• Since climate change issues are taking more and more significance and offering a good field for media and fundraising activities by many NGOs, the polar bear became a new flag species to be emotionally used to support such activities. We may say therefore that the US proposal appears to be based more on emotion than science, in speculating on a rather long term evolution of the species habitat, without taking into account the species adaptive capacity. Thus, the proposal appears as premature, to say the least.

  • The species is covered by the 1973 Agreement on the Conservation of Polar Bears between the five range States, the views of which are not provided in the supporting statement. If the polar bear is actually considered as a marine species, the Agreement should have been consulted by the proponent and shall be consulted by the CITES Secretariat. Concerning consultations, it appears that none of the other range States support the proposal and Canada, the main exporting country, expressed its opposition, stating that “an outright ban on trade will have no impact on quotas [i.e. national management quotas], but might have a negative impact on conservation”.

  • As indicated in the supporting statement, hunting of the species is prohibited in the Russian Federation but a recently adopted agreement between that country and the proponent country will allow local hunting. This seems to be in full contradiction with the spirit of the proposal.

  • A listing in Appendix II does not impose to Parties to trade in the species in question. It allows range States to adapt their species management to the circumstances, including climatic events, without imposing measures that would be difficult if not impossible to change, such as a transfer to Appendix I, while the species in question, such as the polar bear, is not endangered at all.

  • In conclusion, IWMC recommends to the Parties to reject the proposal as excessive and any future similar proposals for as long as they are not submitted at the request of the Agreement on the Conservation of Polar Bears.
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