Stop wildlife imports until proper checks in place: CITES to India

At its last meeting in Geneva this February, the CITES Standing Committee took note of the information provided by a number of countries regarding “the trade in live animals with purpose code Z (zoo) to the facility of the Greens Zoological Rescue & Rehabilitation Center (GZRRC)” in Gujarat, and asked the CITES Secretariat to undertake a verification mission to “understand how Indian authorities ensure that live wildlife are acquired and imported legally”.

The inspection mission was in India between September 15 and 20 when it also visited Vantara’s GZRRC and Radha Krishna Temple Elephant Welfare Trust (RKTEWT) facilities in Jamnagar.

In its 14-page report, the mission noted that while no import to India took place without CITES export and import permits, “several imports still raise questions regarding the origin of the specimens”, the exemptions sought, “the use of source and purpose-of-transaction codes, and the exercise of due diligence by India”.

The report underlined that CITES allows purchase of wildlife if the trade is under certain conditions, but India’s Wildlife Protection Act states that “no zoo shall acquire, sell or transfer any wild or captive animal except from or to a recognised zoo”. This is why wildlife imports by India are almost exclusively under the source code C (captive bred) and purpose code Z (zoo).

Since a number of animals came from “established commercial breeding facilities, which would normally sell the animals,” the report said it would be “important to clarify that exporting facilities are indeed registered as zoos in their countries, to ensure that the operations of the GZRRC and RKTEWT do not inadvertently become a driver of illegal harvest of wild animals that are later declared as captive bred.”

Considering the quantity of specimens being imported by the GZRRC and RKTEWT, the report recommended that India “reviews as a matter of urgency its import procedures and implements such stronger due diligence” so that animals sourced from the wild are not imported as captive-bred.

The CITES Secretariat recommended that India verify all imports highlighted in its report, and other cases that raise similar concerns, with source or transit countries, including Congo, Germany, Guyana, Iraq, Mexico, Syria and the UAE, to check if the imported animals were indeed captive-bred and, if not, take appropriate measures.

These are the key findings of the report:

• As of September 11, GZRRC had 41,839 animals while RKTEWT had 5,794. The Secretariat noted that both facilities operate in accordance with exceptionally high standards and have advanced amenities, and that their representatives expressly stated that no animals have been bought.
• The CITES authority of the Czech Republic told the Secretariat that it “had no doubts that the animals imported from the county had been sold to the GZRRC and were not exported for the purpose of rescue”. Asked to clarify, the Environment Ministry cited the recent Supreme Court order that gave Vantara a clean chit regarding all imports, and claimed the invoices related to the Czech imports were related to CIF (cost, insurance and freight). The Secretariat noted that the invoices provided by the Czech Republic “seem to contradict” India’s claim, and sought a clarification. “The same should be done with any exporter /re-exporter country that has established invoices for the transfer of animals to the GZRRC and RKTEWT,” the report said.
• The report noted that three African Elephants exported from a facility in Tunisia to India are originally wild animals from Burkina Faso. Similarly, it found that 363 animals (mainly primates, crocodilians, and giant anteaters) were exported from Guyana to India, under source code W (wild) and purpose code Z (zoo).
• Regarding the 2024 import of 100 specimens of radiated tortoise (highest protection under CITES Appendix-I) and 40 iguanas (Appendix-II) by GZRRC from Togo with transit in Belgium, Germany informed the Secretariat that a German commercial breeder had exported the animals to a zoo facility in Lomé, Togo, with purpose code T (trade), a few weeks before they were re-exported under purpose code Z (zoo) from Togo to India.
• Flagging the response from Congo that the nine chimpanzees authorized for export to India “are all in captivity (Source C),” the report said “that the animals ‘are’ in captivity is not sufficient, in itself, to justify the use of source code C” and that “exercise of due diligence by India would have allowed to… obtain full traceability of the specimens prior to the export.”
• GZRRC imported two snow leopards (Appendix-I) under import permit with purpose code Z (zoo) but Germany confirmed to the Secretariat that it was “not convinced that the criteria for the use of purpose code Z were fulfilled and therefore issued the export permit with purpose code T” (trade).
• The report highlighted multiple instances when animals were imported via UAE as “captive bred” from source countries which are not known for such captive breeding programs: Chimpanzees from Egypt, Iraq and Kuwait, a bonobo from Iraq, a gorilla from Haiti, cheetahs from Syria etc.
• The report flagged the import of Appendix-I species species imported under source code I (confiscation) — 10 jaguars, 10 ocelots, 10 margays, and 10 jaguarundis from Mexico, as well as 4 chimpanzees, 1 orangutan and 8 cheetahs from the UAE — with unknown country-of-origin.
• Imports of large numbers of Appendix-I specimens from countries which are not range states and/or are not known for their captive breeding should have triggered additional due diligence from India, the report said. The same observation was made for importing species “which are known not to breed well in captivity.”
• In all such cases, the report said, India should exercise “due diligence when presented with a CITES permit or certificate, even if they believe it to have been issued by a competent authority, when they have a reason to believe that the CITES specimens may not have been traded in accordance with the provisions of the Convention.”
• In situations where animals are in peril and need rescuing, the provision of in-country support for such animals would allow for additional time to conduct due diligence verifications, the report said.

The CITES Secretariat recommended that the CITES Standing Committee, scheduled to meet in Uzbekistan’s Samarkand on November 23, ask India to take necessary actions and submit a report within 90 days.

Jay Mazoomdaar is an investigative reporter focused on offshore finance, equitable growth, natural resources management and biodiversity conservation. Over two decades, his work has been recognised by the International Press Institute, the Ramnath Goenka Foundation, the Commonwealth Press Union, the Prem Bhatia Memorial Trust, the Asian College of Journalism etc. Mazoomdaar’s major investigations include the extirpation of tigers in Sariska, global offshore probes such as Panama Papers, Robert Vadra’s land deals in Rajasthan, India’s dubious forest cover data, Vyapam deaths in Madhya Pradesh, mega projects flouting clearance conditions, Nitin Gadkari’s link to e-rickshaws, India shifting stand on ivory ban to fly in African cheetahs, the loss of indigenous cow breeds, the hydel rush in Arunachal Pradesh, land mafias inside Corbett, the JDY financial inclusion scheme, an iron ore heist in Odisha, highways expansion through the Kanha-Pench landscape etc. ... Read More

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