Cites Cop 17 – Traceability Information to Ensure Sustainable and Legal Trade

Three documents on traceability and information systems served at the Cites CoP 17 meeting held in Sandton during 24 September through 5 October 2016. A document on electronic and information systems and another on traceability were prepared for consideration by the CITES secretariat.

Mexico submitted a document on pilot testing of a global traceability information system for reptile skin that is being developed by the International Working Group of Reptile Skins (IWG-RS) of the Responsible Ecosystems Sourcing Platform (RESP). These documents can all be viewed at under documents 44, 45 and 46, respectively.

Three documents on traceability and information systems served at the Cites CoP 17 meeting held in Sandton during 24 September through 5 October 2016

The motivation for the introduction of traceability systems aims to ensure legal, sustainable, stable and continuous supply chains for endangered species listed under Cites. The proposal submitted by Mexico was to enhance the existing traceability systems (trade in crocodilians is already subject to the use of a tagging system, whereas the snakeskin industry has no similar tagging system).

The aim is to develop a traceability information system which can be used for all reptile skins (including crocodiles) with the intention of tracing skins from their origin in the wild or breeding facility up to the final product with controls along the entire supply and regulatory chains, in a biological feasible and economically viable way.

The system is based on biometric image recognition as the identification carrier that works through the acquisition of an image of a determined area of the reptile skin and then analysed by an algorithm to establish a Unique Fingerprint Identifier (UFI). The system uses a mobile application, linked to a global information system, capable of recognizing the unique characteristics of individual reptile skins and to establish the UFI.

Pilot studies throughout the entire supply chain are being undertaken through a collaborative framework between RESP, Mexico, Colombia and Indonesia as range countries and Italy as the importing and manufacturing country on Crocodylus moreletti, Caiman fuscus and Python reticulatus. The results to date as reported by Mexico appear promising.

However, the global traceability  information system as proposed for reptiles did not receive the general support of Parties at CITES, as well as by the IUCN-SSC Crocodile specialist group. CITES is concerned that the system being developed is too species orientated and that a traceability system should be complementary, mutually supportive and standardized across all CITES listed species.

CSG is of the opinion that unlike the snake industry (which depends largely from wild harvest), that the illegal trade in crocodile skins is less of a  problem  and that traceability can adequately be managed using the existing Cites tag and permit system.

Whereas the document on electronic and information systems was unanimously adopted this was not the case for the documents on traceability and in particular the pilot testing of a global traceability information system for reptile for the reasons already provided.

Instead a  task team was formed at the meeting to prepare a new draft decision on traceability by combining the two documents submitted by Mexico. A revised and amalgamated draft decision was eventually presented and adopted. It directs the Standing Committee of Cites to establish a working group on traceability that will work in collaboration with the Secretariat to inter alia:

  • Recommend a working definition of ‘traceability’
  • Ensure that traceability systems being developed are complementary, mutually supportive and standardized, as appropriate, and that they are adapted to the unique conditions relating to trade in CITES-listed species;
  • Provide general guidance on a mechanism to coordinate and oversee the development of traceability systems using lessons learned from the development of the global CITES permits and certificates system, global information and traceability systems, and other relevant initiatives;
  • Subject to the availability of external resources, and as appropriate, develop and make use of umbrella guidelines, and recommend standards, to develop traceability systems for different species that are mutually supportive and that generate standardized data;
  • Subject to the availability of external resources, analyse examples that describe CITES supply chains, including but not limited to those using Unified Modelling Language, and identify points throughout the supply chain where specimens should be located, verified, and its application defined, bearing in mind a wide range of production systems and life forms;
  • Take into account the work on e-permitting to ensure links between CITES permits and certificates and traceability identifiers;
  • Collaborate with United Nations and other relevant organizations that have experience in the development and use of traceability standards and systems;

The position adopted by Exotic Leather South Africa and the South African Crocodile Industry (and which was endorsed by the Department of Environmental Affairs), is that it endorses the concept of improved traceability to ensure the legal and sustainable supply of crocodile skins internationally. However, it does not support a global centralized information system (where domestic data is submitted & stored internationally under the management an international agency as proposed by RESP).

Exotic Leather SA is currently in the process of  developing software to establish a Crocodile Industry Register (“CIR”) for the South African crocodile industry which aims to  achieve the same traceability objectives and aims to supply valuable information for scientific research and accurate domestic industry statistics. The CIR aims to  keep locally generated  data confidential and secure (both at the farm and national level) by the hosting and management of the data under the Exotic Leather Research Centre established at Pretoria University.

Only relevant and summarized information will be released to both local and international stakeholders in order to protect confidential and trade sensitive information. Cites regulations requires that international trade information relating to  the international trade of crocodile produce needs to be submitted to Cites once the produce has been exported in order to monitor the international trade of listed Appendix ll species.

The Department Environmental Affairs is currently in the process of developing and electronic Cites permitting system (e-permitting)

The Department Environmental Affairs is currently in the process of developing and electronic Cites permitting system (e-permitting). This aim is that the Cites e-permitting system will integrate with the CIR to assist in the efficient processing of Cites permit applications.

Only relevant information relating to the export and traceability of exported produce will be submitted to the domestic and international centralized Cites databases once the export has occurred. Cites authorities currently fulfills this requirement. Exotic Leather SA (in collaboration with the Department of Environmental Affairs)  thus support the decision on traceability taken at COP 17.

Discussions were held between the CEO of RESP, Mr Stefan van As, Chairman of Exotic Leather SA and Prof Gerry Swan, Chairman of the South African  during the COP 17 meeting. We expressed our support for an improved traceability system, however we stated our position as outlined above regarding the  development of the global information system.

We indicated our interest to participate as a biometrics identifier pilot site test to  further studying the biometric image recognition system.  We also requested to be provided with the results of the pilot studies in crocodiles already completed to date for peer review prior to  making  commitments in respect of costs and resources towards the testing and acquisition of biometrics identifier technology .