Humphead Wrasse trade into and through Hong Kong

The Humphead Wrasse is a large, naturally rare, slow growing and high value reef fish that is usually traded live and consumed as a delicacy particularly in Hong Kong and mainland China, along with various other reef fish such as groupers and other wrasses. 

The study, Humphead (Napoleon) Wrasse Cheilinus undulatus trade into and through Hong Kong (PDF, 1.3 MB), was published today by TRAFFIC and the International Union for Conservation of Nature (IUCN) Grouper and Wrasse Specialist Group (GWSG) and funded by the Secretariat of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and The University of Hong Kong. 

In 2005, the Humphead Wrasse was listed in Appendix II of CITES, in order to regulate its international trade to sustainable levels through the issuing of export permits by source countries, while Hong Kong also requires import permits for CITES II listed species.

According to UNEP-WCMC data, the official global database for trade in CITES-listed species, Indonesia and Malaysia are the main exporters of Humphead Wrasse, although only Indonesia currently issues CITES export permits; Malaysia set its export quotas for live Humphead Wrasse to zero in 2010 and for all Humphead Wrasse to zero in 2015.  

Traders also told the report’s authors that significant numbers of Humphead Wrasse are sourced from the Philippines, as also claimed by a number of e-commerce websites. However, according to the CITES trade data only three live fish have been exported from the Philippines. 

An official CITES document tabled in 2010 identified Hong Kong and mainland China as the principal destinations for Humphead Wrasse, and although no trade between the two is reported to CITES, it is recorded by Hong Kong's AFCD.

Despite this lack of reported trade involving mainland China, surveys by the report’s authors of physical seafood markets in Shenzhen in May and June 2015 and e-commerce websites found at least 15 companies claiming to sell live, chilled or frozen Humphead Wrasse, 12 of them located in mainland China. 

In Hong Kong, monthly surveys of the three biggest fish markets carried out by a team from Hong Kong University during the study recorded a total of 1,197 live Humphead Wrasse between November 2014 and December 2015. 

There is usually a short turnaround time (around two weeks) between import and sale of live Humphead Wrasse, making it highly unlikely that those observed on sale had been imported in earlier years. 

Figures obtained from Hong Kong’s Agriculture, Fisheries and Conservation Department, Hong Kong’s CITES Management Authority, showed the import of just 150 Humphead Wrasse during the whole of 2014. However, more than that total, 157, were observed by the University team during November and December 2014 alone. 

The market surveys clearly indicate illegal and unreported trade in Humphead Wrasse is taking place at borders and market places which is indicative of insufficient patrolling and enforcement and undermines existing trade regulations

Joyce Wu, a Senior Programme Officer with TRAFFICBetween 2010 and 2014, only one instance of illegal trade in live Humphead Wrasse was reported in Hong Kong: in 2010, a shipment of 53 live fish from Indonesia was discovered with a valid export permit for only 50. Three fish were seized and the remainder imported. 

Traders in Hong Kong and mainland China told the report’s authors that reef fish in general are smuggled from Hong Kong to mainland China by speedboat in order to circumvent high import tariffs, value added tax and stricter import requirements, while by avoiding the waiting time to obtain official documents, the risk of mortality is also reduced. 

“The research findings indicate that work is urgently needed to improve the monitoring and legality of Humphead Wrasse trade both in mainland China and into and through Hong Kong,” said Dr Yvonne Sadovy, co-Chair of IUCN’s GWSG and University of Hong Kong. 

“More collaboration is also needed with the source countries, especially Indonesia and Malaysia, because unregulated trade is threatening to deprive them of their natural resources and the livelihoods these support.”