The EAA together with other prominent NGOs have submitted a joint response to the consultation on “Evaluation of the Eel Regulation”. The response reads as follows:
We strongly support the upcoming evaluation and welcome this opportunity to provide feedback on the effectiveness and implementation of the EU Eel Regulation.
The population of European eel has declined dramatically since the 1970s1. Recruitment of juvenile eels is extremely low, and despite the joint EU management framework, which has now
been in place for 10 years, there has only been a slight improvement in recruitment. The state of
European eel remains critical and further action is urgently needed.
Earlier evaluations indicate that the current EU management framework is insufficient and show that implementation of the regulation and of the national eel management plans has been
delayed, piecemeal and focused on efforts that have little discernible impact on the recovery of
the European eel population. Notably, it has been very difficult to measure progress against the main target – escapement to the sea of at least 40 % of the estimated ‘unimpacted’2 silver eel
biomass. While a strong focus of resources has been placed on restocking of eel, there is no
evidence that this effectively contributes to future recruitment. Most countries maintain a
directed fishery, and illegal catches and trafficking of glass eels remain a major problem.
Habitat loss and deteriorating water quality also affect eel. The latest assessment of the
implementation of the Water Framework Directive shows poor status for around 60 % of surface
water bodies and a massive presence of migration barriers3.
Since the Eel Regulation came into force, some major changes in related EU policies have taken
place. Notably, the reform of the Common Fisheries Policy agreed in 2013 resulted in the new
commitment to restoring the biomass of all harvested fish stocks above levels capable of
producing Maximum Sustainable Yield (MSY). MSY is also used as a key criterion to assess Good
Environmental Status under the Marine Strategy Framework Directive. We are therefore
particularly pleased to see the evaluation’s focus on coherence with other EU legislation, as well
as with international instruments.
We ask the European Commission to ensure that this evaluation of the effectiveness and
coherence of the measures taken to aid the recovery of European eel assesses all aspects of eel
management and potential options for the future, including:
- The overall objective for the EU framework – at least 40 % escapement to the sea of silver eels – and whether it is in coherence with the precautionary principle and the MSY objective.
- The incongruity of the current levels of exploitation of a critically endangered species.
- The effectiveness of fisheries closures/restrictions for all life stages.
- The targets and indicators set in the national eel management plans, as well as the national monitoring to measure progress.
- Reporting and data collection obligations, as one of the main problems when
assessing fishing effort and management progress is a lack of consistent reporting
from the Member States.
- Restocking practices (which rely on wild eel catches) and the associated overall
effectiveness in terms of conservation.
Progress on measures to address other major anthropogenic impacts on eel, primarily
habitat restoration and removal of migration barriers.
- The use of public funds (EMFF) and whether it has aided eel recovery.
- The still substantial illegal trade of European eel outside of and inside the EU and its
effect on eel conservation.
- The legal trade of European eel and its potential role in enabling illegal trade.
- Control and enforcement issues related to the entire chain, from glass eel fisheries to
consumption of eel products, including more coordinated action between the
Member States’ enforcement agencies.
- The implementation of EU commitments within the framework of CMS and CITES.
- Contamination levels of wild European eels at different life stages and related health
aspects linked to consumption.
Bearing all of the above in mind, we look forward to a thorough evaluation of all aspects of the European eel
management framework, and to future opportunities to engage with this process.
It is our hope that through implementation of urgent measures and better management
and protection in the future, we can enable long-term recovery and sustainable
exploitation of European eel, but we note that we are a very long way from there today.
EAA, ClientEarth, FishSec, Good Fish Foundation, Our Fish, Pew Charitable Trusts, Seas At Risk and WWF
Access the consultation page “Evaluation of the Eel Regulation” here