WILDLIFE TRADE FROMASEAN TO THE EU:
ISSUES WITH THE TRADE IN
CAPTIVE-BRED REPTILESFROM INDONESIA
VINCENT NIJMANCHRIS R. SHEPHERD
A TRAFFIC EUROPE REPORT

Report commissioned by the European Commission Contract 070307/2007/479422/MAR/E2

Report prepared by TRAFFIC Europe
for the European Commision
under contract
070307/2007/479422/MAR/E2
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Suggested citation:
Nijman, V. and Shepherd, C. R. (2009).
Wildlife trade from ASEAN to the EU:
Issues with the trade in captive-bred
reptiles from Indonesia.
TRAFFIC Europe Report for the European
Commission, Brussels, Belgium.
ISBN: 9789833393299
Cover photograph: Emerald Monitor Lizard
Varanus prasinus
Photograph credit: Ruchira Somaweera

WILDLIFE TRADE FROM ASEAN
TO THE EU:
Issues with the trade in captive-bred
reptiles from Indonesia

Vincent Nijman and Chris R. Shepherd

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

CONTENTS
ACKNOWLEDGEMENTS ..........................................................................................................iv
EXECUTIVE SUMMARY ............................................................................................................v
INTRODUCTION...........................................................................................................................1
Legislation ....................................................................................................................................1
1. CITES ..................................................................................................................................1
2. National legislation ..............................................................................................................1
3. The European Union ............................................................................................................4
METHODS ......................................................................................................................................5
1. Data collection..........................................................................................................................5
2. Evaluation of evidence of commercial captive breeding.........................................................6
3. Analysis ....................................................................................................................................7
RESULTS.........................................................................................................................................7
1. General Observations ...............................................................................................................7
2. Case study taxa.........................................................................................................................8
Overview ..................................................................................................................................8
Frillneck Lizard Chlamydosaurus kingii ...............................................................................12
Emerald Monitor Varanus prasinus.......................................................................................13
Timor Monitor Varanus timorensis........................................................................................14
Burmese Python Python molurus bivittatus ..........................................................................15
Spiny Turtle Heosemys spinosa .............................................................................................16
DISCUSSION AND CONCLUSIONS ........................................................................................17
RECOMMENDATIONS..............................................................................................................19
REFERENCES..............................................................................................................................20

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesiaiii

ACKNOWLEDGEMENTS

The authors would like to thank Mark Auliya for providing data on the export of captive-bred reptiles
from Indonesia and for his comments on an earlier draft of this report and to Claire Beastall forassistance in sourcing reference material. Thanks to Massimiliano Rocco, WWF Italy / TRAFFIC
Europe - Italy, and Rob Parry-Jones, TRAFFIC Europe, for support in producing the report and for
useful comments throughout. We also thank Maylynn Engler, James Compton, Julie Gray and Azrina
Abdullah for very helpful comments on an earlier draft of this report.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

iv

EXECUTIVE SUMMARY
Unsustainable trade is seen as a major threat to the conservation of many species of reptiles. In
response to this threat, the Government of Indonesia has set in place adequate legislation to regulate
the trade, including promoting captive breeding of species that may not normally be removed from thewild as a conservation tool and an economic solution. Many reptiles are exported from Indonesia to
the European Union (EU) under the auspices of paperwork claiming them to be captive-bred
specimens. However, there are serious discrepancies between the numbers of reptiles exported to the
EU that are declared as captive-bred, and the numbers of reptiles that purported breeding facilities inIndonesia are actually producing, or have the capacity to produce. These discrepancies suggest that
unscrupulous reptile traders may be exporting wild-caught reptiles, along with the required paper workfor captive-bred specimens, to the EU, under the guise of “captive-bred”.
Based on a review of the available evidence, including site visits to all registered captive breeding
facilities in Indonesia, for the majority of species and for the majority of companies, it does not appear
that captive breeding of these species in commercial quantities actually occurs at these facilities. It
appears that wild-caught individuals are misdeclared to circumvent Indonesian wildlife trade
regulation and exported as captive-bred.
To discourage captive-breeding facilities from laundering wild-caught specimens as captive-bred inorder to circumvent Indonesian wildlife export regulations, the Government of Indonesia should:
1) Establish a system of compliance monitoring to reduce levels of laundering wild-caught
reptiles through captive-breeding facilities. Such systems should take into account thebreeding biology and life history characteristics of species that are exported as captive-bred;
2) Undertake regular monitoring, including site visits, of captive breeding facilities andchecking all stock against records;
3) Employ the services of reptile experts to assist in monitoring and inspections;4) Ensure that companies found to be fraudulently exporting wild-caught specimens under theguise of captive-bred specimens should be prosecuted to the full extent of the law, and havetheir business licences suspended or revoked.
To ensure that fraudulently exported wild-caught reptile specimens from Indonesia are not imported,and to ensure that the trade in live reptiles from Indonesia for the pet trade is not occurring to thedetriment of wild populations, the European Commission and Member States should:
1) Refuse imports of “captive-bred” reptiles from countries that do not have effective
monitoring systems in place to ensure legitimate captive-breeding;2) Member States should act in a co-ordinated manner in response to fraudulent export and
CITES enforcement issues;3) Ensure regular dialogue occurs between the EC and the Scientific and Management
Authorities in Indonesia to share knowledge and intelligence on reptile breeding and illegal
trade.
v
Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

INTRODUCTION
Trade in reptiles from Southeast Asia to the rest of the world is extensive and involves large volumes
and numerous species, destined to meet the demand for skins, meat, medicines and pets (Samedi and
Iskandar, 2000; Nijman and Shepherd, 2007). Large numbers of these species originate fromIndonesia, the world’s largest archipelago, and possibly the largest source of reptile species traded fromSoutheast Asia.
The most diverse group of terrestrial fauna exploited for international export from Indonesia are thereptiles, with large volumes being harvested and exported, both legally and illegally (Shepherd, 2000;
Samedi and Iskandar, 2000; Soehartono and Mardiastuti, 2002; Nijman et al., in press). According toreptile traders in Indonesia, and as seen from the UNEP-WCMC CITES Trade Database, more speciesof reptiles are traded from Indonesia for the live pet trade than for any other purpose.
Illegal and unsustainable trade in wild-caught reptiles is a leading threat to the conservation of many
species (Zhou and Jiang, 2004; Shepherd and Ibarrondo, 2005; Stuart et al., 2006). Indonesia has been
identified as a country with high levels of illegal trade in reptile species that are in high demand, andwould benefit greatly from further research into the impact that trade is having on wild populations(Hoover, 1998; Shepherd and Ibarrondo, 2005; Nijman and Shepherd, 2007). In response to the threatof illegal and unsustainable trade, in the early 1990s the Indonesian government began to encourage
captive breeding operations for commercial purposes as both a conservation tool and an economic
solution (Siswomartono, 1998).

Legislation
1. CITES
Indonesia acceded to the Convention on International Trade in Endangered Species of Wild Fauna andFlora (CITES) in December 1978, which entered into force in March 1979. Enforcement of and theimplementation of CITES requirements is the responsibility of the CITES Management Authority, i.e.
Directorate General of Forest Protection and Nature Conservation (PHKA), to enforce the establishedexport quotas for species listed in CITES Appendix II. This is largely carried out via the provincial or
district offices of the Natural Resources Conservation Agency (BKSDA).
2. National legislation
Select species are protected in Indonesia by national legislation, under Undang-undang Republik
Indonesia No.5 Tahun 1990 tentang Konservasi Sumber Daya Alam Hayati dan Ekosistemnya (Act of
the Republic of Indonesia No.5 of 1990 concerning Conservation of Living Resources and their
Ecosystems) widely known as UU No. 5 or Act No. 5. This is also the legislation through which CITES
is implemented and enforced in Indonesia.
Under the CITES National Legislation Project, all Parties to CITES have been categorized, based on
the ability of their national legislation to implement and enforce the requirements under CITES. The
criteria for categorization are as follows:

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

1Category 1 – legislation that is believed to generally meet the requirements for the implementation of
CITES.
Category 2 – legislation that is believed to generally not meet all requirements for the implementationof CITES.
Category 3 – legislation that is believed to generally not meet the requirements for the implementationof CITES.
Indonesia is rated by the CITES National Legislation Project as a Category 1.
Indonesia appears to have sufficient national legislation in place to regulate the trade in wildlife andcommercial captive breeding. Enforcement of this legislation is the responsibility of the PHKA. As
with the implementation of CITES, this is largely carried out via the provincial or district offices of the
BKSDA.
In the Indonesian Government’s regulation No. 8, 1999, “On the utilization of wild plants and animal
species” the following two paragraphs of article 10 define which generations of protected wild animals
may or may not be traded:
1. The result of captive breeding of protected wild animals, which can be traded, is the second
generation and the subsequent generations of the captive breeding.
2. Second generation and following generations resulted from the captive breeding of protectedwildlife animals, are declared as unprotected wild animal species.
This regulation indicates that only the second generation (F2) of protected reptiles from captivebreeding operations can legally be traded, and not wild-caught broodstock (F0) or first-generation
specimens (F1)1.
As a proactive response to Southeast Asia’s alarming levels of wildlife trafficking, the ASEAN Wildlife
Enforcement Network (ASEAN-WEN) was formed in 2005, following the priorities for law
enforcement co-operation identified in the ASEAN Regional Action Plan on Trade in Wild Fauna andFlora, 2005-20102. Indonesia has committed to combating illegal international wildlife trade throughparticipation in ASEAN-WEN, and was pro-active in the actual development of the Regional Action
Plan and ASEAN-WEN itself. Indonesia held the Chair position for ASEAN-WEN for 12 months in
the period 2007-2008.
One of the key objectives of this regional inter-governmental law enforcement network is to promote
direct co-operation amongst relevant law enforcement authorities in ASEAN countries to curb illegal
trade in wild fauna and flora. In order to accomplish this, countries have agreed to increase theefficiency of information and intelligence sharing, and to catalyze efficient inter-agency enforcement
action at both national and international levels. In support of these efforts, TRAFFIC is working with

1 Decree of the Ministry of Forestry, No.P.19/Ministry of Forestry-II/2005 concerning captive managementof wild plant andanimal species

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

2the Wildlife Alliance and its affiliate PeunPa, via a co-operative partnership with USAID, to implement
the ASEAN-WEN Support Program. The Support Program provides technical assistance to thegovernment agencies that constitute ASEAN-WEN, as well as training and capacity building for key
agencies, and via intelligence-led enforcement assistance to enhance the enforcement of national
legislation and CITES protocols.
However, despite Indonesia’s adequate legislation and status as a Party to CITES, it has been well
documented that illegal wildlife trade in Indonesia is widespread and persistent, and current levels of
enforcement are ineffective (Nijman, 2005a; Nijman, 2005b; Shepherd, 2006; Ng and Nemora, 2007;
Shepherd and Nijman, 2007). Of the 179 countries ranked by Transparency International3, Indonesia
ranks 143rd on the Corruption Perceptions Index, and as noted by Newton and Soehartono (2001),
implementation of CITES is hampered by a lack of enforcement and the development of arbitrary
quotas. Lack of capacity, low levels of political will, inadequate allocation of resources and alleged
corruption all impede effective implementation and enforcement of national legislation and CITES.
Indonesia has an extensive quota system for harvest and export of non-protected species to supply both
domestic and international markets (Nijman et al., in press). Prior to setting a quota for CITES-listed
species, the provisions of CITES require that non-detriment findings (NDFs) are carried out to assess
the levels of sustainable off-take for a species or population in any given area, but it appears that NDFs
are rarely undertaken in Indonesia (Shepherd, 2006) or are derived from outdated and questionable
information (Soehartono and Mardiastuti, 2002). Due to concerns that quotas set are too high, theEuropean Union (EU) has suspended trade for some species (Engler and Parry-Jones, 2007).
Furthermore, the EU has suspended trade from certain exporters of particular species of concern (Table
1).
For species listed as protected in Indonesia, there is no quota for capture and trade (domestic orinternational) of specimens from the wild. However, protected species may be bred in captivity andtraded for commercial purposes, as was already proposed in the early 1990s by the Indonesian CITESManagement Authority (PHKA), providing the company doing so is registered with the PHKA andadheres to Indonesian captive-breeding requirements. Based on surveys carried out by TRAFFIC in2006 and information provided by the Indonesian Ministry of Forestry (MoF), 11 companies wereregistered to be actively breeding reptiles for commercial export for the pet trade (Auliya, in prep.). As
of 2008, there were 19 companies registered.
All commercial breeders of reptiles for export in Indonesia are required to submit monthly breeding
reports to the MoF, indicating for each species the volumes of parent stock, and the numbers ofoffspring produced that month.
While a number of companies have permits to breed protected reptile species, it is suspected that
unscrupulous traders are laundering wild-caught specimens, of which many are captured as juveniles,
and misdeclaring the specimens as captive-bred, exploiting the fact that it is extremely difficult for
authorities in importing countries to differentiate between wild and captive-bred specimens. Certain

2
3 http://www.aseansec.org/17753.pdf
http://www.transparency.org/
Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

3

Table 1.
Reptiles included in Annex B to Regulation (EC) No. 338/97 whose introduction into the Community fromcertain exporters is suspended, according to the Commission Regulation (EC) No 605/2006 of 19 April 2006

dealers have stated to TRAFFIC that they welcome the inclusion of rare and high-commercial value
species to be listed as protected in Indonesia, as they are then no longer restricted to harvest and export
quotas, but can export unlimited volumes when they are declared as captive-bred.
Exporting wild-caught specimens, although illegal, can be far more profitable than breeding specimens
for export. TRAFFIC’s research has found that wild specimens can easily be purchased in Indonesia
and exported, declared as “bred in captivity” (often accompanied by the correct paperwork), and thisprocess is far less expensive than the investment required to legitimately raise, breed, rear and housecaptive-bred specimens. Furthermore, legitimate dealers and animal breeders are concerned that bogus“breeding” operations will eventually lead to international bans on reptile (or parrot4) imports fromIndonesia.
Until now, little research has been carried out as to the roles these breeding facilities play in legal andillegal international wildlife trade. In some cases, reported breeding successes are improbable. For
example, breeders claim to have exported first generation offspring of species that take approximately
10 years to reach sexual maturity, such as the Spiny Turtle Heosemys spinosa. It seems unlikely to beeconomically viable in these situations to raise and breed generations of this species in captivebreeding facilities for such a long period of time, before being able to export an F1 or F2 specimen.
Such issues need to be examined further in order to ensure that these breeding facilities are not having
a negative impact on the conservation of wild populations of these species.
3.The European Union
The EU is one of the largest markets for live reptiles for the pet trade (Auliya, 2003). In fact, the EU
was the top global importer by value of live reptiles in 2005 with an estimated import value of EUR 7
million, of the global estimated import value of EUR 30 million for live reptiles (Engler and ParryJones, 2007). While much of the trade is carried out in accordance with relevant laws and regulations,
illegal trade continues to be a serious issue. Demand for rare species in the EU has been documented

4

Research by TRAFFIC Southeast Asia has revealed that problems and challenges very similar to these described here for
reptiles are prevalent in the trade of captive-bred birds, especially parrots, from Indonesia. However, since the ban on importof birds into the EU, imports of birds from ASEAN countries to the EU have declined considerably.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

4as contributing to the decline in some rare Indonesian reptiles, such as the Roti Island Snake-necked
Turtle Chelodina mccordi, which is now near extinction in the wild (Shepherd and Ibarrondo, 2005).
To address this issue, the EU Enforcement Action Plan (Commission Recommendation of 13 June 2007
identifying a set of actions for the enforcement of Council Regulation (EC) No. 338/97 on theprotection of species of wild fauna and flora by regulating trade therein, also refered to as Commission
Recommendation 2007/425/EC) recommends that Member States develop inter-regional collaboration
to combat illegal wildlife trade by building links with other regional and sub-regional initiatives, such
as ASEAN-WEN, exchanging information and providing assistance to facilitate legal and sustainable
trade through the correct application of procedures.
Questions have increasingly been raised over the legitimacy of the export of some captive-bred reptile
species to the EU. In response, TRAFFIC here reviews the validity of commercial captive breeding in
reptiles in Indonesia, especially pertaining to those species exported to EU markets. This reportprovides detailed information on the trade in species from Indonesia that are declared as captive-bred
but which, in fact, involve specimens of wild origin.

METHODS
1. Data collection
This report focuses on five reptile taxa, i.e. three lizards, one snake and one freshwater turtle, (Frillneck
Lizard Chlamydosaurus kingii, Emerald Monitor Varanus prasinus, Timor Monitor Varanus
timorensis, Burmese Python Python molurus bivittatus and Spiny Turtle Heosemys spinosa) whichwere selected as case studies for the captive-bred reptile trade in Indonesia (Table 2, 3). Four of thesetaxa are listed in Appendix II of CITES and four are protected by Indonesian national law. The fivespecies are largely bred for export to international markets, including the EU.
This report focuses on the export of captive-bred specimens of these five case study taxa (Table 2, 3)
in 2006, as these are the most recent data for which export and import data are available. Facility
visits were planned and carried out in consultation with the Indonesian MoF which also functions as
the CITES Management Authority, who provided relevant documents (including monthly breeding
status reports), permits, and staff to accompany a TRAFFIC researcher in the field. From 31 July – 18
August and from 13 November – 30 November 2006, each facility in Indonesia with valid captivebreeding permits was visited. One significant breeder/exporter could not be visited (Co. #6) becauseof a legal dispute between this company and the MoF concerning trade in protected species; thisbreeder’s licence was revoked in 2006 and no export permits were granted5. A comprehensive reporton all the facilities surveyed in Indonesia with regards to captive breeding of reptiles and birds for
global export is currently under preparation (Auliya, in prep.).
All facilities that indicated captive breeding of one or more of the focal taxa were members of theIndonesian Reptile and Amphibian Trade Association (IRATA). Data were requested on the total
numbers of specimens exported, as reported to IRATA.
At each facility, the assessment team (TRAFFIC researcher and MoF staff) was guided around thefacilities, making sure that all relevant taxa were checked. For each taxon, information on quantities,

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

5breeding status and details, etc. were requested from the trader; specimens were counted as accurately
as possible, details on breeding facilities were taken, and, where permitted, photographs were taken.
Information on breeding requirements, successes and obstacles was obtained through discussions withthe breeding facility owners and staff. All interviews were conducted in Indonesian, except where
owners and staff were foreign nationals, in which case English was used.
Data on the reproductive parameters, minimum export sizes, prices to purchase a wild-caught
individual6, and export prices for each species were collected from experts and existing literature.
It must be noted that if a wild-caught female is gravid at the time of purchase, the resulting offspring
are not considered to be captive-bred, but are considered to be wild-caught as well. Consequently,
observing eggs at a captive-breeding facility in the absence of adequate breeding conditions for the
species is considered here as an indication that gravid females were acquired in that condition from thewild. In order for the specimens to be considered captive-bred, the breeding itself must take place incaptivity.
Data were retrieved from the UNEP-WCMC CITES database on the export and import of four of thefive focal taxa, i.e. those that are listed in CITES Appendix II. Data were extracted for live specimens,with individuals traded for commercial purposes (purpose code T), that are reported as captive-bred(source codes either captive-born ‘F’ or captive-bred ‘C’). Where there was a discrepancy between
export and import quantities recorded, the larger of these two values was selected.
2. Evaluation of evidence of commercial captive breeding
To determine the practical status of commercial captive breeding of focal taxa facilities that were
investigated, the following criteria were assessed:a) The focal taxon was observed in the facility by the assessment team;b) Owner/staff confirmed that they are indeed breeding the focal taxa;c) Animals (if present) were in reasonable health, to allow for potential breeding;d) Adequate facilities for breeding were present (e.g., separate enclosures for each female,sufficient breeding conditions including a suitable substrate to lay eggs in were present);e) Quantity data from MoF monthly breeding reports corresponded to an acceptable degreewith what was observed during the site visits by the assessment team, andf) Staff had basic knowledge on breeding requirements.

5

Note: this company has since regained permission to breed (2007) and export, having won a court case against theauthorities
6
Price information was found to be available despite four out of five of the case study species considered being classified asprotected.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

6

If all of the criteria listed in a-d were met at a particular facility, it was assumed that captive-breeding
indeed did take place. When any of the conditions listed under a-d were not met, it was assumed that
captive-breeding did not take place, with e and f providing additional background information for thisassumption. Criteria from d and e, with additional support from f, allowed for assessing the volumes
that each facility was able to produce.
3. Analysis
The numbers of specimens per focal taxon reported in the most recent MoF monthly breeding reportwere compared with the numbers that were actually observed during the site visit (the time lag due toreporting for most companies was one to two months, occasionally up to five months). The data wereavailable for an average of six taxa per company (range 1-16).
Time (in years) needed for production of F2 offspring was estimated for each of the five focal taxa
individually by calculating two times the gestation time plus two times the incubation time plus age atsexual maturity for a female. Maximum reproductive output per year was estimated by multiplying the
maximum possible clutch size with the maximum possible number of multiple clutches per year.
For those companies that appeared capable of commercial captive-breeding based on the assessment
criteria, using the numbers of female specimens observed at facilities in August 2006, and the
reproductive output per female per year, it was assessed whether or not it was physically possible toproduce the number of offspring as reported in CITES database exports.

RESULTS
1. General Observations
This section provides an overview of the observations made during the survey and the practicalpotential of the breeding facilitites to produce captive-bred reptiles. Insight into the methods used todeceive authorities and launder wild-caught reptiles as captive-bred is provided in detail andillustrated through five case studies.
Of the 10 operations surveyed by the team in 2006, only two to three facilities were run at aprofessional level, with knowledgeable staff and adequate facilities to breed reptiles in captivity. Allother facilities did not appear to be suitable for captive breeding or appeared to be rarely used for
captive breeding.
The majority of locations surveyed did not have facilities suitable for breeding reptiles, especially on acommercial scale. Staff capacity and knowledge did not appear sufficient, and indeed some admitted
that laundering was occurring. The quantities of breeding stock required to produce the number ofoffspring that were exported as captive-bred were not present. In six companies (i.e. Co. #1, Co. #2,
Co. #3, Co. #5, Co. #7, Co. #8) between one and five taxa of reptile were reported to be part of theircaptive-breeding programmes (with monthly breeding reports indicating 25 to 201 specimens present
for the most recent month), but not a single specimen was observed to be present at the facility,
therefore it would not be possible to breed these taxa at these facilities.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

7Many of the monthly breeding reports were identical over consecutive months, indicating either
careless reporting, or little active breeding. There were large discrepancies between numbers observed
and numbers reported as stock and offspring. Typically, the observed numbers were about one fifth ofwhat was reported. In two-thirds of the cases the observed numbers were less than half of what wasreported. Additionally, the taxa documented in the breeding reports were not always observed during
the site visits.
Figure 1 shows the relationship between the numbers of reptile taxa (n=27) present at the nine captivebreeding facilities visited, as reported in the most recent monthly breeding reports submitted by thefacilities to the CITES Management Authority (at the time of the survey), versus the numbersrecorded during site visits by the TRAFFIC-MoF team in 2006. The diagonal line represents the lineof unity, where reported and recorded numbers are equal.
Examinations of specimens, when possible, revealed external parasites on various taxa (especially at
Co. #3 and Co. #9) indicating that these were likely to be wild caught specimens. Specimens reared
for a long period of time in captivity, or bred in captivity are not likely to have any external or internalparasites, as these are normally treated by the breeder since they are detrimental to the success of thebusiness and make reptiles unsuitable for export, due largely to the risk of spreading disease andpotential introduction of exotic parasites (Burridge, 2001; Pietzsch, et al., 2006).
Due to conservation concerns, the EU banned import of particular species of reptiles from certain
exporters in Indonesia (Table 1). According to some reptile dealers in Jakarta, in order to elude thisban, it is common practice for exporters to send their animals from other companies that do not havesuch restrictions (often via Co. #9). According to dealers, some export species that they themselves do
not have breeding permits for, using permits obtained by other dealers.

2. Case study taxa
Overview
Of the 10 facilities surveyed, eight claimed to be breeding one or more of the five case study taxa.
Upon analysis of breeding records, breeding facilities, and capacity to breed among other criteria, it
was determined whether the facility could actually breed these taxa in the quantities that were declared(Table 2). According to this analysis, only three facilities could potentially have been legitimately
breeding some of the taxa examined here. Table 3 illustrates the number of breeding stock present foreach of the case study taxa, the number of offspring these taxa produce and based on their life history
characteristics, the number of potential offspring that could be produced.
This is then compared with the number of taxa exported in 2006, according to the UNEP-WCMC
CITES Trade Database (C. kingii is not included in this section as it is not listed in the Appendices of
CITES) and then the total number of each taxon reported as captive-bred (realised) in 2007 to the MoF.
In all five examples, based on these criteria it appears that maximum breeding potential for these taxa
are being greatly exceeded (Table 3).

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

8Figure 1.
Relationship between numbers of reptile taxa and numbers recorded during site visits, showing that for mosttaxa recorded numbers were significantly lower than reported numbers

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

9Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

10^ according to directors, no export of captive bred specimens**Two other companies inspected, Co. #8 and Co. #10, did not indicate breeding any of the five focal taxa, nor were these taxa
observed on their premises, and a third company, Co. #6, was suspended from trading in 2006.

Likelihood of breeding case study species among surveyed breeding facilities, 2006.

Table 2.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

11

1 Sources: C. kingii: Shine and Lambeck, 1989; Griffiths, 1999; V. prasinus: Eidenmuller, 1998; Jacobs, 2002; V. timorensis: Walls 2006; P. molurus bivittatus: Van Mierop and Barnard, 1976;
H. spinosa: Herman, 1993; all species: M. Auliya pers. comm., 2008.
2 Based on a male : female ratio of 1 : 1.5 for breeding stock, with all females delivering the maximum biological production per year.
3 Retrieved from UNEP-WCMC CITES Trade Database; note that C.kingii is not listed on any of the CITES Appendices and hence no information on exports of this species are listed.
4 Indonesian Reptile and Amphibian Trade Association.

4

Table 3.
Case study taxa in facilities claiming captive breeding, showing that numbers in breeding reports are exaggerated, and that for all taxa but the Burmese Python,
captive breeding is unlikely to be occurring as indicatedFrillneck Lizard Chlamydosaurus kingii
Distribution: New Guinea and offshore islands, Australia
IUCN status: Not listed as threatened by the IUCN Red List of Threatened Species.
Protection status in Indonesia: Protected
The Frillneck Lizard is a highly seasonal breeder (Shine and Lamback, 1989), females become
sexually mature at 1.5 years (Griffiths, 1999), and after a long gestation/incubation period, first
production of F2 offspring is possible after >2 years. For oviposition, females dig holes in the ground(Reisinger, 1992); maximum annual production is about 20-30 eggs (Table 3).
Of all the facilities in Indonesia having permits to breed this species in captivity, six facilities hold thespecies and five claim production of F2 offspring for export. The breeding reports of these fivecompanies which claim production of F2 offspring for export list 457 F1, and 1459 F2-F3 specimens
in their facilities. At three of these facilities, no specimens were present, and at two no breeding
facilities were present.
This indicates that despite almost 2000 captive-bred specimens reported from these five facilities, there
is no physical evidence of captive-breeding of Frillneck Lizard. According to some individuals
involved in the trade, specimens of this species are captured as juveniles from the wild, mostly insouthern Papua. It therefore appears that all specimens of this species exported as captive-bred arein fact wild-caught.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

12

Emerald Monitor Varanus prasinus
Distribution: New Guinea and offshore islands, Australia
IUCN status: Not listed as threatened by the IUCN Red List of Threatened Species, howeverconsidered by Ziegler, et al. (2007) to be threatened in the wild by capture for the pet trade andhabitat loss.
Protection status in Indonesia: Protected
Females become sexually mature after approximately 2 years, and with a long gestation period (approx.
60 days) and incubation period (166-206 days) first production of F2 is possible after >2.5 years. This
species breeds year-round but produces small clutches, with a maximum of 2-5 eggs a year
(Eidenmueller 1998; Jacobs 2002).
In 2006, according to the UNEP-WCMC CITES Trade Database, Indonesia exported 661 specimens
labelled as captive-bred (403 C; 258 F), with 250 reported as imported by EU importing countries.
At the time of the survey, six companies held the species and four claimed production of F2, with one
indicating that no captive-bred specimens had been exported thus far. One of the companies lacks
breeding facilities, and the remaining two companies hold a total of 97 F1-F2 specimens. When thespecies’ breeding characteristics are considered, the total possible number of captive-bred offspring
does not exceed half of the quantity actually exported and claimed as captive-bred (Table 3). However,according to dealers involved in the trade of this species, in reality, none are bred in captivity (Anon.,pers comm., 2008). It therefore appears that all specimens of this species exported as captive-bred
are in fact wild-caught.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

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Timor Monitor Varanus timorensis
Distribution: Indonesia; Timor Leste
IUCN status: Not listed as threatened by the IUCN Red List of Threatened Species.
Protection status in Indonesia: Protected
In 2006, Indonesia exported 580 specimens of Timor Monitors labelled as captive-bred (C), of which
182 specimens were reported as imported by EU Member States (UNEP-WCMC CITES Trade
Database).
Females become sexually mature after three years, and have a long gestation period (35-49 days) andincubation period (93-186 days) (Pianka et al., 2004). Consequently the first production of F2
offspring can be expected after ?3.5 years. The species is a highly seasonal breeder, producing one
clutch of 4-10 eggs a year (Walls, 2006).
Four facilities in Indonesia hold the species; one facility breeds small quantities in captivity but does
not export specimens, one facility does not breed this species in captivity, and two facilities claim
production of F2 in monthly reports. One of these facilities (Co. #3) reports 445 specimens (F1-F2),
but only 20 were observed (14 of which were adult females), all F1, according to the owner. The othercompany (Co. #4) erroneously or falsely documented this species as a non-protected species in thebreeding reports, indicating 39 F1-F2, although according to the company they were not breeding thespecies at the time of the survey. The maximum possible number of offspring is about a third of theactual number of exported specimens (Table 3). However, according to dealers involved in the tradeof this species, in reality, none are bred in captivity (Anon., pers comm., 2008). It therefore appears
that all specimens of this species exported as captive-bred are in fact wild-caught

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

14Burmese Python Python molurus bivittatus
Distribution: South and continental SE Asia, patchy distribution in Indonesia (Sulawesi, Java, Bali,
Sumbawa)
IUCN status: Not listed as threatened by the IUCN Red List of Threatened Species.
Protection status in Indonesia: Protected
Indonesia exported 257 captive-bred specimens (243 C, 14 F), of which 130 specimens were imported
into the EU (UNEP-WCMC CITES Trade Database).
Females become sexually mature after the fourth year of age (however sexual maturity strongly
depends on the feeding condition and can also occur between 1.5 and three years). After a gestation
period of approximately 2-3 months and almost two months of incubation; the first F2 offspring can beproduced after ±2.5 years. While clutch sizes can be large (30-58 eggs) on average 18-20 hatchlings
survive (Van Mierop and Barnard, 1976; Manthey and Grossmann 1997; Krysko et al., 2008).
Of all the companies in Indonesia that have permits to breed reptiles in captivity, two companies report
breeding this python species. One includes 60 individuals of F0 generation in the monthly breeding
reports, but none were observed to be present during the survey. Another facility specialises inbreeding rare colour morphs of this species, and reports 6 F0, 20 F1 and 7 F2 in monthly reports. These
27 F1-F2 specimens could in principle supply all reported captive-bred specimens when breeding
characteristics are considered (Table 3). However, in seven of the monthly breeding reports thenumber of F2 is consistently kept at seven individuals, which may indicate inaccurate reporting. It
therefore appears that the number of actual breeding records of this subspecies are reported
inaccurately and therefore do not realistically reflect the current breeding status.

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

15

Spiny Turtle Heosemys spinosa
Distribution: Continental and insular Southeast Asia
IUCN status: Listed as Endangered in the IUCN Red List of Threatened Species.
Protection status in Indonesia: Not ProtectedExport of wild-caught specimens of this species to the EU was suspended as of 16 April 2006
(Commission Regulation (EC) No 605/2006 of 19 April 2006). CITES data indicates that Indonesia
exported 192 specimens in 2006, 40 of which went to France, labelled as captive-bred (C).
However, the Spiny Turtle is not a suitable species for commercial captive breeding due to its life
history characteristics, and so it is questionable whether any of these specimens met the legal
definition of captive-bred specimens in Indonesia. Both sexes may attain maturity at the age of 10
years (Herman, 1993). With a clutch size of 1-3 eggs and up to 3 clutches a year, the maximum
annual production can be 9 eggs/year. However, it has been recorded that a female in captivity laid only
10 eggs in a five year period (Herman, 1993). Growth is also extremely slow: a plastron (lower shell)of one specimen measured 7.5cm, which only increased by 1 cm in six years (Mertens, 1971). Of allcompanies holding captive breeding licences, one (Co. #3) holds the species and claims to produce F1;
however no Spiny Turtles were observed during visits, and no breeding facilities were present.
Consequently it appears that exported specimens were all wild-caught and that no captive breeding of
this species occurs. It therefore appears that all specimens of this species exported as captive-bred
are in fact wild-caught.

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DISCUSSION AND CONCLUSIONS
While some taxa may in fact be reproducing in Indonesian captive-breeding facilities, due to theobservations on numbers present in these facilities, the life history characteristics of the taxa involved,
the conditions at the captive-breeding facilities and the statements of owners and staff, it appears thatthe majority of taxa are most likely captured from the wild and are purposefully misdeclared as
captive-bred for export.
The conditions observed in most captive-breeding facilities visited were not sufficient or conducive for
reptile breeding, and in some facilities no arrangements for breeding were present at all. Few facilities
employed staff with technical skills or expertise in reptile breeding, and indeed staff at many of the
facilities visited indicated to the team that breeding does not take place. Furthermore, given the
difficulties in housing and breeding these animals, keeping offspring alive and rearing them tobreeding size themselves (in order to produce F1 and following generations), and the cost of feeding
and maintenance for so many animals over a longer period of time required to do so by their life
history characteristics, it is not economically feasible to breed many of the species claimed as
captive-bred for commercial purposes. Dealers have stated to TRAFFIC that it is easier and much lessexpensive to purchase wild-caught taxa and export them under the guise of captive-bred to circumvent
regulations restricting trade in wild-caught protected taxa. The chances of this sort of fraud being
detected and intercepted by officials that are able to distinguish captive-bred from wild-caught
specimens are extremely low.
A lack of monitoring and expertise among the enforcement agencies charged with regulating these
operations provides an opportunity for unscrupulous dealers to carry out this illegal trade with little fearof detection and prosecution. Some dealers themselves stated to TRAFFIC that this was the techniquemost commonly used to smuggle high-value protected reptiles to the EU.
Currently there is no established system in Indonesia to ensure that laundering of wild-caught reptile
taxa through captive breeding operations does not take place on a large scale. Likewise, there iscurrently no system or methodology in importing countries to prevent imports of falsely declaredcaptive-bred taxa. Consequently, shipments arrive from Indonesia to importing countries with official
permits stating the specimens are captive-bred, and the specimens are therefore accepted as such by
officials in the importing country. Laundering of this type undermines the Indonesian government’s
efforts to conserve wildlife and provide sustainable incomes for legal traders.
At most, three of the 10 companies that have permits to export captive-bred reptiles in Indonesia arerun professionally and may be breeding reptiles in captivity, whereas the other facilities are very
unlikely to be breeding offspring of reptile species. This second and larger group of facilities may be
exporters of wild-caught reptiles which are purposely misdeclared as captive-bred to circumvent
Indonesian regulations on trade in wild-caught protected species.
Six out of 10 companies claim to produce often substantial numbers of F2 specimens from between one
and five species per company, however often the numbers required to produce this number of
specimens, or the species themselves, are not present in the breeding facilities of these six companies.
There are significant discrepancies between the number of reptile specimens that companies report to
the MA, and the number of reptile specimens present at breeding facilities, with on average only about

Wildlife trade from ASEAN to the EU: Issues with the trade in captive-bred reptiles from Indonesia

17one fifth of the reported numbers actually present. This is an indication that the levels of breeding stock
are not present in sufficient quantities to be producing the number of F2 offspring which are exported,suggesting that these may have actually been wild-caught misdeclared specimens. Additionally, mostmonthly breeding reports submitted to the Indonesian CITES Management Authority are identical eachmonth, and do not reflect the reality of the breeding output of these companies.
Of the five focal taxa investigated by TRAFFIC in Indonesian captive-breeding facilities, only one, theBurmese Python was kept in large enough numbers and, at least in some facilities, such that viable
numbers of captive-bred offspring could be produced for export as live specimens. For the other four
focal taxa, the majority of individuals exported were very likely to have been wild-caught andlaundered as captive-bred.
Based on a review of the available evidence, including site visits to each registered captive breeding
facility, it is concluded that for the majority of species and for the majority of companies, it does notappear that commercial captive breeding of these species occurs, and wild-caught individuals are
misdeclared to circumvent Indonesian wildlife trade regulation and are exported as captive-bred.

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18

RECOMMENDATIONS
To minimize the opportunity for reptile traders with captive-breeding facilities from laundering wildcaught taxa as captive-bred in order to circumvent Indonesian wildlife export regulations, theGovernment of Indonesia should:1). Establish a system of compliance monitoring to reduce levels of laundering wild-caught
reptiles through captive-breeding facilities. Such systems should take into account thebreeding biology and life history characteristics of taxa that are exported as captive-bred;
2) Undertake regular monitoring, including site visits, of captive breeding facilities andchecking all stock against records;
3) Employ the services of reptile experts to assist in monitoring and inspections;4) Ensure that companies found to be fraudulently exporting wild-caught taxa under the guiseof captive-bred specimens should be prosecuted to the full extent of the law, and have theirbusiness licences suspended or revoked.
To ensure that fraudulently exported wild-caught reptile taxa from Indonesia are not imported, and toensure that the trade in live reptiles from Indonesia for the pet trade is not occurring to the detrimentof wild populations, the European Commission and Member States should:
1). Refuse imports of “captive-bred” reptiles from countries that do not have effective
monitoring systems in place to ensure legitimate captive-breeding;2). Member States should act in a co-ordinated manner in response to fraudulent export and
CITES enforcement issues;3). Ensure regular dialogue occurs between the EC andthe Scientific and Management
Authorities in Indonesia to share knowledge and intelligence on reptile breeding and illegal
trade.

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19

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TRAFFIC, the wildlife trade monitoring network, works toensure that trade in wild plants and animals is not a threat
to the conservation of nature. It has offices covering mostparts of the world and works in close co-operation with theSecretariat of the Convention on International Trade inEndangered Species of Wild Fauna and Flora (CITES)For further information contact:

The Director
TRAFFIC Europe / TRAFFIC International
219a Huntingdon Road
Cambridge CB3 0DL
United Kingdom
Telephone: (44) 1223 277427
Fax: (44) 1223 277237
Email: traffic@traffic.org

December 2009

The Director
TRAFFIC Southeast Asia
Unit 3-2, 1st Floor
Jalan SS23/11, Taman SEA
Petaling Jaya, Selangor
Malaysia
Telephone: (603) 7880 3940
Fax: (603) 7882 0171
Email: tsea@po.jaring.my