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
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  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 

1 

INTRODUCTION ...................................................................................................................... 4 

1.1 

Purpose and scope of the evaluation/fitness check ............................................................. 4 

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ............................ 4 

2.1 

Description of the intervention and its objectives ............................................................... 4 

2.1.1 

2.1.2 

2.1.3 

2.1.4 

Impacts of the illegal wildlife trade ............................................................................ 4 

EU and global policy on the illegal wildlife trade leading up to 2016 ........................ 6 

Challenges identified................................................................................................... 8 

The 2016 EU action plan against wildlife trafficking ............................................... 11 

2.2 

Point(s) of comparison ...................................................................................................... 12 

3 

HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ............ 14 

3.1 

3.2 

The state of the illegal wildlife trade in the EU ................................................................ 14 

Implementation of the action plan by priority................................................................... 16 

3.2.1 

Priority 1 – Preventing wildlife trafficking and addressing its root causes............... 16 

3.2.2 
against organised wildlife crime more effective ....................................................................... 17 

Priority 2 – Making implementation and enforcement of existing rules and the fight 

3.2.3 
countries against wildlife trafficking ........................................................................................ 19 

Priority 3 – Strengthening the global partnership of source, consumer, and transit 

4 

EVALUATION FINDINGS .................................................................................................... 21 

4.1 

To what extent was the intervention successful and why? ............................................... 21 

4.1.1 

4.1.2 

4.1.3 

Effectiveness ............................................................................................................. 21 

Efficiency .................................................................................................................. 26 

Coherence ................................................................................................................. 29 

4.2 

How did the EU intervention make a difference? ............................................................. 33 

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? ............................................................................................................. 33 

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? 34 

4.3 

Is the intervention still relevant? ....................................................................................... 35 

4.3.1 
objectives still correspond to the needs within the EU? ........................................................... 35 

To what extent is the action plan still relevant and to what extent do its (original) 

4.3.2 

How flexible has the Plan been in responding to new issues? .................................. 36 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ...................................... 38 

5.1 

5.2 

Conclusions ....................................................................................................................... 38 

Lessons learned ................................................................................................................. 38 

ANNEX I:  

PROCEDURAL INFORMATION ........................................................................... 40 

ANNEX II: 

 METHODOLOGY AND ANALYTICAL MODELS USED ................................. 41 

1 

 
 
ANNEX III:  EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) .................................................. 45 

ANNEX  IV:  OVERVIEW  OF  BENEFITS  AND  COSTS  [AND,  WHERE  RELEVANT,  TABLE 

ON SIMPLIFICATION AND BURDEN REDUCTION] ....................................................... 74 

ANNEX V: 

 STAKEHOLDER CONSULTATION - SYNOPSIS REPORT .............................. 75 

ANNEX VI: 

 OVERVIEW OF PROGRESS  IN  IMPLEMENTATION OF THE ACTION PLAN, 

BY ACTION ............................................................................................................................ 87 

2 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

CBD 

CITES 

EG 

EMPACT 

EU 

FLEGT 

IPBES 

ICCWC  

SRG 

UNGA 

UNTOC 

Convention on Biological Diversity 

Convention  on  International  Trade  in  Endangered 
Species of Wild Fauna and Flora 

EU Wildlife Trade Enforcement Group 

European  Multidisciplinary  Platform  Against  Criminal 
Threats 

European Union 

Forest law enforcement, governance and trade  

Intergovernmental  Platform  on  Biodiversity  and 
Ecosystem Services 

International Consortium on Combating Wildlife Crime 

Scientific Review Group 

United Nations General Assembly 

UN Convention on Transnational Organized Crime 

3 

 
1  1  INTRODUCTION 

1.1 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  20181.  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 study2.  

2  2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1 2.1 

 DESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES 

2.1.1  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 
wildlife3.  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.  

1   Report  from  the  Commission  to  the  Council  and  the  European  Parliament,  Progress  report  on  the 

implementation of the EU Action Plan against Wildlife Trafficking, COM/2018/711. 

2   European Commission, Directorate-General for Environment, Study to support the Evaluation and Revision 

of the EU Action Plan against Wildlife Trafficking, Publications Office, 2022. 

3   UNEP/EA.2/INF/28. 

4 

 
                                                 
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  affected4. 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 use5 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  GDP6.  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  networks7.  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 wildlife8. 

4    Abernethy KA, Coad L, Taylor G, Lee ME, ‘Maisels F, Extent and ecological consequences of hunting in 

Central African rainforests in the twenty-first century’. Phil Trans R Soc B 368: 20130494, 2013. 

5 

‘Sustainable  use’  is  defined  by  the  Convention  on  Biological  Diversity  since  1992  as  ‘the  use  of 
components  of  biological  diversity  in  a  way  and  at  a  rate  that  does  not  lead  to  the  long-term  decline  of 
biological diversity, thereby maintaining its potential to meet the needs and aspirations of present and future 
generations’. 

6  Tourism in Africa: Harnessing tourism for growth and improved livelihoods. The World Bank, 2013. 

7  European Commission, Directorate-General  for International Cooperation and Development,  Study on the 
interaction  between  security and  wildlife  conservation  in Sub-Saharan  Africa  Part  I, Publications  Office, 
2020. 

8  

Ibid. 

5 

 
                                                 
2.1.2  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)9, 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 338/9710, 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 CITES11.  

9   See: Convention on International Trade in Endangered Species of Wild Fauna and Flora – CITES. 

10   Council  Regulation  (EC)  No  338/97 of  9  December  1996 on  the  protection  of  species  of  wild  fauna  and 

flora by regulating trade therein. 

11   Before the 2015-2017 reporting period, parties to CITES (including the EU Member States) were required 
to submit CITES reports every two years. A new format for the CITES Implementation Report was adopted 
at the 66th meeting of the CITES Standing Committee (SC66)  which also saw the adoption of a reporting 

6 

 
                                                 
The  EU  and  all  its  Member  States  are  parties  to  the  UN  Convention  against  Transnational 
Organized  Crime  (UNTOC)12,  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]’13. 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 
Statement14,  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  Crime15  (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. 

format  that  saw  reports  published  every  3  years.  See:  Implementation  Reports  (formerly  CITES  Biennial 
Report) for EU Member States; https://cites.org/eng/resources/reports/Implementation_report. 

12   See: United Nations Convention against Transnational Organized Crime (unodc.org) 

13   UNGA Resolution 69/314. 

14    See: Kasane Statement on the Illegal Wildlife Trade (publishing.service.gov.uk) 

15   See: The International Consortium on Combating Wildlife Crime | CITES 

7 

 
                                                                                                                                                        
2.1.3  2.1.3  CHALLENGES IDENTIFIED16 

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 

16   Commission  Staff  Working  Document,  Analysis  and  Evidence  in  support  of  the  EU  Action  Plan  against 

Wildlife Trafficking, 2016. 

8 

 
 
                                                 
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 

9 

 
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 decade17. 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 

17   UNODC, World Wildlife Crime Report 2020: Trafficking in Protected Species, 2020. 

10 

 
                                                 
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 priority18. 

2.1.4  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. 

18   Report  from  the  Commission  to  the  European  Parliament  and  the  Council,  Report  on  the  Generalised 

Scheme of Preferences covering the period 2014-2015, SWD(2016) 8 final. 

11 

 
                                                 
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 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.  

12 

 
 
 
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  trade19.  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  201920.  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 designed21 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.  

19  UNODC, World Wildlife Crime Report 2020: Trafficking in Protected Species, 2020. 

20   TRAFFIC,  Overview  of  seizures  of  CITES-listed  wildlife  in  the  European  Union,  January  to  December 

2020, 2022   

21   See intervention logic diagram in Annex II. 

13 

 
                                                 
3  3  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1 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.  

2020 SEIZURES

Internal
21%

Export
4%

Transit
8%

Import
67%

Figure 1 - Proportion of seizures of illegally traded wildlife by direction of trade22 

EU  Member  State  authorities  consistently  seize  wildlife  in  various  commodity  types 
including medicinals, corals, reptiles, birds, plants, and mammals23. 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  pandemic24.  Medicinals25  (animal  and  plant-derived 
medicinals)  are  consistently  the  top  commodity  reportedly  seized  in  the  EU,  with  1 869 

22    TRAFFIC, An overview of seizures of CITES-listed wildlife in the EU in 2020, 2022.  

23 

Ibid.  

24   Ibid. 

25   Units used to report medicinals are not consistent across EU Member States: some report units as packs of 
tablets others as individual tablets; sometimes no unit is specified, or kg or l is used. Furthermore, under EU 
law, products which are labelled as containing listed species under the EU Wildlife Trade Regulations are 
taken as containing that particular species and may be seized without any verification of the species content 
in the project or DNA testing beforehand. These data can therefore not distinguish between those verified as 
containing listed species from those simply claiming this on the packaging. 

14 

 
 
                                                 
seizure records involving medicinals reported in 201926. 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-TWIX27. 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 EU28. 
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  parties29. 
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 

26   TRAFFIC, An overview of seizures of CITES-listed wildlife in the EU in 2019, 2020. 

27   The EU-TWIX database is an extensive dataset that provides information on wildlife trafficking involving 
the EU. It enables some comparisons between  the period before the adoption of the 2016 action plan and 
the period after the adoption of the 2016 action plan. The database contains more than 52 000 seizures made 
between 1984 and 2015 and more than 29 000 seizures between 2016 and 2022. 

28   See: https://ec.europa.eu/environment/cites/reports_en.htm  

29   See: Annual Illegal trade reports | CITES 

15 

 
 
                                                 
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 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 study30.  

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  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. France31 and the Netherlands32 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 ivory33, 
which was further revised in 2021, leading to an almost complete ban34. 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 

30   See: Annual Illegal trade report | CITES 

31   European Commission, Progress report on the EU Action Plan against wildlife trafficking – France, 2018. 

32   European Commission, Progress report on the EU Action Plan against wildlife trafficking  – Netherlands, 

2018. 

33   European Commission, EU regime governing intra-EU trade and re-export of ivory, 2017. 

34    European Commission, Revised guidance document, EU regime governing trade in ivory, 2021/C 528/03. 

16 

 
                                                 
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 
programme35,  NaturAfrica36,  and  the  Greater  Kilimanjaro  Transfrontier  Conservation  Area 
project (2018-2019)37. 

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)38 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 
rights39.  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  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  work40.  Member  States  have  also  reported 

35  See:  The  Sustainable  Wildlife  Management 

(SWM)  Programme 

-  SWM  Programme 

(swm-

programme.info) 

36   See: NaturAfrica (europa.eu) 

37   See:  Greater  Kilimanjaro  Trans  Frontier  Conservation  Area  Strengthening  Community  Support  for  Law 

Enforcement and Anti-Poaching Efforts | EEAS Website (europa.eu) 

38   See: Enforcement Group - Environment - European Commission (europa.eu) 

39   See:  Corruption  and  human  rights  in  third  countries:  developments  in  EU  external  action  since  2017 

(europa.eu) 

40   Government of Spain, Ministerio de Agricultura y Pesca, Alimentacion y Medio Ambiente, Plan de acción 

español contra el tráfico ilegal y el furtivismo internacional de especies silvestres, 2018. 

17 

 
                                                 
every  year  on  trade  in  CITES-listed  specimens  and  seizures41.  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 industries42. 

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-ENPE43 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,  EMPACT44  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 programme45 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.  

41   See:  Reports  |  CITES.  Cites.org.  Retrieved  21  April  2022,  from  https://cites.org/eng/parties/country-

profiles/eu/reports  

42   See: Enforcement Group - Environment - European Commission (europa.eu) 

43   See: EU Life Project: LIFE-ENPE (LIFE 14 GIE/UK000043) | ENPE-European Network of Prosecutors for 

the Environment (environmentalprosecutors.eu) 

44   European  Multidisciplinary  Platform  Against  Criminal  Threats  (EMPACT)  is  a  security  initiative  to 

identify and address threats from international crime. 

45   See: EU Policy Cycle - EMPACT | Europol (europa.eu) 

18 

 
                                                 
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 – Europol46. It saw the participation of several Member States47.  

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  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 202048. 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 BIOPAMA49 and the Monitoring the Illegal Killing 
of Elephants project50. 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 action51. 

46   Europol, “Wildlife crime: European seizures and arrests in global Operation Thunderstorm”, 21 June 2018.  

47   CITES,  ‘Global  arrests  and  seizures:  WCO-INTERPOL  Operation  Thunder  2021  strikes  wildlife  and 

timber trafficking networks’, 30 November 2021.   

48   OECD,  ‘European  Union  institutions’,  in  Development  Co-operation  Profiles,  OECD  Publishing,  Paris, 

2022. 

49   See: BIOPAMA.org 

50   See: Monitoring the Illegal Killing of Elephants (MIKE) | IUCN 

51   See: WCS EU > Our Work > Wildlife Trafficking > Partners against Wildlife Crime 

19 

 
                                                 
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 
elephants52’  strategy),  Asia  (the  ‘Larger  than  tigers’  strategy53)  and  Latin  America  (the 
‘Larger than jaguars’ strategy54) 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 species55. The relevant EU authorities have also actively cooperated with 
non-EU  countries.  SADC-TWIX56,  Africa-TWIX57  and  Eastern-Africa  TWIX58  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 wildlife59.  

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  Assembly60.  The  EU  also 

52   European  Commission,  Directorate-General  for  International  Cooperation  and  Development,  MacKinnon, 
J., Aveling, C., Olivier, R., et al.,  Larger than elephants: inputs for an EU strategic approach to wildlife 
conservation in Africa: synthesis, Publications Office of the European Union, 2017. 

53   European  Commission,  Directorate-General  for  International  Cooperation  and  Development,  Larger  than 
tigers: inputs for a strategic approach to biodiversity conservation in Asia: regional reports, Publications 
Office, 2019. 

54   European  Commission,  Directorate-General  for  International  Partnerships,  Aragón,  R.,  Arguedas,  S., 
Blumetto,  O.,  et  al.,  Larger  than  jaguars:  inputs  for  a  strategic  approach  to  biodiversity  conservation  in 
Latin America and the Caribbean: synthesis report, Mayaux, P.(editor), Villanueva Hullebroeck, P.(editor), 
Van Houtte, F.(editor), Marijnissen, C.(editor), Chatelus, S.(editor), Saracco, F.(editor), Publications Office 
of the European Union, 2021. 

55   London School of Economics, Velut, JB., Baeza-Breinbauer, D., De Bruijne, M., Garnizova, E., Jones, M., 
Kolben,  K.,  Oules,  L.,  Rouas,  V.,  Tigere  Pittet,  F.,  Zamparutti,  T.    Comparative  Analysis  of  Trade  and 
Sustainable Development Provisions in Free Trade Agreements, 2022.  

56    See: SADC-TWIX 

57   See: AFRICA-TWIX 

58   See: Eastern Africa-TWIX 

59   European Commission, Directorate-General  for International Cooperation and Development,  Study on the 
interaction  between  security and  wildlife  conservation  in Sub-Saharan  Africa  Part  I, Publications  Office, 
2020. 

60   See  the  statement  made  by  the  EU:  https://www.eeas.europa.eu/delegations/un-new-york/eu-statement-

%E2%80%93-united-nations-general-assembly-resolution-tackling-illicit_en. 

20 

 
 
 
 
                                                 
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. 

4  4  EVALUATION FINDINGS 

4.1 4.1  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY?  

4.1.1  4.1.1  EFFECTIVENESS 

4.1.1.1 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 2016-201861. 
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 

61   European Commission, Revised guidance document, EU regime governing trade in ivory, 2021/C 528/03. 

21 

 
                                                 
(330)  accounted  for  79%  of  2020  seizures62.  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  offenders63.  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  trafficking64,  and  another  on  the  online 
trade in reptiles and birds in Belgium and the Netherlands65. 

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)66 and Operation 
Fame (2019)67 focused on eel trafficking. Mainly carried out by Spain’s Guardia Civil, with 
support  from  Europol  and  AMERIPOL,  Operation  SUZAKU68  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 

62   TRAFFIC, An overview of seizures of CITES-listed wildlife in the EU in 2020, 2022. 

63    Interpol,  ‘Global  arrests  and  seizures:  INTERPOL-WCO  operation  strikes  wildlife  and  timber  trafficking 

networks’, 30 November 2021 

64    TRAFFIC and WWF, Tackling Wildlife Cybercrime in the EU: how technology can help, 2020. 

65   TRAFFIC  and  WWF,  Top  Wildlife  Cybercrime  in  the  EU:  Online  trade  in  reptiles  and birds  in  Belgium 

and the Netherlands, 2020. 

66   OLAF, “OLAF in operation against trafficking of endangered species”, 24 June 2022.  

67   Europol, “Over 5 tonnes of smuggled glass eels seized in Europe this year”, 6 November 2019. 

68   Europol,  “Illegal  trade  in  endangered  species:  29  arrests  and  over  2,000  animals  seized  in  international 

Operation SUZAKU”, 20 December 2017. 

22 

 
                                                 
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 
improved  coordination,  cooperation,  and 
communication between Member States, non-EU countries, and international institutions, as 
well as between Member States’ own enforcement agencies.  

to  continue  support  for 

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  EU69.  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. 

69   According to the latest  figures issued by the World Shipping Council (2019), the following EU ports are 
ranked  among  the  top  50  world  container  ports  based  on  container  traffic  (measured  in  twenty-foot 
equivalent units): Rotterdam, the Netherlands (10th); Antwerp, Belgium (14th); Hamburg Germany (18th); 
Piraeus, Greece (28th); Valencia (30th) and Algeciras, Spain (34th); Bremen/Bremerhaven (36th).  

23 

 
                                                 
Some  Member  States  have  transposed  the  action  plan  into  national  action  plans,  including 
Spain70, Germany, Slovenia71 and Czechia72. 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  trade73.  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’74. 
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. 

4.1.1.2 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.  

70   Government of Spain, Ministerio de Agricultura y Pesca, Alimentacion y Medio Ambiente, Plan de acción 

español contra el tráfico ilegal y el furtivismo internacional de especies silvestres, 2018.  

71   Government  of  Sweden,  Government  Communication  Comm.  2016/17:126  Combating  crime  together.  A 

national crime prevention programme, 2017. 

72   Government of Czechia, Action Plan to Combat Illegal Trade in Endangered Species of Animals and Plants 

by the year 2023, 2021.  

73   See  e.g.  Lemaître  &  Hervé-Fournerau  (2020)  ‘Fighting  Wildlife  Trafficking:  An  Overview  of  the  EU’s 
Implementation  of  Its  Action  Plan  Against  Wildlife  Trafficking’,  Journal  of  International  Wildlife  Law  & 
Policy, 23:1, 62-81, 2020. 

74   Europol, Environmental Crime in the Age of Climate Change - Threat assessment 2022, Publications Office 

of the European Union, Luxembourg, 2022. 

24 

 
                                                 
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 

25 

 
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.  

4.1.1.3 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  4.1.2  EFFICIENCY 

4.1.2.1 To what extent have actions under the action plan been cost-effective? 
What  are  the  overall  costs  and  benefits  of  the  action  plan’s 

26 

 
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 trade75.  

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  EUR76.  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.  

4.1.2.2 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 

75   Lemaitre,  S.,  and  Hervé-Fournerau,  N.,  Fighting  Wildlife  Trafficking:  An  Overview  of  the  EU’s 
Implementation  of  Its  Action  Plan  Against  Wildlife  Trafficking,  Journal  of  International  Wildlife  Law  & 
Policy vol. 23 no. 1 pp. 62-81. 

76   WWF, Living planet report 2020: Bending the curve of biodiversity loss, 2020. 

27 

 
                                                 
and Human Rights (2014-2020) to provide training on tools and methods related to the fight 
against corruption in non-EU countries77. 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. 

4.1.2.3 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.  

77   Regulation  (EU)  No  235/2014  of  the  European Parliament  and  of  the  Council  of  11  March  2014 

establishing a financing instrument for democracy and human rights worldwide. 

28 

 
                                                 
4.1.3  4.1.3  COHERENCE 

4.1.3.1 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.  

4.1.3.2 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 Deal78 and the EU biodiversity strategy79. 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 

78   See: A European Green Deal | European Commission (europa.eu) 

79   See: Biodiversity strategy for 2030 (europa.eu) 

29 

 
                                                 
proposal  for  the  EU  deforestation-free  products  regulation80),  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 203081, presented 
in 2020 as part of the European Green Deal.  

The  objectives  of  the  2016  action  plan  and  the  Habitats82  and  Birds83  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 plan84 (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.  

80   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. 

81    Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions, EU Biodiversity Strategy for 2030: Bringing nature 
back into our lives, COM/2020/380 final. 

82   Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and 

flora. 

83   Directive  2009/147/EC  of  the  European  Parliament  and  of  the  Council  of  30  November  2009  on  the 

conservation of wild birds. 

84   Communication  from  the  Commission  to  the  Council  and  the  European  Parliament  -  Forest  Law 
Enforcement, Governance and Trade (FLEGT) - Proposal for an EU Action Plan, COM/2003/0251 final. 

30 

 
                                                 
The  IUU  Fishing  Regulation85  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 law86) 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  Act87  (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 directive88 (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)89,  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’90  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 

85   Council  Regulation  (EC)  No  1005/2008  of  29  September  2008  establishing  a  Community  system  to 
prevent,  deter and eliminate  illegal,  unreported and unregulated fishing, amending Regulations (EEC) No 
2847/93, (EC) No 1936/2001 and (EC) No 601/2004 and repealing Regulations (EC) No 1093/94 and (EC) 
No 1447/1999.  

86   Directive  2008/99/EC  of  the  European  Parliament  and  of  the  Council  of  19  November  2008  on  the 

protection of the environment through criminal law. 

87   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. 

88   Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  on  Corporate  Sustainability  Due 

Diligence and amending Directive (EU) 2019/1937.  

89   Proposal for a Directive of the European Parliament and of the Council on asset recovery and confiscation, 

COM(2022) 245 final.  

90  

'One Health' is an approach to designing and implementing programmes, policies, legislation and research 
in which multiple sectors communicate and work together to achieve better public health outcomes. 

31 

 
                                                 
disease-control  measures  in  the  wildlife  trade  in  order  to  protect  animal  and  human  health 
worldwide91. 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’92.  

4.1.3.3 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 resolution93 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.  

91   CITES, “World Animal Health Organisation (OIE) and CITES agree to collaborate on animal health and 

welfare issues worldwide to safeguard biodiversity and protect animals”, 12 January 2021. 

 92  See The New European Consensus on Development: 

https://www.consilium.europa.eu/media/24004/european-consensus-on-development-2-june-2017-
clean_final.pdf  

93  CITES-E-CoP17-28  

32 

 
                                                 
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 4.2  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE? 

4.2.1  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 

33 

 
of  the  Expert  Group94  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)95  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  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 

94   The  Expert  Group  is  group  of  experts  of  the  competent  CITES  Management  Authorities  composed  of 
representatives from Member State Management Authorities and chaired by the Commission. The role of 
this expert group is to provide advice and expertise to the Commission and its services in relation to issues 
related to the EU rules on trade in species of wild fauna and flora which do not fall under the competence of 
the Committee on Trade in Wild Fauna and Flora. 

95   The  Serious  and  Organised  Crime  Threat  Assessment  (SOCTA)  updates  Europe’s  law  enforcement 
community  and  decision-makers  on  such  developments  in  serious  and  organised  crime  and  the  threats  it 
poses to the EU. 

34 

 
                                                 
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 4.3  IS THE INTERVENTION STILL RELEVANT? 

4.3.1  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 profits96.  

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)97.  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  trafficking98.  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 

96   Europol, Environmental Crime in the Age of Climate Change - Threat assessment 2022, Publications Office 

of the European Union, Luxembourg, 2022. 

97   IPBES,  Global  assessment  report  of  the  Intergovernmental  Science-Policy  Platform  on  Biodiversity  and 
Ecosystem  Services,  Brondízio,  E.  S.,Settele,  J.,  Díaz,  S.,  Ngo,  H.  T.  (eds).  IPBES  secretariat,  Bonn, 
Germany, 2019. 

98   Europol, Environmental Crime in the Age of Climate Change - Threat assessment 2022, Publications Office 

of the European Union, Luxembourg, 2022. 

35 

 
                                                 
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  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. 

36 

 
(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 trade99. 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 project100 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 products101.  

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 zoonosis and pandemics. 

Tracking of financial flows 

An  important  area  of  increased  interest  in  the  fight  against  wildlife  trafficking  is  the 
tracking of illicit financial flows. The ‘follow-the-money’ approach enables enforcement 
to  go  beyond  singular  cases  of  trafficking  and  to  identify  and  punish  trafficking  and 
organised crime networks. Although actions in the action plan address the links between 
wildlife  trafficking  and  organised  crime,  these  actions  are  not  always  sufficiently 
effective. 

99   TRAFFIC, ‘Chinese internet giants launch alliance to combat wildlife cybercrime’, 2 November 2017.  

100   Project  factsheet  available  from:  https://cites.org/sites/default/files/I/EU%20WWF%20PROJECT%20-

%20Wildlife%20Cybercrime%20project%20factsheet.pdf 

101   Coalition  to  end  wildlife  trafficking  online,  Coalition  to  end  wildlife  trafficking  online:  2021  progress 

update, 2021.  

37 

 
 
 
 
                                                 
5  5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1 5.1  CONCLUSIONS 

The  action  plan  has  raised  the  profile  of  the  fight  against  the  illegal  wildlife  trade  and 
contributed  to  increased  efforts  to  tackle  it.  However,  assessing  the  achievements  of  the 
action  plan  and  its  priorities  is  challenging  due  to  the  lack  of  a  baseline,  the  difficulty  of 
establishing  a  monitoring  and  evaluation 
lack  of  key 
measurable/performance  indicators.  Efforts  to  tackle  the  illegal  wildlife  trade  were  already 
being  implemented  before  the  adoption  of  the  action  plan,  at  both  Member  State  and  EU 
levels. In addition, while many actions have been quite successful, the illegal wildlife trade is 
unlikely to be stopped in the near future. 

framework,  and 

the 

Despite these limitations, the evaluation has identified progress in all areas of the action plan 
since 2016. The action plan has been a crucial tool to coordinate the many aspects of the fight 
against wildlife trafficking and to raise the profile of this fight at Member State level, within 
the EU, and internationally. Although it is difficult to assess the extent to which this progress 
is  attributable  to  the  action  plan  itself,  there  are  indications  that  the  approach  in  the  action 
plan  remains  a  valid  comprehensive  framework  for  tackling  the  fight  against  wildlife 
trafficking in the EU and its Member States.  

However,  the  comprehensive  and  ambitious  nature  of  the  action  plan  does  present  its  own 
challenges.  The  primary  challenges  to  implementation  identified  by  stakeholders  were  the 
persistent lack of skilled staff and money, and the action plan’s wide-ranging scope. Member 
States  said  that  they  often  lacked  the  time  and  staff  to  implement  actions  and  faced 
difficulties in coordinating action between different authorities and actors at a national level, 
as well as in reporting.  

5.2 5.2  LESSONS LEARNED 

The action plan’s focus on implementability and on aligning existing actions, tools and 
processes  has  likely  contributed  to  improved  coordination  and  raised  the  political 
priority of the fight against wildlife trafficking.  

The action plan is comprehensive and ambitious. The focus on tackling the illegal wildlife 
trade from source to consumer, engaging actors at all levels and along the  chain – although 
the engagement of civil society could be made more systematic – makes it possible to address 
the issue from all angles. 

The main barrier to the  success of the action plan has been a lack of resources, both  at EU 
and Member State levels. There is an urgent and continuing need for more resources and 
skilled  staff  to  combat  wildlife  trafficking  within  the  EU.  The  wide  scope  and 
comprehensive nature of the action plan was identified by stakeholders as one of its major 
strengths. Focus should not be put, therefore, on reducing the ambition of the action plan, but 
rather on matching that ambition with the sufficient allocation of resources.  

At  the  same  time,  given  limited  resources,  the  fact  that  the  action  plan  has  tapped  into 
existing  EU  and  Member  State  efforts  and  responsibilities  in  the  fight  against  wildlife 
trafficking seems to have been a factor in its success. The action plan must use resources in a 
smart  way:  (i)  focusing  on  key  issues  where  EU  action  can  be  harnessed  for  the  greatest 
impact; (ii) using modern technology; and (iii) ensuring coordination so no effort is wasted.  

38 

 
There  is  a  need  to  develop  a  well-designed  reporting,  evaluation,  and  monitoring 
framework for the implementation of the action plan. This should provide an overview of 
implementation  at  EU  and  national  levels  and  capture  the  impacts  of  this  implementation. 
This framework should also consider the available financial and human resources at both the 
EU and national levels and use existing tools and reporting mechanisms where possible.  

Efforts  to  combat  wildlife  trafficking  online  must  be  strengthened.  Although  the  action 
plan  has  helped  the  authorities  to  act  against  online  wildlife  trafficking,  stakeholders 
repeatedly  reported  that  this  action  was  inadequate.  In  addition,  the  action  plan  must 
continue  to  respond  to  new  trends,  aligning  in  particular  with  efforts  elsewhere  in  the 
world,  such  as  aligning  with  the  focus  on  tracking  financial  flows  to  tackle  the  organised 
crime  aspect  of  wildlife  trafficking,  and  the  increasingly  recognised  need  to  ensure  that 
measures taken under the action plan align with a ‘One Health’ approach.  

There is  a need for greater  cooperation within the  EU, including between the European 
Commission and EU agencies. This  would  help to  promote effective cooperation on  shared 
issues,  which  include  online  trade,  customs  monitoring,  international  cooperation,  and 
enforcement.  The  fight  against  wildlife  trafficking  should  be  further  mainstreamed  into 
relevant policy areas.  

Stakeholders  must  be  engaged  in  the  implementation  of  the  action  plan.  Greater 
engagement  with  external  stakeholders,  including  civil  society,  the  business  sector,  and 
expert groups will help to: (i) improve enforcement and cooperation in implementation; and 
(ii) pool collective knowledge/experience to ensure that this implementation is effective.  At 
the  international  level,  it  is  crucial  that  indigenous  people,  local  communities,  women,  and 
young people are engaged in all wildlife conservation programmes.  

Member States should be encouraged to adapt the action plan to their national context, 
to  ensure  stronger  implementation,  higher  prioritisation,  and  improved  inter-agency 
collaboration at the national level.  

Efforts to improve the detection of wildlife trafficking need to be matched by an increase in 
appropriate  and  dissuasive  sanctioning.  To  achieve  this,  funding  and  training  of  public 
prosecutors and the judiciary must be strengthened, with a view to creating specialised forces 
and bodies that are able to respond to the threat of wildlife trafficking.  

39 

 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

Lead 

DG  Environment  has 
PLAN/2019/6139. 

Organisation 

led 

this  evaluation  which 

is 

included 

in  Decide  under 

DG  Environment  has  carried  out  the  evaluation  in  consultation  with  the  Interservice  group 
(ISG)  on  Wildlife  Trade.  The  ISG  consists  of  the  following  DGs/services:  AGRI,  CNECT, 
FISMA,  FPI,  HOME,  INTPA,  JUST,  LS,  MARE,  OLAF,  RTD,  SANTE,  SG,  TAXUD, 
TRADE and the EEAS. 

Timeline 

Signature of contract 

Kick-off meeting of Interservice Group (ISG) 
Launch of open public consultation102  
(OPC – 12 weeks) 

Targeted expert consultation  

Publication for feedback of the action plan revision 
roadmap103  

Written consultation of ISG on the inception report 

Analysis of replies to the OPC 

Written consultation of ISG on technical analysis of the OPC 
and targeted expert consultations  

Online workshop with stakeholders and Member States  
(to present and discuss initial consultation findings) 

Meeting of ISG 

CITES Enforcement Group 

Written consultation of ISG on draft evaluation  

5 October 2020 

16 October 2020 

5 October-28 December 2021 

25 October-28 December 2021 

5 October-2 November 2021 

28 October 2021 

February 2022 

22 February 2022 

16 March 2022 

29 March 2022 

27 April 2022 

25 May 2022 

Drafting of evaluation and revised action plan 

June-August 2022 

Adoption and publication of the Communication for a 
revised action plan and evaluation (SWD) 
Although the initial adoption of the action plan was planned for late 2021, it had to be 
postponed to 2022.  

By end of October 2022 

External expertise 

The  evaluation104  was  conducted  by  an  external  consultant  through  a  DG  ENV  framework 
contract.  The deliverables were  generally of limited quality and provided late. The contract 
therefore had to be extended and the adoption of the evaluation postponed. 

102   See: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12675-Preventing-illegal-

trade-in-wildlife-revision-of-EU-action-plan/public-consultation_en  

103   See: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12675-Preventing-illegal-

trade-in-wildlife-revision-of-EU-action-plan_en  

104 European Commission, Directorate-General for Environment, Study to support the Evaluation and Revision 

of the EU Action Plan against Wildlife Trafficking, Publications Office, 2022 

40 

 
                                                 
ANNEX II:    METHODOLOGY AND ANALYTICAL MODELS USED 

Methodology 

The  Commission  and  external  contractors  (Bio  Innovation  Service)  coordinated  various 
consultation activities between October 2021 and March 2022 as part of the evaluation of the 
EU Action Plan against Wildlife Trafficking (EU action plan). These consultation activities 
aimed to understand the progress made within the three priority areas of the EU  action plan 
and how the actions could be improved by identifying: (i) best practices; (ii) the actions that 
were not successful; (iii) lessons learnt; and (iv) identification of possible changes.  

In  addition  to  these  consultation  activities,  the  EU  action-plan  evaluation  exercise  was 
regularly presented and discussed in various meetings organised by the Commission, such as 
the  Interservice  Group  (ISG),  the  EU  Wildlife  Trade  Enforcement  Group,  and  the  Expert 
Group. To cope with both the lack of data available to make a quantitative evaluation and the 
comprehensive  nature  of  the  action  plan,  the  evaluation  was  designed  to  draw  on  the 
collective experience and knowledge of the widest variety of relevant stakeholders.  

Draft  versions  of  the  evaluation  were  shared  within  the  ISG  to  gather  input  from  the 
Commission.  Where  substantial  input  was  required,  bilateral  meetings  were  organised 
between the relevant services and DG Environment. 

Data 

Where available, publicly available data  were used to supplement consultations. These data 
were drawn mainly from the following three types of sources: 

1.  reports  from  respected  international  institutions  and  NGOs  working  on  wildlife 

trafficking;  

2.  reports from EU bodies and agencies (for example Europol); 
3.  yearly  reports on legal and illegal trade from Member States, as reported by UNEP-

WCMC and TRAFFIC, respectively. 

It should be noted that data on wildlife trafficking are only suggestive of trends, and cannot 
be used to accurately identify the impact of action against wildlife trafficking on  the illegal 
wildlife trade. Many factors (such as resource investment by Member States, the geographical 
patterns  of  wildlife  trafficking,  or  disproportionate  interest  by  consumers  or  enforcement 
authorities in specific species or sectors) can influence the data available and what they can 
tell us. In addition, the scope of the action plan goes beyond simple seizures. The action plan 
seeks to address the root causes of wildlife trafficking, as well as to strengthen enforcement 
beyond seizures. For this reason, data were used for illustrative rather than purely analytical 
purposes.  This  was  supported  by  a  literature  review  conducted  by  the  consultants  and  the 
Commission.  The  evaluation  centred  mainly  around  discussions  held  at  consultations  and 
meetings. 

41 

 
 
 
Figure 2 - Intervention logic diagram provided by external consultants 

42 

 
 
Open public consultation (OPC) 

The  OPC  was  open  for  12  weeks,  from  5  October  2021  to  28  December  2021.  The  OPC 
questionnaire was uploaded to the EU’s ‘Have Your Say portal’, and the questionnaire was 
available in all the EU's official languages. The questionnaire was open to all EU citizens and 
organisations interested in the EU action plan against wildlife trafficking. Respondents were 
able to respond to the questionnaire as individuals or on behalf of an organisation/institution. 

The OPC aimed to gather evidence and opinions on the effectiveness, efficiency, coherence, 
relevance and EU added-value of the EU action plan against wildlife trafficking.  

The  OPC  contained  24  questions  split  into  214  sub-questions,  of  which  191  were  closed-
ended, and 23 were open text. The questionnaire was structured around the following specific 
topics:  (i)  raising  awareness  of  the  illegal  wildlife  trade;  (ii)  the  extent  of  stakeholder 
actions/responsibilities/burdens  in  tackling  the  illegal  wildlife  trade;  (iii)  the  extent  of 
Member State implementation of the action plan and effective enforcement against the illegal 
wildlife trade; (iv) the effectiveness of monitoring and reporting measures; (v) perceptions of 
trends  related  to  the  illegal  wildlife  trade  since  2016  at  the  national,  EU,  and  international 
levels; and (vi) the extent to which further work is needed to tackle the illegal wildlife trade.  

Targeted expert consultations  

The consultation strategy included the following five main elements: 

  stakeholder identification and mapping;  
  a  targeted  stakeholder  survey  with  key  stakeholders  and  experts  to  gather  more 

 

detailed information; 
interviews  with  selected  stakeholders  to  clarify  and/or  complement  the  information 
received through the targeted stakeholder survey;  

  a workshop.  

The targeted consultation of stakeholders had the two-fold objective of: (i) collecting missing 
data  required  for  evaluating  the  action  plan;  and  (ii)  using  the  material  collected  to 
complement  the  literature  review  and  the  OPC.  The  targeted  consultations  were  conducted 
along the  following  eight  themes, which were identified from  the objectives, priorities, and 
actions of the EU action plan:  

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 

awareness raising; 
supporting community engagement in tackling illegal wildlife trade; 
capacity building and training for Member States authorities and institutions; 
strengthening compliance with legislation and improving enforcement; 
strengthening cooperation; 
strengthening legislation; 
improving knowledge and monitoring of illegal wildlife trade; 
raising the profile of the fight against illegal wildlife trade. 

The  targeted  expert  consultation  included  two  activities:  a  targeted  expert  survey  and 
stakeholder  interviews.  The  targeted  expert  survey  was  open  for  8  weeks  from  28  October 
2021  to  28  December  2021.  The  stakeholder  interviews  were  then  conducted  with  those 
experts  who  agreed  to  be  contacted  and  interviewed.  These  were  scheduled  and  conducted 
after the targeted expert survey’s deadline, during January 2022.  

43 

 
Stakeholder workshop 

To  complement  the  OPC  and  the  targeted  expert  consultations  (targeted  expert  survey  and 
stakeholder  interviews),  an  online  stakeholder  workshop  was  organised  to  present  the 
preliminary findings of the consultation activities. The goal of this workshop was to update 
stakeholders  on  the  state  of  the  evaluation  of  the  EU  action  plan  and  to  identify  possible 
measures/options  for  its  revision  based  on  input  received  during  the  consultations  and  any 
additional evidence provided by stakeholders.  

There  were  67  participants  at  the  stakeholder  workshop.  The  stakeholder  groups  included: 
management authorities (31.3%, 21/67); enforcement agencies (10.4%, 7/67); NGOs (25.4%, 
17/67);  international  organisations  (IOs)  (10.4%,  10/67);  European  institutions  (EIs)  (8.9%, 
6/67);  business  associations  (2.9%,  2/67);  companies  (2.9%,  2/67);  industry  associations 
(4.4%, 3/67); lobby groups (1.5%, 1/67); academic/research institutions (1.5%, 1/67).  

Stakeholders  from  EU  and  non-EU  states  participated  as  follows:  Austria  (4.5%,  3/67), 
Belgium (10.4%, 7/67), Croatia (1.5%, 1/67),  Czech Republic  (2.9%, 2/67), Finland (1.5%, 
1/67), France (10.4%, 7/67), Germany (10.4%, 7/67), Greater Mekong region105 (1.5%, 1/67), 
Italy  (1.5%,  1/67),  Latvia  (1.5%,  1/67),  Netherlands  (5.9%,  4/67),  Poland  (2.9%,  2/67), 
Portugal  (1.5%,  1/67),  Slovakia  (1.5%,  1/67),  Slovenia  (1.5%,  1/67),  Spain  (4.5%,  3/67), 
United  Kingdom  (1.5%,  1/67),  USA  (1.5%,  1/67).  The  remaining  stakeholders  represented 
European organisations (13.4%, 9/67) and international organisations (19.4%, 13/67). 

The discussions were focused on the three priorities of the EU action plan. Each priority was 
discussed  in  four  breakout  groups,  and  each  group  had  a  moderator  and  rapporteur.  The 
groups  identified  the  strengths  and  weaknesses  of  the  EU  action  plan  and  ideas  for  its 
improvement. 

Commission meetings  

A  meeting  of  the  ISG  was  held  on  29 March 2022.  At  this  meeting,  the  outcomes  of  the 
previous  consultations  and  the  stakeholder  workshop  were  summarised,  and  initial 
impressions and input were shared by the DGs present.  

The  EU  Wildlife  Trade  Enforcement  Group  met  on  27 April 2022.  At  this  meeting, 
enforcement  officers  from  Member  States  were  presented  with  a  structured  list  of 
enforcement-specific  questions,  and  asked  to  share  their  experiences.  The  subjects  covered 
were: (i) implementation of the action plan at national level; (ii) information sharing and risk 
profiling  between  national  agencies  and  between  Member  States;  (iii)  training  along  the 
enforcement  chain,  with  a  focus  on  judges  and  prosecutors;  (iv)  addressing  online  wildlife 
trafficking; (v) digital tools that help with enforcement; and (vi) how the EU could deal with 
nationally protected species that are illegally traded in the EU.  

The Expert Group met on 1 July 2022. At this meeting, Member States were asked to react to 
outcomes of the evaluation, and possible ways forward for a revised action plan.  

In addition, draft versions of the evaluation were shared with the ISG between May and July 
2022, gathering substantial written input. 

105 Cambodia, Laos, Myanmar, Thailand, Vietnam, and China. 

44 

 
                                                 
ANNEX III:  EVALUATION MATRIX  

Note: This evaluation matrix was before the start of consultations. Where the evaluation questions have been edited or abandoned, a small note 
has been added. 

Effectiveness 

The effectiveness criterion assesses how successful the action plan has been in achieving or progressing towards its objectives. It will cover the 
seven evaluation questions identified in the terms of reference (ToR) as presented in the evaluation matrix below. 

Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

1. To what extent have the three priorities and their corresponding objectives been met? 

Progress  made  in  EU  as  a 
whole? 

Progress  made  in  different 
Member States? 

To  what  extent  does  the 
progress 
the 
objectives  of  the  action 
plan (in terms of timeline)?  

match 

To  what  extent  can  the 
achieved  results/effects  be 

Examining 
effort 
in 
States 

enforcement 
the  Member 

Performance  of  Member 
States in integrating action 
plan 
into 
objectives 
national policies 

Performance  of  Member 
States 
implementing 
these national policies 

in 

Whether wildlife crime has 
been a priority since 2016, 
resources 
allocation  of 
available  for  the  Member 
States  in  tackling  wildlife 
of 
crime, 
operations 
and 
investigations  conducted, 
etc.  Change  in  legislation, 
policies,  and  practices  in 
Member States. 

number 

The  role  of  the  EU  and 

Qualitative 
discussion 
based  on  logical  analysis 
of  the  collected  evidence 
and input from stakeholder 
consultation  on  whether 
the actions are all working 
together 
towards 
delivering the objectives 

of, 
for 
Assessment 
stakeholder 
example, 
literature 
views 
consensus  on  the  extent  to 

and 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

45 

 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

credited to the action plan? 

If  any  objectives  of  the 
action  plan  not  achieved 
(or partially achieved) 

Member 
international fora 

States 

in 

results 
which 
credited to the action plan 

can  be 

Stakeholder interviews  

Has there been more focus 
on specific objective(s)?  

Difference  between  results 
and expectations 

View  of  both  stakeholders 
State 
Member 
and 
authorities 

International 
organisation’s view 

of 

drivers 

(e.g. 
List 
political  support,  active 
research  community)  and 
barriers 

of 

List 
expectations 

effects 

/ 

Group 
expected 
unexpected effects 

and 

2. What factors have contributed to or hindered their achievement? 

46 

 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

To  what  extent  are  the 
provisions  of  the  action 
to 
plan 
sufficient 
the  good 
to 
contribute 
implementation 
its 
objectives?  

of 

Other contributing factors? 

Hindrance factors? 

Missed opportunities? 

Factors 
achievement: 

affecting 

the 

  National 

legislation, 

policies, and practices 

Compliance 
enforcement 

and 

Technical 

Legal 

Economic 

both 
and 
State 

  View 

of 
stakeholders 
Member 
authorities  
  International 
organisations 

  New 

techniques 

for 
seizures (e.g. for ivory) 
and 

  Arrests 

prosecutions 

  Provision of resources 
  Penalties  imposed  and 

other deterrents 

47 

discussion 
Qualitative 
based  on  logical  analysis 
of  the  collected  evidence 
and input from stakeholder 
consultation  on  the  factors 
that have contributed to  or 
hindered their achievement 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

Stakeholder feedback 

source 

Crime 
Environmental 
Evaluation, 
if  published 
soon  (as  expected)  should 
also  be  a  useful  source  of 
Another 
information. 
of 
useful 
information  will  be  any 
information  on  EMPACT 
or  any  information  from 
Europol/DG  HOME  (with 
EMPACT 
ECD, 
crime 
environmental 
being 
priority 

all 

 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

synergistic initiatives). 

3.  To  what  extent  have  the  actions  listed  in  the  action  plan  been  carried  out,  and  what  has  been  their  (quantitative  and  qualitative)  impact, 

especially in reducing the ILLEGAL WILDLIFE TRADE? 

NB: Question merged with Q1. 

Progress made in actions. 

Qualitative effects? 

Quantitative effects? 

Progress 
action 
of 
(achieved  by  the  timeline 
achieved 
indicated, 
partially,  or  not  achieved 
at all)  

  National 

legislation, 

policies, and practices 
  View  of  stakeholders 
and  Member  State 
authorities 

  Arrests 

and 

Qualitative  discussion  of 
action’s  implementation  in 
Member  States  based  on 
logical  analysis  and  input 
from  stakeholders  on  the 
trafficking pattern 

Desk research 

Literature review  

OPC questionnaire 

prosecutions 

  Penalties  imposed  and 

other deterrents 

Quantitative  analysis  of 
the  data  on  poaching  and 
availability  of  products 
sourced 
from  wildlife 
trafficking 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

1.   Have there been any unintended or unexpected effects of the action plan? What are they? 

48 

 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

NB: Insufficient data to answer question. 

Unintended effects? 

Unexpected effects? 

Unintended effects of each 
if  Yes, 
action  (Yes/No, 
what are those effects)  

  National 

legislation, 

policies, and practices 
  View  of  stakeholders 
and  Member  State 
authorities 

  Arrests 

and 

Qualitative  discussion  of 
action’s  implementation  in 
Member  States  based  on 
logical  analysis  and  input 
from  stakeholders  on  the 
trafficking pattern 

Desk research 

Literature review  

OPC questionnaire 

prosecutions 

  Penalties  imposed  and 

other deterrents 

Quantitative  analysis  of 
the  data  on  poaching  and 
availability  of  products 
from  wildlife 
sourced 
trafficking 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

5.   How effective has the reporting and monitoring of progress towards action plan objectives (and/or actions listed in the action plan) been? 

How  timely  is  the  process 
and 
reporting 
for 

Content of reporting 

Monitoring frequency 

Monitoring 

plans 

in 

Qualitative  discussion  on 
reporting  and  monitoring 
across 
requirements 

Questionnaires 
and 
interviews  with  EU  and 

49 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

monitoring? 

Member States 

is 

efficient 

How 
the 
process  for  reporting  and 
monitoring? 

Member  States  based  on 
logical  analysis  and  input 
from stakeholders 

national authorities 

OPC 

6.  Did the action plan encourage cooperation between Member States? If so, to what extent? 

NB: Merged with question 1 

What  measures  were 
applied by Member States? 

Cooperation  actions  taken 
by Member States  

How  effective  were  the 
inspections/ 
cooperative 
the 
investigations 
Member States? 

by 

Qualitative  discussion  on 
reporting  and  monitoring 
across 
requirements 
Member  States  based  on 
logical  analysis  and  input 
from stakeholders 

Desk research 

Literature review  

OPC questionnaire 

Assessment  of  stakeholder 
views 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

on 

Views 
inspections/investigations 
and  success 
practices 
from 
Member States) 

(best 
specific 

rate 

involvement 

MS 
EMPACT OAPs 

in 

Number of Member States 
which initiated the actions 

of 
Number 
inspections/investigations, 

50 

 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

and  whether  this  number 
represents 
an 
increase/decrease 
compared 
before the action plan 

the  period 

to 

7. To  the  extent  that  significant  divergences  in  implementation  remain  between  Member  States,  what  are  those  divergences  and  what  is 
causing them? Are such divergences influencing the achievement of the three priority objectives of the action plan?  

NB: Merged with question 2 

National 
voluntary initiatives 

legislation  and 

action 

implementation 
The 
through  which 
measures 
plan  was 
the 
fulfilled 
through 
i.e. 
existing/new  legislation  or 
by a voluntary approach 

Qualitative  discussion  on 
across 
implementation 
Member  States  based  on 
logical  analysis  and  input 
from stakeholders 

Desk research 

Legal  analysis  that  would 
illustrate  divergences 
in 
the  implementation  of  the 
action plan 

Literature review  

OPC questionnaire 

51 

 
 
 
 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
Data-collection methods 

sources/ 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

8. How has implementation of the action plan been affected by relevant initiatives, including stricter domestic measures, at Member State 
level? 

NB: Insufficient data to answer question. 

How  the  implementation 
has  been  affected  by  the 
ECD? 

has 

How 
affected implementation? 

EMPACT 

National 
voluntary initiatives 

legislation  and 

Increased 
exchange 
between  Member  States 
officials 

action 

implementation 
The 
through  which 
measures 
plan  was 
the 
through 
i.e. 
fulfilled 
existing/new  legislation  or 
by a voluntary approach 

Less formal steps that were 
taken (e.g. improved inter-
agency  coordination) 
in 
one Member States but not 

52 

Qualitative  discussion  on 
implementation 
across 
Member  States  based  on 
logical  analysis  and  input 
from stakeholders 

are 
MS-level  measures 
(see 
clearly 
important 
above  point)  and 
these 
would need to be explored 
in 
stakeholder 
consultation 

the 

Desk research 

Legal analysis  

Questionnaires 

and 

 
 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

in another could also cause 
differences 

Data 
Data-collection methods 

sources/ 

interviews  with  EU  and 
national authorities 

OPC 

53 

 
 
 
 
Efficiency 

The efficiency criterion will analyse the relationship between the resources used by the action plan and its impacts (positive or negative). The 
implementation  differences  in  Member  States  will  be  analysed  to  understand  the  influence  of  these  differences  on  the  impacts  of  the 
implementation, and whether these differences show that the same benefits were achieved at less cost in one or more Member States (or whether 
greater benefits were produced at the same cost). The efficiency analysis will look closely at both the costs and benefits of the action plan on 
different stakeholders. It will cover the seven evaluation questions recommended in the ToR as presented in the evaluation matrix below.  

Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

1. To what extent have actions under the action plan been cost-effective? 

To  what  extent  has  the 
action  plan  been  cost-
effective?  Are  the  costs 
related  to  the  action  plan 
proportionate 
the 
benefits? 

to 

Cost-effectiveness 

Proportionality 

for 
Costs  and  benefits 
different 
stakeholders 
(society,  health,  economy, 
environment) 

with 

Costs  for  different  actions 
(in 
the 
particular, 
enforcement  costs)  will  be 
the 
compared 
benefits. Benefits are more 
measure 
difficult 
to 
the 
In 
quantitatively. 
absence  of  quantitative 
data, semi-quantitative and 
qualitative approaches will 
including  a 
be  applied, 
comparison  with  other 
policies. 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

54 

 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

2.   What are the overall costs and benefits of the action plan’s implementation? 

  NB: Merged with question 1. 

Costs 

Benefits 

Calculation of (total)  costs 
and  quantification 
and 
monetisation of benefits 

Costs  of  implementation, 
compliance,  enforcement 
in 
and 
development  aid  to  non-
EU countries 

EU, 

the 

terms 

of 
in 
Benefits 
seizures,  prosecutions  and 
reduction 
trafficking 
in 
volumes 

with 

Costs  for  different  actions 
(in 
the 
particular, 
enforcement  costs)  will  be 
the 
compared 
benefits. Benefits are more 
measure 
difficult 
to 
the 
In 
quantitatively. 
absence  of  quantitative 
data, semi-quantitative and 
qualitative approaches will 
be  applied, 
including  a 
comparison  with  other 
policies. 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

Cost-benefit analysis tools 

3.   To what extent are the costs proportionate to the benefits it has generated? What factors are influencing any particular discrepancies between 

55 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

costs and benefits? How do these factors link to the action plan itself? 

  NB: Merged with question 1. 

studies  or  other 
increased 

Case 
evidence 
burden or complexity 

on 

Presence/absence  of  such 
practices 

Do  the  benefits  outweigh 
the costs? 

Is  there  any  evidence  that 
the  implementation  of  the 
action  plan  has  caused 
regulatory 
unnecessary 
burden  or  complexity  for 
Member States? 

Are there any good or bad 
can  be 
that 
practices 
terms  of 
in 
identified 
efficiency 
achieving 
in 
results? 

is 

efficient 

How 
the 
exchange  of  information 
the  Member 
between 

No specific indicators 

Qualitative analysis  

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

with 

Costs  for  different  actions 
(in 
the 
particular, 
enforcement  costs)  will  be 
compared 
the 
benefits.  It  is  important  to 
understand the relationship 
between  costs  and  actions 
in  order  to  evaluate  and 
assess  proportionality  of 
the action plan (i.e. if costs 
are  too  high  and  benefits 
low,  different 
too 
are 
measures 
needed 
within the action plan) 

are 

Benefits  are  more  difficult 

56 

 
 
 
 
 
 
 
 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

States? 

Increase/decrease 
in 
collaboration  could  reflect 
of 
efficiency 
the 
exchanges 

the 

absence 

to  measure  quantitatively. 
of 
In 
quantitative  data, 
semi-
quantitative and qualitative 
approaches will be applied, 
including  a  comparison 
with other policies. 

4.   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 of the action plan? 

External factors 

Internal factors 

Presence/absence  of  other 
factors and their impact 

Variables  used 
benefit analysis 

in  cost-

Uncertainty  of 
the  data 
used  for  the  key  variables 
in cost-benefit analysis 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

57 

 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

Stakeholder interviews  

Partial equilibrium models 

2. How proportionate were the costs of the intervention borne by different  stakeholder groups, taking into account the distribution of the 
associated benefits? 

  NB: Insufficient data to answer question. 

Different stakeholder types  Calculation 

of 

costs 
/benefits borne by different 
stakeholders 

Cost and benefits  

Distribution  of  costs  vs 
benefits  

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 

(expert) 

58 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

questionnaire 

Stakeholder interviews  

Partial equilibrium models 

6.   Are there opportunities to simplify a revised action plan or reduce unnecessary costs without undermining the intended objectives? What are 

these opportunities? 

  NB: Reworded for clarity 

Reducing  regulatory  costs 
for  Member 
States 
compliance, 
(inspection, 
enforcement) 

in 
actions 

the  way 
Difference 
different 
are 
implemented  in  Member 
States  

Regulatory costs 

Quantitative  analysis  of 
impact  of  Member 
the 
on 
actions 
States 
regulatory costs 

Desk research 

Literature review  

OPC questionnaire 

Feedback 

from 

59 

 
 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

stakeholders. 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

7.  If there are significant differences in costs (or benefits) between MS, what is causing these significant differences? How do these differences 
link to the design of the action plan? 

  NB: Insufficient data to answer question. 

in  costs  and 
Variation 
benefits  across  Member 
States 

- Different types of costs 

-  Different 
benefits 

types 

of 

Semi-quantitative 
discussion  of  costs  and 
benefits  across  Member 
logical 
States  based  on 

Desk research 

Literature review  

60 

 
 
 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

analysis  and  input  from 
stakeholders 

OPC questionnaire 

Quantitative  analysis  of 
data  on  the  illegal  wildlife 
trade 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

61 

 
 
 
 
 
 
The efficiency criterion will analyse further the benefits and costs of the action plan on society/health, the economy, and the environment (in 
particular biodiversity).  

This analysis will also take into consideration technological developments (e.g. specific inspection tools and methods to detect ivory content) – 
including research and development – to improve compliance and enforcement in order to reduce the related costs. 

Coherence 

The questions this criterion seeks to answer are: ‘To what extent are the elements of the intervention logic complementary, mutually supportive 
and  non-contradictory?’  and  ‘To  what  extent  do  the  objectives  and  activities  support  or  contradict  those  of  other  public  interventions?’.  This 
means that the assessment of coherence looks at how well different actions work together, and thus points to synergies as well as to areas where 
there  are  potentially  contradictory  objectives  or  approaches  that  may  cause  inefficiency.  It  is  important  to  assess  whether  EU  intervention  is 
coherent: (i) internally (i.e. within the action plan itself); (ii) with other EU legislation; and (iii) with other EU policy initiatives. The evaluation 
will  point  out  areas  where  there  might  be  possible  tensions,  such  as  contradictory  approaches  or  inconsistencies,  and  will  develop  a  set  of 
recommendations to increase the coherence of actions, if needed. 

As set out in the ToR, the evaluation of coherence needs to look at both internal and external coherence and consider the specific elements in the 
table below, which build on the findings from other parts of the evaluation (e.g. the evaluation of relevance). 

Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

1.  To what extent is the action plan coherent with other EU interventions which have similar objectives? 

For each intervention other 
than the EU action plan  

For each intervention other 
than the EU action plan  

For each intervention other 
than the EU action plan 

-  How  do  the  objectives, 
and 
provisions 

-  Action  plan  objectives 
the 
are  coherent  with 

-  Degree  of  alignment 
objectives, 
between 

assessment 
Qualitative 
based  on  analysis  and 
input  from  stakeholders  as 
to: 
the 
(i)  whether 
objectives  of  the  action 

impact 
Evaluations  and 
assessment 
other 
of 
policies  including  policies 
on biodiversity, trade, etc. 

62 

 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

that 
implementation 
occurred compare with the 
objectives,  provisions  and 
the 
implementation 
action  plan  and  what  are 
the possible gaps, overlaps 
and inconsistencies? 

of 

objectives  of  key  EU  and 
national policies 

provisions, 
implementation 

and 

-  The  action  plan 
coherent 
biodiversity 
policies 

with 

and 

is 
other 
trade 

-  Instances  of  interaction 
and  existence  of  possible 
inconsistencies 

- What are the interactions 
between  the  intervention 
in 
the  action  plan 
and 
practice? 

action 

plan 
- 
The 
complements 
or 
contributes to the targets in 
other policies 

-  The  action  plan 
is 
coherent  with  other  EU 
environmental legislation 

plan and the respective EU 
policies  are  aligned;  and 
(ii)  whether  there  are  any 
overlaps or inconsistencies 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

2. 
same or similar mechanisms (e.g. development aid or law-enforcement cooperation in other policy domains)? 

To  what  extent  is  the  action  plan  coherent  with  other  interventions  which  have  different  objectives  but  employ  the 

NB: Merged with question 1. 

For each intervention 

For each intervention 

For each intervention 

Qualitative 

assessment  Evaluations  and 

impact 

63 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

based  on  analysis  and 
input  from  stakeholders  as 
to: 
the 
(i)  whether 
objectives  of  the  action 
plan and the respective EU 
policies  are  aligned;  and 
(ii)  whether  there  are  any 
overlaps or inconsistencies 

of 

-  How  do  the  objectives, 
and 
provisions 
implementation 
the 
intervention  compare  with 
the  objectives,  provisions 
and  implementation  of  the 
action  plan  and  what  are 
the possible gaps, overlaps 
and inconsistencies? 

- What are the interactions 
in practice? 

-  Action  plan  objectives 
are  coherent  with 
the 
objectives  of  key  EU  and 
national policies 

-  Degree  of  alignment 
objectives, 
between 
provisions 
and 
implementation 

-  Instances  of  interaction 
and  existence  of  possible 
inconsistencies 

-  The  action  plan 
coherent 
biodiversity 
policies 

with 

and 

is 
other 
trade 

action 

plan 
The 
- 
complements 
or 
contributes to the targets in 
other policies 

-  The  action  plan 
is 
coherent  with  other  EU 
environmental legislation 

Data 
collection methods 

sources/Data-

of 

other 
assessment 
policies  including  policies 
on biodiversity, trade, etc. 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

3. To what extent is the action plan internally consistent and coherent? 

To  what  extent 

is 

the  Whether  the  action  plan  is  - 

Stakeholders’ 

and  Qualitative 

discussion  Desk research 

64 

 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

plan 
action 
consistent and coherent? 

internally 

coherent internally 

of 

Are  there  any  identified 
overlaps, 
cases 
contradictions,  or  other 
inconsistencies in  terms  of 
the 
provisions/requirements? 

the 
To  what  extent  do 
actions 
the 
objectives  of  the  action 
plan? 

match 

None  of  the  requirements 
are  unnecessary,  unclear, 
or contradictory 

Instances  of 
interaction 
and  existence  of  possible 
inconsistencies. 

Provisions  of  the  action 
plan  support  action  plan’s 
objectives  

Member  State  authorities’ 
views  on 
internal 
coherence  of  the  action 
plan 

the 

- Clarity of provisions 

-  Consistency  of 
actions and requirements 

the 

based  on  logical  analysis 
and 
from 
input 
stakeholders  on  whether: 
(i)  the  provisions  are  all 
working  together;  and  (ii) 
the  action  plan  is  being 
delivered in a coherent and 
simple manner 

Data 
collection methods 

sources/Data-

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

4.  To what extent is the action plan consistent with relevant international instruments to which the EU has subscribed? 

SDGs  

CITES  and  CoP  decisions 
and resolutions 

Coherence  in  terms  of  the 
objectives  and  results  in 
other 
international 
instruments  

-  Coherence  of  the  action 
plan 

- Clarity of provisions 

UNGA  Resolution 

on 

-  Consistency  of 

the 

Qualitative 
discussion 
based  on  logical  analysis 
and 
from 
input 
stakeholders  on  whether 
the  provisions  are  all 
working well with relevant 

Desk research 

international 
Review  of 
instruments  to  which  the 
EU has subscribed 

65 

 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

actions and requirements 

international instruments 

tackling  illicit  trafficking 
in wildlife 

UN 
Environment 
resolution  on  illegal  trade 
in  wildlife  and  wildlife 
products 

principles 

G20  endorsement  of  high-
on 
level 
corruption 
combating 
related  to  illegal  trade  in 
wildlife 
and  wildlife 
products 

Data 
collection methods 

sources/Data-

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

5.  To what extent is the action plan coherent with other EU environmental policy objectives, in particular those of the FLEGT action plan, the 
Regulation  against  Illegal,  Unreported  and  Unregulated  (IUU)  Fishing,  the  environmental  compliance  assurance  action  plan,  or  the 
Environmental Crime Directive? 

  NB: Merged with question 1. 

Coherence 

in 

terms  of  Common 

approaches,  What  type  of  actors  are  Qualitative 

discussion  Desk research 

66 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

inconsistencies, 
compliance, 
enforcement approaches 

and 

objectives 

Coherence 
in 
actors targeted 

terms  of 

Coherence 
in 
transport routes 

terms  of 

Coherence 
targeting 
platform 

in 
the 

terms  of 
trading 

based  on  logical  analysis 
and 
from 
input 
stakeholders  on  whether: 
(i)  the  provisions  are  all 
working  together;  and  (ii) 
the  action  plan  is  being 
delivered in a coherent and 
simple manner 

(such 

responsible  for  the  policy 
as 
goals 
law-
enforcement 
authorities 
which  deal  with  organised 
crime/armed  groups  or 
terrorists) 

approaches 
Detection 
(enforcement  chain  and 
cooperation  within  and 
between Member States) 

transport 
Tackling 
illegal 
methods  used 
trade  (maritime,  air,  post, 
etc.) 

in 

Sales  on  online  platforms 
(internet) 
secure 
messaging  (the  Telegram 
app) 

and 

Data 
collection methods 

sources/Data-

(legal  analysis  (review  of 
legal proceedings);  

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

3. To what extent is the initiative coherent with wider EU policy, including policy on separate but related policy objectives such as public 

67 

 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

health, animal health, or the fight against food fraud? 

  NB: Merged with question 1. 

Coherence 
objectives 

in 

terms  of 

Coherence 
in 
actors targeted 

terms  of 

approaches, 

Common 
inconsistencies, 
compliance, 
enforcement approaches 

and 

Type  of  actors  (e.g.  actors 
working  to  combat  food 
fraud, or actors working to 
promote  public  health, 
animal  health,  or  external 
aid/development 
and 
cooperation) 
are 
objectives 
towards 
working 
(stability/rule 
law), 
EMPACT  and  EU  crime 
priorities, etc.) 

they 

of 

Qualitative 
discussion 
based  on  logical  analysis 
from 
input 
and 
stakeholders  on  whether 
the  provisions  are  all 
working together  

Desk research 

(i)  legal  analysis  (review 
of  legal  proceedings);  (ii) 
guidance  on  areas  where 
the 
lacks 
action  plan 
clarity  or  coherence;  and 
(iii)  critical  review  of  the 
action  plan  in  comparison 
these  separate  but 
with 
related policy objectives 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 

(expert) 

68 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

questionnaire 

Stakeholder interviews  

69 

 
 
 
 
Relevance 

The relevance criterion analyses the relationship between the needs and problems in society on the one hand and the objectives of the action plan 
on the other. Although the 2018 progress report considered that the priorities and objectives set out in the action plan remain appropriate and 
relevant,  the  relevance  analysis  requires  a  consideration  of  how  the  objectives  of  the  action  plan  correspond  to  wider  EU  policy  goals  and 
priorities (such as the biodiversity strategy, the Green Deal, the SDGs, etc.). It will identify if there is any mismatch between the objectives of 
the action plan and the current situation. It will cover the three evaluation questions asked in the service request as presented in the evaluation 
matrix below.  

Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

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? 

To  what  extent 
action plan still relevant? 

is 

the 

Does  it  correspond  to  the 
current  needs  within  the 
EU? 

with 
scenario 

Relevance 
changing 
improved 
between 
money 
other organised crimes) 

the 
(e.g. 
cooperation 
on 
and 

countries 
laundering 

Does  it  correspond  to  the 
ambitions  of  the  Member 
States? 

Relevance  with  wider 
policy  goals  (Green  Deal, 
biodiversity strategy, etc.) 

Relevance 
to 
policy objectives 

national 

Stakeholders’ 

- 
and 
Member  State  authorities’ 
view on relevance 

- Consistency with EU and 
national policies 

Qualitative 
discussion 
based  on  logical  analysis 
from 
input 
and 
stakeholders  on  whether 
is  still 
the  action  plan 
relevant  on 
three 
questions 

the 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

70 

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

2.   How flexible has the action plan been in responding to new issues? 

Has  the  action  plan  been 
flexible enough to respond 
to  new  issues  (e.g.  sales 
using  social  media  and 
secure networks)? 

the 

action  plan 
Does 
contain  moot  or  redundant 
requirements? 

channels 
New 
trafficking and sales 

of 

Stakeholders’ 

and 
- 
Member  State  authorities’ 
view on flexibility 

COVID-19 
opportunities? 

risks 

and 

Ability  of  Member  States 
to adapt during COVID-19 

discussion 
Qualitative 
based  on  logical  analysis 
and 
from 
input 
stakeholders on flexibility 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

71 

 
 
 
 
 
 
EU added value 

The EU added-value criterion brings together the findings from  all other evaluation criteria and focuses on the benefits and changes resulting 
from the action plan that are additional to those that would have resulted from action at Member State level or sub-MS level (e.g. regional or 
local  level).  It  is  not  possible  to  be  certain  about  what  would  have  happened  without  EU-level  action,  but  this  question  can  be  raised  with 
Member State representatives and other relevant actors, including to assess whether EU policy helped to reduce the political risk associated with 
unilateral Member State policy commitments, as perceived by business and other key stakeholders. 

Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

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? 

What is the added value of 
the  action  plan  at  EU  and 
global level (e.g. on global 
wildlife trafficking)? 

Counterfactual baseline (in 
the  absence  of  the  action 
plan)  

What  would  be  the  most 
likely 
consequences  of 
stopping  or  withdrawing 
the action plan? 

Perception  of  EU  action 
plan  by  Member  States, 
and  whether  it  has  helped 
increase  political  will  to 
tackle wildlife crime 

Existence  of  national-level 
measures/mechanisms 
already in place before the 
action  plan/not  linked  to 
plan 
the 
and 
action 
consideration 
of  what 
these  could  have  achieved 

72 

Qualitative 
discussion 
based  on  logical  analysis 
from 
input 
and 
stakeholders on flexibility 

Desk research 

Literature review  

OPC questionnaire 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

 
 
 
 
Sub-questions 

Assessment criteria 

Indicators 

Data-analysis approach 

Data 
collection methods 

sources/Data-

by  themselves  collectively 
at the EU level  

2.  To what extent does the action plan comply with the principles of subsidiarity and proportionality? What has been the role of and impact on 

local and regional authorities? 

Variation  across  Member 
States 

Impact  at  different  levels 
in Member States 

discussion 
Qualitative 
based  on  logical  analysis 
and 
from 
input 
stakeholders on flexibility 

Desk research 

Literature review  

OPC questionnaire 

Subsidiarity 
proportionality analysis 

and 

Targeted consultation:  

Stakeholder 
questionnaire 

(expert) 

Stakeholder interviews  

73 

 
 
 
 
 
ANNEX  IV.  OVERVIEW  OF  BENEFITS  AND  COSTS  [AND,  WHERE  RELEVANT,  TABLE  ON 
SIMPLIFICATION AND BURDEN REDUCTION] 

The  EU  action  plan  against  wildlife  trafficking  brings  together  a  wide  variety  of  measures 
from different areas and each with a different character. For this reason, it is not possible to 
reliably  estimate  the  costs  it  engendered.  In  addition,  the  data  limitations  in  the  area  of  the 
illegal  wildlife  trade  make  it  almost  impossible  to  determine  the  economic  benefits  of  this 
plan. For more discussion of this issue, please see Section 4.1.2.1. 

74 

 
 
 
ANNEX V:    STAKEHOLDER CONSULTATION - SYNOPSIS REPORT 

1.  OPC 

a.  Profile of OPC respondents 

A  total  of  173  responses  to  the  OPC  were  received,  and  only  one  blank  response  was 
identified, leaving a total of 172 valid responses. Among these responses, 123 were unique, 
and 49 were identified as being part of campaigns. The largest number of responses (59.88%) 
came  from  EU  citizens,  followed  by  non-governmental  organisations  (NGOs)  (20.35%). 
Figure 3 presents the respondents broken down according to different stakeholder groups. 

Responses  were  received  from  both  EU  Member  States  and  non-EU  countries.  Many 
responses  originated  from  the  Netherlands  (69),  with  relatively  fewer  from  Belgium  (15), 
France (25), Germany (15), and the United Kingdom (14). The following countries provided 
very  low  numbers  of  responses  (1-5):  Austria  (3),  Australia  (1),  Bulgaria  (1),  Canada  (2), 
Czech Republic (1), Denmark (4), Finland (1), Italy (4), Kenya (1), Morocco (1), Poland (1), 
Romania  (2),  Spain  (3),  Sweden  (1),  Switzerland  (1),  the  United  States  (5),  and  Zimbabwe 
(2). Not all 116 respondents answered every question of the OPC questionnaire. 

Figure 3: Profile of respondents to the OPC 

In  total,  participants  uploaded  32  position  papers,  of  which  6  were  duplicates  submitted  as 
part of an identified campaign, leaving 26 unique position papers for  in-depth analysis with 
numbers of pages ranging from 1 to 18. 

b.  OPC questionnaire – summary of results 

OPC  responses  show  a  dichotomy  between  stakeholder  groups.  Public  authorities  and 
companies  more  frequently  supported  actions  taken  to  implement  the  action  plan  (although 
these stakeholders were  low in  number  and only tenuous conclusions can be drawn), while 

75 

 
 
citizens  and  NGOs  were  far  more  critical.  NGOs  argued  that  although  the  action  plan 
continues to be relevant, its implementation by the Member States has not been effective and 
requires further actions in various ways. 

The  following  sub-sections  provide  a  general  summary  of  responses  for  each  stakeholder 
group. 

EU citizens and non-EU citizens 

EU  and  non-EU  citizens  showed  a  low  awareness  of  most  efforts  made  to  implement  the 
action plan in their country. For citizens, the four most important priorities for revision of the 
action  plan  were:  (i)  greater  awareness  raising  in  demand  countries;  (ii)  strengthening  EU 
legislation  on  the  wildlife  trade;  (iii)  strengthening  international  agreements  on  the  wildlife 
trade;  and  (iv)  improving  compliance  with  legislation  and  enforcement  in  the  EU.  Citizens 
stressed  that  the  action  plan  should  focus  on  greater  detection,  enforcement  and  harsher 
punishments of those guilty of the illegal wildlife trade. They also believe that the action plan 
should increasingly: (i) target traditional medicines; (ii) encourage behavioural change in the 
illegal  wildlife  trade;  and  (iii)  allocate  sufficient  resources  to  enforcement  and  judicial 
authorities. 

Most  citizens  believed  that  all  key  actors  were  doing  too  little  to  tackle  the  illegal  wildlife 
trade, except NGOs and researchers/academics. In general, citizens disagreed that authorities 
in their country and the EU had taken sufficient action and given sufficient financial support 
to  reduce  the  demand  for  illegal  wildlife  and  illegal  wildlife  products.  Most  disagreed  that 
authorities  had  provided  sufficient  financial  support  for 
the  sustainable  economic 
development of rural/source communities.  

Most citizen respondents believed that the authorities of their country had not systematically 
addressed corruption relating to the illegal wildlife trade. They also believed that corruption 
had increased at the national, EU, and international levels. Most citizen respondents did not 
believe  that  authorities  in  their  country  had  reviewed  and  amended  relevant  national 
legislation to ensure that organised wildlife trafficking, including related money laundering, 
constitutes a serious crime. Furthermore, most citizen respondents did not agree that there are 
adequate facilities for the temporary care of seized or confiscated wildlife. 

Citizens  also  generally  disagreed  that  authorities  have  ensured  monitoring  and  enforcement 
of compliance with  the action  plan and of illegal  killing, trapping and trade of birds within 
their State and at borders. Most citizen respondents did not believe that authorities had drawn 
up  national  enforcement  priorities  for  target  species  and  products  nor  that  they  had  set  up 
joint investigation teams with Europol/Eurojust, other inter-agency coordination mechanisms, 
or  investigators  on  illicit  financial  flows  relating  to  the  illegal  wildlife  trade.  Furthermore, 
citizens  did  not  believe  that  authorities  regularly  published  reports  or  indicators  on  how 
financial support has been used. Most citizens did not know that authorities in their country 
had  set  up  focal  points  in  delegations  and  embassies  in  key  source  transit  and/or  consumer 
countries to strengthen partnerships.  

Civil society  

Civil-society stakeholders were generally aware of most efforts made to implement the action 
plan in  their country.  Their top  four priorities for a  revised action plan were:  (i)  awareness 
raising in high-demand countries; (ii) raising the profile and political importance of tackling 

76 

 
the  illegal  wildlife  trade;  (iii)  improving  cooperation  and  information  sharing  between 
EU/non-EU  countries;  and  (iv)  greater  financial  support  to  local  communities  tackling  the 
illegal  wildlife  trade  in  source  countries.  Key  topics  highlighted  by  this  stakeholder  group 
included: (i) the need to allocate sufficient resources for enforcement and judicial authorities; 
(ii) the need to include experts and expert organisations in the policy-making processes; and 
(iii) the need for countries to better implement and enforce action plan measures.  

Most  civil-society  stakeholders  believed  all  actors  were  doing  too  little  to  tackle  the  illegal 
wildlife trade, except NGOs, researchers and academics.  

Most  civil-society  stakeholders  disagreed  that  the  authorities  in  their  countries  and  the  EU 
had  taken  adequate  actions  or  provided  sufficient  financial  support  to  either:  (i)  reduce  the 
demand for illegal wildlife and their products; or (ii) promote sustainable economic activities 
in  rural/source  communities.  They  were  of  the  view  that  authorities  had  not  set  up  focal 
points  in  delegations  and  embassies  in  key  source,  transit  and/or  consumer  countries  to 
strengthen partnerships.  

Over  half  of  civil-society  respondents  did  not  feel  that  authorities  in  their  country  had 
adequately  reviewed  and  amended  relevant  national  legislation  to  ensure  that  the  illegal 
wildlife  trade  constitutes  a  serious  crime,  nor  that  these  authorities  had  reviewed  and 
amended  relevant  national  legislation  on  money  laundering  related  to  the  illegal  wildlife 
trade.  

Most civil-society respondents  believed that more actions from  the action plan should have 
been  implemented  at  the  EU  rather  than  at  the  national  level.  Despite  believing  that 
implementation was lacking, civil-society stakeholders were split as to whether they believed 
that  the  action  plan  continued  to  provide  a  comprehensive  means  of  tackling  the  illegal 
wildlife trade while facilitating legal trade, with many stating that the action plan was already 
comprehensive and ambitious enough as it is. 

Companies and business associations 

Companies and business associations submitted few responses (6), and the following results 
should be interpreted with caution.  

The  small  group  of  responses  from  companies  and  business  associations  showed  that  these 
respondents  were  generally  aware  of  most  efforts  to  implement  the  action  plan  in  their 
country  except  for  efforts  in  the  areas  of  capacity  building  and  training  of  authorities  and 
institutions.  These  respondents  also  believed  that  the  top  four  priorities  of  a  revision  to  the 
action  plan  should  include:  (i)  greater  awareness  raising  in  demand  countries;  (ii)  capacity 
building and training of authorities; (iii) improved cooperation and information sharing; and 
(iv)  improved  compliance  and  enforcement  within  the  EU.  Key  topics  that  companies  and 
business  associations  highlighted  included  the  need  to:  (i)  support  behavioural  change  in 
consumers;  (ii)  target  cyber  trafficking;  and  (iii)  encourage  continuous  support  and 
commitment  from  the  Member  States  to  the  action  plan  and  the  fight  against  the  illegal 
wildlife trade. 

Most company respondents believed that national authorities, the EU, businesses, NGOs, and 
researchers/academics were doing enough to tackle the illegal wildlife trade (they considered 
that all other stakeholders were doing too little).  

77 

 
Most  companies  and  business  associations  agreed  that:  (i)  existing  awareness-raising  tools 
and  materials  had  been  shared  among  the  EU  Member  States;  (ii)  the  proposed  listing  of 
additional  endangered  species  in  the  three  CITES  appendices  should  go  ahead;  and  (iii) 
authorities systematically discuss corruption related to the illegal wildlife trade.  

In general, companies and business associations believe that the demand for – and supply of – 
illegal wildlife and products have decreased at the national, EU and international levels.  

Most disagreed that authorities had taken adequate actions and provided sufficient financial 
support to reduce the demand for products originating in the illegal wildlife trade. However, 
they  considered  that  the  engagement  of  rural  communities  in  the  fight  against  the  illegal 
wildlife trade had increased at the national and international levels. Similarly, they believed 
that engagement with businesses fighting the illegal wildlife trade had increased at national, 
EU,  and  international  levels.  Furthermore,  most  companies  and  business  associations 
believed that  corruption  had decreased at  all levels.  They  also  believed that  the capacity of 
the enforcement chain, including international cooperation in enforcement and the judiciary, 
had  increased  at  the  national  and  international  levels.  Most  also  were  of  the  view  that  the 
effectiveness of the fight against the illegal wildlife trade had increased.  

Public authorities 

As was the case with the small group of companies and business associations, few responses 
were  submitted  by  public  authorities.  The  following  summary  of  these  responses  should 
therefore be interpreted with caution. 

Public authorities were generally aware of efforts made to implement the action plan in their 
country. Public authorities generally stated that the action plan had had positive impacts but 
that it may not have gone far enough to tackle the illegal wildlife trade.  

Public authorities believed that the top four priorities for revising the action plan should be: 
(i) increased capacity building and training for EU Member State authorities and institutions; 
(ii)  improved  cooperation  and  information  sharing  between  the  EU  Member  States;  (iii) 
improved legislative and enforcement compliance; and (iv) greater awareness-raising efforts. 
Public  authorities  believed  that  the  reporting  and  monitoring  information  provided  in  the 
2018  progress  report  was  useful  for  monitoring.  However,  they  considered  that  this 
information  could  be  improved  by:  (i)  using  common  reporting  standards/templates;  (ii) 
setting  measurable  targets  for  implementation;  and  (iii)  requiring  national  authorities  to 
report.  

Most public authorities believe that the following actors are doing enough to tackle the illegal 
wildlife trade: intergovernmental organisations, EU authorities, national governments of EU 
Member  States,  judiciaries  of  EU  Member  States,  national  customs  authorities  of  EU 
Member States, and NGOs. Most public authorities believed that all other stakeholder types 
were doing too little.  

Public  authority  respondents  agreed  with  the  proposed  listing  of  additional  endangered 
species in the three CITES appendices. 

Most public authorities agreed that national authorities had taken sufficient actions to provide 
financial  support  to  reduce  demand  for  products  originating  in  the  illegal  wildlife  trade  in 
their country, including by encouraging sustainable economic activities in rural communities 

78 

 
near wildlife habitats. However, most disagreed that the authorities had sufficiently supported 
private-led initiatives and private-public partnerships to curb the illegal  wildlife trade. Most 
public authorities also believed that there had not been enough systematic discussion among 
public  authorities  themselves  of  how  to  better  fight  corruption  related  to  the  ILLEGAL 
WILDLIFE TRADE. Most public authorities believed that they and other authorities had set 
up focal points in delegations and embassies in key source, transit and/or consumer countries 
to  strengthen  partnerships.  Most  responses  from  public  authorities  also  suggested  that  the 
effectiveness  of the fight against the  illegal  wildlife trade  had increased at  national  and EU 
levels  since  the  adoption  of  the  action  plan.  International  cooperation  –  specifically  on 
enforcement against the illegal wildlife trade – was also thought to have increased at EU and 
international levels. 

Most public authorities suggested the three following potential improvements to monitoring 
requirements:  (i)  the  use  of  common  reporting  standards  and  templates;  (ii)  the  setting  of 
measurable  targets  and  indicators  for  implementation;  and  (iii)  the  setting  of  specific 
requirements  for  each  type  of  authority  (i.e.  specific  requirements  for  the  European 
Commission, the High Representative of the Union for Foreign Affairs & Security Policy, the 
Vice President of the European Commission, Member State competent authorities, Europol, 
Eurojust, and the European Network of Prosecutors for the Environment). 

c.  Position papers 

In total, 32 position papers were submitted. Of these papers, 6 were duplicates and removed 
from the selection of papers for analysis, and 26 valid position papers were analysed. Of the 
valid position papers, 62% (16) mentioned the issue of legality and legislation on the action 
plan. On this issue, NGOs discussed the link between the legal and the illegal wildlife trade, 
arguing that stricter regulation of the legal trade is also necessary to: (i) prevent the risks and 
consequences  of  the  illegal  wildlife  trade;  and  (ii)  address  the  illegal  trade  in  non-CITES-
listed species protected in their country of origin. NGOs also recommended that the revision 
of  the  action  plan  should  be  coherent  and  aligned  with  other  recent  legislation  and  EU 
policies related to the action plan, such as the Environmental Crime Directive, the EU Green 
Deal,  and  the  Digital  Services  Act.  In  addition,  NGOs  said  that  further  restrictions  were 
needed  on  trophy  hunting  and  the  ivory  trade.  Eight  NGOs  mentioned  the  lack  of  clear 
monitoring  and  evaluation  processes,  and  recommended  the  implementation  of  clear  and 
more  precise  objectives  and  actions  with  key  performance  indicators  (KPIs).  These  eight 
NGOs  also  recommended  the  creation  of  a  robust  and  logical  reporting  framework  and 
monitoring system.  
Sufficient allocation of human and financial resources and a dedicated budget supporting the 
effective  implementation  of  the  action  plan  is  a  prominent  theme  identified  in  the  valid 
position  papers.  Eight  NGOs  reiterate  this  recommendation,  as  does  one  position  paper 
submitted by a public authority, which also presents the transposition of the action plan into a 
national action plan in Czech Republic. 
The following three pages or so set out the main key issues (in bold type) with the current 
action  plan  and  the  corresponding  recommendations  to  improve  them,  as  presented  in  the 
position papers. At the beginning of each recommendation, the main supporting stakeholders 
for the arguments made in bold type are underlined.  

Many of the actions from the action plan were not completed, or their assessment could 
not be completed due to the lack of a clear monitoring and evaluation process  

79 

 
Recommendations 

  NGOs,  public  authorities  (PAs),  research  institutions,  and  businesses:  (i)  implement 
clear and more precise objectives and actions with KPIs; and (ii) create a baseline. 
  NGOs,  PAs,  research  institutions,  and  businesses:  set  up  a  robust,  logical  reporting 

framework and monitoring system that: 

o  contains user-friendly tools such as reporting templates; 
o  makes  it  possible  to  measure  progress  and  ensure  accountability  towards  its 

implementation.  

The current action plan is not legally binding/there should be stronger enforcement of 
legislation 
Recommendations  

  NGOs,  research  institutions:  Understand  the  connection  and  links  between  the  legal 
and illegal wildlife trade – legal trade in wild animals often serves as a cover for the 
illegal wildlife trade. 

  NGOs,  PAs:  Align  and  incorporate  action  to  tackle  the  illegal  and  unsustainable 
wildlife  trade  and  bring  it  into  existing  regulations  (i.e.  the  Environmental  Crime 
Directive  and  the  EU  Wildlife  Trade  Regulations).  Priorities  in  this  work  should 
include:  

o  covering species protected under the Birds and Habitats Directives;  
o  a greater focus on endemic and native species;  
o  ensuring  coherence  with  legislation  related  to  IUU  fishing  and  timber 

trafficking;  

o  references 

to 

the  Directive  on 

freezing  and  confiscation  of 
instrumentalities  and  proceeds  of  crime,  the  Digital  Services  Act,  and  the 
Directive on countering money laundering. 

the 

  NGOs: Develop new legislation to end the sale of live and freshly killed wild animals 

protected by the action plan for human consumption.  

  NGOs, PAs: Transpose the action plan at the national level into national action plans. 
It is important to adapt the action plan to national priorities and contexts, as well as to 
align it with the concerns of national stakeholders (e.g. Spain and Czech Republic).  

There is insufficient capacity to house all confiscated/seized animals – governments rely 
on  privately-owned  facilities,  although  these  facilities  receive  zero  or  limited  public 
funding 
Recommendations:  

  NGOs, PAs, businesses: Funds should be allocated at the EU level and made 
available  to  Member  States  to  ensure  consistent  and  appropriate  support  to 
rescue centres across Europe. This will support the establishment of a network 
of responsible rescue facilities. 

  NGOs, PAs, and research institutions: Seek consistent and transparent reporting on all 
seized or confiscated live animals  to  CITES,  Europol,  and the countries  of origin  to 
help ensure accurate information on the illegal trade of live animals. 

  NGOs,  PAs,  and  research  institutions:  Increase  cross-border  cooperation  between 

Member States in caring for seized animals. 

80 

 
 
 
  NGOs, businesses: Recognise the role of CSOs and set stronger cooperation.  

Demand for – and availability of – wildlife is still increasing  
Recommendations: 

  NGOs, research institutions: Implement evidence-based demand-reduction initiatives 

in key consumer countries. 

  NGOs,  PAs,  research  institutions:  Support  research  into  behaviour  change  in  key 

consumer markets. 

Loopholes must be closed in wildlife-related legislation/directives/regulations 

Recommendations: 

  NGOs,  research  institutions:  Expand  the  number  of  species  covered  –  not  only  by 
encompassing species protected by CITES and the EU Wildlife Trade Regulations but 
also through other regulations such as the EU Timber Regulation and the IUU Fishing 
Regulation.  

  NGOs: Close the loopholes in the EU Wildlife Trade Regulations by  addressing the 
illegal trade in non-CITES-listed species protected in their country of origin (although 
a species can be illegally exported from its country of origin into the EU, if it is listed 
as a non-CITES species, there is currently no legal way to stop its trade). NGOs also 
suggested making use of Annex B of Council Regulation EC No. 338.97. 

  NGOs,  research  institutions:  Adopt  an  EU  ‘positive  list’  of  allowed  species.  Assess 
the safety and suitability of animal species to be kept as pets based on the criteria of 
animal welfare, public health, public safety, biodiversity protection, and invasiveness 
risk. 

Gender and human rights aspects are increasingly linked with the action plan  
Recommendations: 

  NGOs,  research  institutions:  Indigenous  people  and  local  communities  (IPLCs)  and 

women should be involved in decision-making and knowledge sharing.  

  NGOs: Reduce demand from urban consumers and markets for wildlife as food. This 
will lead to less supply, leaving more wildlife for rural families who rely on wildlife 
as a primary source of food and thus help IPLCs. 

  NGOs:  Support  the  scale-up  of  locally  produced,  sustainable,  non-wildlife,  high-

quality food to reduce dependence on wild meat – particularly for IPLCs. 

The  previous  action  plan  contributed  to  boosting  awareness  and  to  training  relevant 
experts – this work should continue 
Recommendations: 

  NGOs,  research  institutions:  There  is  still  a  need  to  accord  wildlife  crime  a  higher 

priority on the political agenda.  

  NGOs,  PAs,  and  research  institutions:  Continue  the  training  and  specialisation  of 

authorities on wildlife crime, forest crime and fisheries crime. 

81 

 
 
 
 
 
 
  NGOs,  PAs,  and  research  institutions:  Set  up  a  dedicated  Wildlife  Trafficking 

Coordinator’s Office.  

  NGOs, research institutions,  and businesses: Increase the involvement of the private 
sector  (such  as  the  transport  sector,  online  platforms  and  companies  supplying 
wildlife products) in the fight against the illegal wildlife trade. Implement legislative 
frameworks that oblige these companies to adopt due-diligence procedures.  

Tackle wildlife cybercrime  – wildlife traffickers are making use of online platforms to 
reach a virtual marketplace 
Recommendations:  

  NGOs: Wildlife cybercrime should be given the same level of priority as other forms 

of cybercrime.  

  NGOs, research institutions: Support the development of technological solutions 

according to the new Digital Services Act.  

  NGOs, PAs: Require traders to declare the legal status of the animal or product they 

are offering for sale. 

  NGOs:  Wildlife  cybercrime  should  be  appropriately  addressed  at  key  international 

fora such as CITES, UNTOC and the IUCN.  

Other main recommendations from the position papers  

  NGOs: A comprehensive global agreement on tackling wildlife trafficking should be 
adopted.  In  addition,  a  new  pandemic-prevention  treaty  should  be  drawn  up.  This 
treaty  should  be  a  multilateral  agreement  to  commit  governments  to  all  necessary 
actions to prevent future pathogen spillover from wildlife to humans.  

  NGOs:  Advocate  for  a  new  protocol  on  the  illicit  trafficking  of  wildlife  under  the 
UNTOC.  States  that  are  party  to  the  protocol  would  agree  to  adopt  legislation  that 
makes  it  a  criminal  offence  to  illicitly  traffic  any  whole  or  part  of  a  wild  animal  or 
plant, whether alive or dead. 

  NGOs, research institutions: Adopt a ‘one health’ approach – working across sectors 

at the local, regional, national, and global levels to tackle zoonotic spillovers. 

  NGOs, research institutions: Impose a ban on trophy hunting – used to cover for the 
illegal import of protected wildlife species into the EU. Require import permits for all 
species listed in Annex B of Council Regulation EC 338/97. 

  NGOs,  PAs,  research  institutions:  On  the  ivory  trade,  relevant  issues  still  remain. 
Trade  restrictions  on  worked  ivory  are  only  partially  addressed  in  Commission 
Regulation 865/2006. Implementation of stricter regulations is needed. 

2.  TARGETED EXPERT CONSULTATIONS  

a.  Respondents to the targeted expert survey  

A  total  of  39  responses  were  received.  Responses  were  provided  by:  public  authorities 
(35.9%,  14/39),  NGOs 
(12.8%,  5/39), 
academic/research  institutions  (10.3%,  4/39),  EU  citizens  (2.6%,  1/39),  environmental 
organisations (2.6%, 1/39), and others (5.1%, 2/39). 84.6% (33/39) of respondents had more 
than 5 years of experience related to CITES/wildlife trade issues.  

(30.8%,  12/39),  business 

associations 

82 

 
 
Responses  were  received  from  both  EU  and  non-EU  states  as  follows:  Belgium  (20.5%, 
8/39), the Netherlands (15.4%, 6/39), Spain (10.3%, 4/39), Sweden (10.3%, 4/39), Germany 
(7.7%,  3/39),  United  Kingdom  (7.7%,  3/39),  Austria  (5.1%,  2/39),  Italy  (5.1%,  2/39), 
Slovenia (5.1%, 2/39), Australia (2.6%, 1/39), Switzerland (2.6%, 1/39), USA (2.6%, 1/39), 
Canada (2.6%, 1/39), and Zimbabwe (2.6%, 1/39).  

Respondents  to  the  targeted  expert  survey  were  asked  whether  they  would  like  to  be 
contacted for an interview. From the 39 responses received from the targeted expert survey, 
23  participants  chose  to  be  contacted  for  an  interview.  Finally,  only  16  stakeholders  were 
available  with  whom  interviews  were  conducted.  Interviews  were  conducted  with  NGOs 
(50%,  8/16),  academic/research  institutions  (18.8%,  3/16),  public  authorities  (12.5%,  2/16), 
business associations (6.3%, 1/16), and others (12.5%, 2/16).  

b.  Targeted consultations – summary 

Throughout  the  expert  consultations,  the  action  plan  offered  a  point  of  reference  and 
framework  to  guide  action,  illustrating  the  urgency  of  addressing  the  illegal  wildlife  trade. 
Overall,  there  is  still  a  strong  need  for  further  measures  to  increase  awareness  and 
behavioural  change.  One  of  the  action  plan’s  main  successes  that  was  identified  in  the 
consultations  was  that  it  encouraged  the  EU  to  play  a  substantial  role  in  funding  certain 
programmes.  

Although action has been taken at EU level, public-awareness campaigns have been scarce in 
most Member States. Demand-reduction activities have not matched the magnitude and scale 
of the growing demand for wildlife, especially in the light of increasing  online trade which 
facilitates  the  illegal  wildlife  trade,  as  seen  particularly  in  the  trafficking  of  exotic  pets. 
Indeed, emerging online trends make it difficult to monitor and prevent wildlife trafficking. 
Limited monitoring by courier companies also makes it easy for illegal wildlife products to 
reach their destination.  

In  the  consultation  activities,  the  need  to  increase  evidence-based  demand-reduction 
initiatives  and  encourage  research  into  behavioural  change  (particularly  in  key  consumer 
markets) was  also  discussed, as was the need to  increase dialogue with  key  stakeholders in 
relevant  business  sectors  (i.e.  the  transportation  sector,  online  platforms)  and  exotic  pet 
keepers.  

Including non-CITES-listed species  

The  EU  and  previous  CITES  CoPs  have  successfully  listed  several  species  threatened  by 
trade  in  the  CITES  appendices.  However,  the  vast  majority  of  species  being  traded  remain 
unprotected  by  CITES.  All  interviewed  NGOs  stressed  that  the  action  plan  was  primarily 
focused on CITES-listed species and was not sufficiently focused on exotic pets, native EU 
species and non-CITES species. NGOs also argued that awareness raising should go beyond 
the  protection  of  CITES  species,  and  make  use  of  Annex  B  of  Council Regulation  EC  No. 
338.97 to require import permits for hunting trophies from all species listed in the Annex.  

From  the  targeted  expert  survey,  50%  of  the  NGOs  mentioned  that  they  supported  the 
adoption of an EU ‘positive list’ of safe and suitable pets,  where species are independently 
evaluated to assess whether they are safe to be traded or not (i.e. to confirm that they do not 
pose a risk to the public or threaten the environment/themselves). The list would only include 

83 

 
species  which  are  safe  to  be  traded.  The  key  issue  in  implementing  such  a  list  is  filling 
legislation gaps and ensuring that an import into the EU is deemed illegal if it breaches the 
local laws of the exporting country. Respondents mentioned the US Lacey Act as an example 
of how this could be attempted. Under the Lacey Act: (i) it is unlawful to import, export, sell, 
acquire, or purchase fish, wildlife or plants that are taken, possessed, transported, or sold in 
violation  of  US  or  Indian  Law;  and  (ii)  it  is  unlawful  to  engage  in  interstate  or  foreign 
commerce involving  any fish, wildlife, or plants  taken in  possession  or sold  in  violation of 
State or foreign law.  

Developing a monitoring and evaluation process and improving knowledge exchange 

In the targeted expert survey, many questions could not be answered as stakeholders felt that 
they  could  not  properly  assess  the  impact  of  the  action  plan  in  several  areas  because  the 
action plan lacked: (i) a clear monitoring and evaluation process; and (ii) measurable KPIs. 
Developing  a  scoreboard  and  measurable  indicators  to  systematically  review  the  quality  of 
the  implementation  of  action  plan  in  each  Member  State,  as  well  as  the  allocation  of  a 
dedicated budget, was advised by 25% of the stakeholders when their opinions were asked on 
how to improve monitoring.  

Cooperation  and  exchange  of  information  between  enforcement  authorities  and  Member 
States  remain  a  challenge  in  some  Member  States.  This  leads  to  essential  information  not 
being  passed  on  from  different  authorities  (i.e.  Europol).  This  information  includes  judicial 
penalties,  prosecutions,  seizure  data,  intervention  strategies,  experience,  training,  and 
legislation.  Without  such  information,  it  is  more  difficult  to  disrupt  organised  criminal 
networks in wildlife trafficking and obtain proper advice on how to consider different cases.  

The lack of resources (technical, human and financial) was identified by 75% of NGOs and 
71% of public authorities as the main obstacle in tackling the illegal wildlife trade. Although 
the exchange of information is facilitated through electronic platforms like EU-TWIX (which 
helps  to  connect  officials  across  borders  and  rapidly  shares  information  and  expertise),  its 
usage varies  greatly within  Member States and can be regarded as insufficient to overcome 
structural or regulatory obstacles. 25% of respondents from the expert survey mentioned that 
the EU-TWIX database is not easily accessible, as this also depends on the willingness and 
ability of Member States to share information. 

Through a complete, transparent and updated overview accessible to all users, data collection 
through the EU-TWIX database can be improved. Supplementing the database with relevant 
information  on  prosecutions  and  judicial  proceedings  would  also  improve  the  database  and 
encourage  authorities  to  submit  information  on  seizures  in  a  timely  manner.  The  database 
should be more easily accessible within the limits of privacy and personal-data protection. 

Although  there  have  been  instances  of  cooperation  between  Member  States,  more  effort 
needs to be made in this area. To ensure joint efforts by different Commission services and 
the Member States – and to support activities at Member State level – the implementation of 
a dedicated Wildlife Trafficking Coordinator’s office within the European Commission was 
suggested.  

Strengthening legislation  

Due to  the low number and low severity of penalties in  Member States, many stakeholders 
disagreed that the legislative framework on environmental crime in many Member States was 

84 

 
in line with the European agenda on security. Many stakeholders also disagreed that wildlife 
trafficking  was  considered  a  serious  crime  under  the  UN  Convention  against  Transnational 
Organized  Crime.  They  argued  that  there  were  still  gaps  between  international,  European, 
and national legislation, and that there was still a lack of information on seizure rates, types 
of  seized  species,  and  quantifiable  impacts.  These  stakeholders  said  that  the  fact  the  action 
plan  was  not  legally  binding  might  limit  governments’  political  will  to  invest  in  tackling 
wildlife crime. 

28% of the respondents from the expert survey advised incorporating actions to tackle illegal 
and unsustainable wildlife trade into existing regulations, such as the Environmental  Crime 
Directive, the EU Wildlife Trade Regulations, the Digital Services Act, and other related EU 
directives/legislation. One stakeholder encouraged developing and adopting a global protocol 
on illicit wildlife trafficking under the UNTOC. 

On drawing up other legislation related to wildlife crime, stakeholders argued that developing 
a  pandemics  agreement  with  a  focus  on  prevention,  preparedness  and  response  would 
strengthen  the  relevancy  and  added  value  of  the  action  plan.  58%  of  NGOs  recommended 
embedding the ‘one health’/‘one welfare’ approach within the revised action plan. 

EU funding 

The action plan provided for trans-sectoral capacity building across  Member States, as well 
as  boosting  capacity  to  tackle  online  wildlife  trafficking.  However,  shortcomings  remain 
within investigations, prosecutions and judicial proceedings against the illegal wildlife trade.  

Although a lot of funding has been designated for wildlife-related programmes and projects 
related to the implementation of the action plan, there have been some problems in evaluating 
the  impact  of  this  funding.  It  has  been  difficult  to  estimate  how  much  money  has  been 
allocated  to  each  objective  and  priority  of  the  action  plan.  Financial  support  has  been  the 
main form of assistance given by the EU to non-EU countries. However, additional support is 
needed for the long-term sustainability of local projects, as many projects remain fragile due 
to  insufficient  support  and  an  insufficient  sense  of  ‘ownership’  by  national  and  local 
authorities.  

Throughout  the  expert-consultation  activities,  stakeholders  voiced  concern  over  the  lack  of 
funds, expertise and staff. They said that many of the actions from the action plan could not 
be  conducted  due  to  the  lack  of  sufficient  resources.  Many  NGOs  emphasised  that 
governments  greatly  depend  on  them  to  care  for  most  seized/confiscated  animals,  although 
these NGOs lack the funding, human resources and space to do so.  

Dedicated funds from the EU and Member States must be implemented to achieve different 
objectives.  These include increasing capacity building and providing training and guidance, 
particularly for law-enforcement agencies. It is essential to help rescue centres and NGOs to 
obtain  more  space  and  resources  for  animal  care  and  welfare,  as  well  as  to  increase 
collaboration  across  relevant  public-  and  private-sector  bodies  with  transport  companies, 
courier companies and online platforms. This would help to ensure cross-sectoral and public-
private cooperation.  

As mentioned above, 75% of NGOs and 71% of public authorities have said that the lack of 
resources  is  an  obstacle  of  either  ‘very  high’  or  ‘high’  significance  that  prevents  them 
tackling the  illegal  wildlife trade. 15% of  respondents  from  the expert survey have  advised 

85 

 
the implementation of a dedicated EU budget to incentivise and facilitate the implementation 
of a new or revised action plan. 

3.  STAKEHOLDER WORKSHOP  

a.  Priority 1 – Preventing wildlife trafficking and addressing its root causes  

The  following  strengths  of  the  action  plan  in  this  area  were  identified  in  the  stakeholder 
workshop:  (i)  the  action  plan  has  been  successful  in  implementing  many actions  (in 
collaboration,  lists, participating  in  operations,  awareness raising, etc.);  (ii)  the  action  plan 
has  been  successful  in  raising  the profile  of  the  fight  against  the  illegal  wildlife  trade 
easier 
on international 
to evaluate the magnitude  of the 
the  action  plan  has 
strengthened cooperation  with  and among  local communities  and authorities;  and  (v)  the 
action plan has increased civil-society initiatives against wildlife trafficking in Europe.  

the  action  plan  has  made 
(iv) 

and national levels; 

illegal  wildlife 

trade; 

(iii) 

it 

The following weaknesses of the action plan were identified in the stakeholder workshop: (i) 
the  action  plan  did  not  result  in  measurable  impacts;  (ii)  there  is  a  need  to prioritise  the 
actions in the action plan; (iii) the action plan does not address gaps in the legal framework; 
(iv) the action plan has too little focus on demand reduction; (v) there is a disconnect in the 
action  plan  between outreach  in  raising awareness  versus  the  actual impact  of  this  outreach 
on  legislation and  bringing  about change;  (vi)  the  action  plan  does  not  cover  non-CITES-
indicators, 
listed  species;  (vii) 
and reliable data; (viii) the action plan lacks a monitoring and evaluation framework; and (ix) 
the action plan lacks funding and resources.  

lacks  a  clear baseline,  measurable 

the  action  plan 

b.  Priority 2 - Making implementation and enforcement of existing rules and 

the fight against organised wildlife crime more effective 

The  two  main  strengths  of  the  action  plan  in  this  area  were  identified  in  the  stakeholder 
workshop:  (i)  the  action  plan  has  helped  raise  political  attention  at  EU  level;  and  (ii)  the 
action  plan  has  improved  knowledge  and  capacity  building.  The  main  weaknesses  of  the 
action plan in this area that were identified in the workshop were: (i) the action plan’s lack of 
a dedicated budget; (ii) that there has been no transposition of the action plan at the national 
level;  (iii)  that  it  is  difficult  to  monitor  and  evaluate  cooperation  and  coordination  between 
Member States and  authorities;  (iv) that rescue centres face all the responsibility for caring 
for/handling  seized  animals;  and  (v)  the  lack  of  resources  to  implement  the  action  plan  – 
especially human resources. 

c.  Priority 3 - Strengthening the global partnership of source, consumer, 

and transit countries against wildlife trafficking 

The  two  main  strengths  of  the  action  plan  in  this  area  were  identified  by  the  workshop, 
namely that: (i) the channels and tools for information exchange already exist and should be 
maintained;  and  (ii)  there  is  strong  cooperation  at  EU  level.  The  main  weaknesses  of  the 
action  plan  in  this  area  that  were  identified  by  the  workshop  were:  (i)  that  it  is  difficult  to 
identify how financial support is attributed to developing countries; (ii) that EU delegations 
in some countries do not know about the action plan; and (iii) that there are inconsistencies 
within reporting to EU-TWIX between Member States. 

86 

 
ANNEX VI: 
ACTION 

   OVERVIEW  OF  PROGRESS  IN  IMPLEMENTATION  OF  THE  ACTION  PLAN,  BY 

Priority I – Preventing wildlife trafficking and addressing its root causes  

Actions  

Objective 1.1 

Reduce 
the  demand 
supply of illegal wildlife products 

for  and 

1.  Increase  support  for  awareness-  raising 
and  targeted  demand  reduction  campaigns 
in the EU and worldwide  

Progress 

Some progress 

2.  Further  limit  trade  in  ivory  within  and 
from the EU 

Good progress 

Objective 1.2 

Ensure  that  rural  communities  in 
source  countries  are  engaged  in 
and 
from  wildlife 
conservation 

benefit 

3.  Reduce  or  ban  unsustainable  imports 
into  the  EU  of  endangered  species  by 
in  CITES 
proposing 
Appendices (e.g. rare reptile species) 

listing 

their 

4.  Strengthen 
communities 
conservation of wildlife  

in 

engagement  of 
rural 
the  management  and 

5.  Support  the  development  of  sustainable 
and 
for 
communities  living  in  and  adjacent  to 
wildlife habitats  

livelihoods 

alternative 

Good progress 

Some progress 

Some progress 

Objective 1.3 

6.  Raise  awareness  of  business  sectors 
trading  in  wildlife  products  within/from 
the EU or facilitating such trade 

Some progress 

business 

Increase 
sector 
engagement  in  efforts  to  combat 
wildlife  trafficking  and  encourage 
sustainable  sourcing  of  wildlife 
products 

7. Support private-sector initiatives to curb 
the  illegal  wildlife  trade  and  encourage 
sustainable  sourcing  of  wildlife  products 
in/from the EU 

Some progress 

87 

 
 
 
 
 
 
 
 
 
Objective 1.4 

Tackle  corruption  associated  with 
wildlife trafficking  

Actions  

initiatives 

8.  Support 
corruption 
trafficking  at  national, 
international levels 

the 
to 
associated  with  wildlife 
regional  and 

fight 

Progress 

Some progress 

Priority  2  –  Making  implementation  and  enforcement  of  existing  rules  and  the  fight 
against organised wildlife crime more effective  

Objective  2.1:  Ensure  more  even 
implementation of EU rules on the 
wildlife  trade  and  develop  a  more 
strategic  approach  to  checks  and 
the  enforcement  of  rules  against 
wildlife trafficking at EU level 

Actions  

9.  Develop 
improve 
strategies 
compliance with EU wildlife legislation at 
national level 

to 

Progress 

Some progress 

10.  Improve  rate  of  detection  of  illegal 
activities  

Some progress 

up 

efforts 

to 
the  EU 

ensure 
Step 
11. 
implementation  of 
roadmap 
towards  eliminating  the  illegal  killing, 
trapping  and  trade  of  birds  (also  relevant 
under Priority 1)  

Some progress 

12.  Define  and  assess  priority 
regularly  

risks 

Good progress 

13.  Improve  cooperation  among  Member 
States  on  cases  of  cross-border  wildlife 
trafficking  

Good progress 

14.  Review  the  EU  policy  and  legislative 
framework on environmental crime in line 
with the European Agenda on Security  

Some progress 

Objective 2.2: Increase capacity to 
combat  wildlife  trafficking  of  all 
parts  of  the  enforcement  chain 
and the judiciary 

15.  Improve  cooperation,  coordination, 
communication and data flow between the 
enforcement  agencies  responsible  in  the 
Member States  

Some progress 

88 

 
 
 
 
 
 
 
 
 
 
Actions  

16.  Improve  knowledge  base  on  checks, 
investigations,  prosecutions  and  judicial 
proceedings against wildlife trafficking 

Progress 

Some progress 

17.  Step  up  training  for  all  parts  of  the 
enforcement chain, including joint training 
activities  

Some progress 

18.  Strengthen  or,  where  applicable, 
establish  practitioner  networks  at  national 
and 
improve 
level, 
cooperation between them 

regional 

and 

Some progress 

19.  Improve  care  of  seized  or  confiscated 
live animals or plants  

Some progress 

Objective  2.3:  Fight  organised 
wildlife crime more effectively 

20.  Regularly  assess  the  threat  posed  by 
organised wildlife trafficking in the EU  

Good progress 

21.  Boost  capacity  of  relevant  experts  to 
tackle the links of wildlife trafficking with 
organised crime, including cybercrime and 
related illicit financial flows  

Some progress 

Some progress 

Some progress 

22.  Member  States  ensure,  in  line  with 
international  commitments  made, 
that 
organised  wildlife  trafficking  constitutes 
throughout  the  EU  a  serious  crime  under 
the  UN  Convention  against  Transnational 
Organized  Crime,  i.e.  that  it  is  punishable 
by imprisonment of a maximum of at least 
four years 

23.  Member  States  review,  in  line  with 
UNGA  Resolution,  national  legislation  on 
money  laundering  to  ensure  that  offences 
connected  to  wildlife  trafficking  can  be 
treated  as  predicate  offences  and  are 
actionable  under  domestic  proceeds  of 
crime legislation 

89 

 
 
 
 
 
 
 
 
 
Objective 
international 
enforcement 
trafficking 

Improve 
2.4: 
cooperation 
on 
against  wildlife 

Progress 

Good progress 

Actions  

24.  Step  up  cooperation  on  enforcement 
between 
the  Member  States  and  EU 
enforcement  actors  and  key  non-EU 
countries  and  other  regional  Wildlife 
Enforcement  Networks,  relevant  global 
networks  (International  Consortium  for 
Trafficking, 
Wildlife 
Combating 
ICCWC106,  and  the  International  Network 
for  Environmental  Compliance 
and 
Enforcement, INECE)  

25.  Support  capacity  building  for  law 
enforcement  in  key  source  and  market 
countries,  including  enforcement  within 
protected sites  

Some progress 

106  Comprising Interpol, the CITES Secretariat, the World Customs Organisation, UNODC and the World Bank.  

90 

 
 
 
 
                                                 
Priority  3  -  Strengthening  the  global  partnership  of  source,  consumer  and  transit 
countries against wildlife trafficking  

Actions  

Objective 3.1: 

Provide increased, more effective 
and  more  strategically  focused 
support to developing countries  

trafficking 

26.  Ensure 
is 
that  wildlife 
considered  for  EU  funding  under  relevant 
programmes in the areas of natural resources 
management, environment, organised crime, 
security and governance  

Progress 

Some progress 

Objective 3.2 

Strengthen and coordinate better 
action against wildlife trafficking 
and  its  root  causes  with  relevant 
source, 
transit  and  market 
countries 

27. Increase effectiveness of funding support 
against wildlife trafficking 

Some progress 

28. Step up dialogue with key source, transit 
and  market  countries,  including  dialogue 
with local communities, civil society and the 
private sector  

Some progress 

29.  Use  EU  trade  policies  and  instruments 
proactively to support action against wildlife 
trafficking  

Some progress 

Objective 3.3 

Address  security  dimension  of 
wildlife trafficking 

Objective 3.4 

Strengthen multilateral efforts to 
combat wildlife trafficking  

Some progress 

Good progress 

Good progress 

with 

relevant 

30.  Strengthen  cooperation  against  wildlife 
regional 
trafficking 
organisations,  such  as  the  African  Union, 
SADC, 
the  East  African  Community, 
ASEAN,  and  in  relevant  multilateral  fora, 
such as ASEM 

31.  Improve  knowledge  base  and  develop 
links  between 
strategies 
wildlife trafficking and security 

tackle 

the 

to 

adoption 

the 
of 

and 
Support 
32. 
implementation 
decisions, 
resolutions  and  political  declarations  on 
international 
trafficking 
wildlife 
instruments and multilateral fora 

strong 

in 

91