Although the Parties at CITES CoP16 adopted Resolutions that expressly provide that the year of take, not the year of export or both, should be on the export permit for leopard and elephant trophies, that is not yet the regulation in the United States. The US Fish & Wildlife Service (USFWS) has not yet published a report of the 16th CoP and has not itself published a change in its own regulations. Of course, the Director of Law Enforcement can issue an interpretive letter or directive to port Law Enforcement inspectors, but has not yet done that either.
At the recent meeting of the International Affairs committee of the Association of Fish and Wildlife Agencies, yours truly asked representatives of the Division of Management Authority and International Affairs of USFWS to issue a letter of interpretation or other steps to prevent new seizures from the confusion, but nothing has been forthcoming.
In short, it is best to continue with double quotas until there is official notice to the contrary from responsible authorities in the USFWS.
The USFWS is expected to publish a post-CoP16 summary in the Federal Register. When it does, perhaps it will provide a statement that all concerned persons can rely upon.
That said, the USFWS does seem to be undergoing an improvement in attitude after several years of “no excuses” enforcement. In May we were able to get four different leopards released that had been seized for technical errors, and only one new leopard was seized. It is something to celebrate, and we hope it continues.