Someone has objected to some aspects of this petition and I have been asked to substantiate or modify certain contentions listed below. I think it proper to add to the petition rather than to edit text which people have already signed. The objections are copied and numbered 1-7 below, the text in question first followed by the specific objections.
"This is contrary to the letter and the spirit of Europe-wide laws and regulations designed to save this crucial species, to which the UK is a signatory."
Issue:
The UK is no longer part of the EU and does not follow EU-wide wildlife trade laws.
If the claim refers to specific international agreements (e.g., CITES), the petition should cite the exact law allegedly being violated.
Action Required:
Either specify the exact legal violation or acknowledge that the UK is no longer bound by EU rules but still follows conservation agreements.
Response: The UK was signatory to the EU eel regulations (Council Regulation (EC) No 1100/2007 (OJ No L 248, 22.9.2007,) which were incorporated into UK law as 2009 No. 3344, The Eels (England and Wales) Regulations 2009 . As such the UK is bound by regulations that are identical with those of the EU. A keystone of this legislation is the requirement for restocking, which in both EU and UK legislation requires a silver eel escapement (ie eels escaping to breed in the ocean) of 40% of what would be expected from pristine waters. This must be laid out in an Eel Management Plan. It is contended by the organiser of the petition that the Eel Management plan for the Vistula lagoon is known to be inadequate and for the Curonian lagoon no such plans exist, making release in that lagoon non-compliant with the eel regulations of either the EU or the UK and hence outwith both UK and EU law and not compliant with CITES requirements. The UK also has no way of verifying compliance in Russia.
"This trade benefits the UK's sole surviving elver trader. Only a small amount of the sale price filters back to the few remaining part-time elver fishermen. Its importance to the local economy is negligible."
Issue:
The claim that the economic benefit is negligible contradicts the complaint's claim that the trade has historically contributed £100 million to the local economy.
Action Required:
Either provide alternative economic data or rephrase the statement to reflect opinion rather than fact (e.g., "Some argue that its economic benefits are limited compared to its environmental impact.").
Response: While the revenues from elver trading were once considerable, in the period where over-exploitation was a major conservation issue, since the EU banned trade to the Far East and since Brexit resulted in the loss to the UK of European markets there is virtually no market for UK elvers. The only known market for UK elvers in the last few years is believed to have been for slightly over 1500 kg to Russia between 2022 and 2024. It is therefore widely argued by some conservationists that its economic benefits are of necessity minimal and limited compared to the potential conservation impact. The figure of £100 million quoted by the complainant is irrelevant as the markets producing those revenues are now permanently closed to him by UK and EU legislation and these kinds of revenues have been unavailable for approximately 15 years,
"These elvers will be sold to Kaliningrad, a known transit point for the vast smuggling trade in elvers, the most smuggled wildlife in the world by numbers and by value."
Issue:
While elvers are known to be smuggled, there is no direct evidence linking this specific UK export to illegal trade.
Action Required:
Either cite a source showing that Kaliningrad is currently used for smuggling UK elvers, or adjust the claim to acknowledge uncertainty (e.g., "Some conservationists are concerned that Kaliningrad has previously been associated with smuggling.").
Response: I am happy to amend this to read “Some conservationists are concerned, in the light of widespread elver smuggling, that Kaliningrad has been associated with various kinds of smuggling and that it is not a safe destination for endangered eels or elvers”. Smuggling is by its nature secretive and hard to demonstrate and EU/Interpol enforcement may not extend to Russia.
"There is no justification for this trade and there is much evidence to suggest that the Russians are ignoring the export conditions that Defra try to impose."
Issue:
"Much evidence" is a strong claim that lacks supporting sources.
Action Required:
Either provide examples of breaches of export conditions or reword (e.g., "Concerns have been raised that Russian authorities may not fully comply with export conditions.").
Response: one export condition is that the elvers are not to be used in aquaculture. 500kg were exported to Kaliningrad in 2023; in 2024 https://fishnews.ru/news/51662 reported that fish farms in the region had raised about 100 tons of commercial eel. They have no other source of elvers except the UK and therefore it is a reasonable conclusion that UK elvers were grown in aquaculture to produce this tonnage. It is a matter of public knowledge that UK elvers are received by an aquaculture company in Kaliningrad called Gudfish. The Chief minister of Kaliningrad also made claims about the large quantity of eel meat Kaliningrad aims to produce, and Russian press material has been quite clear and enthusiastic about raising eel in aquaculture https://klops.ru/kaliningrad/2023-09-25/279950-kazhdomu-kaliningradtsu-po-portsii-ugrya-v-regione-planiruyut-dovesti-vylov-tsennoy-ryby-do-400-tonn-v-god
A second export condition relates to onward transfer of the elvers, which is not permitted under the export conditions. A source in Belorus and another in England alleged that there was a transfer by road in April 2023; a source in Lithuania alleges that these went to Pres. Lukashenko’s eel ponds; I cannot evidence this further without betraying confidences and identities and putting people in danger, so I must content myself with stating that “concerns have been raised that elvers may be transferred onwards from Russia and that the UK has no ability to monitor such possibilities in current conditions.” This Belorus transfer has been investigated by UK Wildlife Crime but they are unable to investigate within Russia, further highlighting the risks to elvers of the Russian export trade.
A third export condition relates to the only authorised use of these elvers, restocking the Vistula and Curonian lagoons. Under EU and UK law as mentioned above restocking must include a provision for the equivalent of 40% of the silver eels that might escape from a pristine ecosystem to be allowed to migrate and breed in the ocean. This is demonstrated in theory by an eel management plan in place for only one of the two lagoons which details how this escapement will be achieved and monitored. The UK CITES authorities also require these documents to be in place in order for them to be able to authorise the export of endangered eels. I have plenty of evidence from eel scientists in Holland, Lithuania and Poland who have told me that the Eel Management Plan for the Vistula lagoon may be inadequate; one called it ‘of stone-age quality’ and another said his work had been copied without his knowledge or consent. Some conservationists have told me they believe the Vistula Eel Management plan was created to facilitate the export, since UK CITES could not have agreed to the export without such a plan having been created and Russia, being outside the EU, having no other reason to create such a plan. Even more significantly there is not an eel management plan for the Curonian lagoon and hence their release there would not be compliant with CITES export conditions or EU/UK law, so the release of 500,000 elvers into the Curonian lagoon in 2024 is, it is contended, in breach of eel regulations and of UK export conditions which cannot be said to have been intended to permit restocking that was not compliant with EU and UK eel regulations. The source below is not the only ref. to stocking the Curonian Lagoon with UK elvers; it has been mentioned several times in Russian media, and informs the source below:
https://www.sustainableeelgroup.org/why-location-is-everything-in-fisheries-management/
"This does not seem to be a conservation project; there is much evidence that the Russians intend to farm the elvers in the lagoons and in a fish farm and to grow and then eat them."
Issue:
The claim that "much evidence" exists is vague.
The complaint states that this is actually a Russian government-backed conservation project.
Action Required:
Provide sources or evidence that the primary intent is farming for consumption rather than conservation.
Alternatively, reword as a concern rather than a fact (e.g., "Some conservationists worry that these elvers may be used for farming rather than restocking.").
Response: Some conservationists worry that these elvers will be used for farming rather than restocking. Indeed restocking the lagoons for fishery purposes is in effect just eel farming if no mature eels are to be allowed to escape (see 6 below). There is much to warrant these suspicions: These links (below) indicate the intention to produce large quantities of eel meet and the explicitly-stated intention to catch all the eels in the lagoons before they can migrate. It should be noted that the elvers are received in Kaliningrad by an aquaculture company and not by a conservation organisation, and none of the literature I have seen mentions conservation plans. I should like to point out that in spite of the exporter’s conservation claims not one single piece of evidence has been produced by him or his supporters or any other conservationists to my knowledge to support his contention that this is a conservation project. Many conservationists in the UK signed a letter to the Telegraph objecting to the exports. https://www.sustainableeelgroup.org/in-full-segs-open-letter-to-the-telegraph/ My eel-scientist contacts in Poland and Lithuania (which share these lagoons) are adamant that this is a purely commercial project with no conservation intent.
https://m.newkaliningrad.ru/short/2023/02/08/24032491.html
https://m.newkaliningrad.ru/short/2023/02/08/24032491.html
"The fisheries chief in Kaliningrad has been reported saying they will catch all the eels before they have a chance to migrate, which means that there will be NO conservation element in the restocking whatsoever."
Issue:
The phrase "has been reported saying" lacks a source.
"NO conservation element whatsoever" is an absolute claim without supporting data.
Action Required:
Provide the source of this claim or reword it to reflect uncertainty (e.g., "Reports suggest that some officials may prioritize eel fishing over conservation efforts.").
Response: The Fisheries chief for Kaliningrad, Yuri Maslov, has indeed been reported in the Russian media as telling a fishery and agriculture committee of the Kalininigrad administration that there was no Intention to let any eels escape tp breed, and hence no conservation intent nor content in the project. He said ‘they will all have been caught’, not ‘some’ or ‘most’, which fully supports my claim that there is no conservation content
https://m.newkaliningrad.ru/short/2023/02/08/24032491.html
"They appear also to have sent elvers on to Belorus, against the export conditions and not to any known conservation project."
Issue:
No evidence is cited to confirm that elvers have been illegally sent to Belarus.
Action Required:
Provide evidence or rephrase to reflect uncertainty (e.g., "There are concerns that elvers could be redirected to Belarus, though this has not been confirmed.").
Response: This has been dealt with under (5) above