CITES CoP20 begins today in Samarkand, Uzbekistan (24 November – 5 December 2025).
CITES — the Convention on International Trade in Endangered Species of Wild Fauna and Flora (https://cites.org) — is turning 50 this year. CoP20 simply means the 20th meeting of the Conference of the Parties, the gathering where 183 signatory countries debate, adjust and vote on wildlife-trade rules.
What drew my attention this year is the fact that, after half a century of CITES, proposals and discussions about reopening trade in ivory and rhino horn are once again on the agenda.
I genuinely don’t understand how, in 2025, this is even being discussed. And I still struggle to understand the basic premise behind CITES — namely, that regulating trade in endangered species is somehow supposed to help protect them. To me, elephants, rhinos and all other wild beings have the same right to live safely on this planet as we do. Treating them as commodities feels deeply wrong.
Yet at the same time, I know we live in a human world shaped by politics, economics and power — so I want to understand what CITES actually is, what it was originally set up to do, and whether its design can genuinely protect endangered species in today’s world. I don’t know yet whether the system works, can work, or was built on assumptions that no longer hold. My hope is that by the end of this series, I’ll understand the convention more clearly and be able to make sense of its role.
For context: many people assume CITES is an animal-protection organisation. It isn’t. It was founded in the 1970s as a trade-regulation system, not a conservation agency. At that time, international wildlife trade was rampant and unregulated, and commercial exploitation was pushing many species towards extinction. The idea behind CITES was to restrict and control this trade, not to end it, in order to prevent further collapse.
I’ve been following Lynn Johnson’s work for many years, starting with her groundbreaking initiative Breaking The Brand, which developed targeted demand-reduction campaigns for rhino horn consumers in Vietnam. That project showed how demand for wildlife products is deliberately shaped and marketed. In 2017, Lynn and her partner Peter expanded this work into Nature Needs More, which builds on BTB but looks at the entire wildlife-trade system — from legal and illegal trade to supply chains, global luxury markets, behaviour change strategies, and the structural weaknesses inside CITES itself. Her analysis often challenges long-held assumptions in the conservation sector, and her work has made me realise how much of this system I never fully understood.
This blog post will become a living, evolving piece.
And in a way, the process itself is a learning journey for me too. As I work through the seven CITES@50 Reality Checks, I’ll add each new section below. This isn’t just a writing project; it’s me trying to understand an incredibly complex system one step at a time — a system that affects the lives of tens of thousands of species.
CITES shapes global wildlife policy in ways most people never see. Understanding its strengths — and its failings — is essential if we want a future in which endangered species are treated as more than commodities, and where “protection” truly means protection.
Photo credit: CITES / https://cites.org
Table of Contents — CITES@50 Reality Checks
- Reality Check 1: CITES is Broke
- Reality Check 2: Sustainable Use Model Remains Unproven
- Reality Check 3: CITES System Stuck in the 1970s
- Reality Check 4: CITES Trade Measures Never Enforced
- Reality Check 5: CITES Must Modernise or Go
- Reality Check 6: CITES Must Not Be Captured by SULi
- Reality Check 7: The CITES Failed 2030 Strategic Vision
CITES@50 Reality Check 1: “CITES is broke”
This first Reality Check from Lynn Johnson looks at the financial structure of CITES. Since funding underpins any organisation’s ability to function, it’s striking that Lynn begins her series here — suggesting that the question of money may be more central to CITES’ challenges than many people realise.
For 2025, CITES requires USD 6.6 million to function.
Only about half of that — USD 3.3 million — has actually been paid by member countries.
And this is not the only issue: there is still USD 1.4 million in unpaid contributions from previous years, money that CITES was supposed to receive but never did.
In other words, the convention responsible for overseeing a global legal trade worth hundreds of billions doesn’t even have access to the full budget it needs to perform its basic functions.
The EU’s legal wildlife imports alone are worth around EUR 100 billion per year.
After seafood, the luxury markets — fashion, furniture, décor — are the largest consumers of wildlife “raw materials”.
The biggest financial beneficiaries are high-income regions: Europe first, then North America, China/Hong Kong, and Japan.
Yet the system that supposedly ensures this trade is legal, traceable, and sustainable is chronically underfunded, dependent on member country contributions that rarely arrive in full.
Lynn summarises the core absurdity clearly:
“A regulator is only as effective as the funds it has to implement its mandate.”
I was surprised to learn that in other sectors, this imbalance would be unthinkable.
Pharmaceutical companies, for example, must finance the regulators overseeing them.
But in wildlife trade, luxury industries that rely on wild species for profit don’t contribute to the regulatory system that enables this trade to continue.
Lynn emphasises that CITES’ own reports acknowledge ongoing financial constraints that limit the Convention’s ability to deliver its mandate.
This raises a basic structural question:
How can CITES be expected to ensure sustainable or controlled trade when it can’t even finance the monitoring required to carry out its most basic functions?
My personal view
If powerful industries profit from using wild species as commodities, then they should also contribute to the cost of regulating that trade. Leaving regulation entirely to member countries — many of whom struggle to meet even their basic contributions — feels outdated and fundamentally unfair.
As the saying goes, “money makes the world go around”, and I can’t help but wonder how much this chronic funding crisis shapes what CITES can and cannot do. I’m working through the Reality Checks one by one, and I’m curious to see whether this structural weakness helps explain why the convention’s effectiveness is being questioned by so many.
➡️ Read the full article here:
https://natureneedsmore.org/cites50-reality-check-1-cites-is-broke/
CITES@50 Reality Check 2: The “sustainable use” model has never been proven
The basic premise
This Reality Check examines the idea at the core of CITES: “sustainable use”. After 50 years, there is still no evidence that the wildlife trade regulated by CITES is actually sustainable — and none of the parties involved seem interested in finding out. Not governments. Not industries. Not even conservation NGOs or academics.
Why no one tests whether the trade is sustainable
- Businesses avoid genuine validation because it could restrict access to the wild species they use as “raw materials”.
- Governments avoid it because true sustainability checks would challenge the “growth at all costs” mindset.
- Many conservation NGOs and academics publicly support the “sustainable use” model without ever demanding evidence for it.
Scientific reviews back up this lack of scrutiny. A 2024 global study scanned more than 30,000 papers and found only five that could even be used to analyse sustainable use. Another major meta-analysis in 2021 found no quantified example of genuinely sustainable trade.
Despite this, the term continues to be repeated as if it were established fact.
The NDF problem: assumptions instead of evidence
CITES relies on something called Non-Detriment Findings (NDFs) to claim that exports won’t harm a species. These sound reassuring — but in practice, they have no binding standards, often lack basic population data, are rarely published, and in some countries are even prepared by industry itself.
With almost no central review, the system rests on assumptions rather than evidence.
Lynn Johnson describes the consequence with sharp clarity:
“Sustainability without the corresponding transparency is just an ideology.”
My personal view
If “sustainable use” is the foundation for legal wildlife trade, then trade should only occur once transparent, independently verified data exists. Without baseline population data and standardised assessments, sustainability can’t be measured — and allowing trade without that information simply isn’t credible.
I’m curious to see how this structural flaw links to the issues raised in the other Reality Checks. If the very model at the core of CITES has never been validated, what does that mean for its ability to protect species in the real world?
Read the full article here:
https://natureneedsmore.org/cites50-reality-check-2-sustainable-use-model-remains-unproven/
CITES@50 Reality Check 3: The CITES System Is Still Stuck in the 1970s
When I read Lynn Johnson’s third CITES@50 Reality Check, I was genuinely surprised. In 2025, in a world that is digital down to the smallest detail of daily life, I didn’t expect to discover that CITES — the global system regulating wildlife trade — is still operating with a 1970s paper-permit system.
I had assumed (wrongly, as it turns out) that international wildlife trade was tracked using the same tools used in other global industries: real-time databases, digital exchanges, traceability systems, and modern supply-chain software. Instead, the reality Lynn lays out feels like opening a time capsule from half a century ago.
And this isn’t a cosmetic detail. A 1970s system cannot regulate a 2025 trade.
The Amazon comparison: complexity is not the issue
One of Lynn’s most powerful illustrations is her comparison to Amazon.
Amazon manages hundreds of millions of products across 175 fulfilment centres worldwide, tracking stock levels, movement and delivery times down to the minute. If Amazon operated its supply chain the way CITES manages wildlife trade, it would collapse within days. Lynn’s point is simple: Amazon’s supply chain is vastly more complex than CITES’ responsibilities, yet Amazon has full transparency and real-time tracking.
CITES oversees 41,000 listed species and 183 border crossings — a fraction of Amazon’s complexity. The problem is not scale. It is the refusal, or inability, to modernise.
What CITES still cannot see
Lynn lays out the consequences of a paper-based system that has barely changed in five decades. CITES still cannot reliably determine:
• where specimens truly come from (including whether they were wild-caught or genuinely captive-bred)
• how many individuals are taken from the wild, because baseline population data and real-time offtake numbers are missing
• where illegal items enter the legal supply chain, because nothing is tracked from source to destination
These are not minor gaps. They go to the heart of whether the trade is legal, sustainable or even traceable at all.
As Lynn writes, this is “what happens when businesses would rather keep you in the dark about the scale of their exploitation of wild species.”
Why this lack of transparency matters
The current lack of transparency is not accidental. It directly benefits industries and investors who profit from the trade in endangered and exotic species.
When origin claims cannot be verified, and supply chains are not monitored in real time, loopholes stay open. Illegal trade can be laundered into the legal system. Wild-caught animals can be passed off as captive-bred. Trade volumes cannot be independently checked against population data.
The system doesn’t just fail — it fails in ways that reward the most powerful actors.
Resistance to traceability: a red flag
One of the most troubling details in Lynn’s analysis is that a corporate conservation organisation stated that adding traceability “confuses the core mandates of CITES.”
Traceability is not a nice-to-have. It is the minimum requirement for any functioning regulatory system.
Lynn’s reaction says it all: such statements make you wonder “what they are trying to hide?”
If transparency threatens the system, then the system has something worth hiding.
Why isn’t CITES pushing back?
This is the part I personally struggle with.
The technology exists.
The loopholes are obvious.
The vulnerabilities are well-documented — from illegal laundering to false “captive-bred” claims to a complete lack of visibility on how many animals are being taken from the wild.
So why does CITES allow itself to be pushed around by industry interests? Why is there no mandatory digital permit system, no real-time monitoring, no centralised tracking infrastructure?
Lynn makes it clear that this isn’t about technical limitations. It’s about political will — and resistance from those who benefit from keeping the system outdated.
My personal view
If CITES cannot track origin, offtake or movement along the supply chain, then it cannot credibly claim to regulate the wildlife trade. After 50 years, the continued reliance on paper forms is not just outdated — it is dangerous. The refusal, or inability, to adopt modern transparency tools raises serious questions about whose interests are being protected, and at what cost to the species the convention is meant to safeguard.
Read the full article here: https://natureneedsmore.org/cites50-reality-check-3-cites-system-stuck-in-1970s/
CITES@50 Reality Check 4: CITES Trade Measures NEVER Enforced
CITES@50 Reality Check 4: CITES Trade Measures Never Enforced
When I read Lynn Johnson’s fourth CITES@50 Reality Check, something that had been building across the earlier pieces finally became clear. CITES cannot function as a regulator because its trade rules have never been enforced. Without enforcement, the entire framework remains a paper system that looks like regulation but cannot deliver it.
The missing foundation: no mandatory enforcement
Former CITES Secretary General John Scanlon describes the convention as ensuring trade is “legal and not detrimental,” but Lynn exposes the structural contradiction: for CITES to regulate trade, its trade-related measures must be verified at every stage. Yet CITES never required signatory countries to create Enforcement Authorities. Verification was left optional, and most countries do not perform it. Lynn’s conclusion is blunt: “Narrow shouldn’t mean useless, but the lack of a mandated Enforcement Authority made CITES ineffective from the start.”
Enforcement should begin with the legal trade
CITES tends to equate “enforcement” with fighting poaching or international wildlife crime. Lynn argues this misses the point. Proper enforcement must begin with the legal trade itself: checking origin claims, verifying whether animals are truly captive bred, confirming quotas, cross-checking population baselines, and ensuring permits contain correct details. Because this isn’t done, legal and illegal trade have blurred together — and no one is trying to separate them.
Legal and illegal trade are now intertwined
A 2020 Refinitiv report found that 65% of companies suspect illegal environmental activity inside their supply chains, yet only 16% would report it externally. Instead of regulators uncovering wrongdoing, the system relies on whistleblowers. In a context where permit data is rarely verified and claims of “captive bred” often go unchecked, laundering illegal wildlife into the legal market becomes easy. As Lynn writes: “The legal and illegal trades are currently functionally inseparable.”
Verification has declined as CITES expanded
Countries often celebrate new species listings, but the more species CITES lists, the more verification is required — and the fewer resources countries have to do the work. A major 2015 study analysing 2,750 species found that only 7.3% of export records were free from documentation discrepancies. Even more worrying: trade monitoring was less efficient in 2012 than in 2003. This means the system is degrading as it grows.
Without enforcement, wildlife crime cannot be controlled
Governments and NGOs have poured attention into illegal wildlife trade, yet global enforcement systems barely touch environmental crime. Only 2% of Interpol Red Notices target environmental offenders — just 21 out of more than 7,000 notices worldwide. Dozens of new networks have been set up to tackle wildlife crime, but without addressing failures in the legal supply chain, their success was always going to be limited. The root drivers remain untouched.
Why there is no desire to enforce the legal trade
Lynn is clear that industries benefiting from wildlife trade resist proper enforcement because it would reduce profits and reveal how porous supply chains really are. Verification would expose misreporting, uncontrolled extraction, and the laundering of wild-caught animals as captive bred. As Lynn states: “The illusion and delusion of CITES effectiveness must stop.”
My personal view
If CITES cannot verify origins, check permits, or enforce its own rules, it cannot claim to regulate international wildlife trade. What struck me most in this Reality Check is how environmental crime isn’t a separate crisis — it grows directly out of this lack of enforcement. When the legal trade isn’t checked, illegal trade simply slips inside it, and the two become impossible to separate. A system built without enforcement inevitably becomes a system that enables crime. For CITES to remain relevant, enforcement has to become the foundation, not an optional extra.
Read the full article here: https://natureneedsmore.org/cites50-reality-check-4-cites-trade-measures-never-enforced/
CITES@50 Reality Check 5: Transparency Is Optional
Coming soon.
CITES@50 Reality Check 6: Enforcement Capacity Is Still Not Built
Coming soon.
CITES@50 Reality Check 7: Trade Data Without Context Cannot Protect Wildlife
Coming soon.

