CITES Resources

This is a selective listing of CITES resolutions and other official documents that pertain to PEGAS activities and campaign goals. It is not a comprehensive directory of CITES documents. To view all published CITES resources, visit

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Non-detriment findings  Resolution Conf. 16.7

The Standing Committee will consult with GRASP and other interested parties with a view to establishing an illegal trade reporting mechanism on great apes. GRASP hopes to establish a database to record all great ape trafficking incidents learned of through media reports, official seizure reports, NGO information, etc. PEGAS strongly supports this initiative.

Conservation of and trade in great apes  Resolution Conf. 13.4 (Rev. CoP16)

This is the primary CITES resolution affecting great apes. It contains many recommendations, but the key ones are:

  • a prohibition of all international trade for primarily commercial purposes, including sale, display, purchase, offer to purchase and acquisition for commercial purposes of wild-caught specimens of great apes
  • limiting the international use of great apes to nationally approved zoological institutions, educational centres, rescue centres and captive-breeding centres in accordance with CITES

There are several CITES Party countries that are currently contravening this resolution, including China, Egypt and Thailand. Illegally traded great apes are being displayed in commercial amusement parks or held in unregistered breeding centres.

Registration of operations that breed Appendix-I animal species in captivity for commercial purposes  Resolution Conf. 12.10 (Rev. CoP15)

A common loophole exploited by corrupt CITES Management Authorities is to allow exportation of Appendix I great apes (and other species) for commercial purposes as “bred in captivity” according to the provisions of Resolution Conf. 10.16 (Rev.) (Source Code C), which PEGAS calls the “C-scam”.

To qualify for a C Source Code, however, the breeding centre must be registered with CITES and meet certain criteria. No country has done this for any species of great ape. Therefore, all great apes seen performing or even simply being displayed in safari parks and unaccredited zoos are illegal. CITES has not been enforcing this resolution.

If a breeding centre for great apes is ever registered with CITES, another possibility is the use of the D Source Code, which allows the commercial trade of Appendix I species from “operations included in the Secretariat’s Register”.

Permits and certificates  Resolution Conf. 12.3 (Rev. CoP16)

This resolution defines the Source and Purpose codes that are used in CITES export, import, and re-export permits and calls for a number of items of information and other criteria that should be included with all permits.
Many permits that have been used to traffic great apes are not in conformance with provisions of this resolution. CITES needs to establish a system by which the permits of Appendix I specimens are validated as genuine before export takes place, particularly in the case of live specimens.

Definition of the term “appropriate and acceptable destinations”  Resolution Conf. 11.20

This resolution defines what are “appropriate and acceptable destinations” for traded Appendix II live specimens. Currently this resolution in principle should not apply to great apes, because there are no Appendix II great apes. However, if an Appendix I specimen has been bred in captivity according to the provisions of Resolution Conf. 10.16 (Rev.), it is considered as Appendix II. Should a breeding centre that includes great apes ever be registered with CITES, this resolution would be highly relevant.

The term “appropriate and acceptable destinations” is defined to mean destinations where the Scientific Authority of the State of import is satisfied that the proposed recipient of a living specimen is suitably equipped to house and care for it. This is an extremely weak definition and in the case of countries in which corruption is high, opens the door for legally sanctioned trafficking, as has happened in places like China and Egypt.

This resolution should be revised to set out clear criteria of what constitutes “appropriate and acceptable destinations”, taking into consideration the unusual cognitive abilities and emotional sensitivity of great apes. In fact, if great apes are going to be held in captivity at all, PEGAS would recommend that the only “appropriate and acceptable destinations” would be proper sanctuaries where they could live in social groups largely outside of cages.

Specimens of animal species bred in captivity  Resolution Conf. 10.16 (Rev.)

This resolution sets out the criteria that must be met in order for an animal to be classified as “bred in captivity” for the purposes of applying the C, D or F Source Code. This resolution also calls for all animals bred in captivity to be marked in some manner (e.g. microchip) and that the mark be indicated on the document authorizing the trade (e.g. microchip number be indicated on the CITES export permit). This would allow the identification of individual apes and prevent the practice of certain facilities selling and replacing great apes.

Disposal of confiscated live specimens of species included in the Appendices  Resolution Conf. 10.7 (Rev. CoP15)

This resolution is highly relevant to cases in which countries are holding confiscated great apes, particularly Egypt, which purportedly has confiscated chimpanzees – and gorillas in a more indeterminate circumstance – being held at facilities. The facilities holding the apes are licensed by the CITES Egypt Scientific Authority to do so. CoP15 Doc. 24 Annex 3, submitted to CoP 15 by Egypt, states that since 2007 only three chimpanzees have been confiscated. Others are known to have arrived in Egypt prior to 2007. There are currently at least 36 chimpanzees and five gorillas being held at three private facilities in Egypt. PEGAS believes they all should be relocated to sanctuaries in sub-Saharan Africa, and this resolution provides grounds that would allow this to occur.

Confiscation of specimens exported or re-exported in violation of the Convention  Resolution Conf. 9.9

The resolution states that confiscation of illegally traded specimens is preferable to the refusal to allow the import by the receiving country, and that the country of import should notify the CITES Management Authority of the country of export as soon as possible of the illegal trade. The seized specimen(s) should be returned to the exporting country.

Transit and transshipment  Resolution Conf. 9.7 (Rev. CoP15)

The resolution recommends that while specimens are in transit under Customs control, they “verify the presence of a valid CITES permit or certificate as required under the Convention or to obtain satisfactory proof of its existence”. In addition, “Parties adopt legislation allowing them to seize and confiscate specimens in transit or being transhipped without a valid permit or certificate or proof of the existence thereof.” There are other specifications, but the intention is that active transit airports such as Dubai and Abu Dhabi should begin to take more action to control the passage of illegally traded great apes and other species.

Use of coded-microchip implants for marking live animals in trade  Resolution Conf. 8.13 (Rev.)

Live animals should be marked with non-programmable microchip codes so that they can be identified.

Definition of “primarily commercial purposes”  Resolution Conf. 5.10 (Rev. CoP15)

Appendix I species should not be traded for commercial purposes. An activity can generally be described as “commercial” if its purpose is to obtain economic benefit (whether in cash or otherwise), and is directed toward resale, exchange, provision of a service or any other form of economic use or benefit. Safari/amusement parks and zoos that use great apes to make money are examples of commercial purposes.

CoP Working Documents

Great Apes  CoP16 Doc. 49

Of interest is the World Customs Organization (WCO) Project GAPIN (Great Apes and Integrity), which targets illegal trade in great apes, but includes other species as well. Customs officers from several African countries received training.

Enforcement Matters  CoP16 Doc. 29 (Rev. 1)

Contains a report on Guinea.

Enforcement Matters  CoP15 Doc. 24

Contains reports on Egypt and Nigeria.

Report submitted by Egypt  CoP15 Doc. 24 Annex (begins on page 14)

A section of this document reports on the efforts Egypt has made to implement recommendations the Secretariat requested. There were many administrative actions taken, the most important being the designation of Cairo International Airport as the only import-export port for CITES-listed species. Giza Zoo is the only Egyptian governmental facility authorized to keep confiscated live specimens. Amongst many statements concerning permitting, one stands out: the CITES MA announced that it would return any confiscated specimen to its country of origin if the origin could be confirmed.

Egypt also announced that no private wild animal park would be allowed unless it was registered and subject to inspection with the General Organization for Veterinary Services (GOVS) and the CITES MA. The name, sex and age and route of entry of each specimen should also be registered. All great apes in public and private facilities were now microchipped and registered. Any illegally traded Appendix I specimen in future would be returned immediately to the country of export and reported to INTERPOL. Only three chimpanzees were seized between 2007 and 2010 and presumably being held in the Giza Zoo.

Great Apes  CoP15 Doc. 42

The Secretariat stated that “Illegal trade in great apes continues to present a considerable threat to these species”. The report pointed out that “…the majority of seizures do not appear to be followed-up by adequate investigations or prosecutions…  through a lack of will or interest on the part of enforcement and prosecution authorities, together with problems of corruption.” GRASP was indicated to be the primary UN focal point for law enforcement, working closely with INTERPOL and the WCO.

Egypt  CoP15 Inf. 25

This is a report on the results of a CITES Secretariat mission to Egypt to follow up on a 2007 visit and recommendations that were made for Egypt to clean up its faulty practices related to great apes. The Gauthier Report, the results of the mission, have never been made public. The summary presented in this Information document concluded “The Secretariat found that Egypt had made great progress in implementing the Convention…” Supposedly, “…ownership of all apes previously kept by private individuals and imported into the country illegally has now been transferred to the Egyptian Government” and “the apes have been tagged with a microchip and registered by the Management Authority.” DNA testing of all great apes to establish their origin was supposed to be completed soon.

PEGAS was told in November 2014 during its mission to Egypt that DNA testing was never done, but that microchip implants had been completed (one chimpanzee died as a result). The Government “ownership” of the apes is not recognized by those who hold the licenses to keep the apes. They dispose of them as they please. In addition, the supposedly confiscated great apes kept at the Giza Zoo were not supposed to be displayed to the public, but they still were in November 2014.

Enforcement Matters  CoP14 Doc. 25

The Secretariat issued an alert concerning invalid CITES documents from Guinea.

Great Apes  CoP14 Doc. 50

The matter of Egypt was discussed and a report was expected. A CITES Great Ape Enforcement Task Force was established and plans were made to gather and analyze data on great ape trafficking. GRASP recently informed PEGAS that this task force has become inactive.

Enforcement Matters  CoP13 Doc. 23

Contains recommendations of how to submit information on illegal trade to the Secretariat.

Great Apes  CoP13 Doc. 26

The European Union expressed great concern about the survival of great apes and submitted a draft resolution “Conservation of and trade in great apes”. The Secretariat supported it and suggested minor amendments. This was adopted as Resolution 13.4

Enforcement Matters  CoP12 Doc. 27

Discusses corruption in CITES MA offices and use of fraudulent permits.

(CoP12 and earlier: No great apes reports)

Egyptian Wildlife Report  CoP12 Inf. 29 Annex

Removed from CITES website

Enforcement  CoP11 Doc. 20.1

Problems with erroneous and fraudulent permits.

Enforcement  CoP10 Doc. 28 (Rev.)

Two cases of illegal great ape trade are reported.

Enforcement  CoP9 Doc. 22 (Rev.)

The first report of great ape trafficking from Guinea to Egypt (two incidents in 1992 and 1993). Other reports of great ape trafficking from Rwanda and the DRC to Egypt, involving Egyptian diplomats. In 1994 a chimpanzee and other specimens from Nigeria were seized at the Cairo airport accompanied by a woman trafficker. She tried to use the Nigerian embassy to gain entry of the animals, but failed. PEGAS believes that many of these incidents involved Heba Saad, a notorious wildlife trafficker of dual Egyptian-Nigerian nationality.

Infractions  CoP 8 Doc. 19 (Rev.)

Thailand, and from DRC via Egypt to Japan. Also, a company in Equatorial Guinea, at that time (1991) not a CITES Party, was advertising gorillas and chimpanzees for sale

Standing Committee Meeting Documents


Captive Bred Specimen

Registration of Appendix I Breeding Operations

Great Apes


Enforcement Matters


Captive Bred Species

Great Apes


Enforcement Matters

Great Apes


Enforcement Matters (Egypt statement)

Great Apes


Enforcement Matters

Annex, CITES Egypt Mission Report

SSN’s comments on the CITES Egypt report

Great Apes


Great Apes

Enforcement Matters


Great Apes

Enforcement Matters


Enforcement Matters


Enforcement Matters


Enforcement Matters


No. 2014/017  Missing DRC Permits

No. 2013/017  Suspension of all commercial trade for Guinea

No. 2012/024  Scientific exchanges

No. 2011/052  CITES Security Stamps

No. 2009/009  SSN list of sources of assistance for confiscated live specimens

No. 2001/003  CITES permits and certificates – Involvement of the Secretariat