Criticism of new eel plan: Unreasonable to allow continued fishing based on wishful thinking

Published 2025-11-06.

Reducing the impact of fishing is one of four key actions to improve the situation for the critically endangered eel in Sweden, according to the new eel management plan recently presented to the government by the Swedish Agency for Marine and Water Management (SwAM). Still, the plan lacks concrete measures in this area. The impact of commercial fishing, which is currently carried out along the Baltic Sea coast and in inland waters, will be gradually reduced by not issuing any new fishing permits until the stock shows clear signs of recovery.

"It is unreasonable to allow fishing in the Baltic Sea to continue, while the fishing ban introduced on the west coast is considered to be the most effective measure to date," says Sara Söderström, fisheries researcher at Stockholm University Baltic Sea Centre.

The revision of the management plan is supposed to take into account the evaluation of Swedish eel management carried out by the research council Formas. In spring 2022, the government of the time tasked Formas with this evaluation, recognising the need for an independent scientific panel to review the measures in the Swedish management plan and Swedish research efforts, in light of advice from the International Council for the Exploration of the Sea (ICES) and the European Commission's evaluation of the Eel Regulation. A particular focus of the review was to be on the analysis presented by the Swedish University of Agricultural Sciences (SLU) on the proportion of migrating eels caught.

For over two decades, ICES had recommended various formulations to halt eel fishing. In 2021, the advice was strengthened from 'as close to zero as possible' to 'zero catches in all habitats', and this recommendation has remained steadfast thereafter, including in the advice released this week. Since 2021, ICES has also emphasised that this includes fishing for glass eels for restocking, one of the cornerstones of the Swedish eel management plan in use since 2009.

Results of the evaluation

Formas' evaluation took 2.5 years, with a budget of SEK 9 million. At the recent seminar organised by Marine Management Academy (Havsförvaltningsakademin – a network organised under the auspices of the Swedish Institute for the Marine Environment), Formas explained that the first 1.5 years were spent travelling around the country, talking to various stakeholders and compiling background information for the international panel of researchers.

In its assessment, the international panel concluded that the main threats to restoration of eels in Sweden, in descending order, are:

1. lack of upstream and downstream migration success 2. illegal fishing anywhere 3. legal inland freshwater fisheries 4. small-scale coastal fisheries in the Baltic

It is not entirely clear from the report how this conclusion was reached, as was also pointed out by several stakeholders who later submitted their comments on it. Fisheries expert at Stockholm University Baltic Sea Centre, wonder whether the international panel may have underestimated the importance of the Baltic Sea's brackish water habitat for eels.

"The evaluators seem to be very focused on the idea that eels need more habitats, but they don't present any evidence for this. In Sweden, for example, brackish coastal environments have always been important habitats for eel growth and development. Given the low number of glass eels arriving today, there is no indication that a lack of habitat would limit increased silver eel migration," says fisheries researcher Henrik Svedäng.

One curious argument in the report concerns the sustainability of eel fisheries in Sweden (see page 24). Here, Formas states that ICES acknowledges in its advice that some mortality may be unavoidable and therefore recommends that fishing and other impacts should be kept 'as close as possible to zero'. However, rather than referencing the advice that ICES has provided since 2021 and that has recommended otherwise, the source of this statement is a workshop report on future advice held earlier in 2021. In this report, ICES states that the phrase 'as close as possible to zero' is open to interpretation and therefore should be replaced with the more explicit 'zero catch'. This distinction is important, given that the Swedish government bases its decisions on scientific advice from ICES in EU negotiations on all fish species other than eel.

Fishing ban stated to have had the largest effect

In its evaluation, the Formas panel emphasises that the complete closure of the west coast fishery in 2012 has been "the most significant and impactful measure implemented" (page 23, referencing its own subproject report). The effect of this closure has also been quantified in a recently published scientific study.

Despite this, the Formas panel does not propose a similar ban on fishing on the east coast, where around 90 tonnes of eel – or 90,000 mature or nearly mature eels – have been caught yearly in recent years.

Baltic fisheries are ”low impact”, writes the panel, which nevertheless suggests that Sweden should continue the current path of not granting new eel fishing licenses and not allowing the transfer of licenses to new license holders.

An additional measure is also proposed: to reduce the annual catch limit of 8,000 kg per license holder to 1,000 kg. However, SwAM chose not to include this specific proposal in the new management plan.

Confusing response from Formas

In a letter to Formas, SwAM officials appear somewhat perplexed by the panel's conclusions. They request references for several statements and proposals, and ask for clarifications regarding fishing. If the fishing at current level does not pose a threat, why should it be phased out?

”We lack references and clear argument to underpin the recommendations on phase-out rather than closure or continuing fishery on current level. Why is a phase-out of fishing proposed if the panel does not consider the current levels of fishery to be a significant threat? Is it just to avoid the risk of increased fishing pressure? If the panel does consider current to be a considerable threat, why wait?”

The panel's response does not provide much clarity. Among other things, it writes:

”The phase-out is part of the current management plan (i.e., as licenses are retired). Fishing [in inland waters] is currently on restocked eels as well that likely won’t escape to spawn anyway.”

However, as mentioned above, the panel itself ranks legal inland freshwater fisheries, which largely target stocked eels, as the third greatest threat, while also recommending an end to restocking. The response ignores coastal fishing, which is mainly carried out on naturally migrating eels.

Furthermore, the panel responds that the fact that fishing has been allowed to continue to date, contrary to scientific advice, implies that trade-offs have been made that they themselves chose not to question:

”ICES has recommend closing all fisheries on eels for years, yet the inland and small coastal fisheries in Sweden continue. This implies some kind of barrier or trade-offs involved in implementing immediate closures that are beyond the scope of the Panel’s evaluation. We don’t imply in the report that closing fisheries, where appropriate would be wrong.”

Contradicts the purpose of the evaluation

Charles Berkow, policy analyst at the Baltic Sea Centre, is perplexed when he reads several of the panel's statements.

"An important purpose of appointing an independent inquiry is to break the deadlock that ‘some form of barrier’ represents. It appears that the panel has chosen to give politicians what it thinks they want, rather than conducting the review that politicians actually requested,” he says.

During the Marine Management Academy's seminar, Formas described it as satisfactory that the evaluation had such a clear mandate and role in the management process, and that they had not considered it meaningful to make recommendations that are not politically feasible.

“Adapting one’s own proposals to what one believes politicians want is, in my view, inconsistent with the ideal of independent expert authorities. Unfortunately, I have seen several deviations from this in relation to eel management,” says Charles Berkow.

Uncertain estimates of fishing mortality

So, what is behind the international panel's view that fishing in the Baltic Sea is "low impact” and shows a "declining fishing mortality"? These claims are also found in the new management plan, in which SwAM states: "The impact of Swedish fishing in the Baltic Sea has declined rapidly over time as a result of the restrictions introduced since 2007".

Estimates of the size of the eel stock and fishing mortality along the Baltic Sea coast are made by SLU using a method based on tagging and self-reporting. A number of captured adult eels (usually 150–300 individuals) are tagged and then released back into the sea. When a fisherman catches a tagged eel, this must be reported. The estimated ratio between tagged and untagged eels in the catches is then used as the basis for calculating fishing mortality and the size of the eel stock.

In recent years, extremely few tagged eels have been reported as caught. In the 2020 decade the average recapture rate has been 1.1 per cent in the Swedish fishery, and 0.5 per cent in the Danish eel fishery. From this, SLU concludes that the fishing mortality is very low (estimated at 0.003, which corresponds to an annual catch of just under 0.3 per cent through fishing). However, if this were true, the total amount of eel in the area would be very large, around 23,500 tonnes. As this is an unreasonable amount, SLU has chosen in its latest report to reuse the estimate of the silver eel run from 2012 and subtract the latest year's catches. The report notes that the assessment is uncertain, yet it still states that it estimates a ”positive trend in the status of silver eel” and that ”commercial fishing pressure on silver eel has been greatly reduced over time”. These formulations are then echoed in Formas' evaluation. 

"One of the key points in the government's assignment to Formas was explicitly to review SLU's calculations and their conclusions in relation to ICES' conclusions that commercial fishing for eel should cease. However, the panel merely noted that SLU's calculations are uncertain, without reflecting on the fact that they form the basis for the lack of effective measures to reduce fishing in the Baltic Sea, as has been done successfully on the west coast. This is disappointing,” says Charles Berkow.

At least some members of the evaluation group of Formas have understood the problems with the method, as was evident at the recent seminar, where it was noted that the approach gives commercial fishermen an incentive to refrain from reporting tagged eels.

Significant decline in stocks

There is no doubt that officially reported eel catches have declined significantly over the past fifteen years. According to SLU, catches amounted to over 300 tonnes in 2010 and 93 tonnes in 2023. However, it is not at all clear that this means that fishing mortality or the impact of fishing has decreased.

In a new study, Henrik Svedäng has used the fishery-independent trawl surveys conducted by ICES in the North Sea, Skagerrak, Kattegat and Baltic Sea to analyse the occurrence of eels over time in these areas. The study shows that the number of eels in a trawl has declined continuously in recent decades. Since the eel management plan came into force, the decline has accelerated. 

"The overall decline in commercial fishermen's catches is most likely due to this; there are simply fewer eels in the sea to catch," says Henrik Svedäng.

If the number of eels caught in the surveys in the Baltic Sea is representative of the eel population in the area as a whole, this also means that the exploitation rate in the fishery has not decreased at all, but remains at the same level as before.

"Since 2010, the abundance of eels has declined by about 85 per cent, and the same applies to catches. In other words, the reduced abundance of large eels in the sea is a good predictor of how large the eel landings will be," says Henrik Svedäng.

Both Formas and SwAM call for new methods to estimate eel stocks and fishing mortality.

"ICES trawl surveys are not designed specifically to monitor eels, but they are systematic measurements that have been carried out over a long period, and they clearly show that the status of eels has deteriorated significantly and that the risk of extinction has increased. If we want to save the eel, fishing for adult or nearly adult eels in the sea must cease completely," says Henrik Svedäng.

He believes that the lack of priority given to the survival of naturally migrating eels in Swedish coastal waters is due to an incorrect focus in the EU's Eel Regulation. The goal of the Eel Regulation, and thus of the national eel management plans, is that the level of migration from the entire inland distribution area of eels (there is no target for coastal waters) should be 40 per cent of an estimated original level. 

"This is a utopian goal that is neither possible nor necessary to achieve. Normally, priority is given to the survival of the existing population when it comes to endangered species, but here we have instead ended up with a traditional production mindset that has been popular in inland fisheries management," says Henrik Svedäng.

No to restocking and transferring of licenses

There are nevertheless some improvements in the new Swedish eel management plan, according to researchers at the Baltic Sea Centre.

At the same time as being tasked with developing a new eel management plan, SwAM was also commissioned to evaluate the effectiveness of eel restocking and the conditions for allowing generational change in eel fishing by enabling the transfer of eel fishing licences.

In its sub-report on generational change, the authority states that such a change would require new regulations to prevent an increase in the total fishing pressure on eels, and the new eel management plan is clear that no new licences will be granted or transferred until the stock shows clear signs of recovery.

"Given the acute threat to eels, it would be completely irresponsible to proceed with such an idea," says Henrik Svedäng.

In its evaluation of eel restocking, SwAM concludes that it is not possible to say whether restocking eel fry contributes to the long-term conservation of eel stocks, and that it should therefore not be included as a conservation measure in the new management plan. (In practice, government-supported restocking has not been carried out since 2020.) This conclusion is welcomed by researchers at the Baltic Sea Centre, who have previously strongly criticised this practise pdf, 1.4 MB..

"Glass eels released in Sweden have been caught elsewhere – a practice that ICES advises against. In Sweden, the glass eels have also often been released above hydroelectric power plants, where the adult eels have subsequently been killed," says Sara Söderström.

In addition to government-supported restocking programmes carried out as a conservation measure over the years, restocking is also carried out as a result of conditions for the granting of old water permits. For example, this may be to compensate fishermen for hydroelectric power development, which has prevented eels from reaching certain fishing waters. Restocking may also be carried out as a voluntary compensation measure. SwAM writes that these water permits should be reviewed, and that when they are, releases should no longer be included as a condition. 

Continued processing of the plan unclear

In order for the new management plan to come into force, it must be adopted by government and submitted to the European Commission. However, it is not yet decided when this will take place or what the national process will look like beforehand.

The current plan was adopted by the Government and sent to the European Commission for approval without being debated in Parliament.

"I hope that the Parliament will also have the opportunity to take a position on the new management plan. The question of whether Sweden should continue to allow fishing for an endangered species, contrary to scientific recommendations, deserves a political debate," says Henrik Svedäng.

Text: Lisa Bergqvist
 

The Swedish eel management plan

• In 2007, the EU adopted an eel regulation to reverse the negative trend for eels, and member states were tasked with developing national eel management plans.
• The Swedish eel management plan was developed in 2008 and approved by the European Commission in 2009. It is based on four types of measures: reduced impact from fishing, reduced impact from hydropower, restocking of glass eel and increased monitoring. As part of the effort to reduce the impact of fishing, fishing on the west coast was completely closed in 2012.
• In spring 2022, the government (led by Magdalena Andersson) commissioned Formas to evaluate both the measures in the Swedish management plan and the Swedish research efforts that have been made on eels.
• In 2024, the government (led by Ulf Kristersson) commissioned SwAM to revise the Swedish eel management plan. The conclusions of Formas' evaluation should be taken into account in the revision. The assignment also included evaluating the effectiveness of eel stocking and investigating the conditions for allowing generational change in eel fishing by enabling the transfer of eel fishing licences.
• Formas' evaluation, with the main report "European eel: common responsibility for a threatened fish", was published in December 2024 and presented at a webinar in January 2025 and at a breakfast seminar in February 2025. Several stakeholders send their comments on the evaluation to SwAM and Formas, and SLU sends SwAM a 22-page review of the evaluation.
• In June 2024, SwAM presented a proposal for a new eel management plan, which is sent out for consultation. Stockholm University Baltic Sea Centre was one of many stakeholders that responded to the consultation. 
• On 1 October 2025, SwAM reported to the government on the task of revising the eel management plan, including an sub-report on the conditions for generational change and an sub-report on the effectiveness of eel restocking.