Comment from Undersecretary of Aquatic Resources and Fisheries - and National Institute of Fisheries Research and Development

The Undersecretariat of Aquatic Resources and Fisheries and the National Institute for Fisheries Research and Development (INIDEP) appreciate the opportunity to submit the most up-to-date information regarding the status of Galeorhinus galeus in Argentina. In our view, the available scientific evidence does not indicate a concerning decline in the species' population. Nevertheless, Argentina continues to implement a comprehensive set of management and conservation measures aimed at ensuring the sustainable exploitation and long-term conservation of this resource. We present a document (INIDEP Technichal Report_039_2026) with novel information on population trends of tope shark Galeorhinus galeus derived from research surveys conducted by the National Institute for Fisheries Research and Development (INIDEP) to assess the status and dynamics of commercially exploited fishery resources in the Argentine Sea. These surveys are conducted using standardized bottom trawl hauls with a demersal benthic trawl net, towed at a speed of 4 knots for 15 or 30 minutes depending on the objectives of each survey. The preliminary analysis of relative abundance patterns derived from these standardized surveys indicates a relatively stable or even slightly positive trend in the abundance of this shark over the last three decades, with no evidence of a sustained decline in the surveyed population component. These results provide an opposite perspective to the population status assessment and projected trends for G. galeus in Argentina considered for species categorization. It is important to highlight that this categorization is subject to relevant uncertainties associated with both the construction of abundance indices and the interpretation of long-term population projections. Such uncertainties may influence the magnitude and direction of inferred trends, particularly when projections extend beyond the period covered by available observations. Similar considerations were highlighted by the FAO Expert Advisory Panel, which concluded that the available evidence does not demonstrate a continuing global decline of sufficient magnitude to meet the biological criteria for inclusion of G. galeus in CITES Appendix II. Therefore, uncertainties related to data sources, analytical approaches, and model assumptions should be carefully considered when interpreting assessment outcomes and conclusions regarding the conservation status of this species. In Argentina, the tope shark is primarily caught by artisanal and industrial fleets. The highest historical landings occurred during the 1950s, when targeted fisheries expanded during the period known as the “tope shark boom” (locally referred to as “fiebre del cazón”). Subsequently, landings declined substantially as catches became mainly associated with bycatch rather than directed fisheries, reaching levels below 100 metric tons in recent years. Official fisheries statistics also report shark landings not identified to species level (NEP), which may include G. galeus. These catches have remained relatively low, with annual totals below 500 metric tons in recent years. Most reported shark landings are destined for domestic consumption, while export volumes have remained minimal. Argentina has implemented multiple fisheries management and conservation measures at provincial, national, and binational levels (jointly with Uruguay), including restrictions on directed shark fisheries, landing limits, seasonal closures, bycatch mitigation measures, and traceability systems. Although many measures were initially established for commercially important resources, they also provide direct or indirect conservation benefits for chondrichthyans (sharks, rays, and chimaeras). Continued monitoring, improved integration of fisheries-dependent and fisheries-independent data, and refinement of assessment methodologies will be essential to reduce uncertainty and support science-based management decisions for G. galeus in the Southwestern Atlantic Ocean. Should any additional information or clarification regarding the material submitted be deemed necessary or appropriate, please do not hesitate to contact Dr. Jorge Colonello, Head of the Chondrichthyan Fisheries Program at the National Institute for Fisheries Research and Development (INIDEP) (jcolonello@inidep.edu.ar), and Ms. Gabriela Navarro, Director of Fisheries Planning at the Undersecretariat of Aquatic Resources and Fisheries (ganava@magyp.gob.ar).