Importing CITES-listed goods from the UK – procedures, documents and permits

Importing goods covered by the Washington Convention (CITES) from the United Kingdom to Poland is one of the most complex customs procedures in UK–EU trade. CITES — the Convention on International Trade in Endangered Species of Wild Fauna and Flora — governs international trade in wildlife species threatened with extinction. Since Brexit, the UK operates its own CITES regime, independent of the EU system. This means that every import from the UK of CITES-listed products requires two separate permits: one issued by APHA on the British side (as the exporting country) and one issued by GDOŚ on the Polish side (as the EU authority in the country of import). Unawareness of these requirements costs importers confiscated goods, fines and criminal proceedings. This article explains the complete process — from identifying goods as CITES-listed, through obtaining the permits, to the customs inspection.

The three CITES Appendices — what do they mean for an importer?

CITES classifies species into three Appendices, which determine the applicable trade regime:

CITES Appendix	Description	Trade from UK to Poland
Appendix I	Species threatened with extinction — commercial trade prohibited	Non-commercial purposes only, with exceptions (scientific research, ex-situ breeding). Requires both export and import permits
Appendix II	Species that could become threatened without trade controls	Trade permitted with an APHA export permit and a GDOŚ import permit
Appendix III	Species protected in selected countries	Requires an export certificate or certificate of origin

After Brexit, the United Kingdom retained its own CITES implementation — UK CITES (Species Specific Controls). The species list broadly mirrors the EU Annexes, but differences may exist; every case must therefore be verified against both databases: the CITES Trade Database (www.trade.cites.org) and the EU Wildlife Trade Regulations.

How to check whether your product is CITES-listed

Identifying goods as CITES-listed is the first and most important step. Tools for verification:

1. CITES Trade Database (trade.cites.org) — search by Latin or common name. The database shows the Appendix and trade history.

2. Species+ / UNEP-WCMC (speciesplus.net) — comprehensive database with information on all Appendices, EU-specific regulations and country annotations.

3. UK CITES Checker — GOV.UK provides a search tool for UK importers and exporters.

4. HS code — useful as a starting point, but insufficient on its own. Many CITES goods fall under broad HS codes (e.g. 9705 — zoological collections, 4205 — leather articles). An HS code alone does not definitively indicate CITES status.

Practical note: Many goods turn out to be CITES-listed unexpectedly. Always carry out verification before placing an order with a UK supplier.

Most common CITES goods in UK–Poland trade

Below is a list of products that regularly appear in trade and that importers mistakenly assume are not CITES-listed:

Product	Species / material	CITES Appendix
Vintage Fender, Gibson electric guitars	Dalbergia spp. (rosewood) — fingerboard	II
Jewellery containing coral	Corallium rubrum, Antipatharia	II/III
Snake or crocodile leather handbags	Crocodylus spp., Python spp.	I or II
Live exotic parrots	Psittacidae spp.	I or II
CITES orchids (wild, not hybrids)	Orchidaceae spp.	II
Spices from CITES plants (agarwood/oud)	Aquilaria spp.	II
Pharmaceutical preparations from musk deer	Moschus spp.	I or II
Antiques containing ivory	Loxodonta/Elephas	I (exceptions for antiques)

UK CITES permits — APHA and form FED0172

On the UK side, the CITES authority is APHA (Animal and Plant Health Agency), operating within DEFRA.

Procedure for obtaining a UK export permit:

1. Form FED0172 — "Application for a CITES permit, certificate or notification", available on GOV.UK. The exporter completes and submits it to APHA.

2. Information required on the form:

3. Scientific and common name of the species
4. Description of the goods (weight, dimensions, quantity)
5. Country of origin — may differ from the UK
6. Purpose of the transaction (commercial / non-commercial)

7. Source of the specimen (letter code: W — wild, C — captive-bred, D — bred on a commercial basis, etc.)

8. Processing time: APHA processes applications within 15–30 working days. Expedited (fast-track) applications are available for an additional fee.

9. APHA fees: standard permit — £63, fast-track — £95 (indicative rates, subject to change).

Polish CITES permits — GDOŚ

On the Polish side, the CITES authority is GDOŚ — the General Directorate for Environmental Protection. The importer must obtain an import permit before the goods are actually imported.

Documents required by GDOŚ:

• Completed application on the GDOŚ form (available at gov.pl)
• Copy of the APHA export permit (or a draft for the purpose of the application)
• Invoice or purchase contract
• Description of the goods (photographs recommended for specimens)
• Proof of legal acquisition (for Appendix I specimens — very detailed)

Processing time: Up to 30 calendar days. Before submitting an application it is worth consulting GDOŚ directly — they often require additional documents specific to the species concerned.

What a CITES permit must contain — key fields

A CITES permit (whether a UK export permit or an EU import permit) must contain:

1. Unique permit number
2. Scientific name of the species (binomial nomenclature)
3. Source of the specimen (letter code)
4. Description of the specimen (quantity, weight, identifying features)
5. Purpose of import/export
6. Country of export and country of import
7. Expiry date of the permit
8. Signature and stamp of the issuing authority

The customs officer at the border checks the matching numbers — the export permit number must correspond to the entry in the import permit. Any discrepancy in the species description (e.g. quantity) will result in the consignment being held.

Antiques with CITES materials — when is an exemption possible?

Objects made before 1947 may qualify for the antique exemption from CITES requirements under Article VII of the Convention. Conditions:

• The item must be clearly identified as having been made before 1 March 1947
• It must be manufactured from CITES material in such a way that it requires no further processing (e.g. an ivory carving, not raw ivory)
• Appropriate provenance documentation is required (antique dealer certificate, expert appraisal)

The antique exemption does not remove the obligation to make a customs declaration — a customs officer may still demand provenance documentation. In practice the exemption is difficult to establish and we recommend seeking advice before importing such items.

Penalties for importing without a CITES permit

Importing without the required CITES permits constitutes smuggling of protected species. In Poland, under the Nature Conservation Act, the penalties are:

• Confiscation of the entire consignment (goods forfeit to the State Treasury)
• A fine of up to PLN 1,000,000
• Criminal liability (up to 5 years' imprisonment for commercial-scale smuggling)

In the United Kingdom: confiscation plus an unlimited fine plus up to 7 years' imprisonment (COTES Regulations).