CITES Re-export Certificate

What is a CITES Re-Export Certificate?

A CITES Re-Export Certificate is a document required when exporting wild fauna and flora regulated under the Washington Convention (CITES), including their parts, derivatives, and processed products, from a country where they were initially imported to a third country.

For example, if products such as crocodile leather goods, items containing ivory, musical instruments made from rare woods, specimens derived from animals or plants, decorative items, cosmetic ingredients, or research samples were imported into Japan from overseas and are then sold, returned, transferred, or resold to another country from Japan, a CITES Re-Export Certificate may be required in addition to regular export documentation.

The critical point regarding the CITES Re-Export Certificate is not simply whether the cargo is shipped out of Japan. It is essential to explain the cargo’s country of origin, the specific CITES documents under which it was imported into Japan, and the distribution route through which it has come into the exporter’s possession.

The Re-Export Certificate serves to verify the origin and import history of the cargo rather than its current location. Therefore, documents such as the CITES Export Permit at import, any prior CITES Re-Export Certificates, Certificates of Import Approval, Certificates of Prior Confirmation, Import Permit Notices issued by Customs, import invoices, sales certificates, and inventory management records should be checked for continuity in practical logistics operations.

Scope Covered in This Article

This article addresses practical issues related to the CITES Re-Export Certificate when shipping CITES-controlled cargo from Japan to a third country.

Purpose and Background of the System

The purpose of the CITES Re-Export Certificate is to ensure the proper management required under the convention when CITES-regulated goods, having been legally imported in the past, are subsequently transferred to a third country.

CITES-regulated items may move through multiple countries after initial export from the country of origin, due to sales, exhibitions, repairs, processing, inventory transfers, resale, research use, or other reasons. Checking only the original export is insufficient. When these goods are moved again to a third country, it is necessary to verify their origin, previous import history, current ownership, and the identity of the goods.

The Re-Export Certificate is not merely an export document; it serves as proof connecting the international movement history of CITES-regulated goods. If the documentation from the initial import is lost, or if there is a discrepancy between quantities at the time of import and re-export, obtaining the Re-Export Certificate or completing import procedures in the receiving country may become problematic.

Difference from CITES Export Permit

The CITES Re-Export Certificate is similar to the CITES Export Permit, but the practical implications differ.

The CITES Export Permit confirms whether it is permissible to export CITES-listed goods from that country. In contrast, the CITES Re-Export Certificate primarily serves to demonstrate that the goods were properly imported in the past and are now being exported again from that country.

The Term "Re-Export Permit"

In CITES practice, the term "re-export permit" is sometimes used. However, the official document names under CITES distinguish Export Permit for exports and Re-Export Certificate for re-exports as a basic rule.

Therefore, in this article, the formal term used is "CITES Re-Export Certificate" or simply "Re-Export Certificate." The term "re-export permit" should be understood as a colloquial or search-related expression in practice and should not be confused with the CITES Export Permit.

Import Approval and Import Permit Should Not Be Confused

In Japan-related CITES practice, the terms import approval and import permit refer to different layers of procedure.

Import approval refers to a trade-control procedure administered by the Ministry of Economy, Trade and Industry. A Certificate of Import Approval may be required for certain CITES-listed goods before or in connection with import into Japan. Prior confirmation is also a METI-related procedure and should be distinguished from Customs import permission.

By contrast, an import permit is issued through Customs import clearance after the import declaration, examination, and necessary duty and tax procedures. Therefore, a Certificate of Import Approval and an Import Permit Notice issued by Customs should be treated as separate documents in re-export practice.

Situations That May Require Re-Export

Decision Flow for Determining Whether It Constitutes Re-Export

When determining whether a CITES Re-Export Certificate is required, verify in the following order.

1. Check if the cargo contains any plant- or animal-derived materials, parts, derivatives, or processed products.
2. Confirm the scientific name, raw materials, components, product specifications, and manufacturer information as thoroughly as possible, rather than relying on general names.
3. Verify whether the species involved are listed in CITES Appendices I, II, or III.
4. Check the country of origin of the cargo. Note that the CITES-defined country of origin may differ from the manufacturing or shipping country.
5. Determine whether the cargo was previously imported into Japan or is originally from Japan.
6. Verify whether a CITES Export Permit, Re-Export Certificate, Certificate of Import Approval, Certificate of Prior Confirmation, or Import Permit Notice was used or issued at the time of import into Japan.
7. Confirm whether the importer, current owner, and exporter are the same entity; if different, review the sales or transfer chain.
8. Check if the quantity, number of items, lot, tags, photographs, etc., correspond between the imported cargo and the cargo currently being exported.
9. Confirm the purpose of export, such as sale, return, return after repair, transfer after exhibition, or transfer for research purposes.
10. Verify whether obtaining a Re-Export Certificate is required, its validity period, the need to present the original certificate at export customs clearance, and import-side procedures in the receiving country.

It is important to conduct this verification not immediately before export declaration, but at an earlier stage, such as before booking, before the export contract, before exhibition shipment, or before return after repair.

Precautions for Re-Export by CITES Appendix Category

In practical handling of re-export certificates, the level of scrutiny varies depending on whether the CITES Appendix is I, II, or III.

Particularly for Appendix I species, simply obtaining a Re-Export Certificate is insufficient. It is necessary to more carefully verify whether the initial export by the country of origin was legal, whether the required approvals or confirmations were obtained at import, and if the current cargo is the same as or a continuous shipment of the imported goods.

Practical Workflow for Re-Exporting from Japan

The practical procedure for re-exporting CITES-regulated cargo from Japan generally follows these steps:

1. Confirm the cargo’s product name, raw materials, scientific name, quantity, and form.
2. Verify whether the cargo corresponds to a CITES-regulated species.
3. Check the classification under Appendices I, II, or III.
4. Review the CITES documentation used when the cargo was imported into Japan.
5. Confirm the Certificate of Import Approval, Certificate of Prior Confirmation, Import Permit Notice, import invoice, and import B/L or AWB.
6. Verify the relationships between the importer, current owner, and exporter.
7. Prepare sales certificates, transfer certificates, inventory records, and lot management documentation.
8. If necessary, submit an application following the procedures of the Ministry of Economy, Trade and Industry.
9. Obtain issuance of the CITES Re-Export Certificate.
10. Confirm the validity period of the certificate and manage schedules to ensure shipment and export customs clearance occur within this period.
11. Match the invoice, B/L, AWB, and other shipping documents with the certificate details.
12. Present the original CITES Re-Export Certificate to Customs at export customs clearance.
13. Confirm any endorsements or notations required by the destination country in the Customs confirmation section.
14. Manage the original certificate to ensure it is properly connected with the cargo and the import procedures in the destination country.

If confirmation is rushed after the shipment date is decided, common issues may occur such as missing import documents, unknown scientific names, discrepancies in quantity, inability to prove sales channels, or failing to meet the certificate’s validity period.

Validity Period Confirmation

CITES Re-Export Certificates have a validity period. Generally, CITES Export Permits and Re-Export Certificates must be used within a specified period from the issuance date. After this period expires, they may not be accepted for import procedures in the destination country.

In practice, obtaining the Re-Export Certificate too early carries the risk of expiration due to shipment delays, booking changes, flight changes, customs clearance hold-ups, or delayed acceptance preparation on the destination side. Conversely, obtaining it too late risks missing the planned shipment date due to insufficient documentation or review periods.

Main Required Documents

The primary documents checked during the application for a CITES Re-Export Certificate and export customs clearance include the following. The actual required documents vary depending on the species involved, Appendix classification, cargo condition, import history, and export purpose.

Why Document Retention at Import is Crucial

In practice, retaining documents at import is critical when dealing with CITES Re-Export Certificates.

The Re-Export Certificate is issued on the premise that the cargo currently being shipped from Japan was originally imported into Japan through proper CITES procedures. Without retaining original import CITES Export Permits, Re-Export Certificates, Certificates of Import Approval, Certificates of Prior Confirmation, Import Permit Notices issued by Customs, import invoices, sales certificates, and other related papers, it will be difficult to verify the cargo’s origin and supply chain.

This issue is especially important for inventory items, old products, exhibition items, artworks, musical instruments, used goods, repaired goods, and research specimens, where a long period may elapse between import and re-export. In such cases, problems may arise such as the importer’s original personnel having left, documents being stored in separate departments, suppliers going out of business, or loss of lot number information.

For cargo that may be subject to CITES regulations, it is recommended to keep the following documents together:

• CITES Export Permit or CITES Re-Export Certificate from the time of import
• Japanese-side METI documents such as Certificates of Import Approval and Certificates of Prior Confirmation
• Customs-side import records such as the Import Permit Notice
• Import invoice, packing list, Bill of Lading (B/L), Air Waybill (AWB)
• Records of domestic sales, transfers, and inventory movements
• Photos of the cargo, tag numbers, serial numbers, and lot numbers for identification
• Manufacturing records and inventory balance documents if processing, splitting, or repackaging has occurred

Points Freight Forwarders and Customs Brokers Should Confirm

Freight forwarders and customs brokers must verify whether the cargo is subject to CITES, even if the shipper simply requests "Please export" or "Please return" the goods. Special attention is necessary, particularly for cargo containing materials derived from animals or plants.

Points to Note During Export Customs Clearance

Obtaining the CITES Re-Export Certificate alone does not complete the practical process. During export customs clearance, it is important to verify that the original certificate, cargo, invoice, B/L, AWB, and other shipping documents are consistent.

• Present the original CITES Re-Export Certificate to Customs.
• Ensure the description, quantity, weight, number of pieces, and scientific names on the certificate match the shipping documents.
• Confirm that required shipping information, such as B/L number, AWB number, and mode of transport, is correctly recorded.
• Verify that any necessary endorsements are made in the Customs confirmation section.
• Confirm that export customs clearance and shipment occur within the certificate’s validity period.
• Ensure the original certificate reliably reaches either the cargo or the importer for import procedures in the destination country.
• Manage so that, for air cargo or international courier shipments, documents are not sent separately from the cargo without proper control.
• Note that clearance procedures are still required for CITES-regulated items even if shipped by mail or as small parcels.

In the destination country, import may be denied due to incomplete or inconsistent CITES documents, missing originals, lacking endorsements in the Customs section, quantity discrepancies, incorrect scientific names, or expired certificates. Even if export is authorized in Japan, failure to obtain import authorization in the destination country could result in cargo return, detention, seizure, or disposal risks.

Common Practical Issues

Example 1: Return Shipment After Repair

When musical instruments, leather goods, artworks, or other items containing CITES-regulated materials are brought into Japan from overseas customers for repair, a CITES Re-Export Certificate may become necessary when returning the items to the original country or another destination after repair.

Shippers tend to think of this as simply "repair and return," but under CITES, the regulated goods enter Japan once and then move internationally again when exported. Therefore, it is necessary to verify the CITES documents at import, repair order, repair details, and evidence of the cargo’s identity such as photos or serial numbers to determine whether a Re-Export Certificate is required.

In particular, if parts replacement, modification, or repackaging has occurred during repair, documentation explaining how the imported goods correspond to the returned goods becomes especially important.

Example 2: Transfer to a Third Country After an Exhibition

When CITES-regulated items brought from overseas to a Japanese exhibition are shipped not back to the exhibitor’s home country but to the next exhibition country or sales destination after the event, a Re-Export Certificate may be required.

Exhibition goods tend to be handled like regular cargo because they are not for sale, remain in Japan only briefly, and are moved immediately after the exhibition ends. However, for CITES-regulated goods, it is necessary to confirm which CITES documentation allowed their import into Japan and to verify whether the items leaving for another country after the exhibition can be identified as the same cargo.

Since communication among the organizer, exhibitor, overseas agent, domestic freight forwarder, and customs broker is often fragmented for exhibition cargo, it is important to confirm plans for return or onward transfer well before the exhibition begins.

Example 3: Partial Re-Export of Stocked Goods

There are cases where products containing CITES-listed materials are imported together into Japan from overseas, stored as inventory domestically, and then sold to third countries in multiple shipments. In such cases, it is important to be able to explain the correspondence between the quantities at import and those for each re-export.

For example, if 100 items of crocodile leather or rare wood products are imported, with 30 sold domestically, 20 sold to third countries, and the remainder kept in inventory, it is necessary to document and clearly identify which import lot the re-exported cargo belongs to. This can be done by combining the CITES import documentation, sales records, inventory ledgers, lot numbers, product tags, and photographs.

With stock inventory, the longer the time between import and re-export, the higher the risks of document loss, personnel changes, unidentified lots, and quantity discrepancies. In practice, it is essential to retain documents from the import stage with the potential for re-export in mind when dealing with CITES-listed items.

Common Misunderstandings

Relation of CITES to This Article

CITES is an international treaty that regulates the trade of wild fauna and flora species threatened with extinction. The main CITES article covers the treaty’s objectives, the concepts of Appendices I, II, and III, the applicable species and products, and the basics of export and import controls.

In contrast, the article on CITES Re-Export Certificates focuses on the practical procedures when goods subject to CITES, already imported once, are to be sent onward to a third country.

Therefore, the basic check of whether goods are subject to CITES should be done using the main CITES article. At the actual stage of export from Japan to a third country, confirmation should be done as shown in this article: whether re-export applies, what import documents were used, the domestic distribution route, certificate validity, and original document handling during export customs clearance.

Summary

The CITES Re-Export Certificate is a crucial document required when re-exporting CITES-regulated goods from a country that previously imported them to a third country.

The key difference from the standard CITES Export Permit lies in the relationship between the goods' country of origin and the exporting country. Documentation and explanations required differ depending on whether the goods originating in Japan are exported from Japan, or goods originating overseas are re-exported from Japan to a third country.

In practice, it is essential to confirm whether the goods are CITES-listed species, identify the country of origin, verify that the goods were properly imported into Japan, confirm the existence of CITES documentation from the import, retain both METI-side import approval documents and Customs-side import permit records where relevant, explain the domestic sales or transfer history, and ensure shipment can occur within the Re-Export Certificate’s validity period.

For Appendix I species in particular, it is important to demonstrate the legality of past imports, explain original export permits or applicable exemptions, and confirm that the current goods correspond to the import documentation.

For freight forwarders and customs brokers, confirming the presence or absence of CITES-related requirements from the cargo owner at the point of instruction is critical to avoid risks of last-minute discoveries before shipment. Practical handling of the CITES Re-Export Certificate involves not only obtaining the certificate but also verifying the origin of the goods, continuity of documentation, validity periods, METI-side import approval records, Customs import permit records, and proper management of original documents at customs clearance.