Sunday 26 July 2020

Anguilla anguilla: The ilicit trade in European Glass Eels.

On 28 October 2019, French customs officers at Charles de Gaulle Airport arrested two people on their way to Kunming, China, because they had 300 000 live Glass Eels in their luggage. Contained in water-filled plastic bags kept cool by frozen water bottles, this contraband weighed 91 kilograms and was worth over 100 000 euros. What these 'Fish Mules' were doing was illegal because, following a significant decline in the wild population, European Eel, Anguilla anguilla, was listed in Appendix II of CITES in 2009, and the European Union placed a ban on the import and export of these eels in 2010. This seizure represents just one small portion of a large-scale illicit flow involving many tons of live, critically endangered European Eels smuggled from Europe to Asia every year.

In a report published in the annual United Nations Office of Drugs and Crime World Wildlife Crime Report on Trafficking in protected species for 2020, Florian Stein of the Sustainable Eel Group presents a report on the ilicit trade in European Glass Eels.

A European Glass Eel, Anguilla anguilla. Guy Verreault in Silfvergrip (2009).

Freshwater Eels are one of the most widespread marine genera and are part of the national cuisine in countries around the world. European Eels, like most Sturgeons, are diadromous, which means they spend part of their life cycle in saltwater and part in freshwater. While Sturgeons spend most of their lives in saltwater and return to the freshwater to breed, Eels do it the other way around, spending most of their lives in rivers and streams and returning to sea to mate. Scientists believe that both European and American Eel, Anguilla rostrata, breed in the Sargasso Sea, a calm area of the North Atlantic bordered by ocean currents and home to a characteristic Seaweed. While this breeding has never been witnessed, captured larvae grow increasingly larger radiating from the Sargasso Sea toward the US and European coastlines. 

After riding the Gulf Stream to the European and North African estuaries over the course of a year or longer, the arriving larvae have matured to the Glass Eel stage, reaching between six and eight centimetres in length. These juveniles, referred to as 'Glass Eels' due to their transparent appearance, are needed for aquaculture because adult European Eels have never been successfully bred in captivity. This means that, unlike Sturgeon caviar, demand for wild caught Eels cannot be replaced by captive breeding. And since populations of Japanese Eel, Anguilla japonica, American eel and European eel are in steep decline, some of the multi-billion-dollar Eel industry appears to have become reliant on poaching.

Eel products are legally produced and consumed in countries around the world. This legal market is relevant to a discussion of Eel trafficking, because it is largely fed by aquaculture producers who may receive some of their Glass Eel stock from illegal sources. Unlike contraband like street drugs, there is no back-alley black market for Eel meat products. Rather, similar to some other wildlife products, legitimate products can be tainted by illegitimate sources of supply. The following section describes the parameters and trends of this legal market and the role European Glass Eels have played in it.

Adult Eels may be caught from rivers for consumption, but most Eels consumed today come from aquaculture. In 2017, Food and Agriculture Organization statistics show over 96 per cent of the global Eel supply was from aquaculture. As explained later in this chapter, some of these farming operations make use of illegally taken Glass Eels.

Adult European Eel, Anguilla anguilla. Animal Pictures Archive.

There are many species of Freshwater Eel (of the genus Anguilla), but it appears that just four provide most of the Glass Eels for Eel aquaculture: Japanese Eel, American Eel, Shortfin Eel, Anguilla bicolor, and European Eel.

According to the International Union for Conservation of Nature, Shortfin Eels are classified as 'Near Threatened', with an uncertain population trend. Both Japanese and American Eels are 'Endangered', European Eels are 'Critically Endangered', and all three species have a declining population trend. However, only European Eel is CITES-listed (Appendix II as of 2009) and, in 2010, the European Union banned all European Eel imports and exports. While sourcing and trading of other Eel species could be contrary to national fisheries laws, only European Eel are subject to international controls.

Only the import and export of European Eel is banned in the European Union. Production of Eel in the European Union for European consumption continues, although at greatly reduced levels compared to 30 years ago. For more than 50 years, stock abundance and fishing yield of European eels have declined by about 5% annually, to less than 10% of their historical levels today. In the 1980s, official Glass Rel catch figures for Europe exceeded 3000 tonnes per year, but between 2010 and 2016, the official catch was less than 60 tonnes. This decline is due to a number of factors, not just overexploitation, but the species has been deemed too vulnerable for international commercial trade from the European Union. National trade data show that France, Spain, Portugal and the United Kingdom hosted the primary fisheries for Glass Eels in the past, and a different group of countries (particularly the Netherlands, Denmark and Germany) grew the Glass Eels to maturity and processed the meat. Today, the Portuguese fishery is strongly restricted, so most of the legal Glass Eel catch in Europe comes from the other three countries. 

European Eel produced (aquaculture and capture fisheries) in Europe, 1990-2017. Stein (2020).

In Spain, the situation is complicated by the fact that the coastal areas have autonomous status, so the fishery is regulated locally with no national quota, and recreational fishing of Glass Eels for personal consumption is allowed in some areas.

In France, a national quota is set (just under 65 tonnes for 2017-2018), which is the sum of local quotas and includes Glass Eels set aside for restocking.

In the United Kingdom, there is no national quota, but fishing is limited to the use of hand nets by a small number of fishers (about 300) operating during a constrained season in a limited geographic area.

The volumes legally fished for Europe appear to be less than those illegally exported for aquaculture. Global seizures alone can represent more than 10 per cent of the French national quota, and have trended upward since 2011, the year after the Rel export ban was put in place. Based on world wildlife seizure data, Spain, France and Portugal appear to be the source of most of Glass Eels seized today. Seizure data also show the destination of these Glass Eels is also the region with the highest legal production: Asia. In 2017, 96 per cent of global aquaculture Eel production took place in Asia.

Weight equivalent of European Eels seized and number of European Eel seizures (live, fingerlings), 2011-2018. Stein (2020).

Traditionally, Asian Eel production was based on Japanese Eel, but declines in catches have forced the industry to import Glass Eels of other species. Based on UN Comtrade data, 89 per cent of the world’s live Eel imports (including Glass Eels) were made by Asian countries in 2018, particularly Japan, the Republic of Korea and China. Japan was the leading importer, importing virtually all its live Eels from China.

Live Eel imports in 2018 (US$ millions). Stein (2020).

Nowhere are Eels more important as a food source than in Japan, where unagi kabayaki is popular year-round, but traditionally eaten by everyone on the Midsummer Day of the Ox. Fisheries catches of Japanese Eels have been steadily declining since the 1960s due to a variety of factors, including over-exploitation. The species has been classified as 'Endangered' on the International Union for Conservation of Nature's Red List since 2014. Parallel to this decline, export of European Eels to East Asia began to rise steeply in the 1970s. According to the CITES Trade database, in 2009, Japan imported 96 per cent of the legally traded European Eel meat. While Japan dominates imports, China dominates aquaculture production. In 2017, 85 per cent of global Eel production by weight occurred in China. The combination of species of the Glass Eels on which this production is based has varied over time. Until exports from the European Union were banned in 2010, most of the Chinese Eel production was based on European Eel (78 per cent in 2008-9). Since then, there have been limited CITES certified exports of live European Eel from North Africa, which is within the range of the European Eel but outside the European Union export restrictions.

Juvenile Eels, Anguilla japonica, legally caught in Japan (metric tons), 1957-2017. Stein (2020).

The 2010 European Union export restriction triggered a rush for Glass Eels from other sources. Based on UN Comtrade import data, it appears that demand for Chinese aquaculture was satisfied by imports from Malaysia and the Philippines (presumably Shortfin Eel) initially, but increasingly from the United States and Canada (presumably American Eel). The shift in demand outside Europe can be seen, for example, in export data on American Glass Eels. In the state of Maine, the catch quadrupled as prices increased twenty-fold in three years, from just under US$100 per pound in 2009 to just under US$2000 per pound in 2012. The increase in both price and volume caused a sharp increase in the total market size in 2012. In 2018, renewed demand for American Eel was seen, albeit at lower prices, suggesting a competing source of supply.

Imports of Glass Eels into legal aquaculture ponds in China (metric tons), 2008-2016. Stein (2020).

Despite population declines and fluctuations in the source of Glass Eels, global Eel production has remained remarkably consistent over the years, driven by rising production in China. Although the 2010 ban on exports from the European Union did cause a slight decline in Eel production until 2013, production again increased after that time, reaching a new high in 2016. Since the total value of recorded Glass Eel imports (of all species) by China have declined by half since the CITES listing of European Eel in 2009, it remains unclear how production is being maintained. Data on the species input for Chinese aquaculture shows a different pattern in the sourcing after 2009, with increasing reliance on the endangered American Eel. Despite its 'Endangered' status, American Glass Eel can still be legally exported without CITES certification.

Imports of Glass Eels into legal aquaculture ponds in China (metric tons), 2008-2016. Stein (2020).

Based on world wildlife seizure data, it appears that it is in the traditional source countries that much of the illegal Glass Eel supply originates. According to high ranking wildlife law enforcement officials interviewed in 2018, there are two main sources of European Glass Eels illegally trafficked internationally: commercial fishers who catch Glass Eels for the legal market and knowingly or unknowingly supply illegal exporters (diversion); and poachers, who Fish clandestinely with the intent to supply the illegal market.

Legal imports of live Glass Eels to China by exporting country (US$ millions), 2001-2018. Stein (2020).

Established Eel traders have been found to be involved in illegal exports, so any commercial fisherman selling Glass Eels to a trader could unwittingly be complicit in illegal exports. Commercial traders can also be involved in acquiring Glass Eels illegally and then further exporting them illegally.

Recorded value of the legal American Glass Eel fishery in the state of Maine (US$ millions), 1994-2018. Stein (2020).

For example, European investigations uncovered a Spanish Eel trader who was working with a Greek Eel farm to illegally export large (800 kg) shipments of Glass Eels to China. The Eels were illegally taken in Spain, transported in trucks to Barcelona, and then by ferry to Italy and onwards to Greece, where the legal Eel farm was located. This ostensibly legal farming operation gave cover to both illegal fishing and illegal export.

Legal aquaculture eel production in China and the world, 1996-2016 (metric tons). Stein (2020).

In parallel, there are also networks of poachers who acquire their Glass Eels clandestinely. Based on their knowledge of the timing and location of Eel migration, poachers use hand nets, trap nets or small trawling nets to work the estuaries where Glass Eels transit at night. According to European law enforcement sources, on average, a poacher can gather between 200 grams and one kilogram of Glass Eels per night, although much larger takes are possible under the right conditions. One kilogram of Glass Eels represents about 3000 individual Fish, so each poacher can remove between 600 and 3000 Eels for every night of work. The number of poachers is unknown, but they collectively add to Glass Eel shipments measured in the tens and hundreds of kilograms.

Glass Eels (all species) legally imported by China (kilograms), 2001-2017. Stein (2020).

The poachers receive between 180 euro and 400 euro per kilogram from buyers, thus receiving up to 400 euro per night. Some poachers keep tanks in their homes and sell to buyers from their front door. In some instances, buyers travel to the harvest locations and consolidate the output of many poachers, paying cash on the spot.

After the Glass Eels are collected from the poachers or licensed collectors, they are transported to consolidation facilities, often located near international airports. These facilities generally include a series of aerated tanks in which the Glass Eels are stored; typically, about 20 kg of Glass Eels are put into oxygenated water tanks with about 1000 litres of water. To ensure the highest survival rates, the Eels are kept in these conditions no longer than 15 days, so the exports should be closely tied to the harvest season. At these facilities, the local buyers are paid between 400 euros and 900 euros per kilogram by those who traffic the Glass Eels internationally.

Based on world wildlife seizure data and interviews with law enforcement officials, Glass Eels are smuggled using two main techniques. They are shipped in refrigerated containers via air freight under cover of, or mis-declared as, other seafood products. They are smuggled using commercial air couriers in specially prepared luggage.

The two trafficking techniques roughly correspond to the two forms of illegal sourcing (diversion and poaching), although it is entirely possible that Eels sourced from poaching could be shipped using cover loads, or that diverted Eels could be smuggled by couriers.

To be transported internationally and arrive alive, Glass Rels must be kept in controlled conditions and released as quickly as possible. Containers suitable for transporting other live seafood can be used in airfreight, so mislabelling (as Shrimp, Mussels, or Octopus, for example) or concealing the Eels in these containers containing other forms of live seafood is common practice.

Air couriers make use of luggage containing bags of Glass Eels in addition to some form of refrigeration, typically frozen bottles of water. This luggage may be shielded with inexpensive insulation material, such as car windshield sun protectors. Raids on consolidation sites have revealed hundreds of identical suitcases used for this purpose. The longer the flight, the fewer Glass Eels that will survive the trip, so direct flights are likely to be favoured, unless a secondary staging area is used. In the latter case, European, North African and other Asian countries are used for transit to Asia. Upon arrival, the traffickers are paid between 800 euros and 1500 euros per kilogram for the contraband. In effect, each buyer in the initial stages of the supply chain doubles or triples their money.

Enforcement activities associated with Europol’s Operation Lake uncovered a new variation in trafficking method, in which Glass Eels are hidden in Styrofoam ice chests that are packed in checked luggage. European Eel was also detected in European consumer markets mislabelled as American Eel. In connection with Operation Lake, some 3.8 tonnes of European Glass Eels were seized in the 2017-2018 season and 5.8 tonnes in 2018-2019. Speaking of the 2017-2018 season, Europol estimated that around 100 tonnes were smuggled from the European Union to China.

Price per kilogram for illegal Eels paid to poachers, traders and importers in 2018 (Euros). Stein (2020).

Seizures of European Glass Eels have increased from an annual average of less than 1.5 metric tons in the first four years of the European Union ban to an average of just under 5.5 tonnes in the last four years. Considerable resources were applied to interdiction, and this trend is surely affected by these dedicated efforts. Some 80 per cent of these seizures were made by the governments of Spain, France and Portugal, the origins of almost all the Eels seized. To put this figure in context, these seizures are equivalent to about 10 per cent of the total supply of Glass Eels introduced into aquaculture in major producer states.

Of those seizures whose destination was known between 2011-2018, more than half were destined for China and 19 per cent for Thailand. Thailand does export hundreds of tons of Eels every year, but this is about 1 per cent of what China exports, so some share of these is likely trans-shipped. Those arrested in connection with these seizures represent a mix of European and Asian nationalities. Of intercepted shipments, the most common destination was Hong Kong, China, which is located near the largest Eel farms, located in the provinces of Guangdong and Fujian. Genetic testing has proven that European Eel are smuggled from Europe to Hong Kong, special administrative regions of China.

Number of people arrested for European Glass Eel trafficking in Spain by nationality, 2016-2018. Stein (2020).

On arrival in Asia, it appears the illicitly exported European Glass Eels are fed into the commercial eel farming industry. According to the Food and Agriculture Organization of the United Nations, in 2017 some 259 000 tonnes of Eel (all species) were produced, of which about 221 000 tonnes were produced by China, accounting for 85 per cent of global production. According to the China Eel Industrial Association, more than half of this is exported, with the rest for domestic consumption. Much of the exports are destined  for the Japanese market, but also to the United States and other destinations around the world.

From the 1970s to the 1990s, live Eels imported by Japan mainly came from Taiwan, Province of China, but Eel production gradually moved to the southern provinces of mainland China, predominantly Guangdong and Fujian, which have been responsible for about 86 per cent of Chinese production in recent years. Before the European Glass Eel export ban in 2010, Fujian production was focused on European Eel. Once imported, despite starting out larger than other species, it takes between 18 and 36 months to grow European Glass Eels to marketable size (400 to 500 grams for export, or 600 grams for the domestic market), making them one of the slowest growing species of Eels, ccording to the Chinese Industrial Eel Association.

Trafficking flow map - European glass eels (2007-2018). Stein (2020).

The Chinese Bureau of Fisheries reported that there were 797 Eel aquaculture operators in 2017. In 2013, the United Nations Industrial Development Organization produced a study focused on an Eel processing company (Firm Y) from the Guangdong province. The company employed 200 workers and procured live Eels from 16 different suppliers to produce 10 000 tonnes of output per year. The sheer volume of production, the number of firms involved, and the complexity of the supply chain makes this industry vulnerable to the introduction of illicit sources of supply. For example, any of the 797 aquaculture operators could unwittingly contract with an overseas Glass Eel supplier who illegally sources European Glass Eel.

Aside from the seizure record, one way of estimating the amount of illegal Eel introduced into legal supply chains is to compare the amounts of Glass Eels of all species imported and the amounts of adult Eels produced. In the case of China, this analysis is complicated by the fact that the country is within the range of Japanese Eel and could, in theory, supply most of the aquaculture demand for Glass Eels from this source. In practice, however, this has not been the case. Rather, Glass Eels from a variety of species are used in Chinese aquaculture, while China exports about half the Japanese Glass Eel it catches. Between 2008 and 2016, China exported roughly half the Japanese Glass Eel it caught. As a result, only one-third of aquaculture demand for Glass Eels between 2008-9 and 2015-16 came from domestic sources, leaving the industry twothirds dependent on imports.

Share of legal exports of prepared or preserved Eels (all species), whole or in pieces (excluding minced), from China by destination country or territory, 2014-2018 (tonnes). Stein (2020).

With this in mind, it is difficult to reconcile reported imports of Glass Eels with total Eel production and exports over time. Of course, Glass Eels of any species can be utilised, but stark changes between Glass Eel imports and production (taking into account utilisation of domestically caught Anguilla japonica) suggest an undocumented source of Glass Eel supply. This supply need not be of European Eel, but the fact that these ascribed imports of Glass Eels are not recorded raises suspicions about their origins.

Share of total seizure volume by reported shipment destination, 2011-2018. Stein (2020).

Between 1995 and 2000, China’s reported production amounts to an average of about 1.5 tonnes of Eel for every kilogram of Glass Eel imported. Between 2001 and 2008, this figure rose to about 4.5 metric tons of Eel for every kilogram of Glass Eel imported. From 2009 (the year of the CITES listing) to 2015, the figure rose to an average of almost 15 tonnes of Eel for every kilogram of Glass Eel imported. Even considering the likelihood that eel growing technology has improved, mortality rates in transit and production will have decreased and that domestic sourcing of Glass Eels may have increased, this tenfold rise is difficult to explain, whatever the yield of the species introduced.

Kilograms of adult Eel produced in China for every kilogram of Glass Eel imported, 1995-2015. Stein (2020).

While there are often discrepancies in trade statistics, there are stark differences between the data presented by CITES, UN Comtrade and Eurostat. Comparison is complicated by the very wide range of codes used to describe Eels and Eel products in trade: 72 different, partly overlapping, codes were identified in Stein's study. In the absence of evidence of illegal trade, it would be difficult to ascribe significance to the discrepancies, but when taken in context, they appear to be evidence that the industry is affected by some unrecorded supply.

Thousands of kilograms of European Glass Eels have been seized since 2012, representing millions of individual Eels. It is unclear what share of the total illegal flow is interdicted, but law enforcement surveillance and intelligence suggest the share is relatively low. For example, one operation seized less than 500 kg of Eels from a group that evidence later suggested had exported more than ten times that amount.

 Transformation of European Glass Eels to Eel filet. Stein (2020).

The volume and value of this trade is thus difficult to estimate. The 6000 kg of Glass Eels seized in 2018 alone would have been worth up to nine million euros to importers. According to law enforcement sources interviewed by UNODC, records seized from a criminal group as evidence suggest that similar volumes are shipped by individual groups annually. Of course, the Glass Eels are only the front end of the production process. Each kilogram of Glass Eels, costing 1500 euros on the black market, can be converted into some 9000 euros worth of filet on a wholesale level, thus enriching businesses who use trafficked eels in their production process. Wholesalers do not pocket all this money, of course, since the costs of farming must be taken into account, but given the volumes, the profits appear considerable.

At this point in time, every European Glass Eel imported for the purposes of farming requires a CITES certificate to export, as should every adult European Eel exported after being grown out. Interviews with aquaculture specialists indicate that one kilogram of European Glass Eels yields 750 kilograms of filet. If so, it should be possible to reconcile Glass Eel imports with Eel meat exports. Even taking into account the gap between introduction and harvest, it is unclear how such large exports of European Eel meat would be possible given the low quantities of reported European Glass Eel imports. This suggests that Glass Eels were imported without CITES certification. In 2017, Eel meat exports were commensurable with expected production, but this would only be possible if all European Eel meat were exported and none retained for the domestic market. Additional, though incomplete, data reported to the CITES Animals Committee suggest that only 4.5 tonnes of European Glass Eels may have been introduced into Chinese cultivation ponds between 2011 and 2017. Teamed with the seizure data, which indicate the majority of intercepted shipments were destined for China, these trade data provide evidence of a sizable illegal flow.

Comparison of European Glass Eel imports, expected production, and legal European Eel meat exports reported by China (tonnes), 2009-2017 aggregated. Stein (2020).

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