CITES 2025: New Protected Species That Could Paralyze Your Business

Key data

If your company handles tropical timber, fish, cosmetics with natural ingredients, medicinal plants or exotic pets, this regulation could change the rules of the game overnight. The Regulation (EU) 2026/1383, published on 26 June 2026, amends Regulation (EC) 338/97 to reflect the decisions adopted at the 20th meeting of the Conference of the Parties to CITES. The result: new species enter protection lists, and what was legal trade yesterday may today require special permits or be directly prohibited.

What does this regulation establish?

Regulation (EC) 338/97 is the standard that translates the CITES Convention into EU law. It classifies species in annexes according to the level of protection:

The new Regulation 2026/1383 updates the annex to Regulation 338/97 to incorporate the decisions of the 20th Conference of the Parties held in 2025, as well as amendments agreed by the EU Scientific Review Group. This means that certain species that were previously in a lower protection annex move to a more restrictive one, or that previously unlisted species are now subject to control.

Economic and operational impact

The impact is not just documentary: it directly affects company operations and costs. The main effects are:

• New CITES authorizations: If a product or species you traded without a permit moves to a higher annex, you will need to obtain import and/or export permits before each transaction. These procedures have costs, take time and may be denied.
• Supply chain review: Foreign suppliers must also comply with CITES at source. If they cannot prove the legality of the species, the goods may be held at customs or seized.
• Existing stock: Products already in storage or in transit may be blocked if the species they come from changes category and the appropriate prior documentation is not available.
• Criminal and administrative penalties: Non-compliance with CITES regulations in Spain is classified as a crime against flora and fauna in the Criminal Code, in addition to administrative penalties provided for in Law 42/2007 on Natural Heritage and Biodiversity. Consequences may include substantial fines, seizure of goods and disqualification.

Who does it affect?

The regulation directly impacts companies and professionals in the following sectors:

• Timber industry: importers and exporters of tropical timber or protected forest species (mahogany, rosewood, ebony, etc.).
• Fishing and aquaculture sector: traders of regulated marine species (sharks, rays, eels, certain tuna and sturgeon species).
• Pharmaceutical industry: laboratories and distributors using extracts or derivatives of wild plants or animals in their formulations.
• Cosmetics industry: manufacturers and distributors of cosmetics with wild-origin ingredients (oils, extracts, keratins, etc.).
• Exotic pet trade: breeders, importers and specialized shops dealing in reptiles, birds, amphibians and ornamental fish.
• Antiques and art trade: galleries and auction houses handling objects made from ivory, tortoiseshell, coral or protected skins.
• General importers and exporters: any company whose supply chain includes raw materials or products of wild biological origin.

Practical example

Imagine a Spanish company that imports timber from a species that until now was listed in Annex B of Regulation 338/97 (export permit from country of origin sufficient). Following the entry into force of Regulation 2026/1383, that species moves to Annex A.

From that moment on, the company needs:

1. An import permit issued by the competent Spanish authority (MITECO) before each shipment.
2. A CITES export permit issued by the country of origin, proving that the timber comes from a legal and sustainable source.
3. To review whether the already stored stock has the prior documentation proving its legal acquisition before the category change.

If the company makes a shipment without the new permits, the goods may be seized at customs and the company may face a penalty proceeding that, in serious cases, may result in criminal liability for its administrators.

What should companies do now?

1. Audit your product catalog: Identify all animal species, plants or derived products that your company imports, exports or trades and cross-reference them with the updated lists in Regulation 2026/1383.
2. Review current CITES permits: Check whether current permits remain valid or whether new categories require additional or higher-level authorizations.
3. Contact suppliers: Verify that suppliers at source can issue the updated CITES documentation required for species affected by the changes.
4. Review stock in storage and in transit: Ensure that products already acquired have documentation proving their legal origin before the new requirements come into force.
5. Update internal compliance procedures: Incorporate the new listings into document verification protocols in purchasing, logistics and customs.
6. Consult the competent authority: In Spain, the Ministry for Ecological Transition and Demographic Challenge (MITECO) is the CITES administrative authority. For questions about species classification or permit processing, contact directly.
7. Seek specialized legal advice: Since non-compliance can have criminal consequences for administrators, it is advisable to have specialized legal advice on wildlife trade.

Official source

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Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601383