No stakeholder is interested in validating the sustainable use model that the CITES is purportedly based on. After 50 years of the CITES, there is still no way to validate if the trade this regulator manages is sustainable.
Businesses and industries know genuine validation of sustainable use of wild species would threaten their profits and is likely to reduce access to the ‘raw materials’ they need for production. After seafood, fashion and furniture are the biggest users of these ‘raw materials’.
Governments know that validating the sustainable use model would challenge their ‘economic growth at all costs’ mindset because a transparent and precise assessment of the current scale of extraction would undoubtedly mean a reduction in trade.
Because industries and governments don’t what to know about the problems of the legal trade, and don’t what them exposed, conservation academics and NGOs have clinically sidestepped the lack of validation of the sustainable use model and simply subscribed to supporting it. These conservation organisations and academics promote their belief in sustainable use (and make public statements to that effect) without demanding any evidence.
Despite regurgitating their mantra of an evidence-based approach, they are willing to accept the sustainable use model on ‘faith’ and ‘wishful thinking’. There is no better evidence for this than a 2024 study, The Positive Impact Of Conservation Action, where 33 authors conducted a meta-analysis of scientific studies on the impact of conservation interventions. Starting with a scan of over 30,000 potentially relevant publications, the finding on the impact of sustainable use interventions was ‘inconclusive’ because the meta-analysis could find only 5 publications related to the sustainable use of species they could use.
This is not the first meta-analysis to struggle to find any positive (or even neutral) impacts of the sustainable use model. A 2021 publication, Impacts Of Wildlife Trade On Terrestrial Biodiversity found a large negative effect of trade on species populations, stating, “We examined 1,807 peer-reviewed articles and >200 TRAFFIC reports yet found no support for a quantified, existing sustainable trade”.
The CITES itself instigated a massive IPBES report, Assessment Report on the Sustainable Use of Wild Species, which analysed over 6,000 studies. Unfortunately for the CITES this report found the same problem – international trade is linked to overexploitation and the massive growth in international trade has driven the increase in unsustainable use.
The response to this lack of proof of the sustainable use model? Silence, as always.
Businesses’ glossy sustainability reports on their use of CITES listed species are meaningless. If the global trade in wild species is to continue, the lack of validation of the sustainable use model can no longer be ignored. The current strategy of simply using the term ‘sustainable use’ over-and-over doesn’t validate it. And, sustainability without the corresponding transparency is just an ideology, not the solution it is (over)stated to be.
The basis for believing in the sustainable use model within the CITES is the Non-Detriment Findings (NDF) process. According to the convention, parties shall allow trade in specimens of species included in Appendix II only if the Scientific Authority of the State of export has advised that “such export will not be detrimental to the survival of that species” (Article IV.2(a)). Referred to as “non-detriment findings” (NDF), they are a supposed to guarantee that exports of products from listed species covered by the NDF have not harmed wild populations or ecosystems.
But, in practice, the CITES has not produced binding technical criteria, just non-binding guidelines, for undertaking NDFs. CITES is not only flexible about what NDFs consist of, but the lack of a central evaluation also means the process is flawed (some say it’s a sham).
NDFs do not need to be published, although CITES belatedly created a repository of NDFs, to which only a handful of countries have contributed to date. About 41,000 species are listed for trade restrictions and CITES has 183 signatory countries, yet the CITES repository has only 266 NDF documents available to view.
That the process is completely broken was acknowledged in a 2020 CITES Secretariat Report which provided a powerful condemnation of NDFs and more evidence of why the CITES convention needs a complete overhaul, starting with a strategic review.
The CITES report showed that of 36 NDFs examined:
- 64% inadequately considered the precautionary principle, and
- 83% did not fully consider historical and current patterns of harvest and mortality.
Other research has confirmed NDFs suffer from:
- Insufficient data for most populations or species, precluding the ability to develop meaningful harvest/export quotas.
- A rarity of good quality assessment.
- The distorting effects of stockpiling and laundering.
- The fact that at least 21% of threatened species have outdated assessment.
- A lack of lack of standards that leads to high degree of bias and subjectivity in some assessments.
- Conflicts of interest in funding bodies for NDF work are not being considered.
There is no dedicated funding for creating an NDF, even when in most instances baseline population data and other biological/ecological features are simply unknown. To make matters worse, CITES has no problem with national MAs outsourcing the creation of NDFs to industry. Conflict of interest? Not a problem!
Of the 41,000 species and most of these species have never been researched in either their population dynamics, threats, biology and so forth because they are not cute/cuddly/iconic and therefore research rarely gets funded.
CITES does have a mechanism to ‘check’ on the effectiveness of the original NDF and the management plan for the species that has to be developed as part of the NDF process – the Reviews of Significant Trade. But again because of the lack of funding the actual number of such reviews is tiny compared to the number of species that are listed.
For example, when writing our 2021 CITES Modernisation Report, the data available showed between 2010 and 2016, of the 40 species selected for Review of Significant Trade only about half had been completed. The other 20 reviews were still ongoing, meaning at this rate the mechanism can never be effective given the increasing number of species listed. The situation hasn’t improved since.
Because there is no central review of NDFs, no monitoring has been put in place to validate the assumptions made and it can’t be because the trade data that CITES collects do not allow to derive the actual offtake in most instances.
The conservation sector needs to stop calling what are effectively ‘guesstimations’ on sustainability of trade an evidence-based approach.
Probably as result of this massive design flaw in the convention, the actual level of trade in a species is never discussed at CoP. There are endless discussions about new listings and listing upgrades at CoP, but even those never touch on the actual level of trade happening in a species.
The question of whether any CITES trade is truly sustainable is ignored instead.
If CITES was actually built around the sustainability of international trade, it would use reverse (white) listing with business having to fund the preparation of NDFs without being involved in the process of creating them or being able to influence that process. The default would be no trade, reviews would be regular and mandatory, and trade data would have to be collected at every step in the supply chain and validated. We have outlined how this would work in practice in our 2021 Modernising CITES report.
The conservation industry is on borrowed time regarding their avoidance of the legal trade in wild species. While models such as the Planetary Boundaries confirmed the loss of biosphere integrity was already in the in the high-risk zone by 2009, a lack of widespread mainstream media and public interest on this issue has enabled yet another decade of delay on tackling the consequences of the legal trade on biodiversity loss and meant the conservation scientists haven’t needed to ‘speak truth to power’ about this.
This is why the lack of proof of the Sustainable Use Model makes it to our CITES@50 Reality Check 2 of issues for immediate discussion at CITES CoP20.
