Imagine we live in a world that when a pharmaceutical company creates a new drug it doesn’t have to test it in the lab, it doesn’t need to do human trials and it doesn’t need regulatory approval; it is simply manufactured and then legally sold.

Once on the market the drug appears to have some terrible side effects and consequences. The groups concerned about the negative effects of this new drug on human lives must scrape together funding, from donors, to undertake research to show their concerns are valid. Each year data is collected from all regions of the world highlighting the negative side effects of the drug together with the number of direct and indirect deaths associated with the drug. This is done for each demographic who uses the drug, including: men, women, children and teens, senior citizens, pregnant women, people with a disability, people with mental health issues etc.

When these concerned parties present their findings about the negative effects of the drug, they are challenged to provide evidence upon evidence upon evidence to back up their concerns, yet the pharmaceutical company isn’t held to the same standards to provide evidence that the drug is safe.

Imagine further that the system that monitors the volume of trade and distribution of this drug (and all drugs) is a paper-based, doesn’t integrate with customs, has been reviewed once in 44 years (in 1994) and has been constantly shown to have flaws that you can drive a Mack Truck through.

On top of this, everyone gets together to review what has been happening in the trade only once every three years. Trends on the negative side-effects of the drug and the mortality rates are tabled. There are clear indications that the trade in this drug is not safe for humans, but the only result is that another 3 years of research is requested, before a decision may be made to stop selling the drug – the can is kicked down the road. Add to this, imagine there are 36,000 drugs listed for sale (36,000 endangered species are listed under CITES for trade restrictions) and the above needs to be done for every demographic and in every region of the world.

Would society let human lives be treated in this way? Would we give the pharmaceutical industry unrestricted ability to trade (or maybe have some minimal restrictions on trade) until, after decades of research demonstrating the drug is unsafe to the human population, we clap with relief when, once-and-for-all, we finally get agreement to ban the trade in this drug?

Again, I ask the question, would we be willing to compromise people’s safety and survival in this way? No, of course we wouldn’t, because it would be a ridiculous approach, right? But we accept this very system for the trade in endangered species.

While the pharmaceutical industry has to apply the precautionary principle, paying for years of research up front (which is a reverse listing approach by the way), to show that a drug is safe for human consumption, in contrast, the default for the world’s endangered wildlife and plants is trade first until it is proven to have severe, negative consequences for the survival of the species.

While I have used the example of the pharmaceutical industry to demonstrate the value a of a reverse listing (or positive list) approach, there are many more including airplane manufacturing, airplane parts and medical implants that are required to operate this way to prevent potential harm.

In contrast, research published in February 2019 highlights that even when a species is identified by the IUCN Red List as being threatened from trade, it can wait up to 24 years to be listed for trade restrictions under CITES; while the average wait for inclusion on the CITES appendices is 12 years.

Wildlife doesn’t have the luxury of time and under the current CITES system species are being allowed to be traded into extinction, as they are not listed in a timely manner. Under the Precautionary Principle, as implemented by the pharmaceutical industry, such delays in listings don’t harm humans, so doing the same for CITES would prevent harm to endangered species.

The recent findings of the IPBES report stated that up to 1 million species are potentially facing extinction and the trade in flora and fauna was confirmed as the second biggest threat to species survival. If we want to save the world’s biodiversity, we must start talking about how to modernise the CITES convention, which regulates the trade in flora and fauna, to cope with the current and future volume of trade.

Nature Needs More, in collaboration with For the Love of Wildlife, have come up with a 3 step plan to modernise CITES:

  1. CITES Modernisation Part I – Electronic Permit Implementation Via Cost Recovery
  2. CITES Modernisation Part II – Reverse Listing
  3. CITES Modernisation Part III – Industry Contributing To The Costs Of Trade

Certainly, implementing an electronic permit system for species traded under CITES is critically overdue, a first step and an urgent one in the modernisation process. It would cost just US$30 Million to roll it out to all 183 CITES signatories. For more information on the see the ASYCUDA eCITES BaseSolution Online Access To electronic Permit Management document.

In speaking to many countries who want this system, but they simply can’t afford to pay for it, our question is, why isn’t industry paying for this system to be implemented, given many industries state that one of their key goals is sustainability. Knowing that an industry is genuinely sustainable is dependent on supply chain transparency and trade analytics. The current CITES system cannot provide this information; so to say this legal trade in endangered species is sustainable is frankly a delusion; there is no proof.

Whilst US$30 Million may seem like a lot to implement this ePermit system, remember that a UK Parliamentary Report stated that the LEGAL trade in endangered species was worth US$320 Billion annually; and that report was published in 2012, it will be worth more now. In addition, a 2016 World Bank Report highlighted that donors had given US$200 Million over 5 years to promote the sustainable-use model, driving up trade. If this much money can be found to promote the sustainable use model, why can’t US$30 Million be found to modernise the system that monitors and manages this trade?

In another example from the pharmaceutical industry, the European Medicines Agency has annual budget of €317million, with 90% coming from industry fees. This enables them to employ 900 staff. Over 2018 these 900 staff processed 60(!) applications, of which 45 were denied.

CITES could use a combination of Application Fees and Annual Listing Fees to raise funds for  application processing and monitoring/enforcement. In day one of CoP 18 there was a presentation on the budget. CITES core budget, from signatory parties, to manage the legal trade globally was announced at US$6.2 Million. But, wait for it, there is US$1.5 Million in arrears. So currently CITES has just US$4.7 Million core funding to manage a global trade of over US$320 Billion; and no one wants to talk about this!

The sobering findings of the IPBES Report should be the trigger for this modernisation work. The reverse listing approach should be considered along with getting industry to contribute to the cost of regulating the trade and so much more. It’s time to bring CITES in to the 21st century and to strictly apply the precautionary principle to regulating the trade in endangered flora and fauna.

Everything I have heard here at CoP18 has been reinforcing our belief that CITES is at a crossroads. Sadly, there is an ever increasing push by the SADC countries for liberalisation of trade and challenging CITES regulation, who are getting increasing support simply because countries are desperate to see some light on the horizon in relation to funding. Our proposals could go a long way to alleviate the pressures felt by all parties with populations of flora and fauna under threat from over exploitation or trafficking, as we are talking about industry funding worth hundreds of millions (or even billions) based on the overall value of the legal trade.

Working groups are created for anything and everything at CITES, so why can’t a working group be created to investigate ways on how to modernise the CITES convention?

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