It has taken 6 years of lobbying to move the dial on just the first step of modernising the CITES regulator, namely trying to drag the CITES from its 1970s paper permits to a digital, real-time system which can more easily monitor supply chains.
After Nature Needs More first published a 3-step process to modernise the CITES, Step 1. Electronic Permits, Step 2. CITES moves to Reverse Listing Model, Step 3. Business Pays cost of Regulation, we started lobbying the governments of signatory countries to implement a modern, digital trade permit system (Step 1).
Modernising CITES from its current 1970s paper-based permit system was first discussed in 2002. When we started, in 2019, only 2 countries had done this – France and Switzerland – by 2022 there were 15 countries and now there are 60.
Even with this number of countries, the 2025 Digital and Sustainable Trade Facilitation: Global Report, based on a United Nations global survey clarified that NO country has fully implemented eCITES. Why? Because it takes a global roll out of eCITES to enable universal Electronic Permit Information eXchange (EPIX).
Let’s clarify what is shown in this report. No country has fully implemented eCITES, which translates to no country can state that its system can provide any real proof of sustainable trade. In turn, any business that states in its glossy sustainability report that its trade in CITES listed species is sustainable is greenwashing.
Given the CITES has over 180 signatories, the world still hasn’t even reached the halfway mark! So now, with 66% of countries still to go, which are the priorities?
Nature Needs More has come up with a CITES Dirty Dozen list – the list of shame. While the time we devote to the eCITES project will be reduced, due to other project commitments, our focus for the next CITES intersessional period will be the USA, the UK, Canada, Japan, India, Hong Kong SAR, South Africa, Botswana, Panama, Columbia, Indonesia and New Zealand.
Neoliberal ideology and all its compliant (conservation) enablers continue to hinder the process of implementing modern, transparent supply chains to monitor the trade in some of the most endangered species on the planet. No surprise really, given there is a lot to hide in this decades old global business and conservation scandal.
The current CITES trade management system is equivalent to Amazon Inc. having no idea what products are in stock anywhere, when they will next arrive, where they come from, who provided them, who they go to and the only tracking updates you ever get come from a border crossing, albeit up to several years after the event.
While international supply chains, under the CITES, remain this opaque and broken the scale of overexploitation driving biodiversity loss remains impossible to monitor, let alone regulate.
So how did we choose the Dirty Dozen list of priorities?
Firstly, the key importers and consumers for the luxury trade in wild species are in the USA, UK, Hong Kong SAR, Japan and India. The demand from these countries alone is driving a significant volume of international trade in endangered and exotic species and, as such, they have no excuses to be such laggards.
Interesting that the USA is one of only two countries (the other being South Korea) who have gone back over with their CITES trade permit system. After being listed on the eCITES map as having some form of electronic CITES permit system in place; as of 2025 they had reverted to the ‘developing/planning’ stage.
The fact that the USA has gone back over is particularly disturbing given both the volume of ‘goods’ being both imported and exported and, in addition, counterfeit goods entering the country; an opaque trade permit system is known to enable illegal ‘products’ to enter the legal marketplace.
As recently reported by the Center for Biological Diversity, for the exotic pet trade (which is a luxury trade) alone, in one 24-hour period close to 300,000 live animals move across US borders. Many of these will be listed for CITES trade restrictions. Now that the USA has moved away from some form of digital eCITES system, just how can a 1970s paper-based system keep up with such a trading volume?
Hong Kong SAR, Japan and India are top destinations and profiters from this trade. Japan, India and Hong Kong are major markets for luxury items made with CITES listed species (crocodiles, alligators, pythons, rays, ivory, tropical hardwood etc.).
Hong Kong SAR and India are constantly seizing illicit wildlife products at their borders. Like anywhere in the world what is found will be only a fraction of what makes it into the country. Each of the seizures are celebrated as a success on social media. Instead, regular and massive seizure should be seen as a country’s system failure because traffickers are targeting it as an easy entry point. This should be a trigger for CITES modernisation, because both India and Hong Kong SAR are both demonstrating they are a weak point in the legal supply chain. Yet neither have invested in modernising their CITES trade system, happy to rely on the 1970s paper permit system known to be wide open to fraudulent use.
In December 2025, Hong Kong published a very comprehensive Biodiversity Strategy and Action Plan for the years leading up to 2035, there was no mention of modernising it’s CITES trade permit system even with numerous mentions of how it would achieve Target 5 – trade being sustainable and legal – of the KMGBF.
Image: Center for Biological Diversity Report EXOTIC EXPLOITATION#
In addition to these key destinations by trade volume, we must add the other wealthy laggards that have no excuse, namely the UK, Canada and New Zealand.
For example, George Monbiot recent article for The Guardian reported on the UK government national security assessment on biodiversity loss and ecosystem collapse, compiled by the joint intelligence committee (on which the heads of MI5, MI6 and GCHQ sit) and which was made only part public because of an FOI request. The reasons it wasn’t made public, “because its conclusions were too negative”, and “because it would draw attention to the government’s failure to act”.
International trade is a key driver of biodiversity loss and the UK government, often self-righteous about its spending on the illegal trade, has avoided modernising the country’s CITES system since we met with DEFRA in 2019.
South Africa and Botswana’s continued push to commercialise the regions’ wild species is the reason they have made the list.
Few countries treat wildlife like a commodity for trading like South Africa. The June 1991 Game Theft Act was passed in the same month that apartheid legislation was repealed; making the Game Theft Act 105 of 1991 one of the last major laws passed by the South African apartheid government. The Act made South Africa one of a few countries globally where wildlife can be privately owned and was a key factor in the emergence of wildlife trade industries. South Africa has around 9,000 privately owned game farms covering 17 to 20 million hectares (14-16.8% of the land surface) and containing between 16 and 20 million animals.
South African government representatives have been saying since 2019 that the country either had implemented eCITES, or it was imminent. Yet at the latest update of the eCITES map on the CITES website South Africa’s eCITES is still in ‘development/planning’.
The news of Dion George’s removal from his role as Minister of Forestry, Fisheries and the Environment because he had in a small way tried to curb the commodification of the country’s wildlife shows that South Africa will continue to rely on the wildlife trade to enrich the owners of the game farms and captive breeding operations.
Panama is included given it is a secrecy jurisdiction known to be involved in money laundering (which includes the illicit wildlife trade).
Why Columbia? Because the country is second only to Myanmar on the Global Organised Crime Index, which states, “has some of the most sophisticated and prolific trafficking networks in the Americas”. When it comes to environmental organised crime, the summary report says, “Colombia is plagued by wildlife trafficking. The black market for animals is thriving, with Europe being the primary destination”. It is also important to state that Colombia is the deadliest place when it comes to the murder of environmental activists.
As for Indonesia, the country has long been major global hub and high-risk hotspot for wildlife trafficking, consistently ranking as one of the most significant countries for the illegal trade of wild-sourced animal specimens.
Other countries that just missed the Dirty Dozen list include Laos, Cambodia, Viet Nam, Tanzania, Nigeria, Gabon, Zimbabwe and El Salvador.
The Dirty Dozen and the countries that just missed the list should be a priority when it comes to progressing the adoption of CITES electronic permit systems.
In the years we have been lobbying for eCITES modernisation, none of the large or small conservation agencies that attend CITES have joined the fray. Why aren’t any wildlife/environmental NGOs making this part of their government lobbying efforts?
It isn’t that this is difficult to understand, it is self-evident that if a country implements electronic permitting both the quality of the permits and the audit trail will reduce the illegal trade and corruption. That means less extraction from the wild, which is a critical protection measure. And yet, no takers. Endless lobbying for funding and expanding protected areas, zero lobbying for reducing extraction.
What is particularly outrageous is that most of the so-called protected areas conservation is lobbying for still allow poorly managed extraction to occur. Go figure!
If you are involved in an NGO that could lobby one of the dirty dozen governments and you get why this is both a very easy and very poignant project, then why not contact me so I can share what we have learned from our years of lobbying for the adoption of CITES electronic permitting?
After shifting the dial to 60 countries, Nature Needs More will downscale our work on the eCITES project to focus on other CITES trade priorities. So, if you are interested, we would love to work with you to tackle the dirty dozen.
Saying that, we have to be upfront that we aren’t interested in the NGOs who do nothing more then ‘encourage’ (their words) governments to take action. There are plenty of these types of organisations, big and small and they have shown themselves to be ineffective. You know who you are.
We would love to hear from the organisations, in the Dirty Dozen countries, who are actively and openly calling out government greenwashing on the trade in wild species and holding governments to account to close loopholes which allow species to be exploited for profit.
In addition to focussing on to the dirty dozen, we will also continue to lobby for the high-income countries, making the biggest profits from the trade in wild species, to cover the costs of completing the eCITES roll out in low- and middle-income countries. This work includes:
- Australia to support the adoption in Oceania.
- The USA, in collaboration with Active for Animals, to support the roll out in continental Africa.
- Europe to commit to funds for eCITES roll out in Latin America.
- Singapore and China could certainly support SE Asia.
- The Middle East could support key trading partners in Central Asia.
In finishing, any CITES MA from a low- or middle-income country who would like help in creating a funding application to a donor country, requesting the funds to support the ASYCUDA eCITES roll out, please don’t hesitate to contact Nature Needs More. We have done this already for a number of countries pro-bono and are very happy to help.