30 July 2012 – The Vietnam CITES Management Authority released its response to the WWF Report on Wildlife Crime Scorecard as follows:
"The Viet Nam CITES Management Authority (MA) received the report “Wildlife Crime Scorecard - Assessing compliance with and enforcement of CITES commitments for tigers, rhinos and elephants” sent from WWF Viet Nam, which ranked Viet Nam the top in wildlife crime. Regarding to this, we would like to have some comments as follows:
"1. We observed that the statistics, analysis and assessment in the report are based upon a collation of the reports released by non-governmental organizations and information from mass media and other individuals. As a result, the report provided unreliable judgments on the legal framework and law enforcement including Viet Nam without consulting law enforcement agencies. As a result, what is judged here are neither comprehensive nor objective.
"2. The report assessed the wildlife crime level of a country based upon the number of seizures that country made. Such scoring did not show or recognize Viet Nam’s law enforcement efforts.
"We assert that with the establishment of the Viet Nam Wildlife Enforcement Network (Viet Nam-WEN) and the cooperation with ASEAN-WEN member countries, Viet Nam has seized a large number of illegally transported wildlife specimens from foreign countries including over 18 tons of elephant ivory, over 50 tons of pangolins, hundreds of kilograms of rhino horns, couple dozens of tiger specimens and many others. These efforts have contributed significantly to tackle illegal international trade and the global conservation efforts. Viet Nam has made significant, positive progress over the last 10 years in combating wildlife crimes ranging thanks to greater inter-agency co-operation, improved international co-operation, a far stronger institutional capacity to address wildlife crimes both through a more informed and connected law enforcement community . For example, in the recent years the Customs anti-smuggling Unit has increased their efforts at detecting illegal wildlife entering Viet Nam. A special section of police has also etablished to increase the joint efforts, that is Environmental Police.
"The challenges Viet Nam facing are not unique to Viet Nam and are actually faced by most countries as the report clearly shows. Who is ‘the worst’ country in terms of compliance and enforcement is a subjective matter when based upon media and NGO reports (e.g. How many studies have been done on the tiger farms in Lao? Do we really know how many rhino horns are consumed in Viet Nam compared to the number moved on to other countries?)
"The Vietnamese legal framework for wildlife trade management and control has been improving and complies with international regulations, including CITES regulations. All behaviors relating to trade, transport, and illegal use of specimens under CITES Appendix I including rhinos, elephants and tigers are prohibited by law. In the Notification to the Parties No. 2012/036 dated 18 April 2012 of the CITES Secretariat on National laws for Implementation of the Convention, Viet Nam was placed in Category 1: legislation that is believed generally to meet the requirements for implementation of CITES.
"3. Regarding to the management of conservation breeding of tigers: Through the efforts of Viet Nam law enforcement agencies, in the early 2000s a number of facilities that illegally kept tigers were checked. Viet Nam CITES MA requested support from international organizations for building facilities to keep the seized tigers in one place, yet no support has been provided. Therefore, after intensive consultation with the CITES Secretariat, the Viet Nam Government decided to permit these facilities to keep tigers solely for conservation purposes, and prohibited all forms of commercial breeding. The permission for pilot tiger breeding in 2007 of Viet Nam did not go against CITES regulations and national law. In fact, tiger breeding facilities in Viet Nam have strictly followed regulations from our regular inspection and monitoring, and no tiger trading, consuming or violations have occurred in these facilities to date.
"Recently the government completed a genetic analysis of captive tigers to clarify origin and sub-species present as part of our ongoing assessment to their conservation potential. Besides that, Viet Nam actively participated in the Global Tiger initiative and Global Tiger Forum, recently completed a national census on wild and captive tigers as part of preparations towards a National Tiger Recovery Program.
"In recent years, law enforcement agencies have actively applied measures to combat illegal hunting and trade of tigers. Since 2000, dozens of illegal trade cases have been detected with over 50 tiger specimens seized all from foreign sources and there has been no record of hunting tigers from the wild in Viet Nam. Although recently there was a recommendation for pilot research using specimens of captive tigers carcasses for making traditional medicines for scientific research and communication campaign on the harm of using tiger bone balm, after careful consideration, the Vietnamese Government did not approve this recommendation.
"4. Regarding to rhinos: The Viet Nam CITES MA has worked closely with the South Africa CITES MA on controlling legal import of rhino specimens in compliance to CITES regulations. The cooperation agreement on biodiversity conservation is being developed and is anticipated to be submitted for the two Governments consideration for signing in late 2012. In June 2012, under the scope of Viet Nam-WEN cooperation, Viet Nam CITES MA conducted checks on a number of rhino horns legally imported into Viet Nam and found that the rhino horns were being kept as souvenirs, including both intact horn and cut pieces to make souvenirs or equipments like lamp base or cups.
"In the context of increasing illegal hunting of rhinos in African countries and to support the tackling of illegal trade in rhino specimens, Viet Nam authorities with strengthened inspection and control has detected dozens of cases of illegal transport and trade in rhino specimens into Viet Nam. Only in early 2012, we have detected 2 cases and seized 22 kilograms which contributed to preventing and restraining the illegal import of rhino horns. Currently, Viet Nam Government is considering a ban on import of all hunting trophies from this species into Viet Nam.
"5. Regarding to ivory, it is inaccurate to judge Vietnam as a destination country for ivory when it is widely recognized as a transit country and has been awarded by the CITES secretariat for its strong efforts to stop illegal trade flows of ivory moving through Viet Nam.
"In Viet Nam, the conservation of nature and endemic, endangered and precious wildlife always receives attention from the Government. Combating illegal trade in wild animals and plants is a focus and duty of many law enforcement agencies such as the Forest Protection Department, Customs, Police, Border Army, Market Control and many others. In fact, Viet Nam law enforcement agencies have shown their highest efforts in combating wildlife crimes in recent years.
"Viet Nam CITES MA is willing to cooperate and provide transparent information to domestic and international organizations, press agencies and stakeholders, yet determined to object to information and assessment that lack the objectiveness and comprehensiveness as in the mentioned report. Such assessments not only impact the prestige of Viet Nam but also reduce law enforcement efforts and cooperation among Viet Nam law enforcement agencies as well as international cooperation in the fight against illegal trade in wildlife, meanwhile, up to date Viet Nam CITES MA never received any support or cooperation from WWF regarding CITES enforcement in Viet Nam.
"We are aware that there are many challenges to combating wildlife crimes in Viet Nam in future and we are looking forward for positive cooperation from all related organizations and member countries."
Viet Nam CITES MA Response to WWF Report on Wildlife Crime Scorecard (PDF)
The WWF Report can be found here