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TRAFFIC International

TRAFFIC

TRAFFIC, the wildlife trade monitoring network, is the leading non-governmental organization working globally to address biodiversity conservation and sustainable development priorities linked to the trade in wild species.

Lobbying Activity

Response to An EU strategy for fisheries external action

15 Sept 2025

TRAFFIC International welcomes the opportunity to provide the European Commission with evidence to support the development of the EU Strategy on EU Fisheries External Action. Firstly, we would like to associate ourselves with the submission made by WWF European Policy Office to this call for evidence. TRAFFIC is also a member of the Coalition for Fisheries Transparency. TRAFFICs mission is to ensure that trade in wild species is legal and sustainable, for the benefit of the planet and people. We have a long history of reviewing trade in fished species, examining their supply chains, management arrangements and recommending improvements to ensure trade is legal, sustainable, transparent and traceable. This has involved working closely with the European Commission, including supporting DG Environment engagement with international agreements such as the Convention on International Trade in Endangered species of flora and fauna (CITES) and with many governments around the world through the engagement in Regional Fisheries Bodies and Regional Fisheries Management Organisations, and other Multilateral Environmental Agreements such as the Convention on Migratory Species. Key to achieving our mission is transparency and traceability within supply chains derived from fishing practices, and in the circumstances of this submission where the EC acts as Flag, Port and Market State with outreach and effect across the world. A lack of transparency allows for illegal activity to manifest and unsustainable practices to occur. The EU should model policies closely on global best practices on improving transparency and traceability such as the Global Charter for Fisheries Transparency to ensure legal, sustainable and ethical fisheries. TRAFFIC considers there are key priorities for the new EU strategy including: Ensure compliance with existing rules and transparency by ensuring EU vessels comply with international and regional obligations outside of Europe; Act to reduce IUU activity through ensuring vessel operations are visible, disclose infractions, and enforce sanctions. Support other governments in building open monitoring and reporting systems. Require the disclosure of beneficial ownership of EU vessels and ensure the information is shared openly to prevent illegal operators hiding behind closed door ownership structures. Make sustainable fisheries partnership agreements (SPFAs) transparent, sustainable, and equitable: o Grant fishing access only to scientifically proven sustainable stocks. o Publish terms of access, financial contributions, and vessel lists. o Involve civil society and artisanal fishers in design, monitoring, and evaluation. o Make vessel activity and ownership transparency a binding condition of SFPAs Ensure supply chains have appropriate traceability systems in place for import and export, noting priority should be given to CITES-listed species, and note transparency and traceability in supply chains is not just about eliminating IUU fishing. It is also about ensuring products from fisheries are derived from sustainable sources; Ensure the cohesion and cooperation between fisheries-related activities within RFBs/RFMOs and MEAs such as CITES. TRAFFIC considers the Global Charter for Fisheries Transparency as key guidance in ensuring fisheries are legal, sustainable and transparent. TRAFFIC is ready to work with the EC in developing further its strategy for fisheries external action.
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Meeting with Chantal Marijnissen (Head of Unit Directorate-General for International Partnerships)

27 Mar 2025 · Exchange of views between TRAFFIC and INTPA and outline the continued relationship. Discuss the utilisation of different financial instruments and private sector engagement.

Response to Sustainable corporate governance

23 May 2022

Please find TRAFFIC's response in the file attached.
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Response to Improving environmental protection through criminal law

21 Apr 2022

TRAFFIC welcomes the proposed revision of the Environmental Crime Directive and the opportunity to provide feedback. Please find our feedback attached.
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Response to EU Agenda to tackle organised crime (2021-2025)

15 Mar 2021

TRAFFIC, the non-governmental organisation working on trade in wild animals and plants in the context of biodiversity conservation and sustainable development, welcomes the European Commission’s (EC) EU initiative to tackle organized crime. While working on wildlife trade, TRAFFIC has come across evidence of the involvement of organized criminality in wildlife (including timber and fish) trafficking. Therefore, TRAFFIC particularly welcomes the positive implications of the proposed strategy for the environment. TRAFFIC calls for the inclusion of environmental crime, specifically wildlife trafficking in the Strategy. The EU is a globally important consumer market of wildlife and their products as well as a transit hub and an exporter. In line with the European Green Deal, the EU has the responsibility to step up its efforts against organized environmental crime. The COVID-19 pandemic has also attracted attention to a growing number of examples of wildlife-sourced diseases emerging as important human health concerns. TRAFFIC has welcomed that environmental crime, including wildlife trafficking, has been an EU priority for the first time during the 2018-2021 policy cycle in the fight against serious international and organised crime under the European Multidisciplinary Platform Against Criminal Threats (EMPACT). While good progress has been made since 2018 – as demonstrated for example by the increasing number of intelligence records related to environmental crime in Europol’s systems – attention must be maintained on this “new” crime area for it to be fully recognized and mainstreamed at all levels. The new Strategy could foster synergies with other existing enforcement cooperation mechanisms such as the EU Wildlife Trade Enforcement Group, which has extensive expertise in tackling wildlife crime. The Strategy is also expected to be in synergy with the new EU Action Plan against Wildlife Trafficking (as announced in the EU Biodiversity Strategy to 2030). TRAFFIC welcomes the proposed initiative’s focus on supporting effective collaboration and co-ordination cross-borders, across sectors and among authorities. These are areas TRAFFIC also finds important. TRAFFIC was instrumental in the founding of the EU Trade in Wildlife Information eXchange (EU-TWIX) system, which has fostered law enforcement co-operation and information exchange in Europe in the field of wildlife trade for over 15 years. TRAFFIC has led and contributed to projects, which provide good examples of cross-sector engagement (law enforcement – business sector – civil society), for instance related to illegal wildlife trade online. The exchange of information and experiences within the EU and also with third countries is also of great importance. Environmental crime is often linked to other forms of criminal conduct, such as money laundering and corruption. Corruption represents one of the largest conservation and development challenges within natural resources sectors. Its presence throughout supply chains for wildlife, forests and fisheries products is a major obstacle to global transitions towards legal and sustainable trade and harvesting. TRAFFIC (co-)authored reports that highlight this problem include ‘Corrupting trade: An overview of corruption issues in illicit wildlife trade’ and ‘Corruption and wildlife crime: A focus on caviar trade’. TRAFFIC also notes the importance of crime prevention approaches, such as social-science based consumer behaviour change initiatives aiming to deter demand from illegal wildlife and their products and the imposition of adequately deterrent penalties, including asset recovery. The success of the Strategy will depend on the financial and human resources allocated to its implementation. TRAFFIC hopes that the Strategy will be backed up by sufficient resources required for its implementation, including for tackling wildlife trafficking. TRAFFIC offers its assistance to the EC to support their efforts to tackle organized crime.
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Response to Wildlife trade – alignment of EU rules with recent decisions taken under the CITES convention and changes to EU ivory trade rules

25 Feb 2021

The global trade in illegal ivory and the African elephant poaching crisis have remained key wildlife conservation issues for decades. A great degree of attention and sacrifice has been made globally to help stem the flow of illegal ivory and protect threatened elephant populations. However the drivers and facilitators of illegal ivory trade are shifting and complex, so various strategies and policies have been suggested or implemented. TRAFFIC has been a leading voice on ivory trade matters for decades; helping to shape global policy decisions where they matter most. TRAFFIC provides regular analyses of the data in the Elephant Trade and Information System (ETIS), which was set up under CITES in 1997 and is managed by TRAFFIC. This centralised database holds almost 28 000 records pertaining to ivory seizures and law enforcement actions from more than 100 countries and enables the monitoring and analysis of complicated ivory trade flows and evolving market dynamics. TRAFFIC has also been at the forefront of documenting poorly regulated domestic ivory markets, providing advice to elephant Range States on management and auditing of ivory stocks, supported law enforcement efforts and informing evidence-based consumer behaviour change strategies. The most recent ETIS analyses did not flag any EU Member States (MS) as ‘countries most or markedly affected by the illegal trade in ivory’, indicating that the EU market has not been implicated in contributing to poaching of elephants or illegal trade in any significant way. While efforts to strengthen ivory trade regulation are welcomed, the effective implementation of such a regulatory framework may present challenges. For this reason, it must be ensured that the implementation of the regulatory framework is proportionate, practical and, ultimately, produces positive conservation impacts. The proposed new rules to tighten the trade in ivory in the EU are expected to significantly increase the workload of EU CITES Management Authorities that will have to issue the required documents. EU enforcement authorities will also be expected to shift their attention to ensuring adequate application of the new rules. These will strain the scarce human and financial resources available to CITES authorities, in particular right after the introduction of the new rules and when authorities already face additional challenges related to the COVID-19 pandemic and the increased workload due to Brexit. TRAFFIC is concerned this will result in the neglect of or the inability to address more pressing wildlife trade issues, where the EU has a more significant, negative conservation impact, such as the illegal trade in exotic reptiles, birds, eels and timber. Therefore, TRAFFIC urges both the European Commission (EC) and the MS to: - allocate additional human and financial resources to the CITES authorities so that attention/vigilance can be maintained on trade issues of high conservation concern that are significantly impacted by EU MS, such as the illegal trade in exotic reptiles, birds, eels and timber; - allocate additional resources to scientifically explore consumers choices and demand for wild fauna and flora and their products and derivatives in Europe. Gaining a better understanding on this would allow shifting consumer decisions and demand towards legally and sustainably sourced wildlife/products in the EU; - establish a monitoring and evaluation mechanism to identify gaps and challenges in the implementation of the EU ivory trade rules and recommend remedial action, where appropriate; - boost technical and financial support to those countries that are mostly or markedly affected by the illegal trade in ivory and facilitate greater collaboration among the elephant range States in tackling the global trade in illegal ivory. TRAFFIC offers its assistance to the EC and the MS in implementing the above recommendations and supporting their efforts to tackle the global trade in illegal ivory.
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Response to Wildlife trafficking - EU action plan (evaluation)

17 Mar 2020

Dear Madam/Sir, Please find attached TRAFFIC's response to the roadmap. Best regards, Katalin Kecse-Nagy TRAFFIC
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