Trade rules

Whale sharks, mantas and whitetips moved to CITES I

Updated 29 September 2026

At the 20th meeting of the Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES CoP20), held in Samarkand, Uzbekistan from 24 November to 4 December 2025, more than 150 Parties voted to transfer the whale shark (Rhincodon typus), all species of manta and devil rays (Mobulidae), and the oceanic whitetip shark (Carcharhinus longimanus) from Appendix II to Appendix I. The amendments entered into force on 5 March 2026, 90 days after the close of the meeting, in line with Article XV of the Convention.

What is CITES CoP20 and when did it happen?

The Convention on International Trade in Endangered Species of Wild Fauna and Flora is the only international treaty that sets trade rules across borders for wild animals and plants. It works by listing species in three Appendices, each carrying a different level of trade control. Parties are the governments that have ratified the Convention. They meet every three to four years at a Conference of the Parties, known as a CoP, to amend the Appendices, pass Resolutions, and steer how the rules are enforced.

The 20th meeting, CITES CoP20, took place in Samarkand, Uzbekistan, from 24 November to 4 December 2025, according to the CITES Secretariat's own programme and the closing statement issued by WWF. More than 150 Parties attended, including the European Union and all its Member States. The conference opened on 24 November 2025 with remarks by the CITES Secretary-General in the Silk Road city, where the CITES Secretariat said parties would consider 50 proposals to amend the Appendices.

What does it mean to move a species to Appendix I?

Appendix I is the highest level of protection under CITES. It covers species threatened with extinction, and the Convention says trade in specimens of these species must be subject to particularly strict regulation in order not to endanger their survival. In practice, Appendix I prohibits international commercial trade in wild-taken specimens and in their parts and products. Trade for non-commercial purposes, such as scientific research, can still happen, but only under permits that are tightly limited. Captive-bred Appendix I animals can be traded commercially only if the breeding operation is registered with the CITES Secretariat under a specific procedure.

Appendix II is the regulation step below that. It covers species that are not necessarily threatened with extinction now but could become so if trade is not controlled. Trade is allowed, but exporting countries have to issue permits that show the trade will not be detrimental to the survival of the species. Appendix III covers species listed at the request of a single Party that needs help from other countries to control trade in its own specimens.

Moving a species from Appendix II up to Appendix I is called an uplisting, and that is what happened at CoP20 for whale sharks, all manta and devil rays, and the oceanic whitetip shark. The species were already on Appendix II. CoP20 took them to the strongest level the Convention has.

Which sharks and rays moved to Appendix I at CoP20?

Three groups were uplisted to Appendix I at CoP20.

Whale shark (Rhincodon typus). The world's largest living fish, listed globally as Endangered on the IUCN Red List. Whale sharks were first added to CITES Appendix II in 2002. The CoP20 proposal moved them to Appendix I.

All manta and devil rays (family Mobulidae). This includes the giant oceanic manta ray, the reef manta ray, and the various devil ray species. The whole family was already on Appendix II. CoP20 uplisted the whole family to Appendix I.

Oceanic whitetip shark (Carcharhinus longimanus). A pelagic shark that was previously listed on Appendix II. CoP20 moved it to Appendix I.

For whale sharks and manta and devil rays, the Appendix I uplisting was adopted by consensus. For the oceanic whitetip shark, the adoption went to a vote, where it passed with a large majority. Those details come from the Save Our Seas Foundation's report on the meeting, written by Sarah Fowler, who attended CoP20 in Samarkand.

Why did whale sharks, manta rays and oceanic whitetips need Appendix I?

The case the proposing Parties made was that the biology of these animals cannot keep up with the rate at which they are being removed from the ocean. Whale sharks are filter feeders that take many years to mature and produce few young. Manta and devil rays have a similar life history, slow to mature and low in fecundity. Oceanic whitetip sharks, which used to be one of the most abundant large pelagic sharks on Earth, have been heavily fished for their fins.

The numbers WCS published at the opening of CoP20 frame the scale of the problem. More than 37 percent of all shark and ray species are now threatened with extinction, the group said. For shark and ray species in international trade, the proportion at risk of extinction is nearly double that figure. Pelagic shark populations on the high seas have collapsed by over 70 percent in 50 years. Reef sharks are now functionally extinct on one in five coral reefs that have been surveyed worldwide.

The WCS team argued that the listings before CoP20 were the most comprehensive suite of shark and ray protections ever brought to the Convention, and that adoption would bring nearly the entire global fin trade and the majority of shark meat trade under CITES control. Proposing Parties included the European Union, the United Kingdom, Brazil, Ecuador, Senegal, Fiji, Panama, and many others, with more than 50 governments co-sponsoring the package.

What is Appendix II, and which sharks joined it at CoP20?

Appendix II is the trade regulation step below Appendix I. It does not prohibit trade but requires exporting countries to issue permits and to make a non-detriment finding, a check that any given export will not harm the survival of the species in the wild.

CoP20 added or uplisted several groups of sharks to Appendix II.

Gulper sharks (family Centrophoridae). Deep-sea sharks that have been heavily fished for their livers, which are rich in squalene, a compound used in cosmetics and pharmaceuticals. The WCS team called these species we had not known much about previously.

Smoothhound sharks (genus Mustelus). Smaller sharks that have been a globally distributed and commercially important catch, often used for meat rather than fins.

Tope shark (Galeorhinus galeus). A dogfish already listed in some national waters and now brought into the global CITES framework.

The Save Our Seas Foundation report describes the smoothhound and tope proposal as the first listing proposal for a globally distributed, commercially important shark taxon to be adopted by consensus at a CITES CoP, an unusually strong endorsement for a fish group that was historically hard to list.

What did CoP20 do about wedgefish and giant guitarfish?

Wedgefish and giant guitarfish are rays sometimes called rhino rays because of their pointed snouts. They have been among the most valuable components of the global shark fin trade, and several species are listed as Critically Endangered on the IUCN Red List. Wedgefish and giant guitarfish species were already on CITES Appendix II after decisions taken at earlier CoPs.

At CoP20, Parties agreed to a different tool: zero export quotas. Under Article III of the Convention, the Parties that are range states for a species can set export quotas, and a quota of zero means no legal international trade. CoP20 adopted zero export quotas for all wedgefish and giant guitarfish species, in effect suspending the legal trade in their fins even though the species remain on Appendix II rather than Appendix I.

How does this change the lookalike problem in shark enforcement?

A persistent problem in CITES shark enforcement has been the lookalike issue. Customs officers often see a fin or a meat sample and cannot tell which species it came from. The Convention's answer is to list lookalike species alongside the protected species, on the grounds that trade in lookalikes is a major part of the trade in the protected species.

CoP20 applied this logic to the Appendix II proposals for smoothhounds, tope, and gulper sharks. Lookalike species were included in the proposals so that trade in sharks that are visually indistinguishable from the protected species would be regulated by the same permits. The Save Our Seas report calls this a long-running CITES tool finally catching up with the practical reality of how the fin trade actually moves.

The CITES Secretariat's own write-up of CoP20 lists the entire shark and ray package as covering around 70 species, which matches the sum of the targeted species, the lookalikes, and the species added to Appendix II. The CITES press release describes it as the largest expansion of shark and ray protections in the Convention's history.

Which non-shark proposals came out of CoP20?

Sharks and rays took most of the headlines, but Parties at CoP20 adopted proposals on other groups too.

Four species of water frogs moved to Appendix II. The Epirus water frog, the marsh frog, the Albanian water frog, and the pool frog as a lookalike species. The proposal was submitted by the European Union, North Macedonia, and Israel. All four frogs are found in freshwater habitats across Europe and North Africa, where the frog leg trade is concentrated.

Golden sandfish (Holothuria lessoni) moved to Appendix II. A sea cucumber found across Indian and Pacific Ocean reefs, listed as Endangered on the IUCN Red List and subject to heavy overfishing for the dried luxury food trade in Asia.

Guggul (Commiphora wightii) moved to Appendix II. A perennial shrub found in India, Pakistan, and Oman, whose gum has been overharvested for traditional medicines. The proposal was initially narrowly rejected by Parties in committee but was reconsidered in the final plenary and adopted with an amendment that excluded many finished products such as incense sticks and perfumes.

These were confirmed by UNEP-WCMC, which provided the scientific input behind the proposals for water frogs, golden sandfish, and guggul.

When did the new listings take effect?

CITES has a standing rule on this. Under Article XV of the Convention, any amendment to Appendix I or II adopted at a CoP enters into force 90 days after the meeting closes, except for a Party that enters a reservation. CoP20 closed on 4 December 2025. Ninety days from that date is 4 March 2026. In practice, the new listings took effect on 5 March 2026, because the Secretariat treats the 90-day clock as expiring at the end of the day before the calendar date.

From 5 March 2026 onward, any international commercial shipment of whale shark, manta ray, devil ray, or oceanic whitetip shark parts or products needs an export permit issued under the Appendix I rules, and most commercial trade is prohibited. Shipments of gulper sharks, tope sharks, and smoothhound sharks, including their lookalikes, need Appendix II export permits, with a non-detriment finding from the exporting country. These are the dates Parties that attended CoP20 worked to, and they are the dates that customs administrations around the world have been preparing for.

Why did the eel proposal fail at CoP20?

One of the higher-profile proposals at CoP20 did not pass. The European Union and Panama proposed to list all anguillid eel species, including the American, European, Japanese, and others, on Appendix II. The European eel is already on Appendix II, and the proposal aimed to extend the same trade controls to its lookalike species, which are difficult to tell apart once they have been processed.

Audrey Chambaudet of the WWF European Policy Office, quoted in WWF's closing statement, said eel trafficking is one of the most lucrative forms of wildlife crime, valued at up to 3 billion euros a year according to Europol. The proposal aimed to support enforcement by requiring permits for trade in all eel species to better protect the critically endangered European eel. It was rejected by a wide margin.

In place of the listing, Parties adopted a new Resolution on eel trade, conservation, and management that keeps the issue on the agenda for future CoPs. WWF called the Resolution a disappointment compared to the listing but a workable fallback that keeps attention focused on these species.

What does this mean for the species in this catalog?

The Creatures in Crisis catalog covers a number of species that came out of CoP20 in changed status.

The whale shark is in the catalog as Endangered and now has the strongest trade protection CITES has. The oceanic whitetip shark, also in the catalog, is in the same position. The giant oceanic manta ray and the lesser devil ray, both in the catalog, are now Appendix I as part of the family listing.

The dwarf gulper shark, the leafscale gulper shark, the mosaic gulper shark, and the broader gulper shark family in the catalog are now Appendix II. The common smooth-hound, the humpback smooth-hound, the narrownose smooth-hound, the smalleye smooth-hound, and the speckled smooth-hound are also Appendix II. The catalog also lists the African wedgefish and the smoothnose wedgefish, both of which are now under a zero export quota.

For practical purposes, the listing change does not make keeping these species legal where it was not before. National wildlife and fisheries laws sit on top of CITES, and they still apply. The change is in cross-border trade: a sale, an import, an export, a re-export, a shipment of fins or meat across a customs line. After 5 March 2026, the international legal trade in whale sharks, manta and devil rays, and oceanic whitetip sharks has effectively ended.

What does this mean for the shark fin trade?

The fin trade is where the listing change has the sharpest practical effect. Shark fins are the highest-value shark product, and the largest single driver of the international trade in sharks and rays. By uplisting the three biggest fin-bearing groups to Appendix I, and by bringing gulper, tope, and smoothhound sharks under Appendix II permits, CoP20 covered a much higher share of the global fin trade than the previous regime.

How much higher is a moving figure, and it depends on how trade is reported. CITES trade database entries are filed by Parties, often with a lag, and illegal trade by definition is not in the database. New genetic testing published before CoP20 showed that far more shark products are in circulation than appear in official CITES records, revealing a large gap between the legal trade and what is actually moving through major markets. The WCS team flagged this as a continuing enforcement problem that the new listings alone do not solve.

What the listings do change is the legal status of the trade. From 5 March 2026, any shipment of fins from an Appendix I species requires an export permit that, under Article III, the Management Authority of the exporting country should not issue for a primarily commercial purpose. Shipments of fins from Appendix II species need a non-detriment finding. Customs authorities in the major importing markets, including Hong Kong SAR, the European Union, and the United States, have been working with the CITES Secretariat on identification guides to tell the listed species from their unlisted cousins.

What about the sharks CoP20 did not change?

Listing proposals only change the species on the table. Parties at CoP20 also considered proposals that did not pass, or that were withdrawn. The freshwater eel package was rejected, as covered above. Some other proposals were deferred, withdrawn, or amended in committee. Several non-shark proposals on African carnivores and pangolins that conservation groups had backed went in different directions, some adopted and some not.

For sharks specifically, this means several commercially important species remained on Appendix II rather than being uplisted. Blue sharks, shortfin mako sharks, and several hammerhead species were not the subject of new uplisting proposals at CoP20. These species continue to be regulated under the rules in place since CoP19 in 2022, when the requiem shark family was listed. The CITES press release for CoP20 emphasised that the new listings build on the CoP19 package rather than replace it.

What is the enforcement picture after CoP20?

Enforcement is the part of CITES that decides whether a paper rule is a real one. CoP20 did not change the basic structure: each Party designates a Scientific Authority and a Management Authority that issue the permits, and customs and law enforcement agencies enforce the rules at the border.

CoP20 added practical tools. Free species identification guides and genetic testing toolkits were already available before the meeting from WCS, TRAFFIC, and the FAO, and these were promoted at CoP20 as the resources customs officers and fisheries inspectors can use to identify fins, meat, and other products at the species level. The WWF team said that having these tools already in place makes rapid implementation feasible for governments once listings pass.

The flip side is the gap that genetic testing has exposed. New pre-CoP20 work found that the trade in shark products in major markets is far larger than official CITES records show, suggesting widespread illegal or unreported trade. CoP20 cannot close that gap on its own. The CITES Standing Committee, which meets between CoPs, is expected to track implementation and report back to the next Conference.

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