T R A F F I C TRACEABILITY SYSTEMS IN THE
CITES CONTEXTREPORT

DECEMBER 2015

2015

A review of experiences, best practices and lessons learned for the
traceability of commodities of CITES-listed shark species
Victoria Mundy and Glenn Sant

Report prepared by TRAFFIC for the CITES
Secretariat.
All material appearing in this publication is
copyrighted and may be reproduced withpermission. Any reproduction in full or inpart of this publication must credit the
CITES Secretariat as the copyright owner.
The views of the authors expressed in thispublication do not necessarily reflect those of
the CITES Secretariat, the European
Commission, the TRAFFIC network, WWF
or IUCN.
The designation of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of the CITES
Secretariat, the European Commission,
TRAFFIC or its supporting organizations
concerning the legal status of any country,
territory, or area, or its authorities, orconcerning the delimitation of its frontiers orboundaries.
The TRAFFIC symbol copyright andRegistered Trademark ownership is held byWWF. TRAFFIC is a strategic alliance ofWWF and IUCN.
Suggested citation: Mundy, V. and Sant, G.
(2015). Traceability systems in the CITES context:
A review of experiences, best practices and lessons
learned for the traceability of commodities of CITESlisted shark species. TRAFFIC report for the
CITES Secretariat
Corresponding author Glenn Sant.

2

Table of contents
Acknowledgements .............................................................................................. 4
Acronyms and abbreviations ................................................................................. 4
1. Project objectives ........................................................................................... 7
2. Methods ........................................................................................................ 8
3. Traceability .................................................................................................... 93.1. Definitions ............................................................................................................... 93.2. Traceability in the CITES context................................................................................ 9

4. Review of CITES traceability systems ............................................................... 124.1. Caviar...................................................................................................................... 12
4.1.1. Overview of caviar trade ............................................................................................... 12
4.1.2. Labelling requirements .................................................................................................. 12
4.1.3. Implementation of the labelling system ....................................................................... 16
4.1.4. Lessons learned ............................................................................................................. 19
4.2. Crocodile skins ........................................................................................................ 22
4.2.1. Supply chains ................................................................................................................. 22
4.2.2. Elements of the CITES crocodilian skin tagging system................................................. 22
4.2.3. Implementation and effectiveness of the crocodilian skin tagging system .................. 23
4.3. Queen Conch ........................................................................................................... 32
4.3.1. Overview of fisheries and trade .................................................................................... 32
4.3.2. Recent developments .................................................................................................... 33
4.3.3. Traceability options for Queen Conch ........................................................................... 33
4.4. Timber .................................................................................................................... 42
4.4.1. Overview of timber traceability systems....................................................................... 42
4.4.2. Challenges ..................................................................................................................... 44
4.4.3. Progress of activities for CITES timber .......................................................................... 46
4.4.4. National case studies ..................................................................................................... 48
4.4.5. Lessons learned and best practices ............................................................................... 55

5. Assessment of the use of traceability systems for commodities of CITES
Appendix II-listed shark species .................................................................... 57
5.1. Traceability systems and sharks .............................................................................. 57
5.1.1. Role of traceability in supporting CITES implementation for shark species listed in
CITES Appendix II ........................................................................................................... 57
5.1.2. Traceability of wild-caught fish products ...................................................................... 58
5.1.3. CITES shark products and generalized supply chains .................................................... 63
5.1.4. Issues to be considered for the traceability of CITES shark commodities .................... 71
5.2. Application of CITES traceability measures to shark commodities............................. 72
5.2.1. General observations .................................................................................................... 72
5.2.2. Possible elements of a traceability system for commodities of CITES-listed sharkspecies ........................................................................................................................... 73

References .......................................................................................................... 863

Acknowledgements
The authors would like to thank the CITES authorities of Australia, Belize, France, Germany,
Guatemala, Italy, the United Kingdom and the United States, and other experts that provided
information for this report. The authors would also like to thank TRAFFIC colleagues Chen Hin
Keong, Katalin Kecse-Nagy, Thomasina Oldfield, Bernardo Ortiz and Richard Thomas forreviewing drafts of the report, and Colomban Mac Dowall, Kanitha Krishnasamy, Paola Mosig
and Kay Wakao for their support in gathering information and providing relevant contacts.
Information provided by Jutta Jahrl, WWF-Austria, on the universal caviar labelling requirements
is also gratefully acknowledged.
TRAFFIC would also like to thank Cathay Pacific Airways Limited for making available to thisreview an unpublished review of traceability and sharks authored by Ian Knuckey1, Glenn Sant2
and Matt Koopman3 in 2014.
This publication was funded by the European Union, through the CITES capacity-building
project.

Acronyms and abbreviations
AC

Animals Committee (CITES)

ACP

African, Caribbean and Pacific

CDS

Catch documentation scheme

CFMC

Caribbean Fisheries Management Council

CITES

Convention on International Trade in Endangered Species of Wild Fauna and
Flora

COFI

Committee on Fisheries (FAO)

COFI FT

Committee on Fisheries Sub-Committee on Fish Trade (FAO)

CONAPConsejo Nacional de Areas Protegidas/National Council of Protected Areas(Guatemala)

CoP

Conference of the Parties

CPUE

Catch Per Unit Effort

CRFM

Caribbean Regional Fisheries Mechanism

CSG

Crocodile Specialist GroupCTE

Critical Tracking Event

1 Fishwell Consulting
2 TRAFFIC
3 Fishwell Consulting

4

EA

Enforcement Authority (CITES)

EEZ

Exclusive Economic Zone

EU

European Union

FAO

Food and Agriculture Organization of the United Nations

FDPM

Forestry Department Peninsular Malaysia

FLEGT

Forest Law Enforcement, Governance and Trade

FOD

Forest Origin Document (Brazil)

HACCP

Hazard Analysis and Critical Control Point

IBAMA

Brazilian Institute for Environment and Renewable Natural Resources

ICCATInternational Commission for the Conservation of Atlantic Tunas

IFS

Introduction from the sea

IGO

Intergovernmental organization

ISO

International Organization for Standardization

ITTO

International Tropical Timber Organization

IUCN

International Union for Conservation of Nature

IUCN SSC

IUCN Species Survival Commission

IUU

Illegal, unreported and unregulated

IWG-RSInternational Working Group on Reptile SkinsKDE

Key Data Elements

MA

Management Authority (CITES)MCS

Monitoring, control and surveillance

NDF

Non-Detriment FindingNGO

Non-Governmental Organization

OSPESCA

Organizacion del Sector Pesquero y Acuicola del Istmo Centroamericano(Central America Fisheries and Aquaculture Organization)

PC

Plants Committee (CITES)

QCEW

Queen Conch Expert Workshop

QCWG

Queen Conch Working GroupRESP

Responsible Ecosystems Sourcing Platform
5

RFID

Radio frequency identification

RST

Review of Significant TradeSA

Scientific Authority (CITES)SCStanding Committee (CITES)SPAWSpecially Protected Areas and Wildlife

TDS

Trade documentation scheme

UK

United Kingdom

UN

United Nations

UN/CEFACT United Nations Centre for Trade Facilitation and Electronic Business
UNCTAD

United Nations Conference on Trade and Development

UNEP-WCMC United Nations Environment Programme World Conservation Monitoring
CentreUS

United States

USD

US Dollars

US FWS

United States Fish and Wildlife Service

VMS

Vessel Monitoring Systems

VPA

Voluntary Partnership Agreement

WECAFC

Western Central Atlantic Fishery Commission

WWF

World Wide Fund for Nature61. Project objectives
At its 27th meeting (AC27, Veracruz, 2014), the CITES4 Animals Committee agreed on a numberof recommendations relevant to addressing the implementation challenges posed by the inclusionof five species of sharks and both species of manta ray Manta spp. in CITES Appendix II at the
16th meeting of the Conference of the Parties (CoP16, Bangkok, 2013). These recommendations,which support implementation of CITES Resolution Conf. 12.6 (Rev. CoP16) on the Conservationand management of sharks, were considered at the 65th meeting of the CITES Standing
Committee (SC65, Geneva) in July 20145 and an intersessional working group was establishedwith a mandate to consider these recommendations6.
The current project contributes to the fulfillment of the following recommendations agreed at
AC27 (paragraph numbers refer to SC65 Doc. 46 on sharks and rays) and will support thedeliberations of the Standing Committee intersessional working group on sharks:Paragraph o) The Animals Committee requests the Standing Committee, at its 65th meeting, to consider
relevant matters relating to the implementation of shark listings, including the following:o ii. Issues pertaining to chain of custody, including where in the trade chain it is considered essential
to be able to identify the products in trade;Paragraph p) Both the Standing Committee and the Animals Committee should review the requirements thathave been developed for the trade in processed product types of Appendix II species such as crocodile skins,
caviar etc. and consider their applicability to shark products containing Appendix II species.

Specifically, this report presents the findings of a review of traceability systems that have beendeveloped in the CITES context for the trade in processed product types of Appendix II-listed
species. The report considers the experiences, lessons learned and best practices from these casestudies for ensuring the traceability of products of shark species listed in CITES Appendix II,
and analyses the potential for establishing an effective traceability system – along the lines of
those already developed in the CITES context – for shark commodities.
For a review of the market chain and other traceability systems developed for commerciallyexploited aquatic species, see Andre (2013) and the following report produced for the CITES
Secretariat: Traceability study in shark products (Lehr et al., 2015).
The case studies of focus in this report are traceability systems developed for sturgeon caviar,
crocodile skins, Queen Conch Strombus gigas, and timber, and/or related developments, as
appropriate. These examples were selected as case studies, in light of experience and recent
progress on issues relating to traceability and the potential to provide relevant guidance for the
traceability of CITES-listed shark products.
The remainder of this report is structured as follows: Section 2 provides an overview of the methods used to gather information for this report.
 Section 3 provides a brief explanation of traceability and how this operates in the CITES
context.
 Section 4 presents the results of the review of traceability systems developed for sturgeon
caviar, crocodile skins, Queen Conch and timber in the CITES context.
 Section 5 assesses the use of traceability measures for commodities of CITES Appendix IIlisted shark species, based on the experiences, lessons learned and best practices identified in
the review of CITES systems.

4 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
5 SC65 Doc. 46: http://www.cites.org/sites/default/files/eng/com/sc/65/E-SC65-46.pdf
6 SC65 Summary Record

72. Methods
The review of CITES traceability systems is based on a literature review and contact withselected CITES authorities, industry representatives and experts with experience of the operationand implementation of the respective systems. Feedback was obtained via questionnaires andthrough email and telephone discussions. Published sources of information reviewed for thisreport include: CITES documents, non-governmental organization (NGO), industry and otherexpert reports and meeting/workshop proceedings.

8

3. Traceability
3.1. Definitions
Traceability is: “… the ability to trace the history, application and location of that which is underconsideration, and for products this can include the origin of materials and parts, the processing
history and the distribution and location of the product after delivery” (ISO, 2011). Traceability
systems provide for the storage and transfer of product information within and between actors in
a supply chain, enabling a product to be traced back along a supply chain, through any processesor transformations it may have undergone. As such, traceability systems provide a mechanism bywhich to verify the integrity of “chains of custody” (FAO, 2014), defined as “the chronology ofthe ownership, custody or location of product from the time it is obtained to the time it ispresented” (Expert Panel on Legal and Traceable Wild Fish Products, 2015).
Originally, the concept of traceability developed in response to food safety concerns, providing amechanism by which contaminated products could be traced back to source and isolated, andenabling the implementation of targeted withdrawals (Knuckey et al., 2014). More recently, withthe upsurge in controls over the origin of products, traceability systems have been used
increasingly to establish compliance with legality requirements (e.g. contained in the US Lacey
Act or the European Union’s Timber Regulation7) or sustainability standards (e.g. the Marine
Stewardship Council’s Fisheries Standard). In the context of the seafood industry, traceability
systems are included in measures to ensure the quality and safety of fish and fish products, andare used as a tool to demonstrate legality and origin from a sustainably managed fishery (FAO,
2012).

3.2. Traceability in the CITES context
CITES sets out conditions for international trade in specimens of species listed in its three
Appendices. The bulk of international trade in CITES specimens, is in Appendix II-listed
species. With an export permit, the exporting State declares that specimens were lawfullyacquired (legality), and that trade is not detrimental to the survival of the species in the wild(sustainability). Exporting States also need to ensure that living specimens are shipped so as tominimize the risk of injury, damage to health or cruel treatment8. International trade in species
listed in the Appendices to CITES operates by way of a system of permits and certificates.
Parties are also required to maintain records of international trade in listed species and submit
annual trade reports to the CITES Secretariat.
Traceability is central to the effective operation of CITES. In order to determine whether a
specimen has been legally acquired, a national CITES Management Authority (MA) will generally
require information about the origin of the specimen and any processing stages it may haveundergone. Traceability can also assist a Scientific Authority (SA) in the non-detriment finding(NDF) process, linking a specimen to its geographical origin so that the impact of international
trade on the wild population can be ascertained. An effective traceability system should therefore
assist national CITES authorities in assessing whether trade is within sustainable limits, on thebasis of which an export permit for international trade will be issued or refused.
Under the provisions of the Convention, traceability of trade from countries of (re-)export tocountries of import is maintained through (CITES Secretariat, 2013):
issuance of appropriate permits and certificates;

7 Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the obligations ofoperators who place timber and timber products on the market
8
CITES convention text Article IV.

9






submission of relevant permit trade data in national annual reports (published via theUNEP-WCMC CITES Trade Database);
identification/verification of transactions and specimens when entering/leaving countries;
compulsory marking of certain specimens in trade; andcollaboration between national CITES authorities and other agencies and enforcement
authorities.

The issuance of permits and certificates is the primary mechanism used by CITES to regulate andtrace international trade falling within the scope of the Convention. However, for certain species
listed in the CITES Appendices, additional measures (usually in the form of CoP resolutions9)
have been implemented to improve the traceability of parts and products in trade. These
measures are designed to facilitate identification of source/origin as well as trade monitoring andcontrol, and include:






the universal labelling requirements for sturgeon (order: Acipenseriformes) caviar, whichprescribes standardized labels for caviar containers in trade, whether for import, export, reexport of domestic trade - see CITES Resolution Conf. 12.7 (Rev. CoP16);
the universal tagging system for the identification of crocodilian skins and parts, which
recommends the use of non-reusable tags for all crocodilian skins entering international trade
and tagging of transparent containers containing crocodilian parts – see CITES Resolution
Conf. 11.12 (Rev. CoP15);
the recommended marking of whole elephant (Elephantidae spp.) tusks and cut pieces ofivory that are both 20 cm or more in length and one kilogramme or more in weight – see
CITES Resolution 10.10 (Rev. CoP16);
the recommended tagging of hunting trophies of leopard Panthera pardus and Markhor Capra
falconeri – see CITES Resolution Conf. 10.14 (Rev. CoP16) and CITES Resolution Conf. 10.15 (Rev.
CoP14), respectively.

In addition to these established systems, options are also being explored for enhancing
traceability of international trade in other CITES-listed taxa. At CITES CoP16, for example, it
was agreed that Queen Conch range States10 “should collaborate in exploring ways to enhance
the traceability of specimens in international trade, including, but not limited to, catch certificates,labelling systems and the application of genetic techniques” (CITES Decision 16.144). Thisdecision reflects the Recommendations of the October 2012 meeting of the Queen Conch
Working Group11 (QCWG, Panama City) on implementation of an auditable chain of custody
procedure so that catches can be traced back to their catch location (including through enhanced
catch documentation and CITES permitting procedures to track international trade), andresearch into practical technology to improve Queen Conch traceability, such as labelling,marking and DNA stock identification (Expert Workshop Recommendations 28b and c; see also
QCWG Workplan for 2015-201812 and an overview of progress as of mid 201513).
Recent developments in traceability solutions, including software, devices and technologies suchas forensics, have presented opportunities for improved tracking and identification of CITES
specimens in international trade. In 2012, a Workshop on Timber Marking and Tracking
9

Resolutions are agreements between the CITES Parties regarding the interpretation of the Convention or theapplication of its provisions. They include recommendations on how to interpret the provisions of the Convention andrules for controlling trade (such as issuing permits and marking specimens in trade). Resolutions are typically intended
to remain in effect for a long period (https://www.cites.org/eng/resources/terms/glossary.php#r).
10 A State whose territory is within the natural range of distribution of a species(https://www.cites.org/eng/resources/terms/glossary.php#r)
11 Of the Caribbean Fisheries Management Council (CFMC), the Central American Fisheries and Aquaculture
Organization (Organización del Sector Pesquero y Acuícola del Istmo Centroamericano – OSPESCA), the Western
Central Atlantic Fishery Commission (WECAFC) and the Caribbean Regional Fisheries Mechanism (CRFM).
12http://www.strombusgigas.com/qcgroup%202ndmeeting%20nov2014/20%20QCWG%20Work%20Plan%20TORs%20(Nov%202014).pdf
13 https://cites.org/sites/default/files/eng/com/ac/28/E-AC28-19.pdf

10Technologies was held within the framework of the ITTO-CITES joint timber programme and aCompendium on available timber tracking technologies was produced to support the efforts of
CITES Parties in making use of such technologies to more effectively implement CITES for
listed tree species and their products14. In addition, several CITES Parties have implemented orare piloting timber tracking systems for CITES-listed species, including under the ITTO-CITES
timber programme and in the context of Voluntary Partnership Agreement (VPA)
implementation/negotiations under the EU Forest Law Enforcement, Governance and Trade(FLEGT) Action Plan. These countries include Brazil, Cameroon, Democratic Republic of theCongo (DRC), Guatemala, Indonesia, Malaysia, Peru and the Republic of Congo.
In recognition of developments in tracking and species identification, the CITES Secretariat
reported on the formation of an internal task team to address various identification andtraceability issues at the joint meeting of the Animals and Plants Committees in May 2014
(AC27/PC21, Veracruz). The Secretariat also noted that a multidisciplinary approach would be
required in order to meet the objectives under the different CITES Decisions and Resolutions on
the identification of specimens of CITES-listed species (AC27/PC21 Doc. 1415). At AC28 in Tel
Aviv in 2015, following discussions of traceability relevant to snakes and reflecting on theconsideration of traceability for sharks, the committee recommended:“The Animals Committee invites the Standing Committee to consider the drafting of a decisionon traceability based on the different decisions related to traceability adopted at CoP16 with aview to increasing coherence, reducing duplication of effort and providing guidance to Parties
implementing traceability systems.”
Details of the Draft Decision which would establish a working group on traceability with termsof reference that include the drafting of a Resolution for consideration at CoP18 can be found in
Annex II of AC28 Com. 6 (Rev. by Sec.)16
A number of the measures/initiatives outlined in the section above have been selected forfurther discussion and analysis in Section 4 below.

14 http://cites.org/eng/news/sundry/2012/20120606_tracking_technologies.php
15 For mandate of intersessional working group, see: https://cites.org/sites/default/files/common/com/ac-pc/ac27-

pc21/sum/E-AC27-PC21-ExSum02%20.pdf
16 https://cites.org/sites/default/files/eng/com/ac/28/Com/E-AC28-Com-06-Rev.%20by%20Sec.pdf

11

4. Review of CITES traceability systems
Traceability systems for sturgeon caviar, crocodile skins, Queen Conch and timber are at various stages ofdevelopment and requirements have not been codified under CITES (e.g. through CoP Resolutions) in all cases.
Therefore, each of the four sections below follows a slightly different structure, as considered most appropriate topresent relevant requirements, issues, best practices and lessons learned for each case study.

4.1. Caviar
4.1.1. Overview of caviar trade
Caviar is the unfertilized roe of sturgeon and paddlefish of the order Acipenseriformes. There are
27 species of Acipenseriformes, divided into two families: Acipenseridae (sturgeon) andPolyondontidae (paddlefish). They occur in the coastal and inland waters of around 25 countries
in Europe, Asia and North America (Knapp et al., 2006).
All species of Acipenseriformes have been listed in the CITES Appendices since 1998. Of these,
two species, the Common or Baltic Sturgeon Acipenser sturio and the Shortnose Sturgeon Acipenser
brevirostrum are listed in Appendix I. The remaining species are listed in Appendix II. The CITES
listings cover all live specimens, as well as any readily recognizable parts and products derived
from these species (such as caviar, meat, leather, fertilized eggs, cartilage, etc.).
Caviar is a gourmet delicacy, and one of the most expensive fisheries products in the world. It is
traded under different names depending on the species. Beluga caviar, from the Beluga Huso huso,
is considered the finest quality and is most expensive. Other traditional varieties include osietra,
which comes from the Russian Sturgeon Acipenser gueldenstaedtii and Persian Sturgeon Acipenser
persicus; and sevruga, which comes from the Stellate Sturgeon Acipenser stellatus (Knapp et al.,2006). Caviar may be stored fresh, or may be pasteurized to extend its shelf-life (by up to two
years). However, all caviar is perishable and must be stored in cool temperatures at between –4ºand –2ºC (CITES Secretariat, 2001).
Over the past decade, countries bordering the Caspian Sea (Azerbaijan, Iran, Kazakhstan andRussia) have dominated global wild caviar exports (Knapp et al., 2006). Other important source
regions for wild caviar have included the Amur and Danube river basins, the Black Sea, the Seaof Azov and the Great Lakes of North America. However, in recent years, zero export quotas
have been established for caviar and meat derived from shared stocks of these species, as noexport quotas were submitted by the range states according to the provisions in CITES Resolution
Conf. 12.7 (Rev. CoP16)). This effectively means that no international trade in wild-sourced caviar
from shared stocks has been allowed, and legal supply has shifted to caviar produced fromaquaculture operations (Engler and Knapp, 2008).

4.1.2. Labelling requirements
Illegal trade in caviar has flourished over the years, perpetuated by high product values andrelatively low risks of detection (Knapp et al., 2006). In spite of zero export quotas, the illegal
fishing of wild sturgeons has continued to supply the caviar trade, posing a threat to populationsof these species (Jahrl, 2013).
A key difficulty for effective regulation of the caviar trade has been in distinguishing caviar fromillegal and legal sources. As a means of addressing this issue, and ensuring that all caviar entering
the market is from legal sources, the CITES Parties have established a caviar labelling andregistration system, to facilitate identification/tracing of source and origin.

12

The universal labelling system for the identification of caviar was established in April 2000 at
CoP11 through CITES Resolution Conf. 11.13. Initially, the system applied only to exports ofcaviar from countries of origin, due to complexities associated with the labelling of re-packaged
caviar in countries of re-export. All caviar containers over 250 grams were required to be labelled,
whether containing caviar sourced from the wild or aquaculture.
In the lead up to CoP12, the Animals Committee and its Working Group on the universal
labelling system agreed that, in order to be fully effective in combatting illegal trade, the labellingsystem also needed to cover re-exports of caviar (AC17 Summary Record). Inadequate controls
in domestic markets were also a concern (AC18 Doc. 15.2.). Therefore, in November 2002
(CoP12), the system was extended to require labelling of all caviar containers, including reexported and re-packaged caviar, whether destined for international trade or domestic markets.
The system has since been revised to further improve the traceability of caviar (in October 2004
at CITES CoP13; in June 2007 at CITES CoP14; and in March 2013 at CITES CoP16), and iscurrently set out in CITES Resolution Conf. 12.7 (Rev. CoP16). It applies to caviar from all sturgeon
species (including hybrids) of wild or farmed origin, and for commercial and non-commercial
purposes for both domestic and international trade. The main components of the universal
labelling system are described further below.

(a) Labels and information requirements
CITES Resolution Conf. 12.7 (Rev. CoP16) provides that all primary containers (i.e. tin, jar or otherreceptacle) into which caviar is packed directly, must be marked with a non-reusable label by theprocessing plant concerned. A non-reusable label is one that cannot be removed undamaged ortransferred to another container. It must either seal the primary container, or the caviar should bepackaged in a manner that permits visual evidence of any opening of the container.
The label must contain details regarding the source and country of origin of the caviar, using thecodes set out in the Resolution as follows:
1. Standard species code as provided in Annex 2 to the Resolution (e.g. “HUS” is thestandard species code for Beluga Sturgeon Huso huso)
2. Source code of the caviar (e.g. “W” for sturgeon harvested from the wild; “C” forcaptive-bred origin)17
3. ISO two-letter code for the country of origin;
4. Year of harvest;
5. Official registration code of the processing plant (see xxxx in example below, also under(b) Registration); and6. Lot identification number for the caviar (caviar tracking system used by the processingor (re-)packaging plant – see yyyy in example below), for instance:
HUS/W/RU/2000/xxxx/yyyy
See examples in Figures 1 and 2.

17 Aquaculture plants may use sturgeon specimens from the wild as well as specimens born or bred in captivity.

Therefore source codes C, F or W may apply (AC27 Doc. 21.3).

13

Figure 1: Example of a CITES label with CITES code

Source: Jahrl (2013)

Figure 2: Example of method used to enable visual evidence of opening of caviar
containers
Method used by one plant in Bulgaria to enable visual evidence of opening of caviar containers. The caviar ispackaged with a seal around the sides of the container and the CITES label includes flaps which also seal thecontainer. Opening of the container would result in tearing of the CITES label (Knapp, 2008)

Source: V. Georgiev, Management Authority of Bulgaria, May 2008 (in Knapp, 2008)14

Containers into which caviar is repackaged must also be affixed with a label that meets the above
criteria. Repackaging occurs where caviar is transferred into new primary containers18. Labels on
repackaged caviar should allow authorities to trace the origin of the caviar and therefore include:
1.
2.
3.
4.
5.

Standard species code;
Source code of the caviar;
ISO two-letter code of the country of origin;
Year of repackaging;
Official registration code of the repackaging plant, which incorporates the ISO twoletter code of the country of repackaging if different from the country of origin (see ITwwww in example below, also under (b) Registration); and6. Lot identification number, or CITES export permit or re-export certificate number (seezzzz in example below), for instance:
HUS/W/RU/2001/IT-wwww/zzzz
The same information that is on the label affixed to the container must be given on the export
permit or re-export certificate, or in an annex attached to the CITES permit or certificate. Parties
should not accept caviar shipments unless they are accompanied by relevant documents
containing this information.

(b) Registration
In support of the labelling system, CITES Resolution Conf. 12.7 (Rev. CoP16) recommends that
Parties establish a registration system for caviar processing and (re-)packaging plants, including
aquaculture operations. Parties should allocate unique registration codes to these plants, andprovide a list of facilities, and their official registration codes, to the Secretariat. This information
is distributed by the Secretariat via Notifications to the Parties, and included in a Register on the
CITES website (https://www.cites.org/eng/common/reg/ce/AR).

(c) Caviar trade database
The caviar trade database was established in 2007 and is managed by UNEP-WCMC. The
database records information relating to exports, re-exports and imports of caviar, helping Parties
to monitor the legal origin of caviar in international trade, check export quota compliance, track
shipments of caviar and identify any potential illegitimate use of CITES permits (UNEP-WCMC,
2008).
CITES Resolution Conf. 12.7 (Rev. CoP16) recommends that Parties submit copies of all export
permits and re-export certificates issued to authorize trade in caviar, no longer than one monthafter they have been issued, for inclusion in the caviar trade database. Parties are recommended
to consult the database prior to issuing a re-export certificate, in order to verify the origin of a
shipment for re-export. Specific uses of the database include:

linking permits electronically from countries of origin to subsequent re-export permits (and if
previously re-exported, to the re-export permit from a third Party), allowing consignments tobe tracked from the country of origin, via any other exporter, to the latest country of export;
andverification of quantities to be re-exported (to ensure the quantity to be re-exported by any
country does not exceed the quantity previously imported, as indicated on the previous (re)export permit) (UNEP-WCMC, 2008).

In contrast, a “secondary container” refers to a receptacle into which primary containers are placed: CITES
Resolution Conf. 12.7 (Rev. CoP16)1815

(d) Additional provisions
Caviar from different Acipenseriformes species should not be mixed into a primary container(except in the case of pressed caviar19). CITES Resolution Conf. 12.7 (Rev. CoP16) also recommends
that: “where available, Parties use the full eight-digit Customs code for caviar, instead of the lessprecise six-digit code (which includes roe from other fish species)”.

4.1.3. Implementation of the labelling system(a) Implementation
CITES Resolution Conf. 12.7 (Rev. CoP16) establishes universal standards for caviar labelling andthe registration of processing/repackaging facilities. However, the Resolution provides scope forParties to determine the exact type of labels used, and flexibility to establish systems for tracking
and monitoring of trade. This section provides some examples of how the guidelines have beeninterpreted and implemented at the national level.
Security features, design and positioning of labels: CITES caviar labels may include a variety of
security features, including holograms, unique security numbers, security prints, security
cuttings (to ensure damage to the label in case of opening), and thermal transfer printing(Knapp, 2008; Scales et al., 2010). Some Parties may require labels to seal the caviar
container; in others, different mechanisms may be used (e.g. individual packaging of tins innets and closed using metal seals) (Scales et al., 2010). Security features/mechanisms may be
used individually or in combination, and are not necessarily prescribed in national legislation.

Issuance of labels: CITES caviar labels may be produced centrally (e.g. by the CITES MA orState printing company) and issued to traders, or the CITES MA may approve a number ofdifferent labels for use. In other cases, traders may issue their own labels provided they arelicensed, registered or otherwise authorized by the CITES MA (Jahrl, 2013).



Record-keeping requirements: some Parties have implemented requirements for caviar
processing/(re-)packaging facilities to maintain records of caviar imported, exported,
produced or stored etc., which must be available for inspection by authorities (e.g. the EU in
Article 66(7) of Commission Regulation (EC) No 865/2006). This provides an essential tool forverification of legal origin, allowing authorities to trace caviar back to the point of
production.



Allocation of processing plant and lot identification numbers: In the early stages of implementing theguidelines, there were differences in how processing plant and lot identification numbers
were applied by Parties (e.g. in some cases, to exporting companies and procedures only; inother cases, already during the prior processing phase). The Secretariat provided clarificationon the issue in AC17 Inf. 9, namely that processing plant and lot identification numbers
should take account of the production process and not simply the identification of caviar
submitted for export and international trade. This would help to confirm that the caviar is oflegal origin by linking directly to the production process.
Monitoring and enforcement of requirements: a number of approaches have been used to monitor
and enforce the labelling system, and ensure the legal origin of labelled caviar. Monitoringand enforcement approaches have included: (i) the provision of information materials andtraining to enforcement authorities; (ii) consultations with processing/(re-)packaging plants
to inform them of CITES labelling requirements; (iii) inspections of caviar processing and

19 Caviar composed of unfertilized eggs (roe) of one or more sturgeon or paddlefish species, remaining after theprocessing and preparation of higher quality caviar - CITES Resolution Conf. 12.7 (Rev. CoP16).

16

(re-)packaging plants and verification of production records; and (iv) testing of samples using
DNA and isotope analysis (Knapp, 2008; Kecse-Nagy, 2011).

(b) Issues
A number of issues have been encountered during implementation of the caviar labelling system,
which may potentially undermine its effectiveness in regulating caviar trade. These aresummarized below:
Regulatory frameworkDifficulties associated with verifying the authenticity of labels. Caviar labels are extremely diverse indesign and quality (including the positioning of the CITES code), causing difficulties for
authorities when attempting to verify the authenticity of labels during inspections/controls(Knapp, 2008; J. Jahrl, WWF Austria, in litt., 2015).



Lack of control over the production of labels. Where the production or issuance of labels is notcentralized, this may result in the use of labels with inadequate security features, or ofotherwise poor quality/design, facilitating misuse and fraud (see below).

Compliance and enforcementInadequate security features, design or positioning of labels. Often the security features, design or
positioning of labels do not meet the requirements of the Resolution (i.e. that labels are nonreusable, and either seal the container or allow visual evidence of any opening or tampering).
For example:o Labels lacking security features and of poor quality, meaning that fraudulent labels canbe easily produced and authorities, retailers and consumers are unable to distinguishfraudulent from valid labels (J. Jahrl, WWF Austria, in litt., 2015).
o Design of label inadequate to prevent reuse, e.g. label can be removed undamaged (J.
Jahrl, WWF Austria, in litt., 2015).
o Insufficient mechanisms to prevent tampering with contents, e.g. codes printed on thelids of containers, making it impossible to determine whether the container has been
(illegally) opened and refilled (Knapp, 2008; Kecse-Nagy, 2011).

Forged/counterfeit CITES labels in circulation. Investigations in the EU have, for example,
detected smuggling of caviar and use of forged CITES labels and falsified or duplicate
CITES documents in order to commercialize illegally sourced products within the EU(Knapp et al., 2006; Kecse-Nagy, 2011).

Information requirements for labels not met. This may include incomplete codes, lack of sourcecode (e.g. W or C) or codes referring to exporting companies rather than processing plants(see under (a) Implementation above) (J. Jahrl, WWF Austria, in litt., 2015; Scales et al.,2010). In some cases, the code is difficult to read or locate (e.g. printed in very small or poor
quality print, or included as part of a block of text), or becomes unreadable when exposed towater and therefore easily falsified (J. Jahrl, WWF Austria, in litt., 2015).



Mislabelling of caviar. Caviar mislabelling has been detected through application of DNA
testing to samples available for purchase (e.g. Doukakis et al., 2012; Jahrl, 2013). Examples
include tins containing caviar from a mixture of different sturgeon species (in contraventionof the CITES Resolution), or containing caviar from a species other than the species
identified on the label (Jahrl, 2013; Knapp et al., 2006). Research has found that illegal fishingof sturgeons is an ongoing and substantial problem in some range States and that caviar fromwild-caught sturgeons may be “laundered” to appear legal through labelling as farmed caviar

17

(Jahrl, 2013; Kecse-Nagy, 2011). A key issue is determining at what point in the supply chain
mislabelling occurred.


Other contraventions of the labelling requirements. These include inconsistencies between
information on labels and permits/certificates (Knapp, 2008), or caviar sold without CITES
labels, for example, in glass jars or plastic tubs to avoid detection (Jahrl, 2013; G. Clarke, UK
Border Force, pers. comm., 2015)

Registration and licensing
Issues with information contained in the CITES Register of caviar facilities/plants. Although recognized
as a useful resource for CITES authorities, there is evidence to suggest that information on
caviar facilities/plants in the CITES Register may be out of date, incomplete or inaccurate(Jahrl, 2013). A number of improvements have also been proposed; for example, theinclusion of information on the species of sturgeon used by each aquaculture facility and thesource of the caviar produced, to assist in determining legality/detecting instances of fraud
particularly if international trade in wild sturgeons re-commences (AC27 Doc. 21.3; A.
Petrossian, Petrossian, pers. comm, 2015). It has also been suggested that registration
numbers of caviar processing and re-packaging plants should show whether the plant isprocessing or only re-packaging, due to significant differences in production methods used
(AC27 Doc. 21.3).

Issues associated with registration of caviar facilities/plants. For example, the involvement of
unregistered or unlicensed companies in producing, processing, (re-)packaging and/or
exporting caviar (Jahrl, 2013; Scales et al., 2010).

Traceability/other

Loss of traceability/break in chain of custody as a result of re-packaging of caviar. Concerns have beenraised regarding the re-packaging process and loss of traceability during this stage. Repackaging can also make it difficult to detect at which point in the supply chain mislabelling
may have occurred (J. Jahrl, WWF Austria, in litt., 2015).

 Difficulties of tracking caviar permit information. Tracking of CITES permits for caviar can bechallenging due to complex and unpredictable trade routes (UNEP-WCMC, 2008).
Furthermore, the effectiveness of the UNEP-WCMC caviar trade database may becompromised by cancelled and unused permits, which cause trade to be over-estimated, as
well as a lack of reporting, delays in reporting and inconsistencies in the terms/units used
(UNEP-WCMC, 2008). In addition, while Parties are recommended to consult the databaseprior to issuing a re-export certificate, it is unclear whether this happens on a routine basis.20


Other issues. These include the continued lack of knowledge of the caviar labelling systemamong retailers, consumers and enforcement agencies; a lack of implementation of thesystem in key domestic markets (J. Jahrl, WWF Austria, in litt., 2015); administrative burden(UK CITES MA, in litt., 2015); and lack of staff/financial means for controls (Hubenova etal., 2009).

It is noted that the requirement for Parties “to supply to UNEP-WCMC copies of all export permits and re-export
certificates issued to authorize trade in caviar, no longer than one month after they have been issued, for inclusion in
the UNEP-WCMC caviar trade database” is currently under review, as it is unclear whether the database is stillneeded/useful – see SC65 Doc. 24.2 Annex 1.
20

18

4.1.4. Lessons learned
The universal caviar labelling and registration requirements have made an important contribution
to improving the traceability of caviar in trade and facilitating enforcement of CITES provisions.
A key strength of the system is the application of unique and globally standardized serial
identification numbers to all containers of caviar, regardless of size, source and origin. This iscombined with the registration of processing and re-packaging plants and through making theseunique registration numbers publically available, this enables authorities, traders and eveninformed consumers to check which plant produced or re-packaged the caviar concerned(German CITES MA, in litt., 2015).
However, as outlined in Section 4.1.3. above, a number of issues appear to compromise theimplementation and effectiveness of the system. These relate to the design and application oflabels, the implementation of registration/licensing requirements, and the oversight andverification of the system, including inspections and controls. This section considers examples of
how the system could be strengthened and best practices, which provide lessons learned for
implementation of other similar systems (see also the examples in Boxes 1 and 2).
To facilitate enforcement controls and reduce the potential for fraud, it has been suggested thatlabels should be standardized and quality security features (such as holograms) should be
required. Centralizing the production and issuance of labels with CITES MAs or State printing
companies could further address issues of forgery/counterfeit labels, as already implemented in a
number CITES Parties (Jahrl, 2013).
Accurate, up to date and detailed book-keeping systems are essential to allow for the tracing ofcaviar along the entire chain of custody in order to confirm legality (Knapp et al., 2006). This isparticularly important where re-packaging makes tracing the origin and source of caviar moredifficult, opening up the potential for fraud (Knapp et al., 2006). In Germany, for example, astringent book-keeping system is established in every plant that applies for a registration number,which must provide information about the caviar processed or re-packaged in the plant,
including species, source codes, quantity, legality, origin and any existing CITES documents, inthe case of importation. In particular, the system must ensure that the quantities of outgoing andincoming caviar are equal, and that no illegal quantities can enter the plant and be legalized(German CITES MA, in litt., 2015).
In addition to strict book-keeping requirements, the robustness of the labelling system depends
on regular monitoring and verification of trade records by enforcement authorities, and theregular inspection of facilities/plants (Knapp et al., 2006). Controls using various laboratory
techniques can also assist in the effective monitoring of caviar trade and enforcement ofregulations, including verifying that species and origin are consistent with information on CITES
labels, and preventing the mixing of caviar from various species21 (Jahrl, 2013; Doukakis et al.,2012; FAO, 2010).

21 For an overview of current challenges relating to the Identification of sturgeons and paddlefish specimens in trade, see

https://cites.org/sites/default/files/eng/com/ac/28/Inf/E-AC28-Inf-18.pdf.

19

Box 1: Example of national systems for regulation of caviar trade

Romanian database of sturgeon captures
To control illegal fishing and trade in sturgeon, the Romanian Ministry of Agriculture issued theMinisterial Ordinance No. 350/Oct. 2001 introducing the compulsory tagging and reporting
within 48 hours of every legally captured and landed specimen of sturgeon.
To make the process of issuing CITES permits for the export of products derived fromsturgeons transparent to the public and national/international authorities, on 3 July 2003, the
CITES MA and SA of Romania launched their web page “Sturgeons of Romania and CITES”.
Since September 2003*, all CITES export permits were issued by the CITES MA only for caviar
specimens reported and posted on the web page in the database of captures. The database of
captures was regularly used by the Romanian Customs Service to check the validity of CITES
permits and labelling of caviar exported.
*Note: In 2006, Romania suspended fishing of sturgeons for 10 years (Jahrl, 2013)
Source: Presentation by the Romanian CITES Scientific Authority for Sturgeons (in Knapp et al.,2006)

Box 2: Example of national systems for regulation of caviar trade

Iranian traceability system for sturgeons
In the Islamic Republic of Iran, control of the whole cycle of sturgeon and caviar utilization,
processing and production of different products, trading and research is carried out through the
Iranian Fisheries Organization (IFO).
A traceability system controls all activities related to sturgeon. Necessary information about
each fish is recorded in digital format and distributed via a special network. A lithographic code
number relating to the processing station and the type and grade of caviar is printed on thecans*. Documentation is also provided which meets the requirements of CITES, the European
Union, Customs and other national level standards. Together, these measures allow for all
caviar cans to be traced back to their source after any period of time.
In addition, a monitoring system has been established to control markets and gather
information about the quantity of illegal catch. Fishery guards control the sea, shore lines, roads
and markets, and have the authority to arrest shop keepers and close shops if illegal sturgeonsor sturgeon products are found. In 2008, the guards made 28 000 inspections, seized 1948 kg
sturgeon and 28.6 kg caviar, and thousands of immature and undersized sturgeons (caught asby-catch) were released back into the sea. In addition, around 320 juridical cases were filed andthe perpetrators brought to court. Fines were imposed and fishing gears and vessels wereconfiscated.
*Note: The labels used are non-reusable and attempts to remove the label will damage it. Tins are also enclosed
in netting with a seal which matches the label and will split if tampered with (Engler and Knapp, 2008).
Source: Presentation by Iran at the FAO and CITES Technical Workshop on Combating Illegal
Sturgeon Fishing and Trade (Antalya, Turkey, 28–30 September 2009) (in FAO, 2010)

20

21

4.2. Crocodile skins
4.2.1. Supply chains
All species of Crocodylia (alligators, caimans and crocodiles) are listed in either Appendix I or
Appendix II of CITES. Over the past few decades, ranching and captive-breeding operations
have come to dominate the production of crocodilian skins for international trade, with acorresponding decline in the proportion of skins supplied from wild-harvesting (Macgregor,
2002; Macgregor, 2006).
Skins are produced from wild-harvesting, ranching or captive-breeding, and producers sell skins
to intermediaries, tanneries or exporters. Tanning is a crucial stage in the supply chain(processing of dried skins to produce leather), traditionally carried out in France and Italy,
although has more recently developed in other countries including the US, Mexico, Colombia,
Italy, South Korea and Japan (Macgregor, 2006). Manufacturing has also diversified anddeveloped technologically, with manufacturers increasingly found in range States and operating
on a larger scale (Macgregor, 2006). Crocodilian leather products are not limited to the luxury
sector, but available globally at a range of prices in a wide range of markets, which are continually
diversifying, changing emphasis and possibly also expanding (Macgregor, 2006).
The number of tanneries, despite having increased in recent years, is relatively small compared to
the number of other entities in the chain, such as exporters and manufacturers (Macgregor,
2002). This provides what has been termed a “Tannery Bottleneck” (Ashley, 2013), which, it has
been suggested makes for relatively easy control of the vast bulk of trade (Hutton and Webb,
2002).

4.2.2. Elements of the CITES crocodilian skin tagging system
The universal system for the tagging of crocodile skins was first introduced in 1992 through
CITES Resolution Conf. 8.14 in response to concerns regarding the resurgence of illegal trade incrocodilian skins and difficulties associated with identifying and monitoring skins in trade(IUCN, 2002; CoP8 Doc. 8.26). The system has since been revised to take into accountexperiences of the various implementing countries (at CoP9 and CoP11; IUCN, 2002) and iscurrently implemented through CITES Resolution Conf. 11.12 (Rev. CoP15). The system applies
only to raw, tanned and finished skins. Finished products, such as handbags, belts and shoes, arenot covered.

(a) Tagging requirements
CITES Resolution Conf. 11.12 (Rev. CoP15) recommends that all raw, tanned and/or finishedcrocodilian skins, flanks and chalecos22, be tagged individually before entering international tradefrom their countries of origin, using non-reusable tags. The non-reusable tags are to include, as aminimum: (i) the ISO two-letter code for the country of origin; (ii) a unique serial identification
number; (iii) a standard species code; and (iv) where appropriate, the year of skin production or
harvest. The tags must also have, as a minimum, the following characteristics: (i) a tamperresistant, self-locking mechanism; (ii) heat resistance; (iii) inertia to chemical and mechanicalprocessing; and (iv) alphanumeric information, which may include bar-coding, applied bypermanent stamping. The Resolution recommends that tails, throats, feet, backstrips and otherparts should be exported in transparent, sealed containers, clearly marked with a non-reusable tagor label, together with a description of the content and total weight (in addition to theinformation required above).
Specific provisions apply to re-exports of raw, tanned and/or finished skins. Parties re-exporting
such items are recommended to ensure that they are re-exported with original tags intact (unless
22 The lateral sides of the belly portion of the skin (flanks) sometimes joined as a “waistcoat” cut (chaleco).

22the pieces originally imported have been further processed and cut into smaller pieces). Where
original tags have been lost, damaged, or removed from raw, tanned, and/or finished skins,
flanks and chalecos, the country of re-export should tag such items prior to re-export with a “reexport tag”. Re-export tags should meet the requirements mentioned above, except that countryof origin, standard species code and years of skin production and/or harvest need not be
included.

(b) Monitoring and control of trade
According to CITES Resolution Conf. 11.12 (Rev. CoP15), Parties should accept export permits or
re-export certificates for the international trade in crocodilian skins, only if they contain therelevant tag information noted above and if the related skins and parts are tagged in accordancewith the provisions of the Resolution. In the case of re-exports, details of the original permit
under which the skins, flanks and chalecos were imported should also be included in the reexport certificate. Parties involved in the re-export of raw, tanned and/or finished skins arerecommended to implement an administrative system for the effective matching of imports andre-exports.
CITES Resolution Conf. 11.12 (Rev. CoP15) recommends that Parties establish, where legallypossible, a system of registration or licensing (or both) for producers, tanners, importers andexporters of crocodilian skins. Parties are also recommended to implement a management andtracing system for tags used in trade, the details of which are set out in Annex 2 to the
Resolution. As part of such a system:







The Secretariat regularly publishes a list of approved manufacturers capable ofmanufacturing tags that meet the minimum requirements of the Resolution (currently
contained in CITES Notification 2013/029), and Parties are recommended to only obtaintags from these approved sources.
When issuing export permits or re-export certificates for crocodilian skins, Parties should
record the numbers of tags associated with each document and make this information
available to the Secretariat on request.
Management Authorities of exporting, re-exporting and importing Parties should provide to
the Secretariat (when directed by the Standing Committee or agreed between the range Stateand the CITES Secretariat), copies of CITES documents issued for crocodilian skins, flanks
or chalecos, immediately after issuance or receipt (as appropriate).
Parties that require or intend to require the use of tags or labels for containers should send at
least one sample tag or label for reference to the Secretariat.

4.2.3. Implementation and effectiveness of the crocodilian skin tagging system
While recognized as an important and successful tool for the monitoring and regulation of
crocodilian skin trade, at CoP14 (Hague, 2007) the Parties agreed on a Decision23 to review the
implementation and effectiveness of the universal tagging system (contained then in CITES
Resolution 11.12 (Rev. CoP14)), in order to determine whether any improvements or streamliningof the Resolution were necessary to better contribute to the objectives of the Convention (see
CoP14 Doc. 43 & 46; AC24 Doc.11).
23 14.62 The Standing Committee shall, at its 57th meeting, initiate a process to review the implementation and effectiveness oftheuniversal tagging system [...], including [its[ impact on the effectiveness of the Convention. For that purpose, it shall establish a working
group with representatives from exporting and importing countries, the Animals Committee, the Secretariat and other interested parties.
The tasks of the working group, which might work electronically, shall be:a) to examine the implementation and effectiveness of the universal tagging system;b) […]c) […]d) to report to the Standing Committee on the results of its work at its 58th meeting.
14.63 The Standing Committee shall, at its 58th meeting, consider the report of the working group established under Decision 14.62 andshall submit recommendations, as appropriate, to the Conference of the Parties for consideration at its 15th meeting.

23

At the 57th meeting of the Standing Committee (SC57), a Working Group was establishedcomprising representatives from Parties, NGOs, private sector companies (with experience in tag
production and tag application through different processing stages), inter-governmentalorganizations (IGOs) such as IUCN, a representative of the Animals Committee and the CITES
Secretariat. The Working Group agreed to compile and assess the experiences of CITES Parties
in using the uniform tagging system to regulate large numbers of enterprises engaged incrocodilian skin production and related activities (e.g. tanners, skin traders and other industry
groups) and, in particular, how Parties had developed procedures to streamline and facilitate
compliance with the provisions of Resolution Conf. 11.12. A questionnaire was drafted anddistributed to major crocodilian importing and exporting countries, industry representatives andIGOs/NGOs, to which 13 responses were received (CITES authorities of Bolivia, Bulgaria,
Colombia, France, Germany, Mexico, Singapore, Switzerland, Thailand, US and Zambia, also H
Trading Co. (Japan) and Ashley Associates (US alligator industry)).
The key findings derived from the questionnaires, and compilation of individual responses, were
submitted to the Standing Committee for consideration at its 58th meeting in July 2009 (SC58Doc. 27). Overall, the review found widespread support among Working Group members forthe continued use of a tagging system as a means of ensuring a legal and sustainable trade incrocodilian skins (SC58 Summary Record). However, a number of recommendations were
proposed to align the system with developments in knowledge of crocodilian taxonomy,conservation and trade practice, and to streamline the system while maintaining a robust andsecure trade control regime (SC58 Summary Record) (see under (d) Effectiveness below).
An overview of implementation and effectiveness of the crocodilian skin tagging system, basedon the 2009 review, is provided below. Where indicated, information from 2009 is supplemented
by updated information from relevant literature and provided by selected CITES authorities andexperts to TRAFFIC for purposes of the present report.

(a) General
The Resolution is implemented widely, but only partially in some Parties (e.g. for imported skins,
but not for re-exports). Implementation is generally overseen by CITES MAs, although
responsibility may be shared with trade associations (e.g. with regard to the purchase, recording
and issuance of tags to members) and administration of tagging requirements/systems may takeplace at sub-national level (Australian CITES MA, in litt., 2015; US Fish and Wildlife Service(FWS), in litt., 2015). In at least one Party, difficulties have been caused by the use of tags forexport but not for harvest and internal movement of skins, which hinders determination oflegality and sustainability of skins for export.
The administrative burden for companies, CITES MAs and enforcement agencies has beenreported as an issue (French CITES MA, in litt., 2015), although may be considered acceptable inview of improvements in traceability and legality of skins (Italian CITES Enforcement Agency(EA), in litt., 2015; US FWS, in litt., 2015). In addition, computerization has reduced theadministrative burden of managing tagging data for relevant authorities (German CITES MA, inlitt., 2015), with some Parties switching to bar codes which can further assist data management.

(b) Tagging requirements
Information on tags
Tags in use in CITES Parties generally contain the minimum information set out in the
Resolution, applied by permanent stamping, although the information sequence is not always
precisely followed.
Physical characteristics of tags

24

Crocodilian skins are tagged using loop or button style tags (Ashley, 2013). In terms of security
characteristics, tags are mostly self-locking and designed to prevent reuse, however, cases ofmanipulation and re-use of tags have occurred where security features were insufficient toprevent misuse. It is thought that this may be occurring less often as more secure tags become
available, for example, the tag used in Colombia which requires a special tool to be affixed to theskin (German CITES MA, in litt., 2015). For examples of tags in use, see Ashley (2013):
http://unctad.org/en/PublicationsLibrary/ditcted2013d6_en.pdf.
Problems may occur during processing (tanning), where tags are not resistant tomechanical/chemical processes and become detached from skins, damaged or destroyed; or thenature of the process requires the systematic removal of the original tags (French CITES MA, inlitt., 2015; Australian CITES MA in litt., 2015). It has been suggested that the removal of tags
before tanning (and subsequent replacement with an export tag) leaves scope for abuse, inparticular to launder illegal skins through tanneries (AC24 Doc. 11; AC27 Doc 19.4 Annex 1).
Some tags have been developed to withstand the skin tanning processes (e.g. loop style tags madeof nylon-based material with laser-etched bar code, used to mark American Alligator skins)(Ashley, 2013).
Reproduction of counterfeit tags has also been reported (Italian CITES EA, in litt., 2015);
however the list of CITES approved tag manufacturing companies and reporting of tag numbers
used should assist in addressing this issue (Ashley, 2013).
Tagging of re-exports
In the 2009 review, most respondents indicated that, in cases where the original tag is lost or
removed, a re-export tag meeting all requirements of the Resolution is used.
Use of technology
There is interest among CITES Parties and industry stakeholders in the use of innovativetechnologies, such as bar coding on tags, to reduce fraud and administrative burden associatedwith implementing the tagging system (French CITES MA in litt., 2015; Australian CITES MA inlitt., 2015). Some Parties, such as the US, have already incorporated such systems into their tags
(Ashley, 2013); however, some problems with bar coding have been encountered (e.g. technicalissues associated with the tanning process impacting readability of the coding) (Australian CITES
MA, in litt., 2015).
In Australia, there is continued interest amongst the Australian crocodile industry to implement
bar coding to facilitate data transfer from the tag to a database. The Australian CITES MA iscurrently investigating new technologies that might address problems encountered previously,
thereby enabling application of bar coding and introduction of automated processes by industry
and/or State/territory governments (Australian CITES MA in litt., 2015).

(c) Monitoring and control of trade
Registration/licensing
Registration and/or licensing of producers, tanners, importers and exporters is not required in all
CITES Parties. Some countries do not implement this requirement, while others only requireregistration or licensing of crocodile farms, or importers/exporters. Registration/licensing may
be undertaken at the sub-national (e.g. State, territory) level (Australian CITES MA, in litt., 2015).
Tag manufacture and issuanceCompanies may obtain tags directly from licensed/registered manufacturers (or possibly via adesignated trade association). In some CITES Parties, the CITES MA oversees tag orders,issuance, distribution and possibly also the tagging itself (see below). Although provided for in
Annex 2 to the Resolution, no respondent in the 2009 review reported requesting that the
Secretariat purchase and distribute tags on their behalf. CITES MAs may also maintain recordsof tags issued.
25

Examples of systems currently in use include:








Australia: the Australian CITES MA purchases crocodile tags and distributes them torelevant State/territory governments for issuance to individual operators/exporters andkeeps a national record. State/territory governments are responsible for maintaining recordsof tags, including replacement tags, issued to individual operators/exporters (Australian
CITES MA, in litt., 2015).
For re-tagging of skins for re-export, where tags have been removed or lost (e.g. during processing):
France: orders for replacement tags are submitted by companies to the Centre Technique duCuir (CTC). CTC then prepares a bulk order specifying tag numbers corresponding to eachcompany and submits this for endorsement by the national CITES MA. The national MA
keeps a copy of all CTC tag orders, which relate tag numbers to the companies. Once a year,
the CTC provides the national CITES MA with an overview of all tags that have been sent
to companies (French CITES MA, in litt., 2015).
Germany: the owner of the skins orders and pays for any replacement tags and these are sentby the tag manufacturing company directly to the Government authority, which undertakes
the re-tagging. Depending on the amount of skins, re-tagging is either directly undertaken by
a Government authority, or is supervised and checked during the re-tagging process.
(German CITES MA, in litt., 2015).
Italy: replacement tags must be requested by companies from the CITES Enforcement
Agency, Corpo Forestale Dello Stato, which provides tags and maintains a register of all tags
provided to companies at the local level (Italian CITES EA, in litt., 2015).

Recording of tag numbers on export/re-export documents
The recording of tag numbers associated with export permits/re-export certificates appears to be
implemented in most, if not all, CITES Parties. Some Parties make use of electronic permitting
systems to store information on permits, including details of tags, which can provide for rapid
retrieval of information on permits and associated tags (French CITES MA, in litt., 2015; German
CITES MA, in litt., 2015).
Administrative systems to match imports and re-exports
In the 2009 review, most respondents reported implementing an administrative system to match
imports and re-exports. Examples of systems currently in use include:France: companies that have carried out re-tagging of skins must update a Register to include
details of the import permit, the old and new tag numbers, and the date of re-tagging. The
effective matching of imports and re-exports is verified by enforcement officers during
random inspections, and by the CITES MA when processing applications for re-export
certificates (French CITES MA, in litt., 2015).
Germany: where tags have been removed, the owner must provide proof of legal origin to
the relevant CITES authority, including the source of the skins (imported or purchased
within the EU). Proof could include invoices, copies of CITES import documents or theoriginal tags which were removed during processing. A government certified expert in skinidentification could also be asked to verify the species of the skins or the age of the skins
before a re-export certificate is issued (German CITES MA, in litt., 2015).
Italy: companies are obliged to maintain a Register of skins that have been received, sold andtransformed. Fiscal documentation must be integrated with a declaration of the origin of theskin and details of the relevant import permit (Italian CITES EA, in litt., 2015).

(d) Effectiveness

26

GeneralAll respondents in the 2009 review regarded the universal crocodilian skin tagging system as
either very necessary or somewhat necessary for the effective control of trade in crocodilian skins(see also Box 3: US case study). Examples of blatant abuses of the system have been reported (e.g.
shipments of skins with tags unattached, multiple skins on a tag), but this appears to be theexception rather than the rule (G. Webb, IUCN CSG, in litt., 2015). In the 2009 review, no
respondent reported more than 25 commercial shipments with CITES violations (including
Colombia and the US, which each reported using more than 500 000 tags annually), with mostreporting 0–10 cases (data for 2007).
Following the 2009 review, a number of changes were made to the Resolution with a view tostreamlining the tagging system and reducing the administrative burden on authorities. These
included removing the requirement for tag manufacturers and CITES MAs to report tag orders
to the Secretariat (previously contained in Annex 2), and reducing the tagging requirement for
chalecos to a single tag24 due to little or no fraud associated with this commodity over the years(SC58 Doc. 27; AC24 Doc.11).
Costs
Four respondents in the 2009 review reported using 20 0001–50 000 tags annually; one reported
100 001–500 000; and two reported using over 500 000 tags. Costs of tags vary and unit costs
decline with increasing volumes ordered. Crocodilian loop tags in Indonesia cost US$0.30 eachfor relatively small quantities (ca. 5000 units); alligator loop tags (with bar codes) used inLouisiana in large quantities (> 300 000 per year) cost US$0.17 per tag (Ashley, 2013).
Costs associated with administering the system exceeded US$75 000 annually in two Parties.
Some Parties recovered the costs of the tagging programme from the private sector (cost of tags).
Strengths
As mentioned above, the tagging system is widely recognized as an effective mechanism forcurtailing the illegal trade in crocodilian skins. Some strengths of the system have been cited as:






Improved assurance of origin and legality of skins in trade (Australian CITES MA, in litt.,
2015; Italian EA, in litt., 2015; US FWS, in litt., 2015).
Establishment of universal standards for tagging of crocodilian skins, but with sufficient
flexibility as to their implementation (German CITES MA, in litt., 2015; US FWS, in litt.,
2015).
Provision of an index of volumes produced in source countries, which can be confirmed byimport statistics for importing countries (G. Webb, IUCN CSG, in litt., 2015).
Potential for integration with CITES electronic permit systems, and incorporation of newtechnologies onto tags.
Requirements for tags to remain on skins during processing (and, if lost, for re-tagging to beundertaken if skins are re-exported), and also for the tagging of smaller parts of skins, which
help to control illegal trade25.

24 Previously, each flank (side) of the chaleco was required to be tagged.

25 Although some problems in implementing these provisions remain (German CITES MA, in litt., 2015)27

Box 3: US case study
The US Fish and Wildlife Service (US FWS) has made legal acquisition and non-detrimentfindings (NDFs) on a State-by-State basis, as a way to address the large-scale export ofAmerican Alligator Alligator mississippiensis skins. States are required to report annually on
applicable laws and regulations and mandatory tagging is based on US FWS approval of eachState’s management and legal regime. Tagging by approved States is considered to provide
sufficient evidence of legal acquisition, and US FWS can refuse to provide tags to States that
do not comply with the implementation requirements.
Properly tagged specimens accompanied by a Service 3-177 Declaration for export and a US
FWS import/export licence, are routinely granted CITES export permits at designated US
ports. Tags are an indication that legal acquisition and NDFs have been made and theprocess provides a uniform approach to presentation of American Alligator skins at ports.
In the US, the tagging regime is augmented by enforcement regimes at the national and local
level, such as State wildlife agency regimes to ensure lawful harvest or production. Shipment
declarations and presentation of specimens for inspections allow authorities to ensure thattags are legitimate and match the documentation association with the specimens.
The past three decades of implementing the tagging of American Alligator skins havedemonstrated that the system is effective, and has contributed not only to improved
implementation of CITES but also to the recovery of the American Alligator.
Source: US FWS, in litt. (2015)
Limitations
Nevertheless, a number of limitations/weaknesses of the system have been identified: Administrative burden and costs for stakeholders.
 Scope for fraud or abuse of the system, for example, resulting from or associated with:o the removal or loss of tags during processing;o insufficient security mechanisms on tags;o ease of reproducing counterfeit tags;
o insufficient verification of tagging/oversight by authorities;o use of tags from previous years.
 Difficulties of selecting tag types that can withstand the tanning process, do not damage
skins, are practical and do not fail, and include all necessary information required by CITES.
 Partial implementation of the system (e.g. tagging requirements for imports but not reexports; registration/licensing provisions not implemented).
 Uncertainty in the application of the tagging requirements in certain production steps (e.g.
where skins are cut transversely into two or three parts, but sent together).26
 Issues associated with information requirements on tags and loss of traceability (e.g. lack ofrequirement to keep original information about the country of origin, species code, year ofskin production or harvest on replacement tags).
Suggested improvements
In order to improve the system further, it has been suggested that the application of electronic
identification technologies to tags, such as bar coding, should be explored, which could bedirectly linked to relevant databases for automated transfer of data (SC58 Doc.27; AC27 Doc.
26 It is unclear whether this practice is legitimate (i.e. part of the organization of work in the production chain), or acircumvention of requirements (French CITES MA, in litt., 2015).

28

19.4 Annex). Combined with electronic management systems to assess and store data on tags,
this could improve the accuracy and handling of skins, while reducing fraud and administrative
burden. Bar coding is already employed by some Parties, and this possibility has been included in
Resolution Conf. 11.12 (paragraph c) since CoP15. The introduction of a database that catalogues
all tags issued and is publically accessible could also reduce the possibility of misuse (Italian
CITES EA, in litt., 2015; see also AC27 Doc. 19.4 Annex).

4.2.4. Lessons learned
Experience of implementing the universal tagging system for the identification of crocodilian
skins has highlighted the importance of ensuring tagging systems are simple, easy to apply, andleave sufficient scope and flexibility for Parties to determine how they should be implemented(AC14 Summary Record; German CITES MA, in litt., 2015; US FWS, in litt., 2015). Affording
Parties and industry flexibility in the types of tags/technology to be used can help to drive
technological improvements to cope with challenges as they arise.
Tagging systems are associated with significant administrative and cost burdens for Parties, which
are not always recouped from industry. Administrative burdens may, however, decline as
developments in technology, such as electronic data capture and management systems, become
more widely available and cost-effective. Systems should be sufficiently flexible to allow forincorporation of technological developments, if considered appropriate/practicable for the
implementing countries.
As is true for all tagging and traceability systems, the universal tagging system is only as strong as
the legal/regulatory regimes and monitoring systems in place (US FWS, in litt., 2015) and cannot
overcome issues of weak governance (Ashley, 2013). Regardless of the type of tagging system
implemented, assurance of legal acquisition is largely dependent on self-reporting by the
producer/harvester, therefore the system must be supported by enforcement regimes at the local
and national level (US FWS, in litt., 2015; see Box 3: US case study).
Managing the re-tagging of skins and re-exports can present considerable challenges, particularly
where processing results in the loss, damage or removal of tags, with the potential for abuse of
the system at this stage. Before considering implementation of systems for re-tagging ofskins/tagging of re-exports, it is important to evaluate whether tagging systems are being
effectively implemented in countries of origin in support of legal and traceable trade.

4.2.5. Related developments
At CITES CoP16 (Bangkok, 2013), the Parties adopted a number of interconnected decisions
concerning Snake trade and conservation management (Serpentes spp.). These included decisions relating
to the potential implementation of a traceability and marking system for snake skins 27, which
27 CoP16 Decisions on Snake trade and conservation management (Serpentes spp.) include the following:

Directed to the Secretariat

16.102 The CITES Secretariat shall, where appropriate in consultation with the Standing Committee:c) inform Parties of the results of the International Trade Centre (ITC) study on trade in python snakes in Asia, the UNCTAD
Biotrade Initiative’s Working Group on reptile skin sourcing, when these become available, and other relevant studies and information;

Directed to the Animals Committee

16.103 The Animals Committee shall:b) examine the study undertaken by the UNCTAD Biotrade Initiative’s Working Group on reptile skin sourcing mentioned in Decision
16.102, paragraph c), and any other relevant available information concerning:i) existing marking and tracing systems and, where relevant, accompanying certification schemes of all kinds (and not necessarily
limited to those currently in use for trade in wild species), which could provide best practices that might be applicable to snakes;ii) a traceability system to confirm the legal origin of snake skins; andiii) the economic feasibility of current technologies to implement such a traceability and marking system;c) advise the Standing Committee on the feasibility of implementing such a traceability system for snakes; andd) report on the status of this work at the 65th and 66th meetings of the Standing Committee.

Directed to the Standing Committee

29were the subject of discussion at the 27th meeting of the Animals Committee (AC27, Veracruz,
May 2014) and 65th meeting of the Standing Committee (SC65, July 2014). Research/activities
undertaken to inform and contribute to implementation of these decisions have included:(i) A study co-commissioned by the CITES and United Nations Conference on Trade andDevelopment (UNCTAD) Secretariats entitled Traceability Systems for a Sustainable International
Trade in South-East Asian Python Skins (Ashley, 2013)28 . This study, which is referred to in
Decision 16.103 paragraph b), incorporates inputs from a broad range of stakeholders andreviewers, and provides decision-makers with a number of options for strengthening theregulatory framework for trade in snake skins, and improve traceability (see AC27 Doc.19.2
for a further description of the study and related consultation processes).
(ii) A stakeholder consultation process initiated by the Responsible Ecosystems Sourcing
Platform (RESP) through its International Working Group on Reptile Skins (IWG-RS), todevelop the basis of a global traceability information system for reptile skins to complement
and strengthen the current CITES permitting system related to this trade. The main findingsof this consultation process were submitted for consideration at AC27 (see Annex to AC27Doc. 19.4).
At AC27, the Animals Committee established a Working Group on snake trade and conservation
management, with the mandate to examine the findings and recommendations concerning
traceability of snake skins presented in the UNCTAD/CITES study and arising from the
RESP/IWG-RS consultation process described above, as well as additional relevant information
concerning, for example, existing marking and tracing systems for snakes, certification schemes
and current technologies.
Based on the discussions of this Working Group, the Animals Committee at AC27 made thefollowing initial recommendations on the feasibility, development and implementation of a
traceability system for snakes, which were reported to the Standing Committee at SC65 (SC65
Doc. 44):b) Concerning traceability, the Animals Committee suggested that the Standing Committee consider implementing
a traceability system for snake skins comprising the following characteristics:- For the formulation of relevant provisions, the Standing Committee may draw upon Resolution Conf.11.12(Rev. CoP15) on Universal tagging system for the identification of crocodilian skins as a template;- In particular, the traceability systems should commence as close to the point of harvest of the animal or
production of the skin as possible. It should be made mandatory up to and including finished skins. Any useof the tagging information further on in the trade chain is optional; and- The identification of skins should make use of devices that are tamper proof, affordable, uniquely seriallynumbered and contain the following minimum information: species, country of origin (where relevant regionalcode), year of harvest or production, unique serial number, source code. In addition, Parties are encouraged to
add other information they deem necessary.
At SC65, the Standing Committee took note of these recommendations, acknowledging that its
Working Group on snake trade and conservation management would further consider the matter
16.105 The Standing Committee shall:a) consider the reports and recommendations from the Animals Committee and the Secretariat provided in accordance with Decisions
16.102 and 16.103 and, as appropriate, the results of the ITC study on trade in python snakes in Asia, the UNCTAD Biotrade
Initiative’s Working Group on reptile skin sourcing, and any other relevant available information;b) examine the study undertaken by the UNCTAD Biotrade Initiative’s Working Group on reptile skin sourcing, and any other relevant
available information concerning:i) the socio-economic implications of such a traceability system; andii) the potential costs of the system at all levels along the supply chain, from producers to consumers;c) make recommendations to the Parties, the Animals Committee and the Secretariat as appropriate; andd) report on the implementation of Decisions 16.102, 16.104 and 16.105 at CoP17, with recommendations for consideration by theParties, if deemed necessary.
28
Available from http://unctad.org/en/PublicationsLibrary/ditcted2013d6_en.pdf

30

of snake skin traceability and sourcing intersessionally and report at SC66 (Geneva, January2016). Further developments and activities relevant to the above are described in AC28 Doc.
14.2.1. and AC28 Doc. 14.2.2. and the outcomes of deliberations at AC28 are discussed under
Section 3.2 above.
Although discussions regarding a traceability system for snake skins are ongoing, research carriedout so far has already provided valuable guidance and lessons learned for the traceability of
reptile skins more generally, including for crocodiles. The UNCTAD/CITES study, for example,(described at point (i) above) was informed, to some extent, by the experience of implementing atagging system for crocodilian skins. A comprehensive discussion of the findings of the
UNCTAD/CITES study is beyond the scope of this report, however, some helpful traceability
considerations that emerge from this initiative include the following:Point of first tagging: Tagging should take place in the range State or country of origin and at
the earliest feasible point of the supply chain. The first point of tagging will vary by range
State, and determination of the appropriate point will require consultation with range
States/regional trade stakeholders. Entities authorized to receive tags must be licensed,
required to report, subject to inspection and accountable for the system used. Considerationmust be given to the limited resources of actors in the first stages of a supply chain and any
negative impacts the tagging system could have on local participation and livelihoods.



Verification of legality: Consideration should be given to the stages in the supply chain during
which legal trade can be reasonably verified. For snake skins, this is at harvest, transport,
processing or tanning level, and the “Tannery Bottleneck” can be used as the final point at
which to verify legal trade. After this point, verification becomes much more difficult:marking/tagging could still be used (e.g. to help ensure chain-of-custody), however,verification of legality needs to be achieved between the dried skin and leather stage. A“tiered approach” to tagging could be considered (e.g. mandatory tier corresponding to earlystages in the value chain, with a mandatory or optional second tier).

Marking options: Marking options used should be specific to trade (in this case, Python skins),
but draw on systems currently used; be low cost, easy to apply, simple to distribute,pragmatic, business-friendly, and fraud-proof; have real-time online registration (which could
be compatible with mobile technology to register skins); provide revenues that can be usedby range States to finance implementation of the traceability system; and be based ontechnical and scientific analysis, as well as population and trade data. Tags should only beallocated to private sector participants that are licensed, subject to inspection, responsible forregular reporting and required to return any unused tags to the issuing authority, or report
those lost or stolen. A range State database detailing who received tags is the foundation of
any traceability system, with subsequent verification of tag numbers exported, in inventory,
lost, stolen or damaged.

Links to CITES permitting processes: Due consideration should be given to the linking oftagging/traceability systems to the CITES permitting process, and ensuring that all
information is standardized. Sharing of real-time information (e.g. when verifying shipments)
will require development of new means for Parties to share data in an automated manner, forexample, through use of mobile phone technology and linking with national databases/the
UNEP-WCMC CITES Trade Database.

31

4.3. Queen Conch4.3.1. Overview of fisheries and trade
Queen Conch Strombus gigas is an edible marine gastropod endemic to the Caribbean region, witha range spanning the territorial waters and Exclusive Economic Zones (EEZs) of at least 36
countries and dependent territories (Theile, 2001). It is one of the most important fisheryresources in the Caribbean in terms of annual landings and socioeconomic importance (Theile,
2001; Aspra et al., 2009). More than 20 000 fishers are thought to be engaged in Queen Conchfishing in the Caribbean region, ranging from small-scale, subsistence fishers to large scale,commercial activities. In spite of the difficulties in obtaining appropriate and updated estimationsof total landings, regional annual conch production is believed to be around 7,600 MT (Pradaand Appeldoorn, 2014).
Queen Conch has been listed in Appendix II of CITES since 1992, which controls international
trade in all specimens (live animals, meat, shells, pearls and other parts and derivatives). The maincommodity in trade is the white conch meat, which is mostly traded in frozen form, but may also
be exported as fresh or dried product (Theile, 2001; Prada and Appeldoorn, 2014). Other
commodities such as shells, carvings and pearls are also traded in considerable quantities (e.g. as
curios, in jewellery, or as souvenirs) but are generally considered as secondary products of thefishery (Mulliken, 1996; Chakalall and Cochrane, 1996). The operculum is also utilised as asouvenir in the tourism industry in low numbers and, since relatively recently, has been exported
to China where it is believed to be used in traditional Chinese medicine (Prada and Appeldoorn,2014).
Queen Conch meat is consumed domestically and exported to major markets such as the US, theEU and the French overseas territories in the Caribbean (FAO, 2013). Prior to export, most
Queen Conch meat undergoes some degree of processing, the extent of which depends, forexample, on the marketing system, final destination and cultural preferences (Aspra et al., 2009).
In general, processing is relatively simple and entails the removal of the intestines and theremoval of the darker portion of outer “skin” (Aspra et al., 2009). Depending on the degree ofprocessing, this may result in a reduction of up to 50% or more of the original tissue weight after
extraction from the shell (Theile, 2001). One kilogram of clean Queen Conch meat costs typicallyaround US$7-8 (Prada and Appeldoorn, 2014).
In the majority of countries, Queen Conch fishing remains an artisanal activity involving small
canoes or dories of 7-10 m long, powered by outboard engines, or sail and oars, and carrying 1-4
divers. Artisanal fishing may also be carried out at distant fishing grounds, using mother ship
vessels to transport small canoes and larger numbers of fishers (7-10 divers approx.), with trips
lasting around 4-7 days. Queen Conch meat in artisanal fisheries is generally landed alive or fresh,with the shell or as unclean meat (i.e. with the majority of organs attached). Where a mother ship
is used, meat is usually landed as refrigerated, clean product (i.e. trimmed meat with no organs)(Prada and Appeldoorn, 2014).
Industrial fishing for Queen Conch involves larger, steel-hulled boats (up to 35 m in length),
powered by inboard engines, and carrying as many as 40 or even 60 divers, for several weeks ormonths at a time. In addition to free/scuba diving, industrial divers may use surface compressor(Hookah) diving techniques. Industrial fishing takes place around 40 to 160 nautical miles fromlanding sites in Jamaica, Honduras and Nicaragua (and up to 2012 also in Colombia). In
industrial fisheries, the meat is generally extracted from conches using a hammer and knife
underwater, before being pre-processed and stored on board the vessel and landed in bags asfrozen, clean product (Prada and Appeldoorn, 2014).

32

It is noted that Queen Conch has been included in the Review of Significant Trade 29 andrecommendations made to range States by the Animals Committee (see AC26/PC20 Doc. 7 andAC26/PC20 Doc. 7 Annex 5). Trade suspensions have also been recommended for some range
States.

4.3.2. Recent developments
Since 2012, a number of recommendations and decisions of relevance to Queen Conchtraceability have been agreed upon in various regional fora and by the CITES CoP. These aresummarized in Table 1 below.

4.3.3. Traceability options for Queen Conch
This section provides an overview of selected measures that are currently being implemented at
the national level for traceability of Queen Conch and/or are being considered for
implementation/harmonization at the regional level. As there is no specific traceability system for
Queen Conch defined under CITES, this section provides examples of possible approaches,
although not attempting to provide an exhaustive or complete list. More general mechanisms tocombat illegal fishing, such as Vessel Monitoring Systems (VMS) and enforcement patrols, arealso essential to improve confidence in traceability systems; however a discussion of theseapproaches is beyond the scope of this report.
Recent discussions have recognized that implementing any measures to improve the traceabilityof Queen Conch will require an understanding of the supply chain for all stages of processing(AC28 Doc. 19). This underlies the discussion of the following measures, but is not consideredfurther here.
The information in this section is based on a review of relevant literature, as well as contact with CITES/fisheries
officials from the region, where indicated. It is noted that experience from implementing management measures forother aquatic species such as abalone Haliotis midae and sea cucumbers should also be considered, whereapproaches such as developing more inclusive fisheries policies and/or listing in CITES Appendix III have been
largely unsuccessful at addressing IUU activity (e.g. due to a lack of adequate resources and international support
to combat illegal trade). See, for example, De Greef and Raemaekers (2014); Sant (2004) in Bruckner (ed.)(2006).

(a) Catch documentation schemes
A catch documentation scheme (CDS) is a system that combines both catch certification andtrade documentation, i.e. it documents verifiable information on fish catch from the point of
capture to final destination (FAO, 2008).
The introduction of a regional CDS has been suggested as a potential management option to
improve traceability of Queen Conch and to reduce opportunities for illegal, unreported andunregulated (IUU) catch to enter trade (Caribbean Regional Fisheries Mechanism (CRFM),
2013). Possible features of a CDS were discussed at the EU ACP Fish II30/CRFM Queen Conch

29 The Review of Significant Trade (RST) process involves a review of biological, trade and other relevant information

on Appendix-II species subject to levels of trade that are significant in relation to the population of the species, inorder to identify problems concerning the implementation of Article IV, paragraphs 2 (a), 3 and 6 (a) of CITES, andpossible solutions. The species subject to the RST are selected by the Animals and Plants Committees. Noncompliance by any State with the solutions recommended by these Committees may ultimately lead to a
recommendation by the Standing Committee to suspend trade with that State in specimens of the species concerned.
See CITES Resolution Conf. 12.8 (Rev. CoP13) (https://www.cites.org/eng/resources/terms/glossary.php#s).
30 The ACP FISH II Programme was a 4.5-year programme financed by the European Development Fund on behalfof ACP (African, Caribbean and Pacific Group of states) countries. See: http://www.acpfish2-eu.org/.

33

workshop in June 2013, although an expansion of the system beyond CRFM31 is considered togreatly increase its utility (CRFM, 2013).
Features discussed at the June 2013 workshop include: Development of a single system compatible with the EU IUU Regulation and CITES
documentation and which serves international reporting requirements.
 Use of unique codes for each shipment, which would link a shipment with the vessel trips
that landed the conch.
 National responsibility for issuing and validating catch documentation and export/re-export
documents and reporting.
 Regional responsibility for managing national data in a regional database,verifying/monitoring data, and reporting on regional Queen Conch trade annually (CRFM,
2013).
Requirements for an effective CDS include a functional database management system, which
would operate across the region and allow importing and exporting countries to report trade in
Queen Conch (CRFM, 2013). A technician would be needed to run the system, as well as longterm support and maintenance requiring funding commitment from the region. Risks identified
include a lack of funding, training, demand for use and expertise within CRFM/countries, or achange of priorities, which might make the system difficult to maintain. A barrier to introductionof a CDS is also the willingness of countries to give up control over their fishery andinternational trade, as they would need to consult with the regional body on export and import.
It is noted that a number of Caribbean States are already familiar with the CDS used by theInternational Commission for the Conservation of Atlantic Tunas (ICCAT) and the EU IUURegulation catch certification scheme for other fish products. In developing any new CDS, it
would make sense to consider the requirements of the EU IUU Regulation system, which is usedby States that export fish products to the EU (MRAG, 2013; see, for example, Box 4 for detailsof the Bahamas EU Catch Certificate).
Box 4: The Bahamas EU Catch Certificate
Exporters from the Bahamas to the EU require a catch certificate, which is provided by the
Department of Marine Resources. The certificate is currently compiled by hand, however toimprove the provision of catch and effort data, the process has been partially automated.
Spreadsheets are used for data entry and transmission, and a simple database is used to hold andreport data. A catch certificate request can be automatically verified based on data previously
provided, and automatically produced and printed both in paper and electronic form. A
significant advantage of the system is that it works using office software and systems, with which
processing company staff are already familiar.
Verification of the information can take place at various points in the chain of custody, where thequantity of conch can be measured and matched against the quantity recorded on the certificate.
Critical points of verification include the landing site/delivery point to the processor, the point ofexport and the point of import. Verification in the Bahamas is not carried out at the landing site,and only superficially at point of export.
Source: MRAG (2013)31 Anguilla, Antigua and Barbuda, Bahamas, Barbados, Belize, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat,

St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Suriname, Trinidad and Tobago, Turks and Caicos

34

Table 1: Progress of discussions regarding traceability of Queen Conch – outcomes of relevant meetings (2012-2015)
Abbreviations: HACCP - Hazard Analysis and Critical Control Point; CFMC - Caribbean Fisheries Management Council; OSPESCA - Organizacion del Sector Pesquero y
Acuicola del Istmo Centroamericano (Central America Fisheries and Aquaculture Organization); WECAFC - the Western Central Atlantic Fishery Commission; CRFM - theCaribbean Regional Fisheries Mechanism; SPAW - Specially Protected Areas and Wildlife
Meeting
Outcomes
QCEW (United
The Queen Conch Expert Workshop (QCEW) agreed on 29 recommendations, including the following:
States, May 2012)
28. The following recommendations represent a set of possible approaches to combat IUU and improve enforcement in the region. Given the on-going problems
with enforcement, there are unlikely to be any simple solutions. However, there are a number of initiatives and procedures which could be enhanced andencouraged: […]b. Implement an auditable “chain of custody” procedure, so that catches can be traced back to their catch location, and not just their point of landing or pointof export. Catch documentation procedures are already required by HACCP and the EU, and CITES permit and certificate system could track Queen
Conch entering international trade;c. Research practical technology to enhance the traceability of queen conch, including labelling, marking, DNA stock identification, etc.
First meeting of the The members of the CFMC/OSPESCA/WECAFC/CRFM Queen Conch Working Group (QCWG) adopted a joint ‘Declaration of
QCWG (Panama,
Panama City’ (with an annex containing the QCEW recommendations of May 2012), and a QCWG work plan for 2012-2013. The
October 2012)
Declaration recommends that “the Conference of the Parties [to CITES]....adopt recommendations as appropriate to support the sustainableutilization, conservation and international trade in Queen Conch”. A separate working group was established to develop a number of draft
decisions for consideration at CoP16, to be based on the regional findings and actions agreed at the October 2012 QCWG meeting.
CITES CoP16
The Parties adopted a number of decisions of relevance to Queen Conch trade, management and conservation (Decisions 16.141(Thailand, March
16.148). These included the following decision on traceability: 16.144 Range States of S. gigas should collaborate in exploring ways to enhance2013)
the traceability of specimens in international trade, including, but not limited to, catch certificates, labelling systems and the application of genetic techniques.
Decision 16.141 also encourages range States to adopt and, where applicable, move towards implementation of the recommendationsof the QCEW. Decisions regarding the development of Queen Conch conversion factors at different stages of processing are also of
relevance to traceability.
EU ACP Fish II /The workshop developed a Regional Management Options Paper for Queen Conch, based on the results of five field missions to The
CRFM Queen
Bahamas, Belize, Dominican Republic, Grenada and Haiti, and a regional review of Queen Conch management and science in theConch workshop (St region. The recommendations of the QCEW in 2012 were also considered to provide a broad outline of options available, allowing
Vincent & the
the workshop to propose how the recommendations might be implemented in practice. It was agreed that the options should be
Grenadines, Juneconsidered at the regional and national levels for implementation (CRFM, 2013).
2013)
WECAFC 15th
A number of recommendations on Queen Conch were adopted including the following: WECAFC, in close coordination withsession (Trinidad & OSPESCA, CRFM, CFMC, CITES and the SPAW Protocol Secretariat, develop a regional plan for the management and conservation of Queen
Tobago, March
Conch, in accordance with the best available scientific evidence to be presented to the 16th session of WECAFC for final review and regional adoption.
2014)

35

Meeting
Second meeting of
the QCWG(Panama, November
2014)International
Regional
Cooperation
Workshop for theManagement andTrade of Queen
Conch (Colombia,
March 2015)

Outcomes
Meeting participants reviewed a draft Queen Conch management and conservation plan and determined which of the 26 potential
measures contained in the plan would contribute most to the sustainability of stocks and livelihoods of those involved in Queen
Conch fisheries. Measures with implications for traceability include: (i) the licensing of all Queen Conch fishers, processors and exporters; (ii)traceability of Queen Conch throughout the value chain; (iii) develop and progressively implement a certification program to promote legal conch consumption
in the Wider Caribbean; (iv) develop and implement a digital catch and effort data entry and analysis system. The experts recommended that 16
measures were suitable for regional level harmonization and should be discussed in 2015 with all relevant stakeholders at national
level in the Queen Conch range States. It was noted that most measures identified were applied already by a majority of range Statesat the national level. Adoption of a final set of regionally harmonized management measures was foreseen to take place at the
16thsession of the WECAFC and the CITES CoP17 in 2016. The QCWG also agreed on a workplan for 2015-2018, including: To
begin a review of options for development of an auditable "chain of custody" procedure to track catches from their catch location to their eventual destination(implementation of Recommendation 28, b. Of the Expert Workshop).
The main objective of the Workshop was to assess and define a regional workplan to incorporate relevant strategies to put in topractice the recommendations laid out in the Panama Declaration and relevant CoP16 decision, with an emphasis on NDFs andconversion factors. Specific objectives included:(i) To develop a proposal for conversion factors at the different levels of transformation of the Queen Conch, which will enable the standardization of dataand instruments for the presentation of reports on catches and trade in meat and other products.
(ii) Definition of the Regional Management Plan for Queen Conch to guarantee conservation and traceability in international trade of this species (AC28Doc. 19).

36

(b) Electronic data collection and management systems
The draft Regional Queen Conch Fisheries Management and Conservation plan (considered at
the second meeting of the QCWG, November, 2014) places emphasis on the gradual transition
from paper-based to electronic data collection, reporting and management systems to underpin
the establishment of an effective harvest strategy for the region. This has implications fortraceability of Queen Conch, supporting implementation of CDS and facilitating verification of
product legality (e.g. compliance with quotas, licences, etc.) and tracing back to point of capture.
In the shorter-term, improving data collection might involve enhancing mechanisms to facilitate
and increase reporting by fishers, or cleaning/improving existing digital databases at the nationaland sub-regional level (Prada and Appeldoorn, 2014). In the longer-term, the draft Regional
Queen Conch Fisheries Management and Conservation plan envisages the following:
1. Establishing mandatory reporting of fishery-dependent32 information, not only for industrial
or processors, but also for all fishermen and processors.
2. Establishing a program to electronically report fishery-dependent data in real-time by
structuring an online platform for sharing and storing Queen Conch information (Figure 3).
Access to the database would be granted to registered users through a secure online
platform. Fishers would access the online platform by sending information through a special
application that works from a mobile phone or a tablet. They could also send a text message
with the requested information.
3. Compiling data in national databases, incorporating conversion factors and mechanisms for
quality control, for analysis at the national level.
4. Storing and sharing national databases in a WECAFC33 server, for analysis on a regional
level, and link with CITES Secretariat.
The use of software tools to increase efficiency in data management and improve accuracy ofreporting (e.g. by industry) was also discussed at the EU ACP Fish II/CRFM Queen Conchworkshop. Implementation would involve: (i) the identification of suitable tasks which can be
automated; (ii) development of the appropriate software tools to complete the task; and (iii)
dissemination of tools to users with appropriate training where necessary (CRFM, 2013).
Software tools could be developed nationally for specific tasks (see, for example, Box 5), butshould be made available throughout the region (CRFM, 2013). Risks identified at the workshop
include a lack of training, which would prevent software tools from being used properly, and theneed for standardized hardware through the chain for data collection and entry (CRFM, 2013).
Widespread acceptance of any software tool that increases efficiency is considered likely,
provided that users understand how it is operated (CRFM, 2013).

32 Fishery-dependent information includes information derived from fishing activity/the fishing sector (e.g. reported

landings, catches, etc.), in contrast to fishery-independent information which is obtained or undertaken independentlyof fishing sector activity. In cases where fishery-independent data, such as stock abundance indices from research
surveys, are available, it is possible to use these as an independent check on catch per unit effort (CPUE) based oncommercial fishery catch and effort data. In cases of suspected serious misreporting of catches, it is possible to use
such fishery-independent data to obtain estimates of the commercial catches (FAO, 1998).
33 Western Central Atlantic Fishery Commission.

37

Figure 3: Simplified diagram of the electronic centralized Queen Conch catch and effort
data collection and storage system

Source: Prada and Appeldoorn (2014)38

Box 5: The Bahamas Data Collection Initiative
Queen Conch processors in a number of Caribbean countries provide reports with catch andeffort information based on their purchases, however these data are often incomplete anddifficult to verify (Prada and Appeldoorn, 2014).
In 2012, The Bahamas introduced a new electronic data collection system to obtain catch andeffort data from key processing facilities that export and supply larger local restaurants with
Queen Conch and other species. The system was primarily set up to improve provision of
accurate data for spiny lobster, but will cover all marine products purchased by the mainprocessors. Implementation is not yet complete: data is not yet routinely processed by the
Department of Marine Resources (DMR) and only one processor has consistently submitted
records so far.
Processors submit catch and effort data of purchased landings using spreadsheet data entry
forms. Forms are transmitted weekly from the processor to the DMR by email. At the DMR,
the spreadsheets are loaded directly and automatically into an MS Access database withminimum staff intervention.
Although processors are required to collect additional data, this may already be required for
EU catch certificates and the software tools provided by DMR facilitate data entry andpreparation. As such, the additional work is not excessive.
Note: the only catches that are recorded are those purchased by processing facilities. Landings for subsistence, or
those purchased by many small local restaurants and smaller commercial outlets, are not recorded. The scale ofunrecorded total catch is not known.
Source: MRAG (2013)(c) Licensing and cooperatives
Licensing of all fishers, processers and exporters is a means for fisheries managers to establish
the number of individuals/entities involved in the Queen Conch fishery and related trade, and tosecure compliance with reporting and management measures (Prada and Appeldoorn, 2014b). It
is proposed as a management measure in the draft Regional Queen Conch Fisheries Management
and Conservation plan, which suggests that provision/renewal of a licence (Prada andAppeldoorn, 2014b):(i)should be on an annual basis;(ii) should be linked to the provision of logbook, landing, processing, export/catch data, andother information; and(iii)
should depend on whether sustainable and legal practices are applied.

39

A licensing system can support traceability through improved data collection and reporting. In
Belize, progress has been made with regard to the traceability of Queen Conch meat ininternational trade through establishment of catch quotas and licensing of fishing cooperatives(AC28 Doc. 19). Further information is provided in Box 6.
Box 6: Fishing cooperatives in Belize
In Belize, the export of Queen Conch meat is carried out exclusively by fishermencooperatives. The Fisheries Department (FD) in Belize has developed a database to store
records of Catch Per Unit Effort (CPUE) data (individual fisherman catch data) gatheredfrom fishermen cooperatives, which are required to register and obtain an export licence
every year. Data are processed and analysed by FD, as a result of which the FD is able to link
catches to area and fishermen who traditionally use the fisheries.
Fishermen cooperatives are required to submit monthly production data, which helps toensure compliance with agreed catch quotas by individual fishermen cooperatives. FD carries
out inspections for each shipment of Queen Conch to ensure compliance with the minimum
size limit regulation.
For Belize, the main challenge to developing a system for traceability in the Queen Conchcommodity is primarily due to lack of field data to determine the origin of the product. Thisis being addressed at present through the implementation of a rights-based management
system called Managed Access. This system allows fishermen the right to harvest fish in
specific fishing zones through a special licensing system. When fully implemented in 2016
this system will allow for the collection of data that will indicate the origin of the product.
Fishermen cooperatives will also be required to include area and date fished on
product labels, in addition to other information.
Over the years, fishermen cooperatives have consistently and fully cooperated with the FD,
and will immediately cease accepting conch meat from all fishermen once their quota is
exhausted. Individual catch data is provided in digital format and FD personnel verify thedata through cross-checking of catch receipts.
Source: M. Gongora, Belize Fisheries Department, in litt. (2015); also AC28 Doc. 19(d) Conversion factors
For any CDS to operate effectively, it must be possible to link products at different levels ofprocessing, in order to interpret quantities consistently and apply controls over exports (MRAG,2013). However, for Queen Conch, conversion factors estimated by countries may not bestandardized or necessarily rigorous, while for some countries conversion factors may not yet beavailable (MRAG, 2013; QCWG, 2014; Prada and Appeldoorn, 2014). Furthermore, althoughcountries should report Queen Conch catch statistics to FAO as live weight (animal with shell),data is often provided as meat weight, with no information on the level of processing (QCWG,
2014; Catarci, 2004). The lack of standardized reporting confounds attempts to makecomparisons between countries and undertake consistent studies on regional trends.
To address these issues, the following decision was adopted at CoP16:
16.143 Range States of S. gigas should:a) in coordination with the Working Group on Queen Conch mentioned in Decision 16.141, develop
conversion factors at different levels of processing of S. gigas for standardization of data and reporting
instruments on the catch and trade in meat and other products;

40b) adopt these conversion factors by the end of 2015 and report them to all range States of S. gigas, FAO
and the CITES Secretariat; andc) by the end of 2016, apply the agreed conversion factors in their S. gigas fishery management and national,
regional and international reporting, and include the degree of processing of S. gigas products in the description
field of the export permit.
The 15th session of the Western Central Atlantic Fishery Commission (WECAFC) (Port of
Spain, Trinidad and Tobago, March 2014) also approved a recommendation, which stated that:“Members of Western Central Atlantic Fishery Commission work towards determining and adopting national
conversion factors based on regionally agreed processing grades and terminologies before the end of 2015 andcommunicate the adoption formally to the FAO and CITES Secretariats.”
Following various field studies, regional conversion factors have been suggested for threestandard and most commonly used processing grades (dirty, 50% clean and 100% clean), to allow
calculation of live weight of Queen Conch caught and to obtain harmonized and comparable
statistics between countries (QCWG, 2014). It is recognized, however, that due to spatial
variability and characteristics of the species, countries should also consider it a priority toestablish their own conversion factors (AC28 Doc. 19). Conversion factors are currently being
developed/refined by various Queen Conch range States (e.g. Jamaica and Belize), while
discussions are continuing on related issues and complexities at a regional level (see AC28 Doc.
19).

(e) Genetic techniques
The application of genetic techniques is referred to in CoP16 Decision 16.144 as a possible
approach to enhancing traceability of Queen Conch (see Table 1). An overview of progress on
genetic techniques has been provided in AC28 Doc. 19, and is summarized briefly below.


US: the US FWS has a forensic laboratory service, which has the capacity to identify Queen
Conch meat.
Jamaica: a project is ongoing to study the application of genetic techniques to characterize
population structure of Queen Conch and the connectivity of populations in the region.
Potential applications include managing IUU fishing of Queen Conch by foreign vessels.
Colombia: genetic studies have been carried out, which can assist in product identification.

(f) Certification
An ecological certification stamp to encourage sustainable production and consumption of
Queen Conch in the wider Caribbean region is being considered as an additional approach todemonstrate sustainable production, improve traceability and incentivize data capture byfishermen (AC28 Doc. 19). Certification could be linked with current chain of custody
procedures and quality controls for exported products, such as HACCP (Hazard Analysis andCritical Control Points) (MRAG, 2013; Prada and Appeldoorn, 2014). The implementation ofpilot projects with local communities/restaurants is being considered (AC28 Doc. 19).

41

4.4. TimberThis section is largely based on developments in timber tracking systems and discussions thathave taken place within the framework of the ITTO-CITES timber programme. This is acollaboration between the International Tropical Timber Organization (ITTO) and CITES
Secretariats, which aims to ensure that international trade in CITES-listed timber species is
consistent with their sustainable management and conservation. The programme plays animportant role in CITES implementation for tropical tree species such as Afromosia Pericopsis
elata, mahogany Swietenia spp., and ramin Gonystylus spp., including recommendations of the
CITES Plants Committee and Working Group on the Bigleaf Mahogany and other Neotropical
Timber Species. This Working Group, at its fourth meeting in November 2011 (Petén,
Guatemala), agreed on the following recommendation:
7. Exporting and importing countries should establish systems to ensure the legality of specimens of the species
concerned that are in trade by using chain of custody and traceability systems and identify possible sources offunding to strengthen such mechanisms. Parties are urged to share their experiences in implementing chain ofcustody and traceability systems for timber (Recommendation 7, PC20 Doc. 19.1).
A key area of focus of the ITTO-CITES timber programme is the development of cooperativeand cost-effective regulatory systems for product tracking and chain of custody (PC17 Doc. 16.2
Annex). Phase II (2012 -2015) of the programme has focused, amongst other things, on assisting
range States in their efforts to demonstrate that robust chains of custody are in place for
products derived from CITES-listed species, including through the use of tracking technologies.
In 2012, the ITTO and CITES jointly published a report entitled “Tracking sustainability: areview of electronic and semi-electronic timber tracking technologies” (authored by Seidel et al.,2012), which provides Parties with a compendium of existing timber tracking technologies anddetailed information on the features of various systems. The report also incorporates information
and recommendations from a Workshop on Tracking Technologies for Forest Governance(Kuala Lumpur, Malaysia, May 2012), which provided an opportunity for participants to shareexperiences about timber tracking technologies and to learn about the latest developments(ITTO, 2012).
The following sections draw on information contained in the 2012 ITTO-CITES report and findings of theWorkshop, as these provide a comprehensive overview of the status of timber tracking technologies in use (or being
developed) in the CITES context, as well as lessons learned and best practices as regards implementation. This issupplemented by experiences from (pilot) projects implemented under the ITTO-CITES timber programme, and
CITES Plants Committee discussions. The national case studies (Section 4.4.4) are based on a literature
review, and information received from relevant authorities.

4.4.1. Overview of timber traceability systems
A generic traceability system in the timber sector might begin with the application of unique
numbers or codes to stumps and logs in a forest concession, through physical marking using
paint, waterproof paper/plastic tags, bar codes or RFID tags (Table 2). Data may be recorded
using a handheld device or on paper, which may be transferred to a database either automatically,or manually at a later stage. At each control point in the supply chain, for example, at the point offelling or removal from the forest, timber may be re-tagged/marked and product information(e.g. length, species and value) recorded and transferred to the database. Data may then beaccessed by authorized departments (e.g. via a web-browser) and analysed to verify the numberof logs from a single tree and location of the stump, detect non-conformities, verify the logicalflow of timber products and/or volume, and ensure that the volume does not increase at any
stage (Seidel et al., 2012; Figure 4).
As an alternative to physical marking of timber, a mass balance system may be used (see Figure5). Mass balance systems monitor whole batches of timber, based on a systematic understanding42

of inputs, outputs and accumulations of timber material, without physical marking. Whereas
physical tracking is appropriate mainly for larger timber items, such as round wood, mass balancesystems allow smaller products (such as smaller pieces of sawn wood, wood chips, etc.) to be
tracked and are therefore commonly used for processed material. Mass balance systems are
generally less costly than physical tracking systems; however, they may be inappropriate where itis necessary to track an individual product or lot back to its physical origin, particularly if there isa possibility that mixing with high-risk material could occur (Seidel et al., 2012).
Table 2: Methods for the physical marking of timber and timber products
MethodPaint
Serial number hand-painted
and stamped onto individuallogs and timbers
Plastic tags
Plastic tags printed withunique ID number

Bar codes
Bar codes fixed to timbers andscanned using reader

Advantages
 Low cost
 Easy to apply Durable Can be read at longer
distances Low cost
 Easy to apply
 Increases legibility
 Avoids duplication in
ID numbers

Disadvantages
 Labour-intensive
 Prone to mis-reading and forgery









Automatic transfer ofdata to database
Relatively low cost
Difficult to forge









Radio Frequency
Identification (RFID)
ID number and product datastored in tag and transmitted
wirelessly to readerAutomatic transfer ofdata to database
Resistant to forgery
Dissolvable tags now
available for use inpulp industry







Prone to forgery
Less durable (can become damaged ordetached from timber)
Inappropriate for roundwood used for pulp
or paper processes
Need to be in proximity of the timber to beread
Requires trained staff to operate readers
Connection to mobile phone/ internet
network may be required
Bar codes may become detached fromproduct
Need to be in relatively close proximity to
the timber to be read
Relatively expensive
Requires trained staff to operate readers
Connection to mobile phone/ internet
network may be required
Inappropriate for roundwood used for pulp
or paper processes
Need to be in relatively close proximity to
the timber to be read

Source: after Seidel et al. (2012), ITTO (2012), H.K. Chen, TRAFFIC, in litt. (2015)

Figure 4: Core elements of an electronic timber and timber products tracking system

Source: Seidel et al. (2012)

Figure 5: Illustrated concept of a mass balance system

43Source: F. Seidel in Seidel et al. (2012)

4.4.2. Challenges
Tracking flows of CITES-listed timber and timber products, from areas of harvest to consumer
countries, presents a significant challenge for reasons including:










The range of products in trade. Tracking is more simple where the CITES-listing is restricted
to products such as logs, sawn wood, veneer sheets and plywood (e.g. for Bigleaf Mahogany
Swietenia macrophylla), but more complex where processed products are involved (e.g. thelisting for ramin Gonystylus spp. extends to all products other than seed, seedlings or tissue
cultures) (PC17 Doc 16.2 Annex)34.
The complexity of timber supply chains, for example, due to the mixing of wood frommultiple concessions, regional transshipment and different stages of processing in different
locations (FAO Forestry Department, 2012, in ITTO, 2012; H.K. Chen, TRAFFIC, in litt.,
2015). A generalized timber supply chain is depicted in Figure 6, with further detail provided
in Figure 7.
Challenging physical environments, especially for marking of tropical species in the tropicalrainforest (Forestry Department Peninsular Malaysia, FDPM, 2010a)
Weak infrastructures, e.g. roads, communications, network, internet connectivity, controls,
etc. (Seidel et al., 2012)
Range of background and skills of forest operators (FDPM, 2010a), weak staff training (ITsystems, literacy, etc.) (Seidel et al., 2012)
Variety of authorities involved in forest management and enforcement; low governancecapacity/verification through government systems (Seidel et al., 2012)
Tracking systems can incur additional costs (e.g. hardware, software, training, labour costsetc.) without guarantee of higher revenues or price premiums, and require sustained funding
to stay operational (Seidel et al., 2012)34 Listings of species in the CITES Appendices may be annotated (i.e. a note attached) to indicate which parts orderivatives are concerned by the listing. This has been most widely used for listings of plants and timber.

44Insufficient incentives for a complete tracking system throughout the timber supply chain to
be realized (Seidel et al., 2012), for example, government revenues only accrue from forest to
primary processing.

Figure 6: Generalized timber supply chain

Source: United Nations Conference on Environment and Development (UNCTAD), adapted fromInternational Trade Centre/ITTO. Tropical Timber Products: Development of Further processing in ITTO ProducerCountries. Geneva: ITC/ITTO, 2002. Available at:
http://www.unctad.info/en/Infocomm/Agricultural_Products/Bois_tropicaux/Marketing-chain/

Figure 7: Detailed timber supply chain

45

Source: Tropical Timber Products: Development of Further processing in ITTO Producer Countries. Geneva: ITC/ITTO,
2002

4.4.3. Progress of activities for CITES timber
Traceability systems implemented for CITES-listed timber vary widely across countries. As
CITES does not prescribe specific traceability requirements for CITES-listed timber, Parties haveconsiderable latitude to develop systems appropriate to their national contexts. These range frompaper-based systems, to systems involving centralized web-platforms and/or integration ofelectronic tracking technologies such as RFIDs. DNA and isotope methods are also being
explored as a means of strengthening compliance with existing systems.

(a) Electronic tracking systems

46

Recent discussions in CITES and under the ITTO-CITES programme have focused on the useof electronic timber tracking systems as a means of improving implementation of CITES fortimber species and addressing the limitations of paper-based systems (ITTO, 2012). Progress
towards more robust and reliable tracking systems has also been prompted by requirements todemonstrate legal origin of timber for access to key consumer markets, for example, under the
EU Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan and US Lacey Act(ITTO, 2012). Potential benefits of electronic tracking systems include improved transparency intrade chains, strengthened chain of custody and increased efficiency of exchange of enforcement
intelligence information between agencies (CITES Secretariat, 2012, in ITTO, 2012).
Electronic tracking systems for CITES-listed timber can be developed at the individual operator
level (i.e. by each company involved in production and trade) or a “new” system developed
centrally, e.g. at the regional or national level by integrated timber businesses or government.
While individual systems can cause issues for interoperability/linking of supply chains,developing a new, centralized system can require significant know-how and government
investment (PC21 Inf. 9). An alternative is to use an existing, “off the shelf” system, with theaddition of specific functionalities appropriate to the particular context. Such systems can often
be integrated with existing infrastructure and may present a more efficient and cost-effective
alternative for supply chain stakeholders, in terms of development and deployment (PC21 Inf. 9).
Examples of existing electronic tracking systems that may be used/adapted for CITES-listed
timber include: the Timber Tracking Platform (RADIX Tree) developed by Global Traceability
Solutions (GTS); CI WorldTM developed by Helveta Ltd; and Track Vision developed by Track
Record Global Ltd. The features of these and other technological solutions are provided in detailin Seidel et al. (2012). Country case studies of electronic/semi-electronic systems in place for
CITES-listed timber species are provided under Section 4.4.4. below.

(b) DNA and isotope methods
The past decade has seen significant advances in DNA analysis and isotope methods forverifying the declared origin of timber in trade. These methods are being used increasingly toverify the accuracy of documentation accompanying flows of timber, as a means of strengthening
existing traceability and chain of custody systems (ITTO, 2012).
Advantages of DNA analysis and isotopic methods include (ITTO, 2012; Seidel et al., 2012):
 resistance to forgery (manipulation of traits inherent to wood is not possible); ease of integration with and strengthening of existing tracking systems (e.g. focus on highrisk sections of supply chains);
 samples can be taken at any point in supply chains, including from processed products.
However, a key constraint is the need to establish very large reference databases for most
methods (if individual samples of each specimen/product are not taken and preserved forreconciliation and verification of the supply chain back to the stump), the cost of which may beprohibitive for companies during the initial phases of development. However, some governments
are providing funding and effort to build databases for selected timber species (ITTO, 2012).
An overview of these methods is provided below. For further discussion and analysis see theAnnex to PC21 Doc. 15 and ITTO (2012)

DNA analysis

47

There are three main scientific approaches applicable to timber identification and tracking
involving DNA analysis (Lowe and Cross (2011); Geach et al. (2011)):DNA barcoding (developing genetic markers for species identification)
Population genetics/genographic mapping (country/area of origin)
DNA fingerprinting (identification of individuals)

DNA barcoding is relatively fast and cheap to develop for new species, however genographic
mapping is a slower and more costly process (J. Geach, DoubleHelix, pers, comm., 2014, cited in
PC21 Doc. 15 Annex), requiring the establishment of comprehensive reference databases for all
species of interest (Seidel et al., 2012).
In the context of origin determination for timber tracking, a DNA sample is taken at any control
point along a timber supply chain and compared with a genographic map to establish thematerial’s area of origin. Alternatively, the sample is physically paired against samples taken fromtimber/timber products at previous control points in the chain (e.g. from the same tree prior toharvest). For this latter option, establishment of a reference database is not required (Seidel et al.,2012).
An overview of recent developments in DNA techniques and their application in the tracking
and identification of CITES-listed species is provided in the Annex to PC21 Doc. 15. These
include an ITTO-CITES pilot project to implement DNA traceability systems for Pericopsis elata
in forest concessions and sawmills in Congo and Cameroon, which was implemented in 20132014 jointly by ANAFOR (National Forestry Development Agency, Cameroon), CNIAF(National Centre for Forest and Fauna Inventory, Congo) and Double HELIX Tracking
Technologies Pte Ltd. The project involved the development of genetic markers for P. elata
suitable for DNA fingerprinting, as well as capacity-building and training of local teams in DNA
sample collection and storage (Sosa Schmidt, 2013b; ITTO-CITES newsletter, February 2015).
Stable isotope method
Isotope methods for timber tracking involve the identification of an isotope profile for aparticular geographic area based on isotopes found in the soil. Samples taken from timber ortimber products can then be traced to their location by analysing the isotope profile against the
profile for a particular area. The precondition is that the isotopes for a region are already known,
defined and registered (Boner, 2013).
Stable isotope methods have been tested in several projects of relevance for CITES-listed timber.
For example, a stable isotope database of teak and mahogany species has been developed by
Agriosolab in Germany, and tested with samples from Southeast Asia, India and Latin America
which confirmed the reliability of this technique (Agriosolab, 2012, in ITTO, 2012). An
international reference database for teak and mahogany is expected to be completed by the endof 2015, which could be used routinely for tracing the origin of CITES timber (Agriosolab, 2012,
in ITTO, 2012). Additional information on isotope analysis can be found in the Annex to PC21Doc. 15, as well as ITTO (2012) and Seidel et al. (2012).

4.4.4. National case studies
This section provides an overview of timber traceability systems that have been implemented (orthe subject of pilot projects) for CITES-listed timber in selected national contexts. These casestudies were considered to provide a range of potentially relevant experience for the developmentof electronic or semi-electronic traceability systems for other CITES commodities. It is noted,
however, that similar developments are being seen across a number of other CITES Parties,

48

including in Indonesia (introduction of an online tracking system, SIPIHH 35 , in 2009, andnational timber legality verification system, SVLK, in 2013) (Hoare and Wellesley, 2014) and
Cameroon (development of a computer-based tracking system under Cameroon’s FLEGT
initiative with the EU) (ITTO-CITES Newsletter, June 2013).

(a) Malaysia
Ramin Gonystytlus spp. is a tropical hardwood found in peat swamp forest habitats. It is one of
the most valuable timber species harvested in Malaysia, being widely used for furniture, picture
frames and indoor crafting (FDPM, 2010b).
A timber tagging system based on plastic tags and bar codes has been used for many years in
Peninsular Malaysia, with considerable merit (FDPM, 2010b). However, large components of thesystem are manual and paper-based, as a result of which monitoring can be cumbersome andvalidation/verification cannot be undertaken effectively on a remote or volume basis (FDPM,
2010b). In addition, bar code technology has had several limitations such as: prone to damage,reader operations affected by moisture, requirement of clear line of sight, and inability toread/write information or to add information to a printed bar code (FDPM, 2010b).
To address these concerns, a project to develop a Ramin timber monitoring system using RFID
technology was implemented in Peninsular Malaysia between 2008 and 2010, under Phase I of
the ITTO-CITES Programme. The project aimed to develop a customized, cost-effective
monitoring system based on RFID technology, and an automated detection and notification
mechanism for tracing non-compliance using hand-held computers with an RFID scannersystem (FDPM, 2010b). RFID scanners were considered more accurate than other methods (e.g.
when scanning all logs on a truck), more able to withstand harsh environments, and provided theopportunity to include additional load specific data to strengthen the chain of custody. Other
benefits of RFID technology were considered to include: the ability to read over a longer range(no line of sight requirement), provision of greater storage capacity and real-time tracking
capability (FDPM, 2010b).
FDPM opted for a commercial, off the shelf, RFID software solution (CI WorldTM) as theplatform for the RFID Ramin Monitoring System. The system was deployed by a nominatedconcessionaire in Pekan Forest Reserve, Pahang, during tree inventory operations, felling, scaling
and log transportation from log yards to the forestry checking station. At each control point, data
were captured by or entered into the RFID handheld application and sent wirelessly to thecentral server system. The data could then be accessed via an online interface (with a User ID
and password), through which reports could be viewed for different control points across the
supply chain. Alarms were set to automatically detect non-conformities, e.g. duplicate RFID
numbers, changes in species or diameters (FDPM, 2010a). Table 3 provides an overview of theprocedures at each control point, the data captured, the contents of the reports generated andany comments/issues regarding implementation at each stage. Screen captures of the reports
generated at the Tree Inventory and Removal Pass stages are included at Figure 8.

The full name is the Information System for Forest Products Administration. See Ministry of Forestry Regulation
No. P.8/Menhut-II/2009.
35

49

Figure 8: Tree Marking (Inventory) Report and Removal Pass Report

Source: FDPM (2010b)

50

Table 3: RFID Ramin Timber Monitoring System Control Points (after FDPM, 2010a)
Control
point
Forestinventory

Procedure

ReportContent of report

Comments/issues

Boundary demarcation; RFID tagging of Ramintrees; details of each tagged tree recorded using
handheld devices.
Log licence issued; trees designated for removal
felled; data captured using handheld computer;another RFID tag fixed to long logs; logs excavatedfrom forest.
Cross cutting (logs divided into shortened, cross cutlogs); RFID tags scanned; additional tags affixed tocross cut logs and scanned.

ramin
inventory
reportramin
fellingreport

RFID tag number, tree species,
diameter, estimated logs produced, log
quality, block and box location
Information of the standing tree RFID
label and fallen tree RFID label

No issues in applying handheld RFID
application. Contractor tagged trees andcollected data without much assistance.
Chainsaw operators applied and scanned
RFID tags effectively. However, tags prone
to loss or damage during excavation.

Log
production
reportStaff carried out data collection effectively.

Main logyard

Tags scanned again; data relating to timber enteredagain using handheld computer.

Log yard
control
book report

Forestchecking
stationLorry stops at assigned forest checking station to
declare logs being removed from concession: Details of logs and truck information enteredinto handheld - provided no discrepancies,
truck issued with Removal Pass, proceeds tomill.
 Unique authentication code generated byhandheld application, written on Removal Pass.
 Forestry tax assessed based on log volume andspecies.

RemovalPass report

Information on the number of logs
being cross-cut: standing tree RFID
label, RFID labels of logs, original
estimated number of logs, actual
number of logs produced.
Lists all logs reaching main log yard.
Information includes date, concessionarea, tree species, log RFID tag
number, log length and diameter,
estimated/actual number of logs
produced.
Information about log species, log
RFID tag number, log length,
diameter and volume, defects
information, royalty rate, checking
station details.

Tree felling

Temporarylog yard

51

System has expedited Removal Passissuance (wireless mobile broadband andconnection with PC via docking station,
allows RFID handheld system tosynchronise and send data directly to central
database. Officer can log into system toproduce and print Removal Pass physicallyat checking station). Authentication code
functionality is available in “offline” modeand has significantly improved removal passsecurity.

Monitoring and checking of Removal Passes and royalty invoicing was carried out by FDPM
enforcement officers using the handheld verification system. To improve the security of thesystem, a unique authentication code was generated using the RFID handheld application andincluded on each Removal Pass. The combination of unique authentication code, Removal Pass
identification number and RFID tag data could then be used by enforcement officers (in offlinemode) to verify the legitimacy of the load at any point along the transport route (see Figure 9;
FDPM, 2010b).
Figure 9: Use of authentication code to verify legitimacy of load

Source: FDPM (2010b)
The project found RFID technology to be a useful instrument to provide fully documented andeffective timber tracking from forest to mill. Key successes of the project have included theautomated verification of chain of custody data and legality compliance, accessibility of digitizedpaper documentation for validation by a range of stakeholders, offline enforcement
functionalities and scalability to handle the volume of marking and legality assurance datarequired (FDPM, 2010b).
In terms of findings/lessons learned from this project (FDPM, 2010a, 2010b):






The project demonstrated the value of an off the shelf, configurable application, which iscost-effective and can be rapidly deployed and customized to meet varying requirements andimprove existing paper-based processes. The CI WorldTM system was configured over fourweeks to match FDPM harvesting processes and Removal Pass procedures.
One of the most important aspects when deploying a RFID ramin timber monitoring system
is to comprehensively study the user requirements in order to make sure the system’s
specifications are appropriate to the processes and challenges of a specific chain of custody.
RFID monitoring systems can provide a tool to better share real-time information anddocuments between district, State and central offices, and facilitate field inspections.
In order to be efficient, a RFID monitoring system must achieve wide acceptance within theforestry sector. Unless all stakeholders in the forest supply chain agree to participate andactively use the system, its impact will remain limited. The best incentive forstakeholders/industry to adopt a RFID timber monitoring system is to provide a flexible tool
than can be easily adapted to internal processes.

52





The long-term utilization of the RFID monitoring system will depend substantially on thecapacity building, sustained and ongoing engagement of the various stakeholders in theprocess. Skills and knowledge must be transferred to the State and district levels, as well as toforest concession operators, as they will be performing RFID tagging and using handhelds toread and capture data in the field. Comprehensive training workshops and adequate user
guides and manuals are crucial for effective implementation.
There is a need for detailed analysis of the form of RFID tags best suited for marking andtracking processes in the peat swamp forest. While the price of an RFID tag is a concern, it
is estimated that prices will quickly reduce as the tag is deployed in commercial applications
and production volumes increase.

In addition, FDPM has made several recommendations for extension of the project and further
work, including (FDPM, 2010b; Young, 2013):


Continuous replication to other management units/states to bring down operational costs.
Extension of scope of coverage to include transformation processes (i.e. sawmill, ply mill) tofurther extend traceability along the chain of custody.
Analysis of RFID system integration with current computer systems, as well as State revenue
collection to provide a wider range of monitoring.
RFID tag management that includes the issuance of unique identifiers in a controlled andauditable manner.

(b) Brazil
Brazil’s Forest Origin Document (FOD) system is a monitoring and control system operated by
the Brazilian Institute for Environment and Renewable Natural Resources (IBAMA) since 2006.
Under the system, an electronic document is required for the transportation and storage of
products and by-products of Brazilian native ecosystems, including forest products from CITESlisted tree species. All processes of transformation and consumption of forest products 36 arecontrolled, for example the use of wood as a raw material in the furniture industry or inconstruction. However, finished goods, such as doors, windows, furniture or other goods
characterized in the final stage of manufacturing, are exempt (Seidel et al., 2012).
The DOF system is managed through a centralized, online database, which allows for integration
with systems developed at the State level. Credits are generated when a State authority issues alogging authorization to a landowner or operator, and are transferred to a tracking system (either
the DOF or other State system). The tracking system then generates the transport documentsthat must accompany the timber along the chain of custody (Wellesley, 2014). All transactions arerecorded in real time (Seidel et al., 2012).
The DOF system serves as a tool for the monitoring of timber production and trade, providing
information on the volume of products and by-products throughout the supply chain (fromtransportation to conversion, including storage) and supporting law enforcement actions throughthe provision of information for real-time analysis and decision-making (Seidel et al., 2012). The
system is open to use by all federal environment agency (IBAMA) offices, as well as by Stateagencies, police and prosecuting counsel (Seidel et al., 2012). Compared to the previous, paperbased licence system (ATPF – Forest Product Transport Authorization), the DOF system offersa more cost-effective, transparent and secure system for timber monitoring and control (Seidel etal., 2012). The development cost of the system has been estimated by IBAMA at around
USD261 000 (excluding hosting hardware and services) and transfer to other countries throughBilateral Cooperation Agreements is being explored (Seidel et al., 2012).

36 Such as wood in logs, bolts, posts, bracing, stump, sleepers, poles, fence posts, logs, chips, boards, blocks, firewood,

charcoal, laminates, flooring, parquet decking (Seidel et al., 2012)53

According to a 2010 Chatham House assessment, Brazil was considered particularly strong interms of the use of timber-tracking technology compared to the other producer countries underreview (Wellesley, 2014). However, in recent years there has been a loss of confidence in the
integrity of the DOF system and its ability to prevent illegal production and fraud, for example
due to (Wellesley, 2014):reports of computer hacking and entry of false information into the system;
concerns regarding the rate of conversion of logs to sawn timber employed by the system(the conversion rate of 45% is thought to be 10-20% higher than actual conversion rates,
allowing additional timber volume credits to be traded or transported);
weak implementation of CONAMA Resolution No. 406/2009 (requiring systems operating
at the State level to be linked to the central DOF system), which has hampered the ability ofthe various systems to monitor trade effectively;
inability of civil society and other stakeholders to verify official documents related to
production and processing (only transportation documents are available online), which has
limited the use of the system as a tool for independent monitoring of compliance with
forest-sector regulations.

As a result of concerns about fraud and abuse of the system, a 2014 Chatham House assessment
emphasized that improved monitoring and auditing of the system are urgently needed, including
evaluations of the DOF/State systems themselves and carrying out spot checks on the ground(Wellesley, 2014).

(c) Guatemala
Information in this sub-section was provided to TRAFFIC by César Beltetón Chacón of CONAP (theGuatemalan National Council of Protected Areas) in June 2015, unless otherwise indicated.
Guatemala’s Automated System on CITES Timber Flora management is managed jointly by
CONAP (the Guatemalan CITES Management Authority and Scientific Authority) and wasdeveloped locally by CONAP using government funds.
The CONAP system applies only to CITES species and provides information to be considered
for the granting of CITES permits/certificates, including on: (i) the origin of the product to beexported; (ii) the verification of the shipment prior to transfer to the port of departure; (iii) thetransportation of the product to the port of departure; and (iv) volumetric and trade information.
The system also contains a database of permits and certificates in downloadable form (C.
Beltetón Chacón, 2013, cited in Chatham House, 2013). Information can be consulted via the
CONAP website 37 by authorities in Guatemala (e.g. Customs when verifying the accuracy of
CITES documents), by importing countries prior to a shipment’s arrival, and by the generalpublic.
All stages of the supply chain are covered by the system, from the authorized volume of standing
trees, through transportation of logs to industry, and transformation of roundwood to sawn
wood, veneer and plywood for export. However, as finished products are not included in the
CITES listings for timber species of relevance to Guatemala, these are not covered by thesystem. For each stage of the supply chain, national legislation provides for the issuance of adocument certifying the legality of the activity concerned, for example, decisions approving
forest management plans and licences in the case of exploitation, or decisions approving yields
for wood transformations. Timber/timber products are not marked, however must be
accompanied by a packing list for verification. In addition, all authorized shipments of timber are
inspected and labeled with a CONAP-CITES security label (C. Beltetón Chacón, 2013, cited in
37 http://www.conap.gob.gt/index.php/servicios-en-linea/manejo-forestal/permisos-certificados-cites-flora-

maderable.html

54

Chatham House, 2013). Currently, documents arising from the verifications of shipments aretransferred through a scanner and uploaded to an online system. Training is provided on use of
the system to relevant authorities/technical personnel.
Key strengths of the system include the ability to assess legal origin of products entering themarket at each stage of the supply chain, as well as improved transparency at all stages of
production and greater credibility for the forest sector. In developing the system it wasconsidered essential to achieve consensus among the entire sector to make information publicly
available, to ensure the system was as transparent as possible. Constraints to the system include
the lack of technical infrastructure, as well as the high costs associated with implementation.

4.4.5. Lessons learned and best practices
This section provides a summary of a number of lessons learned and best practices fordeveloping and implementing effective traceability systems for CITES-listed timber species. For
further analysis and more detailed discussion, it is recommended to consult the 2012 ITTOCITES report (Seidel et al., 2012) and Workshop findings (ITTO, 2012).
System development/design
1. Controlling raw product is generally most efficient and straightforward; therefore controls
should start and be focused at the early stages of the timber industry (Sosa Schmidt, 2013c).
2. The self-development of a system can require a long trial phase before it can become
operational (Seidel et al., 2012). Off-the-shelf solutions can offer a cost and time-efficientsolution in terms of development and deployment for both large and small supply chain
stakeholders. Such solutions are generally flexible (ITTO, 2012) and can be scalable to cover
all types of supply chains (PC21, Inf. 9). However, harmonization of technical standards
should be promoted as far as possible (ITTO, 2012).
3. Tracking systems can be relatively easily integrated within current chain of custody systems(ITTO, 2012) and should be incorporated into existing structures such as management,
accounting and payment systems (Seidel et al., 2012). If designed as standalone systems, thereis the risk that work could be duplicated, resulting in additional costs (Seidel et al., 2012).
4. Poorly designed timber tracking systems can lead to dysfunctional and ineffective systems. A
carefully monitored and evaluated trial phase is essential for any tracking system, in order toevaluate that the design of a tracking system is able to cope with the field challenges (Seidel etal., 2012). In the planning phase, developers must have a good understanding of on the
ground conditions, such as the quality and availability of internet connections, and thesystem must be adapted accordingly (Seidel et al., 2012).
5. Compatibility with upstream/downstream systems, including industry developed systems,
and with other countries’ systems, should be considered, where relevant (ITTO, 2012).
Transparency and security
6. Security measures required for systems and additional verification methods need to bechosen according to the local/national context. Additional verification methods may benecessary if instances of fraud encountered are high (Seidel et al., 2012).
7. A certain level of confidentiality and data security needs to be maintained in timber tracking
systems to maintain confidence and ensure that all suppliers participate (Seidel et al., 2012).

55

8. Countries should ensure relevant information (transport authorisations, Customs clearances,etc.) from tracking systems is made available in a transparent manner (e.g. user-friendly webbased systems) (ITTO, 2012).
Technology
9. Timber tracking technologies must suit local communication infrastructure, be robust andabuse resistant, cheap, effective and user-friendly (Helveta, 2012, in ITTO, 2012).
10. The level of technology used must be appropriate to each individual country/industry andadequate capacity building needs to be undertaken to ensure sustainability and local
ownership of the system after any pilot phase (ITTO, 2012). It is important to ensure that
adequate capacity exists before adopting technologically advanced systems (ITTO, 2012).
11. Timber tracking systems using bar codes and handheld PCs for data capturing processes are
well-developed and have reached the operational stage in forestry and many other sectors.
This standard method should be considered before moving to more advanced methods(Seidel et al., 2012).
12. New technologies such as DNA and isotope analysis can help to verify the accuracy of
information in tracking systems (Johnson, 2013).
13. Whichever tracking system is employed, the system should be open to upgrading as
improved technologies become available (ITTO, 2012). Electronic tracking systems need tostay up to date and incorporate new technologies in order to remain compatible with state of
the art software and technological developments (Seidel et al., 2012).
Costs and incentives
14. The costs and effectiveness of any tracking system to be deployed must be assessed closely.
Electronic tracking systems are generally expensive and external funds are often required toestablish infrastructure in tropical timber producing countries (ITTO, 2012).
15. Incentives could be considered for the establishment of tracking systems. These include tax
incentives, legal requirement for tracking systems, support for smallholders, and priority
recognition of companies with tracking systems in licensing processes (ITTO, 2012).
Stakeholders
16. Implementing a timber tracking system requires many stakeholders to accept changes inpractices to incorporate a new way of handling timber and timber products (Seidel et al.,2012). Prior to deploying a system, consultations must be held with relevant stakeholders inorder to come out with a common workable system. Particular attention must be paid tochallenges faced by smallholders in understanding and implementing such systems (ITTO,
2012).
Governance
17. Timber tracking systems cannot overcome weak governance. If legal systems are weak,timber tracking systems alone will not be able to reduce fraud and combat illegal logging(Seidel et al., 2012)

56

5. Assessment of the use of traceability systems forcommodities of CITES Appendix II-listed shark species
5.1. Traceability systems and sharks
5.1.1. Role of traceability in supporting CITES implementation for shark species
listed in CITES Appendix II
At CoP16, the CITES Parties agreed to list the following seven species of shark and ray in
CITES Appendix II: Oceanic Whitetip shark Carcharhinus longimanus; Porbeagle Lamna nasus;
Scalloped Hammerhead shark Sphyrna lewini, Great Hammerhead shark Sphyrna mokarran, andSmooth Hammerhead shark Sphyrna zygaena (collectively, the “Hammerheads”); and the Manta
rays Manta birostris and Manta alfredi. These listings came into force on 14 September 2014, joining
the Basking Shark Cetorhinus maximus (listed in 2003), Whale Shark Rhincodon typus (listed in 2003)
and Great White Shark Carcharodon carcharias (listed in 2005) in CITES Appendix II. It is notedthat the Sawfish family, Pristidae, are all listed in CITES Appendix I, which prohibits commercial
trade.
Under Article IV of CITES, an export permit must be issued by the Management Authority of
the State of export for the international trade in products of the shark species listed in CITES
Appendix II. As discussed above, an export permit cannot be issued until the Management
Authority has advised that the specimens were legally acquired, and the Scientific Authority of
the State of export has developed an NDF. In the case of specimens caught on the high seas (i.e.
areas outside of the jurisdiction of any State), specific provisions ("Introduction from the Sea")
are set out in Articles IV.6 and 7 of CITES and Resolution Conf. 14.6 (Rev. CoP16):


An NDF is required for specimens landed in the State to which the vessel is flagged (FlagState), in order for the Management Authority of the “State of introduction” (Flag State) togrant an Introduction from the Sea (IFS) certificate. Also the State of Introduction shouldtake into account whether or not the specimen was or will be acquired and landed: i) in amanner consistent with applicable measures under international law for the conservation andmanagement of living marine resources, including those of any other treaty, convention or
agreement with conservation and management measures for the marine species in question;and ii) through any illegal, unreported or unregulated (IUU) fishing activity;
For specimens landed in a different State to the Flag State, the provisions of Article III,
paragraphs 2 and 3, or Article IV, paragraphs 2, 3 and 4, respectively, should be applied. Thismeans, as in a "normal" import-export trade transaction, an NDF and a legal acquisition
finding will be required in order for the Management Authority of the Flag State to issue anexport permit (Mundy-Taylor et al., 2014).

As described in Section 3 above, traceability can assist national CITES authorities in determining
the legal acquisition of a shark specimen intended for international trade and in the developmentof an NDF:In the context of a legal acquisition finding, a traceability system can link a specimen to beexported with a “legal origination process”, defined as a legal procedure, such as a landing
certificate, which creates a document trail to prove the legal origin of the raw material (Lehret al., 2015). A robust system of traceability reduces the likelihood of illegally harvested
product entering legal trade (Willock, 2004).
In the context of NDF development for shark commodities, a traceability system not onlyoffers the possibility of linking a specimen to the area of production/harvest (e.g. FAO or
ICES catch area, if reported correctly), but also for using trade statistics as a proxy for catch
volumes per area (Lehr et al., 2015), which may be useful where catch data (or fisheries57independent data) are not available to assess the severity of fishing pressure on the stock of
the shark species concerned (Mundy-Taylor et al., 2014).
In addition, traceability systems implemented for CITES species offer an opportunity to gather
specific information that can be fed back for the purposes of adaptive management and tostrengthen future NDFs for the species, in line with the recommendations of the 2008
International Expert Workshop on CITES NDFs in Mexico38. In some circumstances when an
NDF is issued, conditions may be set to gather more information through the permitting
process, for example, on catch quantities, location of catch, etc. The collection of samples during
the tagging/labelling process (as part of a traceability system) can allow for more accurate
information to be obtained on species, sex ratios and ocean from which the individual wascaught, through application of new DNA and isotope techniques. Close-kin DNA techniques
also allow for estimates of abundance to be determined (for many shark species there are no
current estimates of abundance).39
While traceability has applications for both legal acquisition findings and NDFs, the main
objective of a traceability system implemented in support of the CITES shark listings is to reduce
the risk of illegal material entering into legal chains (Lehr et al., 2015). Traceability can also
support monitoring and control throughout the trade chain, for example, facilitating Customs
verifications and inspections.

5.1.2. Traceability of wild-caught fish productsThis section considers a number of principles that can guide the design of robust traceability
systems for wild-caught fish (seafood) products. These will provide a framework for the analysis
of application of CITES traceability schemes to shark products in Section 5.2.2.
In addition, recent initiatives have defined principles and (draft) best practice guidelines to beconsidered when establishing traceability systems for supply chains for wild-caught fish products
and should be consulted for more detailed information:







Lehr, H. et al. (2015). Traceability study in shark products. Report prepared for the CITES
Secretariat.
Draft best practice guidelines for traceability – presented at the Fourteenth Session of the
FAO Committee on Fisheries (COFI) Sub-Committee on Fish Trade (COFI:FT) (Bergen,
Norway, 24-28 February 2014). Available at: http://www.fao.org/cofi/295100d3ea0e690044579673debe9c27579459.pdf. The recommendations aim to assist operators in
the creation of reliable, simple, clear and transparent traceability systems.
Recommendations for a Global Framework to Ensure the Legality and Traceability of WildCaught Fish Products – Final Report, March 2015. Prepared by the Expert Panel on Legal
and Traceable Wild Fish Products, a multi-disciplinary expert group convened by WWF.
Available at: http://solutions-network.org/site-legaltraceablefish/
Traceability Principles for Wild-caught Fish Products. WWF, April 2015. Available at:https://www.worldwildlife.org/publications/traceability-principles-for-wild-caught-fishproducts

The design of a traceability system for wild-caught fish products will vary depending on therequirements of a particular product or context. However, three principles effectively summarise
the core elements necessary for the efficient implementation of any traceability system: (i) unique
identification; (ii) data capture and management; and (iii) data communication. These principles
38 Fishes Working Group. See:

http://www.conabio.gob.mx/institucion/cooperacion_internacional/TallerNDF/taller_ndf.html
39 Kinship between individuals of the same species may be used as an indicator of stock abundance, which could
particularly assist with the NDF process for shared stocks (C. Davies, CSIRO, pers. comm., 2015). See, for example:
http://frdc.com.au/research/Documents/Final_reports/2007-034-DLD.pdf

58

provided the framework for a recent FAO analysis of traceability practices in the seafood sector(Andre, 2013), which informed the development of the above draft best practice guidelines(FAO, 2014). Further discussion is also provided in Lehr et al. (2015).

Principle 1: Unique identification
Traceability systems require that any unit in the supply chain be uniquely identified. The
definition of a unit may vary between products. A unit may refer to an individual specimen or a
lot or batch (defined quantity produced at a certain time and placed in a uniform manner –Peterson and Green, 2007). The identification format should be clearly defined, bear somemeaning, be verifiable and should accompany the product at all times, for example, on the label,packaging, container or accompanying document. The size of the traceable unit (e.g. one shark or
several sharks) is commonly called the precision of a traceability system (Lehr et al., 2015).
Any actor (operator) in the supply chain that modifies the product or may have an impact on the
product (e.g. by mixing or splitting the lots) must also be uniquely identified. The identification
format should again be meaningful, and may take the form of a production licence or other formof authorization, which could be integrated into wider registration/licensing procedures.

Principle 2: Data capture and management
Reliable and comprehensive data must be captured and recorded along the supply chain, andthroughout multiple product transformations, such as splitting and mixing of lots, or discardingof parts of lots (as is common in food supply chains). This includes data capture within an
organization, e.g. during processing (internal traceability system), as well as data capture, management
and communication between steps of a supply chain (external traceability system). A system of data
capture and management may be established by an individual operator, by a group of uniform
operators, or by operators along an entire supply chain.
Key Data Elements (KDEs) refer to the essential information from a traceability perspective thatneeds to be captured along a supply chain. The precision and amount of data to be captured will
depend on the purpose of the traceability system and needs for documenting compliance withlegal requirements (see UN/CEFACT FLUX Project 40 ). Nevertheless, minimum information
standards for wild-caught fish products have been recommended, which cover the “who, what,
where, when and how” of fishing, including primary information about vessel registrations,fishing licences and catch documentation sufficient to provide strong evidence of legality (Expert
Panel on Legal and Traceable Wild Fish Products, 2015).
Critical Tracking Events (CTEs) are the points along a seafood supply chain at which fish products
change form, location or ownership, and identify the stages at which capture of KDEs is vital toa successful traceability process (Expert Panel on Legal and Traceable Wild Fish Products, 2015).
Traceability requires that KDEs recorded at the beginning and end of a transformation process
link inputs to outputs (Lehr et al., 2015).
An overview of KDEs and CTEs for seafood traceability is provided in Figure 10.
Mechanisms for verifying the reliability of data captured at each CTE are also essential for
ensuring the robustness of any traceability system. The type of traceability solution selected, e.g.
paper-based, semi-electronic or fully electronic, will affect the degree of accuracy with which a
product’s movements or characteristics can be identified and the amount/frequency ofverifications required to ensure the data captured and communicated are reliable. Paper records
maintained at an individual operator level may be sufficient to comply with minimum
requirements, however the data captured may be more difficult to verify and more prone to40

http://www1.unece.org/cefact/platform/display/CNP/Electronic+Interchange+of+fisheries+catch+data

59

error. In the case of more detailed/rigorous requirements, more sophisticated systems
guaranteeing ease of verification and reliability of data may be needed (FAO, 2014).
Figure 10: Critical Tracking Events for Seafood Traceability

Source: Expert Panel on Legal and Traceable Wild Fish Products (2015), adapted from National FisheriesInstitute (2011). For more detailed information about CTEs and KDEs relevant for documenting legality of caught andlanded fish see the Expert Panel’s Recommendations for a Global Framework to Ensure the Legality and Traceability of
Wild-Caught Fish Products, March 2015 (available for download at: http://solutions-network.org/site-legaltraceablefish/)

There are three general approaches to seafood traceability: paper-based, basic electronic andintegrated hardware traceability systems (Anon, 2015).


Paper-based traceability: manual paper-based records of the source, transformation,
aggregation, destination and other associated information related to seafood products fortraceability purposes.
Basic electronic traceability: computerized record keeping of the source, transformation,
aggregation, destination, and other associated information related to seafood products fortraceability purposes.
Integrated hardware traceability: integrated hardware (e.g. bar codes and reader, radiofrequency identification (RFID) tags and scanners) implemented to capture the source,transformation, aggregation, destination and other associated information related to seafood
products for traceability purposes. RFID tags are physical carriers of electronic data, which
are scanned using radio waves to automatically identify individual items (Anon, 2005, cited in
Knuckey et al., 2014).

The advantages and disadvantages associated with each of these approaches are summarized inTable 4. For electronic approaches, it is noted that the ease of tracking and verifying the data
captured will further depend on the type of database system used to process and store the data
(i.e. whether a multi-database or single database system). Further details are provided underPrinciple 3 below.

Principle 3: Data communication
Data captured by various actors in the supply chain must be transferred and accompany thephysical flow of products. Data should be exchanged in a standardized format, which may be
specified by a standard or regulation (e.g. labelling requirements, catch certificate).

60

There are two types of supply chain traceability information flow models.


The one step up-one step down information flow model and requires that operators are able to trace
one step before and one step after their own operation (FAO, 2014). It is the model mostcommonly used in food businesses (Folinas et al., 2006); however, the final receiver of a
product cannot easily or simply trace a product back to its source using this model.
Operators in the supply chain are responsible for their own data, which may be stored on
paper or electronically (Lehr et al., 2015). Electronic storage of data takes place in individual
databases throughout the supply chain – a multi-database system (Figure 11). Multi-databasesystems allow each operator to retain full control over their data; however, differences instandards of record keeping can present difficulties for communication between links in the
chain (Peterson and Green, 2007).

An aggregated information flow model is used in cases where it is necessary to have immediate
access to information related to all stages of production, treatment and distribution. Data are
stored either in a central (single) database or by accumulating traceability records along the
supply chain (Lehr et al., 2015). In a single-database system, all operators in a supply chain
submit their data to a single database, which can accessed as and when required (Figure 12).
The use of a common standard makes information retrieval easier and faster between various
links in the supply chain; for example, stakeholders may access data via a web-based platform(Peterson and Green, 2007).

61

Table 4: Overview of advantages and disadvantages of approaches to seafood traceability
Paperbased
traceability

Basicelectronic
traceability














Integrated
hardwaretraceability











Advantages
Widespread and well-established in supply chains (know-how and systems may already exist
for implementation)
Require lowest level of technology (little to none)
Inexpensive to implement
Flexible, easy to modify
Can be improved through tagging of products with unique identifiers (physical tamperprooftags) and inclusion of unique identification information in paper records

Efficient data storage
Enables easy transmission of data, including to other links in supply chain
Records, report and queries can be made quickly and adapted to the situation
Facilitates tracking of product throughout supply chain, including to consumer via web-based
systems (if central database)
Facilitates verification of data
Can be improved through tagging of products with unique identifiers (physical tamperprooftags) and inclusion of identification information in electronic system
Efficient data storage
Enables easy transmission of data, including to other links in supply chain
Records, report and queries can be made quickly and adapted to the situation
Facilitates tracking of product throughout supply chain, including to consumer via web-based
systems (if central database)
Facilitates verification of data
Automated data capture faster and less prone to human error
Real-time availability of information
Systems are frequently interoperable1
RFID tags usually small, do not have to be in line of sight (multiple products can be scanned
whilst passing through reader area)











Disadvantages
Can be inefficient and require too much storage space for large quantities of product(viable for small quantities of product only)
Often no common identifier that is consistent throughout supply chain (e.g. productdescription, inconsistent terminology – lots, batches, pallets, etc.)
Manually intensive, data entry prone to errors
Delay in data entry makes systems prone to fraud
Trace-back, review and verification of data time-consuming/difficult
May not be appropriate for complex supply chains (e.g. involving multiple vessels,
products, and outlets).
Consumers/retailers may lack confidence in system
Data entry prone to errors (not an automated system)
May not address issue of common identifiers through supply chainData still needs to be standardized across supply chain (particularly product andlocation codes)
Need for relatively expensive equipment (readers, computer systems, software)
Bar codes
Generally scanned by humans, therefore some room for error
External traceability can be hampered by use of proprietary numbers in bar codes (i.e.
not meaningful to operators down-stream in supply chain)Must be positioned “in line of sight”
RFID
Generally more expensive than bar code systems2

Source: Knuckey et al. (2014), Peterson and Green (2007), Anon (2005) (cited in Knuckey et al), Anon (2015), Regattieri et al. (2007)
Notes:
1. Meaning that “different information technology systems and software applications [can] communicate, exchange data, and use that information” (Global Food Traceability Centre, 2014, cited inAnon, 2015)
2. Although costs will decrease as technology advances (Peterson and Green, 2007)

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Figure 11: A multi-database system

Figure 12: A single database system

Source: Peterson and Green (2007)

5.1.3. CITES shark products and generalized supply chains
Sound knowledge of a product’s supply chain is a prerequisite for implementing an effective
traceability system. This requires identification of all physical entities (and locations) in the chain(Regattieri et al., 2007), and processes taking place at each step.
A simple representation of a generic fresh fish supply chain begins with capture at sea, somedegree of processing onboard the vessel, and storage in a refrigerated onboard hold or ice slurry.
At the port of first landing, the catch is unloaded and transferred to a refrigerated vehicle where
it is transported by road to a land-based wholesaler/processer for further processing, filleting andpackaging. The product is then distributed by refrigerated vehicle to the final entity, being a
retailer or restaurant (Knuckey et al., 2014).

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In reality, however, the supply chains for wild-capture fisheries are far more complex thandescribed above. The chain begins with a fleet of different fishing vessels catching multiple
products (species), which go onto unload at multiple ports from which catches are transported todifferent markets, wholesalers and processers. These entities convert the product into multiple
forms, before distribution to a variety of restaurants, retail and food service outlets bothnationally and internationally. The situation with shark fisheries is further compounded by therange of products that can be derived from a single shark, each with a potentially different supply
chain (Knuckey et al., 2014). Furthermore, products such as shark fins may be bought and soldmultiple times, before being exported for the first time (Chen, 1996).
There are six major categories of products derived from sharks: meat, fins, liver oil, cartilage, skinand teeth (Knuckey et al, 2014). While shark fins and meat are the two most traded commodities(Dent and Clarke, 2015) quantities of liver oil, cartilage, skin and teeth are thought to be underrepresented in trade statistics, which generally do not distinguish these products as deriving fromsharks (Clarke, 2004). Manta rays are targeted and retained as valuable secondary catch to supply
the international gill raker trade (Mundy-Taylor and Crook, 2013).
The shark products listed above are each associated with significantly different uses, processing
techniques, supply chains and distributions (Knuckey et al., 2014; see also Figure 13). These giverise to different challenges for traceability, and a variety of solutions may be needed dependingon specific product requirements and contexts.
In view of the numerous permutations in the supply chains for shark products, the analysis anddiscussion in Section 5.2 of this report focuses primarily on the traceability of meat and fins of
the shark species listed in CITES Appendix II, as these represent the bulk of trade in these
species. The report further focuses on the shark species listed in CITES Appendix II at CoP16,
as they present some of the greatest challenges from a traceability perspective, owing in part tothe commercial scale of international trade in their commodities41.
It is, however, noted that shark product supply chains share some commonalities, particularly inthe earlier stages, from capture to first landing (see Figures 13 and 14). Therefore, many of thelessons learned and best practices identified in this report for the initial stages of meat and fin
supply chains may apply equally to other shark commodities. Future work may include anextension of this review to include other shark commodities/species, if considered
useful/appropriate. For example, lessons learned from implementing the caviar labelingrequirements may be relevant for the labeling of shark liver oil traded in capsule form.
Below is a brief overview of key trade routes and supply chains for meat and fins of CITES
Appendix II-listed species based on a high-level review of relevant literature. For further details
see Dent and Clarke (2015), Mundy-Taylor and Crook (2013), the CITES CoP16 listing
proposals for Oceanic Whitetip, Porbeagle and Hammerheads (2013), the IUCN/TRAFFIC
analyses of the CoP16 listing proposals (2013), Clarke (2004), Vannucini (1999) and Parry-Jones(1996).

41 For example, information from traders indicates that fins of Basking Shark, Whale Shark and Great White Shark aretraded more as trophies for display than for consumption due to the lower quality of the fin needles (Clarke, 2004).

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Figure 13: General shark processing flowchart (shark landed with fins attached)

Source: adapted from Vannuccini (1999).
Notes: * The skin of fins, like that of the rest of the body, is covered with large numbers of usually verysmall thorn-like structures called denticles.

65Figure 14: Simplified shark supply chain

Source: from Lehr et al. (2015)(a) Meat
Trade routes
Shark meat is traded in large quantities globally, with key markets in Europe (e.g. France, Italy
and Spain), Brazil, Mexico and mainland China (and Republic of Korea for skates and rays)(Dent and Clarke, 2015; Mundy-Taylor and Crook, 2013). Uruguay has emerged as an important
trader of shark meat in recent years, importing unprocessed meat from major shark catchers(such as Taiwan and Spain) and re-exporting processed shark meat to the rapidly expanding
Brazilian market (Dent and Clarke, 2015).
As regards trade routes for meat of the CITES Appendix II-listed species:
Porbeagle meat is highly valued by consumers in Europe, where it is traded in fresh and frozen
form (Mundy-Taylor and Crook, 2013). Porbeagle is taken in both targeted fisheries and as
secondary catch, particularly in pelagic longline fisheries for tuna and swordfish, but also in gillnets, driftnets, trawls and handlines. Key catchers include Japan, New Zealand, Republic ofKorea, Spain, Taiwan and Uruguay. In the Southern Hemisphere, Porbeagle is primarily taken on
the high seas, therefore IFS provisions will apply. In the Northern Hemisphere, most Porbeagle
is harvested within Exclusive Economic Zones (EEZs) (Mundy-Taylor and Crook, 2013).
Oceanic Whitetip meat is reportedly eaten in fresh and smoked forms in Mexico and the US; andin fresh, dried and salted forms in the Seychelles and Sri Lanka (CITES CoP16 Proposal).
Oceanic Whitetip is taken in many parts of its range, primarily as secondary catch in oceanic
longline fisheries targeting large pelagic species (tunas, swordfishes and others) (FAO, 2013). Key
catchers of Oceanic Whitetip, according to FAO data, include Sri Lanka, mainland China, Brazil,
Taiwan, Fiji and Tanzania (FAO FishStat, total capture 2002-2011, cited in Mundy-Taylor andCrook, 2013), while other countries/territories that are known to take Oceanic Whitetip as
secondary catch in their fisheries include France, Japan, Spain, Uruguay and the US. Oceanic
Whitetip is often taken on the high seas, therefore IFS provisions will apply (Mundy-Taylor andCrook, 2013).
Hammerhead meat is also traded internationally; however it is unlikely that the amount issignificant when compared to the volume of fins in trade (CITES CoP16 Proposal).
Hammerhead meat is reportedly consumed in Mexico and in many other parts of Latin America(Sosa-Nishizaki, in litt. to IUCN/TRAFFIC, 2012, cited in IUCN and TRAFFIC, 2012), and alsoin Europe, Japan and elsewhere (CITES CoP16 Proposal). Owing to their wide distributions and66

coastal-dwelling nature, Hammerheads are exploited along continental shelves and adjacentoceanic areas in a vast number of countries, in both tropical and warm temperate seas.
Hammerheads are taken in targeted fisheries and as secondary catch in fisheries for pelagic anddemersal species (FAO, 2013). As Hammerheads are primarily taken in EEZs, IFS provisions
will generally not apply, but will in some circumstances (Mundy-Taylor and Crook, 2013).

Supply chains
The generic stages of a shark meat supply chain are described in Table 5 below (see also Figure
13).
Table 5: Stages of a generic shark meat supply chain
LocationFishing vessel

Landing port/landbased processor

Production facility

Main activities/processes
Shark is trunked (head removed and gutted) and stored on ice or
chilled brine (refrigerated sea water) or frozen on the vessel. Fins may
be separated or remain naturally attached, depending on relevant
requirements. The shark may also be filleted and stored onboard as
dried product. Transshipment to another vessel (or vessels) may takeplace before landing.
The carcass is typically weighted and separated into different productcategories (e.g. meat, liver, fins, etc.). The trunk may be processed at
this stage, whereby the meat is removed from the cartilage frame andskinned. Shark meat is usually prepared as whole frozen carcasses(headed and gutted) for storage and shipment, but also as freshcarcasses, and fresh/frozen split carcasses, fillets and blocks.
The carcass is generally filleted, frozen or packaged at this stage, or
minced and made into surimi and packaged. The products are thendistributed and held in cold storage until dispatched to restaurants orretail stores.

Source: Vannuccini (1999); Knuckey et al. (2014)(b) Fins
Trade routes
Shark fins are the most valuable shark commodity per unit weight. The commercial value of a fin
is dependent on a number of factors, including the percentage yield of ceratotrichia (soft collagenand elastin fibres commonly known as fin needles), general appearance and texture (Chen in
Vannuccini, 1999). Separately, or joined as a bundle, the fin needles are considered a delicacy inChinese cuisine, used in soup-making and other dishes (Vannuccini, 1999).
The vast majority of fins are destined for consumption in a relatively small selection ofcountries/territories in East and Southeast Asia, including mainland China, Hong Kong Special
Administrative Region (SAR), Taiwan, Singapore, Malaysia and Viet Nam (Dent and Clarke,2015).
Hong Kong serves as an international trade hub for shark fins, importing large quantities fromproducing countries in (wet and dried) unprocessed forms, and exporting them to regional
markets, where they are generally processed before consumption. Fins commonly arrive in Hong
Kong by sea, and are transported onwards to processing facilities in Guangdong Province,
mainland China, by river barge (Clarke, 2004). After processing, fins may be consumed inmainland China, or transported back to Hong Kong for consumption or re-export (Clarke,
2004). Taiwan is also involved in importing, processing and trading fins (as exports and reexports) (Dent and Clarke, 2015).

67

Singapore plays a similar role to Hong Kong as a regional trading centre, although it is also
believed to be involved in processing to some extent. Recent figures suggest that the shark finmarkets in Thailand, Malaysia and Japan are also significant, primarily for small, low-value fins.
Thailand has also surpassed Hong Kong as the world’s largest exporter of shark fins in recent
years (Dent and Clarke, 2015). These developments suggest a decline in dominance of mainland
China and Hong Kong in the international shark fin trade.
As regards fins of the shark species listed in Appendix II of CITES (from Mundy-Taylor andCrook, 2013):
Oceanic Whitetip is a preferred species in many fin markets, including in Hong Kong
(Vannuccini, 1999). See (a) Meat – Trade routes above for an overview of patterns of
exploitation.
Porbeagle fins are generally less valued than fins of other species due to their low needle count(IUCN and TRAFFIC, 2012). Porbeagle is not one of the common species in the Hong Kong
dried fin market, possibly as most fins in the market derive from areas other than those where
Porbeagle is most abundant (Northeast and Northwest Atlantic) (Clarke et al., 2006). However,
Porbeagle fins are still exported from New Zealand to Hong Kong and also from Norway to
Asian markets as secondary products of meat processing.
Hammerhead fins, and particularly those of the Scalloped Hammerhead, are highly valued ininternational trade because of their large size and high fin needle count (IUCN and TRAFFIC,
2012). See (a) Meat – Trade routes for an overview of patterns of exploitation.

Supply chains
Shark fins are processed and marketed in a variety of forms, the most important being(Vannuccini, 1999):
 Raw fins - in dried form only, with skin (most common). Dried fins from larger sharks are
traditionally traded as fin sets comprising the two pectoral fins, the first dorsal fin, and thelower lobe of the caudal (tail) fin (Parry-Jones, 1996). A complete set from the same shark ispreferred. Other fins are of lower commercial value and sold as mixed fins or fin nets after
processing (Subasinghe, 1992).
 Wet fins - fresh, chilled and unprocessed Semi prepared fins - dried, skin removed, fin needles still intact as one dry mass
 Fully prepared fins - dried, with individual strands of fin needles, and packed in cardboard
boxes or in a single or double layer of viscose film Frozen prepared fins
 In brine Fin nets – fin needles boiled, separated, redried and packaged in loose groupings Prepared ready to eat or cooked products – canned soups, prepared dishes in cans or pouches
and instant soup powders.
The method of processing a shark fin generally depends on the level of infrastructure and postharvest technology available in a fishery. Higher quality fins are those kept fresh, clean andunsalted before drying; however, where infrastructure is lacking, salt is used in preservation
resulting in an inferior product with higher moisture content (Vannuccini, 1999).
Supply chains for shark fins are complex and global in nature, involving multiple countries
between fishing vessel and end consumer (Dent and Clarke, 2015). Fins may be bought and soldnumerous times prior to export and during later stages in the supply chain (e.g. by importers,
retailers, wholesalers and restaurants).

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The generic stages of a shark fin supply chain are described in Table 6 (see also Figure 13).
These stages are most characteristic of industrial and larger-scale artisanal fisheries, operating indeeper waters in EEZs and on the high seas. By contrast, shark fin supply chains for traditionaland smaller-scale artisanal fisheries are relatively diverse, often with specific characteristics
depending on country or region. These supply chains generally involve many operators at eachlevel, may operate in remote locations and can be relatively fluid, as demonstrated by Cripps et al.
(2015) in a recent value chain analysis of the shark fisheries of Madagascar (see Figure 15).
Table 6: Stages of a generic shark fin supply chain
LocationFishing
vesselLanding
port
Regional/
international
trade hubProcessing
centreMain activities/processes
Once a shark is caught, the fins may be removed and stored separately from thecarcass (or the carcass discarded) or left attached to the trunk and removed later
during land-based processing. Freshly cut fins are cleaned well and: kept on ice for several days with re-icing if necessary (fresh/wet fins) hung or stored around the vessel to start the drying process (especially if
fishing operations are long) or oven-dried if sun-drying is not possible(dried fins)
Fins removed from carcass (if landed attached) and dried or frozen.
Unprocessed fins are sold to dealers or intermediaries and may be graded (seenext stage) before export.
Importers/traders grade fins by type, size, as black or white42 and other factors
such as moisture content, smell and cut, according to market requirements. Fins
may also be traded in lots. Fins may be processed by traders (e.g. restaurants) or
re-exported for processing elsewhere.
 Fins are softened in water, denticles removed, skinned and themeat/cartilaginous base plate removed. Fins may be dried in this form, or
the two layers of gelatinous fin rays may be separated into two bundles
before drying.
 Fins may also be further processed into fin needles or fin nets. Processed
fins are softened, boiled and transferred to chilled water to separate finneedles from the gelatinous fin ray membrane. Washed, wet fin needles may
be arranged into fin nets and sun-dried.
 Products may be re-exported or distributed to local markets

Source: Parry-Jones (1996), Chen in Vannuccini (1999), Vannuccini (1999)

42 Black group – deeper water sharks, such as Carcharhinus spp., mako, blue sharks. White group – shallow water sharks,

such as sandbar and hammerheads (Vannuccini, 1999). Fins of the white group are associated with higher percentage
yields of fin needles, and command higher prices.

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Figure 15: Shark fin supply chain for sharks caught in Madagascar’s traditional fisheries(Cripps et al., 2015). For traditional shark fisheries, the trading routes and number of linkages within supply
chains for fins can vary considerably depending on fisher location (proximity to urban centres), price, buyer
availability, personal contacts or know-how of individual fisherman, demand and product condition. Most fishers
sell salted, wet (undried) fins to local collectors (to obtain a higher price per kg), who then dry the fins to meet buyer
specifications and sell them on to regional collectors/traders. However, some fishers with the means to travel,
contacts and know-how sell dried fins directly to main buyers in larger towns, or occasionally to regional traders,increasing income by almost 40% for the highest quality fins. Dried fins are exported to overseas markets such as
Hong Kong SAR (Cripps et al., 2015).

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5.1.4. Issues to be considered for the traceability of CITES shark commodities
Any traceability system implemented to support CITES implementation for shark commodities
must consider the issues listed below.
Pre-landing Multiple species caught by vessels, including CITES-listed and non-listed species
 CITES-listed species taken from multiple catch areas on a single fishing trip
 Transshipments at sea of CITES-listed products (particularly complex if the vessels are
owned by different operators)
 Methods of storage and processing onboard vessels, and possibility for product segregation(separation of CITES listed and non-listed species) Feasibility of physical marking individual/batches of CITES specimens
 Physical conditions that could impact a traceability system (e.g. tracking technology affectedby moisture) Current recording practices onboard vessels (e.g. electronic vs. paper-based logbooks)
 Appropriate level of technology/technical infrastructure Hardware/software needed to meet defined traceability requirements
 Available financial resources Information necessary for assessing compliance with legal requirements (KDEs)
Post-landing Form and quantities in which CITES-listed species are landed and distributed
 Critical Tracking Events (CTEs)
 Processing/product transformations, including mixing and aggregation (species, multiple
vessels etc.), and possibility for product segregation
 Ability of operators to confidently identify specimens
 Feasibility of physical marking individual/batches of CITES specimens Ability of physical marking to withstand processing Current recording practices of operators
 Existing port controls and CITES requirements upon landing in ports
 Appropriate level of technology/technical infrastructure Hardware/software needed to meet defined traceability requirements
 Available financial resources Information necessary for assessing compliance with legal requirements (KDEs)
 Opportunities/prospects for collaboration between operators along the supply chain71

5.2. Application of CITES traceability measures to shark commodities
The aim of this section is to assess whether the measures considered in Section 4 can be appliedin whole or in part, whether individually or in combination, to the traceability of fins and meat of
the shark species listed in CITES Appendix II at CoP16. The reasoning for focusing on these
specific shark commodities was outlined in Section 5.1.3. above.

5.2.1. General observations
From the review of traceability measures carried out in Section 4, it would seem that none of thefour case studies examined would offer an easily transferable solution for the traceability of meator fins of Oceanic Whitetip, Porbeagle or the three Hammerhead species listed in CITES
Appendix II at CoP16. However, there are many commonalities in the lessons learned from thesecase studies, which can provide useful guidance in developing traceability systems and measures
for CITES shark commodities.
Table 7 compares the products, supply chains and traceability measures implemented or underconsideration/development for sturgeon caviar, crocodile skins, Queen Conch and timber.
Relevant information is included for sharks, where possible, to facilitate an assessment of theapplicability of the various traceability measures considered in Section 4 to the products andsupply chains of CITES shark commodities.
The table highlights a number of specific aspects of shark meat and fin supply chains which
would make the direct application of the traceability systems reviewed in Section 4 either
unfeasible or inappropriate. These include the mixing of CITES and non-CITES shark species
onboard vessels and at points of landing, partial processing at sea, capture on the high seas, andexports of products in a range of different forms/stages of processing. The variety of possible
supply chains, e.g. for artisanal vs. industrial fisheries, adds a further layer of complexity.
By comparison, in the case of caviar labelling, both product and packaging are relatively uniform,
the operators are limited in number and easily defined, there is little variation in supply chains,and processing occurs on land, close to the point of harvest, at which stage a label is applied tothe product and no further processing takes place. Likewise for crocodile skin tagging, theexported product is again relatively standard (whole skins) and amenable to being physicallytagged, in contrast to the smaller fins and processed meat products of CITES shark species thatare commonly exported. For further comparisons see Table 7.
Nevertheless, the four case studies considered in Section 4 provide useful guidance for thedesign and implementation of effective traceability systems that are compatible with CITES
requirements and processes. Table 8 provides a summary of some of the main lessons learned
and best practices arising from these case studies for the traceability of CITES sharkcommodities, with commonalities between the case studies listed under Common issues.
Queen Conch, as the only marine fisheries example, provides some particularly useful insights
into regional cooperation on the conservation and management of a CITES marine species,
including on traceability issues. Systems are also being implemented at the national level which
could potentially be scaled-up or replicated elsewhere, for other marine species. Of particular
relevance to sharks are the approaches being implemented/considered to improve traceability inartisanal fisheries and for processed meat products, such as electronic data collection andmanagement systems, catch documentation schemes, standardization of processed meat
conversion factors and incentives for data collection and reporting. While there are importantdifferences between fisheries for Queen Conch and sharks (see Table 7), it would be useful tofollow the progress of these developments for possible guidance for shark commodities.

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A common theme emerging from across the four case studies, is the need to strike a balance
between establishing minimum standards/universal guidelines for traceability systems (e.g. toensure interoperability of systems, coherence and compliance with legal requirements) whilst
affording operators and Parties flexibility to implement systems that are well-adapted to their
specific contexts (e.g. in terms of level of technology, available resources and capacity of users).
The lack of universal standards has allowed for the proliferation of different systems, which are
not necessarily interoperable. As noted in Table 8, traceability systems and technologies should
be appropriate to particular supply chains and take into account local communication
infrastructures, technological capacities, physical conditions, internal systems and businesspractices. Above all, systems should be simple, user-friendly, cost-effective, inclusive, transparent
and robust.
As in the case of timber, the complexity and variety of supply chains for shark meat and fins isparticularly pronounced (see Table 7), and building flexibility into systems will be even morecrucial. However, the experience of timber has also shown how “off the shelf” traceability
solutions can provide readily deployed, flexible systems that may be scalable to cover all types ofsupply chain and customized to meet specific requirements. These are already used and available
for a wide variety of commodities, including fisheries products, and further exploration of theirapplication to commodities of CITES-listed shark species is warranted.
For a more comprehensive list of lessons learned and best practices emerging from the four casestudies, see Table 8.

5.2.2. Possible elements of a traceability system for commodities of CITES-listed
shark species
Before embarking on the design and implementation of a traceability system for supply chains of
CITES shark commodities, there are a number of important steps that should be considered toensure that the system is widely accepted and appropriate to the specific context(s) to which it is
to be applied. These include
1. Considering at which scale a system should be established to achieve its objectives (e.g.
national, regional, global).
2. Mapping key product supply chains from point of harvest to, as a minimum, point of firstexport.
3. Identifying the data input and control points (i.e. where data entry and verification are
possible – e.g. “bottlenecks”), operators involved, and information to be collected at eachstage.
4. Identifying and consulting with stakeholders along the supply chain to determine a workable
solution. Issues to consider include barriers to participation, the need for incentives,
integration with existing systems and processes, cost/administrative burden andtechnical/logistical challenges.
5. Determine what improvements may be necessary to the monitoring, control and surveillance(MCS) systems and regulatory/enforcement regime(s) to support the effective
implementation of the traceability system.
The following sections draw on all four case studies reviewed in Section 4 to provide examplesof traceability options for the fins and meat of Oceanic Whitetip, Porbeagle and Hammerheads,
based on the lessons learned/best practices set out in Table 8 and the specific features of the fin
and meat supply chains (described in Section 5.1.3. and Table 7). The information below is notintended to be exhaustive or cover every possible scenario, but is intended to provide an exampleof how a simple traceability system might work for shark meat and fins, as a basis for further
research and discussion by the CITES Parties.
It is noted that the below options are more relevant to industrial fisheries or to more
technologically advanced artisanal fisheries operating in deeper waters in EEZs/on the high seas.
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Due to the diversity of supply chains and technological capacities for traditional and smaller-scaleartisanal fisheries (which may operate in remote locations and involve numerous individual
operators), further consideration of specific contexts would be required to determine workabletraceability solutions. These fisheries may face particular challenges in achieving traceability
objectives, and a stepwise approach to implementation may be required. Nevertheless, from thefour case studies, and from the example of Queen Conch in particular, it is possible to identify anumber of options that could be adapted for traditional/artisanal fisheries for CITES sharkspecies (see also Table 8 below):
1. Recording of basic information on shark catches by fishers using mobile phones, which could
be sent to a central system either via an app or by text message.
2. Introduction of a paper-based or, ideally, an electronic catch documentation scheme to link
catches to particular trips. Batches of fins may be allocated with a unique codes, linking themwith the vessel trips that landed the fins.
3. Allocation of licences/quotas to operators or entities that handle aggregated fins from many
vessels, e.g. processing plants, regional collectors, or fishing cooperatives, and requiring themto report information on purchased fins (training in the identification of fins of CITES
species may be required). Data could be provided in spreadsheets and emailed on a regularbasis to the fisheries authority for storage in a central database.
4. Provision of incentives to encourage data recording and reporting, e.g. preferential licences,certification schemes, provision of mobile phone technology and training.
Regarding the options for industrial fisheries, these are outlined below under the three
traceability principles: (i) unique identification; (ii) data capture and management; and (iii) data
communication (see Section 5.1.2.).

(a) Unique identification
A CITES-listed shark is caught and processed onboard the vessel into trunked form with fins on
to allow identification to species level. Each trunk is marked with a tamper-proof tag (e.g.
attached to the dorsal fin) which includes the vessel name and a unique identifier, preferably inbar code form. The tags are produced by authorized manufacturers and distributed only tolicensed vessels.
The trunk is then chilled or frozen and stored in the onboard hold. Ideally, no further processingof the product would be allowed during the land-based unloading, transport, trading and coldstorage of the trunked shark. Therefore, the product that is received at the land-based processor
is chilled or frozen shark trunks, each tagged with a unique identifier.
At the processor, the shark trunks would be processed into the component products (shark fin,shark meat etc.) and packaged. Each package would be labelled with a bar code or RFID thatrefers to the unique carcass tag information.
In situations where finning takes place onboard a vessel, fins should be grouped by CITES-listed
species and catch area (or as appropriate to allow verification of legal compliance) andmaintained as separate lots, e.g. in individual containers, and allocated a unique lot number (e.g.
date, container and hatch number). Each lot should be uniquely marked, e.g. the containerlabelled with vessel name and the unique lot number (preferably in bar code form).
Optimally, each lot of fins would remain as a discrete entity up to the point of repackaging forexport (e.g. as a batch of whole frozen or dried fins) and be accompanied by the unique identifier(bar code) affixed to the container onboard the vessel.
However, where this is not possible (e.g. a middleman receives many small batches of fins of thesame CITES-listed species but from different vessels/catch areas), aggregation of lots may beallowed provided that the operator records information about what was mixed and how the new74

mixed lot is now identified. Each package of mixed fins for export would be labelled with a new
unique identifier in the form of a bar code or RFID, which can be linked back to the original lots
and catch information via a central database (see under (b) Data capture and management
below).

(b) Data capture and management
Fishing vessels record catch information associated with each uniquely identified shark carcass or
lot/batch of fins, preferably in an electronic logbook system43. Catch information should include,
as a minimum, the species, date, catch location/area, gear used and vessel name/registration
number. Where a bar code is used, a handheld device can be used to scan the bar code and toenter catch information, which can be transferred in real-time to a central database, or at the
point of landing. This information, in turn, can be used to generate an electronic catch document
confirming the legality of the catch, which is linked with the unique identifier. The catchdocument should also accompany the physical flow of product along the supply chain.
At each data entry and control point along the supply chain (CTE – see Figure 10), information
about the uniquely identified carcass or lot can be recorded by scanning the bar code andentering data using a handheld device, or via a secure, online interface. Examples of KDEs to berecorded at the point of landing, processing and distribution are included in Figure 10. Where
the carcass/lot undergoes processing, the KDE must be recorded at the beginning and end of
the process so that inputs can be linked to outputs.
Verification of data entered at each control point could be achieved through physical inspectionsof shipments, genetic testing (e.g. identification of species, ocean-level geography), manual
analysis/reconciliation of data stored in the central database, and the use of software toautomatically detect non-conformities. Depending on product transformations between captureand export, this may require standardized conversion factors to be defined (e.g. frozen carcass tofrozen meat fillets; frozen to dried fins). Conversion factors will also enable CITES MAs toverify that quantities of fins or meat on a CITES export permit application (i.e. post-processing)correspond to the reported catch (as contained in the catch certificate).
Consideration may be given to the licensing of processing plants/exporters to ensure theirproduction processes are capable of effectively segregating CITES species, and to facilitate
verification of the reliability of data captured and transferred to the central database. Licensed
processing plants/exporters could be allocated a unique registration code for incorporation into
the unique identifier (e.g. bar code) on the packaged product for export.

(c) Data communication
A single (central) database system would seem most appropriate for CITES shark commodities,
due to the importance of rapid retrieval of information from all stages of the supply chain forverification and decision-making purposes. The database should contain all relevant information
to allow the national CITES MA to determine legal acquisition of a shipment for the purposes of
issuing an export permit. This may also include scanned copies of paper-based documents (e.g.
relevant authorisations, licences), where these are not yet issued in digital format. Stakeholders
could be provided access to information in the database via a secure, web-based platform (seeSections 5.3.3(b) and 5.4.4.).
The central database could be maintained at the national level, but with links to a regional
database, e.g. the existing database of a relevant Regional Fishery Body (RFB), for the purposes

43 Alternatively, paper-based records can be manually entered into a computerized system after landing, if this is notpossible at sea.

75

of regional monitoring and reporting of catches. The database should also link to the CITES epermitting process.

76

Table 7: Overview of products, supply chains and traceability measures for the four case studies under review, including relevant considerations forthe traceability of CITES Appendix II shark commodities (fins and meat) for comparison
Caviar

Crocodile skins

Queen Conch

Timber

1. Are all species coveredby the CITES listing?

Yes – all Acipenseriformes
listed in App. I or II

Yes – all Crocodylia species listed
in App. I or II

Yes

No – not all timber-producing
species listed

2. Are all products coveredby the CITES listing?

Yes - all Acipenseriformes
products

Yes - all Crocodylia products

Yes

Depends on species. Generallyroundwood and semi-processed
products (sawnwood, veneers,
plywood). For some species, further
processed products are covered.

SharksCITES listings
No – very small proportion of all
sharks are CITES-listed inApp. I or II
Yes

Products and traceability measures
3. Have traceability
measures been defined
under CITES?
4. Which products aretraded internationally?

Yes – Resolution Conf. 12.7
(Rev. CoP16)

Yes - Resolution Conf. 11.12(Rev. CoP15)

No

No

No

For Acipenseriformes species mainly caviar and meat

For Crocodylia species – mainly
skins, with meat a by-product of
the industry

Primary products (roundwood),
semi-processed products (sawn wood,
veneers, plywood), further processed
products.

Meat, fins, liver oil, cartilage,skin, teeth

5. Are all products ininternational trade coveredby traceability measures? If
not, which products arecovered?

No – labelling is only
required for caviar

No – tagging requirements only
apply to raw, tanned and finishedcrocodilian skins (and containersof parts such as tails, backstrips,etc.).

6. Which processing stages
are covered by traceability
measures?

Post-processing stage - caviaris the first and final processed
product. Re-packaging ofcaviar is also covered (transfer
into new primary containers)

Pre-processing and semiprocessing stages – from raw tofinished skins

Meat is the main target of thefishery for international trade.
However, the secondary products- shells, pearls, operculum – arealso traded internationally.
Measures not defined under
CITES, however various
measures underdiscussion/already implemented,
e.g. documentation schemes,
licensing, labelling. Meat is themain commercial product andpriority for traceability.
Meat is landed and exported invarious stages of processing –this would need to be taken into
consideration in the developmentof a traceability system

77

Depends on system – although
traceability measures are morecommon for primary and semiprocessed products

Depends on system – generally
primary wood processing stage, butsystems also in place for further
processing.

Caviar
Identifying species in caviar
may be possible by visual
identification but is generallyachieved by DNA analysis.

Crocodile skins
Skins in raw, tanned or finishedform generally easy to identify to
species by distinctive features

Queen Conch
Genetic techniques can assist in
identification of meat, potentiallyalso geographical origin.

TimberIdentification to genus level, possibly
also species, may be possible usingwood anatomy; however, chemical or
DNA analysis may be needed to
identify to species level. Identificationof geographical origin throughDNA and isotope analysis may
also be possible.

SharksWhole (or near whole) specimens
and fins with skin attached –species identification based onmorphological features possible.
Processed/semi-processed product(e.g. meat, fins without skin, fin
needles) - genetic testing necessary
for species identification.
Genetic testing is also becoming
available for determining
geographical origin

8. Is the supply chain welldefined/understood?

Yes – the supply chain iswell-defined, and relatively
standard for all caviar

Yes – typical supply chains are
well-defined for crocodile skins
from harvest to tannery.
However, the number of operators
may vary. Also, tanning may
take place either before or after
first export.

Generally yes - although more
information on specific(national) contexts required

Generally yes - from concessions to
the end of primary wood processing,
the supply chain is relatively welldefined. However there arecomplexities (see below).

9. Is the supply chain
complex?

No – uniform product (caviar
in tins/containers), relatively
few, well-defined operators(processors, (re-)packagers,
exporters, importers, retailers)
in a limited number ofcountries. Stages of supply
chain are not numerous. For
wild-sourced caviar, range
States are known andrestricted, providing a goodinitial situation for quota
setting. Introduction from thesea does not apply.

Yes and no – numerous operatorson the harvesting and exportingside and skins may change hands
several times before export.
However, product generally
exported as whole skins. Also,
all skin trade is channelled
through a limited number oftanneries mid-way through thechain (generally in the country offirst import, although tanneries
are also now located in countriesof origin).

No – processing of meat is
relatively simple with few
operators involved between
capture and export. Queen
Conch may be caught in multispecies fisheries (e.g. with Spiny
Lobster), but mixing of products
is not an issue due to distinct
markets. Capture is in
territorial waters and EEZs,
therefore introduction from thesea does not apply.

Yes – due, for example, to: mixing of wood from multiple
concessions; regional transshipment; different stages of processing
carried out in different locations; imported material (e.g. logs)
entering supply chains incountries of origin.
After primary wood processing,products may be destined for both
domestic use and international
trade. Further processing is more

Yes and no – basic/generalized
supply chains understood, butmore information on specificcontexts required. Various
possible supply chains for meatand fins of the App. II species,
involving many different
operators, countries andcomplexities (see below).
Yes – different supply chains forfins and meat, for high seas and
EEZ catches, and for
traditional, artisanal andindustrial fisheries. Complexities
include: CITES and non-CITES
shark species caught byvessels; species from multiple catchareas on a single fishing trip;
 transshipments at sea; mixing of products (species,

7. How easy is productidentification?

Supply chains78

Caviar

10. What operators/
activities are involved andwhere are theselocated/carried out?

Crocodile skins

Country of origin: wildharvest/aquaculture, caviar
processing and packaging

Country of origin: wild-harvest/
breeding facility, slaughterhouse,(domestic) tannery

Country of import: repackaging for domestic
consumption or re-export

Country of import: tannery(production of finished skins andpossible re-export)

Queen Conch

Country of origin: fishers(capture), trader (buy/sell),processing facility (processing ofmeat)
Country of import: traders,retailers

Timbercomplex, however for many species,
the CITES listings do not cover
this stage.

Country of origin: felling(concession/forest), primaryprocessing (e.g. saw mill, veneer,
plywood mill), possibly also further
processing (although may not fallunder CITES), traders, exporters,
retailersCountry of import: further
processing (although generally notcovered by CITES and traceability
systems), traders, re-exporters,
retailers

Sharksvessels);
 introduction from the sea;
 finning/processing at sea; products landed and sold in
various forms.
Traditional/artisanal fisheries(fins)*:
 Country of origin: fishers,collectors, traders, exporters
 Country of import: traders,processors, retailers,
restaurants, re-exporters
 Country of 2nd import:
traders, processors, retailers,
restaurants, re-exporters
Industrial fisheries (meat andfins)*:
 EEZs/high seas: fishers,
multiple vessels(transshipment) Country of landing: trader,
processor, processing facility,
distributor Country of import: trader,
processors, retailers,
restaurants, re-exporters
 Country of 2nd import:
traders, processors, retailers,
restaurants, re-exporters.
*destined for international trade.

79

CaviarCrocodile skins

Queen Conch

Timber

11. How are products
uniquely identified undercurrent traceability
systems?

Label with unique alphanumeric code. Code contains
information on species, source,
country of origin, year of
harvest/repackaging,processing/repackaging plant,
lot or CITES document
number.

Catch documentation, also use oflabels for meat products. May
include catch area and datefished, in addition to otherinformation.

Paper/electronic documentation or
physical marking with paint,waterproof paper/plastic tags, bar
codes, RFID devices containing
unique identification number.

12. How are actors in the
supply chain uniquely
identified under current
systems?

Registration of processing andre-packaging plants andallocation of uniqueregistration codes isrecommended - Resolution
Conf. 12.7 (Rev. CoP16).
Information is included in
CITES Register.
Close to harvest – label
affixed at processing plant or
aquaculture facility

Tag with alpha-numeric code orbar code. Code contains
information on species, country oforigin, year of skin production or
harvest and a unique serial
identification number. Re-export
tags only need to contain aunique serial identification
number. Currently, loop or
button-style tags are used.
Registration and/or licensing ofproducers, tanners, importers andexporters of crocodilian skins is
recommended - Resolution Conf.
11.12 (Rev. CoP15).
Registration/licensing may beundertaken by authorities at thenational or sub-national level.
Depends – tag may be affixed atany stage between harvest andexportExamples include licensing offishers, cooperatives, processors
or exporters at the national
level.

Examples include registration andlicensing (for harvest, processing andexport)Catch documentation may linkproduct to fishing trip, and may
be verified at point of landing or
subsequently. Labels affixed
after processing and packaging(meat)
Generally no

Depends on system, but often atpoint of harvest (e.g. standing trees,
stumps, logs)

Unique identification

13. At what stage in the
supply chain is the productfirst marked or uniquely
identified under current
systems?
14. Is there central control
or oversight of physicalmarking methods used?

Examples include production
and issuance of labels by
CITES MA; production by
State printing company; orproduction by traders andapproved by CITES MA

Tag manufacturers approved andlist published on CITES website.
Parties recommended to only
obtain tags from approved
manufacturers. In some Parties,
the CITES authority may
oversee tag orders, issuance,
distribution and possibly thetagging itself.

80

Generally yes at the forest
department level (can varydepending on system), but not at the
CITES MA level which is usuallya separate agency or division.

Sharks15. Can products be easily
marked?

16. Do marks need towithstand processing?

CaviarYes – caviar tins easy tomark (although smaller sizesof tin are more difficult)

Crocodile skins
Yes – skins large and robust,
can withstand tagging

Queen Conch
Some products only - labelling of
packaging possible for processed
meat

TimberSome products only – larger items
such as roundwood can by physicallymarked. For smaller items (e.g.
smaller pieces of sawn wood, woodchips) marking may be on package
or batch.

No – label is affixed toprimary container after
processing. New label is thenaffixed to new primarycontainer if re-packaging
takes place. However, labels
need to withstand storage inrefrigerated conditions/on ice.

Preferably yes – to avoid removalof tags from skins during tanning
process

No – any label would beapplied to processed productready for export

No - semi-processed and further
processed products would need to be
individually marked again, or as a
lot/batch

Paper-based, basic electronic

Paper-based, basic electronic,
integrated hardware

Paper-based, basic electronic

Paper-based, basic electronic,
integrated hardware

Label and other information(quantities of caviar imported,
exported, produced, stored,etc.) may be stored incomputerized form byindividual operators (e.g.
spreadsheets).

Tag and other information(quantities of skins received,transformed, sold, re-tagged, etc.)
may be stored in computerized
form by individual operators (e.g.
spreadsheets, database). Bar
coding allows for automatedAn example might be themanual entry of data into
spreadsheets by processors or
fishers, and transfer of
spreadsheets to national
authority for storage in a central
database.

Examples of systems:
 Data capture at various control
points using RFID tags andhandheld computers, andautomated transfer of data tosingle online database.
 Electronic or paper

Data capture and management
17. What types of systems
are currently used to
manage product data fortraceability purposes?*
Note: see Section 5.1.2. fordefinitions.
18. How is data captured
and stored by individual
operators?

81

SharksSome products only. Possible
options include: Trunks/carcasses –individual tags (e.g. attached
to dorsal fin)
 Meat – label on package
 Dried fins – tag on larger
fins, or label on package offins Frozen fins – label on
package
No – semi-processed and further
processed products would need to
be individually marked again, or
as a lot/batch. However,labels/tags need to withstandstorage (e.g. in ice slurry or
freezer)

19. How is the reliability ofdata captured by individual
operators verified undercurrent systems?

Caviar

Crocodile skins
transfer to databases.

Queen Conch

Timberdocumentation accompanying
products along the supply chain,
and automatic transfer (orscanning) for storage in central,
online database.
 Manual entry of data into
spreadsheets/forms by harvesters
and processers, and transfer of
spreadsheet/forms to national
authority for storage in central
database.
If data are held in a central
database (e.g. managed by the forest
department, CITES MA), these
may be verified manually or
software may allow for automatic
detection of non-conformities between
control points. Information fromphysical inspections of individual
shipments may also be captured indatabase.

CITES authorities may
verify records held byindividual operators and carryout inspections of plants/
facilities (e.g. processing, repackaging). Spot checks ofproducts using genetic testing
may be carried out.

CITES authorities may verify
records held by individual
operators and carry out
inspections

Data reported to and held innational databases can beverified by national authorities,
with inspections at point oflanding, processing, export, etc.

Information contained in label
accompanies physical flow of
product. Up to point of repackaging, caviar can betraced back to processing
plant/facility in country oforigin. After re-packaging,caviar can be traced back tocountry of origin.
Operators maintain records oflabels and other information,
which are not integrated inInformation contained on tag
accompanies physical flow of
product and allows tracing backto country of origin. However, reexport tags only need to include a
unique serial identification
number, therefore do not enable
tracing back to country of origin.

Catch documentation may
accompany physical flow of
product and allow tracing backto point of capture (e.g. fishingtrip)

Marking devices with unique
number identifiers (plastic tags, bar
codes, RFID devices) andelectronic/paper documents
accompany physical flow of productand allow tracing back to point of
harvest.

Operators maintain records oftags and other information, which
are not integrated into centralized

Some countries have establishednational databases to store
information captured by fishingSome examples of central, online
databases established at thenational (or State/provincial) level

Data communication
20. What informationaccompanies the physicalflow of the product?

21. Is there a central
database to allow for
retrieval of information by82

Sharksall stages in the supply
chain?

Caviarcentralized databases.

Crocodile skins
databases.

National authorities may
maintain a database of labels
issued for internal use.

National or sub-national
authorities may maintain recordsof tags issued for internal use.
Also, national e-permitting
systems provide for storage of tag
information on CITES
documents, but are only accessible
to the CITES authorities incountry.

The CITES caviar trade
database stores information
on export permits and reexport certificates issued(which includes label
information). This allows reexporting countries to track
shipments back to country oforigin and to verify quantities
of caviar previously imported
for the purposes of issuing reexport certificates.

Queen Conchcooperatives, processors, etc.
These can be accessed bynational authorities.
Online platforms for sharing
and storing of catch and effort
data, accessible to registeredusers (e.g. fishers, processors),
have also been proposed for
longer-term development.
National databases may belinked with a regional database
under such a system.

83

Timberto allow for tracking of timber
throughout the chain of custody.
Some information may be accessible
to operators and wider civil society.

SharksTable 8: Overview of lessons learned and best practices from the review of CITES
traceability measures
CommonissuesLessons learned/best practices for application to sharks
Initial considerations: Universal standards for tracking systems are important but should leave sufficient scope
and flexibility for Parties/operators to determine how they should be implemented.
 An understanding of the supply chain is a prerequisite to the establishment of any
traceability system and should include identifying the data entry and control points (wheredata entry and verification are possible), operators involved, and information to becollected at each stage.
 Consultations must be held with relevant stakeholders prior to deploying a system toensure widespread acceptance, with particular attention to challenges faced in
traditional/artisanal fisheries and possible incentives for participation.
 Establishing and maintaining a robust and effective traceability system can be an
administrative and financial burden for authorities. Automation of some or all activities
should be considered to reduce this burden, as well as recouping costs through licensing
and requiring payment for tagging devices.
 For CITES purposes, when designing a traceability system, it is important to first ensurethat a system is robust and effective from harvest to the point of export, before
considering subsequent stages.
 Traceability measures should apply to products destined for domestic and international
trade.
 Traceability systems are only as strong as the legal/regulatory and monitoring regimes inplace and cannot overcome issues of weak governance.
 Mixing of product from different species compromises traceability.
Level of technology:
 Systems should be sufficiently flexible to allow improvements/advances in technology(e.g. software developments) to be easily incorporated, and to encourage innovation.
 Tracking technologies must suit local communication infrastructure, be robust and abuse
resistant, be cheap, effective and user-friendly.
 The level of technology must be appropriate to the context and adequate capacity must
exist before considering more advanced technologies.
 Integrated hardware technologies, such as bar codes, can assist in data management andreducing administrative burden, e.g. through automated, real-time transfer of data to
relevant databases. Systems involving bar codes and handheld PCs for data capture are
well-developed and operational for tracking products in a range of sectors.
 Consideration should be given to the compatibility of tracking technology with smart
phone applications.

CaviarData management, monitoring and verification:
 Consideration should be given to the use of electronic systems for data collection andmanagement, in order to reduce administrative burden, facilitate monitoring andverification, and allow for rapid retrieval of information to determine legal origin.
 Systems must be supported by monitoring and verification procedures to ensure reliabilityof data. Verification is particularly important for high-risk supply chains.
 Stringent book-keeping requirements by operators are essential for a robust and effective
traceability system.
 Traceability systems should have a secure, central database (e.g. national, regional, global)
which link directly with other databases and the CITES e-permitting system. Importantconsiderations include auditing/verification of data, real-time sharing of information,transparency, and provision of universal access (e.g. to civil society stakeholders) via auser-friendly interface.
 Genetic techniques can help to verify the accuracy of information in tracking systems.
 If labels are used, standardization and robust security features are essential. This can beassisted by centralized production of labels/issuance.
 Inspections of operators and verifications of records are also important to ensure
reliability of data.

84

Lessons learned/best practices for application to sharks

Crocodile
skins







Queen
Conch









Timber









Physical marking should take place as close to the point of harvest as possible but firstpoint of tagging should be determined in consultation with stakeholders.
Removal of physical marks (such as tags) during processing provides a potential opening
for abuse of the system but may be unavoidable. If marking cannot be maintained during
processing, alternative mechanisms to ensure the integrity of the system will be necessary –e.g. strict book-keeping requirements to match products received to products sold,verifications and inspections.
Data control points may include bottlenecks in supply chains (where products cometogether for processing or handling by a limited number of stakeholders), which provide
important opportunities for verification of legality.
Administrative burden should be considered when designing a system and streamlining
may need to be considered to remove unnecessary elements.
A catch documentation scheme (CDS) is a key mechanism allowing for the tracking offisheries products through the supply chain and tracing back to point of capture. Features
to be considered include compatibility with regional/international requirements (e.g.
RFMO, CITES, EU IUU Regulation systems), and the linking of national databases with
regional databases for reporting/verification at the regional level. For artisanal fisheries,
linking of documentation back to a particular fishing trip may be sufficient.
For the establishment of any CDS, long-term support and maintenance are essential, as
well as training for users and widespread agreement among countries to ensure coverage is
as comprehensive as possible.
Electronic data collection and management systems should be considered to support
implementation of any CDS/tracking system and facilitate reporting, analysis andverification of data.
The allocation of catch quotas and export licences to fishing cooperatives has proven auseful mechanism for ensuring traceability and improving data collection and reporting.
This can be combined with spatial restrictions and rights-based management approaches
to allow products to be traced back to catch area.
Consideration should be given to establishing standardized/scientifically rigorous
conversion factors to allow detection of discrepancies between processing stages in a
supply chain. This can support implementation of a CDS.
Controls should be focused on the early stages of the industry, where traceability is more
efficient and straightforward. For example, physical markings should start at the stump at
the time of felling.
Systems should be designed to integrate with existing chain of custody and other businesssystems, must be adapted to on the ground conditions, and should be tested during a
trial/pilot phase.
Mass balance systems are an option for processed products, although are inappropriate
where mixing with high risk material could occur or where individual products/lots need
to be traced to origin
RFID monitoring systems have proven a useful tool to share real-time information andautomate data transfer/identification of non-conformities.
Electronic tracking technologies are becoming more user-friendly, reliable, available, andprices are expected to decline further with increasing volumes produced.
“Off the shelf” tracking systems may present an efficient and cost-effective option, in
terms of development and deployment. Systems are generally flexible and can becustomized to meet varying user requirements.
Incentives could be considered for the establishment of tracking systems, e.g. tax
incentives, legal requirements, support for smallholders.

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