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
Date: 2022-11-09
Institutions: Directorate-General for Environment, European Commission
Subjects: EU action, biodiversity, environmental cooperation, illicit trade, organised crime, protection of animals, protection of plant life, wildlife

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 9.11.2022  COM(2022) 581 final  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 {SWD(2022) 354 final} - {SWD(2022) 355 final}  
 
 
Revision of the EU action plan against wildlife trafficking 

Setting the scene 

December 2022 will be a critical moment for preserving global biodiversity.  Signatories to 
the Convention on Biological Diversity (CBD) will meet in Montreal for the conclusion of 
the 15th conference of parties to the CBD. At the meeting, the signatories will seek to shape 
global efforts to identify and commit to action to halt and reverse the continued destruction 
of  biodiversity.  One  month  earlier,  parties  to  the  Convention  on  International  Trade  in 
Endangered  Species  of  Wild  Flora  and  Fauna  (CITES)  will  meet  in  Panama  to  review 
measures to ensure that international trade in wild animals and plants does not threaten the 
survival of species.  

The fight against wildlife trafficking is a crucial part of efforts to halt biodiversity loss. As 
highlighted  by  the  Intergovernmental  Science-Policy  Platform  on  Biodiversity  and 
Ecosystem Services, sustainable use of wildlife is essential to meet the needs of present and 
future  generations.  The  sustainable  use  of  wildlife  can  help  stop  the  emergence  of  new 
pandemics, provide sustained livelihoods for local and indigenous people, and contribute to 
restoring and maintaining biodiversity. By contrast, illegal or ineffectively regulated trade in 
wild species is a threat to this sustainable use1.  

The post-2020 global biodiversity framework, which is to be adopted at the 15th conference 
of  the  parties  to  the  CBD  in  December,  is  expected  to  set  concrete  goals  and  targets  to 
ensure  that  the  harvesting,  use  of,  and  trade  in  wild,  terrestrial,  freshwater  and  marine 
species is legal and sustainable. This updated action plan is intended to contribute to the full 
implementation of this commitment by the European Union and its Member States. 

The  illegal  wildlife  trade  remains  serious  and  widespread.  According  to  the  2020  World 
Wildlife Crime Report by the United Nations Office on Drugs and Crime, no country in the 
world is unaffected by wildlife trafficking, with a wide variety of species involved, from eels 
to  pangolins  to  rosewood2.  Globally,  the  numbers  of  seizures  of  trafficked  wildlife  by  the 
authorities have fallen since the start of the COVID-19 pandemic3, but there is no evidence 
that trafficking itself is being curbed. 

The illegal trade of species is a driver of global biodiversity loss 4. The illegal exploitation 
of species can greatly weaken wild populations, and in some cases drive them to extinction5. 
Species  that  are  not  directly  targeted  for  trafficking  can  also  be  impacted,  for  example 
through  by-catch  or  habitat  depletion.  The  illegal  removal  of  keystone  species  from 
ecosystems  can  also  have  cascading  effects,  affecting  ecosystem  services,  destroying 
important carbon sinks, and disturbing the health and balance of land and water6. Moreover, 
the release of trafficked alien species into the wild in destination countries can disrupt local 
habitats, with potentially devastating impacts on indigenous species. 

Wildlife  trafficking  also  has  very  destructive  socioeconomic  impacts.  The  widespread 
illegal  trade  of  wild  animals  can  increase  the  risk  of  transmission  of  zoonotic  diseases  (i.e. 

1  

IPBES, Summary for policymakers of the thematic assessment of the sustainable use of wild species of the 
Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services, 2022. 

2  UNODC, World Wildlife Crime Report, 2020. 
3    TRAFFIC, An overview of seizures of CITES-listed wildlife in the EU in 2020, 2022. 
4  

IPBES, Summary for Policymakers of the Global Assessment Report on Biodiversity and Ecosystem Services 
of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services, IPBES 
Secretariat, Bonn, Germany, 2019. 

5   Maxwell, S. et al., Biodiversity: the ravages of guns, nets and bulldozers, Nature, 536, pp. 143-145, 2016. 
6   UNODC, Global Programme for Combating Wildlife and Forest Crime, Annual Report, 2021. 

1 

 
                                                           
diseases  originating  in  animals  that  go  on  to  infect  humans),  with  potentially  devastating 
results for public health. The destruction of ecosystems which can result from poaching and 
trafficking  often  deprives  local  communities  of  legal  and  sustainable  forms  of  income. 
These  legal  and  sustainable  forms  of  income  include  nature-based  tourism,  well-managed 
trophy hunting, and sustainable trade in wildlife. Well-managed trade in wildlife can actively 
benefit  species  conservation,  creating  incentives  for  local  communities  to  protect  wildlife 
resources  in  their  environment,  while  making  a  sufficient  and  sustainable  living.  However, 
wildlife  trafficking  is  economically  extremely  lucrative.  The  attractiveness  of  wildlife 
trafficking – given the low risk/high reward nature of the crime – seriously threatens public 
safety.  It  weakens  the  rule  of  law  and  legitimate  institutions.  Wildlife  trafficking  both 
benefits from and contributes to corruption while simultaneously supporting further criminal 
activities7.  There  is  clear  evidence  of  links  between  wildlife  trafficking,  organised  crime 
(including weapons trafficking) and terrorism8.  

A key role for the EU to play 

The EU functions as a hub for global wildlife trafficking9, and has a key role to play in the 
fight against it. The reported value of the illegal wildlife trade in the EU was a minimum 
of EUR 4.7 million in 2019 but is likely to be much larger10.  

The  EU  is  therefore  globally  well-placed  to  lead  the  fight  against  wildlife  trafficking.  EU 
regulations  on  the  wildlife  trade  make  it  possible  to  go  beyond  the  Convention  on 
International Trade in Endangered Species (CITES) in protecting endangered species against 
unsustainable  exploitation.  For  example,  the  EU’s  current  rules  on  trophy  hunting  expand 
permit obligations to – and increase scrutiny of – species beyond those in the strictest CITES 
listing. 

The EU can build on its long experience in combating wildlife trafficking 

The new action plan builds on the previous EU action plan against wildlife trafficking (2016-
2020).11  The  evaluation  of  the  2016  action  plan  found  that,  since  2016,  wildlife  trafficking 
has  risen  up  the  agenda  as  a  priority  issue  among  a  wide  range  of  policymakers,  law-
enforcement agencies, and stakeholders in  the EU and worldwide.  The  EU and its Member 
States have now scaled up enforcement measures, for instance through enhanced cross-border 
investigations  with  the  active  involvement  of  Europol,  Eurojust  and  law-enforcement 
agencies. This has resulted in more seizures and prosecutions, including through the activities 
of  the  European  Multidisciplinary  Platform  Against  Criminal  Threats  (EMPACT).  In 
addition,  the  European  Commission  has  increased  its  support  to  –  and  cooperation  with  – 
relevant national authorities and European networks of enforcement practitioners on tackling 
environmental  crime.  The  Commission  also  adopted  a  proposal  for  a  new  EU  directive  to 
crack down on environmental crime. 

7   European Commission, Directorate-General for International Cooperation and Development, Study on the 
interaction between security and wildlife conservation in sub-Saharan Africa: summary report, European 
Commission, 2019.  

8   UNOCD, World Wildlife Crime Report, 2020. 
9  Europol, Environmental Crime in the age of Climate Change, 2022. 
10   TRAFFIC, Overview of seizures of CITES-listing wildlife in the European Union, January 2019 to 

December 2019, 2020. 

11   Communication from the Commission to the European Parliament, the Council, the European Economic and 

Social Committee and the Committee of the Regions, EU Action Plan against Wildlife Trafficking, 
COM/2016/087 final. 

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The  EU  has  also  led  actions  against  wildlife  trafficking  in  multilateral  fora,  notably  under 
CITES. To deliver on the EU’s commitment to take further action against elephant poaching 
and ivory trafficking globally, the EU updated its rules to end most forms of ivory trade in the 
EU.  

The  EU  and  Member  States’  diplomatic  networks  have  also  been  mobilised,  actively 
engaging  in  bilateral  and  regional  dialogues.  Last,  but  not  least,  the  EU  has  since  2016 
provided  substantial  funding  for  capacity  building  and  international  action  against  wildlife 
trafficking, including for: (i) advocating for the involvement of local communities in source 
countries of wildlife trafficking;  and (ii) providing these local communities with alternative 
livelihoods and alternative sources of income.  

Continued challenges and new opportunities  

Despite these efforts, wildlife trafficking, combined with climate change and environmental 
degradation,  continues to  put a serious strain  on wildlife as well  as on people’s livelihoods 
and security.  There have been changes  over time in  both  trading  routes  and traded species. 
Moreover, increased use of online platforms for trading in wildlife illegally and the related 
use of small-parcel services have created new challenges for detecting and investigating this 
type of crime, calling for new solutions and increased resources. The increase in seizures of 
trafficked  wildlife  in  the  EU  since  2016  has  not  translated  into  a  proportional  increase  in 
prosecutions and convictions. A lack of specialised staff, resources and training in many of 
the  Member  States  and  non-EU  countries  remains  a  major  issue.  There  is  also  scope  for 
improving  cooperation:  (i)  within  EU  Member  States;  (ii)  among  EU  Member  States;  (iii) 
between the EU and non-EU countries; and (iv) with stakeholders and civil society.  

Way forward 

This  revised  action  plan  aims  to  guide  EU  action  against  wildlife  trafficking  in  the  period 
until 2027. Building on the 2016 action plan, it aims to respond to the current challenges in 
a comprehensive way. While the focus of the action plan is on wildlife trafficking, it makes 
necessary links with the EU Wildlife Trade Regulations and other related policies.  

Addressing wildlife trafficking requires a comprehensive approach and a range of measures 
at  the  intersection  of  the  wildlife  trade  and  wider  wildlife  conservation  policy,  all  with  the 
aim of allowing only sustainable trade in wildlife to occur.  

The action plan is structured around four main priorities, set out below.  

Priority 1:  Preventing wildlife trafficking and addressing its root causes  

Priority 2: 

Strengthening the legal and policy framework against wildlife 
trafficking 

Priority 3: 

 Enforcing regulations and policies to fight wildlife trafficking 
effectively  

Priority 4: 

 Strengthening the global partnership of source, consumer and transit 
countries against wildlife trafficking 

Each priority has several objectives, and for each of the objectives, a number of actions have 
been  identified.  These  actions  are  not  exhaustive  and  may  be  complemented  by  additional 
measures. The objectives and related actions have been detailed in the Annex.  

3 

 
 
Through these priorities, the new action plan: 

 

focuses  on  multi-agency  cooperation  and  coordination  to  effectively  prevent, 
detect,  prosecute  and  sanction  wildlife  crime12.  Under  the  action  plan,  cooperation 
will be strengthened: (i) between the law-enforcement authorities of EU Member 
States; and (ii) between the EU, its Member States and non-EU countries.  

  encourages EU Member States and non-EU countries to treat wildlife trafficking as a 
serious  crime,  and  to  build  capacity  and  specialisation  along  the  enforcement 
chain with a view to making proportionate and dissuasive sanctioning the norm.  
  explores the need for, added value of, and feasibility of new legislative and policy 
initiatives  to  ensure  that  EU  action  against  wildlife  trafficking  remains  sufficiently 
strong and proportionate to the threat posed by wildlife trafficking. 

  harnesses  the  momentum  of  the  adoption  of  the  Digital  Services  Act  to 
strengthen  action  against  online  wildlife  trafficking.  Online  trade  in  wildlife  has 
grown rapidly in recent years, making it easier for criminals to operate with lower risk 
and  across  a  wider  market.  The  general  boom  in  e-commerce  has  led  to  increased 
volumes  of  international  parcel  traffic  in  recent  years.  The  adoption  of  the  Digital 
Services  Act  will  equip  the  EU  and  Member  State  authorities  with  new  tools  to 
address  the  challenges  linked  to  online  trade,  including  in  wildlife.  The  skills  and 
capacities  of  law-enforcement,  customs,  and  other  relevant  authorities  will  be 
strengthened. Cooperation with the private sector, such as the cooperation undertaken 
as  part  of  the  Coalition  to  End  Wildlife  Trafficking  Online13  or  the  ROUTES 
partnership14, will be encouraged. New tools will be developed to monitor legal trade 
in wildlife and to detect and investigate wildlife crime. These tools include databases, 
mobile apps, scanners, etc. 

  continues  to  treat  wildlife  trafficking  as  a  global  issue,  ensuring  international 
cooperation  and  coherence  between  action  against  wildlife  trafficking  within  the 
EU  and  support  to  action  against  wildlife  trafficking  globally.  Cooperation  with 
non-EU  countries  will  be  strengthened  through  bilateral  exchanges,  regional 
networks, enforcement networks, trade deals, and multilateral programmes. 
increases  transparency  in  EU  decision-making  and  promotes  stronger  partnerships 
between  the  EU  and  its  Member  States  on  the  one  side  and  non-governmental 
organisations,  international  organisations  and  the  private  sector  on  the  other.  The 
contribution  of  non-governmental  organisations,  international  organisations  and  the 
private  sector  to  the  fight  against  wildlife  crime  will  be  recognised  and  facilitated, 
including by involving them in policy discussions15. 

 

12  This need for cooperation and coordination applies to: CITES management; enforcement and scientific 

authorities; customs agents; the police; public prosecutors; the judiciary; health authorities; animal welfare 
and veterinary authorities; financial intelligence units; ministries of foreign affairs; and diplomatic missions 
amongst others. 

13  See the Coalition to End Wildlife Trafficking Online. 
14  See Welcome to Reducing Opportunities for Unlawful Transport of Endangered Species 

(routespartnership.org). 

15  All the points described in this paragraph also form the core objectives of EMPACT, a security initiative 
driven by EU Member States to identify, prioritise and address threats posed by organised and serious 
international crime. EMPACT runs in four-year cycles, and is a multidisciplinary cooperation platform of 
Member States supported by all EU institutions, bodies and agencies. Non-EU countries, international 
organisations and other public and private partners are also associated to it.  

4 

 
 
 
                                                           
Sufficient financial and human resources 

No real progress can be made in the fight against wildlife crime if no sufficient funding 
is  available  to  support the accompanying actions, both  at  the EU level  and in  EU Member 
States.  It  is  crucial  that  funds  dedicated  to  monitoring  the  wildlife  trade  and  addressing 
wildlife crime are: (i) identified in advance; (ii) made accessible to the relevant implementing 
actors; and (iii) used in the most effective and coherent way.  

The wildlife trade should be fully integrated in the relevant EU funds addressing: (i) security 
and organised crime; (ii) the environment; and (iii) international cooperation/partnerships. In 
particular,  it  should  be  a  priority  under:  EMPACT;  the  Internal  Security  Fund;  the  LIFE 
programme; and the Neighbourhood, Development and International Cooperation Instrument.  

Tracking progress 

To regularly measure progress, a system for monitoring the implementation of the action plan 
will  be  set  up  by  the  Commission  in  cooperation  with  Member  States  in  the  first  year 
following the adoption of the plan. The system will include a light reporting mechanism for 
the EU Member States and stakeholders, based on existing reporting frameworks. A number 
of indicators will be identified to measure, as far as possible, the results achieved in terms of 
the overall impact of the action plan on the wildlife trade.  

Conclusion 

The revised EU action plan against wildlife trafficking strengthens the ambitions of the 2016 
action  plan,  underlining  the  continued  dedication  of  the  EU  to  the  fight  against  wildlife 
trafficking.  If equipped with  appropriate resources,  the action plan  will serve as a blueprint 
for  ambitious  and  comprehensive  action  and  cooperation  –  within  the  EU  and  across  the 
world – to put an end to illegal trade in wildlife. 

5 

 
Priority 1 – Preventing wildlife trafficking by addressing its root causes  

Objectives  

Actors 

Actions 

ANNEX – Table of actions (2022-2027) 

1.  Reduce consumer demand 

for illegally traded wildlife  

COM, MS, 
EU 
networks of 
practitioners 
and expert 
groups 16 

  Promote the effective implementation of CITES Resolution Conf. 17.4 on 

demand-reduction strategies to combat illegal trade in CITES-listed species. 

 

 

Implement awareness-raising activities and well-targeted, social science-based 
demand-reduction activities, targeting in particular behavioural change by 
consumers in the EU. Support such activities in other major destination 
markets. Give priority to activities that address demand for wild-sourced 
reptiles, amphibians, birds, glass eels, African elephants, rhinoceros, pangolins 
and medicines/supplements containing illegally harvested wild plants. Raise 
consumer awareness on how to distinguish between legal and illegal trade. 

Implement initiatives at all levels, within the EU and beyond, that support 
livelihoods and the sustainable use of wildlife and wildlife products by 
encouraging and facilitating the legal and sustainable sourcing of wildlife 
products. This should include promoting transparent and traceable supply 
chains for timber17 and other wildlife products, and enforcing existing 
traceability requirements, such as those in the fishery sector18. 

Indicative 
timing 
Continuous 

From 2023 

From 2023 

16  For example, the European Network of Prosecutors for the Environment, the European Union Network for the Implementation and Enforcement of Environmental Law, 

the European Union Forum of Judges for the Environment, and regional networks. 

17  Proposal for a Regulation of the European Parliament and of the Council on the making available on the Union market as well as export from the Union of certain 

commodities and products associated with deforestation and forest degradation and repealing Regulation (EU) No 995/2010, COM/2021/706 final. 

18   Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for ensuring compliance with the rules of the common fisheries 

policy, amending Regulations (EC) No 847/96, (EC) No 2371/2002, (EC) No 811/2004, (EC) No 768/2005, (EC) No 2115/2005, (EC) No 2166/2005, (EC) No 388/2006, 
(EC) No 509/2007, (EC) No 676/2007, (EC) No 1098/2007, (EC) No 1300/2008, (EC) No 1342/2008 and repealing Regulations (EEC) No 2847/93, (EC) No 1627/94 and 
(EC) No 1966/2006. 

6 

 
 
 
 
 
 
 
 
                                                           
Objectives  

Actors 

Actions 

COM, MS 

 

Implement land-based initiatives such as NaturAfrica, the flagship EU 
initiative to support biodiversity conservation in Africa. NaturAfrica supports 
key landscapes for conservation and development. This will help to create jobs 
and improve security and sustainable livelihoods, while preserving the critical 
ecosystems and wildlife that are vital to all. 

Indicative 
timing 
Continuous 

2.  Strengthen engagement of 
indigenous peoples and 
local communities in the 
management and 
conservation of wildlife, 
including through support 
for the development of 
sustainable livelihoods in 
source countries 

  Apply a human-rights-based approach to wildlife conservation and 

Continuous 

management, with the participation of local communities and indigenous 
peoples (for example, through: (i) community-based natural-resource-
management approaches; (ii) ensuring the free, prior and informed consent 
processes; (iii) effective grievance mechanisms; and (iv) guaranteed access to 
information). 

  Promote the participation of women and young people in the management and 
conservation of wildlife, and ensure a gender-sensitive approach to analysing 
and combating the illegal wildlife trade. 

Continuous 

  Address the wildlife-security nexus by supporting actions in non-EU countries 
that: (i) promote social and economic stability; (ii) strengthen the rule of law; 
and (iii) encourage cooperation between law enforcement, local authorities, 
conservation partners, local communities, and indigenous peoples. 

Continuous 

3.  Prevent and counter 

COM, MS  

  Promote the effective implementation of:  

Continuous 

corruption associated with 
wildlife trafficking at 
national, regional and 
international levels, 
involving source, transit 
and destination countries 

o  CITES Resolution Conf. 17.6 on Prohibiting, preventing, detecting 
and countering corruption, which facilitates activities conducted in 
violation of the Convention; and of  

o  United Nations General Assembly Resolution 75/311 on tackling 

illicit trafficking in wildlife, in particular its paragraph 30, 

taking into account the G20 High-Level Principles on Combating Corruption 
Related to Illegal Trade in Wildlife and Wildlife Products. 

7 

 
 
 
 
 
 
 
 
 
 
 
 
Objectives  

Actors 

Actions 

  Streamline anti-corruption measures in programmes aiming to strengthen the 
capacities of relevant actors against wildlife crime, both within the EU and 
outside the EU (including among: seaport and airport officials; transport 
companies and financial intermediaries/the financial sector; enforcement 
authorities; and administrative authorities), in line with the UN Convention 
Against Corruption and in close cooperation with the United Nations Office on 
Drugs and Crime (UNODC). 

Indicative 
timing 
From 2023 

4.  Take a ‘One Health’ 

COM, MS 

  Examine the risks of the spread of zoonotic diseases related to trade in wild 

From 2023 

approach into account in 
the context of regulating 
wildlife trade in source, 
transit and destination 
countries 

animals and products derived from wild animals such as bushmeat. 

  Implement targeted measures to reduce these risks throughout supply chains, in 

From 2024 

line with the four guiding principles of the Collaborative Partnership on 
Sustainable Wildlife Management19, including through projects such as the EU-
funded ‘Safety across Asia for the Global Environment’ project implemented 
by the UNODC, and the sustainable wildlife management programme 
implemented by the Food and Agriculture Organization of the United 
Nations20. 

19   See Collaborative Partnership on Sustainable Wildlife Management (fao.org). 
20   See Sustainable Wildlife Management, Policy Support and Governance Gateway and the Food and Agriculture Organization of the United Nations, (fao.org). 

8 

 
 
 
 
 
                                                           
Priority 2 – Strengthening the legal and policy framework against wildlife trafficking  

Objectives  

Actors  

Actions 

5.  Set up a framework for the 
effective implementation 
of the EU action plan 
against wildlife trafficking 
at national and EU levels 

MS, 
COM 

6.  Ensure that EU and 

COM, MS 

national policy on the 
wildlife trade and wildlife 
trafficking is 
comprehensive and aligned 
with international 
commitments, standards 
and best evidence 

  Define and assign clear responsibilites for implementing actions at national 
and EU levels, and ensure coordination between the relevant actors (for 
instance: (i) through the creation of inter-agency committees or memoranda of 
understanding; (ii) through the adoption of national action plans; or (iii) 
through the appointment of a national focal point). 

  Set up a reporting, monitoring and evaluation framework for the action plan at 
the EU and national level. This framework should align with existing reporting 
obligations and structures in order to avoid additional administrative burden at 
EU or Member State level. 

  Use EMPACT as a key instrument to implement the EU action plan against 
wildlife trafficking, and involve national EMPACT coordinators in the 
implementation of the action plan.  

  Actively support and work with international institutions and experts to 
undertake research and develop/update guidance and identification tools 
(technical tools including forensic science and identification guidebooks) on 
key issues related to the wildlife trade. 

Indicative 
timing 
2023 

2023/2024 

Continuous 

Continuous 

 

Introduce and impose proportionate, effective and dissuasive sanctions for 
wildlife crime in line with the revised Environmental Crime Directive (once it 
is adopted) and exchange information and good practices to ensure consistency 
in the application of these sanctions.  

From 2023 

 

Implement the updated EU guidelines on trade in ivory and monitor their 
implementation and results. 

Continuous 

9 

 
 
 
 
 
 
 
 
Objectives  

Actors  

Actions 

  Apply increased scrutiny to imports of hunting trophies (for example by: (i) 

exploring extending the requirement for an import permit for hunting trophies 
of additional species covered by Annex B of Council Regulation (EC) No 
338/97; (ii) work with international partners to update available evidence on 
the impacts of trophy hunting on wildlife; and (iii) making opinions of the 
Scientific Review Group on country-species combinations for importing 
hunting trophies more transparent). 

Indicative 
timing 
From 2023 

  Explore the need for, added value of, and feasibility of revising existing 

From 2023 

measures or creating new tools to reduce unsustainable trade in wildlife (e.g. a 
‘positive list’ of species whose specimens taken from the wild can be traded 
and kept as pets; criminalising all trade in illegally sourced wildlife; or 
requiring the registration of all animals and plants brought to the EU). 

7.  Involve relevant 

COM, MS 

  Hold regular stakeholder meetings at national and EU levels, including with 

From 2023 

stakeholders in the 
development and 
implementation of action 
against wildlife trafficking 
at the EU and national 
levels 

8.  Engage with business 
sectors involved in the 
wildlife trade 

COM, MS 

international organisations; relevant law-enforcement and judicial authorities; 
civil society; the private sector; academia; and national governments. 

  Organise thematic sessions of the EU Wildlife Trade Enforcement Group with 
the participation of relevant civil-society groups, businesses, and academia. 

From 2023 

  Support the organisation of multidisciplinary EMPACT action days as part of 

Continuous 

EMPACT. 

  Organise sessions of the EU Wildlife Trade Enforcement Group with relevant 
business representatives to address specific issues (e.g. traditional medicine, 
exotic/wildlife sourced pets, the luxury industry, hunting tourism, timber, the 
fishing and fish-product-trade industries, transport, courier companies, and 
online trade). 

From 2023 

10 

 
 
 
 
 
 
 
 
Objectives  

Actors  

Actions 

  Ensure effective cooperation between CITES management authorities and the 
national administrative authorities responsible for supervising and enforcing 
the rules set out under the proposed directive on corporate sustainability due 
diligence21.  

Indicative 
timing 
From 2023 

  Develop guidelines on how companies should fulfil their due-diligence 
obligation under the proposed directive on corporate sustainability due 
diligence with regard to the wildlife trade. 

2024 

Priority 3 – Enforcing regulations and policies to fight wildlife trafficking effectively 

Objectives  

Actors  

Action(s) 

9.  Improve rate of detection 
of illegal activities within 
the EU, and address 
priority risks 

MS, COM, 
Europol 

  Ensure that the process of developing serious and organised crime threat 

assessments (SOCTAs) also includes an assessment of the threat of wildlife 
trafficking, based on data and – where possible – national threat assessments 
provided by Member States. Streamline data on illegal trade.  

Indicative 
timing 
2023 

  Regularly discuss priority risks (and measures to address these risks) in the EU 

Continuous 

Wildlife Trade Enforcement Group. 

  Develop and use state-of-the-art tools and methods to facilitate the work of law-

Continuous 

enforcement authorities and detect illegal wildlife activities, for instance 
including mobile apps for frontline staff. Report on best practices at the 
Enforcement Group. 

21  Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, 

COM/2022/71 final. 

11 

 
 
 
                                                           
Objectives  

Actors  

Action(s) 

  Implement an EU CITES e-permitting system to: (i) facilitate legal trade; (ii) 
facilitate the sharing of data; (iii) facilitate the identification of false permits; 
and (iv) encourage non-EU countries to develop compatible systems.  
  Connect the EU CITES e-permitting system with the EU Customs Single 

Window Certificate Exchange (EU CSW-CERTEX) system (the central module 
of the EU Single Window Environment for Customs) to facilitate the checks of 
EU CITES e-permits by EU customs authorities, thus improving the 
enforcement of CITES provisions at the borders. 

Indicative 
timing 
2023/2024 

2024 

10. Ensure that law 

enforcement (including 
criminal-law-enforcement 
authorities and the courts) 
have the necessary sectoral 
expertise to address 
wildlife trafficking  

  Consider expanding the marking obligation to live species covered by Annex B 

2024 

of Council Regulation (EC) No 338/97.  

COM, MS, 
Europol, 
CEPOL, 
Eurojust, 
EJTN, ERA 

  Organise cross-professional and cross-border training sessions for law-
enforcement authorities, judicial authorities, and criminal judges where 
appropriate, including targeted training on: (i) how to improve the quality of 
investigation into financial flows; (ii) how to target online wildlife trafficking; 
and (iii) how to make better use of modern forensic methods. 

From 2023 

 

Integrate training on wildlife crime into the national curricula of relevant 
training academies/schools. 

2025 

  Share data, training materials and case law between Member States, using tools 
such as the case-law database of the European Union Network of Prosecutors 
for the Environment, the EU Trade in Wildlife Information Exchange (TWIX), 
etc.  

  Cooperate closely with relevant organisations, associations, and networks, and 
contribute to projects that work on tackling and prosecuting environmental 
crimes22.  

Continuous 

Continuous 

22  Including the European Union Forum of Judges for the Environment, the European Network of Prosecutors for the Environment, the European Union Network for the 

Implementation and Enforcement of Environmental Law, EnviCrimeNet, and the Successful Wildlife Crime Prosecution in Europe project. 

12 

 
 
 
 
 
 
 
                                                           
Objectives  

Actors  

Action(s) 

  Promote and support peer-to-peer training. 

  Encourage and support: (i) the specialisation of law-enforcement bodies, 

judicial bodies and other competent authorities at the national level; and (ii) the 
pooling of resources, for example through the establishment of dedicated 
wildlife-enforcement units within all relevant law-enforcement agencies. 

Indicative 
timing 
Continuous 

From 
2023/2024 

11. Improve cooperation, 

coordination, 
communication and data 
flows within and between 
Member States  

COM, MS, 
EU 
agencies 

  Encourage competent law-enforcement authorities to support and engage in 
criminal proceedings led by police/prosecutors and provide their expertise.  

Continuous 

  Promote online public access to case-law and court documents and publicise 

From 2024 

high-profile cases (with due regard to data-protection and privacy rights) with 
the dual goals of dissuading criminal actions and promoting best practices in 
enforcement. 

  Set up communication channels within Member States between: (i) 

2024 

sectoral/administrative national authorities; (ii) national law-enforcement 
authorities; and (iii) customs.  

  Ensure a common approach to collecting and sharing comparable, accurate and 
complete operational information on wildlife crimes. Ensure, as far as possible, 
coherence with statistical data collection on environmental crime proceedings 
(including wildlife crime) by law-enforcement authorities (police, prosecutors).  

2024 

  Systematically share operational and strategic information on wildlife crime 

Continuous 

with Europol through the Secure Information Exchange Network Application 
(SIENA) to ensure all the necessary data representing a realistic picture of the 
threat level posed by environmental crime: (i) are available to Europol; and (ii) 
feed into the EU Serious and Organised Crime Threat Assessment. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                                                                                                                                                      
 
Objectives  

Actors  

Action(s) 

  At national level, issue risk-information forms to be shared via the EU 

Customs Risk Management System for wildlife commodities to improve risk 
profiling for customs checks/information exchange with EU frontline 
enforcement officers. 

Indicative 
timing 
Continuous 

  Ensure effective cooperation and information sharing between the relevant 

Continuous 

CITES authorities, the Europol national units, Eurojust, OLAF and the Interpol 
Wildlife Crime Working Group. 

  Establish regular and structured collaboration and information sharing between 

From 2023 

the EU Wildlife Trade Enforcement Group and the relevant actors under 
EMPACT. 

  Carry out regular joint operations involving cross-border cooperation by EU 

Member States, the European Commission (OLAF), and relevant EU agencies 
such as Eurojust, Frontex, Europol and the European Fisheries Control 
Agency. These operations can also be part of the implementation of EMPACT 
operational action plans. 

Continuous 

  Systematically request Europol/Eurojust operational/judicial support on cases 

Continuous 

related to serious and organised wildlife crime. 

  Support Member States in strengthening their capacity to: (i) dismantle the 

From 2023 

organised criminal structures involved in wildlife trafficking; and (ii) 
investigate financial flows in the context of wildlife crime. This support should 
include training and raising awareness of crime typologies and risks23. 

  In line with the EU strategy to tackle organised crime 2021-2025, 

Continuous  

systematically launch financial investigations in organised crime investigations 
and, as soon as the financial environment indicates the presence of criminal 
assets, systematically launch asset-recovery investigations and procedures.  

12.  Systematically address 
links between wildlife 
trafficking and organised 
crime, particularly through 
strengthened action to 
target illicit financial flows 

COM, MS, 
Europol, 
Eurojust 

23  E.g. using tools such as the Wildlife Trade Financial Toolkit, https://themisservices.co.uk/iwt.  

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Objectives  

Actors  

Action(s) 

  Continue to step up the fight against the laundering of financial flows stemming 
from wildlife trafficking by supporting and reviewing the implementation by 
Member States of Directive (EU) 2018/1673 on combating money laundering 
by criminal law.  

  Raise awareness of how the directive on asset recovery and confiscation24 (after 
its adoption and entry into force) and Directive (EU) 2019/1153 laying down 
rules facilitating the use of financial and other information for the prevention, 
detection, investigation or prosecution of certain criminal offences25 can be 
used to fight wildlife trafficking. 

  Step up the systematic confiscation of the proceeds of wildlife trafficking in 
criminal cases, raising awareness among enforcement officials of available 
confiscation tools as a dissuasive measure. Encourage the use of the confiscated 
assets to contribute to conservation measures and the fight against wildlife 
trafficking. 

Indicative 
timing 
Continuous 

From 
2023/2024 

From 2023 

13. Increase effort in tackling 
the online aspects of 
wildlife trafficking, 
including through 
implementing the Digital 
Services Act and working 
with online platforms 

COM, MS 

  Implement the recommendations of CITES Resolution Conf. 11.3 paragraphs 

From 2023 

12 and 13 on wildlife crime linked to the internet. 

  Ensure effective cooperation between CITES management and enforcement 
authorities and digital-services coordinators under the Digital Services Act26, 
including by providing sufficient resources to follow up on detected illegal 
activities (e.g. by setting up internet task forces to support CITES management 
and enforcement authorities). 

From 2022 

24   See Proposal for a Regulation of the European Parliament and of the Council on a Single Market For Digital Services (Digital Services Act) and amending Directive 

2000/31/EC, COM/2020/825 final. 

25   Directive (EU) 2019/1153 of the European Parliament and of the Council of 20 June 2019 laying down rules facilitating the use of financial and other information for the 

prevention, detection, investigation or prosecution of certain criminal offences, and repealing Council Decision 2000/642/JHA, PE/64/2019/REV/1. 

26   Proposal for a Regulation of the European Parliament and of the Council on a Single Market for Digital Services (Digital Services Act) and amending Directive 

2000/31/EC, COM/2020/825 final. 

15 

 
 
 
 
 
 
 
                                                           
Objectives  

Actors  

Action(s) 

  Ensure coordination between CITES enforcement and expert groups and the 

European Board for Digital Services. 

Indicative 
timing 
From 2024 

14. Improve access to care for 
seized or confiscated live 
animals or plants 

  Develop EU-specific guidelines on the online trade in wild species, in line with 

2025 

the Digital Services Act.  

MS, COM 

  Follow CITES guidelines for the disposal of confiscated live animals, as 

From 2023 

contained in CITES Resolution Conf. 17.8 on the disposal of illegally traded 
and confiscated specimens of CITES-listed species, ensuring that all options 
for disposal/care are adequately considered and that final decisions are well-
justified. 

  Expand networks of specialised rescue centres at the national level, and share 

2025 

information about the centres at EU level.  

  Promote cooperation between relevant authorities to reduce unnecessary delays 

Continuous 

in investigation and litigation in order to minimise further harm to the 
trafficked specimen. 

 

Increase efforts, where appropriate, to effectively reintroduce seized live 
specimens to the wild. 

Continuous 

16 

 
 
 
 
 
 
 
 
Priority 4 – Strengthening the global partnership of source, consumer and transit countries against wildlife trafficking  

Objectives  

Actors  

Leading action(s) 

15. Raise the profile of the 
fight against wildlife 
trafficking globally 

COM, 
HRVP, MS 

  Regularly include wildlife trafficking on the agenda of high-level bilateral and 

multilateral meetings.  

  Continue dialogue with priority countries and regions at technical and political 
level, including as part of Forest Law Enforcement Governance and Trade and 
forest partnerships. 

  Ensure that wildlife trafficking is treated as a serious crime, including through 
implementation of the EU strategy to tackle organised crime 2021-2025, 
promoting the adoption of a protocol covering wildlife trafficking under the 
UN Convention against Transnational Organized Crime. 

16. Ensure that EU trade 

COM, MS 

 

Include wildlife trafficking on the agenda of: (i) trade dialogues with key 
partners; and (ii) the WTO Committee on Trade and Environment.  

Indicative 
timing 
Continuous 

Continuous 

From 2023 

Continuous 

Continuous 

policies and instruments 
support action against 
wildlife trafficking 

17. Strengthen the capacity of 
key source, transit and 
market countries outside 
the EU to combat wildlife 
trafficking and improve 
cooperation on 
enforcement between the 

  Propose ambitious commitments to combat wildlife trafficking in future free-
trade agreements, including in the EU’s ongoing support to the strengthening 
of the African Continental Free Trade Area.  

COM, MS, 
Europol 

  Train the EU’s wildlife-enforcement agents on international cooperation and 

From 2023 

the instruments available for this purpose.  

  Build capacity and provide scientific and technical training to relevant 

Continuous 

enforcement agencies, prosecutors and judiciaries in key non-EU countries 
affected by the illegal wildlife trade, including the upgrading of national legal 
frameworks to enable cross-border investigative collaboration and 
collaboration between national judiciaries. 

17 

 
 
 
 
 
 
 
Objectives  

Actors  

Leading action(s) 

Member States, EU 
enforcement actors and key 
non-EU countries  

  Encourage bilateral contacts, peer-to peer training and exchanges. Support 

informal and formal regional networks outside of Europe such as the Jaguar 
network in Latin America or the TWIX networks in Africa27, and encourage 
their cooperation with European counterparts. 

  Engage with and support the work of: (i) the relevant global networks, such as 
the International Consortium for Combating Wildlife Crime (ICCWC28) and 
the International Network for Environmental Compliance and Enforcement 
(INECE); and (ii) civil-society organisations and networks, such as the 
Coalition to End Wildlife Trafficking Online. 

Indicative 
timing 
Continuous 

Continuous 

27  E.g. AFRICA-TWIX. 
28   Comprising Interpol, the CITES Secretariat, the World Customs Organization, UNODC and the World Bank.  

18