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Administrative costs

69. The financial implications of a listing for an individual Party depend on the extent to which that Party is engaged in the trade of the listed species as an exporting, re-exporting or importing State. Any such costs will primarily relate to listings in Appendix II or III given that trade in Appendix-I species occurs only in limited circumstances although illegal trade may require the application of enforcement-related resources.

70. It is difficult to separate out the costs of implementing a CITES listing as these costs and tasks are usually absorbed by countries within the overall national resource management and enforcement programmes. However, the main costs directly associated with the implementation of a listing can generally be separated out as start-up costs and recurring costs.

71. Start-up costs for a new listing may include training and capacity building for government officials, education and awareness raising of the fisheries and aquaculture sectors of the requirements for trade under the listing and, where necessary, the production of tools to assist in the identification of specimens of the species in trade. For some Parties, particularly developing countries, the implementation of listings may require new infrastructure to be put in place. In regard to listings of commercially-exploited aquatic species, there is likely to be limited experience within government and industry of implementing such listings which may require more intensive efforts, and resultant higher costs, in the initial stages.

72. The recurring costs include:

(i) research upon which to base non-detriment findings;

(ii) processing of permit applications, compilation and submission of annual reports;

(iii) inspection of imports and exports and detection and prosecution of illegal trade.

73. This financial burden usually falls more on governments, especially the Management Authority, than on the private sector when a species is listed under CITES.

74. Some problems of administration and management of CITES-listed species could result from conflicting jurisdictions of environmental and fisheries agencies, as well as the lack of clarity about the lines of responsibility. Poor communication and coordination between these agencies can have negative implications for both areas of management (as discussed in paragraph 15).

75. The administrative and human capacity, in some countries and circumstances, may have to be improved to meet the additional obligations arising from listing a commercially-exploited aquatic species under CITES. This would be the case in those countries where fisheries management is not well developed or the infrastructure is deficient. Countries, regardless of economic status, have limited resources to devote to the enforcement and control of movement of fish and wildlife across borders, with other border control activities often being accorded higher priority.

76. The case studies provided some indications of administrative costs incurred in support of CITES listings. For example, the costs of undertaking surveillance of the queen conch fishing grounds around Jamaica in support of non-detriment findings are considerable. The Consultation noted that although the case studies of costs and benefits of implementing CITES listings provided some useful insights, further studies would need to be done in order to properly understand their implications. Research costs for non-detriment findings, issuing of permits and certificates, and inspection could be high and without bilateral/multilateral assistance, some governments may find it difficult to bear these costs. Delays due to the bureaucratic processes of issuing certificates and export permits can lead to reduction in economic value in some cases. However, documentation and other formalities required for trade under CITES should facilitate the movement of species or products with minimum delay.


77. The 1995 FAO Code of Conduct for Responsible Fisheries provides a comprehensive guideline for fisheries management in countries where it is being implemented. CITES requires non-detriment findings which use the best available fisheries information and research data (see paragraph 28). Due to the practical realities in many developing countries where there is insufficient management capacity, when species are listed under CITES, Parties may need assistance to put the necessary management measures in place. In accordance with the Code of Conduct these measures should be included in an appropriate management plan. Where fisheries management is deficient, a CITES listing by itself does not solve the management problems. However, it may, under certain circumstances, contribute to more responsible management of the resources, as in the case of the queen conch fisheries of Jamaica. Management measures for CITES-listed species may also, under some circumstances, have benefits for other fisheries resources as well, resulting in an overall improvement in management for non-CITES-listed species.

78. Regulation of fishing pressure, including exploitation for international trade, may not help in addressing population declines resulting from habitat degradation, such as pollution and siltation. These factors may play significant roles in depletion of fisheries resources such as sturgeon and seahorses.

Social and economic implications of listing a commercially-exploited aquatic species

79. Fisheries, including aquaculture, provide a vital source of food, employment, recreation, trade and economic well-being for people throughout the world. Listing of commercially-exploited aquatic species under CITES may have implications for employment, income and food security, particularly in many developing countries. A listing in Appendix I will have immediate impacts because it results in a ban on commercial trade, while stock recovery may deliver socio-economic benefits in the longer term. Appendix-II listings may have initial negative impacts, but may deliver medium to long term benefits.

80. In the international market, a CITES listing may improve the flow of legally obtained products and reduce the chances of entry of illegally obtained products, which may increase the chance of stock recovery. In some countries, caviar exports from the Caspian Sea have benefited the processors and exporters in terms of higher prices from this CITES-listed species, although consumers may have borne these price increases. There is also the potential for reduced export income as a result of a listing. This could be a matter of concern for countries who are dependent on fish exports for foreign exchange, many of which are developing countries. This could lead to a reduction in employment opportunities and income of fishers, fish farmers, and fishworkers who are dependent on these species for a livelihood.

81. Listing of species under CITES may lead to the creation of illegal markets for some species. Domestic policy and regulation of a fishery, in response to a listing of a species in CITES, could convert bona fide fishers into poachers as occurred, for example, in queen conch in Jamaica, with significant socio-economic implications, unless there is effective education and strict control of such illegal activities.

82. There is a range of national regulatory interventions that may be generated in response to a CITES listing. Some of these may result in restructuring of fisheries with attendant adjustment costs. Fishers may have to bear such costs to a greater extent than processors and exporters as, for example, they may have to acquire new fishing gear, move to new fishing grounds, and target new species. As a consequence, the associated communities may have difficulty in readjusting to this new situation. It was suggested by some delegates that this occurred in India with regard to seahorses. In Jamaica, a quota management system was required in order to manage queen conch fisheries under CITES. However, the quotas were allocated mainly to larger companies resulting in a drop in the total number of processing plants, and consequently a reduction in employment. Social implications of such quota allocations are being studied. In formulating regulations to comply with a CITES listing, national authorities and, where appropriate, Parties should make every effort to mitigate any undesirable social and economic effects.

83. The consequences of fishing pressure falling on non-CITES-listed species should be carefully considered. This may be acceptable in the case of underutilized fisheries resources, but would have negative consequences for fisheries under stress. In this context, providing training and alternative employment to fishers outside the fishing sector should be considered. Suitable incentives, including time-bound and targeted subsidies, may help fishers to move, when necessary, from currently exploited CITES-listed species to other sources of livelihood.

84. Different countries take different approaches to deal with the financial implications of a listing. Such financial implications may not need to be borne solely by the Government. The use of mechanisms, such as the “user pays” principle, including permit application fees, to recover all or part of the costs associated with implementing a CITES listing is one approach used by some countries, including some developing States. In such an approach, consideration should be given to the ability of the various users to pay. For example, in the case of queen conch in Jamaica, the private sector has been paying for stock assessments in the fishing grounds in support of non-detriment findings.

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