Wildlife Crime - Environmental Audit Committee Contents

2  International Wildlife Crime

8.  Due to its clandestine nature, the scale of the international illegal trade in wildlife is difficult to quantify. For example, when United States Congress considered the overall value of international wildlife crime in 2008, it found that it was worth at least $5 billion a year, but might total in excess of $20 billion.[12] Another estimate valued the illegal international wildlife trade at between $7.8 billion and $10 billion a year.[13] Wildlife has been estimated to constitute the world's fourth largest criminal market, behind drugs, counterfeiting and human trafficking.[14]

9.  As with any trade, the illegal wildlife market requires supply and demand. The 2012 UN Rio+20 Summit declaration stated:

We recognize the economic, social and environmental impacts of illicit trafficking in wildlife, where firm and strengthened action needs to be taken on both the supply and demand sides.[15]

Since our predecessor Committee's Report in 2004, increased demand for illegal wildlife products has helped to drive the rhino, tiger and elephant to the verge of extinction. In our latest inquiry, we took detailed evidence on the supply of and demand for illegal wildlife products derived from those species, although other animals—notably reptiles and amphibians—are also threatened.


10.  The supply chain for trafficked illegal products derived from elephants, rhinos and tigers begins with poaching in Africa and Asia. The main source for illegal ivory is central Africa, where the elephant population is rapidly declining due to poaching. For example, the Democratic Republic of Congo was once home to more than 100,000 elephants, but now there are only four separate groups of more than 500 elephants and the entire population may be as low as 2,500 elephants.[16] The Elephant Trade Information System (ETIS), which monitors the elephant trade on behalf of parties to CITES, observed

a steadily increasing trend in levels of illicit ivory trade from 2004 onwards, with an exceptionally sharp upsurge in 2009 … Data demonstrate that seizures of ivory reached record levels in 2009 and that these levels were largely sustained in 2010.[17]

In 2011, ETIS recorded the largest number of ivory seizures in its 23-year history.[18] The gangs profiting from the lucrative illegal ivory trade in central Africa reportedly include militias such as the Janjaweed.[19]

11.  There are five species of rhinoceros, three of which are native to southern Asia and two to Africa.[20] All are to a greater or lesser extent threatened by extinction in the wild. Rhino deaths from poaching have increased markedly in recent years. In 2010, 333 rhinos were illegally killed in South Africa, including 10 critically endangered black rhinos. In 2011, 448 rhinos were killed, of which 19 were black rhinos.[21] Over the past 100 years, tigers have lost 93% of their historic range, and all six sub-species of tiger are classified as endangered. The global population in the wild is estimated to number between 3,000 and 4,000 individuals, mostly in small pockets that are isolated from each other. The area occupied by tigers is estimated at less than 1.2 million square kilometres, a 41% decline since the mid-1990s.[22] The operation of 'tiger farms' in south-east Asia, which supply products derived from captive tigers, does not appear to have affected the decline of tigers in the wild.[23]

12.  Perhaps surprisingly, the UK is also a source for illegal rhino horn and ivory. Criminals are purchasing or stealing antique items, such as carved rhino horn libation cups and elephant ivory billiard balls, which are sometimes ground down before being re-sold on the black market.[24] In September 2010, the Animal Health and Veterinary Laboratories Agency detected a surge in the number and value of rhino horn products being exported from the UK. Defra told us:

As a result of concerns about the increasing level of re-exports of antique rhino horn, and that sales appeared to be based on the weight of the horn rather than on antiquity, and that these activities mirrored increased poaching across Southern Africa, the AHVLA recommended that stricter controls be introduced on such re-exports and sales. This was adopted by the UK and subsequently also by EU member states.[25]

Analysis by the International Fund for Animal Welfare (IFAW) indicates that antique ivory and rhino horn products are being advertised and sold on the internet in the UK and being illegally shipped to south-east Asia and China.[26] We discuss later the need for the NWCU to be tasked and funded to monitor wildlife crime on the internet (paragraph 69).


13.  In the past decade, the increased poaching of rhinos, elephants and tigers has largely been driven by the demand for illegal wildlife products in Asian countries, mainly China.[27] We investigated whether this might be a function of Traditional Chinese Medicine, but found that it was not a significant factor.[28] Instead, increased demand in China and south-east Asia appeared to be a function of a newly affluent society, where purchasing illegal wildlife products had recently developed both as an investment— essentially, the closer an endangered species is to extinction, the higher its investment value[29]—and as a form of conspicuous consumption.[30] The current focus of UK CITES enforcement on trafficking related to traditional medicine[31] may be misplaced, because our findings on the nature of demand in south-east Asia and China for illegal wildlife products suggest that wildlife crime driven by investment and conspicuous consumption is more significant.


14.  IFAW's Asia Regional Director commented:

There are people in China, the class with extreme wealth … who may have connections with criminal syndicates. They have power, they have connections. They often have anonymity, and they may order ivory, large shipments of ivory, from Africa on the internet or via the phone. They are conducting this illegal trade and hiding behind it.[32]

In the past decade, the profits that can be made from investing in illegal ivory in China have expanded because of the increased strength of renminbi.[33] IFAW's Asia Director pointed out:

If the Chinese buy ivory anywhere else in the world, they have to buy it in US dollars. For the Chinese, that makes buying ivory anywhere else in the world cheaper and the profit margin on that ivory, once it is smuggled into China and sold on the market—it is very easily sold illegally on the market because it is covered by the legal trade—is huge. That is a great incentive for people who are engaging in this illegal trade.[34]

15.  Southern African elephant range states[35] conducted two one-off, CITES-approved sales of stockpiled seized ivory in 1999 (50 tonnes) and 2008 (100 tonnes) to approved buyers in Japan and China. The aim of both sales was to reduce ivory prices and therefore undermine illegal trade, but our witnesses told us that instead it exacerbated demand for ivory products and undermined the CITES regime in China.[36] The sale of ivory is generally illegal in China, but the two one-off sales of legal ivory appear to have stimulated the illegal market by promoting interest in carved ivory. IFAW's Asia Director explained:

China imported 62 tonnes of ivory in 2008 from this stockpile sale, so China has a legal ivory market … Even law enforcement officers could not distinguish what is legal from illegal.[37]

Ivory in the second one-off legal sale, in 2008, was bought for an average price of $157 a kilogramme by approved buyers such as the Chinese State Forestry Administration, which sold its ivory to traders for up to $1,500 a kilogramme. That mark-up is reflected in the prices of ivory products in retail outlets such as the Chinese Government-owned Friendship Store, which is accredited by the Chinese Government to sell ivory products. Recent reports indicate that the price of illegal ivory in China has increased ten-fold since 2005 in response to the stimulus from the legal market.[38] Indeed, we even heard about a Chinese bank that runs an investment fund based on elephant ivory.[39]

16.  China is a signatory to CITES, which means in theory that all other trade in elephant ivory is illegal. In practice, those international commitments have been undermined by contradictory domestic laws and weak enforcement. IFAW's Asia Director emphasised that "wildlife enforcement—effective enforcement—has to be aided by clear policies and laws … In terms of legal versus illegal, it is very murky for a consumer".[40] Similarly, the Environmental Investigation Agency, an environmental NGO, noted:

There is no proactive enforcement and there is no intelligence-led enforcement. The Chinese authorities are aware of the level of illegal ivory available on the market, and doing nothing about it. Trade is going on in front of police.[41]


17.  Rhino poaching is driven by increased prices for horn in China and south-east Asia in general and in Vietnam in particular, where demand has been compounded by the growth of a damaging rumour that rhino horn is a cure for cancer.[42] IFAW's Asia Director pointed out:

The auction records in 2011 show that 2,750 pieces of rhino horn carving were sold in mainland China, total sale price US $18 million, which was an increase of 90% and 111% respectively from the previous year.[43]

Individuals who hold large stockpiles of rhino horn have an interest in the species becoming extinct in the wild, because this will increase the scarcity value of their investment. IFAW explained:

In China, people are buying rhino horn as an investment. That is why it is comparable with the price of gold but being more than gold; the rarer the animal, the higher the value of that animal's product … they are banking it, basically like they are banking gold. It is one of the secure things that you can bank in.[44]


18.  The illegal poaching of tigers is also driven by demand for wildlife products in south-east Asian countries in general and in China in particular, but demand for tiger products appears to be purely a function of conspicuous consumption rather than a type of investment. The Environmental Investigation Agency pointed out:

China is still the primary consumer, and that is evidenced from the seizures from neighbouring countries. Tiger and other Asian big cat skins are used for luxury home dcor, taxidermy, among the business, political and military elite, and for personal purchase as gifts.[45]

Similarly, TRAFFIC observed:

A lot of it is for status, it is for show, so it is going to be difficult for us to combat that, because we need to try to get a change in the motivation behind individuals in China. They are buying items, like tiger bone wine, which are conspicuously expensive, as gifts to their superiors, as gifts to others. It is very much a social status thing.[46]


19.  Quantifying the demand for trafficked wildlife products in the UK is problematic due to the way in which wildlife crime is currently recorded (paragraph 71). However, it is clear that some people more or less innocently import illegal wildlife souvenirs[47], that a minority of practitioners of Traditional Chinese Medicine utilise illegal wildlife products[48] and that there is a degree of conspicuous consumption of the kind seen on a much larger scale in China and south-east Asia.[49] It is clearly important that wildlife crime law enforcement is maintained in the UK, because the UK must have its own house in order if it is to provide effective international leadership and set standards in this field.

International enforcement

20.  CITES is the key instrument for international co-operation against the illegal wildlife trade. CITES accords varying degrees of protection to some 5,000 species of animals and 28,000 species of plants. Species are added to or removed from the two CITES appendices on a rolling basis depending on their current conservation status, and listed species can only be traded with a CITES permit.[50] Only one CITES-protected species has ever become extinct as a result of illegal trafficking, which supports claims for the past efficacy of the regime.[51]

21.  The 2012 UN Rio+20 Summit declaration highlighted the importance of international co-operation on CITES enforcement:

We recognise the important role of the Convention on International Trade in Endangered Species of Wild Fauna and Flora, an international agreement that stands at the intersection between trade, the environment and development, promotes the conservation and sustainable use of biodiversity, should contribute to tangible benefits for local people, and ensures that no species entering into international trade is threatened with extinction. We recognise the economic, social and environmental impacts of illicit trafficking in wildlife, where firm and strengthened action needs to be taken on both the supply and demand sides. In this regard, we emphasise the importance of effective international co-operation among relevant multilateral environmental agreements and international organisations. We further stress the importance of basing the listing of species on agreed criteria.[52]

22.  Every two to three years, CITES signatories meet at a Conference of the Parties to review the implementation of the Convention. The next meeting will be held in March 2013, which will provide the UK Government with an opportunity to demonstrate leadership on the international issues raised by our inquiry. European Union countries vote as a bloc at CITES meetings, which means that the Government will need to build European consensus. It is a matter of grave concern that increased poaching, driven by demand for illegal wildlife products, threatens the rhino, tiger and elephant with extinction. The Government must take a leading role in exerting robust diplomatic pressure in favour of the development and enforcement of wildlife law at the next CITES Conference of the Parties in March 2013. In particular, the Government should focus attention on the damaging effect of 'one-off' sales of impounded ivory, which undermine the international CITES regime and fuel demand for ivory products, and seek an unequivocal international ban on all forms of ivory trade. Such commitments are essential but may not be sufficient to protect those species that are most endangered because of the persistent demand for products derived from them. Ultimately, rhinos, tigers and elephants will only survive as wild species if attitudes change. In the run-up to the 2013 CITES Conference, the Government should seek international support for an exploration of new ideas to challenge demand for such illegal wildlife products.

UK implementation of CITES

23.  CITES controls within EU countries are set out in the Wildlife Trade Regulations and implemented in UK law by the Control of Trade in Endangered Species Regulations (COTES). The most direct way in which the UK can contribute to international action against the illegal trade in wildlife is by itself running an effective internal CITES regime. This is especially important if the UK is to provide international leadership on addressing wildlife crime, but some provisions of the COTES Regulations do not appear to be facilitating effective enforcement:

  • Under COTES Regulation 5, the UK Border Agency (UKBA) has the power to seize items it believes to have been imported unlawfully and to require the owner to show evidence of lawful importation. The police also often come across similar situations in the course of their investigations, but they do not have a similar power and must rely on UKBA to agree to use its powers in such cases on its behalf. This is repetitious, wastes time and resources and may result in serious wildlife crimes not being investigated.[53]
  • An authorised member of the Animal Health and Veterinary Laboratory Agency Wildlife Inspectorate has the power under COTES Regulation 9(4) to enter any premises to inspect a specimen, but police officers can do so only if they suspect that an offence has been committed and they have obtained a search warrant, which takes time and resources.[54] On the other hand, the Wildlife and Countryside Act 1981 allows the police to enter any land that is not a dwelling to obtain evidence of suspected offences without a search warrant.
  • COTES Regulation 9(3) stipulates that a vet must be present where samples are taken in CITES cases.[55] That appears reasonable in cases involving living animals, but it does not include an exemption for plants, and it also applies to dead specimens. As a result, a vet might have to be called out to take a sample from, for example, a table constructed from Brazilian rosewood.[56]
  • In addition, questions have been raised about the regulations covering the sale of caviar,[57] which do not include a sanction for non-compliance, and the certification system covering changes in ownership of specimens of protected species,[58] which may form a loophole for wildlife traffickers.

24.  Such criticisms of the COTES regime have been voiced by both the police and NGOs.[59] Defra informed us that it was reviewing the operation of COTES, but it did not provide details of the timescale, focus or scope.[60] In order to ensure the efficient operation of the CITES regime in the UK, Defra must amend the COTES Regulations, focusing on the effectiveness of Regulations 5, 9(3) and 9(4) and their scope for consistent application by the various wildlife crime enforcement agencies.

12   Congressional Research Service, International Illegal Trade in Wildlife: Threats and U.S. Policy, August 2008, p 2. Back

13   Jeremy Haken, "Transnational Crime in the Developing World", Global Financial Integrity, February 2011. Back

14   Ev 88 Back

15   United Nations, Rio+20 Declaration, para 203. Back

16   Ev w41 Back

17   Ev 104 Back

18   Ev 104 Back

19   Q 92 Back

20   White Rhinoceros, Black Rhinoceros, Indian Rhinoceros, Javan Rhinoceros and Sumatran Rhinoceros. Back

21   Ev w41 Back

22   International Union for the Conservation of Nature, Red List of Threatened Species. Back

23   Qq 163, 169 Back

24   Q 94 Back

25   Ev 121 Back

26   Ev 107 Back

27   Ev 100 Back

28   Q 123 Back

29   Ev 104 Back

30   Q 160 Back

31   Ev 149 Back

32   Q 161 Back

33   Chinese currency. Back

34   Q 161 Back

35   The 1999 sale included ivory from Botswana, Namibia and Zimbabwe. The 2008 sale included ivory from Botswana, Namibia, Zimbabwe and South Africa. Back

36   Ev 101 Back

37   Q 163 Back

38   Ev 101 Back

39   Q 175 Back

40   Q 163 Back

41   Q 118 Back

42   Ev w41 Back

43   Q 160 (That is a 90% increase in the number of rhino horn items sold and a 111% increase in the value of those items). Back

44   Q 123 Back

45   Q 127 Back

46   Q 128 Back

47   Q 100 Back

48   Q 303 Back

49   Q 281 Back

50   Appendix I lists species faced with imminent extinction in the wild. Appendix II lists species that would face extinction if trade were not tightly controlled. Back

51   Spix's Macaw. Back

52   United Nations, Rio+20 Declaration, para 203. Back

53   Q 294; Ev 152 Back

54   Ev 152 Back

55   ibid. Back

56   ibid. Back

57   ibid. Back

58   ibid. Back

59   Ev 118 Back

60   ibid. Back

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© Parliamentary copyright 2012
Prepared 18 October 2012