TRAFFIC THE SHARK AND RAY TRADER E P O R T

MAY 2017

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IN SINGAPORE
Boon Pei Ya

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TRAFFIC REPORTTRAFFIC, the wildlife trade monitoring
network, is the leading non-governmentalorganization working globally on trade inwild animals and plants in the context of bothbiodiversity conservation and sustainable
development. TRAFFIC is a strategic alliance ofWWF and IUCN.
Reproduction of material appearing in thisreport requires written permission fromthe publisher.
The designations of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of TRAFFIC
or its supporting organizations concerning
the legal status of any country, territory, or
area, or of its authorities, or concerning thedelimitation of its frontiers or boundaries.
The views of the authors expressed in thispublication are those of the writers and do notnecessarily reflect those of TRAFFIC,
WWF or IUCN.
Published by TRAFFIC.
Southeast Asia Regional Office
Suite 12A-01, Level 12A, Tower 1,
Wisma AmFirst,
Jalan Stadium SS 7/15,
47301 Kelana Jaya,
Selangor, Malaysia
Telephone : (603) 7880 3940
Fax : (603) 7882 0171
Copyright of material published in this report
is vested in TRAFFIC.
© TRAFFIC 2017.
ISBN no: 978-983-3393-63-3
UK Registered Charity No. 1076722.
Suggested citation: Boon, P.Y. (2017). The
Shark and Ray Trade in Singapore. TRAFFIC,Southeast Asia Regional Office, Petaling Jaya,
Selangor, Malaysia.
Front cover photograph: Manta Ray.
Photo Credit: Richcareyzim/Dreamstime.com

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THE SHARK AND RAY TRADE
IN SINGAPORE© Richcareyzim/Dreamstime.com

Boon Pei Ya

Manta Ray

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© Srf1516/ Dreamstime.com

Whale shark

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TABLE OF CONTENTS

Acronymsiii

Acknowledgementsiii

Executive Summaryiv

Introduction

1

Methods

8

Results and Discussion

9

Conclusions and Recommendations

27

References

33

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iii TRAFFIC Report: The Shark and Ray Trade in Singapore

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ACRONYMS
ASEAN

Association of Southeast Asian Nations

AVA

Agri-Food and Veterinary Authority of Singapore

AHTN

ASEAN Harmonised Tariff Nomenclature

CA

Competent Authority (product code)

CITES

Convention on International Trade in Endangered Species of Wild
Fauna and FloraCOFIFAO Committee on Fisheries

FAO

Food and Agriculture Organization of the United Nations

HS CodeHarmonized Commodity Description and Coding System, also
known as the Harmonized System of tariff nomenclature

ICA

Immigration and Checkpoints Authority of Singapore

IE Singapore

International Enterprise Singapore

IE Statlink

International Enterprise Singapore Trade Statistics

IPOA–Sharks

International Plan of Action for the Conservation andManagement of Sharks

ISSCAAPInternational Standard Statistical Classification of Aquatic Animals
and Plants

ITC

International Trade Centre

IUU

Illegal, unreported and unregulated (fishing)NGO

Non-governmental Organization

NPOA

National Plan of Action

RMFO

Regional Fisheries Management Organization

STCCED

Singapore Trade Classification, Customs and Excise Duty

WCO

World Customs Organization

ACKNOWLEDGEMENTS
The preparation of this report was made possible by financial support provided by WWF Singapore.
Shelley Clarke and Felix Dent from FAO gave advice on trade data analysis. Kanitha Krishnasamy,
Chris Shepherd and Glenn Sant from TRAFFIC reviewed the report and provided overall advice.
Markus Burgener from TRAFFIC also provided guidance on trade data mining. We also thankAgri-Food and Veterinary Authority of Singapore and the Marine and Land Product Association ofSingapore, the latter during which Melvin Foo and Yio Jin Xian provided industry related insight.
Desmond Chia from Singapore Customs explained HS Code classifications and Jassmine Lam fromIE Singapore helped with explaining IE Statlink data.

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EXECUTIVE SUMMARY
The types of shark commodities traded internationally are diverse with shark meat and fins being
the primary commodity types. Shark meat is reported to be the most traded by quantity (120 305 t
imported globally in 2013, the last year for which full global data are available) while shark fins are
the most valuable (USD214 million worth of global imports in 2013). Skates and rays1 are suspected
to constitute a sizeable proportion of the global shark meat trade, while rays are often overlookedin the fin trade. There is also a growing market for Mobuild Ray gill plates for use as a health tonic
and/or as cures for various illnesses.
Singapore is known to play a major role in the global trade and consumption in shark and ray parts
though a country-specific analysis has not been conducted recently. Based on this, TRAFFIC and
WWF undertook an exercise to understand the scale of this trade involving Singapore, and the roleit plays. This assessment describes the characteristics of shark product trade through Singapore overa ten-year period, from 2005 to 2014 as well as the current regulatory systems in place. The primarysources of data were the Singapore government trade statistics body IE Statlink (for the years
2005-2014) to determine Singapore-specific trade dynamics, Food and Agriculture Organisation(FAO) fishstat (for the years 2005-2013) to undertake comparison in global trade and CITES trade
database. However, the reclassification of shark fins by Singapore Customs (and those captured in
the IE Statlink database) occurred twice in 2008 and 2012 where frozen shark fins were suspected
to be combined with frozen shark meat in 2008 to 2011. A lack of accurate interpretation of thatdata from the Singapore government limited a more comprehensive ten-year trade data analysis.
Nevertheless this report is the first proper detailed report for Singapore, where assessments in thepast have been global overviews. It provides some insight into trade dynamics over the 10 year
period, but focuses on more detailed analysis for two consecutive periods over six years, from 2005
to 2007and from 2012 to 2014.
Imports and exports of shark fin
Analysis of FAO data for the world’s top 20 shark trading countries highlights that Singapore was
the world’s second-largest importer and exporter of shark fins in value terms, after Hong Kong, forboth time periods of 2005 to 2007 and 2012 to 2013. Average imports and exports of all shark fin
products increased by 43.6 % and 29.9% respectively, when comparing data for both time periods.
Exports recorded a high of 2422 t from 2012-2013, representing 10.3% of the total world export andmaking Singapore the second largest exporter after Thailand. Import recorded at a high of 2702 t
for the same period, representing 13.3% of the world imports, ranking it as the world’s third largest
importer, after Malaysia and Hong Kong. Prices for exports and imports over the two assessed
periods however, decreased by 51% and 44.6% respectively. Despite this, Singapore still occupied
the world’s second highest rank in trade values. The lack of distinction between frozen and dried
shark fins - the former of which can weigh four times as much as dried fins due to additional watercontent – requires further scrutiny for a more accurate representation of the trade volume, including
potentially higher volumes of trade. Singapore does not have a domestic shark fishery and domestic
export of locally processed shark fins makes up only 2.6% of the total export. Singapore definesdomestic exports as either primary commodities grown or produced in Singapore or goods whichhave been transformed, that is, manufactured, assembled or processed in Singapore; its classifies all
domestic exports of shark products as products of processors in Singapore.
Analysis of Singapore-specific data from IE Statlink showed that Singapore imported 14 114
tonnes (averaging 2352 tonnes/year) and exported a total of 12402 tonnes (averaging 2067 tonnes/
year) of shark fins over the six years studied. Trade was recorded with a total of 68 countries andother unspecified countries from Africa, Americas, Oceania and Asia. Numbers of both export
and import trading partners decreased, when comparing 2005 to 2007 and 2012 to 2014. Exports
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headed mostly to countries within the Asia-pacific region, with 99.2% and 99.996% of the total
volume of exports heading to countries within the Asia-pacific region in 2005 to 2007 and 2012
to 2014 respectively. The top three destinations was dominated by China (Hong Kong, mainland
China and Taiwan), making up 71.3% of total exports, with Hong Kong receiving the lion’s share ofSingapore’s shark fins for both periods. Shark fin imports on the other hand originated from outside
this region, the top three countries in descending order being Spain, Uruguay and Namibia, making
up 59.6% of total imports. Hong Kong and Spain remained the largest importer and exporter for
shark fins to and from Singapore, for both time periods. Namibia emerged as a new source country
for Singapore recorded from 2012.
Shark species in trade
Trade in CITES listed sharks as recorded for the past 10 years on the CITES trade database revealed
that of the 30 shark species listed on CITES, five species of shark were reported to be traded bySingapore: Basking Shark Cetorhinus maximus, Porbeagle Lamna nasus, Oceanic Whitetip Shark
Carcharhinus longimanus, Scalloped Hammerhead Shark Sphyrna lewini and Great Hammerhead
Shark Sphyrna mokarran. Basking Sharks were all imported from New Zealand, with one recordof re-export to Hong Kong, while the Porbeagle was imported exclusively from Spain. Collectively,
more than 3000 kg from the five species were traded during the period assessed.
Beyond the CITES-listed species in trade, it was not possible to determine specific volume of tradeby species based on FAO data, however interview with Singapore’s Marine and Land Product
Association, the country’s largest shark traders association, stated that shark fin from the Blue Shark
Prionace glauca dominated the market, which comprised as much as 70% of the market. Other key
species traded includes Mako Isurus spp., various requiem sharks (Carcharhinus spp.), School Shark
Galeorhinus galeus, Spotted Estuary Smooth-hound Mustelus lenticulatus, guitarfish, thresher sharks
and dogfish sharks.
Import and export of shark meat
For shark meat, according to FAO data, Singapore moved up the ranks: from being the 18th biggest
exporter of meat by volume in 2005 to 2007 to the 14th biggest exporter by volume in 2012 to 2013.
Singapore was the 14th biggest importer of meat by volume for both time periods. Analysis ofnational trade data showed that Singapore exported a total of 6116 t of shark meat, while imports
recorded a total of 7213 t, over the six years assessed. A comparison of this data for the two time
periods of 2005 to 2007 and 2012 to 2014 showed that average annual exports and imports bothdecreased by 36.0% and 31.3% by quantity respectively while prices for exports and imports also
decreased by 34.8% and 46.0% respectively – this trend is inconsistent with suggestions by FAO
in 2015 that shark meat, while currently under-utilized by international markets, was predicted to
expand. Future monitoring of this aspect is required to determine shark meat trade dynamic.
Contrary to the trade in shark fins, domestic export of locally processed shark meat makes up 76.7%of the total export. Over these six years, Singapore traded shark meat with a total of 51 countries
and other unspecified countries from Africa and Europe. As with the shark fin trade trend, the total
number of trading partners has decreased over time. The top three destinations of shark meat fromSingapore were The Republic of Korea, Brazil and Italy, which make up 62.6% of total exports, with
Brazil only being a new destination from 2012; top three sources of shark meat imports on the other
hand were Taiwan (which alone constituted 55.4% of total imports), followed by The Republic ofKorea and Mauritius; collectively these three countries made up 68.6% of total imports. The speciesof shark meat traded through Singapore is unknown and there were no CITES listed species for the
shark meat trade recorded on the CITES trade database2.
1 “The term “shark and rays” refers to all species of sharks, skates, rays and chimaeras (Class Chondrichthyes).
2 This is not surprising given the recent listing of species most likely to be in trade to and from Singapore did not come into effect until September 2014.
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Import and export of rays and skates
Harmonised Systems Code (or HS Code) is a six-digit international nomenclature developed by
the World Customs Organisation (WCO) for the classification of goods and is used globally tomeasure and classify products in trade. These commodity codes for rays and skates only came into
effect in 2012. From 2012 to 2014, Singapore traded ray and skate products with 21 countries, withneighbouring Malaysia and Indonesia being the two predominant trading partners for both importand export. Export volumes decreased by 70.0% and number of export destinations increased fromthree to five. Domestic export volumes are small but are an indication of an existing processing
market. Import volumes were much higher at a maximum of 1650 t in 2014 as compared to
156 t of exports in the same year, which suggests that majority of the imports are for domestic
consumption. The number of source countries decreased from 15 to 11. Price of re-exported frozen
rays and skates decreased slightly by 17.1%. At the time of the assessment, Singapore did not have acommodity code specific to mobuild gill plates to allow analysis of that trade.

Rays found for sale in Singapore© Boon Pei Ya

CITES trade regulation
A total of 30 shark and ray species have so far been listed in CITES Appendix I and II. Of the 107
threatened ray and skate species, only eleven are listed in the CITES appendices. At the time of theassessment, Singapore only had product code listing for five Appendix II species, and none were inplace for the seven sawfish species listed in Appendix I or the Appendix II manta ray species.

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RECOMMENDATIONS
Globally, many shark and ray species are currently traded at levels that far exceed what can besustainably sourced. In addition, the current lack of genuinely sustainable shark and ray fisheriessystems, or adequate traceable systems with appropriate trade data recording, means that demand
for shark and ray products is inevitably being met from either unsustainable or entirely unknown
sources – this is the case with Singapore. Under-reporting is a primary concern. Although
Singapore submits annual reports to the CITES Secretariat, it is necessary for the government tobe able to report trade information at a much greater resolution given the fact that it is among
the world’s top three traders with much of the global trade going through Singapore. Therefore, afundamental and overarching recommendation from this study points to the need for the Singapore
government to go beyond minimum reporting requirements given the scale of the global trade
involving the country, and the need for more transparency and accountability. These are explained
further below.
Information in this report highlights the need for Singapore to immediately scrutinise current
practises including its HS codes for product types and species. For example, the HS Codes
corresponding to shark commodity categories that are reported to FAO do not completely matchwith the Singapore Trade Classification, Customs and Excise Duties (STCCED) codes for shark
products. Collection and reporting of accurate trade information by key exporters and importers
such as Singapore therefore is essential in making trade more transparent and traceable. Only thencan responsible consumer choices be effective in reducing directed fisheries in sharks and rays.
However, the current incomprehensive reporting system lends itself to suspicions regarding thecountry’s trade from unsustainable and untraceable sources. The elucidation of re-export volumes
is particularly important to monitor domestic consumption, which is currently not possible using
current customs statistics. Distinct commodity codes have been used in Hong Kong for example,
the word’s prominent shark trader, which allows for a more accurate and consistent indication of thescale of the trade.
The geographic position of the country as a leading trade entrepôt also requires robust tradecontrols and interventions to ensure responsible trade in shark and ray products globally. Theinternational momentum and accountability requirements from key trading countries provides themuch needed justification for Singapore to put in place, immediately, a recording and reporting
mechanism to regulate its shark and ray trade, specifically in an effort to proactively minimise therisk or any speculations that Singapore is contributing to the global shark crisis.
1) Establish at least four product-specific codes
At the time of the assessment, product-specific codes were not separated into at least four categories:
unprocessed dried, processed dried, unprocessed frozen and processed frozen. In order to monitor
levels of shark trade, there needs to be distinct commodity codes for shark fin and meat products:
unprocessed dried, processed dried, unprocessed frozen and processed frozen. These codes allow
adjustments for double-counting, where for example, fins are first imported as a raw product toSingapore and re-exported to another country for processing which may be then re-imported toSingapore for sale. With the predicted emerging market for mobuild gill rakers, there was also asimilar need to set up a distinct commodity codes for this product in order to better monitor its
trade. Since this analysis was completed, the Agri-Food and Veterinary Authority of Singapore(AVA), the national CITES management authority, has reported to TRAFFIC that product-specificcodes have been established, including for gill rakers.
2) Establish recording systems for CITES Appendix I and II listed species
At the time of the assessment, Singapore only had product trade codes for five of the 30 CITES
Appendix I and II listed species and therefore, establishing product trade codes for the remaining
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species was a priority; recording systems should have species-specific codes that cover all CITES
Appendix I and II species and species categories. AVA has since reported to TRAFFIC that codes
for rays were established since December 2016; details which are currently unknown at present.
As these species have been subjected to a CITES oversight and regulation process, such informationis critical to ensure accurate and transparent monitoring of all CITES-listed species, and that trade
is conducted in a legal and sustainable manner. This is in addition to the necessary CITES permits
from AVA for the import and export of CITES-listed species. Future monitoring and analysis ofsuch information will enable a better understanding on the scale of the trade.
3) Revisit product codes established by the World Customs Organization (WCO)
Modification of the commodity coding system for shark products set by WCO is necessary in orderfor meaningful trade monitoring to continue. The aforementioned product-specific commodity
codes should be considered by the WCO, without which under-reporting will continue by theworld’s largest shark and ray trading countries/territories, which will impede regulatory systems.
Agri-Food and Veterinary Authority of Singapore (AVA), as the national CITES management
authority, should provide in-country support for these commodity coding changes at the WCO level
and also at the ASEAN level.

Sharks and rays found for sale in Singapore© Boon Pei Ya4) Collaboration with Stakeholders for improved traceability
Singapore Customs, AVA, the Marine and Land Products Association, traders, retailers andresearchers, are urged to co-operate to analyse all available data sources and collaboratively develop
management decisions and traceability systems for the shark and ray trade industry, which does
not currently seem to be present. In some cases, there appears to be inconsistent reporting oftrade data. As a start, availability of detailed trade data based on product specific codes, including
for those reported to have been recently established, as well as seizure data would enable a morecomprehensive understanding of Singapore’s trade dynamics. Traders, distributors and retailers
interested in offering certified-sustainable chondrichthyan products should also be actively engaged,
perhaps through the Marine and Land Products Association, to participate in constructing trademonitoring systems that support traceability and effective management.

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INTRODUCTION
Chondrichthyans (comprising sharks, rays and chimaeras) are one of the most speciose predators
today with top-down control of marine ecosystem structure and function. However, their life
history traits: typically slow growth, maturing late, and producing few young, result in them being
particularly vulnerable to overfishing and slow to recover from depletion. It is estimated that onequarter of chondrichthyans are threatened worldwide, with more than half facing elevated risk
(Dulvy et al., 2014) and a recovery in threatened shark stocks has not yet been observed (Anon.,2014). While an estimated one-third of threatened sharks and rays are subject to targeted fishing,some of the most threatened species have declined due to being secondary catch in fisheries
targeting other species (Dulvy et al., 2014). Chondrichthyan catch, which is targeted or a secondarycatch while targeting other fish species, is retained due to the high and sometimes increasing valueof chondrichthyan meat, fins, livers, and/or gill plates (Lack and Sant, 2009). The lack of effective
management is widespread throughout chondrichthyan fisheries; an assessment of 173 shark
populations, comprising 46 species with a high intrinsic biological vulnerability, found that 87% had
a high management risk and 13% had a medium management risk (Lack et al., 2014).
The global trade in shark commodities was estimated to be USD818.4 million in 2011—a figure
which is likely to be substantially below the true value (Dent and Clarke, 2015). Despite the sizeof the global market for shark-derived products, its key characteristics are relatively unknown due
to the difficulty in obtaining accurate information. Supply chains are not well understood, and inmany cases the roles that individual countries/territories play in the production, trading, processing
and consumption of shark products have not been described in any detail.
Singapore has long been known as an important “port of call” for traders. Due to its strategic
geographic location, robust financial and trading infrastructure, and reliable legal, regulatory,
and tax framework, Singapore has emerged as Asia’s most important commodities trading hub(Tay, 2015) and is the 14th largest merchandise exporter in the world (Anon., 2015a). Singapore’s
importance as a major entrepôt also applies to the shark and ray trade. However, Singapore’s
relevant trade data have yet to be assessed in detail. This is essential as trade analysis can aid
regulation compliance monitoring and interpretation of overall stock status (Clarke, 2014). The
purpose of this study is to assess the trade information available within Singapore to monitor thecountry’s role in the global shark trade better. This will in turn inform regulatory mechanisms to
restrict the access of illegal and unsustainable shark products to Singapore’s market.

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International Trade in Sharks and Singapore
The types of shark commodities in international trade are diverse and include meat, fins, skin, oil,
cartilage, jaws and teeth (Figure 1). The greatest quantity by weight of shark product traded is in theform of shark meat while shark fins are the most valuable (Clarke, 2004). The world’s major shark
producers generally export both shark meat and fins but the markets for these two commodities
are largely distinct from each other, with little overlap between importers (Dent and Clarke, 2015).
Skates and rays are suspected to constitute a sizeable proportion of the shark meat trade, and whilesome species of ray fins are highly prized by shark fin traders, it is currently not possible to detect
the presence of rays in the fin trade (Dent and Clarke, 2015). A recent trend in the traditional
Chinese medicine (TCM) industry to use Mobulid ray gill plates — product name ᖬʷ╂Peng Yu
Sai — as a health tonic and/or medicine for illnesses ranging from Chicken Pox to cancer (Hilton
and O’Malley, 2011) has led to the emergence of its widespread trade and correspondingly increased
landings of mobulids in the past decade (Ward-Paige et al., 2013; Whitcraft et al., 2014). Shark liver
oil and shark skin, which is used for leather, are also traded but in relatively minimal quantities.
Moreover, skates and rays did not have a dedicated Harmonized Systems Code (or HS Code, a sixdigit international nomenclature developed by the World Customs Organization (WCO) for theclassification of goods and is used globally to measure and classify products in trade) before 2012,
and therefore extremely limited trade data on these products are available as they are often recorded
under aggregated seafood commodity categories (Dent and Clarke, 2015).
The following sections mainly focus on the two main products internationally traded: shark fins andshark meat, and a brief overview of the current state of the mobulid (manta and mobula rays) ray
gill plate trade and Singapore’s role in each.
Figure 1. Illustration of the range of products derived from sharks (Image sourced from Global
Guardian Trust, Japan)

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Shark Fins
Shark fins have been a traditional element of Chinese haute cuisine with a reputation for being
expensive and a status symbol, driving an Asian demand for shark fins (Clarke et al., 2007).
This particularly lucrative trade in fins (not only from sharks, but also of shark-like rays such as
wedgefish and sawfish) has been estimated to be worth USD400–550 million annually and equates
to 26 to 73 million individual sharks being killed for the largely unregulated trade (Dulvy et al.,2014).
According to statistics from the Fisheries and Agriculture Organization of the United Nations(FAO), Singapore was one of the principal destinations in East and Southeast Asia for shark finsfrom 2000 to 2011. The others were mainland China, Hong Kong Special Administrative Region(henceforth referred to as Hong Kong), Taiwan, Malaysia and Viet Nam. Reported chondrichthyan
landings and the trade in shark fin peaked in 2003–2004 and subsequently levelled out at quantities
17–18% lower in 2008 to 2011 (Dent and Clarke, 2015). The decline has been attributed to
overfishing (Davidson et al., 2015), with average shark exploitation rates long exceeding the averagerebound rate for many shark populations due to their late maturity and slow reproduction (Worm etal., 2013), and the same scenario is likely for manta rays Manta spp. (Dulvy et al., 2014). A decreasein market demand could be another factor leading to this decline: there have been new mainland
China austerity measures curbing government officials’ expenditures and backlash against artificial
shark fin products with the growing conservation awareness among consumers (Anon., 2015a).
There has also been increased regulation of finning and trade bans (Dent and Clarke, 2015). At thesame time, new figures suggest Thailand has surpassed Hong Kong as the world’s largest exporter,and its main trading partners—Japan and Malaysia—may be among the world’s top four importers,
particularly of small, low-value fins (Dent and Clarke, 2015).
Singapore is a global trading hub for shark fins, being the second-largest importer and exporter invalue terms after Hong Kong based on trade data reported to the FAO from 2000 to 2011 (Dentand Clarke, 2015). Similar to Hong Kong, Singapore is an importer and re-exporter with minimal
domestic shark production (Lack and Sant, 2010). From 2000 to 2011, Singapore took an averageof 10% and 9% share (equivalent to USD40 million and USD28.6 million) of total world imports
and exports of shark fins respectively (Dent and Clarke, 2015). Globally, by volume, Singapore isfourth (after Hong Kong, mainland China and Malaysia) for imports, and sixth (after Hong Kong,
Thailand, Indonesia, mainland China and Taiwan) for exports, with an average of 7% (1127 t) and5% share (864 t) of total world imports and exports by volume respectively (Dent and Clarke, 2015).
This reveals the relatively higher unit value of Singapore’s fin trade which is about USD35/kg forboth imports and exports (Dent and Clarke, 2015).
“Exporters”, mainly in the case of shark fins but also to a lesser extent in the case of shark meat,
includes both primary producers (such as Indonesia and Spain) that contribute to shark capture,and re-exporters. Singapore’s role as a re-exporter however is not well documented and it isunknown how much of this trade is pure trade or processing trade, the latter constitutes raw
products being imported, processed in Singapore then re-exported as a processed product; although
it is believed to be involved in processing to some extent (Dent and Clarke, 2015).
In March 2016, AVA reported that although there is no domestic shark fishery, there is occasional
incidental shark landings by local fishing vessels and more importantly, there are landing of sharks
by foreign flagged fishing vessels which operate on the high seas (J. Yap, AVA, in litt. to P. Boon,
April 2016).

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Shark Meat
Consumption of shark meat has been recorded since the fourth Century (Vannuccini, 1999).
Although shark meat is currently eaten in many parts of the world, there are some countries
with customer resistance to the meat which has led some sellers intentionally to mislabel sharkmeat to overcome this cultural barrier to its consumption (Bornatowski et al., 2010). Althoughchondrichthyan capture production peaked in 2003–2004, there has been steady growth of the
shark meat trade at 4.5% per year from 2000 to 2011, which suggests that shark meat was previously
under-utilized by international markets, although they are likely to continue to expand (Dent andClarke, 2015). This increase in trade may be due to the wider application of restrictions on sharkfinning3 which, if complied with, requires the landing of the shark meat associated with the fins.
If the same amount of fins are landed as previously by a fisher then this will translate into larger
quantities of shark meat available for trade (Dent and Clarke, 2015). The increase in trade of sharkmeat may also be related to the relative drop over time in the cost of shipping frozen product aroundthe world.
The world’s largest consumers of shark meat are found in South America and Europe, with the mostimportant importers being Italy, Brazil, Uruguay and Spain (Dent and Clarke, 2015). The first two
countries import shark meat from large shark producers such as Spain and Taiwan while Uruguay is
an important importer of unprocessed shark meat from the same major producers and re-exporterof processed shark meat supplying the rapidly expanding Brazilian market (Dent and Clarke,2015). In general, compared to shark fins, markets for shark meat are much more diverse andgeographically dispersed, and are therefore predicted to have more potential for expansion (Dentand Clarke, 2015).
Prior to this current study, there was no reported analysis of the trade of shark meat in Singapore.

Rays and Skates
Ray and skate meat comprises more than half of the taxonomically differentiated chondrichthyan
landings over the past four decades. Five of the seven most threatened chondrichthyan families are
rays: sawfishes, wedgefishes, sleeper rays, stingrays and guitarfishes (Dulvy et al., 2014). Shark-likerays such as sawfish and wedgefish in particular are highly sought after for the fin trade (Dulvy et al.,2014) but a lack of trade data on skates and rays does not allow for their detection in the fin trade.
Most countries only started recording trade in ray and skate meat after a 2012 World Customs
Organization (WCO) recommendation for all 179 of its members to implement specific commodity
codes for it (Dent and Clarke, 2015).
Since at least the 1990s, a market for gill plates from manta and mobula rays has emerged andexpanded, driving the growth of targeted mobulid fisheries in Sri Lanka, India, Indonesia and thePhilippines (Croll et al., 2015). Manta or mobula gill plate trade was reported as an export tradefrom India, Indonesia, Mozambique and Sri Lanka (Dent and Clarke, 2015). Secondary markets
include mobulid cartilage and mobulid meat and skins (Heinrichs et al., 2011). The gill plates
trade was valued at an estimated USD30 million in 2013 (Whitcraft et al., 2014) with Guangzhou
the epicentre, representing over 99% of the market — trade involving Singapore represented
an estimated 0.28% of the total trade (Hilton, 2011). Singapore and Hong Kong have also been
identified as involved in intermediate stages of the gill plate trade (Mundy-Taylor and Crook, 2013).

3 The practice of removing the fins from sharks and discarding the remainder of the body.

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International Policy on Sharks and Related Legislation in
SingaporeFAO International Plan of Action for Sharks
The growing awareness of the precarious situation for shark populations led to the adoption of the
FAO International Plan of Action (IPOA) for Sharks by the FAO Committee on Fisheries (COFI)in 1999. It stipulated that shark fishing States should implement national programmes for theconservation and management of shark stocks through National Plans of Action (NPOAs) for
Sharks. Even though many major shark fishers have introduced conservation measures and alsojoined the international fight against illegal, unreported and unregulated (IUU) fishing, there has
been an overall slowness in implementing the IPOA for Sharks. Singapore has only been a memberof FAO since 15 June 2013 and is also a member of COFI.
CITESThe Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
was established as an intergovernmental agreement to ensure that the international trade inwild animals and plants does not threaten their survival. CITES subjects international trade in
specimens of selected species to certain controls; all import, export, re-export and introduction
from the sea of species covered by the Convention has to be authorized through a licensing system.
Each Party to the Convention must assign one or more Management Authorities to administer thatlicensing system and one or more Scientific Authorities to advise on how trade has impacted thestatus of the species.
According to the Convention, species listed in CITES Appendix I are those threatened withextinction and are prohibited from trade under all but exceptional non-commercial circumstances,
for instance for scientific research. Species listed in CITES Appendix II are not necessarily now
threatened with extinction but they may become so unless trade is closely controlled. Appendix II
listed species can only be internationally traded under permits authorized by national authorities.
Trade of species listed in CITES Appendix III are regulated in at least one country, which has asked
other CITES Parties for assistance in controlling the trade. Conditions of trade for species in eachof the appendices are shown in Annex I of this report. A total of 30 shark and ray species have so far
been listed in CITES (Table 1). It should be noted that of the 74 shark species and 107 ray and skate
species that are threatened (Dulvy et al., 2014), only 12 sharks and 18 ray and skate species are listed
in the CITES appendices.

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Table 1. Shark and ray species listed in the CITES appendices
Appendix I

Appendix II

Common Name

Scientific Name

Year listed in CITES

Dwarf Sawfish

Pristis clavata

2007

Small-tooth Sawfish

P. pectinata

2007

Southern Sawfish

P. perottet

2007

Common Sawfish

P. pristis

2007

Green Sawfish

P. zijsron

2007

Knifetooth Sawfish

Anoxypristis cuspidata

2007

Freshwater Sawfish

Pristis microdon

2014

Whale Shark

Rhincodon typus

2001

Basking Shark

Cetorhinus maximus

2001

White Shark

Carcharodon carcharias

2004

Oceanic Whitetip

Carcharhinus longimanus

2013

Silky Shark

Carcharhinus falciformis

2016

Scalloped Hammerhead

Sphyrna lewini

2013

Smooth Hammerhead

S. zygaena

2013

Great hammerhead

S. mokarran

2013

Porbeagle

Lamna nasus

2013

Bigeye Thresher Shark

Alopias superciliosus

2016

Pelagic Thresher Shark

A. pelagicus

2016

Common Thresher Shark

A. vulpinus

2016

Reef Manta Ray

Manta alfredi

2013

Giant Manta Ray

Manta birostris

2013

Giant Devil Ray

Mobula mobular

2016

Spinetail Devil Ray

Mobula japanica

2016

Bentfin Devil Ray

Mobula thurstoni

2016

Box Ray

Mobula tarapacana

2016

Pygmy Devil Ray

Mobula eregoodootenkee

2016

Shortfin Pygmy Devil Ray

Mobula kuhlii

2016

Atlantic Pygmy Devil Ray

Mobula hypostoma

2016

Lesser Guinean Devil Ray

Mobula rochebrunei

2016

Munk’s Pygmy Devil Ray

Mobula munkiana

2016

Despite the 30 shark and ray species listed in CITES Appendix I and II, very few countries/territories
report shark and ray species-specific trade data (Mundy-Taylor and Crook, 2013). Most CITES-listed
shark meat and fin trade is reported under more general shark commodity codes, which include: (a)fresh and frozen shark meat, (b) shark fins in various forms, and (c) other shark products including
dried and salted meat, frozen fillets and oil (Mundy-Taylor and Crook, 2013). There are no universal
ray-specific commodity codes that would include mantas, with trade in rays being reported undercodes for “Rajidae” or included in more general fish codes (Mundy-Taylor and Crook, 2013).
Singapore acceded to CITES in November 1986 and started its implementation on 9 February 1987
(Lye, 1999). Implementation of the Convention varies between Parties (Anon., 2015b). Singapore
was assessed by CITES as having a Category 1 legislation since March 2002, which means it has
legislation that is believed generally to meet the requirements for effective implementation of
CITES (Anon., 2002). The CITES management, scientific and enforcement authority of Singapore
is the same government agency: AVA. AVA maintains contact with the Marine and Land Products
Association (a shark traders’ association based in Singapore) on CITES issues and issues circulars andadvisories to seafood traders and declaring agents to inform them of new CITES listings of sharks
and rays and to comply with CITES requirements (J. Yap, AVA, in litt. to P. Boon, September 2015).

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Adherence to CITES is regulated in Singapore under the Endangered Species (Import and Export)
Act which became effective on 17 March 1989 (Lye, 1999). The Act requires a permit from the AVA
for the import, export, re-export or introduction from the sea of all CITES listed species. It provides
powers of search, entry, and seizure to facilitate investigation and enforcement. It was amended
in 1992 to provide for stricter control on domestic trade in endangered species. The inclusionof transshipment or transit cases in the Act came into effect in March 2006 when AVA was given
further enforcement powers to investigate goods in Free Trade Zones (FTZs) and enforcement
actions could be made based on the markings, labels or claims that a product contains a part orderivative of a CITES species, without having to prove that this part or derivative is actually present
in the product. The general penalty for breaches of this Act is a fine of up to SGD10 000 (USD7100)
or imprisonment for up to 12 months or both. The Act also states more specifically that any person
who trades or introduces from the sea any species without a permit or has in his possession orunder his control, or who sells, offers or exposes or advertises for sale, or displays to the public
such species imported or introduced from the sea without a permit may be fined up to SGD50 000(USD35 500) for each species (but not to exceed in the aggregate SGD500 000 (USD355 100) or
imprisonment for up to two years or both.
Other national legislations applicable to the shark and ray trade are the Fisheries Act and theWholesome Meat and Fish Act. The Fisheries Act regulates the marketing and distribution of fish
and the use and control of fishing ports and harbours. It states that any person who lands or sells
fish caught by use of poisons, explosives or trawl nets, or fish caught within prohibited areas, may
be fined up to SGD10 000 (USD7100) or imprisoned for up to 12 months or both. The Wholesome
Meat and Fish Act states that it is an offence to import, export or transship any fish product withouta licence and permit. The penalties for breaches, such as trade without a licence, include a fine of up
to SGD50 000 (USD35 500) or imprisonment for up to two years or both.
In accordance with Singapore’s Regulation of Imports and Exports Act 1995, all commercial import,
export, re-export consignments of both CITES and non-CITES listed wildlife have to be declared
through TradeNet. TradeNet is an online platform that facilitates the exchange of information
within the trade and logistics community led by Singapore Customs, the Infocomm Development
Authority of Singapore, the Economic Development Board and the enterprise development agency,
SPRING Singapore. All import and export declarations which have been approved by Singapore
Customs are compiled through the trade statistics website, IE Singapore Statlink, since 1 April 2003.
These data exclude postal packages which are based on particulars furnished by the Singapore Post
Pte Ltd and goods supplied to non-Singapore registered aircraft, stores and ships.
Compliance-monitoring Systems for sharks
Within Singapore, AVA works together with Singapore Customs, the Immigration and Checkpoints
Authority of Singapore (ICA) and the Singapore Police Force to implement import control systems.
AVA staff from the wildlife section and the import and export regulation department are trainedin shark fin identification of CITES listed shark species, both using morphological identification
and DNA testing (Lye F.K., AVA, pers. comm. to P. Boon, June 2015). However, AVA has expressedthat sharks are generally not traded in whole body form, but as processed products, such as fillets,
dressed meat or fins. This makes it challenging to identify and differentiate such parts and productsof CITES-listed shark species from other shark species and for Customs or checkpoint officers
effectively to enforce the CITES listing (Yap, 2015). CITES shark product seizures have taken placeover the past 10 years (Lye F.K., AVA, pers. comm. to P. Boon, June 2015) but seizure data were notmade available to TRAFFIC.

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© Willtu | Dreamstime.

Great white shark

METHODSThis report is based on work carried out between March 2015 and April 2016; interviews with theMarine and Land Products Association were held in April 2016. The collection of trade data fromvarious agencies underpins the key analysis of Singapore’s role in the shark and ray trade, which
took place between March–October 2015. A review of published and unpublished literature wascarried out. The libraries and databanks of the following institutions were of particular help:• FAO fishstat◉ For comparison with global trade• IE Statlink (the Singapore government trade statistics body)◉ For Singapore’s trade data: all shark and ray trade data from all trading partners• CITES Trade Database◉ For Singapore’s CITES listed trade data
• Trade Map, International Trade Centre◉ For counter-checking trade data recorded by Singapore’s trade partners
Other methods used include a combination of desk-based analysis and interview-based
consultations.

Interviews
Formal and informal interviews were held with representatives from the following organizations:• CITES Scientific and Management Authority: Singapore Agri-Food and Veterinary Authority(AVA)• Marine and Land Product Association

Data analysis
All financial data reported in nominal prices were adjusted for inflation using food consumer priceindices (CPIs) from the Monetary Authority of Singapore with a common base year (2005), before
being converted to USD.
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RESULTS AND DISCUSSION
There is no shark fishery in Singapore (F. Lye, AVA, in litt. to P. Boon, June 2015) and all shark
products traded stem from imports. In the national trade statistics, domestic exports are definedas either primary commodities grown or produced in Singapore or goods which have beentransformed i.e. manufactured, assembled or processed in Singapore; re-exports refer to all goods
which are exported from Singapore in the same form as they had been imported without any
transformation. Singapore therefore classifies all domestic exports of shark products as products ofprocessors in Singapore.

Singapore’s Role in the Global Chondrichthyan Trade
Research on the FAO Fishstat database, based on the International Standard Statistical Classificationof Aquatic Animals and Plants (ISSCAAP) Code 38 for sharks, rays and chimaeras, showed thatin 2005 to 2013, Singapore recorded an average 3.8% of total world exports of chondrichthyans involume terms and 9.2% by value (3665 t or USD52 million), while the equivalent figures for world
imports were 3.6% of volume and 10.2% of value (4467 t or USD64 million). No FAO data wereavailable for 2014 at the time of this study. It should be noted that FAO import data may include
double counting of imports which transit through a third country (i.e. re-imports will be counted
as imports twice) (Dent and Clarke, 2015). There were only four commodity categories in thechondrichthyan trade data declared by Singapore to FAO. These categories and the corresponding
HS code/s used by Singapore’s national trade database IE Statlink are shown in Table 2 (J. Yap, AVA,in litt. to P. Boon, September 2015).
Table 2. FAO commodity categories and corresponding Trade Codes (latest, 2012 edition) usedby Singapore’s national trade database IE Statlink
FAO commodity category

HS CodeHS Description

Shark fins, dried, salted, etc.

03055920

Marine fish dried but not smoked• Shark, dried, salted• Shark porbeagle, dried, salted• Shark scalloped hammerhead, dried, salted

Shark fins, prepared or preserved

16042019

Sharks fins for immediate consumption not in airtight containers (see Table 3 for product details)

Sharks nei, fresh or chilled

03028100

Dogfish and other sharks fresh or chilled excl livers
and roes (see Table 3 for product details)

03044900

Other fish fillets fresh or chilled• Shark fillet/cut, chilled• Shark porbeagle, fillet/cut, chilled• Shark scalloped hammerhead, fillet/cut, chilled

03038100

Dogfish and other sharks frozen excl livers and roes(see Table 3 for product details)

03048900

Other fish fillets frozen• Shark fillet/cut, frozen• Shark porbeagle, fillet/cut, frozen• Shark scalloped hammerhead, fillet/cut, frozen• Shark basking fillet/cut, frozen• Shark great white fillet/cut, frozen• Shark whale fillet/cut, frozen

Sharks nei, frozen

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For the purpose of this report, the former two FAO categories were grouped and analysed as shark
fins while the latter two were grouped and analysed as shark meat. Due to a postulated change
in trade recording from 2008 to 2011 (i.e. as discussed in the next section, frozen shark fins werecombined with frozen shark meat), the analysis is restricted to focus on the two periods from 2005
to 2007 and 2012 to 2014. In the FAO data, as some countries/territories recorded rays and skatesin aggregate FAO categories that include shark meat, the shark meat analysis also includes ray andskate data.
Singapore recorded an average 10.3% of total world exports of shark fins in volume terms and 15.5%
by value (1697 t or USD42 million) in 2005 to 2007 and 17.9% in volume terms and 20.5% by value(2422 t or USD40 million) in 2012 to 2013. The equivalent figures for world imports were 11.8% ofvolume and 14.0% of value (2047 t or USD51 million) in 2005 to 2007 and 13.3% in volume terms
and 19.1% by value (2702 t or USD51 million) in 2012 to 2013. (Figure 2).
A comparison of FAO data of the top 20 shark fin trading countries/territories based on Dent
and Clarke (2015) revealed that Singapore moved from the 3rd biggest exporter of fins by volume
in 2005 to 2007 to the 2nd biggest exporter by volume in 2012 to 2013 (Annex II, Table II-1).
Singapore was the 3rd biggest importer of fins by volume for both time periods (Annex II, Table
II-2). By value, Singapore remained both the 2nd biggest exporter and importer of fins for both time
periods (Annex II, Table II-1 and Table II-2).
Figure 2. FAO annual global shark fin export (a,b) and import (c,d) from 2005 to 2013 byquantity (a,c) and price (b,d)

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For shark meat, Singapore’s exports were 1.4% of total world imports in volume terms and 1.2% byvalue (1240 t or USD3 million) in 2005 to 2007 and 1.2% in volume terms and 0.7% by value(1476t or USD2 million) in 2012 to 2013. The equivalent figures for world imports were 1.3% ofvolume and 1.0% of value (1418 t or USD2 million) in 2005 to 2007 and 2.1% in volume terms and1.0% by value (2665 t or USD3 million) in 2012 to 2013 (Figure 3).

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A comparison of FAO data of the top 20 shark meat trading countries/territories listed in Dent andClarke (2015) revealed that Singapore moved from the 18th biggest exporter of meat by volume
in 2005 to 2007 to the 14th biggest exporter by volume in 2012 to 2013 (Annex II, Table II-3).
Singapore was the 14th biggest importer of meat by volume for both time periods (Annex II, Table
II-4). By value, Singapore moved from the 18th biggest exporter of meat in 2005 to 2007 to the 17th
biggest exporter in 2012 to 2013 (Annex II, Table II-3) and moved from the 18th biggest importer ofmeat in 2005 to 2007 to the 14th biggest importer in 2012 to 2013 (Annex II, Table II-4).

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Singapore Trade Recording
Singapore’s national trade database IE Statlink, records trade for sharks and rays according to six HS
codes. It is subjected to amendments every four to six years. Countries/territories adopting the HS
Code may make provisions for further subdivisions beyond the 6-digit level. In 2003, the ASEAN
Harmonized Tariff Nomenclature (AHTN) was jointly developed by ASEAN member countries tofacilitate trade within ASEAN. Since then, the HS codes in the AHTN are harmonized at 8-digit
level across all ASEAN member countries. The Singapore Trade Classification, Customs and Excise
Duties (STCCED) are adopted from the AHTN. For the purpose of categorization for this report,
the 8-digit HS codes used in Singapore for shark products were further categorized into three sharkcommodities: shark fins, shark meat, rays and skates (Table 3).
It is noted that the HS Codes corresponding to shark commodity categories reported to FAO(Table 2) do not completely match with the STCCED 2012 HS Codes for shark products (Table 3).
Three HS Codes in STCCED 2012: Shark fins for immediate consumption in airtight containers(HS 16042011), Shark fins (HS 03057100) and smoked shark (HS 03054900) were not included in
the data provided to FAO. AVA could not clarify this matter before the publication of this report.

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Five aggregate HS codes in STCCED 2012: (HS 03044900, HS 03048900, HS 03054900, HS 03055920,
HS 03019939) consisting of 17 product codes were not included in this study’s analysis as data by CAcodes were not made available at the time of the study, and these aggregate HS Codes included CA
codes that were not shark or ray species.
Table 3. Trade Codes of shark and ray products used by Singapore’s national trade database IE
Statlink and corresponding categories. Orange highlights indicate HS code changes
affected how frozen shark fins were recorded; green highlights indicate product codes
not included in this analysis due to aggregate HS codes.
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   12 TRAFFIC Report: The Shark and Ray Trade in Singapore

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Prior to 2007, shark fins were recorded under two basic categories: a general shark fin category
which covers shark fins not for immediate consumption; and another category covering prepared,
ready for use shark fins. In 2007, the latter category was split into two further categories: shark finsfor immediate consumption in airtight containers, and not in airtight containers. According to
the 2012 edition of seafood product codes, the general shark fin code (HS 03057100) and the code
covering shark fins for immediate consumption not in airtight containers (HS 16042019), eachconsists of both frozen and dried fins (Table 3). As trade data were only available by HS codes andnot CA codes, data adjustments could not be made to correct for frozen fins which are four times
heavier than their dried equivalents (Dent and Clarke, 2015).
A drastic decrease in trade of prepared shark fin quantities from 2008 to 2011 (Annex IV, FigureIV-1) along with an associated increase in frozen shark meat export (Annex IV, Fig IV-2) during
the same period led Dent and Clarke (2015) to postulate that frozen shark fins were reported as
prepared shark fin through 2007 and then as frozen shark meat from 2008 to 2011 (Dent andClarke, 2015; Figure 4). The same Dent and Clarke (2015) report stated that in 2012, Singapore’s
shark commodity coding system underwent another revision that removed the specification of“dried” from the description of the general (unprepared) shark fins code. The sharp increase inreported traded quantities of shark fins in 2012 as compared with dried shark fins in 2011, andresults of Dent and Clarke’s (2015) comparison of trading statistics between Singapore and Hong
Kong, led to a postulation that frozen shark fins were moved from the commodity code for frozen
shark meat to the general shark fins code in 2012 (Figure 4).

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Figure 4. Diagrammatic representation of the postulated Singapore commodity code revisions
in 2007 and confirmed code revisions in 2012. SF = shark fins; SM = shark meat.

In this study, AVA and Singapore Customs were consulted on the postulated commodity coderevisions. Singapore Customs claimed that frozen shark fins were classified under the same HS code
as frozen shark meat in all the three versions of the STCCED i.e. 2003, 2007 and 2012 that covered
the 10 years timeframe of this analysis (D. Chia, Singapore Customs, in litt. to P. Boon, September2015). Nonetheless, a comparison of the May 2011 and January 2012 product code list provided by
AVA showed that frozen shark fins were first recorded as frozen shark meat (HS 03037500) before
January 2012 and then recorded as general shark fins (HS 03057100) after January 2012 as postulated
by Dent and Clarke (2015) (Table 3, Figure 4). We were not able to obtain the product code list
before 2007 to check on the other postulated commodity code changes during that period before thepublication of this report.
A check of the monthly trade data for the three commodity codes suspected to be affected showedthat changes in trade volumes started in January of 2008 and January of 2012, which provides
additional evidence for Dent and Clarke (2015) FAO’s postulation, as opposed to changes in tradevolumes by market forces for example. Moreover, unit values of frozen shark meat (HS 03038100)
suddenly increased in 2008 and dropped again to pre-2008 levels in 2012 (Annex IV, Figure IV-2).
Given that shark fins have a much higher unit value than shark meat, this supports the postulationthat frozen shark fins were categorized with frozen shark meat during the period 2008 to 2012.
Trade data of mobulid gill plates cannot be obtained as the HS Code specific to this commodity was
not yet in place during this assessment. These are likely to be recorded under a generic HS 03057900“Other edible fish offal” which covers CA products 1) fish bone, 2) fish gill/fin/lip/guts, and 3) fishskin.
IE Statlink covers trade data of all products while trade data for CITES-listed products were obtained
from the CITES trade database. CITES shark product codes in AHTN are presented in Table 4. Aswith the non-CITES products, trade data by product codes were not available form IE Statlink orother sources. Trade route data i.e. air, land or sea, were also not available from IE Statlink.

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Table 4. CITES Shark and Ray Product Codes in the ATHNHS CodeProduct Code

Product Description

CITES
Appendix

Unit
Quantity

Fish Skin, Leather
41039000

CPP0NDASP

Stingray species-

pieces41039000

CPP0NSHARK

Non-CITES shark species-

pieces41139000

CPP0NPRGLBlue shark (Pronace glauca)-

pieces41139000

CPP0NDASP

Stingray species-

piecesShark Bone, Teeth (non-consumption)
05069000

CPP0NSHARK

Non-CITES Shark bone-pieces

96011000

CPP0NSHARK

Non-CITES Shark teeth-

piecesGame Trophy and Collection
97050000

CPP0NSHARK

Non-CITES Shark teeth-

pieces97050000

CPP2NCACA

Great white shark (Carcharodon carcharias)

2

pieces

The following sections present the results of general trade trends per the three shark and raycommodities.

Trade in Shark Fins
As a result of the difficulty in accurately estimating Singapore’s trade in the four-year period from2008 to 2011 (i.e. as discussed above, frozen shark fins were combined with frozen shark meat), thissection restricts its focus to the period from 2005 to 2007, and also the years 2012 to 2014. All shark
fins are traded through Singapore via shipping (M. Foo, Marine and Land Product Association, pers.
comm. to P. Boon, April 2016).
Singapore imported 14 114 tonnes (averaging 2352 tonnes/year) and exported a total of 12402
tonnes (averaging 2067 tonnes/year) of shark fins over the six years studied. This trade was recordedwith with a total of 68 countries/territories and other unspecified locations (referred to as OC i.e.
“other countries”, in the figures) from Africa, Americas, Oceania and Asia. Exports headed to 23
countries and other unspecified country/s in Africa while imports originated from 65 countries/
territories and other unspecified locations from Africa, Americas, Oceania and Asia. Exports
headed almost exclusively to countries/territories within the Asia-Pacific region, which received
99.2% and 99.996% of exports in 2005 to 2007 and 2012 to 2014 respectively (Figure 5, Annex III).

The top three destinations were Hong Kong, mainland China and Taiwan, which combined made up
71.3% of total exports. Shark fin imports on the other hand originated from outside this region, thetop three sources in descending order being Spain, Uruguay and Namibia, which made up 59.6%
of total imports. Only 32.8% and 24.7% of total volume of imports were sourced from countries/
territories within the Asia-Pacific region in 2005 to 2007 and 2012 to 2014 respectively (Figure 6,
Annex III). Domestic exports consisting of entirely processed goods made up only 2.6% of the totalexport in the six years.

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Figure 5. Trade flow maps of annual average shark fin export quantity in 2005 to 2007 (top)and 2012 to 2014 (bottom) from Singapore. OC = “Other Countries” (unspecified
locations)

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Figure 6. Trade flow maps of annual average shark fin import quantity from top 30 source
countries/territories in 2005 to 2007 (top) and 2012 to 2014 (bottom) to Singapore.
OC = “Other Countries” (unspecified locations), BIOT = British Indian Ocean
Territory

When comparing the two time periods, average annual exports and imports both increased by
43.6% and 29.9% respectively (Figure 7, Figure 8a). The total number of trading partners decreased,from 19 countries/territories and unspecified locations in one region in 2005 to 13 countries/
territories in 2014; imports came from a maximum of 46 countries/territories and unspecified
locations from two regions in 2007 but dropped to a low of 27 countries/territories in 2014.

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The top three destinations for exports in 2005 to 2007 were Hong Kong, Taiwan and mainland
China which received 75.6% of all shark fin exports from Singapore, at an average of 952 t, 186 t
and 145 t of shark fins per year respectively; in 2012 to 2014, Hong Kong, mainland China andJapan took in 72.3% of all shark fin exports from Singapore, at an average of 1044 t, 412 t and 306 t
per year respectively (Figure 7a, Annex III). The top three sources of imports to Singapore in 2005
to 2007 were Spain, Uruguay and Taiwan, which were the source of 60.3% of Singapore’s shark fin
imports at 800 t, 254 t and 180 t respectively; in 2012 to 2013, the top three source countries were
Spain, Namibia and Uruguay, which were the source of 66.1% of Singapore’s imports at 853 t, 470 t
and 435 t per year respectively (Figure 7b, Annex III). It was previously reported that Singapore’s
imports from Spain grew rapidly from 4 t in 2000 to 1107 t in 2007 (Dent and Clarke, 2015).
However, the current findings from 2012 to 2014 seem to suggest that this increase has levelled off.
It is also interesting to note that there were no import data from Namibia before 2012.

 

Due to the changes in trade recording
in 2007 and 2012, unit value trends
Figure 7. Top 10 destinations (a) and sources (b) of sharkby commodity are not conclusive
fin to and from Singapore respectively, with
(Annex IV). The unit values calculated
countries/territories listed in rank order.
from aggregate prices of shark fin
commodities on the other hand showedthat although exports and import       
quantities both increased, re-export(%%%
prices decreased 51% from an average

'*%%
of USD24.2/kg in 2005 to 2007 to
!

USD11.9/kg in 2012 to 2014 while pricess '%%%
"&*%%for imports decreased 44.6% from an
&%%%average of USD24.6/kg in 2005 to 2007
*%%to USD13.6/kg in 2012 to 2014.

'%%*

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The Marine and Land Product 
Association, during an interview,     
provided their insights into the species

(%%%
  "of sharks in the fin trade through'*%%
Singapore; interviews were not verified
!
'%%%

through actual trade records as these&*%%
were not made available. Trade was

&%%%

stated to be dominated by Blue Shark
*%%

Prionace glauca, which comprised as%much as 70% of the market. The secondd most traded species was said to be makooIsurus spp., which comprised 10% to
15% of the market. Other species traded
were reported to be various requiem
sharks (Carcharhinus spp.), School Shark
Galeorhinus galeus, Spotted Estuary Smooth-hound Mustelus lenticulatus, guitarfish, thresher sharks
and dogfish sharks. Fins of chimaera elephant fish Callorhinchus milii were also sold as shark finsthough they are not a shark species (M. Foo, Marine and Land Product Association, pers. comm. to
P. Boon, April 2016).
The reported dominance of the shark fin market in Singapore by Blue Sharks is consistent with

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   

findings from the Hong Kong market (Clarke et al., 2006), which is the largest shark fin trader in theworld and the top destination of shark fin exports from Singapore. Blue Sharks are listed as Near
Threatened, while mako, thresher sharks and some species of dogfish sharks are listed as Vulnerable(IUCN, 2016). Blue Sharks are one of the most productive shark species, forming the majority
of secondary shark catch in pelagic longline fisheries targeting tuna and swordfish, although theimpact of the shark fin trade on this species
is still unknown. The other shark species
traded are listed as Near Threatened or
Figure 8. Quantity (a) and unit value (b) ofleast concern, both statuses being of lower
shark fins imported, re-exported
and exported domestically through extinction risk than Vulnerable. However,it should be noted that Chinese market
Singapore.
categories for shark fins which apply in




  

Singapore, are organized primarily by  
the quality of fin rays and secondarily by
distinguishing features of dried fins (Clarke
et al., 2006). Further confirmatory studies
are needed to verify matches between market
categories and actual taxonomy.





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

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









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














  
     

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

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





Trade in CITES-listed sharks as recorded forthe past 10 years in the CITES trade databaserevealed that fins of five species of sharks
were reported to be traded by Singapore:
Basking Shark, Porbeagle, Oceanic Whitetip
Shark, Scalloped Hammerhead Shark andGreat Hammerhead Shark. The Basking
Shark fins were all imported from New
Zealand, the Porbeagle fins from Spainand the Oceanic Whitetip and Scalloped
Hammerhead Shark fins from Sri Lanka.
All CITES-listed shark fin exports fromSingapore were to Hong Kong and theseincluded fins from Basking Shark, Porbeagle
and Great Hammerhead Shark (Table 5).

Very little shark fin processing occurs in
Singapore for export purposes; a telephonesurvey of seafood importers and processers
in Singapore found through the TradeSeafood Industry Directory (http://www.
trade-seafood.com/directory/) and other sources online revealed that only one of the seven
identified Singaporean companies carried out shark product (mostly fins) processing and this was
only for domestic sale; most of the others that were contacted claimed that processing in Singapore
was too expensive. Efforts to secure an interview and gather further information on this was not
successful at the time of the report completion. Nonetheless shark fin wholesalers in Singapore
carry out sorting and grading to value add to the products (M. Foo, Marine and Land Product
Association, pers. comm. to P. Boon, April 2016).

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Table 5. All CITES-listed shark fins traded by Singapore from 2005 to 2014. Where no unit isshown, the quantity number represents the total number of specimens.
Quantity Reported by
Year

App Species

Importer

Exporter

OriginImporter Exporter Term Unit

2005

II

Cetorhinus
maximus

6LQJDSRUH

1HZ=HDODQG







ÀQV

2006

II

Cetorhinus
maximus

6LQJDSRUH

1HZ=HDODQG







ÀQV

2007

II

Cetorhinus
maximus+RQJ.RQJ

6LQJDSRUH

1HZ=HDODQG





ÀQV

2013

III

Lamna nasus

6LQJDSRUH

6SDLQ-DSDQ





ÀQV

NJ

2014

II

Carcharhinus
longimanus

6LQJDSRUH

6UL/DQND







ÀQV

NJ

2014

II

Sphyrna lewini

6LQJDSRUH

6UL/DQND







ÀQV

NJ

2014

II

Lamna nasus

+RQJ.RQJ

6LQJDSRUH







ÀQV

NJ

2014

II

Sphyrnamokarran+RQJ.RQJ

6LQJDSRUH







ÀQV

NJ

The domestic consumption of shark fins in Singapore is estimated to be less than 10% of total
imports (M. Foo, Marine and Land Product Association, pers. comm. to P. Boon, April 2016).
Considering that this would be equivalent to 270 t of the 2704 t imported in 2012 to 2013, thisestimate is only slightly less than an earlier mid-2000s estimate of 300–400 t per year (or 900–1200 t
per year of unprocessed fins) (Clarke, 2005). In 2013, a representative of the shark fin trade industry
from the Marine and Land Products Association claimed that between 2011 and 2012, domestic
sales of shark fins to hotels and restaurants in Singapore fell by one-third and wholesale prices
decreased by 30 to 50% (Tan and Yeo, 2013). He gave the example of a processed Blue Shark fin
costing USD120/kg to USD160/kg while the unprocessed equivalent costs USD32/kg to USD48/
kg. In the mid-2000s, the reported average retail prices for processed shark fins was USD218/kg
to USD332/kg (Clarke, 2005). A request for updated wholesale prices for each shark fin market
category was made to the Marine and Land Product Association in 2016, however no data wereobtained before the publication of this report.

Trade in Shark Meat
As with shark fins, due to the difficulty of accurately estimating Singapore’s trade in the four-year
period from 2008 to 2011, this section restricts its focus to the period from 2005 to 2007, and also
the years 2012 to 2014.
Analysis of national trade data showed that Singapore exported a total of 6116 t of shark meat, while
imports recorded a total of 7213 t, over the six years assessed. This trade was recorded with a totalof 51 countries/territories and other unspecified countries in Africa and Europe; exports headed
to 22 countries/territories and other unspecified destinations in Africa and Europe while imports
originated from 44 countries/territories and other unspecified locations in Africa. The top threedestinations for shark meat from Singapore were South Korea, Brazil and Italy, which made up
62.6% of total exports; the top three sources of shark meat imports were Taiwan, South Korea andMauritius, which made up 68.6% of total imports. Shark meat imports came from diverse sources,
with 85.1% and 75.3% of the total volume of imports coming from countries/territories within the
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Asia-Pacific region in 2005 to 2007 and 2012 to 2014 respectively (Figure 10, Annex III); 71.8% of
the total volume of shark meat exported was headed for Asia-Pacific countries/territories in 2005
to 2007, which decreased to 32.6% in 2012 to 2014 (Figure 9, Annex III). Contrary to shark fins,domestic exports of locally processed shark meat made up 76.7% of the total export.
The majority of shark meat processing involved filleting (M. Foo, Marine and Land Product
Association, pers. comm. to P. Boon, April 2016).

Figure 9. Trade flow maps of annual average shark meat export quantity in 2005 to 2007 (top)and 2012 to 2014 (bottom) from Singapore. OC = “Other Countries” (unspecified
locations)

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Figure 10. Trade flow maps of annual average shark meat import quantity from top 30 source
countries/territories in 2005 to 2007 (top) and 2012 to 2014 (bottom) to Singapore.
OC = “Other countries” (unspecified locations), BIOT = British Indian Ocean
Territory

When comparing the two time periods, average annual exports and imports both decreased by
36.0% and 31.3% respectively (Figure 11, Figure 12a). The total number of trading partners also
decreased, exporting to a maximum of 14 countries/territories in 2005 but to only five countries/
territories in 2014; imports came from a maximum of 24 countries/territories and unspecified
locations from 1 region in 2006 to 14 locations in 2014. The top three destinations for exports in2005 to 2007 were South Korea, Italy and Malaysia which took in 67.0% of all shark meat exports
from Singapore, at an average of 556 t, 180 t and 96 t of shark meat per year respectively; in 2012 to2014, Brazil, South Korea and Viet Nam took in 76.0% of all shark meat exports from Singapore, at
an average of 453 t, 88 t and 64 t per year respectively (Figure 11a, Annex III). The top three sourcesof imports to Singapore in 2005 to 2007 were Taiwan, OC Africa and Malaysia, which were the

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source of 75.2% of Singapore’s shark meat imports at 936 t (65.7% of total), 69 t, 66 t respectively;
in 2012 to 2013, Taiwan remained the top source, but with a big decrease in shark meat export
quantity to Singapore at 395 t (40.4% of total). The other two top sources were South Korea andMauritius at 168 t and 90 t per year respectively (Figure 11b, Annex III). Together, these top threesources supplied 66.7% of Singapore’s total shark meat imports.
Figure 11. Top 10 destinations (a) and sources (b) of shark meatto and from Singapore respectively, with countries/
territories listed in rank order.
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The price of fresh or chilled shark meat imports (HS 03028100) steadily increased from a low of
USD0.51/kg in 2006 to USD0.82/kg in 2014. There were no other clear trends in price of individual
shark meat commodities during the period studied (Annex IV). The unit values calculated fromaggregate prices of shark meat commodities on the other hand showed that domestic export prices
decreased 39.9% from an average of USD1.9/kg in 2005 to 2007 to USD1.1/kg in 2012 to 2014, while
prices for imports decreased 46.0% from an average of USD1.8/kg in 2005 to 2007 to USD1.0/kg in2012 to 2014 (Figure 12b).
An effort was made to inquire about species of shark meat traded through Singapore through a local
industry player. However, no information was provided before the publication of this report. There
was no CITES-listed shark meat trade recorded on the CITES trade database.

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24 TRAFFIC Report: The Shark and Ray Trade in Singapore

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Trade in Rays and Skates

+)*-

+)*,

+)*+

#'(

Commodity codes for rays and skates only came into effect in 2012 and there are no trade figures
before then (Figure 13). Singapore traded ray and skate products with 21 countries/territories,
importing from 17 countries/territories and exporting to six, with Malaysia and Indonesia being
the two major trading partners for both import and export. Export volumes decreased by 70.0%
over the three years from 523 t in 2012 to 156 t in 2014 (Figure 13a), though domestic exports
increased slightly from 61 t in 2012 to
Figure 13. Destinations (a) and sources (b) of
136 t in 2014 (Figure 13c). The number ofrays and skates to and from Singapore
export destinations increased from threerespectively, with countries/territories
to five over these three years assessed,
listed in rank order and the proportion
though export volumes to these newof domestic export and re-export of rays
trading partners are small (<0.2 t per
and skates from Singapore (c)year); import volumes were much higher
at 1430 t in 2012 to 1650 t in 2014 (Figure13b) and the number of source countries/'("$ # 
territories decreased from 15 to 11 over 
+)))three years. The price of frozen rays
$ 
*.))and skates (HS 03038200) re-exported decreased slightly from USD2.83/kg in*)))2012 to USD2.34/kg in 2014. There were!.))
no other clear trends in price of ray andskate commodities during the period)
studied (Annex IV).
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There was no trade in CITES-listed raysand skates recorded on the CITES trade
database. However, it should be notedthat of the 107 threatened ray and skate
species, only 11 are listed in the CITES
appendices.
There were no trade data specific tomobulid ray gill plates due to a lack of
a HS Code specific to this commodity,
which did not allow for any further
research into this trade. Further
comprehensive investigations into thedomestic market availability for mobulid
ray gill plates is required to determine
the true levels of trade involving
Singapore, while awaiting HS Codes to beestablished.

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The Singaporean Marine and Land Product Association claims that Singapore plays a very small
to negligible role in international mobulid ray gill plate trade (M. Foo, Marine and Land Product
Association, pers. comm. to P. Boon, April 2016). The Association similarly states that the domestic
market for mobulid ray gill plates is likely to be very small and most imports are likely to be reexported to Guangzhou in China (M. Foo, Marine and Land Product Association, pers. comm. to P.
Boon, April 2016). No trade data were made available to determine actual trade volumes.

Trade in Other Products
Over the past 10 years, the Great White Shark Carcharodon carcharias is the only species traded in
Singapore for products other than its meat or fins. Product types recorded in trade included teeth,bones and skulls. In 2011 and 2012 the products were reported to be for educational purposes andcircus or travelling exhibition purposes respectively. Note that it is possible that the three bones andthree skulls reported by the importer, USA, and the exporter, Singapore, respectively may be thesame traded product but termed differently by the two reporting countries.
Table 6. All other CITES-listed shark products traded by Singapore from 2005 to 2014. Whereno unit is shown, the quantity number represents the total number of specimens.

© Chen Dexiang

Quantity Reported by
Year

App Species

Importer

Exporter

OriginImporter Exporter Term Unit

2011

II

USA

Singapore

Australia

3520

Carcharodon carcharias

2011

II

Carcharodon carcharias

USA

Singapore

Australia

2011

II

Carcharodon carcharias

USA

Singapore

Australia

2012

II

Carcharodon carcharias

Singapore

2012

II

Carcharodon carcharias

Singapore

Bones
520

Teeth

3

SkullsAustralia

3

Bones

Australia

520

Teeth

Leopard Whipray

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CONCLUSIONS AND RECOMMENDATIONS
Globally, many shark and ray species are currently traded at levels that far exceed what can besustainably sourced (Grautigam et al., 2015). Moreover, the current lack of genuinely sustainable
shark and ray fisheries, or adequate traceability systems, means that demand for shark and ray
products is inevitably being met from unsustainable or entirely unknown sources (Grautigam etal., 2015). Collection and reporting of accurate trade information by key exporters and importers
such as Singapore is essential in making trade more transparent and traceable, which is expected
to increase the share of sustainably sourced shark and ray products. Only then can responsible
consumer choices be effective in reducing directed fisheries in sharks and rays (Grautigam et al.,2015).
Singapore is the second-largest importer and exporter of shark fins in value terms after Hong Kongbased on trade data reported to the FAO from 2005 to 2007 and 2012 to 2014. Taking into accountthe gaps in available data resulting from the reclassification of shark fins from 2008 to 2012, itappears that trade in shark fins through Singapore has been increasing. This is contradictory to theslight decrease in global shark fin trade from 2000 to 2012 (Dent and Clarke, 2015). It should be
noted however that current trade statistics held and provided by the various organizations are notharmonious and therefore do not necessarily accurately reflect the quantity of actual shark material
being traded. As such, apparent trends over time may be misleading. This is mainly due to the lackof distinction between frozen and dried shark fins, the former of which can weigh as much as fourtimes as much as dried fins (Clarke, 2004) due to additional water content. With current aggregate
commodity codes, it is not possible to adjust for weight by water content from reported quantities
of shark fin. Prepared and preserved fins may also contain ingredients other than shark fins such as
soup broth, which is currently not identified explicitly in trade records.
The decrease in unit values of shark fins in both imports and exports through Singapore should thus
also be interpreted with caution. Although this decrease could be indicative of a lower demand
for the commodity, it is not clear whether a low unit value points to a lower value of the shark finmaterial, which could be a result of its size or species, or whether it is because of a relatively higher
proportion of water content and/or other non-fin components. The only certainty from current
trade statistics is the number of trading partners, which have been decreasing for both imports andexports. There are however, new sources, most notably Namibia, the second largest source of shark
fins to Singapore in 2012 to 2014, with no trade to Singapore recorded in 2005 to 2007. The samegoes for British Indian Ocean Territory, though imported volumes are much lower than Namibia.
Singapore’s trading partners in ray and skate meat are limited to neighbouring countries Malaysia
and Indonesia. It is likely that the majority of imports are for domestic consumption as import
volumes are much higher than export volumes, with a maximum of 1650 t in 2014 for imports and523 t in 2012 for exports respectively. Domestic export volumes are small but are an indication ofan existing processing market. Given that South Korea has consistently been in the top three export
destinations of shark meat from Singapore and it is known to be a major global importer of raysand skates (Dent and Clarke, 2015), the high volumes of “shark meat” reported as exported to South
Korea yet the paucity of exports of rays and skates recorded to South Korea may be due to misslabelling of ray and skate meat as shark meat. A check on ITC’s Trade Map database did not reveal
any imports recorded by South Korea of frozen rays and skates from Singapore.

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*DSVDQG'HÀFLHQFLHV
Domestic Utilization
One of the gaps is the inability to calculate trends in domestic consumption. In Singapore, where
there is no shark capture production, the main difficulty lies in a lack of data on processing yields.
This is especially so for shark meat, as 76.7% of the total shark meat export is domestic export,
i.e. locally processed. As products are exported in a form that is more highly processed than theform in which the fish was landed, domestic consumption is not as simple as subtracting imports
from exports. Moreover, Singapore’s commodity codes aggregate product forms, which makes it
impossible to calculate domestic consumption even if processing yields were available. Althoughprocessing yields are not an issue for shark fins, of which Singapore is almost entirely a true trader,i.e. re-exports mostly do not go through processing, the lack of commodity codes that distinguishes
between processed and non-processed products makes it difficult to account for double countingof imports which transit through a third country (i.e. re-imports will be counted as imports twice).
This is true for all shark products without distinct commodity codes.
An effort was made to inquire about trends in domestic consumption of shark fins over the past ten
years through the Marine and Land Product Association, particularly regarding wholesale prices ofshark fins in Singapore and the domestic sales of shark fins to hotels and restaurants in Singapore.
However, they had no official statistics on domestic consumption trends. There thus seems to be alack of a reliable indicator of domestic consumption. A recent consumer survey conducted in 2015
found that over half of shark fin consumers in Singapore decreased their consumption in the past
12 months and 41% expect to decrease it further the following year (Anon., 2016). Only 18% of
respondents ate shark or ray meat in the past 12 months and out of those, 78% consumed shark finsoup, 39% had ray meat and 18% had shark meat (Anon., 2016).
For rays and skates, products are only recorded as aggregate forms: 1) fresh or chilled and 2) frozen,
with no commodity code specific to mobulid ray gill plate during the time of the assessment. Whilst
the Marine and Land Product Association estimates the domestic mobulid ray gill plate market tobe very small to negligible, data on product specific commodity code would be needed to identify
and verify trends in domestic consumption of gill plates.

Access to Trade DataAt the time of the assessment, certain trade data, such as those of CA product codes which havemore product and species specificity than HS code trade data, trade routes and enforcement actions
such as seizures, were recorded but not made available for this study. The older editions of productcodes prior to 2012 were also not made available to TRAFFIC. The relevant authorities are urged tomake these data publically available for analysis and subsequent identification of improvements thatcan be made to current trade monitoring methods.

Updates from AVA since January 2017
In January 2016, outside the assessment period, AVA reported to TRAFFIC that product specificcodes as well as HS Codes for all 30 CITES-listed species have been introduced in December 2016.
Codes for species-specific product codes under the categories of dried, frozen, chilled, canned andprocessed were established. This is further referred to in the recommendations section. AVA also
reported to TRAFFIC that it introduced a shark surveillance program in October 2014 to monitor
the import, re-export and transhipment of fins for CITES Appendix II listed sharks. This was done
to detect any possible non-compliance for species that were listed on CITES in 2013. Through this,it has conducted random DNA sampling of shark fin shipments to verify that shipments and theirdeclaration correspond. Each shipment of shark fins is required to be declared via the Customs
TradeNet system and accompanied by additional CITES permits (for CITES-listed species). To

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engage the industry, AVA organises meetings with the traders and also issues circulars to theseafood traders and declaring agents to inform them of the new CITES listing of sharks and rays
and to comply with CITES requirements. To enhance public awareness about CITES sharks andcompliance by the industry, AVA circulated an advisory notice on CITES sharks and rays at thefishery ports. AVA officers conduct checks based on TradeNet declarations and tip-offs and inspect
the fishes put up on sale at the fishery ports. Adhoc monitoring of sharks in trade is also conducted.

RECOMMENDATIONS
Globally, many shark and ray species are currently traded at levels that far exceed what can besustainably sourced. In addition, the current lack of genuinely sustainable shark and ray fisheriessystems, or adequate traceable systems with appropriate trade data recording, means that demand
for shark and ray products is inevitably being met from either unsustainable or entirely unknown
sources – this is the case with Singapore. Under-reporting is a primary concern. Although
Singapore submits annual reports to the CITES Secretariat, it is necessary for the government tobe able to report trade information at a much greater resolution given the fact that it is among
the world’s top three traders with much of the global trade going through Singapore. Therefore, afundamental and overarching recommendation from this study points to the need for the Singapore
government to go beyond minimum reporting requirements given the scale of the global trade
involving the country, and the need for more transparency and accountability. These are explained
further below.
Information in this report highlights the need for Singapore to immediately scrutinise current
practises including its HS codes for product types and species. For example, the HS Codes
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Basking sharkcorresponding to shark commodity categories that are reported to FAO do not completely matchwith the Singapore Trade Classification, Customs and Excise Duties (STCCED) codes for shark
products. Collection and reporting of accurate trade information by key exporters and importers
such as Singapore therefore is essential in making trade more transparent and traceable. Only thencan responsible consumer choices be effective in reducing directed fisheries in sharks and rays.
However, the current incomprehensive reporting system lends itself to suspicions regarding thecountry’s trade from unsustainable and untraceable sources. The elucidation of re-export volumes
is particularly important to monitor domestic consumption, which is currently not possible using
current customs statistics. Distinct commodity codes have been used in Hong Kong for example,
the word’s prominent shark trader, which allows for a more accurate and consistent indication of thescale of the trade.
The geographic position of the country as a leading trade entrepôt also requires robust tradecontrols and interventions to ensure responsible trade in shark and ray products globally. Theinternational momentum and accountability requirements from key trading countries provides themuch needed justification for Singapore to put in place, immediately, a recording and reporting
mechanism to regulate its shark and ray trade, specifically in an effort to proactively minimise therisk or any speculations that Singapore is contributing to the global shark crisis.
1) Establish at least four product-specific codes
At the time of the assessment, product-specific codes were not separated into at least four categories:
unprocessed dried, processed dried, unprocessed frozen and processed frozen. In order to monitor
levels of shark trade, there needs to be distinct commodity codes for shark fin and meat products:
unprocessed dried, processed dried, unprocessed frozen and processed frozen. These codes allow
adjustments for double-counting, where for example, fins are first imported as a raw product toSingapore and re-exported to another country for processing which may be then re-imported to
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Singapore for sale. With the predicted emerging market for mobuild gill rakers, there was also asimilar need to set up a distinct commodity codes for this product in order to better monitor its
trade. Since this analysis was completed, the Agri-Food and Veterinary Authority of Singapore(AVA), the national CITES management authority, has reported to TRAFFIC that product-specificcodes have been established, including for gill rakers.

2) Establish recording systems for CITES Appendix I and II listed species
At the time of the assessment, Singapore only had product trade codes for five of the 30 CITES
Appendix I and II listed species and therefore, establishing product trade codes for the remaining
species was a priority; recording systems should have species-specific codes that cover all CITES
Appendix I and II species and species categories. AVA has since reported to TRAFFIC that codes
for rays were established since December 2016; details which are currently unknown at present.
As these species have been subjected to a CITES oversight and regulation process, such informationis critical to ensure accurate and transparent monitoring of all CITES-listed species, and that trade
is conducted in a legal and sustainable manner. This is in addition to the necessary CITES permits
from AVA for the import and export of CITES-listed species. Future monitoring and analysis ofsuch information will enable a better understanding on the scale of the trade.
3) Revisit product codes established by the World Customs Organization (WCO)
Modification of the commodity coding system for shark products set by WCO is necessary in orderfor meaningful trade monitoring to continue. The aforementioned product-specific commodity
codes should be considered by the WCO, without which under-reporting will continue by theworld’s largest shark and ray trading countries/territories, which will impede regulatory systems.
Agri-Food and Veterinary Authority of Singapore (AVA), as the national CITES management
authority, should provide in-country support for these commodity coding changes at the WCO level
and also at the ASEAN level.
4) Collaboration with Stakeholders for improved traceability
Singapore Customs, AVA, the Marine and Land Products Association, traders, retailers andresearchers, are urged to co-operate to analyse all available data sources and collaboratively develop
management decisions and traceability systems for the shark and ray trade industry, which does
not currently seem to be present. In some cases, there appears to be inconsistent reporting oftrade data. As a start, availability of detailed trade data based on product specific codes, including
for those reported to have been recently established, as well as seizure data would enable a morecomprehensive understanding of Singapore’s trade dynamics. Traders, distributors and retailers
interested in offering certified-sustainable chondrichthyan products should also be actively engaged,
perhaps through the Marine and Land Products Association, to participate in constructing trademonitoring systems that support traceability and effective management

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Dulvy, N.K., Fowler, S.L., Musick, J.A., Cavanagh, R.D., Kyne, M., Harrison, L.R., Carlson, J.K., Davidson,
L.N.K., and Sonja, V. (2014). Extinction Risk and Conservation of the World’s Sharks and Rays. Elife
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Tan, A., and Yeo, S.J. (2013). Shark’s Fin Sales and Wholesale Prices Dive. Asia One. http://news.asiaone.com/
news/singapore/sharks-fin-sales-and-wholesale-prices-dive. Viewed 15th August 2015.
Tay, K. (2015). Singapore is most vital commodities trading hub in Asia, says IE. The Business Times(Singapore), 30th September 2015.
Vannuccini, S. (1999). Shark Utilization and Trade. FAO Fisheries Technical Paper 389. Rome: Food andAgriculture Organization.
Ward-Paige, C., Davis, B., and Worm, B. (2013). Global Population Trends and Human Use Patterns of Manta
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Whitcraft, S., O’Malley, M.P., and Hilton, P. (2014). The Continuing Threat to Manta and Mobula Rays: 2013-14
Market Surveys, Guangzhou, China., SOS and WildAid.
Worm, B., Davis, B., Kettemer, L., Ward-Paige, C., Chapman, D., Heithaus, M.R., Kessel, S.T., and Gruber, S.H.
(2013) Global Catches, Exploitation Rates, and Rebuilding Options for Sharks. Marine Policy 40:194–204.
Yap, J. (2015). CITES 28th Meeting of the Animals Committee. Conservation and Management of Sharks[Resolution Conf. 12.6 (Rev. CoP16)] Annex 9 - Reply from Singapore. AC28 Doc. 17.1.1. https://cites.org/
sites/default/files/eng/com/ac/28/E-AC28-17-01-01%20A9.pdf. Viewed 1st Feb 2016.

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APPENDIXANNEX I
Table I-1. Conditions of Trade Required under the different CITES Appendices(Sourced from Clarke, 2004)

34 TRAFFIC Report: The Shark and Ray Trade in Singapore

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ANNEX II
Table II-1. World Exports of Shark Fins, tonnes, 2005-2013 (FishstatJ, all shark fin types
summed, includes re-exports) 

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TRAFFIC Report: The Shark and Ray Trade in Singapore 35

TRAFFIC-sg-sharkray-trade.pdf .pdf 47

26/05/2017 10:08:04

Table II-2. World Imports of Shark Fins, tonnes, 2005-2013 (FishstatJ, all shark fin
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36 TRAFFIC Report: The Shark and Ray Trade in Singapore

TRAFFIC-sg-sharkray-trade.pdf .pdf 48

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Table II-3a. World Exports of Shark Meat, tonnes, 2005-2013 (FishstatJ, all shark, raysand skates meat types summed, includes re-exports) 

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TRAFFIC Report: The Shark and Ray Trade in Singapore 37

TRAFFIC-sg-sharkray-trade.pdf .pdf 49

26/05/2017 10:08:04

Table II-4a. World Imports of Shark Meat, tonnes, 2005-2013 (FishstatJ, all shark meattypes summed, including rays and skates)
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Table II-4b. World Imports of Shark Meat, USD1000, 2005-2013 (FishstatJ, all sharkmeat types summed, including rays and skates)

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38 TRAFFIC Report: The Shark and Ray Trade in Singapore

TRAFFIC-sg-sharkray-trade.pdf .pdf 50

26/05/2017 10:08:04

ANNEX III
Table III-1. Destinations of Singapore’s Shark Fin exports ranked by trade quantity.
Unspecified countries are highlighted; OC = other countries 
Average/ yr (t)

/ "!"!
73/+3.3
0 (!
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/22+337
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6 $'!
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7 $ !
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/+251/4 ".+0/1/5 !&&&%.+.13/6 !&$ $&%.+.12/7 )! $.+.12
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territory  
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/.22+17.
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Rank Country/  
territory

TRAFFIC Report: The Shark and Ray Trade in Singapore

TRAFFIC-sg-sharkray-trade.pdf .pdf 51

39

26/05/2017 10:08:04

Table III-2. Source of Singapore’s Shark Fin imports ranked by trade quantity.
Unspecified countries are highlighted; OC = other countries 
Rank Country/  
territory 
Average/yr (t)


Rank Country/  
territory

8
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40 TRAFFIC Report: The Shark and Ray Trade in Singapore

TRAFFIC-sg-sharkray-trade.pdf .pdf 52

26/05/2017 10:08:04

Table III-3. Destinations of Singapore’s Shark Meat exports ranked by trade quantity.
Unspecified countries are highlighted; OC = other countries  
Average/yr (t)- $# !112).,.
. #'
-4,)..,/ '"
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4 #//)2235 ! .2)043-, 
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  territory  
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Rank Country/
  territory

TRAFFIC Report: The Shark and Ray Trade in Singapore 41

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26/05/2017 10:08:05

Table III-4. Source of Singapore’s Shark Meat imports ranked by trade quantity.
Unspecified countries are highlighted; OC = other countries Country/Rank  
territory

2 +#
3 &
4 !,'
5  '(#6 )&()'7 %#
8 &)),9 ,#"&: #21 #"
22 #$#'
23 $)( $&
24 !$*#
25 & # 
26 $)(&
27 !%%#'
28 #((('29 ,!!'2: (#"31 "#32 &#$!,#'
33 34 #( #$"
35 !!*$&36 $&( $&
37 %)+)#
38 %#39 )("!
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42 +!#
43 &-!
44 #45 &#46 &"#,   
Average/yr (t)

:46.968
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69.:1953.62944.483
43.:7838.748
33.:4:
29.76829.174
27.:6127.77427.21125.95122.931
5.158
4.511
4.491
3.721
3.464
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1.918
1.844
1.781
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1.349
1.324
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1.131
1.131
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1 114

Country/Rank  
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

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3 $)( $&4 )&()'5 #
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21 $)(&
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23 %#24 ,#"&25 #((('26 &-!
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31 #"
32 "#33 #$#'
34 &#$!,#'
35 !%%#'
36 #,
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39 #-#
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3.992
3.861
3.83:
2.919
2.8:7
2.546
2.121
1.919
1.281
1.235
1.153

42 TRAFFIC Report: The Shark and Ray Trade in Singapore

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ANNEX IV
Shark Fins
Figure IV-1. Quantity and value per quantity of re-exports (a,d), domestic exports (b,e)
and imports (c,f) of shark fin commodities. Values have been adjusted for inflation.
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TRAFFIC Report: The Shark and Ray Trade in Singapore 43

TRAFFIC-sg-sharkray-trade.pdf .pdf 55

26/05/2017 10:08:05

Shark Meat

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44 TRAFFIC Report: The Shark and Ray Trade in Singapore

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Rays and Skates

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© Boon Pei Ya

Shark fin found for sale in Singapore

46 TRAFFIC Report: The Shark and Ray Trade in Singapore

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MAY 2017

TRAFFIC, the wildlife trade monitoring network,is the leading non-governmental organization
working globally on trade in wild animals andplants in the context of both biodiversity
conservation and sustainable development.
For further information contact:
TRAFFICSoutheast Asia Regional Office
Suite 12A-01, Level 12A, Tower 1,
Wisma AmFirst
Jalan Stadium SS 7/15
47301 Kelana Jaya
Selangor, Malaysia
Telephone: (603) 7880 3940
Fax : (603) 7882 0171
Website: www.traffic.org

UK Registered Charity No. 1076722,
Registered Limited Company No. 3785518.

is a strategic alliance of

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