TRAFFIC GOING DUTCH
R E P O R T

NOVEMBER 2016

An analysis of the import of live animals fromIndonesia by the Netherlands

Jordi Janssen and Lisa J. Blanken

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

1

TRAFFIC REPORTTRAFFIC, the wild­life trade monitoringnet­work, is the leading non-governmentalorganization working globally on trade inwild animals and plants in the context of bothbiodiversity conservation and sustainable
development. TRAFFIC is a strategic alliance ofWWF and IUCN.
Reprod­uction of material appearing in thisreport requires written­permission fromthe publisher.
The designations of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of TRAFFIC
or its supporting o­ rganizations con­cern­ing
the legal status of any country, territory, or
area, or of its authorities, or concerning thedelimitation of its frontiers or boundaries.
The views of the authors expressed in thispublication are those of the writers and do notnecessarily reflect those of TRAFFIC,
WWF or IUCN.
Published by TRAFFIC.
Southeast Asia Regional Office
Unit 3-2, 1st Floor, Jalan SS23/11
Taman SEA, 47400 Petaling Jaya
Selangor, Malaysia
Telephone : (603) 7880 3940
Fax : (603) 7882 0171
Copyright of material published in this report
is vested in TRAFFIC.
© TRAFFIC 2016.
ISBN no: 978-983-3393-67-1
UK Registered Charity No. 1076722.
Suggested citation: Janssen, J. and Blanken,
L.J. (2016). Going Dutch: An analysis of theimport of live animals from Indonesia by
the Netherlands. TRAFFIC, Southeast Asia
Regional Office, Petaling Jaya, Selangor,
Malaysia.
Front cover photograph: Soft corals
Dendronephthya sp. thrive on a reef in Raja
Ampat, Indonesia.
Credit: © Ethan Daniels/Dreamstime.com

GOING DUTCH

An analysis of the import of live animals fromIndonesia by the Netherlands© Ethan Daniels/Dreamstime.com

Jordi Janssen and Lisa J.Blanken

Soft corals Dendronephthya sp. thrive on a reef in Raja Ampat, Indonesia.

© Robert Delfs/WWF

4 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

T A BLE O F CON T E N T S

List of Tables and Figuresiv
		
Acknowledgementsv
Executive Summaryvi

Introduction
1.1 The European Union
1.2 The Netherlands
1.3 Aim of the Study
1.4 Background: Legislation, Quota Setting andImport Restrictions
1.4.1 Indonesia
1.4.2 The European Union
1.4.3 The Netherlands

1
1
2
3

Methods
2.1 Seizure Data

6
7

Results and Discussion
3.1 Seized Animals
3.2 Inconsistent Quantities
3.3 Birds
3.4 Coral (Reported as No. of Specimens)
3.4.1 EU trade restrictions
3.5 Coral (Reported in Kilogrammes)
3.6 Fish
3.7 Mammals
3.8 Molluscs
3.9 Reptiles
3.9.1 Species not native to Indonesia
3.9.2 EU Trade restrictions
3.9.3 Reptile survey

8
10
12
13
13
17
17
19
22
22
24
25
26
29

Conclusions

36

Recommendations

37

References

39

3
3
4
5

TRAFFIC Report: Going
Dutch: An1
analysis of the import of live animals from Indonesia by the Netherlands
43
Appendix5

“547 947 CITES and EU Annex listed
live animals imported from Indonesia
by the Netherlands during 2003-2013”
PERCENTAGES OF ANIMALS TRADED FROM DIFFERENTGROUPS
1.02%

Fish

Mammals

0.03%

ReptilesMolluscs

0.28%

0.69%

DISCREPANCIES IN NUMBERS REPORTED BETWEENINDONESIA (ID) AND THE NETHERLANDS (NL)ID
157
NL 100ID

Mammals

Birds

Birds

98.02%

Coral(specimens)

ID
NL<0.00%

8810
740

Molluscs

ID
NL

2325
4 066

Fish

ID
NL

3 442
1 672

Reptiles

432 346296 980ID
NL

INDONESIAN REPTILES SOLD IN THE NETHERLANDS
Coral(specimens)

1 Fair: Snake Day (11 October 2015)

ID
NL

303 specimens
32 species
14 CITES listed (Appendix II)
18 Non-CITES listed

Coral(kilogrammes)

17 57140 438DOCUMENTED TRANSACTIONS IN Hydnophora microconos
DESPITE EU TRADE RESTRICTION

SwedenHydnophora microconos (wild-sourced specimens)
EU Negative opinion: 22 May 2003
EU Trade suspension: 10 May 2006

UNEP-WCMC CITES Trade Database
FranceHungary

COUNTRIES OF ORIGIN OF THE DIFFERENT VENDORS

Czech RepublicHungary

Denmark

Netherlands

FranceSwedenGermany

Trade reported by both Indonesia and Netherlands:
25
specimens

19
specimens

57
specimens

2004

2005

2006

iii TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands
United Kingdom

A TRAFFIC REPORT: Going Dutch: An analysis of the import of the live animals from Indonesia by the Netherlands

L IS T S O F T A BLE S A N D F I GUR E S
List of Tables
Table 1

Overview of trade in live animals, as reported in both individual specimens andkilogrammes of all orders and their corresponding sources.

Table 2

Overview of all seized live animals, both CITES listed and non-CITES listed, in the
Netherlands with Indonesia as origin.

Table 3

Number of live specimens of coral taxa (reported above species level) imported into theNetherlands from Indonesia and their reported source during the period 2003-2013.

Table 4

Imported fish species and their corresponding source in the period 2003-2013.

Table 5

Imported clam species and their corresponding source in the period 2003-2013.

Table 6

Imported reptile species and their corresponding source in the period 2003-2013.

Table 7

Observed reptile taxa at the annual Snake Day in Houten, the Netherlands in 2015.

Table 8

Number of live coral specimens imported into the Netherlands from Indonesia and theircorresponding source in the period 2003-2013.

List of Figures
Figure 1

Overview of the trade in live animals, both CITES and EU Annex listed, from Indonesia to
the Netherlands during the period 2003-2013.

Figure 2

Overview of the trade in live, both CITES listed and EU Annex listed, animals fromIndonesia to the Netherlands during 2003-2013.

Figure 3

Overview of the number of export quotas set for coral species versus the number of quotas
set for coral genera in Indonesia over the period 2003-2013.

Figure 4

Trade in Leafy Hedgehog Coral Echinopora lamellosa.

Figure 5

Trade of live coral, Scleractinia spp., from Indonesia into the Netherlands.

Figure 6

Trade in Common Seahorses Hippocampus kuda between Indonesia and the Netherlands.

Figure 7

Reportedly farmed Green Tree Python Morelia viridis (left) and wild-sourced Papuan
Python Apodora papuana (right) for sale by a German vendor at Snake Day (2015). ©
TRAFFIC

Figure 8

Green Tree Pythons Morelia viridis for sale by a Czech vendor during Snake Day (2015)
showing both adults and juveniles from various localities. © TRAFFIC

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

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ABBREVIATIONS AND ACRONYMS
BKSDA.....................................................Natural Resources Conservation Agency (Indonesia)
CITES.......................................................Convention on International Trade in Endangered Species ofWild Fauna and Flora
EC..............................................................European Commission
EU.............................................................European Union
IUCN........................................................International Union for Conservation of Nature
UNEP........................................................United Nations Environment Programme
WCMC......................................................World Conservation Monitoring Centre (referred to as 		
UNEP-WCMC)
NDF..........................................................Non-Detriment Finding
NVWA......................................................Netherlands Food and Consumer Product Safety Authority
PHKA.......................................................Directorate General of Forest Protection and Nature 		Conservation (Indonesia)
RVO.NL....................................................Netherlands Enterprise Agency
SRG...........................................................Scientific Review Group

ACKNOWLEDGEMENTS
The authors would like to thank Chris Shepherd, James Compton, Katalin Kecse-Nagy, Serene
Chng, Richard Thomas and Vicki Crook for their valuable feedback on previous versions of thisreport. Aqeela Abdul Jalil is thanked for the report layout and designing the infographics.
WWF-Netherlands is thanked for generously funding and supporting this study. The authors would
also like to thank the Zoo and Aquarium Association Australasia for supporting TRAFFIC's work in
Southeast Asia.

v TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

EXECUTIVE SUMMARY
Ongoing illegal and unsustainable trade in wildlife is an increasing threat to species conservationin Indonesia, a biodiversity hotspot in Southeast Asia, with possible irreversible effects on wild
populations. In particular, rare and newly identified species have a high commercial value and areincreasingly harvested for the international exotic pet trade. Large numbers of live animals, both
CITES listed and EU Annex listed, were imported from Indonesia by the Netherlands between 2003
and 2013. This report does not include trade on species not listed in CITES or the EU Annexes.
Reported trade in CITES-listed species between the two countries comprised 98% coral specimens
followed by fish (1.02%) and reptiles (0.69%). The total volume of trade between Indonesia and theNetherlands is likely a lot higher since e.g. fewer than 8% of reptiles are currently listed in the CITES
Appendices. This makes the Netherlands a major importer of Indonesian corals and to a lesser
extent of fish and reptiles. The majority of the species were native to Indonesia, except for a few
non-native reptile species originating from Africa. This report highlights several issues as observedin the trade data. Large discrepancies were observed between the quantities reported by Indonesia
and the Netherlands. For only 41 of 1146 records both countries reported the same quantities.
For 496 records, the Netherlands did not report any quantity, and 132 records had no reported
quantity by Indonesia. The large discrepancies mentioned in the report can be caused by differencesin reporting; such as permits issued versus actual trade. Other reasons for reported differences inquantities may be: discrepancies in reporting of source, purpose, terms and units, or permits may
be issued at the end of one year and arrive in the import country in the following year. However, apossibility that cannot be excluded is that no permits were issued for the 132 cases with no recorded
quantity in export documentation.
The UNEP-WCMC CITES Trade Database indicated trade in five wild-sourced reptile species and
14 coral species between the two countries, despite European Union (EU) trade suspensions or
negative opinions being in place. However, for almost all species quantities were only reported byIndonesia, making it likely these originate from permits issued and not actual trade. Nevertheless,commercial trade in wild-sourced specimens was reported by both Indonesia and the Netherlands
for the coral species Hydnophora microconos despite an EU negative opinion being in place at thetime. Further efforts are therefore required by the Dutch authorities to ensure that in the future all
EU import restrictions are fully complied with. In addition, this report shows that trade suspensions
can lead to a sudden increase in trade of captive-bred specimens like that demonstrated for the
trade in Common Seahorse. A sudden switch to captive-bred specimens raises questions about
the legality of the reported source and if the specimens are potentially fraudulently declared assuch. Even though signs are positive that for several species groups (e.g. molluscs and fish) animals
reported as captive-bred or farmed are indeed originating from breeding facilities, the significant
trade in taxa like coral and reptile species, for which laundering has been well documented, suggestthat some of the wildlife imported into the Netherlands could be fraudulently declared as captivebred or captive-born.
The EU single market makes it easy to transport wildlife between EU countries with virtually no
documentation. Therefore the true quantities and species imported and traded in the Netherlands
are likely to be higher and some species imported into the Netherlands are destined for other EU
Member States. This has also been found through surveys of the annual Snake Day in Houten where
the trade in Indonesian species by vendors from eight different EU countries was documented.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the NetherlandsviIn light of the above, the following recommendations have been made:To ensure that trade in live animal species is not occurring to the detriment of wild populations inIndonesia, the Government of Indonesia should:• Increase transparency of the process under which the government conducts Non-Detriment
Findings in order to evaluate issued harvest and trade quotas for CITES-listed species;• The CITES Management Authority of Indonesia should take into account the viable production
capacity and economic viability of any commercial captive breeding/mariculture facility whenauthorizing their operations and should continuously monitor and inspect their operations in orderto prevent laundering of wildlife;• Initiate regular dialogue with the European Commission and individual EU Member States toprevent, discuss or lift trade suspensions and negative opinions;• Ensure that exported quantities do not exceed the quantities for which permits have been granted;• Improve compliance with the CITES requirements regarding the documentation of trade in coral
species, both for specimens and trade in kilogrammes, and should not issue export permits fortaxonomic levels for which trade has not been found appropriate by CITES as mentioned in CITES
Notification No. 2003/020 and 2013/035;
To ensure fraudulently exported wild-sourced specimens are not imported into the Netherlands andinto the EU common market, and to ensure that the import of live animal species from Indonesia is not
detrimental to the survival of wild populations the Government of the Netherlands and the European
Commission should consider the following priorities:
•

•
•
•
•

•

•

The CITES Scientific Authorities of the Netherlands/ European Commission should take steps totake into consideration scientific evidence regarding possible false declarations of captive breeding
before issuing import permits. Systematic requests for detailed information should be made toexporting countries on captive breeding facilities (including for captive-born specimens) and steps
taken to monitor breeding facilities to prevent laundering of wild specimens.
The Netherlands should take steps to record coral trade more accurately, and consider refusing
imports which are incorrectly documented, i.e. with trade terms LIV instead of COR;
The European Commission and the Netherlands should consider refusing the imports of species forwhich quotas have been set at genus or higher taxonomic level, unless the use of higher taxonomic
levels is accepted by the CITES Parties (e.g. CITES Notification No. 2003/020 and 2013/035).
The scale of trade in certain taxa, such as corals and reptiles, should be recognized and EU law
enforcement efforts should be enhanced to respond more effectively to fraudulent and illegal
imports at EU points of entry;
The enforcement authorities of the Netherlands, in particular the Netherlands Food and Consumer
Product Safety Authority (NVWA), should increase regulatory vigilance over commercial events(e.g. reptile trade fairs) that bring together vendors/buyers from various EU Member States in orderto prevent the import of species into the Netherlands for which trade restrictions are in place, but
likely entered the EU via other Member States (possibly those with weaker enforcement capacities);
To ensure a co-ordinated response to illegal and unsustainable trade, EU Member Statesshould pursue a more consistent law enforcement effort across the EU, guided by the effective
implementation of the EU Action Plan against Wildlife Trafficking. This could include exchange
of information obtained by regular monitoring of key EU wildlife fairs and markets (physical andonline), which could provide early warnings for emerging trends and potential illegal trade;
The European Commission should consider improving co-operation on a scientific and/or
enforcement level between Indonesia and the EU (including the Netherlands) for example throughinviting representatives of the Indonesian Government to the Scientific Review Group (SRG). Suchco-operation could include study exchanges, exchange of scientific information and underlying
methodologies or joint enforcement operations that target Indonesian wildlife traded onto the EU
consumer market.

vii TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

INTRODUCTION
Unsustainable trade is increasingly seen as a major threat to the conservation of species in Southeast
Asia, driven by global consumer demand for pets, traditional medicine, luxury items and food(Lenzen et al., 2012; McNeely et al., 2009; Nijman, 2010; Sodhi et al., 2004; Zhou et al, 2004). With
its archipelagic geography and high biodiversity level, Indonesia is one of the largest sources ofwildlife traded from Southeast Asia (Iskandar et al. 2006; Nijman et al., 2009). Ongoing illegal
and unsustainable harvest threatens the survival of populations of many different species groups(Gibbons et al., 2000; Natusch et al., 2012; Shepherd et al., 2005, Shepherd, 2010; van Balen et al.,
2000; Yuwono et al., 1998). Indonesia has been identified as the most significant exporting countryof wild-sourced specimens of reptiles and corals in Southeast Asia between 1998 and 2007 (Nijman,2010). The laundering of wild-sourced specimens fraudulently declared as captive-bred reportedly
occurs on a large scale (Nijman et al., 2009; Nijman et al., 2015) and potentially can have a grave
impact on wild populations in Indonesia (Natusch et al., 2012).
One of the driving forces of wildlife trade in Indonesia is the exotic pet trade (Natusch et al., 2012;
UNEP-WCMC 2007; Yuwono et al., 1998). It has been confirmed that in particular rare and newly
identified species have a high commercial value and are increasingly traded internationally. These
specific taxa attract specialist collectors, fuelling commercial exploitation, which can lead to species
extinction (Nijman et al., 2014; Shepherd et al., 2005; Stuart et al., 2006; Theile et al., 2004; Vinke etal., 2015). Reptiles are possibly the most intensively harvested terrestrial fauna that are sourced ingreat volumes both legally and illegally (Sodhi et al., 2004; Soehartono, 2002; Nijman, 2010; Nijman
et al., 2012), with more reptile species traded for the live pet trade than for any other consumer
market (Nijman et al., 2009). Besides terrestrial species, Indonesian aquatic species are also tradedin large volumes to meet the demand of the marine aquarium industry. Since the Philippines has
prohibited the export of live corals, Indonesia has become the most significant exporting country(Raymakers, 2001; UNEP-WCMC, 2014b).
Indonesia became a Party to the Convention on International Trade in Endangered Species ofWild Fauna and Flora (CITES) in 1979. CITES regulates the international trade in wildlife throughthe listing of species in three Appendices subject to different degrees of regulation. Commercial
international trade in species listed in Appendix I is generally prohibited, except when it concerns
animals bred at registered breeding facilities (source code 'D'). It is possible to commercially trade
species listed in Appendix II and III if certain conditions are met and relevant CITES documents
are obtained.. The government of Indonesia has therefore adopted an extensive quota system forboth harvest and export (Nijman et al., 2012; Vinke et al., 2015). These quotas are also establishedfor non-CITES listed species. Despite these extensive legal instruments, illegal trade and a lack ofenforcement has repeatedly been observed and documented (Natusch et al., 2012, Nijman et al.,2012; Shepherd et al., 2005; Siswomartono, 1998; van Balen et al., 2000). Indonesia is a range State
that is closely monitored by the EU to identify possible trade irregularities (Engler et al., 2007).
Because of concerns regarding the trade volumes and sustainability of the trade the European Union(EU) has suspended the trade in numerous Indonesian species, in particular reptile species (Engler
et al., 2007; UNEP-WCMC, 2007; UNEP, 2016).

1.1 The European Union

The EU is one of the largest and most diverse destination markets for wildlife (Auliya, 2003; Engler
et al., 2007; Theile et al., 2004), with an estimated import value of CITES-listed animal species of
EUR582 million in 2013, excluding the trade between EU Member States (UNEP-WCMC, 2015b).
CITES is implemented in the EU by the so-called EU Wildlife Trade Regulations, which include
Council Regulation (EC) No. 338/97 and Commission Regulation (EC) No. 865/2006 (European
Commission et al., 2015). According to a detailed analysis of the EU and candidate countries trade

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

1

in wildlife covered by the EU Wildlife Trade Regulations in 2013, skins and live animals were themost important animal and animal products imported into the EU in terms of volumes (UNEPWCMC, 2015b). Corals, reptiles and leeches dominated the live animal imports into the EU which
accounted for EUR5.7 million in 2013. In addition wildlife is also illegally imported into the EU,with birds and reptiles amongst the species that are most commonly seized (Pieters, 2016). In 2013
the majority of the specimens imported into the EU were either wild-sourced (54%) or of captive
sources (43%)1 (UNEP-WCMC, 2015b). Because of the common European market and fewer
controls with regard to wildlife trade within the EU, it is difficult to quantify the actual size of theinternal EU wildlife trade. In addition, uneven enforcement and implementation of the EU Wildlife
Trade Regulation across EU Member States provide opportunities for offenders to import specimens
through Member States with less stringent border controls (European Commission, 2015). Once a
specimen has entered the EU it becomes very difficult to regulate trade. Particularly in certain EU
countries such as Germany, the Netherlands, the United Kingdom and the Czech Republic, there isa high demand and collector interest for live animals intended for the exotic pet trade (Auliya, 2003;
Engler et al., 2007; Milieu Ltd et al., 2006). Wildlife traders in these EU Member States often try toimport and breed rare species after which they are sold with high profits (Vinke et al., 2015). So far
little research has been done on the role of individual EU Member States in the legal and illegal live
animal trade (UNEP-WCMC, 2007).

1.2. The Netherlands

It has been acknowledged that within the EU, the Netherlands plays a key role in the wildlife trade,both as a destination market and as a transit country (Engler et al., 2007; UNEP-WCMC, 2007; van
Krevelt, 2007). The role that the Netherlands plays in the trade and trafficking of wildlife is partly
attributed to the Port of Rotterdam, the largest European harbour, and Schiphol airport, one of
the main European transit airports. As the bulk of the trade operates through ports, the logistical
position of the Netherlands makes it an attractive wildlife trade hub on an international scale(Government of the Netherlands, 2014; Pieters, 2016; van Uhm, 2009).
Although many species are traded in accordance with the EU Wildlife Trade Regulations, illegal
and unsustainable trade still takes place. The consumer market inside the Netherlands is diverse
with expanding markets and marketplaces. Private collectors are prone to be involved in the
trade in wildlife, in particular when dealing with the trade in live species (van Krevelt, 2007; vanUhm, 2009). Specialist wildlife fairs for exotic pets (e.g. reptiles, birds, and fish) regularly takeplace in the Netherlands, providing a market place for individuals trading in both legal and illegal
wildlife. These fairs also attract wildlife traders and specialist collectors from across the EU. As theEuropean market enables free movement of goods, it is relatively easy to take a specimen from one
EU Member State to another (Altherr, 2014). The sale of wildlife through the Internet is also an
increasing trend, both for the legal and illegal market (van Krevelt, 2007).
The scale of the trade is demonstrated through the amount of seizures that are made in the
Netherlands. The latest CITES biennial report of the Netherlands for 2013-2014 showed that a totalof 3908 import permits were issued. Over the same two-year period a total of 1634 seizures of bothanimal and plant species were reported. The majority of the seizures (40%) involved Traditional
Chinese Medicine, followed by birds (25%), plants (15%), reptiles (10%) and mammals (10%)(CITES 2015). Indonesia is connected regularly with important seizures in the Netherlands and is
one of the significant players with regard to the animal trade (CITES 2015). Yet, the true dynamics
of the trade relationship between the Netherlands and Indonesia had been poorly understood prior
to the compilation of the present report.

1

Includes species with CITES source code ‘A’; plants that are artificially propagated, source code ‘C’; animals bred in
captivity, source code ‘D’; Appendix I listed animals bred in captivity and source code ‘F’; animals born in captivity.

2 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

1.3. Aim of the study

The aim of this study was to gain insights into the import-export relationships between Indonesia
and the Netherlands by studying the trade in live animals from 2003 to 2013. The true dynamics
of the trade between both countries are relatively poorly understood. This report allows a better
understanding of the role of the Netherlands as an importing country, and Indonesia as an exporterof live animal species by providing an overview of trade dynamics. The results can be used to guide
future policy and regulatory interventions and highlight issues of concern. Within the scope of thisstudy, only trade in species listed in the CITES Appendices and EU Annexes has been analysed.
As several Indonesian species have been fraudulently documented as being captive-bred, while inreality were illegally obtained from the wild, this report will pay special attention to the source of thespecimens. In addition, the import figures are compared to their compliance with the Indonesian
export quotas and EU import restrictions. This report also pays special attention to species listed as
being threatened on the IUCN Red List of Threatened Species. Recommendations are formulated
and addressed to the Goverments and CITES Management Authorities of Indonesia and theNetherlands, and to the European Commission.

1.4. Background: Legislation, quota setting and import restrictions
1.4.1. Indonesia

Indonesia ratified CITES in December 1978, which entered into force in March 1979. The
implementation and enforcement of CITES regulations, including the compliance with theestablished export quotas2 is the responsibility of the appointed CITES Management Authority, theDirectorate General of Forest Protection and Nature Conservation (PHKA). On a provincial anddistrict level this implementation and enforcement is carried out through the regional offices of the
Natural Resources Conservation Agency (BKSDA). Hunters and traders must be registered throughthe BKSDA to be able to harvest species legally from the wild or to be entitled to export a specimen.
In addition a permit is needed in order to harvest or export wildlife. To be able to breed specimens
in captivity for export, the breeding facility must be registered with PHKA. Facilities that supply
captive-bred specimens but do not trade themselves are registered at the provincial level through the
BKSDA.
The import and export requirements are different for species that are captive-bred than forwild-sourced animals. Since it is argued that the trade in captive-bred specimens does not posea similar threat to the survival of wild populations as trade in specimens sourced from the wild,
CITES accommodates more lenient permit and certificate requirements for these specimens.
Hence the Indonesian Government actively encourages captive breeding as a way to prevent, intheory, overexploitation and to reduce the pressure on wild populations. According to Indonesian
Government regulation No. 8, 1999, second generation captive-bred offspring do not require quotas
and can therefore be commercially exported. The Indonesian Government regulates the numberof animals that can be bred in captivity for each registered facility. Trade in wild-sourced species
in Indonesia is regulated through an annual harvest and export quota system. Quotas for species
listed in Appendix II and III of CITES are set by the Indonesian Institute of Sciences (LIPI), theresponsible CITES Scientific Authority at the national level. Indonesia also establishes quotas for
species that are not CITES-listed.
For species that are fully protected under national legislation, no export quotas are establishedand commercial trade in these species is unlawful, unless it comprises animals bred in captivity.
Before quotas can be established, CITES protocols require that a non-detriment finding (NDF)
is made, where the CITES Scientific Authority has to advise if the export of the specimen is not
2
Quotas for wild-sourced and captive-bred specimen are set by the Government of Indonesia, as part of the nondetriment finding (NDF). Indonesia also sets quotas for non-CITES species.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

3detrimental to the survival of the species. All Indonesian quotas are established in dialogue
with various stakeholders, including licensed traders and hunters. The established quotas candistinguish between the types of the specimen traded (e.g. live or skins) and it is only permitted to
trade specimens within assigned quantities, use/type of specimen and from designated origins. In
Indonesia, around 10% of the harvest quota may be used for domestic trade.

1.4.1.1 Law Enforcement issues

Even though Indonesia has adequate national legislation in place, illegal and fraudulent trade is well
documented and persistent (Auliya, 2003; Nijman et al., 2009; Natusch et al., 2012; Nijman et al.,2012; Nijman et al., 2015; Siswomartono, 1998; Yuwono et al., 1998). Actual harvests sometimes
greatly exceed quota levels or quotas are reportedly established based on limited biologicalinformation (Iskandar et al., 2006; Nijman et al., 2012). As many of the Indonesian species collected
for the international trade originate from remote provinces such as West Papua and Papua, locatedon Western New Guinea, information on the reproduction and distribution of species is lacking. In
many cases quotas are reportedly not established on reliable NDFs but are rather based on quotas ofprevious years and information provided by exporters (Natusch et al., 2012; Nijman et al., 2012).
To avoid export quotas and to continue to supply the domestic and international markets, many
wild-sourced specimens are reportedly fraudulently declared as captive-bred and laundered in large
volumes (Lyons et al., 2011). Even though Indonesia is not the only country that actively supports
captive breeding to reduce pressure on wild populations, this system is complex and can be misused
as an effective laundering mechanism. Trade in species taken from the wild is far more profitable, as
no financial investments have to be made to breed and raise wild-sourced specimens. A recent study
on the commercial captive breeding of Tokay Geckos Gekko gecko found that the quantities reported
in trade cannot be sustained by the breeding facilities currently registered in Indonesia (Nijman etal., 2012, Nijman et al., 2015). So far no special techniques have been developed to distinguish easily
wild-sourced specimens from captive-bred specimens.

1.4.2 The European Union

On the European level wildlife trade is governed by the EU Wildlife Trade Regulations that jointly
implement the provisions of CITES (European Commission, 2015; European Commission et al.,2015). All Member States have ratified the Convention and the EU, as a regional entity, has recently
also acceded to CITES, which entered into force in July 2015. The scope of the EU Wildlife Trade
Regulations is more encompassing and stricter than CITES. However trade is not only defined by
the import, export or re-export of wildlife, but also by the movement or transport within the EU
and the possession thereof (European Commission et al., 2015). The EU Annexes (A, B and C)
largely correspond with the CITES Appendices although some species are listed in a higher Annex.
Annex B and C also include some non-CITES species. For example, Annex A also includes a few
species that are listed in CITES Appendix II and III. Species included in Annex D are imported
into the EU in volumes that warrant monitoring or concern species that can potentially constitutean ecological threat to indigenous European wildlife (European Commission, 2015; European
Commission et al., 2015).
Because implementation of the EU Wildlife Trade Regulations and external border control is the
responsibility of the individual Member States, weak national enforcement can seriously affectthe overall capacity of the EU to regulate wildlife trade (Engler et al., 2007; Theile et al., 2004). To
strengthen the EU policy against wildlife trafficking the EC launched a public consultation process
in 2014 on the EU approach against wildlife trafficking. Uneven and insufficient implementationand enforcement of the EU Wildlife Trade Regulations at the Member State level was identified asa major problem, further aggravated by low political will and insufficient awareness, among otherissues (European Commission, 2015). Recognizing its role as a wildlife trade hub and destination
market, the EC adopted a strategic and co-ordinated EU Action Plan against Wildlife Trafficking on

4 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

26 February 20163. The action plan focuses on three priority areas: increase enforcement throughcloser EU collaboration, more effective prevention through demand and supply reduction andstrengthening of co-operation with range States.

1.4.2.1 EU import restrictions

Through Article 4(6) of European Commission (EC) Regulation No. 338/97, the EU Wildlife
Trade Regulations also provides the European Commission with the legal authority to apply trade
restrictions to species that are a cause of concern to the Scientific Review Group (SRG). The SRG,
consisting of Scientific Authority representatives from each Member State, can give an advice on
import restrictions. Meeting three to four times a year, the SRG gives an opinion whether theimport of certain species from certain countries complies with the EU Wildlife Trade Regulations.
If one or more Member States are concerned that the trade in a species from a certain range Stateis detrimental to the species's survival, the SRG consults with the particular range State and gathers
information on the trade and conservation status of the species to be able to reassess the NDF
conducted. The Scientific Authorities of the range States also make an NDF before issuing an export
permit. If the information available is insufficient to ensure that the introduction into the EU would
not have a harmful effect on the conservation status of the species, the SRG forms a "negative
opinion". The SRG can also form an opinion for EU Annex B species that show a high mortality rateduring transportation or are unlikely to survive in captivity. As long as a negative opinion is in place
EU Member States cannot issue any import permits for this specific species-country combination.
These negative decisions are temporary and can be easily changed into a "positive opinion" once
the SRG has been assured that the survival of the species in the wild is no longer at risk. However, if
there is a continuous concern and the respective range State has not provided sufficient information
to prove otherwise, a trade suspension can be imposed, through the so-called "suspension
regulation". The trade suspension becomes effective once it is published in the official journal of the
EU. Lastly, if there are not sufficient data available to enable the SRG to form an opinion, the SRG
can decide to issue a "no opinion", implying that there is little or no actual or anticipated trade, orthat there are insufficient data available for a positive or negative opinion. In these cases, European
Management Authorities have to ask the national Scientific Authorities of the exporting country fora NDF before granting an import permit (European Commission et al., 2015).
Because of the large volumes being exported by Indonesia, the SRG has raised concerns regarding
the quota levels and sustainability of a number of species traded from Indonesia (UNEP-WCMC,
2007). Following limited scientific justification of export quotas, the EU has a number of negative
opinions and trade suspensions in place for animal species exported from Indonesia (Engler et al.,2007; UNEP-WCMC, 2007; UNEP 2016). At the time of writing, a total of 15 negative opinions
are in place for Indonesia, which ban the EU import of certain species of coral (12), insect (1) andreptile (2). The number of trade suspensions at the time of writing totals 39, suspending the importin certain Indonesian species of bird (1), coral (9), fish (7), insect (1), mammal (2) and reptile (19)
into the EU (UNEP, 2016).

1.4.3 The Netherlands

The actual implementation of the EU Wildlife Trade Regulations is the responsibility of theindividual Member States. The Netherlands ratified CITES in April 1984, and it entered into force
in July of the same year. Effective implementation is the responsibility of the CITES Management
Authority of the Netherlands, the Ministry of Economic Affairs. An import permit or certificate
of origin has to be acquired in order to import any CITES listed or EU Annex listed species into
the Netherlands. This is carried out by the executing agency of the CITES Management Authority,
the Netherlands Enterprise Agency (RVO.nl) (van Uhm, 2009; RVO, 2016). The CITES Scientific
Authority of the Netherlands is also positioned within the Ministry of Economic Affairs.
3

http://ec.europa.eu/environment/cites/trafficking_en.htm

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

5METHODS
Data on the trade in live animals from Indonesia and the Netherlands were retrieved from theUnited Nations Environment Programme-World Conservation Monitoring Centre (UNEP-WCMC)CITES Trade Database, publicly available at http://trade.cites.org. The UNEP-WCMC CITES
Trade Database contains records on the import, export and re-export of CITES listed species. The
database also contains records on the import of non-CITES species listed in EU Annexes C and/or
D. However, this is limited to the years when species are listed in these Annexes and only comprise
records of import into the EU. Information on quotas and CITES/EU suspensions, as well as EU
Annex listing and EU decisions were retrieved from the Species+ website, which can be accessed
through http://www.speciesplus.net/. Species+ has been developed by UNEP-WCMC and the
CITES Secretariat to centralize information on, amongst others, CITES and EU listings. This report
does not include trade in species which are not listed in the CITES Appendices or EU Annexes. The
total volume of trade between Indonesia and the Netherlands is likely to be a lot higher since e.g.
less than 8% of all reptiles are listed in CITES (Auliya et al., 2016).
This report focuses on the trade in live animals between Indonesia and the Netherlands from2003 to 2013, with Indonesia as the country of origin. Only records with a mentioned purpose ofcommercial trade (purpose code 'T') were included in the dataset. Trade records are required to
be annually submitted to the CITES Secretariat by the individual Parties which are then uploaded
to the UNEP-WCMC database. Both the importing (the Netherlands) and exporting (Indonesia)
country are required to report the trade quantities in their statistics. As large discrepancies wereobserved between the imported and exported mentioned quantities, the highest mentioned quantity
was used for analysis. By using the highest mentioned quantity the results of this report can beinterpreted as a "worst-case" scenario. This report relies on the data provided by the Parties to
CITES and therefore as available in the UNEP-WCMC CITES trade database and Species+ website(UNEP, 2016). Data from the UNEP-WCMC CITES trade database and Species+ were downloadedin August 2015.
This report uses CITES nomenclature, and therefore may not be consistent with the latest
taxonomic classification. Definitions used in this report follow the CITES definitions and English
common names are given where available. Some coral species are only described with a scientificname. Animals bred in captivity (source code 'C') refers to at least second generation offspring thatwere born in a controlled captive environment (in accordance with CITES Resolution Conf. 10.16
Rev.). Source code 'D' refers to Appendix I animals bred in captivity for commercial purposes atfacilities included in the CITES Secretariat’s Register in accordance with Resolution Conf. 12.10 (Rev.
Cop15). Animals born in captivity (source code 'F') refers to offspring of wild parents or subsequent
generation offspring that do not fulfil the CITES definition of "bred in captivity" in Resolution Conf.
10.16 (Rev.). Source code 'I' refers to confiscated or seized specimens. Wild-sourced animals (sourcecode 'W') refers to animals taken from the wild.
Besides analysis of the UNEP-WCMC CITES Trade Database, a survey was conducted at the annual
Snake Day of the European Snake Society in Houten, the Netherlands on 11 October 2015. This is
the largest snake-only reptile show in the world, held annually in the Netherlands. This particularshow was chosen for a survey since it was held during the study period and was limited to only one
species group. This limited the number of Indonesian species potentially present at the show to
only one group and therefore increased the chance of identifying Indonesian species compared to ashow with all species groups present. During this survey all available Indonesian species, the source,
locality and price were documented whenever possible. Colour morphs were excluded from thesurvey, as these specimens are bred for their morphological characteristics and are therefore likely
not wild-sourced or even imported from Indonesia. The goal of the survey was to observe which

6 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© Jürgen Freund/WWF

Coral Reefs in Banda Neira, Moluccas, Indonesia.

Indonesian species were sold by the various vendors, and if the specimens that were traded were
declared as captive-bred or wild-sourced to gain insight into the trade between EU Member States.

2.1 Seizure data

Data on any seizures of live animals imported from Indonesia into the Netherlands, or wildlife
seized by Indonesian authorities with the Netherlands as a destination country, was requested fromboth the Indonesian and Dutch Governments. On 19 October 2015 a formal Dutch Freedom ofInformation law, Wet Openbaarheid van Bestuur (WoB), request was sent to the RVO.nl. The goalof this request was to obtain data on any seizures of live animals originating from Indonesia by the
Dutch authorities and obtain data on both CITES and non-CITES listed species imported into theNetherlands. On 17 November 2015 RVO.nl approved the WoB request (nr. Wob/2015/256) andprovided the data on all live animals seized originating from Indonesia between 2003 and 2013.
The Indonesian CITES Management Authority, PHKA, was approached with a similar request as the
Dutch authorities based on the Indonesian act on Public Information Openness. No response has
been received to this request.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

7

RESULTS AND DISCUSSION
According to the UNEP-WCMC CITES trade database, 547 947 live animals, both CITES andEU Annex listed, were imported into the Netherlands between 2003 and 2013 (Table 1). The vast
majority of animals were directly imported from Indonesia. Coral, fish and reptiles were also
imported from Indonesia via Japan, Malaysia, Singapore, Switzerland, Thailand, and the USA.
Coral specimens comprised 98% of the total trade in live animal specimens from Indonesia to theNetherlands, followed by fish (1.02%), reptiles (0.69%) and molluscs (0.24%). The share of coral
imports is even higher when coral reported in kilogrammes is taken into account. Between 2003
and 2013 only one bird species (Pesquet’s Parrot Psittrichas fulgidus) and one mammal species(Large Flying-fox Pteropus vampyrus) were reportedly imported from Indonesia. Five reptile
species imported from Indonesia were not native to Indonesia and originated from Madagascar
and Mozambique. Of the live animals imported from Indonesia 55% were reportedly wild-sourced(source code 'W'), 45% were reported as animals born in captivity (source code 'F') and 0.55% of theanimals were bred in captivity (source code 'C'). Quite a substantial percentage of trade is recorded
under source code 'F', which includes species born in captivity of first or subsequent generations. It
is not clear if trade in specimens under this source code falls outside the quota levels issued as theGovernment of Indonesia only excludes second generation specimens born in captivity from quotas.
For coral species, comprising the bulk of the trade, the use of source code ‘F’ has been endorsed by
the CITES Management Authority of Indonesia for specimens originating from mariculture.

Individual specimens traded

3,000

90000

Individual specimens

70000

2,000

60000
50000

1,500

40000
30000

1,000

20000

500
0

Coral (individual specimens)

80000

2,500

10000
2003

2004
2005
Birds

2006
Fish

2007
2008
Mammals

2009
2010
2011
Molluscs
Reptiles

2012
2013
Coral

0

Species traded
160

Species traded

140
120
100
80
60
40
20
0

2003

2004

2005
Birds

2006
Coral

2007
Fish

2008

Mammals

2009
Molluscs

2010

2011

2012

2013

ReptilesFigure 1. Overview of the trade in live animals, both CITES and EU Annex listed, from Indonesia to theNetherlands during the period 2003-2013. The top graph displays fluctuations in the number of specimens
for six species groups, with coral trade on the second axis. The bottom graph displays the fluctuations in
number of species per species group imported per year. Source: UNEP-WCMC CITES Trade Database.

8 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

A

B

Birds

5

Coral
Coral(specimens(specimensand
andkilogrammes)
kilogram)

90,00080,000470,00060,0003

50,00040,0002

30,00020,0001

10,0000C02003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
C

Fish
Fish

2,500

2003

2004

D

2005
C

2006
F

2007
I

2008

2009

2010 2011
Kilogramme
Kilogram

2012

2013

2009

2010

2011

2012

2013

2009

2010

2011

2012

2013

W

Mammals
Mammals

120
100

2,000

80
1,500

60

1,000

40

500
0

20
0
2003

2004

2005

2006

E

2007 2008
C D W

2009

2010

2011

2012

2013

2005

2006

2007 2008
W

ReptilesReptiles

700

400

600

350

500

300
250

400

200

300

150

200

100

100

50
0

2004

F

Molluscs

450

2003

2003

2004

2005

2006

2007 2008
C F

2009

2010

2011

2012

2013

0

2003

2004

2005

2006

2007 2008
C F W

Figure 2. Overview of the trade in live, both CITES listed and EU Annex listed, animals from Indonesia
to the Netherlands during 2003-2013. Graph B comprises both the trade in live coral specimens (stackedbars) and in kilogrammes (line). Captive-bred: source code 'C', and Captive-born: source code 'F' and Wildsourced: source code 'W', CITES Appendix I species bred for commercial purposes: source code 'D'; Seizedanimals: source code 'I'. Source: UNEP-WCMC CITES Trade Database.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

9Table 1. Overview of trade in live animals, as reported in both individual specimens and kilogrammesof all orders and their corresponding sources. The table shows the reported trade for all orders specified by
CITES source code. Trade quantities are also reported for both countries specific to highlight discrepancies
between the reported numbers. Captive-bred: source code 'C' and 'D' (fish), Captive-born: source code 'F',
Confiscated: source code 'I' and Wild-sourced: source code 'W'. 'NL' refers to the reported quantity by the
Netherlands, and 'ID' to the reported quantity by Indonesia. Source: UNEP-WCMC CITES Trade Database.
Order

Captive
bred

Birds

8

Coral (specimens)

135

Captiveborn

Wildsourced

ID

NL

8
265 598

Coral (kilogrammes)
Fish

Confiscated2286

Mammals26

271 320432 346296 980

48 77317 57140 438

3327

2325

4066

175

Molluscs

200

1100

Reptiles

961

91

2720

157

100

810

740

3442

1672

3.1 Seized animals

The data received from RVO.nl on seized live animals, both CITES and non-CITES listed, fromIndonesia provided only a very general insight on seizures made within the Netherlands. Dataobtained from RVO.nl did not include any detailed information on particular species or speciesnames but were confined to general terms like "Coral" or "Stony Coral". The majority of the seizedanimals consisted of live coral with only a few reptiles, clams and shrimp specimens (Table 2).
The data provided did not specify the seized coral to species level. A total of 52 pieces of softcoral, and 263 pieces of stony coral were seized. In addition 852 coral pieces (spp. unknown) wereseized during 2003 and 2013. In addition to the unidentified coral pieces, five individual Green
Tree Pythons Morelia viridis were seized in 2010 and one Giant Clam Tridacna gigas in 2012. Fivesponges (not CITES-listed) and 31 shrimps were seized as well.
Nonetheless, the CITES biennial reports submitted by the Netherlands provide a more complete
overview of the specimens seized, even though only a few documented seizures found in thebiennial reports matched the data received through RVO.nl. Of all Dutch biennial reports forthe period examined, only the reports of 2011-2012 and 2013-2014 contained detailed data on
specimens seized from Indonesia. The biennial report of 2009-2010 describes the seizure of 991 kg
Scleractinia spp. as was also mentioned in the data received from RVO.nl. However between 2011
and 2012, an additional 615 substrate stones of which 73 contained living colonies of Porites spp.
were reportedly seized due to missing CITES export and import permits. Moreover, 169 living coral
specimens (157 Acropora spp., 11 Montipora spp., 1 Merulina spp.) and one clam (Tridacna spp.)
were included in a shipment of ornamental fish, destined for Romania, and seized in transit due
to missing CITES export and import permits. A shipment of 680 kg live corals, containing at least
117 pieces, was also seized due to a lack of CITES permits. Thirty-one pieces of natural stone wereseized based on the fact that they contained live or recently live colonies of Scleractinia spp. andHeliopora spp. while import permits were lacking. Furthermore, 13 pieces of stony corals, identified
as Tubastrea spp. (4), Fungia spp. (3), Cynarina lacrymalis (1), Symphyllia spp. (5), were seized as
CITES permits were lacking. Additionally the biennial report 2013-2014 revealed that the five live
corals seized in 2013 comprised pieces of Fungia spp. (3), Tubastrea spp.(1) and Herpolitha spp. (1).
Specimens were seized as no CITES export and import permits were included.

10 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

Table 2. Overview of all seized live animals, both CITES listed and non-CITES listed, in the Netherlands
with Indonesia as origin. Quantity data are in specimens unless stated otherwise. Data were obtained via aDutch Freedom of Information law request (Wob/2015/0256) to the Netherlands Enterprise Agency (RVO.
NL) and biennial reports submitted by the Netherlands.
Seizure data provided by RVO.nl

Seizure data provided by the biennial reports

Year

Taxon

Quantity

Year

Taxon

Quantity

2003

Stony coral (spp. unknown)

6

2003

Coral (spp. unknown)

37

2004

Coral (spp. unknown)

42

2004

Coral (spp. unknown)

19

2005

Soft coral (spp. unknown)

38

2005

Stony coral (spp. unknown)

29

2006

Stony coral (spp. unknown)

68

2006

Stony coral (spp. unknown)

30

2006

Soft coral (spp. unknown)

14

2007

Coral (spp. unknown)

125
g

2008

Coral (spp. unknown)

25

2008

Coral (spp. unknown)

20

2008

Coral (spp. unknown)

16

2010

Green tree pythons Morelia viridis

5

2010

Coral (spp. unknown)

991
kg

2010

Scleractinia spp.

991
kg

2011

Coral (spp. unknown)

180kg

2011-2012

Porites spp.

73

2011

Stony coral (spp. unknown)

65

2011-2012

Acropora spp.

157

2011

Stony coral (spp. unknown)

65

2011-2012

Montipora spp.

11

2012

Coral (spp. unknown)

106

2011-2012

Merulina spp.

1

2012

Giant Clam Tridacna gigas

1

2011-2012

Coral (spp. unknown)
Scleractinia andHeliopora spp

680 kg2012

Coral (spp. unknown)

582

2012

Cleaner Shrimp (spp. unknown)

31

2011-2012

Tubastrea spp

4

2012

Sponges (spp. unknown)*

5

2011-2012

Fungia spp.
Cynarina lacrymalis
Symphyllia spp.

3
1
5

2013

Coral (spp. unknown)

5

2013

Fungia spp.
Tubastrea spp.
Herpolitha spp.

3
1
1

31

*Not CITES listed.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

113.2 Inconsistent quantities

The UNEP-WCMC CITES trade database provides a unique insight into the trade in CITES listed
species, but must be interpreted taking into account certain caveats. The reliability of the trade
database is dependent on the quality of the national reporting by the CITES Parties. Often, Parties
are bound by limited capacity and unlimited demands on their resources (Foster et al., 2014).
CITES Parties may report data to the UNEP-WCMC CITES trade database based on actual trade
numbers or on the number of permits issued. This may result in substantial discrepancies within
the database and can cause uncertainty about actual trade quantities. Earlier studies have shownthat the importer and exporter reported species and quantities often differ significantly, thereby
compromising the reliability of these datasets (Foster et al., 2014; Nijman, 2010,). Actually traded
quantities are often considerably less than the quantities for which permits have been issued.
Moreover, some permits are not used at all, which leads to reported trade transactions in the
database that actually never took place (UNEP-WCMC, 2013b). Nonetheless for Appendix III or
EU Annex C and D species only an export permit and/or import notification is required which may
result in a reporting gap by the importing country. The import notification is not a requirementby CITES but a stricter EU measure. Other reasons for reported differences in quantities may be:discrepancies in reporting of source, purpose, terms and units, or permits may be issued at the endof one year and arrive in the import country in the following year UNEP-WCMC (2013b).
Even though detailed analyses of the database are tremendously valuable, the factors influencing
the reliability of the dataset should be taken into account. Discrepancies between the importerand exporter-mentioned quantities were observed in our analysis. Of all 1146 reported records,
132 showed no exporter-reported quantity and 496 no importer-reported quantity. Moreover,large differences were observed between the exporter- and importer-reported quantities with
only 41 cases in which both parties reported the same trade quantities. In 2012 data provided by
the Netherlands were based on actual trade (UNEP-WCMC, 2015a), however, in 2013 (UNEPWCMC, 2015b) it was not specified. Hence, the actual amount of animals imported is likely
lower than quantities mentioned in this report. The largest difference in reported quantities was
12 509 specimens. In this particular case, Polyp Stony Coral Acropora spp. were imported by the
Netherlands in 2013. The Netherlands reported the import of 14 955 specimens while Indonesia
reported the export of 27 464 specimens. Discrepancies between reported quantities were also
observed in one case where coral was traded in kilogrammes instead of specimens. In this case,stony corals Scleractinia spp., the exporter reported quantity was 17 571 kg, while the imported
quantity was 9236 kg. For our analysis the highest reported quantity was used to represent a "worst
case" scenario. It is possible that the difference is caused by the fact that Indonesia reported thenumber for which permits were issued whereas the Netherlands reported the actual imported
animals (UNEP-WCMC, 2013b), therefore both the importer- and exporter-mentioned quantities
are additionally displayed in the report.
For 2013-2014 the Netherlands did report refusing CITES permits due to "inadvertent mistakes
or omissions" and is together with France and the United Kingdom responsible for the majority ofrefused import permits (Crook et al., 2016). EU Member States rejected CITES permit applications
during 2013-2014 for the following reasons: Insufficient basis for finding of non-detriment,
technical violations, suspected fraud or insufficient basis for finding of legal acquisition (Crook etal., 2016). Rejection of the CITES permit application could be an additional reason for transactions
with no importer-mentioned quantities.

12 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

3.3 Birds

Imports of live birds into the EU have been generally prohibited since October 2005 (EC 2005/760)
due to veterinary considerations4. According to CITES trade data, four captive bred Pesquet’s
Parrots were exported to the Netherlands from Indonesia in 2011 and 2012; yet only Indonesia
reported any trade quantities (Table 1). This raises doubt as to whether the specimens were actuallyimported, or Indonesia only issued permits for export. No other bird species were reportedly traded
between Indonesia and the Netherlands. The Pesquet’s Parrot is endemic to the rainforests of New
Guinea and classified as Vulnerable on the IUCN Red List. The main threat to this species is rapid
population decline due to hunting for feathers (BirdLife International, 2012).

3.4 Coral (Reported as No. of Specimens)

The Indonesian archipelago has an enormous wealth of coral reefs (Allen, 2008), and is together
with Malaysia, the Philippines and Papua New Guinea part of the Coral Triangle Biodiversity
hotspot (Tittensor et al., 2010). The Indonesian coral reef area comprises approximately
51 000 km2 and accounts for almost 20% of the global coral reef area (Center for Ocean Solutions,2009; Wilkinson, 2008)
Over the last three decades Indonesian coral reefs declined (Allen, 2008) from which many are
considered severely damaged (Scaps et al., 2007). In the mid-2000s the majority of Indonesian coral
reefs were considered to be under "moderate to severe risk" (Center for Ocean Solutions, 2009) eventhough the condition appeared to be improving between 1993 and 2014 (UNEP-WCMC, 2014b).
The main threat to corals in Indonesia is considered to be destructive fishing with explosives (Burkeet al., 2011) while the damage due to harvesting for the aquarium trade is considered as a relativeminor impact compared to other human-induced impacts (Reksodihardjo-Lilley et al., 2007). Even
though the international illegal trade was considered to be substantial (Jones, 2008), the CITES
Scientific Authority of Indonesia regarded this as highly unlikely due to checks in both Indonesia
and importing countries (UNEP-WCMC, 2014b).
For the Indonesian coral species, only the trade in Black Coral Antipathes spp. is prohibited, whileother wild-sourced corals can be traded for commercial purposes (Timotius, 2009; UNEP-WCMC,
2014b). Only live corals can be traded and the regulation of coral harvest falls under PHKA (UNEPWCMC, 2014b). Even though legislation is in place, both legal and non-legal instruments have alimited effect in managing the marine and coastal resources (Dirhamsyah, 2005). Weak governanceand vague legal instruments open for interpretation are seen as the main reasons for this (Tissot
et al., 2010). Indonesian export quotas are based on reef accretion rates and the condition of thereef (UNEP-WCMC, 2014b). Coral taxa are categorized in five categories depending on the size,
relative frequency, relative dominance and hard coral cover (UNEP-WCMC, 2014b). According to
Bruckner and Borneman (2006) collection quotas were set too high for several taxa as there wasa considerable discrepancy between the level of harvest and the abundance of the species. Export
quotas represented 90% of the allowable harvest taking into account any losses during the collection
process.
The Government of Indonesia is aiming at a ban on wild-sourced coral when sufficient coral canbe produced in mariculture (UNEP-WCMC, 2014b). Before 2008, Indonesia reported trade/
export of maricultured corals under source code 'W', but since 2008 under source code 'F' (UNEP4

Commission Regulation (EC) No. 318/2007 was replaced by (EU) 139/2013 which specifies import and quarantine
conditions. The import of captive-bred birds is possible when they originate from specific countries, show negative results
for avian influenza and Newcastle disease virus, are accompanied by animal health certificates and can be identified by aleg-ring or microchip (European Commission, 2007). It is unknown if there are any captive breeding facilities in Indonesiathat have the paperwork to breed this species which could support the legitimacy of the documented import into theNetherlands.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

13

WCMC, 2014b). This is also visible in Figure 2B in which wild-sourced corals made up the majorityof imported corals before 2008. Since Indonesia changed the source codes, the majority of imported
corals were declared under source code 'F'. This should be taken into account as the number ofwild-sourced specimens is therefore likely to be overestimated before 2008. However, the shift tothe majority of exported coral being declared under source code 'F' might raise questions if somecoral exports are not actually sourced from the wild. The quantity of corals produced by mariculture
operations in Indonesia is growing, with almost 75% of the Acropora spp. exported as mariculture
specimens. Coral under source code 'F' are produced by cultivation of fragments taken off other corals
and grown in open seabeds. The first fragmentation is obtained from a wild coral, while subsequentfragmentations are taken from the earlier fragmented pieces (Wood et al., 2012). Indonesia was themain global exporter of live coral with an average of 70% of the annual global export between 2000 and2010 (Wood et al., 2012). Coral mariculture is regulated by the PHKA and specific permits are needed
for the captive breeding and export of live specimens.
When analysing the trade by reported highest quantities, coral specimens comprised 98% of the trade
between Indonesia and the Netherlands between 2003 and 2013 (Table 1). Coral trade quantities
comprised 537 079 specimens, of which 50.20% were reportedly wild-sourced 'W', 49.45% werereported as born in captivity 'F' and 0.03% captive-bred 'C', see Table 8 in Appendix I. Trade inwild-sourced coral increased between 2003 and 2005 after which it decreased again and from 2008
remained relatively stable (Figure 2). This is in contrast to the coral reported under source code 'F'.
Coral reported under this latter source code increased throughout the study period and comprised
the majority of individual corals traded since 2008. Of all 537 079 specimens, only 526 specimens,(three reported at species level and one at coral order level), were imported by the Netherlands via
other countries, namely Malaysia. This comprised Acropora hyacinthus (3), Acropora jacquelineae (20),Caulastrea tumida (3) and the order Scleractinia spp. (500).
Trade in a total of 305 043 coral specimens was reported at genus level (Table 3), with the remaining
232 036 specimens reported at the species level (Table 8 in Appendix 1). Only one genus (Acroporaspp.) and 29 species were imported on an annual basis. However, there were large discrepancies
between the quantities reported between Indonesia and the Netherlands. Indonesia reported
219 480 specimens traded at genus level, while the Netherlands reported 190 607 specimens. Indonesia
reported 212 866 specimens traded at species level, while the Netherlands reported only 106 373
specimens. These discrepancies are likely partly due to the difference in reporting; i.e. permits issued
versus actual trade. Coral specimens also included pieces of reef rock and were reported under theorder Scleractinia (CITES, 2008). Since 2007, trade in pieces of reef rock has not required importpermits for the EU as it is considered as "fossilized" (CITES, 2008). Therefore the actual import of
Scleractinia spp. might be higher than documented in the UNEP-WCMC CITES Trade Database.
Trade in coral specimens should be reported at the species level. However, there are certain coral
genera for which identification at the genus level has been found to be acceptable (CITES Notification
No. 2003/020 and 2013/035). The genus Merulina spp. for which Indonesia reported the export of 150
captive-born specimens is not included in this list (CITES Notification No. 2003/020 and 2013/035)
and therefore should have been traded at species level, and not at genus level. Furthermore, Indonesia
reported the export of 69 504 specimens of Scleractinia spp. which comprises the order of stony corals.
Since only Indonesia reported the trade, it is likely that the transactions did not actually take place orwere reported by the Netherlands at the species level. Nonetheless, trade in live corals should only be
conducted on higher level taxa when the use of these taxa was found appropriate. For both Merulina
spp. and the order Scleractinia spp. this is not the case i.e. both the genus and order are not mentioned
in CITES Notification No. 2003/020 and 2013/035 and should therefore be traded at species level. Tradein live corals at the order level is undesirable as it fails to take into account the genus or species-specificthreats, and therefore may include both non-threatened and threatened species.

14 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

Table 3. Number of live specimens of coral taxa (reported above species level) imported into theNetherlands from Indonesia and their reported source during the period 2003-2013. Captive-bred: sourcecode 'C', Captive-born: source code 'F', and Wild-sourced: source code 'W'. 'NL' refers to the reported quantity
by the Netherlands, and 'ID' to the reported quantity by Indonesia.
Taxon

Captive-bred

Captive-born
190

31

212

96

20

131 517

24 168141 676

90 396160

30

Acanthastrea spp.
Acropora spp.
Alveopora spp.

160

Anacropora spp.

190

Caulastraea spp.

15

4828

Cycloseris spp.

Wild-sourced

ID

NL

190
1767

6458

2687

20

20

245

273

67

Dendrophyllia spp.

10

Distichopora spp.

90

Echinophyllia spp.

857

857

233

Echinopora spp.

1450

1450

520

Euphyllia spp.

150

150

Favia spp.

315

497

812

330

Favites spp.

200

295

495

322

1334

1334

805

481

299

Fungia spp.

10

Galaxea spp.

481

Goniastrea spp.

50

158

197

83

Goniopora spp.

656

5265

5774

2278

Hydnophora spp.

912

912

367

Lobophyllia spp

330

1405

1623

Merulina spp.

150

150

591

Millepora spp.

291

291

39

Montastrea spp.

412

401

200

4826

Montipora spp.

29 443

11 296

Oxypora spp.

370

370

90

Pavona spp.

216

216

59

Pectinia spp.

732

757

274

1731

674

14 515

5512

Pocillopora spp.

20

15

Porites spp.

25 951

25

1731
1780

Scleractinia spp.*

12 675500

69 504

1877

1877

791

Stylophora spp.

1557

1557

678

Symphyllia spp.

411

82

493

214

Tubastraea spp.

20

1011

1024

502

Turbinaria spp.

1806

1455

3261

1480

Seriatopora spp.

70 00420*Trade in a coral order, instead of genus. Source: UNEP-WCMC CITES Trade Database.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

15

Figure 3. Overview of the number of export quotas set for coral species versus the number of quotas set
for coral genera in Indonesia over the period 2003-2013. Showing an increasing number of quotas set forcoral genera compared to quotas set for coral species. Source UNEP-WCMC CITES Trade Database.

In 2003, Indonesia set export quotas for 62 coral species, but the number of species-specific quotas
decreased to no species-specific quota in 2007 and 2008 (Figure 3). Indonesia set no export quotas
for coral in 2007 and 2008. In 2009 export quotas were set again, for 20 species, which increased to
42 species the next year and remained relatively stable with 36 species in 2013. From 2009 a decreasein species-specific export quotas can be observed while export quotas at genus level increased
to 18 genera in 2013. It is obvious that more and more quotas are set at genus level and less for
species specific. Even though trade at genus level was found acceptable by CITES Parties for certain
genera (CITES Notification No. 2003/020 and 2013/035), it may obscure species specific threats andshould be used with caution. Moreover, it should only be applied to the genera mentioned in CITES
Notification No. 2003/020 and 2013/035.
Trade in the Leafy Hedgehog Coral Echinopora lamellose reached 191% of the quota set for 2012.
However, the coral was reported under category 'F'; animals born in captivity while the quota wasset for wild-sourced specimens. It raises questions since coral exported under category 'F' increased
dramatically after 2010 and peaked in 2012. Post 2010, import numbers are significantly higher
than previous import numbers. The sudden increase of Leafy Hedgehog Coral declared undersource code 'F' raises questions if some exports are not actually sourced from the wild instead ofcomprising animals born in captivity.

Figure 4. Trade in Leafy Hedgehog Coral Echinopora lamellosa. Displaying the number of animals traded as
Captive-born: source code 'F' and Wild-sourced: source code 'W', versus the annual set export quota. Source:
UNEP-WCMC CITES Trade Database and Species +.

16 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

3.4.1 EU trade restrictions

Trade suspensions were in place for wild-sourced specimens for 10 coral species according to the
UNEP-WCMC CITES trade database and Species+ during the period 2003-2013, for either the whole
or a part of the study period. Before the EU decides on a trade suspension, an SRG negative opinion
is formed, which also results in a temporary trade suspension. For five species a negative opinion wasin place during the study period that was not turned into a trade suspension. For all species except
Euphyllia glabrescens the UNEP-WCMC CITES Trade Database included trade records following the
adoption of a negative opinion or suspension.
Trade in Catalaphyllia jardinei was suspended on 1 March 2003, however the trade database indicatedreported trade in wild-sourced specimens in 2006 (19 specimens), 2010 (4), and 2011 (20) and 2013(30). These transactions were only reported by Indonesia. It is therefore likely that the discrepancy
is caused by the difference in reporting; i.e. permits issued vs. actual trade. Similar observations
were made for the other coral species with trade suspensions in place; Blastomussa wellsi, Cynarina
lacrymalis, Eguchipsammia fistula, Euphyllia divisa, Heliofungia actiniformis, Plerogyra sinuosa andPlerogyra turbida; and with negative opinions issued: Euphyllia cristata, Euphyllia divisa, Euphyllia
paraancora and Porites cylindrical. In 2008 (10 specimens), 2011 (5), 2012 (30) and 2013 (50) wildsourced White Grape Corals Euphyllia cristata were imported with EU trade suspensions being inplace since 10 May 2005. For 2008, 2011 and 2012 only Indonesia reported traded quantities. For
2013, both Indonesia and the Netherlands reported trade in White Grape Corals. However, in contrast
to the other imports, these were imported under source code 'F', which does not fall under the EU
suspension. A negative opinion for White Grape Corals was already in place between 2000 and 2005
(UNEP, 2016). For Hydnophora microconos a negative opinion was formed on 22 May 2003, formalized
into a trade suspension on 10 May 2006. According to the CITES trade database specimens werereportedly imported into the Netherlands in 2003 (22), 2004 (25), 2005 (19), 2006 (57), 2007 (20),2008 (30) and 2009 (3). Although for 2007, 2008 and 2009 only Indonesia reported the quantities, in
2004, 2005 and 2006 both Indonesia and the Netherlands indicated reported trade in wild-sourced
H. microconos, which makes it very likely the specimens were actually imported despite an EU import
restriction in place. The same might be the case for trade in Trachyphyllia geoffroyi for which a negative
opinion was in place since 22 May 2003 and a trade suspension was issued on 18 February 2005. Tradewas reported in the CITES trade database in 2003 (285), 2006 (20), 2012 (12) and 2013 (69). Althoughfor 2006, 2012 and 2013 only Indonesia reported the trade, which can indicate that only permits were
issued but no actual trade took place. However, in 2003 both Indonesia and the Netherlands reported
trade in T. geoffroyi. All trade could have taken place before the negative opinion that was formed in
May 2003 although it is notable that a particularly large quantity (285) was reportedly traded in 2003
compared to other years.

3.5 Coral (Reported in Kilogrammes)

Besides trade in individual pieces, live coral (source code: LIV) was also reported in kilogrammes.
This was despite the fact that EC No 865/2006 Annex VII states that live coral, i.e. transported in water,
needs to be reported in number of specimens, and raw coral (CITES trade term COR) in kilogrammes.
Accordingly, coral traded in kilogrammes should normally comprise coral rock consisting of formed
or dead coral fragments which may also be colonized by live coralline algae (CITES, 2008; Wood et al.,2012). Nonetheless, the UNEP-WCMC CITES Trade Database contains records of 48 773 kg live coral
imported from Indonesia in the period 2003-2013. European Commission regulation No 865/2006
clearly states that "Specimens of live coral transported in water should be recorded by number of pieces
only". It is unclear if the coral reported in kilogrammes is incorrectly documented with trade term
LIV instead of COR, or that it actually comprised live coral incorrectly documented as kilogrammes
instead of pieces. Moreover the coral imported in kilogrammes is not classified to species or genus
level but traded at the order level; Scleractinia spp. Interestingly, Indonesia reported only the exportof 17 571 kg during 2003-2013, while the Netherlands reported the import of 40 438 kg during the

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

17same period. This may suggest that part of it was illegally exported outside the quantities mentioned
in the permits or that Indonesia reported some of this trade in number of specimens (and not inkg). Indonesia was the second supplier globally for coral rock with an average of 11% of the global
export annually between 2000 and 2010 (Wood et al., 2012). In 2010, coral rock export of Indonesia
increased up to 22% of the global export corresponding to 268 tonnes (Wood et al., 2012).

Coral (kg)Trade in Scleractinia spp.

Table corals Acropora spp.

18 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© Jürgen Freund/WWF

Figure 5. Trade of live coral, Scleractinia spp., from Indonesia into the Netherlands. Quantities display
importer 'NL' and exporter 'ID' mentioned quantities and are given in kilogrammes. Source: UNEP-WCMC
CITES Trade Database.

3.6 Fish

All CITES-listed fish imported between 2003 and 2005 were wild-sourced (Table 4) and quantities
decreased from 2000 live specimens to none in 2005. Since 2007 hardly any wild-sourced CITES
listed fish have reportedly been exported from Indonesia to the Netherlands, while the numberof fish reported as captive-bred increased (Fig. 1D). In total, eight seahorse species and the Asian
Arowana Scleropages formosus were imported from Indonesia between 2003 and 2013. For four
Seahorse species only Indonesia documented an export quantity, which might be due to difference
in reporting i.e. permits issued versus actual trade, and the specimens may not actually have been
imported by the Netherlands.
The Asian Arowana is categorized as Endangered by IUCN and listed in Appendix I of CITES andEU Annex A. Nonetheless, trade in the Asian Arowana is possible when captive breeding facilities
comply with both national and CITES regulations. All Asian Arowanas reported as traded between
Indonesia to the Netherlands were imported as source code 'D', which comprises Appendix I
animals bred in captivity by registered breeding facilities for commercial purposes. Until 1995,
the Indonesian population of ranched Asian Arowana was listed in Appendix II, while all otherpopulations were listed in Appendix I. Since 1995 however, the Indonesian population was also
listed in Appendix I. Of the 286 Asian Arowana, only 137 were directly imported from Indonesia.
The other 149 were imported from Indonesia via Singapore (133) and Thailand (16). The Asian
Arowana is one of the most popular and expensive fishes in the international aquarium industry
fetching high prices (Hua Yue et al., 2004). Prices depend on the colour variety in which the redform as found in West Kalimantan can fetch up to 10 times more than e.g. the green variety which
is widespread in Southeast Asia (Ng et al., 1997). Large-scale harvesting of Asian Arowanas has
been detrimental to wild populations of the species (Rowley et al., 2008). In response to the listingin Appendix I, captive breeding facilities have been established all over Southeast Asia, includingIndonesia (Dawes et al., 1999).
The import of eight seahorse species is documented in the UNEP-WCMC CITES Trade Database.
Besides seahorses identified to species level, the database also documents 2654 wild-sourced
seahorses only identified to genus (Hippocampus spp.) level. However, this transaction was only
reported by Indonesia. In 2002, all seahorse species of the Hippocampus genus were listed inAppendix II of CITES. However, this was not implemented until 2004. For Kellogg’s Seahorse
Hippocampus kelloggi and Common Seahorse Hippocampus kuda EU trade suspensions for wildsourced specimens have been in place since 2008, and for the Barbour’s Seahorse Hippocampus
barbouri, Tiger Tail Seahorse Hippocampus comes, Spiny Seahorse Hippocampus histrix andHedgehog Seahorse Hippocampus spinosissimus since 2007 (UNEP, 2016). These trade suspensions
are apparent from the trade data as well. Since 2009 only two species, Barbour’s Seahorse andCommon Seahorse, were exported from Indonesia to the Netherlands. Before 2008, all seahorse
species traded were reportedly wild-sourced. However, since 2009 all seahorses were reportedly
captive-bred with a trade peak in the year after a trade suspension was in place (Figure 6). Lenzen etal. (2007) already reported an increase in trade shortly before trade bans were installed, suggesting
CITES authorities should have a closer look at the requested import and export permits duringtransition periods and in adhering to quotas. Seahorses reported at the genus level were also
imported from Indonesia. It is therefore unknown which species were involved. The IUCN Red
List status of the eight known seahorse species imported into the Netherlands ranges from Least
Concern to Vulnerable with EU suspensions in place for several species.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

19

Table 4. Imported fish species and their corresponding source in the period 2003-2013. Captive-bred:
source code 'C' and 'D', and Wild-sourced: source code 'W'. IUCN categories: Endangered (EN), Vulnerable(VU) and Least Concern (LC). CITES corresponds to their CITES Appendix listing, where 'N' means notlisted in CITES. 'NL' refers to the reported quantity by the Netherlands, and 'ID' to the reported quantity
by Indonesia. EU corresponds to the species’s EU Annex listing, with *meaning that there is an EU import
restriction for trade in wild-sourced specimen during the study period. Source: UNEP-WCMC CITES Trade
Database.
Taxon
Barbour’s Seahorse
Hippocampus barbouri

Captive-bred

Wild-sourced

NL

ID

IUCN

CITES

EU

1400

100

720

1300

VU

II

B*

25

VU

II

B*

Tiger Tail Seahorse
Hippocampus comes25

Crowned Seahorse
Hippocampus coronatus

67

67

LC

II

B

Long-snouted Seahorse
Hippocampus guttulatus

121

121

LC

II

B

Spiny Seahorse
Hippocampus histrix

25

25

VU

II

B*

Kellogg’s Seahorse
Hippocampus kelloggi

50

50

VU

II

B*

625

VU

II

B*

Common Seahorse
Hippocampus kuda

600

260

335

Hedgehog Seahorse
Hippocampus
spinosissimus

25

25

VU

II

B*

Seahorses Hippocampus
spp.

2654

2654

-

II

B

275

EN

I

A

Asian Arowana
Scleropages formosus

286

169

All seahorses traded at genus level were imported in 2003 and 2004, overlapping with time period
when the CITES Appendix II-listing of all Hippocampus species came into force (15 May 2004).
Trade in seahorses is focused on two purposes, either dried for use in traditional medicine, or live as
aquarium fish. Seahorse life characteristics make them vulnerable to overexploitation (Foster et al.,2004) and concerns have been raised regarding the sustainability of the trade for many populations(Vincent et al., 2011). Seahorses are mainly sourced from non-selective fisheries although Vincent etal. (2011) mentioned that all live wild-sourced specimens were sourced by targeted fisheries.
Foster et al. (2014) stated that dried seahorses make up between 97-99.6% of the global trade inseahorses, with global trade in live seahorses ranging from 22 000-172 000 specimens annually.
Indonesia was reported as a significant exporter of live seahorses, with a reported export of 45 000
live, wild-sourced specimens in 2005. Foster et al. (2014) included the Netherlands in the top fiveimporters of live seahorses, but interestingly no live seahorses were imported by the Netherlands in2005.

20 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© Jürgen Freund/WWF

Common seahorse Hippocampus kuda

Common Seahorse Hippocampus kuda

600

500

Seahorse quantity

500

EU suspension for trade inwild caught animals

400

EU suspension for trade inwild-sourced specimens

300

200

146
100

89

100

25
0

2003

2004

2005

2006

2007
W

2008

2009

2010

2011

2012

2013

C

Figure 6. Trade in Common Seahorses Hippocampus kuda between Indonesia and the Netherlands.
Difference in source of the seahorses pre- and post-EU suspension (2008). Captive-bred: source code 'C' andWild-sourced: source code 'W'. Source: UNEP-WCMC CITES Trade Database.

Following the EU suspensions of wild-sourced specimens only two species have been imported
since 2009; Common Seahorse and Barbour’s Seahorse. The Common Seahorse is one of the two
species that dominates the global trade in live seahorses (Foster et al., 2014), which can also be
observed in this study. In contrast to Foster et al. (2014), who observed that trade in captive-bred
specimens halved between 2004 and 2011 after the EU suspensions for most seahorse species cameinto force, trade in reportedly captive-bred specimens imported into the Netherlands rose sharply
in 2009. In an overview of global aquaculture ventures for seahorse breeding, Koldewey et al.
(2010) mentioned that in 1999, Indonesia had at least one facility that was breeding both the Tiger
Tail Seahorse and Common Seahorse (Vincent, 1996). In Indonesia, the Seafarming Development
Centre is involved in aquaculture of seahorses, and managed to rear up to 53% of the young(Vincent, 1996). The sudden switch from wild-sourced to captive-bred following the EU tradesuspension of wild-sourced specimens can be seen as suspicious, however, evidence of successful
captive breeding suggests a genuine shift to captive-bred specimens.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

213.7 Mammals

Only one mammal species was imported from Indonesia, namely the Large Flying-fox between
2003 and 2013. This species was imported from Indonesia by the Netherlands in 2011 and 2012.
Interestingly, the trade data show discrepancies between reported quantities. In 2011, Indonesia
reportedly exported 100 specimens, while the Netherlands reported importing only 25 specimens.
In contrast, Indonesia reported 57 specimens in 2012 while the Netherlands reported 75 specimens.
The Large Flying-fox is listed as Near Threatened by IUCN and in Appendix II of CITES. In
the years of import, Indonesia reported a quota of 270 and 225 specimens for 2011 and 2012
respectively. However, the 2011 UNEP-WCMC overview of EU wildlife trade suggests that taking
the highest quantity is an overestimation of the actual imported quantity in this particular case
(UNEP-WCMC, 2013a). In 2011 the Netherlands and Italy were the top EU importers for the Large
Flying-fox with a total of 53 live, wild-sourced specimens for both countries combined. In thiscase the Netherlands reported 25 specimens, compared to 100 by Indonesia. The discrepancies in
the reported quantities can be the result of the differences between reporting i.e. permits issued or
actual trade. The discrepancy for 2012 may be a result of export permits obtained at the end of 2011
in Indonesia but actually getting imported into the Netherlands in early 2012. However, it can alsomean that more animals were exported than the permits allowed for. The EU reports an increasing
trend in the import of Large Flying-fox into the EU. From 2002-2008 no specimens were imported
from Indonesia, but this increased to 30 in 2009 and 20 in 2010 to 53 in 2011 and 75 in 2012
(UNEP-WCMC, 2013a). This represents an increase of 42% between 2011 and 2012. The Indonesian
export quotas showed the opposite trend, decreasing from 1000 specimens during 2002-2005 to
fewer than 300 specimens since 2010.

3.8 Molluscs

Giant clams (Subfamily Tridacninae) are an important food source in the South Pacific, but are also
traded as aquarium specimens, for their shells and shellcraft. The vast majority of live maricultured
giant clams sold to Europe are destined for the aquarium trade (Wells, 1997). Giant clams play animportant role in removing nitrates, nitrites and ammonia from water and are therefore increasingly
popular in the aquarium trade. They live in shallow waters in association with coral reefs
throughout the Indo-Pacific region. Giant clams prefer to live in shallow water to maximize the useof sunlight. Giant clams are susceptible to over-harvesting as they can be easily collected due to theirbright colours, late sexual maturity, slow growth and low natural recruitment (Wabnitz, 2003).
Until the 1990s clam farming was poorly developed in Indonesia. Recent technological innovations
lifted the constraints on the spawning of giant clams, and raising of giant clam larvae and juveniles.
Concerns for the survival of giant clams fuelled the interest in giant clam mariculture after wild
stocks declined throughout their range. Giant clam hatcheries were initially used to restock natural
populations and grow clams for food production. However, nowadays hatcheries are used to supply
the aquarium trade with giant clams with government-owned and commercial hatcheries in mostIndo-Pacific countries (Wabnitz, 2003; Wells, 1997). Giant clam mariculture is relatively simple andonly requires clean seawater and sunlight. The number of eggs ranges from millions to hundreds ofmillions which make giant clams well suited for mariculture (Ellis, 2000).
The UNEP-WCMC CITES Trade Database documents trade in five species of giant clams, between
2003 and 2013. Trade in these species fluctuated during this period with years of no reported tradeand years in which four out of five species were imported (Figure 1F). All species are listed as Least
Concern by IUCN, in Appendix II of CITES and EU Annex B (Table 5). There are no export quotas
or EU import restrictions in place for the Indonesian populations of any of the traded species. The
Southern Giant Clam Tridacna derasa was the least traded species with only 20 specimens in 2008.
The most frequently traded species was the Boring Clam Tridacna crocea which was imported
in five out of ten years. However, the Fluted Giant Clam Tridacna squamosa was the most traded

22 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlandsspecies in terms of number of specimens with respectively 600 specimens. All giant clams importedby the Netherlands were either reported as captive-bred or captive-born. When taking the largest
quantity reported, the trade comprised 1500 live specimens. However, discrepancies were foundbetween importer and exporter mentioned quantities. Indonesia reported a total of 810 specimens,
while the Netherlands reported 740 live specimens. The literature review carried out for this study
found no evidence for mis-declaration of specimens of the reported source (F) in trade.

Taxon

Captive-bred Captive-born NL

Bear Paw Clam
Hippopus hippopus
Boring Clam
Tridacna crocea

20

Southern Giant Clam
Tridacna derasa

ID

IUCN

CITES

EU

210

110

150

LC

II

B

460

100

380

LC

II

B

20

LC

II

B

20

Maxima Clam
Tridacna maxima

45

145

105

85

LC

II

B

Fluted Giant Clam
Tridacna squamosa

135

465

175

425

LC

II

B

Giant clam Tridacna gigas

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© Jürgen Freund/WWF

Table 5. Imported clam species and their corresponding source in the period 2003-2013. Captive-bred:
source code 'C', and Captive-born: source code 'F'. CITES refers to their CITES Appendix listing, and 'EU'
corresponds to the species’s EU Annex listing, 'NL' refers to the reported quantity by the Netherlands, and 'ID'
to the reported quantity by Indonesia. Source: UNEP-WCMC CITES Trade Database.

23

3.9 Reptiles

Indonesia is one of the 17 megadiverse countries in the world (Mittermeier 1997) and home to atleast 7.3% of all reptile species (Iskandar et al., 2006; Kusmana, 2011). The trade in reptiles fromIndonesia is well studied over the years. Although Indonesia has regulations and guidelines inplace to regulate trade in its wildlife, wildlife laws are often violated (Natusch et al., 2012; Nijman,2010). Recent studies on Green Tree Pythons Morelia viridis (Lyons et al., 2011) and Tokay Geckos(Nijman et al., 2015) concluded that wildlife laundering through breeding farms is a common
problem in Indonesia. For specimens that are captive-bred, no quotas are set in Indonesia andpermits can be obtained more easily than for their wild-sourced counterparts. However, researchshowed that many of the harvested wild-sourced specimens are actually taken to breeding farms andsubsequently exported as captive-bred while in fact the animals originated from the wild (Lyons etal., 2011). Many breeding facilities do not have the capacity to breed the quantities they reportedly
export as captive-bred (Nijman et al., 2009). For many species it is not economically viable to breed
the large numbers requested by the international trade as breeding farms are not able to produce
them fast enough (Nijman et al., 2015) and profits decline when animals need to be cared for at
breeding facilities compared to harvesting from the wild (Lyons et al., 2011). Species with long
reproductive cycles, like many reptiles, are therefore not economically viable for captive breedingat the scale the international trade would require (Lyons et al., 2011). Interestingly, a key documenton the CITES implementation in Indonesia (Soehartono et al., 2002), recognizes this problem anddescribes breeding of monitor lizards and snakes for commercial use as not cost-effective.
After corals, CITES listed and EU Annex listed reptiles were the third group traded in the highest
quantities between Indonesia and the Netherlands. Between 2003 and 2013 trade comprised 3772
specimens of 46 species according to the CITES Trade Database (Table 6). Of the 3772 specimens,
72% were reportedly wild-sourced, 26% captive-bred and 2% captive-born. Of all 3772 specimens,
129 specimens comprising seven species were imported via other countries than Indonesia butwith a registered origin in Indonesia. A Tanimbar Python Morelia nauta (1) was imported from theCzech Republic5 , Green Tree Pythons (22) from Japan, and Viper Boas Candoia aspera (6), Pacific
Ground Boas Candoia carinata (10), Green Tree Pythons (4), Brongersma's Short-tailed Pythons
Python brongersmai (28) Sumatran Short-tailed Pythons Python curtus (34) and Water Monitors
Varanus salvator (24) from the USA.
Import quantities of reptiles varied during the 10-year study period (Figure 1G). In the period
2003-2005 the number of wild-sourced specimens dropped significantly and subsequently remained
stable until 2007. From 2005 to 2009 the number of specimens reported as captive-bred increased to
exceed the wild-sourced specimens. This is followed by a steep decline in captive-bred specimens.
After the initial decline, the number of wild-sourced specimens increased again after 2008.
However, large discrepancies were found between the quantities reported by the Netherlands andIndonesia. The Netherlands reported the import of 1672 specimens, while Indonesia reported theexport of 3442 specimens.
Of all reptile species mentioned in the UNEP-WCMC CITES Trade Database, one (2%) was listed as
Critically Endangered by IUCN, one (2%) as Endangered, six (13%) as Vulnerable, one (2%) as Near
Threatened, 16 (35%) as Least Concern, and 21 (46%) were not listed in the IUCN Red List. The two
species with the most alarming conservation status are the Sulawesi Forest Turtle Leucocephalon
yuwonoi (CR) and the Spiny Turtle Heosemys spinosa (EN).
The Sulawesi Forest Turtle is listed as Critically Endangered by IUCN and in Appendix II of CITES.
This Critically Endangered species was first described in 1995 and is endemic to the Minahassa
Peninsula of Sulawesi (McCord et al., 1995). The species remains one of the most poorly studied
5

The Czech Republic joined the European Union in May 2004, trade with EU Member States prior to that was reported to
the CITES Trade Database as external trade.

24 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlandsturtles in the world and hardly anything is known about its ecology (Platt et al., 2001; Riyanto,2006). Within a year following its description, the species already appeared at markets in mainland
China (Riyanto, 2006). A survey by Riyanto (2006) suggested that populations may already be
depleted in certain parts of its range. Moreover, the Sulawesi Forest Turtle appears to be a relatively
difficult species to keep in captivity (Lovich et al., 2000). Besides being threatened by international
trade, the species faces destruction of its habitat (Riyanto, 2006). Even though the imported numberof specimens by the Netherlands is low and most likely imported before the EU negative opinion,
for a species that is Critically Endangered such small numbers may still have a significant impact on
local populations.
The EU listed the species on Annex B and suspended trade since 10 May 2006, but a negative
opinion was formed already in 2004 (UNEP, 2016), the same year when the export of six wildsourced specimens was reported by Indonesia. As the Netherlands did not report an importquantity it is likely that the specimens were not actually exported to the Netherlands (and merely
the export permit was issued).
In the same year, the export of 10 wild-sourced specimens of the Spiny Turtle was reported byIndonesia. This species is currently listed as Endangered by IUCN and listed in CITES Appendix
II and EU Annex B. The import of wild-sourced specimens was suspended by the EU at the samedate as for the Sulawesi Forest Turtle. The Spiny Turtle is a species heavily exploited for the foodand Traditional Chinese Medicine markets in China and faces destruction of its habitat (Gong etal., 2009; Spinks et al., 2012). Nijman and Shepherd (2009) concluded that even though specimens
might be sold as captive-bred, all specimens of this species exported are very likely to be wildsourced based on the low fecundity and extremely slow growth of the Spiny Turtle. Similar to the
Sulawesi Forest Turtle, only Indonesia reported a trade quantity. It is likely that only an export
permit was issued by Indonesia but the actual international trade never took place.
Five of the 46 imported reptile species are currently not listed in CITES; 40 species are listed in
CITES Appendix II and one species is listed in CITES Appendix III. The Red-eyed Crocodile Skink
Tribolonotus gracilis and Radiated Ratsnake Elaphe radiata are both listed in EU Annex D but notin CITES. Species listed in EU Annex C and D require an import notification, which is a stricter
EU measure. Therefore any non-CITES species listed in EU Annex C and D are also found in the
UNEP-WCMC CITES Trade Database. This was the same in the cases of the Blue-tongued Skink
Tiliqua scincoides and Sunbeam Snake Xenopeltis unicolor – both species were listed in EU Annex D
until 2004. All reported trade in these species between Indonesia and the Netherlands took place in2003 and 2004.

3.9.1 Species not native to Indonesia

Of the 46 imported species, five were not native to Indonesia, of which four species had a reported
origin in Mozambique; Mozambique Girdled Lizard Cordylus mossambicus (15), Rhodesian Girdled
Lizard Cordylus rhodesianus (15), Transvaal Girdled Lizard Cordylus vittifer (20) and African
Helmeted Turtle Pelomedusa subrufa (10). For trade in the Mozambique Girdled Lizard, bothIndonesia and the Netherlands reported trade, but for the other non-native species only Indonesia
reported trade. All three girdled lizard species are listed in CITES Appendix II and EU Annex B
with EU trade suspensions. Only the Mozambique Girdled Lizard and African Helmeted Turtle arelisted by the IUCN Red List, as Vulnerable and Least Concern respectively. For the MozambiqueGirdled Lizard annual quotas were set for 500 specimens between 2003 and 2009 and for 1500
specimens in 2010. Since 2012 a CITES trade suspension has been in place for this species and since
10 May 2006 for the EU (UNEP, 2016). EU trade suspensions are also in place for the Rhodesian
Girdled Lizard (since 4 September 2014) and Transvaal Girdled Lizard since 10 May 2006 (UNEP,
2016). All trade in these species occurred in 2003 (before trade suspensions were in place). The
fifth non-native species, the Panther Chameleon Fucifer pardalis (6), originates from Madagascar,

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

25however a country of origin is not reported in the database records. The Panther Chameleon iscategorized as Least Concern by the IUCN Red List, listed in Appendix II of CITES and EU Annex
B. All reported sources were wild-sourced, except for the Panther Chameleon, which was reported
as captive-bred. Trade in the African Helmeted Turtle was only recorded until 2004, as the species
was removed from EU Annex D during that year.

3.9.2 EU trade restrictions

EU suspensions are in place for imports of wild-sourced specimens of 12 reptile species fromIndonesia (Table 6). However, for five species, trade in wild-sourced specimens was still reported
to the UNEP-WCMC CITES trade database after the trade suspension. Even though the species
are imported in relatively low numbers, import of wild-sourced specimens should not be possible
with the current EU suspensions in place. Negative opinions on trade are in place before trade issuspended.
The Asiatic Soft-shell Turtle Amyda cartilaginea is listed as Vulnerable by IUCN due to its demandin trade for meat. Even though Indonesia has set annual export quotas for this species (varying
between 25 200 and 27 000 during the study period) the EU has suspended trade in wild-sourced
specimens since 3 September 2008, with a negative opinion in place since 2 October 2006 (UNEP,
2016). Despite this EU suspension, trade in wild-sourced Asiatic Soft-shell Turtles was recorded in
the trade database for 2010, 2011 and 2013 with a total of 18 specimens. However, only Indonesia
reported the transactions, making it likely that only export permits were issued but the actual trade
never took place.
The Malayan Flat-shelled Turtle Notochelys platynota, is listed as Vulnerable by IUCN, in Appendix
II of CITES and EU Annex B. IUCN reported in 1999 that this species was traded at 2-3 tonnes
per day at Asian food markets (Asian Turtle Trade Workgroup, 2016). The EU has suspended tradein wild-sourced specimens since 3 September 2008, and a negative opinion preceded that from 12
June 2006 (UNEP, 2016). Trade in this species was reported for 2010, comprising 10 wild-sourced
specimens. Similar to the Asiatic Soft-shell Turtle, only Indonesia reported the transaction, itis therefore likely that only export permits were issued but the specimens were never actuallyimported by the Netherlands.
This is similar for the Black Marsh Turtles Siebenrockiella crassicollis for which trade was reported
in 2004 and 2011. The Indonesian population of this species is listed as Vulnerable by the IUCNRed List due to exploitation and habitat conversion and loss. Moreover, it is listed in Appendix II of
CITES and EU Annex B. Indonesia has an annual export quota in place for 4500 live specimens.
A SRG negative opinion for this species-country combination was formed in 2003. Since 10 May
2006 the EU has suspended the import of wild-sourced specimens into the EU (UNEP, 2016).
According to the database 50 wild-sourced turtles were imported directly from Indonesia in 2004,
and in 2011 again 14 wild-sourced specimens were imported. Since only Indonesia reported thetransaction it is likely that the transaction never took place and only export permits were issued.
Dumeril’s Monitor Varanus dumerilii is not listed in the IUCN Red list, but is listed in Appendix
II of CITES and EU Annex B. Indonesia has set annual export quotas for live specimens whichranged during the study period between 400 and 900 specimens. Since 1998 there has been an EU
trade suspension in place for wild-sourced specimens of the Dumeril’s Monitor. The trade databasementions the export of four wild-sourced specimens in 2010, although the Netherlands did notreport the import of the specimens. However, wild-sourced specimens of this species have been
observed for sale by a French vendor during a German reptile fair in 2015 (J. Janssen unpublisheddata). It is therefore possible that wild-sourced specimens can still be brought through other EU
countries into the Netherlands.

26 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

The Peach-throated Monitor Varanus jobiensis has a large distribution range and can be foundthroughout New Guinea and its offshore islands. It is suggested that this species is not sufferingfrom major threats (Shea et al., 2016). However, logging is taking place in the lowland habitat thisspecies lives in. This widespread species is listed as Least Concern by IUCN, in Appendix II of
CITES and EU Annex B. Indonesia has set annual export quotas for live specimens, comprising 450
live specimens annually since 2008. Since 1998 there has been an EU trade suspension in place forwild-sourced specimens of the Peach-throated Monitor (UNEP, 2016). Similar to all other species
with an EU suspension on the import of wild-sourced specimens, trade documented in the trade
database only consists of quantities reported by Indonesia. Therefore, it raises doubts if the twowild-sourced specimens reportedly exported in 2013 were actually imported by the Netherlands.

A Red-tailed Ratsnake Gonyosoma oxycephalum for sale at Snake Day 2015.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© TRAFFICThe Green Tree Python was the most common reptile species imported by the Netherlands fromIndonesia between 2003 and 2013. All 819 specimens were declared as captive-bred. This species
is nationally protected in Indonesia under Governmental Regulation 7/1999, which prohibits allexports of wild-sourced specimens. Although on paper declared as captive-bred, Lyons et al. (2011)
estimated that up to 80% of the Green Tree Pythons exported annually by Indonesia were in factwild-sourced. If accurate, this means potentially 655 of the reported 819 Green Tree Pythonsimported by the Netherlands could have been wild-sourced and laundered through breeding farms.
Even though captive breeding has the potential to reduce pressure on wildlife populations (Revol,
1995), when wildlife is laundered through breeding facilities a false sense of sustainability is created.
Population declines as a result of extensive collection have already been reported for Green Tree
Pythons (Lyons et al., 2011) and the Roti Island Snake-necked Turtle, Chelodina mccordi (Shepherd
et al., 2005)

27

28 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© Matthijs Kuijpers/Dreamstime.com

Green Tree Python Morelia viridis.

3.9.3 Reptile survey

The total value of live reptiles imported by the EU was estimated at approximately EUR7 million
in 2005 (Engler et al., 2007), making the EU the largest importer of live reptiles after the USA(Robinson et al., 2015). Although wildlife trade is governed within the EU through the EU
Wildlife Trade regulations encompassing the CITES regulations, day-to-day implementation andthe enforcement is the responsibility of each Member State. The EU single market ensures freemovement of goods since the EU is seen as one territory without internal borders. Discrepancies
between Member States in capacity, resources and legal frameworks to enforce these regulations canfacilitate illegal wildlife trade within the EU (Milieu Ltd et al., 2006). Traders that traffic wildlife can
exploit these vulnerabilities and seek the easiest entry point into the EU, from thereon wildlife canbe more easily moved across Member States (Milieu Ltd et al., 2006). It also shows that increased
enforcement by one Member State will not sufficiently tackle the problem. A co-ordinated response,
like that outlined within the EU Action Plan against Wildlife Trafficking, is needed to address thisproblem and prioritize implementation gaps.

Figure 7: Reportedly farmed Green Tree Python Morelia viridis (left) and wild-sourced Papuan Python Apodora
papuana (right) for sale by a German vendor at Snake Day (2015).

© TRAFFIC

On 11 October 2015 the annual Snake Day was surveyed for the presence of Indonesian species.
Snake Day is the annual snake expo organized by the European Snake Society in the Netherlands.
This snake show allows commercial trade in snakes and any products related to snake husbandry.
Moreover, it allows the sale of venomous snake species in a specific room used for this purpose.
During the survey all Indonesian species were documented including available price, origin and age(Table 7). Colour morphs of the Indonesian species were not included in the survey as these are theresult of selective captive breeding and most likely bred outside Indonesia. Indonesian species wereobserved at 23 stands, comprising 301 specimens of 31 snake species and interestingly also included
two specimens of an Indonesian lizard species; the Giant Blue-tongued Skink Tiliqua gigas gigas.
Stand holders selling Indonesian species came from Czech Republic (2), Denmark (2), France (1),Germany (7), Hungary (2), the Netherlands (7), Sweden (1) and the United Kingdom (1).

The most common Indonesian species encountered was the Green Tree Python with 52 specimens,
described by vendors as variously captive-bred and wild-sourced. Price differences were based onage and locality. Green Tree Python origin localities from eastern Indonesia comprised Biak, Aru,
Wamena, Jayapura, Sorong and Cyclops Mountains. Biak, with 22 animals, was the most common
locality listed by vendors. However, the Green Tree Python is nationally protected in Indonesia,
which prohibits the export of wild-sourced specimens of this species (Governmental Regulation
7/1999). Mis-declaring wild-sourced Green Tree Pythons as captive-bred has been documented in

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

29the past (Lyons et al., 2011). For two adult Green Tree Pythons, no source was mentioned by thevendor, raising questions about the legality of those animals.
Although King Cobras Ophiophagus hannah are native to Indonesia and were for sale at the reptile
show, origin localities were listed respectively as Malaysia and China. Amethyst Pythons Morelia
amethistina origin localities were listed as Biak and Aru. Paulson's Bevel-nosed Boa Candoia
paulsoni and in particular the subspecies Candoia paulsoni tasmai occurs in Indonesia (Halmahera
and Sulawesi). However, the origin locality of only one boa was mentioned, which was Santa
Isabel, Solomon Islands. The Reticulated Python Python reticulatus was one of the most common
snake species sold at the reptile show, except for two wild-sourced snakes, all were so-called colour
morphs. The two wild-sourced Reticulated Pythons were reportedly from the Indonesian localities
Sumana and Bisol. The island of Sumatra was the supposed origin of one of the Brongersma’s
Short-tailed Pythons Python brongersmai. The observed Macklot's Python Liasis mackloti was
not openly for sale but a bag containing this species was seen behind the stand. Two Giant Bluetongued Skinks were for sale despite the fact that Snake Day only specifically allows the sale of snake
species. Although it is unclear if this comprised captive-bred animals or wild-sourced, this species isnationally protected in Indonesia under Governmental Regulation 7/1999, prohibiting all export ofwild-sourced animals.

Figure 8 : Green Tree
Pythons Morelia viridis
for sale by a Czech
vendor at Snake day(2015) showing both
adults and juveniles
from various localities.
30 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© TRAFFIC
Jordi Janssen/TRAFFIC

During the Snake Day reptile survey a total of 162 Indonesian reptiles were documented as wildsourced. Of all wild-sourced reptiles 89% (145 animals) was sold by a single Dutch reptile shop. As
the majority of the species offered by this particular shop originated from Indonesia it suggested
the likelihood of a recent shipment from Indonesia to the Netherlands. The other 17 wild-sourced
reptiles were sold by vendors from Germany, Hungary, the Netherlands and the United Kingdom.
The species presented in this report are therefore very likely an underrepresentation of the species
and quantities actually imported into the Netherlands during the study period as imports via other
EU Member States may have also reached the Dutch market. The fact that wild-sourced reptiles
were sold at Snake Day by vendors from eight different countries emphasizes the fact that when the
trade of a single EU country is analysed, trade within the entire EU should be taken into account.

Table 6. Imported reptile species and their corresponding source in the period 2003-2013.
Captive-bred: source code 'C', and Captive-born: source code 'F' and Wild-sourced: source code 'W', 'NL'
refers to the reported quantity by the Netherlands, and 'ID' to the reported quantity by Indonesia. IUCN
categories: Critically Endangered (CR), Endangered (EN), Vulnerable (VU), Near Threated (NT), and Least
Concern (LC). CITES corresponds to their CITES Appendix listing, where 'N' means not listed on CITES. EU
corresponds to the species’s EU Annex listing, with * meaning that there is an EU or CITES suspension for
trade in wild-sourced animals, ** a positive EU decision, *** no significant trade anticipated by the EU and**** a negative EU decision on trade in wild-sourced specimens. a refers to species which were only listed on
EU-Annex D till 2004. Source: UNEP-WCMC CITES Trade Database and UNEP (2016).
Taxon

Captive Captive-born-bred

Wild-sourced ID

NL

NativeIUCN CITES EU

Y

VU

II

B*

Asiatic Soft-shell
Turtle Amyda
cartilaginea

18

18

Papuan Olive
Python Apodora
papuana

22

19

10

Y

-

II

B

Viper Boa
Candoia aspera

192

182

94

Y

-

II

B

MozambiqueGirdled Lizard
Cordylus
mossambicus

15

15

N

VU

II*

B*

Rhodesian Girdled
Lizard Cordylus
rhodesianus

15

15

N

-

II

B*

Transvaal Girdled
Lizard Cordylus
vittifer

20

20

N

-

II

B*

Amboina Box
Turtle Cuora
amboinensis

335

335

Y

VU

II

B*

Asian Leaf Turtle
Cyclemys dentata

70

70

Y

NT

II

B

Radiated Ratsnake
Elaphe radiata

17

Y

LC

N

D

6

N

LC

II

B*

10

10

Y

EN

II

B*

174

169

Y

-

II

B

6

6

Y

CR

II

B*

2

Y

LC

II

B*

Y

-

II

B

Panther
Chameleon
Furcifer pardalis

6

Spiny Turtle
Heosemys spinosa
White-lipped
Python Leiopython
albertisii

8

Sulawesi
Forest Turtle
Leucocephalon
yuwonoi
Water Python
Liasis fuscus
Macklot's Python
Liasis mackloti

2
25

15

124

17

25

64

10

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

31

Srub Python
Moreliaamethistina

6

Diamond Python
Morelia spilota

10

78

90

24

Y

LC

II

B**

8

54

62

3

Y

LC

II

B

789

571

Y

LC

II

B

1

Y

-

II

B

Green Tree Python 819
Morelia viridis
Tanimbar Python
Morelia nauta

11Javan Spitting
Cobra Naja
sputatrix

10

10

Y

LC

II

B**

Malayan
Flat-shelled
Turtle Notochelys
platynota

10

10

Y

VU

II

B*

16

32

Y

VU

N

B

African Helmeted
Turtle Pelomedusa
subrufa

10

10

N

LC

II

-

Oriental Ratsnake
Ptyas mucosus

10

10

Y

-

II

B**

BorneoShort-tailed
Python Python
breitensteini

97

92

40

Y

LC

II

B

King Cobra
Ophiophagus
hannah16

8Brongersma's
Short-tailed
Python Python
brongersmai

10

202

206

44

Y

LC

II

B

Sumatran Shorttailed Python
Python curtus

6

153

128

85

Y

LC

II

B

Reticulated Python 45
Python reticulatus

7

248

255

89

Y

-

II

B

Black Marsh Turtle
Siebenrockiellacrassicollis

64

64

Y

VU

II

B*

Blue-tongued
Skink Tiliqua
scincoidesa

45

45

Y

-

N

-

Red-eyed
Crocodile Skink
Tribolonotus
gracilis

33

33

Y

-

N

D

Blue-tailed
Monitor Varanus
doreanus

90

86

25

Y

-

II

B

Dumeril's Monitor
Varanus dumerilii

4

4

Y

-

II

B*

32 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

Gould's Monitor
Varanus gouldii

6

6Mangrove Monitor 21
Varanus indicus
Peach-throated
Monitor Varanus
jobiensis

2

Quince Monitor
Varanus melinus

14

6

6

Y

-

II

B

21

11

Y

LC

II

B

Y

LC

II

B*

Y

-

II

B

Y

-

II

B

2

14

6

Argus Monitor
Varanus panoptes

66

Emerald Tree
Monitor Varanus
prasinus

52

51

41

Y

-

II

B

201

63

Y

-

II

B

Y

-

II

B*

LC

II

B

214

Crocodile Monitor
Varanus salvadorii
Water Monitor
Varanus salvator

2
290

Spotted Tree
Monitor Varanus
similisAsiatic
Water Snake
Xenochrophis
piscator

20

Sunbeam Snake
Xenopeltis unicolora

4

Pacific Ground
Boa Candoia
carinata

146

268

183 Y

2

Y

-

II

B

20

Y

-

II

C

4

Y

LC

II

-

56

Y

LC

II

B*

108

Table 7. Observed reptile taxa at the annual Snake Day in Houten, the Netherlands in 2015. Captive-bred:
sourcecode Python'C', andPython
Captive-born:source code 'F' and Wild-sourced: source code ‘W’. CITES refers to Table
Reticulated
reticulatus.

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands© PublicDomainPictures/Pixabay.com

Rough-neckMonitor Varanus
rudicollis

33

Table 7. Observed reptile taxa at the annual Snake Day in Houten, The Netherlands in 2015. Captive-bred:
source code 'C', and Captive-born: source code 'F' and Wild-sourced: source code 'W'. CITES refers to their
CITES Appendix listing, where 'N' means not listed on CITES. EU corresponds to the species IUCN
categories: Endangered (EN), Vulnerable (VU) and Least Concern (LC).
Species

Male Female Sex
Source Price (€)
Unkwn.
Indiv.

Oriental Whipsnake
Ahaetulla prasina
Papuan Python
Apodora papuana

29
3

4

Price (€)
Pair

IUCN

CITES VenomousW

22,5 - 32,5

35 - 55

LC

N

F/W

500-700

12501300

-

II

90

165

-

N

X

-

N

X

-

N

X

Mangrove Snake
Boiga dendrophila

5W

Mangrove Snake Boiga
dendrophila melanota

2

C

Brown Tree Snake
Boiga irregularus

1

1

C

500

Paulson's Bevel-nosed
Boa Candoia paulsoni

2

4

C/W

100-340

400

LC

II

Common Pipe Snake
Cylindrophis ruffus

25

W

45

80

LC

N

Painted Bronzeback
Dendrelaphis pictus

15

W

25

45

-

N

Red-tailed Racer
Gonyosoma
oxycephalum

7

C/W

90-110

160

LC

N

C/W

290-450

960

LC

II

-

II

-

II

White-lipped Python
Leiopython albertisii

22

Macklot's Python
Liasis mackloti

1

1

Tanimbar Python
Morelia nauta

6

Scrub Python
Morelia amesthina

4

Carpet Python Morelia
spilota harissoni

2

1

1

Green Tree Python
Morelia viridis

14

13

25

Javan Spitting Cobra
Naja sputatrix

2

1

2

Golden Spitting Cobra 2
Naja sumatrana

2

Brown Kukri Snake
Oligodon purpurascens

C

350

W

190-600

C
C/F

390-1300 LC

II

100

LC

II

230 - 750

LC

II

LC

II

X

600

LC

II

X

C
W

55

100

LC

N

500

VU

II

-

N

LC

N

King Cobra
Ophiophagus hannah

1

1

C

300-900

Red MountainRatsnake
Oreocryptophis
porphyraceus
laticinctus

1

1

C

150

Keeled Ratsnake
Ptyas carinatus

3

3

W

1100

34 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

XIndo-Chinese
Ratsnake Ptyas korros2

1

Borneo Short-Tailed
Python Python
breitensteini
Brongersma's Shorttailed Python Python
brongersmai

1

1

Reticulated Python
Python reticulates

1

1

Giant Blue-tongued
Skink Tiliqua gigas
gigas*

1

1

White-lipped Pit
Viper Trimeresurusalbolabris

2

2

Mangrove Pit
Viper Trimeresurus
purpureomaculatus

W

40-70

29

C

90

1

C/W

110-270W

190 -250

C

2

Sumatran Pit
Viper Trimeresurus
sumatranus

4

Temple Pit Viper
Tropidolaemus
laticinctus

1

Bornean Keeled
Green Pit Viper
Tropidolaemus
subannulatus

2

Sunbeam Snake
Xenopeltis unicolor

2

5

2

25-30

C

C

1200

C

50

4

C

25

W

35

70

-

N

LC

II

LC

II

-

II

-

N

50

-

N

X

160

LC

N

X

13002300

LC

N

X

-

N

X

400-500

LC

N

X

60

-

N

490

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

35

CONCLUSIONS
The aim of this study was to get insights into the import-export relationships between Indonesia
and the Netherlands to better understand the role of the Netherlands as an importing country,
and Indonesia as a major exporter of wildlife. When taking the highest quantities reported to the
UNEP-WCMC CITES Trade Database, almost 550 000 live animal specimens were imported fromIndonesia by the Netherlands between 2003-2013, comprising birds, coral, fish, mammals, molluscs
and reptiles. Of all live animals traded between the two countries 98% comprised coral specimens,
followed by fish (1.02%) and reptiles (0.69%). The results show that the Netherlands plays asignificant role in the import of wild animals from Indonesia. Significant trade was documented
in particular in coral, fish and reptile species. Compared to the observed quantities for corals, thequantities traded for reptiles seem relatively minor. However, the total quantity traded is likely to bea lot higher since less than 8% of the world’s reptiles are currently listed under CITES, compared toall stony corals, blue corals, organ pipe corals and fire corals being listed in the CITES Appendices.
The reptile survey showed that true reptile trade is likely much higher, as trade in 18 non-CITES
listed reptile species was documented. Therefore this report likely underestimates the true traded
quantities for this species group. The European suspension on the import of wild birds is apparent
because only a few bird trade records are mentioned in the data. Even though signs are positive thatfor several species groups (e.g. molluscs and fish) animals reported as captive-bred are indeed
captive-bred, the significant trade in taxa like coral and certain reptile species suggest that at least
a part of the wildlife imported by the Netherlands is likely fraudulently declared as captive-bred or
captive-born. While only a small percentage of the reptiles imported were reportedly captive-bred,
this does include species like the Green Tree Python for which laundering has been documented.
This report also highlights several issues of concern.
Large discrepancies were observed between the quantities reported by Indonesia and theNetherlands. Indonesia reported the export of 456 658 animal specimens while the Netherlands
reported the import of 343 992 animal specimens. The two countries reported the same import/
export quantities for only 41 records. For 496 of the 1146 reported trade transactions, theNetherlands did not report any quantity at all, and 132 had no reported quantity by Indonesia. The
discrepancies mentioned in the report can be caused by differences in reporting; i.e. permits issued
versus actual trade. Although there are several reasons which can explain discrepancies in the data
it cannot be excluded that no permits were issued in the 132 cases where no exporter quantity was
documented. The observed differences between the importer- and exporter-reported quantities
calls for a careful interpretation of the trade reported to the database, taking into account certain
caveats. The majority of the imported species are native to Indonesia, although a few non-native
reptile species were exported by Indonesia as well. CITES trade data indicated trade in five reptile
species and eight coral species in contravention of EU trade suspensions in place. However, almost
all such trade was only reported by Indonesia, making it possible that these were not actuallyimported by the Netherlands; Indonesia bases their trade reports to CITES on permits issued
and not actual trade levels. For one (coral) species, trade was reported by both Indonesia and theNetherlands despite an EU negative opinion, followed by a trade suspension, being in place. For
several other species that were reportedly traded between the two countries, EU and/or CITES
trade suspensions or negative opinions were in place but trade in those species was limited to theyears before the suspensions became effective. The fact that trade was reported by both Indonesia
and the Netherlands for species while EU import restrictions were in place shows that more effort isrequired from the Dutch authorities to ensure that all EU import restrictions are taken into account.
Analysis of coral trade demonstrated that trade was conducted at both a species and genus level, andeven at the order level. For only a few genera trade the genus level is accepted according to CITES
regulations. Analysis of trade data revealed that trade was reported at the genus level for several

36 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlandsgenera for which trade at this level was not found to be appropriate. Moreover, the coral trade data
show that live coral is documented in kilogrammes, while the regulations state that live coral needs
to be traded as the number of specimens. Both the Netherlands and Indonesia reported trade in
kilogrammes instead. Even though coral trade, and in particular coral trade from Indonesia (e.g.
UNEP-WCMC, 2014b), has received quite a bit of attention through UNEP-WCMC publishingseveral reports, a number of issues as raised in this study still need to be addressed.
In addition, this report shows that trade suspensions can lead to a sudden increase of trade incaptive-bred specimens, as has been shown for the trade in Common Seahorse (UNEP-WCMC,
2014a), and potentially fraudulently declared as such. The issue of fraudulently reporting wildsourced specimens as captive-bred or ranched has been recognized by the EU in the past. Concernswith regards to the potential detrimental effects of this practice have been raised by the EU in 2011
(SC61 Doc. 27). Although CITES requires that a NDF is made, to ensure that the export of thespecimen is not detrimental to the survival of the species, it is unclear how these are conducted by
the Government of Indonesia.
The reptile survey also demonstrated the difficulties in analysing trade for a single European
country. The EU single market enables traders to transport specimens between EU countries
with virtually no documentation requirements. This has become apparent through the survey ofthe annual Snake Day in Houten (2015). Even though there are no EU import restrictions for theobserved species, the presence of Indonesian species at vendors from eight different EU countries
shows that the EU single market should be taken into account when studying wildlife trade within
the EU. Providing more evidence that the true quantities and reptile species imported and tradedwithin the Netherlands are therefore likely to be higher and some species imported into theNetherlands may be destined for other EU Member States.

RECOMMENDATIONS
In light of the findings Indonesia and the Netherlands should increase compliance with CITES
requirements by providing more accurate information on the actual numbers of wildlife traded. The
large discrepancies between importer and exporter mentioned quantities undermine the usefulnessof the UNEP-WCMC CITES trade database.
To ensure that trade in live animal species is not occurring to the detriment of wild populations inIndonesia, the Government of Indonesia should:• Increase transparency of the process under which the government conducts Non-Detriment
Findings in order to evaluate issued harvest and trade quotas for CITES-listed species;• The CITES Management Authority of Indonesia should take into account the viable production
capacity and economic viability of any commercial captive breeding/mariculture facility whenauthorizing their operations and should continuously monitor and inspect their operations inorder to prevent laundering of wildlife;• Initiate regular dialogue with the European Commission and individual EU Member States toprevent, discuss or lift trade suspensions and negative opinions;• Ensure that exported quantities do not exceed the quantities for which permits have been
granted;• Improve compliance with the CITES requirements regarding the documentation of tradein coral species, both for specimens and trade in kilogrammes, and should not issue export
permits for taxonomic levels for which trade has not been found appropriate by CITES as
mentioned in CITES Notification No. 2003/020 and 2013/035;

TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands37

To ensure fraudulently exported wild-sourced specimens are not imported into the Netherlands andinto the EU common market, and to ensure that the import of live animal species from Indonesia
is not detrimental to the survival of wild populations the Government of the Netherlands and theEuropean Commission should consider the following priorities:
•

•
•

•
•

•

•

The CITES Scientific Authorities of the Netherlands/ European Commission should takesteps to take into consideration scientific evidence regarding possible false declarations of
captive breeding before issuing import permits. Systematic requests for detailed information
should be made to exporting countries on captive breeding facilities (including for captiveborn specimens) and steps taken to monitor breeding facilities to prevent laundering of wild
specimens.
The Netherlands should take steps to record coral trade more accurately, and consider refusing
imports which are incorrectly documented, i.e. with trade terms LIV instead of COR;
The European Commission and the Netherlands should consider refusing the imports of species
for which quotas have been set at genus or higher taxonomic level, unless the use of higher
taxonomic levels is accepted by the CITES Parties (e.g. CITES Notification No. 2003/020 and2013/035).
The scale of trade in certain taxa, such as corals and reptiles, should be recognized and EU law
enforcement efforts should be enhanced to respond more effectively to fraudulent and illegal
imports at EU points of entry;
The enforcement authorities of the Netherlands, in particular the Netherlands Food andConsumer Product Safety Authority (NVWA), should increase regulatory vigilance overcommercial events (e.g. reptile trade fairs) that bring together vendors/buyers from various EU
Member States in order to prevent the import of species into the Netherlands for which trade
restrictions are in place, but likely entered the EU via other Member States (possibly those withweaker enforcement capacities);
To ensure a co-ordinated response to illegal and unsustainable trade, EU Member Statesshould pursue a more consistent law enforcement effort across the EU, guided by the effective
implementation of the EU Action Plan against Wildlife Trafficking. This could include exchange
of information obtained by regular monitoring of key EU wildlife fairs and markets (physicaland online), which could provide early warnings for emerging trends and potential illegal trade;
The European Commission should consider improving co-operation on a scientific and/or
enforcement level between Indonesia and the EU (including the Netherlands) for example
through inviting representatives of the Indonesian Government to the Scientific Review Group(SRG). Such co-operation could include study exchanges, exchange of scientific information
and underlying methodologies or joint enforcement operations that target Indonesian wildlife
traded onto the EU consumer market.

38 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

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42 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

APPENDIX
Table 8. Number of live coral specimens imported into the Netherlands from Indonesia and theircorresponding source in the period 2003-2013. Captive-bred: source code 'C', Captive-born: source code
'F' and Wild-sourced: source code 'W'. 'NL' refers to the reported quantity by the Netherlands, and 'ID' to thereported quantity by Indonesia. EU refers to the species’s EU Annex listing, with * meaning that there is an
EU suspension for trade in wild sources during the study period, ** a positive EU decision, *** no significant
trade anticipated by the EU and **** a negative EU decision on trade in wild-sourced specimens. a EU Tradesuspension came into place in 2005, before this a negative EU opinion. b since 2007, c since 2004, prior anegative opinion, d negative opinion between 2007-2011, suspension since 2012, e suspension since 2006, a
negative opinion since 2003, f since 2010, g since 2007, h a negative opinion in place beween 2003-2005 followedby an EU suspension. IUCN Red List categories : Vulnerable (VU), Near Threatened (NT), Least Concern(LC) and Data Deficient (DD). Source: UNEP-WCMC CITES Trade database and Species+.
Taxon

Taxon

Captive
Captive-born
bred Captive born

Captive-bredStarry Cup Coral Acanthastrea echinata

WildWildsourced
sourced

21

ID

ID

IUCN

CITES EUNL IUCN CITES EU
LC

II B

Acropora austera

80

80

NT

II B**

Acropora divaricata

535

535

NT

II B**

Acropora formosa

7178

8161 3918

NT

II B**

Acropora gomezi

561

561

DD

II B**

Acropora horrida

418

418

VU

II B**

Acropora humilis

1028

1908

1880 1908

NT

II B**

Acropora hyacinthus

65

1781

1404 1684

NT

II B**

Acropora jacquelineae

80

20

100

VU

II B**

Acropora kimbeensis

141

141

VU

II B**

Bluetip Coral Acropora loripes

80

80

NT

II B**

Acropora millepora

467

NT

II B**

Acropora nana

378

378

NT

II B**

Acropora prostrata

85

85

DD

II B**

Acropora rosaria

177

177

DD

II B**

Acropora secale

371

371

NT

II B**

Acropora tenuis

2443

NT

II B**Bush Coral Acropora valida

355

LC

II B**

Alveopora spongiosa

70

NT

II B

Blastomussa wellsi
Elegant Coral Catalaphyllia jardinei

30

Caulastraea echinulata

3927

75

617

20

Caulastraea tumida

10

Pacific Rose Coral Cynarina lacrymalis

Diploastrea heliopora

30

Flat Lettuce Coral Echinophyllia aspera

368

Leafy Hedgehog Coral Echinopora lamellosa

2213

Echinopora mammiformis

6

6

NT

II B*

43

73

VU

II B*

VU

89

II B

LC

II B

NT

II B

6

NT

II B*a75

NT

II B***b3552 1913
203031

2804 2211

64

64

11

NT

II B

62

81

30

NT

II B

360

73

LC

II B

1939

969

LC

II B

NT

II B

145

75

Eguchipsammia fistula

617

182

75

Lesser Knob Coral Cyphastrea serailia

2443

75

122

6

Cyphastrea decadia

467

9

355

3703

Candycane Coral Caulastraea furcata

21

NL

75
4556

4528 3635

-

II B*

4544

10 42314 535 8699

VU

II B****White Grape Coral Euphyllia cristata

100

234

334

50

VU

II B****

Frogspawn Coral Euphyllia divisa

100

7

107

43

NT

II B****

13 6098564

21 569 9974

NT

II B****

Hammer Coral Euphyllia ancora

Euphyllia glabrescens

20

25

Branching Anchor Coral Euphyllia paraancora

60

60

VU

II B****

Euphyllia yaeyamaensis

110

110

59

NT

II B****

Knob Coral Favia pallida

20

1374

1300

788

LC

II B

Honeycomb Coral Favites abdita

1425

1313

630

NT

II B

Larger Star Coral Favites chinensis

2398

2243

994

NT

II B

Mushroom Coral Fungia fungites

3995

3778 2227

NT

II B**

Fungia paumotensis

2131

2008 1063

LC

II B**

1497

2572 1068

VU

II B**

TRAFFIC Report: Going Dutch: An analysis of the import of live3097
animals 2795
from Indonesia
by the Netherlands
Fungia moluccensis1403
LC
II B**
Galaxea astreata

1169

43

Hammer Coral Euphyllia ancora

20White Grape Coral Euphyllia cristata
Frogspawn Coral Euphyllia divisa
Euphyllia glabrescens

25

4544

10 423

100

234

100

7

13 6098564

14 535 8699

VU

II B****

334

50

VU

II B****

107

43

NT

II B****

21 569 9974

NT

II B****VU

II B****

Branching Anchor Coral Euphyllia paraancora

60

60

Euphyllia yaeyamaensis

110

110

59

NT

II B****

Knob Coral Favia pallida

20

1374

1300

788

LC

II B

Honeycomb Coral Favites abdita

1425

1313

630

NT

II B

Larger Star Coral Favites chinensis

2398

2243

994

NT

II B

Mushroom Coral Fungia fungites

3995

3778 2227

NT

II B**

Fungia moluccensis

3097

2795 1403

LC

II B**

Fungia paumotensis

2131

2008 1063

LC

II B**

Galaxea astreata

1169

1497

2572 1068

VU

II B**Starburst Coral Galaxea fascicularis

765

5184

5671 2924

NT

II B**

Goniastrea pectinata

411

320

153

LC

II B

Goniastrea retiformis

182

166

70

LC

II B

8631

8751 3965

NT

II B**cGoniopora lobata

219

Goniopora minor
Flowerpot coral Goniopora stokesi
Mushroom Coral Heliofungia actiniformis
Blue Coral Heliopora coerulea

120

Slipper Coral Herpolitha limax
Hydnophora exesa

666

Hydnophora microconos
Hydnophora rigida

3831

Lobophyllia corymbosa

7579

7579 4202

NT

II B**

12 51612 086 6242

NT

II B**

6188

5767 4973

VU

II B*d

299

371

109

VU

II B**

208

201

78

LC

II B

3439

3862 1995

NT

II B**

167

167

51

NT

II B*e7793995 1801

LC

II B

5563

5471 2830

LC

II B**

Teeth Coral Lobophyllia hemprichii

10

3057

2764 2152

LC

II B**

Ruffled Coral Merulina ampliata

2488

2020

4386 2169

LC

II B**

763

689

279

NT

II B

Montastrea annuligera
Montastrea valenciennesi

724

663

203

NT

II B

Montipora digitata

453

72

453

72

LC

II B

Leaf Coral Montipora foliosa

1647

1105

2031 1078

NT

II B

Montipora millepora

293

293

LC

II B

Montipora verrucosa

259

Mycedium robokaki

90

Leaf Coral Pavona cactus

75

Carnation Coral Pectinia lactuca
Pearl Bubble Coral Physogyra lichtensteini

406

343

LC

II B

90

12

LC

II B

40

75

40

VU

II B

198

689

759

538

VU

II B**

40

4336

4376 2658

VU

II B**f

72

NT

II B*

31

Bladder Coral Plerogyra sinuosa

343

72

Jasmine Coral Plerogyra turbida

31

Cauliflower Coral Pocillopora damicornis

5134

Antler Coral Pocillopora eydouxi

360

Pocillopora verrucosa

8596

Sea Mole Coral Polyphyllia talpina

NT

II B*

5702 1831

LC

II B**

340

191

NT

II B**

1807

9118 2449

LC

II B**

2691

2669 1097

LC

II B

NT

II B**g1389

Finger Coral Porites cylindrica

2828

2036

4261 1995

Porites lichen

778

310

950

730

LC

II B

Porites lobata

56

35

56

NT

II B

Hump Coral Porites lutea

10

8

5

LC

II B

817

2716 1202

VU

II B

Porites nigrescens

2318

Seriatopora caliendrum

1.575

73

1315

806

NT

II B

Needle Coral Seriatopora hystrix

5.552

766

5734 1483

LC

II B**

Cluster Coral Stylophora pistillata

7841

986

7805 2499

NT

II B***

Symphyllia agaricia

352

332

147

LC

II B

Crater Coral Trachyphyllia geoffroyi

286

286

278

NT

II B*hOrange Cup Coral Tubastraea coccinea

308

289

39

-

II B**

Organ-pipe Coral Tubipora musica

80

2778

2841 1618

NT

II B**

Pagoda Coral Turbinaria mesenterina

1205

4083

4718 2480

VU

II B

10

10

VU

II B

6866

7405 4047

VU

II B**g

655

VU

II B

Turbinaria patula
Bowl Coral Turbinaria peltata

1284

Yellow Scroll Coral Turbinaria reniformis

861

333

44 TRAFFIC Report: Going Dutch: An analysis of the import of live animals from Indonesia by the Netherlands

NOVEMBER 2016

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working globally on trade in wild animals andplants in the context of both biodiversity
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