November 2025 – CITES is a global agreement among governments to regulate or ban international trade in species under threat. Every two to three years, parties to CITES meet to review progress and adjust the lists of protected species. At the upcoming COP20 meeting in November, CITES Parties will consider a number of proposals to include new species to Appendices, thereby establishing international trade restrictions for those species. ICFA is concerned about proposals to add common eels and sea cucumbers to Appendix II.
The fishing industry recognizes and supports the work of CITES to ensure that the international trade does not threaten the survival of marine species. ICFA urges CITES Parties to reconsider process and materials that they utilize in determining their position for voting and reaffirm that any decision-making for commercially utilized aquatic species to be included in CITES should be science-based, respecting views presented by the FAO Expert Advisory Panel for such species.
Proposal #29 – Tope Shark and Smooth-hound Sharks
The proposal by Brazil, Ecuador, the European Union, Panama and Senegal would add Galeorhinus galeus, Mustelus mustelus, M. schmitti and all other Mustelus species to Appendix II.
ICFA expresses serious concerns regarding this proposal. By grouping all Mustelus species under one listing, it fails to reflect the biological and fisheries diversity that exists among different Mustelus species across regions. In the Northeast Atlantic, catches concern almost exclusively the starry smooth-hound (Mustelus asterias), a species abundant and sustainably exploited according to the 2025 ICES scientific advice.
By contrast, the common smooth-hound (M. mustelus), which is the main focus of the proposal, is rarely encountered in European fisheries. Listing all Mustelus species in Appendix II would therefore be scientifically unjustified and practically inappropriate, as it does not reflect the reality of stocks exploited in the Northeast Atlantic.
The FAO Expert Panel (2025) concluded that G. galeus and M. schmitti do not meet the criteria for inclusion in Appendix II and that there is insufficient evidence to conclude on M. mustelus.
ICFA supports the Final Assessment by the CITES Secretariat:
“Galeorhinus galeus, Mustelus mustelus and Mustelus schmitti do not meet criteria A in Annex 2a of Resolution Conf. 9.24 (Rev. CoP17) for their inclusion in Appendix II. Mustelus spp. therefore do not meet criteria A or B in Annex 2b for inclusion in Appendix II. The Secretariat recommends that this proposal be rejected.” (CoP20 Doc. 114.1, pp. 105-109)
Proposal #35 – Japanese Eel, American Eel and all lookalikes:
The proposal by the European Union, Honduras and Panama would add 17 eel species to Appendix II and makes specific reference to the Japanese eel (Anguilla japonica) and American eel (Anguilla rostrata).
Japanese Eel
The data proves that the population size of Japanese eel has recovered since 1990 and that Japanese eel is not facing the risk of extinction. Regulating all eel species at genus-level without thorough scientific examination thus is inappropriate.
Japan views this proposal particularly detrimental to eel trade in the Asia-Pacific region, where various Anguilla species are fished and cultivated. This is a one-sided move by the EU that shifts administrative burden of addressing illegal trade of European eel to other regions, disproportionately affecting the Asia-Pacific region, especially to small scale fishers/aquaculture farmers.
Japan is fully committed to the conservation and sustainable use of eels through rigorous enforcement of domestic legislation. Since 2012, Japan has been conducting annual consultations with China, the Republic of Korea, and Taiwan to regulate eel fishing through restriction measures.
American Eel
The American eel is a single, panmictic population with one of the widest freshwater distributions in North America. Its life history confers multiple resilience traits. Panmixia produces broad genetic diversity across the range, helping the species resist isolated disease outbreaks. Gender plasticity promotes increased production of female eels as the number of eels in a local area decline. Habitat plasticity allows individual eels to survive in estuarine or marine conditions when freshwater habitat is blocked. Most important, widespread random larval dispersal creates a continuous “rescue effect,” supplying new recruits to help rebuild depleted local populations.
Against this backdrop, the U.S. Fish and Wildlife Service, in both 2007 and 2015, concluded that American eel is not threatened or endangered species wide. At the 2019 Fisheries and Oceans Canada Stock Assessment Framework meeting, attendees concluded eels are depleted compared to historic levels but stable over the past two or three decades.
The proponents of a CITES listing rely on the “lookalike” criterion, arguing that traceability would be easier if baby eel of every species were listed. But, as applied to the American eel species, the current CITES proposal also relies on a second criterion – that it “may become threatened in the near future” without listing. Because the second criterion is based on a questionable assumption about American eel’s conservation status, rather than mere lookalike concerns, it requires careful range-wide scientific scrutiny before binding international trade restrictions are imposed.
The possibility that the American eel may be designated as “threatened” or “endangered” in Canada makes the glass eel fishery and its commercial quotas highly unstable, scaring off potential investors in an eel industry. Moreover, markets that demand “sustainable seafood” will not accept products designated as threatened – or that “may become threatened in the near future,” as the CITES proposal asserts.
ICFA believes the most effective and sustainable path to eel conservation should be found not in a blanket listing to Appendices, but in international cooperation, knowledge sharing and improved management practices. In terms of IUU fishing and trade of eels, ICFA supports enhanced range-state coordination to combat trafficking, based on increased law enforcement, stiffer penalties, and a common traceability system based on cutting edge technology. But listing common eel species at the genus level on the basis that they “may become threatened in the near future” would merely burden responsible and sustainable eel production and stimulate the illegal trafficking of eels to countries with low regulatory barriers.
ICFA supports the 2025 FAO Expert Panel report, which concludes that the proposal does not meet the criteria for CITES listing.
Japanese eel and other look alike eels
The Expert Panel assesses Proposal 35 not to meet the CITES listing criteria.
This conclusion is based on a comprehensive evaluation of the best available scientific data and technical information, which indicates that A. japonica and related species exhibit medium inherent productivity, large effective population sizes above the Appendix II extent of decline threshold, and low extinction risk as demonstrated by Population Viability Analysis (PVA). Furthermore, the suggested direct linking of international trade to population declines across the genus is not well supported by the evidence. Existing regional and national management measures across Asia are extensive and demonstrably effective, particularly in eastern Asia where cooperative frameworks and practical species identification methods support sustainable use and trade monitoring.
While an Appendix II listing might offer some regulatory harmonization benefits, the risks of unintended negative consequences – including increased illegal trade, market distortions and the disruption of successful management cooperation – are considerable. Therefore, the Expert Panel expresses moderate to high confidence in the result of their evaluation, emphasizing that targeted conservation actions and strengthened species and region-specific management represent more effective pathways to sustainable conservation outcomes than a premature genus-wide listing.
American eel
The Expert Panel assesses that information in Proposal 35 for American eel (A. rostrata) does not appear to meet the listing criteria for CITES Appendix II.
An evaluation of available scientific data and technical information revealed major data gaps that preclude a conclusion that the regulation of international trade in A. rostrata is required to ensure that fisheries harvest is not reducing the wild population to a level at which its survival might be threatened by continued harvesting or other influences.
Glass eel and elver stages (fished primarily in Nova Scotia, Canada; Maine, the United States of America; and some Caribbean islands, and shipped to stock eastern Asia aquaculture farms) are the most economically valuable fishery product. As a panmictic species (no subpopulations or barriers to gene flow), it is likely that A. rostrata is resilient to exploitation by fisheries occurring in only a small portion of its range. Given the high and density-dependent natural mortality of recruiting glass eels and elvers, it is expected that fishing pressure on these stages has a lower effect on the population than exploitation of later stages. Additionally, regional management frameworks are in place to regulate commercial eel fishing in some of its range. Unregulated and illegal fishing is a concern to A. rostrata managers, but the relative contributions of these actions to overall fishing mortality is unknown.
Abundance of yellow (and silver) stage A. rostrata in North America has experienced declines of over 50 percent but its population continues to be large and to occupy an enormous range between Greenland and northern South America. Because fisheries for these stages occur in only a small part of this range, there are no firm grounds to suggest that commercial fisheries are the primary driver of abundance declines relative to other threats such as habitat loss and environmental changes. The Expert Panel concludes that the risk of extinction posed by international trade is low. The Expert Panel considers that a CITES listing would not have conservation benefits outweighing the risks of unintended negative consequences. There is considerable concern that a listing could result in increased illegal trade and hence reduced resources for population and fishery monitoring, market disruptions, and economic harm to artisanal and small-scale fishers. The Expert Panel recommends the prioritization of alternative conservation and management efforts, such as those proposed in the Draft Resolution on Trade, Conservation and Management of Anguillid Eel Species (CITES, 2025). (FAO NFISR/R1482, 2025. pp. 105-106)
ICFA is disappointed with the Final Assessment by the CITES Secretariat, which does not follow the expert opinion of the FAO regarding the proposed look-alike species listing.
A. japonica and A. rostrata do not meet criterion B in Annex 2a of Resolution Conf. 9.24 (Rev. CoP17) for inclusion in Appendix II. All non-CITES-listed species of anguillid eels meet criterion A in Annex 2b of Resolution Conf. 9.24 (Rev. CoP17) for inclusion in Appendix II. (CITES COP20 Doc 114-01, p146.)
Proposal #36 – Sea Cucumbers
The proposal by the European Union would add four sea cucumber species to Appendix II and two lookalike species.
ICFA supports the 2025 FAO Expert Panel report, which concludes that the proposal does not meet the criteria for CITES listing.
The Expert Panel concludes that the best available scientific data and technical information presented in CoP 20 Proposal 36 does not meet the criteria for listing in CITES Appendix II.
The Expert Panel noted Actinopyga spp. have high productivity, and their effective population sizes do not meet Appendix II thresholds for extent of decline (see CITES Conf. 9.24 Rev. CoP13, Annex 5, footnote 1). This determination is based on the absence of clear, empirically supported evidence of widespread population declines across the genus. Furthermore, the Expert Panel had very low confidence in the application of proxy species data, given the documented species-specific life history characteristics, and species targeted fishing pressure.
Listing of Actinopyga spp. in Appendix II could result in substantial issues for fishers and authorities in developing range States where capacity and resources are constrained for managing these extensive, dispersed and mostly small-scale fisheries. Remote communities are often heavily reliant on sea cucumber resources, which offer one of their few opportunities for cash incomes. Finding the appropriate resources to implement management and compliance arrangements remains an outstanding need; absence of these resources will lead to a substantial burden on affected fishers. (FAO NFISR/R1482, 2025. p. 137)
ICFA supports the Final Assessment by the CITES Secretariat:
Actinopyga echinites, A. mauritiana, A. miliaris and A. varians do not meet criterion B in Annex 2a of Resolution Conf. 9.24 (Rev. CoP17) for inclusion in Appendix II. CoP20 Doc. 114.1 – p. 153 A. lecanora and A. palauensis therefore do not meet criterion A in Annex 2b to the same Resolution for inclusion in Appendix II. The Secretariat recommends that this proposal be rejected. (CITES COP20 Doc 114-01 pp. 153-154)
Proposal concerning listing of look-alike species
The United Kingdom has proposed the development of guidance to facilitate the application of the look-alike criterion Annex 2b A of Res. Conf. 9.24 (Rev. CoP17). The goal of the proposal is to “ensure the scope of listings in the future are accurate, appropriate, proportionate, and applied with the best interest of the species proposed under Annex 1 or Annex 2a, and for effective implementation of the Convention.” (CITES COP20 DOC102)
The principles for listing look-alike species are ambiguous and open to broad interpretation because criterion A is not supported by any guidance. Conversely, the criteria for individual species must be read in conjunction with the definitions, explanations and guidelines listed in Annex 5. The absence of equivalent guidance for look-alike selection potentially affects the rigour and transparency of listing decisions based on look-alike concerns.
ICFA shares the concern that increasing use of look-alike listings is creating additional, unnecessary burden on Parties with little to no conservation benefit to the species being resembled. Moreover, the additional burden could very well limit the capacity for more effective species management measures and regimes, which are to take priority. Such listings also may not consider unintended negative consequences to relevant stakeholders. Thus, ICFA urgers Parties to support the proposal by the UK. ICFA members look forward to working with their respective national governments as they participate in the development of such guidance.
Therefore, ICFA calls for CITES Parties to-
- Reject Proposal 29 to include Galeorhinus galeus and Mustelus spp. in Appendix II and Reaffirm that effective conservation of smooth-hound sharks should rely on science-based, region-specific fisheries management and monitoring, rather than broad genus-level CITES listings.
- Reject Proposal 35 to include Japanese Eel, American Eel, and look-alike species in Appendix II.
- Reject Proposal 36 to include four sea cucumber species and two look-alike species in Appendix II.
- Support the proposal to develop guidance on the application of look-alike species criterion.
- Reaffirm their support for the CITES-FAO Memorandum of Understanding signed in 2006. In particular, point 6, which states “In order to ensure maximum coordination of conservation measures, the CITES Secretariat will respect, to the greatest extent possible, the results of the FAO scientific and technical review of proposals to amend the Appendices, and technical and legal issues of common interest and the responses from all the relevant bodies associated with management of the species in question.”
- Support international cooperation and enforcement measures to combat IUU fishing where it exists, but without penalizing sustainable fisheries.
The International Coalition of Fisheries Associations (ICFA) is a coalition of the national fish and seafood industry associations from the world’s major fishing nations. The group was formed in 1988 to provide decision makers a unified voice on global fish and seafood issues. ICFA members are committed to the sustainable use of marine resources for their contribution to global food security. ICFA members are also deeply committed to science based and fully participatory fishery conservation and management practices. Currently, we have 24 seafood industry association members from across the world (Europe, North America, Asia, Australia, New Zealand, Africa and Latin America).
ICFA members participate in various UN meetings in which fisheries issues are discussed and debated ensuring the seafood industry’s voice is heard.
