17 December (London, England) – Recent investigations have brought to light irregularities surrounding the use of a Non-Detriment Finding to justify the export of juvenile European eels from the United Kingdom to the Russian Federation. These certificates are intended to guarantee that the given trade will not detriment the species in the wild. As such, they are a key requirement by the Convention on International Trade in Endangered Species of Wild Fauna and Flora, an international agreement aimed at regulating the trade of endangered species to ensure their long-term conservation. To misuse such a critical tool in the fight against illegal or irresponsible trading practices is an affront to conservation efforts and to the eel, a critically endangered species.
The document used by the British Government states its Non-Detriment Finding for ‘a very specific situation where glass eels are caught in two specified English rivers before being transported to Lough Neagh in Northern Ireland to seed a fishery for larger eels’. It makes no mention of trade outside the United Kingdom’s borders, and states that the effects of this would need to be evaluated on a case-by-case basis [1]. And yet, the parties tendering for export licenses have reused these documents as the principal evidence-base for their environmental claims to justify trade to Kaliningrad in Russia.
To the average observer, it would seem that the environmental merit of trade with the Russian exclave was either not assessed, or deemed to have a net negative impact on the European eel stock. For the UK’s Department for the Environment, Food, and Rural Affairs, the question appears to have been one of scale. In the first instance, permission appears to have been granted for a modest cargo, which would have had minor impacts, and then this increased at significant multiples based on the precedent established.
A freedom of information request has revealed that an export of a modest 5 kg was permitted on 3 May 2022, and then used as a basis to justify much larger quantities. A 150.9 kg trade was permitted just nine days later, on 12 May 2022, rising to half a metric tonne on 27 March 2023 and one tonne in 2024. This is all despite the deteriorating state of Anglo-Russian relations, which has affected the transparency of monitoring results for the Vistula and Curonian lagoons.
Further concerns have been raised about false or exaggerated representations of the trade in the documentation submitted by the UK Government’s CITES commission. Whilst the conditions of the permits clearly state that that the juvenile ‘eels may be used solely for the purpose of re-stocking’ and ‘may not be re-exported or used elsewhere in the destination country for any other purpose’, there are no guarantees that eel will remain in the Kaliningrad region, or even Russia. The Fisheries Agency for the Russian Federation has already made statements indicating that the programme is for release and re-capture, rather than release for free escapement [2]. And Kaliningrad does not exist as a standalone market, removed from the wider Russian Federation and its associated commercial supply chains.
This Russian Federation statement of catching all the eels flies in the face of the idea that this trade is environmentally motivated, with an implied increase in silver eel escapement. The UK maintains its commitment to the EU Eel Regulation target of 40% silver eel escapement. There are uncertainties around how this could be met, given these circumstances.
The terms of the Non-Detriment Finding relate to a very specific trade inside the United Kingdom and do not expressly allow for international exports. The Sustainable Eel Group calls upon readers to demonstrate their support for restrictions on the trade to Kaliningrad by signing the petition on the Change.org website [3].
[1] ‘Non-Detriment Findings Guidance, Version 1.1’, CITES
[2] ‘Regional authorities are waiting for eel larvae from England to meet demand’, New Kaliningrad
[3] ‘Petition to stop export of baby eels from UK to Russia’, Change.org