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Opinion of the European Economic and Social Committee – Joint Communication to the European Parliament and the Council – The European Union’s strategic approach to the Black Sea region (JOIN(2025)135 final)

EESC 2025/02608

OJ C, C/2026/877, 27.2.2026, ELI: http://data.europa.eu/eli/C/2026/877/oj (BG, ES, CS, DA, DE, ET, EL, EN, FR, GA, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)

ELI: http://data.europa.eu/eli/C/2026/877/oj

Date of document:: 03/12/2025; Date of vote
Date of vote:: 03/12/2025
Date lodged:: 14/07/2025

Author:: European Economic and Social Committee
Responsible body:: Section for External Relations, EESC_REX
Rapporteur:: Milena ANGELOVA
Form:: Opinion
Internal reference:: REX/609, AVIS-SECTION 2025/2608 FIN
Session:: 601

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Treaty on the Functioning of the European Union

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12016E304

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11.70.10.00 External relations / Development policy / General
13.30.99.00 Industrial policy and internal market / Internal market: approximation of laws / Other sectors for approximation of laws

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C/2026/877

27.2.2026

Opinion of the European Economic and Social Committee

Joint Communication to the European Parliament and the Council – The European Union’s strategic approach to the Black Sea region

(JOIN(2025)135 final)

(C/2026/877)

Rapporteur:

Milena ANGELOVA

Advisor	Daniela BOBEVA
Referral	European Commission, 14.7.2025
Legal basis	Article 304 of the Treaty on the Functioning of the European Union
European Commission documents	JOIN(2025)135 final
Section responsible	External Relations
Adopted in section	7.11.2025
Adopted at plenary session	3.12.2025
Plenary session No	601
Outcome of vote (for/against/abstentions)	186/1/3

1. CONCLUSIONS AND RECOMMENDATIONS

1.1.

The European Economic and Social Committee (EESC) welcomes the long awaited European Commission’s and High Representative Vice-President’s (HRVP) initiative upon invitation by the European Council (1) to devote particular attention to the Black Sea region, proposing for it an European Union (EU) strategic approach – a ‘hub of security, stability and prosperity’ (‘the strategic approach’). This initiative reflects the recent changes in the geopolitical situation and lays the foundations for a comprehensive approach in the face of uncertainty, fragmentation and ambiguity for the future of the Black Sea region. However, the EESC notes, that it comes with a certain delay and calls for swift and decisive actions to implement it and to secure it with sufficient resources.

1.2.

The EESC stresses that although all countries in the region are bearing the negative consequences of military hostilities, targeted social and economic support has not been provided to all of them in proportion to their efforts and sacrifices. This is especially valid for Bulgaria and Romania, where the latest example is the failure of the EU Budget 2028-2034 proposal to recognise the Black Sea as a war border. Both countries are acting prudently in supporting Ukraine, Moldova and other affected countries, applying the Commission policy of sanctions against Russia, sacrificing many sources of competitiveness and paying a heavy price as their economies shrink, while other countries in the region are deriving gains (2).

1.3.

The EESC urges the Commission, in consultation with EU Member States, the countries in the Black Sea region and all stakeholders, to proceed rapidly, ideally by the end of 2025, with preparing a pragmatic and properly funded strategy for the development of the region (‘the strategy’). It must comprise a concrete action plan, a clear implementation timeline, and, most importantly, a dedicated budget, aimed at overcoming the problems and challenges that have built up there, and through it to outline a longer-term vision for the EU’s cooperation and role in the region.

1.4.

The EESC regrets that the previous EU framework policy (Black Sea Synergy (BSS) from 2007 (3)) for the region was not covering the security dimension and underlines the need for the EU’s security initiatives in the Black Sea region to deliver tangible results. It stresses the need to address the lack of effective strategic coordination both between Member States and EU institutions and between the EU, NATO (4) and other international organisations (UN, OSCE, etc.). This is badly needed given the increased militarisation of the Black Sea region, which has an adverse impact on socio-economic development.

1.5.

The EESC highlights the need to urgently develop and upgrade the previous policy framework (BSS) for the region and the new EU strategic approach in order to help regional actors to develop a common vision for regional cooperation in the Black Sea region (5). This is because of the geopolitical and geoeconomic interests that affect the overall situation and put any possible solutions beyond the ability and capacity of the countries in the region To address this situation, the future strategy should be developed at the EU level, include the policies needed to promote and support regional solutions to regional problems, and specify the corresponding resources and tools to implement them, including based on the application of international treaties and conventions. The EESC underlines the need to work with regional organisations such as the OSCE, the Black Sea Economic Cooperation, UN bodies, etc., subject to their commitment to complying with the EU’s principles and strategic guidelines (6).

1.6.

The EESC stresses that achieving a lasting peace is a necessary and essential pre-condition for sustainable economic development and notes with regret that this is not included as an objective in the document. Without normalising the relations in the region, its prosperity cannot be ensured. The strategic approach should include short-term strategies, developed on the basis of alternative scenarios, devised in compliance with international law. It should address the existing and expected challenges with a view to achieving sustainable and lasting peace as quickly as possible and, on that foundation, should develop comprehensive plans for long-term socio-economic cooperation in the region. The EESC calls for extra efforts to secure compliance with international labour standards in the region in order to boost social dialogue at all levels, as a prerequisite for a functioning social market economy. These objectives were further reaffirmed at the Ministerial Meeting on Cross-Regional Security and Connectivity held on 20 October in Luxembourg (7).

1.7.

The EESC stresses that, in order to elaborate and implement a comprehensive and effective Black Sea Strategy, that brings together security, economy and environmental protection within a complex and dynamic geopolitical environment, it is necessary to ensure:

—	clear international support;

—	a comprehensive financial framework;

—	a consistent approach and effective coordination at national and regional level;

—	cooperation on synchronising policy and infrastructure;

—	establishment of working groups for every pillar;

—	a specified time frame;

—	and an action plan.

From this perspective, the EESC accepts the strategic approach as the first step in an overall process and calls for it to be implemented swiftly and provided with the resources and capacity to do so. A key success factor will be the Commission to promptly initiate and launch consultations with all relevant international organisations, state representatives and stakeholders.

1.8.

The EESC finds the major constraint on the strategic approach is that it is based entirely on the existing financial instruments and budgetary resources included in the multiannual financial framework 2021-2027 (8). Experience gained in recent years shows that this financial framework is fragmented, insufficient and ineffective in achieving the ambitious objectives. Furthermore, its resources have either already been exhausted, or committed to other projects. It is very difficult for businesses, social partners and civil society organisations (CSOs) in the region to navigate this network of different programmes and conditions. Therefore, the EESC requires the instruments to be simplified, consolidated and prioritised to produce an immediate and visible effect.

1.9.

The EESC recommends conducting an in-depth impact analysis of all the existing instruments to date and, on this basis, formulating more specific and clearer commitments regarding their use going forward. It urges the Commission to ringfence designated funds in the MFF 2028-2034, making the most of the different programmes within it.

1.10.

While focusing on bolstering democratic resilience and economic prosperity in Black Sea countries, EU policymakers should consider a comprehensive approach when addressing security concerns. To that effect, more attention should be devoted to tackling hybrid threats and governance malfunctions, which threaten to undermine regional stability. The EESC calls on the Commission, NATO, and other institutions to do more to counter these ‘soft’ threats.

1.11.

Countering hybrid threats in the region should be included as a strategic priority, paying particular attention to Moldova, which Russia targets primarily through information manipulation and interference and through political destabilisation, and Georgia, where Russian influence reinforces domestic actors and narratives that undermine democratic processes and values.

2. CONTEXT OF THE PROPOSAL

2.1.

Following a request from the European Council in June 2024, the Commission and the HRVP adopted a joint communication on the EU strategic approach to the Black Sea region. The initiative is designed in such a way that it builds on the existing framework of the BSS. The EESC regrets that it took so long to put forward the proposal and that by presenting a ‘strategic approach’ and not a ‘strategy’ with clear-cut objectives to attain, the new initiative displays a lower level of ambition and could represent a missed opportunity for the EU to establish itself as a key player in the region.

2.2.

The Black Sea holds a strategic position between Europe, the Middle East and the Caucasus, at a crossroads for trade and energy (oil and gas). Since the end of the Cold War, Russia has constantly looked to regain its lost influence and re-establish a new equilibrium in the Black Sea basin more favourable to its interests. It prompted and froze conflicts in the wider region (Nagorno-Karabakh in Azerbaijan and Armenia until 2023, Abkhazia and South Ossetia in Georgia, Transnistria in Moldova, and Russia establishing a new naval base in Ochamchire (9)). Russia has committed to promoting regional cooperation, for instance in the Black Sea Economic Cooperation Organization (BSEC) and its parliamentary assembly (PABSEC), but has taken steps contrary to those commitments in attacking its neighbour, Ukraine.

2.3.

The EESC notes with regret that the regional dimension of the Black Sea has been rather absent from the EU political agenda in recent years. A number of stakeholders expect the EU to adapt its approach to the new security and geopolitical realities of the Black Sea. This could include exploring the threats to security, building regional resilience, supporting freedom of navigation and countering hybrid and cyber activities. Coherence and consistency among EU initiatives in the Black Sea and coordinated action at regional level between the EU and like-minded partners is paramount.

2.4.

The EESC notes that the fields of cooperation defined by the BSS have been reconfirmed in general, while efforts are being made to re-cluster them around the current priorities, i.e. security, connectivity and preparedness. The EESC would like the emphasis to be placed more on security (maritime security, freedom of navigation, protection of infrastructure, irregular migration) than on defence and deterrence, where NATO’s leadership is expected to deliver progress. Greece, Bulgaria and Romania participate in the EU military mobility programme and Ukraine, Moldova and Georgia are both beneficiaries of and contributors to the EU common security and defence policy as well as the European Peace Facility (currently frozen with Georgia). The Black Sea security challenges originate not only from interstate conflicts but also from hybrid and authoritarian trends within partner countries, which weaken democratic legitimacy and make them vulnerable to external manipulation.

2.5.

Noting that the initiative neither benefits from dedicated funding, as it relies on other EU policies and instruments, nor precedes an action plan with clear-cut implementation objectives, the EESC warns with regret that its implementation will be difficult to assess and monitor.

3. GENERAL COMMENTS

3.1.

The EESC regrets to find that, despite of some plausible efforts, the current economic cooperation initiatives in the Black Sea region have not produced the expected results. In a context of increased uncertainty in the region, economic losses are aggravating the social and economic outlook, preventing the region from realising its high economic potential. In addition to the direct losses from the war, regional supply costs have risen, there have been disruptions in value and supply chains, problems with logistics and port operations, infrastructure damage and new trade restrictions, and maritime insurance and fuel prices have increased. Therefore, calls for the strategic approach to more decisively take account of the economic losses of the countries in the region and propose measures to compensate for them.

4. SPECIFIC COMMENTS

4.1. Security

4.1.1.

The EESC notes with regret that the BSS did not succeed due to the outbreak of the Georgian-Russian war and Russia’s aggression against Ukraine. Currently, there is no strategy that engages all the countries in the region, nor any document in the field of arms control (10).

4.1.2.

The EESC welcomes the proposals in the strategic approach on maritime security and safety and recommends that the EU supports and expands good practices, such as the naval initiative between Bulgaria, Romania and Türkiye to clear mines from the three countries’ national maritime zones. It calls for swift implementation of the proposal to build the Black Sea Maritime Security Hub on the basis of the existing EU-funded infrastructure established to monitor maritime traffic in the Black Sea.

4.2. Socio-economic environment

4.2.1.

The EESC notes with regret that the strategic approach does not address one of the biggest challenges in the region: migration. The Black Sea region is under pressure from migration (including labour migration), both external – from countries outside the region – and internal, between the individual countries within it. This dynamic brings both positives and risks, including for stability, which has a direct impact on migration in the EU, as the Black Sea is increasingly used as a corridor for irregular migration. To provide tools to address this situation, the future Strategy should envisage early warning systems and protocols for dealing with the refugee crisis, combating trafficking and fostering labour migration between the countries via intergovernmental employment treaties and other instruments which help manage migration.

4.2.2.

The EESC calls for a thorough assessment and – if need be – update of the existing trade agreements with the countries of the region. They provide the necessary framework, but given the new conditions in global trade, they need to be updated. The EESC shares the view that it is necessary to unleash the full potential of these agreements, to identify the obstacles they may contain and to undertake the necessary changes to remove them with the aim of reducing trade imbalances and increasing mutual trade (11).

4.2.3.

Given the serious challenges that trade in the region faces, the strategic approach must take into account both the overall losses of the Black Sea region’s economy due to Russia’s aggression against Ukraine and the restructuring of foreign trade flows. The EESC proposes that the strategic approach consider the possibility that trade fragmentation in the region may increase in the event that differentiated tariffs for individual countries in the region are introduced in trade with the United States, which will also impact the EU’s trade with the region. On this basis, it proposes that opportunities for increased trade in the region and with the EU be explored and developed.

4.2.4.

The EESC welcomes the ideas put forward in the strategic approach to promote research and innovation and digitalisation in the region as a continuation of existing opportunities. Due to the high priority level of critical raw materials for the EU, the EESC proposes that securing them should be identified as one of the main priorities in the strategic approach, with clear commitments from the EU regarding investments and financing of strategic projects. In this respect, certain characteristics unique to the Black Sea must also be taken into account, such as the fact that it is the largest repository of hydrogen sulphide, which could be used to develop new energy sources.

4.2.5.

The strategic approach focuses on the creation of an independent energy market integrating renewable energy sources, as well as the stability and sustainability of energy systems. The EESC supports these objectives and the integration of the energy market, but stresses that the expansion of cross-border energy trade in the region must consider the effects on prices and long-term investment in the sector. In this regard, the EESC calls for a mechanism to be put in place to compensate for excessively high electricity prices in the region until a sustainable solution is found. It stresses that it does not consider it appropriate for the strategic approach to focus solely on energy generation from renewable sources. Support for renewable energy projects must take into account the risks of energy systems becoming imbalanced. Moreover, it is inappropriate to set a target for reducing energy consumption in the region, given that it significantly lags behind in energy consumption per person. The EESC proposes that special efforts be undertaken to reduce energy poverty in the region.

4.2.6.

While the EESC finds the idea of creating a green energy corridor attractive, at this stage of its development and discussion within the EU, it is too early to impose it as an EU requirement on the region (12). However, it emphasises the necessity of conducting a comprehensive assessment of the region to evaluate its capacities, resources and readiness to serve as a sustainable transport and green energy corridor between Central Asia and the EU.

4.2.7.

The EESC welcomes the support to promote the ‘blue economy’, which refers to improving opportunities for cooperation of maritime stakeholders, and generate sustainable blue growth and innovations in the Black sea region and builds upon the Common Maritime Agenda for the Black Sea. However, it calls for fresh impetus in order to achieve meaningful results. One of the obstacles in this respect is the fact that some countries in the region do not have their own maritime spatial plans and in the case that such plans exist, they lack coordination and better synchronisation (13).

4.2.8.

The EESC finds that the EU initiatives implemented thus far to promote connectivity in the region have been insufficiently supportive of multi-country connections and projects. It calls for initiatives connecting countries in the region to be expanded, focussing on two key areas with an interstate dimension – communication across the sea and a motorway ring. The EESC sees this as a continuity of the EU Global Gateway programme that involves creation of digital and transport infrastructures in the Black Sea region through the development of eLogistics and Digital Transport Corridor platforms and services enabling trade facilitation between the countries of the Caucasus region and the EU. That will ensure harmonised trade and multimodal cargo transportation, taking place on the basis of interoperable eFTI certified national eLogistics platforms including the exchange of trade-related data and documents in electronic form.

4.2.9.

The EESC notes with regret, that most non-EU countries in the region are failing to comply with international labour standards. As a result, social dialog is these counties often stays an abstract exercise, tripartite institutions play façade role, with no regular meetings or agenda, with declarative nature of outcomes, when real policies, including on just transition, energy or security, international cooperation, trade and investments, on budget and taxes, industrial policies – those affecting workers – are being made in other cabinets. Legal processes often ignore social dialog, while ‘consolidation’ policies are bulldozered unilaterally. That erodes trust in democratic institutions, further giving boost for populists and far-right ideology, creating fertile soil for foreign interferences and misinformation.

4.3. Agriculture and environment

4.3.1.

The EESC welcomes the fact that one of the flagship initiatives focuses on ‘promoting environmental protection, climate change resilience and preparedness, civil protection’, as well as the support for developing climate change resilience, adaptation and mitigation of the negative impacts of temperature increases, protection of water resources in the region, prevention and control of pollution of individual components of the environment (air, soil, water, biodiversity) and the transition to a circular economy. However, it must be acknowledged that, despite the numerous initiatives implemented in this area to date, no significant progress has been noted. The EESC recommends that the strategic approach take better account of the specific characteristics of the individual regions, the economic and social effects of the measures undertaken, funding constraints and the diverse and fragmented technological challenges, and include a shared programme of measures applicable to all countries in the region regarding climate change, with a view to the sustainability of the Black Sea coastline and the affected communities.

4.3.2.

The EESC recognises the success of the EU, which has been able to create alternative avenues for agricultural goods in the context of Russia’s war of aggression against Ukraine. The liberalisation of agricultural imports from Ukraine helps to keep the Ukrainian economy running against the backdrop of military hostilities. The EESC recommends that the strategic approach reflect the messages contained in the Declaration of the Ministers of Agriculture of Bulgaria, Hungary, Poland, Slovakia and Romania on the agricultural aspects of the modification of the EU-Ukraine trade agreement.

4.4. Cooperation, resource provision and enabling conditions

4.4.1.

The EESC calls on the Commission to develop and propose an effective and specifically funded strategy under the MFF 2028-2034, based on the proposed strategic approach. This strategy should be preceded by a comprehensive review of the results and an assessment of the impact produced by the initiatives implemented so far and the degree of coordination, identifying the main obstacles to implementing the proposed approach. Some of those obstacles relate to insufficient institutional capacity and ambition to carry out large projects of regional significance. The EESC urges that a functioning mechanism be established to consolidate and coordinate the numerous but under-funded existing schemes, programmes and initiatives for cooperation in the Black Sea, in order to avoid the current overlap. The implementation of the strategic approach should focus on sectors that are regional in nature, that require a high level of interaction between national, regional, local and non-state actors, and that have a cross-border dimension.

4.4.2.

The EESC notes a slowdown in the growth of foreign direct investment in the region, including from the EU, and calls for the strategic approach to address this problem and identify measures to promote cross-border and EU investment in the region with a comprehensive investment plan for the Black Sea region (INVESTMENT COMPACT), which should include sustainable and decent job-creating projects. The strategic approach focuses on public initiatives and actions to be carried out by countries. However, without involving the private sector and scaling up private investment in initiatives and multilateral projects, the impact would be limited. One key problem is the lack of investment projects with a multilateral basis. In this regard, the EESC suggests that concrete and ambitious flagship projects be defined in the future strategy. The EESC supports the involvement of the European Investment Bank (EIB) in financing actions under the strategic approach and suggests attracting also other multilateral development banks to provide an important resource for achieving the objectives, such as the European Bank for Reconstruction and Development (EBRD), the Black Sea Trade and Development Bank (BSTDB), etc.

4.4.3.

The EESC welcomes the promotion of dialogue with partner countries, but believes that the strategic approach should widen that dialogue both with business organisations in the region and with the numerous cross-border business and economic organisations and associations of local authorities. National institutions, together with employers’ organisations, trade unions and consumer organisations, must participate in the dialogue. In the light of the experience gained in the Black Sea cooperation, their involvement will help achieve the objectives of the strategic approach.

4.4.4.

The EESC draws attention to the overregulation and the high administrative burden (14) in the overall regulatory framework applicable to the Black Sea region and calls for substantial efforts to be made to reduce them. The need for national alignment and coordination in implementing European and international requirements should also be discussed (15).

4.4.5.

The EESC calls for flexible implementation, including derogations from the applicable regulatory framework (e.g., for the Member States in the Black Sea region, regarding the most burdensome elements of Green Deal and State aid), given that military action is taking place in the region.

Brussels, 3 December 2025.

The President

of the European Economic and Social Committee

Séamus BOLAND

(1) EUCO Conclusions, https://www.consilium.europa.eu/media/qa3lblga/euco-conclusions-27062024-en.pdf, p. 33.

(2) The import in Türkiye from Russia before the war was USD 29 billion, currently is USD 44 billion.

(3) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52007DC0160.

(4) See Social media and AI algorithms: ensuring the right to accurate information and the visibility of high-quality content across Europe, especially about Eastern and Central Europe .

(5) BSS was successful within the framework in which it was developed: https://data.consilium.europa.eu/doc/document/ST-11900-2024-INIT/en/pdf and https://www.eeas.europa.eu/eeas/black-sea-synergy-success-regional-cooperation-despite-challenges_en.

(6) Taking into account the limitations on EU-BSEC interactions in the current context of Russia’s war of aggression against Ukraine which has more broadly affected the dynamics of the interaction between the BSEC and the EU, as factually outlined in the JSWD/4th implementation report of the BSS (pages 22-23). From a sectoral point of view, BSEC-EU interaction continued to take place through the Common Maritime Agenda and its scientific pillar, the Strategic Research and Innovation Agenda for the Black Sea. These interactions are limited to the BSEC Permanent International Secretariat’s participation in these initiatives as an observer. As part of the EU’s response (13), Russia’s participation in the BSS has been suspended, as well as all forms of cooperation at regional and national level with Russian public stakeholders.

(7) Participants highlighted their determination to deepen cooperation in areas of common interest, enhance mutual resilience and promote more connected, secure and prosperous regions. Participants discussed an ambitious cross-regional connectivity agenda.

(8) The MFA 2021-2027, through Neighbourhood, Development and International Cooperation Instrument (NDICI), the Instrument for Pre Accession Assistance (IPA III), the Connecting Europe Facility, Horizon Europe, European Defence Fund (EDF) and EU Defence Innovation Scheme (EUDIS), the Cohesion policy (ERDF), the Digital Europe Programme, InvestEU, the LIFE programme, Erasmus+, the ReArm Europe Plan, the European Peace Facility, and the Ukraine Facility.

(9) https://www.eeas.europa.eu/delegations/vienna-international-organisations/eu-statement-response-report-co-chairs-geneva-international-discussions_en.

(10) A Memorandum of Understanding between the governments of the Republic of Bulgaria, Romania and the Republic of Türkiye on the establishment of a MCM Black Sea Task Group has been in force since 2024.

(11) Large imbalances – huge trade deficits – exist between some countries. This is a very important issue: Bulgaria has a trade deficit of BGN 1,186 billion – EUR 606,4 million with Ukraine alone.

(12) Green energy corridor linking clean energy production in the Caucasian region and EU markets through – for example – submarine electricity.

(13) Bulgaria has adopted the Maritime Spatial Plan (MSP) 2021-2035.

(14) As per the Ocean Pact, the Commission will also work towards simplifying and synchronising ocean-related reporting obligations for Member States in existing legislation, with the objective of increasing legal clarity and policy coherence, while reducing administrative burden.

(15) For example: at the international level MARPOL 1973, UNCLOS 1982; at the European level 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) ( OJ L 164, 25.6.2008, p. 19, ELI: http://data.europa.eu/eli/dir/2008/56/oj), Directive 2014/89/EU of the European Parliament and of the Council of 23 July 2014 establishing a framework for maritime spatial planning ( OJ L 257, 28.8.2014, p. 135, ELI: http://data.europa.eu/eli/dir/2014/89/oj), Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy ( OJ L 327, 22.12.2000, p. 1, ELI: http://data.europa.eu/eli/dir/2000/60/oj), the European Green Deal, the plastics strategy, the circular economy strategy; and at the regional level, the 1992 Convention on the Protection of the Black Sea Against Pollution, as well as initiatives in the Black Sea region such as the Strategic Research and Innovation Agenda, the Organisation of the Black Sea Economic Cooperation, and others.