““SSeelllliinngg lliikkee HHoott CCaakkeess””

AAnn IInnvveessttiiggaattiioonn iinnttoo tthhee TTrraaddee iinn TToorrttooiisseess iinn GGrreeaatt BBrriittaaiinn

A study in 2002 for Defra By TRAFFIC International Selling like hot cakes

CONTENTS

INTRODUCTION ...... 3 BACKGROUND ...... 3 Laws and treaties...... 3 TORTOISE SPECIES IN TRADE...... 4 THE INVESTIGATION...... 6 Legal trade, 1996-2001...... 7 Illegal trade ...... 11 MARKET DYNAMICS ...... 16 Tortoise prices in Britain ...... 18 CONCLUSION...... 18 SOLUTIONS ...... 19 Informing tortoise buyers, traders and breeders...... 19 Helping law enforcement...... 20 An EU-wide approach...... 20 REFERENCES ...... 21 ACKNOWLEDGEMENTS ...... 21

The views of the authors expressed in this report do not necessarily reflect those of TRAFFIC International or Defra.

The designation of geographical entities in this report and the presentation of the material, do not imply the expression of any opinion whatsoever on the part of the authors, TRAFFIC International or Defra concerning the legal status of any country, territory or area, or of its authorities, or concerning the delimitation of its frontiers or boundaries.

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INTRODUCTION

For many years in Britain there has been a growing interest in reptile keeping, and the keeping of tortoises as pets in particular. There has also been evidence of smuggling and illegal trade in tortoises to meet the demand. To date, no studies on the situation nationally have been undertaken. The UK Government department responsible for the trade in tortoises, the Department for Environment, Food and Rural Affairs – Defra, commissioned this study to investigate the trade, both legal and illegal, and to make suggestions on how to improve any problems found. TRAFFIC has researched the trade for Defra and the summary of the findings is included here.

BACKGROUND

The keeping of tortoises in Britain has been popular over several decades and demand has escalated with the increasing trend for keeping reptiles as pets. This has influenced the trade, encouraging breeding and importation, as well as illegal trafficking. Even with a responsible, largely law-abiding pet trade in Britain, a significant amount of illegal trade in tortoises still occurs and consumers are unwittingly supporting this detrimental and criminal trade. It is very difficult to estimate the true levels of tortoise imports into Britain, both legal and illegal. The removal of internal European Union (EU) trade borders has meant that consignments of tortoises that formerly required permits to be traded between EU countries can now move legally between them without the need for these. It is known that such consignments have come from mainland Europe to Britain since the removal of internal borders in the EU. This places more emphasis on the need to enforce the law at points of sale within Britain and at the same time makes this task more difficult. Tortoises are sold in Britain not only in pet shops, but also at garden centres, DIY stores and through classified advertisements in specialist magazines and local newspapers. Tortoises are also sold through an informal sales network of breeders and their contacts, interest groups and trade fairs. Specialist tortoise keepers play a significant role in the tortoise trade, by driving demand for rarer species and new blood lines, but also by supplying captive-bred stock to meet demand that normally would require taking animals from the wild. The number of tortoise breeders is increasing, but these breeders are unable to meet the demand for captive-bred tortoises in Britain. This low level of legal supply creates a market opportunity for unscrupulous dealers to trade in illegal wild-caught tortoises. The scarcity of fertile females to broaden gene pools has been a particular incentive for breeders to collect tortoises illegally from the wild and smuggle them from their country of origin. Most tortoises that are kept as pets come from the family LAWS AND TREATIES Testudinidae, which includes 44 tortoise species. The whole family is covered by an international treaty on trade in wildlife, called the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The Testudinidae family is listed in Appendix II of CITES, which means that commercial international trade in ‘Appendix II species’ is allowed, if accompanied by the correct permits. A number of rarer species (listed in Appendix I) receive a higher level of protection under CITES. Commercial trade in these ‘Appendix I species’ is allowed only for captive-bred specimens or specimens imported prior to the species being listed in Appendix I. The EU applies the CITES treaty through its own wildlife trade regulations. The EU regulations list protected species in four annexes (A, B, C and D), with Annex A species being the most protected. Requirements under these EU regulations are sometimes stricter

TRAFFIC / Defra 3 Selling like hot cakes than those of CITES. Some Mediterranean tortoises, for example, can be traded according to CITES, but are banned from commercial trade by EU regulations. A European import ban on wild-caught Mediterranean tortoises came into force in 1984, with only captive bred or pre ban tortoises being allowed to be traded. This ban caused an increase in trade of African and Eurasian tortoise species into Europe instead. With this shifting of pressure to new species in trade came the need for protection of a wider range of tortoises. As a result, in February 1999, wild-caught specimens of a further 18 tortoise species were banned from import into the EU. Only captive-bred tortoises or those imported before the ban of these 18 species are now allowed in commercial trade. It is illegal to trade wild caught species listed on Annex A. Only captive bred individuals are allowed in commercial trade, and only if an EU sales exemption certificate accompanies them (called an “Article 10 Certificate”). An Article 10 Certificate is valid for one transaction only and a further certificate is needed for any subsequent trade, unless a specimen can be “uniquely marked” (i.e. with a microchip implant in the case of tortoises). The majority of tortoises on sale in Britain requiring Article 10 Certificates are of a size smaller than is recommended for the insertion of a microchip (i.e. have a shell length of under 10 cm) and, therefore, a new certificate is needed for each sales transaction. As all species popular in the tortoise trade are banned from import to Britain if wild-caught, only captive-bred or tortoises imported before the bans should be found in trade in Britain.

TORTOISE SPECIES IN TRADE

Trends in keeping a particular species of tortoise appear to be more affected by availability dependent on legislation than by the popularity of any given species. In 1998 more Horsfield’s Tortoises were sold in Britain than any other species of tortoise. But since wild- caught Horsfield’s Tortoises were banned from trade in 1999, there has been a resurgence of trade in captive-bred Spur-thighed and Hermann’s Tortoises, to fill the gap in the market brought about by this ban. Hermann’s Tortoises are the most commonly purchased tortoise in Britain today and are kept as pets and by specialist keepers. At one time hundreds of thousands of these tortoises were removed from their habitat in south- east Europe every year and exported to Britain and north- west Europe for the bulk pet trade. Since the ban on their collection from the wild in 1984, wild populations have been recovering. They inhabit Mediterranean countries including France, Spain, Italy, Greece and Romania. Wholesale prices can be as low as £50 and retail prices as high as £250 per tortoise. From 1969 to 1972 a total of 480,000 Spur-thighed Tortoises were imported into Britain. Between 1972 and the 1984 ban on imports of wild Mediterranean tortoises, thousands of Spur-thighed Tortoises were brought from the wild into Britain each year. The population of the species in the wild is estimated to be three million. Spur-thighed Tortoises are distributed in Mediterranean countries, parts of the Russian Federation, Iran and Iraq. Wholesale prices start at £60 and retail prices can reach £300 or more for an adult breeding female.

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Marginated Tortoises have a limited distribution in the wild, existing only in Greece and parts of Albania. They have a very long shell, growing to a length of 25-30 cm. No wild-caught Marginated Tortoises should be on sale in Britain, unless they were brought into the country before the import ban in 1984. Breeding of Marginated Tortoises is now on the increase and juvenile captive-bred tortoises can be found on sale. Prices range from £60 wholesale to £275 retail. Horsfield’s Tortoises have a wide distribution in Central Asia where they occur throughout their range at low densities, yet the area is so vast that the population is estimated in the millions. Horsfield’s Tortoises differ from other tortoises by having a low tolerance to damp climates and rain, although extreme temperatures are less problematic as long as they are kept dry. Consequently, keeping them successfully in captivity requires a high level of expertise as well as suitable housing facilities. Because of the import ban in 1999, no wild-caught Horsfield’s Tortoises should be on sale in Britain today unless they were imported before that year. Prices range from £60 wholesale up to £300 retail. Leopard Tortoises are imported in the hundreds every year to Britain, and the majority are sourced from the wild. These tortoises grow up to 60 cm in length and can weigh up to 40 kg. They originate in eastern and southern Africa. There is an import ban on wild Leopard Tortoises from the Central African Republic, Mozambique, Tanzania and Zambia. Prices start from £125. Hingeback tortoises come from Africa. Wild-caught individuals have been banned from trade in Britain since 1999. These species are not seen very frequently in trade and require specialist conditions to be kept in Britain. The species depicted here is the Home’s Hingeback Tortoise, which comes from West Africa. The African Spurred Tortoise is the largest mainland tortoise, with some adults reaching over 70 cm in length and weighing over 45 kg. It is estimated that no more than 20,000 individuals remain in the wild today. Due to its large size it can be destructive if confined and needs large areas dedicated to it. African Spurred Tortoises occur in countries in North Africa, including Egypt, Sudan, Mauritania, Ethiopia and Eritrea. No recently imported, wild-caught individuals should be in commercial trade as the countries in which the species occurs have stopped exports since 2000. Prices can be as little as £80 wholesale for one tortoise, with retail prices up to £2000 for a pair. The Red-footed Tortoise comes from areas of high humidity and will dehydrate rapidly. It ranges across South America and the Caribbean. These tortoises grow to be quite large (length 45 cm) and because of this, a smaller race of the species is growing in popularity. These tortoises are mainly ranched in South America and shipped to Europe for sale. Wholesale prices begin at £75 and retail prices are up to £400 for an adult.

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Indian Star Tortoises are under threat from the destruction of their habitat and their collection from the wild for the pet trade. They are not easy to keep in captivity and suit only specialist keepers. They are banned from import from the wild, and have a restricted range in only India, Pakistan and Sri Lanka. Wholesale prices start at £250 and retail prices at £1200 a pair. Endangered species that are sought after for their rarity occur in illegal trade. These include species such as the Pancake Tortoise, Kleinmann’s (Egyptian) Tortoise, Radiated Tortoise and Plowshare (Angonoka) Tortoise. There is very rarely any legal trade in captive-bred individuals of these species. Pancake Tortoises have a limited distribution, occurring only in Kenya and Tanzania, and have rigid habitat requirements, living where rock crevices of suitable dimensions are found. This, along with a low reproductive rate, means their population is heavily impacted by any collection from the wild. Only captive-bred Pancake Tortoises should be on sale in Britain, if any breeders have succeeded in breeding them. Because of this and their limited numbers in the wild they are rarely seen in trade and are priced accordingly, between £1500 and £3000 each. Kleinmann’s Tortoise is very rare and threatened with extinction. It is found only in Libya and Egypt, with only a very small population still surviving in Egypt. While there appears to be a larger population in Libya, numbers there are declining rapidly because of illegal trade. Kleinmann’s Tortoises will not be found legally in commercial trade in Britain. The Radiated Tortoise and Plowshare Tortoise are endemic to Madagascar and have very small and fragile populations. The Plowshare Tortoise is perhaps the most endangered tortoise in the world, with only a few hundred tortoises remaining in the wild or in conservation programmes. Habitat loss and collection for the specialist trade threaten both species. Individuals are valued at many thousands of pounds, but these tortoises should not be found legally in commercial trade in Britain.

THE INVESTIGATION

Information was obtained from a range of sources during field investigations and desk-based study. The methods used included:

Analysis of CITES and UK Government databases for information on trade in species listed in CITES and under EU regulations. This involved looking at imports and exports, as well as sales in Britain. Analysis of illegal trade information from a number of sources including Her Majesty’s Customs and Excise (HMCE) seizures data, the CITES database of seizures data, and other instances of documented enforcement in Britain, such as prosecution cases. Surveys of tortoise traders to estimate the level of illegal trade in Britain.

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Studies of the trade routes used to bring tortoises into Britain, based on information from the HMCE CITES Team at Heathrow Airport, from tortoise traders and from analysis of British and EU seizures data. Analysis of the licensing system used by Defra to permit imports, exports and sales of tortoises in Britain. The study looked for potential abuses of the licensing system and difficulties traders may have with the system. Studies of the market dynamics for tortoises, looking at prices and availability, and the influences of supply and demand.

LEGAL TRADE, 1996-2001

Within the EU, Britain is the fourth-largest importer of tortoises, after Volume of trade France, Spain and Germany. The term ‘import’ refers to the import of tortoises into Britain from countries outside of the EU. Figures were obtained from the CITES database and Defra’s database. Any movement of animals within the EU under CITES is not considered an import. Britain has followed European trends, with imports showing an increase from 1992 to 1998, a relative decrease in 1999 and 2000, and a rise again in 2001. The year of peak imports during the period 1996-2001 was 1998. Total annual tortoise imports by year are illustrated in the bar chart below.

Totall Briitiish iimports off tortoiises 1996-2001

6000

5000

4000

3000

2000

1000

0 1996 1997 1998 1999 2000 2001

Overall, during the period 1996-2001, 98% of tortoises were Purpose of imports imported for commercial trade. Although the primary purpose of import for all species other than Horsfield’s Tortoises in 1996 and 1997 was recorded as “personal”, this situation changed markedly in 1998 and 1999, when nearly all imports were reported to be for trade purposes. The vast majority of imports in these years were of Horsfield’s Tortoises. Following the ban in imports of wild individuals, imports of Spur-thighed and Hermann’s Tortoises to Britain rose in 2000 and 2001, almost entirely as a result of demand for commercial trade. The majority of tortoises imported into Britain are destined for the domestic market, not for re-export. This is illustrated by the import data for 1996 to 2001. Britain imported a total of

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14,812 live tortoises, of 16 different species; yet by comparison exported a total of only 155 live tortoises of 13 different species (mainly to Japan and the USA). Tortoises of wild origin dominate the trade for the period 1996-2001, Source of imports with 80% of tortoises imported recorded as wild-caught up until 2000. This proportion dropped to 65% in 2001, by which time imports to the EU of most wild-caught tortoise species in trade had been banned. In 2001, 1494 Spur-thighed Tortoises were imported from stocks declared to be captive-bred in the Lebanon and 467 Hermann’s Tortoises from such stocks in Slovenia. The almost triple-fold increase in tortoise imports to Britain from 2000 to 2001 was largely accounted for by this trade. Since June 2002, 1250 Hermann’s Tortoises have been imported commercially from captive-bred stocks. Total imports of Horsfield’s Tortoises (numbering 5911) were Main species imported more than double those of any other tortoise species for the period 1996-2001. The next most heavily imported species was the Leopard Tortoise, followed by the African Spurred Tortoise. Imports of Spur-thighed Tortoises and Hermann’s Tortoises rose sharply after the importation of wild-caught Horsfield’s Tortoises was banned in 1999. Numbers of all other main tortoise species imported to Britain during the period were in quantities under 1000 and in several cases under 100 (see table below).

Briitiish iimports ffrom outsiide the EU off the maiin tortoiise speciies iin trade 1996-2001 Common name Scientific name EU Number 1984 1999 (Tortoise) Annex imported Import Import Ban Ban Elongated Indotestudo elongata A 100 ? Pancake Malacochersus tornieri A 40 Spur-thighed Testudo graeca A 1546 ? Hermann’s Testudo hermanni A 1082 ? Kleinmann’s Testudo kleinmanni A 8 ? Marginated Testudo marginata A 25 ? Horsfield’s Testudo horsfieldii B 5911 ? Indian Star Geochelone elegans B 36 ? Aldabran Geochelone gigantea B 22 ? Red-footed Geochelone carbonaria B 789 Yellow-footed Geochelone denticulata B 122 ? Leopard Geochelone pardalis B 2891 ? African Spurred Geochelone sulcata B 1793 Bell’s Hingeback Kinixys belliana B 233 ? Serrated Hingeback Kinixys erosa B 86 ? Home's Hingeback Kinixys homeana B 128 ? 14,812

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Briitiish iimports ffrom outsiide the EU off Testudo tortoiise speciies 1996-2002

4000 Spur thighed 3500 Hermanns 3000 Horsfields Kleinmanns 2500 Marginated 2000

1500

1000

500

0 1996 1997 1998 1999 2000 2001 2002

The usefulness of Article 10 Case study: the role of Article 10 Certificates Certificates as a means of investigating tortoise trade in Britain lies in their ability to indicate a whole category of trade that would otherwise go completely unrecorded. The graph below gives the number of Article 10 Certificates issued each year, 1996-2002, for three CITES Appendix II/EU Annex A tortoise species – Spur-thighed, Hermann’s and Marginated Tortoises. As an Article 10 Certificate must be issued each time a tortoise is sold (unless microchipped, which can only be done when the tortoise shell is longer than 10 cm), the graph does not show actual numbers of these tortoises in trade. From the information gathered during this study, it is evident that tortoises can be sold between traders three or four times from point of entry into Britain to final destination. However, it is also evident that many businesses do not transfer Article 10 Certificates into their own name prior to sale and these transactions would not then be recorded by Defra.

Totall Briitiish Artiiclle 10 Certiiffiicates iissued ffor spur-thiighed,, Hermann’’s and Margiinated Tortoiises 1996-2002

4000 3500 Spur thighed Hermann’s 3000 Marginated 2500 2000 1500

1000 500 0 1996 1997 1998 1999 2000 2001 2002

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Despite these caveats, it is possible to have a greater understanding of trade in these tortoises in Britain from these figures. For example, CITES data, which only show numbers of these tortoises imported into Britain from outside the EU, record that fewer than 50 Spur- thighed, Hermann’s and Marginated Tortoises combined were imported directly into Britain from 1997 to 1999. By contrast, the number of Article 10 Certificates issued for sales of these three species each year between 1997 and 1999 was 2000-3000. In other words, CITES data show an average of 12 of these tortoises entering Britain between 1997-99 from outside the EU, while during the same time approximately 8000 Article 10 Certificates were issued for these same species. Captive-breeding capacity for these three species in Britain during the years in question can only account for 6000 of the certificates issued. Therefore, the remainder of 2000 must represent tortoises that entered Britain either illegally or legally from another EU country (in which case no import permits would be required on entry to Britain). An alternative scenario is that breeders in Britain are over declaring the numbers of tortoises they are breeding and supplementing their stock with illegally taken tortoises, which are legitimised through the licensing system. From 1999 to 2002, the number of certificates issued was higher than in previous years and at the same time Defra data shows imports of captive-bred Spur-thighed and Hermann’s Tortoises from outside the EU increased. Information provided by traders interviewed during this study indicates that numbers of tortoises coming into Britain from the EU also increased during the period 2000-2002. According to these traders, at least 1000 Spur-thighed Tortoises and 1000 Hermann’s Tortoises were brought into Britain from other EU countries in 2001. Judging from this information and CITES data, this would mean that at least 3500 Spur-thighed and Hermann’s Tortoises were brought into Britain in 2001 – all reportedly captive-bred from sources outside Britain. Adding to this the number of applications received from British breeders, brings the total number of tortoises with Article 10 certificates on sale in Britain in 2001 to over 6000. Article 10 Certificates are useful as an indicator of increased captive-breeding of tortoises within Britain. There has been an overall increase in the number of Article 10 Certificates issued to British breeders for Spur-thighed, Hermann’s and Marginated Tortoises from 1996 to 2002 (see graph below).

Briitiish breeder Artiiclle 10 certiiffiicate applliicatiions ffor Spur-thiighed,, Hermann’’s and Margiinated Tortoiises 1996-2002

1800 Spur thighed Tortoise Hermann’s Tortoise Marginated Tortoise 1600

1400

1200

1000

800

600

400

200

0 1997 1998 1999 2000 2001 2002

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Shipments of tortoises arriving from outside the EU are Legal trade routes to Britain usually transported by air into Britain. These shipments are accompanied by import and export permits, to be cleared through Customs. Prior to September 1999, air shipments containing Horsfield’s Tortoises were entering Britain from the Ukraine and from Uzbekistan. In 2000, the majority of air shipments of tortoises were of Hermann’s Tortoises from Slovenia and in 2001 air shipments comprised both Hermann’s Tortoises from Slovenia and Spur-thighed Tortoises from Lebanon. Trade within the EU is predominantly transported by road. British traders travel to mainland Europe to collect their orders. This is often timed around one of the major annual reptile shows that take place in the Netherlands or Germany. Large numbers of tortoises as well as other reptiles are purchased at these shows and then transported back to Britain for onward sale. Traders from Britain will either use the ferry or channel tunnel as their access point to the European mainland. Travel time rarely exceeds 12 hours from Germany to London and is less from the Netherlands. As this trade is within the EU, no import or export permits are required to move the tortoises to Britain. However, as they are being transported for onward sale, all captive-bred tortoises should be accompanied by Article 10 Certificates. Wild-caught tortoises listed on EU Annex A or otherwise banned from ILLEGAL TRADE import are still entering the pet and specialist collectors trade in Britain. These tortoises are smuggled to Britain from their countries of origin, often concealed in luggage. When young, tortoises are very easy to smuggle, being small, quiet and fairly still; they can also survive for relatively long periods in confined conditions without food and water. These smuggled tortoises either go directly to specialist keepers or are laundered into the pet market where they can be sold as captive-bred animals from British or other European breeders. Seizures that have occurred throughout Europe give an indication Smuggling in Europe of the existence of this illegal trade, though it is known that much is not detected. Below are a few examples of the types of seizures that have taken place. 1999 A German smuggler was convicted in South Africa for exporting Angulated Germany Germany Tortoises without the necessary permits. The tortoises had been packaged in parcels to be sent by airmail to the smuggler's home address. December 1996 Customs seized 204 Hermann’s Tortoises, 198 Horsfield’s Tortoises, 26 Spur-thighed Tortoises and 47 Kleinmann’s Tortoises that were hidden in two vehicles being driven from Poland to Germany by Polish nationals. July 1996 Customs confiscated three Radiated Tortoises, 282 Horsfield’s Tortoises, 30 Hermann’s Tortoises, 22 Spur-thighed Tortoises and five Indian Star Tortoises. The tortoises had been smuggled into Germany by four Slovakian nationals and were to be sold to reptile traders and private collectors. The tortoises were wild-collected. March 1998 As a result of search warrants on a reptile trader, 282 live and 92 Belgium Bellgiium dead reptiles were seized. These included three Plowshare Tortoises, one Radiated Tortoise, 17 Kleinmann’s Tortoises, 20 Marginated Tortoises, five Spider Tortoises and four Horsfield’s Tortoises. The majority of the tortoises had been imported illegally from the Czech Republic and false documents had been used to legalise the transactions prior to their redistribution to buyers in the EU. The illegal trader had declared the tortoises were captive-bred to the Belgium authorities and applied for Article 10 Certificates to legitimise the

TRAFFIC / Defra 11 Selling like hot cakes sale. Plowshare Tortoises are the rarest tortoises in the world with only several hundred remaining in the wild in Madagascar. May 1999 Customs seized 450 live tortoises, which had been smuggled from France France Madagascar in false-bottomed bags by three Malagasy nationals living in Paris. The tortoises smuggled were 120 Radiated Tortoises and 330 Spider Tortoises, which were to be sold to traders in Germany and the Netherlands. June 2001 Customs seized 649 Spur-thighed and Kleinmann's Tortoises from two Poland Polland Lithuanians who had flown from Syria. The animals had been transported in small cages that were wrapped with plastic bags and hidden in hand luggage.

The table below provides a summary of known tortoise seizures in Europe from 1994 to 2001 and includes the figures for Britain. Nearly 7000 tortoises were seized in this period, evidence of a large illegal trade in tortoises, especially since these seizures represent only a small portion of the actual illegal trade that occurs.

Recorded seiizures iin Europe 1994–2001 Common name Scientific name EU Annex / Total (Tortoise) CITES Appendix Elongated Indotestudo elongata B / II 50 Pancake Malacochersus tornieri A / II 43 Spur-thighed Testudo graeca A / II 1287 Hermann’s Testudo hermanni A / II 1187 Kleinmann’s Testudo kleinmanni A / I 117 Marginated Testudo marginata A / II 106 Horsfield’s Testudo horsfieldii A / II 2239 Indian Star Geochelone elegans B / II 52 Radiated Geochelone radiata B / II 212 Red-footed Geochelone carbonaria B / II 161 Plowshare Geochelone yniphora A / I 6 Leopard Geochelone pardalis B / II 321 Bells Hingeback Kinixys belliana B / II 28 Spider Pyxis planicauda B / II 340 Unknown Unknown species A & B / I & II 496 Total 6645

CITES trade data for seizures are far from Seizures of smuggled tortoises in Britain complete. According to these data, only 370 tortoises, comprising nine species, were confiscated between 1996 and 2001 at British points of entry. More accurate confiscation figures were obtained from HMCE. These report 1808 tortoises of 17 different species confiscated between 1996 and 2001 – almost five times the number reported by CITES data. In 2002 alone, a further 499 tortoises have been confiscated.

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Seizures have primarily been of tortoise species most in demand in trade; the top five in terms of numbers seized are Spur-thighed, Hermann's, Horsfield's, Leopard and Red-footed Tortoises (see table below).

Seiizures off tortoiises by Briitiish Customs 1996-2002 Common name EU Year Annex 1996 1997 1998 1999 2000 2001 2002 Total Elongated A 0 0 50 0 0 0 0 50 Pancake A 1 0 40 0 1 0 0 42 Spur-thighed A 10 19 14 23 14 44 3 124 Hermann’s A 1 169 13 0 121 5 0 309 Kleinmann’s A 0 3 2 2 2 3 0 12 Marginated A 0 0 3 0 8 49 0 60 Horsfield’s B 0 1 15 20 1 710 0 747 Indian Star B 0 20 6 0 0 0 1 26 Argentinean B 1 0 0 0 1 0 1 2 Red footed B 13 0 0 18 0 1 1 32 Yellow-footed B 16 0 0 1 0 0 0 17 Leopard B 101 108 0 0 0 112 384 321 Hingeback B 25 0 2 0 0 0 95 27 Unknown A / B 7 0 7 25 0 0 14 39 Total 175 320 152 89 148 924 499 2307

There is a trend in Britain towards acquiring tortoises Illegal trade routes to Britain from other countries within the EU, rather than importing them direct from countries outside the EU. As there is no need for permits to move tortoises between EU countries and as there is an enormous volume of goods moved within the EU, this reduces the chances of detection for any illegal trader. Seizures information shows that illegal importations have been attempted into the EU from the following countries: Argentina; Czech Republic; Madagascar; Poland; Slovakia; South Africa; Syria; Tajikistan; Tunisia; Turkey and the former Yugoslavia. These tortoises were to be sold to reptile traders and private keepers. Illegal trade in wild- caught tortoises native to EU countries also takes place and a number of tortoise species found in trade are found in the wild in Greece, France, Italy and Spain. Tortoises are smuggled by a number of different transportation methods and concealed in a variety of ways. Frequently tortoises are concealed in people’s personal luggage, which is then transported across borders by car, bus, train, ship and even aboard commercial airlines. False-bottomed bags have been used, as has concealment on the person under clothes or within hand luggage. Alternatively, tortoises have been discovered concealed in cars and vans. Smuggling techniques include hiding tortoises under false floors in trucks, inside the interior coverings of caravans and behind car seats and in car doors. One large seizure in the UK of over 650 Spur-thighed Tortoises involved the concealment of the tortoises in various hiding places on a cargo ship by its crew. There have also been instances of tortoises being packaged in parcels and sent by post or international courier services.

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Evidence of illegal trade has come from a number of Illegal sales in Britain investigations carried out in Britain prior to and during this study, and includes the detection of large-scale illegal imports of tortoises and of wild-caught tortoises being sold as captive-bred animals. Awareness of the licensing system in Britain and the rest of Europe is increasing amongst traders. Although there are instances where tortoises are offered for sale with no certificates at all, it is now more common to find that a certificate accompanies a tortoise but the certificate does not correspond to the tortoise being sold (e.g. the age of the tortoise given on the certificate is not appropriate for the size of the tortoise). Sometimes, certificates may be obtained fraudulently by declaring to the issuing authority that the tortoises are captive-bred, when in fact they are wild-caught.

As wild-caught specimens of all The role of tortoise keepers in licence fraud tortoise species popular in trade are The keepers of tortoises, whether pet-owners or breeders, are often now banned from import to Britain, unwitting perpetuators of the illegal tortoise trade. There are many only captive-bred or pre-ban known instances where someone looking for a pet has purchased a tortoises should be found in British tortoise in good faith from a pet shop, specialist reptile shop, or from trade. This system for licensing a personal contact, and has been totally unaware that their purchase tortoises in Britain relies on a is illegal. Those new to keeping tortoises often rely on those selling certain level of honesty from licence them to inform them of how to care for the tortoise and of the necessity for any permits. Few members of the public would think to applicants and is therefore open to check whether the tortoises being sold were legal or not and there is abuse. Reports by the police and often a general assumption amongst the public that if something is organisations such as TRAFFIC, the on sale, particularly in a pet shop, then it is legal. This lack of Tortoise Trust and the RSPCA, awareness by buyers assists unscrupulous dealers in their illegal document that certificates are being trade. During this study there were a number of instances where duplicated, forged and used traders did not inform the buyer about the need for an Article 10 Certificate unless the buyer specifically asked about it. Some traders fraudulently. For most species, it is stated that if a buyer did not request an Article 10 Certificate, then not until they are three to five years the sale would proceed regardless and the unused certificate would old that they are large enough (with be kept for use with a tortoise that had been acquired illegally. In this a shell length greater than 10 cm) way, illegally sourced tortoises are legitimised into the trade. This to be microchipped. Therefore, wild- only becomes evident when the details on the certificate – such as caught Annex A tortoises under 10 the age of the tortoise - are noticeably different from the tortoise it cm in length can be laundered into accompanies. Evidence of illegally sourced tortoises being in the trade can become known when the purchaser has the tortoise the market with Article 10 examined by a vet. It is often the case that wild-caught tortoises Certificates under the guise of being show signs of illness when brought into captivity, such as runny nose captive-bred, as they are not syndrome or passing worms, and many purchasers have been uniquely marked. Once they are informed by their vets that, in their opinion, the tortoise they have uniquely marked with a microchip, been sold is wild-caught. Other tortoise owners only become aware the microchip code is recorded on that they have bought an illegally sourced tortoise when they come to sell it. When a prospective buyer requests an Article 10 the certificate and the microchip Certificate, this can be the first time the tortoise owner realises that code in the tortoise must match this should have been supplied at the time he or she purchased the that on the certificate. animal. This state of affairs is not helped by the fact that the majority of EU Member States other than the UK are issuing Article 10 Certificates for each tortoise for life, (these documents are called “specimen-specific Article 10 Certificates”), including for tortoises with shells under 10 cm in length. This creates the opportunity for illegally obtained tortoises to be laundered using the Article 10 Certificate system, as there is no way to match the certificate with the tortoise. For tortoises listed on Annex B and banned from import from the wild, the paper trail for each tortoise is even harder to follow. The sale of these tortoises from the wild is prohibited and the seller needs to provide evidence that the specimens were imported or acquired

TRAFFIC / Defra 14 Selling like hot cakes legally. Such evidence could include breeding history (studbook) details or at least, a signed statement that they bred the specimen offered for sale. However, there is no system in place to validate breeders’ claims for Annex B species banned from import in 1999 and no type of permit needs to be obtained from the CITES Management Authority before sale. All tortoises found on sale during this survey were claimed to be captive-bred, with the exception of Horsfield’s and Red-footed Tortoises that were originally wild-caught or ranched animals. In Britain, there have been very few prosecutions to date for the British prosecutions import or sale of tortoises, despite reliable information that offences have been committed. Listed below are summaries of court cases that were successfully prosecuted since 1990, although this may not be entirely comprehensive.

? July 2001: the owner of a zoo was fined £5000 and ordered to pay £350 costs for having on commercial display 10 Spur-thighed Tortoises and nine Hermann’s Tortoises, as well as other Annex A listed animals. ? 1998: two Egyptians received a two-month prison sentence each for illegally importing and selling four Kleinmann’s Tortoises. ? April 1995: a smuggler was found guilty of illegally importing two tortoises and was fined £200. ? July 1994: an illegal trader was given a 12-month conditional discharge plus £100 costs for offering for sale a Spur-thighed Tortoise. ? April 1991: a smuggler was found guilty of illegally importing a tortoise and two boa constrictors and was fined £1400 and £50 costs. ? In addition, a number of formal warnings and cautions have been given to individuals for illegally importing or offering tortoises for sale.

Several prosecutions by the RSPCA have been carried out because of animal welfare offences. Between 1996–2001 the RSPCA had 40 cases involving tortoises and, of these, a total of ten successful prosecutions were achieved on welfare grounds. All of these cases involved other species as well as tortoises, ranging from reptiles to domestic animals and birds. The most recent case arose after police and the RSPCA found a badly decomposed tortoise in a holding pen containing rare tortoises during a search warrant at the home of a former London zookeeper. No food, water or light had been provided to the tortoises. Their owner was found guilty in October 2001 of causing unnecessary suffering to 39 tortoises, including 14 Spur-thighed Tortoises, 16 Hermann’s Tortoises, five Marginated tortoises and four Radiated Tortoises. He received a two-year conditional discharge and was ordered to pay £12,000 costs. The Police also brought charges against the keeper for illegal sales offences but these were later dropped in favour of the RSPCA prosecution. TRAFFIC receives many calls a year claiming that tortoises are being offered for sale illegally. The RSPCA receives hundreds of calls a year concerning tortoises – both with regard to their welfare but also reports of tortoises of illegal origin. Another charity, the Tortoise Trust, receives on average four calls a week from members of the public reporting incidents of possible illegality. These include claims of tortoises sold without Article 10 Certificates and tortoises that have become ill or have died, which on examination by experts, were found to have come from the wild when they were sold to the owner as captive-bred.

TRAFFIC / Defra 15 Selling like hot cakes

TRAFFIC uncovered a number of offences in Britain resulting from investigations carried out, which included many incidences where companies were failing to comply with Article 10 licensing requirements. More worrying, the sale of tortoises without Article 10 Certificates, although not commonplace, was also encountered. It was also confirmed that photocopies of the same Article 10 Certificates were being used for the sale of multiple tortoises and that the use of forged certificates was on the increase. All these ways of evading Defra controls strongly suggest that these methods are being used to legitimise illegally sourced tortoises. The 1999 import ban resulted in a marked drop in the availability of Horsfield’s Tortoises on the market. However, traders are now becoming wise to the fact that there are few controls in place to regulate trade in Annex B species banned from import. Traders are declaring to the authorities that the Horsfield’s Tortoises they have are captive-bred, yet openly admit to customers that they are wild-caught. This also applies to a lesser degree to a number of other tortoise species that are also banned from import from the wild. The information obtained during investigations has been passed onto the appropriate authorities for action.

MARKET DYNAMICS

Tortoises in trade come from a range of sources and often their origins are not known by those who buy and trade in them. Although there are hundreds of tortoise breeders based in Britain, they are unable to supply the demand for tortoises as pets, as the majority only breed small numbers and annually many thousands of tortoises are required by keepers. Breeders in Britain generally sell direct to the tortoise keeper, rather than to wholesale or retail outlets. British traders often source their tortoises from other EU countries, where prices are significantly lower, relative to those in Britain. It is often possible for traders to travel to these countries to buy tortoises and still make a profit. It is normally the case that wild-collected and illegal tortoises are lower in price than legal captive-bred ones. This is because the investment in resources to produce captive tortoises is higher and a legitimate tortoise with a valid certificate Horsfield’s Tortoises can command a higher price, The ban in February 1999 on importation to the EU of wild-caught tortoises as there is no risk involved. It of some species included the Horsfield’s Tortoise. Horsfield’s Tortoises are is possible that the lower exported in huge numbers from the countries in their range, and many of prices in mainland Europe these tortoises were imported into the EU. From 1976 to 1999, nearly one may be an indication that the million Horsfield’s Tortoises were exported from the wild and of these, three- tortoises on sale there are quarters were imported into Europe (on average 30,000 per year). With the taken from the wild rather closure of the EU as a major market for wild Horsfield’s Tortoises, the main exporting countries of Uzbekistan and Kazakhstan are now exporting to than captive-bred. China, the Russian Federation, the USA and Japan. In Britain in 2001 there were noticeably fewer Horsfield’s Tortoises on sale and the EU-wide ban certainly changed the availability of tortoise species in trade. Defra data indicate that no Horsfield’s Tortoises have been imported into Britain (wild-caught or captive-bred) since 2000. However, while surveying traders and the availability of tortoises for this study, a different picture emerged. A number of traders were in the process of purchasing at least 400 Horsfield’s Tortoises towards the end of 2001. These traders openly admitted these Horsfield’s Tortoises were wild-caught and that they would be declared as ‘farmed’ to evade the EU ban. There has been very limited success in breeding this species in Britain and elsewhere because of the difficulty in simulating the conditions of their complex life cycle, as these tortoises naturally hibernate for periods both in winter and in summer. This increases the likelihood that demand will be met from the wild and that traders will deceive the authorities of the origins of the tortoises to legitimise illegal animals.

TRAFFIC / Defra 16 Selling like hot cakes

There are two major dealers of tortoises in Britain and they supply a large part of the trade. In 1998, a total of only three tortoise trading businesses in Britain were responsible for most tortoise imports (mostly Horsfield’s Tortoises) and, by 1999, only one business was responsible for all Horsfield’s Tortoise imports. In 2000, following the ban on wild-caught Horsfield’s Tortoises, there were no recorded imports of this species but, instead, imports of Spur-thighed Tortoises and Hermann’s Tortoises rose sharply. Most of these tortoises – all but about 200, which went to another trader - were imported by the same business. By 2001, a species split had occurred with one business being responsible for all imports of Spur-thighed Tortoises and another responsible for all imports of Hermann’s Tortoises. At least eight companies surveyed in Britain as part of this investigation obtain stock directly from suppliers in Europe, usually Germany, and many travel to Europe themselves to take delivery of orders, or to purchase stock at the larger reptile shows. On average, Hermann’s and Spur-thighed Tortoises – which make up the majority of species on sale in Britain, are purchased by traders in consignments of 50 to 200 tortoises, two or three times a year. Slovenia regularly features as the country of origin for the majority of Hermann’s Tortoises purchased in Germany.

Movement off tortoiises iin trade ffrom source to Briitiish iimporter,, whollesaller,, retaiiller and tortoiise keepers

Outside the EU EU Retailers imports GB Wholesalers & sales GB Retailers

GB Breeder GB Tortoise Keepers sales purchases

Small-scale illegal consignments bring rarer species of higher value into Britain. Species that are known to have been imported in this way include very rare species such as the Plowshare from Madagascar, Kleinmann’s from North Africa, as well as Indian Star and

TRAFFIC / Defra 17 Selling like hot cakes

Madagascan Spider Tortoises. This is an opportunistic trade that is fairly small and is for the specialist collector market. The price of a tortoise is directly related to the number of TORTOISE PRICES IN BRITAIN times that tortoise has been sold. In the case of Hermann’s and Spur-thighed Tortoises, trade prices direct from the importers were as low as £55 per tortoise but rose to a maximum of £180 per tortoise when purchasing from a trader at the end of the supply chain. Retail prices for tortoise keeper purchases ranged from a low of £125 to a high of £240. The cheapest tortoises found on sale were Hermann’s Tortoises from Slovenia available direct from a British importer. As the importer was able to sell them at £55 each and still make a profit, the price in Slovenia must be much lower but will depend on volumes purchased and frequency of orders made by the importer. The level of mark-up in price from the wholesaler to the retailer is typically around 100%. So a tortoise sold by a wholesaler for £55 will have cost the wholesaler about £25. This price differential could be an indicator that the Slovenian-sourced tortoises may not be captive-bred, as such an operation would incur high costs, which would be passed onto the purchaser. The most expensive tortoise found on retail sale to the public were adult Pancake Tortoises at £1500, adult African Spurred Tortoises at £1000, and juvenile Indian Star Tortoises at £500. Other rarer tortoises are unlikely to be sold through the standard retail outlets and are generally traded between known contacts, sometimes illegally. The rarest tortoises fetch much higher prices, at many thousands of pounds per tortoise for large breeding pairs.

CONCLUSION

The tortoise trade is big business. Over 15,000 live tortoises have been imported directly into Britain from outside the EU since 1996. Additionally, large numbers are bought within the EU and brought into Britain, and these do not appear in import statistics. With a 100% mark-up from wholesale to retail, the profits that can be made in the tortoise trade are substantial. The majority of tortoise traders are aware of the legislation in place to protect tortoise species and ensure that they abide by it. A number of other traders either lack the legislative knowledge to stay within the law or choose to ignore it and, by doing so, bring the whole trade into disrepute. As the public is generally not aware of the licensing requirements for tortoises, these disreputable traders are able to perpetuate the illegal tortoise trade with ease. Over 6,600 tortoises were seized in 10 European countries between 1994-2001, illustrating that the illegal tortoise trade is both large-scale and prevalent across Europe. Illegal tortoise trade is happening in Britain, as it is throughout the EU, as a result of smuggling. It is known that tortoises are smuggled into the EU and, once inside, these illegally sourced tortoises are very difficult for enforcement authorities to detect since there are no internal border checks inside the EU. Tortoises can therefore pass freely from one EU Member State to another. Much of the trade in tortoises to Britain comes from within the EU in this way. Licence fraud is another known method of illegal trade in tortoises. In the process of investigating the trade for this report, instances of fraud and illegal trade were detected. The Defra licensing system for issuing Article 10 Certificates is open to abuse, particularly as it is based on a certain level of trust on the part of the issuing authority. Applications for Article 10 certificates need to be thoroughly scrutinised and the information provided by applicants validated to limit the possibility of fraudulent applications being processed. It is important that more effort is made to inform traders of the requirements they need to meet when selling tortoises.

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Increased awareness of tortoise licensing requirements among the general public could be a great asset in combating illegal tortoise trade. It would help to reduce the likelihood that illegally sourced tortoises could be sold to unsuspecting buyers with a fraudulent licence, or without any licence at all. The public should also be informed that price can be a good indicator of legality or otherwise, as tortoises that have been illegally sourced are usually priced lower than those that have been obtained legally. It is only by informing the public of the current situation, through reports like these, that they can aid in uncovering illegal trade. Defra, traders and consumers need to work together to “clean up” the tortoise trade business and thereby eliminate the few rogue traders that are undermining legitimate businesses and threatening wild populations of tortoises throughout their range. Enforcement agencies need to be encouraged and supported in taking forward to prosecution any cases of illegal tortoise trade that they investigate.

SOLUTIONS

The following are suggestions for potential solutions to remedy some of the issues outlined in this study. There are many examples of INFORMING TORTOISE BUYERS, TRADERS AND BREEDERS buyers purchasing tortoises without Article 10 Certificates and only becoming aware of the law after they have made their purchase. Unless purchasers are made aware of the requirements surrounding the sale of tortoises in Britain, they will continue to perpetuate the illegal trade. Raising the awareness of traders and keepers in Britain is essential. Suggested methods for this include:

? A joint campaign by Defra, the police, Customs and the pet trade should encourage buyers to ask the right questions when they are thinking of purchasing a tortoise. If legitimate buyers are well informed, traders will not be able to sell tortoises without the necessary certificates. ? The campaign should focus on highlighting the illegal tortoise trade and the need for an Article 10 Certificate for sale and purchase of a tortoise species listed in Annex A of the EU wildlife trade regulations. ? Through the campaign, more buyers or sellers of Annex B-listed tortoises should be aware that they need to be able to prove its legal origin. ? Traders and breeders of tortoises should also be targeted to make them aware of the tortoise licensing requirements and that Defra Wildlife Inspectors will be making concerted efforts to check sellers of tortoises for possession of Article 10 Certificates and proof of legal origin of tortoises. ? Encouragement should be given to traders to apply for Article 10 Certificates for tortoises they have purchased legally and wish to sell – thereby ensuring they are not breaking the law. To this end, Defra could consider including a colourful information sheet with every Article 10 certificate issued, which can in turn be passed on to buyers. The sheet could be sponsored by interested conservation and animal welfare organisations and could include information on the husbandry, origins, conservation and legal status of the tortoise species being traded. This would add value to the tortoise being traded and ensure that it was more likely to be well-kept by its buyer.

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HELPING LAW ENFORCEMENT

? Police and Customs should be made more widely aware of the illegal trade in tortoises and the tricks used by smugglers and illegal traders to evade the law. Information should be distributed particularly to all Police Wildlife Liaison Officers and Customs Wildlife and Endangered Species Officers. ? Members of the public and traders should be encouraged to report suspected illegal trade in tortoises to the authorities, Crimestoppers or the WWF/TRAFFIC Eyes & Ears campaign. ? Legal traders, breeders and buyers should ask traders if they have Article 10 Certificates for their tortoises and, if they cannot provide them, they should be reported to Defra or the police. ? The police and Customs authorities should be supported in taking forward any cases of suspected illegal tortoise trade. They require provision of expertise (identification, forensics and veterinary), resources such as funding for housing seized tortoises, and tools and materials to assist in investigation and prosecution (e.g. microchip readers, identification manuals). ? Defra Wildlife Inspectors should have appropriate resources to make regular checks on wholesalers, retailers and other sellers of tortoises to ensure that they have the Article 10 Certificates for the tortoises they are selling. A concerted effort by Wildlife Inspectors during the period of the awareness-raising campaign suggested above would help to make traders realise that they are likely to be checked and prosecution may result if they were found to be trading illegally.

There is no doubt that the tortoise trade issues in the UK are AN EU-WIDE APPROACH linked very closely to the wider EU situation of species protection, trade and awareness. It is important that these issues be tackled more widely in the EU, as well as in the UK. Many tortoises in trade in Britain were sourced via other EU countries and traders there should be aware of the need to provide Article 10 Certificates and refuse to purchase and sell illegally sourced tortoises.

? The UK authorities should co-ordinate with the EU Commission, CITES Secretariat, World Customs Organisation, ICPO-Interpol and the EU Enforcement Working Group to review the situation and formulate partnerships for enforcement action and improved controls in the future. ? Awareness campaigns for traders, buyers, breeders and law enforcement should be promoted in the EU in a similar way to those suggested here for the UK.

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REFERENCES ACKNOWLEDGEMENTS

CITES Management Authority France 2001. CITES: Many thanks to Manas Bose, Simon Liebert, Roy Pitt, Nick Rapport Bisannuel de la France – Periode 1999-2000. P. Williams and Jane Withey at Defra for their patience and support. Thanks are also due to Alison Littlewood at CITES Management Authority Germany 1999. Biennial JNCC for guidance on the complexities of the UNICORN Report of the Federal Republic of Germany according to system. In addition, the authors are grateful to the Art 15.4c of Regulation (EC) No. 338/97 1997-1998. following for their invaluable assistance: Tim Luffman of CITES Secretariat 1997. Review of alleged infractions and HM Customs and Excise, Henny Fenwick, Andy Shipp of other problems of implementation of the Convention (Doc. the RSPCA, Jill Martin and Andy Highfield of the Tortoise 10.28). Tenth Meeting of the Conference of the Parties Trust. In addition, thanks to the Police Wildlife Liaison Harare (Zimbabwe) 9-2- June 1997. Officers who helped, in particular to Geoff Culbertson, Alan Roberts, Alan Stewart and Steve Parnwell. Thanks Defra 2002. UNICORN data 1996–2002. Unpublished. also go to Simon Milledge and Rob Quest for the use of Defra, Bristol. their pictures. Lastly, Angela Barden and Julie Gray at European Commission 1997. Council regulation (EC) No TRAFFIC International for their help with data analysis 338/97 on the Protection of the Species of Wild Fauna and and editing respectively. Flora by Regulating Trade Therein. European Commission, Brussels. Stephanie Pendry and Crawford Allan European Commission 1999. Commission regulation (EC) TRAFFIC International No 250/1999 of 2 February 1999 amending Regulation (EC) No 2473/98 suspending the introduction into the Community of specimens of certain species of wild fauna and flora. European Commission, Brussels. HMCE CITES Team 2002. Seizures Data London Airports: Tortoises 1996-2002. HMCE CITES Team, Heathrow Airport Investigation summaries obtained as personal © TRAFFIC International / Defra 2003 communications from HMCE and Police personnel, as 219a Huntingdon Road well as from information held at TRAFFIC International. Cambridge CB3 0DL Personal communications, RSPCA Special Operations Unit. RSPCA, Horsham. RSPCA 2001. Shell Shock. RSPCA, Horsham. TRAFFIC Europe 2002. The Role of the EU in the Live Reptile Trade. Unpublished Report. TRAFFIC Europe, Brussels. TRAFFIC International 1997-2001. TRAFFIC Bulletin Vol. 17 No 1 (1997); TRAFFIC Bulletin Vol. 17 No 2 (1998); TRAFFIC Bulletin Vol. 17 No 3 (1999); TRAFFIC Bulletin Email: [email protected] Web: www.traffic.org Vol. 18 No 1 (1999); TRAFFIC Bulletin Vol. 18 No 2 Global Wildlife Division (2000); TRAFFIC Bulletin Vol. 18 No 3 (2000); TRAFFIC Bulletin Vol. 19 No 1 (2001). TRAFFIC International, Temple Quay House Cambridge. 2 The Square Bristol BS1 6EB TRAFFIC International 2002. UK CITES Prosecutions Table (sourced from HMCE, Police and DEFRA records). Tel: 0117 372 8000 TRAFFIC International, Cambridge. Fax: 0117 372 8393 UNEP-WCMC 2002. Output from the CITES Annual Web: www.defra.gov.uk Report Database: Testudinidae trade 1996-2001. Unpublished. CITES Secretariat, Geneva. Front cover: Juvenile Spur-thighed Tortoise ? Stephanie Pendry / TRAFFIC International

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