Analyses of proposals to amend

Ref. CoP13 Prop. 37
Inclusion of Hoodia spp. in Appendix II, designating all parts and derivatives except
those bearing the label ‘Produced from Hoodia spp. material obtained through
controlled harvesting and production in collaboration with the CITES Management
Authorities of Botswana, Namibia and South Africa under agreement
no. BW/NA/ZA xxxx’. Proponents: Botswana, Namibia and South Africa.

Summary: Hoodia spp. are slow-growing, perennial, spiny succulent plants. They occur in a wide range of arid
habitats in southern Africa, typically on arid gravel or shale plains. The genus is generally considered to consist of 14
species and four infraspecific taxa. A broader taxonomic interpretation of the genus recognises 26 species. Detailed
information on the distribution and population status of individual taxa is limited. The proposal states that ten of the 16
taxa assessed have been classified as threatened according to the IUCN Red List Categories and Criteria, with four
taxa classified as Vulnerable in 2002. Strong commercial interest in the genus results from the isolation and patenting
of an active ingredient (P57) which acts as an appetite suppressant. The active ingredient has been isolated from H.
gordonii, which is abundant and widespread in Namibia and South Africa. It is thought likely that the active ingredient
may also be present in a number of other species, some of which have more limited and patchy distributions. These
may be vulnerable to over-collection. Hoodia spp. are legally protected in most countries of occurrence, and the trade
is regulated by national legislation in Botswana, Namibia and South Africa, but there is evidence of illegal trade, which
seems to be a growing problem.
The proponents seek inclusion of the genus in Appendix II to establish a standardized international trading framework
and monitoring regime. The proposed annotation if adopted would imply that only the certified sustainable trade from
three range States would be exempt from the provisions of the Convention. Trade from Zimbabwe or any non-certified
trade from Botswana, Namibia and South Africa would be subject to the provisions of the Convention as would imports
into Parties from Angola (a non-Party). Trade in specimens of Hoodia grown in countries outside the region, and their
parts and derivatives, would also be subject to CITES controls.
Details of how the proposed controlled harvesting and production operations to be developed in collaboration with the
CITES Management Authorities of Botswana, Namibia and South Africa might operate are not given in the proposal.
Parties are therefore asked to consider a new form of listing on the basis of limited information about how this would
work.
Analysis: Hoodia spp., are at risk in the wild because of their perceived value on the international market as a source
of appetite suppressants. The species from which the active pharmaceutical ingredient has been identified, H. gordonii
remains widespread and abundant but there is evidence of damage to wild populations from collectors. Although not
currently considered to be threatened, this species may meet Resolution Conf. 9.24 Annex 2a, criterion B i) in that
harvesting of specimens from the wild for international trade may have a detrimental impact on the species by
exceeding, over an extended period, the level that can be continued in perpetuity. Other species of Hoodia have much
more restricted ranges and some are considered threatened in the wild. Several of these may be vulnerable to over-
harvesting. In view of the similarity of all species, the remaining species are likely to meet the criteria in Annex 2b of
Resolution Conf. 9.24 for inclusion in Appendix II.
Three of the range States for this species wish to use CITES Appendix II to help manage wild populations harvested
for international trade in a novel way. From the information provided in the listing proposal it is difficult to understand
how the proposed annotation would work in practice. No indication is given in the proposal regarding how the
proponents intend the label to be applied or which agencies would be responsible for granting authorisation to use it.
Furthermore, the label implies that there will be a mutually binding agreement on “controlled harvesting and
production” for Hoodia among the three proponent countries. Information on how this would operate within the context
of CITES would be beneficial for the Parties in considering this proposal.
Information provided and statements made by
Information provided and statements made by
proponents in the Supporting Statement
proponents in the Supporting Statement
Taxonomy
The family for this genus is given as Apocynaceae. Hoodia has previously been included in the family Asclepiadaceae. The two sub-families of the The proposal does not include a full list of taxa Asclepiadaceae were transferred to the Apocynaceae in considered to be included in the genus. 2000 (Endress and Bryuns, 2000), because there are a few bridging genera which possess features from each of these families (Plowes, 2004). There is ongoing taxonomic debate about this decision. Müller and Albers, 2002, whilst noting the formal transfer, continue to use the family name Asclepiadaceae. They consider that the genus Hoodia consists of 14 species and four infraspecific taxa. Information provided and statements made by
Information provided and statements made by
proponents in the Supporting Statement
proponents in the Supporting Statement
According to Plowes (2004), there may be 26 species in the genus Hoodia, including the so-called “spiny Trichocaulons”. Hybrids are known with Orbea and Tromotriche (Müller & Albers, 2002). Angola, Botswana, Namibia and South Africa. Zimbabwe is an additional range State for the genus. H. gordonii occurs in Botswana, Namibia and South Africa. It does not occur in Angola (Golding, 2004). There is uncertainty about the presence of H. gordonii in Botswana. According to Hargreaves (2004) there is no evidence of the species occurring within the country and the record is based on a mislabelled specimen. IUCN Global Category
Ten of the 16 taxa assessed have been classified as The 1997 status information given to in the proposal threatened in the latest Red List assessments. The appears to be based on the 1997 IUCN Red List of Threatened Plants (Walter and Gillett, 1998). The 2002 status information appears to be based on the information given in the Southern African Plant Red Data H. dregei, H. juttae, H. officinalis subsp. Delaetiana, H. pilifera subsp. annulata, H. pilifera subsp. Pillansii, H. pilifera subsp. pilifera, H. ruschii and H. triebneri. Biological and trade criteria for inclusion in Appendix II
B) Harvesting for international trade has, or may have, detrimental impact on population
(i) exceeds sustainable yield; (ii) reduces population to potentially threatened level
Little is known about population trends, although Although Hoodia gordonii is widespread, plants are declines have taken place at various sites. There are usually in small scattered population pockets, often with reports that Hoodia spp. have disappeared from parts of only a few dozen plants in each, or less. They can be their range due to mining, infrastructure development easily seen from a distance because of their size, being higher than the surrounding low karroid shrubs and therefore all individuals are likely to be taken by In addition all species have been subject to collecting by harvesters, leaving only hidden seedlings to regenerate succulent collectors. Harvesting for medicinal purposes has traditionally occurred. Since the isolation of the active ingredient in H. gordonii and the extensive press Recent observations in the Central Namib, Namibia coverage projecting the financial value of this, indicate the removal of larger individuals of H. gordonii commercial harvesting has become a large potential by collectors – usually when the plants are in flower and threat. Although H. gordoniii is abundant and widespread, collectors cannot always tell the species apart and wild collection is thought likely to impact a There is no evidence of harvesting of Hoodia spp., in number of Hoodia spp. Harvesting requires cutting off the above ground parts of the plants, and it is relatively Ethnobotanical records suggest that several species in addition to H. gordonii are of interest for appetite suppressing properties namely: Hoodia currorii, Hoodia To date, levels of trade from Botswana, Namibia and flava, Hoodia lugardii, Hoodia (Trichocaulon) piliferum, South Africa have been very limited. No information is and Hoodia (Trichocaulon) officinale (Wynberg, 2004a). presented from Angola. There is evidence of illegal trade from the three proponent countries. The active ingredient known as P57 has been patented, the patent covering six species: H. currorii, H. gordonii, The potential impact of illegal trade is thought to be very H. lugardii, H. (Trichocaulon) piliferum, and high after the patenting of P57 in South Africa. H. (Trichocaulon) officinale (Wynberg, 2004a). However, Several species, such as H. gordoniii, occur in very large the natural product cannot be patented entirely. There is populations with extensive distributions of over 10 000 therefore no copyright infringement by manufacturing km2. Others occur in small, isolated patches with a total and selling any natural products derived from H. gordonii distribution of less than 1000 km2. No subpopulation of or other species that should prove to contain P57, even H. pilifera subsp. pillansii is thought to exceed 250 though such products would also naturally contain P57. Medications that are reputed to contain Hoodia material are currently sold widely, particularly in the USA and the Information provided and statements made by
Information provided and statements made by
proponents in the Supporting Statement
proponents in the Supporting Statement
UK. Prices vary between USD 39 and USD 70 (90 capsules, 400 mg per capsule). Other information
The extent of illegal trade is unknown, but illegal exports Very few localities are known where diamond or other have been reported in all three countries. It is alleged mineral deposits coincide with Hoodia populations, a that foreign pharmaceutical companies may have been small part of the range of H. currorrii at Rossing uranium obtaining significant amounts of Hoodia through illegal mine near Swakopmund, Namibia being a notable exception. Overgrazing does not directly impact Hoodia species because most, if not all, species are not normally Populations have also been declining due to habitat loss grazed by livestock, but loss of grazeable shrubs could or degradation caused by mining, development of eliminate the ‘nurse’ plants that are necessary for infrastructure, collecting and overgrazing. Several successful germination and growth of Hoodia spp. The localities of H. currorrii subsp. lugardi have been lost to arid habitats required by Hoodia species generally the combined effects of diamond mining and attack by a prevent their conversion to arable lands (Plowes, 2004). Poor regeneration in natural populations has been reported. During the years 1996 to 2004, small populations of H. gordonii in the Spitskoppe, Brandberg and Namib Naukluft Park (Central Namib, Namibia) have been visited on various occasions. Juveniles were rarely found and there was evidence of the soft juvenile plants being browsed by game (Strohbach, 2004). Various species have been impacted by local use for food and medicines. Hoodia rustica (sometimes considered a synonym of H.officinalis) is known only from a few localities on rocky hills in South Africa. The last plant at the Vosberg site was found and eaten in 1985. H. flava and H. pilifera are also utilised locally (Plowes, 2004). As early as 1937 it was reported from South Africa that H. (Trichocaulon) pillansi had been “almost exterminated through the zeal of collectors and because of its edible and supposedly medicinal properties”. Formerly, the plant is said to have been fairly frequent, sufficiently so to give its name to one of the hills in the Witteberge, Ngaap Kop (Trichocaulon Hill) (Wynberg, 2004b). Collecting appears to be the main potential threat. For example, the Northern Cape’s Department of Agriculture, Land Reform, Environment and Conservation (DALEC) has reliably learned of Hoodia material being supplied to the international pharmaceutical market without permits. The illegal collection of Hoodia has escalated to such an extent that its future existence may well be ‘under greater threat than ever before (Anon., 2004). Conservation, management and legislation
South Africa: Hoodia spp. are protected in the Northern
South Africa: The National Biodiversity Act (10 of 2004)
Cape (Environmental Conservation Ordinance No. 19 of has recently been promulgated. Enforcement, however, 1974). Permits are required for collecting, cultivation, will only be possible once regulations are in place. This transport or export. Similar regulations are applied in the legislation will provide national (including access and benefit sharing agreements) protection and international (including CITES) protection and other requirements for Western Cape Nature Conservation has permitted use of plant species such as Hoodia spp. (TRAFFIC developing companies to use a limited amount of wild harvested Hoodia. Permits have been issued to the Council for Scientific and Zimbabwe: H. lugardii is a specially protected plant in
Industrial Research, which has set up a benefit sharing terms of the Zimbabwean Parks and Wildlife Act of 1975. agreement with the local San communities. Botswana: Harvesting is controlled by the Agricultural
Resources Conservation Act [CAP. 35:06] in which Hoodia
is listed as a veld product. Regulations for harvesting of veld Information provided and statements made by
Information provided and statements made by
proponents in the Supporting Statement
proponents in the Supporting Statement
products were published on 26 March 2004. Harvest permits are required and harvest areas are inspected by officers from the Agricultural Resources Board. Hoodia currorii has been presented to the Board to become legally protected. Namibia: All Hoodia species are legally protected requiring
prior authorization for harvesting and trade. Harvesting is not
currently authorized. The country intends to establish a
controlled harvesting system. The status of Hoodia spp. has
been assessed since 2001 and monitoring as part of a long-
term plant conservation programme has been expanded, but
funding is limited.
Angola: No information.
In situ protection: H. gordonii occurs in the central Kalahari
and Makgadikgadi National Parks (Botswana), the Ai-
Ais/Richtersveld Transfrontier Park (South Africa), the
Skeleton Coast Park and a new national park in southern
Namibia (the former Sperrgebiet) as well as in several
Conservancies.
Similar species
Hoodia species resemble one another and have been There are superficially similar species within the family confused with certain cacti species, such as Trichocerus Apocynaceae (Asclepiadaceae) that occur in the same region as Hoodia spp. Large, flat dish-like flowers are generally a distinguishing feature of Hoodia spp. Artificial Propagation
Hoodia spp., are relatively difficult to cultivate, but are Hoodia spp. are grown by succulent plant enthusiasts nevertheless used for horticultural purposes. around the world and are available from specialist nurseries. H. gordonii is considered one of the least Cultivation trials have been set up in South Africa and difficult species to grow (Hewitt, 1993). Namibia, but the plants are not suitable for harvest yet. Hoodia is reported to have been cultivated in Chile and Other comments
Very little work has been conducted on identification of harvest sites and on assessment of damage after harvesting for trade. It is proposed that permission to export will only be given after a full Non-Detriment Finding (NDF) has been concluded. In return for following certain harvest criteria to ensure sustainability, the traders will be allowed to trade without CITES permits. However, legal trade volumes will only be known by the producer country. Ongoing monitoring and periodic re-examination of the NDF seem necessary to control the trade. It will be difficult to track the various purveyors of the plant material, since their identity and their actual involvement are not always clear. The proposed annotation may also create problems in enforcement in importing countries (TRAFFIC East/Southern Africa, 2004). Wynberg (2004a) notes that a standardised international trading framework and monitoring regime for Hoodia needs to be put in place, and needs to ensure that range States capture the economic benefits that accrue from its commercialisation. However, she believes that the implications of the proposal need to be considered more thoroughly before it is approved.
Reviewers: P. Downs, J. Golding, B. Hargreaves, B. Huntley, D. Plowes, T. Ron, M. Strohbach, TRAFFIC East/Southern


References:
Bruyns, P. 1993. A revision of Hoodia and Lavrania (Asclepiadaceae Stapeliae). Botaniche Jahrbücher. 115: 145-270.
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Source: http://data.iucn.org/Themes/ssc/our_work/wildlife_trade/citescop13/pdf/CoP13_Prop_37_Hoodia_spp.pdf