Background and Context
For more than half a century, the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) has provided the framework through which the international community has sought to reconcile the movement of goods with the preservation of species at risk. Since its adoption in 1973, the Convention has enabled governments to create a common language for trade in animals and plants whose future depends upon the moderation of human activity. Through this agreement, countries subscribing to the agreement have accepted that the circulation of wildlife must be guided by principles of care, transparency, and restraint, and that the continuity of trade and the continuity of the natural world are not opposing conditions but aspects of the same responsibility.
At the Twentieth Conference of the Parties, which will be held in Samarkand in late 2025, delegates will examine a proposal that carries particular significance for the future of freshwater eels. The measure, prepared jointly by the European Union and Panama, invites Parties to bring every species of the genus Anguilla within Appendix II of the Convention. It follows the 2007 listing of the European eel, A. anguilla, and extends that approach to the sixteen other anguillid species found in Asia, Oceania, Africa, and the Americas. The proposal arises from the recognition that these species share the same commercial supply chain, that glass eels and eel meat cannot readily be distinguished by sight, and that their distribution and decline reflect the same ecological pressures. A genus-wide listing would therefore replace a set of regional and fragmented controls with a coherent system through which legal trade and biological recovery can proceed together under a unified international standard.
The SEG Perspective
The Sustainable Eel Group welcomes this proposal as a considered and necessary step toward coherence in global governance. Experience drawn from science, enforcement, and management has shown that incomplete or uneven regulation leaves space for substitution and mislabelling on the basis of the lookalike issue, allowing illicit activity to persist in parallel with a legitimate and ethical trade. A single Appendix II listing offers the prospect of replacing this disorder with a structure that functions across borders, supports enforcement, and restores confidence to the market.
This position represents confidence in measures introduced in the European context, but also an emerging consensus that conservation successes in one region tend to displace population pressures elsewhere. The eel is oblivious to artificially imposed boundaries, moving freely between rivers, estuaries, and ocean gyres throughout its life cycle; its protection must therefore extend beyond individual jurisdictions and take shape through an international framework that recognises the mutual benefit of the species. The proposed listing would create such a framework and would align the objectives of CITES with those of the European Union’s Eel Regulation and other regional management initiatives, forming a continuum of policy capable of guiding the species’ recovery.
The proposed eighteen-month transition period provides time for governments, industry, and enforcement agencies to build the capacity required for effective implementation. This preparation will enable the development of documentation systems, the training of customs personnel, and the creation of reliable traceability mechanisms. Through this measured approach, the proposal establishes a bridge between conservation, enforcement, and the commercial sector that ensures the continuation of trade in a manner that strengthens rather than weakens the resilience of the resource.
Reasons to Support
The case for the inclusion of all Anguilla species in Appendix II acknowledges that customs officials cannot reliably distinguish between species; that molecular testing, though precise, is expensive and logistically difficult to implement, and cannot be applied to every consignment; and that the absence of a unified rule leaves the trade vulnerable to exploitation. A single listing provides a structure that simplifies compliance, closes the grey area between legal and illicit fishing, farming and trade, and allows authorities to implement a single standard of oversight. Through simplified processes, it strengthens the ability of enforcement agencies to detect and prevent illegal activity, thereby protecting both the species and those who depend upon it for their livelihoods. A ‘legal acquisition finding’ prior to export facilitates subsequent import procedures in the receiving country, reducing the burden on developing countries and removing the need for laboratory-based DNA testing altogether.
The proposal also affirms a principle that has long guided the work of SEG and its partners in Europe and the Americas: namely, that effective regulation serves those who act responsibly. By ensuring that every shipment of eel is traceable to a legal source, the listing rewards transparency and allows honest operators to participate in a market built upon integrity. This approach maintains economic continuity while promoting ecological balance. For the Japanese and American eels, which have now entered the Endangered category, such a coherent system of regulation offers the only viable path to recovery. When trade in every species of Anguilla is governed by a single standard, substitution will cease to be a profitable strategy, and enforcement will gain the precision it requires to secure lasting sustainability.
SEG Attendance and Delegation to the CoP
The Sustainable Eel Group will take part in the Samarkand conference through a delegation that brings together a depth of experience across policy, communication, research, and enforcement. The delegation reflects SEG’s interdisciplinary character, its evolving position as a custodian of freshwater eel at an intercontinental level, and its commitment to dialogue between science and practice.
Andrew Kerr, Chairman of the Sustainable Eel Group, will lead the delegation and act as its principal representative in plenary and bilateral meetings. Drawing on his experience within the Wildlife Trusts movement and his long engagement with European environmental governance, he will present the case for unity in the management of migratory species, and for policies that sustain livelihoods alongside biodiversity. His approach to diplomacy emphasises continuity, dialogue, and respect for scientific authority, qualities that will guide SEG’s contribution to negotiations at the Conference.
Sheldon Jordan, Policy Consultant and former Director-General of Wildlife Enforcement for Environment and Climate Change Canada, will advise on the enforcement implications of a genus-wide listing and on the development of compliance systems that can be adopted by Parties of differing capacity. His background with INTERPOL and his leadership in international environmental crime prevention bring practical knowledge of how CITES decisions are translated into national law and operational action. At Samarkand he will assist Parties in understanding how trade documentation, customs training, and intelligence exchange can together ensure that the listing delivers real outcomes on the ground.
Katie Schleit, Senior Fisheries Adviser at Oceans North in Canada, will bring the perspective of North American marine policy and the connection between profit, people, and the planet. Her expertise in sustainable fisheries and her long experience in international negotiations will help integrate the needs of Atlantic range states into the global framework envisioned by the proposal. She will contribute to discussions on the implementation period, capacity building, and traceability, drawing on Oceans North’s record of advancing transparent, science-based conservation partnerships.
Alexander Barty, Communications Consultant, will coordinate SEG’s external engagement at the CoP, ensuring that the organisation’s messages reach delegates, journalists, and civil society through print and digital media. His background in editorial design and policy writing informs SEG’s ability to translate technical content into a narrative that resonates across political and linguistic boundaries. He will work with the CITES Secretariat and attending NGOs to support accurate reporting, to facilitate informed debate, and to present SEG’s materials as authoritative reference points during the proceedings.
Together, these individuals embody the range of expertise required to advance an argument that unites legality, ecology, and governance. They will serve as a bridge between researchers, administrators, and field officers, advancing the principle that effective conservation depends upon a shared and enforceable understanding of legality.
Guidance and Further Resources
The Sustainable Eel Group has developed an extensive suite of materials to assist governments, practitioners, researchers, and enforcement professionals in the design and implementation of eel conservation measures. This body of work forms a growing library that is available in both print and digital form, and can be accessed in English, French, and Spanish. Each publication serves a distinct purpose, be that to provide policy direction, to support operational planning, or to offer interpretive context for decision-making. Together, they form an interconnected set of tools through which the global community can approach the management of Anguilla from a bird’s-eye perspective and with a clear understanding of policy and practical implementation measures.
Available materials include:
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The SEG Policy Document, which sets out the organisation’s position on protection, trade, and recovery, and offers a comprehensive overview of the governance framework required to achieve the 40 per cent survival benchmark.
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The Delegation Handout, a concise introduction to the proposal and to SEG’s objectives at the Samarkand Conference, presented in accessible form for delegates and observers.
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CITES Proposal 35, the official submission by the European Union and Honduras calling for the inclusion of all Anguilla species within Appendix II.
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CITES Reference Documents, containing the relevant procedural and interpretive guidance for Parties.
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Florian Stein and Willem Dekker’s latest article, which explores the prerequisite for dialogue between science and administration in the long-term restoration of the stock.
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A commemorative volume, Conservation and Fellowship, SEG’s definitive coffee-table book that presents the story of eel conservation in photography, research, and narrative form, available to order ahead of the Samarkand meeting.



