When the Conference of the Parties to CITES adopted its listing criteria (Resolution Conf. 9.24), it recognized that these criteria may not be fully suitable, in particular for certain categories of species. Therefore, it agreed that the whole Resolution should be reviewed before COP 12.

Terms of reference for the review of the criteria will be discussed at COP 11: Specialists in marine fish species in particular expressed serious concerns with regard to the CITES criteria. Following a recommendation from the FAO Committee on Fisheries (COFI), the FAO, which clearly has competence in this matter, will conduct a scientific review of the CITES listing criteria and report to CITES. The Government of Japan encourages CITES Parties to respect the forthcoming comments from FAO on this matter. In addition, the FAO has developed plans of action to reduce seabird by-catch in fisheries, conserve sharks, and to manage fishing fleet over-capacity. Given that CITES listing criteria do not appear appropriate for commercially harvested marine fish species and that revised criteria will not be available before COP 12, the Government of Japan recommends that COP 11 reject proposals for the listing of such, until satisfactory criteria have been adopted. Regional management organizations and the FAO rather than CITES are in fact the appropriate organizations to implement conservation management regimes for these species.

CITES Procedures -Secret Ballot: It is likely there will be attempts at COP 11 to change the CITES Rules of Procedure, which provide for the use of secret ballots. This is an important matter of principle since the secret ballot allows CITES Parties to vote as they see fit, without coercion or fear of reprisals from other Parties or NGOs. Such coercion and threats of reprisals have occurred in the past both within the IWC and CITES against those countries supportive of sustainable use of certain species. Reprisals have included boycotts of significant export items and of the tourism industries of a number of small developing states. Secret ballots were used reasonably at CITES COP 10 and are a part of the operating procedures in many international organizations.