Euphorbia hedyotoides - Calandstr, Leiden, NL 23 Feb 2009 03 Leo

On Conservation Status and Trade Legality Issues:

The IUCN rates this as an endangered species since 2004. T. Haevermans, the person who evaluated this species for the IUCN, thought it should be rated as endangered due to its small extent of occurrence; he states it is recorded from only 15 localities and comprises of four to five sub-populations. Nonetheless, it is also published as being common throughout its range in a number of articles on the subject by the late Werner Rauh, possibly formerly the greatest expert on this species. Furthermore, I can find a few more localities than 15 on the GBIF, and I know for certain new localities were discovered since 2004. Lastly, looking at the synonymy and history of this species, one must conclude that it is now naturalized in Tanzania, and has thus actually increased its area of distribution due to man. The greatest threat to its continued existence on this planet is habitat degradation, according to Haevermans. Judging from the climate and geography, I think this must be due to cattle-ranching in this area, although possibly also goat-herding. Looking at the FAO's database on international trade in beef (or goat), one would conclude that this ranching is mostly for local consumption. Other threats listed are fire and charcoal production. Fire is probably caused mostly due to people clearing land for ranching and charcoal production is driven by local need for cooking fuel, and can cause habitat destruction for up to 60kms around a large metropolis. The last thing of concern is large specimens being harvested for the horticultural trade, most of which is local.

 

Okay, that was the IUCN, now CITES.

In 1975 this species along with all other Euphorbia (including E. pulcherrima) were placed under CITES II; excluding only pollen, seeds, tissue culture or flasked plants. The reason for this was the massive collecting of wild Euphorbia species belonging to the E. obesa group. It was feared that if only these species were declared illegal to harvest, then collectors' attentions would shift to other species. Although over the next few decades more exceptions were permitted to allow the international trade in horticultural plants; such as E. milii, E. lactea or since 2007 E. trigona; trade in succulent Euphorbia has remained illegal. The two most pertinent changes to CITES in interest of this post are in 2005 and 2007. In 2005 a report was prepared and submitted to the CITES council in which was recommended to delist a large number of species, including E. hedyotoides, based on the fact that the international trade in this species was not seen as a cause for concern regarding its conservation. Here it is (in French): www.cites.org/fra/com/PC/15/F-PC15-WG2.pdf.

This report was ignored. In 2007, the government of Madagascar sent a response to the CITES secretariat. I haven't been able to get my hands on a copy of that. I'd like to see it. Either way, the council again decided to keep this species classed under CITES II; but with the following exceptions:

a) seeds and pollen (including pollinia);

b) seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers.

That means it is now legal to export seedlings internationally; as long as they are grown sterile in a lab in a test-tube or petri-dish.

 

But...

EU policies regarding endangered species (Regulation (EC) No 338/97) are stricter, but also much much more confusing. This species is rated Annex B, so international trade is legal providing:

1.The E.U. does not implement an import restriction for this species.

2. Scientific Authority has advised the Management Authority of its finding (after considering possible opinion Scientific Review Group) that:

import would not have a harmful effect on the conservation status of the species or decrease the population concerned, although this does not apply to re-imports and specimens acquired before 1 June 1947.

3. Management Authority in consultation with the Scientific Authority are satisfied that there are no other conservation factors against import, although this does not apply to re-imports and specimens acquired before 1 June 1947.

4. Scientific Authority is satisfied that intended accommodation for live animals/plants at the place of destination is adequately equipped to conserve and care for them properly, although it does not apply to re-imports and specimens acquired before 1 June 1947.

5. Applicant to provide documentary evidence that specimens were obtained in accordance with legislation on the protection of the species: for CITES specimens an export permit or re-export certificate, or copy thereof. Where a copy of an export permit or re-export certificate was the basis for the issue of an import permit, the latter shall only be valid if at the time of introduction it is accompanied by the valid original (re-) export document.

What does this all mean?

1. To my knowledge, there is no import restriction set by the EU on this species, so it complies with this provision.

2. This hasn't happened, and in practice happens only very rarely. Notable examples are when it is in a member state's interest to allow trade. As international trade in this species most probably will be only potentially economically beneficial for Africa, it is unlikely the EU will ever adopt such a provision.

3. Same as above (2).

4. Jezus, what a bunch of tree-hugging crap. I suppose an applicant would have to have some publicized or photographic evidence he would have to send to the Scientific Authority to prove he knows how to not kill the plant too quickly? I question what the point is of this; as long as natural populations are unaffected then who cares how many European collectors kill their plants? It seems to me great; the more Europeans kill their plants, the more they need to import new ones, the greater the economical significance of the species the more economic incentive for local populations to conserve the species, but that is ethics and I'll get back to that some other time.

5. Yeah, this seems fair. I'd add a link to the obscure website where you can fill in a form for this later.

 

Loophole: Yes, I think I see a loophole on how to get around this. One imports seeds to Europe, germinates them here, re-exports the germinated embryos back to Africa, then re-imports the grown caudexes back to Europe.

 

More Conservation Data:

1. Wild populations are protected in a number of nature parks and reserves.

2. International trade in the EU in this species: From 1999 to 2007 only 76 specimens have been imported to the EU, and none exported from the EU. In 2005 75 plants were imported from Madagascar to Spain, the Czech Republic and Germany. In 2004 1 plant was imported to the Czech Republic from Madagascar for non-trade purposes.

3. Germplasm: This species is well-represented in collections at botanical gardens or university accessions around the globe. Living germplasm is kept in Madagascar, Japan, the USA, France, Germany, Switzerland, the Czech Republic, Spain, the Netherlands, Denmark and the Ukraine. However, may of these collections represent only one or two plants. Considering it is dioecious, it would be pertinent to obtain opposite sexed individuals or to work together to exchange pollen.

 

Discussion of the above:

IUCN: The rating as endangered is somewhat questionable. Without clear data supporting an actual decline in population, and numerous recent reports of it being common (including in the IUCN report), I would myself conclude that endangered is too much. The threats as given by Haevermans might be very real, however, and someone over there needs to do a study on the impact of these threats on the known localities. The issue of known localities is also a finicky one; it is much more likely that that the full distribution of this species has simply not been fully elucidated due to incomplete sampling, than that it is truly restricted to small local populations. Lastly, I would like to point out that the three main threats to the species are local in nature, and are not caused by international trade in this species.

CITES: I think this is out-dated. On an ethical level, it really bugs me that legal trade in this species has been relegated to people with sterilized labs, or contacts with government CITES awarding agencies, making it impossible for the local people, whose environment we say we are protecting for them, to have any economic benefit from this. Furthermore, as pointed out in the IUCN and my analysis of the import figures for the EU, international trade in this species is not the biggest threat. There is a real possibility that CITES accreditation actually harms the conservation of this species, because it renders this species into a worthless, poisonous weed which ought to be cleared for cattle-ranching. Considering land-clearance and so is going on anyway in this region, wouldn't it be wise to allow ranchers with one of these on their land to sell it, rather than just burn it? And this CITES documentation application is earning the Malagasy government a lot of money. Insofar how much seems a question of great significance regarding trade issues in endangered species.

EU Regulation (EC) No 338/97: Come on guys! First off, how about someone rewrites this so it is understandable. The law is barely coherent, and regarding plants includes some quite nonsensical animal-rights activistesque nonsense. As far as I can tell, the extra restrictions are an intimidation method to discourage trade rather than stop it altogether, and have more to do with building non-tariff trade barriers in order to block 3rd world producers from accessing EU markets.

 

PS: Let me quickly note that Mr. Haevermans is a recognised authority on Malagasy Euphorbia, and maybe I should shut up.

Done