The good, the bad and the ugly

EIA campaigners present their detailed analysis on the decisions made at the recent CITES Standing Committee gathering in Lyon, France.

EIA’s UK and US Wildlife Teams were at the 74th Meeting of the Standing Committee (SC74) to the Convention on International Trade in Endangered Species (CITES), in Lyon, 7-11 March 2022. The meeting was held six months ahead of the next major Conference of the Parties (CoP19), scheduled for November 2022 in Panama, and focused on matters of compliance and enforcement. This was an opportunity for us to raise the alarm over species of fauna and flora at risk from trade and the role of crime and corruption in undermining conservation. There were several key agenda items for which our teams had prepared briefings and, in collaboration with other NGO colleagues, intervened to call for more effective action.

Here’s the run down on the outcomes for Asian big cats, elephants, pangolins, rhinos, timber and totoaba/vaquita.

Since the 1980s, CITES Parties have recognised there are situations where some species require action beyond the scope of the text of the CITES Treaty (i.e. beyond just import, export and re-export). Elephants, rhinos, sturgeon, Tibetan antelope and tigers are just some of the species that have been singled out as needing urgent action within national boundaries. A worrying trend that emerged during the course of SC74 is the push back from some Parties, especially China, against valid CITES resolutions, decisions and recommendations to take necessary action to save some of the worlds most threatened species. For example, EIA is extremely concerned by China and Japan’s repeated assertions that reporting on national seizures of endangered wildlife falls outside the scope of the CITES mandate. Wildlife trafficking involves endangered species entering countries illegally before transportation across the national territory to different end-destinations in that country. We believe seizures at points of entry and throughout the destination country must be reported by all Parties to ensure a comprehensive understanding of trafficking scope and trends.

Members of EIA US and UK at the 74th meeting of the Standing Committee to CITES

Big Cats

Asian big cats

The recommendations of the CITES Secretariat were adopted; encouraging Parties to improve monitoring, inspection and enforcement efforts to stop the leaking of tigers from captive facilities into illegal trade. Disappointingly, the packed agenda meant there was no scope for a Working Group to deliberate on time-bound, country-specific recommendations that could be adopted by this meeting. The SC did however recognise that 11 Decisions relating to tigers and other Asian big cats had not been implemented adequately and should be renewed at the CoP19. Whilst this creates channels for EIA and colleagues to inform the Secretariat and Parties of tiger and other Asian big cat trade, it is depressing that some of the worlds most endangered species still suffer from a lack of urgent attention. On behalf of 21 NGOs, EIA called out some specific actions we wanted Parties to take.

Secretariat tiger missions

Finally, after five years the CITES Secretariat missions to Parties with captive tiger facilities of concern (China, Thailand, Laos, Vietnam, South Africa, USA and Czech Republic), will go ahead thanks to funding from the UK and Four Paws International. The UK also called for relevant experts to be involved in the planning and implementation for the missions, echoing the call from 52 NGOs who had written to the CITES Secretariat proposing a risk-based approach to conducting the missions (see page 14 of the EIA SC74 Briefing). While China said it would welcome a mission, it more or less said that it was no-one else’s business as to what it did with its captive-bred tigers. This runs contrary to the CITES decision on tiger farms from 2007 and is an example of China’s resistance to take domestic action.

Tiger skins and enforcement

Since CoP17, the Government of India has been promoting the use of tiger stripe pattern profiling analysis to support investigations into the origin of tigers in trade. The process has helped India and Nepal collaborate on cross-border trade. All Parties that make seizures are supposed to send images of skins to India and Thailand as the two Parties with stripe pattern databases. Despite there having been over 500 seizures of skins, carcasses, live animals and taxidermy specimens globally since CoP17, only a handful of images from Vietnam have been shared with India. It’s such a low cost way of sharing non-sensitive information that could facilitate enforcement, it is shocking that such little action has been taken by Parties making seizures. At this meeting, the call for a better response was made. Let’s see in a few months who was listening.

Leopards and China’s domestic market

EIA and 20 other NGOs raised the threat to leopards from China as China continues to have a burgeoning licensed trade in leopard bone medicine. This contravenes the CITES Resolution on tigers and other Asian big cats that stipulates that ‘all Parties in whose jurisdiction there is a legal domestic market for specimens of tiger and other Asian big cats species that is contributing to poaching or illegal trade, take all necessary legislative, regulatory and enforcement measures to close their domestic markets for commercial trade in tiger and other Asian big cat specimens’.

However, leopards in China continue to be excluded from trade bans. At  SC74, China stated that all domestic measures should be adopted purely on a voluntary basis, which sets back leopard protection efforts significantly. At the same time, this approach has repercussions for the internationalisation of the traditional Chinese medicine. In 2021, the Norwegian Pension Fund, the largest sovereign wealth fund divested from five TCM companies on posing ‘an unacceptable environmental risk’ to species widely used in TCM, such as leopard.

Big Cat Task Force

The new terms of reference and modus operandi for the Task Force were adopted and the meeting is expected to take place before CITES CoP. EIA has provided information to the preparatory study that is due to be released, looking at a range of cross-over issues for big cats, including convergence in the trade chain and common demand drivers. We will be standing by, eager to join the Task Force to support its deliberations and recommendations.

Laos and trade suspensions

Despite everyone agreeing that Laos has not made adequate progress towards effective enforcement or in phasing out tiger farming and knowing that the delays are not just down to COVID, the country was given another extension under what’s known as the Article XIII, or non-compliance procedure. This means instead of facing trade suspensions for the Government’s persistent failure to act, it will have another chance

to show progress, by early 2023. On behalf of EIA and several other NGOs, Born Free intervened to specifically ask that Laos be required to provide evidence of progress with the following:

  • the establishment of a stripe pattern database for tigers;
  • enhanced collaboration with Vietnamese police to investigate trade in tigers;
  • suspension of tiger breeding of tigers in all captive facilities as a first step to implementing the promised phase out of such facilities;
  • initiating a process of strengthening wildlife farming guidelines to prevent trade in parts and derivatives of captive-bred tigers.



Ivory seizure in Nigeria

Nigeria’s non-compliance has been a recurring topic at CITES meetings for the past 20 years. The country has been subjected to a trade suspension in Pterocarpus erinaceus(under a mechanism referred to as ‘Article XIII’) since 2018 and just before the meeting in Lyon, it was recommended that this trade sanction be broadened to cover all CITES-listed species owing to unacceptably slow progress by Nigeria to tackle ivory and pangolin trafficking. In particular, concerns were raised about Nigeria’s failures to tackle organised criminal gangs behind trafficking; to address corruption amongst key government agencies; to untangle competing mandates of key government agencies tasked with tackling wildlife crime; and to abide by its reporting obligations.

Nigeria’s non-compliance with the National Ivory Action Plan (NIAP) process was also hotly debated in Lyon as grounds for a complete trade suspension under another mechanism (Res.Conf.14.3). The country has failed to provide a single progress report in a timely fashion since 2014 which has hampered the Secretariat’s efforts to analyse trends and resilience to ivory trafficking in the region. Content-wise, Nigeria’s NIAP and belated progress reports have not been satisfactory and include gaping loopholes that, for example, allow ivory to be traded legally in Lagos.

Given that Nigeria is the primary export hub for illegal pangolin and ivory, we lobbied hard for the Committee to impose full trade sanctions on Nigeria at the meeting in Lyon under both Article XIII and Res. Conf. 14.3. However, the Committee instead decided to give Nigeria a stay of execution, giving it until May 10th 2022 to submit a NIAP progress report and requested Nigeria to report on progress to address the array of recommendations made by the Committee by 14th September 2022. In the absence of progress, it is likely that trade suspension will be adopted under Article XIII and Res. Conf 14.3. While EIA welcomes the interventions made by Nigeria at the meeting whereby it reiterated its commitment to CITES and to its desire to align itself with its obligations under the Convention, it remains to be seen whether Nigeria will use its last chance to put words into action. Watch this space.

National Ivory Action Plan process

Unfortunately, EIA’s view that Vietnam has not overall made ‘’partial progress’’ in its NIAP implementation was not heeded by the Committee. As reported in a recent briefing, we believe serious gaps in the Party’s progress report remain, including a marked absence of prosecutions for ivory or pangolin scale seizures at seaports and a lack of international cooperation to conduct intelligence-led investigations into organised criminal syndicates trafficking wildlife. As we look to CoP19, we will continue to prioritise Vietnam as a key country involved in illegal ivory and rhino horn trade and will call for appropriate measures to be taken should Vietnam fail to address its role as a leading destination for endangered wildlife.

EIA also made an intervention on behalf of 11 NGOs to draw attention to the fact that, nearly a decade since its inception, it is high time that the NIAP process undergoes a robust review to ensure it is still fit for purpose. This is especially critical given that several countries are required to report against completely outdated action plans which may no longer be accurate or proportional to their evolving roles in ivory trafficking. Ahead of CoP19, we will seek support for a review to ensure the NIAP process does not duplicate existing mechanisms under CITES that already address enforcement and compliance matters relating to ivory trafficking and we will also call for greater use of existing tools and sources of data such as the ICCWC Framework and Toolkit. We believe without a review, the NIAP process risks straying from its original purpose, becoming burdensome for Parties and the Secretariat.

Ivory stocks and stockpiles

Ivory stockpiles held by Governments are a serious threat to elephants through leakage of ivory onto the illegal trade as thefts from stockpiles are frequent, fuelling demand and perpetuating ivory’s status as a marketable commodity. The thefts and illegal sales of ivory from stockpiles usually involves corruption and international criminal networks and EIA welcomed the strong interventions made by Gabon, Kenya and Ethiopia reminding the Committee that stockpiles need to be accounted for in a transparent, secure and consistent manner. Along with a number of our partner NGOs, we expressed concern that 44 countries, including NIAP countries, who hold ivory stocks have never reported on their inventories and called on them to do so as a matter of urgency. Given the level of non-reporting and the importance of stockpile data, we were therefore pleased that the Committee reiterated requests to Parties to step up their efforts to comply with stockpile reporting obligations. Looking forward to CoP19, we will work to ensure that this critical topic remains on the table to ensure a holistic response to elephant poaching and ivory trafficking.

Closure of domestic ivory markets

Discussions at SC74 demonstrated that support for the closure of domestic ivory markets remains strong among most CITES Parties. While the CITES Secretariat had prematurely recommended the deletion of the decision directing Parties that had not closed their ivory markets to report on measures they are taking to ensure that those markets are not contributing to poaching or illegal trade, SC74 firmly rejected this recommendation and endorsed the calls from Burkina Faso, Gabon, the US, the UK, the EU, Israel, and China to instead renew the decision at CoP19.

A number of Parties, including the US and Gabon, emphasised the role that legal domestic ivory markets play in contributing to illegal trade. Burkina Faso referenced an information documentsubmitted by Senegal and Liberia to describe how Japan’s legal domestic ivory market, which with an estimated 244 tonnes of legal stockpiled ivory is the largest legal domestic market in the world, is contributing to the illegal international trade. A joint briefing for SC74 prepared by EIA and the Japan Tiger and Elephant Fund reviews the myriad of problems with Japan’s domestic ivory controls.

Despite the widely available evidence that Japanese ivory is being trafficked abroad, Japan maintains the view that its ivory market does not contribute to illegal trade and is therefore in line with CITES provisions on domestic market closure. However, EIA has documented more than 70 seizures of ivory from Japan made by China’s authorities between 2018-20, which indicates that Japan’s legal market is contributing to the international illegal trade. In what will hopefully remove any shred of doubt, SC74 agreed to a proposal by the EU to have the Elephant Trade Information System (a CITES initiative to monitor illegal ivory trade) report that is submitted to CoP19 include an analysis of ivory seizures connected to Parties with legal domestic ivory markets, if feasible.


Under Agenda Item 73 on pangolins, the SC accepted comments from Parties to encourage species-levelidentification and reporting of seized pangolin specimens, as well as the urgent establishment of stricter controls in securing stockpiles of pangolin derivatives. The acceptance of these comments could prove instrumental in identifying vulnerable pangolin populations and informing targeted enforcement and demand reduction efforts. Additionally, the implementation of more stringent stockpile management measures could reduce the laundering of illegally sourced pangolin derivatives.

While other comments were not taken on board, attention was brought to important concerns surrounding legal markets fuelling illegal poaching, international trafficking and laundering of pangolin specimens. An intervention by the Animal Welfare Institute made on behalf of 15 observer organisations, including EIA, called for the closure of domestic markets, offered specific measures for stockpile management and encouraged increased enforcement efforts and novel demand reduction activities. However, this intervention was disappointingly not accepted.

Despite the positive strides taken on species identification and general controls for stockpiles, the root causes for pangolin trafficking, namely legal markets, demand and specific stockpile management measures, failed to be addressed at this meeting of the SC. Countries operating legal markets with undeclared amounts of stockpiles continue to remain responsible for international demand, enabling and encouraging the exploitation of already threatened global pangolin populations.

In the run-up to CoP19 in November, EIA will carry on active engagement with CITES Parties and collaboration with stakeholders to raise awareness of the threats facing pangolins, establish novel demand reduction activities and finally, campaign for the closure of legal markets and eventual destruction of domestic stockpiles supplying said markets.


During the discussion on the rhinoceros agenda item, Kenya intervened to remind Parties that despite theimportant actions underway to protect rhinos from poaching and prosecute rhino horn traffickers, poaching and illegal trade remain very serious issues in source and consumer countries. Kenya further recognised that it would be especially beneficial to bring law enforcement experts together again to create new strategies and actions to protect rhinos, and called on the SC to recommend that CoP19 reconvene the CITES Rhinoceros Enforcement Task Force. The US also expressed support for reconvening the Task Force, noting it has been nearly 10 years since it last met. The SC subsequently agreed to propose a decision to CoP19 to reconvene the CITES Rhino Enforcement Task Force subject to available funding.

India took the floor to share the conservation and enforcement actions it has taken to protect greater one-horned rhinos, including highlighting the destruction of nearly 2,500 rhino horns last year. India also recommended, and the SC agreed, to propose that CoP19 renew the CITES decision directing parties to close rhino horn markets that contribute to poaching or illegal trade and implement demand reduction programs, and to amend the decision to include timebound reporting requirements to ensure relevant Parties report on implementation.

EIA gave an intervention on behalf of 15 conservation organisations to support the proposals made by Kenya, the US, and India and to bring the catastrophic increase in rhino poaching in Botswana to the attention of all Parties. While no action was taken on Botswana at SC74, this is issue is likely to receive increased attention at CoP19 in November.


Rosewood in West Africa

Rosewood concealed in water tanker © EIA

The Standing Committee took unprecedented strong action to protect West African rosewood (Pterocarpus erinaceus) from illegal and unsustainable trade.

EIA has repeatedly documented how the rosewood crisis has been devastating West African forests and communities’ livelihoods for almost a decade. After investigating scandals in countries such as Senegal, Nigeria, The Gambia, or Ghana, we have shown here most recent explosion in illegal rosewood logging and trade in Mali.

Illegal and unsustainable trade in rosewood from West Africa has persisted despite the species listing on CITES Appendix II, which came into effect in 2017. A report submitted by Senegal shows persisting illegal trade through criminal networks who continue to evade harvest and export bans, and range states therefore called on CITES for solutions at a regional level.

In response, the Standing Committee took decisive steps to address this crisis and protect West African forests and the people and ecosystems that depend on them. A compliance procedure including all range states will be started immediately, and the CITES Secretariat will be issuing a notification to all Parties, according to which range States will have 30 days to demonstrate that their exports are legal and sustainable or set a zero export quota. If countries fail to do so, they will face a trade suspension and importing countries can no longer accept shipments of the precious rosewood from West Africa. In addition, all export permits for Pterocarpus erinaceus rosewood will need to be verified by the CITES Secretariat prior to acceptance by importing countries.

This is a truly remarkable outcome and a huge step towards protecting the world’s most trafficked wild product and stopping the illegal trade of rosewood from West Africa, not over the course of years, but in a matter of weeks.

Madagascar rosewoods, palisanders and ebonies

The SC agreed to maintain the suspension in precious woods Diospyros and Dalbergia spp. from Madagascar until Madagascar has made a legal acquisition finding and a non-detriment finding for these species on a national level to the satisfaction of the Secretariat. A renewed discussion arose around the vast timber stockpiles n Madagascar, which have been subject to theft and smuggling over the years.

Although Madagascar stated that the seized, or so-called “controlled” stockpiles would be for domestic use, rather than exports, and the Secretariat stated that then CITES no longer had any oversight, the SC agreed to recommend maintaining and amending paragraph f) of Decision 18.96, which requires Madagascar to “secure the stockpiles (including undeclared and hidden stocks) of timber of Dalbergia and Diospyros in Madagascar, and submit regular updates on audited inventories and independent oversight mechanisms, for consideration, and further guidance from the Standing Committee;”

The other decisions from CoP18 on Madagascar were not, however, recommended for renewal at CoP19. Together with our partner Transparency International Madagascar, we have documented in our recent paper how the prevailing opacity and corruption in the country continues to enable high level traffickers, and how even the use of the so-called “controlled” stockpiles is plagued by irregularities.  We will work with partners in Madagascar and Parties to ensure that key provisions are included in the decisions at CoP19 in order to prevent the laundering and illegal trade of the stockpiles, which could enable further illegal logging in the country’s rainforests.

Vaquita and totoaba

On the second day, the Standing Committee considered a report from the Secretariat which assessed theactions taken by Mexico to comply with CoP Decision 18.293, which requested that Mexico implement seven actions to address the illegal fishing and trafficking of totoaba. The Secretariat’s report acknowledged continued illegal fishing, noting that “… the continued presence of fishers in the vaquita refuge and zero tolerance area is the single most important factor that significantly undermines the efforts of Mexico and the progress made by Mexico on other fronts.”

Despite this, calls from the US, Senegal and Israel for a suspension of trade in CITES-listed species from Mexico in response to its lack of compliance from Mexico were not supported by the other Standing Committee members. Instead, a series of recommendations drafted by the Secretariat were agreed, including additionally a request for the Secretariat to undertake a second mission to Mexico to evaluate progress.

More bad news followed two days later, when the Standing Committee agreed to allow Earth Ocean Farms (EOF), an aquaculture facility in Mexico, to engage in trade of captive-bred totoaba fish, opening up international totoaba trade for the first time in almost 50 years.

Although Mexico and Earth Ocean Farms committed to temporarily prohibiting the export of totoaba swim bladders and destroying stockpiled maws, these amendments to its application should have triggered submission of a new request under CITES procedures. EIA and partners, and the US, Israel and Senegal, strongly opposed the EOF application, putting forward multiple procedural and conservation arguments, including the major concern that a legal trade in captive-bred totoaba will provide cover for the illegal wild-sourced totoaba trade that has brought the vaquita to the very edge of extinction. Of the 15 voting committee members, Senegal, Congo, Peru, Israel and Australia voted to reject the EOF application, but were outvoted by the remaining members, including European members Poland and Belgium, while Canada abstained.