Evaluation of the Eel Regulation : final report.
Date: 2020-03-05
Institutions: Directorate-General for Maritime Affairs and Fisheries
Subjects: aquaculture, authorised catch, conservation of fish stocks, fish, fisheries policy, fishery management, fishing controls, fishing regulations, protection of animal life, regulation (EU), sustainable development, sustainable fisheries, watercourse

Evaluation of the Eel 
Regulation

Final Report 

Written by: 

June 2019 

Maritime Affairs 

and Fisheries 

EUROPEAN COMMISSION 

Directorate-General for Maritime Affairs and Fisheries 

Directorate D — Fisheries Policy Mediterranean and Black Sea 

Unit D.3 CFP and Structural Support - Policy Development and Coordination 

E-mail:  MARE-D3@ec.europea.eu

European Commission 

B-1049 Brussels

EUROPEAN COMMISSION 

Evaluation of the Eel 
Regulation 

Final Report 

Directorate-General for Maritime Affairs and Fisheries 

2019 

Lead authors: 

Tim Huntington (Poseidon), Benoit Caillart (F&S), Sarah MacNab (Poseidon), Fiona Nimmo (Poseidon), Marco Frederickson 

(EuroFish), Giacomo Luchetta (Economisti Associati) & Robert Uden (Coffey) 

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The information and views set out in this report are those of the author and do not necessarily reflect the official opinion 

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More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2020

ISBN 978-92-76-17265-9 
doi: 10.2771/679816 

© European Union, 2020

Directorate-General for Maritime Affairs and Fisheries 

2019 

Evaluation of the Eel Regulation 

TABLE OF CONTENTS 

Abstract / Résumé / Abstrakt 

EXECUTIVE SUMMARY / SYNTHÈSE / ZUSA 

1.0 INTRODUCTION ...................................................................................................... 1

 Background.......................................................................................................... 1

 Purpose of this evaluation ...................................................................................... 1

 Scope of this evaluation......................................................................................... 2

2.0 BACKGROUND TO THE EEL REGULATION ................................................................ 3

 European Eel Status .............................................................................................. 3

 Eel Management Framework .................................................................................. 5

3.0 METHODOLOGY .................................................................................................... 10

3.1 Overview ........................................................................................................... 10

 Phase 1: Inception Phase ..................................................................................... 10

 Phase 2: Desk-based Data Collection .................................................................... 10

 Phase 3: Consultations ........................................................................................ 11

 Phase 4: Analysis and Presentation ....................................................................... 13

4.0  CURRENT  SITUATION  OF  MEASURES  FOR  THE  RECOVERY  OF  THE  EUROPEAN  EEL 
STOCK UNDER THE EEL REGULATION ......................................................................... 14

 Overview of measures for the recovery of European eel in the Eel Management Plans . 14

 Some good practises in eel conservation management ............................................ 28

 Overlap and conflict in MS measures ..................................................................... 29

 Inspection and control activities on eel fishing and aquaculture across the EU ............ 30

 Evolution of market prices for eels < 12 cm ........................................................... 40

 Analysis of the interlinkages between the Eel Regulation and other EU rules .............. 42

 Analysis of the interlinkages with international instruments that cover eels ................ 48

5.0 ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ............................... 51

 Relevance .......................................................................................................... 51

 Effectiveness ...................................................................................................... 55

 Sustainability ..................................................................................................... 66

 Efficiency ........................................................................................................... 69

 Coherence ......................................................................................................... 73

 EU added value .................................................................................................. 75

6.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................ 78

 Relevance .......................................................................................................... 78

 Effectiveness ...................................................................................................... 79

 Sustainability ..................................................................................................... 81

 Efficiency ........................................................................................................... 82

 Coherence ......................................................................................................... 84

 EU Added Value .................................................................................................. 85

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

ANNEX 1A: INTERVENTION LOGIC ............................................................................. 87

ANNEX 1B: EVALUATION QUESTIONS MATRIX ........................................................... 88

ANNEX 2: REFERENCES ............................................................................................... 94

ANNEX 3: PC QUESTIONNAIRE ................................................................................. 100

ANNEX 4A: TARGETED CONSULTATION - STAKEHOLDER LIST .................................. 109

ANNEX 
STATE  AUTHORITY 
QUESTIONNAIRE ...................................................................................................... 113

CONSULTATION 

-  MEMBER 

TARGETED 

4B: 

ANNEX  4C:  TARGETED  CONSULTATION  –  CONTROL  AUTHORITY  QUESTIONNAIRE 
(DETAILED VERSION) .............................................................................................. 118

ANNEX  4D:  TARGETED  CONSULTATION  –  CONTROL  AUTHORITY  QUESTIONNAIRE 
(SIMPLIFIED VERSION) ........................................................................................... 123

ANNEX 4E: TARGETED CONSULTATION - OTHER STAKEHOLDER QUESTIONNAIRE ... 126

ANNEX  5:  SYNOPSIS  REPORT  ON  THE  PUBLIC,  ROADMAP  AND  OTHER  STAKEHOLDER 
CONSULTATIONS ...................................................................................................... 129

1.

2.

3.

4.

Introduction ................................................................................................. 129

Public consultation......................................................................................... 129

Feedback to evaluation roadmap and ad hoc contribution ................................... 139

Targeted consultation .................................................................................... 140

ANNEX  6:  REVIEW  OF  THE  AMENDMENTS  PROPOSED  BY  THE  COMMISSION  FOR  THE 
REFIT OF THE EU FISHERIES CONTROL SYSTEM ....................................................... 143

ANNEX 7: CASE STUDIES .......................................................................................... 146

LIST OF BOXES 

Box 1: Public and Roadmap Consultation Results – Relevance ............................................. 54
Box 2: Public and Roadmap Consultation Results – Effectiveness......................................... 66
Box 3: Public and Roadmap Consultation Results – Sustainability ........................................ 68
Box 4: Public and Roadmap Consultation Results – Efficiency .............................................. 73
Box 5: Public and Roadmap Consultation Results – Coherence ............................................ 75
Box 6: Public and Roadmap Consultation Results – EU Added value ..................................... 77

LIST OF TABLES 

Table 1: Main information sources ................................................................................... 11
Table 2: Summary of responses from the control questionnaires ......................................... 13
Table 3: Scope and availability of Member State EMPs and Progress Reports ........................ 19
Table 4: Member State Progress in implementing their EMPs .............................................. 21
Table  5:  Examples  of  measures  to  address  hydro-morphological  pressures  by  country  or  river 
basin district (RBD) / international RBD (iRBD) ................................................................. 45
Table 6: Summary of Member States reporting in their 2018 EMP Progress Reports ............... 72

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

LIST OF FIGURES 

Figure 1: Eel recruitment indices ....................................................................................... 3
Figure 2: Time-series of yellow and silver eel fishery landings by country ............................... 4
Figure 3: EU wild eel fishery production (2011 - 2016) ........................................................ 4
Figure 4: Overview of the Evaluation Steps ...................................................................... 10
Figure 5: Proportion of management measures by category ............................................... 16
Figure 6: Evaluation of implementation of management measures in EMPs, as reported in 2012 
progress reports, summarised by category ....................................................................... 18
Figure 7: EU glass eel production (2011 - 2018) ............................................................... 40
Figure  8:  Average  prices  for  glass  eels  <12  cm  (2009-2017)  used  for  restocking,  showing 
production (t, 2011-2017) .............................................................................................. 41
Figure 9: Natura 2000 designations for estuaries (left) and coastal lagoons (right) ................ 47
Figure 10: Summary of EU and international linkages applicable to European eel .................. 49
Figure 11: Modified Precautionary Diagram for Eel Management Units ................................. 52
Figure 12: Box plots showing anthropogenic (non-fisheries) mortality ƩH ............................. 52
Figure 13: Reported production and restocking of glass eel not including those in quarantine by 
country (in millions) and as a proportion of production (%) ................................................ 57
Figure 14: Fishing effort of the six major eel producers in the EU ........................................ 58
Figure 15: EU aquaculture production (2004 - 2017) ......................................................... 65
Figure 16: Recreational eel catches in the EU (2005 - 2017) ............................................... 67
Figure 17: Eel Regulation Intervention Logic ..................................................................... 87
Figure 18: How relevant is the Eel Regulation? ................................................................ 131
Figure 19: Is the 40% escapement target achievable? ..................................................... 131
Figure 20: Should the Eel Regulation be amended of simplified? ....................................... 132
Figure 21: Does the Eel Regulation need alternative targets? ............................................ 132
Figure 22: What has the Eel Regulation achieved? ........................................................... 133
Figure 23: What is the support for Eel Regulation measures? ............................................ 134
Figure 24: What is the support for a ban on eels fishing? ................................................. 135
Figure 25: How coherent is the Eel Regulation with other fisheries instruments? ................. 136
Figure 26: What's the EU-added value of the Eel Regulation? ............................................ 136
Figure 27: How efficient is the Eel Regulation? ................................................................ 137
Figure 28: How efficient is the Eel Regulation as compare to other instruments? ................. 137
Figure 29. How sustain are the effects of the Eel Regulation? ............................................ 138
Figure 30: Questionnaire distribution by stakeholder category .......................................... 141
Figure 31: Questionnaires received by stakeholder category ............................................. 141

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

ACRONYMS/ABBREVIATIONS 

Acronyms/ 
Abbreviations 

Definition 

B0 

Bbest 

Bcurrent 

CDT 

CFP 

CITES 

CMS 

CR 

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

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 

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

Catch documentation and traceability  

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 

Critically Endangered 

DG MARE 

Directorate-General for Maritime Affairs and Fisheries 

EFCA 

EIFAAC 

EMFF 

EMP 

EQ 

EQM 

EQR 

EU 

GES 

GFCM 

HEMP 

ICES 

ITC 

IUCN 

IUU 

JC 

MS 

European Fisheries Control Agency  

European Inland Fisheries and Aquaculture Advisory Commission 

European Maritime Fisheries Fund 

Eel Management Plan  

Evaluation Question 

Evaluation Questions Matrix 

Environmental Quality Ratio 

European Union 

Good Environmental Status 

General Fisheries Commission for the Mediterranean  

Hellenic Eel Management Plan 

International Council for the Exploration of the Sea 

Internal Trade Certificates 

International Union for the Conservation of Nature 

Illegal, Unreported and Unregulated 

Judgement Criterion 

Member State 

MSFD 

Marine Strategy Framework  Directive   

MSY 

NDF 

PC 

PGA 

PGI 

RBD 

RBMP 

SAC 

SCIPs 

Maximum Sustainable Yield 

Non-Detriment Finding 

Public Consultation 

Plans de Gestion des Anguilles (French: EMP) 

Protected Geographical Indication  

River Basin District 

River Basin Management Plan 

Special Area of Conservation 

Specific Control and Inspection Programmes 

 
 
Evaluation of the Eel Regulation 

Acronyms/ 
Abbreviations 

Definition 

Sigma ƩA  

Sigma ƩF  
Sigma ƩH  

SMEF 

SPA 

SRG 

ToR 

VMS 

WFD 

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 

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

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

Sustainable Management of the External Fishing fleets 

Special Protection Area  

Scientific Review Group 

Terms of Reference 

Vessel monitoring System  

Water Framework Directive 

WGEEL 

Joint EIFAAC/ICES/GFCM Working Group on Eels 

WKEELCITES 

Workshop on Eel and CITES 

WKEMP 

Workshop for the Review of Eel Management Plan Progress Reports 

WKSTOCKEEL  Workshop on Eel Stocking 

Country codes 

Country 
Code 

Country Name 

Country 
Code 

Country Name 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

Austria 

Belgium 

Bulgaria 

Cyprus 

Czech Republic 

Germany 

Denmark 

Estonia 

EL / GR  Greece 

ES 

FI 

FR 

HR 

HU 

IE 

Spain 

Finland 

France 

Croatia 

Hungary 

Ireland 

IT 

LT 

LU 

LV 

MT 

NL 

NO 

PL 

PT 

RO 

SE 

SI 

SK 

TN 

TR 

Italy 

Lithuania 

Luxembourg 

Latvia 

Malta 

Netherlands 

Norway 

Poland 

Portugal 

Romania 

Sweden 

Slovenia 

Slovakia 

Tunisia 

Turkey 

UK / GB  United Kingdom 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

GLOSSARY OF KEY TERMS USED IN THIS EVALUATION  

Where applicable, definitions from the ICES WGEEL reports and Hanel (2019) were used. 

Term 

Meaning or Definition 

Anthropogenic Mortality 
Rate (Sigma ƩH )  

The anthropogenic mortality rate outside the fishery, summed 
over the age groups in the stock. 

Current biomass 
(Bcurrent) 

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

Eel Management Unit 
(EMU)  

Elver  

“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.  

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.  

Escapement 

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

Fishing Mortality Rate 
(Sigma ƩF )  

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

Glass eel 

Young, unpigmented eel, recruiting from the sea into continental 
waters. WGEEL consider the glass eel term to include all recruits 
of the 0+ cohort age. In some cases, however, also includes the 
early pigmented stages.  

Pristine biomass (B0) 

The amount of silver eel biomass that would have existed if no 
anthropo-genic influences had impacted the stock. 

Silver eel 

Stocking/Restocking 

Translocation  

Yellow eel 

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.  

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.  

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

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 

 
 
 
 
 
 
Evaluation of the Eel Regulation 

pigmented eels (‘elvers’ and bootlace). Sometimes yellow eel is 
also called ‘brown eel’. 

Abstract / Résumé / Abstrakt 

EN:  The  EU  Eel  Regulation  (2007)  required  Member  States  (MS)  to  establish  eel  management 
plans (EMPs) for their river basins that constitute significant eel habitats.  To date nineteen MSs 
have  produced  EMPs,  six  have  been  exempted,  with  only  Croatia,  Bulgaria  and  Slovenia  not 
submitting  a  plan.    The  main  measures  included  reducing  fishing  mortality  and  improved  eel 
escapement, principally through improving river corridor connectivity.  This evaluation examines 
whether changes need to be made to the Regulation and / or its implementation.   

At first glance progress since 2007 has been limited to date.  Overall biomass and escapement 
levels have not yet significantly improved.  The recovery of the eel stock is, however, recognised 
to be a long-term process and the Regulation is considered to remain both relevant and likely to 
be effective over time. There have been notable successes in terms of reducing fishing mortality, 
improving river connectivity and improving the traceability of the eel supply chain within the EU. 

Whilst  the  Regulation  is  still  relevant,  its  implementation  needs  considerable  improvement, 
especially when addressing non-fisheries related anthropogenic mortality.  There needs to be an 
increased focus on working at the eel management unit level in order to address their particular 
challenges.  Finally it is suggested that the European eel stock could come under a stock-wide 
regional fisheries management approach, with the EU role underpinned by the Regulation.   

FR: Le règlement sur l’anguille européenne (2007) requiert des États membres qu’ils établissent 
des  plans  de  gestion  des  anguilles  (PGA)  dans  les  bassins  hydrographiques  qui  constituent  un 
stock  d’anguilles  significatif.  À  l’exclusion  de  la  Croatie,  la  Bulgarie  et  la  Slovénie,  19  États 
membres  ont  mis  en  place  un  PGA  à  ce  jour.  Six  États  membres  ont  été  exemptés  de  cette 
obligation. Les principales mesures adoptées portent sur la réduction de la mortalité des anguilles 
lors  des  activités  de  pêche  ainsi  que  l’amélioration  des  taux  d’échappement  des  anguilles, 
notamment  par  l’adoption  de  mesures  structurelles  visant  à  permettre  le  franchissement  des 
rivières.  Cette  évaluation  considère  si  des  modifications  sont  nécessaires  afin  d’améliorer  le 
règlement et sa mise en œuvre. 

À première vue, les progrès depuis 2007 apparaissent limités. Pour l’instant, la biomasse et le 
taux  d’échappement  des  anguilles  n’ont  pas  augmenté  de  manière  significative.  Cependant, 
l’accroissement du stock d’anguilles est reconnu comme un processus de long terme pour lequel 
le règlement européen reste pertinent. Le règlement est aussi considéré comme potentiellement 
efficace à l’atteinte de ses objectifs au fil du temps. Il a déjà donné lieu à quelques succès notables 
concernant la réduction du taux de mortalité, l’amélioration de la connectivité des rivières et la 
traçabilité des anguilles dans la chaîne de traitement en Europe.  

Bien que le règlement soit toujours pertinent, l’évaluation détermine que sa mise en œuvre doit 
être améliorée notamment en ce qui concerne le taux de mortalité anthropique des anguilles non 
lié aux activités de pêche. L’évaluation conclut également qu’il est nécessaire de se concentrer 
davantage  au  niveau  des  unités  de  gestion  de  l’anguille  (UGA)  afin  de  résoudre  les  difficultés 
propres à chacune d’elles. Pour finir, l’évaluation recommande que le stock européen d’anguilles 
soit organisé en plans de gestion régionaux, avec un rôle de l’UE encadré par le règlement. 

DE:  Die  EU-Aalverordnung  (2007)  forderte  die  Mitgliedstaaten  auf,  Aalbewirtschaftungspläne 
(EMPs) für ihre Flusseinzugsgebiete aufzustellen, die wichtige Aallebensräume darstellen. Bislang 
haben  neunzehn  Mitgliedsstaaten  diese  EMPs  aufgestellt,  sechs  Mitgliedsstaaten  wurden 
ausgenommen, und nur Kroatien, Bulgarien und Slowenien haben keine EMPs vorgelegt. Zu den 
wichtigsten Maßnahmen gehörten die Verringerung der Fischsterblichkeit und die Verbesserung 
der  Aalflucht,  hauptsächlich  durch  die  Verbesserung  der  Konnektivität  der  Flusskorridore.  Bei 
dieser Bewertung wird geprüft, ob Änderungen an der Verordnung und / oder ihrer Umsetzung 
erforderlich sind. 

 
 
 
Evaluation of the Eel Regulation 

 
 
 
Evaluation of the Eel Regulation 

Auf den ersten Blick sind die Fortschritte seit 2007 bislang begrenzt. Das Gesamtbiomasse- und 
Rückwanderungsniveau hat sich noch nicht wesentlich verbessert. Es wird jedoch anerkannt, dass 
die  Wiederauffüllung  des  Aalbestands  ein  langfristiger  Prozess  ist,  und  es  wird  davon 
ausgegangen, dass die Verordnung sowohl relevant bleibt als auch voraussichtlich im Laufe der 
Zeit  wirksam  wird.  Es  gab  bemerkenswerte  Erfolge  bei  der  Verringerung  der  fischereilichen 
Sterblichkeit, der Verbesserung der Flussanbindung und der Verbesserung der Rückverfolgbarkeit 
der Lieferkette für Aale in der EU. 

Obwohl  die  Verordnung  immer  noch  relevant  ist,  muss  ihre  Umsetzung  erheblich  verbessert 
werden,  insbesondere  im  Hinblick  auf  die  anthropogene  Mortalität,  die  nicht  mit  der  Fischerei 
zusammenhängt. 
der 
Aalbewirtschaftungseinheiten  liegen,  um  ihre  besonderen  Herausforderungen  zu  bewältigen. 
Schlussendlich  wird  empfohlen,  dass  der  europäische  Aalbestand  einem 
regionalen 
Bestandsbewirtschaftungsansatz unterliegt, dessen Rolle durch die Verordnung untermauert wird. 

Schwerpunkt  muss 

verstärkt 

Ebene 

Der 

der 

auf 

 
 
Evaluation of the Eel Regulation 

EXECUTIVE SUMMARY  

Introduction 

Following multi-decadal decline of the European eel stock across Europe, in 2003 the European 
Commission  (hereinafter  referred  to  as  “Commission”)  proposed  the  development  of  a 
‘Community  Action  Plan  for  the  management  of European  Eel’1 and  in 2007  the  Council  of  the 
European  Union    (hereinafter  referred  to  as  “Council”)  adopted  a  regulation  to  put  in  place 
measures for the protection and recovery of this complex species2 (hereinafter referred to as “Eel 
Regulation”).  This Eel Regulation required Member States (MSs) to  establish eel management 
plans (EMPs) for their river basins that constitute significant eel habitats for implementation from 
2009 onwards.   

The objective of this evaluation study is to assist DG MARE's evaluation of current measures for 
the  recovery  of  European  eel  stock  under  the  Eel  Regulation  by  examining  their  effectiveness, 
efficiency,  relevance,  coherence,  EU  added  value  and  sustainability.  The  Commission  first 
attempted an assessment of the outcome of the implementation of the Eel Management Plans in 
2014  on  the  basis  of  the  first  progress  reports  by  Member  States,  but  the  results  of  this  first 
assessment were largely inconclusive due to the delays in the preparation and approval of the 
national  Eel  Management  Plans  and  the  delays  in  the  implementation  of  non-fisheries  related 
measures. 

This particular evaluation study covers the management, implementation and enforcement issues, 
including trade aspects. It looks in particular into the content and implementation of the  EMPs 
and  Member  States  reporting  under  the  Eel  Regulation  to  assess  if  they  have  adequately 
addressed all mortality factors affecting the eel stock, with a special emphasis to 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 rules in place 
such  as  the  Common  Fisheries  Policy,  the  fisheries  control  regulation  and  environmental 
legislation, in particular the Water Framework and Habitats Directives. It looks as well into the 
articulation  and  coherence  with  international  instruments  that  cover  eels,  such  as  the  General 
Fisheries Council of 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). 

Based on its outcome,  the results of this evaluation study may be used to inform the decision 
whether  the  Eel  regulation  needs  to  be  reviewed  or  whether  its    implementation  needs  to  be 
improved.  

Background to the Intervention 

The  European  eel  (Anguilla  anguilla)  stock  is  in  decline,  recruitment  at  an  all-time  low,  and 
exploitation of the stock is currently unsustainable. The most recent ICES stock advice published 
in November 2018 (2018a) confirms that the status of eel remains ‘critical’ and that recruitment 
remains low and the decline in recruitment is mirrored by a long-term decline in commercial and 
recreational fishery catch per unit effort, despite significant re-stocking efforts.    

The Eel Regulation required MSs to establish eel management plans (EMPs) for their river basins 
that  constitute  significant  eel  habitats  for  implementation  in  2009.  Under  the  Eel  Regulation, 
concerned  MSs  are  obliged  to  monitor  the  eel  stock,  evaluate  current  silver  eel  escapement 
(against a 40% target) and post-evaluate implemented management actions aimed at reducing 
eel mortality and increasing silver eel escapement. Under the Regulation, each MS should report 
to the Commission initially every third year until 2018 and subsequently every six years on the 
monitoring, effectiveness and outcomes of EMPs. 

1 COM(2003)573 final Communication from the Commission to the Council and the European Parliament - Development 
of a Community Action Plan for the management of European Eel 
2 Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing measures for the recovery of the stock of 
European eel 

 
                                           
Evaluation of the Eel Regulation 

In addition to the Eel Regulation, the EU has a number of mechanisms to control fisheries and 
manage the aquatic environment.  These include the Control Regulation, technical rules on eel 
fishing  under  the  annual  TAC  and  quota  Regulations,  the  EU  CITES  Regulation  and  the  Water 
Framework Directive with its River Basin Management Plans relevant for migratory fish species.   

Implementation / State of Play 

Nineteen  MSs 3  have  developed  and  implemented  national  EMPs  covering  almost  90  Eel 
Management Units.  MSs with only river basins flowing into the Black Sea (Hungary and Romania) 
were  exempted  as  they  do  not  constitute  a  natural  habitat  for  European  eel  according  to  the 
purpose of the Eel Regulation.  In addition Cyprus, Malta, Austria, and Slovakia were exempted 
from  preparing  EMPs  in  2009  as  their  river  basins  or  maritime  waters  concerned  cannot  be 
identified and defined as constituting natural habitats for the European eel.  Croatia, Slovenia and 
Bulgaria are not formally exempted but have decided not to submit EMPs as they consider  eel 
catches (outside the Black Sea in the case of Bulgaria) to be minimal.  As Member States who 
have not established EMPs, they are required to implement a 50% reduction in eel fisheries.  Only 
one EMP has been developed at cross-border level e.g. the ES / PT Transboundary Plan for Mihno 
River.   

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. In 2013, ICES evaluated 
these  progress  reports  in  terms  of  the  technical implementation  of  actions  (ICES,  2013);  they 
reported  that  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.  ICES noted that many MSs did not completely report stock 
indicators, and that where they were reported, different approaches to their calculation had been 
taken. 

In  2014,  the  European  Commission  (EC,  2014)  reported  to  the  European  Parliament  and  the 
Council with a statistical and scientific outcome evaluation of EMP implementation. The results of 
this first assessment were largely inconclusive due to the delays in the preparation and approval 
of  the  national  Eel  Management  Plans  and  the  delays  in  the  implementation  of  non-fisheries 
related measures.  Member States again reported on progress with implementing their EMPs in 
2015. 18 Member States have reported on progress in 2018. 

On  the  basis  of  the  critical  condition  of  the  eel  stock  and  inconclusive  outcomes  of  existing 
management measures under the Eel Regulation, at a meeting in December 2017 the European 
Commission and Member States agreed to step up their efforts to protect the stock (Council of 
the European Union, 2018); this includes carrying out this evaluation of the Eel Regulation.  

Methodology 

This evaluation has been undertaken over a seven and half month period, with the Final Report 
being submitted mid-May 2019.  It has been implemented over four distinct stages, which are 
shown in the figure overleaf and described briefly below.   

1.  Inception Phase: ran over the first four weeks of the project, following contact signature 
on  21  October  2018.  It  included  a  project  kick-off  meeting,  the  development  of  the 
Intervention  Logic  and  a  preliminary  Evaluation  Question  Matrix  and  resulted  in  the 
delivery of an Inception Report (on 02 November 2018). 

2.  Desk-based  data  collection:  aimed  at  collecting  evidence  to  answer  the  evaluation 
questions.  During this phase, we submitted two project progress reports and the phase 
culminated with the submission of the Interim Report on 18 January 2019. 

3.  Stakeholder consultations: this third phase of the project ran largely concurrent with 
Phase 2 to start collecting evidence for the evaluation and was thus reported in the Interim 
Report and was composed of both a Public Consultation (PC) and targeted consultations. 
With assistance from the consultants in drafting the questions, the Commission launched 

3 BE, CZ, DK, EE, FI, FR, DE, EL, IE, IT, LV, LT, LU, NL, PL, PT, ES, SE, UK 

 
                                           
Evaluation of the Eel Regulation 

the PC on 14 December 2018 and it was closed on 8 March 2019.  In addition we conducted 
specific consultations with key stakeholder groups across all relevant MSs that are directly 
impacted  by  the  Eel  Regulation  (e.g.  state  agencies,  fishers  and  farmers,  and  those 
involved in eel restocking and trade), have an interest in the implementation of the Eel 
Regulation (e.g. international organisations such as bodies implementing CITES and the 
CMS,  NGOs),  or  may  be  under-represented  in  the  public  consultation  (e.g.  research 
bodies).  Overall 174 questionnaire were produced and 80 responses were received and 
analysed.    We  also  held  11  face-to-face  and  over  12  telephone  interviews  with  key 
stakeholders. This process was assisted by case studies in France, Denmark and Italy.  

4.  Analysis and Presentation: during this final phase of the evaluation, we processed and 
analysed the data collected in the previous phases to synthesise and triangulate them to 
answer  the  evaluation  questions.  On  the  basis  of  these,  we  draw  evidence-based 
conclusions and propose recommendations where appropriate. 

Over the duration of the contract, the evaluation team provided DG Mare with monthly Progress 
Reports.  At the end of the contract the evaluation team leader gave a 40 minutes presentation 
of the evaluation results to a lunchtime conference, hosted by DG Mare on 29 April 2019.  This 
attracted  around  40  participants  from  DG  Mare,  DG  Env  and  the  Secretariat-General  and 
generated a further 45 minutes of clarifications and discussions.   

Given the large PC (174) and targeted consultation (80) responses, together with the extensive 
EMP progress report evaluations by the ICES WKEMP in late 2018, we consider the evaluation to 
be robust and well informed.   

Overview of the Evaluation Steps 

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3.1 Open Public Consultation 

2.2 Identification of Best Practices

3.2 Specific Stakeholder Consultations 

2.3 Enforcement of the Eel Regulation

3.3 Collective face to face consultations

2.4 Interlinkages with other instruments

3.4 Case studies

2.5 Finalisation of the Intervention Logic

3.5 Interim Report

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4.1 Final data analysis

4.2 Final Reports

4.3 Conference 

Analysis and answers to the Evaluation Questions 

Relevance: landings of European eels have dropped from around 10,000 t in the early 1990’s to 
level  out  at  around  2,500  t  since  2010,  but  escapement  levels  are  still  well  below  the  general 
objective of the EU recovery plan of at least 40% of the silver eel biomass that would have existed 
if no anthropogenic influence had impacted the stock.  It is now recognised that a key source of 
eel  mortality  is  non-fisheries  related  anthropogenic  activities,  e.g.  through  the  impact  of 
hydroelectric  turbines  and  dams  on  migration  and  escapement  and  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).  Therefore,  in  terms  of  stock  recovery  –  both 
from direct fishing as well as from other anthropogenic source of mortality, the specific objectives 
of the Eel Regulation are still highly relevant.   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

The Common Fisheries Policy is mainly focused on the conservation of marine biological resources 
with its freshwater scope limited to market and financial measures.  The Eel Regulation (2007), 
which precedes the reformed CFP (2013) widens the scope of the EU’s mandate to include the 
management  of  the  European  eels  in  freshwaters  and  has  its  primary  focus  on  managing  the 
fisheries-related  anthropogenic  mortality,  mainly  through  increasing  escapement  rates  and 
reducing fishing mortality.  It also requires Member States to implement measures to reduce the 
eel mortality caused by factors outside the fishery and explicitly recognises the Habitats Directive  
and the Water Framework Directive as key precursors and supporting legislation.   

Effectiveness:  in  terms  of  process,  19  EU  Member  States  with  significant  eel  habitats  have 
produced national eel management plans, although the fact that only five have EMPs that operate 
at  eel  management  unit  (EMU)  level  is  a  concern.    However,  as  suggested  above,  it  will  take 
considerable  more  time  to  achieve  their  EMP  targets.    The  eel  stock  has  not  recovered  to  any 
degree, non-fisheries related anthropogenic mortality has not declined significantly over the last 
decade and the 40% escapement target has not been achieved.  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 target 
of reducing fishing effort by at least 50% has met some success. Fishing effort has declined in 
Sweden  (by  over  90%),  Italy  (just  over  50%),  Denmark  and  France  (by  almost  50%)  and 
Germany (by 25%).  However, effort appears to have risen to 135% of 2008 levels in the UK and 
180% of the 2012 level in Poland.   

Traceability  of  eels  remains  a  key  issue,  in  particular  for  live  glass  eels.    Intra-EU  movement 
traceability  is  hindered  by  some  shortcomings  of  EU  control  system  in  relation  to  control  of 
activities of vessels of less than 10 m.  However, it has been increasingly recognised that this is 
key  to  controlling  illegal  exports  from  the  EU,  and  a  number  of  Member  States  are  now 
implementing traceability schemes based on the EU CITES Regulation, supported by private sector 
initiatives such as the Sustainable Eel Group Standard.  Nonetheless, weak eel traceability from 
“net to plate” appear to be a significant risk factor.  The EU Control Regulation requires traceability 
for  all  species  (incl.  eel),  but  this  is  still  far  from  an  effective  system  that  needs  considerable 
improvement in its implementation by Member States.  The proposed revision of the EU control 
system is likely to improve dramatically the monitoring and control of eel fisheries. 

The  European  eel  fishing  industry  strongly  believes  that  a  limited  and  transparent  capture 
fisheries is both sustainable and desirable, especially when based on small, traditional operations.  
This position is supported by the PC results, which highlighted external factors, such as inability 
to reduce hydropower mortality or poaching, and insufficient implementation of the policy at the 
national level, rather than issues with the legislation itself. 

Sustainability:  There  is  no  ‘end  date’  for  the  Eel  Regulation,  so  it  is  considered  indefinite,  at 
least until the European eel stock has fully recovered. As frequently mentioned in this evaluation, 
the recovery of the European eel population is a long-term process, with some Member States 
considering  2050  as  a  reasonable  point  by  which  the  Regulation’s  target  of  40%  escapement 
across  the  EU  might  be  reached.    Reducing  commercial  fishing  activity  may  have  a  long-term 
impact on fishing mortality but the risk is that IUU fishing – driven by the high price paid in Asia 
for European glass eels, may sustain some level of fishing mortality that is both difficult to assess 
and may have implications for stock recover, thus threatening the sustainability of the initiative.  
Restocking is 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, together with other environmental measures have the potential to make 
the  most  profound,  long-term  impacts  on  eel  stocks.  Once  the  European  eel  stock  has  fully 
recovered,  at  that  point  the  regulation  could  be  reconsidered,  and  a  sustainable  management 
plan put in place.  In the meantime the regular progress reports as required in the Regulation 
should be continued.    

Efficiency:    A  monetarised  analysis  of  the  cost-benefits  of  the  Eel  Regulation is  impossible  to 
quantify  at  this  stage,  as  Member  States  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 

 
Evaluation of the Eel Regulation 

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. 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. This said, the Regulation 
is essentially sound and most Member State respondents 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. Another 
area  that  needs  improvement  is  progress  reporting,  which  needs  to  be  more  harmonised  and 
robust.    At  present  EU  Member  States  are  not  considering  any  policy  alternatives  to  the  Eel 
Regulation as it is considered relevant and effective, albeit over the long-term.   

Coherence:  as  mentioned  above,  the  Eel  Regulation  is  essentially  coherent  with  the  CFP  and 
environmental regulations such as the WFD and Habitats Directive.  There is scope to improve 
connectivity between River Basin Management Plans and EMPs, and the authorities tasked with 
their delivery, including 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  considerable  scope  to  expand  the  role  of  the  CMS  in  eel 
conservation worldwide.     

EU  added  value:  the  Eel  Regulation  has  catalysed  the  development  of  eel  conservation  and 
management  legislation  in  Member  States.    It  has  also  brought  managers  in  together  from 
different  regions  and  organisations  within  Member  States  to  develop  the  plans  and  associated 
measures.    The  Eel  Regulation  has  also  stimulated  other  EU-funded  actions  to  support  the 
recovery  of  the  European  eel,  such  as  the  recently  started  SUDOANG  project  in  South  West 
Europe.  The Regulation has raised awareness of the need for conserving and managing European 
eels throughout its range. 

Conclusions and recommendations 

The adoption of the Eel Regulation is recognised to have been an important milestone in the long 
process  to  allow  the  recovery  of  the  European  eel.    Its  basic  premise  is  still  sound,  and  the 
Regulation remains as relevant now as it was in 2009. Despite notable progress in reducing fishing 
effort and a concerted attempt to develop a pan-EU management framework, ICES still consider 
that the status of the eel remains critical.  

This is not saying that the Regulation is not working.  The core reasons why eel migration and 
escapement  has  been  hindered  still  exist  and  it  will  take  many  years,  decades  even,  for  a 
significant recovery of the European eel population. Most stakeholders agree that the character 
of  the  Regulation  is  solid,  but  its  implementation  needs  considerable  improvement,  especially 
when  addressing  non-fisheries  related  anthropogenic  mortality.    In  addition,  the  current  high-
level national approach to eel management used by some Member States needs to be taken down 
to  watershed  level,  with  a  focus  on  the  Eel  Management  Units  and  their  individual  challenges.  
Some also question the current focus on increasing eel biomass and abundance, and that setting 
mortality  targets  in  line  with  the  long-term  objective  of  40%  silver  eel  biomass,  on  a 
geographically partitioned basis (e.g. at the EMU level)  may be a more efficient harvest strategy.   

There has been some notable progress made at Member State level that also suggest that the 
Regulation will, over time, be a critical factor  in the European eel’s recovery.   Italy has shown 
how  multi-stakeholder  platforms  can  assist  make  regional  EMPs  adaptive  to  the  nature  and 
circumstances of local eel management needs.  Best practices for making in-river structures ‘eel-
friendly’ and protecting them from hydro-power intakes have been developed and published in 
France and in the United Kingdom. There have also been attempts to start opening up migration 
routes and developing hydrological regimes that favour eel movement, particularly in France and 
Italy.  There have also been significant developments in the third party certification of sustainable 
eel fisheries.  Of particular note is the development of CITES-based traceability schemes in Greece 
and Italy that could contribute to the issue of tracking intra-EU eel trade and reducing the risk of 

 
Evaluation of the Eel Regulation 

illegal exports to the outside of the EU.  Joint operations, such as Europol-supported Spanish / 
Portuguese ‘Operations Elvers’ that saw the seizure of 350 kg of glass eels destined for China, 
also demonstrate how multi-national, cross-jurisdictional control operations can work.  

Based  on  the  evaluation  a  number  of  recommendations  can  be  made  to  make  the  Regulation 
more  effective,  both  through  its  direct  implementation  as  well  as  via  other  avenues  that  are 
catalysed by this EU action.   

Direct Eel Regulation implementation issues 

•  A proportionate focus on Member States with significant glass eel (FR, UK, ES & PT) and 

yellow and silver eel (FR, UK, DK, SE, IT, PL, NL, ES & EL) production for fisheries 
measures, with a less rigorous approach to Member States with no or very little 
productivity.     

•  EMPs are developed at EMU-level in all Member States unless credible evidence exists 

that multiple-EMU plans are justified.  Greater emphasis on transboundary collaboration, 
both within and adjacent to the EU.    

•  EMPs need to provide greater focus on non-fisheries related measures such as (i) 

structural measures to make rivers passable and improve river habitats, together with 
other environmental measures and (ii) the temporary switching-off of hydro-electric 
power turbines.  Where necessary, the design of these measures should be conducted 
jointly with those authorities mandated to implement the associated actions.   

•  Greater pressure on Member States to fulfil the Regulation in its entirety. As the EMPs 

vary in quality and fitness for purpose, this has resulted in the partial rates in 
implementation to date and the variability in responses to progress reporting 
requirements and data calls (both by the EU and ICES).   

•  More specific timelines and interim targets across the Regulation. Whilst recognised as a 
long-term approach, the Regulation is not time-bound. There are good reasons for this, 
but many stakeholders have asked that interim targets are developed and the progress 
towards this is monitored.  It is important that such interim targets not only cover 
fisheries-related mortality, but also non-fisheries related mortality and proxy indicators 
(e.g. improved connectivity of rivers).  This may require re-focusing all protective 
actions, assessments, evaluations and advice on anthropogenic mortality goals and 
indicators- considering each of the management areas (countries) individually.   

•  EMPs should be regularly reviewed to ensure that they remain robust, relevant and 

effective.  This will require ongoing research, as well as monitoring of environmental 
conditions, river connectivity and catch, documentation and traceability (CDT) 
effectiveness.  Review of the EMPs needs to be continued on a three-yearly basis for the 
time being. 

•  The evaluation identified a possible source of legal misinterpretation of Art. 7.1 of the 
Eel Regulation in relation to restocking suggesting that 60% of glass eels caught each 
year may not be marketed for this purpose. As a result, control authorities cannot 
enforce this prescription. Article 7.1 of the Eel Regulation may need to be reconsidered 
taking into account the continued relevance of other prescriptions on restocking. 

•  A more cohesive funding approach for EMP and associated measures is required.  Few 

MS provide budgets for implementing their EMPs to cover such aspects as restocking 
costs and habitat improvement projects.  This should include the role of the EMFF and 
other EU public funding, the role of the private sector and possibly development of 
specialist Financial Instruments to fund long-term eel conservation and management.  
This suggests that the Eel Regulation and its measures should be specifically reflected in 
MS EMFF operational programmes for the next funding period (2021 - 2027).  In 
particular glass eel stocking, esp. that was supported by EMFF and other public funds, 
needs to be better justified in terms of its net benefit to silver eel escapement.  The 
Commission’s EMFF Impact Assessment SWD also suggests that the “Member States will 
be required to strengthen national management plans in order to protect eels in the 
inland waters” (EC, 2018).   

 
Wider governance and eel management issues 

Evaluation of the Eel Regulation 

•

•

•

There is a need for a central coordinating body for the recovery of the European Eel. The
Eel Regulation provides a united approach across the EU, but the core issue of stock
recovery needs a stock range wide approach.  One stakeholder mentioned the North
Atlantic Salmon Conservation Organisation (NASCO) as a possible model.

The current poor status of the European eel needs to be better publicised so that greater
public pressure can be applied to improve eel management and water basin conditions.

Internationally coordinated research is required to determine any net benefit of
restocking on the overall population, including carrying capacity estimates of glass eel
source estuaries, detailed mortality estimates at each step of the stocking process, and
performance estimates of stocked vs. non-stocked eels.

• Coordinated research into eel aquaculture techniques in order to develop commercially

viable artificial European eel glass eel production.

• Development of parallel management actions in non-EU countries, including

development of comprehensive eel management plans (at transboundary level, both
with the EU and third countries), coordinated research.

•

•

Encourage Member States to make full use of CITES obligations to strengthen control of
the legality of eels detained or offered for sale in their national territories.

Further action needs to be undertaken to take advantage of Convention on Migratory
Species (CMS) and to ensure it contributes to improving the conservation status of the
European eel and its management.  In practical terms this means the development of an
appropriate instrument, whether in the form of a legally binding agreement or in the
form of any other solution already in existence among the large of CMS family of
instruments.

References in the Executive Summary 

Council of the European Union (2018).  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  

European Commission (2014).  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 (2018). 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} 

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

Evaluation of the Eel Regulation 

SYNTHESE 

Introduction 

À  la  suite  du  déclin  multi-décennal  du  stock  d’anguilles  à  travers  l’Europe,  la  Commission 
européenne a proposé en 2003 un plan d’action de l’UE pour la gestion des anguilles en Europe4. 
En 2007, le Conseil de l'Union Européenne a adopté un règlement afin de mettre en place des 
mesures  de  protection  et  de  repeuplement  de  l’espèce5.  Le  règlement  européen  sur  l’anguille 
requiert des Etats membres qu’ils établissent des plans de gestion de l’anguille dans les bassins 
hydrographiques qui constituent un stock d’anguilles significatif, et cela, à partir de 2009. 

L’objectif de cette évaluation est d’assister la Direction Générale des Affaires maritimes et pêche 
(DG  MARE)  dans  son  appréciation  des  mesures  en  vigueur  pour  la  reconstitution  du  stock 
d’anguilles  européen  définies  par  le  règlement,  en  examinant  leur  efficacité,  efficience, 
pertinence,  cohérence,  valeur  ajoutée  européenne  et  durabilité.  En  2014,  la  Commission  avait 
déjà tenté d’évaluer les résultats des PGA en se basant sur les premiers rapports de progrès des 
États membres. Cependant, les résultats de cette première évaluation ont été peu concluants en 
raison des délais encourus lors de la préparation et l’approbation des plans de gestion nationaux, 
ainsi que le retard dans l’adoption de mesures non liées aux activités de pêche. 

L’évaluation présente porte sur les difficultés liées à la gestion, la mise en œuvre et l’application, 
ainsi que sur certains aspects commerciaux du règlement européen sur l’anguille. En particulier, 
l’évaluation examine le contenu et la mise en œuvre des PGA et des systèmes de notification des 
États  membres  dans  le  cadre  du  règlement,  afin de  déterminer  s’ils ont  adéquatement  abordé 
tous les facteurs pertinents à la mortalité des anguilles, notamment par l’élaboration et la mise 
en place de mesures de repeuplement, ainsi que la gestion de la pêche à la civelle de l'anguille 
d'Europe. L’évaluation porte également sur les problèmes d’application et de contrôle des eaux 
marines et intérieures. L’articulation et la cohérence entre le règlement sur l’anguille et les autres 
réglementations européennes pertinentes en place, telles que la Politique Commune de la Pêche, 
le règlement sur le régime européen de contrôle de la pêche et la législation environnementale 
(notamment la directive-cadre sur l'eau et la directive habitats) sont considérées avec un intérêt 
particulier. L’évaluation s’intéresse également à l’articulation et la cohérence du règlement avec 
les  instruments  de  droit  international  traitant  de  la  conservation  des  anguilles,  tels  que  les 
recommandations  de  la  Commission  Générale  des  Pêches  pour  la  Méditerranée  (CGPM),  la 
Convention sur le commerce international des espèces de faune et de flore sauvage menacées 
d'extinction (CITES) et la Convention sur la conservation des espèces migratrices appartenant à 
la faune sauvage (CMS).  

Les conclusions de la présente évaluation pourront être mises à contribution dans le processus 
de  décision  visant  à  revoir  le  règlement  sur  l’anguille  européenne  ou  à  améliorer  sa  mise  en 
œuvre.  

Contexte de l’intervention 

Le stock d’anguille européenne (Anguilla anguilla) est en déclin et n’est pas exploité de manière 
durable, les taux de recrutement étant au plus bas. En novembre 2018, le Conseil International 
pour l'Exploration de la Mer (CIEM) a publié un rapport sur l’état des stocks confirmant le statut 
« critique » de l’anguille ainsi qu’une baisse du recrutement reflétée par le déclin au long terme 
des  captures  de  pêche  commerciale  et  récréative,  malgré  les  efforts  considérables  de 
repeuplement. 

Le règlement requiert des États membres qu’ils établissent à partir de 2009 des PGA dans leurs 
bassins  hydrographiques  qui  constituent  un  stock  significatif  de  l’espèce.  Les  États  membres 
doivent également contrôler les stocks d’anguilles, calculer les taux actuels d’échappement des 
anguilles  argentées  (par  rapport  à  l’objectif  fixé  à  40  %)  ainsi  qu’évaluer  rétroactivement  les 

4 Communication finale de la Commission au Conseil et au Parlement européen pour le développement d’un plan d’action 
communautaire sur la gestion de l’anguille européenne ; COM (2003) 573.  
5 Règlement  (CE)  n°1100/2007  du  Conseil  du  18  septembre  2007  instituant  des  mesures  de  reconstitution  du  stock 
d’anguilles européennes ; JO L 248 du 22.9.2007, p. 17–23.  

Evaluation of the Eel Regulation 

mesures de gestion mises en œuvre visant à réduire le taux de mortalité et d’échappement. Le 
règlement  dispose  que  chaque  État  membre  doit  faire  notification  à  la  Commission  sur  la 
surveillance, l’efficacité et les résultats du PGA adopté, initialement tous les trois ans jusqu’en 
2018, puis tous les six ans. 

De  nombreux  autres  mécanismes  de  contrôle  de  la  pêche  et  des  environnements  aquatiques 
complètent le règlement sur l’anguille au niveau de l’UE. Il s’agit notamment du régime européen 
de contrôle de la pêche, du cadre technique établi par les règles sur les Totaux Admissibles de 
Captures (TAC) et quotas se rapportant à la pêche aux anguilles, la CITES et la directive-cadre 
sur l’eau, qui établit des plans de gestion des masses d’eau pertinents aux espèces de poissons 
migrateurs. 

Mise en œuvre / Etat d'avancement 

À ce jour, 19 États membres6 ont développé et mis en œuvre des plans de gestion, correspondant 
à près de 90 UGA en Europe. Les États membres ayant uniquement des bassins hydrographiques 
coulant vers la Mer Noire (la Hongrie et la Roumanie) ont été exemptés de cette obligation, car 
ceux-ci ne constituent pas un habitat naturel de l’anguille selon le règlement européen. Chypre, 
Malte,  l’Autriche  et  la  Slovaquie  ont  également  été  exemptés  de  la  mise  en  place  de  plans  de 
gestion de l’anguille en 2009, car leurs bassins hydrographiques et eaux maritimes ne peuvent 
être qualifiés d’habitats naturels de l’anguille européenne. La Croatie, la Slovénie et la Bulgarie 
ne sont pas officiellement exemptées de l’obligation de soumettre un PGA, mais ont décidé de ne 
pas  en  proposer  en  raison  du  niveau  insignifiant  de  capture  de  l’anguille  dans  leurs  bassins 
hydrographiques et eaux maritimes (en dehors de la mer Noire dans le cas de la Bulgarie). Les 
États membres qui ne mettent pas en place de PGA doivent cependant s’engager à réduire de 50 
% la pêche à l’anguille. Un seul PGA transfrontalier a été développé et porte sur la rivière Mihno 
entre l’Espagne et le Portugal. 

En 2012, les États membres ont soumis leur premier rapport de progrès sur les actions mises en 
place dans le cadre de leurs plans de gestion, sur la réduction de la mortalité anthropique et l’état 
des  stocks  d’anguille  par  rapport  aux  objectifs  fixés.  L’année  suivante,  grâce  à  ces  rapports 
d’activité, le CIEM a évalué la mise en œuvre technique de ces actions (CIEM, 2013). Elle a en a 
conclu  qu’un  total  de  756  actions  (par  ex.  l’allégement  des  barrières,  le  repeuplement,  la 
restriction de la pêche) proposées dans les plans de gestion ont été pleinement mises en œuvre, 
259 seulement partiellement et 107 ne l’ont pas été du tout. Le CIEM a constaté que plusieurs 
États  membres  n’avaient  pas  rempli  les  indicateurs  de  stocks  et  que,  lorsque  le  rapport  avait 
effectivement été rempli, les méthodes de calcul étaient très approximatives.  

En 2014, la Commission européenne (CE, 2014) a soumis un rapport d’évaluation statistique et 
scientifique des résultats de la mise en œuvre des PGA au Parlement Européen et du Conseil. Les 
résultats de ce premier exercice ont été peu concluants à cause des retards de mise en œuvre et 
autres mesures non liées aux activités de la pêche. Les États membres ont à nouveau notifié la 
Commission de l’avancement des PGA en 2015. En 2018, les États membres étaient 18 à faire un 
rapport de progrès. 

À l’occasion d’une réunion en 2017, convoquée en réponse à l’état critique du stock d’anguilles et 
aux résultats peu concluants des PGA en place, la Commission et les États membres ont décidé 
de redoubler d’efforts pour protéger le stock d’anguilles (CUE, 2018), notamment par le biais de 
la présente évaluation du règlement sur l’anguille européenne. 

6 BE, CZ, DK, EE, FI, FR, DE, EL, IE, IT, LV, LT, LU, NL, PL, PT, ES, SE, GB 

 
 
 
 
                                           
Méthodologie 

Evaluation of the Eel Regulation 

L’évaluation a duré sept mois et demi, le rapport final ayant été soumis à la mi-mai 2019, et a 
été articulée dans quatre phases décrites en détail ci-dessous :  

1.  Phase de lancement : Cette phase a compris les quatre premières semaines du projet, 
à  compter  de  la  signature  du  contrat  le  21  octobre  2018.  Elle  a  inclu  une  réunion  de 
lancement, le développement d’une matrice comprenant les questions d’évaluation et s’est 
terminée par la rédaction d’un rapport de lancement, soumis le 2 novembre 2018. 

2.  Recherche documentaire et collecte de données : Durant cette phase a été effectuée 
la collecte de données, qui ont servi de base à la formulation de réponses aux questions 
d’évaluation. Deux rapports de progrès ont été présentés, puis un rapport intérimaire a 
été soumis le 18 janvier 2019. 

3.  Consultation des parties prenantes : La troisième phase du projet s’est déroulée en 
parallèle  de  la  seconde  afin  d’initier  la  collecte  de  données  à  travers  les  différentes 
méthodes de consultation prévues. Les fruits de la consultation ont donc été inclus dans 
le rapport intérimaire à la Commission sur l’avancement de l’évaluation. Cette phase s’est 
composée  d’une  Consultation  Publique  (CP)  et  de  consultations  plus  ciblées.  L’équipe 
d’évaluation a soutenu la Commission dans les travaux préparatoires et le lancement de 
la CP le 14 décembre 2018, puis celle-ci fut clôturée le 8 mars 2019. En outre, l’équipe a 
consulté  les  parties  prenantes  directement  touchées  par  le  règlement  sur  l’anguille 
européenne dans tous les États membres concernés (par ex. organismes publics, pêcheurs 
et  agriculteurs,  et  ainsi  que  les  individus  et  organismes  impliqués  dans  la  politique  de 
repeuplement et le commerce), ainsi que celles ayant un intérêt spécifique pour la mise 
en œuvre du règlement (par ex. organisations internationales responsables de l’application 
de la CITES et de la CMS ou ONG). Enfin, certains acteurs sous-représentés dans la CP 
(par  ex.  organismes  de  recherche)  ont  aussi  été  consultés  séparément.  En  tout,  174 
questionnaires  ont  été  envoyés  et  80  réponses  reçues  et  analysées.  De  plus,  l’équipe 
d’évaluation a également organisé et mené onze entretiens face-à-face et réalisé douze 
entretiens par téléphone. Le processus de consultation décrit ci-dessus a été complété par 
des études de cas en France, au Danemark et en Italie. 

4.  Analyse et Rapport : L’étape finale de l’évaluation a compris le traitement et l’analyse 
des données collectées dans le but de répondre aux questions d’évaluation. Les résultats 
ainsi  obtenus  ont  ensuite  permis  d’émettre  des  conclusions  objectives,  fondées  sur  les 
données disponibles, et de proposer des recommandations le cas échéant. 

Tout  au  long  de  la  durée  du  contrat,  l’équipe  d’évaluation  a  soumis  des  rapports  de  progrès 
mensuels  à  la  DG  MARE.  Les  résultats  de  l’évaluation  ont  été  présentés  lors  d’une  conférence 
organisée par la DG MARE le 29 avril 2019. Cette conférence a réuni environ 40 participants de 
la DG MARE, la DG Environnement et du Secrétariat-Général et s’est conclue par 45 minutes de 
discussion et autres clarifications. 

Ayant égard du nombre considérable de réponses obtenues lors de la consultation publique (174) 
et consultations ciblées (80), ainsi que l’évaluation exhaustive des rapports de progrès des Etats 
Membres sur les PGA par le CIEM à l’occasion d’un groupe de travail consacré à l’analyse des PGA 
(Workshop for the Review of Eel Management Plan Progress Reports (WKEMP)) à la fin 2018, nous 
considérons cette évaluation robuste et adéquatement fondée. 

 
 
Vue d’ensemble des étapes de l’évaluation 

Evaluation of the Eel Regulation 

Analyse et réponses aux questions d’évaluation 

Pertinence:  Depuis le début des années 1990, les débarquements d’anguilles européennes ont 
chuté  d'environ  10  000  tonnes  à  environ  2  500  tonnes  en  2010.  Cependant  les  niveaux 
d'échappement  restent  considérablement  en  dessous  de  l'objectif  général  du  plan  de 
repeuplement, à savoir au moins 40% de la biomasse d'anguilles argentées qui aurait existé si 
aucune influence anthropique n’avait eu d’impact sur le stock. Les activités anthropiques telles 
que l’impact des turbines hydrauliques et barrages sur la migration et l’échappement, ainsi que 
le fait que le repeuplement des stocks d’anguilles est un processus de long terme étant donné la 
longévité  de  l’espèce  (20  ans),  sont  aujourd’hui  reconnues  comme  les  sources  primaires  de 
mortalité des anguilles. Par conséquent, la problématique de la reconstitution du stock d’anguilles 
en réponse aux activités de pêche et autres sources de mortalité d’origine anthropique illustre la 
pertinence des objectifs spécifiques du règlement sur l’anguille européenne. 

La  Politique  Commune  de  la  Pêche  porte  principalement  sur  la  conservation  des  ressources 
marines,  par  conséquent  ses  aspects  sur  la  pêche  en  eau  douce  restent  limités  aux  mesures 
financières et liées au commerce. Le règlement sur l’anguille européenne précède la réforme de 
la Politique Commune de 2013 et élargit la portée du mandat européen en y incluant la gestion 
de l’anguille européenne en eaux douces. Le règlement met notamment l’accent sur la diminution 
de la mortalité d’origine anthropique, par le biais d’une augmentation des taux d’échappement, 
ainsi qu’une réduction de la mortalité due aux activités de pêche. Le règlement requiert également 
des États membres qu’ils introduisent des mesures de réduction de la mortalité des anguilles liée 
aux activités autres que la pêche. Enfin, le règlement réitère l’importance de la directive habitats 
et de la directive-cadre sur l’eau. 

Efficacité:  Selon  les  dispositions  du  règlement,  19  États  membres  ayant  des  bassins 
hydrographiques significatifs pour l’anguille ont mis en place des PGA nationaux. Cependant, il 
est préoccupant de constater que seulement cinq plans sont opérés au niveau des UGA. En outre, 
comme mentionné ci-dessus, un temps additionnel considérable sera nécessaire pour atteindre 
les objectifs des PGA. L’évaluation a déterminé que le stock d’anguilles n’a pas été suffisamment 
reconstitué et que la mortalité due aux activités anthropiques autres que la pêche n’a pas baissé 
de façon significative durant cette décennie. Enfin, l’objectif d’un taux d’échappement à 40 % de 
la biomasse n’a pas été atteint. Alors que le repeuplement des stocks est une mesure comprise 
dans la plupart des PGA, seul six ont atteint leurs objectifs. L’évaluation note que l’absence de 
financement a affecté le repeuplement en 2013, alors qu’aujourd’hui la hausse du prix de la civelle 
de  l’anguille  européenne  constitue  le  problème  majeur  du  secteur.  L’objectif  de  réduire  les 

 
 
Evaluation of the Eel Regulation 

activités  de  pêche  d’au  moins  50  %  est  quant  à  lui  plus  abouti  à  ce  stade.  Une  réduction 
considérable des activités de pêche a été observée en Suède (de plus de 90 %), en Italie (plus 
de 50 %), au Danemark et en France (presque 50 %), ainsi qu’en Allemagne (25 %). Cependant, 
il apparait que les activités de pêche ont augmenté de 135% depuis 2008 au Royaume Unis et de 
180 % en Pologne depuis 2012. 

Un  problème  qui  reste  central  au  contexte  du  règlement  est  la  traçabilité  des  anguilles,  en 
particulier  celle  de  la  civelle  de  l’anguille  européenne.  La  traçabilité  des  mouvements  intra-
européens est limitée par les lacunes du système européen en vigueur pour le contrôle des navires 
de moins de 10 mètres. L’amélioration de ce système de contrôle est considérée d’une importance 
clé pour le contrôle des exports illégaux depuis l’UE. À cet effet, les États membres ont mis en 
place  des  mesures  de  traçabilité,  basées  sur  le  règlement  européen  relatif  à  la  protection  des 
espèces de faune et de flore sauvages par le contrôle de leur commerce qui met en œuvre les 
dispositions de la CITES et soutenues par des initiatives du secteur privé, tel que le Standard de 
Développement Durable de l’Anguille du Sustainable Eel Group. Néanmoins, le faible niveau de 
traçabilité de l’anguille européenne « du filet à l’assiette » est un facteur de risque significatif. En 
effet, le règlement sur le régime européen de contrôle de la pêche exige la traçabilité de toutes 
les  espèces  (dont  l’anguille),  or  en  réalité  ce  système  est  loin  d’être  efficace  et  nécessite  des 
ajustements  dans  son  application  par  les  États  membres.  La  révision  proposée  du  régime 
européen  de  contrôle  de  la  pêche  devrait  permettre  une  nette  amélioration  du  système  de 
surveillance, ainsi que du contrôle de la pêche à l’anguille. 

Les acteurs de l’industrie européenne de la pêche à l’anguille s’accordent à dire que des activités 
de pêche de nature limitée et transparente sont à la fois désirables et durables, surtout en ce qui 
concerne  la  pêche  traditionnelle  et  de  petite  envergure.  Cette  position  est  confirmée  par  les 
résultats de la CP, qui ont mis en exergue les facteurs externes tels que l’inaptitude à réduire la 
mortalité due aux turbines ou au braconnage, ainsi que l’application insuffisante des législations 
nationales, plutôt que les lacunes de la législation elle-même. 

Durabilité: L’application du règlement sur l’anguille européenne dans le temps est indéfinie, car 
il ne dispose pas d’une date limite d’application. Il est donc applicable au moins jusqu’à ce que le 
stock européen soit suffisamment reconstitué. Ainsi qu’il a été mentionné à plusieurs reprises, la 
reconstitution de la population d’anguilles européennes est un processus de long terme. À cette 
fin, on considère 2050 comme une raisonnable date-butoir pour atteindre un taux d’échappement 
à 40 % à travers l’Europe. La réduction de la pêche commerciale a beau avoir un impact positif 
sur le taux de mortalité, les risques de pêche illicite, non déclarée et non réglementée (notamment 
à  cause  du  prix  de  vente  élevé  de  la  civelle  de  l’anguille  européenne  en  Asie)  sont  difficiles  à 
mesurer  et  pourraient  bien  avoir  des  répercussions  sur  la  reconstitution  des  stocks  et  par 
conséquent,  sur  la  pérennité  de  cette  initiative.  Le  repeuplement  est  une  solution  de  court  à 
moyen terme, qui devrait être remplacée par le renouvellement naturel du stock à mesure que le 
recrutement  naturel  et  la  connectivité  des  cours  d'eau  s'améliorent.  Les  mesures  structurelles 
pour  rendre  les  rivières  plus  connectées  et  améliorer  l’environnement  aquatique,  ainsi  que 
d’autres mesures environnementales, peuvent aussi avoir un impact de long terme sur les stocks 
de l’anguille européenne. Lorsque le stock européen sera pleinement reconstitué, les dispositions 
du règlement pourraient être  reconsidérées et  un plan de gestion durable pourrait être mis en 
place. En attendant, les rapports de progrès réguliers exigés des États membres par le règlement 
restent nécessaires. 

services  gouvernementaux.  L’évaluation  a 

Efficience:  Une  analyse  monétarisée  des  coûts-avantages  du  règlement  sur  l'anguille  est 
impossible à ce stade, car les États membres ne quantifient pas les coûts directs de la mise en 
œuvre  du  règlement  de  façon  satisfaisante,  la  responsabilité  étant  souvent  répartie  entre 
plusieurs 
les  avantages 
environnementaux  qui  découlent  directement  des  mesures  adoptées  dans  les  PGA  (par  ex.  la 
reconstitution  du  stock  d'anguilles  grâce  à  une  réduction  de  la  mortalité  due  aux  activités  de 
pêche  et  à  l'augmentation  du  nombre  d'échappements  de  géniteurs),  ainsi  que  les  avantages 
environnementaux  indirects  (par  ex.  la  reconnexion  des  écosystèmes  côtiers,  estuariens  et 
riverains),  bien  qu’émergents  à  ce  stade,  sont  de  nature  durable  et  restent  à  être  pleinement 

constaté  que 

 
Evaluation of the Eel Regulation 

quantifiés. Néanmoins, le règlement doit être considéré comme fondamentalement adéquat et la 
plupart  des  répondants  des  États  membres  s’accordent  à  dire  qu’il  n’existe  pas  d’approche 
alternative qui soit meilleure. Toutefois, il faut reconnaître que la mise en œuvre de nombreuses 
mesures du règlement est un processus à long terme et que plusieurs de ses aspects demeurent 
toujours à  réaliser pleinement. Les rapports de progrès des  États membres doivent également 
être améliorés afin de devenir plus harmonieux et robustes. À l'heure actuelle, les États membres 
de  l'UE  ne  proposent  pas  d’alternative  au  règlement  sur  l'anguille,  car  celui-ci  est  considéré 
comme pertinent et efficace, même si ce n’est qu’à long terme.  

Cohérence:  Ainsi  qu’il  a  été  noté  précédemment,  le  règlement  est  cohérent  avec  la  Politique 
Commune de la Pêche et les réglementations environnementales pertinentes, telle que la directive 
habitats et la directive-cadre sur l’eau. Il est cependant encore nécessaire d’améliorer le lien entre 
les  plans  de  gestion  des  rivières  et  des  PGA,  ainsi  qu’avec  les  autorités  en  charge  de  leur 
application  respective,  notamment  par  l’harmonisation  et  hiérarchisation  des  mesures, 
particulièrement en matière de pression hydromorphologique. Ces dernières années, la CGPM a 
reconnu la nécessité d’établir un PGA en mer Méditerranée. Des effets positifs émanent aussi des 
restrictions aux commerce européen à l’anguille vers des pays tiers découlant de l’application de 
la CITES et de la possibilité d’élargir le rôle de la CMS dans la préservation de l’anguille dans le 
monde. 

Valeur ajoutée européenne: Le règlement sur l’anguille européenne a cristallisé l’intégration 
d’obligations  sur  la  conservation  et  la  gestion  de  l’anguille  dans  les  législations  nationales  des 
États membres. Le règlement a aussi facilité la coordination des autorités des différentes régions 
et  organisations  des  états  membres  pour  le  développement  des  PGA  et  mesures  qui  y  sont 
associées. Le règlement a aussi stimulé la création d’autres actions européennes en soutien à la 
reconstitution  du  stock  d’anguilles,  telles  que  le  projet  SUDOANG,  un  volet  de  la  coopération 
territoriale  européenne  Interreg  en  Europe  du  Sud-Ouest.  Par  conséquent,  le  règlement  a 
concrètement  sensibilisé  sur  le  besoin  de  conserver  et  de  mieux  gérer  le  stock  d’anguilles  en 
Europe. 

Conclusions et recommandations 

L’adoption  du  règlement  sur  l’anguille  constitue  une  étape  importante  dans  le  processus  de 
repeuplement  de  l’anguille  européenne.  L’évaluation  a  conclu  que  son  principe  de  base  est 
toujours  valable  et  que  le  règlement  reste  aussi  pertinent  qu’il  l’était  à  ses  débuts  en  2009. 
Cependant,  malgré  les  progrès  notables  en  termes  de  réduction  des  activités  de  pêche  et  les 
tentatives  de  développer  un  cadre  pour  la  gestion  de  l’anguille  au  niveau  européen,  la  CIEM 
considère toujours les stocks de l’anguille européenne en situation critique.  

Cela étant dit, ces constatations ne suggèrent pas que le règlement est dénué de toute efficacité. 
En  effet,  les  entraves  à  la  migration  et  à  l’échappement  des  anguilles  existent  toujours  et  ne 
peuvent  être  éliminées  au  court  terme.  On  estime  qu’il  faudrait  attendre  plusieurs  dizaines 
d’années avant de pouvoir observer un taux satisfaisant de reconstitution du stock de l’anguille 
européenne.  La  majorité  des  parties  prenantes  considère  le  règlement  comme  adéquat,  mais 
s’accorde  à  dire  qu’il  est  nécessaire  d’améliorer  sa  mise  en  œuvre,  en  particulier  en  ce  qui 
concerne la mortalité d’origine anthropique non liée à la pêche. De plus, l’évaluation a constaté 
que  certains  États  membres  privilégient  une  approche  de  la  gestion  de  l’anguille  au  niveau 
national qui devrait être abaissée au niveau des bassins versants ayant égard des UGA et de leurs 
spécificités. Certaines parties prenantes s’interrogent sur l’opportunité du choix du règlement de 
mettre l’accent sur l’augmentation de la biomasse et l’abondance d’anguilles, au lieu de fixer un 
objectif  au  long  terme  de  40  %  pour  la  biomasse  d’anguilles  argentées  repartie  en  zones 
géographiques (par ex. au niveau des UGA), qui paraît être une approche plus efficace. 

Des progrès notables ont été atteints au niveau des États membres, ce qui indique le potentiel 
du règlement pour la reconstitution du stock de l’anguille européenne au long terme. L’exemple 
de l’Italie a démontré que les plateformes multi-acteurs permettent de rendre les PGA adoptés 
au niveau régional plus appropriés aux besoins locaux de gestion de l’anguille. La France  et le 
Royaume-Uni  ont  développé  de  bonnes  pratiques  visant  à  rendre  les  ouvrages  en  rivière  plus 

 
Evaluation of the Eel Regulation 

respecteux de l’habitat des anguilles, tout en les protégeant des turbines hydrauliques. En outre, 
il convient de noter les tentatives, notamment en France et Italie, d’ouvrir des routes de migration 
et de développer des systèmes hydrologiques favorisant le mouvement des anguilles. Enfin, des 
avancées significatives ont eu lieu en ce qui concerne les certifications indépendantes de la pêche 
durable à l’anguille. L’initiative notable dans ce domaine est le développement de systèmes de 
traçabilité en Grèce et en Italie, basés sur la CITES et le règlement d’application européen. Cette 
dernière pourrait contribuer à améliorer la traçabilité de l’anguille sur le marché européen, ainsi 
qu’à réduire les risques d’exports illégaux en dehors de l’UE. Des opérations conjointes, telle que 
le projet hispano-portugais ‘Opération Civelle’ soutenu par Europol et qui a permis de saisir 350 
kg de civelle de l’anguille européenne destinés au commerce en Chine, illustrent à quel point le 
contrôle de la pêche à l’anguille peut revêtir un caractère transfrontalier et inter-juridictionnel. 

L’évaluation a permis de formuler un certain nombre de recommandations ayant pour objectif de 
rendre le règlement plus efficace, à la fois dans sa mise en œuvre directe et par d'autres voies 
catalysées par cette action de l'UE. 

Difficultés portant sur la mise en œuvre directe du règlement sur l’anguille européenne 

•  Lors de l’adoption de mesures relatives à la pêche a l’anguille, l’accent doit être mis de 

façon proportionnelle sur les États membres ayant une production significative de civelle 
(la France, le Royaume-Uni, l’Espagne et le Portugal) et d'anguille jaune et argentée (la 
France, le Royaume-Uni, le Danemark, la Suède, l’Italie, la Pologne, les Pays-Bas, 
l’Espagne et le Grèce). Une approche moins rigoureuse doit être adoptée à l'égard des 
États membres avec une production moindre ou non-existante. 

•  Les PGA doivent être mis en place au niveau de chaque UGA dans tous les États 

membres, sauf si l’opportunité d’adopter un PGA couvrant plusieurs UGA à la fois est 
justifiée par l’existence d’éléments pertinents à cet effet. L'accent doit davantage être 
mis sur la collaboration transfrontalière, à la fois au sein de l'UE et ses pays voisins. 

•  Les PGA doivent porter davantage sur les mesures non liées aux activités de pêche 

comme (i) des mesures structurelles et environnementales pour rendre les rivières plus 
accessibles et améliorer la qualité de l’environnement aquatique, ainsi que d’autres 
mesures à caractère environnemental et (ii) l’arrêt temporaire des turbines des centrales 
hydroélectriques. Au besoin, ces mesures devront être faites conjointement entre les 
autorités avec un mandat réciproque. 

•  Plus de contrainte doit être exercée sur les États membres pour qu’ils appliquent le 

règlement dans son intégralité. La qualité et la pertinence des PGA étant variables, le 
taux de mise en œuvre à ce jour n’est que partiel. L’adhérence des États membres à leur 
obligations de notification de progrès et leur réponses aux demandes de soumettre de 
données (de la part de l'UE et du CIEM) sont aussi variables. 

•  Un calendrier et des objectifs intermédiaires plus précis concernant l’application du 

règlement doivent être introduits. Bien qu’il soit reconnu comme ayant une approche de 
long terme, la date-butoir du règlement n’est pas définie. Cette approche est justifiée, 
cependant beaucoup de parties prenantes ont demandé que des objectifs intermédiaires 
soient fixés et les progrès vers ceux-ci plus suivis. Il est important que ces objectifs 
couvrent la mortalité liée aux activités de pêche, mais aussi les activités non liées à la 
pêche, ainsi que les indicateurs indirects (par ex. la meilleure connectivité des rivières). 
Cela nécessitera peut-être de revoir les activités de protection, de contrôle et 
d’évaluation, mais aussi de considérer comment les taux fixés et indicateurs de mortalité 
anthropique peuvent être améliorés, et cela, en fonction des zones de gestion. 

•  Les PGA doivent être régulièrement revus afin de s’assurer qu’ils restent adéquats, 
pertinents et efficaces. Ceci nécessitera des activités de recherche continues afin de 
documenter et contrôler les conditions environnementales, la connectivité des rivières, 
les captures et l’efficacité des mécanismes de traçabilité. Pour le moment, il faut 
poursuivre avec le régime de revue des PGA actuel, qui a lieu tous les trois ans. 

 
Evaluation of the Eel Regulation 

•  L’évaluation a mis en exergue une possible source d’erreur d’interprétation de l’article 

7.1 du règlement sur l’anguille européenne concernant le repeuplement des stocks, qui 
suggère que 60 % des civelles capturées chaque année ne peuvent pas être 
commercialisées à cette fin. Par conséquent, les autorités de contrôle ne peuvent pas 
appliquer cette règle. L’article 7.1 du règlement sur l’anguille devra peut-être être revu 
en tenant compte de la pertinence d’autres dispositions sur le repeuplement. 

•  Le financement des PGA et mesures associées doit être avec plus de cohésion. Peu 
d’États membres soumettent des budgets sur la mise en œuvre de leurs plans de 
gestion, couvrant les coûts de mesures telles que le repeuplement et les projets 
d’amélioration de l’habitat des anguilles. Ceux-ci devraient inclure le rôle du FEAMP et 
des autres financements publics de l’UE, le rôle du secteur privé et éventuellement le 
développement d’instruments financiers spécialisés pour financer la conservation et la 
gestion à long terme de l’anguille. Le règlement sur l’anguille et ses mesures devraient 
être reflétés dans les programmes opérationnels FEAMP des États Membres pour la 
prochaine période de financement (2021 - 2027). En particulier, le repeuplement de la 
civelle, une mesure soutenue par le FEAMP et d’autres fonds publics, doit être mieux 
justifiée en termes de ses bénéfices nets à l’échappement de l’anguille argentée. Le 
document de travail des services de la Commission sur l’évaluation de l’impact du FEAMP 
suggère également que « les États membres seront tenus de renforcer les plans de 
gestion nationaux afin de protéger les anguilles dans les eaux intérieures » (CE, 2018). 

Difficultés portant sur la gouvernance générale et la gestion de l’anguille 

•  Un organe central de coordination pour la reconstitution du stock d’anguilles 

européennes est nécessaire. Le règlement offre une approche commune à l’ensemble de 
l’UE, mais la question fondamentale de la reconstitution des stocks nécessite une 
approche plus globale. Une des parties prenantes a mentionné l’Organisation de 
conservation du saumon de l’Atlantique Nord (NASCO) comme modèle possible pour la 
création d’un tel organe.  

•  Plus de sensibilisation à l’état actuel critique de l’anguille européenne doit être faite, afin 

d’accroitre la pression sur les autorités publiques pour améliorer la gestion de l’anguille 
et les conditions des bassins hydrographiques.  

•  Des activités de recherche coordonnées au niveau international sont nécessaires pour 

déterminer les possibles bénéfices du repeuplement de la population globale d’anguilles. 
Un tel effort nécessiterait aussi des estimations de la capacité de contenance des 
estuaires qui abritent la civelle de l’anguille européenne, des estimations détaillées de la 
mortalité à chaque étape du processus de stockage et des estimations de rendement des 
anguilles stockées par rapport à celles qui ne le sont pas.  

•  Les activités de recherche sur les techniques d’aquaculture de l’anguille doivent être 

coordonnées, afin de développer une production artificielle de civelles qui soit 
commercialement viable.  

•  L’élaboration de mesures de gestion et des efforts de recherches coordonnés en parallèle 

dans les pays tiers sont nécessaires, notamment pour le développement de plans 
globaux de gestion de l’anguille (au niveau transfrontalier, à la fois avec l’UE et les pays 
tiers). 

•  Les États membres doivent être encouragés à utiliser pleinement les obligations 

découlant de la CITES, afin de renforcer le contrôle sur la légalité des anguilles en stock 
ou en vente sur leur territoire national.  

•  Des mesures supplémentaires doivent être prises pour tirer parti de la CMS et veiller à 
ce qu’elle contribue à l’amélioration de l’état de conservation et la gestion de l’anguille 
européenne. Concrètement, ceci demande l’élaboration d’un instrument approprié, que 
ce soit sous la forme d’un accord juridiquement contraignant ou sous la forme d’une 
autre solution déjà existante parmi les nombreux instruments rattachés à la CMS. 

 
Sources du Résumé 

Evaluation of the Eel Regulation 

Conseil de l’Union européenne (CUE, 2018).  Proposition de règlement du Conseil fixant pour 
2018 les possibilités de pêche pour certains stocks de poissons et groupes de stocks, applicables 
dans les eaux de l’Union et, pour les navires de pêche de l’Union, dans certaines eaux hors Union, 
et modifiant le règlement (UE) 2017 du Conseil/127. 

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

Commission européenne (CE, 2014).  Rapport de la Commission au Conseil et au Parlement 
Européen sur les résultats de la mise en œuvre des plans de gestion de l’anguille, comprenant 
une  évaluation  des  mesures  concernant  le  repeuplement  et  de  l’évolution  des  prix  du  marché 
pour les anguilles de moins de 12 cm de longueur.  Bruxelles, 21.10.2014. COM (2014) 640 final. 

Commission européenne (CE, 2018). Document de Travail des Services de la Commission ; 
ANALYSE  D’IMPACT  Accompagnant  le  document  « Proposition  de  règlement  du  Parlement 
européen  et  du  Conseil  relatif  au  Fonds  européen  sur  les  affaires  maritimes  et  la  pêche  et 
abrogeant  le  règlement  (UE)  no  508/2014  du  Parlement  européen  et  du  Conseil ». 
{COM(2018)390final} -{SEC(2018)276final}. 

Conseil International de l'Exploration de la Mer (CIEM, 2013). Rapport du groupe de travail 
sur  la  progression  de  l’évaluation  des  plans  de  gestion  de  l’anguille  (WKEPEMP),  13  –  15  mai 
2013, Copenhague, Danemark. ICES CM 2013/COM: 32. 

 
 
 
 
Evaluation of the Eel Regulation 

ZUSAMMENFASSUNG  

Einführung 

Nach dem jahrzehntelangen Rückgang des europäischen Aalbestands in ganz Europa schlug die 
Europäische Kommission (im Folgenden als „Kommission“ bezeichnet) im Jahr 2003 vor,  einen 
„Aktionsplan der Gemeinschaft zur Bewirtschaftung des Europäischen Aals“ auszuarbeiten, und 
im  Jahr  2007  erließ  der  Rat  der  Europäischen  Union  (im  Folgenden  als  „Rat“  bezeichnet)  eine 
Verordnung,  um  Maßnahmen  zum  Schutz  und  zur  Erholung  dieser  komplexen  Gattung 
einzuführen (im Folgenden als „Aalverordnung“ bezeichnet). Laut dieser Aalverordnung müssen 
Mitgliedstaaten  Aalbewirtschaftungspläne  (EMPs)  für  ihre  Flusseinzugsgebiete,  die  ab  2009 
wichtige Aalhabitate darstellen, aufstellen. 

Diese Bewertungsstudie hat zum Ziel, die GD MARE bei der Bewertung der aktuellen Maßnahmen 
zur Wiederherstellung des europäischen Aalbestands gemäß der Aalverordnung zu unterstützen, 
und untersucht die Wirksamkeit, Effizienz, Relevanz, Kohärenz, EU-Mehrwert und Nachhaltigkeit 
dieser  Maßnahmen.  Die  Kommission  versuchte  bereits  zuvor  das  Ergebnis  der  Umsetzung  der 
Aalbewirtschaftungspläne  im  Jahr  2014  auf  der  Grundlage  der  ersten  Fortschrittsberichte  der 
Mitgliedstaaten zu bewerten, doch die Ergebnisse dieser ersten Bewertung waren aufgrund von 
Verzögerungen in der Vorbereitung und Genehmigung der nationalen Aalbewirtschaftungspläne, 
wie  auch  wegen  Verzögerung  bei  der  Durchführung  von  nichtfischereibezogenen  Maßnahmen, 
nicht schlüssig. 

sich  mit  Management-, 

Diese  Bewertungssstudie  befasst 
Implementierungs-  und 
Durchsetzungsfragen,  einschließlich  Handelsaspekten.  Sie  untersucht  insbesondere  den  Inhalt 
und die Umsetzung der EMPs, wie auch Berichte, die Mitgliedsstaaten gemäß der Aalverordnung 
erstatten,  um  zu  bewerten,  ob  sie  alle  Sterblichkeitsfaktoren,  die  den  Aalbestand  betreffen, 
angemessen  berücksichtigt  haben.  Ein  besonderer  Schwerpunkt  dieser  Studie  liegt  auf  der 
Formulierung  und  Durchführung  der  Wiederauffüllungsmaßnahmen  und  Bewirtschaftung  von 
Glasaalfischerei.  Die  Studie  befasst  sich  auch  mit  Fragen  der  Durchsetzung  und  Kontrolle  in 
Meeres-  und  Binnengewässern.  Bei  der  Bewertung  wird  auch  untersucht,  inwieweit  die 
Aalverordnung mit anderen geltenden EU-Vorschriften, wie der Gemeinsamen Fischereipolitik, der 
Fischereikontrollverordnung 
der 
Wasserrahmenrichtlinie und der Habitatrichtlinie, in Einklang steht. Sie befasst sich auch mit der 
Artikulation  und  Kohärenz  mit  internationalen  Instrumenten,  die  Aale  betreffen,  wie  den 
Empfehlungen  des  Allgemeinen  Fischereirats 
für  den  Mittelmeerraum  (GFCM),  dem 
Übereinkommen über den internationalen Handel mit gefährdeten Arten wildlebender Tiere und 
Pflanzen (CITES), und dem Übereinkommen über die Erhaltung wandernder Wildtierarten (CMS). 

Umweltvorschriften, 

insbesondere 

und 

den 

Basierend  auf  den  Ergebnissen  dieser  Bewertungsstudie  kann  entschieden  werden,  ob  die 
Aalverordnung überarbeitet oder ihre Umsetzung verbessert werden muss. 

Hintergrund der Intervention 

Der europäische Aalbestand (Anguilla anguilla) ist rückläufig, die Anzahl ist auf einem historischen 
Tief  und  die  Ausbeutung  des  Bestands  ist  derzeit  nicht  nachhaltig.  Die  jüngste  ICES-
Bestandsaufnahme,  die  im  November  2018  (2018a)  veröffentlicht  wurde,  bestätigt,  dass  der 
Status des Aals nach wie vor „kritisch“ ist, und dass seine Anzahl niedrig bleibt. Der Rückgang 
der  Anzahl  spiegelt  sich  in  einem  langfristigen  Rückgang  der  gewerblichen  Fischerfänge  und 
Freizeitfischereifänge wider, trotz erheblicher Auffüllungsbemühungen. 

Gemäß der Aalverordnung mussten die Mitgliedstaaten Aalbewirtschaftungspläne (EMPs) für ihre 
Flusseinzugsgebiete aufstellen, die wichtige Aallebensräume darstellen, für die Umsetzung im Jahr 
2009. Gemäß der Aalverordnung sind die betroffenen Mitgliedstaaten verpflichtet, den Aalbestand 
zu  überwachen,  die  derzeitige  Silberaalflucht  (gegen  ein  40%  -Ziel)  zu  bewerten  und  die 
durchgeführten Bewirtschaftungsmaßnahmen zur Verringerung der Aalsterblichkeit und Erhöhung 
der  Silberaalflucht  nachzubewerten.  Gemäß  der  Verordnung  sollte  jeder  Mitgliedstaat  der 
Kommission, zunächst alle drei Jahre bis 2018 und anschließend alle sechs Jahre, einen Bericht 
über die Kontrolle, Wirksamkeit und Ergebnisse der EMPs erstatten. 

 
Evaluation of the Eel Regulation 

Neben  der  Aalverordnung  verfügt  die  EU  über  eine  Reihe  von  Mechanismen  zur  Kontrolle  der 
Fischerei  und  zur  Bewirtschaftung  der  Wasserumwelt.  Dazu  gehören  die  Kontrollverordnung, 
technische Vorschriften für den Aalfang gemäß den jährlichen TAC- und Quotenverordnungen, die 
EU-CITES-Verordnung  und  die  Wasserrahmenrichtlinie  mit  ihren  für  wandernde  Fischarten 
relevanten Bewirtschaftungsplänen für die Einzugsgebiete. 

Umsetzung / Stand der Sache 

Neunzehn  MS 7 haben  nationale  EMPs  für  fast  90  Aalbewirtschaftungseinheiten  aufgetellt  und 
umgesetzt.  Ausgenommen  sind  Mitgliedstaaten,  in  denen  nur  Flusseinzugsgebiete  in  das 
Schwarze  Meer  münden  (Ungarn  und  Rumänien),  da  sie  im  Sinne  der  Aalverordnung  keinen 
natürlichen  Lebensraum  für  europäischen  Aal  darstellen.  Darüber  hinaus  waren  Zypern,  Malta, 
Österreich und die Slowakei in 2009 von der Ausarbeitung von EMPs befreit, da die betreffenden 
Flusseinzugsgebiete oder Meeresgewässer nicht als natürliche Lebensräume für den Europäischen 
Aal identifiziert und definiert werden können. Kroatien, Slowenien und Bulgarien sind formal nicht 
freigestellt, haben jedoch beschlossen, keine EMPs einzureichen, da sie Aalfänge (außerhalb des 
Schwarzen Meeres im Falle Bulgariens) für minimal halten. Als Mitgliedstaaten, die keine EMPs 
eingerichtet haben, müssen sie die Aalfischerei um 50% reduzieren. Auf grenzüberschreitender 
Ebene  wurde  nur  ein  EMP  entwickelt,  nämlich  der  grenzüberschreitende  ES/PT-Plan  für  den 
Mihno-Fluss. 

Im  Jahre  2012  haben  die  Mitgliedstaaten  erstmals  über  die  im  Rahmen  der  EMPs  ergriffenen 
Maßnahmen,  die  erzielte  Verringerung  der  anthropogenen  Sterblichkeit  und  den  Stand  ihres 
Bestands  im  Verhältnis  zu  ihren  Zielen,  berichtet.  Im  Jahr  2013  hat  der  ICES  diese 
Fortschrittsberichte  im  Hinblick  auf  die  technische  Umsetzung  der  Maßnahmen  (ICES,  2013) 
bewertet.  Sie  gaben  an,  dass  insgesamt  756  Bewirtschaftungsmaßnahmen  (z.B.  Abbau  von 
Rückwanderung,  Wiederaufstockung,  Fangbeschränkungen),  die  in  den  EMPs  vorgeschlagen 
wurden,  vollständig umgesetzt worden waren,  259 nur teilweise und 107 überhaupt nicht. Der 
ICES  stellte  fest,  dass  viele  Mitgliedstaaten  über  ihre  Bestandsindikatoren  nicht  vollständig 
berichtet  haben,  und  dass  dort,  wo  sie  berichtet  wurden,  unterschiedliche  Ansätze  für  ihre 
Berechnung angenommen wurden. 

2014  hat  die  Europäische  Kommission  (EC,  2014)  dem  Europäischen  Parlament  und  dem  Rat 
einen  Bericht  mit  einer  statistischen  und  wissenschaftlichen  Bewertung  der  EMP-Umsetzung 
vorgelegt. Die Ergebnisse dieser ersten Bewertung waren aufgrund von Verzögerungen bei der 
Ausarbeitung und Genehmigung der nationalen Aalbewirtschaftungspläne und Verzögerungen bei 
der  Durchführung  von  nichtfischereibezogenen  Maßnahmen  weitgehend  nicht  schlüssig.  Die 
Mitgliedstaaten  haben  erneut  über  Fortschritte  bei  der  Umsetzung  ihrer  EMPs  im  Jahr  2015 
berichtet. 18 Mitgliedstaaten haben über Fortschritte im Jahr 2018 berichtet. 

Aufgrund  des  kritischen  Zustands  des  Aalbestands  und  der  nicht  schlüssigen  Ergebnisse 
bestehender Bewirtschaftungsmaßnahmen im Rahmen der Aalverordnung haben die Europäische 
Kommission  und  die  Mitgliedstaaten  auf  einer  Tagung  im  Dezember  2017  vereinbart,  ihre 
Anstrengungen zum Schutz des Bestands zu verstärken (Rat der Europäischen Union, 2018); dies 
umfasst auch die Durchführung dieser Bewertungsstudie über die Aalverordnung. 

7 BE, CZ, DK, EE, FI, FR, DE, EL, IE, IT, LV, LT, LU, NL, PL, PT, ES, SE, UK 

 
 
 
                                           
Methodologie 

Evaluation of the Eel Regulation 

Diese  Studie  wurde  über  einen  Zeitraum  von  siebeneinhalb  Monaten  durchgeführt,  wobei  der 
Abschlussbericht  Mitte  Mai  2019  vorgelegt  wurde.  Sie  wurde  in  vier  verschiedenen  Phasen 
durchgeführt,  die  in  der  Abbildung  auf  der  Rückseite  dargestellt  sind  und  nachstehend  kurz 
beschrieben werden. 

1.  Anfangsphase: 

lief  über  die  ersten  vier  Wochen  des  Projekts  nach  der 
Vertragsunterzeichnung am 21. Oktober 2018. Sie umfasste ein Projektstart-Meeting, die 
Entwicklung  der  Interventionslogik  und  einer  vorläufigen  Matrix  von  Bewertungsfragen, 
und führte zur Einreichung von einem Vorbericht (am 2. November 2018). 

2.  Datenerfassung  durch  Recherche:  Erhebung  von  Evidenz  zur  Beantwortung  der 
Bewertungsfragen. In dieser Phase haben wir zwei Projektfortschrittsberichte eingereicht 
und die Phase endete mit der Abgabe des Zwischenberichts am 18. Januar 2019. 

3.  Konsultationen mit  den  Interessengruppen:  Diese  dritte  Phase  des  Projekts  verlief 
weitgehend parallel zu Phase 2, damit mit der Erhebung von Evidenz für die Bewertung 
begonnen  werden  konnte.  Sie  wurde  daher  im  Zwischenbericht  aufgeführt  und  bestand 
sowohl aus einer öffentlichen Konsultation (OPC) als auch aus gezielten Konsultationen. 
Mit  Unterstützung  der  Berater  bei  der  Ausarbeitung  der  Fragen  hat  die  Kommission  am 
14.  Dezember  2018  die  OPC  gestartet  und  am  8.  März  2019  abgeschlossen.  Darüber 
hinaus  haben  wir  spezielle  Konsultationen  mit  wichtigen  Interessengruppen  in  allen 
relevanten Mitgliedsstaaten durchgeführt, die direkt von der Aalverordnung betroffen sind 
(z.B.  staatliche  Behörden,  Fischer  und  Landwirte  sowie  diejenigen,  die  sich  mit  der 
Wiederauffüllung und dem Handel von Aalen befassen), ein Interesse an der Umsetzung 
der Aalverordnung haben (z.B. internationale Organisationen wie Organe, die CITES und 
das  CMS  durchführen,  NROs)  oder  in  der  öffentlichen  Konsultation  vertreten  sind  (z.B. 
Forschungseinrichtungen). Insgesamt wurden 174 Fragebögen erstellt und 80 Antworten 
empfangen  und  analysiert.  Darüber  hinaus  führten  wir  elf  persönliche  und  zwölf 
telefonische  Interviews  mit  wichtigen  Interessengruppen  durch.  Dieser  Prozess  wurde 
durch Fallstudien in Frankreich, Dänemark und Italien unterstützt. 

4.  Analyse und Präsentation: In dieser letzten Phase der Evaluierung haben wir die in den 
vorherigen  Phasen  gesammelten  Daten  verarbeitet  und  analysiert,  um  sie  zu 
synthetisieren und zu triangulieren und die Bewertungsfragen zu beantworten. Auf dieser 
Grundlage  ziehen  wir  evidenzbasierte  Schlussfolgerungen  und  schlagen  gegebenenfalls 
Empfehlungen vor. 

Während  der  Vertragsdauer  übermittelte  das  Bewertungsteam  der  GD  Mare  monatliche 
Fortschrittsberichte.  Am  Ende  des  Vertrags  hielt  der  Leiter  des  Bewertungsteams  eine  40-
minütige Präsentation der Bewertungsergebnisse auf einer Mittagskonferenz ab, die von der GD 
Mare am 29. April 2019 veranstaltet wurde. Daran nahmen rund 40 Teilnehmer aus der GD Mare, 
der GD Umwelt und dem Generalsekretariat teil und weitere 45 Minuten wurden für Klarstellungen 
und Diskussionen generiert. 

In Anbetracht der umfangreichen OPC-Antworten (174) und der gezielten Konsultation (80) sowie 
der  umfangreichen  Evaluierungen  der  EMP-Fortschrittsberichte  durch  das  ICES-WKEMP  Ende 
2018 sind wir der Meinung, dass die Bewertung robust und wohlunterrichtet ist. 

 
 
 
Übersicht der Bewertungsschritte 

Evaluation of the Eel Regulation 

Analyse und Antworten auf die Bewertungsfragen 

Relevanz: Die Anlandungen von europäischem Aal sind von rund 10.000 Tonnen Anfang der 90er 
Jahre auf rund 2.500 Tonnen seit 2010 zurückgegangen, doch die Rückwanderungswerte liegen 
immer noch weit unter dem allgemeinen Ziel des EU-Wiederauffüllungsplans von mindestens 40% 
der  Silberaal-  Biomasse,  die  existiert  hätte,  wenn  sich  kein  anthropogener  Einfluss  auf  den 
Bestand ausgewirkt hätte. Es ist jetzt anerkannt, dass eine Schlüsselquelle für die Aalsterblichkeit 
nichtfischereibezogene  anthropogene  Aktivitäten 
z.B.  die  Auswirkungen  von 
Wasserkraftturbinen und Staudämmen auf Migration und Rückwanderung und die Tatsache, dass 
die  Erholung  des  europäischen  Aals  ein  langfristiger  Prozess  ist,  der  angesichts  der  langen 
Lebensdauer  der  Art  (z.B.  20  Jahre)  Jahrzehnte,  nicht  Jahre,  dauern  wird.  In  Bezug  auf  die 
Wiederauffüllung  des  Bestands  -  sowohl  aus  der  direkten  Fischerei  als  auch  aus  anderen 
anthropogenen Sterblichkeitsquellen - sind die spezifischen Ziele der Aalverordnung daher nach 
wie vor von hoher Relevanz. 

sind, 

Die  Gemeinsame  Fischereipolitik  konzentriert  sich  hauptsächlich  auf  die  Erhaltung  der 
biologischen  Meeresschätze,  wobei  der  Süßwasserbereich  auf  Markt-  und  Finanzmaßnahmen 
beschränkt ist. Die Aalverordnung (2007), die der reformierten GFP (2013) vorausgeht, erweitert 
den Geltungsbereich des EU-Mandats auf die Bewirtschaftung des europäischen Aals in Süßwasser 
und konzentriert sich in erster Linie auf die Bewältigung der fischereibezogenen anthropogenen 
Sterblichkeit.  Dies  geschieht  vor  allem  durch  zunehmende  Flucht  und  Verringerung  der 
fischereilichen Sterblichkeit. Außerdem müssen die Mitgliedstaaten Maßnahmen ergreifen, um die 
durch  Faktoren  außerhalb  der  Fischerei  verursachte  Aalsterblichkeit  zu  verringern,  und  die 
Habitatrichtlinie und die Wasserrahmenrichtlinie werden ausdrücklich als wichtige Vorläufer und 
unterstützende Rechtsvorschriften anerkannt. 

Wirksamkeit:  In  Bezug  auf  den  Prozess  haben  19  EU-Mitgliedstaaten  mit  bedeutenden 
Aalhabitaten nationale Aalbewirtschaftungspläne erstellt, obwohl die Tatsache, dass nur fünf EMPs 
auf der Ebene der Aalbewirtschaftungseinheiten (EWU) tätig sind, Anlass zur Sorge gibt. Jedoch, 
wie  oben  angedeutet,  wird  es  erheblich  länger  dauern,  bis  die  EMP-Ziele  erreicht  sind.  Der 
Aalbestand hat sich in keinem Maße erholt, die anthropogene Sterblichkeit außerhalb der Fischerei 
ist  im  letzten  Jahrzehnt  nicht  signifikant  zurückgegangen  und  das  40%-Ziel  für  die 
Rückwanderung wurde  nicht erreicht. Während die Wiederauffüllung eine Maßnahme ist, die in 
vielen  EMPs  vorkommt,  haben  nur  sechs  ihr  EMP-Besatzziel  erreicht.  Während  im  Jahr  2013 
mangelnde  Finanzierung  die  Wiederauffüllung  der  Bestände  einschränkte,  sind  die  steigenden 

 
 
 
Evaluation of the Eel Regulation 

Kosten für Glasaal ein neueres Problem. Das Ziel, den Fischereiaufwand um mindestens 50% zu 
senken, hat einige Erfolgreiche gebracht. Der Fischereiaufwand ist in Schweden (um über 90%), 
Italien (etwas mehr als 50%), Dänemark und  Frankreich (um fast 50%) und Deutschland (um 
25%)  zurückgegangen.  Die  Anstrengungen  scheinen  jedoch  in  Großbritannien  auf  135%  des 
Niveaus von 2008 und in Polen auf 180% des Niveaus von 2012 angestiegen zu sein. 

Die Rückverfolgbarkeit von Aalen ist nach wie vor ein zentrales Thema, insbesondere bei lebenden 
Glasaalen.  Die  Rückverfolgbarkeit  innerhalb  der  EU  wird  durch  einige  Mängel  des  EU-
Kontrollsystems im Zusammenhang mit der Kontrolle der Tätigkeiten von Schiffen mit einer Länge 
von weniger als 10 m behindert. Es wurde jedoch zunehmend anerkannt, dass dies der Schlüssel 
zur Kontrolle illegaler Exporte aus der EU ist, und eine Reihe von Mitgliedstaaten implementieren 
derzeit  Rückverfolgbarkeitssysteme  auf  der  Grundlage  der  EU-CITES-Verordnung,  die  von 
Initiativen des Privatsektors wie der Sustainable Eel Group unterstützt werden. Dennoch scheint 
die schwache Rückverfolgbarkeit des Aals „vom Netz bis zum Teller“ ein wesentlicher Risikofaktor 
zu sein. Die EU-Kontrollverordnung schreibt eine Rückverfolgbarkeit für alle Arten (einschließlich 
Aal)  vor.  Dies  ist  jedoch  noch  weit  von  einem  wirksamen  System  entfernt,  dessen  Umsetzung 
durch die Mitgliedstaaten erheblich verbessert werden muss. Die vorgeschlagene Überarbeitung 
des  EU-Kontrollsystems  dürfte  die  Überwachung  und  Kontrolle  der  Aalfischerei  dramatisch 
verbessern. 

Die europäische Aalfischerei ist der festen Überzeugung, dass eine begrenzte und transparente 
Fangfischerei sowohl nachhaltig als auch wünschenswert ist, insbesondere wenn sie auf kleinen 
traditionellen  Betrieben  beruht.  Diese  Meinung  stützt  sich  auf  Ergebnissen  der  OPC,  die  eher 
externe  Faktoren  und  nicht  Probleme  mit  der  Gesetzgebung  selbst  hervorheben,  wie  die 
Unfähigkeit  Wasserkraftsterblichkeit  oder  Wilderei  zu  reduzieren,  und  die  nicht  ausreichende 
Implementierung von Regelungen auf nationaler Ebene.  

Nachhaltigkeit: Es gibt kein „Enddatum“ für die Aalverordnung, daher gilt diese als unbefristet, 
zumindest  bis  sich  der  europäische  Aalbestand  vollständig  erholt  hat. Wie  in  dieser  Bewertung 
häufig  erwähnt,  handelt  es  sich  bei  der  Erholung  der  europäischen  Aalpopulation  um  einen 
langfristigen  Prozess.  Einige  Mitgliedstaaten  halten  2050  für  einen  vernünftigen  Zeitpunkt,  an 
dem das in der Verordnung festgelegte Ziel einer EU-weiten Rückwanderung von 40% erreicht 
werden könnte. Die Reduzierung der kommerziellen Fischereitätigkeit kann sich langfristig auf die 
fischereiliche  Sterblichkeit  auswirken,  es  besteht  jedoch  die  Gefahr,  dass  die  IUU-Fischerei  - 
getrieben durch den in Asien für europäische Glasaale gezahlten hohen Preis - ein gewisses Maß 
an  fischereilicher  Sterblichkeit  aufrechterhält,  das  sowohl  schwer  einzuschätzen  ist,  als  auch 
mögliche Auswirkungen auf die Erholung der Bestände haben kann, und somit die Nachhaltigkeit 
der Initiative gefährdet. Das Wiederauffüllen von Lagerbeständen ist eine kurz- bis mittelfristige 
Maßnahme,  die  schrittweise  eingestellt  werden  sollte,  da  die  natürliche  Rekrutierung  und  die 
Konnektivität  der  Wasserläufe  verbessert  werden  müssen.  Strukturelle  Maßnahmen  zur 
Durchgängigkeit von Flüssen und zur Verbesserung der  Lebensräume von Flüssen können  sich 
zusammen mit anderen Umweltmaßnahmen auf Aalbestände langfristig am stärksten auswirken. 
Sobald sich der europäische Aalbestand vollständig erholt hat, könnte zu diesem Zeitpunkt die 
Regulierung überdacht und ein Plan für eine nachhaltige Bewirtschaftung aufgestellt werden. In 
der  Zwischenzeit 
regelmäßigen 
Fortschrittsberichte fortgesetzt werden. 

in  der  Verordnung  vorgeschriebenen 

sollten  die 

Effizienz:  Eine  monetarisierte  Analyse  des  Kosten-Nutzen-Verhältnisses  der  Aalverordnung  ist 
zum gegenwärtigen Zeitpunkt nicht quantifizierbar, da die Mitgliedstaaten die direkten Kosten für 
die  Umsetzung  der  Verordnung  nicht  messen,  da  ihre  Zuständigkeit  häufig  auf  mehrere 
Regierungsstellen  verteilt 
ist.  Die  direkten  Umweltvorteile  der  EMP-Maßnahmen  (z.B. 
Wiederauffüllung  des  Aalbestands  durch  verringerte  fischereiliche  Sterblichkeit  und  erhöhte 
Rückwanderung in Laichbereiche) und die indirekten Umweltvorteile (wiederverbundene Küsten-
,  Mündungs-  und  Flussökosysteme)  sind  langfristiger  Natur,  noch  im  Entstehen  begriffen  und 
müssen  erst  je  nach  ihren  Umweltvorteilen  gemessen  werden.  Dennoch  ist  die  Verordnung  im 
Wesentlichen solide, und die meisten Befragten in den Mitgliedstaaten gaben an, dass alternative 
Ansätze nicht in Betracht gezogen wurden. Es wird jedoch anerkannt, dass die Umsetzung vieler 
Maßnahmen ein langfristiger Prozess ist, und dass viele Aspekte noch nicht vollständig verwirklicht 
sind. Ein weiterer Bereich, der verbessert werden muss, ist die Fortschrittsberichterstattung, die 

 
Evaluation of the Eel Regulation 

harmonisierter  und  robuster  sein  muss.  Gegenwärtig  erwägen  die  EU-Mitgliedstaaten  keine 
politischen Alternativen zur Aalverordnung, da diese langfristig als relevant und wirksam erachtet 
wird. 

Kohärenz: Wie bereits erwähnt, steht die Aalverordnung im Wesentlichen im Einklang mit den 
GFP- und Umweltvorschriften wie der WRRL und der Habitatrichtlinie. Es besteht Spielraum für 
eine  Verbesserung  der  Konnektivität  zwischen  Bewirtschaftungsplänen  für  Flusseinzugsgebiete 
und  den  EMPs,  sowie  den  mit  deren  Umsetzung  beauftragten  Behörden,  einschließlich  der 
Harmonisierung  und  Priorisierung  von  Maßnahmen,  insbesondere  im  Hinblick  auf  den 
hydromorphologischen  Druck.  In  den  letzten  Jahren  hat  die  GFCM  die  Notwendigkeit  für 
Aalmanagement im Mittelmeerraum erkannt. Es profitiert auch von Beschränkungen im Handel 
mit europäischem Aal außerhalb der EU durch CITES, und es besteht erheblicher Spielraum, die 
Rolle des CMS beim weltweiten Aalschutz auszubauen. 

EU-Mehrwert: Die Aalverordnung hat die Entwicklung von Rechtsvorschriften zum Schutz und 
zur Bewirtschaftung von Aalen in den Mitgliedstaaten vorangetrieben. Es hat auch Manager aus 
verschiedenen Regionen und Organisationen in den Mitgliedstaaten zusammengebracht, um die 
Pläne  und  damit  verbundenen  Maßnahmen  zu  entwickeln.  Die  Aalverordnung  hat  auch  andere 
EU-finanzierte Maßnahmen zur Unterstützung der Erholung des europäischen Aals angeregt, wie 
beispielsweise das kürzlich gestartete SUDOANG-Projekt in Südwesteuropa. Die Verordnung hat 
das  Bewusstsein  für  die  Notwendigkeit  geschärft,  den  europäischen  Aal  in  seinem  gesamten 
Verbreitungsgebiet zu erhalten und zu bewirtschaften. 

Schlussfolgerungen und Empfehlungen 

Die Verabschiedung der Aalverordnung gilt als ein wichtiger Meilenstein in dem langen Prozess, 
der die Erholung des Europäischen Aals ermöglicht. Die grundlegende Prämisse ist nach wie vor 
solide,  und  die  Verordnung  ist  nach  wie  vor  genauso  relevant  wie  im  Jahr  2009.  Trotz 
bemerkenswerter Fortschritte bei der Reduzierung des Fischereiaufwands und des konzertierten 
Versuchs, einen EU-weiten Bewirtschaftungsrahmen zu entwickeln, ist der ICES der Ansicht, dass 
der Status des Aals kritisch bleibt. 

Dies  bedeutet  nicht,  dass  die  Verordnung  nicht  funktioniert.  Die  Hauptgründe,  warum  die 
Aalwanderung  und -rückwanderung  behindert  wurde,  bestehen  nach  wie  vor  und  es  wird  viele 
Jahre, sogar Jahrzehnte dauern, bis sich die europäische Aalpopulation signifikant erholt hat. Die 
meisten Interessenträger sind sich einig, dass die Verordnung solide ist, ihre Umsetzung muss 
jedoch erheblich verbessert werden, insbesondere im Hinblick auf die anthropogene Sterblichkeit 
außerhalb des Fischereisektors. Darüber hinaus muss der derzeitige hochrangige nationale Ansatz 
für  das  Aalmanagement,  der  von  einigen  Mitgliedstaaten  verwendet  wird,  auf  die  Ebene  der 
Wasserscheide reduziert werden, wobei der Schwerpunkt auf den Aalmanagementeinheiten und 
ihren individuellen Herausforderungen liegt. Einige stellen auch die derzeitige Ausrichtung auf die 
Steigerung der Biomasse und des Vorkommens von Aalen in Frage, und ob die Festlegung von 
Sterblichkeitszielen im Einklang mit dem langfristigen Ziel von 40% Biomasse aus Silberaal auf 
geografisch  verteilter  Basis  (z.  B.  auf  der  Ebene  der  WWU)  nicht  eine  effizientere 
Befischungsstrategie wäre. 

Auf der  Ebene der Mitgliedstaaten wurden einige bemerkenswerte Fortschritte erzielt, die auch 
darauf  hindeuten,  dass  die  Verordnung  im  Laufe  der  Zeit  ein  entscheidender  Faktor  für  die 
Erholung  des  Europäischen  Aals  sein  wird.  Italien  hat  gezeigt,  wie  Multi-Interessengruppen-
Plattformen  dazu  beitragen  können,  regionale  EMPs  an  die  Art  und  die  Umstände  der  lokalen 
Aalbewirtschaftungsbedürfnisse anzupassen. In Frankreich und im Vereinigten Königreich wurden 
bewährte Verfahren entwickelt und veröffentlicht, um die Flussbauten „aalfreundlich“ zu gestalten 
und vor Wasserkrafteinleitungen zu schützen. Es gab auch Versuche, Migrationsrouten zu öffnen 
und  hydrologische  Systeme  zu  entwickeln,  die  die  Aalbewegung  begünstigen,  insbesondere  in 
Frankreich und Italien. Signifikante Entwicklungen gab es auch bei der Zertifizierung nachhaltiger 
Aalfischerei  durch  Dritte.  Besonders  hervorzuheben  ist  die  Entwicklung  von  CITES-basierten 
Rückverfolgbarkeitssystemen in Griechenland und Italien, die dazu beitragen könnten, den Handel 
mit Aalen innerhalb der EU zu verfolgen und das Risiko illegaler Ausfuhren nach außerhalb der EU 
zu  verringern.  Gemeinsame  Operationen,  wie  die  von  Europol  unterstützten  spanisch-

 
Evaluation of the Eel Regulation 

portugiesischen „Operations Elvers“, bei denen 350 kg Glasaal für China beschlagnahmt wurden, 
zeigen auch, wie multinationale grenzüberschreitende Kontrolloperationen funktionieren können. 

Auf der Grundlage der Bewertung kann eine Reihe von Empfehlungen formuliert werden, um die 
Wirksamkeit der Verordnung sowohl durch ihre direkte Umsetzung als auch über andere Wege, 
die durch diese EU-Maßnahmen angeregt werden, zu verbessern. 

Direkte Probleme bei der Umsetzung der Aalverordnung 

•  Ein angemessener Schwerpunkt auf Mitgliedstaaten mit einer bedeutenden Produktion 

von Glasaal (FR, UK, ES & PT) und Gelb- und Silberaal (FR, UK, DK, SE, IT, PL, NL, ES & 
EL) für Fischereimaßnahmen mit einem weniger strengen Ansatz gegenüber 
Mitgliedstaaten mit keiner oder sehr geringer Produktivität.  

•  EMPs werden in allen Mitgliedstaaten auf WWU-Ebene entwickelt, es sei denn, es gibt 

glaubwürdige Beweise dafür, dass Pläne für mehrere WWU gerechtfertigt sind. Stärkere 
Betonung der grenzüberschreitenden Zusammenarbeit innerhalb der EU und an ihren 
Grenzen. 

•  Die EMPs müssen sich stärker auf nichtfischereibezogene Maßnahmen konzentrieren, z. 
B. (i) strukturelle Maßnahmen zur Durchgängigkeit von Flüssen und zur Verbesserung 
der Flusslebensräume sowie andere Umweltmaßnahmen und (ii) das vorübergehende 
Abschalten von Wasserkraftturbinen. Erforderlichenfalls sollte die Entwicklung dieser 
Maßnahmen gemeinsam mit den Behörden durchgeführt werden, die mit der 
Durchführung der damit verbundenen Maßnahmen beauftragt sind. 

•  Größerer Druck auf die Mitgliedstaaten, die Verordnung in vollem Umfang zu erfüllen. Da 
sich die EMPs in Bezug auf Qualität und Gebrauchseignung unterscheiden, hat dies zu 
den bisherigen Teilquoten bei der Umsetzung und zu den unterschiedlichen Reaktionen 
auf Fortschrittsberichtsanforderungen und Datenabrufe (sowohl von der EU als auch vom 
ICES) geführt. 

•  Mehr spezifische Fristen und Zwischenziele in der Verordnung. Obwohl die Verordnung 
als langfristiger Ansatz anerkannt ist, ist sie nicht zeitgebunden. Es gibt dafür gute 
Gründe, aber viele Interessengruppen haben darum gebeten, Zwischenziele zu 
entwickeln und die Fortschritte auf diesem Weg zu überwachen. Es ist wichtig, dass 
solche Zwischenziele nicht nur die fischereibezogene Sterblichkeit, sondern auch die 
nichtfischereibezogene Sterblichkeit und Proxy-Indikatoren (z. B. verbesserte 
Konnektivität von Flüssen) abdecken. Dies erfordert möglicherweise eine Neuausrichtung 
aller Schutzmaßnahmen, Bewertungen, Bewertungen und Empfehlungen zu Zielen und 
Indikatoren für die anthropogene Mortalität, wobei die einzelnen 
Bewirtschaftungsbereiche (Länder) einzeln zu berücksichtigen sind. 

•  EMPs sollten regelmäßig überprüft werden, um sicherzustellen, dass sie robust, relevant 
und effektiv bleiben. Dies erfordert laufende Forschung sowie die Überwachung der 
Umweltbedingungen, der Konnektivität und der Fangmöglichkeiten, der Dokumentation 
und der Rückverfolgbarkeit (CDT). Die Überprüfung der EMPs muss vorerst alle drei 
Jahre fortgesetzt werden. 

•  Die Bewertung ergab eine mögliche Ursache für eine rechtliche Fehlinterpretation von 

Art. 7.1 der Aalverordnung in Bezug auf die Wiederauffüllung, wonach 60% der jährlich 
gefangenen Glasaale nicht für diesen Zweck vermarktet werden dürfen. Infolgedessen 
können die Kontrollbehörden diese Vorschrift nicht durchsetzen. Artikel 7.1 der 
Aalverordnung muss möglicherweise unter Berücksichtigung der anhaltenden Relevanz 
anderer Vorschriften für die Wiederauffüllung überarbeitet werden. 

•  Ein kohärenterer Finanzierungsansatz für EMPs und damit verbundene Maßnahmen sind 
erforderlich. Nur wenige Mitgliedstaaten stellen Haushalte für die Umsetzung ihrer EMPs 
bereit, um solche Aspekte wie Wiederauffüllungskosten und Projekte zur Verbesserung 
des Lebensraums abzudecken. Dies sollte die Rolle des EMFF und anderer öffentlicher 
Mittel der EU, die Rolle des Privatsektors und möglicherweise die Entwicklung spezieller 
Finanzinstrumente zur Finanzierung des langfristigen Aalschutzes und -managements 
einschließen. Dies legt nahe, dass die Aalverordnung und ihre Maßnahmen speziell in 
den operationellen Programmen des EMFF für den nächsten Finanzierungszeitraum 

 
Evaluation of the Eel Regulation 

(2021 - 2027) berücksichtigt werden sollten. Insbesondere die Auffüllung von Glasaal, 
die vom EMFF und anderen öffentlichen Fonds unterstützt wurden, muss im Hinblick auf 
den Nettonutzen für die Silberaal-Rückwanderung besser gerechtfertigt werden. In der 
Folgenabschätzung der Kommission zu den Auswirkungen des EMFF (SWD) heißt es 
auch, dass die Mitgliedstaaten die nationalen Bewirtschaftungspläne zum Schutz der 
Aale in den Binnengewässern stärken müssen (EC, 2018). 

Weiterreichender Governance und Aalmanagement Probleme 

•  Für die Erholung des Europäischen Aals ist eine zentrale Koordinierungsstelle 

erforderlich. Die Aalverordnung sieht einen einheitlichen Ansatz in der gesamten EU vor, 
das Kernthema der Bestandserholung erfordert jedoch einen umfassenden Ansatz. Eine 
Interessengruppe nannte die North Atlantic Salmon Conservation Organization (NASCO) 
als mögliches Modell. 

•  Der derzeitige schlechte Zustand des europäischen Aals muss besser bekannt gemacht 

werden, damit ein größerer öffentlicher Druck ausgeübt werden kann, um das 
Aalmanagement und die Bedingungen in den Wasserbecken zu verbessern. 

•  Es sind international koordinierte Forschungsarbeiten erforderlich, um den Nettonutzen 

einer Wiederauffüllung der Gesamtpopulation zu bestimmen, einschließlich 
Tragfähigkeitsschätzungen der Flussmündungen von Glasaalquellen, detaillierter 
Sterblichkeitsschätzungen bei jedem Schritt des Auffüllungsprozesses und 
Leistungsschätzungen von eingesetzten vs. nicht eingesetzten Aalen. 

•  Koordinierte Erforschung der Aquakulturtechniken für Aale, um eine kommerziell 

tragfähige künstliche europäische Glasaalproduktion zu entwickeln. 

•  Entwicklung paralleler Managementmaßnahmen in Nicht-EU-Ländern, einschließlich der 
Entwicklung umfassender Aalmanagementpläne (auf grenzüberschreitender Ebene, 
sowohl mit der EU als auch mit Drittländern), koordinierte Forschung. 

•  Förderung von Mitgliedstaaten, die CITES-Verpflichtungen in vollem Umfang zu nutzen, 
um die Kontrolle der Rechtmäßigkeit der in ihrem Hoheitsgebiet festgehaltenen oder 
zum Verkauf angebotenen Aale zu stärken. 

•  Es sind weitere Maßnahmen erforderlich, um das Übereinkommen über wandernde Arten 

(CMS) zu nutzen und um sicherzustellen, dass es zur Verbesserung des 
Erhaltungszustands des Europäischen Aals und seiner Bewirtschaftung beiträgt. In der 
Praxis bedeutet dies die Entwicklung eines geeigneten Instruments, sei es in Form einer 
rechtsverbindlichen Vereinbarung oder in Form einer anderen Lösung, die in der großen 
CMS-Mittelfamilie bereits existiert. 

Referenzen in der Zusammenfassung 

Rat der Europäischen Union (2018). Vorschlag für eine Verordnung des Rates zur Festsetzung 
der Fangmöglichkeiten für bestimmte Fischbestände und Bestandsgruppen in Unionsgewässern 
und  für  Fischereifahrzeuge  der  Union  in  bestimmten  Nicht-Unionsgewässern  für  2018  und  zur 
Änderung 
127 
(EU) 
http://data.consilium.europa.eu/doc/document/ST-5382-2018-INIT/en/pdf  

Verordnung 

Rates/ 

2017 

des 

der 

Europäische  Kommission  (2014).  Bericht  der  Kommission  an  den  Rat  und  das  Europäische 
Parlament. Zu den Ergebnissen der Umsetzung der Aalbewirtschaftungspläne, einschließlich einer 
Bewertung der Maßnahmen zur Wiederauffüllung und der Entwicklung der Marktpreise für Aale 
mit einer Länge von weniger als 12 cm. Brüssel, 21.10.2014. COM(2014) 640 final. 

Europäische  Kommission  (2018).  FOLGENABSCHÄTZUNG.  Begleitdokument  „Vorschlag  für 
eine Verordnung des Europäischen Parlaments und des Rates über den Europäischen Meeres- und 
Fischereifonds  und  zur  Aufhebung  der  Verordnung  (EU)  Nr.  508/2014  des  Europäischen 
Parlaments  und  des  Rates  über  das  Arbeitspapier  der  Kommissionsdienststellen. 
{COM(2018)390final} -{SEC(2018)276final} 

ICES  (2013).  Bericht  über  den  Workshop  zu  Fortschrittsplänen  für  das  Aalmanagement 
(WKEPEMP), 13–15 Mai 2013, Kopenhagen, Dänemark. ICES CM 2013/ACOM:32. 757 pp. 

 
Evaluation of the Eel Regulation 

1.0 INTRODUCTION 

 BACKGROUND 

Following  multi-decadal  decline  of  the  European  eel  stock  across  Europe,  in  2002  the  International 
Council for the Exploration of the Sea (ICES) recommended that a recovery plan for European eel was 
urgently  needed  (ICES,  2002)  and  subsequently  in  2003  the  European  Commission  proposed  the 
development of a ‘Community Action Plan for the management of European Eel’ (EC, 2003).  Following 
this, the Council of the European Union adopted a regulation to put in place measures for the protection 
and recovery of this complex species in 2007.  The Council Regulation 1100/2007 for the recovery of 
the eel stock (hereafter the ‘Eel Regulation’) required MSs to establish eel management plans (EMPs) 
for their river basins that constitute significant eel habitats for implementation in 2009.   

According  to  recurrent  scientific  advice,  “the  European  eel  stock  is  in  critical  condition  and  urgent 
action is needed” to ensure its recovery. On this basis, during the December 2017 Council meeting, 
in the context of the negotiations of the Regulation for the 2018 Fishing opportunities, the European 
Commission and Member States agreed to step up their efforts to protect the stock. This includes also 
carrying  out  the  evaluation  of  the  Eel  Regulation,  for  which  a  roadmap  (EC,  2018b)  was  open  to 
consultation over the second quarter of 2018. 

The evaluation aims at assessing the measures for the recovery of the stock of the European eel under 
the Eel Regulation, and in particular the contribution of the national Eel Management Plans established 
and implemented under this Regulation. These Plans include measures to ensure in the long-term 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; 
making it easier for fish to migrate through the rivers; restocking suitable inland waters with young 
eel. 

The  Commission  attempted  a  first  assessment  of  the  outcome  of  the  implementation  of  the  Eel 
Management Plans in 2014, on the basis of the first progress reports submitted by Member States in 
line with Article 9 of the Eel Regulation and reported to the European Parliament and to the Council 
(EC, 2014a). The results of this first assessment were largely inconclusive due to the delays in the 
preparation and approval of the national Eel Management Plans and the delays in the implementation 
of non-fisheries related measures. 

 PURPOSE OF THIS EVALUATION  

The objective of this evaluation study was to assist DG MARE's evaluation of the currently applicable 
measures  for  the  recovery  of  European  eel  stock  under  the  Eel  Regulation  by  examining  their 
effectiveness, efficiency, relevance, coherence, EU added value and sustainability. 

This was done with the purpose to: 

- 
- 
- 

support the implementation of the current Eel Regulation; 
enhance transparency and accountability, and 
improve the application of this policy. 

The evaluation assesses to what extent the measures under the Eel Regulation are fit for purpose. In 
accordance with the Better Regulation requirements, the evaluation will help to assess the coherence 
between the various pieces of legislation drafted at different times as well as to identify potential for 
simplification. 

Based on its outcome, the results of this evaluation study may be used to inform the decision whether 
the Eel regulation needs to be reviewed and/or whether its implementation needs to be improved. It 
also aims to provide evidence for a possible future impact assessment and/or guide the Commission 
in improving the implementation of the Regulation. 

In  addition  to  the  Commission,  the  results  may  also  be  used  by  Member  States  and  their  national 
authorities, other EU institutions, international organisations and other stakeholders. 

June 2019 

1 

 
 SCOPE OF THIS EVALUATION  

Evaluation of the Eel Regulation 

This  evaluation  study  covers  the  management,  implementation  and  enforcement  issues,  including 
trade  aspects.  This  evaluation  looks  in  particular  into  the  content  and  implementation  of  the  Eel 
management  plans  and  Member  States  reporting  under  the  Eel  Regulation  to  assess  if  they  have 
adequately addressed all mortality factors affecting the eel stock, with a special emphasis to 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 rules in place such as 
the Common Fisheries Policy (European Parliament & the Council of the European Union, 2013), the 
fisheries control regulation (Council of the European Union, 2009) and environmental legislation, in 
particular the Water Framework Directive (European Parliament & the Council of the European Union, 
2000)  and  information  on  eel  habitats  derived  from  the  implementation  of  the  Habitats  Directive 
(Council  of  the  European  Union,  1992).  It  looks  as  well  into  the  articulation  and  coherence  with 
international  instruments  that  cover  eels,  such  as  the  Convention  on  International  Trade  in 
Endangered  Species  of  Wild  Fauna  and  Flora  (CITES)8 and  the  Convention  on  the  Conservation  of 
Migratory Species of Wild Animals (CMS)9. 

The measures established under the Eel Regulation are analysed as a set of tools, with their strengths 
and  weaknesses.  The  individual  measures  taken  by  the  Member  States  have  been  investigated  as 
examples for testing the extent to which provisions are fit for purpose. The evaluation also assesses 
the overall functioning of the Eel Regulation as one instrument, with its own objectives, delivery and 
control methods. 

As the eels is a panmictic10 stock, the evaluation study looks into the state of the stock in all its range 
of natural distribution. The evaluation study considers how ‘fit for purpose’ the existing measures for 
the recovery of the eel stock are and how they interact with other EU rules in place. It examines what 
progress has been made since the Eel Regulation came into force in 2007. 

The analysis took into account other contextual elements such as: 

- 

- 

- 

- 

- 

- 

The literature review, reports, scientific advice on eels (in particular annual ICES advice 
on the state of the Eel stock; 

Member States' reports on the implementation of the Eel Regulation and ICES technical 
analysis of these reports; 

The results of inspections carried out on eel fishing activities; 

Commission's analysis of the use of the European Maritime and Fisheries Fund for the 
implementation of the Eel Regulation (contracted with FAME - Fisheries and Aquaculture 
Monitoring and Evaluation under the European Maritime and Fisheries Fund); 

The findings of the 2007-2012 Habitats Directive Article 17 reports on the conservation 
status of the most important Annex I habitats types for the European Eel11 

The existence of other measures established for the recovery of European eel (either at 
international level or regionally established). 

It evaluated the effectiveness, the relevance and coherence of the existing provisions and assessed 
their  efficiency.  The  evaluation  also  considered  the  EU  added  value  of  the  measures,  unintended 
effects and administrative burden created by the measures under the Eel Regulation, as well as the 
sustainability of the measures.  Finally, the evaluation also assessed if there is room for simplification 
of the applicable legal framework. 

8 https://www.cites.org/  
9 http://www.cms.int/  
10 In a population genetics context, if a species is a panmictic stock there is no genetic evidence of 
population structure throughout its range.  For example, European eels are catadromous fish found 
from  Scandinavia  to  the  southern  Mediterranean.    However,  they  all migrate  to  breed  in  the  same 
location in the Sargasso Sea so genetic samples from throughout their European distribution range 
show a complete lack of genetic differentiation, or complete panmixia. 
11 http://art17.eionet.europa.eu/article17/reports2012/habitat/summary/  

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2.0 BACKGROUND TO THE EEL REGULATION 

Evaluation of the Eel Regulation 

The following section introduces the subject matter and policy landscape relevant to eel management 
in the EU. We also present our understanding of the origins, purpose and current implementation of 
the  Council  Regulation  (EC)  No  1100/2007  of  18  September  2007,  henceforth  the  ‘Eel  Regulation’.  
This section takes into account the recent 2018 ICES WGEEL meeting (ICES, 2018c) and Report of 
the Workshop for the Review of Eel Management Plan Progress Reports (WKEMP) (ICES, 2018d).   

 EUROPEAN EEL STATUS 

The  European  eel  (Anguilla  anguilla)  stock  is  in  decline,  recruitment  is  at  an  all-time  low,  and 
exploitation of the stock is currently unsustainable.  The European eel is listed in the IUCN Red List of 
Threatened  Species  as  a  critically  endangered  species  (based  on  2008,  2010  and  2014  IUCN 
assessments),  although  the  most  recent  assessment 12  notes  that  the  critically  endangered 
classification for European eel is borderline, and that if the “recently observed increase in recruitment 
continues,  management  actions  relating  to  anthropogenic  threats  prove  effective,  and/or  there  are 
positive effects of natural influences on the various life stages of this species, a listing of Endangered 
would be achievable” (Jacoby & Gollock, 2014).  

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 
most recent ICES stock advice published in November 2018 confirms that the status of eel remains 
‘critical’  and  that  recruitment  remains  low  (see  Figure  1  below),  and  the  decline  in  recruitment  is 
mirrored by a long-term decline in commercial (Figure 2 overleaf) and recreational fishery landings 
despite significant re-stocking efforts.    

Figure 1: Eel recruitment indices 

Source: ICES, 2018a 

This decline in eel is attributed to multiple causes, with the focus of concern on anthropogenic mortality 
inflicted by fisheries (commercial and recreational, which exploit all eel life stages) and other human 
activities.   

According to ICES estimates, in 2017 the EU harvested around 2,300 tonnes of eels (ICES, 2018c) 
with France, the United Kingdom, Denmark and Sweden 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 (see Figure 
2 overleaf) and since 2011 glass or yellow / silver eel wild production has stabilised at historically low 
levels (see Figure 3 overleaf).  Recreational landings, mainly of yellow and silver eels which during 
the 1980’s exceeded over 1,000 t in France alone, are now around 161 t, mostly from Denmark, but 
Member States (MSs) reporting is now limited.   There is no doubt that additional unaccounted catches 
from IUU glass and silver eel fisheries exist (SEG, 2018).   

12 The Red List assessments of all Anguillid eels are due to be reviewed by IUCN imminently 

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Evaluation of the Eel Regulation 

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. 

Figure 2: Time-series of yellow and silver eel fishery landings by country 

Figure 3: EU wild eel fishery production (2011 - 2016) 

Source: ICES Working Group on Eels (ICES, 2018c) 

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Evaluation of the Eel Regulation 

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, ICES, 2018c).  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.   

Apart  from  fishing,  other  major  anthropogenic  influences  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  (Jacoby  et  al,  2015).    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).  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).  

 EEL MANAGEMENT FRAMEWORK 

2.2.1 The Eel Regulation 
Historically eel fisheries throughout Europe have been managed as coastal, estuarine and freshwater 
fisheries  on  a  local  geographical  scale.    Local  management  actions  were  aimed  at  improving  the 
commercial return from the fisheries and included minimum legal sizes, closed seasons, restocking, 
restricted licensing, and gear restrictions.   

Following multi-decadal decline of the European eel stock across Europe, in 1999 ICES recommended 
that  a  recovery  plan  for  European  eel  was  urgently  needed  and  in  2003  the  EC  proposed  the 
development of a ‘Community Action Plan for the management of European Eel’ (EC, 2003).  Following 
this,  the  EU  adopted  a  regulation  to  put  in  place  measures  for  the  protection  and  recovery  of  this 
complex species in 2007.  The Eel Regulation required MSs to establish eel management plans (EMPs) 
for  their  river  basins  that  constitute  significant  eel  habitats  for  implementation  in  2009.      The 
Intervention Logic for development of the Eel Regulation is represented in Annex 1A: Intervention 
Logic on page 87 and demonstrates the hierarchy between the inputs (e.g. Eel management Plans, 
EMFF funding and various other mechanisms), activities e.g. setting escapement targets, restricting 
fishing  mortality,  etc),  operational  objectives  ,  specific  objectives  and  the  General  Objective  of  the 
“protection  and  sustainable  use  of  the  stock  of  European  Eel  in  Community  waters,  reflecting  the 
needs of thee  2003 Community Action Plan.   

In  accordance  with  Article  2.4  of  this  Regulation,  the  EMPs  should  set  objectives  to  “reduce 
anthropogenic mortalities so as to permit with high probability the escapement to the sea of at least 
40% of the silver eel biomass relative to the best estimate of escapement that would have existed if 
no anthropogenic influences had impacted the stock”.  The 40% escapement target applies uniformly 
to all management units.  Each EMP constitutes a management plan adopted at national level within 
the framework of a Community conservation measure. 

Under  the  Eel  Regulation,  MSs  are  obliged  to  monitor  the  eel  stock,  evaluate  current  silver  eel 
escapement and post-evaluate implemented management actions aimed at reducing eel mortality and 
increasing  silver  eel  escapement.  Under  the  Regulation,  each  MS  should  report  to  the  Commission 
initially every third year until 2018 and subsequently every six years on the monitoring, effectiveness 
and outcomes of EMPs, including: 

•  The proportion of silver eel biomass that escapes to the sea to spawn, or leaves the national 

territory, relative to the target level of escapement;  

•  The level of fishing effort that catches eel each year; 

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Evaluation of the Eel Regulation 

•  The level of anthropogenic mortality factors outside the fishery; and, 

•  The amount of eel < 12 cm in length caught and the proportion used for different purposes. 

These  reporting  requirements  were  further  developed  by  the  Commission  in  201813.  This  guidance 
added the opportunity to report fishing catches (as well as effort), and provides explanations of the 
various biomass, mortality rates and stocking metrics required for international assessment and post-
evaluation through Excel templates. 

It is noted that the Regulation refers to achieving its aim in ‘the long term’ but provides no explicit 
timeline for the achievement of 40% biomass limit, nor sets short term mortality limits. 

2.2.2 Other supporting measures 
In addition to requirements under the Eel Regulation, a joint declaration on strengthening the recovery 
for European eel (Council of the European Union, 2018a) was agreed in December 2017, committing 
Member States to step up their management actions as set out in EMPs, including a review of current 
restocking practices and fighting illegal fishing and trade. In the context of the fishing opportunities 
for 2018, a 3-month ban on commercial fishing for European eel of 12 cm or more in marine waters 
of ICES area (e.g. SE, DK & DE) was to be implemented by each Member State between 1 September 
2018 and 31 January 2019, when eels are migrating and therefore most vulnerable (Council of the 
European  Union,  2018b).  For  the  2019  the  scope  of  the  3-month  ban  was  extended  to  the 
Mediterranean, eel at all live stages, recreational fishing and transitional waters. In the ICES area the 
ban is to be implemented by each Member State between 1 August 2019 and 28 February 2020, in 
the Mediterranean at a period consistent with the eel’s temporal migration pattern.   

In the Mediterranean, the General Fisheries Commission for the Mediterranean (GFCM) has established 
a multi-annual management plan for catching 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.  The GFCM will launch 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 research programme and 
propose additional long-term management measures for eel in the Mediterranean.     

In addition to the Eel Regulation, the EU has a number of mechanisms to control fisheries and manage 
the  aquatic  environment.    These  include  the  Control  Regulation  (Council  Regulation  (EC)  No 
1224/2009), rules on eel fishing ban under the CFP and the Water Framework Directive with its River 
Basin Management Plans relevant for migratory fish species.  These are examined further in Section 
2.2.4 below and analysed in Section 4.6.   

Parallel  to  the  above,  in  2007,  the  European  eel  was  listed  in  Appendix  II  of  the  Convention  on 
International Trade in Endangered Species of Wild Fauna and Flora (CITES), which came into force on 
13 March 2009 (CITES 2007), and the equivalent Annex (B) of the EU Wildlife Trade Regulations.  In 
December 2010, the EU’s Scientific Review Group (SRG) concluded that at the time it was not possible 
to perform a Non-Detriment Finding (NDF) for the export14 of A. anguilla, and subsequently a zero-
import/export policy was set for the EU (EC, 2010). On that basis, EU CITES Management Authorities 
were not able to allow export of A. anguilla from the EU and commercial trade in all commodities of 
A. anguilla to and from the EU was banned from 3 December 2010 (EC, 2010; TRAFFIC, 2015).  

13 Request  from  the  Commission  “Subject:    Member    States’    reports    under    Regulation    (EC)    no  
1100/2007  (the  “Eel regulation”)”  Ares(2018)1830726 -05/04/2018)  and  “Background  Document  
on  the voluntary templates for the preparation Member States reports under Article 9 of Regulation 
1100/2007 (the “Eel regulation”)” (Ref. Ares(2018)504014 -29/01/2018Ref). 
14 In this report we use the term ‘export’ exclusively for trade out of and into the EU to and from third 
countries.  Movement of eels within the EU Member States is referred to as ‘inter-EU’ trade. 

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Evaluation of the Eel Regulation 

At  its  meeting  in  December  2018,  the  SRG  reviewed  again  the  situation  of  European  eels  and 
concluded once again that there was no sufficient scientific evidence demonstrating a recovery of the 
stock and that it would therefore not be possible for the scientific authorities in the EU to deliver a 
non-detriment  finding  for  any  export  from  or  import  into  the  EU  of  European  eels  until  the  end  of 
2019.  On the basis of this and in accordance with the EU Wildlife Trade Regulations (Regulation (EC) 
No 338/97), EU Member States are not in a position to deliver permits allowing export or import of 
European eels until the end of 2019 and have decided on a "zero export quota" until the end of 2019 
for European eels. In operational terms, the consequences of this situation are that export from and 
import into the EU of European eels will not be authorised until the end of 2019. 

2.2.3 Implementation and Evaluation of the Eel Regulation 
Nineteen MSs15 have developed and implemented national EMPs covering almost 90 Eel Management 
Units (see Table 3 on page 19 for more detail).  MSs with only river basins flowing into the Black Sea 
(Hungary  &  Romania)  were  exempted  as  they  do  not  constitute  a  natural  habitat  for  European  eel 
according to the purpose of the Eel Regulation (clarified in 2008/292/EC, see EC, 2008). In addition 
Cyprus, Malta, Austria and Slovakia were also exempted from preparing EMPs in 2009 as their river 
basins or maritime waters concerned cannot be identified and defined as constituting natural habitats 
for the European eel (clarified in 2009/310/EC, see EC, 2009).  Croatia, Slovenia and Bulgaria are not 
formally  exempted  but  have  decided  not  to  submit  EMPs  as  they  consider  eel  catches  (outside  the 
Black Sea in the case of Bulgaria) to be minimal.  As Member States who have not established EMPs, 
they are required to implement a 50% reduction in eel fisheries. Some EMPs have been developed at 
river basin, rather than national level e.g. the ES/PT Transboundary Plan for Mihno River and the UK. 

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.  In 2013,  ICES  evaluated 
these  progress  reports  in  terms  of  the  technical  implementation  of  actions  (ICES,  2013a);  they 
reported that 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.  ICES noted that many MSs did not completely report stock indicators, and that 
where they were reported, different approaches to their calculation had been taken. 

In  2014,  the  European  Commission  reported  to  the  European  Parliament  and  the  Council  with  a 
statistical and scientific evaluation of the outcome  of the implementation of the EMPs (EC, 2014a). 
The results of this first assessment were largely inconclusive due to the delays in the preparation and 
approval of the national Eel Management Plans and the delays in the implementation of non-fisheries 
related measures.  Member States again reported on progress with implementing their EMPs in 2015.  

In 2016, as part of their annual review of eel stocks, ICES indicated that hardly any improvement in 
the status of the stock had been achieved, and that—on average—mortality had not been reduced any 
further since 2012 (ICES, 2016).  To date, 18 Member States have reported on progress in 2018. 

On  the  basis  of  the  critical  condition  of  the  eel  stock  and  inconclusive  outcomes  of  existing 
management  measures  under  the  Eel  Regulation,  at  a  meeting  in  December  2017  the  European 
Commission and Member States agreed to step up their efforts to protect the stock (Council of the 
European Union, 2018a); this includes carrying out an evaluation of the Eel Regulation. 

15 BE, CZ, DK, EE, FI, FR, DE, EL, IE, IT, LV, LT, LU, NL, PL, PT, ES, SE, UK 

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Evaluation of the Eel Regulation 

Online  feedback  on  the  Roadmap  on  the  evaluation  of  the  Eel  Regulation16 run  by  the  European 
Commission in April-May 2018.  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; 

•  A perceived lack of clarity about short-term and long-term targets; 

•  The scale and effects on management of the illegal trade in eels from Europe to Asia; 

•  The lack of evidence on the effectiveness of restrictions on fishing and restocking on the status 

of the eel stock;  

•  The absence of an internationally coordinated management plan for the whole stock area; and 

•  The coherence of the Eel Regulation with other international and European instruments. 

2.2.4 Other Management Instruments and Drivers 
A number of other instruments or drivers, many of which have come into force after the Eel Regulation, 
have the potential to impact, or interact with, measures for the recovery of the European eel stock 
under the Eel Regulation.  Examples of these instruments include: 

•  The  CITES  Convention  -  The  European  eel  became  listed  on  Appendix  II  of  the  CITES 
convention  in  2009;  at  the  end  of  2010  the  Scientific  Authorities  of  the  EU  Member  States 
confirmed  that  they  would  not  be  able  to  issue  a  non-detriment  finding  for  the  export  and 
import  of  A.  anguilla  specimens,  as  required  under  the  Convention.  This  decision  has  been 
confirmed for every year since, and until the end of 2019. Therefore EU Member States have 
not issued permits for the export or import of A. anguilla specimens out of or into the EU.  This 
decision is relevant to managing illegal trade and ‘lost glass eels’. 

•  The EU Water Framework Directive (WFD) – Commits MSs to achieving good ecological status 
for all water bodies and assists in defining river basin districts for which management plans are 
prepared and which in many cases tally with the geographical units covered by EMPs.  It could 
be anticipated that the WFD may result in improvements to water bodies and to river continuity 
that would in turn have a positive effect on the reproductive potential of silver eel. 

•  The  EU  Marine  Strategy  Framework  Directive  (MSFD)  –  The  MSFD  aims  to  achieve  Good 
Environmental  Status  (GES)  of  the  EU’s  marine  waters  by  2020  and  includes  a  specific 
regulatory objective that “biodiversity is maintained”. In some MSs, eels are specifically listed 
in their national MSFD reports. MSs shall provide an initial assessment, determine what good 
environmental status means, set targets and identify the measures (if necessary) which need 
to be taken to achieve or maintain Good environmental status in respect of each marine region 
or subregion concerned. 

•  Natura  2000  –  designation  of  habitats  and  species  in  Special  Area  of  Conservation  (SACs) 
designated under the EU Habitats Directive and  (as well as in Special Protected Areas (SPAs) 
under  the  EU  Birds  Directive).    Covers  marine,  coastal  and  riverine  environments,  their 
inhabitants and ecosystems. 

16 https://ec.europa.eu/info/law/better-
regulation/initiative/1696/publication/223664/attachment/090166e5b9f25648_en  

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•  The  Common  Fisheries  Policy  (CFP)  –  The  reform  of  the  CFP  resulted  in  a  commitment  to 
restoring the biomass of all harvested fish stocks above levels capable of producing Maximum 
Sustainable  Yield  (MSY).  MSY  is  also  used  as  a  key  proxy  criterion  to  assess  Good 
Environmental Status under the MSFD17.  European aquaculture is supported through the Open 
Method  of  Coordination  (OMC).    The  European  Maritime  and  Fisheries  Fund  (EMFF)  is  the 
current mechanism for providing EU public funds to support the CFP and aquaculture in the EU, 
with  Art.  11(f)  permitting  assistance  to  direct  re-stocking  of  eels  as  they  are  under  a 
conservation measure.   

•  The Convention on the Conservation of Migratory Species of Wild Animals (abbreviated as The 
Convention on Migratory Species, CMS) – In 2014 the European eel was added to Appendix II 
of the CMS, whereby Parties  to the Convention (covering most of the range of distribution of 
the European eel)  cooperate in their endeavours to develop  conservation actions (extending 
beyond the EU and the scope of the Eel Regulation). 

Whilst  the  majority  of  these  instruments  should  theoretically  complement  the  Eel  Regulation,  their 
objectives may not always be aligned with those resulting from measures under the Eel Regulation, 
and multiple and varying management objectives and measures of stock status add to the complexity 
of  eel  management.    Furthermore,  whilst  the  legislative  toolbox  may  be  deemed  to  be  ”well 
developed”, there may be issues around a lack of implementation and enforcement. 

These other instruments are discussed in more detail in Sections 4.6 (EU) and 4.7 (non-EU).   

17 MSFD Descriptor 3: Commercial Fish and shellfish “Populations of all commercially exploited fish and shellfish 
are within safe biological limits, exhibiting a population age and size distribution that is indicative of a healthy 
stock.”    In  scientific  terms,  Descriptor  3  has  various  implications.  Stocks  should  be,  (1)  exploited  sustainably 
consistent with high long-term yields, (2) have full reproductive capacity in order to maintain stock biomass, and 
(3) the proportion of older and larger fish/shellfish should be maintained (or increased) being an indicator of a 
healthy stock.  GES is achieved for a particular stock only if all of the three attributes are fulfilled. This implies 
that all commercially exploited stocks should be in a healthy state and that exploitation should be sustainable, 
yielding  MSY.  MSY  is  the  maximum  annual  catch,  which  can  be  taken  year  after  year  without  reducing  the 
productivity  of 
  See  http://ec.europa.eu/environment/marine/good-environmental-
status/descriptor-3/index_en.htm  

fish  stock. 

the 

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3.0 METHODOLOGY 

Evaluation of the Eel Regulation 

3.1 OVERVIEW 
Figure 4 below provides an overview of the methodology and tools used to carry out the evaluation. 
Explanatory text on the methodology for each numbered task shown in Figure 4 is provided in sub-
sections further below. 

Figure 4: Overview of the Evaluation Steps 

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2.1 Status & management of eel stocks

3.1 Open Public Consultation 

2.2 Identification of Best Practices

3.2 Specific Stakeholder Consultations 

2.3 Enforcement of the Eel Regulation

3.3 Collective face to face consultations

2.4 Interlinkages with other instruments

3.4 Case studies

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4.1 Final data analysis

4.2 Final Reports

4.3 Conference 

 PHASE 1: INCEPTION PHASE  

The inception phase ran over the first four weeks of the project, following signing of the contract on 
21st October 2018. It has included the following activities: 

•  Project kick-off and preparatory work, including development of Intervention Logic (see Annex 

1A) and a preliminary Evaluation Question Matrix (see Annex 1B); 

•  Refinement of evaluation approach and methodology; and 

•  Delivery of an Inception Report (submitted on 2nd November 2018). 

 PHASE 2: DESK-BASED DATA COLLECTION  

This  second  phase  of  the  evaluation  was  aimed  at  collecting  evidence  to  answer  the  evaluation 
questions.  During this phase, we submitted two project progress reports and the phase culminated 
with the submission of the Interim Report on 18 January 2019. The main sources of information were 
in the table overleaf.  

June 2019 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

Table 1: Main information sources 

Topic  

Source and Summary of Information  

EMPs and 
Progress 
Reporting  

Fisheries and 
Aquaculture 
Production and 
Other 
Information on 
Stock Status 

Eel Management Plans, Progress Reports (as supplied by DG MARE and 
summarised in Table 2 of the Inception Report)  
Reports on the outcome of the implementation of EMPs (e.g. European 
Commission 2014 Report and WKEMP 2013, WKEMP 2018) ICES advices 
Results of online feedback to the Roadmap on the evaluation of the Eel 
Regulation run by the EC (available online) 
Other reviews of eel management (e.g. journal articles and outputs of relevant 
workshops; e.g. CMS and Sargasso Sea Commission Workshop 2016) 

Advice (available up to 2018), including information on stock status and 
recruitment indices 
WGEEL Reports (available up to 2018) and outputs of other meetings supporting 
WGEEL (e.g. RGMAREEL 2017) 
ICES eel production (wild fisheries and aquaculture) data and advice 
Other analyses of population data (e.g. journal articles such as Jacoby et al. 
2015.  Synergistic patterns of threat and the challenges facing global anguillid 
eel conservation. In Global Ecology and Conservation, and outputs of relevant 
workshops; e.g. HELCOM Workshop on Eel and the Baltic Sea 2017) 

Habitat/Water 
Quality and 
Management  

River Basin Management Plans and Marine Strategies (focusing particularly on 
trends in Good Environmental Status) 
Natura 2000 site/feature status reports 

Trade 

Control 

Restocking 

Glass Eel Price Reports (as supplied by DG MARE and summarised in Table 2 of 
the Inception Report) 
TRAFFIC Reports and Bulletins  
Sustainable Eel Group 2018 report on quantifying illegal eel trade 
ICES WKEELCITES Report 2015 (ICES, 2015b) 
Other reviews of eel management (e.g. journal articles and outputs of relevant 
workshops; e.g. CITES international technical workshop in 2018) 

Results of the 2018 survey on the control of eel fisheries (supplied via DG 
MARE) 

Sustainable Eel Group 2018 evaluation of restocking and recommendations for 
improvement 
ICES WKSTOCKEEL Report 2016 (ICES, 2016c) 
Other relevant analysis (e.g. Dekker and Beaulaton, 2016.  

Funding 

EMFF & EFF funding records (FAME Support Unit reports, Member State Annual 
Implementation Reports) 

 PHASE 3: CONSULTATIONS 

This  third  phase  of  the  project  ran  largely  concurrent  with  Phase  2  and  was  thus  reported  in  the 
Interim Report.  This phase was aimed at collecting evidence to answer the evaluation questions and 
was composed of both a public consultation (PC), specific and targeted consultations.  We have also 
examined the results of the ‘roadmap’ consultations undertaken by the Commission in the first half of 
2018.  

3.4.1 Public Consultation (PC) 
The  PC  was  launched  on  14  December  2018  and  closed  on  8  March  2019.    The  questionnaire was 
produced in English, then translated into all other EU languages by the Commission services.  The PC 
questionnaire used is provided in Annex 3. 

June 2019 

11 

 
Evaluation of the Eel Regulation 

3.4.2 Specific Consultations 
We  conducted  specific  consultations  with  key  stakeholder  groups  across  all  relevant  MSs  that  are 
directly impacted by the Eel Regulation (e.g. state agencies responsible for developing, implementing 
and monitoring against EMPs, fishers and farmers, and those involved in eel restocking and trade), 
have an interest in the implementation of the Eel Regulation (e.g. international organisations such as 
bodies  implementing  CITES  and  the  CMS,  NGOs),  or  may  be  under-represented  in  the  public 
consultation (e.g. research bodies). 

Over the inception phase around 200 potential stakeholder organisations were identified (see Annex 
4A). Based on this 174 questionnaires – both for the national authorities (see Annex 4B) and other 
stakeholder (see Annex 4E) were distributed and around 80 responses received.  Consultations based 
on  the  questionnaires  were  conducted  mainly  via  email  and  telephone,  supported  by  an  official 
Commission introduction letter to encourage cooperation. 

In addition a separate consultation exercise was conducted with the Member States control authorities 
to understand the success or otherwise of eel conservation related control systems in the EU and to 
identify  the  main  challenges  faced.  A  detailed  (see  Annex  4C)  and  a  simplified  (see  Annex  4D) 
standalone  ‘control’  questionnaire  were  developed  for  Member  States  depending  upon  the  level  of 
information available in a recent internal DG Mare information call. 

Information in support of the evaluation of enforcement strategies of measures of the Eel Regulation 
by the Member States has been obtained according to two main sources: 

• 

• 

Information  reported  by  Member  States  in  response  to  a  dedicated  control  questionnaire 
submitted by DG MARE under its own initiative in 2017 and 2018. The following Member States 
responded to DG MARE : DE, ES, FR, GR, IT, NL, PL, SE and UK. Some Member States (e.g. 
HR  and  PT)  did  not  respond  to  DG  MARE  questionnaire.  DG  MARE  shared  Member  States 
responses with the expert team. 

Information  reported  by  Member  States  in  response  to  a  dedicated  control  questionnaire 
prepared  by  the  expert  team.  In  view  of  the  above,  two  different  questionnaires  have  been 
prepared for Member States having submitted an EMP: a simplified questionnaire (Annex 4D) 
for those Member States who responded to the DG MARE questionnaire to avoid repetition of 
efforts,  and  a  full  questionnaire  (Annex  4C)  for  those  Member  States  who  have  not  been 
consulted by DG MARE or who did not respond to DG MARE. Both versions of the questionnaire 
are in Annex. Own questionnaires have been submitted to Member States authorities identified 
as focal points of DG MARE for CFP matters in early December 2018, with last replies received 
by the end of February 2019. 

At the time of writing of this evaluation, 11 Member States responded to our questionnaire, and 11 
did  not  respond.  Details  are  shown  in  the  table  overleaf.  Among  the  11  who  did  not  respond, 
information on control is nevertheless available from the questionnaire received by DG MARE (ES, NL 
and SI). Note that the 6 Member States that have been exempted from submitting an EMP have not 
been consulted.  

3.4.3 Collective Consultations 
Further  targeted,  face-to-face  and  telephone  interviews  have  been  held  with  relevant  stakeholder 
groups.  These  were  mainly  in  the  three  case  study  counties  (Denmark,  France  and  Italy)  but  also 
included other key stakeholders both within and outside the EU.  23 stakeholders were consulted and 
their  responses  used  to  fill  in  gaps  and  validate  the  evidence  from  the  desk  review  of  EMPs,  the 
progress reports and the specific consultations.    

June 2019 

12 

 
Table 2: Summary of responses from the control questionnaires 

Evaluation of the Eel Regulation 

Questionnaire 
received 

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

Exempted 
from EMP 

AT 
CY 
HU 
MT 
RO 
SK 

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

6 
Note : * denotes Member States having replied to DG MARE questionnaire in 2017 and 2018. 

11 

11 

A synthesis of the results of the public, roadmap, and other stakeholder consultations can 
be found in Annex 5. 

3.4.4 Case Studies 
Three country case studies were implemented to provide more detailed insight into the implementation 
of the Eel Regulation at national, regional and local levels. Case study work includes interviews (face-
to-face where possible) with a sample of representatives of administrations and professionals in three 
Member States.  The case studies covered the following three Member States:  

•  France: In 2016 France was the top producer of wild caught glass eels.  According to WG Eel 
(2017), eel aquaculture does not take place in France.  In 2016 France was the main EU nation 
restocking glass eels (11.5 million in 2016).   

•  Denmark: a major producer of commercially and recreationally caught eels in the EU. Also a 
major aquaculture producer, mainly employing indoor heated farming systems.  Glass eels for 
aquaculture are imported from France, Portugal and the UK.   

•  Italy: Eel (exploitation in Italy has a long-standing tradition, and is still important, despite a 
progressive and increased loss of interest towards this species. Commercial fisheries produced 
around  89  t  in  2016,  with  an  additional  36  t  from  recreational  fisheries.  The  intensive 
aquaculture of eel, which played a major role within the national and European context up to 
some years ago (over 1,200 t in 2004) is strongly reduced today (<500 t).   

The results of each case study have been written up in a concise self-standing report.  These highlight 
the key findings with regard to the real/expected impacts of national measures announced, adopted 
and/or  implemented  following  the  EMPs.  They  also  signal  any  significant  challenges  or  difficulties 
encountered by Member States and how these were / are being addressed and identify lessons learned 
that could be applied more widely.  

The three case studies can be found in Annex 7.   

 PHASE 4: ANALYSIS AND PRESENTATION  

During this final phase of the evaluation, we processed and analysed the data collected in the previous 
phases to synthesise and triangulate them to answer the evaluation questions posed in the Evaluation 
Question Matrix . Based on the answers, we drafted the overarching conclusions and recommendations 
covering  both  the  progress  in  improving  European  eel  stocks  as  well  as  related  issues  such  as 
increasing eel trade transparency and traceability and the successes or otherwise in controlling the 
trade of glass and other eel life stages through the supply chain. 

June 2019 

13 

 
 
 
 
 
 
 
 
 
 
4.0 CURRENT SITUATION OF MEASURES FOR THE RECOVERY OF 
THE EUROPEAN EEL STOCK UNDER THE EEL REGULATION 

Evaluation of the Eel Regulation 

 OVERVIEW OF MEASURES FOR THE RECOVERY OF EUROPEAN 

EEL IN THE EEL MANAGEMENT PLANS 

4.1.1 Introduction 
A management framework for eel within the EU was established in 2007 through the Eel Regulation 
(EU, 2007). The objective of the regulation is the protection and recovery of the European eel stock.  
To achieve the objective, EU Member States were required to develop Eel Management Plans (EMPs) 
for their river basin districts, designed to reduce eel mortality.  The EMPs set out various management 
measures  aimed  at  supporting  achievement  of  the  objective.    In  addition  to  the  original  EMPs,  EU 
Member States have also been required to produce progress reports in 2012, 2015 and 2018, which 
describe the extent to which management measures have been implemented. 

The original EMPs and associated progress reports have been subject to prior detailed analysis, led 
primarily by ICES, whose various working groups have evaluated both the conformity of the national 
EMPs with the Eel Regulation (ICES, 2009, 2010a) and progress in implementing EMP management 
measures  (ICES,  2013a,  2013c,  2018c).    Evaluations  of  conformity  with  the  Eel  Regulation  have 
proved  challenging for  a number  of reasons.   In 2012  many  EU Member States 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.  In 2015, EU Member States post-evaluated the implementation of their EMPs and provided 
estimates of national stock indicators. The information in the 2015 Progress Reports was not always 
complete, and the quality of the national data and assessment were difficult to evaluate (ICES, 2016). 
The 2018 progress reports (and a data call initiated by WGEEL)have been evaluated, (ICES, 2018d) 
though  significant  complexities  are  involved,  for  example  as  a  result  of  the  continued  lack  of 
standardisation in  approaches  being  taken  by  Member  States  to  modelling  and  calculation  of  stock 
indicators. 

An overview of the targets and management measures set out in EMPs and the extent to which they 
are known to have been implemented is presented below.  This overview does not attempt to duplicate 
the extensive analysis already undertaken and presented in the referenced ICES reports. 

4.1.2 EMP Coverage 
To inform the evaluation of the Eel Regulation, EMPs from 19 Member States have been reviewed, in 
addition  to  the  three  tri-annual  progress  reports  prepared  by  each  Member  State.    Some  Member 
States have prepared multiple EMPs to cover individual Eel Management Units, which typically relate 
to River Basin Districts as defined under the Water Framework Directive, resulting in the preparation 
of over 60 EMPs across the 19 Member States, including one transboundary EMP.  

EMPs variously consider freshwater, transitional, coastal and open marine waters.  There exists limited 
evidence  of  transboundary  cooperation  in  the  development  of  EMPs,  despite  water  bodies  often 
crossing the territory of multiple Member States.   

In many cases, multiple parties (managing authorities, state agencies and academic advisors) have 
been  involved  in  the  development  and  implementation  of  EMPs,  reflecting  their  wide  geographical 
coverage,  the  need  to  consider  both  marine  and  freshwater  environments,  and  the  broad  scope  of 
proposed management measures. 

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Evaluation of the Eel Regulation 

4.1.3 EMP Targets 
In line with the requirements of the Eel Regulation, all EMPs should aim to achieve 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.  Via the EMPs 
and Progress Reports, each Member State is required to: 

1  Set management targets based on an assessment of potential silver eel production under 

conditions of no anthropogenic mortality and high levels of recruitment.    

2  Estimate the present-day silver eel production in relation to this target (i.e. estimate 

compliance with the management target).   

3  Develop and take the management actions that are necessary to achieve or maintain 

compliance.   

4  Collect data sufficient to support steps 1 to 3 above, and to demonstrate whether compliance 

will be achieved in the future, i.e. that the actions identified in the EMP will lead to the 
recovery of the eel population. 

Whilst  all  EMPs  share  a  common  target,  the  approach  to  achievement  of  that  target  varies  across 
Member States.  Section 3.1.1.4 below summarises the key management measures that have been 
proposed across all EMPs.  As discussed later in this evaluation, there is no timeline for achieving the 
objectives of the Regulation, nor are any interim targets established.   

4.1.4 EMP Management Measures 
During  the  creation  of  the  Eel  Regulation  in  2007  the  Council  of  the  European Union  noted  that  in 
relation to eel there are diverse conditions and needs throughout the Community which will require 
different  specific  solutions.  That  diversity  was  to  be  reflected  in  the  planning  and  execution  of 
management  measures  to  ensure  protection  and  sustainable  use  of  the  eel  population.  In  order  to 
ensure that their eel recovery measures were effective and equitable, it was necessary that Member 
States identified the measures they intended to take and the areas to be covered within their EMPs. 

The Eel Regulation states that an EMP may contain, but is not limited to, the following measures: 

•  Reducing commercial fishing activity. 
•  Restricting recreational fishing. 
•  Restocking measures. 
•  Structural measures to make rivers passable and improve river habitats, together with other 

environmental measures. 

•  Transportation of silver eel from inland waters to waters from which they can escape freely to 

the Sargasso Sea. 
•  Combating predators. 

•  Measures related to aquaculture. 

In the ICES evaluation of the 2012 progress reports (ICES, 2013a), it was noted that a total of 1,362 
individual  management  actions  were  reported  from  the  81  Eel  Management  Units  established  by 
Member  States.    Since  listing  of  these  individually  was  not  practical,  management  measures  were 
classified  into  categories  and  it  was  found  that  those  aimed  at  control  of  commercial  and/or 
recreational  fisheries  were  the  most  commonly  adopted,  with  slightly  fewer  measures  addressing 
hydropower and  obstacles to  eel movements, and fewer  still implementing habitat improvement or 
stocking  measures  (see  Figure  5  overleaf).    EMP  Progress  Reports  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.  

June 2019 

15 

 
 
Figure 5: Proportion of management measures by category 

Evaluation of the Eel Regulation 

Source: ICES (2014a).  Note: management of predators was not considered in ICES 2014, as their 
evaluation related only to management of anthropogenic impacts) 

Commercial fishing: a variety of measures are proposed in EMPs to reduce the impact of commercial 
fishing on the eel stock.  They are typically focused on reducing fishing effort (ranging from prohibition 
of certain gears in specific areas through to total bans on commercial eel fisheries) and introducing or 
extending closed seasons.  Measures are also aimed at improving fishery administration systems (e.g. 
implementing national catch registers). 

Recreational  fishing:  A  variety  of  measures  are  proposed  in  EMPs  to  reduce  the  impact  of 
recreational fishing on the eel stock.  Management measures 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  aim  to  mitigate 
against  the  effects  of  physical  obstacles  to  migration  in  water  courses.    Measures  are  focused  on 
removal of barriers, or the installation of eel pass structures.  In some cases, management measures 
involve trapping of silver eels upstream of obstacles and releasing them downstream of the obstacle. 

Habitat improvement: Management measures relating to habitat improvement are harder to define.  
Measures include increasing habitat connectivity, improving water quality, and establishing protected 
areas. 

Restocking: Restocking is a management measure that features in the majority of EMPs.  Concerns 
about the effects of eel stocking practices (e.g. spread of disease, illegal trade) and its effectiveness 
in contributing to increased silver eel production have been raised.  ICES reviews of restocking as a 
management  measure  (ICES  2010b  and  2013c)  concluded  that  there  is  evidence  that  translocated 
and stocked eel can contribute to yellow and silver eel production in recipient waters, but that evidence 
of further contribution to actual spawning and the overall biomass increase of the stock is limited. 

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 
and illegal fishery 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. 

June 2019 

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Evaluation of the Eel Regulation 

4.1.5 Implementation of EMP Targets and Management 
Measures 

Table  3  on  page  19  provides  a  summary  of  the  high-level  review  of  EMPs  and  Progress  Reports 
undertaken to inform the evaluation of the Eel Regulation.  Analysis of 2012 and 2015 Progress Reports 
by ICES reported mixed results in terms of progress towards EMP targets; of 59 Eel Management Units 
analysed, 29 reported a rise in silver eel escapement and 30 reported a decline (ICES, 2016a).  The 
review undertaken to inform this report has found that five Member States report full or partial (i.e. 
within some, but not all, Eel Management Units) achievement of the 40% escapement target, though 
in some cases there is significant uncertainty associated with escapement calculations.  The remaining 
14  Member  States  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.  Only in some cases 
do Progress Reports analyse the causes of failure to achieve the Eel Regulation target; where they do, 
they identify the need for higher levels of inter-agency cooperation at Member State level to implement 
management  measures,  a  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 doesn’t necessarily equate to increased spawning), and a lack 
of funding to implement management measures. 

The extent to which management measures as detailed in EMPs have been implemented has also been 
previously analysed (see Figure 6 below).  Analysis by ICES of the 2012 Progress Reports found that 
1,188  management  actions  were  documented;  1,140  of  these  measures  had  been  planned  in  the 
original EMPs and the remaining 48 were new, additional measures.  It was further noted that of the 
actions planned in the EMPs, 756 were implemented fully, 259 partially and 107 were not implemented 
at all.  Information for the remaining 18 measures was missing (ICES, 2013c).  Further analysis in 
2014  by  ICES  gave  an  updated  view  of  the  implementation  of  eel  management  measures  (ICES, 
2014); in this case a total of 1,362 individual measures were identified.  Overall, the 2013 and 2014 
reports found that about two-thirds of the planned measures were  related to fisheries (commercial 
and  recreational),  improved  passage  at  hydropower  installations  and  other  obstacles  and  habitat 
improvement in general.   

The  most  recent  information  on  measures  implemented  for  eel  can  be  found  in  Country  Reports 
provided to the ICES Working Group on Eel in 2018 (ICES, 2018e). According to these reports, there 
are  no  major  changes  in  management  practices  for  eel  throughout  Europe  in  the  recent  years.    In 
2018, ICES organized a new workshop (WKEMP) for the review of the 2018 Progress Reports. This 
workshop  focused  on  the  methods  and  results  for  biomass  and  mortality  estimates  in  single  Eel 
Management  Units  and  discussed  reporting  requirements  for  international  stock  assessment.  The 
effects and effectiveness of management measures were not evaluated (Hanel, 2019), and the way 
in  which  Progress  Reports  presented  information  on  management  measures  does  not  enable  the 
extent of their implementation against targets to be analysed.  Figure 6 overleaf provides information 
on the implementation of management measures in each Member State. 

The extent to which management measures as detailed in EMPs have been implemented has also been 
previously analysed (see Figure 6 below).  There exists disparity amongst Member States regarding 
the  extent  to  which  management  measures  have  been  implemented;  some  have  implemented 
measures according to their stated schedule whilst others have lagged behind.  Despite a significant 
proportion  of  measures  being  fully  implemented,  there  is  no  evidence  to  suggest  that  these  have 
enabled significant progress towards the escapement target. 

As  indicated  earlier  in  this  report,  previous  evaluations  of  EMPs  and  Progress  Reports  have 
encountered difficulties in analyses due to incomplete national datasets, queries over the quality of 
national  data  and  assessments,  and  the  differing  approaches  taken  across  Member  States  to 
measuring  stock  indicators.    This  suggests  that  both  comparative  analyses  of  progress  across  the 
Member States, as well as a cumulative analysis for the entire EU, is currently not achievable.   

June 2019 

17 

 
 
 
Figure 6: Evaluation of implementation of management measures in EMPs, as reported in 
2012 progress reports, summarised by category 

Evaluation of the Eel Regulation 

Source: Reproduced from ICES, 2018d 

4.1.6 Summary 
Whilst the EMPs and progress reports indicate that substantial effort has been made by EU Member 
States to develop and implement (to varying degrees) management measures, the extent to which 
these measures are positively (directly or indirectly) impacting eel status has not been demonstrated, 
though it is recognised that any significant signs of recovery will take 2-3 eel generations (i.e. at least 
10-20 years depending on the region) to emerge.  ICES advice has remained unchanged since 1999 
and  reads  ‘all  anthropogenic  impacts  (e.g.  recreational  and  commercial  fishing  on  all  stages, 
hydropower, pumping stations, and pollution) that decrease the production and escapement of silver 
eels should be reduced to - or kept as close to - zero as possible’ and the ‘status of eel remains critical’ 
(ICES, 2018a).   

June 2019 

18 

 
Table 3: Scope and availability of Member State EMPs and Progress Reports 

Evaluation of the Eel Regulation 

EMP Scope 

f
o
r
e
b
m
u
N

s
P
M
E

n
u
o
b
s
n
a
r
T

y
r
a
d

i
t
a
r
e
d
i
s
n
o
C

s
n
o

Member 
State 

l
e
E

e
m
e
g
a
n
a
M

s
t
i
n
U
t
n

)
.
o
N
(

Belgium 

Scheldt, Meuse (2) 

Czech 
Republic 
Germany 

Odra, Labe (2) 

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

1 

1 

9 

Denmark  Denmark inland (1) 

1 

Estonia 

Narva River, West 
Estonia (2) 

1 

Spain 

1 national 
EMP and 
12 specific 
EMPs 

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

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. 

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

Availability of EMPs and 
Progress Reports 

s
s
e
r
g
o
r
P
t
s
1

Y 

Y 

Y 

t
r
o
p
e
R

)
2
1
0
2
(

s
s
e
r
g
o
r
P
d
n
2

t
r
o
p
e
R

)
5
1
0
2
(

s
s
e
r
g
o
r
P
d
r
3

t
r
o
p
e
R

)
8
1
0
2
(

Y 

N 

Y 

N (tables only) 

Y (no data 
tables) 
Y 

t
a
t
i
b
a
H

e
g
a
r
e
v
o
C

P
M
E

Freshwater  Y 

Freshwater  Y 

Y 

Freshwater 
Transitiona
l 
Coastal 

Y 

Y 

Y 

Y 

Not 
confirmed 

Y 

Y 

N 

Y 

Y 

Y 

N 

Y 

Not 
confirmed 
Freshwater 
Transitiona
l 
Coastal 

Freshwater 
Transitiona
l 

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) 

June 2019 

19 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

Availability of EMPs and 
Progress Reports 

P
M
E

s
s
e
r
g
o
r
P
t
s
1

t
r
o
p
e
R

)
2
1
0
2
(

s
s
e
r
g
o
r
P
d
n
2

t
r
o
p
e
R

)
5
1
0
2
(

Y 

Y 

Y 

Y 

s
s
e
r
g
o
r
P
d
r
3

t
r
o
p
e
R

)
8
1
0
2
(

t
a
t
i
b
a
H

e
g
a
r
e
v
o
C

Freshwater 
Transitiona
l 

Y 

Y 

Y 

Y 

Y 

N 

Y 

N 

Not 
confirmed 

Y 

Freshwater 
Transitiona
l 
Coastal 
Freshwater  Y 

Y 

N 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

Y 

N 

EMP Scope 

f
o
r
e
b
m
u
N

s
P
M
E

n
u
o
b
s
n
a
r
T

y
r
a
d

i
t
a
r
e
d
i
s
n
o
C

s
n
o

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

1 

1 

1 

1 

2 (one 
national 
EMP and 
one 
transbound
ary EMP) 

The Minho 
International 
River Plan was 
developed 
with Spain. 

1 

14 

Y 

Y 

Y 

N (tables only) 

Y 

Y 

Y 

Y 

Transitiona
l 
Coastal 
Open 
Marine 
Freshwater
, 
Transitiona
lCoastal 

Member 
State 

l
e
E

e
m
e
g
a
n
a
M

s
t
i
n
U
t
n

)
.
o
N
(

Italy 

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

Lithuania 

Lithuania (1) 

Luxembo
urg 

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) 

Source:  Consultant review of EMPs and Progress Reports

June 2019 

20 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 4: Member State Progress in implementing their EMPs 

Evaluation of the Eel Regulation 

Member 
State 

Belgium 

Czech 
Republic 

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 

Germany 

(Note 
management 
measures 

Commercial and 
recreational 
fisheries Closed 
season 

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. 

Variable; yes 
within some 
EMUs, no within 
others. 

June 2019 

21 

 
 
 
Member 
State 

Management 
Measures 
Overview  

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

Commercial and 
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  

Denmark 

Achievement 
of 
escapement 
target? 

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

Evaluation of the Eel Regulation 

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

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

June 2019 

22 

 
Evaluation of the Eel Regulation 

Member 
State 

Management 
Measures 
Overview  

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

Estonia 

Spain 

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

Finland 

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 

France 

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

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

Commercial 
fisheries: 
Closed seasons 

Greece 

Recreational 
fisheries: 
Fishing ban  

Restocking 

Commercial 
fisheries: 
Prohibition of 
fyke nets in 
lagoons 

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. 

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. 

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. 

June 2019 

23 

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 

Not clear 

Not clear; likely 
to be below 
target 

Not clear 

 
 
 
 
 
 
Evaluation of the Eel Regulation 

Member 
State 

Management 
Measures 
Overview  

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

Achievement 
of 
escapement 
target? 

Commercial 
fisheries: 
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 

Fishing of small eel below 30 centimetres, for commercial 
exploitation, is banned throughout the country 

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. 

Ireland 

Italy 

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

Lithuania 

June 2019 

24 

Yes, in all but one 
EMU. 

No 
(anthropogenic 
mortality target 
achieved in some 
EMUs, but not 
escapement 
target). 

Reduced fishing 
effort. 

No 

 
 
 
Member 
State 

Management 
Measures 
Overview  

Recreational 
fisheries: Quota 

Removing 
migration 
barriers 
Predator control 
by reduction in 
cormorant 

Restocking 

Luxembourg  Removal of 

Latvia 

Netherlands 

Poland 

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 
Recreational 
fisheries: Daily 
catch limits 

Evaluation of the Eel Regulation 

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? 

No evidence of implementation 

No evidence of implementation 

No 

No 

No 

No 

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 

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. 

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. 

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. 

2018 Progress Report provides evidence of implementation 
annually since 2010, with limit of 2 specimens per day 9from 4 
previously). 

June 2019 

25 

 
 
Member 
State 

Portugal 

Sweden 

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

United 
Kingdom 

Management 
Measures 
Overview  

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 

Commercial 
fisheries: 
Fishery ban / 
quota 

Evaluation of the Eel Regulation 

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

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. 

Achievement 
of 
escapement 
target? 

No evidence of implementation 

No restocking data provided in 2018 Progress Report, though 
2016/17 Country Reports indicate restocking in 2010.   

No 2018 Progress Report available; 2016/17 Country Report 
suggests implemented. 

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 fully implemented in marine waters and partially 
implemented in freshwater. 

No 2018 Progress Report available; 2016/17 Country Report 
suggests partially implemented. 

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. 

2018 Progress Report provides evidence of implementation, with 
effective eel fishery bans or zero quota measures in place in some 
EMUs. 

No 

Variable; yes 
within some 
EMUs, no within 
others. 

June 2019 

26 

 
 
 
Achievement 
of 
escapement 
target? 

Member 
State 

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

Management 
Measures 
Overview  

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  

Evaluation of the Eel Regulation 

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

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). 

June 2019 

27 

 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

 SOME GOOD PRACTISES IN EEL CONSERVATION 

MANAGEMENT  

There have been a number of successes and examples of best practise as a direct result of the Eel 
Regulation. 

4.2.1 Fisheries 

1.  In Italy the development of multi-stakeholder platforms in the preparation of regional 
EMPs is considered a particular success. The process involved all relevant operators, including 
fishers, vallicoltura18 farmers and aquaculture operators and 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). 

1.  In the UK a series of best practice guidance has been produced, 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). 
from 
recommendations  made  at  a  workshop  of  experienced  practitioners,  bringing  together 
expertise, shared practical experiences and lessons that have been learnt so far. The Spanish 
have  also  produced  a  guidance  manual  around  five  thematic  lines  (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)  

  This  document  was  developed 

2.  Granting  restocking  financial  support  through  a  State  Aid  scheme  rather  than 
through EMFF : 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 Commission’s rules. 
These measures contributed to improve implementation of eel stock enhancement measures 
by professional organisations. 

4.2.2 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  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.  Italy 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 (see Italy Case Study in Annexes).  In Italy, 
attempts to focus restocking efforts into protected waters, often using glass eels from the same 
watershed, to increase potential spawner numbers.  

2.  In France Agence Française de la Biodiversité (eaufrance) have 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. 

18 Traditional rearing, usually of wild stocked juveniles, in lagoons, mainly in Italy 

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Evaluation of the Eel Regulation 

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 
supported  implementation  of  the  measure,  which  from  operators  perspective,  must  be 
implemented  only  when  necessary  due  to  the  high  associated  foregone  revenues.  Similar 
models are yet to be developed or refined for other EMUs. 

4.2.3 Traceability and control 

4.  Improved  batch  traceability  in  Greece  has  been  achieved  through  their  ‘simple 
permitting  scheme’.    Α  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, imports / 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. 

5.  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.    

 OVERLAP AND CONFLICT IN MS MEASURES 

No major overlaps or conflicts exist between  measures  established under the Regulation and other 
conservation measures being implemented by Member States.  This said, some issues were raised by 
stakeholders as follows: 

•  Some  researchers  argue  that  the  translocation  and  restocking  of  eels  is  expensive  and  its 
effectiveness unproven, especially when into receiving waters where spawner escapement has 
been restricted (see JC 5.1 in Section 5.3).  One possible conflict is risks of translocation 
from diseases (2 of 4 glass eel batches from France to Sweden in 2017 destroyed due to the 
presence of a virus) and parasites (Pawson, 2012).  Although panmictic in nature, there may 
also be genetic implications of stocking across watersheds, although ICES has previously (ICES, 
2007)  recommended  that  eels  should  not  be  translocated  between  river  basins  for  stocking 
purposes or, if seen as indispensable to avoid an imminent collapse of specific river stocks, any 
stocking should be done within geographically proximate areas e.g. within the Mediterranean 
basin, the North Sea region, or the Baltic Sea.  In this context, there appears to have been no 
formal risk assessment carried out for stocking with eels, which should attempt to balance any 
potential  detrimental  effects  (disease  or  parasite  transmission,  genetic  disruption,  chemical 
contamination,  behavioural  traits  and  skewed  population  dynamics,  of  native  and  cultured 
stock fish) against the benefits of stocking in relation to the objectives of the Eel Regulation 
(Pawson, 2012). 

•  A  number  of  environmental  NGOs  commented  on  the  contradiction  of  a  Regulation  that 
supports  the  continued  fishing  of  a  critically  endangered  species 19.    They  quote  the 
current  ICES  advice  that  “when  the  precautionary  approach  is  applied  for  European  eel,  all 

19 IUCN ‘Red List’ rating – see Jacoby, D. & Gollock, M. (2014)  

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Evaluation of the Eel Regulation 

anthropogenic  impacts  (e.g.  caused  by  recreational  and  commercial  fishing  on  all  stages, 
hydropower,  pumping  stations,  and  pollution)  that  decrease  production  and  escapement  of 
silver eels should be reduced to – or kept as close to – zero as possible in 2019” (ICES, 2018a).  
The Common Fisheries Policy (CFP) does support the preservation of traditional fisheries such 
as those for European eel, esp. in coastal or inland waters (European Parliament & the Council 
of  the  European  Union,  2013).      A  critical  review  of  the  Swedish  EMP  in  2012  (Svedäng  & 
Gipperth,  2012)  suggested  that  ‘the  conflict  between  the  objectives  of  species  and  fishery 
preservation  has  not  been  clarified  nor  is  the  prioritisation  clear’  and  that  ‘management  is 
therefore directed towards mitigating the negative effects of fishing and other human activities 
rather than realising the conservation objective’. 

•  The exclusion of EU operators from access to the lucrative Asia market which pays as much as 
EUR  3,000  EUR  /  kg  for  live  glass  eels  has  triggered  increased  interest  from  illegal 
organisations that catch glass eel in the wild, keep them alive and smuggle them out of the 
EU by plane. Although efforts to combat this illegal trade have intensified in recent years, its 
level remains sufficiently high and of concern to involve high-level trans-national cooperation 
through EUROPOL. 

 INSPECTION AND CONTROL ACTIVITIES ON EEL FISHING 

AND AQUACULTURE ACROSS THE EU 

4.4.1 The EU legal background for control and enforcement of 
eel measures 

Activities covered by the Common Fisheries Policy (i.e. fishing, aquaculture and marketing 
of eels) 

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 20 ,  the  IUU  Regulation 21 ,  the  EFCA  Founding  Regulation 22  and  the  SMEF 
Regulation23 for activities of the EU external fleet.  

The Control Regulation is the main piece of EU legislation applicable in the case of the eel fisheries. 
The Control Regulation applies primarily to activities covered by the CFP carried out on the territory 
of Member States 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.  

For  access  to  the  resource,  the  Control  Regulation  mandates  fishing  vessels  to  hold  valid  licences 
delivered by their Member States to engage in commercial fishing (in marine waters). When applicable, 
fishing  vessels  must  also  have  fishing  authorisations  to  carry  out  specific  activities  concerned. 
However, fishing vessels of less than 10 m fishing in territorial waters may be exempted from fishing 

20 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, 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. OJ L 343, 22.12.2009, p. 1–50 
21 Council Regulation (EC) No 1005/2008 of 29 September 2008 establishing a Community system 
to prevent, deter and eliminate illegal, unreported and unregulated fishing, amending Regulations 
(EEC) No 2847/93, (EC) No 1936/2001 and (EC) No 601/2004 and repealing Regulations (EC) No 
1093/94 and (EC) No 1447/1999. OJ L 286, 29.10.2008, p. 1–32 
22 Council Regulation (EC) No 768/2005 of 26 April 2005 establishing a Community Fisheries Control 
Agency and amending Regulation (EEC) No 2847/93 establishing a control system applicable to the 
common fisheries policy. OJ L 128, 21.5.2005, p. 1–14 
23 Regulation (EU) 2017/2403 of the European Parliament and of the Council of 12 December 2017 
on the sustainable management of external fishing fleets, and repealing Council Regulation (EC) No 
1006/2008. OJ L 347, 28.12.2017, p. 81–104 

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Evaluation of the Eel Regulation 

authorisation  schemes 24 .  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  Art.  11  of  the  Eel  Regulation  which  requires  Member 
States 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 MS 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 Regulation (Art. 10 of the Eel 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 mandates Member 
States 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, Art. 11 of the Eel Regulation includes requirements for Member 
States  to  establish  on  a  regular  basis  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. However, according to the Control Regulation, vessels of less than 
10  m  can  be  exempted  from  these  obligations.  Sales  notes  and  take-over  declarations  must  be 
submitted electronically for buyers with annual turnover of more than 200,000 EUR. In the event eels 
are transported before first sale more than 20 km away from landing site, a transport document is 
required. The transport document must be submitted by the transporter on paper no later than 48h 
after loading. 

Note that 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.  

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 
Member  States  with  the  EFCA  assuring  operational  coordination  of  joint inspection  activities  in  this 
frame.  SCIPs  ensure  that  target  benchmarks  for  inspection  established  on  the  basis  of  risk-
assessments are met. 

24 Commission Implementing Regulation (EU) No 404/2011 of 8 April 2011 laying down detailed rules 
for the implementation of Council Regulation (EC) No 1224/2009 establishing a Community control 
system for ensuring compliance with the rules of the Common Fisheries Policy. OJ L 112, 30.4.2011, 
p. 1–153 

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The CITES Regulation and external trade of eels 

Evaluation of the Eel Regulation 

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

Eels are in Annex B of Council Regulation (EC) N°338/97. A zero-quota applied since 2010 until now, 
meaning  that  import  and  export  of  eels  is  prohibited  (see  Section  2.2.4).  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. Member States 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 EU Member States 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. 

However, Council Regulation (EC) N°338/97 provides in its Article 8.5 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. This could be interpreted as  a 
requirement for operators to prove to the satisfaction of MS competent authorities that eels have been 
obtained in compliance with all conservation applicable rules, rules enacted by the Eel Regulation and 
by the CFP Regulation. 

In the event import / export of eels was authorised (which was not the case up until now), the catch 
certification scheme implemented by the IUU Regulation would have applied only for eels caught in 
marine waters (see DG MARE information note for anadromous species 25), and not for eels caught in 
freshwaters. Concerning eels from aquaculture farms, lots subject to external trade would be subject 
to a catch certificate only for products gained from (glass or yellow) eels caught in marine waters.  

Eel stock enhancement through restocking 

The single EU obligation stems from Art. 7.3 of the Eel Regulation that prescribes that Member States 
must  establish  an  appropriate  reporting  system  to  ensure  that  the  60%  glass  eels  reserved  for 
restocking  are  used  for  this  purpose.  Arguably,  Member  States  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). For glass  eels  caught in its territory but 
used  for  restocking  in  another  Member  State,  the  monitoring  system  implemented  by  the  Member 
State at the origin of the glass eel catch can only cover the lots up to the borders, but not beyond. 

4.4.2 Control and enforcement of eel conservation measures in 
the Member States 

Main risks identified 

Most  Member  States  consulted  indicated  that  eel  fisheries  have  been  subject  to  a  risk-assessment 
analysis to identify priorities. For BE, DE, DK, LV NL, PL, SE and UK, the main risk identified is the use 
of illegal traps in freshwater bodies (rivers and lakes) by unregistered fishermen to catch yellow and 
silver  eels.  For  ES  and  FR,  the  main  risk  is  catches  of  glass  eels  in  river  mouths  by  unregistered 
fishermen, and subsequent export to Asia. SE mentioned risks stemming from illegal trade of glass 
eels in the aquaculture sector and misreporting of eel catches by professional fishermen. From the GR 
perspective where there are virtually no eel fisheries, the main risks stem from non-compliance with 
national rules concerning restocking26. 

Monitoring of eel fisheries 

All Member States consulted have a registration system of professional fishermen and eel buyers for 
catches in marine waters or freshwater as considered by Article 10 of the Eel Regulation. Concerning 
registration  of  recreational  fishermen,  only  DK,  FR  and  UK  reported  having implemented  a  specific 
registration scheme for recreational fishermen targeting eels. In FR, the licencing scheme apply only 
to recreational fishermen using fishing gears other than rod and line (e.g. traps, nets). In the other 
Member States where recreational fishing for eel is allowed (BE, DE, FR, LT and PL), there is no specific 

25 https://ec.europa.eu/fisheries/sites/fisheries/files/docs/body/pacific_salmon_en.pdf  
26 In  GR,  intensive  aquaculture  producers  must  give  10%  of  glass  eels  they  buy,  and  extensive 
aquaculture producers 30% of eels they harvest for restocking without a financial compensation. 

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Evaluation of the Eel Regulation 

registration systems. Recreational fishermen may need a licence, but the licence is not specific for eel 
fishing. 

Catch  declarations  by  professional  fishermen  (for  both  marine  and  fresh  water  environments)  are 
mandatory  as  foreseen  by  Article  10  of  the  Eel  Regulation.  All  details  have  not  been  provided  but 
professional fishermen usually have to submit catch declaration on a weekly (NL), monthly (SE, FR 
for yellow and silver eels) or annual basis (UK). In the case of FR, glass eel catches have to be reported 
every two days for any catch of more than 100 g. From information obtained, catches are submitted 
electronically  only  in  NL  and  in  DK,  with  in  this  later  case,  sales  notes  submitted  electronically  by 
buyers  replacing  catch  declarations.  In  the  case  of  FR,  fishermen  unilaterally  implemented  an 
electronic catch declaration system to support monitoring of quota uptake, but the system does not 
have a legal basis with paper declarations still mandated. 

Concerning  catch  declarations  by  recreational  fishermen,  only  FR  reported  having  mandated  a 
declaration  system  based  on  paper  forms.  In  DK  and  NL,  there  is  no  catch  declaration  system 
implemented, but recreational catches are estimated on a biennial basis through specific surveys using 
in the case of DK internet surveys of registered recreational fishermen. Note that for several member 
states, recreational fishing for eels is either prohibited (e.g. GR, LT, SE) or limited to catch and release 
game fishing (BE, UK), meaning that catch declarations are irrelevant. 

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. 

Eel traceability 

According  to  Member  States  consulted,  full  traceability  of  eels  is  not  readily  available.  The  paper-
based traceability system enforced by the Control Regulation (Article 58) that concern eel caught in 
marine waters (eels caught or farmed in freshwater are not excluded from the scope of the Control 
Regulation) is not yet fully implemented by most Member States as established by the Commission 
own  evaluation  of  the  EU  Control  System 27.  According  to  MS  feedback  from  our  survey,  DK  has 
implemented a “net to plate” electronic traceability system (the SIF solution) but limited to marine 
species.  SE  reported  implementing  a  national  electronic  traceability  system  as  from  this  year,  with 
reflexions  to  extend  it  to  freshwater  products  in  a  near  future.  ES  was  expected  to  implement  the 
TRAZAPES solution as from 2018, but it is unclear whether this has been done according to plans. All 
other Member States acknowledged that there is no real full traceability system implemented as yet, 
with operators only having to show evidences of the immediate supplier and of the immediate buyer 
(one up - one down) based on available documentation, as also provided for by the EU Food Law28. 

Traceability  is  particularly  an  issue  for  live  glass  eels  traded  between  Member  States  to  supply 
aquaculture farms, for direct consumption or for restocking operations. According to the EU Control 
Regulation, live glass eel shipments not sold upon landing may be transported from a Member State 
to another with the transport document provided for under Art. 68 of the EU Control Regulation (or 
its equivalent), in addition to other obligatory documents (invoices, health certificate). As detailed in 
a  previous  section,  transport  documents  are  established  under  the  responsibility  of  the  transporter 
and must be submitted on paper no later than 48 hours after the load to competent authorities of the 
Member State of landing with copy to the competent authority of the Member State in whose territory 
the  first  marketing is  declared  to  take  place.  Arguably,  Member  State  authorities  inspecting  lorries 
may  encounter  difficulties  to  ascertain  the  validity  of  the  document  presented  in  case  of  control. 

27 Report  from  the  Commission  to  the  European  Parliament  and  the  Council  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. COM/2017/0192 final 
28 Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 
laying  down  the  general  principles  and  requirements  of  food  law,  establishing  the  European  Food 
Safety Authority and laying down procedures in matters of food safety. OJ L 31, 1.2.2002, p. 1–24 

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Additionally, the transport document is insufficient to establish within a reasonable delay if the catches 
have been obtained in compliance with applicable conservation measures. 

IT  and  PL  reported  relying  also  on  TRACES  documentation  to  verify  the  legality  of  the  shipments. 
However, TRACES is designed to exchange information on health certificates, and cannot be used to 
ascertain the legality of the catches. This is precisely why the catch certification scheme of the IUU 
regulation has been implemented in parallel to TRACES. 

Some Member States indicated relying (or having relied) on CITES rules for controlling the legality of 
eels  transported  to  another  Member  States.  GR  reports  having  implement  a  CITES  based  ‘simple 
permit’  scheme  probably  based  on  Article  8.5  of  Council  Regulation  (EC)  N°338/97  by  which  any 
transport in and out the  Greek territory is subject to verification of the legality of the shipment by 
relevant managing authorities of the CITES convention. While it can be understood that Greece has 
competence and tools to verify the legality of eels produced in the Member State (basically only from 
aquaculture), how legality of eels introduced in Greece is verified is unclear 29. IT and SE also use this 
legal  basis  to  force  economic  operators  detaining  live  eels  to  keep  a  CITES  registry  with  details  of 
purchases and sales, but like for GR, it remains unclear how legality of catches originating in another 
Member States can be verified. Additional information provided by IT suggest that in this case, CITES 
management authority require that eels have been legally acquired through submission of an invoice 
identifying the supplier and the health certificate.  

FR reported having used EU Internal Trade Certificates (ITC) during the 2009-2010 fishing season on 
the basis of Art. 5.2 of Reg (EC) 338/97 when it could be envisaged that glass eels caught in FR could 
be  exported  from  another  Member  State 30.  Although  a  zero-quota  was  enforced  end  of  2010,  FR 
maintained the ITC scheme during the two next fishing seasons (2010-2011 and 2011-2012) as France 
was hoping the reopening of an export quota for eels. When it became clear that the export quota 
would not be reopened in a foreseeable future, FR abandoned the ITC scheme on the ground that it 
had not legal utility, and also because the ITC scheme proved to generate an administrative burden 
perceived as disproportionate for the authorities in charge31. 

In the UK, eel fishermen in Northern Ireland obtained a Protected Geographical Indication (PGI) label 
for yellow and silver eels caught in Lough Neagh ecosystem. The Lough Neagh PGI scheme includes 
full traceability of eels along the supply chain among other measures. The PGI is underpinned by the 
high ecological quality of the environment and the desire of the local community to valorise a cultural 
heritage. The Sustainable Eel Group (SEG) endeavours to implement a European glass eel traceability 
system based on certification of responsible operators. However, the SEG certification scheme is on a 
voluntary  basis,  with  for  example  no  ES  operators  certified  so  far.  In  addition,  SEG  warns  that 
certification  to  SEG  standards  does  not  necessarily  mean  that  100%  of  the  eel  stocks  traded  by 
certified operators is of legal origin. 

Surveillance and control activities 

All Member States consulted reported that eel control measures fall under the responsibility of different 
Ministries  with  typically  a  Ministry  responsible  for  exploitation  of  eels  during  their  marine  phase, 
aquaculture  and  sanitary  certification  of  products  (e.g.  Ministry  responsible  for  agriculture  and 
fisheries),  a  Ministry  responsible  for  exploitation  of  eels  during  their  fresh  water  and  for  CITES 
implementation  (e.g.  Ministry  responsible  for  environment)  and  a  Ministry  responsible  for  finances 
(i.e. customs). Within Ministries, responsibilities may be allocated to different technical Directorates. 
Surveillance  activities  also  fall  under  the  mandate  of  police  and  military  forces.  All  Member  States 
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 (OCLASEP – 
Office Central de Lutte contre l’Environnement et la Santé Publique) under Gendarmerie coordination 

-29 Greece was asked precisions in this respect, but did not reply as yet. 
30 As the Member State authorities where export take place could not verify the legality of catches by 
themselves to authorise exports, the FR-issued ITC provided them with the relevant information 
31 According to the FR CITES authority, management of ITC entailed 5 agents full-time during the 4 
months of the glass eel fishing season 

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Evaluation of the Eel Regulation 

to  coordinate  investigations  on  environmental  crimes  (incl.  eel  poaching)  and  act  as  focal  point  of 
international  police  networks  (Interpol,  Europol).  In  SE,  coordination  and  cooperation  between 
concerned authorities has been improved through exchange of information, common risk assessment 
and clarification of responsibilities of the different agencies involved. 

Surveillance  activities  are  reported  to  be  organised  according  to  priorities  identified  through  risk-
assessment analysis at National level. However, Member States did not specify inspection deployment 
strategies  (for  example  prioritising  inspection/verification  of  transport  and  sales  channels  over 
traditional inspection of landings to tackle IUU/smuggling). For Member States subject to high risks 
of live glass eel trafficking by organised crime (ES, FR), surveillance activities typically involve close 
cooperation  and  joint  patrolling  by  all  concerned  enforcement  entities,  with  in  the  case  of  France 
involvement of OCLASEP (see above) and Guardia Civil in Spain.  

All Member States reported to organise control on an ongoing basis mostly through cross-checking of 
catch declarations and sales notes, plus regular checks of vessels upon landings and in eel buyers and 
sellers premises to verify documentation. 

For detection of illegal fishing in river mouths or fresh water bodies, inspection bodies reported use of 
modern  technologies  such  as  drones  to  detect  illegal  activities  (DK,  EE,  LT,  LV,  PL,  SE),  side  scan 
sonars to detect illegal gears anchored on the bottom (DE, LV and UK) or heat detectors and night 
binoculars during night patrols (DK, FR and UK).  

Some Member States mentioned having encouraged support from citizens to detect illegal activities. 
DK and SE have implemented internet web site to facilitate reports from citizens which according to 
DK,  could  register  820  citizen  reports  of  illegal  fishing  in  2016  (presumably  not  all  related  to  eel 
poaching). PL is in the process of implementing a similar website (STOP KŁUSOLOM – stop poaching) 
in cooperation with national federations of recreational fishermen. In the UK, a telephone hot line is 
available to report suspected infringements. 

Cooperation for the fight against illegal eel trafficking is supported by EUROPOL under the EMPACT 
ENVICRIME initiative (2017-2021). SE also mentioned the set up for the next 3 years  of the  North 
Atlantic Fisheries Intelligence Group (NA-FIG) which will address eel fisheries among seven themes 
covered by the initiative. 

As detailed in the first section, cooperation between Member States and harmonisation of approaches 
to control will be further encouraged by the organisation of Joint Deployment Plans involving the EFCA. 

Control of restocking obligations 

Feedback  from  Member  States  tends  to  indicate  that  the  obligations  set  out  in  Article  7  of  the  Eel 
Regulation are applied differently.   

In FR, the 60% reserved for restocking are accounted for in the national glass eel quota implemented 
each  year  based  on  scientific  advice,  meaning  that  quantities  sold  for  consumption  cannot  exceed 
40%  of  the  annual  quota.  Monitoring  of  restocking  and  consumption  sub-quotas  is  supported  by 
verification of sales notes, which in the case of glass eels have been modified to allow specification of 
the destination of the glass eel catches as foreseen by art. 7.3 of the  Eel Regulation. However, FR 
authorities have no competence to monitor the fate of glass eels intended for restocking in another 
Member States. A monitoring system is in place to ensure that glass eels intended for restocking in 
the national territory is used for this purpose (restocking operations are supervised by authorities), 
but this concerns only between 5 and 10% of glass eel caught. 

In the case of ES and UK where there is no similar catch quota for glass eels, the restocking obligation 
appears  to  be  unenforceable  according  to  the  authorities  consulted.  Whilst  the  Eel  Regulation 
mandates that 60% of glass eel catches must be reserved (emphasis added) for restocking, concerned 
Member  States  mentioned  that  operators  report  having  reserved  the  glass  eels  as  prescribed,  but 
eventually sold the glass eel so reserved for consumption in the absence of orders of glass eels from 
entities wishing to use them for restocking. In other words, the reservation obligation is not seen as 
an obligation to use the eels subject to reservation for restocking. Given this interpretation, provisions 
of art. 7.3 of the Eel Regulation do not appear to have been implemented in this Member States as 
they would appear irrelevant. 

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Evaluation of the Eel Regulation 

4.4.3 Identification of problems 
The EU fisheries control system, and in particular the Control Regulation has many shortcomings in 
relation  to  the  monitoring  and  control  tools  for  fishing  vessels  of  less  than  10  m  which  form  the 
overwhelming majority of fishing fleets exploiting eels. The shortcomings are extensively described in 
the Commission’s own evaluation of the EU control system and triggered a proposal for amendments.  

The  main  weakness  of  the  EU  Control  Regulation  is  that  it  provides  for  numerous  derogations  in 
relation to catch and landing declarations for such vessels, with Member States having discretionary 
powers for monitoring catches of this fleet segment based on sampling plans or substitution by sales 
notes which prevents cross-checking. There are few evidences of implementation of electronic catch 
reporting systems for vessels of less than 10 m targeting eels. In addition, the EU Control Regulation 
provides exemptions for declarations of catches below 50 kg per fishing trip, a threshold set too high 
in the context of eel fisheries as a reasonable catch of glass eel lies between 1 and 2 kg per fishing 
trip 32.  As  a  result  of  these  shortcomings,  catches  of  eels  by  professional  fishermen  may  not  be 
adequately monitored,  with risks of misreporting. In fact,  ICES (2018) noted that eel data sourced 
from  landing  statistics  remains  incomplete  and  the  level  of  reporting  between  Member  States  is 
inconsistent. 

Monitoring and control of recreational eel fisheries appear also to be largely incomplete. The EU Control 
Regulation  does  not  lay  down  provisions  for  authorisations,  catch  reporting  and  vessels  tracking 
applicable to recreational vessels and excludes recreational fishing without a vessel from its scope. 
Furthermore, the Eel Regulation (Art. 11.2) is limited to “estimate” on a “regular basis” of the number 
of recreational fishermen and of their catches of eels. According to  

Figure 16 on page 67, recreational catches of eels can be significant (≈ 500 tonnes per year) in certain 
Member States (e.g. DE, DK, FR, IT, PL) that did not prohibit recreational fishing for eels at certain 
stages, or at any stage.  

Traceability of eels along the supply chain is a concern. While sales note requirements appear to be 
adequately implemented by Member States through buyers, post landing documentation required in 
the  event  eels  are  intended  for  sale  at  later  stage  (take-over  declarations,  transport  documents  if 
transported more than  20 km away) do not provide evidences  of the  legality of catches. Transport 
documents in particular are inadequate since they are paper based with submission no later than 48h 
after the load and established under the responsibility of the transporter who is generally not fully 
aware of the nature of the cargo. Exchanges of live glass eels between Member States are relatively 
common. The Eel Regulation encourages transport from producing Member States (e.g. ES, FR, PT, 
UK) to Member States in need of glass eels (e.g. BE, DE, DK, NL, SE) for restocking. Exchanges are 
also underpinned by aquaculture development as producing units in some Member States (e.g. GR, 
IT, NL) rely on supply of glass eels caught in the wild in other Member States territories to constitute 
their livestock. Shortcomings of the EU Control Regulation in this area suggest that transport may be 
an ideal vehicle for covering fraudulent practices and for misreporting catch data. Traceability is further 
hindered by the fact that post-landing documentation established by the EU Control Regulation does 
not consider the destination of glass eels which may include consumption, possibly after ranching, or 
restocking, also possibly after ranching. Traceability is further undermined by the relative inertia of 
the one up / one down paper-based system mandated by Art. 58 of the EU Control Regulation, and 
the exclusion of eels caught or farmed in freshwater from its scope. 

Prescriptions of the Eel Regulation for restocking (Art. 7.1) have been reported as unenforceable by 
some Member States (e.g. ES, UK) on the ground that the word “reservation” may not be interpreted 
as an obligation to use the eels so reserved for restocking by concerned operators. In addition, a glass 
eel producing Member State (e.g. FR may ensure that part of the 60% reserved for restocking on its 
territory is used for this purpose but does not have competence to ensure that the remaining % are 
used for this purpose in the territory of another Member State. In this respect, Art. 7.3 cannot be fully 
complied with in the absence of transnational traceability system. 

32 Source : professional glass eel fisherman 

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Evaluation of the Eel Regulation 

Member States did not report specific problems in relation to fight against illegal fishing of eels in their 
territory but suggested that inspection strategies must take into account extensive territory and fishing 
practices that are not readily detectable, in particular when immersed illegal gears (e.g. traps) are 
used to catch yellow or silver eels. However, the lack of information provided by Member States on 
resources deployed for control prevented any further analysis. Problems are reported to occur for the 
control of eels, live glass eels in particular, that may be transported from other Member States due to 
the absence of evidences (i.e. traceability) to ensure that eels have been obtained legally. 

4.4.4 Some good practices in control 
The survey supported identification of best practices, i.e. practices implemented at national level in 
the  field  of  control  that  go  beyond  minimum  EU  requirements.  Best  practices  may  be  a  source  of 
inspiration  for  other  Member  States  for  strengthening  the  control  framework  of  eel  fisheries  under 
their  competence  under  the  current  EU  regulatory  framework.  However,  best  practices  must  be 
evaluated  in  the  context  of  the  eel  fisheries  in  the  Member  States.  For  example,  best  practices 
implemented  for  monitoring  glass  eel  fisheries  in  certain  Member  States  are  irrelevant  for  Member 
States having prohibited glass eel fishing. 

Catch declaration by professional fishermen 

•  FR  mandates  professional  fishermen  targeting  glass  eels  to  declare  catches  every  two  days 
with a reporting threshold set at 100 g, noting that this system is underpinned by the need to 
monitor uptake from a glass eel catch quota. However, the catch declaration system remains 
paper-based. FR fishermen and River Parret UK have unilaterally implemented an e-reporting 
system to support their own monitoring of the fisheries but the e-reporting system does not 
have legal basis. 

•  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 
(yellow or silver). 

Monitoring of recreational fisheries 

•  FR implemented a specific registration system for recreational fishermen using fishing gears 
other than rod and line. A catch declaration system has been mandated but based on paper 
reporting with reportedly insufficient resources to computerise them.  

Traceability of eels 

•  GR, IT and SE seemingly33 used the opportunities offered by Article 8.5 of Council Regulation 
(EC) N°338/97 to involve their CITES management authorities in the control of eel movements 
in their territories. The national mechanisms implemented aim at ensuring that eels detained 
by  national  operators  or  subject  to  intra-EU  movements  have  been  legally  acquired.  Whilst 
verifying the eels entering their territory have been obtained in compliance with conservation 
rules  may  be  challenging  in  the  absence  of  uniform  traceability  solutions  at  EU  level,  the 
verification  of  the  legality  of  eels  detained  by  national  operators  or  transported  out  of  their 
territories  may  be  realistically  implemented  by  measures  under  national  competence.  The 
involvement  of  CITES  management  authorities  has  also  the  advantage  of  providing  a  legal 
basis for the involvement of the concerned CITES management authorities in the national eel 
control system. 

•  Some Member States 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. 

33 This is our own assumption. We asked the concerned Member States to clarify the legal basis, but 
no response received so far. 

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Restocking obligations 

Evaluation of the Eel Regulation 

•  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. 

Inspections 

•  Several  Member  States  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 utilisation of 
heat detectors and night binoculars (DK, FR and UK). 

• 

In Member States where illegal trafficking of live glass eels is suspected to occur, control burden 
is shared by the different national police authorities, with main national police corpses in charge 
of intelligence and coordination (i.e. Gendarmerie in FR, Guardia Civil in ES). 

•  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). 

4.4.5 What can be done at EU level? 
In view of the identified shortcomings of the EU Control System, the Commission tabled a proposal 34 
in May 2018. The proposal is now being discussed by the co-legislators. As outlined in the table in 
Annex 6, the measures proposed by the Commission addresses most of the problems stemming from 
the  numerous  exemptions  foreseen  in  the  current  EU  Control  Regulation  for  monitoring  fishing 
activities  deployed  by  vessels  of  less  than  10  m,  monitoring  of  recreational  fisheries,  post-landing 
documentation  and  traceability  along  the  supply  chain.  All  proposed  amendments  to  the  Control 
Regulation will help Member States and the Commission to strengthen the EU fisheries control system. 
If only three main initiatives tabled in Commission’s proposal were to be distinguished, it would be i) 
the mandatory electronic catch declaration of all vessels irrespective of their sizes, ii) more stringent 
requirements  for  monitoring  and  control  of  recreational  fishing  and  ii)  the  streamlining  and 
improvement of post-landing documentation scheme, with in particular, a comprehensive reform of 
the  transport  document  as  glass  eel  movements  between  Member  States  appear  to  be  critical  in 
relation to control. The development over time of electronic “from net to plate” traceability systems 
will support verification of the legality of eel batches along the supply chain. 

However, there are a few dispositions in the Commission’s proposal for a reformed EU Control System 
that may not be fully appropriate in the case of eel fisheries due to its specificities (i.e. catches of a 
few kilograms of glass eels per fishing trip), although fully proportionate in the broader context of EU 
fisheries. This include: 

•  The tolerance margin (20%) proposed for accuracy of catch declaration in case catches weight 
less than 50 kg, which appears far too high in the case of eels, in particular glass eels for which 
catches normally range between 1 and 2 kg 

•  The exemptions provided for post-harvest documentation for catches of less than 5 kg deemed 

to be sold direct to consumers, which appear very generous in the case of eels 

•  Commission’s proposal does not specify if the reformed EU Control System will have a capacity 
to manage products according to their destination (i.e. restocking or consumption in the case 
of eels). However, this is something that will be probably addressed in a revised implementing 
Regulation 

34 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 

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Evaluation of the Eel Regulation 

•  The  scope  of  the  “net  to  plate”  traceability  system  will  be  probably  defined  in  a  revised 
implementing Regulation. It will need to specify how diadromous species should be treated for 
both fisheries and aquaculture. In the past, the Commission had to formulate an interpretation 
on how catadromous species should be considered under the IUU Regulation. 

Concerning  CITES,  Article  8.5  of  Council  Regulation  (EC)  N°338/97  provides  a  legal  basis  for 
implication of the national CITES management authorities in the control of the legality of eels detained 
or offered for sale by operators in their territory independently from the availability of an export quota. 
The extent to which Member States have involved their CITES management authorities in the control 
process is unclear35, except in a few cases (GR, IT and SE). The Commission may find appropriate to 
remind this legal obligation to Member States and follow up on the national measures implemented. 

The evaluation identified a possible source of legal misinterpretation of Article 7.1 of the Eel Regulation 
in relation to restocking suggesting that 60% of glass eels caught each year may not be marketed for 
this purpose as expected. As a result, control authorities cannot enforce this prescription. Article 7.1 
of  the  Eel  Regulation  may  need  to  be  reconsidered  taking  into  account  the  continued  relevance  of 
other prescriptions on restocking. There is no immediate solution to propose, as it depends to some 
extent  on  what  the  legislator  had  in  mind  for  introducing  the  concept  of  reservation  in  the  Eel 
Regulation. 

Some Member States (e.g. BE, DE, IT and SE) suggested to the evaluation team that the EU should 
deploy a dedicated EU traceability system for glass eels based on the models developed by ICCAT for 
bluefin tuna or by CCAMLR for toothfish. These two specific traceability systems have been developed 
by the RFMOs, implemented through binding instruments and are operated and managed centrally by 
them. They provide a full electronic traceability solution for the species concerned, from catch to final 
sale, on which concerned authorities can rely to verify the legality of shipments across borders and in 
their territories. Arguably, a similar system would provide to Member States an adequate solution to 
verify the legality of eel batches under their competence. However, the relevance of an EU investment 
in a dedicated traceability system for glass eel must be further investigated. The ICCAT and CCAMLR 
catch documentation scheme are justified by the involvement of non-EU countries in these respective 
fisheries,  each  having  its  own  regulatory  framework,  which  is  not  the  case  for  EU  Member  States. 
Also, the development of an EU centralised system just for intra-EU trade of glass eel may not be seen 
as fully proportionate in the broader context of EU fisheries. Finally, an EU traceability system for eels 
may be redundant with the provisions of an improved EU Control System if it successfully strengthens 
traceability requirements as it is the intention of the Commission’s proposal. 

35 We do not have information from Member States who did not respond to our questionnaire, and 
among those who responded, use of CITES instruments may have been overlooked. 

June 2019 

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Evaluation of the Eel Regulation 

 EVOLUTION OF MARKET PRICES FOR EELS < 12 CM 

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)) (Dekker, Van Os & Van Willigen, 1998).  
Reported glass eel production has increased from just under 40 t per annum in 2011 to around 60 t 
in  2018.  France  remains  the  predominant  glass  eel  producer  and  is  the  only  country  to  set  quotas 
(currently 64.75 t, of which 38.75 t are reserved for restocking).  Spain’s glass eel production over 
this period (minimum 1 t in 2018 and maximum 16 t in 2017) is mainly for local use in a small area 
of the Basque region, a traditional practise that is now being replaced with an artificial substitute.   

Figure 7: EU glass eel production (2011 - 2018) 

Source: Compiled from ICES (2018c) 

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  the  Member  States,  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 so far (DG Mare, pers. comm., 11 January 2019). 

The Eel Regulation requires Member States to monitor the market prices for eels annually, and for the 
Commission to report these to the Council, also on an annual basis.  However, the level and quality 
of glass eel price reporting is highly variable between Member States and as a result, the Commission 
has been unable to fulfil this annual reporting requirement.  According to the 2014 evaluation report 
only nine complete glass eel reports were received by July 2012.  Since then, no national reports on 
glass eel prices have been submitted, although Belgium, Denmark, Estonia 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. 

Based on the limited data available, the EU market prices of eels <12 cm that are predominantly used 
for restocking (there is 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  8  overleaf).    These  figures  conform  with  confidential  tender  prices 
provided to the consultant by glass eel traders over 2016 – 2018.   

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Evaluation of the Eel Regulation 

Figure 8: Average prices for glass eels <12 cm (2009-2017) used for restocking, showing 
production (t, 2011-2017) 

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

Nineteen EU countries sold live eels over the last decades. This trade includes re-selling of glass eels 
from  one  country  to  another,  e.g.  in  case  eel  been  sold  from  Spain  to  Germany  and  afterwards 
continued its journey to e.g. Poland for stocking the eel sales would be double counted as sales from 
Spain  and  sales  from  Germany.  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). 

Focusing on the trade in glass eels, the reported EU catch of glass eels is around 60 t per annum (see 
Figure  7  above).  In  fishing  season  2016/2017,  64  t  of  glass  eel  catches  were  declared  to  national 
authorities in France, Spain, Portugal and UK and 59 t in the season 2017/2018.  The market for glass 
eels  within  the  EU  for  aquaculture  is  around  15  –  20  t  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 Spain, so the total EU market is around than 50 to 55 tonnes.  Questions have been 
raised about the fate of the other 5-10 tonnes of glass eels.  The Sustainable Eel Group (SEG) suggest 
that around 30 t of glass  eel production over  2016 and 2017 is unaccounted  for (SEG, 2018), and 
EUROPOL have suggested that this might be as much as 100 t36.  SEG speculate that this unaccounted 
proportion of the legal catch, as well as possibly production from unlicensed fisheries is used to supply 
the  lucrative  market  for  glass  eels  in  Asia,  where  prices  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).   

36

 https://www.europol.europa.eu/newsroom/news/glass-eel-traffickers-earned-more-eur-37-

million-illegal-exports-to-asia  

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Evaluation of the Eel Regulation 

 ANALYSIS OF THE INTERLINKAGES BETWEEN THE EEL 

REGULATION AND OTHER EU RULES 
4.6.1 Common Fisheries Policy 
Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 
on the Common Fisheries Policy (CFP) sets out a collaborative approach to managing the EU’s shared 
seas and fisheries. The CFP aims to ensure high long-term fishing yields, with the objective to restore 
and  maintain  populations  of  harvested  species  above  levels  which  can  produce  the  maximum 
sustainable yield (MSY) by 2015 where possible, and no later than 2020. 

In Art. 4 of Regulation No 1380/2013 the CFP defines ‘marine biological resources’ as available and 
accessible living marine aquatic species, including anadromous and catadromous species during their 
marine life.  Therefore, the CFP and its MSY objective is applicable at certain stages in its life cycle to 
the European eel 37.  Indeed the original Community Action Plan for the management of European Eel 
(EC, 2003) stated that “that the spirit of Council Regulation 2371/2002 is clearly to bring all  living 
aquatic  resources,  including  catadromous  species,  under  the  scope  of  Community  action  when  and 
where necessary. From that point of view, the Commission believes that Council Regulation 2371/2002 
does  not  constitute  a  barrier  to  the  management  of  eels,  including  during  their  freshwater  life,  at 
Community level”. 

Under the CFP, EU fisheries management covers a suite of measures including: 

•  Total Allowable Catches (TACs) and quotas; 
•  Technical measures, including fishing gear specifications and gear usage; 
•  Fishing effort controls, e.g. limit on number of days at sea; 
•  Access to waters, e.g. limitations / control on which vessels can fish which areas; 
•  The Landing Obligation, which reduces unwanted catches and discarding, and; 
•  Multi-Annual Plans (MAPs) which combine management tools for specific species, fisheries 

and marine regions. 

Council Regulation (EU) 2018/120 of 23 January 2018 fixing for 2018 the fishing opportunities for 
certain fish stocks and groups of fish stocks (Council of the European Union, 2018a), applicable 
in Union waters and, for Union fishing vessels, in certain non-Union waters, sets species-specific TACs 
and quotas.   Article 10 of EU 2018/120 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 is determined 
by each Member State and will occur sometime between 1 September 2018 and 31 January 2019.   

Council Regulation (EU) 2019/124 (Council of the European Union, 2019) extends this approach (EC, 
2018a) 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 is designed to be consistent with the conservation objectives set out in the Eel 
Regulation  and  with  the  temporal  migration  patterns  of  European  eel  and  will  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 Member States in the Mediterranean.  It hence transposes into EU law the recent 
GFCM Recommendation GFCM/42/2018/1 establishing management measures for European eel in the 
Mediterranean Sea (GFCM, 2018). 

Regulation (EU) 508/2014 of the European Parliament and of the Council of 15 May 2014 (European 
Parliament  &  the  Council  of  the  European  Union,  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  Art.37.2  on  direct 
restocking  and  Art.  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 operations were funded though the EMFF with total eligible costs of EUR 18.6 million and an EMFF 

37 The Community Action Plan for Eel Management (EC, 2003) suggested that the expression “during 
their marine life” in Regulation 2371/2002 (EC, 2003) might be removed for catadromous species  

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allocation of EUR 11.1 m (EC, 2018a). Germany alone approved 71 operations with an EMFF budget 
of EUR 5.2 m., with the Czech Republic approving nine operations.  Overall, eight MS implemented 
related operations, dedicating 1.8 % of their EMFF to this area.  Six MS 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  MS  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 MS refer 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) 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 have provided financial information on eel-related measures. 

Regulation (EU) 2017/1004 (European Parliament & the Council of the European Union, 2017c) of the 
European  Parliament  and  of  the  Council  of  17  May  2017  establishes  an  EU  framework  for  the 
collection, management and use of data in the fisheries sector and support for scientific advice 
regarding the common fisheries policy.  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.   

Regulation  (EC)  No  1224/2009  of  20  November  2009  (the  Control  Regulation,  Council  of  the 
European Union, 2009) establishes a Union control system for ensuring compliance with the CFP. 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.  The  European  Commission  has  published  its  evaluation  of  the 
fisheries control regulation in April 2017 (EC, 2017) and subsequently tabled a proposal to revise the 
fisheries control system (European Parliament & the Council of the European Union, 2018), including 
the Control Regulation. 

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 Member States is inconsistent. 

4.6.2 Water Framework Directive 
Background 

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

The WFD covers protection of ground water and surface waters, including inland surface waters (rivers 
and lakes), transitional waters (estuaries) and coastal waters and is therefore highly relevant to eel 
habitats.    Member  States  are  required  to  monitor  these  water  bodies,  characterise  river  basins, 
establish  river  basin  management  plans  (RBMP)  and  assess  water  quality  against  ecological  status 
and chemical status classifications. 

The key objective of the WFD is to achieve 'good status' for all aquatic ecosystems, including 111,000 
surface  waters  (e.g.  rivers,  lakes,  coastal  waters),  with  regard  to  their  water  needs,  terrestrial 
ecosystems and wetlands, to meet 'good status' by 2015. The WFD, however, allows for extensions 
to  the  2015  deadline,  provided  that  no  further  deterioration  occurs  and  that  they  are  limited  to  at 
most 2 further cycles (i.e. the present 2015- 2021 period, and the next 2021-2027 one) (EC, 2019b). 

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For surface waters there are two elements: good ecological status and good chemical status: 

•  Good ecological status is defined in Annex V of the WFD, in terms of the quality of the 

biological community, the hydrological characteristics and the chemical characteristics.  

•  Good chemical status is defined in Annex IX and Article 16(7) of the WFD, in terms of 

compliance with all the quality standards established for chemical substances at European 
level. 

Interestingly,  European  eel  has  been  proposed  as  an  appropriate  Ecological  Quality  Ratio  (EQR) 
indicator  for  determining  a  water  body’s  chemical  status.  This  is  based  on  bioaccumulation  of 
contaminants  within  eel  muscle  providing  an  accurate  reflection  of  the  contaminants  within  their 
habitat. However, based on WFD Technical Guidance, together with the protected status of eels, they 
are  only  used  for  existing  trend  monitoring  programmes,  and  not  captured  specifically  to  monitor 
chemical status of water bodies.  The European eel was also proposed as an indicator of ecological 
status, but turned down due to its declining abundance, a decision questioned by some. 

In  terms  of  WFD  timeline,  the  first  management  cycle  of  the  WFD  ended  in  2015,  the  second 
management cycle ends in 2021 and the third ends in 2027, which is also the final deadline for meeting 
WFD objectives under Article 4 (Environmental Objectives) and Article 13 (River Basin Management 
Plans). 

In relation to eels, the WFD is specifically important in protecting and improving water quality of key 
eel  habitats,  including  rivers,  estuaries  and  coastal  waters;  it  is  also  important  in  improving  river 
continuity.  Environmental  impacts  in  marine,  transitional,  and  fresh  waters,  which  include  habitat 
alteration, barriers to eel passage, deterioration in water quality, all contribute to the anthropogenic 
stresses and mortality on eels, and also affect their reproductive success (ICES, 2018). ICES anticipate 
that the implementation of the WFD may result in improvements to the continental environment, and 
that this may have a positive effect on the reproductive potential of silver eel (ICES, 2018). 

WFD improvements benefiting eels 

Eel Management Units as defined by EU Member States, 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. Several European river basins have master plans 
or conservation plans for restoring the population of threatened fish species (salmon, sturgeon, eel 
etc.) as well as improving river continuity as part of the WFD. River Basin Management Plans (RBMPs) 
were introduced for RBDs in 2009.   

A report by WWF, European Environmental Bureau, the European Anglers Alliance and European Rivers 
Network  (2018)  highlights  that  the  WFD  provides  an  effective  framework  for  addressing  the  main 
pressures facing rivers, lakes, wetlands, streams and groundwater.  However, to “achieve these goals, 
efforts  and  resources  for  better  implementation  and  enforcement  of  the  WFD  will  have  to  be 
significantly stepped up”. 

The  European  Environment  Agency  (EEA,  2018)  recently  compared  the  status  of  European  waters 
between the introduction of the first (2009) and second (2015) RBMP cycles.  

In relation to ecological status / potential of water bodies EEA (2018) concluded: 

•  Only 40% of surface waters are in good ecological status or potential (‘potential’ relates to 

status of a heavily modified or artificial water body) 

•  There are less ‘unknown status’ classifications i.e. more water bodies are assessed, and the 

confidence in assessments have improved, together with the intercalibration of methodology. 

•  The overall ecological status / potential of all water bodies has not improved. 
•  There has been some reduction in proportion of water bodies that are in good or better 

ecological status; and there has been some (20%, equating to 16,000 water bodies) that 
have improved in status. 

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The  main pressures  on  surface water bodies are hydro-morphological physical alterations (i.e. that 
cause  continuity  interruptions),  diffuse  source  pollution  (agriculture  and  atmospheric  deposition), 
point  source  pollution  (wastewater  treatment  and  industrial  plants  &  storm  overflow)  and  water 
abstraction.  Hydro-morphological pressures affect around 40% of surface water bodies, notably due 
to physical alterations in the channel, bed, riparian zone or shore as well as structural barriers including 
dams and locks. 

On existing physical modifications of water bodies, most Member States have reported measures (fish 
ladders, removal of structures, etc.) aimed at reducing the negative hydro-morphological pressures 
(EC,  2019b).  The  most  common  measures  applied  include  fish  passes  for  upstream  migration, 
removing  barriers,  establishing  ecological  flow,  re-meandering,  reconnecting  backwaters,  restoring 
bank  structure,  instream  structures  (large  pieces  of  wood,  boulders)  and  sediment  transport 
management  (EEA,  2018).  Recent  implementation  of  some  of  these  key  measures  in  European 
countries are outlined in Table 5 overleaf. 

Restoring  river  connectivity  under  the  WFD  should  benefit  eel  migration,  however,  40%  of  surface 
water  bodies  remain  affected  by  hydro-morphological  pressures  and  therefore  significant  effort  is 
required to fully restore river continuity. 

The  EEA  (2018)  report  concludes  that  only  38%  of  surface  waters  are  in  good  chemical  status.  In 
relation to changes in chemical status of water bodies between the first and second RBMPs, the number 
of  ‘unknown  status’  classifications  has  dropped  significantly,  making  it  difficult  to  compare  across 
different  water  body  types.  Overall,  the  total  number  of  surface  water  bodies  with  good  chemical 
status  has  remained  the  same,  while  the  number  failing  to  achieve  good  status  has  increased. 
However, it is noted that certain Member States are making significant progress in tackling certain 
individual priority substances (e.g. isoproturon, diuron, DDT), while other substances are  cause for 
failure across a significant proportion of water bodies, particularly mercury (which fails to meet good 
status in 41% of water bodies). 

Table 5: Examples of measures to address hydro-morphological pressures by country or 
river basin district (RBD) / international RBD (iRBD) 

Country or River 
Basin District 
(RBD) 

Measures 

Examples of measures to make barriers passable 

Rhine iRBD  

Danube iRBD  

Elbe iRBD 

480 measures aimed at improving river continuity were implemented from 2000 to 2012 
(ICPR, 2015)  

From 2009 to 2015, more than 120 fish migration aids were constructed, and 667 
barriers remained unpassable out of a total of 1030 (ICPDR, 2015)  

Measures to improve continuity were completed in 60 locations and planned in 88 
locations in the International RBD priority network from 2009 to 2015 (ICPE, 2015)  

France, Rhône RBD  

208 out of 788 priority barriers were made passable from 2010 to 2015 (Rhône-
Mediterranée district, 2016)  

France, Seine RBD  

For 254 out of 5474 barriers, measures were implemented to improve river continuity 
from 2013 to 2015 (Seine RBD, 2016)  

Austria 

More than 1 000 barriers were made passable for fish from 2009 to 2015 (BMLFUW, 
2017) 

Netherlands  

Around 600 barriers were made passable from 2008 to 2015 (Kroes et al., 2015) 

UK: England and 
Wales  

229 obstructions across England and Wales were made passable from 2009 to 2014 
(NASCO, 2015)  

UK: Scotland RBD  

Access for fish to 70 water bodies (out of 306 water bodies affected by migration 
barriers) was secured by the removal of barriers to fish migration from 2009 to 2015 
(SEPA, 2015)  

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Examples of measures addressing other hydro-morphological pressures 

Reactivation of floodplains from c. 80 km2 in 2005 to c. 125 km2 in 2012. 

Rhine iRBD  

Increase in structural diversity of banks from c. 50 km bank length in 2005 to c. 100 km 
bank length in 2012. Reconnection of alluvial areas from c. 35 areas reconnected in 2005 
to 80 alluvial areas reconnected in 2012 (ICPR, 2015) 

Danube iRBD  

More than 50 000 ha of wetlands/floodplains have been partly or totally reconnected, and 
their hydrological regime improved, 2009-2015 (ICPDR, 2015) 

Austria 

Approximately 250 water body restructuring activities were carried out to improve hydro-
morphological conditions in the largest waters of the so-called priority restoration zones, 
2009-2015 (BMLFUW, 2017) 

France, Rhône RBD 

Morphological  restoration  works  carried  out  on  more  than  160  km  of  rivers.  Wetland 
restoration  increased  from  7  332  ha  restored  in  2010  to  16  069  ha  restored  in  2015 
(Rhône-Mediterranée district, 2016) 

UK: Scotland RBD 

Physical  conditions  of  36  water  bodies  improved  out  of  255  water  bodies  affected  by 
modifications to their beds, banks or shores, 2009-2015 (SEPA, 2015) 

Source: EEA, 2018 

The comparison between the 2009-2015 cycles, indicate that only a limited number of water bodies 
have improved in status (EC, 2019b). This may be due to late identification of pressures, the longer 
time required to design effective policy measures, the slow introduction of measures, and the response 
time of nature before measures take effect (EC, 2019b).  

While interlinkages between EMPs and WFD are clear, the authorities responsible for the EMP are not 
necessarily  involved  in  the  implementation  of  River  Basin  Management  Plans.    Hanel  (2019) 
highlighted that the legal situation may be difficult or unclear e.g. authorities responsible for the EMPs 
have  no  or  restricted  legal  competence  for  hydropower  issues  making  implementation  of 
change/measures to reduce eel mortality challenging. Hanel (2019) also noted that implementation 
of many proposed measures can often be delayed, likely due to the high costs associated with actions 
in this field.  

Furthermore, only a few Member State EMPs/ Progress Reports make reference to the importance of 
the WFD in improving water quality and connectivity (e.g. Belgium, Spain, Ireland), and where this 
does occur, targets for improvement and expected benefits to eels are not defined.  There are clear 
linkages  in  the  objectives  of  WFD  /  RBMPs  and  EMPs  (i.e.  improve  river  continuity  and  restore  eel 
populations), but not in the delivery and implementation of measures or monitoring of outcomes.  It 
is not clear whether the effects of measures to improve river continuity are monitored at all, let alone 
linked  to  eel  stocks.  Indeed,  Hanel  (2019)  recommends  that  given  the  unknown  efficiency  of  such 
measures at barriers, the transport and stocking programmes of eels to areas upstream of obstacles 
should be ceased, with all efforts focused on fully restoring river continuity. 

4.6.3 Marine Strategy Framework Directive 
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, 2008), known 
as the Marine Strategy Framework Directive (MSFD). The key objectives of the MSFD are to achieve 
or maintain good environmental status of marine waters by 2020; by adopting an ecosystem-based 
approach to management that is implemented through a common regional approach. 

The Good Environmental Status (GES) descriptors are as follows (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  

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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  

Based on these descriptors, Member States 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). 

4.6.4 Habitats Directive 
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, was adopted by EU governments to ensure the protection 
of endangered and/or vulnerable animals, plants and characteristic habitats. 

Over  1,000  animal  and  plant  species,  and  200  habitat  types  are  listed  in  the  Directive  under  its 
Annexes  I to VI.   European eel, A. anguilla, is not listed in the Habitats Directive under any of the 
species  Annexes,  including  II,  IV  or  V.  Habitats  that  are  important  to  eels,  including  estuaries  and 
coastal lagoons are listed in the Habitats Directive, and protected through the designation of Special 
Areas of Conservation (SACs).   

Estuaries are widespread throughout the Atlantic coasts  of  Europe; there are 360 SACs designated 
due to the presence of an estuary (Figure 9). Coastal lagoons are considered a priority habitat under 
Annex I of the Habitats Directive, with 772 current sites designated as SACs. 

Figure 9: Natura 2000 designations for estuaries (left) and coastal lagoons (right) 

Source: Natura 2000 Network Viewer, European Environment Agency, 2017 

The estuaries and coastal lagoons SAC designations require Member States to establish conservation 
measures  which  correspond  to  the  ecological  requirements  of  these  Annex  I  habitats  and  to  take 
appropriate steps to avoid their deterioration.  

A summary of the EU regulations and rules relevant to eels is provided in Figure 10 on page 49. 

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Evaluation of the Eel Regulation 

 ANALYSIS OF THE INTERLINKAGES WITH INTERNATIONAL 

INSTRUMENTS THAT COVER EELS  

4.7.1 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 EEZ but prohibited in the high seas.  

•  Management must include provisions for secured immigration and emigration of the species.  

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

CITES is an international agreement between governments, which ensures that international trade in 
specimens of wild animals and plants does not threaten their survival. 

The European eel was listed on CITES Appendix II  in 2007 (which came into force in 2009), which 
recognises it as a species that is not necessarily now threatened with extinction, but that may become 
so unless trade is closely controlled.  CITES Appendix II stipulates that in relation to species: 

•  An export permit or re-export certificate issued by the Management Authority of the State of 

export or re-export is required.  

o  An export permit may  be issued  only if the specimen was legally obtained and if the 

export will not be detrimental to the survival of the species. 

o  A re-export certificate may be issued only if the specimen was imported in accordance 

with the Convention. 

• 

In the case of a live animal or plant, it must be prepared and shipped to minimise any risk of 
injury, damage to health or cruel treatment. 

•  No import permit is needed unless required by national law. However it should be noted that 
the  EU  does  indeed  have  such  stricter  domestic  measures  and  requires  import  permits  for 
Appendix II species.  

The  EU  implementation  of  CITES  rules  is  via  Council  Regulation  (EC)  No  338/97  Wildlife  Trade 
Regulation and its implementing regulations.   In 2010, and  every  year since then, the  relevant EU 
scientific body decided that it was not possible 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  since  2011 
(ICES, 2018a). 

4.7.3 Convention on the Conservation of Migratory Species of 
Wild Animals 

In 2014, the European eel was added to Appendix II of the Convention on Migratory Species (CMS), 
also known as the Bonn Convention. 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  

Therefore  an  Appendix  II  listing  under  CMS  does  not  require  individual  Parties  to  undertake  any 
specified conservation activities on their own, even though the scope of CMS allows them to address 
habitat,  trade,  and  other  threats.  Appendix II  species  fully  benefit  from  the  CMS  listing  when  an 
agreement or other form of international cooperation follows (Wold, 2018).  

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In 2016 the first Range States Workshop on European eel was held to review conservation status and 
existing  management  measures38.    A  second  workshop  was  held  in  2018  with  the  participation  on 
many  range  states  and  relevant  organizations.  This  workshop  identified  key  areas  for  future 
cooperation, including the role of the CMS in establishing a link between conservation activities in the 
Sargasso Sea and in Europe and North Africa39. 

A summary of the above international linkages relevant to eels is provided in Figure 10. 

Figure 10: Summary of EU and international linkages applicable to European eel 

38 https://www.cms.int/en/meeting/first-range-state-workshop-european-eel  
39 https://www.cms.int/en/meeting/2nd-meeting-range-states-european-eel  

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4.7.4 International Union for the Conservation of Nature 
The International Union for the Conservation of Nature (IUCN) was created in 19048 as a ‘membership 
Union’  composed  of  both  government  and  civil  society  organisations.  It  comprises  six  commissions 
that leverage volunteer experts to assess the state of the world’s natural resources and provide IUCN  
with information and policy advice on conservation issues.  A key tool produced by IUCN is the IUCN 
‘Red List of Threatened Species’ 40 (known widely as the ‘Red List’.  Established in 1964, this 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. 

The European eel was last assessed by the IUCN SSC Anguillid Eel Specialist Group for updating the 
Red List in 2013 (Jacoby & Gollock, 2014).  At that point it was considered to be ‘critically endangered’.  
Ideally the IUCN Red List criteria would be applied to mature eels at their spawning grounds, and in 
the absence of such data, the criteria would be applied to silver eels starting their spawning migration 
(in the case of European eels, leaving ‘continental’ waters), as these represent the maximum estimate 
of spawning stock biomass, but data sets for this are very rare. The majority of available data relates 
to glass eels and yellow eels but the relationships between recruitment, yellow eel populations, silver 
eel escapement, and spawner stock biomass are poorly understood. As such, the IUCN Red List criteria 
have to be applied to an amalgamation of multiple life stages, which may not exactly mirror the mature 
spawning stock but are used by IUCN as the current best estimate. 

Although the relationship between life-stages is poorly understood, but it was generally agreed at the 
2013 assessment that it is very likely that the low recruitment will ultimately translate, though not 
linearly, to  reduced future  escapement for, at  best,  one generation length (15 years). Further, low 
recruitment has been proposed to be indicative of low historical breeding stock due to the relatively 
short time period (~2 years) between spawning and subsequent glass eel abundance. On this basis, 
although  the  mean  decline  in  silver  eel  escapement  is  estimated  to  be  50-60%  over  the  period  of 
three generations (45 years, just placing them in the ‘Endangered’ category), the IUCN SSC Anguillid 
Eel Specialist Group continued the ‘Critically Endangered’ listing.  However this listing will be reviewed 
in 2019 at the next IUCN assessment of the European eel.   

4.7.5 RAMSAR Convention  
The  Ramsar  Convention  on  Wetlands  of  International  Importance  is  an  international  treaty  for  the 
conservation and sustainable use of wetlands.  Also known as the Convention on Wetlands, it is named 
after the city of Ramsar in Iran, where the Convention was signed in 1971. Most EU Member States 
are  Contracting  Parties 41.    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.  

40 See https://www.iucnredlist.org/  
41

 See 

https://www.ramsar.org/sites/default/files/documents/library/annotated_contracting_parties_list_e.
pdf  

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5.0 ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

Evaluation of the Eel Regulation 

The  following section provides an analysis of the  evaluation questions, based upon the Evaluations 
Question  Matrix  (see  Annex  1B).    It  is  structured  around  the  six  Evaluation  Criteria  (Relevance, 
Effectiveness, Sustainability, Efficiency, Coherence and EU Added value) and the Judgement Criteria 
(JC) used to interpret each Evaluation Question (EQ).   

 RELEVANCE 

Relevance - Evaluation Question 1 

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

Data sources 

ICES, EUROSTAT & GFCM data, Progress reports, scientific reports, stakeholder consultations, 
case studies; RBMP reports (key selected river basins only); Desk study; PC; Stakeholder 
consultations; & project case studies 

JC 1.1: The extent to which eel landings, escapement levels and river basin conditions 
have recovered sufficiently to warrant the measures being continued 

The  Joint  EIFAAC/ICES/GFCM  Working  Group  on  Eel  (WGEEL)  documents  the  ongoing  process  of 
describing the stock of the European eel, and associated fisheries and other anthropogenic impacts, 
and developing a methodology for giving scientific advice on management to facilitate a recovery in 
the international, panmictic European eel stock ICES conducts an assessment of the status of the eel 
stock  every  year.  As  recruitment  and  landings  data  are  reported  to  the  working  group  every  year, 
these  form  the  basis  of  the  annual  trend  monitoring.  New  national  biomass  and  anthropogenic 
mortality stock indicators are scheduled to be available in 2015, 2018 and every six years thereafter.  
A Stock Annex for the European eel was accepted by the WGEEL 2015 meeting (see ICES, 2016b) and 
updated in 2018 (ICES, 2018a).  

Eel  landings:  European  eel  landings  are  described  in  Section  2.1.    Wild  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 (see Figure 2 and Figure 3 on page 4) where they are now broadly stable.  
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 is 
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 as 29% of the 1960–1979 
level  (ICES,  2018a).    This  suggests  that,  in  terms  of  landings  and  stock  recruitment,  whilst  the 
situation is no longer declining, it is still critical.   

Escapement levels.  Eel Management Plans (EMPs) 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  11  overleaf  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).  It is 
strongly noted by ICES that the results presented here are preliminary, and data quality processing 
and further analyses need to continue. 

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Evaluation of the Eel Regulation 

Figure 11: 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. 

River basin conditions: A key source of eel mortality is anthropogenic activities and impacts outside 
the fisheries, e.g. through the impact of hydro dams on migration and escapement.  This factor, which 
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.   

Spain 

UK 

Italy 

Ireland 

Germany 

Figure 12: Box plots showing anthropogenic (non-fisheries) mortality ƩH 

Source: ICES (2018c) 

These data suggest that 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. 

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Evaluation of the Eel Regulation 

In  summary  it  is  clear  that  the  recovery  of  the  European  eel  is  a  long-term  process  that  will  take 
decades rather than years to progress. Therefore 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.   

JC 1.2: 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 

The  reformed  CFP  and  other  relevant  EU  initiatives  and  their  relevance  to  the  Eel  Regulation  is 
described in Section 4.6.   

It is noted that the CFP is essentially focused on the conservation of marine biological resources and 
the management of fisheries targeting them, with its freshwater scope limited to market and financial 
measures (see point (2) on page of the preamble (European Parliament & the Council of the European 
Union, 2013).  The Eel Regulation (2007), which precedes the reformed CFP (2013) widens the scope 
of the EU’s mandate to include the management of the European eels in freshwaters.   

The Eel Regulation has its primary focus on managing the fisheries-related anthropogenic mortality, 
mainly through increasing escapement rates and reducing fishing mortality.  It does, however, fully 
recognise the role of Member States in implementing measures “as soon as possible to reduce the eel 
mortality caused by factors outside the fishery, including hydroelectric turbines, pumps or predators” 
(Art.  2  (10)).    This  immediately  introduced  the  need  for  coherence  with  other  EU  policies  and 
regulations (see Section 5.5 below).   Indeed  the Eel Regulation specifically mentions the Habitats 
Directive42 and the Water Framework Directive43 as key precursors.   

The  Marine  Strategy  Framework  Directive44 (2008)  came  into  force  a  year  after  the  Eel  Directive 
(2007).  The Marine Directive 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).  

JC 1.3: 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 

The Public Consultation (PC) results indicate some limited interest in the conservation status of the 
eel.    Of  the  160  respondents  to  the  PC  survey,  only  eight  (5%)  completed  the  section  for  non-
specialised respondents.   Of eight respondents who participated in the survey, only one indicated that 
they  had  never  heard  about  the  problem  of  the  decreasing  European  eel  population,  compared  to 
seven respondents who had.  

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.  

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

In summary, based upon the very limited non-specialist response, it is difficult to conclude the extent 
to which laypersons are aware and concerned about the status of European eel populations.  Indeed, 
the low response level may be an indicator in itself.   

42 Council  Directive  92/43/EEC  of  21  May  1992  on  the  conservation  of  natural  habitats  and  of  wild 
fauna and flora 
43 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 
44 Directive 2008/56/EC of 17 June 2008 

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Box 1: Public and Roadmap Consultation Results – Relevance 

Evaluation of the Eel Regulation 

To what extent are the existing measures for the recovery of European eel stock under 
the Eel Regulation still relevant? 
The PC results confirm that the objectives of the Eel Regulation are still highly relevant. 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 Member States to implement 
Eel  Management  Plans.  Between  eight  and  nine  in  ten  respondents  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;  

•  ensure that the origin and traceability of all live eels imported to and exported from MS;  
•  and regulate fishing effort and catches.  

Despite restocking being questioned as a key long-term measure, three quarters of PC respondents 
indicated that it remains appropriate to regulate the supply of glass eels for restocking operations. 
Two thirds agreed that there remains a need to ensure the 40% target of eel escapement to the 
sea. On the other hand, respondents were much less convinced that the overall aim of achieving 
the  40%  target  is  achievable  and  many  respondents  also  criticised  this  target  from  different 
perspectives.  The  least  supported  measure,  but  still  accepted  by  the  majority  of  respondents 
(57.9%), was to seek reduction in catching of eels to at least 50% of 2006 levels. 

The measures to  recover the population of eel in Europe were  widely supported by  respondents. 
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 
supported restocking. However, the results also suggest that the regulation should be amended or 
simplified (supported by two thirds of respondents) and that it needs alternative targets to ensure 
it delivers on its objectives (supported by three quarters of respondents).  

Suggestions for amendments included:  

• 
• 

• 

further restrictions of fishing and trade; generally reinforcing the regulation;  

setting targets related to reducing migration barriers, limiting hydropower mortality and 
recovery of migration routes and habitats; and 

the need of better understanding the problem (scientific research and monitoring).  

Setting alternative targets to reduce anthropogenic (but not related to fishing) mortality were also 
proposed in feedback received to the evaluation roadmap (submitted before the evaluation). These 
included: temporary shutdown of hydropower turbines, restoration of habitats, etc45. 

How relevant is the need for eel conservation and management to EU citizens? 
We received only eight contributions to the general survey of the PC, addressed to non-specialised 
respondents.46 This suggests that the awareness of and interest in the critical situation of the eel 
population is limited or the topic is simply too technical for the general public. We can hardly draw 
conclusions  on  the  basis  of  eight  contributions,  but  nonetheless  all  eight  respondents  supported 
actions by the EU to regulate eel fishing to ensure the recovery as well as most of the measures 
used, including facilitating migration, limiting fishing, and restocking. 

45 Feedback  received  on:  Evaluation  of  the  Eel  Regulation,  https://ec.europa.eu/info/law/better-regulation/initiatives/ares-
2018-1986447/feedback_en?p_id=223664. 
46 The PC was divided into two separate sections: a survey for experts and a survey for non-specialised respondents. The vast 
majority  of  respondents  contributed  to  the  experts’  survey  (152  contributions,  95%),  compared  to  just  eight  (5%)  for  the 
general survey. 

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Evaluation of the Eel Regulation 

 EFFECTIVENESS 

Effectiveness - Evaluation Question 2 

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

Data sources 

Analysis of Progress Reports; ICES reports; stakeholder consultations, case studies; EUROSTAT, 
CITES and other trade data; & EU and Member State control reports.    

JC 2.1: EMPs implemented and specific targets achieved 

Nineteen MSs have developed and implemented national EMPs, in addition to a joint plan for the Minho 
River, covering almost 90 Eel Management Units (EC, 2014a).  Six Member States 47 were exempted 
from the obligation to establish EMPs as their territory was deemed not to constitute significant eel 
habitat (Article 3).  Slovenia48, Croatia and Bulgaria have not yet prepared an EMP (EC, 2008a).  Some 
EMPs  have  been  developed  at  river  basin,  rather  than  national  level  e.g.  the  Spain  /  Portugal 
Transboundary Plan for Minho River and the UK.  It is noted, however, that only one transboundary 
EMP has been delivered to date, despite this requirement in Art. 6 of the Regulation.   

In 2018 the ICES Workshop on Evaluating Progress with Eel Management Plans (WKEMP) collated the 
data and information reported to EU as per the request from the Commission sent to MS on 5th April 
2018.  Reporting  by  MS  was  not  100%:  of  those  MS  with  EMPs;  Luxembourg  and  Portugal  did  not 
report at all, the Czech Republic, Finland and Ireland provided a description but no data tables, and 
France and Poland did not provide all seven data tables; the Czech Republic, Finland, Greece, Ireland, 
Latvia, Poland and Spain reported after the deadline.  

Progress in achieving implementation of management measures can be found in Table 3 (page 19) as 
well as in the earlier Relevance section.   

JC 2.2: European eel stock has not recovered 

Based upon the ICES Stock Annex (ICES, 2016) and the most recent Joint EIFAAC/ICES/GFCM Working 
Group  on  Eels  (WGEEL)  analyses  (ICES,  2018)  the  European  eel  stock  has  not  recovered  to  any 
significant degree since 2010, although the previous decline in recruitment and landings seem to have 
levelled out, albeit at historically low levels for the former.  As noted previously, it is clear that the 
recovery  of  the  European  eel  is  a  long-term  process  that  will  take  decades  rather  than  years  to 
progress 

JC 2.3: Non-fisheries anthropogenic mortalities have not been reduced 

Likewise,  with  fisheries  mortality  (see  JC 2.2  above),  non-fisheries  related  anthropogenic  mortality 
has  not  been  reduced  significantly  over  the  last  decade  (see  Figure  12  and  accompanying  text  for 
more  details).    The  Eel  Regulation  sets  an  ultimate  goal  (40%  of  B0),  which  translates  into  a  limit 
49.  ICES still 
mortality level ΣAlim (=0.92, i.e. 40%  survival), with lower limits when Bcurrent<40% B0
focus  on  biomass  and  recruit  abundance,  whilst  focusing  on  mortality  may  be  more  appropriate.  
Dekker (pers. comm., 18 January 2019) argues that ICES could have set a definite mortality limit, a 
sentiment echoed by the recent report to the European Parliament (Hanel, 2019).  Hanel states that 
by introducing a mortality target “general problems of a biomass-based approach like setting a uniform 
and proper baseline B0 or the common practice of meeting regional biomass targets solely by stocking 
eels  caught  elsewhere,  while  sustaining  or  even  increasing  anthropogenic  mortalities  (through 

47 Austria, Slovakia, Hungary, Romania, Cyprus, Malta 
48 Slovenia submitted a brief Progress Report in 2018 stating that because the European eel has been 
a protected species since 2004, the country should be exempt from the Eel Regulation. 
49 That  is  the  line  between  orange  and  red  in  Figure  11:  Modified  Precautionary  Diagram  for  Eel 
Management Units 

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Evaluation of the Eel Regulation 

hydropower and fisheries or by stocking in waters not suitable for eels (due to high pollution status, 
etc.) would be obsolete”.  This is further discussed overleaf in relation to the current 40% escapement 
target.   

Anthropogenic  mortalities  can  be  reduced  through  various  different  approaches  e.g.  improving 
upstream and downstream migration through the removal of barriers and reducing mortality within 
hydroelectric  installations.    Hanel  (2019)  examined  the  impact  of  measures  undertaken  in  France, 
Germany, Greece and Spain and noted that: 

• 

• 

• 

In France a number  of  habitat improvement actions have not been reported in the progress 
reports, especially when operating at local level.   

In Greece the Hellenic Eel Management Plan (HEMP) includes mid to long-term actions  with 
measures  targeting  the  improvement  and  upstream  and  downstream  migration.    The  main 
threat foreseen is the presence of weirs, culverts, fords and ramps, which are being constructed 
sometimes  without  proper  design  and  licencing,  fragmenting  the  rivers  prohibiting  the 
migration  of  all  fish  species  inhabiting  the  river.  For  this  reason,  the  HEMP  suggests  the 
development of technical interventions that will allow the free moving of the fish species. 

In  Spain,  a  decree  was  established  in  2015  obliging  electricity  companies  to  transport  eels 
upstream of their facilities (Decree 35/2013), so there has been a significant increase in the 
amounts  of  eels  transported,  ranging  between  678  and  1076  kg  for  the  2015-2017  period.  
Many dams have been removed and passes have been installed; however, available information 
does  not  allow  estimating  the  available  habitat  increase.  In  addition,  different  studies  to 
inventory and catalogue the dams have been carried out. 

Hanel  concludes  that  in  relation  to  habitat improvement  and  hydropower  issues,  the  measures  are 
often  defined  rather  vaguely,  probably  because  of  restricted  legal  competence  of  the  authorities 
responsible for the EMPs. 

JC 2.4: Adult eel escapement progressed towards the long term 40% escapement 
objective 

The management biomass reference limit of 40% of B0 for eel, a Category 3 species in the ICES Data-
Limited Species approach, is in line with the 40% maximum spawning potential (at F=0) reference 
point  (a  common  proxy  for  MSY)  advised  for  category  3  and  4  species  by  ICES  (ICES,  2016b).  As 
implicit in the Regulation, the target of 40% escapement of spawners (e.g. silver eels) is a key long-
term objective, although no definitive time period is specified.   

As noted by ICES (2018c) “as the scope for further reduction of fisheries mortality is decreasing and 
the relative impact of non-fisheries mortality has been shown to be correspondingly increasing, it may 
be  time  for  a  raised  focus  on  non-fisheries  impacts  on  eel.  The  goal  should  be  to  further  integrate 
these non-fishery impacts into the wider quantitative stock assessment”. 

A number of authorities argue that a move from the current 40% regional level escapement targets 
to a mortality-based target in a revised version of an EU Regulation, which would also be in better 
agreement with the current ICES advice (ICES, 2018a) for the species (“all anthropogenic mortalities 
should be reduced to as close to zero as possible”) (Hanel, 2019).  Such mortality-based targets will 
need  to  be  established  at  EMU  levels,  as  different  optimisation  strategies  need  to  be  adopted 
depending upon the different characteristics (e.g. natural, fisheries-related and non-fisheries related) 
of each river basin.  As noted by the Sustainable Eel Group (SEG) contribution to the PC, a move to 
mortality-based  targets  does  not  mean  any  change  in  targets  and  indicators  in  the  Eel  Regulation 
itself, but a better implementation of the existing ones.  

JC 2.5: Supply of glass eels not sufficient for restocking operations 

The Eel Regulation requires that at least 60% of glass eels caught in each Member State should be 
used for restocking (or translocation) within the EU. In 2008,  prior  to  the  inception  of  EMP’s  in  
2009,  twelve  countries  proposed  the  use  of stocking in their management plans to enhance eel 
populations  (ICES,  2008).  At  this  time  ICES  reported  on  a  perceived  stocking  requirement  of 
approximately 40t to fulfil reported EU needs. By 2013, stocking of glass eel was undertaken in 16 
Member States.   

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Evaluation of the Eel Regulation 

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 13 below). However, glass eel restocking has decreased since then. 

Figure 13: Reported production and restocking of glass eel not including those in 
quarantine by country (in millions) and as a proportion of production (%)  

Source: ICES, 2018b 

Whilst stocking is a measure that features in many EMPs, only six 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  EMU’s had undertaken a limited quantity of their  stocking 
targets  while  a  few  had  yet  to  implement  any  of  their  stocking  actions  (ICES,  2013b).    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 availability of glass eel for stocking was highlighted as being restrictive, 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 from tendering for Member State restocking programmes in advance.   

It is noted that the translocation of glass eels should be considered a short to medium term measure 
that  could  be  phased  out  if  natural  recruitment  and  spawner  escapement  were  improved.  
Translocation generally considered an inherently inefficient and short-term response to fisheries stock 
management and is also an expensive process that has to be paid mainly through the EMFF.   

JC 2.6: Fishing effort reduced by at least 50% relative to the average effort 2004-2006 or 
ensure reduction of catches by at least 50% 

Art. 8 (1) of the Eel Regulation requires that “Where a Member State operates a fishery in Community 
waters that catches eel, the Member State shall either reduce fishing effort by at least 50 % relative 
to the average effort deployed from 2004 to 2006 or reduce fishing effort to ensure a reduction of eel 
catches  by  at  least  50  %  relative  to  the  average  catch  from  2004  to  2006.  This  reduction  is  to  be 

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Evaluation of the Eel Regulation 

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

To date, there is no standardised reporting of capacity and fishing effort to accompany the landings 
data  requested  by  the  WGEEL  (ICES,  2018c).  Information  on  fishing effort  and  the  capacity  of  the 
fisheries, is necessary to correctly interpret the changes to the landings data over the years and the 
WGEEL  is  developing  approaches  to  include  and  analyse  fishing  effort  and  capacity  data  in  coming 
years.  However, Member States are required to submit fishing effort data in their Progress Reports, 
and the most recent results for the six top eel fishing Member States in the EU is summarised in the 
Figure overleaf (note that France did not submit effort data in 2018). 

United Kingdom 

Denmark 

Sweden 

Germany 

Italy 

Poland 

Figure 14: Fishing effort of the six major eel producers in the EU 

Source: Data extracted from Form 7 of ICES data call (ICES, 2018c). 

The figures above suggest that effort has declined in Sweden (by over 90%), Italy (just over 50%), 
Denmark (by almost 50%) and Germany (by 25%).  However, effort appears to have risen to 135% 
of 2008 levels in the UK50 and 180% of the 2012 level in Poland.  As mentioned previously, 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 (see Figure 2 and Figure 3 on page 4) where they 
are now broadly stable.   

50 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.   

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Evaluation of the Eel Regulation 

JC 2.7: Origin and traceability of all live eels imported and exported from MS territory 
maintained.  

Member States are required under Art. 12 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  (EC,  2010),  meaning  that  it  was  irrelevant  for  Member  States  to  establish  a 
traceability system for eels imported and exported from their territory. Member States had to ensure 
that the external trade prohibition was complied with, which for some Member States (e.g. ES, FR) 
require 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  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.   

JC 2.8: Control and enforcement activities in support of the implementation of the EMPs 
have taken place in EU waters (and national fresh water) and at all stages of the eel 
supply chain 

Analysis detailed in Section  4.4  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. 
However, control of eels fisheries is hindered by some shortcoming of 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 Member State to another 
to fulfil MS obligations for restocking or to provide livestock for aquaculture farms. 

However,  certain  Member  States  have  implemented  certain  good  practices,  defined  as  practices 
implemented at national level in the field of control that go beyond minimum EU requirements. This 
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). 

Nonetheless, weak eel traceability from “net to plate” appear to be a significant risk factor. However, 
it could be noted that some Member States (e.g. GR, IT and SE) have used the opportunity provided 
by Article 8.5 of Council Regulation (EC) N°338/9751 to involve their CITES management authorities 
in the national control system through national instruments (permit scheme in GR, CITES registries in 
IT and SE). 

Finally, the Commission recently introduced the Commission Implementing Decision (EU) 2018/198652 
which  includes  for  the  first  time  ever  eel  fisheries  in  the  scope  of  Specific  Control  and  Inspection 
Programmes (SCIPs) to be implemented by Member States under the operational coordination of the 
European Fisheries Control Agency (EFCA). 

51 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 
52 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 

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Effectiveness - Evaluation Question 3 

Evaluation of the Eel Regulation 

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 they hindered their achievement and how? 

Data sources 

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

JC 3.1: Identification of the key barriers to achieving the objectives 

A number of barriers to eel stock recovery exist including: 

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. 

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 t 
(e.g.  up  to  300  million  individuals53)  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 Member State, moved to another and then exported to Asia either 
directly or possibly via a neighbouring non-EU country, such as in North Africa (Outhwaite, W. 
and Brown, 2018).    

4.  Differing  levels  of  eel  management  through  the  EU.    In  Spain,  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  comprehensive  data:  despite  the  focus  of  the  joint  EIFAAC/ICES/GFCM  Working 
Group on Eel (WGEEL), as well as annual and periodic reporting requirements from Member 
States via the Eel Regulation, data provision and knowledge is highly variable across the EU.  
Only 75 EMUs (from a total of 116) submitted data to WGEEL in 2018 had data on both total 
fisheries mortality rates (ΣF) and total non-fishing mortalities rates (ΣH).This has consequences 
for the ability for installing harvest control rules and other eel conservation measures.   

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 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. The possibility of fund these measures has been eligible for support under the European 

53 Assuming 3,000 individuals per kg 

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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.   

In summary, as recently noted by WGEEL (ICES, 2018c), “The current focus on fishery-based control, 
with established frameworks for annual reporting of the activity could easily lead to a general view 
that this internationally agreed and structured process will eventually lead to stock recovery. However, 
this  is  at  the  risk  of  overlooking  the  remaining  large  list  of  other  factors  contributing  to  eel  stock 
decline. While taking immediate action to regulate and control eel fishing has been the obvious thing 
to do and an essential emergency first step to (hopefully) stabilising the situation and arresting decline, 
it is clear that eel stocks may not be recoverable to historical maxima by fishery management action 
alone. In addition, the scope for further fishery control/reduction will at some point be limited”. 

JC 3.2: Identification of the common and outstanding successes and resulting best 
practises that have allowed progress towards achieving the objectives 

Notwithstanding  the  above,  the  Eel  Regulation  has,  on  the  whole,  catalysed  the  approach  of  EU 
Member States to rebuild eel stocks.  There have been a number of notable successes, including: 

1.  Reduction in output and fishing effort.  As noted above, wild eel production declined rapidly 
from the 1990s to 2012 since it has stabilised. More significantly, fishing effort has reduced in 
most Member States, some reaching the 50% reduction target.  However effort in others, such 
as  the  UK  and  Poland,  seems  to  be  rising,  albeit  slowly.   It  is  likely  that  these  changes  are 
mainly  due  to  a  reduction  in  demand  from  mainstream  retailers  and  other  market  changes, 
rather  than  legal  restrictions  in  fishing,  although  this  may  change  in  the  future  as  fishing 
opportunities are increasingly restricted, especially in the Baltic and the Mediterranean.   

2.  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  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.  Italy 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 (see Italy Case Study in Annex 7).  In Italy, 
attempts to focus restocking efforts into protected waters, often using glass eels from the same 
watershed, it also thought to increase potential spawner numbers.  

3.  In  France  Agence  Française  de  la  Biodiversité  have  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. 

4.  Modelling periods for temporary switch-off of electric turbines : in the Loire region, 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 
supported  implementation  of  the  measure,  which  from  operators  perspective,  must  be 
implemented  only  when  necessary  due  to  the  high  associated  foregone  revenues.  Similar 
models are yet to be developed or adjusted for other EMUs. 

5.  Again  in  Italy  the  development  of  multi-stakeholder  platforms  in  the  preparation  of 
regional EMPs is considered a particular success. The process involved all relevant operators, 
including fishers, vallicoltura farmers and aquaculture operators and 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). 

6.  In the UK a series of best practice guidance has been produced, 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 

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Evaluation of the Eel Regulation 

populations  (Environment  Agency,  2011). 
from 
recommendations  made  at  a  workshop  of  experienced  practitioners,  bringing  together 
expertise, shared practical experiences and lessons that have been learnt so far. The Spanish 
have  also  produced  a  guidance  manual  around  five  thematic  lines  (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)  

  This  document  was  developed 

7.  Granting  restocking  financial  support  through  a  State  Aid  scheme  rather  than 
through EMFF: 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 Commission’s rules. 
These measures contributed to improve implementation of eel stock enhancement measures 
by professional organisations. 

8.  Improved  batch  traceability  in  Greece  has  been  achieved  through  their  ‘simple 
permitting  scheme’.    Α  national  system  for  controlling  intra-EU  trade  in  European  eel  is 
implemented  by  issuing  the  so-called  'simple  permits'.  With  these  simple  permits  from  /  to 
other  European  countries,  after  checking  all  the  relevant  documents,  imports  /  exports  are 
certified,  preventing  any  illegal  and  non-conforming  export  (in  other  EU  Member  States)  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 regional committee is present during all harvesting. For each harvest batch this 

committee issues 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 issues the so-called 

'simple permits' so the batch is permissible for intra-EU  trade. 

9.  Increased swiftness of catch declaration through an e-declaration system. The private 
sector Telecapêche electronic reporting and data processing platform was developed in France 
and  has  now  been  used  for  over  five  years  by  professional  fishermen,  mainly  in  France  but 
more recently on the River Parret in the UK. In the UK it allows the statutory administration to 
receive real-time catch declarations (via SMS) and has the potential to cover the entire supply 
chain. In France, Telecapêche does not have a legal basis and professional fishermen still have 
to comply with mandatory catch submission mechanisms based on declarations submitted on 
paper every two days (for glass eels) or monthly (for yellow and silver eels).   

In the main, most of these successes have been fisheries-focused.  Many are short-term gains e.g. 
reduction  in fishing  effort  and  output,  but  others  maybe  longer-term,  e.g.  fundamental  changes  in 
Member State 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.  

JC 3.3: Identification of best practices in transboundary areas 

The Interreg Sudoe Programme of the European Regional Development Fund is supporting a regional 
(France,  Portugal  and  Spain)  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 

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Evaluation of the Eel Regulation 

evidence  and  in  a  more  coordinated  fashion,  as  all  the  indicators will be  obtained  using  consensus 
models and methodologies among these participating partners 54.  

It is noted, however, only one transboundary EMP (between Spain and Portugal) has been delivered 
to date, despite this requirement in Art. 6 of the Regulation.  However, eel management issues are 
discussed within the framework of 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. 

JC 3.4: 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 

Supply chain traceability has increased as a result of actions taken at Member State level to ensure 
that  legally  caught  eels  are  accounted  for  via  statutory  reporting  as  well  as  through  voluntary 
mechanism  such  as  Sustainable  Eel  Group  (SEG)’s  Standard,  where  certified  fishers  must  be 
accompanied by audited supply chains using batch coded chain of custody approaches adopted from 
the Marine Stewardship Council (MSC), supported by IT-based “tele-declaration systems’.  However it 
is noted that the SEG standard says that it is preferable but not mandatory for certified fisheries to 
sell only to certified buyers.  This suggests that it is possible for certified suppliers to sell to uncertified 
buyers, thus ending the chain of custody.  Unlike other major certification schemes, there is limited 
multiple-retailer pressure to buy certified eels.   

This said, the intent of the Regulation (Art 12) to “take the measures necessary to identify the origin 
and ensure the traceability of all live eels imported or exported from their territory” has not been fully 
realised to date.  There is a need to better harmonise traceability systems, both within and especially 
between different Member States, to properly account for eel supply chain origin, volumes and final 
fate.  The EU Control Regulation55, combined with the IUU Regulation56, requires traceability for all 
species (inc. eel), but this is still far from an effective system, that need considerable improvement in 
its  implementation,  including  digitisation  and  other  methods  of  automated  mass  balance  analyses.  
This  therefore  requires  concerted  efforts  both  at  Member  State  levels  as    well  as  at  EU  level  to 
implement. 

One particular issue raised by stakeholders is that the species range of A. anguilla exceeds the borders 
of European Union and consequently eels of different origin cannot be distinguished by genetics.  SEG 
are managing an EMFF-funded project to determine the potential of otolith and tissue microchemistry 
for the traceability of glass eels which will end in May 2019.   

JC 3.5: Have the control & enforcement measures at MS levels been adequately resourced 
and implemented? 

France has a national system to trace all eel trade. Records are reported via the VISIOMER system 
to  the  French  authority  AGRIMER.    This  is  a  strictly  national  system  used  to  cross-check  landing 
declarations and its’ information has not been shared with other countries in order to trace the eel 
trade  beyond  the  national  borders.  Domestic  seizure  data  from  France  indicates  that  the  domestic 
control system seems to be quite effective (SEG, pers. comm., 17 January 2019). The Telecapêche 
electronic catch reporting system has been widely used in French POs. 

In the UK, fishermen and traders report their catch / shipments to the Environment Agency (EA), with 
data publicly available upon request at the finish of the fishing season every May.  During the last two 
fishing seasons, SEG, the EA and Manatee  Lab have implemented the Telecapêche electronic catch 

54  AZTI,  Institut  National  de  recherche  en  Sciences  et  Technologies  pour  l'environnement  et 
l'agriculture,  Universitat  de  Girona,  University  of  Córdoba,  Interdisciplinary  center  of  Investigação 
Marinha  E  Ambiental,  Institute  National  de  la  Recherche  Agronomique,  Universidade  de  Lisboa, 
Université de Perpignan Via Domitia, Agence Française pour la Biodiversité, Fundacion Lonxanet for 
sustainable fisheries 
55 Council Regulation (EC) No 1224/2009 of 20 November 2009 
56 Council Regulation (EC) No 1005/2008 of 29 September 2008 

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Evaluation of the Eel Regulation 

declaration system (on the River Parret) which allows real time monitoring of the catches. However 
the future of the pilot project is uncertain. 

In Spain, data on glass eel catches are reported on the level of the autonomous regions and collected 
and  merged  by  AZTI  Technology.  Reporting  seems  to  be  of  poor  quality  and  covers  a  smaller 
proportion of the real catches. 

In Portugal, glass eel fishing is prohibited except the Portuguese side of the Minho river (border with 
Spain). Poaching seems to be a huge problem across the entire Atlantic coast. According to SEG (pers. 
comm., 17 January 2019) reporting seems to be of poor quality and covers a smaller proportion of 
the real catches. 

In Greece improved batch traceability has been achieved through their ‘simple permitting scheme’.  
Α national system for controlling intra-EU  trade in European eel is implemented by issuing the so-
called 'simple permits'. With these simple permits from / to other European countries, after checking 
all the relevant documents, imports / exports are certified, preventing any illegal and non-conforming 
export (in other EU Member States) of such specimens. This mechanism is implemented by the Greek 
Regional Managing Authorities of the CITES Convention after consultation with the relevant Regional 
Fisheries Authorities. 

In  summary,  the  main  weakness  of  the  system  is  not  just  the  variable  ability  and  willingness  of 
Member States authorities to trace and track post-harvest eel movements but is also the lack of an 
EU-wide traceability system.   

Effectiveness - Evaluation Question 4 

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? 

Data sources 
Analysis of Progress Reports; ICES reports; stakeholder consultations, case studies; EUROSTAT, 
CITES and other trade data; & EU and Member State control reports.    

JC 4.1: Extent to which wild eel fisheries (i) safeguard stock reproduction for high long-
term yield, (ii) lay the foundations for a profitable industry and (iii) share out fishing 
opportunities fairly 

Safeguard stock reproduction for high long-term yield: as discussed previously, 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 Member States 
(see  above)  but  stock  recovery  is  a  long-term  goal  that  can  only  be  achieved  through  addressing 
spawner  escapement  through  habitat  rehabilitation  and  improved  connectivity.    As  recognised  by 
Dekker (2016) the objective of the Eel Regulation is alternately worded as either ‘the protection’ (e.g. 
Article  1)  or  ‘the  recovery’  (e.g.  the  title  of  the  Regulation)  of  the  stock  of  European  eel.  Whereas 
protection  can  be  achieved  immediately  and  by  each  management  area  independently,  recovery  is 
necessarily a long-term, global objective, outside the competence of individual management areas, 
and overshadowed by uncertainties about stock dynamics.  

Lay the foundations for a profitable industry: there is no doubt that some elements of the glass 
eel industry consider that the ban on the trade of EU caught eels outside of the EU has encouraged a 
parallel ‘black’ supply chain that 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  Greece  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.    

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Share out fishing opportunities fairly: the key issue is over legitimate versus IUU fishing.  Legal, 
licensed fisheries are mainly based on traditional, location 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. don’t have the costs of accountable businesses, often deal in cash and supply 
the high value Asian aquaculture market. One supplier mentioned that “Our French company has not 
made a profit for five years and our UK company made a substantial loss in 2016”.   

JC 4.2: Extent to which eel farming has developed in sustainable way to relieve pressure 
on wild stocks 

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 (Figure 15 
below). In 2017, the reported quantities of eels produced in aquaculture is 4,546 tonnes.  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  (around  10  million  eels,  making  a  mean  weight  of  20 g,  200  t).    The 
Netherlands (2,005 t in 2017) and Germany (1,202 t in 2017) are the main EU aquaculture producers.   

Reproduction of Anguilla 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, both legally 
in the EU and through illegal trafficking of glass eels to Asia, are still dependent upon glass eels and 
therefore  have  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. 
These risks were originally identified by WGEEL (ICES, 2008) and include deliberate/accidental spread 
of parasites, diseases, altering sex ratios, genetic and biological fitness.  It was noted that two of the 
four batches  of glass  eels imported to Sweden from France in 2017 were infected  with a virus and 
around 4 million glass eels were destroyed as a result.   

Figure 15: EU aquaculture production (2004 - 2017) 

Source: ICES, 2018c 

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Box 2: Public and Roadmap Consultation Results – Effectiveness 

Evaluation of the Eel Regulation 

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

The PC results confirm that the Eel Regulation process has been effective in that the Member States 
have developed EMPs (the majority of respondents agreed with this statement). The effectiveness 
in terms of achieving the targets set in those EMPs was rated low, as most respondents indicated 
that targets were not achieved.  

Respondents’ assessment of other achievements was ambiguous. A relative majority indicated that 
the regulation managed to increase the adult eels’ escapement to the sea towards the 40% target. 
Almost  equal  proportions  of  respondents  agreed  and  disagreed  that  the  regulation  managed  to 
ensure  a  reduction  in  anthropogenic  eel  mortalities.  The  majority  of  respondents  indicated  that 
other objectives remained not achieved, such as: 

•  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, 
•  ensuring control and enforcement activities at all stages of the eel supply chain. 

In an open-ended question, respondents highlighted achievements of the regulation. However, in 
most  responses  there  were  ‘indirect’  achievements,  such  as  raising  awareness  of  the  critical 
condition of the stock and other (reducing fishing effort, removing barriers to migration, improved 
control,  restocking  programmes,  implementation  of  EMPs).  Only  a  small  number  of  respondents 
mentioned direct achievements impacting the population (increased stock or reduced mortality).  

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 they hindered their achievement 
and how? 
The PC 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, 
rather  than  issues  with  the  legislation  itself  (19%).  In  feedback  to  the  evaluation  roadmap, 
hydropower  mortality  and  illegal  fishing  were  also  mentioned,  as  well  as  the  lack  of  traceability 
system, insufficient implementation of EMPs and oceanic factors57. 

 SUSTAINABILITY 

Sustainability - Evaluation Question 5 

Are the effects likely to last after the intervention ends? 

Data sources 

Analysis of Progress Reports; ICES reports; stakeholder consultations, case studies; EUROSTAT, 
CITES and other trade data; & EU and Member State control reports.    

JC 5.1: The extent to which measures implemented under the Eel Regulation have long-
term impacts, even if the intervention were to cease 

There is no ‘end date’ for the Eel Regulation, so it is considered indefinite, at least until the European 
eel stock has fully recovered. As frequently mentioned in this evaluation, the recovery of the European 
eel population is a long-term process, with some Member States  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 
revised sustainable management plan put in place.  In the meantime the regular progress reports as 
required in the Regulation should be continued.    

57 Feedback  received  on:  Evaluation  of  the  Eel  Regulation,  https://ec.europa.eu/info/law/better-regulation/initiatives/ares-
2018-1986447/feedback_en?p_id=223664.  

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Reducing  commercial  fishing  activity  (e.g.  reducing  fishing  effort  to  50%  of  the  2004  –  2006 
average) may have a long-term impact on fishing mortality.  The risk is that IUU fishing, which by 
definition is unregulated and uncontrolled may sustain some level of fishing mortality which is both 
difficult  to  assess  and  may  have  implications  for  stock  recovery  and  thus  sustainability  of  the 
intervention.   

Recreational  /  non-commercial  fishing  is  the  capture  or  attempted  capture  of  living  aquatic 
resources mainly for leisure and/or personal consumption. Recreational and non-commercial fishery 
covers  active  fishing  methods  including  rod  &  line,  spear,  and  hand-gathering  and  passive  fishing 
methods including nets, traps, pots, and setlines. Recreational fisheries for glass eel used to exist in 
France  and  Spain  but  have  been  forbidden  in  France  since  2010.    Ireland  and  Sweden  also  ban 
recreational fisheries.  Recreational landings were estimated as 2 t for glass eel in 2018, and 161 t for 
yellow  and  silver  eel  combined  in  2017  (ICES,  2018c).    The  main  countries  with  recreational  eel 
fisheries are Germany and Denmark.   

Figure 16: Recreational eel catches in the EU (2005 - 2017) 

Source: ICES, 2018c 

Overall,  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 France,  Ireland and Sweden 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. 
Since recreational fishery is mainly directed towards yellow eel, the measures will likely have only a 
weak immediate effect and a larger delayed effect, at least if the measures are designed properly and 
result in a real reduction of fishing mortality. 

As discussed earlier, restocking is a short to medium term measure that should be phased out as 
natural  recruitment  improves,  and  water  course  connectivity  is  improved.    Translocation  of  eels, 
although effective in maintaining or supporting eel populations in compromised river systems, is an 
expensive  and  often  administratively  burdensome  process.    The  outcome  of  stocking  has  been 
evaluated  by  ICES  in  2006,  2008,  2009  and  2011  from  WGEEL  reports  and  it  was  clear  from  local 
studies that stocking had been beneficial by enhancing the yellow and silver eel stocks in a number of 
water  bodies  (Pawson,  2012;  ICES,  2016c).  These  included  several  Danish,  German,  Swedish  and 
Estonian Lakes, Lough Neagh in Northern Ireland as well as Danish streams and marine areas.  

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Evaluation of the Eel Regulation 

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 Eel Management Plans (applying stocking to achieve EMP biomass 

targets); 

•  the continent-wide scale (stocking contributing to the general recovery of the stock). 

However as noted by ICES (2016c) the studies on the effectiveness of restocking lack controls and/or 
a simultaneous assessment of the life history of those glass eel left in situ. This in effect means that, 
whilst  a  local  benefit  may  be  apparent,  an  assessment  of  net  benefit  to  the  wider  eel  stock  is 
unquantifiable.  As  Dekker  &  Beaulaton  (2016)  noted,  as  successful  as  restocking  might  have  been 
locally, it has not markedly changed the overall trends and distribution patterns or halted the general 
decline of the stock and fishery.  However it is noted that freshwater eel production in countries like 
Sweden is almost entirely dependent upon artificial stocking.   

Ultimately the success of a stocking programme will be judged on the ability of resultant silver eels to 
contribute  to  future  generations.  Whilst  concerns  over  the  negotiation  of  migratory  pathways  have 
been reduced, the contribution of translocated silver eel is still not quantifiable and is limited by the 
lack of knowledge on the spawning of any eel.   

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 both 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 process knowledge are required.  

Box 3: Public and Roadmap Consultation Results – Sustainability  

Are the effects likely to last after the intervention ends? 

Opinions  about  the  sustainability  of  the  effects  of  the  Eel  Regulation  presented  in  the  PC  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. 

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Evaluation of the Eel Regulation 

 EFFICIENCY 

Efficiency - Evaluation Question 6 

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? 

Data sources 

Targeted stakeholder consultations, Case studies & EMFF funding records (inc. recent FAME 
reports). 

JC 6.1: 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 

A monetarised analysis of the cost-benefits of the Eel Regulation is impossible to quantify at this stage, 
as Member States 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 (SEG, 2018) 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 2 
and banned for extra-EU export has impacted on the sustainability of traditional, licensed eel fisheries.   

Feedback from the Member States 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 Member States functions such as restocking maybe outsourced to the private sector.   

Efficiency - Evaluation Question 7 

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

Data sources 

Targeted stakeholder consultations; & Case studies.   

JC 7.1: The extent to which alternative options exist and an assessment of their relative 
cost-effectiveness and contribution to the objectives of the Regulation 

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

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This said, a number of improvements to the Regulation were suggested by a number of stakeholders.  
These are summarised below. 

Evaluation of the Eel Regulation 

•  A proportionate focus on Member States with significant glass eel (FR, UK, ES & PT) 
and yellow and silver eel (FR, UK, DK, SE, IT, PL, NL, ES & EL) production for fisheries 
measures, with a less rigorous approach to Member States with no or very little productivity.  
This proportionate approach could also be carried over into national planning, to ensure that 
the more productive (existing and potential) EMUs are the focus of national actions.   

•  Greater  emphasis  on  transboundary  collaboration,  both  within  and  adjacent  to  the 
EU.    The  shortage  of  transboundary  EMPs  as  required  by  the  Regulation  is  a  considerable 
concern,  especially  given  the  transboundary  connectivity  between  in  the  Baltic  Sea  and 
between France and Spain (in the Bay of Biscay and the Mediterranean).  This also suggests 
regional initiatives such as the GFCM Multiannual Mediterranean Management Plan, including 
an  EU  Tunisia  (and  Algeria)  multi-annual  management  plan  for  fishing  activities  catching 
European eel in the Mediterranean Sea58.  

•  Greater pressure on Member States to fulfil the Regulation in its entirety. As discussed 
earlier, the EMPs vary in quality and fitness for purpose.  This has resulted in the partial rates 
in implementation to date and the variability in responses to progress reporting requirements 
and data calls (both by the EU and ICES).   

•  Greater focus on the non-fisheries anthropogenic causes of mortality and recruitment 
impairment.  The  current  Regulation,  whilst  including  this  aspect  to  some  extent,  is  more 
dedicated to reducing fishing mortality and this is reflected in the EMPs.   As noted by ICES 
(2018c) “as the scope for further reduction of fisheries mortality is decreasing and the relative 
impact of non-fisheries mortality has been shown to be correspondingly increasing, it may be 
time for a raised focus on non-fisheries impacts on eel ”. 

•  More specific timelines and interim targets across the Regulation. Whilst recognised as 
a long-term approach, the Regulation Is not time-bound. There are good reasons for this, but 
many stakeholders have asked that interim targets are developed and the progress towards 
this monitored.  Some MS have adopted timebound targets (e.g. interim escapement targets 
in  some  Italian  EMUs)  but  in  others  most  plans  are  made  on  more  vague  timescales.    It  is 
important  that  such  interim  targets  not  only  cover  fisheries-related  mortality,  but  also  non-
fisheries related mortality and proxy indicators (e.g. improved connectivity of rivers).  As noted 
by Dekker (2016), this may require re-focusing all protective actions, assessments, evaluations 
and  advice  on  anthropogenic  mortality  goals  and  indicators—  considering  each  of  the 
management areas (countries) individually.   

•  This could feed into the preparation of a wider strategic plan to scrutinise and consolidate 
existing assessments and management plans, and to expand their spatial coverage, ultimately 
striving  towards  full  geographical  coverage  of  the  whole  European  eel  population.  This  plan 
would need to be based upon the progress made in scientific understanding (mainly via the 
joint WGEEL) as well as a comprehensive stakeholder consultation process.  It may also need 
to include reviews of the pristine eel biomass (B0) and related escapement targets.  It is noted 
that  ICES  produced  guidance  on  European  eel  management  measures  that  can  be 
applied to both EU and non-EU waters in 2014 (ICES, 2014).   

•  Allied to the point above, there is a need for a central coordinating body for the recovery 
of the European Eel. The Eel Regulation provides a united approach across the EU, but the 
core issue of stock recovery needs a stock range wide approach.  One stakeholder mentioned 
the North Atlantic Salmon Conservation Organisation (NASCO) as a possible model.   

•  Improvements to the traceability requirements of the Regulation to ensure that all eel 
harvest and distribution is traceable, including across EU borders.  In the event of the UK -  a 
key glass eel supplier to many other EU restocking programmes - leaving the EU,  mechanisms 
should be in place to account for the UK’s new status as an exporter to the EU.   

58 42nd Session of the GFCM-FAO headquarters, Rome, Italy, 22–26 October 2018 

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•  A more cohesive funding approach for EMP and associated measures.  Few MS provide 
budgets for implementing their EMPs (EC, 2018a) to cover such aspects as restocking costs 
and habitat improvement projects.  This should include the role of the EMFF and other EU public 
funding,  the  role  of  the  private  sector  and  possibly  development  of  specialist  Financial 
Instruments to fund long-term eel conservation and management.  This suggests that the Eel 
Regulation  and  its  measures  should  be  specifically  reflected  in  MS  EMFF  operational 
programmes for the next funding period (2021 – 2027).   

Efficiency - Evaluation Question 8 

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

Data sources 

Member State Progress Reports & ICES WKEMP analyses 

JC 8.1: The extent to which the tri-annual Member State reporting system works in terms 
of timeliness and sufficiency 

In 2012 eighteen of the nineteen countries with EMPs produced progress reports.  Only six countries 
provided all the stock indicators required in Article 9 of 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.    ICES  issued  a  request  for  Stock  Indicator  data  in 
February 2013 at the ICES Data Call. This request was sent to national delegates of ICES countries 
and ICES Advisory Committee ( ACOM) representatives. The reason for making the request was to 
seek the most-up-to-date information on stock indicators in order to ensure that stock assessments 
performed  by  ICES  were  based  on  the  best  available  and  most  complete  dataset.  Not  all  relevant 
contacts in the countries received the Data Call and some countries are not members of ICES.   

In 2015 it is understood that fourteen of the 19 MS submitted progress reports (HR, CZ, EE, LU and 
ES failed to report).  ICES was not asked to review the EMPs for this round of reporting.   

In  2018  the  Commission  changed  their  approach  by  providing  Member  States  (on  5th  April 2018) 
with seven Excel templates as follows: 

Table 1: Overview of stock indicators by EMU 
Table 2: Biomass indicators 
Table 3: Mortalities quantities 
Table 4: Mortality rates 
Table 5: Stocking 
Table 6: Management measures 
Table 7: Fishing effort 

The completion of these templates  was highly recommended but not  compulsory.   WKEMP collated 
the data and information reported to EU  . Reporting by MS was not 100% (see Table 6 below). Of 
those MS with EMPs; Luxembourg and Portugal did not report at all, the Czech Republic, Finland and 
Ireland provided a description but no data tables, and France and Poland did not provide all seven 
data tables; the Czech Republic, Finland, Greece, Ireland, Latvia, Poland and Spain reported after the 
deadline.  

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Table 6: Summary of Member States reporting in their 2018 EMP Progress Reports 

Evaluation of the Eel Regulation 

Data Tables   1-7 

Description of 
the Methodology 

Comment 

Y 

Member 
State 

Belgium  
Czech 
Republic  
Denmark  
Estonia  
Finland  

N 
Y 
Y 
N 
Y, missing Tables 
3, 7 
Y 
Y 
N 
Y 
Y 
Y 
N 
Y 
Y, missing Table 3 
N 
Y 
Y 
Y 

France  
Germany  
Greece  
Ireland  
Italy  
Latvia  
Lithuania  
Luxembourg  
Netherlands  
Poland  
Portugal  
Spain  
Sweden 
UK 
Source: ICES, 2018d.   

Y 

Y 
Y 
Y 
Y 

Y 
Y 
Y 
Y 
Y 
Y 
Y 
N 
Y 
Y 
N 
N 
N 
Y 

Reported late 4/7/18  

Reported late 5/7/18  

Reported late 11/7/18  
Reported late 13/11/18  

Reported late 2/7/18  

Did not report  

Reported late 2/7/18  
Did not report  
Reported late 

Austria, Cyprus, Hungary, Malta, Romania and Slovakia are exempted from preparing EMPs. WKEMP 
also used data and information reported to the EU in 2015, to ICES in response to the 2018 data call, 
Country Reports provided to ICES for the annual meetings of the joint EIFAAC/ICES/GFCM Working 
Group on Eel (WGEEL), and data and information provided directly to WKEMP. WKEMP’s gap analysis 
excludes those EU MS given derogations from implementing EMPs because natural recruitment was 
considered to be very low in the past.  Based on the 2018 return, ICES (2018d) recommended that: 

1.  Reporting format and content should be obligatory rather than voluntary to ensure 

consistent and comparable information is available from which to judge the state of biomass 
and mortality rates. 

2.  It would reduce the burden on MS if the reporting requests from DG MARE, ICES and 

others could be coordinated and combined. 

3.  While submitting the information in Excel spreadsheets is an improvement over submitting in 

paper form or in Word files, data verification, compilation and analysis would be 
greatly facilitated if the data were input in a database by MS and verified by 
knowledgeable personnel before being added to the database. WKEMP understood that 
WGEEL is developing this approach and recommended that all support is provided to make 
this happen. 

5  All data and methods used to estimate all biomass and mortality rates should be 

fully documented and available in a single location. ICES could act as a depository via 
the WGEEL page. 

6  The treatment of restocking in all estimates of biomass and mortality must be 

clearly described. 

7  The Habitats Assessed part of the Overview Table should include the option to record 

Not Applicable for when a habitat type is not assessed because it does not exist in the EMU. 

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Box 4: Public and Roadmap Consultation Results – Efficiency   

Evaluation of the Eel Regulation 

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? 

The  PC  results  confirm  the  difficulty  to  measure  cost-effectiveness  of  the  Eel  Regulation  and  its 
implementation at the  national level. In general, opinions on efficiency were ambiguous but  also 
many respondents selected either “neither agree nor disagree” or “don’t’ know” answers.  As regards 
proportionality of the costs of administrating and implementing the regulation to the environmental 
and  socio-economic  benefits  that  the  regulation  has  generated,  slightly  more  than  one  third  of 
respondents  assessed  them  as  not  proportionate.  More  than  four  in  six  respondents  selected 
“neither agree nor disagree” or “don’t know” answers. Out of the remaining respondents, similar 
proportions  agreed  and  disagree  that  the  same  or  better  result in  terms  of  stock  recovery  could 
have  been  achieved  at  lower  costs.  Most  respondents  were  not  able  to  assess  whether  the 
administration  and  implementation  of  the  regulation  had  been  carried  out  at  the  lowest  possible 
cost. 

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

In  the  PC  most  of  the  respondents  were  not  able  to  assess  the  efficiency  of  the  regulation  in 
comparison with other policy instruments or mechanisms (the majority indicated that they “didn’t 
know”). Out of the remaining respondents, most disagreed that other instruments provided better 
cost-effectiveness. 

 COHERENCE 

Coherence - Evaluation Question 9 

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)? 

Data sources 

Desk research, with some stakeholder consultation.    

JC 9.1: The extent to which wider fisheries and environmental policies remain coherent 
with the objectives and measures under the Eel Regulation 

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  2015  and  at  the  latest  2020.  The  Eel  Regulation  sets  an 
escapement biomass target of 40% of the spawning biomass, which is considered a proxy for MSY. 
Whether  this  target  is  achievable  across  all  Member  States  by  2020  is  unlikely  and  there  are 
considerable difficulties in applying the MSY approach to catadromous species such as the European 
eel. 

The  CFP  quota  regulations  (2018/210)  set  no  TAC  or  quota  for  eels  but  does  prohibit  fishing  for  a 
consecutive three-month period to protect spawners during migrations.  This is relevant to spawning 
biomass of eels, so works cohesively with the 40% escapement target set in the eel regulation. 

The Water Framework Directive (WFD) serves to ensure the ‘good status’ of eel aquatic habitats in 
coastal,  transitional  and  inland  surface  waters  across  a  range  of  ecological  and  chemical  quality 
indicators. A range of monitoring parameters are required to ensure Member States reach good status, 
together with requirement to establish management plans, e.g. river basin management.   While the 
WFD framework is considered fit for purpose, significant effort is required to meet good ecological and 
chemical status across European surface waters. Furthermore, there is scope to improve connectivity 
between  River  Basin  Management  Plans  and  EMPs,  and  the  authorities  tasked  with  their  delivery, 
including  harmonisation  and  prioritisation  of  measures,  specifically  around  hydro-morphological 
pressures. 

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The Marine Strategy Framework Directive (MSFD) aims to achieve or  maintain good  environmental 
status of marine waters by 2020 by adopting an ecosystem-based approach to management that is 
implemented  through  a  common  regional  approach.    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). 

The Habitats Directive provides for two eel-related habitat types  - estuaries and coastal lagoons –to 
be designated as a ‘Special Area of Conservation’ (SAC).  However A. anguilla is not listed as a species 
within  the  species  Annexes,  including  both  the  original  Directive  (22  June  1992)  and  consolidated 
version of the Annexes (01 June 2013).   

Coherence - Evaluation Question 10 

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

Data sources 

Desk study; and Targeted stakeholder consultations e.g. with TRAFFIC, CITES.    

JC 10.1: 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) 

CITES: 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 (Council of the European Union, 1996), which is the equivalent of 
the CITES Appendix II.  See Section 4.7.2 for more details on the European eel and CITES.  

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  bloc.  
This is a critical point, as full traceability across EU borders is essential (see JC 3.4 and 3.5) CITES 
regulates trade through a system of permits, requiring export permits for trade in CITES Appendix II 
specimens. 

In 2015 ICES provided in response to a request from the European Commission to provide scientific 
information and advice on criteria (such as stock indicators), scales and possible conditions that could 
be used to make a CITES non-detriment finding (ICES, 2015). 

In summary, the Eel Regulation and CITES are closely connected and are complementary.  Due to the 
probable high volumes of illegal trade in glass eels, it is difficult to assess what impact this IUU fishing 
mortality has had on the recovery of the European eel stock. 

CMS: the addition in 2014 of the European eel to Appendix II of the Convention on Migratory Species 
(CMS)  is  important  because  it  requires  the  EU  and  other  CMS  parties  to  endeavour  to  agree 
cooperative  conservation  actions  among  Range  States.    With  the  exception  of  Iceland,  Turkey  and 
Russia, all countries within the range of Anguilla are CMS parties.  Given the need – and emphasis of 
the Regulation on, transboundary cooperation, the CMS is fully coherence with the Regulation.  This 
said, further  action needs to be undertaken to take advantage  of this convention  and to ensure it 
contributes to improving the conservation status of the European eel and its management.  In practical 
terms  this  means  the  development  of  an  appropriate  instrument,  whether  in  the  form  of  a  legally 
binding agreement or in the form of any other solution already in existence among the large of CMS 
family of instruments.     

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Box 5: Public and Roadmap Consultation Results – Coherence    

Evaluation of the Eel Regulation 

In contrast with our own analysis, the PC results may suggest that there is an issue with coherence 
of the Eel Regulation, in particular regarding international instruments to regulate fisheries. Most 
respondents disagreed that the regulation was coherent with international instruments or with other 
EU instruments. However, the proportion of respondents who indicated that they “neither agreed 
nor disagreed” and “didn’t know” exceeded one third in both cases. This shows that it is difficult to 
assess  the  coherence  of  the  regulation.  In  their  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). 

 EU ADDED VALUE 

EU added value - Evaluation Question 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? 

Data sources 

PC, Targeted consultations, &  

Case studies 

JC 11.1: Extent that the Eel Regulation has provided additional impetus / support to 
address eel conservation objectives 

Traditionally eel fisheries throughout Europe have been managed as freshwater fisheries  on a very 
local scale (Dekker, 2016).  Deelder (1970) describes a number of approaches to eel management at 
the  time,  including  minimum  legal  sizes,  closed  seasons,  restocking,  restricted  licensing,  gear 
restrictions,  and  more.  Since  the  early  1970s,  the  European  Inland  Fisheries  Advisory  Commission 
(EIFAC59, 1971) and  ICES (ICES, 1976)  organised a standing Eel Working Group, to document the 
status of the stock and to investigate potential mitigation measures. Although this group eventually 
discussed the need for continent-wide protection in the 1990s, its recommendations primarily focused 
on national or even localised protective measures.  Meeting regularly from 2001,  WGEEL started as 
the EIFAC / ICES WG in 1994, with GFCM joining in 2014.   

Following multi-decadal decline of the European eel stock across Europe, the EU adopted a regulation 
to put in place measures for the protection and recovery of this complex panmictic species in 2007.  
The  Eel  Regulation  requires  Member  States  (MSs)  to  address  common  objectives  and  uniform 
reference  points.  An  international  evaluation  process  was  developed  but  the  design  and 
implementation of protective actions and monitoring were delegated to the Member States. 

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

•  The preparation of Eel Management Plans for 19 Member States (Member States where river 
basins or maritime waters lying within its territory do not constitute natural habitats for the 
European eel were able to obtain derogation e.g. AT, BG, CY, HU, MT, RO, SI & SK.  Some of 
these  are  at  national  level,  whilst  others  have  separate  EMPs  for  different  Eel  Management 
Units (EMUs) (see Table 3) for more details).   

•  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.  This required estimates of the pristine biomass (B0) for each river basin. 

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

59 EIFAC, established in 1957, became EIFAAC in 2008 

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•  Development of management measures based around eight different approaches (see Art. 

2 (8) with associated timescales).   

•  Development  of  transboundary  EMPs  with  both  other  Member  States  as  well  as  with 
relevant third countries.  However, to date only one transboundary EMP (between Spain and 
Portugal) has been prepared.   

•  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 (inc. catch monitoring) mechanisms. 
•  A 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 Member States.  It has also brought managers in together 
from different regions and organisations within Member States to develop the plans and associated 
measures.    For  instance  the  EMP  development  process  in  Italy  has  been  highly  participatory  (see 
Section 4.2) and has resulted in some comprehensive documents on best practises from the UK and 
Spain.    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 the recently started (March 2018)  SUDOANG project that aims to 
provide managers with tools and joint methods that support the conservation of the European eel and 
its habitat in the SUDOE area and is being funded under the under the priority axis “Protecting the 
environment and promoting resource efficiency” of the Interreg SUDOE programme in SW Europe.  As 
discussed earlier, 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)).   

Finally the Regulation has raised awareness of the need for conserving and managing European eels 
throughout its range. 

JC 11.2: Extent that it is possible to isolate results and outcomes that could or would not 
have been otherwise achieved without the Eel Regulation 

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 (esp. the WFD) and the CITES listing.  All of these will have contributed to the impacts so 
far e.g. the overall reduction in fishing pressure and the stabilisation of landings.  

The WFD is expected to deliver a range benefits associated with improved water quality, ecological 
and chemical status of surface waters (e.g. lakes, rivers, coastal waters), including improving river 
continuity. These are expected to benefit a range of migratory species including eel, salmon, sturgeon 
etc.    However,  isolating  the  outcomes  of  measures  implemented  via  WFD  specifically  for  individual 
species (i.e. eel) is challenging and not currently documented within progress assessments for River 
Basin Management cycles. 

EU added value - Evaluation Question 12 

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

Data sources 

PC, Targeted consultations, & Case studies.    

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Evaluation of the Eel Regulation 

JC 12.1: Extent that MS authorities are able to identify positive and negative implications 
of stopping the application of the measures as regulated in the 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 therefore consider 
this to be a permanent process that needs to be continued to be effective. No Member States contacted 
indicated that they thought the Regulation was ineffective – indeed most voiced their support for the 
Regulation and its continued relevance.   

At  present  the  only  major  change  in  the  MS  participation  in  the  Regulation  is  that  of  the  United 
Kingdom in the event of their exit 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 under provision within the UK Withdrawal Act (Defra, pers. comm., 16 
January 2019).  This might mean that the measures and activities would be continued on a local basis, 
but some of the EU progress reporting may be discontinued. However we understand the intention is 
to continue to work with DG Mare and the joint EIFAAC/ICES/GFCM WGEEL WG, including responding 
to  any  related  data  calls  they  might  make,  and  continue  to  participate  in  management  of  this 
widespread stock.  In such an event it is likely that there will not be any major consequences in terms 
of rates and timescales of European eel recovery as intended through the Regulation, although the 
movement of glass eels between the UK and the EU may not continue, depending upon the final EU 
exit agreement reached.   

The impact of one or more Member State stop applying the measures from the Regulation depends 
on  which  one  and  their  territory’s  particular  contribution  to  the  European  eel  stock.    For  instance 
France 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 
panmictic stock.   

Box 6: Public and Roadmap Consultation Results – EU Added value    

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? 

According to PC respondents, it is clear that the Eel Regulation provided additional added value to 
what could be achieved by Member States at the national or regional levels in terms of recovering 
the  eel  population.  More  than  three  quarters  of  respondents  valued  the  EU  intervention  (most 
“strongly agreed” with the statement that the Eel Regulation provided additional value), compared 
with only 7.9% who did not. 

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

Respondents to the PC were asked 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  Member  States  will  no  longer  implement 
protective measures. One in ten respondents mentioned positive consequences, for instance fishing 
no longer being limited. 

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6.0 CONCLUSIONS AND RECOMMENDATIONS  

Evaluation of the Eel Regulation 

 RELEVANCE 

6.1.1 What is, or is not, working and the lessons learned  
The Eel Regulation is still highly relevant. The latest ICES advice (November 2018) states that 
“the  status  of  eel  remains  critical”  and  that  that  “when  the  precautionary  approach  is  applied  for 
European  eel, all anthropogenic impacts (e.g.  caused by  recreational  and commercial  fishing on all 
stages,  hydropower,  pumping  stations,  and  pollution)  that  decrease  production  and  escapement  of 
silver  eels  should  be  reduced  to  –  or  kept  as  close  to  –  zero  as  possible  in  2019”  (ICES,  2018a).  
Analysis  from  ICES  also  suggests  that  that  in  2017  the  spawner  (silver  eel)  escapement  from  the 
majority  of  EMUs  in  the  EU  was  below  the  40%  level  and  serves  to    emphasise  that  silver  eel 
escapement levels from the majority of EMUs is still below the 40% escapement reference point (ICES, 
(2018c). 

As a reflection of the Regulation’s predominant focus on reducing fisheries-related mortality, some 
progress has been made in reducing fishing effort and meeting the goal to reduce fishing 
effort by at least 50% relative to the average effort deployed from 2004 to 2006 (or reduce fishing 
effort to ensure a reduction of eel catches by at least 50 % relative to the average catch from 2004 
to 2006).  Since the Regulation was published, fishing effort has declined in Sweden (by over 90%), 
Italy (just over 50%), Denmark (by almost 50%) and Germany (by 25%).  However effort appears to 
have  risen  to  135%  of  2008  levels  in  the  UK  and  180%  of  the  2012  level  in  Poland.    Therefore 
continued focus on reducing fishing mortality to sustainable limits is still required.   

The long-term use of restocking as a key measure is questioned, other than as 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).   

Non-fisheries  related anthropogenic mortality has not declined significantly over the  last 
decade. There is a case to be made that the Regulation focuses too much on fisheries-related 
measures and targets.  As noted by ICES (2018c) “as the scope for further reduction of fisheries 
mortality  is  decreasing  and  the  relative  impact  of  non-fisheries  mortality  has  been  shown  to  be 
correspondingly increasing, it may be time for a raised focus on non-fisheries impacts on eel”. This 
suggests that future emphasis should be put on addressing the non-fisheries anthropogenic 
sources of mortality, supported by any necessary research and financial assistance.  Hanel 
(2019) suggests that such efforts should be focused on the lower reaches of rivers where the silver 
eel runs are concentrated60.  The WFD and the Habitats Directive both preceded the Eel Regulation 
and are broadly supportive and coherent.   

6.1.2 Future needs and recommendations  

Recommendations 

EU-specific   

Wider actions 

•  EMPs are developed at EMU-level in all 

•  Internationally coordinated research is 

Member States unless credible evidence 
exists that multiple-EMU plans are justified.   

•  Glass eel stocking, esp. that supported by 
EMFF and other public funds, needs to be 
better justified in terms of its net benefit to 
silver eel escapement.   

required to determine any net benefit of 
restocking on the overall population, 
including carrying capacity estimates of glass 
eel source estuaries, detailed mortality 
estimates at each step of the stocking 
process, and performance estimates of 
stocked vs. non-stocked eels. 

60 Hanel states that in France and Spain, 60% of the national silver eel run is affected by hydropower 
plants located within 250 km from the sea. At this distance, only 25% of total hydropower plants are 
found. 

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Evaluation of the Eel Regulation 

Recommendations 

EU-specific   
•  The European eel could be better used as 

indicator of ecological status in the 
implementation of the WFD.   

•  Increased research and monitoring to better 

Wider actions 
•  The current poor status of the European eel 
needs to be better publicised so that greater 
public pressure can be applied to improve 
eel management and water basin conditions.   

understand why eel stocks are not 
recovering.   

   EFFECTIVENESS 

6.2.1 What is, or is not, working and the lessons learned  
The  Eel  Regulation  process  has  been  effective  in  that  the  key  EU  Member  States  have 
developed  comprehensive  EMPs  and  these  are  being  reported  upon  and  the  results  of  this 
monitoring evaluated in detail.   

An overwhelming sentiment from the majority of stakeholder respondents is that the recovery  of 
the European eel will take many decades.  Whilst the Regulation has catalysed a wide range of 
actions at Member State level, the fact is that the European eel stock is still in a critical condition and 
whilst its decline appears to have been stabilised, it is still at a historical low.  It is also apparent 
that measures and actions have to be specified at EMU rather than national level, as they 
differ in terms of ecological status, connectivity  and  anthropogenic  activity.    The  fact  that 
only five EU MS (Germany, Spain, Ireland, Italy (9/20 EMUs) and the UK) have EMPs that operate at 
EMU level is a concern.   

However, the Regulation’s effectiveness in terms of ensuring the recovery of the European 
eel is still far from certain and as remarked above, it is still very much early days.  Overall fishing 
effort has reduced, albeit not in all Member States, and catches of yellow and silver eels has declined, 
although reported glass eel catches are steadily increasing.  There is also likely to be considerable un-
observed  and  un-estimated  glass  eel  mortality  through  IUU  fishing in  EU  waters,  which  is  partially 
enabled by the poor level of traceability across the EU.   

The Eel Regulation sets an ultimate goal (40% of B0) for silver eel escapement.  ICES still focus on 
biomass and recruit abundance, whilst focusing on mortality may be more appropriate.  Dekker (pers. 
comm.,  18  January  2019)  argues  that  ICES  could  set  a  definite  mortality  limits  to  assist 
implementation of the Eel Regulation, a sentiment echoed by the recent report to the European 
Parliament (Hanel, 2019).   

Whilst stocking is a measure featuring in many EMPs, only six achieved their EMP stocking target 
(ICES, 2016c).  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.   ICES 
(2018a) suggests that stocking should take place only where survival to silver eel escapement is high 
and should not be used as an alternative to reduce anthropogenic mortality. 

There have been some success stories, including the generation of good practices in relation to 
addressing  both  fisheries  and  non-fisheries  mortalities,  as  well  as  improving  the  traceability  of 
European eel production (see Section 4.2).   

Member  State  estimations  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).    This  echoes  the  earlier  conclusion  (see  previous  section)  that  future  eel 
conservation efforts should more focus on reducing non-fisheries anthropogenic mortality.  
One of the current constraints to this has been that non-fisheries related measures in the EMPs are 
often  defined  rather  vaguely,  probably  because  of  restricted  legal  competence  of  the  authorities 
responsible for the EMPs in relation to riverine and watershed management.   

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In addition, the Eel Regulation itself is rather vague non-fisheries related measures, referring 
only  to  (i)  “structural  measures  to  make  rivers  passable  and  improve  river  habitats,  together  with 
other  environmental  measures”  and  (ii)  the  “temporary  switching-off  of  hydro-electric  power 
turbines”.   

Full-cycle aquaculture of the European eel is still yet to be achieved.  Although some progress 
is being made with Anguilla japonica, the successful reproduction, weaning and survival of A. anguilla 
glass eels is yet to be demonstrated at scale.  The development of commercially viable eel hatchery 
and nursery technology could provide a sustainable source of artificially-produced glass eels, both for 
table eel farming as well as for re-stocking.   

As the export of eels from the EU is currently not permitted, there are no systems required to monitor 
formal eel trade within the bloc.  Despite recent successes in combatting the trade of IUU caught eels, 
there is still a substantial IUU flow of eels from the EU. In particular the control of eels fisheries is 
hindered  by  some  shortcoming  of  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. As a result, traceability of eels is difficult to establish, in particular when eels 
are transported from a Member State to another to fulfil Member State obligations for restocking or 
to provide livestock for aquaculture farms.  On a positive note, the Commission recently included eel 
fisheries in the scope of Specific Control and Inspection Programmes (SCIPs) to be implemented by 
Member States under the operational coordination of the European Fisheries Control Agency EFCA. 

6.2.2 Future needs and recommendations  
There is no reason that this Regulation should not be effective over time – there is just a need 
for  sustained  and  robust  implementation  at  Member  State  level,  further  engagement  and  action  at 
transboundary level, and a regular review and improvement of the EMPs at the tri-yearly review points.  
Given the slow progress to date, it is suggested that the current three yearly review61 continue for the 
foreseeable future, rather than every six years as currently anticipated. 

The PC echoed this, suggesting 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, 
rather than issues with the legislation itself (19%). 

Recommendations 

EU-specific   

•  EMPs need to be developed to provide greater focus on 
non-fisheries related measures such as (i) structural 
measures to make rivers passable and improve river 
habitats, together with other environmental measures 
and (ii) the temporary switching-off of hydro-electric 
power turbines.  Where necessary, the design of these 
measures should be conducted jointly with those 
authorities mandated to implement the associated 
actions.   

•  Progress reviews of the EMPs needs to be continued on 

a three-yearly basis for the time being. 

•  Greater efforts should be made to compile and develop 

good practices achieved at national level and to 
disseminate these within the EU and other countries 
managing the European eel stock.   

Wider actions 

•  EMU level mortality limits are 

considered in replacement of the 
current 40% regional escapement 
target. 

•  Coordinated research into 

anguillid aquaculture techniques 
in order to develop commercially 
viable artificial European eel glass 
eel production.   

•  Improve national management 

for implementation of their CITES 
obligations.   

61 Art. 9 of the Regulation sees reporting every six years following the 2018 review. However 2017 
Declaration on eels call on MS to continue reporting on 3year-basis. 

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 SUSTAINABILITY 

Evaluation of the Eel Regulation 

There is no ‘end date’ for the Eel Regulation, so it is considered indefinite, at least until the European 
eel  stock  has  fully  recovered.    Once  the  European  eel  stock  has  fully  recovered,  at  that  point  the 
Regulation could be reconsidered and a sustainable management plan put in place.  In the meantime 
the  regular  progress  reports  as  required  in  the  Regulation  should  be  continued.      This  part  of  the 
evaluation therefore focuses on what elements of the Eel Regulation (rather than the evaluation itself) 
are sustainable over the medium to long term.   

6.3.1 What is, or is not, working and the lessons learned  
Both the management organisations and other stakeholders consider that the Eel Regulation is a 
sustainable approach and needs to be recognised as a long-term process.  Licensed 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 eel are in decline.  One possible threat to the 
sustainability of the Regulation is the continued IUU fishing, especially of glass eels, driven by 
very high prices and demand from Asian aquaculture.   

One key measure under the Regulation, restocking, is a short to medium term measure that 
is  unsustainable  and  should  be  phased  out  as  natural  recruitment  improves,  and  water 
course connectivity is improved. As Dekker & Beaulaton (2016) noted, as successful as restocking 
might have been locally, it has not markedly changed the overall trends and distribution patterns or 
halted the general decline of the stock and fishery.  However, it is noted that freshwater eel production 
in countries like Sweden is almost entirely dependent upon artificial stocking.   

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,  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).  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  process 
knowledge are required. 

The  Commission’s  EMFF  Impact  Assessment  SWD  suggests  that  the  “Member  States  will  be 
required  to  strengthen  national  management  plans  in  order  to  protect  eels  in  the  inland 
waters” (EC, 2018c).   

6.3.2 Future needs and recommendations 
The PC results suggest that the Regulation will need to be in place over the longer-term, as continued 
pressure will need to be put on Member States to implement their EMPs and where necessary, revise 
them in line with both progress made and to incorporate solutions to emerging issues that emerge 
from scientific research and monitoring.    

Recommendations 

EU-specific   

•  The progress of the EMPs should be regularly reviewed to ensure 
that they remain robust, relevant and effective.  This will require 
ongoing research, as well as monitoring of environmental 
conditions, river connectivity and catch documentation and 
traceability (CDT) effectiveness  

•  Continued emphasis on fisheries control to reduce IUU fishing, 

especially of glass eels. This should be supported by developing a 
Europe-wide traceability system that tracks and monitors intra-EU 
eel movements and fate.   

Wider actions 

•  Development of parallel 
management actions in 
non-EU countries, 
including development 
of comprehensive eel 
management plans (at 
transboundary level, 
both with the EU and 

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Evaluation of the Eel Regulation 

Recommendations 

EU-specific   
•  The evaluation identified a possible source of legal 

misinterpretation of Article 7.1 of the Eel Regulation in relation to 
restocking suggesting that 60% of glass eels caught each year 
may not be marketed for this purpose as expected. As a result, 
control authorities cannot enforce this prescription.  

   EFFICIENCY 

Wider actions 

third countries), 
coordinated research. 

6.4.1 What is, or is not, working and the lessons learned  
It  is  very  difficult  to  assess  how  efficient  the  measures  undertaken  by  Member  States  to 
implement the Eel Regulation have been to date.  Eel management is complex, involving multiple 
organisations  and  stakeholders  at  different  levels  within  Member  States.    Based  on  stakeholder 
feedback, the use of EMPs to provide a strategic approach at MS level to eel conservation has 
been  fundamental  in  bringing  together  these  different  interests  and  charting  a  unified  approach.  
However there needs to be a more coordinated strategy between Member States, as well as 
with  third  countries  who  also  share  the  European  eel’s  range,  possibly  through  development  of  an 
international management body for this species.   

A monetarised analysis of the cost-benefits of the Eel Regulation is impossible to quantify 
at this stage.  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.   

The main finding of this evaluation is that the Regulation is essentially sound, and thus most 
Member State respondents indicated that alternative approaches have not been considered. 
The synergies with the WFD, MSFD and the Habitats Directive are also important factors in improving 
its efficiency.   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.   

There are recognised short-comings in terms of reporting levels and progress monitoring at Member 
State levels.  Not all have produced Progress Reports and there has been  considerable variation in 
their quality and robustness.  Since the first  reporting round in 2012,  no Member State  reports on 
glass eel prices have been submitted, although Belgium, Denmark, Estonia 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.    The  inclusion  of  Excel-based  data  tables  in  the  most  recent 
(2018)  progress  reporting  round  has  provide  very  valuable,  although  needs  to  be  developed  and 
improved.   

The role and added value of the joint ICES/EIFAAC/GFCM Working Group on Eel (WGEEL) 
in developing eel management monitoring and evaluation is strongly noted.  Based on the 
2018 return, the ICES Workshop for the Review of Eel Management Plan Progress Reports (WKEMP) 
(ICES, 2018d) recommended that: 

1.  Reporting format and content should be obligatory rather than voluntary as it is now, 

to ensure consistent and comparable information is available from which to judge the state of 
biomass and mortality rates. 

2.  It would reduce the burden on MS if the reporting requests from DG MARE, ICES and 

others could be coordinated and combined. 

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Evaluation of the Eel Regulation 

3.  While submitting the information in Excel spreadsheets is an improvement over submitting in 

paper form or in Word files, data verification, compilation and analysis would be 
greatly facilitated if the data were input in a database by MS and verified by 
knowledgeable personnel before being added to the database. WKEMP understood that 
WGEEL is developing this approach and recommended that all support is provided to make 
this happen. 

8  All data and methods used to estimate all biomass and mortality rates should be 
fully documented and available in a single location. Perhaps ICES could act as a 
depository with a link provided from the WGEEL page. 

9  The treatment of restocking in all estimates of biomass and mortality must be 

clearly described. 

10  The Habitats Assessed part of the Overview Table should include the option to record 

Not Applicable for when a habitat type is not assessed because it does not exist in the EMU. 

6.4.2 Future needs and recommendations  

Recommendations 

EU-specific   

•  A proportionate focus on Member States with significant glass 
eel (FR, UK, ES & PT) and yellow and silver eel (FR, UK, DK, 
SE, IT, PL, NL, ES & EL) production for fisheries measures, 
with a less rigorous approach to Member States with no or 
very little productivity.  This proportionate approach could also 
be carried over into national planning, to ensure that the more 
productive (existing and potential) EMUs are the focus of 
national actions.   

•  Greater emphasis on transboundary collaboration, both within 
and adjacent to the EU.  The shortage of transboundary EMPs 
as required by the Regulation is a considerable concern, 
especially given the transboundary connectivity between in the 
Baltic Sea and between France and Spain (in the Bay of Biscay 
and the Mediterranean).  This also suggests regional; 
initiatives such as the Multiannual Mediterranean Management 
Plan, including an EU Tunisia (and Algeria) Proposal on a multi-
annual management plan for fishing activities catching 
European eel in the Mediterranean Sea.  

•  Greater pressure on Member States to fulfil the Regulation in 

its entirety. As the EMPs vary in quality and fitness for 
purpose, this has resulted in the partial rates in 
implementation to date and the variability in responses to 
progress reporting requirements and data calls (both by the EU 
and ICES).   

•  More specific timelines and interim targets across the 

Regulation. Whilst recognised as a long-term approach, the 
Regulation is not time-bound. There are good reasons for this, 
but many stakeholders have asked that interim targets are 
developed and the progress towards this monitored.  Some MS 
have adopted timebound targets (e.g. interim escapement 
targets in some Italian EMUs) but in others most plans are 
made on more vague timescales.  It is important that such 
interim targets not only cover fisheries-related mortality, but 
also non-fisheries related mortality and proxy indicators (e.g. 
improved connectivity of rivers).  As noted by Dekker (2016), 
this may require re-focusing all protective actions, 

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Wider actions 

•  This could feed into the 
preparation of a wider 
strategic plan to scrutinise 
and consolidate existing 
assessments and 
management plans, and to 
expand their spatial 
coverage, ultimately 
striving towards full 
geographical coverage of 
the whole European eel 
population. This plan 
would need to be based 
upon the progress made in 
scientific understanding 
(mainly via the joint 
WGEEL) as well as a 
comprehensive 
stakeholder consultation 
process.  It may also need 
to include reviews of the 
pristine eel biomass (B0) 
and related escapement 
targets.  It is noted that 
ICES produced guidance 
on European eel 
management measures 
that can be applied to both 
EU and non-EU waters in 
2014 (ICES, 2014).   

 
  
Evaluation of the Eel Regulation 

Recommendations 

EU-specific   

Wider actions 

assessments, evaluations and advice on anthropogenic 
mortality goals and indicators- considering each of the 
management areas (countries) individually.   

•  Allied to the point above, there is a need for a central 

coordinating body for the recovery of the European Eel. The Eel 
Regulation provides a united approach across the EU, but the 
core issue of stock recovery needs a stock range wide 
approach.  One stakeholder mentioned the North Atlantic 
Salmon Conservation Organisation (NASCO) as a possible 
model.   

•  A more cohesive funding approach for EMP and associated 
measures.  Few MS provide budgets for implementing their 
EMPs (EC, 2018a) to cover such aspects as restocking costs 
and habitat improvement projects.  This should include the role 
of the EMFF and other EU public funding, the role of the private 
sector and possibly development of specialist Financial 
Instruments to fund long-term eel conservation and 
management.  This suggests that the Eel Regulation and its 
measures should be specifically reflected in MS EMFF 
operational programmes for the next funding period (2021 - 
2027).   

  COHERENCE  

6.5.1 What is, or is not, working and the lessons learned  
The  Eel  Regulation  is  strongly  coherent  with  a  number  of  EU  and  wider  international 
initiatives to support the recovery of the European eel.  The CFP provides a policy framework for eel 
fisheries management, with the Eel Regulation providing greater environmental coverage away from 
the  CFP’s  marine  focus.  Both  the  WFD  and  MSFD  are  highly  relevant  to  eel-related  habitat  and 
environmental  protection,  and  thus  contributing  to  the  reproductive  potential  of  eels  populations.  
Particularly important under the WFD are measures introduced by River Basin Management Plans that 
aim  to  restore  river  continuity.  However,  with  a  high  proportion  of  waters  failing  good  status  due 
hydro-morphological pressures, significant effort is required to realise this aim.  The Habitats Directive 
is also highly relevant to the conservation of eel-related habitats, although it is questioned why the 
eel itself is not a listed species for protection within the Directive.   

In  the  Mediterranean,  the  GFCM  has  established  a  multi-annual  management  plan  for  catching 
European  eels  in  the  Mediterranean  Sea  (GFCM,  2018).    This  included  targeted,  incidental  and 
recreational  catches  in  marine,  brackish  and  freshwater.    This  precautionary  approach  to  “to 
immediately adjust fishing mortality levels together with other possible measures and to address the 
critical  state  of  the  stock”  concurs  with  the  Eel  Regulation,  as  do  the  transitional  management 
measures to reduce fishing effort and monitor the effects of restocking.   

The Eel Regulation and CITES are closely connected and are complementary. The addition in 2014 of 
the  European  eel  to  Appendix  II  of  the  Convention  on  Migratory  Species  (CMS)  is  important 
because  it  requires  the  EU  and  other  CMS  parties  to  endeavour  to  agree  cooperative  conservation 
actions among Range States.  With the exception of Iceland, Turkey and Russia, all countries within 
the  range  of  Anguilla  are  CMS  parties.    Given  the  need  –  and  emphasis  of  the  Regulation  on 
transboundary cooperation, the CMS is fully coherent with the Regulation.  This said, further action 
needs to be undertaken to take advantage of this agreement.   

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It should be noted that the PC results suggested that there may be an issue with coherence of the Eel 
Regulation, in particular regarding international instruments to regulate fisheries. Most respondents 
disagreed  that  the  Regulation  was  coherent  with  international  instruments  or  with  other  EU 
instruments.  However,  the  proportion  of  respondents  who  indicated  that  they  “neither  agreed  nor 
disagreed” and “didn’t know” exceeded one third in both cases. This shows that it is difficult to assess 
the coherence of the Regulation. In their 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). 

6.5.2 Future needs and recommendations  
It is important that further developments of the CFP and its implementing regulations remain coherent 
with the Eel Regulation and its freshwater components.  Furthermore it is evident that the potential 
for  the  recovery  of  the  European  eel  population  is  dependent  upon  greater  connectedness  in  in 
Europe’s  rivers,  and  thus  water  basin  management  –  including  hydro-power,  flood  defence  and 
transport considerations – are also cognisant of the needs of this iconic species.   

Recommendations 

EU-specific   

•  Consideration of the European eel as a listed 
species for protection within the Habitats 
Directive. 

•  EU to contribute to GFCM transitional 

management measures and the long-term 
management plan proposed for adoption in 
2023.   

Wider actions 

•  Further action needs to be undertaken to 

take advantage of Convention on Migratory 
Species (CMS) and to ensure it contributes 
to improving the conservation status of the 
European eel and its management.  In 
practical terms this means the development 
of an appropriate instrument, whether in the 
form of a legally binding agreement or in the 
form of any other solution already in 
existence among the large of CMS family of 
instruments.   

 EU ADDED VALUE 

6.6.1 What is, or is not, working and the lessons learned  
Following multi-decadal decline of the European eel stock across Europe, the EU adopted a regulation 
to put in place measures for the protection and recovery of this complex panmictic species in 2007.  
The Eel Regulation has provided a strong catalyst for Member State action to address the 
issues affecting the recovery of the European eel.  The key additional inputs / support provided 
by the Eel Regulation include: 

•  The preparation of Eel Management Plans for 19 Member States (Member States where river 
basins or maritime waters lying within its territory do not constitute natural habitats for the 
European eel were able to obtain derogation e.g. AT, BG, CY, HU, MT, RO, SI & SK.  Some of 
these  are  at  national  level,  whilst  others  have  separate  EMPs  for  different  Eel  Management 
Units (EMUs) (see Table 3) for more details).   

•  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.  This required estimates of the pristine biomass (B0) for each river basin. 

•  Benchmarking of the present situation of eel populations in each river basin. 
•  Development of management measures based around eight different approaches (see Art. 

2 (8) with associated timescales).   

•  Development  of  transboundary  EMPs  with  both  other  Member  States  as  well  as  with 
relevant third countries.  However to date only one transboundary EMP (between Spain and 
Portugal) has been prepared.   

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Evaluation of the Eel Regulation 

•  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 (incl. catch monitoring) mechanisms. 
•  A 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 Member States.  It has also brought managers in together 
from different regions and organisations within Member States to develop the plans and associated 
measures.  The Eel Regulation has also stimulated other EU-funded actions to support the recovery of 
the  European  eel,  such  as  the  recently  started  SUDOANG  project  in  South-West  Europe.    The 
Regulation has raised awareness of the need for conserving and managing European eels throughout 
its range. 

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 therefore consider 
this to be a permanent process that needs to be continued to be effective. No Member States contacted 
indicated that they thought the Regulation was ineffective – indeed most voiced their support for the 
Regulation and its continued relevance.   

6.6.2 Future needs and recommendations  
Through  the  Eel  Regulation,  the  EU  has  provided  both  a  framework  and  impetus  for  managing  the 
European eel in EU waters.  The impact is not restricted to the EU waters, as it has provided a working 
model for eel management for  other States that share this panmictic stock, including Norway, Turkey 
and Russia, as well as an emerging array of best practises for eel management implementation.  As 
remarked above and recognised by many PC respondents, this is not a short-term initiative, but will 
probably require a number of decades of focused and persistent management to reduce and mitigate 
both anthropogenic mortality, as well as the wider implications of natural and climate change induced 
environmental change.   

Recommendations 

EU-specific   

•  In the event of the UK -  a key glass eel 
supplier to many other EU restocking 
programmes - leaving the EU, mechanisms 
should be in place to account for the UK's new 
status as a potential exporter to the EU.   

Wider actions 

•  Further efforts are made to develop 

European eel management mechanisms 
and best practises for adaptation and use 
outside the EU.   

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ANNEX 1A: INTERVENTION LOGIC 

Evaluation of the Eel Regulation 

A schematic for the Eel Regulation’s intervention logic is shown in the figure below.  It has been developed from that provided in the original ToR 
and illustrates a hierarchy of objectives, from inputs through to the ultimate desired impact of the Eel Regulation. 

Figure 17: Eel Regulation Intervention Logic 

General Objective
(Impact)

Protection and sustainable use of the stock of European eel (Anguilla anguilla) in 
Community waters

Development of a 
Community Action Plan for 
the Management of European Eel

Specific Objectives
(longer-term outcomes)

Sustainable fishing 
for eels

Protection & 
conservation of 
aquatic habitats

Cooperation & 
coherent actions all  
levels

Clear interlinkages between 
EU policies & international 
instruments 

Council Regulation 
No. 1100/2007 
establishing measures 
For the recovery o
of European eels

Operational 
Objectives
(intermediate 
outcomes)

Activities

Reduced fishing effort, 
majority eels <12cm for 
restocking & >40% 
escapement

Environmental 
measures to increase 
eel recruitment, 
survival and 
escapement

Adequate control and 
enforcement 
measures

Council Regulation No. 1100/2007
Establishing measures for the 
Recovery of the European eel

Determine 
and enable 
escapement 
targets at 
MS level

Reducing & restricting 
commercial/
recreational fishing, 
restocking, 
environmental 
measures predator 
control & aquaculture

Reduction of eel 
mortality caused by 
factors outside the 
fishery

EFF (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.)

Eel Management 
Plans
& Other EU /
 International 
Initiatives

Inputs

EU MS 
Eel Management 
Plans

EFF (2007-2013) and 
EMFF (2014-2020) 
funding

Scientific advice e.g. 
from ICES WG Eel 

EU and international 
instruments to protect and 
conserve endangered species 
and habitats

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ANNEX 1B: EVALUATION QUESTIONS MATRIX 

Evaluation of the Eel Regulation 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

RELEVANCE 

EQ1.  To what extent are the 

1.  The current state of the eel stock 

and whether conservation 
measures are still required.   

1.  Trends in recruitment indices for key 
European sea basins over 2007 - 
2017. 

1.  Examinations of scientific evidence. 

2.  Face to face meeting with ICES / 

WGEEL group members.   

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

2.  The EMP structure as defined by 

2.  Measures stipulated as required in 

the Eel Regulation is still relevant 
to current needs. 

the EMPs are relevant and adequate 
to current needs. 

EQ1a How well the objectives of 

the Eel Regulation (still) 
correspond to needs within 
EU? 

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

1.  Eel landing patterns, escapement 

1.  ICES, EUROSTAT & GFCM data.   

levels and 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). 

1.  Desk study 

2.  PC 

3.  Stakeholder consultations 

4.  Case studies 

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)? 

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 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.   

EQ1c.  How relevant is the need 

1.  The extent to which EU citizens 

1.  Qualitative assessment of public 

1.  PC.  

for eel conservation and 
management to EU citizens 
?  

are aware and possibly affected by 
the status of European eel 
populations and the role of the 
Regulation in addressing this. 

awareness of the issue and how it 
affects people. 

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Evaluation questions 

Judgement criteria 

Indicators 

Methods 

Evaluation of the Eel Regulation 

EFFECTIVENESS 

1.  EMPs implemented and specific 

1.  Measurable progress towards EMP 

1.  Analysis of Progress Reports 

EQ2   To what extent have the 
current measures for the 
recovery of European eel 
stock under the Eel 
Regulation met its objectives 
(see next column)?  

targets achieved. 

targets. 

2.  European eel stock has recovered. 

2.  Recruitment indices for glass & 

3.  Anthropogenic mortalities (e.g. 

non-fisheries related) have been 
reduced. 

4.  Adult eel escapement progressed 

yellow eels. 

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

towards the long term 40% 
escapement objective. 

4.  Estimates of escapement levels in 

selected key river basins. 

5.  Supply of glass eels sufficient for 

5.  Restocking rates by MS and 3rd 

restocking operations. 

countries, market price analyses. 

6.  Fishing effort reduced by at least 

6.  Eel landings62 by MS and 3rd 

countries. 

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

2.  ICES reports 

3.  Progress Reports, stakeholder 
consultations, case studies  

4.  Progress reports, scientific reports, 
stakeholder consultations, case 
studies 

5.  ICES data calls and price survey 

(<.12 cm) 

6.  ICES, EUROSTAT & GFCM data. 

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.  Analysis of inspections / control 

8.  EU and Member State control 

reports, stakeholder consultations 
and case studies.    

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 

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. 

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

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Evaluation questions 

Judgement criteria 

Indicators 

Methods 

Evaluation of the Eel Regulation 

EFFECTIVENESS 

EQ3.  If the measures for the 

recovery of 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?  

1.  Identification of the key barriers 
to 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 

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 

1.  Extent to which wild eel fisheries 
(i) 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. 

1.  Characterisation and if possible, 
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. 

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.     

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Judgement criteria 

Indicators 

Methods 

Evaluation of the Eel Regulation 

EFFECTIVENESS 

employment benefits, and of 
contributing to the availability 
of food supplies. 

3.  Extent to which (i) producers are 

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

SUSTAINABILITY 

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 

1.  Case studies.   

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

EFFICIENCY 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EQ6.  To what extent have the 

1.  Extent to which the costs of 

1.  Qualitative assessment of the costs 

1.  Targeted stakeholder consultations.   

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? 

administering, implementing and 
overseeing EMP actions have been 
balanced by the environmental 
and socio-economic benefits 
accruing from improved eel 
stocks. 

and benefits. 

2.  Case studies. 

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). 

3.  EMFF funding records (inc. recent 

FAME reports). 

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Evaluation questions 

Judgement criteria 

Indicators 

Methods 

Evaluation of the Eel Regulation 

EFFICIENCY 

1.  The extent to which alternative 

1.  Examination of the alternative 

1.  Targeted stakeholder consultations.   

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

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

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. 

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

2.  Case studies.   

1.  Member State Progress Reports.   

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 

1.  Evaluation the latest CITES 
and CMS measures related 
to European eel 
conservation to determine 
consistency with the 

1.  Desk study.   

2.  Targeted stakeholder 

consultations e.g. with 
TRAFFIC, CITES 

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COHERENCE 

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

and Flora (CITES) and (ii) the Convention 
on Migratory Species (CMS). 

measures under the Eel 
Regulation.  

Evaluation questions 

Judgement criteria 

Indicators 

Methods 

EU ADDED VALUE 

EQ 11  What is the additional 

1.  Extent that the Eel Regulation 

has provided additional impetus 
/ support to address eel 
conservation objectives.   

1.  There is consensus among MS Authorities and 
other stakeholders that the Eel Regulation has 
provided a significant boost to addressing barriers 
to eel stock recovery. 

1.  PC 

2.  Targeted consultations 

3.  Case studies 

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?  

2.  Extent that it is possible to 

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

isolate results and outcomes 
that could or would not have 
been otherwise achieved without 
the Eel Regulation. 

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. 

EQ12 What would be the most 

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

1.  Extent that MS authorities are 
able to identify positive and 
negative implications of stopping 
the application of the measures 
as regulated in the Regulation. 

1.  MS authorities and stakeholders identify main 

1.  PC 

positive and negative implications. 

2.  Targeted consultations 

3.  Case studies  

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Evaluation of the Eel Regulation 

ANNEX 2: REFERENCES  

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]. 
  und  Forstwirtschaft,  Umwelt  und  Wasserwirtschaft 
Report  from  Bundesministerium  fürLand
(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. 

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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. 

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, 
content/EN/TXT/PDF/?uri=CELEX:52003DC0573&from=en  

https://eur-lex.europa.eu/legal-

01.10.2003COM(2003) 

final. 

573 

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. 

June 2019 

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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 

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 
http://natura2000.eea.europa.eu/# 

Environment 

Agency 

(2017). 

Natura 

2000 

Network 

Viewer. 

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.p
df on 20/02/2019  

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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%20guid
elines%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.  

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. 

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  

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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. 

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&article=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 
(http:// 
www.nasco.int/pdf/2015%20papers/CNL_15_43.pdf)  

Organization) 

Conservation 

Atlantic 

Salmon 

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. 

June 2019 

98 

 
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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
2nd 
(https://www.sepa.org.uk/environment/water/river- 
plans/)  

2027, Scotland 
Agency 
basin-management-planning/the-current-

Environment 

Protection 

Scottish 

RBMP, 

‐

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

Accessed 

Report. 

Final 

Lot 

2. 

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. 

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ANNEX 3: PC QUESTIONNAIRE  

Public Consultation on the Eel Regulation 

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

1. Introduction 

Background to the public consultation 

The European eel stock (Anguilla Anguilla) is in critical condition. Recruitment is at an all-time low and 
exploitation  of  the  stock  is  currently  unsustainable.  The  decline  in  eel  stock  has  numerous  causes 
including human activities such as fisheries (commercial and recreational), hydropower turbines and 
pumps,  pollution,  habitat  modification  and  the  creation  of  obstacles  to  eel  migration.  A  further 
deterioration  of  the  status  of  the  stock  should  be  avoided.  In  2007  a  framework  to  ensure  the 
protection and sustainable use of the European eel stock was established at EU level (Regulation (EC) 
No 1100/2007 – the so called ‘Eel Regulation’). 

Purpose of the Public Consultation 

This Public Consultation is part of the evaluation of the Eel Regulation. The evaluation aims to assess 
the  measures  for  the  recovery  of  the  stock  of  the  European  eel  under  the  Eel  Regulation,  and  in 
particular  the  contribution  of  the  Eel  Management  Plans  established  and  implemented  under  this 
Regulation.  These  plans  include  measures  to  ensure  the  long-term  escapement  of  at  least  40%  of 
adult eels and include:  

• 

• 

• 

limiting professional and recreational fisheries, 

facilitating fish migration through rivers, and 

restocking inland waters with young fish. 

The  answers  you  provide  as  part  of  the  consultation  will  form  an  important  part  of  the 
Commission’s evidence basis for the evaluation. The results of this consultation and the evaluation 
study  may  be  used  to  inform  decisions  on  whether  the  Eel  Regulation  and/or  the  implementation 
measures need to be reviewed.   

Scope of the consultation 

This Public Consultation aims to gather input from all the stakeholders to evaluate the measures for 
the  recovery  of  the  European  eel  stock  under  the  Eel  Regulation  of  2007.  It  forms  part  of  a  wider 
consultation  strategy  for  the  evaluation  that  also  includes  targeted  stakeholder  consultations  and 
several case studies that will gather more detailed evidence at a national level.   

This  questionnaire  takes  about  15  minutes  to  complete.  You  will  also  be  able  to  provide  any  other 
relevant information or comments at the end.  

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2. About you 

Language of my contribution (‘radio button’ for language selection) 

I am giving my contribution as: 

 Academic/research institution 

 Business association 

 Company/business organisation 

 Consumer organisation 

 EU citizen 

 Environmental organisation 

 Non-EU citizen 

 Non-governmental organisation (NGO) 

 Public authority 

 Trade union 

 Other 

First Name 
Surname 
Email (this won’t be published) 
Organisation name 

Scope 

 International 

 Local 

 National 

 Regional 

Organisation size 

 Micro (1 to 9 employees) 

 Small (10 to 49 employees) 

 Medium (50 to 249 employees) 

 Large (250 or more) 

Transparency register number (255 character(s) maximum).  

Check if your organisation is on the transparency register. It's a voluntary database for organisations 
seeking to influence EU decision-making. 

Country of origin (‘radio button’ for language selection) 

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Publication privacy settings: The Commission will publish the responses to this public 
consultation. You can choose whether you would like your details to be made public or to remain 
anonymous. 

 Anonymous 

Only your type, country of origin and contribution will be published. All other personal details 
(name, organisation name and size, transparency register number) will not be published. 

 Public 

Your personal details (name, organisation name and size, transparency register number, 
country of origin) will be published with your contribution. 

 *I agree with the personal data protection provisions 

What is the main field of activity of your company/organisation? 

a.  fishery 
b.  aquaculture 
c.  environment 
d.  other (specific) 

How would you best describe the nature of your understanding and involvement in matters 
related to the Eel Regulation?  

a.  I work for a state agency responsible for developing, implementing and/or monitoring 

the Eel Regulation 

b.  I am a fisher or farmer involved the production and/or sale of eels 
c.  I represent an international organisation with an interest in the implementation of the 

Eel Regulation 

d.  I  work  for  an  environmental  body  with  an  interest  in  the  implementation  of  the  Eel 

Regulation 

e.  I work for a research body with an interest in the Eel Regulation 
f.  I have a general interest in matters concerning fisheries in the European Union 
g.  Other (please specify) 

 How familiar are you with the EU Eel Regulation regulations?  

a.  I have at least a basic knowledge of the Eel Regulation and its implementation 
b.  I am not familiar with the Eel Regulation 

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3. Questions on Eel Regulation 

Relevance  

1.  *The Eel Regulation has a number of objectives. To what extent do you consider that each of 

these remains relevant today? 

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*There remains a need for a 
European recovery plan for the 
European eel. 

*There remains a need for 
Member States to implement Eel 
Management Plans. 

*There remains a need to ensure 
that anthropogenic mortalities are 
reduced. 

*There remains a need to ensure 
the escapement to the sea of at 
least 40% of the adult eel 
biomass. 

*It remains appropriate to 
regulate the supply of glass eels 
for restocking operations. 

*There remains a need to 
regulate fishing effort and catches 
to ensure the recovery of the 
European eel. 

*There remains a need to ensure 
the origin and traceability of all 
live eels imported to and exported 
from MS. 

*There remains a need to ensure 
that control and enforcement 
activities take place in EU waters 
and at all stages of the eel supply 
chain. 

*It remains appropriate to seek to 
reduce catching of eels to at least 
50% of 2006 levels. 

2.  * To what extent do you agree or disagree with the following statement? 

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*The 
40% 
escapement 
achievable. 

target  of 
eel 
is 

3.  Please provide a reason for your answer as to  why you think the 40% escapement goal is 

achievable or not (optional).  

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103 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

4.  Do you think that alternative targets are needed to ensure that the Eel Regulation delivers on 

its objective of securing the recovery of the European eel? 

Yes     

No  

Don’t Know  

5.  Which indicators or targets do you think would be more suitable? (optional).  

6.  To what extent do you agree or disagree with the following statement? 

Strongly 
disagree 

Rather 
disagree 

Neither agree 
nor disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

Eel 

*The 
Regulation 
requires  amendment  or 
simplification 

7.  Please provide a reason for your answer, and, if appropriate, identify which aspects of the Eel 

Regulation you think need to be amended or simplified (optional).  

Effectiveness 

8.  *To what extent have the current measures for the recovery of European eel stock under the 

Eel Regulation achieved the following objectives?  

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*Implementing Eel 
Management Plans 

* Achieving the targets set out 
in Eel Management Plans 

*Ensuring a reduction in 
anthropogenic eel mortalities 

*Increasing the escapement to 
the sea of adult eels towards 
the 40% target 

*Ensuring that there is enough 
supply of glass eels for 
restocking operations 

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

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

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

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104 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

9.  Reflecting  your  answers  above,  what  do  you  consider  to  be  the  barriers  to  achieving  the 

objectives of the Eel Regulation?  

10.  What do you consider to have been the successes of the Eel Regulation and its implementation 

to date?  

11.  * Do you support the following measures to recover the population of eel in Europe? 

Strongly 
disagree 

Rather 
disagree 

Neither agree 
nor disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*Limiting professional 
eel fisheries in the sea  

*Limiting professional 
eel fisheries in 
freshwater 

*Limiting recreational 
eel fishing in the sea 

*Limiting recreational 
eel fishing in freshwater 

*Facilitating fish 
migration through rivers 

*Restocking waters with 
young fish 

12.  Do you support the implementation of total or partial bans on eel fishing to aid recovery of 

the European eel stock?  

YES  
NO  
DON’T KNOW  

12a. Please provide a reason for your answer to explain why you support or do not 
support bans on eel fishing in the EU:  

13.  What other actions should the European Union or Member States undertake to recover the 

eel population in Europe? Who should undertake these actions (EU or MSs)?  

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105 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Coherence 

Evaluation of the Eel Regulation 

14.  To what extent do you agree or disagree with the following statement? 

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

The Eel Regulation is coherent with 
other EU instruments to regulate 
fisheries (such as the Common 
Fisheries Policy, Fisheries Control 
Regulation, the Water Framework 
Directive and the Marine Strategy 
Framework Directive) 

*The Eel Regulation is coherent with 
other EU instruments to regulate 
fisheries (such as the Common 
Fisheries Policy, Fisheries Control 
Regulation, the Water Framework 
Directive, the Marine Strategy 
Framework Directive, the Convention 
on International Trade in Endangered 
Species of Wild Fauna and Flora - 
CITES, and the Convention on the 
Migratory Species - CMS) 

14a.  Please  provide  a  reason  for  your  answer  to  explain  what  factors  lead  to  coherence  or  to 
identify those aspects that are inconsistent or a duplication of efforts under other measures: 

EU ADDED value 

15.  * To what extent do you agree or disagree with the following statement?  

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*The  Eel  Regulation  provided 
additional  value  compared  to 
what  could  be  achieved  by 
Member  States  at  national  or 
regional level 

15a. Please provide any comments below to explain your answer (optional). (single textbox) 

16.  * What would be the most likely consequences of stopping the application of the measures 

contained within the Eel Regulation (both positive and negative)? 

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Efficiency 

Evaluation of the Eel Regulation 

17.  * To what extent do you agree or disagree with the following statements? 

Strongly 
disagree 

Rather 
disagree 

Neither 
agree nor 
disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

*Administering and 
implementing the Eel 
Regulation has been carried 
out at the lowest possible 
cost. 

*The costs of administering 
and implementing the Eel 
Regulation are proportionate 
to the environmental and 
socio-economic benefits 
achieved. 

*It is possible to simplify the 
Eel Regulation and still achieve 
the same results. 

*The same or better results in 
terms of eel stock recovery 
could have been achieved at 
lower cost. 

18.  *  Do  you  think  that  other  policy  instruments  or  mechanisms  have  provided  better  cost-
effectiveness  than  has  been  achieved  under  the  current  Eel  Regulation  and  associated  Eel 
Management Plans?  

YES  
NO  
DON’T KNOW  

19.  If yes, what other policy instruments or mechanisms do you think would have been more cost 

effective? 

Sustainability  

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

YES  
NO  
DON’T KNOW  

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4. Questions on eel conservation 

Evaluation of the Eel Regulation 

21.  Before  starting  this  consultation,  had  you  ever  heard  about  the  problem  of  decreasing 

population of the European eel? (choose one only) 

a.  YES 
b.  NO 
c.  DON’T KNOW 

22.  Do you support action by the European Union to regulate eel fishing to ensure the recovery of 

the species? (choose one only) 

a.  YES 
b.  NO 
c.  DON’T KNOW 

23.  Do you support the following measures to recover the population of eel in Europe? 

Strongly 
disagree 

Rather 
disagree 

Neither agree 
nor disagree 

Rather 
agree 

Strongly 
agree 

Don't 
know 

Limiting professional eel 
fisheries in the sea  

Limiting professional eel 
fisheries in freshwater 

Limiting recreational eel 
fishing in the sea 

Limiting recreational eel 
fishing in freshwater 

*Facilitating fish 
migration through rivers 

Restocking waters with 
young fish 

24.  What other actions should the European Union or Member States undertake to recover the 

eel population in Europe? Who should undertake these actions (EU or MSs)?  

5. Document upload and final comments 

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points 
not covered by the questionnaire, you can upload your document here. In preparing your response if 
you  have  specific  recommendations,  we  would  ask  that  you  make  it  clear  who  you  believe  should 
action these. 

Please note that the uploaded document will be published alongside your response to the questionnaire 
which is the essential input to this Public Consultation. The document is an optional complement and 
serves as additional background reading to better understand your position. 

If you wish to add further information - within the scope of this questionnaire - please feel free to do 
so here. 

2,000 characters max 

June 2019 

108 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4A: TARGETED CONSULTATION - STAKEHOLDER LIST 

Evaluation of the Eel Regulation 

Prospective list of stakeholders to be consulted in the Member States 

Member State 

MS Competent authority 

Other stakeholders 

BE Belgium 

Landbouw en Visserij 

CZ Czech Republic  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 Environ
ment 

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 
restocking) 

/Aalversandstelle 

(industry  – 

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

GR Greece 

Ministry of Rural Development and 
Food 

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

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109 

 
Member State 

MS Competent authority 

Other stakeholders 

Evaluation of the Eel Regulation 

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 

NL Netherlands 

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 

Department of Fisheries - Ministry 
of Agriculture, Nature and Food 
Quality 

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 

SE Sweden 

Ministry for Rural Affairs Ministry 
of Environment and Energy – 
Natural Environment Division 

UK United Kingdom  Department for Environment, 

Food and Rural Affairs  

Centre for Marine and Environmental Research (CIIMAR), University of Port
oo (research body) 
Portuguese Institute of Sea and Fisheries (INIAP/IPIMAR) (research body) 

Swedish Agency for Marine and Water Management (state agency) 
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) 

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110 

 
 
 
 
Member State 

MS Competent authority 

Other stakeholders 

Evaluation of the Eel Regulation 

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 

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. 

Joint EIFAAC/ICES/GFCM Working Group 
on Eels 

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. 

Low Impact Fishers of Europe 

Coalition Clean Baltic 

Eel Stewardship Association 

Advisory Councils 

European Anglers Alliance 

Aquaculture Advisory Council (AAC) 

Baltic Sea Fisheries Forum (BALTFISH) 

North Western Waters Advisory Council 
(NWWAC) 

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. 

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

June 2019 

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Stakeholder 

Role / Remit 

Evaluation of the Eel Regulation 

North Sea Advisory Council (NSAC) 

South Western Waters Advisory Council 
(SWWAC) 

TRAFFIC 

IUCN Anguillid Eel Specialist Group 

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. 

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ANNEX 4B: TARGETED CONSULTATION - MEMBER STATE 
AUTHORITY QUESTIONNAIRE 

Evaluation of the Eel Regulation 

Introduction 
The Eel Regulation 

In  2007,  the  EU  adopted  specific  measures  for  the  recovery  of  the  stock  of  European  eel  through 
Council Regulation (EC) 1100/2007 (the Eel Regulation). This required EU Member States to prepare 
eel  management  plans  (EMPs)  for  their  river  basins  that  constitute  significant  eel  habitats  for 
implementation in 2009 onwards.   
Eel management and conservation at Member State level  

Under the Eel Regulation, Member States (MS) are obliged to monitor the eel stock, evaluate current 
silver  eel  escapement  and  post-evaluate  implemented  management  actions  aimed  at  reducing  eel 
mortality and increasing silver eel escapement. Under the Regulation, each MS should report to the 
Commission initially every third year until 2018 and subsequently every six years on the monitoring, 
effectiveness and outcomes of EMPs, including: 

• 

• 
• 
• 

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

These reporting requirements were further developed by the Commission in 2011/2012 . This guidance 
added the requirement to report fishing catches (as well as effort), and provides explanations of the 
various biomass, mortality rates and stocking metrics required for international assessment and post-
evaluation. 
This evaluation 

In view of the lack of improvement of the stock status, the European Commission and Member States 
agreed to step up their efforts to protect the stock. This includes carrying out an evaluation of the Eel 
Regulation. 

The evaluation will look in particular into the content and implementation of the eel management plans 
and Member States reporting under the Eel Regulation to assess if they have adequately addressed 
all mortality factors affecting the eel stock.  

Member State concerned 

Person(s) interviewed (name - 
entity – position – contact 
details) 

Date(s) of interview 

Interviewer 

Many thanks in advance for your help. Please return the questionnaire to xxx by xx/xx/ 
2018 or let us know if you require additional time to return a completed questionnaire. If 
you have any questions while completing the questionnaire, please feel free to write to 
the same email address. You can answer the questionnaire in your national language if 
easier for you, although an answer in English is our preferred option. 

June 2019 

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Questionnaire for Member State Authorities  

Evaluation of the Eel Regulation 

General Questions 

 Question: What key national measures are in place to promote recovery of the European eel stock? 

 Answer 

 Question: Since 2009, what key legislation has been enacted at national level to assist the recovery of 
eel stocks? 

 Answer (please justify in a sentence or two) 

 Question: To what extent have the following measures for the recovery of European eel stock met the 
objectives of the Eel Regulation?  
 Answer 

Yes / 
No / 
Partially 

Justification 

Approach 

Implement Eel Management 
Plans to achieve specific targets; 

Ensured the anthropogenic 
mortalities (e.g. non-fisheries) 
are reduced; 

Increased the escapement to 
the sea of adult eels towards the 
40% target; 

Ensured there is enough supply 
of glass eels for restocking 
operations; 

Ensured reduction of fishing 
effort and catches towards the 
50% target; 

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

Ensure effective control and 
enforcement activities. 

  Question:  What  have  been  the  key  success  factors  that  have  assisted  the 
implementation of the measures for the recovery of the European eel stock under the Eel 
Regulation?    Please  consider  administrative,  social,  cultural,  legal,  trade,  political,  fiscal  and 
technical (inc. scientific and biological)issues when responding. 

 Answer 

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Evaluation of the Eel Regulation 

 Question: What have been the key barriers to implementation of the measures for the 
recovery of the European eel stock under the Eel Regulation?  Please consider administrative, 
social, cultural, legal, trade, political, fiscal and technical (inc. scientific and biological)issues when 
responding. 

 Answer 

  Question:  Is  sufficient  data  available  to  report  progress  against  each  of  the  objectives  of  the  Eel 
Regulation? 

 Answer (please justify in a sentence or two) 

 Question: How sustainable are the measures undertaken e.g. will they continue to be 
effective after the measures are completed or stopped? 

 Answer 

 Question: Did you fund any actions to achieve your Eel Management Plan through the 
European Fisheries Fund (EFF)?  If yes, please provide a brief description of the actions 
taken, if possible with an indication of the budget allocated.   

 Answer 

 Question: Did you fund any actions to achieve your Eel Management Plan through the 
European Maritime and Fisheries Fund (EMFF)?  If yes, please provide a brief description 
of the actions taken, if possible with an indication of the budget allocated.   

 Answer 

  Question:  What  non-fisheries  related  measures  have  been  particularly  effective  in 
achieving the objectives of the Eel Regulation?  Do you have any thoughts on their cost-
effectiveness? 

 Answer 

 Question: What measures are in place to identify the origin and ensure the traceability of all live eels 
imported or exported, and how are these enforced? 

 Answer 

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115 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluation of the Eel Regulation 

 Question: What other international and national policy instruments or mechanisms are important in 
aiding recovery of eel stocks? Do the objectives of these align with the objectives of the Eel Regulation? 

 Answer  

 Question: To what extent are measures for recovery of the European eel stock set out in the Eel 
Regulation still relevant? 

 Answer 

 Question: Has your organisation identified unexpected effects of Eel Regulation? If yes, 
what are these and are they positive or negative?  

 Answer 

  Question:  Are  there  any  conflict  or  incompatibilities  between  eel  conservation 
measures and other national / EU policies and regulations?  

 Answer 

 Question: The Commission may consider a revision of the Eel Regulation. Do you have 
particular views on how the Regulation should evolve? 

 Answer 

Administrative workload 

Developing and monitoring progress against the Eel Regulation may require specific working time 
for administrative agents in the Member States.  The objective of this section is to understand the 
average  number  of  full-time  equivalent  (FTE)  involved  in  developing  and  monitoring  the  Eel 
Regulation at central and at regional level (if applicable). For example, one public agent spending 
half of his annual working time on the Eel Regulation shall be quantified as 0.5 FTE.  Any non-person 
costs (e.g. IT costs) should also be estimated where possible. 

Note, this is separate to workload associated with control and enforcement of the Regulation. 

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Evaluation of the Eel Regulation 

Estimates 

Average number of FTEs at central level:  

Average number of FTEs at regional level:    

Comments:  

Missing points: please develop below important points that are not adequately covered 
by the questions, and that are important to take account into the evaluation 

 Answer 

June 2019 

117 

 
 
 
 
 
ANNEX 4C: TARGETED CONSULTATION – CONTROL AUTHORITY 
QUESTIONNAIRE (DETAILED VERSION) 

Evaluation of the Eel Regulation 

Background to this questionnaire 

In  2007,  the  EU  adopted  specific  measures  for  the  recovery  of  the  stock  of  European  eel  through 
Council Regulation (EC) 1100/2007 (the Eel Regulation). In view of the lack of improvement of the 
stock status, the European Commission and Member States agreed to step up their efforts to protect 
the stock. This includes carrying out the evaluation of the Eel Regulation. 

The evaluation will look in particular into the content and implementation of the eel management plans 
and Member States reporting under the Eel Regulation to assess if they have adequately addressed 
all  mortality  factors  affecting  the  eel  stock.  The  evaluation  will  also  cover  control  and  enforcement 
issues, both in marine and in inland waters. This is the focus of this questionnaire. 

Our  consortium  has  been  contracted  by  DG  MARE  to  carry  out  this  evaluation  (see  attached 
authorisation letter). Since Member States experience for control and enforcement of eel protection 
measures is central to inform the decision whether the Eel Regulation needs to be reviewed or whether 
it is  the  implementation  which  needs  to  be  improved,  we  would  be  grateful  if  your  authority  could 
answer  the  following  questions,  in  order  to  enable  the  evaluation  to  fully  reflect  the  views  and 
experience of MEMBER STATE. 

Many thanks in advance for your help. Please return the questionnaire to xxx by xx/xx/ 2018 or let 
us know if you require additional time to return a completed questionnaire. If you have any questions 
while  completing  the  questionnaire,  please  feel  free  to  write  to  the  same  email  address.  You  can 
answer the questionnaire in your national language if easier for you, although an answer in English is 
our preferred option. 

Respondent details 

Member State concerned 

Name of respondent - entity – 
position – contact details 

Date of questionnaire completion 

National authorities involved in control and enforcement of eel management 
plan measures 

  Question:  what  are  the  main  national  authorities  involved  for  control  and 
enforcement of eel measures in MEMBER STATE? 

Please  list  the  different  authorities  involved  with  identification  of  their  main  area  of 
competence (i.e. marine waters, freshwater bodies, aquaculture, import-export) 

 Answer (list as appropriate) 

•  Authority 1 (main area of competence) 
•  Authority 2 (main area of competence) 

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Evaluation of the Eel Regulation 

 Question: what are the main national arrangements for coordination of the 
different national authorities involved? 

Please  describe  the  arrangements  to  coordinate  control  and  enforcement  actions  at 
national level (e.g. coordinating national authority ;  preparation, implementation and 
monitoring of a national control plan) 

 Answer 

 Question: in the event a national control plan is prepared, is it based on a risk 
assessment? If so, how often is the risk assessment updated? 

 Answer 

  Please  add  any  comment  on  the  national  organisation  for  the  control  and 
enforcement  of  eel  conservation  measures  that  should  be  brought  to  the 
attention of our evaluation team 

 Answer 

Description of main control measures implemented in MEMBER STATE 

Control measures (as relevant in the case of MEMBER STATE) 

 Question: What are the main control measures implemented at national level 
for control of eel conservation measures in marine waters (Community waters 
according to Reg. (EC) 1100/2007)? 

 Answer 

 Question: What are the main control measures implemented at national level 
for control of eel conservation measures in freshwater bodies (Non-Community 
waters according to Reg. (EC) 1100/2007)? 

 Answer 

 Question: What are the main control measures implemented at national level 
for control of ecological continuity of rivers? 

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 Answer 

Evaluation of the Eel Regulation 

  Question:  What  are  the  main  measures  implemented  at  national  level  for 
control of eel aquaculture? 

 Answer 

  Question:  What  are  the  main  measures  implemented  at  national  level  for 
control of import and export of eels? 

 Answer 

  Question:  What  are  the  main  measures  implemented  at  national  level  for 
control of traceability of eels along the supply chain (from net to final sale)? 

 Answer 

Main risks of non-compliance 

Question:  According  to  your  experience,  what  are  the  main  risks  of  non-
compliance with national eel conservation measure? 

When replying, thanks to precise the nature of the risk and the environment in which 
risks  occur  the  most  i)  marine  waters,  ii)  freshwater  bodies,  iii)  aquaculture  and  iv) 
import and export of eels (as relevant for the Member State) 

 Answer 

Question:  What  are  the  challenges  met  at  national  level  to  overcome  risks 
identified according to the answer to the previous question. 

 Answer 

Control means 

 Question: In addition to traditional control means, do control authorities in 
MEMBER  STATE  use  modern  technologies  that  proved  to  increase  cost-
effectiveness of controls? 

Traditional  control  means  generally  include  manned  inspections  (on  land,  seaborne, 
airborne). Modern technologies consider use of unmanned control means like drones or 

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Evaluation of the Eel Regulation 

closed-circuit television (CCTV), or increased use of electronic traceability devices (i.e. 
RFID) or database cross-checking techniques 

In the event such modern technologies is used by your control authorities, please specify 
for what infringement detection purpose. 

 Answer 

The way forward 

  Question:  according  to  your  experience,  what  would  be  the  main 
recommendations for improvement of control and enforcement of national eel 
measures implemented under Reg (EC) 1100/2007? 

 Answer 

 Question: In the event the Eel Regulation is reviewed, what would be your 
main  recommendations  in  relation  to  control  measures  and  enforcement 
thereof? 

 Answer 

Costs of control and enforcement of eel measures 

  Question:  do  you  have  an  estimate  of  costs  of  national  control  and 
enforcement eel measures? 

Please provide any estimate available. Alternatively, please provide an estimate of the 
amount of workforce deployed on control of eel measures (e.g. number of control agents 
involved, number of full-time equivalent). If no estimate is available for your Member 
State, please state so. 

If you provide estimate, please ensure that scope of estimates and units of estimates 
are sufficiently detailed. 

 Answer 

Missing points: please develop below important points that are not adequately 
covered by the questions, and that may be important to take account into the 
evaluation according to MEMBER STATE experience 

 Important missing points 

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ANNEX 4D: TARGETED CONSULTATION – CONTROL AUTHORITY 
QUESTIONNAIRE (SIMPLIFIED VERSION) 

Evaluation of the Eel Regulation 

Background to this questionnaire 

In  2007,  the  EU  adopted  specific  measures  for  the  recovery  of  the  stock  of  European  eel  through 
Council Regulation (EC) 1100/2007 (the Eel Regulation). In view of the lack of improvement of the 
stock status, the European Commission and Member States agreed to step up their efforts to protect 
the stock. This includes carrying out the evaluation of the Eel Regulation. 

The evaluation will look in particular into the content and implementation of the eel management plans 
and Member States reporting under the Eel Regulation to assess if they have adequately addressed 
all  mortality  factors  affecting  the  eel  stock.  The  evaluation  will  also  cover  control  and 
enforcement  issues,  both  in  marine  and  in  inland  waters.  This  is  the  focus  of  this 
questionnaire. 

Our  consortium  has  been  contracted  by  DG  MARE  to  carry  out  this  evaluation  (see  attached 
authorisation letter). Since Member States experience for control and enforcement of eel protection 
measures is central to inform the decision whether the Eel Regulation needs to be reviewed or whether 
it is  the  implementation  which  needs  to  be  improved,  we  would  be  grateful  if  your  authority  could 
answer  the  following  questions,  in  order  to  enable  the  evaluation  to  fully  reflect  the  views  and 
experience of MEMBER STATE. 

We are aware that MEMBER STATE already responded a questionnaire submitted by DG MARE on the 
control of eel fisheries in 2018. This questionnaire focuses on areas not necessarily covered by the DG 
MARE questionnaire. 

Many thanks in advance for your help. Please return the questionnaire to xxx by xx/xx/ 2018, or let 
us know if you require additional time to return a completed questionnaire. If you have any questions 
while  completing  the  questionnaire,  please  feel  free  to  write  to  the  same  email  address.  You  can 
answer the questionnaire in your national language if easier for you, although an answer in English is 
our preferred option. 

Respondent details 

Member State concerned 

Name of respondent - entity – 
position – contact details 

Date of questionnaire completion 

Main risks of non-compliance 

Question:  According  to  your  experience,  what  are  the  main  risks  of  non-
compliance with National eel conservation measure? 

When replying, thanks to precise the nature of the risk and the environment in which 
risks  occur  the  most  i)  marine  waters,  ii)  freshwater  bodies,  iii)  aquaculture  and  iv) 
import and export of eels (as relevant for the Member State) 

 Answer 

Question:  What  are  the  challenges  met  at  national  level  to  overcome  risks 
identified according to the answer to the previous question. 

 Answer 

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Evaluation of the Eel Regulation 

Control means 

 Question: In addition to traditional control means, do control authorities in 
MEMBER  STATE  use  modern  technologies  that  proved  to  increase  cost-
effectiveness of controls? 

Traditional  control  means  generally  include  manned  inspections  (on  land,  seaborne, 
airborne). Modern technologies consider use of unmanned control means like drones or 
closed-circuit television (CCTV), or increased use of electronic traceability devices (i.e. 
RFID) or database cross-checking techniques 

In the event such modern technologies is used by your control authorities, please specify 
for what infringement detection purpose. 

 Answer 

The way forward 

  Question:  according  to  your  experience,  what  would  be  the  main 
recommendations for improvement of control and enforcement of national eel 
measures implemented under Reg (EC) 1100/2007? 

 Answer 

 Question: In the event the Eel Regulation is reviewed, what would be your 
main  recommendations  in  relation  to  control  measures  and  enforcement 
thereof? 

 Answer 

Costs of control and enforcement of eel measures 

  Question:  do  you  have  an  estimate  of  costs  of  national  control  and 
enforcement eel measures? 

Please provide any estimate available. Alternatively, please provide an estimate of the 
amount of workforce deployed on control of eel measures (e.g. number of control agents 
involved, number of full-time equivalent). If no estimate is available for your Member 
State, please state so. 

If you provide estimate, please ensure that scope of estimates and units of estimates 
are sufficiently detailed. 

 Answer 

Missing points: please develop below important points that are not adequately 
covered by the questions, and that may be important to take account into the 
evaluation according to MEMBER STATE experience 

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Evaluation of the Eel Regulation 

 Important missing points 

Thank you for your cooperation 

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ANNEX 4E: TARGETED CONSULTATION - OTHER STAKEHOLDER 
QUESTIONNAIRE 

Evaluation of the Eel Regulation 

Introduction 

The Eel Regulation 

In  2007,  the  EU  adopted  specific  measures  for  the  recovery  of  the  stock  of  European  eel  through 
Council Regulation (EC) 1100/2007 (the Eel Regulation). This required EU Member States to prepare 
eel  management  plans  (EMPs)  for  their  river  basins  that  constitute  significant  eel  habitats  for 
implementation in 2009 onwards.   

Eel management and conservation at Member State level  

Under the Eel Regulation, Member States (MS) are obliged to monitor the eel stock, evaluate current 
silver  eel  escapement  and  post-evaluate  implemented  management  actions  aimed  at  reducing  eel 
mortality and increasing silver eel escapement. Under the Regulation, each MS should report to the 
Commission initially every third year until 2018 and subsequently every six years on the monitoring, 
effectiveness and outcomes of EMPs, including: 

• 

• 
• 
• 

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

These reporting requirements were further developed by the Commission in 2011/2012 . This guidance 
added the requirement to report fishing catches (as well as effort), and provides explanations of the 
various biomass, mortality rates and stocking metrics required for international assessment and post-
evaluation. 

This evaluation 

In view of the lack of improvement of the stock status, the European Commission and Member States 
agreed to step up their efforts to protect the stock. This includes carrying out an evaluation of the Eel 
Regulation. 

The evaluation will look in particular into the content and implementation of the eel management plans 
and Member States reporting under the Eel Regulation to assess if they have adequately addressed 
all mortality factors affecting the eel stock.  

Person(s) interviewed (name - 
entity – position – contact 
details) 

Member State concerned 

Date(s) of interview 

Interviewer 

Many thanks in advance for your help. Please return the questionnaire to xxx by xx/xx/ 
2018 or let us know if you require additional time to return a completed questionnaire. If 
you have any questions while completing the questionnaire, please feel free to write to 
the same email address. You can answer the questionnaire in your national language if 
easier for you, although an answer in English is our preferred option. 

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Questionnaire for stakeholders  

Evaluation of the Eel Regulation 

 Question: In your view, is the Eel Regulation a relevant and effective instrument to 
promote the recovery and sustainable use of the European eel stock?  Please justify your 
answer. 

 Answer 

 Question: In your view, are there measures available in your Member State to 
implement the Eel Regulation adequately?  If not, what should they include? 

Fisheries-related  (e.g.  limits  on  fishing 
effort,  better  control  and  limits  on  eel 
trade) 

Non-fisheries related (e.g. improvements to 
water quality, migration route connectivity, 
etc) 

 Answer 

 Answer 

  Question:  What  have  been  the  key  success  factors  that  have  assisted  the 
implementation of the measures for the recovery of the European eel stock under the Eel 
Regulation?   

 Answer 

  Question:  What  have  been  the  key  success  factors  that  have  assisted  the 
implementation of the measures for the recovery of the European eel stock outside of the 
Eel Regulation?   

 Answer 

 Question: In your view, what are the key barriers to recovery of the European eel stock 
that can be addressed at Member State level? 

 Answer 

 Question: In your view, what are the key barriers to recovery of the European eel stock 
that  cannot  be  addressed  at  Member  State  level  and  need  wider  international 
involvement? 

 Answer 

 Question: In your view, what measures beyond those covered by the Eel Regulation, 
would aid recovery of the European eel stock? 

 Answer 

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Evaluation of the Eel Regulation 

 Question: In your view, what measures to aid recovery of the European eel stock are 
most cost-effective and why? 

 Answer 

 Question: In your view, are any other international and national policy instruments or 
mechanisms important in aiding recovery of eel stocks? If yes, in your view do the 
objectives of these align with the objectives of the Eel Regulation? 

 Answer  

 Question: Has your organisation identified unexpected effects of the Eel Regulation? If 
yes, what are these and are they positive or negative?  

 Answer 

 Question: The Commission may consider a revision of the Eel Regulation. Do you have 
particular views on how the Regulation should evolve? 

 Answer 

 Question: What else could EU Member States do to improve the status of European eels 
in EU waters? 

 Answer 

Missing points: please develop below important points that are not adequately covered 
by the questions, and that are important to take account into the evaluation 

 Answer 

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ANNEX 5: SYNOPSIS REPORT ON THE PUBLIC, ROADMAP AND 
OTHER STAKEHOLDER CONSULTATIONS  

Evaluation of the Eel Regulation 

1. INTRODUCTION 
This report provides a concise overview of all consultation work carried out within the evaluation of 
the Eel Regulation in line with Better Regulation Toolbox, tool #55. According to the guidelines, the 
report should cover formal consultation work, ad hoc contributions directly linked to the preparation 
of  the  evaluation  and  information  on  the  input  received  through  the  feedback  mechanisms  for 
roadmaps. 

Our  synopsis  report  presented  below  covers  all  consultation  activities  conducted  throughout  the 
evaluation study, including: 

•  12-week public consultation (PC), 

•  Feedback received to the evaluation roadmap 

•  Ad hoc contribution, 

•  Targeted consultation. 

2. PUBLIC CONSULTATION 
The Commission launched the public consultation on 14 December 2018. With the obligatory 12-week 
consultation period the PC ended on 8 March 2019. The consultation aimed to gather feedback from 
two types of potential respondents: 

• 

fisheries professionals, familiar with the Eel Regulation, and 

•  EU citizens not familiar with the legislation but interested in eel stock recovery. 

To address the two groups, we have divided the PC questionnaire 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  five  evaluation  criteria.  The  general 
survey  was  more  generic  and  briefer.  It  included  three  closed  and  one  open  question.  The 
questionnaire was accessible on the EU Survey website in all EU official languages.63 

In total, 160 respondents took part in the consultation, 152 responded to experts’ survey and 8 to 
general survey. Ad hoc responses were also received from the Sustainable Eel Group (SEG, the Baltic 
Sea Advisory Council (BSAC) as well as the French and Netherlands governments.  Below we present 
a characteristic of the respondents and a summary of their responses. 

2.1  Respondents’ profile 
Sixteen Member States (57%) and two non-EU countries (Norway and Albania) were represented in 
the contributions. More than 40% of respondents came from France (66 contributions), followed by 
Spain (20), the Netherlands (14), Germany (10), the United Kingdom (8), Portugal (7), Belgium and 
Sweden (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). 

63  Public  consultation  on  the  Eel  Regulation,  https://ec.europa.eu/info/law/better-regulation/initiatives/ares-
2018-1986447/public-consultation_en.  

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

Evaluation of the Eel Regulation 

• 

• 
• 

• 
• 
• 

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%).64  

2.2  Public consultation results 
Below we present the results of the OPC experts’ survey (152 contributions). 

Relevance 

Overall, respondents assessed the relevance of the Eel Regulation positively. As presented in Figure 
18 overleaf, the majority of them considered all the objectives listed as still relevant. 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 Member States to implement Eel 
Management Plans. 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). 

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

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Figure 18: How relevant is the Eel Regulation? 

Evaluation of the Eel Regulation 

Q1: The Eel Regulation has a number of objectives. To what extent do you consider that each of these remains 
relevant today?  

There remains a need for a European recovery plan for the
European eel

There remains a need for Member States to implement Eel
Management Plans

There remains a need to ensure that anthropogenic mortalities
are reduced

There remains a need to ensure that control and enforcement
activities take place in EU waters and at all stages of the eel…

 There remains a need to ensure the origin and traceability of all
live eels imported to and exported from MS

There remains a need to regulate fishing effort and catches to
ensure the recovery of the European eel

It remains appropriate to regulate the supply of glass eels for
restocking operations

There remains a need to ensure the escapement to the sea of at
least 40% of the adult eel biomass

It remains appropriate to seek to reduce catching of eels to at
least 50% of 2006 levels

78,3%

78,3%

77,6%

77,6%

74,3%

14,5%

14,5%

14,5%

9,2%

11,2%

59,9%

56,6%

22,4%

19,1%

50,7%

17,1%

45,4%

12,5%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

n=152 
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” (see Figure 19). 

Figure 19: Is the 40% escapement target achievable? 

Q2: To what extent do you agree or disagree with the following statement?: The target of 40% eel escapement 
is achievable 

25,0%

20,4%

16,4%

11,8%

16,4%

9,9%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

n=152 
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). 

Respondents were able to provide additional comments on the possibility to achieve this target65. Out 
of  those  who  provided  additional  comments  (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  Member 
States 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 the national level being insufficiently implemented (6.7%).  

65 Q3: Please provide a reason for your answer as to why you think the 40% escapement goal is achievable or not (optional), 
n=127. 

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Evaluation of the Eel Regulation 

In  a  separate  contribution  provided  to  the  Commission  by  the  French  national  administration,  it 
indicated that 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. Therefore, it is essential that intermediate objectives 
to  achieve  this  long-term  objective  are  implemented  by  the  Member  States  in  their  management 
plans.  Apart  from  assessing  the  relevance  of  the  current  objectives  of  the  regulation,  respondents 
were asked if the regulation needed amendments or simplification. The majority indicated that it did 
(64.5%), compared to only one in ten who disagreed and about one third without a specified opinion 
(see Figure 20 below). 

Figure 20: Should the Eel Regulation be amended of simplified? 

Q6:  To  what  extent  do  you  agree  or  disagree  with  the  following  statement?:  The  Eel  Regulation  requires 
amendment or simplification. 

33,6%

30,9%

21,7%

7,2% 2,0%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

n=152 
Respondents  were  also  asked  to  provide  suggestions  on  amendments  or  simplification  in  an  open-
ended question.66 From those who provided answers, 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%). 

The vast majority of respondents (76.3%) indicated that alternative targets were needed to ensure 
that the regulation delivers on its objective of securing the recovery of the European eel. One in ten 
respondents disagreed (see Figure 21). 

Figure 21: Does the Eel Regulation need alternative targets? 

Q4: Do you think that alternative targets are needed to ensure that the Eel Regulation delivers on its objective 
of securing the recovery of the European eel? 

76,3%

9,9%

13,8%

agree / yes

disagree / no

don't know

n=152 
In an open-ended question, respondents provided additional comments and proposals for alternative 
targets and indicators.67 Out of those who provide comments, 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).  

66 Q7: Please provide a reason for your answer, and, if appropriate, identify which aspects of the Eel Regulation you think need 
to be amended or simplified (optional), n=121. 
67 Q5: Which indicators or targets do you think would be more suitable? (optional), n=103. 

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Individual respondents also proposed concrete indicators such as: 

Evaluation of the Eel Regulation 

• 

• 

• 

indicators  related  to  migration  barriers  (number  of  those  removed,  number  of  hours  of 
shutdown of turbines, km of watercourses restored), 

indicators of restoration of ecological continuity, rate of colonization of suitable spaces, 

the number of young eels colonizing habitats above estuaries, 

•  quantitative indicator of eel escapement in each catchment or representative catchment, 

•  minimum recruitment rates to be met by watershed below which any exploitation of stocks at 

all stages should be prohibited, 

•  number of eels that need to reach the spawning areas to reach a sustainable stock. 

French authorities also indicated the need to adopt intermediate targets in EMPs that can be evaluated 
in the short or medium term, but also stressed the need to focus efforts not on a modification of the 
regulation but on the proper implementation of the EMPs. 

Effectiveness 

Respondents assessed the achievements of the regulation less positively than its relevance. They were 
asked to make judgement on the effectiveness of the current measures for the recovery of European 
eel stock against the same set of objectives of the regulation. Opinions were mixed. 

The  achievement  of  some  objectives  was  assessed  more  positively  than  others,  for  example,  the 
implementation  of  Eel  Management  Plans  was  the  only  objective  that  the  majority  of  respondents 
(57.2%) agreed that it was achieved.  

A relative majority of respondents also 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:  

•  ensuring the origin and traceability of all live eels imported to and exported from MS (by 9.2 pp), 

•  ensuring reduction of fishing effort and catches towards the 50% targets (by 10.5 pp), 

•  ensuring that there is enough supply of glass eels for restocking operations (by 10.5 pp), 

•  ensuring control and enforcement activities at all stages of the eel supply chain (11.9 pp). 

The majority of respondents (51.3%) indicated that targets set out in Eel Management Plans remain 
not achieved (see Figure 22).  

Figure 22: What has the Eel Regulation achieved? 

Q8: To what extent have the current measures for the recovery of European eel stock under the Eel Regulation 
achieved the following objectives? 

Ensuring control and enforcement activities at all stages of the…
Ensuring the origin and traceability of all live eels imported to…
Ensuring reduction of fishing effort and catches towards the…
Ensuring that there is enough supply of glass eels for…
Increasing the escapement to the sea of adult eels towards the…

Ensuring a reduction in anthropogenic eel mortalities
Achieving the targets set out in Eel Management Plans
Implementing Eel Management Plans

13,2%
11,2%
9,9%
8,6%
9,2%
14,5%
10,5%

18,4%
20,4%
25,0%

15,8%

30,3%

29,6%

19,1%

22,4%
29,6%

13,8%

13,8%

29,6%

21,7%

19,7%

37,5%

15,8%

13,8%

16,4%
17,1%
17,1%

19,7%

27,0%

23,7%

28,3%
15,1%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

0%

25%

50%

75%

100%

n=152 

June 2019 

133 

 
 
Evaluation of the Eel Regulation 

Most respondents were also able to share their views on successes of the Eel Regulation68 and barriers 
hindering its effectiveness in open text comments69 (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  Member  States.  10.2%  mentioned  other 
achievements and 12.9% indicated no or limited achievements or negative consequences. 

As regards barriers hindering regulation’s effectiveness, respondents mentioned as follows: 

•  external barriers (39.1%), such as: 

inability to reduce hydropower mortality (13.9%), 

o 
o  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. 

Support for Eel Regulation measures 

Most of respondents indicated that they supported all the measures of the Eel Regulation. 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%). The details are presented in Figure 23. 

Figure 23: What is the support for Eel Regulation measures? 

Q11: Do you support the following measures to recover the population of eel in Europe? 

Restocking waters with young fish

36,8%

16,4%

Facilitating fish migration through rivers

84,2%

7,2%

Limiting recreational eel fishing in freshwater

Limiting recreational eel fishing in the sea

59,9%

57,2%

14,5%

16,4%

Limiting professional eel fisheries in freshwater

44,1%

21,7%

Limiting professional eel fisheries in the sea

48,7%

25%

0%

21,1%

50%

75%

100%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

n=152 

68 Q10: What do you consider to have been the successes of the Eel Regulation and its implementation to date? 
69 Q9: Reflecting your answers above, what do you consider to be the barriers to achieving the objectives of the Eel Regulation?, 
n=151. 

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Evaluation of the Eel Regulation 

In a separate question, 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, as indicated in Figure 24.  

Figure 24: What is the support for a ban on eels fishing? 

Q12: Do you support the implementation of total or partial bans on eel fishing to aid recovery of the European 
eel stock? 

61,2%

33,6%

agree / yes

disagree / no

don't know

n=152 

Respondents  from  the  business  sector  were  most  likely  to  disagree  that  they  supported  the 
implementation of total or partial bans on eel fishing (58.8%)70. Conversely, 83.3% of respondents 
representing environmental organisations supported it. 

Respondents  also  provided  additional  comments  related  to  bans  on  eel  fishing71:  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 recline.  

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. Negative socio-economic consequences were also referred to 
in a separate contributions by the Baltic Sea Advisory Council72 and the French government, submitted 
to the Commission, as well as in a few contributions to the evaluation roadmap submitted before the 
evaluation  started. 73 The  French  government  insists  that  fishermen  have  reached  the  objectives  of 
the eel management plan and already significantly reduced fishing effort; now focus should be given 
to other anthropogenic mortality factors. 

Respondents  were  also  asked  about  other  actions  at  EU  or  Member  States  levels  that  could  be 
undertaken  to  recover  the  eel  population  in  Europe. 74 43.8%  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  25 

70 n=40 
71 Q12a: Please provide a reason for your answer to explain why you support or do not support bans on eel fishing in the EU, 
N=140. 
72 BSAC is of the view that if all kinds of eel fishing were stopped, it would cost jobs and welfare in coastal regions. Eel is a part 
of the traditional food and culture in some regions, so it has high value for tourism. 
73 For  instance,  the  Alakusten’s  Cultural  Heritage  Association  indicated  that  ell  fishing  is  a  Swedish  cultural  heritage.  See: 
Feedback received on: Evaluation of the Eel Regulation, https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-
1986447/feedback_en?p_id=223664.  
74 Q13: What other actions should the European Union or Member States undertake to recover the eel population in Europe? 
Who should undertake these actions (EU or MSs)?, n=144. 

June 2019 

135 

 
 
                                           
overleaf.  The  proportion  of  respondents  who  indicated  that  they  “didn’t  know”  was  substantial  and 
exceeded one third of all respondents in both cases.  

Evaluation of the Eel Regulation 

Figure 25: How coherent is the Eel Regulation with other fisheries instruments? 

Q14: To what extent do you agree or disagree with the following statements? 

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%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

0%

25%

50%

75%

100%

n=152 
Respondents also provided additional comments on coherence but in most responses those comments 
did not clearly specify the issues with coherence75. 19.1% of those who provided comments 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  additional  added  value  to  what  could  be 
achieved by Member States at national or regional levels. More than three quarters of respondents 
valued the EU intervention, compare to 7.9% who did not (see Figure 26). 

Figure 26: What's the EU-added value of the Eel Regulation? 

Q15:  To  what  extent  do  you  agree  or  disagree  with  the  following  statement?:  The  Eel  Regulation  provided 
additional value compared to what could be achieved by Member States at national or regional level. 

46,1%

30,9%

11,8%

3,3%4,6%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

n=152 

In an open-ended question, respondents were also asked what the consequences of withdrawing the 
intervention  would  be.76 Most  of  them  (59.9%)  referred  to  negative  consequences,  mainly  the  eel 
population  being  more  endangered  and  a  risk  that  Member  States  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.  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 

75 Q14a: Please provide a reason for your answer to explain what factors lead to coherence or to identify those aspects that are 
inconsistent or a duplication of efforts under other measures, n=131. 
76 Q16:  What  would  be  the  most  likely  consequences  of  stopping  the  application  of  the  measures  contained  within  the  Eel 
Regulation (both positive and negative)?, n=147. 

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136 

 
 
 
                                           
Evaluation of the Eel Regulation 

know” whether they agreed or disagreed with this statement (34.9% and 24.3%, respectively). We 
present the detailed results on efficiency in Figure 27 below.  

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 ( “neither agreed nor disagreed” and “didn’t know” answers) (30.3%). 

Figure 27: How efficient is the Eel Regulation? 

Q17: To what extent do you agree or disagree with the following statements? 

The same or better results in terms of eel stock recovery could
have been achieved at lower cost
It is possible to simplify the Eel Regulation and still achieve the
same results
The costs of administering and implementing the Eel Regulation
are proportionate to the environmental and socio-economic…
Administering and implementing the Eel Regulation has been
carried out at the lowest possible cost

8,6%

9,9%

19,1%

15,1%

25,7%

9,2%

26,3%

16,4%

13,2%

21,1%

5,9%

12,5%

23,7%

19,1%

17,1%

9,9%

15,8%

34,9%

6,6%

8,6%

strongly agree

rather agree / yes

neither agree nor disagree

rather disagree / no

strongly disagree

don't know

0%

25%

50%

75%

100%

n=152 
Most of the respondents were not able to assess the efficiency of the regulation in comparison with 
other policy instruments or mechanisms, as indicated in Figure 28 (54.6% responded that they “didn’t 
know”).  Among  the  remaining  respondents,  a  larger  proportion  disagreed  that  other  instruments 
provided better cost-effectiveness. 

Figure 28: How efficient is the Eel Regulation as compare to other instruments? 

Q18: Do you think that other policy instruments or mechanisms have provided better cost-effectiveness than has 
been achieved under the current Eel Regulation and associated Eel Management Plans? 

15,8%

29,6%

54,6%

agree / yes

disagree / no

don't know

n=152 
Respondent had the opportunity to provide examples of more cost-effective policy instruments and 
mechanisms in an open-ended question77, but only 15% of all respondents provided comments 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.  

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.  

77 Q19: If yes, what other policy instruments or mechanisms do you think would have been more cost effective?, n=23. 

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137 

 
 
 
                                           
Evaluation of the Eel Regulation 

Figure 29. How sustain are the effects of the Eel Regulation? 

Q20: Are the effects likely to last after intervention ends? 

30,9%

37,5%

31,6%

agree / yes

disagree / no

don't know

n=152 
General survey 

The  second  section  of  the  OPC  was  addressed  to  non-specialised  respondents. 78  Out  of  eight 
respondents  who  participated  in  the  survey,  one  indicated  that  they  had  never  heard  about  the 
problem of the decreasing European eel population compared to seven respondents who had.79 

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.80 

With  regards  to  specific  measures  to  recover  the  population  of  eel  in  Europe 81,  all  respondents 
supported facilitating fish migration through rivers; seven out of eight 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. 

Conclusions 

There is a significant imbalance in the number of respondents to the OPC 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 OPC were significant with 152 respondents and a 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. 82 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 (France). 

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

78 This section displayed to those who selected the answer: I am not familiar with the Eel Regulation. 
79 Q21: Before starting this consultation, had you ever heard about the problem of decreasing population of the European eel?, 
n=8. 
80 Q22: Do you support action by the European Union to regulate eel fishing to ensure the recovery of the species?, n=8. 
81 Q23: Do you support the following measures to recover the population of eel in Europe?, n=8. 

• 
• 
• 
• 
• 
• 

Limiting professional eel fisheries in the sea 
Limiting professional eel fisheries in freshwater 
Limiting recreational eel fishing in the sea 
Limiting recreational eel fishing in freshwater 
Facilitating fish migration through rivers 
Restocking waters with young fish 

82 Additionally,  20  contributions  were  submitted  to  the  evaluation  roadmap,  before  the  evaluation  started,  some  of  them 
highlighting 
the  Eel  Regulation, 
the  study.  See:  Feedback 
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447/feedback_en?p_id=223664. 

received  on:  Evaluation  of 

importance  of 

the 

June 2019 

138 

 
 
                                           
Evaluation of the Eel Regulation 

The measures to recover the population of eel in Europe were widely supported by respondents. 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  that  the  regulation  requires 
alternative  targets  to  ensure  it  delivers  on  its  objectives  and  two  thirds  indicated  that  it  requires 
amendment  or  simplification.  Suggestions  for  amendments  or  alternative  targets  include:  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 Member States managed to 
implement  Eel  Management  Plans,  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).  Similarly,  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. 
Nevertheless,  in  the  case  of  efficiency,  the  proportion  of  positive  responses  slightly  exceeded  the 
proportion of negative ones. With regards to coherence and sustainability, the opposite was the case.  

3. FEEDBACK TO EVALUATION ROADMAP AND AD HOC 

CONTRIBUTION 

An evaluation roadmap summarising the context, purpose and scope of the upcoming evaluation and 
outlining  the  expected  approach  was  published  at  the  Commission  website  prior  the  evaluation83. 
Stakeholders were able to provide feedback on the roadmap from 13 April to 11 May 2018. 

The feedback was provided by 16 stakeholder organisations (5 from Sweden, 3 from France and the 
UK each, 2 from Germany, 1 from Greece and Finland each, and 1 Brussels-based EU level organisation 
– Europêche)84 and two unaffiliated individuals (from Romania and the Netherlands). 

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

1.  A significance 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; 

83

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

1986447_en.  
84 Full list of organisations: Ålakustens Kulturarvsförening, Stockholm University - Baltic Sea Centre, ÅLFONDEN, 
Coalition Clean Baltic, The Fisheries Secretariat (Sweden); COREPEM, OP Estuaires, Comité National des Pêches 
Maritimes et des Elevages Marins (France); Glass Eels ltd., Lough Neagh Fishermen's Co-operative Society Ltd., 
Sustainable  Eel  Group  (UK);  Deutscher  Angelfischerverband,  Deutscher  Fischerei-Verband  (Germany);  APC 
Advanced Planning Consulting SA (Greece); Suomen luonnonsuojeluliitto (Finland); Europêche (Belgium). 

June 2019 

139 

 
 
                                           
Evaluation of the Eel Regulation 

4.  Insufficient  and  unequal  implementation  level  of  Eel  Management  Plans  (EMP)  in  Member 

States; 

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 (for instance in Sweden). 

Some of those issues were also raised in ad hoc 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  Dutch  and  French  governments  to  the  Public 
Consultations.  BSAC  underlined  a  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. 

4. TARGETED CONSULTATION 

4.1  Approach to consultation 
Targeted consultation was undertaken with key stakeholder groups across all relevant Member States 
to inform the evaluation of the Eel Regulation. Consultation focused on stakeholders that are directly 
impacted by the Eel Regulation (e.g. managing authorities responsible for developing, implementing 
and monitoring against EMPs, fishers and farmers, and those involved in eel restocking and trade), 
those  that  have  an  interest  in  the  implementation  of  the  Eel  Regulation  (e.g.  international 
organisations  such  as  bodies  implementing  CITES  and  the  CMS,  and  NGOs),  or  those  that  may  be 
under-represented in the public consultation (e.g. research bodies). 

Consultation with stakeholders was based upon one of three questionnaires, as follows: 

•  A questionnaire targeted at Member State managing authorities; 

•  Two  questionnaires  (simple  &  detailed)  and  targeted  at  Member  State  fisheries  control 

authorities; and 

•  A questionnaire targeted at all other stakeholders. 

The questionnaires were comprised of between 13 and 18 questions, covering the same themes (e.g. 
effectiveness of the Eel Regulation, successes of and barriers to implementation of the Eel Regulation), 
but  questionnaires  issued  to  managing  and  control  authorities  sought  additional  feedback  on  the 
implementation of EMPs and control measures that support the Eel Regulation. 

Consultation was 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  (Denmark,  France  and  Italy)  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 Member States, and to a 
variety  of  stakeholders,  as  shown  in  Figure  30.  Almost  50%  of  questionnaires  were  issued  to 
stakeholders  in  six  Member  States  (Italy,  United  Kingdom,  Belgium,  Sweden,  the  Netherlands  and 
Germany), with lesser numbers of questionnaires issued to stakeholders in the remaining 18 MS. 

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140 

 
Evaluation of the Eel Regulation 

Figure 30: Questionnaire distribution by stakeholder category  

4.2  Respondents profile 

Around  80  responses  to  questionnaires  were  received.  Responses  were  received  from  stakeholders 
across 15 Member States  from a variety of stakeholders as  shown in Figure 31, and  over 40% of 
responses were received from respondents in Italy and the Netherlands, reflecting to some extent the 
distribution of questionnaires. 

Figure 31: Questionnaires received by stakeholder category 

June 2019 

141 

 
4.3  Targeted consultation results 

Evaluation of the Eel Regulation 

Responses  to  questionnaires  were  collated  in  a  database  and  analysed.  Almost  all  respondents 
reported that the Eel Regulation remains highly relevant given the critical status of the eel population. 
It  has  usefully  driven  forward  the  preparation  of  Eel  Management  Plans  in  Member  States  and 
established  common  targets  for  eel  recovery.  Many  stakeholders  considered  the  Eel  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 Member States to address non-fisheries anthropogenic mortality. 

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.  Stakeholders  typically  acknowledged  that  the  Eel 
Regulation  has  usefully  driven  forward  the  preparation  of  Eel  Management  Plans  within  Member 
States,  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 Member States. In the majority of Member States, 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 improved reporting on progress against EMP targets, should be encouraged, as 
should the sharing of any recognised good practices or key research findings across Member States. 

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. 

Stakeholders held mixed views around the coherence of the Eel Regulation with EU and international 
initiatives, and 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 Member State 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 central coordinating body for the 
recovery of the European Eel, the need for a more cohesive funding approach to implement EMPs and 
associated management measures, and the need for greater efforts to raise the profile of eel and its 
critical status. 

June 2019 

142 

 
 
 
Evaluation of the Eel Regulation 

ANNEX 6: REVIEW OF THE AMENDMENTS PROPOSED BY THE 
COMMISSION FOR THE REFIT OF THE EU FISHERIES CONTROL 
SYSTEM 

The first two columns of the table are a reproduction of the table presented by the Commission in its 
proposal for an amendment to the EU fisheries control system (COM(2018) 368 final – page 7 to 12). 
Text  displayed  in  the  column  titled  “Added  value  of  the  proposal  in  the  case  of  eels”  is  our  own 
elaboration  to  highlight  the  contribution  of  the  proposal  to  an  improved  EU  control  system  of  eel 
fisheries  as  relevant.  Green  characters  are  used  to  denote  improvements,  red  characters  denote 
suggested points of vigilance. 

Amendments  to  Council  Regulation  (EC)  No  1224/2009  establishing  a  Union  control  system  for 
ensuring compliance with the rules of the common fisheries policy 
TOPIC 1: ENFORCEMENT 

Added value of the proposal in the case of eels 
Will support enforcement of the Eel conservation measures + future JDP 
performances 

Will  support  enforcement  of    Eel  conservation  measures  for  marine 
fisheries. Other sanctions (administrative and criminal) remain under MS 
competence. 

Subtopic 
Inspection and 
surveillance 

Sanctions 

Articles  
Amended: 
73,  74,  75, 
76,  77,  78,  
79, 80 
New:  
89a,  91a, 
91b,  92a, 
92b, 
Annexes III 
and IV 

Amended: 
82,  85,  90, 
91, 92 

Logbook  

Vessels below 12 
metres 

TOPIC 2:  DATA AVAILABILITY, QUALITY AND SHARING  
Articles 
Subtopic 
Amended:4
Vessel's tracking 
, 9, 10, 12 
New: 9a 
Amended:1
4 
Amended:9
, 14, 15 
New: 15a 
Amended:  
20, 21, 22,  
23, 24 
Deleted: 
16, 25, 28 
Amended: 
17, 19 
Deleted: 18 
New: 19a 

Transhipment 
declaration and 
landing declarations 

Prior notification 

Specific provisions of the proposal 
Proposed tracking specifications will benefit to control of Eel fisheries as 
almost all vessels concerned are less than 12 m. 

Probably of little use for the Eel Regulation as most vessels are less than 
12 m, not subject to logbooks. 
Very  supportive  for  control  of  Eel  concervation  measures  although  the 
tolerance margin for catches of less than 50 kg (20%) seems high (for 
glass eel fishing, the average catch is ≈ 1.5 kg per fishing trip). 
Very supportive for the Eel Regulation in relation to sales notes, assuming 
no derogation will be granted in the case of fishing vessels targeting eels 
(as proposed Art. 24.5 a) 

Probably of little use for the Eel Regulation. Extension of prior notification 
to  vessels  <  12  m  under cerain  circumstances  (e.g.  multiannual  palns) 
could have been an useful tool for MS control authorities in the case of 
eels. 

Control of 
recreational 
fisheries 

Traceability 

Amended: 
4, 55 

Amended: 
4,  56,  57, 
58 
New: 56a 

Very supportive for control of Eel concervation measures as recreational 
catches may be significant in some MS,  underlining that the exemption 
for  control  of  recreational  fishing  from  shore  in  the  current  Control 
Regulation seems to have been removed.  
Very supportive for control of Eel concervation measures as traceability 
along  the  chain  is  currently  difficult  to  establish  for  eels  as  for  any 
fisheries  and  aquaculture  products.  However,  the  5  kg  derogation  for 
traceability of sales to consumers may be set too high in the case of glass 
eels. The scope of the traceability system will also need to be clarified in 
relation to diadromous species (fishing, aquaculture) 

June 2019 

143 

 
 
 
 
 
 
Amended: 
6, 7 
New: 25a  
New: 39a 
Amended: 
38, 41 
Deleted: 
46,  Annex 
1 
Amended:5
5 
New: 93a 

Amended:1
4, 43, 55 

Evaluation of the Eel Regulation 

New  weighing  clauses  adequately  support  Eel  conservation  measures. 
However, the derogation permitted for unsorted landings not destined for 
human  consumption  may  not  be  desirable  in  the  case  of  glass  eels 
intended for restocking. 
New  prescriptions  for  transport  documents  and  take-over  declarations 
very supportive for control of Eel conservation measures. 
However, the 5 kg derogation for sales notes may be set too high in the 
case of glass eels 
Will support transnational enforcement of the Eel conservation measures 
+ future JDP performances 

Weighing, transport 
and sales 
procedures and data 

Data availability and 
exchange 

Amended: 
59,  60,  62, 
64,  65,  66, 
68 
New: 59a, 
60a 
Deleted: 
61, 63, 67 
Amended: 
33, 
34, 
109,  110, 
111,  112, 
114 
and 
115 
New:111a;  
112a  
Deleted: 
116 

Specific provisions of the proposal 

Amended:4  No comment 

Articles 

TOPIC 3: BRIDGING THE GAPS WITH THE CFP  
Subtopic 
Definition of ‘rules 
of the common 
fisheries policy’ 
Fishing licence and 
fishing authorisation 
Landing obligation 
Fishing capacity 

No comment 
No comment 

No comment 

National control 
programmes and 
annual reports 

Revised  Regulation  include  recreational  fisheries,  which  will  support 
control of eel conservation measures. 

TOPIC 4: SYNERGIES WITH OTHER POLICIES 
Fishing gears 

Provisions  on  the  marking  and  control  of  fishing  gears  for  recreational 
fisheries  will  support  control  of  eel  measures  (numerous  occurences  of 
eel poaching with traps reported by MS) 

Fishing restricted 
areas 
TOPIC 5: ALIGNMENT WITH THE LISBON TREATY 
No comment 
Alignment  with  the  
Lisbon Treaty  

Amended: 
4, 50 

Numerous 
Articles 
amended 
or 
introduced 

Amendments  to  Council  Regulation  (EC)  No  768/2005  establishing  a  European  Fisheries  Control 
Agency 

Topic 

Articles  

Specific provisions of the proposal 

Alignment to CFP 

Amended:2 
and 3 

Agency's inspection powers in the EU territory will support control of eel 
CFP measures 

Exchange of data 

Amended:1
7 

Amended:1
6 

No comment 

Alignment to 
Common approach 

Amended:2
6, 29, 39 

No comment 

June 2019 

144 

 
 
 
Evaluation of the Eel Regulation 

on EU decentralised 
Agencies 

Budget 

Amended:3
5  

No comment 

Amendment to Regulation (EC) No 1005/2008 establishing a Community system to prevent, deter 
and eliminate illegal, unreported and unregulated fishing 

Topic 

Articles  

Specific provisions of the proposal 

Digitalisation of IUU 
catch certificate 
(CATCH) 

Inspections 

Fishing vessel 
engaged in IUU 
fishing 

New:  12a 
to 12e 

Potentially useful external if trade prohibition is lifted. However, eels are 
only partially covered by the catch certification scheme. 

Amended: 
10 

Amended: 
2, 3, 11 

No comment 

No comment 

No comment 

Proceedings and 
enforcement 
measures (including 
serious 
infringements) 

New:  42a, 
Amended: 
27, 42, 43 

Deleted: 44 
to 47 

Amendment to Council Regulation (EC) No 1967/2006 concerning management measures for the 
sustainable exploitation of fishery resources in the Mediterranean Sea 

Amendment to Regulation (EU) 2016/1139 establishing a multiannual plan for the stocks of cod, 
herring and sprat in the Baltic Sea and the fisheries exploiting those stocks 

Topic 

Articles  

Specific provisions of the proposal 

Regulation (EC) No 
1967/2006 

Amended: 
17  

No  comment  (proposed  changes  streamline  concepts  of  recreational 
fisheries across sea-basins) 

Regulation (EU) No 
2016/1139 

Deleted: 
21, 23 

Deleted: 
12, 13  

No comment 

June 2019 

145 

 
 
 
 
 
ANNEX 7: CASE STUDIES 

Evaluation of the Eel Regulation 

France 

Italy 

Denmark 

June 2019 

146 

 
Evaluation of the Eel Regulation 
Specific Contract No. 10 
under Framework contract 
EASME/EMFF/2016/029 

France Case Study 

A fisherman unloading baskets of eels at Le Logeo on the Gulf of Morbihan, Brittany, France 

Cover photo credit: Stephen Dorey / Alamy Stock Photo) 

 
 
 
 
 
 
 
ACRONYMS/ABBREVIATIONS 

Acronyms/ 
Abbreviations 

Definition 

AFB 

ARA 

CEREMA 

CMEA 

Agence Française pour la Biodiversité 

Association pour le Repeuplement de l'Anguille en France 

Centre d'Études et d'Expertise sur les Risques, l'Environnement, la Mobilité 
et l'Aménagement 

Commission pour le Milieu Estuarien et les poissons Amphihalins 

CNPMEM 

Comité National des Pêches Maritimes et des Elevages Marins 

CONAPPED 

Comité National des Pêcheurs Professionnels en Eau Douce 

DEB  

DEB 

DPMA  

DPMA 

EDA 

EFF 

EMFF 

EMP 

EMU 

FR 

INRA 

LEMA 

MFSD 

MNHN 

PGA 

Direction de l’Eau et de la Biodiversité / Ministère de la Transition Ecologique 
et Solidaire 

Direction de l’Eau et de la Biodiversité  

Direction de la Pêche Maritime et de l’Aquaculture / Ministère de l’Agriculture 

Direction de la Pêche Maritime et de l’Aquaculture 

Eel Density Analysis  

European Fisheries Fund 

European Maritime and Fisheries Fund 

Eel Management Plan 

Eel Management Unit 

France 

Institut National de Recherche Agronomique 

L'Eau et les Milieux Aquatiques85 

Marine Strategy Framework Directive 

Muséum National d'Histoire Naturelle 

Plan de Gestion de l'Anguille 

RAMSAR 

International Convention on Wetlands 

ROE 

WFD 

Référentiel des Obstacles à l’Écoulement 

Water Framework Directive 

85 See https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000000649171  

June 2019 

cxlviii 

 
 
                                           
1. OVERVIEW OF THE CASE STUDY 
INTRODUCTION 

This  report  on  France  is  one  of  three  case  studies  (the  others  being  Denmark  and  Italy)  being 
conducted by this evaluation.  The case studies provide more detailed insight into the implementation 
of the Eel Regulation at national, regional and local levels, beyond the information gathered through 
the  synthesis  of  the  EMPs  and  their  progress  report,  and  the  targeted  consultation  with  the  other 
Member States. They are intended to: 

•  Understand the extent to which measures under the 2009 Eel Management Plans (EMPs) 

have been able to address the main objectives of the Eel Regulation 

•  To determine whether the Eel Regulation, and the responses detailed by the EMPs, remain 

relevant to the drivers and pressures relating to the recovery of the European eel stock, and 
the extent to which they can be addressed by the EU alone. 

•  To assess what additional or alternative measures might be taken to achieve the objectives of 

the Eel Regulation. 

•  To assess added value of the Eel Regulation and the sustainability of the measures being 
undertaken through the EMPs and their long-term impact after the interventions have 
ceased. 

METHODOLOGY 

This case study has been conducted through a mixture of a review of background information (such 
as EMP Progress Reports, scientific reports and other relevant studies) and face to face and telephone 
interviews  guided  by  semi-structured  questionnaires.  The  interviews  were  with  a  mixture  of 
participants,  with  representatives  of  national  and  regional  administrations  and  the  industry  (main 
national professional organisations and where possible a few operators).  

For a list of entities interviewed, see the table below.   

Table 1: Entities interviewed in support of the case study  

Organisation / function 

DPMA – Sous-Directeur 

DPMA – desk EMP for marine fishing issues 

DPMA – Aquacuture (restocking) 

DPMA – Control  

MNHN / Research 

INRA-AFB / Research 

CNPMEM (prof. organisation marine fishermen) – desk diadromous fisheries 

Prof. fisherman – Member CNPMEM Commission for diadromous species 

ARA France (restocking)  

CONAPPED (prof. organisation freshwater fishermen) 

DEB  

Fédération Nationale de la Pêche en France (FNPF)  

 
 
 
 
 
Table 2: Document sources 

Document reference  

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 

Amilhat E., Simon G., Faliex E., (2017). Rapport technique du suivi scientifique des relâchers 
d’anguilles argentées menés en Méditerranée en 2015/2016. CEFREM Université de Perpignan Via 
Domitia. 58pp. 

Besse (2017) – Turbines ichtyophiles et dispositifs d’évitement pour les anguilles en avalaison. 
Tableau de Bord Anguille du Bassin Loire (LOGRAMI) 

Briand, C., P-M, C., Beaulaton, L., Drouineau, H., Lambert, P. (2018) Eel density analysis (EDA 
2.2.1). Escapement of silver eels (Anguilla anguilla) from French rivers. 2018 report.DE  

CEREMA (2016) Impact à la dévalaison de l’anguille des centrales hydroélectriques de grande 
capacité de l’aval de la Seine.  

FranceAgriMer (2014) Le marché de l’anguille européenne. Rapport Service Marchés et Études de 
Filières 

Mathieu A., Babut M. (2012) Contamination des poissons d’eau douce par des contaminants 
persistants - Etude des relations biote-sediment (PCB). Onema – Irstea, Vincennes, 42 p. 

Ministère de la Transition Ecologique et Solidaire (2017) – Appel à projets 2017-2018 pour la mise 
en œuvre du programme de repeuplement de l’anguille en France 

Plan de gestion anguille de la France – rapport de mise en œuvre – juin 2018 

Plan de gestion anguille de la France – rapport de mise en œuvre – juin 2015 

Plan de gestion anguille de la France – rapport de mise en œuvre – juin 2012 

Plan de gestion anguille de la France – Volet national – 2010 

Rigaud, C., Beaulaton L., Briand, C., Charrier F., Feunteun E., Mazel V., Pozet F., Prevost E., 
Treguier A., & Verreault G., 2015. Le programme français de repeuplement en civelles. Bilan des 
trois premières années de transferts. GRISAM, 229 pp. 

 
 
 
 
 
2.  OVERVIEW  OF  EEL  PRODUCTION,  MANAGEMENT  AND 
CONSERVATION IN FRANCE  
EEL PRODUCTION AND TRADE  

Wild production 

Professional fishermen 

The  next  table  shows  available  eel  catch  data  according  to  their  different  stages  and  to  the 
environment in which catches were obtained. For some entries, catch data are available on a fishing 
period basis (e.g. 2015-2016 to cover winter season) or on a calendar year basis.  

Table 3: Eel catches in France 

Tonnes 

Marine waters 

Freshwater 

2014-
2015 

2015-
2016 

2016-
2017 

2017-
2018 

2014-
2015 

2015-
2016 

2016-
2017 

2017-
2018 

2015 

2016 

2017 

2018 

2015 

2016 

2017 

2018 

31.2 

41.1 

40.0 

na 

3.9 

5.2 

6.0 

5.1 

240.1 

303.1 

264.3 

na 

29.0 

26.7 

16.1 

na 

74.5 

91.3 

104.0 

66.9 

0.8 

12.0 

0.8 

345.8 

435.5 

408.3 

33.7 

43.9 

22.9 

Glass 
eel 

Yellow 
eel 

Silver 
eel 

Total 

Source: Rapport PGA France 2018 
Note : data in italic refer to fishing period 

Catch data do not take into account restocked glass eels and released silver eels 

While  catches  by  professional  fishermen  in  marine  and  freshwater  are  estimated  to  be  correctly 
monitored, there are some doubts over the statistical coverage of eel catches in freshwaters in view 
of  the  large  differences  between  the  number  of  licensed  recreational  fishermen  having  declared 
catches and the total number of licensed fishermen. 

The main Eel Management Units (EMUs) where catches have been obtained in 2016-2017 or in 2017 
are  shown  below.  For  glass  eel,  the  Loire,  Côtiers  Vendéens  et  Sèvre  Niortaise  (LCVS)  is  the  main  EMU, 
preceding the Garonne, Dordogne, Charentes, Seudre, Leyre (GDC) EMU. Concerning yellow and silver eels, most 
catches originate from the Rhône Méditerranée (RMD) EMU. 

Table 4: Main Eel Management Units from which catches from professional fishermen have 
been obtained 

Tonnes 

Marine waters 

Freshwater 

Life phase 

Glass eel 

LCVS  (20.0)-GDC  (10.8)-
BRE (5.8) 

ADR (3.0) - LCVS (1.8) - 
GDC (1.3)  

Yellow eel 

RMD (238.7)-LCVS (15.1) 

LCVS (12.4)-GDC (2.2) 

Silver eel 

RMD (102.8)-Corse (1.2) 

na 

Source: Rapport PGA France 2018 
Note : LCVS : Loire, Côtiers Vendéens et Sèvre Niortaise / BRE : Bretagne / ADR : Adour, Cours d’eaux côtiers / 
GDC : Garonne, Dordogne, Charentes, Seudre, Leyre / RMD : Rhône Méditerranée 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure1: Eel Management Units defined in France 

Source: ONEMA in Rapport PGA France 2018 

Aquaculture  

There is no eel aquaculture in France, neither commercial nor for growing before restocking. 

Trade in eels 

According to FranceAgriMer (2014)86, the main markets for wild eels caught in France and intended 
for consumption are as follows: 

•  Concerning glass eels, the main market for human consumption is the Intra-EU export market 
(no or insignificant domestic market). For direct human consumption, glass eels are exported 
to Spain. For glass eels intended for aquaculture, main markets are Netherlands, Denmark and 
Germany,  but  also  Spain,  Greece  and  Italy).  For  glass  eels  of  less  than  12  cm  intended  for 
restocking,  markets  are  France  and  Northern  and  Eastern  Europe  Member  States  including 
Netherlands, Germany, Denmark and Poland according to EU trade statistics. According to PGA 
(2018), average first sale prices of glass eels are in the region of EUR 240 / kg for restocking 
and EUR 380 / kg for consumption (average 2017-2018 fishing season). Before CITES listing, 
live glass eels were sold in the region of 3 000 EUR / kg on the Asian market. 

•  Concerning  yellow  and  silver  eels,  the  main  market  is  the  domestic  market  (restaurants, 
retail shops) with some eels being exported to Italy. Retail prices on the domestic market are 
reportedly around EUR 30 / kg for whole eels. 

86 FranceAgriMer (2014). Insights into the European eel market chain.  June 2014. 52 pp. 

 
 
 
 
 
 
 
 
                                           
EEL MANAGEMENT PLAN 

Key measures and approaches 

The French EMP has a comprehensive geographical coverage. The plan encompasses all marine and 
freshwater areas of the national territory up to 1,000 m elevation, including Corsica. The geographical 
scope includes all areas under national jurisdiction where eels are expected to be found. 

The French EMP considered several key measures i) to reduce eel mortality attributable to fishing in 
marine and freshwater environment with specific reduction targets of 40% in 2012 and 60% in 2015 
for glass eels, and 30% in 2012 and 60% in 2015 for yellow and silver eels, ii) to reduce mortality 
attributable to other anthropogenic sources with a specific target of 30% in 2012, 50% in 2015 and 
75% in 2018, and iii) to enhance stock rebuilding through restocking of glass eels with a specific target 
of 35% in 2010 and 60% in 2015, including 5 to 10% for restocking French waters. 

Measures to reduce eel fishing mortality 

Spatial restrictions on fishing 

Fishing for glass eel is authorised for professional fishermen only in EMUs concerning the North Sea / 
English  Channel  /  Atlantic  side.  Glass  eel  fishing  is  prohibited  in  Mediterranean  EMUs  and  for 
recreational fishermen in any EMU.  Fishing for yellow eel is authorised in all EMUs for professional 
and recreational fishermen. 

Fishing for silver eels is authorised in Mediterranean EMUs only for professional fishermen in marine 
waters (including coastal lagoons), in some rivers and waterbodies of LCVS, BRE and RMD EMUs for 
professional fishermen in freshwaters, and prohibited for recreational fishermen in any EMU. 

Temporal restrictions on fishing 

Fishing for eels at different stages is allowed only during certain periods which vary according to EMUs. 
For  example,  for  BRE  EMUs,  fishing  for  glass  eels  is  allowed  between  1st  December  and  30th  April, 
fishing  for  yellow  eel  allowed  between  1st  April  and  31st  August  in  rivers  and  15th  April  and  15th 
September in marine waters, and fishing for silver eels allowed between 1st October and 15th January 
in certain rivers (silver eel fishing is prohibited as per spatial restrictions detailed above). For RMD, 
fishing  for  yellow  eel  has  different  opening  periods  (ex.  1st  March-15  July  and  1st  September-15 
January) and fishing for silver eel open between 1st October and 1st March. There is no EMU in which 
fishing for eel is allowed year-round. 

For recreational fishermen, fishing for yellow eel is authorised only during certain periods of the year. 

Fishing authorisations 

Professional  and  recreational  fishermen  are  subject  to  a  specific  authorisation  scheme.    Maritime 
professional  fishermen  targeting  eels  in  English  Channel  /  Atlantic  areas  must  have  a  specific 
authorisation  called  Licence  CMEA  (CMEA  for  Commission  pour  le  Milieu  Estuarien  et  les  poissons 
Amphihalins)  to  fish  for  eel  and  diadromous  species  in  marine  and  estuarine  waters.  Fishing 
authorisations are managed by CNPMEM and its regional declinations. Fishing authorisations specify 
inter  alia  the  biological  stage  (glass  and/or  silver)  and  the  authorised  fishing  area.  Freshwater 
professional  fishermen  targeting  eels  must  have  a  specific  (different)  fishing  authorisation.  In  the 
Mediterranean, there is also a specific fishing authorisation scheme but managed by the Préfet. 

Recreational fishermen targeting eels with fishing gears (traps or nets) in freshwater are subject to a 
fishing authorisation regime. There  are no such authorisation regimes for  recreational fishermen in 
marine waters as catches are estimated to be insignificant. Recreational fishermen targeting eels in 
freshwater  with  hook  and  line  also  need  an  authorisation  with  a  specific  authorisation  to  catch 
diadromous species. According to information available, about 4 200 recreational fishermen obtained 
the  authorisation  to  catch  diadromous  species  out  of  a  total  population  of  1 500 000  recreational 
freshwater fishermen. 

 
 
 
 
Catch limits 

Catch  quota  for  glass  eels  are  enforced  since  the  2009-2010  season  for  marine  and  freshwater 
components of the fishery. There are no catch quota enforced for yellow and silver eels. Catch quota 
for glass eels are set according to scientific advice taking into account recruitment and exploitation 
rate. The national catch quota agreed is distributed: 

•  Between marine and freshwater glass eel fisheries on the basis of a 87%/13% distribution key 

•  Between consumption and restocking according to a 40%/60% distribution key aligned with 

EMP prescriptions 

•  Between EMUs on the basis of a constant regional distribution key ensuring relative stability. 

Quota  uptake  is  monitored  on  the  basis  of  catch  declarations  from  fishermen  cross-checked  with 
purchase notes submitted by authorised buyers. In 2018, there were ≈ 10 legal entities authorised to 
buy glass eels in France. 

There are no catch quota for yellow and silver eels. 

Other measures contributing to reduce fishing mortality 

Public  health  measures  adopted  to  reduce  consumer’s  exposure  to  PCB,  an  environmental  toxin 
classified as a persistent organic pollutant, led to close certain freshwater areas to yellow and silver 
eel fishing with a compensation scheme implemented for freshwater professional fishermen impacted. 
Eels are among the largest PCB bio-accumulator given their diet and long life-cycle. 

Measures to reduce eel mortality attributable to other anthropogenic sources 

Ecological continuity of rivers 

Following adoption of the EU WFD, France adopted end of 2006 a National law to transpose WFD (i.e. 
Loi sur l’Eau et les Milieux Aquatiques – LEMA). Among the measures adopted, the LEMA enforced a 
classification of rivers into two categories: 

•  Category 1 rivers including rivers (and waterbodies) evaluated as in a good status, including 
in relation to ecological continuity, and for which any new work likely to undermine ecological 
continuity is prohibited. Category 1 rivers represents 30% of total river length in France. 

•  Category  2  rivers  including  rivers  for  which  ecological  continuity  must  be  restored  with  any 
existing or new work managed, equipped and maintained to ensure ecological continuity within 
a 5-year delay. Category 2 rivers represent 11% of total river length in France 

Classification  of  rivers  has  been  carried  out  at  regional  level  on  a  water  basin  basis  under  Préfets 
authority. The first official lists of rivers according to LEMA classification has been published through 
Arrêtés in 2012 (e.g. LCVS, BRE), then in 2013 (e.g. RMD, ADR) and finally in 2015 (Corsica). The 
publication of lists marked the start of the mandatory 5-year period to improve ecological continuity 
of category 2 rivers. The delay has been extended by another 5 years in 2018 when it became clear 
that the initial time-frame was unrealistic. 

Under the FR EMP, priority areas for eel restoration had been defined based on multicriteria analysis 
(left hand side of the next figure) and this supported identification of certain category 2 rivers. The 
identification of category 2 rivers considered additional rivers with eels as target species for restoration 
of ecological continuity (right hand side of the next figure). 

In  parallel,  French  authorities  (Agence  Française  de  la  Biodiversité  –  AFB)  started  a  census  of  all 
obstacles to river flows. As of 2015, 80 000 works have been inventoried with results published online, 
including  15 000  in  category  2  rivers.  Among  these,  close  to  10 000  concern  works  on  category  2 
rivers with eel as target species for restoration.  

 
 
Figure  2:  Priority  areas  for  eel  restoration  (left)  and  category  2  rivers  with  eel  as  target 
species for restoration of ecological continuity (right) 

Source: FR EMP and Rapport PGA France 2018 

Temporary switch off of hydro-electric turbines 

Hydro-electric  turbines  are  known  to  be  a  significant  source  of  mortality  for  migrating  silver  eels 
(CEREMA, 2016). There a high number of hydro-electric turbines in France, the larger ones are owned 
by public companies, but there is also a fairly high number of hydro-electric turbines privately owned. 
Private hydro-electric turbines have been developed under government incentive to develop renewable 
energies in France. 

French authorities implement a programme to impose temporary switch-off of electric turbines during 
the peak of silver eels migrating seasons. Research has also been supported to develop models of eel-
compatible turbines (Besse, 2017) that could equip new installations, or replace existing turbines. 

Elimination of micropollutants 

Concerning PCB, an action plan has been implemented between 2008 and 2014 as foreseen by the 
WFD.  The  action  plan  included  sampling  of  PCB  concentrations  in  eels  (and  other  freshwater  fish 
species). Results led to close certain rivers to eel fishing, in particular in the RMD EMU, and to issue a 
general  recommendation  to  avoid  consumption  of  wild  yellow  and  silver  eels  in  view  of  the  high 
concentrations detected. 

A new action plan covering the 2016-2021 period has been adopted. The plan takes into account EU 
WFD  and  EU  MFSD  prescriptions.  It  aims  at  reducing  micropollutant  concentrations,  including  drug 
residues.  Fight against pesticides is the objective of a different action plan (Ecophyto). 

Research is ongoing to establish the impacts of pollutants on eel life cycles. Pollutants may generate 
mortalities and/or modify eel biology with impacts on its maturation / reproductive capacities. 

Measures to restore eel habitats 

Measures to preserve and restore inland eel habitats consider measures for monitoring rivers flows 
and for protecting and restoring wetlands in line with the RAMSAR convention87. 

87 The Ramsar is an international treaty for the conservation and sustainable use of wetlands ratified 
by France in 1986.  

 
 
 
 
 
 
 
 
                                           
Fighting predators 

Two main predators are identified in the FR EMP: 

•  The great cormorant (Phalacrocorax carbo sinensis) a protected species according to the EU 
Bird Directive. However, in view of their impacts on inland aquaculture stocks, a derogation 
allowing  the  destruction  of  about  21 200  specimens  per  year  has  been  granted  by  FR 
authorities. The need for an EU management plan for great cormorant has been reported by 
FR authorities. 

•  European catfish (Silurus glanis) is an invasive freshwater fish species reported to prey on eels 
and other freshwater species (e.g. salmons), in particular when they concentrate in fish pass. 
European  catfish  can  be  fished  but  with  some  restrictions,  and  FranceAgriMer  launched  a 
market  study  to  find  market  outlets  for  professional  fishermen  to  increase  economic 
attractiveness of the species. 

Measures to enhance stock rebuilding 

Eel restocking of FR EMUs 

As envisaged by the EU Eel Regulation, measures to support eel restocking have been implemented. 
Glass eel quota include a 60% share for eels intended for restocking in France and in other Member 
States.  The  national  restocking  programme  implemented  as  from  2011  consist  in  transferring  5  to 
10% of glass eels caught on the FR territory to habitats in good ecological status with good potential 
for growth (low eel natural density) and reduced sources of mortality until the seaward migration to 
ensure  contribution  to  the  EMP  general  objective.  Restocking  operations  are  organised  under  the 
coordination of an association, the Association  for the Repeuplement des Anguilles (ARA France) in 
close cooperation with relevant scientific institutes. 

Eel  restocking  operations  are  implemented  through  annual  public  call  for  projects  under  scientific 
supervision defining the best areas for restocking, a protocol for glass eel handling and a protocol for 
monitoring  the  results  of  restocking  operations.  Annual  budget  for  restocking  operations  is  EUR  2 
million, with price of glass eels purchased to fish merchants capped at EUR 350 / kg comprising price 
paid to fishermen, costs for stocking, health analysis, conditioning and transport. Selected projects 
can receive up to 96% of eligible costs in public funding if the beneficiary is a public organisation, 80% 
if the beneficiary is a private entity The  annual budget is a State Aid duly declared as such to the 
Commission (case SA 40944).  

Only EMUs where glass eels are caught are eligible to the restocking programme to avoid spread of 
diseases. This means that Mediterranean EMUs where glass eel fishing is prohibited cannot receive 
glass eels from other regions. 

Release of silver eels 

In the Mediterranean, a programme consisting in releasing silver eels caught in coastal lagoons during 
their seaward migrations in the open sea has been implemented as from 2011. Silver eels are paid 
using  public  funds  to  fishermen  at  a  fixed  price  set  at  the  beginning  of  the  fishing  season.  Annual 
budget  is  EUR  420 000  per  year,  considered  as  de  minimis  aid  as  provided  for  by  the  relevant 
Commission Regulation88. Release operations are implemented under a scientific supervision defining 
protocols for verifying the quality and the handling methods of the silver eels. 

Release operations are used to collect scientific information on silver eels, including on their survival 
rate and migration path once in the sea.  

88 Commission Regulation (EU) No 717/2014 of 27 June 2014 on the application of Articles 107 and 
108  of  the  Treaty  on  the  Functioning  of  the  European  Union  to  de  minimis  aid  in  the  fishery  and 
aquaculture sector 

 
 
 
 
                                           
Progress to date 

Progress toward the general objective of EMP 

Silver  eel  biomass  relative  to  the  best  estimate  of  escapement  that  would  have  existed  if  no 
anthropogenic influences had impacted the stock is evaluated through complex modelling (Eel Density 
Analysis – EDA). Data collected to feed the model include surveys of selected rivers to collect data on 
presence and biological characteristics of eels at all stages and available data on past eel catches and 
recruitment levels.  

The main conclusion drawn is that all EMUs are still in the red zone (biomass less than 40% of B0, 
very  significantly  for  some  EMUs,  and  mortality  higher  than  objective  of  0.92),  which  is  in  part 
explained by the fact that the current silver eel biomass includes eels born before the implementation 
of protection measures. It is estimated that the results of the eel plan will be visible only as from 2020 
when glass eel born from eels under the management plan (see graph below) will enter French rivers. 

Figure 3: Forecast for the results of the French EMP 

Source: Agence Française pour la Biodiversité 

However, the model outputs show that mortality reductions achieved since the implementation of the 
plan  support  progresses  toward  the  40%  B0  objective.  Although  this  objective  may  not  be  fully 
achieved, fishing mortality is estimated as at levels likely to contribute to stock rebuilding in the longer 
term. 

However, the accuracy of the model results is undermined by several shortcomings:  
•  There are not enough surveys sites for sampling downstream migrations 
•  The main sampling method (electric fishing) can sample only shallow areas (≈ 70 cm), and is 

not adequate to sample deep areas 

•  Large areas are not covered by the model, including coastal zones, Mediterranean lagoons or 

Gironde estuary to cite only the main 

•  Uncertainty on the value of natural mortality parameter input in the model; 
•  Measures of accessibility of rivers do not take into account fish pass, and; 

•  Failure  to  include  other  sources  of  mortality  including  pollution,  wetland  areas  reductions, 

predation and hydroelectric turbines induced mortality 

Each of these shortcomings have different consequences on model outputs (over or underestimate of 
biomasses), but to a yet unknown extent. 

 
 
 
 
In  conclusion,  the  situation  of  France  with  respect  to  the  general  EMP  objective  is  uncertain  as  a 
consequence  of  the  difficulties  to  obtain  reliable  estimates  of  B0  and  of  Bcurrent  of  silver  eels. 
Nonetheless, estimates available show that France is still short of the EMP general objective, but that 
mortality reduction achieved, mainly through reductions of fishing mortality, may support rebuilding 
of the stock in the longer term, which is the objective of the EMP. 

Progress toward reduction of fishing mortality 

The various measures implemented to limit fishing (inter alia time-area closures, licencing and catch 
quota  policy)  supported  dramatic  reduction  of  the  amounts  of  eels  caught,  in  particular  glass  eels, 
compared to the period preceding the implementation of the EMP. 

The number of fishing authorisations has been decreased over the past few years to reduce fishing 
mortality. The next table shows that fishing authorisations for glass eels decreased by 51% over the 
2006-2018 period for glass eels in marine waters and 71% for glass eels in freshwaters, and by 57% 
overall.  Phasing  out  of  marine  fishermen  has  been  supported  by  permanent  cessation  schemes 
implemented  under  EFF  and  EMFF.  According  to  FR  authorities,  costs  for  decommissioning  vessels 
fishing for eel in maritime waters was in the region of EUR 10 million. 

Table 5: Number of fishing authorisations granted for glass eel fishing between 2006 and 
2018 

6
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

Marine fishermen 

853  643  573  500  475  457  413  420  437  417 

Freshwater fishermen 

371  180  158  147  145  129  126  112  109  109 

-
6
0
0
2

8
1
0
2

-51% 

-71% 

Total 

1 224  823  731  647  620  586  539  532  546  526 

-57% 

Source: Rapport PGA France 2018 

The number of fishing authorisations for yellow and silver eels have also been decreased. Its number 
went down from 1 330 in 2006 to 785 in 2018, a 40% reduction. 

As shown in the figure below, the glass eel quota has been reduced from 44.6 tonnes for the 2010-
11 season to 34 tonnes for 2012-2013. It has been subsequently increased up to 75 tonnes in 2014-
15 underpinned by higher glass eel recruitment levels and consideration of an optimistic scenario. The 
quota  was  then  decreased  and  set  at  64.7  t  for  2016-2017  and  conservatively  carried  over  at  the 
same level for 2017-2018 and 2018-2019 fishing seasons although available evidences suggested that 
recruitment had improved. Total quota uptake  (on a fishing season basis) has  remained below the 
100% limit. However, data published in PGA (2018) suggest that the consumption quota was exceeded 
between 2010 and 2014 (up to 140% in 2012-2013), but not since, with the restocking quota was 
consistently underused over the whole period. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
92%

93%

79%

82%

81%

84%

71%

48%

80 000

70 000

60 000

50 000

g
k

40 000

30 000

20 000

10 000

0

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

e
k
a
t
p
u
a
t
o
u
q
%

% quota uptake

Quota

Catches

Figure 4: Glass eel quota and catches by fishing season 

Source: from data submitted in rapport PGA France 2018 

Compared to the reference catches for the 2004-2008 period as established by ICES for France (78.6 
tonnes on average), glass eel catches decreased by 41%. Current glass eel catches include glass eels 
intended for restocking, a practice that did not exist prior to the adoption of the EU EMP. 

In  terms  of  exploitation  rate  (taking  into  account  recruitment  and  catches),  available  information 
shows  that  exploitation  rate  of  glass  eels  relative  to  2004-2008  decreased  dramatically  as  from 
implementation of the  FR EMP in 2009-2010 until 2013-2014. Exploitation rate increased after and 
was close to 49% of 2004-2008 index in 2016-2017. As above, exploitation rate does not consider 
survival of eels through restocking operations. 

Figure 5: Evolution of glass eel exploitation rate 

Source: Rapport PGA France 2018 
Note:  Exploitation rate establishes a relationship between recruitment and catches 

 
 
 
 
 
 
 
 
Concerning yellow and silver eels, it is not possible to assess the evolution of fishing mortality mainly 
as a result of i) the low submission rate of catch data from recreational freshwater fishermen, and ii) 
the difficulties to establish the reference 2004-2008 situation (no catch declarations were enforced 
prior to the EMP implementation). The 2004-2008 situation is being evaluated based on data available, 
but  information  is  not  yet  available.  Before  the  EMP,  catch  declarations  were  not  mandatory.  The 
2004-2008 baseline must be established through statistical methods using the incomplete information 
available for this period. 

Measures to restore eel habitats 

Ecological continuity of rivers 

One of the main measures implemented by the FR EMP was to make a comprehensive census of all 
obstacles likely to hinder fish migrations, in particular eels. Before the implementation of the plan, 
there was not such information available, except at certain local levels. The result is a comprehensive 
database (ROE – Référentiel des Obstacles à l’Écoulement) that is used to identify obstacles and to 
take  actions  to  restore  ecological  continuity  of  Category  2  rivers  as  enforced  by  the  FR  law 
implementing the WFD. 

The table below shows that as of 01/01/2018, 20% of works were compliant in relation to ecological 
continuity, meaning that 80% were still non-compliant. For some important EMUs, like the LCVS (Loire 
etc) where abundance of glass eels is the highest in France, only 11% of works are compliant, including 
8% in eel priority areas. 

Table 6: Status of compliance with legal prescriptions concerning restoration of ecological 
continuity in Cat. 2 rivers 

EMU 

Number of cat. 2 river 
works with eel as target 
species 
Inc. works in eel priority 
areas 
Number of river works 
conform as of 01/01/2018 
Inc. Prioriry area 

S
M
R

P
R
A

N
E
S

E
R
B

S
V
C
L

C
D
G

R
D
A

D
M
R

e
s
r
o
C

l
a
t
o
T

1 538 

383  2 620 

841  2 394  1 067 

403 

276 

46  9 568 

284 

226 

422 

475 

927 

192 

106 

276 

42  2 950 

94 

121 

603 

146 

252 

313 

107 

235 

11  1 882 

21 

74 

118 

69 

77 

59 

26 

42 

10 

496 

% conform 

6% 

32% 

23% 

17% 

11% 

29% 

27% 

85% 

24% 

20% 

Inc. Priority areas 

7% 

33% 

28% 

15% 

8% 

31% 

25% 

15% 

24% 

17% 

Source: Rapport PGA France 2018 

According to FR authorities, restoration of ecological continuity takes a long time. Legal owners of the 
≈  10 000  works  have  to  be  identified,  then  contacted  to  require  them  to  improve  the  ecological 
continuity, and then followed-up. All concerned owners have reportedly good reasons for not doing 
the  required  improvements.  For  these  reasons,  the  initial  delay  of  5  years  has  been  extended  by 
another five years. Operators concerned can receive a technical support from AFB to identify solution, 
and financial support from the different Agences de l’Eau for the required works. 

Eel mortality attributable to the lack of ecological continuity of rivers cannot be measured. This source 
of mortality was an important component of the targeted 75% reduction of non-fishing anthropogenic 
mortality. Since only 20% of inventoried obstacles have been improved, it can be assumed that the 
FR EMP is short of its objective. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Temporary switch-off of electric turbines 

Some progresses have been achieved in certain EMUs. However, temporary switch off have a cost for 
operators in the form of foregone revenues from sale of electricity produced, requiring an as precise 
as  possible  identification  of  switch-off  periods  by  authorities  (silver  eels  are  known  to  start  their 
downstream migration during a few nights in the winter seasons, i.e. when electricity production is 
the most needed). 

In the Loire EMU, a model for prediction of silver eel migrations has been successfully developed and 
used to determine the mandatory switch-off periods. For other EMUs, the model needs to be adapted. 
Meanwhile,  FR  authorities  have  difficulties  to  identify  and  mandate  switch-off  periods.  As  a  result, 
mortality  induced  by  hydro-electric  turbines  is  likely  to  be  significant  (20%  and  more  for  certain 
installations as suggested by CEREMA (2016)), although it cannot be measured at national level.  

Wetland restoration 

According to FR stakeholders, as much as 70% of wetlands areas have been destroyed over the past 
decades.  Protection  and  restoration  of  wetlands  areas  remains  a  priority  in  line  with  RAMSAR 
convention. An action plan has been implemented over the 2010-2012 period. Its evaluation concluded 
that the action plan has been effective to raise awareness and federate actions of the different entities 
concerned  but  raised  that  there  were  no  signs  of  tangible  results  in  relation  to  restoration  and 
protection of wetlands. An updated action plan for the 2014-2018 period is being implemented. The 
action plan considers specific actions (e.g. action # 49) to improve knowledge and assess the potential 
of coastal wetlands for eels in support of the FR EMP. 

Measures to enhance stock rebuilding 

Restocking 

Recorded catch levels for glass eels intended for restocking show that amounts considerably increase, 
from 5.5 t in 2010-2011 to 30.1 t in 2017-2018. Current catches of glass eels intended for restocking 
represented ≈ 55% of total catches in 2017-2018 (30 tonnes). Amounts of glass eels catches intended 
for restocking stand below the 60% target due to underutilisation of the restocking catch quota which 
is explained by the low economic attractiveness of the activity (i.e. prices paid by public operators for 
glass eels intended for restocking are reportedly low compared to market prices for glass eels intended 
for consumption) and the logistic complexity of the operations. 

g
k

35 000

30 000

25 000

20 000

15 000

10 000

5 000

0

Figure 6: Evolution of glass eel catches intended for consumption and for restocking 

Catch consumption

Catch restocking

Source: from data submitted in rapport PGA France 2018 

As established by the FR EMP, glass eels intended for restocking are used to enhance stocks in the FR 
EMUs for an earmarked quantity of 5-10% of the total catch quota. The remainder, i.e. 50-55% of the 
total catch quota is intended for restocking operations in other Member States, with Northern Member 
States  being  the  main  importers  of  glass  eels  (e.g.  Netherlands,  Germany,  Denmark,  Poland  or 
Sweden).  

Before adoption of the EMP, restocking was not implemented in France. 

 
 
 
For restocking operations implemented in France, operations include a monitoring component aiming 
at assessing the survival rate of glass eels up to three years after release. First results (Rigaud et al. 
2015) show a high variability but are low overall (i.e. less than 15%) and are decreasing over time 
(up to 36 months). Additional research is deployed to improve knowledge on glass eel survival rates 
after restocking, with reference to natural survival rate, and to obtain an estimate on the proportion 
of restocked glass eels that eventually migrate to the open sea. Experience already shows that eel 
restocking operations have some shortcomings: glass eel mortality can be high between catching and 
releasing due to stocking89 and handling operations, and restocking can underpin spread of pathogens, 
including EVEX (Eel-Virus-European-X) and the parasite Anguillicola crassus. 

Since the start of the French operations for restocking with public support under the coordination of 
ARA France, uptake  of  budget has been below expectations (70% budget uptake  on average). The 
reasons put forward by FR stakeholders are i) the low economic attractiveness of the operation due 
to lower selling prices, ii) the additional burden imposed on buyers of eels intended for restocking who 
have to implement prior checks in their premises (e.g. sanitation, tagging), and iii) the level of financial 
support  available  that  is  acceptable  only  for  public  entities  (96%),  with  as  a    result,  only  Regional 
Committees  for  Fisheries  submitting  applications  (the  80%  rate  offered  to  private  operators  is 
reportedly  too  low).  In  order  to  improve  the  financing  conditions,  France  decided  not  to  open  the 
relevant EMFF measure, but to finance restocking operations from State budget. The main advantage 
of doing so was to allow a down-payment to selected operators, which is not readily possible under 
EMFF. 

For live glass eels exported to  other Member States for restocking operations, French stakeholders 
report a lack of information on operations implemented and on their impacts on eels biomasses. Eels 
reported for restocking can be released directly in their natural environment or grown up to 20 cm in 
aquaculture  farms.  There  are  suspicions  that  eels  intended  for  restocking  may  be  used  for 
consumption,  either  sold  as  glass  eels  or  grown  up  to  commercial  grade  by  aquaculture  for 
consumption. Recent investigations from Bulgarian and Romanian operators to buy glass eels intended 
for restocking somehow reinforced these suspicions. FR authorities do  not have the  competence to 
monitor what happens to glass eels intended for restocking after exports. FR stakeholders also report 
that there is a mismatch between the FR glass eel fishing season and international demand for live 
glass  eels  intended  for  restocking.  Most  of  the  market  demand  is in  February  –  March  when  water 
starts to warm up, i.e., when the FR glass eel fishing season arrives at its end. 

Release of silver eels in the Mediterranean 

Operations supporting release of silver eel in the open sea could be implemented as expected with 
public support from State budget (≈ EUR 420 000 per year). Since 2011, 170 tonnes of silver eels 
have been released in the open sea (Mediterranean only), representing 1.1 million silver eels.  

Release  operations  are  implemented  in  partnership  with  a  scientific  institute.  It  could  be  verified 
through electronic tagging that silver eels may pass the Gibraltar strait and continue their Westward 
migration (Amilhat et al. 2017).  However, the farther point where tagged eels could be monitored 
was  near  Azores.  The  extent  to  which  silver  eels  released  contribute  to  the  spawning  stock  in 
Sargassum  Sea  is  yet  unknown.  Scientific  information  collected  also  suggests  that  migrating  silver 
eels are subject to important predation, with as much of 50% of tagged eels being predated by other 
fish after migration in the open sea.  

89 According to a professional fishermen, a good catch for one vessel is ≈ 2 to 3 kg glass eel in a night. 
Buyers need to build 500 kg stocks for restocking. 

 
 
 
 
                                           
3. KEY FINDINGS 
RELEVANCE 

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

JC1a(1):  The  extent  to  which  eel  landings,  escapement  levels  and  river  basin  conditions 
have recovered sufficiently to warrant the measures being continued.   

According  to  results  presented  in  the  2018  FR  triennial  report,  fisheries  management  measures 
succeeded to reduce eel landings and associated fishing mortality in a relatively short time frame, in 
particular  for  glass  eels  caught  in  marine  and  estuarine  waters.  Measures  to  improve  escapement 
levels and river basin conditions took time to design and implement and are likely to stand below the 
FR EMP stated objective of 75% reduction of mortality. 

Given  the  length  of  the  life-cycle  of  eels  in  France  (≈  12  years,  including  more  than  10  years  in 
freshwater bodies), the results of the EMP initiatives will be visible only in 2020, and probably only 
after  since  it  takes  more  time  than  expected  to  reduce  non-fishing  sources  of  mortality  (ecological 
continuity, temporary switch off of turbines, pollution). 

The conclusion, shared by all stakeholders consulted, is that EMP measures remain fully relevant at 
least until 2020. 

EFFECTIVENESS 

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

JC2 (1): EMPs implemented and specific targets achieved. 

All components of the FR EMP have been implemented. Specific targets have been achieved at various 
extent, depending on the types of measures : 

Fishing mortality 

Fishing  mortality  for  glass  eels  has  been  reduced  close  to  initial  specific  objective  of  60%  due  to 
various restrictions on professional fishing, including cessation schemes, catch quota and time-area 
closures of glass eels fisheries. For yellow and silver eels, measures have also been implemented to 
limit fishing mortality, mainly through various fishing time-area prohibitions. However, the impacts of 
these measures on yellow and silver eels cannot be estimated in terms of % reduction as a result of 
i) the low submission rate of catch data from recreational freshwater fishermen, and ii) the difficulties 
to establish the reference 2004-2008 situation (no catch declarations were enforced prior to the EMP 
implementation). 

Other non-fishing anthropogenic mortalities 

This pillar of the FR EMP is probably below its objective of 75% of reduction of eel mortality. In 2018, 
only  20%  of  river  works  impacting  eel  migration  were  estimated  to  be  compliant  with  legislation 
imposing ecological continuity, and programmes for temporary switch-off of turbines were not fully 
implemented (no quantified indicators for this). Measures foreseen in the EMP have been more difficult 
to implement due to the large number of existing river works and the resistance of public and private 
owners of these river works. However, a positive outcome of the measures is that a comprehensive 
database of obstacles has been assembled, and placed in the public domain (ROE – Référentiel des 
Obstacles à l’Écoulement). This database provides a basis for competent authorities to plan actions 
and monitor progresses. Before the EMP, there was no such inventory at national level of obstacles 
impacting migratory fish species. 

Other measures such as wetland restoration or fight against river pollution are being implemented, 
but with results expected only in the longer terms 

 
 
 
 
Fighting predators 

European catfish and cormorant are identified as possible, although unquantified, sources of mortality 
for eels. For European catfish, there are anecdotal evidences of individuals gathering near obstacles 
and feeding on glass eels trying to migrate upstream. Professional fishermen are willing to increase 
fishing pressure on catfish. However, they are reportedly prevented to do so by recreational fishermen 
who  want  to  keep  this  species  for  big  game  fishing.  For  cormorant,  authorisations  are  granted  to 
eliminate  about  20 000  individuals  in  some  regions,  but  a  wider  management  is  hampered  by  the 
protected  status  of  the  species  under  the  bird  directive,  and  strong  opposition  from  environmental 
NGOs. 

Enhancing stocks 

The mandated obligation to reserve 60% of the glass eel catch quota for restocking is complied with. 
The measure of the FR  EMP to use 5 to 10% of total glass eel catches for  restocking operations in 
France is now implemented under scientific supervision to ensure an acceptable survival rate and a 
contribution to the production of silver eels. Glass eels intended for restocking and not used by the FR 
programme are exported to other Member States with no further information on their contribution to 
the  EU  EMP.  FR  stakeholders  also  report  a  lack  of  feedback  on  the  effectiveness  of  restocking 
operations in other MS, and lack of exchange of experience on methodologies applied to restocking. 

JC2 (2): European eel stock has recovered. 

NB : this is addressed under JC 2(4) 

JC2 (3): Anthropogenic other than fishing mortalities have been reduced. 

NB : this is addressed under JC 2(1) 

JC2  (4):  Adult  eel  escapement  progressed  towards  the  long  term  40%  escapement 
objective. 

The situation of France with respect to the general EMP objective is uncertain as a consequence of the 
difficulties  to  obtain  reliable  estimates  of  B0  and  of  Bcurrent  of  silver  eels.  Nonetheless,  estimates 
available  show  that  France  is  still  short  of  the  EMP  general  objective,  but  that  mortality  reduction 
achieved, mainly through reductions of fishing mortality, may support rebuilding of the stock in the 
longer term, which is the objective of the EMP. 

JC2 (5): Supply of glass eels sufficient for restocking operations. 

Answer depends on what is considered as sufficient for restocking operations. As far as France, the 
EMP objective was to use 5 to 10% of the catch quota for restocking operations. Glass eel supply is 
sufficient for the FR Programme. For glass eels caught in France, catch quota reserved for restocking 
was probably too high compared to demand as evidence by underutilisation of this quota. However, 
utilisation of the quota reserved for restocking tended to improve over the last few years, being at 
77%  in  2017-2018.  Still,  supply  of  glass  eels  for  restocking  operations  appear  to  be  in  excess  of 
demand, largely driven by demand from other MS. 

JC2 (6): Fishing effort reduced by at least 50% relative to the average effort 2004-2006 or 
ensure reduction of catches by at least 50%. 

NB : this is addressed under JC 2(1) 

JC2  (7):  Origin  and  traceability  of  all  live  eels  imported  and  exported  from  MS  territory 
maintained.  

There  are no imports  of live eels in France, only exports. Traceability is ensured through transport 
documents up to the borders. After exports, France does not have competence to ensure traceability. 
French  authorities  somehow  regret  that  the  CITES  intra-EU  traceability  documents  have  been 
abandoned, albeit it is acknowledged that they generated administrative burden. 

 
 
 
 
JC2 (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. 

Controls and enforcement activities have taken place in EU waters and in non-EU waters (= freshwater 
environment) on the following basis: 

•  For EU waters, the competent authority is the Direction de la Pëche Maritime et de l’Aquaculture 
of the Ministry for Agriculture. All obligations stemming from the EU Control Regulation have 
been implemented for eel, including mandatory catch declarations from fishermen, purchase 
declarations from authorised buyers and transport documents as enforced by a 2015 Arrêté 
with  a  2017  Arrêté  specifying  obligations  in  the  case  of  the  eel  fishery.  Traceability 
requirements from net to plate set out by the EU Control Regulation are not yet enforced in 
France.  For  catch  declarations,  professional  fishermen  have  to  submit  monthly  declarations 
(regime for all vessels not subject to logbooks) which are centralised by FranceAgrimer. For 
purchase declarations of glass eels, buyers have to declare electronically through a dedicated 
web  interface  called  Visiomer.  Compliance  with  catch  or  purchase  declaration,  as  well  as 
compliance with technical rules on fishing activities (licences, technical measures) is verified 
by authorised Ministry personnel as it is the case for all marine fishing authorities. Inspections 
are  coordinated  at  regional  levels  by  the  competent  maritime  authorities  (Direction 
Interrégionales de la Mer (DIRM) according to control strategies.  

•  For non-EU waters, the competent authority is the Direction de l’Eau et de la Biodiversité of 
the  Ministry  for  Ecology.  Catch  declarations  have  been  mandated  for  both  professional  and 
recreational  through  a  2010  Arrêté  and  further  detailed  by  a  2013  Arrêté  for  professional 
fishermen  targeting  eels.  Sales  notes  and  transport  documents  enforced  for  marine  fishing 
through  the  EU  Control  Regulation  have  been  extended  to  eel  caught  in  freshwater 
environment. Like for marine fishing, buyers of glass eels caught by freshwater professional 
fishermen have to declare purchases electronically. 

Professional  fishermen  (both  freshwater  and  marine)  have  autonomously  implemented  an 
simple electronic reporting system via SMS (Télécapêche with a specific module for glass eels 
Télécacivelle). Electronic declarations have no legal value according to legislation, but they are 
used to monitor uptake of the glass eel quota by fishermen organisations in near real-time. 
•  Control  of  ecological  continuity  of  rivers  falls  under  the  Police  de  l’Eau  aiming  at  controlling 
enforcement  of  environment  and  biodiversity  legislation,  including  eels  measures.  Control 
responsibility  and  objectives  were  framed  by  a  2010  Circular  recently  replaced  by  a  Note 
Technique published in 2017. 

For fishing activities, common controls focus on compliance with reporting obligations and compliance 
with technical rules. As an example, for the 2016-2017 fishing season, a total of 115 marine fishermen 
have  been  controlled  in  Brittany  /  Pays  de  Loire  (the  largest  EMUs  for  glass  eels  fishing)  with  14 
detected  infringements  (12%),  mainly  in  relation  to  reporting  obligations  and  closed  seasons.  In 
freshwater environment, 328 inspections have taken place with 132 infringements detected (40%). 

France is exposed to a high risk of glass eel fishing underpinned by the high prices of live products on 
the  Asian  market.  The  CITES  listing  of  European  eel  somehow  encouraged  glass  eel  trafficking  by 
phasing  out  legal  operators  from  this  lucrative  business.  Glass  eel  poaching  activities  (fishing, 
transport,  export)  operate  in  the  form  of  organised  crimes  requiring  cooperation  of  all  authorities 
involved (fisheries control activities, Gendarmerie, Customs, etc.). Over the past few years, several 
operations succeeded to dismantle certain illegal networks. For serious infringements subject to penal 
sanctions including jail sanctions, French courts dedicated specific audiences to be able to deal more 
easily with the technical specificities of the eel trafficking business. 

 
 
 
 
EQ 3.  If the measures for the recovery of 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? 

JC3 (1): Identification of the key barriers to achieving the objectives. 

According to stakeholders consulted, the main key barriers to achieving the eel objective are the slow 
progresses  to  improve  the  conditions  for  eel  survival  in  rivers,  in  particular  to  restore  ecological 
continuity of rivers or to decrease mortality induced by hydro-electric turbines. A factual evidence is 
that only ≈ 20% of works across rivers are compliant with legislation.  

JC3  (2):  Identification  of  the  common  and  outstanding  successes  and  resulting  best 
practises that have allowed progress towards achieving the objectives. 

The  following  points  detail  what  appear  as  good  practices  to  support  progresses  towards  the 
objectives: 

•  The geographical scope of the French eel management plan : the FR EMP includes all 
eel habitats up to 1,000 m elevation, including Corsica. The geographical scope of the plan, 
and therefore the geographical scope of the eel restoration and conservation measures includes 
all marine and freshwater environment of the French national territory (excluding outermost 
regions) where eels can be found. 

•  The national database of rivers obstacles : the objective to restore ecological continuity 
of rivers led FR authorities to implement a national census of all obstacles across rivers which 
did not exist prior to the adoption of the FR EMP. Relevant information was only available for 
certain  areas  in  some  EMUs,  and  not  harmonised.  The  result  is  the  ROE  database  available 
online (Référentiel des Obstacles à l’Écoulement) which is maintained and updated according 
to results obtained by a central authority. 

•  Voluntary electronic catch declarations by FR professional fishermen (freshwater and 
marine waters): according to legislation, FR fishermen have to declare catches on paper forms 
to be submitted by courier to two different authorities.  In view  of the  relative inertia of the 
declaration  system  to  monitor  glass  eel  quota  uptake,  professional  fishermen  develop  an 
electronic  reporting  system  (Télécacivelles)  to  monitor  quota  uptake  in  near-real  time.  The 
professional electronic reporting system reportedly prevented overshooting of the quota. 
•  Scientific monitoring of eel restocking operations: eel restocking operations are framed 
by a scientific protocol defined to improve survival rate of restocked glass eel and to monitor 
results over a three year period. Areas for restocking are also identified with scientific expertise 
to increase the contribution of the eel restocking operations to restoration of eel populations. 
Compliance with scientific protocols is one of the conditions imposed to organisations benefiting 
from public support for eel restocking. 

•  Granting  restocking  financial  support  through  a  State  Aid  scheme  rather  than 
through EMFF : 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,  FR 
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.  FR  authorities  applied  a  similar  approach  to  support  silver  eel  release  in  the 
Mediterranean with aids granted under the scope of the de minimis Commission’s rules. These 
measures  contributed  to  improve  implementation  of  eel  stock  enhancement  measures  by 
professional organisations. 

•  Public  contribution  for  restoration  of  ecological  continuity  :  through  the  Agences  de 
l’Eau, owners of rivers obstacles can obtain public technical and financial support for restoring 
the  ecological  continuity  of  their  works.  As  an  example,  the  Agence  de  l’Eau  Loire-Bretagne 
committed  a  EUR  295  million  budget  over  the  2019-2024  period  to  protect  and  restore  the 
aquatic environment. 

•  Modelling  periods  for  temporary  switch-off  of  electric  turbines  :  in  the  Loire  are,  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 
supported  implementation  of  the  measure,  which  from  operators  perspective,  must  be 
implemented  only  when  necessary  due  to  the  high  associated  foregone  revenues.  Similar 
models are yet to be developed or adjusted for other EMUs. 

 
 
•  Involvement of Courts: Courts competent for areas where glass eel trafficking is the most 
likely to happen specialised by grouping audiences concerning infringement to eel measures in 
one or two annual sessions. This contributed to increase the Court knowledge on these issues, 
and to better balance sanctions according to the severity of the infringement. A large publicity 
is also given to sanctions imposed as a deterrent (jail sanctions have been imposed in addition 
to fines to offenders involved in organised eel trafficking, see example1 and example 2). 

JC3 (3): Identification of best practices in transboundary areas. 

Scientists from France, Spain and Portugal created in 2018 an exchange platform on stock modelling 
through the Interreg project SUDOANG coordinated by Azti (ES). The main objective of this project is 
to harmonise approaches for scientific modelling of eel populations, including harmonised approach to 
identify  the  situation  of  silver  eel  abundance  compared  to  the  40%  objective  set  out  by  the  Eel 
regulation. 

JC3 (5): Have the control & enforcement measures at MS levels been adequately resourced 
and implemented? 

Both enforcement authorities competent for marine fisheries and enforcement authorities competent 
for freshwater fisheries could not provide information on the control resources deployed as control of 
eel measures is part of the broader control of fisheries and environmental measures. Consequently, it 
is not possible to assess the extent to which resources are adequate.  

SUSTAINABILITY 

EQ 5.  Are the effects likely to last after the intervention ends? 

JC5 (1): The extent to which measures implemented under the Eel Regulation have long-
term impacts, even if the intervention were to cease. 

According to all stakeholders consulted, the measures implemented through the Eel Regulation may 
have  long  term  impacts.  Measures  of  the  FR  EMP  in  relation  to  monitoring  and  control  of  fishing 
activities and in relation to restoration of eel habitats in rivers and lakes have been transposed into 
national  law,  and  are  likely  to  remain  applicable  even  if  the  intervention  was  to  cease.  However, 
restocking measures may not be continued in the absence of EU prescriptions in view of their costs 
for the National budget and in view of the lack of clear scientific demonstration of their effectiveness. 

EFFICIENCY  

EQ 6. 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? 

JC6  (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. 

The cost-benefit of the FR EMP has not been assessed. The problem is twofold: identifying the costs 
and identifying the socio-economic benefits. Some stakeholders report that the value of eel is not only 
socio-economic. Eels have also a patrimonial value which is not readily monetizable. 

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

JC7 (1): The extent to which alternative options exist and an assessment of their relative 
cost-effectiveness and contribution to the objectives of the Regulation.   

None of the stakeholders consulted raised a need for an alternative approach. According to feedback 
received,  the  Eel  Regulation  includes  relevant  protection  measures  all  along  the  life-cycle  of  the 
species  and  a  shared  opinion  is  that  all  foreseen  measures  should  be  implemented  up  to  stated 
objective to ensure eel stock recovery. In this respect, addressing non-fishing anthropogenic sources 
of mortality, and therefore ensuring that all measures of the FR EMP are implemented, should be seen 
as  a  priority.  In  particular,  efforts  to  restore  ecological  continuity  of  rivers  should  be  increased  as 
evidenced by the relatively low proportion of rivers works addressed so far (17%, see Table). 

COHERENCE 

EQ 9.  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)? 

JC9  (1): The extent to which  wider fisheries  and environmental policies  remain coherent 
with the objectives and measures under the Eel Regulation. 

No issues of incoherence have been identified during the consultations. It has been raised that the EU 
Eel management plan is potentially impacted by several other EU instruments, inter alia:  

•  The Common Agriculture Policy that encourages productivity of the sector, with potential 

effects on natural water resources quality and availability; 

•  Europe 2020 strategy that encourages the development of alternative sources of renewable 
energy including the development of hydro-electric energy that creates incentives to increase 
the number of river works potentially hindering eel movements. 

•  The  Water  Framework  Directive  supporting  improved  management  of  natural  water 

resources and of their ecological functions 

•  The Bird Directive that includes protection measures for certain eel predators 

All  these  EU  instruments  have  a  legitimate  objective.  However,  the  main  problem  encountered  in 
France  is  to  strike  an  acceptable  balance  between  socio-economic  interests  and  environmental 
interests. Eel management plan measures are an illustration of the difficulties to strike this balance, 
in particular for non-fishing anthropogenic sources of mortality. 

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?  

JC11  (1):  Extent  that  the  Eel  Regulation  has  provided  additional  impetus  /  support  to 
address eel conservation objectives.   

There  is  a  broad  consensus  between  all  stakeholders  consulted  to  support  the  view  that  the  EU 
Regulation  supported  an  integrated  approach  for  restoration  of  eel  populations,  by  including  in  its 
scope all identified sources of mortality in relation to human activities and in relation to other ecological 
factors such as predators. The eel regulation provided an impetus for a comprehensive approach which 
did  not  exist  prior  to  its  adoption.  Although  there  is  still  a  clear  dichotomy  in  France  between 
authorities in charge of the marine sector and authorities in charge of the freshwater environment, 
the Eel Regulation prompted establishment of a dialogue that was not necessarily existing before the 
Eel Regulation. As a spin-off  effect, the  Eel Regulation is also likely to benefit to other diadromous 
species (e.g. salmon, shad, sturgeon) which are also impacted by the quality of the environment in 
rivers and lakes, including ecological continuity of waterways. 

 
 
 
 
However,  several  stakeholders  (professional  organisation  and  national  authorities)  raised  that 
additional EU interventions through the annual TAC and quota regulation, which concern only marine 
fishing, do not send the right signal. By nature, Tac & quota measures put additional limitations on 
marine fisheries only, a sector which has already been dramatically reduced, while reduction of other 
sources  of  eel  mortality  in  rivers  and  lakes  are  considerably  delayed  compared  to  initial  objectives 
without being subject to similar emergency measures. 

JC11 (2): Extent that it is possible to isolate results and outcomes that could or would not 
have been otherwise achieved without the Eel Regulation. 

The main outcome of the Eel regulation is the comprehensive approach used to address all sources of 
eel mortality.  

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

JC12 (1): Extent that MS authority is able to identify positive and negative implications of 
stopping the Regulation. 

In  the  event  the  Eel  Regulation  is  discontinued,  measures  transposed  into  National  legislation  for 
regulating  fisheries  and  for  restoring  eel  habitats  would  continue  to  apply.  However,  restocking 
measures  may  not  be  continued  in  the  absence  of  EU  prescriptions  in  view  of  their  costs  for  the 
National budget and in view of the lack of clear scientific demonstration of their effectiveness. 

4. CONCLUSIONS AND RECOMMENDATIONS 

France implemented the measures promoted by the Eel Regulation in relation to implemented i) to 
decrease fishing mortality, ii) to decrease other anthropogenic sources of mortality and iii) to enhance 
stocks through restocking of glass  eels and  release  of silver  eels.  In the first 8  years following the 
adoption of the FR EMP, tangible results have been obtained for the reduction of fishing mortality of 
glass eels, and implementation of a FR restocking plan. Concerning yellow and silver eels, reduction 
of fishing mortality through several fishing prohibition has also been obtained but results in terms of 
decrease of fishing mortality cannot be evaluated as yet due to difficulties to quantify the 2004-2006 
baseline  compounded  by  a  lack  of  catch  declarations  by  recreational  fishermen.  Reduction  of  non-
fishing anthropogenic sources of mortality was given high priority in the plan with a high 75%, but 
progress  has  been  slow.  It  took  time  to  establish  a  legislative  basis  for  restoration  of  ecological 
continuity of rivers, to have a comprehensive census of existing rivers works (≈ 10 000 works) and 
to incentivise the owners of these works to do the required improvements. 

According to scientific estimates, France is still below the general objective of the Eel Regulation to 
reduce anthropogenic mortalities so as to permit 40% escapement of silver  eel biomass relative to 
pristine biomass. However, the current levels of fishing mortality are assessed to support restoration 
of the eel population up to this objective in the long term in line with the general objective of the Eel 
Regulation. Given the duration of the life cycle of eels, results of the FR EMP are not expected to be 
visible until 2020. A view shared between all stakeholders consulted is that the Eel Regulation remains 
relevant,  and  that  it  should  be  maintained  at  least  until  2020.  Professional  fishermen  in  both 
freshwater and marine waters raised that the professional fishing sector has already paid a large socio-
economic  contribution  for  eel  restoration,  and  that  priority  should  be  given  to  restoration  of  eel 
habitats in the medium term in view of the low progresses achieved in this area since 2010. 

At EU level, French stakeholders raised two difficulties that could be addressed with support of the 
Commission: 

•  Traceability  of  eels:  once  transported  out  of  the  national  territory  ,  FR  authorities  do  not 
have the competence to ensure that eels intended for restocking in other MS are used for this 
purpose. Anecdotal information suggests that it may not always be the case. 

•  Exchange of knowledge and good practices on eel restocking: French operators reported 
that there is little information available on restocking protocols used in other Member States. 
Since restocking is one of the pillars of the Eel Regulation, exchange of good practices should 
be supported at  EU level instead of each Member State inventing and implementing its own 
procedures.  

 
 
 
Evaluation of the Eel Regulation 
Specific Contract No. 10 
under Framework contract 
EASME/EMFF/2016/029 

Italy – Case Study 

Eel Fishmonger, Traditional Nativity, Bologna 2018

 
 
 
 
 
 
 
 
CASE STUDY - ITALY 

ACRONYMS/ABBREVIATIONS 

Acronyms/ 
Abbreviations 

Definition 

ARPAT 

CEO 

CITES 

CREA 

Agenzia  Regionale  per  la  Protezione  dell’Ambiente  –  Toscana 
(Regional Agency for Environmental Protection – Tuscany) 

Chief Executive Officer 

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

Consiglio per la Ricerca in agricoltura e l’analisi dell’Economia Agraria 
(Council for Research in Agriculture and Angricultural Economics) 

EIFAAC 

European Inland Fisheries and Aquaculture Advisory Commission 

EFF 

EMFF 

EMP 

EMU 

EU 

FAO 

GFCM 

ICES 

IUCN 

MS 

European Fisheries Funds 

European Maritime Fisheries Fund 

Eel Management Plan  

Eel Management Unit 

European Union 

Food and Agriculture Organisation 

General Fisheries Commission for the Mediterranean  

International Council for the Exploration of the Sea 

International Union for Conservation of Nature 

Member States 

MIPAAFT 

Italian Ministry for Agricultural, Food, Fishery and Tourism Policies 

PEMAC 

WGEEL 

WFD 

Pesca Marittima e Acquacoltura (Fisheries and Aquaculture) 

Joint EIFAAC/ICES/GFCM Working Group on Eels 

Water Framework Directive 

 
CASE STUDY - ITALY 
1. OVERVIEW OF THE CASE STUDY 
INTRODUCTION 

This report presents the results of the case study on Italy, one of the three case studies (the other 
focusing on Denmark and France) being conducted in this evaluation. The case studies will provide 
more  detailed  insight  into  the  implementation  of  the  Eel  Regulation  at  national,  regional  and  local 
level,  in  addition  to  the  information  gathered  through  the  synthesis  of  the  Eel  Management  Plans 
(EMPs) and their progress report, and the targeted consultation with the other Member States. They 
are intended to: 

•  understand the extent to which the measures taken under the 2009 EMPs have been able to 

address the main objectives of the Eel Regulation; 

•  determine whether the Eel Regulation, and the responses detailed in the EMPs, remain 

relevant with regard to the drivers and pressures relating to the recovery of the European eel 
stock, and the extent to which the latter can be addressed by the EU alone; 

•  assess what additional or alternative measures might be taken to achieve the objectives of 

the Eel Regulation; 

•  assess the added value of the Eel Regulation and the sustainability of the measures being 

undertaken through the EMPs and their long-term impact after the interventions. 

METHODOLOGY 

This case study has been conducted through both a review of background information (such as EMPs, 
Progress  Reports,  scientific  reports  and  other  relevant  studies)  and  face  to  face  and  telephone 
interviews  guided  by  semi-structured  questionnaires.  The  case  study  has  also  benefitted  from  two 
round  tables  organized  by  the  Italian  Minister  of  Agricultural,  Food,  Forestry  and  Tourism  Policies 
(MIPAAFT) and the Emilia Romagna Region, respectively. The interviews allowed to collect information 
from different subjects active in the entire eel management spectrum, ranging from legal to scientific 
and commercial insights, thus developing a variegate but consistent understanding of the problem at 
issue, of what actions have been taken and of what still needs to be done. In addition to national and 
regional officials, a number of representatives from research bodies (e.g. universities, Unimar) and 
trade associations (e.g. Associazione Cooperative Italiane, Legacoop Agroalimentare Nord Italia) have 
been involved in the discussion.  A list of the interviewees and of the sources consulted is included in 
the tables below.   

Table 1: Interviews carried out in support of the case study  

Organisation  

Ministry  of  Agricultural,  Food,  Forestry  and  Tourism  Policies  /  Direzione  Generale  della  pesca  e 
dell’acquacoltura 

Carabinieri Forestali – Raggruppamento CITES 

Emilia Romagna Region  

Friuli Venezia Giulia Region  

Lombardy Region  

Tuscany Region  

Ente Tutela Pesca Friuli Venezia Giulia  

University of Bologna 

University of Ferrara  

University of Roma Tor Vergata  

Unimar  

CREA - Consiglio per la ricerca in agricoltura e l'analisi dell'economia agraria  

Associazione Cooperative Italiane  

Legacoop Agroalimentare Nord Italia  

Associazione Pescicoltori Italiani  

 
CASE STUDY - ITALY 

Table 2: Document sources 

Document reference  

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

National and Regional EMPs, Progress Reports, Other Legal Acts 

Piano Nazionale di Gestione per l’anguilla in Italia, September 2009 

Piano  Nazionale  di  Gestione  per  l’anguilla  in  Italia  -  Regolamento  (CE)  1100/2007  –  Rapporto 
Annuale Italia art.9 – Anno 2015 

Piano  Nazionale  di  Gestione  per  l’anguilla  in  Italia  -  Regolamento  (CE)  1100/2007  –  Rapporto 
Annuale Italia art.9 – Anno 2018 

Decreto del Ministero delle Politiche agricole alimentari e forestali del 12 gennaio 2011, Disciplina 
della pesca e della commercializzazione del novellame di anguilla della specie Anguilla (Cèca) 

Ministry  for  Agriculture,  Food  and  Forestry  Policies,  Circular  on  CITES  –  Inclusione  della  specie 
Anguilla nell’allegato B del Reg. (CE) 338/97, Chiarimenti in merito alla detenzione del registro di 
detenzione CITES di cui al D.M. 8 gennaio 2002 

Ministry  for  Agriculture,  Food  and  Forestry  Policies,  Circular  on  CITES  –  Inclusione  della  specie 
Anguilla nell’allegato B del Reg. (CE) 338/97, Chiarimenti in merito alla detenzione del registro di 
detenzione CITES di cui al D.M. 8 gennaio 2002 – intergazione 

Piano di gestione regionale dell’anguilla (Anguilla anguilla) Regione Veneto, August 2009, drafted 
following the Deliberazione della Giunta regionale n. 2278 del 28 luglio 2009, Implementazione delle 
misure  per  la  ricostituzione  dello  stock  di  anguilla  europea  imposte  dall'Unione  Europea 
(Regolamento n.1100/2007 del Consiglio) 

Piano di gestione dell’anguilla (Anguilla anguilla) in Friuli Venezia Giulia, October 2011, attached to 
the  Delibera  della  Giunta  regionale,  n.  1848  del  7  ottobre  2011,  relativa  al  Piano  di  gestione 
dell’anguilla  (Anguilla  anguilla)  in  Friuli  Venezia  Giulia  –  Attività  di  monitoraggio  dello  stock  di 
anguilla nella laguna di Marano 

Documento  di  Attuazione  Regionale  del  Piano  Nazionale  per  la  gestione  dell’anguilla  Regione 
Toscana,  attached  to  the  Deliberazione  della  Giunta  regionale n.  558/2012  di  approvazione  del 
documento di attuazione del piano nazionale dell'anguilla 

Academic and Grey Literature 

term 
Aschonitis, V., Castaldelli, G., Lanzoni, M., Rossi, R., Kennedy, C., & Fano, E. A. (2017). Long
records  (1781–2013)  of  European  eel  (Anguilla  L.)  production  in  the  Comacchio  Lagoon  (Italy): 
evaluation of local and global factors as  causes of the population collapse. Aquatic Conservation: 
Marine and Freshwater Ecosystems, 27(2), 502-520 

‐

Brunelli, F., (2012). Evaluation of silver European eel (Anguilla anguilla) for the implementation of 
an  effective  Eel  Management  Plan  in  Mediterranean  coastal  lagoons.  PhD  Thesis  –  University  of 
Bologna, Italy 

Capoccioni, F., Ciccotti, E. & Leone, C., (2018), Report on the eel stock, fishery and other impacts, 
in Italy 2018 in: ICES, Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL) 

Capoccioni, F., Ciccotti, E., Leone, C. & Schiavina, M., (2018), Report on the eel stock, fishery and 
other impacts, in Italy 2017 in: CITES, Report of the Joint EIFAAC/ICES/GFCM Working Group on 
Eels (WGEEL) 

FranceAgriMer (2014). Insights into the European eel market chain. 

Franchi E. (2015). Il Piano di gestione dell’anguilla europea in Toscana e la sua applicazione nella 
laguna di Orbetello, presented during the seminar Le lagune della Sardegna: sviluppo sostenibile, 
tradizioni, prodotti e ambiente, Oristano, 27 March 2015 

ICES (2017), Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL) 

 
 
CASE STUDY - ITALY 

Document reference  

ICES  (2018),  Country  Reports  2017–2018:  Eel  stock,  fisheries  and  habitat  reported  by  country, 
Annex 5 to the ICES, Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL) 

ICES (2018), Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL) 

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

Violani,  A.,  (2014).  Attuazione  del  Piano  di  Ripopolamento  dell’Anguilla  in  Toscana  Anno  2013, 
ARPAT 

 
 
 
 
CASE STUDY - ITALY 
1. OVERVIEW OF THE CASE STUDY 
EEL PRODUCTION AND TRADE  

According to the stakeholders, about 850 tonnes of eels have been produced in Italy in 2017, 
from fishing, extensive and intensive aquaculture, with a production value of about EUR 10 million. In 
detail, about 600 tonnes are produced from intensive aquaculture, and 250 tonnes from fishing and 
extensive  breeding  in  semi-open  coastal  lagoons  (“vallicoltura”).  These  figures  are  grossly  in  line, 
albeit somehow higher, with the fishing data reported by the WGEEL.  

Fishing (including vallicoltura) 

Data  on  eel  fishing  in  Italy  show  certain  discrepancies,  depending  on  the  sources  used  and  the 
definitions applied. In particular, whether vallicoltura90 is considered as aquaculture or fishing remains 
unclear. Italian sources and stakeholders usually tend to include it among fishing activities. 

Commercial landings of yellow and silver eel, as reported by the WGEEL91, amount to 200 tonnes in 
2017, that is about 10% of the total EU landings. In 2017, Italy was the sixth EU producer of 
yellow and silver  eels,  after Denmark, France, the UK, the  Netherlands, and Sweden. This value is 
largely in line with the stakeholders’ estimates, putting the total production from commercial 
fishing and vallicoltura at about 250 tonnes. The trend is also consistent with the stakeholders’ 
perception, as WGEEL data report a mild increase in the 2012-2015 period (when landings amounted 
to about 170 tonnes per year). 

According to the same data, eel fishing in Italy has been declining significantly, both in absolute 
and relative terms to the other EU MS, and this is vastly confirmed by stakeholders (‘There is almost 
no more commercial eel fisheries in Italy compared to the past, now the activity is largely marginal’). 
In the 80’s, Italy was among the top three eel fishing countries in the EU, together with Denmark and 
France,  and  the  top  producer  in  certain  years,  with  about  2,000  tonnes  of  yearly  landings.  In  that 
decade,  the  Italian  output  accounted  for  between  15%  and  20%  of  the  total  EU  production.  The 
production has steeply declined since then: if in 1995 the output was still above 1,000 tonnes, it had 
declined to about 380 tonnes in 2004, and stayed at below 100 tonnes in the 2005-2008 period, before 
recovering to the current levels.  

The  decline  in  the  fishing  output  corresponded  to  a  parallel  decrease  in  the  size  of  the  Italian  eel 
fisheries sector. In 2007, about 1,600 eel fishers operated in Italy; today about 1,100 remain.92 On a 
longer time-horizon, one stakeholder commented that in one single fishing area nearby the Po estuary, 
the number of fishers declined from 600 in the 80’s, to about 40 today. Not only the number of fishers 
declined,  but  also  the  importance  of  eels  among  total  catches,  so  that  eels  represent  a  significant 
share of their landings only for very few operators, becoming for most of them a by-catch, rather than 
a  target  species.  However,  eel  fishing  and  vallicoltura  remain  important  for  certain  fishing  areas 
around the coastal lagoons, and for the smallest and least structured fishing operators in these areas. 

Eurostat data on eel catches93 report about 98 tonnes fished in Italy in 2017, that is about 10% of the 
total EU production. Catches for 2017 seem underestimated, but it is unclear whether Eurostat data 
include vallicoltura. The 2017 value is the highest since the early 2000’s; between 2008 and 2015, 
catches hovered between 3 and 36 tonnes per year. However, such very low catches are not consistent 
with the information retrieved from the interviews, given that stakeholders did signal an increase over 
the last few years, but not of such an order of magnitude. 

Glass eel fishing is almost absent in Italy and is practiced by no more than 10 operators in the 
Tyrrenhian area (Tuscany and Latium). The Italian Ministry and WGEEL data concur in reporting about 
0.1 tonne of glass eel fished in 2017.  

90 Vallicoltura  is  a  form  of  extensive  fish  breeding,  which  includes  eels  as  well  as  other  euryhaline 
species, typical of the Adriatic coast, carried out in brackish water basins, enclosed by embankment 
or dykes, and open to sea water via artificial channels. 
91 Report  on  the  eel  stock,  fishery  and  other  impacts,  in  Italy  2018  in:  ICES,  Report  of  the  Joint 
EIFAAC/ICES/GFCM Working Group on Eels (WGEEL), 
92 Italian EMP Progress Report 2018. 
93 Eurostat, Fisheries, Catches by fishing area - European eel (1980-2017). 

 
                                           
CASE STUDY - ITALY 
The main fishing areas – again, including vallicoltura – in Italy include the Adriatic lagoons (Grado and 
Marano in Friuli Venezia Giulia; Caorle, Chioggia, Venice and the Po mouth in Veneto, the Po mouth 
and Comacchio in Emilia Romagna), two sea lakes in Puglia (Lesina and Varano); Sardinian and Tuscan 
wetted areas, internal lakes in Umbria and Latium and the estuary of the Tiber river in Latium. Adult 
eel  fishing  in  marine  waters  is  practically  absent  in  Italy.  The  table  below  reports  the  estimated 
production in the various Italian Eel Management Units (EMUs). 

Table 3: Yellow and Silver Eel Catches in the Italian EMUs 

EMU 

Apulia 

Emilia Romagna 

Friuli Venezia Giulia 

Latium   

Lombardy 

Sardinia 

Tuscany 

Umbria 

Veneto 

Annual  catch  2017 
(t) 

5 

18 

4 

13 

6 

56 

37 

4 

22 

Source: Report on the eel stock, fishery and other impacts, in Italy 2018 in: ICES, Report of the Joint 
EIFAAC/ICES/GFCM Working Group on Eels (WGEEL) 

Aquaculture  

According  to  the  stakeholders,  in  2017  the  Italian  eel  aquaculture  production  amounted  to 
about 600 tonnes. 2017 data are not included in the WGEEL report: in 2015 and 2016, production 
reached about 450 tonnes, while in 2014 it amounted to slightly less than 600 tonnes. Italy is thus 
the  fourth  or  fifth  largest  producer,  on  par  with  Spain  and  Greece,  and  significantly  below  the  top 
three-producers  (Germany,  Denmark,  and  the  Netherlands).  The  Italian  share  of  the  EU  eel 
aquaculture production hovers around 8-10%. FAO data on eel aquaculture are also consistent, putting 
the Italian production for 2013-2015 at about 550-650 tonnes 94. The average price amounts to about 
EUR 11€/kg, at farm’s gate. 

The  decline  in  the  Italian  eel  aquaculture  production  is  significant,  but  much  less  steep 
compared  to  fishing  activities.  WGEEL  data  go  back  until  2004,  when  the  Italian  production 
amounted to about 1,200 tonnes, i.e. twice the current levels. FAO data show that in the 80’s and 
90’s the production ranged between 2,500 and 3,500 tonnes. Until 1985, Italy represented more than 
90% of the EU eel aquaculture, a share which declined to less than 50% in 1995 and less than 25% 
in 2001, following the increase in Northern European production. 

In Italy, aquaculture started as a way to re-use small yellow eels, whose size was not sufficient for 
being sold on the market. Hence, it hardly relied, and still hardly relies, on glass eel supply. Today, 
due to the decline in the Italian eel fishing, most of the yellow eels used for farming purposes come 
from other EU MS, in particular France. The breeding technique is traditional, and eels are farmed in 
open-air basins, where the growth period is longer than in recirculating plants, so that the product 
comes  qualitatively  closer  to  wild  catches.  The  sector  boomed  in  the  70’s  and  80’s,  before  the 
competition  from  Northern  European  recirculating  plants  arose.  In  recirculating  plants,  production 
costs are lower, and so are prices at farm’s gate (currently, 3€/kg lower than in Italian plants). The 
competition led to a decline in eel prices and significant closures of Italian plants in the early 2000’s, 
with  farmers  switching  to  other  species.  A  new  EU  market  equilibrium  was  found  after  (i)  Chinese 

94 FAO Fisheries & Aquaculture - Fishstat Plus database, Global Aquaculture Production – European eel 
(1980-2016). 

 
                                           
CASE STUDY - ITALY 
exports  in  the  early  2000’s  put  Northern  European  operators  under  pressure,  thus  leading  to  a 
reduction in their production capacity;95 and (ii) the subsequent eels trade bans and limitations, which 
largely  foreclosed  the  European  market  from  external  (i.e.  Chinese)  competitive  pressures.  Today, 
less than 10 eel aquaculture producers operate in Italy, with one major plant in Lombardy, one 
medium-sized plant in Veneto, and few smaller operators. 

Domestic and Intra-EU Trade in Eels 

The market for eel consumption in Italy is small and declining. Most of the eels are traded alive on 
local markets nearby the fishing areas, or at arm’s length directly from fishers. Only for the Christmas 
period the consumption increases, and non-local traders or supermarkets sell eels. Large aquaculture 
producers  sell  a  large  share  of  their  production  to  other  EU  countries,  especially  to  Germany,  for 
subsequent processing (in particular smoking). Differently, more than 50 tonnes of eels are processed 
in Italy to produce marinated eel, a typical product of the northern Adriatic coast. 

EEL MANAGEMENT PLAN 

Here below, the main features of the Italian EMP are discussed, together with the EMPs of the three 
regions  with  whom  direct  interviews  were  carried  out  (Emilia  Romagna,  Friuli  Venezia  Giulia,  and 
Tuscany).  

Key measures and approaches 

In  Italy,  the  competence  on  eel  fisheries  is  shared  between  the  national  and  the  regional  tiers  of 
government. The national government is responsible for fishing activities in sea waters up to the river 
mouths; the regions are responsible for fishing activities in inland fresh waters and coastal lagoons. 
Since, as discussed above, adult eel fishing in marine waters is practically absent in Italy, most of the 
competences  on  eel  fishing  and  management  fall  onto  regions.96 The  central  government  remains 
responsible for (i) the fishing of glass eel in marine waters  and river  mouths; and (ii) coordinating 
regional EMPs. 

As  for  the  fishing  of  glass  eel  in  marine  waters  and  river  mouths,  a  secondary  legislative  act  –  a 
Ministerial  Decree  –  was  approved  jointly  with  the  adoption  of  the  Italian  EMP. 97  The  Decree 
establishes that, by 2013, 60% of glass eel catches are to be used for restocking purposes in waters 
communicating with the sea. In addition, it sets up a national register of fishers of glass eels, which 
are required to obtain an annual authorisation granted by the Ministry, through which catching quotas 
could be allocated. Furthermore, glass eel fishers are required to submit catch returns. In 2017, four 
operators were authorised, and the number has always remained below 10 units since the entry into 
force of the Decree.  In  other words, the Decree was implemented as  to prevent the  entry into the 
market of new operators.  

As discussed above, glass eel fishing in inland waters and lagoons is carried out only in the regions 
bordering the Tyrrenhian sea. At regional level, it has been prohibited in Sardinia, while it is subject 
to a regional authorisation in Tuscany and Latium. In both regions, about 3-4 licensed operators exist. 
For  operators  wishing  to  operate  both  in  marine  and  inland  waters,  both  the  national  and  regional 
licenses are to be obtained. Glass eel fishing is also prohibited in Adriatic regions (e.g. Veneto and 
Friuli  Venezia  Giulia),  where,  however,  the  presence  of  glass  eels  is  very  limited  and  no  related 
fisheries exist anymore. 

As  for  eel  management  in  inland  and  brackish  waters,  the  Italian  government  decided  to  identify 
regions as the relevant EMUs 98. Nine regions adopted an EMP99, while 11 did not. In the regions were 

95 See in particular the decline in Dutch aquaculture, as emerging from the WGEEL data. 
96 Italian EMP; ICES (2018), Country Reports 2017–2018: Eel stock, fisheries and habitat reported by 
country, Annex 5 to the ICES, Report of the Joint EIFAAC/ICES/GFCM Working Group on Eels (WGEEL). 
97 Decree of the Ministry for Agriculture, Fishery and Food Policies, 12.01.2011, Disciplina della pesca 
e della commercializzazione del novellame di anguilla della specie Anguilla Anguilla.  
98 As foreseen in Article 2 of the Eel Regulation. 
99 Lumbardy, Friuli Venezia Giulia, Veneto, Emilia Romagna, Tuscany, Umbria, Latium, Sardinia, and 
Apulia. 

 
                                           
CASE STUDY - ITALY 
an EMP was not adopted, eel fishing is prohibited. While not all 11 regions have included the prohibition 
into  their  legal  framework  yet,  the  measure  is  enforced  and  sanctioned,  as  it  is  deemed  to  derive 
directly from the Regulation100. The government played a coordinating role and suggested regions to 
focus on two sets of measures: (i) in the short term, restocking and reduction of the fishing effort; 
and (ii) in the long-term, reduction of other forms of anthropogenic mortality by restoring water and 
transit conditions. The various regions largely conformed to this approach. More in detail: 

• 

• 

• 

In Friuli Venezia Giulia, the EMP was adopted in October 2011. Two main interventions were 
deployed:  restocking  of  juvenile  eels,  and  reduction  of  the  fishing  effort.  For  professional 
fishing,  a  rest  period  was  introduced,  for  2  months  in  2011  and  4  months  thereafter, 
corresponding  to  a  33%  reduction.  A  fishing  ban  was  also  considered,  but  deemed  as  not 
compatible with the sustainability of the eel fishing and aquaculture sectors. For recreational 
fishing, each fisher cannot catch eels for more than 8 days per month over six months, with a 
maximum of two catches per day of minimum 40 cm. This corresponds to an effort reduction 
by  75%.  For  restocking,  annual  releases  of  juveniles  in  lagoons  and  other  freshwater 
environments  communicating  with  the  sea  have  been  deployed,  up  to  the  current  levels  of 
about  1  to  1.5  tonnes  per  year  (depending  on  the  market  price).  In  the  long-term,  further 
actions will be deployed to improve the quality of eel habitats and waters and re-establish river 
passages for eel.  

In Emilia Romagna, the EMP was communicated to the Ministry of Agriculture and Fisheries, 
but  never  approved  as  a  formal  regional  act.  However,  the  measures  included  were  later 
introduced  in  the  revised  fishing  regulation,  adopted  in  November  2017.  The  regional  EMP 
mainly focused on a reduction of the fishing effort, in particular by introducing: (i) a prohibition 
of commercial and recreational eel fishing in the month of November, which is considered the 
key period for eel escapement; (ii) a maximum amount of 2 catches of minimum 40 cm for 
recreational  fishers;  and  (iii)  the  prohibition  of  recreational  fisheries  with  bilancioni101 in  the 
Comacchio area, from the first weekend of March till May, 30th. Furthermore, alive or dead eel 
cannot  be  used  as  baits.  Restocking  of  juveniles  was  also  carried  out  (0.5  tonnes  in  2017). 
Other interventions included the opening of fish ladders over the Po and Reno rivers, and the 
fight against predators (in particular Silurus glanis). 

In Tuscany, the following actions have been taken: (i) regulation of glass eel fishing in inland 
waters  (as  describe  above);  (ii)  restocking  of  25%  of  glass  eel  fished  in  Tuscany  in  the 
protected wetted area of the Orbetello lagoon; (iii) re-establishment of passage conditions in 
Tuscan rivers; (iv) e-monitoring of eels in protected areas; (v) introduction of a cap to daily 
catches for recreational fishing (10 per days) and min-max dimensions (35-70 cm); and (vi) 
fight against predators (again, of the Silurus species). 

Progress to date 

[Information reported under effectiveness – JC2.1] 

100 Regolamento  regionale  di  attuazione  delle  disposizioni  in  materia  di  tutela  della  fauna  ittica  e 
dell’ecosistema acquatico e di disciplina della pesca, dell’acquacoltura e delle attività connesse nelle 
acque interne, a norma dell’articolo 26 della legge regionale 7 novembre 2012, n. 11. 
101 Fixed squared fishing net operated by levers. 

 
 
 
 
 
 
                                           
CASE STUDY - ITALY 
2. KEY FINDINGS 
RELEVANCE 

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

JC1a(1):  The  extent  to  which  eel  landings,  escapement  levels  and  river  basin  conditions 
have recovered sufficiently to warrant the measures being continued.   

While  an  improvement  of  eel  stocks  and  fishing  outputs  in  Italy  has  been  noted  by  both  public 
authorities  and  market  operators  after  the  introduction  of  the  Eel  Regulation,  levels  remain 
significantly lower than in the previous decades, and in particular in the 80’s. As a consequence, the 
analysis suggests that the main driver for the introduction of this piece of legislation remains 
valid  and  warrants  the  continuation  of  the  measure.  Rather,  the  approach  and  the  rationale 
could  be  revised  and  updated,  taking  into  account  the  more  recent  policy  developments,  and  in 
particular the inclusion of the European eel in the CITES convention. 

JC1b(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.   

With  few  caveats,  Italian  stakeholders  consider  the  objective  and  the  measures  of  the  Eel 
Regulation as still relevant. The drafting and application of EMPs is considered as relevant or partly 
relevant by all public authorities consulted, pointing out that attention is – obviously – to be paid to 
the actual content of the plans, the timing of the measures proposed, and the associated monitoring 
efforts, both on the status of eel stocks, and on the actual carrying out of the measures themselves. 
In this context, all interviewees suggest that the inclusion of detailed control and monitoring provisions 
in both the Regulation and in the EMPs is crucial for this policy to reach its objectives (‘The Regulation 
goes nowhere without proper monitoring and enforcement’). As for monitoring, the Regulation should 
be accompanied by sufficient resources to implement proper plans. 

The 40% escapement target is considered necessary and relevant by public and private stakeholders, 
especially because the additional escapement of silver eels already apt for reproduction can have an 
immediate positive effect on the status of the stock (as compared to other more long-term measures, 
such as restocking and installation of river passages). However, stakeholders questioned whether the 
decision  to  set  the  objective  at  40%  is  realistic,  and  the  scientific  basis  for  opting  for  this  level  is 
sound, given that (i) there is no real data on the ‘pristine’ stock; and (ii) most importantly, since the 
1980s the habitats for eels have been largely reduced (in Italy and elsewhere in the Southern part of 
the EU), due to the fact that in many cases lagoons have been dried out for agricultural or other urban 
zoning purposes. As one stakeholder put it, ‘it will be impossible to have a 40% escapement compared 
to pristine condition if less than 40% of the habitats is available today’. However, Italian eel habitats, 
and in particular lagoons, still have large ‘spare room’ to accommodate additional eel stock, and thus 
contribute to the 40% target. 

With respect to the  reduction of the fishing efforts,  opinions are more diverse. The majority of the 
public authorities consider that as an extremely relevant measure, capable of having an immediate 
and large effect  on the  stock.  Indeed, the early partial recovery of the stock in Italy is linked by a 
number of researchers to the reduction of the professional fishing effort in the EU. Other stakeholders, 
including local administrations and, most vocally, economic operators, suggest that eel fishing in Italy 
is  already  at  such  a  low  level  –  ten  times  lower  than  25  years  ago  –  that  any  further  reduction in 
fishing efforts would be of no relevance for the status of the eel stock and that, in any case, it would 
definitely  hamper  the  socio-economic  sustainability  of  the  eel  sector,  and  would  thus  need  to  be 
accompanied  by  compensatory  measures.  Both  groups  agree  that  a  targeted  effort  to  reduce  or 
eliminate recreational fishing could also be relevant, and with no or negligible negative consequences. 

As for other forms of reduction of anthropogenic mortalities – such as river and lagoon restoration – 
stakeholders  consider  them  relevant,  but  only  in  the  long-term,  and  with  a  significant  caveat.  The 
installation of fish ladders works well to repopulate river sections or lakes in which the eel used to live. 
However, since it is usually not accompanied by interventions to allow the eel to return to the river 
mouth, its contribution to the 40% escapement objective remains questionable. Other measures, such 

 
CASE STUDY - ITALY 
as traceability and the availability of a sufficient supply of glass eels  for  restocking, are  considered 
useful by the stakeholders, but only together with the more relevant measures described above. 

EFFECTIVENESS 

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

JC2 (1): EMPs implemented and specific targets achieved. 

The implementation of the national and regional EMPs 102 has proceeded steadily, albeit, at 
times, slowly.103 At national level, the measures on glass eels have been implemented and enforced 
and froze the number of operators and fishing efforts in the sector. Furthermore, the national EMPs 
have been successful in coordinating regional plans, and thus efforts, in a consistent direction, and 
have led to the collection of sufficient data for monitoring the Regulation in Italy. 

At regional level, the various EMPs have led to an adaptation of the local fishing rules, which reduced 
the fishing effort by both professional and recreational fishers. In all regions covered, a resting period 
for  the  commercial  fisheries  has  been  introduced.  In  principle  this  is  a  positive  measure,  but,  as 
pointed  out,  eel  fishing  activities  are  seasonal,  and  eel  escapement  can  be  supported  only  by 
intervening  in  certain  months,  i.e.  those  in  which  eels  are  more  likely  to  return  to  the  sea.  As  for 
recreational fishing, all regions except for Apulia have introduced limitations to the number of catches 
and the minimum size, and to the period in which eels can be fished.  

The available information on the reduction of the fishing effort and the introduction of resting periods 
is summarised in Figure below. On the left side, the fishing effort by commercial operators deployed 
in the nine EMUs in which eel fishing is allowed is reported, measured in terms of active fishermen, 
fishing  days,  and  fyke  nets.  By  this  aggregated  measure,  the  effort  has  declined  by  44%  between 
2012 and 2017, from about 5.5 million units, to about 3 million. On the right side, the average resting 
period per EMU for both commercial and recreational eel fishing is displayed. For both types of fishing 
activities,  the  resting  period  enlarged  more  and  more.  More  in  details,  for  commercial  fishing,  the 
close season has doubled, from an average of 73 resting days in 2012, to 143 in 2017; for recreational 
fishers, it increased from about 120 to half a year (185 days). 

Figure 1: Reduction of fishing effort 

Commercial fishing effort 

Average close season 

6.000.000

4.000.000

2.000.000

0

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a
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150

100

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2013

2014

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2016

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2012 2013 2014 2015 2016 2017

Active fishermen * Fishing days * Fyke nets used daily

Commercial fishery

Recreational fishery

Note: data covering Italy’s nine regional EMUs.  Source: Italian EMP Progress Report 2018 

102 As above, the analysis mostly focuses on the three regions covered by the interview programme: 
Tuscany, Emilia Romagna, and Friuli Venezia Giulia. For a more comprehensive picture, cf. Italian EMP 
Progress Reports for 2015 and 2018, and in particular Table 6 – Management measures. 
103 Cf. Report on the eel stock, fishery and other impacts, in Italy 2018 in: ICES, Report of the Joint 
EIFAAC/ICES/GFCM Working Group on Eels (WGEEL), at p. 273; Italian EMP Progress Report 2018, at 
p. 15. 

 
 
 
 
 
                                           
 
 
 
 
 
CASE STUDY - ITALY 
The  limitations  to  the  fishing  efforts  have  been  complemented  by  restocking  activities,  which  have 
however not been undertaken extensively in all regions, especially because they required mobilising 
public resources for purchasing glass eels or juveniles. As shown in Figure  below, while between 2012 
and 2014 about 400-600 kg  of glass  eels were restocked across the 9 EMUs  each year, this figure 
dropped to around 100 kg in the period 2015-2017. In Tuscany, one measure particularly praised by 
the stakeholders concerned the restocking of locally-sourced glass eels into the protected habitat of 
the Orbetello lagoons, where fishing efforts are controlled and eels can thus escape once they become 
sexually mature. Most of the EMUs, however, do not carry out glass eel restocking, or have stopped 
during the period under analysis. In addition, few regions, such as Friuli Venezia Giulia and Veneto, 
carry out restocking activities with other juvenile eels, purchased in other Member States and then 
grown locally. 

Figure 2: Restocking activities 

800

600

400

200

0

2012

2013

2014

2015

2016

2017

Wild glass eels stocked according to EMP (kg)

Note: data covering Italy’s nine regional EMUs.                 Source: Italian EMP Progress Report 2018 

As described above, other forms of intervention, such as habitat restoration, were considered as long-
term interventions. For this reason, only few regions have already carried out these measures (such 
as Emilia Romagna on the Po and Reno rivers, or Tuscany, which financed river passage restorations 
for about € 80,000 via European funds). In other regions, such as Friuli Venezia Giulia, a requirement 
has  been  introduced  for  new  river  installations  to  include,  by  default,  a  fish  ladder.  While  further 
information on regional measures is described further below, no overall assessment is available from 
public sources. 

JC2 (2): European eel stock has recovered. 

Italian stakeholders cannot have a comprehensive view on the status of the European stock, but have 
provided some indications of the availability of adult or juvenile eels in Italy, or in other EU markets 
in which they operate: 

1)  in Emilia Romagna, based on fish data and fishers’ feedback, the stock of yellow and silver eels 
is  considered  stable,  or,  possibly,  slightly  growing.  However,  there  is  no  sufficient  granular 
monitoring of adult eels and recruitment levels; and 

2)  in Friuli Venezia Giulia, catches have recently increased, but this does not automatically mean 
that the stock has also increased, given that the fishing effort, weather conditions and market 
conditions could impact catches. The recruitment, as monitored by the region, has remained 
limited.  

One economic operator reported no significant change in the availability of European eels across the 
EU  markets,  and,  more  specifically,  no  upward  pricing  trend  in  the  recent  years.  Rather,  the  price 
trend is  cyclical, with price growth followed by significant restocking in farms, leading to excessive 
production,  and  then  to  a  price  decrease.  The  cyclic-but-stable  price  is  assumed  to  be  a  signal  of 
stable  catches  and,  possibly,  a  non-declining  stock.  Another  economic  operator  which  imports  eels 
from  France  noticed  that  the  share  of  smaller  eels  in  the  total  population  has  increased,  and  this 
suggests that the density of the stock in the French lagoons is increasing. A similar phenomenon is 
occurring in Greece, according to the same operator. Overall, according to these operators, the level 
of catches of wild eels in Europe point to no additional stock decrease.  

 
 
CASE STUDY - ITALY 
JC2 (3): Anthropogenic mortalities have been reduced. 

Interventions  to  reduce  anthropogenic  mortalities  have  been  included  in  the  national  and  regional 
EMPs; however, they were included among the long-term measures, while short-term policies largely 
focused  on  the  reduction  of  the  fishing  effort  and  restocking.  Several  regions  have,  however, 
introduced  measures  for  habitat  restoration  over  the  2007-2018  period,  both  by  relying  on  own 
resources  and,  especially  for  larger  interventions,  by  relying  on  EU  funding  (e.g.  EFF  or  LIFE+ 
programme). In Emilia Romagna, fish ladders have been opened on the rivers Po and Reno and are 
planned on the Savio. In the Reno ladder, eel passage has already been observed; in the Po river, a 
dedicated monitoring tool for eels is soon to be installed (as the ladder is very recent). 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.  

As  discussed  above,  stakeholders  consider  these  interventions  as  very  important  to  enlarge  the 
habitats  for  eels.  At  the  same  time,  if  not  accompanied  by  descent  measures,  they  can  hardly 
contribute to the 40% escape target, as eels may “easily” go up the river but would still find significant 
barriers in their descent. In particular, hydroelectric power plants represent an important source of 
mortality for eels and are present (usually in multiple instances) in all eel-relevant Italian hydrographic 
basins.  An  intervention  on  hydropower  plants  to  favour  escapement  would  need  to  be  coordinated 
among  regions  –  responsible  for  inland  waters  –,  public  authorities  responsible  for  electricity 
production, and plant operators. 

JC2  (4):  Adult  eel  escapement  progressed  towards  the  long  term  40%  escapement 
objective. 

As for the achievement of the 40% target, the Italian authority considers that it could be realistically 
achieved by 2050 and adopted a number of intermediate objectives. In particular, by 2020 a 17.5% 
target should be achieved. This intermediate target was already overcome in 2017, when the 
estimated biomass of escaping eel spawners reached 21% of the pristine condition, or 54% of the Eel 
Regulation target. Italy thus appears on track for reaching the 40% objective by 2050104.  

Importantly,  however,  most  of  these  early  gains  resulted  from  the  limitations  to  adult  eel  fishing 
adopted in Europe and  were  sort  of ‘low hanging fruits’. Reasonably, in the near future the  rate of 
growth of the biomass of escaping eel spawners may decrease, and any further increase can only be 
sustained  by  an  increase  in  eel  recruitment  –  which is  hardly  noticeable  at  the  moment.  However, 
since glass eels are hardly present  on Italian shores, this would rather depend on actions at  EU or 
other MS level. 

JC2 (5): Supply of glass eels sufficient for restocking operations. 

In Italy, 60% of the glass eels fished must be used for restocking purposes. All glass eels fished over 
the recent years (2015-2017) were used for restocking purposes in freshwaters or coastal lagoons. 
Actually, glass eel fishers in certain areas (Tuscany, Apulia, Latium) go fishing only if and when the 
regional authority commits in advance to buy the output for restocking purposes. In 2012-2014, glass 
eel  catches  were  in  part  used  for  farming  purposes;  while  the  exact  quantities  are  unknown,  the 
percentage is likely to amount to less than 40% of total catches105.  

Restocking is done in river or coastal areas, some of which benefit from fishing limitations. The latter 
is  the  type  of  restocking  that  is  considered  the  most  effective  by  public  authorities  and  private 
stakeholders,  since  juveniles  are  moved  from  an  area  in  which  they  are  subject  to  anthropogenic 
pressure,  to  an  area  from  which  they  enjoy  a  higher  escapement  rate.  However,  in  other  cases, 
restocking is used to repopulate fishing areas, vallicoltura or areas from which the eel population had 
disappeared,  and  these  types  of  restocking  are  likely  to  have  a  more  limited  impact  on  the 
achievement  of  the  40%  escapement  objective.  For  this  reason,  even  though  several  restocking 
campaigns were successful and subsequent monitoring verified that eels established in the selected 

104 Italian EMP Progress Report, 2018. 
105 Ibid., at p. 16. 

 
                                           
CASE STUDY - ITALY 
areas and started growing, they may have had a limited impact so far on the  reconstitution of the 
stock, possibly much lower than the reduction of the fishing effort.  

The Italian glass eels supply is too limited to meet the demand for restocking, since many regional 
authorities have included this measure in their EMPs among their priorities. For this reason, certain 
regions also restock larger eels (i.e. bigger than 12 cm) and, most importantly, buy supply from other 
MS,  in  particular  France.  The  price  of  glass  eels  is  considered  an  obstacle  by  the  regional 
administrations,  so  that  the  amount  of  restocking  is  affected  by  yearly  price  conditions  (since  the 
available public budget is set in advance). However, glass eel availability was not considered as an 
issue by regional authorities.  

One economic operator pointed out that, in Italy, glass eel restocking is not used as an indirect subsidy 
for aquaculture producer, with positive impacts on the effectiveness of this measure. Indeed, in certain 
MS, glass eels for restocking purposes are reportedly bought from famers, so that there is the risk 
that the best specimens are kept for aquaculture, and that a ‘second quality’ population is used for 
restocking, with corresponding lower success rates.  

JC2 (6): Fishing effort reduced by at least 50% relative to the average effort 2004-2006 or 
ensure reduction of catches by at least 50%. 

All regions have reduced the commercial fishing effort, mainly by introducing rest periods or reducing 
the  number  of  active  fish  days 106,  and  partly  by  identifying  areas  where  eel  fishing  is  limited  or 
prohibited. In 2017, the fishing effort reduction over the 9 EMUs where eel fishing is allowed totalled 
about 3 million units107. While there is no available baseline to verify whether this corresponds to a 
50%  decrease  compared  to  the  2004-2006  efforts,  the  qualitative  assessment  from  stakeholders 
suggests that the reduction may be in this order  of magnitude. In particular, the number  of  active 
fishers declined by about one third (from 1,700 to about 1,200), and this, combined with the reduction 
in the fishing period, suggests that the decrease is close to or higher than the 50% objective. 

As  of  2017,  all  regions  except  for  Apulia  had  introduced  some  measures  for  the  reduction  of 
recreational eel fisheries108. The measures include: (i) limitation of the fishing period; (ii) limitation of 
the number of days in which eels can be caught over the fishing period; (iii) introduction or reduction 
of  catch  quotas;  and  (iv)  introduction  of  maximum  or  minimum  catch  size.  Even  following  these 
measures,  recreational  catches  remain  significant.  In  Friuli  Venezia  Giulia,  a  sample  analysis  of 
recreational fishers suggests that the amount of catches could reach up to 2.6 tonnes, that correspond 
to  about  three  quarters  of  the  commercial  landings  in  that  region.  Data  submitted  to  the  WGEEL 
suggest that, in Italy, recreational catches could reach up to 40 tonnes109, that is 20% of commercial 
landings of wild eels. No region has so far introduced a ban of eel recreational fishing, and the reasons 
seem to be a resistance from traditional fishers, the fear of going against an established local tradition, 
and the difficulty in monitoring the ban. Several stakeholders have pointed out that the recreational 
eel  fishing  activity  is  marginal  and  practiced  only  by  elder  fishermen;  however,  this  seems  in 
contradiction with the total catches estimated by both the model analysis, and, most importantly, the 
few available real data on catches. 

106 Italian EMP Progress Reports, 2015 and 2018. 
107 That  is,  number  of  fishers  *  fishing  days  *  number  of  fyke  nets  used  daily;  barriers  efforts  not 
considered. Cf. Italian EMP Progress Report 2018, Table 6 – Management Measures. 
108 Ibid. 
109 Report  on  the  eel  stock,  fishery  and  other  impacts,  in  Italy  2018  in:  ICES,  Report  of  the  Joint 
EIFAAC/ICES/GFCM Working Group on Eels (WGEEL), at p. 263-265. 

 
 
 
                                           
CASE STUDY - ITALY 
JC2  (7):  Origin  and  traceability  of  all  live  eels  imported  and  exported  from  MS  territory 
maintained.  

In Italy, traceability of all live eels imported into and exported from the MS territory is maintained and 
enforced  by  the  CITES  group  of  the  Carabinieri  Forestali  (one  of  the  Italian  police  corps).  In  Italy, 
international  traders,  as  well  as  economic  operators  detaining  live  eels,  are  subject  to  CITES 
obligations, and in particular required to keep a detailed purchase and sale registry, where the origin 
of the live eels and their destinations are recorded. An exception has been introduced for economic 
operators detaining live eels only for domestic trading purposes; however, eel farmers and processors 
are subject to CITES obligations even if they do not engage in international trade, but only use locally- 
or EU-sourced live specimens. Domestic eel traders are, to the contrary, only subject to the traceability 
requirements applicable to all fish species110 (i.e. indication of the catch zone and technique).  

Imports and exports of adult eels is subject to licenses; exports and imports of juvenile eels is banned. 
Checks are carried out at borders, as well as internally at traders’, famers’, and processors’ premises. 
Following  the  introduction  of  the  European  eel  in  Appendix  II  of  the  CITES  convention,  and  the 
transposition in the Italian legislation, the Carabinieri Forestali engaged in training activities for local 
inspectors to make them aware of the new limitations and of the characteristics of the specimen. 

JC2 (8): Control and enforcement activities in support of the implementation of the EMPs 
have taken place in EU waters (and national fresh water) and at all stages of the eel supply 
chain. 

The  introduction  of  the  Eel  Regulation,  and  the  consequent  national  and  regional  EMPs,  are 
unanimously considered by the stakeholders as a key change in the control and enforcement of eel-
preservation policies in Italy. The Regulation and the EMPs were instrumental in putting the problem 
‘on the radar’ of public authorities and enforcement bodies, and even more so after the inclusion of 
eels in the CITES Appendix. While the enforcement of the measures described above, and in particular 
of  the  limitation  of  recreational  and  commercial  fishing  efforts,  is  still  less  than  perfect,  an 
improvement was clearly noticed by all stakeholders (‘There was no attention to eels at all before; 
now you have prohibitions and some people going around and verifying compliance’). The awareness 
raised among commercial fishers by the drafting and deployment of the EMP also fostered a number 
of ‘self-regulation’ actions, as legal fishers became more active in signalling fraudulent activities. In 
this regard, certain stakeholders suggest that any control policy needs to necessarily rely on regular 
commercial fishers.  

110 Cf. Ministry for Agriculture, Food and Forestry Policies, Circulars on CITES – Inclusione della specie 
Anguilla Anguilla nell’allegato B del Reg. (CE) 338/97, 19 May 2009 and 26 October 2009; 

 
 
 
                                           
CASE STUDY - ITALY 
EQ 3.  If the measures for the recovery of European eel stock under the Eel Regulation have 
only partially met the objectives in EQ 1, what factors have hindered their achievement and 
how? 

JC3 (1): Identification of the key barriers to achieving the objectives. 

A number of barriers have been identified by Italian stakeholders as preventing the full achievement 
of the objectives set by the Eel Regulation, and in particular the improvement of the stock and the 
fulfilment  of  the  40%  target  for  escapement  of  spawners.  The  near  totality  of  stakeholders  have 
mentioned glass eel fishing as the most significant threat to the improvement of the stock. Various 
drivers  have  been  mentioned  as  leading  to  the  overexploitation  of  this  resource,  including  legal 
demand  for  aquaculture  activities  in  Europe111,  and  the  smuggling  of  glass  eels  towards  extra-EU 
farmers,  especially  in  Asia,  which,  according  to  some  sources,  could  represent  up  to  50%  of  EU 
traceable legal catches (i.e. not counting illegal fishing activities112). In this context, DNA controls on 
imports of adult eels from other jurisdictions, and in particular from China, would allow to verify that 
they do not belong to the Anguilla subspecies, thus reducing the incentives for smuggling European 
glass eels that eventually come back to the EU as adult eels. In Italy, glass eel smuggling is considered 
by public authorities and economic operators alike as very low or absent, given that in many regions 
glass eels are not present and legal fishing activities are limited to Tuscany and Latium. In a limited 
number of cases, fishers have been fined when moving from their own area to neighbouring regions, 
but no cases of smuggling where signalled113. The use of glass eels for human consumption in certain 
MS has also been mentioned by some stakeholders as a secondary driver, which, though of a lesser 
importance, contributes to stock depletion and has not been addressed so far by the Eel Regulation.  

The second main obstacle mentioned by the stakeholders, and in particular by public authorities, is 
the lack of funding associated to 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. However, the 
Regulation does not provide for some forms of compensation for public and private stakeholders. Using 
EFF  /  EMFF  resources  is  difficult,  since  these  funds  do  not  provide  for  dedicated  lines  for  the 
implementation of the Eel Regulation specifically, or eel management more in general. Some regions 
have been able to use EFF or LIFE+ resources to finance certain measures, but this was only sporadic 
and could not guarantee a sufficient continuity for multi-year interventions. In particular, regions have 
not  been  able  to  use  EFF  resources  for  compensating  rest  periods  (‘EFF  resources  can  be  used  for 
general rest periods, but it is very difficult to justify their use when rest periods are species-specific’). 
Italy has also failed to allocate at central level resources for the deployment of the EMPs, which could 
have been then used by regions to finance their measures. 

Other factors include: 

• 

• 

the  growth  of  eel  predators,  both  among  fishes,  which  have  been  targeted  by  abatement 
measures, and among birds (as discussed below in the ‘Coherence’ section); 

changes to climate and ocean conditions which could affect the migration to and return from 
the Sargasso seas; 

•  decrease  in  the  production  of  the  japonica  subspecies,  which  increased  the  demand  for 

European eels (including glass eels); and 

•  anthropogenic pressure, which led to a loss of eel habitats. 

111 Cf. Aschonitis, V., Castaldelli, G., Lanzoni, M., Rossi, R., Kennedy, C., & Fano, E. A. (2017). Long
term records (1781–2013) of European eel (Anguilla anguilla L.) production in the Comacchio Lagoon 
‐
(Italy):  evaluation  of  local  and  global  factors  as  causes  of  the  population  collapse.  Aquatic 
Conservation: Marine and Freshwater Ecosystems, 27(2), 502-520. 
112 Cf.  Sustainable  Eel  Group  (2018).  Quantifying  the  illegal  trade  in  European  glass  eels  (Anguilla 
anguilla): Evidence and Indicators. SEG-Report:2018-1-V1. 
113 Local media sometimes mention cases of eel smuggling or illegal fishing, but they concern adult 
eels. 

 
 
 
                                           
CASE STUDY - ITALY 
JC3  (2):  Identification  of  the  common  and  outstanding  successes  and  resulting  best 
practises that have allowed progress towards achieving the objectives. 

Two best practices emerged from the fieldwork in Italy, one concerning an output of the Regulation, 
i.e.  a  good  restocking  practice,  and  one  concerning  a  process,  i.e.  the  involvement  of 
stakeholders in the drafting and approval of the EMPs. 

As  already  discussed  above,  the  effectiveness  of  restocking  is  questioned  when  just  resulting  into 
moving  resources  from  an  area  in  which  they  would  be  subject  to  exploitation,  to  another  area  in 
which they would still be subject to fishing, or in aquaculture farms and valli. Unfortunately, in Italy, 
and reportedly in other EU MS, restocking is partly carried out that way, i.e. by measures which pursue 
the  conflicting  objectives  of  sustaining  both  the  stock  and  the  escapement  of  spawners,  and  eel 
production  in  coastal  areas  where  recruitment  is  insufficient.  Differently,  in  several  cases  (e.g.  in 
Tuscany,  Friuli  Venezia  Giulia,  and  Sardinia)  part  of  the  restocking  takes  place  in  protected  areas, 
subject  to  active  monitoring,  so  that  the  eels  growing  therein  are  not  (or  limitedly)  subject  to 
anthropogenic pressure and fishing efforts. As  these areas are  connected to the  sea, the likelihood 
that  juveniles  become  escaping  spawners  is  much  higher.  This  is  considered  a  particularly  good 
practice when restocking relies on local supplies, which also creates a gain for fishers, which can fish 
glass eels for supplying the public authority, and also get a compensation for running incubators in 
which glass eels are bred before being released in the wild. 

The other best practice concerns the way regional EMPs have been drafted. In all cases, the process 
involved all relevant operators, including fishers, vallicoltura farmers and aquaculture operators. On 
the negative side, this may have slowed down the process and limited the regions' leeway to impose 
stricter fishing limitations. However, the creation of multi-stakeholder platforms 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). 

JC3 (5): Have the control & enforcement measures at MS levels been adequately resourced 
and implemented? 

A key criticism brought forward by the Italian regional administrations concerns the lack of targeted 
funding, at national and EU level, to finance the control and enforcement measures foreseen by the 
EMPs, and to compensate stakeholders  for their impacts. As discussed above, this applies first and 
foremost to fishing rest periods. The same reasoning, however, also applies to control and monitoring. 
Collecting the data necessary to monitor compliance with the Eel Regulation and the progress towards 
its  objectives  requires  costly  campaigns,  for  which  no  or  limited  resources  were  posted  at  EU  or 
national level. Certain regions (e.g. Friuli Venezia Giulia) financed their own monitoring systems of eel 
stock and recruitment; other (such as Tuscany) used EFF resources to do so (via a € 90,000 project 
on monitoring eels in local protected areas). However, the use of the EFF reportedly creates problems 
of  continuity,  especially  because  there  is  no  dedicated  line  of  funding  for  eel  management.  As  for 
enforcement  efforts,  the  stakeholders  largely  agree  that  additional  enforcement  actions  have  been 
deployed, relying on existing structures and institutions, i.e. both the environmental police and the 
regional administrative control systems.  

 
 
 
 
CASE STUDY - ITALY 
SUSTAINABILITY 

EQ 5.  Are the effects likely to last after the intervention ends? 

JC5 (1): The extent to which measures implemented under the Eel Regulation have long-
term impacts, even if the intervention were to cease. 

All stakeholders consider that long-term measures would be sustainable even if the Regulation were 
to cease, while short-term measures would not. In particular, the restocking carried out in these years 
would produce positive results over the following 10 years – although it is uncertain how many adult 
eels  are  going  to  escape  thanks  to  the  restocking  activities  carried  out  so  far;  furthermore,  the 
restoration of river and lagoon habitats and the introduction of fish ladders would continue to produce 
beneficial effects on the status of the stock. On the contrary, other short-term measures, such as the 
reduction  of  recreational  and  commercial  fishing  efforts,  would  no  longer  generate  impacts  if  the 
Regulation and its implementing measures were to cease. 

EFFICIENCY  

EQ 6. 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? 

JC6  (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. 

Italian  stakeholders  were  largely  not  in  the  position  to  compare  the  costs  of  the  local  measures 
adopted and the benefits in terms of improving eel stocks, because the improvement of the stock is 
not only a local phenomenon and the related information is scant. However, they have been able to 
provide an informed guess on the reasonable  cost-effectiveness of certain measures,  which can be 
summarised as follows. 

•  Rest period for professional fishers. The reduction of the fishing efforts by introducing rest 
periods is reportedly having a positive effect on the status of the eel stock, though imposing a 
burden on professional fishers, who cannot produce revenues from eels during those periods. 
Given that, as discussed above, eel rest periods are hardly compensated, the socio-economic 
sustainability of eel fisheries can be put at risk. Even though the economic importance of eel 
fishing is decreasing, this activity remains an important source of income for small fishers in 
coastal lagoons, also because eels are one of the few winter catches in these areas. Both private 
and public stakeholders concur that any  further decrease in the fishing effort would put the 
survival of Italian eel fisheries at risk, if not properly compensated. Though reducing catches 
and improving the stock, this would generate a social cost in the areas where eel fishing is still 
present and deprive the eel management system from a  ‘privileged point of observation’  on 
the status of the stock and on eel habitats, and of a self-interested safeguard against illegal 
fishing. 

•  Restocking.  Obviously,  restocking  requires  regional  authorities  to  mobilise  public  funds  for 
buying glass eels or juveniles. This can be done via own resources which needs to be found 
each year in the regional budgets. For instance, in the recent years, Friuli Venezia Giulia spent 
about € 50,000 per year to buy and restock juveniles (about 1 tonne, depending on price and 
market conditions), and to compensate local vallicoltori for using their areas for breeding. In 
Tuscany, restocking was financed through EFF resources (about € 100,000 over four years). 
Since the effects on the stock are yet to be determined given the time lag between restocking 
and escapement/recruitment, assessing the cost-effectiveness of restocking is not possible yet. 

 
 
 
CASE STUDY - ITALY 

•  Installation of fish ladders. This measure can be very costly, up to several millions € (e.g. 
for the fish ladder of Isola Serafini, on the Po river). For smaller rivers, the costs are estimated 
between hundreds and tens of thousands of euros, depending on the complexity of the project. 
On the one side, these installations contribute to the general restoration of river environments 
and benefit many species other than eels only. At the same time, given that eels need to both 
climb  and  descend  the  rivers,  the  cost-effectiveness  of  fish  ladders  is  limited,  if  not 
accompanied by interventions to favour eel descent, and thus escapement. 

•  Traceability. Traceability requirements impose a cost on economic operators, in particular the 
obligation to keep detailed registries of purchases and sales. In Italy, this requirement applies 
not only to importers or exporters, but also to farmers and processors detaining live eels. The 
issue is not perceived as a significant burden by farmers: on the one side, they are accustomed 
to keep a number of veterinary registries, and on the other they buy from and sell to a limited 
number of customers via a limited number of transactions. As for fish processors, the costs of 
detaining the CITES registry are considered as very high for various reasons. On the one side, 
the requirement is considered as ‘unfair’, since fish processors in general have to comply with 
a  number  of  trade  limitations  for  their  fish  supplies  (e.g.  under  FAO  rules),  but  only  eel 
processors have also to comply with CITES requirements. Fish processors have also pointed 
out that CITES requirements are designed for small imports of protected animals or vegetable 
specimens, not for animals used for food production, which are bought and processed in large 
stocks. Finally, another difficulty is that their distribution chain is ramified, with thousands of 
customers,  overcomplicating  downward  traceability.  One  processor  has  estimated  that  one 
person has to work almost full time over the eel season (about four months) to comply with 
CITES  requirements. Applying the Standard Cost Model methodology and given the average 
earning of a clerk in Italy, this would correspond to an administrative burden for the company 
of  about  €  11,100  per  year 114.  While  the  per-company  figure  is  very  high,  the  number  of 
operators  subject  to  these  requirements  is  limited  (in  addition  to  international  traders,  the 
population consists of up to 10 farmers and no more than a few processors). As a result, total 
costs are probably limited, and the cost-effectiveness  of CITES traceability measures, which 
are  consistently  considered  a  positive  evolution  of  the  policy  landscape,  can  be  deemed  as 
positive. 

EQ7.   Could the use of other policy instruments or mechanisms have provided better cost-
effectiveness? Do you think there are better and more cost-effective methods that can be 
implemented instead of the existing?   

JC7 (1): The extent to which alternative options exist and an assessment of their relative 
cost-effectiveness and contribution to the objectives of the Regulation.   

Stakeholders have pointed to other alternative measures that should be considered, but could provide 
limited information on their relative cost-effectiveness:  

1)  Prohibition  of  recreational  fishing  of  eels.  Apart  from  resistance  from  local  fishermen,  this 

measure would have no or negligible associated costs; 

2)  Severe  limitation  to  the  fishing  of  glass  eels.  All  glass  eel  fishing  would  be  subject  to 
authorisation  and  quotas,  and  quotas  would  be  granted  only  based  on  the  needs  of  the 
aquaculture sector or for restocking measures. No glass eels could be used for other purposes 
(e.g.  human  consumption).  This  could  reduce  the  socio-economic  sustainability  of  glass  eel 
fisheries. 

3)  Deployment  of  additional  funds  for  research  on  eels,  especially  on  their  reproduction  in 

captivity. 

114 Considering an average salary for an Italian clerk of € 41,500 per year (source: Eurostat Earning 
Statistics, 2014), and that the clerk works  four months  for 80% of his/her time on  complying with 
CITES. 

 
 
 
                                           
CASE STUDY - ITALY 
COHERENCE 

EQ 9.  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)? 

JC9  (1): The extent to which  wider fisheries  and environmental policies  remain coherent 
with the objectives and measures under the Eel Regulation.  

No  coherence  issue  has  been  signalled  by  stakeholders  between  national  legislation  and  the  Eel 
Regulation. As for coherence with other EU pieces of legislation or international policies, the following 
points have emerged from the consultation: 

1)  international policy changes intervened after the approval of the Regulation, in particular the 
inclusion of the Anguilla Anguilla within the CITES Convention (in Appendix II) and within the 
red list of critically endangered species by the IUCN. The Regulation should reflect these policy 
developments and update the list of suggested and required measures for eel protection. In 
particular,  the  fact  that  the  Regulation  still  allows  for  the  fishing  of  juveniles  of  a  critically 
endangered species seems to be a significant inconsistency; 

2)  a positive role has been played by the Water Framework Directive (WFD)115, whose measures, 
aimed at requiring MS and local authorities to improve water quality and aquatic ecosystems, 
strongly complemented the Regulation’s objective to reduce anthropogenic mortality by means 
other than the reduction of the fishing efforts; and 

3)  the Birds Directive116 negatively interacts with the Eel Regulation with respect to cormorants 
(species  Phalacrocorax).  The  Directive  lists  cormorants  among  the  species  in  Annex  I,  i.e. 
species which are particularly threatened. However, cormorants are one of the eel predators, 
and their presence in  Italian wetted areas has  increased significantly over the last decades, 
contributing to the decline of the eel stock. While regions can contain fish predators, deploying 
containment and selected reduction actions against cormorants is much more difficult, given 
their status under the Birds Directive. Although derogations are possible,117 obtaining them in 
order  to  deploy  effective  local  reduction  plans  became  more  difficult  given  the  cormorants’ 
status the Birds Directive. 

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?  

A limited number of stakeholders could comment on how the situation would have evolved if no EU 
action were taken. The EU action is largely considered as desirable and needed in this context, as in 
Italy, at both central and regional level, the attention to eels was very limited before the adoption of 
the Regulation. Furthermore, since the stock is European, without a coordinated EU action there could 
be a tendency to free-riding and a limited incentive for MS to introduce costly actions, such as fishery 
rest periods or restocking. 

115 Directive 2000/60/EC of the European Parliament and of the Council establishing a framework for 
Community action in the field of water policy. 
116 Directive 2009/147/EC of the European Parliament and of the Council on the conservation of wild 
birds. 
117 Cf. Article 9(1)(a) of the Birds Directive. 

 
 
 
 
 
 
                                           
CASE STUDY - ITALY 
3. CONCLUSIONS AND RECOMMENDATIONS  

Italian stakeholders hold a moderately positive view of the Eel Regulation, and the way it has been 
implemented at central and regional level, although views are nuanced from EMU to EMU and across 
private vs. public stakeholders. Even though certain measures have been deployed sometimes slowly 
and  sometimes  only  partially,  all  EMUs  have  intervened  by  reducing  fishing  efforts,  carrying  out 
restocking, and, in some cases, restoring lagoon and river environments. Italy is on track for achieving 
the 40% escapement objective by 2050, and currently the estimated escapement level is at 21% of 
the pristine condition. Though monitoring is far from perfect, the operators have signalled that catches 
are growing, and local stock levels seem stable or possibly even growing, though remaining still very 
low compared to the 80’s. 

The  situation  is  far  from  being  perfect,  and  the  effectiveness  of  regional  EMPs  is  still  only  partial, 
especially taking into consideration that, 11 years after the adoption of the Eel Regulation, only few 
regions have moved from short-term to long-term interventions (and some short-term interventions 
have  been  adopted  only  over  the  last  couple  of  years).  Furthermore,  interventions  on  recreational 
fisheries have probably been yet too shy, and enforcement and monitoring actions too limited. Even 
taking  into  consideration  these  negative  aspects,  however,  the  Eel  Regulation,  as  implemented  by 
national and regional EMPs, remains a game changer in introducing eel management and preservation 
policies, and in putting the problem on policymakers and stakeholders’ radars. 

To progress further, the following recommendations have been collected from stakeholders: 

1)  strongly reduce glass eel fishing across the EU, by clamping down on illegal fishers and 
traders, and by reducing legal fishing efforts. Ideally, glass eels should be subject to a quota-
system, so that no more than what is needed for aquaculture and restocking purposes can be 
caught. Human consumption of glass eels should be prohibited; 

2)  further progressively reduce the fishing effort of adult eels, in particular by intervening 
when  socio-economic  drawbacks  are  smaller,  i.e.  by  banning  recreational  eel  fishing  and 
providing incentives for fishers and farmers to switch to other species. Any further constraint 
on professional fishing efforts should be compensated via monetary subsidies; 

3)  introduce  dedicated  lines  for  eel  management  and  preservation  in  the  EU  fishery 

funds, which could be used to support restocking, rest periods, and monitoring efforts; 

4)  improve traceability of adult eel imports, by introducing DNA tests at border controls; and 

5)  further support research on eels, and in particular on the possibility to obtain reproduction 

in captivity118. 

118 See for example the research led by Prof. Oliviero Mordenti at the University of Bologna,  
http://www.scienzemedicheveterinarie.unibo.it/it/dipartimento/salviamo-languilla  

 
                                           
CASE STUDY - ITALY 

Evaluation of the Eel Regulation 
Specific Contract No. 10 
under Framework contract 
EASME/EMFF/2016/029 

Denmark Case Study 

Cover photo credit: Michael Ingemann Pedersen – DTU Aqua 

 
 
 
 
 
 
 
CASE STUDY - ITALY 

ACRONYMS/ABBREVIATIONS 

Acronyms/ 
Abbreviations 

Definition 

CFP 

CITES 

CMS 

CR 

DG MARE 

DK 

EIFAAC 

EMFF 

EMP 

EQM 

EU 

FR 

GES 

GFCM 

ICES 

IT 

IUU 

IUCN 

MS 

MSFD 

MSY 

OPC 

RBMP 

SAC 

SPA 

ToR 

WGEEL 

WFD 

Common Fisheries Policy 

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

Convention on Migratory Species 

Critically Endangered 

Directorate-General for Maritime Affairs and Fisheries 

Denmark 

European Inland Fisheries and Aquaculture Advisory Commission 

European Maritime Fisheries Fund 

Eel Management Plan  

Evaluation Questions Matrix 

European Union 

France 

Good Ecological Status 

General Fisheries Council of the Mediterranean  

International Council for the Exploration of the Sea 

Italy 

Illegal, Unreported and Unregulated 

International Union for the Conservation of Nature 

Member State 

Marine Strategy Framework Directive   

Maximum Sustainable Yield 

Open Public Consultation 

River Basin Management Plan 

Special Area of Conservation 

Special Protection Area  

Terms of Reference 

Joint EIFAAC/ICES/GFCM Working Group on Eels 

Water Framework Directive 

 
1. OVERVIEW OF THE CASE STUDY 
INTRODUCTION 

This  report  on  Denmark  is  one  of  three  case  studies  (the  others  being  France  and  Italy)  being 
investigated  by  this  evaluation.    The  case  studies  will  provide  more  detailed  insight  into  the 
implementation  of  the  Eel  Regulation  at  national,  regional  and local levels,  beyond  the  information 
gathered through the synthesis of the EMPs and their progress report, and the targeted consultation 
with the other Member States. This report intends to: 

•  Evaluate the extent to which measures under the 2009 Eel Management Plans (EMPs) have 

been able to address the main objectives of the Eel Regulation 

•  Determine whether the Eel Regulation, and the responses detailed by the EMPs remain 

relevant to the drivers and pressures relating to the recovery of the European eel stock, and 
the extent to which they can be addressed by the EU alone 

•  Assess what additional or alternative measures might be taken to achieve the objectives of 

the Eel Regulation 

•  Assess added value of the Eel Regulation and the sustainability of the measures being 

undertaken through the EMPs and their long-term impact after the interventions have eased. 

METHODOLOGY 

This  case  study  has  been  conducted  through  a  combination  of  a  review  of background  information 
(such  as  EMP  Progress  Reports,  scientific  reports  and  other  relevant  studies)  and  face  to  face  and 
telephone interviews guided by semi-structured questionnaires. The interviews were with a mixture 
of  participants,  with  representatives  of  national  and  regional  administrations  and  industry  (main 
national professional organisations and where possible a few operators).  

For a list of interviewees and document sources, see the tables below.   

Table 1: Interviews carried out in support of the case study  

Organisation / function 

Bælternes fiskeriforening (fisheries association for small scale costal fishermen)  

Technical University of Denmark, National Institute of Aquatic Resources in Lyngby (DTU Aqua)  

Technical University of Denmark, National Institute of Aquatic Resources in Silkeborg (DTU Aqua)  

Dansk amatørfiskeriforening (Danish amateur fishery association)  

Royal Danish Fish  

Ministry of Foreign Affairs of Denmark, Danish Fisheries Agency 

Danish Aquaculture Association  

 
 
 
 
 
 
Table 2: Document sources 

Document reference  

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

Danish Eel Management Plan, In accordance with Council Regulation (EC) No 1100/20017 of 18 
September 2007, December 2018. Ministry of Food, Agriculture and Fisheries.    

Danish Report to be submitted in line with Article 9 of Council Regulation (EC) No 1100/2007 of 18 
September 2007 establishing measures for the recovery of the stock of European eel (First Danish 
progress report, 2012). Fisheries Agency at the Ministry of Foreign Affairs of Denmark. 

Second Danish progress report (2015) on implementation of the Eel Regulation and Eel 
Management Plan (EMP) in Denmark, Fisheries Agency at the Ministry of Foreign Affairs of 
Denmark. 

Third Danish progress report (2018) on implementation of the eel regulation and Eel Management 
Plan (EMP) in Denmark, Fisheries Agency at the Ministry of Foreign Affairs of Denmark. 

Danish answers to Commission questionnaire on the control of eel fisheries, Sept 2017, Fisheries 
Agency at the Ministry of Foreign Affairs of Denmark.   

Memo on the “Effect of eel regulation for 2018”. Produced by Danish Technical University National 
Institute of Aquatic Resources (DTU Aqua) for the Fisheries Agency at the Ministry of Foreign 
Affairs of Denmark. 2 May 29018.   

 
 
 
 
 
2. OVERVIEW OF EEL PRODUCTION, MANAGEMENT AND 
CONSERVATION IN DENMARK  
EEL PRODUCTION AND TRADE  

Denmark is a major producer of commercially and recreationally caught eels in the EU (see table 3). 
It is also a major aquaculture producer, mainly involving indoor heated farming systems.  

Wild production 

Table  3:  The  key  river  basins/lake/fjord/sea  basin  where  eel  fishing  takes  place  in 
Denmark119 

River basin/lake/fjord/sea basin 

Annual catch 
2017 (tonnes) 

Sea basin: Belt Sea and Western Baltic (22-IIIc) 

 140.0 

Sea basin: The sound (23-IIIb) 

Sea basin: North Sea (IV) 

Sea basin: Kattegat (IIIaS) 

Lake: Arresø 

Lake: Flade sø 

Lake: Saltbæk vig 

River: Gudenå 

Total catch in 2017 

Aquaculture  

 65.9 

 12.5 

 21.0 

 5.4 

 2.9 

 2.7 

 2.1 

 256.5 

Glass eels for aquaculture are imported from France, Portugal and England. There are 5 aquaculture 
production sites for eel in Denmark that in total produced 550 tonnes in 2017. In average 880 tonnes 
have been produced in the last five years. An important reason for aquaculture is to produce eel for 
restocking purposes and eels for restocking are exported to other EU nations. The total production of 
eel in aquaculture is shown in table 4.  

Table 4: The total production of eel in aquaculture  120   

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

1,699 

1,532 

1,154 

1,129 

7,85 

789 

1,231  1,067 

550 

13,088  12,374  11,291  12,884 

9,079 

6,654  10,940  11,504 

6,733 

Volume 
tonnes 

Value in 
1000 
EUR 

Trade in eels 

Danish exports have been declining for several years, only reaching 728 tonnes in 2017, with a total 
value of 9.5 million EUR. The domestic market is limited, and many supermarket chains do not sell 
eel because it listed as an endangered species on CITES. It is not possible to separate small eel for 
restocking purposes, aquaculture eel, captured eel and eel for consumption in available statistics.  

119 Third  Danish  progress  report,  Ministry  of  Foreign  Affairs  of  Denmark,  Danish  Fisheries  Agency, 
2018 

120 Ministry of Foreign Affairs of Denmark, Danish Fisheries Agency, 2018 

 
 
 
   
 
                                           
 
 
Figure 1 shows the most important export markets and their development over the last three years. 
The Netherlands, Germany, Italy and Poland are the most important export countries.  

600

500

400

300

200

100

0

Figure 1. The eight major countries for the Danish eel export (Volume exported in tonnes) 121 

2015

2016

2017

EEL MANAGEMENT PLAN 

Key measures and approaches 

The Danish EMPs consist of two elements; one MP for inland waters and another for marine waters. 

Inland waters: Due to the small size of the country and the fact that the river ecosystems are similar 
in habitat, there was no justification for designing unique management plans for each of the 887 river 
basins, instead one plan covers the whole country.  The objective of the inland water’s MP is, in the 
long  term,  the  reduction  of  anthropogenic  mortalities  so  as  to  permit  with  high  probability  the 
escapement  to  the  sea  of  at  least  40  %  of  the  silver  eel  biomass  relative  to  the  best  estimate  of 
escapement that would have existed if no anthropogenic influences had impacted the stock.122 

Marine waters: Similar to inland water’s MP, this MP covers the entirety of the coastal line including 
the fjords and sheltered bays.  

The  objective  of  the  marine  water’s  MP  is  introducing  reductions  in  fishing  effort  by  at  least  50% 
relative to the average effort deployed from 2004 to 2006122ORMAT 122. 

Transboundary  River  Basins:  Two  river  basins  are  classified  as  transboundary.  Drainage  occurs  in 
Denmark and Germany. Instead of creating a specialised MP, both countries have agreed that both 
countries will work in collaboration on monitoring both glass eel recruitment and silver eel escapement. 

The focal point of the overall MP is to manage and reduce fishing effort and mortality in eel fisheries. 
The Danish fisheries authorities have legislative and administrative jurisdiction.  

Management measures 

In order to achieve the objectives, set out in the EMP, measures were identified, primarily focusing on 
reducing  fishing  effort  and  reducing  mortality  together  with  improving  habitat  conditions  and  a 
restocking  plan.  The  EMP  contained  two  elements  (inland  and  marine),  and  slight  difference  in 
measures were implemented.  

121 Ministry of Foreign Affairs of Denmark, Danish Fisheries Agency, 2018 
122 Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 of 18 
September 2007 

 
 
 
 
 
                                           
Inland waters – Measures implemented for inland waters are focused on increasing escapement to 
the sea of at least 40% of pristine levels by reducing anthropogenic mortalities, fishing pressure and 
improvements to the inland freshwater ecosystems including habitat restoration, river connectivity, 
predation reduction and restocking.   

Fisheries:  The  EMP  applies  management  tools  addressing  fishing  pressure  and  mortality  in  both 
recreational and commercial eel fishing by tightening legal size, gear type, fishing season, selectivity 
and catch registration regulations. See appendix A for the detailed description of measures.  

In addition, commercial freshwater fishers are subject to the following conditions: 

•  Only fishermen and entities with reported and registered eel catches of a minimum total of 600 
kg  or  30,000  DKK.  in  the  reference  period  2004-2006  and  a  minimum  of  200  kg  or  10,000 
DKK. in 2007 are eligible for commercial eel fishing licences.  

•  Licences  are  non-tradable  and  non-transferable.  Licenses  are  annulled  if  fishing  activities 

cease. 

•  The license allows only for a maximum level of fishing activity equal to the effort 

documented in 2007. Fishermen and entities are not allowed to increase the number of 
gear. 

•  Only the following gear types are allowed in fresh water eel fishing: fyke nets, pound 

nets and eel traps. 

•  With regard to the protection of the European eel and any other elements undertaken by 
the Law on Fisheries, the Directorate of Fisheries decides on the final number and type 
of gear included in each license. 

•  Type, size and position coordinates of pound nets and eel traps used must be registered 

at the Directorate of Fisheries prior to use. 

•  Effort and catch records must be reported to the Directorate of Fisheries. 
•  Further reductions may be implemented pending ongoing monitoring activities, developments 

in the European eel stock and the results of the proposed 2012 evaluation 123 

No new commercial eel fishing licences in fresh water have been issued since 2009. There were 18 
fresh water licences in 2009 and there are 10 licences in 2019. 
Obstructions to migration: Many of the inland water ways in Denmark are affected by barriers, such 
as weirs, used in connection to old mills, fish farms and hydropower. All barriers are required by law 
to be fitted with eel passes. The ability of these passes will continue to be inspected by the department 
of fisheries. A review of the effectiveness of eel passes will continue to be undertaken. 

Hydropower: As with obstructions to migration all 61 hydropower stations are routinely monitored by 
the department of fisheries ensuring the functionality of their mitigating installations such as eel and 
fish passes and will be reviewed.  

Aquaculture: As mentioned above, all flow-through fish farm systems are monitored to address the 
efficiency of the screens with respect to eel mortality and again will be reviewed. 

Predation: Continuation of monitoring programs and research on predation impact on fish stocks. 

Parasites and contaminants: Monitoring will continue of the spread of Anguillicola crassus and its effect 
on wild eel populations. There is continued testing of restocking eel for IPN, VHS and IHN viruses, and 
an attempt to generate data regarding silver eel and contaminants.  

Eel habitats: In accordance with the implemented Water Framework Directive, Denmark is improving 
the habitat for eels concentrating on premium growth areas. 

Restocking:  Under  the  EMP  certain  rivers  were  selected  for  restocking,  based  on  selective  criteria, 
including eel direct migration to the Sargasso Sea and consideration that there was no silver eel fishery 
in the surrounding waters. 

123 Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 of 18 
September 2007 

 
 
 
 
 
                                           
Marine  waters  –  In  order  to  achieve  the  objective  of  the  marine  water  component  of  the  EMP, 
measures directed to the reduction of fishing pressures were implemented. 

The table in appendix B illustrates the measures for reduction and registration of fishing effort. This 
is similar to that of inland waters concentrating on both commercial and recreational fisheries.  

Additionally,  the  introduction  of  a  licence  system  for  commercial  fisheries  will  allow  for  greater 
transparency and structure of the industry. Recreational fisheries will also need to be registered and 
adhere to the newly implemented fishing regulations.  

Progress to date 

According to the third Danish progress report (2018) on implementation of eel regulation and the eel 
management  plan  in  Denmark  the  following  describes  the  level  of  implementation  of  measures 
adopted in the initial EMP; 

Fisheries – All foreseen measures have been implemented. 

Outcomes from the EMP for the commercial fishery are; 

•  a gradual reduction in commercial eel fishing licenses from 406 to 277 
•  a substantial reduction in fishing effort for eel relative to the average effort deployed from 2004 
to 2006. The reduction in eel fishing licenses has resulted in the following reduction in fishing 
effort relative to the average effort deployed from 2004 to 2006: 

- 

- 

- 

fyke nets: 51.1% reduction 

small pound nets: 43.3% reduction 

large pound nets: 61.6% reduction 

-  hook lines: 86.9% reduction 

•  a reduction in commercial marine catches by 55% relative to the average catch in the period 

2004-2006 

•  a substantial regional reduction in commercial catches targeting eel from the Baltic Sea relative 

to the catches in the period 2004-2006  

-  100% reduction in the Eastern Baltic (ICES area 24-IIId)  

-  61.1% reduction in the Belt Sea and Western Baltic Sea (ICES area 22-IIIc) 

-  49.4% reduction in the Sound (ICES area 23-IIIb)  

-  23.4% in the Kattegat (ICES area IIIas).  

Outcomes from the EMP for the recreational fishery is; 

•  Recreational  eel  fishing  effort  in  marine  waters  was  estimated  to  be  reduced  by  50%  by 
implementing closed seasons for fyke nets and hook lines. Catches of recreational fishermen 
have been estimated at approximately 100 ton in 2009 and estimated to have been reduced 
to approximately 55 ton in 2014 but have raised to 117 ton in 2017.  

•  Recreational fishery in freshwater is estimated to have been reduced from approximately 16 
tons  to  8.3  tons  in  2017  by  implementing  a  closed  season  i.e.  a  very  limited  period  for  eel 
fishing from 1 August until 15 October. 

Escapement levels – For 2017 the best estimate for escapement was 169 tons, taking into account 
the mortalities estimated at 43.7 tonnes. This falls well short of the 40% pristine target level of 444 
tonnes. The following table illustrates the breakdown of production and losses. 

 
 
 
 
Table 5: Escapement (2017) from inland waters124 

Silver eel 
production 
(kg/ha) 

Total 
production 
(tonnes) 

Inland water 

Running water 

Lakes 

Total 

Area 
(ha) 

15,000  

45,000 

60,000 

6.8 

1.5 

Mortality (fisheries, hydropower, predation) 

Current escapement 

Target level – 40% pristine 

101.5 

67.5 

169.0 

43.7 

125.3 

444.0 

Obstructions to migration: During the period of the EMP numerous barriers have been or are currently 
being  removed.  This  has  benefitted  river  connectivity  and  the  survival  rate  of  silver  eel.  Routine 
inspections are still being undertaken where necessary. 

Hydropower  and  aquaculture:  Mortality  and  delay  of  silver  eel  caused  by  both  hydropower  and 
aquaculture  facilities  are  significant,  as  shown  by  reports.  Complete  removal  provides  the  best 
mitigating solutions. Finding alternative solutions to hydropower and flow through farming techniques 
are being and will continue to be encouraged, thus increasing the survival rate of eel. 

Predation: Culling of cormorants continue, following the national management plan for cormorants. 
No new research has been conducted evaluating the effect of cormorants on eel populations, but it 
can be surmised that the reduction in number of cormorants will only reduce the mortality rate of eel. 

Parasites and containments: Testing restocking eels for viruses and parasites has and will continue as 
well  as  the  monitoring  of  Anguillicola  crassus  in  wild  populations.  No  new  knowledge  has  become 
available.  

Eel habitats: In accordance with the WFD, Denmark continues to improve and restore waterways to 
good ecological state. Improved water ways will benefit eels.  

Restocking: Restocking effects have been fully implemented as described in the EMP. The following 
table highlights the increasing levels of restocking over the decade. 

Table 6: Restocking of eel in Danish waters125 

Number  of  restocked  eel  size  2-5 
gram 

Year  Lakes 

Rivers 

Total 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

203,900 

50,000 

253,900 

574,350 

672,000  1,246,350 

771,000 

590,000  1,361,000 

644,00 

640,000  1,284,000 

665,400 

610,000  1,275,000 

712,000 

630,000  1,342,000 

790,000 

609,000  1,399,000 

690,000 

700,000  1,390,000 

690,000 

700,000  1,390,000 

124 Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 of 18 
September 2007 
125Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 of 18 
September 2007  

 
 
 
 
 
                                           
3. KEY FINDINGS 
RELEVANCE 

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

JC1a(1):  The  extent  to  which  eel  landings,  escapement  levels  and  river  basin  conditions 
have recovered sufficiently to warrant the measures being continued. 

Eel landings 

There is consensus among all stakeholders interviewed that the target of 50%  reduction of the eel 
fishing effort has been reached and that the measure should continue until the eel stock recovers.  

The targets in the national EMP have been reached in Denmark. This includes the implementation of 
a 50% reduction on eel fishing effort in marine waters, however an additional ban on the commercial 
eel fisheries was introduced for 3 months (November, December 2018 and January 2019) by the EU. 
The  Danish  coastal  small-scale  eel  fishers  are  expected  to  further  lose  about  40%  of  the  expected 
annual turnover by the ban through 2018/2019. Many stakeholders believe that if this winter ban is 
continued unchanged it will signal the closure of the industry. A side effect of a total eel fisheries ban 
is that information about the eel stock is missing. This has been highlighted by researchers interviewed 
as a problem for the monitoring processes.   

Denmark modified the new eel fisheries ban from 1st December 2019 to 29th February 2020, allowing 
fishers to add “catch openings” to enable any eels to escape but retain other finfish species in the nets 
during the eel fisheries ban period.  Fishers now accept the eel catch ban because they can derive a 
small income from other finfish species over the ban period.  

Escapement levels 

Current escapement levels are below that of the limit set within the initial EMP, measures have been 
continuously undertaken to improve this, including barrier removal and restocking. 

There are only a few places in Denmark left where the water ways are blocked today. These include 
three hydro power plants in Denmark, and all have “eel ladders” to allow the escapement of the eel 
(and  other  fish  as  well).  Investments  to  improve  the  conditions  for  eel  are  made  every  year 
(approximately  9.5  million  EUR  is  invested  annually).  Many  aquaculture  plants  are  converted  into 
recirculation aquaculture plants and do not use water from the water ways anymore. 

Several stakeholders said, to improve escapement levels, further regulation is required to protect the 
eel  from  predation.  They  believe  the  current  measures  are  insufficient  to  protect  the  eel  from 
predation. 

All stakeholders highlighted the fact the restocking of eels in marine water is not supported by the EU, 
although there is evidence from research to support this measure. Such measures could improve the 
escapement of eel into the Sargasso Sea because eel released in saltwater grow faster and reproduce 
faster  according  to  the  researchers  interviewed.  Releasing  of  eel  has  been  supported  by  EU  in 
freshwater areas only. There are huge areas with brackish water in Denmark ideal for releasing eel 
(that is saltwater according to the EU definition). 

One stakeholder identified the practice of draining low level waters within the EU. It was stated that 
the methods used are low tech and provide zero protecting for eels when they reach pumps without 
a grid and “eel ladders” to release the eel to the sea.  

The conclusion is that the EMP measures continue to be relevant.   

 
 
 
 
JC1b(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.   

Denmark  has  achieved  all  the  measures  set  out  in  the  national  eel  management  plan.  Further 
limitations on the catch in Denmark will not have a huge effect on saving the eel stock. Measures on 
other  non-fisheries  issues  will  have  much  larger  effect  from  now  on  according  to  all  stakeholders 
interviewed. 

There  is  a  consensus  among  all  stakeholders  interviewed  that  the  EMP  measures  remain  relevant 
following the CFP reform. 

The implementation of the WFD in order to improve the river basin management of Denmark, includes 
river habitat and connectivity improvements required for the eels.  

The majority of the interviewed stakeholders think the Danish eel fisheries have been reduced enough 
and any additional reduction in fishing pressure will have an insignificant effect the status of the eel 
population.  

New  measures  following  a  CFP  reform  could  introduce  greater  focus  on  other  non-fisheries  related 
measures (water quality, predators, migration connectivity). In addition, they believe there is a lack 
of knowledge about what works. Research should be intensified to understand the reasons behind the 
poor conditions for the  eel stock.  New regulation should regulate cormorants and  seals to a higher 
degree than it is done today.  

A  CFP  reform  should  support  restocking  activities  of  eel  in  saltwater  areas  too.  Today  it  is  only 
supported  in  freshwater  areas  probably  because  of  lack  of  knowledge  when  the  EMP  was  prepared 
back in 2004 and the focus was on freshwater areas only. Later in the process 2004-2007 saltwater 
areas were included before the EMP was approved in 2007- but without any support for restocking in 
salt water areas. There is evidence that restocked eels grow much faster and reproduce faster when 
restocked to saltwater areas according to the researchers interviewed.  

IUU fishery and export of glass eel is a very important issue according to all stakeholders. The control 
and prevention of illegal catch and export must be intensified further in a CFP reform. 

Research to be able to understand the eel reproduction should be intensified according to the majority 
of stakeholders interviewed. Research to enable a full reproduction circle for eel in aquaculture should 
be supported heavily. Restocking activities could be intensified as well from captured glass eel until 
aquaculture can manage the full reproduction circle. 

EFFECTIVENESS 

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

JC2 (1): EMPs implemented and specific targets achieved. 

The measures foreseen in the Danish Eel Management Plan have all been implemented and objectives 
met as stated in the section “2.2.2 Progress to date”. The regulation and restrictions for commercial 
eel  fishing  activities  were  implemented  as  of  1  July  2009.  The  regulation  and  restrictions  for 
recreational  eel  fishing  activities  were  implemented  as  of  1  February  2009 126.  Denmark  has  not 
encountered major difficulties in the implementation of the Danish EMP. Since the implementation of 
the Danish EMP, Danish fisheries authorities and the National Institute of Aquatic Resources have had 
a close cooperation with all segments of eel fishing. 

JC2 (2): European eel stock has recovered. 

There is a general agreement among the Danish stakeholders that the measures to recover the eel 
stock have been implemented in Denmark as planned. However, it is believed that it will take a long 
time until the effect of  the implemented measures  can positively impact the  European eel stock to 

126 Third Danish progress report (2018) on implementation of the eel regulation and Eel Management 
Plan (EMP) in Denmark, Fisheries Agency at the Ministry of Foreign Affairs of Denmark. 

 
 
                                           
recover. Up to 20 years according to the researchers interviewed. The greatest concern is if other EU 
nations are not fully implementing their measures and contributing to the recovery of the eel stock. 
Many stakeholders also express deep concern about the illegal catch and export of glass eel to Asia 
and the effect it has on the eel stock. The eel management plan functions well in Denmark according 
to all the stakeholders interviewed, with the commercial fishery strictly controlled and very few new 
fishermen coming into the eel fishery.   

JC2 (3): Anthropogenic mortalities have been reduced. 

Reduction  of  the  anthropogenic  mortalities  are  among  the  long-term  measures  in  the  Danish  eel 
management plan and they follow the plan. Investments to remove barriers and help the passage of 
eels  are  implemented  every  year  (about  9.5  million  EUR  is  invested  annually.  A  high  number  of 
obstacles  are  currently  being  removed,  in  line  with  the  EU  Water  Frame  Directive  Denmark  aims, 
during the years 2012-2023. This includes two major hydropower stations (Harte and Karlsgårde) and 
close  to  100  smaller  dams  and  weirs,  many  of  which  were  fish  farm  dams.  These  measures  have 
improved both up- and downstream eel passage and reduced silver eel mortality substantially in the 
restored rivers. Routine control of eel passes and their functionality at remaining obstructions in rivers 
has continued. 

The mortality and delay (silver eels) caused by hydropower facilities are significant and can best be 
mitigated by complete  removal of the facility or by letting a significant proportion of the water run 
through a bypass  channel. The Danish stations are  old and produce insignificant amount of  power. 
Currently, only 3 larger facilities remain. 

The mortality and delay (of silver eels) caused by traditional fish farms are again significant and can 
best be mitigated by complete removal of the facility or by letting a significant proportion of the water 
run through a bypass channel. Recently, many Danish fish farms are being converted into fully recycled 
facilities,  which  do  not  require  weirs  to  divert  water  through.  Thus,  numerous  weirs  have  been 
removed  and  the  river  connectivity  restored.  This  process  is  encouraged  by  the  authorities  and  is 
expected  to  continue.  A  removal  of  fish  farm  barriers  will  clearly  benefit  migrating  eels.  All 
stakeholders interviewed agree that removal of obstacles and helping the passage of eels has a great 
potential to recover the eel stock. 

The anthropogenic mortality was 43.7 tonnes in 2017 compared to 36 tonnes in 2014 and has not 
been  reduced  at  this  point.  Despite  no  major  difference  was  observed  in  the  overall  production  of 
silver eels since the Danish progress report from 2015, the models of the National Institute of Aquatic 
Resources (Pedersen and Rasmussen 2013) suggest that escapement of silver eels will decrease until 
years ~2030, from where it will start increasing again. A detailed specification of the anthropogenic 
mortalities is already given in section “2.2.2 Progress to date”. 

JC2  (4):  Adult  eel  escapement  progressed  towards  the  long  term  40%  escapement 
objective. 

The escapement in 2017 was 125.3 tonnes per year in Denmark. The long-term target level is 444 
tonnes.  The  production  in  running  water  and  lakes  is  169  tonnes  per  year  and  the  mortality  43.7 
tonnes per year (fishery mortality included). Total estimated fishery mortality is 24.7 tonnes. 

Despite  all  the  implementation  of  measures  under  the  EMP  and  the  goals  set  out  in  the  WFD, 
escapement is yet to reach the 40% objective. Stakeholders discussed additional activities that could 
be done to increase adult eel escapement – eel ladders could be inspected more often; the last three 
hydro power plants could have stronger demands for eel ladders and minimum water supply for the 
eel ladders also in dry periods. Cormorants and seals can be regulated harder that they are currently. 

JC2 (5): Supply of glass eels sufficient for restocking operations. 

Restocking has been fully implemented as described within the Danish EMP and the supply is sufficient 
for restocking operations. The amount of restocked eel in freshwater has increased from year 2010. 
In the Danish EMP the number of eels to be restocked was proposed at 0.8 million eels. The actual 
number  of  restocked  eels  has  increased  to  1.2-1.4  million  eels  during  the  years  2010  –  2017. 
1,390,000 eels weighing 2-5 gram each were restocked in 2017. As there is no glass eel fishery in 
Denmark, eels are to be purchased from sources in the EU. The fees from permits to participate in 

 
 
recreational fisheries are the funds used for the purchasing of glass eel for restocking. According to 
the interviewed researchers from the National Institute of Aquatic Resources farmed eel for restocking 
survive  and  grow  better  than  the  wild  and  there  seems  to  be  no  advantage  in  using  a  larger  eel 
compared with small 2-5 g eels for restocking. 

JC2 (6): Fishing effort reduced by at least 50% relative to the average effort 2004-2006 or 
ensure reduction of catches by at least 50%. 

Commercial marine catches have been reduced by 55 % relative to the average catch in the period 
2004-2006 according to the management plan. There is full control of the commercial fishery and the 
plan  is  updated  every  year.  One  stakeholder  mentioned  that  there  is  limited  regulation  of  certain 
sports fishermen (“fritidsfiskere”). They are allowed to fish with 6 eel fyke nets yet are not required 
to record their catches to authorities. These sports fishermen are not allowed to sell their catch – the 
catch is only for personal use. It is hard to control recreational fisheries activities and new ways to 
control them could be invented. The recreative fisheries organisations are very active to establish new 
habitats for eel, making “eel ladders” and removing obstacles  on a  voluntary basis. The restocking 
activities are carried out voluntary in Denmark by recreational fisheries organisations today. 

JC2  (7):  Origin  and  traceability  of  all  live  eels  imported  and  exported  from  MS  territory 
maintained.  

Eel  farmers  cannot  receive  any  glass  eel  at  the  eel  farm  without  a  “Intrastat”  transport  document 
accompanying the glass eel that certifies that the glass eel are CITES approved. When an eel farm 
export  eel for  restocking, they fill-in a “TRACES” (European Commission TRAde Control and Expert 
System)  document  online.  The  documents  are  controlled  by  Danish  Veterinary  and  Food 
Administration  (the  Export  Control  Centre).  There  is  no  demand  of  unique  lot  number  to  identify 
batches of live eel in Denmark. There is no catch of live glass eel in Denmark.  

JC2 (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. 

Aquaculture plants farming imported glass eel for consumption or restocking: 

Eel  farmers  cannot  receive  any  glass  eel  at  the  eel  farm  without  a  “Intrastat”  transport  document 
accompanying the glass eel that certifies that the glass eel are CITES approved. 

Glass eel from France are designated for two different purposes (consumption or restocking). 

Glass eel from UK or Spain has no specific purpose of use. 

They try the best to keep batches apart in the process, but it is impossible in practice because they 
have limited number of tanks and they can have problems with eel sickness as well. Eels needs to be 
size graded often to reduce cannibalism and to increase growth. Farmers have a huge interest to keep 
batches  apart  to  be  able  to  identify  good  or  bad  suppliers  of  glass  eel.  They  do  their  best  to  keep 
batches apart. 

When  they  export  eel  for  restocking,  they  fill-in  a  “TRACES”  (European  Commission  TRAde  Control 
and Expert System) document online. The documents are controlled by Danish Veterinary and Food 
Administration  (the  Export  Control  Centre).  Different  eel  sizes  are  used  for  restocking  in  different 
countries.  

There is no demand for a unique “lot number” on eel batches that can be traced back to the glass eel 
“lot number” (for traceability).  

The eel farmers have to fill-in two annual reports to the authorities. 

One report is for the Danish Environmental Protection Agency stating: 

1)  The number of eels that has been sold for restocking 

2)  Their average weight 

3)  The total volume 

 
 
The second report is for the Danish Fisheries Agency stating:  

1)  The number of glass ell supplied the farm 

2)  The total volume glass eel supplied 

3)  The number, volume and price of the eel sold either for restocking or consumption.  

4)  A current status of the eel at the farm (number and volume)   

Captured eel: 

The Danish fisheries authorities have implemented a control and catch monitoring system to monitor 
Danish fisheries, including the regulation implemented according to the Danish Eel Management Plan 
(EMP). Thus, the developments in fishing effort, effort reduction, and the developments in eel catches 
and reduction in eel catches have been closely monitored. Since 2007 the Danish fisheries authorities 
have applied a risk based strategic control and monitoring of both commercial and recreational fishing 
activities, in order to target and optimize the utilization of the authority resources based on a dynamic 
assessment of the risks in each type of fishery. The risk-based control and monitoring strategy has 
mainly focused on "hot spot" (high priority) areas, periods and species and supported by a biological 
assessment from the  National Institute of Aquatic Resources.  The Danish fisheries authorities have 
furthermore established an electronic reporting system that helps to collect and distribute information 
about observed irregularities. Since implementation of the Danish EMP in 2009, this risk-based control 
and monitoring strategy has targeted control and monitoring of the restrictions implemented in Danish 
legislation for all types of eel fishing in both marine and freshwater in line with the Danish EMP – i.e. 
closed seasons, number and type of gears allowed, eel passes, and increased minimum legal size for 
yellow eel. 

Glass eel monitoring takes place at a few selected sites in the Danish waters. There is no yellow eel 
monitoring established. As stated in the Danish EMP, silver eel escapement is monitored in 3 out of 
887 river systems. The results from these river systems are converted into production per area (kg/ha) 
values and then up-scaled to national level. Concerning the stocking measure and expected outcome, 
Denmark initiated a program to monitor the effect by stocking tagged eels in selected areas127. 

The Danish fishery agency is responsible for enforcing the control and the inspection of eel fishermen. 
Companies exporting eel are inspected by the Danish Veterinary and Food Administration (under the 
Ministry of Environment and Food).  

Eel fishers in DK are small scale and they have only vessels with a length under 12m - many under 
8m. These vessels have a few exceptions compared to larger vessel above 12 m. 

Vessels under 8m must register the catches within 48 hours after catch if they catch under 100kg. 

If they have catches above 100kg they must inform the authorities 2 hours before landing. They can 
register  the  catches  online  at  the  Danish  Fisheries  Agency.  Information  is  recorded  on  vessel 
name/number, catch date, catch area and species and volumes. 

Vessels from 8-12m use traditional paper logbooks for registration of the catch. 

Vessels  above  12m  are  in  saltwater  and  is  not  designated  for  eel  fishery.  The  Danish  electronic 
reporting system (common database system) is called “SIF” (The Danish fisheries traceability system). 
The electronic logbook on the fishing vessels sends the data directly to the SIF database. SIF fulfils 
the  requirements  of  the  fishing  industry,  EU1224/2009  and  other  relevant  standards.  The  system 
provides full tracking from vessel and all the way to the consumers, providing relevant information as 
required by the EU1224 – art 58. It enables tracing of any fish product back to the point of catch and 
provides  relevant  information  to  buyers,  processing  companies,  authorities  and  consumers.  SIF 
renders  necessary  documentation,  spans  over  the  complete  supply  chain  and  allows  an  indefinite 
number  of  transformation  operations,  such  as;  merging  or  splitting  of  lots,  processing,  renaming, 
repacking, etc. SIF is designed to accommodate any input, whether RFID, bar- code or manual and 
any  ID  whether  company  specific  ID’s  or  proprietary  ID’s  such  as  EAN  or  EPC/GS1  (EPCIS).  Data 

127 Third Danish progress report (2018) on implementation of the eel regulation and Eel Management 
Plan (EMP) in Denmark, Fisheries Agency at the Ministry of Foreign Affairs of Denmark. 

 
 
                                           
interfaces  are  established  in  order  to  reduce  the  workload  of  resellers  and  processing  companies 
enabling them to automatically exchange updated tracking information with SIF. A major emphasis 
has been on ensuring compliance with international standards on traceability for fish, such as: ISO 
12875  “Traceability  of  Finfish  products”  and  European  legislation  (EU1224).  SIF  is  prepared  to 
document discard and register compliance to MSC or other eco-labels. 

EQ 3.  If the measures for the recovery of European eel stock under the Eel Regulation have 
only partially met the objectives in EQ 1, what factors have hindered their achievement and 
how? 

JC3 (1): Identification of the key barriers to achieving the objectives. 

As stated under JC2(3) the anthropogenic mortality was 43.7 tonnes in 2017 compared to 36 tonnes 
in 2014 and has not been reduced at this point. River restoration will continue to improve under the 
WFD  and  approximate  9.5  EUR  is  invested  annually  to  improve  the  conditions  for  eel  every  year 
(removal of barriers in water ways, eel ladders, restoration of eel habitats etc.). Investment could be 
increased to improve the conditions faster.  

Stakeholders highlighted the fact the restocking of eels in marine water is not supported by the EU, 
although there is evidence to support this measure. Such measures could improve the escapement of 
eel into the Sargasso Sea because eel released in saltwater grow faster and reproduce faster according 
to the researchers interviewed. Releasing of eel has been supported by EU in freshwater areas only. 
There  are  huge  areas  with  brackish  water  in  Denmark  ideal  for  releasing  eel  (that  is  saltwater 
according to the EU definition).  

Danish stakeholders acknowledged that IUU fishing is a key issue and the proceeding illegal trade of 
glass eel greater effects the chances of increases in the eel population. Although not a direct measure 
from  the  Danish  EMP,  the  CFP  aims  to  improve  control  and  reduce  this  problem.  Additional 
recommendations from stakeholders focus on international cooperation between Europe and Northern 
Africa on the illegal eel trade.  

JC3  (2):  Identification  of  the  common  and  outstanding  successes  and  resulting  best 
practises that have allowed progress towards achieving the objectives. 

The 50% reduction of the fishing effort catches has been achieved. 

A  best  practise  example  is  that  the  fee  from  recreational  fisheries  permits  are  used  to  restocking 
activities. The practical restocking of eel is done voluntary by recreational fisheries organisations. The 
fees are doubled by the EU support and all funds are used to buy eels from aquaculture for restocking.  

JC3 (3): Identification of best practices in transboundary areas. 

There is no information available on best practice in the Danish and German transboundary area Vidå 
and Kruså river basins draining ground.  

JC3  (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. 

This has been addressed under JC2 (8) 

JC3 (5): Have the control & enforcement measures at MS levels been adequately resourced 
and implemented? 

This has been addressed under JC2 (8) 

 
 
 
 
SUSTAINABILITY 

EQ 5.  Are the effects likely to last after the intervention ends? 

JC5 (1): The extent to which measures implemented under the Eel Regulation have long-
term impacts, even if the intervention were to cease. 

With the majority of the measures already implemented from the EMP, Denmark should benefit in the 
long-term.  In  particular,  fishing  pressure  has  been  reduced  lower  than  originally  planned  and  may 
continue  to  decrease  as  a  result  socio-economic  demographics  of  the  fishery.  Positively,  certain 
measures undertaken will not stop in Denmark including the improvement of waters under the WFD 
and the yearly restocking of waterways with eels.  

The average age of fishers in the eel fishery is 68 years and there are only 240-250 fishing permits 
left.  The  remaining  eel  fisheries  are  in  rural  areas,  it  is  coastal  small-scale,  gentle  fishing  and  it is 
cultural. Further reduction of fisheries will have very limited effect on the eel stock. 

EQ 6. 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? 

JC6  (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. 

The following is the breakdown of costs associated with the EMP; 

•  The administrative costs at central level for the eel management is estimated 0.6 FTE. 
•  The administrative costs at regional level for the eel management is estimated 0.3 FTE. 
•  The control and enforcement of the regulation is estimated 2 FTE. 
• 

(There have not been any specific IT costs by implementing this regulation and the measures.)    

Overall, the costs of administering, implementing and overseeing the EMP actions are relatively small 
in  Denmark.  There  has  been  no  calculation  on  the  environmental  and  socio-economic  benefits 
associated with the implementation of the EMP.  

EQ7.   Could the use of other policy instruments or mechanisms have provided better cost-
effectiveness? Do you think there are better and more cost-effective methods that can be 
implemented instead of the existing?   

JC7 (1): The extent to which alternative options exist and an assessment of their relative 
cost-effectiveness and contribution to the objectives of the Regulation.   

The most cost-effective measures in Denmark according to many stakeholders as listed below are in 
line with the measures implemented by the EMP. 

• 
Increased restocking activities  
•  Remove barriers in water ways 
• 
•  Reduce predators (cormorants and seals) 
•  Restore eel habitats  

Install eel ladders  

• 

Increased  knowledge  about  the  eel  life  cycle  and  eel  reproduction  in  captivity  by  massive 
investments in research projects. 

Continuation of river restoration under the WFD will benefit the EMP. Contribution from the WFD will 
enhance the effectiveness of the EMP. 

 
 
 
 
COHERENCE 

EQ 9.  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)? 

JC9  (1): The extent to which  wider fisheries  and environmental policies  remain coherent 
with the objectives and measures under the Eel Regulation.  

The EMP is coherent with the WFD and the CFP. 

Stakeholders express that the eel stock is one European stock and therefore the solution is European. 
This ties with the WFD and the CFP, a framework encompassing the entire EU.    

EU ADDED VALUE 

What is the additional value resulting from the EU measures for the recovery 
EQ 11.  
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?  

JC11  (1):  Extent  that  the  Eel  Regulation  has  provided  additional  impetus  /  support  to 
address eel conservation objectives.   

All  stakeholders  interviewed  has  expressed  their  support  to  the  EMP  and  its  positive  effect  on  the 
recovery of the eel stock. Restoration of water ways and establishment of eel ladders have positive 
effects for many other fish species than eel.   

JC11 (2): Extent that it is possible to isolate results and outcomes that could or would not 
have been otherwise achieved without the Eel Regulation. 

The Regulation has assured a coordinated approach all over the EU which probably never would have 
happened without. 

EQ12.  
measures as regulated in the Eel Regulation?  

What would be the most likely consequences of stopping the application of the 

JC12 (1): Extent that MS authority is able to identify positive and negative implications of 
stopping the Regulation. 

There  has  been  no  expression  of  interests  to  stop    the  Regulation.  There  is  strong  support  to  the 
Regulation.  Recovering  the  eel  stock  is  seen  as  a  pan  European  task  because  the  eel  stock  is  pan 
European. There would be a risk restocking measures could be stopped or slowed down in case the 
EU co-funding ceased.  

 
 
 
 
 
 
4.  CONCLUSIONS AND RECOMMENDATIONS 

The eel management plan has been implemented as planned in Denmark and there is a consensus 
between all stakeholders that the management plan is working well and as intended. The foreseen 
measures  have  been  implemented  as  described  within  the  adopted  Danish  EMP.    However,  it  is 
believed that it will take a long time until the effect of the implemented measures can positively impact 
the European eel stock to recover. Up to 20 years according to the researchers interviewed. 

The long-term target for escapement levels, 444 tonnes, has not been reached at this point. For 2017 
the  best  estimate  for  escapement  was  169  tons.  Measures  have  been  continuously  undertaken  to 
improve this, including barrier removal and restocking - it follows the EMP. 

Danish  stakeholders  consider  the  reduced  fishing  effort  is  implemented  as  planned  and  a  further 
reduction in fishing pressure will have limited effect on recovering the eel biomass. 

Other measures and initiatives should be strengthened as suggested by stakeholders: 

1)  The  glass  eel  fisheries  should  be  strongly  reduced  across  the  EU.  It  should  be  regulated 

stronger and limited to aquaculture purposes and restocking activities only.  

2)  Cooperation between southern Europe and North Africa could fight the trafficking of glass eels 

towards Asia.     

3)  Research in understanding the eel and its lifecycle. 

4)  Research in reproduction of eel in captivity should be heavily supported by the EU  

5)  Research of the effect of restocking and effectiveness of eel ladders.    

6)  The reduction of other anthropogenic mortalities  

a.  Further reduction in barriers in the waterways, protecting eel from inflow pipes towards 
powerplant  and  inlet  to  aquaculture  plants,  protecting  large  eel  from  water  pumps 
draining low level areas.  

b.  Establishment/documentation of eel ladders best practice and regular control to ensure 
correct operation, assuring minimum water flow for eel ladders to work properly - also 
in dry periods. 

c.  Intensify restocking activities. EU support to restocking activities in saltwater areas too.    

7)  The predators of eel could be regulated to a higher degree (cormorants and seals). 

 
 
 
 
 
 
 
Appendix A: Measures in Inland fisheries 

Source: Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 
of 18 September 2007 

Factor 

DK eel regulations prior to     

1st July 2009 

Eel fisheries regulation in accordance with 
Danish Eel Management Plan (from 
01/07/09) 

Legal size 

•  45 cm minimum legal size 

•  45 cm minimum legal size for yellow eel 

for yellow eel. 

Gear 

•  Fyke nets, eel traps, 

pound nets, seine nets, 
long lines, eel pots and 
varieties of spears and 
rods allowed. 

•  No limits on the number 

of gear. 

•  Minimum 100 m distance 
between fyke- or pound 
nets. 

•  Only eel traps are 
registered with the 
Directorate of Fisheries. 

•  Only fyke nets, pound nets, eel traps, long 
lines and fishing rods are allowed for eel 
fishing. 

•  Eel traps must be made unable to catch eel 

by 31st December 2013. 

•  For licensed commercial fishing activities 
the number and type of gear must be at 
2007 level or lower. 

•  Minimum 100 m distance between fyke- or 

pound nets. 

•  Type, size and position coordinates of all 
pile fixed fyke nets, pound nets and eel 
traps must be registered with the 
Directorate of Fisheries prior to use. 

Fishing 
season 

•  No time limits on fishing 

•  In lakes, only licensed commercial 

activities in lakes 
•  Eel traps allowed in 

operation through- out 
the year from sunset to 
sunrise, except for the 
period 1st March to 31st 
May. 

fishermen are allowed to use a limited 
number of fyke and pounds nets designed 
to catch eel in the period between October 
16th and July 31st. 

•  Eel traps allowed in operation only from 

sunset to sunrise, in the period August 1st 
until October 15th. 

•  Fyke nets in streams 

•  All fishing activities with fixed nets in 

allowed from 1st June – 
30th November. 

streams are restricted to the period Au- 
gust 1st until October 15th. 

•  All eel caught for recreational purposes in 
fixed gear, between October 16th and July 
31st, must immediately be returned to the 
wild. 

•  Depending on stock developments all eel 
fishing activities may be phased out by 
31st December 2013. 

Selectivity 

•  Minimum 32 mm (full 

•  Minimum 32 mm mesh size (14x14 cm) 

mesh) mesh size (10x10 
cm) window in rear fyke 
bag. 

window in rear fyke bag. 

•  All fyke nets and pound nets used in lakes, 
by non licensed fishermen, outside the 
period allowed for eel fishing must be fitted 
with a mesh window, hindering the catch 
of eel. 

•  Gear must be presented for, registered 
with and approved by the Directorate of 
Fisheries. 

 
 
Factor 

Catch 
registration 

DK eel regulations prior to     

1st July 2009 

Eel fisheries regulation in accordance with 
Danish Eel Management Plan (from 
01/07/09) 

•  All commercial catches 

•  All commercial catches and effort in- 

must be reported to the 
Directorate of Fisheries. 

formation must be reported frequently to 
the Directorate of Fisheries, according to 
specifications in license. 

•  Historic catch data and effort must be 

reported to the Directorate of Fisheries in 
license application. 

 
 
 
 
Appendix B: Measures in marine fisheries 

Source: Danish Eel Management Plan In accordance with COUNCIL REGULATION (EC) No 1100/2007 
of 18 September 2007 

Factor 

Legal size 

Fishing 
season 

DK eel regulations prior to     

1st July 2009 

Eel fisheries regulation in accordance with 
Danish Eel Management Plan (from 01/07/09) 

•  Minimum legal size for 
yellow eel ranges from 
29.5 cm to 38 cm. 

•  Minimum legal size for yellow eel will be step 
wise increased (In year 2013 the legal size 
ranges from 38 cm to 40 cm.) 

•  No season. 

•  Only licensed commercial fishermen are 

Selectivity 

•  No selectivity 

Gear 

Effort 
registration 

•  No limits on number and 
type of gear/units for 
commercial fishermen. 
•  Fyke nets, pound nets, 
seine nets, trawl, long 
lines, eel pots, a variety of 
spears and light 
enhancers allowed. 
•  Position coordinates of 

pound nets and other gear 
fixed on piles must be 
registered with the 
Directorate of Fisheries 
prior to use. 

•  Recreational fishermen 
are allowed to use a 
maximum of 6 fishing 
units: 6 long lines (600 
hooks), 6 fyke nets (8 m 
leader) or 3 nets (max. 45 
m). One fyke net can be 
fixed on piles and have a 
40 m leader. 

•  All commercial catches 

must be reported to the 
Directorate of Fisheries. 

allowed to use long lines, fyke nets and pounds 
nets designed to catch eel in the period from 
May 10th until July 31st. 

•  Long lines will be banned from May 1st until 
September 30th for recreational fishermen. 

•  All fyke nets and pound nets used for non 

licensed fishing activities, targeting species 
other than eel must be fit- ted with mesh 
windows or square openings throughout the 
fyke, hindering the catch of eel. 

•  The use of trawl, seine nets, eel pots, spear, 
torchlight and all other gear not explicitly 
described as legal, will be banned. 

•  Long lines will be banned from 1st May until 
30th September for recreational fishermen. 
•  Only fyke nets, pound nets, long lines 5 and 

fishing rods are allowed for eel fishing. 
•  Number of gear for all licensed commercial 
fishing activities must  be equal to the level 
documented in 2007 or lower. 

•  Type, size and position coordinates of all pile 

fixed fyke nets and pound nets must be 
registered with the Directorate of Fisheries 
prior to use. 

•  Recreational fishermen will be allowed to use 
only 6 fyke nets or 3 nets during the fishing 
season. (The pile fixed fyke net will be banned) 

•   All commercial catches and effort information 
must be frequently reported to the Directorate 
of Fisheries, according to specifications in 
license conditions. 

•  Catch data and effort information (2004- 2007) 

must be reported to the Directorate of 
Fisheries in license application. 

 
 
 
 
 
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ISBN:978-92-76-17265-9 
doi: 10.2771/679816