In 2017, when Nature Needs More decided that the illegal trade in wild species couldn’t be decisively tackled until the legal trade system under the CITES was modernised, we stumbled on the historic consideration of moving the CITES to a revise listing system.

For clarity, under the CITES model established 50 years ago the default for any wild species is to allow trade. Trade can happen unregulated until those who are concerned that the (international) trade is undermining the survival of the species can prove that trade is a problem and get this accepted by 2/3 of the CITES signatory parties. Sometimes it can take decades before trading countries and businesses accept the need for any monitoring and restrictions. By this time, it is often too late, and populations have plummeted. Also, sadly for most non-charismatic species, that philanthropists and universities aren’t interested in, this type of research never happens, and the problems of the legal trade are ignored.

At the same time, the wealthy businesses who are profiting from this trade aren’t held to the same standards to provide evidence that the raw material offtakes they are using in their manufacturing process is sustainable. All they have to do is write a glossy sustainability report saying it is, without any validation and investors, customers, media, business journalists etc go, Oh OK then – all good! If it wasn’t so tragic this laissez-faire system enabling the unchecked exploitation of the world’s wild species would be laughable. You have to wonder why this model is accepted and promoted by so many conservation organisations and academics.

In the reverse listing model the default is NO Trade until it is proven such trade can be managed without risk to the species’ survival and there is adequate monitoring to ensure that the offtake is legally harvested.

A submission to move to a reverse listing model was made by the Australian government to CITES CoP3 in 1981, just 6 years into the CITES’ operation.

We stumbled on a reference to the submission document but couldn’t find a link to the document anywhere. No surprise really given the issues in the legal trade have been clinically sidestepped by conservation organisations until very recently.

We contacted the Australian federal government for a copy, but the response was that they didn’t have it anymore and the documents that old had been destroyed. So, we contacted the CITES Secretariat and they emailed us a PDF.

Here is the important point from the submission:

At the time it wasn’t adopted because, at 700, there were considered too few species listed; it is now 41,000 (and growing).

As a result, the CITES system was left to expand and to grow unrestrained, to the point where there are too many species, not enough control and too few resources. Everything the 1981 Australian submission warned would happen has happened.

While Nature Needs More would prefer that there was no trade in wild species, we recognised that ‘sustainable use’ is the accepted model by most stakeholders, including conservation organisations and academics. As such we decided to assess if their faith in the model could be validated. When we found there was no proof that the sustainable use model worked in practice, we then considered how it could be moved into a valid system.  

We spent the two years leading up to CITES CoP18 (Geneva, 2019) discussing our thoughts on how to modernise the CITES with stakeholders worldwide and took three overview papers to CoP18:

Step 1: Electronic Permits 

Step 2: Reverse Listing 

Step 3: Industry Contributions 

While some progress has been made on Step 1 – Electronic permits, particularly in recent months, there still hasn’t been a global roll out of eCITES and key countries (including very wealthy countries) and regions of the world still rely on the 1970s paper permit system.

In the last 6 years there has also been a new focus on the problems associated with the legal trade and discussions of the reverse listing model for all trade.  

One of the most recent publications, published in October 2025 Assessing a reverse approach to traded species protection, is purportedly an assessment of reverse listing for the international trade under CITES. Specifically, the paper states that its objective is to, “evaluate [the reverse listing] approach on an international scale, including the likely risks and benefits involved, and discuss policy solutions”.

As a starting point, the paper states, “International agreements (e.g. CITES) and national laws governing the harvest, use and trade of wild species predominantly apply a “negative” listing approach. Under this approach, the trade of species on the list is either prohibited or closely regulated. Tools such as permits and quotas are used to ensure legality and sustainability, and to monitor trade in listed species only.”

This is a BIG problem, because it means that the paper is built on a presumption that the CITES is currently working to ‘ensure sustainability and legality’, which it blatantly isn’t.

If this is the basis for their assessment of a reverse listing model it is wrong from the beginning. The CITES is a mess, it is impoverished, unfit-for purpose, the laundering of illegal products into legal supply chains is laughably easy and even the CITES leadership has admitted it can no longer cope. The fact that the authors have been willing to allow this statement in the paper, “Under this approach, the trade of species on the list is closely regulated. Tools such as permits and quotas are used to ensure legality and sustainability” is a red flag on what the purpose of the paper is.

The paper ponders, “the feasibility and risks associated with the process of radical system change”. What it doesn’t say is that when reverse listing was proposed in 1981 it was assessed as not required because the CITES only listed 700 species for trade restrictions. So, it wasn’t done at the point in time (1981) when a system change would have been much more feasible and less risky to do. Then the problems of the CITES listed trade were ignored for nearly 40 years and now it is considered ‘too hard’ to do. You can’t have it both ways!

The author of the 1982 paper, International Trade in Endangered Species under C.I.T.E.S.: Direct Listing vs. Reverse Listing whose research was used as the basis for maintaining the direct listing approach has been one of the biggest supporters of the need to overhaul the system since 2020. Martin Ditkof emailed us saying, “Guys: I completely agree with your analysis of my 1982 article on whether reverse listing made sense. The times have changed”. We invited Marty to write a statement, for our Reverse Listing page, about his change in thinking, which has been on our website since 2020.

Nature Needs More has always understood that given the size of the trade under the CITES moving to a reverse listing model isn’t easy, which is why we created a draft submission for an intersessional working group to consider a review of the convention putting ALL options on the table to modernise the CITES so it can cope with current and future trade volumes and conditions. Looking at ALL options would including reverse listing and a business pays model.

We even had a philanthropist pledge to put in US$500,000 to help with the budget of creating a working group. No country or organisation we spoke to was willing to support it.

So, when the 2025 publication we are talking about states, “If reverse listing were to be formally adopted within CITES, this would require amending the Convention text. In such instances, it is unclear how countries would transition from negative to positive lists, and on what timeline, but there are several factors to consider.” Exactly what the submission for the intersessional working group was proposing, but no one had the courage to do it. They would rather maintain the status quo, keeping their heads in the sand and hoping the problem goes away.

There is so much wrong with this 2025 assessment on reverse listing, it is hard to know where to start. So, I just outline a few:

  • Splitting the ‘technical’ aspect of positive lists from the overall regulatory framework is disingenuous. This has been a common mistake of any paper on positive lists by conservation organisations or academics and shows a profound misunderstanding of regulatory frameworks. There is a reason that positive list regulations for industry are paired with a business pays model, the framework can only be effective if industry internalises the compliance, which means they need to pay for it. For example, in 2023, the total budget of the European Medicines Agency (which uses a reverse listing model to approve pharmaceutical drugs) was €458 million.
    • Around 89.0% of the Agency’s budget derives from fees and charges levied on business, 10.9% from the European Union contribution for public-health issues and 0.1% from other sources. This example shows that substantial funds can be raised (for assessment, monitoring and enforcement) from industry if the model is set up correctly. This is well-known but ignored in this paper and any similar proposal put forward by conservationists. In our 2021 report, Modernising CITES – A Blueprint for Better Trade Regulation, which put reverse listing for ALL CITES trade back on the agenda, the model we present makes business responsible for internalising compliance, yet keeps companies at arm’s length from the regulator and the regulatory process.
  • The effectiveness of monitoring and enforcement of a positive list system are not reliant on law enforcement efforts at the point of collection/extraction as implied in the paper. A proper positive list system includes not only a business pays funding model, but also source to destination traceability, which is why we have spent that last 6 years lobbying for the CITES trade permit modernisation. We need to remind ourselves that the person illegally collecting specimens has no ability to sell their ‘product’ on the international market, so the effectiveness of law enforcement comes down to monitoring supply chains and properly penalising businesses that trade in illegal items. The mistake is to assume that illegal trafficking will continue at scale after a species is no longer tradeable under reverse listing. This is by no means obvious. But it is safe to assume the current level of trafficking is in part the result of laundering into legal supply chains being so easy and carrying so little risk; it is a low risk, high reward crime.
  • The argument that the demand for high-value species would persist and hence drive the illegal trade is presented in a one-sided manner that ignores the nature of the demand. In a proper reverse listing system illegal items cannot be legally advertised, which is ignored by the authors. Demand for high-value species is mostly not domestic in nature and in many cases created by marketing and advertising (by the luxury industry for fashion, furniture, gourmet food, jewellery etc). There are of course counterexamples (like the use of pangolin scales in TCM), so the question of what degree of illegal trade will persist after a transition to a positive listing system is not that easy to answer. The key difference is that the current system has a massive illegal trade and no money to fight it, whereas a business-pays positive list would have the money to vastly strengthen monitoring and enforcement along the entire supply chain.
  • Although the paper ostensibly is about “evaluating the feasibility of [reverse listing] on an international scale”, the counterarguments put forward mostly relate to traditional use and domestic trade. Yet the 2024 IPBES report confirmed that traditional use and domestic trade are not the main cause of unsustainable use and overexploitation. They would not be impacted by moving the international trade to a positive list.
  • The international trade is conducted by businesses, and they will adjust to whatever regulations are put in place. The question of social legitimacy of the new regulations raised in the paper hence does not really apply if the change is presented as a risk and safety mitigation approach (which is core to the argument anyway). To presume that properly implementing the Precautionary Principle would lack ‘social legitimacy’ is a rather strange assumption to make. 
  • The paper states, “Nevertheless, reverse listing would not solve many of the problems with existing wildlife trade regulations and is unlikely to be a superior blanket approach at the international level. It would not necessarily result in stronger law enforcement or better compliance by actors with applicable laws.”. This opinion is basically rubbish because it hides the fact that the main actor in international trade – businesses – has no ‘applicable laws’ at present. Under genuine positive lists, businesses not only pay the costs of regulation and enforcement, they are also forced to internalise compliance. That very much means that there will be ‘better compliance’, especially since anything is better than zero as under the current system.

While this paper does acknowledge reverse listing would need system change under the CITES, too often the mistake made by conservationists is that reverse listing is just a change in the mechanics of ‘listing’. This is evidenced by the completely inadequate ‘positive lists’ used in some EU countries for the exotic pet trade. Without regulating the main actor in the trade – businesses – and without a business pays model, going to reverse listing is completely useless and doesn’t really deserve the positive list moniker, which is why we have termed these models ‘basic positive lists’ in our Exotic Pet Trade report.

Yes, reverse listing requires a system change which means a shift in mindset to hold business to account over their current all profit, no responsibility approach. The idea that businesses will voluntarily adopt and pay for ensuring the legality and sustainability of their supply chains ought to be confined to the dustbin of history by now. Forty years of the useless voluntary governance approach clarifies that businesses will always works on a shareholder primacy model, no matter how much they greenwash their only real objective with phantom solutions from CSR, ESG, etc.

For those that are still unsure, I would recommend a 2009 book, From Predators to Icons. The authors challenge the image of the business owner as a visionary with a plan. Instead, they outline their use of the term ‘predation’, as, “ruthlessly taking advantage of imperfections, weaknesses, and vulnerabilities within the market”. This is exactly what businesses have done and are still doing regarding the extraction of wild species for their raw materials for production.

These same businesses only benefit from such poor-quality assessments, such as this October 2025 preprint, of the positive list model, which when done well can genuinely curb commercial excess. Why help maintain the status quo, which is so obviously not working and aid huge profits to continue to be made from this trade, while biodiversity plummets? Let’s remember that the landmark 2019 IPBES report established that trade is the biggest extinction risk for marine species and the second biggest risk for terrestrial and freshwater species. The IPBES further established that international trade is the major culprit for unsustainable extraction, not community use or local trade.

Does anyone really think that reverse listing for pharmaceutical drugs would work just fine if it didn’t regulate the drug companies directly and made them pay for drug approvals??? If governments simply created a list of drugs that can be legally sold, would businesses comply with that out of their innate care for the health of the public, even if it hurt their sales and profits? It is pretty commercially naïve (or deliberately ignorant) to propose such a system.

Let’s be clear, good quality regulation of the pharmaceutical industry in the likes of the EU and Australia saved people from opioid epidemic seen in North America. Once you open the doors to business behaving badly, they inevitably will. Corporations after all have all the psychological traits of psychopaths, they are completely self-interested, amoral, exist purely to make money and have no regard for ethical issues.

From a regulatory perspective, the reverse listing model is the ONLY way of saving wild species from industry’s addiction to profit and continued growth. The wasted decades mean that it is getting too late to leave it just to regulation, even if it is good quality, mandated, well-funded regulation.

Poor quality assessments – some might say hatchet jobs – of genuine solutions mean that we are accelerating to a point where the CITES, CBD and conservation world’s ineffectiveness will become irrelevant.

Whilst we can only speculate on the motivations of the authors to ignore the evidence of well-crafted and properly working reverse listing regulations in other industries, Upton Sinclair’s famous quote that “it is difficult to get a man to understand something when his salary depends on his not understanding it” comes to mind.

Nature Needs More will not sit on the fence with this, we will lobby for a genuine reverse listing model for extraction of all wild species, which includes a business pays model to cover the cost of regulation and monitoring across the whole supply chain. We are of course very interested in someone putting on the table an even better model to curb the overextraction of wild species. We had hoped that the intersessional working group we suggested would uncover such options.

The conservation world’s inertia in the trade in wild species, as highlighted (again) with this October 2025 publication is the reason we can with 100% certainty say that there is NO Chance of achieving Target 5 of the CBD KMGBF (CITES Strategic Vision) by 2030.

To have a chance of achieving this conservation must come out of its ivory tower and step into the real world of commercial ruthlessness and learn how to deal with 50+years of power imbalance that has rendered them so ineffective in protecting wild species from industrial scale commercial trade. The question is, are they willing to do this?