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
Species Survival Network
The Species Survival Network (“SSN”) is an
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
Convention on International Trade in Endangered Species of Wild Fauna
and Flora (“CITES”) issued a press statement
“disappointment” with the ban. The
statement argues that the prohibition on wild bird imports would impair
conservation efforts for the world’s wild birds and will lead
an increase in smuggling.
Nowhere does the Secretariat allege
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
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
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 believes the
Commission’s decision to enact a prohibition on wild bird
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
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.
[the EU ban] risks casting the wrong impression that the international
bird trade is not effectively controlled…”
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
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
regulated,” trade in most CITES-listed bird species has not
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
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
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.)”
enactment of a temporary prohibition on wild bird imports in October
2005, the EU was the world’s largest importer of wild birds
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
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
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
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.
risk creating black markets. By ending legal and tightly managed
imports, the EU risks driving the market underground and making it less
Secretariat’s claim that trade bans ‘drive part of
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
[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
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).
study for CITES by the German Government revealed that mortality rates
for birds during transport for international trade was just
– CITES Secretariat
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;
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.
trade controls are most likely to be effective when they are simple to
implement and have been established on a cooperative, multilateral
– CITES Secretary-General Willem Wijnstekers
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.
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the African Grey Parrot (Psittacus erithacus timneh) and Development of
a Management Program in Guinea and Guinea-Bissau. CITES, Geneva,
Fotso, R. 1998a. Survey status of the
the distribution and utilization of the Grey Parrot (Psittacus
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--Prepared by the Species Survival Network, 17 January 2007
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