First, the procedures for transfer and removal of species from CITES
appendices are complex and cumbersome. Down-listing and de-listing in
particular have proved to be very difficult, even when the scientific
evidence is clear. This is particularly problematic in fisheries where
populations can fluctuate widely from one year to the next.
Secondly, current and proposed procedures may not only lead to
unwarranted listing and prevent de-listing. They may also bring about
costly administrative burdens, among other things as Parties to CITES may
request import permits.
Thirdly, it can also be questioned whether CITES has the administrative
mechanism required to carry out the frequent listing, down-listing and
de-listing from the appendices which will be foreseen if commercial fish
stocks are listed. This issue must be regarded as equally important as the
listing criteria themselves.
