WORKINGTOGETHERTO INSPIRESUSTAINABLE
SOLUTIONSREPORT
EN

2013

ILLEGAL CAVIAR TRADE IN BULGARIAAND ROMANIA
Results of a market survey on trade in caviar from sturgeons(Acipenseridae)

Cover photo: © WWF / Phyllis Rachler
Back cover photo: © Ralf Reinartz
Author:Jutta Jahrl
WWF Austria
Ottakringer Straße 114-116
1160 Vienna
Austria
Jutta.Jahrl@wwf.at
Published by WWF Austria, Vienna, and TRAFFIC© 2013 WWF Austria and TRAFFIC
All rights reserved.
All material appearing in this publication is copyrighted and may be produced with permission.
Any reproduction in full or in part of this publication must credit WWF Austria and TRAFFIC
as the copyright owners.
The designations of geographical entities in this publication, and the presentation of thematerial, do not imply the expression of any opinion whatsoever on the part of WWF,TRAFFIC or its supporting organizations concerning the legal status of any country, territory,or area, or its authorities, or concerning the delimitation of its frontiers or boundaries.
Suggested citation: Jahrl J. (2013). Illegal caviar trade in Bulgaria and Romania - Results of amarket survey on trade in caviar from sturgeons (Acipenseridae). WWF Austria & TRAFFIC,
Vienna, Austria.
Illegal caviar trade in Bulgaria and Romania | 2013

Table of contents
Acknowledgements

1

Executive Summary

2
4

	Summary results table5

1. Introduction
1.1 Conservation status of Danube sturgeons5

1.2 CITES regulations regarding trade in caviar

7

1.3 Caviar labelling regulations

8

1.4 The caviar trade from Bulgaria and Romania

11

1.5	Sturgeon farming and caviar production

11

1.6 Illegal fishing and trade in sturgeons and caviar in/from Romania and Bulgaria

15

17

2. Methodology
2.1 Development of market survey methodology

172.2 	Survey teams

17

2.3 	Survey period

18

2.4 DNA analysis

18

21

3. Results
3.1 Vendor types

21

3.2 The marketing of non-sturgeon caviar

24

3.3 Implementation of caviar labelling in Bulgaria and Romania

24

3.4 Results from DNA testing27

3.5 Qualitative information of illegal fishing and trade networks in Romania and Bulgaria

34

3.6	Prices for caviar

36

4. Conclusions and recommendations

40

4.1. Conclusions

40

4.2. Recommendations

42

46

5. Appendix
5.1 Map of Romania

46

5.2 Map of Bulgaria

47

5.3 	Sturgeon species codes48

5.4 	Specimens of licensed CITES caviar labels – Bulgaria

49

5.5	Specimens of licensed CITES caviar labels – Romania

50

Illegal caviar trade in Bulgaria and Romania | 2013

Acknowledgements
This work was undertaken with the support of The Mohamed bin Zayed
Species Conservation Fund, project no. 10251197.
The project was further supported by WWF Austria, WWF Germany andDeutsche Bundesstiftung Umwelt (DBU).
Special thanks are due to the surveyors in Bulgaria and Romania who
were responsible for the very difficult field work of this project and who
were able to find so much valuable information on sturgeon poaching andcaviar trade.
The very helpful support provided by authorities in Romania, Bulgaria
and other EU Member States is most gratefully acknowledged.
TRAFFIC has been a very important partner in all phases and parts of thisproject, and in particular Katalin Kecse-Nagy deserves major thanks forthe active support and profound expertise she provided.
The Danube Delta National Institute in Tulcea, Romania, – namely Dr.
Radu Suciu and Dr. Dalia Onără – were of great importance to the projectby conducting DNA analysis of caviar samples and by adding significant
information to the project.
The Leibniz-Institute for Zoo & Wildlife Research in Berlin, Germany,– notably PD Dr Arne Ludwig and Dipl. Biol. Dietmar Lieckfeldt – isacknowledged with sincere gratitude for accomplishing the DNA analysis
of caviar samples and for their expert support.
Thanks are also due to our English editor, Gillian Thomas.
A big thank you is also extended to all colleagues of WWF, mostly in
Bulgaria and Romania, who helped with this project, especially to Stoyan
Mihov, Vesselina Kavrakova, Orieta Hulea and Cristina Munteanu.

1

Illegal caviar trade in Bulgaria and Romania | 2013

Executive Summary
Overfishing and unsustainable trade in caviar from wild sturgeons havebeen identified as the major direct threats to sturgeons in the Danube –one of the last mainstays of these globally threatened fish1. In the two key
range States of Danube sturgeons, Romania and Bulgaria, both fishingand domestic trade in caviar from wild sturgeons are now illegal, due
to general moratoria lasting until the end of 2015. However, there areunconfirmed reports that poaching continues there.
The aim of this report is to provide research findings from a survey ofcaviar trade in Bulgaria and Romania, with a special focus on illegal
trade as well as on illegal fishing of sturgeons. The goals of the survey
were to collect reliable data and provide clear indications as to whether
illegal caviar is available in Bulgaria and Romania in order to support theactions of national authorities controlling fishing and trade.
The survey adds to Objective 6 of the “Action Plan for the conservationof sturgeons (Acipenseridae) in the Danube River Basin” in that it aims
to investigate the trade in caviar including the chain of custody fromfishermen to restaurant sellers and exporters of products (Action 6.5)
and the implementation of the Convention on International Trade inEndangered Species of Wild Fauna and Flora (CITES) universal caviar
labelling system (Action 6.3)1.
The project involved local surveyors visiting selected shops, restaurants,
markets, street vendors and sturgeon farms in different parts of the twocountries in order to buy caviar. The survey took place from April 2011 to
February 2012, with a special focus on times of peak supply or demand(e.g. spring and autumn migration times for wild caviar; Christmas and
New Year). Samples were obtained from vendors and then the DNA
analysed to determine the species of origin.
Overall, the findings of the survey suggest that illegal fishing of sturgeons
and illegal trade in caviar continues in both Romania and Bulgaria inspite of the moratoria.
In total, 30 samples of caviar were collected: 14 in Bulgaria, 14 in
Romania and 2 of Bulgarian farmed caviar in Austria. A summary table ofresults appears below. The key research results are as follows:1

Bloesch, J., Jones, T., Reinartz, R. & Striebel, B. (2002) Action Plan for the conservation of sturgeons (Acipenseridae) in
the Danube River Basin. Nature and environment, No. 144, Council of Europe Publishing, 112pp
http://www.iad.gs/docs/reports/SAP.pdf?PHPSESSID=708652a79156332ebc5be9657f0d43b6

Illegal caviar trade in Bulgaria and Romania | 2013

2

Executive Summary• Six samples were shown not to be sturgeon caviar, despite being
explicitly sold as such

• Five samples were declared by vendors to be wild-caught (andtherefore illegal); four of these five samples were shown by DNA
testing to be from the highly sought-after and endangered Beluga
Sturgeon (Huso huso)• Eight samples did not have mandatory CITES labels with CITES

codes (excluding restaurants, where the container with the label is
not expected to be on display); only two of these were in fact caviar
from sturgeon (which was said to be wild-caught)• Three samples were from sturgeon, but DNA analyses suggested they
were from species or hybrids other than those declared on the label• Five samples were mixes containing more than one species ofsturgeon, which is only legitimate for “pressed caviar”2

These cases demonstrate clear contraventions of CITES labellingprovisions and the European Union Wildlife Trade Regulations. In
addition they suggest that caviar of wild sturgeons is offered for sale.
In addition to these results, important qualitative information on illegal
fishing and trade was acquired through the survey. Bulgarian fishermen
told surveyors that they used modern equipment such as sonar andGPS as well as forbidden traditional hook lines (“carmaci”) to catchwild sturgeon. During the course of the project surveyors also founda tendency amongst some vendors in both countries, especially thoseoffering supposedly illegal caviar, to only sell to people they trusted. The
result is a covert chain of custody from poachers to customers.
The results of this survey underline how crucial effective law enforcementin these two important sturgeon range States is. This should include
strong interagency and transborder coordination and employment ofmodern technology such as DNA analysis. The issue of illegal sturgeon
fishing and caviar trade deserves more attention and also firm politicalsupport in order to make the efforts undertaken by Romania and Bulgaria
to protect their native sturgeons successful and ensure a future forsturgeons in the Danube.
The report formulates a number of recommendations aiming to address
the issues identified by the project.

2

CITES Resolution Conf. 12.7 (Rev. CoP14): Conservation of and trade in sturgeons and paddlefish

http://www.cites.org/eng/res/all/12/E12-07R14.pdf

3Illegal caviar trade in Bulgaria and Romania | 2013

Country

Summary results table
No. of No. of
sites
sites
visited selling
allegedcaviarNo. ofsamplespurchased

Price
range
per
gram in
Euros

Speciesof originindicated by
DNA testing

CITES
label
visible?

Where label
Where label
not present, visible, did the
did vendor
species code
indicate wild? correlate with
DNA testing?
Yes (1)

Romania

Restaurants (5)Sturgeon (8)Individual
vendors (3)38150.30 –
4.00

14
Shops (3)Austria

Bulgaria

Marketstalls (3)

41

14

14

Restaurants (2)Sturgeon (11)Sturgeon
Farms (4)Not sturgeon caviar
iv(1,from a restaurant)

0.10 –
2.67

1

2

Shop (2)3.14 –
4.20

N.R.

DNA resultsinconclusive (1)Unknown (1)ii

Not sturgeon caviar(3; all froma market stall)i

No (11)

No results from
DNA analysis (3)Shops (8)1

Yes (3)

Not sturgeon caviar(2,both from fish shops)vi

Sturgeon (2)Yes (5 restaurants/
iii
vendors)

N.R.

No (6)Yes (8)Yes (10)

N.R.

No (4)

No (4)N.R.

N.R.

DNA resultsinconclusive, but
probably no (1)vii

Yes (2)

No (2)v

No (1)viii

Sturgeon DNA present but product not fish eggs; potentially made from sturgeon meat and other material
CITES label was visible, but the exact species code was illegible so it is unknown whether the species label correlatedwith the DNA results or notiii
Sturgeon fishing is currently banned in Romania, so if true, this would indicate illegally sourced caviar
iv
Eggs from Lumpfish (Cyclopterus lumpus)v
One of these samples was labelled as Amur Sturgeon (Acipenser schrenckii), but DNA analysis showed Kaluga Sturgeon(Huso dauricus) as maternal species of origin. The other sample was labelled as Russian Sturgeon (A. gueldenstaedtii) but
results showed a combination of more than one sturgeon species (Russian/Persian/Adriatic Sturgeon and at least one other)vi
No DNA traceable, product not fish eggs; artificially produced from unknown materials
vii
Product was labelled as from Beluga Sturgeon (Huso huso) but DNA results pointed to Siberian/Russian Sturgeon as
species of origin. However, results were too poor to allow a secure species identificationother)iv
Product was labelled as from a Stellate Sturgeon (A. stellatus) but DNA analysis indicated that the caviar was in fact from
Siberian/Russian Sturgeoniii

Illegal caviar trade in Bulgaria and Romania | 20134

1. Introduction
1.1 Conservation status of Danube sturgeonsCaviar, the unfertilized roe of sturgeons, is one of the most valuable
wildlife commodities. This has led to heavy overexploitation and adramatic decline of sturgeons worldwide. According to the most recent
International Union for Conservation of Nature (IUCN) assessments
in 2009, the population of sturgeon has significantly declined withsturgeons now considered the most Critically Endangered group of
species worldwide3.
The Black Sea and Danube River Basin are among the last regions with
viable populations of sturgeons. However, even there, historic patternsof fishing yields reveal drastically declining numbers. In Bulgaria,
total annual catches fell from 63.5 tonnes in the 1940s to 25.3 tonnes
in 1995-20024. In Romania – with the Danube delta as a key fishingarea – total annual catches fell from approximately 1144 tonnes in 1940
to less than 8 tonnes in 19955. A century ago, six species of the ancient
fish were native to the Danube: Beluga Sturgeon (Huso huso), Stellate
Sturgeon (Acipenser stellatus), Russian Sturgeon (A. gueldenstaedtii),
Sterlet (A. ruthenus), Ship Sturgeon (A. nudiventris) and European
Sturgeon (A. sturio). Five of them are now classified by IUCN as CriticallyEndangered - with European Sturgeon already extinct in the Danube andShip Sturgeon extremely rare. Sterlet (A. ruthenus) has been assessed as
Vulnerable.
The Action Plan for the conservation of sturgeons in the Danube River
Basin1 lists the following as the main threats to the survival of Danube
sturgeons:• Overfishing• Disruption of migration routes caused by dams
• Loss of spawning habitats due to river regulations
3

http://www.iucn.org/iyb/about/species_on_the_brink/?4928/Sturgeon-more-critically-endangered-than-any-other-groupof-species;
http://cmsdata.iucn.org/downloads/species__status_and_population_trend_of_sturgeon_on_the_red_list.pdf

4

Vassilev M., Pehlivanov L. (2003): Structural Changes of Sturgeon Catches in the Bulgarian Danube Section. Acta zool.
Bulg., 55 (3), 97-102
5

Novadura (1999) in Reinartz R. (2002): Sturgeons in the Danube River – Biology, Status, Conservation. Report for theInternational Association for Danube Research, 150pp

5

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

As a reaction to declining numbers Romania issued a 10-year catch andtrade ban on wild sturgeons in 2006. Bulgaria in 2011 followed with asimilar, but annual ban, extending the ban in 2012 for a further four
years. This means both the Bulgarian and Romanian bans end in 2015.
Despite the bans illegal fishing remains the greatest direct threat to thesurvival of wild sturgeons in the Danube River Basin. The main driver isthe very high economic value of caviar. Additionally sturgeon meat is indemand as a delicacy and achieves higher prices than that of any otherlocal fish species. Sturgeons are especially vulnerable to overfishing.
Due to their long life cycles and late maturity stocks take many years
to recover. In addition, periodic spawning migration enables targetedfishing of aggregating mature animals1.
Romania and Bulgaria share the major part of the lower Danube River,the last remaining spawning ground for most Danube sturgeons (seemaps in Appendix 5.1 and 5.2). These two States therefore face a great
responsibility for the conservation of sturgeon. Romania and Bulgaria
are also the only European Union (EU) Member States that are potential
source countries for wild caviar. Until relatively recently, the two Danube
States were among the worlds’ top-10 caviar exporting countries6. The
area is also on a potential trade route for caviar – both legal and illegal –from the Caspian Sea to other EU Member States.
Despite the Critically Endangered status of sturgeons and the ongoingthreat of overfishing, the Danube and Black Sea region is still a very
important habitat for sturgeons. The World Sturgeon Conservation
Society cites the Danube as the only large river system in Europe where
the protection of existing but dwindling sturgeon stocks is still possible1.
© WWF / Cristian Mititelu

A. stellatus fromsturgeon farming.

6

Engler M., Knapp A. (2008): Briefing On the Evolution of the Caviar Trade and Range State Implementation of
Resolution Conf. 12.7 (Rev. Cop 14). TRAFFIC Europe for the European Commission, 41pp+Annex
http://ec.europa.eu/environment/cites/reports_en.htm

Illegal caviar trade in Bulgaria and Romania | 20136

Introduction

1.2 CITES regulations regarding trade in caviar
All 27 species of sturgeons and paddlefish have been listed in the
Appendices of CITES since 1998. Two species – the European
Sturgeon (Acipenser sturio) and the Shortnose Sturgeon (Acipenser
brevirostrum) – are listed in Appendix I of the Convention (and Annex
A of the corresponding EU wildlife trade regulations), which prohibits
any international commercial trade in wild-taken specimens. All otherspecies are listed in Appendix II (and Annex B of the EU Wildlife Trade
Regulations), and international trade is regulated through a system of
permits, issued by national CITES Management Authorities7. All speciesof sturgeon and paddlefish are covered by CITES, regardless if wildcaught or captive bred. This includes all parts and products, including
caviar, meat, fingerlings, fertilized eggs, etc.
Any international shipments of these products must therefore always be
accompanied by the appropriate CITES permits, issued by the relevant
national CITES Management Authorities. The only exception is foramounts of up to 125 gram of (Annex B) sturgeon caviar per person,
the import/export of which does not require permits if it is consideredas personal effects (i.e. legally acquired, personally owned for noncommercial purposes and carried in personal baggage at the time ofimport/export); however, CITES labelling of caviar containers is still
mandatory (see Chapter 1.6)8, 9. Shipments of (Annex B) sturgeon caviar
within the EU do not require CITES documents – but do require CITES
labels – as the EU is a common market and trade is therefore considered
as domestic.
For wild sturgeon species from shared stocks (e.g. North-West Black Sea
and Lower Danube river), yearly export quotas need to be set for caviar
and meat in accordance with the procedure approved by the Conferenceof the Parties to CITES. A quota year starts on 1st March and ends on
the last day of February of the following year2. Throughout the durationof this market survey, from April 2011 to February 2012, zero global
export quotas for products from wild sturgeons were established, withthe exception of a few kilograms of fertilized eggs of source “F” from
Romania10 (i.e. from a female born in captivity and where at least one
parent originated in the wild2). This means that no international trade incaviar or meat from wild sturgeons was allowed.
7

Council Regulation (EC) No 338/97, amended by Regulation (EC) No 101/2012

http://ec.europa.eu/environment/cites/legislation_en.htm
8Conf. 13.7 (Rev. CoP14) Control of trade in personal and household effects

http://www.cites.org/eng/res/13/13-07R14C15.php
9Commission Regulation (EC) No 865/2006, amended by Regulation (EC) No 100/2008

http://ec.europa.eu/environment/cites/legislation_en.htm
10

7

CITES Sturgeon Quotas 2011 http://www.cites.org/common/quotas/2011/SturgeonQuotas2011.pdf

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

At the time of writing and during the time of the survey, only caviar
from captive-bred (= source “C”) sturgeons could be legally traded. With
respect to CITES, “captive-bred” or “bred in captivity” means that bothparents of the female were already born in captivity2, 9.
Caviar processing and (re-)packaging plants, including caviar producing
aquaculture operations, as well as exporters need to be licensed by
the Management Authority of CITES member countries in order to beallowed to process, (re-)package or export caviar. These companies
are required to maintain adequate records of the quantities of caviar
imported, exported, produced, stored, etc.9
A unique registration code must be attributed to each such processingor (re-)packaging plant by that Management Authority. This registration
code is part of the mandatory CITES caviar labels (see Chapter 1.6)9.

1.3 Caviar labelling regulations
Following the adoption of guidelines for a universal caviar labellingsystem by all CITES parties2, in 2006 the European Union (EU) adopted
Commission Regulation (EC) No 865/2006, as amended, which has madethe labelling of all caviar containers obligatory in all EU Member States9.
As a result, all caviar containers in the EU market, regardless of their size,
are required to bear a CITES label. The caviar labelling system is designed
to help governments, traders and consumers in distinguishing legal caviar
in trade from illegal caviar and aims to ensure that all caviar entering themarket is from legal sources11.
All sturgeon caviar containers, including tins, jars or boxes regardless of
their size (including less than 125 gram, which can be imported without
CITES permits – see Chapter 1.5), have to bear a non-reusable labelwith details about the source and the country of origin of the caviar. Thisapplies to caviar from all sturgeon species (including hybrids), fromwild as well as farmed origin, to commercial as well as non-commercial
purposes, and to domestic as well as international trade. The nonreusable label is to be affixed by a processing or (re-)packaging plant.
The label must either seal the container or the caviar must be packaged
in such a manner as to permit visual evidence of any opening of thecontainer, and it must not be possible to remove it undamaged or transfer
it to another container2, 11.

11

TRAFFIC factsheet “Universal caviar labelling requirements”

http://www.traffic.org/species-reports/caviar-factsheet-english-1.pdf

Illegal caviar trade in Bulgaria and Romania | 20138

Introduction

This regulation is directly applicable in all EU Member States, and theymust ensure that all caviar containers placed on the domestic market,
whether produced or processed on their territory or imported, arelabelled accordingly11.
The label for caviar containers must include the following information:
1. Standard species code (three-letter code for the identification ofsturgeon species, hybrids and mixed species; “HUS”, for example, isthe standard species code for Beluga Sturgeon (Huso huso) – see list of
species codes in Annex 5.3);
2. Source code of the caviar (“W” for sturgeon harvested from the wild;“C” for captive-bred sturgeon; “F” for caviar produced from a female
born in captivity and where at least one parent originated in the wild);
3. Code for the country of origin (two-letter ISO code);
4. Year of harvest;
5. Official registration code of the processing plant (each exporting
country should establish a national registration system for processing
plants, with official registration codes assigned to each plant);and
6. Lot identification number (caviar tracking system used by theprocessing or (re-)packaging plant)2, 11

Figure 1: Example of a CITES label with CITES code© WWF

BAE – standard species code: Siberian Sturgeon (Acipenser baerii)
C – captive-bred
AT – country of origin: Austria
2009 – year of harvest
0001 – registration code of the processing plant
0076 – lot identification number

9

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

All containers in which caviar is repackaged must also be affixed with alabel meeting all the above criteria. The label on repackaged caviar should
allow authorities to trace the origin of the caviar, i.e. include the countrycode of both the country of origin and of (re-)packaging2.
There is evidence that labelling requirements (non-reusable; sealing thecontainer or allowing visual evidence of any opening) are not always
met and cases of forged labels have been reported by some EU Member
States12, 13.
The use of DNA analysis has shown that considerable amounts ofmislabelled caviar have been available for purchase14. Investigations in
the New York City area in the mid-1990s demonstrated, that out of 95
samples of commercially available caviar, 23% were mislabelled withrespect to species identification15. The survey was repeated in 2006-2008,
with 90 caviar samples bought in shops and from web retailers in the
USA16. This study found a decrease in cases of mislabelling, but 10% werestill mislabelled, all of them from online purchase.

12
Knapp A., Kitschke C., von Meibom S. (eds.) (2006): Proceedings of the International Sturgeon Enforcement Workshop
to Combat Illegal Trade in Caviar. TRAFFIC Europe for the European Commission, 145pp+Annex

http://www.traffic.org/species-reports/traffic_species_fish14.pdf
13Knapp A. (2008): An assessment of the implementation of caviar labelling and licensing provisions in the European
Union. TRAFFIC Europe for the European Commission, 61pp
http://ec.europa.eu/environment/cites/pdf/studies/caviar_labelling.pdf

14

Genetische Tests können Kaviarschmuggel aufdecken – Workshop Leibniz Institute for Zoo and Wildlife Research.
Verbundjournal Dezember 2006, 14-15
http://www.fv-berlin.de/oeffentlichkeitsarbeit/verbundjournal-1/pdfs/verbund68.pdf

15

Birstein V.J., Doukakis P., Sorkin B., DeSalle R. (1998): Population Aggregation Analysis of Three Caviar-Producing
Species of Sturgeons and Implications for the Species Identification of Black Caviar. Conservation Biology, 766-775
https://www.google.com/url?q=http://cmbc.ucsd.edu/Students/Current_Students/MCBP/ConsBiol%2520Birstein%2520et%2520al.pdf&sa=U&ei=n1gRUKusMYfxsgb9voDIAg&ved=0CAUQFjAA&client=internal-uds-cse&usg=AFQjCNESnpYdtP
cTdNmCKOHtQYqED_w0XA
16Doukakis P., Pikitch E.K., Rothschild A., DeSalle R., Amato G., Kolokotronis S.-O. (2012): Testing the Effectivenessof an International Conservation Agreement - Marketplace Forensics and CITES Caviar Trade Regulation. PLoS ONE
Volume 7, issue 7, 1-9
http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0040907

Illegal caviar trade in Bulgaria and Romania | 201310

Introduction

1.4 The caviar trade from Bulgaria and Romania
Prior to the sturgeon fishing ban, both countries were major exportersof caviar. According to the CITES trade database Bulgaria reported
legal exports of over 20 000 kg of caviar and Romania over 26 000 kg
between 1998 and 2008. In Romania, caviar was mostly of wild origin,with amounts gradually decreasing after a peak in 2000, going down tozero in 2006, when the moratorium started. Bulgaria’s exports fluctuatedbetween 1998 and 2005 and peaked in 2006, due to an increase of farmed
caviar17. After Bulgaria’s and Romania’s accession to the EU in 2007,
trade to other EU Member States – among them the main consumersof caviar – was no longer recorded in the CITES trade database, as it nolonger counted as international trade.

1.5 	Sturgeon farming and caviar production
Sturgeon farming is a fast growing sector in the region and worldwide18.
Reported international trade in caviar from aquaculture has significantly
increased, often doubling from year to year, while worldwide importsof wild caviar have declined sharply since 19996. Export data of farmed
caviar from Bulgaria show a rapid growth, starting in 2002 with 100
kg and reaching over 3000 kg in 200617, the last year of data collection
before Bulgaria acceded to the EU in 2007 and exports from Bulgaria toother EU Member States was no longer reported.
Aquaculture caviar production requires high investment and has a long
payback time until the fish mature and caviar can be harvested. It takes
at least six years for females of Siberian Sturgeon (Acipenser baerii) toreach sexual maturity, and more than double that for Beluga Sturgeon(Huso huso). As females are usually killed to obtain the caviar, revenues
are made only once per adult female sturgeon.
If operating in accordance with nature conservation measures (e.g. legal
acquisition of broodstock, preventing escape of hybrids or exotic species),
the aquaculture industry can be positive both for local livelihoods andfor wild sturgeons because it can meet the demand for caviar without
exploiting natural populations. Yet the aquaculture industry also posesrisks to wild sturgeons. In recent years concerns have been expressed thataquaculture operations may be involved in “laundering” wild sturgeonsand caviar12. In Romania, there are allegations that illegally sourced
17

Kecse-Nagy, K. (2011): Trade in Sturgeon Caviar in Bulgaria and Romania – overview of reported trade in caviar, 19982008.
http://www.traffic.org/species-reports/traffic_species_fish47.pdf

18

National Strategic Plan for Fisheries and Aquaculture 2007-2013, National Agency for Fisheries and Aquaculture,
Ministry of Agriculture and Forestry, Bulgaria

11

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

sturgeons are kept as broodstock and that wild sturgeons caught legallyfor breeding purposes are not released again but unlawfully retained infarms and even killed to sell their caviar19. Hubenova “et al.” (2009)20
stated for Bulgaria that the “regime hides in itself the real danger for
selling at the market caviar from wild fish populations, which have beenpresented as produced in the fish farm”. DNA tests of caviar purchased in
the New York City area in the survey of Birstein “et al.” (1998)15 revealed
that mislabelled higher-priced caviar was fraudulently sold as a lowerquality product; e.g. two samples labelled as “American sturgeon” andone labeled as “Sevruga caviar” (from Acipenser stellatus) were in fact
much more costly Beluga Sturgeon (Huso huso) caviar. For a sample
labelled as caviar from Siberian Sturgeon (Acipenser baerii) – the mostcommon sturgeon in aquaculture – DNA analysis showed that it was
actually from Russian or Adriatic Sturgeon (Acipenser gueldenstaedtii
or A. naccarii). The authors of the survey have interpreted these casesof replacement of commercial species (indicated on the label) withendangered species (proven by DNA analysis) as a potential instance
where a wild– probably illegally harvested – product was falsely sold as a
product from aquaculture.
There have been allegations that aquaculture operations in the Danube
region may be involved in the “laundering” of wild caviar originating fromthe Caspian region, and it is possible that this also happens with caviar
from illegally caught Danube sturgeons. Preliminary results of organizedcrime investigations in Germany found that caviar labelled as from
Bulgarian aquaculture was actually proven to have originated from the
Caspian Sea17.

1.5.1	Sturgeon aquaculture and caviar production in Romania
In Romania, sturgeon aquaculture has a rather short history21. The firstsuccessful artificial propagation of Beluga Sturgeons was achieved in
2004 at Isaccea. The same company opened a sturgeon growing farm on
Lake Horia in 2009. In 2006, the second private sturgeon hatchery wasconstructed at Tamadau22. According to Suciu (2011), sturgeons are now
farmed in more than ten locations in Romania.

1920

http://www.romanialibera.ro/exclusiv-rl/investigatii/braconierii-de-sturioni-platiti-de-statul-roman-134370.html;
http://www.romanialibera.ro/exclusiv-rl/investigatii/batalia-sturionilor-48251.html

Hubenova T., Uzunova E., Zaikov A. (2009): Management strategies in protection and restoration of sturgeon
biodiversity in Bulgaria. Proceedings “IV INTERNATIONAL CONFERENCE FISHERY” Belgrade May, 27 – 29. 2009;
39-52

21

Suciu R. (2008): Sturgeons of the NW Black Sea and Lower Danube River countries. NDF Workshop Case Studies
WG 8, Case Study 5, 26 pp

22

Suciu R. (2011): Present state of sturgeon stocks in the Lower Danube River, Romania. First International
Conference on Conservation, Recovery and Sustainable Use of Danube River Sturgeons, 13 pp

Illegal caviar trade in Bulgaria and Romania | 201312

Introduction

The most popular species in Romanian sturgeon farms are Stellate
Sturgeon (Acipenser stellatus), Russian Sturgeon (A. gueldenstaedtii),
Beluga Sturgeon (Huso huso) and Sterlet (A. ruthenus)23.
At the time of writing, four companies are listed on the CITES website as
licensed exporters and/or processing and repackaging plants24.
Table 1: Romanian companies registered as licensed exporters and processing and repackaging plants for
specimens of sturgeon and paddlefish species (April 2013)

Company name

Address

SC Aquarom Elite
Distributions SRL

Praga Str. No. 7,
sector 1, Bucharest

SC Delta FishDistribution 2003 SRL

Soldat Nitu Ene str. No.
92B, sector 2 Bucharest
Registered Office:Prelungirea Ghencea str.
No. 93L, sector 6,
Bucharest

SC INTERFRIG SRLCataloi Village,
Tulcea County

SC Kaviar House
Bucuresti Filiala
TulceaFacility address: Horia
village, Tulcea County
Company address:
Câmpia Libertãtii str. no.
89bis, Isaccea, Tulcea
CountyRegistered asexporter

Registered as processing/repackaging (incl. caviar
producing) operation

Up to the end of the market survey period (i.e. February 2012), thosecompanies produced sturgeons, fingerlings, fertilized eggs and meat but
had not yet harvested, processed or traded caviar. Caviar from Romanianaquaculture is now on the market, with trade starting in December 2012
(Radu Suciu, pers.comm., January 2013).

23

Smederevac-Lalić M., Jarić I., Višnjić-Jeftić Ž., Skorić S., Cvijanović G., Gačić Z., Lenhardt M. (2011): Management
approaches and aquaculture of sturgeons in the Lower Danube region countries. J. Appl. Ichthyol. 27 (Suppl. 3), 94-100

24

CITES register of licensed exporters and of processing and repackaging plants for specimens of sturgeon andpaddlefish species
http://www.cites.org/cms/public/common/resources/reg_caviar.pdf

13

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

1.5.2 	Sturgeon aquaculture and caviar production in Bulgaria
In Bulgaria, sturgeon aquaculture for the production of meat and caviar
started in 1995 when the first sturgeon farm was set up close to Plovdiv.
In 2001, a second sturgeon farm was established close to Vidin on the
Danube20. Sturgeons are produced from ponds and net-cage farms25.
They are bred for meat (mainly for the domestic market) and caviar(mainly for export). Sturgeon farming is now the fastest growing sector
in regional aquaculture18. The main species in aquaculture are Russian
Sturgeon (Acipenser gueldenstaedtii), followed by Siberian Sturgeon (A.
baerii) and hybrids of those, Beluga Sturgeon (Huso huso) and Sterlet (A.
ruthenus)18, 23. By 2003, the Bulgarian Sturgeon Action Plan stated thatthe trade of sturgeon meat was expanding rapidly in Bulgaria and thatsturgeon meat from aquaculture could be found in nearly every shop or
supermarket in the country26.
Caviar production in Bulgaria has shown a constant growth and hasreached a yearly production of over six tonnes. The Tchobanov company
is the major producer, especially of Russian Sturgeons (Acipenser
gueldenstaedtii), with a reported production of five tonnes in 201127.
Most farmed caviar is sold outside of the country. However, there isimported farmed caviar for sale in Bulgaria, originating from a range ofcountries such as Italy, Germany and China27.
Six companies in Bulgaria are registered on the CITES website as licensed
exporters, processing and repackaging plants (including caviar producing
aquaculture operations)24.

25
26

Kissiov l. (2010): Bulgaria - Aquaculture sector shows strong growth. Eurofish Magazine 6/2010, 21-29

Jivkov (2003): Action plan on conservation of sturgeons in the Bulgarian aquatories of the Danube river and theBlack Sea, 25pp

27

according to information gathered by survey teams

Illegal caviar trade in Bulgaria and Romania | 201314

Introduction
Table 2: Bulgarian companies registered as licensed exporters and processing and repackaging plants for
specimens of sturgeon and paddlefish species (April 2013)

Company name

Address

Agamemnon I Ltd.

9, Europe Blvd, Sofia
2113002

Aqua Beluga Ltd.

10, Georgi Kondolov Str.,
Kurdjali

Beluga Inc. Vidin

South Industrial Zone,
3700 Vidin

ET FANI-Miroslav
Shopov

34, Osmi mart Str.,
Kurdjali

Oscietre CommerceLtd.

4114 Boliartzi, Reg.
Plovdiv

Parpen Tchobanov
Ltd.

4114 Boliartzi, Reg.
Plovdiv

Registered asexporter

Registered as processing/repackaging (incl. caviar
producing) operation

1.6 Illegal fishing and trade in sturgeons and caviar in/from Romania and Bulgaria
Data regarding the illegal trade in sturgeons and caviar is naturally
difficult to collect. However, a number of sources cite illegal fishingas an ongoing threat to sturgeon in the Danube. Bacalbasa-Dobrovici
and Patriche (1999)1 and Vassilev and Pehlivanov (2003)4 see illegal or
unreported fishing as a major threat to sturgeon in the Lower Danube
region, at that time exceeding by far legal catches. Hubenova et al.20 statein 2009 that the different regulatory instruments set up by Bulgarianauthorities at that time (gear restrictions, minimum size requirements,
close seasons) have not been sufficient to achieve the desired effecton the status of sturgeon populations. A “considerable delay in the28

Irinel Surugiu, National Customs Authority Romania: presentation at Sturgeon Enforcement Workshop, 27-29 June
2006 in Brussels

15

Illegal caviar trade in Bulgaria and Romania | 2013

Introduction

implementation of these measures” is seen as a main reason for this. The
authors postulate that a moratorium can only be efficient if poaching
can be terminated. However, they expressed concern that poaching
would continue in Bulgaria beyond a ban for a number of reasons e.g.
insufficient number of staff and financial means for controls and a lackof adequate labelling of caviar. The Bulgarian National Strategic Plan forFisheries and Aquaculture18 mentions illegal fishing of many types of fish,
not just sturgeons, as a problem in Bulgaria, estimating it to equal thequantity of fish caught legally.
As a study of seizure data between 2000 and 2009 showed, no casesof illegal caviar trade were reported by Romania and Bulgaria in thisten-year period, while there were 14 cases reported by other EU Member
States (Austria, France, Germany, Hungary, Italy, and the Netherlands)
with Romania and Bulgaria implicated17.
However, there are relevant seizures in both countries, which did notconcern caviar, or took place after the timeframe of the present study:
Romanian authorities seized two large shipments of sturgeon meat in2005:• 204.5 kg of sturgeon meat from Italy was confiscated at Customs of
Baneasa airport in Bucharest in April 2005 and destroyed• 210 kg of sturgeon meat from Poland was confiscated at Arad

Regional Customs – on the border with Hungary – in August 2005,
and a fine of RON 2500 was imposed28.

These seizures followed a “sturgeon alert” by the Romanian Customs andfive years of intensive training on CITES for Customs officers in Romania.
In Bulgaria a major seizure of sturgeon meat and caviar took place inMarch 2012.

• 16 kg of caviar and 30 kg of meat from Beluga Sturgeon (Huso huso)
were confiscated when authorities stopped a car in March 2012close to Montana (a city and province in northwestern Bulgaria,
approx. 50 km south of the Danube). The fish was said to be caught
in the Danube near Nikopol (Pleven province) and Svishtov (Veliko
Turnovo province) and was apparently to be sold in Vidin29.

29

http://www.konkurent.bg/novini/16415/spipaha-16-kila-hayver-ot-moruna; http://www.montana.mvr.bg/PressOffice/News/news_20120312.htm

Illegal caviar trade in Bulgaria and Romania | 201316

2. Methodology
2.1 Development of market survey methodology
The methodology for carrying out the market survey was developed withthe support of experts from TRAFFIC, WWF, and officials from Bulgaria,
Romania and other EU Member States. WWF staff in Bulgaria andRomania supported the project with information on local circumstancesand provided contacts to relevant agencies and experts. Information from
Customs authorities of other EU Member States was very helpful to define
focal areas of research. CITES Management Authorities from Romania
and Bulgaria provided background information on the caviar trade andcompleted questionnaires about labelling and trade regulations.
The focus of the market survey was on caviar from Romania and Bulgaria.
Survey teams visited major cities, holiday resorts along the Black Sea
coast, and areas along the Danube where sturgeons were traditionally
fished, as this is where most caviar trade was expected. Selected shops,
restaurants, markets, street vendors and sturgeon farms were visited.
Additional information was to be gathered, where possible, regarding
vendors, locations, products offered for sale, caviar sources and trade
methods and routes. Where caviar was available, small samples werebought for DNA analysis in order to be able to verify the species origin of
the caviar.
Due to the sensitive nature of the issue, a covert approach was consideredappropriate. Site visits were made by surveyors with a realistic story
to explain the interest in buying caviar, adapted to the location andsituation.
Obtaining samples for DNA testing in such a context was only possible
through purchases (only four samples were obtained directly from
Bulgarian sturgeon farms and were donated to the study free of charge).
However, to limit the negative impacts of such purchases, the project
designers took due care to limit the number of purchases to a minimum
and to ensure that only small quantities of caviar were bought by thesurveyors.

2.2	Survey teams
In both Romania and in Bulgaria, a team of two people were contracted
as surveyors. Each team was made up of nationals of the target country.
Each surveyor team had adequate background and experience withresearch activities though in different subject areas; therefore results for
17

Illegal caviar trade in Bulgaria and Romania | 2013

Methodology

the two target countries are not necessarily directly comparable.
Face to face briefings about the caviar trade and the status of sturgeons
took place between the surveys teams with the WWF project manager andthe TRAFFIC project partner before survey work commenced. They werealso warned about risks, and risk reduction strategies were explained.
Focal areas and sites were determined and different approach strategies
devised, according to local circumstances.

2.3	Survey period
The fieldwork period was focused on times when the chances of finding
caviar on the market were expected to be the highest. Work began in April
2011, in order to cover the main sturgeon migration. The autumn peakin migration was missing in 2011 due to extremely low water levels in the
Danube. The survey period lasted until February 2012 to allow a sufficientnumber of controls and research work and in order to include the peakcaviar selling times of the year (St Nicholas’ Day on 6th December,
Christmas and New Year).
Throughout the market survey period, sturgeon fishing (except withspecial permits for breeding purposes) and trade in wild caviar from the
Danube and Black Sea were prohibited both in Romania and in Bulgaria.

2.4 DNA analysis
In most cases it is not possible to determine the species origin of caviar
by visual inspection alone and molecular methods have been used forthis purpose. DNA analysis of caviar or other sturgeon products has
been used to identify to the species level, including hybrids, which are
popular in aquaculture production16, 30. This methodology can establish if
there are discrepancies between the species indicated on the label on thecontainer and that of the caviar in the container. If undertaken on a larger
scale, DNA testing of caviar on the market can also provide information
on which sturgeon species are most traded and – in the case of illegallyobtained wild caviar – which are most affected by poaching.
DNA analysis is not yet sufficient to identify different populations of
the same species (e.g. Beluga caviar from the Danube/Black Sea versus
from the Caspian Sea, especially as sturgeons with haplotypes from
Caspian populations might be caught in the Danube as a consequenceof restocking or escapes from aquaculture operations). DNA analysis isalso not able to distinguish between caviar of wild and farmed origin, as
30

Ludwig A. (2008): Identification of Acipenseriformes species in trade. J. Appl. Ichthyol. 24 (Suppl. 1), 2-19

Illegal caviar trade in Bulgaria and Romania | 201318

Methodology

there are no genetic differences between wild and hatchery-raised fish30.
Potential methods to address this could be the determination of fatty
acid composition, reflecting differences in feed sources between wildcaught and intensively farmed sturgeons31, or the analysis of isotopes,
whose compositions differ with different food or in different waters.
Isotope analysis was used in a case in Germany, where caviar labelled
as originating from Bulgarian aquaculture was shown actually to derivefrom the Caspian Sea17. The development of isotope analysis could be a
crucial step in combating the “laundering” of illegally obtained wild caviar
through farms.
Survey teams collected 14 caviar samples from Bulgaria and 14 caviar
samples from Romania. Two additional caviar samples with Bulgarian
origin were purchased in Austria. After purchase, samples were
preserved in 96% alcohol (stored in a refrigerator) or frozen. They werethen analysed at the Danube Delta National Institute (DDNI), Tulcea,
Romania (www.ddni.ro) and at the Leibniz-Institute for Zoo and Wildlife
Research (IZW), Berlin, Germany (www.izw-berlin.de).

2.4.1	PCR-RFLP analysis
PCR-RFLP (polymerase chain reaction - restriction fragment length
polymorphism) analysis was applied by the DDNI in Romania. The
methodology (as outlined in Ludwig, 200830) allows identification ofdifferent species of the order of Acipenseriformes, which includes allsturgeon and paddlefish. By targeting mitochondrial DNA (cytochrome bsequences), the maternal sturgeon species can be determined. Therefore,
the technique does not detect hybrids (as no conclusions on the paternal
species are possible). Additionally, this approach has limitations
for the differentiation of very closely related species (e.g. Acipenser
gueldenstaedtii, A. persicus and A. naccarii).

2.4.2 DNA sequencing
To reconfirm the results from PCR-RFLP analysis and to test the samples
with poor DNA, samples were also analysed by DNA sequencing at IZWin Germany. With this more sensitive methodology, the successionof nucleotides representing the genetic code is determined. By using
polymorphism of the mitochondrial cytochrome b gene, which harbours
a sufficient amount of species-specific variation for nearly all sturgeon
species, the maternal species can be determined with a high level ofcertainty. If sufficient reference data sets for evaluation are available
in public data bases, the degree of DNA sequence variation allows
31

Gessner J., Würtz S., Kirschbaum F., Wirth M. (2008). Biochemical composition of caviar as a tool to discriminate
between aquaculture and wild origin. J. Appl. Ichthyol. 24 (Suppl. 1), 52-56

19

Illegal caviar trade in Bulgaria and Romania | 2013

Methodology

separation of sturgeon species and even of sub-species and populations30.
However, for several reasons (close phylogenetic relationship, artificial
hybridization, and hybridization with escaped fish from aquaculture
or release programmes) some species of sturgeons can often not be
distinguished by molecular methods:• The very closely related species from the Russian Sturgeon complex(= Russian Sturgeon Acipenser gueldenstaedtii, Persian Sturgeon A.
persicus and Adriatic Sturgeon A. naccarii)• Russian Sturgeon (Acipeneser gueldenstaedtii) and Siberian

Sturgeon (A. baerii), which often have some parts of their DNA
the same as from the other species, due to historical hybridizationsof these two species in Russian aquaculture operations anduncontrolled release of these animals, which are commonly used
as founder populations in many sturgeon farms worldwide, andprobably also in the Danube region.

No molecular approach has yet been developed to solve this issue
sufficiently.

© WWF

Illegal caviar trade in Bulgaria and Romania | 201320

3. Results
30 samples were obtained as a result of around 100 visits (with somesites being revisited several times). In Romania, 38 sites were visited and14 samples were purchased. In Bulgaria, visits at 41 sites resulted in 14
samples. An additional 2 samples of Bulgarian farm caviar were acquiredin Austria to demonstrate the significance of the region as a supplier for
European consumer markets.
Table 3 (see Executive Summary) summarizes all findings.

3.1 Vendor types
Visits were made at all potential locations where caviar might be sold.
Table 4: Vendor types in Bulgaria, Romania and Austria, with number of samples obtained

21

Type of Vendor

Romania

Bulgaria

Austria

Restaurants

5

2

0

Market stalls

3

0

0

Individual vendors(e.g. street hawkers, fishermen)

3

0

0

Sturgeon farms

0

4

0

Fish shops

0

3

2

“Russian” shops

0

2

0

Other shops

3

3

0

TOTALS

1414

2

Illegal caviar trade in Bulgaria and Romania | 2013

Results

3.1.1	Shops
Many shops both in Romania and Bulgaria explained that they used
to have caviar for sale but had stopped offering it due to low demand.
Some shops only stock sturgeon caviar for the main selling time around
Christmas and New Year. In several cases, caviar could only be bought onorder a few days in advance.

3.1.2 Restaurants
In some restaurants, caviar was listed on the menu, but in others it
could be obtained on special request. Surveyors found that caviar fromwild sturgeon is used as a sales argument to attract customers. In somerestaurants in Romania, waiters advertised their caviar as a special
delicacy from wild sturgeons from the region. However, in several casesa request for caviar was denied after lengthy check-ups of the potential
customers (including their car and license plate) and discussions amongstaff, even if the initial request was received positively or caviar was listed
openly on the menu.

3.1.3 Individual vendors (e.g. street hawkers and fishermen)

Figures 2 and 3: Fishermen at Giurgeni bridge, Romania, showing that they offer
big fish – which often means sturgeons – for sale
© WWF

Street vendors at Giurgeni
bridge in Romania.

© WWF

Illegal caviar trade in Bulgaria and Romania | 201322

Results

Street vendors and fishermen are a very interesting group of suppliers but
they can be difficult to approach because they are cautious about sellingto unknown customers. Individual vendors in both countries offered tosell wild sturgeon caviar to survey teams.
In Romania, three samples were purchased from these types of vendor,
all said to be from wild sturgeons. No caviar was sold by fishermen on the
Danube upstream between Giurgiu and Calarasi, although waiters in acaviar-serving restaurant in Bucharest claimed that one of their sources
for cheap caviar was from the Giurgiu-Ruse border area in Bulgaria.
In Bulgaria, no samples of caviar were collected from individual vendors,
though some fishermen – illegally – offered wild caught Sterlets for sale.
A fisherman from Vidin repeatedly promised to sell caviar from wildcaught sturgeons from the following autumn migration, but in autumn
2011 the sturgeon migration failed due to extremely low water levels in
the Danube so no sale was possible.

3.1.4	Sturgeon farms
Nine samples of farmed caviar from Bulgaria were acquired within
the survey (four directly from the sturgeons farms, one from a shop in
Bulgaria, two from a shop in Romania, two from a shop in Austria), andall of these had the required CITES-labels and codes. During the periodof the market survey, Romanian sturgeon farms did not sell caviar fromtheir own stock as the fish had not yet reached reproductive maturity.

3.1.5 Markets
According to local information, certain markets had a reputation for
selling illegal caviar. Three samples were obtained from markets, but
in many cases enquiries for caviar were treated with suspicion andultimately declined.

3.1.6 Internet
A number of companies or private individuals in Bulgaria and Romania
offer caviar for sale on the internet. Online research found that most of
the company sites provide pictures which show that the caviar has CITES
labels. Most company sites actually offered to sell farmed caviar sourced
from other countries, with only one product apparently from domestic
aquaculture. At one company site, the information on species and countryof origin was inconsistent (“Natural caviar from Russian Sturgeon”
Acipenser gueldenstaedtii from a German producer was announced, but
a photo of the CITES label showed a hybrid of Huso dauricus x Acipenser
schrenckii as the species and China as the country of origin).
23

Illegal caviar trade in Bulgaria and Romania | 2013

Results

The online offers from private individuals did not provide any
information regarding CITES labelling, and the source of caviar is
unknown. Survey teams attempted to contact many of these vendors but
the response rate was low, and those who did speak to the survey teammembers were very suspicious, asked lots of questions, and ultimately
refused to sell caviar. Consequently, no samples obtained via the internet
could be included in this research. Interestingly, one of the telephone
numbers advertised on the internet correlated with a telephone number
obtained by the field survey teams from an individual vendor. This led tothe purchase of caviar from presumably wild-caught sturgeons.

3.2 The marketing of non-sturgeon caviar
The market survey came across other types of caviar that do not originate
from sturgeon. In Bulgaria, for example, a paste made from the eggsof herring or carp is known as “tamara haiver” (cream caviar). Thesetypes of fish eggs are not subject to the same rules and regulations as
caviar from sturgeon. Some non-sturgeon caviar did appear to be “mismarketed” as sturgeon caviar. For example, containers often had asturgeon illustration and were entitled “black caviar” and displayed theactual ingredients in tiny letters.

3.3 Implementation of caviar labelling in Bulgaria andRomania
Some details of the caviar labelling requirements laid down by
Commission Regulation (EC) No 865/2006, as amended, (e.g. productionof the labels, position of the label on the tin, etc.) need to be regulated
by national laws. Accordingly, a questionnaire was sent to the CITESManagement Authorities of Bulgaria and Romania to get details about the
specific requirements in May 2011.

3.3.1 Caviar labelling regulations in Bulgaria
The Bulgarian CITES Management Authority reported that in Bulgaria,
Regulation no. 3 from 31 October 2008 on marking and labelling ofspecimens of species under Regulation 338/97 on the protection of
species of wild fauna and flora by regulating trade therein provides thelegal and administrative measures at the national level on labelling ofcaviar processed, packaged or repackaged and on ensuring that caviar
on the domestic market is appropriately labelled. According to thisregulation, the labels have to be glued to each caviar tin in a way that
ensures that it covers the tin and does not allow the removal and transfer
to another tin without destroying its integrity. This regulation also
Illegal caviar trade in Bulgaria and Romania | 201324

Results

prescribes the information (or codes) to be used on the label.
Specimens of licensed Bulgarian CITES caviar labels, as provided by the
Bulgarian CITES Management Authority, are shown in Annex 5.4.
The production of the labels was reportedly not centralized in Bulgaria;
the labels are instead issued by the trader after they have been authorized
by the CITES Management Authority. In May 2011, four companies
were registered by the CITES Management Authority. As two of thesehave the same registration code, a total of three label types were in use.
The regulation does not prescribe any security features for the labels
according to the Bulgarian CITES Management Authority.
The Bulgarian CITES Management Authority reported that in Bulgaria,
national legislation contains provisions covering sanctions in case ofnon-compliance with the labelling requirements (Regulation no. 8 isconnected with article 102a paragraph 2 of the Biodiversity Act), in theform of fines.
The Bulgarian Management Authority reported not having encounteredany evidence of forged labels.

3.3.2 Caviar labelling regulations in Romania
The Romanian CITES Management Authority reported that in Romania,
Governmental Decision no. 1191/2010 regarding the register system ofsturgeons stocks from aquaculture facilities and of the caviar produced
from aquaculture operations, and marking by labelling of the caviar
provides legal and administrative measures at the national level on thelabelling of caviar processed, packaged or repackaged and on ensuringthat caviar on the domestic market is appropriately labelled. This
regulation requires that the label seals the caviar container.
For specimens of licensed Romanian CITES caviar labels, which were
contributed by the Romanian CITES Management Authority, see Annex
5.5.
The production of the labels is not centralized in Romania according to
the Romanian CITES Management Authority. In May 2011, two different
labels were in use in Romania for two of the 14 exporting or processing
companies that have been licensed by the CITES Management Authority.
The regulation does not prescribe any security features for the labels.
Romania reported that their national legislation (Governmental
Ordinance no. 195/2005 on environmental protection as amended byGovernmental Ordinance no. 164/2008) contains provisions covering
sanctions (more specifically, fines) in case of non-compliance with
25

Illegal caviar trade in Bulgaria and Romania | 2013

Results

the labelling requirements. For private (or natural) persons the fine is
between approximately EUR 730 and approximately EUR 1460 and forbusinesses between approximately EUR 6070 and approximately EUR 12140.
The Romanian Management Authority reported not having encounteredany evidence of forged labels.

3.3.3 Ambiguities concerning licensed caviar producing, processing and (re-)
packaging plants
Caviar processing and (re-)packaging plants need to be licensed by theManagement Authority of CITES Member States in order to be allowed toprocess, (re-)package or export caviar. According to the EU Wildlife Trade
Regulations (Regulation (EC) No 865/2006, amended by Regulation(EC) No 100/2008, Art. 66, paragraph 7)9 caviar-producing aquaculture
operations must also be licensed by the Management Authority.
However, there is some evidence from Bulgaria that companies otherthan those officially listed in the CITES register as exporting or processing
facilities are involved in caviar production or processing. There is also
some ambiguity about whether companies not licensed for export areindeed exporting.
Apart from the six licensed companies listed by CITES24, companies like
Reya Fish, Aquafish or Akvamash are also involved in caviar production
or processing. Akvamash claims to breed four species of sturgeons and tohave a sturgeon caviar capacity of 1.5 tonnes, already selling caviar to the
US and to other EU countries32. Nevertheless, none of these companies
are registered by CITES as exporting or processing facilities.
Another unclear issue is that – according to the CITES website – only
three companies in Bulgaria are listed as licensed caviar exporters(Agamemnon I Ltd., Aqua Beluga Ltd and ET FANI-Miroslav Shopov)24.
The other three companies are only registered as processing and/or
repackaging plants. This leads to the assumption that either these other
Bulgarian companies (Beluga Inc. Vidin, Oscietre Commerce Ltd. andParpen Tchobanov Ltd.) do not export caviar or that the information in
the CITES register is not fully up-to-date.

32

Akvamash produces caviar for the US and the EU. Eurofish Magazine 6/2010, 33-34

Illegal caviar trade in Bulgaria and Romania | 201326

Results

3.4 Results from DNA testing
The results of the DNA testing are contained in Table 5 below. For threesamples from Romania, no results could be achieved, since the caviar andits DNA were too degraded (RO 4, 21 and 24). In the end, a total of 27
samples (= 90 % of all samples) could be analysed.
Table 5: Summary of results on sturgeon species identification from samples acquired from the Romanianand Bulgarian markets.
Samplecode

Location of
acquisition

CITES label
species code

Species (of femaleline) identified

Comments

SAMPLES FROM ROMANIA

27

RO 1

Restaurant, Tulcea

no CITES
label visible

HUS

described by vendor as fromwild Beluga Sturgeons from Sulina

RO 2

Anonymous,Port of Sulina

no CITES
label

HUS

allegedly the caviar supplier of RO 1;
described by vendor as
from wild sturgeons

RO 3

Anonymous, Harsova,
Constanta county

no CITES
label

HUS

contact from RO 4; described by
vendor as from wild sturgeons

RO 4

Fisherman, Vadu Oii –Giurgeni Bridge

no CITES
label

no results

described by vendor as
from wild sturgeons

RO 5

Restaurant,
Bucharest

no CITES
label visible

HUS + at least one
other sturgeon species

RO 6

Restaurant,
Bucharest

no CITES
label visible

HUS + at least one
other sturgeon species

RO 7

Private party at
restaurant, Bucharest

no CITES
label visible

GUE/BAE + at least
one othersturgeon species

RO 8

Shop, Bucharest

CITES label
visible but
species code
not legible

GUE/BAE + at least
one othersturgeon species

farmed caviar from Hungary

RO 9Market stall,
Piata Obor,
Bucharest

no CITESlabel

not caviar

not sturgeon caviar, but
sequences of sturgeon DNA –potentially made from sturgeon
meat and other material

RO 10

Market stall,
Piata Obor,
Bucharest

no CITESlabel

not caviar

not sturgeon caviar, but
sequences of sturgeon DNA –potentially made from sturgeon
meat and other material

RO 11

Restaurant,
Bucharest

no CITES
label visible

no results

RO 12

Market stall,
Piata Obor,
Bucharest

no CITESlabel

not caviar

not sturgeon caviar

RO 13

Shop, Bucharest

GUE

GUE/BAE*in agreement with CITES label;
farmed caviar from Bulgaria

RO 14

Shop, Bucharest

GUE

no results

farmed caviar from Bulgaria

Illegal caviar trade in Bulgaria and Romania | 2013

described by vendor as
from wild sturgeons

Results

Samplecode

Location of
acquisition

CITES label
species code

Species (of femaleline) identified

Comments

SAMPLES FROM BULGARIABG 1Fish shop, Sofia

no CITESlabel

not caviar

no DNA traceable; synthetic product

BG 2

Shop, Sofia

hybrid of
BAExNACNAC

in agreement with CITES label;
farmed caviar from Italy

BG 3

Fish shop, Sofia

no CITES
label

no caviar

no DNA traceable;
synthetic product

BG 4

Sturgeon farm &caviar trader

GUE

GUE

in agreement with CITES label;
farmed caviar from Bulgaria

BG 5

Fish restaurant, Varna

no CITES
label visible

GUE/PER/NAC

DNA from at least
two different animals

BG 6

Fish restaurant, Varna

no CITES
label visible

Lumpfish(Cyclopterus lumpus)

BG 7

Fish shop, Sofia

hybrid of
NACxBAE

GUE/BAE*in agreement with CITES label;
farmed caviar from Bulgaria

BG 8

Russian Shop, Varna

BAE

GUE/BAE*in agreement with CITES label;
farmed caviar from Germany

BG 9

Sturgeon farm &caviar trader

GUE

GUE/PER/NAC*

in agreement with CITES label;
farmed caviar from Bulgaria

BG 10

Shop, Plovdiv

BAE

GUE/BAE*in agreement with CITES label;
farmed caviar from Uruguay

BG 11

Shop, Plovdiv

SCH

DAU

different from CITES label;
microsatellites indicate hybrid status,
probably SCHxDAU;
farmed caviar from China

BG 12

Sturgeon farm &caviar trader

GUE

GUE/BAE*in agreement with CITES label;
farmed caviar from Bulgaria

BG 13

Sturgeon farm &caviar trader

GUE

GUE/BAE*in agreement with CITES label;
farmed caviar from Bulgaria

BG 14

Russian shop, Plovdiv

GUE

GUE/PER/NAC*

in agreement with CITES label;
farmed caviar from Germany

SAMPLES OF BULGARIAN ORIGIN (BOUGHT IN AUSTRIA)AT 1Fish shop, Vienna

STE

GUE/BAEdifferent from CITES label;
farmed caviar from Bulgaria

AT 2

Fish shop, Vienna

HUS

GUE/BAE (but noprobably different from CITES label;
farmed caviar from Bulgaria

secure species
determination possible)* These species of sturgeons can often not be distinguished by molecular methods, but the caviar was determined to beout of this group of species.
HUS: Beluga Sturgeon (Huso huso)

NAC: Adriatic Sturgeon (A. naccarii)

BAE: Siberian Sturgeon (Acipenser baerii)

DAU: Kaluga Sturgeon (H. dauricus)

GUE: Russian Sturgeon (A. gueldenstaedtii)

SCH: Amur Sturgeon (A. schrenckii)

PER: Persian Sturgeon (A. persicus)

STE: Stellate Sturgeon (A. stellatus)

Illegal caviar trade in Bulgaria and Romania | 201328

Results

3.4.1	Samples sold as caviar but shown not to be caviar from sturgeon
As can be seen from the table above, six of the samples proved to be fakei.e. were not caviar from sturgeons:• One sample from a Bulgarian fish restaurant (sample code BG 6) wasfrom Lumpfish (Cyclopterus lumpus).

• Two Bulgarian samples from fish shops in Sofia (sample codes BG

1 and 3) were not fish eggs. It is unclear exactly how this product is
produced and what it is but there were no traces of sturgeon DNA
and the product was shown to not be eggs from fish of any kind

• Three Romanian samples (sample codes RO 9, 10 and 22) from afish shop at a market in Bucharest were not fish eggs either, but
DNA of sturgeons could be determined, suggesting that it was madeartificially from sturgeon tissue and other material.

Prior to DNA extraction, the unusual size and/or colour of these caviar
samples were noted. The size of e.g. sample RO 9 was much smaller than
the typical sturgeon caviar (see Figure 4), indicating that this material
did not originate from sturgeon. In ethanol, the supernatant of thesesamples was reddish-brown (RO 9 and 10) or greenish (BG 1 and 3),
which means that the material had been coloured to give it the typical
blackish colour of sturgeon caviar and the dyes washed out in ethanol.
Figure 4: Sample code RO 9 (A) compared to typical Beluga caviar (B).
© DDNI Romania

A.

29

Illegal caviar trade in Bulgaria and Romania | 2013

B.

Results

3.4.2 Caviar from sturgeons
For 21 out of the 30 purchased samples sturgeon could be determined as
species of origin.
Five of all samples were declared by vendors to be from wild sturgeon(RO 1, 2, 3, 4, 6) and were subsequently shown by DNA testing (except
for sample RO 4, where DNA analysis was not possible, but there was
no indication that it was not from sturgeon.) to be totally or partly from
Beluga Sturgeon (Huso huso), making this claim credible.

3.4.2.1 Caviar from sturgeons: samples from Romania
Of the samples purchased in Romania, five samples were totally or partly
from Beluga Sturgeon (Huso huso):• Three of these samples were bought in restaurants – RO 1 in Tulcea(purely Huso huso), RO 5 and 6 in Bucharest (Huso huso with atleast one other sturgeon species present).

• Two samples were obtained from street vendors – RO 2 in the port ofSulina and RO 3 in Harsova (both purely Huso huso).

CITES labels were not shown in these cases. In four of these cases,
information from waiters or vendors indicated that the origin of thesesamples was from wild individuals. If true, they must have been obtainedby illegal catches as sturgeon fishing is banned in Romania.
Three samples from Romania were shown to be from Siberian Sturgeon(Acipenser baerii)/Russian Sturgeon (A. gueldenstaedtii):• One of these samples (RO 7) was collected at a private party in a

restaurant in Bucharest. In this case DNA analysis determined
Acipenser baerii/A. gueldenstaedtii, but there was at least one othersturgeon species present also.

• The other two samples (RO 8 and 23) were purchased from shops in

Bucharest. Both were labelled according to CITES regulations. In thecase of RO 8, more than two sturgeon species were found, with oneof them being Acipenser baerii/A. gueldenstaedtii.

3.4.2.2 Caviar from sturgeon: samples from Bulgaria• Of the caviar samples obtained in Bulgaria, six samples were fromthe closely related group of Russian Sturgeon (A. gueldenstaedtii)/
Adriatic Sturgeon (A. naccarii)/Persian Sturgeon (A. persicus):• Three were obtained at Bulgarian sturgeon farms (BG 4, BG
Illegal caviar trade in Bulgaria and Romania | 201330

Results

9 and BG 13) and all had CITES labels with species code of A.
gueldenstaedtii. BG 4 proved to be from A. gueldenstaedtii, BG
9 from one of the species group; however, in sample BG 13, DNAfrom different individuals were found, which is unusual for A.
gueldenstaedtii where individuals are genetically too similar to be
distinguished and this indicates the sample is a mixture originatingfrom several species, including A. gueldenstaedtii.

• BG 14 – purchased in a Russian shop in Plovdiv – A. gueldenstaedtii(from Germany) was established as the species of origin, as correctly
shown on the CITES label.

• BG 2 – from a shop in Sofia – was determined as A. naccarii, witha CITES label showing a hybrid of a Siberian Sturgeon (Acipenser
baerii) male and an Adriatic Sturgeon (A. naccarii) female from Italy
as animal of origin.

• BG 5 was bought in a fish restaurant in Varna; no CITES label was
visible in this case.

Four samples were found to derive from Siberian Sturgeon (Acipenser
baerii)/Russian Sturgeon (A. gueldenstaedtii), all were correctly labelled
and species codes were in agreement with DNA results:• BG 7 was bought in a fish shop in Sofia, the species code of the CITES
label showed a hybrid of an Adriatic Sturgeon (A. naccarii) maleand a Siberian Sturgeon (Acipenser baerii) female from Bulgaria as
animal of origin.

• BG 8 was from a Russian shop in Varna, with a CITES label andspecies code of Siberian Sturgeon (Acipenser baerii) from Germany.

• BG 10 was acquired at a shop in Plovdiv, also with a CITES label

and species code of Siberian Sturgeon (Acipenser baerii), but from
Uruguay.

• BG 12 was provided by an aquaculture operation; according to thespecies code of the CITES label it derived from A. gueldenstaedtii.

One sample (BG11) of farmed caviar from China was labelled as Acipenser
schrenckii (Amur Sturgeon), but was actually found via DNA analysis tobe Huso dauricus (Kaluga Sturgeon) as species of origin, at least of thefemale line. Therefore this is likely to be a hybrid of Huso dauricus andprobably Acipenser schrenckii, which has become a quite common hybrid
in aquaculture in China in recent years (Arne Ludwig, pers. comm.,
September 2012).

31

Illegal caviar trade in Bulgaria and Romania | 2013

Results

3.4.2.3 Caviar from sturgeon: samples from Austria
Two samples of Bulgarian farm caviar were bought in Vienna:• AT 1 had a CITES label with the species code of Stellate Sturgeon(Acipenser stellatus), but DNA analysis indicated that the caviar was
in fact from Siberian Sturgeon (Acipenser baerii)/Russian Sturgeon(A. gueldenstaedtii).

• AT 2 was labelled as from Beluga Sturgeon (Huso huso), but DNA

results pointed also to Siberian Sturgeon (Acipenser baerii)/Russian
Sturgeon (A. gueldenstaedtii) as the species of origin. However,results were too poor to allow a secure species identification.

These cases probably do not indicate a problem from a species
conservation point of view, as Siberian Sturgeon is not native to the
Danube but a species quite commonly reared in aquaculture facilities.
Nevertheless, they do illustrate problems with the reliability of the caviar
labeling system.

3.4.3	Samples without a CITES label
In 15 cases – half of the samples – the origin of the purchased caviar
could not be determined as no CITES labels were shown:• Seven unlabelled samples were obtained in restaurants (two in

Bulgaria, five in Romania), where it is not obligatory to show
the CITES labels to customers. However, two of the Romanian
restaurants (in Tulcea and in Bucharest) emphasized that they offer
wild caviar from Sulina. In one Bulgarian restaurant, the caviar was
not from sturgeon but from Lumpfish (Cyclopterus lumpus).

• Five unlabelled samples were acquired in fish shops (two in Bulgaria,
three in Romania). All of those were shown by DNA analysis not to
be caviar from sturgeon.

• Three unlabelled samples (all in Romania) were obtained fromfishermen or vendors selling caviar in the street, allegedly from wildcaught sturgeons. One of these was found in the port of Sulina at theBlack Sea via information from staff in a caviar-serving restaurantin Tulcea. Two samples were obtained further up the Danube, atGiurgeni Bridge and in the nearby town of Harsova.

Illegal caviar trade in Bulgaria and Romania | 201332

Results

3.4.4 Caviar imported from outside of the lower Danube region
Six samples of caviar that were purchased had been imported fromcountries outside of the lower Danube region; namely from Germany (BG
8, BG 14), Italy (BG 2), Hungary (RO 8), China (BG 11) and Uruguay (BG
10). All had CITES labels, displaying them as captive bred. There wasmore of this caviar available on the market, but as this was not directly
within the remit of this study, only a limited selection of this category wasbought.
Figure 5: Origin of puchased samples

Unclear origin: 15 samples (6 of them not sturgeon caviar)
Farmed in Bulgaria: 9 samples
Farmed outside of the region: 6 samples

3.4.5 Caviar produced from mixes of different sturgeon species
For five samples, DNA analysis found that the caviar was not from asingle species, but from several (RO 5, 6, 7, 8 and BG 13). This indicatesmislabelling, as according to current regulations2 only “pressed caviar”(=dense briny paste made from damaged sturgeon eggs) can be a
combination of roes from different sturgeon species and must be labelled
as MIX. No labels in the study were labelled with this code and none of
the samples was “pressed caviar”.
Also experience from DNA analysis at the Leibniz-Institute for Zoo andWildlife Research, Berlin, shows that mixing of caviar from different
species can be found occasionally (Arne Ludwig, pers. comm., September2012).
33

Illegal caviar trade in Bulgaria and Romania | 2013

Results

3.5 Qualitative information of illegal fishing and trade
networks in Romania and Bulgaria
Relevant anecdotal information was gathered during the survey regarding
evidence of illegal fishing and trade during informal conversations with
official and unofficial traders, enforcement officials, fishermen as wellas other local people. This information is based on unconfirmed reports
gathered by survey teams.
Illegal caviar transfer is said to take place from Romania to Bulgaria as
well as the other way round, with many reports pointing to the town of
Ruse as an important crossing for caviar smuggling. Caviar from the
Ukraine is said to come to Bulgaria on ships or ferries over the Black Sea.
According to information from Bulgarian fishermen at the port of Varna,
Ukrainian sailors, who regularly cross the Black Sea, bring small amountsof caviar from Ukraine and sell it to restaurants in the area. Caviar is also
said to be transferred from Kazakhstan via Ukraine and Moldova. Also
cruise liners along the Danube and the Black Sea, which often offer caviar
on their menus, could potentially be involved in illegal trade networks, aswell as other vessels travelling up and down the Danube.
Restaurants appear to be connected to individual vendors throughpersonal networks. In one case in Romania, the trade chain could be
followed from a restaurant selling caviar to a supplier at the port ofSulina. Although the chief waiter in the restaurant claimed that wild
Beluga caviar from the area of Sulina was offered, he would not give any
contacts, but another middleman could be found. DNA analysis showedthat both the sample from the restaurant as well as the one bought at thesame day in Sulina were from Beluga Sturgeon (Huso huso), potentiallyeven deriving from the same specimen.

3.5.1 Bulgaria
Fishermen from the area of Kozloduj on the Danube stated that they use
state-of-the-art equipment to localize large sturgeons in the river. The fish
are tracked with sonar and then caught with electric devices. Coordinatesof sturgeons are saved with GPS, as well as those of nets and illegal hooklines (“carmaci”), so no buoys or empty bottles on the river surface marktheir locations and can reveal their presence to fishing inspections.
Bulgarian National Agency of Fisheries and Aquaculture (NAFA) reported
that hundreds of metres of “carmaci”, traditionally used for fishingsturgeon and banned since 200833, were confiscated along the Danube
in 2010 and 2011. Bulgarian NAFA registered just one case of sturgeon
fishing in the Danube without the necessary licence in 2008-2010 and
33

Law of Fisheries and Aquaculture, Article 35, Paragraph 6 (State Gazette No. 94/11.2005)

Illegal caviar trade in Bulgaria and Romania | 201334

Results

the poacher was fined. Only a few sturgeons accidently caught as bycatchin nets were reported – two Beluga Sturgeons in Vidin province in 2009
and 2011, one Beluga Sturgeon (a 70-80 kg male) in Kozloduj in 2010.
However, it is clear that unreported fishing of sturgeons is occurring as
demonstrated by recent seizures of illegal meat and caviar.
According to fishermen on the Bulgarian side of the Danube, sturgeon
catches have declined sharply, which has reduced the supply of illegal
caviar on the market. Nevertheless, and despite the risk of penalties,
fishermen around Kozloduj indicated that they still catch wild sturgeons,
even if the caviar yield is limited.
Caviar from poached sturgeons is sold to traders or directly to restaurants
in Sofia or in resorts on the Black Sea coast. Some Bulgarian fishermen
explained that caviar is sold to Romania, as higher prices can be achieved
there.
Bulgarian fishermen around Kozloduj related that Beluga (Huso huso) is
the most commonly caught species of sturgeon, especially in the westernpart of the Danube in the provinces of Vidin or Pleven. This correlateswith DNA results arising from this survey. In this area, at least 25-30
Beluga Sturgeons are said to be fished every year, usually in their restingsites. Locals report that those who are involved in poaching and trade of
Beluga Sturgeons are relatively well-off compared to others in the region.
Although protected by the catch moratorium, market survey teams
found that Sterlet (Acipenser ruthenus) is still fished in both Bulgaria
and Romania, as it can be caught with nets and does not need the use of
the banned “carmaci”. Fishermen at the western part of the Bulgarian
Danube offered wild caught Sterlets for sale in spring 2011 and evenvolunteered to send them to Sofia by bus.
Sturgeon breeders in Bulgaria told the surveyors that 8-10 years ago, they
were regularly offered illegal caviar from wild Danube sturgeons caught in
Bulgaria, Romania or Ukraine, as well as live wild sturgeons for breeding.
Nowadays, these attempts have purportedly become very rare – although
they still occur.
Mislabelling is also apparently used by illegal traders. One Bulgariancaviar producer claims that he found his labels on caviar tins for sale thatwere not produced by his company.
Authorities controlling restaurants in Bulgaria unofficially report thatthey are repeatedly finding jam or gherkin glasses of sturgeon caviar
without CITES labels in the fridges of some establishments. Restaurants
usually claim these to be a gift for private consumption and prosecutions
have not ensued from these cases.
35

Illegal caviar trade in Bulgaria and Romania | 2013

Results

All this information points to a substantial and active illegal fishing andtrade in caviar in Bulgaria.

3.5.2 Romania
There are reports that wild sturgeons are poached from the Borcea
branch of the Danube, and that the caviar is then sold in Giurgiu to a
German trader who transfers it to Bulgaria – through Ruse – from where
it is sold by an organized system as Bulgarian farm caviar – “legalized”
and mis-declared with source code “C” (displaying it as captive bred).
Additionally, sturgeon breeders interviewed by survey teams report being
offered illegal caviar.
In a restaurant in Bucharest which offers caviar, the Romanian surveyors
were told that cheap caviar – supposedly from poached sturgeons – canbe sourced from Harsova/Giurgeni as well as from Giurgiu/Ruse on the
Bulgarian side.
Sterlets up to 40 cm in length were sold at Piata Obor Market in
Bucharest in spring 2011, priced at RON 35 (approx. EUR 8.50) per kilo.
The vendor promoted them as “purely Romanian” and “taken from thewild”. The same man also sold caviar which he assured the surveyors
to be from sturgeons but was in fact shown by DNA testing to be fake.
In autumn 2011, Sterlets were also found for sale in the street along the
Danube between Giurgiu and Calarasi. The fish were rather small (around
1 kg).
Again, this information points to a substantial and active illegal trade insturgeons and caviar in Romania.

3.6	Prices for caviar
Prices of caviar vary a lot. A very low price could be an indicator thatthe caviar is in fact fake, but market surveys showed that this is notnecessarily the case.
In Romania, the lowest prices were approximately 0.30 EUR/gram forcaviar (subsequently shown via DNA analysis not to be caviar) bought at afish shop. However, just slightly more – approximately 0.40 EUR/gram –was paid for Beluga (Huso huso) caviar in a restaurant (RO 1). According
to the waiter, this was from wild Danube sturgeons and the species (Huso
huso) was confirmed by DNA analysis. Prices went up to 4 EUR/gram forthe farmed caviar from Hungary purchased in a shop (RO 8).

Illegal caviar trade in Bulgaria and Romania | 201336

Results
Table 6: Prices of purchased real and fake caviar from Romania

SAMPLES FROM ROMANIA
Type of caviar

Price(in RON)

AmountPrice per(in grams) gram in EUR

RO 9, 10, 22; unlabelled;from fish shop in Bucharest

55.00

50

0.30

not caviar

RO 1; no label visible;from restaurant in Tulcea

150.00100

0.40

allegedly wild Beluga
caviar, confirmed by
DNA analysis to befrom Beluga Sturgeon

RO 5; no label visible;from restaurant in Bucharest

350.0050

1.60

RO 6; no label visible;from restaurant in Bucharest

400.0050

1.80

RO 23, 24; labelled (GUE/BG);
from shop in Bucharest

533.0050

2.40

RO 8; labelled (?/HU);
from shop in Bucharest

150.0010

4.00

Comments

allegedly wild caviar,
found by DNA analysis tobe from Beluga Sturgeon
and at least one
other sturgeon species

In Bulgaria, the three cheapest samples (BG 3, 1 and 6), all from shops,
proved to be not from sturgeons. Real sturgeon caviar with CITES labels,bought in shops, cost between 0.86 EUR/gram for farmed Italian caviar(BG 2) and 2.67 EUR/gram for farmed German caviar (BG 10).

37

Illegal caviar trade in Bulgaria and Romania | 2013

Results
Table 7: Prices of purchased real and fake caviar from Bulgaria

SAMPLES FROM BULGARIAType of caviar

Price(in RON)

AmountPrice per(in grams) gram in EUR

BG 3; unlabelled;from fish shop in Sofia

22.00

113

0.10

not caviar

BG 1; unlabelled;from fish shop in Sofia

22.50

113

0.11

not caviar

BG 6; no label visible;from fish restaurant in Varna

16.20

30

0.27

not sturgeon caviar

BG 2; labelled (BAExNAC/IT);from shop in Sofia

84.00

50

0.86

BG 7; labelled (NACxBAE/BG);
from fish shop in Sofia

105.0050

1.08

BG 8; labelled (BAE/DE);from Russian shop in Varna

125.0050

1.28

BG 11; labelled (GUE/DE);from shop in Plovidv

119.9930

2.07

BG 14; labelled (GUE/DE);from Russian shop in Plovdiv

210.0050

2.16

BG 10; labelled (BAE/UY);
from shop in Plovidv

155.9950

2.67

Comments

In Austria, farmed Bulgarian caviar sold as Beluga cost 4.20 EUR/
gram; farmed Bulgarian caviar sold as Sevruga (from Stellate Sturgeon,
Acipenser stellatus) was bought for 3.14 EUR/gram.

Illegal caviar trade in Bulgaria and Romania | 201338

Results
Table 8: Prices of purchased caviar from Bulgaria

SAMPLES OF BULGARIAN ORIGIN (BOUGHT IN AUSTRIA)
Type of caviar

Price(in RON)

AmountPrice per(in grams) gram in EUR

AT 2; labelled (HUS/BG);
from fish shop in Vienna

89.00

28.35

3.14

AT 1; labelled (STE/BG);
from fish shop in Vienna

119.00

28.35

3.14

Comments

When there are quotas for caviar from wild sturgeons and trade is legal,
it is expected to be more expensive than caviar from farmed sturgeons.
During the survey period, there was no quota for wild-taken caviar,
and any trade with caviar from wild sturgeons was illegal. As results for
Romania show, allegedly wild – and therefore illegal – caviar can have
similar prices as legal, farmed caviar.
Obviously it is hard to verify prices from the “black market” but some
information regarding prices for illegally traded sturgeon caviar wasreceived.
According to one individual, black market caviar prices in Tulcea,
Romania, were as follows in February 2011:• 1 kg Beluga caviar (from St George in the Danube delta): RON 24003000 (0.57-0.70 EUR/gram)• 1 kg Sevruga caviar (Stellate Sturgeon): RON 1400-1600 (0.33-0.38
EUR/gram)• 1 kg Beluga caviar (smuggled from Ukraine): up to RON 1800 (0.42
EUR/gram)

Another individual, an aquaculture manager, reported that illegal caviar
prices considerably undercut those of farmed caviar. This person reported
that poachers in Romania sell Sevruga caviar (from Stellate Sturgeon,
Acipenser stellatus), for EUR 200 per kilogram, whereas aquaculture
operations need to sell their caviar for at least EUR 500 per kilo due tothe high investment for sturgeon farming.
On the Bulgarian stretch of the Danube, fishermen around Kozloduj
told the surveyors that caviar from poached sturgeons was sold forapprox. 400 EUR/kg in Bulgaria, while it would achieve 1300 EUR/kg in
Romania.
39

Illegal caviar trade in Bulgaria and Romania | 2013

4. Conclusions and recommendations
4.1 Conclusions
4.1.1 There is evidence of illegal fishing of wild sturgeon in Romania andBulgaria
This survey found that the poaching of sturgeons still appears to be a
problem both in Bulgaria and Romania, despite legal protection in theform of sturgeon fishing bans in both countries. In five cases, the caviar
was declared by vendors to be wild caught, with DNA evidence showingthat at least four of these samples were from the highly sought-after andcostly Beluga Sturgeon (Huso huso).
In addition, there is plenty of qualitative evidence indicating that illegal
fishing still occurs on the Danube. Bulgarian fishermen indicate thatthey are still catching sturgeons in the Danube, and wild caught Sterlet(Acipenser ruthenus) is caught and sold in both countries.
These illegal catches present a significant threat to the last remaining
sturgeon stocks in the Danube, and the catch moratoria in Romania andBulgaria will not be successful if the regulations cannot be enforced more
effectively.

4.1.2 Caviar from wild sturgeons is still offered for sale
Although domestic trade in caviar from wild-caught Danube sturgeons
is forbidden in both countries, caviar claimed to come from wild-caught
sturgeon could be bought by surveyors on several occasions in Romania
and was offered for sale in Bulgaria. Caviar said to be from wild sturgeons
and offered without CITES labels – and thus illicit – was obtained
from street vendors in Sulina (RO 2), Harsova (RO 3) and at Giurgeni
bridge (RO 4). In two restaurants in Tulcea (RO 1) and in Bucharest (RO6), waiters claimed explicitly that their caviar was from wild Danube
sturgeons.
Naturally, true volume of illegal caviar trade could be considerably higher
than documented by the cases in this project.
In all cases where caviar was suspected to be from wild-caught sturgeons(except for RO 4, where DNA analysis failed), the species of origin was
Beluga Sturgeon (Huso huso), the most sought after species of Danube
sturgeon.
Illegal caviar trade in Bulgaria and Romania | 201340

Conclusions and recommendations

Though traders of illegal caviar are aware that their activities are against
the law and take preventive measures (close surveillance and detailed
enquiries of customers), the provenance of caviar from wild sturgeons –and from national territory – seems to be still a valuable sales argument.

4.1.3 Samples without CITES labels presented as caviar from sturgeon are often
fake
The market survey found that six samples were not in fact sturgeon
caviar, despite being explicitly sold as such. These samples were typicallyfrom market stalls or shops and did not have a visible CITES label but
were presented to customers as caviar from sturgeon. DNA analysis foundthese to be artificial eggs made from sturgeon meat or other tissue (RO 9,
RO 10), eggs from other species of fish e.g. Lumpfish (BG 6) or not eggs
from fish of any kind but made artificially by unknown means (BG 1, BG
3).
In addition to this, in a number of cases “caviar” was offered for sale in
Bulgaria and Romania (as well as e.g. in Austria), with the drawing ofa sturgeon on the lid and the words “black caviar” (usually in Russian)
implying it is from sturgeons, though the ingredients usually declare theproduct are eggs from other fish. The misleading of consumers in thismanner is primarily a consumer issue rather than a conservation issue.
However, it does have implications for conservation where sturgeon meatis involved and therefore is an issue which should be considered by CITES
and the enforcement authorities.

4.1.4 The incorrect labelling of caviar is widespread
The market survey found several cases of mislabeling:• Eight samples did not have mandatory CITES labels and codes (notincluding any samples from restaurants, where the container withthe label is not expected to be on display); DNA analysis showed thatfive of these were not from sturgeon• Three samples with CITES labels were from sturgeon, but DNA

analyses suggested they were from species or hybrids other thanthose declared on the label• Five samples were mixes from more than one species of sturgeon
though this was not declared on the label

While caviar in trade without CITES labels is certainly illegal, caviar with
CITES labels is probably often seen as per se legal and is therefore often
not further investigated by enforcement officials.
41

Illegal caviar trade in Bulgaria and Romania | 2013

Conclusions and recommendations

A key concern about incorrect labelling from a conservation point of viewis that caviar from wild-caught sturgeon could be “laundered” to appear
legal by labelling it as farmed caviar. DNA testing used in this survey
could not confirm whether specific species were farmed or wild caught sothis survey cannot confirm or disprove this thesis. However, mislabellingof this type is clearly a risk to wild sturgeon. Advances in technology may
help to distinguish between wild-caught and farmed individuals.
The mixing of caviar from different sturgeon species is also an emerging
issue, as confirmed by this research.

4.1.5	Prices vary considerably and do not correlate clearly to source type andauthenticity of caviar
Prices of caviar vary considerably and do not necessarily indicate whether
the caviar is real or fake, wild or farmed. Unlabelled samples that were
explicitly sold as sturgeon caviar but were exceptionally cheap (0.10-0.27
EUR/gram in Bulgaria, 0.30 EUR/gram in Romania) were indeed notfrom sturgeon but from Lumpfish (Cyclopterus lumpus), presumably
sturgeon meat and other material. Allegedly wild caviar in a Romanian
restaurant, however, cost only slightly more than that (0.40 EUR/gram)
and was actually from Beluga Sturgeon (Huso huso), one of the mostexpensive caviars.

4.2 Recommendations
4.2.1 Active enforcement of existing laws is needed
Effective enforcement is a vital prerequisite for a successful fight against
poaching and illegal wildlife trade. Tight inland and border controls –especially at the external frontier of the EU i.e. to Moldova, Ukraine andTurkey – and good national and cross border cooperation are crucial.
According to Knapp (2008)13 only a few EU Member States are paying
special attention to the caviar trade, which can be a potential reason why
there are problems with labels or inconsistencies between information on
permits and labels.
Illegal caviar trade is not only an issue regarding the protection ofendangered species but it may also involve contraband and organizedcrime. Furthermore, it concerns taxation – with lost tax revenues for thecountries – as well as health and veterinary issues. Therefore controls
in this regard should be of high priority for Bulgaria and Romania andthe EU more widely, particularly in areas of market growth such as
aquaculture and online sales.
Illegal caviar trade in Bulgaria and Romania | 201342

Conclusions and recommendations

Consequently, the following specific recommendations are made:• In order to improve inter-agency coordination at the national level,

national authorities responsible for the control of trade in wildlife
and fisheries – including the national CITES Management and/or Scientific Authorities – are recommended to establish formal orinformal groups (where this is not already happening). Such interagency coordination groups should organize regular meetings andcommunicate using electronic and other means inter-sessionally.
The meetings and frequent exchange of information and experience
could help prioritize and focus enforcement effort on areas of key
concern and assist in planning and carrying out joint and coordinated controls, where those are most needed.

• As sturgeon stocks are shared between Romania and Bulgaria,

coordination of enforcement action between these two countries isrecommended in order to maximize effectiveness. This coordination
could take place in the form of regular cross-border meetings andinformation exchange.

• Enforcement agencies, assisted by the CITES Management

Authorities, should share information about caviar and sturgeon
seizures and investigations with their counterparts in implicatedcountries (e.g. countries of origin, transit or destination).

4.2.2 DNA testing can support law enforcement
As the results of this market survey show, random controls using genetic
techniques are necessary to guarantee effective monitoring of caviar
trade. This needs to include caviar containers with CITES labels, as theintegrity of these labels can be flawed.
This was already outlined in a workshop on caviar trade by the LeibnizInstitute for Zoo and Wildlife Research, Berlin, in 200614. The authorsof a caviar survey in the USA also stated that their research results
underscore the value of DNA testing for enforcement of regulations and,if used by inspection officials in real time, can help detect and discourage
illegal harvesting34.
DNA and other investigatory analysis need to be carried out bylaboratories that ensure highest scientific standards and up-to-datetechnology in order to achieve reliable results which would also be valid
in prosecutions. Such methodologies or institutions could be specificallycertified or accredited according to international standards.

34

International Regulation Curbs Illegal Trade of Caviar

http://www.sciencedaily.com/releases/2012/07/120725200043.htm

43

Illegal caviar trade in Bulgaria and Romania | 2013

Conclusions and recommendations

The preparedness of national institutions for carrying out the required
DNA tests should be investigated (including information about cost)
and where the recognized methodologies are available, these should be
utilized in enforcement. If no national institution can carry out the tests,
the possibility of expanding their profile for these should be explored.
Samples could also be analysed in other EU Member States, which havethe relevant expertise or resources.
As DNA analysis cannot differentiate wild from farmed caviar, othertechniques, such as the investigation of isotopes or fatty acids, should befurther developed and employed on a larger scale.

4.2.3	Further standardisation of CITES caviar labels
This research supports recommendations from elsewhere (Knapp 2008)13
that enforcement authorities need to pay more attention to checking theauthenticity of labels. Each EU Member State should make sure that any
caviar container on the domestic market is labelled correctly, regardlessif the caviar is produced or processed in their territory or if it is imported.
A compilation of official caviar labels of all EU Member States can beobtained from the European Commission and/or the EU Member Statesconcerned.
Moreover, labelling should be improved and requirements for labels
amended in order to ensure the reliability and effectiveness of labelling.
The provision of certain security elements, which cannot be falsified
easily (e.g. holograms), as well as the production of caviar CITES labels
by CITES Management Authorities or State Printing Companies (asdone e.g. in Hungary) could help reduce cases of falsified labels. In
addition, a compulsory design of CITES labels could facilitate controls for
enforcement officials, as currently there is felt to be too much diversity inlabel layouts.

4.2.4 Information regarding aquaculture operations needs to be more carefullycollected
Available data on aquaculture production do not appear very reliable
and are subject to considerable variation. Law enforcement agencies
and CITES Management Authorities need to ensure that the produced
volumes of caviar correspond with the age, number and species ofsturgeons in the respective farms and if the caviar sold as “captive-bred”
is actually from a female of which both parents were already born incaptivity, as defined by CITES. Therefore, it is recommended that therelevant authorities collect such information regularly (for instanceannually) and share these with the relevant enforcement agencies whoshould look to prosecute any farms breaking the law.
Illegal caviar trade in Bulgaria and Romania | 201344

Conclusions and recommendations

The discrepancies regarding companies listed in the official CITES
register should also be clarified. It should be ensured that all caviarproducing aquaculture companies are licensed by the national
Management Authorities, as defined in Article 66, paragraph 7, ofRegulation (EC) No 865/2006, amended by Regulation (EC) No.
100/2008, and that all companies exporting caviar are registered as suchwith CITES.
With the ban in place both in Romania and in Bulgaria, at present only
sturgeon breeding facilities are allowed to take Danube sturgeons fromthe wild in order to enhance their broodstock. Therefore, it is extremely
important that the relevant enforcement agencies implement strict
controls and close monitoring to ensure that wild sturgeons taken
for reproduction are caught and kept under ideal conditions to avoid
mortalities and that all fish are released again as soon as possible.

© WWF/Jutta Jahrl

45

Illegal caviar trade in Bulgaria and Romania | 2013

5. Appendix
5.1 Map of Romania
Source: http://europa.eu/abc/maps/members/romania_de.htm

Illegal caviar trade in Bulgaria and Romania | 201346

5.2 Map of Bulgaria
Source: http://europa.eu/abc/maps/members/bulgaria_de.htm

47

Illegal caviar trade in Bulgaria and Romania | 2013

5.3	Sturgeon species codes
CITES
species code

Scientific nameEnglish name

BAE

Acipenser baerii

Siberian sturgeon

BAI

Acipenser baerii baicalensis

Baikal sturgeon

BVI

Acipenser brevirostrum

Shortnose Sturgeon

DAB

Acipenser dabryanus

Yangtze Sturgeon

FUL

Acipenser fulvescens

Lake Sturgeon

GUE

Acipenser gueldenstaedtii

Russian Sturgeon

MED

Acipenser medirostrisGreen Sturgeon

MIK

Acipenser mikadoi

Sakhalin Sturgeon

NAC

Acipenser naccarii

Adriatic Sturgeon

NUD

Acipenser nudiventris

Ship Sturgeon

OXY

Acipenser oxyrhynchus

Atlantic Sturgeon

DES

Acipenser oxyrhynchus desotoi

Gulf Sturgeon

PER

Acipenser persicus

Persian Sturgeon

RUT

Acipenser ruthenus

Sterlet

SCH

Acipenser schrenckii

Amur Sturgeon

SIN

Acipenser sinensis

Chinese Sturgeon

STE

Acipenser stellatus

Stellate Sturgeon

STU

Acipenser sturio

European Sturgeon

TRA

Acipenser transmontanus

White Sturgeon

DAU

Huso dauricus

Kaluga Sturgeon

HUS

Huso huso

Beluga Sturgeon

SPA

Polyodon spathulaAmerican Paddlefish

GLA

Psephurus gladius

Chinese Paddlefish

FED

Syr-darya Shovelnose Sturgeon

ALB

Pseudoscaphirhynchus
fedtschenkoi
Pseudoscaphirhynchus
hermanni
Pseudoscaphirhynchus
kaufmanni
Scaphirhynchus albus

PLA

Scaphirhynchus platorynchus

Shovelnose Sturgeon

SUS

Scaphirhynchus suttkusi

Alabama Sturgeon

HER
KAU

Small Amu-dar Shovelnose or
Dwarf Sturgeon
Large Amu-dar or
False Shovelnose Sturgeon
Pallid Sturgeon

MIX

Mixed species (for “pressed” caviar exclusively)

YYYxXXX

Hybrid specimens: code for the speciesof the male x code for the species of the female
Illegal caviar trade in Bulgaria and Romania | 201348

5.4	Specimens of licensed CITES caviar labels – Bulgaria
Agamemnon I:© CITES Management Authority Bulgaria

BELUGA Inc Vidin:© CITES Management Authority
Bulgaria© CITES Management Authority
Bulgaria

Illegal caviar trade in Bulgaria and Romania | 201349

© CITES Management Authority Bulgaria© CITES Management Authority Bulgaria

Parpen Chobanov Ltd.:5.5	Specimens of licensed CITES caviar labels – Romania
Aquarom Elite Distribution:© CITES Management Authority Romania

Delta Fish Distribution:© CITES Management Authority Romania

Illegal caviar trade in Bulgaria and Romania | 201350

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