The contents of a short article published last October in Russian specialist publication, Fishnews, are revealing. In his characteristic tone of optimism, the reporter takes a moment to celebrate what he initially implies to be a conservation project, involving the translocation of juvenile eels from British rivers to the brackish waters of Kaliningrad. The tone then turns dark as it revealed the project has no conservation agenda at all, and is instead designed to support a commercial catch-and-release programme spearheaded by the Russian Government.

Work to restore the eel population in the Kaliningrad Region has been underway for the past three years. By the end of 2024, the volume of released young fish exceeded 2.8 million specimens. This is more than twice as much as the year before. 2.35 million specimens of young eel were sent to the waters of the Vistula Lagoon, and another 500 thousand specimens to the Curonian Lagoon.

This text is of course disheartening for advocates of eel conservation to hear, since it shows that the consumption of substantial quantities of eel meat is the principal motivator for the trade. However, the most important detail contained within these lines concerns the geography and dynamic of the restocking programme. If Fishnews’ statistics are to believed, this would suggest that the trade is not only unethical but illegal, in contravention with export permits.

If the permits were issued in line with the United Kingdom’s commitments to the Convention on the Trade in Endangered Species, as policymakers would have us believe, then this would mean, firstly, that the trade would need to be for ‘restocking’, allowing for at least forty per cent pristine escapement in line with the Eel Regulation; and secondly, that the host location needed an Eel Management Plan in place. It would seem there is scope for the traders to fall down on both counts: one being that they exaggerated, manipulated, or manufactured their monitoring capabilities and conservation claims; the other relating to geography.

In the case of the Vistula Lagoon, an Eel Management Plan is in place, which DEFRA officials have used in an official capacity to justify export permits. This plan remains controversial due to its weak evidence base, its apparent lack of rigorous review, and the fact that it was neither formally assessed nor signed off by officials at the Exploration of the Sea. But, from a strictly legal perspective, the existence of the plan provides sufficient grounds for the trade to proceed. The principal question is not whether the trade itself is lawful but rather whether the conditions that led to the development of the Eel Management Plan were legitimate, as it is unclear whether the region would have independently recognised the need for such or document, or whether its creation was primarily a response to the proposed trade. Given that the implementation of such plans is not standard practice for non-EU members – the United Kingdom being a notable exception, given the conditions under which it transitioned from Member status –  the apparent haste with which this particular plan was assembled, along with the dubious quality of the research, strongly suggests that it may have been constructed more as a means to enable the trade than as a genuine effort to promote sustainable eel management.

The Curonian Lagoon has no Eel Management Plan, and therefore presents an entirely different set of concerns. If nearly half a million specimens really were released here, then the traders would not only be in breach of their permits, which significantly complicates both the legal and political implications of the trade.  Some critics might argue that their involvement in the trade suggests complicity in broader efforts to expand the exclave’s fishery, as well as its fish processing and aquaculture industries, thereby creating the impression that they are aligned with established commercial interests, if not with those of the Russian state itself. Others may focus on what appears to be a complete disregard for the conditions under which the export permits were granted, whether this action stems from deliberate actions taken by the Kaliningrad authorities or from a failure on the part of the traders themselves to ensure compliance with the intended use of the exported eels.

This is not to say that the United Kingdom’s Department for the Environment, Food, and Rural Affairs bears no responsibility for the damage that has already been done. Ministersshouldof coursehave been aware that the Eel Management Plan for the Vistula Lagoon was inadequate, and therefore out of step with the standards of good fisheries management upheld by Brussels, and later London, through ratification of the Eel Regulation. But theyshouldalso have recognised at a more basic level that monitoring capabilities in this non-aligned country are severely compromised, making determining the motivators behind this trade inanendangered species more difficult. Their decision to allow the permits was a risk that most conservationists would be unwilling to take.