Some historical background
In the early seventies, some of the glass eel caught in France was exported to Japan. This volume of exports to the country that consumes the most eels in the world reached 180 tonnes in 1973, worth 18.5 million euros (2021 value), before falling rapidly over the following decade to a maximum of 50 tonnes, i.e. no more than 10% of the national production.
At the end of the seventies, the Spanish market remained the main destination. In 1979 and 1980, 725 and 840 tonnes were exported to Spain. After 1980, glass eel catches began to fall, but the drop in catches was offset by an average price per kg that rose from €25 in 1980 to more than €50 (2021 values) between 1983 and 1985. Between 1979 and 1983, the value of exports to Spain was between 17 and 22 million euros2021, more than 10 times the value exported to Japan during the same period.
In the early nineties, the Chinese eel farming industry began to grow in strength and began to buy large quantities of European glass eel production. From 1995 until the introduction of European regulations in 2007, more than 50% of French glass eel production was purchased by China (Figure below after Nielsen and Prouzet, 2007 – FAO report N° 508).
Prices are rising steadily and sometimes sharply, as shown in the diagram below.
This sharp rise in prices is obviously a source of greed. Parallel markets are multiplying despite the best efforts of professional river and sea fishing organisations to counter illegal fishing. These markets are competing with the legal market. This is not a period of ‘bad practices, irresponsibility and a climate of illegality’ as the SEG claims, but a period when, within the Migratory Fish Management Committees and the CIPE (Comité Interprofessionnel de la pêche des poissons migrateurs et des Estuaires), those in charge of French professional fishing are fighting to ensure that stricter management and marketing rules are respected.
It was in this social and economic context, characterised by a glass eel fishery that represents the second most valuable fishery resource in the Bay of Biscay, that European workshops on eels opened in Brussels in 2006.
In 2007, under pressure from the European Commission, the European eel was included in Appendix II of CITES.
On 13 March 2009, the listing of the European eel in Appendix II of CITES came into force. The main consequence: the impossibility to export or import European eels without a CITES transport mandate. The only exception is trade among European countries, where EU is considered as a single entity. The European eel (Anguilla anguilla) is the only eel species listed in Appendix II of CITES. It is classified on the IUCN red list in the same way as the two other eel species used mainly by the farming industry: Anguilla rostrata (American eel) and Anguilla japonica (Japanese eel).
For obscure reasons, since the data on these three species is more than incomplete and their abundance indicators show rapid trends towards decline in recent decades, the European eel is classified more negatively than the other two, as ‘critically endangered’, while the other two are placed in the ‘endangered’ category. However, the trend is the same, as shown by the curves below taken from a 2003 document (Dekker et al 2003) presented in Quebec.
There are many reasons for this decline, and it is still difficult to rank them in order of importance.
On 18 September 2007, the European workshops on eels led to the definition of an eel regulation, Council Regulation 1100/2007, establishing measures for the recovery of the stock of European eel. This regulation advocates a global approach (action on all the human factors impacting the species and its habitats), authorising fishing but controlling its impact ‘by reducing by at least 50% the fishing effort or catches compared with the average fishing effort or catches for the period 2004 to 2006’, and setting up restocking programmes (transfers of individuals) based on a percentage of authorised glass eel catches that must reach 60% of the total catches allocated in 2013.
France adopted its eel management plan in 2009, defining in particular a quota-based management system. The quota is set by a scientific committee and is designed to achieve the objective of reducing fishing mortality by 50%. The definition of a quota also makes it possible to set a maximum volume of catches reserved for consumption and a maximum volume of catches reserved for restocking (transfer of glass eels within the European range of the species).
The consequences of such a listing: a legal eel market limited to Europe and under strain.
In December 2010, the European Commission asked its Scientific Review Group (SRG) whether it was possible to issue a non-detriment finding for the species in accordance with the CITES regulations on the transport of sensitive species. The verdict was clear: ‘The SRG assessed the situation for export of European eels: it was agreed that it was not possible to perform a “non-detriment finding” for the export of European eels, i.e. that it was not possible for the SRG to consider that the capture or collection of European eel specimens in the wild or their export will not have a harmful effect on the conservation status of the species or on the extent of the territory occupied by the relevant population of the species. The SRG would reassess the situation by the end of 2011“.
Since then, and to day, no non-detriment findings have been issued by the European authorities, and so the export of eels, and a fortiori glass eels, for consumption outside the EU under a CITES mandate is not authorised. On the other hand, the United Kingdom outside Europe since the Brexit, and Morocco and Tunisia non European countries, have obtained CITES mandates for export to either Russia or Asia.
The direct consequence of the CITES listing is that the market for glass eel, which is caught almost entirely by the French fishery, is restricted to European territory. This means that the market is almost entirely controlled by the eel farming industry, with prices well below those on the Asian market, where exports can take place under a CITES mandate.
However, it seems obvious that in the context of European regulation EC 1100/2007, which allows the regulated exploitation of eels and eel fry, and in the context of national regulations which, in accordance with article 7 of regulation 1100/2007, define a consumption sub-quota of 40% of the overall quota, a non-detrimental trade notice could be issued, since the consumption glass eel is intended for food and not for reproduction. Whether the glass eel is consumed in Europe or Asia, the result will be the same from a biological point of view: the fry will not participate in reproduction. We shall see later that the consequences of this completely inexplicable decision by the European authorities are serious for the economy of our small-scale professional sea and inland fisheries.
Has the CITES listing led to a reduction in illegal trade?
The worldwide eel farming industry is a multi-billion dollar economic resource based on the capture of fry from the natural environment. It is therefore necessary to control the trade in order to limit illegal trafficking. However, when you look at the results obtained after 15 years of inclusion in Appendix II, you may well wonder whether this highly constraining listing is worthwhile for the French glass eel fishery. Analyses carried out in 2018 and 2019 in major supermarket chains in Hong Kong[1] show that 45% of the eel products tested were European eel, 35% American eel and 10% Japanese eel. It should be remembered that only European eel is listed under CITES. While exports under a CITES mandate, particularly from the Mediterranean basin, may explain the production of European eels in Asian farms, particularly in China, the large proportion of European eels available on supermarkets suggests that production from European glass eels is currently much higher than the available statistics suggest.
[1] Prevalence of critically endangered European eel (Anguilla anguilla) in Hong Kong supermarkets. Richards et al., Sci. Adv. 2020; 6 : eaay0317 4 March 2020.
Analysis carried out by CITES shows that, on the period 2009 to 2017, the cumulative production figures provided by China for the export of eel meat were 46,011 tonnes for an import of 38 tonnes of European eel glass eels: in other words, a production of 1,200 kg of eel fillets per kg of glass eel, i.e. well above European production standards, even though they are at the cutting edge of technology and estimated at 600 kg of fillets per kg of glass eel. The available data listed by CITES are not very precise. The quantities marketed are only differentiated in the databases by designations (bodies, live or meat). The term ‘live’ does not give any indication of the biological stage.
As we can see, the CITES listing has done little to reduce the illegal market in European eels.
In 2019, analysis of seizures made on the illegal trade indicates that of the 132 tonnes seized, 120 tonnes (91%) were live eels (LIV category), but it was not possible to determine whether they were glass eels or older stages. In 2020, 101 tonnes were also seized, including 818 kg of glass eels or elvers (FIG category), but 1.2 tonnes of live eels seized were still classified in the undifferentiated LIV category.
If anything, this listing seems to have increased the problem and shifted the legal market towards other species such as American eel. This has been the case since 2011, with American glass eel accounting for 90% of recorded imports into Asia, other than Japanese eel, with imports doubling from 23 tonnes to 47 tonnes in recent years, not only from the USA and Canada, but also from the Dominican Republic and Haiti[1].
In fact, CITES honestly acknowledges the problem. « Conversely, there are concerns that the listing, and associated EU ban, has shifted trade to non-EU A. anguilla range States and other Anguilla species, and may have resulted in an overall increase in illegal and/or unsustainable harvest and trade in anguillids”[2]. Le commerce illégal n’a pas été stoppé. La Chine et Hong-Kong constituaient et constituent encore les principales destinations des civelles d’anguille européenne, mais de nouvelles destinations se sont ouvertes à partir de 2018 comme le Vietnam et la Thaïlande[3].
[1] CITES report 2022 SC74 Doc 64.1, Annex 4 – Status of use and trade of anguillid eels.
[2] On the other hand, there are concerns that the listing and associated EU ban may have shifted trade to non-EU European eel range states and other eel species, and led to an overall increase in illegal and/or unsustainable catches and pathways of eels. Page 20 – § Effectiveness of the listing- CITES report 2022 SC74 Doc 64.1, Annex 4 – Status of use and trade of anguillid eels.
[3] CITES report – Seventy-fourth meeting of the Standing Committee Lyon 7 – 11 mars 2022 §7 – Implementation of the CITES – Listing of European eel. Sub § 7.1. Summary, page 66.
Is the CITES listing a millstone around the French glass eel fishery's neck?
The answer is undoubtedly yes.
The figure below (from official data: CIPE, CNPMEM, DGAMPA) shows how we went from a fishery with a high economic value to a fishery with a low value after the introduction of the European regulation, which coincided, as we have seen, with the European Commission banning the export of glass eel, even under the consumption quota, outside the European Union.
Since the introduction of Regulation EC 1100/2007, the value of the fishery has collapsed from €50 million (1996-2007 period) to €12.5 million (2008-2023 period). Per fishing company (taking into account the 60% reduction in the number of companies), the drop in turnover is very substantial: from €42,000 to €27,000 on average.
From a social point of view, the crisis is significant for small-scale coastal, estuarine and inland fishing. For inland fisheries, conversion to fishing activities such as netting is difficult, if not impossible, given the increasingly severe restrictions on other species. The most recent of these is the ban on all fishing for migratory salmonids affected by climate change, which is likely to have an impact on the abundance of prey available during the migration of smolt fish to their fattening grounds.
And yet we can do better with a little more common sense and listening to the stakeholders.
Current regulations voluntarily or involuntarily benefit the farming sector by totally isolating the European market from imports and exports outside the EU. While this enables the farming and processing industry to obtain mainly French glass eels at moderate prices, the French fishing industry, unlike the fishermen who harvest American and Japanese eels, is deprived of highly profitable Asian markets. There is at least a 5-fold difference between the price charged in Europe and the price charged in Asia (400 euros compared with 2000 euros on average). As we have been able to demonstrate, this is in no way justified either by protection of the European species or by market regulation.
Within a regulatory framework that takes into account both EC regulation 1100/2007 and the listing in Appendix II of CITES, AFPMAR has put forward a proposal entitled ‘Fish less and value more’.
This involves :
- Firstly, a change in the allocation key between the proportion of glass eels reserved for consumption and for restocking, to better match demand and raise the price of restocking glass eels, which are barely half the price of glass eels for consumption.
Then a certificate of non-detrimental finding on the consumption side for glass eel. This decision is in line with the establishment of this CITES certificate and granted to countries such as Morocco, for example, as long as there is a management plan validated by the EU, and authorised and regulated fishing in line with the objectives of Regulation EC1100/2007. This can be done on all or part of the consumption quota, the calculation method for which is defined by a scientific committee to evaluate the achievement of the reduction target assigned by Regulation EC 1100/2007.
Finally, stop using pseudo-science to avoid answering a simple question: ‘Is exporting eels taken from the consumption quota outside the EU detrimental to the future of the species? The answer, from a biological point of view, is obviously NO. Whether an eel is consumed in Europe or Asia, the result will be the same: it will not participate in reproduction!
The attitude of the European Commission in pushing for the inclusion of the European eel in Appendix I of CITES without any assessment of the national management plans shows that the Commission is well aware that our demands are well-founded. This headlong rush to technocratically impose an Appendix I listing that would mean a ban of fishing activity and a social and economic disaster shows that the CITES listing is more a hindrance than a real advantage for the protection of the species and those who make a living from it.