GGT’S RECOMMENDATIONSON THE AMENDMENT PROPOSALSFOR CONSIDERATION AT THE EIGHTEENTH MEETING
OF THE CONFERENCE OF THE PARTIES TO CITES(Geneva, 2019)

GLOBAL GUARDIAN TRUSTGGT’S RECOMMENDATIONSON THE AMENDMENT PROPOSALSFOR CONSIDERATION AT THE EIGHTEENTH MEETING
OF THE CONFERENCE OF THE PARTIES TO CITES(Geneva, 2019)

GLOBAL GUARDIAN TRUSTSUMMARY OF THE RECOMMENDATIONS
Proposal
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Species
Amendment Recommendation
Capra falconeri heptneri
markhor
I → II
Yes
Saiga tatarica
saiga antelope
II → INo
Vicugna vicugna
vicuñaI → II
Yes
Vicugna vicugna
vicuña annotation
Yes
Giraffa camelopardalis
giraffe
0 → IINo
Aonyx cinereus
small-clawed otter
II → I
No
Lutogale perspicillata smooth-coated otter
II → I
No
Ceratotherium simum simum
white rhino annotation
Yes
Ceratotherium simum simum
white rhino
I → II
Yes
Loxodonta africana
African elephant
I → II
Yes
Loxodonta africana
African elephant annotation
Yes
Loxodonta africana
African elephant
II → INo
Mammuthus primigenius wooly mammoth
0 → II
No
Leporillus conditor
greater stick-nest rat
I → II
Yes
Pseudomys fieldi subsp. Shark Bay mouse
I → II
Yes
Xeromys myoides
false swamp rat
I → II
Yes
Zyzomys pedunculatus
central rock rat
I → II
Yes
Syrmaticus reevesii
Reeves’s pheasant
0 → II
Yes
Balearica pavonina
black crowned crane
II → INo
Dasyornis broadbenti
rufous bristlebird
I → IIYes
Dasyornis longirostris long-billed bristlebird
I → II
Yes
Crocodylus acutus
American crocodile
I → II
Yes
Calotes nigrilabris etc.
garden lizards
0→I
No
Ceratophora spp.
horned lizards
0→INo
Cophotis ceylanica etc.
pygmy lizards
0→INo
Lyriocephalus scutatus hump-nosed lizard
0→INo
Goniurosaurus spp.
leopard geckos
0 → IIYes
Gekko gecko
tokay gecko
0 → II
No
Gonatodes daudini
clawed gecko
0→I
Yes
Paroedura androyensis
ground gecko
0 → II
Yes
Ctenosaura spp.
spiny-tailed iguanas
0 → II
Yes
Pseudocerastes urarachnoides
viper
0 → II
Yes
Cuora bourreti
Bourret’s box turtle
II → I
No
Cuora picturata
Vietnamese box turtle
II → I
No
Mauremys annamensis Annam leaf turtle
II → I
No
Geochelone elegans
star tortoise
II → I
No
Malacochersus tornieripancake tortoise
II → I
No

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46
47
48
49
50
51
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53
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55
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Hyalinobatrachium spp. etc.
glass frogs
Echinotriton chinhaiensis etc. spiny newts
Paramesotriton spp.
Asian warty newts
Tylototriton spp.
crocodile newts
Isurus oxyrinchus etc.
mako sharks
Glaucostegus spp.
guitarfishes
Rhinidae spp.
wedgefishes
Holothuria fuscogilva etc.
teatfishes
Poecilotheria spp.
ornamental spiders
Achillides chikae hermeli
swallowtail
Parides burchellanus riverside swallowtail
Handroanthus spp. etc.
trumpet trees
Widdringtonia whytei
Mulanje cedar
Dalbergia sissoo
North Indian rosewood
Dalbergia spp. etc.
rosewoods
Pericopsis elata
African teakPterocarpus tinctorius
African padauk
Aloe ferox
bitter aloe
Adansonia grandidieri
baobabCedrela spp.
cedars

0 → II
0 → II
0 → II
0 → II
0 → II
0 → II
0 → II
0 → II
0 → II
0→I
0→I
0 → II
0 → II
II → 0annotation
annotation
0 → II
annotation
annotation
0 → II

Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
withdrawn
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No

RECOMMENDATIONS
Prop. Transfer of Tajikistan’s population of the Heptner’s markhor Capra
1 falconeri heptneri from Appendix I to Appendix II (Tajikistan)The species Capra falconeri is distributed in Tajikistan, Afghanistan,
Turkmenistan, India, Pakistan and Uzbekistan. The proposal aims to transfer C.
falconeri heptneri from Appendix I to Appendix II. The species was transferredfrom Appendix II to Appendix I in 1992 based on insufficient information. It is wellknown that in Pakistan, trophy hunting has contributed to community-based
conservation. The markhor population of Tajikistan shows a steady increase
thanks to the involvement of local communities. By transferring it to Appendix II,
local communities will receive further incentives, thus contributing to theconservation of Tajikistan’s subspecies. We strongly recommend that the
proposal be adopted. Other range states of the species may wish to submit
proposals to transfer their populations to Appendix II at future CoPs because thespecies as a whole does not meet the Appendix I listing criteria.
Prop. Transfer of the saiga antelope Saiga tatarica from Appendix II to
2 Appendix I (Mongolia and USA)The species Saiga tatarica was included in Appendix II in 1994. At that time, theproposals submitted by the US was intended to include the population ofMongolia in Appendix I and the rest of the species in Appendix II. The
Conference of the Parties decided to include the species as a whole in Appendix
II. The proponents, Mongolia and the US propose that the species be transferredto Appendix I. While we share the concern expressed by the proponents, atransfer to Appendix I may not have a positive effect on the species as
anticipated by the proponents. Since 2015, hunting has been prohibited in all
range states. In practice, there is no difference between Appendix I listing andAppendix II listing because hunting is prohibited. The saiga specimens subject tointernational trade are those already acquired. There are many threats ranging
from local consumption for meat to habitat loss. There seems to be a large
volume of saiga horn stockpile in Asian countries including China, Japan andSingapore. Saiga horn may have been utilized as substitutes for rhino horn. If
this is the case, an Appendix I listing of the species would further increase theprices of these species. The global population of the species is not small. The
positions of the range states other than Mongolia are not clear. Under thecircumstances, the proposal should be rejected. However, split listings may be
one solution with Mongolian population in Appendix I and others in Appendix II.
Also, we recommend that the range states take remedial actions such as theenhancement of anti-poaching activities and strengthened border control.

1Prop. Transfer of the vicuña Vicugna vicugna population of Salta Province
3 from Appendix I to Appendix II (Argentina)
The species endemic to South America does not meet the Appendix I listing
criteria. It is well known that local communities are involved in the sustainable
management of the vicuña. Vicuña wool is sheared from live animals without
killing them. The vicuña is one of the few species that CITES has worked
successfully because the Conference of the Parties allowed to transfer several
vicuña populations from Appendix I to Appendix II. A transfer of the population inquestion will create more incentives to local communities, thus having positive
impacts on the conservation of the population. The proposal should be adopted.
Prop. Amendment of the name of the vicuña population of Chile already4 listed in Appendix II (Chile)
The proposal was submitted resulting from the name change of a geopoliticalregion. In adopting this proposal, the conservation status of the vicuña
population remains unchanged. The proposal should be adopted.
Prop. Inclusion of the giraffe Giraffa camelopardalis in Appendix II (Central
5 African Republic, Chad, Kenya, Mali, Niger and Senegal)
The species consists of nine subspecies, distributed in 19 range states in Africa.
As is the case with other wildlife such as lions, rhinos and elephants, southern
African countries have the healthy populations while other sub-regions haveexperienced a precipitous decline. The only exception is Niger where aconservation strategy was established. In Niger, the population of G. c. peralta
has increased substantially, from 49 individuals in the 1990s to 400 in 2015.
Niger’s effort is commendable. As the proponents admit, exploitation for trade
may not be the primary cause of decline in wild giraffe populations. The mainthreats are actually habitat loss, civil unrest, illegal hunting and ecologicalchanges. We are concerned that giraffes have recently been poached forbushmeat. This threats however will not be solved by listing the species inAppendix II because CITES has no effect on internal use. Out of six
co-proponents, the hunting of giraffes is prohibited in Central African Republic,
Chad and Kenya. In addition, the giraffe is possibly extinct in Mali and extinct inSenegal. There is no foreseeable merit in listing the species in Appendix II. Whatis needed for the proponents and other range states with declining populations is
to learn Niger’s achievement. It is not clear if southern African countries withhealthy giraffe populations are supportive of this proposal. Under thecircumstances, the proposal should be rejected.
Prop. Transfer of the small-clawed otter Aonyx cinereus from Appendix II to
6 Appendix I (India, Nepal and Philippines)
The small-clawed otter is distributed widely ranging from India to the Philippines.
2

The proponents propose to transfer the species from Appendix II to Appendix I
based on the CITES listing criteria paragraph C: a marked decline in the
population size in the wild. According to the IUCN Redlist, it is inferred that the
global population of the small-clawed otter has declined by 30% or more over the
past 30 years. Under the CITES listing criteria, a marked recent rate of decline is
generally a percentage decline of 50% or more in three generations. The recent
rate of decline is within this threshold and as such, the species does not meet
the Appendix I listing criteria. The threats to the species include aquaculture,pollution by pesticides, habitat loss, alteration to agricultural land, garbage
dumping, poaching for pelts, pets and so on, of which poaching for pelts may be
a main threat. Poaching for pet trade does exist but it constitutes a small fractionof threats. According to the supporting statement, most of the range states havenational legislation by which the species is protected. The range States where
the species is protected include Bangladesh, Bhutan, China, India, Lao PDR,
Malaysia, Myanmar, Philippines, Singapore, Taiwan, Thailand and Viet Nam.
Nepal, one of the proponents, does not protect the species. Since the species isprotected by most of the range States, an Appendix I listing would not makemuch difference. In conclusion, we recommend that the proposal be rejected.
The small-clawed otter is popular among hobbyists due to its looking causing
smuggling attempts. We recommend that destination countries such as Japan
strengthen border controls.
Prop. Transfer of the smooth-coated otter Lutogale perspicillata from
7 Appendix II to Appendix I (Bangladesh, India and Nepal)

The contents of the proposal are similar to the previous one. The smooth-coatedotter is widely distributed in Asia ranging from Pakistan to Indonesia. The
proponents propose to transfer the species from Appendix II to Appendix I basedon the CITES listing criteria paragraph C: a marked decline in the population sizein the wild. According to the IUCN Redlist, it is inferred that the global populationof the smooth-coated otter has declined by 30% or more over the past 30 years.
Under the CITES listing criteria, a marked recent rate of decline is generally apercentage decline of 50% or more in three generations. The recent rate of
decline is within this threshold and as such, the species does not meet the
Appendix I listing criteria. The threats to the species include pelt trade, damconstruction, reclamation of wetlands, aquaculture, etc., all anthropogenic
factors. Since the species is a fish eater, fishermen regard the species as pests
resulting in illegal killing. The species is protected in most of the range States.
The range States where the species is protected include Bhutan, China, India,
Indonesia, Lao PDR, Malaysia, Myanmar, Nepal, Pakistan, Thailand and Viet
Nam. One of the proponents, Bangladesh does not protect the species. Since
the species is protected by most of the range States, an Appendix I listing would
not make much difference. In conclusion, we recommend that the proposal berejected. At the same time, we urge Bangladesh to designate the smooth coatedotter as protected species under its domestic law.

3

Prop. Amendment of the annotation for the Eswatini population of the
8 southern white rhinoceros Ceratotherium simum simum (Eswatini)
The white rhino populations of South Africa and Eswatini are listed in Appendix IIwith annotation. Eswatini submitted a similar proposal for CoP17 aimed at aninternational trade in rhino horns. The proposal was rejected. Eswatini’s intention
is to sell rhino horns coming from the stockpiles and horns from non-lethal
harvesting. Eswatini’s rhino populations occur in one national park and one
game reserve. In addition, it intends to introduce rhinos to one wildlife sanctuary.
These three protected areas are not financed by the Government. They need to
be self-financed. At CoP17, a representative of Eswatini (Swaziland) made aplea for help but unfortunately, the Conference of the Parties rejected the
proposal. By using proceeds from selling rhino horns, Eswatini wishes toenhance its effort to conserve its rhino population. Listing rhinos in Appendix I
has proven to be a failure and innovative approaches need to be taken. This
proposal is one of such approaches and as such, it should be adopted. The
adoption of the proposal is the best interest of the conservation of the species aswell as of biodiversity. Those who oppose this proposal are encouraged toprovide Eswatini with financial assistances.
Prop. Transfer of the Namibian population of the southern white rhinoceros
9 Ceratotherium simum simum from Appendix I to Appendix II (Namibia)
The white rhinoceros consists of two subspecies, Ceratotherium simum simum
and C. s. cottoni. The latter, northern white rhinoceros, is almost extinct with only
two females left. The former, southern white rhinoceros had been extirpated frommost of the range States including Namibia. However, South African remaining
population became subject to protection and has increased rapidly. Rhinos havebeen reintroduced from South Africa to Namibia, Botswana, Zimbabwe,
Mozambique and Eswatini. Sixteen rhinos were reintroduced from South Africa
to Namibia in 1975 and the population has since then increased up to more than
1,000. The species as a whole does not meet the Appendix I listing criteria, nor
Namibia’s population. The population has increased substantially, not because of
CITES but because of Namibia’s effort. Such efforts must be rewarded. The
number of rhinos killed illegally has increased recently but it is negligible
compared to the total number of animals protected. The proposal aims to export
live animals and hunting trophies. Without approving this proposal, the integrityof CITES would be questioned. The proposal should be adopted.
Prop. Transfer of the Zambia population of the African elephant Loxodonta
10 africana from Appendix I to Appendix II (Zambia)
Zambia’s elephant population does not meet the Appendix I listing criteria.
Zambia has submitted proposals to transfer its elephant population from
Appendix I to Appendix II at CoP 12 (Santiago, 2002) and CoP 15 (Doha, 2010).
These proposals were rejected. In relation to CoP 15 proposal, a panel of4

experts was established. Its conclusion was that the acceptance of the proposal
would be beneficial to the conservation of the elephant population of Zambia andlong-term funding for conservation of elephants is required. Such a funding canbe attained by exporting ivories annually. Adoption of the proposal would be thefirst step to this effect. The supporting statement is well documented andenumerates various benefits received by wildlife and local communities. The
main threats are the expansion of human settlements, thus creating humanelephant conflicts. The only solution to this problem could be for local
communities to receive tangible benefits from elephants with whom people
compete. Zambia burned ivory in 1992 anticipating funding from outside.
According to the supporting statement, Zambia has not fully benefited fromprevious pledges for alternative funding from other Parties and animal welfare
groups. In Zambia, most of the elephant population of the country occur in the
Luangwa valley, where a pioneer project known as LIRDP was developed.
Community-based natural resources management programmes such as LIRDP
are keys to the long-term survival of the African elephants. The adoption of thepresent proposal will certainly contribute to the conservation of Africanelephants. The proposal should be adopted.
Prop. Amendment of the annotation for the African elephant Loxodonta
11 africana listed in Appendix II (Botswana, Namibia and Zimbabwe)
The African elephant was transferred from Appendix II to Appendix I at theseventh meeting of the Conference of the Parties (Lausanne, 1989) despite thegeneral recognition that some of the southern African countries did not meet the
Appendix I listing criteria. The elephant populations of Botswana, Namibia andZimbabwe were transferred to Appendix II in 1997 and South African populationin 2000. The Conference of the Parties should have supported the proposals
submitted by southern African countries without any condition attached. The
present proposal aims to delete some sub-paragraphs of the annotation. If this
proposal is adopted, the four countries, i.e., Botswana, Namibia, South Africa
and Zimbabwe will be able to export their stockpiled ivories. If this is the case, itwill be the best interest of the conservation of the African elephant and will be inline with the original intent of CITES. We welcome this proposal and recommendthat it be adopted. Continuing to reject their proposals is the punishment for theconservation success of southern African countries.
Transfer of the populations of the African elephant Loxodonta africana
Prop. of Botswana, Namibia, South Africa and Zimbabwe from Appendix II to
12 Appendix I (Burkina Faso, Côte d'Ivoire, Gabon, Kenya, Liberia, Niger,
Nigeria, Sudan, Syrian Arab Republic and Togo)
The plight now faced by African elephants started in 1989 when the Conferenceof the Parties adopted a transfer of the species as a whole from Appendix II toAppendix I despite the unanimous recognition that southern African populations
did not meet the Appendix I listing criteria. Those who supported an Appendix I
5listing need to take the responsibility because that decision brought about thepresent situation. The elephant populations of Botswana, Namibia andZimbabwe were transferred back to Appendix II in 1997 and that of South Africa
in 2000. Subsequently, international ivory trade took place twice, but both were‘one-off trade’. This decision exacerbated the situation because such tradeprecluded a possibility of establishing a long-term management strategy.
According to the supporting statement, if all African elephant populations are
considered as a whole, the species meets the Appendix I criteria. At the sametime, the proponents admit that individual country populations may be listed
separately in Appendix II. However, the proponents argue that split-listings
should be avoided referring to the listing criteria: “Listing of a species in morethan one Appendix should be avoided in general in view of the enforcement
problems it creates”. The history of CITES, however tells us that ‘split-listings’
was beneficial to many species including vicuna and crocodiles. The Nilecrocodile population of Kenya is listed in Appendix II, creating ‘split-listings’ forthe species. If ‘split-listings’ works negatively, Kenya’s population should betransferred to Appendix I. Furthermore, the proponents make a reference to thepreambular paragraph of Resolution Conf. 9.24: “By virtue of the precautionary
approach and in cases of uncertainty regarding the status of a specie or the
impact of trade on the conservation of a species, the Parties shall act in the bestinterest of the conservation of the species concerned and, when considering
proposals to amend Appendix I or II, adopt measures that are proportionate to
the anticipated risks to the species”. It should be stressed that this paragraphdoes not mean that in cases of uncertainty, international trade should not be
permitted. On the contrary, the best interest of the conservation of the Africanelephant will be achieved through allowing international trade in ivory with anannual export quota. By allowing ivory trade on a regular basis, exporting
countries will be able to establish more pragmatic, long-term elephantconservation programmes, which is indeed in the best interest of theconservation of the African elephant. There should be clear recognition that there
are two different groups of countries, the one who failed to conserve elephants
and the other who succeeded. By submitting this kind of proposal repeatedly, theformer’s country group is asking the latter to adopt the wildlife policy that proved
to have been a failure. In conclusion, there is no justification for transferring theelephant populations of Botswana, Namibia, South Africa and Zimbabwe toAppendix I. The proposal should be rejected.
Prop. Inclusion of the wooly mammoth Mammuthus primigenius in Appendix
13 II (Israel)
The wooly mammoth Mammuthus primigenius is an extinct species. Israel
proposes to include the mammoth in Appendix II for ‘look-alike’ reasons.
According to the supporting statement, Israel consulted all CITES Parties via
CITES Notification dated 8 November. This procedure seems to be against
Resolution Conf. 8.21 (Rev. CoP16) “Consultation with range States on
proposals to amend Appendices I and II”. Under this Resolution, Israel is6required to submit the proposal to the CITES Secretariat at least 330 days inadvance of CoP18. It is unclear whether the Secretariat received the draft
proposal in June 2018. We share the comments made by Canada. Listing the
mammoth will not have any positive impact on the African elephant and the
proposal should be rejected. We feel that listing the mammoth is somethingsimilar to listing the domestic cat in Appendix II. All Felidae species are listed in
CITES Appendices and their parts and derivatives resemble those of other
Felidae species.
Prop. Transfer of the greater stick-nest rat Leporillus conditor from Appendix
14 I to Appendix II (Australia)
This species occurred historically in the Australian mainland but became extinct
in the 1930s. The remaining population was restricted to the Franklin Islands.
The main threat was feral cats and introduced red foxes. Populations have been
reintroduced to other islands and mainland. This proposal to transfer the species
to Appendix II arises from Resolution on Periodic Review of the Appendices inaccordance with the decision made by the Animals Committee. There seems nointernational trade in the species. Since the species does not meet the Appendix
I listing criteria, the proposal should be adopted.
Prop. Transfer of the Shark Bay mouse Pseudomys fieldi praeconis from15 Appendix I to Appendix II (Australia)
The species Pseudomys fieldi became extinct on the mainland and from two
islands by the late 19th century and has survived on Bernier Island only. As is thecase with the previous proposal, populations have been reintroduced to otherislands and mainland. This proposal to transfer the species to Appendix II arises
from Resolution on Periodic Review of the Appendices in accordance with thedecision made by the Animals Committee. There seems no international trade in
the species. Since the species does not meet the Appendix I listing criteria, theproposal should be adopted.
Prop. Transfer of the false swamp rat Xeromys myoides from Appendix I to
16 Appendix II (Australia)
The species is distributed in northern Australia and Papua New Guinea. This
proposal to transfer the species to Appendix II arises from Resolution on Periodic
Review of the Appendices in accordance with the decision made by the Animals
Committee. There seems no international trade in the species. Since the species
does not meet the Appendix I listing criteria, the proposal should be adopted.
Prop. Transfer of the central rock rat Zyzomys pedunculatus from Appendix I
17 to Appendix II (Australia)
The species is endemic to Australia occurring in restricted areas. The main7

threats include feral cats and fires. There seems no international trade in thespecies. This proposal to transfer the species to Appendix II arises from
Resolution on Periodic Review of the Appendices in accordance with thedecision made by the Animals Committee. Since the species does not meet the
Appendix I listing criteria, the proposal should be adopted.
Prop. Inclusion of the Reeves’s pheasant Syrmaticus reevesii in Appendix II
18 (China)
The Reeves’s pheasant is endemic to China. The species is strictly protectedunder China’s domestic legislation. The main threats are illegal hunting, habitat
destruction and poison in farmland. Feathers of this pheasant have been subject
to international trade. Little is known of where the specimens actually come from.
By including the species in Appendix II, it would become easier for China tomonitor illegal trade and as such, the proposal should be adopted.
Prop. Transfer of the black crowned crane Balearica pavonina from19 Appendix II to Appendix I (Burkina Faso, Côte d'Ivoire and Senegal)
The species is distributed from western Africa to eastern Africa. The population is
not small and does not have a restricted area of distribution. The species does
not meet the Appendix I listing criteria. The species comprises two subspecies,
i.e., Balearica pavonina pavonina and B. p. ceciliae. According to the supportingstatement, trend data for B. p. ceciliae is poorly known but may warrant
transferring the species from Appendix II to Appendix I if projections depicting aworst scenario are realized. This can be interpreted that the worst scenario may
not realize. The main threat is habitat loss caused by anthropogenic activities
such as the use of wetlands for agriculture, extraction of water for irrigation andgroundwater extraction. The species is legally protected in most of the range
States. What the range states need to do is to establish comprehensive
management programmes including enforcement efforts. Under thecircumstances, we recommend that the proposal be rejected.
Prop. Transfer of the lesser rufous bristlebird Dasyornis broadbenti litoralis
20 from Appendix I to Appendix II (Australia)
The subspecies Dasyornis broadbenti litoralis is endemic to the south-western
coast of Western Australia. This proposal is similar to Props. 14, 15, 16 and 17 in
its nature. The proposal was submitted by Australia in accordance with thedecision made by the Animals Committee. The subspecies is considered to havebecome extinct. Transfer of the subspecies from Appendix I to Appendix II will
not have any impact. The proposal should be adopted.

8Prop. Transfer of the long-billed bristlebird Dasyornis longirostris from
21 Appendix I to Appendix II (Australia)
The species Dasyornis longirostris is endemic to south-western Western
Australia. The main threats to the species are habitat destruction and wildfires.
As is the case with the previous proposal, Prop. 20, the proposal was submitted
by Australia in accordance with the decision made by the Animals Committee.
Transfer of the species from Appendix I to Appendix II will not have any impact.
The proposal should be adopted.
Prop. Transfer of the American crocodile Crocodylus acutus population of
22 Mexico from Appendix I to Appendix II (Mexico)
The American crocodile widely occurs from Florida through Caribbean islands toSouth America. The species was first listed in Appendix II in 1976. The
population of the US was transferred to Appendix I in 1979 and the rest
remained in Appendix II. In 1981, the species as a whole was listed in Appendix I
and international trade in the American crocodile was prohibited. In 2004, theCuban population was transferred back to Appendix II. In 2016, one population in
Colombia was transferred to Appendix II. Other range states have Appendix I
populations currently. The population of Mexico is not small and does not have arestricted area of distribution. Thus, the population does not meet the Appendix I
listing criteria. This proposal submitted by Mexico aims to transfer its populationfrom Appendix I to Appendix II. At CoP15, Mexico submitted a proposal totransfer its Morelet’s crocodile population from Appendix I to Appendix II, which
was successfully adopted. Since then, Mexico has developed the successful
management programme, which can be applied to the American crocodile aswell. By transferring its population, Mexico will be able to export the specimensfrom the ranching programme. Ranching is beneficial to the crocodile population,
its habitat and local communities. We welcome this proposal and recommendthat the proposal be adopted.
Prop. Inclusion of the garden lizards Calotes nigrilabris and C. pethiyagodai
23 in Appendix I (Sri Lanka)
Lizards in the genus Calotes are distributed from South Asia to East Asia. The
proposal aims to include two species endemic to Sri Lanka in Appendix I.
According to the supporting statement, these two species are strictly protectedunder Sri Lankan legislation and no export for commercial purposes are
permitted. The main threat to these species is habitat destruction/fragmentationand pesticide use by local farmers. These problems will not be solved by listing
the species in Appendix I because they are of internal nature. It is difficult tounderstand the rationale behind the proposal. If the existing measures are
considered to be insufficient, then Sri Lanka should strengthen its legislation andenhance enforcement activities. Under the circumstances, the proposal should
be rejected. An Appendix II or III listing may be more appropriate.
9Prop. Inclusion of the horned lizards Ceratophora spp. in Appendix I (Sri24 Lanka)
The genus Ceratophora comprises five species which are all endemic to Sri
Lanka. The proponent proposes to list the five species in Appendix I. According
to the supporting statement, these five species are strictly protected under Sri
Lankan legislation and no export for commercial purposes are permitted. The
main threat to these species is forest destruction caused by the expansion of tea
plantations and timber extraction. The proponent argues that national
conservation and protection measures appear to be insufficient to save theselizards. Even though these lizards are included in Appendix I, the situation would
remain unchanged because the main threat is of domestic nature. If the existingmeasures are considered to be insufficient, then Sri Lanka should strengthen its
legislation and enhance enforcement activities. Under the circumstances, theproposal should be rejected. An Appendix II or III listing may be more
appropriate.
Prop. Inclusion of the pygmy lizards Cophotis ceylanica and C. dumbara in
25 Appendix I (Sri Lanka)
The genus Cophotis comprises two species, C. ceylanica and C. dumbara.
These species are endemic to Sri Lanka. The proposal aims to include these two
species in Appendix I. According to the supporting statement, these two species
are strictly protected under Sri Lankan legislation and no export for commercial
purposes are permitted. The threats to these species include deforestation, theuse of agrochemicals and effects of climate change. The main problem isdeforestation caused by timber extraction and clearing of forest for tea
plantations. These problems will not be solved by listing the species in Appendix
I because they are of internal nature. It is difficult to understand the rationale
behind the proposal. If the existing measures are considered to be insufficient,then Sri Lanka should strengthen its legislation and enhance enforcement
activities. Limiting the expansion of tea plantations may be one of the solutions.
Under the circumstances, the proposal should be rejected. An Appendix II or III
listing may be more appropriate.
Prop. Inclusion of the hump-nosed lizard Lyriocephalus scutatus in Appendix
26 I (Sri Lanka)
The hump-nosed lizard is endemic to Sri Lanka and is monotypic. The proposal
aims to include this species in Appendix I. The species occurs in cool and shadyforested areas in the southwestern part of Sri Lanka. According to the supportingstatement, the species is strictly protected under Sri Lankan legislation and noexport for commercial purposes are permitted. The main threat to the species isdeforestation, leading to loss of habitat and habitat fragmentation. These
problems will not be solved by listing the species in Appendix I because they areof internal nature. It is difficult to understand the rationale behind the proposal. If
10the existing measures are considered to be insufficient, then Sri Lanka should
strengthen its legislation and enhance enforcement activities. Under thecircumstances, the proposal should be rejected. An Appendix II or III listing may
be more appropriate.
Prop. Inclusion of the leopard geckos Goniurosaurus spp. from China and
27 Viet Nam in Appendix II (China, EU and Viet Nam)
The genus Goniurosaurus consists of 19 species. These species are distributedin China, Japan and Viet Nam. The proposal aims to list 13 species in Appendix
II occurring in China and Viet Nam. Six species endemic to Japan are excluded
from the proposal. The main threats are habitat loss, pet trade and local use.
Although little is known of the population size, it seems that the population has
declined. Most of the leopard gecko species are being sold in the international
pet market. An Appendix II listing will enable the range States to monitor theirtrade volume. We recommend that the proposal be adopted. We also
recommend that the six species not covered by the proposal be listed inAppendix II in future because they are also subject to international pet trade.
Prop. Inclusion of the tokay gecko Gekko gecko in Appendix II (EU, India,
28 Philippines and USA)The tokay gecko is widely distributed in many countries in Asia, i.e., Bangladesh,
Cambodia, China, India, Indonesia, Lao PDR, Malaysia, Myanmar, Nepal,
Philippines, Singapore, Thailand and Vie Nam. The population may havedeclined in some range States but seems large in other States such as
Bangladesh, China and Thailand. The species has historically been subject tointernational trade for medicinal purposes. Hunting and/or export are regulatedby Bangladesh, Cambodia, China, India, Indonesia, Lao PDR, Malaysia, Nepal,
Philippines, Viet Nam and Thailand. Thus, various safeguards already exist inthese range States. A consultation was made by EU with all range States andoppositions were expressed by Cambodia, China, Indonesia, Nepal and Viet
Nam. Under the circumstances, the proposal should be rejected.
Prop. Inclusion of the Grenadines clawed gecko Gonatodes daudini in
29 Appendix I (Saint Vincent and the Grenadines)
The species is found only on Union Island of Saint Vincent and the Grenadines.
Union Island is a very small island with an area of only 9 km2. The species wasrecently described and has become targeted by collectors. The species does
meet the Appendix I listing criteria. The main threat to the species is overharvesting for commercial purposes. In addition to a restricted area of
distribution, the existence of illegal trade warrants an Appendix I listing of thespecies. We recommend that the proposal be adopted. We further recommendthat Saint Vincent and the Grenadines take mitigative actions against otherthreats such as feral cats and wildfires.
11

Prop. Inclusion of the Grandidier’s Madagascar ground gecko Paroedura
30 androyensis in Appendix II (EU and Madagascar)
The species is endemic to Madagascar occurring in dry forests and its
distribution is restricted to a small area of the southern tip of Madagascar. The
proposal aims to list the species in Appendix II. It seems to be severely
fragmented. Although no information is available on the population size, thespecies seems to meet the Appendix II listing criteria based on its restricted areaof distribution and the threats to the species. We recommend that the proposal
be adopted. According to the supporting statement, however, the main threats
are timber extraction for charcoal production and land clearance for slash andburn agriculture. An Appendix II listing of the species will not solve the problem
by itself and as such, Madagascar needs to take remedial actions.
Prop. Inclusion of the spiny-tailed iguanas Ctenosaura spp. in Appendix II (El
31 Salvador and Mexico)
The genus Ctenosaura comprises 18 species. Four species are already includedin Appendix II. The proposal aims to list other 14 species in Appendix II. By doing
so, all 18 species in the genus Ctenosaura will be included in Appendix II.
According to the supporting statement, 13 species, including already listed four
species meet the Annex 2a criteria and the remaining 5 species meet the Annex
2b criteria. The supporting statement lists a variety of threats faced by theseiguana species including international pet trade. Information on international
trade is available for the four species. Inclusion of other species in Appendix II
will provide range States with new information on quantitative data on tradevolume. The proposal should be adopted.
Prop. Inclusion of the spider-tailed horned viper Pseudocerastes
32 urarachnoides in Appendix II (Iran)The species is a new species described only recently. It is found in Iran. Since
the species is a newly described species, little is known of the biological andtrade status. Due to its very special morphology and behaviour, the animals may
have become popular among hobbyists. Despite the fact that the species isprotected in Iran and export of the animals is prohibited, there are evidence ofillegal trade. An Appendix II listing will help Iran to conserve the species and the
proposal should be adopted.
Prop. Transfer of the Bourret’s box turtle Cuora bourreti from Appendix II to
33 Appendix I (Viet Nam)
The species is distributed in Viet Nam and Lao PDR. It was listed in Appendix II
in 2000. The proposal aims to transfer the species from Appendix II to Appendix
I. Lao PDR has its national legislation banning collection. The species isprotected from commercial exploitation in Viet Nam as well. The species inhabits
12well developed evergreen forest. Habitat loss and degradation are threats to thespecies. However, the main threat is collection for trade, both for foodconsumption and pet. Since 2013, a zero annual export quota has been
established for the species Cuora bourreti for specimens removed from the wild
and traded for primarily commercial purposes. In practice, there is no difference
between an Appendix I listing and an Appendix II listing with zero export quota.
The supporting statement admits that though the species is legally protected inboth range States, enforcement may be insufficient. Both countries in particular
Vie Nam as a proponent are required to strengthen their enforcement activities.
Under the circumstances, the proposal should be rejected.
Prop. Transfer of the Vietnamese box turtle Cuora picturata from Appendix II
34 to Appendix I (Viet Nam)
The species is endemic to Viet Nam and found in evergreen forest. It was listed
in Appendix II in 2000. The proposal aims to transfer the species from Appendix
II to Appendix I. The species is legally protected from commercial exploitation inViet Nam. Habitat loss and degradation are threats to the species. However, themain threat is collection for trade, both for food consumption and pet. Since
2013, a zero annual export quota has been established for the species Cuora
picturata for specimens removed from the wild and traded for primarily
commercial purposes. In practice, there is no difference between an Appendix I
listing and an Appendix II listing with zero export quota. According to the
supporting statement, domestic enforcement of existing regulations may beinsufficient. The proponent clearly identifies the problem and as suchenforcement activities must be strengthened. For the same reason as Cuora
bourreti, the proposal should be rejected.
Prop. Transfer of the Annam leaf turtle Mauremys annamensis from35 Appendix II to Appendix I (Viet Nam)
The Annam leaf turtle is endemic to Viet Nam, inhabiting floodplain wetlands. It
was listed in Appendix II in 2000. The proposal aims to transfer the species from
Appendix II to Appendix I. The species is legally protected in Viet Nam from any
form of exploitation. Since 2013, a zero annual export quota has been
established. Nevertheless, enforcement at local jurisdictions may be insufficient.
In practice, there is no difference between an Appendix I listing and an Appendix
II listing with zero export quota. As the proponent points out, domestic
enforcement needs to be strengthened. We recommend that the proposal berejected.
Prop. Transfer of the star tortoise Geochelone elegans from Appendix II to
36 Appendix I (Bangladesh, India, Senegal and Sri Lanka)
The species is distributed in India, Pakistan and Sri Lanka occurring primarily inopen dry scrublands. It was listed in Appendix II in 1973 and has been subject to
13

CITES from the beginning. India and Pakistan became Parties to CITES in 1976
and Sri Lanka in 1979. The species is currently protected in these three range
States. Since 1980, it has been illegal to hunt the species in India. Yet, illegal
trade in the species originating from India is rampant. Illegal attempts would notstop even after transferring the species to Appendix I. What is needed for India
and other two range States is to enhance their enforcement activities, inparticular border controls. An Appendix I listing is not a solution and as such,
more comprehensive approaches must be taken. India has identified a specificlocation where illegal collection are being heavily made. Concentrated
enforcement activities focusing on this area will also be required. Under thecircumstances, the proposal should be rejected.
Prop. Transfer of the pancake tortoise Malacochersus tornieri from Appendix
37 II to Appendix I (Kenya and USA)The species is distributed in Kenya, Tanzania and Zambia. It inhabits semi-arid
and arid thornbush and savannah landscapes. Hunting and trade in wild-caught
animals have been prohibited in Kenya. The species was subject to the
Significant Trade Review process. As a result, Tanzania established a zero quota
for trade in wild tortoises. The species was listed in Appendix II in 1973 and has
been subject to CITES treaty. According to the supporting statement, all threerange States have been exporting animals from captive sources in recent years.
There seems no legal trade in wild-caught tortoises from all the range States.
Even though the species is transferred to Appendix I, illegal trade would continue
and the present situation remains unchanged. In addition, it is not clear whether
other two range States, i.e., Tanzania and Zambia support this proposal. Unlessthese States support the proposal, it should be rejected.
Prop. Inclusion of the glass frogs Hyalinobatrachium spp., Centrolene spp.,
Cochranella spp. and Sachatamia spp. in Appendix II (Costa Rica, El
38 Salvadorand Honduras)
The proponents propose to include in Appendix II glass frogs belonging to thegenera Hyalinobatrachium, Centrolene, Cochranella and Sachatamia,
comprising 104 species. These glass frogs are widely distributed in Central
America and South America. Little is known of the population size of these
species. However, glass frogs have become popular among hobbyists due totheir unique appearance. Inclusion of the four genera will help range States tomonitor trade volume of these glass frogs. We recommend that the proposal be
adopted.
Prop. Inclusion of the spiny newts Echinotriton chinhaiensis and E.
39 maxiquadratus in Appendix II (China)
The two spiny newt species, Echinotriton chinhaiensis and E. maxiquadratus areendemic to China, occurring in forested habitats in the east and southeast China.
14

The latter is a newly discovered species. The population size of both species
seems to be small. The threats to the species include illegal collection for pet
trade and habitat destruction. Inclusion of these spiny newts in Appendix II will
have a positive impact on the conservation of the species. We recommend thatthe proposal be adopted. The genus Echinotriton comprises three species. The
remaining species is E. andersoni occuring on Ryukyu Islands, Japan, which is
not subject to this proposal. By including E. andersoni in Appendix II in future, allspecies in the genus Echinotriton can be covered by CITES.
Prop. Inclusion of the Asian warty newts Paramesotriton spp. in Appendix II
40 (China and EU)
The genus Paramesotriton is distributed in China and Viet Nam. It comprises 14
species. The proposal aims to include 13 species not yet listed in Appendix II. P.
hongkongensis is already listed in Appendix II. By including 13 species, all
known species in the genus become subject to CITES. There may be many
cryptic species and listing these newts as a higher taxon is necessary. Little is
known of the exact population size. Since some species have a very restricted
area of distribution, it is inferred that the population size of some species is verysmall as well. These species meet the Appendix II listing criteria and as such, theproposal should be adopted.
Prop. Inclusion of the crocodile newts Tylototriton spp. in Appendix II (China
41 and EU)
The genus Tylototriton comprises 25 species currently. New species may bedescribed in future. The proposal aims to include the genus Tylototriton in
Appendix II. The genus is distributed in China, Viet Nam, Lao PDR, Thailand,
Myanmar, India, Nepal and Bhutan. Little is known of the population size ofindividual species. The main threats are habitat loss and degradation. These
crocodile newts are also threatened by over-exploitation for food, traditional
medicine, international pet trade, etc.. Although the international trade for pet isonly one of the threats, many animals seem to be exported from the range
States to Europe, America and Asia. An Appendix II listing of the genus will help
monitor species and trade volumes resulting in better conservation management.
The proposal should be adopted.
Inclusion of the mako sharks Isurus oxyrinchus and I. paucus in
Prop. Appendix II (Bangladesh, Benin, Bhutan, Brazil, Burkina Faso, Cabo
Chad, Côte d’Ivoire, Dominican Republic, Egypt, EU, Gabon,
42 Verde,
Gambia, Jordan, Lebanon, Liberia, Maldives, Mali, Mexico, Nepal,
Niger, Nigeria, Palau, Samoa, Senegal, Sri Lanka, Sudan and Togo)
The proponents propose to include the short-fin mako Isurus oxyrinchus andlong-fin mako I. paucus in Appendix II. The latter species is proposed as a lookalike species. The short-fin mako shark is distributed globally. Since CoP12
15

(Santiago, 2002), many commercially exploited marine species, mainly sharks,
have been included in Appendix II. Listings in Appendix II of marine species havewitnessed many difficulties in their implementation including on introduction fromthe sea and non-detriment findings. According to the operative paragraph 9 of
Resolution Conf. 9.24, the Conference of the Parties resolved “that, to monitor
the effectiveness of protection offered by the Convention, the status of species
included in Appendices I and II should be regularly reviewed by the range Statesand proponents, in collaboration with the Animals Committee or the Plants
Committee, subject to the availability of funding.” Nonetheless, the monitoring of
the effectiveness has not taken place. It is imperative to monitor theeffectiveness as a matter of urgency because CITES listings may have anegative impact on the conservation of those species. FAO’s expert panel met inRome in January 2019 and assessed the proposal. It concluded that theavailable data do not provide evidence that the species meets the CITES
Appendix II listing criteria. In addition, we are concerned that a large number ofcountries became co-sponsors without seeing the results of FAO’s conclusion.
Since there is no need to list the short-fin mako in Appendix II, it is not justifiable
to list the long-fin mako as a look-alike species. We strongly recommend that the
proposal be rejected.
Inclusion of the guitarfishes Glaucostegus spp. in Appendix II
Prop. (Bangladesh, Benin, Bhutan, Brazil, Burkina Faso, Cabo Verde, Chad,d’Ivoire, Egypt, EU, Gabon, Gambia, Maldives, Mali, Mauritania,
43 CôteMonaco, Nepal, Niger, Nigeria, Palau, Senegal, Sierra Leone, Sri
Lanka, Syrian Arab Republic, Togo and Ukraine)
The proposal aims to list all species in the genus Glaucostegus in Appendix II.
Two species of the guitarfishes Glaucostegus cemiculus and G. granulatus areproposed in accordance with paragraph 2(a) of the Convention. The blackchinguitarfish G. cemiculus is distributed in the Mediterranean and Atlantic Ocean off
western Africa. The sharpnose guitarfish G. granulatus is distributed in the northwestern Indian Ocean. According to the supporting statement, global population
size is unknown for G. cemiculus, G. granulatus or any other Glaucostegus
species. FAO’s expert panel considers it uncertain whether these two species
meet the criteria for CITES listing because sufficient evidence of declines islacking. The same comment as Prop. 42 is applicable to Prop. 43. Under thecircumstances, the proposal should be rejected.
Inclusion of the wedgefishes Rhinidae spp. in Appendix II(Bangladesh, Benin, Bhutan, Brazil, Burkina Faso, Cabo Verde, Chad,
Prop. Côte d’Ivoire, Egypt, Ethiopia, EU, Fiji, Gabon, Gambia, India, Jordan,
44 Kenya, Lebanon, Maldives, Mali, Mexico, Monaco, Nepal, Niger,
Nigeria, Palau, Philippines, Saudi Arabia, Senegal, Seychelles, Sri
Lanka, Sudan, Syrian Arab Republic, Togo and Ukraine)
As is the case with the guitarfishes, insufficient evidence of decline is available
16

for FAO’s expert panel to make a judgment in relation to the CITES criteria. The
expert panel notes that the information provided in the proposal on trends in
populations across the species’ range was limited, and not sufficient to allow thepanel to determine whether the species qualified globally under the decline
criteria for an Appendix II listing. If listed in Appendix II, exporting countries are
required to ensure that export will not be detrimental to the survival of thatspecies. It would be extremely difficult for the authorities of exporting countries toestablish a non-detriment finding (NDF). Same difficulties would have happenedon marine species already listed in Appendix II. Therefore, it is urgently needed
to monitor the effectiveness of protection offered by CITES for those marine
species. We recommend that the proposal be rejected.
Prop. Inclusion of the teatfishes Holothuria fuscogilva, H. nobilis and H.
45 whitmaei in Appendix II (EU, Kenya, Senegal, Seychelles and USA)
These sea cucumbers are distributed in Indian and Pacific Oceans in the tropicaland sub-tropical regions. The proposal aims to include three species in thegenus Holothuria in Appendix II. FAO’s expert panel concluded that while H.
fuscogilva did not meet the Appendix II listing criteria, H. whitmaei met the listing
criteria. On the other hand, there was insufficient evidence of declines to make a
judgement in relation to CITES criteria for H. nobilis. Our comments on this
proposal are similar to the previous ones related to marine species. Forcommercially exploited marine species, it is of paramount importance to monitor
the effectiveness of CITES listings. Whereas some of the range States support
the proposal, it is not clear whether other range States support the proposal. We
recommend that the proposal be rejected.
Prop. Inclusion of the ornamental spiders Poecilotheria spp. in Appendix II
46 (Sri Lanka and USA)
Tarantulas in the genus Poecilotheria are distributed in Sri Lanka and India,
mainly occurring in forested areas. The genus comprises 15 species. The
proposal aims to include these species in Appendix II. The threats to the species
are habitat loss, habitat fragmentation and collection for pet trade. For somespecies, the international pet trade seems to be a major threat. While thespecies are not protected in India, commercial collection and export of thespecies is prohibited in Sri Lanka. The proponents, i.e., Sri Lanka and the US
admit that though Sri Lanka has a legislative framework for the conservation ofthis genus, all steps of enforcement are weak due to enforcement gaps. These
problems must be first addressed before listing the species in Appendix II. Under
the circumstances, the proposal should be rejected.
Prop. Inclusion of the Mindoro peacock swallowtail Achillides chikae hermeli
47 in Appendix I (EU and Philippines)
Currently, the swallowtail Papilio chikae is listed in Appendix I. This species was17

reclassified as the subspecies Achillides chikae chikae. It is found in northern
Luzon Island in the Philippines. Another swallowtail Papilio hermeli is notincluded in Appendices. This species endemic to Mindoro was reclassified as thesubspecies Achillides chikae hermeli. This means that Achillides chikae consistsof two subspecies, one of which is subject to CITES but another is not coveredby CITES. The proponents propose to include Achillides chikae hermeli in
Appendix I. By doing so, the species Achillides chikae (Papilio chikae + Papilio
hermeli) is included in Appendix I. According to the supporting statement,
Achillides chikae hermeli seems to meet the Appendix II listing criteria. If thissubspecies meets the Appendix II listing criteria, then Achillides chikae as a
species would also meet the Appendix II listing criteria. We recommend that the
proposal be rejected. The proponents may wish to submit a proposal to transfer
Achillides chikae chikae from Appendix I to Appendix II and include Achillides
chikae hermeli in Appendix II. This will accommodate the proponent’s concern
about split-listings.
Prop. Inclusion of the riverside swallowtail Parides burchellanus in Appendix
48 I (Brazil)
This swallowtail butterfly is endemic to Brazil, having a restricted area of
distribution. The main threats are fragmentation of its habitat, fire use, urban
occupation and pollution. Illegal trade does exist but not in a significant volume.
According to the supporting statement, there is no legal device in Brazil
specifically designed to protect the species. Since the main threats are ofinternal nature, Brazil should establish the overall management programme
focusing on these threats. Without such actions, the species has not much
benefit resulting from CITES listing. Under the circumstances, the proposal
should be rejected. An Appendix III listing may be more appropriate.
Prop. Inclusion of the trumpet trees Handroanthus spp., Tabebula spp. and49 Roseodendron spp. in Appendix II with annotation (Brazil)
Withdrawn.
Prop. Inclusion of the Mulanje cedar Widdringtonia whytei in Appendix II
50 (Malawi)
This conifer species Widdringtonia whytei is endemic to Malawi occurring on
Mount Mulanje. The population size is extremely small with a restricted area of
distribution and the species is on the verge of extinction. The threats to thespecies are logging, changing fire regime, invasive tree species and conifer
aphids. There is insufficient information on the international trade in the species.
Due to its small population size, any international trade may affect the species.
As such, the proposal should be adopted. Listing the species in Appendix II will
not solve the real problem faced by the species. Enforcement should be
strengthened on illegal logging and plantations need to be protected from fires
18

rigorously. Overall management programme should be established including
ex-situ conservation.
Prop. Deletion of the north Indian rosewood Dalbergia sissoo from Appendix
51 II (Bangladesh, Bhutan, India and Nepal)
The species is native to Afghanistan, Bangladesh, Bhutan, India, Iran, Iraq,
Myanmar, Nepal, Pakistan, Philippines and South Africa. It has been introduced
to many other countries including Israel, Australia and the US. This tree species
is very popular for plantation and easy to propagate artificially. The species was
included in Appendix II at CoP17 (Johannesburg, 2016) as a result of the
inclusion of the genus Dalbergia. Deletion of the species from Appendix II willremove administrative burdens from the authorities. We welcome this initiativeand recommend that the proposal be adopted.
Prop. Amendment of the annotation for the rosewoods Dalbergia spp.,
Guibourtia demeusei, G. pellegriniana and G. tassmannii listed in
52 Appendix
II (Canada and EU)
The proponents propose to amend the existing annotation to Dalbergia species.
This proposal was submitted in accordance with the decision made by theStanding Committee. The proposal should be adopted.
Prop. Amendment of the annotation for the African teak Pericopsis elata
53 listed in Appendix II (Cote d’Ivoire and EU)
The African teak Pericopsis elata is distributed in CAR, Nigeria, Ghana, Côte
d’Ivoire, Cameroon, DRC and Congo. The proponents’ intention is to include‘plywood and transformed wood’ in the annotation. This amendment is proposedin accordance with the discussions in the Standing Committee Working Groupon Annotations. It is not clear whether other range States than Côte d’Ivoire andRepublic of Congo support this proposed amendment. On condition that most of
the range states support, we recommend that the proposal be adopted.
Prop. Inclusion of the African padauk Pterocarpus tinctorius in Appendix II
54 (Malawi)
The species is distributed in Angola, DRC, Burundi, Tanzania, Malawi,
Mozambique and Zambia. Little is known of the population size. According to the
supporting statement, however, the major threats to the species isoverharvesting, including both legal and illegal extraction, for the international
trade. It seems that many of the range States expressed their support informally.
The proposal should be adopted.

19

Prop. Amendment of the annotation for the bitter aloe Aloe ferox listed in
55 Appendix II (South Africa)
South Africa submitted this proposal to amend the annotation for Aloe ferox by
excluding finished products of Aloe ferox. The species is distributed in South
Africa and Lesotho. Most of the distribution area is within South Africa. The
amendment will not have negative impacts on the species. On the contrary, it willcontribute to the sustainable use of the species as a conservation tool. In
addition, the amendment as proposed will remove administrative burdens fromboth exporting and importing countries. We recommend that the proposal be
adopted.
Prop. Amendment of the annotation for the Grandidier’s baobab Adansonia
56 grandidieri listed in Appendix II (Switzerland)
The proponent proposes to delete ‘living plants’ from the annotation. This word
was erroneously included in the annotation at CoP17 (Johannesburg, 2016).
Since live and dead plants are always subject to the provision of the Convention,
the current annotation is misleading. By keeping the current annotation, one mayinterpret that dead plants are excluded. To avoid these wrong interpretations, theproposal should be adopted.
Prop. Inclusion of the cedars Cedrela spp. in Appendix II (Ecuador and
57 Brazil)

The genus Cedrela comprises 17 species occurring widely from Mexico toArgentina. Three species in the genus, C. fissilis, C. lilloi and C. odorata, arealready listed in Appendix III. The proposal aims to list all the species inAppendix II. The main threats to these cedars are habitat loss and degradation.
According to the supporting statement, the risk of extinction increases unlesssustainable management and regulation of trade are established. What isneeded is to address such management and regulation, and this can be dealt
with by individual countries. It is unclear whether other range States support the
proposal. Unless most of the range States support the proposal, it should be
rejected.

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For the benefit of species and people( GGT ’s motto )A publication of the Global Guardian Trust. 2019
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