Eels on edge: Japan disputes CITES rationale for regulating all eel species over visual similarities

Unagi don grilled eel on rice bowl
Japan is challenging CITES’ justification for listing all Anguilla species under Appendix II. (Getty Images)

Japan is challenging CITES’ justification for listing all Anguilla species under Appendix II, arguing that visual similarities alone do not warrant a blanket inclusion of all eel species

The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) recently published its final recommendations to regulate wild species ahead of the 20th meeting of the Conference of the Parties (CoP20) next month.

Among the 51 proposals, CITES is moving to include Anguilla japonica (A. japonica) and Anguilla rostrata (A. rostrata) in CITES Appendix II, which closely controls trade of species considered at risk due to overexploitation.

The Anguilla Anguilla (A. anguilla), also known as the European eel, was already listed in Appendix II.

The proposed measures aim to closely monitor and control their international trade to prevent decline of A. japonica and A. rostrata, which would disrupt the eel trade – especially in Asia where eels are a delicacy.

“Rising market demand and escalating prices have created conditions for increased exploitation, and with eel farms entirely dependent on wild-caught glass eels and elvers, pressure on wild populations is expected to increase,” said CITES.

If the proposal passes later this year, exporting countries would require permits for international trade for live eels and processed eel products as well.

According to the final document published by CITES, the rationale for including A. japonica and A. rostrata in Appendix II was because of their physical similarities, making it easy of traders to mislabel or mix species.

“Anguillid eel species are almost indistinguishable in their early life stages and in the form of processed products and require molecular techniques for species-level identification that are not feasible for routine use by customs officers…

“Furthermore, as multiple Anguilla species co-occur in trade and are frequently mixed within shipments, the inclusion of the entire genus Anguilla in Appendix II under Criterion A of Annex 2b is necessary to ensure effective enforcement, minimise the risk of misidentification, and support the implementation of CITES controls for currently listed species.”

Listing all Anguilla species under Appendix II would require documentation for every eel shipment, strengthening protection for A. anguilla and curbing illegal trade disguised as other species – closing a major loophole.

Japan has strongly opposed this proposal as it relies on imports from China, Taiwan, and South Korea to meet domestic demand.

Speaking to the press on October 17, Shinjirō Koizumi, emphasised Japan’s disappointment over CITES’ findings before he resigned as Minister of Agriculture, Forestry and Fisheries on October 21.

“In that assessment, it was stated that although the Japanese eel and the American eel (A. rostrata) do not meet the criteria for listing under Appendix II on the grounds of resource depletion, the currently unlisted eel species do meet the criteria as “look-alike species,” given their similarity to the European eel.

“Japan opposes the inclusion of all Anguilla species under Appendix II, and, citing the FAO expert panel’s assessment from August of this year – which concluded that the listing criteria were not met – we intend to make every effort, in cooperation with relevant countries, to ensure that our position is better understood among member states ahead of the Conference of the Parties in November.”

CITES: Eels at risk

According to CITES, A. japonica has experienced a continued downward trend, which has intensified for A. rostrata.

It noted that A. rostrata has been assessed as having a stable population trend over the most recent three-year period.

However, it noted that the species has suffered “dramatic historical declines” and populations in the US and Canada being threatened.

“A recent analysis of East Asian customs datasets highlighted that glass eel and elver imports by the region from the Americas increased from two tonnes in 2004 to 157 tonnes in 2022, demonstrating unprecedented demand for A. rostrata. This has corresponded with sharp price increases for A. rostrata glass eels and elvers, from USD 314/kg in 2009 to USD 3492/kg in 2023 for landed elvers in Canada...

“In combination with the suite of threats facing anguillid eels, from habitat degradation, barriers to migration, pollution and climate change, unsustainable exploitation for the international eel trade continues to pose a significant threat to these depleted populations,” said CITES.

Japan has objected to this proposal on the grounds that it is already managing the A. japonica population in corporation with China, South Korea, and Taiwan.

Japan, China, South Korea, and Taiwan have agreed to restrict input of glass eels and eel fries from the wild into aquaculture ponds for the 2025-2026 season up to 80% of that of the 2013-2014 season.

Despite this, CITES believes international regulation of A. Japonica is still needed.

“While A. japonica is managed under an informal agreement between China, Japan, Republic of Korea and Taiwan, the quantity of eel seed input into aquaculture ponds was expected to approach 150 tonnes for the 2024-2025 fishing season, nearly double the agreed upper limit, according to a Japanese aquaculture publication.

“Recalling that these species have single panmictic populations, and therefore each species comprises a single fishery stock, international cooperation and consistency in regulatory measures are needed throughout their respective ranges.”

FAO data show that aquaculture made up 88% of global eel production between 2014 and 2023, yielding 2.78 million tonnes of live eels, with China contributing 86% of the total.

UN Comtrade figures indicate that global exports of anguillid products fluctuated between roughly 80,000 and 110,000 tonnes annually over the same period.

However, CITES noted that these numbers might not be entirely accurate: “Official production statistics are believed to be vastly underestimated due to high levels of illegal, unreported and unregulated fishing.”