Whether it is born of frustration or is motivated by some other factors, the fact is that CITES is moving, or being pushed, into areas that go beyond its intended remit. Yet it still has a huge amount to achieve for wildlife in areas that everyone agrees fall under its responsibilities.

The mission of the UN Food and Agriculture Organization (FAO) is "to help build a food-secure world for present and future generations." The FAO plays the lead international role in fisheries management, with its Fisheries Department and Committee on Fisheries aiming "to facilitate and secure the long-term sustainable development and utilization of the world’s fisheries and aquaculture."

Various instruments have been introduced by the FAO to improve the international management of fisheries: a Code of Conduct; International Plans of Action (IPOAs); and an IPOA to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (IPOA-IUU).

As an administrative mechanism, CITES can establish international trading procedures but it is not equipped to deal with overall species management issues like those required to address commercial fisheries. For example, fish populations often fluctuate widely from one year to the next, requiring flexible and adaptable management instruments. Does anyone really believe that these characteristics are well suited to CITES? We all know how difficult it is for any commercially exploited species to be transferred from Appendix I to Appendix II.

CITES rightly requires a degree of certainty about the biological vulnerability of a species to become extinct, changes in its population levels and the impact of trade before it can be placed onto its Appendices. Fisheries is characterized by a lack of reliable catch, biological and scientific data. Moreover, fisheries management work is carried out on a stock-by-stock basis whereas CITES focuses on overall species.

From a more practical point of view, CITES listings would create a cumbersome and bureaucratic process for international fisheries. It would be extremely difficult for customs officials to differentiate "look-alike" species, particularly if they are being imported in the form of, say, white fish filets.

And the bottom line is that CITES listings may not even help increase regional fish populations because international trade is not always the primary cause of falling stocks.