[Coral-List] CITES permit exemptions for corals

Richard Dunne RichardPDunne at aol.com
Wed Oct 29 13:11:48 EDT 2008

Strictly speaking the document to which you were referred is an 
interpretation of the Convention for European Union countries only.

The relevant provisions of CITES are:

Conf. 11.10 (Rev. CoP14) which contains definitions. Relevant to 
biologists who collect coral samples which were once alive but in the 
process of collecting/ preservation are killed, are the definitions of:

DEAD CORAL - pieces of coral that are dead when exported, but that may 
have been alive when collected, and in which the structure of corallites 
(the skeleton of the individual polyp) is still intact; specimens are 
therefore identifiable to the level of species or genus.
CORAL FRAGMENTS (including gravel and rubble) - unconsolidated fragments 
of broken finger-like dead coral and other material between 2 and 30mm 
in diameter, which is not identifiable to the level of genus.
Conf. 9.6 (Rev.) "coral sand and coral fragments [as defined in the 
Annex of Resolution Conf. 11.10 (Rev. CoP14)3] are not considered 
readily recognizable and are therefore not covered by the provisions of 
the Convention."

So yes by definition anything fitting into the definition of a CORAL 
FRAGMENT under Conf. 11.10 (Rev. CoP14) is NOT covered by CITES 
throughout the world by all parties to the Convention. This would 
include tips of branching corals and also cores from massive corals less 
than 30mm in diameter.

It also appears that specimens of (for example) decalcified coral 
embedded in resin for electron microscopy, or other dead material in 
formalin etc., where there is no skeleton (e.g., tissue slurry or other 
tissue extracts) are also EXEMPT since they no longer have any skeleton 
by which they can be identified. Additionally, specimens of this type 
which have skeleton but fall within the 2-30mm size would be EXEMPT as 
being Coral fragments.

Anyone like to comment further on this?

Richard P Dunne

Iliana Baums wrote:
> Dear colleagues,
> CITES never ceases to surprise me. After long struggles we had obtained 
> a CITES permit to export small coral samples for DNA analysis. After 
> dropping off the permit with Fish and Wildlife in the US, they called 
> the next day with a few questions. During the conversation the gentleman 
> told me that in fact I did not need a CITES permit for my coral samples 
> because they were so small. I asked for the reference for this and was 
> told to go to the CITES webpage and indeed found the following 
> (http://www.cites.org/common/com/AC/22/E22i-08.pdf):
> ?Overview of coral products in trade and relevant Resolutions / 
> Decisions for implementation of CITES provisions in EU
> Note: fossil corals exempted from CITES, but no common CITES 
> interpretation on definition of “fossil corals”
> .....
> Corals: Helioporidae spp. (Blue corals), Tubiporidae spp. (Organpipe 
> corals), ANTHIPATHARIA spp. (black corals), SCLERACTINIA (order) Stony 
> corals?(hard corals), Milleporidae and Stylasteridae. Please note: NB – 
> there is no exemption for fossils of black corals (Antipatharia) 
> Resolution Conf. 11.10 on definitions
> .....
> Coral fragments: Coral fragments (including gravel and rubble) – 
> unconsolidated fragments of broken finger-like dead coral and other 
> material between 2 and 30 mm in diameter, which is not identifiable to 
> the level of genus. Res: 9.6 (Rev CoP12): not readily recognisable so 
> not covered by convention, Not covered by convention, No CITES export 
> permit and no EU CITES import permit required.
> .....
> Now, does this mean I can quit chasing CITES permits? Anybody know who 
> to ask?

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