CITES CoP19: Nations Converge on Panama to Determine Protections for Species in Trade

In 2019, the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services revealed that over 1 million species were in danger of extinction and called for transformative change to prevent such a catastrophic loss of biodiversity. The biodiversity that sustains the planet and, ultimately, human well-being, is declining at an astonishing pace—primarily a consequence of human-caused threats that include habitat loss and fragmentation, pollution, climate change, and overexploitation for food, timber, recreation, and the pet trade. In the face of this crisis, the 183 member nations of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) will gather for the 19th meeting of the Conference of the Parties (CoP19) in Panama City, Panama, in November 2022 to debate protections for over 600 species.

white-rumped shama - photo by Wang LiQiang
white-rumped shama, photo by Wang LiQiang

AWI has been active in CITES since its inception in 1973 and will send a team of issue experts to CoP19 to participate in the deliberations. We are organizing two side events—on the toll and cruelty of snares and the current initiatives to combat their use, and on the illegal totoaba trade and its devastating impact on the vaquita porpoise (see discussion under Working Documents below). Also, as AWI has done since CoP9 in 1994, we will recognize wildlife rangers and others who have excelled in combating wildlife crime with the Clark R. Bavin Wildlife Law Enforcement Award at a Species Survival Network reception. 

Since CITES’s inception, nearly 39,000 species (including almost 6,000 animal species) have been listed in one of three CITES appendices. Appendix I includes species most in danger of extinction. International commercial trade in these animals is largely prohibited. Appendix II species are those that may be threatened by extinction if trade is not regulated. International trade in these species is allowed, under permit, if certain conditions are met—chiefly that the trade is not deemed detrimental to the species’ survival. Appendix II also includes “look-alike species” that are similar in appearance to more vulnerable species, making it necessary to restrict trade in both. Appendix III species are those that at least one CITES party has unilaterally listed to prevent/restrict exploitation, and that party is seeking assistance from other parties to control trade.

Species Listing Proposals

The dominant theme in Panama will be reptiles, which account for 23 of the 52 listing proposals. In most cases, the proposals seek to increase protections due to rampant trade for meat and/or pets, which has caused significant declines in some species. 

Appendix II listings are sought for common and alligator snapping turtles (in high demand for their meat) and 19 mud turtle species (traded for meat and as pets). Over half a million alligator snapping turtles (most sourced from the wild) were exported from the United States from 2006 to 2020, and seizure data document extensive illegal and unsustainable trade in mud turtles.

Appendix II listings are also proposed for five broad-headed map turtle and six musk turtle species. These animals are traded as pets, with over 1.5 million map turtles traded internationally 2005–2020 and nearly the same number of musk turtles (over 60 percent wild-caught) legally exported from the United States 2013–2019. 

The United States is seeking Appendix II protections for all American softshell turtles not already listed on Appendix I. These turtles are subject to illegal collection in all their range states to satisfy demand in Asia following the decimation of Asia’s own freshwater turtles. There is a proposal to “uplist” Leith’s softshell and Indochinese box turtles from Appendix II to Appendix I due to trade for pets and/or meat, causing wild populations to decline 90 percent or more over the past 30 and 60 years, respectively. The same heightened protection is sought for the red-crowned roof turtle. 

Other species proposed for Appendix II listings include the Chinese water dragon, due to unsustainable trade for pets and meat; two uniquely marked gecko species—the Jeypore ground gecko and the helmeted gecko—due to threats from the pet trade; and 21 species of horned lizards, some of which are subject to extensive legal and illegal trade as pets and some of which are look-alike species. Disturbingly, most wild-caught horned lizards in trade reportedly die from starvation due to the difficulty in meeting their specialized dietary needs (i.e., live ants), fueling a constant demand for more. Trade in the timber rattlesnake, extirpated in Canada and now endemic only to the United States—where the population is declining and reported as threatened, vulnerable, or endangered in 23 of 31 US states where it is found—prompted the United States to seek Appendix II protections for this species. 

Conversely, there are proposals to “downlist” the broad-snouted caiman, the Palawan, Philippines’ population of saltwater crocodiles, and Thailand’s population of Siamese crocodiles from Appendix I to Appendix II. This would permit increased trade in these species, particularly in their skins. For the saltwater and Siamese crocodiles, a zero-export quota would be established for wild members of the species, theoretically limiting trade to captive-bred animals but opening up opportunities for laundering wild specimens.

The Lemur leaf frog, Laos warty newt, and over 100 species of glass frog are proposed for listing on either Appendix I or II. The leaf frog and newt are both adversely impacted by the pet trade, with the frog population declining as much as 90 percent since 1988 and the newt population cut in half over the past decade. Several countries, including the United States, are seeking an Appendix II listing for glass frogs. Protection is being sought for all glass frog species because of look-alike concerns and to prevent the serial depletion of one species after another to satisfy demand. A similar proposal discussed at CoP18 in 2019 was narrowly rejected by the parties.

glass frog - photo by Milan Zygmunt
glass frog, photo by Milan Zygmunt

Sharks, Guitarfish, and Rays 
Three hammerhead shark species (the great, smooth, and scalloped hammerhead) were listed on Appendix II at CoP16 in 2013. At CoP19, the remaining species of hammerhead sharks—bonnethead, scalloped bonnethead, scoophead, and winged head—are proposed for listing on Appendix II. The ongoing and relentless trade in shark fins continues to decimate shark species worldwide, with some bonnethead populations declining by 50 to nearly 80 percent over the past 36 years. The remaining hammerheads are proposed for listing due to look-alike concerns. 

dusty shark - photo by Ilan Elgrably
dusty shark, photo by Ilan Elgrably

Dozens of species of requiem sharks, including gray reef, dusky, and sandbar sharks and all unlisted sharks in the family Carcharhindae (including blue sharks), are proposed for listing on Appendix II due to ongoing overexploitation for the fin trade or look-alike concerns. Populations of species directly impacted by trade have declined by 50 to nearly 100 percent according to recent assessments by the International Union for Conservation of Nature (IUCN). While such listings would help combat the seemingly insatiable demand for fins, many shark species will remain imperiled until the illegal shark fin trade is eradicated. 

All 37 species of guitarfish are proposed for listing on Appendix II due to heavy trade in fins of six of the species and look-alike concerns for the others. Populations of those in trade have declined by 80 percent or more over four decades. Seven species of freshwater rays, including the porcupine and white-blotched river stingrays, are proposed for listing on Appendix II due to the demand from the ornamental fish trade.

The white-rumped shama is proposed for listing on Appendix II, while Appendix I protections are sought for the straw-headed bulbul. Both songbird species have been heavily traded as pets and for singing contests that are popular in Southeast Asia. Straw-headed bulbuls have experienced an 80 percent decline in the past 15 years, with only 600 to 1,700 mature individuals estimated to remain.

Deliberations will continue over the trade in elephants and ivory, rhinos and horns, and hippos. African elephants are currently “split-listed,” with elephants in Botswana, Namibia, South Africa, and Zimbabwe listed on Appendix II and all other African elephants listed on Appendix I. CITES itself cautions against such split-listings, as they create enforcement challenges.

Several African elephant range states have proposed to uplist Botswana, Namibia, South Africa, and Zimbabwe elephants from Appendix II to Appendix I—a move that would prohibit any commercial trade in live elephants and ivory. Conversely, Zimbabwe seeks to amend an annotation to the four-nation Appendix II listing to permit commercial trade in ivory to generate revenue for conservation. Previous experience, however, indicates that such a move would further incentivize poaching—the last one-off sale of ivory, approved by CITES in 2008, triggered a 66 percent increase in black market ivory trade, according to scientific analysis. 

Since 2008, approximately 11,000 rhinos throughout Africa have been brutally slaughtered by poachers for their horns, which are coveted for their purported medicinal value, as a status symbol, and for their investment and collectible value. Two proposals involve loosening restrictions on trade in rhinos, again supposedly to fund conservation efforts: Eswatini, home to fewer than 100 rhinos, is proposing to allow it to trade live rhinos and rhino products, including stockpiled horns. And Namibia, which has 1,237 rhinos, wants to downlist its population from Appendix I to Appendix II to permit trade in live animals and hunting trophies. Risking such small populations to generate conservation revenue is reckless. 

white rhinos - photo by EcoPrint
white rhinos, photo by EcoPrint

Several African countries are seeking to uplist the common hippopotamus from Appendix II to Appendix I in response to declining or unknown population trends in most range states and significant international trade in the species. From 2009 to 2018, over 77,500 hippo specimens (primarily carved teeth, but also uncarved teeth, skins, trophies, feet, skulls, and other products) were traded legally, while over 6,000 known specimens (a likely undercount) were traded illegally.

Working Documents

In addition to species proposals, CITES parties will debate over 90 working documents pertaining to the interpretation and implementation of the convention. From budgetary to species-specific issues, many of these documents contain new or amended resolutions or decision text. (Resolutions provide guidance to parties. Decisions provide direction to the secretariat, technical committees, and CITES parties to collect and analyze data, share information, and study wildlife trade issues to inform future debates.)

Interpretation and Implementation 
Botswana and Zimbabwe seek to amend voting rules to give more weight to the votes cast by range states for species under debate. On elephant proposals, for example, Botswana wants its vote to count more than a vote cast by the United States. This proposal is sure to fail, as it contravenes the plain language of the convention. Similarly, Eswatini seeks to amend the listing criteria to include a requirement that, for a species to be listed, a determination must first be made that international trade is the key driver of its decline and that food security, livelihoods, and socioeconomics must also factor into the decision—a proposal intended to stymie efforts to list species.

African elephants - photo by Javier Hueso
African elephants, photo by Javier Hueso

Many of the working documents seek to renew decisions approved at CoP18 in 2019, as the COVID-19 pandemic and a lack of funding prevented progress on many issues. The pandemic itself, given its origin in wildlife trade, will generate discussions about CITES’s role in preventing future pandemics. While other international forums are actively engaged in deliberations to mitigate future pandemics linked to zoonotic disease, CITES must also play a role, given the links between habitat destruction, wildlife trade, and the spread of such diseases. Senegal and others have proposed that CITES endorse a “one health” approach (a holistic, multidisciplinary, integrated, and collaborative effort to promote the health of humans, animals, and ecosystems) to reduce the likelihood of zoonotic disease outbreak. 

For marine species collected on the high seas (areas beyond the jurisdiction of any country), the United Kingdom seeks to improve the process for making “non-detriment findings”—a critical CITES mechanism aimed at ensuring that authorized trade will not harm the survival of the species in the wild. 

For species bred in captivity, there will be discussion of an assessment process to ensure that trade in the species is not contravening the convention (e.g., by contributing to laundering of wild-caught specimens as captive-bred). The United States seeks critical reforms to a resolution permitting commercial trade in Appendix I species bred in registered facilities. Among other changes, the United States wants parts or products in trade to be explicitly identified, assurances that legal trade will not undermine efforts to combat illegal trade, and a review of each facility registration every three years. 

A proposal pertaining to humane transport guidelines for the international shipment of animals seeks to make such guidance more accessible, establish training workshops, and encourage parties to extend the guidance to domestic transport of CITES-listed wildlife. Ideally, the parties will agree to establish a joint transport working group to regularly review the guidelines, as required by the convention. Parties will also discuss what constitutes an “appropriate and acceptable destination,” a CITES term applicable to certain live animals in trade. During that debate, AWI and allied governments and organizations will seek to amend proposed guidance on the convention’s criteria on what constitutes “in situ” conservation and whether zoos are “suitably equipped” to care for certain African elephants and white rhinos in trade. 

The role of Indigenous peoples, rural communities, and their livelihoods tied to wildlife trade in the CITES decision-making process will generate considerable debate. AWI supports providing all stakeholders a voice in CITES, but this should be done at the national level—through CITES parties representing the interests of stakeholders within their borders. Similarly, while parties can consider livelihoods in decisions regarding implementation, livelihood concerns are not a factor in the listing process itself, which should remain focused on the degree to which species are imperiled and under threat from trade. 

Compliance and Enforcement 
Parties will continue to discuss the failure by 72 countries to promulgate laws that adequately implement the convention. Some of these countries became signatories to the convention decades ago, providing more than enough time to promulgate adequate regulations. Trade sanctions may be needed to compel such countries to address deficiencies. 

The role of domestic wildlife markets and the internet in facilitating illegal trade will be addressed, as will the use of demand-reduction strategies to curb wildlife trafficking. The internet’s facilitation of wildlife trafficking has required significant investments by governments to combat such crimes. Similarly, domestic wildlife markets encourage trafficking and incentivize ongoing collection of animals from the wild. Strategies that educate consumers about the ecological and legal costs of purchasing wildlife products are critical. 

Of particular interest to AWI will be the ongoing discussion of the totoaba, a large fish that lives in Mexico’s Upper Gulf of California whose swim bladders are in high demand in Asia due to their purported medicinal benefit. Mexico’s decades-long failure to stop illegal gillnet fishing for totoaba and shrimp has caused numbers of vaquita to plummet from nearly 700 in the late 1990s to fewer than 10 today. Mexico continues to claim that its enforcement efforts have been successful despite overwhelming evidence to the contrary—a claim many parties have unfortunately accepted. This dichotomy between Mexico’s rhetoric and reality is clear from the results of the CITES secretariat’s second mission to Mexico in May 2022. Ideally, this will convince parties to, at minimum, support revised and strengthened totoaba decision text at CoP19. Scientists report that the vaquita can yet recover if illegal fishing is stopped, but there is no longer any margin for error. 

Species-specific Issues
Several species-specific working documents will generate considerable debate. An initiative approved at CoP18 to restrict export of Appendix II–listed live African elephants (allowing trade only to conservation programs within the species’ native range) will be revisited. Several African countries are seeking to amend a resolution on elephant trade to impose the same live trade restrictions on all African elephants, while the European Union is unnecessarily seeking to delay such a decision until CoP20 in 2025. Efforts to close all remaining domestic ivory markets contributing to illegal trade and elephant poaching will be debated, as will improvements in the management of ivory stockpiles, with an emphasis on promoting destruction of such stocks. As some countries retain ivory stockpiles in hopes of selling them—ostensibly to support conservation—a new strategy to pay parties to destroy stockpiled ivory will be discussed. 

The United Kingdom is seeking to strengthen an earlier pangolin resolution and associated decision text to address the ongoing illegal trade in pangolin and their scales. Despite the Appendix I listing of all pangolin species in 2016, illegal trade remains rampant due to the purported medicinal value of pangolin meat, scales, and other parts. With Asian pangolins decimated by overcollection, African species are now targeted, resulting in population declines and local extirpations. The United Kingdom’s proposal would strengthen enforcement efforts, close domestic pangolin markets, improve reporting requirements, promote development of pangolin conservation plans, improve pangolin stockpile management, and seek recommendations from the Standing Committee on measurable country-specific initiatives to reduce the trade.

Big cats will also be a focus of debate. The parties will consider the process of setting leopard-hunting quotas and the sustainability of some current quotas. Debate will occur over the cruel trade in cheetahs as pets and the trade in African lions, jaguars, and their parts. The extensive captive breeding of tigers to fuel the trade in live tigers and tiger parts, as well as the ongoing failure of several parties that are breeding tigers in captivity to comply with previously approved resolutions and decisions, will also be examined. 


CoP19 will provide important opportunities to seek protections for a multitude of species while strengthening CITES implementation. There will be controversy, and few will leave Panama entirely satisfied with the outcome of the deliberations, particularly considering the urgent action required to address the biodiversity crisis. CITES and other multilateral environmental agreements can aid conservation but rarely operate with the requisite urgency that the planet and its wildlife need. 

While CITES remains imperfect, it is considered one of the more effective international environmental treaties, particularly given its enforcement mechanisms. Agreements reached at CoP19 will not resolve the myriad threats to global biodiversity, but they can reduce threats posed by wildlife trade and, in so doing, provide a foundation for other actions, domestic and international, to protect wildlife and their habitats from anthropogenic impacts.