Cuba Proposes to Allow Trade in Endangered Hawksbills

The following alert was posted on Turtle Trax in the weeks leading up to the COP10: The 10th Conference of the Parties to the Convention on International Trade in Endangered Species. COPS10 ran from June 8 to June 20, 1997. On June 20, there was good news from Harare: the Cuban proposal was defeated 55-49, which was not close to the two thirds needed to pass. We are proud to report that just before COPS10 began, the Canadian delegation informed us that Canada would oppose the proposal.

We are keeping this page online for the record, and because we suspect that we haven't heard the last of this issue.
Stuffed and laquered juvenile hawksbill, offered for sale as a "souvenir".

Image captured from
"Let Our Turtle Family Live!"
a video by
South Pacific Regional Environment Programme, 1997

The Problem

Cuba is proposing that their population of hawksbill turtles be downlisted from CITES I to CITES II. CITES is the Convention on International Trade in Endangered Species. Under CITES, species listed in Appendix I are threatened with extinction and all trade in these species is banned! Appendix II lists species that will be threatened unless trade in them is regulated, therefore a permit is required.

On June 9, 1997, the member countries that have signed CITES will be asked to move the Cuban population of hawksbill turtles (E. imbricata) from Appendix I to Appendix II. If successful, this would allow Cuba to trade in hawksbill shells, or bekko. Since the only significant market for bekko is Japan, there is speculation that Japan is behind this request and is providing funds in support. Success would also set a precedent that would encourage other countries to seek resumption of the bekko trade.

Worse, the already significant illegal trade in bekko would become much harder to prevent, since there is no way practical way to distinguish illegal hawksbill shell from the proposed legal Cuban shell.

The Action You Can Take

According to comments from Allen Salzberg on the CTURTLE mailing list, the US seems to be the only country in North or South America that is expressing opposition. He states, probably correctly, that mail from the US would probably result in a backlash. Citizens of other countries could make a difference, however, especially citizens of those countries that oppose the American embargo of Cuba. If that's you, please write the ministry responsible for representing your country at CITES and express your opposition to the Cuban proposal. Don't delay, we only have until June 9th.

Action Suggestions for Fellow Canadians

Here's what Canadians can do to help defeat the Cuban proposal:

Our Letter

Here's the letter we've prepared. You can use this as your model, or better yet, write your own.

Dear ---,

I am writing to express my concern regarding the Cuban proposal to transfer hawksbill sea turtles (Eretmochelys imbricata) from Appendix I to Appendix II at the upcoming CITES meeting in June in Harare, Zimbabwe.

The world’s oceans are in crisis, and as a concerned Canadian I fully expect my country to do something about it. I also care very much about sea turtles. They have been around for a hundred million years but all evidence suggests they might not survive man’s greed and indifference to their plight. Few marine creatures are taking the repeated “hits” these beautiful animals do.

They are hunted for their meat and eggs. They are drowned in nets by the world’s fishing industry. They are killed for their shells to satisfy the vanity of the affluent. They are stripped of their nesting beaches by developers. They suffer from international decisions, too often politically motivated or influenced by profit.

But make no mistake, they suffer the most when good people do nothing.

First some facts:

There has to be some point when it’s just got to stop! I urge IUCN Canada to oppose the Cuban proposal because I really believe the hawksbill is in desperate straits. My rationale includes:

Given the factors outlined above, I hope Canadian representatives go into Harare with the same grave concerns I have about the Cuban proposal. Canada must play its part in environmental responsibilty. I believe that should be a leadership role.

Oppose the Cuban proposal to transfer hawksbill sea turtles from Appendix I to Appendix II at the upcoming CITES meeting in June.


Summary of Bekko Trade

The following summary of the IUCN analysis of the trade in bekko was posted to the CTURTLE mailing list by Marydele Donnelly, Program Officer for IUCN's Marine Turtle Specialist Group:

The following information is from the IUCN analysis of the Cuban proposal to transfer hawksbill sea turtles (Eretmochelys imbricata) from Appendix I to Appendix II at the upcoming CITES meeting in June in Harare, Zimbabwe.

The analysis was compiled by IUCN's Species Survival Programme in Cambridge, United Kingdom, with information provided by members of the MTSG and TRAFFIC International, the wildlife trade monitoring arm of IUCN and the World Wide Fund for Nature. The IUCN compiles information on all of the CITES proposals to summarize information for the Parties. The resulting publication is called "Analyses of Proposals to Amend the CITES Appendices." The analyses have been mailed to the Management Authorities of the CITES Parties.

Each analysis has 5 sections: Introduction, Biological Parameters, Utilisation and Trade, Conservation and Management,Additional Remarks, and References. Section 3 on utilisation and trade section 4 on Conservation and Management follow:

3. Utilisation and Trade:

International trade in E. imbricata products in contravention of CITES continues in a number of CITES Parties. Some reviewers caution that the effect of reopening the trade in E. imbricata shell must be carefully considered as this may have implications beyond the scope of a proposed single source and market. In many areas of the wider Caribbean small nations lack the resources and personnel to control shell exports in a manner similar to the controls in Cuba.

Caribbean E. imbricata meat has been harvested for centuries and shell has been a valuable byproduct for international trade. Meylan (1997) comments that the trade in shell now appears to be the driving force behind E. imbricata harvest in the Caribbean. Cuba has been reported as a country of origin in Japanese Custom statistics at least since 1970 (Milliken and Tokunaga, 1987).

As noted in the supporting statement, E. imbricata meat and eggs continue to be consumed within Cuba; although egg collection was banned in 1961 (Anon, 1986). Cuba also supports a small domestic artisan shell industry, and finished goods were observed in tourist shops during the mid-1980s (Anon, 1986); although the majority of shells were exported to Japan until 1992 (Groombridge and Luxmoore, 1989). According to the supporting statement, future shell Utilisation will be restricted to 500 animals per year, 10% of levels previous to 1990, and any additional incidental catch will solely be utilised for the meat.

The discussion of Utilisation in the supporting statement is limited by Cuba's contention that it is the only range State for this population. However, other possible range States in or bordering the Caribbean also support a domestic and international trade in E. imbricata products as evidenced by tourist items for sale in Nicaragua (Campbell, 1997; Lagueax, 1997); Costa Rica, Belize (Chaves, 1997); Dominican Republic (Stam and Stam, 1992; Picon, 1997); Mexico (Carlos, 1997).

Meat is sold in the Bahamas and illegally in Puerto Rico (Picon, 1997), and egg harvest and consumption, although illegal, is widespread in the British Virgin Islands (Eckert et Al., 1992).

Japan has been the world's largest consumer market for E. imbricata shell, referred to as bekko in Japan (Milliken, 1995). An average of 31 tonnes of shell per year were imported into Japan from 1970-1994 (Milliken, 1995). From 1970-1987, more than half of the reported volume originated from Caribbean and Latin American countries (Milliken and Tokunaga, 1987) and an average of approximately 5.4 tonnes per year were imported from Cuba.

Until 1994, both Japan and Cuba maintained a reservation on the E. imbricata listing. In January 1993, Japan prohibited all imports and in July 1994, dropped its reservation. Prior to the 1993 ban, Japan imported 2.9 tonnes of shell in 1991 and 3.6 tonnes in 1992 which were reported by Japan as Cuban in origin, but Cuba did not report these as exports. In 1995, 300 shells were imported into Japan for scientific purposes.

Even though Japanese imports were banned in 1993, a registration system for stockpiles was not instituted until July 1994 when 188 tonnes were recorded. Annual consumption was estimated to be 10 tonnes per year in 1993. Additional markets for E. imbricata products occur throughout the world as evidenced by the extent of illegal trade noted below.

Evidence of illegal trade from Cuba is reflected by the large shipment referred to in the supporting statement, as well as by small shipments of shells and stuffed specimens. CITES Annual Report data indicate that only 28 products originating from Cuba have been seized. As reporting of illegal trade in CITES Annual Reports is very limited and much is tourist specimens, these figures should not be considered as indicative. Carlos (1997) reports that Cuban citizens regularly arrive in Costa Rica with suitcases of tortoiseshell to supply local stores.

Reported illegal take and trade elsewhere in the Caribbean includes: the seizure of 88 hawksbills at the US port of San Juan and 56 at Miami, from 1994 to 1997, (Picon, 1997); the alleged landing of 500 shells in the Dominican Republic in 1995 (Picon, 1997); the illegal fishing of 1,000 E. imbricata per year in Puerto Rico and US Virgin Islands (for meat); and the continuing domestic shell trade in Mexico despite a ban (Carlos, 1997); and 2,000 kg of shell annually exported from Colombia to Venezuela each year (Amorocha, 1997).

Japanese officials have seized 3.3 tonnes of shell since the 1994 removal of its reservation, including: in 1995, 2,700 kg of shell en route from Indonesia (TRAFFIC East Asia - Japan, 1997); 24 kg of shell en route from the Dominican Republic (TRAFFIC East Asia - Japan, 1994); 115 kg of shell en route from Singapore; and 587 kg of shell (Anon, 1994).

There is also evidence of illegal trade elsewhere in Asia, including Indonesia; Taiwan, Province of China, and Australia (Suarez, 1997); the Philippines and Papua New Guinea (Anon, 1996). During the first six months of 1994, the Hong Kong Agriculture and Fisheries Department reported that it had conducted 29 seizures for the illegal import, export, or possession of sea turtle products.

4. Conservation and Management:

A number of Caribbean range states have closed their fisheries (Anguilla, Belize, Mexico, St. Kitts); others (USA, Jamaica, Bahamas) enacted moratoria many years ago. In 1991, Parties to the UNEP Cartegena Convention, including Cuba, voted unanimously to include E. imbricata in Appendix II of the SPAW Protocol, conferring full protectioon for the species in recognition of its endangered status throughout the region. In 1996, the Inter-American Convention for the Protection and Conservation of Sea Turtles was adopted to protect the remaining sea turtle fauna of the Americas. Although E. imbricata benefit from marine protected areas and coastal parks in the Caribbean and some zoning for sea turtles on nesting beaches, the only protected area established specifically for E. imbricata in the region is the nesting beach at Manatee Bar, Belize.

Cuba has enacted numerous regulations on its turtle fishery. But Donnelly (1997) cautions that harvested animals are becoming smaller and questions whether the harvest is managed sustainably. Limpus (1997) comments that, based on a mean age of first breeding at around twenty years, a population of 100 females could not sustain a directed harvest of 500 animals, 100 taken incidentally and an egg harvest. He notes that a nesting population of 1000 females may be able to sustain a harvest of 500 animals and 100 from other fisheries for internal trade. If egg harvest is then added, he expresses doubt in the sustainability of the total harvest. However, he notes that there is no adequate database for any E. imbricata population so an adequate population dynamics model cannot be produced at this time to support this figure as being sustainable.

Ross and Hughes agree that the proposed control and marking system (proposal 8.2 and Annex 9) is adequate for identifying and regulating the sale of Cuban E. imbricata shell. Ross notes that a one-time bi-lateral annual export seems foolproof. He suggests that the reciprocal controls for Japan could be improved by requiring that Japanese processors use the sealed bag and Cuban ID numbers until significant processing into products occurs.

Several reviewers expressed concern about the control of Hawksbill shell imports into Japan. Although the bekko dealers inventoried their stockpile in early 1997, Limpus (1997) notes that quantitative information on shell usage by the Bekko association over the last five years has not been forthcoming and is not available to outside conservation agencies wishing to assess the industrial use of bekko.

Ross (1997) discounts the concerns about illegal trade from accumulated stockpiles and concludes that large seizures of smuggled shell in Japan and the strong condemnation of smuggling by the Bekko Association suggest that illegal trade will decrease in the face of legal trade. In terms of regulating the shell sales, Ross (1997) suggests that these could be improved by requiring Japanese users to continue to maitain the product unit and to record Cuban ID numbers until there is significant processing into products.

According to TRAFFIC East Asia-Japan (1997), Japan's control system is very complex but may not be sufficient for effective monitoring and law enforcement. For example, most importers and wholesalers of raw Hawksbill shell acquired stock as individual scutes rather than whole shells. However, the control system is based on the registration of whole shells. In fact, the Environment Agency has not registered any whole shells pursuant to this legal provision since June 1995 (TRAFFIC East Asia-Japan). On the other hand, there is a requirement for dealers (but not those at the retail level) to report the total weight of their bekko holdings. Through this measure, known as the "notification of dealers," 188 tonnes of raw hawksbill shell and worked products were declared to the collective inventory of 243 dealers.

There are several other flaws in the system preventing close monitoring. Dealers are not required to report regularly on the disposition of shell in their possession, although they are required to present their ledger of transactions to the Government upon request. Furthermore, retail sellers of Hawksbill shell are not required to adhere to the reporting system outlined in Annex 11. Finally, a voluntary management card system has been established under which dealers may choose to attach 'management' cards to pieces of shell as they are sold. However, there is no clear incentive to participate in this system (TRAFFIC East Asia-Japan, 1997). As a result, identifying legally imported from illegal Hawksbill shell is very difficult and may not be possible in many instances.

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Last modified 97/06/21
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