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CITES, Wildlife, and Pandemics: Failure to Grasp the Nettle

By John Scanlon, Dan Ashe, Sharon L. Deem

Mar 21 2023 · 5 min read

Illuminem Voices
Biodiversity · Nature · Social Responsibility

The links between human interactions with wild animals and the emergence and spread of zoonotic diseases, including through regulated, unregulated, and illegal trade and markets, is well known.

Many articles exist, and the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) released a relevant report in 2020, all discussing the risks posed by international trade on the spillover of high-risk zoonoses. Of critical importance are those emerging zoonoses that can cause a pandemic or an epidemic for which a cure does not exist; including the World Health Organization (WHO) Blueprint diseases, such as COVID-19.

The COVID-19 pandemic shone a spotlight on serious gaps in the wildlife trade regime, yet efforts to fill these gaps are lacking a sense of urgency and the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) largely wrote itself out of the script.


At the height of the COVID-19 pandemic when the world’s attention was focused on its origins and response, the CITES Secretariat issued a statement that “matters regarding zoonotic diseases are outside of CITES’ mandate.” Surprisingly, the statement made no reference to the Memorandum of Understanding (MoU) signed in 2015 between CITES and the World Organisation on Animal Health (OIE/WOAH).

Given its existing mandate, CITES’ role in preventing zoonoses may be relatively limited, but the Secretariat’s absolute statement displayed a disinterest that likely locked them out of crucial discussions on the topic. CITES was not included in the Quadripartite MoU between the Food and Agriculture Organization of the UN (FAO), WOAH, the UN Environment Programme (UNEP), and WHO on advancing a One Health approach – an approach necessary for pandemic prevention and response – and is not a central player in ongoing discussions.

The non-government sector was quick to act with new initiatives, including the Association of Zoos and Aquariums’ Reduce the Risk and End Pandemics initiatives, the Global Initiative to End Wildlife Crime (EWC), Preventing Pandemics at the Source, and the informal Pandemic and Animal Welfare Coalition – all advocating for prevention and presenting practical options on how to do so.

CITES and risk to public health and animal health

CITES regulates international wildlife trade to ensure it is not detrimental to the survival of the species, without requiring consideration of the public health or animal health implications.

CITES does not regulate the way wildlife is harvested, handled, or stored in the source state, or how it is handled, stored, sold, or consumed in the destination state. Captive breeding now accounts for close to 65% of trade in animals. Captive breeding operations are not assessed by CITES on public health grounds. Yet all these activities can pose a risk factor for zoonotic disease emergence.

Some refer to the Convention’s reference to “any living specimen will be so prepared and shipped as to minimize the risk of injury, damage to health or cruel treatment” as a mandate. Read in context, it likely means to the health of the animal(s) in trade. However, parties could seek to give it a wider interpretation to help address some aspects of wildlife trade that present pandemic potential. However, the text is limited to ‘living’ specimens, not dead animals, their parts or derivatives, and it does not address the capture, holding prior to transport, marketing of the animal, or the criteria for listing a species.

CITES and One Health

Two documents were submitted to CITES CoP19, including a proposed Resolution on ‘One Health and CITES,’ which demonstrated that parties to CITES had an interest in the topic. The plenary ultimately adopted a consolidated set of decisions.

Any progress made toward adopting a One Health approach to wildlife trade and markets is welcome. However, given CITES’ current mandate, such decisions are of limited effect. Parties to the Convention on Biological Diversity (CBD) showed slightly more ambition at COP 15, through the adoption of the Global Biodiversity Framework and related decisions, which is also welcome. 

While valuable, non-binding decisions by CITES and CBD are inadequate to address the scale of risks presented by wildlife trade and markets, and the current response leaves us unnecessarily exposed to future zoonotic diseases.

Amending CITES to cover risk to public health and animal health

Our initial preference, and that of the EWC, was to amend CITES, given its well-established governance and permitting processes, and the impact it has on national legislation. It is, however, a big step for CITES to broaden its focus after nearly 50 years, and, it did not find favor with parties, as well as some observers, including over a concern that opening CITES for these amendments could open it to others.

Another viable way forward

It is essential to coordinate the regulation of wildlife trade, markets, and consumption together with human health and animal health, to help avert the next wildlife-related pandemic.

Other options may even offer greater scope as they start afresh, especially the Pandemics instrument being negotiated in the WHO. The EWC has made submissions and presentations on the need to include prevention in the scope of the instrument, along with preparedness and response. The zero draft of the Pandemics instrument specifically references “wildlife trade” but not markets, in Article 18. Animal welfare is thus far absent.

The final outcome of these negotiations remains to be seen, but the current zero draft, while still insufficient, offers some hope. However, by taking the current WHO route, the wildlife conservation community is not in the driver’s seat and is largely ceding global leadership on how to address the risk to human health posed by wildlife trade and markets to public health organizations.

Looking ahead to the next 50 years

In failing to immediately ‘grasp the nettle,’ CITES removed itself from a central role in negotiations to scale up the global effort to prevent future wildlife-related pandemics.

Nevertheless, the world will increasingly take a One Health approach to wildlife trade and markets at both international and national levels. The risk they pose will be addressed, in some way, within a new Pandemics instrument.

Memories of the COVID-19 pandemic will fade with time, and decisions taken during that period may be slowly wound back. Incremental changes will be made over time, but not as rapidly as is necessary, through a combination of a new Pandemics instrument, implementing resolutions under CBD and CITES, and scaling up efforts to update national legislation and policy.

A failure to rapidly institutionalize how we regulate the risk posed by wildlife trade and markets at the global level and across all countries means we will remain unnecessarily exposed to the risk of future emerging zoonotic diseases, such as those identified by the WHO.

This article is also published by IISD - SDG Knowledge Hub. illuminem Voices is a democratic space presenting the thoughts and opinions of leading Sustainability & Energy writers, their opinions do not necessarily represent those of illuminem.

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About the authors

John Scanlon AO is a seasoned leader in the fields of environment, governance and sustainable development, with a unique range of experience gained across multiple continents, disciplines and organisations. He has served in senior positions in the private sector, with government, international organisations, the United Nations, and not-for-profit organizations, and as chair or member of many boards and initiatives. This includes working with IUCN (Bonn), UNEP (Nairobi) and CITES (Geneva)

Dan Ashe is President and CEO at the Association of Zoos and Aquariums, former Director of the US Fish and Wildlife Service, and US Head of Delegation to CITES CoPs 16 and 17.

Dr. Sharon L. Deem is the Director of the Saint Louis Zoo Institute for Conservation Medicine, President Elect of the American Association of Zoo Veterinarians, and former chair of the Association of Zoos and Aquariums Animal Health Committee.

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