GGT’S RECOMMENDATIONSON THE AMENDMENT PROPOSALSFOR CONSIDERATION AT THE NINETEENTH MEETING
OF THE CONFERENCE OF THE PARTIES TO CITES(Panama City, 2022)

GLOBAL GUARDIAN TRUSTGGT’S RECOMMENDATIONSON THE AMENDMENT PROPOSALSFOR CONSIDERATION AT THE NINETEENTH MEETING
OF THE CONFERENCE OF THE PARTIES TO CITES(Panama City, 2022)

GLOBAL GUARDIAN TRUST

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SUMMARY OF THE RECOMMENDATIONS
Proposal
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
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02表A5.indd 1

Species
Amendment Recommendation
Hippopotamus amphibius
hippopotamus
II → I
No
Ceratotherium simum simum
white rhino
I → II
Yes
Ceratotherium simum simum
white rhino annotation
Yes
Loxodonta africana
African elephant annotation
Yes
Loxodonta africana
African elephant
II → I
No
Cynomys mexicanus Mexican prairie dog
I → II
Yes
Branta canadensis leucopareia
I → II
Yes
Aleutian Canada goose
Kittacincla malabarica
0 → II
Yes
white-rumped shama
Pycnonotus zeylanicus
II → I
Yes
straw-headed bulbul
Phoebastria albatrus
I → II
Yes
short-tailed albatross
Caiman latirostris
broad-snouted caiman
I → II
No
Crocodylus porosus
saltwater crocodile
I → II
Yes
Crocodylus siamensis Siamese crocodile
I → II
Yes
Physignathus cocincinus
water dragon
0 → II
Yes
Cytodactylus jeyporensis
hill gecko
0 → II
Yes
Tarentola chazaliae
helmethead gecko
0 → II
Yes
Phrynosoma platyrhinos
0 → II
No
desert horned lizard
Phrynosoma spp.
horned lizards
0 → IINo
Tiliqua adelaidensis
bluetongue lizard
III → I
Yes
Epicrates inornatus
Puerto Rican boa
I → IIYes
Crotalus horridus
timber rattlesnake
0 → II
No
Chelus fimbriata, C. orinocensis
0 → II
Yes
Amazon matamata
Macrochelys temminckii, Chelydra
III → II
No
serpentine
snapping turtle
Graptemys 5 spp.
map turtle
III → II
No
Batagur kachuga
roofed turtle
II → I
No
Cuora galbinifrons
box turtle
II → I
Yes
Rhinoclemmys spp.
wood turtles
0 → IINo
Claudius angustatus
musk turtle
0 → II
No
Kinosternon spp.
mud turtles
0 → I,IINo
Staurotypus salvinii, S. triporcatus
0 → II
Yes
musk turtles
Sternotherus spp.
musk turtles
0 → II
Yes

2022/10/07 16:47

32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52

02表A5.indd 2

Apalone spp.
American softshell turtle
III → II
Nilssonia leithii
Leith’s softshell turtle
II → I
Centrolenidae spp.
glass frogs
0 → II
Agalychnis lemur
lemur leaf frog
0 → II
Laotriton laoensis
Laos warty newt
0 → II
Carcharhinidae spp.
requiem sharks
0 → II
Sphyrnidae spp.
hammerhead sharks
0 → II
Potamotrygon 7 spp.
stingrays
III → II
Rhinobatidae spp.
guitarfishes
0 → II
Hypancistrus zebra
zebra pleco
III → I
Thelenota spp.
sea cucumbers
0 → II
Flora spp.
plants annotation
Handroanthus spp., Roseodendron spp.,
0 → II
Tabebuia spp.
trumpet trees
Rhodiola spp.
stonecrops
0 → II
Afzelia spp.
African mahoganies
0 → II
Dalbergia sisso
Indian rosewood
II → 0Dipteryx spp.
cumarus
0 → II
Paubrasilia echinata
Brazilwood
II → I
Pterocarpus spp.
African rosewoods
0 → II
Khaya spp.
African mahoganies
0 → II
Orchidaceae spp.
orchids annotation

No
No
No
Yes
Yes
No
No
No
No
No
No
Yes
No
Yes
No
Yes
No
No
No
No
Yes

2022/10/07 16:47

RECOMMENDATIONS
Prop. Transfer of the common hippopotamus Hippopotamus amphibius fromII to Appendix I (Benin, Burkina Faso, Central African
1 Appendix
Republic, Gabon, Guinea, Liberia, Mali, Niger, Senegal, Togo)
The common hippopotamus is distributed in 38 countries in Africa. According to
the IUCN Red List, its population is stable. The species does not meet the
Appendix I listing criteria. The proponents admit that the species does not satisfy
the numerical guideline. Yet, the proponents stress the species meets the
Appendix I listing criteria, referring to Annex 5 “where numerical guidelines arecited in this Annex, they are presented only as examples, since it is impossible togive numerical values that are applicable to all taxa because of differences intheir biology.” GGT feels that this is an abuse of Annex 5. In those countries who
have witnessed the recent population decline, the main threat is civil war/unrest
causing illegal killing. This problem will not be solved by listing the species inAppendix I. In addition, CITES has nothing to do with other threats such ascommercial development, agriculture and dam construction. These must be
solved domestically. Eastern Africa and Southern Africa are strongholds for the
species. It seems the proponents have consulted other range States but theresults are not clear, in particular from these stronghold countries. The
hippopotamus is totally protected in 14 range States, out of which Burkina Faso,
Central African Republic, Gabon, and Niger are the co-proponents of the
proposal. These countries should strengthen their enforcement activities. Under
the circumstances, the proposal should be rejected.
Prop. Transfer of the Namibian population of the southern white rhinoceros
simum simum from Appendix I to Appendix II
2 Ceratotherium(Botswana, Namibia)
The white rhinoceros consists of two subspecies, Ceratotherium simum simum
and C. s. cottoni. The latter, northern white rhinoceros, is almost extinct with only
two females left. The former, southern white rhinoceros had been extirpated frommost of the range States including Namibia. However, South African remaining
population became subject to protection and has increased rapidly. Rhinos havebeen reintroduced from South Africa to Namibia, Botswana, Zimbabwe,
Mozambique and Eswatini. Sixteen rhinos were reintroduced from South Africa
to Namibia in 1975 and the population has since then increased up to more than
1,200. The species as a whole does not meet the Appendix I listing criteria, nor
Namibia’s population. The population has increased substantially, not because of
CITES but because of Namibia’s effort. Such efforts must be rewarded. The
number of rhinos killed illegally has increased recently but it is negligible

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compared to the total number of animals protected. The proposal aims to export
live animals and hunting trophies. Live animals are to be exported for in-situ
conservation purposes. Without approving this proposal, the integrity of CITES
would be questioned. The proposal should be adopted.
Prop. Amendment of the annotation for the Eswatini population of the
3 southern white rhinoceros Ceratotherium simum simum (Eswatini)

The white rhino populations of South Africa and Eswatini are listed in Appendix IIwith annotation. Eswatini’s population was transferred from Appendix I toAppendix II at CoP13 with annotation. Eswatini submitted proposals for CoP17
and CoP18 aimed at an international trade in rhino horns. The proposals were
rejected. Eswatini’s intention was to sell rhino horns coming from the stockpiles
and horns from non-lethal harvesting. It should be pointed out that mostpopulations of the vicuna (Vicugna vicugna) were transferred from Appendix I toAppendix II allowing international trade. The acquisition of rhino horns will also
be conducted in a non-lethal way. Eswatini’s rhino populations occur in one
national park and one game reserve. In addition, it intends to introduce rhinos to
one wildlife sanctuary. These three protected areas are not financed by theGovernment. They need to be self-financed. By using proceeds from sellingrhino horns, Eswatini wishes to enhance its effort to conserve its rhino
population. It is necessary for this proposal to be adopted, in particularconsidering the recent COVID-19 pandemic which has affected the tourism
destined for the two protected areas. Listing rhinos in Appendix I has proven to
be a failure and innovative approaches need to be taken. This proposal is one ofsuch approaches and as such, it should be adopted. The adoption of the
proposal is in the best interest of the conservation of the species as well as of
biodiversity. Those who oppose this proposal are encouraged to provide
Eswatini with financial assistances.
Prop. Amendment of the annotation for the African elephant Loxodonta
populations of Botswana, Namibia, South Africa and
4 africana
Zimbabwe (Zimbabwe)
The African elephant was transferred from Appendix II to Appendix I at its
seventh meeting of the Conference of the Parties (Lausanne, 1989) despite thegeneral recognition that some of the southern African populations did not meet
the Appendix I listing criteria. The elephant populations of Botswana, Namibia
and Zimbabwe were transferred to Appendix II in 1997 and South African
population in 2000. The Conference of the Parties should have supported the
proposals submitted by southern African countries without any conditionattached. The present proposal aims to delete some sub-paragraphs of theannotation. If this proposal is adopted, the four countries, i.e., Botswana,
Namibia, South Africa and Zimbabwe will be able to export their stockpiled
ivories from natural mortality and problem animal control. If this is the case, it will
be in the best interest of the conservation of the African elephant and will be in
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line with the original intent of CITES. GGT welcomes this proposal andrecommend that it be adopted. Continuing to reject their proposals is thepunishment for the conservation success of southern African countries.
Prop. Transfer of the populations of the African elephant Loxodonta africana
Botswana, Namibia, South Africa and Zimbabwe from Appendix II to
5 ofAppendix I (Burkina Faso, Equatorial Guinea, Mali, Senegal)
Most parts of the document are identical to those of the unsuccessful proposals
submitted in the past. The plight now faced by African elephants started in 1989
when the Conference of the Parties adopted a transfer of the species as a wholefrom Appendix II to Appendix I despite the unanimous recognition that southern
African populations did not meet the Appendix I listing criteria. Those who
supported an Appendix I listing need to take the responsibility because thatdecision brought about the present situation. The elephant populations of
Botswana, Namibia and Zimbabwe were transferred back to Appendix II in 1997
and that of South Africa in 2000. Subsequently, international ivory trade took
place twice, but both were ‘one-off trade’. This decision exacerbated the situation
because such trade precluded a possibility of establishing a long-term
management strategy. According to the supporting statement, if all Africanelephant populations are considered as a whole, the species meets the
Appendix I listing criteria. At the same time, the proponents admit that individual
country populations may be listed separately in Appendix II. However, theproponents argue that split-listings should be avoided referring to the listing
criteria: “Listing of a species in more than one Appendix should be avoided ingeneral in view of the enforcement problems it creates”. The history of CITES,
however tells us that ‘split-listings’ was beneficial to many species including
vicuna and crocodiles. For example, the Nile crocodile populations of Kenya andEthiopia are listed in Appendix II, creating ‘split-listings’ for the species. If ‘splitlistings’ works negatively, their populations should be transferred to Appendix I.
Furthermore, the proponents make a reference to Resolution Conf. 9.24 Annex
4: “By virtue of the precautionary approach and in cases of uncertainty regarding
the status of a specie or the impact of trade on the conservation of a species, theParties shall act in the best interest of the conservation of the species concerned
and, when considering proposals to amend Appendix I or II, adopt measures thatare proportionate to the anticipated risks to the species”. It should be stressedthat this paragraph does not mean that in cases of uncertainty, international
trade should not be permitted. On the contrary, the best interest of theconservation of the African elephant can be achieved through allowinginternational trade in ivory with an annual export quota. By allowing ivory tradeon a regular basis, exporting countries will be able to establish more pragmatic,
long-term elephant conservation programmes, which is indeed in the bestinterest of the conservation of the African elephant. There should be clear
recognition that there are two different groups of countries, the one who failed toconserve elephants and the other who succeeded. By submitting this kind of
proposal repeatedly, the former’s country group is asking the latter to adopt the
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wildlife policy that proved to have been failed. In conclusion, there is no
justification for transferring the elephant populations of Botswana, Namibia,
South Africa and Zimbabwe to Appendix I. The proposal should be rejected. It isinteresting to note that the proponents mention that “if IUCN’s formal recognitionof savanna and forest elephants as two separate species is transposed in the
CITES Appendices, there are concerns that this taxonomic update could
potentially spur proposals within CITES to reopen the international commercial
trade in savanna African elephant ivory trade…” The proponents clearlyrecognize that the elephant status varies from country to country.
Prop. Transfer of the Mexican prairie dog Cynomys mexicanus from
6 Appendix I to Appendix II (Mexico)
The Mexican prairie dog is endemic to Mexico. This species has been listed inAppendix I since 1975. The species is fully protected under Mexico’s legislation.
In relation to the Periodic Review process, Mexico explained its review result on
the species and recommended the transfer from Appendix I to Appendix II, which
Animals Committee endorsed (AC31, online). Accordingly, this proposal was
submitted for consideration at CoP19. It is unlikely that an Appendix II listing willcause any negative impact on the survival of the species because any
commercial use is not anticipated. The proposal should be adopted.
Prop. Transfer of the Aleutian cackling goose Branta canadensis leucopareia
7 from Appendix I to Appendix II (USA)The Aleutian cackling goose Branta canadensis leucopareia used to beconsidered a subspecies of the Canada goose Branta canadensis and has been
listed in Appendix I since 1975. The Canada goose Branta canadensis was split
into two different species based on taxonomic studies, the Canada goose B.
canadensis and the cackling goose B. hutchinsii. The cackling goose comprises
5 subspecies including this subspecies B. hutchinsii leucopareia. The proposal
was submitted as a result of the Periodic Review of the Appendices. This
subspecies breeds on the Aleutian and Semedi Islands and winter mainly in thewestern part of the US. This population is thriving and subject to hunting. A small
population was reintroduced in the Kuril Islands thanks to the joint efforts by US,
Japan and Russia and approximately 5,000 birds winter in northern Japan where
the Aleutian cackling goose is totally protected. A transfer of the subspecies toAppendix II will not cause any negative impact and as such, the proposal should
be adopted. The proponent may wish to consider a possibility of deleting the
Aleutian cackling goose from CITES Appendix II in the future.
Prop. Inclusion of the white-rumped shama Kittacincla malabarica in
8 Appendix II (Malaysia, Singapore)

The white-rumped shama is widely distributed in southern Asia from India
through Thailand to Indonesia. This species is a popular cage bird due to its
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singing ability. According to the supporting statement, it seems that several
range States have regulations on domestic trade and border control. Although it
seems unlikely that this species is facing a risk of extinction, there have been
many seizure incidents. Listing in Appendix II would facilitate the monitoring ofcross-border trade. GGT recommends that the proposal be adopted.
Prop. Transfer of the straw-headed bulbul Pycnonotus zeylanicus from
9 Appendix II to Appendix I (Malaysia, Singapore, USA)

As is the case with the white-rumped shama (Prop. 8), this is one of the mostsought-after species for cage birds. The population is in decline. Historically, thestraw-headed bulbul occurred in Myanmar, Thailand, Malaysia, Brunei
Darussalam, Singapore and Indonesia. It is believed that the species is now
extinct in Thailand and Myanmar. The main threats are trapping for the cage-birdtrade and habitat loss. Most of the range States are supportive of the proposal.
GGT recommends that the proposal be adopted. However, it should be notedthat an Appendix I listing by itself may not solve the problem. What is needed is
to strengthen enforcement activities by all range States. This could be done
without transferring the species to Appendix I.
Prop. Transfer of the short-tailed albatross Phoebastria albatrus from
10 Appendix I to Appendix II (USA)This proposal was submitted as a result of the Periodic Review of the
Appendices. This species is found in the northern Pacific Ocean. It breeds
mainly on Torishima Island, Japan. The population of Torishima Island was
believed to be extirpated a century ago caused by feather harvests. After thenesting population was rediscovered, a series of conservation measures havebeen taken leading to the recovery of the species. The population size is now
estimated more than 5,000 including breeding individuals. The major threats are
erosion and volcanic eruption on Torishima Island as well as oceancontamination. To avoid erosion, Miscanthus grasses have been planted.
Another conservation activity includes the translocation of albatross chicks to
Mukojima Island. These conservation programmes have been effectively
implemented. In Japan, the short-tailed albatross is a fully protected species.
Even if the species is transferred from Appendix I to Appendix II, any negative
impact is not foreseen. Rather, such a transfer is considered to be aconservation success. The proposal should be adopted.
Prop. Transfer of the Brazilian population of the broad-snouted caiman
11 Caiman latirostris from Appendix I to Appendix II (Brazil)

The broad-snouted caiman is distributed in Argentina, Bolivia, Brazil, Paraguay
and Uruguay. The species is listed in Appendix I except the population ofArgentina which is listed in Appendix II. The population of Brazil is large anddoes not meet the Appendix I listing criteria. There are five commercial farms in
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Brazil producing broad-snouted caimans, one of which is registered with the
CITES Secretariat. An Appendix II listing will enable the remaining four farms toexport the products. However, they can also export the products withouttransferring to Appendix II if registered with the Secretariat. It is not clear fromthe supporting statement how an Appendix II listing would be beneficial to wild
populations. According to the supporting statement, it seems that Brazil will notallow the export of ranched or wild harvested specimens. Ranching is more
beneficial to the species from a conservation point of view than farming andharvesting in the wild. This possibility should be pursued in the future. In
conclusion, GGT sees no rationale behind this proposal at the moment and assuch, the proposal should be rejected.
Prop. Transfer of the Palawan population of the saltwater crocodile
porosus from Appendix I to Appendix II with a zero quota
12 Crocodylus
for wild specimens (Philippines)
The species is distributed from India through Indonesia to Vanuatu. The
populations of Australia, Indonesia, Malaysia and Papua New Guinea are listed
in Appendix II. Other populations are listed in Appendix I. The species as a wholeis abundant and does not meet the Appendix I listing criteria. The Crocodile
Farming Institute (CFI, current Palawan Wildlife Rescue and Conservation
Center) was established in Puerto Princesa on Palawan in 1988 as a joint
venture between the Philippines and Japan. Since its inception, CFI has
conducted studies on crocodiles in the Philippines and captive breeding
technique. These efforts led to successful breeding in captivity and population
increase in the wild. The population of Palawan does not meet the Appendix I
listing criteria and should be transferred to Appendix II. The approval of the
proposal is the first step towards ranching programmes, thus creating incentives
for local communities to tolerate human-crocodile conflicts. GGT recommends
that the proposal be adopted. It should be pointed out that CFI has contributed
to the conservation of C. porosus and more importantly, C. mindorensis. In thisregard, the governments of both the Philippines and Japan should becommended.
Prop. Transfer of the Thai population of the Siamese crocodile Crocodylus
from Appendix I to Appendix II with a zero quota for wild
13 siamensis
specimens (Thailand)
The Siamese crocodile is distributed in Cambodia, Indonesia, Lao PDR,
Thailand and Viet Nam. The total population in Thailand is estimated to be morethan 100. Most of them are found within protected areas. There are a large
number of crocodile farms in Thailand and 29 farms are registered with the
CITES Secretariat as producing the Siamese crocodile in captivity. In addition,
approximately 900 facilities are keeping the Siamese crocodile. At CoP 16(Bangkok, 2013), Thailand submitted a proposal similar to the present proposal,
which was rejected at Committee I and Plenary. The extant range States, i.e.,
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Cambodia, Indonesia, Lao PDR, Thailand and Viet Nam were all supportive of
the proposal. The approval of the proposal will enable unregistered farms toexport their products. Even though the Thai population is transferred to Appendix
II, wild populations will not be at risk. It is important to note that all the range
States supported the previous proposal in 2013. On condition that they maintaintheir positions, the proposal should be adopted. GGT is aware that the Thai
population of the Siamese crocodile does not meet the Appendix II listing criteria
because the population in the wild is very small. However, a large number of thecrocodiles are being kept in captivity and this should be taken into consideration.
Prop. Inclusion of Indo-Chinese water dragon Physignathus cocincinus in
14 Appendix II (EU, Viet Nam)

The species is distributed in China, Viet Nam, Lao PDR, Cambodia andThailand. It may also occur in Myanmar. The threats to the survival of thespecies include food consumption, pet trade and habitat loss and degradation.
Of these threats, international pet trade is a major concern. A large number oflive specimens were imported into US and EU. In China and Thailand, thespecies is protected under their laws. An Appendix II listing will help monitor
trade volume and enable range States to conduct NDF. Consultations have been
made with all range States, but it is unclear if they are supportive. On condition
that they support an Appendix II listing, the proposal should be adopted.
Prop. Inclusion of the Jeypore hill gecko Cyrtodactylus jeyporensis in
15 Appendix II (India)

The Jeypore hill gecko is endemic to Eastern Ghats, India and has beenrecorded from very few localities. Little is known of the population status andother biological aspects. Since it occupies a very small area of distribution,
threats such as commercial use, habitat loss and mining would have a negative
impact on the survival of the species. The species is not protected under Indian
law but the acquisition of the species requires prior permission. Live specimens
are being sold through internet advertisement outside India. An Appendix II
listing will enable Indian authorities to collect trade data, thereby taking
appropriate measures. The proposal should be adopted. Meanwhile, India
needs to expedite its process to include the species as protected under the Wild
Life Act.
Prop. Inclusion of the helmethead gecko Tarentola chazaliae in Appendix II
16 (Mauritania and Senegal)

The helmethead gecko is distributed in western North Africa, mainly in Moroccoand Western Sahara. The southernmost tip of the distribution is found in
Mauritania. It is unclear whether this species occurs in Senegal. Little is known
of its population status. However, it seems that the species meets the Appendix
II listing criteria. The proponents, i.e., Mauritania and Senegal have no regulation
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with regard to this species. International pet trade for this species does exist. It is
unknown if the proponents consulted Morocco. Conditional on Morocco’s
support, the proposal should be adopted.
Prop. Inclusion of the desert horned lizard Phrynosoma platyrhinos in
17 Appendix II (USA)The desert horned lizard is distributed in US and Mexico, occurring in desert
shrublands. In Mexico, it is marginally found in Baja California. The population isstable in most distribution areas. All range States within the US have regulations
prohibiting commercial collection of desert horned lizards. Even if the species islisted in Appendix II, much would not be gained. As such, the proposal should be
rejected. The species may be included in Appendix II as a result of the adoptionof Mexico’s proposal to include all Phrynosoma species (Prop. 18). In that case,the US is encouraged to be with vigilance in order to avoid any possible
smuggling through Mexico.
Prop. Inclusion of the horned lizards Phrynosoma spp. in Appendix II
18 (Mexico)

According to the supporting statement, the genus Phrynosoma comprises 21
species. The species in the genus Phrynosoma as a whole are found from
Canada to Mexico. The main distributional area is Mexico and the US. P.
blainvilii, P. corroense, P. coronatum and P. wigginsi are already listed inAppendix II. The proponent proposes to include P. asio, P. braconnieri, P.
modestum, P. orbiculare, P. platyrhinos, P. solare and P. taurus in Appendix II inaccordance with the Conf. 9.24 Annex 2a criterion. The inclusion of P.
platyrhinos in Appendix II is proposed by the US as well (see Prop.17). All other
Phrynosoma species are proposed for a look-alike reason. Some species do notoccur in Mexico. Mexico consulted Canada and USA but no response is provided
in the supporting statement. Several species are protected under Mexico’s
regulation. As is the case with Prop.17, the proposal should be rejected.
Prop. Transfer of the pygmy bluetongue lizard Tiliqua adelaidensis from19 Appendix III to Appendix I (Australia)
The pygmy bluetongue lizard is endemic to Australia and only found in the stateof South Australia. According to the supporting statement, the pygmy bluetongue
lizard has not been permitted to be exported live from Australia commerciallysince at least 1982. In addition, Australia has not permitted the exportation of live
specimens for non-commercial purposes since at least 2002. Nevertheless, live
bluetongue lizards in the genus Tiliqua are popular among reptile hobbyists in
Europe, North America, Southeast Asia and East Asia. Live specimens of thepygmy bluetongue lizard are found for sale on online advertisements, forinstance in Germany, UK, Russia and Japan. The major threats include
alteration of land use and agriculture activities. There is a fear that ongoing
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illegal trade may have a negative impact on the survival of the species. The
species has been listed in Appendix III since June 2022. It seems likely that the
species meets the Appendix I listing criteria and as such, the proposal should be
adopted.
Prop. Transfer of Puerto Rican boa Epicrates inornatus from Appendix I to
20 Appendix II (USA)The species is endemic to Puerto Rico. This proposal to transfer the species toAppendix II arises from Resolution on Periodic Review of the Appendices inaccordance with the decision made by the Animals Committee. The species is
considered a habitat generalist and widely found on Puerto Rico. The population
size throughout Puerto Rico is estimated to be more than 30,000. There seems
very few international trade if any. Since the species does not qualify for an
Appendix I listing, the proposal should be adopted.
Prop. Inclusion of the timber rattle snake Crotalus horridus in Appendix II
21 (USA)The timber rattle snake was historically distributed in the US and Canada. The
latter’s population seems to have been extirpated. The species is widely found in
the eastern part of US. The US submitted a proposal to include the species inAppendix II for consideration at CoP 10 (Harare, 1997). At that time, EU and
Switzerland did not support the proposal. They preferred an Appendix III listing
but nevertheless, the US did not list the species in Appendix III. According to the
supporting statement, the threats include road mortality, persecution, illegal
collecting and poaching and habitat loss and fragmentation. It seems unlikelythat international trade is a major threat. All other threats can be solved within
the US in co-operation with each State where the species occurs. Under thecircumstances, GGT recommends the proposal be rejected.
Prop. Inclusion of the matamata turtles Chelus fimbriata and C. orinocensis
22 in Appendix II (Brazil, Colombia, Costa Rica, Peru)

The genus Chelus comprises two species, C. fimbriata and C. orinocensis. The
former is widely distributed in the Amazon Basin and Mahury River drainage.
The latter has a more restricted distribution area. The threats include habitat loss
and fragmentation and international pet trade destined for EU and the US. Some
range States have regulations, prohibiting the export of matamatas but it seems
demand for pet trade is increasing. The proponents did not consult with otherrange States including Bolivia, Ecuador, Guyana and Venezuela. On condition
that these range States support the proposal, GGT recommends the proposal be
adopted.

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Prop. Transfer of the alligator snapping turtle Macrochelys temminckii andthe common snapping turtle Chelydra serpentina from Appendix III to
23 Appendix
II (USA)
These two species are endemic to the US and are already listed in Appendix III
at the request of the US. This proposal aims to transfer the two species from
Appendix III to Appendix II. The common snapping turtle is included for a lookalike reason. M. suwanniensis and M. apalachicolae, both endemic to the US,
are treated as synonyms of M. temminckii in the proposal. The major threats arehabitat loss and modification, harvest and collection, predation and fishingactivities. A large number of the two snapping turtles have been exported toChina, Hong Kong and Macao. Most of the common snapping turtle exported arethose born in captivity. According to the supporting statement, almost allexported M. temminckii specimens are taken from the wild. There is a large
discrepancy between the two species. More accurate data would be required. It
seems likely all range States within the US prohibit harvesting the alligatorsnapping turtle for commercial purposes. Also, most range States prohibit
personal harvest. GGT does not believe an Appendix II listing will solve theexisting problem and as such, the proposal should be rejected.
Prop. Transfer of five species of the broad-headed map turtles in the genus
24 Graptemys from Appendix III to Appendix II (USA)The genus Graptemys comprises 13 species. All species are already listed inAppendix III at the request of the US. The proposal aims to transfer five species
from Appendix III to Appendix II, i.e., G. barbouri, G. ernsti, G. gibbonsi, G.
pearlensi and G. pulchra. All these five species are endemic to the US. In
practice, there is no difference between Appendix III listing and Appendix II
listing. Considering the current Appendix III listing was made at the request of
the US, GGT sees no rationale to list them in Appendix II and as such, it isrecommended the proposal be rejected.
Prop. Transfer of the red-crowned roofed turtle Batagur kachuga from25 Appendix II to Appendix I (India)

The red-crowned roofed turtle is distributed in India and Bangladesh. The statusof the species is not clear but it is considered to be extinct in Bangladesh. The
species is already listed in Appendix II. The species is totally protected in India.
Under Indian law, hunting and collection of the species is prohibited, hence
export from India. Little is known of the level of illegal trade. Even if the species
is transferred to Appendix I, illegal trade would continue. What India needs is tostrengthen its enforcement activities. As such, the proposal should be rejected.

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Prop. Transfer of the Indochinese box turtle Cuora galbinifrons from26 Appendix II to Appendix I (EU, Viet Nam)
The Indochinese box turtle occurs in forested area of southern China, Lao PDR
and Viet Nam. This species was included in Appendix II at CoP11 (Gigiri, 2000),
together with other Cuora species. At CoP16 (Bangkok, 2013), Parties
established a zero quota on wild specimens for commercial purposes for thisspecies. Although little is known of the status, the population size seems verysmall. In China, Lao PDR and Viet Nam, the species is protected from
exploitation. Nevertheless, illegal trade both internally and internationally exists
in these range States. The Animals Committee is supportive of transferring thespecies to Appendix I and GGT feels that the proposal should be adopted.
However, an Appendix I listing would not improve the situation without efforts tostrengthen border control and internal enforcement.
Prop. Inclusion of the neotropical wood turtles Rhinoclemmys spp. in
27 Appendix II (Brazil, Colombia, Costa Rica, Panama)
The genus Rhinoclemmys consists of nine species. The species are distributedin Central and South America, ranging from Mexico to Brazil. The main threats tothese species are habitat destruction and fragmentation caused by development
activities. International trade has less negative impact on the species than otherintrinsic and extrinsic factors including domestic use. It seems that these species
are easy to be bred in captivity. An Appendix II listing would not contribute to theconservation and management of these species. Under the circumstances, theproposal should be rejected.
Prop. Inclusion of the narrow-bridged musk turtle Claudius angustatus in
28 Appendix II (Mexico)
This species is distributed in Belize, Guatemala and Mexico. The main threats
include illegal trade for meat consumption and habitat degradation. It seems
unlikely to prevent these threats from occurring even after listing in Appendix II.
The specimens are being exported legally and illegally for pet trade and meat
consumption. Mexico consulted Guatemala and Belize in March 2022 well inadvance of CoP19 but no response are provided in the supporting statement.
Most of the specimens exported from Mexico originate from captive breeding
facilities. It would be difficult to conclude that listing in Appendix II contribute to
the conservation of the species. According to the supporting statement, wild
specimens have been harvested and laundered as captive bred specimens. This
problem can be solved without including the species in Appendix II. Under thecircumstances, the proposal should be rejected.

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Prop. Inclusion of the mud turtles Kinosternon cora and K. vogti in Appendix
and other Kinosternon spp. in Appendix II (Brazil, Colombia, Costa
29 IRica,
EL Salvador, Mexico, Panama, USA)The genus Kinosternon comprises 22 species. These species are distributed
from US to Argentina. The proposal aims to include 20 Kinosternon species inAppendix II and two species (K. cora and K. vogti) in Appendix I. K. cora and K.
vogti are endemic to Mexico. Among these 22 species, 7 species are proposed
for inclusion in Appendix II for a look-alike reason. The major threats to thespecies in the genus are habitat destruction, human consumption and illegal
harvest for domestic and international pet trade. Other threats include theintroduction of invasive species, wildfires, water pollution and droughts.
According to the supporting statement, there seem to be captive breeding
facilities. The proponents are more concerned about K. cora and K. vogti thanother Kinosternon species. According to the supporting statement, it seems
difficult to distinguish between species. Listing these species in both Appendix I
and Appendix II would create difficulty for non-experts, thus obscuring theobjective of the proposal. The proposal should be rejected as it stands. The
proponents may wish to amend the proposal in order to include K. cora and K.
vogti in Appendix II, not in Appendix I.
Prop. Inclusion of the musk turtles Staurotypus triprocatus and S. salvinii in
30 Appendix II (El Salvador, Mexico)
The musk turtle S. triporcatus is distributed in Belize, Guatemala, Honduras and
Mexico. S. salvinii is distributed in Belize, El Salvador, Guatemala and Mexico.
Both species mostly occur in Mexico, Belize and Guatemala. The former is
proposed based on the Annex 2a criterion of Conf. 9.24 and the latter for a lookalike reason. According to the supporting statement, there are 14 facilities in
Mexico that are allowed to export captive bred specimens. International trade in
S. triporcatus is for meat consumption, mainly destined for China. Although
Mexico authorizes the export of captive bred specimens, illegal trade in S.
triporcatus does exist. Mexico consulted with other range States. El Salvador
agreed to become a co-proponent and Honduras supported the proposal.
However, these two countries do not represent the main distribution area. It is
not clear from the supporting statement if Belize and Guatemala are in favour ofthe proposal. Conditional on their support, GGT recommends the proposal be
adopted.
Prop. Inclusion of the musk turtles Sternotherus spp. in Appendix II (USA)31

The genus Sternotherus consists of six species, i.e., S. carinatus, S. depressus,
S. intermedius, S. minor, S. odoratus and S. peltifer. All species in the genus
Sternotherus are subject to this proposal. These six species are distributed in theeastern part of the US. S. odoratus is found in southern Canada as well. The
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main threat is habitat loss and degradation, followed by collection for pet trade. A
large number of live musk turtles have been exported primarily to East Asia.
Import, export and harvest of S. depressus is prohibited under US Endangered
Species Act. Some musk turtle species are protected at a State level. An
Appendix II listing of Sternotherus as a whole would help monitor trade volume
and assist range States within US in the implementation of their domestic
regulations. GGT recommends that the proposal be adopted.
Prop. Transfer of the softshell turtles Apalone spp. from Appendix III to
32 Appendix II (USA)This proposal aims to list three species in the genus Apalone (Florida softshellturtle A. ferox, smooth softshell turtle A. mutica and spiny softshell turtle A.
spinifera) in Appendix II. These three species were listed in Appendix III in 2016at the request of the US. The Florida softshell turtle is found in southeastern US.
The smooth softshell turtle is endemic to the US, with an introduced populationin France. The spiny softshell turtle occurs from Canada to Mexico. One
subspecies of the spiny softshell turtle, A. spinifera atra occurring in northern
Mexico is included in Appendix I. According to the supporting statement,“population trends are difficult to discern given the limited data available.” These
three species are already listed in CITES Appendices and most of the threats
can be mitigated through internal efforts. As such, GGT sees no justification forlisting the three Apalone species in Appendix II. The proposal should be
rejected.
Prop. Transfer of the Leith’s softshell turtle Nilssonia leithii from Appendix II
33 to Appendix I (India)

This species is endemic to India. It used to be abundant but has recently been in
decline severely. The main threats to the species are harvesting for meat andhabitat degradation such as development, pollution and sand mining. The
species is protected under the India’s Wild Life Act and is expected to be subject
to stricter regulations. According to the supporting statement, no legal traderecords are available for the species. This means that all international trade isillegal. Even though the species is transferred from Appendix II to Appendix I,
this situation would not change. As GGT does not see any merit by listing thespecies in Appendix I, the proposal should be rejected.
Inclusion of the glass frogs Centrolenidae spp. in Appendix II
Prop. (Argentina, Brazil, Costa Rica, Cote d’Ivoire, Dominican Republic,
34 Ecuador, El Salvador, Gabon, Guinea, Niger, Panama, Peru, Togo,
USA)
The proposal aims to include in Appendix II all species in the family
Centrolenidae comprising 158 species. Out of 158 species, 12 species areproposed in accordance with the Annex 2a of Conf. 9.24 criteria. Other 146
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species are for a look-alike reason. Glass frogs are found from Mexico throughBrazil to Argentina. The major threats include habitat loss and fragmentation,water pollution and climate change. The chytrid fungi are another concern. The
proponents propose to include in Appendix II 12 species which are ininternational trade. Although these species may meet the trade criteria to someextent, it seems unlikely that they meet the biological criteria. Consultations weremade with range States. It is unclear from the supporting statement if range
States are supportive of the proposal. However, many range States declined to
become a co-proponent of the proposal. These include Mexico, Guatemala,Belize, Nicaragua, Colombia, Venezuela and Guyana. In conclusion, there is no
justification for listing 158 species in Appendix II. The proposal should be
rejected.
Prop. Inclusion of the lemur leaf frog Agalychnis lemur in Appendix II with a
35 zero annual export quota (Colombia, Costa Rica, EU, Panama)
The lemur leaf frog is distributed in Costa Rica, Panama and Colombia. The
species has recently experienced significant decline due to chytridiomycosis.
The population of Costa Rica has been almost extirpated. In Colombia, thespecies has a restricted area of distribution in the northern part bordering withPanama. Even in Panama, the species witnessed extensive declines. Habitat
loss and fragmentation are considered to be other threats. More abundantspecies in the genus Agalychnis are already listed in Appendix II. All range
States are the proponents of the proposal. GGT recommends that the proposal
be adopted.
Prop. Inclusion of the Lao warty newt Laotriton laoensis in Appendix II (EU)36

The species is endemic to Lao PDR and occurs north of Vientiane. The species
may be locally abundant but has a restricted area of distribution. The mainthreats include collection for international pet trade, traditional medicine andmeat consumption. Habitat loss and degradation is considered another threat.
The species was newly described in 2002. Since then, the species has attracted
attention from commercial collectors. The species has been protected in Lao
PDR since 2008. Nevertheless, the species is offered for sale in UK, Germany,
the US, China, Korea and Japan. According to the supporting statement, Lao
PDR is the co-proponent of the proposal. If this is the case, GGT has no
objection to the proposal and recommends it be adopted.
Prop. Inclusion of Carcharhinidae spp. in Appendix II (Bangladesh,
Dominican Republic, Ecuador, El Salvador, EU, Gabon,
37 Colombia,
Israel, Maldives, Panama, Senegal, Seychelles, Sri Lanka, Syria, UK)
At the outset, it should be pointed out that this proposal has a procedural flaw.
Panama as the original proponent of the proposal asked the CITES Secretariat
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to issue a Notification dated 30 May. The Secretariat issued a Notification (No.
2022/043) and invited all range States to submit their responses to the
Notification by 10 June to Panama’s Management Authority. According to
Resolution Conf. 8.21 (Rev. CoP16), the proposing Party needs to consult withrange States on the substance of the proposal prior to the submission. This musttake place before the submission of the proposal to the Secretariat. Where priorconsultation does not take place, the proposing Party needs to submit the
proposal at least 330 days in advance of CoP 19. It is apparent that theseprocedures were not followed. In addition, 54 shark species are subject to this
proposal. As mentioned above, the Notification was issued on 30 May and range
States were asked to respond by 10 June, which means only less than two
weeks are available. It would be difficult to meet within this time period
considering the number of species subject to the proposal. Furthermore, it isregrettable that many Parties became a co-proponent of the proposal without
waiting for the outcome of FAO’s deliberation. One might say that they have theirown experts. However, it is doubtful that there are other experts more
knowledgeable than FAO’s experts. According to the result of the FAO Expert
Panel, it concluded that the proposal to list all 19 shark species in Appendix II
does not meet the CITES criteria as a single proposal. GGT recommends thatthe proposal be rejected. The reasons behind GGT’s recommendation are twofold. First, GGT believes that CITES is not an appropriate forum to deal withcommercially exploited marine species. The listing of many commercial fish
species, including not-endangered species for a look-alike reason, would create
unnecessary administrative burden on CITES authorities. There should be manyother species of higher priority. We should avoid easy applications of a look-alikeprovision. FAO and RFMOs are better suited for dealing with fisheries issues.
Secondly, the effectiveness of listing commercially exploited marine species
needs to be reviewed as a matter of urgency. Since CoP12 (Santiago, 2002),
many commercially exploited marine species, mainly sharks have been includedin Appendix II. Listing in Appendix II of marine species has faced manydifficulties including introduction from the sea and non-detriment findings. It
should be stressed that a large volume of these shark species are globallylanded for domestic and international markets. According to the operative
paragraph 9 of Resolution Conf. 9.24, the Conference of the Parties resolved“that, to monitor the effectiveness of protection offered by the Convention, thestatus of species included in Appendices I and II should be regularly reviewed by
the range States and proponents, in collaboration with the Animals Committee or
the Plants Committee, subject to the availability of funding.” Nonetheless, themonitoring of the effectiveness has not taken place. In addition to these
considerations, our concern is that there are many species subject to significant
international trade, including those among 35 look-alike species. The supportingstatement focuses on only 19 species. It is difficult to assess the ramification of
CITES listing.

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Prop. Inclusion of the hammerhead sharks Sphyrnidae spp. in Appendix II
38 (Brazil, Colombia, Ecuador, EU, Panama)
Three species in the family Sphyrnidae are already listed in Appendix II, i.e.,
Sphyrna lewini, S. mokarran and S. zygaena. There are the other six species in
the family Shyrnidae (Sphyrna tiburo, S. gilberti, S. tudes, S. corona, S. media
and Eusphyra blochii). The proposal aims to list the bonnethead S. tiburo in
Appendix II in accordance with the Conf. 9.24 Annex 2a criterion and all others inAppendix II for a look-alike reason. The three species already listed in Appendix
II are widely distributed throughout tropical and warm temperate seas. E. blochii
occurs on and near continental shelf waters of Indian and Pacific Oceans fromthe Arabian Gulf through south Asia to Australia and Papua New Guinea. The
other five species occur in the western Atlantic and eastern Pacific Oceans. The
FAO Expert Panel considered this proposal and concluded that these species
meet the Conf. 9.24 criteria. At the same time, however, the Panel pointed outthat some populations do not meet the criteria. The Expert Panel also noted thatbonnethead is often used for domestic consumption, yet the fins of bonnetheadare secondarily sold in the international fin trade. In other words, even if thespecies is listed in Appendix II, domestic consumption would continue andfishers might face difficulties in dealing with their fins acquired as fisheries
by-products. In addition, most of GGT’s views outlined for the previous proposal
can be applied to this proposal. As such, the proposal should be rejected.
Prop. Transfer of the freshwater sting rays Potamotrygon spp. from Appendix
39 III to Appendix II (Brazil)
The proposal aims to include two freshwater stingrays Potamotrygon wallacei
and P. leopoldi in Appendix II in accordance with the Conf. 9.24 Annex 2acriterion and other five Potamotrygon species for a look-alike reason. All of these
species are endemic to Brazil. These two species and the other five species are
already listed in Appendix III at the request of Brazil. They have been caught forornamental purposes. The threats include harvesting for trade, mining,
agricultural development, cattle grazing, dam construction and climate change.
The FAO Expert Panel concluded P. wallacei does meet the Conf. 9.24 criteria.
As for P. leopoldi, the majority of the Expert Panel concluded that the available
data did not provide adequate evidence that the species meets the Appendix II
listing criteria. The proposal provides little information on the five look-alikespecies and therefore it is difficult to grab overall situation. According to the
supporting statement, Brazil’s current legislation provides for a quota of fivestingray species including P. leopoldi and P. wallacei, a limit of maximum export
size. As mentioned above, all Potamotrygon species occurring in Brazil are
already listed in Appendix III. In practice, there is no difference between
Appendix III and Appendix II. What Brazil needs to do is to enhance its
management and enforcement activities. Under the circumstances, the proposal
should be rejected.

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Prop. Inclusion of the guitarfishes Rhinobatidae spp. in Appendix II (Israel,
40 Kenya, Panama, Senegal)
As is the case with Prop. 37, the proposal has a procedural flaw and for otherreasons similar to Prop. 37, the proposal should be rejected. The proposal aims
to list the family Rhinobatidae in Appendix II, six species of which are inaccordance with the Conf. 9.24, Annex 1, paragraph C criterion and 31 species
for a look-alike reason. Like Prop. 37, a large number of species are proposed
for inclusion in Appendix II. The family Rhinobatidae is widely and globally
distributed but each species shows a specific distribution pattern. According to
the supporting statement, the major threats are unsustainable capture andhabitat deterioration. The proponents mention that in many regions, guitarfish
meat is generally directed into domestic use and fins and skins are destined forinternational trade. As pointed out by the FAO Expert Panel, however, there is noevidence that international trade is a key driver of exploitation. The Expert Panelconcluded that these species do not meet the CITES listing criteria. It isinteresting to note that EU’s Scientific Review Group finds that the proposal does
not meet the required scientific standards. This bolsters GGT’s recommendation
to reject the proposal.
Prop. Transfer of the zebra pleco Hypancistrus zebra from Appendix III to
41 Appendix I (Brazil)
The zebra pleco Hypancistrus zebra was first described in 1991. It is endemic to
Brazil, occurring in the Amazon basin. This species was listed in Appendix III in2017 at the request of Brazil. It is known that smuggling does exist throughneighboring countries for ornamental fish market. According to the supportingstatement, the major threat to the species is the placement of hydroelectric dam.
The species is protected in Brazil and capture, transport, sale of wild specimens
and captive breeding in Brazil are prohibited. It seems that the species caneasily be reproduced in captivity. According to the supporting statement, they arecommercially reproduced in Indonesia, Czech and Ukraine. The proposal ispoorly documented. Little information is provided in the supporting statement on
population size and trend. Under Brazil’s law, the species is protected and isalready listed in Appendix III. In addition, listing in Appendix I would create
serious problems to already established captive breeding facilities outside Brazil.
The FAO Expert Panel concluded that the species does not meet the Appendix I
listing criteria. Under the circumstances, the proposal should be rejected. Brazil
may wish to develop the project aimed at captive breeding of the species inquestion.
Prop. Inclusion of the sea cucumbers Thelenota spp. in Appendix II (EU,42 Seychelles, USA)The genus Thelenota comprises three species which are all subject to this
proposal. T. ananas and T. anax are distributed in Indian and Pacific Oceans. T.
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rubrarineata is distributed in Pacific Ocean. The species have been subject tocommercial exploitation for international trade. Little is known of their population
size and trade status and it is difficult to judge the appropriateness of CITES
listing. The FAO Expert Panel concluded that the three species are not qualified
for an Appendix II listing. As such, this proposal should be rejected.
Prop. Amendment of the annotation for flora species including Orchidaceae
43 listed in Appendix I (Canada)This proposal was submitted by Canada, chair of the Standing Committee, in
accordance with the consensus recommendation made by the Standing
Committee at SC74 (Lyon, 2022). At SC74, the Working Group on Annotations
recommended amendments to the annotations and this was endorsed by SC.
The proposal should be adopted.
Prop. Inclusion of the trumpet trees Handroanthus spp., Roseodendron spp.
44 and Tabebuia spp. in Appendix II (Colombia, EU, Panama)
The target species of this proposal are Handroanthus serratefolius and H.
impetiginosus. In addition, the proponents propose to include other 111 species
belonging to the genera Handroanthus, Tabebuia and Roseodendron for a lookalike reason. H. serratefolius is widely distributed in Bolivia, Brazil, Colombia,
Ecuador, French Guiana, Guyana, Peru, Suriname, Trinidad and Tobago andVenezuela. The species were also introduced in Cuba and Puerto Rico. H.
impetiginosus is distributed in Argentina, Bolivia, Brazil, Colombia, Costa Rica, El
Salvador, French Guiana, Guatemala, Honduras, Mexico, Nicaragua, Panama,Paraguay, Peru, Suriname and Venezuela. The main threats are deforestationand logging for domestic and international trade. It is extremely difficult andalmost impossible to distinguish these 113 species’ timber. This is the reason
why the proponents included the three genera. It is doubtful that listing 113
species in Appendix II would contribute to the conservation and sustainable useof these species. There are only four range States which responded to theconsultation. If the proposal is adopted, the most impacted range States would
be Brazil. Nevertheless, Brazil’s position is unclear. Under the circumstances, it
is recommended that the proposal be rejected. There seems to be someregulations in range States in relation to logging and product export. Suchregulations need to be strengthened and uniformed among range States inparticular with regard to international trade.
Prop. Inclusion of the stonecrops Rhodiola spp. in Appendix II (China, EU,
45 Ukraine, UK, USA)The proposal aims to list two species in the genus Rhodiola (R. rosea and R.
crenulata) in accordance with the Conf. 9.24 Annex 2a criteria and all otherRhodiola species (56 species) for a look-alike reason in Appendix II. While R.
rosea is a widely distributed circumpolar species, R. crenulata occurs only in
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Nepal, India, Bhutan and China. Rhodiola species have long been utilized for
traditional medicine and recently started being utilized commercially. Several
Rhodiola species have been cultivated experimentally but most of the Rhodiola
species are being harvested from the wild. According to the supportingstatement, overcollection for commercial use is the most prominent threat totrade species. In considering the wide distribution of these species and expected
future growth in the market, an Appendix II listing could help monitor tradevolume, thus assisting range States in establishing more appropriate
management measures. GGT recommends the proposal be adopted.
Prop. Inclusion of African populations of the pod mahoganies Afzelia spp. in
46 Appendix II (Benin, Cote d’Ivoire, EU, Liberia, Senegal)
Species in the genus Afzelia are distributed in sub-Saharan Africa and Southeast
Asia. This proposal aims to include four species (A. africana, A. bipindensis, A.
pachyloba, A. quanzensi) in Appendix II in accordance with the Conf. 9.24 Annex
2a criterion and other three species (A. bella, A. parviflora, A. peturei) for a lookalike reason. These tree species are being used for a variety of purposes,
ranging from construction materials to firewood. The major threat to these tree
species is logging for international timber trade. Additional threats include habitat
loss, harvest for fuelwood, charcoal, livestock fodder and traditional medicine.
Out of 36 range States, approximately 10 range States support the proposal but
the positions of the rest of the range States are unknown. Unless most of therange States support the proposal, GGT recommends the proposal be rejected.
Prop. Deletion of the North Indian rosewood Dalbergia sissoo from Appendix
47 II (India, Nepal)

The species is native to Afghanistan, Bangladesh, Bhutan, India, Iran, Iraq,
Myanmar, Nepal, Pakistan, Philippines and South Africa. It has been introduced
to many other countries including Israel, Australia and US. This tree species isvery popular for plantation and easy to propagate artificially. The species was
included in Appendix II at CoP17 (Johannesburg, 2016) as a result of the
inclusion of the genus Dalbergia. Deletion of the species from Appendix II willremove administrative burdens from the authorities. GGT welcomes this initiativeand recommends that the proposal be adopted.
Prop. Inclusion of the cumarus Dipteryx spp. in Appendix II (Colombia, EU,
48 Panama)
The genus Dipteryx comprises 14 species, which are widely distributed inCentral and South America. Their range States include Venezuela, Brazil,
Colombia, Cost Rica, Ecuador, French Guiana, Guyana, Honduras, Nicaragua,
Panama, Paraguay, Peru, Bolivia and Suriname. In addition, they may havebeen introduced to Bahamas, Dominica and Trinidad and Tobago. The proposal
aims to include four species (D. alata, D. micrantha, D. odorata and D. oleifera)
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in Appendix II in accordance with the Conf. 9.24 Annex 2a criterion and other 10
species for a look-alike reason. Little is known of population size and population
trend. Regulations have been put in place in many range States in terms oflogging and log export. Among many threats, it seems that the main threat is the
expansion of agricultural activities. According to the supporting statement, aconsultation was distributed by EU to all range States in December 2021.
However, none of the responses are available in the document and as such, it isdifficult to know if range States are in favour of the proposal, except two
co-proponents, Colombia and Panama. Unless most of the range States support
the proposal, GGT recommends the proposal be rejected.
Prop. Transfer of the Brazilwood Paubrasilia echinata from Appendix II to
49 Appendx I (Brazil)
The Brazilwood is endemic to Brazil and has already been listed in Appendix II.
Brazil proposes to transfer the species from Appendix II to Appendix I. The
Brazilwood is mainly utilized for bows for musical instruments. According to the
supporting statement, finished bows are exempted from CITES permit. Brazil’s
laws prohibit the exploitation of this species from the wild but illegal trade is still
rampant. GGT does not feel that a transfer to Appendix I will solve the problem
and recommends that the proposal be rejected. Rather, Brazil should strengthen
its enforcement activities. Without transferring to Appendix I, Brazil may wish toconsider the inclusion of the annotation as suggested in the proposal.
Prop. Inclusion of African populations of the padauks Pterocarpus spp. in
50 Appendix II (Cote d’Ivoire, EU, Liberia, Senegal, Togo)

The proponents propose to list all Pterocarpus species occurring in Africa inAppendix II. P. erinaceus and P. tinctorius are already listed in Appendix II. The
proponents admit that enforcement and customs officers are unlikely to be able
to reliably distinguish African Pterocarpus species. Even if these species arelisted in Appendix II, GGT does not feel that it will solve the problem. There aremany regulations and protocols established nationally and at a regional level. As
mentioned above, the two species have been listed in Appendix II. The
proponents may wish to assess the efficacy of listing the two species inAppendix II, which is not clear from the supporting statement. A consultation wasmade with all range States. Some support the proposal but most range States’
positions are not clear. Under the circumstances, it is recommended that the
proposal be rejected. It is imperative that each range State strengthens forest
management and border control.
Prop. Inclusion of African populations of the African mahoganies Khaya spp.
51 in Appendix II (Benin, Cote d’Ivoire, EU, Liberia, Senegal)
The genus Khaya comprises six species. The proposal aims to include African
populations of these six species in Appendix II. Other populations introduced into
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outside Africa are exempted from the proposal. Although little is known of theoverall population size and trend, the populations of these species seem to be in
decline. There are various threats to these species ranging from logging totraditional medicinal use. According to the supporting statement, legislative
measures are in place in many range States, i.e., Angola, Benin, Burkina Faso,
Cameroon, CAR, Chad, Comoros, Congo, Cote d’Ivoire, Gabon, Gambia,
Ghana, Guinea, Guinea-Bissau, Liberia, Malawi, Mali, Mozambique, Nigeria,
Senegal, Sierra Leone, Togo, Tanzania and Zambia. Strengthening legislationand its enforcement would be more required rather than listing these six species
in Appendix II. Under the circumstances, GGT recommends that the proposal berejected. Many proposals on timber species were submitted for consideration at
CoP19 under EU’s initiative (i.e., Prop.44, 46, 48, 50 and 51). GGT is concernedthat listing these species in Appendix II would create administrative burdens todeveloping countries.
Prop. Amendment of the annotation for the orchid Orchidaceae spp.
52 (Switzerland)
Under Annotation #4 to the listing of plant species, several parts and derivatives
are exempted from the application of CITES requirements. The proponent
proposes to amend the annotation by including the new paragraph: (g) finishedproducts packaged and ready for retail trade of cosmetics containing parts andderivatives of Bletilla striata, Cycnoches cooperi, Gastrodia elata, Pharaenopsis
amabilis or Phalaenopsis lobbii. GGT concurs with Switzerland that artificially
propagated orchids are globally traded on an enormous scale and pose noconservation risk to the species in the wild. The adoption of the proposal willremove the unnecessary administrative burden. The proposal should be
adopted.

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For the benefit of species and people( GGT ’s motto )A publication of the Global Guardian Trust. 2022
Global Guardian Trust
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Japan