“Selling like Hot Cakes”
An Invest igation into the Trade in Tortoises i n
Great Britain
A study in 2002 for Defra
By TRAFFIC International
Selling like hot cakes
CONTENTS
INTRODUCTION ............................................................................................................3
BACKGROUND .............................................................................................................3
Laws and treaties................................................................................................3
TORTOISE SPECIES IN TRADE................................................................................4
THE INVESTIGATION ...................................................................................................6
Legal trade, 1996-2001.......................................................................................7
Illegal trade .........................................................................................................11
MARKET DYNAMICS .................................................................................................16
Tortoise prices in Britain ................................................................................18
CONCLUSION ..............................................................................................................18
SOLUTIONS .................................................................................................................19
Informing tortoise buyers, traders and breeders.....................................19
Helping law enforcement................................................................................20
An EU-wide approach......................................................................................20
REFERENCES .............................................................................................................21
ACKNOWLEDGEMENTS ..........................................................................................21
The views of the authors expressed in this
report do not necessarily reflect those of
TRAFFIC International or Defra.
The designation of geographical entities in this
report and the presentation of the material, do
not imply the expression of any opinion
whatsoever on the part of the authors,
TRAFFIC International or Defra concerning the
legal status of any country, territory or area, or
of its authorities, or concerning the
delimitation of its frontiers or boundaries.
TRAFFIC / Defra
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Selling like hot cakes
INTRODUCTION
For many years in Britain there has been a growing interest in reptile keeping, and the
keeping of tortoises as pets in particular. There has also been evidence of smuggling and
illegal trade in tortoises to meet the demand. To date, no studies on the situation nationally
have been undertaken. The UK Government department responsible for the trade in
tortoises, the Department for Environment, Food and Rural Affairs – Defra, commissioned
this study to investigate the trade, both legal and illegal, and to make suggestions on how to
improve any problems found. TRAFFIC has researched the trade for Defra and the summary
of the findings is included here.
BACKGROUND
The keeping of tortoises in Britain has been popular over several decades and demand has
escalated with the increasing trend for keeping reptiles as pets. This has influenced the
trade, encouraging breeding and importation, as well as illegal trafficking. Even with a
responsible, largely law-abiding pet trade in Britain, a significant amount of illegal trade in
tortoises still occurs and consumers are unwittingly supporting this detrimental and criminal
trade.
It is very difficult to estimate the true levels of tortoise imports into Britain, both legal and
illegal. The removal of internal European Union (EU) trade borders has meant that
consignments of tortoises that formerly required permits to be traded between EU countries
can now move legally between them without the need for these. It is known that such
consignments have come from mainland Europe to Britain since the removal of internal
borders in the EU. This places more emphasis on the need to enforce the law at points of
sale within Britain and at the same time makes this task more difficult.
Tortoises are sold in Britain not only in pet shops, but also at garden centres, DIY stores and
through classified advertisements in specialist magazines and local newspapers. Tortoises
are also sold through an informal sales network of breeders and their contacts, interest
groups and trade fairs. Specialist tortoise keepers play a significant role in the tortoise trade,
by driving demand for rarer species and new blood lines, but also by supplying captive-bred
stock to meet demand that normally would require taking animals from the wild. The number
of tortoise breeders is increasing, but these breeders are unable to meet the demand for
captive-bred tortoises in Britain. This low level of legal supply creates a market opportunity
for unscrupulous dealers to trade in illegal wild-caught tortoises. The scarcity of fertile
females to broaden gene pools has been a particular incentive for breeders to collect
tortoises illegally from the wild and smuggle them from their country of origin.
Most tortoises that are kept as pets come from the family
Testudinidae, which includes 44 tortoise species. The whole family
is covered by an international treaty on trade in wildlife, called the
Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
The Testudinidae family is listed in Appendix II of CITES, which means that commercial
international trade in ‘Appendix II species’ is allowed, if accompanied by the correct permits.
A number of rarer species (listed in Appendix I) receive a higher level of protection under
CITES. Commercial trade in these ‘Appendix I species’ is allowed only for captive-bred
specimens or specimens imported prior to the species being listed in Appendix I.
LAWS AND T REATIES
The EU applies the CITES treaty through its own wildlife trade regulations. The EU
regulations list protected species in four annexes (A, B, C and D), with Annex A species
being the most protected. Requirements under these EU regulations are sometimes stricter
TRAFFIC / Defra
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Selling like hot cakes
than those of CITES. Some Mediterranean tortoises, for example, can be traded according to
CITES, but are banned from commercial trade by EU regulations. A European import ban on
wild-caught Mediterranean tortoises came into force in 1984, with only captive bred or pre
ban tortoises being allowed to be traded. This ban caused an increase in trade of African and
Eurasian tortoise species into Europe instead. With this shifting of pressure to new species in
trade came the need for protection of a wider range of tortoises. As a result, in February
1999, wild-caught specimens of a further 18 tortoise species were banned from import into
the EU. Only captive-bred tortoises or those imported before the ban of these 18 species are
now allowed in commercial trade.
It is illegal to trade wild caught species listed on Annex A. Only captive bred individuals are
allowed in commercial trade, and only if an EU sales exemption certificate accompanies them
(called an “Article 10 Certificate”). An Article 10 Certificate is valid for one transaction only
and a further certificate is needed for any subsequent trade, unless a specimen can be
“uniquely marked” (i.e. with a microchip implant in the case of tortoises). The majority of
tortoises on sale in Britain requiring Article 10 Certificates are of a size smaller than is
recommended for the insertion of a microchip (i.e. have a shell length of under 10 cm) and,
therefore, a new certificate is needed for each sales transaction.
As all species popular in the tortoise trade are banned from import to Britain if wild-caught,
only captive-bred or tortoises imported before the bans should be found in trade in Britain.
TORTOISE SPECIES IN TRADE
Trends in keeping a particular species of tortoise appear to be more affected by availability
dependent on legislation than by the popularity of any given species. In 1998 more
Horsfield’s Tortoises were sold in Britain than any other species of tortoise. But since wildcaught Horsfield’s Tortoises were banned from trade in 1999, there has been a resurgence of
trade in captive-bred Spur-thighed and Hermann’s Tortoises, to fill the gap in the market
brought about by this ban.
Hermann’s Tortoises are the most commonly purchased
tortoise in Britain today and are kept as pets and by
specialist keepers. At one time hundreds of thousands of
these tortoises were removed from their habitat in southeast Europe every year and exported to Britain and northwest Europe for the bulk pet trade. Since the ban on their
collection from the wild in 1984, wild populations have been
recovering. They inhabit Mediterranean countries including
France, Spain, Italy, Greece and Romania. Wholesale prices can be as low as £50 and retail
prices as high as £250 per tortoise.
From 1969 to 1972 a total of 480,000 Spur-thighed Tortoises were
imported into Britain. Between 1972 and the 1984 ban on imports of wild
Mediterranean tortoises, thousands of Spur-thighed Tortoises were
brought from the wild into Britain each year. The population of the
species in the wild is estimated to be three million. Spur-thighed
Tortoises are distributed in Mediterranean countries, parts of the Russian
Federation, Iran and Iraq. Wholesale prices start at £60 and retail prices
can reach £300 or more for an adult breeding female.
TRAFFIC / Defra
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Selling like hot cakes
Marginated Tortoises have a limited distribution in the wild,
existing only in Greece and parts of Albania. They have a very
long shell, growing to a length of 25-30 cm. No wild-caught
Marginated Tortoises should be on sale in Britain, unless they
were brought into the country before the import ban in 1984.
Breeding of Marginated Tortoises is now on the increase and
juvenile captive-bred tortoises can be found on sale. Prices
range from £60 wholesale to £275 retail.
Horsfield’s Tortoises have a wide distribution in Central Asia
where they occur throughout their range at low densities, yet the
area is so vast that the population is estimated in the millions.
Horsfield’s Tortoises differ from other tortoises by having a low
tolerance to damp climates and rain, although extreme temperatures
are less problematic as long as they are kept dry. Consequently,
keeping them successfully in captivity requires a high level of
expertise as well as suitable housing facilities. Because of the import
ban in 1999, no wild-caught Horsfield’s Tortoises should be on sale in Britain today unless
they were imported before that year. Prices range from £60 wholesale up to £300 retail.
Leopard Tortoises are imported in the hundreds every year to
Britain, and the majority are sourced from the wild. These
tortoises grow up to 60 cm in length and can weigh up to 40 kg.
They originate in eastern and southern Africa. There is an import
ban on wild Leopard Tortoises from the Central African Republic,
Mozambique, Tanzania and Zambia. Prices start from £125.
Hingeback tortoises come from Africa. Wild-caught
individuals have been banned from trade in Britain since 1999.
These species are not seen very frequently in trade and require
specialist conditions to be kept in Britain. The species depicted
here is the Home’s Hingeback Tortoise, which comes from
West Africa.
The African Spurred Tortoise is the largest mainland
tortoise, with some adults reaching over 70 cm in length and
weighing over 45 kg. It is estimated that no more than
20,000 individuals remain in the wild today. Due to its large
size it can be destructive if confined and needs large areas
dedicated to it. African Spurred Tortoises occur in countries
in North Africa, including Egypt, Sudan, Mauritania, Ethiopia
and Eritrea. No recently imported, wild-caught individuals
should be in commercial trade as the countries in which the species occurs have stopped
exports since 2000. Prices can be as little as £80 wholesale for one tortoise, with retail prices
up to £2000 for a pair.
The Red-footed Tortoise comes from areas of high humidity and will
dehydrate rapidly. It ranges across South America and the Caribbean.
These tortoises grow to be quite large (length 45 cm) and because of
this, a smaller race of the species is growing in popularity. These
tortoises are mainly ranched in South America and shipped to Europe for
sale. Wholesale prices begin at £75 and retail prices are up to £400 for
an adult.
TRAFFIC / Defra
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Selling like hot cakes
Indian Star Tortoises are under threat from the destruction of
their habitat and their collection from the wild for the pet trade.
They are not easy to keep in captivity and suit only specialist
keepers. They are banned from import from the wild, and have a
restricted range in only India, Pakistan and Sri Lanka. Wholesale
prices start at £250 and retail prices at £1200 a pair.
Endangered species that are sought after for their rarity occur in illegal trade. These include
species such as the Pancake Tortoise, Kleinmann’s (Egyptian) Tortoise, Radiated Tortoise
and Plowshare (Angonoka) Tortoise. There is very rarely any legal trade in captive-bred
individuals of these species.
Pancake Tortoises have a limited distribution, occurring only in
Kenya and Tanzania, and have rigid habitat requirements, living
where rock crevices of suitable dimensions are found. This, along
with a low reproductive rate, means their population is heavily
impacted by any collection from the wild. Only captive-bred
Pancake Tortoises should be on sale in Britain, if any breeders have
succeeded in breeding them. Because of this and their limited
numbers in the wild they are rarely seen in trade and are priced accordingly, between £1500
and £3000 each.
Kleinmann’s Tortoise is very rare and threatened with extinction.
It is found only in Libya and Egypt, with only a very small population
still surviving in Egypt. While there appears to be a larger population
in Libya, numbers there are declining rapidly because of illegal
trade. Kleinmann’s Tortoises will not be found legally in commercial
trade in Britain.
The Radiated Tortoise and Plowshare Tortoise are
endemic to Madagascar and have very small and fragile
populations. The Plowshare Tortoise is perhaps the most
endangered tortoise in the world, with only a few hundred
tortoises remaining in the wild or in conservation
programmes. Habitat loss and collection for the specialist
trade threaten both species. Individuals are valued at many
thousands of pounds, but these tortoises should not be found legally in commercial trade in
Britain.
THE INVESTIGATION
Information was obtained from a range of sources during field investigations and desk-based
study. The methods used included:
Analysis of CITES and UK Government databases for information on trade in species listed in
CITES and under EU regulations. This involved looking at imports and exports, as well as
sales in Britain.
Analysis of illegal trade information from a number of sources including Her Majesty’s
Customs and Excise (HMCE) seizures data, the CITES database of seizures data, and other
instances of documented enforcement in Britain, such as prosecution cases.
Surveys of tortoise traders to estimate the level of illegal trade in Britain.
TRAFFIC / Defra
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Selling like hot cakes
Studies of the trade routes used to bring tortoises into Britain, based on information from the
HMCE CITES Team at Heathrow Airport, from tortoise traders and from analysis of British
and EU seizures data.
Analysis of the licensing system used by Defra to permit imports, exports and sales of
tortoises in Britain. The study looked for potential abuses of the licensing system and
difficulties traders may have with the system.
Studies of the market dynamics for tortoises, looking at prices and availability, and the
influences of supply and demand.
LEGAL TRADE, 1996-2001
Within the EU, Britain is the fourth-largest importer of tortoises, after
France, Spain and Germany. The term ‘import’ refers to the import of
tortoises into Britain from countries outside of the EU. Figures were
obtained from the CITES database and Defra’s database. Any movement of animals within
the EU under CITES is not considered an import. Britain has followed European trends, with
imports showing an increase from 1992 to 1998, a relative decrease in 1999 and 2000, and a
rise again in 2001. The year of peak imports during the period 1996-2001 was 1998. Total
annual tortoise imports by year are illustrated in the bar chart below.
Volume of trade
T otal Brit ish imports of tortoises 1996-2001
6000
5000
4000
3000
2000
1000
0
1996
1997
1998
1999
2000
2001
Overall, during the period 1996-2001, 98% of tortoises were
imported for commercial trade. Although the primary purpose of
import for all species other than Horsfield’s Tortoises in 1996 and
1997 was recorded as “personal”, this situation changed markedly in 1998 and 1999, when
nearly all imports were reported to be for trade purposes. The vast majority of imports in
these years were of Horsfield’s Tortoises. Following the ban in imports of wild individuals,
imports of Spur-thighed and Hermann’s Tortoises to Britain rose in 2000 and 2001, almost
entirely as a result of demand for commercial trade.
Purpose of imports
The majority of tortoises imported into Britain are destined for the domestic market, not for
re-export. This is illustrated by the import data for 1996 to 2001. Britain imported a total of
TRAFFIC / Defra
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Selling like hot cakes
14,812 live tortoises, of 16 different species; yet by comparison exported a total of only 155
live tortoises of 13 different species (mainly to Japan and the USA).
Tortoises of wild origin dominate the trade for the period 1996-2001,
with 80% of tortoises imported recorded as wild-caught up until
2000. This proportion dropped to 65% in 2001, by which time
imports to the EU of most wild-caught tortoise species in trade had been banned. In 2001,
1494 Spur-thighed Tortoises were imported from stocks declared to be captive-bred in the
Lebanon and 467 Hermann’s Tortoises from such stocks in Slovenia. The almost triple-fold
increase in tortoise imports to Britain from 2000 to 2001 was largely accounted for by this
trade. Since June 2002, 1250 Hermann’s Tortoises have been imported commercially from
captive-bred stocks.
Source of imports
Total imports of Horsfield’s Tortoises (numbering 5911) were
more than double those of any other tortoise species for the
period 1996-2001. The next most heavily imported species was
the Leopard Tortoise, followed by the African Spurred Tortoise. Imports of Spur-thighed
Tortoises and Hermann’s Tortoises rose sharply after the importation of wild-caught
Horsfield’s Tortoises was banned in 1999. Numbers of all other main tortoise species
imported to Britain during the period were in quantities under 1000 and in several cases
under 100 (see table below).
Main species imported
Brit ish imports from outside the EU of the main tortoise species in trade 1996-2001
Common name
(Tortoise)
Scientific name
Elongated
Pancake
Spur-thighed
Hermann’s
Kleinmann’s
Marginated
Horsfield’s
Indian Star
Aldabran
Red-footed
Yellow-footed
Leopard
African Spurred
Bell’s Hingeback
Serrated Hingeback
Home's Hingeback
Indotestudo elongata
Malacochersus tornieri
Testudo graeca
Testudo hermanni
Testudo kleinmanni
Testudo marginata
Testudo horsfieldii
Geochelone elegans
Geochelone gigantea
Geochelone carbonaria
Geochelone denticulata
Geochelone pardalis
Geochelone sulcata
Kinixys belliana
Kinixys erosa
Kinixys homeana
TRAFFIC / Defra
8
EU
Annex
Number
imported
A
A
A
A
A
A
B
B
B
B
B
B
B
B
B
B
100
40
1546
1082
8
25
5911
36
22
789
122
2891
1793
233
86
128
14,812
1984
Import
Ban
1999
Import
Ban
?
?
?
?
?
?
?
?
?
?
?
?
?
Selling like hot cakes
Brit ish imports from outside the EU of T estudo tortoise species 1996-2002
4000
Spur thighed
3500
Hermanns
Horsfields
3000
Kleinmanns
2500
Marginated
2000
1500
1000
500
0
1996
1997
1998
1999
2000
2001
2002
The
usefulness
of
Article
10
Certificates as a means of investigating
tortoise trade in Britain lies in their
ability to indicate a whole category of trade that would otherwise go completely unrecorded.
The graph below gives the number of Article 10 Certificates issued each year, 1996-2002, for
three CITES Appendix II/EU Annex A tortoise species – Spur-thighed, Hermann’s and
Marginated Tortoises. As an Article 10 Certificate must be issued each time a tortoise is sold
(unless microchipped, which can only be done when the tortoise shell is longer than 10 cm),
the graph does not show actual numbers of these tortoises in trade. From the information
gathered during this study, it is evident that tortoises can be sold between traders three or
four times from point of entry into Britain to final destination. However, it is also evident that
many businesses do not transfer Article 10 Certificates into their own name prior to sale and
these transactions would not then be recorded by Defra.
Case study: the role of Article 10 Certificates
T otal Brit ish Art ic le 10 Certif icates issued for spur-thighed, Hermann’s and Marginated
T ortoises 1996-2002
4000
Spur thighed
Hermann’s
3500
3000
Marginated
2500
2000
1500
1000
500
0
1996
TRAFFIC / Defra
1997
1998
1999
9
2000
2001
2002
Selling like hot cakes
Despite these caveats, it is possible to have a greater understanding of trade in these
tortoises in Britain from these figures. For example, CITES data, which only show numbers of
these tortoises imported into Britain from outside the EU, record that fewer than 50 Spurthighed, Hermann’s and Marginated Tortoises combined were imported directly into Britain
from 1997 to 1999. By contrast, the number of Article 10 Certificates issued for sales of
these three species each year between 1997 and 1999 was 2000-3000. In other words,
CITES data show an average of 12 of these tortoises entering Britain between 1997-99 from
outside the EU, while during the same time approximately 8000 Article 10 Certificates were
issued for these same species. Captive-breeding capacity for these three species in Britain
during the years in question can only account for 6000 of the certificates issued. Therefore,
the remainder of 2000 must represent tortoises that entered Britain either illegally or legally
from another EU country (in which case no import permits would be required on entry to
Britain). An alternative scenario is that breeders in Britain are over declaring the numbers of
tortoises they are breeding and supplementing their stock with illegally taken tortoises,
which are legitimised through the licensing system.
From 1999 to 2002, the number of certificates issued was higher than in previous years and
at the same time Defra data shows imports of captive-bred Spur-thighed and Hermann’s
Tortoises from outside the EU increased. Information provided by traders interviewed during
this study indicates that numbers of tortoises coming into Britain from the EU also increased
during the period 2000-2002. According to these traders, at least 1000 Spur-thighed
Tortoises and 1000 Hermann’s Tortoises were brought into Britain from other EU countries in
2001. Judging from this information and CITES data, this would mean that at least 3500
Spur-thighed and Hermann’s Tortoises were brought into Britain in 2001 – all reportedly
captive-bred from sources outside Britain. Adding to this the number of applications received
from British breeders, brings the total number of tortoises with Article 10 certificates on sale
in Britain in 2001 to over 6000.
Article 10 Certificates are useful as an indicator of increased captive-breeding of tortoises
within Britain. There has been an overall increase in the number of Article 10 Certificates
issued to British breeders for Spur-thighed, Hermann’s and Marginated Tortoises from 1996
to 2002 (see graph below).
Brit ish breeder Art ic le 10 certif icate applicat ions for Spur-th ig hed, Hermann’s and Marginated
T ortoises 1996-2002
1800
Spur thighed Tortoise
Hermann’s Tortoise
Marginated Tortoise
1600
1400
1200
1000
800
600
400
200
0
1997
TRAFFIC / Defra
1998
1999
10
2000
2001
2002
Selling like hot cakes
Shipments of tortoises arriving from outside the EU are
usually transported by air into Britain. These shipments
are accompanied by import and export permits, to be
cleared through Customs. Prior to September 1999, air shipments containing Horsfield’s
Tortoises were entering Britain from the Ukraine and from Uzbekistan. In 2000, the majority
of air shipments of tortoises were of Hermann’s Tortoises from Slovenia and in 2001 air
shipments comprised both Hermann’s Tortoises from Slovenia and Spur-thighed Tortoises
from Lebanon.
Legal trade routes to Britain
Trade within the EU is predominantly transported by road. British traders travel to mainland
Europe to collect their orders. This is often timed around one of the major annual reptile
shows that take place in the Netherlands or Germany. Large numbers of tortoises as well as
other reptiles are purchased at these shows and then transported back to Britain for onward
sale. Traders from Britain will either use the ferry or channel tunnel as their access point to
the European mainland. Travel time rarely exceeds 12 hours from Germany to London and is
less from the Netherlands. As this trade is within the EU, no import or export permits are
required to move the tortoises to Britain. However, as they are being transported for onward
sale, all captive-bred tortoises should be accompanied by Article 10 Certificates.
Wild-caught tortoises listed on EU Annex A or otherwise banned from
import are still entering the pet and specialist collectors trade in Britain.
These tortoises are smuggled to Britain from their countries of origin,
often concealed in luggage. When young, tortoises are very easy to smuggle, being small,
quiet and fairly still; they can also survive for relatively long periods in confined conditions
without food and water. These smuggled tortoises either go directly to specialist keepers or
are laundered into the pet market where they can be sold as captive-bred animals from
British or other European breeders.
ILLEGAL TRADE
Smuggling in Europe
that have taken place.
Seizures that have occurred throughout Europe give an indication
of the existence of this illegal trade, though it is known that much
is not detected. Below are a few examples of the types of seizures
1999 A German smuggler was convicted in South Africa for exporting Angulated
Tortoises without the necessary permits. The tortoises had been packaged in
parcels to be sent by airmail to the smuggler's home address.
G
Geerrm
maannyy
December 1996 Customs seized 204 Hermann’s Tortoises, 198 Horsfield’s Tortoises, 26
Spur-thighed Tortoises and 47 Kleinmann’s Tortoises that were hidden in two vehicles being
driven from Poland to Germany by Polish nationals.
July 1996 Customs confiscated three Radiated Tortoises, 282 Horsfield’s Tortoises, 30
Hermann’s Tortoises, 22 Spur-thighed Tortoises and five Indian Star Tortoises. The tortoises
had been smuggled into Germany by four Slovakian nationals and were to be sold to reptile
traders and private collectors. The tortoises were wild-collected.
March 1998 As a result of search warrants on a reptile trader, 282 live and 92
dead reptiles were seized. These included three Plowshare Tortoises, one
Radiated Tortoise, 17 Kleinmann’s Tortoises, 20 Marginated Tortoises, five Spider Tortoises
and four Horsfield’s Tortoises. The majority of the tortoises had been imported illegally from
the Czech Republic and false documents had been used to legalise the transactions prior to
their redistribution to buyers in the EU. The illegal trader had declared the tortoises were
captive-bred to the Belgium authorities and applied for Article 10 Certificates to legitimise the
BBeelg
lgiu
ium
m
TRAFFIC / Defra
11
Selling like hot cakes
sale. Plowshare Tortoises are the rarest tortoises in the world with only several hundred
remaining in the wild in Madagascar.
May 1999 Customs seized 450 live tortoises, which had been smuggled from
Madagascar in false-bottomed bags by three Malagasy nationals living in Paris. The
tortoises smuggled were 120 Radiated Tortoises and 330 Spider Tortoises, which were to be
sold to traders in Germany and the Netherlands.
FFrraannccee
June 2001 Customs seized 649 Spur-thighed and Kleinmann's Tortoises from two
Lithuanians who had flown from Syria. The animals had been transported in small
cages that were wrapped with plastic bags and hidden in hand luggage.
PPoola
lanndd
The table below provides a summary of known
tortoise seizures in Europe from 1994 to 2001 and
includes the figures for Britain. Nearly 7000 tortoises
were seized in this period, evidence of a large illegal
trade in tortoises, especially since these seizures
represent only a small portion of the actual illegal
trade that occurs.
Recorded seizures in Europe 1994–2001
Common name
(Tortoise)
Elongated
Pancake
Spur-thighed
Hermann’s
Kleinmann’s
Marginated
Horsfield’s
Indian Star
Radiated
Red-footed
Plowshare
Leopard
Bells Hingeback
Spider
Unknown
Scientific name
Indotestudo elongata
Malacochersus tornieri
Testudo graeca
Testudo hermanni
Testudo kleinmanni
Testudo marginata
Testudo horsfieldii
Geochelone elegans
Geochelone radiata
Geochelone carbonaria
Geochelone yniphora
Geochelone pardalis
Kinixys belliana
Pyxis planicauda
Unknown species
EU Annex /
CITES Appendix
B / II
A / II
A / II
A / II
A/I
A / II
A / II
B / II
B / II
B / II
A/I
B / II
B / II
B / II
A & B / I & II
Total
Total
50
43
1287
1187
117
106
2239
52
212
161
6
321
28
340
496
6645
CITES trade data for seizures are far from
complete. According to these data, only
370 tortoises, comprising nine species,
were confiscated between 1996 and 2001 at British points of entry. More accurate
confiscation figures were obtained from HMCE. These report 1808 tortoises of 17 different
species confiscated between 1996 and 2001 – almost five times the number reported by
CITES data. In 2002 alone, a further 499 tortoises have been confiscated.
Seizures of smuggled tortoises in Britain
TRAFFIC / Defra
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Selling like hot cakes
Seizures have primarily been of tortoise species most in
demand in trade; the top five in terms of numbers seized
are Spur-thighed, Hermann's, Horsfield's, Leopard and
Red-footed Tortoises (see table below).
Seizures of tortoises by Brit ish Customs 1996-2002
Common name
Elongated
Pancake
Spur-thighed
Hermann’s
Kleinmann’s
Marginated
Horsfield’s
Indian Star
Argentinean
Red footed
Yellow-footed
Leopard
Hingeback
Unknown
EU
Annex
A
A
A
A
A
A
B
B
B
B
B
B
B
A/B
Total
1996
0
1
10
1
0
0
0
0
1
13
16
101
25
7
175
Year
1997 1998 1999 2000 2001 2002 Total
0
50
0
0
0
0
50
0
40
0
1
0
0
42
19
14
23
14
44
3
124
169
13
0
121
5
0
309
3
2
2
2
3
0
12
0
3
0
8
49
0
60
1
15
20
1
710
0
747
20
6
0
0
0
1
26
0
0
0
1
0
1
2
0
0
18
0
1
1
32
0
0
1
0
0
0
17
108
0
0
0
112
384
321
0
2
0
0
0
95
27
0
7
25
0
0
14
39
320
152
89
148
924
499
2307
There is a trend in Britain towards acquiring tortoises
from other countries within the EU, rather than
importing them direct from countries outside the EU. As
there is no need for permits to move tortoises between EU countries and as there is an
enormous volume of goods moved within the EU, this reduces the chances of detection for
any illegal trader. Seizures information shows that illegal importations have been attempted
into the EU from the following countries: Argentina; Czech Republic; Madagascar; Poland;
Slovakia; South Africa; Syria; Tajikistan; Tunisia; Turkey and the former Yugoslavia.
Illegal trade routes to Britain
These tortoises were to be sold to reptile traders and private keepers. Illegal trade in wildcaught tortoises native to EU countries also takes place and a number of tortoise species
found in trade are found in the wild in Greece, France, Italy and Spain.
Tortoises are smuggled by a number of different transportation methods and concealed in a
variety of ways. Frequently tortoises are concealed in people’s personal luggage, which is
then transported across borders by car, bus, train, ship and even aboard commercial airlines.
False-bottomed bags have been used, as has concealment on the person under clothes or
within hand luggage. Alternatively, tortoises have been discovered concealed in cars and
vans. Smuggling techniques include hiding tortoises under false floors in trucks, inside the
interior coverings of caravans and behind car seats and in car doors. One large seizure in the
UK of over 650 Spur-thighed Tortoises involved the concealment of the tortoises in various
hiding places on a cargo ship by its crew. There have also been instances of tortoises being
packaged in parcels and sent by post or international courier services.
TRAFFIC / Defra
13
Selling like hot cakes
Evidence of illegal trade has come from a number of
investigations carried out in Britain prior to and during this
study, and includes the detection of large-scale illegal imports of
tortoises and of wild-caught tortoises being sold as captive-bred animals. Awareness of the
licensing system in Britain and the rest of Europe is increasing amongst traders. Although
there are instances where tortoises are offered for sale with no certificates at all, it is now
more common to find that a certificate accompanies a tortoise but the certificate does not
correspond to the tortoise being sold (e.g. the age of the tortoise given on the certificate is
not appropriate for the size of the tortoise). Sometimes, certificates may be obtained
fraudulently by declaring to the issuing authority that the tortoises are captive-bred, when in
fact they are wild-caught.
Illegal sales in Britain
As wild-caught specimens of all
tortoise species popular in trade are
now banned from import to Britain,
only captive-bred or pre-ban
tortoises should be found in British
trade. This system for licensing
tortoises in Britain relies on a
certain level of honesty from licence
applicants and is therefore open to
abuse. Reports by the police and
organisations such as TRAFFIC, the
Tortoise Trust and the RSPCA,
document that certificates are being
duplicated,
forged
and
used
fraudulently. For most species, it is
not until they are three to five years
old that they are large enough (with
a shell length greater than 10 cm)
to be microchipped. Therefore, wildcaught Annex A tortoises under 10
cm in length can be laundered into
the market with Article 10
Certificates under the guise of being
captive-bred, as they are not
uniquely marked. Once they are
uniquely marked with a microchip,
the microchip code is recorded on
the certificate and the microchip
code in the tortoise must match
that on the certificate.
The role of tortoise keepers in licence fraud
The keepers of tortoises, whether pet-owners or breeders, are often
unwitting perpetuators of the illegal tortoise trade. There are many
known instances where someone looking for a pet has purchased a
tortoise in good faith from a pet shop, specialist reptile shop, or from
a personal contact, and has been totally unaware that their purchase
is illegal. Those new to keeping tortoises often rely on those selling
them to inform them of how to care for the tortoise and of the
necessity for any permits. Few members of the public would think to
check whether the tortoises being sold were legal or not and there is
often a general assumption amongst the public that if something is
on sale, particularly in a pet shop, then it is legal. This lack of
awareness by buyers assists unscrupulous dealers in their illegal
trade. During this study there were a number of instances where
traders did not inform the buyer about the need for an Article 10
Certificate unless the buyer specifically asked about it. Some traders
stated that if a buyer did not request an Article 10 Certificate, then
the sale would proceed regardless and the unused certificate would
be kept for use with a tortoise that had been acquired illegally. In this
way, illegally sourced tortoises are legitimised into the trade. This
only becomes evident when the details on the certificate – such as
the age of the tortoise - are noticeably different from the tortoise it
accompanies. Evidence of illegally sourced tortoises being in the
trade can become known when the purchaser has the tortoise
examined by a vet. It is often the case that wild-caught tortoises
show signs of illness when brought into captivity, such as runny nose
syndrome or passing worms, and many purchasers have been
informed by their vets that, in their opinion, the tortoise they have
been sold is wild-caught. Other tortoise owners only become aware
that they have bought an illegally sourced tortoise when they come
to sell it. When a prospective buyer requests an Article 10
Certificate, this can be the first time the tortoise owner realises that
this should have been supplied at the time he or she purchased the
animal.
This state of affairs is not helped by
the fact that the majority of EU Member States other than the UK are issuing Article 10
Certificates for each tortoise for life, (these documents are called “specimen-specific Article
10 Certificates”), including for tortoises with shells under 10 cm in length. This creates the
opportunity for illegally obtained tortoises to be laundered using the Article 10 Certificate
system, as there is no way to match the certificate with the tortoise.
For tortoises listed on Annex B and banned from import from the wild, the paper trail for
each tortoise is even harder to follow. The sale of these tortoises from the wild is prohibited
and the seller needs to provide evidence that the specimens were imported or acquired
TRAFFIC / Defra
14
Selling like hot cakes
legally. Such evidence could include breeding history (studbook) details or at least, a signed
statement that they bred the specimen offered for sale. However, there is no system in place
to validate breeders’ claims for Annex B species banned from import in 1999 and no type of
permit needs to be obtained from the CITES Management Authority before sale.
All tortoises found on sale during this survey were claimed to be captive-bred, with the
exception of Horsfield’s and Red-footed Tortoises that were originally wild-caught or ranched
animals.
In Britain, there have been very few prosecutions to date for the
import or sale of tortoises, despite reliable information that
offences have been committed. Listed below are summaries of
court cases that were successfully prosecuted since 1990, although this may not be entirely
comprehensive.
British prosecutions
? July 2001:
the owner of a zoo was fined £5000 and ordered to pay £350 costs for
having on commercial display 10 Spur-thighed Tortoises and nine Hermann’s Tortoises,
as well as other Annex A listed animals.
? 1998: two Egyptians received a two-month prison sentence each for illegally importing
and selling four Kleinmann’s Tortoises.
? April 1995:
fined £200.
a smuggler was found guilty of illegally importing two tortoises and was
? July 1994: an illegal trader was given a 12-month conditional discharge plus £100 costs
for offering for sale a Spur-thighed Tortoise.
? April 1991:
a smuggler was found guilty of illegally importing a tortoise and two boa
constrictors and was fined £1400 and £50 costs.
? In addition, a number of formal warnings and cautions have been given to individuals for
illegally importing or offering tortoises for sale.
Several prosecutions by the RSPCA have been carried out because of animal welfare
offences. Between 1996–2001 the RSPCA had 40 cases involving tortoises and, of these, a
total of ten successful prosecutions were achieved on welfare grounds. All of these cases
involved other species as well as tortoises, ranging from reptiles to domestic animals and
birds. The most recent case arose after police and the RSPCA found a badly decomposed
tortoise in a holding pen containing rare tortoises during a search warrant at the home of a
former London zookeeper. No food, water or light had been provided to the tortoises. Their
owner was found guilty in October 2001 of causing unnecessary suffering to 39 tortoises,
including 14 Spur-thighed Tortoises, 16 Hermann’s Tortoises, five Marginated tortoises and
four Radiated Tortoises. He received a two-year conditional discharge and was ordered to
pay £12,000 costs. The Police also brought charges against the keeper for illegal sales
offences but these were later dropped in favour of the RSPCA prosecution.
TRAFFIC receives many calls a year claiming that tortoises are being offered for sale illegally.
The RSPCA receives hundreds of calls a year concerning tortoises – both with regard to their
welfare but also reports of tortoises of illegal origin. Another charity, the Tortoise Trust,
receives on average four calls a week from members of the public reporting incidents of
possible illegality. These include claims of tortoises sold without Article 10 Certificates and
tortoises that have become ill or have died, which on examination by experts, were found to
have come from the wild when they were sold to the owner as captive-bred.
TRAFFIC / Defra
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Selling like hot cakes
TRAFFIC uncovered a number of offences in Britain resulting from investigations carried out,
which included many incidences where companies were failing to comply with Article 10
licensing requirements. More worrying, the sale of tortoises without Article 10 Certificates,
although not commonplace, was also encountered. It was also confirmed that photocopies of
the same Article 10 Certificates were being used for the sale of multiple tortoises and that
the use of forged certificates was on the increase. All these ways of evading Defra controls
strongly suggest that these methods are being used to legitimise illegally sourced tortoises.
The 1999 import ban resulted in a marked drop in the availability of Horsfield’s Tortoises on
the market. However, traders are now becoming wise to the fact that there are few controls
in place to regulate trade in Annex B species banned from import. Traders are declaring to
the authorities that the Horsfield’s Tortoises they have are captive-bred, yet openly admit to
customers that they are wild-caught. This also applies to a lesser degree to a number of
other tortoise species that are also banned from import from the wild.
The information obtained during investigations has been passed onto the appropriate
authorities for action.
MARKET DYNAMICS
Tortoises in trade come from a range of sources and often their origins are not known by
those who buy and trade in them. Although there are hundreds of tortoise breeders based in
Britain, they are unable to supply the demand for tortoises as pets, as the majority only
breed small numbers and annually many thousands of tortoises are required by keepers.
Breeders in Britain generally sell direct to the tortoise keeper, rather than to wholesale or
retail outlets. British traders often source their tortoises from other EU countries, where
prices are significantly lower, relative to those in Britain. It is often possible for traders to
travel to these countries to buy tortoises and still make a profit. It is normally the case that
wild-collected and illegal tortoises are lower in price than legal captive-bred ones. This is
because the investment in resources to produce captive tortoises is higher and a legitimate
tortoise with a valid certificate
Horsfield’s Tortoises
can command a higher price,
as there is no risk involved. It
The ban in February 1999 on importation to the EU of wild-caught tortoises
is possible that the lower
of some species included the Horsfield’s Tortoise. Horsfield’s Tortoises are
exported in huge numbers from the countries in their range, and many of
prices in mainland Europe
these tortoises were imported into the EU. From 1976 to 1999, nearly one
may be an indication that the
million Horsfield’s Tortoises were exported from the wild and of these, threetortoises on sale there are
quarters were imported into Europe (on average 30,000 per year). With the
taken from the wild rather
closure of the EU as a major market for wild Horsfield’s Tortoises, the main
than captive-bred.
exporting countries of Uzbekistan and Kazakhstan are now exporting to
China, the Russian Federation, the USA and Japan.
In Britain in 2001 there were noticeably fewer Horsfield’s Tortoises on sale
and the EU-wide ban certainly changed the availability of tortoise species in
trade. Defra data indicate that no Horsfield’s Tortoises have been imported
into Britain (wild-caught or captive-bred) since 2000. However, while
surveying traders and the availability of tortoises for this study, a different
picture emerged. A number of traders were in the process of purchasing at
least 400 Horsfield’s Tortoises towards the end of 2001. These traders
openly admitted these Horsfield’s Tortoises were wild-caught and that they
would be declared as ‘farmed’ to evade the EU ban. There has been very
limited success in breeding this species in Britain and elsewhere because of
the difficulty in simulating the conditions of their complex life cycle, as these
tortoises naturally hibernate for periods both in winter and in summer. This
increases the likelihood that demand will be met from the wild and that
traders will deceive the authorities of the origins of the tortoises to legitimise
illegal animals.
TRAFFIC / Defra
16
Selling like hot cakes
There are two major dealers of tortoises in Britain and they supply a large part of the trade.
In 1998, a total of only three tortoise trading businesses in Britain were responsible for most
tortoise imports (mostly Horsfield’s Tortoises) and, by 1999, only one business was
responsible for all Horsfield’s Tortoise imports. In 2000, following the ban on wild-caught
Horsfield’s Tortoises, there were no recorded imports of this species but, instead, imports of
Spur-thighed Tortoises and Hermann’s Tortoises rose sharply. Most of these tortoises – all
but about 200, which went to another trader - were imported by the same business. By
2001, a species split had occurred with one business being responsible for all imports of
Spur-thighed Tortoises and another responsible for all imports of Hermann’s Tortoises.
At least eight companies surveyed in Britain as part of this investigation obtain stock directly
from suppliers in Europe, usually Germany, and many travel to Europe themselves to take
delivery of orders, or to purchase stock at the larger reptile shows. On average, Hermann’s
and Spur-thighed Tortoises – which make up the majority of species on sale in Britain, are
purchased by traders in consignments of 50 to 200 tortoises, two or three times a year.
Slovenia regularly features as the country of origin for the majority of Hermann’s Tortoises
purchased in Germany.
Movement of tortoises in trade from source to British importer, who lesaler, retailer and
tortoise keepers
Outside
the EU
GB Retailers
sales
GB Wholesalers &
Retailers imports
EU
GB
Breeder
sales
GB Tortoise Keepers
purchases
Small-scale illegal consignments bring rarer species of higher value into Britain. Species that
are known to have been imported in this way include very rare species such as the
Plowshare from Madagascar, Kleinmann’s from North Africa, as well as Indian Star and
TRAFFIC / Defra
17
Selling like hot cakes
Madagascan Spider Tortoises. This is an opportunistic trade that is fairly small and is for the
specialist collector market.
The price of a tortoise is directly related to the number of
times that tortoise has been sold. In the case of
Hermann’s and Spur-thighed Tortoises, trade prices direct
from the importers were as low as £55 per tortoise but rose to a maximum of £180 per
tortoise when purchasing from a trader at the end of the supply chain. Retail prices for
tortoise keeper purchases ranged from a low of £125 to a high of £240. The cheapest
tortoises found on sale were Hermann’s Tortoises from Slovenia available direct from a
British importer. As the importer was able to sell them at £55 each and still make a profit,
the price in Slovenia must be much lower but will depend on volumes purchased and
frequency of orders made by the importer. The level of mark-up in price from the wholesaler
to the retailer is typically around 100%. So a tortoise sold by a wholesaler for £55 will have
cost the wholesaler about £25. This price differential could be an indicator that the
Slovenian-sourced tortoises may not be captive-bred, as such an operation would incur high
costs, which would be passed onto the purchaser. The most expensive tortoise found on
retail sale to the public were adult Pancake Tortoises at £1500, adult African Spurred
Tortoises at £1000, and juvenile Indian Star Tortoises at £500. Other rarer tortoises are
unlikely to be sold through the standard retail outlets and are generally traded between
known contacts, sometimes illegally. The rarest tortoises fetch much higher prices, at many
thousands of pounds per tortoise for large breeding pairs.
T ORTOISE P RICES IN B RITAIN
CONCLUSION
The tortoise trade is big business. Over 15,000 live tortoises have been imported directly into
Britain from outside the EU since 1996. Additionally, large numbers are bought within the EU
and brought into Britain, and these do not appear in import statistics. With a 100% mark-up
from wholesale to retail, the profits that can be made in the tortoise trade are substantial.
The majority of tortoise traders are aware of the legislation in place to protect tortoise
species and ensure that they abide by it. A number of other traders either lack the legislative
knowledge to stay within the law or choose to ignore it and, by doing so, bring the whole
trade into disrepute. As the public is generally not aware of the licensing requirements for
tortoises, these disreputable traders are able to perpetuate the illegal tortoise trade with
ease. Over 6,600 tortoises were seized in 10 European countries between 1994-2001,
illustrating that the illegal tortoise trade is both large-scale and prevalent across Europe.
Illegal tortoise trade is happening in Britain, as it is throughout the EU, as a result of
smuggling. It is known that tortoises are smuggled into the EU and, once inside, these
illegally sourced tortoises are very difficult for enforcement authorities to detect since there
are no internal border checks inside the EU. Tortoises can therefore pass freely from one EU
Member State to another. Much of the trade in tortoises to Britain comes from within the EU
in this way.
Licence fraud is another known method of illegal trade in tortoises. In the process of
investigating the trade for this report, instances of fraud and illegal trade were detected. The
Defra licensing system for issuing Article 10 Certificates is open to abuse, particularly as it is
based on a certain level of trust on the part of the issuing authority. Applications for Article
10 certificates need to be thoroughly scrutinised and the information provided by applicants
validated to limit the possibility of fraudulent applications being processed. It is important
that more effort is made to inform traders of the requirements they need to meet when
selling tortoises.
TRAFFIC / Defra
18
Selling like hot cakes
Increased awareness of tortoise licensing requirements among the general public could be a
great asset in combating illegal tortoise trade. It would help to reduce the likelihood that
illegally sourced tortoises could be sold to unsuspecting buyers with a fraudulent licence, or
without any licence at all. The public should also be informed that price can be a good
indicator of legality or otherwise, as tortoises that have been illegally sourced are usually
priced lower than those that have been obtained legally. It is only by informing the public of
the current situation, through reports like these, that they can aid in uncovering illegal trade.
Defra, traders and consumers need to work together to “clean up” the tortoise trade
business and thereby eliminate the few rogue traders that are undermining legitimate
businesses and threatening wild populations of tortoises throughout their range.
Enforcement agencies need to be encouraged and supported in taking forward to
prosecution any cases of illegal tortoise trade that they investigate.
SOLUTIONS
The following are suggestions for potential solutions to remedy some of the issues outlined
in this study.
There are many examples of
buyers purchasing tortoises
without Article 10 Certificates
and only becoming aware of the law after they have made their purchase. Unless purchasers
are made aware of the requirements surrounding the sale of tortoises in Britain, they will
continue to perpetuate the illegal trade. Raising the awareness of traders and keepers in
Britain is essential. Suggested methods for this include:
INFORMING TORTOISE BUYERS, TRADERS AND BREEDERS
?A
joint campaign by Defra, the police, Customs and the pet trade should encourage
buyers to ask the right questions when they are thinking of purchasing a tortoise. If
legitimate buyers are well informed, traders will not be able to sell tortoises without the
necessary certificates.
?
The campaign should focus on highlighting the illegal tortoise trade and the need
for an Article 10 Certificate for sale and purchase of a tortoise species listed in
Annex A of the EU wildlife trade regulations.
?
Through the campaign, more buyers or sellers of Annex B-listed tortoises should be
aware that they need to be able to prove its legal origin.
?
Traders and breeders of tortoises should also be targeted to make them aware of
the tortoise licensing requirements and that Defra Wildlife Inspectors will be making
concerted efforts to check sellers of tortoises for possession of Article 10
Certificates and proof of legal origin of tortoises.
?
Encouragement should be given to traders to apply for Article 10 Certificates for
tortoises they have purchased legally and wish to sell – thereby ensuring they are
not breaking the law. To this end, Defra could consider including a colourful
information sheet with every Article 10 certificate issued, which can in turn be
passed on to buyers. The sheet could be sponsored by interested conservation and
animal welfare organisations and could include information on the husbandry,
origins, conservation and legal status of the tortoise species being traded. This
would add value to the tortoise being traded and ensure that it was more likely to
be well-kept by its buyer.
TRAFFIC / Defra
19
Selling like hot cakes
HELPING LAW ENFORCEMENT
? Police and Customs should be made more widely aware of the illegal trade in tortoises
and the tricks used by smugglers and illegal traders to evade the law. Information
should be distributed particularly to all Police Wildlife Liaison Officers and Customs
Wildlife and Endangered Species Officers.
? Members
of the public and traders should be encouraged to report suspected illegal
trade in tortoises to the authorities, Crimestoppers or the WWF/TRAFFIC Eyes & Ears
campaign.
? Legal traders, breeders and buyers should ask traders if they have Article 10 Certificates
for their tortoises and, if they cannot provide them, they should be reported to Defra or
the police.
? The police and Customs authorities should be supported in taking forward any cases of
suspected illegal tortoise trade. They require provision of expertise (identification,
forensics and veterinary), resources such as funding for housing seized tortoises, and
tools and materials to assist in investigation and prosecution (e.g. microchip readers,
identification manuals).
? Defra Wildlife Inspectors should have appropriate resources to make regular checks on
wholesalers, retailers and other sellers of tortoises to ensure that they have the Article
10 Certificates for the tortoises they are selling. A concerted effort by Wildlife Inspectors
during the period of the awareness-raising campaign suggested above would help to
make traders realise that they are likely to be checked and prosecution may result if they
were found to be trading illegally.
There is no doubt that the tortoise trade issues in the UK are
A N EU-WIDE APPROACH
linked very closely to the wider EU situation of species
protection, trade and awareness. It is important that these
issues be tackled more widely in the EU, as well as in the UK. Many tortoises in trade in
Britain were sourced via other EU countries and traders there should be aware of the need
to provide Article 10 Certificates and refuse to purchase and sell illegally sourced tortoises.
? The UK authorities should co-ordinate with the EU Commission, CITES Secretariat, World
Customs Organisation, ICPO-Interpol and the EU Enforcement Working Group to review
the situation and formulate partnerships for enforcement action and improved controls in
the future.
? Awareness
campaigns for traders, buyers, breeders and law enforcement should be
promoted in the EU in a similar way to those suggested here for the UK.
TRAFFIC / Defra
20
Selling like hot cakes
REFERENCES
ACKNOWLEDGEMENTS
CITES Management Authority France 2001. CITES:
Rapport Bisannuel de la France – Periode 1999-2000.
Many thanks to Manas Bose, Simon Liebert, Roy Pitt, Nick
P. Williams and Jane Withey at Defra for their patience
and support. Thanks are also due to Alison Littlewood at
JNCC for guidance on the complexities of the UNICORN
system. In addition, the authors are grateful to the
following for their invaluable assistance: Tim Luffman of
HM Customs and Excise, Henny Fenwick, Andy Shipp of
the RSPCA, Jill Martin and Andy Highfield of the Tortoise
Trust. In addition, thanks to the Police Wildlife Liaison
Officers who helped, in particular to Geoff Culbertson,
Alan Roberts, Alan Stewart and Steve Parnwell. Thanks
also go to Simon Milledge and Rob Quest for the use of
their pictures. Lastly, Angela Barden and Julie Gray at
TRAFFIC International for their help with data analysis
and editing respectively.
CITES Management Authority Germany 1999. Biennial
Report of the Federal Republic of Germany according to
Art 15.4c of Regulation (EC) No. 338/97 1997-1998.
CITES Secretariat 1997. Review of alleged infractions and
other problems of implementation of the Convention (Doc.
10.28). Tenth Meeting of the Conference of the Parties
Harare (Zimbabwe) 9-2- June 1997.
Defra 2002. UNICORN data 1996–2002. Unpublished.
Defra, Bristol.
European Commission 1997. Council regulation (EC) No
338/97 on the Protection of the Species of Wild Fauna and
Flora by Regulating Trade Therein. European
Commission, Brussels.
Stephanie Pendry and Crawford Allan
TRAFFIC International
European Commission 1999. Commission regulation (EC)
No 250/1999 of 2 February 1999 amending Regulation
(EC) No 2473/98 suspending the introduction into the
Community of specimens of certain species of wild fauna
and flora. European Commission, Brussels.
HMCE CITES Team 2002. Seizures Data London
Airports: Tortoises 1996-2002. HMCE CITES Team,
Heathrow Airport
Investigation summaries obtained as personal
communications from HMCE and Police personnel, as
well as from information held at TRAFFIC International.
© TRAFFIC International / Defra 2003
219a Huntingdon Road
Cambridge CB3 0DL
Personal communications, RSPCA Special Operations
Unit. RSPCA, Horsham.
RSPCA 2001. Shell Shock. RSPCA, Horsham.
TRAFFIC Europe 2002. The Role of the EU in the Live
Reptile Trade. Unpublished Report. TRAFFIC Europe,
Brussels.
TRAFFIC International 1997-2001. TRAFFIC Bulletin Vol.
17 No 1 (1997); TRAFFIC Bulletin Vol. 17 No 2 (1998);
TRAFFIC Bulletin Vol. 17 No 3 (1999); TRAFFIC Bulletin
Vol. 18 No 1 (1999); TRAFFIC Bulletin Vol. 18 No 2
(2000); TRAFFIC Bulletin Vol. 18 No 3 (2000); TRAFFIC
Bulletin Vol. 19 No 1 (2001). TRAFFIC International,
Cambridge.
Email: [email protected]
Web: www.traffic.org
Global Wildlife Division
Temple Quay House
2 The Square
Bristol BS1 6EB
TRAFFIC International 2002. UK CITES Prosecutions
Table (sourced from HMCE, Police and DEFRA records).
TRAFFIC International, Cambridge.
Tel: 0117 372 8000
Fax: 0117 372 8393
Web: www.defra.gov.uk
UNEP-WCMC 2002. Output from the CITES Annual
Report Database: Testudinidae trade 1996-2001.
Unpublished. CITES Secretariat, Geneva.
TRAFFIC / Defra
Front cover: Juvenile Spur-thighed Tortoise ?
Stephanie Pendry / TRAFFIC International
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TRAFFIC / Defra
22