Priorities and general comments
- The focus of the strategy should be on maintaining and developing the competitiveness of
European ports, including small ports, in a changing geo-economic environment. Therefore,
the key elements of the strategy should be:
- securing funding for investments in ports (continuation of an EU-funding instrument such as the Connecting Europe Facility (CEF) in the next MFF period); funding should prioritise the development of links between EU countries and the creation of pan-European added value;
- reducing the administrative burden for ports;
- streamlining permitting procedures regarding, for example, port investments and their participation in clean industry or circular economy.
2. The strategy should acknowledge that not all ports are the same. The recent events have affected European ports in a variety of ways, depending on their location, customer base, types of cargo, and so on. Today, different European sea basins face different challenges, e.g. maritime traffic in the Baltic Sea is challenged by a shadow fleet, GNSS jamming and other security problems, and on the other hand, the Mediterranean Sea has its own conflict zone and challenges with the emissions trading system and the instability of the Red Sea region. Therefore, if the Commission decides to envisage legislative measures in the context of the port strategy, a careful impact assessment will be needed that is sufficiently regional and detailed.
3. The strategy should recognise that ports are also important for tourism and sustainable mobility. In the Baltic Sea region the maritime passenger transport, and the regular cargo traffic on ro-pax vessels, are crucial for regional connectivity. Maritime transport is an important enabler for business and trade, strengthening the economic ties of the Baltic Sea countries and facilitating labour mobility and commuting. The European port sector has also a role to play in greening the European tourism sector and enabling modal shift.
4. The Finnish Ports Association does not consider it needed or justified to interfere with the ownership of ports or port areas by direct means from the European level. In our view, the revision of the Foreign Direct Investment Directive, which is currently negotiated, provides sufficient means to control foreign ownership in ports. The sovereignty and competence of the Member States with regard to strategic issues concerning their port network must be preserved. Most of Finland’s ports are owned by municipalities and operated as limited liability companies, but there are also ports in Finland that are directly owned by industry.
5. In Finland, the role of ports has been further emphasised as part of the security of supply and defence. In 2024, 95.3% of Finland’s foreign trade were transported by sea through ports. We consider it important that the needs of commercial transport, security of supply transport and military mobility are taken into account in the current geopolitical situation when defining Europe’s key transport networks and corridors. The security of supply and military mobility are reliant on efficient and well-functioning commercial transport enabling connections to the trade partner and ally countries. With regard to the network guiding the allocation of funding (currently the TEN-T network), it should be ensured that the network takes into account the use of both normal and military traffic.
Recommendations in order to facilitate the clean transition and ports’role in energy transition
6. The EU should provide targeted funding opportunities for clean transition projects to support the development of renewable energy plants, electrification of ports, onshore power supply and carbon capture logistics chain infrastructure. This could be achieved through existing programmes such as the Connecting Europe Facility (CEF) or through the creation of new financial instruments focusing on the sustainability of ports. Finnish Ports Association points out that it is important to examine the TEN-T network from the perspective of the geostrategic and energy roles of ports.
7. The allocation of ETS revenues to support the clean transition in the transport sector should be promoted both at the EU level and in the Member States. When allocating emissions trading revenues, the funding should be made available for the investments to the distribution and storage of alternative low-emission fuels in ports, as well as to support the production and use of those fuels.
8. In the view of the Finnish Ports Association, the AFIR or TEN-T obligations should not be extended in a direction where all seaports in the TEN-T core network are required to provide methanol and ammonia refuelling services. Ports should be able to flexibly determine their investment priorities based on customer demand and local conditions. Investments in bunkering infrastructure should be based on market demand. If there is no demand in the market, ports should not be required to invest. Instead, a market-based approach should be promoted.
9. Although methanol and ammonia are important new fuels, the other low- or zero-carbon fuels should not be ignored. Other options, such as hydrogen and biogas, are becoming increasingly important. In addition, the potential of fully electric maritime transport also seems greater than previously estimated. These options should also be included in the policy debate to ensure appropriate support for the efficient green transition. The coordinated planning of energy and transport infrastructure should be enhanced, and the ports should be recognised as important stakeholders when considering e.g. future grid capacity.
10. The preparation of the port strategy must also take into account enabling investments in the ports needed for offshore wind farms. Offshore wind power construction is expected to start in the Northern Baltic Sea in the late 2020s. The conditions in the area differ significantly from those prevailing elsewhere in Europe. Our ports are located in shallow boulder waters, and the annual operating time is significantly shortened by the freezing of the seas. Finland’s low-traffic ports, mainly owned by municipalities, do not have the capacity to invest in such ports without significant public investment or financial support, e.g. guarantees. Measures to ensure the ports’ investment opportunities should be taken into account as part of the port strategy.
Ensuring safety and security of port operations
11. In July 2025, in Finland a national legislation entered into force introducing an extension of security clearance procedures for the port personnel. Generally speaking, Finnish Ports Association considers common EU-level requirements and practices in the implementation of security clearances as a good tool, as long as it also improves the exchange and access to information between the authorities of the Member States. In this case, security clearance vetting could also be prepared more comprehensively for personnel originating or living in another EU Member States. At the EU level, however, the matter should be promoted primarily through the model in which each employee’s own employer is always responsible for commissioning security clearances. When developing the Union’s common policy, it is important to ensure the proportionality and effectiveness of procedures and to ensure that the availability of labour and the timely implementation of recruitment can be ensured in the future as well.
12. Within the framework of the work of the European Ports Alliance, the problem relates to the presence of organised crime in European ports has been raised. Organised crime can be combated in a variety of ways, and on the other hand, measures that have been introduced to the port sector for other reasons (e.g. for national security) can also make an effective contribution to the fight against organised crime. An example of this is the security clearance procedures for port personnel, which in Finland have been laid down primarily to improve national security. Therefore, it is good to examine the range of measures that strengthen the various aspects of port security as a whole and to promote measures that have a strong and broad impact. This is particularly important in Finland, where, for example, many ports are significantly smaller in size and administrative resources than Central European ports.
13. European ports are part of the critical infrastructure and ports are constantly developing their security measures due to the requirements introduced by CER directive and other recent initiatives. With regard to the work of the European Ports Alliance, and its recommendations, it should be ensured that the recommendations take into account the specificities of ports, in particular traffic, volumes and administrative resources.
More information: Piia Karjalainen, CEO, Finnish Ports Association, piia.karjalainen@suomensatamat.fi
