JLG meeting 11 January 2012
Minutes SUN session
Guild of Taxidermists
International Centre for Birds of Prey
National Council for Aviculture
Apologies: Peter Berry (A Berry & Son Ltd), Sally Cunningham (Defra),
John, Philip McGowan (World Pheasant Association), Robert Morgan (British Fur Trade
Association), Aeron Williams (Parrot Society)
Welcome and introductions
meetings were introduced by Defra in 2006 to bring together traders and wildlife
NGOs in a forum where CITES issues could be discussed between the various groups,
CITES policy and delivery officials. SUN members, for a number of years, have
participated in an additional bi-annual AHVLA organised meeting, which policy officials
attended as necessary.
Following a reduction in resources AHVLA told SUN in October 2011 that they would not be able to provide the Secretariat for
future such meetings. Nevertheless, members
could attend the regular JLG meetings
to discuss non-case specific CITES Issues.
Summary of discussion - 11 Jan 2012
expressed concerns about the cessation of meetings hosted by AHVLA and felt that an
important line of communication had been removed. SUN stressed that consultation should take place
between Government and traders on relevant issues. SUN members were reassured at the meeting that it
always has been and remains Defra/AHVLA policy to consult with stakeholders on issues of
SUN were also concerned about the propriety of discussing some commercially
sensitive trade issues in the same fora as NGOs.
AHVLA/Defra informed SUN
that it was not their intention to curtail such meetings but rather that with the JLG in existence the provision of Secretariat
duties to the SUN meeting could no
longer be justified. They and policy were
available, as required, for bilateral meetings to discuss specific trade issues.
Defra reiterated that the scope of the JLG was limited to CITES related matters, and not broader biodiversity topics
such as bird related issues under the Wildlife and Countryside Act (WCA) 1981. Separate meetings, involving the relevant Defra
policy lead as appropriate, would need to be arranged for those. Specific case related
discussions should take place directly between SUN and AHVLA and/or Defra.
SUN also asked for an update on team names and
SUN will arrange and provide Secretariat for future
case related meetings, if possible running these immediately before or after JLG meetings. Defra/AHVLA/SAs
will attend these meetings as necessary
Defra/AHVLA to circulate staff organisation charts to SUN members, including those for DG Env
Annex A captive bred specimens
This topic related to proof of legal
origin for specimens not commonly kept and/or bred in captivity that were never originally
intended to be used
for commercial purposes. In cases, for
example, where a keeper keeps annex A specimens which they had not intended to sell and
therefore for which they do not have Article 10 certificates, if/when the animals breed
this can result in a surplus of animals which the keeper may then decide to sell.
SUN had previously suggested that AHVLA/Defra set
up a registration scheme to enable specimens kept but not intended for a commercial use to
be registered, as this would help with proof of legal origin if the keeper subsequently
wished to use the specimens commercially. A
meeting between SUN/Defra/JNCC took
place on this matter several years ago. At
that time, and now, Governments view was that such a registration scheme should not
be established. Such a scheme could not be
imposed, was likely to be expensive, and was unlikely to be comprehensive if introduced on
a voluntary basis.
Defra confirmed, however, that long time periods between the time a specimen
was first acquired and the time of first application for an Article 10 would not in
itself be interpreted by default as evidence or suspicion of illegality of origin.
However, Defra / AHVLA encouraged
keepers to keep good records which could help in establishing the legal origin of such
Applications will continue to be considered on a case by case basis using a
risk assessment approach.
AHVLA would liaise with Chris Newman in respect of general guidance on the
sort of evidence which would be satisfactory for them to use as evidence of legal
The term commercial
As part of the review of the EU
Wildlife Trade Regulations the European Commission had agreed that where there was a lack
of clarity in the existing regulations, this should be addressed either by changes to the
Wildlife Trade Regulations or by informal guidance. EU Member States had been asked to
assist with drafting these guidance notes which are expected to go through a period of
consultation within the EU and also with stakeholders.
The UK is involved in
drafting guidance on the following topics:
Definition of primarily commercial purposes/commercial purpose
Questions related to transaction specific certificates
Definitions of applicant, importer/exporter, agent
The UK is also assisting
a small number of other MS with drafting guidance on other issues.
No final decisions had yet been taken on any guidance. Defra will ensure that relevant UK stakeholders are consulted on the draft guidance
once it is in a fit form and before it publication; this is likely to be from spring 2012.
Defra to supply SUN
members with a list showing which EU Member States are involved in drafting each guidance.
AHVLA briefly provided an overview of Operation RAMP; an Interpol led global operation aimed at the illegal trade in reptiles and
SUN expressed a number of concerns, in particular
the perceived heavy handedness and timing of the Operation, which coincided with a
procedural change, related to return of transaction specific certificates on the sale of
specimens. SUN believe that a number of traders who were not aware of this change were
disadvantaged by the timing of the operation. AHVLA
stated that no such circumstance had resulted in prosecutions. Several SUN members said they thought communications from AHVLA on the procedural change
were poor and that to ensure future good compliance, communications should be timely and
consistent. Participants took different views
on whether the TSC change was a
significant one, but also explored how communications could be improved.
Nevin Hunter would convene a meeting in April 2012 to review Operation RAMP to consider lessons learnt. This will be an open meeting to which SUN Members will be invited.
Defra/AHVLA will consider how communication with the trade on any procedural
changes which are normally placed on the AHVLA website, could be improved.
Extracts from a Meeting between DEFRA Wildlife
Licensing and Registration Service (WLRS), Scientific Authorities & SUN Representatives (Tuesday 1 March 2011,
of Pre-issued Certificates under Article 63 of 865/2006
Hounslow (DEFRA)] explained that WLRS were no longer issuing semi-complete Article 10
certificates as there was evidence of them being used to illegally sell birds and that
breeders were consistently failing to provide adequate records and completing returns in a
timely fashion. Mike Gates (World Owl Trust)
stated that he hadnt received the letter informing traders of this; his members had
not been consulted and they were concerned that there would be problems hand-rearing owls
if they had to wait 6 weeks for an Article 10 certificate.
JH confirmed that WLRS met its targets so there shouldnt be a problem. Kim McDonald (Guild of Taxiderista) expressed his
frustration that this change affected taxidermy specimens but no criminal offences had
taken place for dead birds.
b. Bird Reg/A10 combined Application Form
A new form is
being developed to enable applicants to apply for an Article 10 certificate and register a
bird at the same time. This will save
time having to provide the same information twice.
c. Wild disabled birds
explained that WLRS has had concerns for some time about the number of wild Schedule 4
birds that are registered for rehabilitation and subsequently end up permanently kept in
captivity. WLRS will be taking a stricter view
to ensure that wherever possible any wild Schedule 4 bird taken into captivity is
rehabilitated and released back to the wild as soon as possible. They will be inspecting keepers of wild Schedule 4
birds to check that rehabilitation is occurring and that the keeper has sufficient
knowledge to successfully release the bird back to the wild.
are 2 new forms available for avian vets to download and complete http://www.defra.gov.uk/animalhealth/about/formsandfees/formdisplay.asp?ref=WLRS118 and http://www.defra.gov.uk/animalhealth/about/formsandfees/formdisplay.asp?ref=WLRS117
10 certificates for wild disabled birds will only be granted where there are genuine
exceptional conservation benefits to the species.
back from SRG meeting and
Upcoming: SRG, Plants and
Animals Committee Meetings
Littlewood (JNCC) gave an overview of the last
Scientific Review Group (SRG) meeting which included discussions on eels, the new
suspension regulation and reptiles from Benin. She explained that the SRG regularly reviews
species and country combinations subject to long standing import suspensions. KD said that
he felt that transparency had
improved within the SRG but it
was not yet appropriate to the 21st century. AL
stated that there had been some progress in this regard and a lot of SRG reports and
documents have now been made available via the commission website
http://ec.europa.eu/environment/cites/home_en.htm including the agenda for the next
Charging, merger with VLA and other corporate proposals
that a submission is being sent to Ministers about increasing CITES charges. WLRS customers will be consulted. New fees are likely to be introduced in 2012. JH said that Animal Health was merging with VLA and
this may make bird imports more joined-up.
THE SUSTAINABLE USERS NETWORK (SUN)
The Sustainable Users Network (SUN) was established in the late 1980's at the specific behest of the UK's
Department of Environment (now DEFRA) who were getting frustrated at the number of
organisations seeking to have dialogue with them and the relative lack of professionalism from many of these groups. At the same time
our opponents likewise formed an umbrella grouping for discussions with Government
(Wildlife & Countryside Link).
At the universal agreement of all the affiliates to SUN it is intentionally run on a relatively ad hoc and informal basis but acts
as a single point of contact to the likes of DEFRA and the JNCC (Joint Nature Conservation
Committee) so that regular meetings and such like can be organised with our Scientific and
Management Authority's. As such, SUN
meets as a group of affiliates, share information, endeavour to support each other in
lobbying, etc. SUN's main role is to
help ensure that animal and plant interests, hobby and trade, work together and wherever
possible have a unified approach on legislation. The only requirement for SUN affiliation is that all organisations are able
to state that they support the concept of sustainable trade in wildlife (i.e. trade in
both captive-derived and wild-taken stock provided this is undertaken sustainably i.e.
within the constraints established by CITES for setting quotas, establishing non-detriment
In addition to the NCA - which has been an affiliate since the inception of SUN - the Sustainable Users Network has a mass of
organisations affiliated to it amounting to a combined membership in the region of 1.2
million. Included in the affiliated membership are two UK organisations concerned with
field sport activities (The Hawk Board and The British Association for Shooting and
Conservation) and a host of others connected with both plant and animal interests both
trade and hobbyist - e.g. British & Irish Association of Zoos & Aquaria, Pet Care
Trust, National Association of Private Animal Keepers, Timber Trade Federation, Guild of
Taxidermists, Royal Horticultural Society, International Owl Society, British Orchid
Growers Association, Parrot Society, to name but a very few. It is widely acknowledged by
DEFRA that SUN has been able to
influence legislation a great deal more successfully than any of the affiliates are able
to do on their own.
Jim Collins - a keen bird-keeper - has been SUN's Co-ordinator for the past fifteen years.