Endangered Animals Act – Speech by Leon Perera

Mr Speaker sir, the illegal trade in wildlife and endangered species is a major driver of biodiversity loss and species extinction throughout the world. The depletion of biodiversity at commercial scales is contributing to the deterioration of biodiversity and ecosystem functions and services, posing a long-term threat to the well-being of humanity, as noted in the 2019 report of the Inter-governmental Science-Policy Platform on Biodiversity and Ecosystem Services.

There is broad international consensus about the widespread harm caused by the illegal wildlife trade. Governments must do what they can to deter such crimes. Developed nations like Singapore have an even greater responsibility in this regard. We owe it to the world to crack down hard on these enterprises. Rightfully, Singapore has been a party to the The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) since 1986.

As an important trade hub and global middleman, Singapore, along with other cities, is one node in a vast network of illegal wildlife trade. This region is also an entryway to China, reportedly the world’s largest consumer market for illegal wildlife products. Our highly developed trade infrastructure and global connectivity is prone to exploitation to facilitate illicit activities.

The Endangered Species (Import and Export) Amendment Bill (ESA) was read for the first time on 9 May 2022 and initiated to amend the 2006 Act. I support this Bill as a step in the right direction, but in my speech I shall raise a number of suggestions for how the regulatory regime applicable to the wildlife trade can be further strengthened with a view to stamping out the trade in endangered species.

A step in the right direction

Mr Speaker, I am pleased to note that the Bill before the House today has addressed several issues and loopholes inherent to the 2006 Act. The amendments acknowledge updates to CITES protocols and definitions, and concurrently update the law. Definitions pertaining to import/export, the items being traded, as well as the documentation required to validate this trade, have been clarified.

In addition, the Bill grants improved powers of enforcement to the National Parks Board or NParks, the agency responsible for implementing CITES regulations. It closes loopholes by explicitly not recognizing retrospective CITES trade permits (granted, with certain exceptions).

These are positive changes. Singapore’s import/export laws must adapt to ensure that the wildlife trade is regulated sustainably, and that the illegal wildlife trade, which is driven by organised crime, be dealt a body blow.

Gaps in the Bill: Animal derivate products and Hybrid animals

Although CITES offers an accredited framework to build our legislation on, it is not all-encapsulating. Mr Speaker sir, I hope to see the Endangered Species Act move beyond CITES. I offer the following suggestions for future changes that could be made via legislation or perhaps subsidiary legislation.

In line with CITES regulations, exceptions to the import/export rules have been made for naturally excreted urine, faeces and ambergris. Nevertheless, in a regional context, they represent exploitable loopholes that can allow unsustainable practices to persist.

For example, Kopi Luwak, or civet coffee is typically sold as coffee beans excreted by civets from many Southeast Asian nations. In truth, this industry sometimes relies on inhumane wild-capture and force feeding of civets, though I am not claiming that every Kopi Luwak producer engages in inhumane practices. It is often difficult to identify if the resultant product is “naturally excreted” or not. As a result of these exceptions, the amended law does not afford these animals the protection they need.

Before I move on from this example, let me note that I am using the example of Kopi Luwak as an illustration. The Asian palm civet is not currently an endangered species and the issue I alluded to is related to cruelty towards animals. Nevertheless, the example illustrates a problem that may arise with endangered animal-derived products.

Next let me talk about hybrids. I will take the example of leopard cats. Sir, leopard cats are the last remaining wild cats in Singapore, and there are fewer than 50 individuals left. They are classified under CITES Appendix II, which requires their trade to be controlled. Their hybrids (with domestic cats) are known as Bengal cats.

The Bill as it stands would allow a 5th generation Bengal cat to be freely traded in Singapore, without requiring any documentation of when, where or how the original leopard cat was purveyed. Such exceptions can allow local demand to drive poaching and captive breeding in other parts of the world.

We should consider tweaks to the regulations that would require the spirit of CITES to be applied to hybrids in a reasonable manner, so as to deter such activities.

Penalties and Law Enforcement

Next sir, in this Bill, penalties for infringements to the Act have been increased. This will, laudably, increase the deterrence against infringements of the law.

Nevertheless, there is room for stiffer penalties. Singapore’s maximum jail term for wildlife trafficking is still the lowest penalty in ASEAN. In order to position Singapore as a regional leader in the fight against illegal wildlife trade, a harsher jail term of 7 years can be considered.

Next, one significant gap in the ESA Bill as it stands would appear to be the online wildlife trade. An overwhelming share of the illegal wildlife trade is now carried out online. A 2020 study found that more than a third of all reptile species were traded online. Almost 90% of those species were caught from the wild, with many being rare and endangered. There are recent reports of exotic wildlife being sold as pets on social media in Singapore.

These examples demonstrate the extent to which the internet is used as a tool in conducting such deplorable trades.

I propose that advertising endangered wildlife or wildlife products on these platforms should also be treated as an offence if those transactions would be illegal under the law. We should require online platforms to self-police the transactions they facilitate.


The CITES regulations operate under a blacklisting model. The trade of species which are listed in the various appendices are regulated. At present, almost 6,000 animal and 33,000 plant species are protected against over-exploitation. Nevertheless, this still represents a small fraction of animals and plants on earth. Larger, more charismatic animals are disproportionately represented in these appendices. Species that are identified by experts and NGOs as being threatened by trade take many years to make it into CITES listings. Without such a listing, unregulated trade in wildlife is the default.

Sir, I suggest that Singapore show leadership regionally and globally and move beyond CITES by considering a new approach to regulating the trade in wildlife – reverse listing.

The current model of direct listing relies on customs agents to verify shipments. It places the burden of proof of trade sustainability onto the government, and on NGO watchdogs, while businesses profit from the trade. Newly described species, which are usually unlisted, are left completely vulnerable to trade.

Why not, then, use a reverse-listing model which would make “no-trade” the default? Such a system would require the traders themselves to produce proof of sustainable trade.  

Such a system could also incorporate a default ban on newly discovered species for a period of time, so as to allow time for that species to be listed, if the facts so warrant.


In conclusion sir, given the scale of biodiversity loss, unrestricted trade in wildlife is simply no longer acceptable. What some scientists have dubbed the Anthropocene era – the era in earth’s history when human actions drive change in global climate and biological conditions – must not become the era of another mass extinction.

Rare and endangered specifies have a role to play in keeping eco-systems in balance. Their bodies may contain keys to bio-pharmaceutical and other scientific breakthroughs. And they form part of the earth’s magnificent diversity, of which we are stewards and which should not be denied to future generations of human beings.

And in Asia, the problem is acute, as Asia is home to many endangered species while also being a major global centre of demand for endangered wildlife and wildlife products.  While public awareness of the plight of iconic species such as the African Elephant and the Black Rhino, for example, is relatively high, many other less high-profile species are also prey to illegal wildlife markets. In Southeast Asia, the Asian Elephant population has declined by 50% over the past century. The four species of Asian pangolins are now among most poached animals in the world, by some reports.

This Bill is a step in the right direction. But going forward, Singapore can go further and can do more to demonstrate forward thinking and leadership on this issue by going beyond CITES.