REPTILES, REGULATIONS AND RE-THINKS

The regulation of the trade in wild animals is a key consideration for all exotic pet keepers. Even the most popular pet species, which are captive bred in large numbers, have at some point been imported from the wild and subject to regulation. Many of these regulations are made by governing bodies that must navigate information from various lobbying groups to implement new measures. Most of this is overseen by the Convention on International Trade in Endangered Species of Flora and Fauna (CITES), sometimes referred to as the “Washington Convention”. This multilateral treaty was signed in 1973 and has afforded varying degrees of protection to over 38,000 species. It has been widely celebrated internationally, but some believe the convention is flawed.

REPTA, Regulation and WC/CB

Chris Newman and David Perry founded the Reptile and Exotic Pet Trade Association alongside other members in 2005 to help feed important data back to government. REPTA inform DEFRA (Department for Environment, Food and Rural Affairs) on issues that concern keepers and businesses. These include topics such as invasive species lists, AAL guidelines and the impact of Brexit on the exotic pet industry. By establishing the National Centre for Reptile Welfare in 2018, Chris is also hoping to gather even more data to better inform national and international regulations around reptile keeping. Chris explained: “Years ago, green iguanas (Iguana iguana) were a major problem because we were importing about 20,000 iguanas a year and they were pretty much sold throughout the pet trade as juveniles at 6 inches long. They’re not so manageable when they reach 6 feet long. There was clearly an issue in the 00s that the rehoming centres were filled with green iguanas. So, REPTA fed that back into the trade, not to say, ‘don’t sell green iguanas’ but to say, ‘let’s improve the information we provide at the point of sale’. That has now shifted greatly and there are far fewer green iguanas available in the UK.”

By gathering data on the trade of exotic animals, REPTA can feed information back to CITES. While ecological surveys and trafficking statistics amongst other information are used to inform whether a species requires additional protection, the data that REPTA collates can provide insight into the drive for the demand of these species and in many cases, the benefits of having regulated trade. The reptile-keeping industry will have impacted the wild populations of different species in different ways. In some cases, it has been detrimental and protection is fundamental to a species’ survival. In others, captivebreeding efforts have produced large populations of endangered species, driven international demand down and informed conservationists on how to establish in-situ breeding programmes.

Cites

CITES awards tiered protection to each species. At its most basic level, there are three “appendices” in which to categorise animals. Appendix I is designed to protect species which without strong protection, could be endangered by being overexploited by international trade in wild-taken specimens. Appendix II is for species which are vulnerable to overexploitation. Appendix III is a monitoring programme to help authorities gain a better understanding of whether a species could potentially be overexploited in the future. At its most basic level, CITES appears very simple. However, there are multiple other factors that can be added to the CITES listing to prevent certain aspects of trade. For example, a species can be listed in Appendix II, but also have a negative export quota. This will provide stronger protection than just an Appendix I listing that still permits export for scientific research etc.

On top of this, there are also EU Wildlife Trade Regulations which are often referred to as “EU CITES” for ease. As things stand, the UK has the EU Regulations since they formed part of Retained Legislation post-Brexit. Although, it is anticipated that UK-specific CITES legislation will be enacted in the next 1-2 years. “EU CITES” add annexes to the mix. In principle an Appendix I animal should fall under Annex A, an Appendix II under Annex B and an Appendix III under Annex C or D (Annex D being another ‘monitoring’ categorisation unique to the EU and UK). However, these can be uplifted in listing at the behest of the EU’s Scientific Review Group. The very popular Hermann’s (Testudo hermanni) tortoise is listed as CITES Appendix II. However, the EU has listed them as Annex A because they occur within the boundaries of the EU and it was felt that they needed a bit of extra protection. This means that whilst they can be bred and sold, they also need to be microchipped and have an article 10 certificate which follows the animal for its entire life. Many people will remember when these species were imported from the wild at very low cost. Now, they are sold for almost 100 times more than what they were in the 1980s. The CITES listing certainly has a role to play in this. In this respect, the model was successful and it achieved its goal of protecting wild animals, whilst also incentivising breeders to produce more captive-bred tortoises.

There are 183 signatories to CITES. For a species to get listed, up-listed or down-listed requires a two-thirds (66.6%) majority. As with any democratic political system, some lobbyists believe this has allowed voting blocks to establish. For example, East African countries may support one another, or European countries may support one another. In the case of the EU, 27 votes could have a large impact on the result. “CITES, in principle, is a very good piece of legislation that really aims to protect wildlife. However, in recent years, it has got itself in a bit of a pickle” explains Chris.

“A good example of this is Indian star tortoises (Geochelene elegans) were on Appendix II of CITES and at the last CoP, were uplifted to Appendix I. In the UK, we had one of the largest breeding programmes of star tortoises in the world and that listing destroyed that. Even though the programme was theoretically viable to keep breeding these tortoises, commercially it wasn’t. An Appendix I listing requires a new article 10 certificate to be supplied at each point of sale. Hermann’s tortoises are also Annex A, the same as star tortoises. However, for reasons that are unclear, the UK CITES management authority will not issue Specimen Specific Certificates (SSC’s) as they have for Hermann’s tortoises. Even though the animals are microchipped they will only issue Transaction Specific Certificates (TSC’s) so each time the animal is sold it requires a new certificate which is expensive and time consuming. Appendix I animals are microchipped and issued with a lifetime certificate as soon as they reach 10cm in length, star tortoises are not. They would need a new A10 once the breeder sells to a wholesaler, another when the animal reaches the shop and another when the animal reaches its first keeper. The keeper then cannot move the animal into another breeding project without, again, issuing another certificate. So, it put an immediate halt to the largest captive breeding project of Indian star tortoises in the world.” As many breeders also cannot prove the origin of their adult, breeding animals, it prevents them from obtaining the necessary paperwork. This, in turn, stops all offspring from receiving correct paperwork and thus halts any small-scale breeding projects of the species also.

There are many potential avenues for legislation to change in the future. Many lobbyists believe that The Rio Convention on Biodiversity may play a central role in the exotic pet industry further down the line. This convention looks at natural resources being the property of the country of origin. Essentially, it is legal to buy a natural resource, but not to reproduce it unless the country of origin has authorised a particular institution to do so. This is currently being used in the pharmaceutical industry and is already a widely celebrated method. Whether it can be applied to live animals is an entirely different debate.

Sustainable farming is another route that protects wild populations of animals. For example, Tesoros be Colombia produces large quantities of endangered poison frogs to be shipped across the world. They are based in Eastern Colombia, in the native range of Oophaga lehmanni and Oophaga histrionica and have been granted government permission to source these protected species for in-situ breeding. Not only does this ensure that the offspring are from genetically viable parents, but a much smaller fraction of wild-caught animals needs to be harvested. Without the risks associated with harvesting and shipping delicate frogs, the institution’s breeding success rates are exceptionally high.

CoP19

Every third year, CITES holds a ‘Conference of the Parties’ where proposals are put forward by different countries to award extra protection to certain species. Documents outlining their reasoning are made public via the CITES website, but officials will debate the subject at the conference and thus make any amendments or new additions during this time. The 19th Conference of Parties (CoP19) will be held in Panama from the 14th-25th November. Proposals for new amendments have recently been published and there are some commonly-kept species which might see a change in their availability.

Chinese water dragons (Physignathus cocincinus) are proposed by the European Union and Vietnam, to be added to Appendix II. Although the import of Appendix II species is permitted, restrictive quotas in the source countries could be introduced which could greatly affect the availability of the species. Water Dragons have been a commonly traded species for many years. Historically, they have been inexpensive, which has been more of a driving force for their popularity than their suitability as a pet. If the species is listed under Appendix II, this will change. The cost will almost certainly increase, and the supply may well decrease or stop altogether, meaning that purchasers are more likely to be individuals who understand the needs of this species. Hopefully, this will generate a greater emphasis on captive breeding in the UK and breeders will be able to set prices that more accurately reflect the work required to produce the young.

David Perry of REPTA added: “Restricting international trade is unlikely to result in a significant improvement in the population status of Chinese water dragons in the wild, with local pressures such as hunting for food and habitat destruction having a greater impact on population decline. However, there probably is a justification to be made for restricting international trade to help provide the species with the status it deserves.”

Both the USA and Mexico have put forward proposals to list horned lizards (Phrynosoma spp.) at species and genus levels. This would restrict trade in some capacity and would probably be accompanied by quite small quotas or additional EU/UK measures. Although they are not commonly kept in the UK, they have appeared periodically in recent years. Improvements in husbandry have seen some success in captive breeding of these species but a reduced availability might impact these advances.

Proposals to add two turtle genera, Kinosternon and Sternotherus spp. to Appendix II have also been put forward. Since the removal of species such as red-eared sliders due to the Invasive Alien Species regulations turtle keepers in the UK have been encouraged to keep smaller, more manageable species. This is most commonly the common musk turtle (S. odoratus). David continued: “While there are some Stenotherus species that are vulnerable to both collecting and habitat loss or destruction, the use of a block listing means that common and widespread species will be included by default. Indeed, the proposal itself emphasises the status of S. odoratus, and the fact that it is also captive-farmed. The listing of these species on Appendix II has the potential to remove the majority of turtle species from the UK market, resulting in either a switch to more unsuitable species or encouraging illegal trade.”

Several other proposals have been put forward that might affect exotics keeping to some degree. These include glass frogs and snapping turtles which are sometimes kept by hobbyists, but rarely in UK collections.

REPTA (The Reptile and Exotic Pet Trade Association) regularly attend meetings with the EU CITES team to put evidence-based ideas forward from an exotics keeping perspective.

Self-regulation within the industry

Peregrine Livefoods, the largest reptile wholesaler in the UK, recently published their new stance on wildcaught animals as well as a ‘species selection process’ designed to limit which animals they sell. Being an industry giant for over two decades, the company is responsible for producing a large percentage of the most popular pet species available in the UK. As well as this, they historically imported an eclectic mix of wild-caught animals to diversify the species that are kept in the UK. Last year, the business decided to stop large-scale imports and instead turn its attention towards ensuring the highest welfare standards for the most appropriate pet species.

Chris Jones, Managing Director of Peregrine Livefoods said: “Following a successful transition away from largescale WC shipments, we needed to solidify our stance on ‘wild-caught’. We do not believe that sourcing animals from the wild is inherently bad and recognise the many benefits to the hobby, conservation and local populations of people that wild-caught animals can provide. We do, however, believe that as a wholesaler, we must be responsible for the types of animals we sell, assessing all the pros and cons to reach a balanced decision. We believe it would be irresponsible to continue to import some species of animals when there may be other more suitable alternatives, of a CB supply.”

The business will now be assessing all wild-caught animals on the following criteria:

• Population: Is this species considered threatened according to the IUCN?

• Sustainability: Has the collection and trade of this species shown to be sustainable or beneficial to the local population of animals and humans?

• Invasive: Is this species considered ‘non-native’ from the country of export?

• Stress and hardiness: Does this species show high tolerance for shipping and being placed into captive care?

• CB availability: Is this species already available as captive-bred in reasonable quantities?

• Reproduction: Do historic records demonstrate this species is likely to be reproduced in captivity?

• Breeding programme: Is this species being imported specifically for re-sale to experienced breeders on the basis that new bloodlines will assist in the growth of captivebred animals?

The points-based system will create an assessment process that only permits the most suitable animals to be imported. With most imports relying on a specific quota to be filled, Peregrine Livefoods believes that their large-scale imports will be completely unviable going forward. This is welcomed by the business, who have not had a ‘wildcaught’ shipment since the criteria was put in place. The business is targeting future animal sales to be comprised of just 7% wild-caught specimens in 2023. This is less than half the percentage they imported in 2021.Whilst this self-regulation is designed to protect the longevity of the hobby, some people believe that by narrowing the species available to hobbyists, there may be repercussions in the future. “If we stop the wild-caught trade that could be detrimental to conservation” explained Chris Newman. “We should have had a fairtrade policy a long time ago, whereby more money goes back into the pockets of people harvesting animals. Madagascar is a good example. Something like 80% of the island is under threat of deforestation. Without an incentive to protect the remaining 20% why would local people choose to save that area? If there is no money coming in, they may as well chop it down or eat it.”

Unfortunately, mortality rates for some imported species are exceptionally high. Although nowadays things are beginning to change, importing large numbers of fragile species can lead to disaster scenarios. This used to be reasonably common in the 1990s. “ A good example are red-headed agamas (Agama agama)” added Chris Newman . “We didn’t know how to keep them alive in those days and 99% probably did die in the first year. Now we do know how to keep them alive, there is a serious argument for bringing them in. Specialist keepers lead the discussions on best husbandry practices for the entire hobby. If we stop specialists from doing that, we could be in a rather dire situation. This is where we need to distinguish between a specialist animal and a pet.”

Peregrine Livefoods has decided to invest the additional time and resources that would previously be spent on catering for imported animals, in improving welfare standards and captive breeding projects at their facility.

“We must be honest with our place in the industry” added Chris Jones, Managing Director of Peregrine Livefoods “Most of our customers are pet shops which will be primarily supplying pet keepers. They have the choice to bring in more unusual species from elsewhere, but we feel that it is not our place to supply them. Each year there is a shortage of the most popular pet species. These animals are often best suited to captivity. We feel there is sincere merit in producing animals which can thrive with the majority of our customers and will continue to work with our vast network of breeders to supply interesting and unique animals of captive-bred supply. Our species list is just as eclectic as ever, without the need to impact wild populations at all.”

Individual responsibility

Responsible pet keeping is best achieved by remaining honest about the reasons that someone chooses to keep an animal. Most pet owners keep animals purely for the joy of it. In most cases, domestic pet keepers prioritise captive-bred animals that are well-suited to a captive environment and exotics keeping should be no different. Equally, expert breeders who could have a significant impact in developing scientific understanding of a particular species, may be more equipped to choose a wild-caught specimen. In this case, extra measures to ensure the sustainability of the source, or the reputability of the supplier might also prove beneficial. Ultimately, questioning the long-term goals of keeping an animal can ensure self-regulation at the very foundations of the hobby.