CITES was conceived in 1973, long before personal computers and smartphones. Consequently, the permit system developed to manage exports and imports under CITES was paper based and quite simple. This 1970s paper-based system is still in use today.

Whereas individuals and businesses have mostly gone fully digital, CITES permits are still mostly paper based, often still written on typewriters or filled in by hand. It goes without saying that this a huge problem, as it enables traffickers to forge permits, reuse them or alter them with minimal effort. There is currently no central repository of CITES permits against which a custom official could check if the permit presented to them is valid.

In addition, the permits contain very limited information. For example, the default quantity is ‘units’, which is completely open to interpretation. CITES has guidelines for how quantities should be stated, but they are often not followed. Even if they are followed, they can be ambiguous. Take the example of the ongoing issue of labelling lion bones, exported from South Africa. CITES allows the terms ‘bone’, ‘skeleton’ and ‘body’. This leads to inconsistencies in labelling, which in turn lead to poor data quality in the CITES trade database.

Beyond the generally poor quality of the data submitted to the CITES trade database, the data is only submitted once a year and usually late. By the time the data appears in the database, it is 12-24 months old. In most years, some parties fail to submit data altogether. Yet it is this trade database that is used to decide if, for example, a species should be uplisted from Appendix II to Appendix I.

As a result, researchers often turn to customs data to try to validate the data in the CITES trade database. Because there is no integration between the CITES permits and customs records, it is not possible to reconcile shipments. CITES permits only state the maximum quantity that can be exported, not the actual quantity. Whilst permits contain a section at the bottom for customs reconciliation and entry of a waybill number, this section is not always filled out (as in the example shown).

The current system also does not provide for traceability, despite tracing specimens being a critical aspect of CITES enforcement. CITES listings may prohibit the trade in a species from one particular population but allow trade in a nearby population. If specimens cannot be tracked, how does anyone know if a shipment contains specimens from the prohibited population?

To summarise, the current CITES permit system is hopelessly out of date, open to fraud and abuse and generates poor quality data for decision making. It is also not integrated with customs systems, making verification impossible and thereby creating further loopholes exploited by the illegal wildlife trade.

Dear…

Given our country is a signatory to CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), which is supposed to ensure that the international trade in animals and plants does not threaten their survival, I was shocked to hear that CITES has not been modernised since it entered in to force in 1975.

CITES still uses the 1970s paper-based system to facilitate and monitor the legal trade in endangered species. It is astonishing that this is still the case in the 21^st century, particularly given the legal trade is valued at over US$320 Billion annually. There can be NO excuse for any country to maintain this obsolete system.

The transition to an electronic permit system, which is fully integrated with customs to ensure traceability from source to destination, is long overdue, particularly since this archaic system means that is easy to launder of illegal items into the legal marketplace.  In addition, it is critically important that any electronic permit system is secure and trustworthy. So, I was delighted to hear that the eCITES BaseSolution was developed jointly between CITES, UNCTAD, with the support of the Swiss and Sri Lankan Governments.

To-date, Sri Lanka is the only CITES signatory country to implement this system and this needs to change. Rolling out the eCITES BaseSolution over all 183 signatory parties will cost in the region of US$30 Million in total, with the first 20 signatories costing US$3 Million. For a legal trade worth over US$320 Billion annually, these roll-out costs are minimal.

Whilst wealthy countries should cover the cost themselves, donations should be made for developing countries to implement the eCITES BaseSolution; such donations can be made available via the World Bank’s Global Wildlife Program.

As my local MP, I request that you seek support from our government and the responsible department to implement the eCITES BaseSolution not only in our own country, but across all CITES signatory parties by the next CITES Conference of the Parties in 2025.

As part of this support, and to ensure that implementation occurs with the urgency needed – given an electronic permit system has been discussed for nearly a decade without any progress – any signatory party that refuses to implement the eCITES BaseSolution or wants to implement an electronic permit system of their own design, which is not considered to be as secure, and so is less trustworthy, must have trade restrictions imposed, this may take the form of reduced export and/or import quotas.

In not modernising this CITES permit and trade monitoring system in nearly 50  years, we as a signatory, have let down the world’s precious wildlife and the natural world more broadly. This needs to change, urgently, by closing the loopholes that this obsolete permit system provides to traffickers.

I look forward to a response addressing the precise points raised above. Please note I am not interested in a response consisting of banal statements about the government’s current commitment to tackling the illegal wildlife trade.