Letter from Le Comité national des pêches maritimes et des élevages marins  (CNPMEM) concerning traceability in European eels

French professional fisheries: a strong link to traceability in Europe

A context evolution in favor of traffics development

This is a sad reality which was, however, predictable, but the risk of increased poaching activity and the development of illegal glass eel trafficking were promoted by:

•  The decline of the number of fishing enterprises, permitting poachers to rapidly take over the areas freed or less frequented by the legal players in the production line;
•  The ban on all eel exports outside the EU, creating the conditions for the development of illicit networks in an increasingly lucrative market.

Conscious of the risks of drift, the French sector has alerted starting from 2009 the French public authorities and the European authorities. The restrictions imposed on French fishery have benefited the illegal players. The French sector is the first victim of illegal trade (economic, ecological and social prejudice).

In this situation, traceability is a major challenge for the European eel sector and constitutes an obligation of the RCE 1100/2007 requiring Member States to take the measures necessary to identify the origin and ensure the traceability of all live eels imported or exported from their territory.

The French profession at the center of a strict regulatory framework

A complete reporting system and traceability of productions is in force in France. Professional fishers hold a CMEA fishing license (professional marine fishermen) or a fishing license issued by the departmental authority (professional inland fishermen). They record their catches of eel of the species Anguilla anguilla in the fishing log or their fishing card from the first hundred grams caught for glass eels and from the first kilogram fished for larger specimens. The fishing log is completed as soon as landing and before transport of the fishery products. When the destination is known by the fisherman (consumption or restocking), the destination of the products is indicated on the catch declaration. The professional fisherman who catches eels of less than 12 centimeters transmits his fishing log every 24 hours (professional marine fishermen) or 48 hours (professional inland fishermen). Each batch of eels transported from the place of landing – and before the first sale, must be accompanied by a transport document. The stakeholders who collect eels complete a declaration of taking over with a sales note before the first sale. First buyers are also subject to strict traceability. They declare all their purchases with an online declaration procedure (VISIOMER) and by sending a daily declaration table of purchases and a weekly table of summary declarations purchases.

A profession at the initiative of the setting up of additional framework

Fishermen fish declare and sell their production in accordance with the current regulatory framework, not always knowing it is not their responsibility to control for what purpose their products were destined, the majority of the production being sold beyond the borders of the country. In order to strengthen the traceability system, optimize and ensure the impermeability of the first links in the production line, the profession has taken initiatives at local, regional or national level to improve and complete the existing mechanisms:

• By facilitating the action of control authorities, by regularly spreading the national eel file, which lists the holders of fishing license;
• By participating, in consultation with control authorities, in improving the content of fishing logs and transport declarations;
• By developing complementary tools of teledeclaration such as TELECAPECHE or TELECACIVELLE;
• By supporting fishermen during the evolution of regulatory or voluntary framework.

At the same time, the profession continues to call for (i) the strengthening of controls on trade flows of glass eels in France and in Europe and (ii) the extension of the French traceability system beyond national borders, in particular through the use of an intra-Community certificate (CIC).