COMMISSION STAFF WORKING DOCUMENT EVALUATION of Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing measures for the recovery of the stock of European eel
Date: 2020-02-17
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: authorised catch, catch by species, catch quota, conservation of fish stocks, fishing controls, fishing rights, freshwater fish, protected species, protection of animal life

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.2.2020  SWD(2020) 35 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION of Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing measures for the recovery of the stock of European eel {SWD(2020) 36 final}  
 
 
Table of contents 

1. 

INTRODUCTION ................................................................................................................................ 6 

Purpose and scope ...................................................................................................................................... 6 

2. 

BACKGROUND TO THE INTERVENTION ..................................................................................... 7 

Description of the intervention and its objectives ...................................................................................... 7 

Baseline and points of comparison ........................................................................................................... 10 

3. 

IMPLEMENTATION / STATE OF PLAY ........................................................................................ 11 

3.1. 

3.2. 

Description of the current situation ............................................................................................. 11 

Eel Management Plans and exemptions ...................................................................................... 11 

3.3.  Measures contained in the EMPs ................................................................................................ 12 

3.4. 

Reporting by Member States and the Commission ..................................................................... 14 

Reporting on EMP implementation .......................................................................................................... 14 

Progress reports - 2012 ............................................................................................................................. 14 

2014 Commission report .......................................................................................................................... 16 

Progress reports - 2015 ............................................................................................................................. 16 

Progress reports - 2018 ............................................................................................................................. 16 

Good practices in eel conservation ........................................................................................................... 17 

Reporting on the evolution of market prices for eels < 12 cm ................................................................. 18 

3.5. 

Overall state-of-play of the implementation of the Eel Regulation ............................................. 20 

4.  METHOD............................................................................................................................................ 21 

4.1.  Methodology and data collection ................................................................................................ 21 

4.2. 

4.3. 

Consultation strategy ................................................................................................................... 22 

Timing and robustness of the evaluation ..................................................................................... 23 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS .......................................... 23 

5.1. 

5.2. 

5.2.1. 

5.2.2. 

5.2.3. 

5.2.4. 

5.2.5. 

5.2.6. 

Evaluation Questions Matrix ....................................................................................................... 23 

Analysis and answers .................................................................................................................. 23 

RELEVANCE ......................................................................................................................... 23 

EFFECTIVENESS .................................................................................................................. 25 

SUSTAINABILITY ................................................................................................................ 36 

EFFICIENCY ......................................................................................................................... 37 

COHERENCE ........................................................................................................................ 38 

EU ADDED VALUE .............................................................................................................. 46 

6. 

CONCLUSIONS ................................................................................................................................. 48 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 51 

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 52 

ANNEX 3: METHODS AND ANALYTICAL MODELS .......................................................................... 65 

ANNEX 4: COMMISSION DECISIONS UNDER THE EEL REGULATION .......................................... 81 

ANNEX 5: EMP IMPLEMENTATION ...................................................................................................... 82 

ANNEX 6: EUROPEAN EEL STATUS AND IMPACTS ON THE STOCK ............................................ 94 

1 

 
ANNEX 7 SUMMARY OF THE EU AND INTERNATIONAL LINKAGES APPLICABLE TO 

EUROPEAN EEL ............................................................................................................................. 103 

2 

 
Glossary 

Term or acronym 

Meaning or definition 

B0 
Pristine biomass 

The amount of silver eel biomass that would have existed if no anthropogenic 
influences had impacted the stock 

Bbest 

The amount of silver eel biomass that would have existed if no anthropogenic 
influences had impacted the current stock, hence only natural mortality operating on 
stock, i.e. excluding restocking practices 

Bcurrent 
Current biomass  

The amount of silver eel biomass that currently escapes to the sea to spawn 

CFP 

CITES 

CMS 

DCF 

Common Fisheries Policy 

Convention on International Trade in Endangered Species of Wild Flora and Fauna 

The Convention on the Conservation of Migratory Species of Wild Animals 

Data Collection Framework 

Diadromous fish 

Fish species that migrate between salt water and fresh water as part of their life 
cycle. Catadromous species like eels spend most of their lives in fresh water and 
then migrate to the sea to breed. Anadromous fish, including salmon, live in the sea 
and migrate to fresh water to breed. 

DG MARE 

European Commission Directorate-General for Maritime Affairs and Fisheries 

Commission 

European Commission 

Eel Regulation 

Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing 
measures for the recovery of the stock of European eel 

EFCA 

EFF 

European Fisheries Control Agency  

European Fisheries Fund (for the period 2007-2013) 

EIFAAC 

European Inland Fisheries and Aquaculture Advisory Commission 

Elver 

EMFF 

EMP(s) 

EMU 
Eel Management 
Unit 

Young eel, in its first year following recruitment from the ocean. The elver stage is 
sometimes considered to exclude the glass eel stage, but not by everyone. To avoid 
confusion, pigmented 0+ cohort age eels are included in the glass eel term. 

European Maritime and Fisheries Fund (for the period 2014-2020) 

Eel Management Plan(s)  

“Member States shall identify and define the individual river basins lying within 
their national territory that constitute natural habitats for the European eel (eel river 
basins) which may include maritime waters. If appropriate justification is provided, 
a Member State may designate the whole of its national territory or an existing 
regional administrative unit as one eel river basin. In defining eel river basins, 
Member States shall have the maximum possible regard for the administrative 
arrangements referred to in Article 3 of Directive 2000/60/EC [i.e. River Basin 
Districts of the Water Framework Directive].” EC No. 1100/2007. 

Escapement 

The amount of silver eel that leaves (escapes) a water body, after taking account of 
all natural and anthropogenic losses. 

3 

 
EU 

European Union 

FAME Support Unit  Fisheries and Aquaculture Monitoring and Evaluation Support Unit under the 

European Maritime and Fisheries Fund 

GES 

GFCM 

Glass eel 

Good Environmental Status under the Marine Strategy Framework Directive 

General Fisheries Commission for the Mediterranean  

Young, unpigmented eel, recruiting from the sea into continental waters. Joint 
EIFAAC/ICES/GFCM Working Group on Eels consider the glass eel term to 
include all recruits of the 0+ cohort age. In some cases, however, also includes the 
early pigmented stages. 

ICES 

International Council for the Exploration of the Sea 

ICES Stock Annex 

Stock-specific documentation of the assessment procedures used by ICES for 
European Eel (Anguilla anguilla), last updated September 2016 

IUCN 

IUU 

MS(s) 

MSFD 

MSY 

International Union for the Conservation of Nature 

Illegal, Unreported and Unregulated 

Member State(s) 

Marine Strategy Framework  Directive   

Maximum Sustainable Yield under the CFP 

NDF  
Non-Detriment 
Finding 

The competent scientific authority has advised in writing that the capture or 
collection of the specimens in the wild or their export will not have a harmful effect 
on the conservation status of the species or on the extent of the territory occupied by 
the relevant population of the species. 

PC 

RBD 

RBMP 

SAC 

SCIPs 

Sigma ƩA 

ΣAlim 

Public Consultation 

River Basin District under WFD 

River Basin Management Plan under WFD 

Special Area of Conservation 

Specific Control and Inspection Programmes 

The sum of anthropogenic mortalities, i.e. sigma A = sigma F + sigma H. It refers to 
mortalities summed over the age groups in the stock. 

Limit anthropogenic mortality ΣAlim is set at ΣA=-ln(40%)=0.92, corresponding to 
the 40% biomass limit 

Sigma ƩF 

The fishing mortality rate, summed over the age groups in the stock 

Sigma ƩH 

Silver eel 

Anthropogenic mortality rate outside the fishery, summed over the age groups in the 
stock 

Migratory phase following the yellow eel phase. Eel in this phase are characterized 
by darkened back, silvery belly with a clearly contrasting black lateral line, enlarged 
eyes. Silver eel undertake downstream migration towards the sea, and subsequently 
westwards. This phase mainly occurs in the second half of calendar years, although 
some are observed throughout winter and following spring. 

4 

 
 
SMEFF 

Sustainable Management of the External Fishing Fleets 

SPA 

SRG 

Special Protection Area  

Scientific Review Group 

Stocking/Restocking  Stocking is the practice of adding fish to a waterbody from another source,  

to supplement existing populations or to create a population where none exists. 
Since eels cannot be artificially reproduced, stocking material is always wild caught. 

TAC 

Total Allowable Catch set under the Fishing Opportunities Regulations 

Translocation 

Removal of eels from one place (e.g. the coast of arrival) to another (e.g. river or 
lake) to increase local population numbers. 

VMS 

WFD 

Vessel Monitoring System defined under the Control Regulation 

Water Framework Directive 

WGEEL 

Joint EIFAAC/ICES/GFCM Working Group on Eels 

Yellow eel 

Life-stage resident in continental waters. Often defined as a sedentary phase, but 
migration within and between rivers, and to and from coastal waters occurs and 
therefore includes young pigmented eels (‘elvers’ and bootlace). Sometimes yellow 
eel is also called ‘brown eel’. 

Country code  Country name 

  Country code  Country name 

COUNTRY CODES 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 

Austria 
Belgium 
Bulgaria 
Cyprus 
Czechia / Czech Republic 
Germany 
Denmark 
Estonia 
Greece 
Spain 
Finland 
France 
Croatia 
Hungary 

IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
UK 

Ireland 
Italy 
Lithuania 
Luxembourg 
Latvia 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Sweden 
Slovenia 
Slovakia 
United Kingdom 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

Purpose and scope 

The purpose of this evaluation is to assess the measures established for the protection and 
sustainable use of the stock of European eel  under the Regulation  (EC)  No 1100/20071 
(hereinafter referred to as ‘Eel Regulation’), and the contribution of the Eel Management 
Plans to  the achievement  of the objectives  of this regulation  and to  the recovery  of the 
stock of European eel. 

The European Commission presented a first assessment of the implementation of the Eel 
Management Plans (EMPs) in 20142. The results of this assessment were however largely 
inconclusive due to the delays in the preparation and approval of the national EMPs and 
the delays in the implementation of non-fisheries related measures.  

During  the  December  2017  Council  meeting,  in  the  context  of  the  negotiations  of  the 
Regulation  for  2018  Fishing  opportunities3,  the Commission  and  Member  States  (MSs) 
agreed to step up their efforts to protect the European eel stock4 that according to solid 
scientific advice remains in critical condition. It was agreed that the Commission would 
launch  an  external  evaluation  of  the  Eel  Regulation  to  assess  its  effectiveness  and  its 
contribution  to  the  recovery  of  the  stock  of  European  eel,  with  a  view  to  its  possible 
revision. 

This evaluation covers the entire period since the entry into force of the Eel Regulation in 
September  2007  (while  the  EMPs  are  being  implemented  since  2009)  until  the  second 
quarter  of  2019.  It  examines  the  effectiveness,  efficiency,  relevance,  coherence,  EU 
added-value and sustainability of the measures established under the Eel Regulation. 

The  evaluation  assesses  biological  aspects,  the  management,  implementation  and 
enforcement issues, including trade aspects, as well as the use of the European Maritime 
and Fisheries Fund (EMFF)5 and its predecessor the European Fisheries Fund (EFF)6 for 
the  implementation  of  the  Eel  Regulation.  It  considers  the  EMPs  and  MSs  reporting 
under  the  Regulation  to  assess  if  they  have  adequately  addressed  all  mortality  factors 
affecting  the  eel  stock,  with  a  special  emphasis  on  the  design  and  implementation  of 
restocking  measures  and  the  management  of  glass  eel  fisheries.  It  also  covers  the 
enforcement and monitoring issues, both in marine and in inland waters. The evaluation 
also looks into the articulation and coherence between the Eel Regulation and other EU 

1 Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing measures for the recovery of 

the stock of European eel, OJ L 248, 22.9.2007, p. 17–23 

2  Report  from  the  Commission  to  the  Council  and  the  European  Parliament  on  the  outcome  of  the 
implementation  of  the  Eel  Management  Plans,  including  an  evaluation  of  the  measures  concerning 
restocking and of the evolution of market prices for eels less than 12 cm in length – COM(2014)0640 
final 

3  Proposal  for  a  Council  Regulation  fixing  for  2018  the  fishing  opportunities  for  certain  fish  stocks  and 
groups of fish stocks, applicable in Union waters and, for Union fishing vessels, in certain non-Union 
waters, and amending Council Regulation (EU) 2017/127 

4  Joint  Declaration  on  strengthening  the  recovery  for  European  eel  (Commission  and  Member  States) 

http://data.consilium.europa.eu/doc/document/ST-5382-2018-INIT/en/pdf 

5  Regulation  (EU)  No  508/2014  of  the  European  Parliament  and  of  the  Council  of  15  May  2014  on  the 

European Maritime and Fisheries Fund, OJ L 149, 20.5.2014, p. 1–66 

6 Council Regulation (EC) No 1198/2006 of 27 July 2006 on the European Fisheries Fund 

6 

 
                                                           
rules in place such as the Common Fisheries Policy7, the fisheries control regulation8 and 
environmental legislation, in particular the Water Framework and Habitats Directives9. It 
looks as well into the articulation and coherence with international instruments that cover 
eels,  such  as  the  General  Fisheries  Commission  for  the  Mediterranean  (GFCM) 
recommendations, the Convention on International Trade in Endangered Species of Wild 
Fauna and Flora (CITES) and the Convention on the Conservation of Migratory Species 
of Wild Animals (CMS). 

2.  BACKGROUND TO THE INTERVENTION 

Description of the intervention and its objectives 

Recognising the complex life cycle of the European eel and the variety of the pressures 
impacting the stock helps to understand the background for setting the intervention. 

The European eel (Anguilla anguilla) belongs to one single population. It is a long-lived 
species  that  has  a  complex  lifecycle  and  spawns  only  once  in  the  lifetime.  It  is  a 
catadromous species, which means it spawns in the sea and grows and matures in inland 
waters (see Annex 6). Scientific data indicate the spawning area is in the Sargasso Sea (a 
region  of  the  North  Atlantic  Ocean,  outside  EU  waters),  so  the  distribution  of  eels  on 
their spawning migration extends all the  way  from  northern  Europe across  the Atlantic 
Ocean and down to the Sargasso Sea. 

Following  multi-decadal  decline  at  an  alarming  rate  of  the  European  eel  stock  across 
Europe,  in  1999  the  International  Council  for  the  Exploration  of  the  Sea  (ICES) 
recommended that a recovery plan for European eel was urgently needed. 

This decline is attributed to multiple causes. The stock is facing numerous anthropogenic 
pressures, including fisheries and non-fisheries. Climate change may also have impacts. 
Fisheries  take  place  in  marine,  transitional  and  freshwaters,  although  fishing  pressure 
varies from  area to  area, from  almost  nil to  heavy  overexploitation.  Illegal,  unreported, 
and unregulated (IUU) fishing and illegal trade are known to occur, as recognised by the 
scientific advice, Member States, civil societies and the EUROPOL among others. Other 
human  activities  than  fishing  affecting  eel  are    (a)  hydropower,  pumping  stations,  and 
other water intakes; (b) habitat loss or degradation; (c) pollution, diseases, and parasites; 
and (d) other management actions that may affect levels of predation, e.g. conservation 
vs. control of predators. 

Therefore, the conservation and management of  eels  as  a wide-ranging issue needed to 
take into account both fisheries and environmental considerations. 

In October 2003, the European Commission proposed the development of a Community 
Action  Plan  for  the  management  of  European  Eel10.  In  July  2004  the  Council  adopted 

7 REGULATION (EU) No 1380/2013 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

of 11 December 2013 on the Common Fisheries Policy, OJ L 354, 28.12.2013, p. 22–61 

8 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system 
for ensuring compliance with the rules of the common fisheries policy, OJ L 343, 22.12.2009, p. 1–50 
9 Directive 2000/60/EC of the European Parliament and of  the Council of 23 October 2000 establishing a 
framework  for  Community  action  in  the  field  of  water  policy,  OJ  L  327,  22.12.2000,  p.  1–73,  and 
Council  Directive  92/43/EEC  of  21  May  1992  on  the  conservation  of  natural  habitats  and  of  wild 
fauna and flora, OJ L 206, 22.7.1992, p. 7–50 

10 COM/2003/0573 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52003DC0573  

7 

 
                                                           
conclusions in this regard and requested the Commission to come forward with proposals 
for  long-term  management  of  eels  in  Europe.  Later  in  November  2005,  the  European 
Parliament  adopted  a  resolution  calling  on  the  Commission  to  submit  a  proposal  for  a 
regulation  for  the  recovery  of  European  eel  stock.  Based  on  the  identified  actions  and 
targets for rebuilding eel stocks under the Community Action Plan for the management 
of  European  Eel  and  the  scientific  advice,  in  2005  the  Commission  proposed  a 
Regulation to put in place measures for the protection and recovery of the European eel 
stock, which was adopted by the Council in 2007 (Regulation No 1100/2007). 

This so called Eel Regulation entered into force in September 2007 and required MSs to 
establish  EMPs  for  their  river  basins  that  constitute  significant  eel  habitats  for 
implementation in 2009. EMPs had to include (i) measures to ensure the escapement to 
the  sea  of  at  least  40%  of  adult  eels  relative  to  the  escapement  levels  that  would  have 
existed  in  the  absence  of  human  influences,  such  as  limiting  (professional  and 
recreational) fisheries; and (ii) making it easier for fish to migrate through the rivers; iii) 
restocking suitable waters with young eel. The Regulation refers to achieving its aim in 
‘the long term’. The choice of the conservation measures to ensure eel survival remained 
with  MSs  as  different  choices  would  have  different  social  and  economic  consequences 
which could not have been evaluated in a global fashion. In addition, MSs that permit the 
fishing of eels less than 12 cm in length (glass eels) were obliged to reserve 60% of their 
glass  eel  catches  for  restocking  purposes.  MSs  that  have  not  established  EMPs  are 
obliged to reduce their fishing effort/eel catches  by at least 50% relative to the average 
from 2004 to 2006. 

Intervention Logic 

The  schematic  Intervention  Logic  for  the  development  of  the  Eel  Regulation  is 
presented  in  Figure  1  below.  It  illustrates  the  hierarchy  between  the  objectives,  from 
inputs  through  activities  to  the  ultimate  desired  impact  of  the  Eel  Regulation  and  its 
contribution to achieving the protection and sustainable use of the stock of European Eel 
in EU waters, reflecting the needs of the 2003 Community Action Plan. 

8 

 
 
 
Figure 1. Schematic intervention logic of the Eel Regulation 

9 

General Objective(Impact)Specific Objectives(longer-term outcomes)Operational Objectives(intermediate outcomes)ActivitiesInputsDevelopment of a Community Action Plan for the Management of European EelProtection and sustainable use of the stock of European eel (Anguilla anguilla) in Community watersCouncil Regulation No. 1100/2007 establishing measures For the recovery oof European eelsSustainable fishing for eelsProtection & conservation of aquatic habitatsCooperation & coherent actions all  levelsClear interlinkages between EU policies & international instruments Council Regulation No. 1100/2007Establishing measures for the Recovery of the European eelReduced fishing effort, majority eels <12cm for restocking & >40% escapementEnvironmental measures to increase eel recruitment, survival and escapementAdequate control and enforcement measuresEel Management Plans& Other EU / International InitiativesEFF (2007-2013) and EMFF (2014-2020) fundingEU MS Eel Management PlansEU and international instruments to protect and conserve endangered species and habitatsDetermine and enable escapement targets at MS levelReducing & restricting commercial/recreational fishing, restocking, environmental measures predator control & aquacultureEFF (2007 – 2013 and EMFF ((2013-2020) funded support to Member state Operational Programmes, as well as direct support to common activities e.g. fisheries control, data collection, etc.)Scientific advice e.g. from ICES WG Eel Reduction of eel mortality caused by factors outside the fishery 
 
Baseline and points of comparison  

The  European  eel  population  has  fallen  by  90%  since  the  1960s/70.  Scientific  advices, 
before the Eel Regulation entered into force, indicated that the stock was highly depleted 
and outside safe biological limits11, and in particular pointed out the following: 

 

 

 

the  stock  was  at  an  historical  minimum  in  most  of  the  distribution  area  and 
continued to  decline; the fishery was not  sustainable; the anthropogenic  factors 
(habitat  loss, contamination,  and transfer of diseases) have had negative  effects 
on the stock; 
fishing mortality was thought to be high both on juvenile (glass eel) and older eel 
(yellow and silver eel); 
recruitment  to  the  stock  was  at  a  historically  low  level  (1-5%  of  the  pre-1980 
level) and most recent observations did not indicate recovery; 

  estimated total yield has declined to about half that of the mid-1960s. 

Prior  the  Eel  Regulation,  many  MSs  have  implemented  a  wide  range  of  measures 
concerning  eel  management  such  as  minimum  landing  sizes,  closed  seasons  and  areas, 
licensing of eel  fishermen, regulations concerning  construction of dams  and eel  passes. 
Restocking has been practised by some countries for decades, but this has generally been 
to  maintain  fisheries  rather  than  improve  the  stock  or  recruitment.  The  EU  Habitats 
Directive was established in 1992 and the Water Framework Directive was established in 
2000, inter alia, to protect, conserve and enhance the environment where the eel spends 
the largest part of its life cycle. 

The  Eel  Regulation  introduced  a  common  target  for  all  MSs  in  order  that  measures  to 
restore  eel  population  are  equitable.  The  Community  approach  was  needed  that  MSs 
could each implement a balanced and adequate contribution to the eel management. The 
Regulation specifically refers to achieving the 40% biomass target in ‘the long term’ but 
provides  no  explicit  timeline.  It  also  established  an  obligation  for  MSs  to  report  to  the 
Commission  on  the  monitoring,  effectiveness  and  outcomes  of  their  EMPs  every  third 
year until 2018 and subsequently every six years. 

If no action was taken to improve the survival of adult silver eels, a very low abundance 
of glass eel would result in a decline in the abundance of yellow eel in rivers and at the 
end  the  abundance  of  emigrating  silver  eel  would  also  decline.  Further  decline  could 
mean  that  the  European  eel  stock  could  no  longer  exist  as  a  significant  exploitable 
aquatic resource, and the associated jobs and markets could be lost. Failure to act could 
also accelerate a biodiversity loss and result in a disappearance of the specie. 

Other points of comparison relevant for the evaluation of the Eel Regulation 

The below described facts underlined the need for policy response. 

11 http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2005/may/wgeel.pdf 

http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2006/may/eel-eur.pdf 
http://ices.dk/sites/pub/Publication%20Reports/Advice/2007/oct/eel-eur.pdf  

10 

 
 
                                                           
Considering  dire  state  of  the  stock,  in  September  2008  European  eel  was  listed  in  the 
International  Union  for  Conservation  of  Nature  (IUCN)  Red  List  as  a  critically 
endangered species12. Next category is extinction of the specie. 

European eel was also listed in Appendix II of the Convention on International Trade in 
Endangered  Species  (CITES)  in  2007  (the  listing  came  into  force  in  2009),  which 
concerns species that are not necessarily threatened with extinction but that may become 
so unless trade is closely controlled in order to avoid utilisation that is incompatible with 
their  survival.  This  is  reflected  through  listing  since  13  March  2009  in  Annex  B  to 
Council Regulation (EC) No 338/97 on the protection of species of wild fauna and flora, 
which  implements  the  CITES  in  the  EU.  The  EU  Scientific  Review  Group  (SRG) 
established under the Regulation No 338/97, which gathers all scientific authorities of the 
EU MSs, at a meeting in December 2010 came to the conclusion that "it was not possible 
for the SRG to consider that the capture or collection of European eel specimens in the 
wild  or  their  export  will  not  have  a  harmful  effect  on  the  conservation  status  of  the 
species". On that basis and recurrent  annual assessment by the SRG, the EU MSs have 
not been in a position to allow export from or import to into the EU of the European eel. 

In  2014,  European  eel  was  also  included  in  the  Convention  for  the  Protection  of  the 
Marine Environment of the North-East Atlantic (OSPAR) List of the Threatened and/or 
Declining Species and Habitats13. The same year, European eel was added to Appendix II 
of  the  Convention  on  Migratory  Species  (CMS),  whereby  Parties  (covering  almost  the 
entire distribution of European eel) to  the Convention call for cooperative conservation 
actions to be developed among Range States. 

3. 

IMPLEMENTATION / STATE OF PLAY 

3.1.  Description of the current situation  

According to  the scientific advice, the status  of  the European eel  stock remains critical 
and the glass eel recruitment remains at low levels at all times. The annual recruitment of 
glass eel to European waters in 2018 was 2.1% of the 1960–1979 level in the ‘North Sea’ 
series  and  10.1%  in  the  “Elsewhere  Europe”  series.  The  annual  recruitment  of  young 
yellow eel to European waters in 2018 was 29% of the 1960–1979 levels. MSs’ progress 
in  implementing  their  EMPs  and  associated  measures  for  the  recovery  of  eel  stock  is 
presented below. 

3.2.  Eel Management Plans and exemptions 

Pursuant to Article 2 of the Eel Regulation, MSs are required to establish the EMPs for 
their river basins that constitute natural habitats for the European eel, for adoption by the 
Commission on a basis of the technical and scientific assessment. Each EMP constitute a 
management plan adopted at national level within the framework of the EU conservation 
measure. 

19 MSs have developed and implemented national EMPs: BE, CZ, DK, EE, FI, FR, 
DE,  EL,  IE,  IT,  LV,  LT,  LU,  NL,  PL,  PT,  ES,  SE,  UK.  Some  MSs  have  prepared 
multiple EMPs to cover individual Eel Management Units (EMU), which typically relate 

12 https://www.iucnredlist.org/ja/species/60344/45833138   

13 https://www.ospar.org/work-areas/bdc/species-habitats/list-of-threatened-declining-species-habitats  

11 

 
                                                           
to River Basin Districts as defined under the Water Framework Directive, resulting in the 
preparation of over 60 EMPs. One EMP has been developed at cross-border level under 
Article 6 of the Regulation (the ES / PT Transboundary Plan for Minho River). In the 
majority  of  MSs,  EMPs  have  remained  static  documents,  rather  than  being  used  to 
encourage  adaptive  management  based  on  the  findings  of  the  latest  monitoring  and 
research.  Only  one  EMP  has  been  amended  so  far  (by  NL).  The  Commission  has 
approved all EMPs and their amendments based upon an assessment by ICES. 

The  EMPs  cover  almost  90  Eel  Management  Units  and  around  1,880  actions.  The 
management  measures  vary  from  one  EMU  to  the  other  and  not  all  measures  are 
implemented  in  all  EMUs.  In  many  cases,  multiple  parties  have  been  involved  in  the 
development  and  implementation  of  EMPs  (national  authorities  and  state  agencies  for 
fisheries,  environment,  control,  structural  funds,  as  well  as  academic  advisors).  This 
broad  involvement  reflects  the  wide  geographical  coverage,  the  need  to  consider  both 
marine  and  freshwater  environments,  and  the  broad  scope  of  proposed  management 
measures. 

Five  MSs  (CY,  MT,  AT,  RO,  SK)  were  exempted  from  preparing  EMPs  in  2009, 
pursuant  to  Article  3  of  the  Eel  Regulation,  as  their  river  basins  or  maritime  waters 
concerned  cannot  be  identified  and  defined  as  constituting  natural  habitats  for  the 
European eel. 

In accordance with Article 1(2) of the Eel Regulation and based on scientific evidence, 
the Black Sea and the river systems connected to the Black Sea have been assessed as not 
constituting a natural habitat for European eel for the purpose of the Regulation. Hence, 
MSs with river basins flowing only into the Black Sea (HU, RO) were exempted from 
preparing the EMPs.  

SI,  HR,  as  well  as  BG  (for  river  systems  outside  the  Black  Sea)  are  not  formally 
exempted but have decided not to submit EMPs as they consider eel catches (outside the 
Black Sea in the case of BG) to be minimal. Those MSs operating a fishery that catches 
European  eel,  who  have  not  submitted  EMP  to  the  Commission  for  approval  and  have 
not been exempted, are subject to a 50% reduction of fishing effort or a 50% reduction in 
eel catch relative to the average from 2004 to 2006, according to Articles 4(2) and 8 of 
the Regulation. 

A list of relevant Commission decisions is provided in Annex 4 to this SWD. 

3.3.  Measures contained in the EMPs 

The  implementation  of  the  Eel  Regulation  has  suffered  significant  delays.  EMPs  were 
submitted  late  by  MSs  (ranging  from  several  months  to  almost  two  years  after  the 
deadline),  technical  evaluations  took  unexpectedly  long,  reports  had  to  be  re-submitted 
for approval by the Commission, and the implementation of the majority of plans were 
correspondingly delayed. 

The  main  categories  of  the  measures  contained  in  the  EMPs  submitted  by  the  MSs 
include the following: 

Commercial fishing: a variety of measures to reduce the impact of commercial fishing 
on the eel stock typically focused on reducing fishing effort (ranging from prohibition of 
certain gears in specific areas to total bans on commercial eel fisheries) and introducing 

12 

 
or extending closed seasons.  Measures are also aimed at improving fishery monitoring 
systems (e.g. implementing national catch registers). 

Recreational fishing: the measures to reduce the impact of recreational fishing on the eel 
include bans on targeting or capturing eel, closed seasons, introduction of quota, increase 
in minimal size limit, and development of systems to report catches. 

Hydropower and other connectivity obstacles: within some EMPs, measures aiming to 
mitigate  against  the  effects  of  physical  obstacles  to  migration  in  water  courses  are 
focused on removal of barriers, or the installation of eel pass structures.  In some cases, 
they involve trapping of silver eels upstream of obstacles and releasing them downstream 
of the obstacle. 

Habitat  improvement:  management  measures  relating  to  habitat  improvement,  often 
described  in  unspecific  and  vague  terms,  include  increasing  habitat  connectivity, 
improving water quality, and establishing protected areas. 

Restocking is a management measure that features in the majority of EMPs. 

Other:  other  management  measures  listed  in  EMPs  tend  to  consider  enhancement  of 
fisheries  management  frameworks  (e.g.  setting  up  fisheries  reporting  systems  and 
improvement  of  fisheries  control)  or  monitoring  and  research  programmes  (e.g. 
expanding  catchment  fish  surveys  and  progressing  research  on  fish  health  and 
development  of  models  to  assess  stock  indicators),  rather  than  strictly  looking  at 
addressing anthropogenic impacts.  In some cases, measures also target predator control, 
focused particularly on the control of cormorant populations. 

Each  MS  applies  management  measures  to  reach  specific  common  targets  established 
under the Eel  Regulation in  order that measures  to  restore eel  population  are equitable. 
These targets are described below. 

The 40% escapement target 

In line with  the requirements of the  Eel  Regulation (in particular Article 2 thereof), all 
EMPs should aim to achieve in the long-term an escapement of silver eel to the spawning 
population that equals or exceeds a target set at 40% of the potential biomass that would 
be produced under conditions with no anthropogenic disturbance. There is no timeline for 
achieving this objective, nor are any interim targets established. 

Whilst all EMPs share this common target, the approach to the achievement of that target 
varies across MSs. 

The 60 % restocking target 

In accordance with Article 7 of the Regulation, MSs who permit fishing for eels less than 
12 cm in length (glass eels), either as part of an EMP or as part of a reduction in fishing 
effort/catches, are obliged to reserve at least 60 % of those eels caught by the fisheries in 
that MS during each year to be marketed for use in restocking in eel river basins for the 
purpose of increasing the escapement levels of silver eels. 

This target was to be achieved by 31 July 2013 gradually by setting at least 35 % in the 
first year of EMP application and then increased by steps of at least 5 % per year. 

13 

 
The 50% fishing reduction 

Pursuant to Articles 4(2) in conjunction with Article 8(1) of the Regulation, a MS, who 
has not submitted an EMP to the Commission and who has not been exempted from this, 
is obliged either to reduce fishing effort by at least 50 % or eel catches by at least 50 %, 
both relative to the average from 2004 to 2006. 

This reduction was to be achieved gradually from 1 July 2009, initially by steps of 15 % 
per year in the first two years over a 5-year period. 

3.4.  Reporting by Member States and the Commission 

Reporting on EMP implementation 

Under Article 9 of the Eel Regulation, MSs are required to  report on the monitoring, 
effectiveness  and  outcomes  of  EMPs  initially  every  three  years  and  then  after  a  third 
progress report every six years. Under the Joint Declaration on the recovery of European 
eels  (December  2017),  MSs  agreed  to  continue  providing  progress  reports  on  the 
implementation of their EMPs every three years, until there is a strong scientific evidence 
of recovery signs for the eel population across Europe. 

The required information includes:  

 

 
 
 
 

the  proportion  of  silver  eel  biomass  (relative  to  the  target  level  of  escapement) 
that escapes to the sea to spawn or leaves the national territory;  
the level of fishing effort that catches eel each year;  
the level(s) of anthropogenic mortality outside the fishery;  
the amount of eel less than 12 cm in length caught; and  
the proportions utilized for different purposes. 

The  Commission  has  facilitated  this  reporting  and  the  assessment  by  providing  further 
guidance to MSs through explaining various definitions and preparing specific templates 
in Excel format, developed with ICES, to be used on a voluntary basis. 

Moreover, MSs are obliged to establish the appropriate reporting systems: 

 

 

to ensure that the respective percentages of eels less than 12 cm in length caught 
are used in a restocking programme (Article 7(3) of the Regulation); 
to  monitor  market  prices  for  eels  of  less  than  12  cm  in  length  to  be  reported 
annually to the Commission (Article 7(5) of the Regulation). 

Progress reports - 2012 

In  2012,  MSs  first  reported  on  the  actions  taken  under  the  EMPs,  the  reduction  in 
anthropogenic  mortalities  achieved,  and  the  state  of  their  stock  relative  to  their  targets. 
ICES  evaluated  these  progress  reports  in  terms  of  the  technical  implementation  of 
actions. 

The 2012 Progress Reports inform about a total of 1,362 individual management actions 
from  the  81  Eel  Management  Units  (EMU)  established  by  MSs.    The  most  commonly 
adopted  categories  of  measures  were  those  aimed  at  the  control  of  commercial  and/or 
recreational fisheries with slightly fewer measures addressing hydropower and obstacles 
to  eel  movements,  and  fewer  still  implementing  habitat  improvement  or  stocking 
measures (see Figure 2). 

14 

 
Figure 2: Proportion of management measures by category [source: ICES (2014a)] 

About  two-thirds  of  the  planned  measures  under  the  EMPs  relate  to  fisheries 
(commercial  and  recreational),  improved  passage  at  hydropower  installations  and  other 
obstacles and habitat improvement in general. 

Many MS did not  completely report stock indicators (22 of 81 EMPs did  not report all 
biomass  indicators,  and  38  did  not  report  all  mortality  indicators),  and  there  were 
differences in the approaches used to calculate reported stock indicators. 

Analysis  of  2012  Progress  Reports  showed  mixed  results.  Out  of  1,188  management 
actions documented, 1,140 had been planned in the original EMPs and the remaining 48 
were  new,  additional  measures.  A  total  of  756  management  actions  (e.g.  easement  of 
barriers, restocking, restrictions on fishing) proposed in the EMPs had been implemented 
fully,  259  partially  and  107  declared  as  not  implemented  at  all.  Information  for  the 
remaining 18 measures was missing.  

In  terms  of  progress  towards  EMP  targets,  out  of  81  EMUs,  17  EMUs  were  achieving 
their  biomass  targets,  in  42  EMUs  this  was  not  the  case,  and  there  is  no  report  for  22 
EMUs. 24 EMUs reported on achieving their anthropogenic mortality targets, 19 reported 
not to have achieved these targets. Of 59 EMUs analysed, 29 reported a rise in silver eel 
escapement and 30 reported a decline. 

In most EMUs established by countries for the implementation of their EMPs, progress 
was  made  in  implementing  management  measures  related  to  fisheries,  but    other 
management  measures,  such  as  improving  habitats,  combatting  parasites  or  predator 
control, have often been postponed or only partially implemented. 

The extent to which management measures as detailed in EMPs have been implemented 
is presented in Figure 3 below. 

15 

 
 
Figure  3:  Implementation  of  management  measures  in  EMPs,  as  reported  in  2012 
progress reports, summarised by category [Source: Reproduced from ICES, 2018d] 

2014 Commission report  

In October 2014, the Commission reported to the European Parliament and the Council 
on  the  outcome  of  the  EMP  implementation,  as  well  as  on  the  measures  concerning 
restocking  and  evolution  of  the  market  prices  on  glass  eels14.  The  results  of  this  first 
assessment were largely inconclusive due to the delays in the preparation and approval of 
the  national  EMPs  and  the  delays  in  the  implementation  of  non-fisheries  related 
measures.    In  general,  it  remained  difficult  to  assess  the  outcome  of  EMPs  against  the 
40% escapement target set by the Regulation. It was not yet possible to determine on an 
individual basis the contribution of EMUs to the recovery of the whole stock. 

Progress reports - 2015 

MSs  again  reported  on  progress  with  implementing  their  EMPs  in  2015.  14  out  of  19 
countries submitted national reports15. However, the required information was not always 
complete, and the quality of the national data and assessment were difficult to evaluate.  

Progress reports - 2018 

It needs to be noted that the 2018 reporting by MSs was again not complete. Of those 
countries  with  EMPs:  LU  and  PT  did  not  report  at  all;  CZ,  FI  and  IE  provided  a 
description but no data tables, and FR and PL did not provide all seven data tables. CZ, 
FI, EL, IE, LV, PL and ES reported after the deadline. 

The 2018 progress reports have been evaluated by ICES (for the biological part) and by 
the external  study consultants  (for other parts). Significant complexities were involved, 
for example as  a result of the continued lack of standardisation in  approaches taken by 
countries to modelling and calculation of stock indicators. 

14 COM/2014/0640 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2014:640:FIN  

15 CZ, EE, ES, LU and LV did not submit their progress reports. 

16 

 
 
                                                           
An  overview  of  the  targets  and  management  measures  set  out  in  EMPs  and  the 
extent to which they are known to have been implemented in each MS is presented in 
Annex 5. It includes a scope and availability of EMPs and Progress Reports (Annex 5.1), 
and  MS  progress  in  implementing  their  EMPs  and  achieving  the  escapement  target 
(Annex 5.2). 

The analysis based on 2018 Progress Reports has found that: 

  5 MSs report full or partial (i.e. within some but not all EMUs) achievement 
of  the  40%  escapement  target,  though  in  some  cases  there  is  significant 
uncertainty associated with escapement calculations. 
the remaining 14 MSs mostly report that the escapement target has not been 
achieved, and in some cases, there is insufficient data to judge whether the target 
has been achieved. 

 

Table 1. Achievement of the 40% escapement target by MSs 

Achievement of 40% escapement target 

Member State 

YES 

EE, IE (in all EMU but one) 

Partial/variable 

DE, ES, UK 

NO 

Not clear 

BE, DK, IT, LT, LU, LV, NL, PL, SE 

CZ, FI, FR, EL, PT 

Only  in  some  cases,  Progress  Reports  analyse  the  causes  of  failure  to  achieve  the  Eel 
Regulation main target (i.e. escapement). Causes mentioned are: 

  need  for  higher  levels  of  inter-agency  cooperation  at  MS  level  to  implement 

management measures,  
 
lack of/poor data on which to base management measures and monitor progress,  
  concerns  about  the  uncertainty  around  management  measures  influencing 
spawning and ultimately stock status (i.e. more fish does not necessarily equate 
to increased spawning), and  
lack of funding to implement management measures. 

 

The  EMP  Progress  Reports  and  Country  Reports  provided  to  the  WGEEL  in  2018 
indicate  that  management  measures  set  out  in  original  EMPs  have  not  changed 
significantly over time. Broadly, it appears that the focus has moved even further towards 
fishing restrictions and away from non-fisheries measures. 

The assessment of EMPs and Progress Reports shows that both comparative analyses of 
progress across the MSs, as well as a cumulative analysis for the entire EU, is currently 
not achievable. This is due to incomplete national datasets, uncertainty about the quality 
of  national  data  and  assessments  and  the  differing  approaches  taken  by  MSs  for 
measuring stock indicators. 

Good practices in eel conservation 

This evaluation finds that there have been a number of successes and examples of good 
practice  as  a  direct  result  of  the  Eel  Regulation.  These  practices  may  be  a  source  of 
inspiration for other MSs for strengthening the implementation of their EMP and various 
activities. These good practices are described in more detail in Annex 5.3. In summary, 

17 

 
most of these successes have been fisheries-focused.  Many are bringing short-term gains 
e.g.  reduction  in  fishing  effort  and  output,  but  others  maybe  longer-term,  e.g.  bringing 
fundamental  changes  in  MS  and  individual  EMU  management.    However  the  main 
challenge  is  now  to  consolidate  these  successes  and  to  address  the  longer-term,  often 
non-fisheries related anthropogenic impacts on spawner escapement. 

Reporting on the evolution of market prices for eels < 12 cm 

Reporting requirements 

Pursuant to Articles 7(5) of the Eel Regulation, the Commission shall report annually to 
the Council on the evolution of market prices for eels of less than 12 cm in length16. For 
this purpose, MSs are obliged to establish an appropriate system to monitor these prices 
and report on them annually. By 1 July 2011, the Commission was to report for the first 
time to  the Council on the evaluation  of the measures concerning restocking, including 
the evolution of market prices. 

The level and quality of glass eel price reporting is highly variable between MS and as a 
result,  the  Commission  has  been  unable  to  fulfil  this  annual  reporting  requirement. 
According to the 2014 Commission assessment report17, only 9 complete glass eel reports 
were received by July 2012. Since then, no national reports on glass eel prices have been 
submitted,  although  BE,  DK,  EE  and  the  UK  have  provided  some  price  data  in  their 
recent  2018  Annual  Progress  Reports.  This  represents  a  major  failure  in  the 
Regulation’s monitoring requirement. As mentioned above, these prices are linked to 
the  glass  eel  harvest  strategy  in  terms  of  managing  the  proportion  of  eels  <12  cm 
reserved for stocking. 

According to Article 7(6) of the Eel Regulation, when market prices of glass eel used for 
restocking suffer a significant decline compared to the price of glass eels used for other 
purposes, based on price information submitted by MSs, the Commission is required to 
take  appropriate  measures  to  address  the  situation.  These  measures  may  include  a 
reduction in the percentage of glass eels to be reserved for restocking as set out in Article 
7(2) of the Regulation. No such measures have been adopted. 

Glass eel production 

Reported  glass  eel  production  has  increased  from  just  under  40  tonnes  per  annum  in 
2011 to around 60 tonnes in 2018. FR remains the predominant glass eel producer and is 
the only country to set quotas (currently 64.75 tonnes, of which 38.75 tonnes are reserved 
for  restocking).    ES  glass  eel  production  over  this  period  (minimum  1  ton  in  2018  and 
maximum 16 tonnes in 2017) is mainly for local use in a small area of the Basque region, 
a traditional practice that is now being replaced with an artificial substitute. 

16 Eels less than (<) 12 cm in length are mainly composed of glass eels (min. 5.4, max 9.2 cm) and smaller 

yellow eels (e.g. from 6.9 cm upwards (to 133 cm)) 

17 COM/2014/0640 final 

18 

 
                                                           
Figure 4: EU glass eel production (2011 - 2018), Source: Compiled from ICES (2018c) 

Evolution of market prices of eels less than 12 cm in length 

Based  on  the  limited  data  available,  the  EU  market  prices  of  eels  <12  cm  that  are 
predominantly used for restocking (besides some limited traditional direct consumption) 
remained fairly constant at around €470 / kg over the five year period 2009 – 2013 before 
collapsing  to  €128  in  2014  (presumably  in  response  to  the  abovementioned  spike  in 
production that year) and recovering slowly to the 2018 average of €274 (see Figure 5).  
These figures conform  with  confidential  tender  prices provided to  the  consultant of the 
external study by glass eel traders over 2016 – 2018. 

Figure  5:  Average  prices  for  glass  eels  <12  cm  (2009-2017)  used  for  restocking, 
showing production (tonnes, 2011-2017) 

Source: Prices 2018 Country Progress Reports (BE, EE, FR & UK); production ICES 2018a 

19  EU  countries  sold  live  eels  over  the  last  decades.  This  trade  includes  re-selling  of 
glass eels from one country to another e.g. if eel is sold from ES to DE and afterwards is 

19 

 
 
transported to PL for stocking, the  eel sales would be double counted as sales from ES 
and  sales  from  DE.  A  comparison  between  sales  and  buyer  statistics  reveals  that 
potentially 50% of the total sales could be double counted in this way and that for several 
countries the percentage of re-sales could be as large as 100%. As most of the countries 
in the above graph do not produce any glass eel, presumably these prices are re-exports. 
Therefore the total sales values should be regarded with caution (Motova, 2014). 

Intra-EU trade in glass eel 

Focusing on the intra-EU trade in glass eels, the reported EU catch of glass eels is around 
60  tonnes  per  annum  (see  Figure  5  above).  In  fishing  season  2016/2017,  64  tonnes  of 
glass  eel  catches  were  declared  to  national  authorities  in  FR,  ES,  PT  and  UK  and  59 
tonnes in the season 2017/2018.  The market for glass eels within the EU for aquaculture 
is around 15 – 20 tonnes and restocking is about 36 tonnes (60% of reported catches must 
be used for restocking). There may be an additional 10 tonnes for direct consumption in 
ES, so the total EU market is around 50 to 55 tonnes.  Questions have been raised about 
the fate of the other 5-10 tonnes of glass eels. 

It needs to be noted that at the lucrative Asian market the prices for glass eel can reach 
€1,500 – 2,500 per kg in Hong Kong.  Much of this is on-grown in China, but some may 
be exported to Japan, also for aquaculture (MRAG, 2017; Sanada, 2018). 

3.5.  Overall state-of-play of the implementation of the Eel Regulation 

Substantial  efforts  have  been  made  by  MSs  to  develop  and  implement  management 
measures  for  the  recovery  of  the  eel  stock.  About  two-thirds  of  the  planned  measures 
under  the  EMPs  relate  to  fisheries  (commercial  and  recreational),  improved  passage  at 
hydropower installations and other obstacles and habitat improvement in general.  

The  implementation  of  measures  varies  in  terms  of  progress  and  in  terms  of  approach. 
The management measures vary by the EMU, i.e. not all measures are implemented in all 
EMUs. There are no major changes in management practices for eel throughout Europe 
in the recent years. Some countries have implemented measures according to their stated 
schedule whilst others have lagged behind. 

Despite a significant proportion of measures fully implemented, there is no evidence to 
suggest  that  these  measures  have  enabled  significant  progress  towards  the  escapement 
target. The silver eel escapement is still well below the 40% target. 

Some progress has been made in reducing fishing effort, but it has also risen in some MS. 
Catches of yellow and silver eels have declined. Glass eel catches are steadily increasing. 
There  is  also  likely  to  be  considerable  un-observed  and  un-estimated  eel  mortality 
through  IUU  fishing  in  EU  waters.  Whilst  restocking  works  in  some  countries,  not  all 
have achieved their 60% restocking targets. 

The  reporting  on  the  evolution  of  the  market  prices  for  eels  <  12cm  has  been  largely 
incomplete and on irregular basis. Reported glass eel production has increased from just 
under  40  tonnes  per  annum  in  2011  to  around  60  tonnes  in  2018.  FR  remains  the 
predominant glass eel producer and is the only country to set quotas. 

20 

 
4.  METHOD 

4.1.  Methodology and data collection 

The evaluation is based on three pillars: 

1)  an evaluation study, carried out by an external consultancy18, and which primarily 
looked into management, implementation and enforcement issues, including trade 
aspects; 

2)  the International Council for the Exploration of the Sea (ICES) recurrent advices 
on eels  and the ad hoc assessment of the 2018 Member States’ progress  reports 
for the biological part; and 

3)  Commission's  analysis  of  the  use  of  the  EMFF  and  the  EFF  for  the 

implementation of the Eel Regulation, tasked to the FAME19 Support Unit. 

The procedural information can be found in Annex 1. 

The external study was conducted between 21 September 2018 and 3 July 2019 over four 
main stages: inception phase, desk-based data collection, stakeholders consultations, and 
analysis  and  presentation.    The  study  was  supported  by  three  country  case  studies  to 
provide more detailed insight into the implementation of the Eel Regulation at national, 
regional and local levels. Three MSs included FR (top producer of wild caught glass eel, 
main  EU  MS  restocking  glass  eels),  DK  (major  producer  of  commercially  and 
recreationally  caught  eels  in  the  EU;  a  major  aquaculture  producer)  and  IT  (eel 
exploitation  still  important  despite  a  progressive  and  increased  loss  of  interest,  the 
intensive  aquaculture  strongly  reduced  today).  The  FAME  reports  and  ICES  advices 
were taken into account for the analysis under the external study. 

For this evaluation, data were collected using different methods: 
  analysis of MSs EMPs and relevant progress reports; 
  analysis of  MSs reports on the use of the EMFF and the EFF; 
 

results  of  the  questionnaires  from  the  Commission  on  control  of  eel  fisheries 
(2017-2018); 
feedback from MSs; 
targeted stakeholder consultations and public consultations; 
literature  review,  reports,  scientific  advice  on  eels  (in  particular  annual  ICES 
advice on the state of the eel stock and ad hoc advices requested); 

 
 
 

  analysis  of  the  River  Basin  Management  Plans  (RBMPs)  submitted  under  the 
Water Framework Directive (WFD) and relevant evaluation reports of the second 
cycle RBMPs; 
findings of 2007-2012  Habitats  Directive Article  17 reports on the conservation 
status of the most important Annex I habitat types for the European Eel20; 

 

  previous  Commission  assessment  report:  2014  Report  from  the  Commission  to 
the Council and the European Parliament on the outcome of the implementation 

18 “Evaluation of the Eel Regulation. Final Report”, Coffey. 

19 Fisheries and Aquaculture Monitoring and Evaluation under the European Maritime and Fisheries Fund 

20 http://art17.eionet.europa.eu/article17/reports2012/habitat/summary/  

21 

 
                                                           
of the Eel Management Plans, including an evaluation of the measures concerning 
restocking and of the evolution of market prices for eels less than 12 cm in length. 

The methods and tools for data collection and analysis were designed and refined such as 
the Evaluation Questions Matrix (see Annex 3.1). 

List of main literature consulted is included in Annex 3.3. 

4.2.  Consultation strategy  

The consultation was carried out to gather input from all relevant sources to evaluate the 
measures taken for the recovery of European eel stock under the Eel Regulation and their 
contribution to the achievement of the objectives of this regulation. 

The main objectives of the consultations were to: 

1)  obtain, analyse and integrate the views and experiences of those that are directly 

affected by the implementation of the Eel Regulation; 

2)  gather  the  views  of  citizens  and  a  wider  stakeholder  community  on  the  issues 

related to the implementation of the Eel Regulation; 

3)  identify  the  benefits  and  burdens  generated  by  the  implementation  of  this 

Regulation; 

4)  detect issues in the applicability and enforcement of these rules. 

The  main  consultation  tools  used  were  a  public  consultation  (Commission-led)  and 
targeted consultations with the assistance of an external consultancy within a supporting 
evaluation study. 

The consultation featured the following components: 

  The online feedback to the Evaluation Roadmap21 open for 4 weeks from 13 April 

to 11 May 2018. 

  A  public  consultation  via  the  Commission's  central  public  consultations  page22 
with  a  structured  questionnaire  (developed  with  support  of  the  external  study 
consultants)  published  online  in  all  EU  languages  on  14  December  2018  for  a 
period  of  12  weeks  and  publicised  on  the  Commission  websites,  networks  and 
with national authorities. Separate written contributions were also received. 

  Targeted  consultations,  both  written  (based  on  questionnaires)  and  oral  in  a 
limited number of EU languages of the MS public authorities, conducted by the 
external consultants. 

  Targeted consultations of key stakeholders affected by the implementation of the 
Eel  Regulation  through  bilateral  interviews,  complemented  by  additional  phone 
interviews in some MSs, carried out by the external consultants. 

  Targeted  consultation  of  the  relevant  Advisory  Councils,  the  main  stakeholder 
bodies bringing together sectorial organisations and other interest groups affected 
by  policy  initiatives  in  the  area  of  the  eels  management,  carried  out  by  the 
external consultants. 

The list of main stakeholders consulted is provided in Annex 3.2.  

21 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447_en  

22 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447/public-consultation_en  

22 

 
                                                           
Synopsis Report of the consultation is enclosed in Annex 2. 

4.3.  Timing and robustness of the evaluation 

The evaluation started in the first quarter (Q1) of 2018 and was planned to be completed 
in Q1 2019 to present the results of the evaluation and its conclusions to the Council in 
Q1  2019,  as  agreed  under  the  Joint  Declaration  on  strengthening  the  recovery  for 
European  eel  (December  2017).  The  external  study  in  support  of  this  evaluation  was 
finalised in July 2019. 

The  data  gathered  from  the  analysis  of  the  EMP  progress  reports,  other  reports  and 
literature,  the  targeted  and  open  consultations,  all  together,  provide  a  solid  body  of 
evidence. The evaluation is considered to be robust and well informed. 

Key limitations 

The complex biology of the European eel  and its long life cycle (from 10-20, up to  50 
years) makes it difficult to observe significant signs of recovery of the eel when focusing 
on the past ten years of the EMPs being implemented. This factor impacted at this stage 
the analysis of the effectiveness of the Eel Regulation and the associated measures. 

The lack of data on costs in MSs made it impossible to provide a monetarised analysis of 
the cost-benefits of the Eel Regulation. Thus, the efficiency of the measures established 
under the Regulation could not be evaluated in depth. 

The lack of progress  reports  from  some MSs, incomplete reports and national datasets, 
uncertainties  on  the  quality  of  national  data  and  assessments,  and  the  differing 
approaches  taken  by  MSs  to  measuring  stock  indicators,  impeded  both  comparative 
analyses of progress across MSs, as well as a cumulative analysis for the entire EU. 

5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1.  Evaluation Questions Matrix 

The  evaluation  questions  were  drafted  to  provide  answers  to  the  six  evaluation  criteria 
(relevance, effectiveness, sustainability, efficiency, coherence and EU added value) and 
structured around the judgement criteria (JC) used to interpret  each evaluation question 
(EQ). The analysis of the evaluation questions are based upon the Evaluation Questions 
Matrix that is provided in Annex 3.1. 

5.2.  Analysis and answers 

5.2.1.  RELEVANCE 

EQ1.  To  what  extent  are  the  existing  measures  for  the  recovery  of  European  eel 
stock under the Eel Regulation still relevant? 

Escapement levels 

The  analysis  of  the  2018  Progress  Reports  suggests  that  only  two  MSs  achieved  their 
escapement  targets  (EE,  IE),  three  countries  met  them  partially  (DE,  ES,  UK),  while 
other MSs who reported did not achieve this target or it is not clear. 

23 

 
The results of the scientific assessment by  ICES show that in  2017 the spawner  (silver 
eel) escapement from the majority of EMUs was below the 40% target (ICES, 2018c). 

This confirms that the escapement levels are still well below the general objective of the 
Eel  Regulation  of  at  least  40%  of  the  silver  eel  biomass  that  would  have  existed  if  no 
anthropogenic influence had impacted the stock. 

Eel landings, aquaculture production and eel recruitment 

Fisheries impact local eel populations and spawner escapement in 15 out of 20 countries 
reporting to the WGEEL. In total, fisheries make up for more than 50% of anthropogenic 
mortality  in  29  of  62  EMUs,  where  data  for  fishing  and  hydropower  mortality  was 
reported. 

Wild fisheries landings have declined to the current levels of around 2,500 tonnes since 
2010 onwards where they are now broadly stable. According to ICES estimates, in 2017 
the EU harvested around 2,300 tonnes of eels  with  FR, UK, DK and SE taking around 
two-thirds  of  the  EU  wild  catch  between  them.  In  particular,  recreational  landings, 
mainly  of  yellow  and  silver  eels  are  now  around  161  tonnes,  mostly  from  DK,  but 
reporting is now limited. ES is the only country to have glass eel recreational landings. 

Aquaculture  production  of  eels  declined  to  approximately  5,000–6,000  tonnes  now, 
mainly reflecting a reduced demand. It should be noted that eel aquaculture is based on 
wild recruits, and some of them are subsequently released as on-grown eel for stocking. 

Eel  recruitment  indices  show  a  similar  pattern,  having  strongly  declined  from  1980  to 
about 2010, and have remained at a low level since. The annual recruitment of glass eel 
to European waters in 2018 was 2.1% of the 1960–1979 level in the ‘North Sea’ series 
and 10.1% in the “Elsewhere Europe” series. The annual recruitment of young yellow eel 
to European waters in 2018 was 29% of the 1960–1979 level (ICES, 2018a). 

Annex  6  provides  for  more  detailed  information  on  the  European  eel  status,  landings, 
recruitment and aquaculture. 

This suggests that, in terms of landings and stock recruitment, whilst the situation is 
no longer declining, it is still critical. Concern has also been expressed  around the 
effects on species status of illegal, unreported and unregulated (IUU) fishing and the 
illegal trade in glass eels (SEG, 2018, Crook, 2010). 

Mortality outside the fishery and river basin conditions 

A key source of eel mortality outside the fishery is the impact of hydroelectric turbines 
and  dams  on  migration  and  escapement.  As  reported  by  ICES,  the  estimations  of  MS 
suggest  that  hydropower  mortality  accounts  for  more  than  50%  of  anthropogenic 
mortality  in  33  of  62  EMUs,  where  data  for  fishing  and  hydropower  mortality  was 
reported (ICES 2017b). 

The scientific data suggest that the anthropogenic mortality outside the fishery, whilst 
variable (can depend upon environmental conditions (flooding vs. drought) at the time of 
the down-stream migration), has not declined significantly over the past decade. 

See Annex 6 for more detailed information on the eel mortality outside the fishery, 

24 

 
 
Overall 

The  Eel  Regulation  provides  an  avenue  for  addressing  both  the  fisheries  and  non-
fisheries-related mortality in marine and fresh waters.  

As the recovery of the European eel is a long-term process that will take decades rather 
than  years to  progress,  in terms  of stock recovery  – both  from  direct  fishing as well as 
from other anthropogenic source of mortality, the objectives of the Eel Regulation are 
still  highly  relevant.  This  was  confirmed  in  the  Public  Consultation,  where  more  than 
nine  in  ten  respondents  agreed  that  there  remains  a  need  to  ensure  that  anthropogenic 
mortalities are reduced, for a European recovery plan for the European eel and for MSs 
to implement EMPs. 

5.2.2.  EFFECTIVENESS 

EQ2. To what extent have the current measures for the recovery of European eel 
stock under the Eel Regulation met its objectives? 

This  section is  structured around the objectives  as set  out  in  the intervention logic (see 
Figure 1 in Chapter 2). 

The protection and sustainable use of the European eel stock in EU waters 

The  ICES  Stock Annex and the most recent  ICES assessments show that the European 
eel stock is outside safe biological limits, the current fishery is not sustainable and that 
the stock has not recovered to any significant degree since 2010. The previous decline in 
recruitment  and  landings  seem  to  have  levelled  out,  although  recruitment  remains  at 
historically low levels, which is an indication that the reproduction is seriously impaired. 
The stock stabilisation is likely to have been supported by the reduction in fishing effort 
in  many  MSs  but  stock  recovery  is  a  long-term  goal  that  can  be  achieved  through 
addressing spawner escapement through habitat rehabilitation and improved connectivity. 
Only  a  combination  of  several  measures  can  be  expected  to  bring  the  stock  out  of  its 
current critical state. 

According  to  science,  an  analysis  of  the  stock  dynamics  under  different  management 
regimes indicates that the recovery time for eel could be at least 20 years or much more, 
or three eel generations (although eel generations differ with location across Europe, an 
average of 18 years per generation)23. Some MSs consulted argue that it can even take up 
to 50 years or more for the eel to recover. 

Concerns about the conservation and the unsustainable exploitation of the eel stock have 
been  growing  and  the  need  for  conservation  and  management  measures  is  clearly 
identified by scientists, managers, various stakeholders and by the public. The protective 
measures  to  recover  the  eel  population  in  Europe  were  widely  supported  by  the 
respondents  to  the  Public  Consultation.  Moreover,  many  stakeholders  consider  that  the 
‘black’ market and trade of eels has implications for both European eel management and 
recovery. 

23http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2007/Special%20Requests/EC%20guideline

s%20for%20eel%20MP.pdf  

25 

 
                                                           
It is clear that the recovery of the European eel is a long-term process that will take 
decades rather than years to progress given the long life-span of the species (e.g. 20 
years). Overall, the Eel  Regulation has  not yet proven its effectiveness in reaching 
its  objective  of  achieving  the  appropriate  protection  and  sustainable  use  of  the 
European eel stock in EU waters that would reflect the recovery of the stock. This is 
further evidenced below. 

Sustainable fishing of eels 

  On EMP and escapement target 

The key  objective of the Eel  Regulation  and consequently  of the EMPs is to  achieve  a 
target  of  40%  escapement  of  spawners  (e.g.  silver  eels).  This  is  a  long-term  objective, 
although no definite time period is specified. The management biomass reference limit of 
40%  for  eels  is  considered  as  a  common  proxy  for  maximum  sustainable  yield  (MSY) 
under the Common Fisheries Policy, however there are difficulties in applying the MSY 
approach to catadromous species such as the European eel, which spends a part of its life 
in marine waters and mostly in fresh waters. 

The  evaluation  finds  as  confirmed  by  the  scientific  advice  that  the  spawner  (silver  eel) 
escapement  from  the  majority  of  EMU  is  below  the  40%  target.  Currently,  the 
achievement of this target by MSs has been analysed as: 

fully implemented in EE and IE (in all EMU but one); 

- 
-  partially in DE, ES, UK; 
-  not implemented in BE, DK, IT, LT, LU, LV, NL, PL, SE; 
-  not clear in CZ, FI, FR, EL, PT. 

This indicates that it will take considerable more time to achieve EMP targets by MSs. 

The  Public  Consultation  respondents  were  much  less  convinced  that  the  overall  aim  of 
achieving the 40% eel escapement target was achievable. 

Some scientists suggested that focusing on mortality and setting mortality targets in line 
with  the  long-term  objective  of  40%  silver  eel  biomass  may  be  a  more  appropriate 
harvest strategy. This is echoed by the recent report to the European Parliament (Hanel, 
2019),  providing  that  a  number  of  authorities  argue  that  a  move  from  current  40% 
regional  level  escapement  targets  to  a  mortality-based  target  would  also  be  in  better 
agreement with ICES advice on eels (“all anthropogenic mortalities should be reduced to 
as close to zero as possible”). 

  On fishing effort reduction 

The information on fishing effort reduction in those MSs who have not established their 
EMP  and  were  not  exempted  by  the  Commission,  and  who  operate  a  fishery  in  EU 
waters  that  catches  eels,  is  not  available.  The  Eel  Regulation  does  not  provide  for  a 
reporting mechanism in this regard.  

26 

 
 
 
Limiting  eel  fisheries  and  fishing  effort  reduction  is  a  measure  that  features  in  many 
EMPs.  This  information  is  necessary  to  correctly  interpret  the  changes  to  the  landings 
data over the years.  

The most recent results for the six top eel fishing MSs in the EU (note that FR did not 
submit effort data in 2018) suggest that effort has declined in SE (by over 90%), IT (just 
over 50%), DK (by almost 50%) and DE (by 25%). However, effort appears to have risen 
to 135% of 2008 levels in the UK24 and 180% of the 2012 level in PL. See also Annex 6. 
The wild eel fisheries landings varied between 8,000 and 10,000 t until the early 1990’s 
when  they  declined  to  the  current  levels  of  around  2,500  t  since  2010  onwards,  where 
they are now broadly stable. 

It  needs to  be also  highlighted that the impact  of recreational  fisheries on the eel  stock 
remains largely unquantified although landings can be thought to be at a similar order of 
magnitude to those of commercial fisheries. A number of stakeholders contacted as part 
of this evaluation called for recreational fisheries for eel to be phased out or substantially 
reduced, often citing the example of FR, IE and SE in banning recreational eel fishing.  
According  to  ICES  (2013c),  almost  all  countries  planned  management  measures  for 
recreational fisheries. However there has been little or no monitoring of the effects. 

  On restocking 

The  Eel  Regulation  requires  that  at  least  60%  of  glass  eels  caught  in  each  MS,  who 
permits  fishing  for  eels  less  than  12  in  length,  should  be  reserved  and  used  for 
conservation-oriented restocking (or translocation) within the EU. 

Stocking is  a measure that features in  many EMPs. By 2013, stocking of glass eel  was 
undertaken in  16 MSs.  The amount of  glass eels restocked increased in  2014 when the 
lower  market  prices  guaranteed  a  larger  number  of  glass  eels  could  be  purchased  for 
fixed restocking budgets but has decreased since then (see Figure 6 below). 

Figure  6:  Reported  production  and  restocking  of  glass  eel  not  including  those  in 
quarantine by country (in millions) and as a proportion of production (%) (ICES, 2018b) 

24 In the UK, it is understood that good glass eel catches rapidly stimulate further effort as the mainly part-

time fishers communicate with others via smart phones.   

27 

 
                                                           
Whilst  stocking  is  a  measure  that  features  in  many  EMPs,  only  six  countries 
achieved  their  EMP  stocking  target  (ICES,  2016c).  The  figure  above  shows  that  the 
overall target of 60% use of reported catch in restocking was only achieved in 2014 when 
there was a plentiful supply of glass eels, but it has dropped to around 22% in 2018. Most 
EMUs had undertaken a limited quantity of their stocking targets while a few had yet to 
implement  any of their stocking actions. The most common reason given in  2013 for a 
country being unable to achieve its stocking target was a lack of funding to buy glass eel, 
which  was  different  from  that  given  in  the  recent  past  when  the  cost  of  glass  eel  was 
given as the cause. 

More  recently  the  limited  availability  of  glass  eel  for  stocking  was  highlighted,  a 
situation exacerbated by the high cost and considerable administrative process required to 
tender for  glass eel  supplies under the EMFF. One major stakeholder involved in  glass 
eel restocking noted (i) as the lowest of three tendered has to be taken, the quality of such 
supply is often poorer than more expensive tenders and (ii) it is difficult to forecast the 
actual  price  of  glass  eels  in  advance,  which  discourages  glass  eels  stakeholders  from 
tendering for MS restocking programmes in advance. 

The benefit of stocking can be considered at three geo-political scales: 

 
 

 

local interests (the production gained locally by stocking); 
the  national/EMU  scale  of  EMPs  (applying  stocking  to  achieve  EMP  biomass 
targets); 
the  continent-wide  scale  (stocking  contributing  to  the  general  recovery  of  the 
stock). 

Concerns about the effects of eel stocking practices (e.g. spread of disease, illegal trade, 
stocking above dams and hydro barriers) and its effectiveness in contributing to increased 
silver eel production have been raised.  Scientific reviews of restocking as a management 
measure (ICES, 2010b; Pawson, 2012; ICES, 2013c; ICES, 2016c) concluded that there 
is  evidence  that  translocated  and  stocked  eel  can  contribute  to  yellow  and  silver  eel 
production in recipient waters25. However, the scientific evidence of further contribution 
to actual spawning and the overall biomass increase of the stock is limited. Whilst a local 
benefit  may  be  apparent,  an  assessment  of  net  benefit  to  the  wider  eel  stock  is 
unquantifiable and limited by the lack of knowledge on the spawning of any eel. 

ICES  also  suggest  that  stocking  should  take  place  only  when  survival  to  silver  eel 
escapement  is  high  and  should  not  be  used  as  an  alternative  to  reduce  anthropogenic 
mortality. 

Moreover, the translocation of eels,  although effective in  maintaining or  supporting eel 
populations  in  compromised  river  systems,  is  considered  an  expensive  and  often 
administratively burdensome process. It is noted that restocking/translocation of glass eel 
should be considered a short to medium term measure that could be phased out if natural 
recruitment and spawner escapement were improved. 

  Eel aquaculture 

25 These included several Danish, German, Swedish and Estonian Lakes, Lough Neagh in Northern Ireland 

as well as Danish streams and marine areas. 

28 

 
                                                           
It  should  be  noted  that  eel  aquaculture  is  based  on  wild  recruits,  and  part  of  them  is 
subsequently  released  as  on-grown  eel  for  restocking.  The  farmed  production  of 
European  eel  increased  until  the  end  of  the  1990s.  It  clearly  starts  to  decline  since  the 
mid-2000s from 8,000–9,000 tonnes to approximately 5,000–6,000 tonnes now (see also 
Annex  6).  In  2017,  the  reported  quantities  of  eels  produced  in  aquaculture  is  4,546 
tonnes. NL and DE are the main EU aquaculture producers.   

Reproduction of the European eel  has not  yet  been achieved in  captivity  and glass eels 
are normally purchased from the UK, French and less frequently Spanish and Portuguese 
wild fisheries.  Progress is being made in terms of spawning, nursing and weaning onto 
first diets (Butts et al, 2016) but the large-scale, closed cycle farming of eels is not  yet 
achievable.  Until  this  is  achieved,  aquaculture  is  still  dependent  upon  glass  eels  and 
therefore has not reduced the pressure on wild stocks as yet.  It is also noted that there are 
associated risks attached to stocking glass eel, young yellow eel and on-grown eel from 
aquaculture. As identified by scientists,  those risks include spread of parasite, diseases, 
altering sex ratios, genetic and biological fitness. 

  On control and enforcement measures, including traceability 

MSs  are  required  to  establish  a  control  and  catch  monitoring  system  adapted  to  the 
circumstances  and  to  the  legal  framework  already  applicable  to  their  inland  fisheries, 
which must be consistent with the relevant provisions on the fisheries control system. 

The  eel  control  measures  fall  under  the  responsibility  of  different  Ministries  (e.g. 
agriculture  and  fisheries,  environment,  finances)  and  in  case  of  surveillance  activities 
also  under  the  mandate  of  police  and  military  forces.  All  countries  reported  having 
implemented cooperation mechanisms between the different entities in charge of control 
through dedicated steering platforms. 

Analysis based on the targeted consultations on control issues, suggests that control and 
enforcement activities in support of the EMP have taken place in EU waters and in their 
territories, and at  all stages of the eel supply chain. The eel fisheries control have been 
subject to a risk-assessment analysis to identify priorities. A number of MSs identified as 
main risks the illegal fishing in freshwater bodies of eels at all life stages, illegal trade in 
the aquaculture sector, misreporting of catches. 

All  MSs  consulted  have  a  registration  of  professional  fishermen  and  eel  buyers  for 
catches in marine waters or freshwater as considered by Article 10 of the Eel Regulation. 
Catch registration systems have been established. 

However,  control  of  the  eel  fisheries  is  hindered  by  some  shortcomings  in  the  EU 
control system in  relation to control of activities of vessels of less than 10 m that form 
the  bulk  of  the  fleet  targeting  eels  and  in  relation  to  post-landing  documentation  (sales 
notes,  transport  documents).  As  a  result,  traceability  of  eels  is  difficult  to  establish,  in 
particular  when  eels  are  transported  from  a  MS  to  another  to  fulfil  MS  obligations  for 
restocking or to provide livestock for aquaculture farms. Also, the monitoring and control 
of recreational eel fisheries appear largely insufficient. 

According  to  MSs  consulted,  full  traceability  of  eels  is  not  readily  available.  As 
recognised  by  the  Commission  own  evaluation  of  the  EU  Control  System26,  most  MSs 

26 REFIT evaluation, COM/2017/0192 final, SWD/2017/0134 final, COM(2017) 192 final 

29 

 
                                                           
have  not  yet fully implemented traceability system enforced by the Control Regulation 
(Article 58) that is the paper-based and  concern eel caught in marine waters. However, 
eels  caught  or  farmed  in  freshwater  are  not  excluded  from  the  scope  of  the  Control 
Regulation. To note, DK has implemented a “net to plate” electronic traceability system 
but limited to marine species. SE reported having a national electronic traceability system 
from 2019, with reflexions to extend it to freshwater products in a near future.  

Traceability  is  particularly  an  issue  for  live  glass  eels  traded  between  MSs  to  supply 
aquaculture  farms,  for  direct  consumption  or  for  restocking  operations.  MS  authorities 
inspecting  lorries  with  eels  may  encounter  difficulties  to  ascertain  the  validity  of  the 
document presented in case of control. Some MSs indicated relying (or having relied) on 
CITES rules for controlling the legality of eels transported to another MS. 

Nonetheless, certain countries have implemented practices that go beyond the minimum 
EU  requirements.  These  include  more  stringent  conditions  for  monitoring  glass  eel 
catches (FR, UK), use of modern technologies to detect illegal fishing (DK, EE, LT, LV, 
PL, SE), coordination of police forces at national level to fight illegal trafficking of glass 
eels (ES, FR) or support of citizens for reporting suspected infringements (DK, SE, UK, 
and  PL).  Some  countries  (e.g.  EL,  IT  and  SE)  have  used  the  opportunity  provided  by 
Article 8(5) of Council Regulation (EC) N°338/9727 to involve their CITES management 
authorities in the national control system through national instruments (permit scheme in 
EL, CITES registries in IT and SE). Supply chain traceability has increased as a result of 
actions taken at MS level to ensure that legally caught eels are accounted for via statutory 
reporting  as  well  as  through  voluntary  mechanism  such  as  the  Marine  Stewardship 
Council (MSC) or the Sustainable Eel Group (SEG)’s Standard. 

As regards the control of restocking practices, feedback from MSs tends to indicate that 
the  obligations  set  out  in  Article  7  of  the  Eel  Regulation  are  applied  differently.  In 
particular,  Article  7(3)  of  the  Eel  Regulation  requires  MSs  to  establish  an  appropriate 
reporting system to ensure that the 60% glass eels reserved for restocking (in accordance 
with  Article  7(1))  are  used  for  this  purpose.  Arguably,  MSs  implement  such  reporting 
systems  only  for  activities  under  their  competence  (i.e.  for  glass  eels  caught  in  their 
territory and by their vessels used for restocking operations in their territories). For glass 
eels  caught  in  its  territory  but  used  for  restocking  in  another  country,  the  monitoring 
system  implemented  by  the  country  at  the  origin  of  the  glass  eel  catch  covers  only  the 
lots up to the borders but not beyond. 

Finally, the Commission Implementing Decision (EU) 2018/198628 includes for the first 
time  ever  eel  fisheries  in  the  scope  of  Specific  Control  and  Inspection  Programmes 
(SCIPs) to be implemented by MSs under the operational coordination of the European 
Fisheries Control Agency (EFCA). This will further encourage the cooperation between 
MSs and harmonisation of approaches to control. 

27  Article  8.5  provides  that  detaining  eels  or  offering  eels  for  sale  is  prohibited  except  when  it  can  be 
proved that the specimens were acquired in accordance with legislation in force for the conservation of 
wild fauna and flora 

28 Commission Implementing Decision (EU) 2018/1986 of 13 December 2018 establishing specific control 
and inspection programmes for certain fisheries and repealing Implementing Decisions 2012/807/EU, 
2013/328/EU, 2013/305/EU and 2014/156/EU. C/2018/8461OJ L 317, 14.12.2018, p. 29–46 

30 

 
                                                           
As regards the traceability of exported and imported eels, MSs are required under Article 
12 of the Eel Regulation to take all measures necessary to identify the origin and ensure 
the traceability of all live eels imported or exported from their territory  - whether glass 
eels for restocking or yellow and silver eels for human consumption.  However, a zero-
import/export policy was set for the EU in 2010, meaning that it was irrelevant for MS to 
establish  a  traceability  system  for  eels  imported  and  exported  from  their  territory.  MS 
had  to  ensure  that  the  external  trade  prohibition  was  complied  with,  which  for  some 
countries  (e.g.  ES,  FR)  required  substantial  efforts  supported  by  the  involvement  of 
EUROPOL initiatives against environmental crime. 

One  glass  eel  trader  noted  that  “Traceability  is  an  extra  burden  for  legitimate  traders 
whilst the illegal trade is inadequately controlled”. Some in the glass eel trade consider 
that the EU external trade prohibition has actually contributed to illegal exports of glass 
eels  from  the  EU  in  that  it  has  increased  prices  and  reduced  overall  traceability  and 
understanding of eel flows out of the EU. 

One particular issue raised by stakeholders is that the distribution range of European eel 
exceeds  the  borders  of  the  EU  and  consequently  eels  of  different  geographical  origin 
cannot be distinguished by genetics. 

In  general,  there  is  a  need  to  better  harmonise  traceability  systems,  both  within  and 
especially  between  different  MSs,  to  properly  account  for  eel  supply  chain  origin, 
volumes and final fate.  The EU Control Regulation, combined with the IUU Regulation, 
requires traceability for  all species (including eel), but  this is  still far from  an effective 
system.  Its  implementation  needs  considerable  improvement,  including  digitisation  and 
other  methods  of  automated  mass  balance  analyses.  This  therefore  requires  concerted 
efforts both at MS levels as well as at EU level to implement. It should be noted that the 
proposal  for  the  revision  of  the  fisheries  control  system29  addresses  some  shortcomings 
by extending monitoring and reporting requirements to small-scale vessels and reporting 
requirements  to  recreational  fisheries,  and  modernising  the  system  to  record  and  report 
fishing activities that would become fully electronic, irrespective of the vessels' size. 

In  summary,  the  week  traceability  system  from  “net  to  plate”  undermines  the 
effectiveness  of  the  Eel  Regulation  as  regards  measures  concerning  control  and 
traceability.  The  main  weakness  of  the  system  is  not  just  the  varying  ability  and 
willingness of MS authorities to trace and track post-harvest  eel movements but is also 
the lack of an EU-wide traceability system. 

Protection and conservation of aquatic habitats 

  On environmental measures to increase eel recruitment, survival and escapement 

Apart  from  fishing,  other  major  anthropogenic  influences  on  the  eel  stock  include: 
hydropower  turbines/pumps  and  other  physical  obstacles  to  eel  migration;  pollution, 
diseases  and  parasites;  and,  habitat  modification,  all  of  which  are  thought  to  have 
contributed to the decline in eel escapement rates and associated recruitment. 

Non-fisheries  mortality  can  be  reduced  through  various  different  approaches,  e.g. 
improving upstream and downstream migration through removal of barriers and reducing 

29 (COM)2018/368 

31 

 
                                                           
mortality  within  hydroelectric  installations.  The  structural  measures  to  make  rivers 
passable and improve river habitats, together with other environmental measures have the 
potential to make the most profound, long-term impacts on eel stocks. However there is 
little quantifiable evidence in the EMP Progress Reports to assess what actions have been 
taken as a result of the Eel Regulation to make rivers passable and improve river habitats 
or the impact this might have had on spawner escapement rates.  

Actions on habitat improvements  were addressed in EMPs and 2012 progress reports 
of many EMUs. The descriptions of the actions taken, as well as the expected impact on 
escapement  or  mortality  were  often  unspecific,  vague  and  lacking  specific  reference  to 
eel-specific habitats (ICES, 2013c). Most measures on habitat improvement were related 
to  the implementation  of the Water  Framework  Directive  and therefore  not  specifically 
related  to  the  EMP.  Progress  in  implementation  is  often  unclear.  When  actions 
concerning habitat are considered (e.g. by water level fluctuation to flood meadows), the 
effect on silver eel production and escapement would be expected only in the long term, 
while  actions  focused  on  improvement  of  habitat  quality  (e.g.  reduction  of  pollution) 
could  have  an  immediate  effect,  not  only  on  escapement  and  mortality  but  also  on 
migration and reproductive success. To assess the effect of actions taken, monitoring data 
and knowledge are required. 

Nonetheless, there have been some local successes in terms of habitat restoration and 
improved  spawner  connectivity.  Best  practices  for  making  in-river  structures  ‘eel-
friendly’  and  protecting  them  from  hydro-power  intakes  have  been  developed  and 
published in FR and the UK. There have also been attempts to start opening up migration 
routes and developing hydrological regimes that favour eel movement, particularly in FR 
and  IT.  Moreover,  as  noted  by  Hanel  2019,  in  ES  a  decree  was  established  in  2015 
obliging  electricity  companies  to  transport  eels  upstream  of  their  facilities  (Decree 
35/2013).  Many  dams  have  been  removed  and  passes  have  been  installed.  However 
available information does not allow estimating the available habitat increase. 

More details on best practices in eel conservation are presented in Annex 5.3. 

Overall, the evaluation finds that the non-fisheries related anthropogenic mortality, 
whilst variable (can depend upon environmental conditions (flooding vs. drought) at 
the time of the down-stream migration), has not been reduced significantly over the 
last decade. 

EQ3. If the measures for the recovery of European eel stock under the Eel 
Regulation have only partially met the objectives in EQ 2, what factors have 
hindered their achievement and how? 

A number of barriers to eel stock recovery exist: 

1.  Hundreds  of  years  of  modifications  to  water  courses  e.g.  dams,  water 
abstraction  structures  and  other  barriers  are  a  major  cause  of  reduced  spawner 
escapement.    This  is  not  easily  reversed,  as  either  removing  obstructions  or 
putting in mitigation structures e.g. eel passes are costly, often required complex 
permitting  and  are  not  always  necessarily  effective.  This  will  be  a  long-term 
process, and will require continued pressure on both environmental regulators, as 
well as private sector users of water courses to include eel connectivity in forward 
planning and investment. 

32 

 
2.  Continued  loss  of  eel  habitat  through  land  reclamation  and  drainage  of  eel 
holding  waters  –  although  now  usually  subject  to  more  scrutiny  from 
environmental  regulators,  there  is  pressure  in  a  number  of  MSs  to  develop  and 
alter  floodplains  and  water  courses  for  urban,  industrial  and  agriculture 
development. 

3.  IUU fishing for eels, especially juveniles, continues to hold back improvements 
in  recruitment.  Illegal  glass  eel  trafficking  could  account  for  the  mortality  of 
between 20 – 100 tonnes (e.g. up to 300 million individuals30) per annum, mainly 
driven  by  demand  from  Asian  eel  aquaculture.  Stakeholders  suggest  that  this 
trade  is  facilitated  by  austere  conditions  in  rural  coastal  and  estuarine  areas  and 
the potential high financial rewards involved. In many cases glass eels are caught 
in one MS, moved to another and then exported to Asia either directly or possibly 
via a neighbouring non-EU country, such as in North Africa. 

4.  Differing  levels  of  eel  management  through  the  EU.    In  ES,  for  instance,  eel 
management is conducted by the different autonomous regions, where regulations 
and approaches can differ, even within the same EMU. At a wider level, the large 
number  of  organisations  involved  in  fisheries,  water  and  environmental 
management, both  within and between MSs, means that coordination is  a major 
challenge. 

5.  Lack  of 

the 

focus  of 

comprehensive  data:  despite 

Joint 
EIFAAC/ICES/GFCM Working Group on Eel (WGEEL), as well as annual and 
periodic reporting requirements from MSs via the Eel Regulation, data provision 
and knowledge is highly variable across the EU. Total landings and effort data is 
incomplete and inconsistent. Only 75 EMUs (from a total of 116) submitted data 
to  WGEEL  in  2018  on  both  total  fisheries  mortality  rates  and  total  non-fishing 
mortalities  rates.  This  has  consequences  for  the  ability  for  establishing  harvest 
control rules and other eel conservation measures. 

the 

6.  Increased mortality from the recovery of predator populations – the recovery 
of,  or  increase  in,  predators  such  as  the  cormorant  (Hansson  et  al,  2017)  or  the 
silurid  catfish  has  increased  the  rate  of  natural  mortality  in  eel  populations.  
Whilst  a  natural  function  of  a  healthy  ecosystem,  this  may  hinder  recovery  of 
depleted species such as the European eel. 

7.  Limited  uptake  of  funding  available  to  implement  the  Eel  Regulation.  The 
Eel  Regulation  promotes  a  number  of  measures  which  generate  costs  for  public 
authorities  –  such  as  restocking,  monitoring,  and  enforcement  –  and  private 
stakeholders  –  such  as  the  reduction  of  the  fishing  effort.  These  measures  have 
been eligible for support under the European Maritime and Fisheries Fund (2014-
2020) but uptake has been limited. However it is recognised that overall funding 
for eel conservation has increased as a result of the Eel Regulation.  

The  Public  Consultation  results  suggest  that  factors  hindering  effectiveness  of  the  Eel 
Regulation  are  mainly  beyond  the  regulation  itself.  Most  respondents  highlighted 
external  factors,  such  as  inability  to  reduce  hydropower  mortality  or  poaching,  and 
insufficient  implementation  of  the  policy  at  the  national  level.  In  feedback  to  the 
evaluation  roadmap,  hydropower  mortality  and  illegal  fishing  were  also  mentioned,  as 

30 Assuming 3,000 individuals per kg 

33 

 
                                                           
well as the lack of traceability system, insufficient implementation of EMPs and oceanic 
factors. 

EQ4. To what extent has the Eel Regulation contributed to achieving the objectives 
of the Common Fisheries Policy, in particular to ensure that fisheries and 
aquaculture activities are environmentally sustainable in the long-term and are 
managed in a way that is consistent with the objectives of achieving economic, social 
and employment benefits, and of contributing to the availability of food supplies? 

Safeguard stock reproduction for high long-term yield 
The eel recruitment, whilst now stable, is at a historic low level and does not show any 
particular signs of improving.  Stock stabilisation is likely to have been supported by the 
reduction in fishing effort in many MSs but stock recovery  is a long-term goal that can 
only be achieved through addressing spawner escapement through habitat rehabilitation 
and improved connectivity. 

Lay the foundations for a profitable industry 
A glass eel ‘black’ supply chain has implications for both European eel management and 
recovery.  This  also  impacts  legitimate  suppliers  through  price  and  other  market 
distortions.  They  argue  that  controlling  a  limited  external  market  would  reduce  the 
pressure for IUU fisheries and stabilise the market. In EL intensive aquaculture operators 
must give 10%, and extensive aquaculture operators 30% of their purchased glass eels for 
restocking  without  financial  compensation,  which  has  had  repercussions  on  their 
business models. 

Share out fishing opportunities fairly 
The key issue is over legitimate versus IUU fishing.  Legal, licensed fisheries are mainly 
based on traditional, local and gear specific enterprises. Volumes are relatively small and 
transactions  mainly  made  through  the  formal  banking  system  with  a  high  level  of 
transparency.  Glass eel suppliers blame the unquantified but apparently significant black 
trade  as  unfair  competition,  e.g.  not  having  the  costs  of  accountable  businesses,  often 
deal in cash and supply the high value Asian aquaculture market.   

Cooperation and coherent actions at all levels 

The  Eel  Regulation  sets  common  targets  across  the  EU,  however  MSs  take  different 
approaches  in  achieving  those  targets,  as  well  as  in  measuring  stock  indicators  and  in 
reporting. 

An  example  of  cooperation  between  various  stakeholders  is  the  process  of  the 
development  of  multi-stakeholder  platforms  in  the  preparation  of  regional  EMPs  in  IT 
that  involved  all  relevant  operators,  including  fishers,  vallicoltura  farmers  (traditional 
rearing, usually of wild stocked juveniles, in lagoons) and aquaculture operators. 

To  date,  only  one  transboundary  EMP  between  ES  and  PT  for  Minho  River  has  been 
delivered  and  approved  by  the  Commission.  However,  the  eel  management  issues  are 
also  discussed  within 
international  organisations  managing 
transboundary rivers like the International Commission for the Protection of the Rhine or 
similar international organisations managing the Meuse and Scheldt rivers. Nevertheless, 
there are no transboundary EMPs developed between EU MSs and third countries. 

the  framework  of 

34 

 
In the field of control of eel fisheries, all MSs reported having implemented cooperation 
mechanisms between the different entities in charge of control through dedicated steering 
platforms, but no further details have been made available except in the case of FR and 
SE. In FR, a dedicated inter-ministerial task force has been created with the Gendarmerie 
coordinating investigations on environmental crimes (including eel poaching) and acting 
as  focal  point  of  international  police  networks  (Interpol,  Europol).  In  SE,  coordination 
and cooperation between concerned authorities have been improved through exchange of 
information, common risk assessment and clarification of responsibilities of the different 
agencies involved. 

The cooperation between MSs and the harmonisation of approaches to control has been 
further encouraged through the Commission Implementing Decision (EU) 2018/1986. It 
includes  for  the  first  time  ever  eel  fisheries  in  the  scope  of  Specific  Control  and 
Inspection  Programmes  (SCIPs)  to  be  implemented  by  MSs  under  the  operational 
coordination  of  the  European  Fisheries  Control  Agency  (EFCA).  SCIPs  trigger 
cooperation  and  pooling  of  inspection  resources  between  countries  with  the  EFCA 
through  joint  inspection  activities  and  ensure  that  target  benchmarks  for  inspection 
established on the basis of risk-assessments are met. 

The strategic enforcement priorities and increased actions are also implemented by MSs 
both  nationally  and  through  cross-border  joint  actions  against  trafficking  of  eels  under 
the EU Action Plan against Wildlife Trafficking31. 

Cooperation for the fight against illegal eel trafficking is supported by EUROPOL under 
the  EMPACT  ENVICRIME  initiative  (2017-2021).  Joint  operations,  such  as  Europol-
supported Spanish/Portuguese ‘Operations Elvers’ that saw the seizure of 350 kg of glass 
eels  destined  for  China,  demonstrate  how  multi-national,  cross-jurisdictional  control 
operations can work.  

Furthermore,  the  Eel  Regulation  has  stimulated  the  Interreg  Sudoe  Programme  of  the 
European  Regional  Development  Fund  supporting  a  regional  (FR,  PT  and  ES)  project 
(SUDOANG, 2018 – 2021) to provide tools and concerted methods in order to carry out 
an effective evaluation, management and monitoring of the European eel and its habitats.  
To achieve this, an interactive internet application has been created that houses tools to 
enable  Anguilla-related  managers  to  study  indicators  of  population  monitoring  and 
different  possible  management  scenarios.  This  is  intended  to  assist  decision-making 
based on better scientific evidence and in a more coordinated fashion, as all the indicators 
will  be  obtained  using  consensus  models  and  methodologies  among  these  participating 
partners. 

The  evaluation  finds  there  is  a  scope  for  improvement  in  terms  of  the  transboundary 
cooperation in developing EMPs including with third countries. 

Clear interlinkages between EU policies and international instruments 

This will be further addressed below under the ‘coherence’ criterion.  

31 https://ec.europa.eu/environment/cites/trafficking_en.htm  
https://ec.europa.eu/environment/cites/pdf/progress_report_EU_action_plan_wildlife_trafficking_en.pdf  

35 

 
 
                                                           
Opinions  of  the  respondents  to  the  Public  Consultation  on  the  effectiveness  of  the 
current measures for the recovery of European eel stock were mixed. 

Overall, the above analysis of the effectiveness criterion shows that the eel stock has 
not recovered to any degree, recruitment is at an all-time low, non-fisheries related 
anthropogenic mortality has not declined significantly over the last decade and that 
the  40%  escapement  target  has  not  been  achieved.  It  can  therefore  be  concluded 
that the Eel Regulation has not yet proven its effectiveness in reaching its objective 
of  achieving  the  protection  and  sustainable  use  of  the  European  eel  stock  in  EU 
waters that would reflect the recovery of the stock. 

5.2.3.  SUSTAINABILITY 

EQ5. Are the effects likely to last after the intervention ends? 

There  is  no  ‘end  date’  for  the  Eel  Regulation.  Both  the  management  organisations  and 
other stakeholders consider that the Regulation is a sustainable approach that needs to be 
maintained over a long-term. This is because the recovery of the European eel population 
is a long-term process, with some MSs considering 2050 as a reasonable date by which 
the  Regulation’s  target  of  40%  escapement  across  the  EU  might  be  reached.  Once  the 
European  eel  stock  has  fully  recovered,  at  that  point  the  Eel  Regulation  could  be 
reconsidered and a management plan put in place.  In the meantime the regular progress 
reports as required in the Regulation should be continued. 

Reducing commercial fishing activity may have a long-term impact on fishing mortality.  
Licenced fishing activity, especially for yellow and silver eels is likely to continue to fall 
as the elderly fishers drop out of the fishery and many of the traditional markets for eels 
are in decline. However, the risk is that IUU fishing and illegal trade – driven by the high 
price paid in Asia for European glass eels, may have implications for stock recovery and 
thus sustainability of the intervention. One key measure under the Regulation, restocking, 
is questioned and considered as a short to medium term measure that should be phased 
out as natural recruitment and water course connectivity improves. Structural measures to 
make rivers passable and improve river habitats with other environmental measures have 
the potential to make the most profound, long-term impacts on eel stocks. 

Opinions  about  the  sustainability  of  the  effects  of  the  Eel  Regulation  presented  in  the 
Public Consultation were diverse. A slight majority of respondents indicated that effects 
of the intervention would not last after it ended. A significant proportion of respondents, 
about  one  third,  selected  the  “don’t  know”  option  to  this  question.  This  does  not 
necessary  suggest  a  weakness  in  the  sustainability  of  the  intervention,  but  rather 
recognition that it is a long-term process. 

In needs to be also noted here that respondents to the Public Consultation were asked in 
the part relating to the EU Added Value to indicate which consequences they foresaw if 
the  intervention  would  be  withdrawn.  Most  (almost  two  thirds)  referred  to  negative 
consequences, mainly the eel population being more endangered and a risk that MSs will 
no longer implement protective measures. 

The evaluation does not conclude comprehensively on whether the effects of the Eel 
Regulation are likely to endure since the recovery of the eel is a long process. 

36 

 
5.2.4.  EFFICIENCY 

EQ6. To what extent have the costs associated with implementing the Eel 
Regulation been proportionate to the environmental and socio-economic benefits 
that this has generated?  Could the same results have been achieved with less 
funding? 

A monetarised analysis of the cost-benefits of the Eel Regulation is impossible to provide 
at this stage, as MSs do not quantify the direct costs of implementing the Regulation, 
the  responsibility  for  which  is  often  spread  across  a  number  of  different  government 
departments.   

The  direct  environmental  benefits  of  the  EMP  actions  (e.g.  eel  stock  recovery  through 
reduced  fishing  mortality  and  increased  spawner  escapement)  and  the  indirect 
environmental benefits (reconnected coastal, estuarine and riverine ecosystems) are long-
term in nature, still nascent and yet to be fully quantified in terms of their environmental 
benefits.  Likewise  it  is  difficult  to  quantify  the  socio-economic  benefits  of  the  EMP 
measures to date, especially given landings have stabilised and fishing effort has (mainly, 
but not in all Member States) reduced. Only when stock recovery becomes more evident 
and  fishing  opportunities  consolidated  will  the  socio-economic  benefits  become  more 
apparent.    In  addition  there  is  some  evidence  that  the  growth  of  a  parallel  IUU  fishery 
and unregulated supply chain to serve the Asian aquaculture market since the European 
eel was included in the CITES Appendix II and banned by EU MS authorities for extra-
EU export has impacted on the sustainability of traditional, licensed eel fisheries.   

The  synergies  with  the  WFD,  MSFD  and  the  Habitats  Directive  are  also  important 
factors in improving the efficiency of the Eel Regulation. 

Feedback from the MSs on this subject has been limited. Calculating the administrative 
burden  and  associated  costs  is  complex,  especially  where  EMUs  are  managed  at  local 
levels.  Administration  loads  are  also  spread  across  fisheries  management,  fisheries 
control  and  environmental  management  bodies,  which  in  many  cases  operate  under 
separate budgets and planning systems.  In some MSs functions such as restocking may 
be outsourced to the private sector. 

Moreover, it is considered that restocking and translocation of eels, although effective in 
maintaining  or  supporting  eel  populations  in  compromised  river  systems,  is  considered 
an expensive and often administratively burdensome process that has to be paid mainly 
through the EMFF. 

The difficulty to measure cost-effectiveness of the Eel Regulation and its implementation 
at the national level has also been confirmed in the Public consultation. Most respondents 
were not able to assess whether the administration and implementation of the regulation 
had been carried out at the lowest possible cost.  

EQ7. Could the use of other policy instruments or mechanisms have provided better 
cost-effectiveness? 

The main finding of this evaluation is that the Regulation is essentially sound e.g. it has 
enabled  the  EU  MSs  to  develop  and  monitor  EMPs,  and  thus  most  MS  respondents 

37 

 
indicated that alternative approaches have not been considered. However, it is recognised 
that the implementation of many of the measures is a long-term process, and that many 
aspects are still yet to be fully realised. 

EQ8. How timely and efficient is the process for reporting and monitoring? 

In  2012,  18  of  19  countries  with  EMPs  produced  progress  reports.    Only  six  countries 
provided all the stock indicators required by the Eel Regulation, nine reported incomplete 
data and three did not provide any of the required stock indicators. Furthermore, since the 
national  reports  did  not  follow  a  standard  format,  the  level  of  detail  of  the  reporting 
differed  significantly,  and  reports  were  written  in  a  range  of  languages.  This  made  the 
assessment of the reports a challenging exercise. 

In 2015, 14 of the 19 MS submitted progress reports32. 

In  April  2018,  the  Commission  facilitated  MS  reporting  and  assessment  to  make  those 
more efficient by providing seven Excel templates developed with ICES, as regards the 
overview of stock indicators by EMU, biomass indicators, mortality quantities, mortality 
rates,  stocking,  management  measures  and  fishing  effort.  The  completion  of  these 
templates was highly recommended but not compulsory. Overall, reporting by MSs was 
not complete. Of those MSs with EMPs; LU and PT did not report at all, the CZ, FI and 
IE  provided  a  description  but  no  data  tables,  and  FR  and  PL  did  not  provide  all  seven 
data tables; the CZ, FI, EL, IE, LV, PL and ES reported after the deadline. 

Moreover, since the first reporting round in 2012, no MS reports on glass eel prices have 
been  submitted  to  the  Commission,  although  BE,  DK,  EE  and  the  UK  have  provided 
some  price  data  in  their  2018  progress  reports.  This  represents  a  major  failure  in  the 
Regulation’s monitoring requirement. 

Based  on  partial  analysis  of 
the  2018  progress  reports,  ICES  made  several 
recommendations (ICES 2018d) on the reporting format and content suggesting to make 
them  obligatory  and  highlighted  that  it  would  reduce  the  burden  on  MSs  if  reporting 
requests from the Commission, ICES and other could be coordinated and combined. 

Overall,  the  evaluation  finds  it  difficult  to  provide  for  the  monetarised  analysis  of 
the  cost-benefits  of  the  Eel  Regulation  at  this  stage.  It  also  finds  that  progress 
reporting on the implementation of the EMP by MS needs improvement to be more 
harmonised and robust. 

5.2.5.  COHERENCE 

EQ9. To what extent are the measures for recovery of the European eel stock under 
the Eel Regulation coherent with wider policy and interventions which have similar 
objectives (e.g. Common Fisheries Policy, fisheries control regulation, 
environmental legislation and in particular Water Framework Directive)? 

The  assessment  of  the  coherence  criterion  presented  below  is  based  on  the  desk 
research/study and some stakeholder consultations, unless otherwise stated. 

32 HR, CZ, EE, LU and ES failed to report. 

38 

 
                                                           
FISHERIES LEGISLATION 

The Common Fisheries Policy33 (CFP) aims to ensure that fishing and aquaculture are 
environmentally, economically and socially sustainable and that they provide a source of 
healthy food for EU citizens. Its goal is to foster a dynamic fishing industry and ensure a 
fair  standard  of  living  for  fishing  communities.  The  scope  of  the  CFP  includes  the 
conservation  of  marine  biological  resources  and  the  management  of  fisheries  targeting 
them.  In  addition,  it includes, in  relation  to  market  measures  and financial  measures in 
support  of  its  objectives,  fresh  water  biological  resources  and  aquaculture  activities,  as 
well  as  the  processing  and  marketing  of  fishery  and  aquaculture  products,  where  such 
activities  take  place  on  the  territory  of  MS  or  in  Union  waters.  A  key  objective  of  the 
CFP reform in 2013 is to restore or maintain fish stocks at levels that support maximum 
sustainable yield (MSY) by 2020 at the latest. Therefore, the CFP and its MSY objective 
is applicable to the European eel at certain stages in its life cycle. 

The  Eel  Regulation  (2007),  which  precedes  the  reformed  CFP  (2013),  includes  the 
management of the European eels in marine, transitional and fresh waters, and considers 
both  the  impact  of  fisheries  and  the  impact  of  environmental  modifications.  The 
Regulation sets an escapement biomass target of 40% of the spawning biomass, which is 
considered a proxy for MSY. There are however considerable difficulties in applying the 
MSY approach to catadromous species such as the European eel. 

its  primary  focus  on  managing 

The  Eel  Regulation  has 
the  fisheries-related 
anthropogenic  mortality,  mainly  through  increasing  escapement  rates  and  reducing 
fishing mortality. It however fully recognises the role of MS in implementing measures 
“as  soon  as  possible  to  reduce  the  eel  mortality  caused  by  factors  outside  the  fishery, 
including hydroelectric turbines, pumps or predators” (Article 2 (10)). This immediately 
introduced the need for coherence with other EU policies and regulations. 

Fishing Opportunities 

Council  Regulation  (EU)  2018/120  fixed  for  2018  the  fishing  opportunities  for  certain 
fish stocks and groups of fish stocks, applicable in Union waters and, for Union fishing 
vessels, in certain non-Union waters, mainly in form of species-specific Total Allowable 
Catches (TACs) and quotas. Article 10 of this Regulation prohibits EU fishing vessels to 
fish European eel in marine waters of an overall length of 12cm or longer in EU waters 
of the  ICES  area for a consecutive three-month period to  protect  spawners during their 
migrations.  The  three-month  time  period  was  determined  by  each  MS  between  1 
September  2018  and  31  January  2019.  The  fishing  closure  is  relevant  to  spawning 
biomass  of  eels,  so  works  cohesively  with  the  40%  escapement  target  set  in  the  Eel 
Regulation. 

Council  Regulation  (EU)  2019/124  fixing  the  fishing  opportunities  for  2019  extended 
this  approach  by  creating  a  consecutive  three-month  closure  period  for  all  fisheries  of 
European eel at all life stages in relevant Union waters (including brackish waters such as 
estuaries, coastal lagoons and transitional waters). It was designed to be consistent with 
the conservation objectives set out in the Eel Regulation and with the temporal migration 
patterns of European eel (to be applied over the period between 1 August  2019 and 29 
February  2020  for  ICES  waters,  and  at  a  period  to  be  determined  by  each  MS  in  the 

33 Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on 

the Common Fisheries Policy 

39 

 
                                                           
Mediterranean).  For  the  Mediterranean,  it  transposes  into  the  EU  law  the  GFCM 
Recommendation GFCM/42/2018/1 establishing management measures for European eel 
in the Mediterranean Sea. 

Data collection framework 

Regulation (EU) 2017/1004 of the European Parliament and of the Council establishes an 
EU framework for the collection, management and use of data in the fisheries sector and 
support  for  scientific  advice  regarding  the  CFP.    This  EU  data  collection  framework 
(DCF)  is  applicable  to  eels  and  covers  inland  waters,  specifically  establishing  a 
programme for the collection of biological data on all stocks caught or by-caught in EU 
commercial  and,  where  appropriate,  recreational  fisheries  in  and  outside  EU  waters, 
including eels. 

Data on eels from the EU DCF may be useful for stock assessment purposes but does not 
cover  fishery  independent  sampling  or  non-fisheries  related  eel  mortality.  ICES  (2018) 
noted  that  eel  data  sourced  from  landing  statistics  has  improved  in  2017  and  2018  but 
remains incomplete and the level of reporting between MSs is inconsistent. 

Fisheries control system 

For  fishing  and  aquaculture  activities,  control  and  enforcement  of  eel  conservation 
measures  are  part  of  the  measures  considered  under  the  EU  fisheries  control  system, 
which  is  based  on  four  regulations:  the  Control  Regulation,  the  IUU  Regulation,  the 
EFCA  Founding  Regulation34  and  the  SMEFF  Regulation  for  activities  of  the  EU 
external  fleet35.  The  Control  Regulation  (Regulation  (EC)  No  1224/2009)  is  the  main 
piece of EU legislation applicable in the case of the eel fisheries. This Regulation applies 
primarily to activities covered by the CFP carried out on the territory of MSs or in Union 
waters or by Union fishing vessels, the latter being defined by the CFP Regulation as any 
vessel equipped for commercial exploitation of marine biological resources. The Control 
Regulation defines a number of rules that apply to monitoring, control and surveillance 
of  fisheries  targeting  diadromous  species  during  their  marine  phase,  and  to  fresh  water 
fisheries,  aquaculture,  processing  and  marketing  of  diadromous  species  in  relation  to 
market and financial measures supported by the CFP. 

For access to the resource, the Control Regulation requires fishing vessels to hold valid 
licences delivered by their MSs to engage in commercial fishing (in marine waters). The 
partial coverage of the Control Regulation in terms of fishing authorisations (potentially 
applicable only to vessels of more than 10 m fishing in marine waters in the case of eel 
fisheries)  is  compensated  by  Article  11  of  the  Eel  Regulation  which  requires  MSs  to 
establish  lists  of  vessels  authorised  to  fish  eels  in  marine  waters  irrespective  of  their 
length, lists of fishing vessels, commercial entities or fishermen authorised to fish eels in 
designated EMUs, and list of entities authorised to undertake the marketing of eels. 

The obligations set out by the Control Regulation for control of fisheries (Title IV, Art. 
14  to  Art.  55)  apply  basically  to  fishing  activities  conducted  from  a  vessel  in  marine 
waters. However, the Eel Regulation provides that MSs shall establish a control system 
adapted  to  circumstances  and  to  the  legal  framework  already  applicable  to  their  inland 
fisheries,  which  shall  be  consistent  with  relevant  provisions  set  out  in  the  Control 

34  Regulation (EU) 2019/473 

35 Regulation (EU) 2017/2403 

40 

 
                                                           
Regulation.  For  small  scale  vessels  of  less  than  10  m  that  form  the  bulk  of  the  fishing 
fleet  targeting  eels  (often  glass  eels),  the  Control  Regulation  includes  numerous 
exemptions in relation to monitoring (logbooks, prior notifications, VMS), and leave to 
the MS to monitor the fisheries on the basis of sampling plans or alternative measures as 
appropriate.  Concerning  recreational  fisheries,  the  Control  Regulation  requires  MSs  to 
monitor eel  catches  by  vessels (excluding  fishing  from  shore) on the basis of sampling 
plans under an overarching objective of ensuring that recreational fisheries are conducted 
in  a  manner  compatible  with  the  CFP.  However,  Article  11  of  the  Eel  Regulation 
includes requirements for MSs to establish on a regular basis an estimate of the number 
of recreational fishermen and their catches of eels, which is rather vague (“regular basis”, 
“estimate”). 

Concerning control of marketing (Title V), the Control Regulation applies to marketing 
of  fisheries  and  aquaculture  products,  from  first  sale  to  retail,  including  transport.  The 
Control  Regulation  imposes  traceability  from  net  to  plate  (art.  58)  that  do  not  apply  to 
products  (incl.  eels)  caught  or  farmed  in  freshwater.  However,  the  Regulation  on  the 
common  organisation  of  the  markets  in  fishery  and  aquaculture  products  (Regulation 
(EU) No 1379/2013) applies to those products.  

Eels  caught  by  professional  fishermen  are  subject  to  submission  of  sales  notes  by 
registered  buyers,  mandatory  weighing  and  take-over  declarations  if  the  products  are 
intended for sale at later stages, which may be the case of eels stocked alive. In the event 
eels  are  transported  before  first  sale  more  than  20  km  away  from  the  landing  site,  a 
transport document is required. However, all post-landing documentation required by the 
Control  Regulation  (i.e.  sales  notes,  take-over  declaration  and  transport  documents)  do 
not specify the use of the products which in the case of eels may include consumption, 
possibly after ranching, or restocking, also possibly after ranching.  

The traceability systems set up by MSs under the Control Regulation concern eel caught 
in  marine waters.    However eels  caught  or farmed in  freshwater are not  excluded from 
the scope of the Control Regulation. 

Until  2018,  eel  fisheries  were  not  included  in  the  scope  of  the  Specific  Control  and 
Inspection  Programmes  (SCIPs)  adopted  by  the  Commission  as  foreseen  by  Art.  95  of 
the Control Regulation. The situation changed recently with the adoption of Commission 
Implementing Decision (EU) 2018/1986 applying as from 2019 which included fisheries 
exploiting eels in Union waters of the Mediterranean, of the Baltic Sea, of the North Sea 
and ICES division IIa, and of Western Waters (ICES areas VI, VII, VIII and IX). SCIPs 
trigger  cooperation  and  pooling  of  inspection  resources  between  MSs  with  the  EFCA 
assuring operational coordination of joint inspection activities in this frame. 

European Maritime and Fisheries Fund 

Regulation  (EU)  508/2014  of  the  European  Parliament  and  of  the  Council  of  15  May 
2014 establishes the European Maritime and Fisheries Fund (EMFF).  The EMFF does 
not  refer  specifically  to  eel  recovery  or  the  Eel  Regulation  but  initiatives  for 
implementing  the  Eel  Regulation  can  be  supported  (e.g.  via  Article  37(2)  on  direct 
restocking and Article 54 on aquaculture providing environmental services).   

The  Fisheries  and  Aquaculture  Monitoring  and  Evaluation  (FAME)  Support  Unit  (SU) 
reported  that  by  the  end  of  2017,  87  operations36  were  funded  through  the  EMFF  with 

36 Operation funded under Articles 37 and 54 and reviewed as to whether the title mentions ‘eel’ 

41 

 
                                                           
total  eligible costs of EUR 18.6 million  and the EMFF  allocation of EUR 11.1 million 
(EC,  2018a).  DE  alone  approved  71  operations  with  the  EMFF  budget  of  EUR  5.2 
million, with the CZ approving nine operations.  Overall, eight MSs implemented related 
operations,  dedicating  1.8  %  of  their  EMFF  to  this  area.    Six  MSs  indicated  that  eel 
recovery  is  a  priority  of  the  EMFF  programme  (CZ,  DE,  DK,  NL,  PL,  SE).  The 
Managing  Authorities  (MAs)  support  different  types  of  operations:  restocking,  habitat 
recovery,  data  collection,  studies  and  temporary  cessation  of  fishing  activities.  Some 
MSs indicated that they  also  intend to  support eel-related operations in  the future;  they 
also stressed that this depends on the interest of beneficiaries, the EMFF being a demand-
driven programme.  FAME noted that (i) the EMPs and the tri-annual reports give little 
attention to the budgetary implications of the proposed plans, with only a few countries 
referring  specifically  to  the  use  of  EU  structural  funds  and  (ii)  whilst  some  EMFF 
Operational  Programmes  (OPs)  mention  eel,  either  in  relation  to  EMP  or  to  data 
collection, many OPs do not mention eel at all.    

In the previous European Fisheries Fund (EFF) for 2007-2013 period, the funding related 
to eel management represented well below 1% of the total EFF OP allocation, with most 
commonly  applied  eel-specific  measures  contributing  to  the  implementation  of  the  Eel 
Regulation being permanent and temporary cessation as well as restocking (EC, 2019a).  
A review of the EFF Annual Implementation Reports (AIR) showed that only FR, IT, ES 
and DE provided financial information on eel-related measures. 

ENVIROMENTAL LEGISLATION 

Imports and export of eels 

Import  and  export  refer  to  movements  of  eels  of  any  stage  between  the  EU  and  third 
countries.  

European eel is listed in Annex B of Council Regulation (EC) N°338/97 Wildlife Trade 
Regulation, transposing CITES decisions to the EU law. In 2010, and every year since 
then, the relevant Scientific Authorities of the EU MSs agreed that eels cannot be taken 
from  the  wild  in  a  sustainable  way.  The  EU  Scientific  Review  Group  was  not  able  to 
issue a “non-detriment finding”. Hence it has not been allowed to issue import and export 
permits for European eel to and from the EU, meaning that import and export of eels is 
prohibited. Therefore, up until now, prescriptions of Article 12 of the Eel Regulation for 
control and enforcement concerning import and export of eel could not apply. MSs had to 
ensure  that  the  import  /  export  prohibition  was  effectively  enforced.  Import  and  export 
considered by the Eel Regulation do not refer to movements of eels between the EU MSs 
which are based on the principle of free circulation of goods, one of the pillars of the EU 
single market. Therefore, intra-EU trade of eels is fully legal. 

Furthermore,  the  Eel  Regulation  specifically  mentions  the  Habitats  Directive37  and  the 
Water Framework Directive38 as key precursors and supporting legislation. 

37 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna 

and flora 

38  Directive    2000/60/EC    of    the    European    Parliament    and    of    the    Council  of    23    October    2000 

establishing  a  framework  for  Community  action  in  the  field  of  water  policy 

42 

 
 
 
                                                           
Habitats Directive 

The  Habitats  Directive  was  adopted  to  ensure  the  protection  of  endangered  and/or 
vulnerable  animals,  plants  and  characteristic  habitats.  It  provides  for  two  eel-related 
habitat types - estuaries and coastal lagoons - to be protected and designated as Special 
Areas  of  Conservation  (SAC).  This  designation  requires  MS  to  establish  conservation 
measures which correspond to the ecological requirements of these Annex I habitats and 
to take appropriate steps to avoid their deterioration.  However, European eel (Anguilla 
anguilla),  which  is  assessed  by  IUCN  as  critically  endangered,  is  not  listed  under  the 
Habitats Directive’ species Annexes. 

Water Framework Directive 

As  regards  the  Water  Framework  Directive  (WFD),  the  Eel  Management  Units 
(EMUs)  as  defined  by  EU  MSs,  often  follow  the  spatial  management  model  of  River 
Basin Districts (RBD), as introduced by the WFD. This alignment of spatial EMUs and 
RBDs  provides  opportunity  for  clear  interlinkages  between  the  management  measures 
required to improve eel stocks and ecological status within water bodies. 

The WFD serves to ensure the ‘good status’ of eel aquatic habitat in coastal, transitional 
and  inland  surface  waters  across  a  range  of  ecological  and  chemical  quality  indicators. 
Interestingly,  the  concentrations  of  some  pollutants  measured  in  European  eel  have  in 
some  MSs  been  taken  into  account  in  the  assessment  of  the  chemical  status  of  water 
bodies  under  the  WFD.  However,  it  should  be  noted  that  since  2010  MSs  have  been 
advised  that  because  of  their  endangered  status,  eels  should  only  be  used  for  existing 
trend-monitoring  programmes39.  WFD  is  also  important  in  improving  river  continuity, 
which should benefit eel migration. However, significant effort is required to meet good 
ecological  and  chemical  status  across  European  surface  waters  as  only  40%  of  surface 
water  bodies  are  in  good  ecological  status,  and  38%  of  surface  waters  are  in  good 
chemical  status.  Moreover,  40%  of  surface  water  bodies  are  affected  by  hydro-
morphological pressure (EEA, 2018).  

Furthermore, only a few MS EMPs/Progress Reports make reference to the importance of 
the WFD in improving water quality and connectivity (e.g. BE, ES, IE), and where this 
occurs, targets for improvement and expected benefits to eels are not defined.  

While interlinkages between EMPs and WFD in the objectives (improve river continuity 
and restore eel population) are clear, this is not a case in the delivery and implementation 
of  measures  or  monitoring  of  outcomes.  Moreover,  the  authorities  responsible  for  the 
EMP are not necessarily involved in the implementation for the River Basin Management 
Plans  (RBMPs)  under  the  WFD.  Thus,  there  is  scope  to  improve  connectivity  between 
RBMP and EMPs, and the authorities tasked with their delivery, including harmonisation 
and prioritisation of measures, specifically around hydro-morphological pressures. 

Marine Strategy Framework Directive  

Then, other environmental management instrument of importance for eels is the Marine 
Strategy Framework Directive40 (MSFD) that came into force in 2008, a year after the 

39  Guidance  No  25  -  Chemical  Monitoring  of  Sediment  and  Biota,  Technical  Report  -  2010  –  041: 
https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa7-9964bbe8312d/library/7f47ccd9-ce47-
4f4a-b4f0-cc61db518b1c/details 

40 Directive 2008/56/EC of 17 June 2008 

43 

 
                                                           
Eel Regulation. The MSFD aims to achieve or maintain the good environmental status41 
of marine waters by 2020 by adopting an ecosystem-based approach to management that 
is implemented through common regional approaches. 

Based  on  the  good  environmental  status  descriptors,  MSs  have  developed  GES 
definitions and targets that are of relevance to their marine environment.   In relation to 
eels,  the  MSFD  is  important  to  reaching  and  maintaining  good  environmental  status  of 
the  marine  environment,  which  (as  with  the  WFD),  may  have  a  positive  effect  on  the 
reproductive potential of silver eel (ICES, 2018). 

EQ10. To what extent are the measures under the Eel Regulation coherent with 
international obligations (e.g. under CITES and CMS)? 

United Nations Convention on the Law of the Sea 

The  United  Nations  Convention  on  the  Law  of  the  Sea  (UNCLOS,  1982),  Article  67 
relates  to  catadromous  species  (including  European  eel)  with  the  following  rules 
applicable to UN member states, including EU: 

  Coastal  states/countries  are  responsible  for  management,  but  also  states  through 
the territory of which the species migrate are responsible for binding agreements 
concerning management measures.  

  Fishing  at  sea  is  allowed  within  the  Exclusive  Economic  Zones  (EEZ)  but 

prohibited in the high seas.  

  Management must include provisions for secured immigration and emigration of 

the species. 

General Fisheries Commission for the Mediterranean 

The  General  Fisheries  Commission  for  the  Mediterranean  (GFCM)  has  adopted  the 
Recommendation  GFCM/42/2018/1  establishing  a  multi-annual  management  plan  for 
European  eels  in  the  Mediterranean  Sea  (GFCM,  2018).    This  included  targeted, 
incidental  and  recreational  catches,  as  well  as  taking  into  account  in  their  management 
measures “other anthropogenic mortalities factors in order to reduce their impact on eels 
and  increase  their  probability  of  the  escapement  to  the  sea,  as  well  as  including 
restocking or translocation practices” through both short-term transitional precautionary 
management  measures  as  well  as  long-term  measures.    This  is  in  line  with  the  Eel 
Regulation.  

Furthermore,  the  GFCM  adopted  a  research  programme  in  2019  aiming  at  providing  a 
comprehensive state of play of the status of the stock in the Mediterranean, reviewing the 
national management measures adopted by the riparian countries and propose long-term 
management  measures.  A  working  group  was  established  to  examine  the  results  of  the 

41  The  Good  Environmental  Status  (GES)  descriptors  (Annex  I  of  MSFD):  1.Biodiversity  is  maintained; 
2.Non-indigenous species do not adversely alter the ecosystem; 3.The populations of commercial fish 
species are healthy; 4.Elements  of  food  webs  ensure  long-term  abundance  and  reproduction; 
5.Eutrophication  is  minimised,  6.Sea  floor  integrity  ensures  the  functioning  of  the  ecosystem; 
7.Permanent  alteration  of  hydrographical  conditions  does  not  adversely  affect  the  ecosystem; 
8.Concentrations  of  contaminants  have  no  effects;  9.Contaminants  in  seafood  are  within  safe  levels; 
10.Marine litter does not cause harm; 11.Introduction of energy (including underwater noise) does not 
adversely affect the ecosystem. 

44 

 
                                                           
research programme  and propose additional long-term  management measures  for eel  in 
the Mediterranean. 

Convention on International Trade in Endangered Species of Wild Fauna and Flora 
(CITES) 

CITES42  is  an  international  agreement  between  governments,  which  ensures  that 
international  trade  in  specimens  of  wild  animals  and  plants  does  not  threaten  their 
survival. European  eel  was  CITES-listed  at  the  14th  Conference  of  the  Parties  to  
CITES   in   June  2007,   with   an   18-month  delay   before implementation so that the 
listing came into effect on 13 March 2009. The listing was implemented in the EU by the 
inclusion  of  European  eel  in  Annex  B  of  Council  Regulation  (EC)  No  338/97,  which 
generally corresponds to the CITES Appendix II.  

Appendix  II  of  CITES  is  for  “species  which  although  not  necessarily  now  threatened 
with  extinction  may  become  so  unless  trade  in  specimens  of  such  species  is  subject  to 
strict regulation in order to avoid utilization incompatible with their survival”.  Trade is 
defined in CITES as “export, re-export, import and introduction from the sea”. In other 
words,  CITES  only  controls  trade  across  international  borders  and  does  not  have 
implications for trade within countries or, in this instance, the EU. This is a critical point, 
as full traceability across EU borders is essential. CITES regulates trade through a system 
of permits, requiring export permits for trade in CITES Appendix II specimens.  

Convention on the Conservation of Migratory Species of Wild Animals (CMS) 

In  2014,  the  European  eel  was  added  to  Appendix  II  of  the  Convention  on  Migratory 
Species (CMS), also known as the Bonn Convention43. According to Article IV of CMS, 
Parties are encouraged to take action with a view to concluding agreements concerning 
these  species.  Such  international  cooperation  would  be  beneficial  for  the  conservation 
status of those species.  Not all species listed in  Appendix II are necessarily covered by 
agreements. There are also other possibilities such as non-legally binding memoranda of 
understanding, species action plans, and cooperative actions. It is to be noted that for the 
European eel the CMS Parties cover almost the entire distribution of European eel Range 
States (with the exception of Iceland, Turkey and Russia). 

International Union for the Conservation of Nature (IUCN) 

The IUCN was created in 1948 as a ‘membership Union’ composed of both government 
and  civil  society  organisations  and  provides  information  and  policy  advice  on 
conservation issues.  The IUCN ‘Red List of Threatened Species’44 (known widely as the 
‘Red List’), established in 1964, is a widely respected database that provides information 
on species populations and their trends, their habitats and ecology and the main threats to 
their survival. In 2008, and again in 2014, the European eel was listed in IUCN Red List 
as critically endangered. This listing will be reviewed in at the next IUCN assessment of 
the European eel. 

42 https://www.cites.org/  

43 https://www.cms.int/  

44 https://www.iucnredlist.org/  

45 

 
 
                                                           
Convention on Wetlands 

In addition, the evaluation finds a linkage with the Ramsar Convention on Wetlands of 
International  Importance45  (also  known  as  the  Convention  on  Wetlands),  the 
international treaty for the conservation and sustainable use of wetlands. The overarching 
objectives  of  the  Convention  are  to  stem  the  loss  and  progressive  encroachment  on 
wetlands  -  a  key  European  eel  habitat  -  now  and  in  the  future.  Most  EU  MSs  are 
Contracting Parties. Hence, the wetlands protected under this Convention will benefit eel 
population. 

The summary of the linkages is presented in Annex 7. 

No issues of incoherence were identified during the targeted stakeholder consultation. 

In  contrast,  the  Public  Consultation  results  may  suggest  that  there  is  an  issue  with 
coherence of the Eel Regulation, in particular with international instruments to regulate 
fisheries.  In  contributions  to  an  open-ended  question,  some  respondents  referred  to 
inconsistencies  within  Common  Fisheries  Policy  (MSY  principle),  Water  Framework 
Directive  not  applicable  to  eels,  Habitats  Directive,  or  other  issues  (e.g.  ban  of  export 
leading to illegal trade, protecting predators within environmental policy etc.). However, 
many  respondents  indicated  that  they  “neither  agreed  or  disagreed”  or  “did  not  know”. 
This shows it was difficult for them to assess the coherence of the Regulation. 

Based  on  the  above  analysis,  it  can  be  concluded  that  the  Eel  Regulation  is 
essentially  coherent  with  a  number  of  fisheries  and  environmental  legislation,  and 
with  wider  international  agreements  and  initiatives.  However,  it  is  noted  that 
significant efforts are required to fully restore river continuity and there is scope to 
improve  synergies  between  RBMP  under  the  WFD  and  EMPs  under  the  Eel 
Regulation.  

5.2.6.  EU ADDED VALUE 

EQ 11. What is the additional value resulting from the EU measures for the 
recovery of European eel stock under the Eel Regulation, compared to what could 
reasonably have been expected from Member States acting at national and / or 
regional levels? 

The Eel  Regulation  requires MSs to  address  common  objectives and uniform  reference 
points.  The  design  and  implementation  of  protective  actions  and  monitoring  were 
delegated to MSs. 

The key additional inputs / support provided by the Eel Regulation include: 

  The preparation of EMP for 19 MSs.  
  Establishment  of  common  targets  e.g.  40%  escapement  of  silver  eel  biomass 
relative  to  the  best  estimate  of  escapement  that  would  have  existed  if  no 
anthropogenic influences had impacted the stock.   

  Benchmarking of the present situation of eel populations in each river basin. 

45 https://www.ramsar.org/  

46 

 
                                                           
  Development  of  management  measures  based  around  eight  different 

approaches (see Art. 2 (8) with associated timescales).   

  Development  of  transboundary  EMP  with  both  other  MSs  as  well  as  with 
relevant third countries.  However, to date only one transboundary EMP (between 
ES and PT) has been prepared and adopted by the Commission.   

  Mandatory restocking targets for eels  <12 cm caught in EU fisheries (60% to 

be achieved by 2013).   

  Reduction in fishing effort by 50%. 
  Establishment  of  control  and  enforcement  (including  catch  monitoring) 

mechanisms. 

  Requirement  to  collect  data  on  eel  biomass  estimates,  mortality  rates,  fishing 

effort and stocking rates for analysis by the Commission and its partners. 

In addition to these direct functions, the Eel Regulation has catalysed the development of 
eel  conservation  and  management  legislation  in  MSs.    It  has  also  brought  managers 
together  from  different  regions  and  organisations  within  MS  to  develop  the  plans  and 
associated measures.  For instance, the EMP development process in IT has been highly 
participatory and has resulted in some comprehensive documents on best practises from 
the UK and ES.  The role of the Joint EIFAAC/ICES Working Group on Eels (WGEEL) 
has been considerably enabled by the Eel Regulation and its data reporting requirements. 

The Eel Regulation has also stimulated other EU-funded actions to support the recovery 
of  the  European  eel.  One  such  example  is  SUDOANG  project,  which  started  in  March 
2018  that  aims  to  provide  managers  with  tools  and  joint  methods  that  support  the 
conservation of the European eel and its habitat in the South-West Europe (SUDOE) area 
and is  being funded under the priority axis  “Protecting the  environment  and promoting 
resource efficiency” of the Interreg SUDOE programme.  SUDOANG supports a number 
of  task  groups  building  various  models  to  estimate  barrier-related  mortality,  eel 
recruitment in the SUDOE region, escapement and also investigates various government 
platforms.    Other  EU-funded  projects  include  AMBER  (citizen-mapping  of  barriers  in 
European rivers), the Interreg IIIB Atlantic area Project Indicang (establishing abundance 
indicators) and POSE (a DG MARE service contract to estimate the escapement of silver 
eels (see Walker et al., 2011). 

Furthermore,  the  Regulation  has  raised  awareness  of  the  need  for  conserving  and 
managing European eel throughout its range. 

It needs to be noted that it is difficult to systematically isolate the results and outcomes 
that  could  or  would  not  have  been  otherwise  achieved  without  the  Eel  Regulation, 
especially given its close relationship with other EU initiatives (especially the WFD) and 
the  CITES  listing.    In  particular,  isolating  the  outcomes  of  measures  implemented  via 
WFD  specifically  for  individual  species  (i.e.  eel)  is  challenging  and  currently  not 
documented within progress assessments for River Basin Management cycles. 

EQ12. What would be the most likely consequences of stopping the application of 
the measures as required in the Eel Regulation? 

The MS authorities contacted over this evaluation stressed the fact that the objectives of 
the  Regulation  can  only  be  achieved  over  the  long-term  (e.g.  50  years  or  more)  and 

47 

 
therefore  consider  this  to  be  a  permanent  process  that  needs  to  be  continued  to  be 
effective. 

The  impact  of  one  or  more  MSs  stopping  to  apply  the  measures  from  the  Regulation 
depends  on  which  one  and  their  territory’s  particular  contribution  to  the  European  eel 
stock.  For instance, FR is a key participant due to the importance of the Bay of Biscay in 
terms  of  glass  eel  flows  and  spawner  escapement  and  thus  has  a  significant  role  in  the 
conservation and management of this single stock. 

At present, the only major change in the MS participation in the Regulation would be that 
of  the  UK  in  the  event  of  their  withdrawal  from  the  EU.  The  UK’s  Department  for 
Environment, Food and Rural Affairs (Defra) have confirmed that, as with other relevant 
EU legislation, the Eel Regulation will be rolled over into UK legislation within the UK 
Withdrawal  Act  (Defra,  pers.  comm.,  16  January  2019  to  the  external  study).  This 
confirmation suggests that the provisions, measures and activities would be continued in 
the UK as in the EU. Progress reporting under the Regulation to the Commission is likely 
to be discontinued.  

Under  the  scenario  of  the  UK  withdrawal,  and  to  ensure  comprehensive  and  quality 
scientific advice it would be key that the UK continues to contribute to the work of the 
Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL), including responding to 
any related data calls that the group may make.  Trade of glass eels between the UK and 
the EU may no longer be allowed. 

Most  of  respondents  to  the  Public  Consultation  (almost  two  thirds)  being  asked  to 
indicate  which  consequences  they  foresaw  if  the  intervention  would  be  withdrawn, 
referred to negative consequences, mainly the eel population being more endangered and 
a risk that MSs will no longer implement protective measures. 

Overall, it is  clear that the Eel  Regulation provided added value to what could be 
achieved  by  MSs  at  the  national  or  regional  levels  in  terms  of  recovering  the  eel 
population.  It  was  also  confirmed  by  the  vast  majority  of  the  respondents  to  the 
Public Consultation. 

6.  CONCLUSIONS 

This section summarises the main conclusions of the evaluation. 

Relevance 

As confirmed by the scientific advice, the status of the European  eel  remains ‘critical’. 
The  stock  is  in  decline,  despite  significant  re-stocking  efforts.  The  recruitment  is  at  an 
all-time low and exploitation of the stock is currently unsustainable. 

Therefore,  the  Eel  Regulation  is  still  relevant  and  basically  fit  for  purpose  as  an 
instrument to help the European eel stock to recover. It ensures that management can be 
applied at all eel life stages and allows to address both fisheries and non-fisheries related 
anthropogenic impacts. 

Effectiveness 

In terms of ensuring the recovery of the European eel, the Regulation’s effectiveness is 
still far from certain. However, it is widely recognised that the recovery of the European 
eel will take many decades, given the long life-span of the species. 

48 

 
The Eel Regulation has been effective in that the key EU MSs with natural eel habitats 
have  developed  comprehensive  EMPs.  However,  the  escapement  levels  are  still  well 
below the  general  objective of the Regulation  of at  least  40% of the silver eel  biomass 
that would have existed if no anthropogenic influence had impacted the stock.  

Whilst restocking is a measure that features in many EMPs, only six achieved their EMP 
stocking target.  Whilst  in 2013 a lack of funding constrained restocking, the increasing 
cost  of  glass  eel  is  a  more  recent  issue.  The  long-term  use  of  restocking  as  a  key 
conservation measure is questioned. It seems more a short term emergency measure until 
greater  natural  migration  in  freshwater  is  possible,  given  its  uncertain  contribution  to 
spawner  escapement  and  subsequent  recruitment,  as  well  as  the  risks  involved  (e.g. 
disease introduction, as well as mortality from poor handling). 

The target of reducing fishing effort by at least 50% has met some success. Fishing effort 
has declined in SE, IT, DK, FR and DE.  However, effort appears to have risen in the UK 
and PL.   

The control of eel fisheries is hindered by some shortcoming of the EU control system in 
relation to monitoring and control tools for fishing vessels of less than 10 m. The intra-
EU  trade,  including  that  of  glass  eels  for  restocking  in  another  country,  is  not  fully 
monitored  and  the  full  traceability  of  eel  traded  between  MSs  is  yet  to  be  established. 
However, it has been increasingly recognised that this is key to controlling illegal exports 
from the EU.  Also, the monitoring and control of recreational eel fisheries appear to be 
incomplete.  

There have been some local successes and examples of good practice (fisheries-related, 
including  traceability,  and  in  terms  of  habitat  restoration  and  improved  spawner 
connectivity). Those may be a source of inspiration for other MSs for strengthening the 
implementation of their EMP and various activities. 

Efficiency 

A monetarised analysis of the cost-benefits of the Eel Regulation is impossible to provide 
at this stage, since MSs do not quantify the direct costs of implementing the Regulation, 
the  responsibility  for  which  is  often  spread  across  a  number  of  different  government 
departments.   

The  direct  environmental  benefits  of  the  EMP  actions  (e.g.  eel  stock  recovery  through 
reduced  fishing  mortality  and  increased  spawner  escapement)  and  the  indirect 
environmental benefits (reconnected coastal, estuarine & riverine ecosystems) are long-
term in nature, still nascent and yet to be fully quantified in terms of their environmental 
benefits.  Likewise  it  is  difficult  to  quantify  the  socio-economic  benefits  of  the  EMP 
measures to date, especially given landings have stabilised and fishing effort has (mainly, 
but not in all MSs) reduced. Only when stock recovery becomes more evident and fishing 
opportunities consolidated will the socio-economic benefits become more apparent. 

Moreover,  there  is  scope  for  improving  the  efficiency  of  the  reporting  by  MSs  (e.g. 
Progress Reports and data calls). 

Coherence 

The  Eel  Regulation  is  essentially  coherent  with  a  number  of  EU  fisheries  and 
environmental legislation and with  wider international  agreements. Highly  relevant  are: 

49 

 
Common Fisheries Policy  (policy  framework),  Water Framework Directive and Marine 
Strategy  Framework  Directive  (for  eel-related  habitat  and  environmental  protection), 
Habitats  Directive  (for  the  conservation  of  eel-related  habitats),  CITES  (trade  related 
issues)  and  CMS  (international  cooperation).  Nevertheless,  there  is  scope  to  improve 
synergies between River Basin Management Plans under the WFD and the EMPs under 
including 
the  Eel  Regulation,  and 
harmonisation  and  prioritisation  of  measures,  specifically  around  hydro-morphological 
pressures.  In recent years the GFCM has recognised the need for eel management in the 
Mediterranean.  It also benefits from restrictions in the trade of European eels outside of 
the  EU  through  CITES,  and  there  is  scope  to  expand  the  role  of  the  CMS  in  eel 
conservation worldwide. 

the  authorities 

their  delivery, 

tasked  with 

EU added-value 

The Eel Regulation has provided a strong catalyst for MSs’ actions to address the issues 
affecting  the  recovery  of  the  European  eel.  It  has  also  brought  managers  together  from 
different  regions  and  organisations  within  MSs  to  develop  the  plans  and  associated 
measures.  Moreover, it has stimulated other EU-funded actions to support the recovery 
of  the  European  eel,  such  as  the  SUDOANG  project  in  South  West  Europe.    The 
Regulation has also helped to raise awareness of the need for conserving and managing 
European eels throughout its range. 

Sustainability 

The  evaluation  does  not  conclude  comprehensively  on  whether  the  effects  of  the  Eel 
Regulation are likely to endure since the recovery of the eel is a long process. 

There is no ‘end date’ for the Eel Regulation. Current measures remain in force until the 
Regulation  is  amended  or  repealed.  The  recovery  of  the  European  eel  population  is  a 
long-term process, with  some MS considering 2050 as a reasonable point by which the 
Regulation’s target of 40% escapement across the EU might be reached. 

Once  the  European  eel  stock  has  fully  recovered,  at  that  point the  Regulation  could  be 
reconsidered, and a management plan put in place.  In the meantime the regular progress 
reports as required in the Regulation should be continued. 

Overall conclusion 

The  adoption  of  the  Eel  Regulation  has  been  an  important  milestone  in  the  long 
process towards the recovery of the European eel. It remains as relevant now as it was 
in 2009. Nevertheless, despite notable progress in reducing fishing effort and a concerted 
attempt  to  develop  a  pan-EU  management  framework,  the  status  of  the  eel  remains 
critical. The Regulation’s success in ensuring the recovery of the European eel is still far 
from certain, as it is widely recognised that the recovery of the European eel will take 
many decades.  In this respect,  further ambition is needed to implement the Regulation 
with a greater focus on non-fisheries related measures. 

50 

 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

Lead DG: Directorate-General for Maritime Affairs and Fisheries (DG MARE) 

Planning reference: PLAN/2018/2447 

2.  ORGANISATION AND TIMING 

This  evaluation  has  been  steered  by  the  DG  MARE  since  21  March  2018  under  the 
scrutiny of an inter-service group (ISG) comprising of representatives of SG, DG ENV 
and DG MARE. 

The  ISG met seven times and was  consulted at  each stage of the evaluation process.  It 
reviewed  each  deliverable  produced  by  the  contractor  as  well  as  this  Staff  Working 
Document. 

3.  EXCEPTIONS TO THE BETTER REGULATION GUIDELINES 

None 

4.  CONSULTATION OF THE RSB (IF APPLICABLE) 

Not applicable 

5.  EVIDENCE, SOURCES AND QUALITY 

The evaluation is based on three pillars: 

 

 

 

the  external  expertise:  ‘Evaluation  study  on  evaluation  of  the  Eel  Regulation’, 
carried  out  by  a  consortium  of  consultants  led  by  Coffey  International 
Development during the period 21 September 2018 – 03 July 2019; 
the International Council for the Exploration of the Sea (ICES) recurrent advices 
on eels and the ad hoc assessment of Member States’ progress reports; 
the  Commission’s  analysis  of  the  use  of  the  European  Maritime  and  Fisheries 
Fund (EMFF) and the European Fisheries Fund (EFF) for the implementation of 
the Eel Regulation,  carried out through two auxiliary tasks with  FAME Support 
Unit. 

List of main documents of relevance is provided for in Annex 3.3. 

The evaluation is considered to be robust and well informed. 

51 

 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

The  consultation  activities  were  carried  out  in  line  with  the  Commission’s  Better 
Regulation  Toolbox,  tool  #55.  They  were  composed  of  a  public  consultation  (via 
feedback to the Evaluation Roadmap and the Public Consultation), specific and targeted 
consultations, as well as ad-hoc written contributions. 

1.  FEEDBACK  TO  EVALUATION  ROADMAP  AND  AD  HOC 

CONTRIBUTION 

The  Evaluation  Roadmap46  summarising  the  context,  purpose  and  scope  of  the 
upcoming  evaluation  and  outlining  the  expected  approach  was  published  at  the 
Commission website prior the evaluation. Stakeholders were able to provide feedback on 
the Evaluation Roadmap from 13 April to 11 May 2018. 

The feedback was provided by 16 stakeholder organisations (5 from SE, 3 from FR and 
the  UK  each,  2  from  DE,  1  from  EL  and  FI  each,  and  1  Brussels-based  EU  level 
organisation – Europêche) and two unaffiliated individuals (from RO and NL). 

Published responses repeatedly highlight some of the perceived key issues that evaluation 
of the Eel Regulation will need to consider, including: 

•  mixed opinion on whether the 40% silver eel escapement target is achievable; 
• 
• 
• 
• 
• 

incomplete or inconsistent reporting by MSs; 
use of metrics that are challenging to measure and report against; 
perceived lack of clarity about short-term and long-term targets; 
scale and effects on management of the illegal trade in eels from Europe to Asia; 
lack of evidence on the effectiveness of restrictions on fishing and restocking on 
the status of the eel stock;  
absence of an internationally coordinated management plan for the whole stock 
area; and 
coherence  of  the  Eel  Regulation  with  other  international  and  European 
instruments. 

• 

• 

Some of the key most-frequently raised issues in contributions included: 

1.  A significant hydropower mortality and illegal fishing as  factors influencing the 

stock as well as oceanic factors; 

2.  A need for alternative targets in the Regulation to reduce anthropogenic (but not 
related  to  fishing),  for  instance:  temporary  shutdown  of  hydropower  turbines, 
restoration of habitats, etc., and a need for intermediate targets; 
3.  A need for improved control, monitoring and traceability system; 
4.  Insufficient and unequal implementation level of EMP in MS; 
5.  Uncertainty of the effectiveness of restocking operations; 
6.  Socio-economic consequences of restrictions on eel fishing, in particular the total 
ban, as well as an importance of eel fishing as a cultural heritage (e.g. in SE). 

Some of those issues were also raised in separate contributions. The Baltic Sea Advisory 
Council (BSAC), UK’s Department for Environment, Food and Rural Affairs (Defra) and 
a  coalition  of  NGOs  provided  ad  hoc  contributions  to  the  Evaluation  Roadmap,  and 

46 Evaluation of Eel Regulation, https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447_en.  

52 

 
 
                                                           
Dutch  and  French  governments  to  the  Public  Consultations.  BSAC  underlined  the 
meaningfulness of fighting illegal fishery, facilitating migration routes, and in particular 
socio-economic  consequences  of  total  ban  on  eel  fishing.  The  Dutch  government 
expressed its support to strengthen the Regulation. Both, French and Dutch governments 
stressed the need for improving implementation of EMPs. 

2.  TARGETED CONSULTATION 

Targeted  consultation  was  undertaken  by  the  external  study  consultants  with  key 
stakeholder groups across all relevant MSs. Consultation focused on stakeholders that are 
directly impacted by the Regulation (e.g. competent/managing authorities responsible for 
developing,  implementing  and  monitoring  against  EMPs,  for  control  and  enforcement, 
for  implementing  EMFF;  fishers  and  farmers,  and  those  involved  in  eel  restocking  and 
trade),  those  that  have  an  interest  in  the  implementation  of  the  Regulation  (e.g. 
international  organisations  such  as  implementing  CITES  and  the  CMS,  and  NGOs),  or 
those  that  may  be  under-represented  in  the  public  consultation  (e.g.  research  bodies). 
Around  200  potential  stakeholder  organisations  were  identified.  See  Annex  3.2  listing 
main stakeholders consulted. 

Consultation  with  stakeholders  was  based  upon  one  of  three  questionnaires  as  follows: 
one targeted at MS competent/managing authorities, two targeted at MS fisheries control 
authorities and one targeted at  all other stakeholders. Responses to questionnaires were 
collated in a database and analysed by the external study consultants. 

Information in support of the evaluation of control and enforcement of measures of the 
Eel Regulation by MS has been obtained according to two main sources: 

 

 

Information  reported  by  MSs  in  response  to  a  dedicated  control  questionnaire 
submitted by DG MARE under its own initiative in 2017 and 2018 to a sample of 
MSs  to  understand  the  success  or  otherwise  of  eel  conservation  related  control 
systems  in  the  EU  and  to  identify  the  main  challenges.  The  following  MSs 
responded:  DE,  ES,  FR,  EL,  IT,  NL,  PL,  SE  and  UK.  Some  MSs  (e.g.  HR  and 
PT) did not respond to DG MARE questionnaire. 
Information  reported  by  MSs  in  response  to  a  dedicated  control  questionnaire 
prepared by the expert team. Two different questionnaires have been prepared for 
MS  having  submitted  an  EMP:  a  simplified  questionnaire  for  those  MSs  who 
responded to the DG MARE questionnaire to avoid repetition of efforts, and a full 
questionnaire for those MSs who have not been consulted by DG MARE or who 
did not respond to DG MARE.  

Consultations  based  on  the  questionnaires  were  conducted  mainly  via  email  and 
telephone.  Further,  more  than  23  in-depth  face-to-face  and  telephone  interviews  were 
held  with  relevant  stakeholders;  these  were  focused  on  stakeholders  in  case  study 
countries  (DK,  FR  and  IT)  but  also  included  other  key  stakeholders  both  within  and 
outside the EU.  Interviews sought to follow the themes covered in the questionnaires. 

In total, 174 questionnaires were issued, distributed to stakeholders in 24 MSs, and to a 
variety of stakeholders, as shown in Figure 7. Almost 50% of questionnaires were issued 
to  stakeholders  in  six  MSs  (IT,  UK,  BE,  SE,  NL  and  DE),  with  lesser  numbers  of 
questionnaires issued to stakeholders in the remaining 18 MSs.  

53 

 
 
 
 
Figure 7: Questionnaire distribution by stakeholder category 

At  the  time  of  writing  of  the  external  evaluation  study,  11  MSs  responded  to  the 
questionnaire, and 11 did not respond. Details are shown in the Table 2 below. Among 
the 11 who did not respond, information on control was nevertheless available from the 
questionnaire received by DG MARE (ES, NL and SI). Note that the six MSs that have 
been exempted from submitting an EMP have not been consulted. 

Table 2: Summary of responses from the control questionnaires 

Questionnaire 
received 
BE 
CZ 
DE* 
FR* 
GR* 
IT* 
LT 
LV 
PL* 
SE* 
UK* 
11 

No response to 
questionnaire 
BG 
DK 
EE 
ES* 
FI 
HR 
IE 
LU 
NL* 
PT 
SI* 
11 

Exempted from 
EMP 
AT 
CY 
HU 
MT 
RO 
SK 

6 

Note: * denotes MS having replied to DG MARE questionnaire in 2017 and 2018. 

Responses  to  questionnaires  were  collated  in  a  database  and  analysed  by  the  external 
study consultants. 

54 

 
 
  
 
 
 
 
 
 
Respondents’ profile 

Around  80  responses  to  questionnaires  were  received.  Responses  were  received  from 
stakeholders across 15 MSs from a variety of stakeholders as shown in Figure 8 below, 
and over 40% of responses were received from respondents in  IT and NL, reflecting to 
some extent the distribution of questionnaires. 

Figure 8: Questionnaires received by stakeholder category 

Targeted consultation results 

As regards the relevance of the Eel Regulation, almost all respondents reported that it 
remains highly relevant given the critical status of the eel population.  

In terms of the effectiveness of the Eel Regulation, a number of respondents suggested 
that recovery of the eel population will take many decades and thus it is difficult to judge 
the  effectiveness  of  measures  already  taken  under  the  Regulation.  Many  stakeholders 
considered the Regulation to have been particularly effective in reducing fisheries-related 
eel mortality, though noted that the focus has perhaps been too much on fisheries-related 
management  measures  and  that  there  has  been  insufficient  action  taken  by  MSs  to 
address non-fisheries anthropogenic mortality. 

Stakeholders typically acknowledged that the Regulation has usefully driven forward the 
preparation of EMPs within MSs, though in many cases also suggested that the approach 
to preparing, implementing and monitoring progress against EMP management measures 
needs to be improved and made more consistent across MSs. In the majority of countries, 
EMPs have remained as static documents, rather than being used to encourage adaptive 
management based on the findings of the latest monitoring and research. As an example 
of this lack of responsiveness, most EMPs encourage restocking, which is now felt to be 
an ineffective long-term management measure. Regular review and update of EMPs, and 

55 

 
 
 
improved reporting on progress against EMP targets, should be encouraged, as should the 
sharing of any recognised good practices or key research findings across MSs. 

As  regards  the  control  of  eel  fisheries,  all  MSs  consulted  reported  that  eel  control 
measures  fall  under  the  responsibility  of  different  Ministries  and  competent  bodies  and 
that  cooperation  mechanisms  have  been  implemented  through  dedicated  steering 
platforms.  The  eel  fisheries  control  have  been  subject  to  a  risk-assessment  analysis  to 
identify  priorities.    A  number  of  MSs  identified  as  main  risks  the  illegal  fishing  in 
freshwater  bodies  of  eels  at  all  life  stages,  illegal  trade  in  the  aquaculture  sector  and 
misreporting of catches. 

Catch registration of professional fishermen and eel buyers for catches in marine waters 
or  freshwater  have  been  established.  Catch  declarations  by  professional  fishermen  (for 
both  marine  and  fresh  waters)  are  mandatory.  Only  FR  reported  having  implemented  a 
declaration  system  for  recreational  fishermen  based  on  paper  form.  As  regards  sales 
notes,  DK,  FR  and  NL  specified  that  buyers  of  eels  are  mandated  to  declare 
electronically  purchases  of  eels  from  fishermen  in  real  time  (marine  and  fresh  water 
eels). In the UK, buyers are requested to declare purchases of eels “periodically”. Other 
MS did not specify information in this respect. 

According to MS authorities, full traceability of eels is not readily available. The paper-
based traceability system enforced by the Control Regulation that concern eel caught in 
marine waters is not yet fully implemented. To note, two MSs (DK, SE) reported having 
implemented  electronic  traceability  system  but  limited  to  marine  species.  Furthermore, 
MS  authorities  inspecting  lorries  transporting  the  eel  may  encounter  difficulties  to 
ascertain the validity of the document presented in case of control. 

As regards an appropriate reporting system to ensure that the 60% glass eels reserved for 
restocking  are  used  for  this  purpose,  MSs  feedback  indicates  they  can  only  implement 
such reporting systems for activities under their competence (i.e. for glass eels caught in 
their territory and by their vessels used for restocking operations in their territories). 

Several  countries  reported  having  implemented  control  practices  that  go  beyond  the 
minimum  EU  requirements.  These  include:  more  stringent  conditions  for  monitoring 
glass eel catches (FR, UK), use of modern technologies to detect illegal fishing (DK, EE, 
LT, LV, PL, SE), coordination of police forces at national level to fight illegal trafficking 
of glass eels (ES, FR) or support of citizens for reporting suspected infringements (DK, 
SE,  UK,  and  PL).  Some  countries  (e.g.  EL,  IT  and  SE)  have  involved  their  CITES 
management  authorities  in  the  national  control  system  through  national  instruments 
(permit scheme in EL, CITES registries in IT and SE). 

Many stakeholders highlighted concerns about the evident trade in illegal, unreported and 
unregulated  fished  eels  undermining  the  effectiveness  of  the  Eel  Regulation.  It  was 
broadly  felt  that  there  is  a  need  for  improved  control  measures  to  assist  in  addressing 
illegal trade, particularly around the activities of small fishing vessels that are understood 
to form the bulk of the fleet targeting eels. 

Considering the sustainability of the Eel Regulation, respondents again suggested that 
management  efforts  around  non-fisheries  anthropogenic  mortality  should  be  increased, 
looking  at  improving  eel  habitat  connectivity  and  improving  the  quality  of  eel  habitat. 
Such measures are considered most likely to have long-term beneficial impacts on the eel 
population. 

56 

 
Stakeholders  held  mixed  views  around  the  coherence  of  the  Eel  Regulation  with  EU 
and  international  initiatives.  They  typically  considered  that  the  efficiency  of  the  Eel 
Regulation  could  be  improved  through  better  exploiting  synergies  with  EU  and 
international instruments, such as the Water Framework Directive and Habitats Directive, 
which could better reflect the critical status of the eel population. It was also suggested 
that  efficiency  could  be  improved  by  encouraging  the  further  development  and 
improvement  of  progress  reporting  on  EMPs,  noting  that  this  has  historically  varied 
substantially in quality and robustness, making monitoring of overall progress under the 
Eel  Regulation  very  challenging.  The  burden  on  MS  reporting  could  also  be  eased  by 
reporting  requests  from  various  bodies,  including  DG  MARE  and  ICES,  being 
coordinated.  Finally,  a  number  of  questionnaire  respondents  indicated  that  it  would  be 
beneficial for the Eel Regulation to allow for interim targets and encourage the setting of 
timelines for achievement of targets. 

Other  points  raised  by  several  stakeholders  included  the  need  for  a  more  cohesive 
funding  approach  to  implement  EMPs  and  associated  management  measures,  the  need 
for greater efforts to raise the profile of eel and its critical status, as well as the need for a 
central coordinating body for the recovery of the European Eel. 

3.  PUBLIC CONSULTATION 

The Commission launched the Public Consultation (PC)47 on 14 December 2018 for the 
obligatory 12-week period that ended on 8 March 2019. The consultation aimed to gather 
feedback from two types of respondents: professionals familiar with the Eel Regulation 
and the EU citizens not familiar with the legislation but interested in eel stock recovery. 

The PC questionnaire prepared with an assistance of the external study consultants was 
divided into two sections: an experts’ survey and a general survey. The experts’ survey 
included  12  closed  and  11  open  questions.  The  questions  were  more  specific  and 
complex, and they referred to all the six evaluation criteria. The general survey was more 
generic  and  briefer.  It  included  three  closed  and  one  open  question.  The  questionnaire 
was  prepared  in  English  language  and  translated  to  all  EU  languages  accessible  on  the 
EU Survey website. 

In total, 160 respondents took part in PC, of which 152 responded to experts’ survey and 
8  to  general  survey.  Also  ad-hoc  written  responses  were  received  from  the  Sustainable 
Eel  Group (SEG), the  Baltic Sea Advisory Council (BSAC), as  well as the French  and 
the Netherlands governments. 

Respondents’ profile 

Sixteen MSs (57%) and two non-EU countries (Norway and Albania) were represented 
in  the  contributions.  More  than  40%  of  respondents  came  from  FR  (66  contributions), 
followed by ES (20), NL (14), DE (10), UK (8), PT (7), BE and SE (6 each). 

Out of 160 respondents, 45 gave their contributions as “EU citizens” without institutional 
affiliation  (28.1%)  and  115  respondents  in  a  professional  capacity  (71.9%)  as 
representatives  of:  a  company  or  business  organisation  (26),  NGOs  (19),  academic  or 
research  institutions  (18),  environmental  organisation  (18),  public  authority  (12), 
business association (8), trade union (3), and “other” (11). 

47 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447/public-consultation_en  

57 

 
                                                           
Respondents’ self-description in relation to the Eel Regulation was as follows: 

 

 

 

 
 
 

I  work  for  an  environmental  body  with  an  interest  in  the  implementation  of  the 
Eel Regulation (18.1%); 
I have a general interest in matters concerning fisheries in the European Union 
(17.5%); 
I  work  for  a  public  administration  responsible  for  developing,  implementing 
and/or monitoring the Eel Regulation (16.9%); 
I am a fisher or farmer involved the production and/or sale of eels (10%); 
I work for a research body with an interest in the Eel Regulation (8.8%); 
I represent  an international organisation with an interest  in  the implementation 
of the Eel Regulation (6.9%); 

  Other 

(21.9%), 

for 

instance  hydropower  producers, 

fisheries  advisors, 

organisations representing fishermen and other NGOs. 

Fields  of  activity  of  respondents’  organisations  were:  environment  (42.5%),  fishery 
(31.3%),  aquaculture  (4.4%),  other  (21.9%),  for  instance  hydropower,  shipping, 
agriculture and law enforcement.  Their organisations varied in terms of size: large with 
over 250 employees (20%), medium (10.6%), small (16.3%) and micro (25%).48  

Public consultation results 

There is a significant imbalance in the number of respondents to the Public Consultation 
(PC) experts’ survey (n=152 out of 160; 95%) and the general survey addressed to non-
specialised respondents (n=8). This suggests that the issue of recovery of eel population 
could be too technical for the general public to provide feedback on, and that knowledge 
about  and/or  interest  in  this  issue  is  rather  limited.  It  is  difficult  to  make  any  broader 
conclusions  on  the  basis  of  eight  contributions,  but  nonetheless  almost  all  of  those 
respondents  supported  actions  by  the  EU  to  ensure  stock  recovery.  Contributions  by 
experts  to  the  PC  were  at  high  completion  rate.  About  75%  of  respondents  provided 
comments  to  all open-ended questions and one third of  respondents  also added  general 
comments  at  the  end  of  the  survey.  15  respondents  (9.4%)  uploaded  additional 
documents.  However,  it  is  doubtful  to  what  extent  the  results  presented  are  indeed 
representative  of  the  expert  community  across  Europe,  since  40%  of  all  contributions 
came from just one country (FR). 

Overview of responses 

The relevance of the Eel Regulation was considered high. All objectives were assessed as 
fit-for-purpose by the vast majority of respondents. The majority of them also confirmed 
the EU added value of the intervention in comparison to what could be achieved by MS 
at national or regional levels. However, respondents were much less convinced that the 
overall aim of achieving the 40% eel escapement target was achievable. 

The measures  to  recover the eel  population  in  Europe were widely supported. The vast 
majority  supported  all  forms  of  limiting  eel  fishing  (recreational  and  professional,  in 
freshwater and the sea) and facilitating eel migration through rivers, and a small majority 
also  indicated  to  support  restocking.  However,  the  results  also  suggest  that  changes  in 
addressing  the  issue  of  eel  stock  recovery  are  necessary.  Three  quarters  of  respondents 
indicated the regulation requires alternative targets to ensure it delivers on its objectives 

48 Not all respondents specified the size of organisation, n=115. 

58 

 
                                                           
and two thirds indicated it requires amendment  or simplification. Suggestions included: 
further  restrictions  of  fishing  and  trade,  generally  reinforcing  the  regulation,  reducing 
migration barriers and recovery of migration routes and habitats, and the need to better 
understand the problem (scientific research and monitoring). 

Achievements of the regulation, especially at the national level, were assessed much less 
positively  than  its  relevance.  According  to  the  majority  of  respondents,  although  MSs 
managed  to  implement  EMPs,  they  did  not  manage  to  achieve  the  targets  set  in  those 
plans.  Respondents  highlighted  that  the  regulation  managed  to  raise  awareness  of  the 
critical situation of the eel population and to introduce some measures, which may reduce 
pressure on the stock rather than directly increase the stock. As regards barriers hindering 
the  effectiveness  of  the  regulation,  respondents  highlighted  in  particular  those  that  are 
external: hydropower mortality and poaching, or insufficient implementation (rather than 
the legislation itself). When asked about other actions which could help the recovery of 
the  eel  population,  most  indicated  the  need  to  restore  migration  routes  (address 
hydropower  mortality)  and  habitats  or  reduce  pollution.  However,  the  majority  of 
respondents also supported a total ban on eel fishing. 

It was more challenging for respondents to assess efficiency, sustainability and coherence 
of the regulation and many of them selected either “neither agree nor disagree” or “don’t 
know” answers. 

Experts’ survey - details 

Relevance 

Overall,  respondents  assessed  the  relevance  of  the  Eel  Regulation  positively.  The 
majority of them considered all the objectives listed as still relevant (Q1). More than nine 
in  ten  respondents  agreed  that  there  remains  a  need  to  ensure  that  anthropogenic 
mortalities are reduced, for a European recovery plan for the European eel, and for MSs 
to implement EMPs. 86.8% agreed that there remains a need to ensure that control and 
enforcement activities take place in EU waters at all stages of the eel supply chain. 85.5% 
agreed  that  there  remains  a  need  to  ensure  the  origin  and  traceability  of  all  live  eels 
imported  to  and  exported  from  MS.  82.2%  agreed  that  there  remains  a  need  to  ensure 
fishing  effort  and  catches  are  regulated.  75.67%  of  respondents  agreed  that  it  remains 
appropriate  to  regulate  the  supply  of  glass  eels  for  restocking  operations  and  67.8% 
agreed that there remains a need to ensure the escapement to the sea of at least 40% of 
the adult eel  biomass.  The lowest  number of respondents,  but  still the majority,  agreed 
that  it  remains  appropriate  to  seek  to  reduce  catching  of  eels  to  at  least  50%  of  2006 
levels (57.9% agreed and 28.3% disagreed). 

While  the  target  to  ensure  40%  eel  escapement  to  the  sea  was  perceived  as  “relevant”, 
less  than  half  of  respondents  (45.4%)  indicated  that  it  was  indeed  “achievable”  (Q2). 
When analysed by sector, business sector respondents tended to indicate more frequently 
that  they  disagreed  with  the  statement  that  this  target  was  achievable  (44.1%),  while 
representatives of NGOs and academic communities tended to agree (66.7% and 58.8%, 
respectively).  Out  of  those  who  provided  additional  comments  (Q3,  n=127),  34.8% 
highlighted  a  number  of  issues  with  the  40%  target  itself,  namely:  the  target  is  not 
measurable, not ambitious enough, not based on scientific evidence, set for pristine rivers 
rather  than  real-life  situations,  not  comparable  between  MSs  or,  in  fact,  too  ambitious. 
Others  referred  to  external  reasons  why  the  target  is  unachievable:  unresolved  problem 
with  barriers  to  eel  migration and hydropower-turbines mortality  (14.8%), the policy at 

59 

 
the national level being insufficiently implemented (6.7%).  

The  vast  majority  of  respondents  (76.3%)  indicated  that  alternative  targets  (Q4)  were 
needed to ensure that the regulation delivers on its objective of securing the recovery of 
the  European  eel.  One  in  ten  respondents  disagreed.  Out  of  those  respondents  who 
provided  additional  comments  and  proposals  in  an  open-ended  question  (Q5,  n=103), 
22.3% highlighted the need to further limit eel fishing, in particular glass eel fishing and 
recreational  fishing,  and  9.7%  mentioned  a  total  ban  on  eel  fishing.  16.5%  proposed 
targets  related  to  reduction  of  migration  barriers  (hydropower,  dams;  turbines’  closures 
during migration periods) and 11.7% proposed focusing on recovery of estuaries, rivers 
and  habitats  and  reducing  pollution  (including  PCBs  and  endocrine  disruptors).  Other 
proposed targets were related to: better understanding of the problem (scientific research 
and monitoring) (5.9% of respondents) and introducing interim targets and deadlines for 
implementation (5.3% of respondents). 

On question if the regulation needed amendments or simplification (Q6), the majority of 
respondents indicated that it did (64.5%), compared to only one in ten who disagreed and 
about  one  third  without  a  specified  opinion.  From  those  who  provided  suggestions  on 
amendments or simplification in an open-ended question (Q7, n=121), many (39.7%) did 
not specify concrete steps and 9.9% suggested it was the implementation that needed to 
be improved rather than the regulation itself. Other suggestions included: 

 

introducing  stricter  rules  on  fishing  and  trade  (including  a  total  ban  on  fishing) 
and reinforcing the regulation (20.7%), 

  modifying the escapement objective (clarification or setting more realistic target) 

 

(9.1%), 
introducing  more  harmonized  standards  or  indicators  to  assess  effects  across 
countries (7.4%). 

Effectiveness 

The opinions on the effectiveness of the current measures for the recovery of European 
eel stock against the same set of objectives of the regulation were mixed. 

The  achievement  of  some  objectives  was  assessed  more  positively  than  others  (Q8, 
n=152, see  Figure 9), for example, the implementation of EMP was  the only objective 
that the majority of respondents (57.2%) agreed that it was achieved. But the majority of 
respondents (51.3%) indicated that targets set out in EMP remain not achieved. A relative 
majority of respondents indicated that the regulation managed to increase the adult eels’ 
escapement to the sea towards the 40% target (3.3 percentage points difference between 
positive and negative answers) and to ensure a reduction in anthropogenic eel mortalities 
(0.7 percentage  points  difference  between  positive  and  negative  answers).  As  regards 
other  objectives,  more  respondents  indicated  that  they  were  not  achieved,  and  in  most 
responses the difference in responses was between 9 and 12 percentage points. 

60 

 
 
 
 
 
 
 
 
 
 
Figure 9: What has the Eel Regulation achieved? 

Ensuring control and enforcement activities at all stages
of the eel supply chain

Ensuring the origin and traceability of all live eels
imported to and exported from MS

Ensuring reduction of fishing effort and catches towards
the 50% targets

Ensuring that there is enough supply of glass eels for
restocking operations
Increasing the escapement to the sea of adult eels
towards the 40% target

13,2% 

18,4% 

16,4% 

27,0% 

11,2% 

20,4% 

17,1% 

23,7% 

9,9% 

25,0% 

17,1% 

28,3% 

8,6% 

15,8% 

19,7% 

15,1% 

9,2% 

30,3% 

22,4% 

13,8% 

Ensuring a reduction in anthropogenic eel mortalities

14,5% 

29,6% 

29,6% 

13,8% 

Achieving the targets set out in Eel Management Plans

10,5% 

19,1% 

29,6% 

21,7% 

Implementing Eel Management Plans

19,7% 

37,5% 

15,8% 

13,8% 

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

0%

25%

50%

75%

100%

Most  respondents  shared  their  views  on  successes  of  the  Eel  Regulation  (Q10)  and 
barriers  hindering  its  effectiveness  in  open  text  comments  (Q9),  147  and  139, 
respectively. 

In  terms  of  successes  of  the  Regulation,  7.5%  of  respondents  who  provided  comments 
referred to increased stock or reduced mortality, 25.2% referred to more indirect effects 
which can lead to reducing mortality in the long term (reducing fishing effort, removing 
barriers  to  migration,  improved  control,  restocking  programmes,  implementation  of 
EMPs),  and  29.9%  referred  to  raised  awareness  of  the  problem,  increased  efforts  and 
cooperation of different actors and MS. 10.2% mentioned other achievements and 12.9% 
indicated no or limited achievements or negative consequences. 

As regards barriers hindering effectiveness, respondents mentioned as follows: 

  external  barriers  (39.1%),  such  as:  inability  to  reduce  hydropower  mortality 

(13.9%), black market and poaching (12.6%); 
issues with the regulation itself (18.5%); 

 
  problems with its implementation (17.2%), especially bad quality or insufficient 

implementation of EMPs. 

Most of respondents indicated that they supported all the measures of the Eel Regulation 
(Q11,  n=152).  The  measure  most  frequently  supported  (9  out  of  10  respondents)  was 
facilitating fish migration through rivers. Almost three quarters of respondents supported 
limiting recreational eel fishing in freshwater (74.3%) and the sea (73.7%). The majority 
also supported limiting professional fisheries in the sea (69.7%,) and freshwater (65.8%). 
Restocking waters with  young fish was  the least supported measure, but  still supported 
by a majority of respondents (53.3%). 

In  a  separate  question  (Q12),  respondents  were  asked  if  they  were  in  favour  of 
implementation of total or partial bans on eel fishing to aid recovery of the European eel 
stock.  This  measure  was  also  supported  by  a  majority  of  respondents  (61.2%)  and 
opposed by one third of them (33.6%). Respondents from the business sector were most 
likely to  disagree that they supported the implementation  of total  or partial bans on eel 

61 

 
 
fishing  (58.8%,  n=40).  Conversely,  83.3%  of  respondents  representing  environmental 
organisations supported it. 

In additional comments related to bans on eel fishing (Q12a), 34.3% justified supporting 
a  total  ban  mainly  because  of  the  critical  condition  of  the  eel  population  and  need  for 
urgent action and 5% mentioned fishing being of the main reasons of stock decline. Out 
of those who indicated that they did not support a ban (28.6%), 15.7% highlighted that 
other factors are responsible for the decline of the stock (such as hydropower, pollution), 
5.7% mentioned that a ban would lead to increased poaching, and another 5.7% referred 
to negative social and economic consequences of a total ban. 

On a question about other actions at EU or MS levels that could be undertaken to recover 
the eel population in Europe (Q13, n=144), 43.8% respondents highlighted the need for 
ecological  actions  (restoring  migration  routes,  rivers,  shelters,  reducing  pollution  etc.), 
16.0%  mentioned  improving  monitoring  activities,  traceability,  scientific  research  and 
evaluation  of  current  activities,13.9%  referred  to  enhancing  control  of  legal  and  illegal 
fishing, and 9.7% mentioned further limitation of fishing, including a total ban. 

Coherence 

The  coherence  of  the  Eel  Regulation  was  assessed  rather  negatively.  39.5%  of 
respondents  indicated  they  disagreed  that  the  regulation  is  coherent  with  international 
fisheries  instruments  (“external  coherence”)  and  35.6%  selected  the  same  answer  for 
coherence  with  other  EU  instruments  (“internal  coherence”).  The  proportion  of 
respondents  who  disagreed  that  the  regulation  was  externally  coherent  exceeded  those 
who  agreed  by  12.5  percentage  points.  In  terms  of  internal  coherence  negative 
assessment  exceeded  positive  by  6.6%  percentage  points.  The  details  are  presented  in 
Figure 10 (Q14, n=152). The proportion of respondents who indicated that they “didn’t 
know” was substantial and exceeded one third of all respondents in both cases. 

Figure 10: How coherent is the Eel Regulation with other instruments? 

The Eel Regulation is coherent with international
instruments to regulate fisheries

The Eel Regulation is coherent with other EU
instruments to regulate fisheries

4,6% 

22,4% 

20,4% 

19,1% 

5,9% 

23,0% 

20,4% 

15,1% 

0%

25%

50%

75%

100%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

Respondents  who  provided  additional  comments  (Q14a)  in  most  cases  did  not  clearly 
specify the issues with  coherence. 19.1% of those who  commented  (n=131) referred to 
inconsistencies  within  Common  Fisheries  Policy  (MSY  principle),  Water  Framework 
Directive not applicable to eels, Habitat Directive, and 9.9% referred to other issues (e.g. 
ban of export leading to illegal trade, protecting predators etc.). 

EU added-value 

Respondents  indicated  that  the  Eel  Regulation  provided  added  value  to  what  could  be 
achieved by MS at national or regional levels (Q15, n=152). More than three quarters of 
respondents valued the EU intervention, compare to 7.9% who did not. 

62 

 
 
In  an  open-ended  question,  respondents  were  also  asked  what  the  consequences  of 
withdrawing the intervention would be (Q16). Most of them (59.9%, n=147) referred to 
negative consequences, mainly the eel population being more endangered and a risk that 
MSs  would  no  longer  implement  protective  measures.  12.9%  mentioned  positive 
consequences, such as fishing no longer being limited. 

Efficiency 

Opinions on the efficiency of the Eel Regulation were rather ambiguous (Q17, n=152). 
40.8%  of  respondents  disagreed  that  the  same  or  better  results  in  terms  of  eel  stock 
recovery  could  have  been  achieved  at  lower  cost,  whereas  18.5%  agreed  with  the 
statement.  On  the  other  hand,  36.2%  disagreed  that  the  costs  of  administering  and 
implementing the regulation are proportionate to the environmental and socio-economic 
benefits achieved, with 18.4% agreeing with this statement. One quarter of respondents 
indicated that administering and implementing the regulation has been carried out at the 
lowest possible cost, however, a majority of respondents ”neither agreed nor disagreed” 
and  ”did  not  know”  whether  they  agreed  or  disagreed  with  this  statement  (34.9%  and 
24.3%, respectively).  

Opinions whether the regulation could be simplified but still achieve the same result were 
mixed. Almost equal proportions of respondents  (35.5%) agreed and disagreed (34.2%) 
and did not specify their opinion (30.3%). 

Most  of  the  respondents  were  not  able  to  assess  the  efficiency  of  the  regulation  in 
comparison  with  other  policy  instruments  or  mechanisms  (Q18,  n=152).  54.6% 
responded  that  they  “didn’t  know”.  Among  the  remaining  respondents,  a  larger 
proportion disagreed (29,6%) that other instruments provided better cost-effectiveness. 

Only  15%  of  all  respondents  provided  examples  of  more  cost-effective  policy 
instruments and mechanisms (Q19, n=23) and tended to propose alternative actions such 
as:  recovery  of  migration  routes  and  habitats,  reducing  fishing,  improved  international 
cooperation, and controlled opening of exports to Asia. 

Sustainability 

Responses to questions on the sustainability of the effects of the regulation were varied 
(Q20, n=152).  A slightly larger proportion of respondents  indicated that they disagreed 
that the effects of the intervention were likely to last after it ended (37.5% compared to 
30.9%  who  agreed,  a  difference  of  6.6  percentage  points).  A  substantial  proportion  of 
respondents (one third) indicated that they “did not know” whether the effects were likely 
to last.  

General survey - details 

Out  of  eight  respondents  who  participated  in  the  survey  addressed  to  non-specialised 
respondents, one indicated that they had never heard about the problem of the decreasing 
European eel population compared to seven respondents who had (Q21). 

All eight respondents indicated that they “rather agreed” that they supported action by the 
EU to regulate eel fishing to ensure the recovery of the species (Q22). 

With regards to specific measures to  recover the population of eel in Europe (Q23), all 
respondents  supported  facilitating  fish  migration  through  rivers;  seven  out  of  eight 

63 

 
respondents supported limiting professional eel fisheries in the sea and in freshwater, and 
limiting  recreational  eel  fishing  in  freshwater,  whereas  six  respondents  supported 
restocking  waters  with  young  fish.  Five  out  of  eight  respondents  supported  limiting 
recreational eel fishing in the sea. 

Summary of ad-hoc written contributions submitted 

Four  written  contributions  have  been  submitted  in  response  to  the  Public  Consultation 
from the Sustainable Eel Group (SEG), the Baltic Sea Advisory Council (BSAC) as well 
as the French and Netherlands governments. They are summarised as follows: 

1)  The SEG considers that the Regulation as such is effective (increasing awareness, 
management  plans,  protective  action,  comprehensive  approach)  and  that  the 
implementation  needs  to  be  strengthened.  It  suggests  keeping  the  Regulation  in 
place,  possibly  with  minor  modifications.  It  notes  that  the  key  to  the  successful 
protection of the European eel across Europe are: strengthening the international 
coordination  and  evaluation,  refocusing  protective  actions  on  a  geographically 
partitioned basis (EMUs), implementing full traceability of eels and eel-products, 
extending the protection of the eel beyond the borders of the EU, prioritising the 
eel  and  increasing  its  protection  in  policies  such  as  the  Water  Framework 
Directive, Natura 2000, and others, to address the non-fishing impacts. 

2)  The  BSAC  sent  as  its  contribution  to  the  Public  Consultation  the  BSAC  joint 
position papers on eels prepared in the framework of consultations held in 2017 
and  2018  (including  on  the  possible  ways  forward  to  improve  the  situation  of 
European  eel  and  the  measures  to  promote  the  recovery  of  eel).  Given  the 
electronic  format  of  the  on-line  consultation  process,  BSAC  members  were 
encouraged to respond individually. 

3)  The French government indicated that: i) achieving the goal of a 40% escape rate 
is only possible in the long term, given the life cycle of the species and the state 
of  the  stock;  ii)  the  need  to  adopt  intermediate  targets  in  national  management 
plans; iii) the need to focus efforts the proper implementation of the EMPs (with 
emphasis on non-fisheries anthropogenic mortality factors). 

4)  The Dutch government noted that: i) the decline in eel mortality has not yet led to 
an  increase  in  the  biomass,  ii)  the  recovery  of  eel  stocks  is  slow;  iii)  further 
management is needed to improve eel status and make fisheries more sustainable. 
It  made  several  suggestions  to  strengthen  the  Eel  Regulation,  while  ensuring  a 
level playing field within the EU and with third countries. 

64 

 
 
ANNEX 3: METHODS AND ANALYTICAL MODELS 

1.  Evaluation Question Matrix 

RELEVANCE 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ1.  To what extent are the existing 

1.  The current state of the eel stock and 

1.  Trends in recruitment indices for key European 

1.  Examinations of scientific evidence. 

measures for the recovery of 
European eel stock under the Eel 
Regulation still relevant ? 

EQ1a  How well the objectives of the Eel 

Regulation (still) correspond to 
needs within EU? 

whether conservation measures are still 
required.   

2.  The EMP structure as defined by the Eel 

Regulation is still relevant to current needs. 

1.  The extent to which eel landings, 
escapement levels and river basin 
conditions have recovered sufficiently to 
warrant the measures being continued.   

sea basins over 2007 - 2017. 

2.  Measures stipulated as required in the EMPs 
are relevant and adequate to current needs. 

2.  Face to face meeting with ICES / WGEEL 

group members.   

1.  Eel landing patterns, escapement levels and 

1. 

ICES, EUROSTAT & GFCM data.   

river basin management plan indicators (GES 
status change). 

2.  Progress reports, scientific reports, 

stakeholder consultations, case studies. 

3.  RBMP reports (key selected river basins 

only). 

EQ1b.  How well adapted is the Eel 

Regulation to subsequent legal 
provisions or scientific advances / 
assessments (linked to the 
reformed CFP, environmental 
policy, reporting and compliance)? 

EQ1c.  How relevant is the need for eel 

conservation and management to 
EU citizens ?  

1.  Extent to which the Regulation’s objectives 
and measures remain relevant following 
CFP reform, the introduction of new 
environmental policies and measures, and 
EU reporting and evaluation approaches.   

1.  Review of the key relevant reformed CFP 

1.  Desk study 

elements (e.g. conservation, profitability, equal 
access, common market provisions (see EQ 3), 
developments in environmental policy (e.g. 
WFD, MSFD & Natura 2000) to ensure 
continued relevance.   

2.  PC 

3.  Stakeholder consultations 

4.  Case studies 

1.  The extent to which EU citizens are aware 
and possibly affected by the status of 
European eel populations and the role of the 
Regulation in addressing this. 

1.  Qualitative assessment of public awareness of 

1.  PC.  

the issue and how it affects people. 

65 

 
 
 
 
Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ2   To what extent have the current 

1.  EMPs implemented and specific targets 

1.  Measurable progress towards EMP targets. 

1.  Analysis of Progress Reports 

EFFECTIVENESS 

measures for the recovery of 
European eel stock under the Eel 
Regulation met its objectives (see 
next column)?  

achieved. 

2.  European eel stock has recovered. 

3.  Anthropogenic mortalities (e.g. non-
fisheries related) have been reduced. 

4.  Adult eel escapement progressed towards 
the long term 40% escapement objective. 

2.  Recruitment indices for glass & yellow eels. 

2. 

ICES reports 

3.  Non-fisheries-related measures that have 
increase eel recruitment & survival. 

3.  Progress Reports, stakeholder consultations, 

case studies  

4.  Estimates of escapement levels in selected 

4.  Progress reports, scientific reports, 

key river basins. 

5.  Restocking rates by MS and 3rd countries, 

stakeholder consultations, case studies 

ICES data calls and price survey (<.12 cm) 

ICES, EUROSTAT & GFCM data. 

5. 

6. 

7.  EUROSTAT, CITES and other trade data.  
Supported by stakeholder consultations to 
obtain non-quantitative and anecdotal 
information on legal and illegal trade 
patterns.  

8.  EU and Member State control reports, 

stakeholder consultations and case studies.    

5.  Supply of glass eels sufficient for 

market price analyses. 

restocking operations. 

6.  Fishing effort reduced by at least 50% 

relative to the average effort 2004-2006 or 
ensure reduction of catches by at least 
50%. 

7.  Origin and traceability of all live eels 

imported and exported from MS territory 
maintained.  

8.  Control and enforcement activities in 

support of the implementation of the EMPs 
have taken place in EU waters and at all 
stages of the eel supply chain. 

6.  Eel landings49 by MS and 3rd countries. 

7. 

Inter-EU and extra-EU (banned since 2010) 
import and export levels. 

8.  Analysis of inspections / control activities 

carried out on eel fishing activities / farming 
across EU Member States (in marine and 
inland waters), content of controls and 
evidence as regards the enforceability of the 
measures for the recovery of the European 
eel stock under the Eel Regulation 

49 Fishing effort is not currently monitored by WGEEL, only landings 

66 

 
                                                           
Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EFFECTIVENESS 

EQ3.   If the measures for the recovery of 

1.  Identification of the key barriers to 

1.  Characterisation and if possible, 

European eel stock under the Eel 
Regulation have only partially met 
the objectives in EQ 1, what factors 
have they hindered their achievement 
and how?  

achieving the objectives. 

2.  Identification of the common and 

outstanding successes and resulting best 
practises that have allowed progress 
towards achieving the objectives. 

3.  Identification of best practices in 

transboundary areas. 

4.  Supply chain transparency and control 
points will need to be examined at key 
points within and on the borders of the EU, 
covering both inward and outward flows. 

5.  Have the control & enforcement measures 
at EU and MS levels been adequately 
resourced and implemented? 

EQ4.   To what extent has the Eel 

1.  Extent to which wild eel fisheries (i) 

Regulation contributed to achieving 
the objectives of the Common 
Fisheries Policy, in particular to 
ensure that fisheries and aquaculture 
activities are environmentally 
sustainable in the long-term and are 
managed in a way that is consistent 
with the objectives of achieving 
economic, social and employment 
benefits, and of contributing to the 

safeguard stock reproduction for high long-
term yield (ii) lay the foundations for a 
profitable industry, (iii) share out fishing 
opportunities fairly, and (iv) conserve 
marine resources. 

2.  Extent to which eel farming has been 

developed in  sustainable way that relieves 
pressure on wild stocks. 

3.  Extent to which (i) producers are enabled 

quantification of key barriers, including 
social, cultural, legal, trade, political, fiscal 
and technical issues. 

2.  Common approaches that have been causal in 
achieving measurable progress towards EMP 
targets (see above in EQ 1).   

3.  Common approaches in resolving 

transboundary eel conservation issues. 

4.  High level mapping of the main supply 

chains and critical control points at EU level 
and more detailed in DK, FR & IT to identify 
main internal and border control points.  
Based on this, evaluation of controllability 
and leakage.   

5.  Based on (3) above, examination of the main 
control measures and their adequacy at 
fishery, supply chain and border points. 

1.  Indicators include (i) long-term recruitment 
indices, (ii) profitability of key parts of the 
value chain, (iii) no evidence of unequal 
fishing opportunities and (iv) evidence of 
ecosystem benefits from eel conservation 
actions. 

67 

1.  Examination of EMPs and the resultant 
progress reports.  Discussions with 
stakeholders, and ‘deep dives’ at case study 
level.   

2.  Examination of EMPs and the resultant 
progress reports.  Discussions with 
stakeholders, and ‘deep dives’ at case study 
level.   

3.  Examination of EMPs and the resultant 
progress reports.  Discussions with 
stakeholders, and ‘deep dives’ at case study 
level.   

4.  Literature review, discussions with 

stakeholders, and ‘deep dives’ at case study 
level.  TRAFFIC reports are particularly 
relevant.   

5.  Examination of EMPs and the resultant 
progress reports.  Discussions with 
stakeholders (inc. control authorities), and 
‘deep dives’ at case study level.   

1.  Apart from the L/T recruitment indices, this 

will mainly be examined at case study level.     

 
 
 
Evaluation questions 

availability of food supplies. 

EFFECTIVENESS 

Judgement criteria 

Indicators 

Methods 

to best market eel products, (ii) purchasers 
along the supply chain are well informed 
and (iii) common marketing standards are 
maintained.   

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ 5 

 Are the effects likely to last after 
the intervention ends?  

1.  The extent to which measures implemented 
under the Eel Regulation have long-term 
impacts, even if the intervention were to 
cease. 

1.  Mainly qualitative analysis of the permanence 
and longer-term impact of fishing effort 
restrictions, river basin improvements (to assist 
survival and escapement) and restocking.   

1.  Case studies.   

SUSTAINABILITY 

EFFICIENCY 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ6.   To what extent have the costs 

associated with implementing the Eel 
Regulation been proportionate to the 
environmental and socio-economic 
benefits that this has generated?  
Could the same results have been 
achieved with less funding? 

1.  Extent to which the costs of administering, 
implementing and overseeing EMP actions 
have been balanced by the environmental 
and socio-economic benefits accruing from 
improved eel stocks. 

1.  Qualitative assessment of the costs and 

1.  Targeted stakeholder consultations.   

benefits. 

2.  Quantitative assessment of the costs 

(administration and implementation of the 
measures, compliance, opportunity and 
other) and benefits (environmental, social 
and economic accruing from the EMPs). 

2.  Case studies. 

3.  EMFF funding records (inc. recent FAME 

reports). 

68 

 
 
 
 
Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EFFICIENCY 

EQ7.   Could the use of other policy 

instruments or mechanisms have 
provided better cost-effectiveness? 

1.  The extent to which alternative options 
exist and an assessment of their relative 
cost-effectiveness and contribution to the 
objectives of the Regulation (see EQ 1).   

1.  Examination of the alternative options e.g. 
non-fisheries-related environmental (e.g. 
through the WFD, MSFD, Habitats 
Directive, etc) and trade (e.g. CITES) 
approaches to examine the additionality and 
cost-effectiveness of the measures under the 
Regulation.   

1.  Targeted stakeholder consultations.   

2.  Case studies.   

EQ8.   How timely and efficient is the 

process for reporting and monitoring? 

1.  The extent to which the tri-annual Member 
State reporting system works in terms of 
timeliness and sufficiency. 

1.  Examination of the responsiveness and 

1.  Member State Progress Reports.   

adequacy of Member State Progress Reports 
in identifying progress made against their 
EMP targets and the overall objectives of the 
Regulation. 

2. 

ICES WKEMP analyses 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

COHERENCE 

EQ 9   To what extent are the measures for recovery 
of the European eel stock under the Eel 
Regulation coherent with wider EU policy 
and interventions which have similar 
objectives (e.g. Common Fisheries Policy, 
fisheries control regulation, environmental 
legislation and in particular Water 
Framework Directive)? 

EQ10   To what extent are the measures under the 
Eel Regulation coherent with international 
obligations (e.g. under CITES and CMS)? 

1.  The extent to which wider fisheries and environmental 
policies remain coherent with the objectives and 
measures under the Eel Regulation. 

1.  Consultative identification of key 
conflicts or incompatibilities 
between EU polices and measures.   

1.  Desk research, with some 
stakeholder consultation.   

1.  The extent to which the Eel Regulation continues to be 
coherent with the current eel-related measures and 
commitments under (i) the Convention on International 
Trade in Endangered Species of Wild Fauna and Flora 
(CITES) and (ii) the Convention on Migratory Species 
(CMS). 

1.  Evaluation the latest CITES and 

1.  Desk study.   

CMS measures related to European 
eel conservation to determine 
consistency with the measures 
under the Eel Regulation.  

2.  Targeted stakeholder consultations 

e.g. with TRAFFIC, CITES 

69 

 
 
 
 
EU ADDED VALUE 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ 11  What is the additional value 

1.  Extent that the Eel Regulation has 

1.  There is consensus among MS Authorities and other 

1.  PC 

resulting from the EU measures for 
the recovery of European eel stock 
under the Eel Regulation, 
compared to what could reasonably 
have been expected from Member 
States acting at national and / or 
regional levels?  

provided additional impetus / support to 
address eel conservation objectives.   

stakeholders that the Eel Regulation has provided a significant 
boost to addressing barriers to eel stock recovery. 

2.  Extent that it is possible to isolate results 
and outcomes that could or would not 
have been otherwise achieved without 
the Eel Regulation. 

2.  It is possible to identify results / outcomes that can be directly 

attributed to the Eel Regulation. 

3.  There is consensus among MS authorities and stakeholders that 
the identified results / outcomes would not have been achieved 
without the Eel Regulation. 

2.  Targeted consultations 

3.  Case studies 

EQ12  What would be the most likely 

1.  Extent that MS authorities are able to 

1.  MS authorities and stakeholders identify main positive and 

1.  PC 

consequences of stopping the 
application of the measures as 
required in the Eel Regulation?  

identify positive and negative 
implications of stopping the application 
of the measures as regulated in the 
Regulation. 

negative implications. 

2.  Targeted consultations 

3.  Case studies  

70 

 
 
 
 
 
2.  Targeted Consultations stakeholders list 

Prospective list of stakeholders consulted in the Member States 

Member State  MS Competent authority 

Other stakeholders 

BE Belgium 

Landbouw en Visserij 

CZ Czechia 

Ministry of Agriculture 

DE Germany 

Federal Ministry of Food and 
Agriculture 

DK Denmark 
(Case Study) 

Ministry of foreign affairs, 
Fishery political office 

EE Estonia 

Fisheries Resources 
Department of Ministry of Envir
onment 

ES Spain 

Ministerio de Medio Ambiente y 
Medio Rural y Marino 

FI Finland 

Ministry of Agriculture and 
Forestry 

FR France 
(Case Study) 

Ministre de l'Agriculture et de 
l'AlimentationMinistère de 
l'Agriculture et de la pêche 

Amicale des Pêcheurs du Brabant (fishing society) 
Research Institute for Nature and Forest (INBO) (research body) 
Agency for Maritime Services and Coast (state agency) 
Brussels Institute for Management of the Environment (IBGE-BIM)  
Sustainable Eel Group (NGO) 

Czech Fishing Union (CFU) Board (fishery association) 
Czech Fish Farmers Association (fishery association) 
River Administrations (state agency) 

Institute of Inland Fisheries (state agency) 
Thünen Institute of Fisheries Ecology (research body) 
State research Centre of Agriculture and Fisheries (research body) 
German Fisheries Association (fishery association) 
German association of eel traders and eel farmers (Initiative zur 
Förderung des Europäischen Aals e.V, IFEA) (NGO) 
Albe fish farm GmbH & Co. KG (industry - farming) 
DEUTSCHER FISCHEREI VERBAND /Aalversandstelle (industry 
– restocking) 

Danish AgriFish Agency 
Danish Technical University (research body) 
Danish Fishermen’s Association (fishery association) 
Dansk Amatørfiskerforening (fishery association) 
DANISH AQUACULTURE ASSOCIATION (fishery association) 
Eel farm, Jupiter Ål (industry – farming) 
ROYAL DANISH SEAFOOD (eel farming, processing) 

Ministry of Agriculture, Fishery Economics Department (state 
agency) 
Estonian University of Life Sciences, Centre for Limnology 
(research body) 
Lake Vörtsjäve Fisheries Development Agency (industry – 
restocking coordination) 
Triton PR AS (industry – farming, processing) 

Department of Marine Investigation, AZTI (state agency / research 
body) 
VALENCIANA DE ACUICULTURA (industry – farming) 
Universitat Politécnica de Valéncia, Grupo de Acuicultura y 
Biodiversidad (research body) 

Natural Resources Institute Finland (state agency) 
Finnish Game and Fisheries Research Institute (research body) 
Federation of Finnish Fisheries Associations (fishery association) 
Finish Federation for Recreational Fishing (fishery association) 
Association of Sea Fishers in Southern Finland (fishery 
association) 
Finnish Association for Nature Conservation (NGO) 

Comité de gestion des poissons migrateurs (state agency) 
Direction de la Pêche et de l’Aquaculture (state agency) 
Museum National Histoire Naturelle (reseatch body) 
Comité National des Pêches et des Elevages Marins (fishery 
association) 
Comité National de la Pêche Professionnelle en eau douce (fishery 
association) 
Association pour le Repeuplement de l’Anguille (fishery 
association) 
OP ESTUAIRES (producers organisation) 

71 

 
Member State  MS Competent authority 

Other stakeholders 

GR Greece 

Ministry of Rural Development 
and Food 

IE Ireland 

Department of Agriculture, 
Food and the 
MarineDepartment of 
Communications, Energy and 
Natural Resources  

IT Italy 
(Case Study) 

Ministry of Agricultural, Food 
and Forestry 

LT Lithuania 

LU 
Luxembourg 

LV Latvia 

Fisheries Department of the 
Ministry of Agriculture of the 
Republic of Lithuania (Baltic 
Sea) 

Ministry of Environment (inland 
waters) 

Ministère de l'Agriculture, de la 
Viticulture et de la Protection 
des 
consommateursDépartement 
de l'environnement 

National Board of Fisheries of 
the Ministry of Agriculture 

NL Netherlands  Department of Fisheries - 

Ministry of Agriculture, Nature 
and Food Quality 

ETHNOCONSERVATION (NGO) 
Gurruchaga Maree SARL (industry – buyer) 

FISHERIES RESEARCH INSTITUTE (state agency / research 
body) 
University of Patras (research body) 

Department of Environment, Heritage and Local Government 
(state agency) 
Marine Institute (state agency / research body) 
Central Fisheries Board (fishery association) 
A Bord Iascaigh Mhara (BIM - The Irish Sea Fisheries Board) 
(state agency) 
Inland Fisheries Ireland (state agency) 

Centro di ricerca per la Zootecnia e l'Acquacoltura (ZA) (state 
agency / research body) 
Associazione Mediterranea Acquacoltori (fishery association) 
University of Bologna (research body) 
Emilia Romagna Region (regional authority) 
Federcoopesca Emilia Romagna (fishery association) 
AGCI AGRITAL – Emilia Romagna (fishery association) 
Federazione Italiana Pesca Sportiva e Attività Subacquee, Ferrara 
(fishery association) 
Ittica Luciani srl (industry – processing) 
Medusa (industry – processing) 

Nature Research Centre, Laboratory of Marine Ecology (research 
body) 
Environmental Protection Agency (state agency) 

Ministry of Environment (state agency) 
Latvian Fish Resources Agency (state agency) 
Latvian Anglers Association (fishery association) 

Dutch foundation of eel traders (NeVePaling) (fishery association) 
Dutch Association of fish farmers (NEVEVI) (fishery association) 
DUPAN Foundation (NGO) 
Nijvis Group (eel farms, traders, processors) 
IMARES / WAGENINGEN (research body) 
COMBINATIE VAN BEROEPVISSERS (fishery association) 
Glasaal Volendam BV (industry – hatchery) 

PL Poland 

Ministry of Maritime Economy 
and Inland WaterwaysMinistry 
of Agriculture and Rural 
Development 

Sea Fisheries Institute (state agency / research body) 
Stanislaw Sakowicz Inland Fisheries Institute (state agency / 
research body) 
Polish Anglers Association (fishery association) 
Alldan (industry – glass eel trading) 

PT Portugal 

Ministério do MarDirecção 
Geral das Pescas e Aquicultura 

Centre for Marine and Environmental Research (CIIMAR), Universi
ty of Portoo (research body) 
Portuguese Institute of Sea and Fisheries (INIAP/IPIMAR) 
(research body) 

SE Sweden 

Ministry for Rural Affairs 
Ministry of Environment and 

Swedish Agency for Marine and Water Management (state 
agency) 

72 

 
 
 
Member State  MS Competent authority 

Other stakeholders 

Energy – Natural Environment 
Division 

UK United 
Kingdom 

Department for Environment, 
Food and Rural Affairs  

Scandinavian Silver Eel (industry - farming) 
Skåne county board, Kristianstad (industry – restocking) 
Stockholm University, Baltic Sea Centre (research body) 
Swedish University of Agricultural Sciences, Institute of Freshwater 
Research (research body) 
Swedish Anglers Association (fishery association) 
Swedish Society for Nature Conservation (NGO) 

Environment Agency, Scottish Environment Protection Agency, 
Natural Resources Wales, Northern Ireland Environment Agency 
(state agencies) 
Marine Scotland Science (state agency / research body) 
Centre for Environment, Fisheries and Aquaculture Science 
(research body) 
Lough Neagh Eel (industry – fishery) / Lough Neagh Fishermen’s 
Cooperative Society (fishery association) 
Glass Eels Ltd (industry- trade) 
Severn & Wye Smokery (industry – processing) 

List of other stakeholders consulted 

Stakeholder 

Role / Remit 

Convention on International Trade in 
Endangered Species of Wild Flora and 
Fauna (CITES) – Scientific Services 

Convention of Migratory Species (CMS) – 
Aquatic Species Team 

European Association of Fish Producers 
Organisations (EAPO) 

European Inland Fisheries and Aquaculture 
Advisory Commission (EIFAAC) 

Europeche 

International agreement aiming to ensure that international trade of wild 
animals and plants does not threaten their survival. 

As an environmental treaty focused on the conservation and sustainable 
use of migratory species, including eels. CMS brings together the States 
where migratory animal species spend different parts of their life cycle 
including migratory routes, and lays the legal foundation for internationally 
coordinated conservation measures throughout a migratory range. 

Represents 38 Producer Organisations from 10 Member States. 

Promote the long-term sustainable development, utilization, conservation, 
restoration and responsible management of European inland fisheries and 
aquaculture, consistent with the objectives and principles of the FAO Code 
of Conduct for Responsible Fisheries and other relevant international 
instruments. 

Representative body for fishermen in the European Union representing 
around 45,000 vessels, both artisanal and large scale, 80,000 fishermen 
and counting 16 member organisations from 10 European countries. 

Fisheries and Aquaculture Monitoring and 
Evaluation (FAME) Support Unit 

Assists the European Commission in monitoring and evaluating the 
implementation of the EMFF. 

Fisheries Area Network (FARNET) Support 
Unit 

Joint EIFAAC/ICES/GFCM Working Group 
on Eels 

Low Impact Fishers of Europe 

Coalition Clean Baltic 

FARNET is the community of people implementing Community-Led Local 
Development (CLLD) under the European Maritime and Fisheries Fund 
(EMFF). This network brings together Fisheries Local Action Groups 
(FLAGs), managing authorities, citizens and experts from across the EU. 

Report on the status of the European eel stocks and provide advice to 
support development and implementation of EC Regulation No. 
1100/2007 for eel stock recovery. 

Aim to provide a clear and coherent voice at EU level for smaller scale 
fishers who use low impact fishing gears and methods. 

Joint NGO, comprised of NGOs from the countries of the Baltic Sea 
region, with goal of protecting and improving the Baltic Sea environment 
and natural resources. Eel status is one of their key working areas. 

Eel Stewardship Association 

The Eel Stewardship Association (ESA) is founder of the Eel Stewardship 

73 

 
 
 
Stakeholder 

Role / Remit 

Advisory Councils 

European Anglers Alliance 

Aquaculture Advisory Council (AAC) 

Baltic Sea Fisheries Forum (BALTFISH) 

North Western Waters Advisory Council 
(NWWAC) 

North Sea Advisory Council (NSAC) 

South Western Waters Advisory Council 
(SWWAC) 

TRAFFIC 

IUCN Anguillid Eel Specialist Group 

Fund and owner of the esf trademark. ESA was established in 2015 by 
industry organisations of the Netherlands and Germany and it is hoped it 
will be adopted elsewhere.  The main goal is to accelerate the eels 
recovery in Europe and adopting measure to ensure sustainable use of 
the stock. 

Advisory Councils e.g. Baltic Sea, North Sea, South-Western Waters, 
North Western Waters, Mediterranean, Aquaculture and Market. 

The European Anglers Alliance (EAA) is the pan-European organisation 
for recreational angling. 

This stakeholder-led organisation has as main objective to provide the 
European institutions and the Member States with recommendations and 
advice on issues related to the sustainable development of the sector. 

Regional body providing a platform for discussion on important fisheries 
issues in the Baltic Sea. 

A representative fisheries stakeholder body which is legally recognised as 
an organisation aiming an European Interest. It is established in Ireland 
and it produces regular advice on its own initiative or at request of the 
European Commission and the concerned Member States on all relevant 
matters related to fisheries management in the EC offshore waters within 
the EEZ of Ireland, part of United Kingdom and France (ICES areas Vb, 
VIa and VII). 

The NSAC prepares and provides advice on the management of fisheries 
in the North Sea on behalf of its members; fisheries organisations and 
other stakeholders including environmental organisations. 

The SWWAC brings together all actors who have an interest in Fisheries 
Management to put forward opinions to the European Commission and 
the Member States on the management of the fisheries in the South 
Atlantic. 

Wildlife trade monitoring network; an NGO working globally on trade in 
wild animals and plants in the context of both biodiversity conservation 
and sustainable development. 

A specialist IUCN group of experts seeking to promote research on 
anguillid species and advocate their conservation. 

74 

 
 
 
 
 
 
 
3.  Reference list of the literature consulted 

Acou A., Boisneau C. & Feunteun E. (2009). Prédiction des pics de dévalaison des anguilles argentées à 
partir des données environnementales : état des connaissances et développement d’un modèle opérationnel 
sur la Loire pour la gestion du turbinage. Rapport du Muséum National d’Histoire Naturelle, CRESCO, 
Dinard 

AZTI (2013).  I Jornadas españolas de lka Anguila. Irailak 28, 29, 30 de septiembre, 2013.  Palacio 
Miramar Jauregia. Donostia-San Sebastián.  Laburpen liburua Libro de resúmenes.  128 pp. 

Belpaire, C., Geeraerts, C., Evans, D., Ciccotti, E. & Poole, R. (2011). The European eel quality 
database: Towards a pan-European monitoring of eel quality. Environmental monitoring and assessment. 
183. 273-84. 10.1007/s10661-011-1920-2 

BMLFUW (2017). Nationaler Gewässerbewirtschaftungsplan 2015 [Austria national RBMP 2015]. Report 
from Bundesministerium fürLand‐  und Forstwirtschaft, Umwelt und Wasserwirtschaft 
(https://www.bmlfuw.gv.at/wasser/wisa/ fachinformation/ngp/ngp-2015/text/textdokument_ ngp2015.html)  

Butts, I.A.E., Sørensen, S.R., Politis, S.N., Tomkiewicz, J. (2016). First-feeding by European eel larvae: 
A step towards closing the life cycle in captivity. Aquaculture 464: 451-458. 

CITES (2017). Amendments to Appendices I and II of the Convention adopted by the Conference of the 
Parties at its 14th meeting, The Hague (Netherlands), 3–15 June 2007. Notification to the Parties. No. 
2007/022. 

CMS (2016). First Range State Workshop on the European Eel https://www.cms.int/en/meeting/first-
range-state-workshop-european-eel. 

Council of the European Union (1992). Council Directive 92/43/EEC of 21 May 1992 on the 
conservation of natural habitats and of wild fauna and flora, known as the Habitats Directive 

Council of the European Union (1996). Council Regulation (EC) No 338/97 of 9 December 1996 on the 
protection of species of wild fauna and flora by regulating trade therein 

Council of the European Union (2002). Council Regulation (EC) No 2371/2002of 20 December 2002 on 
the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy.   

Council of the European Union (2009).  Council Regulation (EC) No 1224/2009 of 20 November 2009 
establishing a Union control system for ensuring compliance with the rules of the common fisheries policy, 
amending Regulations (EC) No 847/96, (EC) No 2371/2002, (EC) No 811/2004, (EC) No 768/2005, (EC) 
No 2115/2005, (EC) No 2166/2005, (EC) No 388/2006, (EC) No 509/2007, (EC) No 676/2007, (EC) No 
1098/2007, (EC) No 1300/2008, (EC) No 1342/2008 and repealing Regulations (EEC) No 2847/93, (EC) 
No 1627/94 and (EC) No 1966/2006 

Council of the European Union (2017). Council agreement on 2018 fishing quotas in the Atlantic and 
North Sea.  Accessed at: https://www.consilium.europa.eu/en/press/press-releases/2017/12/13/council-
agreement-on-2018-fishing-quotas-in-the-atlantic-and-north-sea/pdf  

Council of the European Union (2018a).  Proposal for a Council Regulation fixing for 2018 the fishing 
opportunities for certain fish stocks and groups of fish stocks, applicable in Union waters and, for Union 
fishing vessels, in certain non-Union waters, and amending Council Regulation (EU) 2017 / 127 
http://data.consilium.europa.eu/doc/document/ST-5382-2018-INIT/en/pdf  

Council of the European Union (2018b). Atlantic and North Sea: Council agrees 2019 fishing quotas. 
https://www.consilium.europa.eu/en/press/press-releases/2018/12/19/atlantic-and-north-sea-council-agrees-
2019-fishing-quotas/  

Council of the European Union (2018c). Council Regulation (EU) 2018/120 of 23 January 2018 fixing  
for 2018  the  fishing opportunities for  certain  fish  stocks and  groups of  fish  stocks, applicable in  
Union waters and,  for  Union fishing vessels, in  certain  non-Union waters, and amending Regulation 
(EU) 2017/127. 168 pp. 

Council of the European Union (2019). Council Regulation (EU) 2019/124 of 30 January 2019 fixing  for  
2019  the  fishing opportunities for  certain  fish  stocks and  groups of  fish  stocks, applicable in Union 
waters and, for Union fishing vessels, in certain non-Union waters.  Official Journal of the European 
Union. 31.01.2019, 166 pp. 

75 

 
Crook, A (2010). Trade in Anguilla species, with a focus on recent trade in European Eel Anguilla 
anguilla.  June 2010.  A TRAFFIC Report prepared for the European Commission Contract 
070307/2007/479422/MAR/E2. 

Deelder, C. L. (1970). Synopsis of Biological Data on the Eel Anguilla anguilla L. FA0 Fishery Synopsis 
No. 80, Rome 1970, 84 pp. 

Dekker, W (2016).  Food for Thought.  Management of the eel is slipping through our hands! Distribute 
control and orchestrate national protection. ICES Journal of Marine Science (2016), 73(10), 2442–2452. 
doi:10.1093/icesjms/fsw094  

Dekker, W and L. Beaulaton (2016).  Faire mieux que la nature?  The history of eel restocking in Europe.  
Environment and History 22 (2016): 255–300. doi: 10.3197/096734016X14574329314407 

Dekker, W., B. Van Os & J. Van Willigen (1998).  Minimal and maximal size of eel.  Short Note. Bull. 
Fr. Pêche      Piscic. 349:195-197   

Environment Agency (2011). The Eel Manual.  GEHO0211BTMU-E-E Environment Agency, United 
Kingdom. 

European Commission (2003). Development of a Community Action Plan for the management of 
European Eel. Communication from the Commission to the Council and the European Parliament.  
Brussels, 01.10.2003COM(2003) 573 final.  https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52003DC0573&from=en  

European Commission (2008). Commission Decision 2008/292/EC of 4 April 2008 established that the 
Black Sea and the river systems connected to it did not constitute a natural eel habitat for European eel for 
the purposes of the Regulation. 

European Commission (2009). Commission Decision 2009/310/EC of 2 April 2009 approving requests 
by Cyprus, Malta, Austria, Romania and Slovakia for exemption from the obligation to prepare an Eel 
Management Plan in accordance with Council Regulation (EC) No 1100/2007. 

European Commission (2010). Summary of Conclusions. 54th Meeting of The Scientific Review Group 
on Trade in Wild Fauna and Flora. Brussels 3rd December 2010. https://circabc.europa.eu/sd/a/49ab3fc9-
646b-4b35-ac42-f0333479ce24/54_summary_srg.pdf  

European Commission (2011). Seas for life- Protected - sustainable - shared European seas by 2020 

European Commission (2014a).  Report from the Commission to the Council and the European 
Parliament. On the outcome of the implementation of the Eel Management Plans, including an  evaluation 
of the measures concerning restocking and of the evolution of market prices for eels less than 12 cm in 
length.  Brussels, 21.10.2014. COM(2014) 640 final. 

European Commission (2014b). Science for Environment Policy: DG Environment News Alert Service, 
edited by SCU, The University of the West of England, Bristol. Eels can be used to help monitor water’s 
ecological quality. 

European Commission (2015). EU Water Framework Directive. 
http://ec.europa.eu/environment/water/water-framework/info/intro_en.htm  

European Commission (2017). Implementation and evaluation of Regulation (EC) 1224/2009 establishing 
a Union control system for ensuring compliance with the rules of the common fisheries policy as required 
under Article 118 REFIT Evaluation of the impact of the fisheries regulation.  Report from The 
Commission to the European Parliament and the Council COM/2017/0192 final. 9 pp. 

European Commission (2018a). Directorate-General for Maritime Affairs and Fisheries – Unit D.3 
(2018): FAME SU Report EMFF use for the implementation of the Eel Regulation ', Brussels. 12 pp. 

European Commission (2018b). Evaluation Roadmap. Ref. Ares(2018)1986447 - 13/04/2018. See 
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447_en  

European Commission (2018c). IMPACT ASSESSMENT. Accompanying the document ‘Proposal for a 
Regulation of the European Parliament and of the Council on the European Maritime and Fisheries Fund 
and repealing Regulation (EU) No 508/2014 of the European Parliament and of the Council’ Commission 
Staff Working Document. {COM(2018)390final} -{SEC(2018)276final} 

European Commission (2019a). EFF and Eel Regulation.  Summary Report. European Commission - 
Directorate-General for Maritime Affairs and Fisheries, Unit D.3. Prepared by the FAME SU, Brussels 

76 

 
European Commission (2019b). Report from the Commission to the European Parliament and the 
Council on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive 
(2007/60/EC) Second River Basin Management Plans First Flood Risk Management Plans 

European Environment Agency (2017). Natura 2000 Network Viewer. http://natura2000.eea.europa.eu/# 

European Environment Agency (2018). European waters Assessment of status and pressures 2018. EEA 
Report No 7/2018. 

European Parliament & the Council of the European Union (2000). Directive 2000/60/EC of the 
European Parliament and of the Council of 23 October 2000 establishes a framework for Community 
action in the field of water policy. 

European Parliament & the Council of the European Union (2008). Directive 2008/56/EC of 17 June 
2008 establishes a framework for community action in the field of marine environmental policy. 

European Parliament & the Council of the European Union (2013). Regulation (EU) No 1380/2013 of 
the European Parliament and of the Council of 11 December 2013 on the Common Fisheries Policy, 
amending Council Regulations (EC) No 1954/2003 and (EC) No 1224/2009 & repealing Council 
Regulations (EC) No 2371/2002 & (EC) No 639/2004 and Council Decision 2004/585/EC. 40 pp. 

European Parliament & the Council of the European Union (2014).  Regulation (EU) No 508/2014 of 
the European Parliament and of the Council of 15 May 2014 on the European Maritime and Fisheries Fund 
and repealing Council Regulations (EC) No 2328/2003, (EC) No 861/2006, (EC) No 1198/2006 and (EC) 
No 791/2007 and Regulation (EU) No 1255/2011 of the European Parliament and of the Council.  Official 
Journal of the European Union L 149/1. 

European Parliament & the Council of the European Union (2017). Regulation (EU) 2017/1004 of the 
European Parliament and of the Council of 17 May 2017 on the establishment of a Union framework for 
the collection, management and use of data in the fisheries sector and support for scientific advice 
regarding the common fisheries policy and repealing Council Regulation (EC) No 199/2008.  Official 
Journal of the European Union. 30.06.2017, 21 pp. 

European Parliament & the Council of the European Union (2018). Proposal for a Regulation of the 
European Parliament and of the Council amending Council Regulation (EC) No 1224/2009, and amending 
Council Regulations (EC) No 768/2005, (EC) No 1967/2006, (EC) No 1005/2008, and Regulation (EU) No 
2016/1139 of the European Parliament and of the Council as regards fisheries control. COM/2018/368 
final. 91 pp. 

GFCM (2018).  Recommendation GFCM/42/2018/1 on a multiannual management plan for European eel 
(Anguilla anguilla L.) in the Mediterranean. Forty-second session of the Commission.  FAO headquarters, 
Rome, Italy, 22–26 October 2018. Appendices (p23-30). 

Hanel, R (2019). Research for PECH Committee – Environmental, social and economic sustainability of 
European eel management, European Parliament, Policy Department for Structural and Cohesion Policies, 
Brussels. Downloaded from 
http://www.europarl.europa.eu/RegData/etudes/STUD/2019/629189/IPOL_STU(2019)629189_EN.pdf on 
20/02/2019  

Hansson, S., Bergström, U., Bonsdorff, E., Härkönen, T., Jepsen, N., Kautsky, L., Lundström, K., 
Lunnery, S.-G., Ovegård, M., Salmi, J., Sendek, D., Vetemaa, M. |(2017). Competition for the fish–fish 
extraction from the Baltic Sea by humans, aquatic mammals, and birds. ICES Journal of Marine Science, 
fsx207 

ICES (1976). First report of the working group on stocks of the European eel, Charlottenlund, 27–31 
October 1975. ICES CM1976/M:2 (mimeo), 34 pp. 

ICES (2002). European eel. In CES Cooperative Research Report No. 255. p940 - 948 

ICES (2007). EC request on the Draft EU Guidelines for Eel Management Plans (Council Regulation n° 
1100/2007). 7 pp. 
http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2007/Special%20Requests/EC%20guidelines
%20for%20eel%20MP.pdf  

ICES (2008).  The report of the 2008 Session of the Joint EIFAAC/ICES Working Group on Eels, 
September 2008; ICES CM 2008/ACOM:15. 192 pp. and Country Reports. 

ICES (2009). European eel. In Report of the ICES Advisory Committee, 2009. ICES Advice 2009, Book 
9, Section 9.4.9. 4 pp.  

77 

 
ICES (2010a). European eel. In Report of the ICES Advisory Committee, 2010. ICES Advice 2010, Book 
9, Section 9.4.9. 9 pp. 

ICES (2010b).  The report of the 2010 Session of the Joint EIFAC/ICES Working Group on Eels, 
September 2010; ICES CM 2009/ACOM:19. 198 pp. 

ICES (2013a).  Report of the WGEEL. 13-15 May, Denmark. ICES CM 2013/ACOM:32. 

ICES (2013b). Report of the Joint EIFAAC/ICES Working Group on Eels (WGEEL), 18–22 March 2013 
in Sukarrieta, Spain. 4–10 September 2013 in Copenhagen, Denmark. ICES CM 2013/ACOM:18. 851 pp. 

ICES (2013c). Report of the Workshop on Evaluation Progress Eel Management Plans (WKEPEMP), 13–
15 May 2013, Copenhagen, Denmark. ICES CM 2013/ACOM:32. 757 pp. 

http://www.ices.dk/sites/pub/Publication%20Reports/Expert%20Group%20Report/acom/2013/WKEPEMP
/wkepemp_2013.pdf  

ICES (2013d). European eel. In Report of the ICES Advisory Committee, 2013. ICES Advice 2013, Book 
9, Section 9.4.7. 7 pp 

ICES (2014). Report of the Joint EIFAAC/ICES/GFCM Working Group on Eel, 3–7 November 2014, 
Rome, Italy. ICES CM 2014/ACOM:18. 203 pp.  

ICES (2015a). EU request on criteria for CITES non-detriment finding for European eel (Anguilla 
anguilla).  ICES  Special Request Advice, Northeast Atlantic. Published 30 April  2015. 7 pp.  

ICES (2015b). Report of the Workshop on Eel and CITES (WKEELCITES), 10–12 March 2015, 
Copenhagen, Denmark. ICES CM 2015/ACOM:44. 57 pp. 

ICES (2016a). Report of the Joint EIFAAC/ICES/GFCM Working Group on Eel (WGEEL), 24 
November–2 December 2015, Antalya, Turkey. ICES CM 2015/ACOM:18. 130 pp. 

ICES (2016b). Stock annex for the European Eel. Downloaded from 
http://www.ices.dk/sites/pub/Publication%20Reports/Stock%20Annexes/2016/Anguilla_anguilla_SA.pdf  

ICES (2016c). Report of the Workshop on Eel  Stocking (WKSTOCKEEL) , 20–24 June 2016, 
Toomebridge, Northern Ireland, UK. ICES CM 2016/SSGEPD:21. 75 pp 

ICES (2017a).  ICES Advice on fishing opportunities, catch and effort – European eel.  DOI: 
10.17895/ices.pub.3440 

ICES (2017b).  Report of the Working Group on Eels (WGEEL), 3-10 October 2017, Greece.  ICES CM 
2017/ACOM:15. 

ICES (2018a).  ICES Advice on fishing opportunities, catch and effort – European eel throughout its 
natural range.  Published 7 November 2018. https://doi.org/10.17895/ices.pub.4601 . 

ICES (2018b). EU request relating to estimates of stock parameters for European Eel Management Units.  
ICES Special Request Advice.  North Atlantic ecoregions. Published 17 December 2018. sr.2018.35, 10 
pp. https://doi.org/10.17895/ices.pub.4671  

ICES (2018c). Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL), 5–12 
September 2018, Gdańsk, Poland. ICES CM 2018/ACOM:15. 152 pp.  

ICES (2018d). Report of the Workshop for the Review of Eel Management Plan Progress Reports 
(WKEMP), 17–19 July and 13–16 November 2018, Copenhagen, Denmark. ICES CM 2018/ACOM:46. 
100 pp. 

ICPDR (2015). The Danube River Basin District Management Plan — Update 2015, International 
Commission for the Protection of the Danube River (http://www.icpdr.org/ main/activities-projects/river-
basin-management-plan- update-2015). 

ICPE (2015). Aktualisierung des Bewirtschaftungsplans nach § 83 WHG bzw. Artikel 13 der Richtlinie 
2000/60/EG für den deutschen Teil der Flussgebietseinheit Elbe für den Zeitraum von 2016 bis 2021, 
Flussgebietsgemeinschaft Elbe (https://www.fgg-elbe.de/berichte/aktualisierung- nach-art-13.html)  

ICPR (2015). The international river basin district Rhine (IRBD Rhine), 2nd RBMP from International 
Commission for the Protection of the Rhine (http://www.iksr.org/en/ water-framework-directive/river-
basin-management- plan-2015/index.html).  

Jacoby, D. & Gollock, M. (2014). Anguilla anguilla. The IUCN Red List of Threatened Species 2014: 
e.T60344A45833138. http://dx.doi.org/10.2305/IUCN.UK.2014-1.RLTS.T60344A45833138.en. 

78 

 
Jacoby, D., J. Casselman, V. Crook, M-B DeLucia, H. Ahnf, K. Kaifu, T. Kurwieh, P. Sasal, A. 
Silfvergrip, K. Smith, K. Uchida, A. Walker & M. Gollock (2015). Synergistic patterns of threat and the 
challenges facing global anguillid eel conservation. Global Ecology and Conservation 4 (2015) 321–333 

Kirkegaard, E. (Ed.), Aarestrup, K., Pedersen, M. I., Jepsen, N., Kirkegaard, E., Koed, A., ... 
Tomkiewicz, J. (2010). European eel and aquaculture. Charlottenlund: DTU Aqua. Institut for Akvatiske 
Ressourcer.  DTUAqua-rapport, No. 229-2010.  http://orbit.dtu.dk/files/6581078/229-2010_European-Eel-
and-Aquaculture.pdf  

Kottelat, M. and J. Freyhof (2007). Handbook of European freshwater fishes. Publications Kottelat, 
Cornol and Freyhof, Berlin. 646 pp 

Kroes, M., H. Wanningen, N. Breve and P. van Puijenbroek  (2015). 'Fish migration possibilities in the 
Netherlands; state of the art (barriers, solutions, monitoring), session E8, International Conference on 
Engineering and Ecohydrology for Fish Passage 
(https://scholarworks.umass.edu/cgi/viewcontent.cgi?referer=https://www.google.com/&httpsredir=1&artic
le=1949&context=fishpassage_conference)   

Motova, A. (2014).  Economic impact of eel trade ban – general trends. Study in support to the STECF 
2014. Publications Office of the European Union, Luxembourg, EUR 26941 EN, JRC 9253, 10 pp. 

MRAG (2017).  IUU Fishing Risk in and around Japan.  Final Report JP2278 for WWF Japan. 393 pp.  

NASCO (2015). Maintaining and improving river connectivity: The current position and experience in 
England (annex 4, CNL(15)43), Report at the Theme- based Special Session of the Council of NASCO 
(North Atlantic Salmon Conservation Organization) (http:// 
www.nasco.int/pdf/2015%20papers/CNL_15_43.pdf)  

Outhwaite, W. and Brown, L. (2018). Eastward Bound: Analysis of CITES listed flora and fauna exports 
from Africa to East and Southeast Asia 2006 to 2015.TRAFFIC International, Cam-bridge, United 
Kingdom. 

Pawson, M. (2012). Does translocation and restocking confer any benefit to the European eel population? 
A review. London: Sustainable Eel Group (SEG).   

Rhône-Mediterranée RBD (2016) 'Tableau de bord du SDAGE Rhône-Méditerranée — version mai 
2016' (http://www.rhone-mediterranee.eaufrance.fr/gestion/ sdage2016/tableau-de-bord.php) 

Sanada, Y. (2018).  News report on the catch of glass eels (eel larvae) and its import.  Downloaded from 
https://www.jwcs.org/data/180407NewsReportGlassEels_EN.pdf  

SEG (2018). Quantifying the illegal trade in European glass eels (Anguilla anguilla): Evidences and 
Indicators Sustainable Eel Group.  SEG-Report:2018-1-V1. 

Seine RBD (2016). Tableau De Bord du Schema Directeur D'amenagement et de Gestion des Eaux, Bilan 
2016, Bassin de La Seine et des Cours d'Eau Côtiers Normands (http://www.eau-seine-normandie.fr/ 
mediatheque/Dossier_partage/INSTITUTIONNEL/ SDAGE_2016_2021/TdB_SDAGE_2016_CB-
4.2_big.pdf)  

SEPA (2015). The river basin management plan the Scotland river basin district 2015‐ 2027, Scotland 2nd 
RBMP, Scottish Environment Protection Agency (https://www.sepa.org.uk/environment/water/river- 
basin-management-planning/the-current-plans/)  

Svedäng, H., and L. Gipperth (2012). Will regionalisation improve fisheries management in the EU? An 
analysis of the Swedish eel management plan reflects difficulties. Marine Policy, 36: 801–808 

TRAFFIC (2015). Overview of reported trade in Anguilla anguilla for 2012–2015, with a focus on illegal 
trade. Internal briefing prepared by TRAFFIC for the European Commission. Version 2. 

UNCLOS (1982). United Nations Convention on the Law of the Sea (UNCLOS) of 10 December 1982. 
http://www.un.org/Depts/los/convention_agreements/texts/unclos/UNCLOS-TOC.htm 

Van Ael, E., Belpaire, C., Breine, J., et al. (2013). Are persistent organic pollutants and metals in eel 
muscle predictive for the ecological water quality? Environmental Pollution, 186C, 165–171. 
DOI:10.1016/j.envpol.201 3.12.006.  

Walker, A.M., Andonegi, E., Apostolaki, P., Aprahamian, M., Beaulaton, L., Bevacqua, P., Briand, 
C.,  Cannas,  A7,    De  Eyto,  E.,  Dekker,  W., De  Leo, G., Diaz, E., Doering-Arjes, P., Fladung, E., 
Jouanin, C., Lambert, P., Poole, R., Oeberst, R. & Schiavina, M. (2011). Pilot projects to estimate the 

79 

 
potential and actual escapement of silver eel. Service Contract No. SI2.539598.  Lot 2. Final Report.  
Accessed from https://ec.europa.eu/fisheries/documentation/studies/silver-eel_en  

Wold, C. (2018). Options for Developing an Agreement Under the Convention on Migratory Species for 
European eels. Prepared for the Sargasso Sea Commission. 

WWF, European Environmental Bureau, the European Anglers Alliance and European Rivers 
Network (2018). Bringing life back to Europe’s Waters: The EU Water Law in Action. Lead authors: 
Martina Mlinaric (WWF-EU) and Jack Rhodes. 

80 

 
 
ANNEX 4: COMMISSION DECISIONS UNDER THE EEL REGULATION 

Member 
State 
BE 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
IE 
IT 
LT 
LU 
LV 
NL 

PL 
PT 
SE 
UK 

Commission decisions approving EMP 

C(2009)10510 final of 5.1.2010 
C(2009)9429 final of 30.11.2009 
C(2010)2133 final of 8.4.2010 
C(2009)10241 final of 22.12.2009 
C(2009)9358 final of 30.11.2009 
C(2010) 8218 final of 29.11.2010 
C(2010) 6360 final of 1.10.2010 
C(2010)1872 final of 29.3.2010 
C(2010)947 final of 15.2.2010 
C(2009) 5962 final of 30.7.2009 
C(2011)4816 final of 11.7.2011 
C(2009)10244 final of 22.12.2009 
C(2009)7681 final of 14.10.2009 
C(2009)9372 final of 30.11.2009 
1st decision: C(2009)7830 final of 20.10.2009 
Commission Implementing Decisions, amending EMP: 
C(2011)3930 final of 10.6.2011 and C(2018)2153 of 16.04.2018 
C(2009)10601 final of 6.1.2010 
C(2011) 2248 final of 5.4.2011 
C(2009)7699 final of 14.10.2009 
C(2010)1865 final of 13.4.2010 

C(2008)1217 of 04/04/2008 
2008/292/EC: Commission Decision of 4 April 2008 establishing that the Black Sea 
and the river systems connected to it do not constitute a natural habitat for European 
eel for the purposes of Council Regulation (EC) No 1100/2007 

C(2009)2231 final of 2.4.2009 
2009/310/EC: Commission Decision of 2 April 2009 approving requests by Cyprus, 
Malta, Austria, Romania and Slovakia for exemption from the obligation to prepare 
an  Eel  Management  Plan  in  accordance  with  Council  Regulation  (EC)  No 
1100/2007 (notified under document number C(2009) 2231) 

C(2012)3118 of 21/05/2012 
COMMISSION  IMPLEMENTING  DECISION  approving  the  Transboundary  Eel 
Management Plan for the Miño/Minho River submitted by Spain and Portugal to the 
Commission 
in  accordance  with  Council  Regulation  (EC)  No  1100/2007 
establishing measures for the recovery of the stock of European eel 

81 

 
 
 
 
 
ANNEX 5: EMP IMPLEMENTATION 

1.  Scope and availability of Member State EMPs and Progress Reports 

Availability of EMPs and 
Progress Reports 

s
s
e
r
g
o
r
P
t
s
1

)
2
1
0
2
(

t
r
o
p
e
R

s
s
e
r
g
o
r
P
d
n
2

)
5
1
0
2
(

t
r
o
p
e
R

s
s
e
r
g
o
r
P
d
r
3

)
8
1
0
2
(

t
r
o
p
e
R

Y 

Y 

Y 

Y 

N 

Y 

N (tables 
only) 
Y (no 
data 
tables) 
Y 

P
M
E

Y 

Y 

Y 

Y 

Y 

Y 

Y 

t
a
t
i
b
a
H

e
g
a
r
e
v
o
C

Freshwater 

Freshwater 

Freshwater 
Transitional 
Coastal 

Not 
confirmed 

Y 

Y 

N 

Y 

Y 

Y 

N 

Y 

Not 
confirmed 

Freshwater 
Transitional 
Coastal 

Freshwater 
Transitional 

Y 

Y 

N 

Y 

Y 

Y 

Y (no 
data 
tables) 
Y (missed 
tables 3 
& 7) 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y (no 
data 
tables) 

EMP Scope 

f
o
r
e
b
m
u
N

s
P
M
E

y
r
a
d
n
u
o
b
s
n
a
r
T

s
n
o
i
t
a
r
e
d
i
s
n
o
C

Member 
State 

l

e
E

t
n
e
m
e
g
a
n
a
M

)
.
o
N

(

s
t
i
n
U

Belgium 

Scheldt, Meuse (2) 

Czech 
Republic 

Germany 

Odra, Labe (2) 

Ems, Weser, Eider, 
Schlei/Trave, Maas, Rhein, 
Warnow/Peene, Elbe, Oder 
(9) 

Denmark 

Denmark inland (1) 

Estonia 

Narva River, West Estonia 
(2) 

1 

1 

9 

1 

1 

Spain 

Galicia, Asturias, Cantabria, 
Basque Country, Murcia, 
Navarra, Cataluña, Cuenca 
del Ebro, Valenciana, Castilla 
La ManchaIslas, Baleares, 
Andalucía (12) 

1 national 
EMP and 12 
specific EMPs 

Finland 

Entire Finland (1) 

France 

Greece 

Ireland 

Rhône – Méditerranée, 
Adour, Garonne, Loire, 
Bretagne, Seine-Normandie, 
Artois-Picardie, Rhin-Meuse, 
Corse (9) 
North-Western Greece, 
Western Peloponnesos, 
East Macedonia – Thrace, 
Central Greece - Aegean 
Islands (4) 

Eastern, North-Western, 
Western, Shannon, South 
Western, South-Eastern (6) 

1 

1 

1 

6 

EMP excludes 
trans-boundary 
river basins 
shared with 
Germany. 

Narva River 
shared with 
Russia; extent of 
collaboration not 
clear. 

The Minho 
International 
River Plan was 
developed with 
Portugal. 

Transboundary 
agreements in 
place with the 
United Kingdom 
for the Neagh 
Bann EMU. 

82 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EMP Scope 

Availability of EMPs and 
Progress Reports 

y
r
a
d
n
u
o
b
s
n
a
r
T

s
n
o
i
t
a
r
e
d
i
s
n
o
C

t
a
t
i
b
a
H

e
g
a
r
e
v
o
C

P
M
E

s
s
e
r
g
o
r
P
t
s
1

)
2
1
0
2
(

t
r
o
p
e
R

s
s
e
r
g
o
r
P
d
n
2

)
5
1
0
2
(

t
r
o
p
e
R

s
s
e
r
g
o
r
P
d
r
3

)
8
1
0
2
(

t
r
o
p
e
R

Freshwater 
Transitional 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Not 
confirmed 

Freshwater 
Transitional 
Coastal 

Freshwater 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

N 

Y 

Y 

Y 

Y 

N 

Y 

Y 

Y 

N 

Y 

Y 

Y 

N (tables 
only) 

Y 

Y 

Y 

Y 

Transitional 
Coastal 
Open Marine 

Freshwater, 
TransitionalC
oastal 

f
o
r
e
b
m
u
N

s
P
M
E

Of 20 EMUs, 
nine have 
prepared 
EMPs: 
Sadegna, 
Puglia, Lazio, 
Umbria, 
Toscana, 
Emilia-
Romagna, 
Veneto, Friuli 
Lombardia 
1 

1 

1 

1 

1 

Member 
State 

Italy 

l

e
E

t
n
e
m
e
g
a
n
a
M

)
.
o
N

(

s
t
i
n
U

 All 20 Italian Regions (note 
there is no eel fishing in 11 
of these) 

Lithuania 

Lithuania (1) 

Luxembour
g 

Maas, Rhein (2) 

Latvia 

Latvia (1) 

Nether-
lands 

Netherlands (1) 

Poland 

Oder, Vistula (2) 

Portugal 

Sweden 

United 
Kingdom 

Minho and Lima, Cávado, 
Ave & Leça, Douro,  
Vouga, Mondego, Lis & 
Ribeiras do Oeste, Tejo, 
Sado & Mira, Guadiana, 
Ribeiras do Algarve (8) 

Single unit, but reporting 
distinguishes between 
Inland Waters, Eastern 
region and Western region 

Northumbria, Humber, 
Anglian, Thames, South-
East, South-West. Severn, 
West Wales, Dee, North-
West, Solway, Tweed, 
Neagh Bann, North-East 
Northern Ireland, North-
West Northern Ireland, 
Scotland (17) 

2 (one 
national EMP 
and one 
transboundar
y EMP) 

The Minho 
International 
River Plan was 
developed with 
Spain. 

1 

14 

   Source:  External consultant review of EMPs and Progress Reports 

83 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.  Member State Progress in implementing their EMPs 

Member State 

Belgium 

Czech Republic 

Germany 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 

Management 
Measures 
Overview  
Commercial 
fisheries: 
Prohibiting 
fishing 
Commercial 
fisheries: 
Controlling 
poaching 

Recreational 
fishing: Gear 
restrictions 

Recreational 
fishing: Closed 
season 

Recreational 
fishing: 
Minimum 
landing size 
Installation of 
fish passes 

Restocking 

Other: 
Monitoring; 
Water and 
Habitat Quality 

Commercial 
fisheries: 
Prohibited 
Recreational 
fisheries: 
Closed season 
in autumn 
Recreational 
fisheries: 
Reduction in 
maximum catch 
to 2 specimens 
Recreational 
fisheries: 
Minimum 
landing size 
Monitoring: 
Mortality at 
hydropower 
plants; 
presence of 
parasitic 
nematodes 

Restocking 

Commercial 
and 
recreational 
fisheries Closed 
season 
Commercial 
and 

Achievement 
of escapement 
target? 
No 

Not clear 

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

2018 Progress Report states that since 2007 all commercial fisheries in 
inland waters in Flanders are prohibited. In Wallonia, commercial eel 
fisheries have been prohibited since (at least) 1954.  Report indicates 
decrease in commercial fisheries catches. 

Country Report indicates specific action taken since 2014 to seize illegal 
fishing equipment and suggests this has resulted in decreased offence 
rates. 

2018 Progress Report states that since 2009 recreational fisheries with 
fykes in the Scheldt river in Flanders are prohibited. This resulted in a 
decrease of catches.  In Wallonia fishing for eel was still possible 
between 2006 and 2016, but there was a release obligation during that 
period.  Since 2017, eel fishing is prohibited in Wallonia. 
2018 Progress Report states that since 2010 there is an obligation for 
recreational fishermen to release every fish caught during the night 
(whole year), and in the period from the 16th of April till the 31st of 
May (day and night), and this is estimated to have resulted in 
decreased catches. 

2018 Progress Report states that in 2013 MLS was raised to 300mm 
(relevant to Flanders only). 

2018 Progress Report shows continued increase in installation of 
passes (from 71 in 2008 to 198 in 2017). 
2018 Progress Report states that glass eels are stocked in March-April 
immediately after delivery (no quarantine period). The length at 
stocking is approximately 7 cm.  Annual restocking varies between 
~120 and ~550 kg glass eels, sourced from the UK or France. 
Country Report indicates other management measures have been 
implemented, but these are not reported on in the 2018 Progress 
Report.  Extent of implementation not clear.  Examples in Country 
Report include monitoring of eel contaminant levels for Water 
Framework Directive monitoring, and monitoring of eel mortality at 
pumping stations. 

2018 Progress Report (technical report; no tables provided) indicates 
decrease in fisheries by 50% from 2004-2006 to 2014-2016. 

2018 Progress Report (technical report; no tables provided) states 
there is limited data on recreational fishing.  Regulations have been 
enacted to ensure these measures are implemented. 

2018 Progress Report (technical report; no tables provided) describes 
studies, but not clear to what extent measures put in place to address 
observed mortality factors.  Notes likely increase in number of 
hydropower plants. 

2018 Progress Report (technical report; no tables provided) reports 8 
million individuals released in the EMP area 2010-2016. 

2018 Progress Report indicates that this measure has been fully 
implemented in two EMUs.  Within 33 % of the German eel river basin, 
a closed season has been introduced for eel.  Data indicates that fishing 
effort has decreased from 2008 across all EMUs. 

2018 Progress Report indicates measure has been fully or partially 
implemented across all EMUs.  Within about 96 % of the total German 

Variable; yes 
within some 
EMUs, no within 
others. 

84 

 
 
 
Member State 

implemented in 
all EMUs) 

Denmark 

Achievement 
of escapement 
target? 

No 
(anthropogenic 
mortality target 
achieved, but 
not escapement 
target) 

Management 
Measures 
Overview  
recreational 
fisheries: 
Minimum 
landing size 

Commercial 
and 
recreational 
fisheries: 
Restriction in 
coastal waters 

Restoration of 
river continuity 

Reduction in eel 
traps 

Trap and 
transport 

Restocking 

Monitoring 

Predator 
control: 
Cormorants 

Commercial 
fisheries: Gear 
controls 
Recreational 
fisheries: 
Closed period 
October to July, 
and gear 
controls 
Commercial 
and 
recreational 
fisheries: 
Minimum 
Landing Size 
Removing 
migration 
barriers 

Predator 
control: 
Cormorants 

Restocking  

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

eel river basin area, the minimum size valid for commercial fishermen 
and anglers for catching eels was increased to 45 or 50 cm; for 4 % of 
the water area the legislative implementation procedure is still in 
progress.  Data indicates that fishing effort has decreased from 2008 
across all EMUs. 
2018 Progress Report indicates that this measures has been fully or 
partially implemented across all EMUs where restocking is applicable.  
In some EMUs a ban on trawling has been in place since 2006; in others 
fishing has been completely prohibited since 2009, and across all EMUs 
there is very little commercial fishing for eel.  Data indicates that fishing 
effort has decreased from 2008 across all EMUs. 
2018 Progress Report indicates partial implementation in applicable 
EMUs.  A reduction in mortality caused by hydroelectric installations to 
near zero has so far not been achieved. 
2018 Progress Report indicates partial implementation in applicable 
EMUs. 
2018 Progress Report indicates failure to implement in one EMU, and 
full or partial implementation in other applicable EMUs.  The number of 
silver eels carried to areas without appreciable anthropogenic mortality 
has risen since 2008 and in the period 2013-16, at about 12.4 tonnes 
per year, more than doubled. In the EMU Weser, silver eels were 
transported right to the North Sea in 2013, as an experiment. In 2017, 
further Catch & Carry operations took place, which are to be continued 
in 2018 and beyond. 
2018 Progress Report indicates restocking plans have been fully or 
partially implemented across all EMUs where restocking is applicable.  
Overall, during the period 2014-2016 considered here, about 32.3 
million glass eels, 15.6 million advanced farm eels and 0.2 million 
bootlaces were restocked; less than planned in the EMP.  Regulations 
promote restocking in some EMUs, and in some EMUs targets for 
restocking have been raised from 2019. 
2018 Progress Report indicates studies undertaken, focusing on quality 
of eel restocking material, elver monitoring, yellow eel stock status and 
silver eel monitoring.  Studies are considered to have considerably 
improved the data situation on the eel stock and its dynamics in 
German inland and coastal waters. 
2018 Progress Report indicates full or partial implementation across 
applicable EMUs.  Regulations prevent significant damage by 
cormorants to fish stocks, including the eel stock, but there is limited 
evidence of any actions taken to control the cormorant population. 

2018 Progress Report notes reduction in fishing effort and catches. 

2018 Progress Report notes reduction in fishing effort and catches. 

2018 Progress Report notes increase from 360mm in 2009 to 400mm 
from 2013 onwards. 

2018 Progress Report indicates high number of migration obstacles 
removed, including two major hydropower stations and close to 100 
smaller dams and weirs. 
2018 Progress Report indicates reduction in breeding pairs of 
cormorants in line with the National Management Plan for Cormorants.  
Notes no research has been undertaken to evaluate the effect of this 
on the local eel population. 
2018 Progress Report indicates restocking has been fully implemented 
in line with EMP targets.  The Danish EMP proposed annual restocking 
of 0.8 million eels; the actual amount of restocked eel was 1.2-1.4 
million per year from 2010 to 2017. 

85 

 
Member State 

Estonia 

Management 
Measures 
Overview  

Spain 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 
implemented in 
all EMUs) 

Finland 

France 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 
implemented in 
all EMUs) 

Greece 

Restocking 

Commercial 
fisheries: 
Closure of 
fisheries / 
reduce fishing 
effort 
Commercial 
fisheries: 
Minimum 
Landing Size 
Recreational 
fisheries: 
Closure of 
fisheries / 
reduce fishing 
effort 
Predator 
control: 
Cormorants and 
mink 
Trap and 
transport 
Removing 
migration 
barriers 
Improve water 
quality 
Implement 
scientific 
studies 
Restocking 

Restocking 

Commercial 
fisheries: 
Fishing ban / 
Reduction in 
fishing effort 
Commercial 
fisheries: 
Quotas 

Commercial 
fisheries: 
Closed seasons 

Recreational 
fisheries: 
Fishing ban  

Restocking 

Commercial 
fisheries: 
Prohibition of 
fyke nets in 
lagoons 
Commercial 
fisheries: 

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

2018 Progress Report indicates restocking undertaken annually since 
2011.  Eels are restocked only into the waterbodies of Narva River 
Basin District, sourced from France or the Netherlands.  Stocking is 
funded partly by the Environmental Investment Centre and partly by 
fishermen. 

In some EMUs fishing days have been reduced, and in others eel fishery 
licensing has ceased, and in some cases fisheries have been totally 
closed. 

Achievement 
of escapement 
target? 
Yes, though high 
level of 
uncertainty in 
some 
calculations and 
most likely this is 
an overestimate 
Variable; yes 
within some 
EMUs, no within 
others 

No information available. 

Fishing seasons have been reduced and then further reduced in some 
cases in 2018-2019, fisheries have been closed (e.g. through 
designation of protected rivers and no further issue of fishing licences), 
and quotas (e.g. 4 eels or 1kg per day) have been introduced variously 
across EMUs. 

Programmes exist in some EMUs to manage cormorants and American 
mink. 

In some EMUs, hydropower companies have been obliged to trap and 
transport eels. 
Obstacles have been demolished and eel passes introduced variously 
across EMUs.  In some cases, turbines have been temporarily 
disconnected to enable migration. 

To be delivered via Water Framework Directive. 

Studies have, for example, investigated the potential impacts of 
hydropower turbines on eel. 

In some EMUs, caught eel is reserved for stocking. 
2018 Progress Report indicates ‘official’ restocking undertaken since 
2011 (~200,000 individuals per year), though suggestion it has been 
occurring since the late 1800s.  On average, since 2010 around 58 % of 
all restocking operations have been targeted at sea areas.  The 
restocking target of 0.5 million glass eels set out in the Eel 
Management Plan has not been achieved. 

Eel fishing ban is present across some EMUs, for various eel life stages.  
2018 Progress Report indicates number of fishing authorisations has 
generally decreased across EMUs from 2009 onwards.   

2018 Progress Report indicates eel fishing quota varies from 2010 
onwards across EMUs; no obvious trend. 

2018 Progress Report indicates fishery closures in place across all 
EMUs; duration of closures varies across EMUs and across marine and 
freshwaters.  In some EMUs if the eel quota by type of fishing is 
reached, the fishing season is closed for that type of fishing. 
2018 Progress Report indicates that recreational fishing for silver eel 
and glass eel is forbidden.  Yellow eel fishing deemed insignificant and 
recreational yellow eel fishing at night is banned. 
2018 Progress Report indicates variable annual restocking of glass eels 
from 2010 onwards.  Restocking effort varies significantly across EMUs.  
A proportion of eel catches are kept for restocking. 

The use of fyke nets, the traditional eel static fishing gear in Greece 
called “volkos” is totally prohibited in all lagoons and in the leased 
seaports in the Amvrakikos Bay. 

Fishing of small eel below 30 centimetres, for commercial exploitation, 
is banned throughout the country 

86 

Not clear 

Not clear; likely 
to be below 
target 

Not clear 

 
 
 
 
 
 
Member State 

Ireland 

Italy 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 
implemented in 
all EMUs) 

Lithuania 

Management 
Measures 
Overview  
Minimum 
landing size 
Commercial 
fisheries: 
Closed season 
Recreational 
fisheries: 
Fishing ban 

Restocking 

Commercial 
and 
recreational 
fisheries: 
Closure / catch 
and return 

Trap and 
transport 
programme 
(and other 
measures) to 
reduce 
migration 
barriers 
Improve water 
quality 
Commercial 
fisheries: 
Closed seasons 
Commercial 
and 
recreational 
fisheries: 
Minimum 
landing size 
Recreational 
fisheries: 
Quotas 
Predator 
control: Perch 
Installation of 
eel passes 

Restocking 

Commercial 
fisheries: 
Reduction in 
trap numbers 
Commercial 
and 
recreational 
fisheries: 
Closures 

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

Achievement 
of escapement 
target? 

Eel fishing is totally prohibited in rivers and rivers delta in an area 3 
nautical miles from the estuaries from 1st November to the end of 
January every year.  Additional closures in some EMUs. 

Recreational eel fishing is totally prohibited in Greece 

Intensive aquaculture producers are obliged to give 10% (of the glass 
eel they buy as fries for their business) for restocking.  Authorized 
lagoon extensive aquaculture operators are obliged to give 30% of the 
eel they harvest, for restocking.  2018 Progress Report indicates 
variable annual restocking of glass, silver and yellow eels from 2012 
onwards, 
All management regions confirmed total closure of the eel fishery for 
the period 2009 to 2014 with no commercial or recreational licences 
issued.  All commercial fisheries remained closed in 2016 and 
recreational fisheries, confined to angling, were obliged by law to 
release all eels caught.  Despite the closure of commercial eel fishing in 
Ireland, a number of instances occurred whereby eel transport lorries 
were detected transferring eels apparently from N. Ireland (L. Neagh 
fishery) to Britain or mainland Europe. Continued closure of the eel 
fishery in Ireland will be subject to review of eel stocks in relation to 
the EU Council regulation and consequent recovery of European eel 
stocks.    

Extensive trap and truck programmes on the Shannon, Erne and Lee 
river systems.  2015 Progress Report indicates annual silver eel trap 
and truck efforts. 

Implemented via the Water Framework Directive. 

2018 Progress Report provides evidence of closed seasons of varying 
lengths across all EMUs.  Evidence of reduced fishing effort. 

2018 Progress Report indicates minimum size increased from 300mm 
to 500mm in 2014. 

2018 Progress Report indicates quotas in place in some EMUs (e.g. 5 
silver eel per fisherman reduced to 2 silver eel per fisherman in 2011). 

2018 Progress Report provides evidence of perch control in some 
EMUs. 
2018 Progress Report provides evidence of eel passes being installed in 
some EMUs. 
2018 Progress Report provides evidence of glass eel restocking, which 
varies in quantity across EMUs, and which in most EMUs has not been 
undertaken annually, but sporadically since the EMPs were prepared.  
Proportion of caught eels required to be retained for restocking.  
Restocking has typically not met targets and restocking has in most 
EMUs been with eels larger than 12cm. 
2018 Progress Report provides evidence of implementation; in 2008 
gear quota for Lagoon fyke nets in the Curonian Lagoon was 413 and 
from 2009 onwards this has been limited at 223. 

2018 Progress Report provides evidence of implementation; yellow eel 
fishery in the inland has been closed from 2015. Specialised fishery for 
eels in coastal waters is banned. 

Yes, in all but 
one EMU. 

No 
(anthropogenic 
mortality target 
achieved in some 
EMUs, but not 
escapement 
target). 

Reduced fishing 
effort. 

No 

87 

 
 
 
Member State 

Management 
Measures 
Overview  

Recreational 
fisheries: Quota 

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

2018 Progress Report provides evidence of implementation annually 
since 2009; reduction in daily bag limit to 3 specimens; before 2009 this 
was 5. 

Achievement 
of escapement 
target? 

Luxembourg 

Latvia 

Netherlands 

Poland 

Removing 
migration 
barriers 
Predator 
control by 
reduction in 
cormorant 

Restocking 

Removal of 
migration 
barriers 
Commercial 
and 
recreational 
fisheries: 
Minimum 
landing size 

Recreational 
fisheries: Quota  
Removal of 
migration 
barriers 

Restocking  

Commercial 
fisheries: 
Closed season  
Commercial 
fisheries: 
Minimum 
landing size 
Commercial 
fisheries: 
Closed areas 
Recreational 
fisheries: Catch 
and release 
Reduction in 
barriers to 
migrations  

Restocking 

Commercial 
and 
recreational 
fisheries: 
Closed season 
Commercial 
and 
recreational 
fisheries: 
Minimum 
landing size 
Commercial 
fisheries: More 
selective gears 
Commercial 
fisheries: 
Limiting 
poaching 

No evidence of implementation 

No evidence of implementation 

2018 Progress Report provides evidence of implementation annually 
since 2011 (peaked in 2013 and declined since) 

No evidence of implementation; not covered in 2016/17 Country 
Reports or 2018 Progress Reports 

No 

No 

2018 Progress Report provides evidence of implementation annually 
since 2016 with introduction of 500mm limit. 

2018 Progress Report provides evidence of implementation annually 
since 2016 with introduction of bag limit to 3 specimens. 

No evidence of implementation 

2018 Progress Report provides evidence of implementation annually 
since 2011, with sporadic restocking of up to ~270kg glass eel per year. 

2018 Progress Report provides evidence of implementation annually 
since 2009 with closed fishing season running from September to 
December.  Any changes in fishing effort not reported. 

No 

2018 Progress Report provides evidence of implementation with 
minimum size of 280mm. 

2018 Progress Report provides evidence of implementation annually 
since 2009 with the closure of eel fisheries in contaminated areas. 

2018 Progress Report provides evidence of implementation since 2009. 

2018 Progress Report indicates intention to reduce mortality at 
hydroelectric/pumping stations, but no evidence of implementation 
provided. 
2018 Progress Report indicates implementation with records of glass 
and yellow eel restocking since 1946,  Average restocking of glass eel 
~800kg per year between 2009 and 2017 (4,300kg average for yellow 
eel per year over same period). 

2018 Progress Report provides evidence of implementation annually 
since 2010 with closed fishing season running from December to 
March.  Closed season expanded from 30 days to 120 days in 2016. 

No 

2018 Progress Report provides evidence of implementation annually 
since 2010, with minimum size of 500mm. 

Gear selectivity requirement adopted in 2016; minimum mesh bar 
length set for fishing nets/sieves (20mm). 

No evidence of implementation. 

88 

 
 
Member State 

Portugal 

Sweden 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 
implemented in 
all EMUs) 

Management 
Measures 
Overview  
Recreational 
fisheries: Daily 
catch limits 
Eel passes and 
other measures 
to reduce 
migration 
barriers 
Predator 
control by 
reduction in 
cormorant 

Restocking 

Commercial 
fisheries: 
Prohibit fishery 
outside of 
certain areas 
Commercial 
fisheries: Gear 
restrictions 
Commercial 
fisheries: Catch 
reporting 
required to 
obtain new 
annual licence 
Commercial 
fisheries: 
Closed season 
(October – 
December) 
Commercial 
fisheries: 
Reduce number 
of licences 
Recreational 
fisheries: 
Prohibited 
Mitigate impact 
of existing 
migration 
obstacles 
Monitoring: 
Monitoring and 
control of glass 
eel poaching 
Monitoring: 
Stock studies 
Commercial 
fisheries: 
Closed seasons 
and areas 
Recreational 
fisheries: Ban 
Trap and 
transport 
programme 

Restocking of 
glass eel 

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

2018 Progress Report provides evidence of implementation annually 
since 2010, with limit of 2 specimens per day 9from 4 previously). 

Achievement 
of escapement 
target? 

No evidence of implementation, though areas selected within National 
Parks to develop unobstructed spawning migration routes for silver eel 
and information regarding migration obstacles has been gathered. 

No evidence of implementation 

No restocking data provided in 2018 Progress Report, though 2016/17 
Country Reports indicate restocking in 2010.   

Not clear 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
fully implemented in marine waters and partially implemented in 
freshwater. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
partially implemented. 

No 

No 2018 Progress Report available; 2016/17 Country Report suggests 
implemented. 

No 2018 Progress Report available; 2016/17 Country Report suggests 
partially implemented. 
From 2007, licence is required to fish and this was followed by 
additional restrictions.  Since 2012, closed seasons introduced.  Fishing 
along west coast prohibited. 2018 Progress Report provides evidence 
of reductions in fishing effort.   
2018 Progress Report indicates implementation of ban since 2007 (with 
some exempted locations). 
2018 Progress Report provides evidence of implementation.  
Hydropower companies have performed stocking of quarantined glass 
eel at the Swedish west coast as a voluntary measure, and in some 
cases infrastructure has been remodelled to enable migration.  Country 
Report indicates trap and transport programme saw movement of 
47,000 silver eels between 2011 and 2014 and that programme 
continued to at least 2017. 
2018 Progress Report provides evidence of implementation annually 
since 2010.  Country Report indicates target for restocking was 2.5 
million individuals annually and that this target has typically been 
reached with an exception in 2015. 

89 

 
 
Achievement 
of escapement 
target? 
Variable; yes 
within some 
EMUs, no within 
others. 

Member State 

United Kingdom 

(Note 
management 
measures vary 
by EMU; i.e. not 
all measures are 
implemented in 
all EMUs) 

Management 
Measures 
Overview  
Commercial 
fisheries: 
Fishery ban / 
quota 
Commercial 
fisheries: 
Closed seasons 
Commercial 
fisheries: Gear 
restrictions 
Commercial 
fisheries: 
Minimum 
landing size 
Recreational 
fisheries: 
Fishery ban / 
catch and 
release 
Measures to 
prevent eel 
entrainment in 
river structures, 
including fish 
recovery and 
return systems 

Monitoring 

Improvement 
of eel habitat 

Restocking  

Implementation of Management Measures (based on ICES 
2013a, ICES 2017b and Progress Reports) 

2018 Progress Report provides evidence of implementation, with 
effective eel fishery bans or zero quota measures in place in some 
EMUs. 

2018 Progress Report provides evidence of implementation with closed 
seasons for next and trap fishing since 2010. 

2018 Progress Report indicates limitations on some gear types in some 
EMUs (e.g. removal of fyke net as a legal fishing means in Northern 
Ireland). 

2018 Progress Report provides evidence of implementation, with MLS 
raised to 400mm in some EMUs. 

2018 Progress Report provides evidence of implementation, with either 
effective fishery bans or 100% catch and release measures in place 
since 2009. 

2018 Progress Report provides evidence of implementation; significant 
number of eel passes installed and refurbished, and screens installed at 
water intakes. 

2018 Progress Report provides evidence of implementation with 
creation of glass eel monitoring sites; monitoring distribution of 
parasitic worm A. crassus; various other funded studies. 
2018 Progress Report provides evidence of implementation with 
wetted area assessments for migration barrier impacts 
2018 Progress Report provides evidence of implementation, though 
restocking is limited and most significant in Neagh/Bann EMU (up to 
~2700kg) – here restocking targets have rarely been reached (only in 
2014 over the past decade). 

Source:  External consultant review of EMPs and Progress Reports 

90 

 
 
 
 
 
3.  Good practices in eel conservation 

FISHERIES 

1)  The  development  of  multi-stakeholder  platforms  in  the  preparation  of 
regional EMPs in Italy is considered a particular success. The process involved 
all  relevant  operators,  including  fishers,  vallicoltura50  farmers  and  aquaculture 
operators. It has been beneficial in: (i) raising awareness of the danger to the eel 
stock among local fishers; and (ii) tailoring the measures to the local conditions 
and habitats (e.g. in deciding when the rest period could be more effective while 
taking into account also the interests of local fishers, or where restocking would 
have higher success rates). 

2)  A series of best practice guidance has been produced in the UK, including the 
‘Eel  Manual’  that  has  four  components  covering  (i)  eel  and  elver  passes,  (ii) 
screening at intakes and outfalls: measures to protect eel, (iii) stocking European 
eels and (iv) monitoring elver and eel populations (Environment Agency, 2011).  
This  document  was  developed  from  recommendations  made  at  a  workshop  of 
shared  practical 
experienced  practitioners,  bringing 
experiences  and  lessons  that  have  been  learnt  so  far.  ES  has  also  produced  a 
guidance  manual  around  five  themes  (Management  Plans,  Eel  Monitoring  and 
Management  Methods,  Aquaculture  and  Marketing,  Fisheries,  Research  and 
Management  Measures)  as  a  result  of  a  series  of  national  conferences  (AZTI, 
2013). 

together  expertise, 

3)  Restocking obligation: FR implemented a national glass eel catch quota further 
broken down in  two sub-quotas: a sub-quota for  consumption (40%)  and  a sub-
quota for restocking (60%). The restocking sub-quota ensures reservation of part 
of  the  catch  potential  for  this  purpose.  The  measure  is  further  supported  by  a 
modification of the sales notes format, which has to specify the destination of the 
concerned catches. 

4)  Granting  restocking  financial  support  through  a  State  Aid  scheme  rather 
than through EMFF. The EMFF rules prevent  release of  advance payments  to 
beneficiaries,  and  this  was  seen  as  a  major  impediment  for  the  attractiveness  of 
the  measure. Given this,  in  France authorities preferred not  to  open the relevant 
EMFF measure, and to implement financial aid for restocking through a State Aid 
Scheme  that  allows  releases  of  advanced  payments  to  beneficiaries.  The  French 
authorities  applied  a  similar  approach  to  support  silver  eel  release  in  the 
Mediterranean with aids granted under the scope of the de minimis state aid rules. 
These measures contributed to improve implementation of eel stock enhancement 
measures by professional organisations. 

NON-FISHERIES 

1)  There  have  been  some  local  successes  in  terms  of  habitat  restoration  and 
improved spawner connectivity.  In Italy’s Emilia Romagna region fish ladders 
have been opened on the rivers Po and Reno and are planned on the Savio. In the 

50 Traditional rearing, usually of wild stocked juveniles, in lagoons, mainly in Italy 

91 

 
 
 
 
 
                                                           
Reno ladder, eel passage has already been observed; in the Po river, a dedicated 
monitoring tool for eels is soon to be installed. The intervention on the Po River 
is  expected to  allow eels to  return to  a very large hydrographic basin,  including 
Italian Northern lakes, such as Garda.  IT considers the target of 60% escapement 
could be achieved by 2050, and their intermediate target of 17.5% escapement by 
2020  has  already  been  achieved.    IT  attempts  to  focus  restocking  efforts  on 
protected  waters,  often  using  glass  eels  from  the  same  watershed,  to  increase 
potential spawner numbers.  

2)  In FR, L’Agence de la Biodiversité (eaufrance) has conducted a national census 
of all obstacles across rivers, which did not exist prior to the adoption of the FR 
EMP. Although relevant information was only available for certain areas in some 
EMUs, and not harmonised, the result is the ROE online database (Référentiel des 
Obstacles à l’Écoulement) which is maintained and updated. 

3)  Modelling periods for temporary switch-off of electric turbines: in the Loire 
area a scientific model (Acou et al. 2009) has been developed and further refined 
to identify the best periods for temporarily switching-off of electric turbines with 
a reasonable accuracy. This facilitated the implementation of the measure, which 
from  operators  perspective,  should  only  be  implemented  when  necessary  due  to 
the high associated foregone revenues. Similar models are yet to be developed or 
refined for other EMUs. 

TRACEABILITY AND CONTROL 

1)  Improved batch traceability through ‘simple permitting scheme’.   

In  Greece  a  national  system  for  controlling  intra-EU  trade  in  European  eel  is 
implemented by issuing 'simple permits'. With these simple permits from/to other 
European  countries,  after  checking  all  the  relevant  documents,  intra-imports  / 
intra-exports  are  certified  preventing  any  illegal  and  non-conforming  export  (in 
other EU MS) of such specimens. This mechanism is implemented by the Greek 
Regional  Management  Authorities  after  consultation  with  the  relevant  Regional 
Fisheries Authorities according to the following procedure: 

  Α  three-member  regional  committee  is  present  during  all  harvests.  For 
each harvest batch this committee issues a Certificate of Restocking only 
after the free release of 30% of the batch for restocking purposes. 

  The committee issues a written Certificate of Legality for each eel batch, 
certifying  that  this  is  produced  in  accordance  with  National  and 
Community  legislation,  including  cohesion  with  the  National  Eel 
Management Plan. So the batch is legal for trade in Greece. 

  The  Greek  Regional  Management  Authorities  of  the  CITES  Convention 
issue the so-called 'simple permits' so the batch is permissible for intra-EU 
trade. 

2)  Increased monitoring of eel catches by an e-declaration system 

The Telecapêche electronic reporting and data processing platform was developed 
by professional fishermen and has now been used for over five  years, mainly in 
France but more recently on the River Parret in the UK. It allows the professional 
fishing  organisations  to  submit  real-time  catch  declarations  (via  SMS)  and  to 
have access to total catches landed. 

92 

 
 
NL  implemented  an  electronic  weekly  catch  registration  system  for  yellow  and 
silver  eel  fisheries.  However,  the  system  does  not  allow  specification  of  the 
maturity stage of eel caught. 

3)  Some MS have implemented electronic “net to plate” traceability systems (e.g. 
DK,  ES,  SE).  SE  is  considering  extending  the  scope  of  the  national  traceability 
system to freshwater products, which will unambiguously cover eels at all stages 
irrespective of the nature of the ecosystem from where they originate. 

4)  Several  MS reported utilisation of  modern technologies  to detect illegal gears 
deployed to catch yellow and silver eels. Modern technologies include drones (i.e. 
DK, EE, LT, LV, PL, SE) and side scan sonars (i.e. DE, LV and UK). Detection 
of  illegal  fishing  activities  targeting  glass  eels,  which  take  place  mostly  during 
night hours, is supported by the utilisation of heat detectors and night binoculars 
(DK, FR and UK). 

5)  In MS where illegal trafficking of live glass eels is suspected to occur, the control 
burden  is  shared  by  the  different  national  police  authorities,  with  main 
national  police  corpses 
intelligence  and  coordination  (i.e. 
in  charge  of 
Gendarmerie in FR, Guardia Civil in ES). 

6)  DK,  SE,  UK,  and  PL  in  a  near  future,  have  implemented  systems  to  facilitate 
reporting to Authorities of suspected infringements to fishing rules by citizens. 
Systems implemented include dedicated websites (DK, SE and PL) or telephone 
hotlines (UK). 

93 

 
 
 
 
 
 
 
ANNEX 6: EUROPEAN EEL STATUS AND IMPACTS ON THE STOCK 

Life cycle of the European eel 

The newly hatched larvae in the Sargasso Sea drift with the Gulf Stream and the North 
Atlantic Current to the continental shelf of Europe where they metamorphose into glass 
eels  that  enter  continental  waters at  an  age of approximately 1-2  years.  Glass  eels  then 
settle in estuaries or migrate further up in the river basin before they become yellow eels 
settling for 2-25  years (or even 50  years) prior to maturation and metamorphosis to the 
silver eel stage. The European eel life cycle is shorter for population in the southern part 
of their range compared to the north. An adult distribution covers freshwater habitats and 
adjacent  brackish  and  coastal  marine  waters  of  Iceland  and  Europe  from  Norway 
southward,  Northwest  Africa,  and  the  Mediterranean  and  Black  Sea  watersheds  of 
Turkey and the Middle East. 

Figure  11:  The  life  cycle  of  the  European  eel  (source  ICES  2013c,  diagram:  Willem 
Dekker). 

State of the European eel 

The  Commission  monitors  the  status  of  the  European  eel  based  on  recurring  scientific 
advice and ad-hoc specific requests. The International Council for the Exploration of the 
Sea (ICES) delivers annual advice on the state of the eel stock, the management of the 
fisheries and other anthropogenic factors impacting the eel, revealing long-term declines 
in  the  abundance  of  the  stock  and  in  recruitment.  The  reports  of  the  joint 
EIFAAC/ICES/GFCM Working Group on Eel (WGEEL) document the ongoing process 
of describing the stock state and developing a methodology  for  giving scientific advice 
on management to effect a recovery of the stock. 

94 

 
 
 
According  to  ICES,  the  European  eel  (Anguilla  anguilla)  stock  remains  in  dramatic 
decline,  recruitment  is  at  an  all-time  low,  and  exploitation  of  the  stock  is  currently 
unsustainable. 

ICES  have  advised  for  about  20  years  on  a  precautionary  basis  that  all  anthropogenic 
mortality  affecting  production  and  escapement  of  eels  should  be  reduced  to  as  close  to 
zero as possible. The ICES stock advice published in November 2018 confirms that the 
status of eel remains ‘critical’ and that recruitment remains low (see Figure 12 below), 
and  the  decline  in  recruitment  is  mirrored  by  a  long-term  decline  in  commercial  and 
recreational fishery landings despite significant re-stocking efforts. 

Figure 12: Eel recruitment indices 

Eel recruitment indices strongly declined from 1980 to about 2010, and have remained at 
a  low  level  since.  The  annual  recruitment  of  glass  eel  to  European  waters  in  2018  was 
2.1%  of  the  1960–1979  level  in  the  ‘North  Sea’  series  and  10.1%  in  the  “Elsewhere 
Europe” series. The annual recruitment of young yellow eel to European waters in 2018 
was 29% of the 1960–1979 level (ICES, 2018a). 

Fisheries impact 

Fisheries impact local eel populations and spawner escapement in 15 out of 20 countries 
reporting to the WGEEL (ICES 2017b). In total, fisheries make up for more than 50% of 
anthropogenic  mortality  in  29  of  62  EMUs,  where  data  for  fishing  and  hydropower 
mortality was reported. 

According  to  ICES  estimates,  in  2017  the  EU  harvested  around  2,300  tonnes  of  eels 
(ICES, 2018c) with FR, UK, DK and SE taking around two-thirds of the EU wild catch 
between  them.  Tunisia  (149  t),  Turkey  (38  t)  and  Norway  (10  t)  are  the  main  non-EU 
producers  of  yellow  and  silver  eels.  This  is  less than  a  quarter  of  the  1990  landings  of 
around 10,000 t and since 2011 glass or yellow / silver eel wild production has stabilised 
at historically low levels (see Figure 13). 

95 

 
 
 
 
 
 
Figure 13: Yellow and silver eel fishery landings by country 

Figure 14: EU wild eel fishery production 

Source: ICES Working Group on Eels (ICES, 2018c) 

96 

 
 
 
 
Recreational landings/non-commercial fishing (the capture or attempted capture of living 
aquatic resources mainly for leisure and/or personal consumption), mainly of yellow and 
silver eels which during the 1980’s exceeded over 1,000 t in FR alone, are now around 
161 t, mostly from DK and DE, but MS reporting is now limited. Recreational fisheries 
for glass eel used to exist in FR and ES but have been forbidden in FR since 2010. IE and 
SE also ban recreational fisheries. Recreational landings were estimated as 2 t for glass 
eel in 2018 (ICES, 2018c). 

Figure 15: Recreational eel catches in the EU (2005 - 2017) Source: ICES, 2018c 

Recreational catches of eels can be significant (≈ 500 tonnes per year) in certain MS (e.g. 
DE, DK, FR, IT, PL) that did not prohibit recreational fishing for eels at certain stages, or 
at any stage. 

Additional  unaccounted  catches  from  IUU  glass  and  silver  eel  fisheries  exist  (SEG, 
2018). 

Fishing effort 

The most recent results on fishing effort for the six top eel fishing MS in the EU (UK, 
DK, SE, DE, IT, PL) is presented in the  Figure 16. Note that FR did not submit effort 
data in 2018. 

97 

 
 
 
Figure 16: Fishing effort of the six major eel producers in the EU 

United Kingdom 

Denmark 

Sweden 

Germany 

Italy 

Poland 

98 

 
 
 
 
 
Source: Data extracted from Form 7 of ICES data call (ICES, 2018c). 

Aquaculture production 

Aquaculture  production  of  eels  increased  until  the  end  of  the  1990s.  It  started  to  decline  since  the  mid-2000s  from  8,000–9,000  tonnes  to 
approximately  5,000–6,000  tonnes  now,  mainly  reflecting  a  reduced  demand  from  multiple-retailers  who  have  responded  to  pressure  from 
environmental NGOs to  stop  using wild  glass eel-based aquaculture products  (Kirkegaard et  al,  2010). Most eel  farms now use recirculation 
aquaculture systems (RAS), especially in the Netherlands and Germany where the majority of farmed eels are produced.  It should be noted that 
eel  aquaculture is  based  on wild  recruits,  and some of them are subsequently released as on-grown eel  for stocking (around 10 million  eels, 
making a mean weight of 20 g to the overall 200 t of wild catch, according to ICES). Although it is now possible to close the cycle of Japanese 
eel (Anguilla japonica) production, so far it has not been possible to spawn and then wean European eels in any significant quantities.   

99 

 
 
 
 
 
Figure 17: EU aquaculture production (2004 - 2017) Source: ICES, 2018c 

Restocking of glass eel 

The restocking of glass eel peaked in the 1990s, followed by a steep decline to a low in 
2009. The amount of glass eels restocked increased in 2014 when the lower market prices 
guaranteed a larger number of glass eels could be purchased for fixed restocking budgets 
but  has decreased since  then (see  Figure 18 below). However,  glass eel restocking has 
decreased since then. 

Figure  18:  Reported  production  and  restocking  of  glass  eel  not  including  those  in 
quarantine by country (in millions) and as a proportion of production (%), ICES, 2018b 

100 

 
 
 
 
 
 
Impacts outside fishery - hydropower mortality 

Estimations  of  MS  suggest,  that  hydropower  mortality  accounts  for  more  than  50%  of 
anthropogenic  mortality  in  33  of  62  EMUs,  where  data  for  fishing  and  hydropower 
mortality was reported (as reported by ICES 2017b). 

The  impact  of  hydro  dams  on  migration  and  escapement  is  included  in  the  reporting 
regime developed by the Commission for the Eel Regulation, is referenced as Sigma H 
(ƩH) and described as the anthropogenic mortality rate outside the fishery, summed over 
the age groups in the stock.   

Figure 19. Box plots showing anthropogenic (non-fisheries) mortality ƩH (by ICES) 

Spain 

UK 

Italy 

Ireland 

Germany 

These data suggest that  anthropogenic mortality outside the fishery whilst variable (ƩH 
can  depend  upon  environmental  conditions  (flooding  vs.  drought)  at  the  time  of  the 
down-stream migration) has not declined significantly over the past decade. 

Escapement levels 

Eel Management Plans for river basin districts are designed to reduce mortality to a level 
(Blim)  that  allows  at  least  40%  of  the  silver  eel  biomass  to  escape  to  the  sea  with  high 
probability,  relative  to  the  best  estimate  of  escapement  that  would  have  existed  if  no 
anthropogenic  influences  had  impacted  the  stock  (e.g.  when  the  stock  was  at  B0,  as 
opposed  to  the  current  silver  eel  biomass  escapement  biomass,  Bcurrent).  This  40% 
escapement level is essentially a proxy Btrigger for the trigger reference point for biomass 
at maximum sustainable yield (BMSY-trigger). 

Figure  20  presents  the  status  of  the  stock  (horizontal,  spawner  escapement  (Bcurrent) 
expressed  as  a  percentage  of  the  pristine  (B0)  escapement)  and  the  anthropogenic 
impacts.  These results suggest that in 2017 the spawner (silver eel) escapement from the 
majority  of  EMUs  was  below  the  40%  target  (ICES,  2018c).  This  serves  to  emphasise 
that  silver  eel  escapement  levels  from  the  majority  of  EMUs  is  below  the  40% 
escapement reference point (shown on the horizontal axis). 

101 

 
 
 
 
 
 
 
 
Figure 20: Modified Precautionary Diagram for Eel Management Units  

Source: ICES (2018c). Data from the 2018 Data call or from Country Reports provided to WGEEL. Note 
that all indicators have been used as reported, despite some inconsistencies and errors 

Figure 21. Explanations of the Modified Precautionary Diagram for Eel 
Management Units [Source: ICES, 2013c] 

102 

 
 
 
 
ANNEX  7  SUMMARY  OF  THE  EU  AND  INTERNATIONAL  LINKAGES  APPLICABLE  TO 
EUROPEAN EEL 

103