A TRAFFIC REPORT

Wildlife tradein the Eurasian
Customs Union andin selected Central
Asian countries

byAlexey Vaisman,Victoria Mundy-Taylor
and Katalin Kecse-Nagy
A TRAFFIC REPORT

Reproduction of this report has been authorized bykind permission of the Secretariat of the Convention
on International Trade in Endangered Species of Wild
Fauna and Flora (CITES).

Wildlife trade in the Eurasian Customs Union and inselected Central Asian countries

EU‐CITES Capacity building project No. S‐415

2013
CITES Secretariat

About the EU‐CITES Capacity‐building project
The project Strengthening CITES implementation capacity of developing countries to ensure sustainable wildlife
management and non‐detrimental trade was approved for funding by the European Union (EU) in 2009.
A major challenge for many countries is the difficulty in meeting the requirements for trade in CITES‐listed
species, ranging from legal sourcing and sustainability requirements, to the effective control of legal trade anddeterrence of illegal trade. Mechanisms exist in CITES and in both exporting and importing countries that
promote and facilitate compliance – although Parties are often hampered by a lack of capacity or a lack of
current biological or trade information with respect to certain species. This can result in levels of trade which
are unsustainable, which in turn can impact on economic growth and local livelihoods, and reduce options andincentives for conserving and managing wild resources effectively.
The overall aim of the EU’s support is to strengthen capacities to implement the Convention and satisfy the
CITES‐related requirements of trading partners (such as the EU), to prevent overexploitation and to ensure legal
international trade in wild fauna and flora does not exceed sustainable levels.
This publication is one of the reports and tools developed under this project, which provide information andguidance to Parties in a particular area of concern, based on needs identified by developing countries.

Published by the CITES Secretariat, Geneva, Switzerland.
Copyright 2013 CITES Secretariat.
This document was prepared by TRAFFIC, under contract to the CITES Secretariat and made possible through funding
received from the European Union.
This document, in part or in full, may be reproduced for educational or non-profit purposes without special permission from the
copyright holder, provided acknowledgement of the source is made. Reproduction for any other purpose requires the previous
agreement of the CITES Secretariat. The CITES Secretariat would appreciate receiving a copy of any publication that uses thisdocument as a source.
The views expressed in this publication are those of the authors and do not necessarily reflect the views of the CITES
Secretariat, the European Union, or TRAFFIC.
The geographical designations employed in this document do not imply the expression of any opinion whatsoever on the part of
the CITES Secretariat, the European Union, or TRAFFIC concerning the legal status of any country, territory, or area, orconcerning the delimitation of its frontiers or boundaries. The responsibility for the contents of the document rests exclusively
with its authors.
Suggested citation: Vaisman, A., Mundy-Taylor, V. and Kecse-Nagy, K. (2013). Wildlife trade in the Eurasian Customs Unionand in selected Central Asian countries. Secretariat of the Convention on International Trade in Endangered Species of Wild
Fauna and Flora (CITES), Geneva, Switzerland. pp.90
ISBN 978 2 930490 19 9
Front cover photographs: Background photo: the Ukok Plateau natural park, Altai Republic; Other photos, from top to bottom:
Saker Falcon Falco cherrug; Argali Ovis ammon; and Russian Sturgeon Acipenser gueldenstaedtii
Photograph credit: Background photo: Denis Bogomolov/WWF Russia; Saker Falcon: Hartmut Jungius/WWF-Canon; Argali:
Alexander Kreik/WWF Russia; Russian Sturgeon: Andrey Nekrasov/WWF-Canon
The TRAFFIC symbol copyright and Registered Trademark ownership is held by WWF: TRAFFIC is a strategic alliance ofWWF and IUCN.

Wildlife trade in the Eurasian
Customs Union and in selected
Central Asian countries

Vaisman, A., Mundy-Taylor, V. and
Kecse-Nagy, K.

TABLE OF CONTENTSACKNOWLEDGEMENTS ........................................................................................................................... 1
EXECUTIVE SUMMARY ............................................................................................................................ 2
INTRODUCTION ....................................................................................................................................... 6
METHODOLOGY ...................................................................................................................................... 9
BACKGROUND ON THE EURASIAN CUSTOMS UNION (ECU) ................................................................ 11
Common ECU legislation ................................................................................................................... 12
Future membership and preparations for accession ........................................................................ 12
CITES in the ECU ................................................................................................................................ 14
OVERVIEW OF THE REPORTED TRADE IN CITES‐LISTED SPECIES IN THE TARGET COUNTRIES ............. 17
Live reptiles ....................................................................................................................................... 19
Hunting trophies ............................................................................................................................... 22
Caviar (and other sturgeon products)............................................................................................... 26
Live birds ........................................................................................................................................... 27
Trade in medicinal products derived from animals .......................................................................... 30
Reptiles: Trade in non‐medicinal bodies, parts and derivatives ....................................................... 32
Live plants ......................................................................................................................................... 33
Live mammals ................................................................................................................................... 33
Timber ............................................................................................................................................... 34
SUMMARIES OF COUNTRY VISITS ......................................................................................................... 35
Belarus .............................................................................................................................................. 35
Kazakhstan ........................................................................................................................................ 38
Kyrgyzstan ......................................................................................................................................... 41
Russia ................................................................................................................................................ 44
Tajikistan ........................................................................................................................................... 47
Uzbekistan......................................................................................................................................... 50
CITES IMPLEMENTATION IN OTHER CUSTOMS UNIONS AND REGIONAL ORGANISATIONS ................ 54
ASEAN ............................................................................................................................................... 54
European Union ................................................................................................................................ 55
North America ................................................................................................................................... 58
Southern African Customs Union...................................................................................................... 58
DISCUSSION........................................................................................................................................... 60
CONCLUSIONS AND RECOMMENDATIONS ........................................................................................... 67
REFERENCES .......................................................................................................................................... 70
ANNEX I ................................................................................................................................................. 73
List of authorities participating in meetings in the target countries in March‐April 2013 ............... 73
ANNEX II ................................................................................................................................................ 75

Stricter measures in the EU and the USA.......................................................................................... 75
ANNEX III ............................................................................................................................................... 82
CITES export quotas for 2013*.......................................................................................................... 82
ANNEX IV ............................................................................................................................................... 83
Notable differences in numbers of live birds reported as (re‐)exported by the target countries,
according to exporters’ and importers’ reports (2000‐2010)........................................................... 83
ANNEX V ................................................................................................................................................ 84
Overview of national CITES/wildlife trade legislation in the target countries.................................. 84
ANNEX VI ............................................................................................................................................... 90
The list of captive breeding facilities registered in Uzbekistan ........................................................ 90

ACKNOWLEDGEMENTS
Many people assisted in the compilation of this report by contributing their expertise, experienceadvice, time and information. Special thanks are due to Stephanie von Meibom (TRAFFIC), whoreviewed several drafts and provided valuable technical assistance throughout this project.
Drafts of the report were also reviewed by Olga Pereladova (WWF Russia) and by colleagues at
TRAFFIC: Richard Thomas and Roland Melisch, who are gratefully acknowledged. The authors would
also like to thank other TRAFFIC colleagues who provided input into various sections of the report:
Claire Beastall, Ernie Cooper, Rachel Kramer, Paola Mosig Reidl, Thomasina Oldfield and Sabri Zain.
The authors are particularly grateful to CITES authorities in the target countries visited in March‐
April 2013 for their input and assistance. Without their help, the compilation of this report would
not have been possible. The assistance of Olga Pereladova in preparing these visits is also gratefully
acknowledged.
Information obtained during the country visits was supplemented by information compiled byconsultants, whom the authors also thank for their assistance: Ms Elena Shushkova, Ecoproject(Belarus); Dr Tatiana M. Bragina, WWF Project leader in Kazakhstan (Kazakhstan); Almaz Musaev,
Vice‐Director of the Hunting Department of the State Agency of Environmental Protection andForestry (Kyrgyzstan); Ms Svetlana Senotrusova, Professor at the Faculty of Civil Management of the
Moscow State University and of the Russian Customs Academy (Russia); Ms Firuza Illarionova, WWF
Project Co‐leader in Tajikistan (Tajikistan); and Mr Oleg Tsaruk, Ecologist and researcher(Uzbekistan).
Information provided by Maria Karlstetter, Flora and Fauna International (FFI) about training
materials and wildlife detector dogs from Central Asia is also greatly appreciated.
This publication was funded by the European Union, through the CITES capacity‐building project.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

1

EXECUTIVE SUMMARY
This report examines the implementation of the Convention on International Trade in Endangered
Species of Wild Fauna and Flora (CITES) in the Eurasian Customs Union (ECU) and in selected Central
Asian countries. The ECU is comprised of the Republic of Belarus, the Republic of Kazakhstan andthe Russian Federation, hereafter referred to as “Belarus”, “Kazakhstan” and “Russia”, respectively.
The Central Asian countries considered in this report are the Republic of Kyrgyzstan, the Republic of
Tajikistan and the Republic of Uzbekistan, hereafter referred to as “Kyrgyzstan”, “Tajikistan” and“Uzbekistan”, respectively. These countries are collectively referred to as “the target countries” or“the region” in this report. The region is home to a rich fauna and flora, including species such as
Snow Leopard, Tiger, Saiga Antelope, Musk Deer, Saker and Gyr Falcons, Argali and many endemic
plant species in the Caucasus. The region collectively is also home to over 200 million people andcomprises a vast territory that stretches from China in the East to the European Union (EU) in theWest.
The Eurasian economic integration process started in 2000 with the creation of the Eurasian
Economic Community (EurAsEC). The Eurasian Customs Union (ECU) was established by Belarus,
Kazakhstan and Russia in 2007 and started to be implemented in July 2010, which resulted in theabolishment of internal border controls between the three countries. Kyrgyzstan’s accession to the
ECU was agreed in 2010 and is expected to take place soon. The future is also likely to see further
enlargement of the ECU to include participants such as Armenia and Tajikistan.
Based on the analysis of trade data collected under the Convention on International Trade inEndangered Species of Wild Fauna and Flora (CITES), the target countries are mainly importantsource countries for wildlife in trade, with some of them playing a transit (e.g. Kyrgyzstan) or aconsumer role (Russia) as well. The most important commodities in terms of number of specimens
legally exported from the region based on exporters’ reports for 2000‐2010 included:i)Live retiles (mainly Horsfield’s Tortoise Testudo horsfieldii) – with Uzbekistan as theleading (re‐)exporter in the region;ii)
Live birds (birds of prey and Psittacidae) – again with Uzbekistan as the leading (re‐)exporter in the region, followed by Russia and Kazakhstan;iii)
sturgeon caviar – with exports from Russia and Kazakhstan showing a declining trend
over the period 2000‐2010;iv)
Medicinals (i.e. medicinal products and also parts and derivatives for medicinal use) –including exports of products consisting of/derived from Musk Deer Moschus
moschiferus from Russia and Saiga Antelope Saiga tatarica horn from Kazakhstan;v)
Hunting trophies (species including Brown Bear Ursus arctos, Grey Wolf Canis lupus andArgali Ovis ammon) – mainly exported from Russia, Tajikistan and Kyrgyzstan.
Overall, the trade data analysis found some large discrepancies between traded quantities asreported by the importers and the exporters. Some of these discrepancies are likely to be due to thepoor communication and co‐operation between CITES Management Authorities (MAs) and Customs.
With the exception of Tajikistan, all target countries are Parties to CITES and have been
implementing and enforcing the provisions of the Convention for several years or even decades.
However, there remain a number of areas that would benefit from further improvement according
to the findings of this project. These areas include i) addressing gaps in national legislation, ii)
enhancing the co‐operation between the CITES MA and enforcement staff, iii) ensuring regular CITES
training for enforcement staff, and iv) improved reporting to CITES (both on legal and illegal trade).
This baseline situation with its challenges has become more complex with the formation of the ECU
in July 2010. While formally the ECU is not meant to affect CITES implementation and enforcement

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries2

in the target countries (i.e. according to the regulations in place, CITES‐listed species are not coveredby the ECU), it does have implications for wildlife trade. With the removal of controls at the internal
ECU borders, CITES‐listed wildlife can be moved freely within the ECU. To prevent this having
negative impacts on the control of wildlife trade in the region, a highly organized and co‐ordinatedapproach needs to be taken by ECU member countries. Co‐ordination and information exchange at
all levels of CITES implementation and enforcement will be necessary to ensure consistency acrossthe ECU. An absence of such consistency could result in the exploitation of the weakest link in the
chain (e.g. illegal trade entering the ECU by way of the route of least risk of detection) or permit
shopping (e.g. when wildlife traders are refused an import permit by one ECU member country, theshipment may enter the ECU by way of a permit granted by another member country), which posesa threat to both native and exotic wildlife traded by the ECU members. Furthermore, the potential
future enlargement of the ECU to include non‐CITES Parties such as Tajikistan may create an
additional layer of complexity for those addressing the implementation and enforcement of CITES in
the ECU.
When the integration process in the EU reached a similar level to that of the ECU (i.e. when theSingle Market came into effect resulting in the absence of systematic internal border controls), theEU decided that the provisions of CITES needed to be implemented in all EU Member States
uniformly and in a co‐ordinated manner through the adoption of a comprehensive set of EU
regulations that apply to all EU Member States—the EU Wildlife Trade Regulations. These wereintroduced with three co‐ordinating bodies established at the EU level to allow for regular andfrequent information exchange and consistent decision‐making for the different aspects of CITES
implementation ranging from scientific issues (Scientific Review Group) to management (Committee)
and enforcement issues (Enforcement Group). Other free trade agreements and regional economic
integrations, such as the Association of Southeast Asian Nations (ASEAN) and the North American
Free Trade Agreement (NAFTA), which represent a much smaller degree of co‐operation among theirmember countries than that in the EU or the ECU, have also found it useful to establish formal
mechanisms for co‐operating on CITES enforcement, and thus have established wildlife enforcement
networks, namely ASEAN‐WEN and NAWEG, respectively.
The findings of this report suggest that CITES implementation and enforcement warrants further
attention by current and future member countries of the ECU.
RECOMMENDATIONS
The following recommendations are put forward to address the issues identified above:
Strengthening national legislation in the region‐ Where there are gaps in national legislation, these should be addressed by the adoption of
new legislation or amendments to existing regulations (e.g. in Kyrgyzstan, Russia andUzbekistan).
‐ Target countries are advised to consider adopting legislation that prescribes the registration
and regular control of captive breeding facilities where this is not already required, andwhich makes the marking of certain CITES‐listed species obligatory. This would beparticularly important for Kyrgyzstan and Uzbekistan but also for other target countries.
Strengthening Enforcement of CITES controls in ECU members‐ Customs are encouraged to provide copies of processed CITES documents to their respective
CITES MA.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

3

‐

‐

‐

Enforcement authorities are encouraged to improve their record keeping of detected casesof illegal trade to ensure that key information (e.g. scientific name of species, trade route,etc.) are recorded, stored centrally and shared with their respective CITES MA.
When carrying out controls at external borders, risk assessments and targeted controls by
enforcement authorities should take into account the trends in legal as well as in detectedcases of illegal trade, preferably considering these at the ECU level (as opposed to focusing
on the national level only).
Notable discrepancies identified in legal trade reports should be monitored by CITES MAs
and investigated by enforcement authorities, if warranted. For example, large discrepancies
found in exporters’ and importers’ reported quantities, or trade partners reporting
significant exports from a particular country that the country has not reported as exports.

Interagency co‐operation among CITES authorities at the national level‐ The different authorities responsible for CITES implementation at the national level shouldmeet regularly to exchange information and co‐ordinate activities. The signing ofagreements or Memoranda of Understanding between the relevant authorities may help
formalize such co‐operation and ensure participation by the relevant agencies.
‐ The target countries are encouraged to establish National Environmental Security Task
(NEST) Forces, as recommended by INTERPOL.
Training and capacity building‐ Further CITES training is recommended in the target countries. Preferably, this should beheld regularly to ensure continuity even for authorities with a high staff turnover. Train the
trainer workshops are also encouraged.
‐ The holding of regional (or ECU) level training seminars is greatly encouraged to help
improve regional co‐operation.
‐ The CITES Secretariat is encouraged to assist target countries with training events, boththrough participation by CITES Secretariat staff and through assistance in obtaining financial
resources for training.
‐ The target countries are encouraged to participate in all wider or regional training initiatives,
such as those organized by the Green Customs or the Organization for Security and Co‐
operation in Europe (OSCE).
‐ Training materials developed by the target countries (e.g. those already developed in
Belarus, Russia, Uzbekistan) should be used more widely in the region and adapted tonational needs as necessary.
CITES in the ECU‐ Current ECU members, plus Kyrgyzstan that is imminently joining the ECU, are encouraged
to raise the urgent need for an organized and co‐ordinated approach to CITES
implementation and enforcement in the ECU in order to ensure consistency across themember countries.
‐ ECU member countries are encouraged to establish co‐ordination mechanisms based on thebest practice examples of existing regional economic integrations (e.g. those established by
ASEAN, EU, NAFTA), which allow for regular and frequent information exchange andconsistent decision‐making for the different aspects of CITES implementation from scientificto management and enforcement issues. ECU member countries are encouraged toformalize these co‐ordination mechanisms within ECU legislation. The discussions on co‐ordination should also address the issues surrounding the implementation of nationally set
export quotas in the ECU context.
‐ To this end, ECU member States are recommended to establish a Wildlife Enforcement
Network.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

4

‐
‐
‐

Additionally, the establishment of new or the wider use of existing (close to) real‐timeinformation‐sharing mechanisms between authorities across the ECU are recommended.
ECU member countries should consider regulating or monitoring internal trade in some
CITES‐listed species (e.g. those listed in Appendix I or a selection of these species).
The intentions to harmonize sanctions across the ECU in general should be encouraged toinclude those for wildlife trafficking too.

International co‐operation with other relevant institutions‐ The target countries should inform the CITES Secretariat about changes in their national
CITES legislation and provide a translation of the new legislative text (in one of the working
languages of CITES).
‐ CITES authorities in the target countries who do not currently actively participate in thevarious international CITES fora or provide information as part of various CITES processes(e.g. Reviews of Significant Trade) are strongly encouraged to do so.
International accession to and co‐operation with CITES‐ In view of the developments under the ECU more generally and the above‐mentioned
challenges, further conscious of Tajikistan’s own expression and desire to join the ECU, andmindful of the President of Tajikistan’s recommendations to the Tajik Parliament regarding
the ratification of CITES, the Government of Tajikistan should be further encouraged andsupported to continue its plan to accede to CITES at the earliest opportunity.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

5INTRODUCTION
This report has been compiled in the framework of a project examining the implementation of theConvention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in theEurasian Customs Union (ECU). Overall, the project aimed at contributing to strengthening capacities
to implement the Convention, to prevent overexploitation and to ensure that legal international
trade in wild fauna and flora does not exceed sustainable levels. The project focuses on member
countries of the ECU (comprised of the Republic of Belarus, Republic of Kazakhstan and the RussianFederation, hereafter “Belarus”, “Kazakhstan” and “Russia”, respectively) and on selected Central
Asian countries (namely the Republic of Kyrgyzstan, the Republic of Tajikistan and the Republic of
Uzbekistan, hereafter “Kyrgyzstan”, “Tajikistan” and “Uzbekistan”, respectively). These countries arecollectively referred to as “the target countries” or “the region” in this report.
The region is home to a rich fauna and flora, some of which are sought‐after in international wildlife
trade, such as Snow Leopard, Tiger, Saiga Antelope, Musk Deer, Saker and Gyr Falcons, Argali andmany endemic plant species in the Caucasus. Trophy hunting is an important activity in this region,
with Russia and several Central Asian countries a popular destination for European hunters seeking
trophies of various species of bird and mammal (Hofer, 2002, Knapp, 2007). The region collectively
is also home to over 200 million people and comprises a vast territory which stretches from China in
the East to the European Union (EU) in the West, and includes Russia, the world’s largest country interms of area. From this, the ECU represents a population of 167 million, a GDP of USD 2 trillion anda goods turnover of USD 900 billion1 (Krotov, 2011).
In the ECU, traditionally, a significant amount of Russian and Kazakh foreign trade has been oriented
towards the European Union (EU). However, the People’s Republic of China (hereafter referred to as
China) is rapidly emerging as an important trading partner for these two countries. With regard to
trade routes, significant quantities of Russia‐China trade pass through Kazakhstan, while Belarus is a
key route for Russian trade with the EU (Silitski, 2010) (see Figure 1). Full use of the potential of the
ECU can shorten the time required for transportation of goods from China to Europe by four times(Anon., 2010b). In terms of general development opportunities, it is estimated that the creation of
the ECU will promote economic development, and can provide up to an additional 15% of the GDP ofthe participating countries by 2015. Russia alone can expect additional monetary income worth
around USD 400 billion from the ECU, while Belarus and Kazakhstan can expect around USD 16
billion each by 2015 (Anon., 2009c).

1 Figures in short scale: billion = 1 000 million; trillion = 1 000 billion.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

6Figure 1: Map of ECU depicting key international trade routes and neighbouring countries

Source: Map drawn on information after Silitski (2010), taken from TRAFFIC, 2012.
Abbreviations: AM – Armenia, AZ – Azerbaijan, BY – Belarus, CN‐ China, EE – Estonia, FI – Finland, GE – Georgia, JP – Japan, KG – Kyrgyzstan, KP – Democratic People’s
Republic of Korea, KZ – Kazakhstan, LT – Lithuania, LV – Latvia, MN – Mongolia, PL – Poland, RU – Russia, TJ – Tajikistan, TM – Turkmenistan, UA – Ukraine, UZ – Uzbekistan.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

7

The need for investigating implications of the ECU on CITES implementation has been raised for
instance by the Green Customs Initiative2 and by TRAFFIC. At the Green Customs Workshop held in
Astana, Kazakhstan, 27‐28 June, 2012, “participants highlighted the importance of strengthening
monitoring and control of trade in environmentally sensitive commodities in the Region after thecreation of a Customs Union between the Russian Federation, the Republics of Belarus andKazakhstan” (Anon., 2012a). TRAFFIC noted that the removal of Customs controls at the internalborders of the member countries of ECU may have negative consequences on wildlife trade controls
in the region and which would require further investigation (Taylor et al., 2012).
In July 2011, internal physical border controls were eliminated in the ECU and in January 2012, theCommon Economic Space (CES) came into effect ensuring the freedom of movement of goods.
When a similar level of integration was reached in the EU in 1984 (i.e. when the European Single
Market came into effect resulting in the absence of systematic border controls within the EU), theEU decided that the provisions of CITES needed to be implemented in all EU Member States
uniformly and in a co‐ordinated manner through the adoption of a comprehensive set of EU
regulations that apply to all EU Member States. To date, the ECU has not paid a comparable level ofattention to the complexities of implementing and enforcing the provisions of CITES in this newcontext.
The present report aims to undertake a scoping exercise concerning the implementation of CITES in
the ECU and in selected countries in the region in order to establish the possible impact of the ECU
on trade in CITES‐listed species. The report provides a background to the past and expected future
development of the ECU. It also presents an overview of CITES trade to/from the target countries.
The report then looks at various aspects of CITES implementation and enforcement at the country
level, (e.g. national wildlife trade legislation, training needs and illegal trade).

2

Green Customs is the partnership of international organizations co‐operating to prevent the illegal trade inenvironmentally‐sensitive commodities and facilitation of the legal trade in these. CITES is one of the partners of thisinitiative. (http://www.greencustoms.org/)

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

8

METHODOLOGY
Trade data sources and analysis
CITES trade data (data provided by CITES Parties in their annual reports) were used to analyse
reported international trade involving ECU member countries (Belarus, Kazakhstan and the RussianFederation (Russia)) and other Central Asian countries (Kyrgyzstan, Tajikistan and Uzbekistan) as
either the country of origin, export or import. These countries are together referred to as the “target
countries”. Data were extracted for the period 2000 to 2010, inclusive (as 2010 was the most recent
year for which comprehensive data were available at the time of writing) and for all CITES species inAppendices I, II and III. The data were downloaded from the CITES Trade Database in January 2013.
Comparative tabulations, which compare the imports and exports reported by individual CITES
Parties, were used.
Although the trade records should be reported identically by the importer and exporter, in practicethese often differ due to differences in reporting between the importing and exporting country.
Where (re‐)exports are referred to in this report, this includes both direct exports from a country
and re‐exports. In some cases total reported exports significantly exceed total reported imports. Thiscan be caused by the fact that usually reporting is based on the export permits issued rather thanthe export permits actually used.
Both importing and exporting Parties’ reported data were considered in the present analysis.
However, as trade was, in the majority of cases, only reported by exporting countries, it should beassumed that quantities being referred to are those reported by exporters, unless specifically statedotherwise. However, importing country reports were used where exporting country data wereabsent. The following considerations had to be taken into account when interpreting the trade data:Tajikistan is not a Party to CITES and therefore does not submit its trade data to the CITES
Trade Database in the form of annual reports. The analysis of trade involving Tajikistan istherefore based on the reported exports/imports of its trading partners.
Russia did not submit an annual report for 2006. Therefore trade involving Russia for thisyear is based on the reported exports/imports of its trading partners.
Kyrgyzstan did not become a Party to CITES until 2 Sept 2007 and submitted its first annual
report for trade that took place in 2009. Trade involving Kyrgyzstan for the years 2000 to2008 is therefore based on the reported exports/imports of its trading partners.

Unless specified otherwise, all CITES trade descriptions and totals include all sources (e.g. wild,
captive‐bred) and purposes (e.g. commercial, personal or hunting) for data from 2000 to 2010.
Where reference is made to “captive‐bred” specimens, this includes trade records reported withsource codes A (artificially propagated plants), C (animals bred in captivity), D (Appendix I animals
bred in captivity and Appendix I artificially propagated plants) and F (animals born in captivity).
Reference to “wild” specimens includes trade records reported with source codes I (confiscated or
seized specimens), O (Pre‐Convention specimens), R (ranched specimens) and W (specimens takenfrom the wild). In addition, trade records for which the source is unknown (source code U and where
no source code is specified) are likely to be of wild origin, therefore it is prudent to include them aswild specimens in any analysis.
All trade is reported as individual specimens unless a unit is specified (such as kg). Trade wasanalysed by reference to key commodity groups that were selected according to their importance inwildlife trade in the target countries (total number of trade records and/or total quantities of
specimens in trade). The analysis also focused on CITES species or species groups that are native tothe target countries and for which this is an important source region, e.g. Brown Bears, sturgeons,Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

9birds of prey and leeches. The commodity groups selected for analysis were (in order of importancebased on total number of records of trade involving the target countries, i.e. as countries of import,(re‐)export or origin): (i) reptile bodies, parts and derivatives; (ii) live plants; (iii) live mammals; (iv)hunting trophies; (v) live birds; (vi) caviar; (vii) mammal bodies, parts and derivatives; (viii) live
reptiles; and (ix) medicinals. When interpreting the results of the analysis, the following should be
noted:
 For reptile bodies, parts and derivatives, trade reported in kg, m or m2 was excluded as thisrepresented a small proportion of overall records. Quantities reported using the unit “pairs”
were converted to whole values to facilitate analysis (1 pair = 2 items).
 Live plants include trade records reported with the CITES terms seeds and live.
 For caviar, trade records reported without a unit or records reported with the CITES term
eggs (live) were not included in the analysis as these usually refer to live eggs destined foraquaculture rather than for consumption as caviar. Caviar trade reported as cans or flasks
was converted to kg with a weight of 0.1 kg chosen as the average weight3 of a caviar can or
flask.
 Hunting trophies include mammal, reptile and bird trade records reported with thefollowing CITES terms: bodies, skulls, skins or trophies (jointly referred to as “trophy items”).
Other items, such as claws, teeth or tails, may also be trophies; however, it was assumed to
be unlikely that a hunter would take only these items without the “primary” trophy (such as
the body or skin). Restricting the analysis to the primary trophy items aims to avoid an
exaggerated estimate of the actual trophy trade and is consistent with past studies on
trophy hunting (Knapp, 2007). In addition, only shipments with the Purpose Code “Hunting”(H) or “Personal” (P) were selected. An exception was made for the term “Trophies”, forwhich shipments reported with the purpose “Commercial Trade” (T) were also included.
Only shipments reported without units (i.e. reported as number of trophy items) wereconsidered in the analysis.
Summaries of country visits
Visits were organized by TRAFFIC to each target country in March‐April 2013 in order to meet anddiscuss with CITES authorities as well as with consultants, who gathered relevant information, (e.g.
about CITES legislation). The list of authorities that attended the meetings is provided in Annex I.
The type of information gathered during the visits and interviews included:
 national CITES legislation,
 the structure and responsibilities of CITES agencies,
 the extent of interagency and cross‐border collaboration among CITES authorities nationallyand regionally, training needs,
 implications of the formation of the Eurasian Customs Union for CITES, and challenges in CITES implementation, also in light of the emerging Eurasian Customs Union.
This section also provides some general background information, such as area, government type anda map. This information was downloaded from the Central Intelligence Agency (CIA) World Factbook
website (https://www.cia.gov/library/publications/the‐world‐factbook/) in August‐September 2013.

3 The weight estimation of caviar flasks/cans is based on TRAFFIC’s experience and is likely to be a conservative

estimate.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

10

BACKGROUND ON THE EURASIAN CUSTOMS UNION (ECU)
The member countries of the ECU are the Republic of Belarus (hereafter Belarus), the Republic of
Kazakhstan (hereafter Kazakhstan) and the Russian Federation (hereafter Russia). They form an
integrated Customs area which is part of the Eurasian Economic Community (EurAsEC, Krotov, 2011).
EurAsEC is an international economic organisation which is aimed at forming common external
Customs borders and developing common external economic policy, tariffs, prices and otherfunctioning parts of a common market, adapted from the European Union, the World Trade
Organization and other international norms (Anon, 2013e). The Agreement to create the EurAsEC
was signed on 10 October 2000 by Belarus, Kazakhstan, Kyrgyzstan, Russia and Tajikistan. Uzbekistan
joined the EurAsEC in 2005 however, in 2008, Uzbekistan suspended participation in the work of
EurAsEC bodies (Anon, 2013e). Moldova, Ukraine and Armenia are observers. In accordance with thestatutory goals and objectives of EurAsEC and guided by the principle of multispeed integration, theECU was formally created by Belarus, Kazakhstan and Russia in 2007 and it came into effect inJanuary 2010. The next step in the integration process was the creation of the Common Economic
Space (CES) in January 2012. Its full function work will begin in 2015, which is the planned start of
the Eurasian Economic Union, implying an even greater level of integration. Other EurAsEC States
will join the ECU and the CES when their economies and legislative systems are ready (Anon, 2013e).
The key stages in the development of the ECU are set out in Table 1. All current members of the ECU
are Parties to CITES.

Table 1: Chronology of key developments in the establishment of the ECU
Date
6 October 2007
28 November
2009
1 January 2010

1 July 2010

April 2011

July 2011
1 January 2012

Development
ECU formally established by the signing of the Treaty on the Establishment ofan Integrated Customs Area and Formation of a Customs Union in Dushanbe,
Tajikistan.
Meeting of the Presidents of Belarus, Kazakhstan and Russia in Minsk(Belarus). Following this meeting, a number of intergovernmental agreements
were signed to implement the ECU in practice.
ECU comes into effect with the implementation of a single Customs tariff. TheECU Commission, the ECU’s permanent functioning regulatory body, formally
begins work.
‐ Existence of common Customs territory declared and ECU common Customs
Code comes into effect, replacing domestic legislation in the ECU member
countries.
‐ Removal of internal border controls (with some transitional periods inrelation to the Russia‐Kazakhstan border) allows free circulation of imported
goods within the ECU territory and for goods originating within the ECU.*
Start of negotiations with the Kyrgyz Republic (Kyrgyzstan) on futureaccession to the ECU:
- In October 2011 Kyrgyzstan receives the green light from the other ECU
countries for accession.
- Work is currently underway on a roadmap for Kyrgyzstan’s accession, aprocess that Russia is encouraging to take place as quickly as possible.
Elimination of internal physical border controls.
Common Economic Space (CES) comes into effect ‐ to ensure the freedom of
movement of goods, services, capital, labour and equal treatment of economic
entities.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

11

Date
1 July 2012
1 January 2015

Development
Eurasian Economic Commission (EEC, replacing the ECU Commission) becomes
effective.
Planned start of the Eurasian Economic Union ‐ a greater level of integration
based on the ECU and the CES among the ECU member countries.

Source: Anon. (2012b); Dragneva and Wolczuk (2012); Plekhanov (2012), taken from TRAFFIC, 2012
*Although Customs controls now occur only at external ECU borders, a number of non‐tariff trade barriers (e.g. technicaland sanitary regulations) are yet to be fully removed.
Note: On 6 March 2012, the “Republic of South Ossetia”, an internationally disputed territory that is adjacent to Russia,
unilaterally declared the elimination of its Customs border with the ECU. South Ossetia is home to many species endemic
to the Caucasus. Georgia has not recognized the existence of South Ossetia as a political entity and regards most of its
territory as a part of the Shida Kartli region under Georgian sovereignty, occupied by the Russian army.

The ECU is a form of trade and economic integration between the Parties that envisages a common
Customs territory in the framework of which goods exchanged in mutual trade that originated fromthe common Customs territory and also those originating from third countries and freely circulatingin this Customs territory are exempt from Customs duties and economic restrictions. At the sametime the member countries apply a unified Customs tariff and other unified measures for regulating
commodity trading with third countries (Anon, 2013e).
A unified regulatory supranational standing body – The Customs Union Commission – started
operating on 1 January, 2010. Its main objective is to provide conditions for the functioning anddevelopment of the ECU. From 1 July 2012, the Eurasian Economic Commission (EEC) replaced the
ECU Commission. The EurAsEC Interstate Council is the supreme body of the Customs Union. (Anon,
2013e).
Common ECU legislation
Currently there is a single Customs Code of the ECU. All relevant provisions of other national
legislative and regulatory enactments have had to be harmonized to this Code in all member
countries.
Regarding CITES, there are special rules governing the procedure of wildlife trade across externalborders. The ECU legal framework consists of Decision of the Customs Union Commission of 18 June2010 No. 311 ‘regulation on the procedure for Customs operations execution regarding personal use
goods moved across the Customs border by a natural person and reflecting the fact of admitting such
goods not supervised by the Customs’ and EEC ruling of 16 Aug 2012 No. 134. These establish theprocedures for the export of endangered wildlife from the Customs territory of the ECU and when
the species are listed in the Red Data Books4 of Belarus, Kazakhstan and Russia, they prescribe
mandatory written declaration on export via the external Customs border even when the purpose of
the export is personal (i.e. non‐commercial).
Future membership and preparations for accession
Kyrgyzstan’s accession to ECU was agreed in April 2010, which was followed by a preparatory
process for outlining the steps required before accession. In May 2013, ECU and Kyrgyzstan signed amemorandum on the development of co‐operation in Minsk, Belarus. The document sets thetimeline for the elaboration of a roadmap for Kyrgyzstan’s accession to the ECU, which is planned tobe completed by the end of 2013. As part of the preparation for accession, the Kyrgyz government
adopted Government Decree No.269 Amendments to the Government Decree on the Inter‐agency
Negotiation Commission (under the Government of the Kyrgyzstan) on Kyrgyzstan’s accession to theCustoms Union of the Republic of Belarus, the Republic of Kazakhstan and the Russian Federationand the Single Economic Area. In addition to these, an action plan for the accession of Kyrgyzstan to4

In the target countries, the so‐called “Red Data Book” lists nationally protected species.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

12the ECU has also been adopted for 2012‐2013 by the EEC’s working group. The action plan comprises
actions such as analysis of:
Kyrgyzstan’s trade regimes with third countries;
The equipment and technical facilities (including buildings, premises and constructions),
which are needed to organize border, Customs, sanitary, quarantine, phytosanitary andtransport control at checkpoints at the Kyrgyz external borders of the ECU so that these meetthe ECU Common standard requirements adopted by the ECU Committee on 22 June 2011(No. 688);
The national legislation and international treaties to ensure harmonization with thecontractual legal framework of the ECU in the relevant areas.
Before joining the ECU, it is expected that Kyrgyzstan will need to enact or amend approximately 200
regulations in order to meet the requirements set by the ECU.
In preparation for the accession, Kyrgyzstan is radically changing its Customs legislation. The main
directions set for the development of the Customs administration until 2015 include:
Priority of electronic administration vs. paper based administration;
Use of the integrated software and technical tools which automate State supervisionfunctions at the Customs checkpoints;
Ensuring access for Customs authorities in other ECU member countries to information
systems of other State authorities, which centralize permit information relevant for theexport/import of goods subject to supervision by other bodies;
Implementation of a unique identifier (code) for every importer/exporter, which will allow
the tracking of shipments;
Creating special channels for quick processing of the ECU citizens at the main land, air andmaritime border crossing points;
Development of legislation:
 Adoption of the new Customs Code of the ECU;
 Signing of a treaty on standardisation of sanctions of criminal and administrative
offences; Joining (or implementation of provisions of) international treaties which facilitate, firstof all, international transport (transit); Ratification of international treaties, which form the contractual legal framework of the
ECU and the Single Economic Area;
 Increase co‐operation and information exchange among the Customs authorities of the
ECU member States regarding criminal and administrative cases; Partnership and co‐operation with economic entities to combat illegal trafficking andviolation of Customs rules, and to prevent abuse of authority/contravention of ethicalnorms by Customs officers.
The future is also likely to see further enlargement of the ECU to include participants such as
Armenia and Tajikistan.
Armenia has expressed its desire to join the ECU; however, it does not currently border an ECU
member country – a precondition for membership. Its position is therefore dependent on future ECU
developments (Dragneva and Wolczuk, 2012). In a September 2013 statement, jointly issued by the
Armenian president (Serzh Sargsyan) and the Russian president (Vladimir Putin), the Armenian
President voiced the country’s decision to join the ECU and take the relevant required practicalsteps, and later participate in forming the Eurasian Economic Union (Anon., 2013b).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

13

As early as 2007, when the ECU signature ceremony took place in its capital, Tajikistan (not a Party to
CITES) expressed a desire to join the ECU. However, given that Tajikistan does not currently borderan ECU member country – a precondition for membership – its position is dependent on
developments with regard to Kyrgyzstan (Dragneva and Wolczuk, 2012). Tajikistan’s intention to join
the ECU was officially announced by the Ministry of Economic Development and Trade in September
2012 (Anon., 2013l). The intention was confirmed during the round table “The Customs Union andTajikistan: A new perspective of integration”, which was held in September 2012 in Dushanbe (Anon,
2013m). According to the statement of the general secretary of EurAsEC, Tair Mansurov, the Tajik
President Emomali Rahmon said that Tajikistan not only wants to join the ECU, but is also eager tostart preparing itself for accession (Anon., 2012f). More recently however, the process of
convergence between Tajikistan and the ECU has slowed down due to several unresolved issues
mainly related to illegal labour migration and narcotics trafficking (e.g. Anon, 2012g).
CITES in the ECU
When the first ECU agreements between Russia and Belarus were signed, both countries accepted tofollow their obligations under CITES. The first document concerning this was Resolution of theGovernment of Russian Federation No. 948 of 25 August 1999 On the adoption of rules(pharmaceutical, technical, medical, sanitary, veterinary and ecological) concerning the goods being
imported to the countries of the ECU. According to article 14, “the countries of the Customs Union
must follow the rules of CITES during Customs control of animals, plants and their derivatives thatare listed on the CITES Appendices”.
The consolidated list of goods that are prohibited or limited in trade between the countries of the
ECU and the non‐Customs union member countries of the EurAsEC was agreed by the Decision of theIntergovernmental Council of EEC5 No. 19 of 27 Nov 2009 concerning unified non‐tariff regulation in
the ECU. The document lists various commodities (e.g. weapons, explosives, narcotics, etc.) for the
cross‐border movement of which, permits or other documents are still required. Chapter 2.7 of thisdecision also lists CITES‐listed species. The species listed in this chapter have been agreed to be kept
up to date in‐line with the actual CITES Appendices by the CITES Management Authority (MA) of
Russia. With this, the Russian CITES MA has been assigned a leading role among the CITESManagement Authorities of ECU. The latest amendments to Chapter 2.7 were made by EEC
Resolution No.134 of 16 August 2012.
The necessity to resolve the problem of transportation of CITES specimens between the ECU
countries was discussed at the time of the establishment of the ECU. At the meeting of the expert
group on “application of non‐economic prohibitions and restrictions in trade between the ECU
member countries”, held on 12 October 2010 in Moscow, it was decided that the procedure formoving goods of wild flora and fauna and the collection of wildlife from the wild within the common
Customs area will be harmonized. The participants at the meeting agreed on the need formaintaining the licensing procedures for the movement of commodities between the member
countries of the ECU. At the same meeting, it was also decided that Belarus would prepare proposals
on harmonization of procedures for issuing documentation for species listed in the CITES Appendicesand/or in the Red Data Books of the ECU member countries. According to the findings of this project,
this decision has not been implemented or followed up on. It also became apparent during thecountry visits that the CITES authorities of the ECU member countries were not aware of thisdecision.

5

Eurasian Economic Commission (EEC) – the single permanent regulatory body (supranational governing body)of the ECU

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

14However, in practice the CITES authorities (including Customs) in the current ECU member countries
reported the complete lack of Customs control on internal trade, including of CITES‐listed specimens.
Therefore the above presented requirements regarding the control of internal trade for CITES arereported to be generally not implemented.
Even if CITES documents are still required for internal trade within the ECU, as before, there are anumber of issues that need considering and to be dealt with. In the CES, goods are moved freely
with fewer opportunities for control. Imaginary scenarios are provided below to help illustrate thepotential implications of the ECU for CITES implementation.
Hypothetical example 1 – “permit shopping”: a trader applies for a CITES export permit in
Kazakhstan for the export of a live Common Kestrel Falco tinnunculus that has been taken from thewild in Kazakhstan. The Kazakh Scientific Authority (SA) cannot make a non‐detriment finding andthe Management Authority (MA) thus does not issue the requested export permit. The same trader
could take the specimen easily (but illegally) across the border to Russia (or Belarus) as there are nointernal Customs controls. Then the trader could apply for an export permit from Russia, claimingthat the specimen was taken from the wild in Russia. Without an agreed and formalized mechanism
for sharing information on rejected CITES permit applications in the ECU member countries, would
the MA in Russia exercise more care when determining that the specimen was indeed from Russia?
And what can Kazakhstan do to protect its wildlife?
Hypothetical example 2 – “exploiting the weakest link in the chain”: illegal traders of sturgeon
caviar willing to smuggle caviar into the European Union (EU) find that Customs officers at theexternal ECU borders in Belarus are less attentive to caviar trade than Customs officers in
Kazakhstan or Russia. The smugglers therefore change their trade route and instead of using airlines
from Russia to the EU for taking the caviar, they swap to the road and try to smuggle the caviar via
Belarus. If there is not a mechanism to ensure that information on detected cases of illegal trade(species, specimens in trade, methods of concealment, etc.) is shared among ECU members, howwould Belarus Customs know that more attention should be paid to illegal caviar trade to the EU?
Hypothetical example 3 – “assistance needed from fellow ECU members”: The demand for
medicinal products containing Costus Root Saussurea costus (App. I) increases in Russia withproducts appearing on the market without CITES permits to prove their legal origin. The products
enter Russia via Kazakhstan from China. What can Russia do alone to protect its market from illegal
Costus Root products without co‐operation and information sharing with its fellow ECU members?
Hypothetical example 4 – “concerns raised by the importer”: Russia has issued an export permit for
the trophy of a Wolf Canis lupus for an EU hunter. The EU has stricter measures for Wolf and hunting
trophies: i) the Wolf is treated in the EU as if it was listed in Appendix I and so the EU requires animport permit along with the export permit, ii) Kazakhstan and Russia have a Scientific Review Grouppositive opinion6 in place for Wolf trophies, however imports of Wolf trophies from Belarus havebeen suspended. When the EU evaluates the application for the import permit, it needs to besatisfied that the specimen was indeed taken in Russia and not in Belarus (due to the different
opinions in place) and if this cannot be proven adequately, the EU may refuse to issue the importpermit. Similarly, in the case of any nationally applied export quotas in ECU member countries, there
may be questions by the importer regarding the exact country of origin within the ECU.
6The Scientific Review Group (SRG) consists of representatives from EU Scientific Authorities. If the SRG canmake a positive non‐detriment finding and thus allow the import when an import application is being
considered, the Positive Opinion remains valid for subsequent import permit requests for the given
species/country combination as long as the conservation and trade status have not changed significantly. (Seealso Annex II.)

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

15

The EU has seen at least one actual example similar to hypothetical example 4 above, reported by
Latvia. In December 2011, Latvia received an application for an import permit from Belarus for three
stuffed specimens of Brown Bear7. The specimens were accompanied by an export permit (note nota re‐export certificate) issued by Belarus along with hunting permits indicating that the specimens
had been hunted in Russia (Kamchatka region). The Latvian MA contacted their counterparts in
Belarus to inquire about the inconsistencies found but no answer was received. As a result, theapplication for the CITES import permit was refused (G. Strode, Latvian CITES MA in litt. to K. Kecse‐
Nagy, October 2013).

7

In the EU, Brown Bear is treated as if it was listed in App. I and thus an import permit is also required inaddition to the export permit. (See also Annex II on EU stricter measures.)Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

16

OVERVIEW OF THE REPORTED TRADE IN CITES‐LISTED SPECIES IN THE TARGET COUNTRIESThis section examines reported trade involving the target countries between 2000 and 2010,
focusing on groups of CITES‐listed species that are of particular relevance for this region.
Tables 2 and 3 provide an overview of total reported imports, exports and re‐exports of selected
CITES‐listed animal and plant groups by the target countries during this period, in terms of numbersof specimens. Each of these commodity groups are discussed in more detail below, including
information on trends between 2000 and 2010, the most important importers and exporters, traderoutes and, where relevant, the most important taxa traded in each commodity group and thesource of specimens traded.
For most commodity groups, it was generally the case that either imports into or exports from thetarget countries exhibited particularly noteworthy trends. Therefore, in such cases only the major
trade direction (i.e. either imports or exports) are discussed in detail below. However, where thetarget countries were found to be important importers and exporters of a particular commodity
group, both imports and exports are discussed under separate headings in the sections below.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

17

Table 2 Reported imports of selected CITES‐listed animal and plant groups by the target countries (2000‐2010) (number of specimens, unless otherwise
stated), ordered by number of trade records (all purposes and sources)
BY

KZ

KG

RU

TJ

UZ
Imp.
Exp.
0
9545

Imp.
310

Total
Exp.
1 104 021

4742

10

376 059

3235

2890

4888

31 713

16

186

133

620

8934

N.R.

0

0

8

299

4528

166 019 kg

N.R.

0

0

0

0

166 399 kg

74 234

N.R.

54

7049

3366

7137

77 933

Imp.
0

Exp.
6597

Imp.
179

Exp.
44 456

Imp.
0

Exp.
1693

Imp.
131

Exp.
1 041 395

Imp.
N.R.

Exp.
335

Live plants

0

11 87305090

012 221

0342 133

N.R.

0

10

Live birds

13

34

1244

1902

0

123

396

26 764N.R.

0Live mammals

58

388

153

498

0

32

223

7867

N.R.

Hunting trophies

1

38

0

41

0

4

298

4437

Coral

0

0

0

380 kg000Live reptiles

7

104

4

173

0

2

77

Reptile bodies, parts and derivatives

Table 3 Reported exports of selected CITES‐listed animal and plant groups by the target countries (2000‐2010) (number of specimens, unless otherwise
stated), ordered by number of trade records (all purposes and sources)

Hunting
trophies8
Live mammals

BY
Imp.
Exp.
53
167

KZ
Imp.
100

KG
Exp.
126

Imp.
430

Exp.
668

RU
Imp.
5326

Exp.
7369

Imp.
655

TJ
Exp.
701

Imp.
11

UZ
Exp.
13

Total
Imp.
Exp.
6575
9044

61

204

60

116

7

9

1952

3360

3

0

33

240

2116

3929

Live birds

1

31

1030

787

1

0

4009

5540

7

0

4843

10971

9891

17 329Live reptiles

112

355

13

41 03600

33 89440 37821 0540362 953385 465

418 026467 234

Caviar37 kg

0

108 847 kg

101 933 kg

3 kg

0

121 022 kg

84 687 kg

0

0

24 kg

0

229 933 kg

186 621 kg

Medicinals9

6 kg

3 kg

3000 kg

26 500 kg

004772 kg

782 kg00007778 kg

27 285 kg

1320

2512

0

0

0

0

1 017 044

1 477 700

0

0

0

0

1 018 364

1 480 212

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, N.R. – not relevant, RU – Russian Federation, TJ – Tajikistan, UZ – Uzbekistan. Imp. – Importers’ Reports, Exp. – Exporters’
Reports. Notes: Kyrgyzstan became a CITES Party in 2007 and submitted its first annual report for 2009, Russia did not submit an annual report for 2006, Tajikistan is not a CITES Party and sodoes not submit annual reports. Explanation on what the different commodity groups comprise is provided in the relevant sections below.
8This includes both: (i) trophies reported as direct exports from the target countries (no country of origin reported); and (ii) trophies for which a target country was reported as the country oforigin (country of origin taken to be the country of export). The latter were included in total exports, primarily to ensure that significant exports of Argali Ovis ammon trophy items from
Kyrgyzstan and Tajikistan were accounted for in the totals (the majority of these trophy items were exported to RU, however trade was not reported until their subsequent re‐export from
Russia due to: (a) in general, a lack of reporting of imports by Russia; and (b) non‐reporting by Kyrgyzstan (2000‐2008) and Tajikistan (2000‐2010) as non‐Parties to CITES).

9

The term “medicinals” is used in this report to refer to medicinal products and also to parts and derivatives for medicinal use.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

18

Live reptiles(Re‐)exports of live reptiles
A total of 467 234 live reptiles were (re‐)exported from the target countries during the period 2000‐
2010, according to exporters’ reports. The leading (re‐)exporter was Uzbekistan (385 465
specimens), followed by Kazakhstan (41 036 specimens) and Russia (40 378 specimens) and, whenimporters’ reports are considered, Tajikistan (21 054 specimens).
The vast majority of (re‐)exports of live reptiles from the target countries involved Testudinidae
specimens (over 98% of total (re‐)exports or 460 554 specimens, almost all of which were of wild
origin). Of these, over 99% (458 856 specimens) were (re‐)exports of Horsfield’s Tortoise Testudo
horsfieldii. Uzbekistan was responsible for the majority of Horsfield’s Tortoise (re‐)exports from thetarget countries during the period 2000‐2010 (84% of total specimens (re‐)exported), with smaller
quantities (re‐)exported from Russia, Kazakhstan and, when importers’ reports were considered,Tajikistan (Figure 2). Tajikistan also featured as an important country of origin for live re‐exports ofHorsfield’s Tortoise, with nearly 138 245 specimens re‐exported during the period 2000‐2010
reportedly originating in Tajikistan, according to exporters’ reports. Live specimens of Horsfield’s
Tortoise were frequently exported to end consumer markets via Ukraine: Ukraine re‐exported
126 628 specimens between 2000 and 2010, 85% of which originated in Tajikistan and 15% of which
originated in Uzbekistan.
Figure 2
Reported (re‐)exports of live reptiles from the target countries (2000‐2010), exporters’ reports

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: BY – Belarus, KZ – Kazakhstan, RU – Russia, TJ – Tajikistan, UZ – Uzbekistan.
*Importers’ reports are used for Russia (for 2006 only) and Tajikistan (all years) for the reasons outlined in the
Methodology section (no Annual Reports submitted by these target countries for those years). No (re‐)exports of live
reptiles were reported from Kyrgyzstan during the period 2000‐2010 (according to importers’ and exporters’ reports)

It is noted that, according to importers’ reports, in 2000 Russia re‐exported a particularly largecommercial shipment of 10 000 wild specimens of Horsfield’s Tortoise from Kazakhstan to China;
however this was not reported as a re‐export by Russia.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

19

The main importers of Horsfield’s Tortoise from the target countries were the USA (191 005
specimens), the EU (135 297 specimens) and Japan (78 700 specimens), according to exporters’
reports. (Re‐)exports of this species from Uzbekistan, the main (re‐)exporter, to the EU increased
during the period 2000‐2010, despite a ban on the import of wild specimens of Horsfield’s Tortoise
into the EU from 2000 to 2006 (see also Annex II on EU stricter measures). The majority of these (re‐)exports from Uzbekistan were reported as Ranched (source code R): the number of ranchedspecimens of Horsfield’s Tortoise (re‐)exported from Uzbekistan increased from zero in 2000, to2000 specimens in 2001, to 16 904 specimens in 2010 (exporters’ reports).
Currently the EU has an import suspension in place for Kazakhstan for the species, while imports offrom Tajikistan (wild taken specimens) and from Uzbekistan (wild taken and ranched specimens)
have Positive Opinions in place (see also Annex II). Uzbekistan has established export quotas for the
species for 2013 both for ranched and wild‐taken specimens, each set at 45 000 specimens per year
(see Annex III).
Review of Significant Trade
The CITES Review of Significant Trade (RST) procedure (defined in Resolution Conf. 12.8 (Rev.
CoP13)) was designed to identify species that may be subject to unsustainable levels of international
trade, and to identify problems and solutions concerning effective implementation of theConvention.
Horsfield’s Tortoise Testudo horsfieldii
At the 25th meeting of the CITES Animals Committee (AC25, in July 2011), as part of the RST process,Tajikistan and Uzbekistan were categorised as of possible concern for trading in Horsfield’s Tortoise
and were requested that information be provided on the following issues within 90 days:
Tajikistan:a) Information on population distribution, size and trends; andb) Justification for and details of the scientific basis by which it has been established that the current
quota for wild specimens is not detrimental to the survival of the species and in compliance with
Article IV, paragraphs 2 (a) and 3, taking into account any potential unregulated and/or illegal
offtake and trade.
At SC62 (July 2012), it was concluded that although no response was received by the Secretariat inrelation to the recommendations of the Animals Committee, in view of the absence of recent tradein this species, the Secretariat should liaise with Tajikistan to determine whether it is still exporting
specimens of T. horsfieldii, and to report at the SC6310.
(According to information provided by Tajikistan as part of this project, a moratorium has been
declared on the export of wild animals native to Tajikistan, unless a harvest quota is set. No quotas
could be set for live tortoises (including T. horsfieldii) due to a lack of data on the number and statusof populations in the wild. See section on Tajikistan.)Uzbekistan:a) Justification for and details of, the scientific basis by which it has been established that the current
quotas are not detrimental to the survival of the species and are in compliance with Article IV,paragraphs 2 (a) and 3, taking into account any potential unregulated and/or illegal offtake andtrade; and10

The summry records of the 63rd meeting of the Standing Committee was not available at the time of writing.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

20b) Additional information to demonstrate how the impact of ranching operations on the wild
population is assessed, including an assessment of the survival rate of female specimens used in theranching operation.
At SC62 (July 2012), it was concluded that Uzbekistan complied with the recommendations of theAnimals Committee, the species/country were removed from the review. (See detailed response
provided by Uzbekistan in SC62 Doc. 27.1 (Rev. 1).)
Source: Anon., 2012d, Anon., 2012cOther live reptiles (re‐)exported from the target countries included: i) lizards (3823 specimens in
total, nearly all of captive‐bred origin) of the families Agamidae (2050 specimens), Chamaeleonidae(1308 specimens) and Varanidae (450 specimens); and ii) snakes (2669 specimens, 53% of wild
origin).
According to importers’ reports, between 2003 and 2006, Lebanon (a non‐Party to CITES at the time)
re‐exported 19 131 live specimens of lizard, turtle and tortoise to Thailand and Japan, all of whichwere declared as having been captive‐bred with the country of origin reported as Kazakhstan. Of thistotal, the majority of specimens (re‐)exported were tortoises (63%), particularly the Indian Star
Tortoise Geochelone elegans (10 170 specimens), a species that has previously been identified as the
subject of possible false claims of captive‐breeding (TRAFFIC, 2011). Other live reptiles reported as(re‐)exported from Lebanon during the period 2000 to 2010 with Kazakhstan as the country of origin
included chameleons (4607 specimens or 24% of total (re‐)exports) and turtles of the family
Geoemydidae (1097 specimens or 6% of total (re‐)exports). In addition, 2211 reportedly captive‐
bred live tortoises and chameleons were (re‐)exported from Thailand and Japan between 2004 and2010, with the country of origin reported as Kazakhstan (exporters’ reports). This figure was higher
when importer reported quantities were considered (3087 specimens), with Indian Star Tortoiseaccounting for 47% of specimens (re‐)exported. However, it is noted that Kazakhstan did not report
the export of any live captive‐bred reptiles to Japan, Lebanon or Thailand during the period 2000 to2010 (Todd, 2011).
In terms of longer‐term trends, (re‐)exports of live reptiles from Uzbekistan increased between 2000
and 2010, which is primarily a reflection of the above‐described increase in (re‐)exports ofspecimens of Horsfield’s Tortoise to the EU during this period. (Re‐)exports of live reptiles from
Russia and Kazakhstan appeared to fall from highs in 2000 and 2001.
Imports of live reptiles
The target countries imported a total of 79 333 live reptiles during the period 2000‐2010, according
to exporters’ reports. Russia was responsible for the majority of these imports (74 234 specimens,
almost 94% of the total), with key aspects of trade including the following:(i)
the import of captive‐bred iguanas from El Salvador (18 716 specimens);(ii)
the import of wild‐sourced snakes (mainly species of the family Pythonidae), lizards(families: Chamaeleonidae, Varanidae) and tortoises from Benin, Ghana and Togo;(iii)
the import of wild‐sourced alligators, snakes (family: Boidae) and lizards (families Teiidae
and Iguanidae) from Guyana and Suriname (4560 specimens); and(iv)
the import of wild and captive‐bred snakes (mainly species of the family Pythonidae),tortoises/turtles and lizards (family: Varanidae) from Indonesia (3803 specimens).
Imports of live reptiles into the target countries remained relatively constant during the period
2000‐2010. An exception is a peak in imports into Russia in 2000, which is due to a single import of
35 000 live specimens of Horsfield’s Tortoise of wild origin from Kazakhstan. Likewise, the peak in

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

21

imports into the target countries (excluding Russia) in 2005 also relates to intra‐target country trade,reflecting the commercial import of 3327 live specimens of Horsfield’s Tortoise (reportedly wild‐
origin) by Uzbekistan from Russia; country of origin Tajikistan.
Hunting trophies
A total of 904411 hunting trophies were exported from the target countries during the period 2000‐
2010, according to exporters’ reports. This includes both: (i) trophies reported as direct exports fromthe target countries (no country of origin reported); and (ii) trophies for which a target country wasreported as the country of origin (country of origin taken to be the country of export)12. The latter
were included in total exports, primarily to ensure that significant exports of Argali Ovis ammon
trophy items from Kyrgyzstan and Tajikistan were accounted for in the totals (the majority of thesetrophy items were exported to Russia, however trade was not reported until their subsequent re‐export from Russia due to: (a) in general, a lack of reporting of imports by Russia; and (b) non‐reporting by Kyrgyzstan (2000‐2008) and Tajikistan (2000‐2010) as non‐Parties to CITES.
The majority (81%) of trophy items were exported from Russia (7369 trophies), with smaller
numbers exported from Tajikistan (701 trophies), Kyrgyzstan (668 trophies), Belarus (167 trophies)
and Kazakhstan (126 trophies), according to exporters’ reports. When importers’ reports wereconsidered, hunting trophy exports from these target countries were as follows: Russia (5326
trophies), Tajikistan (655 trophies), Kyrgyzstan (430 trophies), Kazakhstan (100 trophies) and Belarus(53 trophies). As would generally be expected, nearly all trophy items exported from the target
countries were of reportedly wild origin.
Exports of hunting trophies from Russia showed a general decline over the period 2000‐2010 (Table4). Exports of hunting trophies from the other target countries peaked in 2000, following which
exports fluctuated at between approx. 70 and 140 trophy items exported per year, with a second
smaller peak in 2009 (Table 4). Exports from the target countries (excluding Russia) appeared slightly
higher after 2007, primarily due to increased exports from Kyrgyzstan and Tajikistan (Table 4).
However, exports from Tajikistan fell in 2010, with just 23 trophies exported (importers’ reports).
Exports of trophy items from Belarus appeared to cease after 2006, according to exporters’ reports(Table 4).

11 It is noted that a (re‐)export of 3600 gall bladders from Russia to Lithuania in 2007 was excluded from theanalysis of hunting trophies, despite it being reported with the Hunting (H) Purpose Code. This was assumed to
be an error, and is analysed instead in the section on Medicinals.
12
It is important to bear in mind that the initial import and subsequent re‐export may have taken place indifferent years. Therefore, in this Section, where exports from the target countries are referred to have takenplace in a particular year; this should be taken as an approximation based on the trade data available.
However, the majority of re‐exports to which this applies are of Argali Ovis ammon trophies that originated in
Kyrgyzstan and Tajikistan and which were re‐exported from Russia. It would seem unlikely for there to be aconsiderable time lag between import and re‐export in such cases.

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22

Table 4
Reported annual exports by the target countries of hunting trophies, exporters’ reports (2000‐
2010)*
2000
64
33
65
1050
82
8

2001
25
19
15
1023
11

2002
15
2
81
860
56
1

2003
37
5
55
1060
41
2

2004
8
26
638
33
-

Year
2005
11
4
33
763
66
2

2006
2007
2008
2009
2010
BY
7
KZ
9
3
16
18
17
KG
24
31
23
60
88
RU
423
663
500
419
384
TJ
77
63
104
99
23
UZ
Annual
1302
1093
1015
1200
705
879
540
760
643
596
512
total
*Includes both: (i) trophies reported as direct exports from the target countries; and (ii) trophies for which a target country
was reported as the country of origin.
**Numbers in italics are taken from importers’ reports. Importers’ reports are used for Russia (for 2006 only), for
Kyrgyzstan (2000‐2008) and for Tajikistan (all years) for the reasons outlined in the Methodology section (no Annual
Reports submitted by these target countries for those years).
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russia, TJ – Tajikistan, UZ – Uzbekistan.

Main taxonomic groups in trade
The main taxonomic groups represented in hunting trophies exported from the target countries
were, according to exporter reported quantities:(i) Ursidae species (5020 trophies) ‐ mainly Brown Bear Ursus arctos trophies (5014 trophies)
exported from Russia. Exports of U. arctos trophies from Russia fluctuated between around 350
and 600 trophy items exported annually during the period 2000‐2010, showing a declining trend
after 2007. Exports of U. arctos trophies were also reported from Kazakhstan, but totalled only
14 trophy items between 2000 and 2010. The EU and the USA respectively imported 45% and
39% of total U. arctos trophy items exported from the target countries during the period 2000‐
2010. (See also Annex II for EU and USA stricter measures regarding the imports of trophies).
(ii) Canidae species (682 trophies) – all Wolf Canis lupus trophies were exported from Russia,
Belarus, Kazakhstan and Kyrgyzstan (exporters’ reports). Exports of C. lupus trophies from
Russia showed a declining trend during the period 2000‐2010, while exports from Kazakhstan
increased slightly after 2007 with between 11 and 15 trophy items exported per year in 2008,2009 and 2010. No exports of C. lupus trophies were recorded from Belarus from 2007‐2010,
after peaks of 64 and 37 trophy items reportedly exported in 2000 and 2003, respectively(exporters’ reports). This is likely due to the suspension of imports to the EU in 2003 (see Annex
II). Over 75% of C. lupus trophy items exported from the target countries during the period
2000‐2010 were imported by EU Member States, with the USA and Norway importing 8% and
5% of the total, respectively. (Again, see also Annex II for EU and USA stricter measures
regarding the imports of trophies).
iii) Anatidae species (1635 trophies) – all exported from Russia to Malta during the period 2000‐
2005 (exporters’ reports). These exports all involved Appendix III‐listed species, which werelisted by Ghana under Anatidae spp. in 1976. The Appendix III listing for these species was
subsequently deleted in 2007.
iv) Bovidae species (1501 trophies) – mainly Argali Ovis ammon trophies (1364 trophies) exported
primarily from Tajikistan and Kyrgyzstan (exporters’ reports). Exports of O. ammon trophiesfrom Tajikistan fluctuated quite widely during the period 2000‐2010, with peaks in 2008 and2009 and lows in 2001 and 2010 (Figure 3). Exports of O. ammon trophies from Tajikistan

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

23totalled 687 items for the period 2000‐2010 according to exporters’ reports; 635 items
according to importers’ reports.13
Russia reported having re‐exported 666 O. ammon trophy items originating from Tajikistan
between 2000 and 2010, chiefly to the USA (371 items) and EU (165 items). However, it is notedthat exports from Tajikistan were generally not reported as imports by Russia at the time ofexport: Russia reported the import of just seven O. ammon trophy items from Tajikistan during
the period 1975‐2010 (in 2003, 2009 and 2010).
Between 2000 and 2004, exports of O. ammon trophies from Kyrgyzstan appeared to mirror
trends in exports from Tajikistan (Figure 3). However, these trends then appear to diverge, until
after 2008, exports of O. ammon trophies from Kyrgyzstan begin to increase while exports fromTajikistan decline (Figure 3). This is due to a moratorium on hunting Marco Polo Sheep O.
ammon polii, which was in effect from autumn 2008 to September 2010 (Mallon, 2013). Exportsof O. ammon trophies from Kyrgyzstan totalled 614 items for the period 2000‐2010 according toexporters’ reports; 417 items according to importers’ reports.14 Russia re‐exported 488 trophy
items from Kyrgyzstan between 2000 and 2010, chiefly to the USA (244 items) and EU (179
items). It is again noted that exports of O. ammon trophies were generally not reported asimports by Russia at the time of export: Russia reported the import of just seven O. ammon
trophy items from Kyrgyzstan during the period 1975‐2010 (in 2009 and 2010).
In Kyrgyzstan, Argali O. ammon hunting quotas in 2010 and 2011 were set at 70 per year, 10
allocated for scientific purposes and 60 for hunting. In 2010, 53 out of 70 trophies allowed weretaken and in 2011 69 out of 70 (Mallon, 2013). In Tajikistan, following a moratorium on hunting
Marco Polo Sheep O. ammon polii, in effect from autumn 2008 to September 2010, the hunting
quotas for 2010/2011 and for 2011/2012 were set at 80 specimens for each hunting season. In
both countries, hunting quotas are reported to be set based on the most recent population
census (Mallon, 2013).
v) Felidae species (167 trophies), nearly all of which were Eurasian Lynx Lynx lynx trophies
exported by Russia, primarily to the EU (138 items) (exporters’ reports).

13

Tajikistan is not a party to CITES and, as such, does not submit Annual Reports of trade under theConvention. Therefore importer reported quantities, although lower overall than quantities reported byexporters, should be taken into consideration to account for direct exports of Ovis ammon trophy items fromTajikistan, i.e. where Tajikistan is the reported exporter, rather than the reported country of origin.
14
Kyrgyzstan did not become a party to CITES until 2007, reporting trade in CITES species for the first time forthe year 2009. Therefore importer reported quantities, although lower overall than quantities reported byexporters, should be taken into consideration to account for direct exports of Ovis ammon trophy items from
Kyrgyzstan for the period 2000‐2008, i.e. where Kyrgyzstan is the reported exporter, rather than the reported
country of origin.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

24Figure 3
Reported exports* of Ovis ammon hunting trophy items from the target countries (2000‐2010),
exporters’ reports**

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
*Includes both: (i) trophies reported as direct exports from the target countries; and (ii) trophies for which a target country
was reported as the country of origin.
**Importers’ reports are used for Russia (for 2006 only), for Kyrgyzstan (2000‐2008) and for Tajikistan (all years) for thereasons outlined in the Methodology section (no Annual Reports submitted by these target countries for those years).
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russia, TJ – Tajikistan, UZ – Uzbekistan.

Destinations of trophies
The EU was an important destination for hunting trophies exported from the target countries during
the period 2000‐2010. According to exporter reported quantities, 5005 trophies were imported into
the EU between 2000 and 2010, the leading importers being Malta (1635 trophies – all Anatidae
trophies), Germany (752 trophies), Spain (431 trophies) and France (353 trophies). The USA was theleading non‐EU importer of hunting trophies exported from the target countries, importing 2850
trophies between 2000 and 2010 (exporters’ reports). Norway, Mexico and Canada imported smaller
numbers of trophies from the target countries, importing 326, 242 and 146 trophies, respectively,
according to exporter reports. Given that the EU and the USA are key destinations for hunting
trophies from the region, Annex II provides details of the stricter import measures these countries
have introduced.

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25

Caviar (and other sturgeon products)
Reported caviar (re‐)exports from the target countries totalled 231 292 kg between 2000 and 2010,
according to importers’ reports (186 621 kg according to exporters’ reports), and exhibited a generaldeclining trend during this period (Figure 4).
Figure 4
Reported (re‐)exports of caviar from Kazakhstan and Russia (2000‐2010), importers’ reports*

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: KZ – Kazakhstan, RU – Russia.
*Importer reported quantities were used to analyse exports of caviar during the period 2000‐2010. Russia only reported
exports of caviar in 2000 and 2001 and not for the period 2002‐2010 therefore importer reported quantities wereconsulted to reveal trends.

Kazakhstan and Russia were responsible for the majority of (re‐)exports from the target countries(108 847 kg and 121 875 kg, respectively, according to importers’ reports), nearly all of which
originated from wild sources. Importer reports were considered in the present analysis due to gaps
in reporting by Russia and Kazakhstan: Russia did not report any exports of caviar after 2001;
Kazakhstan did not report any exports of caviar in 2005 and 2006.
Key importers of caviar from the target countries were the USA (127 130 kg), the EU (70 897 kg),
Japan (10 389 kg), Switzerland (8235 kg), Turkey (7885 kg) and the UAE (4031 kg), according toimporters’ reports. Russia and Kazakhstan were also reported as the countries of origin for 95 091 kg
of caviar re‐exported from other countries between the years 2000 and 2010 (according toimporters’ reports), a key re‐exporter being the UAE, which re‐exported 38 841 kg or 41% of thistotal.
Export quotas for sturgeon caviar from the wild were not communicated by Kazakhstan and Russia
to the CITES Secretariat and thus these are zero for the quota year 2013 (1 March 2013 ‐ 28 February2014). The EU has had a negative opinion in place since 2010 for imports of wild taken caviar fromthe Caspian range States (see Annex II).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

26

Beluga Sturgeon Huso huso in the Review of Significant Trade process
Huso huso was previously included in the CITES Review of Significant Trade 2001‐2006 (actions
summarised in SC54 Doc. 30.1). The species was discussed again at the 23rd meeting of the Animals
Committee, when it was recommended that the Secretariat and the range States provide a
document at AC24, with detailed scientific information on which to base a decision (AC23 Summary
Record). A questionnaire was subsequently sent to the range States of H. huso requesting a responseby 31 October 2008. At AC24, H. huso was selected for inclusion in the Review of Significant Trade
process (AC24 Summary Record). At AC25, the working group decided to retain Bulgaria, Georgia,
Hungary, the Islamic Republic of Iran, Kazakhstan, Russia and Turkmenistan in the Review of
Significant Trade.
At AC26 (March 2012) the following range States of H. huso were identified as of possible concern:
the Islamic Republic of Iran, Kazakhstan and Russia; and the following recommendations were madeto them:Within 90 days, the Management Authority should:a) Provide the Secretariat with written confirmation that the commercial catch of H. huso is
prohibited during 2012.
Within two years, the Management Authority should:b) If planning to resume the commercial catch and export of wild H. huso in 2013, provide to theSecretariat with a justification for, and details of, the scientific basis by which it has been establishedthat any proposed export quota for H. huso will not be detrimental to the survival of the species andis in compliance with Article IV, paragraphs 2 (a) and 3.
At SC63 (March 2013), it was determined that recommendation a) had not been compiled with by
any of the countries and the Standing Committee recommended that all Parties suspend trade of
Huso huso with, among others, Kazakhstan, Russia (and Iran). The Standing Committee decided that
this recommendation would remain in effect until Kazakhstan and Russia demonstrated compliancewith Article IV, paragraphs 2 (a) and 3 for the species concerned and provided full information to theSecretariat regarding compliance with the recommendations of the Animals Committee. The tradesuspensions are still in effect at the time of writing.
Source: Anon, 2013j; Anon, 2012e; and Anon, 2013d.
Export of sturgeon meat and eggs
A total of 498 301 kg of sturgeon meat was exported from the target countries during the period
2000‐2010, according to exporters’ reports. Kazakhstan (436 973 kg) and Russia (61 328 kg) were
responsible for 100% of these exports: Kazakhstan exports were primarily destined for Russia(424 591 kg), while Russia exports were primarily destined for the USA (54 942 kg) (exporters’
reports). In terms of exports of live sturgeon eggs, Russia exported 520 005 specimens and 558 kg ofeggs during the period 2000‐2010 (exporters’ reports), with the EU (110 kg) and China (390 kg) the
leading importers during this period.

Live birds(Re‐)exports of live birds
During the period 2000‐2010, 17 329 live birds were (re‐)exported from the target countries,
according to exporters’ reports. The main families represented in (re‐)exports of live birds from thetarget countries were: (i) Strigidae (5031 specimens, almost all of wild origin); (ii) Falconidae (4890
specimens, 72% of captive‐bred origin); (iii) Psittacidae (3967 specimens, 97% of captive‐bred origin;

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

27

(iv) Accipitridae (2476 specimens, 87% of wild origin); and (v) Gruidae (458 specimens, 75% of wild
origin).
Uzbekistan was the leading (re‐)exporter of live birds among the target countries, exporting 10 971
specimens (or 63% of the total) between 2000 and 2010 (Figure 5). (Re‐)exports of captive‐bredbirds from Uzbekistan primarily involved Psittacidae and Falconidae specimens: exports of
Psittacidae specimens fluctuated considerably during the period 2004 to 2009, from around 100
specimens in some years to over 1000 specimens in others, but declining to close to zero in 2010
(exporters’ reports). (Re‐)exports of wild‐sourced birds from Uzbekistan primarily involved birds ofprey, particularly specimens of the families Accipitridae, Falconidae and Strigidae. (Re‐)exports ofwild specimens from Uzbekistan peaked in 2004, before declining sharply to zero across all taxa in2006 (according to both importer and exporter reports). For live birds of the family Falconidae, (re‐)exports of wild specimens fluctuated at low levels after 2006, while (re‐)exports of captive‐bred
specimens exhibited a slightly increasing trend from 2006 onwards. (See Annex III for 2013 CITES
export quotas for live birds for Uzbekistan.)
Russia exported 5540 live birds during the period 2000‐2010 (or 32% of total exports from the target
countries), with Kazakhstan accounting for just over 4% of the total (787 specimens). (Re‐)exports oflive birds from Russia appeared to decline during the period 2000‐2006 (Figure 5), beginning toincrease again in 2009 and 2010 but not to the levels seen earlier in the decade. (Re‐)exports of live
birds from Kazakhstan appeared to peak in 2008 (277 specimens (re‐)exported, according toexporters’ reports), which was primarily due to a single commercial export of 220 captive‐bred Saker
Falco cherrug specimens to the United Arab Emirates (UAE).
It is noted that Tajikistan was the reported country of origin for 1028 live birds re‐exported from
Russia (625 specimens) and Ukraine (403 specimens) to Japan during the period 2000‐2010(exporters’ reports). Nearly all of these commercial shipments involved wild‐taken specimens of thefamilies Falonidae and Strigidae, and took place in 2000 and 2001. However, the original exports ofthe specimens from Tajikistan to Russia and Ukraine were not reported (according to importer andexporter reports). Only two exports of live birds, involving a total of seven specimens, were reported
from Tajikistan after 2001 (importers’ reports).
The main importers of live birds exported from the target countries were Japan (7702 specimens),
the UAE (3164 specimens), the EU (1037 specimens) and the Ukraine (658 specimens), according toexporters’ reports.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

28

Figure 5
Reported exports of live birds from the target countries (2000‐2010), exporters’ reports

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
*Importers’ reports are used for Russia (for 2006 only), Kyrgyzstan (for 2000‐2008) and Tajikistan (all years) for the reasons
outlined in the Methodology section (no Annual Reports submitted by these target countries for those years).
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russian Federation, TJ – Tajikistan, UZ – Uzbekistan.

A number of notable discrepancies were detected between numbers of live birds reported as (re‐)exported from the target countries, according to importers’ and exporters’ reports (Annex IV). In
particular: Between 2002 and 2004, the numbers of live (captive‐bred) Falconidae specimens reportedby the UAE as imported from Kazakhstan were higher than the exporter reported quantities(in 2002 and 2004, no (re‐)exports were reported by Kazakhstan). This was also the case forimports of Falco cherrug from Kazakhstan by Saudi Arabia (Annex IV).
 Uzbekistan reported the (re‐)export of a significant number of captive‐bred Falconidae
specimens to the UAE during the period 2001 to 2010 but, for most of these years, noequivalent imports of such specimens were reported by the UAE (Annex IV 5).
Trade in live birds between the target countries was significant during the period 2000‐2010: 3800
specimens were (re‐)exported from the target countries to Russia, according to exporters’ reports. A
large proportion of these (re‐)exports concerned captive‐bred specimens of the family Psittacidae(re‐)exported from Uzbekistan under purpose codes P (personal use) (813 specimens) and T(commercial use) (2912 specimens). It is noted that a large proportion of these (re‐)exports werereported by Uzbekistan as exporter but not also reported by Russia as importer (Annex IV). There
were also discrepancies in the numbers of live birds reported as (re‐)exported from Russia to
Uzbekistan during the period 2000‐2010 (see Annex IV).

Imports of live birds
The target countries imported 31 713 live birds during the period 2000 to 2010, according toexporters’ reports. Over 90% of these imports concerned birds of the families Psittacidae (86% of thetotal, 56% of which were of wild origin) and Falconidae (7% of the total, 85% of which were of
captive‐bred origin). Russia was the leading importer of live birds among the target countries (26 764
specimens imported), followed by Uzbekistan (2890 specimens) and Kazakhstan (1902 specimens).
The main exporters to the target countries were (according to exporters’ reports): (i) with respect toPsittacidae species, Suriname (5619 specimens), the Czech Republic (5155 specimens), Guyana (3299
Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

29

specimens) and Guinea (2946 specimens); and (ii) with respect to Falconidae species, the UAE (2785
specimens). Exports of live Falconidae specimens from the UAE to the target countries generally
involved reportedly captive‐bred specimens for personal use, typically originating in EU Member
States. Imports of live birds into the target countries have remained relatively stable since 2003,
according to exporters’ reports.
Saker Falcon Falco cherrug in the Review of Significant Trade process
At its 21st meeting (AC21, May 2005), the Animals Committee categorized Saker Falco cherrug as “ofurgent concern” in nine range States and “of possible concern” in a further 26 range States. In
consultation with the Secretariat, it formulated recommendations directed to the range Statesconcerned with deadlines for their implementation.
As recommended by the Animals Committee, all range States of urgent concern (the Islamic Republicof Iran, Kazakhstan, Kyrgyzstan, Mongolia, Pakistan, Russia, Saudi Arabia, Turkmenistan andUzbekistan) suspended the issuance of export permits for F. cherrug in November 2006 (Notification
No. 2006/061). (The case of Mongolia was dealt with at SC58).
Concerning the remaining range States of urgent concern, the Animals Committee recommended at
AC21 that those range States wishing to resume the exportation of F. cherrug from the wild should,
by August 2007:i) conduct a survey of the status of F. cherrug in the country, including an assessment of distribution
and abundance, population trends, threats to populations and other relevant factors to provide thebasis for the making of non‐detriment findings as required under the provisions of Article IV,paragraphs 2 (a); andii) develop a science‐based population monitoring system, and establish adaptive management
programmes for harvesting of and trade in F. cherrug, taking into consideration the results of thesurvey referred to under i).
None of the eight range States concerned (Iran, Kazakhstan, Kyrgyzstan, Pakistan, Russia, Saudi
Arabia, Turkmenistan and Uzbekistan) provided this information to the Secretariat or expressed awish to resume authorizing exports of wild specimens of F. cherrug by SC59, March 2010.
At SC59 (March, 2010), it was agreed that for Iran (Islamic Republic of), Kazakhstan, Kyrgyzstan,
Pakistan, Russia, Saudi Arabia, Turkmenistan and Uzbekistan:a) the Secretariat shall include a zero export quota for wild specimens of Falco cherrug from theserange States;b) any State wishing to resume trade shall advise the Secretariat of measures taken to comply withthe recommendations in sub‐paragraph c); andc) the Secretariat, in consultation with the Chair of the Animals Committee, shall determine whether
they have been implemented and report to the Standing Committee accordingly.
Source: Anon, 2012d

Trade in medicinal products derived from animals
The term “medicinals” is used in this report to refer to medicinal products and also to parts andderivatives for medicinal use. During the period 2000‐2010, the majority of trade in medicinals
involving the target countries consisted of (re‐)exports from Russia.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

30Medicinal Leech
According to exporters’ reports, 169 236 dead specimens and 774 341 live (mainly captive bred)
specimens of Medicinal Leech Hirudo medicinalis, were (re‐)exported, primarily from Russia to the
EU for commercial purposes during the period 2000‐2010.
Musk Deer
According to exporters’ reports, a total of 429 kg of products consisting of/derived from Musk Deer
Moschus moschiferus (reported under the CITES term “musk”) were (re‐)exported from Russia
during the period 2000‐2010. Importers’ reports, however, show 1561 kg of “musk” were (re‐)exported from Russia during the same period. The discrepancy is mainly related to (re‐)exports of“musk” from Russia to the Republic of Korea, Hong Kong SAR and China. According toexporters’/importers’ reports, the leading importers of “musk” from Russia during the period 2000‐
2010 were the Republic of Korea (244 kg/1340 kg), Hong Kong SAR (87 kg/200 kg) and China(86 kg/0 kg).
During the same period, 127 408 kg of products consisting of/derived from Musk Deer (reported
under the CITES terms “derivatives”, “extract” and “musk”), whose origin was given as Russia, werere‐exported primarily from Hong Kong (SAR) (126 932 kg) and the Republic of Korea (462 kg)(according to exporters’ reports).
Further background information on trade in “musk” can be found in reports published by TRAFFIC,
available at http://www.traffic.org/mammals/, e.g. No Licence to Kill: The Population and Harvest ofMusk Deer and Trade in Musk in the Russian Federation and Mongolia (Homes, 2004).
Brown Bear
Just over 100 kg of Brown Bear Ursus arctos gall/gall bladders were (re‐)exported from Russia during
the period 2000‐2010 according to exporters’ reports, although importers’ reports show a muchlarger quantity of 3197 kg. Similar to “musk”, the discrepancy is mainly attributable to differences in
the quantities reported as imported by the Republic of Korea. According to exporters’ reports, theleading importers of Brown Bear gall from Russia during the period 2000‐2010 were Hong Kong SAR(62 kg), followed by China (24 kg) and the Republic of Korea (16 kg). However, the Republic of Korea
reported imports of 3139 kg over the period.
In addition to (re‐)exports of Brown Bear gall/gall bladders reported in kg, over 13 000 “specimens”
were (re‐)exported according to data from Russia (with almost none of this trade featuring in thereports of the countries of import – only 69 specimens according to importers’ reports). This total
was dominated by two particularly large (re‐)exports in 2007: one of 3600 specimens of gall (re‐)exported to Lithuania (reported under Purpose Code H, which is likely to be a reporting error);another 10 000 specimens of gall were (re‐)exported to Latvia for commercial purposes.
Saiga Antelope
Kazakhstan was the only target country (re‐)exporting Saiga Antelope Saiga tatarica horn15 during
the period 2000‐2010 according to exporters’ reports. 26 500 kg of this commodity were (re‐)exported to China in two commercial shipments (in 2001 and 2003). Hong Kong SAR also reported
the import of 3000 kg of Saiga horn from Kazakhstan in 2002; however this commercial import was
not reported as a (re‐)export by Kazakhstan. It is noted that, as part of the Significant Trade Review
process, in June 2001, the CITES Standing Committee recommended that CITES Parties suspend allimports of Saiga Antelope specimens from Kazakhstan and Russia until the two range States hadcomplied with certain recommendations, including with regard to the implementation of a regional
conservation strategy for the species. Since then, several steps have been taken to improve the15

Reported with the CITES terms “horns” and “horn products”.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

31

conservation status of Saiga Antelope. These include the development of Medium‐Term
International Work Programmes for the Saiga Antelope (2007‐2011 and 2011‐2015) in support of a
Memorandum of Understanding concerning the Conservation, Restoration and Sustainable Use of
the Saiga Antelope (Anon., 2010a) and implementation of a Saiga Action Plan under the Convention
on Migratory Species (CMS).
Russia and Kazakhstan were also the reported countries of origin for 6952 kg of Saiga Antelope horn
re‐exported by Singapore (4049 kg), China (2340 kg) and Hong Kong SAR (563 kg) between 2001 and2010, according to exporters’ reports. China has previously been identified as the largest importerand consumer of Saiga horn, with Singapore and Hong Kong SAR identified as important hubs for the
Saiga horn trade in South‐East Asia and East Asia respectively (von Meibom et al., 2010).

Reptiles: Trade in non‐medicinal bodies, parts and derivatives
Imports of reptile products
According to exporters’ reports, a total of 1 104 021 specimens were imported into the target
countries during the period 2000 to 2010. The vast majority (94%) were destined for Russia(1 041 395 specimens), with most of the remainder going to Kazakhstan (44 456 specimens, 4%).
Imports of reptile bodies, parts and derivatives into Russia peaked in 2007, before declining slightly
by the end of the decade (Table 5). There was a large discrepancy in the number of specimens
reported as imported into the target countries: importers’ reports showed just 310 specimens
during the period.
The EU was the most important (re‐)exporter of reptile bodies, parts and derivatives to the target
countries between 2000 and 2010 (794 400 specimens, 72% of reported imports), with Italy,
Germany and France the leading exporting EU Member States. Switzerland exported 278 126
specimens to the target countries during this period.
Over 90% of the specimens imported by the target countries were bodies, parts and derivatives ofsnakes (particularly Python spp.) and crocodiles (Alligatoridae and Crocodylidae), of which 65% and
53% respectively were of wild origin. Nearly all of the remaining imports involved lizard specimens,
particularly Varanus spp. and Tupinambis spp., with over 99% of these specimens sourced from thewild. The majority of specimens imported by the target countries were small leather products (79%),
with shoes and garments together comprising 14% of the total.
Table 5
Reported annual imports by the target countries of reptile bodies, parts and derivatives,
exporters’ reports (2000‐2010)
BY
KZ
KG
RU
TJ
UZ
Yearly
total

196

2004
546
2281
281
69 714
62
367

Year
2005
507
7075
1
127 243
1
757

2006
1454
6289
598
154 263
56
1453

2007
748
8475
215
164 148
56
1429

2008
1015
6810
183
157 130
133
1950

2009
460
5592
296
105 411
26
1512

2010
540
5153
119
112 432
11241

56 20373 251

135 584

164 113175 071

167 221113 297

121 496

2000
381
370

2001
215
545

2002
364
653

2003
367
1213

28 45728 06240 10854 427

374

88

178

29 58228 91041 303

Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russian Federation, TJ – Tajikistan, UZ – Uzbekistan.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

32

Live plants
According to exporters’ reports, most of the trade in CITES‐listed live plants (including seeds)
involving the target countries consisted of imports into Russia (342 133 specimens) and, to a lesser
extent, Belarus, Kyrgyzstan, Kazakhstan and Uzbekistan (together accounting for the import of
33 926 specimens). A total of 376 059 specimens were (re‐)exported to the target countries during
the period 2000‐2010, of which the majority (91%) were artificially‐propagated.
There was a very large discrepancy in the number of specimens reported as imported into the target
countries: importers’ reports showed just 10 specimens during the period.
The main taxa in trade were species in the following families: Amaryllidaceae (143 987 specimens,
particularly Galanthus spp.), Cactaceae (117 248 specimens), Orchidaceae (70 324 specimens) andPrimulaceae (33 952 specimens, all Cyclamen spp.).
The main (re‐)exporters to the target countries were the Netherlands, the USA, Thailand and theRepublic of Korea, which together accounted for 92% of (re‐)exports during the period 2000 to 2010.
Trends in (re‐)exports to the target countries remained relatively constant between 2000 and 2010,
with the exception of a peak in (re‐)exports to Russia in 2007 (Table 6). This peak was chiefly related
to several relatively large imports of wild and artificially‐propagated specimens of Galanthus spp.
and Cyclamen spp. from the Netherlands, a number of which originated from Turkey (exporters’
reports). None of these live plant imports were reported by Russia.
Table 6
Reported annual imports by the target countries of live plants, exporters’ reports (2000‐2010)
2000
0
0
0
12 273
0

2001
0
0
0
11 779
0

2002
0
12
0
6907
0

2003
0
0
0
22 425
0

2004
0
49
0
29 625
700

Year
2005
0
5
0
22 439
262

2006
2007
2008
2009
BY
371
2112
9338
52
KZ
0
560
4243
186
KG
0
12 20021
0RU
41 534167 1265367
10 973
UZ
923
24
2071
2
Yearly12 273 11 779
6919 22 425 30 374
22 70642 828182 02221 04011 213
total
Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russian Federation, UZ – Uzbekistan.
Note: Tajikistan is not included as no trade recorded.

2010
0
35
0
11 685760
12 480Live mammals(Re‐)exports of live mammals
A total of 3929 live mammal specimens were (re‐)exported by the target countries during the period
2000 to 2010, according to exporters’ reports. Taxa most commonly exported were: (i) Ursidae
species (1210 specimens), primarily Ursus arctos (1056 specimens); (ii) Felidae species (892
specimens), particularly Panthera tigris (429 specimens) and, to a lesser extent, P. leo (232specimens); and (iii) Cercopithecidae species (867 specimens), particularly Macaca spp. (688
specimens). The majority (77%) of live mammal specimens (re‐)exported from the target countries
were of captive‐bred origin (3036 specimens). Most (wild and captive‐bred) specimens (re‐)exported
from the target countries were (re‐)exported for the purpose of circuses and travelling exhibitions(76%) and zoos (11%).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

33

Imports of live mammals
A total of 8934 live mammal specimens were imported into the target countries during the period
2000 to 2010, according to exporters’ reports. Taxa most commonly imported were: (i)Cercopithecidae species (6336 specimens), particularly Chlorocebus spp. (5380 specimens) andMacaca spp. (789 specimens); (ii) Felidae species (837 specimens), particularly Panthera tigris (362
specimens) and P. leo (260 specimens); and (iii) Ursidae species (816 specimens), particularly Ursus
arctos (722 specimens). There was a discrepancy in the number of specimens reported as imported
into the target countries: importers’ reports showed just 620 specimens during the period.
The majority (69%) of live mammal specimens imported by the target countries were of wild origin(6142 specimens), however this total mainly reflects two particularly large imports of Chlorocebus
aethiops by Russia from Tanzania in 2000 and 2001 for commercial/bio‐medical research purposes(4460 specimens). These imports were not reported by Russia.

TimberAlthough the number of trade records involving timber species in the CITES Trade database for 2000‐
2010 was relatively low, (a total of 58 records reported for this period) the target countries
collectively imported a total of 2614 m3 of CITES‐listed timber between 2000 and 2010, based onexporters’ reports (taking into account transactions reported in m3 only). The main species in tradeduring this period was ramin Gonystylus spp. (2572 m3), most of which was imported by Russia (2348m3).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

34

SUMMARIES OF COUNTRY VISITSThis section aims to provide a snapshot of the status of CITES implementation and enforcement in
the target countries with a focus on the following issues:- national CITES legislation,- compliance with CITES,- national CITES authorities and their co‐operation,- CITES training and capacity building, and- reported illegal trade.
Further information on issues such as registration and marking, and raising public awareness are also
provided where available.
CITES National Legislation Project
CITES has an initiative to analyse national CITES legislation, which is conducted under the CITESNational Legislation Project. The assessment places the national CITES legislation into one of three
categories: Category 1: legislation that is believed generally to meet the requirements for
implementation of CITES; Category 2: legislation that is believed generally not to meet all of the requirements for the
implementation of CITES; Category 3: legislation that is believed generally not to meet the requirements for the
implementation of CITES.
The legislative analysis focuses on four aspects: i) designation of national CITES authorities, ii)
prohibition of trade in violation of the Convention, iii) penalization of illegal trade, iv) authorization
to confiscate specimens illegally traded or possessed (see document CoP12 Doc. 28 for moredetails).

BELARUS

Population: 9.5 million
Area: 207 600 km2
Official languages: Belarusian and Russian
Capital: Minsk
CITES accession date: 10/08/1995
CITES legislation: category 2 according to
CITES national legislation project (Anon,
2013k)CITES export quotas: none published
CITES MA: Ministry of Natural Resources
and Environmental Protection
CITES SA: National Academy of Science

Source: CIA World Factbook
https://www.cia.gov/library/publications/the‐world‐
factbook/geos/bo.html (downloaded 1 Sept 2013)

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National CITES legislation
An overview of the national CITES legislation of Belarus is provided in Annex V. As part of thenational legislation project, in January 2013, the CITES Secretariat sent reminders on behalf of theStanding Committee to Parties that had not submitted updated information to the Secretariat on the
progress made for the submission of legislation for parliamentary, cabinet or ministerial approval,
among them to Belarus (Anon., 2013g). During the visit to the country, the Belarusian MA noted to
TRAFFIC that legislation text had been submitted to the CITES Secretariat in Russian. TRAFFIC
encouraged the translation of these legal texts into English. The MA of Belarus reported that thetranslated texts were sent to the Secretariat in June 2013.
Compliance with CITES provisions
Belarus submitted annual reports for the years 2008, 2009 and 2010 with a delay in April/May 2012.
The annual report for 2012 was submitted in Jan 2013 (Anon., 2013a). Belarus submitted all fourbiennial reports to the CITES Secretariat required for the period 2003‐2010 (Anon., 2013c).
National CITES authorities and interagency co‐operation on CITES
Changes in the staff of the MA were reported to be frequent during the country visit.
Communication with the CITES Secretariat, different CITES committees and with the EU Scientific
Review Group (SRG) has been reported to be limited. The latter led to the formation of a negative
opinion by the SRG in 2003, which resulted in a suspension of imports into the EU of Grey Wolf Canis
lupus hunting trophies from Belarus in 2004 (see Annex II for further information on EU stricter
measures).
During the meeting with the CITES authorities in Belarus, co‐operation between the Customs
authority and the MA were described as weak: when CITES specimens are imported with permits,
the MA does not receive copies of the permits, leading to poor reporting of actual imports in annual
reports.
Registration and captive breeding
According to existing regulations, CITES‐listed species bred in captivity in Belarus must be registeredby the MA. The registration is the responsibility of the owner of the specimen within one month ofpurchase or entrapment. Registration of offspring must take place no later than five days after theyreach three months of age. It is not permitted to keep unregistered wild animals in captivity. The
register is held centrally by the CITES MA and is said to be in the process of being transferred frompaper based administration to an electronic database.
According to the Belarusian CITES authorities, the demand for exotic animals and plants appears tobe very low in Belarus. In 2008‐2012, 18 registration certificates (13 for App. II‐listed species, five forApp. I‐listed species) were issued by the CITES MA to captive breeding facilities.
At the time of writing, no requirements were in place for the marking of CITES‐listed species inBelarus.
Training and capacity building
According to the CITES authorities in Belarus, there is no specialized training course on CITES
available in educational institutions or training centres of enforcement agencies, such as Customs.
No CITES training workshops or other events took place in Belarus in the period 2005‐2012.
However, in December 2011, the Scientific Authority (SA), Customs and veterinary specialists took
part in a training seminar in Tbilisi, Georgia, sponsored by IFAW and WWF. According to TRAFFIC’s
research and the Belarusian CITES MA, training is particularly needed for Customs. Customs offices

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

36

have computer and internet access and therefore could make use of capacity building materials
available online.
At the time of writing, the following field guides to CITES specimens were being used:- Concise Field Guide to Animals and Plants included in the CITES Appendices by V. Ilyashenko(ed) (1999). WWF Russia.
- An illustrated field guide to the animals and plants listed in the CITES Appendices mostfrequently encountered in Belarus. (“BelNITs Ekologiya” 2005‐2006, research advisor –Novitsky, R.V.)

Reported illegal trade
Belarusian Customs detected eight cases of illegal movement of CITES‐listed specimens across theborder during the period 2009‐2011, resulting in the confiscation of 145 specimens. All the cases
took place on the Ukraine‐Belarus border and involved insect chrysalises. Exact species names were
not recorded by the authorities.
Public awareness
The Ministry of Natural resources and Environmental Protection website (www.minpriroda.gov.by)
has all the information necessary for the correct application of CITES requirements in Belarus. Publicawareness about CITES is perceived to be low according to CITES authorities in the country.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

37

KAZAKHSTAN

Population: 17.7 million
Area: 2 724 900 km2 (the largest
landlocked country in the world)
Languages: Russian (official),
Kazakh (State)
Capital: Astana (former capital:
Almaty)Government type: presidential
republic
CITES accession date:
20/01/2000

Source: World Factbook, CIA (https://www.cia.gov/library/publications/the‐world‐factbook/geos/kz.html)

CITES legislation: category 2 according to CITES national legislation project (Anon, 2013k)
CITES MA: Committee of Forestry and Hunting of the Ministry of Environment Protection (before
2013: Forestry and Hunting Committee of the Ministry of Agriculture); For fish and other aquatic
animals: Ministry of Agriculture, Fish Industry Committee
CITES SA: Zoological Institute of Ministry of Education and Science
National CITES legislation
An overview of the national CITES legislation of Kazakhstan is provided in Annex V. CoP16 Doc. 28
on National laws for implementation of the Convention (Annex 2) lists Kazakhstan among “Parties
requiring attention as a priority” (Anon., 2013k). Kazakhstan has informed the Secretariat that thenational law on the protection, reproduction and use of animals was amended in January 2012 andnow includes additional clauses concerning CITES, including on functions and competencies of therelevant government authorities. At the time of TRAFFIC’s visit to Kazakhstan, the head of the MA
explained that all necessary documents had been sent to the Secretariat. According to Kazakh
authorities, the current legislation fulfils the obligations under the Convention and should therefore
be placed in Category 1. The Secretariat is in the process of reviewing the new information andconsulting bilaterally with the CITES Management Authority of Kazakhstan as well as with othernational authorities on the matter.
National CITES authorities and interagency co‐operation on CITES
CITES is not regard as a priority issue by Customs and more widely by the government, which resultsin low staff capacities, especially at the MA. The frequent changes in government structure(ministries, agencies) make stable and continuous work difficult, including communication with the
CITES Secretariat. Co‐operation between some authorities is made difficult by territorial
disconnection: the MA is located in the new capital Astana, while the SA has remained in the former
capital Almaty along with all the scientific institutes/universities. While there is co‐operation
between the MA and Customs, it is not regular or institutionalized by a formal agreement or MoU.
Regarding enforcement, it is worth noting that Flora and Fauna International (FFI) provided financial
support in February 2013 for a week‐long exchange trip to the World Customs Organization’s Canine
Training Centre in the Czech Republic by a delegation of four officers from the regional dog training
centre and regional Customs departments from Kazakhstan (M. Karlstetter, FFI in litt. to K. Kecse‐
Nagy, March 2013). FFI also reported that Kazakhstan is very interested in developing its own dog

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

38

training for implementing CITES. According to FFI, the dog training centre in Kazakhstan appears tobe very experienced and it is hoped that once a training programme for implementing CITES has
been developed there, the centre could function as a training hub for the region. The centre has
already trained officials from Uzbekistan, Turkmenistan, Tajikistan, Mongolia, Afghanistan andKyrgyzstan (M. Karlstetter, FFI in litt. to K. Kecse‐Nagy, March 2013). Kazakhstan plans to purchaseand train wildlife detector dogs in early 2014 (M. Karlstetter, FFI in litt. to K. Kecse‐Nagy, August2013). FFI also reported discussions with Nazarbayev University on the use of gas‐chromatography
to determine the specific odour composition of a pair of confiscated Saiga Antelope horn. It is a legal
requirement to ensure Saiga Antelope horn can be discriminated from other ungulate horns (M.
Karlstetter, FFI in litt. to K. Kecse‐Nagy, August 2013).
Compliance with CITES provisions
Kazakhstan submitted annual reports for 2008, 2009 and 2010 with a delay in July 2012 (Anon.,2013a). Kazakhstan did not submit biennial reports in the period 2003‐2010 (Anon., 2013c).
A trade suspension for Beluga Sturgeon Huso huso from Kazakhstan has been in place since 2 May
2013 (see also the section on caviar in the trade chapter). Some other CITES‐listed species for which
Kazakhstan is a range State, have been in the Review of Significant Trade process, for instance, Saiga
Antelope (trade suspended in 2001) and Saker Falcon (zero quota set by the relevant CITES
committees from 2007, see also the relevant sections of the trade chapter).
Training and capacity building
Staff training for the Kazakh Customs Control Committee is carried out in the Russian Customs
Academy as well as via training courses held in Kazakhstan. Customs officers are required to taketraining courses regularly, which focus on specialized issues.
According to Kazakh Customs, staff are generally aware of CITES. There are identification andinformation materials in all Customs border offices, which are based on materials developed in
Russia. All officers know where to report seized CITES specimens and where to seek expert advice for
species identification. Samples of blank CITES permits, stamps and signatures are also said to beavailable at all Customs border offices.
A training‐seminar was organized by the Ministry of Finance (Customs Control Committee) withsupport from the United Nations’ Food and Agricultural Organization (FAO) in Almaty in 2012. A brief
overview lecture on CITES was given as part of the seminar.
All Customs checkpoints are equipped with computers and have access to the Internet and to therestricted information networks and databases. Customs have focused a great deal on changing toelectronic processes (vs. paper based administration).
FFI has developed Russian language CITES training materials for the region and is currently discussing
with the Kazakh authorities whether there would be interest and need to adapt these for Kazakhstan(M. Karlstetter, FFI in litt. to K. Kecse‐Nagy, August 2013).
Illegal trade
Neither the MA, nor the employees of the Customs Control Committee had any specific information
regarding seizures of CITES specimens at the borders of Kazakhstan. Searching Russian language
websites brought no results either. However, according to interviews conducted as part of thisproject, there are illegal exports of CITES‐listed species, involving: Saiga Antelope Saiga tatarica horns to China;
 Saker Falcon Falco cherrug to the Middle East and Pakistan;

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

39






Commercial volumes of Horsfield’s Tortoise Testudo horsefieldi to Russia and Uzbekistan;
Illegal trophy hunting for mountain sheep (e.g. Argali Ovis ammon), for example using
permits issued for hunting for scientific purposes. The main customers of these “black
outfitters” are said to be wealthy hunters from Russia. The trophies are then said to beexported within the Customs Union without any registration.
According to Kazakh hunting legislation, it is permitted to shoot Grey Wolf Canis lupus during
any legal hunt without a licence. Many outfitters include Grey Wolf hunts as an add‐on totrophy hunts targeting mountain sheep. Hunters from Russia and to a lesser extent from
Belarus are believed to be involved in the export of Wolf trophies without the necessary
CITES documentation.

Regional co‐operation on CITES
A consultative meeting on “Development of international co‐operation for the realization of CITES in
the Altai‐Sayan Ecoregion” took place in 2007 in Novosibirs. Participants included CITES authorities(MA, SA as well as Customs) from Russia, Kazakhstan and Mongolia, as well as international non‐governmental organizations. The main target of the meeting was to establish working relations
between Customs of the invited countries, as well as agencies and institutions involved in CITES
implementation. Special attention was drawn to the development of active co‐operation. Preventing
trafficking of certain key species was discussed, with detailed discussions on Saiga Antelope, Argali,
Saker and Gyr Falcons. The meeting was organized under the framework of a United Nations
Development Programme, Global Environment Facility project on “Biodiversity Conservation in the
Russian Section of the Altai‐Sayan Ecoregion” in support of a project on “Conservation andSustainable Use of Biodiversity in the Kazakhstani Sector of the Altai‐Sayan Ecoregion”.

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40

KYRGYZSTAN

Area: 199 951 km2
Population: 5.5 million
Government type: republic
Languages: Kyrgyz and Russian (bothofficial)
Capital: Bishkek
CITES accession: 04/06/2007
CITES legislation: category 2
according to CITES national legislation
project (Anon, 2013k)

Source: World Factbook, CIA
https://www.cia.gov/library/publications/the‐world‐factbook/geos/kg.html(downloaded 24 August 2013)

CITES MA: Government Agency ofEnvironmental protection andforestry
CITES SA: Biological and Soils Instituteof the National Academy of Science

National CITES legislation
An overview of the national CITES legislation of Kazakhstan is provided in Annex V. There were two
periods of political instability, sometimes referred to as ‘revolutions’ in Kyrgyzstan in 200516 and in
201017, which have caused delays in the development of the country’s legal framework in general.
Background, national CITES authorities and interagency co‐operation on CITES
The above‐mentioned revolutions also brought about changes of governments as well as significant
staff changes in the various management authorities. Some paper documents were lost during theturmoil, in particular a formal co‐operation agreement between the Academy of Science (SA) and
Environmental Agency (MA) as well as between the Environmental Agency (MA) and Customs.
According to the CITES authorities, although these agreements were not implemented in practice,they provided a framework for co‐operation, which has now been lost as the agreements have notyet been renewed.
There were said to be few staff working on wildlife protection and control of trade in wildlife at thetime of the country visit. Authorities spoke about a lack of equipment and insufficient training ofboth Customs officers and nature conservation agency employees. At the time of writing, alldatabases, both at the MA and Customs, were largely still on paper, making their practical use
difficult.
It was said that information about imported specimens was not being passed on by Customs to the
MA.

16
17

http://en.wikipedia.org/wiki/Tulip_Revolution
http://en.wikipedia.org/wiki/Kyrgyz_Revolution_of_2010

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

41

Kyrgyzstan has been setting hunting quotas for Argali, one of the most valuable CITES‐listed hunting
species in the country. The hunting quotas are based on data obtained from regular monitoring of
the populations (Mallon, 2013).
Compliance with CITES provisions
Kyrgyzstan became a CITES Party in June 2007 and submitted its first annual reports for 2009,
delayed until July 2012. The annual report for 2010 was also submitted at the same time (Anon.,2013a). At the time of writing, Kyrgyzstan has not submitted any biennial reports (Anon., 2013c).
Kyrgyzstan has been implicated in the Review of Significant Trade process for Saker Falcon, as aresult of which, a zero export quota was set by the relevant CITES committees from 2007 (see also
relevant sections of the trade chapter).
Training and capacity building
According to the MA and SA, Kyrgyz CITES authorities lack knowledge about CITES. There are no
educational materials or CITES identification guides aimed at Customs officers. There is no regulartraining for Customs or for the inspectorate of the Government Agency of Environmental Protection
and Forestry. The SA reported not being familiar with international CITES processes and thus raised
the need for more active involvement in international CITES meetings to build capacity in thisregard. The lack of knowledge of official CITES languages among CITES staff was also noted, whichhampers communication with the CITES Secretariat, some CITES Parties and at the same timehinders active involvement in international meetings.
Customs officers are trained at the National Law Academy, and in the Russian Customs Academy(there is a yearly quota of 10 officers) as well as in the Customs Academy in the Ukraine. Most of
those working in Customs have a variety of backgrounds and training. The key requirement is tohave some form of higher education and once selected during the recruitment process, candidates
are trained at the Centre of Professional and Canine Training for 1.5 months.
MA employees organized training seminars for Customs officers in 2009 and 2012. The MA took
part in several international seminars on CITES implementation.
According to MA, SA and Customs staff, there is an urgent need for organizing training seminars ona regular basis, as well as for providing CITES training, reference and identification materials.
According to the German CITES Biennial Report for 2010‐2011, following an invitation of the CITES
MA in Kyrgyzstan, co‐organized by the German Society for International Cooperation (Deutsche
Gesellschaft für Internationale Zusammenarbeit GmbH, GIZ), a representative from the German
CITES MA (Federal Agency for Nature Conservation) took part in a fact‐finding mission to Kyrgyzstan
on 14‐18 May 2012, looking into different aspects of CITES implementation. The mission helped to
improve the implementation and enforcement of CITES in Kyrgyzstan and to promote a better
representation of interests of Kyrgyzstan as a Party to the Convention. A report with several
recommendations to increase the effectiveness of CITES implementation was prepared by theGerman MA and officially transmitted to the Kyrgyz CITES MA as well as to the CITES Secretariat.
Reported illegal trade
No seizures of CITES specimens have been made at the Kyrgyz borders since the country’s accession
to the Convention in 2007. The most recent seizure found during internet research dates back to
2004 and involved Saker Falcons at a Russian air base in Kyrgyzstan. (No specific details could beobtained.)

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

42

Nevertheless, based on discussions with the MA and SA employees, some information on illegal
trade of wildlife was obtained: Kyrgyzstan is thought to be a transit country for illegal trade in live parrots and exotic
ornamental plants (mainly orchids) going from China to Russia and Kazakhstan; The collection of medicinal and aromatic wild plants, their seeds and bulbs is reported tobe significant in Kyrgyzstan. Large amounts (tonnes) of these raw materials are processedin the country. The processed materials are then exported to China (sometimes via
Kazakhstan).
 The chrysalises of butterflies and beetles are also said to be collected on a large scale; Kyrgyzstan is said to play a transit role in the illegal trade of falcons to the Middle East. The
falcons are thought to originate from Kazakhstan and Russia (e.g. Gyr Falcons from the Altai
and Kamchatka). To a lesser extent, falcons are also wild caught in Kyrgyzstan. Unregistered
breeding facilities, claimed to be financed from the Middle East, so that illegally caught andimported falcons can be exported with CITES documents claiming the specimens were
captive bred; Increased demand for Snow Leopard Uncia uncia skins in the early 2000s led to a poachingboom, which later declined significantly. However, currently in Kyrgyzstan andneighbouring Tajikistan (Gorno‐Badakhshansky region) there are rumours of demand for
Snow Leopard bones for traditional Asian medicine, with prices said to be in the region of
USD500‐600 per kilogramme;
 Significant numbers of Horsefield’s Tortoise are exported to Russia, China, Turkey and theUAE; Frogs, bear fat and bile (of the App. I‐listed subspecies Ursus arctos isabellinus obtained by
local hunters) are said to be exported to China without permits.
Public awareness
The Department of Hunting of the Government Agency of Environmental Protection and Forestry
maintains a specialized website, which contains information about CITES and describes theprocedure for obtaining CITES documents (www.nature.kg). The Customs website is available atwww.customs.gov.kg.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

43

RUSSIA

Source: CIA World Factbook https://www.cia.gov/library/publications/the‐world‐
factbook/geos/rs.html (downloaded 9 September 2013)

Population: 143 million
Area: 17 098 242km2 (the largest
country in the world)
Languages: Russian (official), many
minority languages

CITES accession date: 13/01/1992 (acontinuator of the USSR, joined in 1976)
CITES legislation: category 1 according to
CITES national legislation project (Anon,
2013k)

Government type: presidential
republic

CITES MA: the Federal Supervisory Natural
Resources Management Service (Ministryof Natural Resources and Environment);
For sturgeons: Federal Agency for Fisheries

Administrative divisions: 83
subordinate entities: 46 regions, 21
republics, 9 territories, 2 cities offederal subordination, 4autonomous districts, and 1
autonomous region

CITES SA: Russian Institute of Nature
Protection; Severtsov Institute of Ecology
and Evolution of the Russian Academy of
Science;
For Sturgeons: Russian Federal ResearchInstitute of Fisheries and Oceanography

Capital: Moscow

National CITES legislation
The legislation in Russia sets out clearly the roles and responsibilities of government agencies
regarding CITES implementation and enforcement. However, there are some gaps, inaccuracies andcontradictions, which hamper implementation of the regulations. This is partly due to the fact thatcurrent laws and regulations were adopted in different time periods when the country had adifferent form of government. New laws were sometimes approved without formal cancelation ofold ones or without examining previously approved legislation (Vaisman, 2012).
In June 2013, the Russian State Duma (parliament) approved amendments to the legislation thatmean tougher punishments for poaching and trafficking of rare species. Amendments were made to
the Criminal Code and the Code of Administrative Offences. Regarding the latter, penalties havebeen increased for the illegal hunting, storing, transportation, collection, management and purchaseof any specimens of rare species to around USD157 for natural/physical persons and aroundWildlife trade in the Eurasian Customs Union and in selected Central Asian countries

44

USD31 373 for legal persons/entities. Even more significant changes have been introduced to the
Criminal Code for the illegal trafficking of “especially valuable wild animal and aquatic biologicalresources, included in the Russian Red Data Book and (or) protected by international treaties (livespecimens, as well as their parts and derivatives). The penalty for someone committing the crimealone is a fine of around USD31 373, imprisonment for one year as well as confiscation of thespecimens; and for a member of a criminal group, the fine is the same with up to two years
imprisonment.
There is now also a separate article on “illegal hunting, storage, purchasing, keeping, transportation,
shipping and selling of especially valuable wild animal and aquatic biological resources, protectedaccording to the Russian Red Data Book and/or protected by international treaties to which Russia is
a Party”, (also covering parts and derivatives as well as live specimens). The penalty is now a fine ofaround USD 31 000 and imprisonment for one year for someone acting alone, or around USD 62 000
and imprisonment for up to seven years, for members of criminal gangs.
Due to gaps in national legislation, currently there is no agency responsible for controlling wildlife
trade within Russia. Only specimens of species that can be legally hunted are required to becontrolled internally although there are no specific legal requirements for police and otherauthorities to carry out these duties.
National CITES authorities and interagency co‐operation on CITES
There is a transparent system governing the issuance of CITES permits in Russia. Decisions are madeby a special Committee, which also includes NGO representatives.
There is poor co‐operation between Customs and the MA, with copies of CITES permits seldom
passed on.
Compliance with CITES provisions
Russia did not submit an annual report for 2006 during the period 2006‐ 2012 (Anon., 2013a).
Between 2003‐2010, Russia submitted one biennial report covering the period 2005‐2006 (Anon.,2013c).
Since 2 May 2013 a trade suspension for Beluga Sturgeon Huso huso from Russia has been in place(see also section on caviar in the trade chapter). Some other CITES‐listed species for which Russia is arange State have been in the Review of Significant Trade process. For instance, Saiga Antelope (tradesuspended in 2001) and Saker Falcon (zero quota set by the relevant CITES committees from 2007,see also relevant sections of the trade chapter).
Training and capacity building
The formal training of Customs officers in Russia takes place at the Russian Customs Academy and its
branches located in Vladivostok, Rostov‐on‐Don and Saint‐Petersburg. The re‐training of specialists,such as lawyers, economists, and retired officers from the police or army, is also widespread.
Specialists in other fields, such as biologists, geologists, humanitarians, who can provide expertise on
specific issues, are also actively hired. The re‐training is carried out by special departments of the
Customs Academy and its branches as well as in scientific and training centres of the territorial
offices of the Federal Customs Service.
For the officers of the Federal Customs Service, it is obligatory to undertake further training at least
once every five years. In addition to these, brief training courses are also organized if there arechanges to regulations or if new equipment is introduced.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

45

The Federal Customs Service also hosts a well‐developed detector dog service, which has been
especially active from 2005 onwards in the detection of wildlife goods, especially, CITES‐listed
species. A number of illegal shipments have been detected with the help of detector dogs. For
example, in June 2011, a specially trained sniffer dog in the Russian city of Blagoveschensk on theborder with China, led Customs Officers to a haul of more than 1000 Brown Bear paws in the back ofa lorry (Anon., 2011).
The first CITES field guides were compiled in 1998 by TRAFFIC and WWF in Russia. In 2005, a
specialized course for the Customs Academy was developed by TRAFFIC entitled “Customs
regulation and the prevention of the international illegal trade in CITES‐listed species”. The course
textbook and a CITES field guide were published on a CD‐ROM. The course has been in the
curriculum of the Customs Academy since 2006. A special course on prevention of smuggling of
biological resources has been developed by the Vladivostok branch of the Customs Academy. Thereis also a specialized course adapted to the local conditions in the Russian Far East. Updated
information materials, textbooks and new field guides on CDs have been published many times.
Reported illegal trade
Information on detected cases of illegal trade involving CITES species are not recorded centrally in
Russia, only regionally. Therefore, this section is based on information obtained during theinterviews conducted as part of this project as well as on previous research carried out by TRAFFIC.
Illegal imports into Russia mainly involve live reptiles, amphibians, primates and parrots used as pets
or for captive breeding. Some of these illicit imports are destined for “home zoos” of wealthypeople. Although this trade involves small numbers of specimens, it is reported to be a persistentphenomenon. Reptile skins are illegally imported to be manufactured into various leather products.
Hunting trophies are also imported illegally, including, Argali Ovis ammon trophies from Kyrgyzstan
and Tajikistan (see relevant country profiles). Seasonally (usually in the spring), large quantities(several million) of snowdrops, Galanthus spp. and Cyclamen spp., are illegally imported into Russia
from the Ukraine and Georgia.
Illegal export is mainly to the Middle East and China. Falcons (primarily, Saker Falcon and Gyr Falcon)
are destined for the Middle East. In 2008 the total number of illegal falcon exports from Russia wasestimated as between 1000 to 1500 specimens a year. Live falcons are seized by Customs at borders
on a regular basis. Many parts and derivatives, used in traditional Asian medicine, are illegally
exported to China, estimated as follows: Musk from Musk Deer: 400‐420 kg per year (equivalent to approximately 20 000 adultmales);
 Brown Bear: bile and paws – no estimate of volume available (though note the seizure
reported in the section above); Ginseng Panax ginseng: 2 tonnes per year;
 Tiger: approximately 30 specimens are poached a year. It is estimated about half of theseare smuggled to China as bones;
 Saiga Antelope: there are reports of illegal hunting of male Saiga Antelopes for their horns,
which are used in traditional Asian medicine. No estimates are available on the levels of thisillegal trade.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

46

TAJIKISTAN

Area: 143 100 km2
Population: 7.9 million
Government type: republic
Languages: Tajik (official),
Russian widely used ingovernment and business
Capital: Dushanbe
CITES accession: Non‐Party
Authority competent to issuecomparable CITES
documentation: Committee
on Environmental Protection

Source: World Factbook, CIA, https://www.cia.gov/library/publications/the‐world‐
factbook/geos/ti.html (downloaded 4 September 2013)

Scientific institution capable of advising that an export is not detrimental to the survival of thespecies concerned: Committee on Environmental Protection

National CITES legislation
See Annex V. for an overview of the Tajik national legislation relevant to CITES. Current legislation
focuses on the protection of native wildlife and not on exotic species. Tajikistan is not a Party to
CITES and thus its national legislation has not been assessed as part of the CITES National Legislation
Project.
National authorities and interagency co‐operation
Following the collapse of the Soviet Union in 1992, it was officially communicated to the CITES
Secretariat that the Russian MA would assist former USSR States in issuing CITES permits until theyjoined CITES. Accordingly, during the last two decades Tajikistan has received CITES re‐export
permits from the Russian MA.
The Tajik authorities said, during the country visit in April 2013, that they were very close to joining
CITES. In preparation for CITES accession, the Committee on Environment Conservation of theGovernment of Tajikistan informed the CITES Secretariat that Tajikistan started to issue national
export permits for CITES‐listed species in 2010 and stopped obtaining CITES permits from theRussian MA from September 2011 onwards. Samples of permits, seals and signatures have been sent
to the CITES Secretariat.
The Tajik Authorities met during the country visit reported in April 2013, that the President of
Tajikistan has made strong recommendations to the Tajik Parliament regarding the ratification of
CITES before the start of the next parliamentary vacations in July 2013. However, no information
about further progress has been received.
Currently the authority competent to issue Tajik export permits and other comparable documents(the Committee on Environmental Protection) is the agency planned to be appointed as the CITES
MA on accession to the Convention. The Zoological and Parasitological Institute and the Forest
Institute of the National Academy of Science will possibly be appointed as SA.

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47

Information exchange and co‐operation between Customs and the environmental‐protection
authorities is required by law. However, in practice it is rare and sporadic.
Tajikistan has been setting hunting quotas for Argali, one of the most valuable CITES‐listed hunting
species in the country. The hunting quotas are based on data obtained from regular monitoring of
the populations (Mallon, 2013).

Compliance with CITESTajikistan is not required to submit annual or biennial reports to CITES. However, the country has
been implicated in the Review of Significant Trade process as a range State for Horsfield’s Tortoise18.
Legal trade
According to the Head of the Division for the Protection of Flora and Fauna, Abdukadir Maskaev, in
accordance with a decree of the President of Tajikistan, a moratorium has been declared on theexport of wild animals native to Tajikistan, unless a harvest quota is set. Quotas have been set for
huntable species, such as Argali (see also section on hunting trophies in the trade chapter), but notfor live tortoises (e.g. Testudo horsfieldii) due to a lack of information on the number and status ofwild populations.
Training and capacity building
Customs officers are trained at the faculty of Tourism and Customs services, of the Institute ofBusiness and Service and in the Customs Department of the Institute of Economics. Several
economic departments of a number of higher education institutions also offer a degree in Customs
matters. The Russian Customs Academy provides an annual quota for the free education of
specialists from Tajikistan. Economists and lawyers can also take on positions within Customs
without specialized education due to a shortage of staff.
CITES training materials are not yet available in the country. There are materials to prevent poachingof native wildlife designed for hunting inspectors.
Trainings on CITES were held in Dushanbe in November 2012 and February 2013 as part of an
Organization for Security and Co‐operation in Europe (OSCE) education programme focusing moreon theoretical than practical implementation.
In order to prepare for CITES accession, the MA and Customs will need training, both to be future
trainers as well as for front‐line officers.
Illegal trade
According to information obtained during the country visit in April 2013, trophy hunting of mountain
ungulates involves high revenues, corruption and illegal trade. There are several official hunters andhunting associations in Tajikistan, who organize trophy hunting and tend to accuse their competitorsof organizing “black” hunts, exceeding quotas and being involved in illegal export. It is likely that
there is illegal trophy hunting and that the illegal export of trophies occurs too. A former TRAFFIC
staff member was an expert witness to the seizure of hunting trophies (skulls, skins and horns)
arriving on a Dushanbe‐Moscow flight at Moscow’s Domodedovo International Airport in 2009. The
case involved five Marco Polo Sheep Ovis ammon polii (App. II) and two Markhor Capra falconeri18

The outcome of the process is likely to be positive for Tajikistan, as the country has not allowed the export ofHorsfield’s Tortoise in recent times. It is noted that the summary records of the 63rd meeting of the Standing
Committee had not yet been published at the time of writing.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

48

(App. I) trophies. The shipment was accompanied by false Russian MA CITES permits. The quality of
the falsified permits was so good that at first it did not arouse suspicion and only comparison of thepermits’ details with information logged by the Russian MA revealed the fraud (Anon., 2009a).
According to information obtained during interviews with people involved in trophy‐hunting
tourism, the hunting of two animals per permit is also quite common even though the permit is forone specimen only. This usually happens after, having shot one animal, the hunter encountersanother one with better trophy properties. The organizers of the hunt may decide to overlook theshooting of the second specimen for an additional (unofficial) fee. According to interviews
conducted as part of this project, trophies are mostly taken to Kyrgyzstan, from where they areexported illegally.
There are also reports of several butterfly (Lepidoptera), mainly endemic species, being caught inTajikistan and then exported (Alikhon Latifi, advisor of Tajik Hunting Association pers. comm. to A.
Vaisman, 2013). There was also mention of illegal falcon trade, but the scale of this appears to be
insignificant. Among the people living in remote villages in the Gorno‐Badakhshan region of
Tajikistan, there are rumours of Chinese traders buying Snow Leopard Uncia uncia (App. I) bones at a
price of USD500‐600 per kilogramme.
Public awareness
Public awareness raising will also be required upon accession to CITES.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

49

UZBEKISTAN

Source: World Factbook, CIA, https://www.cia.gov/library/publications/the‐world‐factbook/geos/uz.html(downloaded 7 September 2013)

Population: 28.6 million
Area: 447 400 km2
Languages: Uzbek (official), Russian,
Tajik
Capital: Tashkent
Government type: republic
CITES accession date: 10/07/1997

CITES legislation: category 2 according to
CITES national legislation project (Anon,
2013k)CITES MA: State Inspectorate on Wildlife
Conservation (Gosbiocontrol), State
Committee on Nature Protection
CITES SA: Zoological Institute of Academyof Science and Institute of Botany of the
Academy of Sciences

National CITES legislation
An overview of the national CITES legislation of Uzbekistan is provided in Annex V.
The following are banned from import/export to/from Uzbekistan: rare and endangered species of animals, wild drugs, food and ornamental plants that arelisted in the Red Data Book, without the permission of the State Committee for Nature
Protection;
 products of wild origin without the permission of the Sanitary and Epidemiological Service.
The legislation also refers to a document called “the list of biological objects banned for export fromthe Republic of Uzbekistan”, but there is no such document in any database and the MA has no
information about it so it is assumed that this document was planned but never written.
The Criminal Code has a section (Chapter XIV) on the protection of environmental and natural
resources, in particular Article 200 “Violation of veterinary rules” and Article 202 “Violation of use ofanimal and plant resources”, however these do not directly concern CITES.
In accordance with the Rules, all use of wildlife included in the Red Data Book of Uzbekistan,
including the import or export of flora and fauna (animals and plants, their parts, derivatives) acrossthe countries’ borders can only take place under special permits issued by the Cabinet of Ministers

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

50

of Uzbekistan on the proposal of the State Committee for Nature Protection and the consent of the
Academy of Sciences.
Import and export of wildlife species not listed in the Red Data Book of Uzbekistan across Stateborders can be authorized by special permission from the State Committee for Nature Protection of
Uzbekistan.
Permissions for the export and import of plant species listed in Appendices I, II and III of CITES, aregiven by the MA with a prior agreement from the SA, with the exception of those listed in the Red
Data Book of Uzbekistan. Export should take place only through certain border crossing points statedon the permit.
When importing CITES‐species to Uzbekistan, the original CITES permit should be provided to the
MA for registration straight after Customs formalities.
The MA prepared a new draft law in 2013 “On the International Trade of Endangered Species of Wild
Fauna and Flora, Endangered Species (CITES) in the territory of the Republic of Uzbekistan.”
However, this legislation has not been discussed or adopted yet.
Almost all the existing Uzbek regulations concerning the protection and regulation of wild fauna andflora, including the trade in CITES‐listed species require the adoption of sub‐ordinate
implementation regulations, some of which are missing. This results in easily avoidable or minimal
sanctions for violations of CITES rules. In most cases, the offender faces the forfeiture of the illegallytransported CITES specimen as a maximum penalty, with the only significant exception being thecommercial movement of large numbers of live specimens. The scale of punishment for breaking therules of import/export of CITES specimens are not clearly set out in the legislation. While theconfiscation of illegal goods is clearly laid down, further preventive measures are required to be
carried out “in accordance with applicable laws,” the norms of which have not yet been developed.
The scale of sanctions has been set and published for illegal hunting, which has had a deterrent
effect.
National CITES authorities and inter‐agency co‐operation on CITES
Co‐operation between the MA and Customs developed actively after the country became
independent, with the MA conducting seminars for Customs officers. Joint actions at Tashkent
airport also took place. However, with the number of staff decreasing at the MA, less time became
available for keeping the co‐operation active and thus the relationship with Customs weakened. The
priority for dealing with wildlife trade within Customs also appears to have reduced during that time.
In spite of attempts by the MA to renew the relationship with Customs, collaboration was said to benon‐existent for about a decade. More recently co‐operation resumed, resulting in an increasing
number of seizures at borders. Training conducted by the MA has gradually resumed from 2011 bothfor front‐line Customs officers and for officers working in the central office.
The country consultant reported that Customs and law enforcement in general have little awarenessof the legal framework regulating wildlife trade. According to the consultant, Customs checks atborders take place randomly unless some illegal trade patterns are known, for example, traffickingof Saiga Antelope horns: the MA reported the seizure of a total of 557 horns during the period 2010‐2012. Between 2009‐2012, there was no cases of criminal procedure/prosecutions for the smugglingof animals or plants (in general or of CITES specimens).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

51Registration and captive breeding
There are several officially registered captive breeding facilities in Uzbekistan, which breed CITES‐
listed wildlife. According to the legislation, breeding facilities have to be registered even if they
breed non‐CITES‐listed species. The large commercial breeding facilities are officially registered by
the MA. There is no requirement for nurseries of plants to be registered. The list of captive breeding
facilities registered in Uzbekistan is provided in Annex VI, which also lists some very rare Appendix I‐
listed species, such as Spix’s Macaw Cyanopsitta spixii. The marking of captive bred animals is not
required by law and thus is not practiced.
There is also a large number of unregistered breeding facilities and collections that keep and breed
CITES species. Live pet markets and pet shops often offer different species of tortoises and turtles,
parrots, the origin of which is unknown. The rules for carrying out environmental control inspections
at markets or shops require the involvement of the local police and the mandatory prior notificationof the markets, which makes any checks meaningless.
Compliance with CITES provisions
Uzbekistan submitted annual reports for 2006‐2011. The 2010 report was received after a delay, inJanuary 2012 (Anon., 2013a). For the years 2003‐2010, Uzbekistan submitted one biennial reportcovering the period 2009‐2010 (Anon., 2013c).
Uzbekistan has been in the Review of Significant Trade process as a range State for Horsfield’s
Tortoise (review concluded in July 2012 as Uzbekistan complied with the recommendations of therelevant CITES committees) and for Saker Falcon, with a zero export quota established by therelevant CITES committees. Uzbekistan has provided export quotas to the CITES Secretariat to be
published on the CITES website (see Annex III).
Training and capacity building
Customs officers are trained at the Customs Supreme Military Institute, where there are also further
training courses for employees of the State Customs Committee. After a period of weaker co‐operation, training conducted by the MA has gradually resumed from 2011 onwards, both for front‐
line Customs officers, and for officers working in the central office. Training seminars on CITES havebeen consistently organised for Customs officers by the MA. In 2013, such seminars were planned tobe conducted in all regions and Customs offices.
Customs in Uzbekistan have access to an illustrated list of CITES‐listed animals and their parts: “A
short guide to CITES‐listed species – A guide for officers of the Customs Committee and the State
Committee for Nature Protection”. A new version of the manual has been prepared by the MA,
which has not yet been published owing to a lack of funds.
In 2013, Flora & Fauna International (FFI) published a training manual for Customs, rangers, andother law enforcement personnel in Uzbekistan with a special emphasis on tackling the regional
trade in Saiga Antelope on the Ustyurt Plateau (Byukova and Grigoryants, 2013). This has extensive
information about CITES and is available in Russian. In addition, FFI have also developed a horn
identification poster for ungulate species found in Uzbekistan, published in both Uzbek and Russian
languages (M. Karlstetter, FFI in litt. to K. Kecse‐Nagy).
Reported illegal trade
From 2005‐2012, 18 cases of seizures of smuggled animals and animal derivatives were reported by
the MA (Table 7). Fourteen of these concerned CITES‐listed species, all of which were made by
Customs. No additional details about the seizures could be obtained from the CITES authorities in

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

52

Uzbekistan. According to the CITES MA, tortoises and Saiga Antelope horns appear mainly in illegal
trade in Uzbekistan.
Table 7
Seizures reported be Uzbekistan for 2007‐2012
Date of seizure

No. of specimens

Species

Type of specimen

23/05/2007

1100

Steppe Tortoise

live

3

Tiger

skins

2

Gibbonlive

40

Falcon spp.

live

11

Cockatoolive

4

Marmosetlive

1

Thick Loris

live

2

White Handed Gibbon

live

8/04/20092

Saker Falcon

live

21/08/2009

1500

Steppe Tortoise

live

5/11/2009

280

Steppe Tortoise

live

2008
2008

February 2009

2 Clouded Leopard Neofelis nebulosa

live

3

Nycticebus pygmaeus

live

4

Cockatoolive

2Marmoset

live

April 2010

119

Saiga

horn

July 2010

254

Turtlelive

3/10/2010

350

Turtlelive

September 2011

2

Saiga

horn

29/12/2011

134

Saiga

horn

23/02/2012

302

Saiga

horn

2011

2000

Testudo horsfieldii

live

2011

850

Testudo horsfieldii

live

2010

1

Cervus nippon

horn

2010

10

Gracula religiosa

live

2010

7

Cacatua galerita

live

February 2010

Source: Uzbek MA, 2013 and Uzbek Biennial Report for 2010‐2011.
Note: seizures with a grey background were reported in the Uzbek Biennial Report for 2010‐2011. The otherseizures were provided by the MA during the country visit. All dates and species names have been included in
the table as provided by the MA/in the Biennial Report.

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53

CITES IMPLEMENTATION IN OTHER CUSTOMS UNIONS AND REGIONAL ORGANISATIONS

The following section presents selected examples of how CITES is implemented and enforced indifferent forms of trade agreements, Customs unions or other economic integrations. The aim of thissection is to provide best practice examples of existing co‐operation and co‐ordination mechanisms
in such formations, which may assist the ECU in deciding how to deal with CITES implementation andenforcement across its borders.
ASEAN
The Association of Southeast Asian Nations (ASEAN) was established in 1967 in Bangkok, Thailand,with the signing of the ASEAN Declaration by Indonesia, Malaysia, Philippines, Singapore andThailand. At the time of writing, ASEAN has ten Member States, with Brunei Darussalam joining in
1984; Viet Nam in 1995; Lao PDR and Myanmar in 1997, and Cambodia in 1999.
At the 12th ASEAN Summit in January 2007, the Member States signed the Cebu Declaration,affirming their commitment to establish an ASEAN Community by 2015. To this end, the Member
States agreed to hasten the establishment of the ASEAN Economic Community by 2015,transforming ASEAN into a region characterised by the free movement of goods, services,
investment, skilled labour and freer flow of capital and requiring inter alia the removal of non‐tariffbarriers as well as trade facilitation measures such as the integration of Customs structures andprocedures (Anon., 2009b).
The implications of future regional economic integration for CITES implementation in the ASEAN
region are yet to be fully elucidated. At present, CITES continues to be implemented at the level ofeach individual Member State, with CITES permits issued by national authorities for trade in CITES‐
listed species and their products within the region. In addition, controls remain in place at borders
between Member States, at which endorsement of CITES permits can be carried out and goods may
be inspected by Customs.
Although still in the preparatory stages of economic integration, ASEAN has established a large inter‐governmental wildlife law enforcement network, bringing together law enforcement, Customs andenvironment agencies of all ten ASEAN Member States to address illegal exploitation and trade in
CITES‐listed species within the ASEAN region. Launched on 1 December 2005, the Association ofSoutheast Asian Nations’ Wildlife Enforcement Network (ASEAN‐WEN) facilitates cross‐bordercollaboration in the fight against illegal wildlife trade, enabling countries to share information andbest practices, while increasing capacity and improving co‐ordination through annual meetings,
workshops and trainings.
ASEAN‐WEN operates at the national and regional levels. Each country is expected to establish andsustain a national inter‐agency task force comprised of police, Customs and environmental officers,
with focal points from each agency sharing information across the region. To improve the capacity of
the network, law enforcement officers in national task forces receive training in patrolling,
investigations, species identification and wildlife regulation/legislation. Seminars and workshops arealso aimed at building the capacity of border officers, prosecutors and the judiciary in the area ofwildlife crime, for example, the Judiciary Workshop on Wildlife Crime held in November 2009 forrepresentatives from the Malaysian, Indonesian and Bruneian Courts and Attorney General's Offices.
ASEAN‐WEN Judiciary Workshops were also held in 2010 to raise awareness of Wildlife Crime in
Thailand and Cambodia and a Wildlife Trade Regulation Course conducted in Medan, Indonesia.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries54

At the global level, ASEAN‐WEN co‐operates with the USA, China, the South Asia Wildlife
Enforcement Network (SAWEN) and the Lusaka Agreement Task Force (LATF), having also developed
links inter alia to INTERPOL, the World Customs Organization, and the United Nations Office on
Drugs and Crime (UNODC).
The new ASEAN Regional Action Plan on Trade in CITES Wild Fauna and Flora (2011‐2015) was
agreed in May 2011 at a Special Meeting of the ASEAN Experts Group on CITES in Manila and aims tosustain earlier efforts and successes of ASEAN‐WEN. The ASEAN‐WEN Program Coordination Unit
(PCU) has been established to co‐ordinate technical support for ASEAN‐WEN and assist in theorganisation of meetings, seminars, workshops exchanges and training programs, with support fromthe ASEAN Secretariat.

European Union
Regulation of trade in wild flora and fauna into, from and within the EU
Due to the establishment of the European Union (EU) Single Market and the absence of bordercontrols within the EU, the provisions of CITES must be implemented uniformly in all EU Member
States19. CITES is implemented in the EU through a set of Regulations known as the EU Wildlife Trade
Regulations. Currently these are Council Regulation (EC) No 338/97 on the protection of species ofwild fauna and flora by regulating trade therein (the Basic Regulation), Commission Regulation (EC)No 865/2006 (as amended) laying down detailed rules concerning the implementation of Council
Regulation (EC) No 338/97 (the Implementing Regulation), and Commission Implementing
Regulation (EU) No 792/2012 laying down rules for the design of permits, certificates and otherdocuments provided for in Council Regulation (EC) No 338/97 on the protection of species of wild
fauna and flora by regulating the trade therein and amending Regulation (EC) No 865/2006 (thePermit Regulation). A Suspensions Regulation is also in place to suspend the introduction into the
EU of particular species from certain countries.
The Basic Regulation applies to species listed in its four Annexes. Annexes A to C are broadly
equivalent to CITES Appendices I to III, while Annex D includes inter alia certain non‐CITES species forthe purposes of consistency with other EU regulations on the protection of native species. The
introduction into the EU of specimens of species listed in Annex A or B requires the prior issue of a
CITES import permit, while an import notification form must be completed by the importer for the
introduction of specimens into the EU of species listed in Annex C or D. The importpermit/notification must then be presented to the Customs office at the first point of introduction
into the EU.
CITES goods can generally be moved and traded freely within the EU, again owing to theestablishment of a Single Market and removal of border controls. However, wild specimens ofspecies listed in Annex A (and any others that do not meet the formal definitions of captive‐bred or
artificially propagated) are generally not allowed to be used for commercial purposes and their
movement inside the EU is also regulated. As a general rule, no permits or certificates are needed
for keeping or moving a specimen of a species listed in Annex B, C or D inside the EU; nor are permits
generally required for commercial activities inside the EU involving specimens of species listed in
Annex B (if they have been legally acquired and imported into the EU), C or D.

19

At the time of writing, the 28 Member States of the EU are: Austria, Belgium, Bulgaria, Croatia, Cyprus,
Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Hungary, Latvia, Lithuania,
Luxemburg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the UK

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55

Member States are obliged to designate Customs offices for carrying out the checks and formalities
required under the EU Wildlife Trade Regulations, a list of which must be communicated to andpublished by the European Commission in the Official Journal. In general, checks on shipments of
CITES goods introduced into the EU must take place at the first point of introduction, irrespective of
the shipment’s final destination within the EU. An exception to this rule is where a shipment arrives
at a border Customs office by sea, air or rail, and is to be dispatched by the same mode of transport
and without intermediate storage to another designated Customs office. In such circumstances, thecompletion of the necessary checks and the presentation of import documentation shall take placeat the second Customs office. In addition, shipments are frequently dispatched from a first Customs
office at the outside EU border to another Customs office where the scope for physical inspection of
the goods is greater. In these cases the second Customs office shall require presentation of theimport permit/notification and may carry out any checks it deems necessary in order to establish
compliance with the Regulations.
Regional co‐operation on CITES implementation in the EU
The European Commission monitors the implementation of the EU Wildlife Trade Regulations in co‐operation with the EU Member States. It also prepares proposals for CITES legislation and adopts
CITES implementing measures, in addition to ensuring that the EU Member States act on the basis of
a common position at meetings of the CITES Conference of the Parties.
EU Member States and the European Commission are required by law to communicate to one
another the information necessary to implement the EU Wildlife Trade Regulations. In addition, theCommission must communicate with the CITES Secretariat to ensure that CITES is effectively
implemented throughout the territory to which the Regulations apply.
To facilitate co‐ordination and co‐operation between EU Member States on wildlife trade issues, theBasic Regulation establishes a Committee on Trade in Wild Fauna and Flora consisting ofrepresentatives of Member States’ competent authorities (generally the CITES Management
Authorities) and chaired by a representative of the Commission. The Committee meets three to fourtimes a year in Brussels to discuss and provide guidance on the implementation of the EU Wildlife
Trade Regulations, as well as to approve the necessary implementing measures to be adopted by theCommission.
The Basic Regulation also establishes a Scientific Review Group (SRG) consisting of representatives ofeach Member State’s CITES Scientific Authority and chaired by a representative of the Commission.
The SRG meets three to four times a year in Brussels to examine all scientific questions related to theapplication of the EU Wildlife Trade Regulations, including assessing whether trade is detrimental tothe conservation status of species. The SRG can form opinions on whether or not imports of certain
species from particular countries of origin comply with the conditions set out in the Regulations:where a Negative Opinion is established by the Commission based on the advice of the SRG, importof the particular specimens from a certain country of origin will not be allowed. Opinions of the SRG
are conveyed to the Committee by the Commission. (See also Annex II for further information on EU
stricter measures.)Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

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Enforcement of the EU Wildlife Trade Regulations
Although the EU Wildlife Trade Regulations are directly applicable in all EU Member States, mattersrelating to enforcement remain under the sovereignty of each Member State and necessary
provisions must therefore be transposed into, and supplemented by, national legislation. Member
State competent authorities are responsible for monitoring compliance with the provisions of theRegulations and must take appropriate steps to ensure compliance with these provisions, or toinitiate legal action where there is reason to believe the provisions have been infringed. In the eventof significant infringements of the Regulations, the Commission and (where CITES‐listed species areconcerned) the CITES Secretariat must be informed of any steps taken, include seizures andconfiscations. The Commission may also draw the attention of Member State competent authorities
to matters where it considers investigation necessary. The result of any subsequent investigationmust be provided to the Commission and, where appropriate, to the CITES Secretariat.
In addition to the core legislation described above, the Commission has issued a non‐binding
recommendation (Commission Recommendation No 2007/425/EC identifying a set of actions for theenforcement of Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by
regulating trade therein, commonly referred to as the EU Enforcement Action Plan), which sets out
a number of actions to be taken by EU Member States for more effective enforcement of the EU
Wildlife Trade Regulations. These include adopting national action plans for enforcement, imposing
penalties for wildlife trade offences that are effective, dissuasive and proportionate, and using risk
and intelligence assessments to detect illegal and smuggled wildlife products. The Action Plan also
recommends that Member States take action to increase public awareness about the negative
impacts of illegal wildlife trade and to increase co‐operation and exchange of information within andbetween Member States as well as with third countries and relevant international organizations (e.g.
Interpol, World Customs Organization).
As regards co‐operation in the area of enforcement, the Basic Regulation establishes theEnforcement Group, consisting of representatives of Member State authorities charged with
monitoring compliance with the EU Wildlife Trade Regulations, such as Customs, police and wildlife
inspectorates. The Enforcement Group meets on average twice a year in Brussels and is chaired by arepresentative of the Commission. It is responsible for monitoring enforcement policy and practicein the EU Member States and making recommendations to improve the enforcement of wildlife
trade legislation. It also facilitates the exchange of information, experience and expertise on
enforcement issues between the Member States, including sharing of intelligence information andestablishing and maintaining databases. Opinions of the Enforcement Group are to be conveyed to
the Committee by the Commission.
In addition, EU‐TWIX (the European Union Trade in Wildlife Information eXchange) functions as animportant tool for information‐sharing and co‐operation between law enforcement officials andauthorities across the EU. Its database component, to which access is restricted to designatedenforcement officials, centralises information on wildlife trade seizures submitted by EU
enforcement agencies. This helps to monitor trends in illegal trade and enhance the efficiency of
enforcement actions. The mailing list component, meanwhile, facilitates the efficient sharing of
information between designated enforcement officials on seizures, and exchange experience andexpertise on matters related to illegal wildlife trade.

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North America
The North American Free Trade Agreement (NAFTA) is a comprehensive economic and trade
agreement that establishes a free‐trade area encompassing Canada, Mexico and the United States ofAmerica (USA). Since the agreement entered into force on 1 January 1994, NAFTA has systematicallyeliminated most tariff and non‐tariff barriers to free trade between the three countries (Anon.,2013h).
Mexico’s accession to CITES was a pre‐requisite for its inclusion in NAFTA. This occurred in 1991,
securing the necessary improvements in the country’s wildlife trade regulations for entry into forceof the free trade agreement (P. Mosig Reidl, TRAFFIC, in litt., 2013).
The relationship between the provisions of NAFTA and CITES is clarified by NAFTA’s Article 104. This
Article states that the trade obligations of CITES prevail over NAFTA's provisions to the extent of any
inconsistency between them. Trade in specimens of CITES‐listed species between the three NAFTA
countries is regulated in the usual way as between other CITES Parties, with permits issued bynational competent authorities for import and export, in accordance with the requirements of theConvention. Border controls remain in place between the USA and Canada and between the USA
and Mexico allowing for the inspection of CITES shipments and endorsement of permits as required.
Shipments of wildlife between the three NAFTA countries are dealt with in the same way as tradewith any other country.
While trade in CITES species is not directly impacted by the free trade provisions of NAFTA, Canada,
Mexico and the USA have nevertheless taken various steps to co‐operate on environmental matters,
including on illegal wildlife trade. Since 1994, the three countries have collaborated in protecting
North America's environment through the North American Agreement on Environmental
Cooperation (NAAEC), establishing an intergovernmental organization ‐ the Commission forEnvironmental Cooperation (CEC) ‐ to support co‐operation to address environmental issues ofcontinental concern. Through its Law Enforcement and Compliance Cooperation program, the CEC
supports the work of the North American Wildlife Enforcement Group (NAWEG), an organisation
formed in 1995 with the aim of improving North America’s capacity to enforce wildlife trade laws,
including by (Anon., 2013i):

improving the training of wildlife enforcement officers;
co‐ordinating the exchange of wildlife enforcement information at both the regional andglobal levels;
expanding access to forensic resources and technologies; andestablishing partnerships with international and regional enforcement agencies.

NAWEG works with other enforcement and compliance programmes to provide guidance indeveloping priorities for regional co‐operation on wildlife enforcement and develops strategies andproposals for co‐operative enforcement activities.

Southern African Customs Union
The Southern African Customs Union (SACU) is the world’s oldest Customs union(http://www.sacu.int). It was established in 1910 with the primary goal of promoting economic
development through regional co‐ordination of trade. The SACU currently consists of five member
countries, namely Botswana, Lesotho, Namibia, South Africa and Swaziland which have entered into
a number of trade agreements since the Custom union’s inception. The most recent SACU

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58agreement was concluded in 2002 to address issues including joint‐decision making processes andquestions of external trade.
The terms of the SACU make clear that the agreement does not suspend or supersede the provisionsof national legislation in its member countries regarding prohibitions and restrictions on import andexport. This is set out in Article 25(2) of the 2002 SACU Agreement which provides that:“Except in so far as may be agreed upon between the Member States from time to time, theprovisions of this Agreement shall not be deemed to suspend or supersede the provisions of any law
within any part of the Common Customs Area which prohibits or restricts the importation orexportation of goods.”
As a result of this provision, CITES must still be applied in the SACU member countries even thoughcertain Customs barriers have been dropped (D. Newton, TRAFFIC, in litt., 2013). This means, forexample, that permits must be issued for CITES trade between the member countries as required by
the Convention.

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DISCUSSION
The Eurasian Customs Union (ECU) and CITESThe Eurasian economic integration process started in 2000 with the creation of the Eurasian
Economic Community (EurAsEC). The Eurasian Customs Union (ECU) was established by Belarus,
Kazakhstan and Russia in 2007and started to be implemented in July 2010. In January 2012, theCommon Economic Space (CES) of these three countries started operating. Kyrgyzstan’s accession to
the ECU was agreed in 2010 and is planned for 2013. The future is also likely to see further
enlargement of the ECU to include participants such as Armenia and Tajikistan.
The ECU has a common Customs Code, which has replaced domestic Customs legislation in the ECU
member countries. Regarding CITES implementation in the ECU, all current member countries haveaccepted to follow their obligations under CITES. Legally, CITES‐listed species cannot be moved
freely within the ECU. However, due to the elimination of physical border controls at the internalborders of the ECU in July 2011, these requirements have not been implemented in practice. In
other words, while CITES documents are theoretically still required, there is no border control tocheck the shipments or to process the CITES documents even if these are granted.
The existing legal framework seemingly maintained the status quo of CITES implementation and left
the relevant authorities in the ECU countries with the impression that there is no need to address
the issue of CITES implementation and enforcement in the context of the emerging ECU and EEC.
However, this impression is misleading as the removal of Customs controls at borders between
Russia and Kazakhstan and between Russia and Belarus has created a vast Customs territory and theopening up of these borders has effectively removed a number of barriers to the legal and illegal
trade of wildlife between the EU, ECU member countries and the Far East, with reduced
opportunities for control and enforcement at borders. Once a specimen of a CITES‐listed species has
been illegally introduced into the ECU (e.g. by way of the route of least risk of detection) transport
throughout the ECU can now effectively continue unhindered. Native species can likewise be tradedfreely within the ECU, with fewer borders to cross between range areas and consumers in Western
Europe and East Asia.
To address this, a highly organized and co‐ordinated approach would need to be taken by ECU
member countries. As in the EU, co‐ordination and information exchange at all levels of CITES
implementation and enforcement would be necessary to ensure consistency across the ECU. An
absence of such consistency could result, for example, in wildlife traders being refused an importpermit by one ECU member country, only for the shipment to enter the ECU by way of a permit
granted by another member country. Enforcement capacity must also be at a similar level across the
ECU so that smugglers are not able to exploit the weakest link in the chain. It is cause for concernthat according to the findings of this project, the ECU have not considered these issues or taken theco‐ordinated monitoring and enforcement actions necessary for effective wildlife trade regulation
either within member countries or between member countries within the single Customs area.
Furthermore, the potential future enlargement of the ECU to include CITES non‐Parties such as
Tajikistan will create an additional layer of complexity for those addressing the implementation andenforcement of CITES in the ECU.
When a similar level of integration was reached in the EU in 1984 (i.e. when the European Single
Market came into effect resulting in the absence of systematic border controls within the EU), theEU decided that the provisions of CITES needed to be implemented in all EU Member States
uniformly and in a co‐ordinated manner through the adoption of a comprehensive set of EU
regulations that apply to all EU Member States. The EU Wildlife Trade Regulations establish three co‐ordinating bodies, which allow for regular and frequent information exchange and consistentdecision‐making for the different aspects of CITES implementation from scientific issues (ScientificWildlife trade in the Eurasian Customs Union and in selected Central Asian countries

60Review Group) to management (Committee) and enforcement issues (Enforcement Group). In
addition, EU‐TWIX20 functions as an important tool for the near real‐time information‐sharing
between enforcement officials and authorities across the EU. Whereas the EU also regulates internal
trade in Annex‐A listed species21, internal trade in CITES‐listed species in the ECU is only regulated on
paper but not in practice.
Other free trade agreements and regional economic integrations, for example ASEAN, NAFTA andthe South Asian Association for Regional Cooperation (SAARC), which represent a much smaller
degree of co‐operation among their member countries than that in the EU, have also found it usefulto establish formal mechanisms for co‐operating on CITES enforcement, and thus have establishedwildlife enforcement networks, namely ASEAN‐WEN, NAWEG and SAWEN, respectively.
Trade in CITES listed species in the target countries
Based on CITES trade data analysis, Russia reported the largest amount of trade from the target
countries for the period 2000‐2010 both in terms of overall imports and exports of CITES‐listed
species. This is in line with the size of the country (both in terms of territory and population), being
significantly bigger than any of the other target countries.
Imports to the region
Regarding imports, the most important commodities in terms of number of specimens imported
based on exporters’ reports for 2000‐2010 included: i) reptile bodies, parts and derivatives from theEU; ii) live plants from the Netherlands, the USA and Thailand; iii) live reptiles such as Horsfield’s
Tortoise traded between the target countries (e.g. from Kazakhstan to Russia and from Tajikistan via
Russia to Uzbekistan); and iv) live birds (mainly parrots and cockatoos) from Suriname, the Czech
Republic, Guyana and Guinea. Russia was the leading importer for all of these commodity groups.
(Re‐) exports from the region
Regarding exports, the most important commodities in terms of number of specimens exported
based on exporters’ reports for 2000‐2010 included:i)Live reptiles – Uzbekistan was by far the leading (re‐)exporter. The vast majority of (re‐)exports of live reptiles from the target countries involved tortoises, almost exclusively
Horsfield’s Tortoise (in total 460 554 tortoise specimens during 2000‐2010), practically all ofwhich were of wild origin. The main importers of Horsfield’s Tortoise were (in order ofimportance) the USA, the EU and Japan. (Re‐)exports of this species from Uzbekistan, the main(re‐)exporter, to the EU increased during the period 2000‐2010, despite a ban on the import ofwild specimens of Horsfield’s Tortoise into the EU from 2000 to 2006. The majority of these(re‐)exports from Uzbekistan were reported as Ranched (source code R).
The trade in Horsfield’s Tortoise from the region has received attention as part of the CITES
Review of Significant Trade process from July 2011, with Tajikistan and Uzbekistan categorized
as range States of concern. For Uzbekistan, the review was concluded in July 2012 as thecountry complied with all recommendations of the process. According to information
provided by Tajikistan, a moratorium has been declared on the export of wild animals native
to Tajikistan, unless a harvest quota is set. No quotas could be set for any species of live
tortoise (including Horsfield’s Tortoise) due to a lack of data on the number and status of wild
populations. It is therefore likely that Tajikistan will be removed from the Review of Significant
Trade process.

20
21

European Union – Trade in Wildlife Information eXchange. (See www.eutwix.org.)
Broadly equivalent to CITES Appendix I.

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61

A number of reporting anomalies were noted for Kazakhstan: between 2000 and 2010,
Thailand reported the imports of captive bred tortoises and other reptiles from Lebanon (atthe time not a Party to CITES), with country of origin reported as Kazakhstan. As Kazakhstan
reported none of these exports to Lebanon, the issue warrants further investigation andclarification.
ii)

Live birds – The main families represented in (re‐)exports were Strigidae (almost all of wild
origin), Falconidae (72% of reportedly captive‐bred origin) and Psittacidae (practically all of
captive‐bred origin). Uzbekistan was the leading (re‐)exporter of live birds among the target
countries between 2000 and 2010 followed by Russia and Kazakhstan. (Re‐)exports of captive‐
bred birds from Uzbekistan primarily involved Psittacidae and Falconidae specimens. (Re‐
)exports of wild‐sourced birds primarily involved birds of prey (Accipitridae, Falconidae andStrigidae). The main importers of live birds exported from the target countries were Japan, theUAE, the EU and the Ukraine. A number of notable discrepancies were detected between
numbers of live birds reported as (re‐)exported from the target countries, according toimporters’ and exporters’ reports, which warrants further attention in light of captive
breeding of some rare birds (both native and exotic species) going on in the target countries,
especially in Uzbekistan.

iii) Caviar – Russia and Kazakhstan were responsible for the majority of (re‐)exports of caviar
from the target countries, which exhibited a general declining trend during 2000‐2010. Key
importers of caviar from the target countries were the USA, the EU, Japan and Switzerland. It
is noted that both Russia and Kazakhstan have been implied in the Review of Significant Tradein Beluga Sturgeon and as neither of them complied with the recommendations formulated
during the process, the Standing Committee suspended trade of the species from these range
States in March 2013.
iv) Medicinal products derived from animals ‐ A total of 429 kg of products consisting of/derived
from Musk Deer Moschus moschiferus (reported with the CITES term “musk”) was (re‐)exported from Russia during the period 2000‐2010, according to exporters’ reports. However,when importers’ reports are considered, a larger quantity of 1561 kg was reported as (re‐)exported from Russia during the same period: this discrepancy is mainly related to (re‐)exports of musk from RU to the Republic of Korea and Hong Kong SAR, with these importing
countries/territories reporting much higher quantities in trade than reported by Russia. In
addition, between 2000 and 2010, Russia was the reported country of origin in respect of
127 408 kg of products consisting of/derived from Musk Deer (reported with the CITES terms“derivatives”, “extract” and “musk”), re‐exported primarily from Hong Kong (SAR) (126 932 kg)
and the Republic of Korea (462 kg) (according to exporters’ reports). Kazakhstan was the only
target country to have reported (re‐)exporting Saiga Antelope Saiga tatarica horn22 during theperiod 2000‐2010, (re‐)exporting 26 500 kg of this commodity to China in two commercial
shipments (in 2001 and 2003), according to exporters’ reports. Hong Kong SAR also reported
the import of 3000 kg of Saiga horn from Kazakhstan in 2002; however this commercial import
was not reported as a (re‐)export by Kazakhstan. It is noted that, in June 2001, the CITESStanding Committee recommended that the CITES Parties suspend all imports of specimens of
Saiga Antelope from Kazakhstan and Russia until these two range States had complied withcertain recommendations, including with regard to the implementation of a regional
conservation strategy for the species.

22

Reported with the CITES terms “horns” and “horn products”.

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62

v)

Hunting trophies – The majority (81%) of trophy items were exported from Russia (7369
trophies), with smaller numbers exported from Tajikistan (701 trophies), Kyrgyzstan (668
trophies), Belarus (167 trophies) and Kazakhstan (126 trophies). The main taxonomic groups
represented in hunting trophies exported from the target countries were, according toexporter reported quantities: Ursidae (mainly Brown Bear), Anatidae, Bovidae species (Argali),
Canidae (Wolf) and Felidae (Eurasian Lynx). The EU was the most important destination for
hunting trophies exported from the target countries during the period 2000‐2010, followed by
the USA.

The ECU has been implemented from July 2010. Therefore, changes in trade patterns and flows
inside the ECU (i.e. among the members of the ECU) could not yet be examined as 2010 was the lastyear for which relatively complete information was available for.
Overall, there were large discrepancies between traded quantities as reported by the importers andthe exporters. Some of these discrepancies are likely to be due to the poor communication and co‐operation between the MAs and the Customs, which has resulted in copies of export permits notreaching the MAs. This was confirmed by interviews conducted in the countries as part of thisproject.
CITES legislation in the target countries
Each CITES Party has to adopt its own domestic legislation to ensure that the Convention is
implemented at the national level. Legislation of most target countries have been put in category 2
as part of the CITES National Legislation Project (Belarus, Kazakhstan, Kyrgyzstan, Uzbekistan), while
Russia’s legislation is in category 1 and Tajikistan is not a CITES Party. With the exception of
Kyrgyzstan, the target countries whose legislation has been categorized in Category 2 have been
Parties to CITES for many years allowing ample time for enacting improved legislation orcommunicating new legislation adopted to the CITES Secretariat. Gaps in legislation were found in
most target countries (with Tajikistan clearly standing out as a non‐Party and, as would be expected,
the country lacks legislation regulating trade in non‐native species). For instance in Russia, noauthority is clearly assigned the responsibility of carrying out controls of wildlife trade on theinternal market (e.g. at pet shops or breeders). In Uzbekistan, while higher level laws have beenenacted, some of their implementation regulations have not and so detailed rules for
implementation are lacking. The ECU is intending to harmonize sanctions that can be applied forillegal trade, which would also be required in the case of sanctions applicable for illegal wildlife
trade. Those involved in illicit activities may use certain entry points knowing that the risk of a strict
punishment is low in the given country. In the ECU context this would be highly undesirable.
CITES authorities and inter‐agency co‐operation
The CITES authorities are clearly designated in each of the target countries. This also includes
Tajikistan, which is not a Party to CITES at the time of writing; there is a competent authority for
issuing documents comparable to CITES documents. It is this same agency that is expected to
become the MA upon Tajikistan’s planned accession to CITES. Co‐operation among the different
CITES authorities at national level, especially between the MA and the Customs was reportedly poor,
as also demonstrated by the large discrepancy of imports reported by the target countries and theirtrade partners (copies of processed CITES permits are not sent on to the MA) or by the poor record
keeping of CITES seizures: many times the scientific name of the species or the trade route were notrecorded.
The information obtained during the country visits indicates that inter‐agency co‐operation at theregional level is also weak and when present at all, focuses on specific species (e.g. Saiga Antelope
conservation) and not on CITES in general. The information provided by the target countries

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63indicates no established mechanisms for regional co‐ordination and communication, or exchange of
information not even among ECU member countries.
Compliance with CITES provisions
All target countries submitted some of their CITES annual reports with a delay during the period
2006‐2012. Russia did not submit an annual report for 2006 at all. The submission rate of CITES
Biennial Reports was even lower. Belarus was the only one among the target countries which
submitted all of their Biennial Reports for 2003‐2010 in a timely manner, while other target
countries did not submit any Biennial Reports (e.g. Kazakhstan, Kyrgyzstan, Russia), indicating that
there is further room for improvement. (Tajikistan is not a Party to CITES and therefore is not
required to submit any of these reports.)
Several of the target countries have been implied in the Review of Significant Trade (RST) process,some of which has led to a trade suspension: most recently, the Standing Committee imposed a
trade suspension for Beluga Sturgeon Huso huso for Kazakhstan and Russia on 2 May 2013 as theserange States did not comply with recommendations formulated by the relevant CITES committees.
Another RST procedure focusing on Saker Falcon led to the imposition of zero export quotas for
Kazakhstan, Kyrgyzstan, Russia and Uzbekistan (among others) in 2007, which is still in place. There
have also been more positive examples of outcomes of the RST process; for instance Uzbekistan andHorsfield’s Tortoise were taken out of the RST process in July 2012 after Uzbekistan provided
satisfactory information to the questions raised by the relevant CITES committees. This also
underlines the importance of communication and the provision of the requested information to the
CITES Secretariat and various committees, which is required for the daily work of the Convention.
Training and capacity building
There are special schools for the training of Customs officers in all target countries. Nevertheless,many Customs officers are also trained abroad: the Russian Customs Academy offers courses tomany of the target countries, such as Kazakhstan, Kyrgyzstan and Tajikistan. The Russian Customs
Academy has had a course on CITES in its curriculum since 2006. A special course on prevention of
wildlife smuggling has been developed in the Vladivostok branch of the Russian Customs Academy.
Examples of training events and workshops were provided during the country visits, for instanceabout training workshops held in Kazakhstan (with the support of FAO in 2012), in Kyrgyzstan(organized by the MA) in 2012, in Tajikistan in 2012 and 2013 (as part of an Organization for Security
and Co‐operation in Europe (OSCE) education programme), and in Uzbekistan (regular training
seminars for Customs by the MA since 2011).
During the country visits, the authorities in Belarus, Kyrgyzstan (a relatively new CITES Party) andTajikistan (preparing for CITES accession) specifically noted that more CITES training would be
required in their country. Kyrgyzstan also mentioned that training for the MA and SA would also bebeneficial along with the country’s more active participation in international CITES fora mainly forcapacity building purposes. In this regard, the Kyrgyz authorities also noted their poor knowledge ofthe official CITES languages. Kazakhstan reported about an adequate level of awareness about CITES
among their Customs officers.
Although there have been training seminars conducted in the target countries, these do not appear
to have been sufficiently regular or reaching a sufficiently large number of staff, especially if theturnover of Customs staff is taken into account. Therefore, any training seminar in the future in thetarget countries should start from a basic level of introduction to CITES and focus on species
identified under the illegal trade section (below). The importance of co‐operation and co‐ordination
among the ECU member countries cannot be stressed enough, which could be greatly helped by theholding of regional training workshops.

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Although these were not specifically mentioned by the countries during the country visits, several
regional training events were also organized, for instance as part of the Green Customs Initiative.
This initiative aims to enhance the capacity of Customs and other relevant enforcement personnel tomonitor and facilitate legal trade and to detect and prevent illegal trade in environmentally‐sensitive
commodities covered by the relevant conventions and multilateral environmental agreements,
including CITES (http://www.greencustoms.org/). Examples of events held in the region included theGreen Customs Workshops in Minsk, Belarus, 30 ‐ 31 May 2012, and in Astana, Kazakhstan, 27 ‐ 28
June 2012. Another regional event organized by the CITES Secretariat was the workshop forstrengthening CITES implementation capacity to ensure sustainable wildlife management and non‐detrimental trade, in Riyadh, Saudi Arabia, held in December 2011 and which had several
representatives of the target countries as participants.
Training and species identification materials have also been developed in the region: in Belarus in
2006, in Russia in 2005 (updated several times since then), in Uzbekistan in 2013. Two of thesematerials received input/financial support from NGOs. In addition, the MA in Uzbekistan has
updated their short guide to CITES‐listed species, but funding is still being sought for its publication.
Kyrgyzstan and Tajikistan clearly noted the need for more training and identification materials.
In ECU member countries, as well as Kyrgyzstan (in the process of preparing for ECU accession),
Customs offices at the borders were reported to be well equipped with computers and internet
connection. The priority of electronic administration over paper based administration has been oneof the key requirements under the ECU, which implies that e‐versions of training and identificationmaterials would be adequate.
Reported illegal trade
Some of the target countries did not provide information on seizures during this project or reported
that no CITES seizures were made in their country (Kazakhstan, Kyrgyzstan, Russia and Tajikistan).
Some target counties (Belarus, Uzbekistan) reported detected cases of illegal trade however, thequality of these reports were low, with some key information (e.g. scientific name of species
involved, trade route) missing or incomplete. Each country provided their perception of what can befound in illegal wildlife trade in their country, which is summarized below.
i) Illegal activities related to trophy hunting were noted by Kazakhstan, Russia and Tajikistan,
and according to some of these countries, Kyrgyzstan may also be implicated in this trade.
Kazakhstan noted that illegal trophy hunting of mountain sheep (e.g. Argali Ovis ammon), may
be carried out by mis‐declaring the purpose of the hunt for scientific purposes. The hunts are
granted permits (for scientific purposes) but the trophies are taken to Russia, with wealthy
hunters from Russia being the main customers of these hunts. Kazakhstan also reported theillegal export of Grey Wolf Canis lupus trophies to Russia and to a lesser extent to Belarus.
While the taking of Grey Wolf is legal is Kazakhstan, the exports are reported to take place
without the required CITES documents. In another case detected in Russia, trophies of Argali
and Markhor were seized on import from Tajikistan. The shipment was accompanied byfalsified Russian CITES documentation. Tajikistan reported that trophy hunting of mountain
ungulates involves high revenues, corruption and illegal trade. Tajikistan also reported
another way of illegal hunting: the permit is issued for the hunting of one specimen but inpractice, two specimens are taken. This may happen when having shot one specimen, thehunter encounters another one with better trophy properties. The organizers of the hunt may
decide to overlook the shooting of the second animal for an additional (unofficial) fee.

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65

ii)

The illegal trade in Saiga Antelope horn is related to illegal hunting but in this case thepurpose of the hunt and the trade is different: the horns are used in traditional Asian
medicine. This issue was mentioned by Russia, Kazakhstan and Uzbekistan. Uzbekistan
reported the seizure of 567 Saiga Antelope horns in four seizures over the period 2007‐2012.
Other wildlife used in traditional Asian medicine mentioned by the countries included Musk
Deer (musk, from Russia), Brown Bear (bile and paws, from Kyrgyzstan and Russia), Tiger(bones, from Russia), Ginseng (roots, from Russia), Snow Leopard (bones from Kyrgyzstan andTajikistan).

iii) Falcons (mainly Saker Falcon Falco cherrug) illegal taking from the wild was mentioned as animportant issue by Kazakhstan, Kyrgyzstan, Russia and Uzbekistan. The birds are reportedly
destined for the Middle East. The total volume of illegal export of falcons from Russia wasestimated in 2008 to be between 1000 to 1500 specimens a year. Kyrgyzstan reported playing
a transit role in the illegal trade of falcons from Kazakhstan and Russia to the Middle East.
Kyrgyzstan also reported about the potential role that falcon breeding facilities may play inlegalizing some of these wild‐taken falcons in that country. In addition to the Middle East,
Kazakhstan also noted Pakistan as a destination for the falcons. Uzbekistan reported theseizure of 42 live specimens of falcons in two seizures during 2007‐2012. It is interesting tonote that the analysis of CITES trade data (i.e. of reported legal trade) also highlighted notablediscrepancies between trade recorded by importers and exporters for live birds, especially forfalcons. The zero export quotas set as part of the RST process for Saker Falcon appears to be
warranted.
iv) Tortoises were reported to appear in illegal trade by Kazakhstan, Kyrgyzstan and Uzbekistan,with Russia mentioned by two of these countries as a destination market for the tortoises. In
addition to Russia, Kyrgyzstan reported China, Turkey and the UAE as important destination
markets. Kazakhstan noted Russia and Uzbekistan as consumers. Uzbekistan reported theseizure of a total of approximately 7000 live specimens of tortoises (species unspecified) inseven seizures during 2007‐2012. Again, the analysis of the legal trade data also indicatedpotential issues regarding trade in tortoises: according to importers’ reports: between 2003
and 2006, Lebanon (a non‐Party to CITES at the time) re‐exported 19 131 live specimens oflizard, turtle and tortoise to Thailand and Japan, all of which were declared as having been
captive‐bred with the country of origin reported as Kazakhstan. Kazakhstan, however, did notreport the export of any live captive‐bred reptiles to Japan, Lebanon or Thailand during theperiod 2000 and 2010.
The target countries of this project appear to be mainly the source of wildlife illegally taken andtraded. However, Russia has a dual role, being both a source as well as a consumer market for
certain wildlife commodities (e.g. live tortoises). Kyrgyzstan and Uzbekistan also seem to play atransit role in illegal trade. In the context of the ECU, the picture is even more complex with
consumer and source regions being within the same borders.
The interest in detector dog programmes in Kazakhstan and the already operational programme in
Russia are promising and are expected to assist the target countries in fighting illegal wildlife trade.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

66

CONCLUSIONS AND RECOMMENDATIONS

The target countries are mainly important source countries for wildlife in trade, with some of themplaying a transit (e.g. Kyrgyzstan) or a consumer role (Russia) as well. With the exception of
Tajikistan, all target countries are Parties to CITES and have been implementing and enforcing theprovisions of the Convention for several years or even decades. However, there remain a number ofareas, which would benefit from further improvement. These areas include i) addressing gaps innational legislation, ii) enhancing the co‐operation between the CITES MA and enforcement staff, iii)
ensuring regular CITES training for enforcement staff, and iv) improved reporting to CITES (both on
legal and illegal trade).
This baseline situation with its challenges has become more complex with the formation of the ECU
in July 2010. While formally the ECU is not meant to affect CITES implementation and enforcementin the target countries (i.e. according to the regulations in place, CITES‐listed species are not coveredby the ECU), it does have implications for wildlife trade. With the removal of controls at the internal
ECU borders, CITES‐listed wildlife can be moved freely within the ECU. In this context, a highlyorganized and co‐ordinated approach would need to be taken by ECU member countries. Co‐
ordination and information exchange at all levels of CITES implementation and enforcement would
be necessary to ensure consistency across the ECU. An absence of such consistency could result in
the exploitation of the weakest link in the chain (e.g. illegal trade entering the ECU by way of theroute of least risk of detection) or permit shopping (e.g. when wildlife traders are refused an importpermit by one ECU member country, the shipment may enter the ECU by way of a permit granted byanother member country), which poses a threat to both native and exotic wildlife traded by the ECU
members. Furthermore, the potential future enlargement of the ECU to include non‐CITES Parties
such as Tajikistan may create an additional layer of complexity for those addressing theimplementation and enforcement of CITES in the ECU.
Accordingly, it is concluded that CITES implementation and enforcement warrants further attention
by current and future member countries of the ECU. The following recommendations are suggested
to address the issues identified:
Strengthening national legislation in the region‐ Where there are gaps in national legislation, these should be addressed by the adoption of
new legislation or amendment of existing regulations (e.g. in Kyrgyzstan, Russia andUzbekistan).
‐ Target countries are advised to consider adopting legislation, which prescribes theregistration and regular control of captive breeding facilities where this is not required
already, and which makes the marking of certain CITES‐listed species obligatory. This would
be particularly important for Kyrgyzstan and Uzbekistan but also for other target countries.
Strengthening Enforcement of CITES controls in ECU members‐ Customs are encouraged to provide copies of processed CITES documents to their CITES MA.
‐ Enforcement authorities in the target countries are encouraged to improve their record
keeping of detected cases of illegal trade to ensure that key information (e.g. scientific nameof species, trade route, etc.) are recorded, stored centrally and shared with the CITES MA.
‐ When carrying out controls at the external borders, risk assessments and targeted controls
by enforcement authorities should take into account the trends in legal as well as indetected cases of illegal trade, preferable considering these at the ECU level (as opposed tofocus on national level only).
‐ Notable discrepancies identified in legal trade reports (e.g. when comparing exporters’ andimporters’ reported quantities or the case of Kazakhstan that according to some trade
Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

67partners reported significant exports without Kazakhstan reporting those exports), especiallywhen detected cases of illegal trade indicate a similar trend, should be monitored by theMAs and investigated by the enforcement authorities, if warranted. For example, more
attention on breeding facilities is suggested by the findings of this report (e.g. in Kyrgyzstan
and Uzbekistan).
Inter‐agency co‐operation among CITES authorities at national level‐ The different authorities responsible for CITES implementation at the national level should
regularly meet to exchange information and co‐ordinate their activities. The signing ofagreements or Memoranda of Understanding between the relevant authorities may help
formalize the co‐operation and ensure participation of the relevant agencies.
‐ The target countries are encouraged to establish National Environmental Security Task
Forces (NEST) as recommended by Interpol.
Training and capacity building‐ Further CITES training is recommended in the target countries. Preferably, these should beheld regularly to ensure continuity even for authorities with a high staff turnover. Train the
trainer workshops are also encouraged.
‐ The holding of regional (or ECU) level training seminars is greatly encouraged as that would
also help improve regional co‐operation.
‐ The CITES Secretariat is encouraged to assist the target countries in their efforts to organize
training events both by the participation of CITES Secretariat staff and by assistance inobtaining financial resources for training as far as possible.
‐ The target countries are encouraged to participate in all wider or regional training initiatives,
such as those organized by the Green Customs or OSCE.
‐ The training materials developed by the target countries (e.g. those developed in Belarus,
Russia, Uzbekistan) should be used more widely in the region and adapted to national needs,
as necessary.
CITES in the ECU‐ Current ECU members and Kyrgyzstan imminently joining the ECU are encouraged to raise at
all levels the urgent need for an organized and co‐ordinated approach to CITES
implementation and enforcement in the ECU in order to ensure consistency across themember countries.
‐ ECU member States are encouraged to establish co‐ordinating mechanisms, based on thebest practice examples of existing regional economic integrations (e.g. mechanisms
established by ASEAN, EU, NAFTA), which allow for regular and frequent informationexchange and consistent decision‐making for the different aspects of CITES implementationfrom scientific to management and enforcement issues. ECU member States are encouraged
to formalize these co‐ordinating mechanisms in ECU legislation. The discussions on co‐ordination should also address the issues surrounding the implementation of nationally set
export quotas in the ECU context.
‐ To this end, ECU member States are recommended to establish a Wildlife Enforcement
Network.
‐ In addition, the establishment of new or the wider use of existing (close to) real‐timeinformation‐sharing mechanisms between authorities across the ECU are recommended.
‐ ECU member countries should consider regulating or monitoring internal trade in some
CITES‐listed species (e.g. those listed in Appendix I or a selection of these species).
‐ The intentions for harmonizing sanctions across the ECU in general are encouraged to be
implemented for illegal wildlife trade, too.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

68International co‐operation with other relevant institutions‐ The target countries should inform the CITES Secretariat about changes in their national
CITES legislation and provided a translation of the new legislative text (in one of the working
languages of CITES).
‐ Those CITES authorities of the target countries, which do not yet participate actively invarious international CITES fora or provide the required information as part of different
CITES processes (e.g. Review of Significant Trade), are encouraged to do so in order to get abetter understanding of the working mechanisms of the Convention or to assist the work of
the Convention.
International accession to and co‐operation with CITES‐ In view of the developments under the ECU more generally and the above‐mentioned
challenges, further conscious of Tajikistan’s own expression and desire to join the ECU, andmindful of the President of Tajikistan’s recommendations to the Tajik Parliament regarding
the ratification of CITES, the Government of Tajikistan should be further encouraged andsupported to continue its plan to accede to CITES at the earliest opportunity.

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69

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ANNEX I
List of authorities participating in meetings in the target countries in March‐April 2013
Belarus CITES Management Authority (MA): Ms Natalia Minchenko – Head of Department of Biology
and Landscape Diversity, Ministry of Natural Resources and Environmental Protection;
 CITES Scientific Authority (SA): Mr Ruslan Novitsky – Head of Wildlife Conservation Dept. of
the State Scientific and Production Amalgamation of the National Academy of Science; Mr
Dmitry Tretiakov – Senior researcher of Botany Institute; Customs: Mr Alexander Krivosheja – Senior Inspector of Customs;
 Other: Ms Galina Volchuga ‐ Vice‐Minister of Natural Resources and Environmental
Protection; Ms Marina Filipiuk – Department of International Collaboration, both from the
Ministry of Natural Resources and Environmental Protection; Ms Elena Shushkova,“Ecoproject” (NGO).
Kazakhstan
 CITES MA: Mr Bakhytbek Duysikeev – Vice‐Head of the Committee of Hunting and Forestryof the Ministry of Agriculture; Customs: Mr Yury Kim – Senior Expert of Kazakh Customs;
 Other: Mr Sergey Bolozh – Senior staff of the Committee on Hunting and Forestry; Dr.
Tatiana M. Bragina, WWF Project leader in Kazakhstan; Mr. Victor Ukrainsky – Game
management specialist, ex‐director of “Ohotzooprom”, recently ‐ independent expert,
consultant of Kazakh CITES SA.
Kyrgyzstan
 CITES MA: Mr Almaz Musaev, Hunting Department of State Agency of Environment
Protection and Forestry (CITES focal point); Mr Sabir Atadjanov – Director of State Agency ofEnvironment, Conservation and Forestry; CITES SA: Mr Bekmamat Djenbaev – Director of the Biological and Soil Research Institute of
the National Academy of Sciences;
 Customs: Mr Ulan Muratov –Senior inspector, Anti‐smuggling Department, State Customs
Service; Mr Ulan Kimeinov –Head of Customs at Manas International Airport (Bishkek); Other: Ms Lira Sabyrova – Counsellor, Department of International Organization and
Security, Ministry of Foreign Affairs; Ms Saltanat Seitova – Director of Wildlife Rescue Centre(funded by NABU23); Ms Farida Balbakova – WWF Project Leader for Kyrgyzstan; Ms
Valentina Toropova – the Executive Director of the Kyrgyz representation of NABU.
Russia CITES MA: Ms Tatiana Skripnik – Vice–head, Division on Permit Issuing of the Federal
Supervisory Natural Resources Management Service (Rospirodnadzor)
 CITES SA: Alexander Sorokin – Head, Division of the all‐Russian Research Institute of Nature
Protection, Vice‐head of SA;
 Customs: Ms Svetlana Senotrusova, Professor at the Faculty of Civil Management of the
Moscow State University and of the Russian Customs Academy.
Tajikistan

23

Naturschutzbund Deutschland (NABU) e.V., a German Nature Conservation NGO.

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73




Ministry of Environment: Mr Abdukadyr Maskaev – Head, Division of Conservation of andControl on Use of Plants and Animals; Mr Alikhon Latifi – Advisor to the Tajik Hunting
Association, former Vice Minister of Conservation and Nature Protection;
Other: Ms Firuza Illarionova, conservationist, WWF Project Co‐leader in Tajikistan; Mr Zafar
Bekmurodov and Mr. Otobek Bekmurodov – Co‐chairmen of the Tajik Hunting Association;
Mr Stefan Michel – GIZ Project leader in Tajikistan; Mr Kokul Kassirov – former senior staff ofthe Ministry of Environment (focal point for CMS and the Ramsar Conventions).

Uzbekistan
 CITES MA: Mr Alexander Grigoriants – Head, State Inspection on Protection of Animals andPlants of the Republic of Uzbekistan (“Gosbiokontrol”);
 Other: Mr Oleg Tsaruk, Ecologist and researcher.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries74

ANNEX II
Stricter measures in the EU and the USA
As the EU and the USA have been identified as important destinations of wildlife exported from thetarget countries, it is interesting to provide further information about some of the stricter importmeasures implemented by the EU and the USA for wildlife in trade. The EU and the USA might also
require additional information from the target countries of this project before making decisions oncertain imports. Therefore, it is important to understand the decision making mechanisms and thebackground to these. The following section provides a brief overview of these stricter measures.
Stricter measures in the USA
This section is based on information obtained from the US Fish and Wildlife Service (US FWS)
website (http://www.fws.gov/international and http://www.fws.gov/permits). In the USA, theEndangered Species Act of 1973 (ESA) is the key legislation that implements CITES, which howevergoes beyond the requirements of the Convention. It lists species into two groups: i) endangered
species and ii) threatened species. An “endangered” species is in danger of extinction throughout all
or a significant portion of its range. A “threatened” species is likely to become endangered in theforeseeable future. Division of Scientific Authority (under the FWS) biologists draft proposed andfinal rules for the listing, reclassification, or delisting of foreign species under the ESA. Whenevaluating species for listing, solely biological status and threats to their existence are considered.
This also highlights that under CITES and the ESA both the mechanisms for listing species and thespecies listed are somewhat different. Accordingly, a species may be listed under the ESA (e.g.
species native to the USA) but not under CITES or under both. In line with this, the international
trade in these species may require a permit under the ESA, CITES, or both. As the list of species is
kept updated regularly, it is advised that those interested in exporting wildlife to the USA regularly
check the list of species protected under the ESA at: http://www.fws.gov/endangered/.
It is important to note that the different populations of the same species may be categorized
differently under the ESA. For instance, Argali Ovis ammon from Kyrgyzstan, Mongolia and Tajikistan(where an annual quota on the take of the species has been published) are listed as “threatened”,
while the same species from the other range States are categorized as “endangered” and thus
stricter conditions apply to them. The imports of wildlife, including parts and products, like trophies,
mustgothroughoneofthedesignated
ports
of
entry
for
wildlife(www.fws.gov/le/ImpExp/Contact_Info_Ports.htm). These ports are used for all movement of
wildlife, including for commercial, non‐commercial, scientific, or personal purposes. Certain port
locations are designated to allow the international movement of any lawful wildlife, while otherlocations are restricted to allow only certain types of wildlife for certain purposes.
Special rules may also be published under the ESA. For instance, On 4 March 2005, the USFWS
published a Special Rule to control trade in Beluga Sturgeon Huso huso, listed as “Threatened” under
the ESA in 2004. Under the Special Rule, for trade with the USA to continue, Caspian and Black Sea
littoral States were to provide certain information to the USA Scientific Authority, including copies ofbasin‐wide management plans for Beluga Sturgeon and copies of their national laws implementing
the management plans. This information was to be provided within six months of the date of
publication of the Special Rule. After the Caspian Sea littoral States failed to provide any of theinformation required under the Special Rule, the USA suspended import of and foreign commerce inBeluga Sturgeon caviar and meat originating in the Caspian Sea basin on 30 September 2005. On 28
October 2005, the USA suspended import of and foreign commerce in Beluga Sturgeon caviar andmeat originating in the Black Sea basin after Black Sea littoral States failed to provide information

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

75required under the Special Rule. These trade suspensions remain in place. However, they may belifted at any time if the necessary information is submitted.
It is also noted that, in addition to the ESA, the USA has enacted other legislation that is also relevant
to trade in CITES‐listed species. An example is the US Marine Mammal Protection Act, which
prohibits the import of any marine mammal parts or derivatives. Therefore, parts or derivatives of a
CITES Appendix II‐listed species such as Narwhal (e.g. a Narwhal tusk) could not be legally imported
into the USA, even if accompanied by a valid CITES export permit (E. Cooper, TRAFFIC in litt. to K.
Kecse‐Nagy).
Further information can be obtained from the US CITES MA:
U.S. Fish & Wildlife Service, International Affairse‐mail: managementauthority@fws.gov
http://www.fws.gov/international
http://www.fws.gov/permits

Stricter measures in the EU
The information presented in this section is based on the European Commission’s website on CITES(in particular http://ec.europa.eu/environment/cites/pdf/differences_b_eu_and_cites.pdf).
The EU has also adopted a number of measures, which are stricter than CITES.
EU Annexes
First of all, the EU Wildlife Trade Regulations categorize species in four Annexes as opposed to thethree Appendices of CITES.
Annex A: All CITES Appendix I species, except where EU Member States have entered a reservation
 Some CITES Appendix II and III species, for which the EU has adopted stricter domestic
measures Some non‐CITES species
Annex B: All other CITES Appendix II species, except where EU Member States have entered areservation
 Some CITES Appendix III species
 Some non‐CITES species
Annex C: All other CITES Appendix III species, except where EU Member States have entered areservation
Annex D: Some CITES Appendix III species for which the EU holds a reservation
 Some non‐CITES species
 The import into the EU of the species listed in this Annex warrants monitoring
In practice this means that a larger number of species are accorded a greater level of regulation andprotection than by CITES. For instance, all Annex A‐listed species get the same protection as

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

76Appendix I‐listed species, while Annex A lists CITES Appendix I species, as well as some Appendix II
and III species, and non‐CITES listed species.
In addition, the import of both Annex A and B‐listed species into the EU requires an import permit
and the making of the related non‐detriment finding by the Scientific Authority of the importing EU
Member State. An import notification is required for Annex C and D species. An import notification isa declaration filled in by the importer and to be submitted, where appropriate together with CITES
Appendix III documents from the (re‐)exporting country, to the Customs office of introduction into
the EU.
Import restrictions
Regulation (EC) 338/97 provides the Commission with the possibility to establish import restrictions
with regard to certain species/countries. The procedure is outlined in Figure 6 below (taken fromhttp://ec.europa.eu/environment/cites/pdf/differences_b_eu_and_cites.pdf
andEuropeanCommission and TRAFFIC (2013)):
1. A Scientific Authority advises its Management Authority not to issue an import permit because it
is of the opinion that one or more of the import conditions are not met (or the Scientific Review
Group24, SRG, decides at one of its meetings that this is the case, A and B in Figure 6).
2. The authorities in the other Member States are immediately informed of this advice and suspend
the issue of import permits until a restriction is established or not. Due to the absence of internalborder controls, it is essential that any import restrictions are applied throughout the EU (A, B
and C in Figure 6).
3. The opinion of other Scientific Authorities of EU Member States is sought (if the case has not
yet been discussed at the SRG meeting. If a non‐detriment finding is made, the SRG forms a
Positive Opinion and imports can be resumed. If the initial opinion is confirmed, the SRG forms a
Negative Opinion (i.e. the import is deemed to have a harmful effect on the conservation statusof the species). For as long as this opinion is in place Member States will normally reject all permit
applications for the species/countries in question. (D in Figure 6) Opinions of the SRG areavailable here: http://www.unep‐wcmc‐apps.org/eu/taxonomy/tradeRestSearch.cfm.
4. On a regular basis, the Commission consults with affected range States to ask them for any new
biological and trade information on the species subject to an import restriction (E in Figure 6). If
the range State provides this information, the SRG reconsiders its decision to suspend the import.
If the information leads to a non‐detriment finding, the Negative Opinion is transformed into a
Positive Opinion. If there is no new information provided by the range State or other sources, orif this information is not sufficient for a non‐detriment finding, the Negative Opinion will beformalised through a publication of the import suspension in the Official Journal of the European
Union (F in Figure 6). It is important to note that the published import suspensions are reversible
at any moment if new information is received. The latest suspensions are available here:
http://www.unep‐wcmc‐apps.org/eu/taxonomy/tradeRestSearch.cfm, andhttp://eur‐lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32013R0578:EN:NOT.
Hunting trophies
The import into the EU of Annex A‐listed trophies requires both an export and an import permit. For
the import of an Annex B‐listed hunting trophy for non‐commercial purposes into the EU, only an
export permit is required. However, at the time of writing, August 2013, the European Commission is24

Scientific Review Group (SRG) consists of representatives from the Scientific Authorities of EU Member
States.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

77conducting a consultation regarding a possible revision of the EU Wildlife Trade Regulations which
would require import permits be issued for hunting trophies of Annex B specimens (all or selected
species or populations) into the EU (European Commission, 2013).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

78Figure 6
Overview of procedures to establish Positive and Negative Opinions and import restrictions for
species listed in Annex A or B of the EU Wildlife Trade Regulations
At National level
Scientific Authority (SA) makes a decision on whether or not to allow an import based on nondetriment finding under Article 4(1)(a)(i) or 4(2)(a) of Regulation (EC) No 338/97
SA to check if there is an existing SRG Opinion. If so, this existing SRG Opinion will be followed
unless circumstances have changed or additional information has become available.

SA positive advice= imports can take place

SA negative advice= imports cannot be allowed

The Management Authority rejects import application andinforms the Commission

At EU level
SRG examines scientific issues(e.g. by regular review of tradelevels for species/country
combinations or levels of voluntary
export quota)"No Opinion"
by SRGThe Commission notifies other EU Member
States and the issuance of import permits is
put on hold (where there is not yet a Negative
Opinion of the SRG in place)
Consultation with SRG on this SA opinion(either by post or in meeting)

SA negative advice confirmed by SRG =SRG Negative Opinion

SA negative advice not confirmed by SRG =SRG Positive Opinion

A

B

C
D

Included in EU Wildlife Trade Regulation Database at www.unep-wcmc.org
SRG Negative Opinion:
The Commission may consult affected Range State about
establishing an import restriction under Article 4(6) ofRegulation (EC) No 338/97

Third country reply: when restriction NOT
supported = issue referred back to SRG

Negative opinion reversed into a
SRG Positive Opinion: imports
can be allowed

SRG Negative Opinion
confirmed

SRG Positive Opinion: imports can beallowedE

Third country reply: restriction supported

Legally binding import suspension establishedand published in Official Journal of theEuropean Union as“Suspension Regulation"F

Source: European Commission and TRAFFIC (2013). Reference Guide to the European Union Wildlife Trade Regulations

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

79

Table 8
EU import restrictions and opinions of the Scientific Review Group (SRG) in effect September 2013
for target countries of this project

ScientificnameCommonname

CITES
Appendix/
EU Annex

Suspension (Article
4.6 of theSuspensions
Regulation)*

Opinionof theSRG

Grey Wolf

I/II, A/Ba‐

RussianSturgeon

II/B

negative

Since 2010

Ship Sturgeon

II/B

positive

Since 2002

Stellate
Sturgeon

II/B

negative

Since 2010

Grey Wolf

II/B

positive

Hunting trophies(since 2007)

II/B

negative

Since 2010

Details

Belarus
Canis lupus

Kazakhstan
Acipenser
gueldenstaedtii
Acipenser
nudiventris
Acipenser
stellatus
Canis lupus

Testudohorsfieldii

BelugaSturgeon
Horsfield’s
Tortoise

Ursus arctos

Huso huso

Wild hunting trophies(negative opinion formed
in 2003 and turned into asuspension in 2004)

All wild specimens (since
2006)
Wild hunting trophies(negative opinion formed
in 2008, turned into asuspension in 2012)

II/B

b

Brown Bear

I/II, Aa

Canis lupus

Grey Wolf

I/II, A/B

positive

Since 2012

RussiaAcipenser
gueldenstaedtii
Acipenser
stellatus
Anthropoides
virgo

RussianSturgeon
Stellate
Sturgeon
Demoiselle
Crane

II/B

negative

Since 2010

II/B

negative

Since 2010

II/B

positive

Since 2001

Canis lupus

Grey Wolf

I/II, A/B

positive

Hunting trophies(since 1997)

Kyrgyzstan

Gyps bengalensis
Huso huso
Moschusmoschiferus
Saiga borealis

Asian White‐
BackedVultureBelugaSturgeonSiberian Musk
Deer
Mongolian
Saiga

II/B

All wild specimens(Since 2005)

b

II/B
II/B

b

II/B

b

Ursus arctos

Brown Bear

I/II, A

Ursus thibetanus

Asian Black
Bear

I/A

a

Cypripedium
macranthos

NA

II/B

b

negative

Since 2010

positive

All wild specimens (since
1999)
All wild specimens (since2003)
Hunting trophies from all
populations(since 2010)
Wild hunting trophies(since 2006)
Wild source(since 2001)

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

80ScientificnameCommonname

CITES
Appendix/
EU Annex

Suspension (Article
4.6 of theSuspensions
Regulation)*

Orchiscoriophora

NA

II/B

b

Orchis pallens

NA

II/B

b

Orchis ustulata

NA

II/B

b

Opinionof theSRG

Details
Wild source(since 2001)
Wild source(since 2001)
Wild source(since 2001)

Tajikistan
Canis lupus

Grey Wolf

I/II, A/B

Testudohorsfieldii
Uzbekistan

Horsfield’s
TortoiseII/Bapositive

Capra falconeri

Markhor

I/Aa

Cervus elaphus
bactrianus

Bukhara Deer

II/B

b

Eryx tataricus

Tartary Sand
Boa

II/B

Ovis vignei
bochariensis

Bukhara Urial

II/B

Testudohorsfieldii

Horsfield’s
Tortoise

II/B

Hunting trophies (negative
opinion formed in 2010,
turned into a suspension
in 2012)Wild specimens(since 2008)
Hunting trophies(negative opinion formed
in 2006, turned into asuspension in 2007)
All wild specimens(negative opinion formed
in 2002, turned into asuspension in 2004)

positiveb

positive

Since 2012
All wild specimens(negative opinion formed
in 2006, turned into asuspension in 2008)
Wild and ranchedspecimens(since 2010)

Source: UNEP‐WCMC EU Wildlife Trade Regulation database (accessed 25 September 2013)*a, b = suspensions introduced on the basis of concerns relating to the conservation status of the species (“a” relates toAnnex A‐listed species, “b” relates to Annex B‐listed species).
**Positive Opinion formed at the 60th meeting of the SRG on 7 June 2012 and will become effective once this species‐
country combination is removed from Commission Implementing Regulation (EU) No 757/2012 of 20 August 2012
suspending the introduction into the Union of specimens of certain species of wild fauna and flora (the Suspensions
Regulation).

Further information about EU stricter measures (such as on stricter housing and transport conditions
or regulation of internal trade in Annex A‐listed species) is available at:
http://ec.europa.eu/environment/cites/pdf/differences_b_eu_and_cites.pdf
http://ec.europa.eu/environment/cites/home_en.htm, or directly from the CITES Team at theEuropean Commission, Environment Directorate‐General env‐cites@ec.europa.eu

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries81

ANNEX III
CITES export quotas for 2013*
Species
Kazakstan
Falco cherrug
Kyrgyzstan
Falco cherrug
RussiaFalco cherrug
Uzbekistan
Accipiter badius
Accipiter gentilis
Accipiter nisus
Asio flammeus
Asio otus
Athene noctua
Cervus elaphus
Eryx miliaris
Eryx tataricus
Falco cherrug
Falco columbarius
Falco subbuteo
Falco tinnunculus
Milvus migransOtus brucei
Otus scops
Ovis vignei
Pseudoscaphirhynchus kaufmanni
Strix aluco
Testudo horsfieldii
Testudo horsfieldii

Common name

Quota

Type of specimen

Saker Falcon

0**Live, wild‐taken

Saker Falcon

0**

Saker Falcon

0**

ShikraGoshawk
Sparrowhawk
Short‐eared Owl
Long‐eared Owl
Little Owl
Bukhara Deer
Desert Sand Boa

100
150
80
30
40
200
3
50
500
0**
20
50
50
20
200
200
5
20
24
45 00045 000

Tartary Sand Boa

Saker Falcon
MerlinEurasian Hobby
Common Kestrel
Black Kite
Pallid Scops Owl
Eurasian Scops Owl
Urial
Large Shovelnose Sturgeon
Tawny Owl
Horsfield’s Tortoise
Horsfield’s Tortoise

Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Trophies: horn and skull, skin
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Live, wild‐taken
Trophies: horn and skull, skin
Live, wild‐taken
Live, wild‐taken
Live, ranched
Live, wild‐taken

Source: UNEP‐WCMC EU Wildlife Trade Regulation database (accessed 20 September 2013).
*Note that all export quotas published for Acipenseriformes spp. for 2013 for Kazakhstan and Russia were zero as no
quotas were communicated to the CITES Secretariat. Also note that an import suspension is in place for Huso huso forboth countries.
** Quota resulting from recommendations of the Animals Committee, Plants Committee and the Standing Committee.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries82

ANNEX IV
Notable differences in numbers of live birds reported as (re‐)exported by the target countries,
according to exporters’ and importers’ reports (2000‐2010)
Year

Taxa
(family)

2000
2002

Falconidae
Falconidae

2003

Falconidae

2004
2005
2008
2009
KZ
SA
2003
2004
Russian Federation
RU
UZ
2002

Falconidae
OtidaeFalconidae
Falconidae
Falconidae
Falconidae

2003
2009

Falconidae
Psittacidae

2007

Psittacidae

2001

Falconidae

Exp.

Imp.

Kazakhstan
KZ
AE

RU
US
Uzbekistan
UZ
AE

Falconidae

SourceImp.
reported
quantityExp.
reported
quantity

Captive‐bred
Captive‐bred

9
126

49
0

Captive‐bred

111

83

Captive‐bred
Wild
Captive‐bred
Captive‐bred
Mostly wild
Mostly wild

99
50
110
88
31
30

0
0
220
0
0
0

Falco cherrug, Falco
rusticolus
Falco spp.
Mostly Platycercus spp. andPsephotus spp.

Captive‐bred

101

60

Captive‐bred
Wild

34
288

60
0

Various species

Wild

243

2

Species

Falco cherrug
Various (F. cherrug, F.
rusticolus, F. hybrid)
Various (F. cherrug, F.
rusticolus, F. hybrid)
Falco cherrug
Chlamydotis undulata
Falco cherrug
Falco cherrug
Falco cherrug
Falco cherrug

Falco cherrug (also F.
Captive‐bred
069
rusticolus and F. hybrid)
2002
Falconidae
Various species
Captive‐bred
111
188
2003
Falconidae
Falco cherrug (also F.
Captive‐bred
128
7
rusticolus and F. hybrid)
2004
Falconidae
Mostly Falco spp.
Captive‐bred
10
130
2005
Falconidae
Falco spp.
Captive‐bred
0
140
2006
Falconidae
Falco spp.
Captive‐bred
0
131
2007
Falconidae
Falco spp.
Captive‐bred
0
363
2008
Falconidae
Falco spp.
Captive‐bred
0
194
2009
Falconidae
Falco spp.
Captive‐bred
0
320
2010
Falconidae
Falco spp.
Captive‐bred
0
301
UZ
RU
2004
Psittacidae
Mostly Agarpornis spp.
Captive‐bred
0
516
2005
Psittacidae
Mostly Agarpornis spp.
Captive‐bred
0
1276
2006
Psittacidae
Agarpornis personatus
Captive‐bred
0
150
2007
Psittacidae
Mostly Psittacula krameri
Captive‐bred
0641
and Psittacus erithacus
2008
Psittacidae
Psittacus erithacus
Captive‐bred
0
120
2009
Psittacidae
Psittacula spp. and Psittacus
Captive‐bred
01020
erithacus
Source: CITES trade statistics derived from the CITES Trade Database, UNEP‐WCMC, Cambridge, UK.
Abbreviations: AE – United Arab Emirates, BY – Belarus, KZ – Kazakhstan, KG – Kyrgyzstan, RU – Russian Federation, SA –Saudi Arabia TJ – Tajikistan, US – United States of America, UZ – Uzbekistan.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

83ANNEX V
Overview of national CITES/wildlife trade legislation in the target countries

Belarus
Title of legislation
Order of the cabinet of ministers of Republic of Belarus No. 350 ofJuly 3, 1995 on measures to ensure Belarus’ compliance with the
obligations under CITES (amending Decree of the council ofministers of Republic of Belarus No. 664 of 29 April 1998)
Order of the council of ministers of the Republic of Belarus of 3
July 1995 No. 350

Decree of the council of ministers of the Republic of Belarus of 23
September 2008 No. 1397
Law of 10 July 2007 No. 257‐3 on wildlife

Decree of the council of ministers of the Republic of Belarus of 30
January 2008 No. 126

Joint Decree of the Ministry of Natural Resources andEnvironmental Protection of the Republic of Belarus, Ministry ofAgriculture and Food of the Republic of Belarus, Ministry of
Housing and Utilities and the Ministry of Cultural Affairs of the
Republic of Belarus of 23 February 2005 No. 7/10/4/5
Administrative Offences Code of the Republic of Belarus of 21
April 2003 No. 194‐Z,- Article 15.32-

Details- Ratification of CITES- Designates CITES MA and SA- Outlines procedure and terms
for export and import of CITES
specimens and issuing CITES
documents- Outlines new procedure andterms for issuing CITES
documents- Prescribes mandatory
registration of live animals –for all CITES‐listed species
kept and/or bred in captivity- Lays down detailed rules forthe registration of live CITES
species kept and/or bred in
captivity- Defines the procedure for
confiscation and temporary
keeping of live wild animals
species listed on CITES- Provides sanctions foroffences of the laws
concerning wildlife use andprotection

Article 15.33

Decree of the President of 26 July 2012 No. 332 on certain
measures of improvement of control in the Republic of Belarus
and subordinated acts

- Provides sanctions for illegal
import or export of wild
animals and plants to or fromthe territory of Belarus- Provides for enforcement
powers both during bordercontrols and controls inside
the country (e.g. checks atshops)

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

84

Overview of national CITES/wildlife trade legislation in Kazakhstan
Title of legislation
Law of 6 April 1999 No. 372‐1 on theaccession of Republic of Kazakhstan to
the CITES
Government Decree of 31 May 2012 No.
705 on rules of issuing by theadministrative body of permits forimport to the Republic of Kazakhstan
and export from the country of theendangered species of animals, theirparts and derivatives
State Law of 25 January 2012 on thechanges and additions to certain
legislative enactments of the Republic of
Kazakhstan regarding forestry, wildlife
and conservation areas
Decree No. 57‐r of 20 March 2012 on
measures for implementing State Law of
25 January 2012

Details- Ratification of CITES- CITES implementing regulation- Provides rules for the conservation of native species- Implementing regulation- Also contains a list of subordinated legislative andregulatory enactments to be amended or reissued
after revision
Administrative Code- No specific provisions for wildlife trade- Article 298- It sets sanctions for violation of hunting rules andrules of using wildlife. The fines range from approx.
USD56 for natural persons to USD1130 for legal
persons, at the time of writing. (The basis of
calculation of the penalty is the so‐called “monthly
calculated index”25.)
Criminal Code
- It sets sanctions for the illegal hunting, purchasing,- Article 290
keeping, selling, import, export, sending, shipping, as
well as killing of rare and endangered species of wild
flora and fauna, including for their parts andderivatives. Sanctions include imprisonment for theperiod of up to three years; confiscation of theproperty of convicted person and the property, whichis the object of the criminal activity, crime instrument
or facility.
Kazakhstan is in the process of enacting several pieces of new national legislation as a result of theestablishment of the ECU. The process has been somewhat delayed due to structural reorganization(of the environmental protection bodies and transferring the Forestry and Hunting Committee from
the Ministry of Agriculture to the Ministry of Environmental Protection). The list of regulations to be
adopted has been approved by the Prime Minister, as follows:- Decree on approval of the list of derivatives- Decree on approval of the rules of animal management in captivity or semi‐free conditions- Decree on approval of the rules of accounting and registration of hunting birds- Decree on approval of the rules of animals’ introduction and re‐introduction

25

Monthly calculated index is the sum used to calculate penalties. At the time of writing the monthly
calculated index is KZT1731 (approx. USD11).

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

85Title of legislation

Details- Decree on approval of the rules of issuing permits by the administrative body for import to the
Republic of Kazakhstan and export from the country of the endangered species of animals, theirparts and derivatives- Decree on approval of the rules of issuing permits by the administrative body for import to the
Republic of Kazakhstan and export from the country of the endangered species of plants, theirparts and derivatives- Order of the CITES Management Authority on approval of the rules of administration of the Red
Data Book of the Republic of Kazakhstan- Order of the CITES Management Authority on approval of the rules of issuing permits for import to
the Republic of Kazakhstan and export from the country of the endangered species of animals, theirparts and derivatives- Rules of issuing permits for export, import and transit of the moved (transported) specimens taking
into account the epizootic26 situation at the relevant territory

Overview of national CITES/wildlife trade legislation in Kyrgyzstan
Title of legislation- Law of 30 November 2006, No. 192 on
joining of the Kyrgyz Republic to CITES
signed March 3, 1973 in Washington- Law of 123.05.1999 “On Wildlife” (rev.
24.06.2003)- Administrative Offences Code of 4 April
199, No. 115
Article 147 on ‘Import or export of floraand fauna objects without a permit’

Details- Ratification of CITES- The basic law on wildlife protection- It prohibits the ‘import of wildlife specimens, which
can damage natural biotic communities’ and the‘import and export of wildlife specimens, theirproducts and parts in violation of legislativerequirements of the Kyrgyz Republic’- It provides the legal framework for prevention ofillegal trade in wildlife, including CITES specimens- It sets sanctions- (The basis of calculation of the fine is the so‐called“monthly calculated index” 27.)

26

a disease that appears as new cases in a given animal population, during a given period, at a rate that
substantially exceeds what is "expected" based on recent experience (i.e. a sharp elevation in the incidencerate) (http://en.wikipedia.org/wiki/Epizootic, 12 Sept 2013).
27
Calculation index – a conventional basic sum used for calculations of penalties. At the time of writing, thecalculation index in Kyrgyzstan was 100 soms or USD2.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

86Title of legislation

Details- Decree of the Government of 09 March
2011, No. 101 on the authorization
documents issued by the Government
Agency of Environmental Protection andForestry affiliated to the Government of
the Kyrgyz Republic- Article 3.1. ‘Procedure of issuing
permits for export from the
Kyrgyz Republic, import to the
Kyrgyz Republic and re‐export ofanimals and plants, their parts orderivatives subject to the CITES”- Criminal Code (No.68 of 1 Oct 1997)- Outlines the procedure and the terms for issuing
permits- It sets out that CITES documents for import, export
and re‐export of wildlife specimens are issued upon
the positive opinion of the SA (except for circuses,
transportation of hunting trophies and fish
taxidermies, museum and exhibitions and personal
effects). The MA is required to consult the CITES
Secretariat, and the importing or the exporting
country, if necessary.
- All live animals intended for export must be marked
in accordance with the CITES requirements.
- It does not provide for separate responsibility for
illegal import or export of wildlife objects.

Overview of national CITES/wildlife trade legislation in Russia
Title of legislation- Federal Law of 24 April 1995 No. 52‐FZ on Wildlife- Criminal Code of the Russian Federation of 13 June 1996
No. 63‐FZ (edition of 23 July 2013 with amendments
coming into force on 1 Sept 2013)- Code on Administrative Violations (Administrative Code)of the Russian Federation- Government Decree of 26 Sept 2005 No. 584 on measures
for the implementation of obligations of the RussianFederation under CITES, concerning species of sturgeon- Government Decree of 4 May 2008 No. 337 on measures
for the implementation of obligations of the RussianFederation under CITES, concerning endangered speciesof wild fauna and flora, excluding species of sturgeon

Details- It sets the rules regarding theconservation of rare andendangered species of animals(article 24).
- It sets criminal sanctions for theillegal harvest and trade in wildlife
listed in the Red Data Book of Russia
and/or protected by international
agreements to which Russia is a
Party (articles 258.1 and 226.1).
- Article 16.3 sets the sanctions fornon‐compliance with theprohibitions or restrictions onimport of commodities into the ECU
or Russia and export of commodities
from the ECU or Russia.
- It provides detailed rules regarding
trade in sturgeons.
- It provides detailed rules regarding
trade in CITES‐listed species, withthe exception of sturgeons.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

87Title of legislation

Details- Decree of the Ministry of Natural Resources andEnvironment of 27 Feb 2008 No. 47 on enforcing theAdministrative procedure for the Federal Supervisory
Natural Resources Management Service concerning theissuance of permits for export from the RussianFederation and for import into this territory of animals
and plants listed on CITES, concerning endangered speciesof wild fauna and flora, excluding species of sturgeon as
well as their parts and derivatives- Government Decree of 20 Nov 2008 No. 872 (revision ofGovernment Decree of 26 Jan 2012 No. 18) on approvalof the rules of supervision over persons, carrier vehicles,
cargos, goods and animals crossing State border of theRussian Federation.

- It provides detailed rules regarding
trade in CITES‐listed species, withthe exception of sturgeons.

- The decree defines specialized
checkpoints for sanitary, quarantine,
veterinary and phytosanitary typesof inspection (including CITES) at thestate borders of Russia.

Overview of national CITES/wildlife trade legislation in Tajikistan
Title of legislation
Law No. 760 of 2 August2010 on environmental
protection
Law No. 751 of 2 August
2011 on the licensing
systemCode of Administrative
Offenses
Article 205
Customs Code

Details- It is the basic environmental protection law- It lays down the general principles of the licensing and permit
issuing- It sets the sanctions for violation of import/export rules for wildlife- (The basis of calculation of the fine is the so‐called “monthly
calculated index”)- It prohibits the euthanasia of confiscated animals of endangered
species and the destruction of plants, their part or derivatives withthe exception of cases when they can be a source of diseases

Overview of national CITES/wildlife trade legislation in Uzbekistan
Title of legislation

Details

Decree of the Supreme Council‐Parliament of 25
April 1997 No. 433‐1
Decree of the Cabinet of the Ministers of 28 Oct
2004 on enforcement of a control on sustainable
use of biological resources and on the export
and import in the Republic of Uzbekistan- CITES ratification- Designation of national CITES authorities- Confirms competencies of designated national
CITES authorities

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

88Title of legislation
Rules of import/export of goods through theborders of the Republic of Uzbekistan

Customs Code
Code of Administrative Responsibility- Article 92 on violation of the rules ofanimal habitats, the rules of creating
zoological and botanical collections andtrading them, as well as unauthorized
migration, acclimatization or animal
crossing- Article 93 ‐ The smuggling of animals orplants detrimental to the conservationof species of animals and plants listedon the Red Data Book
Decision of the Cabinet of Ministers No. 508 of
28 Oct 2004 on strengthening the control overthe management of biological resources, importand export of them to and from the Republic of
Uzbekistan
Ordinance of the Cabinet of Ministers No. 76‐p
of 19 February 1996, on restriction of importand export of the birds of prey
Resolution of the Cabinet of Ministers No. 276
of 20 Dec 2008 on measures to improve theefficiency of breeding Houbara Bustard in the
territory of the Republic of Uzbekistan

Details- Customs declaration is based on these rules- It provides the Customs declaration form forwildlife in trade (including parts, derivatives
and products)- It also sets the standard for duty‐free individual
import/export to/from Uzbekistan, which also
concern some CITES products such as caviar
and clothes made of furs
- Contains no specific references to CITES- Fines are calculated based on the minimum
wage- These provide “regulations on the use, importand export of flora to and from the Republic of
Uzbekistan" and "regulations on the use,
import and export of wildlife from the Republicof Uzbekistan and the management of hunting
and fishing- Specific regulation on birds of prey

- Specific regulation on breeding Houbara
Bustard in captivity

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

89

ANNEX VI
The list of captive breeding facilities registered in Uzbekistan
Date ofregistration /Registration No.

List of species bred in captivity

November 9, 2005 Appendix I: Cacatua moluccensis, Cacatua sulphurea, Cacatua galerita aruensis,
No. 000005
Cacatua galerita triton, Probosciger aterrimus, Cacatua goffini, Cacatua
tenuirostris, Amazona leucocephala, Anodorhynchus spp., Aratinga guarouba(Date ofestablishment:
Appendix II: Psittaciformes spp. Plyctolophus galeritus, Plyctolophus albus,
1980)
Cacatua sanguinea, Amazona amazonica, Amazona ochrocephala, Amazonaxanthops, Amazona aextiva, Amazona arausiaca, Psittacula erithacus, Psittacula
eupatria, Psittacula cyanocephala, Psittacula krameri, Electus roratus, Lorius
garrulous, Trichoglossus haematobus, Platycercus eximius, Platycercus elegans,
Tanygnathus sumatranus , Touit dilectissima, Nandayus nenday, Alisterus
scapularis, Pionopsitta barrabandi, Eos histrio, Platycercus flaveolus, Platycercus
adscitus, Deroptyus accipitrinus, Tauraco spp., Ramphastos tucanus
4 August 2005
No. 000004

Appendix I: Cacatua moluccensis, Cacatua sulphurea, Cacatua goffini, Amazona
leucocephala, Cacatua roseicapitta, Ara macao.
Appendix II: Psittacula erithacus, Alisterus scapularis, Touit dilectissima,
Psittacula eupatria, Psittacula cyanocephala, Electus roratus, Pionopsitta
barrabandi, Barnardius barnardi, Platycercus elegans, Platycercus adscitus,
Neophema sptendida, Neophema bourki, Neophema pulchella, Cyanoramphus
novaezelandiae, Psittacus erithacus.

14 November
Appendix I: Cacatua moluccensis, Cacatua sulphurea, Cacatua alba, Probosciger
2005 No. 000007 aterrimus, Cacatua goffini, Cacatua roseicapitta, Amazona versicolor, Amazonabarbadensis, Ara macao, Ara ararauna, Cyanopsitta spixii, Lophophorus spp.,
Pavo muticus, Saguinus spp.
Appendix II: Electus roratus, Psittacula eupatria, Alisterus scapularis, Psittaculacyanocephala, Psittacula erithacus, Psittacus erithacus, Lorius garrulous, Eosbornea, Trichoglossus haematodus, Prioniturus montanus, Pyrrhura rupicola,
Psittacula Alexsandri fasciata, Platyctrcus adscitus, Platyctrcus elegans,
Platyctrcus venustus, Nandayus nenday, Amazona amazonica, Gruidae spp.,
Cercopithecidae spp., Macaca spp.
18 July 2007
No. 000014

Appendix I: Chlamydotis undulata macquinii28

6 September 2007 Appendix I: Chlamydotis undulata macquinii29
No. 000018
Source: CITES MA of Uzbekistan, April 2013
28
29

This taxon is listed as Chlamydotis macqueenii under CITES.
Same as above.

Wildlife trade in the Eurasian Customs Union and in selected Central Asian countries

90

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