CITES 2026: What importers and traders of protected species must review

Key data

European operators trading in protected wildlife species have an immediate obligation: to review the amended annexes of Regulation (EC) No 338/97, as the corrigendum published on 16 October 2026 takes effect from 26 June 2026. This means that any operation carried out from that date must comply with the corrected lists and conditions, not the previous versions.

Regulation (EU) 2026/1383 adapted European legislation to the decisions adopted at the 20th Conference of the Parties to CITES and the recommendations of the Scientific Review Group. The corrigendum now published corrects errors in that text, which may affect the lists of species included in the annexes, their trade conditions or the applicable exceptions.

What does this regulation establish?

The European regulatory framework for wildlife trade is structured around Regulation (EC) No 338/97, which transposes the CITES Convention into EU law. This regulation classifies species into four annexes (A, B, C and D) with different levels of protection and documentation requirements for their trade.

Regulation (EU) 2026/1383 updated those annexes to reflect the amendments agreed at the 20th meeting of the Conference of the Parties to CITES. The corrigendum now published corrects material errors in that text. The corrections may affect:

• The lists of species included in annexes A, B, C or D.
• The trade conditions applicable to certain species.
• The exceptions provided for certain uses or types of operators.

The corrigendum does not introduce new substantive obligations, but does amend the current text with retroactive effect from 26 June 2026. Any operation documented from that date must be verified against the corrected text.

Economic and operational impact

The main impact is not a new fee or amount: it is the risk of operating with documentation or permits based on a version of the regulation that has been corrected. The practical consequences are:

• Import or export permits processed between 26 June and 16 October 2026 that may not comply with the corrected text.
• Stocks in commercialisation of species whose annex classification or trade conditions have been amended.
• Ongoing contracts with international suppliers or customers that reference conditions based on the text prior to the correction.
• Administrative and criminal penalties for non-compliance with CITES regulations, which in Spain can be very high under wildlife protection legislation.

The sectors with the greatest operational exposure are those managing high volumes of species or working with species at the boundaries of classification between annexes, where a change in category radically alters documentary requirements.

Who does it affect?

• Importers and exporters of protected wildlife and flora in the EU.
• Traders of live species or products derived from wildlife.
• Zoos and aquariums that acquire or transfer protected animals.
• Nurseries and botanical sector companies working with plants included in the CITES annexes.
• Exotic pet shops and breeders that commercialise protected species.
• Companies producing derived products from wildlife: skins, timber, medicines of animal or plant wildlife origin, etc.
• Customs advisors and foreign trade agents managing operations with these species.

Practical example

A Spanish nursery that regularly imports wild-origin orchids from a third country processed its import permits in July 2026, based on Regulation (EU) 2026/1383 published in June. With the corrigendum published in October, some of the species in its catalogue may have seen their trade conditions or annex classification amended.

If the corrigendum corrects, for example, that a species the nursery considered included in Annex B (trade permitted with documentation) is correctly classified in Annex A (maximum restrictions), all commercialisation operations carried out from 26 June must be reviewed. The nursery must verify each species in its catalogue against the corrected text and, if discrepancies are detected, contact the Spanish CITES authority (Directorate General for Biodiversity) to regularise its situation before an inspection detects it.

What should companies do now?

1. Download and review the corrected text of Regulation (EU) 2026/1383 published in the Official Journal of the EU (OJ:L_202690884) to identify exactly which species, conditions or exceptions have been amended.
2. Audit the catalogue of species the company operates with from 26 June 2026, comparing their current classification with the corrected text.
3. Review import and export permits processed between 26 June and 16 October 2026 to detect possible discrepancies with the corrected text.
4. Contact the national CITES authority (in Spain, the Directorate General for Biodiversity of the Ministry for Ecological Transition) if operations are detected that may not comply with the corrected text.
5. Update internal compliance procedures and communicate the changes to the purchasing, logistics and foreign trade teams.
6. Consult with a CITES specialist advisor if the company operates with species at the boundaries of classification between annexes or if the volume of operations is high, given the risk of administrative and criminal penalties.

Official source

Consult full regulation at official source

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_202690884