Hidden stockpile in Madagascar.

EIA Priorities for CITES CoP18


On August 17th, the world’s governments will convene in Geneva, Switzerland, for the 18th meeting of the Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES CoP18). At CoP18, governments (or “Parties” in CITES parlance) will address the most pressing trade-related conservation issues facing wildlife and plant species around the world. EIA will be at CoP18 working to ensure that protections for threatened species like elephants, rhinos, and rosewood will be strengthened and to hold to account those Parties that have failed to meet CITES requirements.

We’ve highlighted some of our priority CoP18 issues below; our complete detailed position statements on CoP18 species proposals and agenda items can be found here.


Japan and Domestic Ivory Markets
At CoP17, CITES Parties took the historic step to call for the closure of domestic ivory markets that contribute to poaching or illegal trade. While some countries like the United States, China (including Hong Kong SAR), and the United Kingdom have already banned domestic ivory trade, holdouts like Japan and the EU refuse to close their ivory markets.

The reality is that all ivory markets contribute to poaching or illegal trade, and EIA will be urging Parties to further amend Resolution Conf. 10.10 at CoP18 to call for the closure of all domestic ivory markets unequivocally and without qualification.

With the closure of China’s ivory market in 2018, Japan now holds the title for the largest legal domestic ivory market in the world with approximately 17,000 registered ivory manufacturers, wholesalers, and retailers. Japan’s domestic ivory market is riddled with loopholes and has been increasingly linked to illegal ivory exports, primarily to China. At the same time, Japan has failed to step up enforcement and has made only superficial reforms to its domestic ivory trade regulations. EIA encourages CoP18 to direct Japan to close its domestic ivory market and to request that Japan produce a National Ivory Action Plan as part of its commitment to market closure.

International Trade in Elephant Ivory
International trade in elephant ivory was banned by CITES in 1989, and Parties will once again debate whether to lift the ban at CoP18. Burkina Faso and nine other Parties on behalf of the African Elephant Coalition (AEC) have submitted a proposal to place all African elephant populations on CITES Appendix I to extend the highest levels of international protections to populations in all countries across their range. Currently, all populations are on Appendix I except those in Botswana, Namibia, South Africa, and Zimbabwe, which are on Appendix II. The Appendix II listing for these populations include an annotation that allows trade in live animals and some elephant products such as skin and hair, but not ivory. The AEC proposal would prohibit commercial trade in all elephant products from all African elephant populations.

A competing proposal submitted by Botswana, Namibia, and Zimbabwe would instead rescind the international trade ban to allow legal trade in ivory from their and South Africa’s elephant populations, despite the fact that the Monitoring of Illegal Killing of Elephants report for CoP18 detailed an increase in the proportion of illegally killed elephants for Southern Africa since 2016. Separate reports have also described an increase in the number of poached elephants in Botswana since at least 2017.

A third elephant proposal has been submitted by Zambia, which is also seeking approval to trade ivory by downlisting its elephant population from Appendix I to Appendix II. EIA notes with concern that Zambia continues to be implicated in large-scale movements of ivory, and that at least 12 tons of ivory have been seized in Zambia since 2010, representing at least 1,785 elephants.

Legalizing international trade in ivory would have devastating consequences for elephants, as was the case before 1989 and in the aftermath of the two CITES-approved ivory auctions in 1999 and 2008. Africa’s elephant population declined by more than 111,000 between 2006 and 2015, and today elephants continue to be poached at unsustainable levels to supply the illegal ivory trade. EIA strongly opposes reopening trade in ivory and urges CoP18 to uphold the international ivory trade ban.


International Trade in Rhino Horn
African rhinos continue to suffer under immense poaching pressure as a result of demand for their horn in countries like China and

 Southern white rhinoceros (Ceratotherium simum simum) in Kruger National Park, South Africa. Southern white rhinoceros (Ceratotherium simum simum) in Kruger National Park, South Africa. Photo credit: Lisa Grossman

Vietnam, where rhino horn is consumed for its perceived medicinal properties or carved into jewelry and other trinkets. By the end of 2017, the continental white rhino population had been reduced by 15 percent in the span of just five years to an estimated 18,000. Much of this decline can be attributed to poaching in Kruger National Park, the stronghold for the world’s white rhinos, which lost more than half of its white rhino population during this time period.

Despite the ongoing poaching crisis, two proposals have been submitted to CoP18 that would weaken protections for rhinos. Eswatini (formerly Swaziland) is seeking to lift the international rhino horn trade ban to permit legal commercial trade in rhino horn from its population of white rhinos, which consists of just 66 animals. Not only is it impossible for this small rhino population to produce enough rhino horn to meet consumer demand, the proposal fails to account for the significant increase in demand that would be unleashed by legalizing rhino horn trade and provides scant details about how poached rhino horn would be prevented from being laundered through a parallel legal market.

Namibia has submitted a proposal to downlist its white rhino population to Appendix II, limiting trade to live animals and hunting trophies. Namibia is still experiencing troubling levels of rhino poaching and has faced challenges securing convictions for criminals accused of poaching and illegal trade in rhino horn. Moreover, trade in live rhinos and hunting trophies for non-commercial purposes is already possible under the current Appendix I listing and occurring with respect to Namibia. While the country’s white rhino population has increased in recent years, its total population consists of just around 1,000 rhinos and much of the population increase can be attributed to rhino imports from South Africa to private reserves in Namibia. Less than one third of Namibia’s white rhinos are found in State-run protected areas. The small white rhino population in Namibia together with a high risk of poaching and illegal trade justifies its current Appendix I listing.

Domestic Rhino Horn Trade
International rhino horn trade is currently prohibited by CITES, however there are no CITES provisions that expressly prohibit domestic trade in rhino horn. Today, rhino horn trade is legal in South Africa, and recent seizures in South Africa and in Asia appear to indicate that this domestic market is contributing to the illegal international rhino horn trade. In China, the primary destination country for illegal rhino horn, a new policy was announced last year to allow rhino horn use for medicinal purposes. While the government has since postponed implementation of this new law, it was never officially repealed and could be implemented at any time. If this were to occur, it could unleash a torrent of demand for rhino horn causing poaching rates to skyrocket.

To address the threat that domestic rhino horn trade poses to the world’s rhinos, Kenya has submitted a proposal to amend Resolution Conf. 9.14 to urge Parties to close all domestic markets for rhino horn and other rhino parts and derivatives as a matter of urgency.

EIA is urging all Parties to uphold the international trade ban in rhino horn and strengthen protections for rhinos by supporting the submission from Kenya calling for the closure of all domestic rhino horn markets.


Wild male saiga antelope (Saiga tatarica) visiting a waterhole at the Stepnoi Sanctuary, Astrakhan Oblast, Russia.Wild male saiga antelope (Saiga tatarica) visiting a waterhole at the Stepnoi Sanctuary, Astrakhan Oblast, Russia. Photo credit:Andrey Giljov

Saiga antelope once numbered in the millions, but today survive at less than 20 percent of their historic abundance across their range in Central Asia and are highly vulnerable to mass die-offs caused by disease outbreaks. For instance, in 2015 a bacterial infection killed more than 200,000 saiga in Kazakhstan, 62 percent of the total population, in only a few days, and a similar disease outbreak in Mongolia in 2016 reduced its already small saiga population to just 5,000 animals.

Saiga horn is widely consumed in East and Southeast Asia for its perceived medicinal benefits, and this demand fuels saiga poaching and illegal trade in their horn. All saiga range states have instituted voluntary bans on trade in saiga horn, so all saiga horn in trade and consumed today is supposed to be derived from stockpiles held by consumer countries such as China and Singapore that should have been acquired before these bans went into effect. However, the current total stockpile figures in consumer countries is unknown, as is the breakdown of pre-Convention specimens and specimens acquired after saiga were listed on Appendix II in 1994. Without regular, accurate assessments of saiga stockpiles there is a risk that illegally-sourced saiga horn can be laundered through these stockpiles as “pre-Convention” specimens.

EIA is encouraging CoP18 to support the proposal submitted by Mongolia and the United States to transfer all saiga populations to Appendix I to ensure international trade does not further contribute to the threats currently facing saiga. EIA is also calling on the major saiga trading countries to declare their stockpile figures and improve stockpile management.


Mukula (Pterocarpus tinctorius)
For years, EIA has documented the illegal and

Mukula in the Miombo woodland region in southern Democratic Republic of the Congo.Mukula in the Miombo woodland region in southern Democratic Republic of the Congo. Photo credit: PremiCongo

unsustainable global rosewood trade and the devastating impact it has on forests and local livelihoods. A study by World Resources Institute and Global Eye submitted to CoP17 found that “Serial depletion of rosewood species across the globe is a real and substantial risk to their survival.” At CoP17, a record number of rosewood tree species were included in CITES Appendix II, including the entire genus of Dalbergia, African Kevazingo (Gibourtia) and West African Kosso (Pterocarpus erinaceus).

However, the same well documented model of trans-border “boom and bust” in the rosewood trade which brought Pterocarpus erinaceus (“kosso”) to the brink of commercial extinction in several West African countries and resulted in its CITES listing, is now playing out for mukula trees in the Central and Southern regions of the continent. This is why Malawi has proposed to include mukula in Appendix II.

As with other rosewoods, the number one destination for mukula wood is China, where it is being turned into high end furniture. Available data shows that Chinese log imports from Zambia for example have been sharply increasing, despite a variety of different bans placed on transport and export of the wood over the years. Data analysis reveals staggering discrepancies between exporting and importing countries: in 2016, Zambia declared log exports of about 3,000m3 for an approximate value of US$900,000, while China declared imports of about 61,000m3 for an approximate value of US$87 million. Field investigations have reported how traffickers routinely pay bribes to government officials and police. In order to effectively fight the illegal harvesting and trade of mukula trees and protect it from becoming commercially extinct, EIA urges all parties to support the listing proposal by Malawi to include mukula in Appendix II.

Mulanje cedar (Widdringtonia whytei)
Mulanje cedar is a conifer of the cypress family endemic to the Mount Mulanje massif in Malawi. It is also the national tree of Malawi. The tree is classified on the IUCN Red List of Endangered Species as “Critically Endangered”. A survey in 2017 found only seven mature individual left in the wild and concluded the species to be practically extinct. One year later, a new survey found no mature individual tree left in the wild. The catastrophic downfall of the Mulanje Cedar can be attributed among others to illegal logging, fire damage and invasive tree species. Since 2007, all logging of the species is illegal. It is estimated that in the last 10 years, 115,000 cubic meters of Mulanje Cedar have been harvested illegally.

Mulanje Cedar with a view across Mulanje Mountain in southern Malawi.Mulanje Cedar with a view across Mulanje Mountain in southern Malawi. Photo credit: Julian Bayliss

As the national tree of Malawi, Mulanje cedar plays a major role in the country’s culture, imagination and social fabric, and its extinction would have consequences far beyond the obvious ecological and economic implications. The government of Malawi has started a major effort to restore Widdringtonia whytei in its natural habitat on Mount Mulanje as well as in commercial plantations, and is expecting to start a sustainable trade from matured planted forests soon. In order to save its national tree from extinction and at the same time enable a strictly controlled and sustainable trade of planted trees, Malawi proposes the inclusion of Mulanje cedar in Appendix II. EIA urges all parties to support Malawi in this effort and to adopt this proposal to save its national tree.

Cedrela spp.
The Cedrela genus represents 17 known tree species throughout Latin America from Mexico to Argentina. The by far most exploited and traded species is Cedrela odorata, also known as Spanish cedar, which the IUCN calls “one of the world’s most important timber species”. Spanish cedar wood has a wide range of uses from cigar boxes and crafts to veneers, moldings and furniture. However, physical and anatomical characteristics of the wood make it extremely difficult to distinguish between different species of Cedrela in trade, so that the genus is often treated as one single species. Illegal logging rates are high in the majority of range states, in particular the largest exporters Peru and Brazil, and uncontrolled overexploitation and illegal logging are the main causes for the overall decline in Cedrela trees. EIA has been documenting the systematic large-scale illegal harvest and trade of cedar and mahogany in Peru in detail since 2012.

Ecuador and Brazil are now proposing to include the genus of Cedrela spp. in Appendix II in order to make its trade legal and sustainable. EIA urges all parties to support this proposal.

Hidden stockpile in Madagascar.Hidden stockpile in Madagascar.
Photo credit: OCCRP

Malagasy precious woods (Dalbergia and Diospyros)
Since May 2013, Malagasy rosewoods and ebony woods have been listed on CITES Appendix II. Nevertheless, illegal logging has continued leading to vast accumulations of rosewood stocks, the whereabouts of many of them are unknown. A CITES Action Plan was first issued in 2013 and subsequently modified over the years, but has still not been fully implemented by Madagascar. The precious trees have become so scarce Madagascar that scientists are now demanding they be moved to Appendix I for full protection.

The most important decision to be taken at CoP18 regarding Madagascar will be to uphold the ban on Malagasy rosewood and ebony trade. Sales of the vast stockpiles that have accumulated over the years would trigger new demand for the extremely valuable wood and increase the pressure on the remaining trees to be logged. Further, Madagascar must finally get serious about fighting corruption and enforcing the law, including prosecuting high-level offenders, who are often connected to the political establishment.

EIA also strongly supports moving Malagasy rosewood trees to Appendix I to give them full protection. An international group of scientists who have recently assessed the status of precious woods in Madagascar concluded that “Moving Dalbergia and Diospyros from CITES Appendix II to Appendix I is the only way out of what has become a vicious circle”. While it will not be possible to do this at the upcoming CoP18, Madagascar, with the support of its international partners, should take leadership by committing to and starting to prepare for the inclusion of its rosewoods and ebonies in Appendix I.

Experience over many years of CITES has shown that the approach to list individual tree species is overwhelmingly inadequate to prevent commercial extinction and combat illegal logging and trade. As soon as one species is listed, traffickers either move to another tree species that looks alike or mis-declare the timber as a different, non-protected species. The cases of both rosewood (Pterocarpus spp.) and cedar (Cedrela spp.) are prime examples that a genus-wide listing that includes all so-called “look-alike” tree species would be more suitable to effectively protect trees, and ultimately, the forests that so many other species, including humans, depend upon.

Banner photo credit: Maggie Dewane