Regulators Failing to Substantiate Conservation Benefits of Wildlife Fashion Trade, Argues Study

The study tests regulators, not rhetoric. Instead of evaluating industry claims directly, the authors tested the evidentiary foundations of regulatory approval. Governments with direct responsibility for harvest or trade in four frequently commercialised species — saltwater crocodiles, reticulated pythons, Burmese pythons and South African ostriches — were formally surveyed. The CITES Secretariat was also approached. The aim was straightforward: to see what independent, non-trade data regulators could produce to justify permissive trade.

Authorities were asked to provide five consecutive years of objective scientific evidence supporting the proposition that commercial use of these species is beneficial or necessary for their survival in the wild. Trade-generated reports were excluded from consideration on the grounds that they derive from vested interests. The burden was placed squarely on regulatory bodies to demonstrate that their policies rested on impartial data.

The survey covered national and sub-national departments across Australia, Bangladesh, Cambodia, China, India, Indonesia, Malaysia, Myanmar, Nepal, the Philippines, Singapore, South Africa, Thailand and Vietnam. Questions were issued in writing, with response periods aligned to formal governmental and CITES protocols. Follow-up reminders were sent, and additional time was offered where necessary. After six weeks — more than twice the standard response window indicated in official procedures — the inquiry was formally closed.

The response rate was limited. Of the 15 government departments contacted across relevant jurisdictions, only three supplied any response containing data. Those responses were partial and largely administrative in nature. The Singapore authorities clarified that they neither harvest nor captive-breed reticulated pythons. The Philippines confirmed the existence of registered crocodile farms but did not provide independent conservation evidence. Queensland supplied limited information tied to its monitoring framework. Other governments did not provide substantive replies within the response period.

The CITES Secretariat acknowledged receipt of the questionnaire but did not furnish independent evidentiary material in response to the specific survey questions. No dataset was produced demonstrating that the trade in the four target species delivers measurable conservation gains. Across the surveyed institutions, no relevant independent evidence was supplied to substantiate the claim that the wildlife fashion industry benefits species survival.

The absence of material cannot automatically be interpreted as proof that no such data exist. It does, however, illuminate a structural asymmetry. Regulatory systems operate on the assumption that sustainability claims are supported by credible monitoring and analysis. Yet when formally requested to disclose that analytical basis, the record presented was sparse. In effect, the exercise shows how hard it is to locate the independent evidence that permissive policy is supposed to rest on.

For a sector that trades on conservation legitimacy, the gap matters. If sustainability is the justification, regulators need to show—clearly and independently—what evidence supports it.

The limited response from regulators forms part of a wider pattern identified in the study: structural weaknesses in how wildlife trade governance assesses and communicates sustainability. The debate is often framed as a contest between prohibition and regulated use. The evidence reviewed here suggests the more immediate issue lies in how claims of conservation benefit are validated, monitored and enforced.

Central to industry defence is the proposition that captive breeding, ranching and farming reduce pressure on wild populations. Yet captive production has not been proven to eliminate harvesting pressure and may, in some circumstances, generate additional demand that would not otherwise exist. The ready availability of farmed skins can stabilise supply, but it may also normalise consumption and expand market expectations. In that context, commercial systems risk managing trade-generated pressures rather than removing them.

A second problem is data integrity. The reliability of sustainability assessments can be compromised by mislabelling of wild-caught animals as captive-bred, the pooling of information across different markets, and weak monitoring and control mechanisms. Where traceability systems are incomplete or enforcement uneven, population data and trade figures can obscure as much as they reveal. Such weaknesses complicate efforts to determine whether observed stability reflects biological resilience or reporting limitations.

Pooling data from international commercial trade and local subsistence use further complicates interpretation. When figures from small-scale, community-level exploitation are aggregated with export-driven trade flows, distinctions in scale, intent and ecological impact can be blurred. This aggregation risks presenting composite stability where pressures may in fact be concentrated in particular geographies or supply chains. Without disaggregated datasets and transparent methodology, headline numbers may conceal uneven population stress.

The design of the regulatory system adds another layer. International wildlife trade regulation, including CITES frameworks, operates largely through a negative-list model, in which restrictions intensify after evidence of harm accumulates. That reactive structure places a significant evidentiary burden on those seeking tighter controls, while commercial activity can proceed in the interim. In practice, the threshold for intervention may be high, and the documentation required to demonstrate harm substantial.

The study argues that these elements — market incentives, data opacity and reactive regulation — interact in ways that favour continuity over precaution. Governments and multilateral bodies maintain mandates that accommodate wildlife commercialisation, and policy development frequently draws on trade monitoring systems embedded within that same ecosystem. That does not require intentional bias. It is enough that the system, as built, tends to default to continuity unless strong contrary evidence forces change.

None of these dynamics prove that trade in the four target species is unsustainable. They do, however, illustrate how institutional design can shape outcomes independently of ecological reality. When conservation legitimacy depends on confidence in monitoring systems and data quality, structural vulnerabilities become more than technical concerns. They become central to assessing whether sustainability claims can withstand independent scrutiny.

After mapping the evidence gaps, the authors set out what they think regulators should change. Its central argument is not that all wildlife trade must immediately cease, but that permissive commerce should not proceed in the absence of demonstrable, independent proof of safety and conservation benefit. In its current configuration, the regulatory burden is largely inverted: trade is permitted unless clear evidence of harm accumulates.

A primary recommendation is the wider application of the precautionary principle, supported by high-level monitoring and enforcement. Where objective data are lacking, unclear or contested, the default position should not favour commodification. Instead, regulators should require advance demonstration that commercial use satisfies criteria relating to animal welfare, species conservation, ecological protection, public health and socio-economic stability. This approach reframes sustainability from a declarative label to a condition that must be substantiated before market access is granted.

Closely linked to this shift is the adoption of positive lists. Under a positive-list model, the burden of proof rests with trade proponents to show that a species and its commercial pathway meet defined safety thresholds. Such systems are already standard in other regulatory domains, including food safety, pharmaceuticals and professional licensing. Applied to wildlife trade, a positive list would require overwhelming, objective evidence before a species could be commercially exploited for fashion or other purposes.

The paper also argues for clear investigative criteria that can be applied consistently across species and jurisdictions. It proposes a ‘prove it or lose it’ approach: claims about conservation and welfare should be checked against independent datasets, with clear thresholds for maintaining—or withdrawing—trade permissions when evidence is absent or insufficient.

The study also questions reliance on data originating from commercial or trade-adjacent sources. It concludes that dependence on the commercial sector for policy-relevant information appears imprudent and calls for reform in how evidence is sourced, validated and shared. Independent scientific institutions, rather than vested interests, should occupy the primary advisory role in determining trade policy. Greater transparency in data acquisition and disclosure is positioned as essential to restoring confidence in regulatory decisions.

The paper also focuses on enforcement. The paper notes that bans combined with high-level monitoring can function as effective control mechanisms where manifest threats are identified. While blanket prohibitions are contested within parts of the conservation community, they remain embedded within global wildlife legislation as the ultimate safeguard against species decline. In this context, bans are framed not as ideological instruments but as regulatory tools deployed when evidentiary thresholds are breached.

Taken together, the proposed reforms seek to realign governance with empirical accountability. The study does not claim to settle the sustainability question for the four target species. Rather, it argues that until independent, transparent data clearly demonstrate conservation benefit, regulatory systems should err on the side of precaution rather than presumption.