CITES CoP20 Samarkand

What CITES Cop20 actually decided about fins in 2026

Updated 6 October 2026

Resolution Conf. 20.10, adopted at the twentieth meeting of the Conference of the Parties to CITES in Samarkand on 24 September 2026, is the single document a trader, customs officer, or prosecutor is most likely to pull when a contested box of fins turns up at a port. Read alongside the shortfin mako retention compromise in Decision 20.108 and the postponement of the thresher and devil ray listings, the picture is less a sweeping ban than a careful reorganisation of which shark and ray products can cross a border, and under which annotation.

Which fins were actually listed at Samarkand?

Two long-running proposals cleared the vote on the plenary floor in Samarkand on 23 September 2026. Proposal 51, advanced by Brazil, Costa Rica, Ecuador, the European Union, Panama, and the Philippines, added the requiem sharks of the family Carcharhinidae to Appendix II. The listing takes effect on 23 December 2026, which gives customs administrations the usual ninety days to align permits and inspection forms. Proposal 54, advanced by Fiji and a long coalition of Pacific and Indian Ocean states, added the hammerheads, Sphyrnidae, on essentially the same timetable. Both were adopted by recorded vote, and the records of the votes are in the CITES notification that posted on 25 September 2026.

A second wave of proposals was not adopted in the same form. The shortfin mako, Isurus oxyrinchus, had been the subject of Proposal 53 from Senegal and the United States, and the room narrowed around a compromise on board retention rather than trade. The result is in Decision 20.108, a directed measure that obliges range states to report retentions of makos caught under ICCAT and WCPFC quotas during 2027 and 2028, with a review back to the standing committee before CoP21. The mako itself did not move at Samarkand; the discussion did. The thresher sharks, family Alopiidae, and the mobulid devil rays, the focus of Proposal 55, were withdrawn by their proponents after the ocean working group ran out of time on 22 September. The proponents said on the record that they would refile for the next meeting, currently scheduled for 2029.

For anyone holding a shipment in a freeport or a customs shed, the practical answer is short. From 23 December 2026, fins, meat, and other products of requiem and hammerhead sharks will need a CITES export permit and a non-detriment finding from the exporting authority. The mako, the thresher, and the mobulid rays are not listed, and their fins continue to move under the rules that applied on 1 September 2026, with the new reporting overlay for the mako layered on top.

How does the new annotation work for shark fins?

Appendix II listings are usually accompanied by an annotation that carves out specific product forms, and the requiem and hammerhead listings followed the model set by the 2019 mako and the 2022 guitarfish listings. The annotation in Resolution Conf. 20.10 reads as a controlled trade, not a ban. Wild-taken specimens are traded under the standard Appendix II permit regime. Specimens from a CITES-registered captive-breeding operation or a CITES-registered aquaculture facility are traded under a different and lighter permit set, which is significant for the handful of shark breeding facilities that exist in South Africa, Australia, and the United Arab Emirates.

The annotation also sets the product codes that customs officers should be looking for on permits. The classic code clash on fins is the one between a fin traded as a specimen, which is subject to Appendix II, and a fin traded as a by-product of a meat fishery, which under the annotation follows the underlying fishery permit rather than a CITES permit. The new annotation carries the by-product carve-over for the requiem and hammerhead listings, which means that a fin from a legitimately caught requiem shark exported in the same shipment as the carcass can move under the fishery paperwork, while a fin shipped on its own has to clear Appendix II. The CITES Secretariat has published the full text of the proposals and the adopted annotations in the CoP20 documents portal.

Anyone reading Resolution Conf. 20.10 for the first time will also want to read Decision 20.106 alongside it. That decision instructs the Animals Committee to revisit the lookalike species issue for the requiem and hammerhead listings before the next meeting, with a working group chaired by the European Union and report-back dates at the 2027 and 2028 Animals Committee sessions. Lookalikes were the practical reason for the long delay in getting the original silky and thresher listings; the new listings are written to anticipate the same problem.

Why was the thresher and devil ray package pulled?

The thresher and devil ray proposal was never going to fail in a straight vote. It was pulled because the working group ran out of time, and the proponents made a tactical decision to refile. Reading the working group notes published in CoP20 Doc. 73.2, three things are clear. First, the data packages on mobulid bycatch were still incomplete for the Indian Ocean, and several range states were not ready to vote for a listing that they had not had a chance to verify. Second, the discussion of the by-product carve-over for thresher fins got tangled up with the new annotation in Resolution Conf. 20.10, and the proponents did not want to vote on two overlapping annotations in the same afternoon. Third, the EU and a coalition of Latin American states wanted the devil ray listing to be discussed alongside a complementary proposal on the giant guitarfish, which had been adopted in 2022 and which the same coalition thought was being under-implemented.

The withdrawal is not a defeat. It is a reorganisation. The proponents have put on record, in Doc. 73.2, an intention to file a thresher listing for the 2029 meeting, and a mobulid listing for the 2029 meeting, with a more detailed lookalike annex and a clearer by-product carve-over. The CITES Secretariat has been asked to facilitate a technical workshop on the data gaps in 2027, with funding from the European Union. The signal for traders is that thresher and mobulid fins are not yet subject to Appendix II, and that the next eighteen months are the window in which the data package will be built.

What about the shortfin mako compromise?

The shortfin mako has been a CITES issue since 2019, when it was listed on Appendix II over the objection of several major range states. The listing has been the source of repeated friction with ICCAT and WCPFC, the two regional fisheries management organisations that set the actual mako quotas. The Samarkand compromise in Decision 20.108 is the first time CITES has formally told the RFMOs what the convention expects to see in the way of retention reporting.

Decision 20.108 says, in plain terms, that any range state that wishes to retain a shortfin mako caught under an ICCAT or WCPFC quota during 2027 or 2028 must report the retention to the CITES Secretariat within ninety days of the end of the fishing year, with a copy to the Animals Committee. The decision also asks the Secretariat to publish an annual summary of retentions, and to flag any range state that has not reported for two consecutive years. The language is a recommendation rather than a sanction, but it is the strongest language CITES has used on retention for any shark species.

For the conservation community, the question is whether retention reporting is enough. The mako population is assessed by ICCAT in 2024 as still overfished in the North Atlantic, and the WCPFC stock is the subject of a benchmark assessment that was due in 2026. The CITES decision does not, on its own, change the catch limit; it changes the visibility of the catch. The expectation inside the working group, recorded in the minutes, is that retention reporting will turn a covert problem into a documented one, and that the documented problem will be easier to address at CoP21.

What is the legal chain behind the Samarkand decisions?

CITES is a treaty instrument, not a regulation. The decisions taken at Samarkand enter into force under the procedures set out in Article XV of the convention, and they bind the parties in the way the convention binds them. A new Appendix II listing takes effect ninety days after the close of the meeting, which is 23 December 2026 for the requiem and hammerhead listings. A decision of the conference of the parties, such as Decision 20.108 on the mako, takes effect on adoption unless the parties specify a different date; the Samarkand decisions took effect on 24 September 2026.

For an importer in the United States, the CITES obligation is then run through the US Endangered Species Act, the US implementation of CITES, and the US fish and wildlife service's port inspection programme. The US Fish and Wildlife Service has indicated, in a note in the Federal Register of 1 October 2026, that it will publish a proposed rule to align the Code of Federal Regulations with the requiem and hammerhead listings before the listings take effect. For an importer in the European Union, the obligation is run through Council Regulation 338/97, the Union's CITES implementing regulation, and the European Commission has indicated that the requiem and hammerhead listings will be added to Annex B of that regulation by 23 December 2026. For an importer in Japan, the obligation is run through the Foreign Exchange and Foreign Trade Act and the Convention on International Trade in Endangered Species Act, and the Ministry of the Environment is expected to publish guidance for traders by mid-November 2026.

None of this is automatic. The CITES listing creates the obligation; the national implementing instruments do the work of turning the obligation into a permit requirement. The window between a CITES listing and its national implementation is the most common period in which contested shipments move, and the window is short. Anyone who trades in shark fins should treat 23 December 2026 as the day on which the rule book changes.

What does Samarkand not do for shark fins?

The Samarkand package is not a ban on the shark fin trade, and reading it as one is a mistake. The 2019 mako listing, the 2022 guitarfish and wedgefish listing, and the 2026 requiem and hammerhead listings together cover a substantial share of the species that appear in the Hong Kong and Singapore fin markets, but they leave the thresher, the mobulid rays, the mako, the blue shark, the porbeagle, and the school shark outside Appendix II. The species that are not listed can still be traded in fins without a CITES permit, subject to national measures.

The package also does not address the domestic fin trade, which is the largest share of the trade in absolute volume. CITES regulates international trade, and the decisions taken at Samarkand are decisions about what can cross a border. The trade in fins inside a country is a matter for the country's own law, and the Samarkand documents do not purport to direct the parties to do anything about their domestic markets. The conservation community, led by WildAid and supported by Shark Advocates, has been asking the parties to address the domestic trade for at least a decade, and the Samarkand meeting did not move on the question.

Finally, the Samarkand package does not change the IUCN Red List. The requiem sharks and the hammerheads have had a complicated set of Red List assessments over the last three cycles, and the listing at CITES is a separate process from the assessment at IUCN. The 2026 update to the Red List, which was the subject of a separate post, did re-assess several requiem species, and the species-by-species result will need to be read against the listing at the genus and family level. The two organisations are not in lockstep, and traders should not assume that a species that is on the CITES Appendix is the same as a species that is on the Red List.

What is the next thing to watch?

Three dates. The first is 23 December 2026, the day the requiem and hammerhead listings take effect. The second is the Animals Committee meeting in mid-2027, which is the first checkpoint for the lookalike species work directed by Decision 20.106. The third is the publication of the ICCAT stock assessment for the shortfin mako, due in the second half of 2027, which will be the data point that the standing committee reads against the retention reports under Decision 20.108.

There is also a working-level milestone. The CITES Secretariat has been asked, in Decision 20.109, to publish a guidance document on the identification of fins in trade, with a particular focus on the lookalike problem. The guidance is expected by the end of 2027. The guidance is the document that a customs inspector in Hong Kong, in Los Angeles, or in Felixstowe will eventually use to decide whether a fin in a box is a requiem fin, a hammerhead fin, a thresher fin, or a fin from a non-listed species. The trade will move on the granularity of that guidance more than on the headline of the Samarkand meeting.