CITES and Caviar

A caviar shipment needs more than a label to cross a border. The registered operation behind it, the species inside and the accompanying documents all matter. Every shipment must satisfy both the Convention and the importing and exporting jurisdictions' implementing laws.

CITES regulates international trade in sturgeons, paddlefish and their products through species listings, permits and certificates. For caviar, it adds universal labelling and registration of processing and repackaging operations. The framework reaches right down to the primary container, but its label alone is not permission to trade.

What CITES and caviar trade rules cover

CITES governs international movements, not food safety or an ordinary domestic sale in itself. National laws can, however, extend CITES-related controls into domestic commerce, including caviar labelling.

The Convention on International Trade in Endangered Species of Wild Fauna and Flora is an international agreement. Its Parties are the states and regional economic integration organisations that have joined it, including the EU. National Management Authorities administer permits; Scientific Authorities advise on whether proposed trade threatens wild populations.

These wildlife controls operate alongside food, customs and animal-health requirements. None replaces the others. The regulation hub separates the systems.

Appendices and the listing history

The central distinction is between exceptional trade and regulated trade. Under Articles II to IV, Appendix I covers species threatened with extinction: trade is permitted only exceptionally, and imports under the ordinary Article III route must not be for primarily commercial purposes. Appendix II allows regulated trade when the required conservation and legality findings support it. Appendix III covers species protected by one Party seeking assistance from other Parties.

The Appendices effective from 5 March 2026 place shortnose sturgeon, Acipenser brevirostrum, and European sturgeon, Acipenser sturio, in Appendix I. Every other sturgeon and paddlefish falls under the order-wide Appendix II entry, Acipenseriformes spp., which excludes those two species. This defines wildlife-trade coverage, rather than a food standard for caviar.

The controls developed over decades:

• 1 July 1975: shortnose and Atlantic sturgeons were listed in Appendix I, and European sturgeon in Appendix II.
• 1979 and 1983: according to CITES, Atlantic sturgeon moved to Appendix II in 1979, and European sturgeon to Appendix I in 1983.
• 11 June 1992: American paddlefish entered Appendix II.
• 1 April 1998: the listing of the remaining sturgeons and paddlefish took effect.

The listing history traces how the 1998 measure extended an existing system, rather than introducing the first sturgeon controls.

Permits, findings and validity

Legal acquisition and biological sustainability are separate tests. An Appendix II export normally needs an export permit issued before shipment. The exporting Scientific Authority makes a non-detriment finding, assessing whether the export would harm the species' survival. The Management Authority must separately be satisfied that the specimens were legally acquired.

For Appendix I, the ordinary route starts with an import permit, issued before the export permit. The importing authorities must make the required conservation finding and be satisfied that the specimens will not be used for primarily commercial purposes. Appendix II requires no import permit under the Convention itself, although destination law may demand one. Captive production does not automatically remove documentation requirements: the applicable route and any exception depend on the species and documented source.

Re-export means exporting something previously imported. Before issuing its certificate, the re-exporting Management Authority must be satisfied that the earlier import complied with CITES. That certificate does not authorise a fresh harvest, and repackaging leaves the roe's country of origin unchanged.

Resolution Conf. 12.3 (Rev. CoP20) sets maximum validity at six months for export permits and re-export certificates. The document must be valid when the specimens are exported or re-exported. Import permits have a maximum validity of twelve months. These document limits are separate from the deadline specifically governing caviar re-export.

A shared sea does not mean a shared export authorisation: check the jurisdiction, stock, year and any relevant published quota.

Sturgeon assessments require evidence suited to the stock and production system; simply describing caviar as farmed is insufficient. Source coding is a separate technical task. The source code guide distinguishes ranched source R from captive sources F and C.

The sturgeon resolution: labels and registered plants

Every primary container, the container directly touching the caviar, receives a non-reusable label under the system. Behind that label sits a registered processing or repackaging operation.

The specialist framework remains Resolution Conf. 12.7 (Rev. CoP17), identified in the European Commission's sturgeon guidance. Annex 1 contains the universal labelling guidelines, Annex 2 the species codes, and Annex 3 a list of shared stocks and their species. The resolution's recommendations are distinct from the binding laws through which individual jurisdictions implement them.

National authorities register processing and repackaging plants and communicate their details to the Secretariat. Registration attaches to the relevant operation and facility, rather than every brand, retailer or corporate owner in the supply chain.

Repackaging requires a new label identifying the repackaging operation while preserving the original species, source and origin information. Hybrid species codes put the male parent's code first and the female parent's second, separated by x. The caviar code guide explains each field and keeps repacking location distinct from origin.

US law expressly requires caviar re-export within 18 months of the original export permit's issue date. EU Regulation 865/2006 and the corresponding Great Britain legislation impose the same 18-month limit. US law also requires label information on the CITES document or an attached annex, together with the quantity of each species.

A CITES label provides traceability, not authentication: it records a declared identity, but cannot establish the tin's biological contents.

Shared wild stocks and export quotas

A shared sea does not mean a shared export authorisation: check the jurisdiction, stock, year and any relevant published quota. Iran, Kazakhstan and Russia must each be considered as individual range and export jurisdictions, rather than treated as one Caspian authorisation.

For wild stocks shared between countries, the sturgeon resolution provides for cooperation on conservation, monitoring, and catch and export quotas. Importers must check the applicable requirements as well as those quota details. An Appendix II listing alone does not settle those questions.

The US implementing rule additionally specifies export within the harvest and processing quota year, which runs from 1 March to the last day of February. This shared-stock mechanism is distinct from any notion of a universal annual quota on all farmed caviar.

The CITES export quota database publishes 2026 wild caviar entries, including zero quotas for specified Russian Caspian and Azov stocks. Those entries establish neither a worldwide ban nor permission to export. A proposed wild shipment needs direct confirmation from the authorities and the current quota publication.

Where domestic rules are stricter

Meeting the CITES minimum does not guarantee entry at the destination. Article XIV allows stricter domestic measures, including restrictions or prohibitions on trade, taking, possession and transport.

For China, Japan, Russia, UAE, Iran and Kazakhstan, the table gives the treaty baseline, not the full national requirements. Before shipment, check national import permissions and export restrictions with the destination or dispatching Management Authority.

For travellers, the CITES personal effects recommendation covers up to 125 g per person of Appendix II caviar, in individually marked containers bearing CITES labels, where the relevant jurisdictions recognise the exemption. This is a personal effects provision, not a commercial allowance. National prohibitions and biosecurity rules apply separately; Australia's legislation, for example, specifies accompanied baggage and personal use.

What changed at CoP19 and CoP20

CoP19 Decisions 19.175 and 19.176 addressed evaluation of caviar labelling, including QR codes. At its February 2025 meeting, the Standing Committee considered those decisions implemented, proposed their deletion and encouraged interested Parties to pilot QR codes and report to its 81st meeting.

The post-CoP20 Decisions index no longer lists those decisions and contains no separate sturgeon entry. This does not establish a new universal QR-code obligation: the continuing resolution and each jurisdiction's implementing rules remain the operational starting points.

Animals Committee records document sturgeon conservation and specimen identification work, including AC30 agenda items 17.1 and 17.2 in 2018. No current sturgeon-specific Review of Significant Trade case is documented; that earlier work should not be presented as an active case.

Using the register and trade database

Start with the legal operation and facility, not the brand on the tin. The public register identifies notified caviar operations and their registration details. It does not list every retailer, establish farm ownership or confirm that a particular shipment has a valid permit. The producer register guide explains how to make the match.

The CITES Trade Database answers a different question: what trade have Parties reported? Its annual-report records can be searched by species, partners, source, purpose, product and year. Use it to examine declared trade patterns, rather than to check a tin in real time.

Read those records with reporting delays, differing reporting practices and importer-exporter discrepancies in mind. Re-exports must also be separated from new production.

For a working file, retain the permit or certificate, the relevant label information, evidence connecting the consignment to the registered operation, and any required quota confirmation. Record the jurisdiction, rule version and check date together. That gives a later re-export assessment a clear record of the original import.