On the road to regulating international trade in sharks and rays

A new paper outlines a Theory of Change that charts the course we need to take to move from the current unsustainable shark and ray trade to a bright future for sharks and people. It’s a long, uneven road, but the authors show that there have been numerous local conservation successes in response to CITES listings along the way.

It’s hard to find a positive news headline these days. It’s even harder to envisage what conservation success and a bright, sustainable future for sharks and rays might look like. But a sharp vision of that future is precisely what we need if we’re to build the stepping stones to success. It’s those incremental wins paving the way for sustainable shark fisheries and populations that are highlighted in a new paper by Dr Mark Bond and his co-authors.

‘There has been criticism of CITES, and its naysayers have questioned whether listing species makes a tangible difference to conserving them,’ explains Mark.

Moving from listing a species on CITES Appendix I, II or III (in response to trade-related risk of extinction) to documenting the recovery of its population doesn’t happen overnight; there are numerous steps that need to be taken to effect the long-term vision of change. But it’s this step-by-step process that Mark has assessed, using a Theory of Change framework to outline the road from CITES’ intervention to the achievement of its intended goal and gathering evidence to either support or refute each stage.

‘We haven’t got evidence to assess every stage along the Theory of Change yet, but we’re halfway through and we are seeing massive progress at a scale and speed that we’ve not seen under other fisheries management regulations,’ he says. Unlike much of what we contend with in reporting, Mark’s approach is one that confronts us with a hopeful vision of the future and challenges us to evaluate how well we’re doing in getting there. And, contrary to what the naysayers might want us to think, his findings corroborate the sense of motivation and commitment that we see in local case studies and in actions on the ground.

‘I hope that this paper can highlight that while we do have a lot of work left to do – and some distance still to travel along that Theory of Change – governments should stay motivated and keep trying to make this difference for sustainable shark fisheries and recovering populations.’

What is CITES and why do we need it for sharks?

CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) is a global agreement to ensure that international trade in wild plants and animals does not threaten their survival. Species can be listed on one of three Appendices that outline various levels of trade regulation. Sharks and rays are a relatively newer addition to the listing process. The first CITES resolution was adopted in 1963 and it came into effect on 1 July 1975 after 10 countries had formally ratified the Convention. So, while CITES itself turns 50 this year (it was the curious-looking vicuña from the Chilean, Bolivian, Peruvian and Argentinian high Andean and Puna ecosystems that first made it onto an Appendix), sharks and rays only began to be listed in 2003.

Between then and 2019, 44 sharks and rays were listed on CITES Appendices I and II. This is because more than one-third of sharks, rays and chimaeras are at risk of extinction. Overfishing is the main cause of these declines, partly driven by international trade demand for shark and ray products from targeted and incidental catches. Due to their prevalence in international trade, 39 commercially valuable species have been listed on Appendix II.

The paper ‘Trade regulations drive improved global shark and ray management’, which was published today in the journal Marine Policy, assesses the impact that these CITES listings have had on global shark and ray conservation. For CITES to work, countries that are Party to the Convention need to comply with a host of regulations and requirements outlined for each specific Appendix. Parties are legally bound to implement the Convention through domestic legislation (and in doing so, ensure that trade in listed species is legal, sustainable and traceable), and the means to do so can range from quotas to complete bans on harvest and trade.

CITES listings don’t typically impact domestic use, but if Parties continue trading CITES-listed species internationally, they must demonstrate non-detriment finding (NDF) assessments (a science-based foundation for trade quotas and legal demonstration of compliance). To achieve CITES’ overarching goals, fisheries management measures may need to come into play for sharks and rays, because overfishing is the primary cause of their declines.

Infographic by Kelsey Dickson | © Save Our Seas Foundation

What does the road to CITES success look like?

The Theory of Change comprises seven steps, four of which could realistically be evaluated with evidence gathered since sharks were first listed in 2003. And, excitingly, 54% of Parties showed the political will to comply: 99 CITES Parties participated in at least one national or regional workshop, and 79 in multiple workshops. This demonstrates that countries allocated time, effort and potential expenses to ensure the listings are properly implemented.

‘In many places, the data that are collected are not species-specific,’ explains Mark. ‘So they are aggregating sharks and rays, or recording catches as “not indicated elsewhere”. Improving data collection and reporting is one of the biggest changes in daily operating procedures that has to take place, and there are two hurdles that countries need to overcome to do so. Firstly, fisheries data collectors and landing site inspectors need to be trained in how to correctly identify sharks and rays to the species level; and secondly, they need to take the time to gather species-level data.’

Just how challenging this step is becomes evident in the result that 22% of Parties showed improvement here. Nine Parties (Bangladesh, Costa Rica, Colombia, Peru, Mexico, Kenya, Gabon, Indonesia and Mozambique) have prioritised data collection on shark catch and landings and/or trade since 2014.

‘I was quite surprised by how many countries had changed their national legislation in such a short time,’ says Mark. Forty-eight per cent of CITES Parties showed that they had improved regulations, and shark and ray policy changes were documented for 88 Parties. ‘Typically, legislation takes a while to change’, he continues, ‘but this has been relatively rapid at this scale.’

Twenty-seven per cent of Parties had evidence of improved compliance monitoring and enforcement. There was evidence of 194 seizures of shark and ray products made by relevant agencies of 49 CITES Parties between 1 January 2002 and 31 December 2022. Fins comprised 47% of confiscated contraband. Mark adds, ‘I was also surprised by how many countries have intercepted non-compliance shipments.’

What does a CITES-compliant world look like?

It’s not often that we really evaluate conservation success and make a noise about it; it’s even less frequent that we laud countries for taking actions that (at face value) seem small but require significant local change to achieve. As part of their approach, Mark and his co-authors also assessed several case studies and found what they dubbed CITES implementation ‘Bright Spots’ in various Parties in the global tropics: the countries that, despite perceived implementation challenges, were accelerating local conservation actions that will, ultimately, lead to global shark conservation success.

Prior to the CITES listings, these countries had little to no shark management in place. Nevertheless, Bangladesh had introduced threatened species protection measures and an NDF to provide evidence that harvest is sustainable. India introduced a total prohibition on the export of shark fins. Gabon implemented species protections and an all-export trade prohibition, while Colombia introduced protection measures for all species through fisheries management regulations and export prohibitions. Peru continued to trade via NDFs, and the Hong Kong Special Administrative Region (SAR) demonstrated effective compliance monitoring and enforcement. Interestingly, Indonesia (the world’s leading shark-fishing nation) continued trade via NDFs, introduced some species protections, regulated trade and moved towards sustainable fishing – the first example of on-water behaviour change.

The results, for evidence of political will in particular, but also for the changes made by these implementation ‘Bright Spots’, are really positive given the short timeframes. What is it, then, that the shark and ray sector has done differently to see these strides being made relatively quickly?

‘Other regulations, and the Regional Fisheries Management Organisations (RFMO) approach, had no compliance mechanism and so there was no “negative impact” for countries not abiding by the rules,’ suggests Mark. ‘However, it seems that countries are very concerned about getting trade restrictions imposed on other CITES-listed species that are economically important to them (or they just don’t want to look bad on the international stage). I feel that the national-level conversation has been accelerated so that they comply with CITES regulations.’

The path to the future

Each step moves countries closer to the end goal: achieving the sustainable trade of CITES-listed species, supplied by sustainable fisheries, and our oceans filled once more with stable and/or recovering shark and ray populations.

There are more steps along the Theory of Change to gather evidence for, and more recent CITES listings to include in any future assessments. In 2019, 90% of the international shark-fin trade was brought under regulation through the additional listing of a host of species.

‘I would hope that this will lead to widespread seizures and confiscations,’ says Mark. ‘Today, countries trading any species that is part of the fin trade require a CITES permit to do so, but we’re seeing that there are massive unreported and illegally sourced trades. So once these more recently listed species are included in our assessments, I would assume that we would see more regulations implemented – and, predominantly, more enforcement applied – because the entire fin trade is now regulated by CITES.’

We have the roadmap and we have the evidence to suggest that not only are we on the right path, but also that path could work more quickly and more effectively for sharks and rays than anticipated. In order to move swiftly and successfully towards CITES’ end goals, species identification tools at ports must be scaled up; customs officers must be given access to increased training opportunities; data collection and reporting on trade volumes and sources must be improved; and cross-border collaboration among fisheries and wildlife agencies must be fostered.

References:

Trade regulations drive improved global shark and ray management. Marine Policy
Mark E. Bond, Hollie Booth, Akshay Tanna, Sarah L. Fowler, Carlos J. Polo-Silva, K.H. Stanley Shea, Floriane Cardiec, Elisabeth F. Mansur, Rima W. Jabado. doi.org/10.1016/j.marpol.2025.106733

Read the full paper at: https://www.sciencedirect.com/science/article/pii/S0308597X25001484