Trade in Sturgeon Caviar in Bulgaria and Romania
overview of reported trade in caviar, 1998-2008
May 2011
Katalin Kecse-Nagy

Report prepared by TRAFFIC Europe –Central Eastern, Budapest, Hungary
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Trade in Sturgeon Caviar in Bulgaria and Romania overview of reported trade in caviar, 1998-2008. A
TRAFFIC report for WWF Austria, Budapest,
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ISBN: 978 2 930490 14 4
EAN: 9782930490144
Cover photo:© Emma Duncan / WWF-Canon

CONTENTS
1)

Acknowledgements ................................................................................................................ 1

2)

Introduction ........................................................................................................................... 1

3)

Methodology .......................................................................................................................... 2
Legal trade ........................................................................................................................................................... 2
Illegal trade .......................................................................................................................................................... 2

4)

Legal trade from Bulgaria and Romania ............................................................................... 3
Export quotas ..................................................................................................................................................... 3
History of SRG opinions .................................................................................................................................. 4
Trade patterns in legal caviar for the years 1998 to 2008 ............................................................................. 4
Direct exports of caviar (all sources) .......................................................................................................... 4
Exports of caviar of wild origin................................................................................................................... 7
Exports of farmed caviar .............................................................................................................................. 8
Importing countries of caviar from Bulgaria and Romania .................................................................... 9Re-exports of caviar through Bulgaria and Romania ............................................................................. 10
Imports to Bulgaria and Romania ............................................................................................................. 10
Trade in other sturgeon products.............................................................................................................. 10

5)

Illegal trade implicating Bulgaria and Romania and overview of seizures ......................... 11
Seizures of illegal caviar implicating Bulgaria ............................................................................................... 11
Seizures of illegal caviar implicating Romania ............................................................................................. 12
EU context ........................................................................................................................................................ 12

6)

Summary and conclusions .................................................................................................... 12

7)

References ............................................................................................................................. 14

ANNEX A .................................................................................................................................... 15
ANNEX B .................................................................................................................................... 16
ANNEX C .................................................................................................................................... 17

1) Acknowledgements
TRAFFIC gratefully acknowledges the financial support kindly provided by the Mohamed bin Zayed
Species Conservation Fund and WWF Austria for the production of this briefing. The author would
also like to thank the reviewers of this briefing, who provided useful advice and comments: Jutta Jahrl(WWF Austria) and colleagues from TRAFFIC: Stephanie von Meibom, Richard Thomas and Sabri
Zain.
2) Introduction
The aim of this briefing is to provide an overview of legal trade patterns of caviar of Acipenseriformes
from Bulgaria and Romania (hereafter referred to as the ‘two target countries’) for the period 1998 to2008 and to gather information of detected cases of illegal trade in sturgeon caviar where these twocountries were implicated.
In response to reported declines in sturgeon populations and with the aim of ensuring that trade insturgeon products, such as caviar, is sustainable and not threatening the species’ survival, all species ofsturgeon and paddlefish have been listed in Appendix II of the Convention on International Trade inEndangered Species of Wild Fauna and Flora (CITES) since April 1998. Accordingly, in April 1998, theorder was also listed in Annex B of the EU Wildlife Trade Regulations1 (EU Regulations) implementing
CITES in the European Union (EU). The Annex B/Appendix II listing regulates trade in all parts andderivatives, including caviar, meat, etc. Fishing and export of sturgeon and sturgeon products of wild
origin was banned in Romania in 2006 for 10 years.

Caviar trade in a global context
In an overview of global caviar trade for the period 1998 to 2006, TRAFFIC reported that legal
international trade amounted to 1313 t; with Romania ranking as the world’s fifth largest caviar
exporter, exporting 26 tonnes (t) over the period, after Iran (438 t), the Russian Federation (138 t),
Kazakhstan (95 t), Azerbaijan (35 t) and China (29 t) (TRAFFIC, 2009). The EU was reported to be theworld’s largest importer of caviar for the period 1998-2006, importing 619 t, followed by the USA (292t), Switzerland (149 t) and Japan (132 t) (TRAFFIC, 2009). During the same period, the volumes ofcaviar reported in international trade per year plummeted from a peak at 263 tonnes (t) in 1999 to 44 t
in 2006.
Regarding illegal trade in caviar, it is difficult to quantify its levels, as this is by nature a hidden activity.
However, large seizures of illegal caviar in Europe indicate that there is a thriving black market in theluxury roe. They also demonstrate that caviar smugglers are well-organized and use sophisticatedmethods and the illegal caviar trade is considered to have strong links with organized crime groups.
According to data reported to EU-TWIX, over 7 t of illegal caviar were seized by European authorities
from 2000 to 2007 (TRAFFIC, 2009). However, the real size of the illegal trade is likely to beconsiderably higher, given that much of it is undetected and information is incomplete for some
importing countries.

1 Council Regulation (EC) No. 338/97 on the protection of species of wild fauna and flora by regulating trade therein

Trade in Sturgeon Caviar in Bulgaria and Romania13) Methodology
Legal trade
CITES trade data (data provided by CITES Parties in their annual reports) were used to analyse
reported international trade in caviar. This briefing uses trade data for the years 1998 to 2008 (as 2008
was the most recent year for which comprehensive data were available at the time of writing). The data
were downloaded from the CITES Trade Database (http://www.unep-wcmc.org/citestrade/
trade.cfm), managed by UNEP-WCMC on behalf of the CITES Secretariat, in August 2010. For the
purpose of this report, comparative tabulations, which compare the imports and exports reported byindividual CITES Parties, were used.
The analysis looked at data at the order level (Acipenseriformes spp.) unless specified otherwise.
Although the trade records should be reported identically by the importer and the exporter, in practicethese often differ due to differences in reporting between the importing and exporting country. These
discrepancies in reporting explain why the totals according to importers and exporters do not match in
Table 3.
When exports are referred to, this includes direct exports from a country only and does not include reexports (indirect trade).
The analysis focused exclusively on trade in caviar (eggs) and thus excluded other commodity types
such as live specimens, sturgeon meat, live eggs or bodies from the analysis. Equally, specimens
reported in cartons (crt) were also excluded from the analysis. All CITES trade descriptions and totals
include all purposes (e.g. commercial, personal, etc.) and sources (e.g. wild, farmed, etc.) unlessspecified otherwise for data from 1998 to 2008. Data reported in grams were converted to kilograms
and included in the analysis.
As the data reported by exporters and importers were largely the same (see Table 3), the analysis
mainly used data reported by the exporters. Where discrepancies between the two datasets wereapparent, both were analysed.
Illegal trade
Information on detected cases of illegal trade in caviar implicating Bulgaria and Romania was gatheredfrom selected Member States of the European Union (henceforth EU Member States): Austria,
Belgium, Bulgaria, France, Germany, Hungary, Italy, the Netherlands, Romania and the UK. Seizures
information was downloaded from the EU-TWIX2 database in July 2010, following approval by therelevant EU Member States and in the case of Italy, information on seizures was provided by
TRAFFIC Italy (Massimiliano Rocco). Data were also collected through contacts with individual EU
Member States. Seizures made in a total of 10 countries were gathered. Of these four (Belgium,
Bulgaria, Romania and the UK) reported that no caviar seizures were made from 2000 to 2009
involving the two target countries and thus the compilation used information as reported by six EU
Member States: Austria, France, Germany, Hungary, Italy and the Netherlands. The timeframe 2000 to2009 was selected for investigation because most of the data used originated from EU-TWIX, whichholds data from 2000 only.
CITES trade data reported using the source code "I" (namely, confiscated or seized specimens) were
not analyzed in this section of the briefing as the interpretation and use of this code by the different
countries often shows inconsistencies (i.e. different countries use it for different purposes; some forreporting seizures, others for reporting exports of seized specimens).

2 The EU-TWIX (EU-Trade in Wildlife Information eXchange) database, maintained by TRAFFIC, gathers seizures datafrom European enforcement agencies and as of July 2010, held over 31 000 seizures data from 26 European countries,
covering the period 2000-2010.
Trade in Sturgeon Caviar in Bulgaria and Romania24) Legal trade from Bulgaria and Romania
Export quotas
CITES Resolution Conf. 12.7 (Rev. CoP14) Conservation of and trade in sturgeons and paddlefish recommends
that all sturgeon range States of shared stocks should establish scientifically-based annual catch andexport quotas for each sturgeon species and product and communicate these to the CITES Secretariat.
These recommendations do not apply to specimens from aquaculture or from stocks found only in one
country. Countries of the region (Bulgaria, Romania, Serbia and Ukraine) have regularly coordinatedand jointly set CITES export quotas for wild-taken Danube sturgeons since 2001 through meetings
held in 2001, 2003, 2006 and more recently in 2011 (Anon, 2011a).
Table 1 summarizes the export quotas published for caviar of wild origin from Bulgaria and Romania
for 2001 to 2010, the period for which information was available on the CITES website in August
2010. The export quotas for wild-taken species were gradually decreased for all species (for which a
quota was published) in both target countries through the period examined, going down to zero in 2006
in Romania for all species as well as in Bulgaria in 2007. The highest quotas for wild species were set
for the most expensive beluga caviar (from Beluga Huso huso) in both countries. For 2011, the quotas
communicated to the CITES Secretariat were zero for all wild-taken species in both countries.
Although the setting of export quotas for caviar from aquaculture is voluntary for CITES Parties, bothtarget countries also set export quotas for farmed caviar in the period examined and communicate theseto the CITES Secretariat. Bulgaria published quotas for farmed caviar in 2006 and 2007, while Romania
did so in 2007, 2009 and 2010.
Table 1. Published export quotas for caviar of wild origin from Bulgaria and Romania, 20012010 (in kg)
Bulgaria
A. baerii
A. gueldenstaedtii
A. naccari
A. nudiventris
A. ruthenus
A. stellatus
Huso huso
hybrids
Romania
A. baerii
A. gueldenstaedtii
A. nudiventris
A. ruthenus
A. stellatus
Huso huso

2001
wild
NR
50
NR
NP
NP
NP
5 000
NR

2002
wild
NR
20
NR
NP
NP
NP
1 720
NR

2003
wild
NR
20
NR
NP
NP
NP
1 720
NR

2004
wild
NR
NP
NR
NP
NP
NP
1 720
NR

2005
wild
NR
NR
NP
NP
1 460
NR

NR
1 750
NP
NP
2 050
3 100

NR
1 200
NP
NP
1 470
2 180

NR
900
NP
NP
1 100
2 250

NR
160
NP
100
900
2 250

NR
160
100
900
2 000

2006
wild farmed
NR
450
2400
NR
NP
NP
150
450
1 000
300
NR
550
NR
-

NP
NP
NP
NP
NP
NP

2007
wild farmed
NR
500
3880
NR
100
NP
NP
100
NP
NP
NP
350
NR
500
NR
NP

NP
NP
NP
NP
30
NP

2008
wild
NR
NR
NR
NR
-

2009
wild farmed
NR
NP
NP
NR
NP
NP
NP
NP
NP
NR
NP
NR
-

70
20*
130
-

2010
wild
farmed
NR
NP
NP
NR
NP
NP
NP
NP
NP
NR
NP
NR
-

100
NP
10
10
30

Source: CITES website (www.cites.org), August 2010.
Abbreviations: A. – Acipenser, NP – not published (by the CITES Secretariat, in practice it equals a zero export quota), zero quota (set by the range State), NR – not relevant (for species that are not native to the Danube)
Note: the list of names of all species names mentioned in this briefing can be found in Annex A;
Information on quotas for farmed caviar was only included for the years when a quota was set.

Trade in Sturgeon Caviar in Bulgaria and Romania

3

History of SRG opinions
Prior to Bulgaria’s and Romania’s accession to the EU in 2007, the Scientific Review Group (SRG)
formed a positive opinion3 for Beluga from Bulgaria. The details of the history of the SRG opinions
can be found in Table 2. No SRG opinion related to sturgeons from Romania was recorded in the EU
Wildlife Trade Regulation database of UNEP-WCMC (http://www.unep-wcmc.org/eu/taxonomy/
viewed 19 August 2010).
Table 2. History of SRG opinions concerning imports of Acipenseriformes spp. from
Bulgaria into the EU
DateSpecies
SRG opinion
10 September 1998 Huso huso
Negative
22 April 1999
Huso huso
Positive
1 January 2007
Huso huso positive removed due to accession to the EU
Source: EU Wildlife Trade Regulation database, UNEP-WCMC, Cambridge, UK (viewed 19 August 2010).

As of August 2010, the CITES ‘Register of licensed exporters and of processing and repackaging plants
for specimens of sturgeon and paddlefish species’ (www.cites.org) lists four processing/repackaging
plants in Bulgaria, one of which is also registered as an exporter. It also lists 14 exporters in Romania,of which 12 are also registered as processing/repackaging plants.
Trade patterns in legal caviar for the years 1998 to 2008
This section aims to provide an overview of trade patterns in caviar from Bulgaria and Romania in the
period 1998 to 2008.

Direct exports of caviar (all sources)
Table 3 provides an overview of the volume of trade in caviar (all sources, including wild, farmed, etc.)from Bulgaria and Romania with a total of over 46 000 kg (exporters’ reports) of caviar exported fromthe two countries during 1998-2008. Importers’ reports show a somewhat smaller amount (over 41 000
kg in total) for the same period. The data indicate that in the period examined Romania was the bigger
exporter of the two countries with a total of over 26 000 kg (exporters’ reports) while Bulgaria reported
a total of over 20 000 kg (exporters’ reports) for the same period.

3 The EU Scientific Review Group (SRG) that consists of representatives of each Member States’ Scientific Authority canform opinions on whether or not imports of certain species from a particular country of origin comply with the conditions
set out in the EU Wildlife Trade Regulation. If the SRG determines that these conditions are met, a positive opinion isformed and import into the EU can take place. Otherwise, the SRG can form a negative opinion. In this case, imports ofthe species from the country under consideration are temporarily suspended and EU Management Authorities will reject all
EU import permit applications for the relevant species-country combination. As soon as a negative opinion has been
formed, a Member State or the European Commission informs and consults with the range State involved. Negative
opinions are of a temporary nature and may be lifted immediately when new information on the trade or conservation statusof the species in the country of concern is provided (anon, 2010b).

Trade in Sturgeon Caviar in Bulgaria and Romania

4

Table 3. Overview of direct exports of caviar from Bulgaria and Romania, allsources, 1998 to 2008 (based on exporters’ and on importers’ reports)
Exporter
BG imp r
BG exp r
RO imp r
RO exp r
Total imp r
Total exp r

1998
1 717
2 392
1 265
1 588
2 982
3 980

1999
1 768
2 025
4 301
4 590
6 069
6 616

2000
2 131
2 788
6 566
6 751
8 697
9 539

2001
1 303
992
3 734
3 645
5 037
4 636

2002
2 046
2 437
3 282
3 902
5 328
6 338

2003
1 403
1 588
2 291
2 773
3 695
4 361

2004
1 149
1 092
1 684
2 004
2 833
3 096

2005
2 854
2 803
938
1 099
3 792
3 901

2006
2 904
3 726
0
0
2 904
3 726

2007
109
250
2
0
111
250

2008
366
324
0
0
366
324

Total
17 75020 41724 06326 35041 81446 767

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: BG – Bulgaria, RO – Romania, imp r – importers’ reports, exp r – exporters’ reports

Figure 1 shows that direct exports of caviar from the two range States reached the highest amount in2000 in Romania with over 6700 kg and in 2006 in Bulgaria with over 3700 kg. In Romania thereported amounts of caviar gradually decreased after the peak in 2000, going down to zero in 2006, thestart of the sturgeon fishing and export ban in that country. Bulgaria’s exports fluctuated between 1000
and 2803 kg per year between 1998 and 2005 and peaked in 2006. Although the CITES data indicate asharp decline in 2007 and 2008 for caviar exports from Bulgaria, this does not necessarily indicate adeclining trend. Both Bulgaria and Romania acceded to the EU in January 2007 and since then, caviar
shipments to EU Member States have not been recorded in the CITES trade data. Therefore, caviar
trade from Bulgaria and Romania to other EU Member States as of January 2007 was no longer
reported as direct exports in the CITES trade data.
Figure 1

8 000,0
7 000,0
6 000,0
5 000,0
4 000,0
3 000,0
2 000,0
1 000,00,0BG exp r

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

RO exp r

1998

quantity (kg)Direct exports of caviar from Bulgaria andRomania (all sources), exporters' reports, 19982008

year

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: BG – Bulgaria, RO – Romania, exp r – exporters’ reports

Table 4 provides an overview of the species exported as caviar (all sources) from Bulgaria andRomania between 1998 and 2008. In both countries, the species exported in the largest amounts was
Beluga Huso huso with approximately 15 000 kg exported from each of Bulgaria and Romania in the
period examined. This amount represents over 76% of total caviar exports from Bulgaria and over 56%
of total caviar exports from Romania in this period. In Bulgaria, caviar from Russian Sturgeon Acipenser
gueldenstaedtii was the second most common species in trade with over 3700 kg (18% of total caviar
exports) between 1998-2008 and Stellate Sturgeon A. stellatus as third with approx. 600 kg (3% of total
caviar exports) in the same period. Other species reported by Bulgaria in trade were Siberian Sturgeon
A. baerii and Sterlet A. ruthenus as well as a hybrid. In Romania, caviar from Stellate Sturgeon was thesecond most common species in trade with over 6700 kg (26% of total caviar exports) in 1998-2008
and Russian Sturgeon came as third with approx. 4500 kg (17% of total caviar exports) in the same
period.
Trade in Sturgeon Caviar in Bulgaria and Romania

5

Table 4. Overview of species exported as caviar from Bulgaria and Romania, all sources, exporters’ reports, 1998 to 2008
Exporter
Taxon
1998
1999
2000
2001
2002
BG
991.6 2 327.8
Huso huso
2 392.0 2 025.4 2 747.5
25.4
109.0
A. gueldenstaedtii
A. stellatus
A. gueldenstaedtii x baerii
A. baerii
A. ruthenus
14.8
BG Total
2 392,0 2 025.4 2 787.7
991.6 2 436.8
RO
Huso huso
872.9 1 757.5 3 200.0 1 788.6 2 381.6
A. stellatus
325.8 1 709.9 2 117.3 1 146.9
933.5
A. gueldenstaedtii
389.2 1 123.1 1 433.7
709.1
586.5
RO Total
1 587,9 4 590.4 6 751.1 3 644.5 3 901.6
Grand Total
3 979,9 6 615.8 9 538.8 4 636.1 6 338.4
Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: A. – Acipenser, BG – Bulgaria, RO – Romania
Note: the list of names of all species names mentioned in this briefing can be found in Annex A

Trade in Sturgeon Caviar in Bulgaria and Romania

2003
1 548.4
40.0
1 588.4
2 169.5351.1
252.0
2 772.6
4 361.0

2004
960.4
132.0
1 092.4
1 785.7
138.0
80.1
2 003.8
3 096.1

6

2005
1 534.1
938.3
119.1
60.0
151.0
2 802.6
1 035.4
56.0
7.2
1 098.6
3 901.1

2006
1 048.3
2 038.6
403.4
236.1
3 726.3
3 726.3

2007

2008

219.5
30.0
249.5
249.5

216.5
36.0
71.7
324.2
324.2

Total
15 575.4
3 719.3
588.5
367.8
151.0
14.8
20 416.8
14 991.1
6 778.5
4 580.8
26 350.4
46 767.1

Exports of caviar of wild origin
Regarding the source of caviar exported by Bulgaria and Romania, Table 5 provides an overview ofexports of caviar of wild origin compared to caviar from all sources. These show that Romania exported
only wild caviar between 1998 and 2008 with a peak in 2000 with 6750 kg (exporters’ reports) and thengradually decreased to about 1100 kg in 2005 and to zero in 2006. In Bulgaria the export figures ofwild/all sources caviar were almost identical (fluctuating around 1000-2000 kg per year) during theperiod 1998 to 2004. From 2005, the amounts of wild caviar exports decreased to approx. 660 kg in
2006, while exports of caviar from all sources increased to a maximum in 2006 with 3726 kg. With
Bulgaria’s accession to the EU in 2007, intra-EU trade no longer appears in the CITES records and theamounts of caviar shipments to the EU are unknown. Therefore, CITES data for exports of caviar fromall sources from 2007 indicating a sharp decline may be misleading as trade to other EU countries could
have continued after 2007 without being recorded in the CITES data.
Table 5. Comparison of direct exports of caviar of wild origin and of caviar from all
sources from Bulgaria and Romania, 1998-2008, exporters’ reports
Exporter Source
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Total
BG
all sources 2 392 2 025 2 788
992 2 437 1 588 1 092 2 803 3 726
250
324 20 417
BGwild
2 392 2 025 2 788
992 2 337 1 563
920 1 421
667
0
0 15 104
BG
farmed
0
0
0
0
100
25
173 1382 3060
250
324 5 313RO
all sources 1 588 4 590 6 751 3 645 3 902 2 773 2 004 1 099
00
0 26 350
ROwild
1 588 4 590 6 751 3 645 3 902 2 773 2 004 1 099
00
0 26 350
Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: BG – Bulgaria, RO – Romania.

Regarding compliance with export quotas set by Bulgaria and Romania for caviar of wild origin, bothtarget countries complied with the quotas set for the period 2001 to 2008, with the exception of exports
of Beluga in the year 2002, when reported exports were higher than the quota for that year in bothcountries (Figures 2 and 3). This however, may be related to exporting caviar not reported in theprevious quota year. Further details, including information on exports of wild caviar by species and on
quota compliance, can be found in Annex B.
Figure 2

quantity (kg)Compliance with quotas for wild caviar from
Beluga Huso huso, Bulgaria, exporters' reports,
2001-2006
6 000,0
5 000,0
4 000,0
3 000,0
2 000,0
1 000,00,0reported exportsquota

2001 2002 2003 2004 2005 2006year

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK; CITES website(www.cites.org), August 2010.

Trade in Sturgeon Caviar in Bulgaria and Romania

7Figure 3
Compliance with quotas for wild caviar from
Beluga Huso huso , Romania, exporters' reports,
2001-2006

quantity (kg)

4 000,0
3 000,0reported exports

2 000,0quotas

1 000,00,02001 2002 2003 2004 2005 2006year

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK; CITES website(www.cites.org), August 2010.

Exports of farmed caviar
This section looks at exports of farmed caviar reported by the two target countries. For Romania noexports in specimens reported with source code “C” were included in the CITES trade database andaccording to exporters’ reports, the following source codes were used: ‘F’, ‘I’, ‘O’ and ‘W’4; importers’
data only recorded source code ‘W’). Information for Bulgaria is compiled in Table 5.
The absence of recorded exports of farmed caviar (source code ‘C’) from Romania appears to contradict
the fact that export quotas have also been set for farmed caviar by Romania (although for smaller
quantities, see Table 1). It may also seem to be in contrast with the large number of caviar
processing/repackaging plants and exporters (14 and 12 each) listed in the most recent (Aug. 2010)
version of the CITES ‘Register of licensed exporters and of processing and repackaging plants for
specimens of sturgeon and paddlefish species’. However, it must be noted here that Romania has set
export quotas for commodities other than caviar (e.g. fingerlings, larvae, fry, fertilized eggs, etc.) of
farmed origin and which were not examined in this report.
Table 5 and Figure 4 show a rapid increase in the export of farmed caviar from Bulgaria from 2004
with a peak in 2006 (over 3000 kg, according to exporters’ reports). The seeming decline in 2007 (250kg, according to exporters’ reports) is again likely to be related to the country’s EU accession in that year
and thus direct trade destined to EU Member States not being recorded in the CITES trade data.
Exports of “wild” caviar decreased steadily over the years.

4 Source codes: C – animals bred in captivity and their parts and derivatives, F – animals born in captivity and their parts andderivatives, I – confiscated or seized specimen, O – Pre-Convention specimen (here specimen from before the CITES listingin 1998), W – specimen of wild origin.
Trade in Sturgeon Caviar in Bulgaria and Romania

8Figure 4

3 500,0
3 000,02 500,0
2 000,0
1 500,0
1 000,0500,00,0farmed
wild

19
98
19
99
20
00
20
01
20
02
20
03
20
04
20
05
20
06
20
07
20
08

quantity (kg)Direct exports of "wild" and farmed caviar from
Bulgaria, exporters' reports, 1998-2008

year

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.

Importing countries of caviar from Bulgaria and Romania
The US (with over 11 000 kg) was the largest direct importer of caviar from Bulgaria based on exporters’
data (Figure 5) in the years 1998-2008, followed by France and Switzerland (in order of importance).
When imports to EU Member States are added up, the EU stands out as the second most important
importer (with over 6500 kg) after the US. For further details see Annex C, which also illustrates thatimports to the EU significantly increased in 2005-2006, the last two years before Bulgaria’s accession to
the EU.
Figure 5
Importers of caviar from Bulgaria, exporters'
reports, 1998-2008
1%
2%
4% 2%
11%

0%

US

0%

FR
CH
LT
CZ
55%

25%

DE
BE
RO
AE

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: AE – United Arab Emirates, BE – Belgium, CH – Switzerland, CZ – Czech Republic, DE – Germany, FR –France, LT – Lithuania, RO – Romania, US – United States of America

Figure 6 presents the importers of caviar from Romania for the same period, with Germany, the USA
and Japan as the major importers (in order of importance, for detailed information see Annex C). When
imports to EU Member States are considered together, the EU appears as the largest importer of caviar
from Romania with over 13 500 kg in the same period. In the case of Romania however, the trend is
Trade in Sturgeon Caviar in Bulgaria and Romania9different from Bulgaria with exports to the EU peaking in 2000 and then decreasing sharply from 2003
with a small increase in 2005 before the introduction of the fishing and export ban in 2006.
Figure 6
Importers of caviar from Romania, exporters'
reports, 1998-2008

4% 2%

7%

10%

DE
41%

US
JP
BE
GB

36%

others

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: BE – Belgium, DE – Germany, GB – the United Kingdom, JP – Japan, US – United States of America

Re-exports of caviar through Bulgaria and Romania
Re-exports through Bulgaria and Romania were scarce in the period 1998 to 2008, with a total of two reexports reported: one involved 1.5 kg of “wild” sturgeon caviar originating from the Russian Federation
and re-exported by Romania to the USA in 2001; the other involved almost 90 kg of “wild” beluga caviar
originating from Serbia, re-exported by Bulgaria to the USA in 2004.

Imports to Bulgaria and Romania
Caviar was rarely imported directly by the two target countries and only in small quantities. According toexporters’ data, four such imports were made, two by Romania (29.5 kg from Bulgaria and Russia) andtwo by Bulgaria (over 92 kg from Serbia). According to importers’ data, three such imports were madeby Bulgaria and involved a total of about 100 kg of caviar from Russia and Serbia.
Caviar imported to the two target countries through re-exports involved small amounts according toimporters’ data with a total of 10 kg over the period 1998-2008. Countries of origin were Azerbaijan,
France, Iran and Kazakhstan while the re-exporters were Belgium and Germany. According to exporters’
data, caviar imported by the two target countries through re-exports also involved small amounts but
higher than reports by importers’ (a total of 169 kg over the period 1998-2008). The countries of origin
were Azerbaijan, Bulgaria France, Iran, Kazakhstan and Romania; the re-exporters were: Belgium,
France, Germany, Switzerland, the UK and the USA. The re-exports to Romania where the country oforigin was also Romania were reported in 2000 (97.9 kg of caviar from A. stellatus through France) and in
2002 (36 kg Beluga caviar through Germany). One similar case was also reported for Bulgaria in 2000 (16kg Beluga caviar exported by Bulgaria through the USA and then back to Bulgaria).

Trade in other sturgeon products
Although the focus of the present briefing is caviar, it must be noted that international trade in allsturgeon specimens is regulated under CITES. Specimens reported in international trade in 1998-2008
for Bulgaria and Romania also included meat, live eggs, fingerlings, live specimens, bodies, extracts,
derivatives, etc.
Trade in Sturgeon Caviar in Bulgaria and Romania

105) Illegal trade implicating Bulgaria and Romania and overview of seizures
Due to its high price and rarity, the luxury roe is often traded illegally. Tables 6 and 7 provide an
overview of reported seizures of illegal caviar made in selected EU Member States and where Bulgaria
and Romania were implicated for the period 2000-2009. Of the 10 EU Member States contacted, four
(Belgium, Bulgaria, Romania and the UK) reported not detecting any cases of illegal caviar trade
involving Bulgaria and Romania in the period examined. The Romanian Customs however reported two
significant seizures of sturgeon meat in 2005 (I. Surugiu, Romanian Customs, in litt. to K. Kecse-Nagy,
July 2010). In-depth analysis of the seizures was impossible due to the relatively small number ofdetected cases (five for Bulgaria and nine for Romania). It must also be noted that the data presented inthis section are far from being complete and therefore can only provide an indication of illegal caviar
trade concerning these countries.
Seizures of illegal caviar implicating Bulgaria
Table 6 compiles five seizures where Bulgaria is implicated in illegal trade in caviar in 2000-2009. A totalof 27.5 kg of caviar was seized in that period. In all cases Bulgaria was reported to be the country ofdeparture of illegal trade. However, in two cases the seizure of Russian caviar was reported, which may
mean that Bulgaria was a transit country. It is also worth noting that the seizure involving the highest
quantity (over 10 kg) was made in France in 2007, following Bulgaria’s accession to the EU. Eight kg ofcaviar were seized by Dutch authorities in 2009 because the CITES labels on the tins were easily
removable with some having actually been broken or removed, which is against CITES labelling
requirements (CITES Resolution Conf. 12.7 (Rev.CoP14)) as it could allow the addition of illegal caviar
to the tins.
Table 6. Seizures of illegal caviar* reported by selected EU Member States and where
Bulgaria is implicated, 2000-2009
Reporting Country ofcountry
departure

TransitcountryCountry of Country of
Direction
destination
origin1,11 kg

Austria

Bulgaria

NA

Austria

Unknown

Import2002

7,12 kg

Austria

Bulgaria

NA

Austria

Unknown

Import2002

0,31 kg

Italy

Bulgaria

NR

NR

Unknown

ImportTransport/
Source Purpose
Remarks
Concealment
Personal
baggageU
NA
Russian caviar
Road,
Land border Nickelsdorf
U
NA
Russian caviar
Acipenser
gueldenstaedtii
Airport,VeronaUnknown
W
P
Russian Sturgeon

2007 10,96 kg

FranceBulgaria

NR

NR

Bulgaria

ImportLand border, Personal
Beinheimbaggage

U

NA

2009

Netherlands Bulgaria

NA

NA

NA

ImportAirport

W

NA

Date

Mass

2001

Unit

8,00 kgType oflocation
Airport,ViennaNA

NA
Huso huso Beluga,
easily removablelabels, somebrokenSource: EU-TWIX database, Austrian Customs and CITES Management Authority, and Massimiliano Rocco, TRAFFIC, in litt to K. Kecse-Nagy, Aug 2010
Abbreviations: NA - not availbale, NR - not relevant, P - personal, U - unknown, W - wild taken* Acipenseriformes spp. unless specified further under remarks

In addition to the cases listed in Table 6, the German authorities also reported an ongoing investigation,in which Bulgaria was implicated. A witness in an organised crime investigation conducted by the
Cologne Customs Investigation Office claimed that Russian caviar was smuggled into the EU, where it
was subsequently commercialized as Bulgarian farmed caviar. This claim has been investigated by theGerman authorities using innovative techniques, such as isotope analysis. Some of the samples taken in2009 appeared to support the claim and found caviar labelled as originating from Bulgarian aquaculture
operations to originate actually from the Caspian Sea (T. Tietz, German Customs, in litt. to K. KecseNagy, August 2010).

Trade in Sturgeon Caviar in Bulgaria and Romania

11

Seizures of illegal caviar implicating Romania
Table 7 compiles nine cases of caviar seizures where Romania is implicated in illegal trade in caviar in
the period 2000-2009. A total of 25 kg of caviar was seized during this period. In eight of the nine cases
Romania was the country of departure of illegal trade and only in one case did the illegal caviar transit
through Romania with Moldova as country of departure and Hungary as the country of destination. It is
worth noting that the seizure involving the highest amount (over 11 kg) was made in Hungary in 2006 in
transit from Romania to Austria. It is also notable that Italy reported the largest number of cases, a totalof over 9 kg of caviar was seized in five seizures, all detected at Verona Airport in personal baggage.
Table 7. Seizures of illegal caviar* reported by selected EU Member States and where
Romania is implicated, 2000-2009
Reporting Country of Transit
country
departure country

Country of Country
Direction
destination of origin

0,79 kg

Germany

RomaniaNR

Germany

Unknown Import

2,04
0,34
1,21
2,67
2,74
0,56

kg
kg
kg
kg
kg
kg

Italy
Germany
Italy
Italy
Italy
Italy

Romania
Romania
Romania
Romania
Romania
Romania

NR
NR
NR
NR
NR
NR

Italy
Germany
Italy
Italy
Italy
Italy

Unknown Import
Unknown Import
Romania Import
Romania Import
Romania Import
Romania Import

2006 11,05 kg

Hungary

Romania

Hungary

Austria

Unknown Transit

2006

Hungary

Moldova

Romania Hungary

Unknown Import

Date

Mass

2000
2000
2001
2004
2004
2004
2006

Unit

3,84 kgType of location
Airport, Frankfurt
Airport, Verona/
Villafranca
Airport, München
Airport, Verona
Airport, Verona
Airport, Verona
Airport, Verona
Border post in free
trade zone, Gyır
Border post in free
trade zone, Nagylak

Concealment/
transport

SourcePurposeU

NA

Personal baggage U
Unknown
U
Personal baggage U
Personal baggage U
Personal baggage U
Personal baggage U

NA
NA
NA
NA
NA
NA

Inside vehicle

U

NA

Inside vehicle

U

NA

Unknown

Source : EU-TWIX database, Austrian Customs and CITES Management Authority, and Massimiliano Rocco, TRAFFIC, in litt to K. Kecse-Nagy, Aug 2010
Abbreviations: NA - not availbale, NR - not relevant, U - unknown* Acipenseriformes spp.

In summary, it is of concern that the two target countries reported no seizures of caviar, while other EU
Member States reported several seizures where Bulgaria and Romania were implicated. Noting that thereal volume of illegal trade involving these countries is likely to be considerably higher than shown by thedetected cases, it is advisable to increase awareness of enforcement agencies, their capacity and efforts todetect illegal caviar trade in the two target countries.
EU context
According to data reported to EU-TWIX up to 2009, over 7 t of illegal caviar were seized by European
authorities from 2000 to 2007 (TRAFFIC, 2009). However, the real size of the illegal trade is likely to beconsiderably higher, given that much of it is undetected and information is incomplete for some
importing countries.
6) Summary and conclusions
The present analysis focused on trade in caviar from Bulgaria and Romania. The analysis of legal trade
showed that direct exports of caviar from the two range States peaked in 2000 in Romania with over
6700 kg and in 2006 in Bulgaria with over 3700 kg. In Romania the reported amounts of caviar gradually
decreased after the peak in 2000, going down to zero in 2006, the start of the sturgeon fishing and exportban in that country. Bulgaria’s exports fluctuated between 1000 and 2500 kg per year between 1998 and2005 and peaked in 2006. Following the countries’ accession to the EU in January 2007 caviar exported
to other EU Member States have no longer been recorded in the CITES trade data.
Regarding the species in trade, both countries exported the most of the expensive beluga caviar; Bulgaria
over 15 000 kg between 1998 and 2008 representing over 76% of total caviar exports from that country;
Romania with almost 15 000 kg representing over 56% of total caviar exports in the same period.
The analysis demonstrated that Romania reported exporting practically only caviar of wild origin
between 1998 and 2008, with a peak in 2000 with 6750 kg (exporters’ reports) and then gradually
decreasing to about 1100 kg in 2005 and to zero from 2006 following the country’s fishing ban. In
Trade in Sturgeon Caviar in Bulgaria and Romania

12Bulgaria, the export figures of wild/all sources caviar were almost identical (fluctuating around 10002000 kg per year) during the period 1998 to 2004. From 2005, the amounts of wild caviar exports also
decreased in that country to approx. 660 kg in 2006. Exports of caviar from all sources increased to a
maximum in 2006 with 3726 kg (according to exporters’ figures) due to the export of farmed caviar.
From 2007, the year for Bulgaria’s accession to the EU, intra-EU trade does not appear in the CITES
data therefore, for the period 2007-2008 trends cannot be identified.
Nevertheless, it appears that the Bulgarian aquaculture industry adapted fairly quickly to the decreasing
quotas set for the export of “wild” caviar and managed to produce and export even more than the
maximum “wild” caviar exports in the early 2000s. Although this quick adaptation of the aquacultureindustry is quite possible, further investigation would be required to exclude any possibility of launderingcaviar of wild origin (whether from the Danube or elsewhere) via aquaculture operations or to establish
whether fraudulent labelling could be occuring. Such investigations should focus on, among others,
national regulations on aquaculture operations and their enforcement, feasibility of obtaining mature
specimens in a short time span, checking records of production at aquaculture facilities, DNA analysis ofcaviar samples, etc.
The major direct importers of caviar from Bulgaria in the years 1998-2008 were the USA (with over
11 000 kg, exporters’ data), France and Switzerland (in order of importance). When imports to EU
Member States were added up, the EU came in as the second most important importer (with over 6500
kg, exporters’ data) after the US. Imports to the EU from that range State significantly increased in 20052006, the last two years before Bulgaria’s accession to the EU. As for the importers of caviar from
Romania for the same period, Germany, the US and Japan were reported to be the major players (inorder of importance, based on exporters’ reports). When imports to EU Member States were considered
together, the EU appeared as the largest importer. In the case of Romania however, the trend is different
from Bulgaria with exports to the EU peaking in 2000 and then decreasing sharply from 2003 with asmall increase in 2005 before the introduction of the fishing and export ban.
Regarding illegal trade, a total of 14 caviar seizures implicating Bulgaria (27.5 kg in five seizures) andRomania (25 kg in nine seizures) were reported to the EU-TWIX database between 2000 and 2009. In
addition to the seizures in EU-TWIX, the German authorities also reported about an ongoinginvestigation, in which a witness claimed that caviar of Russian origin was smuggled into the EU, where
it was subsequently commercialized as Bulgarian farmed caviar. This claim has been investigated by theGerman authorities using innovative techniques, such as isotope analysis. Some of the samples taken in2009 appeared to prove this claim and found caviar labelled as originating from Bulgarian aquaculture
operations to originate actually from the Caspian Sea (T. Tietz, German Customs, in litt. to K. KecseNagy, August 2010). This finding also supports the need for further investigation of the aquacultureindustry in Bulgaria.
It is also of concern that Bulgaria and Romania reported no seizures of caviar, while other EU Member
States reported several seizures where these two countries were implicated. Noting that the real volumeof illegal trade involving these countries could be considerably higher than shown by the detected cases,
and also the fact that these countries are now within the common market of the EU, without Customs
control, it is therefore recommended that both countries increase the awareness of their control agencies
about the significance of the illegal caviar trade, strengthen their capacity to control and monitor thecaviar trade and increase enforcement efforts in both countries.

Trade in Sturgeon Caviar in Bulgaria and Romania

137) References
Anon. (2010). International and EU Legislation. TRAFFIC Europe – European Commission http://euwildlifetrade.org/pdf/en/1_international_legislation_en.pdf 19 August.
Anon. (2011). Danube Delta National Instuitute, Romania http://ddni.ro/rosturgeons/index.php?option=com_content&task=view&id=137&Itemid=172 15 June
TRAFFIC (2009). Black gold: The caviar trade in western Europe. Fact Sheet.TRAFFIC Europe. Belgium,
Brussels.

Trade in Sturgeon Caviar in Bulgaria and Romania

14

ANNEX A
Scientific and common name of sturgeon species appearing in this briefing
Scientific name
Acipenser baerii
A. gueldenstaedtii
A. naccari
A. nudiventris
A. ruthenus
A. stellatus
Huso huso

Common nameSiberian Sturgeon
Russian Sturgeon
Adriatic Sturgeon
Ship Sturgeon
SterletStellate Strugeon
BelugaTrade in Sturgeon Caviar in Bulgaria and Romania

15

ANNEX B
Quota compliance in Bulgaria and Romania, 2001-2006
2001
Exporter Taxon
BG
A. gueldenstaedtii
H.husoRO

A. gueldenstaedtii
A. stellatus
H. huso

exp r.
reported export
quota
reported export
quota
reported export
quota
reported export
quota
reported export
quota

0
50
992
5 000
709
1 750
1 147
2 050
1 789
3 100

2002
imp r.

exp r.

0
50
1 303
5 000
853
1 750
1 131
2 050
1 749
3 100

9
20
2 328
1 720
587
1 200
934
1 470
2 382
2 180

imp r.
0
20
1 971
1 720
379
1 200
761
1 470
2 130
2 180

2003
exp r.
imp r.
15
13
20
20
1 548
1 363
1 720
1 720
252
165
900
900
351
394
1 100
1 100
2 169
1 732
2 250
2 250

2004
exp r.
0
NP
920
1 720
80
160
138
900
1 786
2 250

2005
imp r.
0
NP
1 009
1 720
60
160
138
900
1 469
2 250

exp r.
0
0
1 421
1 460
7
160
56
900
1 035
2 000

2006
imp r.
25
0
1 587
1 460
7
160
56
900
875
2 000

exp r.
0
0
667
1 000
0
0
0
0
0
0

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK. and quotas fromwww.cites.org (viewed Aug 2010)
Abbreviations: BG – Bulgaria, RO – Romania, exp r. – exporters’ reports, imp r. – importers’ reports

Trade in Sturgeon Caviar in Bulgaria and Romania

16

imp r.
0
0
667
1 000
0
0
0
0
0
0

ANNEX C
Destinations of direct exports of caviar from Bulgaria and Romania, exporters’
reports, 1998-2008
Exporter Importer
BG
US
FR
CH
LT
CZ
DE
BE
RO
AE
BG Total
BG Total to EU
RO
DE
US
JP
BE
GB
FR
CH
IT
DK
GR
NL
MX
HK
CN
SE
ZA
NZ
SG
CA
RO Total
RO Total to EU
Grand Total

1998
650
1 742
2 392
650
5
1 079
498
5
1
1 588
10
3 980

1999
1 117
470
413
25
2 025
470
2 557
697
750
290
22
80
40
68
87
4 590
3 064
6 616

2000
2 668
120
2 788
0
3 214
1 492
1 034
309
120
250
20
115
40
157
6 751
4 225
9 539

2001
980
12
992
0
2 046
382
224
488
128
52
225
71
30
3 645
2 814
4 636

2002
2 217
220
2 437
220
2 010
1 258
62
197
6
62
128
37
82
60
3 902
2 312
6 338

2003
1 563
25
1 588
25
252
2 230
114
34
82
44
10
7
2 773
411
4 361

2004
691
82
135
185
1 092
402
85
1 844
12
48
10
5
2 004
97
3 096

2005
634
1 549
439
156
25
2 803
2 168
480
471
71
43
34
1 099
585
3 901

2006
570
2 175
41
283
457
51
150
3 726
2 658
0
0
3 726

2007
250
250
0
0
0
250

2008
322
2
324
0
0
0
324

Total
11 012
5 171
2 328
856
457
391
175
25
2
20 4176 593
10 650
9 452
2 683
1 099
544
479
432
212
183
161
157
91
82
60
34
20
7
5
1
26 35013 51846 767

Source: CITES trade statistics derived from the CITES Trade Database, UNEP-WCMC, Cambridge, UK.
Abbreviations: AE – United Arab Emirates, BE – Belgium, CA – Canada, CH – Switzerland, CN – China, CZ – Czech
Republic, DE – Germany, DK – Denmark, FR – France, GB – United Kingdom, GR – Greece, HK – Hong Kong (Special
Administrative Region of the People's Republic of China), IT – Italy, JP – Japan, LT – Lithuania, MX – Mexico, NL – The
Netherlands, NZ – New Zealand, RO – Romania, SE – Sweden, SG – Singapore, US – United States of America, ZA – South
Africa, - zero
Data in italics and with grey background indicate data regarding EU Member States.

Trade in Sturgeon Caviar in Bulgaria and Romania

17