Consultation outcome

Summary of responses and government response

Updated 9 February 2026

Background

This document summarises the consultation responses on proposals to amend the assimilated UK Wildlife Trade Regulations (WTR). It also outlines the proposed course of action of the UK government.

The purpose of this consultation was to seek views on proposals and policy options for reforming the WTR, which implement the UK’s obligations under the Convention on International Trade in Endangered Species (CITES). WTR reform aims to ensure legislation is clear, proportionate, and fit for purpose to protect wildlife and support sustainable trade. This aligns with recommendations from the Corry Review, which advocates for regulations that deliver effective outcomes for both economic growth and nature recovery.

The consultation was launched by Department for Environment, Food and Rural Affairs (Defra) on 11 September 2025 and remained open until 23 October 2025.

It was hosted on the Citizen Space digital platform at: CITES Reform proposals – Defra – Citizen Space, and responses could also be submitted via post and email.

Executive summary

The UK government will implement targeted reforms to the Wildlife Trade Regulations (WTR) to make them clearer, proportionate, and aligned with CITES obligations while also supporting conservation and sustainable trade. Key changes will include reducing regulatory burdens through risk-based measures:

• adding low-risk species to Annex X of EC Regulation 865/2006 and allowing export and re-export permits to substitute for Article 10 certificates
• import permit requirements for Annex B specimens will be streamlined by introducing a low-risk species list and replacing permits with digital pre-notifications
• semi-complete permits will be extended to imports and exports of live Annex B and C specimens under strict safeguards, while Annex D will be retained but modernised through species review and digitisation

Other reforms include recognising travelling exhibition certificates issued by other authorities, maintaining welfare checks for Annex B specimens and expanding civil sanctions to address enforcement gaps.

Measures to strengthen traceability for Schedule 4 bird species, introduce validity periods for Article 60 certificates and digitise Annex C notifications will improve oversight and compliance.

Fee changes proposed in the consultation will be adopted once the wider reforms have been implemented, ensuring a fair and sustainable approach to cost recovery. The changes will be made through statutory instruments and supported by updated guidance and stakeholder engagement. The aim is to create a permitting system that is efficient, transparent and focused on conservation.

Methodology

The consultation was broken down into four substantive parts. The first part included general consultation questions, and the analysis of this section is summarised in the ‘about the respondents’ section of this report. The remaining 3 sections included questions pertaining to policy proposals. These are summarised in the ‘summary by policy proposal’ section of this report.

The consultation included 98 questions and used a combination of multiple choice and open-text responses. Respondents were not required to submit a response to all questions. All percentage figures in this summary are expressed as a proportion of respondents who submitted an answer to that question.

There were 49 multiple choice questions where respondents were asked to choose from a range of responses. For many of these questions, including those where respondents were asked to express preferences over policy options, respondents could select more than one answer. This should be taken into account when interpreting the report and may result in the sum of percentage totals in summary tables exceeding 100%.

The remaining 45 questions were ‘open-text’ questions. Each response was individually read, analysed and summarised. Respondents’ interpretation of cost and impact questions varied, so analysis focused on key themes rather than quantitative data.

The information collected from analysis of cost and impact questions associated with policy proposals was predominantly used to inform the underlying assumptions in the impact assessment. Questions related to crosscutting impacts of reform (questions 84 to 86 ), including familiarisation time and trade implications, were also used to inform the impact assessment. These were referenced as potential costs and benefits where appropriate and converted into monetary estimates where possible. Therefore, analysis of these questions is not presented in detail in this report.

This summary of responses is not an exhaustive list of all ideas provided by respondents but summarises the key comments, concerns and opinions. Therefore, a range of qualitative terms are used, such as ‘many’, ‘some’, ‘most’ and ‘a few’. All references to changes in the number of permits or costs incurred due to the proposed government response are modelled on 2024 to 2025 permit data.

The consultation questionnaire collected personal data on respondents (such as names and contact details). Care was taken to ensure this personal data was used responsibly by anonymising respondents before analysis began. While writing this summary, care was taken to ensure no respondent might be individually identified to guarantee confidentiality.

About the respondents

A total of 141 responses were received, of which 129 were submitted via the online form and 12 were received by email.

Questions 1 to 4 of the consultation questionnaire asked for contact information and privacy preferences of respondents and are not analysed here. Question 5 asked respondents for details on the type of organisation they are responding on behalf of.

• 76 (54%) responses (digital platform and email) were from individuals
• 65 (46%) responses (digital platform and email) were from a range of organisations, including public bodies, businesses, industry associations, non-governmental organisations (NGOs) and academic institutions

Respondents were asked to indicate the type of organisation they were responding on behalf of. A total of 79 respondents answered this question. A breakdown of these responses is provided below.

Type of organisation	Number	Percentage
A government body	5	6%
Non-governmental organisation (NGO)	11	14%
Local authority	0	0%
Charity	10	13%
Consultancy	1	1%
Small or micro-business (less than 50 employees, including any global operations)	22	28%
Medium business (50 to 249 employees, including global operations)	8	10%
Large business (250 or more employees, including global operations)	2	3%
Industry association	13	16%
Academia – in an official capacity as a representative of an academic or scientific institution	0	0%
Other	7	9%

Respondents were also asked which sectors affected by CITES they were interested in, with respondents able to provide more than one answer. 141 responses were received for this question, and a breakdown is provided below:

CITES sectors	Number	Percentage
All sectors regulated by CITES	30	21%
Zoos and captive breeding programmes	61	43%
Fashion	3	2%
Food	5	4%
Antiques	12	9%
Musical instruments	33	23%
Biological and biomedical samples	19	13%
Timber	4	3%
Beauty and health products	5	4%
Live plants and horticulture	23	16%
Pet trade	30	21%
Aquatics	13	9%
Museums, botanical gardens, and travelling exhibitions	9	6%
Other	17	12%

Question 7 asked respondents about their use of CITES permits. All 141 respondents answered the first part of this question. The majority (67%) of respondents said they are involved in the trade of specimens that require CITES permits.

82 respondents answered a question about how often they apply for a CITES permit. The most popular answer was once or twice a year (40%), followed by quarterly (23%), then once or twice a month (21%). A small number of respondents apply weekly (9%) or rarely (7%).

74 respondents (52%) indicated that they use additional licences or other official documentation for trade of CITES specimens. The most commonly cited examples were export health certificates, Schedule 4 bird registration and phytosanitary certificates.

Respondents were asked for information on the current costs of complying with CITES legislation. Data collected were used to inform the impact assessment.

In the open-text part of this question, many respondents referenced the logistical challenges of trading in CITES specimens. These include transportation delays, shipping costs and complications with freight handling due to the need for specific permits. Seasonal industries such as horticulture and bird breeding raised the challenge of completing permitting requirements during peak operational times. It was noted that physical permits add further burdens, with the need for careful tracking and presentation at borders.

Beyond operational issues, stress associated with CITES compliance was mentioned by many stakeholders. Complex and frequently changing regulations, the fear of legal consequences and understanding of requirements were all referenced.

Summary and government response by policy proposal

Proposals to amend CITES assimilated legislation

Article 10 certificates (commercial use certificates)

Four options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 108 respondents answered this question. Results are summarised in the table below.

Options for Article 10 certificates	Number	Percentage
1. Add additional low-risk species to Annex X to better target certification burden	28	26%
2. Self-certification instead of certificates	55	51%
3. Use export or re-export permits in place of Article 10 certificates for their validity period	28	26%
4. Do nothing	30	28%

Respondents were asked to provide any views or preferences on the options (1 to 4) described, including whether they had any alternative proposals. Key points made were:

• businesses and trade groups viewed Article 10 certificates as burdensome and unnecessary under CITES, favouring self-certification (option 2) and use of export or re-export permits (option 3) to reduce costs and duplication
• conservation NGOs and enforcement agencies supported retaining the current system (option 4) to ensure traceability, prevent illegal trade and uphold environmental commitments
• there was broad support for proportionate regulation, including targeted reforms such as adding low-risk species to Annex X (option 1) with safeguards
• alternative proposals provided by respondents included removing Article 10s entirely, industry-led transfer systems, expanding Annex X (for example, adding birds of prey species) and using Transaction Specific Certificates (TSCs)

Government response: Article 10 certificates

The government will seek to proceed with a combination of options 1 and 3 to reduce regulatory burden. This will deliver targeted, proportionate changes that make trade more efficient without compromising conservation standards.

We will initially add 3 commonly captive-bred Mediterranean tortoise species (Testudo hermanni, Testudo graeca, and Testudo marginata) to Annex X of EC Regulation 865/2006.

This change will:

• remove the need for Article 10 certificates for appropriately marked captive bred specimens of these species
• reduce Article 10 volumes by approximately 41% (9,000 permits per year), reducing fee expenditure and easing administrative pressures to deliver estimated savings to the sector of £132k per year
• retain import controls, including captive breeding assessments via import permits

To maintain integrity and transparency, Defra will establish a formal review process with expert input from CITES scientific authorities for Fauna and Flora (Joint Nature Conservation Committee (JNCC) and Royal Botanic Gardens, Kew (RBG Kew)) and work with stakeholders to ensure future amendments to Annex X are supported by evidence. We will consider additional species suggested by respondents as part of this review process.

We will allow a valid export or re-export permit to substitute for an Article 10 certificate for its 6-month validity period.

These changes will:

• avoid duplication and reduce costs
• simplify export and re-export processes while maintaining enforcement standards
• reduce Article 10 volumes by a further 6,800 permits per year (32% of the current annual figure), delivering an additional £100k in savings to commercial exporters of Annex A species per year

We will not proceed with option 2 (self-certification) due to concerns over misuse, enforcement burden and inconsistent application. However, we remain committed to exploring future efficiency improvements that uphold compliance and conservation goals.

Import permits for Annex B specimens

Six options were set out in the consultation. Respondents were asked to indicate their preference and could choose more than one option. 101 respondents answered this question. Results are summarised in the table below.

Options for import permits for Annex B specimens	Number	Percentage
1. Create low risk species list	38	38%
2. Replace import permits with import notifications	52	51%
3. Exempt artificially propagated plants	38	38%
4. Semi complete permits for high volume, low risk trade	19	19%
5.Removal or other amendment of Annex B import permit requirement	42	42%
6. Do nothing	29	29%

Respondents were asked to provide any views or preferences on the options (1 to 6) described, including whether they had any alternative proposals. Key points made were:

• most respondents supported reform of the Annex B import permit system, favouring a more flexible, risk-based approach
• businesses and trade groups preferred partial or total exemptions (options 3 and 5) – some viewed the current system as a retained EU measure not required by CITES, adding unnecessary cost and delays
• conservation NGOs and enforcement agencies preferred retaining the current system (option 6) or limited reforms (options 1 and 4) – comments stressed the need for oversight to prevent illegal trade and supported proportionate regulation with safeguards
• many respondents supported combining multiple options to balance simplification with conservation safeguards – alternative proposals included digital pre-notification systems, broader exemptions and reciprocal arrangements with EU partners

Government response: Import permits for Annex B specimens

The government will seek to adopt an integrated approach, combining options 1, 2 and 3 to achieve its objectives. Together, these measures will deliver proportionate regulation and improve efficiency without compromising the UK’s ability to monitor and respond to conservation concerns.

These changes will:

• remove approximately 3,000 import permits per year currently issued for artificially propagated plants, delivering an estimated £97k per year saving in permit fee and administrative costs to business
• create further savings as options 2 and 3 are implemented
• focus regulatory effort on higher-risk species and trade routes, ensuring resources are used where they have the greatest conservation impact
• enable authorities to target enforcement and monitoring on higher-risk species and trade routes
• improve visibility of trade flows and enable timely action on conservation concerns
• reduce paperwork and processing times, making compliance simpler and faster for businesses

Defra will formalise a process with expert input from JNCC and RBG Kew, and work with stakeholders, to periodically review and update the exempted species list based on robust scientific risk assessment.

For specimens on the low-risk list, we will aim to introduce a new digital pre-notification system as part of the ongoing project to digitise CITES licensing activities. This will improve visibility of trade flows, enable timely action on conservation concerns, and reduce paperwork and processing times. Under this system, low-risk Annex B species will not need an import permit but will require to be pre-notified in the UK permitting system before entering the country, with the export permit for the consignment included. The importer or their UK-based agent will be responsible for completing this process.

We will not progress option 4 (semi-complete permits) or option 5 (removal of import permits for all Annex B specimens). Option 4, as proposed, lacks sufficient safeguards, could undermine compliance and increase enforcement complexity. However, as described in the following section, we will introduce a more controlled, risk-based extension of semi-complete permits for live Annex B and C specimens, supported by guidance and monitoring to maintain oversight.

Semi-complete permits

Two options were set out in the consultation. Respondents were asked to indicate their preferred option. 59 respondents answered this question. Results are summarised in the table below.

Options for semi-complete permits	Number	Percentage
1. Extend use of semi-complete permits to both imports and exports of live Annex B and C specimens	27	46%
2. Do nothing	32	54%

Respondents were asked to provide any views or preferences on the options (1 to 2) described, including whether they had any alternative proposals. Key points made were:

• industry and some individual respondents supported option 1 due to the potential for reduced administration and costs for businesses, especially relating to large-volume, low-risk trade
• concerns were raised that while extending the use of semi-complete permits could work for imports and live plants, it may be less suitable for live animals due to practical challenges with conducting inspections
• others noted option 1 would require improved monitoring and guidance and could result in greater administrative burdens on authorities
• option 2 had high levels of support among NGOs, who were concerned about weakened oversight, welfare risks, disease and conservation impacts

It was highlighted that high compliance and record keeping standards should be maintained through a risk-based application of option 1. Non-compliance should result in those at fault losing the ability to use semi-complete permits.

Government response: Semi-complete permits

While recognising that neither option was heavily favoured over the other, the government will seek to amend regulations to allow the extension of semi-complete permits to cover imports and exports of live Annex B and C specimens (option 1).

The extension will not be applied automatically following regulatory amendments. Its future application will be subject to clear, risk-based criteria, with appropriate oversight and authority to restrict access for non-compliant parties. This change will:

• provide opportunities to improve operational flexibility for businesses engaged in sustainable, low-risk trade
• maintain regulatory oversight, with APHA retaining discretion over permit issuance and monitoring
• reduce administrative costs for up to 7,900 permits issued to live Annex B specimens in 2024 to 2025

Eligibility for semi-complete permits will depend on an applicant’s proven record of accurate record-keeping. APHA will assess each application individually and retain the right to issue standard permits where appropriate. Any reform will be supported by updated guidance and processes to help businesses understand and comply with semi-complete permit requirements.

Retaining the current framework without the potential for changes would not address the limitations identified by stakeholders and would miss an opportunity to improve efficiency and responsiveness within the permitting system. Applying a risk-based approach to the extension of semi-complete permits would help address issues raised by respondents, such as the need for enhanced oversight and guidance.

Annex D

Four options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 67 respondents answered this questions and the results are summarised in the table below.

Options for Annex D	Number	Percentage
1. Retain Annex D, but review listed species and digitise import notifications	21	31%
2. Retain Annex D as a published list but remove the import notification requirement	9	13%
3. Remove Annex D entirely	31	46%
4. Do nothing	16	24%

Respondents were asked to provide any views or preferences on the options (1 to 4) described, including whether they had any alternative proposals. A handful of alternative proposals were received and were considered during analysis. Respondents made the following key points:

Respondents highlighted the semi duplicative nature of Annex D import notifications. They suggested the further development of current systems such as IPAFFS (import of products, animals, food and feed system) could provide a solution. However, concerns with the differing naming conventions used across systems raised by some respondents indicated that this would not provide a suitable route forward at this time.

Some indicated that the conservation benefit provided by Annex D did not outweigh the administrative burden. Others highlighted the importance of monitoring trade in non-CITES listed species.

Conservation NGOs and some implementing organisations indicated the usefulness of Annex D as an early warning system for potential Appendix I and II listing proposals, and an important tool for conservation. However, it was also noted that a tailored list of species of UK interest would be preferred.

Government response: Annex D

While some respondents supported removing Annex D, there was insufficient evidence that doing so would deliver significant benefits without creating risk. Annex D continues to provide monitoring value and removing it could weaken the UK’s ability to detect emerging trade risks.

However, we recognise the need to reduce unnecessary administrative burdens, and the government therefore intends to proceed with option 1. Annex D will be retained but all current species listings under Annex D will be reviewed for appropriateness, drawing on expert input from JNCC and RBG Kew and working with stakeholders. The government will also seek to digitise import permit notifications for Annex D listed species. This approach delivers a better balance between efficiency and oversight.

These changes will:

• achieve a more targeted and responsive system for future needs, which will reduce the burden on business over the longer term
• streamline import notification processes, reducing costs for business and administration
• retain monitoring benefits of CITES Appendix III species for which the UK has placed a reservation and for non-CITES species

Options 2, 3 and 4 will not be taken forward. We recognise these options could reduce administrative burdens, but they would undermine the UK’s ability to monitor and respond effectively to trade risks. In the case of option 4, it would perpetuate inefficiencies in the permitting system and diminish the value of collected data.

Travelling exhibition certificates (TECs)

Three options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 42 respondents answered this question. Results are summarised in the table below.

Options for TECs	Number	Percentage
1. Recognition of TECs issued by other management authorities	25	60%
2. Permit applications by tour organisers or authorised agents	18	43%
3. Do nothing	20	48%

Respondents were asked to provide any views or preferences on the options (1 to 3) described, including whether they had any alternative proposals. Key points made were:

• implementing organisations and interested sectors – including antiques, music and museums – supported option 1 (recognition of TECs issued by other management authorities) and option 2 (permit applications by tour organisers or authorised agents) to reduce duplication and administrative burden
• conservation NGOs advocated for option 3 (retaining the current system) to safeguard traceability and enforcement, emphasising the risks of fraud
• alternative proposals included creating a centralised digital system for TECs and introducing a model similar to the ATA Carnet

Government response: TECs

The government will seek to proceed with options 1 and 2 to streamline processes, reduce administrative and financial burdens, and facilitate the movement of travelling exhibitions while ensuring compliance with CITES. Concerns about fraud and traceability were noted but lacked evidence; existing APHA controls will ensure compliance.

This change will:

• remove over 100 duplicative TEC certificates issued per year
• support legitimate touring exhibitions by enabling faster, simpler movement of travelling exhibitions including between the UK and EU

Accommodation and care considerations within the WTR

Two options were set out in the consultation. Respondents were asked to indicate their preferred option. 62 respondents answered this question. Results are summarised in the table below.

Options for accommodation and care	Number	Percentage
1. Removal of welfare assessment for Annex B specimens	39	63%
2. Do nothing	23	37%

Respondents were asked to provide any views or preferences on the options as described or if they had any alternative proposals. Respondents made the following key points:

Industry associations and zoos respondents argued Annex B welfare checks duplicate existing UK frameworks (Animal Welfare Act, Balai rules, animal activities licensing), adding cost and delays without improving welfare outcomes.

Some respondents, including conservation and welfare NGOs, warned removing checks could create gaps, as the Animal Welfare Act excludes invertebrates and local authorities face capacity issues. They advocated maintaining welfare checks for all CITES species and stricter standards for overseas premises receiving UK exports.

Some stakeholders cautioned that removing checks could undermine our international obligations, as CITES checks are proactive while domestic enforcement is reactive.

Alternative proposals included:

• simplifying Annex B checks based on compliance history
• streamlining Annex A assessments
• exemptions for animal activities licence (AAL) holders
• a single welfare process across agencies
• better data-sharing
• stricter welfare standards for overseas premises

Government response: Accommodation and care considerations

Following consideration of the consultation responses, the government will seek to proceed with option 2 and retain the welfare assessment requirement for Annex B imports at this time. This decision reflects:

• valid concerns about the potential to create gaps in welfare protection
• the need to maintain consistency in welfare standards
• the importance of avoiding changes that create uncertainty or unintended consequences for applicants and regulatory authorities

However, the government recognises the importance of ensuring that administrative processes are proportionate and relevant. We are committed to working with stakeholders to review the questions asked and the information required as part of welfare assessments, with the aim of ensuring that these are appropriate, clear, and directly relevant to permit decisions. We will continue to look at ways to reduce unnecessary or confusing requests for information and improve the overall experience for applicants, while maintaining the integrity of welfare standards.

Greater use of civil sanctions to address enforcement gaps

Two options were set out in the consultation. A total of 103 responses were received to this question, and the results are summarised in the table below.

Options for civil sanctions	Number	Percentage
1. Extend civil sanctions to 6 additional areas	39	38%
2. Do nothing	66	64%

Respondents were asked to provide any views or preferences on the options as described or if they had any alternative proposals. A total of 88 responses were received to this question. Respondents made the following key points:

Respondents highlighted that civil sanctions could strengthen compliance and close enforcement gaps if implemented with robust safeguards. Many supported their use for minor breaches, provided clear criteria, transparency, reinvestment of revenue and separation from criminal offences are in place. Conservation groups, regulators, law enforcement and policy advocates expressed conditional support, seeing potential for civil sanctions to address low-level breaches effectively.

There was strong backing for legislative reform to accompany any expanded powers, including a tiered enforcement model that distinguishes serious crimes from administrative errors. Modernising the Wildlife and Countryside Act and publishing enforcement data were widely supported as steps to improve fairness and trust.

However, several sectors raised concerns. The falconry and captive breeding community strongly opposed option 1, citing outdated legislation, disproportionate penalties and risks of clerical errors harming livelihoods. They warned that expansion without reform could erode trust and push expertise overseas, calling for informal resolution of minor errors and proportionate enforcement.

Musicians and related stakeholders rejected civil sanctions for CITES-regulated instruments, urging clearer guidance and international cooperation. Law enforcement and regulators flagged jurisdictional gaps and conflicts with criminal investigations, while legal and compliance professionals questioned unclear proof standards and costly, slow civil processes, raising concerns about fairness and efficiency.

The consultation sought views on which (if any) of the 6 additional areas respondents supported to be covered by civil sanctions. Respondents were asked to indicate their preferred option and could choose more than one option. 38 respondents answered this question. The results are summarised in the table below.

Proposed areas for civil sanctions	Number	Percentage
1. Introduction into, or export or re-export from, the UK of specimens without the appropriate permit or certificate, or with a false, falsified or invalid permit or certificate, or one altered without authorisation by the issuing authority.	31	82%
2. Knowingly or recklessly making a false declaration or knowingly providing false information in order to obtain a permit or certificate (additionally referenced in COTES 2018 Schedule 1(2) under Offences and penalties).	30	79%
3. Knowingly using specimens listed in Annex A other than in accordance with the authorisation given at the time of issuance of the permit or subsequently.	28	74%
4. Purchase, offer to purchase, acquisition for commercial purposes, use for commercial gain, display to the public for commercial purposes, sale, keeping for sale, offering for sale or transporting for sale of specimens in contravention of Article 8.	31	82%
5. Knowingly using a permit or certificate for any specimen other than one for which it was issued (additionally referenced in COTES 2018 Schedule 1(2) under Offences and penalties).	31	82%
6. Knowingly falsifying or altering any permit or certificate issued in accordance with this Principal Regulation or Subsidiary Regulation (additionally referenced in COTES 2018 Schedule 1(2) under Offences and penalties).	30	79%
Not answered	103	73%

Respondents were asked to provide any views or preferences on the options (1 to 6) described, including whether they had any alternative proposals. Respondents suggested several alternative proposals:

• use civil sanctions for first-time, low-impact or technical breaches; reserve criminal penalties for serious or deliberate offences
• modernise the Wildlife and Countryside Act to reduce ambiguity and align with current conservation practices
• ensure proportionate penalties, publish annual enforcement data, and reinvest civil sanction funds into CITES enforcement and biodiversity protection
• provide clear guidance, apply consistently and apply civil sanctions uniformly with legal safeguards

Respondents were asked if they could outline any other circumstances where civil sanctions might provide helpful additional enforcement capacity. A total of 39 responses were received to this question. Key points made were:

• certain offences under COTES Schedule 1 and Article 16 of EC Regulation 338/97, specifically those under Article 16(a) and 16(b), except offences involving impersonation or deception
• keeping specimens commercially without proof of source
• ignoring repeated warnings or failing to return invalid documents
• administrative breaches below the criminal threshold (such as missing phytosanitary or CITES documents, poor record-keeping, non-compliance with marking)
• knowingly selling or using false permits; omission of certificate numbers in listings
• minor permit condition breaches (such as routing through non-designated ports) and first-time or occasional non-knowing offences
• failure to cooperate with audits or provide required information

Government response: Civil sanctions

The government has carefully considered the range of views expressed during the consultation and will proceed with expanding the scope of civil sanctions within COTES 2018. This means that the 6 infringements listed in the consultation document will now be applicable to the issuance of civil sanctions.

We recognise that stakeholders expressed mixed views on this proposal. While some sectors raised concerns about fairness, proportionality and administrative burden, others (including conservation groups, regulators and enforcement bodies) highlighted the potential for civil sanctions to strengthen compliance and close enforcement gaps when implemented with certain safeguards. The government agrees that robust safeguards are essential and will ensure they are embedded in the approach.

Expanding the scope of civil sanctions addresses a key issue identified during consultation, which is that criminal sanctions alone are not always timely, proportionate or appropriate to the nature of the contravention.

This change will:

• give enforcement agencies a flexible tool to take proportionate and timely action, divert cases from court, and reduce the resource burden on enforcement authorities, police and the justice system
• bridge the gap between limited recourse and criminal prosecution, ensuring enforcement is fair and proportionate
• improve effectiveness and transparency while helping prevent future breaches

Civil sanctions are not intended to replace criminal enforcement but to complement it by offering a proportionate response to minor breaches. They will be applied with clear criteria and safeguards to prevent disproportionate impacts on legitimate stakeholders. The government will also work with stakeholders to develop improved guidance and ensure processes are clear, relevant and practical. This includes reviewing information requirements to avoid unnecessary or confusing requests and focusing on permit-relevant questions.

By implementing civil sanctions alongside guidance and stakeholder engagement, the government aims to create a transparent, collaborative enforcement system that:

• protects wildlife
• supports conservation
• upholds the UK’s international commitments under CITES
• recognises and addresses the concerns raised by affected sectors

Strengthen controls in place for Schedule 4 listed bird species

Five options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 74 respondents answered this question, and the results are summarised in the table below.

Options for Schedule 4 listed bird species	Number	Percentage
1. Standardise ringing requirements	54	73%
2. Remove bird registration exemption for peregrine falcons and merlins	48	65%
3. Regulate hybrid specimens	22	30%
4. Extend and align registration timelines	45	61%
5. Do nothing	11	15%

Respondents were asked to provide any views or preferences on the options (1 to 5) described, including whether they had any alternative proposals. The alternative proposals were substantive and will therefore be considered further with stakeholders, post-reform. Respondents made the following key points.

Respondents indicated the importance of maintaining traceability of specimens, and the recognition of modern breeding techniques, with broad support for provisions working to provide both conservation benefit and enhanced traceability for both industry and regulator.

NGOs and implementing organisations highlighted the importance of maintaining oversight of specimens to prevent their laundering into the legal trade. Industry emphasised the importance of consistency across the devolved governments and the need to ensure regulation was proportionate to risk, particularly noting concern for the regulation of hybrids.

Preferences varied by sector, with industry preferring options 1, 2 and 4, while NGOs and regulators supported options 1, 2 and 3.

Government response: Strengthen controls for Schedule 4 listed bird species

The government intends to proceed with options 1, 2 and 4. We will amend legislation to implement ring standardisation, which will be published in guidance. We will seek to remove the current registration exemption in place for merlins and peregrine falcons that allows Article 10 certificates to act in lieu of Schedule 4 registration requirements. We will also seek to extend and align the registration time frame for captive bred Schedule 4 specimens. We will also work to provide guidance on the record keeping expectations for breeders of Annex A specimens.

These changes will:

• improve traceability and enforcement, reducing risks of laundering native species
• align regulation with modern breeding practices, supporting compliance and lowering administrative costs
• aid in future digitisation of processes

While we acknowledge full oversight of native specimens and their hybrids aids enforcement. However, the costs and associated administrative burden for industry and the management authority significantly outweigh likely conservation benefit, given hybrid specimens are not naturally occurring in the wild. Option 3 will therefore not be taken forward. Additionally, option 5 will not be taken forward, as responses indicated a strong desire for change.

Industry voiced support for an alternative proposal put forward which emphasised a number of reforms, including cost benefits associated with self-certification. At this time, the risks associated with self-certification are deemed to be too high because of their potential to mask illegality. However, we will continue to consider other proposed reforms, recognising the proposals put forward.

In addition to the options presented, we asked whether guidance on record keeping expectations for breeders of Annex A specimens would be beneficial. Of those that answered, 93% indicated yes. We will, therefore, work to provide guidance on the record keeping expectations for breeders of Annex A specimens.

Article 60 (A60) certificates

Three options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 35 respondents answered this question. Results are summarised in the table below.

Options for Article 60 certificates	Number	Percentage
1. Introduce a validity period, for example 5 years	20	57%
2. Enable revocation where standards are no longer met	24	69%
3. Do nothing	10	29%

Respondents were asked to provide any views or preferences on the options (1 to 3). Several respondents provided views or preferences regarding these options, summarised below. Of these, respondents across a range of sectors but especially among NGOs had selected both options 1 and 2 to work in parallel. Key themes identified were:

• a streamlined process and clearer guidance are needed to support compliance and help organisations avoid unnecessary costs
• validity periods and potential action to revoke an A60 certificate should be aligned with existing processes for licensing, inspection or accreditation
• respondents across a range of sectors supported both options 1 and 2 to work in parallel, referring to a need for improved oversight, traceability and protection of high risk or high value Annex A specimens
• alternative proposals included removing A60 certificates and relying on individual A10 certificates, limiting A60 availability to just institutions engaged in breeding, research or conservation-based education, a validity period of longer than 5 years, and a requirement to provide an annual inventory report

Government response: Article 60 certificates

The government will seek to proceed with option 1 to introduce a fixed validity period for A60 certificates. 

This change will:

• ensure regular review and revalidation of A60 certificates, based on assessments by APHA (as the management authority) in consultation with JNCC or RBG Kew (as scientific authorities)
• encourage improved record keeping and collection management, particularly for higher-risk specimens
• maintain flexibility for institutions while ensuring accountability and compliance

This change takes into account the importance of maintaining a proportionate and effective system for managing Annex A specimens held by eligible institutions such as zoos and museums.

The government will not seek to proceed with option 2. Although this option had broad support from respondents, it would place an extra burden on institutions and authorities by introducing additional checks, beyond the revalidation process that option 1 would introduce. This extra burden would not deliver a comparable conservation and protection benefit to that provided by option 1.

Provisions to better address smuggling post-import

The consultation sought views on introducing additional domestic measures to strengthen enforcement action following entry into the UK. Two options were set out in the consultation. 74 respondents answered this question. The responses are summarised in the table below.

Option to address smuggling post-import	Number	Percentage
1. Introduce additional domestic measures	32	43%
2. Do nothing	43	58%

Respondents were asked to share their views or preferences on the options, as described or if they had alternative suggestions. Key points made were:

• some supported stronger domestic measures to deter illegal trade and align with global best practice; others opposed due to cost, feasibility, and welfare concerns
• administrative burden and compliance costs were flagged, especially for flora and complex supply chains; implementing organisations stressed need for clear guidance and investment
• stakeholders feared penalising those unknowingly acquiring smuggled specimens, with many questioning conservation benefits of post-import controls, preferring stronger border measures, DNA tracing and robust documentation chains
• NGOs urged more funding for enforcement agencies and better use of existing provisions and implementing organisations recommended strict provenance documentation for traders

Government response: post-import smuggling provisions

The responses received indicated that additional policy measures may be required to address issues with the regulation of trade and related activities to effectively deter the smuggling and subsequent utilisation of illegally traded specimens.

However, there was no new information provided or clear consensus among respondents on what measures should be taken. Views were strongly divided, with concerns raised about feasibility, cost, welfare implications, and potential unintended consequences for businesses and individuals.

Given this lack of agreement and the complexity of the issues highlighted, no new domestic measures are currently proposed. Instead, we will continue to work closely with UK CITES authorities and other stakeholders to explore proportionate and practical approaches to strengthen compliance and enforcement within existing frameworks.

Our priority remains to support conservation objectives, uphold international obligations, and ensure that any future proposals are informed by robust evidence and stakeholder engagement.

Registration of facilities that captive breed Appendix I species for commercial purposes in line with CITES Resolution 12.10

Respondents were invited to comment on the UK’s planned implementation of CITES breeder registration. 62 responses were received and the key points made were:

• many respondents reported high administrative and financial burden, and concerns about lack of clarity in requirements
• some questioned conservation value and fairness; others were concerned about the potential impact on livelihoods
• there was also support for registration because it ensures compliance, transparency, and strengthens legal trade
• potential benefits noted were improved species protection, traceability, and streamlined permitting
• several breeders have already registered or intend to register, with mixed experiences of the process for those that have achieved registration
• there were strong calls for clearer guidance and transitional measures
• suggested refinements to the current system included clarifying exemptions for zoos and hobby breeders, aligning UK policy with international practices, and introducing alternative compliance methods such as DNA schemes or interviews

Government response: Registration of Appendix I captive-breeding facilities

The government is committed to fulfilling international obligations under CITES and will implement the recommendations of the CITES Standing Committee. From 1 January 2027, APHA will no longer issue import or export permits for Appendix I species bred for commercial purposes unless the specimen originates from a breeding facility registered in accordance with CITES Resolution Conf. 12.10 (Registration of operations that breed Appendix-I animal species in captivity for commercial purposes).

We acknowledge the concerns raised and will take steps to ensure that the system is proportionate, clear, and effective. The government will take forward measures to provide clearer guidance, reduce complexity and ensure proportional requirements. We will continue to engage with stakeholders to support understanding and practical delivery. Breeders can apply for registration before the requirement becomes mandatory. This transition period will allow time for facilities to apply and for UK Authorities to support the process.

UK domestic stricter measures

Three options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 71 responses were received, and the results are summarised in the table below.

Options for domestic stricter measures	Number	Percentage
1. Introduce a legal provision for stricter measures	19	27%
2. Additional guidance	34	48%
3. Do nothing	33	46%

Respondents were asked to provide any views or preferences on the options as described, including if they had alternative suggestions. Key points made were:

• some respondents support both options 1 and 2 in parallel
• other respondents had polarising views, with many preferring guidance over legislation, citing practicality and lower burden, and a few arguing that legal provision aids trader compliance
• some caveated their support for legal provision with the need for regular review of species listed, and the need for stricter measures relating to species of conservation concern
• most respondents indicated current guidance on UK domestic stricter measures is insufficient

Government response: UK domestic stricter measures

The government intends to proceed with both options 1 and 2. We will seek to amend existing regulations to provide a clear legal basis for the application of stricter measures, and issue comprehensive guidance for their application.

These changes will empower the Secretary of State, in consultation with UK CITES scientific authorities, to publish a formal list of species and specimen types subject to stricter measures and the scope of restrictions. 

We will provide additional guidance to give clarity to stakeholders and practical information for applicants, reducing costs to business and non-compliance. This approach aligns with Article XIV(1)(a) of the CITES Convention, which permits parties to adopt stricter domestic measures.

Revising the criteria for exceptional port of entry (PoE) use

Two options were set out in the consultation. 68 respondents answered this question. Results are summarised in the below table.

Options for exceptional port of entry use	Number	Percentage
1. Introduce a set of exceptional use criteria into the WTR	55	81%
2. Do nothing	13	19%

Respondents were asked to provide any views or preferences on the options as described or if they had any alternative proposals. Key points made were:

• the majority of respondents support amending WTR to allow temporary designation of non-standard ports under clear criteria – this option was seen as practical, transparent and reducing delays, and was strongly backed by small businesses, charities, industry associations and some government bodies
• NGOs and some industry groups warned enforcement capacity is overstretched and called for strict safeguards if implemented
• flexibility was widely seen as critical for welfare-sensitive and urgent conservation shipments, noting temporary ports must have trained staff and proper facilities for live specimens
• alternative proposals included digitisation, flexibility for transport disruptions, restricting temporary PoEs to welfare or conservation cases only, adding more fully designated ports for musicians travelling to and from the EU, and contingency plans for misrouted shipments to prevent destruction of legal consignments

Government response: criteria for exceptional port of entry use

The government will proceed with the proposal to introduce criteria for exceptional PoE use. The regulations will specify that exceptional PoE use can only occur under defined circumstances, notably for non-commercial use and for time bound designations. This facilitates government to respond to rare, unpredictable scenarios, such as emergency conservation situations. The details of which will be set out in accompanying guidance.

This change will provide clarity and a proportionate process, developed in collaboration with APHA, to:

• ensure these requirements are applied consistently
• assess, on a case-by-case basis, if sufficient enforcement resources and facilities can be reasonably provided

This change preserves sufficient flexibility while ensuring that exceptional PoE use remains tightly controlled, justified and subject to clear procedural safeguards.

Amendments to the implementation of Appendix III (Annex C)

Five options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one option. 48 respondents answered this question. Results are summarised in the below table.

Options for implementation of Appendix III (Annex C)	Number	Percentage
1. Remove non-detriment findings (NDFs) requirement for Annex C exports	20	42%
2. Automatically implement Appendix III amendments	24	50%
3. Digitise import notifications	34	71%
4. Remove import notification requirements	13	27%
5. Do nothing	5	10%

Respondents were asked to provide any views or preferences on the options as described or if they had any alternative proposals. They made the following key points.

Some respondents argued that import notifications are onerous, disproportionate, and offer limited conservation benefit, particularly for captive-bred specimens.

Many respondents emphasised that import notifications for Annex C specimens are critical for monitoring trade, detecting emerging conservation risks and informing future regulatory decisions. For example, trade data from import notifications on zebra pleco (Hypancistrus zebra) informed the UK’s position on Brazil’s proposal to list the species under Appendix I at the CITES Conference of the Parties 2019.

Opinions on option 1 (removal of NDF requirement) were divided. Industry representatives and some NGOs view NDFs as unnecessary for Annex C exports. Conversely, implementing organisations and other NGOs strongly oppose removal, warning that it would weaken scrutiny over Appendix III species (many of which are not low-risk and often endangered), making verification of captive-breeding claims essential. NDFs also remain relevant if UK species are added to Appendix III in the future.

Most respondents favour option 3 (digitising import notifications) as a practical solution that enhances data visibility, transparency and traceability, while reducing paperwork and administrative overhead.

Government response: Appendix III (Annex C) implementation

The government will seek to proceed with option 3. We will introduce an online system for submitting import notifications for Annex C specimens as part of the ongoing project to digitise CITES licensing activities.

This change will:

• reduce cost for business and administrative burden
• improve data accuracy
• support real-time monitoring of trade
• complement proposals to digitise import notifications more broadly

Import notifications provide useful oversight and monitoring to allow UK scientific authorities to understand trade volumes, species demand and administrative implications. They reduce administration and cost, while enabling effective and transparent development of evidence-based policy.

We considered removing NDF requirements and import notifications, which would reduce burden, but judged the conservation and compliance risks to be too high. Additionally, retaining the NDF requirement is prudent because it could become relevant if UK native species are added to Appendix III in the future. To ensure proportionality, UK scientific authorities will adopt a risk-based approach to NDFs, placing greater emphasis on legal acquisition findings (LAFs) for low-risk cases where detailed NDFs are disproportionate.

Suspensions regulation (EC Regulation 1587/2019)

Four options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one. 56 respondents answered this question. Results are summarised in the table below.

Options for the suspensions regulation	Number	Percentage
1. Enable Secretary of State to directly publish a list of species-country combinations	40	71%
2. Remove grounds for listing in sub-paragraphs (c) and (d) in Article 4(6) of Regulation 338/97	22	39%
3. Repeal the suspensions regulation and rely on the negative opinions list	25	45%
4. Do nothing	7	13%

Respondents were asked to provide any views or preferences on the options (1 to 4) described, including whether they had any alternative proposals. Key themes included:

• option 1 was widely supported across various sectors, for improving transparency and responsiveness
• there was more limited support for option 2, with some reservations about removing subparagraph (c)
• option 3 was favoured by some businesses and government bodies for flexibility, but there were concerns it could weaken enforcement and legal clarity
• industry and other sectors wanted to avoid penalising legitimate trade, particularly of captive-bred specimens
• NGOs prioritised transparency, responsiveness and precautionary welfare measures
• implementing organisations emphasised transparency and alignment with CITES
• alternative proposals included adding UK restrictions to the Species+ database and amending the wording of Article 4(6)(c) to take a more precautionary approach

Government response: suspensions regulation (EC Regulation 1587/2019)

The government intends to proceed with options 1 and 3. We will seek to make regulatory amendments to enable the Secretary of State, in consultation with the UK scientific authorities, to directly publish a list of species-country combinations for which an import suspension is in place.

This will replace a list of import suspensions set out in regulations, and so accordingly the suspensions regulation will be revoked, while the legal basis for import suspensions (Article 4(6) of Regulation 338/97) is retained.

These changes will:

• remove the need for new regulations each time a listing is updated and align with the UK’s existing negative opinions list
• provide a clear and accessible mechanism for stakeholders, while reducing the administrative burden of maintaining and updating the suspensions regulation

The government will not proceed with option 2. Option 2 had more limited support among respondents, with some raising concerns about the removal of sub-paragraph (c) in particular, which provides for the imposition of restrictions on welfare grounds.

Grounds for application refusal

Three options were set out in the consultation. Respondents were asked to indicate their preferred option and could choose more than one. 78 respondents answered this question, and the results are summarised in the table below.

Options for grounds for application refusal	Number	Percentage
1. Introduce an additional ground for refusal	22	28%
2. Broaden the scope of existing provisions	17	22%
3. Do nothing	49	63%

Respondents were asked to provide any views or preferences on the options (1 to 3) described, including whether they had any alternative proposals. Key themes identified were:

• several respondents emphasised the importance of keeping controls focused on conservation, indicating other controls fall outside of the domestic implementation of CITES provisions – they expressed concern that such changes might allow open-ended discretion to refuse permits or enable political influence, potentially harming trade
• some organisations recommended broadening the scope and providing clearer guidance, suggesting this would reduce time currently spent searching for information
• others highlighted the value of incorporating checks across relevant legislation and policy frameworks, arguing this would lower the risk of inadvertently breaching other applicable laws and prevent the issuance of non-usable permits

Government response: Grounds for application refusal

The government intends to proceed with option 3, noting the limited support and the concerns raised. It remains important for CITES permit applicants to consider if they need to comply with any other controls or legal requirements. We will ensure applicants are advised at the time of issuing a permit on the need to consider any other applicable legislations that may impact the usability of their permit.

Proposed amendments to the CITES fees and charges framework

Background

Fees are charged for current CITES permits and certificates so that providing this service is financially sustainable and paid for by service users rather than out of general taxation. CITES has not yet reached full cost recovery (FCR), but this was proposed in the options set out in this part of the consultation.

Proposed amendments

To support the simplification of fees and move to FCR, 2 options were set out in the consultation:

1. Charge a common fee to all permits and certificates issued (£61 per permit or certificate).
2. Charge a common fee to applications of all types (£200 per application).

Both options would replace the existing fee structure with a single standard permit or application fee. The fee amounts stated for each of these options were based on the current permitting and regulatory regime and were presented as provisional. They did not factor in the effect of the reforms described within this consultation.

Respondents were asked to indicate their preferred option. 72 respondents answered this question. Results are summarised in the table below.

Fees charging options	Number	Percentage
1. Per permit	34	47%
2. Per application	38	53%

Respondents were also asked to provide any views or preferences on the options described including whether they had any alternative proposals. There were 75 responses to this question and the key themes identified included:

• as a rule, low users (individuals and small businesses) preferred option 1 and high users (businesses, organisations and high-volume importers and exporters) preferred option 2
• respondents raised a wide range of concerns about proposed fee changes and permit structures, particularly their disproportionate impact on small traders, hobbyists, large species groups (such as orchids and corals) and conservation activities
• multiple respondents feared unsustainable costs or increased illegal trade
• some argued that fee increases would hinder travelling musicians, proposing that this should not be treated as commercial activities or that musical instrument certificates should have longer durations
• some proposed that fees should be waived for conservation activities
• some supported wider permitting reforms as a means to reduce fee costs
• others highlighted inefficiencies within APHA, suggesting improved efficiency could support FCR

Overall, feedback reflected widespread concern that both options would disproportionately burden small operators while failing to improve efficiency or fairness. 

Most respondents felt that no transitional measures would effectively offset the impact of fee increases. A few suggested that phased increases, subsidies or a 12-month notice period could help smaller operators adapt.

Government response: Amendments to CITES fees and charges framework

The government will apply a two-stage process to reforms of the fees and charging framework at this time:

1. Firstly, we will apply the reforms to the permitting regime as outlined in this government response to the consultation, which will result in an overall reduction in permits and increase efficiency.
2. After this, we will revisit the fees and charging structure based on the reformed permitting regime and the responses to this consultation. This will allow us to take advantage of the efficiencies generated from legislative and administrative changes and ensure fees are accurate. At this time, customers will be notified of both the direction of travel and the proposed timeline to delivery, giving a sufficient notice period prior to changes being applied.

This approach will ensure a sustainable approach to achieving FCR, while accounting for views shared by respondents. It will also allow time to embed further efficiencies within APHA generated through the continued improvements in Pegasus. Provisional fee costs outlined in the consultation were based on the current permit regime, therefore there is a risk that these fees will not achieve FCR under the reformed permitting regime. We, therefore, wish to avoid fee changes which would apply a financially unsustainable approach and likely lead to the need for subsequent fee changes in the near term. The government’s proposed approach prioritises giving certainty to stakeholders and business and avoiding unnecessary costs, particularly noting the strength of concerns and impacts raised within the consultation responses.

APHA would seek to give customers a suitable notice period before any changes are made to the existing fee tables by communicating through usual and established communication channels and would commit to reviewing fees every 2 to 3 years to ensure they remain fair, obtain desired cost recovery and take account of any departmental efficiencies.

Draft statutory guidance for COTES civil sanctions

The consultation included draft guidance on the use of civil sanctions under Control of Trade in Endangered Species Regulations (COTES) 2018. The consultation sought views on whether the draft guidance clearly explains how civil sanctions will be applied once introduced and invited comments on 4 areas:

Key points made were:

• stakeholders welcomed the focus on proportionality, transparency and consistency, and valued the consultation process for raising sector concerns
• civil sanctions were broadly seen as a modern, flexible alternative to criminal prosecution for minor breaches, promoting proportionate regulation
• publishing compliance guidance and recognising sector-specific challenges (breeders, musicians, traders) was viewed as a positive step to avoid penalising legitimate activities
• draft guidance lacks clarity on how civil sanctions will be applied – responses suggested more detail and practical examples
• there was strong opposition to expanding civil sanctions without legislative reform, with concerns about conflating wildlife crime with administrative errors
• breeders, traders and musicians feared penalties for administrative errors or genuine mistakes at the border, while conservation groups worried that sanctions could discourage research
• most respondents rejected new non-compliance categories, with the exception of permit misuse or false information post-reform
• assurance measures proposed included independent oversight, published enforcement data, sector engagement and clear appeal processes to ensure fairness and trust
• respondents also recommended applying aggravating factors (intent, repeat offences, commercial scale) and mitigating factors (self-reporting, prompt correction)

Government response: draft statutory guidance for COTES civil sanctions

The majority of respondents supported the need for statutory guidance on civil sanctions to clarify enforcement powers and ensure proportionality. However, some felt the draft lacked detail on how sanctions would be applied and requested more practical examples.

The government acknowledges these concerns and will update the guidance to reflect feedback by providing clearer explanations and illustrative examples were possible. These will demonstrate how enforcement will be fair, transparent and proportionate, without discouraging compliance or conservation efforts.

The guidance will also clearly set out the appeals process and outline any applicable aggravating and mitigating factors to help demonstrate that decisions reflect the circumstances of each case.

A clear timeline for implementation will be provided ahead of enforcement, and stakeholders will receive updates through established communication channels prior to the effective date.

Next steps

Defra welcomes the comments and information received through this consultation relating to the proposed regulatory reforms to the CITES implementing framework in the UK. We will now seek to take forward the government’s proposed responses. Where legislative changes are required, these will be delivered through statutory instruments, subject to Parliamentary time and scrutiny. Non-legislative changes will be implemented as soon as feasible.

We are committed to keeping stakeholders informed throughout this process, providing clear updates on progress, timelines and any revisions to proposals. These reforms aim to deliver a more efficient, proportionate and transparent CITES framework for the UK, while maintaining strong environmental protections.