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Marking and Labelling

1. MARKING
   1.1 Why do certain specimens need to be marked?
   1.2 Marking of live vertebrates listed in Annex A
   1.3 Specific marking methods approved for live captive-bred Annex A animals
   1.4 Exemptions from the marking provisions and the use of alternative marking methods
   1.5 Some examples of alternative marking methods used in EU Member States
   1.6 Marking requirements for other specimens listed in Annex A and B
   1.7 Marking of crocodilian skins
2. LABELLING
   2.1 Caviar labelling


1. Marking

1.1 Why do certain specimens need to be marked?

There are certain specimens of species listed in Council Regulation (EC) No 338/97 that have to be uniquely marked or labelled, for example, for internal EU trade control purposes (e.g. in live Annex A animals) or for the purposes of controlling trade to and from the EU (e.g. crocodilian skins and caviar). These marking requirements have been developed to prevent fraud and to curtail illegal trade in specimens and products that are controlled by the EU Wildlife Trade Regulations. For example, the details of the mark, such as the unique number code, have to be provided on the permit or certificate and this helps to ensure that the specimens being traded are in fact the ones referred to in the accompanying documents.


1.2 Marking of live vertebrates listed in Annex A

All live vertebrates (mammals, birds, reptiles, amphibians and fish) listed in Annex A that are exempt from the prohibition on commercial use (Art. 8.3 of Council Regulation (EC) No 338/97), for example captive-bred specimens, must be uniquely marked in accordance with Art. 66 of Commission Regulation (EC) No 865/2006 before an internal trade certificate can be granted for their commercial use. The full details of the mark have to be provided on the permit or certificate of the specimen (Art. 68.2 of Commission Regulation (EC) No 865/2006).


1.3 Specific marking methods approved for live captive-bred Annex A animals

There are specific marking provisions for live specimens of Annex A-listed species of birds and for all other live Annex A-listed vertebrates (Art. 66 of Commission Regulation (EC) No 865/2006):

  • Captive born or bred Annex A-listed birds must be marked with a uniquely marked closed ring. In cases where this is not possible due to the physical or behavioural characteristics of the bird, an unalterable microchip transponder conforming to ISO Standards 11784:1996 and 11785:1996 (E) should be used.
  • All other live Annex A-listed vertebrates should be marked with an unalterable microchip transponder conforming to ISO Standards 11784:1996 and 11785:1996 (E). In cases where this is not possible due to physical or behavioural characteristics of the animal, a ring, band, tag, tattoo or another appropriate method should be used.

Note: Council Regulation (EC) No 338/97 stresses that marking must be undertaken with due regard to the humane care, well-being and natural behaviour of the specimens concerned (Art. 67 of Commission Regulation (EC) No 865/2006), and in cases were this can not be guaranteed (e.g. for juveniles) the Management Authorities can recognize alternative methods or procedures.


1.4 Exemptions from the marking provisions and the use of alternative marking methods

In some cases certain live animals are exempt from the marking requirement of Art. 66 of Commission Regulation (EC) No 865/2006. These are:

  • Certain commonly bred bird species: Captive-born and bred bird species that are listed in Annex X of Commission Regulation (EC) No 865/2006, and hybrids thereof. These species are bred in such numbers that it is felt unnecessary for them to be uniquely marked. The bird species listed in Annex X are also covered by a general exemption, and no sale specific certificate is needed for the commercial use of these specimens.
  • For animal welfare reasons: An exception may also be made in cases where the physical properties of the animal do not allow the safe application of any marking method. This may for example be the case for juvenile specimens. In such cases, the Management Authority may recognise an alternative marking technique as the appropriate method. In some cases the Management Authority will exempt the animal from the marking requirement and will record this on the sale exemption certificate or, where marking can be carried out at a later date, a special condition may be included, for example, specifying when the animal has to be marked.



1.5 Some examples of alternative marking methods used in EU Member States

In cases where the marking method recommended by the EU Regulations (closed ring for birds and microchip for all other live vertebrates) cannot be safely applied, EU Member States can recognise alternative marking methods for live Annex A-listed vertebrates. Some Member States have developed guidelines (e.g. Italy) that specify which marking method can be used for which species and specimens, and some Member States have developed specific national legislation (e.g. Austria, Germany) with regard to the marking of live animals and the approved method to be used. In some instances, these guidelines and legislation go beyond the requirements of the EU Regulations. Any alternative marking method approved in one EU Member State should be recognised by the Management Authority of another EU Member State (Art. 68.1 of Commission Regulation (EC) No 865/2006).

Photo identification and other alternative marking method in Germany
Germany’s national species conservation legislation, the Federal Ordinance on Species Conservation (Bundesartenschutzverordnung (pdf 198KB)), which entered into force in January 2001 and was updated in 2005 and 2007, specifies marking requirements for live vertebrates ("Kennzeichnungspflicht") listed in Annex 6 of the legislation. This Annex includes all mammals, reptiles and bird species listed in Annex A of Council Regulation (EC) No 338/97, as well as some bird species listed in Annex B (e.g. parrots). Any person owning (even if not trading) a species listed in Annex 6 must have it marked. In cases where the safe application of a recommended marking method is not possible due to animal welfare reasons, the authorities may temporarily exempt the specimen from the marking provisions. For example, there is a ban on marking falconry birds with a transponder; this ban also applies to animals that have not yet attained a certain weight (500g for tortoises or 200g for other reptiles). Photo documentation for individual specimens and other non-invasive marking methods have been developed for several reptile species, including Geochelone radiata, Testudo hermanni, Testudo marginata, (for more information visit www.dght.de).

Germany's Federal Ordinance on Species Conservation of 25 February 2005, includes a revision of the provisions on marking of wild animals e.g. by extending the marking regulations to additional bird species and by explicitly naming organisations that are authorized by the federal government to provide the respective marks, labels or transponders. In addition, keepers of animals, especially reptiles, have the right to choose between marking by transponder or identification by photo documentation. Mammals should be marked with a transponder. Birds taken from the wild should be marked either with leg rings or a transponder.



1.6 Marking requirements for other specimens listed in Annexes A and B

In addition to the requirements outlined above, certain other specimens of species listed in Annexes A and B of Council Regulation (EC) No 338/97 have to be uniquely marked before they can be imported into the EU, i.e. before the Management Authority can issue an import permit. This applies to certain live animals as well as to dead specimens and parts of these species such as skins, trophies or caviar (Art. 64 of Commission Regulation (EC) No 865/2006). For these specimens, the Conference of the Parties to CITES determined the approved or recommended marking method, and information on these methods can be obtained through the relevant CITES Resolutions. This concerns the following specimens:

  • Raw tanned and/or finished crocodilian skins, flanks, tails, throats, feet, backstrips and other parts thereof that are exported to the EU and entire raw, tanned, or finished crocodilian skins and flanks that are re-exported to the EU (see CITES Res. Conf. 11.12 (Rev. CoP15));
  • Live vertebrates of Annex A-listed species that belong to a travelling live animal exhibition, e.g. a circus (see Permits);
  • All containers and packages containing Sturgeon Acipenseriformes spp. caviar (see caviar labelling and CITES Res. Conf. 12.7 (Rev. CoP16));
  • Specimens that derive from a captive breeding or ranching operation that was approved by the Parties to CITES at CoP12 and revised at CoP13, 14 and 15 (CITES Res. Conf. 12.10 (Rev. CoP15));
  • Specimens of a population of a CITES Appendix I-listed species for which an export quota has been approved by the Conference of the Parties to CITES, for example hunting trophies and skins of Leopard Panthera pardus  from certain African countries (see CITES Res. Conf. 10.14 (Rev. CoP16)) or for hunting trophies of Markhor Capra falconeri from Pakistan (see CITES Res. Conf. 10.15 (Rev. CoP14)); 
  • Raw tusks of African Elephant Loxodonta africana and cut pieces thereof that are both over 20 cm in length and 1 kg in weight (see CITES Res. Conf. 10.10 (Rev. CoP16)).


1.7 Marking of crocodilian skins

As mentioned before, all parts of crocodilian skins whether raw, tanned and/or finished crocodilian skins (including flanks, tails, throats, feet, backstrips and other parts) that are to be exported to the EU, as well as entire raw, tanned or finished crocodilian skins that are to be re-exported to the EU, have to be marked with a universal tag as agreed by CITES Parties in CITES Res. Conf. 11.12 (Rev. CoP15). This Resolution describes the requirements for the tag to be used by CITES Parties, for example the tag must be non-reusable and should include the ISO code for the country of origin and a unique serial identification number. The CITES Secretariat regularly publishes the latest and most up-to-date list of approved manufacturers for tags (CITES Notification 2013/029 (pdf 55KB)) that meet the criteria described in CITES Res. Conf. 11.12 (Rev. CoP15) and Management Authorities should ensure that only tags obtained from these sources are used. 

Note: Finished products made of crocodile skin such as handbags, purses, shoes and watchstraps do not need to be tagged and the CITES tag is only relevant for trade to and from the EU in raw, tanned and finished crocodilian skins. 
Export and re-export of crocodilian skins from the EU

When countries issue export permits or re-export certificates for crocodilian skins, the Management Authority should record the numbers of the tags on each document. CITES Res. Conf. 11.12 (Rev. CoP15) also recommends that countries re-exporting raw, tanned and/or finished crocodilian skins develop a system that allows them to match import and re-exports effectively, and ensure that skins and flanks are re-exported with the original tag intact unless the pieces originally imported have been further processed and/or cut into smaller pieces.

Certification systems for reptile leather products

In Germany and other countries, the reptile leather industry has developed their own tagging systems for finished CITES-listed reptile products. These voluntary certification schemes are primarily used for the domestic market and to assist consumers in their decision making. One example is the “Artenschutzfahne” or “Conservation tag” of the German-based International Reptile Association (IRV). The IRV Conservation tag is a certification system for finished reptile leather products. The tag is a voluntary scheme but it is recognised by the German CITES Authorities as proof of legal origin. The tag is used only for those products that originate from raw materials that were obtained and traded in accordance with the provisions of CITES and the EU Wildlife Trade Regulations, and only products for which the original CITES documents are available can be tagged. The tag uses a combination of letters and numbers that provide information about the country of origin, the species, the CITES permit number and year of issuance. The information is managed through a computerised database that ensures an easy and secure way to track the individual product to the origin of the raw material and to assist the authorities in controlling the trade in these products.


2. Labelling

2.1 Caviar labelling

In April 1998, the decisions to list all species of sturgeon and paddlefish (Acipenseriformes spp.) in the CITES Appendices entered into effect, covering all live specimens, as well as any parts and products derived from these species (such as caviar, meat, leather, fertilised eggs, cartilage, etc.). These specimens may only be traded in accordance with the provisions of CITES and the EU Wildlife Trade Regulations.

Labelling of caviar containers

In April 2000, CITES Parties agreed on a universal labelling system for the identification of caviar that came into effect in the EU on 1 January 2002. The labelling system was revised in November 2002 (CITES CoP 12), October 2004 (CoP 13), June 2007 (CoP 14) and March 2013 (CoP 16) (see CITES Res. Conf. 12.7 (Rev. CoP16) Conservation of and trade in sturgeons and paddlefish). This system includes a unique code that must be used on the non-reusable label (see Figure 1), which must be affixed to all primary caviar containers (tin, box, jar, or other container into which caviar is directly packed)  regardless of size. The uniform labelling system applies to all caviar produced for commercial and non-commercial purposes and includes re-packaged caviar and all caviar sold on domestic markets.

Since 9 July 2006, when Commission Regulation (EC) No 865/2006 came into effect, traders in the EU are legally required to comply with these labelling provisions. In February 2008, this Regulation was amended by Commission Regulation (EC) No 100/2008, which includes stricter measures on labelling of caviar containers, such as requiring that the label affixed to each primary container either seal the primary container or that the caviar be packaged in such a manner as to permit visual evidence of any opening of the container. In January 2015, the Regulation was amended by Commission Regulation (EC) No 2015/56 to prohibit the mixing of caviar from different Acipenseriformes species into a primary container, except in the case of pressed caviar (i.e. caviar composed of unfertilised eggs (roe) of one or more sturgeon or paddlefish species, remaining after the processing and preparation of higher quality caviar)

For the purposes of facilitating the marking requirements for caviar, the Management Authority must license facilities (or plants) that process, package or repackage caviar and must attribute a unique registration number to these facilities. The facilities must also maintain adequate records of the quantities of caviar imported, exported, re-exported, produced in-situ or stored that must be available for inspection by the Management Authority in the relevant Member State.

caviar labelling

Fig 1.
Description of labels to be affixed in the country of origin by the processing plant on all caviar containers

More detailed information about caviar labelling can be found in the Caviar labelling leaflet (pdf 238KB).