CITES — Customs Checks and Required Documents for Imports and Exports
Interlink編集部What is CITES?
CITES stands for the Convention on International Trade in Endangered Species of Wild Fauna and Flora, commonly known in Japanese as the Washington Convention.
CITES is an international treaty that regulates the trade of endangered wild animals and plants, including their specimens, parts, and processed products. It was adopted in 1973 in Washington, D.C., USA, with the aim of preventing the extinction of wildlife caused by excessive international trade.
In international logistics and trade practice, CITES may apply not only to the animals and plants themselves but also to leather goods, timber, musical instruments, specimens, ornaments, pharmaceutical raw materials, cosmetic raw materials, food ingredients, antiques, and wildlife-derived products sold through cross-border e-commerce.
For CITES-regulated cargo, standard documents such as invoices, packing lists, Bills of Lading, and Air Waybills alone may not be sufficient to complete procedures. It is necessary to confirm before shipment the regulated species, scientific names, raw materials, country of origin, appendix classification, export permits from the exporting country, whether the goods are for re-export, and whether approval or prior confirmation is required in the importing country.
Scope Covered in This Article
This article outlines the basic structure of the entire CITES system and the initial points to confirm in international logistics and customs clearance practice.
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of CITES | Covers the purpose of CITES, regulated cargo, appendices classification, and an overview of required documents. | Details on treaty texts and individual amendments at Parties’ meetings should be checked in specialized materials. |
| Appendices I, II, III | Outlines the levels of regulation per appendix and practical differences in logistics. | Individual species listings, annotations, export quotas, and reservations must be confirmed case-by-case. |
| CITES Export Permit | Explains the role of permits required in the exporting country. | Application forms, issuance conditions, issuing authorities, and submission documents vary by exporting country and are covered separately. |
| CITES Re-export Certificate | Describes the approach when re-exporting CITES-listed items previously imported. | Requirements for obtaining re-export certificates, prior import records, and identity verification are detailed in dedicated articles. |
| Import Approval and Prior Confirmation in Japan | Explains issues related to Japan’s Ministry of Economy, Trade and Industry import approval and prior confirmation for imports into Japan. | Public import notifications, the Import Trade Control Order, and individual application requirements are covered in system-specific explanations. |
| Relation to the Act on the Conservation of Endangered Species of Wild Fauna and Flora | Summarizes the relationship between CITES and domestic regulations on transfer, sale, display, and advertisement in Japan. | Domestic sales, registration tags, specified international species projects, and transfer restrictions are explained in the Act’s dedicated article. |
| Relation with Other Laws | Organizes relevant points concerning plant quarantine, animal quarantine, food sanitation, Pharmaceuticals and Medical Devices Act (PMD Act), and customs law. | Quarantine procedures, food notifications, PMD Act applicability, and import/export declaration practices are confirmed in respective articles. |
Purpose and Background of CITES
The purpose of CITES is to prevent extinction caused by excessive international trade in wild animals and plants, balancing species conservation with sustainable use.
Rare animals and plants may see increased international demand as materials for leather, timber, ornaments, musical instruments, specimens, pharmaceutical ingredients, cosmetics ingredients, and food ingredients. Rising demand can lead to overexploitation, illegal collection, smuggling, improper breeding or cultivation, and trade misrepresenting the origin.
CITES classifies the species it covers into Appendices I, II, and III, establishing a system where exporting and importing countries regulate international trade through permits and certificates. Therefore, CITES is not merely a customs procedure but a framework intersecting environmental protection, species conservation, international trade management, and export-import control.
Regulatory Positioning within Japan
Although CITES is an international treaty, its practical application to export and import cargo in Japan is implemented through domestic legal frameworks.
In Japan, the export and import control of CITES-listed items involves procedures under the Foreign Exchange and Foreign Trade Act, the Export Trade Control Order, the Import Trade Control Order, and export and import notifications administered by the Ministry of Economy, Trade and Industry (METI). When exporting from Japan, export approval by the Minister of Economy, Trade and Industry and a CITES export permit are relevant. For imports into Japan, a CITES export permit or re-export certificate issued by the exporting country is required, and depending on the species, import approval or prior confirmation from the Minister of Economy, Trade and Industry may also be necessary.
Separately, domestic transfer, sale, public display for distribution purposes, or advertising of CITES-listed or rare wild flora and fauna may be subject to the Act on Conservation of Endangered Species of Wild Fauna and Flora, commonly known as the Species Conservation Act.
Therefore, for CITES-controlled cargo, it is essential to distinguish between border control at export/import and domestic trade regulations after import or during domestic distribution. Even if import customs clearance is granted, subsequent domestic sale, transfer, or advertising may not be unrestricted.
Roles of Related Organizations
| Organization | Main Role | Practical Verification Situations | Notes |
|---|---|---|---|
| CITES Secretariat | Manages overall treaty implementation, organizes information among Parties, and publishes Appendix lists. | Referenced when checking target species, Appendices, Parties, and export quota information. | Does not directly determine import eligibility of individual cargo in Japan. |
| Exporting Country’s Management Authority | Issues CITES export permits and re-export certificates. | Relevant when exporters obtain required documents before shipment. | Having an export permit does not guarantee that import approval or prior confirmation will be waived by the importing country. |
| Ministry of Economy, Trade and Industry (METI) | Oversees export authorization, import approval, and prior confirmation for CITES-controlled cargo in Japan. | Engaged when confirming procedures for exports from Japan or imports into Japan. | Required procedures vary depending on species, Appendix classification, country of origin, exporting country, and intended use. |
| Customs | Checks CITES-related documents and export/import authorizations during declarations. | Involved in export/import declarations, cargo inspections, document reviews, and clearance at designated customs offices. | CITES cargo may be restricted to declaration at specific customs offices. |
| Ministry of the Environment | Manages the Act on Conservation of Endangered Species of Wild Fauna and Flora, and systems for domestic and internationally rare wildlife species. | Involved in confirming domestic transfers, sales, displays, advertising, and registration tags. | Domestic distribution controls must be verified separately from import border procedures. |
| Shippers / Manufacturers | Prepare raw materials, scientific names, country of origin, manufacturing processes, and certification documents. | Relevant during quoting, ordering, pre-shipment confirmation, and preparing customs documents. | Freight forwarders and customs brokers alone may not be able to verify the authenticity of scientific names or raw materials. |
Overview of CITES Appendices I, II, and III
CITES-listed species are classified into Appendix I, Appendix II, and Appendix III. In actual logistics practice, this classification is the first key point to check.
| Category | Regulatory Concept | Commercial Trade Concept | Main Required Documents | Practical Notes |
|---|---|---|---|---|
| Appendix I | Species facing a high risk of extinction and subject to or potentially affected by trade impact, thus strictly regulated. | International commercial trade is generally prohibited. | For exceptions such as non-commercial purposes, permits from both the exporting and importing countries may be required. | “Appendix I = no trade whatsoever” is not absolute; exceptions for scientific use, specimens obtained before treaty application, and artificially propagated or bred specimens need to be confirmed. |
| Appendix II | Species not necessarily currently endangered but which could become at risk without controlled trade. | International commercial trade may be permitted under certain conditions. | Usually requires the exporting country’s CITES export permit or re-export certificate. | For some species, it is necessary to verify whether the export quota set by the exporting country applies. |
| Appendix III | A specific party requests cooperation from other parties to control trade for species protected nationally. | International commercial trade may be allowed. | For exports originating from the listing country, an export permit is required; if the origin is outside the listing country, a certificate of origin or similar documents apply. | Necessary documents vary depending on which country requested the listing, the origin country, and the exporting country. |
The Appendix classification is more than just a label. It forms the basis for determining trade permissibility, the necessity of export permits, import approvals, re-export certificates, and documents checked during customs clearance.
Confirming Exceptions under Appendix I
Appendix I generally prohibits international trade for commercial purposes; however, in practice, it is important to verify whether any exceptions apply.
| Commonly Checked Exception Cases | Overview | Practical Confirmation Points | Notes |
|---|---|---|---|
| Academic Research Purposes | Transactions for research, education, specimen exchange, or other non-commercial purposes. | Confirm the purpose of the transaction, receiving institution, export permits, import approvals, or related authorizations. | Supporting documents must prove the non-commercial nature of the transaction. |
| Specimens Acquired Before Treaty Application | Cases involving specimens or processed items obtained prior to CITES regulations. | Verify acquisition date, acquisition channel, and any existing certification documents. | It may be difficult to prove the acquisition date for old antiques or artworks. |
| Artificially Bred or Cultivated Specimens | Specimens bred or cultivated in controlled facilities, not derived from the wild. | Check breeding or cultivation facility, registered facility status, breeding certificates, and origin information. | Even if marked as artificially bred, evidence may be insufficient. |
| Personal Effects and Household Goods | Items transported as personal belongings rather than commercial cargo. | Confirm intended use, quantity, acquisition route, and whether there is any intent to sell. | CITES documentation may still be required even for personal items. |
| Re-exported Items | CITES-listed items previously imported and now being exported to another country. | Check previous import approval records, re-export certificates, and confirm identity of the specimens. | Required documents differ from those for direct export from the country of origin. |
| Cases Involving Reservations by Parties | Situations where a Party has placed reservations on specific species. | Verify the species involved, the Party (country), and the presence of reservations. | Separate confirmation is needed for handling by Japan and by the counterpart country. |
Checking Appendix II and Export Quotas
Appendix II may allow international trade under certain conditions. However, being listed in Appendix II does not mean exports or imports can be freely conducted.
For some species, the exporting country may set an annual export quota. If an export quota is established, export permits may only be issued within the allocated quota. Additionally, handling may vary depending on the species' country of origin, population, harvesting region, harvest year, intended use, and whether they are wild-sourced or artificially propagated.
In practice, it is necessary to verify not only the Appendix classification but also whether the export country authorizes issuance, the presence of export quotas, the validity period of permits, and that the cargo quantity matches the permitted quantity.
Situations Where CITES Applies
CITES may apply not only to whole animals and plants but also to parts, derivatives, and processed products.
| Situation | Potential Cargo | Information to Confirm | Practical Considerations |
|---|---|---|---|
| Import/export of live animals and plants | Ornamental fish, reptiles, birds, plants, orchids, cacti, etc. | Scientific name, appendix classification, country of origin, exporting country, purpose of import | Quarantine requirements and transport conditions may also be relevant. |
| Import/export of leather products | Crocodile leather bags, snake leather shoes, lizard leather wallets, etc. | Material, scientific name, country of origin, processing country, export permits | Species identification cannot be based on product names alone. |
| Import/export of timber and wood products | Rare woods, furniture, veneers, musical instrument materials, etc. | Wood species, scientific name, country of origin, processing status, quantity | Should be coordinated with plant quarantine and legal timber verification. |
| International movement of musical instruments | Instruments containing rosewood, ivory, tortoiseshell, shells, leather | Materials, manufacturing date, owner, purpose of movement, presence of re-export | Classification differs depending on whether items are for sale or for touring/exhibition. |
| Raw materials for pharmaceuticals, cosmetics, dietary supplements | Plant extracts, animal-derived materials, fragrances, extracts, etc. | Raw materials, scientific names, ingredient lists, intended usage, applicability under the Pharmaceuticals and Medical Devices Act (PMD Act) | Even if not subject to CITES, shipment may be halted under the PMD Act or food sanitation laws. |
| Specimens, taxidermy, and ornaments | Taxidermy, bones, horns, tusks, coral, shells, insect specimens, etc. | Target species, acquisition date, country of origin, whether intended for sale | CITES checks may be required even for antiques or personal possessions. |
| Cross-border e-commerce and personal imports | Leather goods, accessories, ornaments, specimens, folk crafts, etc. | Sales page details, materials, dispatching country, country of origin, presence of permits | Regulations may apply even for small quantities or personal use. |
Goods Potentially Subject to CITES
In practice, the following types of goods may require verification of their CITES applicability.
- Leather products made from animals
- Products using reptile leather, including crocodile, snake, and lizard leather
- Products made from ivory, tortoiseshell, bone, horn, or tusks
- Coral, shells, mother-of-pearl, and animal-derived ornaments
- Rare woods, wooden products, furniture, veneers, and musical instrument materials
- Plant-derived raw materials for pharmaceuticals, cosmetics, and health supplements
- Specimens, taxidermy, insect collections, and artworks or antiques derived from animals or plants
- Animal and plant-derived powders, extracts, oils, fragrances, and processed raw materials
The product name alone may not be sufficient to determine CITES applicability. It is necessary to check the raw materials, scientific names, country of origin, processing status, acquisition date, and intended use.
Application Requirements and Possible Exemptions
| Category | Items to Confirm | Cases Likely Subject to CITES | Cases Possibly Exempt or Requiring Separate Confirmation |
|---|---|---|---|
| Target Species | Check if the animals or plants included in the cargo are listed in the CITES Appendices. | When the species are listed in Appendix I, II, or III. | Even if not listed, species may still be regulated under other laws. |
| Scientific Name | Confirm the Latin scientific name rather than the common name. | When multiple species share the same common name. | If the scientific name is unknown, it may not be possible to determine applicability. |
| Parts and Derivatives | Verify whether parts or derivatives such as leather, wood, bone, or extracts are subject. | When the Appendices' annotations specify that parts or derivatives are covered. | Certain processed products may be exempt based on annotations. |
| Country of Origin / Export | Confirm the raw material's country of origin and the actual exporting country. | When the country of origin differs from the export country, requiring a re-export certificate. | If the movement is solely domestic with no international transit, procedures focus on domestic laws rather than CITES export/import processes. |
| Purpose of Transaction | Confirm whether the purpose is commercial, scientific, personal use, or exhibition. | When intended for sale, resale, commercial exhibition, or purchase for resale. | Non-commercial purposes do not automatically exempt document requirements. |
| Acquisition Date | Check if the specimen was acquired before treaty enforcement or if it is an antique. | If the acquisition date cannot be proven, it may be treated as subject to standard regulations. | If acquisition date and origin can be documented, exceptions may be considered. |
Types of Documents and Responsible Parties
CITES-regulated cargo may involve multiple documents such as export permits, re-export certificates, import approvals, prior confirmations, and raw material certificates.
| Document / Procedure | Main Role | Who Confirms/Obtains It | Practical Notes |
|---|---|---|---|
| CITES Export Permit | Permission issued by the exporting country to export CITES-regulated items. | Usually obtained by the exporter from the export country’s competent authority. | Check that it has been obtained before shipment, verify validity period, quantity, scientific name, and consistency with the cargo. |
| CITES Re-export Certificate | Certificate required when re-exporting CITES-regulated items previously imported into a country. | Obtained by the re-exporter from the re-export country’s competent authority. | Issues include confirming the country of origin, previous import approval records, and identity of the re-exported goods. |
| Import Approval | Procedure to obtain approval from the Minister of Economy, Trade and Industry for imports into Japan. | Typically confirmed and applied for by the importer. | Import approval may be required depending on the species involved and the Appendix classification. |
| Prior Confirmation | Procedure to confirm necessary details with the Ministry of Economy, Trade and Industry before import. | Usually confirmed by the importer. | Some cargo requires prior confirmation rather than import approval. |
| Raw Material Certificate / Scientific Name Confirmation Documents | Documents to verify the species of animals or plants contained, raw materials, and scientific names in the cargo. | May be prepared by the shipper, manufacturer, or exporter. | Product names, common names, or brand names alone may be insufficient. |
| Certificate of Origin | Sometimes required to clarify the country of origin, especially for Appendix III listed items. | May be prepared by exporters, manufacturers, or relevant agencies. | For Appendix III, the relationship between the listed country and country of origin is important. |
| Non-Applicability Explanation Materials | Documents explaining that the cargo does not fall under CITES regulations. | May be prepared by the shipper, manufacturer, or exporter. | Must provide justification based on scientific name, materials, annotations, or manufacturing information. |
Points to Confirm in Customs Clearance Practice
CITES-related cargo may require more than the usual customs documents for proper verification.
- Whether the cargo contains raw materials derived from plants or animals
- Whether the scientific names of the applicable species can be confirmed
- Which CITES Appendix (I, II, or III) the species falls under
- Whether a CITES export permit has been obtained from the exporting country
- Whether a CITES re-export certificate is required for re-export shipments
- Whether import approval or prior confirmation is needed on the Japan side
- Whether the details in the invoice, packing list, and permits are consistent
- Whether the customs office where the declaration is made can handle CITES-related cargo
- Whether other regulations such as plant quarantine, animal quarantine, food sanitation, or the Pharmaceuticals and Medical Devices Act (PMD Act) need to be verified
Waiting until immediately before the import declaration to check CITES requirements may be too late. If cargo may be subject to CITES, it is important to confirm at the stages of quotation, contract, order placement, and shipment arrangement.
Points Freight Forwarders and Customs Brokers Should Confirm
Even if freight forwarders and customs brokers are not directly responsible for obtaining CITES permits, overlooking the possibility that cargo is subject to CITES may result in shipment delays, customs clearance suspension, storage charges, return shipments, disposal, and liability issues with the cargo owner.
| Confirmation Timing | Contact Party | Items to Confirm | Actions if Issues Arise |
|---|---|---|---|
| When receiving a quotation request | Shipper / Importer | Check if the cargo contains materials derived from animals or plants. | If the material is unclear, request manufacturer documentation or ingredient lists. |
| Before arranging shipment | Exporter / Overseas agent | Confirm plans to obtain the CITES Export Permit or Re-export Certificate. | If permits have not been obtained, make completion of permits before shipment a condition. |
| Upon receiving documents | Shipper / Exporter | Verify that scientific names, quantities, origin country, export country, and product descriptions agree across documents. | If discrepancies exist, request corrections or supplementary documents before declaration. |
| Before import declaration | Importer / Customs broker | Check whether import approval or prior confirmation is required in Japan. | If required procedures are incomplete, review the timing of declaration and delivery plans. |
| When confirming designated customs office | Customs broker / Customs | Confirm that the customs office can process declaration of CITES-regulated cargo. | If declaration cannot be made at the designated office, coordinate a change of delivery location or declaration office. |
| When confirming other legal compliance | Shipper / Customs broker / Relevant agencies | Check applicability of plant quarantine, animal quarantine, food sanitation, and Pharmaceuticals and Medical Devices Act (PMD Act). | Explain to the shipper the need for procedures under these other laws in addition to CITES documentation. |
| When document deficiencies are identified | Shipper / Exporter / Overseas agent | Confirm feasibility of additional documentation, replacements, return shipments, disposal, or continued storage. | Promptly clarify responsibility for costs, impacts on delivery schedule, and contractual liability. |
Points Shippers and Importers/Exporters Should Confirm
Shippers, exporters, and importers need to verify the following when there is a possibility that the cargo falls under CITES regulations:
- Whether the product contains raw materials derived from animals or plants
- Whether the scientific name of the species can be confirmed
- Whether the country of origin of the raw materials can be identified
- Whether the species is commercially allowed for trade
- Whether the species falls under CITES Appendix I, II, or III
- Whether an export permit, re-export certificate, import approval, or prior confirmation is required
- Whether certification documents can be obtained from the manufacturer or supplier
- Whether additional checks such as export quotas, acquisition timing, artificial propagation, or breeding are necessary
- Whether permits or inspections under other laws such as plant quarantine, animal quarantine, food sanitation, Pharmaceuticals and Medical Devices Act (PMD Act) are required
- Whether all necessary documents are prepared before shipment
If CITES-regulated items are shipped without proper documentation, resolving issues post-shipment becomes difficult. It is critical for the shipper to confirm product details, raw material information, scientific names, country of origin, and acquisition routes as early as possible.
Comparison between CITES and Other Systems
| System | Main Purpose | Main Target | Responsible Authorities / Counterparties | Relationship with CITES |
|---|---|---|---|---|
| CITES | To regulate international trade of endangered wild flora and fauna. | Listed species in appendices, their specimens, parts, derivatives, and processed products. | Export country control authorities, Ministry of Economy, Trade and Industry, Customs, shippers. | Permits, certificates, and import approval issues arise during international trade. |
| Species Protection Law | To regulate protection, transfer, and sale of rare wild flora and fauna within Japan. | Rare domestic and international wild flora and fauna species. | Ministry of the Environment, trade parties, retailers. | Issues may arise regarding domestic sales, transfers, display, and advertising after import. |
| Foreign Exchange and Foreign Trade Act / Export and Import Trade Control Order | To manage Japan’s export and import controls. | Goods subject to export approval, import approval, and prior confirmation. | Ministry of Economy, Trade and Industry, Customs, exporters and importers. | Related to border control of CITES-regulated goods in Japan. |
| Plant Quarantine | To prevent the introduction and spread of pests and diseases. | Plants, seeds, timber, plant-derived products, etc. | Plant Protection Stations, importers, customs brokers. | May require inspection even if items are outside CITES scope. |
| Animal Quarantine | To prevent the introduction of livestock infectious diseases. | Animals, livestock products, animal-derived products, etc. | Animal Quarantine Stations, importers, customs brokers. | Separate checks needed for leather, hair, bones, and other animal-derived products apart from CITES. |
| Food Sanitation Act | To ensure food safety. | Food, food additives, food ingredients, utensils, containers, and packaging. | Quarantine stations, importers, customs brokers. | Necessary to verify when plant- or animal-derived ingredients are for food use. |
| Pharmaceuticals and Medical Devices Act (PMD Act) | To regulate pharmaceuticals, quasi-drugs, cosmetics, medical devices, and others. | Pharmaceuticals, cosmetics, quasi-drugs, raw materials, products with medicinal claims. | Ministry of Health, Labour and Welfare, prefectural governments, importers. | Verification is needed when plant- or animal-derived materials are used for pharmaceutical or cosmetic purposes. |
Common Misconceptions
| Common Misconception | Actual Understanding | Practical Notes |
|---|---|---|
| The Washington Convention applies only to live animals and plants. | It covers not only whole specimens but also parts, derivatives, and processed products in some cases. | Leather, wood, bones, horns, coral, extracts, powders, and ornaments should also be checked. |
| If the product name does not include animal or plant names, it is not subject to CITES. | The determination is based on raw materials, scientific names, country of origin, and processing status—not on product names. | It is important not to rely solely on brand names or generic terms to exclude applicability. |
| If the export country issues a CITES export permit, no procedures are needed on the Japan side. | For certain species, import approval or prior confirmation may still be required in Japan. | Export-side documents and import-side procedures should be checked separately. |
| Appendix I species cannot be exported or imported under any circumstances. | Commercial international trade is generally prohibited, but exceptions like academic use, specimens obtained before treaty application, and artificially propagated or bred individuals may apply. | Exceptions require verification with supporting documents and relevant authorities. |
| Appendix II species can be imported just like regular cargo. | Even Appendix II species require export permits, re-export certificates, export quotas, and import-side confirmations. | Confirm whether the export country issues permits before shipment. |
| Appendix III species usually do not require concern. | Requirements vary depending on the listing country, country of origin, and export country, even for Appendix III. | Confirm whether the listing country is considered the country of origin or if origin is another country. |
| CITES does not apply to small quantities or personal imports. | Even small amounts, personal use, postal shipments, or cross-border e-commerce may be regulated if the items are subject species. | Documentation checks at export/import may be necessary even if not for resale. |
| Checking CITES compliance means no need to check other regulations. | Separate regulations such as quarantine, food sanitation, Pharmaceuticals and Medical Devices Act (PMD Act), and Customs Act may also apply. | For animal- and plant-derived cargo, multiple laws often need to be reviewed simultaneously. |
Typical Situations Where the System Becomes an Issue
| Situation | Common Problematic Cargo | Main Risks | Practical Measures |
|---|---|---|---|
| When importing crocodile leather bags | Leather goods made from crocodile, snake, lizard, etc. | Unclear scientific names, lack of export permits, unconfirmed import approval | Confirm material, scientific name, country of origin, export permits, and Japanese procedures before shipment. |
| When importing furniture made with rare wood | Wood products including rosewood, mahogany, etc. | Unidentified wood species, overlooked annex notes, missed plant quarantine | Confirm wood species, scientific name, processing status, and plant quarantine requirements. |
| When selling musical instruments overseas | Instruments containing wood, ivory, tortoiseshell, shell, leather | Parts subject to CITES, lack of re-export certificates | Confirm manufacturing date, materials, country of origin, sales purpose, and whether re-export is involved. |
| When importing cosmetic raw materials | Plant extracts, animal-derived ingredients, fragrances, fats and oils | CITES applicability, overlap with Pharmaceuticals and Medical Devices Act (PMD Act) and Food Sanitation Law | Check ingredient lists, scientific names, intended use, and regulatory status under PMD Act. |
| When importing antiques or decorative items | Products containing ivory, tortoiseshell, coral, bone, horns, tusks | Unknown acquisition date, insufficient proof of pre-convention acquisition | Verify acquisition date, origin, past documentation, and presence of sales purpose. |
| When handling re-exported items | CITES-covered goods previously imported into a third country | Need re-export certificate instead of export permit | Confirm country of origin, past import records, re-export certificates, and cargo identity. |
| When importing small quantities via cross-border e-commerce | Accessories, small leather goods, specimens, folk crafts | Mistaken as personal import leading to failure in obtaining necessary documents | Explain that even small quantities of regulated items require checking export/import controls. |
| When dealing with species subject to export quotas | Species managed under quota systems by exporting countries | No export permit issued or quantity does not match quota | Early confirmation of issuing authority, permitted quantities, and remaining quota balance in the exporting country. |
Practical Confirmation Workflow
- Check whether the cargo contains raw materials derived from animals or plants.
- Verify the scientific name of the species involved, rather than using common names.
- Confirm the country of origin, exporting country, and whether there is any re-export involved for the raw materials.
- Determine which CITES Appendix (I, II, or III) applies to the species concerned.
- Review the annotations in the appendices, including the relevant parts, derivatives, and the scope of processed products.
- If the species is listed in Appendix I, check the general prohibition status and any applicable exceptions.
- If listed in Appendix II, verify if export permits, re-export certificates, or export quotas are required.
- If listed in Appendix III, confirm the relationship between the listing country, country of origin, and exporting country.
- Check whether import approval, prior confirmation, or export approval is required on the Japan side.
- Ensure consistency among the invoice, packing list, permit documents, and certificates.
- Confirm the applicability of other regulations such as plant quarantine, animal quarantine, food sanitation, the Pharmaceuticals and Medical Devices Act (PMD Act), and customs law.
- Perform a final check that all necessary documents are prepared before shipment.
This confirmation process should ideally take place at the stages of quotation, contract, order placement, and shipping arrangements—not immediately before the import declaration.
Risks of Incomplete Documentation
When documentation required for CITES-regulated cargo is missing, the following risks may arise:
- Cargo may be detained by customs
- Declaration processes may need to be switched to designated authorities
- Import approval may be denied
- Shipment may be prevented at the exporting country
- Storage fees may be incurred
- Return or disposal of cargo may be required
- Delivery delays may occur
- Additional time may be needed to obtain missing documents
- Contractual breaches with trading partners may become an issue
- Domestic sale or transfer may be restricted
For CITES-controlled goods, it is critical to verify all necessary documents before shipment rather than waiting to address issues after cargo is held at customs.
Summary
CITES is an international treaty that regulates the trade of endangered wild animals and plants, including their specimens, parts, and processed products.
In international logistics and trade operations, CITES may apply not only to the animals and plants themselves but also to cargo derived from them, such as leather goods, timber, musical instruments, ornaments, specimens, pharmaceutical raw materials, cosmetic ingredients, and food ingredients.
In Japan, the export and import of CITES-listed goods involve procedures under the Ministry of Economy, Trade and Industry (METI), based on the Foreign Exchange and Foreign Trade Act, Export Trade Control Order, Import Trade Control Order, and import notifications. Additionally, after import and during domestic distribution, regulations under the Act on Conservation of Endangered Species of Wild Fauna and Flora may apply to transfers, sales, displays, and advertising.
In CITES compliance, it is essential not to rely solely on product names but to verify raw materials, scientific names, country of origin, appendix classification, export permits, re-export certificates, import approvals, prior confirmations, export quotas, and applicable laws.
Confirming CITES compliance during the quotation, contracting, ordering, and shipping arrangement stages — rather than at customs clearance — is fundamental to preventing transport delays, customs holds, returns, destruction, and additional costs.
