Trade, Trophies and Trust: What's Wrong with CITES

At the Los Angeles International Airport in July, a man from Japan was arrested for attempting to illegally smuggle Queen Alexandra's birdwing butterflies—one of the largest butterfly species in the world—into the United States. In Singapore in 2002, customs agents discovered a 20 foot long cargo container filled with 13,000 pounds of illegal elephant ivory. And in the United Arab Emirates, more than one-half of the monkeys illegally smuggled from Pakistan in water tankers with false bottoms arrive dead. Whether the trade is in skins, shells, bushmeat, gall bladders, bones, sport-hunted trophies or live animals, our world's wildlife is under threat from a burgeoning illegal business. Trade in wildlife and wildlife products, worth over $10 billion in annual revenue, ranks only behind drugs and guns as the most lucrative illegal trading activity in the world.

The Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES) was created in 1973 to regulate wildlife trade, recognizing its threat to animal populations. To fulfill its mission, CITES contains increasingly restrictive trade criteria for species listed in Appendices I, II and III. Trade in Appendix I species, such as tigers, sea turtles and most species of bears and elephants, is prohibited with minimal exceptions, while trade in Appendix II and III species is permitted with proper documents. Yet with mounting evidence of increasing anthropogenic threats to wildlife, particularly those associated with trade, CITES is in dire need of an overhaul. Convincing the majority of member countries—many of whom generate significant revenue through wildlife trade—of this need may be difficult, but as the world's leading importer of wildlife, the United States is uniquely situated to strengthen its CITES standards and provide an example for the rest of the world to emulate.

Recently, in response to a proposed rule to update the US CITES regulations, the Animal Welfare Institute (AWI) submitted a letter that provided ample evidence of the urgent need for the US Fish and Wildlife Service (FWS) to establish national standards addressing the deficiencies inherent to CITES. Of particular importance is the need to simplify the process by eliminating loopholes. These loopholes are being exploited to facilitate the illegal smuggling of wildlife or wildlife products across international borders.

Even more urgently, the FWS must toughen the requirements for trade in Appendix I and II species. CITES requires the issuance of non-detriment findings (NDFs) for the export of Appendix I and II species and for the import of those in Appendix I. These findings are intended to ensure the trade will not harm the survival of the species in the wild. CITES does not require such findings be made in writing or even that they be shared between exporting and importing countries. As a consequence, there is no accountability in the system because a country with neither the population data nor resources to issue a valid NDF can manufacture a fraudulent NDF, issue a verbal NDF, or ignore the requirement altogether—with little chance that the shipment will be rejected or confiscated by the importingcountry.

AWI also urged the FWS to make its CITES process more transparent by informing the public when it receives trade applications for all CITES-listed species. At present, the public is only informed of applications received (cont.'d) for species listed as endangered under the Endangered Species Act. Consequently, most people are unaware of the vast amount of wildlife trade—including the trade in live wildlife and sport-hunted trophies—of CITES-protected species that the FWS approves every year. According to trade data compiled by the World Conservation Monitoring Center, in 2004, the United States reported over 1,600 import permits issued for an unknown number of animals representing more than 100 species, including bottlenose dolphins, jaguars, African and Asian elephants and lilac-crowned and red-spectacled Amazon parrots. For the same year, the United States also reported 270 import permits issued for the sport-hunting trophies of an unknown number of Appendix I, II and III animals of over 110 species and subspecies, such as hamadryas baboons, gray wolves, grizzly bears, polar bears, caracals, African lions, leopards, African elephants, hippopotami, argali sheep andNilecrocodiles.

Illegal trade is second only to habitat destruction as a threat to the survival of wildlife around the world. Legal wildlife trade also contributes to these threats due to the aforementioned problems with the CITES process and the increasing demand for imperiled wildlife. As even the FWS concedes, this can create a market for protected wildlife that, if not met through legal trade, results in increased illegal trade. Some believe making wildlife valuable by allowing trade is the only means to save these animals. Preliminary data compiled by AWI suggests that this claim is erroneous. Indeed, for those Appendix II mammal species for which World Conservation Union population trend data is available, the majority of species have a downward trend suggesting that whatever value is allegedly generated through trade does not correspond to increased species protection.