Self sacrifice or Self Destruction? The EU is still overfishing

Light painting projection by marine conservation campaign group Our Fish reading “Hey EU! Stop the Overfishing” outside the Brussels Seafood Expo, which opens on April 25.

According to a recent  EU report monitoring the performance of the Common Fisheries Policy, Europe’s precious fish stocks are still being destroyed for a quick profit, while European citizens are being fed a raw deal by both the big end of the fishing industry and national governments. [1]

The EU’s Scientific, Technical and Economic Committee for Fisheries has  reported that around 6 out of 10 fisheries in the North East Atlantic managed by European nations are still considered unsustainable and do not meet the Common Fisheries Policy (CFP). The CFP is the law that defines EU fisheries management and aims to make the fisheries sector environmentally, socially and economically sustainable.

According to the report, the situation in the  Mediterranean Sea – an icon for Europe’s love of the sea and seafood – is actually getting worse, with the highest levels of fishing pressure in the last ten years recorded in 2011 and 2014. Industrial trawlers from Italy, Spain and France  have the biggest impact on fish stocks and ecosystems along the seabed, to the detriment of those who love and rely on mare nostrum, including tens of thousands of low-impact small scale fishers. [2]

The industrial fishing lobby claims that the recent improvement in fish stocks is due to “decades of self sacrifice”, whilst ignoring the fact that they have opposed the decreases in fishing effort needed to deliver these improvements almost every chance they’ve had.  

In the last ten years, Europe’s fisheries improved from 90% of fishing being unsustainable to 60% unsustainable [1]. If this so-called “return to greatness” that the industrial fishing lobby has claimed as their own, was  a school report card it would be a C not an A.

STECF  reports that at the current rate of improvement we will not meet the CFP timetable of sustainable fish stocks and fishing levels by 2020.  So, despite what the industrial fishing lobby says and thanks to their lobby efforts to set fishing limits above sustainable levels, everything is not peaches. This is a warning signal that we need stronger action from European countries if we are to secure healthy fish stocks, good seafood, and a sustainable fishing industry.

Europe is the largest trader of seafood and fisheries products in the world [3] . The Global Seafood Expo is attracting thousands of seafood traders to Brussels this week, but the question remains – why are European nations still plundering our fish at a rate we cannot afford to maintain, and to whose gain?

Rebecca Hubbard is Campaign Manager for Our Fish



[1] Scientific, Technical and Economic Committee for Fisheries (STECF) – Monitoring the performance of the Common Fisheries Policy (STECF-17-04). 2017.

[2] Scientific, Technical and Economic Committee for Fisheries (STECF) – Western Mediterranean Multi-annual Plan STECF-15-09. 2015.

[3] EUMOFA, 2016, The EU Fish Market 2016 Edition

EU Eel Evaluation Roadmap: NGO submission

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

“We strongly support the upcoming evaluation and welcome this opportunity to provide feedback on the effectiveness and implementation of the EU Eel Regulation.”

The population of European eel has declined dramatically since the 1970s*. Recruitment of juvenile eels remains extremely low despite the joint EU management framework, which has now been in place for 10 years. The state of European eel remains critical and further action is urgently needed.

Earlier evaluations indicate that the current EU management framework is insufficient and show that implementation of the regulation and of the national eel management plans has been delayed, piecemeal and focused on efforts with little discernible impact on the recovery of the European eel population. Notably, it has been very difficult to measure progress against the main target – at least 40% escapement of silver eels. While a strong focus of resources has been placed on restocking of eel, there is no evidence that this effectively contributes to future recruitment. Most countries maintain a directed fishery, and illegal catches and trafficking of glass eels remain a major problem.

Habitat loss and deteriorating water quality also affect eel. The latest assessment of the implementation of the Water Framework Directive shows poor status for around 60% of surface water bodies and a massive presence of migration barriers**.

Since the Eel Regulation came into force, some major changes in related EU policies have taken place. Notably, the reform of the Common Fisheries Policy resulted in the new 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 criterion to assess Good Environmental Status under the Marine Strategy Framework Directive. We are therefore particularly pleased to see the evaluation’s focus on coherence with other EU legislation, as well as with international instruments.

We ask the European Commission to ensure that this evaluation of the effectiveness and coherence of the measures taken to aid the recovery of European eel assesses all aspects of eel management and potential options for the future, including:

  • The objective of 40% escapement of silver eels and whether it is in coherence with the precautionary principle and the MSY objective
  • The effectiveness of fisheries closures/restrictions for all life stages
  • The targets and indicators set in the national eel management plans, as well as the national monitoring to measure progress
  • Reporting and data collection obligations
  • Restocking practices and the associated overall effectiveness in terms of conservation
  • Progress on measures to address other major anthropogenic impacts on eel, primarily habitat restoration and removal of migration barriers
  • The use of public funds (EMFF) and whether it has aided eel recovery
  • The substantial illegal trade of European eel outside of and inside the EU and its effect on eel conservation
  • Control and enforcement issues related to the entire chain, from glass eel fisheries to consumption of eel products, including more coordinated action between the Member States’ enforcement agencies
  • The implementation of EU commitments within the framework of CMS and CITES

Bearing all of the above in mind, we look forward to a thorough evaluation of all aspects of the European eel management framework, and to future opportunities to engage with this process.

It is our hope that through implementation of urgent measures and better management and protection in the future, we can enable long-term recovery and sustainable exploitation of European eel, but we note that we are a very long way from there today. 

Submitted by: ClientEarth, European Anglers Alliance, FishSec, Good Fish Foundation, Our Fish, Pew Charitable Trusts, Seas At Risk and WWF

Download as PDF: Eel Evaluation Roadmap NGO submission




Background: EU begins evaluation of eel management

On 13 April 2018, the European Commission released a Roadmap for the upcoming evaluation of the Eel Regulation. The evaluation is set to help the Commission decide whether to review the regulation or focus on improving implementation. Stakeholders are invited to provide feedback on issues related to the implementation of the Eel Regulation until 11 May 2018, and then in a second consultation in October.

The so called Evaluation and Fitness Check Roadmap of Council Regulation (EC) No 1100/2007 of 18 September 2007 establishing measures for the recovery of the stock of European eel provides background on the issue and explains the process and focus for the evaluation. The intention is to inform stakeholders and enable them to participate effectively in the process as well as provide views and possible solutions for better eel management. It is the first step of a process that may take several years.

The evaluation process started in Spring 2018, with a final report expected in the first quarter of 2019. It consists of three parts: an external evaluation of the management framework, an ICES assessment of the biological aspects and a Commission review of the use of public funds to support implementation. The first public feedback period (open 13 April to 11 May) is intended to inform the initial phase of the evaluation, whereas the second public consultation in October will give stakeholders a chance to reflect on some of the initial results and provide views on potential measures.

First evaluation found significant delays

This will be the second EU evaluation since the Eel Regulation came into force in September 2007. The previous evaluation took place after the first national progress reports were submitted in 2012 and a report was presented to the Council and European Parliament in 2014 (in line with requirements in the regulation (Art. 9.2)).

The first evaluation found that the status of the European eel remained critical and in need of urgent action and that the implementation of the Eel Regulation had suffered significant delays. It also found that most of the management measures taken were related to fisheries, whereas other measures such as improving habitats or controlling predators and parasites had been postponed or only partially implemented. Altogether, it was difficult to assess progress towards the main objective of increasing silver eel escapement due to all the delays and the long timeframes involved. It also highlighted that few countries had reached their restocking targets and there was concern that restocking practices may not contribute to increased escapement but instead sustained the fishing for eel.

This second evaluation is therefore crucial in terms of assessing the effects of management measures, as more time has passed. Also, since the previous Commission report, the reformed CFP (Regulation (EU) 1380/2013) objective of Maximum Sustainable Yield (MSY) has been applied to stock management.

Effectiveness and coherence in focus

The emphasis of this evaluation is on the effectiveness and coherence of the measures taken to aid the recovery of European eel, in particular through the national Eel Management Plans. A number of areas are listed, including the design and implementation of restocking efforts, the management of glass eel fisheries, enforcement and monitoring both in marine and inland waters, coherence with other EU legislation and international instruments, including CITES and CMS, as well as the use of public money from the European Maritime and Fisheries Fund (EMFF) to aid implementation.

The Commission is now awaiting Member State reports on the use of EMFF funds, implementation of the Water Framework Directive and, in particular, the national eel management plans in order to gather the information needed for the external and internal evaluations. ICES has put out an extended data call on eel to support its work.

When the evaluation report is finalised in early 2019, the Commission will make its decision on the way forward, probably including an Impact Assessment of potential measures. If the regulation needs to be revised, this is a longer process with proposals for amendments that will need to be discussed and agreed between the Council and the European Parliament. It could take years, particularly considering that 2019 is the year of European Parliament elections, the appointment of a new European Commission and Brexit.

Meanwhile, European eel remains listed as Critically Endangered by IUCN, trade is restricted under CITES Annex II and efforts are ongoing to support its conservation under the Convention on the conservation of Migratory Species of Wild Animals (CMS). European eel is still in need of urgent actions to support its recovery.

A Commission attempt last year to close all EU fishing of adult eels – arguably the most rapid way to aid increased reproduction – was not supported by the Member States. Instead, a joint Declaration on strengthening the recovery for European eel was agreed, committing Member States to step up their actions, including a review of current restocking practices and fighting illegal fishing and trade. In the context of fishing opportunities for 2018, a 3-month ban on fishing for European eel of 12 cm or more is to be implemented by the Member States between 1 September 2018 and 31 January 2019. .

Across the wide geographical spread of European eel, responses to its plight have been slow, patchy and largely ineffective. The first reports of substantial decline came already in the 1970s, but it took over three decades to get agreement on a management framework for the European Union and a listing under CITES Annex II to restrict trade.

The European eel regulation (EC 1100/2007) was finally adopted in 2007. It is a framework regulation with an overarching objective (Art. 2.4) – 40 % escapement of silver eel biomass compared to pre-anthropogenic levels – and an agreed set of measures to use. It requires Member States to create and implement Eel Management Plans for each “eel river basin”, and to submit progress reports every third year, beginning in June 2012.

The implementation of the eel management plans has been riddled with problems, including delays, a lack of reporting, a misuse of measures to support fishing rather than conservation and a very substantial illegal trade in glass eels with countries outside of the EU. Against this background, the upcoming evaluation is incredibly important.

Photo: Actress Florence Keith-Roach “98.4% of the European eel population is already GONE. Continuing to fish for them is like hunting pandas!”

Photo credit: @Fishlove/Jillian Edelstein, Check out this story on the collaboration between Our Fish and Fish Love.

Letter from NGOs to Danish Fisheries Minister Karen Ellemann

The following letter was sent to Denmark’s Minister for Fisheries and Equal Opportunities and Minister for Nordic Cooperation on February 21st, 2018.

Download PDF Version of NGO letter to Minister Ellemann re LO monitoring and control

Minister Karen Ellemann

Minister for Fisheries and Equal Opportunities and Minister for Nordic Cooperation, Denmark

Via email: [email protected]
21 February 2018
Re: Ending illegal, unreported discarding of fish by the Danish fishing industry

Dear Minister Ellemann,

We are writing to you to express our concern regarding the illegal and unreported discarding being carried out in the Baltic Sea by the Danish fishing fleet, as recently documented by scientists and NGOs, and reported by DR (1,2). We appreciate your acknowledgement of the problem, and we urge you to implement the solutions needed to reduce wasteful and illegal discarding, including significantly increasing at-sea monitoring and control.

Discarding of fish not only wastes resources, it increases fishery costs, threatens endangered species, and impacts our food webs. The growing awareness of these threats to Europe’s oceans led to almost 900,000 people supporting a ban on discards during the reform of the Common Fisheries Policy, and motivated the European Parliament and the EU Council to legislate the Landing Obligation in 2013, in order to eliminate discards and drive change in fishing practices.

The failure to properly enforce the discard ban in the Baltic Sea not only jeopardises the sustainability of fish stocks and undermines scientific advice, it introduces illegal activity into our fisheries. This must change: it is not acceptable for the fishing industry to continue to indulge in blatant law breaking, threatening the future of both our fisheries and those that depend on it for their livelihoods.

Scientists and experts from countries with effective discard bans have recommended that EU member states substantially increase at-sea monitoring and control to ensure compliance of their fleet (3). However, following the Landing Obligation coming into force in the Baltic Sea, Denmark actually decreased at-sea inspections from 2015 to 2016 by ten per cent (4). Although widespread non-compliance with the landing obligation in the Baltic Sea is known by fisheries managers and control officers, just two fines were given for discarding in three years, demonstrating the inadequacy and dysfunctional nature of the current control system.

Demersal trawlers and seines were responsible for 97% of discards of Eastern Baltic cod in 2016 (5), yet commercial adoption of selective gears has been slow. Denmark’s trawl industry has had three years to adapt to the introduction of the Landing Obligation in the Baltic Sea; the ongoing discarding equates to nothing less than wilful, illegal, unreported activity, and can no longer be brushed aside with excuses.

The EU Control Regulation is currently under review and provides an opportunity to introduce the compulsory use of Remote Electronic Monitoring in the entire EU fleet, ensuring a fair playing field and improving compliance with the law.

Denmark has been a leading developer of remote electronic monitoring (fully documented fisheries) projects in the past, and improvements in technology, decreases in costs, and its adoption by governments in other parts of the world means implementation is not only achievable, but likely to be more efficient and effective than current monitoring systems (6). It also enables vessels to demonstrate they are operating in accordance with best practice and improves data collection to support stock assessment and management decisions.

Now, we believe the Danish government has an obligation and the opportunity to take the lead on ensuring that EU fisheries rules are respected by all stakeholders. We are confident that as the new Minister of Fisheries in Denmark you can drive better practices within our fisheries, and be an example for other European nations.

We urge you to act now, so that Denmark can:

  1.  Ensure undersized fish are not caught in the first place, by requiring the use of more selective gear types;
  2. Implement proven, cost-effective monitoring onboard all vessels above 10m length and in segments with an increased risk of discarding (EFCA classification) in the Danish fishing fleet, e.g through the installation of Remote Electronic Monitoring (REM) and closed-circuit video surveillance;
  3. Increase inspections and control at sea; and
  4. Begin re-allocating quota to those in the fishing industry who have minimal impact, such as small-scale passive-gear fishers, and are complying with the law.

We would welcome an opportunity to discuss these issues with you in further detail. To arrange a meeting, please contact Rebecca Hubbard, Our Fish.

Yours sincerely,

Rebecca Hubbard
Program Director,Our Fish

Birgitte Lesanner
Head, Greenpeace Denmark

Bo Øksnebjerg

Conrad Stralka
Executive Director, BalticSea2020

Jan Isakson
Fisheries Secretariat

Henning Mørk Jørgensen
Water Policy Officer
Danmarks Naturfredningsforening

Erik Bjørn Olsen
Seniorconsultant, Levende Hav

Copies to:

Ib Poulsen, Danish People’s Party
Trine Torp, Socialistisk Folkeparti
Simon Kollerup, Socialdemokratiet
Andreas Steenberg, Medlemssekretær (RV)
Ida Auken, Radikale Venstre
Soren Egge Rasmussen, Enhedslisten
Maria Reumert Gjerding, Enhedslisten
Christian Poll, Alternativet


2 Our Fish, 2017, Thrown Away: How illegal discarding in the Baltic Sea is failing EU fisheries and citizens.

3 Agreed record of fisheries consultations between Norway and the European Union for 2018.

4 Danish Agrifish Agency, 2016, Annual report on inspection of commercial and recreational fisheries 2016, Ministry of Environment and Food in Denmark.

5 ICES, 2017. Report of the Baltic Fisheries Assessment Working Group (WGBFAS). ICES CM 2017/ACOM:11.

6 WWF, 2017, Remote Electronic Monitoring: Why camera technology is a cost-effective and robust solution to improving UK fisheries management. 10/Remote%20Electronic%20Monitoring%20in%20UK%20Fisheries%20Management_WWF.pdf