Cuban proposal to downlist the Caribbean hawksbill turtle


La Havana, September 27th of 1999

To: Management and Scientific Authorities CITES of:

Aruba, Antigua y Barbuda, Netherlands Antilles, Bahamas, Barbados, Belice, Colombia, Costa Rica, Dominica, Republica Dominicana, El Salvador, Estados Unidos de America, Francia, Guetamala, Guyana, Islas Ciaman, Islas Turks Y Caicos, Islas Virgenes Britanicas, Honduras, Jamaica, Mexico, Nicaragua, Paises Bajos, Panama, Reino Unido de Gran Brotana e Ireland, Norte, Saint Kitts y Nevis, Santa Lucia, San Vincente y las Granadinos, Suriham, Trinidad y Tobago, y Venezuela

Dear Sir/Madam:

The Republic of Cuba is considering the possibility of presenting a proposal to the 11th Conference of the Parties of CITES, to be held in April 2000 in Nairobi, to transfer to Appendix II that segment of the Caribbean population of Eretmochelys imbricata present in Cuban waters.

As part of the consultative process with countries in the region, we enclose a draft of the proposal summary of review. We are interested to receive any comments, opinions or other matters of interest relating to the proposal.

We would appreciate it if you could send your comments by Facsimile as soon as possible.

Many greetings and my sincerest considerations,

Dra. Silvia Alvarez Rossell
Centro de Inspeccion y Control Ambiental
Autoridad Adminstrativa CITES Cuba

Tel. (537) 22 7573
Telfax (537) 22 7030 24 5895


An annotated transfer of that part of the Caribbean population of Hawksbill Turtles (Eretmochelys imbricata) inhabiting Cuban waters*, from Appendix I to Appendix II pursuant to Resolution Conf. 9.24 for the exclusive purposes of allowing:

  1. The export in one shipment of all existing registered stocks of shell accumulated from Cuba’s management program between 1993 and March 2000 (approximately 7200 kg) to Japan which will not re-export; and,
  2. The international trade each year thereafter to Japan or other Parties with equivalent controls which will not re-export, of the shell produced from the traditional harvest, which will not exceed 500 individual E. imbricata each year.
*In accordance with Article I(a) of the Convention, the population for which a transfer to Appendix II is sought is comprised of that segment of the regional Caribbean population bounded by the geographic limits of Cuban waters and includes E. imbricata resident within Cuban waters and immigrants and emigrants, only while they are located within Cuban waters and under the jurisdiction of Cuba.


Republic of Cuba


1. Taxonomy (Resolution Conf. 9.24, Annex 6.C.1)

1.1 Class: Reptile
1.2 Order: Testudinata
1.3 Family: Cheloniidae
1.4 Species: Eretmochelys imbricata
1.5 Scientific synonyms: none
1.6 Common names: Torgua de carey (Spanish), hawksbill turtle (English), tortue caret (French), see Marquez (1990) for local names
1.7 Code number: A-301.003.003.001

2. Executive Summary

2.1 Regional Perspective

2.1.1. The Caribbean region population of E. imbricata is a mosaic of subpopulations of different sizes, with different centers of activity and overlapping ranges of movement. No subpopulations are “closed” but nether are they randomly mixed. Their long term conservation, management and sustainable use requires attention at national and regional levels, in both the short-term and long-term.

2.1.2. Eretmochelys imbricata inhabit inshore ecosystems and regardless of movements between foraging and nesting areas the majority of the population is within the national waters of different countries at any one point in time. Improving and consolidating management at national level, within existing legal frameworks, is fundamental to improving conservation at both national and regional levels.

2.1.3. The status of E. imbricata in the waters of different Caribbean nations reflects the area of habitat in different nations (80% of coral reefs in the Caribbean are restricted to 20% of the nations), the quality of habitat, past and present management practices, and proximity to major population foraging and nesting areas. No two nations are the same and there is no single “status” category nor management prescription that is appropriate in all nations.

2.1.4. Cuba has long been aware of the importance of regional co-operation in E. imbricata conservation and management, and has contributed positively towards it. Cuba held a regional meeting to discuss the conservation and management of E. imbricata; undertook three regional training programs and workshops; joined regional forums germane to this issue (SPAW Protocol, CTMRG, IUCN); contributed to debate on the issue within international treaties (CBD, CITES, IACCPST); participated in numerous technical and scientific conferences on marine turtles; entered into bilateral co-operative agreements with regional neighbors; published research results openly and transparently; visited regional neighbors to discuss Cuba’s management program and to dispel misinformation; and, has continually opened its program to international scrutiny and constructive criticism.

2.1.5. From a regional perspective, there is no doubt that the transfer of national subpopulations from Appendix I to Appendix II by countries seeking it, who can provide supportive data, is more precautionary than transferring the global or Caribbean population to Appendix II in one step. There is no conflict between advancing national and regional management together and neither can wait until the other is perfect.

2.1.6. Under international law, Cuba has responsibility for the geographically bounded population of E. imbricata in Cuban waters which contain an estimated 32% of all coral reef habitat in the Caribbean. The E. imbricata population in Cuban waters meets the criteria for Appendix II (Annex 2a of Resolution Conf. 9.24) and not the criteria for Appendix I (Annex I of Resolution Conf. 9.24), taking into account the “Precautionary Measures” (Annex 4 of Resolution Conf. 9.24). Transfer to Appendix II will contribute to Cuba’s national conservation efforts and will consolidate responsible management for a significant portion of E. imbricata within the Caribbean.

2.1.7. Strictly controlled legal trade from Cuba will create a much-needed incentive for other nations in the region to invest further in E. imbricata conservation and management and will strengthen Japan’s commitment to stamping out illegal trade. To criticize and penalize Cuba for responsible conservation efforts is hardly conducive to enhancing investment in regional conservation. Cuba’s previous legal trade did not stimulate illegal trade and stockpiling and nor can future legal trade be reasonably expected to do so. Cuba’s intention to submit this proposal has stimulated regional interest in research, co-operation and improved management, not illegal trade or stockpiling.

2.2 National Perspective

2.2.1. Cuba’s management stocks of E. imbricata shell, accumulated since 1993, are a byproduct of a national conservation and management program implemented by the Government of Cuba in accordance with national laws and sovereign rights under international law(Permanent Sovereignty over Natural Resources, United Nations Geneva) Assembly, Resolution General Assembly. Resolution 1803 (XVII) Dec. 14, 1962); Declaration of the Rights to Development, United Nations General Assembly Resolution 41/128( Dec. 4 1984) Declaration of the United Nations Conference on the Human Environment. Principle 21, June 16, 1972 (Stockholm Declaration); United Nations Law of the Sea (Dec. 2, 1982). Cuban management stocks of shell have been obtained legally from Cuban waters and belong to the State.

(Figure 1 Chart [unavailable] shows Sustained Managed Harvest 1968-90, Phase Down 1990-95, and Current Traditional Harvest 1995-2000.)

(Figure 1) Harvest data (number of individuals) for E. imbricata in Cuba. Cuba voluntarily phased down its historical harvest (1991-94) to meet changed economic circumstances and contribute further to regional conservation efforts; stocks were still abundant. The E. imbricata shell Cuba stocks to export is that derived from its conservation and management program from 1983 onward, which included the period of phase down and the current traditional harvest, which under current adaptive management protocols can be sustained indefinitely.

2.2.2. When Cuba acceded to CITES in 1990 it had a national management program for conserving marine turtle resources which provided for their sustainable use for food. Turtles have been harvested in Cuba since the 1500’s and since the 1960’s legislative controls on use and consumption have been greatly strengthened. In the period 1988-90 the harvest was strictly controlled by the Ministry of Fishing Industries (MIP) using annual quotas, limited seasons, monitoring and adjustments to fishing effort (ROC 1998a; Carrillo et al. 1999). The harvest levels (average of 4744 E. imbricata individuals per year) were sustained for over two decades (Fig. 1).

2.2.3. When Cuba acceded to CITES, it entered a reservation on E. imbricata as provided for by Article XXIII of CITES because the wild population in Cuban waters was large, and did not meet the criteria for Appendix I listing. In 1976, when the Parties listed E. imbricata on Appendix I, this population was not taken into account, and nor was it considered by the IUCN in past global assessments of status (Meylan and Donnelly 1999).

2.2.4. Between 1990 and 1994 Cuba faced severe economic restrictions and fishing effort was diverted to export fisheries generating foreign exchange. The turtle fishery was phased down despite stocks being abundant. In 1994, as a further contribution to regional conservation, Cuba voluntarily reduced their marine turtle fisheries sites to less than 1% of available habitat. That is, to two local communities with a long tradition of marine turtle fishing. By 1995 the traditional harvest had been reduced from an average of 4744 individuals per year (1968-90) to an average of 406 (1995-98), with an upper ceiling of 500 per year for both areas combined. Turtle meat continues to be distributed by the State to restaurants and maternity hospitals.

2.2.5. Cuba’s traditional harvest provides definitive data for monitoring sustainability and results to date are consistent with a sustainable harvest. Juveniles are abundant in Cuban reef ecosystems and the mean size of turtle caught is stable or increasing and nest numbers are stable or increasing. Populations in neighboring countries are stable or increasing, although some may be depleted relative to the distant past (Carrillo et. al. 1999, Meylan and Donnelly 1999).

2.2.6. A significant and continuing Cuban research effort is providing new information on population dynamics, genetics, movement, general biology and ecology. That is adding greatly to regional and global knowledge of E. imbricata.

2.2.7. Because E. imbricata are abundant in parts of the Caribbean, including Cuba, and because most Caribbean nations rely on commercial fishing as a primary focus of economic activity, incidental catch of E. imbricata is widespread in the region. It is largely unavoidable and creates a management dilemma in all nations. In Cuba, live E. imbricata caught in fishery operations must be released. Dead E. imbricata are handled in two ways.

  1. Within the two traditional harvest sites, around 20 individuals (mostly juveniles) per year die in fin-fish and ray fisheries, and in “out of season” capture studies for tagging. These individuals are identified as “incidental catch” for record keeping purposes, but are otherwise treated as part of the traditional harvest from those sites and contribute to the overall ceiling of 500 individuals per year from the two sites combined.
  2. Outside the two traditional harvest sites, incidental catch is managed the same way as in most other Caribbean nations. It is illegal to possess parts of E. imbricata caught as incidental catch. The shell derived cannot be legally traded, nor can it enter the Government store for eventual export; it is usually discarded. Strong legal disincentives for fishermen to increase catch under the guise of incidental catch are in place, but these make it difficult to quantify the extent of incidental catch precisely. Data indicate that in Cuba as a whole it may involve <400 individuals (mostly juveniles) per year.

2.2.8. Management stocks of shell accumulated in the Government store since 1993, when trade with Japan ceased, have been meticulously registered and stored using a stringent method of marking and control that exceeds CITES requirements.

2.2.9. Despite recognized gaps in the scientific knowledge of species of marine turtles (Meylan 1982; Chaloupka and Musick 1997; Carrillo et al. 1998e, 1999) the wild population supporting the Cuban harvest is large. A conservative estimate is 110, 905 non-hatchlings, which includes 5865 adults (AACC 1998; Carrillo et al. 1998e, 1999), but some authorities argue(Dol et al. Heppell et al. 1995; Heppell and Crowder 1996) the population may be much larger.

2.2.10. The traditional fishery does not involve expensive infrastructure, and cannot reasonably be expected to create commercial incentives to harvest unsustainably in the future.

2.2.11. Cuba has tried to find middle-ground with organizations philosophically opposed to the consumptive use of marine turtles, including the IUCN Marine Turtle Specialist Group (MTSG). Cuba contributed to IUCN workshops revising criteria for threatened categories and has encouraged independent review of its program by the IUCN and others.

2.2.12. The purpose of the Cuban proposal to COP11 is not to increase its harvest level. It is to allow foreign exchange to be gained from a legally acquired byproduct, from an animal that is deceased. The economic benefits derived will provide considerable resources and incentives for Cuba to continue its commitment to marine turtle conservation, research, monitoring, education, training and information exchange at national, regional and international levels, and will provide social benefits to Cuban people derived from the sustainable use of a natural renewable resource in accordance with the policies of the IUCN and CBD.

2.2.13. Given support by the Parties for this proposal, Cuba makes the following undertakings:

  1. To withdraw its reservation on E. imbricata within 90 days in accordance with Annex 4, Para. B3 of resolution Conf. 9.24.
  2. To organize under the control of the CITES Secretariat the immediate export of the stocks of shell derived from the management program in Cuba, in one shipment to Japan, where equally strict controls are in place and where there will be no re-export.
  3. To continue to limit the traditional harvest of E. imbricata to a maximum of 500 individuals per year and ensure local communities receive benefits.
  4. To trade internationally the shell produced annually form the traditional harvest for the remainder of the Year 2000 and each year thereafter with Japan or other Parties, which will not re-export and have equivalent controls.
  5. After proceeds from the sale of management stocks are received, ensure an appropriate budget is made available to meet the conservation, management and research obligations made in this proposal.
  6. Provide the CITES Secretariat with an annual report on conservation, management and research of E. imbricata in Cuba which includes details of the extent of the harvest and of all monitoring and research results.
  7. Within the constraints of budget, continue to support regional efforts to conserve and manage marine turtles, through training programs, a further regional meeting and participation in regional forums.
  8. Provide the 12th Conference of the Parties with a comprehensive report on the conservation and management of E. imbricata in Cuba, and specifically provide information pertaining to Article IV2 (a) of the Convention, which requires that utilization “is not detrimental to the survival of the species.”

Turtle Happenings

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