We received many requests for a more detailed blueprint for how the new CITES framework based on white-listing and industry paying the cost of regulation would actually work. When the first draft of the CBD post-2020 global biodiversity framework was published in early 2020, it included a new target (Target 5) which stated that all trade in wild flora and fauna should be legal and sustainable. It was then that we decided to create a detailed framework based on this target.
This meant that we had to design a detailed regulatory mechanism that can cope with a large number of listings for trade and a very diverse range of businesses involved in the trade. We adopted the basic white-listing model from the European Medicines Agency, which is a supra-national regulator for the trade in pharmaceuticals in the EU. The EMA has a proven model for dealing with a large number of products being traded, for managing complex applications and approvals and for working with natonal authorities. It also publishes a detailed fee schedule which we adapted for use in CITES to make the system financially viable and to remove the current inequities.
The main difference between the regulation of pharmaceuticals and the trade in wild flora and fauna is the level of concentration in the businesses involved. Pharmaceuticals are dominated by just a handful of giant manufacturers whereas the CITES trade is much more diverse. We therefore adapted the ‘joint application’ model from the ECHA (which regulates the manufacture and import of chemicals in the EU), which solves this problem and has been proven in practice.
From these building blocks we created a detailed framework and investigated how it would work in practice based on a number of different trades (pythons, corals, rosewood timber). We further outlined detailed transition arrangements from the current to the new framework.
The resulting Modernising CITES report was published in July 2021 and is available in all 6 official UN languages. Nature Needs More is actively working with CITES signatory countries and NGOs to promote the new regulatry framework. We aim to get CITES to create a working group to study our proposal at CoP19 in 2022 in Panama.