Purpose
This document is intended to raise awareness of biodiversity, biosecurity and welfare risks associated with the legal and illegal trade in wildlife.
This policy is mainly focused on the illegal export of Australian native wildlife, however it is acknowledged that the import of exotic wildlife is also a significant issue.
Policy
1. The AVA supports the ban on the export of live native Australian mammals, birds, reptiles, and amphibians for commercial purposes, under the Environment Protection and Biodiversity Conservation Act 1999. The AVA encourages the extension of this ban to include any of the following fresh water and marine species intended for the ornamental trade: wild caught native Australian fish, cephalopods, crustacea and corals.
2. Any legal trade for non-commercial purposes such as public exhibition or scientific research should be carefully weighed against welfare risks, and should not occur unless there is a conservation benefit.
3. The AVA supports Australian legislation that limits the keeping of imported exotic species as pets, and advocates strengthening and enforcing current legislation.
4. The AVA also supports current state and territory legislation that limits the keeping of Australian native wildlife as pets to those species that are demonstrated to be suitable for a domestic environment.
5. Any permitted legal trade must be conducted with the highest standards of animal welfare, through appropriate regulatory oversight and training of participants.
6. The legal trade must be transparent and sustainable, through mechanisms such as use of electronic permitting systems, tagging (where practical) and recording in a nationwide centralised register, registration of businesses, and public education. Any legal trade where this has not been demonstrated is opposed.
7. The AVA acknowledges the significant welfare and biodiversity impact the illegal wildlife trade has on trafficked Australian native species.
8. Greater effort must be made to combat the illegal trade, including increased resourcing and training for detection, enforcement, prosecution, and care of seized animals, as well as the imposition of larger penalties.
Background
Definitions
For the purposes of this policy, the ‘wildlife trade’ refers to the legal and illegal trade in live wild animals, both wild sourced and captive bred.
For the purposes of this policy, ‘Exotic Pet’ refers to species that would be considered unusual or uncommonly kept in a home and would in general be accepted to be a wild species rather than domesticated. In the case of Australia, the EPBC Live import list contains several birds and fish which may be imported into Australia as pets, but in general reptiles, amphibians and mammals are excluded for importation as pets. A limited number of exotic reptiles, amphibians and mammals are legally kept under permit because of historic importation.
Regulatory framework
In Australia, the trade of wildlife occurs through both legal and illegal channels, via import and export. In principle, through the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), Australia maintains a strong position in relation to the wildlife and exotic pet trade: under the EPBC Act, it is illegal to export a native Australian mammal, reptile, bird or amphibian to another country for a commercial purpose. (EPBC Act, 1999)
Illegal wildlife trafficking laws vary considerably across the world, with some countries only legislating against the international trade of animals listed on the Convention of International Trade in Endangered Species of Wild Fauna and Flora (CITES) list. CITES is a global agreement among governments to regulate or ban international trade in species under threat. Many of the Australian native animals popular in the exotic pet trade are either not listed with CITES or at a level that does not protect them once they have left Australia. As such they can be legally traded in some countries. This means the ability to detect illegal wildlife trafficking on Australian soil before animals are trafficked overseas is critically important in disrupting criminal networks.
The EPBC Act does permit some limited export of native fauna for non-commercial purposes. This includes export for zoological purposes, scientific research, and conservation breeding. There is also some legal trading of wildlife permitted for the exotic pet trade, most notably the international aquarium trade.
Where legal trade in wildlife does occur, the AVA is supportive of Australia’s commitment to the Kunming-Montreal Global Biodiversity Framework[1] particularly, Target 5 of this agreement, “Ensure that the use, harvesting and trade of wild species is sustainable, safe and legal, preventing overexploitation, minimising impacts on non-target species and ecosystems, and reducing the risk of pathogen spillover, applying the ecosystem approach, while respecting and protecting customary sustainable use by indigenous peoples and local communities.” The AVA notes Australia’s commitment to CITES and the CITES Strategic Vision: 2021-2030 and acknowledges its linkage to the Biodiversity Framework.
Scale of legal trade in live animals
The 2022 CITES State of Trade report (CITES Secretariat, 2022) suggests in the decade of 2011-2020, globally there were 82 million animals and 86 million kilograms of animal material by weight reported as traded involving 58% of CITES listed species. The value of the legal global trade in wildlife was estimated variously at USD$220 – 320 billion (UK Parliament, 2012; WCO, 2017) and the 2022 CITES report suggests animal trade represents approximately 20% of CITES listed trade. The AVA notes with concern that there are no interoperable worldwide systems in place to capture species information, or to quantify volume or trends of trade in non-CITES listed species.
Consumer Desire and Regulation – The scale of global trade in wildlife, including the exotic pet trade, is growing annually, because of increasing consumer demand. There is a worrying lack of oversight and regulation of this trade. This is particularly the case for non-CITES species.
Wild Sourcing and Captive Breeding – CITES reported figures for the decade 2011-2020 show more than 50% of individual CITES listed animals were wild sourced. Captive breeding also plays a role in the support of the wildlife trade, and it is important that this is done in a manner that maintains transparency, safeguards animal welfare, and does not further impact wild populations of the same species.
What illegal activities currently occur?
There is strong evidence of illegal trade of Australian wildlife within and exported from Australia, and illegal importation of exotic wildlife into Australia (Toomes et al, 2023; Heinrich et al, 2022; AUSTRAC, 2020; Daeid et al, 2021; Chekunov et al, 2024).
Estimates of the scale and value of the global illegal wildlife trade vary widely. In part, this is as a result of the point of valuation being determined at origin, destination or cumulatively through the chain of supply. In addition, the clandestine nature of the trade further complicates this. Various estimates put the value of the global trade conservatively at USD$10 billion in 2012 (UK Parliament, 2012) while the World Bank Group reported figures of USD$7-23 billion in 2019 (Miranda Montero et al, 2019). The illegal wildlife trade is considered the fourth largest criminal endeavour behind drug trafficking, counterfeiting and human trafficking (Miranda Montero et al, 2019).
What are the concerns and risks of the wildlife trade (both legal and illegal)?
There are multiple risks associated with both legal and illegal trade of wildlife and the exotic pet trade.
Animal welfare
Welfare risk exists at all stages of wildlife trade from capture to final destination. Poor welfare may result from injury or stress during capture and transport, inappropriate housing, husbandry, environmental conditions, poor hygiene, disease, or lack of or inadequate provision of food and water.
The AVA holds grave concerns for the welfare impact on illegally trafficked animals and argues that greater effort should be made to address the illegal trade in relation to detection, enforcement, and penalties, including the application of relevant state and territory Animal Welfare legislation.
Biosecurity
It is widely accepted that the trade in live or dead wildlife (or parts thereof), both legal and illegal, poses a significant biosecurity risk. This includes disease transmission to free ranging native species populations, the risk to Australia’s livestock industries, and as a source of human disease pandemics. (Hulme, 2021; Hulme, et al, 2023; Lockwood et al, 2019; WOAH, 2021; WOAH, 2024; Fauziah et al, 2024; Brookes et al, 2022). For this reason, the AVA encourages enhanced transparency within all trade of wildlife globally and nationally.
Evidence shows that the primary source of invasive exotic species now, are escaped or purposely released, legally or illegally traded pets or wildlife posing a risk to native ecosystems (Lockwood et al, 2019; WOAH, 2024).
Biodiversity loss
The planet is facing a biodiversity loss crisis, with rates of species extinction dramatically above the historical extinction rate. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) Global Assessment Report on Biodiversity and Ecosystem Services (2019) suggests that direct exploitation is the largest driver of the loss of marine species and the second largest for terrestrial and freshwater species (IPBES, 2019).
Lack of Legal Trade Supply Chain Transparency and Governance
The AVA believes the existing legal trade in wildlife globally lacks transparency and governance. In relation to the existing trade in CITES listed species, the AVA notes CITES’ own reservations stated in 2023 that the current permitting system is open to “fraudulent use, “and encourages the global uptake of an electronic permitting system to allow end to end monitoring of trade and inhibit the parallel illegal trade.” (https://cites.org/eng/news/sg-statements/eCITES-transforming-global-wildlife-trade-management)
Lack of Sustainability
The AVA accepts the definition of Sustainable Use as defined in article 2 of the Convention on Biological Diversity (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.” The AVA recognises that current legal trade and certainly the illegal trade is not sustainable (IPBES, 2022; Hughes et al, 2023).
Links to organised crime
There is strong evidence to suggest a link between the illegal trade in wildlife and other organised crime (UK Parliament, 2012; WCO, 2017; Miranda Montero et al, 2019).
Recommendations
1. The AVA supports development and implementation of technology and systems to detect, intercept and disrupt the illegal trade in wildlife and the perpetrators of the trade. The AVA encourages increased regulation, enforcement, resources, and appropriate penalties.
2. The AVA encourages steps such as embracing a global electronic permitting system and improved business registries regarding consumption of wildlife, to better guide the validity of sustainability claims of the trade of wildlife. These steps are likely to also aid in more clearly separating legal from illegal trade of wildlife.
3. The AVA advocates for an urgent review of the existing CITES trade system to ensure its requirements are practical and meet conservation needs.
4. Transparency around the legal trade should be improved by:
· Modern domestic and international electronic permitting system e.g. eCITES
· Tagging (where practical) of all exotic pets and information sharing between jurisdictions
· All businesses breeding, sourcing, and trading wildlife and exotic pets must be on a Register of Businesses on the public record
· Businesses profiting from this trade should pay a levy on trade which can:
o Finance a nationwide centralised register
o Provide funding for training border security staff and police
o Finance additional resources for detection and prosecution
5. The legal trade should be based on the precautionary principle to ensure:
· Readily accessible information including an official list of permitted species that can be traded (Whitelist approach) (Hulme, 2015)
· Public education programs
· Development of a veterinary Code of Conduct in relation to exotic pets and wildlife (including in relation to professional expectations on ensuring authenticity of ownership and trade of exotic species, appropriate management of seized animals from illegal trade including disposal/return/homing)
· Relevant Veterinary training programs
6. Regular training programmes for customs personnel that incorporate:
· Verifying the legality of exports
· Identifying CITES Appendix II taxa
· Updates regarding CITES regulations
7. Greater effort must be made to combat the illegal trade:
· Greater resourcing and training for detection and prosecution
· Greater resourcing for the care of seized animals
· Higher penalties including consideration of prosecution of cases under State and Territory Animal Welfare legislation, in addition to the Environment Protection and Biodiversity Conservation (EPBC) Act
· Public education programs
8. The AVA supports training of barristers, judges and magistrates on the biosecurity and welfare consequences of the illegal live animal trade, to improve enforcement of penalties in the EPBC Act. The AVA believes that this training is important given the leniency to date of sentences for wildlife-related crimes in Australia.
9. Penalties do not currently provide an adequate deterrent to acts that contravene Australia’s wildlife laws. The AVA supports regular (at least every 5 years) reviews of the appropriateness of these penalties.
10. If veterinarians suspect that an animal presented to them may have been illegally acquired or held without an appropriate license, they are encouraged to contact the following agency provided they feel safe to do so:
Wildlife Trade Office
Phone: (Australia) 1800 075 065 or (International) +61 5156 5063
Email: wildlifetrade@dcceew.gov.au
References
AUSTRAC. (2020). Stopping the illegal trafficking of Australian wildlife – Financial crime guide, October 2020. https://www.austrac.gov.au/sites/default/files/2020-10/Stopping%20the%20illegal%20trafficking%20of%20Australian%20wildlife.pdf
Brookes, V. J., Wismandanu, O., Sudarnika, E., Roby, J. A., Hayes, L., Ward, M. P., Basri, C., Wibawa, H., Davis, D., Indrawan, D., Manyweathers, J., Nugroho, W. S., Windria, S., & Hernandez-Jover, M. (2022). A scoping review of live wildlife trade in markets worldwide. Science of The Total Environment, 819, 153043. https://doi.org/10.1016/j.scitotenv.2022.153043
Chekunov, S., Stringham, O., Toomes, A., Prowse, T., & Cassey, P. (2024). Scale of unregulated international trade in Australian reptiles and amphibians. Conservation Biology, 38, e14355. https://doi.org/10.1111/cobi.14355
CITES Secretariat. (2022). World wildlife trade report (a pilot edition for CoP19). CITES Secretariat. https://bvearmb.do/handle/123456789/3779
Daeid, N. N., Hackman, L., & Linacre, A. (2021). Wildlife crime in Australia. Emerging Topics in Life Sciences, 5(3), 487–494. https://doi.org/10.1042/ETLS20200288
Environment Protection and Biodiversity Conservation Act, No. 91. (1999).
Fauziah, I., Nugroho, H. A., Yanthi, N. D., Tiffarent, R., & Saputra, S. (2024). Potential zoonotic spillover at the human–animal interface: A mini-review. Veterinary World, 17(2), 289–302.
Heinrich, S., Toomes, A., Shepherd, C. R., Stringham, O. C., Swan, M., & Cassey, P. (2022). Strengthening protection of endemic wildlife threatened by the international pet trade: The case of the Australian shingleback lizard. Animal Conservation, 25, 91–100. https://doi.org/10.1111/acv.12721
Hughes, A., Auliya, M., Altherr, S., Scheffers, B., Janssen, J., Nijman, V., Shepherd, C. R., D’Cruze, N., Sy, E., & Edwards, D. P. (2023). Determining the sustainability of legal wildlife trade. Journal of Environmental Management, 341, 117987. https://doi.org/10.1016/j.jenvman.2023.117987
Hulme, P. E. (2021). Advancing One Biosecurity to address the pandemic risks of biological invasions. BioScience, 71(7), 708–721. https://doi.org/10.1093/biosci/biab019
Hulme, P. E. (2015). Invasion pathways at a crossroad: Policy and research challenges for managing alien species introductions. Journal of Applied Ecology, 52, 1418–1424. https://doi.org/10.1111/1365-2664.12470
Hulme, P. E., Beggs, J. R., Binny, R. N., Bray, J. P., Cogger, N., Dhami, M. K., Finlay-Smits, S. C., French, N. P., Grant, A., & Hewitt, C. L. (2023). Emerging advances in biosecurity to underpin human, animal, plant, and ecosystem health. iScience, 26(9), 107462. https://doi.org/10.1016/j.isci.2023.107462
Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). (2019). Summary for policymakers of the global assessment report on biodiversity and ecosystem services. https://doi.org/10.5281/zenodo.3553579
Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). (2022). Thematic assessment report on the sustainable use of wild species. https://doi.org/10.5281/zenodo.6448567
Kunming-Montreal Global Biodiversity Framework. (n.d.). UNEP. https://www.unep.org/resources/kunming-montreal-global-biodiversity-framework
Lockwood, J. L., Welbourne, D. J., Romagosa, C. M., Cassey, P., Mandrak, N. E., Strecker, A., Leung, B., Stringham, O. C., Udell, B., Episcopio-Sturgeon, D. J., Tlusty, M. F., Sinclair, J., Springborn, M. R., Pienaar, E. F., Rhyne, A. L., & Keller, R. (2019). When pets become pests: The role of the exotic pet trade in producing invasive vertebrate animals. Frontiers in Ecology and the Environment, 17(6), 323–330. https://doi.org/10.1002/fee.2059
Miranda Montero, J. J., Wright, E. M., & Khan, M. N. (n.d.). Illegal logging, fishing, and wildlife trade: The costs and how to combat it. World Bank Group. http://documents.worldbank.org/curated/en/422101574414576772
Toomes, A., Moncayo, S., Stringham, O. C., Lassaline, C., Wood, L., Millington, M., Drake, C., Jense, C., Allen, A., Hill, K. G. W., García-Díaz, P., Mitchell, L., & Cassey, P. (2023). A snapshot of online wildlife trade: Australian e-commerce trade of native and non-native pets. Biological Conservation, 282. https://doi.org/10.1016/j.biocon.2023.110027
UK Parliament. (2012). House of Commons Environmental Audit Committee – Wildlife crime – Third report of session 2012–13, Volume I. https://publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/140/14002.htm
World Customs Organization (WCO). (2017). Illicit trade report 2017, Section 3, 94–115. https://www.wcoomd.org/-/media/wco/public/global/pdf/topics/enforcement-and-compliance/activities-and-programmes/illicit-trade-report/itr_2017_en.pdf
World Organisation for Animal Health (WOAH). (2021). OIE wildlife health framework: Protecting wildlife health to achieve One Health. https://www.woah.org/fileadmin/Home/eng/Internationa_Standard_Setting/docs/pdf/WGWildlife/A_Wildlifehealth_conceptnote.pdf
World Organisation for Animal Health (WOAH). (2024). Guidelines for addressing disease risks in wildlife trade.
[1] Kunming-Montreal Global Biodiversity Framework: https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-en.pdf