EAZA's POSI TION EUROPEAN ASSOCIATION OF ZOOS AND AQUARIA (EAZA) OF THE PARTIES TO CITES
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EUROPEAN ASSOCIATION OF ZOOS AND AQUARIA
(EAZA)
EAZA’s POSI TION
ON PROPOSALS FOR THE 18TH CONFERENCE
OF THE PARTIES TO CITES
Published in August 2019
Species and photo-credits see page 3
EAZA’S POSITION ON CITES CoP18 PROPOSALS
CONTENTS
INTRODUCTION……………………………………………………………………………………………………………………………. PAGES 2-3
PART 1. SPECIES LISTING PROPOSALS…………………………………………………………………………………………… PAGES 4-10
PART 2. WORKING DOCUMENTS…………………………………………..……………………………………………………… PAGES 10-14
INTRODUCTION
What is EAZA?
The European Association of Zoos and Aquaria (EAZA) is the largest regional accreditation-based zoo and
aquarium association in the world. It unites 419 Member institutions in 48 countries in Europe (including in
26 EU Member States), in the Middle East and beyond. Formed in 1992, it facilitates cooperation within the
EAZA community towards the goals of education, research and conservation.
The cornerstone of our Members’ cooperation are the EAZA Ex Situ Programmes (EEPs) for more than 400
species. These scientifically managed and non-commercial joint population management programmes aim
towards achieving and maintaining healthy populations of individuals with positive animal welfare. As part of
the Regional Collection Planning (RCP) process, species specialists from EAZA’s 39 Taxon Advisory Groups
(TAGs) set species-specific and tailor-made conservation roles for our EEPs. These are based on the IUCN
Guidelines on the Use of Ex situ Management for Species Conservation.
Our Members, and EAZA as a whole, collaborate with many conservation partners worldwide. EAZA
Members are encouraged to add data to the EAZA Conservation Database which demonstrates their support
to field conservation projects. The current level of reporting on activities carried out in 2018 shows support
for more than 300 species across the world, adding up to €16 million and almost 63,000 staff hours. These
values will increase as more Members add data throughout this year. You can find further details about the
EAZA Conservation Database and scope of projects in the EAZA Annual Report 2018.
For the past two decades EAZA has also been organising annual or biennial conservation campaigns. In the
current one, ‘Silent Forest’, we partner with BirdLife, TRAFFIC and IUCN Asian Songbird Trade Specialist
Group to help address the Asian songbird crisis. Please also refer to our Position Statement of April 2018 for
more information.
EAZA and CITES
Species conservation is at the forefront of the mission of EAZA and our Members. We strongly believe in the
importance of sustainable trade and use of natural resources and are highly concerned about the scale and
impact of illegal wildlife trade.
EAZA Members collectively hold some 5700 species and 1.7 million individuals in their care among which are
a large variety of CITES listed species. For decades, modern zoos have been striving to make their animal
populations self-sustainable. There is a wealth of expertise available within our Membership on the keeping
and breeding of animals across all taxonomic groups. For an increasing number of our EAZA Ex situ
Programmes have documented our expertise in EAZA Best Practice Guidelines. These are continuously
expanded and publicly available on our EAZA website.
We require due diligence in terms of CITES documentation whenever our Members transfer animals of a
CITES-listed species internationally. Through our Acquisition and Disposition standards, EAZA requires that all
animals acquired by our Members are preferentially born in captivity. Furthermore, our Members act as
rescue centres for animals confiscated from illegal trade. They provide their expertise in the care for such
animals and assist authorities in the identification of species in trade.
2 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
Our most recent animal transaction analyses indicated that 86% of animals acquired by EAZA Members in the
reporting period (2013-2017) came from another zoological institution, 4% of the animals were rescued and
3% of the animals were imported from the wild.
We believe we are inherently linked to CITES through education and outreach. EAZA Members receive over
140 million visits per year which make them uniquely positioned to educate the public about wildlife trade
how it is regulated and to promote demand-reduction initiatives.
EAZA and its Members also contribute to the progressing of animal, veterinarian, conservation and other
science, development of conservation tools and sharing of knowledge on topics including small population
management, and animal management and welfare, through for example the peer-reviewed Journal of Zoo
and Aquarium Research (JZAR), supporting the development of conservation management tool under the
umbrella of the Species Conservation Toolkit Initiative (SCTI) and our EAZA Academy. EAZA Members are
required to keep animal records of good standards to be entered into the Zoological Information
Management System (ZIMS), as operated under the auspices of Species360.
Our EEPs and the overarching Taxon Advisory Groups enable EAZA Members to contribute to species
conservation and build expert knowledge which we share in this document.
Contact
To discuss our positions please contact Danny de Man, EAZA Deputy Executive Director
and head of EAZA delegation to CoP18, at danny.de.man@eaza.net
Published in August 2019 by European Association of Zoos and Aquaria.
Cover photographs:
Top row: Vietnamese pond turtle © ZSL, Sumatran laughingtrush © Simon Bruslund, Bird Park Marlow,
Vietnamese box turtle © P. Wagner AllwetterZoo Munster, Mid row: Amur leopard © Land of the Leopard,
Sumatran tigers © Ian Moore Photography, Asian small clawed otters © Burgers Zoo, Bottom row: White
rhinos © Burgers Zoo, Black crowned crane © Africa Alive!, Giraffes © Gaia Zoo -Kerkrade.
3 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
PART 1. SPECIES LISTING PROPOSALS
Our recommendations are developed in close cooperation with our Taxon Advisory Group experts, many of
which are directly involved with species conservation. Our TAGs work with partners on both the in situ and
ex situ conservation spectrum and are usually working in cooperation with the relevant Specialist Groups of
the IUCN Species Survival Commission.
Under the list you will also find our comments on proposals that we consider of most relevance to our work
and highest importance for ensuring sustainable trade and contributing to species survival.
1.1. Summary of our voting recommendations
Proposal number, species name Proposal (link) Recommendation
And hyperlink to
comment, if any
MAMMALS
6 Aonyx cinereus Small-clawed otter Transfer to App. I ADOPT
1 Capra falconeri heptneri Turkmenian markhor Transfer Tajikistan pop. from App I. to II DO NOT ADOPT
8 Ceratotherium simum simum Southern white rhino Remove annotation (eSwatini) DO NOT ADOPT
9 Ceratotherium simum simum Southern white rhino Transfer Namibia pop. from I to II See comment
5 Giraffa camelopardalis Giraffe List in App. II DO NOT ADOPT
14 Leporillus conditor Greater stick-nest rat Transfer from App. I to App. II ADOPT
Transfer Zambia population from App. I
10 Loxodonta africana African elephant DO NOT ADOPT
to App. II
11 Loxodonta africana African elephant Amend annotations BW, NA,ZA and ZW DO NOT ADOPT
Transfer the pop. of BW, NA, SA and
12 Loxodonta africana African elephant DO NOT ADOPT
ZW from App. II to App. I
7 Lutrogale perspicillata Smooth-coated otter Transfer to App. I ADOPT
13 Mammuthus primigenius Woolly mammoth Include in Appendix II DO NOT ADOPT
15 Pseudomys fieldi praeconis Shark Bay mouse Transfer from App. I to App. II ADOPT
2 Saiga tatarica Saiga Transfer to App. I See comment
Transfer Province of Salta pop.
3 Vicugna vicugna Vicuña ADOPT
(Argentina) from App. I to App. II
4 Vicugna vicugna Vicuña Amend the name of the pop. in Chile ADOPT
16 Xeromys myoides False swamp rat Transfer from App. I to App. II ADOPT
17 Zyzomys pedunculatus Central rock rat Transfer from App. I to App. II ADOPT
BIRDS
19 Balearica pavonina Black-crowned crane Transfer from App. II to I ADOPT
20 Dasyornis broadbenti litoralis Lesser rufous bristlebird Transfer from App. I to II ADOPT
4 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
21 Dasyornis longirostris Western bristlebird Transfer from App. I to II ADOPT
18 Syrmaticus reevesii Reeves’s pheasant List in App. II ADOPT
REPTILES & AMPHIBIANS
Calotes nigrilabris and Calotes
23 Garden lizards Include in App. I DO NOT ADOPT
pethiyagodai
24 Ceratophora spp. Horned lizards Include in App. I DO NOT ADOPT
Cophotis ceylanica and Cophotis
25 Pygmy lizards Include in App. I DO NOT ADOPT
dumbara
Transfer pop. Mexico from App. I to
22 Crocodylus acutus American crocodile ADOPT
App. II
31 Ctenosaura spp. Spiny-tailed iguanas Include in App. II ADOPT
33 Cuora bourreti Bourret’s box turtle Transfer from App. II to I ADOPT
34 Cuora picturata S. Vietnam box turtle Transfer from App. II to I ADOPT
Echinotriton chinhaiensis and
39 Spiny newts Include in App. II ADOPT
Echinotriton maxiquadratus
28 Gekko gecko Tokay gecko List in App. II ADOPT
29 Gonatodes daudini Grenad. clawed gecko List in App. I ADOPT
36 Geochelone elegans Indian star tortoise Transfer from App. II to I ADOPT
27 Goniurosaurus spp. Leopard gecko List China, Viet Nam pop. in App. II ADOPT
Hyalinobatrachium spp., Centrolene
38 spp., Cochranella spp., and Glass frogs Include in App. II DO NOT ADOPT
Sachatamia spp.
26 Lyriocephalus scutatus Hump-nosed lizards Include in App. I DO NOT ADOPT
37 Malacochersus tornieri Pancake tortoise Transfer from App II. To App. I ADOPT
35 Mauremys annamensis Vietnam. pond turtle Transfer from App. II to I ADOPT
40 Paramesotriton spp. Asian warty newt List in App. II ADOPT
Grandidier's Madag.
30 Paroedura androyensis List in App. II ADOPT
ground gecko
32 Pseudocerastes urarachnoides Spider-tailed horned viper List in App. II ADOPT
41 Tylototriton spp. Crocodile newts List in App. II ADOPT
MARINE SPECIES
43 Glaucostegus spp. Giant guitarfish List in App. II ADOPT
45 Holothuria (Microth.) fuscogilva et al Teatfish List in App. II ADOPT
42 Isurus oxyrinchus, I. paucus Mako sharks List in App. II ADOPT
44 Rhinidae spp. Wedgefish List in App. II ADOPT
INVERTEBRATES
47 Achillides chikae hermeli Peacock swallowtail Include in App. I ADOPT
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48 Parides burchellanus Riverside swallowtail Include in App. I ADOPT
46 Poecilotheria spp. Ornamental spiders List in App. II DO NOT ADOPT
1.2 Explanation of our key recommendations
MAMMALS
Aonyx cinereus (Asian small-clawed otter)
Proposal by India, Nepal and Philippines
EAZA supports the transfer of the Asian small-clawed otter from Appendix II to Appendix I. EAZA notes that
the volumes of Asian small-clawed otters in international trade are low and that trade in wild caught
individuals is likely domestic. Additionally, we note that it is questionable whether the population declines
meet the criteria for Appendix I listing as well as that there are many uncertainties in this regard. We are
concerned about the increasing number of Asian small-clawed otters that are offered as pets through online
advertisement. Whilst otters are reported as being captive bred, it is not clear to what extent the demand
truly is met by captive breeding, for example in captive breeding farms. Therefore, we believe that an
Appendix I listing would contribute to ensuring appropriate and secure marking systems to identify breeding
stock and specimens in trade. EAZA maintains a studbook for Asian-small clawed otters held by its Members.
The species breed very successfully with studbook records indicating 468 individuals held by EAZA Members
(23 July 2019), of which 99% are captive born.
Capra falconeri heptneri (Turkmenian markhor)
Proposal by Tajikistan
• EAZA does not support the transfer of the Turkmenian markhor population of Tajikistan from Appendix
I to Appendix II. We applaud the increase of the population in Tajikistan, however with this increase
being very recent, and in part related to increased habitat for markhor, we are concerned that the down-
listing would reduce the incentives for regulated trophy hunting as a conservation tool. This creates the
risk of a renewed population decline. We are furthermore concerned that illegal trade across the border
from Tajikistan is ongoing and that precautionary criteria do not seem to be met.
Ceratotherium simum simum (Southern white rhinoceros)
Proposal by eSwatini
• EAZA does not support the proposal of eSwatini to remove the existing annotation for the population of
the country. EAZA and its Rhinoceros TAG are actively involved in dozens of rhino conservation projects
and in discussions in which the option of legalising the trade is frequently brought up. We do not believe
that the proponents have duly and fully considered the long list of issues to be resolved, related to the
necessity of ensuring proper law enforcement and market oversight, including mechanisms to
differentiate between legal and non-legal horn, etc. We conclude that it is not clear how the proposed
legal trade will be controlled, and we believe the precautionary measures (Annex 4 to Res. Conf. 9.24
(Rev CoP17)) are not in place. EAZA believes furthermore that live southern white rhinos should only be
exported to “appropriate and acceptable” destinations and does not support removing this requirement
from the existing annotation.
Ceratotherium simum simum (Southern white rhinoceros)
Proposal by Namibia
• Provided that a number of provisions are put in place EAZA would support the proposal of Namibia to
transfer the population of Namibia from Appendix I to Appendix II. The southern white rhino population
in Namibia seems to grow and poaching, whilst increasing, is fairly low compared to other countries.
EAZA however recommends that Namibia sets a quota of live animals to be exported and reports to the
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CITES Secretariat on how, and how effective, the proceeds of these exports are invested in rhino
conservation and the prevention of poaching.
Giraffa camelopardalis (Giraffe)
Proposal by Central African Republic, Chad, Kenya, Mali, Niger and Senegal [here in FR]
• EAZA does not support the proposal to list the giraffe in Appendix II. We appreciate the precaution that
giraffes may become endangered before adequate listing is undertaken. However, based on data from
the IUCN Okapi and Giraffe Specialist Group, we believe this is too pre-emptive and scientifically
unsupported. There appears to be no evidence that international trade has a significant impact on giraffe
populations. Moreover, as much as 97% of international trade is sustainable legal trade. The EAZA Ex situ
Programme (EEP) for the giraffe included 327 males and 502 females at the end of 2018, totalling 829
animals. The are five subspecies held in the population, as well as number of subspecific hybrids. The
population EEP population is very successful. The number of captive bred individuals in the population
exceeded the number of wild caught giraffes already in the 1970s, today including only four giraffes
(99,5%) born in captivity. From the
giraffes that moved between EEP participants, 95% of the transfers between 2008 and 2017 were within
the EU.
Loxodonta africana (African elephant)
Proposal by Zambia
• EAZA does not support the proposal of Zambia to transfer the population of African elephant in Zambia
from Appendix I to Appendix II. From the proposal it is difficult to understand the intention behind the
proposed commercial trade in ivory and furthermore there is insufficient detail to understand if the
precautionary measures are in place.
Loxodonta africana (African elephant)
Proposal by Botswana, Namibia and Zimbabwe
• EAZA does not support the proposal of Botswana, Namibia and Zimbabwe to amend the existing
annotation for the populations of African elephant in Botswana, Namibia, South Africa and Zimbabwe.
There is need for updating the annotations as part of the previous decisions are no longer valid, given
that timeframes have passed. EAZA notes the increase in the proportion of illegally killed elephants in
southern African and is concerned about the impact of this proposal allowing unrestricted exports of
registered raw ivory. We believe that the trade in raw ivory must be restricted and that a control
mechanism should be in place. Details are lacking to be able to assess whether appropriate enforcement
controls and compliance with the requirements of the Convention are in place.
Loxodonta africana (African elephant)
Proposal by Burkina Faso, Côte d’Ivoire, Gabon, Kenya, Liberia, Nigeria, Sudan, Syria and Togo
• EAZA does not support the proposal by Burkina Faso, Côte d’Ivoire, Gabon, Kenya, Liberia, Nigeria,
Sudan, Syria and Togo to transfer the populations of African elephant in Botswana, Namibia, South
Africa and Zimbabwe from Appendix II to Appendix I. The proposal is not specific to the populations of
Botswana, Namibia, South Africa and Zimbabwe. These specific populations do not meet the biological
criteria for inclusion of Appendix I. EAZA is not against non-commercial and sustainable trade provided
that such trade is controlled, appropriately restricted and monitored.
Lutrogale perspicillata (Smooth-coated otter)
Proposal by Bangladesh, India and Nepal
• EAZA supports the transfer of the Smooth-coated otter population from Appendix II to Appendix I. As
with the Asian small-clawed otter, we note that there is insufficient information on the scale of the trade
in smooth-coated otters, to what extent the demand is domestic and/or international, and whether the
amount of the trade is met by captive bred sources. EAZA believes that an Appendix I listing would be
beneficial as it would contribute to ensuring appropriate and secure marking systems to identify
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breeding stock and specimens in trade. EAZA has a small population of some 30 smooth-coated otters
that breeds well. The EAZA Small Carnivore Taxon Advisory Group (TAG) is aiming to set up an EAZA Ex
situ Programme (EEP) for the species following their next Regional Collection Planning meeting which is
scheduled in 2020.
Mammuthus primigenius (Woolly mammoth)
Proposal by Israel
• EAZA does not support the proposal of Israel to include the Woolly mammoth in Appendix II. Whilst
there is anecdotal evidence of elephant ivory being traded as mammoth ivory, the scale of these
substitutions is unclear and thought to be limited. EAZA believes further research into the scale of
mammoth ivory being substituted by elephant ivory is warranted and important, prior to considering a
proposal to include the woolly mammoth in Appendix II.
Saiga tatarica (Saiga)
Proposal by Mongolia and United States of America
• EAZA does not take a position on the proposal to transfer the Mongolian saiga to Appendix I. There is a
taxonomic confusion between the proposal and the CITES nomenclature, ironically resulting in the
proposal excluding the Mongolian population that is most effected by trade. Irrespective of the incorrect
taxonomy used on the proposal, EAZA is undecided as to whether the saiga population as a whole should
be transferred to Appendix I. Populations have declined significantly across the entire saiga range mainly
due to disease. However, populations have fluctuated over time and the species is highly fecund
demonstrating robustness against these declines. We recognise the decline of the Mongolian saiga
population as well as the potential for laundering of Mongolian saiga horns into the legal trade (e.g. via
stock piles). We also recognise the difficulty to establish the origin of horns due to the resemblance
between both saiga species including their horns. The extent to which the decline of the Mongolian
population is due to laundering is not clear to us. Considering these points, we could see a CITES II listing
for all saiga, with a zero quota as a potentially sufficient alternative to a proposed listing of all saiga on
Appendix I.
BIRDS
Balearica pavonina (Black crowned crane)
Proposal by Burkina Faso, Côte d’Ivoire and Senegal
• EAZA supports the transfer of the Black crowned crane population from Appendix II to Appendix I. We
are concerned by the reported numbers of crane in international trade and the lack of sustainability of
this trade. The Appendix I listing we believe will contribute to improved and more transparent records of
trade, including birds that are traded as being captive bred. Black-crowned cranes held by EAZA
Members are managed as part of an EAZA Ex situ Programme with the last recorded wild caught bird
dating back to 1999. There are however birds traded in the private sector for which information on origin
(of parents of captive bred birds) is not available at all times.
Syrmaticus reevesii (Rheeves’s pheasant)
Proposal by China
• EAZA supports to list the Rheeves’s pheasant population in Appendix II. The population has declined
significantly in the past decade due to illegal hunting, habitat loss and fragmentation and poisoning. We
believe the criteria for Appendix II listing are fully met. The listing will contribute to providing better
clarity as to whether live individuals that are captured are to only meet domestic or also international
demand. The species is held in zoos around the world, including a population of 191 in Europe, of which
some 50% is held by EAZA Member Zoos (ZIMS, 23-07-2019). This population is not managed as part of
an EAZA Ex situ Programme, however based on preliminary analyses the species breed well in captivity
and there are no birds recorded as wild caught. Experts from the EAZA Galliformes TAG believe the
8 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
population in captivity in Europe, that is not recorded in ZIMS (including private holders) to be higher,
estimating between 500 and 1000 birds.
REPTILES AND AMPHIBIANS
TESTUDINES
• EAZA supports the proposed listing in Appendix I for all five Testudines species, namely:
Cuora bourreti (Bourret’s box turtle)
Proposal by Viet Nam
Cuora picturata (Vietnamese box turtle)
Proposal by Viet Nam
Geochelone elegans (Indian star tortoise)
Proposal by Bangladesh, India, Senegal and Sri Lanka
Malacochersus tornieri (Pancake tortoise)
Proposal by Kenia and United States of America
Mauremys annamensis (Vietnamese pond turtle)
Proposal by Viet Nam
EAZA is very concerned by the vast number of Testudines in domestic and international trade, the lack of
sustainability of this trade and the declines of populations in the wild. We note that there are zero quota
in place for live wild caught Bourret’s box turtle, Vietnamese box turtle and Vietnamese pond turtle for
commercial breeding purposes, and would thus like to stress the importance of enforcement measures
needing to be put in place in order for the Appendix II listing to have an effect on the ground. The
number of animals that are traded as ‘captive bred’ are alarmingly high across the species not least in
case of the Indian star tortoise and the Pancake tortoise. We are concerned about the lack of
appropriate records to demonstrate keeping and breeding of the species.
The EAZA Reptile TAG is in the process of finalising its new 5-year Regional Collection Plan (RCP) for
Chelonians. Our Bourret’s box turtle, Vietnamese pond turtle and Pancake turtle populations will
(continue to) be managed as part of an EAZA Ex situ Programme (EEP) with an established ex situ
conservation ‘Insurance’ role. The fairly small Vietnamese box turtle and larger Indian star turtle
population will also be closely monitored by our TAG. Our Reptile TAG is keen to share our expertise and
knowledge with the identification, keeping and breeding of these species with Parties.
Gekko gecko (Tokay gecko)
Proposal by European Union, India, Philippines and United States of America
• EAZA supports the listing of Tokay gecko on App II. We note that increased enforcement measures have
resulted in a decrease in trade of live wild caught specimens for the international pet trade. Yet the
volume of the trade is large and the impact not full clear. We also note the species is not protected in
Thailand and Indonesia and therefore believe the precautionary principle for Appendix II listing apply
here.
Goniurosaurus spp. (Leopard geckos)
Proposal by China, European Union and Viet Nam
• EAZA supports the listing of Leopard geckos on App II. With eleven out of the thirteen of the species
under this proposal being only recently discovered, the species increasing being seen in trade -
particularly G. catabensis, G. luii and G. lichtenfeldi -, the population declining and becoming fragmented
and species being hard to tell apart, we believe the criteria for this listing to be fully met.
Gonatodes daudini (Grenadines clawed gecko)
Proposal by Saint Vincent and the Grenadines
• EAZA supports the listing of Grenadines clawed gecko on App I. The Grenadines clawed gecko is
Critically Endangered, endemic to Saint Vincent and the Grenadines and occurring in just a small area in
9 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
one of the Grenadines only remaining stands of mature forest. Over-harvesting for the international pet
trade is the single important threat to the continued survival of this species. Illegal trade in this species
was first reported in 2011 and is ongoing. Wild-caught specimens are reportedly offered for sale in EU
countries. We believe the listing criteria to be fully met for an App I. listing.
INVERTEBRATES
Poecilotheria spp. (Ornamental spiders)
Proposal by Sri Lanka and United States of America
• EAZA does not support the listing of the ornamental spiders (Poecilotheria spp.) in App II. Information
on historical and current wild population sizes is lacking as is trend data. The species ranges are
fragmented, and habitat loss appears to be the biggest threat to the species, with international trade
having a much smaller impact. The fact that there is some degree of trade in wild-caught animals is of
concern, but its extent is unknown. Our experts believe that the majority of specimens traded are in fact
captive-bred. The genus is widely and successfully bred in captivity in Europe. At the same time, the
listing can also pose administrative problems, as most of the animals held in captivity might not have
sophisticated data available about their provenance. We would recommend that Parties consider listing
the genus in Appendix III with a possible zero-quota for export of wild-caught specimens.
PART 2. WORKING DOCUMENTS
2.1 Strategic matters
10. CITES Strategic Vision Post 2020 CoP18 Doc. 10
EAZA supports the draft CITES Strategic Vision: 2021-2030.
We stand ready to continue contributing to the five strategic goals:
• With regard to Goal 1: Trade in CITES-listed species is conducted in full compliance with the
Convention in order to achieve their conservation and sustainable use:
Modern zoos and aquariums strive to maintain self-sustaining animal populations. Also, in EAZA,
Members are required to keep imports from the wild at an absolute minimum. Any import from the
wild would require scientific evidence for the need to do so. In all transfers of CITES-listed animals we
require Members’ due diligence regarding CITES documentation. We also require all EAZA Members to
keep detailed records of their animals and all their transfers; this data is stored in ZIMS (Zoological
Information Management System). All releases into the wild need to be performed in compliance with
CITES and with IUCN Guidelines for Reintroductions and Other Conservation Translocations (IUCN,
2013). EAZA will continue to share our experiences and good practices in these fields with the
authorities and other stakeholders.
• With regard to Goal 2: Parties’ decisions are supported by the best available science and
information;
EAZA will continue to share our Members’ expertise in ex situ and in situ conservation, in particular
with regard to CITES-listed species or species under CITES consideration. As appropriate, we will
continue to provide information about the animal populations in EAZA Member institutions and the
EAZA Ex Situ Programmes (EEP) to the CITES authorities.
• With regard to Goal 3: Parties (individually and collectively) have the tools, resources and capacity to
effectively implement and enforce the Convention, contributing to the reduction of illegal trade in
CITES-listed wildlife species:
EAZA will continue to promote due diligence regarding CITES permits among our Members for any
transfers of CITES-listed species. Our Members will remain active in the rescue and rehabilitation of
confiscated animals and will continue to assist the authorities in the identification of species in trade.
10 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
• With regard to Goal 4: CITES policy development also contributes to and learns from international
efforts to achieve sustainable development:
EAZA will continue working with CITES authorities and other parties to ensure that CITES facilitates the
conservation role of modern zoos and aquariums, in particular by ensuring that ex situ conservation
remains recognized as one of the available conservation instruments, as mandated by Art. 9 of the
Convention on Biological Diversity.
• With regard to Goal 5: Delivery of the CITES Strategic Vision is improved through collaboration:
EAZA will continue to seek effective partnerships towards the goals of conservation, research,
outreach and education, both with official CITES bodies and authorities and with other non-
governmental stakeholders.
2.2 Compliance & Enforcement
35. Disposal of confiscated specimens CoP18 Doc. 35
EAZA supports the recommendations and draft decisions of this document.
• As members of the intersession working group on the disposal of illegally traded and confiscated
specimens, we would like to highlight conclusion no. 24:
“[…] there were mixed views in the working group on whether or not to propose to the Standing
Committee and the Conference of the Parties that the work should be continued. At its 70th meeting,
the Standing Committee agreed that the mandate had been fulfilled and that the decisions therefore
should not be renewed. Instead, the Standing Committee suggested to collect existing information
and possibly at a later stage decide whether this information presented any gaps that would need to
be filled.”
• EAZA stands ready to contribute to this objective by providing information and expertise.
2.3 Regulation of trade
44. Definition of the term 'appropriate and acceptable destinations'
CoP18 Doc.
44.1 Report of the Standing Committee
44.1
EAZA supports Doc. 44.1 and its recommendation 15 to the CoP to:
a) adopt the non-binding guidance for determining whether a proposed recipient of a living
specimen is suitably equipped to house and care for it, as presented in Annex 1;
b) adopt the draft decisions on Definition of “appropriate and acceptable destinations”, as presented
in Annex 2;
c) agree to delete Decisions 17.178 to 17.180.
• Concerning the non-binding guidance, we wish to underline the importance of applying the whole set
of criteria in an integrated way when assessing whether a destination is appropriate and acceptable,
rather than applying just some of the criteria.
• Furthermore, we propose that the non-binding guidance refers to the expertise gathered by EAZA and
other zoo associations which is readily available to the public in the form of Best Practice Guidelines.
The added point could read: (i) Any other taxon-specific considerations including peer-reviewed
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scientific evidence and ex situ guidelines developed by accreditation-based zoo and aquarium
associations.
• Regarding the mandate for the Animals Committee to prepare non-binding best practice guidance on
how to determine whether “the trade would promote in situ conservation” (draft Decision 18.DD,
point a), we wish to make the following comments:
1. EAZA is concerned that the nuance and complexity is easily underestimated. It is important to
consider this task very carefully, to avoid severe unintended consequences – which may include
perverse commercial incentives to trade in CITES listed species because of large payments for
animals under the umbrella of ‘conservation support’.
2. Defining a contribution to conservation cannot be normalised with the precision of exact science,
as we have proven while developing the EAZA Guidelines on the definition of a direct contribution
to species conservation (2015).
• Concerning the more detailed species-specific guidance for living specimens of the African elephant
and Southern white rhinoceros (Doc. 44.1, draft Decision 18.DD, point b), EAZA and our network of
Taxon Advisory Groups and EAZA Ex situ Programmes are keen to continue to share our expertise in
appropriate housing and care, and to work together with the Parties, the CITES Animals Committee
and the CITES Secretariat to contribute to the development of this guidance.
• Finally, we wish to recall that Doc. 44.1, like all documents that refer back to Resolution Conf. 11.20
(Rev. CoP17), should consistently refer to the African elephant and the Southern white rhinoceros
rather than ‘elephant’ or ‘rhinoceros’, to avoid misinterpretation. We also recommend that the
document consistently refers to ‘living specimens of CITES Appendix I listed species’. This is especially
important for Recommendation 15a) and in the heading and first paragraph of Annex 1.
International trade in live African elephants: Proposed revision of Resolution
CoP18 Doc.
44.2 Conf. 11.20 (Rev. CoP17) on Definition of the term 'appropriate and acceptable
44.2
destinations'
EAZA does not support Doc. 44.2, submitted by Burkina Faso, Jordan, Lebanon, Liberia, the Niger, Nigeria,
the Sudan and Syrian Arab Republic, for the following reasons:
• We are convinced that it would be premature to define the appropriate and acceptable destinations
for one species, i.e. the African elephant, before the adoption of the overarching species-unspecific
guidance. Therefore, we consider Doc. 44.2 (and especially its Recommendations 26a and 26c) to
contradict the strategic proposals of Doc. 44.1.
• Moreover, Doc. 44.2 obliges the CoP to consider whether a species in principle can or cannot be held
in captivity, which we consider to be a question falling outside the mandate of CITES.
• We also wish to point out that the statement made in Doc. 44.2 that “the only certain way to promote
in situ conservation of live wild African elephants is through in situ conservation programmes within
their wild natural range” appears to disregard the IUCN Species Survival Commission Guidelines on the
Use of Ex situ Management for Species Conservation.
• For EAZA, these IUCN SSC guidelines are the basis for our joint population management programmes
and for integrating ex situ and in situ work. Our Taxon Advisory Groups work closely with the
respective IUCN SSC Specialist Groups on defining the conservation role of the animals in our care,
always considering a number of direct and indirect roles.
12 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
• This is also the case of the elephant: we are striving to maintain a sustainable population of elephants
in the EAZA region in order to fulfil these direct and indirect conservation roles. This is in addition to
EAZA Members’ support to in situ elephant conservation as illustrated in the box below.
BOX 1. EAZA MEMBERS’ CONTRIBUTION TO ELEPHANT CONSERVATION
EAZA Members have donated €4.3 million (USD 4.8 million) to elephant conservation since 2004 when the EAZA
Conservation Database was established to register Members’ conservation involvement and spending.
Around 50% has been directed to elephant-specific conservation projects, and 50% to projects that support elephant
conservation but also target other species (e.g. habitat protection projects). Some 40% of the funding is for the
African elephant and 60% for the more endangered Asian elephant.
A total of 30 EAZA Member zoos have reported their contributions. Among them, 12 hold African elephants, 15 hold
Asian elephants and 3 do not hold elephants.
Zooming into the last 10 years, we can observe the following trend with regards to elephant conservation support
from EAZA members:
EAZA Member support to elephant in situ
conservation
1,000,000
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
0
2006 2008 2010 2012 2014 2016 2018
Currency: EUR. Source: EAZA Conservation Database
The actual figures are higher than presented above, since not all EAZA Members have recorded their contributions in
the EAZA Conservation Database yet. Moreover, the registered figures only cover direct financial contributions and
exclude other significant conservation contributions such as costs of conservation education and ex situ
conservation.
In 2017 EAZA set up an Elephant Endotheliotropic Herpes Virus Fund through which elephant holders have already
collectively put more than €135,000 (USD 152,000) into research on this disease. This is in addition to more than
€120,000 (USD 135,000) directly contributed by EAZA Members.
Implementation of the Convention relating to captive-bred and ranched
57. CoP18 Doc. 57
specimens
EAZA supports the recommendations on the implementation of the Convention relating to captive-bred
and ranched specimens.
13 of 14EAZA’S POSITION ON CITES CoP18 PROPOSALS
71. Asian big cats (Felidae spp.)
71.2 Draft decisions on Asian big cats CoP18 Doc. 71.2
EAZA supports the draft decisions on Asian big cats.
• We particularly wish to endorse the comments of the CITES Secretariat that “given the wealth of
information contained in the Review and the considerable time and resources that have gone into
producing it, …., it would be wasteful if no substantive recommendations on Asian big cats came about
as a result of it” (point 10).
• EAZA wishes to reiterate our concerns about commercial trade in tigers and tiger products within the
European Union. Please refer to our Position Statement of November 2018 for more information.
79. Songbird trade and conservation management (Passeriformes) CoP18 Doc. 79
EAZA appreciates this document submitted by Sri Lanka and the United States.
• The trafficking of South East Asian songbirds is the theme of EAZA’s current two-year conservation
campaign, titled ‘Silent Forest’. Together with the campaign partners, IUCN SSC Asian Songbird Trade
Specialist Group, Birdlife International and TRAFFIC, we have been calling for measures to halt the
trade that has a detrimental effect on species survival.
• We are disappointed to see that no listing proposals have been put forward for any of the species,
despite the recent IUCN Red List update moving many of them upwards on the scale of extinction risk,
largely as a result of excessive trapping for international trade.
• This is a global problem, since demand for wild-caught Asian songbirds persists in many continents
beyond Asia, including in the European Union (despite EU legislation banning the importation of wild-
caught songbirds). We call on all Parties to CITES, including the EU, to treat this issue with urgency.
• Please refer to our Position Statement of April 2018 for more information.
84. Helmeted hornbill (Rhinoplax vigil) CoP18 Doc. 84
EAZA does not consider the document of the Standing Committee to be sufficiently strong.
• We are convinced that the significant illegal trade and high poaching levels in South East Asia, with
hornbill parts sold throughout the region, require prompt discussions at the CoP level and hopefully
a stronger decision and action without delay.
• The Helmeted hornbill is one of the species covered by the IUCN SSC Asian Species Action
Partnership (ASAP). EAZA is part of ASAP’s Governing Council, co-chairs its ex situ working group, and
has a number of Members involved. Through ASAP, we participated in the creation of the 10-year
Conservation Strategy and Action Plan for this species.
90. Black Sea bottlenose dolphin (Tursiops truncatus ponticus) CoP18 Doc. 90
EAZA supports the draft decision on Black Sea bottlenose dolphin.
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