The debate on Proposal 35 extended over a full session and produced a range of interventions that illustrated the complex interplay of scientific, procedural, and political considerations shaping national positions on Anguilla species, revealing that Parties’ concerns were deeply influenced by their regional management systems, trade structures, and available data sources. While the proposal ultimately failed to achieve the threshold necessary for adoption, the deliberations themselves provided significant clarity regarding how Parties interpret the available evidence, assess the feasibility of enforcement measures, and apply the principles underpinning CITES decision-making, particularly in relation to the lookalike criterion, declining populations, and the challenges of regulating international trade in anguillid eels.

Opening the debate, the European Union framed the proposal as addressing ‘long-standing challenges that have limited the effectiveness of the European eel’s Appendix II listing since 2009’, emphasising that seizures demonstrate that traffickers ‘exploit regulatory gaps between listed and non-listed species by mislabelling them or mixing them with other species’, thereby undermining conservation measures. DG Environment’s Patrick Child, who spoke at SEG’s side event, argued that ‘all Anguilla species meet the lookalike criteria’ and highlighted that ‘populations of the three main temperate species in trade have all suffered major population declines and remain depleted’, stressing that harvest in international trade is ‘a major cause for the decline’ and that unilateral national measures or species-specific regulations cannot keep pace with the scale of trade. In concluding, the EU warned that ‘if we do not act together now, history risks repeating itself’, underscoring the urgency of collective international action to prevent further declines and to ensure that enforcement measures are effective across borders.

The United States, while acknowledging continuing concerns about the illegal trade in glass eels and eel meat, maintained that domestic regulations and the Dominican Republic’s Appendix III listing for American eel ‘should be sufficient to ensure continued sustainable use of these species’, and therefore stated that it ‘strongly opposes’ the proposal at this time, framing it as unnecessary in light of robust controls at the state level. By contrast, the United Kingdom offered a more nuanced assessment, recognising that the decline of eel populations is supported by available evidence and highlighting the ‘substantial identification challenges’ posed by glass eels, particularly in mixed shipments. Its conclusion was that ‘the lookalike criterion is met’ even if broader population trends remain subject to debate.

Opposition from the Asia–Pacific region was the most vocal and strategically coordinated, with several delegations using formal interventions and selective evidence to challenge the proposal. Japan led this position, asserting controversially that the proposal ‘is not supported by science’ and arguing that American and Japanese eel ‘do not meet basic criteria of population decline’, despite scientific advice to the contrary. It also rejected the look-alike rationale by stating that juvenile identification is ‘customary in Japan’, ignoring the challenges experienced in customs checkpoints elsewhere, before concluding that the European eel sector should address ‘its own problem’ rather than ‘impose the burden on other Parties’. This position overlooks the extent to which regulation focused solely on A. anguilla continues to displace demand onto other species, including tropical anguillids in regions with more limited enforcement capacity, and the reality that the bulk of global supply feeds Chinese farms supplying low-cost eel to the Japanese market, with limited economic return to fishers in developing countries.

For the most part, China supported Japan’s overall stance, while also noting the need for continued efforts to counter trafficking. South Korea adopted a similarly measured tone, drawing attention to national investments in identification kits, and the Philippines highlighted existing domestic controls, including a prohibition on trading glass eels under 15 cm. The most unexpected development came from the African Union, which delivered an unusually coordinated block intervention expressing concern that the proposal amounted to a ‘blanket listing’ that risked ‘affecting all species worldwide’. Our analysis suggests this could be linked to controversies about protections of several African species in trade.

Several interventions relied heavily on advice from the FAO, which was criticised for methodological weaknesses in its report and selective representation at its side event. The day before the vote, the FAO hosted a presentation in which they made a number of questionable editorial decisions: emphasising ‘environmental narratives’ rather than scientific consensus; framing listed species in red and unlisted species in green; and making unclear comparisons between species numbers and unrelated metrics such as cars or whales in unspecified countries or regions. The lack of cited evidence, and the prominence afforded to Japan in the talks, amplified perceived uncertainty and created a misleading impression of the scientific and management context which prompted a fierce line of questioning from civil society groups on the floor. Delegations citing FAO advice against the proposal often ignored TRAFFIC-IUCN report and the CITES Secretariat’s recommendation to adopt, leveraging a minority view to challenge the proposal without engaging with the broader body of evidence that supports its adoption. The extensive European Union response to the FAO analysis was also notably absent in the committee meeting, despite the best efforts of civil society to get this on the agenda.

In its closing interventions, the European Union acknowledged the diversity of views, stating that ‘arguments advanced by some countries merit further discussion’, while reiterating that the scientific case for Proposal 35 remains strong and noting that concerns with the FAO study were valid given the existence of additional peer-reviewed literature from Japan. Monaco formally proposed a secret ballot, designed to allow Parties to vote based on scientific and enforcement considerations rather than external political or economic pressures, a procedural adjustment explicitly supported by a broad coalition of Parties including South Korea, Zambia, Zimbabwe, Fiji, Kuwait, Iceland, St Lucia, Lebanon, Japan, China, Sri Lanka, Russia, the UAE, Laos, Madagascar, DRC, and Congo.

The final vote returned Yes: 35, No: 100, and Abstain: 8, insufficient for adoption, reflecting not only differing scientific assessments but also the strategic interventions of opponents, including selective reliance on the FAO study, coordinated lobbying by opponents which reached all Parties several months before the vote, and efforts to shift regulatory responsibility onto the EU. These interventions often overlooked practical enforcement realities, particularly the implications of lookalike species, and amplified perceived uncertainties and cultural implications of responsibility rather than addressing the conservation needs identified in independent assessments. Importantly, the adoption of Resolution 87 received broad support, demonstrating that, despite disagreement over listing, Parties remain committed to improving monitoring, identification, and data clarity for Anguilla species.