Is CITES PC28 supporting GBF Target 5?

A look at the 28th meeting of the CITES Plants Committee (Geneva, 17–23 July 2026) through the lens of the Kunming–Montreal Global Biodiversity Framework’s Target 5.

GBF Target 5

Target 5 of the Global Biodiversity Framework (GBF), adopted under the Convention on Biological Diversity (CBD), calls for the use, harvesting and trade of wild species to be sustainable, safe, and legal. It aims to prevent overexploitation, minimise impacts on non‑target species and ecosystems, and reduce risks associated with wildlife trade. Because CITES regulates international trade in CITES0-listed wild fauna and flora, it is one of the principal mechanisms through which Target 5 is implemented in practice.

The 28th meeting of the CITES Plants Committee (PC28) provides a clear window into how CITES’ technical work aligns with Target 5, even if the Committee never uses GBF terminology. PC28’s agenda covers the issues Target 5 is meant to govern, e.g., timber and rosewood trade, medicinal plants in e‑commerce, non‑detriment findings, and compliance challenges in high‑risk range States. The question is whether this work substantively advances Target 5’s “sustainable, safe and legal” criteria.

No explicit reference at PC28

A search of PC28’s documents for “Target 5” or “Global Biodiversity Framework” yields no substantive results. This is unsurprising as CITES and the CBD operate under separate mandates with distinct decision‑making processes and technical vocabularies. PC28 speaks in terms of Non‑detriment Findings (NDFs), the Review of Significant Trade (RST), annotations, source codes, and nomenclature –  not GBF Targets.

The absence of explicit reference, however, does not mean the absence of substance. Much of PC28’s work is directly relevant to Target 5, even if framed in CITES terms. This is supported by the only explicit reference to the GBF in PC28 documents. This occurs in the preambular section of the Draft Resolution on Medicinal and Aromatic Plants (PC28 Doc. 25 Annex 3) which highlights GBF Goals A, B and C, and Targets 4, 5, and 9 and 13.

How PC28 supports Target 5

Sustainable. The Country‑wide Review of Significant Trade (RST) (AC34 Doc. 12 / PC28 Doc. 12) is effectively a rolling sustainability audit of plant species in international trade. Over 40 species/country combinations are currently under review, many of them plants such as:

  • African blackwood (Dalbergia melanoxylon) in Mozambique and Tanzania
  • African cherry (Prunus africana) in Equatorial Guinea
  • African rosewood (Pterocarpus erinaceus) across eight range States
  • East African sandalwood(Osyris lanceolata) in Burundi and Ethiopia

Six range States –  Benin, Ghana, Madagascar, Mali, Mozambique, and the Solomon Islands – are identified as most in need of targeted capacity‑building due to recurring NDF challenges. This is Target 5’s sustainability criterion applied directly to specific taxa and trade routes.

The Non‑detriment Findings agenda item (AC34 Doc. 17 / PC28 Doc. 15) reinforces this. The new CITES NDF guidance includes modules for timber, orchids, and other plant groups, and is undergoing review based on feedback from the Parties and field‑testing. An intersessional working group is proposed to maintain and update the guidance. This is core Target 5 work – improving the scientific basis for determining whether trade is sustainable.

Further, the proposed amendments to Resolution Conf. 9.24 (AC34 Doc. 44 / PC28 Doc. 28) would introduce a formal risk‑assessment requirement into all future listing proposals. This would encourage Parties to consider assess more explicitly the likely conservation consequences of proposed trade measures leading to a more explicit operationalisation of Target 5’s sustainability logic.

Legal. The most direct link to Target 5’s “legal” criterion is the study on medicinal and aromatic plant (MAP) species in trade (PC28 Doc. 25). It documents:

  • the use of social media and online marketplaces to advertise and sell MAP products;
  • gaps in traceability and identification; and
  • the need to cross‑reference MAP trade with wildlife‑cybercrime provisions in Resolution Conf. 11.3.

This is a plant‑specific extension of Target 5’s legality requirement into e‑commerce – a channel that is rapidly expanding and poorly regulated.

Beyond MAPs, PC28’s compliance‑related agenda items sit squarely within Target 5’s legality criterion. The RST process remains the primary mechanism for identifying and correcting unsustainable or illegal trade.

Safe. Target 5’s “safe” criterion focuses on reducing pathogen spillover risk from wildlife trade. This concern maps naturally onto live animal trade but often not onto plants. PC28’s agenda reflects this asymmetry.

There is no plant‑specific equivalent to the Animals Committee’s discussions on zoonotic risk. The closest analogue is probably the item on specimens produced through biotechnology (AC34/PC28 Comp.), which deals with identification and regulation of biotechnologically produced specimens. This is a trade‑control issue, however, and not a spillover‑risk issue.

For plants, Target 5’s “safe” dimension is essentially unaddressed — not because PC28 is neglecting it, but because the risk profile of plant trade differs fundamentally from that of animals. That said, some CITES‑listed plants used medicinally do pose toxicological risks when misused, such as Himalayan yew (Taxus wallichiana), Indian Snakeroot (Rauvolfia serpentina), or the African cherry (Prunus africana).  Such risks, however, fall outside PC28’s current mandate and agenda.

Linked but not in sync

As with the Animals Committee, PC28 is not itself making decisions framed in GBF terms. The most direct institutional link to the GBF is the CITES response to the IPBES Sustainable Use of Wild Species Assessment (Decisions 20.15 and 20.16). This is being led by the Standing Committee (SC) and PC28’s role is limited to nominating representatives to the intersessional working group.

The proposed amendments to Resolution Conf. 9.24, however, introduce a new tension. By recognising that “well‑regulated trade rather than trade prohibitions may represent the more precautionary and effective conservation measure,” they could be seen as strengthening Target 5’s sustainability logic or, alternatively, as shifting the burden of proof toward justifying restrictions. This debate will continue in the intersessional working group.

Ecosystem and non‑target species impacts which are also part of Target 5 appear only indirectly, mainly through habitat and trend information required in listing proposals. They are not addressed as standalone agenda items.

Enhancing policy coherence

Sustainable Development Goal target 17.14 calls on governments to enhance policy coherence for sustainable development. On that measure, PC28 supports GBF Target 5 in substance, though not in name:

  • The Review of Significant Trade operationalises “sustainable;”
  • The NDF guidance strengthens scientific decision‑making;
  • The MAPs study extends “legal” into e‑commerce; and
  • The “safe” criterion remains largely irrelevant to plant trade.

The clearest formal pathway to GBF alignment, however, sits one level up, with the SC’s IPBES working group. Whether that process will eventually reshape how the Plants Committee operates remains an open question to be further considered at SC81 in November.

By Francis Vorhies

Also see: CITES AC34 & PC28 – Earthmind

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