Highlighting EIA’s illegal trade concerns for wildlife and trees at CITES Standing Committee

This year is a big one for the Convention on International Trade in Endangered Species (CITES), with the 78^th meeting of the Standing Committee (SC78) kicking off in Geneva, Switzerland from 3-8 February.

This will be followed by the much larger 20^th Conference of the Parties (CoP20) in Samarkand, Uzbekistan later in the year.

EIA will be actively engaging at SC78 on a range of key issues relating to the protection of elephants, rhinos, Asian big cats, pangolins, vaquita porpoises and trees, in addition to broader compliance and enforcement issues.

A summary of EIA’s priorities can be found below; for more detailed comments and recommendations, read our SC78 briefing.

 

Elephants

 

Asian elephants

SC78 will be the first time EIA engages on the illegal parts and derivatives trade threat facing Asian elephants at CITES.

A 2019 study was the last known assessment of this illegal trade. However, recent findings by EIA indicate a notable rise in online sales of elephant skins and other parts in the Greater Mekong Subregion from 2022-24.

The current extent of these illegal activities remains unclear, aggravated by consistently low reporting rates by Asian elephant range states and CITES Parties involved, leaving stakeholders with an inadequate understanding of the issues and the effectiveness of interventions.

As such, we do not support the Secretariat’s proposed recommendation to delete key Decisions relating to trade in Asian elephants. These Decisions should be renewed, subject to our proposed amendments aimed at strengthening the monitoring of illegal trade, including conducting a systematic study and enforcing stricter criteria regarding the disposal of elephant carcasses to mitigate opportunities for illegal trade.

To raise awareness of the findings from our monitoring of the online trade in Asian elephant parts and derivatives, EIA has prepared a stand-alone briefing with key recommendations.

 

National Ivory Action Plan process

The National Ivory Action Plan (NIAP) is a key CITES tool for elephant conservation whereby countries identified as affected by ivory trafficking must develop and implement a plan to target and improve their responses to ivory trafficking.

EIA has taken a leading role in monitoring both progress made by NIAP Parties and the overall effectiveness of NIAPs, successfully leading the call for a review of the process at CoP19. Progress on the review as reported to SC78 is largely welcomed, although we are concerned about the limited adoption of the recommendations to the NIAP Guidelines by the Secretariat, with a focus on the short-term.

As such, we have proposed strengthened amendments to the Guidelines to better reflect the findings. Regarding the Secretariat’s assessment of NIAP Party progress, we agree that Cambodia and Malaysia should exit and that Angola remains in the process.

To better guide Parties in the NIAP deliberations, we have prepared a stand-alone briefing on the NIAP country progress reports with key recommendations.

 

Domestic ivory markets

Since 2016, countries have agreed to the CITES recommendation to close domestic ivory markets contributing to poaching or illegal trade urgently.

At SC78, domestic ivory markets will be up for discussion, including on decisions intended to support the implementation of Resolution Conf. 10.10 (Rev. CoP19) paragraph 5, which “urges those Parties in whose jurisdiction there is a legal domestic market for ivory that is contributing to poaching or illegal trade and that have not closed their domestic ivory markets for commercial trade in ivory to implement the above recommendation as a matter of urgency.”

EIA proposes that the Standing Committee recommends that CoP20 renews decisions to hold Parties that choose to maintain legal domestic ivory markets accountable by requiring them to report on measures they are taking to ensure their legal domestic ivory markets are not contributing to poaching or illegal trade.

Additionally, EIA also recommends that an analysis of ivory seizures related to open ivory markets be pursued – while the path needs to be identified, exploring the relationship between existing domestic markets and illegal trade is important for identifying areas for action. EIA believes an analysis of ivory seizures related to legal domestic ivory markets is feasible, important and that there are viable paths forward.

EIA urges the Standing Committee to establish an intersessional working group to options for conducting the analysis. EIA remains concerned about Japan’s legal market for the commercial trade in ivory and urges prioritising the inclusion of Japan in the analysis of ivory seizures connected to Parties with legal domestic markets.

Other key agenda items we will be following include the Taxonomy and Nomenclature of African elephants (Loxodonta spp.) and the Dialogue Meeting for African elephant range states.

 

Rhinos

 

Reducing demand for rhino horn is essential to protect wild rhinos from poaching and the illegal rhino horn trade. This is why CITES Parties banned international trade in rhino horn, adopted a Decision directing countries with illegal markets for rhino horn to develop target demand reduction programmes and enshrined similar demand-reduction directives in the CITES Resolution on rhino conservation and trade issues.

Given the clear CITES obligations for Parties to reduce demand for rhino horn, EIA is concerned about recent developments in South Africa which point to a concerted effort to develop a commercial market for rhino horn products aiming to increase demand.

During the past few months, a suite of private and public proposals for rhino horn trade in South Africa, including a draft Government plan calling for creating a market with rhino horn products such as medicines aimed at Asian tourists, have come to light.

These proposals could spell disaster for rhinos by kicking off a wave of demand and poaching if implemented. EIA is urging the Standing Committee to provide oversight on these developments by directing South Africa to share more information on its commercial trade plans, including how these processes will avoid an increase in demand, illegal killing and enforcement complications.

EIA is also calling on the Standing Committee to direct Parties which did report on their implementation of rhino decisions and recommendations – China, Mozambique and Namibia – to provide reports on their efforts to address rhino horn trafficking and poaching.

China is the primary destination for rhino horn trafficked out of Africa and Asia and its engagement in CITES processes aimed at tackling the ongoing poaching and trafficking crisis affecting rhino populations globally is paramount. Namibia continues to experience high levels of rhino poaching, especially of the Critically Endangered black rhino.

Without information from these Parties, the Standing Committee will not have the best available information on which to base its decisions and recommendations. If these Parties fail to provide reports, EIA is urging the Standing Committee to consider appropriate compliance measures.

 

Pangolins

 

Pangolins continue to be at risk from illegal poaching and trafficking, with at least 15 tonnes of pangolin seized globally in 2024, an estimated three tonne increase on figures from 2023.

The countries with the largest quantity of seizures were Nigeria and Indonesia, of which neither reported details of their stockpiles and stockpile management to the CITES Secretariat following a Notification in 2024.

EIA further expresses concerns regarding the implementation of the pangolin Resolution, especially relating to China’s legal domestic market. In 2024, China released a notice confirming that pangolin scales will continue to be permitted for traditional Chinese medicine production, with an annual control of approximately one tonne.

While this reflects some progress in transparency, it still begs the question as to where these pangolin scales are sourced, given that China claims it does not use scales from unknown or illegal origins. With China highlighted in the United Nations Office on Drugs and Crime (UNODC) World Wildlife Crime Report as one of the main destinations of pangolin scale shipments and having not publicly reported on its stockpiles, EIA urges for China to practice transparency and compliance with the pangolin Resolution.

EIA will be encouraging Parties to report in accordance with the pangolin Resolution and its associated Decisions, which includes annual reporting on trade, seizures and markets as well as stockpiles.

We support the alignment of pangolin stockpile reporting with that of ivory and rhinoceros horn and further encourage the CITES Secretariat to develop time-bound and measurable recommendations for consideration at CoP20.

 

Totoaba/vaquita

 

Despite Mexico’s implementation of a CITES Compliance Action Plan (CAP), it continues to fail to halt illegal totoaba fishing within vaquita porpoise habitat in the Upper Gulf of California. The gillnet fishing results in vaquita bycatch and trafficking of totoaba swim bladders.

Totoaba are listed on Appendix 1 of CITES and implementation of the CAP will be a subject of discussion at the SC meeting.

Despite the ban, gillnet fishing continues, both to some degree within the core Zero Tolerance Area and, significantly, within the broader Vaquita Refuge. Vaquita are critically endangered because of fisheries bycatch and the population is rapidly spiralling towards extinction – only 6-8 individual animals were observed during a 2024 survey.

EIA documented the ongoing illegal transnational trade in totoaba swim bladders on social media platforms in our 2024 report, On Borrowed Time, also highlighting the decline in enforcement action in 2023, as measured by the number of totoaba swim bladder seizures.

Mexico’s implementation of the CAP is inadequate, given the urgency of the situation. Mexico is failing to enforce the CITES ban on commercial export of totoaba. Vaquita recovery is possible, but only if Mexico enforces its environmental laws concerning the protection of the species and eliminates the use of gillnets in vaquita habitat.

Given these concerns and the immediate threat of extinction to vaquita, EIA urges the Standing Committee to consider trade sanctions as a necessary next step.

 

Asian big cats

 

Application of Article XIII in Laos

Laos is currently subject to a suspension of all commercial CITES trade due to a range of issues affecting the country, including inadequate CITES implementing legislation, insufficient enforcement action to tackle illegal trade and the presence and growth of tiger and other wildlife farms which do not comply with CITES recommendations.

The Secretariat has recommended that this suspension should continue to apply to the country.

The Secretariat reports that Laos is yet to implement a number of measures relating to tiger farms, as required. Despite the ongoing spotlight on the country, a new facility was set up in 2023 which appears to be breeding tigers for trade. This has occurred even though, in May 2018, the Prime Minster of Laos prohibited the establishment of wildlife farms for Appendix I species for business purposes.

The Secretariat has assessed Laos’ legislation as meeting the minimum criteria to satisfy implementation of CITES; however, EIA’s assessment is that there continues to be material gaps in CITES implementation.

EIA will be encouraging the Standing Committee to adopt the Secretariat’s recommendations with a modification to ensure that the current tiger farms in Laos, which are purely commercial in nature and have been linked to criminal enterprises, are not entrusted with conservation breeding of Indochinese tigers.

We will also be encouraging the Standing Committee to continue to monitor any remaining gaps in Laos’ legislation as part of the compliance process.

 

CITES Big Cats Task Force    

It’s not just tigers and other Asian big cats that are at risk from demand-driven poaching and trafficking – cheetahs, jaguars and African lions face similar threats.

EIA participated in the CITES Big Cats Task Force meeting in 2023, where measures to address trade, legal protection, enforcement and demand-reduction were adopted in the outcome report.

We will be encouraging the Standing Committee to propose that the draft decisions suggested by the Secretariat are adopted by CoP20. These decisions would enable the CoP and the Standing Committee to monitor implementation of the outcome of the CITES Big Cats Task Force meeting.

We are encouraged by the development of both CatByte and the International Big Cat Alliance and urge Parties to engage with these initiatives to strengthen implementation of CITES recommendations on big cats.

 

The Secretariat’s report on Asian big cats   

Over the past several years, with a few notable exceptions, the resolutions and decisions relating to Asian big cats have been affected by low numbers or non-specific responses by relevant Parties.

The trend continues for this meeting, with the Secretariat’s report not containing a meaningful analysis or recommendations on the issues addressed by the decisions currently in force. Particularly regarding the conservation status and illegal trade of leopards, on which the Standing Committee has requested information, the report does not refer to the wide range of information available, such as seizure data in the UNODC World WISE database.

Leopards are the Asian big cat species most frequently recovered in seizures and have disappeared from large parts of their range in South-East Asia over the past two decades. EIA will be advocating for the Standing Committee to encourage Parties to report on the conservation status, legal and illegal trade of Asian leopards, not just so this can be reviewed as part of the CITES process, but to drive more targeted and effective action to prevent further decline.

The consistent poor reporting for all Asian big cat species not only results in an incomplete picture of trade threats and responses, but also means opportunities to encourage and support timely and targeted interventions are being missed.

EIA will be encouraging the Standing Committee and the upcoming CoP20 to adopt a regular review mechanism for Asian big cats similar to that in place for rhinos.

 

Asian big cats in captivity

The Secretariat has now completed missions to all seven countries identified as having facilities keeping or breeding tigers which may be of concern and at SC77, the Standing Committee made country-specific recommendations to the Czech Republic, South Africa, Vietnam, Thailand and Laos. For SC78, the Secretariat has reported on its missions to China and the USA.

The Secretariat reports that there are 2,744 captive tigers in China. This number is a significant variation from the report commissioned by the Secretariat in 2018, which estimated there to be 6,057 captive tigers in the country and, from China’s own previous reports to CITES, that there were more than 5,000. No reasoning has been given for this decline and EIA will be encouraging the Standing Committee to seek clarification.

We will also be highlighting inconsistencies, in our view, which have been reported in China’s legislation regarding tigers along with concerns about the stockpiling of body parts of deceased captive tigers and will be recommending that the Standing Committee ensures there are country-specific recommendations for all concerned Parties and that implementation of these is reported on beyond CITES CoP20.

 

Forests

 

For decades, EIA has spotlighted how the illegal trade of highly endangered tree species, including the iconic Dalbergia cochinchinensis and other rosewoods, are being harvested to the brink of extinction.

Our successful campaign in 2017 led to the entire Dalbergia genus being listed under CITES Appendix II. After a brief hiatus, we are returning to CITES to present evidence on the implementation of this listing, focusing on Indonesian sonokeling (Dalbergia latifolia).

We will highlight an imminent report by our Indonesian partner Kaoem Telapak (KT), which reveals significant gaps and ongoing issues with illegal logging and international exports of Dalbergia latifolia. These exports are sourced from both wild and artificially propagated stands, whose distinction is often ambiguous. Additionally, inconsistent trade data raises concerns that raw or unrefined timber could be laundered under the finished products exemption.

We support the Secretariat’s report on the topic recommending further work is still needed. Alongside this, we will closely monitor all other agenda items related to CITES-listed timber species, including compliance issues concerning Malagasy populations of ebonies and rosewoods (Diospyros spp. and Dalbergia spp.).

 

 Wildlife crime enforcement support in West and Central Africa

 

Wildlife crime continues to threaten biodiversity in West and Central Africa, where species are trafficked at alarming rates. There remain key challenges in enforcing wildlife crime laws and a need for stronger collaboration between source, transit and destination countries.

The Working Group formed to discuss enforcement issues in the region reported disappointingly low participation in actions to combat wildlife crime. Only three Parties responded to a questionnaire on funding issues and virtual meetings saw minimal attendance, including from the most affected regions.

This lack of engagement hindered progress on improving cooperation and funding. While funding is critical, Parties are urged to leverage existing resources rather than create new enforcement funds.

Tackling wildlife trafficking requires robust international collaboration, but existing tools such as secure channels from INTERPOL and the World Customs Organization (WCO) are underused. For example, despite the confiscation of 10 tonnes of ivory shipped from Nigeria and Angola to Vietnam between 2023-24, there has been little cooperation to dismantle smuggling networks. A long-delayed Memorandum of Understanding between Nigeria and Vietnam also underscores the need for stronger bilateral commitments.

Furthermore, illegal trade in CITES-listed tree species, such as West African rosewood, remains a major issue. Many countries fail to meet sustainable trade standards, drawing continued scrutiny under CITES compliance mechanisms. Closing these gaps is vital to preserving vulnerable ecosystems.

Given these remaining issues, we do not support the Secretariat’s recommendations to delete key decisions on combating wildlife crime in the region. These Decision should be renewed and updated to strengthen commitment and compliance by Parties, particularly the use of INTERPOL and WCO services, with these organisations reporting on interactions to future CITES meetings.