Regulatory Brief

 AVMA Response to the FWS proposed rule to revise the regulations implementing the CITES


Formal title: Docket Number [FWS-R9-IA-2010-0083; 96300-1671-0000-R4] Revision of Regulations Implementing the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES); Updates Following the Fifteenth Meeting of the Conference of the Parties to CITES

On March 8, 2012 the U.S. Fish and Wildlife Service (FWS) proposed to revise the regulations that implement the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) by incorporating certain provisions adopted at the fourteenth and fifteenth meetings of the Conference of the Parties (CoP14 and CoP15) to the CITES and by clarifying and updating certain other provisions.


Brief Description:

The proposed changes would bring U.S. regulations in line with revisions adopted at the most recent meetings of the Conference of the Parties to the CITES, which took place in June 2007 (CoP14) and March 2010 (CoP15). The revised regulations would help the FWS to more effectively promote species conservation, help the FWS to continue to fulfill its responsibilities under the CITES, and help those affected by the CITES to understand how to conduct lawful international trade.

AVMA Response:

The AVMA supports the U.S. Fish and Wildlife Service (FWS) proposed rule, Revision of Regulations Implementing the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES); Updates Following the Fifteenth Meeting of the Conference of the Parties to CITES (docket number FWS-R9-IA-2010-0083; 96300-1671-0000-R4). The AVMA favors conservation of animals in their natural habitats and is an advocate for animals and animal health. As such, it is concerned about the possible extinction of many animal species. The AVMA supports the Endangered Species Act (ESA) and applauds the FWS for its efforts, along with those of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), relevant to conservation and protection of endangered and threatened species.

The data shared by the FWS in the proposed rule states that the declared value for U.S. international trade of CITES wildlife in 2008 was $486 million. In addition to the legal wildlife trade, the AVMA understands that there is substantial illegal trade globally of wildlife and wildlife parts. The Coalition Against Wildlife Trafficking (CAWT), an organization supported by the U.S. Department of State and the FWS, estimates that such annual global illicit trafficking may be $10 billion or more – just behind illegal guns and drugs in value. The proposed rule seems to facilitate legal possession and trade of CITES wildlife, while providing means to better detect and reduce the illicit possession and trade. The compilation of both should benefit conservation efforts for CITES wildlife in their natural habitats.

Background Documents:

Full AVMA Response (PDF)

Proposed Rule (PDF)

Proposed Rule; Correction (PDF)

Relevant AVMA Policies: