EIA’s priorities at CITES SC77 for elephants, pangolins, rhinos, big cats and the vaquita

On 6 November, the 77th meeting of the CITES Standing Committee (SC77) will convene in Geneva, Switzerland for the first Standing Committee meeting following the 19th Conference of the Parties (CoP19) last year in Panama.

From species-specific issues to evaluating Party compliance with the Convention, SC77 participants will have their hands full as they work through a loaded agenda.

EIA will be actively engaging at SC77 on a variety of issues important to the protection of elephants, rhinos, tigers, pangolins, vaquita and rosewood, as well as compliance and enforcement of CITES more broadly. Read on for a summary of EIA’s priorities at SC77 and check out EIA’s detailed SC77 Briefing with our full comments and recommendations.



National Ivory Action Plan Process

Countries that have been identified as affected by ivory trafficking are required under CITES to develop and implement National Ivory Action Plans (NIAP) – a collection of activities aimed at building their resilience to the problem. Developed in 2013, the NIAPs are a key CITES tool for elephant conservation and EIA has been involved since its inception to make recommendations to improve the process and countries’ implementation of their NIAP activities.

Unfortunately, eight out of the 13 countries in the NIAP process failed to submit a progress report for consideration at SC77, as per their obligations. EIA is extremely concerned about this very low rate of reporting, which undermines the process, its objectives and its aims of elephant conservation and improved governance against organised wildlife crime.

At CoP19 in 2022, EIA successfully lobbied alongside partners WWF and WCS for a review of the NIAP process, but we firmly believe that until the review is concluded, the NIAP process must continue and countries need to continue abiding by its guidelines. As such, we have prepared a standalone briefing analysing the progress made by key countries in which we make specific recommendations to SC77 regarding numerous shortcomings with countries’ implementation of activities relating to ivory stockpile reporting, closure of domestic ivory markets, legislation and regulations, international cooperation and enforcement matters.

Domestic ivory markets

Domestic ivory markets are again up for discussion by Parties at SC77. In 2016, CoP17 agreed to language in Resolution Conf. 10.10 urging countries with domestic ivory markets contributing to poaching or illegal trade to close them urgently. At CoP19, Parties agreed to explore the feasibility of conducting analysis of ivory seizure data linked to each Party with a legal domestic ivory market and direct the CITES Secretariat to report the results of the analysis to SC78 and CoP20.

SC77 will consider a report from the Secretariat with an update on the feasibility of the analysis and agree the next steps to conduct an analysis. The Secretariat has expressed a need for further clarification from SC77 on how to identify which markets to assess in the analysis and guidance on relevant research and data.

EIA is calling for SC77 to agree to criteria that is inclusive of ivory markets which facilitate legal commercial trade in ivory, even if the regulatory framework includes some provisions in place to restrict commercial trade, aside from very narrow and well-defined exemptions. The analysis should consider relevant ETIS data and information on stockpiles and enforcement.

EIA is further working to ensure that Japan, home to the world’s largest remaining legal domestic ivory market, is included in the analysis. Japan has a massive ivory stockpile of more than 174 tonnes of whole tusks and nearly 76 tonnes of cut pieces and the country has at least 5,500 Government-approved ivory traders. Japan’s robust domestic ivory trade and poor enforcement at its borders make it easy for smugglers to take ivory out, where it is frequently seized overseas in countries such as China which have strong ivory bans in place.


Poaching and the illegal trade in rhino horn remain major threats to Africa’s two rhino species, the white rhino and the black rhino. At SC77, Parties will consider information provided by countries most affected by rhino poaching and rhino horn trafficking (Botswana, China/Hong Kong SAR, Malaysia, Mozambique, Qatar, South Africa, the UAE and Vietnam) on the measures they are taking to respond to these crimes in response to a suite of decisions adopted at CoP19 last November and will make recommendations accordingly.

Two Parties, Malaysia and Vietnam, did not provide any information and while China (including Hong Kong SAR), Qatar and the UAE did provide some details on their initiatives to address rhino horn trafficking, none included information on collaboration with other countries – which was specifically requested of them in the CoP19 decisions.

EIA is calling for SC77 to formally request that China, Qatar and the UAE provide the missing information and to instruct Malaysia and Vietnam to submit their responses the CoP19 decisions by an agreed deadline or risk facing compliance measures.

Finally, EIA is appealing for Parties to urgently provide the remaining funding needed to convene a meeting of the CITES Rhinoceros Enforcement Task Force. This will be the first Task Force meeting in more than a decade and will provide law enforcement officials from Africa and Asia the critical opportunity to meet face-to-face and collaboratively develop strategies to respond to the current state of rhino poaching and rhino horn trafficking.


Investing in Extinction

Pangolins, surprisingly, do not have their own standalone agenda item at SC77. An eventful year since CoP19 has passed, with such milestones as the discovery of a ninth pangolin species and the certification of China by the US under the Pelly Amendment.

However, there are several agenda items to which our Pangolin Campaign will be tuning in. Demand-reduction to combat the illegal trade, stocks and stockpiles, law enforcement in West and Central Africa and Article XIII on the Democratic Republic of the Congo are our main priorities for this meeting.

Along with out Tiger Campaign, we will also be running a side event at SC77 on EIA’s latest report, Investing in Extinction, which reveals 62 banks and financial houses investing in traditional Chinese medicine made from pangolin, leopard, rhino and tiger. This will be our opportunity to campaign directly with CITES Parties to push for the implementation of trade bans for these species.


Totoaba fish are a priority at SC77, with the first review of Mexico’s Compliance Action Plan (CAP). Implementation of the CAP must result in the end of illegal totoaba fishing in the Gulf of California, which is causing the decline of the critically endangered vaquita porpoise. As the most endangered marine mammal on the planet, only about 10 vaquita remain and they are at serious risk of extinction.

The future of vaquita relies on total elimination of gillnets in their habitat, a legal requirement Mexico has so far failed to meet, and the CAP is not robust enough to ensure this is achieved. Further, there are deficiencies in Mexico’s implementation of the CAP, some of which have been identified by the CITES Secretariat (SC77 Doc. 33.13.2 Annex 5).

EIA urges the Standing Committee to require full independent scrutiny and revision of the CAP to ensure it includes all required measures necessary to ensure protection and recovery of the vaquita and that these measures are implemented and enforced without delay.

In addition, EIA calls on all transit and destination countries affected by trafficking of totoaba specimens that have not yet reported, including but not limited to Malaysia and Thailand, to report on their implementation of Decisions 18.292 (Rev. CoP19) and 19.75 to SC77. Furthermore, for all transit and destination countries affected by trafficking of totoaba specimens to increase efforts to ensure prevention of trade.

Wildlife crime enforcement support in West and Central Africa

Wildlife Crime Enforcement support in West and Central Africa

Since CoP18 in 2019, the region of West and Central Africa has drawn attention from Parties for its significant role in wildlife crime. This is exemplified by vast quantities of elephant ivory, pangolin scales and other CITES specimens trafficked within and from the region to Asia.

Because countries cannot effectively tackle wildlife crime in isolation, a set of decisions was adopted at CoP19 in Panama calling for enforcement support and increased collaboration from Parties, inter-governmental organisations and NGOs to combat wildlife crime in West and Central Africa. To assist relevant stakeholders in better understanding the implications of the decisions, EIA produced a report providing detailed analysis and guidance on implementation.

At SC77, EIA will urge the Standing Committee to clarify the scope and the Parties affected by the decisions, since there are some 180 countries importing CITES specimens from the West and Central Africa. EIA will also call for the increased use of existing INTERPOL and World Customs Organization mechanisms to strengthen international law enforcement cooperation between Parties in West and Central Africa and those Parties importing CITES specimens from the region.

Importantly, many funding opportunities exist to support enforcement against illegal wildlife trade and the Secretariat is encouraged to make sure such funds are available to accessible by Parties affected by the decisions.

Asian big cats

Application of Article XIII in Laos

The CITES compliance process is taking place in relation to Laos for, among other reasons, its failure to control and phase out tiger farms in the country, which the Government had committed to convert to zoos in 2016.

Based on a mission to the country, the Secretariat has raised serious concerns about the power of the Laotian authorities to conduct inspections of captive tiger-facilities. Laos has also not been able to demonstrate compliance with other long-standing Standing Committee recommendations, including on fundamental issues such as national legislation to implement CITES.

The Secretariat has highlighted that very limited efforts are being taken to combat illegal wildlife trade in the country, despite significant support being provided. EIA will be encouraging the Standing Committee to adopt the Secretariat's recommendation to suspend commercial trade in CITES-listed species with Laos and the other recommendations in paragraph 38 of SC77 Doc. 33.10, with suitable amendments to ensure that any captive breeding of identified pure specimens of Indo Chinese tigers is not conducted by the current captive tiger facilities which have links to criminal enterprises.

CITES Big Cats Task Force

SC77 Doc 39.3 presents the outcomes of the CITES Big Cats Task Force meeting held in Entebbe from 24-28 April 2023, in which EIA participated.

EIA supports the adoption of the recommendation in paragraph 10.b of the document encouraging implementation of the task force outcomes by affected Parties. However, we will be urging the Standing Committee to reject consideration of a common CITES resolution for all big cats as it is premature at this stage.

The current ABC resolution (RC 12.5) applies to only Appendix I species and contains recommendations on subjects such as domestic markets, stockpiles and eliminating use of parts and derivatives in traditional medicines. It is not clear how these recommendations will apply to an Appendix II species such as lions nor whether a common resolution will result in dilution of these recommendations.

A common resolution for big cats would also necessarily first involve agreement on what recommendations are appropriate for jaguars, cheetahs and lions, given that none of these species have specific resolutions applicable to them.

The Secretariat's report on ABCs

In SC77 Doc. 41.1, the Secretariat reports on implementation of the ABC resolution and associated decisions except for the matters relating to ABCs in captivity, for which there is a separate document.

Disappointingly, only nine Parties – including five Asian big cat range States – responded to the Secretariat’s notification seeking the relevant information. Some of the responses by Parties are contradicted by information that is well known and readily available. For example, China's assertion that it tightened control measures for tiger products in 2018 is contradicted by a 2018 State Council Order which permits the use of tiger bones from captive-bred sources for medical research and clinical treatment of critical, acute or complex illnesses. EIA has also documented the online display of at least three medicinal products stated to contain tiger bone and bearing National Medical Products Administration of China permit numbers.

A lack of reporting and accurate information has been a consistent problem for many years for ABCs and there is a need to explore constructive solutions to this. EIA supports the adoption of the recommendations in the document, but will urge the SC to seek further information on the implementation of Decisions 18.100, 18.101, 18.105 and 18.106 and consider a process by which an appropriate expert body reports on the implementation of ABC recommendations for future CITES meetings.

ABCs in captivity

In SC77 Doc. 42.2, the Secretariat reports on the missions it conducted to five of the seven Parties with captive tiger facilities which may be of concern.

A few key observations from these missions are that there is serious concern about the ability of Laos to conduct inspections of facilities, there is a risk of specimens entering illegal trade from facilities with large numbers of tigers and no sustainable income and most of the tigers kept in facilities in Laos, Vietnam and Thailand do not seem to have any intrinsic conservation value. Missions are yet to take place to the USA and China and the latter has yet to invite the Secretariat to conduct a mission.

China has also reported there are no commercial breeding facilities for tigers in the country, a claim contradicted by various sources of information. In December 2013, China reported to CITES that there were more than 5,000 captive tigers in the country, mainly held in two facilities. As recently as 2018, Species 360, commissioned by the Secretariat, estimated that 6,057 captive tigers, amounting to almost half (48 per cent) of the global captive tiger population, were in China, on the basis of which the Secretariat identified 36 captive tiger facilities in the country which may be of concern.

EIA will be supporting the adoption of the recommendations in the document and will also urge the Standing Committee to encourage China to welcome a mission from the CITES Secretariat and request clarification from South Africa regarding the commercial nature of its captive tiger exports.