The CITES Debacle
The Convention on International Trade in Endangered Species
Nigel Carter
The Salk Institute, La Jolla, California USA

From Forum Vol. 6, No. 5

Every once in a while, all of us interested in the keeping and propagation of tarantulas run up against the CITES regulations regarding members of the only genus currently listed, Brachypelma. CITES was originally signed in Washington, DC in March 1973, and later amended in Bonn in June 1979. Until recently I was relatively ignorant of the details regarding the CITES regulations, but my recent attempts to import various Brachypelma species into the US has cured me of that to some extent.

I relate below some of the things I have learned in this respect. Without the generous help of the following people I would still be in the dark regarding CITES. I am, therefore, very grateful to Rick West, Mark Hart, and Ronald Baxter for discussions and much information on this subject.

The Law

Some definitions for CITES Appendices are:

1. Appendix I shall include all species threatened with extinction which are or may be affected by trade. Trade in specimens of these species must be subject to particularly strict regulation in order not to endanger further their survival and must only be authorized in exceptional circumstances.

2. Appendix II shall include: (a)all species which although not necessarily now threatened with extinction may become so unless trade in specimens of such species is subject to strict regulation in order to avoid utilization incompatible with their survival; and (b) other species which must be subject to regulation in order that trade in specimens of certain species referred to in sub-paragraph (a) of this paragraph may be brought under effective control.

By virtue of their placement on CITES Appendix II (CITES II), the international trade in Brachypelma spp. is highly regulated. Yet unless one is in a position to either import or export Brachypelma spp. then one rarely needs to be concerned with the CITES regulations.

Specifics

The first Brachypelma was listed in 1985 and was Brachypelma smithi. Hence no wildcaught animals were collected and exported out of Mexico without the permission of the Mexican government AND with valid CITES papers after this time. Of course there are always illegally collected animals available from time to time and it is owners of these animals who may experience the long arm of the law. The US Fish & Wildlife service (USF&W) actively pursues buyers of illegally collected and imported animals along with the miscreants involved in collecting and smuggling; BE WARNED!

The articles of the CITES II agreement indicate that it is perfectly legal to breed the animals in captivity, with the progeny being freely saleable within the country in which they were bred. However, one must obtain CITES papers if one is to export the captive bred animals. Currently the fee for obtaining such papers in the US is $25 per each group of each species listed to be exported at one time. Different countries have different regulations, e.g. obtaining CITES papers in the UK is currently free, although this may change quite soon. Regulations in Germany require that each individual animal being exported have its own CITES certificate.

There are also different circumstances involved in obtaining CITES permits for captive bred individuals over the re-export of animals already imported with CITES certificates. One breeder/dealer indicated to me that in the former case, the wait for papers could be up to 180 days and in the latter 10-15 days; quite a difference I think you'll agree!

Many people believe that the CITES II designation covers all Brachypelma species, but this is not the case. In November 1994, nine Brachypelma species were proposed and placed on CITES II. Table 1(a) lists those species. Other species have been transferred to the genus Brachypelma since this listing and it is these species along with newly described Brachypelma species that are not yet covered by Appendix II.

Table 1(b) lists some of the species transferred to Brachypelma or described since late 1994. However, in my dealings with the USF&W they regard ALL Brachypelma spp. to be covered by CITES. After talking to a senior USF&W Inspector recently, I expect that importation of ANY Brachypelma spp. not accompanied by CITES would be a big problem and would doubtless be confiscated at the point of entry to the US.

In at least two cases the water is still muddier. Schmidt & Krause (1994) first erected the genus Brachypelmides and placed a new species in it (B. klaasi). Smith (1994) placed this species into the genus Brachypelma. The nine Brachypelma species proposed were placed in CITES II in November 1994, when B. klaasi was a member of the genus Brachypelmides, NOT Brachypelma at that time. Schmidt (1997) has since described another species in the genus Brachypelmides (B. ruhnaui) which I'm told may be placed, or may already be in by default, the Brachypelma. Hence B. klaasi and the newer species are not listed and no CITES permits are required for captive bred either species' export or import. This does not address the question of whether this animal is really in the genus Brachypelma or Brachypelmides, and suffice it to say that this question will be resolved by expert taxonomists in time, but the species remains in Brachypelma for now. However, even though B. klaasi is not listed as an Appendix II animal, I am now in possession of an authentic CITES certificate for this species, issued in February 1997 in Great Britain!

Conclusions

The main conclusion from all this is that buying or selling captive bred Brachypelma is in no way illegal or even regulated within the country of origin, or if authentic CITES certificates are available. However, there has to be a good degree of caveat emptor when buying that mature female B. smithi for $30, in a paper bag from someone in a back street when the current market value is $150-200. This is not a bargain, but an invitation to lose ALL of one's collection.

Currently the main problem, as I see it, is in the lack of specificity in (a) the listing of Brachypelma species and (b) in the lumping together of ALL Brachypelma species in the eyes of the USF&W. What is needed is some clarification from the administration of CITES regarding which species are SPECIFICALLY listed in Appendix II, and some dissemination of information regarding this listing to both the USF&W and the authorities dispensing CITES certificates.

References
Schmidt, G. E. W. & R. H. Krause. 1994. Eine neue Vogelspinnen-Spezies aus Mexico, Brachypelmides klaasi sp. n. (Araneida, Theraphosidae, Theraphosinae). Stud. Neotrop. Fauna Environ. 29: 7-10.
Schmidt, G. E. W. 1997. Eine zweite Brachypelmides-Art aus Mexiko: Brachypelmides ruhnaui n. sp. (Arachnida: Araneae: Theraphosidae: Theraphosinae). Entomol. Z., Frankfurt 107: 205-208.
Smith, A. M. 1994. Tarantula spiders, tarantulas of the USA and Mexico. Fitzgerald Publishing, London 196 pp.


Later in the ATS Eggsac, Dr. Nigel and the ATS editor had more on the subject.

Who's On CITES And Why?

What is initially needed is a systematic survey of species currently listed under CITES II in the wild. Unfortunately, it is very difficult indeed to obtain funding for this type of work for animals generating public sympathy, let alone enormous hairy spiders believed by many to be deadly! However, until data of this type are available no species will be removed from the CITES listing. One does wonder about the "threatened" status of Brachypelma albopilosum or Brachypelma vagans in the wild, for instance, yet there is such a paucity of good quality public domain data that both will require CITES permits for the foreseeable future.

Other genera may also require studying with regards to CITES listing, although many governments are now placing their own restrictions, at least to some extent, on export of native flora and fauna. These include Costa Rica, Venezuela, Brazil, India, and Sri Lanka among others, all countries with good numbers of theraphosid species.

One genus that does seem to need looking at is Poecilotheria, the ornamental tarantulas of India and Sri Lanka, mainly described by Pocock in the late 1800's. Although the two most common species in captivity, P. regalis and P. fasciata, are routinely bred each year, it would be invaluable to know their current distribution and numbers in the wild. Most other Poecilotheria are much less common in captivity and those that are the wildcaught founders of captive bred stocks are represented by a small number of animals in some cases, which may well eventually lead to significant inbreeding without the influx of genes from the wild.

In the case of P. rufilata it is my understanding that less than 100 individual animals have ever been collected from the wild, hence there is a severely restricted gene pool for this species in captivity. This is quite a rare (and expensive) spider in captivity and very few individuals in the US actually have mature females in their collections. Most if not all the individuals present here have been imported from Europe as spiderlings. It is therefore likely that there are only half a dozen or so distinct female bloodlines present in the US. A tiny number of captive matings have now occurred in the US and it is distinctly possible that the number of generations required before depletion of the gene pool occurs due to inbreeding will be a small number. When coupled with the fact that P. rufilata is extremely rare in the wild, a chilling picture emerges. It is not unreasonable to foresee extinction for species such as this within our lifetimes. Hence if our captive stock does not benefit from introductions to the gene pool we will also eventually lose the captive stock. It is imperative that wild stocks are protected as habitats are plundered and destroyed, hence CITES II listing along with slowing down the arboreal carnage may go some way towards saving members of this genus. I for one would applaud the placement of this genus on CITES II.

Nigel Carter

A response by the ATS editor

CITES was started with the best of intentions by good people who believed in what they were doing. CITES has probably helped a lot with many of the vertebrates. It may also be a good idea for some of the invertebrates. For example, Dr. Polis told me he suspected that emperor scorpions probably were being collected out of certain areas in Africa in numbers that would eventually hurt or wipe out populations. As for Brachypelma, there is no solid evidence that any are endangered. If they are, and the problem is caused by overcollecting, then CITES might help. If they are endangered because of habitat loss, as is likely the case with Poecilotheria, then they should be removed from CITES immediately to allow at least some of their genetic diversity to survive in captivity, even if that's the only place the species will ever exist. Many people have been hurt by CITES rules being bandied about like a club by largely uninformed bureaucrats. I could tell you many horror stories dealing with mistakes being made, such as unasked-for samples of certain Brachypelma being sent to dealers and the trouble they go through, but that's not the point.

Of most concern here is the survival of tarantula species. I've thought about the CITES subject for years, both the potential benefits and negative aspects and have ultimately been led to the same conclusion. When it comes to tarantulas (I'm not in a position to voice an opinion on any other group of animals) all species currently listed in CITES should be removed and clauses should be added prohibiting the placement of any tarantula species on any future CITES list. When all aspects are considered for tarantulas, it appears CITES functions only to worsen the plight of the animals it is intended to protect, and is much more likely to cause rather than prevent their eventual extinction.

Dr. R.G. Breene III
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