finds that eco-scheme funding is too low and required funding amendments [91]. In addition, inadequate payment levels for farmers will likely impede adoption [92,93]. Against the backdrop of current high production costs, farmers urge that the fixed payment rates for eco-schemes have to be increased to ensure uptake (Section 3.1) [94,95,96]. In response, Germany revised the payment rate for one eco-scheme and will review payment levels in light of their uptake in 2023 [66]. However, this little amendment will certainly be insufficient to ensure wide application of these measures. To achieve substantial P reductions, funding cuts and underfunding are counterproductive. Instead, effective CAP measures require funding increases.
  • Continuation instead of real reform: The CAP subsidy scheme as a whole has not been comprehensively reformed, except for the introduction of the eco-schemes (Section 3.1) [82,97,98,99]. Measures such as establishing buffer strips and protecting wetlands and peatlands have been a mandatory standard of the first pillar of the CAP for multiple years. However, these standards–summarised under ‘cross conditionality’ in the past–have not achieved a turnaround in soil degradation [11,81,100]. In fact, soil erosion and degradation have been an ongoing, frequently worsening issue in the EU (Section 3.1) and are linked to increasing P discharge into the environment including the Baltic Sea [69]. This is also reflected in missing a net nutrient input ceiling of the updated BSAP (Section 3.3). These trends will most likely not be turned around by the new P controlling requirement of Conditionality (SMR 1) because controls such as prior authorisation or registration are far away from fertilisation practices. It is furthermore inappropriate that farmers are paid for pollution reduction measures rather than enforcing the polluter pays principle as established in EU primary law (Art. 191 (2) TFEU). The overall continuation also implies that administrative complexities, insufficient transparency and enforcement issues continue to exist [101,102].
In addition, counterproductive incentives of the CAP continue to exist. For example, CAP subsidies are associated with production intensification and unsustainable fertiliser/P management [60,73,103,104]. Against this backdrop, it is unfortunate that Germany does not use its flexibility to adopt ambitious P and soil requirements which would also contribute to the recently published EU’s fertilisation strategy [95]. Buffer strips offer one example for Germany’s unambitious policy making. P retention capacity of buffer strips–and hence decreased P discharges into water bodies–increases with buffer strips width [105,106]. However, Germany sticks to the EU minimum width requirement (Section 3.3) instead of implementing an ambitious standard and hence an effective measure to avoid P discharges into the Baltic Sea.
Overall, despite addressing most agriculture actions of the updated BSAPs, the measures of the reformed CAP will most likely, to a limited extent, reduce P discharges into the Baltic Sea and hence contribute to the objective of the Helsinki Convention. This finding aligns with results of another study on the implementation of the Helsinki Convention. The study finds substantial shortcomings in national policies, including CAP measures, on nutrient management not only but also in Germany [22].
In addition to the inadequacies of CAP measures, the actions listed in the updated BSAP predominantly do not express mandatory obligations (Section 3.3). Where they do (buffer zones), the national implementation in Germany is insufficient–as argued above. Aside from these shortcomings, the actions on eutrophication, except for promoting a ‘balanced’ livestock density and organic farming, fail to address a major driver of eutrophication which is livestock farming [26,43,53]. In doing so, the actions of the updated BSAP generally miss an important mark. In addition, as small-scale instruments, these actions will frequently suffer from shifting effects and enforcement problems as further discussed below.
Legally binding goals such as those of the Helsinki Convention do not induce change unless accompanied by effective instruments and enforcement mechanisms (see also [107]). However, neither the one nor the other are established in the Helsinki Convention (Section 3.2). Complicating matters is the unclear legal status of the updated BSAP and counterproductive incentives of the CAP (see above). In addition, it is questionable if the original BSAP led to the introduction of new measures, or if only existing instruments, e.g., agri-environment-climate commitments of the CAP or measures from the Nitrates Directive have simply been inserted into the reporting to HELCOM [20] (p. 234) [75] thus not requiring any policy change at all.
Overall, the question remains why the updated BSAP partly needs to reiterate obligations of EU legislation. For example, action E 5 requires ‘balanced livestock densities’ which is also incorporated in organic farming and supported through the second pillar of the CAP and listed in Annex II of the Helsinki Convention (see also [29]). Likewise, action E 18 of the updated BSAP (adoption of ‘agri-environment measures by 2024′) is a mandatory obligation of the CAP (Section 3.1). As such, the updated BSAP duplicates already existing mandatory obligations. While incorporating actions into the updated BSAP arguably makes these actions more tangible to stakeholders and allows for participatory governance [20,73,108], it adds complexity to an already highly complex legal system and thereby, e.g., exaggerates enforcement problems [75]. Ideally, the measures adopted at the EU level would be effective in addressing eutrophication in the Baltic Sea (and other water bodies). Therefore, amending and aligning EU legislation to legally binding goals such as the Helsinki Convention, the Convention on Biological Diversity and the Paris Agreement, and addressing the drivers of global environmental issues, i.e., livestock farming and fossil fuels [29,53,109,110], is more effective than amending the (eutrophication) actions of the updated BSAP. To this end, further reforming the EU Emissions Trading System to fully phase out fossil fuels and implementing an emissions trading scheme for the livestock sector appears very effective [110,111,112]. These mandatory instruments address the major drivers of global environmental problems including eutrophication and avoid typical governance issues.

5. Conclusions

The eutrophication of the Baltic Sea is a longstanding environmental issue which is caused by excessive nutrient input including P input. The neighbouring countries to the Baltic Sea have adopted the Helsinki Convention and the updated BSAP which aim at the ecological restoration of the Baltic Sea including a Baltic Sea that is unaffected by eutrophication. EU Members to the Helsinki Convention are expected to use the CAP to implement the actions of the updated BSAP. This article adopts a qualitative governance analysis which shows the broad coverage of the actions through the CAP. In particular, the second pillar measures can implement multiple actions and thereby contribute to reducing P discharges into the Baltic Sea. However, their potential will likely be offset by unclear adoption and limited funding. Furthermore, continuation instead of real CAP reform will impede substantial P reduction achievements in Germany. Overall, this article finds that the national implementation of the CAP in Germany will, only to a limited extent, contribute to the objective of the Helsinki Convention, if at all. A greater effect of CAP subsidies could have been achieved if Germany had used its flexibility to adopt ambitious P and soil standards in its national CAP Strategic Plan. This article concludes that implementing other effective policy instruments at the EU level which are aligned to global environmental goals is more effective than amendments to the updated BSAP.


This research was partly funded by the German Federal Ministry of Education and Research (BMBF) within the BonaRes project InnoSoilPhos (No. 031B1061A) and by the Leibniz Association within the Leibniz ScienceCampus Phosphorus Research Rostock.

Data Availability Statement

Not applicable.

Conflicts of Interest

The author declares no conflict of interest.


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Figure 1. Baltic Sea sub-basins and catchment area (own figure based on (accessed on 8 January 2023)).
Figure 1. Baltic Sea sub-basins and catchment area (own figure based on (accessed on 8 January 2023)).
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Figure 2. Overview of the qualitative governance analysis (based on [29]).
Figure 2. Overview of the qualitative governance analysis (based on [29]).
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Figure 3. Relevant first pillar CAP measures for agriculture actions of the updated BSAP (based on [5,61].
Figure 3. Relevant first pillar CAP measures for agriculture actions of the updated BSAP (based on [5,61].
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Figure 4. Relevant second pillar CAP measures for agriculture actions of the updated BSAP (based on [5,61,80]).
Figure 4. Relevant second pillar CAP measures for agriculture actions of the updated BSAP (based on [5,61,80]).
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Table 1. Phosphorus input ceilings and fulfilments of Germany (based on [5,79]).
Table 1. Phosphorus input ceilings and fulfilments of Germany (based on [5,79]).
Maximum Allowable Input of Total Phosphorus (Tonnes/Year)Net Nutrient Input Ceiling of Phosphorus of Germany (Tonnes/Year)Estimated Phosphorus Inputs 2017 Including Uncertainty (Tonnes)P Input Ceilings Fulfilment (Tonnes)
Baltic Sea sub-basinsKattegat1687
Danish Straits1601401350+51
Baltic Proper7360109481−372
Bothnian Sea2773
Bothnian Bay2675
Gulf of Riga2020
Gulf of Finland3600
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Heyl, K. Reducing Phosphorus Input into the Baltic Sea—An Assessment of the Updated Baltic Sea Action Plan and Its Implementation through the Common Agricultural Policy in Germany. Water 2023, 15, 315.

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Heyl K. Reducing Phosphorus Input into the Baltic Sea—An Assessment of the Updated Baltic Sea Action Plan and Its Implementation through the Common Agricultural Policy in Germany. Water. 2023; 15(2):315.

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Heyl, Katharine. 2023. "Reducing Phosphorus Input into the Baltic Sea—An Assessment of the Updated Baltic Sea Action Plan and Its Implementation through the Common Agricultural Policy in Germany" Water 15, no. 2: 315.

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