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Response to the EU Ban on Wild Bird Imports
A Statement by the Species Survival Network

Summary: Wildlife groups rebut claims by the CITES Secretariat that the EU prohibition on wild bird imports adopted to prevent the introduction of avian flu will impair bird conservation efforts or spur increased smuggling.

About the Species Survival Network

The Species Survival Network (“SSN”) is an international global coalition of more than eighty organizations dedicated to ensuring that the international trade in wildlife is conducted legally, humanely and only when evidence demonstrates that survival of the species and their role in the ecosystems in which they occur will not be detrimentally affected by trade. SSN member organizations are active in wildlife conservation efforts in dozens of countries on every inhabited continent. In recent years, many SSN members have grown increasingly concerned with the emerging linkages between wildlife trade and the spread of human and animal diseases. Although SSN as an organization does not generally make statements on public health matters, recent events related to highly pathogenic avian influenza warrant an exception.

The EU Ban on Wild Bird Imports

On 11 January, 2007, the European Commission’s Standing Committee on the Food Chain and Animal Health (SCOFCAH) unanimously adopted a permanent prohibition on the import of wild-caught birds into EU countries, effective 1 July 2007, in order to address the health threat posed by H5N1 avian influenza and other diseases. In addition, the regulation limits captive bred imports to those countries that have implemented high standards of disease prevention for birds in captivity.

On 12 January 2007, the Secretariat of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (“CITES”) issued a press statement expressing its “disappointment” with the ban. The Secretariat’s statement argues that the prohibition on wild bird imports would impair conservation efforts for the world’s wild birds and will lead to an increase in smuggling.

Nowhere does the Secretariat allege that the new regulation violates the Convention. Indeed, Article XIV(1),(2) reserves the right for any Party to enact stricter domestic measures to regulate wildlife trade including for the protection of public health. The EU Member States were within their sovereign right to enact this new measure. Furthermore, the implication in the Secretariat’s press release that the EU failed to consider the economic and conservation consequences of its new regulation is wholly inappropriate. The Secretariat is acting outside of its competence and jurisdiction; its statement is an ultra vires action that should be retracted.

Because the statement contains factual errors and misconstrues the findings of scientific studies, SSN feels constrained to provide the following rebuttal. Put simply, there is no evidence that the European Union ban on bird imports will either harm wild bird populations or spur increased smuggling of potentially diseased birds. In fact, SSN and many other conservation organizations strongly believe the European Union’s action will benefit both human health and the conservation of wild birds.

SSN’s Response

SSN believes the European Commission’s decision to enact a prohibition on wild bird imports is a reasonable precautionary measure in light of the potentially significant risks associated with the spread of H5N1 and the demonstrated potential of live caged birds of various species to move the disease between countries and continents. The bird trade provides an ideal environment for the spread of diseases because stress and the crowding prior to and during transport encourage the expression and transmission of infectious diseases. Indeed, the Secretariat does not dispute that the importation of wild-caught birds increases the risk of introducing potentially harmful diseases such as avian influenza or Newcastle’s Disease. Nor could it do so. Instead, the Secretariat argues that a permanent ban on wild bird imports may have unintended consequences for wild bird conservation by removing economic incentives to conserve wild birds and by encouraging increased poaching. These arguments cannot withstand close scrutiny.

1. “…it [the EU ban] risks casting the wrong impression that the international bird trade is not effectively controlled…” –CITES Secretariat

FACT: Though SSN strongly supports CITES and other multilateral conservation efforts, in practice, CITES has proved insufficient to protect many bird species. The scientific evidence necessary to make a non-detriment finding—that is, a finding, required under CITES, that export will not be detrimental to the survival of the species—is poor or non-existent for most birds species in trade. For example, more than 40,000 wild-caught Senegal parrots (Poicephalus senegalus) enter international trade each year even though there are no scientific assessments of the status of wild populations of this species.

Contrary to the Secretariat’s claim that international trade is “carefully regulated,” trade in most CITES-listed bird species has not been shown to be biologically sustainable. The scientific basis of non-detriment findings required for the export of most species of wild birds is, therefore, questionable. It is precisely for this reason that the CITES Parties have established a Review of Species in Significant Trade, designed to examine heavily-traded species to determine why non-detriment findings do not seem to result in sustainable levels of trade. If the statement made by the Secretariat were true, there would be no need for this process—one of the most extensive and broadly-supported within CITES—to exist.

The process by which exporting countries make non-detriment findings is not transparent or accessible to the public, making independent assessments of the validity of non-detriment findings difficult if not impossible. Likewise, the non-detriment findings of importing countries, where required, such as in the European Union, also lack transparency and are made without public consultation.

2. “The international trade in wild birds now consists mostly of West African finches, which are naturally abundant in their countries of origin. A recent analysis by BirdLife International showed that just 0.05% of the world’s bird species appear to be significantly threatened by international trade. Virtually all of these threatened species are subject to stringent controls by CITES (The main threat to wild birds is habitat destruction and degredation.)” --CITES Secretariat

FACT: Prior to the enactment of a temporary prohibition on wild bird imports in October 2005, the EU was the world’s largest importer of wild birds with nearly one million CITES-listed birds each year or 87% of the global trade (UNEP-WCMC 2006). Annually, this trade consisted of tens of thousands of psittacines (the parrot family) and other vulnerable species; and contrary to the Secretariat’s assertion, there are several West African finches that are vulnerable to endangerment, according to BirdLife International. Many species of tropical birds are experiencing population declines due to capture for both legal and illegal trade. In fact, 57% of the world’s threatened parrot species and one in ten Globally Threatened Birds are threatened by trade (BirdLife 2007). In 2006, EU BirdLife Partners reported that, “There is little evidence that the bird trade is sustainable and significant evidence that it results in biodiversity loss and deterioration of the conservation status of the species concerned.” By focusing on trade as a subset of the many threats faced by bird species, the CITES Secretariat’s statement minimizes the threat trade poses to the many species in trade and, thereby, diminishes the accountability of CITES for allowing the continuing unsustainable trade in wild birds.

3. “…bans risk creating black markets. By ending legal and tightly managed imports, the EU risks driving the market underground and making it less transparent” --CITES Secretariat

FACT: The Secretariat’s claim that trade bans ‘drive part of the trade underground’ is unsubstantiated and refutable. Data on seizures from many EU countries suggest that the temporary import ban on wild birds has reduced the illegal flow of birds into the EU. This is consistent with the impacts of similar measures elsewhere. Field biologists have demonstrated that when the United States enacted the Wild Bird Conservation Act, which banned the import of wild parrots for pets into the United States, there was a significant decline in nest poaching throughout the Americas (Wright et al. 2001); this research also demonstrated a strong positive correlation between the existence of legal markets for parrots and levels of illegal trade. Legal trade provides cover for illegal trade. Prohibitions on legal trade reduce opportunities for laundering of illegally acquired birds and reduce smuggling.

4. “It [the trade ban] also risks undermining the impoverished communities in countries of origin who depend on the environmentally sustainable trade in birds and removing their economic incentives for protecting bird habitat.” --CITES Secretariat

FACT: Exploiting wild birds does not provide meaningful and equitable financial benefits to people who live near these birds. The seasonality of bird captures and the low value of exported birds mean that the wild bird trade only provides a meager income to people who live near the birds. Profits are monopolized by a handful of middle men and importers. For example, local trappers of blue-fronted Amazon parrots (Amazona aestiva) earn an estimated US$10 per specimen while these same birds sell for up to US$750 each in Europe. Similarly, in Tanzania, it is estimated that trappers earn 1-2% of the price paid for the same bird in consumer countries (Mulliken et al., 1996). Export values show that the bird trade is not important to the economies of most range countries (Mulliken et al., 1996).

There is not one example of trade in wild birds that has provided sufficient resources to fund adequate, science-based monitoring and management of an exploited wild bird population. The capture and export of Amazona aestiva from Argentina is often touted as an example of local communities benefiting from trade in wild birds while protecting wild populations of the species. However, despite almost ten years of operation, the Amazona aestiva project in Argentina has not produced the scientifically-based information needed to manage the trade to ensure it is sustainable or to demonstrate that the wild population is not being harmed by capture and export.

In contrast, there are alternative ways in which people who live near wildlife can benefit from wildlife without harming wild populations, such as carefully planned and regulated ecotourism (Vieta 1999). Whales and sea turtles are worth much more alive than dead: whale watching is ten times more profitable than hunting (Hoyt 2001) and sea turtles are worth three times more alive than dead (Troeng et al., 2004). Bird-watching is a valuable source of tourist revenue in many parts of the world, and it frequently provides opportunities for local people to earn revenue as guides for visiting birders. For example, in the Rio Grande Valley of South Texas, the economic impact of birders at surveyed refuges is estimated to be in excess of US$90 million per year. An estimated 14,000 - 22,000 birders annually visit the Platte River in Nebraska and contributed between US$25 to US$50 million in the rural communities (WDFW 2005). Bird-related tourism is also a growing trend within many bird-exporting regions, such as Africa. In 1998, for example, researchers from the University of Cape Town estimated that bird-watchers contributed up to US$27 million each year to the South African economy. (Marshall 2001).

5. “An extensive study for CITES by the German Government revealed that mortality rates for birds during transport for international trade was just 1.36%.” – CITES Secretariat

FACT: Wild birds experience unacceptable levels of mortality and cruel treatment from the point of capture, before they are exported to markets overseas. Estimates for pre-export mortality of birds in trade range from 30-66% (Clemmons 2003; Fotso 1998a; Fotso 1998b; McGowan 2001; Iñigo and Ramos 1991), with many of the estimates sourced from CITES-commissioned studies. And though these mortalities significantly increase the need to take more birds from the wild in order to fill demand, the CITES Secretariat has resisted all attempts to expand CITES trade controls to limit mortalities from time of capture.

6. “Wildlife trade controls are most likely to be effective when they are simple to implement and have been established on a cooperative, multilateral basis.” – CITES Secretary-General Willem Wijnstekers

FACT: CITES is not an appropriate venue for discussing the need to restrict trade in wildlife for the purposes of protecting human health or agriculture.

Countries that participate in CITES should not be discouraged from acting unilaterally to protect the health of their citizens or agriculture or to address a threat to the survival of a species after multilateral action has proven ineffective.

References Cited:

Birdlife International. April 2006. Position Statement by EU BirdLife Partners on the importation of wild birds into the European Union.

Birdlife International. 2007. CITES and the wild bird trad. http://www.birdlife.org/action/change/cites/index.html. Retrieved 12 January 2007.

Clemmons, J.R. 2003. Status Survey of the African Grey Parrot (Psittacus erithacus timneh) and Development of a Management Program in Guinea and Guinea-Bissau. CITES, Geneva, Switzerland.

Fotso, R. 1998a. Survey status of the the distribution and utilization of the Grey Parrot (Psittacus erithacus) in Cameroon.

Fotso, R. 1998a. Etude sur l'état, la répartition géographique et l'utilisation du perroquet gris (Psittacus erithacus) dans al République démocratique du Congo. CITES, Geneva, Swizerland.

Hoyt, E. 2001. Whale Watching 2001:Worldwide tourism numbers, expenditures, and expanding socioeconomic benefits. International Fund for Animal Welfare, Yarmouth Port, MA, USA, pp. i–vi; 1–158.

Iñigo E and Ramos, M. 1991. The Psittacine Trade in Mexico. In J.G. Robinson and K.H. Redford eds. Neotropical Wildlife Use and Conservation, pp. 380-392 The University of Chicago Press. Chicago.

IUCN. 2004. 2004 IUCN Red List of Threatened Animals. IUCN, Gland, Switzerland and Cambridge, UK.

IUCN. 2000. 2000 IUCN Red List of Threatened Animals. IUCN, Gland, Switzerland and Cambridge, UK. As referenced in http://www.cites.org/eng/resources/species.html

IUCN. 1996. 1996 IUCN Red List of Threatened Animals. IUCN, Gland, Switzerland and Cambridge, UK. As referenced in http://www.cites.org/eng/resources/species.html

Juniper, T. 2002. Spix’s Macaw: The Race to Save the World’s Rarest Bird. London: Fourth Estate.

Marshall, L. 2001. Africa’s New Safari Trend is for the Birds. National Geographic News. http://news.nationalgeographic.com/news/2001/07/0725_birdsafaris.html.

McGowan, P. 2001. Status, Management and Conservation of the African Grey Parrot, Psittacus erithacus in Nigeria. CITES, Geneva, Switzerland.

Mulliken et al., 1996. A global overview of the wild bird trade: In: The live bird trade in Tanzania. N.Leader-Williams & R. Tibanyenda (Eds.). IUCN, Gland, Switzerland.

Shepherd, Chris R., Jeet Sukumaran, Serge A. Wich. 2004. Open Season:An analysis of the pet trade in Medan, Sumatra 1997 - 2001. TRAFFIC Southeast Asia

Troeng, S and Drews C. 2004. Money Talks: Economic Aspects of Marine Turtle Use and Conservation, WWF-International, Gland Switzerland.

UNEP-WCMC. 2006. CITES Trade Database. http://www.unep-wcmc.org/citestrade/trade.cfm

Vieta, Frances E. 1999. Ecotourism propels development. Africa Recovery, Vol.13(1).

Wright, T. F., C. A. Toft, E. Enkerlin-Hoeflich, J. Gonzalez-Elizondo, M. Albornoz, A. Rodriguez-Ferraro, F. Rojas-Suarez, V. Sanz, A. Trujillo, S. R. Beissinger, V. Berovides A, X. Galvez A, A. T. Brice, K. Joyner, J. Eberhard, J. Gilardi, S. E. Koenig, S. Stoleson, P. Martuscelli, J. M. Meyers, K. Renton, A. M. Rodriguez, A. C. Sosa-Asanza, F. J. Vilella, and J. W. Wiley. 2001. Nest poaching in neotropical parrots. Conservation Biology 15:710-720.

WDFW (Washington Department of Fish and Wildlife). Retrieved 21 November 2005 from, http://wdfw.wa.gov/viewing/watchwld/watchwld.htm

--Prepared by the Species Survival Network, 17 January 2007

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