CITES Certificate & Dragon Fish(Asian Arowana)

CITES and the Dragon Fish

Whenever there is a genuine reason for concern regarding the continued survival of a species of plant or animal in the wild, it makes sense to take steps to protect it. In many instances, the geographical range of a species or subspecies can be so restricted, the numbers of adult reproducing specimens so little, and the generation times so long (as with the various subspecies of Galapagos Giant Tortoises) that only drastic measures and an energetic conservation program can offer any degree of security.

Clearly, in such cases – and even where the species in question is known to be threatened but is not on the brink of extinction- trade must be carefully controlled and monitored or, if necessary, banned. Where doubt exists, or where there is insufficient information available on the actual status of wild populations, precautionary steps are usually taken about the trade. These preventive measures can range from restrictions to total bans.

Several fish fall within one or other of these categories. The world famous living fossil, the Coelacanth (Latimeria chalumnae), for example, is considered to be most highly endangered. So, interestingly, is the Dragon Fish. Both are therefore afforded the highest degree of protection by being listed in CITES Appendix I.

Larval fish being raised in well-aerated aquarium tanks.
Larval fish being raised in well-aerated aquarium tanks.

CITES is an acronym for the Convention on International Trade in Endangered Species of Wild Fauna and Flora. Rather than an actual organization or official body, CITES is an agreement between countries, called signatories (around 130 at present), the aim of which is to regulate, not ban, international trade in wildlife and wildlife products. Therefore, for example, not only are the threatened species of marine turtles listed as a result of criteria defined by the Convention but so are products derived from them, such as tortoiseshell ornaments and accessories.

The idea of the Convention initially arose out of a series of meetings held during the 1960s and early 1970s between representatives from countries who were concerned about threats to wild stocks resulting from international trade in specimens and their products. These meetings culminated in a gathering in February 1973 at which 81 countries finally launched the agreement and thus set up the Convention with an active official starting date of 1 July 1975.

CITES operates mainly through three Appendices, each reflecting a different level of perceived threat and defining precise controls concerning trade.

Appendix I

This is the highest risk category and, consequently, the one with the strictest level of control about the trade. Animals and plants to which Appendix I applies ” …are endangered species and commercial import, export and sale are normally prohibited…. “.

The “normally prohibited ” clause allows for some flexibility so that limited trade can be permitted if, for example, the specimens concerned:

• are bred in captivity or (in plants) are artificially propagated;
• are required for research purposes;
• will be used for non-commercial purposes;
• date from before the Convention came into force

At the moment, the Dragon Fish, the Coelacanth and six other species of
fish are listed in Appendix I.

Appendix II

Under the less strict Appendix II controls are listed animals and plants which “…are vulnerable species but (which) may be traded commercially provided that import or export permits have been obtained….”

This level of control is designed to ensure that populations of such species do not decline to such an extent that they become threatened with extinction. In other words, these measures aim to prevent an Appendix II species from having to be transferred to Appendix I.

Also included in Appendix II are any species which closely resemble other species listed under Appendix I. No fish currently fall within this group of lookalikes, but five species qualify for listing under Appendix II. These include the Australian Lungfish (Neoceratodus forsteri), the Arapaima or Pirarucu (Arapaima Gigas) – a close relative of the Dragon Fish- and the American Paddlefish (Polyodon spathula). For a while, the Indonesian populations of the Dragon Fish were listed under Appendix II, but these have now been transferred back to Appendix I.

Shoal of juveniles about 12cm (c. 5in) total length.
Shoal of juveniles about 12cm (c. 5in) total length.

Appendix III

Species listed under Appendix III are deemed not to be under significant threat, and regulations controlling their trade are domestically devised and administered, although individual countries can call on international co¬ operation if they feel that this is required. Generally speaking, though, controls are, quite rightly, more relaxed for Appendix III species than for those listed under Appendices I and II.

Need for Evaluation

For a species to qualify for listing under Appendix I, it needs to meet
Certain criteria. For example, the wild population must be small and

• be in decline regarding numbers or habitat; or
• consist of small sub-populations; or
• contain a concentration of individuals in one population; or
• exhibit significant short-term fluctuations in numbers; or
• be prone to high vulnerability due to biology or behavior.

Alternatively, large populations can qualify for listing if they satisfy certain criteria with regard either to having a restricted natural distribution or to exhibiting a distinct decline in total numbers, due to a range of factors which can include deterioration of habitat and a decrease in reproductive potential.

In addition to having to meet one or other of the main criteria outlined above, there are also certain trade factors that have to be completed before listing can proceed. Clearly, therefore, the listing is a matter that calls for a great deal of data and careful consideration and is not something that is ever taken lightly.

In the case of the Dragon Fish, growing concern for its continued survival in the wild led to its listing under Appendix I on 1 July 1975, with exports from Indonesia becoming illegal in 1978 when the country acceded to CITES and those from Singapore in 1980. Singapore itself joined CITES on 30 November 1986. On 18 January 1990, the Indonesian population of Dragon Fish was downlisted to Appendix II, with all other residents remaining on Appendix I, but on 16 February 1995, it was returned once more to Appendix I.Therefore, all populations of Dragon Fish are currently listed in Appendix I.

International Union for Conservation of Nature and Natural Resources (IUCN)

Interestingly, if we look at how another major conservation-based (but not trade-related) organization rates the status of Scleropages formosus in the wild, we get a slightly different picture. In its 1994 list of threatened animal species, the IUCN (The International Union for Conservation of Nature and Natural Resources) considered the status of Dragon Fish as ” Insufficiently Known .”

According to the official definition of this category, listed species are suspected but not known to belong to any of the above categories, because of lack of information. The above categories include Extinct, Endangered, Vulnerable, Rare and Indeterminate.

This classification probably represents a more accurate picture concerning our current state of knowledge regarding wild population levels of the Dragon Fish and the firm ‘Endangered’ label imposed upon it by being listed in CITES Appendix I. However, since, in cases of uncertainty, one must always err on the side of caution, it would not help matters if an argument were to be advanced to downlist the Dragon Fish to Appendices II or III without detailed and unequivocal evidence derived from first-hand studies carried out in the wild. The fact is that we lack reliable data based on population studies conducted throughout the species’ natural range. Indeed, much of the evidence we do have is anecdotal or secondhand or, as the following example from Vierke (1992) shows, intriguing. It would therefore not be sensible or helpful to base major decisions on such shaky foundations.

Sub-adult O. bicirrhosum.
Sub-adult O. bicirrhosum.

In an interesting article written for Tropical Fish Hobbyist, Vierke reports on a visit to Malaysia. He tells of a large nature park, Taman Negara, in some of whose waters Dragon Fish are known to occur. Visitors to the park are urged to Take Nothing but Pictures’, a commendable sentiment which is perfectly in tune with everyone’s concept of conservation, particularly within the confines of an area dedicated to the welfare of wildlife.

However, reportedly, Vierke came across a ‘prospectus’, written in German but published by the Malaysian Ministry of Commerce and Industry, providing information on angling within the national park. This brochure contains a section on where Dragon Fish may be found in the park’s waters saying that, for example, they prefer small coves along the river bank. It also includes advice on what types of the hook are best for catching Dragon Fish, provides a fishing map and even describes the sort of fight this fish puts up when hooked.

It is always easy to jump to conclusions, especially when one is dealing with such an emotive issue as the Dragon Fish. Such a tendency should, however, be resisted since it often leads to misleading, inaccurate and potentially damaging statements that may not take into account specific, and probably unique, local factors which may have a direct bearing on the situation. Neither should one allow personal feelings regarding the actual activity of sports angling per se to cloud the issue.

The crucial thing here is what this sort of publication tells us about the Dragon Fish population in the park. It would seem unlikely, irrespective of whether or not the area concerned is part of a national park, that such a guide would be made available if the numbers of Dragon Fish were down, or close, to endangered levels. Indeed, the very existence of published advice on how to angle for Dragon Fish may indicate quite the opposite; that the population is sufficiently large and widespread to make angling feasible. If this were to be the case, and if it were an accurate reflection of population levels elsewhere in the species range, then the Dragon Fish may be more secure in the wild than we fear.

In reality, of course, this prospectus does not provide proof of abundance or scarcity, and therefore could not be used to advance any argument regarding the official categorisation of the Dragon Fish.

Disappointingly, there is no indication at present that any census studies are being contemplated. The unfortunate consequence of such a lack of research is that, until and unless we know for certain how the Dragon Fish is faring in its native waters, not only might we be classifying it incorrectly but, more worryingly, the species could conceivably (though this is perhaps unlikely) be undergoing a dangerous natural decline without this even being detected.

So far, an earthen pond has proved the best habitat for captive breeding of Dragon Fish.
So far, an earthen pond has proved the best habitat for captive of Dragon Fish.

Two other relatives of the Dragon Fish also appear in the 1994 IUCN list. The Spotted Saratoga (Scleropages leichardti) is classified as Rare, which identifies it as being ‘at risk’ of becoming either Vulnerable or Endangered, while the Pirarucu (Arapaima Gigas) is rated, like the Dragon Fish, as Insufficiently Known.

Stocking larvae in aquarium tanks in hatchery
Stocking larvae in aquarium tanks in hatchery

In late 1994, the IUCN revised its categories, resulting in the following classifications listed in order of threat: Extinct, Extinct in the Wild, Critically Endangered, Endangered, Vulnerable, Lower Risk (subdivided into Conservation Dependent, Near Threatened, and Least Concern), Data Deficient and Not Evaluated.

At present, the extensive existing species list has not been reallocated on the new categories so that no definite statement can be made with regard either to the Dragon Fish, the Spotted Saratoga or the Pirarucu. It is unlikely, however, that on current levels of knowledge, any of the three will undergo a dramatic change in status, perhaps ultimately ending up either under one of the Lower Risk subcategories or the Data Deficient category.

Packing of fry
Packing of fry


Whatever the outcome, it seems improbable, unless there is an unforeseen development of some kind, that sufficiently startling new evidence will come to light in the short term regarding wild populations to warrant downlisting the Dragon Fish from CITES Appendix I to Appendix II.

Therefore, for the foreseeable future, the Dragon Fish will continue to be regarded as Endangered according to the CITES criteria and remain subjected to all the trade restrictions implied by being listed in Appendix I. This does not, however, mean that no international trade is allowed but rather, as mentioned earlier, that this business needs to be carefully regulated and that permission will only be granted if CITES strict criteria can be met.

Among these criteria, as has already been outlined, there is one that can result in permission to trade in listed species if the specimens in question have been bred in captivity. Clearly, of course, it is not sufficient merely to claim that this has been achieved. Convincing evidence must be provided, and this is easier said than done, but it is not impossible. Chapter 8 describes how one enterprising Singaporean Dragon Fish breeder joined forces with the governments Primary Production Department in a sophisticated captive breeding project designed to provide the CITES authorities with precisely this kind of evidence.


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