February 5, 2019 Dear Members of the IUCN Giraffe and Okapi Specialist Group, The undersigned organizations thank you for your work on behalf of giraffes and for sounding the alarm about the on-going silent extinction of this species. We write to urge you to support the proposal submitted by Central African Republic, Chad, Kenya, Mali, Niger and Senegal to list the giraffe (Giraffa camelopardalis) on Appendix II under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). 1 This proposal will be considered at the 18th meeting of the Conference of the Parties (CoP18) to CITES, which will be held in Sri Lanka from 23 May – 3 June 2019. Beyond our shared concern over declining giraffe populations, our organizations have worked on CITES matters for decades and seek to provide you with our views on why a CITES Appendix II listing is an essential component to preventing the extinction of giraffes. Indeed, we are aware that members of the IUCN Giraffe and Okapi Specialist Group (GOSG) may be involved in reviewing this proposal as part of the IUCN/TRAFFIC analysis of species proposals to be considered at CITES CoP18. We would like to ensure that you have all the information you may find useful in conducting an informed review including, but not limited to, international trade data for giraffe. We understand that the GOSG has not identified international trade as one of the primary threats to giraffes. However, as explained below, international trade does not have to be a primary threat to a species for it to qualify for listing on CITES Appendix II. Often, international trade may act synergistically with primary threats to negatively impact wildlife populations. Moreover, a listing on Appendix II does not result in a trade ban. Rather, Appendix II listing would result in regulation of international trade. Currently, most international giraffe trade is occurring without regulation for conservation purposes. This letter explains why the giraffe meets the CITES criteria for listing on Appendix II, and what it would mean in terms of regulation of international giraffe trade if the proposal is adopted. We stand ready to answer any questions you may have. I. About CITES CITES is a United Nations treaty signed and ratified by 183 countries (or “Parties”). 2 It aims to ensure that international trade in specimens of wild animals and plants does not threaten their survival. The treaty has three Appendices: 1 2 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf https://cites.org/ 1 • • • Appendix I includes species threatened with extinction which are or may be affected by trade. Trade in specimens of these species is subject to particularly strict regulation in order not to further endanger their survival and must only be authorized in exceptional circumstances. With a few exceptions, international trade for primarily commercial purposes (such as for sale in the importing country) is not permitted for species listed on Appendix I. Species listed on Appendix I include the tiger, Asian elephant, and chimpanzee. 3 Appendix II includes: o species that are not necessarily currently threatened with extinction, but may become so unless trade in such species is strictly regulated; and o other species which must be subject to regulation in order that trade in specimens of certain species referred to in sub-paragraph (a) of this paragraph may be brought under effective control. This clause refers to species that, in their traded form, look like species included in Appendix II. International trade for commercial purposes in Appendix II species is allowed but regulated to ensure that traded specimens are legally acquired, that trade is not detrimental to the survival of the species, and that live specimens are prepared and shipped as to minimize risk of injury, damage to health, or cruel treatment. Examples of species on Appendix II are the hippopotamus, Hamadryas baboon, and Sakar falcon. Appendix III includes species that any Party identifies as being subject to regulation within its jurisdiction for the purpose of preventing or restricting exploitation, and as needing the co-operation of other Parties in the control of trade. Examples of species on Appendix III are Dorcas gazelle (Algeria, Tunisia), aardwolf (Botswana), and alligator snapping turtle (US). There are specific criteria that must be met for a species to be listed on CITES Appendix II. Firstly, Article II, paragraph 2(a) of the CITES treaty states: “Appendix II shall include: (a) all species which although not necessarily now threatened with extinction may become so unless trade in specimens of such species is subject to strict regulation in order to avoid utilization incompatible with their survival.” 4 Secondly, the Parties have adopted Resolution Conf. 9.24 (Rev. CoP17), on Criteria for amendment of Appendices I and II, 5 that states: • • II. “A species should be included in Appendix II when, on the basis of available trade data and information on the status and trends of the wild population(s), at least one of the following criteria is met: … B. It is known, or can be inferred or projected, that regulation of trade in the species is required to ensure that the harvest of specimens from the wild is not reducing the wild population to a level at which its survival might be threatened by continued harvesting or other influences.” (Annex 2a, Criterion B). “When considering proposals to amend Appendix I or II, the Parties shall, by virtue of the precautionary approach and in case of uncertainty either as regards the status of a species or the impact of trade on the conservation of a species, act in the best interest of the conservation of the species concerned and adopt measures that are proportionate to the anticipated risks to the species.” (Annex 4). Status of the Species As you are aware, both the 2018 and 2016 assessments of the giraffe for the IUCN Red list resulted in a Vulnerable classification due to an observed population decline of 36-40 percent over three generations (30 years, 1985-2015). 6 Your previous assessment of the giraffe was of Least Concern (2010). However, the 2018 and 2016 assessments recognized that the population is decreasing: in 1985 it was estimated at https://cites.org/eng/app/appendices.php https://cites.org/eng/disc/text.php#II https://cites.org/sites/default/files/document/E-Res-09-24-R17.pdf 6 https://www.iucnredlist.org/species/9194/136266699#assessment-information and Muller, Z. et al. 2018. Giraffa camelopardalis (amended version of 2016 assessment). The IUCN Red List of Threatened Species 2018: e.T9194A136266699. http://dx.doi.org/10.2305/IUCN.UK.2016-3.RLTS.T9194A136266699.en 3 4 5 2 151,702-163,452 (106,191-114,416 mature individuals) declining to only 97,562(68,293 mature individuals) in 2015. The 2018 assessment identifies four primary threats – habitat loss; civil unrest; illegal hunting; and ecological changes – but also recognizes “the species has been overlooked in terms of research and conservation” and recent efforts have focused upon assessing “population size and distribution.” 7 The giraffe is currently not listed under CITES. The proposal’s proponents are concerned that the substantial international trade in giraffe parts documented in their proposal may be, or may become, harmful to giraffe populations – especially in light of the other ongoing threats to giraffes. Accordingly, their proposal to list giraffes in Appendix II seeks to regulate trade to ensure that it is not detrimental to the survival of the giraffe, and that specimens in trade are legally acquired. Requiring CITES export permits will provide essential missing data on the levels and sources of giraffe parts and derivatives in trade and help ensure that demand for bones, skins, and other parts are not further contributing to the species’ decline due to habitat loss, civil unrest, illegal hunting, and ecological change. It should be noted that the taxonomy used in the proposal, which recognizes one species of giraffe (Giraffa camelopardalis), is based upon the CITES-accepted nomenclatural reference for mammals: 8 Wilson & Reeder’s Mammal Species of the World, third edition (2005). 9 It is also consistent with the taxonomy used in the 2018 IUCN Red List assessment. 10 As noted in the proposal, the proponents are aware of the ongoing scientific discussion surrounding giraffe taxonomy; however, this debate is not a reason to withhold support for the proposal. Even if the giraffe is split into four or more species, this does not change the fact that it is difficult, if not impossible, to distinguish giraffe parts in trade to the species or subspecies level, particularly since specimens in trade include bone carvings. Consequently, the option of listing some but not all giraffe populations or subspecies (a so-called “split listing”) would undoubtedly create enforcement problems. It is for this reason that species can be listed on Appendix II if they look like other species listed on that Appendix. 11 Thus, whether there are one, four, or more species of giraffes, given they all look alike, especially in trade, all giraffes meet the Appendix II criteria. As you know, the 2018 giraffe assessment recognizes nine giraffe subspecies, of which four are increasing (G. c. angolensis, G. c. giraffa, G. c. peralta, G. c. rothschildi), four are decreasing (G. c. antiquorum, G. c. camelopardalis, G. c. reticulata, G. c. tippelskirchi), and one is stable (G. c. thornicrofti) (see Table below). Two are classified as Critically Endangered (G. c. antiquorum, G. c. camelopardalis), one as Endangered (G. c. reticulata), two as Vulnerable (G. c. thornicrofti, G. c. peralta), one as Near Threatened (G. c. rothschildi), and one as Least Concern (G. c. angolensis). The remaining two subspecies were not assessed. Five of the nine subspecies have small population sizes (defined as <5000 in Resolution Conf. 9.24 (Rev. CoP17)): G. c. antiquorum, G. c. camelopardalis, G. c. thornicrofti, G. c. peralta, G. c. rothschildi). Three of the nine subspecies have very small population sizes (defined as <500 in Resolution Conf. 9.24 (Rev. CoP17)): G. c. camelopardalis, G. c. thornicrofti, G. c. peralta). III. International Trade in Giraffe Specimens As noted previously, international trade in giraffe parts was not recognized by the GOSG as a threat to the species, except in the case of G. c. antiquorum where the threat posed by transboundary giraffe Muller, Z. et al. 2018. Giraffa camelopardalis (amended version of 2016 assessment). The IUCN Red List of Threatened Species 2018: e.T9194A136266699. http://dx.doi.org/10.2305/IUCN.UK.2016-3.RLTS.T9194A136266699.en 8 CITES Resolution Conf. 12.11 (Rev. CoP17), https://cites.org/sites/default/files/document/E-Res-12-11-R17.pdf 9 https://www.departments.bucknell.edu/biology/resources/msw3/browse.asp?s=y&id=14200476 10 Muller, Z., Bercovitch, F., Brand, R., Brown, D., Brown, M., Bolger, D., Carter, K., Deacon, F., Doherty, J.B., Fennessy, J., Fennessy, S., Hussein, A.A., Lee, D., Marais, A., Strauss, M., Tutchings, A. & Wube, T. 2018. Giraffa camelopardalis (amended version of 2016 assessment). The IUCN Red List of Threatened Species 2018: e.T9194A136266699. http://dx.doi.org/10.2305/IUCN.UK.2016-3.RLTS.T9194A136266699.en. Downloaded on 23 January 2019. https://www.iucnredlist.org/species/9194/136266699#population 11 CITES, art. II paragraph 2(b) (Appendix II shall include “other species which must be subject to regulation in order that trade in specimens of certain species referred to in sub-paragraph (a) of this paragraph may be brought under effective control”). 7 3 bushmeat trade within Central Africa was acknowledged. 12 Yet, in fact, there is significant international trade in giraffe body parts (see below). From 2006-2015, the U.S. alone imported a total of 39,516 giraffe specimens (99.7 percent of which were wild-sourced). 13 The most commonly-traded items were bone carvings (21,402), bones (4,789), trophies (3,744), skin pieces (3,008), bone pieces (1,903), skins (855), and jewelry (825) 14 (See Annex, Table 1). Other giraffe specimens in trade included shoes (528), hair (501), small leather products (366), feet (339), large leather products (325), horn (ossicone) carvings (201), and smaller numbers of skulls, hair products, specimens, tails, skeletons, rugs, shell products, carapaces, trim, wood products (e.g. furniture), plates, genitalia, horns (ossicones), live animals, bodies, teeth, eggshells (e.g. ostrich egg products with giraffe hair affixed), ears, legs, and unspecified products. As noted in the proposal, recent online trade studies found 321 giraffe products offered for sale in seven countries within the European Union. 15 Furthermore, a recent investigation of giraffe trade in the U.S. found giraffe parts for sale country at more than 52 U.S. locations throughout the country. 16 Western boots made from giraffe leather and specialty knives/knife products made from giraffe bone were the most commonly found giraffe products in the U.S. Other giraffe products found in the U.S. included giraffe taxidermy “trophies;” giraffe hide pillows and rugs; giraffe skin bible covers and furniture; and giraffe bones and bone carvings. There is direct evidence of international trade in all giraffe subspecies (see Annex, Table 2). As noted above, the Critically Endangered giraffe subspecies, G. c. antiquorum, is affected by international trade in giraffe bushmeat within Central Africa. 17 All of the other subspecies have been documented in international trade by U.S. import data from 2006-2015. While most specimens documented originated in South Africa (31,245 specimens) or Zimbabwe (5,249 specimens), where the populations of the relevant subspecies are increasing, the data include giraffe specimens that originated in countries with Critically Endangered, Endangered, and Vulnerable subspecies, or those with declining or small populations. The number of giraffes involved in this trade is small in comparison to exports from South Africa and Zimbabwe, but for threatened species, or those with small or declining populations, the impact of even limited trade could be highly detrimental. Examples of concern include: the 692 specimens imported to the U.S. between 2006 and 2015 from Tanzania, where according to 2018 assessment, the giraffe population decreased by 52 percent since 1977-1980; and the four trophies and one skin imported to the U.S. between 2006 and 2015 from Zambia, where the giraffe population includes only 420 mature individuals. The top exporting country, South Africa, has exported to the U.S. giraffe specimens that originated in other countries. These exports include 50 wild sourced bones of Somalia origin that were exported for commercial purposes in 2012. As you know, the giraffe subspecies that exists in Somalia, G. c. reticulata, is Endangered and the population has declined by 77.8 percent since the 1990s. Furthermore, 449 giraffe specimens, most exported from South Africa, had an “unknown” country of origin (see Annex, Table 3) and could have originated from threatened, declining or small populations. Your 2018 assessment of giraffes further recognizes that illegal hunting is a concern in southern Africa. 18 Thus, even if giraffe populations there are stable, ensuring exported giraffe parts were legally acquired is important to curtailing the threat of illegal hunting. The trade data in the proposal and collected herein represents only a portion of all international trade in giraffe specimens, as it represents U.S. import data and some information on the EU market. Based on our experience at CITES, it is highly likely that the U.S. comprises no more than half of the global market, https://www.iucnredlist.org/species/88420742/88420817#threats https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 14 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 15 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 16 http://www.hsi.org/assets/pdfs/giraffe-report-HSI-HSUS-082318.pdf 17 https://www.iucnredlist.org/species/88420742/88420817 18 https://www.iucnredlist.org/species/9194/136266699 12 13 4 and possibly significantly less. A CITES Appendix II listing, in addition to other benefits noted above, would provide data for all giraffe trade globally, for all purposes, and from all sources. This data, submitted by CITES Parties, would be disclosed in the searchable CITES Trade Database. 19 Such a database would reveal, for the first time, the true extent of the trade and possibly shed light on its impact on giraffe conservation. We would be pleased to provide you with the raw data, in excel format, on giraffe imports that we received under a Freedom of Information Act request to the U.S. Fish and Wildlife Service. IV. The Benefit of Listing Giraffes on Appendix II Given the vulnerable and declining status of the giraffe species as a whole, and the demonstrably large volumes of trade (including some trade from countries with threatened, declining and small populations), an Appendix II listing is necessary to ensure that the giraffe parts traded internationally are legally acquired and not detrimental to the survival of the species in the wild. Based on the information presented above, Giraffa camelopardalis meets the criteria for listing on CITES Appendix II and the giraffe would benefit from such a listing. Such a listing would also help draw much needed attention to giraffes and create the possibility for synergy between CITES and CMS to benefit this species and your on-going conservation efforts. We trust that you will find the information presented in this letter useful as you develop your recommendations on the giraffe proposal. Please do not hesitate to contact us if we can provide further information or assistance. Finally, we thank you for your strong and unwavering commitment to giraffe conservation. Sincerely, Teresa M. Telecky, Ph.D. Vice President, Wildlife Humane Society International Tanya Sanerib International Legal Director Center for Biological Diversity DJ Schubert Elly Pepper Deputy Director, Wildlife Trade Initiative Natural Resources Defense Council DJ Schubert Wildlife Biologist Animal Welfare Institute Jan Creamer Mark Jones, veterinarian Head of Policy Born Free Foundation Jan Creamer President, Co-Founder Animal Defenders International Co-Founder Pro Wildlife 19 https://trade.cites.org/ 5 Annex Table 1. Total U.S. Giraffe Imports, 2006-2015, all sources and all purposes. 20 Wildlife Description 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Bone Carvings 2,933 4,194 1,641 2,735 1,736 233 790 1,418 1,495 4,227 Bodies 0 0 1 1 0 0 0 1 0 0 3 Bones 167 65 487 345 77 1403 350 434 775 686 4,789 1,691 2 15 9 10 2 37 7 76 54 1,903 38 0 0 0 0 0 0 1 0 0 39 Ears 0 0 0 0 0 0 0 0 1 0 1 Eggshells 0 2 0 0 0 0 0 0 0 0 2 18 9 22 37 45 29 69 58 23 29 339 Bone Pieces Carapaces Feet Genitalia 21,402 0 0 2 1 0 0 0 0 2 1 6 400 2 5 1 0 1 0 81 0 11 501 Hair Products 10 0 0 2 2 0 1 0 3 100 118 Horn Carvings 0 0 0 0 0 3 0 63 48 87 201 Horns 0 0 0 0 0 2 3 0 0 0 5 Hair Jewelry 53 66 670 0 10 0 5 9 5 7 Leather Products Large 825 2 3 6 18 32 11 11 58 76 108 325 Leather Products Small 5 4 3 1 1 3 42 147 58 102 366 Legs 0 0 0 0 0 0 0 1 0 0 1 Live 0 0 0 0 3 0 0 1 0 0 4 Plates 0 0 0 0 0 0 0 3 2 3 8 15 6 15 5 6 0 2 8 1 5 63 Shell Product 0 0 0 0 0 0 0 0 50 0 50 Shoes 0 0 0 0 0 0 0 2 8 518 528 Skeletons 0 0 0 0 0 0 0 0 0 64 64 Rug Skins 16 22 115 18 307 9 18 22 163 165 855 Skin Pieces 50 310 85 133 34 245 62 704 465 920 3,008 Skulls 18 2 14 12 32 29 6 6 4 27 150 Specimens 1 0 0 19 0 0 50 6 0 25 101 Tails 1 0 1 15 7 6 18 7 5 5 65 Teeth 0 0 0 0 1 0 0 0 0 2 3 Trim 0 2 3 4 0 9 0 1 0 2 21 425 372 339 405 280 328 342 408 386 459 3,744 Trophies Unspecified Wood Products TOTAL 20 TOTALS 10 0 0 2 1 0 0 1 2 0 16 0 0 0 6 0 1 0 3 0 0 10 5,853 5,061 3,424 3,769 2,584 2,314 1,806 3,450 3,648 7,607 39,516 Proposal, https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf, p. 22. 6 Table 2. Giraffe subspecies, conservation status and evidence of international trade. Subspecies Range States G. c. antiquorum Cameroon, Central African Republic, Chad, Democratic Republic of Congo, South Sudan Ethiopia, South Sudan G. c. camelopardalis G. c. reticulata Kenya, Somalia, Ethiopia Number of mature individuals 1,400 IUCN Status Population Trend Evidence of International Trade CR 21 Decreasing Giraffe bushmeat traded transboundary within Central Africa. 22 455 CR 23 Decreasing 11,048 EN 25 Decreasing U.S. imported one wild source trophy from Ethiopia in 2008; unknown if G. c. camelopardalis or G. c. reticulata. 24 U.S. imported from Kenya three pieces of jewelry for personal purposes in 2006 and 125 bone carvings for commercial purposes in 2007, all wild source; unknown subspecies. 26 U.S. imported one wild source trophy from Ethiopia in 2008; unknown if G. c. camelopardalis or G. c. reticulata. 27 U.S. imported 50 wild source bones that originated in Somalia but were exported from South Africa in 2012 for commercial purposes. 28 G. c. tippelskirchi Kenya, Tanzania 31,611 Not assessed Decreasing U.S. imported one tail and one hair item in 2009 that originated in Somalia but were exported from Italy for personal purposes. 29 U.S. imported 692 specimens from Tanzania, 2006-2015. 30 This included 670 wild source jewelry items for commercial purposes (2008) exported from Tanzania and wild source for personal purposes: 1 hair item (2006) and 20 jewelry pieces (2007) both exported from Tanzania, and 1 bone piece (2006) exported from Zimbabwe. 31 U.S. imported from Kenya three pieces of jewelry for personal purposes in 2006 and 125 bone carvings for commercial purposes in 2007, all wild source; unknown subspecies. 32 https://www.iucnredlist.org/species/88420742/88420817 https://www.iucnredlist.org/species/88420742/88420817#threats 23 https://www.iucnredlist.org/species/88420707/88420710 24 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 25 https://www.iucnredlist.org/species/88420717/88420720 26 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 27 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 28 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 29 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 30 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 31 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 32 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 21 22 7 Subspecies Range States Number of mature individuals 420 IUCN Status Population Trend Evidence of International Trade G. c. thornicrofti Zambia VU 33 Stable 10,173 LC 34 Increasing 21,387 Not assessed Increasing G. c. peralta Namibia, Botswana Zimbabwe, Mozambique, South Africa, Botswana Niger 425 VU 37 Increasing G. c. rothschildi Uganda, Kenya 1,399 NT 38 Increasing U.S. imported from Zambia four wild source trophies (in 2006, 2008, and 2011) for hunting purposes, and one wild source skin in 2008 for hunting purposes. U.S. imported 685 specimens from Namibia, 2006-2015. 35 U.S. imported 31,245 specimens from South Africa and 5,249 specimens from Zimbabwe, 20062015. 36 U.S. imported one wild-sourced skin for personal purposes in 2009 from Nigeria; the giraffe is extinct in Nigeria but this could have been G. c. peralta. U.S. imported from Kenya three pieces of jewelry for personal purposes in 2006 and 125 bone carvings for commercial purposes in 2007, all wild source; unknown subspecies. 39 G. c. angolensis G. c. giraffa https://www.iucnredlist.org/species/88421020/88421024 https://www.iucnredlist.org/species/88420726/88420729 35 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 36 https://cites.org/sites/default/files/eng/cop/18/prop/020119_d/E-CoP18-Prop_draft-Giraffa-camelopardalis.pdf 37 https://www.iucnredlist.org/species/136913/51140803 38 https://www.iucnredlist.org/species/174469/51140829 39 U.S. Fish and Wildlife Service import data. See Annex, Table 3. 33 34 8 Table 3. Raw data on U.S. imports (2006-2015) of giraffe specimens from select countries of origin. 40 Genus Species GIRAFFA CAMELOPARDALIS Wildlife Descr. 41 TRO Qty Unit Ctry Exp ET Purpose Source Ship Date NO Ctry 43 Org ZW US Importer Foreign Exporter TAXIDERMY COOPERATIVE SOCIETY MOUNT KENYA ART GALLERIES 1 H W 8/24/08 GIRAFFA CAMELOPARDALIS JWL 3 NO KE KE P W 9/27/06 GIRAFFA CAMELOPARDALIS BOC 125 NO KE KE T W 11/27/07 GIRAFFA CAMELOPARDALIS SKI 1 NO NG NG P W 12/22/2009 GIRAFFA CAMELOPARDALIS TAI 1 NO SO IT P 1/20/2009 VITTORIO TEDESCO ZAMMARANO VITTORIO TEDESCO ZAMMARANO GIRAFFA CAMELOPARDALIS HAI 1 NO SO IT P 1/20/2009 VITTORIO TEDESCO ZAMMARANO VITTORIO TEDESCO ZAMMARANO GIRAFFA CAMELOPARDALIS BON 50 NO SO ZA T W 11/21/2012 TEXAS KNIFE SUPPLY(TKS) P W 8/21/06 AFRICAN KNIFE HANDLE SUPPLIES GIRAFFA CAMELOPARDALIS HAP 1 NO TZ TZ GIRAFFA CAMELOPARDALIS JWL 20 NO TZ GIRAFFA CAMELOPARDALIS JWL 670 NO TZ TZ P W 6/28/07 TZ T W 1/23/08 ART BY GOD TZ ZW P W 7/2/06 TERRY ADAMS NO ZM ZM H W 3/11/06 1 NO ZM ZM H W 1/4/08 TRO 1 NO ZM ZM H W 12/16/08 CAMELOPARDALIS TRO 1 NO ZM ZM H W 12/2/2011 MENDA TAXIDERMY LTD VICTORIA FALLS HOTEL TAXIDERMY ENTERPRISES MUCHINGA ADVENTURES LIMITED CHARLTON MCCALLUM SAFARIS BANGWEULU TAXIDERMY LIMITED GIRAFFA CAMELOPARDALIS BOP 1 NO GIRAFFA CAMELOPARDALIS TRO 1 GIRAFFA CAMELOPARDALIS TRO GIRAFFA CAMELOPARDALIS GIRAFFA GIRAFFA CAMELOPARDALIS TRO 1 NO ZM ZM H W 11/10/2014 GIRAFFA CAMELOPARDALIS SKI 1 NO ZM ZW H W 3/12/08 42 44 45 Exemptions 6 and 7(C) 46 TAXIDERMY ENTERPRISES PVT LTD Source of Data: U.S. Fish and Wildlife Service, obtained under a Freedom of Information Act request. Wildlife Descriptions: BOC (bone product or carving), BON (Bones (including jaws, but not skulls)), BOP (Bone pieces (not manufactured)), FOO (Foot), HAI (Hair), HAP (Hair product (including paint brushes, etc.)), JWL (jewelry (other than ivory jewelry)), LPS (Leather product (small manufactured including belt, wallet, watchband)), SKI (skin (substantially whole, including tinga frames)), SPE (Specimen (scientific or museum)), SPR (Shell product (mollusc or turtle)), TAI (Tails), TEE (Teeth (excluding tusk)), TRO (trophy (all the parts of one animal)). 42 Unit: NO = number of items. 43 Country codes: CA = Canada, ET= Ethiopia, IT = Italy, KE = Kenya, LS = Lesotho, NG = Nigeria, SO = Somalia, TZ = Tanzania, ZA = South Africa, ZM = Zambia, ZW = Zimbabwe, XX = unknown. 44 Purpose codes: H = hunting; P = personal; T = commercial; Q = travelling exhibit. 45 Source code W = wild. 46 USFWS redacted this information. 40 41 9 Genus Species GIRAFFA CAMELOPARDALIS Wildlife Descr. 41 BOC Qty Unit Ctry Exp CA Purpose Source Ship Date US Importer NO Ctry 43 Org XX 8 P W 9/10/2013 Exemptions 6 and 7(C) GIRAFFA CAMELOPARDALIS HAI 1 NO XX ZA P W 8/15/08 GIRAFFA CAMELOPARDALIS FOO 1 NO XX CA Q W 11/22/2011 GIRAFFA CAMELOPARDALIS HAI 20 NO XX LS T W 1/2/2013 GIRAFFA CAMELOPARDALIS BON 50 NO XX ZA T W 11/1/2011 GIRAFFA CAMELOPARDALIS BON 2 NO XX ZA T W 12/21/2011 GIRAFFA CAMELOPARDALIS BON 50 NO XX ZA T W 7/5/2012 GIRAFFA CAMELOPARDALIS BON 60 NO XX ZA T W 11/22/2012 GIRAFFA CAMELOPARDALIS BON 50 NO XX ZA T W 12/13/2012 MASECRAFT SUPPLY COMPANY GIRAFFA CAMELOPARDALIS BON 40 NO XX ZA T W 3/7/2013 GIRAFFA CAMELOPARDALIS BON 50 NO XX ZA T W 1/29/2014 GIRAFFA CAMELOPARDALIS HAI 4 NO XX ZA T W 1/27/2012 GIRAFFE BONE KNIFE SUPPLY TEXAS KNIFE SUPPLY(TKS) SAFARI GOLD GIRAFFA CAMELOPARDALIS LPS 62 NO XX ZA T W 5/24/2013 GIRAFFA CAMELOPARDALIS SPR 50 NO XX ZA T W 10/22/2014 GIRAFFA CAMELOPARDALIS TEE 1 NO XX ZA T W 3/19/2010 42 10 44 45 AMERICAN MUSEUM OF NATURAL HISTORY ATHOL M FODEN DBA SAFARI GOLD USA MASECRAFT SUPPLY COMPANY TUDOR FARMS MASECRAFT SUPPLY COMPANY GIRAFFE BONE KNIFE SUPPLY MASECRAFT SUPPLY COMPANY Exemptions 6 and 7(C) NATIONAL ORNAMENTAL MUSEUM Foreign Exporter CANADIAN MUSEUM OF NATURE ARNO BERNARD KNIFE HEART WOOD BOWS ARNO BERNARD KNIFE AFRICAN KNIFE HANDLE SUPPLIES AFRICAN KNIFE HANDLE SUPPLIES PURE AFRIQUE JEWELLERS CC STELLENBOSC H UNIVERSITY