Berlin, 19.

August 2022

CITES COP19 – Listing of new timber species

To whom it may concern,

the European Timber Trade Federation (ETTF) is the trade and lobby association for the European timber trade and timber
import trade. ETTF represents 12 European member associations and several associated companies in countries that are
closely related to the EU timber trade. Our member associations unite timber importers and traders from the predominantly
small and medium-sized business sector, among which several deal with import and trade of timber species that are subject
to CITES regulations.

We have asked our importers for their opinion on the planned CITES listing of new species and we would like to share the
results with you in the following.

Overall, our members fully support the principles of sustainability and the Washington Convention on International Trade in
Endangered Species of Wild Fauna and Flora, and they welcome the protection of endangered species without exception.
Furthermore, they praise the cooperation with EU CITES officials so far, especially in connection with EUTR-CA inspections, as
no further EUTR-relevant documents have to be submitted after an approved import of CITES-protected species.

We note that by far not all species of the genera mentioned below would justify the proposed listing status. This raises the
question of why species that are specifically relevant for trade should be protected with the entire genus, whereas species
threatened with extinction with regionally very limited occurrence often do not yet have a protected status. In many cases
(Khaya spp., Afzelia spp.), we believe that protected status would only be appropriate for some regional occurrences, or from
targeted countries; not, however, for all populations in Central and West Africa.
For the above reasons, we oppose the proposed listing of the following genera:

- Handroanthus spp.
- Tabebuia spp.
- Afzelia spp.
- Pterocarpus spp.
- Khaya spp.
- Dipteryx spp.

EUROPEAN AM WEIDENDAMM 1 A VOLKSBANK WIESBADEN E. G. VEREINSREGISTER-NR.:

TIMBER TRADE FEDERATION 10117 BERLIN, GERMANY IBAN DE 29 5109 0000 0045 1105 08 AG CHARLOTTENBURG, VR 27657 B
EUROPÄISCHER TELEFON +49 30 726258-00 BIC WIBADE5W GOEBEL@ETTF.INFO
HOLZHANDELSVERBAND TELEFAX +49 30 726258-88 UST-ID DE 113.821.949 WWW.ETTF.INFO
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Within these genera, however, the protection of specific species from specific origins, provided they are threatened, would
of course be approved by ETTF.

Regarding the question of whether our members welcome the new listings, a clear and refusing opinion is evident. It is
unanimously stated that this will increase the administrative burden for the species in question and that this will result in a
competitive disadvantage for European importers. The waiting periods for obtaining import and export licences are often too
long, customers therefore refrain from buying listed species or even withdraw from concluded contracts because of the
waiting period.

Our members also report that CITES listings are increasingly becoming a barrier to trade. The national CITES authorities in the
EU often demand further information about the foreign suppliers - despite the existence of an export licence - like an EUTR
inspection. In our opinion, this contradicts the CITES system, in which market participants are not assigned any role.
Enforcement deficits in the listing country must not be to the detriment of the import trade.

The customers’ attitude towards listed CITES species is often negative per se, because they see the danger of trading a strictly
protected species – which is permitted in Annex II / EU B within the appropriate framework. The knowledge of the timber
trade’s customers certainly plays a role here, and it must be emphasised that the background to the various protection
classes is understandably not always familiar.

Furthermore, we would like to point out that the protection of existing forests, and thus species, is possible, in addition to
conservation, to a large extent through legal or even certified trade. If wood products lose their market share due to
increased administrative requirements, the market value and its positive effects on local value creation also diminish. As a
result, previously high-value timber assortments are, in the worst case, converted to charcoal and the land is subsequently
transferred to other forms of land use. In turn, we see the loss of value of the forest, especially in the tropical countries of
Africa, as a gateway for global actors who attach much less value to species conservation issues than the EU does, for
example.

Counteracting this development is our priority goal, but we do not consider the protection of more and more species, that
are not significantly threatened as a whole, to be appropriate.

We would be very pleased if our positions could be considered in the further course of the negotiations and are, of course,
happy to answer any questions.

Nils Olaf Petersen on behalf of

European Timber Trade Federation

EUROPEAN AM WEIDENDAMM 1 A VOLKSBANK WIESBADEN E. G. VEREINSREGISTER-NR.:

TIMBER TRADE FEDERATION 10117 BERLIN, GERMANY IBAN DE 29 5109 0000 0045 1105 08 AG CHARLOTTENBURG, VR 27657 B
EUROPÄISCHER TELEFON +49 30 726258-00 BIC WIBADE5W GOEBEL@ETTF.INFO
HOLZHANDELSVERBAND TELEFAX +49 30 726258-88 UST-ID DE 113.821.949 WWW.ETTF.INFO