EUROPEAN COMMISSION Brussels, 9.11.2022 SWD(2022) 354 final COMMISSION STAFF WORKING DOCUMENT



EVALUATION

of the EU action plan against wildlife trafficking Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS















Revision of the EU action plan against wildlife trafficking {COM(2022) 581 final} - {SWD(2022) 355 final}



Table of contents 1Introduction 1.1 Purpose and scope of the evaluation/fitness check 2What was the expected outcome of the intervention? 2.1 Description of the intervention and its objectives 2.1.1 Impacts of the illegal wildlife trade 2.1.2 EU and global policy on the illegal wildlife trade leading up to 2016 2.1.3 Challenges identified 2.1.4 The 2016 EU action plan against wildlife trafficking 2.2 Point(s) of comparison 3How has the situation evolved over the evaluation period? 3.1 The state of the illegal wildlife trade in the EU 3.2 Implementation of the action plan by priority 3.2.1 Priority 1 – Preventing wildlife trafficking and addressing its root causes 3.2.2 Priority 2 – Making implementation and enforcement of existing rules and the fight against organised wildlife crime more effective 3.2.3 Priority 3 – Strengthening the global partnership of source, consumer, and transit countries against wildlife trafficking 4Evaluation findings 4.1 To what extent was the intervention successful and why?

4.1.1 Effectiveness 4.1.2 Efficiency 4.1.3 Coherence 4.2 How did the EU intervention make a difference? 4.2.1 What is the European added value of the action plan, compared to what could have been achieved in its absence by Member States at national and/or regional levels, and by international organisations globally? 4.2.2 To what extent does the Plan comply with the principles of subsidiarity and proportionality? What has been the role of – and impact on – local and regional authorities? 4.3 Is the intervention still relevant? 4.3.1 To what extent is the action plan still relevant and to what extent do its (original) objectives still correspond to the needs within the EU? 4.3.2 How flexible has the Plan been in responding to new issues? 5What are the conclusions and lessons learned? 5.1 Conclusions 5.2 Lessons learned Annex I: Procedural Information Annex II: Methodology and Analytical models used Annex III:Evaluation matrix and, where relevant, details on answers to the evaluation questions (by criterion) Annex IV: Overview of benefits and costs [and, where relevant, Table on simplification and burden reduction] Annex V: Stakeholder consultation - Synopsis report Annex VI: Overview of progress in implementation of the action plan, by action





Glossary Term or acronym Meaning or definition CBD Convention on Biological Diversity CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora EG EU Wildlife Trade Enforcement Group EMPACT European Multidisciplinary Platform Against Criminal Threats EU European Union FLEGT Forest law enforcement, governance and trade IPBES Intergovernmental Platform on Biodiversity and Ecosystem Services ICCWC International Consortium on Combating Wildlife Crime SRG Scientific Review Group UNGA United Nations General Assembly UNTOC UN Convention on Transnational Organized Crime 11 Introduction 1.1 Purpose and scope of the evaluation/fitness check The EU action plan against wildlife trafficking (‘action plan’) was adopted in 2016, for the period 2016 to 2020. The Commission undertook an initial review of implementation of the action plan in 2018. The Commission then carried out a more extensive evaluation of the action plan in the course of 2021-2022. Both these studies feed into to the current exercise. The current evaluation covers action to combat the illegal wildlife trade undertaken by the European Union and its Member States since the adoption of the action plan. The evaluation seeks to assess the action plan by evaluating its effectiveness, efficiency, relevance, coherence, and EU added value. Due to its illegal nature, data on the illegal wildlife trade is not widely available. Any data that are available are not robust or complete. There is therefore a notable absence of a baseline against which to compare current action against wildlife trafficking. Moreover, the action plan is very broad and ambitious by its very design, encompassing a wide variety of actors and actions, and including objectives that are difficult to measure. Therefore assessing its achievements is challenging – especially due to the lack of a monitoring and evaluation framework. In addition, the action plan was adopted in the context of existing EU and Member State action against wildlife trafficking, seeking to raise ambitions and coordinate and equalise existing efforts within the EU. Where new actions have been undertaken, it is difficult to prove that they would not have occurred without the action plan. Taking these limitations into account, this evaluation draws on the implementation report, literature reviews, and a series of stakeholder consultations undertaken in 2021-2022. More detail on the findings of the evaluation can be found in the support study. 22 What was the expected outcome of the intervention? 2.1 Description of the intervention and its objectives 2.1.1 Impacts of the illegal wildlife trade A report presented by the United Nations Environment Programme (UNEP) at the 2nd United Nations Environment Assembly in 2016 outlined the environmental impacts of illegal trade in wildlife. The primary impact noted in the report was the drastic reduction of wild populations of the species being illegally traded, which, exacerbated by habitat reduction and other stressors, can threaten the long-term survival of species. The report notes that poaching was identified as the primary driver of these extinctions, which led to extinction of the black rhinoceros in 2011. The illegal wildlife trade can also have impacts beyond target species, as many hunting or harvesting methods can have detrimental impacts on populations of non-target species. In addition, the loss of wild fauna and flora linked to wildlife trafficking can change the patterns of entire ecosystems. For example, forest elephants are key seed dispersers, so if their numbers decline through poaching, forest regeneration is affected. The illegal trade in live animals and plants also bypasses sanitary, veterinary and health checks and raises the risk of spreading diseases and invasive species. This can have unexpected detrimental consequences for other species. The illegal wildlife trade and poaching also drives biodiversity loss within the EU, especially of high-value species that are already under significant pressure from habitat loss and overexploitation, such as certain species of birds, bears, and the European eel. Wildlife trafficking also has significant economic impacts. Firstly, it undermines the legal trade in wildlife. This legal trade is particularly important in regions and communities living close to nature. In these areas, sustainable use of local wildlife can: (i) generate economic benefits; (ii) create green jobs; (iii) reduce human-wildlife conflict; and (iv) foster a sense of ownership of local nature and biodiversity. Not only does wildlife trafficking affect the legal wildlife trade, but it can also impact other wildlife-based economies. In 2013, the World Bank estimated that tourism accounted for 2.8% of the GDP of sub-Saharan African countries. In certain biodiversity-rich countries such as Zimbabwe, Tanzania and Namibia, tourism was estimated in 2013 to account for more than 8% of GDP. In these countries, the loss of biodiversity and destruction of wildlife translate directly into economic losses. The illegal wildlife trade also has strong links with security. The low-risk/high-reward nature of wildlife trafficking creates a vicious cycle: the proceeds of wildlife crime are used to fund illicit activities, enable corruption, and weaken the rule of law. In turn, wildlife trafficking is enabled by increasingly empowered and complex criminal networks. Wildlife crime and security issues intersect in many ways. For example: (i) armed conflict is financially sustained through poaching and trafficking; (ii) the availability of weapons increases poaching activity and weakens enforcement; (iii) forced migration, particularly of pastoralist communities, can drive populations closer to wildlife, leading to potential human-wildlife conflict; and (iv) economic instability can deprive local populations of legitimate income, forcing them to resort to poaching or illegal trade in wildlife. 2.1.2 EU and global policy on the illegal wildlife trade leading up to 2016 Trade in wildlife is regulated at international level through the Convention on International Trade in Endangered Species (CITES Convention), a major international agreement that has been in force since 1975. The main added value of the Convention is the global protection it gives to animal and plant species through regulation of their international trade. The inclusion of a species in the CITES Appendices is often a very important step in raising public awareness of the fact that it is – or might become – endangered because of international trade. This can play an important role in reducing supply and demand for the species and keeping trade at sustainable levels. A CITES listing also creates an obligation for governments to control trade in the relevant products and seize them if they are traded in contravention of CITES provisions. In addition, with the level of global policy concern about the illicit wildlife trade arguably stronger now than at any time since the Convention entered into force, there is a strong focus on wildlife trafficking in the work of the CITES bodies. This focus can be seen in the adoption by the CITES Conference of Parties and by the CITES Standing Committee of targeted recommendations designed to address specific shortcomings in the implementation of the CITES Convention. The CITES Standing Committee is tasked with monitoring how these recommendations are implemented by the CITES parties and is empowered to adopt compliance measures, such as prohibiting trade in all CITES-listed products if there is a serious failure by a party to comply with its obligations. The EU has been an active member of CITES since 2015. Wildlife trade has been regulated at EU level since 1983. The main legal instruments for this are Council Regulation (EC) No 338/97, which incorporates CITES provisions into EU law, and the Commission Regulations implementing this Council Regulation. These ‘EU Wildlife Trade Regulations’ go beyond CITES in many respects, in particular by: (i) regulating trade in a number of species that are not listed under CITES; (ii) imposing stricter import controls for some species; and (iii) empowering the EU to suspend imports of species from exporting countries. Implementation of the EU Wildlife Trade Regulations is regularly monitored by the Commission in close cooperation with Member States. It is assessed through meetings with Member States (around 10 per year) which focus on the scientific, management and enforcement aspects of the legislation and on the implementation of the action plan (and previously of Commission Recommendation No 2007/425/EC, which identified a set of actions for the enforcement of Regulation (EC) No 338/97 on the protection of species of wild fauna and flora and was replaced by the 2016 action plan). Member States report every year to the Commission on seizures of – and trade in – specimens covered by Council Regulation (EC) No 338/97. The Commission analyses these data, partly with a view to detecting trade authorised in contravention of EU law. Member States also submit comprehensive implementation reports every 3 years on measures taken to fulfil their obligations under EU wildlife trade law and CITES. The EU and all its Member States are parties to the UN Convention against Transnational Organized Crime (UNTOC), which defines ‘serious crime’ as ‘conduct constituting an offence punishable by a maximum deprivation of liberty of at least four years (…)’ (Article 2(b)). In various high-level fora, before 2016, the EU and its Member States addressed the problem of illegal wildlife trade by making ‘illicit trafficking in protected species of wild fauna and flora involving organised criminal groups a serious crime, in accordance with their national legislation and Article 2(b) of [UNTOC]’. Under UNTOC, mutual legal assistance in investigations, prosecutions, and judicial proceedings, which may be essential for successful investigation and prosecution, can be requested for serious crimes.

In February 2014, the Government of the United Kingdom convened the London Conference on the illegal wildlife trade, which was attended by heads of state, ministers, and high-level representatives from the EU and 46 countries, including those countries most heavily impacted by poaching and illegal trade in wildlife. In a declaration, the conference participants undertook to take ‘decisive and urgent action’ to tackle the global illegal trade in wildlife. At a follow-up conference in Botswana a year later, participants adopted the Kasane Statement, reaffirming their determination to: (i) scale up their response to the global poaching crisis; (ii) adopt crucial new measures to tackle money laundering and other financial aspects of wildlife crime; (iii) engage relevant rural community groups; and (iv) engage further with the private sector, including logistics and transport companies. A major step forward in the strengthening of enforcement efforts worldwide was the creation in 2011 of the International Consortium on Combating Wildlife Crime (ICCWC). The ICCWC consists of the CITES Secretariat, Interpol, the United Nations Office on Drugs and Crime, the World Bank, and the World Customs Organization. The ICCWC pools the expertise of five international organisations on the basis that, by aligning their efforts, they could provide a catalyst for greatly improved global cooperation and capacity to combat wildlife and forest crimes. The key aims of the ICCWC include: (i) long-term capacity-building (i.e. adding and training staff to work in this area, including by promoting the use of modern investigative techniques, such as deoxyribonucleic acid or DNA analysis); and (ii) improving the international exchange of information and intelligence, and thus the coordination of enforcement efforts. The ICCWC has also provided support at the request of countries in specific emergency situations. The Commission is one of the main donors to the ICCWC. 2.1.3 Challenges identified The bulleted paragraphs in this section set out some of the challenges to implementing and enforcing rules to prevent the illegal trade in wildlife when the action plan was developed. The section is split in two: (i) challenges in enforcing existing rules in the EU; and (ii) challenges in supporting efforts to fight wildlife trafficking globally. (I)Challenges to implementation and enforcement of existing rules in the EU ·Uneven levels of implementation and enforcement throughout the EU One of the primary challenges that the 2016 action plan sought to address was the uneven implementation and enforcement of the rules governing trade in wildlife throughout the EU. In 2012, seizures of illegally traded wildlife specimens in three Member States accounted for 59% of total seizures. In comparison, the 18 Member States with the fewest number of seizures reported less than 6% of EU-wide seizures for the year. In addition, the severity of sanctions imposed on perpetrators of the illegal wildlife trade varied widely across the EU. In 2013-2014, the highest fine (EUR 250 000) was reportedly imposed for two cases of illegal collection of – and trade in – birds and bird eggs. In four Member States, however, the highest fines were less than EUR 1 000. Notably, one of these Member States issued the most CITES documents in 2013-2014, suggesting that the low sanctions are not related to the absence of trade in wildlife. ·Awareness and prioritisation Responses to the 2014 Commission stakeholder consultation highlighted the problem of low awareness of – and low priority given to – wildlife trafficking. The low priority given to wildlife trafficking is reflected in the shortage of staff and technical resources at national level. CITES management authorities are often understaffed; 61% of Member States reported fewer than 10 staff members spending anything between 10% and 100% of their time on CITES issues. The need for a larger budget and workforce has been consistently emphasised since 2009. Some Member States, including Croatia, Ireland, and Malta, specifically stated that the shortage of such resources makes it difficult to implement CITES. ·Capacity throughout the enforcement chain In 2013-2014, only 19 Member States had set up national specialised units for CITES-related enforcement. There is vast inconsistency in resource provision across Member States in: (i) specialised environmental and law-enforcement units; (ii) judicial police, (iii) environmental protection agencies; and (iv) specially appointed officers. According to the Commission’s 2013-2014 analysis of Member State seizure and trade reports, only 7 Member States had adopted national action plans for coordination and enforcement, and only 2 of these implemented long-term action plans (over 4 or more years). On the more positive side, 23 Member States both: (i) carried out regular in-country trader checks and risk and intelligence assessments; and (ii) cooperated with enforcement agencies in other Member States to investigate offences. However, between 2011-2012 and 2013-2014, 12 Member States reported no detailed information on significant cases of illegal trade or information on convicted illegal traders and persistent offences. ·Coordination within Member States The Commission found room for improvement in communication and information-sharing between Member State authorities within the same Member State. For example, enforcement authorities should pass on to their management authorities information on any discrepancies between the number of items in a permit and the number of items actually traded. This is to ensure that management authorities can accurately monitor and report on actual levels of trade. However, in the analysis of the 2013-2014 reports, only 50% of Member State enforcement authorities reported that such information had been exchanged. Questions therefore arise as to how these Member States can report accurately on levels of trade. From the 2013-2014 biennial reports, only nine Member States appear to have set up a national inter-agency or inter-sectoral committee on CITES. ·Capacity to fight organised wildlife crime The level of knowledge about the activity of organised criminal groups in the EU active in wildlife trafficking was low among experts on organised crime, related illicit financial flows, and related illegal online activities. Due to this lack of awareness, limited financial, staff, and specialist resources were allocated to regulating the wildlife trade, despite its complex and organised nature. This also led to challenges in prosecuting and sanctioning environmental crimes. ·Enforcement cooperation among Member States Although Member States met regularly through the CITES Enforcement Group and exchanged practical experience on enforcing EU legislation on the wildlife trade (e.g. via EU-TWIX), there was limited cooperation on specific cases and limited involvement of relevant EU coordination bodies such as Europol and Eurojust. According to the analysis of the 2013-2014 biennial reports, 11 Member States that reported that they had been involved in administrative measures, criminal prosecutions and other court actions provided no further details. Several Member States provided no information at all on enforcement cooperation. ·Enforcement cooperation with non-EU countries

Several cases illustrated the challenges in cooperating with non-EU countries on investigations of wildlife trafficking cases. These challenges included checking the legality of export permits, tracking the source of wildlife products, and investigating financial flows. Although some steps were taken to improve international cooperation – for example Operation COBRA III in 2015 – the Commission identified this as an area that needed strengthening. (ii) Challenges in the fight against wildlife trafficking globally ·Scale of EU support provided to developing countries In the 30 years prior to 2016, the EU committed over EUR 500 million for biodiversity conservation in Africa. The EU also supported a number of national and local projects working on natural-resource management, the rule of law, and governance. Although these initiatives brought some progress, the synergies between conservation, livelihoods of local populations, enforcement, and good governance were not always sufficiently exploited. In addition, the long-term sustainability of a number of projects remained fragile due to insufficient support by – and an insufficient sense of ‘ownership’ among – the national and local authorities (and sometimes among local populations). This fragility was exacerbated by a high dependence on external funding. ·Donor coordination EU support to developing countries often comes in addition to funding by Member States, non-EU countries, development banks and financial institutions. Close cooperation between donors and supported countries is critical to maximise impact, avoid overlap and ensure that the allocation of funds meets the needs and priorities identified by the countries themselves. ·Demand reduction Despite ongoing efforts to fight the illegal wildlife trade, by 2016, demand for unsustainably sourced wildlife products had been rising significantly for a decade. This growth in demand was accompanied by dramatic shifts in consumer dynamics. Among several examples of priorities, a need was identified for effective awareness-raising techniques leading to changes in consumer behaviour. ·Anti-corruption tools At its first session on 27 June 2014, the UN Environment Assembly adopted a resolution on illegal trade in wildlife. The resolution called on governments to ‘promote and implement policies of zero tolerance towards all illegal activities, including corruption associated with the illegal trade in wildlife’. In July 2015, the United Nations General Assembly (UNGA) Resolution on tackling illicit trafficking in wildlife called on member states to ‘prohibit, prevent, and counter any form of corruption that facilitates illicit trafficking in wildlife and wildlife products’. In practice, however, anti-corruption strategies in EU programmes of development support often did not include wildlife trafficking as a focus area. ·Diplomatic tools for more effective cooperation with relevant source, transit and market countries/regions Respondents to the Commission’s 2014 stakeholder consultation called for the EU to address wildlife trafficking more through its diplomatic contacts, including in high-level political dialogues with key countries such as China. They also called for a greater role for EU delegations and Member States’ diplomatic missions in addressing wildlife trafficking. Stakeholders were of the view that, given the vast diplomatic network of the EU, there was a need to channel available resources to ensure a comprehensive response to poaching and illegal wildlife trafficking. ·Using EU trade policy to support the fight against wildlife trafficking EU trade policy supports and promotes environmental objectives such as wildlife protection and combating wildlife trafficking. This is reflected in the EU’s international trade agreements. When negotiating these agreements, the Commission seeks to include substantial environmental provisions on trade in a specific chapter on trade and sustainable development. In January 2016, in a report on the generalised scheme of preference arrangements, the Commission highlighted shortcomings in some countries’ implementation of the CITES Convention (in particular, national legislation failing to ensure full implementation, insufficient reporting, and other specific issues), stressing that these should be addressed as a matter of priority. 2.1.4 The 2016 EU action plan against wildlife trafficking Recognising the role of the EU as an important end market, transit region, and source region, the 2016 action plan sought to scale up and better coordinate EU and Member State action against wildlife trafficking. The 2016 action plan had three priorities, each of which contained several objectives. These three priorities are discussed in the paragraphs below. For a more detailed diagram of the intervention logic, please see Annex II. For a list of actions under each objective, please see Annex VI. (1)Preventing wildlife trafficking and tackling its root causes The first objective under this priority aimed to reduce the demand for – and supply of – illegal wildlife products through actions ranging from awareness raising to strengthening restrictions on the ivory trade. The second objective under this priority was to engage rural communities in source countries to promote community management of conservation and support the development of alternative, sustainable livelihoods for communities living in – and adjacent to – wildlife habitats.

The third objective aimed to increase the involvement of the private sector, noting a need to engage with key economic sectors that facilitated trade in wildlife. Finally, the final objective identified the importance of tackling corruption associated with wildlife trafficking. (2)More effective implementation and enforcement of existing rules and the fight against organised wildlife crime The first objective under this priority addressed the uneven implementation and enforcement of legislation to prevent the illegal wildlife trade throughout the EU, including through identifying priority risks and improving compliance with EU legislation. The second objective under this priority aimed to build the capacity of enforcement authorities, through: (i) improving cooperation, coordination, and communication; (ii) improving the knowledge base of practitioners; (iii) improving training; and (iv) strengthening practitioner networks. The third objective under this priority was targeted at the links between wildlife trafficking and organised crime. To ensure cooperation among authorities and relevant expert agencies, the action plan called for a concerted effort to raise awareness of the clandestine and organised criminal nature of the illegal wildlife trade at political level among: (i) enforcement and prosecution officials; (ii) relevant specialists in organised crime and money laundering; and (iii) financial investigation units. As wildlife trafficking is usually an international crime, the fourth objective under this priority looked to strengthen international cooperation of enforcement actors, in line with UNGA Resolution 69/314, which calls on United Nations organisations and Member States to improve cooperation with all relevant stakeholders to facilitate a comprehensive approach by the international community. (3)Strengthening the global partnership of source, consumer and transit countries against wildlife trafficking. The first objective under priority 3 related to support to developing countries. It aimed to increase this support by ensuring that wildlife crime is integrated as a priority in EU funding in the areas of natural-resource management, environment, organised crime, and security. It also aimed to ensure the effectiveness of this support. The second objective highlighted the importance of coordination and dialogue between source, consumer, and transit countries. A range of EU diplomatic and international cooperation tools could be used to strengthen this cooperation, including EU trade policies and instruments, participation in relevant regional organisations, and EU diplomatic channels. The third objective under this priority identified the need for greater understanding of the security-related dimensions of the illegal wildlife trade. The fourth objective under this priority called for continued participation in the strengthening of multilateral efforts to combat wildlife trafficking. This includes active participation and supporting the adoption and implementation of strong decisions, resolutions, and political declarations in CITES, the Convention on Biological Diversity, and all other relevant fora. 2.2 Point(s) of comparison In principle, the starting point for assessing the effectiveness of any actions is the state-of-play before the adoption of the 2016 action plan, both in terms of actions undertaken and outcomes. However, as previously mentioned, wildlife trafficking is a pervasive, complex, and vastly under-researched and under-reported issue. This means that there are limited representative data available on wildlife trafficking from either before or after 2016. In addition, the COVID-19 pandemic is likely to have had a significant impact on wildlife trafficking (see Box 1 ). This means that it is difficult to establish a clear baseline or to determine how the situation would have developed without the adoption of the 2016 action plan. Box 1 - Impacts of the COVID-19 pandemic on wildlife trafficking The pandemic resulted in worldwide travel restrictions, border closures, and limitations on direct contact with other people for much of 2020. Measures to prevent the spread of COVID-19 are likely to have disrupted traffickers’ transport methods, in some cases impacting the scale of the operation of trafficking networks due to fewer opportunities for illegal trade . This factor is likely to have contributed to reduced number of seizures registered in this time, with 38% fewer seizure records reported by EU Member States in 2020 than in 2019 . The COVID-19 pandemic also had an impact on the number of personnel able to carry out enforcement actions, resulting in reduced capacity to detect and report on illegal trade in wildlife. E-commerce volumes accelerated during the pandemic, in part triggered by travel restrictions and physical shop closures. The intensified volume of parcel deliveries represented a significant challenge for authorities in charge of checking parcels and enforcing CITES and the EU Wildlife Trade Regulations. In addition to the difficulty of establishing a baseline against which to compare the current state of play, it is not possible to precisely disentangle actions (and the impacts of these actions) that would have happened as a direct result of the action plan from those that would have occurred regardless. Complicating this further, the action plan was designed to align with and include existing actions.

Finally, it is important to remember that the action plan was designed to be a comprehensive framework to address the issue of wildlife trafficking globally. It contained many actions, varying in scope. The wide range of actions of the action plan was intended to allow for a broad and extensive approach to combating the illegal trade in wildlife, but this wide range of actions also further complicates the assessment. While the action plan included provisions for Member State reporting, it did not contain a clear and precise framework for monitoring and evaluation. This is in large part due to the fact that no clearly defined metrics (e.g. number of seizures, number of training sessions, value of goods seized) are fully representative of the EU fight against wildlife trafficking and its impacts. While a robust monitoring and evaluation framework could have been designed, it might have required resources (time and expertise of staff) that were disproportionate in relation to the accuracy of the knowledge gained. The success of the action plan is assessed through progress in achieving the objectives it set out. Measuring this success involves: (i) analysing the priorities identified in the action plan; (ii) evaluating the actions taken to reach the objectives; and (iii) identifying where barriers to reaching those objectives were faced. Considering the limitations outlined above, the evaluation draws chiefly from the input and views of stakeholders gathered during the consultation period, as well as data included in reports from Member States on legal and illegal trade. 33 How has the situation evolved over the evaluation period? 3.1 The state of the illegal wildlife trade in the EU The EU plays many roles in the international wildlife trade. It is an important market for wildlife and their products globally. As shown in Figure 1, it is also a transit and source region for wildlife traded both legally and illegally. EU Member State authorities consistently seize wildlife in various commodity types including medicinals, corals, reptiles, birds, plants, and mammals. Since 2017, there are an average of over 6 000 annual seizures involving CITES-listed wildlife in the EU (Table 1), a figure that rose incrementally until 2020. In 2020, there was a reduction which was likely due to the impact of the COVID-19 pandemic. Medicinals (animal and plant-derived medicinals) are consistently the top commodity reportedly seized in the EU, with 1 869 seizure records involving medicinals reported in 2019. Live coral rock, non-live coral rock, reptile bodies, reptile parts, reptile derivatives, live reptiles, live birds, bird bodies, bird parts, and bird derivatives are also consistently seized across the EU. The clandestine nature of the illegal wildlife trade means that although seizure data offers an insight into the scale of illegal wildlife trade, the true scale of illegal trade in wildlife is likely to be much greater. Table 1. Reported EU seizures involving wildlife between 2014 and 2020, extracted from EU-TWIX database. Year Number of seizures 2014 3 508 2015 5 035 2016 4 078 2017 6 142 2018 6 549 2019 6 898 2020 4 669 Table 1 illustrates the total seizures of illegally traded wildlife per year, as based on data submitted to EU-TWIX. It should be noted that the total number of seizures per year differs from that reported in the annual overview of seizures of CITES-listed wildlife in the EU. This is due to late submissions by Member States every year which retrospectively add additional seizures to the annual total. It should also be noted that, from 2017, annual reports on illegal trade have become a mandatory reporting requirement for all CITES parties. Before this mandatory requirement was in place in 2017, EU Member States were requested to submit a yearly overview of significant seizures for analysis to provide an indication of seizure levels across the EU. Therefore, the rates of reporting before 2017 differ from the rates post-2017. Furthermore, although they are a valuable indicator of the varying levels of trade across years, seizure data are not indicative of absolute quantities of illegal wildlife traded. Seizures records also contain varying quantities of wildlife, from tourist souvenirs to commercial containers of tropical wood. When making inferences based on seizure records, it is also important to note that although observed changes in the number of reported seizures could be indicative of a shift in demand or changes in illegal wildlife trade dynamics, these reported seizures are also indicative of reporting procedures, the varying levels of the enforcement effort, as well as capacity to detect and report illegal trade in wildlife. With these points in mind, the EU-TWIX data shows a steady increase in the number of seizures post-2016 (apart from 2020, which was likely due to the COVID-19 pandemic) which may be linked to: (i) an increase in enforcement efforts across the Member States related to the implementation of the 2016 action plan; (ii) an increased focus on tackling the illegal wildlife trade across the EU without specific reference to the action plan; or (iii) an increase in trafficking. 3.2 Implementation of the action plan by priority Analysis of each action under the action plan has shown that each of the 32 actions have been, at least in part, implemented. Section 3.2 outlines, using some examples, how actions have been undertaken under each Priority and Objective of the action plan. For a comprehensive analysis of progress under each action, see the support study. A wide range of actions to combat the illegal wildlife trade has been implemented since the adoption of the 2016 action plan. This overview is provided to illustrate some – by no means exhaustive – examples of implementation of key objectives under the three priorities of the 2016 action plan. This implementation is analysed in Section 4. 3.2.1 Priority 1 – Preventing wildlife trafficking and addressing its root causes There have been many actions implemented under Priority 1 to reduce the demand for and supply of illegal wildlife products. Actions led to raise awareness have included events, workshops, exhibitions, and campaigns conducted at schools, universities, zoos, and rescue centres (e.g. Austria, Sweden, Italy, Hungary and Belgium), with particular focus on CITES rules and other relevant international legislation. France and the Netherlands have created apps to inform travellers on prohibitions and restrictions related to importing/exporting wildlife and their products. In May 2017, the European Commission adopted a guidance document recommending that Member States stop issuing export documents for raw ivory, which was further revised in 2021, leading to an almost complete ban. In 2016 and 2019, at the 17th and 18th Conference of the Parties to CITES, the EU successfully proposed to CITES that it extend its protection to various species largely imported into the EU. Indigenous people and local communities in source countries have been engaged in the fight against illegal wildlife trafficking through programmes to support and build their capacity to sustainably manage natural resources. These programmes create jobs in green sectors and give communities the necessary tools to restore and conserve protected areas. For instance, the EU has funded programmes which aim to: (i) improve law enforcement against the illegal wildlife trade by strengthening local community support and participation; and (ii) to build the capacities of local communities to sustainably manage their natural resources. Some examples of these programmes include the sustainable wildlife management programme, NaturAfrica, and the Greater Kilimanjaro Transfrontier Conservation Area project (2018-2019). Businesses and industries have increasingly engaged in efforts to combat wildlife trafficking by developing task forces and partnerships such as United for Wildlife, a United Kingdom organisation founded in 2014, which is leading the Transport Taskforce and the Financial Taskforce to tackle the illegal wildlife trade. The EU Wildlife Trade Enforcement Group (Enforcement Group) led a special meeting with representatives of the aviation and courier/parcel industries.

A successful proposal driven by the EU at the 17th Conference of the Parties to CITES (CoP17) recognised that corruption is a key enabler for wildlife trafficking, and called on the CITES parties and bodies to prevent, detect and penalise it. The EU has been involved in financial support to tackle corruption in non-EU countries, through the programmes managed by EU delegations. For example, the EU has aided civil society organisations (CSOs) through financial support from the European Instrument for Democracy and Human Rights (EIDHR) to train local staff in non-EU countries on tools and methods related to corruption and human rights. Anti-corruption features in multiple programmes under the Neighbourhood, Development and International Cooperation Instrument and the Instrument for Pre-Accession Assistance and predecessors of these programmes. 3.2.2 Priority 2 – Making implementation and enforcement of existing rules and the fight against organised wildlife crime more effective To promote the consistent implementation of EU rules on the wildlife trade, some countries have transposed the action plan into national action plans, which facilitated the integration of the action plan’s objectives into national priorities. For example, Germany drew up a national action plan which lists the activities it intended to conduct to effectively implement the action plan. Spain also developed a national action plan against wildlife trafficking, which makes it possible for different Spanish institutions and administrations to follow actions to combat the illegal wildlife trade within their own areas of work. Member States have also reported every year on trade in CITES-listed specimens and seizures. At CITES CoP17, the EU successfully presented a resolution setting out agreed principles on ensuring the legality and sustainability of trade in hunting trophies. The EU also funded the Intergovernmental Task Force on Illegal, Killing, Taking and Trade of Migratory Birds in the Mediterranean (MIKT). Perhaps most significantly, the Enforcement Group was empowered to assess priority risks by monitoring enforcement policy and practice in the EU Member States, encouraging the exchange of information and improving the enforcement of wildlife trade legislation. The Enforcement Group has met on average twice a year and has participated in special thematic meetings. These have included meetings with enforcement authorities from non-EU countries, or informational sessions with aviation and courier/parcel industries. To increase the capacity of enforcement actors, several Member States participated in joint EU-wide enforcement operations such as the ‘Thunder’ operations – month-long coordinated actions to disrupt wildlife trafficking and search cars, trucks, boats, and cargo transporters (see Box 2 below). Coordination mechanisms have also been put in place at the national level (through inter-agency task forces and memoranda of understanding). Training on CITES for officers, prosecutors, judges, inspectors, and customs officers has been administered by various Member States. The implementation of the LIFE-ENPE project (to build a network of environmental prosecutors) and the IMPEL project (to analyse good practices in implementing EU tools) has contributed to increasing the capacity of enforcement authorities to combat wildlife trafficking. On the fight against organised wildlife crime, EMPACT introduced an integrated approach to EU internal security. EMPACT has also drawn up a methodology to evaluate priorities in the fight against organised and serious international crime. One of the priorities for the EMPACT 2022-2025 programme is environmental crime, with a focus on disrupting criminal networks involved in wildlife trafficking. The EU funded the EU Wildlife Cybercrime Project from February 2019 to January 2021, with input from the Worldwide Fund for Nature (WWF) Belgium, the International Fund for Animal Welfare, Interpol, Belgian customs, WWF France, and WWF Hungary. The project aimed to disrupt wildlife trafficking which occurs via the internet and parcel delivery services, through increased detection and removal of fraudulent adverts and accounts. Several Member States have ensured that their legislation treats wildlife crime as a serious crime, as defined by the UN Convention against Transnational Organized Crime. These Member States have increased their efforts to investigate and sanction money laundering and other illicit financial flows related to wildlife crime. The EU and its Member States have actively engaged in strengthening the international cooperation of enforcement and management authorities, including through joint training days and financial support for training in non-EU countries. Box 2 – ‘Thunder’ operations Since 2017, several worldwide joint actions were initiated by the Interpol Wildlife Crime Working Group and coordinated by Interpol and the World Customs Organization. These actions received EU funding from – and additional coordination at EU level by – Europol . It saw the participation of several Member States . These joint actions include operations: Thunder (2021), Thunderball (2019), Thunderstorm (2018) and Thunderbird (2017). These operations successfully disrupted criminal networks and led to hundreds of arrests worldwide by: (i) targeting criminals and networks involved in cross-border wildlife crime; and (ii) supporting the cooperation of customs, police, financial intelligence units, wildlife-enforcement agencies, and forestry-enforcement agencies. Since 2017, the ‘Thunder’ operations have led to more than 8 000 seizures of protected wildlife and forestry species and the arrest of more than 3 000 offenders. 3.2.3 Priority 3 – Strengthening the global partnership of source, consumer, and transit countries against wildlife trafficking On priority 3, the EU, through financial support, has helped to train and equip local communities, improve law enforcement, and raise the profile of action against the illegal wildlife trade. According to the OECD, the EU and its Member States continues to account for the largest share of total official development assistance (ODA) in the world. This ODA has developed cooperation in all regions and across all sectors, and collectively amounted to USD 76.1 billion in 2020. Over the course of the period covered by the action plan, the EU and its Member States have funded many projects and programmes addressing the illegal wildlife trade in source countries, such as BIOPAMA and the Monitoring the Illegal Killing of Elephants project. Partners Against Wildlife Crime is an EU-funded action implemented by a consortium of 12 international and national partner organisations led by the Wildlife Conservation Society. The project aims to disrupt illicit supply chains from source to market for tigers, Asian elephants, Siamese rosewood, and freshwater turtles in the Greater Mekong region, Malaysia, and China by leveraging civil-society partnerships to increase the effectiveness of government action. Coordination between source, transit and market countries has been improved through a variety of tools. The Commission and the High Representative of the Union for Foreign Affairs and Security Policy have developed continental strategies for Africa (the ‘Larger than elephants’ strategy), Asia (the ‘Larger than tigers’ strategy) and Latin America (the ‘Larger than jaguars’ strategy) to tackle the principal threats to wildlife in these regions. EU trade agreements have also been used, with the EU-Vietnam agreement being seen as a good example of including environmental issues in its provisions. Out of 11 EU foreign trade agreements evaluated, 10 address the issue of biodiversity protection, while 9 cover illegal trade in endangered species. The relevant EU authorities have also actively cooperated with non-EU countries. SADC-TWIX, Africa-TWIX and Eastern-Africa TWIX have been increasingly used by local officials, supporting the exchange of information between authorities. The EU commissioned a study released in 2020 about the security issues of illegal wildlife trade in sub-Saharan Africa, expanding in detail on the links between security and the illegal wildlife trade in communities living close to wildlife. The EU and its Member States have actively participated in multilateral efforts to combat wildlife trafficking. The EU contributed to the development and adoption of the Resolution on ‘Illegal trade in Wildlife and Wildlife products’ adopted by the 2nd UN Environment Assembly in 2016 and participated in the Hanoi Conference on the illegal wildlife trade in November 2016. In 2019, the EU and its Member States co-sponsored again the Resolution on Tackling Illicit Trafficking in Wildlife at the UN General Assembly. The EU also pushed at the CITES Conference of the Parties and at the CITES Standing Committee meeting in November 2017 for targeted recommendations and sanctions to improve the fight against trafficking in ivory, rhino horn, rosewood, and tigers. 44 Evaluation findings 4.1 To what extent was the intervention successful and why?

4.1.1 Effectiveness To what extent have the actions planned been carried out and the objectives met, and what have been the impacts of these actions? As acknowledged previously, the extent to which efforts to curb wildlife trafficking can be directly linked to the EU action plan against wildlife trafficking is difficult to assess. Nevertheless, there has been progress towards several objectives of the action plan since it was launched. Three clear lessons from stakeholder consultations, about which there was broad agreement, suggest that the actions taken to address the illegal wildlife trade (outlined in Section 3.2) may have led to: (i) a strengthened response to the threat of the illegal wildlife trade; (ii) increased cooperation between Member States; and (iii) increased coherence between the actions of Member States. The following paragraphs look at each of these three areas in turn. A strengthened response to the illegal wildlife trade According to input received during the consultations, the action plan has contributed to raising the profile of the fight against the illegal wildlife trade in the EU, within Member States, in non-EU countries, and at the international level. It has helped to increase skills and staff levels and has increased cooperation between authorities (including wildlife authorities, CITES management authorities, customs, police, etc.). The action plan has also promoted action to: (i) increase the involvement of important stakeholders from the enforcement chain such as prosecutors and judges; and (ii) increase recognition of other issues related to the illegal wildlife trade, such as corruption, money laundering and security. It also increased the involvement of the private sector in the fight against the illegal wildlife trade. Furthermore, the action plan supported activities in source countries to provide both sustainable alternatives to the illegal wildlife trade and benefits from wildlife protection. Although few quantitative indicators are available to measure the impacts of these actions, some numbers are available. For example, the CITES indicator ‘Proportion of Illegally Killed Elephants’ in Africa has decreased consistently after a peak in 2012. Similarly, ivory re-exports have decreased for both raw and legally worked ivory since the adoption of the action plan: 420 tusks were re-exported in 2016, but only 101 in 2017 and the average number of re-export certificates fell from approximately 470 during 2012-2015 to 280 during 2016-2018. It is difficult to interpret illegal wildlife trade seizure records, as an increase of seizures can be either due to better targeting and implementation of verifications or increased illegal trade, but recent numbers remain relatively high. In 2020, 24 Member States reported a total of 3 977 seizure records, and 6 441 seizure records were reported by 25 Member States in 2019. Of the 3 977 seizures, Germany (1 144), France (1 071), the Netherlands (459) and Spain (330) accounted for 79% of 2020 seizures. The ‘Thunder’ operations have led to approximately 8 000 seizures of protected wildlife and forestry species and the arrest of more than 3 000 suspected offenders. It is important to note that it is impossible to identify whether these increases can be attributed directly to the existence and implementation of the action plan, although they are aligned with its actions and objectives. Although the rate of seizures seems to have increased since 2016, Member States and civil society organisations have noted that this has not systematically translated into the increased sentencing and sanctioning of criminals. Although several Member States reported having updated their national legislation to ensure that wildlife trafficking was treated as a serious crime (and therefore punishable by imprisonment of at least 4 years), there is no evidence to show that this has led to more appropriate and dissuasive sanctioning. In addition, several Member States reported a need to strengthen the response to wildlife trafficking online. The EU Wildlife Cybercrime Project mentioned above led to two reports: one on using technology to tackle online wildlife trafficking , and another on the online trade in reptiles and birds in Belgium and the Netherlands . Increased cooperation between Member States There have been concrete efforts to boost capacity, detect illegal activities, share data and knowledge, and strengthen cooperation between enforcement services and practitioners within and between EU Member States. The extent of cooperation among law-enforcement agencies grew slowly but surely between 2018 and 2022. There are several good examples of successful cooperation that led to convictions of criminals beyond the emphasis on seizures. Examples of enhanced cooperation between Member States include the ‘Thunder’ operations launched since 2017 (see Box 2 ). Operation LAKE (sixth edition 2021-2022) and Operation Fame (2019) focused on eel trafficking. Mainly carried out by Spain’s Guardia Civil, with support from Europol and AMERIPOL, Operation SUZAKU also focused on wildlife trafficking. Beyond these flagship operations, cooperation has also been promoted through specialised EU networks for enforcement professionals working on environmental crimes. These operations are key to combating wildlife crime and are a clear example of strengthened cooperation. Many participants in the consultations for this evaluation said that the action plan has been a useful tool to ensure that combating wildlife trafficking remained a political priority, even in the absence of robust data, although it is difficult to assess to what extent the action plan has been instrumental in that respect. On data sources related to the illegal wildlife trade, and to environmental crimes more broadly, several tools enable information exchange across the EU and with neighbouring countries (including EU-TWIX). Although there seems to be broad recognition of the usefulness of these tools, Member States and other stakeholders mentioned that the tools are not updated often enough. This may be because of a lack of capacity, a lack of resources, and/or a lack of transparency – in cases where information is conserved sensitive. Or it may also be because of limited access to the tools. In addition, there is currently no common, updated database on information about the prosecution of cases in the EU. At the 42nd Enforcement Group meeting, some ideas on strengthening information sharing were also discussed, such as: (i) improving risk profiling/information sharing with front-line officers through the use of risk information forms (RIFs) (proposed by DG TAXUD); (ii) reporting risk profiling information/seizure data to SIENA (Europol) to ensure that wildlife crime will continue to be categorised as a priority under EMPACT; and (iii) the creation of a centralised database (modelled on EU-TWIX) collating all information on national legislation relating to the trade in birds, as well as images and details of bird rings used in different countries. Overall, these activities to promote cooperation between Member States have led to clear improvements. However, to successfully carry out the other activities in the action plan, there is still a need to continue support for improved coordination, cooperation, and communication between Member States, non-EU countries, and international institutions, as well as between Member States’ own enforcement agencies. Increased coherence of action in Member States Differences remain between Member States in the fight against the illegal wildlife trade. Such differences can be partially explained by the extent to which the illegal wildlife trade is a risk in the country. For example, the TRAFFIC report on seizures of CITES-listed wildlife in the EU in 2020 reported that Germany, France, and the Netherlands reported approximately 80% of all CITES-related seizures in the EU that year, with Germany and France reporting 60% of these seizures. The Netherlands, Belgium, Germany, Spain, and France have the largest sea ports in the EU. This partly explains why these countries are very active in international trade in general and therefore have stronger controls and enforcement capacity, which has a greater impact in combating illegal trade. Some Member States are also source countries of illegal trade, e.g. eels and birds. With regard to cooperation with non-EU countries, some Member States have well developed bilateral cooperation mechanisms, including mechanisms that focus on biodiversity. For example, Germany’s GIZ and KfW are important development partners in many non-EU countries, as is the France’s AFD, along with other smaller agencies (Spain’s AECID, Italy’s CDP, Denmark’s Danida, Belgium’s ENABEL, Irish Aid, Luxembourg’s Lux Dev, Sweden’s SIDA, etc.). This reflects the difference in the extent to which Member States have been involved in the implementation of actions in non-EU countries. Some Member States have transposed the action plan into national action plans, including Spain, Germany, Slovenia and Czechia. The reported advantages of this include that a national action plan may: (i) facilitate the integration of the action plan’s objectives into national priorities; (ii) clearly identify national priorities related to the illegal wildlife trade; (iii) demonstrate the commitment of the Member States to prioritise the fight against the illegal wildlife trade; and (iv) raise political and public awareness of issues related to the illegal wildlife trade. An alternative approach is that taken by Belgium, which demonstrates that with clear national objectives and strengthened coordination mechanisms, a national action plan may not be necessary to implement the EU action plan. The differences between Member States have led to different levels of implementation and enforcement. According to input from stakeholders, the action plan seems sufficiently flexible to account for these differences. The national action plans or other mechanisms to implement the action plan at the national level can also identify the priorities within each Member State, according to its situation. However, stakeholders from civil society have criticised an unequal implementation of rules, which creates possible loopholes that facilitate the illegal wildlife trade. As highlighted in the recent Europol report, ‘environmental criminals know how to exploit the differences in product classification systems in various countries, the partial transposition of international protocols, the limited exchange of data among authorities, and the lack of harmonisation in prosecution rules across jurisdictions’. This allows environmental criminals to make the best use of uneven rules in different Member States to successfully traffic live animals, live plants, plant and animal products, plant and animal parts, or derivatives using these plant and animal parts. An evaluation of capacities and the varying implementation and enforcement needs in Member States in terms of implementation and enforcement could make it possible to target support to Member States with lower capacities and set up knowledge exchange activities with Member States implementing good/best practices.

What factors have contributed to or hindered the achievement of the objectives? Although there has been progress towards achieving some objectives of the action plan, the evaluation has drawn attention to several barriers to effective action to curb the illegal wildlife trade. These include: (i) the impact of COVID-19; (ii) the lack of legal tools beyond CITES; (iii) the broad scope of the action plan; and (iv) the lack of skilled, specialised staff and money to match the ambition of the action plan. An important factor which has contributed to the achievement of the objectives of the action plan is the complementarity between the priorities, objectives, and actions of the action plan, which helps to tackle the different aspects of wildlife trafficking. However, many Member States were of the view that this broad scope has also complicated implementation of the action plan. Some Member States reported that some actions went beyond their capabilities or required action from government agencies beyond those tasked specifically with addressing the illegal wildlife trade. This is also reflected in 2018 progress reports by Member States that include several blank responses, for example, when it came to reporting on initiatives to work with relevant business sectors, and notably on objective 2.3 on organised crime. In the 42nd Enforcement Group meeting, implementation of priority 3, which aims to strengthen global cooperation in the fight against wildlife crime, was mentioned as particularly challenging due to the limited time and capacity available at the national level. The lack of an appropriate monitoring framework makes it difficult to better identify gaps and successes. An appropriate monitoring framework would provide a strong basis for improving the action plan at all levels. Funding was identified as a significant challenge. Member States reported at the 42nd Enforcement Group meeting that there was a significant lack of funding to implement the action plan at the national level, with all countries having to rely on national budgets to implement the action plan. The failure to track resource allocation has also been highlighted by stakeholders from the targeted expert survey as a barrier to understanding the actions being taken and how to improve them. Beyond funding, Member States also report a lack of skilled staff for implementation, enforcement, and reporting on the implementation of the action plan, in relation to the scale of action needed to adequately respond to the threats posed by the illegal wildlife trade. COVID-19 has been a challenge to implementing many of the planned activities set out in the action plan. The pandemic also led to a change in the pathways of the illegal wildlife trade, with for example, increased use of online platforms and parcel services. This required enforcement authorities to adapt accordingly. On possible missed opportunities, some stakeholders, mostly researchers and non-governmental organisations, considered that the action plan was too focused on taking measures to control the trade of CITES-protected species, even though these stakeholders felt that an increasing number of endangered non-CITES species are still being legally traded. Other stakeholders, mainly Member States, suggested continuing to only focus on CITES species. This divergence of views illustrates the tension between the need to be realistic about the financial and human resources available for enforcement, and the magnitude of action that would be necessary to fully tackle the illegal wildlife trade. Finally, several stakeholders raised the issue that there is little scope within the action plan for the participation of civil society. Civil society plays a key role in action against the illegal wildlife trade, including through gathering data, raising awareness, and managing projects in source countries, and brings a wealth of knowledge and experience, so the failure to explicitly include civil society in the action plan can be seen as a missed opportunity. One strength of the 2016 action plan is that although it sets out actions that should be implemented to tackle the illegal wildlife trade, it is not rigid in prescribing formats or requirements for these actions. This allows for flexibility in implementation and leaves room for other activities to be implemented in parallel, a benefit identified by several stakeholders, including the Commission and Member States. For example, actions have already been taken to identify and tackle cybercrime as an emerging issue, including through the ICCWC, Interpol and Europol. One important gap that was frequently raised during stakeholder meetings was the action plan’s failure to adequately strengthen the legal ‘teeth’ of EU action against wildlife trafficking. As identified in the analysis that preceded the drafting of the action plan, the sanctioning of wildlife crime in the EU is uneven across Member States (see section 2.1.3). According to Member States, this problem has persisted. Although the action plan makes it possible to focus on all stakeholders of the enforcement chain, training and properly equipping judges and prosecutors has been piecemeal and has not translated into significantly strengthened sanctioning. In addition, stakeholders – particular CSOs – believed that EU wildlife trade legislation was too narrowly focused on CITES rules. The lack of effective and implementable legal support to the action plan was also raised in the context of trafficking in species beyond those listed in CITES. These same stakeholders referred to a need to explore new legal tools to address all unsustainable trade in wildlife. These legal tools ranged from extending existing obligations under the current EU regulations on wildlife trade to more species, to passing new legislation criminalising all unsustainable trade in wildlife. How effective has the reporting and monitoring of progress towards action plan objectives (and/or actions listed in the action plan) been? Reporting and monitoring have repeatedly been found to be a major issue in both the evaluation and the implementation of the action plan. While there are some reporting obligations for Member States, there is a clear lack of capacity for detailed reporting and analysis. There is also no rigorous framework to make reporting and monitoring effective. As mentioned previously, the action plan lacks a baseline on actual trafficking levels, and also lacks a clear monitoring and evaluation process, for example through the creation of performance indicators. This makes it difficult to assess the impact of the action plan effectively. The main source of information about the impact of the action plan is the self-reporting by Member States on their activities to implement the action plan in 2018. In addition to the mandatory reporting to the Commission, Member State reports to CITES also provide relevant information to evaluate the progress of Member States in the fight against the illegal wildlife trade. Although these reports do not explicitly provide information on the action plan, they do show results of seizures, a key indicator of results. Several Member States often said that they lacked the skilled staff and resources necessary for self-reporting. Other responses from Member States mentioned that the content of the current progress reports of EU Member States show too much divergence and are too focused on easier, ‘low-hanging-fruit’ activities, such as organising meetings. These activities do not give any insights as to whether or not the actions carried out had any tangible results or impact. 4.1.2 Efficiency To what extent have actions under the action plan been cost-effective? What are the overall costs and benefits of the action plan’s implementation? To what extent are the costs proportionate to the benefits it has generated? It is particularly difficult to measure the cost efficiency of the action plan as it is a collection of many measures by different actors. These measures include projects, policy and legal initiatives, and outreach at the international level, most of which do not come with dedicated funding. Their results cannot be expressed in economic terms. Despite this, it is important to note that no stakeholder raised the issue of any action or measure under the action plan being too costly. As already indicated, the EU action plan does not include quantified and measurable indicators and targets, nor is any reporting required from the Member States on the financial allocations they have made for the actions related to the 2016 action plan. Even for EU funded projects, the actions listed in the action plan have often been implemented through measures supporting wider environmental (e.g. promoting biodiversity), enforcement (e.g. fighting organised crime) and other objectives. A detailed breakdown of budget, programmes, activities, and beneficiaries’ relevance for the action plan is therefore not available. This makes it difficult to estimate the allocated financial resources or how effectively they contributed to specific objectives or actions. There are also problems in measuring benefits. Although there is a well-established link between providing alternative, sustainable incomes to local populations and reducing poaching, there is little way to measure this impact directly. Many of the projects in non-EU countries take a community-based, comprehensive approach within which action against wildlife trafficking is a small part rather than the primary aim. Therefore, only general estimates of benefits and resources are available. For example, there are clear indications that the EU and its Member States are currently the largest donor for conservation activities in non-EU countries. It was estimated that at least EUR 580 million has been allocated by the EU since 2016 to address the illegal wildlife trade. The benefits generated by the action plan are also difficult to determine precisely. It is possible, however, to outline the potential benefits. Fighting the illegal wildlife trade contributes to preserving global biodiversity, which underpins all economic activity, and is estimated to be worth over 127 trillion EUR. In addition, the fight against the illegal wildlife trade contributes to strengthening the rule of law, reducing threats to security. The fight against the illegal wildlife trade is a key part of the fight against organised crime. The benefits of these issues are not easily quantifiable and go beyond economics.

To what extent do factors linked to the intervention influence the efficiency with which the observed achievements were attained? What other factors influence the costs and benefits? One factor that presents a risk to the efficiency of action against wildlife trafficking is corruption. This is particularly a risk in countries with weak environmental governance and enforcement. The EU takes steps to minimise the risk of corruption in projects in non-EU countries, and to support global anti-corruption activities more generally. For example, the EU has aided CSOs through financial support from the European Instrument for Democracy and Human Rights (2014-2020) to provide training on tools and methods related to the fight against corruption in non-EU countries. At the 17th Conference of the Parties to the CITES Convention in 2016, the European Union successfully introduced a dedicated resolution against the corruption that facilitates wildlife trafficking. This resolution: (i) sets out clearly, for the first time, that corruption plays a major role in the current wildlife trafficking crisis; (ii) calls on CITES parties to adopt targeted actions to address this problem; and (iii) provides a mandate to CITES bodies to hold parties accountable for instances of corruption affecting the implementation or enforcement of CITES. When discussing the efficiency of the action plan, it is important to note that many of the actions it included were already being carried out. The aim of the action plan was to coordinate and streamline these actions and provide a framework for better cooperation. This means that the action plan did not engender particularly large costs, whether financial or in requirements for staff. For example, for action 1.3, the Enforcement Group already met twice a year, and therefore most of the costs associated with this action were already being accounted for. Inviting businesses to attend these meetings was just an additional step. Similarly, the analysis in the implementation report is a follow-through of the analysis of EU Member States’ implementation of the EU Wildlife Trade Regulations, which was already covered financially through a service contract. It should be noted that there are also new actions within the 2016 action plan that initially did not involve costs (other than staff costs at the EU and Member-State-administration level) but that would still provide benefits. For example, the development of the 2017 guidance documents on the EU regime governing the intra-EU trade and re-export of ivory, did not require much funding. Nevertheless, the guidelines led to benefits by further restricting the ivory trade. However, as noted by Member States, these benefits also came alongside further burdens on enforcement in the Member States. The same could also be said for other actions, for which the expected results included the preparation of proposals, resolutions, and interventions at international fora. Are there opportunities to simplify the action plan, or reduce costs, without undermining the intended objectives? The exact extent of funding allocated to the implementation of the action plan is difficult to quantify. Nevertheless, Member States and CSOs voiced their concern over the lack of funds, expertise, and staff dedicated to implementation. According to the feedback received, some of the actions from the 2016 action plan could not be undertaken by Member States due to the lack of appropriate resources. In addition, CSOs emphasised that governments greatly depend on them for taking care of most of the seized/confiscated animals, although they themselves lack the funding, skilled staff and space to do so. Although this suggests that targeted prioritisation may increase the efficiency of funding and action under the action plan, it is important to note that none of the actions that were identified as underfunded or lacking in resources were considered superfluous. On the contrary, the lack of resources was presented as a key issue and barrier preventing action against illegal wildlife trade. 4.1.3 Coherence To what extent is the action plan internally consistent and coherent? Analysis of the actions taken under each objective does not identify any contradiction and suggests that the action plan is internally consistent and coherent. The action plan is divided into 3 priorities, including 12 objectives and 32 actions. The 3 priorities represent complementary goals to reduce wildlife trafficking. The 12 objectives and 32 actions cover different dimensions of the action against the illegal wildlife trade. Structurally, the action plan was constructed to cover all aspects of the illegal wildlife trade: (i) root causes; (ii) enforcement; and (iii) international cooperation. As highlighted several times in this evaluation, the action plan was meant to address a complex problem comprehensively, and by involving all relevant actors. It therefore included actions in the EU and in non-EU countries, including source, transit, and destination countries. It also covered actions targeting different kinds of stakeholders in local communities, private companies, and the whole enforcement chain. The evaluation has not identified significant inconsistencies or a significant lack of coherence. However, it has identified actions which overlap. Action 12, for example, which aims to ‘define and assess priority risk regularly’, partly overlaps with action 20: ‘Regularly assess the threat posed by organised wildlife trafficking in the EU’. There are also overlaps in actions 22 and 23, both of which encourage Member States to align their national legislation with international standards. In addition, although priority 3 was directed at strengthening global partnerships, many other actions under priorities 1 and 2 also had an international scope. Such overlaps are due to the complexity of wildlife trafficking, but they may contribute to the confusion over which actor is responsible for each action. To what extent is the action plan coherent with other EU interventions which have similar objectives, or that employ the same or similar mechanisms? The action plan was found to be aligned with other related EU interventions on protecting biodiversity, both in its aim and in its mechanisms. Opportunities for further alignment were identified by the Commission where EU interventions had been revised or set up since 2016 (for example the revised Environmental Crime Directive or the Digital Services Act). The objectives of the 2016 action plan are about biodiversity protection and combating the illegal wildlife trade, while ensuring the sustainable use of wildlife, for the benefit of local communities and economies (including by supporting legal trade in wildlife as a sustainable alternative, if relevant). EU policies related to these topics include at the strategic level the European Green Deal and the EU biodiversity strategy. The main EU environmental legal acts related to biodiversity protection are the Birds and Habitats Directives. EU legislation related to the trade of species includes the EU Wildlife Trade Regulations, the FLEGT Regulation (linked to the FLEGT action plan, the EU Timber Regulations, and the recent proposal for the EU deforestation-free products regulation), and the IUU Regulation on illegal, unreported and unregulated fishing. Other policies, existing legislation and proposed legislation directly relevant to the illegal wildlife trade are the Eel Regulation, the Environmental Crime Directive, the environmental compliance assurance action plan, the EU corporate sustainability due diligence directive and the newly proposed asset recovery and confiscation directive. The illegal wildlife trade falls under one of the European Green Deal’s priorities, aimed at protecting biodiversity and ecosystems. The revision of the action plan and the tightening of the rules on the EU ivory trade are targeted in the biodiversity strategy for 2030, presented in 2020 as part of the European Green Deal. The objectives of the 2016 action plan and the Habitats and Birds Directives are complementary in the protection of EU species. Some species targeted by the illegal wildlife trade, such as eels, are also covered by specific EU legislation. The Eel Regulation (Council Regulations (EC) No 1100/2007) provides a framework for the recovery of the eel stock, and in December 2010, EU Member States decided not to allow trade in European eel outside the EU. Although eels are not directly mentioned in the 2016 action plan, they are one of the most lucrative species to trade. Article 12 of the Regulation is about control and enforcement of imports and exports of eels, as part of activities to combat the illegal wildlife trade. Eels are one of the priority species targeted by EMPACT activities, which is in line with the objectives of the 2016 action plan. The EU forest law enforcement, governance and trade action plan (EU FLEGT action plan), set outs seven measures for the EU and Member States to tackle illegal logging. These measures aim to prevent the import of illegal timber into the EU, improve the supply of legal timber, and increase demand for timber from responsibly managed forests. CITES and the EU Wildlife Trade Regulations include some timber species. The 2016 action plan offers a framework to act on the strengthening of international commitments to fight timber trafficking. The EU FLEGT action plan and the 2016 action plan have similar measures/actions. It is important to continue promoting cooperation between CITES management authorities and competent authorities for both the EU Timber Regulation and FLEGT. The IUU Fishing Regulation shares common objectives with CITES in the prohibition of entry into the EU market of illegally harvested fishing products. For example, most species of sharks are listed in Annex II of CITES and therefore also fall under the scope of the action plan. Both instruments have similar mechanisms such as requiring certificates for fishery products imported in the EU to confirm the legality of the fishing activity. The Environmental Crime Directive (Directive 2008/99/EC on the protection of the environment through criminal law) and the environmental compliance assurance action plan are important initiatives to help implement the objectives of the action plan by: (i) aiming to consider wildlife crime more seriously; and (ii) providing guidance to combat wildlife crime through enforcement, information exchange and capacity building. The Digital Services Act (DSA) will introduce due diligence obligations for providers of intermediary services, such as online platforms, with the aim of reducing the dissemination of illegal content online. These obligations include, for instance, the ban on targeted adverts for minors or based on sensitive data, strengthening obligations for very large online platforms (i.e. online platforms with more than 45 million users in the EU) to prevent misuse of their systems, and the obligation to have notice and action mechanisms to allow users to flag illegal content. The DSA is a key tool to help the action plan tackle the online illegal wildlife trade. The DSA refers to illegal wildlife trade within their definition of ‘illegal content’, which can improve the effectiveness of detecting illegal wildlife items and prosecuting those who sell them.

The newly proposed EU corporate sustainability due diligence directive (which includes the Convention on Biological Diversity and CITES Conventions in its scope), as well as the asset recovery directive, (which includes wildlife trafficking in its scope), are other recently proposed instruments that have the potential to further strengthen actions against the illegal wildlife trade. The COVID-19 pandemic has brought global attention to the issue of the spread of zoonotic disease and the importance of the ‘One Health’ approach, including in the context of the wildlife trade. As highlighted in the joint press release from CITES and the World Organisation for Animal Health, there is a need to efficiently implement surveillance and disease-control measures in the wildlife trade in order to protect animal and human health worldwide. The action plan does not cover this issue. In addition, the fight against the illegal wildlife trade has been successfully integrated into related EU policies. For example, the ‘new European consensus on development’ states that the EU and Member States ‘will address wildlife poaching, illegal trade in wildlife and timber, and the illegal exploitation of other natural resources’. To what extent is the action plan consistent with relevant international instruments to which the EU has subscribed? Overall, the action plan is consistent with relevant international instruments to which the EU has subscribed that are directly linked to the illegal wildlife trade. Moreover, the action plan explicitly fosters consistency with important related international instruments. The EU and its Member States are signatories to a variety of multilateral environmental agreements (MEAs) and other international instruments, many of which include some provisions related to the illegal wildlife trade. Instruments directly relevant to the illegal wildlife trade include: (i) the United Nations SDGs; (ii) MEAs such as CITES and the Convention on Biological Diversity (CBD); and (iii) the Bern and Bonn Conventions. The action plan also aims to ensure that international commitments in other fora such as the G20 – and linked activities, such as several resolutions on financial issues – are included in EU and Member State legislation. The 17 SDGs were set in 2015 by the UNGA and are intended to be achieved by 2030. The action plan is fully coherent with Target 15.7 which calls for ‘urgent action to end poaching and trafficking of protected species of flora and fauna and address both demand and supply of illegal wildlife products’. The EU has been an active party to the CITES CoP since it became as a member in 2015. In 2016, at the 17th CoP, the EU: (i) successfully proposed to CITES that it extend its protection to various species which were largely being imported into the EU; and (ii) successfully proposed a resolution which, for the first time in CITES, clearly recognises that corruption is a key enabler for wildlife trafficking and called on CITES parties and bodies to prevent, detect and penalise it. The EU also pushed at the CITES CoP and the CITES Standing Committee meeting in November 2017 for targeted recommendations and sanctions to improve the fight against trafficking ivory, rhino horn, rosewood, and tiger. In January 2019 at CoP18, further proposals were developed and submitted by the EU for endangered species to be added to CITES annexes to improve species conservation and protection. The EU provides specific financial support for implementing CITES CoP decisions and continues to follow up closely on their implementation. Other relevant MEAs include the CBD, which aims for the conservation and sustainable use of biological diversity. The CBD’s draft post-2020 global biodiversity framework features: (i) a target that addresses the harvest, use and trade of wild species of flora and fauna; and (ii) targets that recognise the benefits to conservation and humans resulting from the legal and sustainable use of wild species. These targets are in line with the objectives of the action plan. The Bern Convention on the Conservation of European Wildlife and Natural Habitats protects EU biodiversity; while the Bonn Convention on the conservation of migratory species is in particular linked to conserving birds, fish and other migratory species that are the target of illegal trade, which is also one of the objectives of the action plan. The action plan explicitly mentions the UN Convention against Transnational Organized Crime and the UNGA resolution on money laundering. Although not all Member States have yet transposed these two instruments into national legislation, Member States are already taking steps towards achieving the goals of these instruments. More recently, on 23 July 2021, the UNGA adopted a Resolution on tackling illicit trafficking in wildlife. The Resolution urges UN Member States to take decisive steps to prevent, combat and eradicate wildlife crime. The EU contributed to the development and adoption of the Resolution on Illegal Trade in Wildlife and Wildlife Products adopted by the 2nd UN Environment Assembly in 2016, a resolution which is in line with the action plan. At the Hamburg summit in 2017, and with the involvement of the German presidency, the EU, and other Member States, the G20 committed to focusing its attention on corruption related to the illegal trade in wildlife and wildlife products, as part of its implementation plan for the G20 anti-corruption action plan 2017-2018. This is fully in line with Objective 1.4 of the action plan. More broadly, the EU and its Member States participate in international cooperation in the fight against illegal wildlife trade through bilateral and multilateral activities. In particular, they participate in the activities led by the ICCWC initiative, which, according to stakeholders, improves international cooperation and has led to key successes. 4.2 How did the EU intervention make a difference? 4.2.1 What is the European added value of the action plan, compared to what could have been achieved in its absence by Member States at national and/or regional levels, and by international organisations globally? Many actions against the illegal wildlife trade were occurring in the EU, in Member States, and internationally before the action plan was adopted. However, analysis and stakeholder input have indicated that the action plan has been a broadly well-suited response to the need for organised actions at EU level. Coordination, funding, and political prioritisation are key benefits brought by the action plan, highlighting the EU added value in these areas. Examples of coordination efforts include the various networks at EU level linked to implementation and enforcement to tackle environmental crime. They also include meetings of the Expert Group and the Enforcement Group. These meetings make it possible to discuss important aspects of the illegal wildlife trade between relevant authorities of Member States, as well as between relevant actors at the EU level, including Europol and different DGs of the European Commission. As illustrated in Section 3.2, increased cooperation between Member States has also included data sharing, joint action days, joint operations, and joint training through practitioner networks. This coordination at EU level was noted as important during stakeholder consultations. Primarily, this coordination makes it possible for enforcement actors to collaborate in cross-border cases, both operationally (through joint operation days), and through the sharing of information. This sharing of information in turn can help enforcement actors in their work through the gathering of intelligence at an EU-level, enabling more and better targeted action. More generally, the coordination of actions between Member States at an EU level is important to ensure stronger and more consistent implementation across the single market. According to the Member States, the EU action plan provides guidance for them on how to step up their fight against wildlife trafficking in a coordinated manner. The Member States said that the action plan helps them to target potential weaknesses in enforcement through specific actions, such as: (i) improved compliance at national level with EU wildlife regulations; and (ii) the introduction into national law of relevant provisions, such as those related to organised crime, money laundering and corruption. The EU action plan has also supported the fight against wildlife trafficking through supporting the deployment of substantial EU funding. Finally, the EU action plan has given the fight against wildlife trafficking a higher level of political priority, both in the EU and globally. Consultations within the Commission have shown the importance of the action plan and its use of EU tools such as the serious and organised crime threat Assessment (SOCTA) and EMPACT. On several occasions, stakeholders said that these tools have ensured the continued allocation of resources and political focus. At the global level, the EU coordination of the response to wildlife trafficking has contributed to raising the profile of the fight against the illegal wildlife trade and in making the EU a key player at international level, recognising its responsibilities as a source, transit, and destination area for illegally traded wildlife. 4.2.2 To what extent does the Plan comply with the principles of subsidiarity and proportionality? What has been the role of –and impact on – local and regional authorities?

Wildlife trafficking takes different forms in different Member States and requires adapted approaches to tackle the challenges at hand. However, coordination and cooperation between Member States is key in the single market. A high degree of coordination and cooperation is necessary to ensure a common and consistent implementation of rules, and to avoid loopholes in certain Member States being problematic for other Member States. At the same time, the action plan is also sufficiently flexible to allow Member States to prioritise actions that are most relevant to them, whether through drawing up a national action plan or through mechanisms that improve the coordination and prioritisation of actions. 4.3 Is the intervention still relevant? 4.3.1 To what extent is the action plan still relevant and to what extent do its (original) objectives still correspond to the needs within the EU? The action plan was created as a tool to catalyse and harmonise EU action against the illegal wildlife trade. As the illegal wildlife trade remains an important threat to biodiversity and security both worldwide and in the EU, the action plan remains an important and relevant tool. The EU remains an important space for the illegal wildlife trade, as pointed out in Europol’s recent report, which stated the following: Criminal networks operating in Europe traffic both exotic fauna (i.e. tigers, leopards, rhinos, narwhals, whales, elephants, devilfish, toucans, parrots, iguanas, insects, lizards, snakes, frogs, etc.) and exotic flora (especially cacti), some of which are commonly traded under the label of medicinal products. Traffickers operating in Europe are increasingly targeting less monitored endemic non-CITES listed species, which are trafficked to both EU and non-EU destinations. The illegal trafficking of European eels alone generates EUR 2 to 3 billion in yearly criminal profits. According to IPBES, direct exploitation of animals and plants (which includes exploitation for trade) has had the second largest relative negative impact on nature (after land-use change).Therefore, regulating the international wildlife trade and keeping it within sustainable levels remains important as biodiversity is being lost across the globe. This sentiment is also reflected in the European Green Deal. Wildlife trafficking also continues to change over time due to: (i) changes in consumer interests; and (ii) smugglers adapting the methods they use to ship their contraband to routes perceived as less risky or in reaction to increasing enforcement effort/policy changes in given areas. There is increasing evidence of the involvement of organised criminal groups in wildlife trafficking. Therefore, there is a continued need to respond to this dynamic landscape in a coordinated manner. Overall, the actions put forward in the 2016 action plan are essential to tackling the illegal wildlife trade. Improvements in the fight against the illegal wildlife trade have been reported by Member States since 2016, including: (i) increased seizures and arrests; (ii) new CITES resolutions; (iii) awareness-raising campaigns; (iv) projects in source countries; and (v) many other activities. Despite these improvements, the international wildlife trade remains a serious threat to biodiversity, the rule of law and sustainable development. Evaluation of each action did not identify any action that is no longer relevant or no longer needed at this stage. On the contrary, stakeholder consultations repeatedly highlighted the continued relevance of the 2016 action plan. The continued relevance of the action plan is also demonstrated by the growing international interest in the fight against wildlife trafficking. As discussed in Section 4.1.3.3, the action plan aligns with many international goals and commitments, including the SDGs, the CBD’s draft post-2020 global biodiversity framework, and of course the ongoing objectives of CITES. At the level of the EU itself, the action plan remains a core part of the 2030 biodiversity strategy, which itself is a key deliverable of the Green Deal. Environmental crime, including wildlife and timber trafficking, was for the first time incorporated as an EU priority for the fight against organised crime for the EU’s 2018-2021 SOCTA policy cycle, and again for the 2022-2025 policy cycle. 4.3.2 How flexible has the Plan been in responding to new issues? Analysis of actions undertaken have shown that the priorities, objectives, and actions of the 2016 action plan provide a comprehensive approach to tackling the various facets of the illegal wildlife trade. No stakeholders or Member States reported a problem with the flexibility of the action plan. Indeed, the variety and scope of actions that have occurred in the EU fight against wildlife trafficking since 2016 suggests that the plan is broad and flexible enough to allow for a wide range of approaches and actions. On the other hand, the action plan’s broad and comprehensive approach may have contributed to a lack of prioritisation or focus and, subsequently, to the persistent lack of skilled staff and financial resources in actions against wildlife trafficking. Three main areas have been identified where action could be strengthened. These three areas are set out in the paragraphs below. (1) Continued strengthening of enforcement, with a particular focus on applying proportionate and dissuasive sanctions. This means ensuring that all Member States: (i) apply strict rules; (ii) share case-law and best practices; and (iii) ensure continuous specialised training for all actors in the enforcement chain, with a particular focus on prosecutors and the judiciary. These actions will ensure that wildlife trafficking is not only detected but also that it is appropriately sanctioned. (2) Ensuring the meaningful and purposeful involvement of all relevant actors, including – but not limited to – private companies (in particular courier and transport companies), pet traders, and civil society. Civil society and the private sector are two key actors in combating the illegal wildlife trade and are potentially important allies for implementing the action plan. Several actions and objectives identify the importance of engaging with business sectors and civil society. However, progress in this area is difficult to track, and there are no structures for involving civil society and the private sector further in the implementation of the action plan. (3) Focus on the following three under-addressed issues: (i) wildlife crime linked to the internet; (ii) the ‘One Health’ approach; and (iii) tracking financial flows. The following paragraphs examine each of these issues in turn. Wildlife crime linked to the internet The 2018 progress report mentions that the online trade in wildlife was an issue needing more investigation. As early as 2017 in China, based on TRAFFIC’s routine online monitoring, a shift was revealed in the illicit trade in wildlife products from physical markets to e-commerce marketplaces and onto social media platforms. This prompted internet companies in late 2017 to sign a charter pledging to address online wildlife trafficking. These companies also discussed adopting a standard operating procedure for providing guidance to internet companies on how to detect, prevent and deal with information related to the illegal wildlife trade. Unfortunately, since the inception of the action plan, the trafficking of wildlife using online platforms has continued to increase, including during the COVID-19 pandemic. Although some EU funded projects, such as the EU wildlife cybercrime project have already been implemented, more needs to be done. Many interesting initiatives have been implemented from which the EU could take inspiration, such as the Coalition to End Wildlife Trafficking Online, set up by TRAFFIC, WWF and IFAW. In 2021, the Coalition to End Wildlife Trafficking Online: (i) engaged 47 companies; (ii) blocked or removed more than 11.6 million posts about illegal wildlife and wildlife products; (iii) trained more than 2 000 staff; and (iv) reported more than 11 000 listings for illegal wildlife and wildlife products.

The ‘One Health’ approach The COVID-19 crisis is widely thought to have arisen from a virus in wild animals that passed to humans through contacts between wild animals, domestic animals, and humans, including in food markets. This crisis has reminded humanity of the links between biodiversity protection, the wildlife trade, animal health and human health. The adoption of a ‘One Health’ approach that considers human, animal, and environmental health as a single issue, including through stricter control of wildlife trade, is widely advocated to combat as effectively as possible future zo