CITES Sustainable Use
Group CSUG Minutes Thursday 27 March 2014
SUN-AHVLA Licensing Meeting Friday 6th December
SUN meeting Following from the JLG Meeting
November 21st 2013
JLG meeting 11 January 2012
Minutes SUN session
Guild of Taxidermists
International Centre for Birds of Prey
National Council for Aviculture
Apologies: Peter Berry (A Berry & Son Ltd), Sally Cunningham (Defra),
John, Philip McGowan (World Pheasant Association), Robert Morgan (British Fur Trade
Association), Aeron Williams (Parrot Society)
Welcome and introductions
JLG meetings were introduced by
Defra in 2006 to bring together traders and wildlife NGOs in a forum where CITES
issues could be discussed between the various groups, CITES policy and delivery officials. SUN members, for a number of years, have
participated in an additional bi-annual AHVLA organised meeting, which policy officials
attended as necessary.
Following a reduction in resources AHVLA told SUN in October 2011 that
they would not be able to provide the Secretariat for future such meetings. Nevertheless, members could attend the regular JLG
meetings to discuss non-case specific CITES Issues.
Summary of discussion - 11 Jan 2012
SUN expressed concerns about the
cessation of meetings hosted by AHVLA and felt that an important line of communication had
been removed. SUN stressed that consultation
should take place between Government and traders on relevant issues. SUN members were reassured at the meeting that it
always has been and remains Defra/AHVLA policy to consult with stakeholders on issues of
SUN were also concerned about
the propriety of discussing some commercially sensitive trade issues in the same fora as
AHVLA/Defra informed SUN that it was not their intention to curtail such
meetings but rather that with the JLG in existence the provision of Secretariat duties to
the SUN meeting could no longer be justified. They
and policy were available, as required, for bilateral meetings to discuss specific trade
Defra reiterated that the scope of the JLG was limited to CITES related
matters, and not broader biodiversity topics such as bird related issues under the
Wildlife and Countryside Act (WCA) 1981. Separate
meetings, involving the relevant Defra policy lead as appropriate, would need to be
arranged for those. Specific case related discussions should take place directly between
SUN and AHVLA and/or Defra.
SUN also asked for an update on team names and responsibilities.
SUN will arrange and provide Secretariat for future case related meetings, if
possible running these immediately before or after JLG meetings. Defra/AHVLA/SAs will attend these meetings as
Defra/AHVLA to circulate staff organisation charts to SUN members,
including those for DG Env
Annex A captive bred specimens
This topic related to proof of legal
origin for specimens not commonly kept and/or bred in captivity that were never originally
intended to be used
for commercial purposes. In cases, for
example, where a keeper keeps annex A specimens which they had not intended to sell and
therefore for which they do not have Article 10 certificates, if/when the animals breed
this can result in a surplus of animals which the keeper may then decide to sell.
SUN had previously suggested that AHVLA/Defra set up a registration scheme
to enable specimens kept but not intended for a commercial use to be registered, as this
would help with proof of legal origin if the keeper subsequently wished to use the
specimens commercially. A meeting between
SUN/Defra/JNCC took place on this matter several years ago.
At that time, and now, Governments view was that such a registration scheme
should not be established. Such a scheme could
not be imposed, was likely to be expensive, and was unlikely to be comprehensive if
introduced on a voluntary basis.
Defra confirmed, however, that long time periods between the time a specimen
was first acquired and the time of first application for an Article 10 would not in
itself be interpreted by default as evidence or suspicion of illegality of origin.
However, Defra / AHVLA encouraged
keepers to keep good records which could help in establishing the legal origin of such
Applications will continue to be considered on a case by case basis using a
risk assessment approach.
AHVLA would liaise with Chris Newman in respect of general guidance on the
sort of evidence which would be satisfactory for them to use as evidence of legal
The term commercial'
As part of the review of the EU
Wildlife Trade Regulations the European Commission had agreed that where there was a lack
of clarity in the existing regulations, this should be addressed either by changes to the
Wildlife Trade Regulations or by informal guidance. EU Member States had been asked to
assist with drafting these guidance notes which are expected to go through a period of
consultation within the EU and also with stakeholders.
The UK is involved in drafting guidance on the following topics:
Definition of primarily commercial purposes/commercial purpose
Questions related to transaction specific certificates
Definitions of applicant, importer/exporter, agent
The UK is also assisting a small number of other MS with drafting guidance
on other issues.
No final decisions had yet been taken on any guidance. Defra will ensure that relevant UK stakeholders are
consulted on the draft guidance once it is in a fit form and before it publication; this
is likely to be from spring 2012.
Defra to supply SUN members with a list showing which EU Member States are
involved in drafting each guidance.
AHVLA briefly provided an overview of Operation RAMP; an Interpol led global
operation aimed at the illegal trade in reptiles and amphibians.
SUN expressed a number of concerns, in particular the perceived heavy
handedness and timing of the Operation, which coincided with a procedural change, related
to return of transaction specific certificates on the sale of specimens. SUN believe that a number of traders who were not
aware of this change were disadvantaged by the timing of the operation. AHVLA stated that no such circumstance had resulted
in prosecutions. Several SUN members said they
thought communications from AHVLA on the procedural change were poor and that to ensure
future good compliance, communications should be timely and consistent. Participants took different views on whether the
TSC change was a significant one, but also explored how communications could be improved.
Nevin Hunter would convene a meeting in April 2012 to review Operation
RAMP to consider lessons learnt. This
will be an open meeting to which SUN Members will be invited.
Defra/AHVLA will consider how communication with the trade on any procedural
changes which are normally placed on the AHVLA website, could be improved.
Extracts from a Meeting between DEFRA Wildlife
Licensing and Registration Service (WLRS), Scientific Authorities & SUN
Representatives (Tuesday 1 March 2011,
a. Withdrawal of Pre-issued Certificates
under Article 63 of 865/2006
Hounslow (DEFRA)] explained that WLRS were no longer issuing semi-complete Article 10
certificates as there was evidence of them being used to illegally sell birds and that
breeders were consistently failing to provide adequate records and completing returns in a
timely fashion. Mike Gates (World Owl Trust)
stated that he hadnt received the letter informing traders of this; his members had
not been consulted and they were concerned that there would be problems hand-rearing owls
if they had to wait 6 weeks for an Article 10 certificate.
JH confirmed that WLRS met its targets so there shouldnt be a problem. Kim McDonald (Guild of Taxiderista) expressed his
frustration that this change affected taxidermy specimens but no criminal offences had
taken place for dead birds.
b. Bird Reg/A10 combined Application Form
A new form is
being developed to enable applicants to apply for an Article 10 certificate and register a
bird at the same time. This will save
time having to provide the same information twice.
c. Wild disabled birds
explained that WLRS has had concerns for some time about the number of wild Schedule 4
birds that are registered for rehabilitation and subsequently end up permanently kept in
captivity. WLRS will be taking a stricter view
to ensure that wherever possible any wild Schedule 4 bird taken into captivity is
rehabilitated and released back to the wild as soon as possible. They will be inspecting keepers of wild Schedule 4
birds to check that rehabilitation is occurring and that the keeper has sufficient
knowledge to successfully release the bird back to the wild.
are 2 new forms available for avian vets to download and complete http://www.defra.gov.uk/animalhealth/about/formsandfees/formdisplay.asp?ref=WLRS118 and http://www.defra.gov.uk/animalhealth/about/formsandfees/formdisplay.asp?ref=WLRS117
10 certificates for wild disabled birds will only be granted where there are genuine
exceptional conservation benefits to the species.
back from SRG meeting and
Plants and Animals Committee Meetings
Littlewood (JNCC) gave an overview of the last
Scientific Review Group (SRG) meeting which included discussions on eels, the new
suspension regulation and reptiles from Benin. She explained that the SRG regularly reviews
species and country combinations subject to long standing import suspensions. KD said that
he felt that transparency had
improved within the SRG but it
was not yet appropriate to the 21st century. AL stated that
there had been some progress in this regard and a lot of SRG reports and documents have
now been made available via the commission website
http://ec.europa.eu/environment/cites/home_en.htm including the agenda for the next
Charging, merger with VLA and other corporate proposals
that a submission is being sent to Ministers about increasing CITES charges. WLRS customers will be consulted. New fees are likely to be introduced in 2012. JH said that Animal Health was merging with VLA and
this may make bird imports more joined-up.
THE SUSTAINABLE USERS NETWORK (SUN)
The Sustainable Users Network (SUN) was established in the late
1980's at the specific behest of the UK's Department of Environment (now DEFRA) who were
getting frustrated at the number of organisations seeking to have dialogue with them and
the relative lack of professionalism from many of these groups. At the same time our
opponents likewise formed an umbrella grouping for discussions with Government (Wildlife
& Countryside Link).
At the universal agreement of all the affiliates to SUN it is
intentionally run on a relatively ad hoc and informal basis but acts as a single point of
contact to the likes of DEFRA and the JNCC (Joint Nature Conservation Committee) so that
regular meetings and such like can be organised with our Scientific and Management
Authority's. As such, SUN meets as a group of affiliates, share information, endeavour to
support each other in lobbying, etc. SUN's main role is to help ensure that animal and
plant interests, hobby and trade, work together and wherever possible have a unified
approach on legislation. The only requirement for SUN affiliation is that all
organisations are able to state that they support the concept of sustainable trade in
wildlife (i.e. trade in both captive-derived and wild-taken stock provided this is
undertaken sustainably i.e. within the constraints established by CITES for setting
quotas, establishing non-detriment findings, etc.).
In addition to the NCA - which has been an affiliate since the
inception of SUN - the Sustainable Users Network has a mass of organisations affiliated to
it amounting to a combined membership in the region of 1.2 million. Included in the
affiliated membership are two UK organisations concerned with field sport activities (The
Hawk Board and The British Association for Shooting and Conservation) and a host of others
connected with both plant and animal interests both trade and hobbyist - e.g. British
& Irish Association of Zoos & Aquaria, Pet Care Trust, National Association of
Private Animal Keepers, Timber Trade Federation, Guild of Taxidermists, Royal
Horticultural Society, International Owl Society, British Orchid Growers Association,
Parrot Society, to name but a very few. It is widely acknowledged by DEFRA that SUN has
been able to influence legislation a great deal more successfully than any of the
affiliates are able to do on their own.
Jim Collins - a keen bird-keeper - has been SUN's Co-ordinator for
the past fifteen years.